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Presenting Dispositive Motions to the Court — 151st District Court practice guide — posted on the court's own website — the court-procedure tier (standing procedures, policies, and preferences the court itself publishes), distinct from the TOPICs-registered local-rules tier (TRCP 3a registration applies to local rules). Operative requirements quoted verbatim; the posted document is the controlling text.
Texas > Harris County > 151st District Court practice guide
The Motion Must be Granted......................................................................................... … Is this a new motion based on different causes of action or defenses? Is this a partial or final motion? Is this an amended motion in that it is presenting new bases for the same relief? Is it a supplemental motion presenting merely additional bases for the same relief previously requested? Is it directed to all of the opposite parties or only some? You get the idea. … Parties/Claims for Relief Either in the title or the first paragraph, the Court must be able to easily identify (a) who is moving for the traditional summary judgment; … Affidavits, in order to be utilized as summary judgment evidence, must satisfy a number of requirements as mandated by Texas courts. … Namely, affidavits must: … (a) be based upon the affiant’s personal knowledge and must state that the facts in it are true, Ryland Group, Inc. v. … The Texas Supreme Court has held that conclusory affidavits do not raise an issue of fact and are not competent summary judgment evidence. … It must state, among other things, that the information contained herein is “within my personal knowledge based upon (describe your involvement) and is true and correct.” The blank should specify how you know that information. … This must be done for each separate evidentiary ruling you want the court to make. … If your pleading must be amended and you are fewer than 8 days from the date of the hearing or submission, then you will need to seek leave to amend your pleading. … That is, after the citation, give a brief description of the point of law for which the case is cited and what the case says about it, such as: “(holding that a negligence cause of action accrues when the plaintiff suffers a legal injury)” or “(discussing what steps an employee may and may not take in preparing to compete with an employer prior to separation 11 from the employer).” The point is, the effective motion or response will allow the court to more quickly grasp what the arguments and authorities are, and show that the cited cases stand for the propositions for which they are cited. … If the attorney includes both the pinpoint cite—and in the case of an unpublished opinion, a cite to the starred or asterisk page—as well as a useful parenthetical, it can only help. … Then, when the court double checks the cites and sees that the cases stand for what they are represented to stand for, that party’s credibility will only increase with the judge. … However, there are a few tips that apply only to the response. … If the only representation that you can come up with when the other side invariably moves for summary judgment on your negligent misrepresentation, fraud and DTPA claims is that the defendant promised he or she would perform under the contract, and then failed to do so, maybe it is time to consider non-suiting those claims and going forward with your breach of contract claim. … Do not be afraid to make such arguments, and take the time to find cases that have similar fact patterns in which courts have denied summary judgment. … Third, do not forget the basic “blocking and tackling” of distinguishing the other side’s cases. … If left unchallenged, the court may conclude that you do not disagree that they stand for the proposition for which the other side has cited them. … The author was frequently amazed to find, both as a litigator, and now as a judge, that cases do not stand for the proposition for which they are cited. … Some seek to prove not only liability in favor of a party seeking affirmative relief, but also their actual damages. … The attorney should remember that they are entitled to not only attorney’s fees up to the time of judgment, but also for successfully defending the judgment on appeal. …
Reviewer note: Own-site content fetched by us 2026-08-22 (Phase 3 justex/page sweep; hashed receipts in custody). Operative mandatory-language provisions quoted verbatim; the full posted document is the controlling text. Judge-authored practice guide; operative expectations quoted.
17 verbatim requirements extracted from 4243-01__2021-05.pdf, across 4 topics.
Judge Eckley-Moulder's courtroom policies (court starts 9:30 sharp): at the Final Pre-Trial, all trial counsel and the defendant must be physically present, phones silenced, and no recording without media clearance.