Tarrant County Civil District Courts Document Filing Requirements

Applies to

Discovery dispute motion

Must include

certificate of conference

A motion raising a discovery dispute must include an attached Certificate of Conference and may then be set for a hearing before the Court.

These disputes can be set for hearing before the Court after filing a motion; a Certificate of Conference must be attached to each filed motion.

Applies to

Motion

Must include

proposed order

Every motion must be accompanied by a proposed order.

All motions must be accompanied with a proposed Order.

Applies to

Trial witness list

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.

Applies to

Motion or letter

A motion, objection, or special exception may not be set for hearing unless the moving party includes a substantially specified conference certification in the motion or a separate letter.

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:

Applies to

Deposition notice

Before noticing an oral deposition, the initiating party must confer or adequately attempt to confer with opposing counsel about the deposition date, time, place, and materials, and the written notice must include the prescribed conference language; failure may result in quashing the deposition.

A party initiating an oral deposition shall first attempt to communicate with opposing counsel to determine whether agreement can be reached as to date, time, place and material, to be furnished at the time of deposition. Any written notice of deposition shall state as follows: "A conference was held (or attempted) with the attorney for opposing party to agree on a date, time, place and materials to be furnished. Agreement could not be reached (or counsel will not respond) and the deposition is therefore being taken pursuant to this notice (or Agreement was reached and this notice complies with the agreement)." Failure to hold such conference or to make adequate attempt to hold such conference prior to noticing a deposition shall be grounds to quash the deposition.

Applies to

Ex parte application

Every ex parte relief application must include a certificate signed by counsel stating that the opposing party is unrepresented, that opposing counsel was notified and given an opportunity to be heard, or that diligent notice attempts were unsuccessful and further attempts are not permitted.

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.

Applies to

Proposed order

A proposed order authorizing private service under Rule 103 must be accompanied by a counsel-signed certificate identifying the person to be authorized and affirming that the person is at least 18, is not a party, and has no interest in the outcome.

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 person is not less than eighteen (18) years of age, is not a party, ===== PAGE 6 ===== and has no interest in the outcome of the suit in which the authorization is sought.

Applies to

Motion

Must include

proposed order

A motion seeking affirmative relief must be accompanied by a proposed order or have the order 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.

Applies to

Certificate of written discovery

The original or an exact copy of listed discovery 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.

Applies to

Certificate of written discovery

Whenever listed discovery material is retained or sent to another party, a signed Certificate of Written Discovery must be filed identifying the document, its recipients, and the service date.

(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. The certificate may list more than one document. 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.

Applies to

Ex parte application

Every ex parte application for relief must include a certificate signed by counsel stating one of three alternative facts about representation, notice, or unsuccessful diligent notice efforts.

(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.

Applies to

Proposed order

A proposed order authorizing private service under Rule 103 will not be signed without a counsel-signed certificate identifying the proposed server and affirming that the person is at least 18, is not a party, and has no interest in the 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, 13 ===== PAGE 6 ===== and has no interest in the outcome of the suit in which the authorization is sought.

Applies to

Motion

Must include

proposed order

A motion seeking affirmative relief must include a proposed order granting or denying it, 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.

Applies to

Discovery material

When discovery materials listed in Rule 1.07(b) are retained or sent to another party, a signed Certificate of Written Discovery must be filed identifying the document, recipients, and service date.

(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. The certificate may list more than one document. 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.

Applies to

Jury instructions

The jury charges must be filed.

File the jury charges.

Applies to

Notice of hearing

A notice of hearing must state the hearing format, motions to be heard, allotted time, filing deadline, and any applicable notebook-delivery requirement.

When you do send out the notice of hearing, please include: 1. The hearing is In-Person, by ZOOM, or by Submission.* 2. Which motion(s) will be heard. 3. The amount of time allotted for the hearing – 30 minutes, 1 hour, etc. 4. All orders and responses must be filed according to the Texas Rules of Civil Procedures or the day before the hearing by 12:00 pm. 5. If the motion and response is over 50 pages, a notebook must be delivered to the court 2 days prior to the hearing, between 9:00 am – 11:00 am or 2:00 pm – 4:00 pm.

