District of New Jersey Document Filing Requirements

Proposed order required with any submission seeking relief.

Source text: If any relief is being sought, a proposed order must accompany the party's submission.

Summary judgment motions require separately filed statement of material facts with citations to record evidence.

Source text: 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.

Opposing summary judgment requires separately filed response to each material fact with dispute status and citations.

Source text: 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.

RICO claims require filing a RICO Case Statement within 30 days of complaint.

Source text: 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.

Pre-trial briefs and in limine motions due 3 weeks before trial; responsive papers due 2 weeks before.

Source text: 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).

Joint jury questionnaire due 3 weeks before trial in hard copy and Word format on USB.

Source text: 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).

Joint requests to charge due 3 weeks before trial in hard copy and Word format on USB.

Source text: 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. Any additional or contested proposed charges that could not be agreed upon by the parties should be submitted by the propounding party to the Court at the same time.

Proposed jury charges must cite authority; exceptions require court approval; non-compliance may result in adjournment and fees.

Source text: Counsel shall cite to the applicable authority for each proposed charge. 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).

Joint verdict sheet (hard copy + Word USB) due 3 weeks before trial; separate sheets if no agreement; exceptions require court approval.

Source text: 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. If counsel cannot agree on a joint verdict sheet, counsel shall separately submit proposed verdict sheets in the same manner. 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).

Exhibit/witness lists due 1 week before trial; pre-marked exhibits; no courtesy copies unless requested; custody retained until closings; special handling for weapons/narcotics.

Source text: 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. The parties shall not send courtesy copies of trial exhibits unless the Court requests them. Counsel shall retain custody of their trial exhibits until closings. Chief Judge Bumb does not send weapons, narcotics, currency and the like into the jury room. If jurors wish to see such an exhibit during deliberations, they are permitted to do so in the emptied courtroom with only a United States Marshal or Courtroom Security Officer present. The prosecuting attorney and/or investigating agency is generally required to maintain custody of exhibits such as weapons, narcotics, or currency during trial.

Deposition designations and objections due 2 weeks before trial; non-compliance may result in preclusion.

Source text: 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. A party’s failure to comply with this rule may result in the Court precluding a party from using

Extension requests must be filed via ECF with proposed order and indicate party consent.

Source text: All requests for extensions shall be filed via ECF and be accompanied by a proposed order. Any requests for extensions shall indicate whether all parties consent.

Motions for final judgment by default must include a brief addressing all required elements.

Source text: All motions for final judgment by default pursuant to Fed. R. Civ. P. 55(b)(2) shall include a brief which addresses each of the elements necessary to support the entry of a final judgment by default.

Responses to Statements of Material Facts must include both the fact and response in a single document.

Source text: When responding to a Statement of Material Facts, the responding party should include the fact that they are responding to and provide a response as to whether it is admitted or denied in a single document. Stated differently, any response must include both the fact as stated by the moving party, and the opposing party's response, in a single document (i.e., similar to the usual format for interrogatory responses). Non-compliant filings will be administratively terminated and required to be re-filed.

Unincorporated business organizations are citizens of all states where their members/partners are citizens for diversity jurisdiction purposes.

Source text: Limited liability companies, limited partnerships, and general partnerships are unincorporated business organizations. For the purposes of subject-matter jurisdiction pursuant to 28 U.S.C. § 1332 — commonly known as diversity jurisdiction — in a civil action, unincorporated business organizations are deemed to be citizens of all states in which all of their members and/or partners are citizens, and not simply the states in which they were formed or have their principal places of business.

Must plead names and citizenships of all members/partners, tracing through layers of unincorporated entities.

Source text: When diversity jurisdiction is asserted in an action, and when a party is an unincorporated business organization, the Court expects the following for purposes of determining the citizenship of that unincorporated business organization: (a) The name and citizenship of each member (including managing managing partners, general partners, and limited partners) of that unincorporated business organization must be specifically pleaded; and (b) When a member and/or a partner thereof is itself an unincorporated business organization, the citizenship of that member and/or that partner must be traced and analyzed accordingly.

RICO claims require filing a RICO Case Statement within 30 days of complaint.

Source text: In all matters in which the complaint contains a RICO claim, pursuant to 18 U.S.C. §§ 1961—1968, plaintiff(s) must file a RICO Case Statement within 30 days of filing the complaint, in accordance with Appendix O of the Local Civil Rules & Appendices found at: https://www.njd.uscourts.gov/local-rules-and-appendices.

Parties must consult Judge Salas's General Pretrial and Trial Procedures before submitting this document.

Source text: Before submitting this document, the parties are to consult “JUDGE ESTHER SALAS’S GENERAL PRETRIAL AND TRIAL PROCEDURES.”

Pretrial submissions in paragraphs 2, 18, and 19 must be filed 45 days before trial or will be waived.

Source text: the pretrial submissions detailed in ¶¶ 2, 18 and 19 below are to be submitted no later than forty-five (45) days prior to trial (or as otherwise ordered by the Court) or they will be deemed waived;

Trial brief or memorandum required under Local Civil Rule 7.2 for non-jury trials

Source text: Each side shall submit to the Court and opposing counsel a trial brief or memorandum in accordance with Local Civil Rule 7.2 with citation to authorities and arguments in support of its position on all disputed issues of law.

Proposed findings of fact and conclusions of law required within one week after non-jury trial

Source text: Following a non-jury trial, proposed findings of fact and conclusions of law must be submitted to the Court within one week of the close of trial (or as otherwise ordered by the Court). Submitting litigants must include specific reference to testimonial or documentary evidence in support of the proposals.

Three copies of bench book with exhibits required

Source text: Additionally, the parties must prepare three copies of the bench book containing the exhibits that they expect to use.

Must send contemporaneous copies to all litigants

Source text: All litigants should be sent a contemporaneous copy of all correspondence sent to the Court.

Written requests to court must include situation, opposing party position, and specific relief

Source text: Any written communication requesting action by the Court on any subject should include at a minimum: (1) a very brief description of the situation requiring the Court’s attention; (2) the position of the opposing party(ies) (i.e., consent or opposition); and (3) the specific relief sought.

All important factual assertions must be supported by pinpoint citations.

Source text: Every factual assertion considered by the submitting litigant to be important to that litigant's position in a motion, opposition, or brief must be supported by citation or other specific reference to the record where that fact may be found. Legal and record citations must be 'pinpoint cites.'

Summary judgment motions require statement of undisputed material facts.

