Travis County District Court’s unique central docket sometimes has pitfalls for the uninitiated. It requires counsel to think differently about strategy in pretrial hearings and at trial. When seeking summary judgment, movant’s counsel always should err on the side of filing a reply when faced with a response. That’s true even though Texas Rule of Civil Procedure 166a, which governs summary judgment, does not require a reply. Here are three reasons why.
1. Opposing counsel may be long-winded, eating through the time allotted for the hearing. When setting a matter on the Travis County District Court docket, counsel must estimate the amount of time necessary for the hearing. This sounds straightforward, but it’s not.
