Texas Litigation Drafting for Attorneys
Texas civil drafting for petitions, special exceptions, Rule 91a motions, summary judgment and discovery. Litigify structures the work around the Texas rule and court counsel identifies, with the current rule text and local requirements checked for the assignment. Membership from $1,500 a month.
Special exceptions and Rule 91a are distinct
Rule 91 requires a special exception to identify the challenged pleading and its particular insufficiency. Rule 91a addresses causes of action alleged to have no basis in law or fact, subject to its terms and exclusions. The draft uses the procedure counsel selects and states the grounds claim by claim. We do not translate either device into a generic federal motion to dismiss.
Keep the Rule 91a record within its limits
Rule 91a.6 generally directs the court to decide the motion from the pleading and permitted pleading exhibits rather than evidence, apart from the rule’s fee provision. We flag proposed evidentiary material for counsel’s review and confirm the requested relief. Counsel supplies the operative pleading and confirms the specific filing, response and hearing schedule under the current rule.
Use the current summary judgment rule
Texas Rule 166a was rewritten in 2026. The current text distinguishes traditional, no-evidence and combined motions and prescribes their titles and contents. The assignment identifies the selected motion and elements at issue, with a source map for the proof. Counsel confirms which version and timing provisions govern the matter; legacy briefing templates and old subsection references are checked rather than reused without review.
Electronic form and local procedure both matter
Rule 21(f)(8) requires an electronically filed document to be a text-searchable PDF, directly converted when possible, unlocked and compliant with the approved technology standards. We prepare the agreed draft and electronic-document components for counsel’s review. Applicable local rules, standing orders and appellate formatting requirements are confirmed separately; no universal Texas trial-brief page cap is assumed.
Start with the controlling materials.
Scope the jurisdiction-specific work.
Can you draft Texas special exceptions?
Yes. Provide the pleading and counsel’s identified defects. The draft points to the particular allegations and requested clarification or other relief rather than using a general challenge to the entire pleading.
Can you draft a no-evidence summary judgment response?
Yes. Supply the motion, the challenged elements and the evidence counsel intends to use. We map the response to those elements and the current Rule 166a requirements.
Do you file through eFileTexas or attend hearings?
No. Counsel handles signature, filing, service and appearances. Litigify prepares the agreed drafting package and does not request court-filing credentials.