Superior Court of Fulton County Document Filing Requirements

CRITICAL

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 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

CRITICAL

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.

CRITICALCivil cases

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).

CRITICALCriminal cases

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).

CRITICALCivil cases

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.

CRITICALCriminal cases

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.

CRITICALCriminal cases

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.

CRITICALCivil cases

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.

CRITICALCriminal cases

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.

CRITICALCivil cases

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.

CRITICALCriminal cases

Applies to

Exhibits

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.

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.

CRITICALCriminal cases

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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).

CRITICALCivil cases

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.

CRITICALCriminal cases

Applies to

Voir dire questions

Parties must submit a list of potential voir dire questions.

A list of potential voir dire questions.

CRITICAL

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.

CRITICALCriminal cases

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

CRITICALCivil cases

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.

CRITICAL

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.

CRITICALCriminal cases

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

CRITICALCriminal cases

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

CRITICALCivil cases

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.

CRITICALCriminal cases

Applies to

Verdict form

Parties must submit a proposed verdict form.

A proposed verdict form.

CRITICALCriminal cases

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.

CRITICAL

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.

CRITICAL

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'"').

CRITICALCriminal cases

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.

CRITICAL

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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.

CRITICALCriminal cases

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.

CRITICALCriminal cases

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.

CRITICAL

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.

CRITICAL

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.

CRITICAL

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.

CRITICALCriminal cases

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.

CRITICAL

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

CRITICAL

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.

CRITICAL

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.

CRITICAL

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

CRITICALCriminal cases

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.

CRITICAL

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.

CRITICAL

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.

CRITICALCriminal cases

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).

CRITICALCriminal cases

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.

CRITICAL

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.