Source text: On motions for summary judgment, the movant shall furnish a statement which sets forth material facts as to which there does not exist a genuine issue, in separately numbered submitted in support of the motion. A motion for summary judgment unaccompanied by a statement of material facts not in dispute shall be dismissed.

Opposition to summary judgment must respond to each factual assertion.

Source text: A litigant opposing summary judgment must state in similar paragraph form whether that litigant agrees or disagrees that the fact(s) as stated by the moving litigant are undisputed. If a litigant contends that a fact is in dispute, citation must be made to the record evidence that supports the litigant’s view of that particular fact. Failure to address the moving party’s factual contentions in this manner will lead to the Court’s consideration of the moving party’s factual assertion(s) as undisputed.

TRO/injunction hearings require proposed findings and conclusions.

Source text: Submission of proposed findings of fact and conclusions of law for TRO and injunction hearings will be required. The time for submission of these items will be set at the pre-hearing conference.

Submit 3 copies of bench book of trial exhibits; update 2 copies in courtroom at 4:30 pm if exhibits change.

Source text: Litigants shall also submit three (3) copies of the bench book of trial exhibits, unless otherwise advised by Chambers. The Courtroom Deputy will use the originals. However, during the course of trial, if litigants change exhibit tabs or add new exhibits, litigants must update two copies that will be left in the Courtroom at 4:30 pm. These copies are for the Judge and the Law Clerk assigned to the trial.

Submit combined neutral statement of facts in column format showing plaintiff and defendant proposals.

Source text: The litigants should submit a short proposed statement of the case that the Court will read during jury selection as part of the Court’s initial statements. Any disagreements by the litigants should be submitted in column form. The column on the left will contain Plaintiff’s (or the Prosecution’s) proposals. The column on the right will contain the Defendant’s proposals.

Submit combined jury instructions and verdict sheet with disagreements shown in columns.

Source text: Instead of separate submissions from the litigants, Judge Salas requires one combined submission, identifying any areas of disagreement. Where the litigants are unable to agree, the submission should be split into two columns as discussed above.

Model jury instructions must indicate if unchanged or modified; modifications must underline additions and bracket deletions.

Source text: If a model jury instruction is submitted, for instance, from the Third Circuit Model Instructions at http://www.ca3.usCourts.gov/modeljuryinstructions.htm, Devitt & Blackmar, Federal Jury Practice and Instructions, or Sand, Modern Federal Jury Instructions, the submitting litigant shall state whether the proposed jury instruction is unchanged or modified. If a litigant modifies a model jury instruction, additions should be underlined and deletions placed in brackets.

Juror note-taking prohibited.

Source text: Judge Salas does not permit jurors to take notes.

Juror questions to witnesses prohibited.

Source text: Judge Salas does not permit jurors to submit questions to the Court to be posed to a witness.

Trial briefs must be submitted no later than 45 days before trial.

Source text: Generally, Judge Salas requires the submission of trial briefs no later than forty-five (45) days before trial.

In limine motions are typically due 45 days before trial.

Source text: Submission dates for in limine motions are set during the initial telephone conference with Judge Salas following the Magistrate Judge’s final pretrial conference. Typically, in limine motions are due forty-five (45) days before trial.

Witnesses may not testify about exhibit content until it is admitted into evidence.

Source text: Generally, unless the litigants have an agreement as to the admissibility of a proposed exhibit, a witness may not testify as to its content until it has been admitted into evidence.

Depositions must be used for essential witnesses who may be unavailable at trial.

Source text: Because a witness may be unavailable at the time of trial, as defined in Federal Rule of Civil Procedure 32(a)(3), the Court expects oral or videotaped depositions to be used at trial for any witness whose testimony a litigant believes essential to the presentation of that litigant’s case, whether the witness is a party, a non-party, or an expert. The unavailability of such witness will not be a ground to delay the commencement or progress of trial.

Lay witness opinion testimony requires same disclosure as expert witnesses.

Source text: Any litigant expecting to offer opinion testimony from lay witnesses pursuant to Federal Rule of Evidence 701 with respect to issues of liability or damages shall, at the time required for submission of expert reports, serve the opposing litigants with the same information and/or documents required with respect to such expert witnesses.

Exhibits generally available to jury unless good cause shown.

Source text: Unless good cause is shown, Judge Salas will permit all exhibits containing substantive or real evidence to be available to the jury for deliberation. Litigants should confer with each other as to which exhibits should go into the jury room. Before deliberation, litigants will confer with the Courtroom Deputy to confirm which exhibits including demonstratives (and which versions of exhibits) will go into the jury room.

Litigants must remain near courthouse during jury deliberations.

Source text: Unless excused by the Court, litigants should remain in the Courthouse during jury deliberations, and, in any event, be no more than 10 minutes away from the Courthouse.

Moving submissions must be served to Court at least 10 business days before sentencing.

Source text: Unless otherwise ordered by the Court, a party moving for a variance, downward departure, or submission in mitigation of a sentence (a “Moving Submission”) is instructed to directly serve the Court, in accordance with the procedures set forth in subsection ii below, no fewer than ten (10) business days prior to the sentencing date.

Responsive submissions must be served to Court at least 5 business days before sentencing.

Source text: The responsive party’s submission (a “Responsive Submission”) to any related motions... no fewer than five (5) business days prior to the sentencing date.

Sentencing materials must be submitted directly to Court and copied to counsel and probation department.

Source text: All sentencing memoranda, along with all supporting exhibits and correspondence (collectively, the “Sentencing Materials”), shall be submitted directly to the Court. The submitting party is also expected to furnish copies to all Counsel of Record and the United States Probation Department.

Submission Notice must be filed on CM/ECF, but memorandum itself need not be.

Source text: Although the submitting party is not required to file its memorandum on the Court’s CM/ECF system, the submitting party is required to file a notice via CM/ECF (a “Submission Notice”) on the form prescribed by the Clerk of the Court.

Public/press must file Request for Disclosure within 48 hours of Submission Notice.

Source text: Any interested member of the public or press who wishes to obtain a copy of the Sentencing Materials (a “Requestor”) must make a Request for Disclosure on a form prescribed by the Clerk of the Court within 48 hours of receiving the Submission Notice.

All documents for Court or jury must first be given to Courtroom Deputy.

Source text: Any and all documents to be provided to the Court or viewed by the jury should first be handed to the Courtroom Deputy.

GAI use in filings requires mandatory disclosure/certification of program, portion drafted, and human review.

