Pre-Motion Conference Requirements
2510 rules across 21 courts
Many courts and judges require a conference, letter, joint statement, or meet-and-confer process before certain motions may be filed. These procedures are common for discovery disputes, dispositive motions, and emergency applications. Requirements vary: one source may require a short pre-motion letter, another may require a joint statement, and another may require a conference call or in-person appearance. Filing a motion without completing the required steps can result in rejection, continuance, or an order striking the filing.
Southern District of New York
View all rules for SDNY.Initial case management conference scheduled within one month of Answer filing.
Parties must file joint letter and proposed case management plan one week before initial pretrial conference.
Discovery disputes require good faith meet-and-confer with opposing party before filing.
Unresolved discovery disputes may be filed as joint letter (max 4 pages) requesting informal conference.
Pre-motion letter required (max 3 pages) for certain motions, describing motion and consent status.
Opposition pre-motion letter (max 3 pages) due within 3 business days if motion not on consent.
Summary judgment pre-motion letters must include Rule 56.1 statements.
Summary judgment pre-motion letters due one week before Post-Discovery Conference.
Parties must confer with adversary before seeking TRO unless Rule 65(b) requirements are met.
TRO applications must be scheduled at mutually agreeable time when adversary doesn't consent.
Qualified immunity motions must be filed within 60 days with plaintiff's deposition testimony; no extensions granted.
Letter-motions are permitted for extensions, adjournments, pre-motion conferences, and nondispositive matters; other motions require judicial authorization.
Discovery motions (Fed. R. Civ. P. 26-37, 45) require a pre-motion letter-motion for an informal conference before being heard, unless the presiding judge's individual practices dictate otherwise.
Criminal conferences/proceedings by telephone or video; counsel must submit letter one week before
Oral argument requests must be included in moving papers, not separate motions.
FLSA cases must be referred to mediation within 60 days before case management conference.
If no settlement, parties must promptly meet and confer under Rule 26(f) for case management conference.
Discovery disputes require meet-and-confer before filing 3-page letter-motion
Summary judgment motions due 30 days after discovery closes; opposition due 2 weeks after service; reply due 1 week after opposition
Expert testimony exclusion motions must be filed within 30 days of discovery close, with specific briefing schedule and single motion requirement.
Pre-motion conference required for most motions except specified exceptions.
Pre-motion letter (max 3 pages) required from both parties with 3 business day response time.
All motions and applications must follow the Court's Individual Practices, including pre-motion conference requirements.
Parties are limited to one summary judgment motion unless they obtain prior court approval.
Parties must confer in good faith (including Lead Trial Counsel) before raising discovery disputes with the Court.
Pre-motion conferences are not required except for discovery disputes, which follow Paragraph 5 procedures.
Sur-reply memoranda are not accepted without prior court permission.
Pre-motion conference required before filing summary judgment motions.
Summary judgment pre-motion conference request must be made in writing within 14 days after close of fact discovery.
Motions in limine must be filed 4 weeks before trial; responses due 1 week after filing.
Substitution of counsel requires conference with Deputy Clerk.
Rule 26(f) conferences must occur at least 21 days before initial conference.
Pre-motion conference required before filing summary judgment motions.
Pre-motion conference required before most motions, with 3-page letter and 3-day response deadline.
Discovery disputes require good faith in-person or telephonic meet-and-confer before filing.
Opposition to discovery Letter-Motion due in 3 business days; reply due in 1 business day.
Motions in limine must be fully briefed one week before Final Pretrial Conference.
Pre-motion conferences required except for specific motion types.
Discovery motions require good faith conference before filing.
Pre-motion letter (max 3 pages) required for non-discovery motions.
Sur-replies require prior court permission.
Pre-motion conferences required for motions before Judge Gorenstein except for pro hac vice, reconsideration, certain appeal motions, recusal, and show cause applications.
Discovery motions require good faith conference first; moving party must certify conference details in 5-page letter; opposing party responds promptly.
Pre-motion letter (max 3 pages) required before motions to dismiss.
Pre-motion letter required for most motions except specified exceptions.
Two sets of pre-motion letters required for motions to dismiss.
Plaintiff response to first pre-motion letter due within 5 business days.
Second pre-motion letter set for motions to dismiss must be filed with Court.
Pre-motion letter for Rule 12(b) motions stays time to answer until further order.
Non-moving party must notify Court within 10 days of motion to dismiss filing whether amending pleading.
Pre-motion letter required for summary judgment motions
Opposition letters for summary judgment pre-motion must be filed within 5 business days
Pre-motion letter required before filing most motions, with specific exemptions listed.
Attorneys at pre-motion conferences must have authority to commit to motion schedules and address settlement conference participation.
Daubert motions to exclude expert testimony must be made by the dispositive motions deadline and are not treated as motions in limine.
Opposition filings must be submitted within one week after the pretrial order but no fewer than three days before trial.
If parties unavailable for call, send 2-page letter to chambers describing efforts and proposed motion.
Discovery disputes require meet-and-confer before filing letter motion (max 4 single-spaced pages).
Pre-motion conference required before filing motions, with specific exceptions.
Principal trial counsel must appear at all scheduling and motion conferences.
Parties must send letter requesting pre-motion conference for motions not excepted.
Opposing parties must reply within 2 business days of receiving pre-motion letter.
If pre-motion exchange fails, defendant must notify court in writing with copies of correspondence.
Non-compliant memoranda will be returned without additional time if prejudicial.
Orders to show cause or motions for injunctive relief require notice to opposing counsel and an agreed briefing schedule.
Discovery disputes require letter-motion (max 1,050 words) with 5-business-day response limit
Extensions and adjournments must be requested via letter-motion, not proposed stipulations or orders.
Sur-reply memoranda require prior Court permission
Pre-motion letter required for summary judgment motions.
Expert testimony exclusion motions must be filed by dispositive motion deadline.
Prompt motion for default judgment required when party fails to respond.
Clerk's Certificate of Default required before default judgment motion.
Pre-motion conferences required for motions before/referred to Judge Gorenstein, except for specified exceptions.
Discovery motions require good faith conference with opposing parties before filing.
Conference request letter must certify that required conference took place.
Conference request letter must include conference date/time, duration, participants, adversary positions, and impasse notification.
Letter motions required for adjournments/extensions/pre-motion conferences; 3-day response time; courtesy copy to Chambers
Discovery disputes require meet-and-confer process before filing 3-page letter motion on ECF.
Opposing party may respond to discovery letter motion within 3 business days (max 3 pages).
Pre-motion letter (max 3 pages) required for certain motions, describing grounds and consent status.
Opposition pre-motion letter (max 3 pages) due within 3 business days if motion not on consent.
Must confer with adversary before filing TRO unless Rule 65(b) requirements are met.
Discovery disputes must first be resolved by party conference, then 3-page letter-motion allowed
Opposition papers due within 30 days; reply papers due within 2 weeks
Discovery disputes require good-faith meet and confer before a letter motion; the letter is limited to 3 single-spaced pages and must certify that meet and confer occurred.
Before filing a Rule 12(b) or 12(c) motion, the moving party must notify plaintiff and offer a chance to amend; if declined, the notice of motion must include a specific certification statement.
A pre-motion conference is required before filing any motion, except motions by incarcerated pro se litigants, reconsideration, new trial, motions in limine, and time-certain federal rule motions.
Pre-motion conference request letters are limited to 3 single-spaced pages and must summarize the motion basis; each opposing party has 3 business days to respond with up to 3 pages.
Motions in limine are filed with the pretrial order; oppositions are due two weeks later; no replies without court permission.
Pre-motion conference required for most civil motions except specified exceptions.
Pre-motion letter limited to 3 pages.
