Judge Ana C. Reyes
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- 1 copy
- 2 copies
Sealed Submission
- 1 copy • Hand Delivery • Upon Filing
Adjournments
- Extension/continuance motions must be filed 4+ days prior with specific required content.
- Extension/continuance motions must be filed at least 4 business days before the deadline/hearing and include specific content: original date, prior extensions, good cause, effect on deadlines, suggested deadlines or alternative dates, and opposing party's position.
- Extensions require motion, not stipulation; strongly discouraged.
- Opposition to extension/continuance must be filed by 5 PM next business day or motion is deemed conceded.
- Motions for extensions or continuances are strongly disfavored; counsel should not assume approval even if joint.
- +1 more
Request must include
Communication
Clerk
Chambers
Phone
Chambers
Oral Argument
In Person
Page & Word Limits3 rules
Defendant must answer or file Rule 12 motion within 21 days of transfer.
A defendant who did not answer the complaint before transfer must answer or make any motion otherwise authorized under Federal Rule of Civil Procedure 12 within twenty-one days after the transfer order is filed in this Court's docket.
Support/opposition memoranda limited to 45 pages; reply memoranda limited to 25 pages.
Absent leave of the Court, memoranda of points and authorities in support of, and in opposition to, motions may not exceed 45 pages, and reply memoranda may not exceed 25 pages. See LCvR 7(e).
Brief
45 pages
Applies to: Attorney
Reply Brief
25 pages
Applies to: Attorney
Support/opposition memoranda limited to 45 pages; reply memoranda limited to 25 pages.
Absent leave of the Court, memoranda of points and authorities in support of, and in opposition to, motions may not exceed 45 pages, and reply memoranda may not exceed 25 pages.
Brief
45 pages
Applies to: Attorney
Reply Brief
25 pages
Applies to: Attorney
Document Format Requirements10 rules
Briefs must be indexed, tabbed, double-sided, and in B&W/greyscale.
Briefs and exhibits shall be indexed and tabbed for ease of reference. Pages should be double-sided and in either black and white or greyscale, unless color would aid the Court’s review (e.g., charts and photographs).
Motions must be double-spaced, 12-point Times New Roman, with 1-inch margins and two spaces between sentences.
Motions and submissions should be double-spaced, in 12-point, Times New Roman font, with page numbers and margins of no less than 1 inch, and two spaces between sentences.
All electronically filed documents must be in text-searchable PDF format.
All electronically filed documents are to be in text-searchable Portable Data Format (“PDF”).
Motions must be double-spaced, 12-point Times New Roman, with page numbers, 1-inch margins, and two spaces between sentences.
Motions and submissions should be double-spaced, in 12-point, Times New Roman font, with page numbers and margins of no less than 1 inch, and two spaces between sentences.
Each attachment must be filed as a separate PDF, labeled in ECF; attachments with own pagination should be separate.
Each attachment to a filing (e.g., supporting memorandum, each exhibit, each affidavit, and proposed order) must be filed as a separate PDF and appropriately labeled in ECF. If the attachment has its own pagination, it should be a separate attachment.
Electronically filed documents must be text-searchable PDF; scanned exhibits should use OCR if possible.
All electronically filed documents are to be in text-searchable Portable Data Format ("PDF"). Likewise, exhibits that must be scanned because they exist only in paper format should, if possible, be submitted as text-searchable files using Optical Character Recognition ("OCR") technology, available in Adobe Acrobat.
Joint Pretrial Statement must be submitted electronically in Microsoft Word format via email to chambers.
The parties shall also submit an electronic copy of the Joint Pretrial Statement in Microsoft Word format, including attachments and exhibits thereto, by email to Reyes_Chambers@dcd.uscourts.gov.
DOCX
Preferred A5 coil-bound; accept 3-ring binders up to 2-inch.
The Court prefers A5 coil-bound courtesy copies; however, the Court will also accept three-ring binders (no larger than two-inch). See Exhibit A for sample images. Before providing any courtesy copy that would exceed three coil-bound copies or three two-inch binders, counsel shall contact Chambers for instruction.
Paper exhibits should be submitted as text-searchable files using OCR technology when possible.
exhibits that must be scanned because they exist only in paper format should, if possible, be submitted as text-searchable files using Optical Character Recognition (“OCR”) technology, available in Adobe Acrobat.
