Judge Gregory B. Williams
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Filings (Discovery Letter)
Required
Filings (Pretrial Order)
Required
Filings (Brief, Appendix, Exhibit, Declaration, Affidavit, Sealed Document)
Required • Binding: Tabbed Three Ring
Filings (Letter)
Required
Filings (Exhibits)
Required
Filings (All filings)
Required • Binding: Stapled
Filings (Joint Proposed Final Pretrial Order)
Required
Filings (Jury Instructions, Voir Dire, Special Verdict Forms)
Required
Communication
Letter Ecf
Chambers
Chambers
Chambers
Detailed Drafting Rules
Seeking party must file 3-page letter 48 hours before discovery conference
On a date to be set by separate order, generally not less than forty-eight (48) hours prior to the conference, the party seeking relief shall file with the Court a letter, not to exceed three (3) pages, outlining the issues in dispute and its position on those issues.
Pre-Motion Conference
A pre-motion conference is mandatory before filing. You must submit a letter first.
Letter Requirements
Opposing party may file 3-page opposition letter before discovery conference
On a date to be set by separate order, but generally application for relief may file a letter, not to exceed three (3) pages, outlining that party's reasons for its opposition.
Pre-Motion Conference
Check specific requirements before filing.
Letter Requirements
Motions to amend require 3-page letter with proposed pleading and blackline
Any motion to amend (including a motion for leave to amend) a pleading shall NOT be accompanied by an opening brief but shall, instead, be accompanied by a letter, not to exceed three (3) pages, describing the basis for the requested relief, and shall attach the proposed amended pleading as well as a "blackline" comparison to the prior pleading.
Pre-Motion Conference
A pre-motion conference is mandatory before filing. You must submit a letter first.
Letter Requirements
Opposition to motions to amend must file 5-page response within 7 days
Within seven (7) days after the filing of a motion in compliance with this Order, any party opposing such a motion shall file a responsive letter, not to exceed five (5) pages.
Pre-Motion Conference
Check specific requirements before filing.
Letter Requirements
Motions to strike must be accompanied by a 3-page letter, not an opening brief.
Any motion to strike any pleading or other document shall NOT be accompanied by an opening brief but shall, instead, be accompanied by a letter, not to exceed three (3) pages, describing the basis for the requested relief, and shall attach the document to be stricken.
Pre-Motion Conference
A pre-motion conference is mandatory before filing. You must submit a letter first.
Letter Requirements
Opposition to motions to strike must be filed within 7 days as a 5-page letter.
Within seven (7) days after the filing of a motion in compliance with this Order, any party opposing such a motion shall file a responsive letter, not to exceed five (5) pages.
Reply to motions to strike must be filed within 3 days as a 2-page letter, with teleconference request.
Within three (3) days thereafter, the moving party may file a reply letter, not to exceed two (2) pages, and, by this same date, the parties shall file a letter requesting a teleconference to address the motion to strike.
Plaintiff's opening brief limited to 5,000 words (served but not filed)
Plaintiff shall serve, but not file, its opening brief, not to exceed 5,000 words, on .
Defendant's answering brief limited to 7,500 words (served but not filed)
Defendant shall serve, but not file, its answering brief not to exceed 7,500 words, on .
Plaintiff's reply brief limited to 5,000 words (served but not filed)
Plaintiff shall serve, but not file, its reply brief, not to exceed 5,000 words, on .
Defendant's sur-reply brief limited to 2,500 words (served but not filed)
Defendant shall serve, but not file its sur-reply brief, not to exceed 2,500 words, on .
Parties must notify court by joint letter about testimony request and time allocation for claim construction hearing
The parties shall notify the Court, by joint letter submission, no later than the date on which their answering claim construction briefs are due: (i) whether they request leave to present testimony at the hearing; and (ii) the amount of time they are requesting be allocated to them for the hearing.
Letter via ECF
Direct to: Chambers
- Advance Notice Required
- Hours
- Status Inquiries
Interim status report required by joint letter on specified date
On , counsel shall submit a joint letter to the Court with an interim report of the matters in issue and the progress of discovery to date.
