Judge Tanya Garrison
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- 3 Days Before Hearing If Possible
Courtesy Copy
Filings > 25 pages
- 3 Days Before Hearing If Possible
Adjournments
- Parties should generally follow these guidelines in determining if extra time is required: Dispositive motions, summary judgment motions, and jurisdictional motions, requiring more than 20 minutes of total (for both the movant and all respondents) time for argument; All evidentiary hearings (other than defaults, minor settlements, or transfer of structured payments); and Pre-trial motions - including sanctions, discovery, and procedural motions - that will require more than 10 minutes of total (for both the movant and all respondents) time for argument.
- Continuance requests, even agreed ones, are not expected to be granted without good reasons.
- An agreed continuance motion on the first trial setting does not require an oral hearing unless the case is three years old.
- +2 more
Request must include
Communication
Clerk
Phone
Clerk
Phone
Court-widePage & Word Limits1 rule
Emergency hearing requests must be made to the Court Clerk, with a filed and served letter or motion (max 2 pages) stating reasons for the hearing and emergency.
- Letter
- Up to 2 pages
Court's wording
Parties may request an emergency oral hearing or telephonic conference by contacting the Court Clerk. A letter or motion requesting such a hearing, the reasons for the hearing, and the reasons giving rise to emergency consideration should be filed and served on all parties. The letter or motion should not exceed 2 pages in length.
Document Format Requirements2 rules
When filing documents, please type the entire title of your pleading in the description field and clearly label all exhibits. Do not use all caps. Please limit the title of documents to no more than 10 words.
Formatting
- •Clearly label all exhibits
- •Do not use all caps
Footnotes on filings are accepted. If you have hyperlinks on motions that have been filed, you can provide a courtesy copy of the motion in a USB thumb drive with your courtesy copies.
- Motion
Formatting
- •Footnotes are accepted
Document Filing Requirements21 rules
Withdrawal motions must include a statement of circumstances, a certificate with client contact info, a copy of the notice letter with specified contents, and proof of service if the client has not agreed.
Court's wording
The motion must contain: a statement of the particular circumstances and disciplinary rules requiring withdraw; a certificate of the attorney of record of the client’s name, address, telephone number, e-mail address and the last known time the information was correct; a copy of a letter from the attorney of record to the client giving notice: (a) that the attorney is withdrawing; (b) that the client is deemed to have knowledge of and is required to abide by the Texas Rules of Civil Procedure if the client proceeds pro se; (c) that all notices from the Court to the client's current address will be deemed to have been received unless the client notifies the Court of any change of address; (d) that no continuances or extensions will be granted to the pro se client in order to obtain other counsel; and (e) notice of the hearing at which the motion to withdraw will be considered; and If the client has not agreed to the withdraw, proof of service of the letter described above must be filed.
Rule 106 motions may be submitted without an oral hearing but must include an affidavit with specified service details.
Court's wording
Rule 106 Motions can be submitted to the Court without the need for an oral hearing but 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 and time; identity of persons who were present at the subject address and what was said; and identity of cars in driveway, other indications that defendant resides at the subject address, or other evidence that service as proposed is likely to give the defendant actual notice of the lawsuit.
All demonstrative exhibits and Power Point presentations must be shown to all parties before being shown to the jury.
Discovery motions must include a brief description of the dispute, a certificate of conference with details of discussions, and copies of the discovery requests and responses at issue.
- Document
- Discovery motion
Should include
- •Certificate of conference
Court's wording
The complaining party should file a motion containing: a brief description of the dispute; a certificate of conference stating the name of all counsel participating in the discussions, including the date, time, and place the parties have had out of-court discovery discussions, and the results of those discussions; and a copy or verbatim reproduction of the discovery requests and responses at issue.
Parties must prepare, exchange, and bring a Trial Notebook containing live pleadings, witness lists, exhibit lists, motions in limine, deposition excerpts, and proposed jury charges.
- Document
- Trial notebook
Must include
- •Exhibit list
Court's wording
The parties must prepare, exchange and bring to the pretrial conference, a Trial Notebook that contains: live pleadings; witness lists (with estimated time for examination and cross-examination of each); exhibit lists (including copies of exhibits and any objections); motions in limine and objections; deposition excerpts and objections; and proposed jury charges.
A Guardian Ad Litem will be required for all settlements involving minor children, unless the Court has been advised of same and approved proceeding without a guardian ad litem during an in person status conference.
A certificate of conference is required for all motions, pleas, and special exceptions except for: dispositive motions, including motions for summary judgment; default judgments; motions for voluntary dismissal or non-suit; and motions involving service of citations.
- Document
- Motion
Must include
- •Certificate of conference
The parties are to submit an agreed motion and order for appointment of a Guardian Ad Litem. The Court will then select the Guardian Ad Litem for that case, and will inform the parties of the Court's decision.
