Courtesy copies are required for all covered filings. Details: delivery as directed. Courtesy copies must be submitted if required, following directions in Section 6.
Judge Nicholas Jon Ganjei's rules set a pre-motion procedure for protective order. Parties must jointly confer in good faith on protective order terms before filing a motion for entry of a protective order.
Judge Nicholas Jon Ganjei's rule states these limits: 5000 words; 2000 words. Excludes caption, table of contents, table of authorities, signature blocks, and certificates. Motions and responses limited to 5000 words; replies limited to 2000 words. Sur-replies prohibited without permission. Word count certificate required. Exclusions: caption, TOC, TOA, signature, certificates. Word limit extensions rarely granted.
Judge Nicholas Jon Ganjei's rule states these limits: 2 pages. Pre-motion letters for discovery/scheduling disputes are limited to 2 pages.
Judge Nicholas Jon Ganjei's formatting rule includes binding tabbed 3-ring, exhibits/attachments tabbed at right margin, use smallest possible binder, max binder size 4 inches, divide into multiple binders if needed, and mark with file-stamped cm/ecf docket number unless urgent. Hard copy courtesy copies must be tabbed at the right margin, stored in binders no larger than 4 inches, and marked with the CM/ECF docket number unless urgent.
The rule requires proposed order. All non-dispositive motions must include a proposed order.
The rule requires certificate of service. Removing parties must file a certificate of service and additional required information within ten days of removal.
Parties may contact Judge Nicholas Jon Ganjei's chambers by phone only as allowed by the rule. All emergency-related communications must be made through the Case Manager via telephone.
A motion to seal is required for covered sealed filings before Judge Nicholas Jon Ganjei. Process: file redacted on ecf and file unredacted to clerk. Motion to seal required for any pleading, brief, or supporting material under seal; file unredacted material under seal, motion to seal with redacted version on public docket, and label under-seal filings with SEALED designation.
Judge Nicholas Jon Ganjei's rules specify what an adjournment or extension request must include. The request must include reason for request and proposed new dates. Modification of the Scheduling Order requires a motion establishing good cause, and requested changes must include recommended dates for all adjusted deadlines after the first modification.
Yes. Judge Nicholas Jon Ganjei requires bundling for covered papers. Joint Pretrial Orders filed on CM/ECF must have Section 19 pretrial filings attached as exhibits.
All emergency-related communications must be made through the Case Manager via telephone.
All non-dispositive motions must include a proposed order.
Courtesy copies must be submitted if required, following directions in Section 6.
Inquiries about cases assigned to Judge Ganjei must be directed to the Case Manager by phone at (713) 250-5656.
Removing parties must file a certificate of service and additional required information within ten days of removal.
Emergency motions must be filed via CM/ECF, then a copy emailed to Case Manager upon filing; extension motions are not considered emergencies.
All informal communications to the Court must go through the Case Manager, using specified methods based on the purpose of the communication.
Counsel may not initiate contact with Law Clerks except to return a message, and may only discuss the specific subject of the Law Clerk’s inquiry.
For status inquiries, first check the District Court website and CM/ECF system; direct filing questions to the Office of the Clerk, not the Court.
Letters or emails sent to the Court must copy all parties using the same delivery method; such letters/emails must not be filed on the CM/ECF system.
Courtesy copies are only required for trial deposition excerpts with objections (highlighted), sealed documents, joint pretrial orders, and other trial material.
Trial deposition excerpts with objections must have the objections and corresponding questions/answers highlighted.
Hard copy courtesy copies must be tabbed at the right margin, stored in binders no larger than 4 inches, and marked with the CM/ECF docket number unless urgent.
Electronic courtesy copies must be emailed to the Case Manager; hard copies mailed or hand-delivered with a transmittal letter (not filed); copy all parties on transmittal letters without attachments.
Counsel seeking to receive CM/ECF notices must file a notice of appearance; inclusion in a pleading’s signature block is insufficient.
Pro hac vice admission applications must include an averment of the applicant’s familiarization with court procedures and Local Rules.
All parties must sign the joint discovery/case management plan, plaintiff’s counsel must file a single completed plan, and the plan must comply with Rule 26(f).
Modification of the Scheduling Order requires a motion establishing good cause, and requested changes must include recommended dates for all adjusted deadlines after the first modification.
Parties may extend discovery deadlines by agreement without court approval if the extension does not impact the Scheduling Order or other court-set deadlines.
The Court will accommodate vacation and family-related continuance requests if made well in advance of the hearing or trial.
A party may file a motion requesting a ruling on a pending motion, which must explain the case posture, the pending motion, and the need for expedited attention.
Parties must jointly confer in good faith on protective order terms before filing a motion for entry of a protective order.
Motions for entry of a protective order must include the proposed order as an exhibit.
Parties must have a person with detailed electronic data knowledge available at conferences on electronic discovery disputes.
Motion to seal required for any pleading, brief, or supporting material under seal; file unredacted material under seal, motion to seal with redacted version on public docket, and label under-seal filings with SEALED designation.
Continuances based on failure to complete discovery are disfavored, with potential sanctions for discovery failures.
Parties must attempt to resolve discovery and scheduling disputes without court intervention; bad faith may result in cost shifting.
Lead counsel must personally confer on all discovery and scheduling disputes before involving the Court.
Initiating letter (max 2 single-spaced pages) required to bring discovery or scheduling dispute motions; responsive letters allowed, no replies.
Initiating letter not required for discovery relief motions against nonparties.