Response to pre-motion letter due within 3 business days, max 3 pages.
Response letters must address moving party's arguments; no reply letters allowed.
Affidavits/exhibits generally prohibited in pre-motion letters; required for amendment motions.
Joint discovery dispute letter (max 5 pages) required before discovery motion.
Separate or successive discovery dispute letters will not be read.
Parties must confer before filing joint discovery dispute letter.
Joint letter must describe issues, positions, and supporting authority.
Party may submit letter without opposing party's contribution if no response within 72 hours.
Opposing party must file letter position within 7 business days of pre-motion conference request.
Discovery motions require informal conference with Court before filing.
Pre-motion conference (3-page letter) required before summary judgment motions.
Non-moving party has 10 days to notify Court about amended pleading after motion to dismiss.
Moving party has 21 days after amended pleading to file answer, new motion to dismiss, or rely on original motion.
Rule 26(f) conferences must occur at least 21 days before initial conference.
Pre-motion conference required before filing summary judgment motions.
Pre-motion conference required before most motions, with 3-page letter and 3-day response deadline.
Discovery disputes must first be resolved through good faith meet and confer.
Failed discovery disputes require joint call to Chambers for teleconference with Court.
Pre-motion teleconference required before filing Motion to Strike
Expert testimony disputes must be raised at status conference after fact discovery.
Summary judgment motions generally not available in non-jury cases without good cause.
Motions require pre-motion conference except motions in limine.
Pre-motion conference required for all motions except specific enumerated exceptions.
Discovery motions require informal conference and strict meet-and-confer compliance.
Pre-motion letter required (max 3 pages) with 3 business day response deadline
Counsel must meet for at least one hour to discuss settlement 14 days before filing joint pretrial order
Summary judgment motions require pre-motion letter within 14 days after fact discovery closes.
Motions in limine must be filed after discovery closes but before pretrial submission date; pre-motion letter waived.
Pre-motion letter required for all motions except discovery motions, motions by order to show cause, and motions by incarcerated pro se litigants
Pre-motion letter must detail legal/factual basis and proposed schedule
Response to pre-motion letter due within 4 business days
Response to pre-motion letter for motion to dismiss must state if seeking leave to amend
Pre-motion letter for Rule 12(b) motion stays time to answer or move
Pre-motion letter must state date of any scheduled conference in first paragraph
Discovery dispute letter must include Rule 37(a)(1) certification and full discovery materials
Response to discovery dispute letter due within 4 business days with case law and affidavits
Motions in limine must be filed within 21 days of discovery completion and responded to within 14 days.
Discovery disputes require letter-motion (max 1,050 words) with 5-business-day response limit
All motions and applications must follow the Court's Individual Practices, including pre-motion conference requirements.
Substitution of counsel requires letter-motion on ECF to schedule conference.
Bail modification requests must be filed as letter-motions on ECF with consent indication.
Bail appeals require conference and submission of transcripts/submissions 24 hours before.
Discovery disputes must first be resolved by party conference, then 3-page letter-motion allowed
Opposition papers due within 30 days; reply papers due within 2 weeks
Discovery disputes require good faith confer with opposing party, including Lead Trial Counsel conference.
Non-moving party must notify intent to amend within 10 days of motion to dismiss.
Only one summary judgment motion allowed without prior Court approval.
Expert testimony exclusion motions must be filed by dispositive motion deadline, not as motions in limine.
Default judgment must be sought by motion on ECF, not by order to show cause.
Opposition papers must be filed within 30 days; reply papers within 2 weeks.
Discovery disputes require meet-and-confer before filing 3-page letter-motion
Summary judgment motions due 30 days after discovery closes; opposition due 2 weeks after service; reply due 1 week after opposition
Expert testimony exclusion motions must be filed within 30 days of discovery close, with specific briefing schedule and single motion requirement.
Discovery disputes must be resolved by conference before filing letter-motion (max 3 pages).
Motions in limine require certification of good faith conference between parties before filing.
Post-discovery dispositive motions require letter submission per Rule 4(A), with opposition due 3 business days later.
Pre-motion conference required before filing motion for summary judgment.
Pre-motion conference required before filing summary judgment motions.
Summary judgment pre-motion conference request must be made in writing within 14 days after close of fact discovery.
Motions in limine must be filed 4 weeks before trial; responses due 1 week after filing.
Motion briefing limited to three rounds: supporting, opposing, and reply.
Pre-motion conference required for summary judgment and dispositive motions, to be requested in writing at least 2 weeks before deadline.
Discovery disputes require conference before filing letter-motion (max 3 pages)
Pre-motion conference required only for motions to dismiss, amend, or summary judgment.
Motions in limine: opposition due 1 week after service, reply due 3 days after opposition, fully briefed 2 weeks before trial.
Discovery disputes require meet-and-confer, then 3-page letter-motion with certification, response within 3 business days.
Pre-motion conference required for most motions except specified exceptions; 3-page letter and 5-day response.
Qualified immunity motions must be filed within 60 days with plaintiff's deposition testimony; no extensions granted.
Discovery disputes require meet-and-confer before filing letter motion (max 4 single-spaced pages).
If parties unavailable for call, send 2-page letter to chambers describing efforts and proposed motion.
One week before conference, file joint Case Management Plan and Scheduling Order on ECF, plus joint letter and email courtesy copy of pleadings.
Good faith meet-and-confer required before filing discovery dispute letter-motion.
Good faith meet-and-confer required before TRO application unless Rule 65(b) requirements met.
Pre-motion conferences required only for discovery-related motions.
Motions in limine opposition due within 7 days, replies not permitted.
Responses to pretrial memorandum due within one week.
Motion for default judgment required under FRCP 55(b)(2) and Local Rule 55.2(b); order to show cause not permitted.
Pre-motion conferences not required except for discovery motions and summary judgment motions.
Good-faith conference required before filing discovery disputes; Court will not consider disputes without this requirement met.
Opposing party must notify Court within 1 business day and file response within 3 business days; reply letters not permitted.
Pre-motion conference required for summary judgment/expert testimony motions, requested 3 weeks before post-discovery pretrial conference.
Expert testimony exclusion motions must meet dispositive motion deadline, not treated as in limine.
Discovery disputes require letter-motion (max 3 pages) and 5-day response.
Substitution of counsel requires conference with Deputy Clerk.
Pre-motion letter (max 750 words, single-spaced) required before motions to dismiss.
Pre-motion conference required for non-incarcerated pro se cases.
Pre-motion conference generally required
Pre-motion conference required for dispositive motions, with pre-motion letter due at least two weeks before conference.
Parties must confer on discovery disputes before contacting the Court.
Pre-motion conference required for most motions with 10 business day notice and 1,200 word limit
Letter communication required for certain motions with 1,200 word limit and 7 day response
Pre-motion letter required for motions to dismiss (no pre-motion conference required).
Pre-motion conference required for most motions (except specified exceptions); moving party must submit 3-page letter explaining basis for anticipated motion.
Pre-motion conference required before most motions (except specified exceptions).
Pre-motion letter (max 3 pages) required to arrange conference.
Opposing party must submit 3-page letter at least one week before pre-motion conference.
Discovery motions require informal conference with Court before filing, following meet-and-confer rule.
Motions in limine must be fully briefed one week before Final Pretrial Conference.
Motions require pre-motion conference except motions in limine.
Summary judgment motions must request pre-motion conference within 14 days of fact discovery close.
Pre-motion conference for summary judgment must be requested within 14 days of fact discovery close.
Pre-motion letter required for most motions except specified exceptions.
Two sets of pre-motion letters required for motions to dismiss.
Plaintiff response to first pre-motion letter due within 5 business days.
Second pre-motion letter set for motions to dismiss must be filed with Court.
