Judge Lauren Reeder
Individual Rules, Standing Orders & Policies
Adjournments
- First continuances are available for good cause or by agreement, and an agreed first continuance does not require a hearing unless the Court decides otherwise.
- Continuances after the third must show substantial need and must be set for an oral hearing whether agreed or opposed.
Request must include
Communication
Phone
Clerk
Phone
Court-wideDocument Filing Requirements19 rules
The complaining party should file a motion containing: A brief description of the dispute; The date, time, and place the parties have had out-of-court discovery discussions; The names of all counsel participating in the discussions; and A copy or verbatim reproduction of the discovery requests and responses at issue.
A severance order must contain the case style and number, parties, documents, disposition status, and allocation of severance costs.
Court's wording
The order of the severance must contain the following information: Style of the case; Case number; Parties to be included in the severed case; Documents to be included; whether the severed case is disposed of or remains active; and the party paying for the costs of court and severance.
Persons preparing a certificate of conference must confer personally with opposing counsel or explain why they could not; sending a letter/email and receiving no response is insufficient.
Court's wording
The movant must confer person-to-person with opposing counsel before the Court will consider a motion that requires a conference. The Court will pass motions that do not have a certificate stating (1) that the movant has actually talked to opposing counsel, or (2) why counsel have not been able to discuss motion. A certificate of conference stating that you sent a letter or email to opposing counsel and received no response is not a proper certificate of conference
If default service was made at a different address than stated in the citation, a motion to amend citation and proposed order to amend citation must be filed.
- Document
- Motion to amend citation
Must include
- •Proposed order
Court's wording
If the defaulting party was served at an address other than the address for which the citation was issued, the Court requires filing a Motion to Amend Citation, requesting that the citation be amended to reflect the actual address of service, along with a proposed Order to Amend Citation.
A certificate of conference is required on all motions, pleas and special exceptions except: Summary Judgments Default Judgments Agreed Judgments Motions for voluntary dismissal or non-suit Post-verdict motions; or Motions involving service of citation
- Document
- Motion
Must include
- •Certificate of conference
File proposed orders with all motions and responses.
- Document
- Motion and response
Include
- •Proposed order
When a lawsuit involves a minor, any notice or motion for nonsuit must be filed without prejudice.
E-file motion responses at least 48-hours before the hearing and include a proposed order.
- Document
- Motion response
Include
- •Proposed order
Once you obtain a hearing date you are required to file a Notice of Oral Hearing and serve it on all counsel or pro se parties.
A Guardian Ad Litem will be required for all settlements involving minor children. The parties are to submit an Agreed motion and order for appointment of a Guardian Ad Litem.
When submitting a proposed order, you must include a cover letter and indicate whether the order is agreed to as to form.
If the parties would like to amend the docket control order in addition to continuing the trial date, please note your request in the Motion for Continuance and include the statement that a new scheduling order shall be issued by the Court in the proposed order. Alternatively, an amended scheduling order may be submitted.
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.
Proposed orders should list each discovery issue separately so that the court may sign a specific order granting or denying the requested relief.
When proving attorney's fees in a motion for default judgment, in your affidavit provide the court with evidence to support your claim for attorney's fees. At a minimum you should show (1) your experience, (2) the work you did on the lawsuit, (3) how long it took you to do it and (4) your hourly rate.
agreed motions should be titled as such and must be signed by all parties or include a Certificate of Conference.
- Document
- Agreed motion
Must include
- •Certificate of conference
The proposed order granting the continuance shall provide a space for the new trial date to be inserted by the Court.
Before any m to withdraw is considered, the attorney must file the enumerated list including notice of hearing, supporting statement, client information certificate, client notice letter, and acceptance or proof of service.
- Document
- Motion to withdraw
Must include
- •Certificate of service
Court's wording
The following must be filed before any motion to withdraw as attorney of record will be considered: (1) Notice of hearing; (2) A statement of the particular circumstances and disciplinary rules requiring withdrawal; (3) A certificate by the attorney of the client's name, address, and telephone number, and a current statement; (4) A copy of a letter to the client giving the required notices; and (5) A signed acceptance of the letter or a proof of service of the letter.
The substituted-service order must include and attach Exhibit A requiring specific mailing, return, and reporting provisions.
