Filing Bundling Requirements

The binder must include all the following documents placed in the binder in the following order:

Motions in limine should be submitted in a separate tabbed binder with a table of contents.

Motions in limine, oppositions, and replies must be bundled in a tabbed binder with table of contents, provided to court 2 days before FSC.

The court requests that a separate book/binder be submitted to the chambers at the time of the Pre-Trial Conference, containing all MILs. The motions should be tabbed by number and contain all relevant pleadings to each MIL, including the motion, the P&As in support thereof, the prosed order, any opposition pleadings, and any reply pleadings. Each party who files any MIL shall submit such a book/binder for their own MILs. Alternatively, the parties may submit a joint book/binder.

Motions in Limine Binder required, lodged 3 days before Final Status Conference, three-ring binders, tabbed numerically, one-sided conformed copies.

Each motion in limine must be filed separately with its own supporting papers, and pleadings may not be stapled, bundled together, or filed as an omnibus motion.

Any important orders that may impact the scope or nature of the trial must be included in the Trial Binder.

Parties must jointly prepare and lodge a Trial Binder in Department 74 no later than five court days before the Final Status Conference.

Jury trial parties must jointly lodge a tabbed 3-ring trial binder with table of contents 2 calendar days before FSC.

Motions in limine must be submitted in a 3-ring binder with table of contents and tabs, due 2 calendar days before FSC.

Moving parties must lodge a binder with all motion in limine papers in Department R no later than five court days before the FSC.

Parties must jointly prepare and lodge a Motions in Limine Binder in Department 205 no later than five calendar days before the Final Status Conference.

Cross-motions on same issues prohibited; parties must meet and confer to determine single moving party.

Only one joint MSJ allowed without leave of court.

Only one Rule 56 motion per party is permitted; parties may not evade page limits by filing multiple motions, and leave for an additional motion or increased page limits requires a noticed motion with a detailed good-cause showing.

Only one joint summary judgment motion may be filed without leave of court; additional motions require court permission.

Parties must fully integrate the Joint Brief, JAF, JAE, and JAO; failure to comply may result in the motion being stricken and the process repeated.

Only one joint Rule 56 motion may be filed without leave of court; leave requires a joint noticed motion showing good cause, and multiple summary adjudication motions filed without leave result in subsequent motions being stricken.

Post-trial briefs are prohibited unless the court specifically authorizes additional briefing.

Cross-motions on same legal issues are highly disfavored; non-moving party should argue in response.

No more than one joint Rule 56 motion may be filed without leave of court, whether styled as summary judgment or summary adjudication.

JAE must be filed as single PDF unless file-size constraints require multiple PDFs, which must be titled by part and exhibit series.

Related materials with mixed sealing status must be filed as single docket entry with multiple attachments.

A superseding information or indictment must not be attached to the plea agreement and must be filed separately with its own docket entry.

Motion papers are to be filed on ECF only after full briefing is complete.

Motion and cross-motion papers must be bundled and filed only after full briefing, on the later of the reply due date or scheduled return date.

Social Security motions must be fully briefed before filing

Motion papers must be bundled and filed only when fully briefed (hold until fully briefed), except for reconsideration and Rule 4(a)(4)(A) motions.

Noncompliance with the Bundling Rule leads to termination of the motion without prejudice.

Parties must submit one joint requests-to-charge document that includes agreed requests and any disputed proposals with objections.

Motion papers must be bundled and fully briefed before filing.

Under the Bundling Rule, movants serve full motion papers but file only a cover letter on ECF, and that cover-letter filing preserves timeliness.

The Court requires bundled motion filing (file only when fully briefed) except for FRCP 50/52/59/60 motions, remand motions, and pro se movant motions.

Motion papers must be held and filed only when the motion is fully briefed.

Motion papers must be fully briefed before electronic filing; cover letter required with service.

The movant must file all motion papers, statements of contentions, and the administrative record together as a complete set.

Digital courtesy copies of all motions in limine and oppositions must be included in pretrial filings using the format specified in Paragraph five.

Box.com link for pretrial filings must be obtained 28 days before pretrial conference

Only one summary judgment motion per party is allowed in each patent case absent leave of court, with related entities counted as one party.

At least 12 weeks required between dispositive/Daubert motions deadline and final pretrial conference.

Daubert motions seeking to preclude expert reliance at the class certification stage, and all related oppositions and replies, must be included in the same brief as the class certification motion or opposition, and in the same brief as the class certification merits argument, respectively.

When filing an amended pleading, party must concurrently file a redlined or highlighted version comparing to the prior operative pleading.

Joint designations of deposition testimony must be filed 7 days before trial

Case-dispositive motions must be bundled and heard together on cut-off date.

Cross-motions for summary judgment require four sequentially filed briefs (plaintiff opening, defense opening/opposition, plaintiff opposition/reply, defense reply) rather than three pairs of simultaneous briefs, unless the parties agree to reverse the order.

Each side's motions in limine must be filed in a single document.

Separate joint letter required for each discovery device in dispute.

A proposed verdict form must be filed with the motion for class certification.

Separate briefing on in limine requests is prohibited unless the Court permits it.

Motions in limine must not be filed separately.

A party may not combine motions based in whole or in part on different facts into a single motion.

In limine requests must be included in proposed pretrial order, limited to 3 per side.

Separate briefing on in limine requests is prohibited unless the Court permits it.

The parties must combine their previously unfiled briefs into one Joint Claim Construction Brief, presenting positions on each claim term in sequence, and file it by the specified date.

The parties must serve individual claim-construction briefs without filing them, then submit a joint claim-construction brief.

Motions in limine and separate briefing on in limine requests may not be filed; requests and responses must instead appear in the proposed pretrial order, unless the Court permits otherwise.

First Day Binders require submission of a virtual hyperlinked hearing agenda and delivery of one physical binder to Chambers.

In limine motions and separate briefing may not be filed; requests and responses must be included in the proposed pretrial order unless the Court permits otherwise.

Claims Binders require delivery of a physical binder to Chambers.

Exhibit Binders require submission of a virtual binder unless otherwise requested by Chambers.

Motion papers must be filed promptly after service.

If a party intends to introduce exhibits at a hearing, that party shall before the hearing begins submit two tabbed binders containing all documentary exhibits organized by exhibit number. If the number of exhibits is so voluminous as to make compliance with this rule impractical, the parties shall contact the Court for guidance.

At this point the parties should meet to collate the various disputed and undisputed proposed findings, submitting to the court ONE CONSOLIDATED pre-trial order signed by all the parties to the action.

Electronically filed sentencing letters must be grouped as attachments to one document marked SENTENCING MEMORANDUM with the caption and docket number clearly indicated.

No paper submissions to Chambers without Court request.

Motions in limine must be filed with the Joint Pretrial Order.

Paper-filed sentencing letters must be grouped into one filing under a cover marked SENTENCING MEMORANDUM with the caption and docket number, and submitted to the Clerk’s Office.

Motion papers must be filed promptly after service and not held until all submissions are complete.

Non-ECF motion papers must be filed promptly after service.

Motion papers must be filed promptly after service.

Electronically filed letters must be grouped as attachments to one document marked SENTENCING MEMORANDUM that clearly identifies the caption and docket number.

Motion papers must be filed on ECF only when fully briefed (except pro se).

Parties must jointly submit two sets of specified trial materials 4 days before trial, printed double-sided, in 4-inch or less binders with index and tabs.

Exhibits referenced in briefs, and unpublished/non-Texas state cases not on Westlaw/Lexis must be attached to the brief or pleading.

Requests for expedited consideration must be filed separately from the motion.

Required attachments must be filed as separate documents, not bundled with the Joint Pretrial Order.

Required attachments for jury and non-jury trials must be filed as separate documents, not bundled together.

