Harris County District Courts Document Filing Requirements

WARNINGCivil cases

Applies to

Minor settlement

Must include

proposed order

For settlements involving minors with conflict of interest, parties must submit agreed motion/order for Guardian Ad Litem, and at hearing present proposed judgment and ad litem fee report.

A Guardian Ad Litem will be required for all settlements involving minor children. This applies when there is a conflict of interest between the minor(s) and the parent or legal guardian. The parties are to submit an agreed motion and order for appointment of a Guardian Ad Litem. The Court will then select the Guardian Ad Litem for that case, and will inform the parties of the Court's decision. Once a Guardian Ad Litem has been appointed, the parties may contact the Court Clerk in order to obtain a Minor Settlement hearing date. At the time of the hearing, the parties are to present the proposed Judgment, as well as the Supreme Court ad litem fee report.

WARNINGCivil cases

Applies to

Notice of submission

When setting a matter on submission docket, file notice of submission with exact motion titles and serve on all parties.

If you set a matter on the submission docket file a notice of submission with the exact title of the motion or motions set for consideration and serve it on all counsel and self-represented parties.

WARNING

Applies to

Opposed motion

The clerk must not submit noncompliant opposed motions to the judge, except that this requirement does not apply to the listed motion types.

The clerk of each court is directed not to submit opposed motions to the judge which do not comply with this rule. The provisions of subparts 5.1.2 and 5.1.3 do not apply to motions for summary judgment, default judgments, agreed judgments, motions for voluntary dismissal or non suit, and motions involving service of citation.

WARNING

Applies to

Final order

When staff are available, a DRO staff attorney shall review the final order or decree and any necessary attachments or other documents.

As available, the DRO staff attorney shall review the final order/decree, any necessary attachments, and any other necessary documents.

WARNING

Applies to

Exhibits

Rebuttal or impeachment exhibits not exchanged before the hearing must respond to a matter raised by the other side.

Rebuttal or impeachment exhibits that were not exchanged before the hearing must be responsive to a matter raised by the other side.

WARNING

DRO review is available only when a qualifying family law case is pending in Harris County, is uncontested by agreement or default, and neither party is represented by an attorney.

Required criteria: - *A petition for divorce, a suit affecting parent child relationship, or other family law case is currently pending in Harris County.* - *The suit is uncontested, either by agreement (decree/order is signed by the other party) or default (other party has signed a global waiver or has been served and failed to file an answer following the prescribed time-period); and* - *Neither party to the suit is presently represented by an attorney.*

WARNINGCivil cases

Applies to

Pleading

Must include

exhibit list

When e-filing, type the full pleading title in the description field, label exhibits clearly, avoid all caps, and file each exhibit separately.

When filing documents, please type the entire title of your pleading in the description field and clearly label all exhibits. Do not use all caps. Each exhibit should be filed separately.

WARNINGCivil cases

Applies to

Minor settlement hearing

At the minor settlement hearing, parties must present the proposed Judgment and the Supreme Court ad litem fee report.

At the time of the hearing, the parties are to present the proposed Judgment, as well as the Supreme Court ad litem fee report.

WARNINGCivil cases

Applies to

Notice of oral hearing

The notice of oral hearing must state the exact title of the motion or motions to be heard.

The hearing notice must state the exact title of the motion or motions to be heard.

WARNING

Applies to

Deposition designations

Deposition page/line designations and a non-condensed transcript copy must be furnished to the court reporter before the offer, and readers must announce 'Question' and 'Answer' when reading deposition testimony.

Page/line designations of deposition testimony, along with a non-condensed copy of the transcript, are to be furnished to the court reporter prior to the offer. When one person is reading from written deposition testimony, the reader must say “Question” prior to reading each question and “Answer” prior to reading each answer.

WARNINGCivil cases

Applies to

Courtesy copy

Must include

proposed order

Courtesy copies must include the proposed order, latest live pleading and answer, latest DCO, and any legal authority.

Also include a copy of the proposed order, latest live pleading and answer, latest DCO, and any legal authority, with any courtesy copy provided to the court.

WARNINGCivil cases

Applies to

Order of severance

The proposed Order of Severance must include specified details about styling, cause number, parties, pleadings, disposition, and costs.

The proposed Order of Severance should include the following: how the severed case is to be styled; the cause number; the parties to be included in the severed case; all the pleadings that are to be severed into the new file; whether the Order disposes of the severed case, or whether it will remain an active case; and who will pay for the costs of severance.

WARNINGCivil cases

Applies to

Discovery motion

Must include

proposed order

Discovery proposed orders must list each issue separately, and both movant and non-movant must submit a proposed order.