Each proposed jury instruction must begin on a new page.
Joint proposed jury instructions, which are formatted so that each instruction begins on a new page
Document Filing Requirements30 rules
Pro se parties must file in paper form; counsel must serve pro se parties in paper form.
In a case involving a pro se party, electronic filing procedures will be followed by parties represented by counsel only. Absent separate order of the Court, the party appearing pro se shall continue to file documents in paper form with the Clerk’s Office. Parties represented by counsel must serve documents upon pro se parties in paper form.
Document Type
All
Non-ultimate relief requests must be in separate motions with supporting law and facts.
Requests other than for ultimate relief that are referenced in the Complaint, such as requests for an extension of time to seek class certification or for a temporary restraining order, shall be made in a motion separate from the Complaint. See, e.g., LCvR 75.1(a). Such motions shall be accompanied by a statement of the specific points of law and authority that support the motion, including, where appropriate, a concise statement of facts. LCvR 7(a).
Document Type
Motion
Juror names and personal information must be kept confidential and not disclosed outside of open court except by court order.
a. Confidentiality. The names and personal information of prospective and sitting jurors in any trial of this matter shall be kept confidential and not disclosed outside of open court, except upon order of the Court. See D.D.C. JURY SELECTION PLAN ¶ 18.1, available at https://www.dcd.uscourts.gov/jury-selections. Counsel and parties are cautioned that violation of this directive may result in contempt proceedings.
Document Type
Jury Selection
Court strictly enforces LCvR 7(h) for summary judgment motions; facts not controverted are deemed admitted.
This Court strictly enforces Local Civil Rule 7(h) when resolving motions for summary judgment and will “assume that facts identified by the moving party in its statement of material facts are admitted, unless such a fact is controverted in the statement of genuine issues filed in opposition to the motion.” LCvR 7(h); see also FED. R. CIV. P. 56(e).
Document Type
Summary Judgment Motion
Amended pleadings must include redline comparison with original.
Any amended pleading shall be accompanied by a redline comparison between the original and the amended or proposed amended pleading.
Document Type
Amended Pleading
Proposed orders required for relief requests; must be filed as PDF and emailed as Word doc with specific subject line format.
e. Proposed Orders. A proposed order should be submitted whenever a party requests relief from the Court, including for matters as routine as proposing a new date for a joint status report (with an exception for FOIA cases, as noted above, supra Section 5.d). Proposed orders should be filed on the docket as a PDF attachment to the corresponding motion, and counsel must also submit proposed orders to the Court by emailing a Microsoft Word version of the draft to reyes_proposedorders@dcd.uscourts.gov. The subject line of the email must include (1) the case name; (2) the case number; (3) the docket number of the corresponding motion; and (4) the title of the order that is proposed as indicated on the Notice of Electronic Filing. Counsel must serve a copy of a proposed order on all other parties by copying them on the email to the Court. Unless the Court directs otherwise, a party must file a motion asking the Court to enter the proposed order. Submitting a draft to the Court’s proposed order inbox is not a substitute for a motion. The Court will consider proposed orders when ruling on motions, but will modify (or disregard altogether) such proposed orders as it deems appropriate, even if all parties agree on the proposed order. Proposed orders (such as stipulated protective orders) require Court approval before they are in effect.
Document Type
Motion
Description of other relief sought must be included.
a description of other relief sought by each party;
Document Type
Joint Pretrial Statement
Stipulations on authenticity, admissibility, or undisputed facts must be included.
stipulations concerning authenticity of documents, admissibility of exhibits or testimony, or undisputed facts;
Document Type
Joint Pretrial Statement
Deposition objections must be in 8-column chart format with specific headings.
a designation of depositions, or portions thereof, to be offered into evidence by each party. To facilitate the Court’s review and ensure clarity of the record regarding the Court’s ruling on each objection posed by any party to the opposing party’s transcript designation or cross-designation, any objections to a designation shall be set out in a chart for each deposition, which chart shall be in a format with eight columns that identifies, for each transcript designation to which objections are lodged, IN TRANSCRIPT PAGE NUMBER ORDER: (1) the sequential number to be associated with the objection; (2) identification of the page and line of the transcript designations offered; (3) the party offering the transcript designation; (4) the party objecting to the transcript designation; (5) the Federal Rule of Evidence relied upon for the objection and a brief explanation by the objecting party; (6) a brief rebuttal by the proponent of the transcript designation; (7) a column, which the parties shall leave blank, with the heading “Sustained”; and (8) a second column, which the parties shall leave blank, with the heading “Overruled”;
Document Type
Joint Pretrial Statement
Summary judgment motions require Statement of Material Facts Not in Dispute formatted as two-column table.
