District of Columbia Document Filing Requirements

Defendant must refile pre-removal answer and distribute Standing Order.

Source text: 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.

One 3-ring binder of key cases (tabbed, alphabetical, indexed) required.

Source text: 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.

Exhibits over 1 require index; must be edited to exclude irrelevant material.

Source text: 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.

Each attachment must be separate PDF, properly labeled in ECF.

Source text: 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.

Proposed orders required for relief requests; must be filed as PDF and emailed as Word doc with specific subject line format.

Source text: 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.

Amended pleadings must include redline comparison with original.

Source text: Any amended pleading shall be accompanied by a redline comparison between the original and the amended or proposed amended pleading.

Court strictly enforces LCvR 7(h) for summary judgment motions; facts not controverted are deemed admitted.

Source text: 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).

Summary judgment motions require Statement of Material Facts Not in Dispute formatted as two-column table.

Source text: 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

Pro se parties must file in paper form; counsel must serve pro se parties in paper form.

Source text: 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.

Non-ultimate relief requests must be in separate motions with supporting law and facts.

Source text: 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).

Joint Pretrial Statement must be filed at least 14 days before final pretrial conference.

Source text: 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).

Exhibit list must have 6 columns with specific headings for trial exhibits.

Source text: 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;

Deposition objections must be in 8-column chart format with specific headings.

Source text: 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”;

Damages must be itemized with each element and monetary amount.

Source text: 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;

Description of other relief sought must be included.

Source text: a description of other relief sought by each party;

Stipulations on authenticity, admissibility, or undisputed facts must be included.

Source text: stipulations concerning authenticity of documents, admissibility of exhibits or testimony, or undisputed facts;

Description of demonstrative, physical, and videotape evidence must be included.

Source text: a description of each specific item of demonstrative evidence, physical evidence, or videotape evidence that will be offered at trial and any objections;

List of pending motions in limine must be included.

Source text: 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.

Proposed voir dire questions must indicate questions parties agree on.

Source text: proposed voir dire questions that indicate: I. the voir dire questions on which the parties agree; and

Juror names and personal information must be kept confidential and not disclosed outside of open court except by court order.

Source text: 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.

Each attachment must be separate PDF and properly labeled in ECF.

Source text: 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.

Joint Pretrial Statement must be filed 10 business days before pretrial conference.

Source text: In order “to provide a fair and expeditious trial,” FED. R. CRIM. P. 17.1, a pretrial conference will be scheduled at least two weeks before the date set for trial. 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.

Electronic copy of Joint Pretrial Statement must be emailed to chambers.

Source text: 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.

First or second-chair attorney must personally review and approve disputes.

Source text: The first- or second-chair attorney for each party must personally review and approve any dispute before it is brought to the Court.

Juror names and personal information must be kept confidential outside of open court.

Source text: 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.

Witness lists must be submitted with sentencing memoranda identifying relationship and testimony matter.

Source text: In addition, a party wishing to present witnesses at the sentencing hearing must submit with the memorandum, a witness list that identifies the relationship, matter of the testimony.

Letters for sentencing consideration must be attached to sentencing memorandum, not sent to chambers.

Source text: 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.

Parties must keep contact information current on docket and file notice of changes; failure may result in dismissal.

Source text: All counsel shall ensure that their phone number, current mailing address, and email address are correctly listed on the Court’s docket. Pro se parties shall ensure that their phone number, current mailing address, and email address are correctly listed on the Court’s docket. Any counsel or pro se party whose contact information changes while this case is pending should immediately file a notice with their updated information. If the Court is unable to contact counsel or a pro se party due to a failure to comply with this requirement, the Court may dismiss the action for failure to prosecute or take other appropriate action.

Plaintiffs must serve complaint per FRCP 4, file proof of service per LCR 5.3, and distribute Standing Order; IFP plaintiffs have court-assisted service.

Source text: The plaintiff(s) must promptly serve the complaint on the defendant(s), in accordance with Federal Rule of Civil Procedure 4; file proof of service, in accordance with Local Civil Rule 5.3; and ensure that all parties receive a copy of this Standing Order. For in forma pauperis plaintiffs, “officers of the [C]ourt” will ensure that service on the defendant(s) is properly effected. See 28 U.S.C. § 1915(d).

Corporations must file disclosure certificate listing parent/subsidiary/affiliate with public securities or 10%+ ownership at first pleading and update changes.

Source text: To facilitate the Court’s determination of the need for recusal, in all civil or agency actions where a corporation is a party or intervenor, counsel of record for that party or intervenor shall file, in accordance with Federal Rule of Civil Procedure 7.1 and Local Civil Rules 7.1 and 26.1, a certificate listing for that party or intervenor any parent corporation, subsidiary or affiliate, which to the knowledge of counsel has any outstanding securities in the hands of the public, or any publicly held corporation owning 10% or more of its stock. Such certificate shall be filed at the time of filing the party’s first pleading. Counsel shall have the continuing obligation to advise the Court of any change.

Settlement authority individuals must be present or available by phone for pretrial conference.

Source text: A Pretrial Conference will be held at [TIME] on [DATE], in Courtroom 9. Counsel are instructed that individuals with settlement authority must be present or available by telephone during the pretrial conference.

Parties must meet and confer before pretrial conference to prepare Joint Pretrial Statement and discuss settlement.

Source text: Prior to the pretrial conference the parties shall meet and confer for the purpose of preparing the Joint Pretrial Statement and discussing the prospects for settlement. To the extent possible, the parties shall conduct a face-to-face meeting. The parties are directed to confer in good faith and Counsel for Plaintiff shall file a Joint Pretrial Statement pursuant to Local Civil

Non-compliance with Pretrial Order may result in sanctions including fines, striking submissions, dismissal, or public admonishment.