Letter via ECF
Direct to: Chambers
- Advance Notice Required
- Hours
- Status Inquiries
In limine requests limited to 3 pages of argument.
Each in limine request may be supported by a maximum of three (3) pages of argument, may be opposed by a maximum of three
Party seeking discovery relief limited to 3-page letter.
On a date to be set by separate order, generally not less than forty-eight (48) hours prior to the conference, the party seeking relief shall file with the Court a letter, not to exceed three (3) pages, outlining the issues in dispute and its position on those issues. On a date to be set by separate order, but generally
Opposing party in discovery dispute limited to 3-page response letter.
application for relief may file a letter, not to exceed three (3) pages, outlining that party's reasons for its opposition.
Motions to amend require 3-page letter instead of opening brief, with proposed amended pleading and blackline comparison.
Any motion to amend (including a motion for leave to amend) a pleading shall NOT be accompanied by an opening brief but shall, instead, be accompanied by a letter, not to exceed three (3) pages, describing the basis for the requested relief, and shall attach the proposed amended pleading as well as a "blackline" comparison to the prior pleading.
Opposition to motion to amend limited to 5-page responsive letter, due within 7 days.
Within seven (7) days after the filing of a motion in compliance with this Order, any party opposing such a motion shall file a responsive letter, not to exceed five (5) pages.
Motions to amend must include proposed amended pleading and blackline comparison; opening brief not permitted.
Any motion to amend (including a motion for leave to amend) a pleading shall NOT be accompanied by an opening brief but shall, instead, be accompanied by a letter, not to exceed three (3) pages, describing the basis for the requested relief, and shall attach the proposed amended pleading as well as a "blackline" comparison to the prior pleading.
Document Type
Motion
Motions to strike must be accompanied by a letter (max 3 pages) instead of an opening brief, and must attach the document to be stricken.
Any motion to strike any pleading or other document shall NOT be accompanied by an opening brief but shall, instead, be accompanied by a letter, not to exceed three (3) pages, describing the basis for the requested relief, and shall attach the document to be stricken.
Pre-Motion Conference
A pre-motion conference is mandatory before filing. You must submit a letter first.
Letter Requirements
Reply to motion to strike opposition must be filed within 3 days, not exceeding 2 pages.
Within three (3) days thereafter, the moving party may file a reply letter, not to exceed two (2) pages
Motions to strike must attach the document to be stricken.
Any motion to strike any pleading or other document shall NOT be accompanied by an opening brief but shall, instead, be accompanied by a letter, not to exceed three (3) pages, describing the basis for the requested relief, and shall attach the document to be stricken.
Document Type
Motion To Strike
Joint Claim Construction Chart must be in Word format and emailed to gbw_civil@ded.uscourts.gov simultaneously with filing.
The Joint Claim Construction Chart, in Word format shall be e-mailed simultaneously with filing to gbw_civil@ded.uscourts.gov.
Direct to: Chambers
Plaintiff's opening claim construction brief limited to 5,000 words.
Plaintiff shall serve, but not file, its opening brief, not to exceed 5,000 words
Defendant's answering claim construction brief limited to 7,500 words.
Defendant shall serve, but not file, its answering brief not to exceed 7,500 words
Plaintiff's reply claim construction brief limited to 5,000 words.
Plaintiff shall serve, but not file, its reply brief, not to exceed 5,000 words
Defendant's sur-reply claim construction brief limited to 2,500 words.
Defendant shall serve, but not file its sur-reply brief, not to exceed 2,500 words
Motions in limine are limited to 3 pages of argument, 3 pages of opposition, and 1 page of reply per side.
Each SIDE shall be limited to three (3) in limine requests, unless otherwise permitted by the Court. The in limine request and any response shall contain the authorities relied upon; each in limine request may be supported by a maximum of three (3) pages of argument, may be opposed by a maximum of three (3) pages, and the moving party may file a maximum of one (1) additional page in reply in support of its request. If more than one party is supporting or opposing an in limine request, such support or opposition shall be combined in a single three (3) page submission (and, if the moving party, a single one (1) page reply), unless otherwise ordered by the Court. No separate briefing shall be submitted on in limine requests, unless otherwise permitted by the Court.
