Court Rules

District of Columbia Document Filing Requirements

310 rules from official source documents

Required elements, certificates, and structural requirements for court documents. This page is scoped to District of Columbia; use the court rules overview to switch categories without leaving this court.

Applies to
Amended pleading

Amended pleadings must include a redline comparison to the prior operative pleading.

Any amended pleading shall be accompanied by a redline comparing it to the otherwise operative pleading.

Judge Amir H. AliCRITICAL
Applies to
Joint meet and confer report

The joint meet-and-confer report must address FRCP 26(f) and Local Rule 16.3(c) matters, include a case description and jurisdictional basis, and attach a proposed scheduling order.

The joint meet-and-confer report in cases subject to Local Civil Rule 16.3(d) must address all matters listed in Federal Rule of Civil Procedure 26(f)(2) & (3) and Local Civil Rule 16.3(c). It must also include: (i) a brief statement describing the nature of the case and the statutory basis of the Court’s jurisdiction for all causes of action and defenses; and (ii) a proposed scheduling order in accordance with Local Civil Rule 16.3(d).

Judge Amir H. AliCRITICAL
Applies to
Motion
Must include
certificate of conference

Motions subject to Local Civil Rule 7(m) must contain the requisite statement or will be summarily denied.

The Court will summarily deny motions that are subject to Local Civil Rule 7(m) but do not contain the requisite statement.

Judge Amir H. AliCRITICAL
Applies to
Answer
Must include
notice of electronic filing

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.

Judge Ana C. ReyesCRITICAL
Applies to
Key cases binder
Must include
index

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.

Judge Ana C. ReyesCRITICAL
Applies to
Exhibit
Must include
index

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.

Judge Ana C. ReyesCRITICAL
Applies to
Attachment
Must include
separate pdf, appropriate labeling

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.

Judge Ana C. ReyesCRITICAL
Applies to
Motion
Must include
proposed order

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.

Judge Ana C. ReyesCRITICAL
Applies to
Amended pleading
Must include
redline comparison

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.

Judge Ana C. ReyesCRITICAL
Applies to
Summary judgment motion
Must include
lr 7 h compliance

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).

Judge Ana C. ReyesCRITICAL
Applies to
Summary judgment motion
Must include
statement of material facts

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

Judge Ana C. ReyesCRITICAL
Applies to
All
Must include
certificate of service

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.

Judge Ana C. ReyesCRITICAL
Applies to
Motion
Must include
legal argument, statement of facts

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).

Judge Ana C. ReyesCRITICAL
Applies to
Joint pretrial statement
Must include
judge name, case number

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).

Judge Ana C. ReyesCRITICAL
Applies to
Joint pretrial statement

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;

Judge Ana C. ReyesCRITICAL
Applies to
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”;

Judge Ana C. ReyesCRITICAL
Applies to
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;

Judge Ana C. ReyesCRITICAL
Applies to
Joint pretrial statement

Description of other relief sought must be included.

a description of other relief sought by each party;

Judge Ana C. ReyesCRITICAL
Applies to
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;

Judge Ana C. ReyesCRITICAL
Applies to
Joint pretrial statement

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;

Judge Ana C. ReyesCRITICAL
Applies to
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.

Judge Ana C. ReyesCRITICAL
Applies to
Joint pretrial statement

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

Judge Ana C. ReyesCRITICAL
Applies to
Jury selection
Must include
certificate of confidentiality

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.

Judge Ana C. ReyesCRITICAL
Applies to
Motion
Must include
proposed order

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.

Judge Ana C. ReyesCRITICAL
Applies to
Plea agreement

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

Judge Ana C. ReyesCRITICAL
Applies to
Filing
Must include
notice of electronic filing

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

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.

Judge Dabney L. FriedrichCRITICAL
Applies to
Joint pretrial statement
Must include
caption, judge name, case number

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

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.

Judge Dabney L. FriedrichCRITICAL
Applies to
Joint pretrial statement
Must include
notice of electronic filing

Electronic copy of Joint Pretrial Statement must be emailed 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.

Judge Dabney L. FriedrichCRITICAL
Applies to
Motion in limine
Must include
certificate section

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

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

Judge Dabney L. FriedrichCRITICAL
Applies to
Trial procedures
Must include
judge name, case number

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

Judge Dabney L. FriedrichCRITICAL
Applies to
Sentencing memorandum
Must include
witness list

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

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.

Judge Dabney L. FriedrichCRITICAL
Applies to
Sentencing memorandum
Must include
letters attached

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

Judge Dabney L. FriedrichCRITICAL
Applies to
Discovery motion

Discovery motions must include relevant portions of nonfiled discovery materials.

Any motion concerning discovery matters shall be accompanied by a copy of, or shall set forth verbatim, the relevant portion of any nonfiled discovery materials to which the motion is addressed. Discovery materials may be used and filed as exhibits or evidence in support of any motion or at a trial or evidentiary hearing in accordance with the Federal Rules of Evidence.

Judge Dabney L. FriedrichCRITICAL
Applies to
All

Use of CM/ECF password to submit documents constitutes the filer's signature for all purposes.

The use of a CM/ECF password to login and submit documents creates an electronic record that operates and serves as the signature of the person to whom the password is assigned for all purposes under the Federal Rules of Civil Procedure and the Local Rules of this Court.

Judge Dabney L. FriedrichCRITICAL
Applies to
All electronically filed documents
Must include
redaction

Electronically filed documents must exclude or redact SSN (last four digits only), minor children's names (initials only), dates of birth (year only), and financial account numbers (last four digits only).

The following personal identifiers shall be excluded, or redacted where inclusion is necessary, from all electronically filed documents unless otherwise ordered by the Court. (1) Social Security numbers. If an individual's Social Security number must be included in a pleading, only the last four digits of that number should be used. (2) Names of minor children. If the involvement of a minor child must be mentioned, only the initials of that child should be used. (3) Dates of birth. If an individual's date of birth must be included in a pleading, only the year should be used. (4) Financial account numbers. If a financial account number is relevant, only the last four digits should be used.

Judge Dabney L. FriedrichCRITICAL
Applies to
Motion
Must include
proposed order

Each motion must be accompanied by a proposed order.

Each motion and opposition shall be accompanied by a proposed order.

Judge Dabney L. FriedrichCRITICAL
Applies to
Motion for summary judgment

Motion for summary judgment must include a statement of material facts with references to the record.

Each motion for summary judgment shall be accompanied by a statement of material facts as to which the moving party contends there is no genuine issue, which shall include references to the parts of the record relied on to support the statement.

Judge Dabney L. FriedrichCRITICAL
Applies to
Opposition to summary judgment

Opposition to summary judgment must include a statement of genuine issues with references to the record.

An opposition to such a motion shall be accompanied by a separate concise statement of genuine issues setting forth all material facts as to which it is contended there exists a genuine issue necessary to be litigated, which shall include references to the parts of the record relied on to support the statement.

Judge Dabney L. FriedrichCRITICAL
Applies to
Motion for leave to amend

Motion for leave to amend must be accompanied by the original proposed amended pleading.

A motion for leave to file an amended pleading shall be accompanied by an original of the proposed pleading as amended.

Judge Dabney L. FriedrichCRITICAL
Applies to
Motion to intervene

Motion to intervene must be accompanied by an original pleading setting forth the claim or defense.

A motion to intervene as a party pursuant to Fed. R. Civ. P. 24(c), Procedure, shall be accompanied by an original of the pleading setting forth the claim or defense for which intervention is sought.

Judge Dabney L. FriedrichCRITICAL
Applies to
Motion
Must include
certificate of conference

Nondispositive motions must include a statement that the required discussion occurred and whether the motion is opposed.

A party shall include in its motion a statement that the required discussion occurred, and a statement as to whether the motion is opposed.

Judge Dabney L. FriedrichCRITICAL
Applies to
Motion
Must include
proposed order

Motion for leave to file amicus brief must state nature of interest, party supported, reasons, party positions, and include a proposed order.

A motion for leave to file an amicus brief shall concisely state the nature of the movant's interest; identify the party or parties supported, if any; and set forth the reasons why an amicus brief is desirable, why the movant’s position is not adequately represented by a party, and why the matters asserted are relevant to the disposition of the case. The motion shall state the position of each party as to the filing of such a brief and be accompanied by a proposed order.

Judge Dabney L. FriedrichCRITICAL
Applies to
Application for three judge court

An Application for Three-Judge Court with a supporting memorandum must be filed with the complaint.

In every case in which by statute a Three-Judge Court is required, there shall be filed with the complaint a separate document entitled 'Application for Three-Judge Court,' together with a memorandum of points and authorities in support of the application.

Judge Dabney L. FriedrichCRITICAL
Applies to
Habeas petition or section1983 complaint or section2255 motion

Incarcerated petitioners must use standard forms for habeas, §1983, and §2255 filings; counsel must include the same information as on the standard form.