Source text: Failure to comply with the requirements and deadlines established in this Pretrial Order may result in sanctions including, but not limited to, fines payable to the Clerk of the Court, a court order striking untimely or non-compliant pretrial submissions and pleadings, dismissal of claims/defenses, and/or public admonishment of counsel. See Fed. R. Civ. P. 16(f); Fed. R. Civ. P. 37(b)(2)(A)(ii)–(vii); Gregory P. Joseph, Sanctions: The Federal Law of Litigation Abuse 598 (5th ed. 2013) (“The primary purpose for imposing Rule 16(f) sanctions is deterrent: to insure expeditious and sound management of the preparation of cases for trial. Secondarily, sanctions are awarded to compensate parties for inconvenience and expense incurred because of an opponent's noncompliance.”).

Challenged exhibits must be produced with Joint Pretrial Statement in two copies.

Source text: If there are objections to an exhibit listed in the Joint Pretrial Statement, the exhibit shall be produced at the time the Joint Pretrial Statement is submitted. Two copies of the challenged exhibits shall be submitted to the court in separate three ring

Witnesses not listed in Joint Pretrial Statement cannot be called at trial (except for impeachment).

Source text: No party may call at trial any witness the party has not listed in the Joint Pretrial Statement (except those called for impeachment purposes).

Exhibits must be listed in Joint Pretrial Statement to be admitted at trial.

Source text: No exhibit will be admitted at trial unless it is listed on the Joint Pretrial Statement.

Parties offering >5 exhibits must pre-mark them with court-provided labels.

Source text: Each party that anticipates offering more than five (5) exhibits as substantive evidence shall pre-mark such exhibits in advance of trial, using exhibit labels and lists available from the Clerk of the Court. The court will provide up to 100 labels; if a party needs more labels, that party must use labels of the same type as those supplied by the court.

Deposition testimony must be identified by page/line numbers in JPTS.

Source text: Identify each deposition or portion thereof, by page and line numbers, that the party intends to offer in evidence. All cross-designations under Fed. R. Evid. 106 must be identified as well.

Objections to deposition testimony must be in JPTS with basis and authority.

Source text: Designated or cross-designated deposition testimony will be deemed potentially admissible at trial, unless an objection is made in the Joint Pretrial Statement. The objecting party must note the basis for the objection, as well as provide supporting authority.

Deposition objections must include excerpts from the deposition.

Source text: Any objections to deposition testimony shall be accompanied by excerpts from the depositions, including the testimony to which the objection relates.

Objections not in JPTS are waived except for Rules 402/403.

Source text: Objections not disclosed in the Joint Pretrial Statement, except those pursuant to Fed. R. Evid. 402 and 403, shall be deemed waived, unless such failure to timely object is excused by the court for good cause shown.

Demonstrative/physical/videotape evidence must be described in JPTS.

Source text: Describe all demonstrative, physical and/or videotape evidence that will be used at trial. Such evidence listed in the Joint Pretrial Statement shall be deemed potentially admissible at trial, unless an objection is made in the Joint Pretrial Statement, along with the specific basis for the objection and supporting legal authority.

JPTS must separately list each damage element and monetary amount.

Source text: Set forth separately each element of damages and the monetary amount claimed (including prejudgment interest, punitive damages, and attorney’s fees). Do not include amounts claimed for intangible damages. Set forth all other types of relief sought against any party.

Jury trial waiver required in jury cases

Source text: In jury cases, the parties also must submit (a) Any waiver of a jury trial;

Voir dire objections and proposals required with supporting authority

Source text: In jury cases, the parties also must submit (b) Any objections or proposed additions to Judge Chutkan’s standard voir dire, including i. the voir dire questions on which the parties agree; and ii. the voir dire questions on which the parties disagree, with specific objections noted below each disputed question and supporting legal authority (if any);

Proposed jury instructions with citations and formatting required

Source text: In jury cases, the parties also must submit (c) A list of proposed jury instructions, followed by the text of each proposed instruction, as well as the specific source and citation for the proposed instructions (e.g., Standardized Civil Jury Instruction for the District of Columbia 2.01: Evidence in the Case) or, for modified or new instructions, specific supporting legal authority. Any variations or alterations of standard jury instructions shall be so noted and the proposed instructions shall be formatted so that each individual instruction begins a new page. Additionally, the parties shall indicate i. the instructions on which the parties agree; and ii. the instructions on which the parties disagree, with specific objections noted below each disputed instruction and supporting legal authority (if any);

Proposed verdict form with signature line required in jury cases

Source text: In jury cases, the parties also must submit (d) a proposed verdict form, as well as proposed special interrogatories (if any), that includes a date and signature line for the jury foreperson.

Objections must specify objectionable portions with legal authority and proposed alternatives

Source text: Any objections shall be listed immediately following the voir dire question, jury instruction, or verdict question. The objecting party shall specifically identify the objectionable portion of the voir dire question, instruction, or verdict form, along with the basis of the objection and citations to supporting legal authority. Any objections to the verdict form shall be accompanied by a proposed alternative form.

Detailed proposed findings of fact and conclusions of law required in non-jury cases

Source text: In non-jury cases, the parties must submit detailed proposed findings of fact and conclusions of law with supporting authorities.

Estimated trial length and witness scheduling problems must be listed

Source text: List the number of days estimated for trial, and set forth any scheduling problems with witnesses.

