Superior Court of Fulton County Document Filing Requirements

Applies to

Discovery response

Boilerplate and rote objections in discovery responses are prohibited.

Boilerplate objections in response to discovery requests are prohibited. Parties should not invoke a litany of rote objections, e.g., attorney-client privilege, work-product immunity, overly broad/unduly burdensome, irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, etc.

Applies to

Discovery response

Discovery responses may not include a 'Preamble' or 'General Objections' section asserting blanket objections.

General objections are also prohibited, i.e., a party shall not include in its response to a discovery request a <Preamble= or <General Objections= section stating that the party objects to the discovery request <to the extent that= it violates some rule pertaining to discovery, e.g., attorney-client privilege; work product immunity; the prohibition against discovery requests that are vague, ambiguous, overly broad, or unduly burdensome; etc.

Applies to

Discovery response

Each individual discovery request must be met with specific objections limited to only those that actually apply to that particular request.

Instead, each individual discovery request must be met with specific objections thereto -- but only those objections that actually apply to that particular request.

Applies to

Discovery response

A party that objects to a discovery request but still responds must expressly state whether the response is complete, i.e., whether additional information or documents would have been provided but for the objection(s).

Finally, a party which objects to a discovery request but then responds to the request must indicate whether the response is complete, i.e., whether additional information or documents would have been provided but for the objection(s).

Applies to

Ministerial motion

Must include

proposed order

Every ministerial motion (e.g., motion to exceed page limit or extend discovery) must be accompanied by a proposed order.

Every ministerial motion (e.g., motion to exceed page limit, to extend discovery, etc.) must be accompanied by a proposed order (with the proposed order submitted electronically as a Microsoft Word document).

Applies to

Oral argument request

A party seeking oral argument on a motion for summary judgment must comply with Uniform Superior Court Rule 6.3 and file a pleading requesting oral argument.

A party seeking oral argument on a motion for summary judgment must comply with Uniform Superior Court Rule 6.3 and file a pleading to that effect.

Applies to

Jury charge request

Each party must provide a list identifying the title and number of each requested pattern charge using current Council of Superior Court Judges pattern charges, without needing to recite the charge text.

Each party shall provide a list identifying the title and number of each proposed pattern charge requested by the party, using the current pattern charges published by the Council of Superior Court Judges. The parties need not recite the text of pattern charges.

Applies to

Jury charge request

Requests for non-pattern charges must include citation to applicable statutory or case authority.

Parties requesting non-pattern charges shall provide citation to applicable statutory or case authority.

Applies to

Exhibits

All exhibits must be pre-marked and numbered before they can be introduced at trial.

All exhibits must be pre-marked and numbered for introduction at trial.

Applies to

Child support documents

Parties must submit proposed Child Support Worksheets, Child Support Addendum, and Parenting Plans at the 30-Day Status Conference.

Parties are required to submit proposed Child Support Worksheets, Child Support Addendum, and Parenting Plans at the 30-Day Status Conference.

Applies to

Consolidated pretrial order

Consolidated Pretrial Orders are required and must be emailed to Chambers one week before trial.

Consolidated Pretrial Orders are required and are due to Chambers one week prior to trial by email to Senior Staff Attorney Jessica Cummings for those set before Judge Benton, or Litigation Manager Stephanie Cooper for trials set before Judicial Officer Greg Miller.

Applies to

Consolidated pretrial order

Each individual exhibit must be itemized in the Consolidated Pretrial Order; general categories are prohibited.

The Parties are required to itemize each individual exhibit in the Consolidated Pretrial Order and avoid listing general categories of documents (e.g. "all discovery produced in this case," "email," or "photographs'"').

Applies to

Domestic relations financial affidavit

In cases involving minor children, parties must file updated financial affidavits, child support worksheets, addendum, and parenting plan one week before trial.

If the case involves minor children, the Parties SHALL exchange and file with the Court an updated Domestic Relations Financial Affidavit, a proposed Child Support Worksheet, proposed Child Support Addendum and proposed Parenting Plan one week prior to trial, pursuant to U.S.C.R. 24.2.

Applies to

Petition to withdraw

Petitions to Withdraw must comply with U.S.C.R. 4.3 and state that written notice was given, ten days have expired, no objection exists, or withdrawal is with client's consent.

Any Petition to Withdraw as Counsel must be in full compliance with U.S.C.R. 4.3. The Petition shall state that the attorney has given written notice to the client and that ten days have expired since notice, that there has been no objection, or that withdrawal is with the client's consent.

Applies to

Attorney fee request

Attorney fee requests must cite the authorizing statute, provide required factors, and include findings and conclusions required by law.

Parties seeking attorney's fees shall cite to the statute or other provision of law authorizing same, provide the requisite factors and considerations the Court must assess, and the findings and conclusions required by law.

Applies to

Motion for extension

Must include

proposed order

Extension motions must include a proposed order for the Court's consideration.

Such motions must provide a detailed, fact-based explanation of the need for the extension including the amount of time needed to provide outstanding discovery, along with a proposed order for the Court's consideration.

Applies to

Motion to compel

Motions to compel must be case-specific and itemize articulable instances of non-compliance; 'form' motions will not be considered.

discovery obligations. The parties are ordered not to file "form" motions seeking an order compelling the generalized disclosure of discoverable materials or the general exclusion of evidence. Any such non-specific "form" motions will not be considered by the Court. Should a party need to file a motion to compel discovery, the party shall itemize the articulable and case-specific instances in which the party believes the opposing party has failed to comply with

Applies to

Expert notice

Expert notices must be in writing and include a meaningful summary of testimony and the expert's qualifications.

Any party seeking to rely on expert testimony at trial (or any evidentiary hearing) must provide written notice to the opposing party. This notice must include a meaningful summary of the expert's testimony as well as his or her qualifications to serve as an expert witness.

Applies to

Motion

Motions must be particularized, tailored to the facts, limited to a single issue, and identify the specific statement or evidence at issue.

Only those motions sufficiently particularized as to provide legal notice to the opposing parties will be considered by the Court. Generalized and omnibus motions are not to be filed, and if filed will be denied as vague, dilatory, and in violation of this order. Motions must specify, with particularity, the item, statement, or event at issue and must be tailored to the facts of the case at hand. Each motion shall be limited to a single issue and filed separately. Thus, a general motion seeking to suppress all statements or all evidence is insufficient and will be denied. The motion must identify the specific statement or evidence that the movant is seeking to suppress and must provide a theory of suppression.

Applies to

Entry of appearance

Attorneys must file an entry of appearance or notice of substitution of counsel that fully complies with U.S.C.R. 4.2 or 4.3(3) before appearing before the Court.

No attorney shall appear in that capacity before the Court until the attorney has filed an entry of appearance that fully complies with U.S.C.R. 4.2 or a notice of substitution of counsel that fully complies with U.S.C.R. 4.3(3).

Applies to

Voir dire questions

Parties must submit a list of potential voir dire questions.

A list of potential voir dire questions.

Applies to

Witness list

Parties must submit a witness list with names and titles/positions, separate from discovery requirements.

A list of all potential witnesses. This witness list is for the Court's use during voir dire and need not list anything more than the witnesses' name and any applicable title or position. This list is separate from all pre-trial discovery requirements concerning witnesses, including the disclosure of all requisite identifying information and the content of expert opinions, if any.

Applies to

Motion in limine

Each motion in limine must be a separate document limited to discrete evidentiary/procedural matters; improper use will be denied as untimely.

All motions in limine. Each such motion shall be a separate document. Such motions should be limited to discrete evidentiary or procedural matters, such as the admissibility of a specific piece of evidence. It is not proper to attempt to raise, as a motion in limine, matters that should have been resolved during the pre-trial motions phase of proceedings, such as a motion to sever, etc. Such a motion cast as a motion in limine will be denied as untimely absent good cause shown.

Applies to

Jury charges

Parties must submit all proposed jury charges; pattern charges by number only, non-pattern with full text and authority.

Proposed Jury Charges. The parties must submit all proposed requests to charge, including the charges of the particular offense(s) alleged in the indictment. For pattern charges, each party is to submit only the pattern charge number and not the text of the charge itself. F For non-pattern or modified pattern charges, the parties are required to submit the full text and cite the case law, statute, or other authority supporting such requested

Applies to

Verdict form

Parties must submit a proposed verdict form.

A proposed verdict form.

Applies to

Proposed order

Proposed orders must be submitted by email to the Litigation Manager and opposing counsel within three business days of pronouncement.

Orders. Counsel shall promptly prepare orders or judgments to be presented to the Court. Proposed orders shall be submitted by email to Litigation Manger Stephanie Cooper (Stephanie.Cooper@fultoncountyga.gov) and opposing counsel simultaneously and within three business days of the pronouncement of that order or judgment, unless directed otherwise by the

Applies to

All written submissions

Must include

ai disclosure

Any attorney or pro se litigant using AI to prepare, draft, or review a filing must include a certification of AI use and citation verification at the end of the document, before the signature block.

Certification: Any attorney or pro se litigant who uses AI in any capacity to prepare, draft, or review a filing shall disclose such use in the document with the following certification: This document was generated with the assistance of [identify AI tool(s) used, e.g., Chat GPT, Perplexity, Claude, etc.]. I hereby certify under penalty of perjury that, despite reliance on an AI tool, I have independently reviewed this document to confirm accuracy, legitimacy, and use of good and applicable law. Page 1 of 2 ===== PAGE 2 ===== I hereby certify under penalty of perjury that every citation to law, case, statute, or the record in this document has been verified as accurate and that it exists as cited and for the proposition cited. The above certification must appear at the end

Applies to

Exhibits

Counsel must mark exhibits with labels and provide documentary evidence digitally to the court reporter after trial.

Counsel is required to mark with exhibit labels and provide all documentary evidence to the court reporter in digital format as soon as possible after trial, unless otherwise ordered by the Court.

Applies to

Exhibits

The State must take and permanently store all original exhibits after trial or hearing.

All original exhibits introduced by both the State and the defendant(s) must be taken by the State at the conclusion of the trial or hearing and permanently stored by the State.

Applies to

Filing

Must include

ai disclosure

Each filing must include a note indicating whether AI was used to prepare or draft it.

All parties should note whether artificial intelligence (AI) was used to prepare or draft a filing in this Court at the end of each filing.

Applies to

Pretrial order

Parties may not submit individual pre-trial order portions without written certification of good faith efforts to consolidate.

No party shall submit their own individual portion of a pre-trial order to the Court without written certification detailing their good faith efforts to present the Court with a fully consolidated order.

Applies to

Pretrial order

Pre-trial orders must designate witnesses needing interpreters and the required language; interpreter contact info must be listed if known, and promptly provided once known.

Pursuant to Uniform Superior Court Rule 7.3 Any proposed pre-trial order submitted by any party shall designate any witnesses whose testimony will need the services of an interpreter and the language, including sign language for the deaf, for which the interpreter is required. If known, the name, address, and telephone number of the interpreter or interpreting service intended to be used shall be listed. If this information is not known at the time the pre-trial order is signed, it shall be promptly provided to Court and opposing counsel once known.

Applies to

Request for oral hearing

Oral argument on summary judgment requires a separate pleading entitled 'Request for Oral Hearing' filed with the motion or within 5 days after response.

However, oral argument on a motion for summary judgment shall be permitted upon written request made in a separate pleading bearing the caption of the case and entitled "Request for Oral Hearing," and provided that such pleading is filed with the motion for summary judgment or filed not later than five (5) days after the time for response.

Applies to

Proposed order

Must include

proposed order

Counsel must email a proposed final order to the Staff Attorney in Word format prior to the hearing.

Prior to the hearing, counsel shall email a proposed final order to the Staff Attorney in Word format.

Applies to

Filing

All filings must include the email addresses of counsel or pro se parties.

To aid the Court in also observing this practice, all filings by Parties are required to include the email addresses of counsel or Pro-se Parties on the matter.

Applies to

Conflict letter

Conflict letters must be timely, comply with U.S.C.R. 17.1, be filed with the Clerk and received by the Court at least 7 days before the conflict, and be copied to opposing parties; parties are not excused until Court confirmation, and counsel must notify all parties if a listed matter is disposed; non-compliance results in denial.

CONFLICT LETTERS Any conflicts must be substantiated with a timely conflict letter in full compliance with U.S.C.R. 17.1 which letter is filed with the Clerk9s office and received by the Court at least seven days prior to the date of conflict pursuant to U.S.C.R. 17.1(B). All conflict letters must be copied to opposing parties. Parties are not excused from the calendar unless or until they have received confirmation from the Court. In the event any matter listed in the conflict letter is disposed of prior to the end of the calendar, counsel shall immediately notify all Parties and the Court and proceed with the remaining cases absent good cause shown pursuant to U.S.C.R.17.1(C). Conflict letters are DENIED if they fail to comply with

Applies to

Expert disclosure

Expert disclosures must include specified details and be made 30 days prior to the end of discovery.

The disclosures shall include the names, subject matters, substance of facts and opinions, and a summary of the grounds for each opinion which any expert is expected to testify at trial on issues which the disclosing party bears the burden of proof. Disclosures shall be made 30 days prior to the end of discovery.

Applies to

Reply

Replies and sur-replies will not be considered without prior express court permission.

No replies or sur-replies will be considered absent prior express permission of Court.

Applies to

Motion

Parties must file authenticated, admissible evidence contemporaneously with a motion to enforce a settlement (or response), e.g., via authenticating affidavits.

The Parties are directed to file contemporaneously with such motion or the response thereto, authenticated and admissible evidence. Specifically, and by way of example only, even signed settlement agreements, and email between counsel, as well as most other documents, require affidavits authenticating the documents for the Court to consider them as evidence.

Applies to

Pretrial order

Consolidated Pretrial Orders are required, due to Chambers one week before trial by email, and must itemize each individual exhibit rather than listing general categories.

Consolidated Pretrial Orders are required and are due to Chambers one week prior to trial by email to Senior Staff Attorney Elizabeth Marum for those set before Judge Eaton, or Litigation Manager Cathy Robinson for trials set before Judicial Officer Osby. The Parties are required to itemize each individual exhibit in the Consolidated Pretrial Order and avoid listing general categories of documents

Applies to

Proposed order

In cases involving minor children, parties must file an updated Domestic Relations Financial Affidavit, proposed Child Support Worksheet, proposed Child Support Addendum, and proposed Parenting Plan one week before trial, emailing clean editable versions to chambers.

If the case involves minor children, the Parties SHALL exchange and file with the Court an updated Domestic Relations Financial Affidavit, a proposed Child Support Worksheet, proposed Child Support Addendum and proposed Parenting Plan one week prior to trial, pursuant to U.S.C.R. 24.2 and shall email a clean, editable format of the proposed orders to elizabeth.marum@fultoncountyga.gov or cathy.robinson@fultoncountyga.gov.

Applies to

Petition to withdraw

A Petition to Withdraw as Counsel must comply with U.S.C.R. 4.3 and state that written notice was given to the client, ten days have elapsed, there was no objection, or withdrawal is with the client's consent.

Any Petition to Withdraw as Counsel must be in full compliance with US.C.R. 4.3. The Petition shall state that the attorney has given written notice to the client and that ten days have expired since notice, that there has been no objection, or that withdrawal is with the client9s consent.

Applies to

Attorney fee request

Attorney fee requests must cite the authorizing statute and set forth the required factors, considerations, and legal findings; otherwise, the request is denied.

Parties seeking attorney9s fees shall cite to the statute or other provision of law authorizing same, provide the requisite factors and considerations the Court must assess, and the findings and conclusions required by law. Absent such detail, attorney fee requests are DENIED.