Pursuant to Local Civil Rule 7(h)(1), the moving party shall include a separate document entitled Statement of Material Facts Not in Dispute. This document shall be formatted as a two-column table. In the left column, the moving party shall list in separately numbered rows concise statements of each material fact it
Document Type
Summary Judgment Motion
Description of demonstrative, physical, and videotape evidence must be included.
a description of each specific item of demonstrative evidence, physical evidence, or videotape evidence that will be offered at trial and any objections;
Document Type
Joint Pretrial Statement
Defendant must refile pre-removal answer and distribute Standing Order.
A defendant removing an action to this Court must refile any answer filed before removal and promptly ensure that all parties receive a copy of this Standing Order.
Document Type
Answer
Proposed voir dire questions must indicate questions parties agree on.
proposed voir dire questions that indicate: I. the voir dire questions on which the parties agree; and
Document Type
Joint Pretrial Statement
Exhibits over 1 require index; must be edited to exclude irrelevant material.
Each submission that attaches more than one exhibit shall contain an index of exhibits. Exhibits shall be edited properly to exclude irrelevant material and to direct the Court’s attention to the pertinent portions.
Document Type
Exhibit
Joint Pretrial Statement must be filed at least 14 days before final pretrial conference.
The parties must file with the Court a Joint Pretrial Statement at least 14 days before the final pretrial conference unless the Court sets another filing date. See LCvR 16.5(a).
Document Type
Joint Pretrial Statement
Each attachment must be separate PDF, properly labeled in ECF.
Each attachment to a filing (e.g., supporting memorandum, statement of material facts, exhibit, affidavit, and proposed order) must be filed as a separate PDF and appropriately labeled in ECF. If the document has its own pagination, it should be a separate attachment.
Document Type
Attachment
One 3-ring binder of key cases (tabbed, alphabetical, indexed) required.
The moving party shall also provide one jointly-prepared, three-ring binder comprised of key cases. The cases should be tabbed and in alphabetical order, and the binder should include an index. Pages should be single-sided.
Document Type
Key Cases Binder
Exhibit list must have 6 columns with specific headings for trial exhibits.
a list of exhibits that each party intends to offer during trial and separately identifying exhibits that may be offered if the need arises, followed by specific objections (if any) to each exhibit, which exhibit list shall be in a format with six columns, with separate headings for: (1) exhibit number, (2) description of exhibit, (3) marked for identification, (4) admitted in evidence, (5) objection, and (6) witness/date;
Document Type
Joint Pretrial Statement
Damages must be itemized with each element and monetary amount.
an itemization of damages setting forth each element of damages and the monetary amount thereof (including prejudgment interest, punitive damages, and attorney’s fees) sought;
Document Type
Joint Pretrial Statement
List of pending motions in limine must be included.
a list of any motions in limine that are pending to address issues the parties reasonably anticipate will arise at trial. See infra ¶ 14 regarding the timing for briefing on motions in limine.
Document Type
Joint Pretrial Statement
Proposed orders must be emailed as Word docs to reyes_proposedorders@dcd.uscourts.gov (not filed on docket), with specific subject line, and served on all parties by copying them on the email.
A proposed order should be submitted whenever a party requests relief from the Court. Proposed orders should not be filed on the docket, even if the parties agree on the draft order. Instead, counsel must submit proposed orders to the Court by emailing a Microsoft Word version of the draft to reyes_proposedorders@dcd.uscourts.gov. A PDF file does not count. The subject line of the email must include (1) the case name; (2) the case number; (3) the docket number of the corresponding motion; and (4) the title of the order that is proposed as indicated on the Notice of Electronic Filing. Counsel must serve a copy of a proposed order on all other parties by copying them on the email to the Court. Unless the Court directs otherwise, a party must file a motion asking the Court to enter the proposed order. Submitting a draft to the Court's proposed order inbox is not a substitute for a motion.
