Judge Jennifer Muench-McElfresh
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
Court-wideMotion
Court-wideMotion To Seal
Court-wide- Upon Filing
Suggestion Of Complex Litigation
Court-wideDocument Format Requirements1 rule
Each assembled set of trial materials must be placed in a binder or cover.
Each set shall be placed in a binder or cover.
Document Filing Requirements3 rules
Pretrial statements must include the parties' claims and defenses, admitted and stipulated facts, disputed factual and legal issues, supporting authority, and witness information.
Counsel shall prepare pretrial statements which shall contain the following: (1) A concise statement of the claims and defenses of the parties; (2) Those facts established by admissions in the pleadings, admissions by discovery, and stipulations of counsel; (3) The contested issues of fact; (4) The contested issues of law, together with counsel's citations of authority for his position; (5) The names and addresses of witnesses, together with a brief statement of the subject matter of each witness's testimony and a brief summary of each witness's expected testimony;
Document Type
Pretrial Statement
Pretrial statements must also identify expert witnesses, list and mark trial exhibits, identify pending motions in limine, list special damages, estimate trial time, report settlement status, and provide requested jury instructions and interrogatories.
(6) The names, addresses, and qualifications of the expert witnesses expected to testify at trial, together with a brief statement of the subject matter of each expert witness's testimony; (7) A list of exhibits which counsel intends to offer into evidence, marked as follows: (a) Joint exhibits with Roman numerals, (b) Plaintiffs exhibits with Arabic numerals. (c) Defendant's exhibits with letters; (8) Motions in limine not previously filed; (9) A list of all special damages being requested; (10) Counsel's expectation of the trial time needed to present his side of the case; (11) The status of settlement negotiations including specific demands and/or offers; (12) Requested jury instructions (other than boilerplate), and jury interrogatories.
Document Type
Pretrial Statement
Objections to exhibits or other trial material must be written, filed by 4:00 p.m. on the indicated date, contemporaneously delivered to chambers, and briefly state the grounds with supporting authority.
Objections to the admission of exhibits or to the use of other material must be made in writing and filed before 4:00 p.m. on the date indicated and a copy of the objection shall be contemporaneously delivered to the court in chambers. Objections shall state briefly the grounds for the objection and a brief citation of authority.
Document Type
Exhibit Or Material Objection
Filing & Service rules
Filing Timing and Cure Windows
Separate trial-material sets must be delivered to opposing counsel and the court before 4:00 p.m. on the indicated date.
Separate sets of materials shall be delivered to opposing counsel and to the court before 4:00 p.m. on the date indicated.
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Pretrial statements must be delivered to the court in chambers by 4:00 p.m. on the indicated date, and the deadline may be extended only with leave of court.
The pretrial statements shall be delivered to the court in chambers no later than 4:00 p.m. on the date indicated. This deadline is firm and cannot be extended except by leave of court.
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Objections to the admission of exhibits or use of other trial material must be made in writing, filed before 4:00 p.m. on the indicated date, and copied contemporaneously to the court in chambers.
Objections to the admission of exhibits or to the use of other material must be made in writing and filed before 4:00 p.m. on the date indicated and a copy of the objection shall be contemporaneously delivered to the court in chambers.
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Counsel must file all transcripts and video depositions with the Clerk's office before trial.
Counsel is responsible for insuring that all transcripts and video depositions are filed with the Clerk's office prior to trial.
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Filing Bundling Requirements
Counsel must assemble complete sets of trial materials, place each set in a binder or cover, and deliver separate sets to opposing counsel and the court by 4:00 p.m. on the indicated date.
Counsel shall assemble sets of all depositions, documents, photographs and other items to be used at trial. Each set shall be placed in a binder or cover. Separate sets of materials shall be delivered to opposing counsel and to the court before 4:00 p.m. on the date indicated.
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Chambers Communication Rules
Counsel must contact the Clerk's office before trial to ensure the availability of the depositions.
This rule requires counsel to contact the Clerk's office prior to trial to insure the availability of the depositions.
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