B 122 Form must be e-filed as a separate CM/ECF event.

Prohibited from combining unrelated pleadings into a single electronically filed document.

Prior to Final Pretrial Conference, offering party must provide copy of exhibits in properly tabbed and indexed notebook.

Proposed voir dire questions must be bundled with the Joint Pretrial Order.

At least 14 days before the initial pretrial conference, counsel must file a joint case management plan listing the identities and purposes of witnesses, sources, and types of documents, and other requirements for a prompt and inexpensive preparation of this case for disposition by motion or trial. See Fed R. Civ. P. Rule 26(f).

Parties represented by counsel must file Form JS44c with all original pleadings.

Counsel should NOT attempt to avoid this requirement by unnecessarily separating a motion, brief, and attachments or exhibits into separate submissions.

Final disposition forms must be submitted together with all final orders of dismissal and final judgments.

No more than 2 motions should be set for one Special Set hearing unless you have received prior approval from the Court by coordinating with her JA.

Every order submission must be accompanied by a motion and supporting documents or a letter of explanation.

After briefing is complete, counsel must email the Motion to Dismiss and all responses, replies, memoranda, and supporting authority to the judicial assistant, copying all relevant parties.

Add-ons are not accepted by the Court.

Do not combine documents that may need to be introduced separately as evidence.

Competing proposed orders must be submitted together via CourtMAP with supporting documents and a cover letter explaining that the parties are submitting competing orders.

All proposed orders must be submitted through CourtMap together with the respective motion and cover letter.

Only two motions per case may be heard at a single courtMAP motion calendar event, a second motion requires a separate courtMAP event, and cross-notices are allowed only if mutually coordinated with a separate event.

Each proposed order submission must be accompanied by the corresponding motion and all supporting documents, or a letter of explanation.

Add-on motions to special set hearings are not permitted.

Add-on motions may not be added to special set hearings.

Each of the three competing-order documents must be submitted as a separate, clearly named attachment rather than one combined attachment.

Motions in limine must be filed as independently-noticed motions and may not be bundled into omnibus motions.

Proposed findings of fact will only be accepted if submitted within a civil trial memorandum, to avoid ex parte communications.

Motions in limine must be filed as independently-noticed motions and may not be bundled into omnibus motions.

The court will not accept an exhibit designated as both joint and separate; each exhibit must be either joint or separate.

Motions in limine must be filed as independently-noticed motions, not bundled into omnibus motions.

Parties must file omnibus (consolidated) motions in limine with oppositions and replies rather than individual motions.

Motions in limine must be independently noticed and may not be submitted as omnibus motions.

Motions seeking an extension of time should be submitted separately from a motion for service by publication as they each have separate requirements to support an order.

Stipulated exhibits must not be duplicated, removed from their binders, or placed in a separate binder.

All proposed electronic exhibits must be submitted on a single electronic storage device unless integrity would be corrupted or volume makes single-device storage impractical.

Parties submitting separate Plaintiff and Defendant exhibits must not also submit joint exhibits.

Dispositive motion cutoff is set 105 days before trial.

Defense trial briefs due 17 days before trial.

Untimely motions in limine will be stricken.

Defense expert disclosures due 30 days before pretrial motions deadline.

Motions and supporting legal arguments must be filed as a single document.

Government rebuttal disclosures due 14 days before pretrial motions deadline.

Motions in limine must be filed 28 days before trial.

Pursuant to Local Civil Rule 16, Judge Jones sets the dispositive motion cutoff 90 days prior to the trial date. This allows the parties 30 days to brief the motion; the Court 30 days to decide the motion; and the parties 30 days after receiving the ruling to prepare for trial, if necessary.

Each party may file one omnibus motion in limine.

Motions challenging expert witnesses must be filed by pretrial deadline.

All motions must be filed before pretrial motions deadline.

Dispositive motions (dismissal, summary judgment, etc.) must be filed together with supporting papers.

Courtesy copies and proposed orders for remote proceedings must be submitted in one email per case; multiple emails for same case are prohibited.

A default and a default judgment must be obtained separately and cannot be bundled or decided at the same time.

All damages must be proven up together in one motion, not piecemeal.

All damages must be proven up together in one motion, not piecemeal, without the Court's prior consent.

Piggy-backing motions is prohibited without prior leave of the Court.

Sur-replies are not permitted.

(6) All motions shall be in ONE tabbed PDF file with all supporting documents. Each tab shall be clearly titled (e.g., Notice of Motion, Complaint, Service Affidavits, Motion for Default, etc.) and neatly and intuitively organized.

The Court will not enter multiple judgments of foreclosure in one case without prior consent.

Requests for a sealed-bid auction must be presented by separate motion.

Parties should not submit copies of any briefs relating to contested motions until all briefing is complete. Courtesy copies should be one complete set sent electronically to the Calendar R email, and one complete set of physical courtesy copies delivered to Room 2208. In the physical copy all exhibits must be tabbed and all materials must be printed double-sided.

Moving for judgment piecemeal against separate litigants is prohibited.

Motions must be bundled into a single tabbed PDF with all supporting documents.

At least three sets of trial exhibits, in binders no more than 2½ inches wide and on a thumb drive, must be delivered to the court at least 14 days before trial.

Each party must submit a tabbed binder containing motions in limine and oppositions, with each opposition placed immediately behind its motion in the same tab.

Parties must file joint pretrial conference statement, and provide to the Court one (1) set of BINDERS NO MORE THAN 2½ INCHES WIDE – with the following: 1. Proposed jury instructions; 2. Proposed verdict form(s); 3. Proposed voir dire and juror questionnaire (if any); 4. Proposed statement of the case; 5. Witness lists; 6. Exhibit lists, including any disputed exhibits; 7. Motions in limine, oppositions, and supporting declarations or requests for judicial notice; and 8. Deposition designations and objections — At least 14 days before the Pretrial Conference

The parties must provide deposition-designation binders and binders containing the motions in limine and related filings.

Declarations, requests for judicial notice, and attached exhibits supporting or opposing motions in limine must be submitted in a separate tabbed binder.

Three sets of joint trial exhibit binders and thumb drives must be delivered to the court on the day of trial.

Each party must submit one tabbed binder containing its motions in limine in numerical order, with the opposition immediately behind each motion in the same tab.

Trial exhibits must be provided in at least three binder sets and on a thumb drive.

The parties must provide the court one set of binders no more than 2½ inches wide containing the specified pretrial materials.

Each party must submit a tabbed binder containing its motions in limine in numerical order, with each opposition placed immediately behind its motion in the same tab.

The required tabbed binders must be submitted with the Joint Pretrial Conference Statement.

A binder containing motions in limine and oppositions must be provided three court days before the pretrial conference.

Co-parties (multiple plaintiffs or defendants) must file joint motions unless there is a clear conflict in their positions.

Discovery must be completed before arbitration; no discovery or dispositive motions after arbitration unless motion was filed before and unresolved.

All grounds for relief should be set forth in a single, comprehensive motion. A motion to dismiss, for example, should not be divided into separate motions for each count but rather should include all bases for relief.

One set of pre-marked trial exhibits required; provide two copies to Judge.

Supplemental joint appendix required for multiple response parties.

Exhibits must be pre-marked, exchanged, and compiled into a joint exhibit book with electronic copy for final pretrial conference.

The joint exhibit chart and all exhibits must be provided together on a single USB flash drive organized into three subfolders: PDFs (documents), Videos (AVI or compatible), and Audio (WAV or compatible).

Exhibits must be provided as two tabbed loose-leaf books (one for judge, one for law clerk) with joint, plaintiff's, and defendant's exhibits.

For summary judgment motions, parties must prepare a consolidated statement of facts (structured with movant’s assertion/evidence, respondent’s response, and movant’s reply per paragraph) and joint exhibits; cross-motions require separate statements of facts but a single consolidated exhibit set, unless a party is a pro se prisoner.