Document Type
Motion
At least 5 business days before plea hearing, counsel must submit plea agreement/outline, type of agreement, and statement for agreements outside guideline range to courtroom deputy and chambers.
At least 5 business days, as defined by FED. R. CIV. P. 6(a), before the hearing, counsel must submit the following to the Courtroom Deputy, Chashawn White (Chashawn_White@dcd.uscourts.gov) and Reyes_Chambers@dcd.uscourts.gov: a. The written plea agreement or an outline of the agreement if it has not been reduced to writing, and i. Specification of the type of agreement under FED. R. CRIM. P. 11(c); and ii. For any plea agreement that includes a nonbinding recommendation, under FED. R. CRIM. P. 11(c)(1)(B) or a binding sentencing range, under FED. R. CRIM. P. 11(c)(1)(C), that is outside the applicable guideline range, a statement setting forth
Document Type
Plea Agreement
Motions for reconsideration are strongly discouraged and limited to new arguments.
Motions for reconsideration are strongly discouraged. The Court will not entertain a motion that (a) reasserts arguments previously raised and rejected by the Court or (b) raises for the first time arguments that should have been advanced in the original motion.
Document Type
Motion For Reconsideration
Submissions with multiple exhibits must include an exhibit index; exhibits must be edited to exclude irrelevant material.
Each submission that attaches more than one exhibit shall contain an index of exhibits. Exhibits shall be edited properly to exclude irrelevant material and to direct the Court's attention to the pertinent portions.
Document Type
Submission
Memoranda 10+ pages must include Table of Contents and Table of Authorities.
Every memorandum of points and authorities that is ten pages or longer in length must contain a Table of Contents and Table of Authorities, regardless of whether it is filed in support of or in opposition to a motion.
Document Type
Brief
Joint Pretrial Statement must include specific contents: written statements, joint statement of case, proposed voir dire, proposed jury instructions, expert witness list, motions in limine list, prior convictions list, exhibit list, stipulations, proposed verdict form.
The parties must file with the Court at least 10 business days before the pretrial conference, unless a different time is set by the Court, a Joint Pretrial Statement that contains the contents set out below.
Document Type
Joint Pretrial Statement
Sentencing support letters must be attached to the sentencing memorandum, not sent directly to chambers.
Letters from family members, friends or work associates that the defendant wishes the Court to consider in connection with sentencing should not be sent directly to chambers but should be attached to the sentencing memorandum submitted by counsel.
Document Type
Sentencing Memorandum
Sentencing memoranda must cite supporting authority; witness list required if presenting witnesses.
These memoranda and any responses thereto must cite to supporting legal or other authority on which the parties intend to rely. In addition, a party wishing to present witnesses at the sentencing hearing must submit with the memorandum, a witness list that identifies the relationship, if any, of each witness to the defendant and a brief summary of the purpose or subject matter of the testimony.
Document Type
Sentencing Memorandum
Parties may request oral argument in motions, oppositions, or replies.
A party may include a request for oral argument in its motion, opposition, or reply papers and, if this request is granted, counsel will be advised of the argument date. See LCvR 7(f). See supra ¶ 6(d) for further information concerning oral argument.
Document Type
Motion
Supplemental authorities may be submitted without leave but must follow FRAP 28(j) procedures and not reargue issues.
d. Supplemental Authorities. A party may bring supplemental authorities to the Court’s attention without seeking prior leave of the Court but should refrain from using the submission of supplemental authorities as an opportunity to reargue issues or to respond to arguments made in an opposing brief. Although the submission of supplemental authorities should not be made by letter to the Clerk, but rather in a pleading filed in the usual manner, the parties are otherwise directed to follow the procedures set forth in Federal Rule of Appellate Procedure 28(j).
Document Type
Supplemental Authorities
Filing & Service rules
Filing Timing and Cure Windows
Opposition to extension motions must be filed by 5:00 PM the next day; otherwise motion is deemed conceded.
