Circuit Court for Baltimore City Document Filing Requirements

Applies to

Scheduling order

Counsel must file a line identifying agreements that change a date or deadline in the existing scheduling order.

Counsel shall file a line detailing any agreements made between Counsel that affect a change in any date or deadline in the existing Scheduling Order.

Applies to

Dismissal

Must include

caption

Each dismissal caption must state whether the dismissal is with or without consideration.

The caption of each dismissal shall state that the dismissal is with or without consideration.

Applies to

Guardianship petition

Must include

caption, case number

The petition and related paperwork must be filed with the Clerk of the Court in Room 462 of the Cummings Courthouse.

The petition and all related paperwork must be filed with the Clerk of the Court in Room 462 of the Cummings Courthouse.

Applies to

Guardianship petition

Must include

proposed order

A proposed guardianship order must be submitted to Magistrate Walsh for approval as to form.

A proposed order for guardianship must also be submitted to Magistrate Walsh for approval as to form.

Applies to

Guardianship filing

All filings in non-expedited guardianship matters must be made directly with the Clerk’s office in Room 462 of Courthouse East.

All filings are to be made directly with the Clerk’s office in Room 462 Courthouse East.

Applies to

Written statement

At least five days before the settlement conference, each party must submit a written statement addressing the matters listed in Rule 2-504.2(b).

Each party shall submit no less than five (5) days in advance of that date: a. A written statement addressing each of the pertinent matters listed in Rule 2-504.2(b);

Applies to

Confidential pretrial statement

Each party must submit a confidential pretrial statement containing specified factual, legal, settlement, valuation, and share information.

d. A confidential pretrial statement containing the following information: brief summaries/description of facts, work histories, factual disputes, legal disputes, case strengths and weaknesses, history of settlement negotiations, reasonable estimated settlement value, and the number of "shares."

Applies to

Written statement

Each party must file a written statement addressing the matters listed in Rule 2-504.2(b) no later than five days before the pretrial conference.

Pursuant to Maryland Rule 2-504.2(a), each party shall file not later than five days before the conference a written statement addressing the matters listed in Rule 2-504.2(b).

Applies to

Voir dire

A voir dire must be filed by the D+226 motions hearing deadline.

File voir dire, jury instructions.

Applies to

Inactive civil docket plaintiff information form

The attached material must support the claim that the conditions identified in paragraph 9 are asbestos related and include everything required by the Rule.

The following material is attached in support of the claim that the conditions indicated in paragraph 9 above are asbestos related (include all required by the Rule):

Applies to

Claimant counsel certification

Claimant's counsel must make the stated certification regarding counsel status, supporting information, payments, and substantially similar proceedings.

Certification: I do hereby certify in accordance with the provisions of the Maryland Rules of Procedure that I am counsel for the above-named claimant, that the information set forth to support the claim being filed herein is true and correct, that no payment for this claim or one substantially similar to it as to this claimant has been received from any entity listed in paragraph 11 above, and that there is no proceeding pending in this or any other jurisdiction on behalf of the claimant or exposed person listed herein which is substantially similar to the present claim in its factual allegations.

Applies to

Inactive civil docket plaintiff information form

Must include

certificate of service

The form includes a required Certificate of Service section.

Certificate of Service

Applies to

Notice of accomplishment of service

After distributing a court order, defense liaison counsel must file a Notice of Accomplishment of Service with the clerk and not provide a copy to chambers.

Defense liaison counsel shall file with the clerk of court (no copy to court chambers) a "Notice of Accomplishment of Service of Court Order" upon completion of distribution of an order.

Applies to

Answer or response

The answer or response must be filed with the appropriate clerk, with no copy to court chambers.

The answer or response shall be filed with the appropriate Clerk of Court (no copy to court chambers).

Applies to

Notice of accomplishment of service

Must include

certificate of service

Defendants' liaison counsel must file a notice of accomplishment of service that certifies distribution of the materials.

Defendants' Liaison Counsel is required to (1) acknowledge receipt of the information of plaintiffs' counsel; (2) mail or hand deliver complete copy of each Form B and documentation and a copy of the service list received form to plaintiffs' counsel, to each defendants' counsel named on the plaintiffs' service list; and (3) file a notice of accomplishment of service with the Court which certifies the distribution, with three (3) working days of the receipt of the Form B and documentation from plaintiffs' counsel.

Applies to

Objection

After an objection based on particular grounds is filed, other defendants may not file objections or adoptions based on those same grounds.

Once an objection to a plaintiff's request for removal from the inactive docket is filed, no other defendants shall file objections (or adoptions of the objections) based on the same grounds.

Applies to

Status report

The status report must identify each objected-to case, the grounds for objection, and why the objection remains uncured.

The status report shall list case by case the cases that are objected to and the reasons for the objection, as well as, the reasons the objection has not been able to be cured.

Applies to

Notice of settlement

When settlement is reached before the pretrial conference, the parties must promptly file a notice of settlement and provide the Transaction Identification Numbers to the Asbestos Case Managers.

If a settlement is reached before the Pretrial Conference, the parties shall promptly file notice of settlement with the Court and provide the Transaction Identification Numbers to the Asbestos Case Managers.

Applies to

Notice of selection of adr provider

Parties must submit the written notice of mediator selection substantially in the form prescribed by MD Rule 17-203(c)(1) to the Civil ADR Program by mail or fax.

Parties must submit a written “Notice of Selection of ADR Provider by Stipulation In Health Care Malpractice Claims” substantially in the form set forth in MD Rule 17-203(c)(1) to the Civil ADR Program by mail or fax (see contact information below).

Applies to

Confidential mediation conference statement

Parties must complete and send the Confidential Mediation Conference Statement to the mediator at least five days before mediation, and the statement must not be exchanged or filed with the court.

Parties must complete and send to the mediator the Confidential Mediation Conference Statement (CMCS) form, which is enclosed with the Order for Mediation, at least five (5) days prior to the scheduled mediation session. Only the mediator shall have access to the CMCS. Parties should not exchange CMCSs or file them with the court. The mediator shall not share the CMCS with the court.

