Courtesy copies are required for all covered filings. Details: 1 copy, delivery within 24 hours, by hand delivery. Mandatory chambers copies must be delivered to Judge Fitzgerald's mailbox by 5:00 p.m. on first court day after filing.
Judge Michael W. Fitzgerald's rules set a pre-motion procedure for covered motions. Opposition to motion must be filed 21 days before hearing date.
Judge Michael W. Fitzgerald's rule states these limits: 10 pages. Each party limited to 5 motions in limine (10 pages each) unless leave granted.
Judge Michael W. Fitzgerald's rule states these limits: 10 pages. Motions in limine limited to 5 per party; motions and oppositions limited to 10 pages.
Judge Michael W. Fitzgerald's formatting rule includes binding three ring binder, three hole punched left, no blue backs, and stapled top left. Pretrial documents must be delivered binder-ready with three-hole punch, no blue-backs, stapled top left.
The rule requires caption, judge name, case number, legal argument, and statement of facts. Pro se representation rules: individuals may represent themselves, but corporations, associations, partners, and shareholders must have counsel.
The rule requires notice of electronic filing. All matters for the Court must be filed and served on opposing party.
Parties may contact Judge Michael W. Fitzgerald's chambers by email only as allowed by the rule. Parties must not communicate with judge without opposing counsel present.
Judge Michael W. Fitzgerald's rules specify what an adjournment or extension request must include. The request must include reason for request, original date, and proposed new dates. Motions to add parties or amend pleadings must be noticed by the cut-off date.
Pro se representation rules: individuals may represent themselves, but corporations, associations, partners, and shareholders must have counsel.
Pro se litigants must comply with all court rules and procedures, cannot receive judicial assistance, and face significant disadvantages.
Court strongly recommends against proceeding pro se and suggests seeking counsel, including contingency arrangements.
Parties must not communicate with judge without opposing counsel present.
Contact Courtroom Deputy for inquiries; they cannot provide legal advice or waive requirements.
All matters for the Court must be filed and served on opposing party.
Opposition to motion must be filed 21 days before hearing date.
Motions to add parties or amend pleadings must be noticed by the cut-off date.
Unserved parties will be dismissed at pretrial conference under Local Rule 16-8.1.
Counsel must not use first names alone for witnesses/parties, except for witnesses under 14.
Discovery cut-off date is when all discovery must be completed, not when requests are served.
Discovery motions must be filed early enough to obtain responses before cut-off if granted.
Depositions must start early enough to complete before cut-off; motion to compel requires 6-week meet-and-confer.
Documents and requests for admissions must be served early enough to challenge deficient responses before cut-off.
Expert disclosures must be in writing; expert discovery should begin after initial designation; failure to comply may result in exclusion.
Motion cut-off date established; all motions must be noticed by this date.
Memoranda of contentions, witness lists, joint exhibit list, and motions in limine due 21 days before final pretrial conference.
Court may close hearing dates when motion limit is reached; file motions early to secure hearing date.
Conformed Chambers copies of all documents must be provided to Chambers.
Settlement conference under Court-Directed ADR Program must be completed by Court-set date.
Pretrial documents must be delivered binder-ready with three-hole punch, no blue-backs, stapled top left.
Strict compliance with Local Rule 16 required; no exemptions for pro per parties.
Memoranda of contentions, witness lists, joint exhibit list, and proposed final pretrial order required; format must follow Appendix A.
Non-compliance may result in final pretrial conference being taken off-calendar, continued, or other sanctions.
Proposed final pretrial order, jury instructions, verdict forms, statement of case, voir dire questions, and oppositions to motions in limine due 14 days before final pretrial conference.
Trial briefs due 7 days before trial if desired.
Witness lists must include brief description of testimony and separate time estimates for direct and cross-examination.
Each party limited to 5 motions in limine (10 pages each) unless leave granted.
Motions in limine due 3 weeks before final pretrial conference; oppositions due 2 weeks before; no reply briefs accepted.
Counsel must meet and confer with opposing counsel before filing motions in limine.