A party opposing a motion for an extension of time must file, by 5:00 PM the day after the motion is filed, the party's reasons for opposing the motion. If no such explanation is provided to the Court within this time frame, the motion shall be deemed conceded.
Page 4 | 7. MOTIONS FOR EXTENSION OF TIME OR RESCHEDULING HEARING
Late motions must be filed at least 8 days before jury selection.
The Court will entertain late motions for which there is a compelling explanation if filed at least 8 days prior to the date set for jury selection.
Page 7 | Motions in Limine
Oppositions to late motions must be filed at least 5 days before jury selection.
Oppositions to late motions must be filed at least 5 days prior to jury selection
Page 7 | Motions in Limine
Replies to late motions must be filed at least 4 days before jury selection.
replies must be filed at least 4 days prior to jury selection
Page 7 | Motions in Limine
Sentencing memorandum must be submitted at least 10 business days before sentencing.
Any memorandum in aid of sentencing must be submitted at least 10 business days before the date of the sentencing
Page 8 | SENTENCING HEARING
Response to sentencing memorandum must be submitted at least 7 business days before sentencing.
responses (if any) submitted at least 7 business days before the date of the sentencing
Page 8 | SENTENCING HEARING
Parties must submit objections to presentence report within 14 days of disclosure.
The parties must submit objections (if any) in writing to the probation officer and opposing party within 14 days of that disclosure.
Page 8 | SENTENCING HEARING
Joint Pretrial Statement must be filed at least 10 business days before the pretrial conference.
The parties must file with the Court at least 10 business days before the pretrial conference, unless a different time is set by the Court, a Joint Pretrial Statement that contains the contents set out below.
Page 5 | JOINT PRETRIAL STATEMENT
Opposition to motion in limine must be filed within 5 [units not specified] after service.
The opposition shall be filed and served upon the moving party within 5
Page 6 | MOTIONS IN LIMINE
Motion in limine and supporting memorandum must be filed by the date the Joint Pretrial Statement is filed.
Accordingly, the moving party’s motion in limine and supporting memorandum shall be filed and served upon the opposing party no later than the date of filing the Joint Pretrial Statement.
Page 6 | MOTIONS IN LIMINE
Motions in limine must be fully briefed by the time of the pretrial conference.
Motions in limine shall be fully briefed at the time of the pretrial conference.
Page 6 | MOTIONS IN LIMINE
Counsel must advise the Court of unresolved recording disputes at least four days before trial.
If it proves impossible for counsel to resolve the dispute, they shall so advise the Court at least four days before trial
Page 7 | RECORDINGS
Probation officer must disclose draft presentence report within 45 days after referral.
The probation officer assigned to the case shall disclose the draft pre-sentence investigation report to the parties within 45 days after referral.
Page 8 | SENTENCING HEARING
Probation officer must file final presentence report within 10 days of objections submission.
The probation officer shall disclose to the parties and file with the Court the final pre-sentence investigation report, noting any unresolved objections, within 10 days of the submission of objections.
Page 8 | SENTENCING HEARING
Sentencing generally scheduled about 90 days after plea or conviction.
Sentencing will generally be scheduled approximately ninety days after entry of the plea or conviction.
Page 8 | SENTENCING HEARING
Courtesy Copy Requirements
Two courtesy copies required for submissions over 50 pages.
Counsel for the moving party shall provide Chambers, not the Clerk’s Office, with two printed courtesy copies, with ECF headers, of any electronic submission that, along with exhibits, numbers fifty (50) pages or more in total length.
A courtesy copy of any sealed submission must be delivered to chambers on the day it is filed.
Parties must deliver a courtesy copy to chambers of any sealed submission on the day it is filed with the Court to avoid any delay in receiving notice of the sealed matter.
Page 2 | 4. SEALED SUBMISSIONS
Courtesy copies required for electronic submissions of 50+ pages (including exhibits), with specific formatting: spiral-bound, double-sided, tabbed exhibits, ECF headers.
Counsel shall provide Chambers, not the Clerk's Office, with a printed courtesy copy, with ECF headers, of any electronic submission that, along with exhibits, numbers fifty (50) pages or more in total length. Such courtesy copies shall be in spiral-bound binders, with double-sided pages. Exhibits shall be tabbed for ease of reference.