Joint Pretrial Statement must include list of parties and counsel with contact information and lead counsel names.

Source text: In accordance with Local Civil Rule 16.5(b), the Joint Pretrial Statement must include the following: 1. Parties and Counsel: List names, addresses, and telephone numbers of all counsel on whose behalf the Joint Pretrial Statement is filed. In addition, provide the names of lead counsel who intend to try the case. List names and addresses of all parties.

Parties cannot call witnesses at trial unless they were listed in the Joint Pretrial Statement, with impeachment witnesses being the only exception.

Source text: No party may call at trial any witness the party has not listed in the Joint Pretrial Statement (except those called for impeachment purposes).

Jury cases require submission of jury trial waiver, voir dire objections/additions, proposed jury instructions with citations, and proposed verdict form.

Source text: In jury cases, the parties also must submit (a) Any waiver of a jury trial; (b) Any objections or proposed additions to Judge Chutkan's standard voir dire... (c) A list of proposed jury instructions... (d) a proposed verdict form

Non-jury cases require submission of detailed proposed findings of fact and conclusions of law with supporting authorities.

Source text: In non-jury cases, the parties must submit detailed proposed findings of fact and conclusions of law with supporting authorities.

Amended pleadings must include redline comparison showing changes

Source text: Any amended or proposed amended pleadings shall be accompanied by a redline comparison of the original and amended or proposed pleading.

Pro hac vice motions must comply with Local Civil Rule 83.2(d) requirements.

Source text: All motions for admission pro hac vice shall comply with the requirements of Local Civil Rule 83.2(d). The Court may deny any such motion that fails to provide all required information.

Extension motions must include 7 specific elements including original date, requested time, previous extensions, good cause, impact on other deadlines, proposed schedule, and opposition statement.

Source text: Motions for extension of time shall include the following: (1) the original date of the deadline the motion is seeking to extend; (2) the time requested for the extension; (3) the number of previous extensions, if any, granted to each party; (4) good cause supporting the extension; (5) the effect, if any, that the granting of the extension will have on other previously-set deadlines; (6) a proposed schedule for any other affected deadlines, to be proposed only after consulting with opposing counsel; and (7) a statement of whether opposing counsel opposes the motion in accordance with Local Civil Rule 7(m).

Non-dispositive motions must comply with Local Civil Rule 7(m) and include required statement.

Source text: All non-dispositive motions shall comply with Local Civil Rule 7(m), which applies to all non-incarcerated parties. The Court may deny any non-dispositive motion that fails to include the required statement.

Protective order motions must include proposed order attachment and explain good cause.

Source text: All motions for protective order shall: (1) include as an attachment the proposed order, and (2) explain why good cause exists to enter the proposed order, see Fed R. Civ. P. 26(c); Klayman v. Judicial Watch, Inc., 247 F.R.D. 19, 22–23 (D.D.C. 2007).

Seal motions must explain justification under Hubbard factors, propose redactions, and include each document as separate exhibit.

Source text: Any motion for leave to file under seal shall: (1) explain why sealing specific information is justified in light of the factors set forth in United States v. Hubbard, 650 F.2d 293 (D.C. Cir. 1980); (2) propose redactions or explain why redactions are sufficiently impracticable to outweigh the presumption of public access; and (3) include as a separate exhibit each document sought to be sealed.

Summary judgment motions must include statement of material facts with specific record citations under Local Civil Rule 7(h)(1).

Source text: For those cases covered by Local Civil Rule 7(h)(1), each party submitting a motion for summary judgment shall comply with it by submitting a statement of material facts for which that party contends there is no genuine dispute, with specific citations to those portions of the record upon which the party relies in fashioning the statement.

Opposition to summary judgment must include statement of genuinely disputed material facts.

Source text: The party opposing the motion shall, in turn, submit a statement enumerating all material facts which the party contends are genuinely disputed and thus require trial.

Court strictly enforces Local Civil Rule 7(h)(1); facts in moving party's statement are admitted unless controverted in opposition.

Source text: The Court strictly enforces Local Civil Rule 7(h)(1) 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)(1); see also Fed. R. Civ. P. 56(e).

Moving party must file 2-column table of undisputed facts for summary judgment

Source text: The moving party shall, in accordance with Local Civil Rule 7(h)(1), file a short and concise statement of material facts for which it contends there is no genuine dispute. This document shall be formatted as a two-column table entitled “Statement of Material Facts Not in Dispute.”

Opposing party must file 2-column table of disputed facts for summary judgment

Source text: The party opposing summary judgment shall, in accordance with Local Civil Rule 7(h)(1), file a statement setting forth all material facts that the party contends are genuinely disputed and thus require trial. This document shall be formatted as a two-column table entitled “Counter-Statement of Disputed Facts.”

Counsel must promptly advise court when case settles in whole or in part

Source text: If the case settles in whole or in part, counsel shall promptly advise the Court.

Moving party must file 2-column reply table for disputed facts in summary judgment

Source text: The moving party shall file a statement responding to any additional facts that the party opposing summary judgment has identified. This document shall be formatted as a two-column table entitled “Reply to Counter-Statement of Disputed Facts.”

Moving party must provide editable electronic copy of undisputed facts to opposing party

Source text: Following the filing of this document, the moving party shall promptly provide an electronic copy in editable format to the opposing party.

Opposing party must provide editable electronic copy of disputed facts to moving party

Source text: Following the filing of this document, the opposing party shall promptly provide an electronic copy in editable format to the moving party.

