Superior Court of Fulton County Document Filing Requirements

WARNINGCivil cases

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.

WARNINGCriminal cases

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.

WARNINGCivil cases

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.

WARNINGCriminal cases

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.

WARNINGCivil cases

Applies to

Discovery response

Boilerplate objections in discovery responses are prohibited.

Boilerplate objections in response to discovery requests are prohibited.

WARNINGCriminal cases

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.

WARNINGCivil cases

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.

WARNINGCriminal cases

Applies to

Leave of absence

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

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

WARNINGCriminal cases

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.

WARNINGCivil cases

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.

WARNINGCriminal cases

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.

WARNINGCriminal cases

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.

WARNINGCivil cases

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.

WARNINGCivil cases

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).

WARNINGCriminal cases

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.

WARNINGCriminal cases

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.

WARNINGCivil cases

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.

WARNINGCivil cases

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.

WARNINGCriminal cases

Applies to

Voir dire questions

Parties must submit a list of potential voir dire questions.

A list of potential voir dire questions.

WARNINGCivil cases

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.

WARNINGCriminal cases

Applies to

Verdict form

Parties must submit a proposed verdict form.

A proposed verdict form.

WARNINGCriminal cases

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.

WARNINGCivil cases

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.

WARNINGCivil cases

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.

WARNINGCriminal cases

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.

WARNINGCriminal cases

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

WARNINGCriminal cases

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.

WARNINGCivil cases

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.

WARNINGCivil cases

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.

WARNINGCivil cases

Applies to

Discovery response

Boilerplate objections in discovery responses are prohibited.

Boilerplate objections in response to discovery requests are prohibited.

WARNINGCivil cases

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.

WARNINGCriminal cases

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.

WARNINGCivil cases

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

WARNINGCriminal cases

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.

WARNINGCriminal cases

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.

WARNINGCivil cases

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.

WARNINGCivil cases

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.

WARNINGCriminal cases

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.

WARNINGCriminal cases

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.

WARNINGCivil cases

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.

WARNINGCriminal cases

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.

WARNINGCivil cases

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.

WARNINGCivil cases

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.

WARNINGCriminal cases

Applies to

Exhibit list

Must include

exhibit list

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.

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.

WARNINGCriminal cases

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.

WARNINGCriminal cases

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.

WARNINGCivil cases

Applies to

Motion in limine

Motions in limine must be made in writing.

Motions in Limine shall be made in writing

WARNINGCriminal cases

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.

WARNINGCivil cases

Applies to

Filing

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

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

WARNINGCivil cases

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.