Judge Michael Herrod
Individual Rules, Standing Orders & Policies
Communication
Chambers
Phone
Chambers
Document Filing Requirements10 rules
Reply briefs to responses to motions in limine are not permitted.
There are to be no replies.
Document Type
Reply
Parties must appear in person at the Final Trial Management Conference.
Please note the parties must appear in person at the Final Trial Management Conference.
Document Type
Pretrial Order
Exhibits and exhibit descriptions must be presented to the Clerk at least 10 judicial days before trial.
Counsel shall present all exhibits with a list of exhibit descriptions to the Clerk of the Court no less than ten (10) judicial days before trial.
Document Type
Exhibits
Parties must submit a Joint Notice of Statement of the Case within 3 days before the Status Conference.
Within three (3) days prior to the Status Conference, the parties shall submit a written Joint Notice of Statement of the Case, indicating the status of the case, compliance with deadlines, issues that have been resolved, and issues still in need of resolution.
Document Type
Notice
Parties must file a Joint Proposed Scheduling Order covering discovery, motion, and disclosure deadlines.
Counsel and/or the parties shall prepare and file with the Court a Joint Proposed Scheduling Order, for discovery, motion and disclosure deadlines.
Document Type
Proposed Order
Joint Pretrial Statement is due 5 days before the Final Trial Management Conference.
In accordance with Rule 16(d), A.R.C.P., a Joint Pretrial Statement is due five (5) days before the Final Trial Management Conference.
Document Type
Pretrial Order
Written request for a court reporter is due at least 3 court days before the proceeding.
If a court reporter is required, the Court must receive a written request at least (3) court days before the commencement of the proceeding.
Document Type
Request
Parties must file proposed voir dire questions and proposed jury instructions.
The parties should also file proposed voir dire questions, and proposed jury instructions.
Document Type
Jury Instructions
Parties relying on out-of-state cases must provide copies to the Court.
If motions contain out of state cases, that party shall provide the Court with copies of those cases.
Document Type
Motion
Motions must address a single subject rather than being omnibus filings.
Motions should be single subject over omnibus.
Document Type
Motion
Filing & Service rules
Electronic Filing Rules
All pleadings must be filed electronically.
All pleadings must be e-filed.
Page 1 | Motion Practice
Filing Timing and Cure Windows
Motions in limine are due at least 30 days before the Final Pre-Trial Management Conference.
Motions in limine are due no less than thirty (30) days prior to the Final Pre-Trial Management Conference and will not be heard until the pre-trial conference, especially if the case is dispositive.
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections
Written responses to a motion in limine are due within 10 days of receipt.
Written responses to a motion in limine may be filed no later than ten (10) days after receipt of such motion.
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections
Service and Proof of Service Rules
All documents and pleadings must be delivered to opposing counsel on the filing date.
All documents and pleadings shall be delivered to opposing counsel on the date they are filed with the Court.
Page 1 | Motion Practice
Sealing & Redaction Procedures
Sealed filings are discouraged and require a significant reason.
Filings under seal are discouraged. There must be a significant reason to shield records from public view and to create administrative hardships for court access via such designation.
Page 1 | Discovery or Disclosure Disputes and/or Sanctions
Pre-Motion Conference Requirements
Counsel and parties must meet personally to discuss Rule 16(b) matters.
Counsel and/or the parties are to meet personally to discuss all of the matters set forth in Rule 16(b), Ariz. R.Civ.P.
Page 1 | Discovery or Disclosure Disputes and/or Sanctions
Motions to compel require a personal telephone consultation between counsel; correspondence alone is insufficient.
However a motion to compel will not be honored, unless parties make every effort to speak with each other. Civil Rule 37(a)(2)(c) provides that an exchange of correspondence is not sufficient to satisfy the "personal consultation" requirement of the Rule, except in extraordinary circumstances. At a minimum, counsel must speak to each other by telephone to attempt to resolve the dispute in good faith before involving the Court.
Page 1 | Discovery or Disclosure Disputes and/or Sanctions
Counsel must meet and confer to identify disputed evidentiary issues for motions in limine.
Counsel shall meet and confer to identify disputed evidentiary issues that are anticipated to be the subject of motions in limine.
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections
Chambers Communication Rules
Chambers should be copied directly only on emergency measures.
My division should be copied directly only on emergency measures.
Page 1 | Motion Practice
Pretrial scheduling conferences are held by telephone.
Please note pretrial scheduling conferences are held telephonically.
Page 1 | Discovery or Disclosure Disputes and/or Sanctions