District of Delaware Local Rules and Judge Filing Requirements

Concise statement of facts must have numbered paragraphs and record citations.

Markman briefs must include a proposed construction for each disputed term, even if the term should be given its plain and ordinary meaning.

All hearing agendas must include hyperlinks to all referenced filings.

The case management statement must state whether the plaintiff expects to request attorneys' fees.

Agendas for in-person court proceedings must include specified text regarding in-person attendance requirements, remote participation options, and references to relevant chambers procedures and court eCourt appearance resources.

Opposition letters in discovery disputes are limited to 3 pages and must use 12-point font.

Letters related to discovery disputes (moving and response) must not exceed 5 pages.

Seeking party must file 3-page letter outlining dispute and position.

Discovery dispute letters are limited to 5 pages for both moving and opposition.

Plaintiff's opening brief (max 7,500 words) must be served but not filed.

Exhibits and attachments must be separated by tabs.

All proposed orders must have 4 inches of blank space at the end and must not include a signature line or date line.

All hearings must be noticed for 10:00 a.m. on the listed dates unless otherwise instructed.

Revised proposed orders must be provided to the Court in clean and redline form at least one hour before the hearing.

Hard copies must comply with formatting requirements in paragraphs 10 and 14.

Parties must provide two courtesy copies of all letters, briefs, and supporting documents to the Court; also applies to sealed papers.

All agendas (including amended agendas) must be emailed to chambers upon filing.

Only hard copies of Notice of Completion of Briefing binders and trial exhibits may be delivered to chambers, unless otherwise directed.

Two hard copies required within 1 hour of e-filing.

For notice of completion of briefing, email hyperlinked notice and deliver two physical binders.

Technology tutorials must be submitted on or before the date the Joint Claim Construction Brief is filed.

Remote appearance registration must be completed by 4:00 PM Eastern Time the business day prior to the hearing, unless otherwise noticed.

The parties are expected to begin discovery before the Rule 16 conference.

Proposed voir dire, jury instructions, and special verdict forms must be filed 7 calendar days before the Pretrial Conference.

Agendas must be filed and emailed, and hearing binders delivered, by noon ET two business days before hearing.

The Joint Claim Construction Chart must be emailed to Magistrate Judge Hatcher's chambers at Idh_civil@ded.uscourts.gov simultaneously with filing.

Parties must contact Chambers to advise of unresolved discovery disputes unless a pretrial order provides otherwise.

Judge Wolson's Policies and Procedures specify required keywords to use when emailing Chambers, which counsel and pro se parties must acknowledge.

Joint Claim Construction Chart must be emailed to cfc_civil@ded.uscourts.gov simultaneously with filing.

Contact chambers if there will be a delay in filing or delivering agenda/binder.

Discovery motions require a pre-motion conference procedure: file a motion for teleconference, then submit a 3-page letter with proposed order and exhibits at least 72 hours before the conference.

Contact Case Manager to schedule in-person conference for discovery disputes.

Discovery disputes require a pre-motion letter (max 5 pages) with 48-hour response, after which court decides on conference or motion practice.

Pre-motion letter (max 3 pages) required for discovery disputes, with 7-day and 5-day filing deadlines.

Before filing a Rule 12 motion, parties must contact opposing counsel for a substantive discussion and an opportunity to cure pleading deficiencies.

Separate briefing on in limine requests is prohibited.

Multiple motions relying on different facts must be filed separately

All exhibits e-filed in Judge Noreika's cases must be grouped into one PDF when possible, or into as few PDFs as possible if the single PDF is too large.

Multiple co-parties must file joint motions unless clear conflicts exist.

Consensual adjournments of relief-from-stay motions require the debtor to make a mortgage payment by the payment deadline; otherwise the court may grant the motion upon certification.

Claim construction hearing: no testimony without prior approval, max 3 hours total.

Objections to expert reports must be raised within one week of submission.

Requests to reschedule the Rule 16 conference must be made as early as possible and based on a pre-existing commitment.

Proposed orders in Chapter 11 and Chapter 7 business cases must be uploaded for electronic order processing.

Proposed orders must be filed electronically, with all related docket numbers in the caption and exhibits uploaded as separate attachments.

For fee application binders, email hyperlinked index or consolidated searchable PDF.

Proposed orders must be filed electronically; non-electronic proposed orders are not accepted by Judge Shannon.

Exhibits must be submitted as separate ECF documents; a combined 'Exhibits' filing will be struck.

Parties must seek leave of Court to file documents under seal unless a protective order is in place.

Sealed documents require 1 original + 2 copies to Clerk; electronic redacted version within 7 days.

Redacted version of sealed documents must be filed electronically within 7 days.

Claim construction briefs must be served but not filed individually; they are later combined into a joint brief.

Parties may consent to email service of pleadings and discovery under FRCP 5(b)(2)(E); non-consenting parties must explain their reasons.

Exhibits intended for use at a hearing must be emailed in PDF format to all relevant parties and chambers no later than 24 hours before the hearing.

Newer attorneys (practicing fewer than 7 years) are encouraged to participate in oral arguments; upon notice, judge grants oral argument if practicable, considers extra time, and allows experienced counsel to assist.

Judge Wolson encourages assigning court presentations to less-experienced attorneys and may permit two lawyers to argue if requested in advance.

Pro hac vice motions will be denied if no filing fee is submitted.