Joint appendix must be filed separately on same day as first summary judgment motion.

Joint appendix required for multiple summary judgment motions.

Reply briefs are not permitted on motions in limine.

Cross-noticing is prohibited; agreed additions must be cleared with chambers through an amended notice, while unilaterally cross-noticed motions will not be heard and may be denied without prejudice.

Exhibits intended for introduction at a hearing or trial must be bundled in a tabbed binder with an index.

Orders may not be uploaded until all required documents are filed and three business days have passed to allow the Clerk to docket them.

A stipulated proposed order must be submitted with its stipulation as one filing.

Otherwise, do not send any paper documents to Chambers.

A cover letter must accompany each party-agreed proposed order uploaded through the e-portal.

Attorneys must not upload an order until all required documents have been filed in the court file.

Please do not submit any hearing binders or other documents to Chambers.

Briefing notebooks may not be submitted.

Motions unilaterally cross-noticed for a hearing will not be heard and may be denied without prejudice.

Hearing binders and other documents may not be submitted to chambers unless the court specifically approves or rejects them.

Attorneys must not upload orders until all required documents are filed and three business days have passed for the Clerk to docket them.

These motions and responses should not be bound with the Pretrial Order. They should be filed separately on the CM/ECF system.

Expert testimony exclusion motions must be filed as part of Rule 56 summary judgment or motion in limine, not as separate motions.

Motions in limine must be filed separately from joint pretrial statement.

The parties must meet and confer to seek agreement on jury instructions and verdict forms and submit one combined set to the Court.

Motions in limine must be filed in consolidated filings; responses due one week after filing; no replies without leave.

Replies to motions in limine are not permitted unless ordered by the Court.

Exhibit submission requirements: USB drives and binders for proposed and final exhibits.

Motions in limine must not be bound with the proposed final Pretrial Order and must be filed separately through CM/ECF by Court-set deadlines.

Motions in limine must be filed separately.

Parties filing motions in limine should submit their initial motions and the supporting exhibits in one document for the Court. Responses to motions in limine should also be submitted in one document.

Initial motions in limine and supporting exhibits should be submitted together in one document.

The motions should not be bound with the final pretrial order.

File separate motions for separate motions or forms of relief rather than combining them in one filing.

Combination pleadings are prohibited; petitions, objections, applications, and motions must be filed separately, and filings must be self-contained without incorporating other filings by reference.

File modification petitions separately from enforcement petitions.

No party should include more than one motion in a single filing or combine a response and a motion or a reply and a motion in one filing (with the exception of a true cross-motion for summary judgment). This applies to requests for attorneys' fees or sanctions. A separate petition/application/motion should make such requests.

Motions, responses, replies, and other filings must be submitted individually; combined filings will not be accepted.

Motions, responses, replies, and other filings must be submitted separately; combined filings will not be accepted.

A document must be filed jointly when a Rule or Court order requires joint filing.

File each motion separately and designate it as a motion.

Motions, responses, replies, and other court-requested filings must be submitted individually; motions must be filed separately and designated as motions, and combined pleadings will not be accepted.

No party should include more than one motion in a single filing or combine a response and a motion or a reply and a motion in one filing (with the exception of a true cross-motion for summary judgment). This applies to requests for attorneys' fees or sanctions. Such requests should be made by separate motion.

Required or court-ordered joint documents must be filed jointly, unless an opposing party fails to participate in good faith, in which case a party may file separately and notify the Court why.

No party should include more that one motion in a single filing or combine a response and a motion or a reply and a motion in one filing. This applies to requests for attorneys' fees or sanctions. Such requests should be made by separate motion.

Supporting affidavits, declarations, memoranda of points and authorities, and similar documents must be attached to the moving papers when filed.

Supporting affidavits, declarations, memoranda, and similar documents must be attached to the moving papers when filed.

Each party must provide the Court with a binder containing its filed motions in limine and related papers, and failure to do so may result in denial of the motion.

Supporting affidavits, declarations, memoranda of points and authorities, and similar documents must be attached to the notice of motion, order to show cause, or other moving papers when filed.

Parties must provide their own filed motions in limine and related papers to the Court in a binder, and failure may result in denial of the motion.

Supporting affidavits, declarations, memoranda, authorities, and similar documents must be attached to the moving papers when filed.

At the first appearance for trial, each party must provide at least four conforming binders of trial exhibits for the court, witness stand, and each side.

Supporting affidavits, declarations, memoranda of points and authorities, and similar documents must be attached to the moving papers when filed.

If there are more than a small number of exhibits, the sides are to put all exhibits into one or more binders with appropriate tabs.

Supporting affidavits, declarations, memoranda of points and authorities, and similar documents must be attached to the notice of motion, order to show cause, or other moving papers when filed.

An order shortening time may be filed only if the underlying motion was filed previously or is filed simultaneously.

Supporting affidavits, declarations, memoranda, and similar documents must be attached to the moving papers when filed.

To seek entry of default within two court days, the petitioner must submit the request to enter default and proof of service of summons separately from other documents.

Papers relating to a pleading or request for order must be bundled into a single electronic transaction.

All fee-request support, including timesheets, must accompany the original petition or be filed contemporaneously; nonconforming fee requests may be forfeited.

If neither party timely submits the required statement, the case is removed from the settlement conference calendar and the parties must file a new Family Law At-Issue Memorandum and pay applicable filing fees.

All plaintiff motions in limine and their respective oppositions must be bundled in a single indexed, tabbed binder submission to the trial department.

A request to continue or vacate a settlement conference must be filed and lodged separately from any motion or ex parte application seeking a trial-date continuance.

All initial joint defense motions in limine and their respective oppositions must be bundled in a single indexed, tabbed binder submission to the trial department.

Plaintiffs must provide the trial department with courtesy copies of all plaintiffs’ MILs and their respective Oppositions together in one indexed, tabbed binder.

Papers relating to a pleading or request for order must be bundled and E-Filed together in one transaction.

A request to continue or vacate a settlement conference must be filed and lodged separately from any request to continue the trial date.

A substituted-judgment petition to create and fund a trust or execute estate-planning documents must be filed separately from any other petition.

All additional motions in limine and their respective oppositions must be bundled in a single indexed, tabbed binder submission to the trial department when leave is granted.

Multiple parties should coordinate/consolidate briefing for same relief.

Motions to extend, amend, continue, or vacate deadlines must be filed as a single motion regardless of party agreement.

Multiple motions by same party on same date must be briefed together.

Stipulated protective orders must be filed together as a joint motion.

Summary judgment and Daubert motions consolidated on single hearing date; 25-page limit without leave.

Stipulated protective orders must be filed as joint motions.

Multiple motions by same party must be bundled.

All stipulations must be filed as joint motions.

Parties may select Friday hearing dates 30-60 days after filing, or following Monday if Friday is federal holiday; do not contact chambers.

Multiple motions by same party on same date must be briefed together in single 25-page memorandum.

Motions must be set for hearing 35 days after filing.

Stipulations must be filed as joint motions, except for certain dismissals under FRCP 41(a)(1)(A)(ii).

BUT IF YOUR MATTER INVOLVES MORE THAN A HANDFUL OF RELATIVELY SHORT DOCUMENTS: please provide hard copies to chambers IN ONE JOINT BINDER by postal system (USPS, Fed-Express, UPS etc.) or hand delivered to the 1st floor drop-box.

Each order must be uploaded separately; multiple orders in one submission will be rejected.

After mediation, the parties must schedule the temporary-relief or final hearing in a 30-minute special-set slot.

A proposed order must not be uploaded more than once.

Companion-case files must remain separate, and pleadings may not be consolidated into a single pleading file.

