Judge Jennifer Edgeworth
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Courtesy copies
- By Noon Day Before Hearing
Exhibit List, Witness List, Vocabulary List
Exhibits
Requested Relief
Adjournments
- A party seeking additional trial time must request leave of court at least 60 days before the initial trial setting.
Communication
Document Format Requirements14 rules
It is counsel’s responsibility to ensure that documents displayed on monitors have been first admitted in evidence and redacted, if necessary, to comply with the Court’s rulings.
Formatting
- •Displayed documents must be admitted in evidence before display on courtroom monitors
All exhibits shall be PRE- MARKED, three-hole punched on the left side, and in a three-ring binder notebook with numbered index tabs with the notebook labeled as to which party’s exhibits.
- Binding
- Three-ring binder
- Exhibits
Formatting
- •All exhibits must be premarked
- •All exhibits must be three-hole punched on the left side
- •The notebook must be labeled to identify the party’s exhibits
The documents must be in pdf format and pre-marked (or saved) by Exhibit No. For example, save each exhibit as a separate pdf, and name each pdf as PEX1, PEX2, etc.
- File type
Formatting
- •Name each PDF using the PEX-number convention, such as PEX1 and PEX2
VIDEO OR AUDIO RECORDING IS PROHIBITED. The public may view the proceeding while it is happening, but is prohibited from recording the proceeding.
The attorney calling the witness is responsible for ensuring the witness has a separate video and audio feed.
- Attorneys
(2) For a nonjury case, proposed findings of fact and conclusions of law should be emailed in editable Word format to Court Coordinator.
- File type
- Word
- Proposed findings conclusions
(1) For a jury case, a proposed jury charge should be emailed in editable Word format to Court Coordinator.
- File type
- Word
- Proposed jury charges
If three-hole punching the original exhibit will destroy a part of the exhibit, such exhibit may be placed in a plastic envelope in the exhibit notebook
Exhibits exceeding 8 ½” x 11” in size will be accompanied by an 8 ½” x 11” copy.
- More than 8 pages
If you are not able to provide a notebook, please have the exhibits three-hole punched.
Counsel shall not mark on or attach any item to an opposing counsel’s demonstrative exhibit while using it.
The pleading on this disk should be in 12 pitch font, free of any typographical emphasis i.e. bolding, all caps, underlining, italics, etc., and labeled with the case style and submitting party’s name.
- Font size
- 12 points
Formatting
- •Do not use bolding, all caps, underlining, italics, or other typographical emphasis
- •Label the document with the case style and the submitting party’s name
Attorneys should not attempt to “share” a connection with a witness.
- Attorneys
The parties should email the proposed jury charge questions, instructions, and definitions in Word format to the Court Coordinator by Noon on the Friday before the Jury Trial Setting.
Formatting
- •Word format
Document Filing Requirements18 rules
The motion for severance must be set either by submission or oral hearing and state the basis for the severance.
- Document
- Severance motion
Must include
- •State the basis for the severance
A severance order must identify the case style and number, severed-case parties, whether the case is disposed of or remains active, and the party paying severance costs.
Court's wording
The order of severance must include the following information: • Style of the case • Case number, i.e., 219-________ • Parties to be included in the severed case • Whether the severed order disposes of the severed case or if the case shall remain active • Party paying for cost of the severance
Unless prohibited by a confidentiality agreement or order, please state verbatim the request(s) and answer(s) in the body of your motion and attach a copy of the discovery request(s) and response(s) at issue.
When proving damages in a motion for default judgment, show the Court how you calculated the damage figure and provide evidence to support your calculation.
Always submit a proposed order whether you are the movant or respondent.
Include
- •Proposed order
All Rule 106 motions must be filed with a proposed order.
- Document
- Substituted service motion
Must include
- •Proposed order
A Rule 106 substituted-service motion must include a detailed affidavit describing verification efforts, at least three service attempts, people present and statements made, vehicle owners, or other indicia of residence.
Court's wording
All motions for substituted service under Rule 106 must be accompanied by an affidavit that describes the efforts taken to verify that the defendant actually lives or works at the subject address, at least three attempts of service at different times of day with the specific dates and times, the identity of person(s) present at the subject address and what was said, the identity of the owners of any cars in the driveway, or other indications that the defendant resides at the subject address.
Before trial, deposition testimony must be officially transcribed, and any video excerpts to be presented must be submitted to the court reporter in MP3 format.
Court's wording
Before trial begins, any deposition or video that will be presented during the trial will need to be submitted to the court reporter already officially transcribed, or if video excerpts are used, the video excerpts in MP3 format will need to be submitted to the Court Reporter.