Pre-motion letter for Rule 12(b) motions stays time to answer until further order.
Non-moving party must notify Court within 10 days of motion to dismiss filing whether amending pleading.
Pre-motion letter required for summary judgment motions
Opposition letters for summary judgment pre-motion must be filed within 5 business days
Opposition papers due within 30 days; reply papers due within 2 weeks.
Counsel must meet face-to-face for 1 hour within 14 days of responsive pleading to discuss settlement.
Joint letter (max 4 pages) required for discovery disputes after unsuccessful meet-and-confer.
Pre-motion letter required at least 4 days before conference.
Criminal conferences/proceedings by telephone or video; counsel must submit letter one week before
Initial case management conference scheduled within one month of Answer filing.
Parties must file joint letter and proposed case management plan one week before initial pretrial conference.
Discovery disputes require good faith meet-and-confer with opposing party before filing.
Unresolved discovery disputes may be filed as joint letter (max 4 pages) requesting informal conference.
Pre-motion letter required (max 3 pages) for certain motions, describing motion and consent status.
Opposition pre-motion letter (max 3 pages) due within 3 business days if motion not on consent.
Summary judgment pre-motion letters must include Rule 56.1 statements.
Summary judgment pre-motion letters due one week before Post-Discovery Conference.
Parties must confer with adversary before seeking TRO unless Rule 65(b) requirements are met.
TRO applications must be scheduled at mutually agreeable time when adversary doesn't consent.
FLSA cases must be referred to mediation within 60 days before case management conference.
If no settlement, parties must promptly meet and confer under Rule 26(f) for case management conference.
Motions in limine must be filed via ECF with specific briefing deadlines.
Opposition papers due within 4 weeks; reply papers due within 2 weeks of opposition.
Discovery disputes require good faith in-person or telephonic meet-and-confer before filing.
Opposition to discovery Letter-Motion due in 3 business days; reply due in 1 business day.
Must meet and confer in good faith before filing discovery dispute; letters/emails alone insufficient
Discovery disputes must be filed as Letter-Motion (max 1,050 words) after meet and confer
Summary judgment motions against pro se litigants must comply with Local Civil Rule 56.2 notice requirements.
Motions to dismiss or judgment on pleadings against pro se litigants must serve and file notice under Local Civil Rule 12.1 when referring to matters outside pleadings.
Pre-motion conferences required for motions before/referred to Judge Gorenstein, except for specified exceptions.
Discovery motions require good faith conference with opposing parties before filing.
Conference request letter must certify that required conference took place.
Conference request letter must include conference date/time, duration, participants, adversary positions, and impasse notification.
Joint letter required within 14 days of discovery close for summary judgment motions.
Discovery motions require pre-motion conference with Court.
Discovery motions require informal conference with Court before filing.
Pre-motion conference required for most motions except specified exceptions.
Pre-motion letter via ECF (max 3 pages) required to arrange pre-motion conference.
Opposing party must respond via ECF (max 3 pages) within 3 business days.
Letter-motions must be filed using the letter-motion option for specific requests
Discovery motions require good faith meet-and-confer in real time before filing.
Discovery letter-motions must certify meet-and-confer and detail conference specifics.
Discovery letter-motions must include verbatim disputed requests and responses.
Pre-motion letter required for summary judgment motions (14 days after discovery closes)
Discovery disputes require meet-and-confer before filing 5-page ECF letter motion; responsive letters due within 3 business days.
Discovery disputes require meet-and-confer, then 3-page ECF letter-motion with 3-day response time.
Pre-motion conference required for all motions except specified exemptions.
Pre-motion letter limited to 3 pages; responses limited to 3 pages within 3 business days.
Pre-motion conference required only for discovery motions under Rules 26-37 or Rule 45.
Good faith meet-and-confer required in person or by phone before discovery motions.
Responsive letters to discovery motions due within 3 business days.
Opposition to letter-motions due within 3 business days; reply within 1 business day.
Opposition and reply papers for formal motions follow Local Civil Rule 6.1.
Agreed briefing schedules must be approved by Court in notice of motion or letter-motion.
Modifications to agreed briefing schedules require Court approval by letter-motion.
Alternate/new briefing schedules require Court approval or default to Local Civil Rule 6.1.
Sur-replies require prior Court permission.
Pre-motion conference required for all motions except specific enumerated exceptions
Pre-motion conference required for Rule 12(b)/(c) motions with specific statement requirement
Oral argument requests must be made by letter after motion is fully briefed
Motions in limine must be filed with proposed pretrial order; oppositions due within 2 weeks; no replies allowed.
Pre-motion letters required for most motions before Judge Willis except specified exemptions
Discovery disputes require meet-and-confer, then 3-page letter motion, 3-day response window, waiver for late response
Non-discovery pre-motion conferences require letter motion following Individual Practice I.B requirements
Parties must not attend the pre-conference phone call.
Discovery disputes require conference before filing letter-motion (max 6 pages)
Pre-motion conferences required for motions before Judge Gorenstein except for pro hac vice, reconsideration, certain appeal motions, recusal, and show cause applications.
Discovery motions require good faith conference first; moving party must certify conference details in 5-page letter; opposing party responds promptly.
Pre-motion letter (max 3 pages) required before motions to dismiss.
Pre-motion conference required for discovery motions per Local Civil Rule 37.2.
Pre-motion conference required for most motions with specific exemptions.
Pre-motion letter required, limited to 3 pages, stating basis for anticipated motion.
Opposing party must submit response letter within 3 business days, limited to 3 pages.
TRO applications require notice to adversary unless notice would cause immediate and irreparable injury.
Discovery disputes require good-faith meet-and-confer before filing letter-motion; responses due within 2 business days.
Summary judgment motions must be submitted within 30 days after discovery closes unless otherwise ordered.
Pre-motion conference required for summary judgment motions filed before discovery closes.
Response to pre-motion letter limited to 2 pages and due within 3 days.
Motion briefing is limited to three rounds: opening, opposition, and reply.
Pre-motion letter required before filing most motions, with specific exemptions listed.
Attorneys at pre-motion conferences must have authority to commit to motion schedules and address settlement conference participation.
Daubert motions to exclude expert testimony must be made by the dispositive motions deadline and are not treated as motions in limine.
Opposition filings must be submitted within one week after the pretrial order but no fewer than three days before trial.
Motions in limine are exempt from pre-motion conference requirements.
Summary judgment motions require a written request for pre-motion conference within 14 days of the close of fact discovery.
Pre-motion conference requests for summary judgment motions must be made within 14 days after fact discovery closes.
Parties must submit a joint letter proposing summary judgment briefing schedules within 14 days of close of discovery before filing the motion.
Discovery motions require a pre-motion conference per Local Rule 37.2.
Opposition papers due 30 days after motion service; reply papers due 14 days after opposition receipt.
Defendant must file and serve Pretrial Statement 14 days after plaintiff's statement service.
Discovery disputes require good faith conferral with Lead Trial Counsel participation, 2-business-day response requirement, and 10-business-day waiting period before filing with the Court.
Discovery motions require good faith real-time conference before filing.
Opposition to letter-motions due within 3 court days; reply within 2 court days.
Pre-motion letters limited to 3 pages; opposition must respond within 3 business days.
Non-moving party must state intent to amend during pre-motion conference for motions to dismiss.
Moving party must provide electronic copy of Rule 56.1 Statement to all parties (except pro se cases).
Settlement conference required 14 days before joint pretrial order filing
Motions in limine require certification of good faith conference with opposing counsel before filing.
Motions to dismiss in fully counseled cases require pre-motion letter with arguments and case law, staying the answer deadline.
Pre-motion conference letters limited to 3 pages; responses also limited to 3 pages within 7 days.
