Judge Renée Marie Bumb
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Courtesy Copies
Brief
- 1 copy
Exhibits
- Upon request
Adjournments
- Adjournment/extension requests must comply with Local Civil Rule 6.1 and include specified information; unreasonable withholding of consent may result in fees.
Request must include
Communication
Phone
Document Format Requirements5 rules
properly hyperlinks and bookmarks the location of each exhibit within that PDF. The Court will strike electronic submissions that fail to comply with this rule.
Exhibits supporting a motion must be clearly labeled, dated, tabbed, and indexed; noncompliance may result in striking.
To the extent any party submits exhibits to support a motion, such exhibits shall be clearly labeled, dated, tabbed, and indexed. The Court may strike a party’s submission for failure to comply with this rule.
All papers electronically submitted shall, to the extent possible, be submitted in a text-searchable PDF format.
Verdict sheet must be submitted in hard copy with an electronic Word version on a USB drive.
Counsel for all parties must confer with each other prior to trial and submit a joint verdict sheet three (3) weeks before trial in hard copy form, accompanied by a USB drive containing an electronic version of the verdict sheet, in Word format.
DOCX
Jury charges must be submitted in hard copy with an electronic Word version on a USB drive.
Counsel for all parties must confer with each other prior to trial and submit joint requests to charge three (3) weeks before trial in hard copy form, accompanied by a USB drive containing an electronic version of the charges, in Word format.
DOCX
Document Filing Requirements13 rules
Opposing parties must file a responsive statement of material facts addressing each paragraph as disputed or undisputed, with record citations, and without legal argument.
If a summary judgment motion is opposed, the opposing party shall set forth, in a separately filed document, each paragraph of the moving party’s statement of material facts. Directly below each paragraph, the opposing party shall denote whether that fact is disputed or undisputed. If the fact is disputed, the opposing party must include a citation to record evidence with a pin cite that supports the dispute. Any explanation must include a citation to record evidence with a pin cite. The opposing party shall not include legal argument or extraneous detail outside the scope of the moving party’s statement.
DocumentResponsive Statement Of Material Facts
Summary judgment motions must include a separately filed statement of material facts; each fact must cite record evidence with a pin cite or may be disregarded.
Chief Judge Bumb requires strict compliance with Federal Rule of Civil Procedure 56 and Local Civil Rule 56.1 in seeking or opposing summary judgment. A motion for summary judgment must be accompanied by a separately filed statement of material facts. Each fact must include a citation to the record evidence with a pin cite that supports that fact. Facts without citation to record evidence may be disregarded by the Court.
DocumentMotion
If any relief is being sought, a proposed order must accompany the party’s submission.
DocumentSubmission
Plaintiffs in RICO cases must file a RICO Case Statement within 30 days of filing the complaint, in accordance with Appendix O of the Local Rules.
In all matters in which the complaint contains a RICO claim, pursuant to 18 U.S.C. §§ 1961–1968, the plaintiff(s) must file a RICO Case Statement within thirty (30) days of filing the complaint, in accordance with Appendix O of the Local Rules & Appendices found at: http://www.njd.uscourts.gov/LocalRules.html.
DocumentRico Case Statement
Counsel must confer and submit a joint jury questionnaire 3 weeks before trial in hard copy plus a USB drive with a Word electronic version; contested questions submitted at the same time.
Counsel for all parties must confer with each other prior to trial and submit a joint jury questionnaire three (3) weeks before trial in hard copy form, accompanied by a USB drive containing an electronic version of the questionnaire, in Word format. Any additional or contested proposed questions that could not be agreed upon by the parties should be submitted by the propounding party to the Court at the same time. Exceptions to this rule must be approved by the Court. Failure to adhere to this rule may result in an adjournment of the trial with imposition of attorneys’ fees and costs to the offending party(ies).
DocumentJury Questionnaire
Jury charge submissions must delineate charges for before trial and at close of trial, and cite applicable authority for each proposed charge.
Counsel are to delineate in their submissions charges they wish to be given before trial, including a joint preliminary statement of the case, and charges they wish to be given at the close of trial. Counsel shall cite to the applicable authority for each proposed charge.
DocumentJury Charges
Each party shall submit a list of pre-marked exhibits and a witness list, including the name and address (city and state only) of each potential witness, one (1) week prior to trial. All trial exhibits must be pre-marked in accordance with each party's exhibit list.
DocumentExhibit List
If a party fails to comply with these rules, the Court will likely strike that party’s submission.
