Judge Wendy Beetlestone
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- 2 copies
Binding: Three Ring Binder
Filings > 10 pages
- Upon Filing
Adjournments
- Extensions for trial dates, discovery deadlines, or dispositive motions must be made sufficiently in advance.
- Continuance requests must be filed as motions with reasons and defendant's position.
- Proposed orders must comply with Speedy Trial Act and include detailed findings.
- +2 more
Request must include
- Continuance requests must be filed at least 14 days before trial.
Communication
Phone
Chambers
Page & Word Limits5 rules
21 days to respond to Rule 12(b) or Rule 56 motions.
Court's wording
parties have twenty-one (21) days after service of a motion to dismiss under Federal Rule of Civil Procedure 12(b) or a motion for summary judgment under Federal Rule of Civil Procedure 56 to file their response.
Reply briefs limited to 10 pages, due within 7 days of opposition.
- Reply brief
- Up to 10 pages
Court's wording
Reply briefs are permitted. Reply briefs must be filed within seven (7) days of the date that a non-moving party files its opposition brief, may not exceed ten (10) pages, and must be limited to issues newly raised in the opposing
Motions briefs/memoranda limited to 30 pages (excluding TOC/attachments).
- Motion brief
- Up to 30 pages
- Format
- Double-spaced; 12-point
Excluded from page count
- •Table of contents
- •Attachments
Court's wording
Any brief or memorandum filed in support of or in opposition to a motion must be limited to thirty (30) pages of double-spaced 12-font text, excluding the table of contents and any attachments or addenda.
The sur-reply brief may not exceed five (5) pages.
- sur-reply
- Up to 5 pages
In standard track cases, the Court usually allows up to ninety (90) days from the date of the Rule 16 conference to complete discovery.
Document Format Requirements2 rules
Each point for charge shall be numbered and on a separate sheet of paper identifying the name of the requesting party.
All proposed exhibits shall be placed in binders accompanied by a table of contents. The table of contents should include the following columns: Exhibit # - Bates #; a brief description of the document; a column entitled “Stipulations” a column entitled “Introduced”; and a column entitled “Admitted”.
Document Filing Requirements22 rules
Stipulations must have original signatures, not filed on ECF, effective only after Court approval.
- Document
- Stipulation
Must include
- •Original signatures
Court's wording
Any stipulations, consent decrees, or other documents requiring Court approval or signature must be submitted in a form containing original signatures (faxed signatures are accepted). Please do not file Stipulations on ECF. Stipulations are not effective until approved by the Court.
Lead trial counsel must attend the Rule 16 conference. If a party fails to appear at a scheduled Rule 16 Conference, absent good cause, monetary sanctions may be applied.
Initial disclosures pursuant to Rule 26(a) shall be completed no later than seven (7) days before the Rule 16 conference.
At least three business days prior to the pretrial conference, counsel must complete and submit to the Court via ECF filing the joint status report of the Rule 26(f) meeting.
Any such motion must be accompanied by a proposed form of Order which, if approved by the Court, would grant the relief sought by the motion.
Such a memorandum shall include the elements of each offense to which the defendant is pleading guilty and legal citations for such elements.
Proposed jury instructions and verdict forms due 3 working days before trial.
Court's wording
Judge Beetlestone requires that at least three (3) working days before the date the case is set for trial, each party shall submit to the Court and serve on each other, two (2) copies of proposed points for charge and a proposed verdict form, and also shall provide those documents to Chambers in digital form in Microsoft Word format.
Judge Beetlestone requires the government to submit a guilty plea memorandum five (5) days prior to the guilty plea.
The sentencing memoranda should be submitted to the Court no later than five (5) days prior to the sentencing hearing.
Judge Beetlestone will not consider material not included in the appendix.
Any brief of twenty (20) pages or more shall include a table of contents and table of authorities.
- Document
- Brief
Must include
- •Table of contents
- •Table of authorities
she may require proposed findings of fact and conclusions of law no later than twenty-four (24) hours after such a hearing.
Counsel for the moving party shall email a copy of the Reply Statement of Undisputed Material Facts to Chambers in Microsoft Word format.
All pages of the joint appendix shall be consecutively “Bates stamped” and referenced in the motions and briefs by the Bates number assigned each page.
Judge Beetlestone expects discovery to commence upon receipt of the Notice scheduling the initial Rule 16 conference.
The joint appendix shall be filed by the movant no later than the date the initial motion for summary judgment is docketed.
Discovery motions must include certification of good faith resolution efforts.
- Document
- Discovery motion
Must include
- •Certificate of conference
Court's wording
All discovery motions must contain the certification required under Local Civil Rule 26.1(f). The Rule requires that counsel who is submitting the dispute to the Court include a certification that a good faith resolution effort has been made by counsel involved in the dispute. Judge Beetlestone expects that such a certification will be substantive, specific, and meaningful.
TRO petitioners must notify and serve respondents when practical.
Court's wording
Except in cases where the nature of the emergency precludes it, Judge Beetlestone requires the petitioner to notify the respondent of the nature of the request for a Temporary Restraining Order; to serve the petition and proposed Order upon the respondent, if practical; and to provide the respondent with notice of the date, time and location of the hearing or argument.