Source text: The use of any GAI (e.g., OpenAI’s ChatGPT or Google’s Bard) in any court filings requires a mandatory disclosure/certification that: (1) identifies the GAI program; (2) identifies the portion of the filing drafted by GAI; and (3) certifies that the GAI work product was diligently reviewed by a human being for accuracy and applicability. A failure to comply with this requirement may result in sanctions, such as the filing being stricken, and/or a referral to a bar disciplinary committee.

Witnesses prohibited from private conversations with jurors at any time during trial.

Source text: Litigants have the responsibility to advise witnesses that no witness may talk to the jury at any time during the pendency of the case. For example, if the witness has stepped down from the witness stand to testify as to an exhibit, the witness should not have any private conversation whatsoever with any juror.

Trial briefs must be submitted 45 days before trial.

Source text: Judge Padin requires the submission of trial briefs no later than forty- five (45) days before trial.

In limine motions typically due 45 days before trial.

Source text: Submission dates for in limine motions are set during the initial telephone conference with Judge Padin following the Magistrate Judge’s final pretrial conference. Typically, in limine motions are due forty-five (45) days before trial.

Proposed findings of fact and conclusions of law required in non-jury cases with specific formatting.

Source text: The Court will set a timeframe for submitting proposed findings of fact and conclusions of law in non-jury cases depending on the complexity of the matter. The Court will generally require litigants to submit a joint submission of proposed findings of fact in column format as follows: (1) in each column, litigants must provide consecutively numbered paragraphs with headings and subheadings to indicate issues and sub-issues; (2) litigants must indicate which facts are agreed upon; and (3) litigants must include specific reference to testimonial or documentary evidence in support of the proposals.

Extension requests must be filed via CM/ECF.

Source text: All requests for extensions shall be filed via CM/ECF.

All pleadings, motions, and letters must be filed via CM/ECF.

Source text: All pleadings, motions, and letters to the Court (except for confidential settlement position letters) must be filed via CM/ECF.

Extension/adjournment requests must indicate party consent.

Source text: Any requests for extensions or adjournments shall indicate whether all parties consent.

Pro se parties must file directly with clerk's office.

Source text: Parties appearing pro se must file all documents, applications, and motions directly with the Clerk’s Office.

Exhibit index required 3 weeks before trial with witness identification.

Source text: At least three weeks before the start of trial, counsel for all parties must submit an exhibit index. The list must identify the witness through which each exhibit will be introduced. Counsel must also denote exhibits that will be marked for identification but not moved into evidence.

Deposition designations and objections due 2 weeks before trial.

Source text: 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 weeks before trial.

Parties must confer with Courtroom Deputy before jury deliberation.

Source text: Before the case goes to the jury, parties must confer with the Courtroom Deputy to ensure the exhibits going to the jury room are all in evidence and in good order.

Proposed order required with any motion seeking relief.

Source text: If any relief is being sought, a proposed order must accompany the CM/ECF filing.

RICO case statement required within 30 days of complaint filing.

Source text: 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 here.

Summary judgment motions require statement of material facts with citations.

Source text: Motions for summary judgment must be accompanied by a statement of material fact. 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.

Opposing summary judgment motions must respond to each fact with dispute status and citations.

Source text: If a summary judgment motion is opposed, the opposing party shall set forth, in a single 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.

Default judgment motions must include brief addressing all required elements.

Source text: All motions for default judgment under Federal Rule of Civil Procedure 55(b)(2) shall include a brief that addresses each of the elements necessary to support the entry of a final judgment by default.

Joint letter required 2 days before oral argument for multiple counsel or witness testimony.

Source text: If multiple counsel will be arguing on each side or the parties intend to introduce live witness testimony, two (2) days before the scheduled appearance, counsel shall file a joint letter in CM/ECF with the parties' proposed (a) order of presentation for each party or issue and (b) division of the allotted argument time for each counsel and party.

Responsive papers must be submitted at least 3 weeks before trial.

Source text: Any responsive papers shall be submitted at least three (3) weeks before the start of trial.

Parties must consult with Courtroom Deputy daily about exhibits.

Source text: Parties must consult with each other and with the Courtroom Deputy at the end of each trial date and compare notes as to which exhibits are in evidence and any limitations thereon.

Pre-trial submissions due 4 weeks before trial in hard copy and electronic format.

Source text: Four (4) weeks before trial, the parties shall submit in hard copy form and an electronic version, preferably in Word, via email to Judge Neals’s law clerk the following pre-trial submissions:

Jury charges must include citations in footnotes.

Source text: Each proposed charge shall include citations to the applicable authority using footnotes.

Counsel must specify which charges to give before and after trial.

Source text: 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.

Parties must provide revised exhibit list for jury room.

Source text: Parties shall provide a revised list of all exhibits in evidence (and no others) stating the exhibit number and a brief, non-argumentative description.

Sentencing memoranda must be emailed to judge with copies to counsel and probation department, plus CM/ECF notice.

Source text: All Sentencing Memoranda, along with all supporting exhibits and correspondence (collectively, the “Sentencing Materials”), shall be submitted directly to the Court via email (njdnef_neals@njd.uscourts.gov). The submitting party is also expected to furnish copies to all Counsel of Record and the United States Probation Department. Although the submitting party is not required to file its memorandum on the Court’s CM/ECF system, it must file a notice via CM/ECF (a “Submission Notice”) on the form prescribed by the Clerk of the Court.

In limine motions due 3 weeks before trial; responsive papers due 2 weeks before trial.

Source text: Once the joint final pretrial order has been filed in a civil case, each party shall submit any in limine motions at least three weeks before the start of trial. Any responsive papers shall be submitted at least two weeks before the start of trial.

Joint jury questionnaire (hard copy + email) due 3 weeks before trial.

Source text: Counsel for all parties must confer with each other prior to trial and submit a joint jury questionnaire three weeks before trial in hard copy form and via email (njdnef_Williams@njd.uscourts.gov). Any additional proposed questions that could not be agreed upon should be submitted by the propounding party to the Court at the same time.

Joint jury charges (Word format + email) due 2 weeks before trial.

Source text: Counsel for all parties must confer with each other prior to trial and submit joint requests to charge two weeks before trial in hard copy form and via email (njdnef_Williams@njd.uscourts.gov) in Word format. Any additional proposed charges that could not be agreed upon should be submitted by the propounding party to the Court at the same time.

Joint verdict sheet (Word format + email) due 2 weeks before trial.

Source text: Counsel for all parties must confer with each other prior to trial and submit a joint verdict sheet two weeks before trial in hard copy form and via email (njdnef_Williams@njd.uscourts.gov) in Word format. If counsel cannot agree on a joint verdict sheet, counsel shall separately submit proposed verdict sheets in the same manner.