DocumentSummary Judgment Submission
In addition to filing a responsive statement of material facts, the opposing party may submit a separately filed supplemental statement of material facts setting forth any relevant facts in support of its position, which the moving party shall respond to in turn. The Court may ignore a supplemental statement of material facts if it fails to include citation to record evidence.
DocumentSupplemental Statement Of Material Facts
Exhibits shall be clearly labeled. Exhibits shall be separately filed as related attachments to the document they support (i.e., a declaration/certification summarizing the
DocumentExhibits
If counsel cannot agree on a joint verdict sheet, counsel shall separately submit proposed verdict sheets in the same manner.
DocumentVerdict Sheet
Counsel shall retain custody of their trial exhibits until closings.
DocumentExhibits
The prosecuting attorney and/or investigating agency is generally required to maintain custody of exhibits such as weapons, narcotics, or currency during trial.
DocumentExhibits
Filing & Service rules
Electronic Filing Rules
Pro se parties must file all documents, applications, and motions directly with the Clerk's Office.
Parties appearing pro se must file all documents, applications, and motions directly with the Clerk’s Office.
Page 4 | II.B. Pro Se Filings
Courtesy copies of exhibits and other supporting papers must be filed electronically on CM/ECF only.
courtesy copies of all exhibits and other supporting papers shall be filed electronically on CM/ECF only
Page 4 | II.D. Courtesy Copies and Exhibits
All parties except pro se litigants must file all documents electronically via CM/ECF in both civil and criminal matters.
All parties, with the exception of pro se parties, shall file all documents, in both civil and criminal matters, electronically via CM/ECF.
Page 4 | II.A. Electronic Submissions (CM/ECF)
Filing Timing and Cure Windows
Pre-trial briefs, proposed findings of fact and conclusions of law, and in limine motions must be submitted at least 3 weeks before trial; responsive papers at least 2 weeks before trial.
Once the Joint Final Pretrial Order has been filed, each party shall submit its pre-trial brief or its proposed findings of fact and conclusions of law, and any in limine motions, at least three (3) weeks before the start of trial. Any responsive papers shall be submitted at least two (2) weeks before the start of trial. Exceptions to this rule must be approved by the Court. Failure to adhere to this rule may result in an adjournment of the trial with imposition of attorneys’ fees and costs to the offending party(ies).
Page 6 | VI.A Pre-Trial Briefs or Proposed Findings of Fact and Conclusions of Law, and In Limine Motions
Each party must submit a list of pre-marked exhibits and a witness list one week before trial.
Each party shall submit a list of pre-marked exhibits and a witness list, including the name and address (city and state only) of each potential witness, one (1) week prior to trial.
Page 7 | E. Trial Exhibits
Joint verdict sheet must be submitted three weeks before trial.
Counsel for all parties must confer with each other prior to trial and submit a joint verdict sheet three (3) weeks before trial in hard copy form, accompanied by a USB drive containing an electronic version of the verdict sheet, in Word format.
Page 7 | D. Verdict Sheet
Joint requests to charge must be submitted three weeks before trial.
Counsel for all parties must confer with each other prior to trial and submit joint requests to charge three (3) weeks before trial in hard copy form, accompanied by a USB drive containing an electronic version of the charges, in Word format.
Page 7 | C. Jury Charges
Deposition designations and evidentiary objections must be submitted no later than two weeks before trial; failure may result in preclusion of deposition testimony.
If a party anticipates introducing deposition testimony at trial, then such deposition designations, and any evidentiary objections thereto, must be submitted to the Court no later than two (2) weeks before trial.
Page 8 | F. Deposition Designations
Submitting a pre-motion letter tolls the motion-filing deadline; if the Court waives the conference, the party gets 5 additional business days to file.
A party’s submission of a pre-motion letter will toll that party’s time to file its motion (or answer) through (i) the date of the pre-motion conference or (ii) the Court’s decision not to conduct such a conference. If the Court determines that a pre-motion conference would not be helpful and instructs a party to proceed with filing its proposed motion without a conference, that party shall have an additional five (5) business days to file its motion after its deadline pursuant to Federal Rule of Civil Procedure 12(a), unless additional time is so stipulated or the Court so orders.
Page 2 | I.A. Pre-Motion Conference
Service and Proof of Service Rules
Pro se parties are encouraged to consent to electronic service and may be ordered to do so for good cause.
Pro se parties are strongly encouraged to consent to receive documents and notices electronically and may, with good cause, be ordered to do so.
Page 4 | II.B. Pro Se Filings
Courtesy Copy Requirements
Parties must provide one courtesy copy of supporting briefs only, unless the Court directs otherwise.
