Southern District of Texas Local Rules and Judge Filing Requirements

In minor-plaintiff cases with a potential conflict of interest between parents and the minor, counsel must jointly move for appointment of an attorney ad litem upon settlement or before any mediation/ADR.

Joint Pretrial Orders must list each party, counsel, counsel’s address, and telephone number in separate paragraphs.

Proposed conclusions of law must cite legal authority and specify agreed propositions of law.

Failure to timely object results in waiver/admission; failure to timely respond results in objection being sustained.

Motions must contain the arguments and relief sought; a separate memorandum of law must not be filed.

Substantive issues are prohibited in letters or emails to the Court; all letters must be filed with the Court; email correspondence may be docketed at the Court’s discretion.

Judge Hanen's chambers can be reached by phone at (713) 250-5908 at the United States Courthouse, 515 Rusk Street, Room 8631, Houston, Texas.

Case-related telephone and email inquiries regarding any case should be made to Arturo Rivera, Case Manager and Court Coordinator at 713-250-5181 or Arturo_Rivera@txs.uscourts.gov.

Email correspondence with the Case Manager may be docketed at the Court's discretion.

Emergency motions must be emailed directly to the Case Manager after e-filing.

Supporting evidence must be filed as separate exhibits with cover sheets and clearly identified on CM/ECF docket entries.

Joint Pretrial Orders must use Form 12, adapted as needed for case complexity.

Civil cases require plaintiff's counsel to submit a Word version of documents via email to the Case Manager.

When providing copies of filings over fifty pages, print double-sided and submit in a binder. Organize exhibits and attachments by tab at the right margin. Use the smallest binders that comfortably hold the material. Do not use binders larger than four inches. Divide into multiple binders when necessary.

Restraining order and immediate relief applications must be filed with the District Clerk’s Office at the specified address.

Amicus briefs require leave by motion with the brief attached as an exhibit; party responses to amicus briefing are freely allowed.

Oral argument requests are not required; the Court will notify counsel if a motion hearing is deemed beneficial.

Opposed motions are submitted to the Court twenty- one calendar days from filing. The Court may rule on the motion at that time. Accordingly, file any response no later than twenty-one calendar days of the motion. There is no right to file a reply. The Court may consider a reply if it is filed prior to the Court ruling on the motion. Any reply must be filed no later than seven days after the response is filed. Do not file a sur-reply absent permission.

Parties must have a person with detailed knowledge of relevant electronic systems available at conferences for electronic data discovery disputes.

When a party believes an opponent has misused its privilege log, it may request that the Court make in camera inspection of not more than twenty documents. Bring any request by letter not to exceed approximately three single-spaced pages. Lead counsel must confer in good faith to resolve the dispute prior to any letter. In the letter, identify the documents for review, state the grounds for challenge, specify the conference between lead counsel, and summarize the results. This letter establishes consent to ex parte contact between the Court and the party’s opponent regarding the nature and verity of the asserted privilege. Each party may freely submit only a single letter requesting in camera inspection. Submit any letter at least sixty days before the end of discovery or promptly upon receipt of any later privilege log.

Continuances not granted for prior trial settings unless attorney has commenced trial in another court.

Motions for extension of deadlines in the Scheduling and Docket Control Order are not emergencies and may not be treated as such.

Motions for extension of deadlines do not qualify as emergency motions.

Plaintiff may request a reasonable continuance if service has not been perfected.

Parties requesting Real Time Transcription must notify the Court at least three weeks prior to trial.

Proposed voir dire questions must be filed with the Joint Pretrial Order (JPO).

Objections to deposition designations must be filed at least three business days before the final pretrial conference, and objecting counsel bears the burden of securing a ruling before trial begins.

Leave of court is required to add or amend invalidity contentions after the service deadline.

The U.S. Probation Office must incorporate the Paroline findings into the defendant's PSI within 14 days of the Government's filing of its Paroline memorandum.

Original documents offered must be filed as soon as practicable.

Parties must promptly forward courtesy copies to Chambers of documents pertaining to matters to be heard by the Court within seven days after the document is filed; absent compliance, the Court will not consider documents filed within seven days of a court appearance.

Nevertheless, parties should submit courtesy hard copies to the Case Manager if any part of a filing is sealed.

Moving party must provide 2 courtesy copies of Responsive Brief and exhibits to the Court.

Two copies of documents filed during or within seven days prior to trial must be ready for the Court.

Courtesy copy of non-paper exhibit must be mailed to the Court's specified address.

A party requiring authentication of an exhibit must notify offering counsel in writing within five days after the exhibit is listed and made available, and failure to object in writing before trial concedes authenticity.

Responses and hearing requests for motions to dismiss must be filed within 20 days after service.

Counsel must notify offering counsel in writing within 7 days of exhibit identification to require authentication, or risk admission of authenticity.

Revised deposition designations must be provided to opposing counsel two days before intended use.

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.

Copies of supporting affidavits, deposition testimony excerpts, and other discovery referred to in the briefs should be separately filed in one or more appendices of no more than 40 pages each.

Briefs and memoranda limited to 20 pages including case style, table of contents/authorities, and signature block, absent leave for extended briefing.

Reply letters to pre-motion letters regarding discovery and scheduling disputes are prohibited.

Motions/responses limited to 5,000 words; replies limited to 2,000 words.

Motions are limited to 20 pages.

Any exhibits containing personal data identifiers must comply with S.D. Texas General Order #2004-11 (available at the District website).

Only the confidential portions of court filings should be placed under seal where possible, with non-confidential portions remaining public.

Filing documents under seal requires a motion establishing good cause, with redacted versions filed publicly, unredacted versions filed under seal, and proper SEALED designation on CM/ECF.

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.

Grand juror names must be kept confidential.

All motions should incorporate supporting briefs or authority and pertinent exhibits. Motions are not to exceed twenty pages. Briefs must be filed together with or incorporated within a motion, response, or reply.

Joint trial notebook required, materials paired in order listed; JPO first item in civil cases.

Counsel for each party is required to provide the Court with a copy of that party's exhibits in a properly tabbed and indexed notebook.

Joint Exhibit List is encouraged where possible.

Motions to seal and all exhibits to motions to seal must be filed as a single, combined document.

Electronic filings must comply with the Administrative Procedures for Electronic Filing in Civil and Criminal Cases.

Initial disclosures must not be filed with the court.

Parties must file copies of all letters sent to the Court.

Proposed findings of fact must be submitted electronically and via email to the Case Manager.

All parties must file documents electronically through the CM/ECF system per Local Rule 5.1.

The Court strongly encourages giving lawyers with less than seven years' experience primary speaking roles in conferences, trials, and evidentiary presentations, and will consider such participation in deciding whether to grant oral argument on motions it would otherwise decide on the papers.

Court encourages opportunities for lawyers with fewer than 7 years of experience to conduct hearings, especially those who contributed to the underlying motion or response.

Young lawyers (practicing less than 7 years) are encouraged to conduct hearings, especially for motions they drafted or contributed to.

Junior lawyers (licensed fewer than 7 years) are encouraged to receive speaking roles, especially if they drafted the motion/response or prepared the witness.

Court encourages lawyers with less than seven years of experience to conduct hearings, especially for motions they drafted or contributed to, to provide substantive speaking opportunities.

Debtors must pay the filing fee with the petition or promptly by the due date set in an installment-payment order.