Judge Timothy J. Savage's rules set a pre-motion procedure for covered motions. Motions in limine must be filed by Scheduling Order deadline.
Judge Timothy J. Savage's rule states these limits: 7 pages. Government must file trial memorandum 1 week before trial with specific content.
Judge Timothy J. Savage's rule states these limits: 10 pages. Reply briefs limited to 10 pages, due within 7 days of opposition brief.
Judge Timothy J. Savage's formatting rule includes margins top 1 inches, bottom 1 inches, left 1 inches, right 1 inches, separate sheet per instruction, numbered, and party name identification. Each jury instruction/interrogatory must be on separate sheet with party name.
The rule requires proposed order. Government must file proposed findings and conclusions before suppression/Starks/Daubert hearings.
The rule requires legal authority. Each proposed jury instruction must include legal authority.
Parties may contact Judge Timothy J. Savage's chambers by letter ecf only as allowed by the rule. Voir dire questions must be resolved with deputy clerk the day before jury selection.
Requests should be made at least 2 weeks in advance when this rule applies before Judge Timothy J. Savage. Suppression, Starks, and Daubert hearings held at least 2 weeks before trial.
Yes. Judge Timothy J. Savage's rules include a junior lawyer participation incentive. Only one attorney per party may examine same witness or argue same point.
Oral argument granted on motions at judge's discretion.
Pretrial conferences held only in complex cases or with multiple attorneys.
Suppression, Starks, and Daubert hearings held at least 2 weeks before trial.
Government must file proposed findings and conclusions before suppression/Starks/Daubert hearings.
Parties may request to supplement proposed findings after hearing.
Proposed jury instructions and interrogatories due 7 days before trial.
Each jury instruction/interrogatory must be on separate sheet with party name.
Each proposed jury instruction must include legal authority.
Must indicate if model jury instruction is unchanged or modified.
Modified model instructions must underline additions and bracket deletions.
Government must file trial memorandum 1 week before trial with specific content.
Defendant may file trial memorandum but not required.
Trial pool cases require 48-hour notice to commence trial.
Voir dire questions must be resolved with deputy clerk the day before jury selection.
Objections must cite rule number or be one word only.
Sidebar conferences are discouraged except for unanticipated issues.
Motions in limine must be filed by Scheduling Order deadline.
Time limits for opening statements and summations may be imposed based on case issues and trial length.
Rebuttal cannot rehash closing argument.
Only one attorney per party may examine same witness or argue same point.
Evidentiary issues must be resolved privately before involving deputy clerk.
Videotaped testimony objections must be resolved 10 days before final pretrial conference.
Videotaped testimony must be edited and tested before trial.
Exhibits must be provided at final pretrial conference and trial in three-ring binders.
Exhibits admitted at close of case-in-chief, not during testimony.
Exhibits published after witness examination or before break, with permission for during testimony.
Counsel must meet to discuss and submit agreed-upon jury instructions and verdict forms.
Proposed jury instructions should only cover substantive issues, not basic instructions.
Counsel must cooperate in preparing joint jury instructions or face sanctions.
Submitting a proposed instruction does not waive objection to it.