Page 2 | 5. FILING GUIDELINES
Pro se, IFP, and incarcerated plaintiffs excused from courtesy copies.
Pro se, in forma pauperis, and incarcerated plaintiffs are excused from providing courtesy copies.
Sealing & Redaction Procedures
Protective orders alone insufficient for sealing; must confer with opposing party and provide results in motion to seal.
Parties may not rely solely on designation under a protective order to file documents under seal. Even when a protective order has been issued in a case, the Court cannot abdicate its responsibility to determine whether filings should be made available to the public, applying the test articulated in United States v. Hubbard, 650 F.2d 293 (D.C. Cir. 1980). Before moving to file under seal materials subject to a protective order, the moving party must confer with the opposing party and provide the results of that conferral process in the motion to
Redacted version required when filing motion to seal; must notify court if all portions must remain sealed.
A party must submit a redacted version, suitable for filing on the public docket, of any document that it proposes to seal at the same time the party files a motion to seal. If a party believes that all portions of a sealed document must remain sealed, the party must specifically notify the Court of that belief at the time of filing the motion to seal.
Parties cannot rely solely on a protective order to seal; must confer with opposing party and provide conferral results and Hubbard analysis in the motion to seal.
Parties may not rely solely on designation under a protective order to file documents under seal. Even when a protective order has been issued in a case, the Court cannot abdicate its responsibility to determine whether filings should be made available to the public, applying the test articulated in United States v. Hubbard, 650 F.2d 293 (D.C. Cir. 1980). Before moving to file under seal materials subject to a protective order, the moving party must confer with the opposing party and provide the results of that conferral process in the motion to seal, as well as analysis of the relevant Hubbard factors warranting sealing, to ensure that any requested sealing is appropriate under Hubbard.
Page 2 | 4. SEALED SUBMISSIONS
Juror names and personal information must be kept confidential and not disclosed outside open court.
The names and personal information of prospective and sitting jurors in any trial of this matter shall be kept confidential and not disclosed outside of open court, except upon order of the Court.
Page 7 | TRIAL PROCEDURES
Filing Bundling Requirements
Pending motions must be refiled within 7 days of transfer or deemed withdrawn.
Any motion pending in the court from which the case is removed at the time of removal must be refiled in this Court by the party seeking relief. See FED. R. CIV. P. 81(c)(2). Motions that are not refiled will be deemed withdrawn and not considered.
Pre-Motion Conference Requirements
Pre-motion conference required for dispositive motions; 4-page notice and 1-week response required.
f. Pre-Motion Conference. If a party wishes to file a dispositive motion, it must request that the Court schedule a pre-motion conference. To so request, the moving party shall submit a short notice via ECF, not to exceed four double-spaced pages in length, setting forth the basis for the anticipated motion, including the legal standards and the claims at issue. Other parties shall respond by filing, within one week, a document of similar length setting forth their anticipated responses to the proposed motion. The Court will review and discuss with counsel the anticipated motion at the pre-motion conference, which will take place in-person unless the Court grants permission to hold the conference by video. The parties should contact Judge Reyes’ Courtroom Deputy to schedule the conference for a date 1-2 weeks after the response is filed. This requirement shall not apply to incarcerated pro se litigants or immigration mandamus cases.
Motions in limine must be fully briefed with specific timing: 21 days before JPTS for motion, 14 days for opposition, 7 days for reply.
Motions in limine shall be fully briefed at the time of filing of the parties’ Joint Pretrial Statement. Accordingly, the moving party’s motion in limine and supporting memorandum shall be filed and served upon the opposing party at least 21 days before the Joint Pretrial Statement is due. The opposition shall be filed and served upon the moving party within 14 days of service of the motion in limine. Any reply shall be due within 7 days of service of the opposition.
Separate numbered motions in limine required for each discrete issue; omnibus motions not accepted.
The Court does not accept omnibus motions in limine. Parties should file separate motions in limine for each discrete issue. The motions should be numbered in sequential order.
Sur-replies require leave of court with good cause; motion for leave cannot include the sur-reply itself.
c. Sur-Replies. A party may not file a sur-reply without first obtaining leave of the Court and may do so only upon a specific showing of good cause. Any motion for leave to file a sur-reply shall not be accompanied by a copy of the sur-reply that the party wishes to file.
