Judge Jeffrey V. Brown
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Pretrial Filings, Exhibits
- 2 copies • With Pretrial Filings
Adjournments
- Continuing the dispositive-motion deadline or the docket-call date requires a motion, and agreed motions for continuance are not binding on the court.
- Vacation requests will be respected if made well in advance of a trial setting or hearing date.
- Motions for continuance and motions to revise the docket-control order must include proposed dates.
- +2 more
Request must include
Communication
Chambers
Chambers
Phone
Chambers
Phone
Clerk
Phone
Page & Word Limits2 rules
Absent leave of court, any motion or response shall be limited to 30 pages. Replies are limited to 15 pages.
- Motion or response
- Up to 30 pages
- Reply
- Up to 15 pages
- Motion
- Response
Exception
More pages with leave of court
Surreplies and sur-surreplies, if allowed, are limited to 10 pages.
- Surreply
- Up to 10 pages
- Sur surreply
Document Format Requirements9 rules
Filings must be double-spaced and in 13-point or larger font.
- Font size
- At least 13 points
- Line spacing
- Double
responses, other briefs, and pleadings—must be filed in text-searchable PDF format, not as scanned images, so the court can search the text.
- File type
- Responses
- Briefs
- Pleadings
Designated documents must be marked with CONFIDENTIAL or CONFIDENTIAL—FOR ATTORNEYS’ EYES ONLY; non-documentary material must be designated equivalently.
- Designated material
Formatting
- •Non-documentary designated material must be designated in a reasonably equivalent way
Court's wording
10. Documents shall be designated by stamping or otherwise marking the documents with the words “CONFIDENTIAL” or “CONFIDENTIAL—FOR ATTORNEYS’ EYES ONLY,” thus clearly identifying the category of Designated Material for which protection is sought under the terms of this Order. Designated Material not reduced to documentary form shall be designated by the producing party in a reasonably equivalent way.
Deposition transcripts may be designated when recorded or by written notice to counsel; counsel must mark copies as directed, and exhibits must have the same confidentiality designation as the original material.
- Deposition transcript
- Deposition exhibit
Formatting
- •Designating Party may exclude unauthorized persons from depositions when testimony is designated
Court's wording
13. Deposition transcripts or portions thereof may be designated either (a) when the testimony is recorded, or (b) by written notice to all counsel of record, 3 transcript, in which case all counsel receiving such notice shall be responsible for marking the copies of the designated transcript or portion thereof in their possession or control as directed by the Designating Party. Pending expiration of the 10 business days, the deposition transcript shall be treated as designated. When testimony is designated at a deposition, the Designating Party may exclude from the deposition all persons other than those to whom the Designated Material may be disclosed under paragraph 5 of this Order. Any party may mark Designated Material as a deposition exhibit, provided the deposition witness is one to whom the exhibit may be disclosed under paragraph 5 of this Order, and the exhibit and related transcript pages receive the same confidentiality designation as the original Designated Material.
Except for motions to seal, exhibits to motions, responses, and other briefs and pleadings should be readily distinguishable from both the document to which they are appended and each other.
Exhibits consisting of sound or video files should be sent to the court in USB thumb drives—not on CDs.
Each exhibit should be individually attached and descriptively labeled on CM/ECF.
- Exhibits
Formatting
- •Each exhibit must be individually attached and descriptively labeled on CM/ECF
Plaintiffs/petitioners in ex parte admiralty matters should email Word versions of all proposed orders to Judge Edison's Case Manager at ruben castro@txs.uscourts.gov.
- File type
- Word
- Proposed order
Filings should substantially comply with The Bluebook: A Uniform System of Citation, the Texas Law Review’s The Greenbook: Texas Rules of Form and Manual on Usage & Style (a.k.a. “The Whitebook”), and Bryan Garner’s The Redbook: A Manual on Legal Style. Conflicts between The Bluebook and The Greenbook should be resolved in The Greenbook’s favor. Any citation to these rules should follow this example: Gal. Div. R. Prac. 5.
Document Filing Requirements14 rules
All non-dispositive motions must include a proposed order. Proposed orders must relate to the substance of the filed motion, be more than a mere “Grant/Deny” form, and include Judge Brown’s or Judge Edison’s signature block, as applicable.
- Document
- Non-dispositive motion
Must include
- •Proposed order
The court will strike non-dispositive motions that do not include a certificate of conference. See Southern District Local Rule 7.1.