The proposed Order of Severance must include styling, new cause number, parties, pleadings to sever, disposition status, and cost responsibility.
Court's wording
The proposed Order of Severance should include the following: how the severed case is to be styled; the new cause number; the parties to be included in the severed case; all the pleadings that are to be severed into the new file; whether the Order disposes of the severed case, or whether it will remain an active case; and who will pay for the costs of severance.
Certificates of conference must state: how and when parties conferred on the matters on which relief is sought; the names of the attorneys/parties who conferred; and whether the relief is opposed, agreed, or agreed in part.
- Document
- Certificate
Must include
- •Certificate of conference
To request remote testimony via Zoom, file an agreed motion for leave set for oral hearing, including a sworn statement with specific equipment, setting, and exhibit requirements.
Court's wording
If a party would like to request permission from the Court to have a witness appear for trial via Zoom, a motion requesting leave for this purpose should be filed and set for oral hearing. The Motion for Leave must be agreed, and must include a sworn statement from the attorney presenting the witness that: They have ensured that the witness has available electronic equipment sufficient to host such testimony and that the attorney and witness have personally tested the equipment to ensure it works and everyone involved knows how to use the equipment; The witness will be testifying in a neutral setting with no room decoration within view of the camera; The witness will be the only person in the room; and A complete set of all exhibits (or select exhibits as agreed upon by all counsel in cases with more than 50 total exhibits), in hard copy, have been delivered to the witness, and that the witness will have all exhibits available for testimony.
All motions and responses must have a proposed order filed in advance of the hearing on that motion.
- Document
- Motion
Must include
- •Proposed order
At least 24 hours prior to the time of the hearing, the parties are to present the proposed Judgment, as well as the Supreme Court ad litem fee report.
After filing the motion, the complaining party should contact the Court about a hearing. Proposed orders should list each discovery issue separately. Both the movant and non-movant must submit a proposed order.
- Document
- Discovery motion
Must include
- •Proposed order
Failure to include the necessary information in the proposed order may result in denial of the Motion.
Motions for Severance may be set either for submission or oral hearing. The motion must state the basis for the severance.
Failure to include a Certificate of Conference may result in a hearing being passed.
Include
- •Certificate of conference
If statutory or case law will be presented to the Court at any hearing, a copy of the statute or case should be made available with highlighted portions of the relevant language.
The proposed order should include the exact title of the motion being considered.
Parties requesting an Order for Substituted Service under Rule 106 shall use the court’s suggested form: 157th Order Granting 106 Substitute Service.docx
A motion for default judgment can be set for an oral hearing or submission hearing. The Non-Military Affidavit must comply with recent amendments to the Soldiers and Sailors Relief Act.
Filing & Service rules
Electronic Filing Rules
All cases in the 157th Civil District Court must be filed electronically.
In accordance with the Local Rules of Harris County District Courts, all cases in the 157th Civil District Court shall be electronically filed.
Civil cases
Page 1 | 1. Mandatory Electronic Filing
Filing Timing and Cure Windows
Responsive pleadings must be filed by 4:00 pm on the last business day before the hearing.
Any responsive pleading must be filed by 4:00 pm the last business day before the hearing.
Civil cases
Page 1 | 3.1 Oral Hearings
If no judgment is filed within 30 days of settlement notice, the case may be dismissed for want of prosecution, subject to extension.
Cases may be dismissed for want of prosecution if no judgment is filed within 30 days after the court is notified of settlement (this time may be extended where necessary).
Civil cases
Page 1 | 2.6.1 Settlement Announcements
Cases are set on a two-week trial docket with no docket positions; if not reached, the Court automatically resets the trial date.
All cases are set on a two-week trial docket. There are no docket positions; cases will be set for a date certain by the Trial Coordinator. If a case is not reached within the two-week docket the Court will automatically issue an order resetting the trial date.
Civil cases
Page 1 | 6.1 Trial Settings
Service and Proof of Service Rules
After a hearing date is assigned, the requesting party must file and serve a notice of oral hearing stating the exact title of the motion(s).
Once the clerk assigns a hearing date the party requesting the hearing must file a notice of oral hearing and serve it on all counsel and self-represented parties. The hearing notice must state the exact title of the motion or motions to be heard.
Civil cases
Page 1 | 3.1 Oral Hearings
Submission docket is Mondays at 8:00 a.m. with ten days notice; file and serve a notice of submission with the exact title of the motion(s).
The submission docket takes place Mondays at 8:00 a.m. with ten days notice. If you set a matter on the submission docket file a notice of submission with the exact title of the motion or motions set for consideration and serve it on all counsel and self-represented parties.
Civil cases
Page 1 | 3.2 Submission Docket
Trial Notebook documents must be exchanged before the pretrial conference, and parties are ordered to confer to reach agreements on limine, exhibits, objections, and jury charges.
