Tarrant County Civil District Courts
Court-Level Rules, Filing Procedures & Policies
Document Format Requirements1 rule
Before trial begins, counsel must mark, exchange, and examine all exhibits so examination does not delay trial.
Prior to commencement of trial all exhibits will be marked, exchanged and examined by counsel so that the trial will not be delayed by such examination.
Document Filing Requirements8 rules
A motion seeking affirmative relief must include an order granting or denying the motion, or the order must be brought to the hearing.
All filed motions seeking affirmative relief from the court will either be accompanied by an Order in such form as to grant or deny the motion, or said Order will be brought to the hearing on the motion.
Document Type
Motion
The Certificate of Written Discovery must identify the document containing the discovery material, the recipients, and the service date.
The certificate shall identify: 1. the document containing the discovery material, 2. counsel or parties to whom the document is sent, and 3. the date the discovery response or related matter is served on other counsel or parties.
Document Type
Certificate Of Written Discovery
A signed Certificate of Written Discovery must be filed with the clerk whenever Rule 1.07(b) discovery materials are retained or sent to another party.
(3) Sign and file A Certificate entitled "Certificate of Written Discovery" with the Clerk whenever discovery materials listed in Rule 1.07 (b) are retained and/or sent to another party.
Document Type
Certificate Of Written Discovery
The original or an exact copy of the listed discovery responses and related material must be retained during the case and related appellate proceedings and for one year afterward, with a Certificate of Written Discovery signed and filed when necessary.
(2) Retain the original or exact copy of the discovery responses and related material listed in Rule 1.07 (b) while the case and any related appellate proceedings are pending and for one year thereafter, and sign and file a Certificate of Written Discovery with the clerk when necessary.
Document Type
Certificate Of Written Discovery
When parties report for trial, they must deliver a witness list and exhibit list to the Court and other parties.
At the time the parties report for trial they will deliver to the Court and the other parties a witness list, exhibit list, any motion in limine and any requested instructions and questions if a jury trial and proposed findings of fact and conclusions of law if a non-jury trial.
Document Type
Witness List
Every ex parte relief application must include a counsel-signed certificate establishing that the affected party is unrepresented, that counsel was notified and given an opportunity to be heard, or that diligent notice attempts failed and further efforts are not permitted by the circumstances.
(c) Ex Parte Applications. Every application for relief ex parte shall contain a certificate signed by counsel that: (1) To the best of his or her knowledge that party against whom relief is sought ex parte is not represented by counsel in the matter made the basis of the relief sought; or, (2) Counsel for the party against whom relief is sought ex parte has been notified of the application and has stated whether he or she wishes to be heard; or, (3) Diligent attempts to notify counsel for the party against whom ex parte relief is sought have been unsuccessful, and the circumstances do not permit additional efforts to give notice.
Document Type
Ex Parte Application
A proposed order authorizing private service under Rule 103 will not be signed without a counsel-signed request certificate identifying the proposed server and affirming that the person is at least 18, is not a party, and has no interest in the suit's outcome.
(b) Any proposed order authorizing private service under Rule 103 will not be signed by the judge unless accompanied by a certificate signed by counsel requesting such an appointment. Such certificate shall set out the name and address of the person to be so authorized and affirm that such perspn is not less than eighteen (18) years of age, is not a party, ===== PAGE 14 ===== and has no interest in the outcome of the suit in which the authorization is sought.
Document Type
Proposed Order
Witnesses and exhibits omitted from the required lists may be used at trial only if the Court grants leave.
Any witnesses and exhibits not shown on such list can be used at the trial only upon leave of the Court.
Document Type
Trial Witness And Exhibit Lists
Filing & Service rules
Filing Timing and Cure Windows
A hearing on special exceptions, pleas in abatement, or another dilatory plea must be obtained at least 30 days before trial or as soon as possible if filed within 30 days of trial; matters not heard are waived.
Any party filing special exceptions, pleas in abatement or other dilatory pleas shall request and obtain a hearing on them at least 30 days prior to the trial date or as soon as possible after the pleading is filed within 30 days of the trial date. Any such matters not heard ===== PAGE 10 ===== are waived.
Page 9 | Rule 3.03(a): Trial Procedure
Service and Proof of Service Rules
Discovery responses and related material must be served on all other lead counsel or parties and filed with the Clerk, although items designated optional need only be served and may be filed.
The following discovery responses and related material SHALL be served upon all other lead counsel or parties and filed with the Clerk in accordance with the Texas Rules of Civil Procedure and the Texas Civil Practice and Remedies Code; those denoted [OPTIONAL] SHALL be served, and MAY be filed, accordingly:
Page 4 | Rule 1.07: Filing Responses to Discovery
Discovery documents and related materials must be served on all other lead counsel or parties but generally must not be filed with the clerk except by special order.
(b) The following discov.ery documents and related materials SHALL be served upon all other lead counsel or parties in accordance with the Texas Rules of Civil Procedure and the Texas Civil Practice and Remedies Code, but SHALL NOT BE FILED with the clerk except on Special Order.
