Judge Caroline Goldner Cinquanto
Limits & Logistics
Document Limits
Courtesy Copies
Filings (All filings)
Required
Filings (Exhibits)
Required • Binding: Securely Bound
Adjournments
Must Include
- 1Reason For Request
- 2Proposed New Dates
Must Include
- 1Reason For Request
- 2Adversary Position
- 3Proposed New Dates
Communication
Letter Ecf
Chambers
Chambers
Phone
Chambers
Conference
Opposing Counsel
Detailed Drafting Rules
Correspondence permitted from counsel if copies sent to all other parties.
Judge Goldner Cinquanto permits correspondence from counsel on any matters, so long as all other counsel or unrepresented parties are sent copies of such correspondence.
Letter via ECF
Direct to: Chambers
- Status Inquiries
Counsel may communicate with law clerks on procedural matters; pro se parties limited to mail/email.
Judge Goldner Cinquanto permits communications from counsel, both written and oral, with her law clerks on procedural matters only. Parties who are pro se (do not have counsel) may only communicate by mail or email to the chambers address above, unless otherwise directed.
Direct to: Chambers
- Status Inquiries
Notify court by call/email at least 1 week before conference if settlement unlikely.
If settlement is not a real possibility (e.g., if the defendant will not make an offer or will offer only nuisance value), counsel shall notify the Court (jointly or individually) by a call or email to request a brief video conference regarding the lack of settlement possibility at least one week before the scheduled settlement conference.
Direct to: Chambers
Confidential settlement summary (max 5 pages) due 2 weeks before conference.
Counsel for all parties must submit a confidential settlement summary and case synopsis via email (to Chambers_of_Magistrate_Judge_Goldner_Cinquanto@paed.uscourts.gov) two weeks before the conference. The case synopsis should be no more than five-pages in length.
Document Type
Settlement Summary
Attachments to settlement summary limited to 30 pages with labeled dividers.
The synopsis should attach key summary expert reports, policy language excerpts, photographs, sketches, diagrams, charts, etc., to the conference memos. Judge Goldner Cinquanto will review them. Please attach only those excerpts which are most relevant to the claims at issue. Relevant portions must be delineated. Attachments should be no more than 30 pages and should be separated with labeled divider pages.
Document Type
Settlement Summary
Telephone participation by settlement authority clients is prohibited unless compelling circumstances with prior approval.
Having a client with settlement authority available by telephone is not an acceptable alternative unless compelling circumstances exist and there is prior approval from Judge Goldner Cinquanto (e.g., client is located in another state at the time of the conference).
Phone
Direct to: Chambers
- Status Inquiries
Judge will not intervene in discovery disputes without good faith telephone/video conference effort.
Judge Goldner Cinquanto will not entertain a request for judicial intervention if parties or their counsel have exchanged emails or other correspondence but have not made a good faith effort to speak to each other by telephone or video conference regarding a discovery dispute.
Phone
Direct to: Opposing Party
- Status Inquiries
Email chambers to request telephone conference before filing discovery motion after good faith efforts.
If a party still requires Court intervention in a discovery dispute after making good faith efforts to communicate with an opposing party, the requesting party shall email Chambers_of_Magistrate_Judge_Goldner_Cinquanto@paed.uscourts.gov to request a telephone conference before filing any discovery motion on the docket.
Direct to: Chambers
- Status Inquiries
Memoranda limited to 30 pages (excluding TOC/appendices), double-spaced, 12-point font; TOC and TOA required for memos over 15 pages.
Memoranda must not exceed 30 pages in length (excluding table of contents and appendices), must be double spaced, and must use 12-point font. Memoranda over 15 pages in length must include a table of contents and table of authorities.
Memoranda over 15 pages require table of contents and table of authorities.
Memoranda over 15 pages in length must include a table of contents and table of authorities.
Document Type
Memorandum
Joint appendix required for summary judgment motions, consecutively numbered, with TOC, filed by movant when motion is docketed.
Joint Appendix: A party who plans to file a motion for summary judgment must meet and confer with all other parties and develop a single, joint appendix of all exhibits that may be referenced in their respective memoranda. All pages of the joint appendix must be consecutively numbered with an appendix page number. Page references in the memoranda must be to the appendix page number, not internal document page numbers. The joint appendix must include a table of contents. The joint appendix must be filed by the movant no later than the date the initial motion for summary judgment is docketed.
Document Type
Summary Judgment Motion
Case synopsis (max 5 pages, single spaced) due 2 weeks before conference.
• Counsel for all parties must submit the attached summary and their confidential case synopsis to Chambers_of_Magistrate_Judge_Goldner_Cinquanto@paed.uscourts.gov on or before [two weeks before the conference]. The synopsis should be no more than five (5) pages in length, single spaced.
Attachments to synopsis limited to 30 pages with labeled dividers.
• The synopsis should attach key summary expert reports, policy language excerpts, photographs, sketches, diagrams, charts, etc. Only attach excerpts which are most relevant to the claims at issue. Relevant portions must be delineated. Attachments should be no more than thirty (30) pages and should be separated with labeled divider pages.
Counsel must notify court one week before settlement conference if settlement is not possible.
If settlement is not a real possibility (e.g., if defendant will not make an offer or will offer only nuisance value), counsel shall notify the Court (jointly or individually) to request a brief video conference regarding their status on or before [one week before the conference].
Letter via ECF
Direct to: Chambers
- Advance Notice Requiredone week before settlement conference
Ex parte Zoom conferences available before settlement conference upon request.
If requested by counsel, with no opposition, Judge Goldner Cinquanto is available for ex parte Zoom conferences before the settlement conference. Please contact chambers to arrange a pre-conference video call.
Direct to: Chambers
Settlement conference synopsis limited to 5 pages single-spaced with max 30 pages of attachments.
The synopsis should attach key summary expert reports, policy language excerpts, photographs, sketches, diagrams, charts, etc. Only attach excerpts which are most relevant to the claims at issue. Relevant portions must be delineated. Attachments should be no more than thirty (30) pages and should be separated with labeled divider pages Judge Goldner Cinquanto may require hard copies of lengthy materials.
Motion briefs limited to 30 pages, reply briefs to 15 pages.
Briefs accompanying motions and responses to motions are limited to thirty pages absent leave of Court. Any reply brief is limited to the issues raised in the response, may not raise theories or issues not discussed in the original motion, and shall not exceed fifteen pages absent leave of Court.
Counsel must confer to narrow disputed issues before trial
Counsel should work together to narrow any areas of dispute before trial.
Conference
Direct to: Opposing Counsel
Final pretrial conference 7 days before trial with settlement authority required
A final pretrial conference will be held on [seven days before date certain] at __ a.m./p.m. in Courtroom 3D. Counsel shall confer in advance and shall be prepared to discuss all aspects of their Pretrial Stipulation, including any disputed issues. A principal with full settlement authority shall be in attendance for each party.
Conference
Direct to: Court
- Advance Notice Required7_days_before_trial
Principal with full settlement authority required at final pretrial conference
A principal with full settlement authority shall be in attendance for each party.
Conference
Direct to: Court
- Principal With Settlement Authority Required
Plaintiff’s counsel must promptly advise Court of any settlement
Plaintiff’s counsel shall promptly advise the Court of any settlement.
Letter via ECF
Direct to: Court
- Prompt Notification Required