Applies to

Mediator report

Mediators must complete a Mediator Report for every case, even when mediation does not occur.

Mediators must complete a Mediator Report for each case whether or not mediation occurs.

Applies to

Mediation survey forms

All counsel and parties must complete the mediator’s survey forms, and the forms must be mailed to the Civil ADR Office within seven days after the last mediation session.

All counsel and parties must complete survey forms provided by the mediator. All forms must be mailed to the Civil ADR Office within seven (7) days of the last mediation session.

Applies to

Mediation conference statement

Must include

caption, case number

The Mediation Conference Statement must identify the case by caption and case number.

1. Identification of the case by caption and case number.

Applies to

Mediation conference statement

The Mediation Conference Statement must include a brief statement of the facts counsel will rely on in support of a claim.

4. A brief statement of the facts counsel will rely on in support of a claim.

Applies to

Newly added party notice

Must include

notice of electronic filing

Counsel for the claiming party must serve the Order on a newly added party and advise that party of its right to participate in eFiling.

If a new party is brought into the Asbestos Litigation after the signing of this Order, then counsel representing the claiming party shall serve a copy of this Order on the newly-added party and advise such party of its right to participate in this project.

Applies to

Discovery request

A party generating discovery requests must satisfy Maryland Rule 2-431's certificate requirement before presenting a discovery dispute to the court.

The party generating discovery requests must comply with Maryland Rule 2-431 (Certificate Requirement) before bringing a discovery dispute before the Court.

Applies to

Proposed order

The filing type Proposed Order must be selected when filing a proposed order.

The filing type "Proposed Order" must be selected for all proposed orders.

Applies to

Efiled pleading paper or document

Every e-filed pleading, paper, or document must bear an attorney’s facsimile or typographical signature and specified typed contact information.

Every eFiled pleading, paper, and document shall bear a facsimile or typographical signature of at least one of the attorneys of record, along with the typed name, address, telephone number and e-mail address (if available) of that attorney.

Applies to

Motion

A motion seeking an expedited trial date must include executed answers to interrogatories when filed.

Any plaintiff seeking an expedited trial date must provide the following at the time of filing of said motion: (a) executed answers to interrogatories;

Applies to

Motion

A motion seeking an expedited trial date must include records in the plaintiff's possession, custody, or control showing when or how the plaintiff was exposed to asbestos.

(b) any records in Plaintiffs’ possession, custody, or control reflecting when or how Plaintiff was exposed to asbestos, including any records reflecting any of the information called for in paragraphs (a) above;

Applies to

Scheduling order

Parties must submit a scheduling order for a case set on an expedited basis.

If a case is set in on an expedited basis, the parties are directed to submit a scheduling order in the format and using the dates set forth in Exhibit A.

Applies to

Settlement order

A settlement order identifying the party responsible for outstanding costs must be filed in the Civil Assignment Office for every case that has settled.

A settlement order with designation of which party will pay any outstanding costs must be filed in the Civil Assignment Office for all cases that have settled.

Applies to

Settlement order

Must include

proposed order

When a remand order is required, the settlement order must include a proposed remand order.

If a Remand Order is required (e.g., workers’ compensation cases), a proposed Remand Order must be attached to the Settlement Order.

Applies to

Settlement conference submissions

At least five days before the settlement conference, each party must submit a Rule 2-504.2(b) written statement, a list of remaining claims and crossclaims, a list of pending filed motions, and a confidential pretrial statement containing the specified case information.

Each party shall submit no less than five (5) days in advance of that date: a. A written statement addressing each of the pertinent matters listed in Rule 2-504.2(b); b. A list of all claims (including crossclaims) to which it remains a party; c. A list of all pending motions which it has filed; and d. A confidential pretrial statement containing the following information: brief summaries/description of facts, work histories, factual disputes, legal disputes, case strengths and weaknesses, history of settlement negotiations, reasonable estimated settlement value, and the number of “shares.”

Applies to

Expedited trial motion

A motion seeking an expedited mesothelioma trial date must include executed interrogatory answers, asbestos-exposure records, a Social Security printout or request documentation, a current HIPAA-compliant medical records authorization, available medical records, a physician’s mesothelioma diagnosis report, the requested trial group, and information about defendants served and settlements reached.

Any plaintiff seeking an expedited trial date must provide the following at the time of filing of said motion: (a) executed answers to interrogatories; (b) any records in Plaintiffs’ possession, custody, or control reflecting when or how Plaintiff was exposed to asbestos, including any records reflecting any of the information called for in paragraphs (a) above; (c) Plaintiffs’ social security print­out, or, if not yet available, documentation showing that it has been requested from the Social Security Administration; ===== PAGE 2 ===== (d) a current, executed and HIPAA­compliant medical records authorization; (e) all medical records in Plaintiff’s possession, custody, or control; (f) a report of a physician setting forth a diagnosis of mesothelioma; (g) the trial group to which that plaintiff seeks to be joined; (h) identification of defendants served with process and identification of the parties with whom settlements have been reached.

Applies to

Pretrial statement

Each party must file a written statement addressing the Rule 2-504.2(b) matters no later than five days before the pretrial conference.

Pursuant to Maryland Rule 2-504.2(a), each party shall file not later than five days before the conference a written statement addressing the matters listed in Rule 2-504.2(b).

Applies to

Complaint

Counsel bringing a future claim must file both a complaint and Inactive Docket Claimant Information Form (Form A).

Each plaintiff's counsel bringing a future claim shall, regardless of the disease process alleged, file a complaint and an Inactive Docket Claimant Information Form (Form A) with the Court and effect service on each person or entity named as a defendant in accordance with Maryland Rules and law relating to service of complaints.

Applies to

Request for Removal (Form B)

Counsel must file a Request for Removal (Form B) when a claim is or becomes eligible for removal from the Inactive Docket.

For each such future claim alleged by the claimant to be immediately eligible for removal from the Inactive Docket, or which the claimant later alleges is eligible for removal because circumstances have changed, claimant's counsel shall also file with the Court a Request for Removal (Form B) and the documentation necessary to show that the claim meets the "minimum criteria for removal" set forth in Paragraph 10 above.