All trial exhibits must be digitized and uploaded to dedicated server.

Source text: All parties are required in advance of trial to digitize all evidence expected to be used at trial. When introduced into evidence, the exhibit is downloaded onto a dedicated server. During deliberations each juror will review the admitted evidence with an iPad which can only access the dedicated server.

Proposed orders in searchable PDF required when relief is sought.

Source text: Proposed Orders: If any relief is being sought, the CM/ECF filing must be accompanied by a proposed order in searchable PDF format.

Pro se litigants must file with Clerk's Office, not Judge Kirsch.

Source text: Pro se Filings: All filings by pro se litigants shall be mailed to or filed directly with the Clerk’s Office, NOT Judge Kirsch.

Extension requests must include a proposed order.

Source text: The request shall indicate the current and proposed dates and include a proposed form of order.

Motions to amend must attach a blacklined or redlined proposed amended complaint showing the proposed changes.

Source text: Motions to amend pleadings must include as an exhibit a black- or red-lined proposed amended complaint, which clearly indicates the proposed changes.

The sealing-related motion/request must include a proposed order and proposed findings of fact and conclusions of law.

Source text: must include a proposed order and proposed findings of fact and conclusions of law.

If parties submit a confidentiality order differing from Appendix S, they must provide a clean signature-ready proposed order.

Source text: (1) a clean version of the proposed order that is ready for signature,

If parties submit a non-Appendix S confidentiality order, they must also submit a marked comparison copy showing deletions and additions.

Source text: (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.

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.

Source text: 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).

Pro hac vice applications must include a proposed order.

Source text: A proposed form of order must be submitted.

Discovery extension or amended scheduling requests must include a proposed order.

Source text: Any such request shall include a proposed order.

The joint discovery dispute letter must include specified content items, including positions of both sides and meet-and-confer efforts.

Source text: 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.

Each party must submit a confidential settlement memorandum before the settlement conference.

Source text: 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.

Parties must submit a joint proposed final pretrial order before the final pretrial conference.

Source text: 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.

Motions to amend must include black/red-lined proposed amended complaint; failure results in administrative termination.

Source text: 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.

Motions must include proposed order and proposed findings of fact and conclusions of law; failure to comply results in administrative termination.

Source text: 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.

Pro hac vice applications on consent require informal CM/ECF filing with consent letter, admission certification, local counsel certification, and proposed order; if not consented, proceed by motion.

Source text: 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.

Extension/amended scheduling order requests must indicate current/proposed dates, consent status, and include proposed order.

Source text: 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.

Discovery disputes must follow Local Rules 16.1 and 37.1; unresolved disputes brought via joint letter (max 5 pages) with specific content requirements.

Source text: 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.

Joint proposed final pretrial order due 5 business days before conference.

Source text: 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.

Pro hac vice applications must be emailed to Angela DiAndrea with consent letter.

Source text: Applications for admission pro hac vice shall comply with L.Civ.R. 101.1(c) and shall be emailed, along with a cover letter advising the court whether there is adversary consent, to courtroom deputy Angela DiAndrea at Angela_DiAndrea@njd.uscourts.gov.

Trial submissions due 10 days before trial via email to Angela DiAndrea.

Source text: Trial Submissions. Trial briefs, proposed voir dire questions, proposed jury instructions, lists of pre-marked exhibits (tabs), witness lists including the name and address of each potential witness, and requests to charge should be submitted by counsel at least ten days prior to the commencement of the trial by email to Courtroom Deputy Angela DiAndrea: Angela_DiAndrea@njd.uscourts.gov

Settlement memoranda must include specific required content elements.

Source text: Settlement memoranda must include the following: (i) a brief description of the action, the claims and/or counterclaims asserted, and the applicable defenses and/or positions concerning the asserted claims, counterclaims, and/or defenses; (ii) a specific and current demand or offer of settlement addressing all relief or remedies sought; (iii) a brief description of any prior settlement offers, if any, mediation sessions, or mediation efforts; and (iv) a brief delineation of any non-monetary terms and/or conditions necessary for settlement.

All parties and representatives with settlement authority must appear in person.

Source text: All parties, adjusters for insured defendants, and other party representatives with full and complete settlement authority, as well as the principal attorneys responsible for the litigation, shall appear in person and remain available for the duration of the settlement conference.

Corporate entities must have both corporate representative and outside counsel present.

Source text: As set forth supra, in addition to principal attorneys responsible for the litigation, a party or party representative with full settlement authority must be present for the settlement conference. In the case of a corporate entity, an authorized representative of the corporation, in addition to retained outside counsel, must be present.

Exhibits must be physically pre-marked.

Source text: Counsel are reminded that each such exhibit shall be physically pre-marked

Hypothetical questions for experts must be submitted in writing before trial.

Source text: If any hypothetical questions are to be put to an expert witness on direct examination, they shall be written in advance and submitted to the court and counsel prior to commencement of trial.

Only listed exhibits may be introduced at trial; objections must be noted.

Source text: In this section of the Final Pretrial Order, counsel should number each proposed exhibit and upon receipt of the exhibit list of an adversary, opposing counsel should prepare a response to this exhibit list indicating as to each exhibit whether there will be an objection and if there is, the nature of the objection. Absent an extraordinary showing of good cause, ONLY THE EXHIBITS LISTED BELOW SHALL BE INTRODUCED AT THE TIME OF TRIAL.

Only listed witnesses may testify; objections must be noted with reasons.

Source text: Only the witnesses whose names and addresses are listed herein will be permitted to testify at the time of trial. For each witness listed, there must be a description of their testimony. Any objection to a witness must be noted by opposing counsel and for each such witness objected to, the name of the witness and the reason for the objection shall be given.

Only experts listed in the pretrial order may testify.

Source text: Any prior Scheduling Order of the court concerning experts is applicable to this action and the directives of the Scheduling Order shall govern expert testimony in this case. Any expert not listed in this portion of the Final Pretrial Order shall not be permitted to testify at the time of trial.

Expert CVs must be attached to the pretrial order.

Source text: Additionally, the curriculum vitae of every expert expected to testify at the time of trial shall be attached to this Final Pretrial Order.

Opposing counsel must receive expert CVs and Rule 26(a)(2) information before testimony.

Source text: No expert will be permitted to testify at trial unless all opposing counsel have received the curriculum vitae of the expert and the information required by Fed.R.Civ.P. 26(a)(2) as directed in the Scheduling Order.

