Court of Common Pleas of Washington County, Pennsylvania Pre-Motion Conference Requirements

CRITICAL

Arguments for all Motions for Summary Judgment shall be heard on the same day.

Arguments for all Motions for Summary Judgment shall be heard on the same day.

CRITICALCivil cases

Unless the Court orders otherwise, the moving party must file its brief with the motion, and the responsive party must file its brief at least ten days before argument.

(4) Unless otherwise ordered by the Court, the brief of a moving party shall be filed contemporaneously with the motion. The brief of the responsive party shall be filed at least ten (10) days prior to the argument.

CRITICALCivil cases

Unless the Court orders otherwise, the moving party must file its brief at least 20 days before the motion proceeding, and the responsive party must file within 10 days thereafter.

Unless otherwise ordered by the Court, the brief of the moving party shall be filed at least twenty (20) days prior to the proceeding on the motion. The brief of the responsive party shall be filed within ten (10) days thereafter.

CRITICAL

Unless the Court orders otherwise, the moving party must file its brief with the motion, and the responsive party must file its brief at least ten days before argument; this rule does not apply to briefs supporting or opposing a Pa.R.C.P. 227.1 post-trial-relief motion.

(4) Unless otherwise ordered by the Court, the brief of a moving party shall be filed contemporaneously with the motion. The brief of the responsive party shall be filed at least ten (10) days prior to the argument. (5) This rule shall not apply to any brief filed in support of, or in opposition to, a motion for post-trial relief pursuant to Pa.R.C.P. 227.1.

CRITICAL

Objections to jurisdiction, venue, joinder, or standing must be filed and presented to the assigned judge, who will order briefing and schedule argument.

(a) Objections to jurisdiction, venue, joinder of parties, and standing shall be filed and presented to the judge to whom the case is assigned. The Court shall order a briefing schedule and schedule argument on the objections.

CRITICAL

If all parties have not consented, the moving party must present the motion in Motions Court after complying with applicable court rules.

If consent has not been obtained from all parties, the moving party shall present the motion in Motions Court after complying with all applicable rules of court.

CRITICAL

Before presenting an unconsented motion, counsel and/or the parties must confer in an attempt to resolve its subject matter.

Prior to the presentation of an unconsented motion, counsel and/or the parties shall confer to attempt to resolve the subject matter of the motion.

CRITICAL

Before a sanctions motion, counsel must confer or attempt to confer with all interested parties to resolve or narrow the issues.

Any motion for sanctions shall be governed by Wash.L.R.C.P. 208.2(e) and 208.3(a), and the motion shall contain a certification that counsel has conferred or attempted to confer with all interested parties in order to resolve the matter or narrow the issues to be reviewed by the Court.

CRITICAL

For discovery motions, the moving party must confer with all interested parties and comply with the referenced requirements for a Certificate of Compliance.

For all discovery motions, see Wash. L. R. Civ. P. 208.2(3)(a) for the requirements to confer with all interested parties and the filing of a Certificate of Compliance.

CRITICAL

Before moving to modify a case management order, counsel or an unrepresented party must confer in an effort to reach agreement.

Prior to filing a motion to modify any case management order, all counsel, or a party if unrepresented, shall confer in an effort to reach agreement on the proposed modification.

CRITICAL

At the conclusion of discovery, the Court must hold a status conference that includes setting a filing date and briefing schedule for a summary-judgment motion.

(1) At the conclusion of discovery, the Court shall hold a conference to review the status of the case, including: (a) any outstanding issues concerning discovery; (b) disposing of pending motions; (c) settling the case and using special procedures to assist in resolving the dispute when authorized by statute or rule of court; (d) setting forth a date for the filing of a motion of summary judgment pursuant to Pa.R.C.P. 1035.2, and issuing a briefing schedule; and (e) setting forth a date for the scheduling of a pre-trial conference.

WARNINGCivil cases

After summary-judgment responses are filed, any party may move for an argument date, and all summary-judgment arguments must be heard on the same day.

After the responses to the Motions for Summary Judgment have been filed, any party may present a motion for argument date. Arguments for all Motions for Summary Judgment shall be heard on the same day.

WARNINGCivil cases

Argument on preliminary objections will not be scheduled until the 20-day period to amend as of right has expired.

Argument on Preliminary Objections are not scheduled until after the twenty-day window to amend as of right has expired.

WARNINGCivil cases

The Argument Court notice may modify the default briefing schedule, will identify the schedule in effect, and should be reviewed to confirm the applicable deadlines.

Local Rule L-210 contains a default briefing schedule. This briefing schedule may be modified by the argument court notice. The Argument Court notice will always indicate if the default briefing schedule or an alternate briefing schedule is being utilized for that Argument Court. Ensure that you review the notice when you receive it to confirm your briefing schedule.

WARNING

After responses to summary judgment motions are filed, any party may move for an argument date.

After the responses to the Motions for Summary Judgment have been filed, any party may present a motion for argument date.

WARNINGCivil cases

Motions for judgment on the pleadings and summary judgment are not set for argument until the 30-day response period has expired.

Argument on Motions for Judgment on the Pleadings and Motions for Summary Judgment are not set until after the thirty-day window to file a response has expired.

INFO

Responses and briefs are not required for motions, but a party may file a brief when it anticipates the Court will wish to consider one.

This Court specifically declines to adopt the alternative procedures set forth in Pa.R.C.P. 208.3(b), imposing mandatory requirements for the filing of a response or brief with respect to any motions. Note: A party may file a brief when it is anticipated that the Court will wish to consider a brief before deciding an issue; however, there is no requirement to do so.