Proposed orders should list each discovery issue separately. Both the movant and non-movant must submit a proposed order.

WARNING

Applies to

Business card

Attorneys must identify themselves to the Judge and court reporter before a hearing and provide a business card with contact details and party representation.

Identify yourself to the Judge and the court reporter before a hearing begins. Provide a business card with your name, correct address, phone number, fax number and e-mail address. Also include party representation.

WARNINGCivil cases

Applies to

Motion to retain

Must include

proposed order

A proposed order must be e-filed with a Motion to Retain.

Please e-file a proposed Order to accompany your Motion.

WARNINGCivil cases

Applies to

Severance motion

A motion for severance must state the basis for the severance.

The motion must state the basis for the severance.

WARNINGCivil cases

Applies to

Motion

By requesting a preferential setting, counsel agrees to waive all vacation letters for that time period.

Counsel understands that by requesting a preferential setting, they agree to the following:To waive all vacations letters for that time period.

WARNINGCivil cases

Applies to

Guardian ad litem application

Guardian ad litem applicants must affirm that professional liability coverage is in effect and will remain current.

Applicants must also affirm that professional liability coverage is in effect and will remain current.

WARNINGCivil cases

Applies to

Motion

Both parties must agree to a preferential setting request and file a motion with the court.

Both parties must agree to the request and file a motion with the court.

WARNINGCivil cases

Applies to

Motion

The Motion to Request a Preferential Setting must include the basis for the preferential setting (e.g., out-of-town witnesses, trial will take two weeks or longer).

The Motion to Request a Preferential Setting must include the basis for the preferential setting (i.e out of town witnesses, will take two (2) weeks or longer to try.)

WARNING

Applies to

Proposed order

The order granting substituted service should conform to the prescribed form.

The Order granting the substituted service should comport with this form to be found here.

WARNINGCivil cases

Applies to

Guardian ad litem application

Applicants for the guardian ad litem list must submit a written request with a complete resume detailing their civil trial experience and any special capabilities.

Those wishing to be included in the Court’s list must submit a written request with a complete resume that details the nature of the applicant’s experience as a civil trial practitioner. Special capabilities, such as fluency in languages other than English, financial background, and the like, should also be listed.

WARNING

Applies to

Proposed order

The proposed order on a discovery motion should list each discovery issue separately so the court may rule on each.

The proposed order should list each discovery issue separately so that the court may deny or grant each issue.

WARNING

Applies to

Proposed order

Orders on motions to withdraw must include contact information for the pro se litigant.

Orders on motions to withdraw also must include contact information for the pro-se litigant.

WARNING

Applies to

Jury questionnaire

Do not bring a jury questionnaire to the first day of trial.

Do not bring a jury questionnaire to the first day of trial.

WARNING

Applies to

Motion to substitute counsel

Must include

certificate of conference

Motions to substitute counsel require signed signature blocks of outgoing and incoming attorneys, or a certificate of conference showing agreement; if not agreed, a hearing is required.

Parties need to have a signed signature block of the outgoing & incoming attorney or attach a Certificate of Conference stating all parties are in agreement of substitution. If not agreed by all, this will need to be set for a hearing.

WARNING

Applies to

Motion

The Court will pass (not consider) motions whose certificate does not state either that the movant talked to opposing counsel or why counsel could not discuss the motion.

The Court will pass motions that do not have a certificate stating (1) that the movant has actually talked to opposing counsel, or (2) why counsel have not been able to discuss the motion.

WARNING

Applies to

Motion in limine

Motions in Limine should not duplicate the Court's standing Order in Limine and should be limited to case-specific items.

The Court has adopted a standing Order in Limine applicable to all cases. Do not duplicate these items in your Motions in Limine. Your motion should be limited to only those items specific to the facts and circumstances in your case.

WARNING

Applies to

Trial binder

The trial binder should contain the motion in limine, exhibits, exhibit lists, witness lists, and page line designations.

The trial binder should contain the motion in limine, exhibits, exhibit lists, witness lists, and page line designation.

WARNING

Applies to

Motion

A certificate stating only that a letter/email was sent with no response is not a proper certificate of conference.

A certificate of conference stating that you sent a letter or email to opposing counsel and received no response is not a proper certificate of conference.

WARNING

Applies to

Minor settlement

Must include

proposed order

A Guardian ad Litem is required for all settlements involving minor children; parties must submit a motion and order to request one, and the minor must be present at the settlement hearing.

A Guardian Ad Litem will be required for all settlements involving minor children. The parties must submit a motion and order to request a Guardian Ad Litem. * Minor must be present for the minor settlement hearing.

