New: a trial court in 1 of every 10 U.S. counties. Read the post
Court Rules
Judge

Judge Erica R. Hughes

Individual Rules, Standing Orders & Policies

Harris County District Courts

Limits & Logistics

Courtesy Copies

Mandamus Petition

Proposed Findings Conclusions

  • Email • Upon Filing

Adjournments

  • A summary-judgment motion cannot be passed; the party must proceed or withdraw, and a reset request must comply with Rule 166a and is allowed only if that rule authorizes it.
  • The standard docket control order does not require ADR; parties who consider mediation appropriate should schedule it promptly and should not wait until the trial period is near to seek a continuance for mediation.
  • Trial or pretrial-deadline continuance motions must include an appropriate affidavit unless agreed, and should be filed early.
  • +2 more

Request must include

Reason for Request

Communication

Phone

Clerk

832-927-2450
Scheduling
Phone

Clerk

713-368-6222
Phone

Clerk

SchedulingEmergencies
Email
Court-wide
246hearings@justex.net
Scheduling
Email
Court-wide
melissa_love@justex.net
Filters:

Document Format Requirements5 rules

FormattingMandatoryCivil cases

Do not alter or mark through exhibits with pen/pencil/marker during court proceedings. Should this occur, the exhibit (s) will not be accepted.

Harris:section:40
|Section8. TRIALS — A) Pretrial Orders/Exhibits/Motions in Limine
FormattingImportantCivil cases

Mark an 8 x 11 size exhibit for any blowup used.

Harris:section:40
|Section8. TRIALS — A) Pretrial Orders/Exhibits/Motions in Limine
FormattingImportantCivil cases

In some instances, the Court may require that longer or more complex proposed orders be emailed to the Clerk in Word format. When submitting a proposed order, include a cover letter stating whether the order is agreed as to form.

Harris:section:40
|Section6. PROPOSED ORDERS
FormattingImportantCivil cases

Only after assignment to trial, the parties should email the Trial Coordinator their proposed charge in Microsoft Word format.

File type
Word

Court's wording

Only when actually assigned to trial, the parties should email the Trial Coordinator their proposed charge to the court in Microsoft Word format so that the court may compile the court’s charge as the trial proceeds.

Harris:section:40
|Section8. TRIALS — D) Court’s Charge
FormattingNoteCivil cases

Although not required, the Court considers PDF files exchanged by flash drive, email attachments, or a cloud link to be the best and least expensive practice.

Court's wording

The court finds that the best and least expensive practice (this is not required) is to create .pdf (Adobe) files of these filings and the exhibits and exchange them on a flash drive or by sending them to opposing counsel an e-mail with attachments. A link to a cloud-based version of these documents is also acceptable.

Harris:section:40
|Section8. TRIALS — A) Pretrial Orders/Exhibits/Motions in Limine

Document Filing Requirements53 rules

Filing RequirementsMandatoryCivil cases

The motion and proposed order must identify each discovery issue separately. Proposed orders shall list each disputed request or objection individually, allowing the Court to grant or deny relief as to each item.

Harris:section:40
|SectionC. Discovery Disputes
Filing RequirementsMandatoryCivil cases

Counsel are responsible for ensuring that all cited authorities exist and are accurately quoted.

Harris:section:40
|SectionCitations and Hyperlinks
Filing RequirementsMandatoryCivil cases

Please explicitly identify by page and paragraph the pleading or portion thereof to which you are specially excepting (unless the special exception is only to the maximum amount of damages sought pursuant to TRCP 47).

Harris:section:40
|SectionG. Special Exceptions
Filing RequirementsMandatoryCivil cases

Provide page/line for any witness anticipated to testify by deposition PRIOR to the docket call.

Harris:section:40
|Section8. TRIALS — B) Depositions
Filing RequirementsMandatoryCivil cases

Include an explicit certificate of conference as described in the section of these procedures titled “Certificates of Conference”.

Include

  • Certificate of conference
Harris:section:40
|SectionDiscovery Motions
Filing RequirementsMandatoryCivil cases

Every continuance or reset motion must identify its number, whether agreed, unopposed, or opposed.

Court's wording

In addition, ALL continuance or reset motions (whether agreed, unopposed or opposed) MUST state what number continuance motion is being filed (i.e. "Plaintiff’s First” or “Defendant’s Second” or “Third Agreed Motion,” etc.).

Harris:section:40
|SectionAgreed Motions
Filing RequirementsMandatoryCivil cases

A Rule 106 motion must include an affidavit detailing residence-verification efforts, each service attempt, persons encountered and statements, and evidence confirming the address, with the specified identifying details.

Court's wording

All motions for substituted service under Rule 106 must be accompanied by an affidavit that includes the following information: ·Efforts taken to verify that defendant actually lives or works at the subject address; ·Each attempt at service, with date(s) and time(s); ·Identity of persons who were present at the subject address and what was said; and · A printout of some public record or Public Data.com or similar online database confirming that the person to be served actually resides at the address at which service is being attempted. This can also include a statement identifying license plates of cars in the driveway and attaching a printout of license plates registered to the person to be served. Statements by neighbors or by people residing in the abode must include the full name of the person and a description. The idea is to give the court some assurance that the person resides at that address.

Harris:section:40
|SectionH. Substitute Service (Rule 106)
Filing RequirementsMandatoryCivil cases

If the parties request or agree to a summer trial setting, they must also expressly waive any vacation letters that would conflict with that setting.

Harris:section:40
|Section8. TRIALS — K) Summer Trials
Filing RequirementsMandatoryCivil cases

If you are requesting damages or fees, the Court requires you to provide exhibits to prove up the damages sought.

