Court Rules
magistrate Judge
Verified Current9 days ago

Judge Pamela A. Carlos

Eastern District of Pennsylvania

Limits & Logistics

Document Limits

Settlement Conference Memorandum
4 pgs

Adjournments

Notice Required
14Calendar Days

Must Include

  • 1
    Reason For Request
  • 2
    Adversary Position

Must Include

  • 1
    Reason For Request
  • 2
    Proposed New Dates
  • 3
    Adversary Position
Notice Required
0Calendar Days

Must Include

  • 1
    Reason For Request
  • 2
    Proposed New Dates

Communication

Letter Ecf

Chambers

Advance Notice Required
No Hours, Status Inquiries
Email

Chambers

Scheduling
Advance Notice Required
No Hours, Status Inquiries
In Person

Chambers

Advance Notice Required
No Hours, Status Inquiries
Phone

Chambers

Emergencies
Advance Notice Required
No Hours, Status Inquiries
Email

Chambers

PAED_Carlos_Chambers@paed.uscourts.gov
Technical Issues
No Status Inquiries
Chambers

Chambers

Scheduling
No Hours
Filters:AllMandatoryImportantCommunicationConferencesSettlementMemorandaDiscoveryLettersElectronicsOral Argument

Detailed Drafting Rules

Communication ProtocolNote

Correspondence allowed if copies sent to all parties.

Judge Carlos 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

Approved Topics
SchedulingEmergenciesStatus InquiriesTechnical Issues
Requirements
  • Advance Notice Required
Prohibited
  • Hours
  • Status Inquiries
Page 1
|SecI. A. Correspondence with the Court
Communication ProtocolNote

Counsel may contact law clerks for scheduling/administrative matters only.

Judge Carlos permits counsel to communicate with her law clerks on scheduling and administrative matters, but never on the merits of a case.

Email

Direct to: Chambers

Approved Topics
SchedulingEmergenciesStatus InquiriesTechnical Issues
Requirements
  • Advance Notice Required
Prohibited
  • Hours
  • Status Inquiries
Page 1
|SecI. B. Communication with Law Clerks
Communication ProtocolMandatory

Settlement conferences must be in-person at Allentown courthouse.

Judge Carlos prefers that counsel and the parties come to the U.S. Courthouse in Allentown, Pennsylvania for all settlement conferences.

In Person

Direct to: Chambers

Approved Topics
SchedulingEmergenciesStatus InquiriesTechnical Issues
Requirements
  • Advance Notice Required
Prohibited
  • Hours
  • Status Inquiries
Page 1
|SecI. C. Telephone Conferences
Communication ProtocolNote

Status conferences and discovery disputes by phone; Rule 16 conferences by Zoom.

Telephone conferences are utilized for status conferences and routine discovery disputes. Rule 16 conferences are generally conducted by Zoom.

Phone

Direct to: Chambers

Approved Topics
SchedulingEmergenciesStatus InquiriesTechnical Issues
Requirements
  • Advance Notice Required
Prohibited
  • Hours
  • Status Inquiries
Page 1
|SecI. C. Telephone Conferences
Communication ProtocolMandatory

Oral arguments and evidentiary hearings must be in-person.

Oral argument and evidentiary hearings will be conducted in person.

In Person

Direct to: Chambers

Approved Topics
SchedulingEmergenciesStatus InquiriesTechnical Issues
Requirements
  • Advance Notice Required
Prohibited
  • Hours
  • Status Inquiries
Page 1
|SecI. D. Oral Arguments and Evidentiary Hearings
Communication ProtocolNote

Oral argument scheduled only if helpful to case resolution.

Judge Carlos will schedule oral argument on motions only if it appears likely to be helpful to the Court's resolution of the matter.

In Person

Direct to: Chambers

Approved Topics
SchedulingEmergenciesStatus InquiriesTechnical Issues
Requirements
  • Advance Notice Required
Prohibited
  • Hours
  • Status Inquiries
Page 2
|SecII. B. 1. Oral Argument on Motions
Communication ProtocolImportant

Reply/supplemental briefs require prior court permission.

Judge Carlos will not normally permit reply or supplemental briefs. Counsel desiring to file a such a brief must first seek permission of the Court before such a brief will be accepted.

Letter via ECF

Direct to: Chambers

Approved Topics
SchedulingEmergenciesStatus InquiriesTechnical Issues
Requirements
  • Advance Notice Required
Prohibited
  • Hours
  • Status Inquiries
Page 2
|SecII. B. 2. Reply and Supplemental Briefs
Communication ProtocolImportant

Counsel must attempt to resolve discovery disputes before contacting court.

Judge Carlos expects counsel to attempt to resolve disputes prior to bringing them to her attention, pursuant to Rule 26.1(f) of the Local Rules of Civil Procedure for the Eastern District of Pennsylvania.

Letter via ECF

Direct to: Chambers

Approved Topics
SchedulingEmergenciesStatus InquiriesTechnical Issues
Requirements
  • Advance Notice Required
Prohibited
  • Hours
  • Status Inquiries
Page 2
|SecII. C. 1. Discovery Disputes
Communication ProtocolNote

Contact deputy clerk to schedule discovery dispute conferences.

Judge Carlos permits contact with the Court through her deputy clerk to set up telephone or chambers conferences to resolve outstanding issues.

Email

Direct to: Chambers

Approved Topics
SchedulingEmergenciesStatus InquiriesTechnical Issues
Requirements
  • Advance Notice Required
Prohibited
  • Hours
  • Status Inquiries
Page 2
|SecII. C. 1. Discovery Disputes
Communication ProtocolNote

Discovery disputes should be submitted via letter memoranda.

