Madison County District Court, Texas Pre-Motion Conference Requirements

CRITICAL

Before filing a motion, movant’s counsel must personally attempt to confer with opposing counsel, except for the listed dispositive motions and motions related to service of citation.

Prior to the filing of a motion, movant's counsel must personally attempt to confer with opposing counsel to resolve the disputed matter(s). Rule 3.15.7 does not apply to dispositive motions, including motions for summary judgment, default judgment, voluntary dismissal or nonsui! post-verdict motions, or motions related to service of citation.

CRITICAL

A discovery motion may be deemed premature unless counsel makes a good-faith effort to resolve the dispute, complies with the Texas Rules of Civil Procedure or shows good cause, and includes the required proposed order and Certificate of Conference.

A discovery motion may be deemed premature unless the movanfs counsel has: (1) made a good faith attempt to obtain the discovery or requested relief by agreement with opposing counsel; (2) complied with the Texas Rules of Civil Procedure and either was unsuccessful or demonstrates good cause fornot doing so; and (3) included a proposed order and a Certificate of Conference in accordance with Rule 3.L5.7.

CRITICAL

Before filing a motion, movant’s counsel must personally attempt to resolve the dispute with opposing counsel, and the motion must include a certificate of conference signed by movant’s counsel, subject to stated exceptions.

4.1,8.7 Conference requirement. No party may file a motion without attaching a "certificate of conference" signed by movant's counsel. Prior to the filing of a motion, movanfs counsel must personally attempt to confer with opposing counsel to resolve the disputed matter(s).

WARNING

Parties are directed to use all reasonable means to resolve pretrial disputes without judicial intervention.

4.18.1 Resolution. Parties are directed to use all reasonable means to resolve pretrial disputes to avoid the necessity of judicial intervention.

WARNING

The parties may waive a motion hearing if all counsel of record agree and notice is provided to the court.

4.18.6 Waiver of hearing. Hearings on any motion may be waived with the agreement of all counsel of record, provided that notice is provided to the court.

WARNING

A discovery motion may be deemed premature unless counsel has made a good-faith effort to obtain discovery or relief by agreement, complied with the Texas Rules of Civil Procedure or shown good cause for not doing so, and included a proposed order and a certificate of conference under Rule 4.18.7.

4.19.1 Discovery motions. A discovery motion may be deemed premature unless the movanfs counsel has: (1) made a good faith attempt to obtain the discovery or relief by agreement with opposing counsel; (2) complied with the Texas Rules of Civil Procedure and either was unsuccessful or demonstrates good cause for not doing so; and (3) included a proposed order and a Certificate of Conference in accordance with Rule 4.18.7.

WARNING

Parties are directed to use all reasonable means to resolve pretrial disputes before seeking judicial intervention.

Parties are directed to use all reasonable means to resolve pretrial disputes to avoid the necessity of judicial intervention.

INFO

The court routinely grants unopposed motions without a hearing unless the judge determines that doing so would not serve the interests of justice.

The court will routinely grant unopposed motions without a hearing, unless the judge determines that granting the motion would not serve the interests of justice.

INFO

Parties may submit matters for a ruling without appearing personally or making an oral presentation.

Parties may submit matters for ruling by the judge without a personal appearance or oral presentation.