Unless otherwise directed by the Court, the parties shall provide one (1) courtesy copy of their supporting briefs only
Page 4 | II.D. Courtesy Copies and Exhibits
Parties must not send courtesy copies of trial exhibits unless the Court requests them.
The parties shall not send courtesy copies of trial exhibits unless the Court requests them.
Page 7 | E. Trial Exhibits
Pre-Motion Conference Requirements
Before filing specified motions, a party must submit a pre-motion letter (max 3 single-spaced pages) requesting a conference, with adversaries responding within 5 business days (also max 3 pages).
In an effort to resolve cases expeditiously, before filing a motion to dismiss, motion for a more definite statement, motion to remand, motion for change of venue, or motion for judgment on the pleadings, a party must submit a letter, not to exceed three (3) single-spaced pages, requesting a pre-motion conference. The letter must set forth the basis for the anticipated motion and include citations to relevant authority. Within five (5) business days after receipt of this letter, all adversaries must submit a written response, not to exceed three (3) single-spaced pages. No party may submit a reply letter unless directed by the Court. Affidavits and exhibits are not permitted unless directed by the Court.
Page 1 | I.A. Pre-Motion Conference
Motions for summary judgment require compliance with the same pre-motion conference procedure; if the Court waives the conference, the moving party gets 5 additional business days to file.
Before filing a motion for summary judgment, a party must first comply with the same pre-motion conference procedure as outlined above. See supra Section I.A. In general, the same rules apply. If the Court determines that a pre-motion conference would not be helpful and instructs a party to proceed with filing its proposed motion without a conference, that party shall have an additional five (5) business days to file its motion after its deadline pursuant to Federal Rule of Civil Procedure 56(b), unless additional time is so stipulated or the Court so orders.
Page 3 | 1. Pre-Motion Conference
Summary judgment motions are prohibited in ANDA patent cases unless a party obtains a waiver via a 3-page single-spaced letter; adversaries must respond within 5 business days in a 3-page single-spaced letter, and replies are disallowed unless directed.
Chief Judge Bumb does not permit the filing of summary judgment motions in ANDA patent cases. A party may, however, submit a letter to the Court, not to exceed three (3) single-spaced pages, seeking a waiver of this rule if the party believes that a summary judgment motion would assist the Court in expeditiously resolving the case and would resolve more than mere tangential issues. The letter must set forth the basis for the proposed motion for summary judgment, with citations to relevant authority, and the issue(s) expected to be resolved by the motion. Within five (5) business days after receipt of this letter, all adversaries must submit a written response, not to exceed three (3) single-spaced pages. No party may submit a reply letter unless directed by the Court. This rule is intended to be read in concert with Section I.E.1.
Page 4 | 2. Statements of Material Fact
Adjournment & Extension Requirements
Adjournment/extension requests must comply with Local Civil Rule 6.1 and include specified information; unreasonable withholding of consent may result in fees.
All requests for adjournments or extensions of time, other than those pursuant to Local Civil Rule 7.1(d)(5), must comport with Local Civil Rule 6.1 and include: (1) the date or dates sought to be extended; (2) the number of previous requests for extensions and the Court’s rulings; (3) the reason for the current request; and (4) whether the adversary consents and, if not, the reasons given by the adversary for refusing to consent. If consent is unreasonably withheld, the Court may impose attorneys’ fees and costs. If the requested extension affects any other scheduled dates/deadlines, the request must list the proposed change for all such other dates/deadlines.
Page 2 | I.C. Adjournments
Chambers Communication Rules
All communications with Chambers must be by letter filed via CM/ECF; no hard copies or courtesy copies of letters may be delivered, and pro se parties are exempt.
All communications with Chambers shall be by letter electronically filed via CM/ECF. No hard copies or courtesy copies of letters shall be delivered to the Court. Pro se parties are exempt from this requirement.
Page 5 | III.C Letters
Do not contact Chambers with legal or procedural questions already covered by these Rules, the Local Rules, or the Federal Rules.
Please do not contact Chambers with legal or procedural questions that are covered by these Rules, the Local Rules of this Court, or the Federal Rules of Civil or Criminal Procedure.
Page 5 | III.A Telephone Calls
Chambers does not accept fax or email communications.
Chambers does not accept fax or e-mail.
Page 5 | III.B Fax and E-Mail
Contact Courtroom Deputy Larry MacStravic at (856) 757-5433 between 9:00 a.m. and 4:00 p.m. for docketing, scheduling, or calendar matters.
For docketing, scheduling, or calendar matters, please contact Courtroom Deputy Larry MacStravic at (856) 757-5433 between 9:00 a.m. and 4:00 p.m.
Page 5 | III.D Docketing, Scheduling, or Calendar Matters