Eastern District of Pennsylvania Local Rules and Judge Filing Requirements

The Court will generally require the parties to submit a joint proposed set of jury instructions and verdict forms.

The required pretrial submissions also include jointly proposed jury instructions and verdict sheet, motions in limine, and final pretrial memoranda under Local Civil Rule 16.1(c).

Counsel must identify where each exhibit referenced in a motion or response can be found in the record.

Pretrial memoranda must detail the substance of each witness's testimony, not just identify their role.

Deposition transcripts must be attached to summary judgment motions when cited.

Limited correspondence must include specific situation description and opposing party's position.

Counsel may communicate directly with law clerks on procedural matters.

Judge does not typically give jury copies of written instructions, but may in appropriate cases.

Contact Courtroom Deputy Nancy DeLisle for scheduling inquiries; law clerks may assist if unavailable but cannot provide legal advice.

Re-cross examination only allowed when new evidence is introduced on re-direct.

Final pretrial conference is conducted on the record.

Continuance requests must identify other court, judge, and docket number if conflict exists

Threshold motions (e.g., motions to transfer or substitute parties) should be filed at least seven (7) days before the Rule 16 conference.

Judge Sánchez will not consider any request for a continuance exceeding 90 days.

Extension requests must be filed as motions with good cause shown, made as far in advance as possible.

Summary judgment reply limited to 25 pages with specific record citations.

Supporting memoranda in multi-defendant criminal cases limited to 20 double-spaced pages.

Upon showing good cause based on a need for the transcript to brief the post-trial issues, Judge Kearney may allow the movant to file the memorandum not exceeding twenty-five pages in support of post-trial relief within thirty days of the receipt of the transcript.

Discovery motions limited to 5 pages, no exhibits or memorandum of law.

Factual statements on summary judgment do not count toward 25-page limit unless substantially argumentative.

Reply briefs require leave of court, filed within 5 days with email courtesy copy.

Counsel expected to resolve objections before motions in limine deadlines.

By the Rule 16 conference, Rule 26(a) disclosures are expected to be complete and initial interrogatories and document requests served (and answered or soon to be answered), with discovery begun without waiting for the conference.

Discovery disputes require motion to compel after failed resolution attempts.

Parties must request a pre-filing conference with the Court before filing any discovery motion requiring intervention.

Judge's courtroom is not electronic

Exhibits must be taped and submitted in binders for the Court’s use.

Parties should not submit pleadings from the case before Judge Wolson. For example, there is no need to attach a copy of a complaint to a Motion to Dismiss. Judge Wolson can retrieve those documents from the CM/ECF system. Nor should parties submit pleadings from other federal cases. It is enough to cite the pleading by court, case number, and docket number. Judge Wolson will retrieve the pleading from the CM/ECF

Trial exhibits must be in three-ring binder with tabbed table of contents in 12-point font.

Deposition testimony and other transcripts shall be submitted to the Court as full-sized pages, not manuscripts. In addition, parties submitting deposition transcripts should provide a cover page identifying the witness and relevant pages from the transcripts. Parties should not submit the entire transcript unless the entire transcript is relevant to the issue before the Court. The Court will request the entire transcript if it deems it necessary.

One courtesy copy of motion papers required, stapled or neatly bound with dividers.

Chambers may request a courtesy copy when a motion or its exhibits are voluminous.

Two courtesy copies required for all motions and related briefs filed electronically; two copies required for all pleadings if not filed electronically or when requested.

Prior to trial, each party must submit two marked copies of exhibits and three copies of the exhibit list to chambers.

If settlement summary attachments exceed 20 pages, a hard copy must be sent to chambers by the date the summaries are due.

Motion to seal must identify specific injuries if materials are not sealed.

(ii) If the motion to file under seal is granted, file the complete, unredacted versions of the documents under seal by ECF on the docket (observing appropriate deadlines). Consistent with representations made when seeking leave to file under seal, and any related order, counsel should highlight the non-public portions of sealed documents.

Non-emergency documents cannot be filed under seal without leave.

When filing a redacted document, the party must submit an unredacted version with highlighted proposed redactions to Chambers or via CM/ECF.

Parties should also otherwise conform to the Clerk's general procedures for filing documents under seal.

Both the government's attorney and the defense attorney must file sentencing memoranda, motions, and exhibits at least 7 days before the sentencing hearing.

Counsel must file the completed Rule 26(f) meeting report with the Clerk at least five business days before the Rule 16 conference.

Settlement summary and confidential case summary are due 2 weeks prior to the settlement conference.

Each party must file its sentencing memorandum no later than seven days prior to the scheduled sentencing date.

Sentencing memoranda (exclusive of motions) must be filed no later than 7 days before scheduled sentencing date.

Cases should be tried within 1 year of filing, or 2 years if extended pretrial proceedings are necessary.

Discovery must be completed before arbitration; no discovery or dispositive motions after arbitration unless motion was filed before and unresolved.

All grounds for relief should be set forth in a single, comprehensive motion. A motion to dismiss, for example, should not be divided into separate motions for each count but rather should include all bases for relief.

Exhibits must be pre-marked, exchanged, and compiled into a joint exhibit book with electronic copy for final pretrial conference.

All motions in limine must be consolidated and filed together as a single omnibus motion.

Court encourages assigning court presentations and arguments to less experienced attorneys.

Judge encourages junior attorneys who worked on briefs to participate in oral argument.

Oral argument and motions encouraged in criminal cases.

Counsel are encouraged to let other trial team members argue all or parts of motions, participate in Rule 16 conferences, and prepare ancillary witnesses, provided they have access to the client and all information needed to prepare.

Court encourages junior lawyers to argue and will accommodate them with additional time.

Attorneys of record must maintain current contact information in their ECF user accounts and update all contact information displayed on the docket as needed.

Attorneys must file searchable briefs on the CM/ECF electronic system.

Counsel must be registered on ECF to participate in the conference.

Communications addressing substantive issues must also be filed on ECF, and advocacy during ex parte contacts with the judge's staff is prohibited.

Judge Hodge requires all counseled parties to use Electronic Case Filing (“ECF”). Proposed orders should be attached to corresponding motions or memoranda of law. Submission of pleadings, motions, or other filings to Chambers by any method other than ECF is not permitted. Except as expressly provided in Section I.C. Stipulations (above), the Court will not act on any submission that has not been docketed.

Counsel must disclose, serve, and maintain copies of all exhibits under the Federal and Local Rules whether or not the exhibits are filed on ECF, and must retain copies after proceedings conclude or the action terminates.

Judge Toplin permits correspondence from counsel on any matter, providing all other counsel in the matter are provided copies of such correspondence; and unless otherwise specified.

Counsel must mark and exchange exhibits before a hearing or trial begins.

Moving parties must serve the statement of undisputed material facts on all parties at least 28 days before the summary judgment motion deadline.

Rule 56 moving parties must provide a Word document of the Statement of Undisputed Material Facts to opposing counsel.

Pro hac vice counsel must pay the associated fee before the conference.

The pro hac vice admission fee must be submitted at the time the application is filed on the docket, or the application will be denied pending payment.

Pro hac vice motions submitted without the required fee will be denied.

Pro hac vice motions will be denied if the required filing fee is not submitted.