District of Delaware Local Rules and Judge Filing Requirements

Any submission using a word-count limit must include a certification of total word count.

Motions to join parties or amend pleadings must be filed by specified deadline

Initial disclosures under Rule 26(a)(1) must be made within 5 days of the scheduling order.

Additional expert reports require consent or court leave

Initial disclosures under Rule 26(a)(1) must be made within 5 days of order entry.

When a page limit is set by order or rule, parties may use a word-count alternative calculated at 250 words per page.

Discovery dispute letters limited to 3 pages; 48-hour and 24-hour filing deadlines.

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

Maximum number of interrogatories permitted per side.

Defendant's answering brief limited to 30 pages.

Courtesy copy of sealed documents must be provided within one hour of e-filing.

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

Two courtesy copies required for all briefs and supporting documents

Two courtesy copies required for discovery letters.

Two courtesy copies required for briefs and supporting documents; one copy for other documents.

Absent a case-specific order, responses to pre-trial or post-trial motions are due in 21 calendar days, and any reply is due 10 calendar days after the response.

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

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

Letter filing deadline: 72 hours before conference, max 4 pages, double-spaced, 12pt font

Motions to join parties or amend pleadings must follow procedures in Paragraphs 4(g) and 5.

Citations must appear in body text rather than in footnotes or endnotes.

Jury documents must be submitted in Word format to specified email address.

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

Joint Claim Construction Chart must be in Word format and emailed to specific address.

Parties must highlight important portions of exhibits in yellow.

All phone calls to Chambers must include local counsel.

Telephonic Rule 16 status conference scheduled with specific coordination requirement

Counsel must discuss discovery issues before seeking court intervention

Joint Claim Construction Chart must be emailed in Word format to chambers at Samantha_Miller@ded.uscourts.gov.

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

Sealed papers require original and copy to Clerk; redacted version due within 7 days.

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

Sealed courtesy copies no longer required in sealed envelopes.

ADR communications are confidential and disclosure is prohibited except by court authorization or party agreement.

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

In limine requests must be included in proposed pretrial order with page limits.

Multiple motions relying on different facts must be filed separately

Motions in limine must be included in proposed pretrial order with page limits and combined submissions.

ADR/mediation communications must not be filed or docketed.

ADR/mediation communications must not be filed or docketed.

Either party may request a change to the presumptive response/reply schedule upon a showing of good cause.

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

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

Objections to magistrate judge decisions are due within 14 days of service of R&R or Order

Motions to join parties or amend pleadings must be filed by specified date.

Zoom hearing registration required by 4:00 p.m. business day prior, or 1 hour prior for emergency/first day hearings.

Revised proposed orders must be provided to the Court at least one hour before the scheduled hearing.

Responses to letters or motions in discovery/administration matters must be filed by noon two days before the hearing.

Opposing parties in discovery disputes must submit response letters no later than 48 hours after receiving the moving party's letter.

The Court encourages attorneys with fewer than seven years of practice to participate in oral argument and trial proceedings, and welcomes notice when they will do so.

Judge encourages newer attorneys to argue motions they contributed to briefing for.

Newer attorneys (less than 7 years experience) are encouraged to have in-court speaking opportunities; parties may notify the court of intent to have a newer attorney argue, opposing parties are encouraged to designate a younger attorney, and supervising counsel may assist during oral argument.

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.

Proposed orders will only be considered after the associated e-order has been uploaded.

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

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

Proposed orders must be filed electronically, and all exhibits to the proposed order must be uploaded as separate attachments.

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

Exhibits not on the docket must be emailed in PDF format to parties and the Court no later than 24 hours before the hearing.

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.