Applies to

Written objections to removal from the Inactive Docket

A defendant objecting to removal must state the objections in a written submission within fourteen days of the Paragraph 13 submission.

Within fourteen (14) days of the submission required by Paragraph 13 above, any defendant objecting to the removal of any claim or claims from the Inactive Docket shall set forth those objections in a writing not to exceed two pages per claim.

Applies to

Petition for removal

The Petition for Removal must state the factual and medical bases for the claimant's allegation of a compensable asbestos-related injury.

a. The Petition shall state the factual and medical bases for claimant's allegation that claimant has a compensable asbestos-related injury.

Applies to

Petition for removal

Each Petition for Removal must include Form B with current documentation showing the claimant's present medical condition and status under the minimum removal criteria.

b. Each Petition so filed must attach a Request for Removal (Form B) with current documentation to show the claimant's current medical condition and the claimant's status with respect to the "minimum criteria for removal" set forth in Paragraph 10 above.

Applies to

Request to substitute mediator

Parties seeking to replace the court-appointed mediator must submit a written Request to Substitute Mediator in substantially the form prescribed by MD Rule 17-202(g).

Parties must submit a written “Request to Substitute Mediator,” substantially in the form set forth in MD Rule 17-202(g) to the Civil Mediation Program at the address below or by fax.

Applies to

Confidential mediation conference statement

Parties must complete and send the Confidential Mediation Conference Statement to the mediator at least five days before the scheduled mediation session.

Parties must complete and send to the mediator the Confidential Mediation Conference Statement (CMCS) form, which is enclosed with the Order for Mediation, at least five (5) days prior to the scheduled mediation session.

Applies to

Attorney evaluation form

Attorneys must complete an Attorney Evaluation Form immediately after the final mediation conference, and mediators must complete an ADR Data Sheet.

Attorneys must complete an Attorney Evaluation Form immediately following the final mediation conference, and Mediators must complete an ADR Data Sheet.

Applies to

Confidential mediation conference statement

Parties must complete and send the CMCS form to the mediator at least five days before the scheduled mediation session.

Parties must complete and send to the mediator the Confidential Mediation Conference Statement (CMCS) form, which is enclosed with the Order for Mediation, at least five (5) days prior to the scheduled mediation session.

Applies to

Pretrial order

The joint master pretrial order may contain only non-plaintiff-specific information and must follow the form mandated by District of Maryland Local Rule 35.

It shall contain only non-plaintiff-specific information and shall be set forth in the form mandated by Local Rule 35 of the Rules of the United States District Court for the District of Maryland.

Applies to

Legal document

Must include

caption, case number

Legal documents filed in both the Master File and an individual action file must include both captions and file numbers.

Any legal documents to be filed in both the Master File and the file of an individual action shall be captioned with both the Master File caption and file number and the individual case caption and file number.

Applies to

Motion

A motion relying on or challenging a discovery response must attach the necessary portions of the response or a sufficient synopsis or listing.

In any motion contesting the sufficiency of any discovery response, or any motion for summary judgment or partial 'summary judgment, or any other motion wherein reference is made to any discovery response, the moving party shall attach such portions of the discovery response or a synopsis or listing of same as shall be necessary for a ruling on the motion.

Applies to

Master complaint

Plaintiffs' counsel must file a Master Complaint in each case category or subcategory in which counsel intends to make filings.

Each Plaintiffs' counsel shall file in each case category or subcategory in which that Plaintiffs' counsel intends to have filings, a Master Complaint alleging common facts and causes of action.

Applies to

Master answer

Each defendant must file a Master Answer to each Master Complaint.

Each Defendant shall file a Master Answer to each Master Complaint.

Applies to

Short form answer

Must include

caption, local rule certificate

Each defendant must file a Short-Form Answer that adopts the defendant's Master Answer by reference and states any case-specific additional responses.

Each Defendant shall file a Short-Form Answer to the Short-Form Complaint which adopts by reference the Defendant's Master Answer and sets forth any additional responses unique to the newly-filed case.

Applies to

Short form amended complaint

An amended complaint must be filed as a Short-Form Amended Complaint specifying the causes of action alleged in the Master Complaint.

Any amended complaint, including those filed in cases initiated before January 1, 1987, shall be made by filing a Short-Form Amended Complaint which specifies the causes of action which are being alleged from those in the Master Complaint.

Applies to

Third party pleading

A copy of the Order must accompany any third-party pleading served on an impleaded party, and the pleading must draw attention to the Order.

When serving any third party pleadings on an impleaded party, a copy of this Order shall be attached and attention drawn to it.

Applies to

Master service list

Liaison counsel must file with the clerk and serve on all parties a master service list identifying all attorneys of record in each established case category.

Liaison counsel shall file with the Clerk and serve on all parties a master service list of all attorneys of record in each case category established in Part III, Paragraph 1(a) of this Order.

Applies to

Interrogatories

In CT-5 cases, plaintiffs' and defendants' Master Sets of Interrogatories must match the Trade Case Master Sets, except for corrections of mistakes.

Plaintiffs' and Defendants' Master Sets of Interrogatories in CT-5 cases shall be identical (except for correction of mistakes) to the Master Sets of Interrogatories employed for "Trade Cases" under Pre-Trial Order No. 1 governing asbestos cases in Baltimore County.

Applies to

Plaintiff specific documents

All plaintiff-specific documents produced in response to a document-production request or request for admissions must receive specific identification numbers under a clear code-numbering system.

All Plaintiff-specific documents produced by Plaintiff's counsel in response to a Request for Production or in conjunction with a Request for Admissions under "VI." Request for Admissions" shall be assigned specific numbers under a code numbering system clearly identifying each and every document produced.

Applies to

Itemized index

The itemized index must describe each document group generally and identify the series of code numbers included in that group.

The index shall include a generalized description of the groups of documents with code numbering in series included in each group of documents.

Applies to

Request for admission

A party requesting admission concerning a document must code-number the document and its service or inspection copies and identify the document by that code number in each related request for admission.

