Judge André M. Espinosa
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- 1 copy • Mail
Adjournments
- Adjournment requests must be filed at least five business days before a scheduled conference.
- Extensions must be requested in writing at least five business days before the deadline.
- Adjournment requests must be made at least 5 business days before conference.
- +3 more
- After the standard extension window, conference-date extensions require unforeseen emergent circumstances and leave of Court even with consent.
- Counsel should endeavor to seek the consent of all parties prior to making such requests and must note in the request whether consent has been obtained.
- Extension requests must identify current and proposed dates.
- +2 more
Request must include
Communication
Chambers
Phone
Chambers
Page & Word Limits5 rules
the matter shall be brought to the Court’s attention via a joint letter, not to exceed five pages, that sets forth:
Joint Discovery Dispute Letter
5 pages
Each party shall submit, by email to AME_orders@njd.uscourts.gov, a confidential settlement memorandum of no more than five double-spaced pages no later than five business days before the conference.
Settlement Memorandum
5 pages
Applies to: Attorney
Each party shall submit, by email to AME_orders@njd.uscourts.gov, a confidential settlement memorandum of no more than five double-spaced pages no later than five business days before the conference.
Settlement Memorandum
5 pages
Discovery dispute joint letters are limited to five pages.
Should counsel fail in their good faith efforts to resolve the dispute by conferring pursuant to Rule 37.1, the matter shall be brought to the Court’s attention via a joint letter, not to exceed five pages, that sets forth: a) the request; b) the response; c) efforts to resolve the dispute; d) the position of the complaining party; e) the position of the responding party; and, if applicable, f) the efforts of a party to contact a non-responsive party to meet and confer and submit the joint letter.
Discovery Dispute Letter
5 pages
Applies to: Attorney
Each party shall submit, by email to AME_orders@njd.uscourts.gov, a confidential settlement memorandum of no more than five double-spaced pages no later than five business days before the conference.
Settlement Memorandum
5 pages
Document Format Requirements1 rule
Each party shall submit, by email to AME_orders@njd.uscourts.gov, a confidential settlement memorandum of no more than five double-spaced pages no later than five business days before the conference.
Document Filing Requirements26 rules
Motions to amend pleadings must include as an exhibit a black- or red-lined proposed amended complaint, which clearly indicates the proposed changes.
DocumentMotion To Amend
Motions to amend must include black/red-lined proposed amended complaint; failure results in administrative termination.
Pursuant to Local Civil Rule 15.1, motions to amend pleadings must include as an exhibit a black- or red-lined proposed amended complaint, which clearly indicates the proposed changes. Failure to do so will result in administrative termination of the motion.
DocumentMotion To Amend
The request shall indicate the current and proposed dates and include a proposed form of order.
DocumentExtension Request
The application must contain a letter indicating consent, a certification of admission and good standing, and a certification of local counsel stating that counsel shall comply with Local Civil Rule 101.1(c).
DocumentPro Hac Vice Application
(2) an additional version that shall indicate in what respect(s) it differs from Appendix S by bracketing or striking through materials to be deleted and underlining materials to be added.
DocumentProposed Confidentiality Order
A proposed form of order must be submitted.
DocumentPro Hac Vice Application
(1) a clean version of the proposed order that is ready for signature,
DocumentProposed Confidentiality Order
Any such request shall include a proposed order.
DocumentDiscovery Extension Request
If admission pro hac vice is sought on consent, the request should be made by informal application filed on CM/ECF. The application must contain a letter indicating consent, a certification of admission and good standing, and a certification of local counsel stating that counsel shall comply with Local Civil Rule 101.1(c). A proposed form of order must be submitted. If not consented, the party making the application must proceed by motion.
DocumentPro Hac Vice Application
The joint discovery dispute letter must include specified content items, including positions of both sides and meet-and-confer efforts.
a) the request; b) the response; c) efforts to resolve the dispute; d) the position of the complaining party; e) the position of the responding party; and, if applicable, f) the efforts of a party to contact a non-responsive party to meet and confer and submit the joint letter.
