Judge Vince Santini
Individual Rules, Standing Orders & Policies
- Rules last changed:
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Chambers
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Document Format Requirements2 rules
When an attorney or self-represented litigant uses generative AI in work product, research, or drafting, the required verification must be in bold in their pleadings.
Court's wording
As a result of Generative AI’s tendency to fabricate and malfunction, the Court hereby ORDERS any attorney or self-represented litigant that chooses to use Generative AI in their work product, research, or drafting must include the following verification in bold in their pleadings:
Do not attach written discovery, objections, or responses to the motion or response unless needed to show an inaccurate quotation; in that case attach only the necessary pages and highlight the error.
Court's wording
Please do not attach copies of the written discovery or the objections and responses to the written discovery to the electronically filed motion or response except as necessary to evidence a failure to accurately quote a discovery request, objection, or response. In that event, attach only the page(s) necessary to evidence the error and highlight the error on the page(s) attached.
Document Filing Requirements15 rules
The proposed order must set out each disputed discovery request by its propounded number, list each objection or deficiency below it, and leave space for the Court’s rulings.
Court's wording
The Movant will prepare a proposed Order in which each disputed discovery request, identified by its number as propounded, is set forth and below which each discrete objection or deficiency is set forth, and leaving space below each discrete objection or deficiency in which the Court will make its rulings.
Immediately below the quoted discovery materials, the motion must state concise argument and authority addressing each disputed objection and deficient response.
Court's wording
Immediately below the matters described in (1), above, the Movant will succinctly state argument and authority pertaining to, as applicable: Each discrete objection as to why that objection should be overruled, and Each discrete response as to why the response is deficient.
After scheduling a submission date, send notice under the specified local rules unless they are inconsistent with this Order.
Court's wording
Motions to Compel discovery are considered on the 457th District Court’s submission docket. Please contact the Court (936-538-3697) in order to schedule a submission date, then please send notice in compliance with the Local Rules of the District Courts of Montgomery County, Texas, and, in particular, with Rule 3.7 Hearings on Pre-Trial, subparts B and C, to the extent those Rules are not inconsistent with this Order.
In response to the Motion to Compel, and with respect to each discrete objection or response, Respondent shall succinctly state Respondent’s argument and authority as to why, as applicable, an objection should be sustained or a particular response is adequate.
The motion must identify each disputed discovery request by its propounded number and reproduce the request, each objection, and each answer or response verbatim.
Court's wording
The Movant will prepare a Motion to Compel, identifying each separate discovery request about which there is controversy set forth by its number as propounded, and: Writing the discovery request verbatim, Writing each objection made to that request by the Respondent verbatim, and Writing each answer or response made by the Respondent to that request verbatim.
In the case of a Motion to Compel as to written discovery to which a responding party has wholly failed to timely respond, a simple Motion so stating which provides the date(s) the written discovery was served and a simple proposed Order granting the Motion will suffice:
For motions to compel answers to unanswered or deficient oral-deposition questions, follow the procedures in B(1)–(8), using deposition page and line references instead of discovery-response numbers.
Court's wording
If a party seeks a Motion to Compel responses to questions lodged in an oral deposition which the Deponent did not answer or whose answers were deficient, then the Movant must follow the procedures in (B)(1)-(8), modified only insofar as the Movant shall provide deposition page and line references (as opposed to providing the number of the discovery response).
It is further ORDERED that if a document must contain unredacted sensitive data, then the filing party must notify the clerk by marking it “NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA”, and the District Clerk may, without further order of the Court, restrict any document so marked from being posted on the internet.
Documents containing Protected Health Information that are filed or offered in Court must redact six specified patient identifiers.
Court's wording
It is further ORDERED that if any Protected Health Information will be used as a filing in a case or as a document offered in Court for any purpose, then the party filing or proffering the document containing Protected Health Information must redact the patient’s (1) name, (2) birthdate, (3) social security number, (4) driver’s license or government identification card number, (5) address, and (6) telephone number.
IT IS FURTHER ORDERED that, upon completion of the ADR procedure, the ADR provider/impartial third party is directed to advise this Court, in a writing filed with the Clerk, when the process was completed, whether the parties and their counsel appeared as ordered, and whether a settlement resulted.