The Petitioner ☐/Attorney ☐ further certifies that all the required information was previously filed or filed concurrently with the Petition.

Special-set hearings use 15- or 30-minute increments, with only one time slot per case per day.

Papers filed in a termination of parental rights case must be submitted as separate documents and may not be bundled under one Notice of Filing.

Motions and orders concerning companion cases must be filed separately in each case.

Papers filed in a petition for adoption case must be submitted as separate documents and may not be bundled under one Notice of Filing.

When the parties do not file exhibits jointly, they must file them unilaterally at least two calendar days before the evidentiary hearing.

A motion to withdraw filed within 90 days of trial must be set on the UMC docket.

Motions to compel initial responses must be filed as a single motion regardless of the number of discovery sets.

A trial notebook containing the trial brief, pre-marked exhibits, exhibit list, and witness list must be delivered to the courtroom Clerk five court days before trial or hearing; two notebooks are required (one for the Court, one for the Clerk).

At least two (2) court days before trial, the parties are expected to provide the following materials: A Trial Binder with the following included: 1. Table of contents 2. Joint Trial Readiness Report 3. Limine motions and oppositions and index of Limine motions 4. Copy of Joint Witness List. Listing the witness as either percipient or expert. 5. Copy of Joint Exhibit List (follow grids format – see attachment to ADR, with objections noted) 6. Copy of Trial Briefs 7. Copy of the Operative Pleadings, e.g., Complaints and Answers.

Motions to compel further responses, and motions to deem facts admitted, should be reserved and filed as separate motions for each set of discovery at issue.

Motions to compel further responses, and motions to deem facts admitted, should be reserved and filed as separate motions for each set of discovery at issue.

Motions to compel initial responses must be filed as a single motion regardless of the number of discovery sets at issue.

Discovery motions must not combine discovery sought from multiple parties; each party must file its own separate motion.

Parties must bring a separate binder with motions in limine and opposition, arranged in order, to trial call.

Each party must submit one set of 3-ring exhibit binders to the court (clerk), provide one set to the other party/counsel, and have binders available for witnesses.

Motions to compel initial responses must be filed as a single motion regardless of number of sets.

Motions to compel further responses, and motions to deem facts admitted, should be reserved and filed as separate motions for each set of discovery at issue.

Discovery motions must not combine multiple parties; each party must file its own separate discovery motion.

Add-ons to existing UMC hearings are prohibited unless all parties agree, and no more than two motions may be noticed per case on UMC.

Every written continuance request must be filed with an attached proposed order.

Add-ons, cross notices, exchanged motions, and amended notices are prohibited without written Court approval delivered by U.S. mail, overnight, or hand-delivery.

Motions for reconsideration must be submitted by hand-delivery, overnight, or UPS Ground with an accompanying letter.

Every zoom request must be accompanied by a Motion for Zoom together with the corresponding underlying motion.

Add-ons to UMC or Special Set hearings require agreement of all parties, no more than two motions may be noticed per UMC, and an agreed add-on requires an Amended Notice of Hearing.

Competing proposed orders are not accepted; parties must schedule a UMC hearing to resolve disputes over the substance of a proposed order.

Every proposed order must include the underlying motion, either attached or referenced by the date of the pre-filed CMS motion.

Agreed orders submitted through the CMS workbench must bundle the motion and the opposing counsel's written response/agreement as attached documents.

Double-booking or adding matters onto a pre-scheduled hearing is prohibited at all times unless approved by the Court.

In virtual proceedings, no evidence may be submitted to the Court before the hearing; evidence must be presented contemporaneously with the proceeding per Administrative Order 2022-37-Gen.

Orders must be filed together with their appropriate motion on CMS or the Court will reject the order.

Each motion generally must be filed separately with its own supporting memorandum, although inextricably intertwined motions that are substantively related or alternative may be filed together.

The Court will not accept an exhibit binder in advance without prior approval.

Cross-notices are prohibited unless the opposing party agrees and the court approves them.

The verified checklist and notice of final hearing must be filed as separate documents simultaneously.

The Verified Checklist and Notice of Final Hearing must be filed as separate documents simultaneously.

When stipulations are submitted, the order must be submitted separately rather than attached to or placed at the end of the stipulation.

Copies of primary legal authorities cited must accompany the chamber copy.

All agreements must be attached to the final judgment in one PDF file.

A proposed order must not be sent to the court until opposing counsel approves its form.

All agreements must be attached to the Final Judgment in a single PDF file.

The verified checklist and notice of final hearing must be filed simultaneously as separate documents.

Counsel must promptly file a Notice of Cancellation when the order is signed before the scheduled hearing.

Email all Ex Parte hearing documents together in one PDF attachment by noon on the business day immediately before the hearing.

Submit motions and proposed orders as separate Portal documents; combined motion-and-order documents are prohibited.

Submit each hearing document as a separate file; do not combine all documents into one PDF or submit ZIP files.

Motions and proposed orders must be submitted as separate Portal documents; combining them is prohibited.

Motions and proposed orders must be submitted as separate Portal documents and may not be combined in one document.

Do not submit consolidated forms; submit each e-filed stipulation as its own document with the proposed order, and e-file motions and stipulations for the court to consider them.

Do not submit two orders for the same case simultaneously through the ePortal.

Motions and proposed orders must be submitted as separate Portal documents and may not be combined in one document.

Courtesy materials should be combined into as few attachments as reasonably possible.

Cross-noticing or piggybacking motions is prohibited unless all parties and the Court consent.

Do not ask the Court or its staff to hold a proposed order for an objection period; such proposed orders will be rejected.

After a motion is scheduled, subsequent motions may not be cross-noticed without prior approval from opposing counsel and the Court.

Additional motions may be added by cross-notice only with all parties’ agreement, must have hearing materials submitted timely or they will not be heard, and receive no extra hearing time without Court approval.

When a hearing addresses multiple pleadings or motions, one proposed order must account for each in its title, body, and ordered section; separate orders for individual motions will be rejected.

The e-docket call form must be submitted together with the required joint pre-trial statement.

The E-Docket Call Form must be submitted with the required Joint Pre-Trial Statement and Jury Instructions.

The E-Docket Call Form must be submitted together with the required joint pre-trial statement.

Additional motions may not be piggy-backed by cross-notice unless counsel confirms with opposing parties and the online calendar that sufficient additional time is available and can be reserved.

Additional motions may not be piggy-backed by cross-notice for hearings under one hour without the Judicial Assistant’s permission.

All documents must be submitted together in one email to the listed address.

Additional motions may not be piggy-backed by cross-notice for UMC hearings without the Judicial Assistant’s permission.

Additional motions may not be piggy-backed by cross-notice unless counsel first confirms that enough additional hearing time can be reserved.

Additional motions may not be added by cross-notice unless counsel first confirms that sufficient additional hearing time can be reserved.

Additional motions may not be piggy-backed by cross-notice unless counsel confirms with opposing parties and the online calendar that sufficient additional time is available and can be reserved.

An opening brief and a response brief may not be combined into a single filing.

An employer moving to vacate a conditional judgment must file an answer at the same time as the motion to vacate.

Bulk filings of multiple cases or combined PDFs are prohibited; different case numbers must be filed individually, same case documents may be in single transaction.

The stipulation dismissing the cause of action must be filed together with the voucher acknowledging receipt of the minor's funds.

Withholding Orders and QDROs must be presented separately as Agreed Orders after judgment is entered.

Withholding orders and similar post-judgment orders must be presented separately as agreed orders after entry of judgment, not with the judgment itself.

Bulk filings combining multiple cases or documents into one PDF are prohibited.

Schedules of property must be filed together with the bond.

Vouchers must be numbered, arranged in order, securely fastened under a separate cover, and filed with the account.

