how to file a motion to dismiss in texas
1 A motion to dismiss a baseless case under Rule 91a must: 2  state that it is made pursuant to Rule 91a; 3  identify each cause of action to which it is addressed; and. 4  specifically state the reasons that the cause of action has no basis in law, fact, or both.ule 91a does not affect the order of pleadings under the Texas Rules of Civil Procedure: a party seeking to make a special appearance or motion to transfer venue must still file those pleadings before filing a Rule 91a motion to dismiss. Expedited Actions: Rule 169.