IT IS FURTHER ORDERED that a statement of the fees charged and the amounts each party paid shall be filed with the District Clerk by the ADR provider/impartial third party for inclusion in the Bill of Costs.
An attorney or self-represented litigant who uses generative AI in work product, research, or pleading drafts must include the specified verification in their pleadings.
- Document
- Pleading
Must include
- •AI disclosure
Court's wording
As a result of Generative AI’s tendency to fabricate and malfunction, the Court hereby ORDERS any attorney or self-represented litigant that chooses to use Generative AI in their work product, research, or drafting must include the following verification in bold in their pleadings: “Verification Regarding Use of Generative Artificial Intelligence My name is ____________________, my address is _________________________, I am over 18 years of age, of sound mind, and capable of making this verification. I swear under penalties of perjury that the statements contained in this verification are true and correct and
A pleading prepared using Generative AI must contain the above verbatim verification in bold or it will not be considered.
- Document
- Pleading
Include
- •AI disclosure
- •The above verbatim verification in bold
Court's wording
If an attorney or self-represented litigant uses Generative AI in their work product, research, or drafting of a pleading and that pleading fails to contain the above verbatim verification in bold, it will not be considered by the Court.
It is further ORDERED that if all of the above listed items (1)-(6) are not redacted from any document containing Protected Health Information which is filed in a case, then the District Clerk may, without further order of the Court, restrict any such unredacted document from being filed and require the filing party to provide a conformed copy of the document with redactions in its stead.
It is further ORDERED that if the above listed items (1)-(6) are not redacted from any document containing Protected Health Information offered in Court for any purpose, then the Court may reject the offer of such document, the admission of such document, or both, and may require offering a conformed copy of the document with the redactions in its stead.
Filing & Service rules
Electronic Filing Rules
The movant must electronically serve and file the motion with a Notice of Submission and provide the respondent an electronic or emailed Word or WordPerfect copy.
The Movant shall electronically serve and file the Motion to Compel along with a Notice of Submission in the usual manner, and shall also email or otherwise electronically serve a copy of the Motion in Word or WordPerfect format on the Respondent.
Civil cases
Page 1 | B. USE OF A SINGLE DOCUMENT FOR MOTIONS TO COMPEL WHERE A RESPONSE WAS MADE
The proposed order must be electronically served and filed, and a Word or WordPerfect copy with the specified filename must be emailed to the provided address.
The proposed Order will be electronically served and filed in the usual manner, and a copy of the proposed Order in Word or WordPerfect format with the file named ”[Case Number] - Proposed Order – [Name of Party] Motion to Compel” will be emailed to david.kallus@mctx.org.
Civil cases
Page 1 | B. USE OF A SINGLE DOCUMENT FOR MOTIONS TO COMPEL WHERE A RESPONSE WAS MADE
If the Movant wishes to do so, the Movant may prepare a succinct Reply to each discrete response immediately below that particular response and will electronically serve and file any such Reply in the usual fashion.
If the Movant wishes to do so, the Movant may prepare a succinct Reply to each discrete response immediately below that particular response and will electronically serve and file any such Reply in the usual fashion.
Civil cases
Page 2 | B. USE OF A SINGLE DOCUMENT FOR MOTIONS TO COMPEL WHERE A RESPONSE WAS MADE
The respondent must electronically file and serve the response and provide the movant an electronic or emailed Word or WordPerfect copy.
The Respondent shall electronically file and serve the Response to the Motion to Compel in the usual manner and shall also email or otherwise electronically serve a copy of the Response in Word or WordPerfect format on the Movant.
Civil cases
Page 2 | B. USE OF A SINGLE DOCUMENT FOR MOTIONS TO COMPEL WHERE A RESPONSE WAS MADE
Service and Proof of Service Rules
The movant must serve the motion and Notice of Submission electronically and provide the respondent a Word or WordPerfect copy by email or other electronic service.
The Movant shall electronically serve and file the Motion to Compel along with a Notice of Submission in the usual manner, and shall also email or otherwise electronically serve a copy of the Motion in Word or WordPerfect format on the Respondent.
Civil cases
Page 1 | B. USE OF A SINGLE DOCUMENT FOR MOTIONS TO COMPEL WHERE A RESPONSE WAS MADE
The respondent must electronically serve the response and provide the movant a Word or WordPerfect copy by email or other electronic service.