The pleading should be named “[Name of Party]’s Proposed Jury Questions and Instructions” in Microsoft Word format and emailed to the Court Coordinator by the date of the Formal Pre-trial Conference.
Defense counsel must file a Writ or Motion before requesting a hearing.
Proposed orders should list each discovery issue separately.
- Document
- Proposed order
Should include
- •List each discovery issue separately
Please also make sure that a request for attorney’s fees submitted by affidavit complies with Rohrmoos Venture v. UTSA DVA Healthcare LLP, 578 S.W.3d 469 (Tex. 2019).
Please include on the proposed Jury Questions/Instructions a reference to where you obtained the specific jury question or instruction (Texas Pattern Jury Charge number or case cite).
This document should be exactly as it would be presented to a jury without signature blocks for the Judge for granting, denying or modifying any requests.
Vocabulary List (if one is filed): Required in medical malpractice cases.
The Subject Line of the email should say: Zoom Hearing Request – [Insert Cause No. of Case]
The subject line of the email should say: Zoom Hearing Exhibits of (Plaintiff/Petitioner/State or Defendant/Respondent) – Cause No.
Reports shall not be required of any non-retained experts unless the non-retained expert has opinions which have not reasonably been disclosed in business records, in response to a Request for Disclosure, or in deposition testimony.
Filing & Service rules
Electronic Filing Rules
A notice of hearing with the date and time completed must be filed electronically.
Please e-file a notice of hearing with the date and time filled in.
Page 5 | FAMILY LAW CASES
An Agreed Divorce Decree or Agreed Order must be electronically filed with all signatures.
You just need to efile the order with all the signatures.
Page 6 | FAMILY LAW CASES
Civil litigants must electronically file a completed notice of hearing with the agreed date.
Please e-file a notice of hearing with the date filled in.
Page 7 | CIVIL CASES
E-File your motion, get a date set with the Court, and bring a proposed order with you to the hearing.
E-File your motion, get a date set with the Court, and bring a proposed order with you to the hearing.
Page 8 | CRIMINAL CASES
Voluminous remote-hearing exhibits may be uploaded to the Court's Dropbox account, with Court Coordinator Amy Munger providing the link.
If you have voluminous exhibits, these exhibits may also be uploaded to the Court’s Dropbox account and Amy Munger can provide you with the link.
Page 2 | Using Exhibits at the Remote Hearing
Filing Timing and Cure Windows
Mediation is required before trial, and the parties must file a designation of an agreed mediator within 30 days after the Scheduling Order.
Mediation is required before trial. Parties must file a Designation of Agreed mediator within 30 days of the date of the Scheduling Order.
Page 5 | FAMILY LAW CASES
Parties must file their designation of an agreed mediator within 30 days from the date of the order.
30 days from the DESIGNATION OF AGREED MEDIATOR. Parties shall file with the Court their date of this Order designation of an Agreed Mediator.
Civil cases
Page 1 | DESIGNATION OF AGREED MEDIATOR
Parties must file and serve amended pleadings asserting new causes of action or defenses no later than 60 days before the initial trial setting.
60 days before AMENDED PLEADINGS. Parties shall file with the Court and serve all other parties Initial Trial Setting with any amended pleadings asserting new causes of action or defenses no later than this date.
Civil cases
Page 1 | AMENDED PLEADINGS
A party opposing affirmative relief that designates an expert must serve the expert designation and provide the expert's written report no later than 60 days before the initial trial setting.
60 days before AFFIRMATIVE RELIEF. If designating an expert, a party opposing affirmative relief Initial Trial Setting shall serve a designation of experts and provide written reports of such experts.
Civil cases
Page 2 | EXPERT DESIGNATION DEADLINE OF PARTIES OPPOSING AFFIRMATIVE RELIEF
All dispositive motions must be filed, set for hearing, and heard at least 30 days before trial.
30 days before trial DISPOSITIVE MOTIONS. All dispositive motions (summary judgment, etc.) must be filed, set for hearing, and heard at least thirty (30) days before trial.
Civil cases
Page 2 | DISPOSITIVE MOTIONS
A party seeking affirmative relief that designates an expert must serve the expert designation and provide the expert's written report no later than 90 days before the initial trial setting.
90 days before RELIEF. If designating an expert, a party seeking affirmative relief shall serve a Initial Trial Setting designation of experts and provide written reports of such experts.
Civil cases
Page 2 | EXPERT DESIGNATION DEADLINE OF PARTIES SEEKING AFFIRMATIVE RELIEF
An objection or motion to exclude or limit expert testimony must be filed, set for hearing, and heard at least 30 days before trial, or it is waived.
30 days before trial MOTIONS TO EXLUDE EXPERT TESTIMONY. Any objection or motion to exclude or limit expert testimony must be filed, set for hearing, and heard at least thirty (30) days before trial or it is waived.