A party requesting an admission concerning a document shall code number the document (and any service or inspection copies of the document) and shall specifically identify the document by its code number in each request for admission concerning that document.

Applies to

Log index

A party intending to use a videotape deposition at trial must prepare a log index identifying the subject matter explored, corresponding digital-counter readings, exhibits, and persons present, subject to technical obstacles.

A party intending to make use of the videotape deposition at trial shall prepare a log index that includes the subject matter being explored, cross referenced to a digital reading on the digital counter of the videotape equipment, a list of exhibits, and the names of all persons present at the deposition conditioned on whether or not there appear technical obstacles to accomplishing these requirements.

Applies to

Videotape deposition notice

Unless the parties agree otherwise or emergency circumstances require otherwise, the videotape deposition notice must state why the deposition is being taken.

Unless the parties agree otherwise or emergency circumstances require otherwise, counsel noticing a videotape deposition shall: (ii) State in the videotape deposition notice the reason(s) the deposition is being taken; and

Applies to

Pretrial order

The supplemental order must incorporate relevant portions of the joint master pretrial order and include other information required by Federal Local Rule 35 that the original does not contain.

That Order shall incorporate relevant portions of the Joint Master Pre-Trial Order and set forth any other information required by Federal Local Rule 35 that is not already contained in the Joint Master Pre-Trial Order.

Applies to

Confidential mediation conference statement

Parties must complete and send the CMCS form to the mediator at least five days before the scheduled mediation session.

Parties must complete and send to the mediator the Confidential Mediation Conference Statement (CMCS) form, which is enclosed with the Order for Mediation, at least five (5) days prior to the scheduled mediation session.

Applies to

Confidential mediation conference statement

The CMCS is confidential and may be accessed only by the mediator; parties should not exchange or file it, and the mediator may not share it with the Court.

Only the Mediator shall have access to the CMCS. Parties should not exchange CMCS’s or file it with the Court. The mediator shall not share the CMCS with the Court.

Applies to

Request for cancellation of pretrial conference

A request to cancel the pretrial conference must be submitted to the mediation director with a signed mediator certification, and copies must be served on opposing parties.

In order to secure cancellation of the pre-trial conference, a party must submit a request for cancellation to the mediation director, contact information below, accompanied by a certification signed by the court-appointed mediator (with copies served upon opposing parties) attesting that mediation has occurred in accordance with the terms of the Court’s order.

Applies to

Attorney evaluation form

Attorneys must complete the Attorney Evaluation Form after the final mediation conference, mediators must complete the ADR Data Sheet, and both forms should be faxed or mailed to the Civil Mediation Program Coordinator within seven days.

Attorneys must complete an Attorney Evaluation Form immediately following the final mediation conference, and Mediators must complete an ADR Data Sheet. All forms should be faxed or mailed to the Civil Mediation Program Coordinator within seven (7) days of the last mediation session.

Applies to

Adr data sheet

The Attorney Evaluation Form is required from attorneys after the final mediation conference, and the ADR Data Sheet is required from mediators.

Attorneys must complete an Attorney Evaluation Form immediately following the final mediation conference, and Mediators must complete an ADR Data Sheet.

Counsel must file a line identifying any agreement that changes a date or deadline in the existing Scheduling Order.

Counsel shall file a line stating any agreements made between Counsel that affect a change in any date or deadline in the existing Scheduling Order.

Applies to

Complaint

Every civil non-family complaint filed with the Clerk must include a Civil Non-Domestic Case Information Report.

Under Maryland Rule 2-111, every complaint filed with the Clerk of the Court must include a Civil Non-Domestic Case Information Report (PDF).

Applies to

Mediation conference statement

Parties or counsel must send the statement to the designated mediator at least five days before the mediation conference.

Parties or counsel must send a Confidential Mediation Conference Statement to the designated mediator at least five (5) days prior to the scheduled mediation conference.

Applies to

Mediation conference statement

Must include

caption, case number

The statement must identify the case by caption and case number.

1. Identification of the case by caption and case number.

Applies to

Mediation conference statement

The statement must identify each non-counsel representative with decision-making authority who will attend mediation and provide that person's name, address, email address, and telephone number.

2. The name, address, e-mail address and telephone number of all persons with decision making authority who, in addition to counsel of record, will attend the mediation as a representative of a party (as they are required to do so);

Applies to

Mediation conference statement

The statement must include a brief statement of the facts and a list of key documents or other tangible evidence counsel intend to rely on at trial.

3. A brief statement of the facts and list of key documents or other tangible evidence upon which counsel intend to rely at trial;

Applies to

Mediation conference statement

The statement must describe the strengths and weaknesses of the case, including areas opposing counsel is expected to focus on.

4. Strengths and weaknesses of your case, including areas opposing counsel is expect to focus;

Applies to

Mediation conference statement

The statement must provide a realistic maximum and minimum damages evaluation and state the grounds for it.

5. A realistic maximum/minimum damages evaluation stating grounds therefore, including, e.g., recent cases tried to verdict or settled in this or a comparable court; and

Applies to

Mediation conference statement

The statement must include any history of settlement negotiations.

6. Any history of settlement negotiations.

Applies to

Motion

Must include

proposed order

Motions should include an attached proposed order.

All motions should have attached proposed orders.

Applies to

Hearing request

A timely request for a hearing is required for a motion to be placed on the hearing docket.

Only those motions in which a party has made a timely request for a hearing will be set on the hearing docket.

Applies to

Hearing request

A hearing request in a motion or response must appear under the heading "Request for Hearing."

Parties are reminded that under Maryland Rule 2-311(f), a hearing request in a motion or response must be under the heading "Request for Hearing."

Applies to

Motion

A motion to add product-identification witnesses beyond fifty must include a claim and jobsite description, the first fifty and proposed additional witness lists with counsel's certification, a description of attempts to resolve the dispute, and any claimed exceptional circumstances stated with particularity; absent exceptional circumstances, it must be filed at least forty-five days before the scheduled trial date.

