Courtesy copies are required when a filing is > 20 pages. Details: 1 copy, delivery upon filing, by mail. One courtesy copy is required for submissions over 20 pages and must be sent to chambers by mail or courier.
Judge André M. Espinosa's rules set a pre-motion procedure for covered motions. Formal motions require prior leave of Court except Rule 12 motions, timely remand motions, and motions expressly allowed by the Case Management Order.
Judge André M. Espinosa's rule states these limits: 5 pages. Unresolved discovery disputes must be presented by joint letter limited to five pages.
Judge André M. Espinosa's rule states these limits: 5 pages. Settlement memoranda are limited to five pages.
Judge André M. Espinosa's formatting rule includes double spacing. Settlement memoranda must be double-spaced.
The rule requires proposed order. Extension requests must include a proposed order.
The rule identifies required filing content or certificates. Motions to amend must attach a blacklined or redlined proposed amended complaint showing the proposed changes.
Parties may contact Judge André M. Espinosa's chambers by letter ecf only as allowed by the rule. Communications to the Court must be made in writing through CM/ECF.
The rule does not state that a motion to seal is required for the covered filing process. Settlement and discovery dispute letters under confidentiality order may be emailed to AME_orders@njd.uscourts.gov.
Requests should be made at least 5 business days in advance when this rule applies before Judge André M. Espinosa. Adjournment requests must be filed at least five business days before a scheduled conference.
Communications to the Court must be made in writing through CM/ECF.
Telephone calls to chambers are limited to administrative matters unless the Court directs otherwise.
Email communications are not accepted unless expressly authorized by the Court.
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.
Extension requests must identify current and proposed dates.
Extension requests must state whether party consent was obtained.
Extension requests must include a proposed order.
After the standard extension window, conference-date extensions require unforeseen emergent circumstances and leave of Court even with consent.
Formal motions require prior leave of Court except Rule 12 motions, timely remand motions, and motions expressly allowed by the Case Management Order.
Motions to amend must attach a blacklined or redlined proposed amended complaint showing the proposed changes.
The sealing-related motion/request must include a proposed order and proposed findings of fact and conclusions of law.
Counsel must make every effort to obtain opposing counsel's consent for a sealing request.
If parties submit a confidentiality order differing from Appendix S, they must provide a clean signature-ready proposed order.
If parties submit a non-Appendix S confidentiality order, they must also submit a marked comparison copy showing deletions and additions.
Confidential settlement and discovery dispute letters may be emailed to chambers at AME_orders@njd.uscourts.gov.
When pro hac vice admission is on consent, it should be requested by informal CM/ECF application.
A consent-based pro hac vice application must include a consent letter and required certifications, including local counsel's Local Rule 101.1(c) certification.
Pro hac vice applications must include a proposed order.
A pro hac vice application without consent must be filed as a formal motion.
Discovery extension or amended scheduling requests must state current and proposed dates and whether the request is on consent.
Discovery extension or amended scheduling requests must include a proposed order.
Unresolved discovery disputes must be presented by joint letter limited to five pages.
The joint discovery dispute letter must include specified content items, including positions of both sides and meet-and-confer efforts.
Discovery motions require leave of court and prior compliance with Local Rules 16.1 and 37.1 before filing.
Third-party subpoena enforcement or quash motions do not require meet-and-confer, but still require leave of court before filing.
One courtesy copy is required for submissions over 20 pages and must be sent to chambers by mail or courier.
Each party must submit a confidential settlement memorandum before the settlement conference.
Settlement memoranda are limited to five pages.
Settlement memoranda must be double-spaced.