Judicial Foreclosure Rule 736 
Motions for Default regarding Applications for Expedited Judicial Foreclosure under T.R.C.P. 736, proof of service of the notice to the Defendant/Homeowner is required by filing with the court a copy of the signed green card(s) or if the certified mail is returned  unclaimed, a recitation in the certificate of service by the Plaintiff/Applicant's counsel that a copy of this notice was also sent via regular mail on __________(date) and it was not returned to their office. All Applications for Expedited Judicial Foreclosure can be set on the Submission Docket or Oral Docket.

Motion for Substituted Service
Motions for substituted service filed in the 80th District Court must be in strict compliance with Texas Rules of Civil Procedure Rule 106. 

A proper form of order relative to substituted service is available here.

Motions for withdrawal of counsel
All motion for withdrawal of counsel involving a Corporation must be set for oral hearing unless all counsel agree to the motion. The following, in substance, must be in the Motion and Order:

"If the corporation is not represented by an attorney within 14 days from the signing of the order to withdraw, the corporation's pleadings may be struck and a default judgment may be rendered against the unrepresented defendant corporation." For review-TRCP 7, Kunsto-Plast, Inc vs. Formosa Plantis 937 SW 2nd 455, 456 (Tex.1996)

Hearings are on Friday's @ 9 a.m. with 3 days written notice to the Court.

Motions for Default Judgment
Motions for Default Judgment filed in the 80th District Court must be in conformity with the Texas Rules of Civil Procedure, particularly Rule 239 and Rule 239a. A motion for Default Judgment may be set for oral or submission docket.

An Affidavit of Non-Military status as to an individual defendant is, of course, required.  This proof should be based on personal knowledge or, at a minimum, by reference to https://www.dmdc.osd.mil/scra/owa/scra.home (if you are having problems with this site, please call the Department of Defense and the number listed on the website.  Do not call the Court for assistance with this matter).

Motions to Retain
Motions to retain filed in the 80th District Court should indicate an adequate factual background to justify retention of the case. Motions to Retain must be set on the oral docket and if not set prior to the Dismissal Docket will be heard at the time of the Dismissal Docket. Motion's to Retain are not rule on summarily. See Local Rule 3.3.4.

Motions to Reinstate                                                                                                                                                        
Motions to reinstate must bet set on the oral docket.

Mediation Requirement
At least 60 days prior to trial counsel/pro se partites need to provide the Court with a Rule 11 agreement indicating who they would like to mediate the subject case. The Court prefers that the parties agree to the mediator but if an agreement cannot be reached the Court will make an appointment unless an objection to mediation is granted by the Court.  

Setting Cases for Trial
If you need to set a case for trial please contact the Trial Coordinator, Loris Garrett at 713-368-6098. He will advise you of the available trial dates. Once you receive some possible trial dates you must contact the opposing counsel and agree on said trial date. Once you have come to an agreement please submit a rule 11 dicatating the trial date to the Trial Coordinator Loris Garrett. If the parties want a Docket Control Order they must agree to all pre-trial deadlines and submit a proposed DCO to the Court. A proper form of DCO is available here: Docket Control Order* ALL DISPOSITIVE MOTIONS AND PLEAS IN SEC. 7 OF DOCKET CONTROL ORDER MUST BE SET AND HEARD AT LEAST 30 DAYS PRIOR TO THE TRIAL DATE. AN AGREEMENT TO A MEDIATOR MUST BE FILED 60 DAYS PRIOR TO THE TRIAL DATE.

Trial Continuances
ABSENT EMERGENCYS, TRIAL CONTINUANCES MUST BE HEARD NO LATER THAN 14 DAYS PRIOR TO THE TRIAL DATE.
Agreed motions and orders for continuance must contain an agreed trial date and filed at least 14 days prior to trial. Prior to submitting a motion for continuance please contact the Trial Coordinator, Loris Garrett @ 713-368-6098 to obtain available trial dates. ALL CONTINUANCES REQUESTING A SUMMER SETTING MUST ALSO INCLUDE A WAIVER OF VACATION FOR THE TWO WEEK PERIOD THAT IS REQUESTED.
Please do not file prior to having spoken with the trial coordinator.All continuances must specify in the motion if this is the first continuance or the number of continuances previously filed.The continuance must be agreed and approved as to form and substance otherwise it will need to be set for an oral hearing with the clerk of the court. PLEASE INDICATE IN YOUR MOTION FOR CONTINUANCE HOW MANY PREVIOUS CONTINUANCES HAVE BEEN FILED IN THE CASE.

Trial Procedures
Prior to the time your case is assigned for a pre-trial please insure that you have exchanged all your pre-trial motions with opposing counsel(s) and that you have had a chance to discuss any problems that you may have in order to streamline the pre-trial. Have all exhibits pre-marked and seperated as to which you have agreed on and those that you may have problems with. All pre-trial motions must be exhchanged and filed with the court according to the Trial Preparation Order which is normally sent out by the Court approximately 30 days prior to the trial date. 

Once your case is assigned to trial please bring a copy of your Proposed Charge on a disc so that any revision can be made.

Severance Requirements

1. The motion for severance must be set either by submission or oral hearing.

2. The motion for severance must state the basis for the severance.

3. The order of severance must include the following information: 

• How you want the case to be styled.
• Case number, i.e. 2006-32041-A.
• What parties are to be severed into the severed case.
• What documents are to be severed into the severed case.
• State if the severed order disposes of the severed case or will it remain an active case.
• State who will pay for the cost of the severance.

4. If the motion is granted, the attorney requesting the severance will be responsible for providing the clerk of the court with certified copies of the documents being severed out that are mentioned in the order before the Court will sign the severance order.