- Document
- Non-dispositive motion
Include
- •Certificate of conference
A motion or stipulation to amend a pleading must include the proposed amended pleading in redline format showing deletions by strike-through and additions by underlining.
Court's wording
A motion or stipulation to amend a pleading shall be accompanied by the proposed amended pleading in redline format, which must indicate in every respect how the proposed amended pleading differs from the pleading that it amends, by striking through the text to be deleted and underlining the text to be added.
Amended pleadings must reproduce the entire pleading as amended and may not incorporate any part of a prior pleading by reference except with leave of court.
Court's wording
Any party filing or moving to file an amended complaint, counterclaim, third-party complaint, or answer or reply thereto shall reproduce the entire pleading as amended and may not incorporate any part of a prior pleading by reference, except with leave of court.
Any late filing must be accompanied by a motion for leave to file, or the court may strike it. The motion must provide an adequate excuse for why the party failed to request an extension of time in advance of the relevant deadline.
A filing that contains more than 10 pages of argument must contain a short statement of the nature and stage of the proceeding, a short summary of the argument, and a table of authorities.
- Document
- Filing
Must include
- •Table of authorities
Whether post-trial briefs are filed or not, the parties must file proposed findings of fact and conclusions of law. On a cases-by-case basis, the court may require proposed findings and conclusions to be filed before trial.
all social security appeals filed in the Galveston Division must be opened using only the claimants' first and last initials (e.g., A.Z. v. Commissioner) in the last name field
Every filing must cite only legal authorities verified to exist, and papers citing nonexistent decisions or fabricated language/propositions will be struck from the record.
Court's wording
Every pleading, motion, or other paper filed with the court must cite only legal authorities that the filing attorney or party has verified to exist. A paper that cites a nonexistent judicial decision or attributes fabricated language or a fabricated legal proposition to an authority will be struck from the record.
7. The confidential information may be displayed to and discussed with the persons identified in Paragraphs 5(b) and (c) only on the condition that, prior to any such display or discussion, each such person shall be asked to sign an agreement to be bound by this Order in the form attached hereto as Exhibit A. In the event such person refuses to sign an agreement in substantially the form attached as Exhibit A, the party desiring to disclose the confidential information may seek appropriate relief from the Court.
Motions to seal must include a line-by-line balancing of the public’s right of access against interests favoring nondisclosure.
Court's wording
The motion to seal must undertake a “line-by-line balancing of the public’s common law right of access against the interests favoring nondisclosure.” Le, 990 F.3d at 419 (quotation omitted).
When the Filing Party is not the Designating Party, filing sealed Designated Material requires a certificate of conference reflecting the Designating Party’s position.
- Document
- Sealed filing
Must include
- •Certificate of conference
Court's wording
Whenever the Filing Party is not the Designating Party, the Filing Party must confer with the Designating Party as to whether the Designating Party will withdraw the designation. If the Designating Party refuses to withdraw the designation, the Filing Party may file the Designated Material under seal, but must provide a certificate of conference reflecting the Designating Party’s position.
A Joint Discovery/Case Management Plan, in the form found on Judge Brown's homepage, must be filed at least 10 days before the Rule 16 conference.
Proposed orders in ex parte admiralty matters should include a signature block for Judge Edison.
- Document
- Proposed order ex parte admiralty
- Placement
- Signature block
Should include
- •Signature block for Judge Edison
Filing & Service rules
Electronic Filing Rules
The court expects parties to file documents through the Case Management/Electronic Case Filing (CM/ECF) System. See Southern District Local Rule 5.1 and the District's Administrative Procedures for CM/ECF (as amended and available at www.txs.uscourts.gov).
The court expects parties to file documents through the Case Management/Electronic Case Filing (CM/ECF) System. See Southern District Local Rule 5.1 and the District's Administrative Procedures for CM/ECF (as amended and available at www.txs.uscourts.gov).
Page 2 | Galveston Division Rules of Practice
Pro se parties may file documents by mail or in person at the clerk's office on the fourth floor of the Galveston courthouse instead of electronically.
Parties without lawyers may file their documents by mail or in person at the clerk's office on the fourth floor of the Galveston courthouse.
Page 2 | Galveston Division Rules of Practice
Filing Timing and Cure Windows
The Joint Discovery/Case Management Plan must be filed at least 10 days before the Rule 16 conference.
A Joint Discovery/Case Management Plan, in the form found on Judge Brown's homepage, must be filed at least 10 days before the Rule 16 conference.