These documents must be exchanged prior to the pre-trial conference. The parties are ORDERED to confer with each other prior to the pre-trial conference to discuss these documents to determine if any agreements can be reached regarding limine, pre-admission of exhibits, deposition objections, and jury charge submissions.
Civil cases
Page 1 | 6.2 Pretrial Conferences
Courtesy Copy Requirements
Parties filing pleadings more than 25 pages in length or with more than 50 pages of exhibits may provide a courtesy copy of those pleadings and accompanying exhibits to the Court, and give written notice to all parties stating the specific documents that were provided.
Parties filing pleadings more than 25 pages in length or with more than 50 pages of exhibits may provide a courtesy copy of those pleadings and accompanying exhibits to the Court, and give written notice to all parties stating the specific documents that were provided.
Civil cases
Page 1 | 2.3 Courtesy Copies
If a courtesy copy is marked or highlighted, the filing party must provide an exact copy to all other parties.
If a party highlights or otherwise marks a document in a courtesy copy provided to the Court, that party shall provide all other parties to the litigation an exact copy of what was provided to the Court.
Civil cases
Page 1 | 2.3 Courtesy Copies
Courtesy copies should be provided three days before the scheduled hearing when possible.
Courtesy Copies should be provided 3 days before the scheduled hearing if possible.
Civil cases
Page 1 | 2.3 Courtesy Copies
Filing Bundling Requirements
All motions should have their own proposed order (Please do not combine multiple motions into one order).
All motions should have their own proposed order (Please do not combine multiple motions into one order).
Civil cases
Page 1 | 2.2 Proposed Orders
Each pleading, motion, response, exhibit, proposed order, and notice must be filed as a separate document.
All pleading, motions, responses, etc., must be separated with the filing as follows: motion and response/reply, each individual exhibit, proposed order, notice of hearing and/or submission.
Civil cases
Page 1 | 1. Mandatory Electronic Filing
Pre-Motion Conference Requirements
Parties must confer before filing a discovery motion to attempt resolution without court intervention.
The Court expects that parties will make every effort to resolve all discovery issues without court intervention. Conferences shall occur prior to the filing of the discovery motion.
Civil cases
Page 1 | 2.5 Discovery Motions
Motions to withdraw as counsel must be set for oral hearing unless the client agrees and signs an acceptance of the notice letter.
Motions for withdrawal of counsel must be set on the oral hearing docket, unless the client has agreed to the withdraw and signed an acceptance of the attorney’s notice letter.
Civil cases
Page 1 | 2.9 Motions to Withdraw as Attorney of Record
The first Verified Motion to Retain may be filed without a hearing; subsequent motions to retain must be set for oral hearing.
The first Verified Motion to Retain does not need to be set on an oral hearing or submission docket. It should be filed and will be considered by the Court. Any subsequent motion to retain must be set for an oral hearing.
Civil cases
Page 1 | 2.11 Motions to Retain
Pursuant to 4.1 herein, any Motions to exclude or challenge expert evidence should be filed and set for hearing on a date in advance of trial.
Pursuant to 4.1 herein, any Motions to exclude or challenge expert evidence should be filed and set for hearing on a date in advance of trial.
Civil cases
Page 1 | 6.3 Expert Witnesses
Preferential trial settings may be requested by motion, which must be set for an oral hearing.
Preferential settings are available in special circumstances and may be requested by motion. Such motions must be set for an oral hearing to be considered by the Court.
Civil cases
Page 1 | 6.1 Trial Settings
A pretrial conference is generally held the week before the two-week trial docket; the Trial Coordinator confirms the date.
There will be a pretrial conference, generally held the week before the two-week trial docket, for each case set for trial. The Trial Coordinator will contact the parties to confirm the date of the pretrial conference.
Civil cases
Page 1 | 6.2 Pretrial Conferences
Mediation is not required in every case but may be ordered on a case-by-case basis.
The Court does not require mediation in every case. It may, however, order mediation on a case-by-case basis.
Civil cases
Page 1 | 7. Mediation
Adjournment & Extension Requirements
Opposed continuance motions require an oral hearing; a third or later continuance motion requires an oral hearing even if agreed.
All opposed Motions for Continuance require an oral hearing. If it is the 3rd or more Motion for Continuance, an oral hearing is required regardless of any agreements between the parties.
Civil cases
Page 1 | 5. Trial Continuances
Continuance requests, even agreed ones, are not expected to be granted without good reasons.
Parties should not expect that a continuance request, even an agreed request, to be granted in the absence of good reasons for the continuance.
Civil cases
Page 1 | 5. Trial Continuances
Continuance motions should be filed as early as possible; those filed after trial assignment are disfavored.
Motions for Continuance should be filed as early as possible. Motions filed after receiving assignment from the trial coordinator will not be looked upon favorably.
