Judge Richard G. Andrews
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Filings (All filings)
Required
Filings (Brief, Appendix, Exhibits, Declarations, Affidavits)
Required
Filings (Chambers Copy)
Required
Filings (Brief)
Required
Adjournments
Must Include
- 1Reason For Request
- 2Original Date
- 3Proposed New Dates
Communication
Chambers
Detailed Drafting Rules
Word count alternative to page limits: 250 words per page with certification required.
For all double-spaced submissions where there are page limits specified by Order or Rule, the parties may alternatively use a word count limit. The word count limit is 250 words per page and shall not exceed the total word count for the page limit specified in the Order or Rule. For example, if the page limit specified is 20 pages, the maximum number of words for the submission is 5,000 (20 x 250). To the extent that a word count is used, a certification as to the total number of words must be attached as part of the submission.
Parties may use word count (250 words per page) as an alternative to page limits for double-spaced submissions.
For all double-spaced submissions where there are page limits specified by Order or Rule, the parties may alternatively use a word count limit. The word count limit is 250 words per page and shall not exceed the total word count for the page limit specified in the Order or Rule. For example, if the page limit specified is 20 pages, the maximum number of words for the submission is 5,000 (20 x 250).
Certification of total word count is required when using word count limit.
To the extent that a word count is used, a certification as to the total number of words must be attached as part of the submission.
Document Type
Brief
Discovery dispute letters limited to 3 pages; 48-hour and 24-hour filing deadlines.
By no later than forty-eight hours prior to the hearing, the party seeking relief shall file with the Court a letter, not to exceed three pages, outlining the issues in dispute and its position on those issues. By no later than twenty-four hours prior to the hearing, any party opposing the application for relief may file a letter, not to exceed three pages, outlining that party’s reasons for its opposition.
In limine requests must be included in proposed pretrial order with page limits.
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 party shall be limited to three 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 pages of argument and may be opposed by a maximum of three pages of argument, and the party making the in limine request may add a maximum of one 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 page submission (and, if the moving party, a single one page reply). No separate briefing shall be submitted on in limine requests, unless otherwise permitted by the Court.
Filing Strategy
Bundling Policy
In limine requests must be included in proposed pretrial order, not separately filed
In limine requests limited to 3 per party with 3-page argument limits.
Each party shall be limited to three 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 pages of argument and may be opposed by a maximum of three pages of argument, and the party making the in limine request may add a maximum of one additional page in reply in support of its request.
Party seeking relief in discovery dispute must file letter not exceeding 3 pages at least 48 hours before hearing.
Unless otherwise ordered, by no later than forty-eight hours prior to the hearing, the party seeking relief shall file with the Court a letter, not to exceed three pages, outlining the issues in dispute and its position on those issues.
Opposing party in discovery dispute may file letter not exceeding 3 pages at least 24 hours before hearing.
By no later than twenty-four hours prior to the hearing, any party opposing the application for relief may file a letter, not to exceed three pages, outlining that party's reasons for its opposition.
In limine requests are limited to 3 pages of argument, opposition limited to 3 pages, and reply limited to 1 page.
each in limine request may be supported by a maximum of three pages of argument and may be opposed by a maximum of three pages of argument, and the party making the in limine request may add a maximum of one additional page in reply in support of its request.
Pre-motion letter (max 3 pages) required for discovery disputes, with 7-day and 5-day filing deadlines.
Should counsel find they are unable to resolve a discovery matter or a dispute relating to a protective order, the parties involved in the discovery matter or protective order dispute shall contact the Court’s Case Manager to schedule an in-person conference/argument. Unless otherwise ordered, by no later than seven business days prior to the conference/argument, any party seeking relief shall file with the Court a letter, not to exceed three pages, outlining the issues in dispute and its position on those issues. By no later than five business days prior to the conference/argument, any party opposing the application for relief may file a letter, not to exceed three pages, outlining that party’s opposition.