Discovery disputes must be resolved through good faith conference before filing motion

Source text: The parties are expected to fully comply with Local Civil Rule 26.2. Moreover, counsel are required, under both Federal Rule of Civil Procedure 26(f) and Local Civil Rule 7(m), to confer in good faith in an effort to resolve any discovery dispute before bringing it to the Court’s attention.

Discovery motions require prior consultation with opposing counsel and leave of court

Source text: The parties shall not file a discovery motion without prior consultation with opposing counsel, and without leave of Court.

Amended pleadings must include a redline comparison showing changes from the original.

Source text: Any amended or proposed amended pleadings shall be accompanied by a redline comparison of the original and amended or proposed pleading.

Plaintiff must file proof of service with the Court per Local Civil Rule 5.3.

Source text: Plaintiff shall promptly serve the Complaint in accordance with Federal Rule of Civil Procedure 4; shall file the proof of service with the Court, in accordance with Local Civil Rule 5.3; and shall ensure that all parties receive a copy of this Standing Order.

Extension motions must include seven specific elements including original deadline, time requested, prior extensions, good cause, and consulting opposing counsel.

Source text: Motions for extension of time shall include the following: (1) the original date of the deadline the motion is seeking to extend; (2) the time requested for the extension; (3) the number of previous extensions, if any, granted to each party; (4) good cause supporting the extension; (5) the effect, if any, that the granting of the extension will have on other previously-set deadlines; (6) a proposed schedule for any other affected deadlines, to be proposed only after consulting with opposing counsel; and (7) a statement of whether opposing counsel opposes the motion in accordance with Local Civil Rule 7(m).

Non-dispositive motions must comply with Local Civil Rule 7(m) and include required statement or face denial.

Source text: All non-dispositive motions shall comply with Local Civil Rule 7(m), which applies to all non-incarcerated parties. The Court may deny any non-dispositive motion that fails to include the required statement.

Pro hac vice motions must comply with Local Civil Rule 83.2(d) or face denial.

Source text: All motions for admission pro hac vice shall comply with the requirements of Local Civil Rule 83.2(d). The Court may deny any such motion that fails to provide all required information.

Motions for protective order must attach proposed order and explain good cause under Fed R. Civ. P. 26(c).

Source text: All motions for protective order shall: (1) include as an attachment the proposed order, and (2) explain why good cause exists to enter the proposed order, see Fed R. Civ. P. 26(c); Klayman v. Judicial Watch, Inc., 247 F.R.D. 19, 22–23 (D.D.C. 2007).

Summary judgment motions require statement of material facts with specific record citations per Local Civil Rule 7(h)(1).

Source text: For those cases covered by Local Civil Rule 7(h)(1), each party submitting a motion for summary judgment shall comply with it by submitting a statement of material facts for which that party contends there is no genuine dispute, with specific citations to those portions of the record upon which the party relies in fashioning the statement.

Opposing party must submit statement enumerating all genuinely disputed material facts requiring trial.

Source text: The party opposing the motion shall, in turn, submit a statement enumerating all material facts which the party contends are genuinely disputed and thus require trial.

Moving party must file LR 56.1 statement as two-column table with specific formatting and provide editable electronic copy to opponent.

Source text: The party moving for summary judgment shall, in accordance with Local Civil Rule 7(h)(1), file a short and concise statement of material facts for which it contends there is no genuine dispute. This document shall be formatted as a two-column table entitled "Statement of Material Facts Not in Dispute." In the left column, the moving party shall list in separately numbered rows concise statements of each material fact it contends is not in dispute, supported by citations to the record. The statement must contain only one undisputed factual assertion per numbered row. Following the filing of this document, the moving party shall promptly provide an electronic copy in editable format to the opposing party.

Opposing party must file counter-statement as two-column table with specific admission/denial format and citations, plus provide editable electronic copy to movant.

Source text: The party opposing summary judgment shall, in accordance with Local Civil Rule 7(h)(1), file a statement setting forth all material facts that the party contends are genuinely disputed and thus require trial. This document shall be formatted as a two-column table entitled "Counter-Statement of Disputed Facts." In the left column, the opposing party shall include the list of material facts that the movant contends are not in dispute, with the movant's citations to the record. In the right column, the opposing party shall indicate whether each corresponding fact in the left column is admitted or denied, and for those denied, provide specific citations to the record. If the fact is admitted in part and denied in part, the opposing party shall specifically identify which parts are admitted and which are denied, with appropriate citations to the record. The opposing party shall also include any information relevant to its response in the right column, again, with specific citations to the record. If the opposing party has additional facts that do not directly correspond to its response to a specific paragraph, it must identify such facts in consecutively numbered rows in the right-hand column at the end of its responsive statement of facts. Following the filing of this document, the opposing party shall promptly provide an electronic copy in editable format to the moving party.

Moving party's reply to counter-statement must be formatted as two-column table with citations.

Source text: The moving party shall file a statement responding to any additional facts that the party opposing summary judgment has identified. This document shall be formatted as a two-column table entitled "Reply to Counter-Statement of Disputed Facts." In the corresponding spaces in the left column, the moving party shall respond to the opposing party's additional facts with appropriate citations to the record.

Amended submissions must include a redline comparing the original and amended pleading.

Source text: Any amended submissions shall be accompanied by a redline comparison of the original and amended pleading.

Parties must submit a Rule 16.3 report and proposed scheduling order by the stated deadlines unless the Court orders otherwise.

Source text: Unless otherwise ordered by the Court, by no later than 30 days after any defendant has filed an answer, or by no later than 14 days after the Court resolves any motion brought pursuant to Federal Rule of Civil Procedure 12(b), the parties shall submit to the Court a report and a proposed scheduling order as required by Local Civil Rule 16.3.