DocumentJoint Discovery Dispute Letter
Any request for an extension or an amended scheduling order shall indicate the current and proposed dates as well as whether the request is made on consent. Any such request shall include a proposed order.
DocumentExtension Request
must include a proposed order and proposed findings of fact and conclusions of law.
DocumentMotion To Seal
must include a proposed order and proposed findings of fact and conclusions of law. Failure to comply with Local Civil Rule 5.3(c) will result in administrative termination of the motion.
DocumentMotion
Discovery disputes must follow Local Rules 16.1 and 37.1; unresolved disputes brought via joint letter (max 5 pages) with specific content requirements.
Discovery disputes shall proceed in accordance with Local Rules 16.1 and 37.1. Should counsel fail in their good faith efforts to resolve the dispute by conferring pursuant to Rule 37.1, the matter shall be brought to the Court's attention via a joint letter, not to exceed five pages, that sets forth: a) the request; b) the response; c) efforts to resolve the dispute; d) the position of the complaining party; e) the position of the responding party; and, if applicable, f) the efforts of a party to contact a non-responsive party to meet and confer and submit the joint letter.
DocumentDiscovery Dispute Joint Letter
Each party shall submit, by email to AME_orders@njd.uscourts.gov, a confidential settlement memorandum of no more than five double-spaced pages no later than five business days before the conference.
DocumentSettlement Memorandum
The parties shall submit, by email and regular mail, a copy of the joint proposed final pretrial order no later than five business days before the conference.
DocumentJoint Proposed Final Pretrial Order
The parties shall submit, by email and regular mail, a copy of the joint proposed final pretrial order no later than five business days before the conference.
DocumentJoint Proposed Final Pretrial Order
Extension requests must include current and proposed dates, a proposed order, and note whether consent was obtained.
The request shall indicate the current and proposed dates and include a proposed form of order. Counsel should endeavor to seek the consent of all parties prior to making such requests and must note in the request whether consent has been obtained.
DocumentExtension Request
Motions to amend must include a black- or red-lined proposed amended complaint showing changes.
Pursuant to Local Civil Rule 15.1, motions to amend pleadings must include as an exhibit a black- or red-lined proposed amended complaint, which clearly indicates the proposed changes. Failure to do so will result in administrative termination of the motion.
DocumentMotion To Amend
Motions to seal must comply with Local Rule 5.3(c) and include a proposed order and proposed findings of fact and conclusions of law.
Motions to seal must comply with Local Civil Rule 5.3(c) and must include a proposed order and proposed findings of fact and conclusions of law. Failure to comply with Local Civil Rule 5.3(c) will result in administrative termination of the motion.
DocumentMotion To Seal
If admission pro hac vice is sought on consent, the request should be made by informal application filed on CM/ECF. The application must contain a letter indicating consent, a certification of admission and good standing, and a certification of local counsel stating that counsel shall comply with Local Civil Rule 101.1(c). A proposed form of order must be submitted. If not consented, the party making the application must proceed by motion.
DocumentPro Hac Vice Application
Discovery extension requests must include current and proposed dates, consent note, and proposed order.
Any request for an extension or an amended scheduling order shall indicate the current and proposed dates as well as whether the request is made on consent. Any such request shall include a proposed order.
DocumentDiscovery Extension Request
Counsel shall make every effort to secure the consent of opposing counsel regarding the request to seal.
DocumentMotion To Seal
Use Appendix S confidentiality order form; if submitting own version, must provide clean version and version showing differences with brackets/strikes/underscores.
The parties are encouraged to use the form discovery confidentiality order found at Appendix S of the Local Rules. If the parties submit their own version of a confidentiality order, which differs from Appendix S, they must submit: (1) a clean version of the proposed order that is ready for signature, and (2) an additional version that shall indicate in what respect(s) it differs from Appendix S by bracketing or striking through materials to be deleted and underlining materials to be added.
DocumentConfidentiality Order
If submitting a confidentiality order different from Appendix S, parties must submit a clean version and a version showing changes.