Page 5 | Rule 1.07: Filing Responses to Discovery
A responding or initiating party must serve the Rule 1.07(b) discovery materials on all other lead counsel or parties and may not file them with the clerk except on special order.
(1) Serve upon all other lead counsel or parties, discovery material listed in Rule 1.07 (b) as required therein; but the same shall NOT be filed with the Clerk except on Special Order.
Page 6 | Rule 1.07: Filing Responses to Discovery
Unless otherwise agreed or ordered, counsel must make qualifying videotapes and films available and serve page-and-line designations at least 14 days before trial when they were taken 45 or more days before trial; impeachment-only materials are excepted.
Unless otherwise expressly agreed to by the parties or ordered by the Court, counsel intending to offer videotaped depositions, or other films or videotapes at trial, except those offered solely for impeachment, must make such videotapes and films available to opposing counsel, and serve opposing counsel with page and line designations for videotaped depositions, not later than fourteen (14) days prior to trial for all depositions or other films taken forty-five (45) days or more in advance of trial.
Page 10 | Rule 3.03(d): Trial Procedure
Videotaped depositions and films taken within 45 days of trial must be made available, with required designations, as soon as possible and sufficiently early for an objections hearing before trial.
All videotaped depositions and other films taken within forty-five (45) days of trial must be made available , and the aforementioned designations made, as soon as possible to opposing counsel and sufficiently in advance of trial so that a hearing on any objections can be held before commencement of trial.
Page 10 | Rule 3.03(d): Trial Procedure
Opposing counsel must serve the proffering attorney with page-and-line designations for intended deposition portions no later than 10 days before trial.
Opposing counsel shall then serve the proffering attorney with page and line designations of any portion of the videotape deposition they intend to introduce at trial not later than ten (10) days prior to trial.
Page 10 | Rule 3.03(d): Trial Procedure
The proffering attorney must serve opposing counsel with page-and-line designations for any additional deposition portions intended for trial no later than 7 days before trial.
The proffering attorney shall then serve opposing counsel with page and line designations of any portion of the videotape deposition they further intend to introduce at trial not later than seven (7) days prior to trial.
Page 10 | Rule 3.03(d): Trial Procedure
For purposes of these local rules, “counsel” includes a party proceeding without an attorney.
Wherever "counsel" is used it includes a party not represented by an attorney.
Page 2 | Rule 1.02: Parties Proceeding Pro Se
Pre-Motion Conference Requirements
A motion, objection, or special exception may not be set for hearing unless the moving party includes the prescribed conference certification in the filing or a separate letter.
(b) No motions, objections or special exceptions will be set for hearing unless the moving party shall have certified in such motion or in a letter substantially the following:
Page 11 | Rule 3.06: Motion Practice (b)
The conference-certification requirement does not apply to dispositive motions, including summary-judgment, dismissal, cause-of-action dismissal, and new-trial motions.
(f) Section (b) of this Rule does not pertain to dispositive motions, e.g., Motions for Summary Judgment, Motions to Dismiss and Special Exceptions seeking to dismiss a cause of action, or a Motion for New Trial.
Page 11 | Rule 3.06: Motion Practice (f)
Adjournment & Extension Requirements
A continuance motion ordinarily must be filed by the Wednesday preceding trial and heard at 2:00 p.m. the following Thursday, unless the Court sets otherwise.
A trial date cannot be postponed or changed without the consent of the Court. Except as hereinafter provided and unless otherwise set by the Court, any motion for continuance will be filed no later than the Wednesday preceding the trial date and will be heard by the Court in the courtroom at 2:00 p.m. on the Thursday preceding the trial date.
Page 9 | Rule 3.02: Motion for Continuance
A continuance motion based on facts arising on or after the Wednesday before trial must be filed as soon as possible and will be heard at a time set by the Court.
Any motion for continuance based upon facts which occur on or after the Wednesday preceding the trial date will be filed as soon as possible and will be heard at a time to be set by the Court.
Page 9 | Rule 3.02: Motion for Continuance
An attorney must notify the Court as soon as a trial-setting notice is received and immediately notify the Court and other parties if a conflicting vacation plan is made afterward, requesting that the case be reset; the Court then must give all parties an opportunity to respond.
If a case is set for trial by the court on a date for which an attorney has planned a vacation, the attorney will notify the Court as soon as the notice of trial setting is received and the case may be reset for a different time at the discretion of the court. If plans for a vacation are made by an attorney after a trial setting notice.has been received, the attorney will immediately notify the Court and other parties with a request that the case be reset for a different time. The Court will rule on such request after giving all parties to the lawsuit an opportunity to respond to the request.
Page 8 | Rule 1.11: Vacations of Attorneys
Chambers Communication Rules
Requests for hearings to approve settlements involving minors and unliquidated default judgments must be made to the Court Coordinator, who will schedule them.
Requests for hearing to approve settlements in cases involving minors and default judgments, where the amount is unliquidated, shall be made to the Court Coordinator who will schedule the same for hearing.
Page 10 | Rule 3.04: Settlement Prove-Ups and Default Judgment Hearings