Pre-Motion Conference
A pre-motion conference is mandatory before filing. You must submit a letter first.
Letter Requirements
Briefing Schedule
Open: 7d • Opp: 5d • Reply: d
Discovery-related motions must be emailed in Word format to rga_civil@ded.uscourts.gov simultaneously with filing.
order shall be e-mailed, in Word format, simultaneously with filing to rga_civil@ded.uscourts.gov.
DOCX
Plaintiff's opening brief (max 7,500 words) must be served but not filed.
Plaintiff shall serve, but not file, its opening brief, not to exceed 7,500 words, on ________.
Plaintiff's reply brief (max 5,000 words) must be 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 (max 2,500 words) must be served but not filed.
Defendant shall serve, but not file its sur-reply brief, not to exceed 2,500 words, on ________.
Each disputed term must have a table showing term, competing constructions, and dispute significance. Tables don't count against word limits.
For each term in dispute, there should be a table or the like setting forth the term in dispute, the parties’ competing constructions, and why resolution of the dispute matters. The table does not count against the word limits.
Document Type
Joint Claim Construction Brief
Each party limited to 3 in limine requests with strict page limits for arguments and replies.
Each party shall be limited to three 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 pages of argument and may be opposed by a maximum of three pages of argument, and the party making the in limine request may add a maximum of one 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 page submission (and, if the moving party, a single one page reply). No separate briefing shall be submitted on in limine requests, unless otherwise permitted by the Court.
Joint Claim Construction Chart must be emailed to rga_civil@ded.uscourts.gov simultaneously with filing.
The Joint Claim Construction Chart, in Word format, shall be e-mailed simultaneously with filing to rga_civil@ded.uscourts.gov.
Discovery dispute letters seeking relief are limited to 3 pages and must be filed 7 business days before the conference.
By no later than seven business days prior to the conference/argument, any party seeking relief shall file with the Court a letter, not to exceed three pages, outlining the issues in dispute and its position on those issues.
Opposition letters in discovery disputes are limited to 3 pages and must be filed 5 business days before the conference.
By no later than five business days prior to the conference/argument, any party opposing the application for relief may file a letter, not to exceed three pages, outlining that party's opposition.
Discovery disputes require contacting the Case Manager to schedule a conference, with pre-conference letters (max 3 pages) due 7 days for moving party and 5 days for opposition.
Should counsel find they are unable to resolve a discovery matter or a dispute relating to a protective order, the parties involved in the discovery matter or protective order dispute shall contact the Court's Case Manager to schedule an in-person conference/argument. Unless otherwise ordered, by no later than seven business days prior to the conference/argument, any party seeking relief shall file with the Court a letter, not to exceed three pages, outlining the issues in dispute and its position on those issues. By no later than five business days prior to the conference/argument, any party opposing the application for relief may file a letter, not to exceed three pages, outlining that party's opposition.
Pre-Motion Conference
A pre-motion conference is mandatory before filing. You must submit a letter first.
Letter Requirements
Scheduling order must be emailed in Word format to chambers simultaneously with filing.
order shall be e-mailed, in Word format, simultaneously with filing to rga_civil@ded.uscourts.gov.
Direct to: Chambers
- Status Inquiries
Claim construction briefs have word limits: opening brief 7,500 words, reply brief 5,000 words, sur-reply brief 2,500 words.
Claim Construction Briefing4. Plaintiff shall serve, but not file, its opening 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 ________.
In limine requests limited to 3 pages support, 3 pages opposition, 1 page reply.
each in limine request may be supported by a maximum of three pages of argument and may be opposed by a maximum of three pages of argument, and the party making the in limine request may add a maximum of one additional page in reply in support of its request
Jury instruction documents must be submitted in Word format via email to rga_civil@ded.uscourts.gov simultaneously with filing.
The parties shall submit simultaneously with filing each of the foregoing four documents in Word format to rga_civil@ded.uscourts.gov.
Direct to: Chambers