Proposed findings of fact must be submitted 7 days before trial.

Source text: No later than seven days prior to the scheduled trial date, counsel for each party shall submit to the District Judge, with a copy to opposing counsel, proposed findings of fact and

Trial brief must be submitted 7 days before trial and electronically filed.

Source text: No later than seven days prior to the scheduled trial date or at such time as the court may direct: Each party shall submit to the District Judge and to opposing counsel a trial brief or memorandum with citations and authorities and arguments in support of the party's position on all issues of law. The trial brief shall be electronically filed.

Jury charge requests must be submitted 7 days before trial with specific formatting.

Source text: Each party shall submit to the District Judge and to opposing counsel written requests for charges to the jury. Supplemental requests to charge that could not have been anticipated may be submitted any time prior to the arguments to the jury. All requests for charge shall be on a separate page or pages, plainly marked with the name and number of the case; shall contain citations of supporting authorities; shall designate the party submitting same; and shall be numbered in sequence.

Proposed requests for charge should be submitted on Work Perfect disk and electronically filed with paper copy.

Source text: IF you have the capability, the Proposed Requests for Charge should be submitted on computer disk, Work Perfect format. All proposed requests for charges shall be electronically filed, and a paper copy must also be provided.

Proposed voir dire questions must be submitted 7 days before trial.

Source text: Each party shall submit to the judge and to opposing counsel proposed voir dire questions.

All trial preparation items must be filed before the first trial date even if continued.

Source text: EACH OF THESE ITEMS IS TO BE FILED PRIOR TO THE FIRST TRIAL DATE EVEN IF THE CASE IS CONTINUED.

Motions to amend must include black/red-lined proposed amended pleading as exhibit; no leave of court required.

Source text: Motions to amend a pleading must comply with Local Civil Rule 15.1. Pursuant to the rule, such motions must include as an exhibit a black- or red-lined proposed amended pleading that clearly indicates the proposed changes. Failure to do so may result in administrative termination of the motion. Motions to amend shall not require leave of Court.

Proposed order with findings and conclusions required for motions to seal.

Source text: Along with the motion to seal, the moving party shall submit a form of order containing proposed findings of fact and conclusions of law concerning the factors set forth in Local Civil Rule 5.3(c).

Joint Discovery Plan must be filed on CM/ECF 5 business days before Rule 16 conference.

Source text: The Court's form Joint Discovery Plan may be found at https://www.njd.uscourts.gov/sites/njd/files/forms/R16DiscoveryPlan_1.pdf. The parties shall file their completed Joint Discovery Plan on CM/ECF no later than five (5) business days before the scheduled Rule 16 conference.

Bail requests require consultation with USAO and assessment by Pretrial/Probation Officer.

Source text: The Court will not consider a request for bail or bail modification until after defense counsel has consulted with the U.S. Attorney's Office and until the U.S. Pretrial Services Officer or the U.S. Probation Officer has assessed the proposed bail package.

Opposed continuances require filing a motion on CM/ECF.

Source text: If one party opposes the entry of a continuance order, the moving party must file a motion on CM/ECF.

Discovery plan must be submitted 5 business days before Initial Scheduling Conference.

Source text: At least fourteen (14) days prior to the Initial Scheduling Conference, counsel shall personally meet and confer pursuant to Rule 26(f) and shall jointly submit a discovery plan to this Court not later than five (5) business days prior to the conference with the Court.

No formal discovery demands before Initial Scheduling Conference.

Source text: No formal discovery demands may be issued before the Initial Scheduling Conference, other than as permitted by Rule 26(d).

Counsel must have full authority to bind clients at Initial Scheduling Conference.

Source text: At the Initial Scheduling Conference, all parties who are not appearing pro se must be represented by counsel who shall have full authority to bind their clients in all pretrial matters. Counsel shall also be prepared to discuss the merits of the case and shall have settlement authority.

Plaintiff's counsel must notify new parties about this Order.

Source text: Counsel for the plaintiff(s) shall notify any party who enters an appearance after the Initial Scheduling Conference is scheduled about this Order and shall forward to that party a copy of this Order.

Pro hac vice applications require adverse party consent and disclosure.

Source text: Counsel may file unopposed applications for pro hac vice admission. Counsel should obtain the consent of adverse parties prior to filing the application and shall advise, in both the cover letter and the proposed order, of such consent.

Pro hac vice applications must comply with Local Civil Rule 101.1(c).

Source text: Counsel shall follow the requirements of Local Civil Rule 101.1(c) with regard to the contents of the proposed form of order and the supporting certifications of local counsel and each proposed pro hac vice attorney.

Joint Discovery Plan must use specific form from court website.

Source text: The parties shall submit a Joint Discovery Plan using the attached form available at: https://www.njd.uscourts.gov/sites/njd/files/forms/R16DiscoveryPlan_1.pdf.

Discovery dispute letters must be double-spaced, max 10 pages, and identify requests, responses, and resolution efforts.

Source text: The party(ies) seeking relief shall file a letter with the Court, which shall be double-spaced shall not exceed ten (10) pages, regardless of the number of disputed issues. The letter must identify the relevant request(s), the response(s) to the request(s), and the efforts taken to resolve the dispute.

Motions to amend must include proposed amended pleading with tracked changes.

Source text: Motions to amend must comply with Local Civil Rule 15.1 and shall be accompanied with a proposed amended pleading with black- or red-lined edits that clearly indicate the proposed changes.

Joint proposed final pretrial order due 3 weeks before conference via email and mail

Source text: The parties shall submit, by email and regular mail, one (1) copy of the joint proposed final pretrial order no later than three (3) weeks before the conference.

Joint status letter required 3 days before status conference.

Source text: The Court will conduct a telephone status conference on Click here to enter a date. at ___ ; Counsel for Plaintiff is directed to initiate the call to (609) 989-2144. The parties are directed to submit a joint status letter three (3) days prior to the conference.

Lead counsel and client with settlement authority must attend settlement conferences.

Source text: Counsel should be prepared to discuss settlement at every conference with the Court. Lead trial counsel and client(s) with full settlement authority are required to appear at any settlement conference conducted by the Court. In cases involving insurance companies and other corporate or business entities, it is expected that the executive who will make the final decision regarding settlement will be the person available for the conference.

Discovery disputes must be resolved through joint letter following Local Civil Rules 16.1 and 37.1.