Applies to

Motion

Motions must be particularized, specifying the specific item, statement, or event at issue; generalized and omnibus motions will be denied as vague and dilatory.

Only those motions sufficiently particularized as to provide legal notice to the opposing parties will be considered by the Court. Generalized motions and omnibus motions are not to be filed and if filed will be denied as vague, dilatory and in violation of this order. Motions must specify, with particularity, the item or statement or event at issue and must be tailored to the facts of the case at hand. Thus, a general motion seeking to suppress any and all statements or any and all evidence is insufficient and will be denied. The motion must identify the specific statement or evidence that the movant is seeking to suppress, as well as provide a theory of suppression.

Applies to

Jury instructions

Parties must submit all proposed jury charges; pattern charges require only the charge number, while non-pattern or modified charges require the full text with citation to supporting authority.

The parties must submit all proposed requests to charge which, for the State, includes charges of the particular offense(s) alleged in the indictment. For pattern charges, each party is to submit ONLY the pattern charge NUMBER and not the text of the charge itself. For all non-pattern or modified pattern charges, the parties are required to submit the full text and cite the case law, statutory or other authority supporting such requested charge.

Applies to

Proposed voir dire questions

Counsel must submit all proposed voir dire questions to the Court as directed.

Counsel shall submit to the Court all proposed voir dire questions as directed above.

Applies to

Exhibit list

Parties intending to introduce trial exhibits must provide an exhibit list to the Court and one copy to all other parties prior to jury selection, including each exhibit's number and brief description.

Any party that intends to introduce exhibits during trial must provide an exhibit list to the Court and one copy to all other parties prior to jury selection. The exhibit list should include for each exhibit both the exhibit number and a brief description of what the exhibit purports to be.

Applies to

Brief

Must include

ai disclosure

Any attorney or pro se litigant using AI to prepare, draft, or review a filing must include a specified AI-use and citation-verification certification at the end of the document before the signature block.

Certification: Any attorney or pro se litigant who uses Al in any capacity to prepare, draft, or review a filing shall disclose such use in the document with the following certification: This document was generated with the assistance of [identify Al tool(s) used, e.g., Chat GPT, Perplexity, Claude, etc. ]. | hereby certify under penalty of perjury that, despite reliance on an Al tool, have independently reviewed this document to confirm | accuracy, legitimacy, and use of good and applicable law. Page 1 of 2 ===== PAGE 2 ===== | hereby certify under penalty of perjury that every citation to law, case, statute, or the record in this document has been verified as accurate and that it exists as cited and for the proposition cited. The above certification must appear at the end

Applies to

Brief

Noncompliance with the AI certification order may result in striking the filing, sanctions, or disciplinary referral; mistake, lack of technical expertise, or time constraints are not accepted as excuses, and AI use does not relieve ethical or professional obligations.

Failure to comply with this Order may result in the Court taking appropriate action, including without limitation striking the filing, imposing sanctions, or disciplinary referral. Mistake, lack of technical expertise, or time constraints will not be accepted as good faith excuses for noncompliance. The use of Al does not relieve any attorney or pro se litigant of their ethical obligations and/or professional obligations (such as Georgia Rules of Professional Conduct 1.1 and 3.1).

Applies to

Discovery motion

Must include

certificate of conference

Counsel must file a statement certifying that a conference occurred and that efforts to resolve the dispute by agreement failed.

If the good faith efforts to resolve the dispute are not successful, then at the time of filing the motion, “counsel shall also file a statement certifying that such conference has occurred and that the effort to resolve by agreement the issues raised failed.” U.S.C.R. 6.4(B).

Applies to

Pretrial order

Parties must submit a fully consolidated pre-trial order by email to the Staff Attorney no later than one week before the trial calendar begins.

If a party files a jury demand, or if a party anticipates wanting a trial by jury, then the parties shall submit, by email, a fully consolidated pre-trial order directly to the Staff Attorney no later than one week before the trial calendar begins.

Applies to

Discovery extension motion

Must include

proposed order

Discovery extension motions must include a detailed fact-based explanation and a proposed order.

Such motions must provide a detailed, fact- based explanation of the need for the extension including the amount of time actually needed to provide outstanding discovery, along with a proposed order for the Court’s

Applies to

Expert notice

Parties must provide written notice of expert testimony (with a summary and qualifications) at least 14 days before trial and 7 days before any evidentiary hearing.

Experts. Any party seeking to rely on expert testimony at trial (or any evidentiary hearing) must provide written notice to the opposing party. This notice must include a meaningfiil summary of the expert’s testimony as well as her qualifications to serve as an expert witness. The notice must be provided at least fourteen days before trial and seven days before any evidentiary

Applies to

Motion in limine

Motions in limine must be limited to discrete evidentiary or procedural matters; improper attempts to raise pre-trial matters will be denied as untimely absent good cause.

All motions in limine. Each such motion shall be a separate document and attachment to the email to opposing counsel and to Ms. Little. Such motions should be limited to discrete evidentiary or procedural matters, such as the admissibility of a specific piece of evidence. As mentioned above, it is not proper to attempt to raise, as a motion in limine, matters that should have been resolved during the pre-trial motions phase of proceedings, such as the submission of identification evidence or a confession or a motion to sever, etc. Such a motion cast as a motion in Zimine will be denied as untimely absent good cause shown.

Applies to

Exhibit list

Parties must mark exhibits before trial, provide an exhibit list (two hard copies to the Court and one to each opposing party) prior to jury selection, preview exhibits with opposing counsel, and obtain Court approval before publishing exhibits to the jury.

Exhibits should be marked before trial. Any party that intends to introduce exhibits during trial shall provide two hard copies of an exhibit list to the Court (one to the judge and one to the court reporter) and one copy to each opposing party prior to jury selection; The exhibit list should include for each exhibit both the exhibit number and a brief description of what the exhibit purports to be. Counsel are under a continuing obligation to preview exhibits with opposing counsel before relevant witnesses are called to the stand. It is not an appropriate use of the jurors' time to have the parties reviewing proposed exhibits while the witness waits on the stand and the jurors sit idly in the box. Counsel shall obtain approval from the Court before publishing any evidence/exhibits to the jury.

Applies to

Proposed order

Must include

proposed order

Proposed orders must be submitted by email to the Court and opposing counsel simultaneously within three business days of the ruling unless directed otherwise.

Proposed orders shall be submitted by email to the Court (April.Woods@fultoncountvga.gov) and opposing counsel simultaneously and within three business days of the pronouncement of that order or judgment unless directed otherwise by the Court.

Applies to

Entry of appearance

No attorney may appear before the Court until filing an entry of appearance complying with U.S.C.R. 4.2 or a notice of substitution of counsel complying with U.S.C.R. 4.3(3).

No attorney shall appear in that capacity before the Court until the attorney has filed an entry of appearance that fully complies with U.S.C.R. 4.2 or a notice of substitution of counsel that fully ' complies with U.S.C.R. 4.3(3).

Applies to

Discovery motion

Must include

certificate of conference

A certificate of conference must be filed with a discovery motion if the parties could not resolve the dispute.

If the good faith efforts to resolve the dispute are not successful, then at the time of filing the motion, "counsel shall also file a statement certifying that such conference has occurred and that the effort to resolve by agreement the issues raised failed." U.S.C.R. 6.4(8).

Applies to

Pre trial order

Parties must submit a fully consolidated pre-trial order by email to the Staff Attorney no later than one week before the trial calendar begins.

If a party files a jury demand, or if a party anticipates wanting a trial by jury, then the parties shall submit, by email, a fully consolidated pre-trial order directly to the Staff Attorney no later than one week before the trial calendar begins.

Applies to

Pre trial order

Parties may not submit individual portions of the pre-trial order without written certification of good-faith efforts to consolidate.

No party may submit their own individual portions of the pre-trial order to the Court without written certification detailing their good-faith efforts to present the Court with a fully consolidated order.

Applies to

Verdict forms

Attorneys must email proposed verdict forms in Word format to the Staff Attorney at least one week before the trial calendar begins.

The attorneys shall submit any proposed verdict forms to the Staff Attorney by email in Word format no later than one week prior to the beginning of the trial calendar.

Applies to

Jury charges

Parties must email proposed jury charges in Word format to the Staff Attorney at least three business days before the trial calendar begins.

Parties shall email proposed jury charges in Word version to the Staff Attorney at least three business days before the beginning of the trial calendar.

Applies to

Filing

Must include

ai disclosure

Attorneys and pro se litigants must include a certification disclosing any AI-assisted preparation and verifying accuracy of the document and its citations, placed at the end of the document before the signature block.

se litigants): Certification: Any attorney or pro se litigant who uses Al in any capacity to prepare, draft, or review a filing shall disclose such use in the document with the following certification: This document was generated with the assistance of [identify Al tool(s) used, e.g., Chat GPT, Perplexity, Claude, etc.1. | hereby certify under penalty of perjury that, despite reliance on an Al tool, have independently reviewed this document to confirm accuracy, legitimacy, and use of good and applicable law. | hereby certify under penalty of perjury that every citation to law, case, statute, or the record in this document has been verified as accurate and that it exists as cited and for the proposition cited. The above certification must appear at the end of the document, before the signature block.

Applies to

Ministerial motion

Must include

proposed order

Every ministerial motion must be copied to chambers and accompanied by a proposed order submitted electronically as a Microsoft Word document.

Every ministerial motion (e.g., motion to file reply brief, to extend discovery, etc.) must be copied to chambers and accompanied by a proposed order submitted to chambers electronically as a Microsoft Word document.

Applies to

Oral argument pleading

Parties seeking oral argument on a summary judgment motion must comply with USCR 6.3 and file a pleading to that effect.

seeking oral arguments on a motion for summary judgment must comply with Uniform Superior Court Rule 6.3 and file a pleading to that effect.

Applies to

Expert testimony notice

The expert testimony notice must include a meaningful summary of the expert's expected testimony and her qualifications.

This notice must include a meaningful summary of the expert's expected testimony as well as her qualifications to serve as an expert witness.

Applies to

Motion

Each motion must be limited to a single issue and specify with particularity the items, statements, or events at issue; generalized and omnibus motions are denied as vague and dilatory.

Generalized motions and omnibus motions are not to be filed; they will be denied as vague and dilatory. Each motion shall be limited to a single issue (e.g., suppression of statement, suppression of fruits of search warrant, etc.); multi-issue motions seeking to suppress, for example, both physical evidence and statements are not proper. In this Page 3 of 5 ===== PAGE 4 ===== vein, motions must specify, *with particularity*, the item(s) or statement(s) or event(s) at issue. Thus, a motion seeking to suppress “any and all statements” is insufficient; the motion must identify the specific statement(s) the movant is seeking to suppress, as well

Applies to

Entry of appearance

Attorneys must provide an email address at the entry of appearance, either through the filing or by emailing the Litigation Manager.

At the entry of appearance of counsel, the attorneys are required to provide an email address through the filing or by emailing the Litigation Manager.

Applies to

Discovery motion

Motions to compel discovery must be case-specific and itemize articulable instances of non-compliance; boilerplate or form motions will not be considered.

parties are directed to comply with all discovery obligations. The parties are ordered not to file boilerplate or "form" motions seeking an order compelling the generalized disclosure of discoverable materials or the general exclusion of evidence. Any such non- specific "form" motions will not be considered by the Court. Should a party need to file a motion to compel discovery, the party shall itemize the articulable and case-specific instances in which the party believes

Applies to

Motion

Motions must be sufficiently particularized, limited to a single issue, and filed separately; generalized and omnibus motions will be denied.

Only those motions sufficiently particularized as to provide legal notice to the opposing parties will be considered by the Court. Generalized and omnibus motions are not to be filed, and if filed will be denied as vague, dilatory, and in violation of this Order. Motions must specify, with particularity, the item, or statement or event at issue and must be tailored to the facts of the case at hand. Each motion shall be limited to a single issue and filed separately.

Applies to

Proposed jury charges

Pattern jury charges are submitted by number only; non-pattern or modified charges require full text with supporting authority.

For un-modified pattern charges, each party is to submit ONLY the pattern charge NUMBER and not the text of the charge itself. For all non-pattern or modified pattern charges, the parties are required to submit the full text and cite the case law, statute, or other authority supporting such requested charge.

Applies to

Exhibit list

Parties must provide the Court and each opposing party an exhibit list prior to jury selection that identifies each exhibit by number and description.

Any party that intends to introduce exhibits during trial shall provide two hard copies of an exhibit list to the Court (one to the judge and one to the court reporter) and one copy to each opposing party prior to jury selection. The exhibit list should include for each exhibit both the exhibit number and a brief description of what the exhibit purports to be.

Applies to

Discovery motion

Must include

certificate of conference

Discovery motions must include a certificate of conference.

"[a]t the time of filing the motion, counsel shall also file a statement certifying that such [pre-filing] conference [amongst affected parties or entities] has occurred and that the effort to resolve by agreement the issues raised failed."

Applies to

Discovery response

Boilerplate objections to discovery requests are prohibited; parties must particularize each objection.

Boilerplate objections in response to discovery requests are prohibited. Parties should not carelessly invoke a litany of rote objections, e.g., attorney-client privilege, work-product immunity, overly broad/unduly burdensome, not reasonably calculated to lead to the discovery of admissible evidence, etc. Instead, parties are required to particularize their objections.

Applies to

Discovery response

General objections and 'to the extent that' boilerplate are prohibited; each request requires specific objections.

General objections are prohibited, i.e., a party shall not include in his response to a discovery request an introductory or "General Objections" section stating that the party objects to the requests "to the extent that" they violate some rule pertaining to discovery, e.g., attorney-client privilege, work product immunity; the prohibition against discovery requests that are vague, ambiguous, overly broad, or unduly burdensome, etc. Instead, each individual discovery request must be met with specific objections that apply to that request. All general objections may be disregarded by the requesting party and the Court.

Applies to

Discovery response

When a party objects but still responds, it must state whether the response is complete absent the objections.

A party who objects to a discovery request but then responds to the request must indicate whether the response is complete, i.e., whether additional information or documents would have been provided but for the propounded objection(s). For example, in response to an interrogatory, a party is not permitted to raise objections and then state, "Subject to these objections and without waiving them, the response is as follows..." unless the party expressly indicates whether additional information would have been included in the response but for the objection(s).

Applies to

Consolidated pretrial order

In jury cases, parties must email a fully consolidated pretrial order to the Staff Attorney at least one week before the trial calendar; individual portions require written certification or may result in sanctions.

a party files a jury demand in this case, or if a party anticipates wanting a trial by jury, then the parties shall submit, by email, a fully consolidated pre-trial order ("PTO") by email directly to the Judge's Staff Attorney no later than one (1) week before the trial calendar begins. No party may submit their own individual portions of the PTO to the Court without written certification detailing their good- faith efforts to present the Court with a fully consolidated order. Failure of any party to submit its portion of the PTO may result in sanctions including dismissal of their claims (or the entire case) for want of prosecution.

Applies to

Deposition objection list

Parties relying on depositions must confer to agree on testimony; objecting parties must provide the Court a list of disputed page and line numbers with the relevant deposition text by the motions-in-limine deadline or the objection is waived.

trial calendar. If parties intend to rely on deposition testimony, that party must confer with all other parties prior to trial and attempt to agree on the testimony to be presented. If the parties cannot agree on what portions of the deposition testimony, if any, should be excluded, the objecting party must prepare a list of the page and line numbers at issue and provide it to the Court no later than the time that party files its motions in limine (one (1) week prior to beginning the trial calendar) - along with the relevant text from the deposition(s). Failure to comply with this requirement will constitute a waiver of the objection to the challenged

Applies to

Exhibit list

Parties must provide the Court an exhibit list before jury selection, showing each exhibit's number/letter and a brief description.

