District of Delaware Filing Bundling Requirements

Multiple motions relying on different facts must be filed separately

Source text: A party shall not combine into a single motion multiple motions that rely in whole or in part on different facts.

Multiple summary judgment motions must be numbered in order of priority; Court will not review subsequent motions if one is denied.

Source text: A party that files more than one summary judgment motion shall number each motion to make clear the order in which the party wishes the Court to consider the motions in question. The first motion the party wishes the Court to consider shall be designated # 1, the second motion shall be designated #2, and so on. The Court will review the party's summary judgment motions in the order designated by the party. If the Court decides to deny a motion filed by the party, barring exceptional reasons determined sua sponte by the Court, the Court will not review any further summary judgment motions filed by the party.

Multiple Daubert motions must be numbered in order of priority; Court will not review subsequent motions if one is denied.

Source text: A party that files more than one Daubert motion shall number each motion to make clear the order in which the party wishes the Court to consider the motions in question. The first motion the party wishes the Court to consider shall be designated # 1, the second motion shall be designated #2, and so on. The Court will review the party's Daubert motions in the order designated by the party. If the Court decides to deny a motion filed by the party, barring exceptional reasons determined sua sponte by the Court, the Court will not review any further Daubert motions filed by the party.

In limine requests must be included in pretrial order; max 3 requests per party with 3-page arguments and 1-page reply

Source text: 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. Each 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

Court reviews summary judgment motions in designated order and stops reviewing if any motion is denied, unless exceptional reasons exist.

Source text: The Court will review the party’s summary judgment motions in the order designated by the party. If the Court decides to deny a motion filed by the party, barring exceptional reasons determined sua sponte by the Court, the Court will not review any further summary judgment motions filed by the party.

Separate briefing on in limine requests is prohibited unless court permission is obtained.

Source text: No separate briefing shall be submitted on in limine requests, unless otherwise permitted by the Court.

Multiple motions relying on different facts cannot be combined into a single motion.

Source text: A party shall not combine into a single motion multiple motions that rely in whole or in part on different facts.

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

Source text: 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.

In limine motions must be included in pretrial order.

Source text: Motions in limine shall not be separately filed.

ADR/mediation communications must not be filed or docketed.

Source text: IT IS FURTHER ORDERED that any communications regarding the ADR/mediation process, including but not limited to the scheduling or rescheduling of teleconferences or mediation dates, are not to bee-filed or docketed. Such communications are to be made as designated or ordered by the Magistrate Judge. Mediation statements are not to bee-filed or docketed.

Motions in limine must be bundled into the proposed pretrial order and not filed separately.

Source text: Motions in limine shall not be separately filed. All in limine requests and responses thereto shall be set forth in the proposed pretrial order.

In limine requests must be included in proposed pretrial order, limited to 3 per side.

Source text: 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.

Briefing for multiple case dispositive and Daubert motions must be consolidated within aggregate page limits per side.

Source text: Unless otherwise ordered by the Court, all sides are limited to a maximum of thirty (30) pages of opening briefs, thirty (30) pages of answering briefs, and fifteen (15) pages of reply briefs relating to any case dispositive and Daubert motions filed by a side, no matter how many such motions are filed.

ADR/mediation communications must not be filed or docketed.

Source text: IT IS FURTHER ORDERED that any communications regarding the ADR/mediation process, including but not limited to the scheduling or rescheduling of teleconferences or mediation dates, are not to bee-filed or docketed. Such communications are to be made as designated or ordered by the Magistrate Judge. Mediation statements are not to bee-filed or docketed.

Total briefing limit of 250 pages for all case dispositive and Daubert motions across related cases

Source text: 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.

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

Source text: 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.

Motions in limine must not be filed separately and must be included in the proposed pretrial order instead.

Source text: Motions in limine shall not be separately filed. All in limine requests and responses thereto shall be set forth in the proposed pretrial order.

Multiple parties supporting or opposing an in limine request must combine their submission into a single 3-page document (or single 1-page reply for moving parties).

Source text: 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).

Parties must prepare a joint exhibit book containing all trial exhibits and a schedule of exhibits.

Source text: The parties will prepare a joint exhibit book with all exhibits counsel may use at trial based on the rulings along with a schedule of exhibits.

No separate briefing on in limine requests is permitted; submissions must be combined, unless the Court allows otherwise.

Source text: No separate briefing shall be submitted on in limine requests, unless otherwise permitted by the Court.

Parties are prohibited from combining multiple motions that rely on different facts into a single motion.

Source text: A party shall not combine into a single motion multiple motions that rely in whole or in part on different facts.

Parties are prohibited from combining multiple motions that rely on different facts into a single motion.

Source text: A party shall not combine into a single motion multiple motions that rely in whole or in part on different facts.

Separate briefing on in limine requests is prohibited unless court permission is obtained.

Source text: No separate briefing shall be submitted on in limine requests, unless otherwise permitted by the Court.

Materials that would be submitted in an appendix must be bundled into a Joint Appendix.

Source text: If there are any materials that would be submitted in an appendix, the parties shall submit them in a Joint Appendix.