If the parties submit their own version of a confidentiality order, which differs from Appendix S, they must submit: (1) a clean version of the proposed order that is ready for signature, and (2) an additional version that shall indicate in what respect(s) it differs from Appendix S by bracketing or striking through materials to be deleted and underlining materials to be added.
DocumentConfidentiality Order
If admission pro hac vice is sought on consent, the request should be made by informal application filed on CM/ECF.
DocumentPro Hac Vice Application
Filing & Service rules
Filing Timing and Cure Windows
Joint proposed final pretrial order must be submitted by email and regular mail no later than 5 business days before the final pretrial conference.
The parties shall submit, by email and regular mail, a copy of the joint proposed final pretrial order no later than five business days before the conference.
Civil cases
Page 3 | 13. Final pretrial conferences
Settlement memorandum must be submitted no later than 5 business days before the settlement conference.
Each party shall submit, by email to AME_orders@njd.uscourts.gov, a confidential settlement memorandum of no more than five double-spaced pages no later than five business days before the conference.
Civil cases
Page 3 | 12. Settlement conferences
Courtesy Copy Requirements
One courtesy copy is required for submissions over 20 pages and must be sent to chambers by mail or courier.
Courtesy copies. One courtesy copy of all submissions exceeding 20 pages shall be sent by regular mail or other courier addressed to chambers.
Civil cases
Page 3 | Courtesy copies
Courtesy copies required for submissions over 20 pages.
One courtesy copy of all submissions exceeding 20 pages shall be sent by regular mail or other courier addressed to chambers.
Civil cases
Page 3 | 11. Courtesy copies
One courtesy copy required for submissions over 20 pages, sent by mail or courier to chambers.
One courtesy copy of all submissions exceeding 20 pages shall be sent by regular mail or other courier addressed to chambers.
Civil cases
Page 3 | 11. Courtesy copies
Sealing & Redaction Procedures
Settlement and discovery dispute letters under confidentiality order may be emailed to AME_orders@njd.uscourts.gov.
Settlement letters and discovery dispute letters containing information subject to a Discovery Confidentiality Order may be submitted to the Court by email to AME_orders@njd.uscourts.gov.
Civil cases
Page 2 | Confidential submissions
Pre-Motion Conference Requirements
Formal motions require prior leave from court except for Rule 12 motions, timely remand motions, and those expressly permitted.
Other than motions filed under Federal Rule of Civil Procedure 12, motions to remand within the time provided by 28 U.S.C. § 1447(c), and motions expressly permitted by this Case Management Order, formal motions shall not be filed without prior leave from this Court.
Civil cases
Page 1 | Formal motions
Formal motions require prior leave of Court except Rule 12 motions, timely remand motions, and motions expressly allowed by the Case Management Order.
Other than motions filed under Federal Rule of Civil Procedure 12, motions to remand within the time provided by 28 U.S.C. § 1447(c), and motions expressly permitted by this Case Management Order, formal motions shall not be filed without prior leave from this Court.
Civil cases
Page 1 | Formal motions
A pro hac vice application without consent must be filed as a formal motion.
If not consented, the party making the application must proceed by motion.
Civil cases
Page 2 | Pro hac vice applications
Third-party subpoena enforcement or quash motions do not require meet-and-confer, but still require leave of court before filing.
Motions to secure enforcement of a subpoena or to quash a subpoena involving third parties may be made without meeting and conferring, but counsel must obtain leave of Court before filing any such motion.
Civil cases
Page 3 | Discovery extensions, disputes, and motions
Discovery motions require leave of court and prior compliance with Local Rules 16.1 and 37.1 before filing.
Discovery motions may be filed only upon leave of Court and only after the parties have proceeded in accordance with Local Rules 16.1 and 37.1.
Civil cases
Page 3 | Discovery extensions, disputes, and motions
Formal motions (except Rule 12 motions, motions to remand, and motions permitted by this Order) require prior leave of Court.
Other than motions filed under Federal Rule of Civil Procedure 12, motions to remand within the time provided by 28 U.S.C. § 1447(c), and motions expressly permitted by this Case Management Order, formal motions shall not be filed without prior leave from this Court.