Before jury selection begins, the parties shall provide the Court with a copy of the exhibit list. Exhibit lists shall include for each exhibit both the exhibit number/letter and a brief description of what the exhibit purports to be.

Applies to

Filing

Must include

ai disclosure

Any attorney or pro se party using AI to prepare filings must include a certification of AI use and citation verification at the end of the document before the signature block.

Any attorney or pro-se party who uses AI in any capacity to prepare, draft, or review a filing or submission to the Court shall disclose such use in the document with the following certification: This document was generated with the assistance of [identify Al tool(s) used, e.g., Chat GPT, Perplexity, Claude, etc. ]. I hereby certify under penalty ofperjury that, despite reliance on an AI tool, I have independently reviewed this document to confirm accuracy, legitimacy, and use ofgood and applicable law. I hereby certify under penalty of perjury that every citation to law, case, statute, or the record in this document has been verified as accurate and that it exists as cited and for the proposition cited. The above certification must appear at the end of the document, before the signature block.

Applies to

Proposed final order

Must include

proposed order

Counsel must email a proposed final order to the Staff Attorney before the hearing.

Prior to the hearing, counsel shall email a proposed final order to the Staff Attorney in Word format.

Applies to

Case specific scheduling order

Discovery and motion filing deadlines are set by a Case Specific Scheduling Order entered at Plea and Arraignment, and re-indicted cases remain bound by the original case's CSSO dates absent good cause and court order.

The specific deadlines for discovery and motion filing are provided in accordance with a separate Case Specific Scheduling Order ("CSSO") at Plea and Arraignment ("P &A"). Re-indicted cases are likewise bound by the CSSO dates, notices and published calendars for the originally indicted case, absent good cause shown and further Order of this Court.

Applies to

Motion for extension

Must include

proposed order

Motions for extension of the discovery deadline must be accompanied by a proposed Order for the Court's consideration.

Such motions must provide a detailed, fact-based explanation of the need for the extension, including the amount of time actually needed to provide outstanding discovery, along with a proposed Order for the Court's consideration.

Applies to

Motion to compel discovery

Motions to compel discovery must itemize specific, case-specific instances of discovery noncompliance; non-specific 'form' motions seeking generalized disclosure or exclusion will not be considered.

The parties are ordered not to file "form" motions seeking an order compelling the generalized disclosure of discoverable materials or the general exclusion of evidence. Any such non-specific "form" motions will not be considered by the Court. Should a party need to file a motion to compel discovery, the party shall itemize the articulable and case-specific instances in which the party believes the opposing party has failed to comply with discovery obligations.

Applies to

Expert witness notice

Parties relying on expert testimony must provide written notice to the opposing party including a meaningful summary of the expert's testimony and the expert's qualifications.

Any party seeking to rely on expert testimony at trial (or any evidentiary hearing) must provide written notice to the opposing party. The notice must include a meaningful summary of the expert's testimony, as well as, his/her/their qualifications to serve as an expert witness.

Applies to

Standard procedural motion

Must include

proposed order

Counsel must email a proposed Order to Litigation Manager Seneca McRae for standard procedural motions such as motions to withdraw as counsel, continuances, and deadline extensions.

Counsel shall ensure he/she/they email, to Litigation Manager Seneca McRae, a proposed Order in connection with any "standard" procedural motions (such as, Motions to Withdraw as Counsel, Motions for Continuance, Motions for Extending Deadline Imposed by the Court and similar such motions).

Applies to

Motion

Only sufficiently particularized motions tailored to the facts of the case will be considered; generalized and omnibus motions, including blanket suppression motions, will be denied.

Only those motions sufficiently particularized as to provide legal notice to the opposing parties will be considered by the Court. Generalized and omnibus motions are not to be filed, and if filed will be denied as vague, dilatory and in violation of this Order. Motions must specify, with particularity, the item or statement or event at issue and must be tailored to the facts of the case before the Court. Thus, a general motion seeking to suppress any and all statements or any and all evidence is insufficient and will be denied. The motion must identify the specific statement or evidence that the movant is seeking to suppress, as well as provide a theory of suppression.

Applies to

Motion for continuance

Must include

proposed order

A continuance/status conference motion must identify the grounds for the request and include a proposed order.

Such motion shall specifically identify the grounds for the request for continuance and/or conference and. as indicated above. a proposed order in WORD format shall be emailed to Litigation Manager Seneca McRae

Applies to

Pretrial submissions

Pretrial submissions must include all proposed general voir dire questions, a list of potential witnesses (with names and any applicable professional titles/positions), and motions in limine.

a. All proposed GENERAL voir dire Questions b. A list of potential witnesses This witness list will simply provide the Court with the names of any potential witnesses and any applicable professional titles/positions. c. Motions in Limine

Applies to

Jury instructions

The State must include the applicable portion of the code section for each indicted offense in its submitted jury charges, and those charges do not count against the State's 15 NON-PATTERN charge limit.

Counsel for the State shall also include, within its submitted charges, the applicable portion of the code section for each offense alleged in the indictment; these jury charges will not count against the number of NON-PATTERN charges allowed the State.

Applies to

Jury instructions

NON-PATTERN jury charges must be submitted with the full text of each requested charge, followed by a reference to the case law, statute, or other authority supporting it.

For all NON-PATTERN charges, the parties are required to submit the full text of each such requested NON-PATTERN charge and, below such text, the requesting party shall reference the case law, statute or other authority supporting such requested NNON-PATTERN charge.

Applies to

Proposed voir dire questions

Counsel must submit all proposed general voir dire questions to the Court, which will confer with counsel before voir dire begins to determine which questions will be permitted.

Counsel shall submit to the Court all proposed general voir dire questions as directed above. Prior to the commencement of the voir dire process, the Court will discuss with the counsel/parties which of their proposed questions will be permitted to be asked.

Applies to

Voir dire questions

Counsel may use electronic devices for voir dire questions but must bring a paper copy of all anticipated general and individual voir dire questions to court as a backup in case electronic use interferes with jury selection.

Counsel is permitted to use electronic devices containing his/her/their voir dire questions during the jury questioning phase of the trial. HOWEVER, should the use of such electronic devices during juror questioning interfere with the efficiency of the jury selection process, the Court will compel counsel to utilize a paper copy of the voir dire questions in interacting with the jurors. Accordingly, counsel shall bring to court a PAPER COPY of his/her/their anticipated general and individual voir dire questions for potential use during the voir dire process.

Applies to

Exhibits

All exhibits must be marked before trial begins.

Exhibits SHALL be marked BEFORE trial.

Applies to

Stipulation

Stipulations must be in writing, signed by the parties, and presented to the Court outside the jury's presence; oral stipulations before the jury are prohibited without prior Court permission.

All stipulations must be made in writing. signed by the parties and presented to the Court outside the presence of the jury. No counsel should offer to enter into a stipulation orally in front of the jury. unless prior permission is granted by the Court.

Applies to

Victim impact statement

Victim impact statements must be in writing, on point, and directed to the Court and not others.

All victim impact statements must be in writing. on point and directed to the Court and not others,

Applies to

Request for leniency

Requests for leniency must be in writing, on point, and directed to the Court and not others.

Any requests for leniency must be in writing. on point and directed to the Court and not others,

Applies to

Entry of appearance

No attorney may appear before the Court until filing an entry of appearance complying with USCR 4.2 or a notice of substitution of counsel complying with USCR 4.3(3).

No attorney shall appear in that capacity before the Court until the attorney has filed an entry of appearance which fully complies with USCR. 4.2 or a notice of substitution of counsel which fully complies with USCR.4.3(3).

Applies to

Leave of absence

A Leave of Absence that is not filed or served pursuant to USCR 16.1 or 16.2, that is filed before entry of appearance of counsel in a case at issue, or that is not served upon chambers stands denied under USCR 16.6.

Note that any Leave of Absence not filed or served pursuant SCR 16.1 or 6.2 or filed prior to entry of appearance of counsel in acase at issue and not served upon chambers. stands DENIED under USCR .6.

Applies to

Motion

Motions must be sufficiently particularized and identify the specific item, statement, or evidence at issue; omnibus motions are prohibited.

Only those motions sufficiently particularized as to provide legal notice to the opposing parties will be considered by the Court. Generalized and omnibus motions are not to be filed, and if filed will be denied as vague, dilatory and in violation of this Order. Motions must specify, with particularity, the item or statement or event at issue and must be tailored to the facts of the case before the Court. Thus, a general motion seeking to suppress any and all statements or any and all evidence is insufficient and will be denied. The motion must identify the specific statement or evidence that the movant is seeking to suppress, as well as provide a theory of suppression.

Applies to

Proposed order

Proposed orders must be emailed to the Litigation Manager and opposing counsel within three business days of the order's pronouncement.

Unless directed otherwise, proposed orders shall be submitted by email to the Court via the Court's Litigation Manager, Ms. Angela Sims (Angela.Sims@fultoncountyga.gov) and opposing counsel simultaneously and within three business days of the pronouncement of that order or judgment.

Applies to

Entry of appearance

An attorney may not appear before the Court until filing an entry of appearance complying with USCR 4.2 or a notice of substitution of counsel complying with USCR 4.3(3).

No attorney shall appear in that capacity before the Court until the attorney has filed an entry of appearance which fully complies with USCR, 4.2 or a notice of substitution of counsel which fully complies with USCR, 4.3(3).

Applies to

Conflict letter

A filed conflict letter does not excuse counsel's appearance unless there is an actual conflict, and counsel failing to follow USCR 17.1 and its subsections will not be deemed to have a conflict.

Counsel should be particularly mindful of the fact that the filing of a conflict letter **DOES NOT** serve to excuse counsel from appearing before the Court unless there is an **actual** conflict. Should counsel fail to follow the guidance of USCR 17.1 and its subsections, counsel **shall not** be deemed to have a conflict, in accordance with USCR 17.1 (A).

Applies to

Filing

Must include

ai disclosure

Counsel and pro se parties must disclose any AI use in preparing a filing by signing and filing a Disclosure of Use of Artificial Intelligence before the signature block, using the required certification language.

All counsel and *pro se* parties must disclose the use of artificial intelligence (AI) in any capacity to prepare documents submitted to the Court. If AI was used in any way to prepare a filing or submission to the Court or chambers, counsel and/or *pro se* parties are **REQUIRED** to sign and file a Disclosure of Use of Artificial Intelligence at the end of said document, before the signature block, stating as follows:

Applies to

Brief

Briefs must not rely on AI-generated case law, and mistake, time constraints, or lack of technical expertise are not accepted as good faith excuses for violations.

Counsel and *pro se* parties are cautioned that mistake, time constraints and lack of technical expertise are not recognized by the Court as a good faith excuse for submission of documents that violate the Georgia Civil Practice Act or this disclosure rule. Accordingly, arguments in briefs to the Court which are supported by AI-generated case law (that is, cases that do not exist or are substantially dissimilar from their presentation to the Court) are not acceptable.

Applies to

Deposition objection list

The objecting party must provide a list of disputed deposition page/line numbers with the relevant text to the Court when filing its motion in limine; failure to comply waives the objection.

If the parties cannot agree on what portions of the deposition testimony, if any, should be excluded, the objecting party must prepare a list of page and line numbers at issue and provide it to the Court **at the time it files its motion *in limine*** – along with the relevant text from the deposition(s). Failure to comply with this requirement will constitute a waiver of objection to the challenged deposition testimony.

Applies to

Exhibit list

Before jury selection, each party must provide the Court an exhibit list identifying each exhibit by number/letter and a brief description.

Before jury selection begins, each party shall provide the Court with an exhibit list. The exhibit list should include for each exhibit both the exhibit number/letter and a brief description of what the exhibit purports to be.

Applies to

Witness list

Parties intending to call witnesses or present deposition testimony must provide two copies of a witness list to the Court and one copy to each opposing party before jury selection.

Any party intending to call witnesses (or present deposition testimony) must provide two copies of a witness list to the Court and one copy to each opposing party prior to jury selection.

Applies to

Pattern jury charge list

Pattern jury charges must be listed and numbered on a single cover page by name and paragraph number, and the text of Pattern charges must not be included.

All Pattern jury charges shall be listed and numbered on a single cover page identifying each charge by name and paragraph number. Counsel SHALL NOT include the text of such Pattern jury charges.

Applies to

Non pattern jury charge

Each non-pattern jury charge must include the charge text and the supporting case/statute citation.

All NON-pattern jury charges must include the text of each charge and the case/statute citation which supports the respective charge.

Applies to

Scheduling order

Parties must submit an agreed proposed Scheduling Order using the Court's form within 30 days of service of the last answer; if none is submitted, the Court enters a court-issued order and may deny later requests to amend it.

Within 30 days of service of the answer (or last answer if there are multiple defendants), the parties shall submit to the Court an agreed-upon proposed Scheduling Order, using the Court's Scheduling Order form

Applies to

Motion amended scheduling order

A Motion for Amended Scheduling Order must include all current and requested extended deadlines, accomplished and remaining discovery tasks, and a proposed amended scheduling order; motions lacking these items will be denied.

A motion, entitled Motion for Amended Scheduling Order, seeking an extension of the deadlines shall include the following: 1. all current deadlines and all requested extended deadline dates; 2. a list of discovery tasks accomplished as of the filing of the motion and a schedule of additional tasks to be completed during the requested extension; and 3. a proposed amended scheduling order.

Applies to

Discovery motion

Must include

certificate of conference

A motion to compel must include a certification that the parties conferred on the discovery issues; otherwise it will be denied.

When a motion to compel is filed, it shall conform to the requirements of Uniform Superior Court Rule 6.4. Motions filed without a certification that the parties conferred as to the discovery issues in the motion will be denied.

Applies to

Motion

Must include

proposed order

Ministerial motions must include a proposed order and be submitted to the Court's staff attorney.

Ministerial motions (e.g., motion to extend, exceed page limits, withdrawal) shall include a proposed order and submitted to Mitchell. the Court's staff attorney.

Applies to

Summary judgment motion

Summary judgment motions must conform to OCGA § 9-11-56 and USCR 6.5, and each party's statements of fact must be supported by record citations.

When a motion for summary judgment is filed, it shall conform to the requirements of O.C.G.A. § 9-11-56 and Uniform Superior Court Rule 6.5. Each party must support its 6.5 statements of fact with citations to record evidence (i.e., including depositions, documents, affidavits, stipulations, admissions, interrogatory responses, etc.).

Applies to

Default judgment

Motions or proposed orders for default judgment must recite the particulars of the default, including service facts and answer deadline; otherwise denied.

Any motion or proposed order asking the Court to grant default judgment must recite the particulars of the default, including facts and dates associated with service and resulting answer deadline. Motions that fail to recite such facts will be denied.

Applies to

Pretrial order

A party may only submit its individual portions of the pre-trial order to the Court with a written certification detailing good-faith efforts to present a fully consolidated order.

No party may submit their own individual portions of the pre-trial order to the Court without written certification detailing their good-faith efforts to present the Court with a fully consolidated order.

Applies to

Pretrial order

Failure to submit a pre-trial order waives the right to a jury trial and elects a non-jury trial; counsel's failure also authorizes the court to enter an appropriate order or impose sanctions.

proposed order). Failure to submit a pre-trial order to this Court shall act as an affirmative and irrevocable waiver of a jury trial and an affirmative election to proceed with a

Applies to

Motion

Must include

proposed order

扩展动议必须提供详细、基于事实的延期原因解释，并附上拟议命令供法院考虑。

Such motions must provide a detailed, fact-based explanation of the need for the extension, along with a proposed order for the Court's consideration.

