Texas Motion for Summary Judgment

Count every period under Rule 4 (Tex. R. Civ. P. 4)

The day of the act, event, or default is not included; the last day is included unless it is a Saturday, Sunday, or legal holiday; Saturdays, Sundays, and legal holidays are not counted in any period of five days or less.

File the motion electronically where electronic filing is mandated, with your email address on it (Tex. R. Civ. P. 21(f)(1)-(2))

Attorneys must electronically file documents in courts where electronic filing has been mandated, and the email address of an attorney or unrepresented party who electronically files a document must be included on the document.

Serve the motion through the electronic filing manager when the other side's email address is on file (Tex. R. Civ. P. 21a(a)(1))

A document filed electronically under Rule 21 must be served electronically through the electronic filing manager if the email address of the party or attorney to be served is on file with the electronic filing manager.

No hearing or submission date within 35 days after the motion's filing (Tex. R. Civ. P. 166a(g)(1))

Unless the motion is withdrawn, the court must set it for a hearing or submission within 60 days after the motion's filing, or within 90 days if the court's docket so requires, on a showing of good cause, or if the movant agrees.

Calendar the response: due within 21 days after the motion is filed (Tex. R. Civ. P. 166a(d)(1))

Except on leave of court or agreement of the parties.

Calendar the reply: due within 7 days after the response is filed (Tex. R. Civ. P. 166a(e)(1))

The movant may file a reply; except on leave of court or agreement of the parties, it is due within 7 days after the response is filed.

Each party submits a proposed order before the hearing or submission date (Tex. R. Civ. P. 166a(g)(3))