Real Estate Exhibits for Texas Courts
Texas real estate litigation—including title disputes, foreclosure defense, boundary issues, and broker disputes—requires careful documentation under Texas Property Code and TRCP discovery rules. With 254 counties and strong homestead protections, understanding Texas-specific requirements is essential. This guide covers exhibit preparation for property cases in Texas district courts.
Texas Quick Reference
| E-Filing System | eFileTexas ↗ |
| File Size Limit | 25 MB |
| Exchange Deadline | 30 days before trial (TRCP 194.4) |
| Primary Rule | Texas Property Code, TRCP 194 |
Common Real Estate Exhibits in Texas
Texas Real Estate Tips
- 1Texas homestead protection is constitutional - include homestead affidavit for foreclosure defense
- 2Harris County (Houston) has specific pre-trial exhibit exchange requirements
- 3Dallas County real estate cases often go to specific courts - check local rules
- 4Texas requires 30-day expert exchange under TRCP 194 for property valuation disputes
- 5Title disputes require complete chain of title - go back to patent if necessary
- 6eFileTexas is mandatory - ensure survey images are high resolution in PDF
- 7Bates stamp all closing documents for deposition and trial reference
Common Real Estate Filing Mistakes in Texas
Real Estate Exhibits in Texas: FAQ
What exhibits are needed for Texas title dispute litigation?
Title disputes require: (1) complete chain of title from grantor to grantee, (2) title commitment showing exceptions, (3) survey showing boundaries, (4) deeds in question, (5) any title insurance claims. Go back to the patent or common source of title if ownership is contested.
How do I document Texas homestead protection in foreclosure defense?
Include: (1) homestead affidavit/declaration, (2) driver's license showing address, (3) voter registration, (4) utility bills proving residence. Texas Constitution Art. XVI § 50 protects homesteads - lenders must prove valid exception.
What are eFileTexas requirements for real estate exhibits?
eFileTexas requires PDF format, 25 MB maximum, and clear document naming. Surveys and plats should be high-resolution scans (300+ DPI) to ensure legibility. Large survey files may need to be filed as separate exhibits.
How should I organize closing documents as exhibits?
Organize chronologically: (1) original contract, (2) amendments, (3) inspection reports by date, (4) title commitment, (5) closing disclosure, (6) recorded deed. Bates stamp each page for easy reference during depositions.
What expert exhibits are common in Texas real estate litigation?
Common expert exhibits include: property appraisals (market value), surveys (boundary disputes), structural engineering reports (defect cases), and title expert opinions. Exchange 30 days before trial under TRCP 194.
Related Resources
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