Applies to

Discovery motion

Notices or motions alleging discovery deficiencies must itemize the specific deficiencies and discovery to be produced.

Any notice or motion alleging a deficiency in discovery shall itemize the specific alleged deficiencies and the specific discovery to be produced.

Applies to

Motion

Motions must be specific and particularized; generalized omnibus motions will be denied.

Motions must specify, with particularity, the item or statement or event at issue and must be tailored to the facts of the case at hand. Thus, a general motion seeking to suppress any and all statements or any and all evidence is insufficient and will be denied.

Applies to

Pre trial submission

Pre-trial submissions must include a list of voir dire questions, witness list, motions in limine, proposed jury charges, and a proposed verdict form.

the following: 1. A list of potential voir dire questions. See below Voir Dire Procedure utilized by Judge Krause. 2. A list of all potential witnesses. This witness list is for the Court's use during voir dire and need not list anything more than the witnesses' name and any applicable title or position. This list is separate from pre-trial discovery requirements concerning witnesses, including the disclosure of all requisite identifying information and the content of expert opinions, if any. 3. All motions in limine. Such motions should be limited to discrete evidentiary or procedural matters, such as the admissibility of a specific piece of evidence. 4. Proposed Jury Charges. The parties must submit all proposed requests to charge, including for the State charges of the particular offense(s) alleged in the indictment. For pattern charges, each party is to submit the pattern charge number and not the text of the charge itself. For non-pattern or modified pattern charges, the parties are required to submit the full text in Word format and cite the case law, statute or other authority supporting such requested charge. 5. A proposed verdict form.

Applies to

Motion

Must include

proposed order

Discovery extension motions must include a proposed order.

Such motions must provide a detailed, fact-based explanation of the need for an extension and a proposed extended deadline, along with a proposed order for the Court's consideration.

Applies to

Expert notice

Expert notice must include a meaningful summary of the expected testimony and the expert's qualifications.

Any party seeking to rely on expert testimony at trial (or any evidentiary hearing) must provide written notice to the opposing party. This notice must include a meaningful summary of the expert's expected testimony as well as her qualifications to serve as an expert witness.

Applies to

Motion

Generalized and omnibus motions are barred; each motion must be limited to a single issue and specify with particularity the items, statements, or events at issue.

Generalized motions and omnibus motions are not to be filed. They will be denied as vague and dilatory.... Rather, each motion shall be limited to a single issue.... Motions must specify, with particularity, the item(s), statement(s), or event(s) at issue.

Applies to

Motion

The movant must include hearing logistics information with any courtesy copy of a motion when a hearing is requested or required.

It is the responsibility of the movant, when providing a courtesy copy of any motion to Chambers, to provide the following information if a hearing is requested/required: (a) whether the Defendant obj ects .to a motions hearing via video conference; (b) the estimated time for presentation of the motion; (c) the estimated number of witnesses; and (d) whether an interpreter is required (and, if so, the

Applies to

Written waiver of presence

In absentia hearings will not be held until a written waiver of the Defendant's presence is filed in the record.

At its discretion, the Court may schedule in absentia bond or other motions hearings. Such matters will not: be heard until a written waiver of the Defendant’s presence is filed in the record.

Applies to

Motion in limine

Motions in limine must be limited to discrete evidentiary or procedural matters, cite applicable law, and will be denied as untimely if the matter should have been resolved in the pre-trial phase absent good cause.

Motions in limine. Motions should be limited to discrete evidentiary or procedural matters and- shall cite applicable law. As noted above, matters that should have been resolved in the pro-trial phase of proceedings will be denied as untimely absent good cause.

Applies to

Motion

Motions for attorney's fees must cite authorizing statutes, set forth the factors the Court must assess, and identify required findings and conclusions, or the request may be denied.

All motions for attorney's fees shall cite to all relevant statutes or other provisions of law authorizing the request. Such motions shall also set forth the requisite factors and considerations the Court must assess, as well as identify the findings and conclusions required by law. Absent such detail, attorney's fee requests may be denied.

Applies to

Pretrial order

Consolidated pretrial orders are required in every case, due one week prior to trial, and delivered via email to the appropriate judicial officer's staff.

Consolidated pretrial orders are required in every case; they are due one week prior to trial and should be delivered via e-mail to Monica Niles at monica.niles@fultoncountyga.gov for trials before Judge McBurney and to Deedra Nelson at deedra.nelson@fultoncountvga.gov for trials before Judicial Officer Kaye.

Applies to

Domestic relations financial affidavit

In cases involving minor children, parties must exchange, email to the Court, and e-file an updated domestic relations financial affidavit, proposed child support worksheet, addendum, and parenting plan one week prior to trial.

Pursuant to USCR 24.2, if the case involves minor children, the parties must (1) exchange, (2) e-mail to the Court, and (3) e-file an updated domestic relations financial affidavit, a proposed child support worksheet, proposed child support addendum and proposed parenting plan one week prior to trial.

Applies to

Petition to withdraw

Petitions to withdraw as counsel must comply with USCR 4.3 or they will be denied.

Petitions to withdraw as counsel must comply with USCR 4.3; failure to do so will result in the petition being denied.

Applies to

Discovery motion

Must include

proposed order

Motions to extend the discovery deadline must include a proposed order.

along with a proposed order

Applies to

Discovery motion

Defendant must not file generalized discovery motions; discovery litigation must be limited to specific alleged failures.

17-16-4(c). The Defendant is directed not to file generalized motions compelling disclosure of otherwise discoverable materials. Rather, the Defendant shall limit discovery litigation to specific instances in which the Defendant believes the State has failed to comply with its discovery

Applies to

Motion

Each motion must be limited to a single issue and must identify with particularity the item, statement, or event at issue.

Rather, each motion shall be limited to a single issue (e.g., suppression of statement, suppression of fruits of search warrant, etc.); multi-issue motions seeking to suppress, for example, both physical evidence and statements are not proper. In this vein, motions must specify, with particularity, the item(s) or statement(s) or event(s) at issue.

Applies to

Discovery motion

Motions to compel discovery must itemize articulable, case-specific instances of non-compliance; non-specific form motions will not be considered.

The parties are ordered not to file "form" motions seeking an order compelling the generalized disclosure of discoverable materials or the general exclusion of evidence. Any such non-specific "form" motions will not be considered by the Court. Should a party need to file a motion to compel discovery, the party shall itemize the articulable and case-specific instances in which the party believes the opposing party has failed to comply with discovery obligations.

Applies to

Expert notice

Parties relying on expert testimony must provide written notice to the opposing party with a summary of the testimony and the expert's qualifications, at least 14 days before the Final Plea/Trial Calendar Call and seven days before any evidentiary hearing.

Any party seeking to rely on expert testimony at trial (or any evidentiary hearing) must provide written notice to the opposing party. This notice must include a meaningful summary of the expert's testimony as well as his or her qualifications to serve as an expert witness. The notice must be provided at least 14 days before the Final Plea/Trial Calendar Call and seven days before any evidentiary hearing requiring expert testimony.

Applies to

Motion

Motions must be particularized, limited to a single issue, identify the specific item/statement/evidence at issue, and state a theory; generalized omnibus motions will be denied.

Only those motions sufficiently particularized as to provide legal notice to the opposing parties will be considered by the Court. Generalized and omnibus motions are not to be filed, and if filed will be denied as vague, dilatory, and in violation of this order. Motions must specify, with particularity, the item, statement, or event at issue and must be tailored to the facts of the case at hand. Each motion shall be limited to a single issue and filed separately. Thus, a general motion seeking to suppress all statements or all evidence is insufficient and will be denied. The motion must identify the specific statement or evidence that the movant is seeking to suppress, and must provide a theory of suppression.

Applies to

Entry of appearance

Attorneys must file an entry of appearance or notice of substitution of counsel complying with U.S.C.R. 4.2/4.3(3) before appearing.

No attorney shall appear in that capacity before the Court until the attorney has filed an entry of appearance that fully complies with U.S.C.R. 4.2 or a notice of substitution of counsel that fully complies with U.S.C.R. 4.3(3).

Applies to

Motion

Must include

proposed order

Every ministerial motion must be accompanied by a proposed order submitted electronically as a Microsoft Word document.

Every ministerial motion (e.g., motion to exceed page limit, to extend discovery, etc.) must be accompanied by a proposed order (with the proposed order submitted electronically as a Microsoft Word document).

Applies to

Document

Must include

ai disclosure

All counsel and pro se parties must include an AI disclosure statement within the certificate of service for any document prepared with AI assistance.

All counsel and pro se parties must disclose the use of artificial intelligence (AI) in any capacity to prepare documents submitted to the Court by including the following disclosure within the certificate of service: "This document was generated with the assistance of [identify AI tool name]. I hereby certify under penalty of perjury that, despite reliance on an AI tool, I have independently reviewed this document to confirm accuracy, legitimacy, and use of good and applicable law."

Applies to

Motion in limine

Each motion in limine must be a separate document limited to discrete evidentiary or procedural matters; motions raising matters that should have been resolved earlier will be denied as untimely absent good cause.

All motions in limine. Each such motion shall be a separate document. Such motions should be limited to discrete evidentiary or procedural matters, such as the admissibility of a specific piece of evidence. As mentioned above, it is not proper to attempt to raise, as a motion in limine, matters that should have been resolved during the pre-trial motions phase of proceedings, such as a motion to sever, etc. Such a motion cast as a motion in limine will be denied as untimely absent good cause shown.

Applies to

Proposed order

Must include

proposed order

Proposed orders must be emailed to Litigation Manager Cheryl Vortice and opposing counsel simultaneously within three business days of the order or judgment, unless the Court directs otherwise.

Counsel shall promptly prepare orders or judgments to be presented to the Court. Proposed orders shall be submitted by email to Litigation Manager Cheryl Vortice and opposing counsel simultaneously and within three business days of the pronouncement of that order or judgment, unless directed otherwise by the Court.

Applies to

Motion

Must include

proposed order

Extension motions must include a detailed fact-based explanation, the time needed, and a proposed order.

Such motions must provide a detailed, fact-based explanation of the need for the extension including the amount of time needed to provide outstanding discovery, along with a proposed order for the Court's consideration.

Applies to

Motion

Motions to compel must itemize articulable and case-specific instances of non-compliance; form motions seeking generalized disclosure or exclusion of evidence will not be considered.

The parties are ordered not to file "form" motions seeking an order compelling the generalized disclosure of discoverable materials or the general exclusion of evidence. Any such non-specific "form" motions will not be considered by the Court. Should a party need to file a motion to compel discovery, the party shall itemize the articulable and case-specific instances in which the party believes the opposing party has failed to comply with discovery obligations.

Applies to

Motion

Motions must be sufficiently particularized, limited to a single issue, and filed separately; generalized and omnibus motions will be denied.

Only those motions sufficiently particularized as to provide legal notice to the opposing parties will be considered by the Court. Generalized and omnibus motions are not to be filed, and if filed will be denied as vague, dilatory, and in violation of this order. Motions must specify, with particularity, the item, statement, or event at issue and must be tailored to the facts of the case at hand. Each motion shall be limited to a single issue and filed separately.

Applies to

Notice of appearance

An attorney must file an entry of appearance (U.S.C.R. 4.2) or a notice of substitution of counsel (U.S.C.R. 4.3(3)) before appearing before the Court.

No attorney shall appear in that capacity before the Court until the attorney has filed an entry of appearance that fully complies with U.S.C.R. 4.2 or a notice of substitution of counsel that fully complies with U.S.C.R. 4.3(3).

Applies to

Motion in limine

Each motion in limine must be a separate document limited to discrete evidentiary or procedural matters; motions raising matters that should have been resolved earlier will be denied as untimely absent good cause.

All motions in limine. Each such motion shall be a separate document. Such motions should be limited to discrete evidentiary or procedural matters, such as the admissibility of a specific piece of evidence. It is not proper to attempt to raise, as a motion in limine, matters that should have been resolved during the pre-trial motions phase of proceedings, such as a motion to sever, etc. Such a motion cast as a motion in limine will be denied as untimely absent good cause shown.

Applies to

Jury instructions

Parties must submit all proposed jury charges; pattern charges by number only, non-pattern or modified pattern charges with full text and supporting authority.

The parties must submit all proposed requests to charge, including the charges of the particular offense(s) alleged in the indictment. For pattern charges, each party is to submit only the pattern charge number and not the text of the charge itself. For non-pattern or modified pattern charges, the parties are required to submit the full text and cite the case law, statute, or other authority supporting such requested charge.

Applies to

Stipulation

Stipulations must be in writing, signed by the parties, and presented outside the jury's presence.

All stipulations must be made in writing, signed by the parties, and presented to the Court outside the presence of the jury.

Applies to

Pretrial order

A party may not submit its own individual pre-trial order portions to the Court without written certification of good-faith efforts toward a consolidated order.

No party may submit their own individual portions of the pre-trial order to the Court without written certification detailing their good-faith efforts to present the Court with a fully consolidated order.

Applies to

Motion

Must include

proposed order

Ministerial motions must be accompanied by a proposed order, submitted electronically as a Word document.

Every ministerial motion (e.g., motion to file reply brief, to extend discovery, etc.) must be accompanied by a proposed order (with the proposed order submitted electronically as a Microsoft Word document).

Applies to

Proposed order

Proposed orders on summary judgment motions must include detailed findings of facts and conclusions of law.

Proposed orders on motions for summary judgment should include detailed findings of facts and conclusions of law which the Court may adapt as appropriate.

Applies to

Pretrial order

Failure to submit a pre-trial order results in an election for a bench trial.

Failure to submit a pre-trial order will be deemed an election to proceed with a bench trial.

Applies to

Proposed order

Must include

proposed order

Parties seeking to import their own equipment must provide a proposed order to Ms. Candler at least two business days before trial.

Any party seeking such an order must provide a proposed order to Ms. Candler at least two business days before trial.

Applies to

Exhibits

All exhibits and demonstrative evidence must be marked, digitized (scanned), and exchanged before trial begins.

All exhibits and demonstrative evidence must be marked, digitized (scanned) and exchanged prior to the start of trial.

Applies to

Exhibits

The parties must confer before trial on any issues of exhibit authenticity.

The parties must confer before trial concerning any issues of authenticity.

Applies to

Exhibit list

Parties introducing trial exhibits must provide an exhibit list to the Court and each opposing party before jury selection; the list should include each exhibit's number and a brief description.

Any party that intends to introduce exhibits during trial must provide an exhibit list to the Court and one copy to each opposing party prior to jury selection. The exhibit list should include for each exhibit both the exhibit number and a brief description of what the exhibit purports to be.

Applies to

Exhibits

Counsel must preview exhibits with opposing counsel before relevant witnesses are called to testify.

Counsel are under a continuing obligation to preview exhibits with opposing counsel before relevant witnesses are called to the stand.

Applies to

Witness list

Parties intending to call witnesses or present deposition testimony must provide a witness list to the Court and each opposing party before jury selection.

Any party that intends to call witnesses (or present deposition testimony) must provide a witness list to the Court and one copy to each opposing party prior to jury selection.

Applies to

Jury charges

Counsel must submit proposed jury charges to the Court before jury selection or by the court-set deadline.

Counsel must submit to the Court any proposed jury charges prior to jury selection, or by the specific deadline set by the Court.

Applies to

Motion

Must include

proposed order

Extension motions must present a proposed order for the Court's consideration.

Motions for an extension of that deadline shall be submitted in writing to the Court; such motions must provide a detailed, fact-based explanation of the need for the extension, along with a proposed order for the Court9s consideration.

Applies to

Notice of discovery deficiency

A Notice of Discovery Deficiency must be filed before a party may seek the remedy of evidence exclusion.

