Courtesy copies are required for motions and stipulations. Details: delivery upon filing. Electronically filed motion papers and stipulations require courtesy hard copies to chambers at filing, with specific ECF-related markings.
Judge William F. Kuntz's rules set a pre-motion procedure for rule 12, rule 56, venue change, compel arbitration, rule 24, and rule 15 leave. A pre-motion conference is mandatory before filing specified motions, including Rule 12, Rule 56, venue change, arbitration, Rule 24 intervention, and Rule 15 leave-to-amend motions.
Judge William F. Kuntz's rule states these limits: 25 pages. Excludes table of contents, table of authorities, appendices, and attachments. Support and opposition memoranda are limited to 25 double-spaced pages in 12-point Times New Roman.
Judge William F. Kuntz's rule states these limits: 10 pages. Excludes table of contents, table of authorities, appendices, and attachments. Reply memoranda are limited to 10 double-spaced pages in 12-point Times New Roman.
Judge William F. Kuntz's formatting rule includes voluminous exhibits should be placed in binders with tabs. Voluminous exhibits should be organized in tabbed binders.
The rule requires proposed order. An extension request affecting other deadlines must include a proposed revised scheduling order that states whether dates are on consent.
The rule requires certificate of service. A default judgment motion must include proof of service on the defaulting party.
Parties may contact Judge William F. Kuntz's chambers by letter ecf only as allowed by the rule. Communications to chambers must be filed as ECF letters with service on all counsel, and routine correspondence between counsel should not be sent to the Court.
A motion to seal is required for covered sealed filings before Judge William F. Kuntz. Sealed electronic filing requires prior leave by motion with the proposed filing attached under seal, and only then may the original be filed separately under seal in ECF.
Requests should be made at least 48 hours in advance when this rule applies before Judge William F. Kuntz. Adjournment requests for court appearances require written submission at least 48 hours in advance, with emergency requests within 48 hours initiated by phone to the case manager.
Bundling is encouraged for covered papers before Judge William F. Kuntz. The Court encourages parties to hold motion filing until briefing is complete.
Communications to chambers must be filed as ECF letters with service on all counsel, and routine correspondence between counsel should not be sent to the Court.
Telephone calls to chambers are prohibited for general information that is not about docketing, scheduling, or calendar matters.
Fax communications to chambers are limited to time-sensitive matters with prior authorization, must be copied to all counsel, and should not be followed by hard copy unless directed.
Adjournment requests for court appearances require written submission at least 48 hours in advance, with emergency requests within 48 hours initiated by phone to the case manager.
Extension requests must be in writing and include the original date, prior extension history, and the adversary’s consent position including reasons for refusal.
When the adversary does not consent, extension requests must be submitted at least 24 hours before the deadline unless good cause is shown.
An extension request affecting other deadlines must include a proposed revised scheduling order that states whether dates are on consent.
Electronically filed motion papers and stipulations require courtesy hard copies to chambers at filing, with specific ECF-related markings.
When exhibits are filed in hard copy instead of electronically, parties must provide both an original-marked copy and a courtesy copy.
Sealed electronic filing requires prior leave by motion with the proposed filing attached under seal, and only then may the original be filed separately under seal in ECF.
A pre-motion conference is mandatory before filing specified motions, including Rule 12, Rule 56, venue change, arbitration, Rule 24 intervention, and Rule 15 leave-to-amend motions.
Pre-motion conferences are not required for listed categories of motions and case types, and the Court may waive them when unnecessary.
A pre-motion conference request requires a three-page letter stating the motion basis, and optional responses are limited to three pages within five business days.
For Rule 12 timing purposes, the pre-motion conference letter is treated as the motion itself.
After the Rule 12 pre-motion decision order, plaintiffs have 21 days to amend as of right; amendments after that require leave under Rule 15(a)(2).
Rule 56 motions must be made within 30 days of discovery completion absent good cause, and a timely pre-motion letter satisfies timely service.
A default judgment motion must include proof of service on the defaulting party.
A certificate of default issued by the Clerk is a prerequisite to consideration of a default judgment motion.
If service was only through the Secretary of State, counsel must certify no other known address for the defaulting party.
When the Service Members Civil Relief Act applies, a non-military affidavit must be filed for default judgment practice.
Letter briefs are prohibited.
Default judgment motions must be noticed after the certificate of default is docketed and set returnable 20 days after service of notice.
Parties must obtain Court approval of a briefing schedule before serving motion papers, and schedule changes require court order.
Support and opposition memoranda are limited to 25 double-spaced pages in 12-point Times New Roman.
Reply memoranda are limited to 10 double-spaced pages in 12-point Times New Roman.
Memoranda that are 10 pages or longer must include a table of contents and a table of authorities.
Every memorandum must display the date of service prominently on its front cover.
The Court encourages parties to hold motion filing until briefing is complete.
Non-pro-se moving parties must provide chambers with a full courtesy-copy set of motion papers and a letter itemizing the package.
When parties wait to file until fully briefed, they must serve papers with a cover letter containing specified information and file only that cover letter in advance as a letter filing.