Pre-motion conference required for Rule 12(b)/(c) motions except pro se cases, with mandatory statement in notice of motion if no amendment agreement.
Discovery disputes require good faith in-person/phone meet-and-confer, then ECF letter-motion with required content; responses due 3 business days.
Letter-motion oppositions due 3 business days after moving letter, replies due 1 business day after opposition; alternate schedules require court approval.
Formal motion briefing due per Local Civil Rule 6.1 unless court approves party-agreed alternate schedule.
Sur-reply memoranda require prior court permission to be accepted.
Parties are limited to one summary judgment motion unless they obtain prior court approval.
Parties must meet and confer in good faith before raising discovery disputes with the court.
Reply letters to discovery dispute letters are not permitted.
Pre-motion conferences are required only for discovery and summary judgment motions.
Within 14 days of fact discovery close, parties must request scheduled pretrial conferences serve as pre-motion conferences for summary judgment, submitting a 3-page single-spaced letter with other parties responding within one week.
Parties must confer in good faith (including Lead Trial Counsel) before raising discovery disputes with the Court.
Pre-motion conferences are not required except for discovery disputes, which follow Paragraph 5 procedures.
Sur-reply memoranda are not accepted without prior court permission.
File a letter via ECF to Chambers for order of reference to Magistrate Judge upon first discovery dispute; thereafter direct all disputes to Magistrate Judge.
In limine motions require separate notice of motion and brief, omnibus motions prohibited, responses individual, no replies allowed.
Discovery motions require an informal pre-filing conference per Local Civil Rule 37.2 and strict adherence to Fed. R. Civ. P. 37(a)(1) meet-and-confer requirements.
Pre-motion conference required for summary judgment motions; moving party files 3-page ECF letter-motion, opposing party files 3-page response within 7 business days.
Sur-reply memoranda are not accepted unless prior permission is granted by the Court.
Default judgments must be obtained via order to show cause, following the attached Default Judgment Procedure.
Letter-motions are permitted for extensions, adjournments, pre-motion conferences, and nondispositive matters; other motions require judicial authorization.
Discovery motions (Fed. R. Civ. P. 26-37, 45) require a pre-motion letter-motion for an informal conference before being heard, unless the presiding judge's individual practices dictate otherwise.
Court generally won't retain jurisdiction to enforce settlements; requires motion with reasons and settlement agreement.
Parties must confer within 1 week after discovery closes to propose joint briefing schedule for summary judgment motions
Parties must confer under FRCP 26(f) as soon as practicable after complaint service.
Joint status letter required within 7 days if no summary judgment pre-motion conference requested.
Plaintiff must respond to motion to dismiss letter within 5 business days.
Filing motion after court indicates likely denial may result in sanctions against defendant.
Court will not consider new matters raised for first time in reply memoranda.
Sur-replies require court permission and only for new controlling law.
Oral argument not routine; request by marking cover page
Additional oral argument request requires letter, not letter-motion
Pre-motion letters don't stay deadlines except for motions to dismiss staying defendant's answer time.
Pre-motion submissions not required from pro se parties; response due 3 business days if adversary files.
Incomplete rule about deposition requirements for summary judgment motions.
Sur-replies require prior permission from the Court
Special rules for pre-motion conferences on motions to dismiss regarding amended pleadings
Leave to amend unlikely if non-moving party doesn't amend and motion to dismiss is granted
Declining to amend after motion to dismiss may waive right to cure defects later.
Parties must confer within 1 week after discovery closes to propose joint briefing schedule for summary judgment motions
Joint status letter required within 7 days if no summary judgment pre-motion conference requested.
Counsel must meet in person for at least one hour to discuss settlement within 14 days after fact discovery closes.
Summary judgment practice not ordinarily allowed in non-jury cases without good cause.
If adversary notified but doesn’t consent to TRO, application must be heard at mutually agreeable time.
Good-faith conference requires meaningful dialogue, not just sending letters/emails; must attempt to resolve issues.
Court generally won't retain jurisdiction to enforce settlements; requires motion with reasons and settlement agreement.
Oral argument generally not heard in pro se matters unless otherwise ordered.
Sur-reply memoranda require prior permission from the Court.
Sur-replies require prior permission.
Parties may agree to alternate briefing schedule but must get Court approval.
Remote conference requests require letter-motion and Court approval even if on consent
Pre-motion conference request for motion to dismiss stays deadline to move or answer.
Opposing party may respond to discovery dispute motion within 2 business days electronically.
A pending motion to dismiss cancels any scheduled initial scheduling conference.
Sur-reply memoranda require prior court permission.
Cross-motions are prohibited.
Plaintiff must respond to motion to dismiss letter within 5 business days.
Leave to amend unlikely if non-moving party doesn't amend and motion to dismiss is granted.
Parties must confer under FRCP 26(f) as soon as practicable after complaint service.
Initial pretrial conference is not automatically cancelled if a fully briefed motion is pending; court may adjourn conference if motion is not fully briefed. Counsel must discuss pending motions at conference.
Pre-motion conferences not required for specific motion types including pro se, TROs, injunctions, remand, etc.
Pre-motion letters don't stay deadlines except motion to dismiss stays defendant's answer deadline.
Pre-motion submissions not required from pro se parties; response optional if adversary files.
Patent cases require status conference; continue discovery under existing order until conference.
IDEA/ERISA cases use summary judgment on administrative record instead of discovery schedule.
PSLRA cases require conference and schedule in accordance with statute.
Pro se cases must follow existing scheduling order; Magistrate Judge has authority.
If no scheduling order exists in pro se cases, Judge will conference and refer to Magistrate for discovery.
Court determines whether to grant oral argument and notifies counsel of date.
Rule 26(f) conference must occur at least one week before Initial Case Management Conference.
Pre-motion conferences not required for non-discovery motions
After failed discovery conference, request Court conference under Local Rule 37.2.
Briefing schedule defaults to Local Civil Rule 6.1 when no court order exists.
Pre-motion conferences are not required in civil cases.
Court decides whether summary judgment motion is warranted after pre-motion letter
Pre-motion letters may request to be deemed and filed as formal motions.
Court may treat pre-motion letter as formal motion if it contains sufficient factual and legal statement.
Court schedules conference (phone or in person) after pre-motion exchange fails.
Court aims to decide expedited motions within 14 days of full submission.
Must respond to conference requests within one business day unless emergency.
If conference doesn't resolve dispute, moving party must confirm impasse with opposing party.
After impasse, moving party must promptly request conference with court.
Conference request letter limited to 5 pages, setting forth dispute basis and need for motion.
Requirements cannot be satisfied by attaching party communications.
Opposing party must respond to conference request letter as soon as practicable.
Oral argument only if ordered by Court
Filing a pre-motion conference request to dismiss automatically stays the Answer deadline until the motion is resolved.
Pre-motion conferences required only for discovery disputes.
Pre-motion letter for pre-answer motion to dismiss stays answer obligation until conference.
Pre-motion conference not required for substantive motions other than discovery and summary judgment.
Prior motion to dismiss terminated as moot if new motion to dismiss is filed.
Initial Rule 16 conference scheduled for Friday morning ~6 weeks after Complaint filing.
Parties must be prepared to discuss pending/anticipated motions and subject matter jurisdiction at initial pretrial conference.
Parties may request oral argument; Court will advise if granted and schedule date
Oral argument only if ordered by Court
Oral argument is not heard in pro se matters unless ordered.
Briefing schedule follows Local Civil Rule 6.1 unless otherwise ordered; joint letter-motion required for agreed schedules.
Final pretrial conference scheduled 2 weeks before trial; counsel must attend and be prepared for settlement discussions.