File the stipulation of dismissal together with the financial institution voucher acknowledging receipt of funds.

Bulk filings combining multiple cases or multiple documents into one PDF are prohibited; documents in different cases must be filed in separate transactions, but multiple documents within the same case may be accepted in a single e-filing transaction.

A copy of the Periodic Imprisonment Rules and Regulations must be filed with every Petition to Revoke Periodic Imprisonment.

The joint witness list must be included with the Trial Notebook copy.

Declarations in summary judgment motions must be filed separately, not attached to the motion or memorandum.

All proposed jury instructions must be included in the Trial Notebook.

The proposed verdict form must be in the Trial Notebook, and if the parties cannot agree, both parties' proposed forms must be included.

Stipulations must be submitted as one WORD-format document so the court can modify the order portion.

The court requests that motions in limine be placed in a binder separate from the Trial Notebook's other contents.

Jury instructions and verdict forms must be bundled and submitted as part of the Joint Trial Notebook.

If there are 3 or more in limine motions, they must be bound separately from the trial notebook and delivered to the Courtroom Clerk with it.

If five or more motions in limine are filed, they must be placed in a separate binder.

If there are more than six exhibits, and to the extent that exhibits are standard size and not too bulky, they should be placed in 3-ring binders with tabbed dividers.

In limine motions and oppositions must be included in the trial notebook.

Motions in limine should be placed in a separate binder from the rest of the Trial Notebook.

A motion to cancel sale, including an emergency motion, must be submitted as early as possible to permit adequate review and action.

The respective proposed orders must be filed as exhibits attached to the specified Notice of Filing Proposed Order cover pleading.

Hearing materials exceeding 20 pages collectively must be delivered in a binder to the courthouse no later than two weeks before the hearing.

An additional motion may not be added to an already scheduled hearing without the court’s prior approval, and an unapproved motion will not be heard.

The parties must file their respective proposed orders as exhibits attached to the specified Notice of Filing cover pleading.

The parties should seek to file all exhibits jointly, but in the absence of a joint filing, must file uni- laterally at least 2 calendar days in advance.

Emailed exhibits should be sent as one PDF file, or as few PDFs as possible, and include an index, cover sheets before each exhibit, and should be easily identified.

The exhibits should be organized pursuant to the instructions set forth in Judge Fahlgren’s division procedures, and should be hand delivered or mailed to Robert M. Foster Justice Center at Magistrate Wallace’s attention.

Emailed exhibits should be sent as one PDF file, or as few PDFs as possible, and include an index, cover sheets before each exhibit, and should be easily identified.

The court encourages parties, where possible, to coordinate and submit one copy of supporting materials.

Counsel are encouraged to timely file written argument supporting and opposing their positions.

Parties are encouraged, where possible, to work together and submit one copy of supporting materials for the court’s consideration.

Custody or visitation motions must be filed separately from motions concerning financial issues.

The parties must coordinate a single Rule 14 submission containing the initial letter and all responsive letters.

Bundling motion papers and exhibits is prohibited because each must be e-filed separately.

Each electronically submitted document or exhibit must be filed separately and identified in NYSCEF's Additional Document Information section.

Omnibus affidavits, affirmations, memoranda of law, and similar papers may not be filed for use across multiple motions.

All motion papers and related exhibits must be filed separately on NYSCEF with a concise and accurate description of each document.

Similarly situated parties should make reasonable efforts to consolidate briefing papers and avoid duplication in combined briefs.

After good-faith efforts to resolve a discovery dispute, the parties must coordinate a single Rule 14 submission containing the initial and responsive letters.

Similarly situated parties should make reasonable efforts to consolidate briefing papers to avoid duplication, and the Court will consider requests to enlarge word limits for combined briefs.

Counsel should not combine all motion papers in one PDF under one document number, and each e-filed document must receive its own docket number.

Custody and visitation motions may not be combined with motions concerning financial issues.

Filing a dispositive motion does not stay discovery.

CRSR must be jointly filed by all parties.

Exhibits must be submitted by judge-set deadline or will be returned.

All files must be provided on a single storage device (USB, CD, or DVD).

The parties must jointly complete one document containing the specified information, obtain signatures from participating parties or authorized representatives, and have the plaintiff file it.

The parties should submit agreed jury instructions jointly; disputed instructions should be submitted separately with supporting citations to controlling authority.

Dispositive and non-dispositive motions should not be combined.

A motion to dismiss and an answer must not be combined in one filing.

A response and a motion must not be combined in one filing.

Motions generally must not be combined in one filing, except when motions of the same type seek alternative relief.

A motion to dismiss must not be characterized as a motion for summary judgment in the alternative.

All pretrial submissions should be submitted simultaneously.

Court prefers to manage related patent cases as a group.

Supporting documents must be docketed as attachments to the primary filing.

Parties must combine their served briefs into a single Joint Claim Construction Brief for filing.

Bulk exhibits are prohibited; exhibits must be filed separately.

Joint submissions required 3 weeks before trial via USB and docket.

Bulk exhibit filings are prohibited; exhibits must be filed separately, with one allowed exhibit list containing separately attached exhibits.

Parties must exchange all briefing for specified motions before filing, serve in sequence, then file all papers simultaneously under separate docket entries, exempting pro se cases.

Parties must refrain from filing summary judgment briefs until all briefing is complete, then file consecutively in order of moving papers, oppositions, replies.

No separate briefing is allowed on in limine requests unless the Court permits otherwise.

Separate briefing on in limine requests is prohibited unless the Court permits otherwise.

If multiple parties support or oppose an in limine request, they must combine their arguments into a single three-page submission.

Appendix materials must be submitted in a Joint Appendix.

Out-of-town cases scheduled same as local cases.

Each pleading or document must be separated from other documents in a PDF packet and uploaded as its own document.

For domestic new case filings, submit all required documents in the same bundle while uploading each as a separate document.

For an order under the 7-day rule, file the Notice of Presentment, Proposed Order, and Proof of Service as one document and file a separate copy of the proposed order.

For an order under the 7-day rule, file the Notice of Presentment, Proposed Order, and Proof of Service together as one document, and file a separate additional copy of the proposed order.

Multiple motions may not be heard in a single filing.

The summons may be included in the complaint’s bundle but must be a separate document.

Counsel shall attempt to stipulate exhibits before the trial date.

Parts of a document may be uploaded in the same bundle if each document is under 25 MB.

Parties seeking default judgments are encouraged to e-file proposed judgment documents at the same time as their motion.

The Court encourages parties to agree on jury instructions and submit them jointly.

Multiple pleadings or documents may be submitted together in one submission as a bundle.

The required trial-preparation items must be completed at least seven days before trial or jury selection, whichever is sooner, and supplied to the judge and all parties in separate binders along with the documents marked for trial use.

Papers opposing a main motion must be submitted in a stand-alone document and may not be bundled into a cross-motion.

Every dispositive motion must be accompanied by a complete set of pleadings.

Papers opposing a cross-motion must be submitted in a stand-alone document and may not be bundled into a reply.

On the first Part appearance, counsel must submit an indexed binder or notebook of trial exhibits for the court, copies for each trial attorney, and witness originals in similar binders or notebooks, with plaintiff exhibits numerically tabbed and defendant exhibits alphabetically tabbed.

All multiple motions on the same matter must be submitted on the same date because the Court does not stagger submission dates.

Sur-reply papers are prohibited.

Exhibits must be filed separately rather than bundled with other filings.

A trial conference must be held immediately before every nonjury trial.

Court with a courtesy hard copy (in a binder) of the following:

All exhibits must be tabbed or placed in a binder for easy reference.

The parties must cooperate and prepare a single set of depositions marked for the judge's consideration rather than separate sets.

Cross-motions and additional separately briefed dispositive motions must be separately scheduled with the Court and may not be included as part of a response.