Page 2 | 2. Rule 16 Conferences and Docket-Control Orders
If leave to amend is granted, the amended pleading (with redline formatting removed) must be filed within 14 days of the order granting leave, unless the court orders otherwise.
If granted or allowed, the amended pleading shall be filed, with redline formatting removed, and served on all parties under Fed. R. Civ. P. 5 within fourteen (14) days of the filing of the order granting leave to amend, unless the court orders otherwise.
Page 3 | 5. Amended Pleadings
Responses to motions are due within 21 days unless the court orders otherwise.
Responses to motions must be filed within 21 days unless the court orders otherwise.
Page 4 | 6. Motion Practice
Replies are due within 7 days after the response is filed.
Replies must be filed within 7 days of the date the response is filed.
Page 4 | 6. Motion Practice
In criminal cases, a motion to suppress must be filed before the pretrial conference unless the court orders otherwise.
A motion to suppress in a criminal case must be filed before the pretrial conference unless otherwise ordered by the court. See Fed. R. Crim. P. 12.
Page 5 | 6. Motion Practice
Written discovery requests must be filed early enough for the recipient’s response to be due by the discovery-completion deadline.
Written discovery requests ===== PAGE 2 ===== are not timely if they are filed so close to this deadline that the recipient would not be required under the Federal Rules of Civil Procedure to respond until after the deadline.
Civil cases
Page 2 | DEADLINES
Rule 10 pretrial filings must be filed at least one day before docket call.
All Pretrial Filings (exhibit list, witness list, etc.) required under Rule 10 of the Galveston District Court Rules of Practice must be filed at least one day before this date.
Civil cases
Page 2 | DOCKET CALL
The parties should exchange these materials at least 72 hours before the hearing and confer beforehand to narrow evidentiary objections.
The parties should exchange these materials at least 72 hours before the hearing and confer beforehand to narrow evidentiary objections.
Page 7 | Pretrial Filings in Jury Cases
On settlement announcements the court enters conditional dismissal, and any party may move to reinstate within 60 days.
The court will order conditional dismissal—without prejudice to the right of any party to move to reinstate within 60 days—on all settlement announcements.
Page 5 | 8. Settlements
Each party must file its pretrial filings—exhibit list, witness list, proposed voir dire questions, proposed jury instructions, motions in limine, and deposition designations and objections—at least 24 hours before docket call.
Instead, at least 24 hours document: exhibit list, witness list, proposed voir dire questions, proposed jury instructions, motions in limine, and deposition designations and objections.
Page 5 | 10. Pretrial Filings in Jury Cases
Service and Proof of Service Rules
A removing party must serve a copy of these rules on all other parties along with the removal papers.
A party removing a case to this court must serve a copy of these rules on all other parties with the removal papers.
Page 1 | Galveston Division Rules of Practice
Proof of service of the Galveston Division Rules of Practice must be filed with the U.S. District Clerk.
Proof reflecting service of these rules must be filed with the U.S. District Clerk.
Page 1 | Galveston Division Rules of Practice
Plaintiffs must serve a copy of the Galveston Division Rules of Practice on each defendant together with the summons and complaint.
Plaintiffs must serve a copy of these rules on each defendant with the summons and complaint.
Page 1 | Galveston Division Rules of Practice
A party that causes new parties to be joined after entry of the docket-control order must provide them with copies of the operative docket-control order and these rules.
If new parties are joined after entry of the docket-control order, the party causing such joinder shall provide to the new parties copies of both the operative docket-control order and these rules.
Page 2 | 2. Rule 16 Conferences and Docket-Control Orders
The amended pleading must be served on all parties under Fed. R. Civ. P. 5 within 14 days of the order granting leave to amend.
If granted or allowed, the amended pleading shall be filed, with redline formatting removed, and served on all parties under Fed. R. Civ. P. 5 within fourteen (14) days of the filing of the order granting leave to amend, unless the court orders otherwise.
Page 3 | 5. Amended Pleadings
The attorney adding new parties must provide them copies of this order and all previously entered orders.
The attorney causing the addition of new parties will provide copies of this order and all orders previously entered in the case to new parties.
Civil cases
Page 1 | DEADLINES
The parties should exchange proposed motions in limine, exhibit lists, and deposition designations at least one week before docket call.
The parties should exchange proposed motions in limine, exhibit lists, and deposition designations at least one week before docket call.
