Motion to Dismiss must include Certificate of Conference or will be struck.

Non-dispositive motions must include Certificate of Conference or will be struck.

Sealing discouraged; redaction preferred; leave of court required for sealed filings.

All motion facts must be in numbered paragraphs with specific record citations.

Case citations must use Westlaw format, not Lexis.

Motion must include argument and citations; separate memorandum not allowed.

Summary judgment motions are disfavored in cases without jury trial rights and should be limited to purely legal issues.

Complete diversity required for federal jurisdiction in diversity cases; removing party must demonstrate it.

For individuals, notice of removal must plead citizenship, not just residence.

For LLCs and partnerships, citizenship must be traced through all members/partners to establish diversity jurisdiction.

If LLC/partnership members are unknown after diligent investigation, citizenship may be alleged on information and belief.

Corporations are citizens of their state(s) of incorporation and principal place of business (nerve center test).

Removing party must supplement record with all state court pleadings, filings, and docket sheet.

Failure to properly plead citizenship of all parties may result in remand without further notice.

Motions filed in state court before removal must be re-filed in federal court.

Pretrial objections to exhibits required; failure to raise at Pretrial Conference may waive objections at trial.