Civil cases
Page 2 | MOTIONS TO EXLUDE EXPERT TESTIMONY
All discovery must be completed 30 days before trial.
30 days before trial DISCOVERY DEADLINE. All discovery shall be completed by this date.
Civil cases
Page 2 | DISCOVERY DEADLINE
Remote-hearing exhibits should be emailed before the hearing and preferably by noon on the preceding day.
If you intend to offer any exhibits during the Remote Hearing, please email them to all parties, the court coordinator Amy Munger, amunger@co.collin.tx.us and the court reporter Tonya Lebo, tlebo@co.collin.tx.us before the hearing begins, preferably by Noon the day before the hearing.
Page 2 | Using Exhibits at the Remote Hearing
Responses to amended pleadings, including affirmative defenses and special exceptions, may be filed within two weeks after the amended-pleadings deadline.
Responses to such Amended Pleadings, including any and all affirmative defenses and/or special exceptions may be filed within two (2) weeks after this deadline.
Civil cases
Page 1 | AMENDED PLEADINGS
Service and Proof of Service Rules
A party joining an additional party must serve the scheduling order on the new party concurrently with the joinder pleading.
NOTE: The party joining an additional party must serve a copy of this Order on the new party concurrently with the pleading joining the new party.
Civil cases
Page 1 | Joinder of Parties
The sender should copy opposing counsel or the self-represented litigant when emailing the Court.
Please also copy opposing counsel (or the self-represented litigant) when emailing the Court.
Page 7 | CIVIL CASES
The request should copy opposing counsel (or self-represented parties), and include emails of all parties and witnesses participating.
The request should copy opposing counsel (or self-represented parties), and include emails of all parties and witnesses participating.
Page 1 | PROCEDURES FOR LITIGANTS
Documents already electronically filed and accepted into the court file need not be resent to the court's email address.
Documents which have been e-filed and accepted into the Courts file do not need to be re-sent to the Court’s email.
Page 2 | Using Exhibits at the Remote Hearing
Courtesy Copy Requirements
Counsel submitting a courtesy notebook to the court must also provide an identical copy to opposing counsel.
If submitting a courtesy notebook to the Court, an identical copy must also be provided to opposing counsel.
Page 2 | ALL CASES
Copies of the exhibit list, witness list, and vocabulary list must be delivered to the court reporter at the pretrial conference.
Courtesy Copies for Court Reporter (To be delivered at Pretrial Conference): Exhibit List Witness List Vocabulary List
Page 4 | PROCEDURES FOR TRIAL
Each side should provide the Court with a copy of its Requested Relief at the beginning of a temporary-orders hearing or final trial.
For a temporary orders hearing and final trial, each side should provide to the Court a copy of their Requested Relief at the beginning of the hearing or trial.
Page 5 | FAMILY LAW CASES
For a larger motion involving extensive legal authority, the court requests a notebook by noon on the hearing day before, containing the relevant filings and highlighted legal authorities.
Please submit a notebook to the Court Coordinator by Noon the day before the hearing that includes the applicable motion, responses, replies, statutes and/or case law referenced with the referenced portions highlighted.
Page 2 | ALL CASES
The judge does not need a courtesy exhibit notebook for a jury trial but appreciates receiving one for a bench trial.
For a jury trial, the judge does not need her own courtesy copy of exhibits in notebooks. For a bench trial, the judge does appreciate a courtesy copy of a notebook of exhibits.
Page 3 | PROCEDURES FOR TRIAL
Sealing & Redaction Procedures
Parties cannot agree to seal a case; sealing requires court approval after an evidentiary hearing, and cases cannot be sealed before final trial.
Parties may not agree to seal cases. Sealing requires Court approval after an evidentiary hearing. Cases will not be sealed before final trial.
Page 6 | FAMILY LAW CASES
Pre-Motion Conference Requirements
A personal conference is required before filing any discovery-related motion.
Always personally confer before filing any motion related to discovery.
Page 2 | ALL CASES
Adjournment & Extension Requirements
Resetting or continuing the initial trial setting does not change existing deadlines unless the parties provide a Rule 11 agreement or the court orders otherwise after a good-cause motion.
Reset or continuance of the Initial Trial Setting will not alter any deadline established by this Order or established by the Texas Rules of Civil Procedure, unless specifically provided by Rule 11 of the parties or Court Order after motion showing good cause.
Civil cases
Page 1 | BENCH TRIAL SETTING
A party seeking additional trial time must request leave of court at least 60 days before the initial trial setting.
If additional time is requested, the parties must seek leave of Court at least 60 days before the Initial Trial Setting.