Petitions for a writ of habeas corpus and complaints pursuant to 42 U.S.C. § 1983 filed by a petitioner incarcerated in the District of Columbia, and motions filed pursuant to 28 U.S.C. § 2255 (attacking a sentence imposed by the Court), must be filed on standard forms to be supplied upon request to the petitioner or plaintiff by the Clerk without cost. Counsel filing a petition for a writ of habeas corpus, a complaint under 42 U.S.C. §1983, or a motion under 28 U.S.C. § 2255 need not use a standard form, but any such petition, complaint or motion shall contain essentially the same information set forth on the standard form.

Judge Dabney L. FriedrichCRITICAL
Applies to
Motion to amend

Motions to amend must attach a copy of the proposed amended pleading as an exhibit.

A motion for leave to file an amended pleading shall attach, as an exhibit, a copy of the proposed pleading as amended.

Judge Dabney L. FriedrichCRITICAL
Applies to
Scheduling order

Scheduling orders under Rule 16(b) must be in writing.

All scheduling orders pursuant to Fed. R. Civ. P. 16(b) must be in writing.

Judge Dabney L. FriedrichCRITICAL
Applies to
Pretrial statement

Pretrial statements must include statement of the case, claims, defenses, witness schedule, exhibit list, deposition designations, damage itemization, and relief request.

A party's Pretrial Statement shall contain the following: (i) a statement of the case; (ii) a statement of claims made by the party; (iii) a statement of defenses raised by the parties; (iv) a schedule of witnesses to be called by the party; (v) a list of exhibits to be offered in evidence by the party; (vi) a designation of depositions, or portions thereof, to be offered in evidence by the party; (vii) an itemization of damages the party seeks to recover; and (viii) a request for other relief sought by the party.

Judge Dabney L. FriedrichCRITICAL
Applies to
Complaint

Complaints in class actions must contain a separate 'Class Action Allegations' section with specific content.

In any case sought to be maintained as a class action, the complaint shall contain under a separate heading styled "Class Action Allegations": (1) A reference to the portion or portions of Fed. R. Civ. P. 23, under which the suit is claimed properly to be maintainable as a class action. (2) Appropriate allegations justifying such claim, including, but not necessarily limited to: (i) the size (or approximate size) and definition of the alleged class; (ii) the basis upon which the plaintiff claims to be an adequate representative of the class, or if the class is comprised of defendants, that those named as parties are adequate representatives of the class; (iii) the alleged questions of law and fact claimed to be common to the class; and (iv) in actions claimed to be maintainable as class actions under Fed. R. Civ. P. 23(b)(3), allegations supporting the findings required by that subdivision.

Judge Dabney L. FriedrichCRITICAL
Applies to
Motion for class certification

Motion for class certification under Rule 23(b)(3) must include a statement proposing notice details.

In an action maintained under Fed. R. Civ. P. 23(b)(3), the plaintiff shall include in the motion for certification a statement proposing (1) how, when, by whom, and to whom the notice required by Fed. R. Civ. P. 23(c)(2) shall be given, (2) how and by whom payment therefore is to be made, and (3) by whom the response to the notice is to be received.

Judge Dabney L. FriedrichCRITICAL
Applies to
First pleading

Corporate parties must file a certificate of affiliations and financial interests with their first pleading, with continuing obligation to update.

In all civil, agency, or criminal cases where a corporation is a party or intervener, counsel of record for that party or intervener shall file a certificate listing any parent, subsidiary, affiliate, or any company which owns 10% or more of the stock of that party or intervener which, to the knowledge of counsel, has any outstanding securities in the hands of the public. Such certificate shall be filed at the time the party's first pleading is filed. The purpose of this certificate is to enable the judges of this Court to determine the need for recusal. Counsel shall have the continuing obligation to advise the Court of any change.

Judge Dabney L. FriedrichCRITICAL
Applies to
Temporary restraining order application

TRO application must be filed as a separate motion.

An application for a temporary restraining order shall be made in a motion separate from the complaint.

Judge Dabney L. FriedrichCRITICAL
Applies to
Temporary restraining order application
Must include
certificate of service

TRO application must include a certificate of counsel or proof of notice to adverse party.

The application shall be accompanied by a certificate of counsel, or other proof satisfactory to the Court, stating (1) that actual notice of the time of making the application, and copies of all pleadings and papers filed in the action to date or to be presented to the Court at the hearing, have been furnished to the adverse party; or (2) the efforts made by the applicant to give such notice and furnish such copies.

Judge Dabney L. FriedrichCRITICAL
Applies to
Temporary restraining order application

If unable to notify Clerk before emergency TRO, file an affidavit explaining why.

If notice is not given to the Clerk as provided herein, the party shall file with its application an affidavit stating why such notice was not given.

Judge Dabney L. FriedrichCRITICAL
Applies to
Preliminary injunction application

Preliminary injunction application must be in a separate document.

An application for a preliminary injunction shall be made in a document separate from the complaint.

Judge Dabney L. FriedrichCRITICAL
Applies to
Preliminary injunction application

PI application must include all supporting affidavits.

The application shall be supported by all affidavits on which the plaintiff intends to rely.

Judge Dabney L. FriedrichCRITICAL
Applies to
Opposition

Opposition to PI must include all affidavits defendant intends to rely on.

The opposition shall be served and filed within seven days after service of the application for preliminary injunction, and shall be accompanied by all affidavits on which the defendant intends to rely.

Judge Dabney L. FriedrichCRITICAL
Applies to
Request for live testimony

Request for live testimony at PI hearing must be in writing 72 hours before, with witness list and time estimate.

any party who wishes to offer live testimony or cross-examine an affiant at the hearing shall so request in writing 72 hours before the hearing and shall provide the Court and all other parties a list of the witnesses to be examined and an estimate of the time required.

Judge Dabney L. FriedrichCRITICAL
Applies to
Pro hac vice motion
Must include
certificate of good standing

Pro hac vice motions must include a certificate of good standing from the applicant's state bar, issued within 30 days.

The motion must be accompanied by a certificate of the court or bar for the state in which the applicant regularly practices, which has been issued within thirty (30) days of filing and states that the applicant is a member in good standing of the bar of that state court.

Judge Dabney L. FriedrichCRITICAL
Applies to
Pro hac vice motion
Must include
declaration

Pro hac vice motions must include a declaration with specific information about the attorney's background and disciplinary history.

accompanied by a declaration by the non-member that sets forth: (1) the full name of the attorney; (2) the attorney’s office address and telephone number; (3) a list of all bars to which the attorney has been admitted; (4) a certification that the attorney either has or has not been disciplined by any bar, and if the attorney has been disciplined by any bar, the circumstances and details of the discipline; (5) the number of times the attorney has been admitted pro hac vice in this Court within the last two years; and (6) whether the attorney, if the attorney engages in the practice of law from any office located in the District of Columbia, is a member of the District of Columbia Bar or has an application for membership pending.

Judge Dabney L. FriedrichCRITICAL
Applies to
Pro hac vice motion
Must include
sponsor signature

Pro hac vice motions must be signed by a sponsoring member of the Court's Bar.

Any attorney seeking to appear pro hac vice must file a motion signed by a sponsoring member of the Bar of this Court

Judge Dabney L. FriedrichCRITICAL
Applies to
Any

Documents filed by law students must be read, approved, and co-signed by the supervising lawyer.

Documents or papers filed with the Court must be read, approved, and co-signed by the supervising lawyer.

Judge Dabney L. FriedrichCRITICAL
Applies to
Motion
Must include
certificate of service

Motion to withdraw must include certificate of service with party's address and notice of right to object within 7 days.

Unless the party is represented by another attorney or the motion is made in open court in the party's presence, a motion to withdraw an appearance shall be accompanied by a certificate of service listing the party's last known address, unless such address does not appear on the public docket, and stating that the attorney has served upon the party a copy of the motion and a notice advising the party to obtain other counsel, or, if the party intends to conduct the case pro se or to object to the withdrawal, to so notify the Clerk in writing within seven days of service of the motion.

Judge Dabney L. FriedrichCRITICAL
Applies to
Notice of withdrawal
Must include
certificate of service

A notice of withdrawal must include proof of service on the pro se litigant and specific language citing the grounds for relief.

An attorney seeking to be relieved from appointment for the reasons set forth in subparagraph (b)(6)(i)(aa), (bb), or (cc) above shall file a notice of withdrawal with the Court, with proof of service on the pro se litigant, stating without identification of reasons, that 'grounds for relief from appointment under subparagraph (b)(6)(i)(aa), (bb), or (cc) exist.'

Judge Dabney L. FriedrichCRITICAL
Applies to
Motion for withdrawal
Must include
certificate of service

A motion for withdrawal must set forth the circumstances constituting cause and include proof of service on the pro se litigant.