Leave of Court required before filing discovery dispute motions.
Before filing a motion relating to a discovery dispute, a party must obtain leave of the Court. Failure to comply with this requirement may result in any such motion being stricken.
Non-dispositive motions require conference with opposing counsel and certificate of conference with at least two personal communications.
Local Civil Rule 7(m), which requires counsel to confer before filing a non-dispositive motion and to include in the motion confirmation that such conferral occurred and a statement whether the motion is opposed, will be strictly enforced. See LCvR 7(m). The Court expects counsel to exhaust efforts to confer before bringing before it any such dispute. An adequate certificate of conference almost always requires at least two personal communications between counsel. Un-responded to emails are not enough to satisfy counsel’s obligations under this Rule. Failure to comply fully with Local Civil Rule 7(m) when filing a non-dispositive motion will result in the motion being stricken and may also result in further sanctions.
Discovery disputes must be resolved informally first, then email Court for teleconference with specific content requirements.
Before bringing a discovery dispute to the Court’s attention, the parties must confer in good faith in an attempt to resolve the dispute informally. If unable to resolve the dispute informally, the parties shall jointly prepare a short email to send to the Court, at Reyes_Chambers@dcd.uscourts.gov, requesting a teleconference with the Court and including a clear, concise description of the issues in dispute, an explanation of the parties’ positions with citations, and responses to opposing arguments.
Initial Scheduling Conference required after answer in cases under FRCP 26(f).
After an answer is filed, for those cases covered by Federal Rule of Civil Procedure 26(f) and Local Civil Rule 16.3, the Court will set an Initial Scheduling Conference and order the parties to meet and confer to discuss the matters set forth in Local Civil Rule 16.3(c), and to jointly file a report addressing them.
Opposition to motions in limine due within 7 days; reply due within 2 days.
Any opposition to a motion in limine shall be filed within 7 days of service of the motion in limine. Any reply shall be due within 2 days of service of the opposition.
Page 7 | Motions in Limine
Parties must meet and confer in person before bringing any dispute; first- or second-chair attorney must review and approve.
Parties are required to meet and confer on any dispute brought to the Court. At least one such meeting must occur in person. The first- or second-chair attorney for each party must personally review and approve any dispute before it is brought to the Court.
Page 7 | Motions in Limine
Oral argument on motions in limine, if needed, will be held at the Pretrial Conference.
Oral argument on motions in limine, if necessary, shall occur at the Pretrial Conference.
Page 7 | Motions in Limine
Adjournment & Extension Requirements
Extension/continuance motions must be filed 4+ days prior with specific required content.
When good cause is shown, the Court will consider a motion for time extension or continuance of a proceeding that is filed at least 4 days prior to the deadline and states: i. the original date of the deadline the motion is seeking to extend or the date of the scheduled hearing the motion is seeking to continue; ii. the number of previous extensions of time or continuances granted to each party; iii. the good cause supporting the motion; iv. the effect, if any, that the granting of the motion will have on existing deadlines; v. for motions, suggested deadlines (reached in consultation with the opposing party) for the filing of any opposition and reply papers; for continuances, three alternative dates and times that are convenient to all parties; and vi. the opposing party’s position on the motion, including any reasons given for refusing to consent, see LCvR 7(m).
Page 13 | Motions for Extension of Time or Rescheduling Hearing
Opposition to extension/continuance must be filed by 5 PM next business day or motion is deemed conceded.
A party opposing a motion for an extension of time or continuance of a scheduled hearing date must file, by 5:00 PM of the business day after the motion is filed, the party’s reasons for opposing the motion. If no such explanation is provided to the Court within this time frame, the motion shall be deemed conceded. Informing the opposing party that the motion for an extension or continuance is opposed does not constitute an explanation to the Court.
Page 14 | Opposition
Extension/continuance motions must be filed at least 4 business days before the deadline/hearing and include specific content: original date, prior extensions, good cause, effect on deadlines, suggested deadlines or alternative dates, and opposing party's position.