In the absence of such agreement, which shall not be unreasonably withheld, Plaintiffs' counsel shall file a motion which includes the following: (1) A general description of the Plaintiffs' claims as they relate to product identification and jobsite; (2) A listing of the names of the first fifty (50) witnesses named pursuant to paragraph 3 above (the "basic list"), a separate listing by name and address of the additional witnesses Plaintiffs seek to add, and a certification by Plaintiffs' counsel that counsel has reviewed both lists, that each of the witnesses named thereon is necessary for proper and complete prosecution of the Plaintiffs' claims, and that there are no substitutions or deletions from the lists that are feasible to lower the number of necessary witnesses; (3) A description by Plaintiffs' counsel of the attempts to resolve the matter with Defense counsel; and (4) Absent exceptional circumstances, which must be stated with particularity in the Motion, no Motion will be entertained if filed within forty-five (45) days of the scheduled trial date.

Applies to

Temporary restraining order motion

Must include

proposed order

A temporary restraining order filing should include the motion, supporting affidavits and exhibits, a proposed order, and the complaint when applicable.

The motion, affidavits, exhibits, proposed order, and complaint (if applicable) should be filed with the Clerk of the Court, 462 Cummings Courthouse.

Applies to

Motion

Requests for court action must be made by motion; the court will not act on a letter request.

As required by Md. Rule 2-311(a), all requests to the Court to take action should be by motion. There is no provision for the Court to act in response to a letter.

Applies to

ADR evaluation forms

The parties must complete and return all ADR evaluation forms to the ADR practitioner.

We understand that we are required by the court to complete and return to the ADR Practitioner all ADR evaluation forms.

Applies to

ADR evaluation forms

At the conclusion of ADR, the ADR practitioner must provide the required forms and instructions to the parties and return the completed forms by mail to the court address.

At the conclusion of the ADR, I agree to give to the parties all required ADR evaluation forms and instructions provided by the court and will return the completed forms by mail to 111 N. Calvert Street, Room 248E, Baltimore, MD 21202.

Applies to

Case information report

In civil cases, the plaintiff must file a case information report (CC/DCM 002) with each complaint, subject to the stated administrative-order exemption.

Consistent with Md. Rule 2-111 (except as provided by Administrative Order Altering Exemptions from Information Report Requirement under Rules 2-111 and 2-323 dated December 2, 2005), the plaintiff must file with each complaint a case information report (CC/DCM 002) used to assist the clerk and the court in scheduling actions promptly and efficiently.

Applies to

Scheduling order

A scheduling order or trial/hearing notice must be entered in every Baltimore City civil action expected to proceed to trial.

Scheduling orders or trial/hearing notices are entered in every civil action expected to proceed to trial in Baltimore City.

Applies to

Pretrial memorandum

Each party must file a pretrial memorandum at least five days before the pretrial conference, covering all items (1) through (12) of Md. Rule 2-504.2(b).

All parties shall file no later than five days in advance of the conference a pre-trial memorandum covering in full each of items (1) through (12) of Md. Rule 2-504.2(b).

Applies to

Pretrial statement

Each party must file a pretrial statement before the pre-trial settlement conference.

Each party must file a pretrial statement before the settlement conference.

Applies to

Pretrial memorandum

At least five days before the pre-trial settlement conference, every party must file a pre-trial memorandum covering all 12 items specified in Md. Rule 2-504.2(b).

All parties shall file no later than five days in advance of the conference a pre-trial memorandum covering in full each of items (1) through (12) in Md. Rule 2-504.2(b).

Applies to

Pretrial memorandum

Each party must file a pretrial memorandum at least five days before the pretrial conference, covering all items (1) through (12) of Rule 2-504.2(b).

All parties shall file no later than five days in advance of the conference a pre-trial memorandum covering in full each of items (1) through (12) of Rule 2-504.2(b).

Applies to

Expert designation

Expert designations must include all information specified in Maryland Rule 2-402(g)(1)(A) and (B).

(g) Expert designations shall include all information specified in Rule 2-402(g)(1)(A) and (B).

Applies to

Pretrial memorandum

At least five days before the conference, the parties must file a pre-trial memorandum covering all items (1) through (12) of Maryland Rule 2-504.2(b).

(b) The parties shall file not later than five days in advance of the conference a pre-trial memorandum covering in full each of items (1) through (12) of Rule 2-504.2(b).

Applies to

Identification report

Plaintiff must submit a report identifying each plaintiff's full name, birth date, last four SSN digits, and case status.

Plaintiff shall submit to the court a report identifying each plaintiff by full name, date of birth, last four digits of plaintiff’s SSN, and indicating the status of the plaintiff in this case, i.e, asbestos-related injury victim, spouse of injured party, personal representative/executor/administrator of injured party, child of injured party, etc.

Applies to

Statement of ongoing interest

Plaintiff's counsel must provide a written certification identifying the date and time of direct communication with the client and confirming the client's intent to proceed.

Plaintiff's counsel shall certify in writing that they spoke directly with their client (identifying date and time of the communication) and that the client intends to proceed with the case.

Applies to

Statement of case status

Plaintiff must identify all named defendants and their status, including settlements or dismissals, bankruptcy status and claim submission, and active non-bankrupt defendants.

Plaintiff shall identify all of the named defendants, including i. Each defendant with whom plaintiff has reached resolution of the case, whether by settlement or agreement to dismiss with or without prejudice. ii. Each defendant that is currently in bankruptcy, and whether a claim has been submitted. iii. Each non-bankrupt active defendant.

Applies to

Related proceedings statement

Plaintiff must identify all prior or pending related court or administrative proceedings, provide specified details about each, and list all settlement entities and the type of release received.

Plaintiff shall identify each and every prior or pending court or administrative proceeding brought with the intent of satisfying in whole or in part the damages sustained by plaintiff as a result of an alleged asbestos-related injury, including the forum, case number, parties involved, and current status or outcome of the proceeding. Plaintiff shall include a listing of all entities with whom settlements have been reached, (whether or not that entity was at any time a party to the present case), indicating for each the type of release received.

