Courtesy copies are required for settlement letters. Details: delivery when notified, by chambers notification. Courtesy copies of settlement letters are not routinely accepted.
The rule does not state that a pre-motion letter is required, but it sets the applicable pre-motion procedure. Rule 37 meet-and-confer required before filing motions in limine.
Judge Keri L. Holleb Hotaling's formatting rule includes file format docx, separate documents, and editable. Court prefers separate editable Word documents for pretrial items.
The rule requires court order compliance. Settlement conference date can only be changed by motion; letter exchange deadlines are court orders requiring chambers approval for amendments.
The rule requires judge name, case number, legal argument, and statement of facts. Settlement demands/offers must be realistic and compromise from prior positions; punitive damages excluded from demands.
Parties may contact Judge Keri L. Holleb Hotaling's chambers by email only as allowed by the rule. Final pretrial conference held 10 days before trial; lead counsel must attend.
Requests should be made at least 60 calendar days in advance when this rule applies before Judge Keri L. Holleb Hotaling. Daubert motions must be filed 60 days before trial unless court sets different schedule.
Yes. Judge Keri L. Holleb Hotaling's rules include a junior lawyer participation incentive. Junior lawyers are encouraged to substantively participate in settlement conferences.
Settlement conference date can only be changed by motion; letter exchange deadlines are court orders requiring chambers approval for amendments.
Courtesy copies of settlement letters are not routinely accepted.
Settlement demands/offers must be realistic and compromise from prior positions; punitive damages excluded from demands.
Parties must be willing to negotiate from their written settlement positions; no standing on initial demands/offers.
Settlement letters must include history of all prior demands/offers with dates; non-compliant letters may be rejected.
Settlement positions must be compromised from prior positions; compromise must be monetary, not just removal of non-monetary terms.
Court conducts ex parte communications about settlement letters; telephonic communications docketed, email follow-ups may not be.
Parties must promptly notify Court if settlement reached, conference rescheduled, or deemed unnecessary.
Settlement conferences may be in-person, virtual (Cisco WebEx), or hybrid; details in conference order.
Junior lawyers are encouraged to substantively participate in settlement conferences.
Parties with settlement authority must attend settlement conference in person.
Insured parties must bring insurer representative with settlement authority.
Uninsured corporate parties must bring authorized representative with settlement authority.
Telephone participation is not acceptable for settlement conference.
Non-English speaking parties must provide interpreter for settlement conference.
Interpreter must provide real-time word-for-word translation.
Settlement statements are inadmissible in discovery and trial.
Final Pretrial Order must be submitted 14 days before trial date.
Court prefers separate editable Word documents for pretrial items.
Daubert motions must be filed 60 days before trial unless court sets different schedule.
Motions in limine must be filed 21 days before trial; responses due 14 days before trial.
Motions in limine discouraged; avoid boilerplate and undisputed matters.
Rule 37 meet-and-confer required before filing motions in limine.
Requests for expedited transcripts must be made 7 days before trial.
Final pretrial conference held 10 days before trial; lead counsel must attend.