Tarrant County Civil District Courts Pre-Motion Conference Requirements

A motion, objection, or special exception may not be set for hearing unless the moving party includes a substantially specified certification concerning a conference or inability to confer.

(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: "A conference was held on (date) with (name of attorney for opposing party) on the merits of this motion. A reasonable effort has been made to resolve the dispute without the necessity of court intervention and the effort failed. Therefore it is presented to the Court for determination." or "A conference was not held with (name of opposing attorney) on the merits of this motion because (explanation of inability to confer)."

The conference-certification requirement does not apply to dispositive motions, including motions for summary judgment or dismissal, special exceptions seeking dismissal of a cause of action, and motions for a new trial.

(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.

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

(a) Parties are directed to use all reasonable means to resolve pre-trial disputes to avoid the necessity of judicial intervention.