Page 6 | 10. Pretrial Filings in Jury Cases
Courtesy Copy Requirements
Each party should also submit to the court two tabbed binders containing these filings (one for the judge and one for the clerk), and two separate tabbed binders containing its exhibits.
Each party should also submit to the court two tabbed binders containing these filings (one for the judge and one for the clerk), and two separate tabbed binders containing its exhibits.
Page 6 | 10. Pretrial Filings in Jury Cases
Sealing & Redaction Procedures
Filings under seal must be accompanied by a motion to seal and a version of the document(s) with proposed redactions highlighted; wholesale sealing requires an extraordinary showing.
if a party wishes to file a pleading, motion, or exhibit under seal, it must be accompanied by a motion to seal ... Such motion must also be accompanied by a version of the document(s) to be sealed/redacted in which proposed redactions are highlighted. The court will not seal documents wholesale absent an extraordinary showing.
Page 3 | 6. Motion Practice
Designated Material filed with the Court is sealed only upon motion, with no automatic sealing; specific procedures apply based on whether the Filing Party is the Designating Party.
14. “[D]isplacing the high bar for sealing orders with the low bar for protective orders . . . undercuts the public’s right of access and thus undermines the public’s faith in our justice system.” Binh Hoa Le v. Exeter Fin. Corp., 990 F.3d 410, 421 (5th Cir. 2021). Accordingly, Designated Material filed with the Court will be sealed by the Court only upon motion and in accordance with applicable law. This Order does not provide for the automatic sealing of such Designated Material. If it becomes necessary to file Designated Material with the Court, the Designating Party must move to file the Designated Material under seal, even if the Designating Party is not the party who seeks to file such Designated Material with the Court (the “Filing Party”). a. When the Designating Party and the Filing Party are one in the same, that party must file a motion to seal contemporaneously with filing the Designated Material under seal. The motion to seal must undertake a “line-by-line balancing of the public’s common law right of access against the interests favoring nondisclosure.” Le, 990 F.3d at 419 (quotation omitted). Designated Material will remain sealed while a ruling on the motion to seal is pending. b. Whenever the Filing Party is not the Designating Party, the Filing Party must confer with the Designating Party as to whether the Designating Party will withdraw the designation. If the Designating Party refuses to withdraw the designation, the Filing Party may file the Designated Material under seal, but must provide a certificate of conference reflecting the Designating Party’s position. Once the Designated Material is filed under seal, the Designating Party has seven days to file a motion to seal. Designated Material will be automatically unsealed if a motion to seal is not filed within seven days of the Designated Material being filed under seal.
Civil cases
Page 4 | 14
Redacted exhibits may not be filed under seal.
Redacted exhibits may not be filed under seal.
Civil cases
Page 5 | 14c
All motions to seal must include redacted exhibits of the Designated Material.
Accordingly, all motions to seal must be accompanied by redacted exhibits of the Designated Material.
Civil cases
Page 5 | 14c
Non-opposition or mutual agreement does not exempt motions to seal from compliance requirements.
Parties’ non-opposition or mutual agreement regarding the sealing of Designated Material is irrelevant where the public record is concerned. Even unopposed motions to seal must comply with this paragraph.
Civil cases
Page 5 | 14d
Proposed redactions in sealed documents should be highlighted for the court's convenience.
Proposed redactions in the documents filed under seal should be highlighted for the court’s convenience.
Civil cases
Page 5 | 14c
Filing Bundling Requirements
A party should not file a motion and separate “Memorandum of Law.” The motion should include the party’s argument supporting the relief sought.
A party should not file a motion and separate “Memorandum of Law.” The motion should include the party’s argument supporting the relief sought.
Page 3 | 6. Motion Practice
Motions to seal and all exhibits to motions to seal must be filed as a single, combined document.
Motions to seal and all exhibits to motions to seal should be filed as a single, combined document.
Page 4 | 6. Motion Practice
Parties should not file a joint pretrial order; each party submits its own pretrial filings instead.
The parties should not file a joint pretrial order.
Page 5 | 10. Pretrial Filings in Jury Cases
Parties are encouraged to file all proposed highlighted redactions as a single document.
Regardless of how many documents the parties seek to redact, the parties should endeavor to file the proposed highlighted redactions as a single document for the court’s convenience.
Civil cases
Page 5 | 14c
Pre-Motion Conference Requirements
Parties must first obtain leave of court by motion before filing a surreply or sur-surreply, and unauthorized surreplies and sur-surreplies will be struck.