An attorney wishing to be relieved for the reasons set forth in subparagraph (b)(6)(i)(dd) or (ff) shall file a motion for withdrawal setting forth the circumstances constituting cause for withdrawal, with proof of service on the litigant pro se.

Judge Dabney L. FriedrichCRITICAL
Applies to
Complaint of misconduct

Written complaints of misconduct must contain a clear and concise statement of facts supporting the allegations.

Subsection (d)(1) This rule was modified to require that written complaints of misconduct contain a clear and concise statement of facts supporting the allegations made again attorneys.

Judge Dabney L. FriedrichCRITICAL
Applies to
Affidavit of compliance

For automatic reinstatement after suspension, attorney must file an affidavit of compliance and, for reciprocal discipline, proof of reinstatement by the other court.

An attorney suspended for a specific period shall be automatically reinstated at the end of the period upon the filing with the Court of an affidavit of compliance with the provisions of the order of suspension (including, in the case of reciprocal discipline, proof that the attorney has been reinstated by the court in which the attorney was disciplined.)

Judge Dabney L. FriedrichCRITICAL
Applies to
Discovery motion
Must include
certificate of conference

Discovery motions must include a statement that defense counsel previously requested the information from the US attorney and that the request was not complied with.

No discovery motion shall be heard unless it states that defense counsel has previously requested that the information sought from the attorney for the United States and that such attorney has not complied with the request.

Judge Dabney L. FriedrichCRITICAL
Applies to
Motion for pro hac vice

Pro hac vice motion must include a detailed declaration and a certificate of good standing from the state bar.

Any attorney seeking to appear pro hac vice must file a motion signed by a sponsoring member of the Bar of this Court, accompanied by a declaration by the non-member that sets forth: (1) the full name of the attorney; (2) the attorney’s office address and telephone number; (3) a list of all bars to which the attorney has been admitted; (4) a certification that the attorney either has or has not been disciplined by any bar, and if the attorney has been disciplined by any bar, the circumstances and details of the discipline; (5) the number of times the attorney has been admitted pro hac vice in this Court within the last two years; and (6) whether the attorney, if the attorney engages in the practice of law from any office located in the District of Columbia, is a member of the District of Columbia Bar or has an application for membership pending. The motion must be accompanied by a certificate of the court or bar for the state in which the applicant regularly practices, which has been issued within thirty (30) days of filing and states that the applicant is a member in good standing of the bar of that state court.

Judge Dabney L. FriedrichCRITICAL
Applies to
Notice of appearance

Attorneys in criminal cases must file a notice of appearance on a court-approved form.

An attorney appearing for a defendant in a criminal case, whether appointed or retained, shall file with the Clerk a notice of appearance on a court-approved form.

Judge Dabney L. FriedrichCRITICAL
Applies to
Certificate of familiarity with sentencing guidelines

Lead counsel in criminal cases must file a certificate of familiarity with sentencing guidelines, valid for three years.

Every attorney who appears as sole or lead counsel in a criminal case must have on file with the Clerk's Office a certificate, in a form prescribed by the Clerk, in which the attorney states that he or she is familiar with the Federal Sentencing Guidelines. If the attorney has filed such a certificate during the previous three years (see Rule 701.1), a new certificate is not necessary.

Judge Dabney L. FriedrichCRITICAL
Applies to
Motion to withdraw

Withdrawal of counsel requires a written motion.

An attorney who has appeared in a criminal case may thereafter withdraw only by written motion served upon the defendant personally or at the defendant's last-known address, and upon all other parties.

Judge Dabney L. FriedrichCRITICAL
Applies to
Certificate of corporate affiliations

Corporate parties in criminal cases must file a certificate listing corporate affiliations at the time of first appearance.

In all criminal cases where a corporation is a party, counsel of record for that party shall file a certificate listing any parent, subsidiary, affiliate, or any company which, to the knowledge of counsel, has any outstanding securities in the hands of the public. Such certificate shall be filed at the time counsel first enters his or her appearance in the case.

Judge Dabney L. FriedrichCRITICAL
Applies to
Motion

Each motion must include a statement of the specific points of law and authorities that support it.

Each motion shall include or 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.

Judge Dabney L. FriedrichCRITICAL
Applies to
Motion
Must include
proposed order

Each motion must include a proposed order.

Each motion shall be accompanied by a proposed order.

Judge Dabney L. FriedrichCRITICAL
Applies to
Attorney signed document

Documents signed by an attorney must include the attorney's name, address, phone number, and D.C. Bar ID if applicable.

All documents signed by an attorney shall contain the name, address, telephone number, and D.C. Bar identification number of the attorney if the attorney is a member of the D.C. Bar. All attorneys listed on any document who are members of the D.C. Bar must include their D.C. Bar identification numbers regardless of whether they sign the document.

Judge Dabney L. FriedrichCRITICAL
Applies to
Signed document

By signing, an attorney certifies that all attorneys on the document are admitted or have pending admission to the court's bar.

By signing a document that is presented to the Court, an attorney is certifying that the attorney and all other attorneys appearing with the attorney on the document are members of or have a pending application for admission to the Bar of this Court, or have complied with LCrR 44.1 (c) or (d), or are covered by LCrR 44.1(e) as counsel for the United States.

Judge Dabney L. FriedrichCRITICAL
Applies to
Application for relief

Applications for relief by non-parties must include a statement of interest, statement of facts, and specific prayer for relief.

The application shall include a statement of the applicant's interest in the matter as to which relief is sought, a statement of facts, and a specific prayer for relief.

Judge Dabney L. FriedrichCRITICAL
Applies to
All documents
Must include
caption

All documents in referred bankruptcy cases must be filed with the Clerk of the Bankruptcy Court and captioned 'United States Bankruptcy Court for the District of Columbia.'

Except as otherwise provided in DCt.LBR 5011-5, and in the Bankruptcy Rules relating to appeals, all documents filed in any such referred case or proceeding, including the original bankruptcy petition, must be filed with the Clerk of the Bankruptcy Court and must be captioned "United States Bankruptcy Court for the District of Columbia."

Judge Dabney L. FriedrichCRITICAL
Applies to
Motion to withdraw reference
Must include
caption

Motion to withdraw reference must bear caption of Bankruptcy Court and include movant's designation of the record.

A motion for withdrawal in whole or in part of the reference of a case or proceeding referred to a bankruptcy judge must bear the caption of the Bankruptcy Court, and be filed with the Clerk of the Bankruptcy Court, accompanied by the required filing fee, and the movant's designation of the record.

Judge Dabney L. FriedrichCRITICAL
Applies to
Motion to withdraw reference

Motion to withdraw reference must include specification, facts, reasons, docket sheet, list of relevant documents, and copies of relevant documents with ECF headers.

A motion for withdrawal of the reference must include the following: (1) a specification of the case or proceedings to be withdrawn; (2) the facts necessary to understand the grounds presented in support of the requested withdrawal of the reference; (3) the reasons why the withdrawal of the reference should be granted; (4) a copy of the docket sheet of the case or proceeding for which withdrawal of the reference is requested; (5) a separate list of any documents filed in the Bankruptcy Court that are relevant to the motion for withdrawal of the reference, including the date of filing, the document number, and the title of each such document; and (6) copies of the listed relevant documents (other than documents that were filed under seal), appended to the list in chronological sequence, with each document to bear the Electronic Case Filing header showing the document number and date of filing in the Bankruptcy Court.

Judge Dabney L. FriedrichCRITICAL
Applies to
Notice of removal
Must include
caption

Notice of removal of civil action must be captioned for the Bankruptcy Court.

Pursuant to paragraph (c) and DCt.LBR 9027-1, the notice of removal of such a civil action must be captioned for the Bankruptcy Court.

Judge Dabney L. FriedrichCRITICAL
Applies to
Motion to withdraw reference
Must include
proposed order

Motions to withdraw the reference and oppositions must include a proposed order captioned for the District Court.

The motion to withdraw the reference (and any related motion seeking an order of the District Court), and any opposition thereto, must include a proposed order captioned for the District Court and complying with LCvR 7(k).

Judge Dabney L. FriedrichCRITICAL
Applies to
Objection
Must include
proposed order

Objections and responses under Bankruptcy Rule 9033(b) must include a proposed order.

Objections, and responses thereto, filed under Bankruptcy Rule 9033(b) must include a proposed order captioned for the District Court and complying with DCt.LCvR 7(k).

Judge Dabney L. FriedrichCRITICAL
Applies to
Notice of contact change
Must include
case number, phone number, email address +1 more

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

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.

Judge Randolph D. MossCRITICAL
Applies to
Proof of service
Must include
certificate of service

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.

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).

Judge Randolph D. MossCRITICAL
Applies to
Disclosure certificate
Must include
case number, certificate of service

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

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.

Judge Randolph D. MossCRITICAL
Applies to
Pretrial conference
Must include
settlement authority present

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

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.