Harris:section:40
|SectionD. Default Judgments
Filing RequirementsMandatoryCivil cases

Certificates should summarize reasonable conference efforts; sending a motion, email, or voicemail alone is not a conference, and repeated unanswered contact attempts should be described.

Court's wording

Please summarize your reasonable efforts in your certificate. Note: sending a copy of a motion, without more, is not a conference. Sending an e-mail or leaving a telephone message, without more, is not a conference. If opposing counsel refuses to return numerous phone calls or other messages, describe your efforts to confer in your certificate of conference.

Harris:section:40
|Section5. CERTIFICATES OF CONFERENCE
Filing RequirementsMandatoryCivil cases

To withdraw a summary-judgment motion, file a written notice with the specified title and identify the motion’s original filing date.

Court's wording

To withdraw a motion for summary judgment, the party must file a written notice of withdrawal with the Court. The notice shall be titled “Notice of Withdrawal of Motion for Summary Judgment” and, pursuant to Rule 166a, as amended, must identify the date the motion was originally filed.

Harris:section:40
|Section7. HEARINGS — G) Summary Judgments
Filing RequirementsMandatoryCivil cases

Request the Lien Holder issue a notice for hearing.

Harris:section:40
|SectionTAX TRIAL CASES
Filing RequirementsMandatoryCivil cases

All requests for attorney’s fees as sanctions MUST be established by affidavit (preferred) or live testimony as to reasonableness and necessity (and meet other legal requirements), unless the parties agree on the record, in a filed Rule 11 Agreement, or an agreed order as to the amount.

Harris:section:40
|SectionE. Sanctions
Filing RequirementsMandatoryCivil cases

Please make clear in your motion and proposed judgment whether the judgment will be final (disposing of all claims and all parties) or interlocutory (partial).

Harris:section:40
|SectionD. Default Judgments
Filing RequirementsMandatoryCivil cases

Please submit the proper non-military affidavit by visiting the Defense Manpower Data Center’s (DMDC) Military Verification service athttps://scra.dmdc.osd.mil. A Certificate of Last Known Address must be filed.

Harris:section:40
|SectionD. Default Judgments
Filing RequirementsMandatoryCivil cases

The address on the notice must match the last known address in the petition.

Harris:section:40
|SectionTAX TRIAL CASES
Filing RequirementsMandatoryCivil cases

The certificates of conference required by the TRCP are extended to all motions, pleas and special exceptions except summary judgments, default judgments, agreed judgments, motions for voluntary dismissal or non-suit, post-verdict motions and motions involving service of citation.

Document
Motions pleas and special exceptions

Must include

  • Certificate of conference
Harris:section:40
|Section5. CERTIFICATES OF CONFERENCE
Filing RequirementsMandatoryCivil cases

Once you have scheduled any hearing date with the court clerk, follow up with a notice of oral hearing or (if applicable) notice of written submission.

Harris:section:40
|SectionFILINGS AND COURTESY COPIES
Filing RequirementsMandatoryCivil cases

Responses that are filed after the response deadline provided for in the rules MUST be accompanied by a separate motion for leave to late file the response with a proposed order.

Document
Late response

Must include

  • Proposed order
Harris:section:40
|Section4. RESPONSES/REPLIES/OBJECTIONS
Filing RequirementsMandatoryCivil cases

If a movant requests an oral hearing, the request must appear in the title of the motion.

Harris:section:40
|Section7. HEARINGS — G) Summary Judgments
Filing RequirementsMandatoryCivil cases

Be sure to submit the discovery response(s) at issue as sub-documents when e-filing, or state verbatim the request and answer in the body of your motion.

Harris:section:40
|SectionDiscovery Motions
Filing RequirementsMandatoryCivil cases

If citing an unpublished opinion, counsel shall provide the Westlaw citation. The Court does not use Lexis; Lexis citations are not acceptable unless a copy of the unpublished opinion is provided to the Court.

Harris:section:40
|SectionCitations and Hyperlinks
Filing RequirementsMandatoryCivil cases

A discovery motion or hearing request must certify that a reasonable effort to resolve the dispute without court intervention was made and failed.

Court's wording

All discovery motions or requests for hearings relating to discovery must contain a certificate by the party filing the motion or request that a reasonable effort has been made to resolve the dispute without the necessity of Court intervention and the effort failed.

Harris:section:40
|Section5. CERTIFICATES OF CONFERENCE
Filing RequirementsMandatoryCivil cases

File your motion or other document with a certificate of service, (include certificate of conference as required by the TRCP) and a proposed order each time you ask the Court to grant or deny relief.

Document
Motion or other document seeking relief

Must include

  • Proposed order
  • Certificate of service
  • Certificate of conference
Harris:section:40
|SectionFILINGS AND COURTESY COPIES
Filing RequirementsMandatoryCivil cases

The attorney filing the notice must include the Zoom link for the 151st District Court. The notice MUST be filed with the Zoom information.

Harris:section:40
|Section7. HEARINGS — F) Minor Settlements
Filing RequirementsMandatoryCivil cases

Do not combine multiple motions into a single proposed order.

Harris:section:40
|Section6. PROPOSED ORDERS
Filing RequirementsMandatoryCivil cases

Severance motions and orders must include the new case details, parties, transferred pleadings and document metadata, cost-assessed attorney, case status and finality, whether the severed case remains active, and responsibility for costs and fees.

Court's wording

All motions and orders for severance must contain the following: ·New case number, court number, case type and new style name; ·Reference the parties in the new suit; ·List of original pleadings to be severed out and transferred to the new case (together with a listing of the document type, activity date for the document, number of pages and image number); ·Indicate attorney name, address and bar number to whom costs for the severance are to be assessed; and ·Indicate the severance case's status, and whether the new case file is interlocutory (not a final appealable matter) or whether severance will cause the newly severed matter to be final and appealable upon severance. As an example, if a plaintiff obtains a summary judgment as to one of multiple defendants and severs the disposed claims against that defendant into a new cause, that severance order will start the appellate timelines because all claims in the new cause will be resolved as to all claims and all parties. This should be expressly stated one way or the other in the motion for severance. Whether the severance order disposes of the severed case or whether the severed case will remain active; and The party responsible for payment of court costs and severance fees.

