Circuit Court for Baltimore City Filing Timing and Cure Windows

An expedited guardianship petition filed by 11:00 a.m. will receive a hearing on the seventh day after filing.

A hearing will be scheduled for the seventh day following the filing of the petition provided that the petition is filed by 11:00 a.m.

Court-appointed counsel’s answer and report must be filed before the hearing, with a courtesy copy delivered to the hearing judge’s chambers at least one day beforehand.

The answer and report of court-appointed counsel for the allegedly disabled person must be filed with the Clerk of the Court before the hearing and a courtesy copy should be delivered to the hearing judge’s chambers at least one day prior to the hearing.

When a bond is required for a pre-judgment attachment, counsel must post it with the Clerk before receiving the order and writs.

If a bond is required, it must be posted with the Clerk of the Court before counsel can receive the order and the writs.

When a temporary restraining order is issued with a bond, counsel must post the bond with the Clerk before receiving a copy of the order.

If a temporary restraining order is issued and a bond is imposed, the bond must be posted with the Clerk of the Court before counsel can receive a copy of the order.

Summary-judgment and other dispositive motions must be filed by D+155, even if discovery remains incomplete.

D+155 | Deadline to file motions for summary judgment and other dispositive motions, including motions addressing product identification and/or exposure issues. This deadline shall not be affected by discovery being incomplete.

Oppositions or responses to summary-judgment and other dispositive motions are due by D+170.

D+170 Oppositions/responses to motions for summary judgment and other dispositive motions due.

Replies to summary-judgment and other dispositive motions are due by D+180.

D+180 Replies to motions for summary judgment or other dispositive motions due.

Motions in limine must be filed by D+207, and responses are due ten days afterward.

D+207 Deadline for filing motions in limine. Response to motions in limine due ten (10) days thereafter.

A show-cause objection must be filed no later than the close of business on Tuesday, March 30, 1993.

Any party wishing to object to this amendment shall show cause, in a writing not to exceed three (3) pages, filed with the Court, courtesy copy to chambers, and served upon all other counsel, not later than the close of business on Tuesday, March 30, 1993.

Written objections to removal from the inactive docket are due within 30 days after delivery of the removal request to defense liaison counsel.

Within thirty (30) days of the date a Form B and documentation requesting removal of a case from the Inactive Docket are delivered to Defendants' Liaison Counsel, any defendant objecting to the requested removal shall set forth those objections in a writing not to exceed two pages per claim.

A properly sued and served defendant has 30 days after the notice-of-service date to answer or respond after removal from the inactive docket.

Once a case is removed from the inactive docket, defendants who have been properly sued and served shall have 30 days from the date of "Notice of Accomplishment of Service of Court Order" within which to answer or respond to the complaint.

A written objection must be filed no later than the close of business on September 10, 1993.

Any party that objects to this amendment shall show cause why the amendment should not be ordered, in writing not to exceed three (3) pages, filed with the Court, courtesy copy to chambers, and served upon all other counsel, not later than the close of business on September 10, 1993.

A written objection must be filed no later than the close of business on Friday, April 2, 1995.

Any party wishing to object to this amendment shall show cause, in a writing not to exceed three (3) pages, filed with the Court, courtesy copy to chambers, and served upon all other counsel, not later than the close of business on Friday, April 2, 1995.

Deadline

3 working days

The notice of accomplishment of service must be filed within three working days after receipt of Form B and supporting documentation.

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.

A defendant objecting to removal from the inactive docket must provide written objections within 30 days after delivery of the removal materials to Defendants' Liaison counsel.

Within 30 days of the date a Form B and documentation requesting removal of a case from the inactive docket are delivered to Defendants' Liaison counsel, the defendant objecting to requested removal shall set forth those objections in a writing not to exceed two pages per claim.

An objection to removal from the Inactive Docket is deemed filed by all defendants once filed.

Once an objection is filed to a plaintiff's request for removal from the Inactive Docket the objection will be deemed filed by all defendants.

Plaintiff has 30 days from filing the objection to attempt to cure it.