Applies to

Asbestos case submission

Plaintiff must submit all then-available medical records, a current medical authorization acceptable to the healthcare providers receiving it, existing plaintiff-specific expert reports, and the tests or studies supporting those reports.

Plaintiff shall submit all medical records relating to that plaintiff’s claims then available to plaintiff, and a current medical authorization in a form acceptable to any health care providers to whom said authorization will be sent, together with any existing plaintiff-specific expert reports for that plaintiff, as well as any tests, studies, etc., on which the reports rely.

Applies to

Asbestos case submission

Plaintiff must submit the injured person’s work history, including service dates and alleged asbestos-exposure work sites, and must identify other alleged exposure sites and the dates of exposure.

Plaintiff shall submit a statement of the injured person’s work history, including dates of service and identification of each work site at which exposure to asbestos is alleged. If exposure is alleged at any place other than a work site, plaintiff shall submit a statement identifying each site of exposure with dates of exposure.

Applies to

Asbestos case submission

Plaintiff must identify by name and address each co-worker or other witness relied upon to establish asbestos exposure and state the exposure sites and products known to each witness.

Plaintiff shall identify by name and address all co-workers or other witnesses who will be relied upon to furnish identification of exposure to asbestos of the injured person, including identification of each site and product of which such witness has knowledge.

Applies to

Asbestos case submission

Plaintiff must identify each deposition transcript containing relied-upon co-worker or witness testimony about asbestos exposure.

Plaintiff shall identify each deposition transcript containing testimony of a co-worker or witness that will be relied upon to furnish identification of exposure to asbestos of the injured person.

Applies to

Asbestos case submission

Plaintiff must submit a social-security printout for the exposed plaintiff and, in a secondary-exposure case, for each vector; if a printout is unavailable, plaintiff must submit a signed authorization allowing defendants to obtain it.

Plaintiff shall submit a social security printout for the exposed plaintiff, and, if a secondary exposure case, then in addition for the vector(s) through whom exposure is claimed, or if such a printout is not currently available, then a signed authorization sufficient to permit defendants to obtain it.

Applies to

Written objection

A defendant challenging the sufficiency of plaintiff's submission must file a written objection specifying each challenge ground within 30 days after plaintiff files the submission.

Any defendant who desires to challenge the sufficiency of plaintiff’s submission must file a written objection specifying each ground of challenge not later than thirty (30) days after the filing of plaintiff’s submission.

Applies to

Scheduling order update

Counsel must file a written line identifying agreements that change any date or deadline in the existing Scheduling Order.

Counsel shall file a line detailing any agreements made between Counsel that affect a change in any date or deadline in the existing Scheduling Order.

Applies to

Written statement

Must include

statement of facts

At least five days before the Settlement Conference, each party must submit a written statement addressing specified Rule 2-504.2(b) matters, a list of remaining claims, a list of pending motions, and a confidential pretrial statement containing specified case and settlement information.

Each party shall submit no less than five (5) days in advance of that date: a. A written statement addressing each of the pertinent matters listed in Rule 2-504.2(b); b. A list of all claims (including crossclaims) to which it remains a party; c. A list of all pending motions which it has filed; and d. A confidential pretrial statement containing the following information: brief summaries/description of facts, work histories, factual disputes, legal disputes, case strengths and weaknesses, history of settlement negotiations, reasonable estimated settlement value, and the number of “shares.”

Applies to

Written statement

Each party must file a written statement addressing the matters listed in Maryland Rule 2-504.2(b) no later than five days before the Pretrial Conference.

Pursuant to Maryland Rule 2-504.2(a), each party shall file not later than five days before the conference a written statement addressing the matters listed in Rule 2-504.2(b).

Applies to

Jury instructions

Voir dire and jury instructions must be filed by the scheduled case-management date.

File voir dire, jury instructions.

Applies to

Affidavit of compliance request for judgment

Plaintiff must file an Affidavit of Compliance/Request for Judgment at least 20 days before the initial hearing.

Plaintiff shall file an Affidavit of Compliance/Request for Judgment no later than 20 days before the initial hearing.

Applies to

Notice of settlement

If settlement is reached before the Pretrial Conference, the parties must promptly file a notice of settlement and provide the Transaction Identification Numbers to the Asbestos Case Managers.

If a settlement is reached before the Pretrial Conference, the parties shall promptly file notice of settlement with the Court and provide the Transaction Identification Numbers to the Asbestos Case Managers.

Applies to

Pre judgment attachment request

A pre-judgment attachment request must be filed with the Clerk of the Court in Room 462 Courthouse East with the motion, affidavits, exhibits, and complaint if applicable.

All requests for pre-judgment attachment pursuant to Section 3-303 of the Courts and Judicial Proceedings Article of the Maryland Annotated Code shall be processed as follows: The motion, affidavits, exhibits and complaint (if applicable) shall be filed with the Clerk of the Court, Room 462 Courthouse East.

Applies to

Cross claim

A defendant asserting an indemnity cross-claim, rather than contribution, must file a specific cross-claim pleading or stipulation under the Rules of Civil Procedure.

3. A defendant who wishes to assert a cross-claim for indemnity, as distinguished from contribution, against any other party shall do so by filing a specific cross-claim pleading or stipulation as to same, as provided for under the Rules of Civil Procedure.

Applies to

Claims list

Each party must submit a list of all claims, including crossclaims, to which it remains a party.

b. A list of all claims (including crossclaims) to which it remains a party;

Applies to

Pending motions list

Each party must submit a list of all pending motions that it has filed.

c. A list of all pending motions which it has filed; and

Applies to

Scheduling order change line

Counsel must file a line describing any agreement that changes a date or deadline in the existing Scheduling Order.

Counsel shall file a line detailing any agreements made between Counsel that affect a change in any date or deadline in the existing Scheduling Order.

Applies to

Pleading

Must include

caption

Each electronically filed pleading, paper, or other document, including a multi-case filing, must have a brief but informative title describing the document.

The title of each electronically filed pleading, paper or other document ("paper"), including multi-case filings, shall include a brief but informative description of the paper.