When good cause is present, the Court will consider a motion for an extension of time that is filed at least 4 business days prior to the deadline the motion is seeking to extend or the scheduled hearing date; and states: i. The original date of the deadline the motion is seeking to extend or the scheduled hearing date; ii. The number of previous extensions of time or continuances granted to each party; iii. The good cause supporting the motion; iv. The effect that the granting of the motion will have on existing deadlines; v. For motions, suggested deadlines (reached in consultation with the opposing party) for the filing of any opposition and reply papers; for continuances, three alternative dates and times that are convenient to all parties; and vi. The opposing party's position on the motion, including any reasons given for refusing to consent.
Page 3 | 7. MOTIONS FOR EXTENSION OF TIME OR RESCHEDULING HEARING
Extensions require motion, not stipulation; strongly discouraged.
Extensions or enlargements of time will be granted only upon motion, and not upon stipulation by the parties. Motions for extensions of time or for continuances of court proceedings are strongly discouraged. Counsel and parties should work within the time frames set by the Scheduling Order.
Page 13 | Motions for Extension of Time or Rescheduling Hearing
The 4-business-day notice requirement may be waived in emergencies, but a written motion is still required.
In the event of an emergency, the four-day rule may be waived, but counsel must still file a motion in writing.
Page 3 | 7. MOTIONS FOR EXTENSION OF TIME OR RESCHEDULING HEARING
Motions for extensions or continuances are strongly disfavored; counsel should not assume approval even if joint.
Motions for extensions of time or for continuances of Court proceedings are strongly disfavored. Counsel should not assume that the Court will approve an extension, even if jointly made.
Page 3 | 7. MOTIONS FOR EXTENSION OF TIME OR RESCHEDULING HEARING
Chambers Communication Rules
Parties generally may not call chambers; emergencies require a joint telephone conference call; chambers provides no legal advice.
Except as authorized in this order, the parties may not contact chambers by telephone. If extraordinary circumstances or emergencies require it, however, counsel should contact chambers jointly via telephone conference call to avoid ex parte communications. Chambers will not provide legal advice of any kind.
Page 1 | 1. COMMUNICATIONS WITH CHAMBERS
Telephone contact with Chambers generally prohibited except for emergencies.
Except as authorized in this Order, the parties may not contact Chambers by telephone. If extraordinary circumstances or emergencies so require, however, counsel may contact Chambers jointly via telephone conference. Chambers will not provide legal advice of any kind.
Counsel must notify the Courtroom Deputy at least 5 days in advance if interpretive services are needed.
Counsel shall notify the Courtroom Deputy, Chashawn White (Chashawn_White@dcd.uscourts.gov), at least five days in advance of any status conference, motions hearing, plea or trial if the defendant or any witness will require interpretative services provided by the Court.
Page 2 | 3. INTERPRETIVE SERVICES
Court may reference Red Sox history during oral argument; Game 6 of 1986 World Series is prohibited.
The Court understands that, for reasons passing understanding, not all counsel are fans of the Boston Red Sox. Counsel should be aware, however, that the Court may reference key moments in Red Sox history during oral argument. References may include: (a) Dave Roberts’s steal; (b) Carlton Fisk’s walk-off homerun; (c) Ted Williams’s final at-bat; 3 and, inter alia, (d) David Ortiz’s “this is our [bleep] city” speech. Any reference to Game 6 of the 1986 World Series is strictly prohibited.
Counsel may share preferred pronouns with Courtroom Deputy upon arrival.
Upon arrival to the courtroom, counsel may share their preferred pronouns with the Courtroom Deputy.
Submit Joint Pretrial Statement by email to Reyes_Chambers@dcd.uscourts.gov.
The parties shall also submit an electronic copy of the Joint Pretrial Statement in Microsoft Word format, including attachments and exhibits thereto, by email to Reyes_Chambers@dcd.uscourts.gov.
Page 5 | JOINT PRETRIAL STATEMENT
Junior Lawyer Participation Incentives
Junior attorneys (under 7 years) may increase likelihood of oral argument if they played substantial role in filing/witness preparation.
The Court encourages the participation of less experienced attorneys in all proceedings—including pretrial conferences, hearings on discovery disputes, oral arguments, and examinations of witnesses at trial—particularly where that attorney played a substantial role in drafting the underlying filing or in preparing the relevant witness. The Court will be more likely to grant a request for oral argument if doing so would afford the opportunity for a junior attorney to gain courtroom experience.