If any party seeks to employ the remedy of evidence exclusion, a Notice of Discovery Deficiency must be filed.

Applies to

Motion

Motions must be particularized to a single issue, specify with particularity the item(s), statement(s), or event(s) at issue, and provide a theory of suppression; generalized and omnibus motions will be denied as vague and dilatory.

Generalized motions and omnibus motions are not to be filed; they will be denied as vague and dilatory. Motions seeking to suppress 'everything,' to include items not present in a particular case (e.g., an identification in a case in which no identification was made) are improper and should not be filed. Rather, each motion shall be limited to a single issue (e.g., suppression of statement, suppression of fruits of search warrant, etc.); multi-issue motions seeking to suppress, for example, both physical evidence and statements are not proper. In this vein, motions must specify, with particularity, the item(s) or statement(s) or event(s) at issue. Thus, a motion seeking to suppress 'any and all statements' is insufficient; the motion must identify the specific statement(s) the movant is seeking to suppress, as well as provide a theory of suppression.

Applies to

Voir dire questions

Proposed voir dire questions must be filed with the Clerk of Court, and parties need only submit additional questions beyond the Court's general ones.

A list of proposed voir dire questions. The Court has general questions it propounds (see Document Appendix). Parties only need to submit additional proposed questions. This shall be filed with the Clerk of Court.

Applies to

Motion in limine

Motions in limine must state the relief sought and legal basis, should be limited to discrete evidentiary matters, and substantive motions masquerading as motions in limine will be denied as untimely absent compelling justification.

All motions in limine shall state clearly the relief sought and the legal basis therefor. Such motions should be limited to discrete evidentiary or procedural matters, such as the admissibility of a medical examiner9s photos from an autopsy or the propriety of using a defendant9s purported moniker of <Maniac.= It is not proper to raise, via motions in limine, matters that should have been resolved during the pre-trial motions phase of proceedings, such as the admissibility of identification evidence or a confession. Absent compelling justification, such substantive motions masquerading as motions in limine will be denied as untimely.

Applies to

Motion in limine

All motions in limine must be filed with the Clerk of Court.

All motions in limine must be filed with the Clerk of Court.

Applies to

Voir dire questions

Counsel must submit all proposed voir dire questions to the Court as directed in the pre-trial submission requirements.

Voir Dire Procedure. Counsel shall submit to the Court all proposed voir dire questions as directed above.

Applies to

Exhibit list

Exhibit list must be provided to the Court and other parties prior to jury selection and include exhibit numbers and descriptions.

Any party that intends to introduce exhibits during trial must provide an exhibit list to the Court and one copy to all other parties prior to jury selection. The exhibit list should include for each exhibit both the exhibit number and a brief description of what the exhibit purports to be.

Applies to

Witness list

Witness list must be provided to the Court and other parties prior to jury selection and include all potential witnesses.

Any party that intends to call witnesses shall provide two copies of a witness list to the Court and one copy to every other party prior to jury selection. This list should include all potential witnesses; it is not sufficient for a party to rely on the indictment or documents provided in discovery as a witness list.

Applies to

Pretrial order

The Consolidated Pretrial Order must state all theories of liability, legal issues, damages sought, actionable conduct, and affirmative defenses.

Upon compiling material for the submission of the Consolidated Pretrial Order, the plaintiff shall explicitly state each and every theory of liability and legal issues raised, together with the type and amount of each type of damage sought. The specific actionable conduct shall be set out, and, in a multi-defendant case, the actionable conduct of each defendant shall be identified. The defendant shall explicitly set out any affirmative defenses upon which it intends to rely at trial, as well as satisfy the above requirements with respect to any counterclaims.

Applies to

Pretrial order

The Consolidated Pretrial Order must identify trial witnesses by name, or such witnesses may be excluded from trial; parties may not reserve the right to supplement their lists or adopt another party's list.

In identifying witnesses, it is not sufficient to include boiler plate language covering groups of potential witnesses, such as "all individuals identified during discovery." Instead, trial witnesses must be identified by name. Failure to identify a witness, including expert witnesses, by name in the consolidated pretrial order may result in the exclusion of the undisclosed witness' testimony from trial. In listing witnesses or exhibits, a party may not reserve the right to supplement his list, nor shall a party adopt another party's list by reference.

Applies to

Pretrial order

Parties must identify in the pretrial order each exhibit and deposition, interrogatory, or request to admit response they may introduce; such items are admitted at trial unless objected to in the pretrial order.

In preparing the pre-trial order, each party shall identify to opposing counsel each deposition, interrogatory or request to admit response, or portion thereof, which the party expects to or may introduce at trial, except for impeachment. All exhibits, depositions, interrogatories, and requests to admit responses shall be admitted at trial when offered unless the opposing party indicates an objection to it in the pre-trial order.

Applies to

Discovery extension request

Discovery extension requests must include current and proposed deadlines, discovery conducted, requested extension, and a schedule of outstanding discovery.

The request for a discovery extension, for which a formal motion is not required, shall include all the current deadlines and all proposed litigation deadline extensions, including the new proposed deadlines for filing dispositive motions and readiness for trial. All requests for discovery extensions shall also include a list of discovery conducted thus far, the requested deadline extension, and a schedule of outstanding discovery to be completed during the requested extension. Without this detail, requests for discovery extensions will not be considered.

Applies to

Discovery motion

Must include

certificate of conference

Discovery dispute motions must conform to Uniform Superior Court Rules 6.4(A) and (B), including a certificate of conference filed with the motion.

Any motion seeking resolution of a discovery dispute must conform to the requirements of Uniform Superior Court Rules 6.4(A) and (B). Specifically, all parties are reminded of the requirement that both parties confer with one another prior to raising a discovery dispute with the Court. These rules also require that "at the time of filing the motion, counsel shall also file a statement certifying that such conference has occurred and that the effort to resolve by agreement the issues raised failed." Ga. Unif. Super. Ct. R. 6.4(B).

Applies to

Ministerial motion

Must include

proposed order

Every ministerial motion must be accompanied by a proposed order.

Every ministerial motion (e.g., motion to extend, exceed page limits, withdrawal) must be accompanied by a proposed order.

Applies to

Proposed order

Proposed orders must be emailed to the Senior Staff Attorney in Microsoft Word format at the time of filing the corresponding motion or response and must not be filed with the clerk of court.

Proposed orders shall be emailed to the Court in Microsoft Word Format contemporaneously with the filing of either the corresponding motion or response. Parties are required to email all proposed orders to the Senior Staff Attorney, Erik Smith at erik.smith@fultoncountyga.gov. Proposed orders shall not be filed with the clerk of court. Once again, proposed orders shall not be filed with the clerk of court.

Applies to

Pretrial order

A fully consolidated pre-trial order must be emailed to the Judge's chambers by the scheduling order deadline; the plaintiff/petitioner consolidates it and all other parties must exchange their portions to the plaintiff/petitioner no later than 10 business days before the due date.

All parties shall submit, by email, a fully consolidated pre-trial order directly to the Judge's chambers by the deadline set forth in the Scheduling Order. See O.C.G.A. §9-11-16. Plaintiff/Petitioner shall be responsible for consolidating the pre-trial order. All other parties shall exchange their portions of the consolidated pre-trial order to the Plaintiff/Petitioner no later than ten (10) business days prior to the due date.

Applies to

Conflict letter

Conflict letters must follow Uniform Superior Court Rule 17.1 in proposing a resolution; submitting a conflict letter alone does not excuse attendance at trial.

All conflict letters must be submitted three (3) weeks before the trial calendar begins and must follow Uniform Superior Court Rule 17.1 in proposing a resolution. Please note that the submission of a conflict letter alone does not excuse counsel or self-represented litigants from the trial of the case.

Applies to

Dvd cd

DVDs/CDs must be provided to the court reporter as an original plus one copy, contained in a hard case.

Regarding DVDs/CDs and the like, provide the court reporter with the original and one copy. They must be contained in a hard case (such as a jewel case).

Applies to

Discovery motion

Form motions to compel are prohibited; motions to compel must itemize case-specific instances of non-compliance.

The parties are ordered not to file "form" motions seeking an order compelling the generalized disclosure of discoverable materials or the general exclusion of evidence. Any such non-specific "form" motions will not be considered by the Court. Should a party need to file a motion to compel discovery, the party shall itemize the articulable and case-specific instances in which the party believes the opposing party has failed to comply with discovery obligations.

Applies to

Expert witness notice

Parties relying on expert testimony must provide written notice including a summary of the testimony and the expert's qualifications.

seeking to rely on expert testimony at trial (or any evidentiary hearing) must provide written notice to the opposing party. This notice must include a meaningful summary of the expert's 3 ===== PAGE 4 ===== testimony as well as her qualifications to serve as an expert

Applies to

Motion

Motions must be particularized, identifying the specific item, statement, or evidence at issue with a theory of suppression and legal citations; generalized and omnibus motions will be denied.

Only those motions sufficiently particularized as to provide legal notice to the opposing parties will be considered by the Court. Generalized and omnibus motions are not to be filed and if filed will be denied as vague, dilatory, and in violation of this order. Motions must specify, with particularity, the item or statement or event at issue and must be tailored to the facts of the case at hand. Thus, a general motion seeking to suppress any and all statements or any and all evidence is insufficient and will be denied. The motion must identify the specific statement or evidence that the movant is seeking to suppress, as well as provide a theory of suppression, supported by citations to applicable persuasive legal authority.

Applies to

Pretrial submission

Pre-trial submissions must include a list of potential voir dire questions, a list of all potential witnesses, and all motions in limine.

the parties are required to file with the Clerk of Court, serve on opposing counsel by email and submit by email to the Litigation Manager Matthew Cormier at Matthew.cormier@fultoncountyga.gov, by. 4 p.m. one week before the first day of trial, the following FIVE ITEMS: a. A list of potential voir dire questions. See below: Voir Dire Procedure utilized by Judge Cox. b. A list of all potential witnesses. This witness list is for the Court's use during voir dire and need not list anything more than the witnesses' name and any applicable title or position. This list is separate from all pre-trial discovery requirements concerning witnesses, including the disclosure of all requisite identifying information and the content of expert opinions, if any. c. All motions in limine.

Applies to

Firearm evidence

Firearms or guns used at trial must have a locked external locking mechanism before entering the courtroom, and counsel must affirm in open court that the weapon has been checked to contain no ammunition.

All firearms or guns that are to be used during the trial must be fitted with an external locking mechanism that is locked before they arrive in the courtroom. Counsel shall also affirm in open court that the firearm or gun has been checked to ensure that no ammunition is in the gun or firearm.

Applies to

Pretrial order

Parties must submit a consolidated pre-trial order three weeks before trial calendar or by court deadline.

If any party files a jury demand or otherwise desires a jury trial, the parties must submit, directly to the Court, a consolidated pre-trial order three weeks before the trial calendar begins or on the deadline set by the Court.

Applies to

Pretrial order

Failure to submit a pre-trial order results in a bench trial election.

Failure to submit a pre-trial order will be deemed an election to proceed with a bench trial.

Applies to

Proposed order

Parties seeking an order to import equipment must provide a proposed order to Mr. Kerns at least two business days before trial.

Any party seeking such an order must provide a proposed order to Mr. Kerns at least two business days before trial.

Applies to

Deposition dispute list

Parties must jointly prepare a list of disputed deposition page and line numbers and provide it to the Court with their motions in limine.

If the parties cannot agree on what portions of the deposition testimony, if any, should be excluded, the parties must jointly prepare a list of the page and line numbers at issue and provide it to the Court at the time they file their motions in limine, along with the relevant text from the deposition(s).

Applies to

Exhibits

All exhibits and demonstrative evidence must be marked, digitized, and exchanged prior to trial.

All exhibits and demonstrative evidence must be marked, digitized (scanned)and exchanged prior to the start of trial.

Applies to

Exhibit list

Parties must provide an exhibit list to the Court and opposing parties prior to jury selection, including exhibit numbers and descriptions.

Any party that intends to introduce exhibits during trial must provide an exhibit list to the Court and one copy to each opposing party prior to jury selection. The exhibit list should include for each exhibit both the exhibit number and a brief description of what the exhibit purports to be.

Applies to

Witness list

Parties must provide a witness list to the Court and opposing parties prior to jury selection.

Any party that intends to call witnesses (or present deposition testimony) must provide a witness list to the Court and one copy to each opposing party prior to jury

Applies to

Ministerial motion

Must include

proposed order

Every ministerial motion must be accompanied by a proposed order submitted electronically to Mr. Kerns in Microsoft Word format.

Every ministerial motion (e.g., motion to file reply brief, to extend discovery, etc.) must be accompanied by a proposed order (with the proposed order submitted electronically to Mr. Kerns in Microsoft Word format).

Applies to

Rule 6 3 pleading

A party seeking oral argument on a summary judgment motion must comply with Uniform Superior Court Rule 6.3 and file a pleading to that effect.

A party seeking oral argument on a motion for summary judgment must comply with Uniform Superior Court Rule 6.3 and file a pleading to that effect.

Applies to

Proposed order

Proposed orders on summary judgment motions should include detailed findings of fact and conclusions of law for the Court to adapt as appropriate.

Proposed orders on motions for summary judgment should include detailed findings of facts and conclusions of law which the Court may adapt as appropriate.

Applies to

Jury charge request

Non-pattern charges may be requested only when no pattern charge applies to the specific issue.

Parties may request non-pattern charges only where there is no pattern charge applicable to the specific issue.

Applies to

Deposition dispute list

If parties cannot agree on which deposition testimony should be excluded, the objecting party must prepare a list of disputed page and line numbers along with the relevant deposition text.

If the parties cannot agree on what portions of the deposition testimony, if any, should be excluded, the objecting party must prepare a list of page and line numbers at issues and provide the list, along with the relevant text from the deposition to the Staff Attorney no later than two days before the beginning of the trial calendar.

Applies to

Motion in limine

A party filing a motion in limine expected to require a hearing longer than one hour must alert the Court so the prospective jurors' schedule can be managed.

If a party filing a motion in limine believes that the motion will require a hearing lasting more than an hour, the party must alert the Court so that the prospective jurors' schedule can be properly managed.

Applies to

Filing

All filings must include the email addresses of counsel or pro-se parties.

To aid the Court in also observing this practice, all filings by Parties are required to include the email addresses of counsel or Pro-se Parties on the matter.

Applies to

Discovery documents

Each party must submit a Financial Affidavit, Child Support Worksheet and Schedules, Answers to Interrogatories, and documents responding to Required Documents to be Produced by the 30-Day Status Conference.

each Party must submit by the 30-Day Status Conference his or her Financial Affidavit, Child Support Worksheet and Schedules, Answers to Interrogatories, and documents in response to Required Documents to be Produced

Applies to

Expert disclosures

Expert disclosures must include names, subject matters, substance of facts and opinions, and a summary of the grounds for each opinion for any expert expected to testify.

The disclosures shall include the names, subject matters, substance of facts and opinions, and a summary of the grounds for each opinion which any expert is expected to testify at trial on issues which the disclosing party bears the burden of proof.

Applies to

Discovery motion

Notices of Discovery Dispute and Motions to Compel Discovery must meet the requirements of U.S.C.R. Rule 6.4(A) and (B).

Any Notice of Discovery Dispute or Motion to Compel Discovery pursuant to FCSCFD Rules 4000-6.1.1 or 4000-6.1.2 and/or the Civil Practice Act must meet the requirements of U.S.C.R. Rule 6.4(A) and (B)

Applies to

Reply

Replies and sur-replies will not be considered unless the Court has given prior express permission.

No replies or sur-replies will be considered absent prior express permission of Court.

Applies to

Motion

Parties must file authenticated and admissible evidence contemporaneously with a motion to enforce a settlement agreement or the response to it.

