John Henry
Procedural intake for Texas civil litigation
Accepting files (214) 673-1960
Reference

Terms of art

The words that do the work, defined plainly. Each links to the mechanism it belongs to and to the order that proves it.

Special appearance

The sworn instrument a non-resident defendant files under Tex. R. Civ. P. 120a to contest a Texas court’s personal jurisdiction without submitting to it. It must be filed before any other plea and heard and determined before any other matter.

Holding your forum against a special appearance →

Forum-selection clause

A contract term fixing the court or county in which disputes between the parties must be brought. Texas treats such clauses as presumptively valid and will enforce them by mandamus.

Holding your forum against a special appearance →

No-evidence motion for summary judgment

A motion under Tex. R. Civ. P. 166a(i) identifying elements the opposing party cannot support, which shifts the burden to that party to produce evidence. The movant files no evidence of its own.

No-evidence summary judgment →

Conclusory

A statement that offers a conclusion without the underlying facts supporting it, so that it cannot be effectively controverted. Conclusory statements are not competent summary judgment evidence, and the defect is one of substance rather than form.

Striking opposing counsel's own declaration →

Mandatory exclusion

The rule in Tex. R. Civ. P. 193.6 that untimely-disclosed testimony is inadmissible unless the party who missed the deadline shows good cause or an absence of unfair surprise. Exclusion is the default outcome, not a discretionary one.

Mandatory exclusion of a late-designated expert →

Turnover order

An order under Tex. Civ. Prac. & Rem. Code § 31.002 requiring a judgment debtor to deliver nonexempt property that ordinary legal process cannot readily reach. The court may also appoint a receiver and enjoin the debtor from transferring the property.

Turnover order and post-judgment receiver →

Post-judgment receiver

An officer appointed under the Texas turnover statute with authority to take possession of, investigate and sell a judgment debtor’s nonexempt property in satisfaction of a judgment.

Turnover order and post-judgment receiver →

Badges of fraud

The factors listed in Tex. Bus. & Com. Code § 24.005(b) from which a court may infer actual intent to hinder, delay or defraud a creditor — transfer to an insider, retained possession or control, concealment, timing relative to suit, insolvency, and others.

Fraudulent transfer →

Substituted service

Service authorized by the court under Tex. R. Civ. P. 106(b) in a manner other than personal delivery, granted on a sworn statement listing where the defendant can probably be found and the specific attempts already made.

Substituted service on a defendant who cannot be found →

Domestication of a judgment

Filing a judgment rendered in one state with a court of another state so that it can be enforced there, under that state’s Uniform Enforcement of Foreign Judgments Act.

Taking a Texas judgment into another state →

Exemplified copy

A copy of a judgment authenticated under 28 U.S.C. § 1738 — certified by the clerk and attested by a judge — which some states require before a foreign judgment may be filed.

Taking a Texas judgment into another state →

Dormant judgment

A Texas judgment on which no writ of execution issued within the period set by Tex. Civ. Prac. & Rem. Code § 34.001. Execution may not issue on a dormant judgment unless it is revived.

Abstract, writ, and the constable →

Abstract of judgment

The instrument that, when recorded and properly indexed in a county, creates a judgment lien on the debtor’s nonexempt real property in that county under Tex. Prop. Code § 52.001.

Abstract, writ, and the constable →

Verified denial

A denial that Tex. R. Civ. P. 93 requires be sworn — capacity, defect of parties, denial of the execution of an instrument, denial of an account — and which is waived if it is not verified.

Verified denial — defect of parties →

Forfeited corporate privileges

The status of a Texas entity that has not satisfied its franchise tax obligations. Under Tex. Tax Code § 171.252 the entity is denied the right to sue or defend in a court of this state.

Special exceptions on a forfeited charter →

Dismissal docket

The list of cases a court has noticed for dismissal for want of prosecution under Tex. R. Civ. P. 165a. A verified motion to retain, filed before the setting, takes a case back off it.

Verified motion to retain →

Send a file

Send the file. That's the whole first step.

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Step 2 — conflicts. One name, before anything is read.
Step 3 — how to reach you

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