Applies to

Pleading

Must include

caption

The caption must identify the filing parties, the document's nature, the parties against whom relief is sought, and the relief requested.

The caption of the paper shall also contain the following information: i. the party or parties filing the paper; ii. the nature of the paper; iii. the party or parties against whom relief, if any, is sought; and, iv. the nature of the relief sought (e.g., "John Doe's Motion to Compel Discovery and for Sanctions against Jim Smith").

Applies to

Paper

The signature page must identify the attorney, applicable law-firm contact information, and the represented party.

The signature page of any paper filed shall contain the name of the attorney and, if applicable, the name, address, phone number and e-mail address (if available) of the law firm representing the party, and the name of the party on whose behalf the paper is filed.

Applies to

Multi case filing

Must include

caption

A multi-case filing must list all relevant trial-cluster case numbers and individually affected cases and state 'multi-case filing' below the court's name at the top of the caption.

The party shall caption the pleading, paper or document to include all relevant trial cluster case numbers and individually affected cases. Further, the top of the caption, below the Court's name, shall state "multi-case filing."

Applies to

Appeal record

Parties to an appeal must work with and provide the Circuit Court Clerk any materials required by Rule 8-413 that were originally filed electronically.

The parties to an appeal shall work with and provide to the Clerk of the Circuit Court any materials required by Rule 8-413 that were originally filed in an electronic format pursuant to this Order.

Applies to

Expedited trial motion

The court may allow additional time to provide the required expedited-trial materials when an item was not reasonably available when the motion was filed.

The Court may on motion allow Plaintiff additional time to locate and/or provide any of the items listed in subparagraphs (a) through (h) above, to the extent that such item was not reasonably available to Plaintiff at the time of filing.

Applies to

Petition for removal

A claimant may file a Petition for Removal with the Administrative Judge after the case has remained on the Inactive Docket for at least 24 months if the claimant does not meet the minimum removal criteria but contends that a compensable asbestos-related injury exists.

18. Any claimant whose case has been assigned to the Inactive Docket for not less than twenty-four (24) months, and who does not meet the minimum criteria for removal established in paragraph 10, above, but who contends that he or she nonetheless has a compensable asbestos-related injury and should thus be removed from the Inactive Docket, may file a Petition for Removal ("Petition") with the Administrative Judge of the Circuit Court for Baltimore City upon the expiration of that twenty-four month period:

Applies to

Attorney evaluation form

Attorneys must complete an Attorney Evaluation Form immediately after the final mediation conference, mediators must complete an ADR Data Sheet, and the forms should be faxed or mailed to the Civil Mediation Program within seven days after the last session.

Attorneys must complete an Attorney Evaluation Form immediately following the final mediation conference, and Mediators must complete an ADR Data Sheet. All forms should be faxed or mailed to the Civil Mediation Program within seven (7) days of the last mediation session.

Applies to

Document request

Each document-production request must specify a reasonable time, place, and manner for inspecting the documents.

All requests for the production of documents shall specify in the request a reasonable time, place and manner for making the inspection.

Applies to

Paper

Must include

caption

A paper relating to all cases within a case category must use the applicable "All ... Cases" caption.

If a paper relates to all cases within that case category, this fact shall be indicated on the paper by the caption "All Trades Cases," "All Bethlehem Steel Cases," "All Railroad Cases," "All Other Asbestos Cases," or "All Shipyard Cases," as may appropriate.

Applies to

Paper

Must include

caption

A paper relating to all cases within an "Other" subcategory must use the applicable subcategory caption.

If a paper relates to all cases within a subcategory of the "Other" category, then this fact shall be indicated on the paper by the caption "Other-Trades/Sparrows Point," "Other-Plasterers," or "Other-Engineers," as may be appropriate.

Applies to

Paper

Must include

caption

A paper that does not relate to all actions within the applicable case category or subcategory must list the individual docket numbers.

If such paper does not relate to all actions within the case category or subcategory, the individual docket numbers shall be listed.

Applies to

Pretrial order

Before filing the joint master pretrial order, the parties must exchange drafts, identify disputes in writing, and meet to resolve them if any exist.

Prior to filing the Joint Master Pre-Trial Order, the parties will exchange proposed orders, notify each other in writing of disputes and meet to resolve such disputes, if any.

Applies to

Short form complaint

For cases filed on or after the specified dates, a plaintiff may file and, beginning December 1, 1987, must file a Short-Form Complaint identifying alleged Master Complaint causes of action and the docket category and subcategory.

Each Plaintiff who has filed a case on or after January 1, 1987, may file, and on or after December 1, 1987 shall file, a Short-Form Complaint which specifies the causes of action from the Master Complaint which the Plaintiff alleges and which designates the case category and subcategory in which the case is to be docketed.

Applies to

Master service list

The master service list must state its preparation date.

The master service list shall state the date it was prepared.

Applies to

Master service list

Liaison counsel must update the master service lists as necessary.

The master service lists shall be updated as necessary by Liaison Counsel.

Applies to

Interrogatories

The master interrogatories apply to all pending and future actions in the case category and must match the corresponding Baltimore County asbestos-case master set except for corrections of mistakes.

These Interrogatories shall apply to all pending and future actions in that case category, and shall be identical (except for correction of mistakes) to the master set of interrogatories served on the plaintiffs in the corresponding case category under Pre-Trial Order No. 1 governing asbestos cases in Baltimore County.

Applies to

Interrogatories

A previously served master set or an applicable Baltimore City Circuit Court written order controls instead of the general master-interrogatories rule.

Where a master set of interrogatories has already been served upon a plaintiff, or where a written Order has been issued in the Baltimore City Circuit Court requiring that a single master set of interrogatories shall be applicable to all asbestos cases of a Plaintiffs' counsel, then that previous filing or written Order shall control.

Applies to

Defendants master requests for production of documents

Defendants' master document-production requests must apply to all pending and future actions in the corresponding case category and, except for corrections of mistakes, must be identical to the referenced Baltimore County master requests.