Harris:section:40
|SectionF. Severances
Filing RequirementsMandatoryCivil cases

Please clearly identify your request for an oral hearing or your request to continue the hearing by filing them separately from your response with proposed orders attached.

Document
Request for oral hearing or to continue hearing

Include

  • Proposed order
Harris:section:40
|Section7. HEARINGS — D) Submission Docket
Filing RequirementsMandatoryCivil cases

If you wish to pass an oral hearing or submission setting. Pass the setting on the e-Hearing system and/or efile a Notice to Pass the hearing. Specify the time, date and motion to be discussed.

Harris:section:40
|SectionTO PASS A HEARING (SUBMISSION/ORAL)
Filing RequirementsMandatoryCivil cases

A Guardian ad Litem is required in all settlements involving minor children. The parties shall file an Agreed Motion and Proposed Order for Appointment of Guardian ad Litem.

Document
Settlement involving minor children

Must include

  • Proposed order
Harris:section:40
|SectionSETTLEMENTS INVOLVING CHILDREN
Filing RequirementsMandatoryCivil cases

ALL continuance or reset motions (whether agreed, unopposed or opposed) MUST state what number continuance motion is being filed (i.e.“Plaintiff’s First” or “Defendant’s Second” or “Third Agreed Motion,”etc.).

Harris:section:40
|SectionI. Trial Continuances
Filing RequirementsMandatoryCivil cases

A motion and proposed order to withdraw must address client notice and mailing evidence, consent, client contact details, the client’s right to object or respond, reasonable efforts to find substitute counsel, and a certificate of conference.

Document
Motion and order to withdraw as attorney

Must include

  • Certificate of conference

Court's wording

All motions and proposed orders to withdraw as attorney of record must contain the following: ·An indication that the motion to withdraw and notice of the hearing or notice of submission was provided to the client, including evidence of mailing the motion to the client; ·An indication of whether or not the client consents to the motion; ·The last known mailing address, email, phone and fax number of client(s); and ·Notice to client that client has the right to appear at the hearing to object to the motion or file a response prior to the submission of the motion; ·Please make reasonable efforts to find substitute counsel in the appropriate case so that the client’s interests are protected; ·These motions DO require a certificate of conference, as opposing counsel has a right to be heard on these motions.

Harris:section:40
|SectionJ. Withdrawal as Attorney of Record
Filing RequirementsMandatoryCivil cases

Final orders MUST state that the order disposes of all claims and all parties and is intended to be a final, appealable order.

Harris:section:40
|Section9. VOLUNTARY NON-SUITS/DISMISSALS/JUDGMENTS
Filing RequirementsMandatoryCivil cases

Motions must include required certificates of conference explicitly describing efforts to resolve the motion with all other parties or counsel before filing.

Document
Motion

Must include

  • Certificate of conference

Court's wording

All motions must have certificates of conference as required by the Texas Rules of Civil Procedure and our local rules. All certificates of conference must be explicit as to the party’s efforts to resolve the motion with all other parties/counsel prior to filing.

Harris:section:40
|Section5. CERTIFICATES OF CONFERENCE
Filing RequirementsMandatoryCivil cases

If amendments are made, the parties must either file the amended proposed judgment or present a copy at the hearing with all changes from the previously filed version clearly highlighted.

Harris:section:40
|SectionSETTLEMENTS INVOLVING CHILDREN
Filing RequirementsMandatoryCivil cases

A default-judgment request for attorney’s fees must include an affidavit with competent evidence addressing counsel’s experience, work performed, time spent, and hourly rate.

Court's wording

When seeking attorney’s fees in a motion for default judgment, the movant must include an affidavit providing competent evidence to support the claim. At a minimum, the affidavit should address: (1) counsel’s experience; (2) the work performed in the case; (3) the time spent performing that work; and (4) the hourly rate charged.

Harris:section:40
|SectionD. Default Judgments
Filing RequirementsMandatoryCivil cases

If the defaulting party was served at an address different from the one listed on the citation, the movant must file a Motion to Amend Citation. This motion should request that the citation be amended to reflect the address where valid service was achieved and should include a proposed Order to Amend Citation.

Document
Motion to amend citation

Must include

  • Proposed order
Harris:section:40
|SectionD. Default Judgments
Filing RequirementsMandatoryCivil cases

In a non-jury trial, proposed Findings of Fact and Conclusions of Law MUST be filed prior to trial to enable the court to follow along during trial.

Harris:section:40
|Section8. TRIALS — E) Findings of Fact/Conclusions of Law
Filing RequirementsImportantCivil cases

Parties are encouraged to quote the challenged paragraphs verbatim in the proposed order and provide a sustained/overruled choice for each exception.

Court's wording

Parties are encouraged to restate verbatim the paragraph(s) to which your special exceptions apply in the proposed order and provide blanks in which the Court may check "sustained" or "overruled" as to each separate matter to which the movant is specially excepting.

Harris:section:40
|SectionG. Special Exceptions
Filing RequirementsImportantCivil cases

The Court may pass any hearing on a motion filed without a proposed order.

Harris:section:40
|Section6. PROPOSED ORDERS
Filing RequirementsImportantCivil cases

If a party was unable to reach the other side prior to filing the motion, the certificate should state the efforts to communicate with that party and should always be supplemented as soon as possible after the parties have actually conferred.