Parties must cooperate and use a single set of depositions marked for the Judge's consideration rather than separate sets.

Cross-motions and additional separately briefed dispositive motions must be separately scheduled with the court and may not be included in a response to a motion.

Each motion is allotted one hour, and cross-motions or additional separately briefed dispositive motions must be scheduled separately and may not be included in a response.

A request for consideration on shortened time requires both noting the underlying motion in the regular course and filing a separate motion to shorten time.

Motions to shorten time are strongly disfavored and should only be used in extraordinary circumstances. If a party wishes the Court to consider a motion on shortened time, the underlying motion must be noted in the regular course, and a separate motion to shorten time should be submitted.

The Court prefers that all designations, counter-designations, and objections for a single deposition be presented at the same time to avoid confusion or duplication regarding what requires rulings.

For cross-motions for summary judgment, parties are strongly urged to stipulate to four briefs filed sequentially (with combined opposition/cross-motion and reply/cross-opposition) rather than six briefs in two parallel sets.

The proposed order to seal and the proposed protective order must be submitted as separate documents in the e-mailed packet.

The Court's practice is to hear multiple parties' dispositive motions on the same date in the interest of judicial economy.

E-filed documents should be combined into a single PDF with bookmarks separating content, unless the file exceeds 35 MB.

Documents may not contain multiple filings in the same document; each filing must be filed separately.

If a filing exceeds 35 MB, it must be split and the remaining split documents attached to the lead document as an attachment.

Only admitted exhibits may be included on the exhibit jump drive; demonstratives are prohibited unless authorized by written court order.

At the close of evidence, parties must jointly upload all admitted exhibits to an external jump drive.

The Court requests that witness lists, exhibit lists, and motions in limine be submitted jointly by all parties in one notebook.

The Court accepts electronic or courtesy binders delivered before the hearing and requests a proposed order be filed prior to the hearing.

Attorneys and parties must collaborate and transmit participant information to the Court Reporter in a single submission.

For complicated motions, the Court appreciates brief books containing briefs, orders, and highlighted important cases.

Combining multiple documents from a single filing into one PDF with bookmarks is preferred but not required.

The moving party must file the motion, proposed order, and supporting brief at the same time.

The moving party must file the summary-judgment motion, proposed order, and supporting brief together; if the brief is missing, an opposing party may seek withdrawal by praecipe.

The moving party must file the motion, proposed order, and supporting brief concurrently; if the brief is omitted, an opposing party may praecipe for the motion to be deemed withdrawn without prejudice.

The moving party must file the motion, proposed order, and supporting brief concurrently; if the brief is omitted, an opposing party may praecipe for the motion to be deemed withdrawn without prejudice.

The moving party must file the motion, proposed order, and supporting brief together; if the brief is missing, an opposing party may seek withdrawal by praecipe.

Motions are sent for disposition after the briefing schedule is complete or upon a party’s praecipe, unless the parties agree to extend the schedule.

Briefs and memoranda must be filed separately and may not be appended to other documents.

After all briefs are filed, either party may praecipe for disposition, after which the prothonotary forwards the motion and briefs to chambers.

The motion, proposed order, and supporting brief must be filed together; an opposing party may praecipe to have a motion without its brief deemed withdrawn without prejudice.

After the praecipe for disposition is filed, the prothonotary must forward the objections and filed briefs to chambers as a set.

An administrative-appeal assignment must be accompanied contemporaneously by each party's memorandum of law and the complete administrative-agency record.

The moving party is responsible for assembling all completed filings into one comprehensive package for submission to the court.

All case-initiating documents, required documents, attachments, and exhibits must be submitted individually as separate files in the same initial submission or filing.

Subsequent pleadings, motions, and other papers must be submitted individually, with related documents filed as separate files in the same submission or filing.

Counsel should file memoranda for all parties simultaneously and as early as possible.

Bills, receipts, invoices, photographs, and similar items may be submitted together in one attachment.

Bills, receipts, invoices, photographs, and similar items may be grouped into a single EFS attachment.

A single discovery motion may address multiple parties and discovery requests, and one order may memorialize all resulting rulings.

Bills, receipts, invoices, photographs, and similar items may be combined into one attachment.

The parties must meet and confer and bring three complete copies of the Joint Exhibit Binder to the court on the first day of trial.

At the Trial Readiness Conference, the parties must bring a three-ring Joint Trial Binder containing the listed pretrial documents when applicable.

The parties must meet and confer and bring two complete Joint Exhibit Binders to the first day of trial, allocating the premarked original to the witness and one copy to the Court.

Any provided trial brief must be included in the judge's working binder with the other trial documents.

Neither side may file other substantive documents addressing the discovery issues, and disputes exceeding the five-page IDC scope must be addressed across multiple IDC dates.

Substantive discovery documents must not be submitted for the conference, although they should be available for reference, preferably electronically.

Documents should be jointly submitted.

The parties should jointly submit trial-readiness documents, but may submit individual documents if they cannot agree.

The vital statistics form must be submitted separately.

All agreements must be attached to the final judgment in one PDF file.

Exhibits must be submitted as separate documents rather than bundled into one PDF.

Final Disposition Form 1.998 must be submitted separately.

Litigants should not send binders or notebooks containing copies of pleadings already in the court file.

The sender should, if possible, send all documents in one submission.

The court generally prefers that parties not send binders or notebooks containing copies of pleadings already in the court file.

Parties with many exhibits are encouraged to use a thumb drive or zip files to transmit evidence or to agree to appear in person.

A motion seeking substantive relief may not be joined with a discovery application.

After a motion is fully submitted or argued, no further submissions or post-argument letters concerning that motion will be accepted.

Reply papers may not be submitted on an order to show cause.

Sur-reply papers and correspondence addressing a motion's merits are prohibited and will not be considered.

A motion seeking substantive relief may not be combined with an application for discovery relief.

A motion seeking substantive relief may not be combined with any application for discovery.

Sur-replies, post-sur-replies, and related correspondence are prohibited unless the court expressly permits them in writing or orally during virtual argument.

A discovery motion must stand alone, may not include requests for other relief, and must initially be returnable in Motion Support Office, Room 217, on a non-court-holiday weekday at 9:30 a.m.

A reply to a cross-motion is prohibited.

Multiple documents may not be grouped under one exhibit, and each exhibit must contain one document uploaded separately through NYSCEF.

Each NYSCEF exhibit must contain one separately uploaded document, and multiple documents may not be grouped under one exhibit.

Motion papers are limited to moving, opposing, and reply papers, but reply papers on an Order to Show Cause require advance permission.

Motion papers must be bound together, and the Court will not accept loose motion papers, affidavits, affirmations, or exhibits.

Oversized papers may be rejected or not considered, and motion papers may include only moving, opposing, and reply papers because sur-reply papers are prohibited.

Sur-reply papers, including sur-replies contained in letters, are prohibited and will not be considered.

All documents needed to decide an application must be included with that application; prior filings with the Clerk are insufficient.

The listed foreclosure motion documents must be filed separately and not bundled together.

Bulk filings combining multiple cases or documents in one PDF are not accepted, except multiple citations may be transmitted in one transaction directly by a law enforcement agency.

Documents bearing different case numbers must be filed in separate transactions.

The following documents are deemed to be of independent legal significance, and so they should be filed separately rather than being bundled with other documents: Returns of service of summons; Notices of Motion; Military Affidavits; Appearances; Any certificate of publication; and In foreclosure cases, the following types of documents: prove-up affidavits; attorney fee affidavits; loss mitigation affidavits; sale documents, including the report of sale, certificate of sale, receipt of sale; motion for approval of sale; notice of motion for approval.

Parties should file separate court documents rather than bundle them, except that motions may be bundled with supporting exhibits unless an exhibit is listed in part (b).