The Parties are directed to file contemporaneously with such motion or the response thereto, authenticated and admissible evidence.

Applies to

Temporary hearing request

A Temporary Hearing request must state the specific issues to be determined, the time needed, and the dates of any other already scheduled hearings or status conferences.

The request must set out the specific issue(s) to be determined at the Temporary Hearing, time needed, as well as the date(s) of any other already scheduled hearing and/or status conference.

Applies to

Supporting documentation

All supporting documentation for the required pretrial documents must be available for review at trial.

All supporting documentation for the above shall be available for review at trial.

Applies to

Waiver of arraignment

A Waiver of Arraignment must be personally signed by the defendant and indicate entry of a Not Guilty plea and waiver of formal arraignment.

counsel may file a Waiver of Arraignment personally signed by the defendant indicating that the defendant is entering a plea of Not Guilty and waiving formal arraignment

Applies to

Notice of manual filing

When filing non-conforming materials manually, the filing party must e-file a Notice of Manual Filing for docketing.

The filing party shall E-File a "Notice of Manual Filing" which shall be docketed in the Case Management System to denote that a manual filing has been made and that the material is being held by the Clerk of Court.

Applies to

Notice of filing under seal

Filers must e-file a Notice of Filing under Seal when submitting sealed documents.

Also, filers submitting Documents to be filed under seal are required to E-File a "Notice of Filing under Seal".

Applies to

Proposed order

Proposed Orders may be E-Filed as exhibits or separate filings if they include the submitting party's signature block and are titled 'Proposed'.

Proposed Orders may be E-Filed as an exhibit to a motion or other pleadings or as a separate filing provided that (1) the Proposed Order includes the signature block of the submitting party or attorney in compliance with U.S.C.R. 36.4 and (2) the title of the filing is clearly marked "Proposed".

Applies to

E document

Each E-Document's electronic title must include the filing party, the nature of the document, and the relief sought.

The electronic title of each E-Document shall, to the extent practicable, include: i. the party or parties filing the E-Document, ii. the nature of the E-Document, and iii. the nature of the relief sought.

Applies to

Exhibit list

Exhibit lists must include the exhibit number and a brief description for each exhibit.

The exhibit list should include for each exhibit both the exhibit number and a brief description of what the exhibit purports to be.

Applies to

Exhibits

Parties must provide their exhibits in digital form.

Additionally, the parties are now required to provide their exhibits in digital form as later detailed.

Applies to

Proposed order

Proposed orders on summary judgment motions must include detailed findings of fact and conclusions of law.

All proposed orders on motions for summary judgement should include detailed findings of fact and conclusions of law.

Applies to

Leave of absence application

Leaves of Absence must comply with U.S.C.R. 16.1, 16.2, and 16.4; non-compliance results in denial.

All Leaves of Absence must be filed in conformance with the provisions of U.S.C.R. 16.1, 16.2, and 16.4. Any Leave of Absence not in compliance with these rules, or any part thereof, are DENIED.

Applies to

Motion

Must include

proposed order

Motions for an extension must include a proposed order for the Court's consideration.

Such motions must provide a detailed, fact-based explanation of the need for the extension including the amount of time needed to provide outstanding discovery, along with a proposed order for the Court's consideration.

Applies to

Motion to compel

Parties may not file non-specific 'form' motions to compel; any motion to compel must itemize articulable, case-specific instances of non-compliance.

obligations. The parties are ordered not to file "form" motions seeking an order compelling the generalized disclosure of discoverable materials or the general exclusion of evidence. Any such non- specific "form" motions will not be considered by the Court. Should a party need to file a motion to compel discovery, the party shall itemize the articulable and case-specific instances in which the party believes the opposing party has failed to comply with

Applies to

Motion in limine

Each motion in limine must be a separate document attached to the email and limited to discrete evidentiary or procedural matters.

All motions in Jimine. Each such motion shall be a separate document and attachment to the email to opposing counsel and to Ms. Marum. Such motions should be limited to discrete evidentiary or procedural matters, such as the admissibility of a specific piece of evidence.

Applies to

Exhibit

Exhibits should be marked and digitized (scanned) before trial.

Exhibits should be marked and digitized (scanned) before trial.

Applies to

Stipulation

Stipulations must be in writing, signed by the parties, and presented to the Court outside the jury's presence; oral stipulations before the jury require prior Court permission.

All stipulations must be made in writing, signed by the parties and presented to the Court outside the presence of the jury. No counsel should offer to enter into a stipulation orally before the jury, unless prior permission is granted by the Court.

Applies to

Leave of absence

A Leave of Absence must be filed pursuant to USCR 16.1 or 16.2, after entry of appearance of counsel, and be served upon chambers, or it stands denied under USCR 16.4.

Note that any Leave of Absence not filed pursuant to USCR 16.1 or 16.2 or filed prior to entry of appearance of counsel in the case at issue and not served upon chambers, stands denied under USCR 16.4.

Applies to

Conflict letter

A conflict letter must comply with all subsections of USCR 17.1 for the attorney to be deemed to have a conflict under USCR 17.1(A).

Unless USCR 17.1 is followed in all its subsections, then the attorney shall not be deemed to have a conflict pursuant to USCR 17.1(A).

Applies to

Discovery response

Discovery objections must be stated with specificity; general or boilerplate objections may be disregarded unless accompanied by a specific explanation.

Objections to discovery requests must be stated with specificity. General or boilerplate objections are disfavored and may be disregarded by the Court unless accompanied by a specific explanation.

Applies to

Pretrial order

Parties may not submit individual portions of the pre-trial order without written certification of good-faith efforts to consolidate.

No party may submit their own individual portions of the pre-trial order to the Court without written certification detailing their good-faith efforts to present the Court with a fully consolidated order.

Applies to

Motion in limine

If parties cannot agree on deposition testimony exclusions, they must jointly prepare a list of page/line numbers and provide it with their motions in limine.

If the parties intend to rely on deposition testimony, they shall confer prior to trial and attempt to agree on the testimony to be presented. If they cannot agree on what portions of the deposition testimony should be excluded, they are instructed to jointly prepare a list of the page and line numbers at issue and provide it to the Court at the time they file their motions in limine, along with the relevant text from the deposition.

Applies to

Jury instructions

Each party must list requested pattern charges by title and pattern number using the current pattern charges published by the Council of Superior Court Judges.

Each party shall list by title and pattern number the applicable pattern charges that they request be given, using the current pattern charges published by the Council of Superior Court Judges, (the pattern charges are updated January and July of each year).

Applies to

Jury instructions

Parties requesting non-pattern charges must provide the citation to applicable authority and a physical copy of the published case.

In requesting non-pattern charges, parties shall provide the cite to applicable statutory or case authority and shall provide a physical copy of the published case.

Applies to

Exhibits

All exhibits and demonstrative evidence must be marked with exhibit labels and exchanged among the parties before trial.

All exhibits and demonstrative evidence shall be marked with exhibit labels and exchanged among the parties prior to the beginning of the trial of the case.

Applies to

Exhibits

Parties must provide all documentary evidence to the court reporter in digital format at the time of tender, unless otherwise ordered.

Parties shall mark with exhibit labels and provide all documentary evidence to the court reporter in digital format at the time of tender, unless otherwise ordered by the court.

Applies to

Exhibits

For DVD/CD exhibits, parties must provide the court reporter with the original and one copy contained in a hard case.

Regarding DVD/CD exhibits, parties shall provide the court reporter with the original and one copy of the DVD/CD. They will need to be contained in a hard case (e.g., jewel case).

Applies to

Motion to compel discovery

Parties may not file non-specific 'form' motions to compel discovery or to exclude evidence, and such motions will not be considered.

The parties are ordered not to file “form” motions seeking an order compelling the generalized disclosure of discoverable materials or the general exclusion of evidence. Any such non-specific “form” motions will not be considered by the Court.

Applies to

Witness list

The witness list need only include each witness's name and title or position, and is separate from discovery requirements.

A list of all potential witnesses. This witness list is for the Court?s use during voir dire and need not list anything more than the witnesses’ name and any applicable title or position. This list is separate from all pre-trial discovery requirements concerning witnesses, including the disclosure of all requisite identifying information and the content of expert opinions, if any.

Applies to

Proposed jury charges

For pattern jury charges, only the charge number is submitted; for non-pattern or modified charges, full text and supporting authority must be submitted.

Proposed Jury Charges. The parties’ must submit all proposed requests to charge which, for the State, includes charges of the particular offense(s) alleged in the indictment. For pattern charges, each party is to submit ONLY the pattern charge NUMBER and not the text of the charge itself. For all non-pattern or modified pattern charges, the parties are required to submit the full text and cite the case law, statute or other authority supporting such requested charge.

Applies to

Leave of absence

A Leave of Absence that is not filed and served pursuant to U.S.C.R. 16.1 or 16.2, is filed before counsel's entry of appearance, or is not served upon chambers stands denied.

Note that any Leave of Absence not filed or served pursuant to U.S.C.R. 16.1 or 16.2 or filed prior t0 entry 0fappearance 0f counsel in the case at issue and not served upon chambers, stands denied under U.S.C.R. 16.4. Note

Applies to

Conflict letter

An attorney is not deemed to have a conflict under U.S.C.R. 17.1 unless U.S.C.R. 17.1 is followed in all its subsections.

Note that unless U.S.C.R. 17.1 is followed in all its subsections, then the attorney shall not be deemed to have a conflict pursuant to U.S.C.R. 17.1(A).

Applies to

Court submission

Parties must include their email address on all Court submissions.

Please include your email address on all Court submissions.

Applies to

Motion in limine

Parties relying on deposition testimony must confer and, if they cannot agree, jointly prepare a list of disputed page and line numbers to provide with their motions in limine.

at Trial If the parties intend to rely on deposition testimony, they shall confer prior to trial and attempt to agree on the testimony to be presented. If they cannot agree on what portions of the deposition testimony should be excluded, they are instructed to jointly prepare alist of page and line numbers at issue and provide it to the Court at the time they file their motions in limine, along with the relevant text from the

Applies to

Jury charges

Each party must list requested pattern jury charges by title and pattern number using the current published pattern charges.

Each party shall list by title and pattern number the applicable pattern charges that they request be given, using the current pattern charges published by the Council of Superior Court Judges.

Applies to

Jury charges

Requests for non-pattern jury charges must include a citation to applicable statutory or case authority and a physical copy of the published case.

In requesting non-pattern charges, parties shall provide the cite to applicable statutory or case authority and shall provide a physical copy of the published case.

Applies to

Exhibits

All exhibits and demonstrative evidence must be marked with exhibit labels and exchanged among the parties before trial begins.

All exhibits and demonstrative evidence shall be marked with exhibit labels and exchanged among the parties prior to the beginning of the trial of the case.

Applies to

Exhibits

Parties must mark exhibits with labels and provide all documentary evidence to the court reporter in digital format at tender, unless the court orders otherwise.

Parties shall mark with exhibit labels and provide all documentary evidence to the court reporter in digital format at the time of tender, unless otherwise ordered by the court.

Applies to

Exhibits

DVD/CD exhibits must be provided to the court reporter as the original plus one copy, contained in a hard case.

Regarding DVD/CD exhibits, parties shall provide the court reporter with the original and one copy of the DVD/CD. They will need to be contained in a hard case (e.g., jewel case).

Applies to

Motion for service by publication

To seek service by publication, plaintiff must file proof of attempted service, a Motion for Service by Publication, and an Affidavit of Diligent Search.

To seek an order for service by publication, Petitioner/Plaintiff must file proof of attempted service on Respondent/Defendant at Respondent's/Defendant's last known address, together with a Motion for Service by Publication and an Affidavit of Diligent Search.

Applies to

Proposed revised scheduling order

Must include

proposed order

A party requesting a CSSO modification must submit a proposed revised scheduling order with all extensions and deadlines plus a statement of prior extension requests.

In the event a modification to the CSSO is requested, the moving party shall submit a proposed revised scheduling order setting forth all requested extensions and deadlines, together with a statement identifying whether the Court has previously granted any requests for extensions.

Applies to

Proposed order

Proposed orders on summary judgment motions should include detailed findings of fact and conclusions of law.

Proposed orders on motions for summary judgment should include detailed findings of facts and conclusions of law which the Court may adapt as appropriate.

Applies to

Discovery motion

Discovery deficiency motions must itemize the case-specific instances of noncompliance, and motions compelling generalized disclosure are prohibited.

Should a party need to file a discovery deficiency motion, the party shall itemize the articulable and case-specific instances in which the party believes the opposing party has failed to comply with discovery obligations. The Parties are directed not to file motions compelling the generalized disclosure of otherwise discoverable materials.

Applies to

Bond motion

All bond motions must be filed with the Clerk of the Superior Court.

All bond motions must be filed with the Clerk of the Superior Court.

Applies to

Proposed order

Must include

proposed order

Proposed orders are submitted by email to the Litigation Manager and opposing counsel simultaneously.

Proposed orders shall be submitted by email to the Litigation Manager and opposing counsel simultaneously

Applies to

Jury instructions

When a pattern jury charge is requested, parties must list only the title and pattern number, without reciting the charge text.

version of the pattern charge is being requested, do not recite the text of the pattern charge, just list the title and pattern number.

Applies to

Court submission

All Court submissions must include the filer's email address.

Include your email address on all Court submissions.

Applies to

Expert disclosure

Expert disclosures must include expert names, subject matters, substance of facts and opinions, and a summary of the grounds for each opinion.

Expert disclosures shall include the names, subject matters, substance of facts and opinions, and a summary of the grounds for each opinion which any expert is

Applies to

Jury charges

For pattern jury charges, parties must list the title and pattern number of each requested charge using the current Council of Superior Court Judges pattern charges.

In this WORD document — for pattern charges — the parties shall list on a page(s) the title and pattern number of the requested pattern charges, using the current pattern charges published by the Council of Superior Court Judges (the pattern charges are updated January and July of each year).

Applies to

Jury instructions

For non-pattern jury charges, parties must recite the charge text with supporting authority and may request them only when no pattern charge applies.

for non-pattern charges - the parties must recite the text of the charge requested and reference the applicable, supporting statutory or case authority. The parties may request non-pattern charges only if there is no pattern charge that covers the issue.

Applies to

Exhibits

Exhibits and demonstrative evidence must be marked with labels and exchanged among the parties, with an exhibit list, before trial begins.

All exhibits and demonstrative evidence shall be marked with exhibit labels and exchanged among the parties, along with an exhibit list, prior to the beginning of the trial.

Applies to

Technology request form

Parties using Court technology to display evidence must contact Court Technology Services and fill out a request form at least one week before trial.

Parties seeking to utilize Court technology to display recordings or other evidence must prepare for trial by contacting Court Technology Services (www. fultoncourt.org/court-technology) to fill out a request form at least one (1) week before

Applies to

Order

Must include

proposed order

A party seeking to bring its own evidence viewing equipment must provide a proposed order to the Staff Attorney at least one day before trial.

Any party seeking such an order must provide a proposed order to the Staff Attorney at least one (1) day prior to trial.

Applies to

Motion in limine

Motions in limine must be limited to discrete evidentiary or procedural matters (such as admissibility of a specific piece of evidence) and may not be used to raise issues that should have been resolved during the pretrial motions phase.

Such motions should be limited to discrete evidentiary or procedural matters, such as the admissibility of a specific piece of evidence. As mentioned above, it is not proper to attempt to raise, as a purported motion in limine, matters which should have been raised and resolved during the pretrial motions phase of the 'journey to trial.'

Applies to

Exhibit list

The exhibit list must identify each exhibit with both its exhibit number and a brief description of what it purports to be.