Applies to

Designated deposition testimony

The page and line numbers of designated deposition testimony must be filed with the court when the testimony will be read into the record or played by video.

For deposition transcripts that will be read into the record or played by video, the page and line numbers of the designated testimony is to be filed with the Court.

Applies to

Designated deposition testimony objection

Must include

proposed order

The objecting party must file a proposed order identifying the page and line of the objected-to testimony and stating the reason for the objection.

In addition to the condensed transcript, the objecting party will need to file a proposed order(located on the Court’s website) indicating the page and line of the objected to testimony and the reason for the objection.

Applies to

Ex parte relief application

Must include

certificate of conference

The certificate of conference must comply with Tarrant County local rules for ex parte relief.

CERTIFICATE OF CONFERENCE IN COMPLIANCE WITH TARRANT COUNTY LOCAL RULES FOR EX PARTE RELIEF

Applies to

Certificate of conference

When counsel could not be notified, the certificate must describe the diligent attempts made.

Diligent attempts to notify counsel for the party against whom ex parte relief is sought has been as follows:

Applies to

Certificate of conference

The certificate must state that the diligent notice attempts were unsuccessful and that additional notice efforts are not permitted by the circumstances.

And said diligent attempts have been unsuccessful, and the circumstances do not permit additional efforts to give notice.

Applies to

Plaintiffs original petition

The plaintiff's original petition must be on file before the TRO is presented to the judge.

1. Plaintiff’s Original Petition

Applies to

TRO application

An application for a temporary restraining order must be on file before the TRO is presented to the judge.

2. Application for TRO

Applies to

TRO supporting affidavit

An affidavit supporting the temporary restraining order must be on file before the TRO is presented to the judge.

3. Affidavit Supporting TRO

Applies to

Certificate of conference

Must include

certificate of conference

A certificate of conference complying with the Tarrant County local rules must be on file before the TRO is presented to the judge.

4. Certificate of Conference in Compliance with Tarrant County Local Rules

Applies to

Order granting TRO

Must include

proposed order

An order granting the temporary restraining order must be on file before the TRO is presented to the judge.

5. Order Granting TRO

Applies to

Hearing binder

A hearing binder assembled for documents exceeding 50 combined pages must include a table of contents.

If your motion, response, reply, and/or related exhibits combined are in excess of 50 pages, the party requesting a hearing must deliver to the Court by 12 p.m. the day before the hearing a binder containing all documents related to the hearing (e.g., both parties’ motions, responses, replies, exhibits, and attachments) appropriately tabbed with a table of contents. Failure to do so may result in cancellation of the hearing.

Applies to

Pro se filing information

All attorney requirements apply equally to pro se litigants, who must provide reachable address and telephone listings.

All requirements of these rules applicable to attorneys or counsel apply with equal force to pro se litigants. Pro se litigants are required to provide address and telephone listings at which they can be reached by Court personnel and opposing counsel.

Applies to

Exhibits

The email subject for exhibits must include the full cause number and identify the exhibits as Plaintiff’s or Defendant’s Exhibits.

The subject of the e-mail should contain the full cause number and an indication of “Plaintiff’s Exhibits or Defendant’s Exhibits.”

Applies to

Certificate of conference

The certificate may certify that the party against whom ex parte relief is sought is unrepresented.

To the best of my knowledge the party against whom relief is sought ex parte is not represented by counsel in this matter (the matter made the basis of the relief sought).

Applies to

Certificate of conference

The certificate may certify that counsel for the opposing party was notified and does not wish to be heard.

Counsel for the party against whom relief is sought ex parte has been notified of this application and has stated that he or she does not wish to be heard in this matter.

Applies to

Jury instructions

Each side must submit its proposed charge in Microsoft Word format to the court reporter by e-mail or flash drive.

Each side shall submit their proposed charge in electronic format (Microsoft Word) to the court reporter via e-mail or flash drive.

The conference-certification requirement in subsection (b) does not apply to dispositive motions, including summary-judgment, dismissal, cause-of-action dismissal, and new-trial motions.

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.