Civil cases
Page 1 | BENCH TRIAL SETTING
Failure to mediate cannot serve as the basis for requesting a continuance.
The failure to mediate is not a basis for a continuance.
Page 5 | FAMILY LAW CASES
A continuance of the final trial requires court approval, a verified motion, and an email to the coordinator requesting a hearing.
Court approval is required for any request for a continuance of the final trial date, even if the request is agreed to by all parties. File a verified motion for continuance and email the coordinator to request a hearing (by submission, by Zoom, or in person).
Page 5 | FAMILY LAW CASES
Any request to continue the final trial date requires court approval, even when all parties agree or it is the first request.
Court approval is required for any request for a continuance of the final trial date, even if the request is agreed to by all parties and even if it is the first request for a continuance.
Page 7 | CIVIL CASES
No additional affirmative defenses, inferential rebuttal defenses, or any other defensive theories shall be pled after this date without prior leave of court based upon a showing of good cause or by written Rule 11 agreement of the parties.
No additional affirmative defenses, inferential rebuttal defenses, or any other defensive theories shall be pled after this date without prior leave of court based upon a showing of good cause or by written Rule 11 agreement of the parties.
Civil cases
Page 1 | AMENDED PLEADINGS
Counsel seeking a continuance must review and follow Texas Rules of Civil Procedure 251 and 252.
Please review and follow Rules 251 and 252 of the Texas Rules of Civil Procedure when seeking a continuance.
Page 7 | CIVIL CASES
A reset or continuance of the initial trial setting does not change existing case or procedural deadlines unless the parties agree by Rule 11 or the court orders a change after a motion showing good cause.
Reset or continuance of the Initial Trial Setting will not alter any deadline established by this Order or established by the Texas Rules of Civil Procedure, unless specifically provided by Rule 11 Agreement of the parties or Court order after motion showing good cause.
Civil cases
Page 1 | TRIAL SETTING
Chambers Communication Rules
To obtain a hearing, email Amy Munger, copy opposing counsel or the pro se party, and agree on the hearing date and time.
You need to email Amy Munger to have a hearing set, copy opposing counsel(s)/pro se party, and agree to a hearing date and time.
Page 1 | Settings
After filing a default judgment motion, contact the Court Coordinator by email to schedule submission and state whether an oral hearing is requested.
Upon filing a default judgment, please contact the Court Coordinator by email and set a date for submission of the motion and let her know if you are requesting an oral hearing.
Page 2 | ALL CASES
A continuance request requires a verified motion and an email to the coordinator to request a hearing, which may be conducted by submission, Zoom, or in person.
File a verified motion for continuance and email the coordinator to request a hearing (by submission, by Zoom, or in person).
Page 5 | FAMILY LAW CASES
A remote-hearing request must include a cell phone number for each participant appearing only by telephone.
If any parties or witnesses are participating only by phone, you must include a cell phone number for them.
Page 1 | PROCEDURES FOR LITIGANTS
A remote-hearing request must be emailed to Court Coordinator Amy Munger by noon three business days before the hearing.
You must email the court coordinator, Amy Munger, at amunger@co.collin.tx.us by Noon three business days before the hearing.
Page 1 | PROCEDURES FOR LITIGANTS
Exhibits intended for use in a remote hearing must be emailed to all parties, the court coordinator, and the court reporter before the hearing, preferably by noon the preceding day.
If you intend to offer any exhibits during the Remote Hearing, please email them to all parties, the court coordinator Amy Munger, amunger@co.collin.tx.us and the court reporter Tonya Lebo, tlebo@co.collin.tx.us before the hearing begins, preferably by Noon the day before the hearing.
Page 2 | Using Exhibits at the Remote Hearing
When emailing the Court about a hearing, copy opposing counsel or the self-represented litigant.
Please also copy opposing counsel (or the self-represented litigant) when emailing the Court.
Page 5 | FAMILY LAW CASES
A party requesting to seal a case must contact the Court Coordinator to schedule a sealing hearing after the final judgment is signed.
If you are requesting to seal a case, please contact the Court Coordinator to schedule the hearing, which will be held after the final judgment is signed.
Page 6 | FAMILY LAW CASES
Email Court Coordinator Amy Munger to request a hearing date.
To set a hearing, please email the Court Coordinator, Amy Munger.
Page 5 | FAMILY LAW CASES
To set a civil hearing, email the Court Coordinator for available dates.
To set a hearing, please email the Court Coordinator, Amy Munger, for available dates.
Page 7 | CIVIL CASES
Criminal-case settings requests are made by email to Bailiff Patterson with the State copied and specified identifying information included.
Please contact Bailiff Patterson by email and copy the State (to include Defendant’s name, cause, and Attorney’s name).
Page 8 | CRIMINAL CASES