The Rule 16.3 report must include a brief statement of the case.

Source text: In addition to reporting on the matters required by Local Civil Rule 16.3, counsel shall include in their report a brief statement of the case.

Submissions with more than one exhibit must include an exhibit index.

Source text: Every submission that attaches more than one exhibit shall contain an index of exhibits.

A summary judgment movant must file a separate Statement of Material Facts Not in Dispute.

Source text: Pursuant to Local Civil Rule 7(h)(1), the moving party shall include a separate document entitled Statement of Material Facts Not in Dispute.

The moving party must present each claimed undisputed material fact in separately numbered left-column rows with record citations.

Source text: In the left column, the moving party shall list in separately numbered rows concise statements of each material fact it contends is not in dispute, supported by appropriate citations to the record.

The opposing party must file a separate Counter-Statement of Disputed Facts.

Source text: In response, the opposing party shall file a separate document entitled Counter-Statement of Disputed Facts.

When partially admitting and partially denying a fact, the opposing party must identify admitted and denied portions with record citations.

Source text: If the fact is admitted in part and denied in part, the opposing party shall specifically identify which parts are admitted and which are denied, with appropriate citations to the record.

The counter-statement must end with a list of material facts that the opposing party contends are genuinely disputed for trial.

Source text: At the end of the Counter-Statement of Disputed Facts, the opposing party shall list the material facts as to which the opposing party contends there is a genuine issue of material fact for trial.

The moving party must file a separate reply to the counter-statement with left-column responses and appropriate citations to additional facts.

Source text: In response, the moving party shall file a separate document entitled Reply to Counter-Statement of Disputed Facts, responding with appropriate citations in the left column to the additional facts.

Counsel and pro se litigants must comply with Local Civil Rules.

Source text: Counsel and pro se litigants are expected to comply with the Local Civil Rules of this Court.

Plaintiffs must serve Standing Order with Complaint or promptly after.

Source text: If this Standing Order is entered on the docket prior to the appearance of defendant(s), the plaintiff(s), except pro se parties, shall ensure that all other parties receive a copy of this Standing Order by serving it with the Complaint, or providing it promptly following service of the Complaint.

Removed actions require refiling answers and pending motions; parties must receive Standing Order.

Source text: A defendant removing an action to this Court must refile as a supplement to the petition any answer and must promptly ensure that all parties receive a copy of this Standing Order. Any pending motion at the time of removal must be refiled in this Court by the party seeking relief for the motion to be considered. See Fed. R. Civ. P. 81(c)(2).

Amended submissions must include redline comparison of original and amended pleading.

Source text: Any amended submissions shall be accompanied by a redline comparison of the original and amended pleading.

Plaintiffs must consider motion to dismiss arguments and amend complaints under Rule 15(a).

Source text: Plaintiffs are therefore DIRECTED to carefully consider arguments raised in a motion to dismiss and correct defects through an amended complaint as allowed under Rule 15(a).

Memoranda of 10+ pages must include table of contents and table of authorities.

Source text: Every memorandum of points and authorities that is ten pages or longer must contain a table of contents and table of authorities, regardless of

Moving party must file Statement of Material Facts Not in Dispute as two-column table.

Source text: 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.

Each row in Statement of Material Facts must contain one undisputed fact with record citation.

Source text: In the left column, the moving party shall list in separately numbered rows concise statements of each material fact it contends is not in dispute, supported by appropriate citations to the record. The statement must contain only one undisputed factual assertion per numbered row.

Opposing party must file Counter-Statement of Disputed Facts.

Source text: the opposing party shall file a separate document entitled Counter-Statement of Disputed Facts.

Moving party must file Reply to Counter-Statement of Disputed Facts with citations.

Source text: the moving party shall file a separate document entitled Reply to Counter-Statement of Disputed Facts, responding with appropriate citations in the left column to the additional facts.

The government must produce discoverable evidence in a readily usable form.

Source text: The government is further directed to produce all discoverable evidence in a readily usable form.

Document production must either follow usual business order or be clearly organized and labeled.

Source text: For example, the government must produce documents as they are kept in the usual course of business or must organize and label them clearly.

Electronically stored information must be produced in its ordinary form unless that form is not readily usable, then in a readily usable form.

Source text: The government must also produce electronically-stored information in a form in which it is ordinarily maintained unless the form is not readily usable, in which case the government is directed to produce it in a readily-usable form.

Information already memorialized in a tangible format must be produced in that same format.

Source text: If the information already exists or was memorialized in a tangible format, such as a document or recording, the information shall be produced in that format.

Any summary-format production must be detailed and specific enough for the defense to assess relevance and usefulness.

Source text: a summary format, the summary must include sufficient detail and specificity to enable the defense to assess its relevance and potential usefulness.

Government must make good-faith efforts to disclose Brady material from arraignment through criminal proceeding

Source text: Beginning at the defendant’s arraignment and continuing throughout the criminal proceeding, the government shall make good-faith efforts to disclose such information to the defense as soon as reasonably

Government must produce exculpatory evidence during plea negotiations

Source text: This government responsibility includes producing, during plea negotiations, any exculpatory evidence in the government’s possession.

Government must resolve doubts in favor of full disclosure of evidence

Source text: Where doubt exists as to the usefulness of the evidence to the defendant, the government must resolve all such doubts in favor of full disclosure.

Failure to timely produce Brady information may constitute prejudice

Source text: Even if ultimately disclosed, a failure to timely produce Brady information may constitute prejudice if the accused suffers from the delay.