Court's wording
Additionally, the following must be referenced and attached as an exhibit to the order: EXHIBIT A ... (a) mailing by certified and regular mail, (b) return not made within 30 days after mailing, (c) return stating date and result, (d) attaching any returned envelope.
Filing & Service rules
Electronic Filing Rules
Emergency hearing requests must be e-filed as an emergency motion with a detailed explanation of necessity.
In order to receive an emergency hearing, you must e-file an emergency motion that provides a detailed explanation of why it is needed.
Page 1 | EMERGENCY HEARING
Motion responses must be e-filed at least 48 hours before the hearing and must include a proposed order.
E-file motion responses at least 48-hours before the hearing and include a proposed order.
Page 1 | MOTION RESPONSES
Filing Timing and Cure Windows
A summary-judgment motion may not be set for hearing less than 35 days after the motion is filed.
All MSJ must be set no sooner than 35 days after the motion has been filed.
Page 1 | MOTIONS FOR SUMMARY JUDGMENT
A default judgment for unliquidated damages requires an oral hearing on Mondays at 10:30 AM with at least ten days' notice.
Default judgments asking for unliquidated damages will need an oral hearing on Mondays at 10:30am with a ten days’ notice.
Page 1 | MOTIONS FOR DEFAULT JUDGMENT
Most motions must receive at least 10 days' notice before being set on Monday's submission docket at 8:00 AM.
Submission docket takes place on Monday at 8:00 AM after 10 days’ notice for most motions.
Page 1 | Submission Docket
Motions for Severance should be set on the submission docket, any Monday at 8:00am with ten days’ notice.
Motions for Severance should be set on the submission docket, any Monday at 8:00am with ten days’ notice.
Page 1 | MOTIONS TO SEVER
Service and Proof of Service Rules
In a default judgment, the movant must give the defaulting party and other appearing parties 10 days’ notice by regular and certified mail and must file a certificate of service.
The Court requires the movant to give the defaulting parties (as well as any other parties who may have made an appearance in the case) 10 days’ notice of the hearing and of the default motion by regular and certified mail, and to certify that this has been done in a certificate of service.
Page 1 | MOTIONS FOR DEFAULT JUDGMENT
Substituted service is complete upon compliance with the court's order even if the defendant does not sign the certified-mail receipt.
Service will be complete upon compliance with this Order regardless of whether Defendant signs the certified mail receipt.
Page 1 | RULE 106 MOTIONS FOR SUBSTITUTED SERVICE
Sealing & Redaction Procedures
Confidential matters included in a motion to withdraw may be filed under seal.
Confidential matters may be filed under seal.
Page 1 | Motions to Withdraw as Attorney of Record
Adjournment & Extension Requirements
Continuances after the third must show substantial need and must be set for an oral hearing whether agreed or opposed.
Continuations after the third continuance must demonstrate substantial need for a delay of the trial setting and must be set for oral hearing whether agreed or opposed.
Page 1 | CONTINUANCES
First continuances are available for good cause or by agreement, and an agreed first continuance does not require a hearing unless the Court decides otherwise.
First continuances may be granted for good cause or upon agreement of the parties if a motion for continuance is filed sufficiently in advance of the trial setting. If agreed, first continuances will not require a hearing unless after reviewing the motion the Court deems one necessary.
Chambers Communication Rules
An oral hearing date may be obtained by calling the court clerk at 832-927-2234.
Any party requesting an oral hearing can obtained a date by the clerk, please call the main number 832-927-2234.
Page 1 | HEARINGS
All counsel and the court clerk must be notified when a hearing is passed.
Please call the Court Clerk and all counsel when any hearing is passed.
Page 1 | HEARINGS
Before scheduling hearings, movers should call the Court and notify the Court (1) regarding readiness to proceed with the hearing, and (2) the estimated length of the hearing.
Before scheduling hearings, movers should call the Court and notify the Court (1) regarding readiness to proceed with the hearing, and (2) the estimated length of the hearing.
Page 1 | Temporary Injunctions
Settlements may be announced by a phone call to the court coordinator or by email, without appearing in court.
You do need not appear in court to announce a settlement; a phone call to the court coordinator is sufficient or email from parties.
Page 1 | Settlements