Civil cases
Page 1 | 5. Trial Continuances
An agreed continuance motion on the first trial setting does not require an oral hearing unless the case is three years old.
If you are currently on your 1st trial setting, and have filed an agreed motion with an order, it does not have to be set for an oral hearing, unless the case is 3 years old.
Civil cases
Page 1 | 5. Trial Continuances
Parties should generally follow these guidelines in determining if extra time is required: Dispositive motions, summary judgment motions, and jurisdictional motions, requiring more than 20 minutes of total (for both the movant and all respondents) time for argument; All evidentiary hearings (other than defaults, minor settlements, or transfer of structured payments); and Pre-trial motions - including sanctions, discovery, and procedural motions - that will require more than 10 minutes of total (for both the movant and all respondents) time for argument.
Parties should generally follow these guidelines in determining if extra time is required: Dispositive motions, summary judgment motions, and jurisdictional motions, requiring more than 20 minutes of total (for both the movant and all respondents) time for argument; All evidentiary hearings (other than defaults, minor settlements, or transfer of structured payments); and Pre-trial motions - including sanctions, discovery, and procedural motions - that will require more than 10 minutes of total (for both the movant and all respondents) time for argument.
Civil cases
Page 1 | 3.1 Oral Hearings
Chambers Communication Rules
Remote appearances via Zoom or other means are prohibited without prior court order.
Witness, parties, lawyers, etc., may no longer appear by Zoom (or other remote means), absent prior order from the Court.
Civil cases
Page 1 | 6.4 Remote Testimony
Emergency rulings during depositions may be requested by calling the Court Coordinator; parties must first take reasonable action to avoid the need, and bad-faith requests may incur sanctions.
Parties may request an emergency ruling during a deposition by calling the Court Coordinator. Attempts will be made to schedule a time for an emergency hearing as soon as possible. Prior to contacting the Court, all parties are expected to all take action reasonably required to avoid the necessity of such a hearing. If the Court determines that such a request is made in bad faith or for purposes of delay, sanctions may be imposed.
Civil cases
Page 1 | 3.4 Emergency Rulings During Depositions
Temporary injunction hearings are generally Mondays at 1:30 p.m.; parties must contact the Court Clerk before the hearing to confirm service, readiness, duration, and witness count.
Temporary Injunctions are generally set on Mondays at 1:30 p.m. Please contact the Court Clerk before your hearing date to confirm that all necessary parties have been served, that you are ready to proceed, how long your hearing will take, and how many witnesses will be called.
Civil cases
Page 1 | 4. Temporary Injunctions
Telephonic appearances on contested matters require advance special permission from the Court, requested through the Court Clerk with specific reasons.
Telephonic appearances on contested matters are strongly discouraged. You may only appear by telephone upon receiving special permission from the Court in advance of the hearing. Please contact our Court Clerk with your request and state the reasons, with specificity, as to why you need to appear by telephone.
Civil cases
Page 1 | 3.5 Telephonic Appearances
Motions requiring extra time or evidence presentation must be flagged to the Court Clerk for an off-docket setting.
Parties filing motions that will require extra time, or the presentation of evidence, must alert the Court Clerk of this fact and request an off-docket setting.
Civil cases
Page 1 | 3.1 Oral Hearings
Settlement announcements may be made by phone to the Trial Coordinator without appearing in court.
It is not necessary to appear in Court to announce a settlement; a phone call to the Trial Coordinator is sufficient.
Civil cases
Page 1 | 2.6.1 Settlement Announcements
Courtrooms have AV equipment; parties are encouraged to use the ELMO and may contact the bailiff to schedule a technology visit.
All courtrooms have audio-visual equipment, including an ELMO (document camera), computer jacks, projectors, TV screens and DVD players. We encourage you to use the ELMO to present exhibits to the jury. If you are unfamiliar with its use, you may visit our courtroom to test the equipment. Please contact the Court’s bailiff to schedule a technology visit.
Civil cases
Page 1 | 8. Courtroom Audio/Video Equipment
To convert a submission docket matter to an oral hearing, call the Court Clerk and give notice to all parties; requests are generally honored.
If any party wants an oral hearing on a motion that has been placed on the submission docket that party should call the Court Clerk and request a hearing date and time. The party requesting the oral hearing must give notice to all parties of the hearing. Absent extraordinary circumstances, all such requests will be honored.
Civil cases
Page 1 | 3.2 Submission Docket
Oral hearings are usually held on Monday; parties requesting an oral hearing must call and email the Court Clerk with an estimated time needed.
The Court’s oral hearing docket is usually held on Monday. Any party requesting an oral hearing should call and email the Court Clerk for a date and time for a hearing and be ready to state an approximate amount of time needed for the hearing.
Civil cases
Page 1 | 3.1 Oral Hearings