Source text: Discovery disputes and applications shall proceed in accordance with Local Civil Rules 16.1 and 37.1. Should counsel fail in their good faith efforts to resolve the dispute by conferring pursuant to Local Civil Rule 37.1, the matter shall be brought to the Court’s attention through a joint letter 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.

Motions to amend require proposed amended pleading with black/red-line edits.

Source text: Motions to amend must comply with Local Civil Rule 15.1 and shall be accompanied with a proposed amended pleading with black- or red-lined edits that clearly indicate the proposed changes.

Joint final pretrial order must be submitted by email and mail 3 weeks before conference

Source text: The parties shall submit, by email and regular mail, one (1) copy of the joint proposed final pretrial order no later than three (3) weeks before the conference.

Motions to amend require red-lined proposed pleading and consent attempts.

Source text: Applications to amend or supplement pleadings: Motions to amend must comply with Local Civil Rule 15.1 and shall be accompanied with a proposed amended pleading with red-lined edits that clearly indicate the proposed changes. Counsel shall attempt to gain the consent of all other parties before filing the application and indicate, in the application, whether consent was obtained. If a party seeks to file a motion to amend after the deadline set by a Scheduling Order, that party must show good cause why the amendment could not have been sought earlier pursuant to Federal Rule of Civil Procedure 16.

Final pretrial order due 14 days before conference via email and mail.

Source text: Final Pretrial Conferences: The Court conducts final pretrial conferences pursuant to Federal Rule of Civil Procedure 16(e). The parties shall submit, by email to SDA_orders@njd.uscourts.gov and regular mail, one (1) copy of the joint proposed final pretrial order no later than fourteen (14) days before the conference. Counsel should check the individual rules for the presiding District Judge to obtain the preferred form of final pretrial order. The Court expects counsel to meet and confer regarding the final pretrial order in an effort to minimize disputes.

Each motion must include a proposed order in searchable PDF format.

Source text: All motions must be accompanied by a proposed order in searchable PDF format, filed via CM/ECF.

Proposed orders must be emailed in Word format to SDA_orders@njd.uscourts.gov.

Source text: In addition to filing via CM/ECF, a copy of any proposed orders should be submitted in Word format via email to SDA_orders@njd.uscourts.gov.

Non-compliance with summary judgment rules may result in striking of submission.

Source text: If a party fails to comply with these rules, the Court will likely strike that party's submission.

Hypothetical questions for expert witnesses must be submitted to court and opposing counsel

Source text: If any hypothetical questions are to be put to an expert witness on direct examination, they shall be submitted to the Court and opposing counsel.

Judge prefers model-based jury instructions and disfavors case-specific facts; include facts in summations instead.

Source text: Judge Salas strongly prefers jury instructions that track the relevant model. She disfavors jury instructions containing case-specific facts or contentions. Because Judge Salas usually charges the jury before closing arguments, and because she disfavors the inclusion of facts or contentions in the jury charge, litigants are encouraged to include facts and contentions in their summations.

Trial date takes precedence over other matters.

Source text: Once a trial date has been set, the Court expects that obligation to take precedence over other matters (except serious, unanticipated personal or professional emergencies).

Transcripts not available for jury deliberations.

Source text: Although the Court reporter will be transcribing the testimony, litigants should not assume that transcripts will be available for review by jurors during jury deliberations.

Peremptory challenges must be announced while standing; only one pass allowed without forfeiture.

Source text: Judge Salas prefers that counsel stand and announce their peremptory challenges, and Judge Salas will typically permit only one pass by a party without forfeiture.

Litigants are responsible for equipment and must have backup plans.

Source text: Equipment and the smooth presentation of exhibits in video or other electronic form is the responsibility of litigants and should be attended to with care. Back-up plans in the event of equipment failure should be available.

Requests after 48 hours may not be considered before sentencing.

Source text: A Request for Disclosure made after 48 hours of receiving the Submission Notice may or may not be considered by the Court prior to the sentencing hearing.

Defendant and counsel are not ordinarily permitted to review Probation Department's sentencing recommendations.

Source text: Judge Salas will not ordinarily permit the defendant or counsel for either party to review the Probation Department's recommendations regarding sentencing.

Jury instructions should track model instructions and avoid case-specific facts.

Source text: Judge Padin strongly prefers jury instructions that track the relevant model. She disfavors jury instructions containing case-specific facts or contentions except where absolutely necessary.

Objections must be stated briefly with basis; speaking objections disfavored.

Source text: If a litigant wishes to make an objection, he or she should stand, state the objection, and simply state the basis for the objection, such as “hearsay” or “relevance.” The Court disfavors speaking objections.

Directed verdict motions should be in writing where possible.

Source text: Motions for judgment as a matter of law in jury trials and motions for an involuntary dismissal in non-jury trials should be in writing where possible.

Mailed documents must be addressed to clerk's office, not judge.

Source text: Documents mailed to the courthouse must be addressed to the Clerk’s Office and not to Judge Castner.

Settlement after jury summons may result in jury cost assessment.

Source text: If an action is settled after the jury has been summoned or during trial, the parties are reminded that the Court is likely to assess the costs of empaneling the jury on the parties and/or their attorneys.

Only one pass allowed without forfeiture of peremptory challenge.

Source text: Judge Neals will typically permit only one pass by a party without forfeiture.

Weapons, narcotics, currency not sent to jury room.

Source text: Judge Neals does not send weapons, narcotics, currency, and similar items into the jury room.

Weapons/narcotics/currency not sent to jury room; viewed in courtroom with marshal.

Source text: Judge Williams does not send weapons, narcotics, currency, and the like into the jury room. If jurors wish to see such an exhibit during deliberations, they are permitted to do so in the emptied courtroom with only a Deputy Marshal present.

Notice required for electronic demonstrative evidence.

Source text: If counsel intends to use electronic demonstrative evidence at trial, notice should be given to the Courtroom Deputy and all parties as soon as possible.

Defendant and counsel cannot review probation sentencing recommendation.

Source text: Judge Williams does not permit the defendant or counsel to review the Probation Department’s recommendation as to sentencing.

Counsel must make every effort to obtain opposing counsel's consent for a sealing request.

Source text: Counsel shall make every effort to secure the consent of opposing counsel regarding the request to seal.

Use Appendix S confidentiality order form; if submitting own version, must provide clean version and version showing differences with brackets/strikes/underscores.

Source text: 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.

Electronic demonstrative evidence requires 10-day advance notice.

Source text: If counsel intends to use electronic demonstrative evidence at trial, please notify the Court at least 10 days in advance of trial.

Joint Final Pretrial Order must follow form instructions; non-compliance may result in sanctions.