Judge Tanya S. ChutkanCRITICAL
Applies to
Joint pretrial statement
Must include
meet and confer required, good faith conferring required, settlement discussion required +1 more

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

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

Judge Tanya S. ChutkanCRITICAL
Applies to
Pretrial order
Must include
sanctions warning

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

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.”).

Judge Tanya S. ChutkanCRITICAL
Applies to
Joint pretrial statement
Must include
exhibit list

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

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

Judge Tanya S. ChutkanCRITICAL
Applies to
Joint pretrial statement
Must include
witness schedule

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

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

Judge Tanya S. ChutkanCRITICAL
Applies to
Joint pretrial statement
Must include
exhibit list

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

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

Judge Tanya S. ChutkanCRITICAL
Applies to
Joint pretrial statement
Must include
exhibit premarking

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

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.

Judge Tanya S. ChutkanCRITICAL
Applies to
Joint pretrial statement

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

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.

Judge Tanya S. ChutkanCRITICAL
Applies to
Joint pretrial statement
Must include
deposition objections

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

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.

Judge Tanya S. ChutkanCRITICAL
Applies to
Joint pretrial statement
Must include
deposition excerpts

Deposition objections must include excerpts from the deposition.

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

Judge Tanya S. ChutkanCRITICAL
Applies to
Joint pretrial statement
Must include
timely objections

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

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.

Judge Tanya S. ChutkanCRITICAL
Applies to
Joint pretrial statement

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

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.

Judge Tanya S. ChutkanCRITICAL
Applies to
Joint pretrial statement

JPTS must separately list each damage element and monetary amount.

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.

Judge Tanya S. ChutkanCRITICAL
Applies to
Jury case
Must include
waiver of jury trial

Jury trial waiver required in jury cases

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

Judge Tanya S. ChutkanCRITICAL
Applies to
Jury case

Voir dire objections and proposals required with supporting authority

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);

Judge Tanya S. ChutkanCRITICAL
Applies to
Jury case

Proposed jury instructions with citations and formatting required

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);

Judge Tanya S. ChutkanCRITICAL
Applies to
Jury case

Proposed verdict form with signature line required in jury cases

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.

Judge Tanya S. ChutkanCRITICAL
Applies to
Jury case

Objections must specify objectionable portions with legal authority and proposed alternatives

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.

Judge Tanya S. ChutkanCRITICAL
Applies to
Non jury case

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

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

Judge Tanya S. ChutkanCRITICAL
Applies to
Trial preparation

Estimated trial length and witness scheduling problems must be listed

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

Judge Tanya S. ChutkanCRITICAL
Applies to
Pretrial order

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

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.

Judge Tanya S. ChutkanCRITICAL
Applies to
Pretrial order

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

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

Judge Tanya S. ChutkanCRITICAL
Applies to
Pretrial order

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

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

Judge Tanya S. ChutkanCRITICAL
Applies to
Proposed findings conclusions

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

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

Judge Tanya S. ChutkanCRITICAL
Applies to
Amended pleading
Must include
redline comparison

Amended pleadings must include redline comparison showing changes

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

Judge Timothy J. KellyCRITICAL
Applies to
Motion for admission pro hac vice
Must include
local rule 83 2d compliance

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

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.

Judge Timothy J. KellyCRITICAL
Applies to
Motion for extension of time
Must include
good cause, original date, time requested +4 more

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.

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).

Judge Timothy J. KellyCRITICAL
Applies to
Non dispositive motion
Must include
local rule 7m statement

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

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.

Judge Timothy J. KellyCRITICAL
Applies to
Motion for protective order
Must include
proposed order, good cause explanation

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

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).

Judge Timothy J. KellyCRITICAL
Applies to
Motion to seal
Must include
redaction proposal, hubbard factors explanation, separate exhibit for each document

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

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.

Judge Timothy J. KellyCRITICAL
Applies to
Motion for summary judgment
Must include
statement of material facts

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

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.

Judge Timothy J. KellyCRITICAL
Applies to
Opposition to summary judgment
Must include
statement of genuinely disputed facts

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

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.

Judge Timothy J. KellyCRITICAL
Applies to
Motion for summary judgment
Must include
statement of material facts

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

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).

Judge Timothy J. KellyCRITICAL
Applies to
Summary judgment motion

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

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.”

Judge Timothy J. KellyCRITICAL
Applies to
Summary judgment opposition

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

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.”

Judge Timothy J. KellyCRITICAL
Applies to
Settlement
Must include
notice of settlement

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

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

Judge Timothy J. KellyCRITICAL
Applies to
Summary judgment reply

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

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.”

Judge Timothy J. KellyCRITICAL
Applies to
Summary judgment motion
Must include
editable electronic copy

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

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

Judge Timothy J. KellyCRITICAL
Applies to
Summary judgment opposition
Must include
editable electronic copy

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

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

Judge Timothy J. KellyCRITICAL
Applies to
Discovery motion
Must include
certificate of conference

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

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.

Judge Timothy J. KellyCRITICAL
Applies to
Discovery motion
Must include
leave of court

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

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

Judge Timothy J. KellyCRITICAL
Applies to
Amended pleading

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

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

Judge Timothy J. KellyCRITICAL
Applies to
Complaint
Must include
certificate of service

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

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.

Judge Timothy J. KellyCRITICAL
Applies to
Motion
Must include
certificate of conference

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

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).

Judge Timothy J. KellyCRITICAL
Applies to
Motion
Must include
certificate of conference

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

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.

Judge Timothy J. KellyCRITICAL
Applies to
Motion

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

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.

Judge Timothy J. KellyCRITICAL
Applies to
Motion
Must include
proposed order

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

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).

Judge Timothy J. KellyCRITICAL
Applies to
Motion

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

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.

Judge Timothy J. KellyCRITICAL
Applies to
Opposition

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

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.

Judge Timothy J. KellyCRITICAL
Applies to
Motion

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

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.

Judge Timothy J. KellyCRITICAL
Applies to
Opposition

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

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.

Judge Timothy J. KellyCRITICAL
Applies to
Reply

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

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.

Judge Timothy J. KellyCRITICAL
Applies to
Motion

In agency review cases, summary judgment motions and oppositions must include a statement of facts with precise citations to the administrative record.

In accordance with Local Civil Rule 7(h)(2), each motion for summary judgment, and opposition thereto, shall include a statement of facts with references to the administrative record. The parties must furnish precise citations to the portions of the administrative record on which they rely; the Court need not consider materials not specifically identified. See FED. R. CIV. P. 56(c)(3).

Senior Judge Colleen Kollar-KotellyCRITICAL
Applies to
Motion

In non-agency cases, summary judgment motions must include a statement of material facts with citations; opposition must include a statement of disputed facts.

The Court strictly adheres to the dictates of Local Civil Rule 7(h), which requires that each party submitting a motion for summary judgment attach 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. The party opposing the motion must, in turn, submit a statement enumerating all material facts which the party contends are genuinely disputed and thus require trial. See LCvR 7(h)(1).

Senior Judge Colleen Kollar-KotellyCRITICAL
Applies to
Opposition

Facts not controverted in opposition may be deemed admitted.

The Court may assume that facts identified by the moving party in its statement of material facts are admitted, unless such facts are controverted in the statement filed in opposition to the motion. See LCvR 7(h)(1).

Senior Judge Colleen Kollar-KotellyCRITICAL
Applies to
Motion for reconsideration

Motions for reconsideration may not reassert previously rejected arguments or raise new arguments that could have been raised earlier.

Moreover, the Court will not entertain: (a) motions which simply reassert arguments previously raised and rejected by the Court; or (b) arguments which should have been previously raised, but are being raised for the first time.

Senior Judge Colleen Kollar-KotellyCRITICAL
Applies to
Motion for reconsideration

Motions for reconsideration must meet FRCP 54(b), 59(e), or 60(b) requirements.

Such motions shall be filed only when the requirements of Federal Rules of Civil Procedure 54(b), 59(e), and/or 60(b) are met.

Senior Judge Colleen Kollar-KotellyCRITICAL
Applies to
Discoverable evidence

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

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

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Documents

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

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

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Electronically stored information

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

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.

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Tangible format information

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

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.

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Summary

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

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

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Amended submission

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

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

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Rule 16 3 report
Must include
proposed order

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

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.

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Rule 16 3 report

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

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.

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Submission with multiple exhibits

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

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

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Summary judgment motion

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

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

Senior Judge Emmet G. SullivanCRITICAL
Applies to
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.

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.

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Summary judgment opposition

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

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

Senior Judge Emmet G. SullivanCRITICAL
Applies to
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.

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.

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Counter statement of disputed facts

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

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.

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Reply to counter statement of disputed facts

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

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.

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Brady material

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

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

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Exculpatory evidence

Government must produce exculpatory evidence during plea negotiations

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

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Evidence

Government must resolve doubts in favor of full disclosure of evidence

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.