Government must produce discoverable evidence in readily usable form, maintaining original format when possible.

Source text: The government is further directed to produce all discoverable evidence in a readily usable form. For example, the government must produce documents as they are kept in the usual course of business or must organize and label them clearly. The government must also produce electronically-stored information in a form in which it is ordinarily maintained unless the form is not readily usable, in which case the government is directed to produce it in a readily-usable form. If the information already exists or was memorialized in a tangible format, such as a document or recording, the information shall be produced in that format.

Joint Report must include certification that counsel discussed Local Civil Rule 16.3(c) topics in good faith.

Source text: 13. a certification from counsel that they have discussed, in good-faith, every topic listed in Local Civil Rule 16.3(c) and this Order.

3 days before guilty plea hearing, submit plea agreement, elements, factual proffer, penalty consequences, aggravated felony notice, and superseding indictment if applicable.

Source text: At least three (3) days in advance of the hearing, counsel shall submit to the Court the following documents: (a) the written plea agreement; (b) the elements for each offense to which a guilty plea will be entered; (c) the factual proffer regarding the charged conduct the defendant is prepared to acknowledge; (d) a statement of all potential penalty consequences of the guilty plea; (e) written notice as to whether the defendant will be pleading guilty to an “aggravated felony” as defined by 8 U.S.C. § 1101(a)(43), which would subject the defendant to mandatory deportation and other potential consequences, if the defendant is not a United States citizen, and (f) any superseding indictment or new information, if applicable.

Brady Material known at indictment must be disclosed to defense within 2 weeks of indictment filing.

Source text: Brady Material known to the Government at the time of indictment—other than purely impeachment materials and information required to be produced pursuant to Giglio v. United States and its progeny (“Giglio Material”)—must be produced to defense counsel no later than two weeks following the date of the filing of the indictment, regardless of whether the parties are engaged in plea discussions.

Brady Material discovered after indictment must be disclosed within 2 weeks or 4 weeks before trial/plea.

Source text: Brady Material (other than Giglio Material) that becomes known to the Government following filing of the indictment must be disclosed, absent exceptional circumstances, within two weeks of when it becomes known and, in any event, no later than four weeks prior to any trial or guilty plea.

Giglio Material must be disclosed 4 weeks before trial start date.

Source text: Absent exceptional circumstances, Giglio Material must be disclosed four weeks prior to the date of the start of trial.

Giglio Material discovered less than 4 weeks before trial must be disclosed immediately.

Source text: Giglio material developed less than four weeks before trial (e.g., as a result of further interviews of witnesses) must be disclosed immediately.

Government must continuously seek Brady and Giglio Material from all relevant agencies.

Source text: To achieve adequate compliance with the foregoing rules, the Government has a continuing obligation to seek Brady Material and Giglio Material from law enforcement and regulatory agencies that are or have been involved in the prosecution of the defendant or in parallel proceedings or investigations involving the defendant.

Counsel must refrain from releasing information about pending criminal matters per Local Criminal Rule 57.7(b)(1).

Source text: In accordance with Local Criminal Rule 57.7(b)(1), counsel must refrain from releasing or authorizing the release of information or opinions regarding criminal matters pending before

Requests for additional preliminary instructions must be submitted in writing at least 5 days before trial.

Source text: If counsel desire that any additional preliminary instructions be given, they should make that request in writing at least five (5) days before the trial is scheduled to commence.

Counsel must object to improper statements during opening statements.

Source text: Counsel are expected to object if improper statements are made by opposing counsel during opening statements.

No personal opinions or attacks on opposing counsel in opening/closing arguments.

Source text: Counsel are reminded that the Court will enforce the traditional rules regarding opening statements and closing arguments, e.g., no personal opinions and no personal attacks on opposing counsel.

All objections and statements by counsel must be made while standing.

Source text: All objections or other statements by counsel shall be made while standing.

Motions in limine must follow case orders; decided on papers or after hearing as Court determines.

Source text: The parties are expected to file any such motions in accordance with any order that is issued in the case. Such motions will be decided either on the papers, when possible, or after a hearing, if the Court decides that a hearing is necessary.

Counsel must file motions in limine for issues reasonably expected to be contested at trial.

Source text: Counsel for the parties shall file motions in limine regarding any issues that they reasonably expect will be contested at trial.

Objections must state only legal basis without elaboration

Source text: Counsel who lodge objections before a jury must state merely the legal basis for their objections, i.e., hearsay, relevancy, etc., without elaboration or argument, and the Court will rule on the objection without additional discussion whenever possible.

Exhibit lists with descriptions due 3 days before trial

Source text: Unless otherwise indicated by the Court, all of the parties' exhibits are to be marked numerically in advance of trial, and the written list of the exhibits along with a brief description of each exhibit must be submitted to the Court and opposing counsel at least three (3) days before the trial commences.

Voir dire questions must be submitted electronically in Microsoft Word at least 7 days before trial.

Source text: Proposed voir dire questions must be submitted to the Court at least seven (7) days before the scheduled trial date electronically in Microsoft Word.

Strikes for cause must be made immediately after individual questioning.

Source text: Strikes for cause will be entertained immediately after the individual questioning of each potential juror.

Government strikes first in first 6 rounds; defendant gets 2 strikes in rounds 1-4, 1 strike in rounds 5-6.

Source text: During the first six (6) rounds of peremptory strikes on the non-alternate jurors, the government on each round will exercise its strikes first, followed by the defendant who on rounds one through four will exercise two strikes, and on the last two rounds one strike.