Source text: The Joint Final Pretrial Order must be signed by all counsel and submitted to the United States Magistrate Judge in accordance with the directives in the Scheduling Order. Attorneys who submit a proposed Joint Final Pretrial Order to the court that indicates they have not followed the form and instructions that are provided herewith greatly impede the processing of litigation in this court and create burdens for the court and its staff which are unnecessary. A persistent pattern of conduct in this regard by any attorney will result in the imposition of sanctions.

Failure to cooperate on Joint Final Pretrial Order or obey orders may result in sanctions.

Source text: Sanctions may be imposed for the unexcused failure of counsel to cooperate in submitting the Joint Final Pretrial Order when due, or for failing to obey a Scheduling Order or Discovery Order. See Rules 16(f) and 37(b)(2) and (g), Federal Rules of Civil Procedure.

Failure to comply with trial preparation deadlines may result in trial postponement, costs, or sanctions.

Source text: COUNSEL ARE ON NOTICE THAT FAILURE TO PROVIDE TIMELY COMPLIANCE WITH THE REQUESTS OF PART X AND XI MAY RESULT IN THE POSTPONEMENT OF TRIAL AND THE ASSESSMENT OF JUROR AND OTHER COSTS AND/OR THE IMPOSITION OF SANCTION.

Discovery confidentiality orders must include clean and redline versions if differing from Appendix S.

Source text: The parties are encouraged to use the form discovery confidentiality order found in Appendix S of the Local Civil Rules. If the parties submit a confidentiality order that differs from Appendix S, they must submit: (1) a clean version of the proposed order that is ready for signature; and (2) a redline version that indicates the differences between the proposed order and the Appendix S order.

Objections at depositions limited to form and privilege only.

Source text: No objections to questions posed at depositions shall be made other than as to form or privilege. See Fed. R. Civ. P. 32(d)(3)(A). No instruction not to answer shall be given unless a privilege is implicated.

Meet and confer required before bringing disputes to court.

Source text: Counsel must meet and confer in a good faith effort to resolve any discovery or case management dispute before bringing such dispute to the attention of the Court. See L. Civ. R. 16.1(f)(1). Any unresolved disputes must be brought to the Court's attention promptly, in compliance with paragraph 6 of Magistrate Judge Quinn's Case Management Order, which is available on the District Court's Website.

Failure to appear at conferences may result in sanctions.

Source text: The Court may from time-to-time schedule conferences as may be required, either sua sponte or at the request of a party. Failure to appear at such conferences, or to comply with the terms of this or any Court Order, may result in the imposition of sanctions.

Juror note taking is generally permitted.

Source text: Chief Judge Bumb allows juror note taking in most cases.

Preliminary settlement approval hearing required before final approval in class actions.

Source text: It is the Court’s practice to conduct a preliminary settlement approval hearing in advance of the final settlement approval hearing required by Fed. R. Civ. P. 23(e). At the preliminary approval hearing the parties shall be prepared to address, in a reasonably comprehensive manner, all of the factors the Court will consider at the final approval hearing, including but not limited to the factors enumerated in Fed. R. Civ. P. 23(e), Girsh v. Jepson, 521 F.2d 153, 157 (3d Cir. 1975), and In re Prudential Ins. Co. Am. Sales Practice Litig. Agent Actions, 148 F.3d 283, 323 (3d Cir. 1998).

Chief Judge Bumb conducts voir dire; follow-up questions at sidebar.

Source text: At the beginning of the trial, prospective jurors will complete the juror questionnaire. Chief Judge Bumb conducts voir dire, and any follow-up questions will be asked at sidebar.

Peremptory challenges exercised in writing, one round at a time; two passes end process.

Source text: Challenges for cause and any Batson challenges will be heard at sidebar. Peremptory challenges are exercised in writing with counsel marking challenges on a sheet presented to them by the Courtroom Deputy. Peremptory challenges are exercised in turn, with each side exercising one round of challenge(s) at a time. In the event there are two passes in succession, the process ends. A pass is otherwise considered a forfeited peremptory challenge. Chief Judge Bumb will announce any jurors that are excused.

Jurors are not permitted to submit questions to witnesses.

Source text: Chief Judge Bumb does not permit jurors to submit questions to the Court to be posed to witnesses.

Formation state and principal place of business are irrelevant for unincorporated business organization citizenship.

Source text: By way of example, the Court sets forth a hypothetical analysis of a limited liability company that is a party to an action wherein diversity jurisdiction is asserted: (a) Alpha LLC is a limited liability company formed under the laws of Oregon with its principal place of business located at 123 Main Street in Boise, Idaho. All of the members of Alpha LLC must be identified because Alpha LLC is an unincorporated business organization. Its Oregon formation and Idaho location are not relevant for a determination as to whether there is complete diversity of citizenship.

Pretrial housekeeping meeting required before jury selection.

Source text: On the business day before jury selection, or on a day otherwise specified by the Court, Judge Salas will hold an in-person housekeeping meeting with litigants.

Combined voir dire question submission required instead of separate submissions.

Source text: Instead of separate submissions from the litigants, Judge Salas requires one combined submission, identifying any questions in dispute.

Example voir dire questions provided; litigants should use similar format.

Source text: The Court will provide an example of voir dire questions that were used during a recent trial. Litigants should utilize a similar format in crafting the proposed voir dire question for their case.

Prepared voir dire script provided for counsel review before selection.

Source text: Judge Salas will provide a prepared script she will read at voir dire. The script will be available for counsel to review prior to voir dire selection.

Pretrial meeting covers exhibits, objections, voir dire, and jury instructions.

Source text: The meeting will include (but will not be limited to) marking exhibits and previewing objections, discussing the voir dire, and discussing jury instructions.

Note-taking distracts jurors from witness testimony.

Source text: Note taking is not necessary and will distract jurors from paying attention to what a witness is saying and his or her manner on the witness stand.

Jurors rely on collective memory during deliberations.

Source text: The jurors will be able to rely on their collective memory about the testimony and other evidence when the jury is deliberating.

Opening statements: 20-30 minutes; summations: 30-45 minutes.

Source text: Judge Salas normally attempts to obtain the agreement of litigants regarding time limits on opening statements and closing arguments. However, in most cases, twenty (20) to thirty (30) minutes should be adequate for an opening statement, and thirty (30) to forty-five (45) minutes should be adequate for summation.

Multiple attorneys may examine different witnesses or argue different points, but only one attorney per party may examine the same witness.