Harris:section:40
|Section5. CERTIFICATES OF CONFERENCE
Filing RequirementsImportantCivil cases

All dismissals should be filed with prejudice.

Harris:section:40
|Section9. VOLUNTARY NON-SUITS/DISMISSALS/JUDGMENTS
Filing RequirementsImportantCivil cases

Please index your exhibits.

Harris:section:40
|SectionFILINGS AND COURTESY COPIES
Filing RequirementsImportantCivil cases

All unopposed or agreed motions should be titled as such.

Harris:section:40
|SectionAgreed Motions
Filing RequirementsImportantCivil cases

All non-suits, dismissals and judgments should be titled as interlocutory or final. Interlocutory orders should expressly list which parties and claims are being dismissed and which remain, if any.

Harris:section:40
|Section9. VOLUNTARY NON-SUITS/DISMISSALS/JUDGMENTS
Filing RequirementsImportantCivil cases

If a motion is actually agreed, the motion and order should contain signature blocks for all parties that are agreed to the relief requested and should state “AGREED AS TO SUBSTANCE AND FORM AND ENTRY REQUESTED” above the signature block.

Harris:section:40
|SectionAgreed Motions
Filing RequirementsImportantCivil cases

All motions should be accompanied with an Order.

Harris:section:40
|SectionAgreed Motions
Filing RequirementsImportantCivil cases

Motions and notices of non-suit as well as orders of non-suit should expressly state that they are being filed pursuant to Rule 162 of the Texas Rules of Civil Procedure.

Harris:section:40
|Section9. VOLUNTARY NON-SUITS/DISMISSALS/JUDGMENTS
Filing RequirementsImportantCivil cases

If you are seeking to dismiss or nonsuit a minor's claim, the Court will want to know whether the minor is receiving a settlement to determine whether a Guardian Ad Litem should be appointed.

Harris:section:40
|SectionNONSUITS INVOLVING MINORS
Filing RequirementsImportantCivil cases

Any Rule 106 Motion should be accompanied by this form proposed order. Failure to do so may delay the court’s granting of an otherwise proper motion.

Document
Rule 106 motion

Should include

  • Proposed order
Harris:section:40
|SectionH. Substitute Service (Rule 106)
Filing RequirementsImportantCivil cases

Please work together to prepare a joint questionnaire that is as brief as possible.

Harris:section:40
|Section8. TRIALS — H) Voir Dire
Filing RequirementsImportantCivil cases

Separately, if there are “form” objections in the deposition transcript that cannot be agreed upon, the party seeking to overrule the objection should file a motion for a ruling on these.

Harris:section:40
|Section8. TRIALS — B) Depositions
Filing RequirementsNoteCivil cases

The Court prefers that the Supreme Court Ad Litem Fee Report be filed in advance of the hearing; however, it is not required in order to obtain a hearing date.

Harris:section:40
|SectionSETTLEMENTS INVOLVING CHILDREN

Filing & Service rules

Electronic Filing Rules

A party seeking an emergency hearing when the other side does not agree must e-file a motion for emergency hearing.

If only one side thinks it is an emergency, efile a motion for emergency hearing.

Civil cases

Page 1 | 7. HEARINGS — B) Emergencies

Documents must be e-filed through efiletexas.gov, subject to exceptions permitted by the Texas Supreme Court’s e-filing rules.

All documents shall be filed electronically through efiletexas.gov except as permitted by the Texas Supreme Court's e-filing rules effective January 1, 2014.

Civil cases

Page 1 | FILINGS AND COURTESY COPIES

Parties need not appear in person to announce settlement if an e-filed Notice of Settlement is on file.

Parties are not required to appear in person to announce a settlement if a Notice of Settlement is on file (efiled).

Civil cases

Page 1 | SETTLEMENT ANNOUNCEMENTS

Filing Timing and Cure Windows

File the appointee fee and proposed final judgment 24 hours before the minor-settlement hearing.

Please ensure the appointee fee and proposed final judgment are filed 24 hours prior to the hearing.

Civil cases

Page 1 | 7. HEARINGS — F) Minor Settlements

The Court Clerk will remove noncompliant motions from the docket and notify the requesting party.

PLEASE NOTE: The Court Clerk will remove from the docket any motions that do not comply with this rule and will notify the requesting party of the same.

Civil cases

Page 1 | 5. CERTIFICATES OF CONFERENCE

The first motion to retain may be granted only if substitute service was granted at least six months before filing.

The first Motion to Retain may be granted only if a Motion for Substitute Service was granted at least 6 months prior to the filing.

Civil cases

Page 1 | L. Motion to Retain

Expert-exclusion motions should be filed and set well before trial; a motion filed after the docket-control-order deadline will not be considered without leave demonstrating exceptionally good cause.

All motions to exclude experts should be filed AND set for hearing WELL IN ADVANCE OF TRIAL. The court will NOT consider such motions filed after the deadline in the docket control order without a motion for leave demonstrating exceptionally good cause.

Civil cases

Page 1 | K. Daubert Motions (Exclusion of Expert Witness Testimony)

A final judgment or other dispositive e-filing should be submitted within 14 days after settlement notice, or the case may be dismissed; the Court may extend the deadline if appropriate.

If a final judgment or other dispositive efiling is not submitted within fourteen (14) days after the Court is notified of the settlement, the case may be dismissed for want of prosecution. The Court may extend this deadline if appropriate.

Civil cases

Page 1 | SETTLEMENT ANNOUNCEMENTS

File a proposed Final Judgment before contacting the Clerk for a minor-settlement hearing date.

A proposed Final Judgment must be filed before contacting the Clerk to obtain a hearing date on the minor’s settlement.

Civil cases

Page 1 | SETTLEMENTS INVOLVING CHILDREN

The submission docket is Monday at 8:00 a.m. and requires 10 days’ notice.