Patent cases require status conference; continue discovery under existing order until conference.
IDEA/ERISA cases use summary judgment on administrative record instead of discovery schedule.
PSLRA cases require conference and schedule in accordance with statute.
Pro se cases must follow existing scheduling order; Magistrate Judge has authority.
If no scheduling order exists in pro se cases, Judge will conference and refer to Magistrate for discovery.
Initial Rule 16 conference scheduled within one month of Answer filing.
Court will discuss anticipated summary judgment motions at post-discovery pretrial conference.
Pre-motion submissions not required for pro se parties.
Oral argument not permitted unless otherwise ordered.
Motions not requiring pre-motion conference
Pretrial status conferences may be suggested by parties or called by Court at any time.
Pre-motion conferences are not required in civil cases.
Pre-motion conference request for motion to dismiss stays existing deadlines.
Oral argument is not usually heard but may be requested by letter when filing motion papers.
Pre-motion conferences not required for non-discovery motions
Court decides whether summary judgment motion is warranted after pre-motion letter
Pre-motion conferences not required for specific motion types including pro se, TROs, injunctions, remand, etc.
Pre-motion letters don't stay deadlines except motion to dismiss stays defendant's answer deadline.
Pre-motion submissions not required from pro se parties; response optional if adversary files.
Court prefers conferences for discovery disputes in Letter-Motions.
Pre-motion conference not required for non-discovery motions unless ordered.
Must respond to conference requests within one business day unless emergency.
If conference doesn't resolve dispute, moving party must confirm impasse with opposing party.
After impasse, moving party must promptly request conference with court.
Conference request letter limited to 5 pages, setting forth dispute basis and need for motion.
Requirements cannot be satisfied by attaching party communications.
Opposing party must respond to conference request letter as soon as practicable.
Oral argument may be requested by letter when filing motion papers.
Pre-motion conference not required for non-discovery motions but may be requested by letter.
Opposition and reply papers for non-discovery motions due per Local Civil Rule 6.1.
Oral argument may be requested by letter when filing motion papers.
Summary judgment motions may be filed directly (28 days after discovery closes)
Pre-motion conference not required except for discovery motions with formal briefing
Parties encouraged to agree on briefing schedule before filing formal motions.
Rule 26(f) conference must occur at least one week before Initial Case Management Conference.
Pre-conference phone call scheduled approximately one week before conference.
Motions (except Orders to Show Cause) should be filed without a return date.
Parties with expedited discovery schedules (6 months or less) may request cancellation of the Initial Pretrial Conference via Joint Letter.
Pre-motion conferences are not required except for discovery disputes and early summary judgment motions.
No pre-motion conference or permission required; motions may be filed at attorney discretion.
Pre-motion conferences and pre-motion letters are not required in pro se cases.
Pre-motion conference requirement is waived for motions in limine.
Pre-motion conferences are optional for non-discovery motions; may be requested by letter motion.
Oral argument will not be heard in pro se matters unless the Court orders otherwise.
Pre-motion conferences are not required except for discovery disputes.
Pre-motion conferences are optional for non-discovery motions and may be requested by letter-motion.
Formal motion briefing schedule follows Local Civ. R. 6.1 unless otherwise ordered.
Nonmovant must respond within 7 days to pre-motion letter, indicating amendment plans or reasons not to amend with supporting case law.
If nonmovant doesn't amend, Court schedules pre-motion conference to discuss issues and set briefing schedule.
Complaint dismissed based on pre-motion letter may be dismissed with prejudice as nonmovant had chance to amend.
Oral argument may be requested via letter after motion is fully briefed, per Section I(A) procedures.
Pre-motion conferences are not required for other substantive motions.
Parties may request oral argument by letter when filing motion, opposing, or reply papers; court decides whether to hold argument.
Central District of California
View all rules for CDCA.All motions require pre-filing meet and confer with opposing counsel, with no exceptions for pro se parties, futility, or redundancy.
Parties must seek leave via noticed motion with good cause to file multiple summary judgment motions or increase page limits.
Cross-motions for summary judgment on the same legal issues are prohibited; counsel must meet and confer to consolidate into one motion.
Default summary judgment briefing schedule: motion 42 days before hearing, opposition 28 days, reply 21 days; modifications allowed via stipulation subject to court approval.
Pretrial motions must be filed 28 days before hearing; opposition 21 days; reply 14 days.
Discovery motions require consultation with opposing counsel and specific content; non-compliant motions may not be heard.
Motions in limine must be noticed by final pretrial conference; no replies without leave.
Pre-motion conference required before filing motions in limine.
Maximum 5 motions in limine per party without leave of court.
Motions in limine exceeding 5 per party will be stricken.
Motion required for juror questionnaires (8 weeks before trial), Court prefers agreement.
Applications for Leave to File Under Seal do not require a hearing; do not set hearing date or time when e-filing.
Meet and confer required before filing any motion under Local Rule 7-3.
Meet and confer required before filing discovery motions.
Daubert motions must be heard by 8 weeks before FPTC
Motions in limine limited to 5 per side, filed 28 days before FPTC
Meet and confer required before filing motions in limine
Jury instruction meet-and-confer schedule: 35 days (exchange proposals), 28 days (exchange objections), 14 days (file joint/disputed instructions).
Plaintiff must seek all defendants’ counsel consent before filing motion to substitute Doe defendant; denied consent requires regularly noticed motion, with diversity jurisdiction address in diversity cases.
Parties must strictly comply with FRCP 16, 26, and court orders regarding scheduling conferences.
Counsel must meet and confer in person/by phone at least 7 calendar days before filing sealing application; non-proposing party confirms within 2 days after; email alone insufficient.
Local Rule 7-3 pre-filing meet and confer is strictly enforced, applying to all cases including those with pro se litigants.
Counsel must meet and confer on all potentially disputed matters (except Local Rules 7-3/16-12) before presenting to court, including continuances and seal applications, to resolve or narrow issues.
Meet and confer must be conducted via videoconference or in person; email is insufficient.
Failure to comply with meet and confer requirements may result in sanctions; moving party must detail opposing party’s refusal to participate in good faith.
All motions must be filed in compliance with Local Rules 6 and 7.
Parties must check Judge Murillo’s closed motion dates on the court website immediately before filing a motion; motions noticed for closed dates may be struck or reset.
Parties must adhere to Local Rules 7-9 and 7-10 briefing schedules for all motions except Rule 56 motions.
Motions in limine must be filed 28 days before FPTC; oppositions 14 days before.
Meet and confer required before filing motions in limine.
Maximum 5 motions in limine per party without leave.
Meet and confer schedule for jury instructions: exchange proposals at 35 days, objections at 28 days before FPTC.
Telephonic and/or in-person conferences required to resolve discovery disputes; email exchanges insufficient.
Local Rule 7-3 requires meet and confer before filing any motion; must discuss thoroughly, preferably in person; statement of compliance required; sanctions possible for non-compliance; no exceptions for pro se or futility.
Redlined version must be delivered to opposing counsel 2 hours before Local Rule 7-3 conference.
Motions in limine must follow Scheduling Order and be heard before Final Pretrial Conference.
Motions for default judgment must be filed within 14 days of default entry or resolution of claims.
Movant must appear at default judgment hearing prepared to argue even without opposition.
Only one Rule 56 motion allowed without leave of court.
Opposition to ex parte applications due within 24 hours of receipt.
Opposition to TRO applications due within 24 hours of service or filing.
Court will not rule on TRO for at least 24 hours after service.
Ex parte travel applications must be made well in advance and indicate Pretrial Services approval.
Meet and confer with opposing counsel required before filing any motion.
Pretrial motions must be noticed for mutually agreed Monday; briefing schedule: motions (3 weeks), oppositions (2 weeks), replies (1 week).