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Brady information

Failure to timely produce Brady information may constitute prejudice

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

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Discovery

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

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.

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Answer

A removing defendant must refile any answer as a supplement to the petition.

A defendant removing an action to this Court must refile as a supplement to the petition any answer

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Motion

Pending motions at removal must be refiled in this Court by the party seeking relief to be considered.

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.

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Amended submission

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

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

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Submission

Every submission with more than one exhibit must include an index of exhibits.

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

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Statement of material facts

Moving party must file a Statement of Material Facts Not in Dispute as a two-column table with one undisputed fact per numbered row, citing the record.

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 contends is not in dispute, supported by appropriate citations to the record. The statement must contain only one undisputed factual assertion per numbered row.

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Counter statement of disputed facts

Opposing party must file a Counter-Statement of Disputed Facts indicating in the right column whether each fact is admitted or denied, with citations, and identifying partial admissions/denials.

In response, the opposing party shall file a separate document entitled Counter-Statement of Disputed Facts. The opposing party shall indicate in the right column whether each corresponding fact in the left column is admitted or denied, and for those denied, provide appropriate 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.

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Reply to counter statement

Moving party must file a Reply to Counter-Statement of Disputed Facts responding with citations in the left column to the additional facts.

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.

Senior Judge Emmet G. SullivanCRITICAL
Applies to
Sur reply
Must include
leave of court

Sur-replies require leave of court.

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

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Motion
Must include
proposed order

All motions must include a proposed order.

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

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Memorandum of points and authorities

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Submission with exhibits

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Motion
Must include
compliance with local rules

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

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

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Motion
Must include
motion required instead of stipulation

Motions must be filed rather than stipulations.

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

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Initial scheduling conference
Must include
settlement authority

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

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

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Joint report
Must include
meet and confer

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Joint statement
Must include
dispositive motions

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Administrative record
Must include
dispositive motions

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Motion for summary judgment

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Opposition to summary judgment

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Opposition to summary judgment

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Reply to summary judgment

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Motion for summary judgment

Parties must provide precise citations to record portions relied upon.

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).

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Motion for reconsideration

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
All

Citations must follow Bluebook format with exact page references.

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
All

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
All

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

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

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Guilty plea hearing
Must include
factual proffer, superseding indictment, written plea agreement +3 more

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Brady material
Must include
judge name, case number

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Brady material
Must include
judge name, case number

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Giglio material
Must include
judge name, case number

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

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

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Giglio material
Must include
judge name, case number

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

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

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Brady giglio material
Must include
judge name, case number

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Extrajudicial statements
Must include
judge name, case number

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

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

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Preliminary instructions request
Must include
written request

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Opening statement
Must include
objection procedure

Counsel must object to improper statements during opening statements.

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

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Opening statement closing argument
Must include
no personal attacks, no personal opinions

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Objection
Must include
standing required

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

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

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Motion in limine
Must include
follow case orders

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Motion in limine
Must include
contest expected issues

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

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

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Objection

Objections must state only legal basis without elaboration

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Exhibit list
Must include
certificate of service

Exhibit lists with descriptions due 3 days before trial

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Voir dire questions
Must include
electronic filing, microsoft word format

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

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

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Strikes for cause
Must include
judge name, case number

Strikes for cause must be made immediately after individual questioning.

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

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Peremptory strikes
Must include
judge name, case number

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Joint report
Must include
certificate of conference

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Notice
Must include
notice of electronic filing

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

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

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Motion for extension of time

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Guilty plea hearing documents

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Exhibit list

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

(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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Trial exhibits
Must include
exhibit list

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

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.).

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Jury instructions

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

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.

Senior Judge Reggie B. WaltonCRITICAL
Applies to
Supplement
Must include
proposed order

If a supplement is filed, the parties must confer and submit a proposed joint scheduling order.

In any case in which the Federal Public Defender files such a supplement, the United States and the Federal Public Defender will confer and present a proposed joint scheduling order to the Court to govern future filings.

Chief Judge James E. BoasbergWARNING
Applies to
Report

Parties must jointly submit a scheduling report within 14 days after any defendant files an answer in APA cases.

record, counsel for the parties shall jointly prepare and submit a report to the Court, within fourteen days after any defendant files an answer, proposing a schedule for the filing of the certified list of the contents of the administrative record and any motions.

Judge Amir H. AliWARNING
Applies to
Report

Parties must jointly submit a FOIA status report within 14 days after any defendant files an answer.

In cases arising under the Freedom of Information Act ("FOIA"), 5 U.S.C. § 552, the parties shall jointly submit a report to the Court within fourteen days after any defendant files an answer addressing the status of Plaintiff's FOIA request, including the anticipated number of documents responsive to the request and the anticipated date(s) for release of the requested documents.

Judge Amir H. AliWARNING
Applies to
Motion

Motions, oppositions, and replies of 10 pages or more must include a Table of Contents.

Every motion, opposition, or reply that is ten pages or longer must have a Table of Contents.

Judge Amir H. AliWARNING
Applies to
Notice of settlement

Plaintiff's counsel must promptly file a notice of settlement with the Court when the case settles.

If the case settles, in whole or in part, Plaintiff's counsel must promptly file a notice with the Court.

Judge Amir H. AliWARNING
Applies to
Motion for reconsideration
Must include
new arguments

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.

Judge Ana C. ReyesWARNING
Applies to
Submission

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.

Judge Ana C. ReyesWARNING
Applies to
Brief

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.

Judge Ana C. ReyesWARNING
Applies to
Joint pretrial statement

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.

Judge Ana C. ReyesWARNING
Applies to
Sentencing memorandum
Must include
citation to authority

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.

Judge Ana C. ReyesWARNING
Applies to
Sentencing memorandum
Must include
attached letters

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.

Judge Ana C. ReyesWARNING
Applies to
Submission

Submissions with multiple exhibits require index and proper editing.

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.

Judge Dabney L. FriedrichWARNING
Applies to
First filing
Must include
caption

First filing must include party's name and full residence address in the caption.

The first filing by or on behalf of a party shall have in the caption the name and full residence address of the party.

Judge Dabney L. FriedrichWARNING
Applies to
First filing
Must include
caption

Pro se party must include telephone number in caption unless sealed.

If the party is appearing pro se, the caption shall also include the party's telephone number, unless the pro se party wishes to include that in its sealed filing.

Judge Dabney L. FriedrichWARNING
Applies to
First filing
Must include
caption

Pro se IFP filers must include each defendant's name and full address in caption.

Those filing pro se in forma pauperis must provide in the caption the name and full residence address or official address of each defendant.

Judge Dabney L. FriedrichWARNING
Applies to
Any document

Attorney-signed documents must contain attorney's name, address, phone, and D.C. Bar ID if member.

All documents signed by an attorney shall contain the name, address, telephone number, and D.C. Bar identification number of the attorney if the attorney is a member of the D.C. Bar.

Judge Dabney L. FriedrichWARNING
Applies to
Any document
Must include
caption

Every attorney listed on a document who is a D.C. Bar member must include their D.C. Bar ID.

All attorneys listed on any document who are members of the D.C. Bar must include their D.C. Bar identification numbers regardless of whether they sign the document.

Judge Dabney L. FriedrichWARNING
Applies to
Any document
Must include
caption, judge name, case number

Documents must have a heading describing nature, case number with judge initials, and exhibits must show case number.

Every document shall ... contain a heading under the caption describing the nature of the document. The case number on every document shall be followed by the initials of the judge to whom the case has been assigned. If the case has been referred to a magistrate judge, the magistrate judge’s initials shall also be shown. Any exhibit or attachment to documents shall reflect the number of the case in which it is filed.

Judge Dabney L. FriedrichWARNING
Applies to
Pleading

Only essential documents may be attached to pleadings.

No complaint, amended complaint, counterclaim, cross claim or third-party complaint shall have appended thereto any document that is not essential to determination of the action.

Judge Dabney L. FriedrichWARNING
Applies to
Document with declaration or affidavit

Filing a document with a declaration or affidavit certifies that the original signed document is in the filer's possession and available for review.

Electronically filing a document that contains a declaration, verification, certificate, sworn statement, oath or affidavit certifies that the original signed document is in the possession of the attorney or pro se party responsible for the filing and that it is available for review upon request by a party or by the Court.

Judge Dabney L. FriedrichWARNING
Applies to
Notice of filing
Must include
notice of electronic filing

Documents filed under the exception must be identified in a Notice of Filing.

Such a filing shall be made available for a party or the Court and must be identified in a Notice of Filing filed with the Court.

Judge Dabney L. FriedrichWARNING
Applies to
Motion

Motions must include a statement of points and authorities and may require asterisks in table of cases.

Each motion shall include or 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. If a table of cases is provided, counsel shall place asterisks in the margin to the left of those cases or authorities on which counsel chiefly relies.