Civil cases
Page 1 | 4. Formal motions
Discovery disputes must be brought to the Court via a joint letter not exceeding five pages with specified content after conferring.
Should counsel fail in their good faith efforts to resolve the dispute by conferring pursuant to Rule 37.1, the matter shall be brought to the Court’s attention via a joint letter, not to exceed five pages, that sets forth: a) the request; b) the response; c) efforts to resolve the dispute; d) the position of the complaining party; e) the position of the responding party; and, if applicable, f) the efforts of a party to contact a non-responsive party to meet and confer and submit the joint letter.
Civil cases
Page 2 | 10. Discovery extensions, disputes, and motions
Subpoena enforcement/quash motions involving third parties exempt from meet-and-confer but require leave of Court.
Motions to secure enforcement of a subpoena or to quash a subpoena involving third parties may be made without meeting and conferring, but counsel must obtain leave of Court before filing any such motion.
Civil cases
Page 3 | Subpoena motions
Discovery motions require leave of Court and compliance with Local Rules 16.1 and 37.1 before filing.
Discovery motions may be filed only upon leave of Court and only after the parties have proceeded in accordance with Local Rules 16.1 and 37.1.
Civil cases
Page 3 | Discovery motions
Adjournment & Extension Requirements
After the standard extension window, conference-date extensions require unforeseen emergent circumstances and leave of Court even with consent.
Thereafter, no extensions of any conference date will be granted except upon a showing unforeseen, emergent circumstances and by leave of Court, even if there is consent of all counsel.
Civil cases
Page 1 | Extensions
Adjournment requests must be made at least 5 business days before conference.
Adjournment requests must be made no later than five business days before the scheduled conference.
Civil cases
Page 1 | Adjournments
Extension requests must identify current and proposed dates.
The request shall indicate the current and proposed dates and include a proposed form of order.
Civil cases
Page 1 | Extensions
Extensions of time as provided in court-ordered schedules must be requested in writing at least five business days prior to the expiration of deadlines. The request shall indicate the current and proposed dates and include a proposed form of order. Counsel should endeavor to seek the consent of all parties prior to making such requests and must note in the request whether consent has been obtained. Thereafter, no extensions of any conference date will be granted except upon a showing unforeseen, emergent circumstances and by leave of Court, even if there is consent of all counsel.
Extensions of time as provided in court-ordered schedules must be requested in writing at least five business days prior to the expiration of deadlines. The request shall indicate the current and proposed dates and include a proposed form of order. Counsel should endeavor to seek the consent of all parties prior to making such requests and must note in the request whether consent has been obtained. Thereafter, no extensions of any conference date will be granted except upon a showing unforeseen, emergent circumstances and by leave of Court, even if there is consent of all counsel.
Civil cases
Page 1 | Extensions
Adjournment requests must be filed at least five business days before a scheduled conference.
Adjournment requests must be made no later than five business days before the scheduled conference.
Civil cases
Page 1 | Adjournments
Extensions must be requested in writing at least five business days before the deadline.
Extensions of time as provided in court-ordered schedules must be requested in writing at least five business days prior to the expiration of deadlines.
Civil cases
Page 1 | Extensions
Discovery extension or amended scheduling requests must state current and proposed dates and whether the request is on consent.
Any request for an extension or an amended scheduling order shall indicate the current and proposed dates as well as whether the request is made on consent.
Civil cases
Page 2 | Discovery extensions, disputes, and motions
Adjournment requests must be made at least five business days before the scheduled conference.
Adjournment requests must be made no later than five business days before the scheduled conference.
Civil cases
Page 1 | 2. Adjournments
Extension requests must be made in writing at least five business days before the deadline.
Extensions of time as provided in court-ordered schedules must be requested in writing at least five business days prior to the expiration of deadlines.
Civil cases
Page 1 | 3. Extensions
Thereafter, no extensions of any conference date will be granted except upon a showing unforeseen, emergent circumstances and by leave of Court, even if there is consent of all counsel.