Suppression motions must be noticed for mutually agreed Monday; briefing schedule: motions (4 weeks), oppositions (2 weeks), replies (1 week).
Discovery motions require meet-and-confer; must detail request, basis, prior requests, and opposition response; no prior consultation = motion not heard.
Opposition to motion must be filed 21 days before hearing date.
Motions require meet-and-confer with opposing counsel to discuss substance and potential resolution before filing.
Non-limine motions: file 5 weeks before hearing, oppositions 3 weeks before hearing.
Oppositions must be filed 14 days before final pretrial conference; no replies allowed.
Parties must meet and confer before filing motions in limine, with specific disclosure requirements.
Parties must meet and confer to resolve discovery disputes before filing motions to compel; motions must state specific details.
Parties must meet and confer before filing motions or requests for relief, except for exempt categories.
Discovery motions handled by assigned Magistrate Judge; must be filed early enough to obtain responses before discovery cut-off.
Planned motions to compel discovery must be discussed with opposing counsel at least six weeks before the discovery cut-off date.
Reply briefs to motions in limine are prohibited.
Informal discovery conference required before filing discovery motions, unless movant obtains ex parte leave of court.
Counsel must meet and confer per Local Rule 7-3 before filing motions in limine.
Parties must request leave to file more than four motions in limine.
Parties must meet and confer to prepare the joint exhibit list and stipulate to foundation and admissibility as much as possible.
Pre-motion conference required before filing any motion.
Cross-motions on same issues not allowed; parties must meet and confer to determine single moving party.
Opening brief and appendices must be provided to non-moving party 63 days before hearing.
Challenging parties must initiate meet and confer disputes prior to challenging confidentiality designations.
Parties must meet and confer to resolve disputes before filing any motion or request for relief.
Ex parte application required for other in limine motions 7 days before due date.
Local Rule 7-3 requires pre-filing meet and confer conference.
Motion may be struck or denied for lack of compliance statement or bad faith.
Meet and confer required before filing motions to dismiss or strike.
Extended briefing schedule required for Rule 56 motions: motion 5 weeks before hearing, opposition 3 weeks before, reply 2 weeks before.
Counsel must meet and confer to determine filing order for cross-motions and stipulate to extended briefing schedule and page limits.
Meet and confer under Local Rule 7-3 before filing attorneys' fees motion.
Pre-filing conference required for all motions, including pro se parties.
Only one summary judgment motion permitted per case; papers should be well-organized with tabs and headings.
Motions must be filed 14 days before hearing; support/opposition limited to 10 pages; reply (optional) limited to 5 pages and due 3 days before hearing.
Pre-filing conference required before any motion; Notice of Motion must include compliance statement; court may strike motion if parties fail to meet and confer in good faith.
Rule 56 motions require extended briefing schedule: motion 35 days before hearing, opposition 21 days before (14 days after motion), reply 14 days before (7 days after opposition).
Pre-filing conference required before filing any motion per Local Rule 7-3, applies to attorneys and pro se parties.
Discovery motions require compliance with mandatory pre-motion telephonic conference procedure before filing.
Pre-filing conference (meet and confer) required before filing motions to discuss motion substance and potential resolution.
Cross-motions for summary judgment require counsel to meet and confer; if no agreement, file joint submission 45 days before motion deadline.
Rule 56 motions require 12-week advance filing, opposition due 4 weeks later, reply due 2 weeks after opposition, with at least 2 weeks before hearing.
Attorneys' fees motions require pre-filing meet and confer in person or by videoconference.
Pre-filing meet and confer required before filing motions; must be in person, by telephone, or videoconference; written correspondence insufficient.
Local Rule 7-3 requires a pre-filing conference to discuss the motion's substance and potential resolution.
Pre-motion conference (in-person or videoconference) required no later than 60 days before motion hearing cutoff for summary judgment motions.
Only one joint Rule 56 motion permitted without leave of court.
Meet and confer conference is required no later than 60 days before motion hearing cutoff for summary judgment motions.
Joint brief must be assembled sequentially: moving party submits portion within 14 days after meet and confer, opposing party integrates their portion within 14 days after receipt, then moving party files without modifications.
Reply brief must be filed within 7 days after Joint Brief and at least 21 days before hearing; no sur-replies or supplemental briefing permitted.
Pre-filing meet and confer requirement exists for motions.
Good faith conference required before motions to dismiss/strike under Local Rule 7-3.
Opposition to ex parte applications must be filed within 24 hours of service.
TRO applications will not be ruled on for at least 24 hours after service unless notice is excused.
Scheduling conference will be set per FRCP 16 and 26; strict compliance required.
All parties must participate in settlement conference or ADR.
Parties must meet and confer before filing motions or requests for relief, except for exempt categories.
Discovery motions handled by assigned Magistrate Judge; must be filed early enough to obtain responses before discovery cut-off.
Motions filed under LR 7; heard Mondays at 1:30 PM; no supplemental briefs without leave; hearing must be within 35 days of service.
ERISA cases require agreed statement of facts for summary judgment motions.
Pre-motion conference required for motions in limine within 5 days; moving party arranges and identifies disputed matters.
Motions in limine heard at Final Status Conference; ex parte motions require showing of irreparable injury.
Settlement conference under Court-Directed ADR Program required by court-set date.
Trial cannot proceed without personal appearance at settlement conference by all parties and principals.
Final Pretrial Conference required; lead trial counsel must represent each party.
Pro per parties are not exempt from Local Rule 16 requirements.
Rule 26(f) discovery plan conference required 21 days before scheduling conference; Joint Rule 26(f) Report due 14 days before.
Extended briefing schedule for summary judgment motions: motion 5 weeks before hearing, opposition 3 weeks before, reply 2 weeks before.
Parties must meet and confer before filing any motion or request for relief (except those in LR 7-3 and 16-12).
JMIL briefing schedule: moving party 25 days before PTC, opposing party 18 days before PTC, reply 14 days before PTC.
Pretrial motions must be filed 28 days before hearing with specific deadlines for opposition (21 days) and reply (14 days).
Pretrial motions must be noticed for mutually agreed Friday.
Briefing schedule: motions 5 weeks, oppositions 3 weeks, replies 2 weeks before hearing.
Pre-filing conference required before filing motions.
Pre-filing conference requirement applies even with pro se parties.
Discovery motions require meet-and-confer and specific content about prior requests.
Multiple summary adjudication motions by same party require leave of court; subsequent motions without leave will be stricken.
Ex parte travel applications must be made well in advance and indicate Pretrial Services approval.
Meet and confer with opposing counsel required before filing any motion.
Pretrial motions must be noticed for mutually agreed Monday; briefing schedule: motions (3 weeks), oppositions (2 weeks), replies (1 week).
Suppression motions must be noticed for mutually agreed Monday; briefing schedule: motions (4 weeks), oppositions (2 weeks), replies (1 week).
Discovery motions require meet-and-confer; must detail request, basis, prior requests, and opposition response; no prior consultation = motion not heard.
Motions in limine must be filed 3 weeks before final pretrial conference; oppositions 2 weeks before.
Meet and confer required before filing motions in limine.
Lead trial counsel must meet and confer in person per Local Rule 16-2, exchange proposed jury instructions 14 days before, serve objections 10 days before, and attempt to agree at the meeting.
Opposition to motion must be filed 21 days before hearing date.
Motions (except in limine) briefing schedule: motions 5 weeks, oppositions 3 weeks, replies 2 weeks before hearing.
Conference of Counsel required at least 7 days before filing most motions.
Opposing parties have 48 hours to file opposition papers after receiving ex parte application.
