THE HONORABLE W. EDWIN DENMAN

412th DISTRICT COURT

BRAZORIA COUNTY, TEXAS

 

CERTIFICATE OF CONFERENCE BETWEEN COUNSEL

(Required by the 412th District Court on all Motions except for Summary Judgments)

 

            No counsel for a party shall file, nor shall any clerk accept for filing, any motion except a Motion for Summary Judgment, unless accompanied with a “Certificate of Conference” signed by counsel for movant in one of the forms set out below.

 

            Prior to the filing of a motion, counsel for the potential movant shall personally attempt to contact counsel for the potential respondent to hold or schedule a conference to resolve the disputed matters.  Counsel for the potential movant shall make at least three (3) attempts to contact counsel for the potential respondent.  The attempts shall be made during regular business hours on at least two business days.

 

            A “Certificate of Conference” shall mean the appropriate one of the following three paragraphs (verbatim):

 

(1)        “Counsel for movant and counsel for respondent have personally conducted a conference at which there was a substantive discussion of every item presented to the Court in this motion and despite best efforts the counsel have not been able to resolve those matters presented.

 

Certified to the _____ day of ______________, 20____, by __________________.”

 

(2)               “Counsel for movant has personally attempted to contact the counsel for respondent to resolve the matters presented as follows:

 

(Dates, times, methods of contact, results)

 

Counsel for the movant has caused to be delivered to counsel for respondent, and counsel for respondent has received a copy of the proposed motion.  At least three (3) attempts to contact the counsel for respondent followed the receipt by counsel for respondent of the proposed motion.  Counsel for respondent has failed to respond or attempt to resolve the matters presented.

 

Certified to the _____ day of ______________, 20____, by __________________.”

 

(3)        “Counsel for movant has personally attempted to contact counsel for respondent, _________________________, as follows

 

(Dates, times, methods of contact, results)

 

An emergency exists of such a nature that further delay would cause irreparable harm to the movant, as follows:

 

(Details of emergency and harm)

 

Certified to the _____ day of ______________, 20____, by __________________.”