Category: Northern District Practice Tips

“Unless exempted by LR 83.11 [which deals with attorneys appearing on behalf of the United States Justice Department or the Attorney General of the State of Texas], local counsel is required in all cases where an attorney appearing in a case does not reside or maintain the attorney’s principal office in this district. ‘Local counsel’ means…

“Unless the presiding judge otherwise directs, during a trial or hearing, attorneys must:  (a) stand when making objections or otherwise addressing the presiding judge; (b) use the lectern while examining or cross-examining witnesses; (c) when examining a witness, refrain from making statements, comments, or remarks before or after asking a question; (d) limit to one…

Not without the presiding judge’s permission:  “A party, attorney, or representative of a party or attorney, shall not, before or after trial, contact any juror, prospective juror, or the relatives, friends, or associates of a juror or prospective juror, unless explicitly permitted to do so by the presiding judge.”  See L.R. 47.1.

It depends on your presiding judge’s requirements, which can be found here.

“Unless the presiding judge otherwise directs, all sealed documents maintained on paper will be deemed unsealed 60 days after final disposition of a case.  A party that desires that such a document remain sealed must move for this relief before the expiration of the 60-day period.  The clerk may store, transfer, or otherwise dispose of…

“A party may file under seal any document that a statute or rule requires or permits to be so filed.”  “If no statute or rule requires or permits a document to be filed under seal, a party may file a document under seal only on motion and by permission of the presiding judge.”  “When a…

Typically, one per party:  “Unless otherwise directed by the presiding judge, or permitted by law, a party may file no more than one motion for summary judgment.”  See L.R. 56.2(b).

A motion for summary judgment must, (i) on the first page, under the heading “summary,” contain a concise statement that identifies the elements of each claim or defense as to which summary judgment is sought, (ii) contain the legal and/or factual grounds on which the moving party relies, and (iii) if the motion is accompanied…

Typically, 14 days after the clerk enters judgment:  “A party awarded costs by final judgment or by judgment that a presiding judge directs be entered as final under Fed. R. Civ. P. 54(b) must apply to the clerk for taxation of such costs by filing a bill of costs in a form approved by the…

File a motion for continuance:  “A motion for continuance of a trial setting must be signed by the moving party as well as by the party’s attorney of record.  Unless the presiding judge orders otherwise, the granting of a motion for continuance will not extend or revive any deadline that has already expired in a…