The exhibit list should include for each exhibit both the exhibit number and a brief description of what the exhibit purports to be.

Applies to

Request for production order

Counsel must submit written requests for court orders producing incarcerated defendants or witnesses, with inmate identifying information matching Georgia Department of Corrections records.

Atthe request of counsel. the Court will order production of a Defendant and 'or witness incarcerated in any Georgia prison. jail system or facility. For individuals located within the Georgia Department of Corrections system. the requested inmate's identifying information should coincide with the Georgia Depail ment of Corrections' identifying information for that inmate. Counsel parties must submit his'her'their request in writing

Applies to

Motion

Must include

proposed order

Every ministerial motion must be accompanied by a proposed order submitted electronically as a Microsoft Word document.

Every ministerial motion (e.g. motion for leave to file a reply brief, for leave to extend discovery, etc.) must be accompanied by a proposed order (with the proposed order submitted electronically as a Microsoft Word document).

Applies to

Motion

Must include

proposed order

A party seeking oral argument on a motion for summary judgment must file a pleading complying with USCR 6.3 and email it with a proposed rule nisi in Microsoft Word format.

A party seeking oral argument on a motion for summary judgment must comply with Uniform Superior Court Rule 6.3 and file a pleading to that effect. That Rule 6.3 pleading must also be emailed to Ms. Sarah Thomas along with a proposed rule nisi in Microsoft Word format.

Applies to

Motion

Must include

proposed order

Parties must submit proposed orders for review whenever a motion is ripe for adjudication.

When a dispositive motion (or any motion) is ripe for adjudication, the parties shall submit proposed orders for review.

Applies to

Proposed order

Proposed orders for summary judgment motions must include detailed findings of fact and conclusions of law.

Proposed orders on motions for summary judgment shall include detailed findings of fact and conclusions of law which the Court may adapt as appropriate

Applies to

Victim impact statement

Victim impact statements must be in writing, on point, and directed to the Court.

All victim impact statements must be in writing, on point and directed to the Court and not others.

Applies to

Expert notice

Expert notice must include a meaningful summary of the expert's testimony and qualifications.

The notice must include a meaningful summary of the expert's testimony, as well as, his/her/their qualifications to serve as an expert witness.

Applies to

Standard procedural motion

Must include

proposed order

Proposed Orders must be emailed to Litigation Manager Angela Sims for standard procedural motions.

Counsel shall ensure he/she/they email, to Litigation Manager Angela Sims, a proposed Order in connection with any "standard" procedural motions (such as, Motions to Withdraw as Counsel, Motions for Continuance, Motions for Extending Deadline Imposed by the Court and similar such motions).

Applies to

Motion to compel

Motions to compel discovery must itemize specific instances of noncompliance.

Should a party need to file a motion to compel discovery, the party shall itemize the articulable and case-specific instances in which the party believes the opposing party has failed to comply with discovery obligations.

Applies to

Proposed order

Must include

proposed order

A proposed order in WORD format must be emailed to Litigation Manager Angela Sims.

a proposed order in WORD format shall be emailed to Litigation Manager Angela Sims (Angela.Sims@fultoncountyga.gov)

Applies to

Motion in limine

Motions in limine should be limited to discrete evidentiary or procedural matters, such as admissibility of a specific piece of evidence.

Such motions should be limited to discrete evidentiary or procedural matters, such as the admissibility of a specific piece of evidence.

Applies to

Pattern jury charges

Pattern jury charges must be listed on a single cover page.

PATTERN jury charges shall be listed on a single cover page.

Applies to

Pattern jury charges

Each pattern charge must be numbered and identified by title and paragraph, without reproducing the text of the charge.

Each PATTERN charge shall be numbered and identified by title and paragraph. The substance/content of any such PATTERN charge shall not be put forth.

Applies to

Non pattern jury charges

The State must include the applicable code section portion for each offense in its submitted charges, and these do not count toward the State's non-pattern charge limit.

Counsel for the State shall also include, within its submitted charges, the applicable portion of the code section for each offense alleged in the indictment; these jury charges will not count against the number of NON-PATTERN charges allowed the State.

Applies to

Non pattern jury charges

For all non-pattern charges, the full text must be submitted and, below the text, the requesting party must cite the supporting case law, statute, or other authority.

For all NON-PATTERN charges, the parties are required to submit the full text of each such requested NON-PATTERN charge and, below such text, the requesting party shall reference the case law, statute or other authority supporting such requested NON-PATTERN charge.

Applies to

Voir dire questions

Counsel must submit all proposed general voir dire questions to the Court as directed.

Counsel shall submit to the Court all proposed general voir dire questions as directed above.

Applies to

Leniency request

Requests for leniency must be in writing, on point, and directed to the Court.

Any requests for leniency must be in writing, on point and directed to the Court and not others.

Applies to

Court production order request

Requests for court production orders must be submitted in writing, with inmate identifying information matching GDC records.

For individuals located within the Georgia Department of Corrections system, the requested inmate's identifying information should coincide with the Georgia Department of Corrections' identifying information for that inmate. Counsel parties must submit his/her their request in writing

Applies to

Pretrial order

Plaintiff/Petitioner consolidates the pre-trial order; other parties must provide their portions no later than two business days before the due date, and failure to submit is deemed an election for a non-jury trial.

Unless the parties otherwise agree, Plaintiff/Petitioner shall be responsible for consolidating the pre-trial order. All other parties shall provide their portions of the consolidated pre-trial order to the Plaintiff/Petitioner no later than two business days prior to the due date. Failure to submit a pre-trial order will be deemed an election to proceed with a non-jury trial.

Applies to

Courtroom equipment import order

Must include

proposed order

Parties may import their own courtroom equipment with a U.S.C.R. 22 order, but a proposed order must be provided to Ms. Thomas at least one day before trial.

Parties are also free to import their own equipment, although this will require the issuance of an order pursuant to U.S.C.R. 22. Any party seeking such an order must provide a proposed order to Ms. Thomas at least one day before trial.

Applies to

Proposed order

Must include

case number

Proposed orders must not have the Court's signature alone on a separate page; if a page break is unavoidable, the signature page must identify the parties, case number, and document.

Do not submit a proposed order where the Court's signature appears alone on a separate page. See U.Sup.C.R 36.4. Where the page break cannot be avoided, the signature page must identify the parties, the case number, and the document.

Applies to

Motion

Motions for withdrawal of counsel must include a viable email address for the client so the Court can contact the client if the motion is granted.

Any motion by counsel seeking to withdraw from representation of a client must include a viable email address for that client by which the Court can contact the client should the motion for withdrawal be granted.

Applies to

Conflict letter

Conflict letters must comply fully with Rule 17.1 of the Uniform Superior Court Rules.

Conflict letters must be submitted one week before the trial calendar begins and shall comply fully with Rule 17.1 of the Uniform Superior Court Rules.

Applies to

Jury instructions

Each party must provide a list of proposed pattern charges by title and number, using current pattern charges; text need not be recited.

Each party shall provide a list identifying the title and number of each proposed pattern charge requested by the party, using the current pattern charges published by the Council of Superior Court Judges, (the pattern charges are updated January and July of each year). The parties need not recite the text of pattern charges.

Applies to

Jury instructions

Non-pattern charges are allowed only when no pattern charge applies, and must include citation to authority.

Parties may request non-pattern charges only where there is no pattern charge applicable to the specific issue. Parties requesting non-pattern charges shall provide citation to applicable statutory or case authority.

Applies to

Exhibits

All exhibits must be pre-marked and numbered for trial.

All exhibits must be pre-marked and numbered for introduction at trial.

Applies to

Motion in limine

Motions in limine should be limited to discrete evidentiary or procedural matters.

Such motions should be limited to discrete evidentiary or procedural matters, such as the admissibility of a specific piece of evidence.

Applies to

Jury charges pattern

Pattern jury charges must be submitted by charge number, not full text.

For pattern charges, each party is to submit the pattern charge number and not the text of the charge itself.

Applies to

Voir dire questions

Parties must submit a list of potential voir dire questions.

Voir Dire Questions. A list of potential voir dire questions.

Applies to

Witness list

Parties must submit a potential witness list for the Court's use in voir dire, including each witness's name and title/position if relevant.

Potential Witness List. This witness list is for the Court's use in voir dire. It should include the name of each potential witness and title/position if relevant.

Applies to

Jury instructions

For pattern jury charges, submit only the charge number; for all non-pattern charges, submit the requested charge with supporting case law.

Proposed Jurv Charge_s: For pattern charges, a. party should submit only the pattern charge number and not the text of the charge itself. For all non-pattern charges, a party must submit the requested charge together with case law in support of the charge.

Applies to

Proposed verdict form

Parties must submit a proposed verdict form.

Proposed Verdict Form.

Applies to

Notice of appearance

No limited entries of appearance: entering counsel serves as full-time, full-service lawyer until permitted to withdraw.

There are no "limited" entries of appearance. If you enter the case as counsel for a party, you are that litigant's full-time, full-service lawyer until you are permitted to withdraw.

Applies to

Affidavit of diligent search

The affidavit of diligent search must include proof of attempted service at Respondent's last known address.

To obtain an order for service by publication, Petitioner must e-file a motion for service by publication and an affidavit of diligent search (which includes proof of attempted service at Respondent's last known address) within sixty days of filing the case.

Applies to

Motion

Evidence for motions to enforce settlement agreements must be submitted with the motion, and affidavits authenticating documents are required for the Court to consider them as evidence.

Evidence the Court will need to rule on such motions such as signed settlement agreements, e-mails between counsel, -- etc. -- should be submitted along with the motions (or responses). Note that such evidentiary submissions require affidavits authenticating the documents for the Court to consider them as evidence.

Applies to

Child support worksheets

Parties must submit proposed child support worksheets, child support addenda, and parenting plans at the 30-Day Status Conference.

Parties are required to submit proposed child support worksheets, child support addenda, and parenting plans at the 30-Day Status Conference.

Applies to

Motion

Requests for temporary hearings must specify the issues to be determined, the time needed, and dates of other scheduled hearings or status conferences.

Requests for temporary hearings must set out the specific issue(s) to be determined at the hearing, the time needed, as well as the date(s) of any other already scheduled hearings and/or status conferences.

Applies to

Expert disclosure

Counsel must provide expert notices and summaries as part of discovery.

Don't forget to provide expert notices and summaries. Your expert will be very quiet if you don't.

Applies to

Proposed order

Must include

proposed order

After the ten-day cure period expires, the filing party may send the Court a proposed order excluding the missing discovery.

If the served party does not cure the alleged deficiency within ten days (or otherwise adequately explain the delay), the filing party may, after the expiry of the ten days, send the Court a proposed order excluding the missing discovery.

Applies to

Expert notice

The expert notice must include a meaningful summary of expected testimony and the expert's qualifications, attach any prepared report if not already provided, and state if no report was prepared.

This notice shall include a meaningful summary of the expert's expected testimony as well as her qualifications to serve as an expert witness. If the expert has prepared a report, that report should be attached to the notice if it has not already been provided in discovery. If the expert has not prepared a report, that fact should be included in the notice.

Applies to

Amicus curiae brief

Must include

proposed order

Amicus briefs require attorney admission and a motion for leave attaching the proposed brief as Exhibit 1, stating the movant's interest, and including a proposed order; unapproved non-party filings will not be docketed.

An amicus curiae brief may be filed only by an attorney admitted to practice before this Court. Consent of the parties is not required. A motion for leave to file an amicus curiae brief may be presented to the Court by email to the Litigation Manager. The motion shall attach the proposed brief as Exhibit 1, shall state the identity and nature of the movant's interest, and shall include a proposed order granting the motion. Any unapproved filings submitted by a non-party shall not be docketed by the Clerk of Court and/or stricken from the record by this Court.

Applies to

Leave of absence

Attorneys must file a Leave of Absence in accordance with U.S.C.R. 16.1/16.2 to be excused from appearance.

a proper Leave of Absence in accordance with U.S.C.R. 16.1 or 16.2, is timely filed and served upon chambers

Applies to

Conflict letter

A proper conflict letter in accordance with U.S.C.R. 17.1 is timely filed and served upon chambers.

a proper conflict letter in accordance with U.S.C.R. 17.1, is timely filed and served upon chambers

Applies to

Discovery response

Boilerplate objections in discovery responses are prohibited.

Boilerplate objections in response to discovery requests are prohibited.

Applies to

Discovery response

General objections and preamble sections are prohibited; each discovery request must be met with specific, applicable objections.

General objections are also prohibited, i.e., a party shall not include in its response to a discovery request a “Preamble” or “General Objections” section stating that the party objects to the discovery request “to the extent that” it violates some rule pertaining to discovery, e.g., attorney-client privilege, work product immunity, the prohibition against discovery requests that are vague, ambiguous, overly broad, or unduly burdensome, etc. Instead, each individual discovery request must be met with specific objections — but only those objections that actually apply to that particular request.

Applies to

Discovery response

Must include

completeness statement

A party that objects and responds must indicate whether the response is complete and whether additional information would have been provided but for the objections.

Finally, a party which objects to a discovery request but then responds to the request must indicate whether the response is complete, i.e., whether additional information or documents would have been provided but for the objection(s).

Applies to

Deposition

Deposing counsel must instruct the witness to ask deposing counsel for clarifications, and the witness must comply.

At the beginning of a deposition, deposing counsel shall instruct the witness to ask deposing counsel, rather than the witness' own counsel, for clarifications, definitions, or explanations of any words, questions, or documents presented during the deposition. The witness shall abide by these instructions.

Applies to

Deposition

Most objections are preserved and need not be made during depositions; defending counsel should limit objections to form and avoid speaking objections.

All objections except those that would be waived if not made at the deposition under O.C.G.A. § 9-11-32(d)(3)(B) and those necessary to assert a privilege or to present a motion pursuant to O.C.G.A. § 9-11-30(d) shall be preserved. Therefore, those objections need not be made during depositions. If counsel defending a deposition feels compelled to make objections during depositions, counsel should limit the objections to only "objection to form." Defending counsel should only elaborate on their objection upon the request of deposing counsel. Defending counsel should avoid speaking objections except in extraordinary circumstances.

Applies to

Deposition

Counsel may not instruct a witness not to answer unless the objection is based on privilege or a court-imposed limitation; questions should be answered over objections.

Counsel shall not instruct a witness not to answer a question unless that counsel has objected to the question on the ground that the answer is protected by a privilege or a limitation on evidence directed by the Court. Therefore, objections lodged during depositions should be noted but questions should be answered over those objections.

Applies to

Amicus leave motion

Must include

proposed order

The motion for leave to file an amicus brief must attach the proposed brief as Exhibit 1, state the identity and nature of the movant's interest, and include a proposed order granting the motion.

The motion shall attach the proposed brief as Exhibit 1, shall state the identity and nature of the movant's interest, and shall include a proposed order granting the motion.

Applies to

Proposed order

Proposed orders on summary judgment should include detailed findings of facts and conclusions of law, though submission of proposed orders is optional.

When a dispositive motion is ripe for adjudication, the parties are invited to submit proposed orders for review. Proposed orders on motions for summary judgment should include detailed findings of facts and conclusions of law which the Court may adapt as appropriate.

Applies to

Voir dire questions

Parties must submit a list of potential voir dire questions.

A list of potential voir dire questions.

Applies to

Witness list

Parties must submit a list of all potential witnesses, listing only names and titles/positions; the list is separate from pre-trial discovery requirements.

A list of all potential witnesses. This witness list is for the Court's use during voir dire and need not list anything more than the witnesses' name and any applicable title or position. This list is separate from all pre-trial discovery requirements concerning witnesses, including the disclosure of all requisite identifying information and the content of expert opinions, if any.