These Requests shall apply to all pending and future actions in that case category, and shall be identical (except for correction of mistakes) to the master Requests served on the plaintiffs in the corresponding case category under Pre-Trial Order No. 1 governing asbestos cases in Baltimore County.

Applies to

Defendants master requests for production of documents

A previously served master document-production request, or a written Baltimore City Circuit Court order making a master request applicable to all of plaintiffs' counsel's asbestos cases, controls.

Where a master request for production of documents has already been served upon a plaintiff, or where a written Order has been issued in the Baltimore City Circuit Court directing that a master production request shall be applicable to all asbestos cases of Plaintiffs' counsel, then that previous filing or written Order shall control.

Applies to

Plaintiffs master requests for production of documents

Plaintiffs' master document-production requests must apply to all pending and future actions in the corresponding case category and, except for corrections of mistakes, be identical to the referenced Baltimore County master requests served on defendants.

These Requests shall apply to all pending and future actions in that case category and shall be identical (except for correction of mistakes) to the Master Requests served on the Defendants in the corresponding case category under Pre-Trial Order No. 1 governing asbestos cases in Baltimore County.

Applies to

Pretrial order

Only one pretrial schedule may be used for each month in which cases begin.

There shall only be one Pre-Trial Schedule for every month that cases will begin.

Applies to

Motion

Must include

proposed order

A temporary restraining order filing package should include the motion, affidavits, exhibits, proposed order, and complaint if applicable.

The motion, affidavits, exhibits, proposed order, and complaint (if applicable) should be filed with the Clerk of the Court, 462 Courthouse East.

Applies to

Settlement order

A settlement order must use the court-approved form and may be used only for cases involving claims for money damages.

Settlement orders must be in the form approved by the court and available on its web site and may be used only in cases involving claims for money damages only.

Applies to

Discovery motion

Must include

local rule certificate

The court will only rarely consider a discovery motion unless the certificate required by Md. Rule 2-431 has been filed.

The court only rarely will entertain a discovery motion without filing of the certificate required by Md. Rule 2-431.

Applies to

Motion

A party requesting track reassignment must file a written motion stating the reasons for the request.

A party requesting reassignment must file a written motion specifying the reasons for the request.

Applies to

Motion

Must include

proposed order

A proposed order should accompany every motion.

A proposed order should be attached to every motion.

Applies to

Settlement order

A settlement order in a multi-plaintiff or multi-defendant case must expressly state whether it is a partial or full settlement order.

Any settlement order submitted in a multi-plaintiff or multi-defendant case must indicate explicitly whether it is a partial settlement order (i.e. an order reflecting the settlement of less than all claims) or a full settlement order (i.e. an order reflecting the settlement of all claims, leading to the administrative closing of the file by the Clerk).

Applies to

Settlement order

A full settlement order not executed for all defendants must be accompanied by the dates on which claims against the remaining defendants were finally resolved.

If it is a full settlement order that is not executed on behalf of all defendants, the order must be accompanied by a listing of the dates on which the claims against all other defendants were finally resolved.

Applies to

Settlement order

A noncompliant settlement order will not result in cancellation of court events.

If the settlement order does not comply with these requirements, NO court events will be canceled.

Applies to

Settlement order

A settlement order or other paper resolving all claims must identify the party responsible for open court costs, be filed with the Clerk, and be accompanied by payment of outstanding court costs.

A settlement order or other paper resolving all claims, such as a stipulation of dismissal, must designate which party will pay any open court costs and must be filed with the Clerk. Outstanding court costs must be paid when a settlement order or stipulation of dismissal is filed.

Applies to

Computer generated evidence

A party intending to use computer-generated evidence at trial must comply with Md. Rule 2-504.3(b).

Any party who intends to use computer-generated evidence at trial for any purpose must comply with Md. Rule 2-504.3(b).

Applies to

Notice of agreement

Counsel must file a line identifying agreements that change any date or deadline in the existing scheduling order.

Counsel shall file a line stating any agreements made between Counsel that affect a change in any date or deadline in the existing Scheduling Order.

Applies to

Pre judgment attachment papers

Two copies of the pre-judgment attachment papers should be given to the Clerk for date-stamping and, for a new action, assignment of a case number.

Two copies of these papers should be given to the Clerk to be date-stamped and to receive a case number (if it is a new action).

Applies to

Amended cross claim

Before the automatic dismissal of cross-claims, a Cross-Plaintiff may file an amended cross-claim that states a cause of action, recognizes the dismissal, and states an intent to proceed despite the Plaintiff's dismissal.

At any time between the docketing of the dismissal without consideration and the resulting automatic dismissal without prejudice of all cross-claims in the suit, any Cross-Plaintiff may file with the Court an amended cross-claim which states a cause of action against the Cross-Defendant, which recognizes the dismissal and states the intent to pursue the cross-claim in spite of the dismissal of the Defendant(s) by the Plaintiff.

Applies to

Notice of service of discovery

Separate Notices of Service of Discovery filings are no longer required.

Separate Notices of Service of Discovery filings are no longer required.

Applies to

Request to substitute mediator

By unanimous agreement, the parties may replace the court-appointed mediator within 30 days by submitting a written Request to Substitute Mediator substantially in the prescribed form to the Civil Mediation Program or by fax.

By agreement of all parties to the case, the Court appointed mediator named in the Order for Mediation may be replaced with a new mediator of the parties’ choice within thirty (30) days from the date of the Order for Mediation. Parties must submit a written “Request to Substitute Mediator,” substantially in the form set forth in MD Rule 17-202(g) to the Civil Mediation Program at the address below or by fax.

Applies to

Defendant additional information statement

A defendant may file a statement containing additional pertinent information in plaintiff's submission format within 30 days after plaintiff files the submission.

Any defendant may file a statement with additional pertinent information in the same format as plaintiff’s submission not later than thirty (30) days after the filing of plaintiff’s submission.

Applies to

Dismissal submission alternative

Instead of making the submission, plaintiff may file a stipulation of dismissal or a party-consented motion for dismissal.

In lieu of the submission, plaintiff may file a stipulation of dismissal or a motion for dismissal consented to by the parties.