All trial correspondence must go through the GBW Civil email mailbox.
Any and all trial correspondence should be via Delaware counsel through the GBW Civil mailbox (gbw_civil@ded.uscourts.gov).
Objections to evidence must be emailed to chambers by 6:00 a.m. on the trial day.
Delaware counsel, on behalf of the parties, shall notify the Court by email (gbw_civil@ded.uscourts.gov) by 6:00 a.m. of any objections to demonstratives, witnesses, deposition designations, or other evidence to be presented that trial day.
Direct to: Chambers
- Advance Notice Requiredby 6:00 a.m. on trial day
Parties must email revised proposed jury instructions and verdict sheet to chambers before the charge conference.
Prior to the charge conference, the parties shall file and email chambers (gbw_civil@ded.uscourts.gov) revised versions of their proposed final jury instructions and verdict sheet.
Direct to: Chambers
Parties must email glossary, witness list, and pronunciation guide to court reporter and chambers at least 3 business days before trial.
At least three (3) business days before the start of the jury trial, the parties shall email the court reporter and chambers a glossary of terms and names, a list of possible witnesses who may appear at trial, and a list of phonetic pronunciation of attorneys' and witnesses' names.
Direct to: Chambers
Daubert motions subject to dispositive motion page limits.
Briefing on such motions is subject to the page limits set out in connection with briefing of case dispositive motions.
Party seeking discovery relief must file 3-page letter at least 48 hours before conference.
On a date to be set by separate order, generally not less than forty-eight (48) hours prior to the conference, the party seeking relief shall file with the Court a letter, not to exceed three (3) pages, outlining the issues in dispute and its position on those issues.
Pre-Motion Conference
A pre-motion conference is mandatory before filing. You must submit a letter first.
Letter Requirements
Motion to amend requires 3-page letter instead of brief.
Any motion to amend (including a motion for leave to amend) a pleading shall NOT be accompanied by an opening brief but shall, instead, be accompanied by a letter, not to exceed three (3) pages, describing the basis for the requested relief, and shall attach the proposed amended pleading as well as a "blackline" comparison to the prior pleading.
Document Type
Motion To Amend
Motion to amend letter limited to 3 pages.
Any motion to amend... shall, instead, be accompanied by a letter, not to exceed three (3) pages
Opposition letter to motion to amend limited to 5 pages.
Within seven (7) days after the filing of a motion in compliance with this Order, any party opposing such a motion shall file a responsive letter, not to exceed five (5) pages.
Reply letter to motion to amend limited to 2 pages.
Within three (3) days thereafter, the moving party may file a reply letter, not to exceed two (2) pages
Motion to strike requires 3-page letter instead of brief.
Any motion to strike any pleading or other document shall NOT be accompanied by an opening brief but shall, instead, be accompanied by a letter, not to exceed three (3) pages, describing the basis for the requested relief, and shall attach the document to be stricken.
Document Type
Motion To Strike
Motion to strike letter limited to 3 pages.
Any motion to strike... shall, instead, be accompanied by a letter, not to exceed three (3) pages
Word limits for claim construction briefs: opening/reply 5,000 words, answering 7,500 words, sur-reply 2,500 words.
opening brief, not to exceed 5,000 words, on . Defendant shall serve, but not file, its answering brief not to exceed 7,500 words, on . Plaintiff shall serve, but not file, its reply brief, not to exceed 5,000 words, on . Defendant shall serve, but not file its sur-reply brief, not to exceed 2,500 words, on .
Claim construction briefs must be served but not filed with the court.
Defendant shall serve, but not file, its answering brief not to exceed 7,500 words, on . Plaintiff shall serve, but not file, its reply brief, not to exceed 5,000 words, on . Defendant shall serve, but not file its sur-reply brief, not to exceed 2,500 words, on .
Document Type
Claim Construction Brief
Summary judgment motions require 6-page concise statement of essential facts.