Judge Dabney L. FriedrichWARNING
Applies to
Motion for summary judgment

For cases based solely on the administrative record, summary judgment motions and oppositions must include a statement of facts with references to the administrative record.

Paragraph (1) shall not apply to cases in which judicial review is based solely on the administrative record. In such cases, motions for summary judgment and oppositions thereto shall include a statement of facts with references to the administrative record.

Judge Dabney L. FriedrichWARNING
Applies to
Proposed order

Proposed orders, judgments, and stipulations must include a list of names and addresses of all attorneys entitled to notice.

Each proposed order, judgment and stipulation shall have appended to it or endorsed upon it a list of the names and addresses of all attorneys entitled to be notified of its entry. If a party is not represented by an attorney, the name and address of the party shall be included, unless such address does not appear on the public docket.

Judge Dabney L. FriedrichWARNING
Applies to
Appendix

Appendix must contain only copies of administrative record portions cited or relied upon in memoranda; excess material not related to issues is prohibited.

counsel shall provide the Court with an appendix containing copies of those portions of the administrative record that are cited or otherwise relied upon in any memorandum in support of or in opposition to any dispositive motion. Counsel shall not burden the appendix with excess material from the administrative record that does not relate to the issues raised in the motion or opposition.

Judge Dabney L. FriedrichWARNING
Applies to
Pretrial statement

Pretrial statements must include a list of exhibits, designation of depositions, itemization of damages, and request for other relief.

(6) The list of exhibits shall set forth a description of each exhibit the party may offer in evidence (other than those created at trial), separately identifying those which the party expects to offer and those which the party may offer if the need arises. Exhibits shall be listed by title and date. Exhibits will be presumed to be authentic unless objection to their authenticity is made at or before the final Pretrial Conference and the objection is sustained. (7) The designation of depositions shall identify each deposition or portion thereof (by page and line numbers) the party intends to offer in evidence. Any cross-designation sought by any other party pursuant to Rule 106, Federal Rules of Evidence, must be made at or before the final Pretrial Conference. (8) The itemization of damages shall set forth separately each element of damages, and the monetary amount thereof, the party claims to be entitled to recover of any other party, including prejudgment interest, punitive damages and attorneys' fees. No monetary amount need be set forth for elements of intangible damage (e.g., pain and suffering, mental anguish, or loss of consortium). (9) The request for other relief shall set forth all relief, other than judgment for a sum of money, the party claims to be entitled to receive against any other party.

Judge Dabney L. FriedrichWARNING
Applies to
Discovery response

Discovery responses must quote each interrogatory or request in full before the answer, response, or objection.

Answers, responses and objections to interrogatories and requests for admissions or for production of documents and motions to compel answers or responses, shall identify and quote each interrogatory or request in full immediately preceding the answer, response or objection thereto.

Judge Dabney L. FriedrichWARNING
Applies to
Opposition

Opposition must identify each objected item and grounds.

The opposition shall identify each item objected to, and the grounds for the objection.

Judge Dabney L. FriedrichWARNING
Applies to
Motion to retax

Motion to retax must specify the ruling of the Clerk excepted to.

A motion to retax shall specify the ruling of the Clerk excepted to and no other costs will be considered

Judge Dabney L. FriedrichWARNING
Applies to
Supplemental affidavit

Supplemental affidavits for PI require court permission.

Supplemental affidavits either to the application or the opposition may be filed only with permission of the Court.

Judge Dabney L. FriedrichWARNING
Applies to
Objections

Objections must specifically designate the order or part objected to and state the basis for the objection.

The objections shall specifically designate the order or part thereof to which objection is made, and the basis for the objection.

Judge Dabney L. FriedrichWARNING
Applies to
Objections to magistrate judge

Objections must be titled 'Objections to the Magistrate Judge’s Proposed Findings and Recommendations.'

The objections shall be denominated 'Objections to the Magistrate Judge’s Proposed Findings and Recommendations.'

Judge Dabney L. FriedrichWARNING
Applies to
Objections to magistrate judge

Objections must specifically identify the objected-to portions and the basis for each objection.

The objections shall specifically identify the portions of the proposed findings and recommendations to which objection is made and the basis for the objection.

Judge Dabney L. FriedrichWARNING
Applies to
Magistrate judge report

Magistrate judge's reports must include a notice about waiver of appeal rights for failure to file timely objections.

All magistrate judge's reports shall contain a notice substantially as follows: Failure to file timely objections to the findings and recommendations set forth in this report may waive your right of appeal from an order of the District Court adopting such findings and recommendations. See Thomas v. Arn, 474 U.S. 140 (1985).

Judge Dabney L. FriedrichWARNING
Applies to
Mediation statement

Mediation statements must include facts, legal issues, settlement options, history, and identify decision-makers and other relevant persons.

The mediation statement shall not exceed ten pages and shall outline the underlying facts of the dispute, the key legal issues in the case, possible areas of agreement and options for settlement, and the settlement history of the dispute, if any, and include such other information as may be requested by the mediator. The mediation statement shall also identify, by name and title or status: (1) the person(s) with decision-making authority, who in addition to counsel, will attend the mediation as representative(s) of the party; and (2) persons connected with either party (including insurer representatives) whose presence might substantially improve the utility of the mediation or the prospects for settlement.

Judge Dabney L. FriedrichWARNING
Applies to
Mediation report

The report on mediation must indicate whether counsel discussed mediation with their clients.

Counsel must also indicate whether they discussed mediation with their clients before filing their report.

Judge Dabney L. FriedrichWARNING
Applies to
Notice

Written notice under seal must be provided to the Clerk at least 48 hours before filing the petition.

The Secretary shall provide written notice under seal to the Clerk of the Court that a petition will likely be filed with the Court, and to the extent feasible, the notice will be provided at least 48 hours prior to filing the petition.

Judge Dabney L. FriedrichWARNING
Applies to
Petition
Must include
certificate of service

Petition must include a certificate of counsel or other proof of notice to the financial company, including contact information.

A petition shall be accompanied by a certificate of counsel or other proof satisfactory to the Court, stating (1) that actual notice of the time of filing the petition, and copies of all papers filed to date or to be presented to the Court at any hearing, have been or are being furnished to the financial company; or (2) the efforts made by the Secretary to give such notice and furnish such copies. The certificate shall also contain the name and contact information of the individual at the financial company to whom notice was given and upon whom service was effected.

Judge Dabney L. FriedrichWARNING
Applies to
Petition
Must include
proposed order

Each petition and opposition must include a proposed order.

Each petition and opposition shall be accompanied by a proposed order.

Judge Dabney L. FriedrichWARNING
Applies to
Petition for admission

Petition for admission must be on a form supplied by the Clerk and include specified information about the applicant's background and familiarity with court rules.

Each applicant for admission shall file with the Clerk at least 14 days prior to hearing thereon (unless for good cause shown the judge shall shorten the time) a written petition for admission on a form supplied by the Clerk stating: (1) applicant's residence and office addresses and office telephone number; (2) the court where and date when admitted; (3) applicant's legal training and experience; (4) whether the applicant has ever been held in contempt of court and, if so, the nature of the contempt and the final disposition thereof; (5) whether the applicant has ever been convicted of any crime (other than minor traffic offenses) or publicly reprimanded, publicly censured, suspended, disciplined or disbarred by any court, and, if so, the facts and circumstances connected therewith; and (6) that the applicant is familiar with: (i) the provisions of the Judicial Code (Title 28 U.S.C.) which pertain to the jurisdiction of and practice in the United States District Courts; (ii) the Federal Rules of Civil or Criminal Procedure; (iii) The Rules of the United States District Court for the District of Columbia; and (iv) the Rules of Professional Conduct as adopted by the District of Columbia Court of Appeals except as otherwise provided by specific rule of this Court, and that he/she will faithfully adhere thereto; and (v) D.C. Bar Voluntary Standards for Civility in Professional Conduct, adopted by the Bar on June 18, 1996 (attached as Appendix B to the Local Civil Rules).

Judge Dabney L. FriedrichWARNING
Applies to
Affidavit of sponsor

Petition must be accompanied by an affidavit from a bar member who has known the applicant for at least one year, on a form supplied by the Clerk, with exceptions for current law clerks.

The petition shall be accompanied by an affidavit of an attorney who is a member in good standing of the Bar of this Court who has known the applicant for at least one year stating when the affiant was admitted to practice in this Court and how long and under what circumstances the attorney has known the applicant and a statement of the applicant's character and experience at the bar. The affidavit shall be on a form supplied by the Clerk. The affidavit requirement does not apply to current law clerks of Judges of the U.S. Courts of the D.C. Circuit.

Judge Dabney L. FriedrichWARNING
Applies to
Complaint of misconduct

Complaints of attorney misconduct must be a clear and concise written statement of facts, subscribed and under oath or affirmed under penalty of perjury.