WARNING

Applies to

Motion to withdraw

When the withdrawing attorney represents a corporation, counsel must notify the corporate party that corporations cannot proceed pro se in Texas courts.

If the withdrawing attorney represents a corporation, counsel must notify the corporate party that corporations cannot proceed pro-se or self-represented in Texas courts.

WARNINGCivil cases

Applies to

Motion

Ex parte motions must be labeled as ex parte in the title of the motion.

Ex Parte Motions (Please label as ex parte in the title of the motion.)

WARNINGCivil cases

Applies to

Motion

When filing documents, the exact name as it appears on the pleading is to be used. The name of the pleading appears on the search results or summary page for the case. To simplify the search results page, please limit the title of documents to no more than 10 words, unless additional words are absolutely necessary.

When filing documents, the exact name as it appears on the pleading is to be used. The name of the pleading appears on the search results or summary page for the case. To simplify the search results page, please limit the title of documents to no more than 10 words, unless additional words are absolutely necessary.

WARNINGCivil cases

Applies to

Objections

The deposition itself must be submitted when filing objections.

When filing objections the deposition itself must be submitted.

WARNINGCivil cases

Applies to

Proposed order

Proposed orders for discovery motions should list each discovery issue separately.

Proposed orders should list each discovery issue separately.

WARNINGCivil cases

Applies to

Proposed order

Proposed orders for special exceptions should list each exception separately.

Proposed orders should list each exception separately.

WARNINGCivil cases

Applies to

Proposed order

Proposed orders on motions to compel and special exceptions should delineate each item.

Proposed orders on motions to compel and special exceptions should delineate each item.

WARNINGCivil cases

Applies to

Motion

Agreed and unopposed motions must be labeled as such in the title of the motion.

Agreed/Unopposed Motions (Please label as such in the title of the motion.

WARNINGCivil cases

Applies to

Motion

Sanctions should not be requested unless the opponent has violated a previous order. Instead, ask for reimbursement of your costs in the form of attorney fees.

Sanctions should not be requested unless the opponent has violated a previous order. Instead, ask for reimbursement of your costs in the form of attorney fees.

WARNINGCivil cases

Applies to

Motion

If the motion title includes 'emergency', no separate emergency hearing request is needed.

If the motion itself includes "emergency" in the title, there is no need to file a separate request.

WARNINGCivil cases

Applies to

Special exception proposed order

Parties are encouraged to quote the challenged paragraphs verbatim in the proposed order and provide a sustained/overruled choice for each exception.

Parties are encouraged to restate verbatim the paragraph(s) to which your special exceptions apply in the proposed order and provide blanks in which the Court may check "sustained" or "overruled" as to each separate matter to which the movant is specially excepting.

WARNINGCivil cases

Applies to

Motion

Must include

proposed order

The Court may pass a hearing on a motion filed without a proposed order.

The Court may pass any hearing on a motion filed without a proposed order.

WARNINGCivil cases

Applies to

Certificate of conference

If the other side could not be reached before filing, the certificate should describe communication efforts and be supplemented as soon as possible after the parties confer.

If a party was unable to reach the other side prior to filing the motion, the certificate should state the efforts to communicate with that party and should always be supplemented as soon as possible after the parties have actually conferred.

WARNINGCivil cases

Applies to

Dismissal

Dismissals should be filed with prejudice.

All dismissals should be filed with prejudice.

WARNINGCivil cases

Applies to

Filing with exhibits

Exhibits should be indexed.

Please index your exhibits.

WARNINGCivil cases

Applies to

Unopposed or agreed motion

All unopposed or agreed motions should be titled as such.

All unopposed or agreed motions should be titled as such.

WARNINGCivil cases

Applies to

Non suit dismissal or judgment

Non-suits, dismissals, and judgments should be titled interlocutory or final; interlocutory orders should identify dismissed and remaining parties and claims.

All non-suits, dismissals and judgments should be titled as interlocutory or final. Interlocutory orders should expressly list which parties and claims are being dismissed and which remain, if any.

WARNINGCivil cases

Applies to

Agreed motion and order

If a motion is actually agreed, the motion and order should contain signature blocks for all parties that are agreed to the relief requested and should state “AGREED AS TO SUBSTANCE AND FORM AND ENTRY REQUESTED” above the signature block.

If a motion is actually agreed, the motion and order should contain signature blocks for all parties that are agreed to the relief requested and should state “AGREED AS TO SUBSTANCE AND FORM AND ENTRY REQUESTED” above the signature block.

WARNINGCivil cases

Applies to

Motion

Must include

proposed order

Motions should be accompanied by an order.

All motions should be accompanied with an Order.