The plaintiff shall have 30 days from the date of filing the objection to attempt to cure the objection.

Deadline

3 working days

A notice of accomplishment of service must be filed with the court within three working days after receipt of the Form B and documentation, certifying that email service occurred.

Defendants' Liaison Counsel is required to (1) acknowledge receipt of the information to plaintiffs' counsel; (2) serve via email a complete copy of each form B and documentation and a copy of the service list received from the Plaintiffs' counsel to all Defendants' counsel on Plaintiffs' service list; and (3) file a notice of accomplishment of service of with the Court which certifies the service via email occurred within (3) working days of the receipt of the Form B and documentation from Plaintiffs' counsel.

A defendant must serve written objections to removal within 14 days after service of the Form B and supporting documentation, and each objection may not exceed two pages per claim.

Within 14 days of the date a Form B and documentation requesting removal of a case from the inactive docket are served on defendants, any defendant objecting to the requested removal shall set forth those objections in writing not to exceed two pages per claim.

A filed objection to removal is deemed filed by all defendants.

Once an objection is filed to a plaintiff’s request for removal from the Inactive docket the objection will be deemed filed by all defendants.

The plaintiff has 30 days from the filing of an objection to attempt to cure it.

The plaintiff shall have thirty (30) days from the date of the filing the objection to attempt to cure the objection.

If the objection is not cured within 30 days, counsel must meet and confer within the following 15 days to attempt to cure it.

If the objection is not cured within ===== PAGE 36 ===== the 30 day period, the plaintiff’s counsel and the defendant’s counsel who filed the objection to removal shall meet and confer within fifteen (15) days thereafter to attempt to cure the objection.

If an objection remains uncured seven days after the meet-and-confer, the requesting and objecting counsel must jointly submit one status report covering all disputed removal requests.

If the objection remains uncured seven (7) days after this meeting, the plaintiff’s counsel who is requesting removal, and the defendant’s counsel objecting to removal, shall submit a single status report to the Court for all of the requests for removal that are still in dispute.

A notice of settlement must be filed promptly with the court after settlement is reached before the pretrial conference.

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.

Counsel and representatives are excused from the pretrial conference only if the settlement documents are filed at least three days before the scheduled conference.

Unless such documents are filed at least three (3) days prior to the scheduled Pretrial Conference date, counsel and representatives must attend the Pretrial Conference.

An electronically filed document is considered served and filed when completely submitted and given an authorized date and time.

Any paper or document filed electronically shall be considered as served and filed with the Clerk of the Court when it is completely submitted and receives an authorized date and time.

Electronic filings submitted before midnight are deemed timely for filing deadlines.

Any paper or document filed electronically before midnight shall be deemed filed for purposes of filing deadlines.

An electronically filed document is docketed when the clerk accepts it, with the docketed date matching the authorized date and time.

Any paper or document electronically filed shall be considered docketed by the Clerk of the Court for all purposes contemplated by the Maryland Rules upon acceptance by the Clerk; the docketed date shall be the same as the authorized date and time.

Unless the court orders otherwise, a party has 18 days to respond to an electronically filed motion.

Unless otherwise provided by an order of court, a party has eighteen (18) days to respond to an eFiled motion.

Replies to summary-judgment and other dispositive motions are due by D+180.

D+180 Replies to motions for summary judgment or other dispositive motions due.

Motions in limine must be filed by D+207, and responses are due ten days after that filing deadline.

D+207 Deadline for filing motions in limine. Response to motions in limine due ten (10) days thereafter.

Defendants must file motions challenging discovery adequacy by D+14; plaintiffs must respond within five days, and any conference request must be filed with the motion or response.

D+14 Defendants file any motions contesting the adequacy of existing discovery responses. Plaintiffs shall respond within five (5) days. Any request for conference with the Court shall be filed with the motion or response.

By D+20, direct defendants must identify parties against whom contribution or set-off claims will be pursued; claims against unidentified parties are dismissed.

