Judge Jill Renfro Willis
Individual Rules, Standing Orders & Policies
Adjournments
- A continuance or trial reset does not alter existing deadlines unless the parties agree under Rule 11 or the court orders a change after a motion showing good cause.
- A continuance or reset of the initial trial setting does not change existing deadlines unless the parties agree by Rule 11 or the court orders otherwise after a good-cause motion.
Request must include
Document Format Requirements3 rules
For a jury case, proposed jury charges (instructions, definitions, and questions) in hard copy and emailed in editable Word format to the Court Coordinator.
- File type
- Word
For a jury case, proposed jury charges (instructions, definitions, and questions) in hard copy and emailed in editable Word format to the Court Coordinator.
- File type
- Word
- Proposed jury charges
Formatting
- •Hard copy
The Court prefers descriptive markings, for example “H-1” for husband’s exhibits or “M-1” for mother’s exhibits.
Document Filing Requirements7 rules
Per Rule 191.2, all discovery motions or requests for hearing relating to discovery must contain a certificate of conference
- Document
- Discovery motion
Must include
- •Certificate of conference
b. Completed witness lists and exhibit lists.
Include
- •Exhibit list
c. All exhibits must be pre-marked for identification (for the purpose of stipulating to the authenticity and admissibility of exhibits).
Each party is directed to produce the following at the pre-trial conference:
a. Proposed jury charges (instructions, definitions, and questions) emailed in editable Word format to the Court Coordinator.
At the pretrial conference, each party must provide proposed jury charges in jury cases, completed witness and exhibit lists, premarked exhibits, and designations of deposition testimony for direct examination.
- Document
- Pretrial materials
Must include
- •Exhibit list
Court's wording
Each party is directed to produce the following at the pre-trial conference: 1) For a jury case, proposed jury charges (instructions, definitions, and questions) in hard copy and emailed in editable Word format to the Court Coordinator. 2) Completed witness lists and exhibit lists. 3) All exhibits must be produced to the court reporter pre-marked for identification (for the purpose of stipulating to the authenticity and admissibility of exhibits). 4) Designation of deposition testimony to be offered in direct examination.
**Per Rule 191.2, all discovery motions or requests for hearing relating to discovery must Date: contain a certificate of conference**
- Document
- Discovery motion
Must include
- •Certificate of conference
Filing & Service rules
Filing Timing and Cure Windows
Dispositive motions must be filed at least 30 days before trial.
All dispositive motions (summary judgment, plea to the before trial jurisdiction, plea in abatement, etc.) must be filed at least thirty (30) days before trial.
Civil cases
Page 1 | DISPOSITIVE MOTIONS
Written objections to Daubert/Dupont expert challenges must be filed at least 10 days before the hearing.
Unless good cause is shown, all Daubert/Dupont expert challenges shall be heard no later than the formal pre-trial, and written objections must be on file at least 10 days before hearing.
Civil cases
Page 1 | FORMAL PRE-TRIAL CONFERENCE
A motion to compel discovery responses must be filed within 14 days after the discovery deadline or the complaint is waived, except for exclusion under Rule 193.6.
Any motion to compel responses to discovery must be filed no later than 14 (fourteen) ______________ days after the discovery deadline or such complaint is waived, except for the sanction of (Date) exclusion under Rule 193.6.
Civil cases
Page 2 | IF THIS IS A LEVEL 3 CASE
Amended pleadings asserting new causes of action or defenses must be filed with the court and served on all other parties by the stated date.
Parties shall file with the Court and serve all other parties with any amended pleadings asserting new causes of action or defenses no later ______________ than this date.
Civil cases
Page 2 | IF THIS IS A LEVEL 3 CASE
Responses to amended pleadings, including affirmative defenses or 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 2 | IF THIS IS A LEVEL 3 CASE
Pretrial disclosures must be made at least 30 days before trial.
Parties are required to comply with Rule 194.4 (pretrial disclosures must be made at least 30 days before trial).
Civil cases
Page 1 | Formal Pre-Trial Conference
All pretrial motions must be filed at least 10 days before the formal pretrial conference and heard at that conference.
All pre-trial motions (motions in limine, etc.) shall be filed at least 10 days before the formal pre-trial conference and will be heard at the formal pre-trial conference.
Civil cases
Page 1 | Formal Pre-Trial Conference
A motion to compel discovery responses must be filed within 10 days after discovery closes, or the complaint is waived except for exclusion under Rule 193.6.
Any motion to compel responses to discovery days after must be filed no later than 10 (ten) days after the close of the discovery period or such discovery period complaint is waived, except for the sanction of exclusion under Rule 193.6.
Civil cases
Page 2 | Motions to Compel Discovery
Joinder of additional parties must occur no later than five months after commencement of the case, absent leave of court on a good-cause motion.
