Dallas County District Courts Pre-Motion Conference Requirements

CRITICALCivil cases

Unliquidated default judgment motions require a prove-up hearing.

Motions for Default Judgments where damages are un-liquidated will require a prove-up hearing.

CRITICAL

No counsel for a party shall file, nor shall any clerk set for hearing, any motion unless accompanied with a "Certificate of Conference" signed by counsel for movant in one of the forms set out in Rule 2.07(c). b. Prior to the filing of a motion, counsel for the potential movant shall personally attempt to contact counsel for the potential respondent to hold or schedule a conference to resolve the disputed matters. Counsel for the potential movant shall make at least three attempts to contact counsel for the potential respondent. The attempts shall be made during regular business hours on at least two business days.

No counsel for a party shall file, nor shall any clerk set for hearing, any motion unless accompanied with a "Certificate of Conference" signed by counsel for movant in one of the forms set out in Rule 2.07(c). b. Prior to the filing of a motion, counsel for the potential movant shall personally attempt to contact counsel for the potential respondent to hold or schedule a conference to resolve the disputed matters. Counsel for the potential movant shall make at least three attempts to contact counsel for the potential respondent. The attempts shall be made during regular business hours on at least two business days.

CRITICAL

Before filing a motion, movant's counsel must make at least three attempts to contact respondent's counsel during regular business hours on at least two business days.

Prior to the filing of a motion, counsel for the potential movant shall personally attempt to contact counsel for the potential respondent to hold or schedule a conference to resolve the disputed matters. Counsel for the potential movant shall make at least three attempts to contact counsel for the potential respondent. The attempts shall be made during regular business hours on at least two business days.

CRITICAL

Local Rule 2.07 requires a meaningful conference between opposing counsel before the Court will intervene.

Dallas Civil Courts Rule 2.07 requires a meaningful conference between opposing counsel prior to the Court's intervention.

CRITICALCivil cases

Parties must conference in compliance with local rules before filing a discovery motion.

The Court expects parties to conference in compliance with local rules prior to making motion regarding discovery disputes.

CRITICAL

Dallas Civil Courts Rule 2.07 requires a meaningful conference between opposing counsel before seeking the Court's intervention.

Dallas Civil Courts Rule 2.07 requires a meaningful conference between opposing counsel prior to the Court's intervention.

CRITICALCivil cases

Counsel must meaningfully confer on discovery issues and submit a Certificate of Conference that conforms to the Local Rules before any hearing is set.

Counsel must meaningfully confer on discovery issues and submit a Certificate of Conference that conforms to the Local Rules before any hearing is set.

CRITICAL

A meaningful conference between opposing counsel is required before the Court will intervene, per Dallas Civil Courts Rule 2.07.

Dallas Civil Courts Rule 2.07 requires a meaningful conference between opposing counsel prior to the Court's intervention.

WARNINGCivil cases

The Court will not conduct a Pre-Trial conference on matters the parties have not discussed and meaningfully attempted to resolve.

The Court will not conduct a Pre-Trial conference on matters the parties have not discussed and made a meaningful attempt to resolve.

WARNINGCivil casesCourt notice

Please discuss those exhibits and any motions in limine with the opposing side beforehand to see if any agreements can be reached that can shorten the pretrial.

Please discuss those exhibits and any motions in limine with the opposing side beforehand to see if any agreements can be reached that can shorten the pretrial.

WARNING

The certificate of conference requirement does not apply to dispositive motions, summary judgment motions, default judgments, and other listed motions.

Sections (a) and (b) of this Rule do not pertain to dispositive motions, motions for summary judgment, default judgments, motions to confirm arbitration awards, motions to exclude expert testimony, pleas to the jurisdiction, motions to designate responsible third parties, motions to strike designations of responsible third parties, motions for voluntary dismissal or nonsuit, post-verdict motions and motions involving service of citation.

WARNINGCivil cases

Parties must diligently confer before bringing discovery disputes to the Court.

The Court expects the parties to diligently confer prior to bringing discovery disputes before the Court.

WARNING

Parties must discuss exhibits and motions in limine with opposing side beforehand to seek agreements.

Please discuss those exhibits and any motions in limine with the opposing side beforehand to see if any agreements can be reached that can shorten the pretrial.

INFOCivil cases

Agreed motions are typically set for submission; non-agreed motions are set for oral hearing.

If the Motions are agreed, they are typically set for submission. If the Motions are not agreed, they are set for oral hearing.