D+20 Direct Defendants identify parties against whom contribution/set-off claims will be pursued. Claims against any party not so identified are hereby dismissed.

Direct defendants must serve third-party complaints no later than D+34.

D+34 Last day for direct Defendants to serve third-party complaints.

Defendants must notify plaintiffs of discovery disputes and file related motions within 15 days after receiving discovery.

Defendants must give notice to Plaintiffs of any dispute contesting the adequacy of discovery and file motions within fifteen (15) days of receipt of discovery.

Plaintiffs must respond to defendants' discovery-dispute notice within 5 days.

Plaintiffs shall respond within five (5) days.

A discovery dispute does not justify delaying other discovery, and filing a dispositive, protective-order, sanctions, or discovery-compulsion motion does not extend the discovery deadline.

The existence of a discovery dispute as to any matter will not justify delay in completing other discovery. The filing of any dispositive motion or any motion for protective order, for sanctions, or to compel discovery, will not result in an extension of the discovery deadline.

Plaintiffs must notify defendants of discovery disputes and file related motions within 15 days after receiving discovery.

Plaintiffs must give notice to Defendants of any dispute contesting the adequacy of discovery and file motions within fifteen (15) days of receipt of discovery.

Defendants must respond to plaintiffs' discovery-dispute notice within 5 days.

Defendants shall respond within five (5) days.

Summary-judgment and other dispositive motions addressing product identification or exposure must be filed by D+155, regardless of whether discovery is complete.

D+155 Deadline to file motions for summary judgment and other dispositive motions, including motions addressing product identification and/or exposure issues. This deadline shall not be affected by discovery being incomplete.

Oppositions or responses to summary-judgment and other dispositive motions are due by D+170.

D+170 Oppositions/responses to motions for summary judgment and other dispositive motions due.

The required settlement-conference submissions must be made at least five days before the conference.

Each party shall submit no less than five (5) days in advance of that date:

The required pretrial written statement must be filed 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).

Each currently participating defendant must file and serve the required service-designation information within 15 days after entry of the order.

Within fifteen (15) days of the entry of this Order, each defendant who is presently a party in any present case shall file with the Court and serve upon defendants' liaison counsel and all plaintiffs' counsel with whom they have present cases pending, a designation, by name, address and title, of the person who is to be served with documents and filings made in accordance with this Order.

A motion for exemption from mandatory mediation must be filed within 30 days of the Order for Mediation unless good cause justifies a later filing.

The motion must be filed within 30 days of the date of the Order for Mediation, or provide good cause for later filing.

Defendants represented by Whiteford, Taylor & Preston may jointly file one Short-Form Answer within 30 days after the last of them is served.

The Defendants represented by Whiteford, Taylor & Preston may file one joint Short-Form Answer to the Short-Form Complaint within thirty (30) days after the last of these Defendants have been served with the Short-Form Complaint;

A plaintiff's action is deemed filed and commenced under Rule 2-101 when that plaintiff's Short-Form Complaint is filed.

a particular Plaintiff's action shall be deemed filed and commenced for purposes of Rule 2-101 when that Plaintiff's Short-Form Complaint is filed.

A supplemental joint master pretrial order must be filed according to the master pretrial schedule.

A Supplemental Joint Master Pre-Trial Order shall be filed in accordance with the Master Pre-Trial Schedule.

Covered counsel must exchange and discuss proposed pretrial schedules of less than 425 days no later than fifteen days after the Order's date.

All counsel with cases that are scheduled for trial in a month less than 425 days after the signing of the Master Pre-Trial Order, or cases that should be scheduled under the requirements of the "Schedule," must submit to one another and discuss proposed Pre-Trial schedules of less than 425 days no later ===== PAGE 30 ===== than fifteen days after the date of the Order.

Counsel must submit the pretrial schedule and any unresolved disagreements to the court within three weeks after a trial date is set.

Within three weeks of the setting of a trial date, counsel must submit a Pre-Trial Schedule to the Court, along with any irreconcilable disagreements for the Court's resolution.

