TX-ND -- Meet and Confer

The Northern District of Texas imposes a mandatory pre-filing conference requirement for most motions, with detailed certificate requirements that carry real consequences for non-compliance.

LR 7.1(a) -- Conference: 'Before filing a motion, an attorney for the moving party must confer with an attorney for each party affected by the requested relief to determine whether the motion is opposed. Conferences are not required for motions to dismiss, motions for judgment on the pleadings, motions for summary judgment, motions for new trial, or when a conference is not possible.'

LR 7.1(b) -- Certificate of Conference:

'(1) Each motion for which a conference is required must include a certificate of conference indicating that the motion is unopposed or opposed.

(2) If a motion is opposed, the certificate must state that a conference was held, indicate the date of conference and the identities of the attorneys conferring, and explain why agreement could not be reached.

(3) If a conference was not held, the certificate must explain why it was not possible to confer, in which event the motion will be presumed to be opposed.'

Motions requiring conference (LR 7.1(h) table): Amend, change of venue, compel, consolidation, continuance, extend time, intervene, leave to file, limine, more definite statement, preliminary injunction, produce documents, protective order, quash, remand, sanctions, stay, strike, substitute counsel.

Motions NOT requiring conference (LR 7.1(a); LR 7.1(h) table): Dismiss, judgment as a matter of law, judgment on the pleadings, new trial, summary judgment.

Practical note: Subsection (b)(3) contains a default rule with teeth -- if no conference was held and no adequate explanation is given, the motion is presumed opposed regardless of whether it actually is. The certificate must affirmatively explain why conference was impossible, not merely state it was not held.