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Houston Injury Lawyers

Our Blog


701 N Post Oak Rd #207
Houston, TX 77024


Discovery Motions

Always confer before filing any motion related to discovery and include a certificate of conference. Be sure to attach a copy of the discovery response at issue or state verbatim the request and answer in the body of your motion. Proposed orders should list each discovery issue separately.


If time is short before a hearing, after efiling, please email a copy of your response directly to the court clerk so that the judge will be able to read the response before the hearing date. Include a propsoed order denying your opponent’s motion.

Any replies that are filed after Friday at 10:00 a.m. for a Monday oral hearing are NOT LIKELY to be considered by the Court. The Court prepares diligently over the weekend for the Monday docket. If your reply is filed on Friday, there is a good chance it will not make it into the Court’s electronic file, and therefore, the Court will not be able to review it over the weekend. Please do everything in your power to file any necessary replies (or sur-replies, etc.) by Thursday before a Monday hearing.

Document Separation

All pleading, motions, responses, etc., must be separated with the filing as follows., motion and response, each individual exhibit, proposed order, notice of hearing and/or submission.

Filings not in accordance with the above will be rejected.

Naming Pleadings

When filing documents, the exact name as it appears on the pleading is to be used. The name of the pleading appears on the search results or summary page for the case. To simplify the search results page, please limit the title of documents to no more than 10 words, unless additional words are necessary.

Special Exceptions

Attach a copy of the pleading you are excepting to (unless the exception is only to the amount of damages sought) or state verbatim the paragraph you except to in the pleading. Proposed orders should list each exception separately.


Sanctions should not be requested unless the opponent has violated a previous order. Instead, ask for reimbursement of your costs in the form of attorney fees.


Motions for Severance should be set either on submission or the oral hearing docket. The motion must state the basis for the severance. The order of severance must contain the following listed below:

- Style of Case
- Proposed new case number / example 2006-00000-A
- Parties to be included in the severed case
- Each document to be included in the severed case
- Whether the severed case has a final order or if the case shall remain active
- The party paying for court cost of the severance


Motions for Continuance should be filed as early as possible. Motions filed after receiving assignment from the trial coordinator will not be looked upon favorably.

Agreed Motion

Agreed motions do not have to be placed on the court’s docket, unless the case is older than 3 years. Just file them with the court for consideration. If an agreed motion is denied without a hearing, you can request a subsequent oral hearing on the motion.

Motion for Default Judgment

Motion for Default Judgment seeking the foreclosure of a lien on real property-

- Must be presented by oral hearing, the Court will no longer consider these motions by submission,
 - Notice must be sent to the defaulting party after service of citation pursuant to Rule 21a of the Texas Rules of Civil Procedure and
- If there is a mortgage company that also holds a lien on the subject property notice must be sent to the mortgage company of the hearing of Motion for Default Judgment.


If both sides agree to an emergency hearing, call the court clerk and set up a date and time with the judge. If only one side thinks it is an emergency, file a motion for an emergency hearing. File it directly with the court clerk who will then give it to the judge to set a hearing time.

Oral Docket
Any party requesting an oral hearing should call the court clerk for a date and time and file a notice of hearing. All notices must include the date and time of the hearing, the date that the motion(s) was filed, the motion(s) to be heard, and how much time you are requesting. A party who sets a hearing and subsequently passes that hearing MUST notify all parties involved including the court.

Submission Docket
The submission docket is held on Mondays at 8:00 am after 10 days’ notice.

Temporary Injunctions

Please call the court clerk before your scheduled hearing. TIs are automatically set on Mondays at 1:30 p.m. It is imperative that we know whether or not you are ready to proceed with the hearing and how long the hearing will take. If it is lengthy, we may need to reschedule your hearing (because of other hearings or trial) and extend the TRO until the court is available. Do not bring your witnesses to court until you have spoken to the court clerk!

Motions in Limine which are in addition to the Court’s Standing Motion in Limine and exhibits must be exchanged with other pursuant to the Texas Rules of Civil Procedure. Deposition excerpts and objections to same shall be exchanged as soon as practical but no later than 48 hours prior to the voir dire examination.

If you anticipate a challenge to an expert’s qualifications, or opinions, it must be done in accordance with the Court’s Docket Control Order.

Time for voir dire depends on the complexity of the case. Jury questionnaires may be discussed with the court at an earlier status conference.

All cases are automatically set for trial after the answer of a Defendant.

Witnesses, parties, lawyers, etc., may no longer appear by Zoom.


Exhibits should be marked with numbers, not letters. Please ensure any exhibit that has more than one page is stapled, binder clipped or contained in a notebook. Original exhibits should be submitted to the court reporter once they have been offered into evidence, whether admitted into evidence by the court or not.

When citing case law in hearings or trials, the citation should be stated on the record.

Any PowerPoint presentations and/or case law should be given to the court reporter at the same time they are handed to the court.

If daily copy, expedited, or rough draft transcripts will be requested of the court reporter, notice should be given to the court reporter as soon as possible before the start of the hearing or trial, so that the reporter may prepare appropriately.


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