Courtesy copies are required for all covered filings. Details: delivery in advance of court, by hand delivery. All relevant documents must be delivered to Chambers in advance of court.
Judge Caroline Goldner Cinquanto's rule states these limits: attorney: 30 pages; pro se: 30 pages. Excludes table of contents and appendices. Memoranda limited to 30 pages (excluding TOC/appendices), double-spaced, 12-point font; TOC and TOA required for memos over 15 pages.
Judge Caroline Goldner Cinquanto's rule states these limits: 5 pages. Case synopsis (max 5 pages, single spaced) due 2 weeks before conference.
The rule requires full day attendance. Counsel must be prepared to attend entire settlement conference day with clients.
The rule requires costs, damages, and attorney fees. Plaintiff must submit settlement demand at least 3 weeks before conference.
Parties may contact Judge Caroline Goldner Cinquanto's chambers by phone only as allowed by the rule. Telephone participation by settlement authority clients is prohibited unless compelling circumstances with prior approval.
A motion to seal is required for covered sealed filings before Judge Caroline Goldner Cinquanto. Documents generally require court leave to be filed under seal, except in emergencies.
Requests should be made at least 1 business days in advance when this rule applies before Judge Caroline Goldner Cinquanto. The request must include reason for request, adversary position, and proposed new dates. Extension requests must be emailed in advance with detailed basis and party positions.
Counsel must be patient as settlement is a process that takes time.
Counsel must be flexible and avoid bottom lines or top numbers.
Counsel must be creative in settlement discussions.
Counsel must manage their own expectations.
Correspondence permitted from counsel if copies sent to all other parties.
Counsel must be prepared to discuss legal, financial, or emotional impediments to settlement.
Counsel must be prepared to attend entire settlement conference day with clients.
Counsel may communicate with law clerks on procedural matters; pro se parties limited to mail/email.
Deadlines must be strictly followed unless compelling reason exists.
Extension requests must be emailed in advance with detailed basis and party positions.
Plaintiff must submit settlement demand at least 3 weeks before conference.
Defendant must submit settlement offer at least 2 weeks before conference.
Notify court by call/email at least 1 week before conference if settlement unlikely.
Confidential settlement summary (max 5 pages) due 2 weeks before conference.
Counsel must bring critical evidence including policy language, photographs, sketches, diagrams, and charts.
Attachments to settlement summary limited to 30 pages with labeled dividers.
Judge may require hard copies of lengthy materials.
Settlement conference requires principals with full settlement authority to be present for entire duration.
Insurer representatives with settlement authority must attend if insurer approval is required.
Telephone participation by settlement authority clients is prohibited unless compelling circumstances with prior approval.
Adjournments for additional settlement authority may result in sanctions including opposing party's attorney fees.
Counsel must be prepared to discuss both strengths and weaknesses of their case.
Counsel must be prepared to discuss factual and legal points of agreement and disagreement.
Rule 26(f) report must be emailed to chambers at least 5 days before scheduling conference if not already on docket.
Discovery must be proportional to the needs of the case.
Judge will not intervene in discovery disputes without good faith telephone/video conference effort.
Email chambers to request telephone conference before filing discovery motion after good faith efforts.
Discovery dispute request must describe prior efforts, summarize matters in dispute, and attach relevant information.
Rule 37 requires certification of good faith conferment before filing discovery motions.
Local Rule 26.1(f) requires certification that parties are unable to resolve discovery dispute after reasonable effort.