Yes. A pre-motion letter is required for covered motions before Judge Mary Kay Costello. Details: response due in 3 days. Rule 16 conference scheduled after all defendants answer; joint Rule 26(f) report with discovery plan due 3 business days before conference.
Judge Mary Kay Costello's rule states these limits: 5 pages. Excludes caption, index, table of contents, table of authorities, signature blocks, and certificates. Discovery disputes raised by letter limited to 5 pages, response within 5 days also limited to 5 pages.
Judge Mary Kay Costello's rule states these limits: 10 pages. Excludes caption, index, table of contents, table of authorities, signature blocks, and certificates. Complex discovery disputes must be filed as motions, limited to 10 pages, response within 5 days also limited to 10 pages.
The rule requires proposed order and attached memorandum. All motions must include a proposed order and attached memorandum.
The rule identifies required filing content or certificates. No separate statements of undisputed facts for summary judgment; all facts must be in memorandum with pinpoint citations.
Parties may contact Judge Mary Kay Costello's chambers by email only as allowed by the rule. The rule lists email chambers costello@paed.uscourts.gov. All communications must go through Courtroom Deputy Clerk; direct contact with law clerks is prohibited.
Judge Mary Kay Costello's rules specify what an adjournment or extension request must include. The request must include reason for request, adversary position, and proposed new dates. Extensions/continuances require compelling reason and must be requested by letter with detailed basis and other counsel's position.
Correspondence limited to scheduling, routine matters, and settlement notifications; other communications must be filed as pleadings/motions.
All communications must go through Courtroom Deputy Clerk; direct contact with law clerks is prohibited.
Counsel must discuss matters with opposing counsel before bringing them to the Court's attention.
Rule 16 conference scheduled after all defendants answer; joint Rule 26(f) report with discovery plan due 3 business days before conference.
Counsel must have client authority and be prepared to discuss all claims, defenses, and topics at pretrial conferences.
Extensions/continuances require compelling reason and must be requested by letter with detailed basis and other counsel's position.
Extensions/continuances for trial dates or dispositive motion deadlines only granted in extraordinary circumstances.
Standard discovery period is 120 days from Rule 16 conference; additional time must be requested at conference.
Discovery disputes must be resolved through meet-and-confer before seeking court intervention; sanctions may be imposed.
Discovery disputes raised by letter limited to 5 pages, response within 5 days also limited to 5 pages.
Complex discovery disputes must be filed as motions, limited to 10 pages, response within 5 days also limited to 10 pages.
All motions must include a proposed order and attached memorandum.
Reply and sur-reply briefs must be filed within 7 days of the brief they respond to, without seeking leave.
Motions briefs/memoranda limited to 25 pages (excluding TOC, TOA, attachments/exhibits), double-spaced 12-point font.
Sur-reply briefs limited to 5 pages and must address only new issues from the reply.
Exhibits must be separately numbered attachments with clear objective titles.
Pre-motion conference required 7 days before filing Rule 12(b)(6), (e), or (f) motions, except in pro se, bankruptcy, or social security cases.
No separate statements of undisputed facts for summary judgment; all facts must be in memorandum with pinpoint citations.
Summary judgment rarely granted in non-jury cases.
TRO motions must be served on respondent with notice of hearing date/time.
Motions in limine briefs limited to 5 pages, double-spaced, 12-point font; no reply briefs allowed.
One day before trial, submit witness/exhibit lists and two hard copies of each exhibit in tabbed binders; electronic submission optional; paper copies available on request.
Speaking objections discouraged; state "objection" and cite rule; sidebars permitted only sparingly.
In non-jury cases, submit proposed findings of fact and conclusions of law per Final Pretrial Scheduling Order; revised versions allowed after trial.
Unavailability of witness (per FRCP 32(a)(4)) requires use of oral/video deposition; not grounds for delay.
Lay opinion testimony under FRE 701 requires disclosure of supporting information/documents at expert report deadline.
Government must submit guilty plea memorandum at least 3 days before hearing
Sentencing memoranda and motions due 7 days before sentencing hearing