General Motion Practice

Please consult the Tarrant County Local Rules before setting a motion.

Generally, motions are set for hearing every morning and occasionally on Friday afternoons. Depending on the type of motion and notice requirements under the Texas Rules of Civil Procedure, hearings can be obtained in three to 45 days.

Emergency hearings can be obtained by calling the court coordinator. Attorneys should let the coordinator know, at the time the hearing is set, that it is time sensitive and any deadlines that need to be met.

Tarrant County Court at Law No. 2 has the following rules regarding motions (other than dispositive motions):

  1. Parties should use all reasonable means to resolve disputes and avoid the necessity of court intervention.
  2. No motion, objection, or special exception will be set for hearing unless the moving party has certified in the motion, or in an attached letter, substantially the following:

    • "A conference was held on (date) with opposing counsel regarding the merits of this motion. A reasonable effort was made to resolve this dispute without the necessity of a hearing but such effort failed. Therefore it is presented to the Court for determination."

      OR

    • A conference was not held with opposing counsel on the merits of this motion because (set forth in detail the reasons a conference could not held)".
  3. On the date of hearing, on a Discovery Motion or Special Exceptions, the parties appearing for the motion will be directed to discuss the points of contention and attempt to resolve the dispute without Court intervention.
  4. By agreement, and with Court approval, motions which do not require additional evidence or a record may be heard by telephone. The movant will be responsible for arranging the conference call.
  5. The Court will set appropriate motions by submission, however, a motion will be removed for the submission docket if the opposing party objects.
  6. Default Judgments. The Court requires a hearing with testimony to prove up a non-liquidated damages. Liquidated damages can be proven by instruments in writing and no hearing is required.