The parties must file a joint master pretrial order for each case category sixty days before the category's first trial.

A Joint Master Pre-Trial Order shall be filed by the parties for each case category sixty days before the date of the first trial of cases in that category.

Summary judgment motions and known motions in limine must be filed 50 days before the scheduled X date.

Summary Judgment Motions and known Motions in Limine filed by any party X - 50 days

Oppositions to summary judgment motions and motions in limine must be filed 35 days before the scheduled X date.

Oppositions to Summary Judgment Motions and Motions in Limine filed X - 35 days

Replies to oppositions to summary judgment motions and motions in limine must be filed 25 days before the scheduled X date.

Reply to Oppositions to Summary Judgment Motions and Motions in Limine filed X - 25 days

The pretrial order, voir dire, and final motions in limine must be filed 20 days before the scheduled X date.

Pre-Trial Order and Voir Dire filed; final Motions in Limine filed X - 20 days

Pre-trial settlement conference statements must be filed with the Clerk’s Office at least five days before the conference.

Maryland Rule 2-504.2 requires that pre-trial settlement conference statements be filed with the Clerk’s Office no later than five (5) days before the conference.

A motion to appear by telephone at a pre-trial settlement conference must be filed at least 21 days before the conference.

Motions shall be filed not later than twenty-one (21) days before the conference.

A motion for exemption from mandatory mediation must be filed within 60 days of the Order for Mediation unless the party shows good cause for a later filing.

Any party may file a motion for exemption from mandatory mediation. The motion must be filed within 60 days of the date of the Order for Mediation, or provide good cause for later filing.

Defendants must respond to a motion contesting the adequacy of discovery within five days, and any request for a hearing must be filed with the motion or response.

*Plaintiffs must file any motions contesting the adequacy of discovery. Defendants shall respond within five (5) days. Any request(s) for hearing with the Court shall be filed with the motion(s) or response(s).*

A response to a motion in limine must be filed within ten days after the motion.

Response to any motions in limine shall be filed within ten (10) days, thereafter.

Defense counsel must respond within ten days after receiving the motion and state all objections specifically and completely.

Upon receipt of the Motion, Defense counsel must respond within ten (10) days setting forth specifically and completely such objections that they have.

Dispositive motions in Track 6 Lead Paint cases must be filed three months before trial.

Dispositive Motions filed 3 months before trial

In Track 7 Tax Sale Foreclosures, amended pleadings, joinder of additional parties, and service of all defendants must be filed within eight months.

Amended pleadings, Joinder of additional Foreclosures) parties, and service of all defendants filed within 8 months

In Track 7 Tax Sale Foreclosures, the Affidavit of Compliance or Request for Judgment must be filed within thirteen months.

Affidavit of Compliance/Request for Judgment filed within 13 months

In Track 9 Baltimore City In Rem Tax Foreclosures, written objections and the Affidavit of Compliance must be filed no later than twenty days before the initial hearing.

Written objections and Affidavit of Compliance filed no later than 20 days before initial hearing

The pretrial memorandum is due no later than five days before the pretrial conference.

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).

The pretrial memorandum is due no later than five days before the pretrial conference.

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).

All discovery and discovery disputes must be resolved within eight months after the scheduling order.

All discovery including full resolution of all discovery disputes shall be completed no later than eight months from date of this order

Plaintiffs must identify experts within three months after the scheduling order.

Plaintiff(s) shall identify experts three months after date of this order-

Defendants must identify experts within six months after the scheduling order.

Defendant(s) shall identify experts six months after date of this order-

Plaintiffs must identify rebuttal experts within seven months after the scheduling order.

Plaintiff(s) shall identify rebuttal experts seven months after date of this order-

Amended pleadings must be filed within five months after the scheduling order.

Any amended pleadings shall be filed no later than five months from date of this order-

Additional parties must be joined within five months after the scheduling order.

Any additional parties must be joined no later than five months from date of this order-

Dispositive motions, motions to exclude expert testimony, and Daubert-Rochkind hearing requests must be filed within nine months after the scheduling order.

