Courtesy copies are required when a filing is > 3 pages. Details: 1 copy, delivery upon filing, by hand delivery. Physical courtesy copies required for ECF filings with more than 3 exhibits; must be three-hole punched with tabbed, labeled exhibits.
Judge Gerald A. McHugh's rules set a pre-motion procedure for rule 16. Rule 16 conference required after answer; lead counsel must appear in person.
Judge Gerald A. McHugh's formatting rule includes file format PDF, separately numbered, objectively titled, and index required. ECF exhibits must be separately numbered, clearly titled with objective descriptions, and include an index.
The rule requires critical documents. Rule 26(f) Report must attach critical documents for court review.
The rule identifies required filing content or certificates. All motions and pleadings must reference other documents by ECF number.
Parties may contact Judge Gerald A. McHugh's chambers by email only as allowed by the rule. The rule lists email Chambers_of_Judge_Gerald_McHugh@paed.uscourts.gov. Protective order stipulations must be emailed to specific chambers email address.
Judge Gerald A. McHugh's rules specify what an adjournment or extension request must include. The request must include adversary position and reason for request. Extension stipulations must be emailed to Chambers and require court approval.
Bundling is optional for covered papers before Judge Gerald A. McHugh. Supplemental, reply, and sur-reply briefs may be filed without leave, but consideration begins after initial opposition.
Rule 16 conference required after answer; lead counsel must appear in person.
Lead trial counsel must appear in person at Rule 16 conference.
Rule 16 conference addresses substantive issues; counsel must discuss case strengths/weaknesses and critical documents.
Rule 26(f) Report must attach critical documents for court review.
E-discovery agreement required before Rule 16 conference; default order available if no agreement.
Discovery may begin immediately; not delayed by pending motions to dismiss except for complete dismissal motions.
Discovery disputes must be resolved by meet-and-confer; disputes must be filed as motions, not letters.
Call chambers for immediate ruling on deposition disputes if judge is available.
Protective order stipulations must be emailed to specific chambers email address.
Joint/unopposed motions must be clearly identified in title for expedited consideration.
Oral argument granted only when Judge determines it will facilitate resolution.
Searchable briefs encouraged; scanned briefs should use OCR software.
ECF exhibits must be separately numbered, clearly titled with objective descriptions, and include an index.
All motions and pleadings must reference other documents by ECF number.
Supplemental/reply/sur-reply briefs may be filed without leave; Court considers merits after initial opposition.
MSJ motions cannot include unilateral Statements of Undisputed Facts; all facts must be in memorandum with record citations.
Physical courtesy copies required for ECF filings with more than 3 exhibits; must be three-hole punched with tabbed, labeled exhibits.
No pretrial conference for arbitration cases; discovery must be completed before arbitration date.
Judge McHugh generally does not address MSJ motions before arbitration hearing.
Chambers email contact is available for scheduling and technical issues; substantive communications must also be filed on ECF and advocacy during ex parte contact is prohibited.
Extension stipulations must be emailed to Chambers and require court approval.
Stipulations requiring court approval must be emailed to a specific Chambers address.
Rule 26(f) Reports must attach critical documents for Court review.
Discovery disputes require parties to meet and confer in good faith, and must be filed as motions rather than letters.
During deposition disputes, counsel may phone Chambers for immediate rulings if the Judge is available.
Courtesy copy required when filing has more than 3 exhibits; must be three-hole punched with tabbed exhibits.
Exhibits on ECF must be separately numbered attachments with objective descriptive titles.
All filings must include a separate index of exhibits.
Motions and pleadings must reference docket documents by ECF number.
Summary judgment motions cannot include separate Statements of Undisputed Facts; facts must be in the memorandum with record citations.