Submission docket is on Monday at 8:00 AM after 10 days’ notice.

Civil cases

Page 1 | 7. HEARINGS — D) Submission Docket

Submit disputed jury-questionnaire questions to Judge Hughes by submission or oral hearing before docket call.

If there are any questions not agreed on, you need to present them to Judge Hughes by submission or oral hearing PRIOR to the docket call.

Civil cases

Page 1 | 8. TRIALS — H) Voir Dire

Parties should make every effort to file necessary replies or sur-replies by Thursday before a Monday hearing.

Please do everything in your power to file any necessary replies (or sur-replies, etc.) by Thursday before a Monday hearing.

Civil cases

Page 1 | 4. RESPONSES/REPLIES/OBJECTIONS

If objections remain, then the party seeking to exclude the testimony should file a motion to rule on the objections as soon as possible so that the court can promptly rule on the objections prior to voir dire.

If objections remain, then the party seeking to exclude the testimony should file a motion to rule on the objections as soon as possible so that the court can promptly rule on the objections prior to voir dire.

Civil cases

Page 1 | 8. TRIALS — B) Depositions

Replies filed after noon Friday for a Monday oral hearing are unlikely to be considered.

Any replies that are filed after Friday at NOON for a Monday oral hearing are NOT LIKELY to be considered by the Court.

Civil cases

Page 1 | 4. RESPONSES/REPLIES/OBJECTIONS

The Court may refuse to consider responses or replies filed after noon Friday before a Monday oral hearing or submission.

The Court reserves the right to refuse to consider responses or replies filed after noon on a Friday before a Monday oral hearing or submission setting.

Civil cases

Page 1 | 7. HEARINGS — C) Law Day Docket

Service and Proof of Service Rules

If an emergency hearing is granted, the movant must give proper notice to all parties.

If an emergency hearing is granted, the movant is responsible for providing proper notice of the hearing to all parties.

Civil cases

Page 1 | 7. HEARINGS — B) Emergencies

After obtaining a hearing date through the e-Hearing system, file a notice of oral hearing and serve all counsel and self-represented litigants.

Once you obtain a hearing date from the e-Hearing system, file a notice of oral hearing and serve it on all counsels and/or pro se litigants.

Civil cases

Page 1 | 7. HEARINGS — C) Law Day Docket

Before docket call, parties must exchange proposed jury charges, motions in limine, exhibit lists and exhibits, party/attorney lists, witness lists, and deposition excerpts.

This court requires the parties to actually exchange proposed jury charges, motions in limine, exhibit lists, actual exhibits, party/attorney lists, witness lists, and deposition excerpts BEFORE the docket call, which is usually conducted by the coordinator via email the Friday that is 10 days before the beginning of the two-week trial docket.

Civil cases

Page 1 | 8. TRIALS — A) Pretrial Orders/Exhibits/Motions in Limine

The movant must give defaulting parties and other appearing parties 10 days’ notice of the hearing and motion by regular and certified mail, and certify service.

The Court requires the movant to provide defaulting parties, as well as any other parties who have appeared in the case, with 10 days’ notice of the hearing and the default motion. Notice must be sent via regular and certified mail, and the movant must certify this action in a certificate of service.

Civil cases

Page 1 | D. Default Judgments

Most oral hearings require 10 days’ notice to opposing counsel unless all parties agree to shorten the notice period.

For most motions, the court requires 10 days’ notice to opposing counsel for an oral hearing, unless shortened by agreement of all parties.

Civil cases

Page 1 | 7. HEARINGS — C) Law Day Docket

The movant must give proper written hearing notice to the Court and all parties and timely advise opposing counsel if passing the hearing.

It is the movant’s responsibility to provide proper written notice of the hearing to the Court and to all parties. It is also the movant’s responsibility to timely advise opposing counsel if he/she is passing the hearing.

Civil cases

Page 1 | 7. HEARINGS — C) Law Day Docket

Draft proposed jury charges should be exchanged before docket call.

Drafts of proposed jury charges should be exchanged PRIOR to the docket call date.

Civil cases

Page 1 | 8. TRIALS — D) Court’s Charge

Courtesy Copy Requirements

The Court does not accept paper or emailed courtesy copies; a party may call after e-filing to draw attention to a document, or, if a courtesy copy is absolutely necessary, provide it on a flash drive or disc.

The Court no longer accepts paper courtesy copies or e-mails of courtesy copies. Instead, if a party wishes to bring a particular filing to the Court's attention, the party may (1) file the document electronically with the clerk's office as it normally does and then (2) call the Court to bring the document to the Court's attention, and ask the Court to view and consider the document that is already in the Court's electronic file system. Alternatively, if you absolutely must file a courtesy copy of the document (which is discouraged) then you must do so on a flash drive or disc.

Civil cases

Page 1 | FILINGS AND COURTESY COPIES

Do not deliver paper copies of mandamus petitions to the Court; provide the petition on a flash drive or disc instead.

COPIES OF MANDAMUS PETITIONS: Please do not serve the Court with paper copies of your mandamus petition. Please put it on a flash drive or disc and deliver it to the Court.

Civil cases

Page 1 | FILINGS AND COURTESY COPIES

Courtesy copies of proposed findings and conclusions should be emailed to the Trial Coordinator in Microsoft Word format.

Courtesy copies should be filed via e-mail to the Trial Coordinator in Microsoft Word format.

Civil cases

Page 1 | 8. TRIALS — E) Findings of Fact/Conclusions of Law

Pre-Motion Conference Requirements

Parties must consult with one another before filing a discovery-related motion; consultation between lead attorneys is preferred.

Always consult with each other (preferably lead attorney on the case to opposing lead attorney on the case) before filing any motions related to discovery.