Any dispositive motion(s), motion(s) to exclude expert testimony, or requests for a Daubert-Rochkind hearing shall be filed no later than nine months from date of this order-

Mediation must be completed within nine months after the scheduling order.

Mediation must be completed within 9 months from date of this order-

Motions in limine must be filed no later than 20 days before trial.

Any motions in limine shall be filed no later than 20 days before trial.

Defendants must file motions challenging discovery adequacy within 28 days after receiving discovery, and plaintiffs must respond within 8 days; any hearing request must be filed with the motion or response.

Defendants must file any motions contesting the adequacy of discovery within twenty-eight (28) days of receipt of discovery. Plaintiffs shall respond within eight (8) days. Any request(s) for hearing with the Court shall be filed with the motion(s) or response(s).

Plaintiffs must file motions challenging discovery adequacy, defendants must respond within 5 days, and any hearing request must be filed with the motion or response.

Plaintiffs must file any motions contesting the adequacy of discovery. Defendants shall respond within five (5) days. Any request(s) for hearing with the Court shall be filed with the motion(s) or response(s).

The deadline for filing summary-judgment, other dispositive, or case-removal motions is X-96, remains fixed despite incomplete discovery, and requires service on adversaries through File&Serve.

X-96 Deadline to file any motions for summary judgment, other dispositive motions, or any motion seeking to remove an individual case from a consolidated trial group. Any such motion shall be served on adversaries via the File&Serve electronic filing system. NOTE: This deadline shall not be affected by discovery being incomplete.

Plaintiff must file an Affidavit of Compliance/Request for Judgment no later than one year after the case is filed.

Plaintiff shall file an Affidavit of Compliance/Request for Judgment no later than one year from the date of filing- .

A request to extend the Affidavit of Compliance/Request for Judgment deadline must be made by motion filed with the clerk at least 90 days before the deadline.

Any request to extend the time to file the Affidavit of Compliance/Request for Judgment must be made by motion filed with the clerk of the court no later than 90 days before the date it is due.

Defendants must notify plaintiffs within 10 days if service is contested.

Defendants shall notify Plaintiffs within ten (10) days of any case in which service is contested.

Plaintiffs and consenting defendants must request a settlement conference within 74 days after the order is signed.

74 days from the signing Deadline for Plaintiffs and any consenting Defendants to of the Order1 request a settlement conference with the Court.

Plaintiffs must produce claim forms and related exposure materials by 88 days and supplement the information every 30 days thereafter.

88 days Plaintiffs produce all claim forms and any exposure affidavits or statements submitted to any bankruptcy entity or trust, in connection with or during the pendency of this lawsuit, and supplement such information every thirty (30) days, thereafter.

Plaintiffs must answer the defendants’ joint interrogatories, respond to document requests, or submit updated discovery responses by 88 days.

88 days Deadline for Plaintiff(s) to submit answers to Defendants’ joint interrogatories (which interrogatories are not to exceed 45 in number, including subparts) and responses to document requests (which requests for documents are not to exceed 60 in number, including subparts), or to submit updated/amended discovery responses if previously filed.

Defendants must notify plaintiffs of discovery-adequacy disputes within 15 days after receiving discovery.

Defendants must give notice to Plaintiffs of any dispute contesting the adequacy of discovery within fifteen (15) days of receipt of discovery.

Defendants must file discovery-adequacy motions within 28 days of receiving discovery, and plaintiffs must respond within 8 days.

Defendants must file any motions contesting the adequacy of discovery within twenty-eight (28) days of receipt of discovery. Plaintiffs shall respond within eight (8) days.

Plaintiff must file a list of anticipated fact witnesses by 97 days.

97 days Deadline for Plaintiff to file a list of fact witnesses whom Plaintiff anticipates calling at the trial of the case:

Defendants must file motions concerning discovery disputes within 15 days after receiving the discovery.

Defendants must give notice to Plaintiffs of any dispute contesting the adequacy of discovery and file motions within fifteen (15) days of receipt of discovery.