Pre-motion letter briefs (max 5 pages) required for summary judgment motions; opposition briefs due within 7 days; no reply without permission.
Pre-motion conference required before filing motions in limine.
Maximum 5 motions in limine per party without leave of court.
Motions in limine exceeding 5 per party will be stricken.
Motion required for juror questionnaires (8 weeks before trial), Court prefers agreement.
Meet and confer required before filing motions or ex parte applications.
Pre-filing conference required 7 days before filing any motion.
Motion in limine requires meet and confer conference within 10 days, no later than 21 days before Pretrial Conference.
Settlement conference must be conducted 11 weeks and 1 day before trial.
Pre-filing conference required 7 days before filing any motion.
Meeting and conferring required before filing motions or ex parte applications.
Ex parte applications require strict procedures; opposition due within 24 hours; no reply unless authorized; decided on papers unless hearing ordered.
Summary judgment motions can be filed anytime with 35 days’ notice required.
Motion in limine requires meet-and-confer conference within 10 days, in person unless geographically impractical.
Motions in Limine have specific filing and hearing dates per court schedule.
Class certification motions must follow Local Rule 23-3 and meet deadline.
Motions in limine must be filed and served 21 days before FPTC; oppositions 10 days before; replies 4 days before with courtesy copies to chambers.
Discovery motions require prior consultation with opposing counsel and must include specific information.
Ex parte application required for other in limine motions 7 days before due date.
Parties must meet and confer to resolve disputes before filing any motion or request for relief.
Pre-filing conference required for all motions, including pro se parties.
Only one summary judgment motion permitted per case; papers should be well-organized with tabs and headings.
Opposing parties may file motions to dismiss (Rule 12) or for summary judgment (Rule 56).
Conference of counsel required at least 3 days before filing any criminal motion.
Pretrial motions must be noticed by 11 days before trial; earlier hearings require CRD clearance.
Discovery motions require prior consultation with opposing counsel and must include specific information or may be stricken.
Motions set for hearing >70 days out: opposition due 21 days, reply due 35 days after filing.
Prefiling conference required before filing motions; declaration must state conference method.
Cross-motions on same issues not allowed; parties must meet and confer to decide who moves.
Extended briefing schedule: 63 days for opening brief, 14 days for opposition.
Counsel must meet and confer to resolve discovery disputes informally before filing discovery motions.
Briefing schedule: motions 28 days, oppositions 14 days, replies 7 days before hearing.
Parties must meet and confer before filing motions in limine.
Parties must meet and confer to resolve discovery disputes before filing motion.
Parties must meet and confer before filing any motion.
Special procedures for summary judgment motions including joint brief requirement.
For hearings 35-70 days out: opposition due 14 days after filing, reply due 21 days after filing.
For hearings >70 days out: opposition due 21 days after filing, reply due 35 days after filing.
Pre-filing conference required to discuss motion substance and potential resolution; pro se status doesn't exempt.
Motions must be filed 14 days before hearing; support/opposition limited to 10 pages; reply (optional) limited to 5 pages and due 3 days before hearing.
Motions in limine must be noticed by final pretrial conference; no replies without leave.
Pre-filing meet and confer required for all motions, including pro se cases.
Meet and confer required for disputed matters before court presentation.
Motions in limine must be scheduled for the Final Pretrial Conference.
Daubert motions must be noticed for hearing at least 8 weeks before Final Pretrial Conference.
Extended briefing schedule required for class certification motions.
Discovery motions must state meet and confer compliance and detail request specifics.
Court may decline discovery motions without prior consultation.
Meet and confer required for pre-trial motions (except motions in limine).
Good faith meet and confer required to resolve issues without motion.
Briefing schedule: motions 3 weeks, oppositions 2 weeks, replies 1 week before hearing.
Failure to meet deadlines may result in court declining to consider untimely documents.
Parties must strictly comply with FRCP 16 and 26 and court orders regarding scheduling.
Prefiling conference required to discuss motion substance and potential resolution.
Meet and confer requirement applies to all cases including pro se litigants.
Meet and confer must be in person or by videoconference; email is insufficient.
Motion without required certification may be stricken or summarily denied.
Moving party must include signed certification of meet and confer attempt.
Failure to comply with meet and confer may result in sanctions including striking/denying motion.
Good faith conference required before motions to dismiss/strike to potentially avoid through amendment.
Joint brief due 5 weeks before hearing; reply brief due 3 weeks before hearing.
Ex parte applications are considered on papers without hearing unless separate motion requests hearing.
All parties must attend personal settlement conference before trial.
At least 2 weeks required between reply filing and hearing date.
Pre-filing conference required for all motions; real-time discussion required; letters/emails insufficient.
Class certification motion due within 100 days of scheduling conference.
Planned motions to compel discovery must be discussed with opposing counsel at least six weeks before the discovery cut-off date.
Reply briefs to motions in limine are prohibited.
Stipulations or motions to continue discovery deadlines must be separately filed and noticed for hearing before Judge Kato; court disfavors extensions.
Counsel must meet and confer in real-time per Local Rule 7-3 before filing any motion; letters/email insufficient, non-compliance may result in strike/denial.
Reply briefs are prohibited for ex parte applications and will be stricken unless the court orders otherwise.
Pending motions in removed cases must be re-noticed per Local Rule 6-1.
Extension requests to identify fictitious defendants must be in the Joint Rule 26(f) Report.
Substitution of fictitious defendants requires consent of counsel or a noticed motion.
Counsel must meet and confer prior to or at the Rule 16-2 Meeting to agree on joint jury instructions and verdict forms.
Counsel must meet and confer in person or by telephone at least 7 calendar days before filing a sealing application based on the other party's confidentiality designation.
Plaintiff must seek all defendants’ counsel consent before filing motion to substitute Doe defendant; denied consent requires regularly noticed motion, with diversity jurisdiction address in diversity cases.
Parties must strictly comply with FRCP 16, 26, and court orders regarding scheduling conferences.
Counsel must meet and confer in person/by phone at least 7 calendar days before filing sealing application; non-proposing party confirms within 2 days after; email alone insufficient.
Local Rule 7-3 pre-filing meet and confer is strictly enforced, applying to all cases including those with pro se litigants.
Counsel must meet and confer on all potentially disputed matters (except Local Rules 7-3/16-12) before presenting to court, including continuances and seal applications, to resolve or narrow issues.
Meet and confer must be conducted via videoconference or in person; email is insufficient.
Failure to comply with meet and confer requirements may result in sanctions; moving party must detail opposing party’s refusal to participate in good faith.
All motions must be filed in compliance with Local Rules 6 and 7.
Parties must check Judge Murillo’s closed motion dates on the court website immediately before filing a motion; motions noticed for closed dates may be struck or reset.
Parties must adhere to Local Rules 7-9 and 7-10 briefing schedules for all motions except Rule 56 motions.
Parties must comply with FRCP 56, local rules, this order, and the court's civil case standing order when filing or opposing summary judgment motions.
Moving party must arrange an in-person or videoconference meet and confer no later than 60 days before the MSJ hearing cutoff, discussing all issues, law, and evidence.
No additional briefing or filings in support of or opposition to MSJ are permitted.
Parties must check closed motion dates on Judge Murillo’s Procedures and Schedules Page immediately before filing a motion; no need to clear date with Courtroom Deputy first.
Moving parties must schedule an in-person or videoconference meet and confer for summary judgment motions no later than 60 calendar days before the motion hearing cutoff, with encouragement to meet sooner.
Pretrial detention review requests must first be addressed to the Magistrate Judge.
Meet and confer required before filing discovery motions; email alone insufficient; motions must state meet and confer compliance and request details.
Counsel must meet and confer in good faith regarding pre-trial motions (except motions in limine) before filing; email alone does not satisfy this requirement.