Civil cases

Page 1 | Discovery Motions

The listed motions are considered on submission, except that unliquidated-damages default motions require an oral hearing; the Court may require an oral or phone conference hearing in certain circumstances.

The Court requires that certain motions be considered only on submission. These motions include; liquidated default judgment motions (unliquidated damages motions for default will, of course, require an oral hearing with a record), motions to compel, objections to discovery, motions to enroll pro hac vice, routine Rule 47 special exceptions, motions to withdraw as attorney of record, motion to substitute counsel, motion to appoint ad litems, referral and objections to mediation, motion to deposit registry funds, and motions for withdrawal of funds. HOWEVER, the court, in its' discretion, may require an oral hearing or phone conference hearing for such motions in certain circumstances.

Civil cases

Page 1 | 7. HEARINGS — D) Submission Docket

Default-judgment motions based on unpaid assessments or deed restriction violations must be set for an oral hearing.

Motions for Default Judgment based on unpaid assessments or deed restriction violations must be set for oral hearing.

Civil cases

Page 1 | Special Note Regarding Homeowners’ Association Defaults

Default judgments are set on the submission docket, except when unliquidated damages must be proved up.

Default judgments are set on the submission docket unless you need to prove up unliquidated damages.

Civil cases

Page 1 | D. Default Judgments

Parties are expected to make every reasonable effort to resolve discovery disputes without court intervention; if unsuccessful, a party may move to compel and set the matter for oral hearing or submission as appropriate.

The Court expects parties to make every reasonable effort to resolve discovery disputes without judicial intervention. If those efforts are unsuccessful, a party may file a motion to compel and either set the matter for oral hearing or set it for submission, as appropriate.

Civil cases

Page 1 | C. Discovery Disputes

A requested oral hearing on a submission-docket matter may be allowed when a response is filed, but is unlikely to be granted without one.

Oral hearings for matters placed on the submission docket are sometimes, but not always, allowed if requested and a response is filed. However, the request is unlikely to be granted if a response has not been filed.

Civil cases

Page 1 | 7. HEARINGS — D) Submission Docket

Adjournment & Extension Requirements

Trial or pretrial-deadline continuance motions must include an appropriate affidavit unless agreed, and should be filed early.

Motions for trial or pretrial deadline continuances MUST be accompanied by an appropriate affidavit, unless they are agreed. Continuance motions should be filed early.

Civil cases

Page 1 | I. Trial Continuances

A summary-judgment motion cannot be passed; the party must proceed or withdraw, and a reset request must comply with Rule 166a and is allowed only if that rule authorizes it.

Passing a motion for summary judgment is not permitted under Rule 166a, as amended. A party must either proceed on the motion or withdraw it. Any request to reset the hearing or submission must strictly comply with Rule 166a and will be granted only if authorized by the rule.

Civil cases

Page 1 | 7. HEARINGS — G) Summary Judgments

For cases filed 18 months or less ago, the first and second agreed continuances should be filed as Rule 11 Notices and include the reason for the request.

If the case is 18 months or less from the date of filing, first and second agreed continuances should be filed as a Rule 11 Notice. Please include the reason that you are requesting a continuance as you would in the motion.

Civil cases

Page 1 | I. Trial Continuances

The standard docket control order does not require ADR; parties who consider mediation appropriate should schedule it promptly and should not wait until the trial period is near to seek a continuance for mediation.

The court’s standard docket control order does not require the parties to complete ADR.If you believe that your case is appropriate for mediation schedule mediation as soon as practicable. Do not wait until the two-week trial period is near to file a continuance to complete mediation.

Civil cases

Page 1 | 8. TRIALS — I) Mediation

Providing more detail in a continuance motion may improve its chance of being granted.

The more detail in your motion, the better the chance that it will be granted.

Civil cases

Page 1 | I. Trial Continuances

Chambers Communication Rules

An email or telephone call to the Clerk does not withdraw a summary-judgment motion or satisfy Rule 166a.

An email to, or telephone call with, the Clerk advising of an intent to withdraw the motion is insufficient and does not constitute withdrawal or compliance with Rule 166a.

Civil cases

Page 1 | 7. HEARINGS — G) Summary Judgments

Opposing counsel must promptly advise of any objections to deposition testimony designations.

Opposing counsel must promptly advise of any objections.

Civil cases

Page 1 | 8. TRIALS — B) Depositions

Do not bring witnesses to court for a temporary-injunction hearing until you have spoken with the Court Clerk.

Do not bring your witnesses to court until you have spoken with the Court Clerk.

Civil cases

Page 1 | 7. HEARINGS — E) Temporary Injunctions

If more than 60 jurors are needed, notify the Trial Coordinator at least 45 days before trial.

If you need a panel larger than 60, please advise the trial coordinator at least 45 days before trial so that we may reserve the ceremonial courtroom.

Civil cases

Page 1 | 8. TRIALS — G) Jury Panel

Notify the Court Coordinator 30 days before trial if using a jury questionnaire.

If you are going to use a jury questionnaire, let the court coordinator know 30 days before trial.

Civil cases

Page 1 | 8. TRIALS — H) Voir Dire

Telephone or email notification to the Court Coordinator is not sufficient settlement notice.

Notification by telephone or email to the Court Coordinator is not sufficient.

Civil cases

Page 1 | SETTLEMENT ANNOUNCEMENTS

Appear in person unless Judge Hughes agrees to another method of appearance.

Appear in person unless Judge Hughes has agreed to another method of appearance.

Civil cases

Page 1 | 7. HEARINGS — A) Appearance by Phone

When both sides agree to an emergency hearing, call the Clerk to arrange a conference with Judge Hughes by Zoom, phone, or in person.

If both sides agree to an emergency hearing, call the Court Clerk to set up a conference by Zoom, phone or in person with Judge Hughes.

