Judge Pamela A. Carlos' rule states these limits: 4 pages. Settlement conference memoranda limited to 4 pages.
The rule requires offer demand proposal and exhibit list. Settlement conference memoranda must be submitted one week before conference, max 4 pages, in Word format.
The rule requires party representative with settlement authority. Parties must attend settlement conference in person with full settlement authority.
Parties may contact Judge Pamela A. Carlos' chambers by in person only as allowed by the rule. Settlement conferences must be in-person at Allentown courthouse.
Requests should be made at least 14 calendar days in advance when this rule applies before Judge Pamela A. Carlos. Continuance requests for settlement conferences must be made within 14 days of notice.
Correspondence allowed if copies sent to all parties.
Counsel may contact law clerks for scheduling/administrative matters only.
Settlement conferences must be in-person at Allentown courthouse.
Status conferences and discovery disputes by phone; Rule 16 conferences by Zoom.
Oral arguments and evidentiary hearings must be in-person.
Oral argument scheduled only if helpful to case resolution.
Reply/supplemental briefs require prior court permission.
Counsel must attempt to resolve discovery disputes before contacting court.
Contact deputy clerk to schedule discovery dispute conferences.
Discovery disputes should be submitted via letter memoranda.
Motion practice discouraged for discovery matters except subpoenas to non-parties.
Settlement conference memoranda must be submitted one week before conference, max 4 pages, in Word format.
Settlement conference memoranda limited to 4 pages.
Settlement conference memoranda must be emailed to chambers, not filed with clerk.
Parties must attend settlement conference in person with full settlement authority.
Attendees must have full settlement authority and cannot seek additional authority by phone.
Judge may continue settlement discussions after conference if matter unresolved.
Continuance requests for settlement conferences must be made within 14 days of notice.
Continuance requests granted only for most compelling reasons.
Extensions to dispositive motion, Daubert, or trial deadlines are generally not granted.
Extensions require showing of circumstances beyond counsel's reasonable control.
Final pretrial conference is held in person in Allentown, Pennsylvania.
Extension requests require formal motion, proposed order, and certification of counsel concurrence/objection.
Most extension requests require a conference with the Judge.
Discovery period is normally 90-120 days, with 120 days including expert examination.
Additional discovery time allowed in complex cases or upon showing of need.
Judge encourages early essential discovery to foster settlement and minimize costs.
Additional discovery post-arbitration is generally not permitted.
Failure to identify expert witnesses or provide reports bars expert testimony at trial.
Final pretrial conference is conducted on the record.