Generally, Judge Carlos prefers letter memoranda outlining the discovery dispute.

Letter via ECF

Direct to: Chambers

Approved Topics
SchedulingEmergenciesStatus InquiriesTechnical Issues
Requirements
  • Advance Notice Required
Prohibited
  • Hours
  • Status Inquiries
Page 2
|SecII. C. 1. Discovery Disputes
Communication ProtocolImportant

Motion practice discouraged for discovery matters except subpoenas to non-parties.

Except for subpoenas issued to non-parties, the use of motion practice in discovery matters is discouraged.

Letter via ECF

Direct to: Chambers

Approved Topics
SchedulingEmergenciesStatus InquiriesTechnical Issues
Requirements
  • Advance Notice Required
Prohibited
  • Hours
  • Status Inquiries
Page 2
|SecII. C. 1. Discovery Disputes
Document RequirementMandatory

Settlement conference memoranda must be submitted one week before conference, max 4 pages, in Word format.

Judge Carlos will normally require counsel to submit a conference memorandum one week before the scheduled conference. It shall include an offer/demand settlement proposal. This memorandum should not exceed four (4) pages and should be submitted in Word format.

Document Type

Settlement Conference Memorandum

Content & Formatting
Offer Demand Proposal
Exhibit List
Page 3
|SecD. Settlement
Page or Word LimitMandatory

Settlement conference memoranda limited to 4 pages.

This memorandum should not exceed four (4) pages and should be submitted in Word format.

Page 3
|SecD. Settlement
Communication ProtocolMandatory

Settlement conference memoranda must be emailed to chambers, not filed with clerk.

The memoranda are not to be filed with the Clerk’s office. Instead, they should be sent to chambers via email at: PAED_Carlos_Chambers@paed.uscourts.gov.

Email

Direct to: Chambers

Approved Topics
Technical Issues
Prohibited
  • Status Inquiries
Page 3
|SecD. Settlement
Communication ProtocolNote

Counsel must provide phone number and be available by phone during jury deliberations.

Judge Carlos will not require counsel to remain in the courthouse during deliberations but will require counsel to be available on short telephone notice. Counsel must provide the deputy clerk with their phone number.

Phone

Direct to: Chambers

Approved Topics
SchedulingEmergenciesStatus InquiriesTechnical Issues
Requirements
  • Advance Notice Required
    short_telephone_notice
Prohibited
  • Hours
    during_jury_deliberations
  • Status Inquiries
Page 9
|SecAvailability of Counsel During Jury Deliberations
Communication ProtocolNote

Counsel may contact deputy clerk or law clerks with questions about courtroom practices.

Counsel should feel free to contact Judge Carlos' deputy clerk or law clerks if they have any questions about her courtroom practices or procedures.

Email

Direct to: Chambers

Approved Topics
SchedulingEmergenciesStatus InquiriesTechnical Issues
Requirements
  • Advance Notice Required
    none
Prohibited
  • Hours
    business_hours
  • Status Inquiries
Page 10
|SecOther General Matters
Communication ProtocolMandatory

Plaintiff and counsel report at 9:30 AM, defense counsel at 10:30 AM for settlement conference.

PLAINTIFF AND COUNSEL ARE TO REPORT TO CHAMBERS AT 9:30 A.M. ON THE DATE STATED ABOVE. DEFENSE COUNSEL SHALL REPORT AT 10:30 A.M.

Chambers

Direct to: Chambers

Approved Topics
Scheduling
Prohibited
  • Hours
    9:30 AM for plaintiff/counsel, 10:30 AM for defense counsel
Page 1
|SecSETTLEMENT CONFERENCE SCHEDULING ORDER
Communication ProtocolMandatory

Parties must email chambers confirming settlement demand/offer status.

LETTER TO CHAMBERS, VIA EMAIL, INDICATING WHETHER A SETTLEMENT DEMAND AND A SETTLEMENT OFFER HAVE BEEN MADE. THE PARTIES ARE ALSO DIRECTED TO CONFIRM WHETHER BASED UPON THE STATUS OF NEGOTIATIONS THERE IS AN AGREEMENT TO PROCEED WITH A GOOD FAITH SETTLEMENT CONFERENCE.

Email

Direct to: Chambers

Approved Topics
Scheduling
Page 2
|SecSETTLEMENT CONFERENCE SCHEDULING ORDER
Document RequirementMandatory

Settlement memorandum must include participant info, 4-page synopsis, exhibits, expert reports, and deposition excerpts.

The settlement conference memorandum shall include: 1. Name, title and email of all persons participating in the settlement conference. 2. An updated case synopsis, limited to four pages, which shall be in Microsoft Word format. 3. Critical exhibits in support of the parties' liability and damage claims or defenses. The parties should coordinate with one another as to which party will produce the specific documents if possible. Duplicate submission are discouraged. 4. Affirmative and rebuttal experts reports, if any. 5. Relevant portions of deposition testimony may be submitted. Submission of entire deposition transcripts is strongly discouraged.

Document Type

Settlement Conference Memorandum

Content & Formatting
Exhibits
Case Synopsis
Expert Reports
Participant Info
Deposition Testimony
Page 2
|SecSETTLEMENT CONFERENCE SCHEDULING ORDER
Communication ProtocolNote

Settlement conference communications should be sent to PAED_Carlos_Chambers@paed.uscourts.gov.

The Email address is PAED_Carlos_Chambers@paed.uscourts.gov.

Page 2
|SecSETTLEMENT CONFERENCE SCHEDULING ORDER