Any person seeking to charge an attorney subject to the Rules with any act or omission which may justify disbarment, suspension, censure, reprimand or other discipline shall do so by a clear and concise written statement of facts in support of the allegations, subscribed and under oath or affirmed under the penalty of perjury pursuant to the United States Code, Title 28, Section 1746.

Judge Dabney L. FriedrichWARNING
Applies to
Answer

Answers to misconduct complaints must be in writing, under oath, and include a list of all courts where the respondent is admitted to practice.

An Answer to a Complaint shall be in writing, subscribed and under oath or affirmed under the penalty of perjury in a form prescribed by the provisions of the United States Code, Title 28, Section 1746 and shall be accompanied by a list of all courts before which the respondent is admitted to practice.

Judge Dabney L. FriedrichWARNING
Applies to
Answer

Answer must include a list of all courts where the attorney is admitted.

shall file with the Answer a list of all courts before which the attorney is admitted to practice.

Judge Dabney L. FriedrichWARNING
Applies to
Notice of disbarment

Attorney disbarred on consent or resigned from another bar must advise this Court and submit certified copy of the order.

Any attorney admitted to practice before this Court who shall be disbarred on consent or who shall resign from the Bar of any court of the United States or from the bar of any State, Territory, District, Commonwealth or Possession of the United States while an investigation into allegations of misconduct is pending, shall so advise this Court and submit a certified or exemplified copy of the judgment or order accepting such disbarment on consent or resignation.

Judge Dabney L. FriedrichWARNING
Applies to
Objections to magistrate report

Objections must be titled 'Objections to the Magistrate Judge’s Proposed Findings and Recommendations' and must specifically identify the portions objected to and the basis.

The objections shall be denominated 'Objections to the Magistrate Judge’s Proposed Findings and Recommendations.' The objections shall specifically identify the portions of the proposed findings and recommendations to which objection is made and the basis for the objection.

Judge Dabney L. FriedrichWARNING
Applies to
Request for review

Request for review must specially designate the part of the order and the bases for review.

The request for review shall specially designate the part of the order for which review is requested and the bases for such review.

Judge Dabney L. FriedrichWARNING
Applies to
Opposition

Opposition must include a list of additional relevant documents and attach them in chronological sequence with ECF headers.

include a separate list of any additional documents filed in the Bankruptcy Court that are relevant to the motion to withdraw the reference, including the date of filing, the document number, and the title of each such document; and include the listed documents (other than documents that were filed under seal), attached to the list in chronological sequence, with each document to bear the Electronic Case Filing header showing the document number and date of filing in the Bankruptcy Court.

Judge Dabney L. FriedrichWARNING
Applies to
Motion for attorney fees

Claims for attorney's fees on appeal must be made by motion.

A claim for attorney’s fees and related nontaxable expenses incurred in an appeal must be made by motion.

Judge Dabney L. FriedrichWARNING
Applies to
Motion for attorney fees
Must include
caption

Motion for attorney's fees must bear the caption of the Bankruptcy Court.

the motion must be filed with the Clerk of the Bankruptcy Court, with the motion bearing the caption of the Bankruptcy Court

Judge Dabney L. FriedrichWARNING
Applies to
Objection

Objections and responses must include a statement of points and authorities; if a table of cases is provided, asterisks must mark chief authorities.

Objections, and responses thereto, filed under Bankruptcy Rule 9033(b) must include or be accompanied by a statement of the specific points of law and authority that support the party's position, including where appropriate a concise statement of facts. If a table of cases is provided, counsel must place asterisks in the margin to the left of those cases or authorities on which counsel chiefly relies.

Judge Dabney L. FriedrichWARNING
Applies to
Transcript order

If record includes a transcript, the designating party must order the transcript and arrange payment by the designation date.

If the record designated by any party includes a transcript of any proceeding or a part thereof, then by the date of making that designation, that party must deliver to the reporter (designated on the Bankruptcy Court's website–or authorized by order or rule of the Bankruptcy Court–to prepare the transcript) and file with the Clerk of the Bankruptcy Court a written order for the transcript and make satisfactory arrangements with the reporter for paying the cost of the transcript.

Judge Dabney L. FriedrichWARNING
Applies to
Record

Objecting party challenging evidentiary support must include relevant transcript and exhibits in the record.

If an objecting party intends to argue that a proposed finding or conclusion is unsupported by the evidence or is contrary to the evidence, that party must include in the record a transcript of all relevant testimony and copies of all relevant exhibits.

Judge Dabney L. FriedrichWARNING
Applies to
Proposed order
Must include
caption, judge name

Proposed orders for entry by the District Court must bear the District Court caption, a signature line for a District Judge, and leave the Civil Action Number blank if no docket has been opened.

The objections papers filed in the Bankruptcy Court for the District Court’s eventual attention should bear the caption of the Bankruptcy Court except that proposed orders intended for entry by the District Court should bear the caption of the District Court, bear a signature line for a United States District Judge, and, when a docket has not yet been opened in the District Court, leave the Civil Action Number blank.

Judge Dabney L. FriedrichWARNING
Applies to
Trial preparation

Special trial considerations including disability accommodations must be identified

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.

Judge Tanya S. ChutkanWARNING
Applies to
Discovery motion
Must include
sanctions warning

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

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.

Judge Tanya S. ChutkanWARNING
Applies to
Pretrial order

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

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

Judge Tanya S. ChutkanWARNING
Applies to
Removed action

Defendant removing an action must re-file answer as supplement and re-notice pending motion.

Defendant(s) removing an action to this Court must re-file any answer as a supplement to the petition and re-notice any pending motion.

Senior Judge Colleen Kollar-KotellyWARNING
Applies to
First pleading
Must include
local rule certificate

Corporate party must file a certificate of affiliations with its first pleading.

Where a corporation is a party or intervenor, counsel of record for that party or intervenor shall file a certificate listing any parent, subsidiary, or affiliate of that party or intervenor which, to the knowledge of counsel, has any outstanding securities in the hands of the public. Such certificate shall be filed with the party’s first pleading.

Senior Judge Colleen Kollar-KotellyWARNING
Applies to
Electronic filing

Attorneys must be precise in describing the type of document and requested relief in electronic filings.

Attorneys are to be precise in describing the type of document and requested relief when making electronic filings with the Court, because that description

Senior Judge Colleen Kollar-KotellyWARNING
Applies to
Exhibits

Exhibits must be edited to exclude irrelevant material and highlight pertinent portions.

Exhibits shall be properly edited to exclude irrelevant material and to direct the Court’s attention to the pertinent portions thereof.

Senior Judge Colleen Kollar-KotellyWARNING
Applies to
Brief

Each submission must include a table of authorities.

Each submission shall be accompanied by a table of cases and other authorities cited therein.

Senior Judge Colleen Kollar-KotellyWARNING
Applies to
Pleading

Every pleading must include name, address, phone number, and bar ID for attorneys.

Every pleading or paper, regardless of whether it is signed by an attorney or a pro se party, shall contain the name, address, telephone number, and, for an attorney, bar identification number. See LCvR 5.1(e).

Senior Judge Colleen Kollar-KotellyWARNING
Applies to
Exhibits

In agency review cases, parties must provide a joint appendix of cited administrative record portions.

In accordance with Local Civil Rule 7(n), the parties shall provide the Court with a joint appendix containing copies of those portions of the administrative record that are cited or otherwise relied upon in any memorandum in support of, or in opposition to, a motion for summary judgment.

Senior Judge Colleen Kollar-KotellyWARNING
Applies to
Motion

Parties must provide precise record citations; court may disregard uncited materials.

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)(3).

Senior Judge Colleen Kollar-KotellyWARNING
Applies to
Motion

Statement of material facts must be short, concise, in numbered paragraphs with one fact per paragraph.

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.

Senior Judge Colleen Kollar-KotellyWARNING
Applies to
Opposition

Response to statement of facts must use correspondingly numbered paragraphs and indicate admission or denial, with specificity for partial admissions.

The party responding to a statement of material facts must respond to each paragraph with a correspondingly numbered paragraph, indicating whether that paragraph is admitted or denied. If a paragraph is admitted only in part, the party must specifically identify which parts are admitted and which parts are denied.

Senior Judge Colleen Kollar-KotellyWARNING
Applies to
Opposition

Response must include relevant information in corresponding paragraphs; additional facts must be in consecutively numbered paragraphs at the end; opponent must respond to additional facts.

The responding party must include any information relevant to its response in its correspondingly numbered paragraph, with specific citations to the record. However, if the responding party has additional facts that are not directly relevant to its response, it must identify such facts in consecutively numbered paragraphs at the end of its responsive statement of facts. If additional factual allegations are made, the opponent must file a responsive statement of its own.

Senior Judge Colleen Kollar-KotellyWARNING
Applies to
Complaint

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

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.