Notice of need for interpretive services must be given at least 10 days before the court proceeding.

Source text: to notify her that the defendant and/or any witnesses will require interpretive services provided by the Court—this must be done at least ten (10) days in advance of the relevant court proceeding

Stipulations for extensions are not accepted; parties must file a motion even if consented.

Source text: The Court will not entertain stipulations concerning extensions of time. The parties must file a motion, whether consented to or not, when seeking an extension.

Counsel must submit 6 categories of documents at least 3 days before guilty plea hearings.

Source text: At least three (3) days in advance of the hearing, counsel shall submit to the Court the following documents: (a) the written plea agreement; (b) the elements for each offense to which a guilty plea will be entered; (c) the factual proffer regarding the charged conduct the defendant is prepared to acknowledge; (d) a statement of all potential penalty consequences of the guilty plea; (e) written notice as to whether the defendant will be pleading guilty to an "aggravated felony" as defined by 8 U.S.C. § 1101(a)(43), which would subject the defendant to mandatory deportation and other potential consequences, if the defendant is not a United States citizen, and (f) any superseding indictment or new information, if applicable.

Exhibit list with descriptions must be submitted at least 3 days before trial.

Source text: (l) Exhibit Lists: Unless otherwise indicated by the Court, all of the parties' exhibits are to be marked numerically in advance of trial, and the written list of the exhibits along with a brief description of each exhibit must be submitted to the Court and opposing counsel at least three (3) days before the trial commences.

Counsel must furnish current photographs of all trial witnesses prior to final jury instruction, reflecting their appearance at trial.

Source text: Prior to the final instruction of the jury, counsel for each party shall furnish to the Court current photographs of all witnesses called during the course of the trial. Government counsel shall be responsible for providing photographs of the witnesses called by the government, and defense counsel shall be responsible for providing photographs of the witnesses called by the defense. These photographs should reflect how the witness looked at the time he or she appeared at trial (e.g., current hairstyle, facial hair, etc.).

Proposed jury instructions must use most recent Criminal Jury Instructions for District of Columbia; alternative versions require Court notification in separate filing.

Source text: Proposed instructions submitted by counsel shall include the instructions contained in the most recent addition of the Criminal Jury Instructions for the District of Columbia. If any other version of the proposed instructions are submitted, counsel shall specifically advise the Court of this fact in a separate filing.

Sur-replies require leave of court.

Source text: Counsel may not file a sur-reply without first requesting leave of the Court.

All motions must include a proposed order.

Source text: All motions must be accompanied by a proposed order setting forth the relief or action sought with specificity. See LCvR 7(c).

Memos 10+ pages require Table of Contents and Table of Authorities.

Source text: Every memorandum of points and authorities that is ten (10) pages or more 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.

Submissions with multiple exhibits require index; exhibits must be edited.

Source text: 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 thereof.

Non-compliant motions or oppositions will be sua sponte denied.

Source text: Any motion or opposition that does not comply with Local Civil Rule 7, unless otherwise indicated below, will be sua sponte denied.

Motions must be filed rather than stipulations.

Source text: The Court requires that the parties file motions, whether consented to or not, rather than stipulations.

Counsel with settlement authority must appear at initial scheduling and final pre-trial conferences.

Source text: Counsel with settlement authority must appear at the initial scheduling conference and at the final pre-trial conference.

Joint report required within 14 days after meet-and-confer meeting.

Source text: counsel shall meet and confer and then submit their joint Report addressing all topics listed in Local Civil Rule 16.3(c) no later than fourteen (14) days following that meeting.

Exempt proceedings require joint statement within 14 days of all appearances.

Source text: If the proceeding is exempt under Rule 16.3(b), counsel for both parties shall jointly prepare and submit a statement to the Court, no later than fourteen (14) days after counsel for all parties have entered an appearance in the matter, indicating whether they believe the matter will be resolved solely through the filing of dispositive motions and proposing a scheduling timeline for the filing of such motions, as well as oppositions and replies.

Administrative record required within 30 days of joint statement for dispositive motions.

Source text: To the extent an administrative record is necessary for the resolution of any dispositive motion, the administrative record must be filed with the Court no later than thirty (30) days after the parties’ joint statement has been submitted to the Court.

Moving party's statement of material facts must be numbered paragraphs with one factual assertion each.

Source text: The moving party’s statement of material facts shall be a short and concise statement, in numbered paragraphs, of all material facts as to which the moving party claims there is no genuine dispute. The statement must contain only one factual assertion in each numbered paragraph.

Responding party must restate movant's facts and provide response after each numbered paragraph.

Source text: The party responding to a statement of material facts must (1) restate the movant’s statement of undisputed material fact in numbered paragraphs, and (2) immediately following each numbered paragraph state the opponent’s response to the stated fact.

Additional facts must be in consecutively numbered paragraphs at end; movant must respond with reply brief.

Source text: If the responding party has additional facts that are not directly relevant to its response to any specific paragraph, it must identify such facts in consecutively numbered paragraphs at the end of its responsive statement of facts. If such additional factual allegations are made, the movant must file a responsive statement of its own with its reply brief.

Movant must file responsive statement with reply brief or facts may be treated as conceded.

Source text: If the movant fails to include a responsive statement of facts with its reply brief, the Court may treat as conceded any such facts asserted in the movant’s statement of facts.

Parties must provide precise citations to record portions relied upon.

Source text: The parties must furnish precise citations to the portions of the record on which they rely; the Court need not consider materials not specifically identified. See Fed. R. Civ. P. 56(c)(1)(A), (c)(3).