At the close of evidence, the parties shall submit to the Court a thumb drive which includes only those exhibits admitted into evidence. The documents on the thumb drive shall be provided to the Jury.
- Document
- Exhibits
Must include
- •Thumb drive
If the parties cannot resolve the problem through the reasonable efforts required by Local Civil Rule 26.1(f), they may file on the docket submit brief letters explaining the dispute and requested relief.
If a witness was on the stand at a recess or adjournment, the witness should be on the stand ready to proceed when court resumes.
V. Pro Hac Vice Admissions: To be admitted appearing before Judge Beetlestone pro hac vice, associate counsel of record should submit a written motion for admission prior to the day of the first appearance of out-of-state counsel. The admission of out-of-state counsel pro hac vice does not relieve associate counsel of responsibility for the matter before the Court.
- Document
- Motion
Should include
- •Pro hac vice admission
Filing & Service rules
Courtesy Copy Requirements
Courtesy copies should be printed double-sided in a three-ring binder, with dividers between the exhibits.
Courtesy copies should be printed double-sided in a three-ring binder, with dividers between the exhibits.
Page 3 | VII. Stipulations and Consent Decrees
or memorandum that exceeds (10) pages in length to chambers at the time of filing.
or memorandum that exceeds (10) pages in length to chambers at the time of filing.
Page 3 | VII. Stipulations and Consent Decrees
Unless the Court orders otherwise two copies of the exhibit binder(s) shall be made available for the Court's use.
Unless the Court orders otherwise two copies of the exhibit binder(s) shall be made available for the Court's use.
Sealing & Redaction Procedures
Confidentiality/sealing orders require good cause and specific language.
The Court will only approve confidentiality or sealing orders for good cause shown. See Pansy v. Borough of Stroudsburg, 23 F.3d 772 (3d Cir. 1994); In re: Avandia Marketing Sales Practices and Products Liability Litig, 924 F.3d 662 (3d Cir. 2019). All such orders must contain the following language or language substantially similar: “The court may order disclosure of any subject covered by this stipulation or modify this stipulation at any time in the interest of justice.”
Filing Bundling Requirements
Parties should collaborate to create a single numbered exhibit set for trial.
Judge Beetlestone strongly suggests that the parties work together to prepare a single set of sequentially numbered trial exhibits, without regard for who will propound the exhibit at trial.
Pre-Motion Conference Requirements
Motion to compel may be filed if telephone conference doesn't resolve discovery dispute.
If a discovery dispute is not resolved following a telephone conference and a motion to compel becomes necessary, the motion and any
Adjournment & Extension Requirements
Continuance requests must be filed as motions with reasons and defendant's position.
Requests for a continuance must be filed as a motion stating the reasons for the request. The motion should include the position of the defendant.
Page 15 | II. Trial Continuances
Sentencing continuance requests must include defendant's position.
All requests for continuance of sentencing hearings should include the position of the defendant.
Page 15 | VII. Sentencing Memoranda
Continuance requests must be filed at least 14 days before trial.
Any request for a continuance must be filed no later than fourteen (14) days in advance of the scheduled trial date.
Page 15 | II. Trial Continuances
Proposed orders must comply with Speedy Trial Act and include detailed findings.
The proposed form of Order must be consistent with the requirements of the Speedy Trial Act, 18 U.S.C. § 3161(h)(7)(A),(B), and must include a proposed finding that explains in reasonable detail why the ends of justice served by granting the requested continuance outweigh the best interest of the public and the defendant in a speedy trial.
Page 15 | II. Trial Continuances
Requests for continuances are strongly discouraged. In civil cases, counsel must have good cause for the request. If good cause exists, a continuance must be sought as soon as possible. Requests for continuances must be in writing and should be e-mailed to chambers copied to opposing counsel. A formal motion is not required. The party requesting a continuance must present the position of opposing counsel. If opposing counsel opposes the request, the requesting party must set up a conference call with the Court to resolve the matter.
Requests for continuances are strongly discouraged. In civil cases, counsel must have good cause for the request. If good cause exists, a continuance must be sought as soon as possible. Requests for continuances must be in writing and should be e-mailed to chambers copied to opposing counsel. A formal motion is not required. The party requesting a continuance must present the position of opposing counsel. If opposing counsel opposes the request, the requesting party must set up a conference call with the Court to resolve the matter.
Extensions for trial dates, discovery deadlines, or dispositive motions must be made sufficiently in advance.
If the request is for an extension or continuance of the trial date, discovery deadline, or the deadline for filing dispositive motions, it must be made sufficiently prior to the due date to allow time for the Court to consider it.
Chambers Communication Rules
All other communications should be filed as pleadings, motions, or applications.
G. All other written communications with the Court concerning any case assigned to the Court’s calendar should be by the filing of a pleading, motion, application, brief, legal memorandum or other similar filing provided for in the Federal Rules of Civil or Criminal Procedure or our Local Rules of Civil or Criminal Procedure. Do not write letters to the Court that are properly the subject of these filings.