Senior Judge Emmet G. SullivanWARNING
Applies to
Motion for summary judgment

Motions to dismiss presenting matters outside the pleadings may be converted to summary judgment motions, requiring compliance with summary judgment instructions.

If a motion to dismiss presents matters outside of the pleadings, it may be converted to a motion for summary judgment. In this situation, all parties must comply with the instructions set forth below regarding motions for summary judgment.

Senior Judge Emmet G. SullivanWARNING
Applies to
Counter statement of disputed facts

Additional facts not directly relevant to a specific paragraph must be listed in consecutively numbered rows in the right column at the end of the responsive statement.

If the opposing party has additional facts that are not directly relevant 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.

Senior Judge Emmet G. SullivanWARNING
Applies to
Counter statement of disputed facts

At the end of the Counter-Statement, the opposing party must list material facts for which it contends there is a genuine issue for trial.

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.

Senior Judge Emmet G. SullivanWARNING
Applies to
Opposition
Must include
opposition required

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

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.

Senior Judge Reggie B. WaltonWARNING
Applies to
Voir dire questions

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

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.

Senior Judge Reggie B. WaltonWARNING
Applies to
Supplemental authorities
Must include
certificate section

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).

Judge Ana C. ReyesINFO
Applies to
Motion
Must include
oral argument request

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.

Judge Ana C. ReyesINFO
Applies to
Any document
Must include
local rule certificate

Signing an attorney certifies bar membership or compliance with admission rules.

By signing a document that is presented to the Court, an attorney is certifying that the attorney, and all other attorneys appearing with the attorney on the document, are members of, or have a pending application for admission to, the Bar of this Court, or have complied with LCvR 83.2(c) or (d), or are covered by LCvR 83.2(e) as counsel for the United States.

Judge Dabney L. FriedrichINFO
Applies to
Verification

Unsworn declarations under penalty of perjury may be used in lieu of sworn statements, using specified forms.

Whenever any matter is required or permitted by law or by rule to be supported by the sworn written statement of a person (other than a deposition, oath of office, or oath required to be taken before a specified official other than a notary public), the matter may, with the same force and effect, be supported by the unsworn declaration, certificate, verification, or statement, in writing of such person which is subscribed as true under penalty of perjury, and dated, in substantially the following form: (1) If executed without the United States 'I declare (or certify, verify, or state) under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on (date). (Signature)'. (2) If executed within the United States, its territories, possessions, or commonwealths: 'I declare (or certify, verify, or state) under penalty of perjury that the foregoing is true and correct. Executed on (date). (Signature)'.

Judge Dabney L. FriedrichINFO
Applies to
Notice of appearance
Must include
caption

Attorneys may enter an appearance by signing a pleading or filing a notice with contact and bar ID.

An attorney eligible to appear may enter an appearance in a civil action by signing any pleading described in Fed. R. Civ. P. 7(a), or by filing a written notice of entry of an appearance listing the attorney's correct address, telephone number and bar identification number.

Judge Dabney L. FriedrichINFO
Applies to
Notice of withdrawal
Must include
caption

Before trial, an attorney may withdraw by filing a signed notice with the party's consent if another attorney has appeared.

If no trial date has been set, an attorney may withdraw an appearance in a civil action by filing a notice of withdrawal signed by the attorney and the party represented, if another attorney has previously entered an appearance on behalf of the party.

Judge Dabney L. FriedrichINFO
Applies to
Petition
Must include
caption

Petition for admission must include residence/office address, court and date of admission, and legal training/experience.

Each applicant for admission shall file with the Clerk at least 14 days prior to hearing thereon (unless for good cause shown the judge shall shorten the time) a written petition for admission on a form supplied by the Clerk stating: (1) applicant's residence and office addresses and office telephone number; (2) the court where and date when admitted; (3) applicant's legal training and experience;

Judge Dabney L. FriedrichINFO
Applies to
Proposed order

Proposed orders, judgments, and stipulations must include a list of names and addresses of all attorneys (or unrepresented parties) entitled to notice.

Each proposed order, judgment and stipulation shall have appended to it or endorsed upon it a list of the names and addresses of all attorneys entitled to be notified of its entry. If a party is not represented by an attorney, the name and address of the party shall be included.

Judge Dabney L. FriedrichINFO
Applies to
Verification

Unsworn declarations under penalty of perjury may substitute for sworn statements, using specified language.

Whenever any matter is required or permitted by law or by rule to be supported by the sworn written statement of a person (other than a deposition, oath of office, or oath required to be taken before a specified official other than a notary public), the matter may, with the same force and effect, be supported by the unsworn declaration, certificate, verification, or statement, in writing of such person which is subscribed as true under penalty of perjury, and dated, in substantially the following form: (i) If executed without the United States: "I declare (or certify, verify, or state) under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on (date). (Signature)". (ii) If executed within the United States, its territories, possessions, or commonwealths: "I declare (or certify, verify, or state) under penalty of perjury that the foregoing is true and correct. Executed on (date). (Signature)".

Judge Dabney L. FriedrichINFO
Applies to
Agreed statement

Parties may submit an agreed statement of facts as the record, subject to bankruptcy judge approval and certification.

The parties may submit an agreed statement of facts as a proposed record. If the statement is accurate, it–together with any additions that the Bankruptcy Court may consider necessary to a full presentation of the issues–must be approved by the bankruptcy judge and then certified as the record, and it shall constitute the record unless the District Judge undertaking de novo review directs otherwise.

Judge Dabney L. FriedrichINFO
Applies to
Statement

Bankruptcy Court may file a statement recommending record items.

The Bankruptcy Court may file a statement designating items that it believes support its proposed findings of fact and conclusions of law and that it recommends that the District Court direct be included in the record.

Judge Dabney L. FriedrichINFO
Applies to
Trial
Must include
trial date, trial time, trial location

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

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

Judge Tanya S. ChutkanINFO
Applies to
Joint pretrial statement
Must include
exhibit stipulation

Parties should stipulate to admissibility of exhibits when possible.

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.

Judge Tanya S. ChutkanINFO
Applies to
Joint pretrial statement
Must include
relevant exhibits

Counsel should be judicious in selecting relevant exhibits.

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

Judge Tanya S. ChutkanINFO
Applies to
Settlement
Must include
settlement evaluation

Settlement evaluation and alternative dispute resolution encouraged at any time

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.

Judge Timothy J. KellyINFO
Applies to
Declaration

Filing a document with a declaration, etc. certifies that the original signed document is in the filer's possession and available for review.

Electronically filing a document that contains a declaration, verification, certificate, sworn statement, oath or affidavit certifies that the original signed document is in the possession of the attorney or pro se party responsible for the filing and that it is available for review upon request by a party or by the Court. LCvR 5.4(b)(5)

Senior Judge Colleen Kollar-KotellyINFO
Applies to
Alternative dispute resolution
Must include
adr

All cases presumptively referred to alternative dispute resolution.

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

Senior Judge Reggie B. WaltonINFO
Applies to
Juror notebook
Must include
notebook provided

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

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.

Senior Judge Reggie B. WaltonINFO
Applies to
Jury selection procedure
Must include
judge name, case number

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

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.

Senior Judge Reggie B. WaltonINFO
Applies to
Voir dire form
Must include
judge name, case number

Jurors complete voir dire forms indicating affirmative responses.

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.

Senior Judge Reggie B. WaltonINFO
Applies to
Individual voir dire
Must include
judge name, case number

Individual questioning of jurors after collective voir dire.

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

Senior Judge Reggie B. WaltonINFO
Applies to
Peremptory strikes multiple defendants
Must include
judge name, case number

Multiple defendants receive equal number of peremptory strikes when practicable.

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

Senior Judge Reggie B. WaltonINFO
Common questions about District of Columbia document filing requirements

What must be included with discoverable evidence filings in District of Columbia?

The rule identifies required filing content or certificates. The government must produce discoverable evidence in a readily usable form.

View ruleSource: page 5, section ORDER

What must be included with documents filings in District of Columbia?

The rule identifies required filing content or certificates. Document production must either follow usual business order or be clearly organized and labeled.

View ruleSource: page 5, section ORDER

What must be included with electronically stored information filings in District of Columbia?

The rule identifies required filing content or certificates. Electronically stored information must be produced in its ordinary form unless that form is not readily usable, then in a readily usable form.

View ruleSource: page 5, section ORDER

What must be included with tangible format information filings in District of Columbia?

The rule identifies required filing content or certificates. Information already memorialized in a tangible format must be produced in that same format.

View ruleSource: page 5, section ORDER

What must be included with summary filings in District of Columbia?

The rule identifies required filing content or certificates. Any summary-format production must be detailed and specific enough for the defense to assess relevance and usefulness.

View ruleSource: page 6, section ORDER

What must be included with amended submission filings in District of Columbia?

The rule identifies required filing content or certificates. Amended submissions must include a redline comparing the original and amended pleading.

View ruleSource: page 3, section 6. Amended Submissions