Civil cases

Page 1 | 7. HEARINGS — B) Emergencies

When a hearing is passed, the requestor must promptly notify the Court Clerk at the listed number and all parties.

If a hearing is passed, the requestor must promptly notify the Court Clerk at 832-927-2450 and all parties.

Civil cases

Page 1 | TO PASS A HEARING (SUBMISSION/ORAL)

Before a temporary-injunction hearing, the Court must be informed whether the parties are ready, whether they were properly served, and the expected duration and number of witnesses.

For a temporary injunction hearing, it is imperative that we know whether or not you are ready to proceed; if the parties were properly served, and the length of time and the number of witnesses.

Civil cases

Page 1 | 7. HEARINGS — E) Temporary Injunctions

Parties must consult about an emergency; if both agree, call the Clerk to arrange a conference, while a party seeking an emergency hearing over the other side’s objection must e-file a motion, unless short time makes e-filing impractical, in which case contact the Clerk.

Parties must consult with each other about the matter (preferably lead attorney on the case to opposing lead attorney on the case).If both sides agree to an emergency hearing, call the Court Clerk to set up a conference by Zoom, phone or in person with Judge Hughes. If only one side thinks it is an emergency, efile a motion for emergency hearing. If time is short and e-filing is impractical, please contact the Court Clerk for further instructions.

Civil cases

Page 1 | 7. HEARINGS — B) Emergencies

If time is short and e-filing is impractical, contact the Court Clerk for instructions.

If time is short and e-filing is impractical, please contact the Court Clerk for further instructions.

Civil cases

Page 1 | 7. HEARINGS — B) Emergencies

Parties should bring discovery, witness, or other trial-preparation problems to the Court’s attention as early as possible.

Likewise, the parties should proactively bring discovery, witness or other problems to the court’s attention as early as possible so that the court may attempt to provide guidance to the litigants to enable them to efficiently proceed to trial.

Civil cases

Page 1 | I. Trial Continuances

Please call the Court Clerk before your scheduled hearing to confirm the hearing.

Please call the Court Clerk before your scheduled hearing to confirm the hearing.

Civil cases

Page 1 | 7. HEARINGS — E) Temporary Injunctions

When requested additional evidence has been filed for an unopposed motion, default judgment, or expedited foreclosure, a party may call the Court Clerk to follow up.

In certain situations, the Court will ask you to supplement your unopposed motion or request for default judgment or expedited foreclosure with additional evidence. It is not always immediately brought to the Court's attention when you have filed that additional evidence. Feel free to call the Court Clerk to follow up on your motion.

Civil cases

Page 1 | Agreed Motions

Notice of rulings is generally sent electronically; the Judge may also have orders faxed, and parties encountering difficulty may check with the District Clerk or call the Court Clerk.

3)How is notice of ruling given by the Court? For most matters, you will receive notice electronically that an order has been entered in your case. In addition, orders may, if desired by the Judge, be faxed to you. Check with the District Clerk office about accessing imaged documents on-line if you encounter difficulty. You may also call the Court Clerk at 713-368-6222. Note: Notices required of the District Clerk are automated.

Civil cases

Page 1 | FREQUENTLY ASKED QUESTIONS

A party need not separately bring a filing to the Court’s attention, but may do so using the method described above.

It is not necessary to bring a filing to the Court's attention, but if a party would like to do so, please use the method described in the preceding paragraph.

Civil cases

Page 1 | FILINGS AND COURTESY COPIES

Court-wide rules

Applies court-wide

These 99 rules apply across Harris County District Courts. Where this judge's own standing orders above address the same topic, the judge's requirement controls.

Filing Requirements

All 38
  • Applies to
    Trial documents

    In all cases, the parties must exchange the listed applicable trial documents at least 10 days before trial.

  • Applies to
    Required documents

    If a hearing or trial is reset, each party must reasonably supplement or amend the required documents, no later than 10 days before the new trial date.

  • Applies to
    Motion
    Must include
    proposed order

    Motions must be written and accompanied by a separate proposed order granting the requested relief.

Filing Timing

All 23
  • Applicable documents required under Rule 5.2.2 must be exchanged at least 10 days before trial.

  • Required supplementation must be provided no later than 10 days before the new trial date.

  • Judgments and orders must be submitted to the court for signing within ten days after rendition, unless the court directs otherwise.

Communication

All 17
  • Attorneys and self-represented litigants who expect to be late for docket call must notify the court and opposing party and provide the listed information.

  • When a child must be interviewed or testify, the responsible party must coordinate a specific time with the court coordinator.

  • The party responsible for a child's attendance must immediately notify the court coordinator when the child arrives.

Service

All 10
  • Notice of submission setting must be served at least 10 days before the date of the hearing, or more if required by statute or rule.

  • Required documents must be delivered using methods authorized by the Texas Rules of Civil Procedure.

  • Applies to
    Scheduling order

    When a Scheduling Order has issued, parties seeking affirmative relief must provide it to all parties who have appeared or will later appear generally.

About Judge Erica R. Hughes

Judge Erica R. Hughes is a district judge in the Harris County District Courts, which hear civil matters in the Houston metropolitan area.

Judge Hughes's procedures are published through the court's general rules.

Common questions about Judge Erica R. Hughes's rules

Are courtesy copies required for Judge Erica R. Hughes?

The Court does not accept paper or emailed courtesy copies; a party may call after e-filing to draw attention to a document, or, if a courtesy copy is absolutely necessary, provide it on a flash drive or disc.

View ruleSource: page 1, section FILINGS AND COURTESY COPIES

Does Judge Erica R. Hughes require a pre-motion conference or letter before filing a motion?

Parties must consult with one another before filing a discovery-related motion; consultation between lead attorneys is preferred.

