Courtesy copies are required only when requested by chambers. Lodging documents via email allowed for submissions under 50 pages; over 50 pages must be delivered in person.
The rule does not state that a pre-motion letter is required, but it sets the applicable pre-motion procedure. Meet and confer by phone/video/in-person required before raising discovery disputes.
Judge D. Thomas Ferraro's rule states these limits: 5 pages. Confidential ENE statements must be submitted 7 days before ENE, max 5 pages.
Judge D. Thomas Ferraro's rules include formatting requirements. Proposed orders cannot include attorney or law firm captions.
The rule requires all parties present, claims adjusters present, principal attorneys present, and authorized representatives present. All parties and authorized representatives must attend ENE
The rule requires cm ecf filing. Joint Discovery Plan must be filed on CM/ECF 7 days before ENE/CMC.
Parties may contact Judge D. Thomas Ferraro's chambers by phone only as allowed by the rule. During depositions, suspend and meet/confer immediately; call chambers for immediate ruling if available.
Judge D. Thomas Ferraro's rules specify what an adjournment or extension request must include. The request must include reason for request and emergency nature. Requests within 24 hours require a phone call. Requests to continue ENE, MSC, or VSC require joint call/email to Chambers after meeting and conferring.
Counsel must meet and confer before requesting in-person conference.
Counsel responsible for client participation in ENE.
Laptops/desktops recommended over mobile devices for Zoom.
Court uses Zoom for ENE and CMC conferences.
Court emails Zoom invitations before ENE.
Parties can request in-person ENE/CMC via joint call or email to chambers.
Participants must maintain professionalism and full attention during ENE.
Participants should ensure devices are charged or plugged in for Zoom.
Chambers communication limited to administrative matters only
Chambers contact information provided
CM/ECF technical issues directed to Help Desk
Must review all court resources before contacting chambers
Law clerks limited to discussing issues only with counsel or pro se parties
ENE/CMC requirements in separate court order
ENE scheduled after all significant defendants answer
All parties and authorized representatives must attend ENE
Authorized representatives must have full settlement authority
Corporate entities must send authorized representative with settlement authority
Government entities excused if attorney has primary responsibility and negotiation authority
No excuses for required party attendance except exceptional circumstances with opposing counsel conference
Confidential ENE statements must be submitted 7 days before ENE, max 5 pages.
ENE statements over 50 pages must be delivered physically to chambers.
Joint Discovery Plan must be filed on CM/ECF 7 days before ENE/CMC.
Requests to continue ENE, MSC, or VSC require joint call/email to Chambers after meeting and conferring.
Joint Motion required for continuances/hearing amendments, filed 7+ days before deadline.
Filing Joint Motion for Continuance does not excuse compliance with existing deadlines.
Joint Motion for Continuance follows Local Rule 7.2 format, no proposed order needed.
Joint Motions for Continuance require supporting declarations by counsel.
Scheduling Order modifications require showing of good cause under Fed. R. Civ. P. 16(b).
Amendments extending pre-trial conference or trial dates may be denied.