Page 1 | PRELIMINARY GENERAL MATTERS
When counsel become aware of any unavoidable and compelling professional or personal conflicts affecting the trial schedule, they should notify Judge Beetlestone and opposing counsel immediately. Such notice may be given to Judge Beetlestone’s Deputy Clerk by telephone, but it must be confirmed in writing.
When counsel become aware of any unavoidable and compelling professional or personal conflicts affecting the trial schedule, they should notify Judge Beetlestone and opposing counsel immediately. Such notice may be given to Judge Beetlestone’s Deputy Clerk by telephone, but it must be confirmed in writing.
Letters are permitted for personal matters affecting counsel's participation.
E. When the participation of counsel in the case is expected to be affected by a personal matter concerning counsel, a party, a witness or counsel’s immediate family, such as medical problems, or other similarly personal problems or questions;
Page 1 | PRELIMINARY GENERAL MATTERS
Letters are permitted to confirm case settlement or dismissal.
F. To confirm or advise the Court that a case has been settled, dismissed or otherwise finally disposed;
Page 1 | PRELIMINARY GENERAL MATTERS
Uncontested continuances of Rule 16 deadlines are permitted by letter.
C. When there is an uncontested request for a continuance of the Rule 16. Scheduling Order deadlines not affecting the trial date or pool placement;
Page 1 | PRELIMINARY GENERAL MATTERS
Letters of transmittal are permitted when accompanying required documents.
A. When letters of transmittal accompany documents required to be sent to, or filed with, the Court or in another official office in the courthouse;
Page 1 | PRELIMINARY GENERAL MATTERS
Letters are permitted when specifically requested by the Court.
B. When counsel is specifically requested by the Court to communicate some information to the Court by letter;
Page 1 | PRELIMINARY GENERAL MATTERS
Judge Beetlestone permits correspondence with the Court under specific circumstances.
I. Correspondence with the Court: Judge Beetlestone permits correspondence with the Court under the following circumstances:
Page 1 | PRELIMINARY GENERAL MATTERS
Letters are permitted to seek Court's assistance with discovery disputes.
D. To seek the Court’s assistance in resolving a discovery dispute;
Page 1 | PRELIMINARY GENERAL MATTERS
Telephone communications are permitted when written communication cannot timely address a problem.
B. When a written communication concerning a case cannot timely address a problem, counsel may initiate necessary telephone communications with chambers. Issues appropriately addressed by telephone contact include:
Page 2 | III. Telephone Conferences
Telephone contact is permitted for scheduling conferences or proceedings.
1. Scheduling of conferences or proceedings, including pretrial and trial conferences;
Page 2 | III. Telephone Conferences
All such inquiries should be directed to the Deputy Clerk. Counsel should submit current email, telephone numbers and any changes to the Clerk’s Office, and to Judge Beetlestone’s Deputy Clerk.
All such inquiries should be directed to the Deputy Clerk. Counsel should submit current email, telephone numbers and any changes to the Clerk’s Office, and to Judge Beetlestone’s Deputy Clerk.
Page 2 | III. Telephone Conferences
Telephone contact is permitted for absolutely necessary time extensions.
5. Requests for absolutely necessary extensions of time to file any response, reply, brief, memorandum of law or the like.
Page 2 | III. Telephone Conferences
Telephone contact is permitted for arranging discovery dispute conferences.
4. Arrangements for telephone conferences regarding discovery disputes;
Page 2 | III. Telephone Conferences
Judge Beetlestone may hold telephone conferences for scheduling or discovery disputes.
III. Telephone Conferences A. Judge Beetlestone may hold telephone conferences to resolve scheduling matters or discovery disputes. The Court will notify counsel of the date and time for the telephone conference. In a civil case, counsel for the moving party will be responsible for initiating the telephone conference and contacting Judge Beetlestone through her Deputy Clerk after all parties are present on the call. In a criminal case, the United States Attorney’s Office will be responsible for initiating the call and contacting Judge Beetlestone through her Deputy Clerk after all parties are present on the call.
Page 2 | III. Telephone Conferences
Judge Beetlestone does not set aside specific days for oral arguments or hearings.
IV. Oral Arguments and Evidentiary Hearings: Judge Beetlestone does not set aside certain days or times for oral argument, motions, or evidentiary hearings. Hearings and argument are scheduled when requested or warranted.
Page 2 | IV. Oral Arguments and Evidentiary Hearings
Telephone contact is permitted for witness attendance issues.
2. Attendance of witnesses;
Page 2 | III. Telephone Conferences
Telephone contact is permitted for exhibit handling or video replay arrangements.
3. Exhibit handling or arrangements for video replay;
Page 2 | III. Telephone Conferences
Telephone conferences are generally held to address discovery disputes.
Judge Beetlestone will generally hold a telephone conference to address the dispute.
Junior Lawyer Participation Incentives
Multiple attorneys may examine different witnesses or argue different points, but not the same witness or point.
Judge Beetlestone will permit more than one attorney for a party to examine different witnesses or to argue different points before the Court, but she will not permit two attorneys for a party to examine the same witness or argue the same point. See Local Rule of Civil Procedure 43.1.
Page 13 | Examination of Witnesses or Argument by More than One Attorney