The Respondent shall electronically file and serve the Response to the Motion to Compel in the usual manner and shall also email or otherwise electronically serve a copy of the Response in Word or WordPerfect format on the Movant.
Civil cases
Page 2 | B. USE OF A SINGLE DOCUMENT FOR MOTIONS TO COMPEL WHERE A RESPONSE WAS MADE
If the Movant wishes to do so, the Movant may prepare a succinct Reply to each discrete response immediately below that particular response and will electronically serve and file any such Reply in the usual fashion.
If the Movant wishes to do so, the Movant may prepare a succinct Reply to each discrete response immediately below that particular response and will electronically serve and file any such Reply in the usual fashion.
Civil cases
Page 2 | B. USE OF A SINGLE DOCUMENT FOR MOTIONS TO COMPEL WHERE A RESPONSE WAS MADE
Sealing & Redaction Procedures
Documents containing sensitive data must have that data redacted before attorneys or parties file them.
Texas Rule of Civil Procedure 2lc defines Sensitive Data as “consist[ing] of; (1) a driver’s license number, passport number, social security number, tax identification number, or similar government-issued personal identification number; (2) a bank account number, credit card number, or other financial account number; and (3) a birth date, a home address, and the name of any person who was a minor when the underlying suit was filed”, and prohibits attorneys and parties from filing documents “unless the sensitive data is redacted.”
Civil cases
Page 1 | Standing Order Regarding Online Publication of Sensitive Data
Any document containing Protected Health Information offered in Court must be sealed for filing exhibits with the District Clerk and for the appellate record, whether redacted or not and whether admitted or not.
It is further ORDERED that any document containing Protected Health Information, whether redacted or not, which is offered in Court, whether admitted as evidence or not, will be sealed for purposes of filing exhibits with the District Clerk and for the purpose of the appellate record.
Civil cases
Page 2 | Court Order Regarding Protected Health Information
The District Clerk may restrict unredacted documents containing sensitive information from being posted on the internet without further court order.
ORDERED that the District Clerk may, without further order of the Court, restrict documents containing sensitive information which is not redacted from being posted on the internet.
Civil cases
Page 1 | Standing Order Regarding Online Publication of Sensitive Data
If a filed document violates the redaction rule, the clerk may require or allow the party to resubmit a redacted substitute document, which may be posted online.
It is further ORDERED that if a filed document contains unredacted sensitive data in violation of the rule, the clerk may require or allow the party to resubmit a redacted, substitute document pursuant to Rule 21c(e), which may be posted on the internet.
Civil cases
Page 1 | Standing Order Regarding Online Publication of Sensitive Data
Filing Bundling Requirements
If the Movant wishes to do so, the Movant may prepare a succinct Reply to each discrete response immediately below that particular response and will electronically serve and file any such Reply in the usual fashion.
If the Movant wishes to do so, the Movant may prepare a succinct Reply to each discrete response immediately below that particular response and will electronically serve and file any such Reply in the usual fashion.
Civil cases
Page 2 | B. USE OF A SINGLE DOCUMENT FOR MOTIONS TO COMPEL WHERE A RESPONSE WAS MADE
Chambers Communication Rules
Email the proposed order in Word or WordPerfect format to the provided address using the specified filename.
The proposed Order will be electronically served and filed in the usual manner, and a copy of the proposed Order in Word or WordPerfect format with the file named ”[Case Number] - Proposed Order – [Name of Party] Motion to Compel” will be emailed to david.kallus@mctx.org.
Civil cases
Page 1 | B. USE OF A SINGLE DOCUMENT FOR MOTIONS TO COMPEL WHERE A RESPONSE WAS MADE
Contact the Court by phone to schedule a submission date, then send notice in compliance with the specified local rules to the extent they do not conflict with this Order.
Motions to Compel discovery are considered on the 457th District Court’s submission docket. Please contact the Court (936-538-3697) in order to schedule a submission date, then please send notice in compliance with the Local Rules of the District Courts of Montgomery County, Texas, and, in particular, with Rule 3.7 Hearings on Pre-Trial, subparts B and C, to the extent those Rules are not inconsistent with this Order.
Civil cases
Page 1 | A. SUBMISSION AND NOTICE