Court will not entertain motions that reassert rejected arguments or raise new arguments for first time.

Source text: The Court will not entertain: (a) motions that simply reassert arguments previously raised and rejected by the Court; and (b) arguments that should have been previously raised, but are being raised for the first time in the motion for reconsideration.

Citations must follow Bluebook format with exact page references.

Source text: All citations must be in accordance with the most recent edition of The Bluebook: A Uniform System of Citation. All citations to case authority should include exact page references.

Parenthetical descriptions of case holdings must follow citations used in passing or as supplemental authority.

Source text: When case authority is cited in passing or as supplemental authority for a stated principle or rule, parenthetical descriptions of that case’s holding should immediately follow.

Online case authority must include Westlaw (preferred) or LexisNexis citation.

Source text: When case authority is accessible only through online resources, either the Westlaw (preferred) or the LexisNexis citation must be provided.

Motions for reconsideration are strongly discouraged and limited to new arguments.

Source text: 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.

Submissions with multiple exhibits require index and proper editing.

Source text: 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.

Losing party in discovery dispute may be ordered to pay costs and attorney's fees.

Source text: Counsel are hereby notified that a party who does not prevail in a discovery dispute may be ordered to pay the costs involved, including reasonable attorney's fees.

Special trial considerations including disability accommodations must be identified

Source text: The parties shall identify any special considerations for trial, such as accommodations for persons with disabilities, or any other pertinent matters about which the court should be aware.

In civil cases, parties must arrange and provide their own interpreters; the court does not supply them.

Source text: The parties are reminded that the Court does not provide interpreters in civil matters; the parties are to provide interpreters if needed.

When the standing order is docketed before defendants appear, plaintiffs must provide it with or promptly after service of the complaint.

Source text: If this Standing Order is entered on the docket prior to the appearance of defendant(s), the plaintiff(s), except parties receive a copy of this Standing Order by serving it with the Complaint, or providing it promptly following service of the Complaint.

Submissions with more than one exhibit require an index.

Source text: Every submission that attaches more than one exhibit shall contain an index of exhibits.

Moving party must provide editable electronic copy of Statement of Material Facts to opposing party.

Source text: Following the filing of this document with the Court, the moving party shall promptly provide an electronic copy in editable format to the opposing party.

Opposing party must provide editable electronic copy of Counter-Statement to moving party.

Source text: the opposing party shall promptly provide an electronic copy in editable format to the moving party.

Counsel must promptly notify court of settlements; court may dismiss without stipulation subject to reconsideration motion.

Source text: Counsel shall promptly notify the Court if a case settles in whole or in part. Upon receipt of a notice of settlement that is not accompanied by a stipulation of dismissal, the Court may dismiss the case subject to a motion for reconsideration by a date certain.

Failure to submit voir dire questions on time results in waiver and potential sanctions.

Source text: Failure to comply with this requirement will be deemed a waiver and/or sanctions will be imposed if the Court decides to entertain untimely voir dire requests.

Failure to oppose motion may result in concession; failure to respond to arguments may result in concession of those arguments.

Source text: If a party fails to oppose a motion, the Court may treat the motion as conceded. Similarly, if a party fails to respond to arguments in opposition papers, the Court may treat those specific arguments as conceded.

Supplemental authorities may be submitted without leave but must follow FRAP 28(j) procedures and not reargue issues.

Source text: 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).

Parties may request oral argument in motions, oppositions, or replies.

Source text: 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.

Trial date set for [DATE] at 9:00 a.m. in Courtroom 9.

Source text: Trial is hereby set to begin on [DATE], at 9:00 a.m., in Courtroom 9.

Parties should stipulate to admissibility of exhibits when possible.

Source text: The court expects most objections to exhibits to be cured by discussion between the parties, and the parties should stipulate to the admissibility of as many exhibits as possible.

Counsel should be judicious in selecting relevant exhibits.

Source text: The court urges counsel to be judicious in determining which documents actually are relevant to necessary elements of the case.

Settlement evaluation and alternative dispute resolution encouraged at any time

Source text: The parties are expected to evaluate their respective cases for purposes of settlement. The Court encourages the use of alternative dispute resolution—e.g., mediation or neutral case evaluation. The use of these methods is available at any time, as is a settlement conference before a magistrate judge.

Jurors must leave notebooks in jury box during recesses; Clerk collects and returns them daily.

Source text: During recesses, the jurors will be required to leave their notebooks in their seats in the jury box. At the end of each day, the notebooks will be collected by the Courtroom Deputy Clerk, and will be placed back in the jurors’ seats in the jury box at the commencement of the trial on the following day.

Court will seat entire venire, administer oath, and explain jury service importance.

Source text: if that space is needed to seat the entire venire. Once all of the jurors are seated, they will be placed under oath and the Court will make a statement about jury service and its importance.

Jurors complete voir dire forms indicating affirmative responses.

Source text: The Court will then ask the jurors collectively the voir dire questions the Court agreed to ask the venire. The jurors will designate, on a form provided to them by the Courtroom Deputy Clerk, the questions to which they have affirmative responses.

Individual questioning of jurors after collective voir dire.

Source text: The potential jurors will then be individually returned to the courtroom for individual questioning by the Court and counsel.

Multiple defendants receive equal number of peremptory strikes when practicable.

Source text: In the event there are multiple defendants in a case, when practicable, each defendant will be provided with an equal number of peremptory strikes.

All cases presumptively referred to alternative dispute resolution.

Source text: There is a presumption that all cases will be referred for some form of alternative dispute resolution.