Superior Court of Fulton County Document Filing Requirements

CRITICAL

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).

CRITICAL

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 | 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

CRITICALCriminal cases

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

CRITICAL

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).

CRITICALCriminal cases

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.

CRITICALCriminal cases

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.

CRITICALCriminal cases

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

CRITICAL

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.

CRITICAL

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.

CRITICAL

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).

CRITICAL

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.

CRITICAL

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.

CRITICAL

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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.

CRITICALCriminal cases

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

CRITICALCriminal cases

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.

CRITICALCriminal cases

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.

CRITICAL

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.

CRITICAL

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.

CRITICALCivil cases

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.

CRITICAL

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.

CRITICAL

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).

CRITICALCriminal cases

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

CRITICAL

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.

CRITICALCriminal cases

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.

CRITICALCriminal cases

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.

CRITICAL

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."

CRITICALCriminal cases

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.

CRITICAL

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

CRITICAL

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.

CRITICALCivil cases

Applies to

Petition to withdraw as counsel

A granted petition to withdraw is not effective until the attorney registers the client for eFileGA and adds a service contact.

Any Petition granted will not be effective until the attorney registers his/her client for eFileGA with a service contact added.

CRITICALCivil cases

Applies to

Petition to withdraw as counsel

A petition to withdraw must comply with U.S.C.R. 4.3 and state that written notice was given, ten days have expired, and either no objection was filed or the client consents.

A Petition to Withdraw as Counsel must strictly comply with U.S.C.R. 4.3. Failure to comply shall result in the Petition being denied. The Petition shall state that the attorney has given written notice to the client, ten (10) days have expired ===== PAGE 2 ===== since notice was provided, no objection has been filed by the Court or client or withdrawal is with the client's consent.

CRITICALCriminal cases

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.

CRITICALCriminal cases

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.

CRITICALCivil cases

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.

CRITICALCriminal cases

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.

CRITICALCivil cases

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.

CRITICALCriminal cases

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.

CRITICALCriminal cases

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).

CRITICAL

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.

CRITICALCriminal cases

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 heshe 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).

CRITICALCriminal cases

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,

CRITICALCriminal cases

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.

CRITICALCriminal cases

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.

CRITICALCriminal cases

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

CRITICALCriminal cases

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 J oir 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

CRITICALCivil cases

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.

CRITICALCriminal cases

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.

CRITICALCriminal cases

Applies to

Exhibits

All exhibits must be marked before trial begins.

Exhibits SHALL be marked BEFORE trial.