Thereafter, no extensions of any conference date will be granted except upon a showing unforeseen, emergent circumstances and by leave of Court, even if there is consent of all counsel.
Civil cases
Page 1 | 3. Extensions
Counsel should endeavor to seek the consent of all parties prior to making such requests and must note in the request whether consent has been obtained.
Counsel should endeavor to seek the consent of all parties prior to making such requests and must note in the request whether consent has been obtained.
Civil cases
Page 1 | Extensions
Chambers Communication Rules
All communications must be via CM/ECF; phone calls only for administrative matters; mail/email/fax not accepted unless authorized.
All communications to the Court shall be in writing via CM/ECF. Telephone calls to chambers will be permitted as to administrative matters only or as otherwise directed by the Court. Mail, email, and fax communications will not be accepted or considered unless expressly authorized by the Court.
Civil cases
Page 1 | Communications with the Court
Communications to the Court must be made in writing through CM/ECF.
All communications to the Court shall be in writing via CM/ECF.
Civil cases
Page 1 | Communications with the Court
Mail, email, and fax communications will not be accepted or considered unless expressly authorized by the Court.
Mail, email, and fax communications will not be accepted or considered unless expressly authorized by the Court.
Civil cases
Page 1 | Communications with the Court
The parties shall submit, by email and regular mail, a copy of the joint proposed final pretrial order no later than five business days before the conference.
The parties shall submit, by email and regular mail, a copy of the joint proposed final pretrial order no later than five business days before the conference.
Civil cases
Page 3 | Final pretrial conferences
Settlement memoranda must be emailed to chambers at the listed address at least five business days before the conference.
Each party shall submit, by email to AME_orders@njd.uscourts.gov, a confidential settlement memorandum of no more than five double-spaced pages no later than five business days before the conference.
Civil cases
Page 3 | Settlement conferences
Mail, email, and fax communications are not accepted unless expressly authorized by the Court.
Mail, email, and fax communications will not be accepted or considered unless expressly authorized by the Court.
Civil cases
Page 1 | 1. Communications with the Court
All communications to the Court shall be in writing via CM/ECF.
All communications to the Court shall be in writing via CM/ECF.
Civil cases
Page 1 | 1. Communications with the Court
Telephone calls to chambers are limited to administrative matters unless the Court directs otherwise.
Telephone calls to chambers will be permitted as to administrative matters only or as otherwise directed by the Court.
Civil cases
Page 1 | Communications with the Court
Telephone calls to chambers are permitted only for administrative matters or as directed by the Court.
Telephone calls to chambers will be permitted as to administrative matters only or as otherwise directed by the Court.
Civil cases
Page 1 | 1. Communications with the Court
Confidential settlement and discovery dispute letters may be emailed to chambers at AME_orders@njd.uscourts.gov.
Settlement letters and discovery dispute letters containing information subject to a Discovery Confidentiality Order may be submitted to the Court by email to AME_orders@njd.uscourts.gov.
Civil cases
Page 2 | Confidential submissions
Settlement and discovery dispute letters with confidential information may be submitted by email to AME_orders@njd.uscourts.gov.
Settlement letters and discovery dispute letters containing information subject to a Discovery Confidentiality Order may be submitted to the Court by email to AME_orders@njd.uscourts.gov.
Civil cases
Page 2 | 8. Confidential submissions
Settlement memoranda must be submitted by email to AME_orders@njd.uscourts.gov.
Each party shall submit, by email to AME_orders@njd.uscourts.gov, a confidential settlement memorandum of no more than five double-spaced pages no later than five business days before the conference.
Civil cases
Page 3 | 12. Settlement conferences
Joint proposed final pretrial order must be submitted by email and regular mail.
The parties shall submit, by email and regular mail, a copy of the joint proposed final pretrial order no later than five business days before the conference.
Civil cases
Page 3 | 13. Final pretrial conferences
Parties must contact Chambers to obtain the model joint final pretrial order.
The parties shall contact Chambers for a model version of the joint final pretrial order applicable to the District Judge assigned to the matter.
Civil cases
Page 3 | 13. Final pretrial conferences