A party wishing to file a surreply, or a sur-surreply, must first obtain leave of court by motion. The court will strike unauthorized surreplies and sur- surreplies. Surreplies and sur-surreplies,
Page 4 | 6. Motion Practice
Before filing a motion to compel, parties must file a joint letter of no more than 2 pages outlining the dispute, each side's position, and resolution efforts, after which the court typically convenes a Zoom conference.
When those earnest and valiant attempts prove unsuccessful, the parties should file a joint letter not to exceed two pages outlining the dispute, each side’s position, and the efforts made to resolve the dispute. Typically, the court will then convene a Zoom conference to resolve the issue as quickly as possible. Parties may not file a motion to compel without first exhausting this procedure.
Page 5 | 7. Discovery Disputes
Adjournment & Extension Requirements
Continuing the dispositive-motion deadline or the docket-call date requires a motion, and agreed motions for continuance are not binding on the court.
Continuing the dispositive- motion deadline or the docket-call date requires a motion. Agreed motions for continuance are not binding on the court.
Page 2 | 3. Continuances of Docket-Control Deadlines and Trial Settings
Motions for continuance and motions to revise the docket-control order must include proposed dates.
Motions for continuance and motions to revise the docket-control order must include proposed dates.
Page 3 | 6. Motion Practice
Extensions of response and reply deadlines must be obtained by motion; a mere agreement between the parties is insufficient.
Any extension of these deadlines must be obtained by motion; though the court would be pleased to see that such a motion is unopposed, a mere agreement between the parties will be insufficient to extend the deadline.
Page 4 | 6. Motion Practice
Parties may agree to extend discovery and expert deadlines without court approval unless the extension affects the dispositive-motion deadline or the docket-call date.
The parties may agree to extensions of discovery and expert deadlines without seeking court approval, so long as the extension does not affect the dispositive-motion deadline or the docket-call date.
Page 2 | 3. Continuances of Docket-Control Deadlines and Trial Settings
Vacation requests will be respected if made well in advance of a trial setting or hearing date.
Vacation requests will be respected if they are made well in advance of a trial setting or hearing date.
Page 2 | 3. Continuances of Docket-Control Deadlines and Trial Settings
Chambers Communication Rules
Before filing an emergency motion, TRO application, or motion for preliminary injunction seeking expedited relief, a party must notify the case manager in advance.
A party seeking an expedited ruling on an application for a TRO, a motion for preliminary injunction, or any other motion it believes to be an emergency must notify the case manager in advance of the impending filing.
Page 6 | 15. Emergency Motions and TROs
Parties contemplating settlement should call the case manager, and parties must inform the court immediately if the case settles.
Parties contemplating settlement should advise the court by calling the case manager so that the court can postpone consideration of any pending motions. If the parties succeed in settling the case, they must inform the court immediately.
Page 5 | 8. Settlements
Plaintiffs/petitioners in ex parte admiralty matters should email Word versions of all proposed orders to Judge Edison's Case Manager at ruben castro@txs.uscourts.gov.
Plaintiffs/petitioners in ex parte admiralty matters should email Word versions of all proposed orders to Judge Edison's Case Manager at ruben castro@txs.uscourts.gov.
Page 7 | 18. Ex Parte Admiralty Matters
Document status, orders, and docket entries should be checked via CM/ECF or PACER, with the U.S. District Clerk's office (409-766-3530) used only if absolutely necessary.
Information about the status of documents, entry of orders, or docket entries should be obtained from CM/ECF or PACER or, if absolutely necessary, from the U.S. District Clerk's office (409-766-3530).
Page 2 | Galveston Division Rules of Practice
Inquiries related to cases proceeding before Judge Brown should be made to his case manager, George Cardenas, at 409-766-3737 or at george_cardenas@txs.uscourts.gov.
Inquiries related to cases proceeding before Judge Brown should be made to his case manager, George Cardenas, at 409-766-3737 or at george_cardenas@txs.uscourts.gov.
Page 2 | Galveston Division Rules of Practice
Inquiries in cases before Judge Edison and Rule 16 conference inquiries should be directed to case manager Ruben Castro at ruben_castro@txs.uscourts.gov.
Inquiries related to cases proceeding before Judge Edison and inquiries related to Rule 16 conferences should be made to his case manager, Ruben Castro, at ruben_castro@txs.uscourts.gov.
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