Bill Whitehill

First Business Court Division — Judge Whitehill's Guidelines (rev. Feb. 5, 2026)

Judge Whitehill's comprehensive chamber guidelines for Division 1B (rev. Feb. 5, 2026): a party-autonomy philosophy with active judicial management; professionalism per the Texas Rules of Professional Conduct, the Lawyer's Creed, and Dondi; NO AI NOTETAKERS in virtual conferences; an in-person planning conference within 30 days of the first defendant's appearance (client representative attending; ESI plans pre-discussed; the proposed scheduling order helpful three business days ahead; a one-year trial goal; dispositive-motion cutoff and trial date immovable without leave); early identification of pure legal issues under TRCP 166(g),(p); informal jury-charge flowcharts within 30 days of the scheduling order; status calls every two to three months; email accessibility through the Court Manager and Staff Lawyer with all counsel copied; redline comparisons with amended pleadings; court reporters scheduled for trials and dispositive hearings; targeted document requests with rule-compliant objections; the informal discovery-dispute path (authorized counsel confer → brief court phone conference with non-binding guidance → 7-day letters → motion only for what remains, modifying BCLR 4(d)); electronic courtesy copies only; dispositive-motion responses in 14 days and replies in 7 (expert-strike motions treated as dispositive); special-appearance resolution plans within a week; special-exception hearings on the movant; sealing discipline (redaction-first, temporary orders discouraged, § 134A.0065 for trade secrets, in-camera email delivery); Word proposed orders; hearings requested after filing with a 25-minute-per-side default, conducted in person in the court's hearing room or at the Robert H. Dedman SMU School of Law; briefs per BCLR 5 in 14-point Century Schoolbook with tables for 10+ pages; record-stamped single-appendix practice; a pre-trial conference at least 14 days out with the proposed pre-trial order and limine motions three days ahead; party-selected mediators against a scheduling-order deadline; jury mechanics (fee paid eight weeks out; 30–40 minutes voir dire per party; 10–20 hours of evidence per party; 25–45 minute closings; Casteel-aware charges in Word by trial day one); equivalent non-jury practice with appellate-standard findings; non-speaking objections; a 30-day settlement dismissal presumption; and the court's legal-writing guidance.