Superior Court of Fulton County Pre-Motion Conference Requirements

Parties are encouraged to raise potential discovery disputes informally first, and if that fails the aggrieved party must notify the Court by letter or e-mail demonstrating compliance with Uniform Superior Court Rule 6.4 and providing sufficient information and/or documentation.

Direct, informal communication is encouraged between the parties to address potential discovery disputes before they become actual discovery disputes. If that fails, an aggrieved party must notify the Court of the discovery dispute by submitting a letter/e-mail demonstrating compliance with Uniform Superior Court Rule 6.4 and providing sufficient information and/or documentation.

No party may file a motion to compel or for a protective order without first discussing the issue with opposing parties (including in disputes with non-parties), and motions to compel that do not comply with Rule 6.4 will be denied.

No party may file a motion to compel or a motion for a protective order without first having discussed the issue with opposing parties. This stricture applies to disputes with non-parties as well. Motions to compel that do not comply with Rule 6.4 will be denied.

Parties must confer prior to filing a discovery dispute motion, per Uniform Superior Court Rules 6.4(A) and (B).

The motion must conform to the requirements of Uniform Superior Court Rules 6.4(A) and (B), including without limitation the requirement that the parties confer prior to the filing of a motion.

Parties must confer before filing a discovery motion.

The motion must conform to the requirements of Uniform Superior Court Rules 6.4(A) and (B), including without limitation the requirement that the parties confer prior to the filing of a motion.

A party must notify the Court of a discovery dispute by letter/email demonstrating USCR 6.4 compliance and providing sufficient information for a meaningful conference.

If that fails, an aggrieved party must notify the Court of the discovery dispute by submitting a letter/e-mail demonstrating compliance with Uniform Superior Court Rule 6.4 and providing sufficient information and/or documentation to permit a meaningful conference between the parties and the Court.

Parties must discuss the issue with the opposing party before filing a motion to compel or protective order; non-compliant motions to compel will be denied.

No party may file a motion to compel or a motion for a protective order without first having discussed the issue with the opposing party. This requirement applies to disputes with non-parties as well. Motions to compel that do not comply with Rule 6.4 will be denied.

Discovery motions require a pre-filing conference and certification that the conference occurred and efforts to resolve failed.

"[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."

Parties must confer before the motions hearing date to discuss narrowing issues, the State's offer, and the Defendant's plea options.

The Court hereby directs the parties to confer before the motions hearing date to determine whether any of the issues set forth in the motions can be narrowed or resolved by agreement and to discuss the State's offer to resolve the case, as well as, Defendant's desire to enter a plea of "guilty"--- or move forward with the motions hearing and trial.

Parties must discuss the issue with opposing parties and notify the Court by letter/e-mail demonstrating USCR 6.4 compliance before filing a motion to compel or protective order.

**No party may file a motion to compel or a motion for a protective order without first having discussed the issue with opposing parties.** This stricture applies to disputes with non-parties as well. Motions to compel which do not comply with Uniform Superior Court Rule 6.4 will be denied.

Required

Always

Parties must confer before the motions hearing date to attempt to narrow or resolve issues by agreement and to discuss plea possibilities versus proceeding to the motions hearing and trial.

The Court hereby directs the parties to confer before the motions hearing date to determine whether any of the issues set forth in the motions can be narrowed or resolved by agreement and to discuss the State's offer to resolve the case. as well as. Defendant's desire to enter a plea of"guilty"--- or move forward with the motions hearing and trial.

Required

Always

Parties must confer and complete all plea negotiations well before the Final Plea Calendar so that defense counsel can announce at calendar call whether the case will resolve by guilty plea or proceed to trial; no pre-trying or last-minute negotiations are permitted during the calendar.

The Court hereby orders the parties to confer and negotiate with each other well before the date ofthe Final Plea Calendar. such that there will be an announcement from defense counsel. at the calendar call ofthe Final Plea Calendar. as to whether the case is anticipated to resolve that day by guilty plea or whether Defendant desires a trial. There will be no pre-trying cases during the Final Plea Calendar. All negotiations shall be resolved before the commencement of the Final Plea Calendar. The Court is simply and only entertaining announcements from defense counsel as to how his/her client would like to proceed in resolving the case. The progress of the Final Plea Calendar will not be delayed by last minute discussions/negotiations between counsel.

Required

Always

State and defense counsel must work together diligently, including defense counsel relaying information to the client, so that all offers and counter-offers are communicated and concluded well before the Final Plea Calendar date.

*** Again. in order to facilitate this mandate, counsel for the State and the defense MUST work together diligently (and defense counsel in relaying information to his/her/their client) to ensure the communication of offers and counter-offers have concluded well before the date of the Final Plea Calendar. ***

Before filing a motion to compel, the moving party must discuss the matter with the Court's staff attorney; failure to do so results in automatic denial.

No party may file a motion to compel until the moving party has first discussed the matter with the Court's staff attorney to allow the Court to determine if the dispute may be resolved through a conference call with the court and the parties. Motions filed without first consulting the Court's staff attorney stand automatically denied. The parties must comply with Uniform Superior Court Rule 6.4 and attempt, in good faith, to resolve the issue before contacting the Court.

Opposing responses to non-evidentiary motions are due within 30 days; replies within 15 days of the response; additional briefing requires leave of court requested by email; deadlines may be shortened or extended.

As a general practice, non-evidentiary motions will be decided upon the written submissions of the parties, however, the Court may request oral argument sua sponte or allow it upon good cause shown. For motions which do not rely on the introduction of evidence through proffer or formal hearing, opposing parties may file a response within 30 days of the initial motion. 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. If approved, movants may file a reply within 15 days of the response. These filing deadlines may be shortened or extended at the discretion of the Court.