View ruleSource: page 1, section Discovery Motions

What formatting rules apply to filings before Judge Erica R. Hughes?

Judge Erica R. Hughes' formatting rule includes file format docx and in some instances, longer or more complex proposed orders may be required to be emailed to the clerk in word format. include a cover letter stating whether the proposed order is agreed as to form.. The Court may require longer or more complex proposed orders to be emailed to the Clerk in Word format; submissions should include a cover letter stating whether the order is agreed as to form.

View ruleSource: page 1, section 6. PROPOSED ORDERS

What must be included with summary judgment withdrawal notice filings before Judge Erica R. Hughes?

To withdraw a summary-judgment motion, file a written notice with the specified title and identify the motion’s original filing date.

View ruleSource: page 1, section 7. HEARINGS — G) Summary Judgments

What must be included with notice to pass hearing filings before Judge Erica R. Hughes?

To pass an oral hearing or submission setting, use the e-Hearing system and/or e-file a notice specifying the time, date, and motion.

View ruleSource: page 1, section TO PASS A HEARING (SUBMISSION/ORAL)

How may parties contact Judge Erica R. Hughes' chambers?

An email or telephone call to the Clerk does not withdraw a summary-judgment motion or satisfy Rule 166a.

View ruleSource: page 1, section 7. HEARINGS — G) Summary Judgments

How do I request an adjournment or extension before Judge Erica R. Hughes?

A summary-judgment motion cannot be passed; the party must proceed or withdraw, and a reset request must comply with Rule 166a and is allowed only if that rule authorizes it.

View ruleSource: page 1, section 7. HEARINGS — G) Summary Judgments

Is electronic filing required before Judge Erica R. Hughes?

Yes. Electronic filing is required for the covered filings. A party seeking an emergency hearing when the other side does not agree must e-file a motion for emergency hearing.

View ruleSource: page 1, section 7. HEARINGS — B) Emergencies

What filing deadlines does Judge Erica R. Hughes set?

Expert-exclusion motions should be filed and set well before trial; a motion filed after the docket-control-order deadline will not be considered without leave demonstrating exceptionally good cause.

View ruleSource: page 1, section K. Daubert Motions (Exclusion of Expert Witness Testimony)

What rule applies to serving all parties before Judge Erica R. Hughes?

Details: recipient: all parties. If an emergency hearing is granted, the movant must give proper notice to all parties.

View ruleSource: page 1, section 7. HEARINGS — B) Emergencies
Complete rules summary for Judge Erica R. Hughes

A summary-judgment motion cannot be passed; the party must proceed or withdraw, and a reset request must comply with Rule 166a and is allowed only if that rule authorizes it.

To withdraw a summary-judgment motion, file a written notice with the specified title and identify the motion’s original filing date.

An email or telephone call to the Clerk does not withdraw a summary-judgment motion or satisfy Rule 166a.

To pass an oral hearing or submission setting, use the e-Hearing system and/or e-file a notice specifying the time, date, and motion.

Default judgments are set on the submission docket, except when unliquidated damages must be proved up.

The motion and proposed judgment must identify whether the default judgment is final or interlocutory.

A discovery motion and proposed order must separately identify each issue, disputed request, or objection so the Court can rule on each item.

Submit a proper non-military affidavit using the DMDC Military Verification service and file a Certificate of Last Known Address.

Counsel must ensure that cited authorities exist and are quoted accurately.

A response filed after its deadline must be accompanied by a separate motion for leave to file late and a proposed order.

Replies filed after noon Friday for a Monday oral hearing are unlikely to be considered.

Parties should make every effort to file necessary replies or sur-replies by Thursday before a Monday hearing.

Motions must include required certificates of conference explicitly describing efforts to resolve the motion with all other parties or counsel before filing.

If the other side could not be reached before filing, the certificate should describe communication efforts and be supplemented as soon as possible after the parties confer.

The Court may require longer or more complex proposed orders to be emailed to the Clerk in Word format; submissions should include a cover letter stating whether the order is agreed as to form.

Appear in person unless Judge Hughes agrees to another method of appearance.

Parties must consult about an emergency; if both agree, call the Clerk to arrange a conference, while a party seeking an emergency hearing over the other side’s objection must e-file a motion, unless short time makes e-filing impractical, in which case contact the Clerk.

When both sides agree to an emergency hearing, call the Clerk to arrange a conference with Judge Hughes by Zoom, phone, or in person.

A party seeking an emergency hearing when the other side does not agree must e-file a motion for emergency hearing.

If time is short and e-filing is impractical, contact the Court Clerk for instructions.

If an emergency hearing is granted, the movant must give proper notice to all parties.

A summary-judgment motion requesting an oral hearing must state that request in its title.

When a hearing is passed, the requestor must promptly notify the Court Clerk at the listed number and all parties.

Draft proposed jury charges should be exchanged before docket call.

Only after assignment to trial, the parties should email the Trial Coordinator their proposed charge in Microsoft Word format.

The standard docket control order does not require ADR; parties who consider mediation appropriate should schedule it promptly and should not wait until the trial period is near to seek a continuance for mediation.

Parties requesting or agreeing to a summer trial setting must expressly waive conflicting vacation letters.

In tax trial cases, the address on the notice must match the last known address in the petition.

In tax trial cases, request that the lien holder issue a hearing notice.

Parties need not appear in person to announce settlement if an e-filed Notice of Settlement is on file.

More Judges in Harris County District Courts

Aaron Burdette
Judge
Ana Martinez
Judge
Andrea Beall
Judge
Angela L. Graves-Harrington
Judge
Angela M. Lancelin
Judge
Angelina D. A. Gooden
Judge
Bethany Arnold
Judge
Beverly D. Armstrong
Judge