Plaintiffs must respond to discovery-dispute motions within five days.

Plaintiffs shall respond within five (5) days.

Plaintiffs must file motions concerning discovery disputes within 15 days after receiving the discovery.

Plaintiffs must give notice to Defendants of any dispute contesting the adequacy of discovery and file motions within fifteen (15) days of receipt of discovery.

Defendants must respond to discovery-dispute motions within five days.

Defendants shall respond within five (5) days.

Summary-judgment and other dispositive motions are due on the D+155 case-management deadline.

D+155 Deadline to file motions for summary judgment and other dispositive motions, including motions addressing product identification and/or exposure issues.

Oppositions or responses to summary-judgment and other dispositive motions are due on the D+170 case-management deadline.

D+170 Oppositions/responses to motions for summary judgment and other dispositive motions due.

The mediator must return the ADR data sheet within seven days after the last mediation conference by delivery or fax.

For Statistical Purposes Only: The mediator must return this form, within seven (7) days after the last mediation conference, to Jeff Trueman, Esquire, Civil Mediation Program Deputy Director, Room 248 Courthouse East, 111 N. Calvert Street, Baltimore, Maryland 21202 or fax to: (410) 396-7378.

If the parties cannot agree and an electronic filing cannot be submitted or processed because of specified technical failures, the court may order a late filing permitted.

If an agreement cannot be reached however, and an electronic filing cannot be filed because of (1) inaccessibility to Vendor, (2) downtime of a Participant's Internet Service Provider, (3) an error in the transmission of the pleading, paper or document to the Vendor which was unknown to the filing Participant, or (4) a failure to process the electronic filing when received by the Vendor, the court may enter such order as is necessary to permit the late filing of the pleading, paper or document.

A living mesothelioma plaintiff may request an expedited trial schedule and trial date within 180 days after the case is initially filed.

A living plaintiff who asserts that he or she has been diagnosed with malignant mesothelioma may, within 180 days of the initial filing of that case, request this Court to set that case in for an expedited trial schedule and trial date.

Defendants must notify plaintiffs within the D+7 deadline of any case in which service is contested.

D+7* Defendants notify Plaintiffs of any case in which service is contested.

A defendant objecting to removal may file an objection within 14 days after service of the Petition.

19. Within fourteen (14) days after service of a Petition filed in accordance with Paragraph 18, any defendant objecting to the removal of such claim may file a

Each individual defendant may serve no more than 20 nonduplicative supplemental interrogatories and must file them by the applicable schedule date.

Each individual Defendant may serve a set of Supplemental Interrogatories, not to exceed twenty (20) in number, subject to the conditions that such Supplemental Interrogatories not be duplicative and that they are timely filed in accord with the dates set forth in the applicable Master Pre-Trial Schedule or Phase-In Pre-Trial Schedule.

Each plaintiff may serve no more than 20 nonduplicative supplemental interrogatories on each individual defendant and must file them by the applicable schedule date.

Each Plaintiff may serve on each individual Defendant a set of Supplemental Interrogatories, not to exceed twenty (20) in number, subject to the conditions that such Supplemental Interrogatories not be duplicative and are timely filed in accord with the dates set forth in the applicable Master Pre-Trial Schedule or Phase-In Pre-Trial Schedule.

Expert reports and Maryland Rule 2-402(e)(1)(A) material must be provided promptly when available and no later than the date specified in the Master Pre-Trial Schedule.

All Expert Reports and all Md. Rule 2-402(e)(1)(A) material is to be provided by the parties to all opposing counsel promptly when available but no later than the date indicated in the "Master Pre-Trial Schedule."

The scheduling order may be modified by written motion filed within 15 days after its date.

This order is subject to modification, including the scheduling of the pre-trial and settlement conference and trial, upon a written motion for modification filed within 15 days of the date of this order.

Eastern Time applies to all pleadings, papers, and other documents regardless of counsel’s location.

Regardless of the location of counsel, the Vendor and this Court will apply Eastern Time to all pleadings, papers and other documents.