Parties must discuss discovery disputes informally before filing motions to compel or for protective orders; a letter/email demonstrating compliance with Rule 6.4 is required.

Direct, informal communication is encouraged between the parties to address potential discovery disputes before they become actual discovery disputes. If that fails, an aggrieved party must notify the Court of the discovery dispute by submitting a letter/e-mail demonstrating compliance with Uniform Superior Court Rule 6.4 and providing sufficient information and/or documentation. No party may file a motion to compel or a motion for a protective order without first having discussed the issue with opposing parties. This stricture applies to disputes with non-parties as well. Motions to compel that do not comply with Rule 6.4 will be denied.

Before filing a motion to compel or for a protective order, parties must first discuss the dispute with the Court and opposing parties and submit a letter/e-mail demonstrating compliance with USCR 6.4; non-compliant motions will be denied.

Direct, informal communication is encouraged between the parties to address potential discovery disputes before they become actual discovery disputes. If that fails, an aggrieved party must notify the Court of the discovery dispute by submitting a letter/e-mail demonstrating compliance with Uniform Superior Court Rule 6.4 and providing sufficient information and/or documentation to permit a meaningful telephone conference between the parties and the Court. No party may file a motion to compel or a motion for a protective order without first having discussed the issue with the Court and opposing parties. This stricture applies to disputes with non-parties as well. Motions to compel that do not comply with Rule 6.4 or that precede an initial conference with the Court will be denied.

Replies and sur-replies require prior Court approval, requested informally by email with an explanation of need.

Neither replies nor sur-replies will be considered without prior approval from the Court. Approval may be requested informally by email and should explain the reason why a reply or sur-reply is needed.

All parties must participate in a mandatory mediation before trial, with a neutral registered with the Georgia Office of Dispute Resolution.

Prior to trial, all parties are required to participate in a mandatory mediation. The neutral must be registered with the Georgia Office of Dispute Resolution. ADR will be specifically raised and discussed during the status conference.

Before filing a motion to compel or for a protective order, parties must attempt informal resolution, then notify the Court by a Rule 6.4-compliant letter/e-mail and participate in a meaningful telephone conference; non-compliant motions to compel will be denied.

Direct, informal communication is encouraged between the parties to address potential discovery disputes before they become actual discovery disputes. If that fails, an aggrieved party must notify the Court of the discovery dispute by submitting a letter/e-mail demonstrating compliance with Uniform Superior Court Rule 6.4 and providing sufficient information and/or documentation to permit a meaningful telephone conference between the parties and the Court. No party may file a motion to compel or a motion for a protective order without first having discussed the issue with the Court and opposing parties. This stricture applies to disputes with non-parties as well. Motions to compel that do not comply with Rule 6.4 or that precede an initial conference with the Court will be denied.

Parties must confer before the motions hearing date to narrow or resolve outstanding motions and discuss the State's offer and plea options.

The Court hereby orders the parties to confer before the Motions hearing date to determine whether any of the outstanding motions can be narrowed or resolved by agreement and to discuss the State's offer to resolve the case as well as the defendant's desire to enter a plea of guilty or move forward to the motions hearing and to trial.

Filing reply or sur-reply briefing requires prior leave of court, requested via email to the Court's staff attorney.

No party may file briefing other than the initial and response briefs without leave of court, which may be requested by email to the Court's staff attorney explaining why additional briefing is necessary.

Parties must confer before the Motions Hearing Date to narrow or resolve outstanding motions and discuss the State's offer and the Defendant's plea or trial decision.

The Court hereby orders the parties to confer before the Motions Hearing Date to determine whether any of the outstanding motions can be narrowed or resolved by agreement and to discuss the State's offer to resolve the case as well as the Defendant's desire to enter a plea of guilty or move forward to the Motions Hearing Date and to Trial.

Parties must confer before the Final Plea Date to determine the State's offer and whether the Defendant will plead guilty or proceed to trial.

The Court hereby orders the parties to confer before the Final Plea Date to determine the State's offer and whether the Defendant will enter a plea of guilty or move forward to trial.

The Court encourages (but does not require) parties to request discovery, pre-trial, or settlement conferences with specific goals, and will meet in chambers, in court, or by phone.

Discovery, pre-trial, and settlement conferences promote the speedy, just, and efficient resolution of cases. Therefore, the Court encourages the parties to request a conference whenever they believe that such will be helpful and have specific goals for the conference. The Court will accommodate the parties by meeting in chambers, in court, or over the phone, consistent with the parties9 schedules and preferences.

Parties must confer before the Motions Hearing Date to determine whether outstanding motions can be narrowed or resolved and to discuss the State's offer and the defendant's desired course.

The Court hereby orders the parties to confer before the Motions Hearing Date to determine whether any of the outstanding motions can be narrowed or resolved by agreement and to discuss the State's offer to resolve the case as well as the defendant's desire to enter a plea of guilty or move forward to the Motions Hearing Date and Trial.

Parties must confer before the Final Plea Date to discuss the State's offer and whether the defendant will plead guilty or proceed to trial.

The Court hereby orders the parties to confer before the Final Plea Date to determine the State's offer and whether the defendant will enter a plea of guilty or move forward to trial.

The Court may sua sponte appoint a Special Master for frequent discovery disputes, with costs apportioned among parties.

The Court will sua sponte appoint a Special Master pursuant to U.S.C.R. 46 in any case where it appears discovery disputes have been or will be frequent and reoccurring. Such a special master will be directed to promptly address and provide guidance for any motions to compel, motions for contempt, and any other discovery disputes, with costs to be apportioned among the parties.

Parties are encouraged, but not required, to contact chambers and request a pre-trial conference in advance of trial to resolve motions in limine.

Parties are encouraged to contact chambers and request a pre-trial conference in advance of trial to resolve motions in limine.