Any motion for summary judgment shall be accompanied by a separate concise statement, not to exceed six (6) pages, which details each material fact which the moving party contends is essential for the Court's resolution of the summary judgment motion (not the entire case) and as to which the moving party contends there is no genuine issue to be tried.
Document Type
Summary Judgment Motion
Opposing party's response to concise statement limited to 6 pages.
Any party opposing the motion shall include with its opposing papers a response to the moving party’s concise statement, not to exceed six (6) pages, which admits or disputes the facts set forth in the moving party’s concise statement on a paragraph-by-paragraph basis.
Opposing party may include separate concise statement limited to 4 pages.
The party opposing the motion may also include with its opposing papers a separate concise statement, not to exceed four (4) pages, which sets forth material facts as to which the opposing party contends there is a genuine issue to be tried.
Moving party's reply response limited to 4 pages.
The moving party shall include with its reply papers a response to the opposing party’s concise statement of facts, not to exceed four (4) pages, on a paragraph-by-paragraph basis.
Combined page limits for case dispositive motions: 40 pages for answering briefs, 20 pages for reply briefs.
opening briefs, a combined total of 40 pages for all answering briefs, and a combined total of 20 pages for all reply briefs regardless of the number of case dispositive motions that are filed.
Daubert motions increase page limits to 50 pages for opening/answering briefs, 25 pages for reply briefs per side.
In the event that a party files, in addition to a case dispositive motion, a Daubert motion to exclude or preclude all or any portion of an expert’s testimony, the total amount of pages permitted for all case dispositive and Daubert motions shall be increased to 50 pages for all opening briefs, 50 pages for all answering briefs, and 25 pages for all reply briefs for each SIDE.
Total briefing limit of 250 pages for all case dispositive and Daubert motions across related cases.
The parties must work together to ensure that the Court receives no more than a total of 250 pages (i.e., 50 + 50 + 25 regarding one side’s motions, and 50 + 50 + 25 regarding the other side’s motions) of briefing on all case dispositive motions and Daubert motions that are covered by this scheduling order and any other scheduling order entered in any related case that is proceeding on a consolidated or coordinated pretrial schedule.
Motions in limine must be included in proposed pretrial order with page limits and combined submissions.
Motions in limine shall not be separately filed. All in limine requests and responses thereto shall be set forth in the proposed pretrial order. Each SIDE shall be limited to three (3) in limine requests, unless otherwise permitted by the Court. The in limine request and any response shall contain the authorities relied upon; each in limine request may be supported by a maximum of three (3) pages of argument, may be opposed by a maximum of three (3) pages of argument, and the side making the in limine request may add a maximum of one (l) additional page in reply in support of its request. If more than one party is supporting or opposing an in limine request, such support or opposition shall be combined in a single three (3) page submission (and, if the moving party, a single one (1) page reply), unless otherwise ordered by the Court. No separate briefing shall be submitted on in limine requests, unless otherwise permitted by the Court.
Filing Strategy
Bundling Policy
Motions in limine must be included in proposed pretrial order, not separately filed
In limine requests limited to 3 per side, with 3-page support, 3-page opposition, and 1-page reply.
Motions in limine shall not be separately filed. All in limine requests and responses thereto shall be set forth in the proposed pretrial order. Each SIDE shall be limited to three (3) in limine requests, unless otherwise permitted by the Court. The in limine request and any response shall contain the authorities relied upon; each in limine request may be supported by a maximum of three (3) pages of argument, may be opposed by a maximum of three (3) pages of argument, and the side making the in limine request may add a maximum of one (l) additional page in reply in support of its request. If more than one party is supporting or opposing an in limine request, such support or opposition shall be combined in a single three (3) page submission (and, if the moving party, a single one (1) page reply), unless otherwise ordered by the Court. No separate briefing shall be submitted on in limine requests, unless otherwise permitted by the Court.
Post-trial briefs limited to 20 pages (opening/answering) and 10 pages (reply).
Unless otherwise ordered by the Court, all SIDES are limited to a maximum of 20 pages of opening briefs, 20 pages of answering briefs, and 10 pages of reply briefs relating to any post-trial motions filed by that side, no matter how many such motions are filed.