No later than 5 months after commencement of the case
Civil cases
Page 2 | Joinder of Parties
Summary-judgment motions must be filed, set, and heard at least 30 days before trial or they are waived absent leave of court.
motions for summary judgment Initial Trial Setting motions must be filed, set for hearing, and heard at least thirty (30) days before trial or they are waived, absent leave of court.
Civil cases
Page 2 | Motions for Summary Judgment
An objection or motion to exclude or limit expert testimony must be filed at least 30 days before trial and heard by the pretrial conference, absent leave of court.
Any objection or motion to exclude Initial Trial Setting or limit expert testimony must be filed at least thirty (30) days before trial and heard at or before the pre-trial conference or it is waived. **This deadline cannot be moved without Date: leave of court**
Civil cases
Page 2 | Motions to Exclude Expert Testimony
Daubert/Dupont expert challenges must be filed at least ten days before the hearing or trial.
All Daubert/Dupont expert challenges must be filed at least ten (10) days before hearing/trial.
Civil cases
Page 1 | Bench Trial Setting
All dispositive motions must be filed at least thirty days before trial.
All dispositive motions (summary judgment, plea to the before trial jurisdiction, plea in abatement, etc.) must be filed at least thirty (30) days before trial.
Civil cases
Page 1 | Dispositive Motions
A motion to compel discovery responses must be filed within fourteen days after the discovery deadline, subject to the stated Rule 193.6 exception.
Any motion to compel responses to discovery must be filed no later than 14 (fourteen) ______________ days after the discovery deadline or such complaint is waived, except for the sanction of (Date) exclusion under Rule 193.6.
Civil cases
Page 1 | Discovery Deadline
Amended pleadings asserting new causes of action or defenses must be filed with the court and served on all other parties by the stated deadline.
Parties shall file with the Court and serve all other ______________ parties with any amended pleadings asserting new causes of action or defenses no later (Date) than this date.
Civil cases
Page 1 | Amended Pleadings
Parties seeking affirmative relief have a stated deadline for expert designation.
EXPERT DESIGNATION DEADLINE OF PARTIES SEEKING ______________ AFFIRMATIVE RELIEF.
Civil cases
Page 2 | IF THIS IS A LEVEL 3 CASE
Parties opposing affirmative relief have a stated deadline for expert designation.
EXPERT DESIGNATION DEADLINE OF PARTIES OPPOSING ______________ AFFIRMATIVE RELIEF
Civil cases
Page 2 | IF THIS IS A LEVEL 3 CASE
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
Amended pleadings asserting new claims, affirmative relief, or defenses must be filed with the court and served on all other parties by the scheduling-order deadline.
Parties shall file with the Court and serve all other parties with any amended pleadings asserting new causes of action/claims for affirmative relief or defenses by this date.
Civil cases
Page 1 | Amended Pleadings
A party joining an additional party must serve the scheduling order on the new party concurrently with the joinder pleading.
The party joining an additional party must serve a copy of this Order on the Date: new party concurrently with the pleading joining the new party.
Civil cases
Page 1 | Joinder of Parties
Parties seeking affirmative relief must serve their expert designations and provide the experts' written reports by the scheduling-order deadline.
Parties Initial Trial Setting seeking affirmative relief shall serve his/her/its designation of experts and provide written reports of such experts.
Civil cases
Page 2 | Expert Designations of Party Seeking Affirmative Relief
Parties opposing affirmative relief must serve their expert designations and provide the experts' written reports by the scheduling-order deadline.
Parties opposing affirmative relief shall serve his/her/its designation of experts and provide written reports of such experts.
Civil cases
Page 2 | Expert Designations of Party Opposing Affirmative Relief
Parties Initial Trial Setting seeking affirmative relief shall serve his/her/its designation of experts and provide written reports of such experts.
Parties Initial Trial Setting seeking affirmative relief shall serve his/her/its designation of experts and provide written reports of such experts.
Civil cases
Page 2 | Designation of Rebuttal Experts
Amended pleadings asserting new claims, affirmative relief, or defenses must be filed with the court and served on all other parties by the scheduling-order deadline.
AMENDED PLEADINGS. Parties shall file with the Court and serve all other parties with any amended pleadings asserting new causes of action/claims for affirmative relief or defenses by this date.
Civil cases
Page 1 | Amended Pleadings
Parties must serve all other parties with amended pleadings asserting new causes of action or defenses by the stated deadline.
Parties shall file with the Court and serve all other ______________ parties with any amended pleadings asserting new causes of action or defenses no later (Date) than this date.
Civil cases
Page 1 | Amended Pleadings
Adjournment & Extension Requirements
A continuance or trial reset does not alter existing deadlines unless the parties agree under 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 of the parties or Court order after motion showing good cause.
Civil cases
Page 1 | Trial Setting
A continuance or reset of the initial trial setting does not change existing deadlines unless the parties agree by Rule 11 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 | Trial Setting