Applies to

Jury instructions

Parties must submit all proposed jury charges; pattern charges require only the charge number, while non-pattern charges require full text and supporting authority.

The parties must submit all proposed requests to charge, including the charges of the particular offense(s) alleged in the indictment. For pattern charges, each party is to submit only the pattern charge number and not the text of the charge itself. For non-pattern or modified pattern charges, the parties are required to submit the full text and cite the case law, statute, or other authority supporting such requested charge.

Applies to

Verdict form

Parties must submit a proposed verdict form.

A proposed verdict form.

Applies to

Exhibit list

Exhibit lists should include the exhibit number and a brief description for each exhibit.

The exhibit list should include for each exhibit both the exhibit number and a brief description of what the exhibit purports to be.

Applies to

Notice

Expert notice must include a meaningful summary of the expert's testimony and the expert's qualifications.

This notice must include a meaningful summary of the expert's testimony as well as his or her qualifications to serve as an expert witness.

Applies to

Brief

No party may file additional briefing beyond the motion and response without leave of court, which may be requested by email.

No party may file additional briefing other than the motion and response without leave of court, which may be requested by email explaining why additional briefing is necessary.

Applies to

Amicus brief

An amicus curiae brief may be filed only by an attorney admitted to practice before this Court.

An amicus curiae brief may be filed only by an attorney admitted to practice before this Court.

Applies to

Amicus brief

Must include

proposed order

A motion for leave to file an amicus brief must attach the proposed brief as Exhibit 1, state the movant's interest, and include a proposed order.

The motion shall attach the proposed brief as Exhibit 1, shall state the identity and nature of the movant's interest, and shall include a proposed order granting the motion.

Applies to

Amicus brief

Unapproved non-party filings will not be docketed and may be stricken from the record.

Any unapproved filings submitted by a non-party shall not be docketed by the Clerk of Court and/or stricken from the record by this Court.

Applies to

Exhibit list

Parties introducing exhibits must provide an exhibit list (two hard copies to the Court and one to each opposing party) prior to jury selection, listing each exhibit's number and a brief description.

Any party that intends to introduce exhibits during trial shall provide two hard copies of an exhibit list to the Court (one to the judge and one to the court reporter) and one copy to each opposing party prior to jury selection. The exhibit list should include for each exhibit both the exhibit number and a brief description of what the exhibit purports to be.

Applies to

Pretrial order

The pre-trial order must be presented in the form prescribed by Uniform Superior Court Rule 7.2.

The pre-trial order shall be presented in the form prescribed by Uniform Superior Court Rule 7.2.

Applies to

Conflict letter

Conflict letters must comply fully with Uniform Superior Court Rule 17.1.

Conflict letters must be submitted one week before the trial calendar begins and shall comply fully with Uniform Superior Court Rule 17.1.

Applies to

Jury charge request

Each party must provide a list of proposed pattern charges by title and number using the current published pattern charges.

Each party shall provide a list identifying the title and number of each proposed pattern charge requested by the party, using the current pattern charges published by the Council of Superior Court Judges.

Applies to

Non pattern charge request

Parties requesting non-pattern charges must provide citation to applicable statutory or case authority.

4 ===== requesting non-pattern charges shall provide citation to applicable statutory or case authority.

Applies to

Discovery response

Boilerplate objections in discovery responses are prohibited.

Boilerplate objections in response to discovery requests are prohibited.

Applies to

Discovery response

General objections (Preamble/General Objections sections) are prohibited; each discovery request must be met only with specific objections that actually apply.

General objections are also prohibited, i.e., a party shall not include in its response to a discovery request a "Preamble" or "General Objections" section stating that the party objects to the discovery request "to the extent that" it violates some rule pertaining to discovery, e.g., attorney-client privilege; work product immunity; the prohibition against discovery requests that are vague, ambiguous, overly broad, or unduly burdensome; etc. Instead, each individual discovery request must be met with specific objections thereto -- but only those objections that actually apply to that particular request.

Applies to

Deposition excerpt list

Parties relying on deposition testimony must confer before trial, and if they cannot agree on exclusions, must jointly provide the Court a list of the page and line numbers at issue with the motion in limine.

intends to rely on deposition testimony, that party must confer with all other parties prior to trial and attempt to agree on the testimony to be presented. If the parties cannot agree on what portions of the deposition testimony, Page 3 of 7 ===== PAGE 4 ===== if any, should be excluded, the parties must jointly prepare a list of the page and line numbers at issue and provide it to the Court at the time they file their motions in limine, along with the relevant text

Applies to

Exhibits

Any exhibit admissibility disagreement should be brought to the Court's attention before trial begins.

Any disagreement about the admissibility of exhibits should be brought to the Court's attention before trial begins.

Applies to

Jury charges

Pattern jury charges may be listed by number and title (the Court supplies the language), while non-pattern or modified charges should be submitted in full text with citations to authority.

If a party is seeking any pattern charges, the party need only list the pattern charge numbers and titles; the Court will supply the relevant pattern language. Non-pattern requests or modified pattern requests should be submitted in full text along with citations to authority.

Applies to

Jury instructions

For proposed jury charges, parties must submit only the pattern charge NUMBER for pattern charges, and the full text with supporting authority for non-pattern or modified pattern charges.

The parties must submit all proposed requests to charge which, for the State, includes charges of the particular offense(s) alleged in the indictment. For pattern charges, each party is to submit ONLY the pattern charge NUMBER and not the text of the charge itself. For all non-pattern or modified pattern charges, the parties are required to submit the full text and cite the case law, statutory or other authority supporting such requested charge.

Applies to

Stipulation

All stipulations must be made in writing, signed by the parties and presented to the Court outside the presence of the jury. No counsel should offer to enter into a stipulation orally before the jury unless prior permission is granted by the Court.

All stipulations must be made in writing, signed by the parties and presented to the Court outside the presence of the jury. No counsel should offer to enter into a stipulation orally before the jury unless prior permission is granted by the Court.

Applies to

Order

Counsel must prepare orders or judgments and mail or email them to the Court and opposing counsel simultaneously within three business days of entry, unless directed otherwise.

Counsel shall promptly prepare orders or judgments to be presented to the Court and mail or email (fantashia.francis@fultoncountyga.gov) the same to the Court and opposing counsel simultaneously and within three business days of the entry of that order of judgment by the Court unless directed otherwise by the Court.

Applies to

Reply brief

Replies and sur-replies will not be considered without prior Court approval.

Neither replies nor sur-replies will be considered without prior approval from the Court.

Applies to

Pretrial order

A party may submit only its own individual pre-trial order portions only with a written certification detailing good-faith efforts toward a fully consolidated order.

No party may submit their own individual portions of the pre-trial order to the Court without written certification detailing their good-faith efforts to present the Court with a fully consolidated order.

Applies to

Motion in limine

Motions in limine must be made in writing.

Motions in Limine shall be made in writing

Applies to

Deposition dispute list

If attorneys cannot agree on excluded deposition testimony, they must jointly provide the Court with a list of disputed page and line numbers and relevant text when filing motions in limine.

If the attorneys cannot agree on what portions of the deposition testimony should be excluded, the attorneys are instructed to jointly prepare a list of the page and line numbers at issue and provide it to the Court at the time they file their motions in limine, along with the relevant text from the deposition.

Applies to

Jury charges

Attorneys must list requested pattern jury charges by title and pattern number using the current Council of Superior Court Judges pattern charges, without reciting the text.

Each attorney shall list by title and pattern number the applicable pattern charges that he or she requests be given, using the current pattern charges published by the Council of Superior Court Judges, (the pattern charges are updated January and July of each year). Please do not recite the text of the pattern charge, just list the title and pattern number.

Applies to

Jury charges

Non-pattern jury charges may be requested only if no pattern charge covers the issue; they must cite statutory or case authority, and parties are limited to twenty non-pattern charges unless the Court orders more for good cause.

In addition, attorneys may request non-pattern charges, if there is no pattern charge that covers the issue. It is the Court's preference to utilize pattern charges. In requesting non-pattern charges, attorneys shall reference applicable statutory or case authority. The parties are limited to requesting twenty (20) non-pattern jury charges absent prior Order from the Court based on motion and good cause shown for requesting additional non-pattern jury charges.

Applies to

Filing

Attorneys or pro se litigants who use AI to prepare or draft any filing must be aware that the Court may act upon review of any improper AI use.

Any attorney or pro se litigant who uses AI in any capacity to prepare or draft any filing in this Courtroom SHALL be aware that if, on review, this Court finds the

Applies to

Motion in limine

Each motion in limine must be filed as a separate document and limited to discrete evidentiary or procedural matters.

Each such motion shall be a separate document and attachment to the email to opposing counsel and to Ms. Cormier. Such motions should be limited to discrete evidentiary or procedural matters, such as the admissibility of a specific piece of evidence.

Applies to

Oversized exhibit

Oversized or non-paper exhibits may be submitted as a digital photograph marked with an exhibit sticker; if not, a paper description will be inserted in the transcript.

For oversized or non-paper exhibits, such as guns, poster boards, etc., you may submit a digital photograph of the object marked with an exhibit sticker. If no photograph is submitted, thena piece of paper describing the exhibit (such as a gun, poster board, etc.) will be inserted by the court reporter in its place as the exhibit attached to the transcript.

Applies to

Jury instructions

Parties must submit proposed jury charges, with pattern charges given by number only and non-pattern or modified charges requiring full text plus citations to legal authority.

The parties must submit all proposed requests to charge which, for the State, includes charges of the particular offense(s) alleged in the indictment. For pattern charges, each party is to submit ONLY the pattern charge NUMBER and not the text of the charge itself. Pattern charges are strongly encouraged. For all non-pattern or modified pattern charges, the parties are required to submit the full text and cite the case law, statute, or other authority supporting such requested charge. Counsel may not submit proposed charges without citations to applicable legal authority.

Applies to

Verdict form

An agreed proposed verdict form must be submitted on the first day of trial, with lead counsel for both sides initialing the reverse side.

A proposed verdict form agreed to by both parties, shall be submitted to the Court on the first day of trial. The Court will request that lead counsel of record, for both the State and the Defendant, initial the back of the reverse side of the verdict form.

Applies to

Voir dire questions

Counsel must submit all proposed voir dire questions to the Court as directed.

Counsel shall submit to the Court all proposed voir dire questions as directed above.

Applies to

Exhibit list

Must include

exhibit list

Parties introducing exhibits must provide two hard copies of an exhibit list to the Court and one copy to each opposing party before jury selection, listing each exhibit's number and brief description.

Any party that intends to introduce exhibits during trial shall provide two hard copies of an exhibit list to the Court and one copy to each opposing party prior to jury selection. The exhibit list should include for each exhibit both the exhibit number and a brief description of what the exhibit purports to be.

Applies to

Demonstrative exhibit

All demonstrative exhibits must be shared with opposing counsel and the Court before trial begins.

All demonstrative exhibits must be shared with opposing counsel and the Court before the trial begins.

Applies to

Exhibit

Counsel must obtain Court approval before publishing any evidence or exhibits to the jury.

Counsel shall obtain approval from the Court before publishing any evidence/exhibits to the jury.

Applies to

Pretrial order

Plaintiff/Petitioner is responsible for consolidating the pre-trial order unless parties agree otherwise.

Unless the parties otherwise agree, Plaintiff/Petitioner shall be responsible for consolidatingthe pre-trial order.

Applies to

Email

Emails to chambers must include specifics of technology questions or support needed in advance of trial.

Said e-mail should include the specifics of the technology questions/support needed in advance of trial.

Applies to

Jury charges

Pattern jury charges require only listing numbers and titles; non-pattern or modified charges must be submitted in full text with citations.

If a party is seeking any pattern charges, the party need only listthe pattern charge numbers and titles;the Court will supply the relevant pattern language. Non-pattern requests or modified pattern requests should be submitted in full text along with citations to authority.

Applies to

Reply brief

Movants may not file reply briefs without the Court's permission; unauthorized replies will be stricken from the record.

Absent permission of the Court, movants may not file reply briefs. Replies filed without permission will be stricken from the record.

Applies to

E document

Electronic signatures and scanned ink signatures are treated as personal signatures under Georgia law.

An E-Document bearing an electronic signature, e.g., / s/ NAME, or a scanned copy of an ink signature shall be treated as a personal signature for all purposes under Georgia law.

Applies to

Exhibits

Oversized or non-paper exhibits may be submitted as a digital photograph marked with an exhibit sticker.

For oversized or non-paper exhibits, e.g., guns, poster boards, etc., you may submit a digital photograph of the object marked with an exhibit sticker.

Applies to

Exhibits

If no photograph is submitted, the court reporter will insert a paper describing the exhibit in its place as the exhibit attached to the transcript.

If no photograph is submitted, then a piece of paper describing the exhibit, e.g., gun, poster board, etc., will be inserted by the court reporter in its place as the exhibit attached to the transcript.

Applies to

Waiver of arraignment

Counsel may file a Waiver of Arraignment before the hearing indicating a not guilty plea and waiver of formal arraignment.

Prior to the hearing date, counsel may file a Waiver of Arraignment, indicating that the defendant is entering a plea of 'Not Guilty' and waiving formal arraignment.

Applies to

Witness list

The witness list need list only the witnesses' names and titles/positions and is separate from pre-trial discovery requirements.

Witness list. This witness list is for the Court's use during voir dire and need not list anything more than the witnesses! name and any applicable title or position. This list is separate from all pre-trial discovery requirements concerning witnesses, including the disclosure of all requisite identifying information and the content of expert opinions, if any.

Applies to

Exhibits

For oversized or non-paper exhibits, parties may submit a digital photograph of the object marked with an exhibit sticker.

For oversized or non-paper exhibits, e.g., guns, poster boards, etc., parties may submit a digital photograph of the object marked with an exhibit sticker.

Applies to

Witness list

The pretrial witness list must provide the names of potential witnesses and any applicable professional titles or positions.

This witness list will simply provide the Court with the names of any potential witnesses and any applicable professional titles positions.

Applies to

Witness list

Witness lists need only include witness names and titles.

This witness list is for the Court's use during voir dire and need not list anything more than the witnesses' name and any applicable title or position.

Applies to

Exhibit list

Exhibit lists should include the exhibit number and a brief description for each exhibit.

The exhibit list should include for each exhibit both the exhibit number and a brief description of what the exhibit purports to be.

Applies to

Court production request

For individuals in the Georgia Department of Corrections system, requested inmate information should coincide with GDC information.

For individuals located within the Georgia Department of Corrections system, the requested inmate information should coincide with the Georgia Department of Corrections information.

Applies to

Pleading

Attorneys may rely on AI in drafting pleadings and work product without disclosing AI reliance in filings.

You are free to rely on AI in drafting -- your pleadings and preparing your work product; you do not need to disclose your reliance on AI in your filings.

Applies to

Witness list

The witness list need only include each witness's name and title/position; it is separate from pre-trial discovery requirements.

A list of all potential witnesses. This witness list is for the Court's use during voir dire and need not list anything more than the witnesses' name and any applicable title or position. This list is separate from all pre-trial discovery requirements concerning witnesses, including the disclosure of all requisite identifying information and the content of expert opinions, if any.

Applies to

Pretrial order

Plaintiff/Petitioner is responsible for consolidating the pre-trial order unless parties agree otherwise.

Unless the parties otherwise agree, Plaintiff/Petitioner shall be responsible for consolidating the pre-trial order.

Applies to

Proposed order

Proposed orders on summary judgment motions should include detailed findings of facts and conclusions of law.

Proposed orders on motions for summary judgment should include detailed findings of facts and conclusions of law which the Court may adapt as appropriate.