Separate, unrelated tasks may not be combined in a single invoice entry.

Individual documents in one case may be filed in a single transaction, but each must be uploaded and titled separately under General Order 9.09.

A party may bundle a motion with supporting exhibits unless an exhibit is among the document types required to be filed separately.

The guideline child support calculation must be attached to form FL-342 unless form FL-342 itself sets out the calculation inputs.

A marital settlement agreement incorporated by reference in a proposed judgment must be physically attached to the judgment.

The plea attachment form must be submitted together with the Misdemeanor Advisement of Rights, Waiver and Plea form.

Motions in limine may not aggregate separate evidence or issues into a single motion.

This plea attachment must be submitted together with the Misdemeanor Advisement of Rights, Waiver and Plea form.

The DUI penalties attachment must be submitted together with the Misdemeanor Advisement of Rights, Waiver and Plea form.

The stipulation must be filed together with the Case Management Conference Statement.

An electronically filed motion must attach previously filed materials as new exhibits rather than incorporating them by NYSCEF docket number.

Every stipulation of adjournment must be accompanied by a briefing schedule.

A motion must be fully briefed at least 10 days before its return date absent prior written permission, and submitted stipulations must meet that deadline.

Final accounts must be submitted as one consolidated accounting rather than multiple annual accounts.

Discovery remains available while any motion is pending unless the court directs a stay.

Filing a dispositive motion does not stay discovery unless the court orders otherwise.

Hard copies are optional, but parties may bring specified exhibits or affidavits in hard copy for the court.

Each motion must be filed separately; omnibus motions are prohibited.

Individual submissions of pre-trial order portions are prohibited unless accompanied by written certification of good-faith efforts to consolidate.

Each motion in limine must be a separate document, not combined with other motions.

Omnibus and generalized motions are prohibited and will be denied as vague and dilatory.

Each motion in limine must be a separate document and attachment to the email.

Do not file omnibus motion packets; file one motion per filing.

Each motion in limine should be sent as an individual file rather than bundled with other motions.

A minimum of four full sets of pre-numbered exhibits is required.

Entire sets of written discovery documents may never be lodged with or received by the Court; only extracts are permitted.

Entire deposition transcripts may never be received by the Court; only pertinent provisions or extracts may be used.

All final approval issues must be heard at the same time; if settling parties file separate motions for fees, incentive awards, or expense reimbursements, those motions must be set to be heard concurrently.

If attachments to the Settlement Conference Statement collectively exceed twenty (20) pages, the attachments should be lodged with the Court separately from the Statement, and will be returned to the party at the conclusion of the MSC.

If attachments to the Settlement Conference Statement collectively exceed twenty (20) pages, the attachments should be lodged with the Court separately from the Statement, and will be returned to the party at the conclusion of the MSC.

Proposed orders may not be submitted with moving papers before a hearing on a regularly noticed motion, unless ordered by the Court or required by statute or Rule of Court.

Jury instructions must be submitted in one agreed-upon package, appropriately ordered, with disputed instructions flagged.

Subsequent motions may not be piggybacked or cross-noticed onto a scheduled motion's reserved time without prior approval from both the court and the original scheduling attorney.

A proposed order must not be submitted until its supporting documents are viewable in the Clerk's system.

Exhibits may be filed together in one filing, but the filing must include an index identifying the exhibit pages.

Jury instructions must be submitted as one agreed-upon package in proper presentation order, with disputed instructions flagged.

The parties should seek to file all exhibits jointly, but in the absence of a joint filing, must file unilaterally at least 2 calendar days in advance.

Counsel and parties should file exhibits jointly where possible.

For self-represented litigants with IFP status or a waiver of filing fees and costs, the Court waives the exhibit binder requirement and accepts exhibits by email.

Chambers will provide physical Exhibit Binders to qualifying self-represented litigants upon request made at least 14 days before trial.

Uncontested general asbestos motions do not require a presentation.

When an evidentiary issue is anticipated, a party may submit its Motion in Limine with its Pretrial Statement.

Exhibit binders are preferred, but alternatives for voluminous exhibits will be reviewed at the pretrial conference.

Using binders for trial exhibits is preferred.

The child name-change petition, applicable consent, and order or decree must be fully completed and filed as separate lead documents.

PDF packages and portfolios are prohibited; documents for one filing must be combined into one PDF or have their exhibits filed as attachments.

A notice of hearing or proposed order may not be bundled or contained within a motion.

Documents requiring separate filing fees must be filed separately; one document may not combine multiple such filings.

Documents in an agreed divorce finalization submitted electronically must be filed as separate lead documents.

The adult name-change petition and order or decree must be fully completed and filed as separate lead documents.

Proposed or draft orders may not be filed alone; they may be filed only as attachments to other pleadings.

Parties filing motions to retain must file any objection to mediation simultaneously with a motion to retain.

All necessary evidence must be bundled into the same email as the submission request.

Parties filing motions to retain must file any objection to mediation simultaneously with a motion to retain.

All necessary evidence must be included in the submission email.

PDF proposed orders may optionally be attached as an exhibit to the motion in the same filing.

Each person seeking to appear by Zoom must separately file their own motion and proposed order.

File each document individually under a specific title; do not combine multiple motions or proposed orders into one document or attach a proposed order to a motion.

The parties should seek to file all exhibits jointly, but in the absence of a joint filing, must file uni- laterally at least 2 calendar days in advance.

If the guardians of the property and person are different, they must make a good-faith effort to file the initial guardianship report jointly.

A cover letter is optional, but if filed it must be filed separately through the E-portal rather than attached to the referenced motion or order.

Case law may be submitted as a composite under a Notice of Filing.

Separately filed petitions to set aside and for admission of a will or letters of administration should be set for hearing at the same time when filed concurrently.

Orders should be submitted separately rather than attached to another document or pleading.

Probate Code §200, et seq. authorizes a petition to establish fact of death to be included in a verified petition for probate of will or for letters of administration. However, attorneys are encouraged to file a separate petition under the same number in order to avoid administrative difficulties. No such separate petition may be filed after the filing of a petition for final distribution; and, if a petition to establish fact of death is then filed, it should be in a new proceeding under a new number.

A petition to set aside may be filed separately or worded in the alternative to request admission of the will and letters if the set-aside petition is denied.

Any two or more parties may file a joint case management statement instead of filing separate statements.

Attorneys are encouraged to file a separate petition under the same case number to avoid administrative difficulties.

Motions, responses, replies, exhibits, and proposed orders must each be filed as stand-alone documents, though they may be filed in the same envelope.

Do not split your documents into separate envelopes when filing.

All motions should have their own proposed order (Please do not combine multiple motions into one order).

Each pleading, motion, response, exhibit, proposed order, and notice must be filed as a separate document.

The parties are asked to eliminate duplicate exhibits by agreement when possible.

The parties are asked to work with opposing counsel or self-represented parties to narrow motion-in-limine issues by agreement.

When multiple open cases for a defendant are disposed of at the same time, all cases must be reported on one attorney voucher, and the same event may not be billed twice.

Exhibits may be combined in a filing, but each exhibit must remain easily identifiable and clearly labeled.

Multiple charges for one defendant may be reported on one form, but the form must include companion cause numbers and charge-specific work descriptions; insufficient explanations may result in non-payment for the hour.

The Court encourages parties to file responses, replies, and objections as early as possible.

In an appropriate case, parties may consider abatement or separate trials as a potentially more suitable and less burdensome alternative to severance.

Multiple charges for the same defendant may be bundled on one claim form.

Permitted evidentiary material supporting or opposing summary judgment must be filed with the original motion or responsive memorandum.

Evidentiary material may not be filed with a reply memorandum or at oral argument without prior leave of court.