Source text: Judge Salas will permit more than one attorney for a party to examine different witnesses or to argue different points of law before the Court, but only one attorney per party may examine the same witness.

Different attorneys may give opening and summation, but each must provide the full argument.

Source text: Although Judge Salas permits different attorneys to give the opening and summation, the opening attorney must provide the full opening and the closing attorney must provide the full summation.

Motions for judgment as a matter of law or involuntary dismissal should be in writing; oral argument permitted.

Source text: Motions for judgment as a matter of law in jury trials and motions for an involuntary dismissal in non-jury trials should be in writing if at all possible. Oral argument on such motions is ordinarily permitted.

Court sets timeframe for proposed findings of fact and conclusions of law based on complexity.

Source text: The Court will set a timeframe for submitting proposed findings of fact and conclusions of law in non-jury cases depending on the complexity of the matter.

Judge Salas typically charges jury before closing arguments.

Source text: In most cases, Judge Salas will charge the jury before closing arguments, providing the jurors with an opportunity to learn the law before hearing summations that match the facts and contentions to the law.

Judge Salas typically provides jurors with written instructions.

Source text: In most cases, Judge Salas will provide jurors with copies of the instructions.

Sanitized transcript may be provided to jury with litigant consent.

Source text: At the jury’s request, if the transcript is available, Judge Salas will permit a copy of the sanitized transcript to go into the jury room, but only with the consent of the litigants.

Trial typically held Mon-Thu, 9:30 AM-3:30 PM with two 15-minute breaks.

Source text: Judge Padin will typically hold trial on Monday through Thursday, from 9:30 a.m. until 3:30 p.m., with two fifteen minute breaks, so that the early morning and late afternoon periods can be used for addressing matters outside the presence of the jury.

Permission required to approach witness, single request suffices for multiple approaches.

Source text: If a litigant wishes to approach the witness, the litigant should ask for permission to do so. If a litigant needs to approach one witness many times, a single request for permission will suffice.

Evidentiary questions should be raised outside jury presence, preferably before/after proceedings.

Source text: Litigants are encouraged to bring any evidentiary questions to the Court’s attention outside the presence of the jury, preferably before or after the day’s proceedings.

Redacted indictment generally permitted in jury room; redaction questions to Courtroom Deputy.

Source text: Generally, Judge Padin does permit the jury to have a copy of the redacted indictment. During deliberation, any question regarding what to redact should be made to the Courtroom Deputy.

Judge typically seeks agreement on time limits for opening/closing.

Source text: Judge Neals typically attempts to obtain the agreement of litigants regarding time limits on opening statements and closing arguments.

30-60 minutes recommended for opening statement and summation.

Source text: thirty (30) to sixty (60) minutes should be adequate for an opening statement and summation in most non-complex cases.

Jury charge typically given after closing arguments.

Source text: Judge Neals will generally charge the jury after counsel make their closing arguments.

Jurors receive written copy of jury charge.

Source text: Judge Neals provides jurors with a written copy of the jury charge.

Judge asks follow-up questions at sidebar.

Source text: Judge Neals will ask any follow-up questions at sidebar.

Peremptory challenges exercised in alternating rounds.

Source text: Peremptory challenges are exercised in turn, with each side exercising one round of challenge(s) at a time.

Sensitive exhibits viewed in emptied courtroom with Deputy Marshal.

Source text: If jurors wish to see such an exhibit during deliberations, they are permitted to do so in the emptied courtroom with only a Deputy Marshal present.

Prosecuting attorney maintains custody of sensitive exhibits.

Source text: The prosecuting attorney and/or investigating agency is generally required to maintain custody of exhibits such as weapons, narcotics, or currency during trial.

Juror note taking may be allowed; discussed with counsel before trial.

Source text: Judge Williams may allow juror note taking and will discuss with counsel prior to trial.

Live testimony preferred; videotaped testimony allowed only against blank background.

Source text: Judge Williams prefers all witness appear live at trial. Judge Williams will permit videotaped testimony at trial provided that the witness is recorded against a blank background. No videotaped testimony will be shown to a jury if there are any images,

Juror questions for witnesses allowed in civil cases with all parties' agreement.

Source text: Judge Williams may, if all parties agree, permit jurors to submit questions for witnesses to the Court to be posed to witnesses in civil cases only.

When pro hac vice admission is on consent, it should be requested by informal CM/ECF application.

Source text: If admission pro hac vice is sought on consent, the request should be made by informal application filed on CM/ECF.

Exhibits used only for impeachment need not be listed.

Source text: You are not required to list exhibits that will be used, if at all, only for impeachment purposes.

Mediation is governed by Local Civil Rule 301.1.

Source text: Mediation is governed by Local Civil Rule 301.1.

Judges may refer civil cases to mediation without party consent.

Source text: Any district judge or magistrate judge may refer a civil action to mediation. This may be done without the consent of the parties.

Parties are encouraged to consent to mediation.

Source text: However, the Court encourages parties to confer among themselves and consent to mediation.

ADR eligibility must be discussed during Rule 26(f) conference.

Source text: Moreover, you are reminded that, when counsel confer pursuant to Rule 26(f) of the Federal Rules of Civil Procedure and Local Civil Rule 26.1, one of the topics that must be addressed is the eligibility of a civil action for participation in ADR.

Parties encouraged to consent to mediation before Rule 26(a)(1) disclosures.

Source text: Accordingly, the Court encourages parties to consent to mediation prior to or at the time that automatic disclosures are made pursuant to Rule 26(a)(1) of the Federal Rules of Civil Procedure.

Parties may choose mediator from Court list or private mediator.

Source text: If parties consent to mediation, they may choose a mediator either from the list of certified mediators maintained by the Court or by the selection of a private mediator.

Judicial officer selects mediator if case referred without consent.

Source text: If a civil action is referred to mediation without consent of the parties, the judicial officer responsible for supervision of the program will select the mediator.

Mediator fee is $300/hour, split equally between parties.

Source text: The mediator’s hourly rate is $300.00, which is borne equally by the parties.

Mediation guidelines available on Court website and Appendix Q.

Source text: If you would like further information with regard to the mediation program please review the Guidelines for Mediation, which are available on the Court’s Web Site www.njd.uscourts.gov and appear as Appendix Q to the Local Civil Rules.

Discovery must be conducted expeditiously, diligently, and proportionally.

Source text: All parties must conduct discovery expeditiously and diligently. In addition, all discovery conducted must be proportional to the needs of the case considering the factors set forth in Fed. R. Civ. P. 26(b)(1).