Judge Frank G. Forchione
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Exhibits
- 1 copy
Adjournments
Court-wideRequest must include
Document Format Requirements1 rule
Exhibits must be marked before trial with official stickers, using party-specific numbers or letters and double letters when the defendant has more than 26 exhibits.
All exhibits shall be marked before trial with official exhibit stickers. Plaintiff shall mark exhibits with numbers and Defendant shall mark exhibits with letters. If there are multiple parties, numbers or letters shall be used followed by the party’s last name (i.e. “1- Miller,” or “A-Jones”). If Defendant has more than twenty-six (26) exhibits, double letters shall be used (i.e., AA, BB, CC, etc.).
Document Filing Requirements3 rules
Trial briefs must include a statement of facts, controlling-law discussion, proposed-witness list and testimony descriptions, a proposed-exhibit index with descriptions, and anticipated evidentiary-issue discussion.
Trial briefs shall include the following: a) a statement of facts; b) a discussion of the controlling law; c) a list of proposed witnesses, along with a brief description of the subject matter of the testimony of each witness; d) an index of all proposed exhibits containing a brief description of each exhibits; and e) a discussion of any evidentiary issues likely to arise at trial.
Document Type
Trial Brief
Counsel must exchange copies of all exhibits and exhibit indexes no later than two working days before trial.
Counsel shall exchange copies of all exhibits and exhibit indexes no later than TWO (2) working days before the scheduled trial date.
Document Type
Exhibits
When the parties anticipate needing a stipulated protective order, they should submit a proposed order within 30 days after the court’s Case Management Order.
If so, a proposed Stipulated Protection Order should be submitted within 30 days of the Court’s Case Management Order.
Document Type
Stipulated Protective Order
Filing & Service rules
Filing Timing and Cure Windows
Video-deposition transcripts and objection logs stating each objection and citing relevant authority must be filed no later than one week before trial.
Transcripts of video depositions to be used at trial, along with objection logs stating the reasons for each objection and citations of any relevant authority, shall be filed no later than one week prior to trial.
Page 1 | JUDGE FORCHIONE’S TRIAL PROTOCOL
Trial briefs must be filed at least one week before the scheduled trial date.
Counsel shall file trial briefs at least ONE (1) week prior to the scheduled trial date listed above. Trial briefs shall include the following:
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Motions in limine must be filed four weeks before trial unless good cause requires filing closer to trial.
Motions in Limine: 4 weeks prior to trial (unless good cause necessitates filing closer to the time of trial)
Page 2 | Court Issued Dates
A dispositive-motion deadline must fall at least 75 days before trial.
Dispositive motion deadlines must be at least 75 days prior to trial.
Page 2 | Case Management Deadlines
Filing Fees and Waivers
Required court cost deposits must be paid within five days of the order's entry date.
All required court cost deposits must be paid within FIVE (5) days of the date of this entry.
Page 1 | JUDGE FORCHIONE’S TRIAL PROTOCOL
Courtesy Copy Requirements
One copy of all proposed trial exhibits and a descriptive exhibit index must be furnished to the court no later than two working days before trial.
ONE (1) copy of all exhibits proposed to be introduced at trial, along with an index of the exhibits containing a brief description of such exhibit, shall be furnished to the Court no later than TWO (2) working days before the scheduled trial date.
Page 2 | JUDGE FORCHIONE’S TRIAL PROTOCOL