Do not file multiple versions of the same document. Please email the Court’s staff attorney if a motion or document needs attention. The filing of multiple version of the same thing bogs down our system, causing decisions to take longer.

For motions needing immediate action, parties should first confer and, if possible, file a joint or unopposed motion with a proposed entry.

The Court strongly encourages parties to identify and prepare joint exhibits.

Exhibits should, to the extent possible, be bundled with the motion or brief to which they apply.

For a matter scheduled for a hearing, do not submit a proposed order until after the hearing and the Court has ruled.

Submit Count I possession paperwork separately from Count II damages; do not include damages with Final Possession paperwork.

Bulk composite exhibits are prohibited; each exhibit must be uploaded separately.

Do not submit the same proposed order multiple times unless the Court specifically requests it.

Submit Count II damages separately and do not include them with the final possession paperwork.

Parties are encouraged to submit in-camera review requests in manageable batches rather than in one grouping.

2. File the Notice of Motion and Declaration for Joinder – Judicial Council Form (FL-373) with a copy of these forms attached:

Opposition and reply papers addressed to separate motions may not be combined.

Motions generally must be filed separately, subject to the rule's stated exceptions for permitted combined motions.

A request for dismissal may be combined with a motion for good faith settlement.

Requests for sanctions and stays are not treated as separate motions when ancillary to another motion, except where statute requires otherwise.

Discovery motions to compel may be combined when no discovery response has been received and the motions involve the same legal and factual issues.

The filing documents must be assembled in the stated order.

Two copies of the complete document package must be made, with summonses attached as specified.

The filing package must be assembled in the specified order: Sheriff’s Entry of Service, Petition, copy of the pre-existing Court Order, Verification, and Rule Nisi.

Exhibits and supporting materials may be bundled with the main document as one PDF, but a Registered User faced with a technical limitation may separate them into multiple PDFs.

File one complete paper-clipped set of the forms for the court and retain a second complete set for the filer’s records.

The certified transcript must be filed as an attachment to the Commissioner's answer in Social Security cases.

Pursuant to 28 U.S.C. § 636(b)(1)(A), all pretrial motions in Sherman Division criminal cases assigned to United States District Judge Sean D. Jordan, with the exception of motions to suppress evidence, to dismiss or quash an indictment or information made by the defendant, to continue, to sever, and to transfer venue, are hereby REFERRED to United States Magistrate Judge Aileen Goldman Durrett or United States Magistrate Judge Bill Davis, as randomly assigned by the Clerk of Court, for consideration and hearing as deemed necessary, and a determination.

Mock jury studies discouraged in the same division where case is pending.

Court encourages consolidating courtesy copies into a single binder; additional binders permitted but not required.

Paper copies of electronically filed documents should not be provided unless specifically requested by the court.

The plaintiff or petitioner must compile and submit the consolidated pre-trial order.

Each motion must address a single issue, be filed separately, identify the specific statement or evidence, and provide a suppression theory.

Motions in limine may not be combined; each must be filed as a separate document.

A motion should contain all arguments and citations in one document rather than being accompanied by a separate supporting brief.

Motions should consolidate all arguments and citations in one document rather than using a cover motion and a separate supporting brief.

A trial binder in the format available on the Court’s website must be delivered to Department M302 by 9:00 a.m. on the trial date.

Parties must deliver one tabbed binder containing all joint trial documents to Department PS2 before the matter is called; trial documents are not to be filed separately.

Unless there are less than 10 exhibits, all documentary exhibits and photographs (8 ½” x 12” or smaller) should be placed in a loose-leaf notebook with numbered dividers corresponding to the exhibit number.

When more than five motions in limine are filed collectively, the parties must submit a hard copy of the motions in a binder with the joint documents required under Rule C.

Counsel need not lodge copies of out-of-state authorities unless the authority is unavailable on Lexis or Westlaw.

Source Materials for Informal Discovery Hearings must be filed as separate documents.

Written discovery motions between parties are prohibited unless specifically authorized by court order.

Substantive discovery motions filed on docket will be stricken; use discovery calendar instead.

Settlement negotiations before conference are not required but encouraged.

Motions and memoranda are rarely needed.

A motion to continue a trial date must be filed as a routine motion.

A case referred to a special discovery master may use a modified discovery-motion practice protocol.

Otherwise, the compendium and appendix should be separate hardcopy submissions.

Counsel may optionally attach a few short exhibits or authorities directly to a motion or brief.

Movants are encouraged to prepare one compendium containing the opening and reply brief authorities when the reply brief is filed.

The investigator’s bill must be filed with assigned counsel’s attorney-fee application and paid as part of counsel’s expenses.

Every criminal motion other than a discovery motion must be delivered to the court on its filing date.

When an opposing party responds to a motion, the Court will rule only after the matter is fully briefed.

Civil reply briefs may be filed without prior court approval, but responses to them will not be accepted.

When a Scheduling Order exists, a continuance motion must include a proposed Amended Scheduling Order or the Court will not consider it.

When the combined motion, response, reply, and related exhibits exceed 50 pages, the party requesting a hearing must deliver a binder containing all hearing-related documents by noon on the preceding day, failing which the hearing may be cancelled.

If the motion and response exceed 50 pages, a notebook must be delivered to the court two days before the hearing during one of the stated delivery windows.

Case law binders are accepted, and attorneys may highlight portions to focus the Court’s attention.

A movant may not file a summary-judgment motion and a separate brief; all argument and authority must be combined in the motion.

Exhibits should be submitted in one filing when possible.

Exhibits should be submitted in one filing when that is possible.

Documentary exhibits must be marked and uploaded into the Court Filing System as one submission when possible, with the filing party’s designation.

Attachments and exhibits should be combined into one PDF; if too large, they may be filed in multiple parts with the related filing identified in the e-filing comment field.

Attachments and exhibits to pleadings or motions should be combined into one PDF file.

Parties should incorporate by reference, rather than attach as supporting appendices, duplicates of pleadings or documents already in the file.

Counsel are encouraged to file dispositive motions as early as practical.

The person seeking to affect the parties' marital status or their attorney must present the required prove-up documents together in a single package before testimony begins.

For prove-up, the person seeking to affect marital status or their attorney must present the listed documents to the court in one package before testimony begins.

The person seeking to affect the parties' marital status, or that person's attorney, must present the listed prove-up materials to the court in a single package before testimony begins.

The person seeking to affect the parties’ marital status or their attorney must present the required prove-up documents together in a single package before testimony begins.

Orders and judgments may not be bundled with any other papers and must be completely separated.

An electronic transmission to TexasOnline generally may contain only one document.

The court reporter or recorder should prepare only one consolidated record despite multiple notices of appeal or record-preparation requests.

A document may be electronically transmitted with another document as an attachment.

A manila envelope containing confidential exhibits must not be attached to the principal motion or other paper.

Opposition and reply briefs for motions to strike must be filed simultaneously with the corresponding briefs on the merits.

A Request for Order for Special Immigrant Juvenile Findings must be a stand-alone application and may not combine other issues.

Parties are encouraged to file joint pretrial documents whenever possible during the meet-and-confer process.

All documents associated with a sealed filing must be filed together conventionally with the Civil Department.

The Order to Show Cause must be presented at ex parte together with the supporting documents, a Motion for a Show Cause Hearing, and an Order setting the hearing.

Tip: If the document to be filed under seal is one component of a larger pleading, such as an exhibit to a declaration, ensure all documents are filed with the court at the same time to keep the record clear and consistent.

When a document to be sealed is part of a larger pleading, file all documents with the court at the same time.

One (1) week before trial, the parties shall prepare a joint neutral statement of the case for use during jury voir dire and in the initial instructions given to the jury prior to opening statements. The joint neutral statement of the case shall briefly describe the case, including the relevant claims and defenses.