Motions (except in limine) require briefing 3 weeks before hearing (motion), 2 weeks (opposition), 1 week (reply); must be noticed by FPTC; alternate schedules allowed with court approval.
Motions in limine require good faith meet and confer; email alone is insufficient to satisfy this requirement.
Parties with excessive or frivolous jury instruction disagreements must meet and confer immediately.
Applications for Leave to File Under Seal do not require a hearing; do not set hearing date or time when e-filing.
Counsel must meet and confer with opposing counsel to resolve issues before filing any motion.
Pretrial motions and motions in limine must be filed 28 days before pretrial conference, with opposition 7 days after filing, reply 7 days after opposition (motions in limine reply require leave), and hearing by pretrial conference.
Hearings on pretrial motions are held Thursdays at 10:00 a.m. unless the Court sets a different time.
Counsel must contact the Courtroom Deputy for a hearing date before filing non-pretrial/post-trial motions.
Counsel must meet and confer to resolve discovery disputes before filing a discovery motion.
Discovery motions filed without prior meet and confer with opposing counsel may be denied a hearing.
Parties must meet and confer to resolve discovery disputes before filing a discovery motion.
Parties must meet and confer at least 7 days before filing non-discovery or Daubert motions.
Replies to ex parte applications are not permitted without court leave.
Ex parte applications are decided on the papers without a hearing unless the court orders otherwise.
Parties must meet and confer before filing a motion in limine to attempt to resolve the dispute without filing.
Parties must attempt to agree on jury instructions before submitting proposals to the Court.
Before filing a motion to substitute a fictitiously named defendant, plaintiff must seek consent of all defense counsel; if consent is denied, the motion must be filed on regular notice.
Counsel must hold a prefiling conference and file a compliance declaration; pro se status does not exempt parties, noncompliance results in motion denial.
Supplemental briefs and surreplies are prohibited without prior leave of court.
Counsel must meet and confer at least 7 days before filing sealing applications, with non-proposing party confirmation due within 2 days.
All motions require pre-filing meet and confer with opposing counsel, with no exceptions for pro se parties, futility, or redundancy.
Parties must seek leave via noticed motion with good cause to file multiple summary judgment motions or increase page limits.
Cross-motions for summary judgment on the same legal issues are prohibited; counsel must meet and confer to consolidate into one motion.
Default summary judgment briefing schedule: motion 42 days before hearing, opposition 28 days, reply 21 days; modifications allowed via stipulation subject to court approval.
Pre-filing conference required for all motions per Local Rule 7-3, applies to all parties including pro se.
Supplemental briefs are prohibited unless prior leave of court is granted.
Each party may file only one summary judgment motion per case.
Daubert motions must be noticed for hearing on the first available motions date at filing, or at the final pretrial conference if that date is after.
Discovery motions require a pre-motion conference before filing unless ex parte leave is obtained.
Counsel must confer at least 3 days before filing any criminal motion to resolve or narrow issues.
Supplemental briefs are prohibited unless prior leave of court is granted.
Counsel must contact the CRD to clear hearing date and time for all motions scheduled before the pretrial status conference.
Parties must consult with opposing counsel before filing any discovery motion.
Parties must meet and confer before filing a motion in limine.
Mandatory pre-filing conference of counsel required for discovery motions, with format based on opposing counsel's county location; written electronic communications cannot substitute for the conference.
Ex parte applications to shorten motion to compel hearing time due to an impending discovery cutoff are prohibited without due diligence and good cause; parties must obtain district judge scheduling order relief before filing such motions if they cannot show diligence and cause.
Rule 56 motions must be filed 49 days before hearing, oppositions 35 days before, and replies 28 days before.
Motions in limine must be filed 6 weeks before FPTC, oppositions 4 weeks before, hearing 1 week before.
Parties must meet and confer to resolve disputes before filing any motion, per local civil and criminal rules.
Criminal motions must comply with Fed. R. Crim. P. 47 and local rules, are heard Fridays (9 AM non-custody, 10 AM custody), pretrial motions require mutually agreed Friday, no CRD clearance needed.
Non-motions in limine must be filed 5 weeks before hearing, opposition 3 weeks, replies 2 weeks, and noticed by Final Pretrial Conference.
Motions in limine require pre-filing meet and confer, must be filed 4 weeks before final pretrial conference, oppositions 2 weeks prior, with no replies allowed.
Counsel must meet and confer to resolve discovery disputes before filing a motion to compel discovery.
Counsel must hold telephonic or in-person conferences to resolve discovery disputes; pro forma email exchanges do not satisfy the pre-filing conference requirement.
Challenging parties must initiate meet and confer disputes prior to challenging confidentiality designations.
Informal discovery conference required before filing discovery motions, unless movant obtains ex parte leave of court.
Counsel must meet and confer per Local Rule 7-3 before filing motions in limine.
Parties must request leave to file more than four motions in limine.
Parties must meet and confer to prepare the joint exhibit list and stipulate to foundation and admissibility as much as possible.
Counsel must conduct a pre-filing meet and confer in person, by phone, or videoconference under Local Rule 7-3 before filing most motions, with specified exemptions; non-compliance may result in the motion being struck or denied.
No hearing is required for Application for Leave to File Under Seal, so no hearing date should be set.
Before filing a motion in limine, counsel must confer in good faith, and the moving party must send a letter with required content at least 5 days before the conference.
All motions (except preliminary injunctions, which have a separate 5-day requirement) require a pre-filing meet and confer in person, by telephone, or via video conference at least 7 days prior to filing; incarcerated pro se parties are exempt unless otherwise ordered.
Preliminary injunction motions require a pre-filing meet and confer in substantive compliance with Local Rule 7-3 at least 5 days prior to filing, notwithstanding Local Rule 7-3's exception for such motions.
Criminal motions require meet and confer with opposing counsel before filing; pretrial motions are scheduled on Fridays (evidentiary hearings on non-Fridays); briefing schedule requires motions 5 weeks before hearing, oppositions 3 weeks before.
Each side is limited to 5 motions in limine unless the court grants leave; motions in limine are heard at the Final Pretrial Conference, with possible oral ruling.
Parties must meet and confer in good faith before filing a motion in limine, with moving and nonmoving parties exchanging specified information.
Oppositions to motions in limine must be filed 14 days before the Final Pretrial Conference, and no replies are permitted.
Counsel must meet and confer informally to resolve discovery disputes before filing a motion to compel discovery, or the court may decline to hear the motion.
Counsel must conduct a pre-filing meet and confer conference (in person/phone/videoconference) before filing most motions, with specified exemptions; non-compliance may result in motion being struck or denied.
Motions for attorney fees must be set for hearing in accordance with Local Rule 6-1 and this Standing Order; electronic filing is required per general e-filing rules.
Each party is limited to five motions in limine unless the court grants permission to file additional motions.
Replies to motions in limine are prohibited.
No additional briefing or filings in support of or opposition to MSJ are permitted after supplemental memoranda.
Parties must meet and confer before filing a motion in limine to attempt to resolve the dispute without filing.
Motions in limine must address only evidence admission/exclusion, specific issues, and may not be disguised summary adjudication motions; the court may strike excessive or unvetted motions.
Parties must conduct an in-person or videoconference meet and confer no later than 53 days before the MSJ hearing cutoff to discuss all issues, law, and evidence.
If parties cannot agree on which party is moving party, defendant is deemed the moving party.
Parties may modify pre-filing MSJ deadlines without leave if all agree and motion is timely filed per case management order.
Only one joint Rule 56 motion may be filed without leave; leave requires a joint noticed motion stating good cause positions.
Ex parte applications disfavored; must attempt to obtain opposing counsel's position first.
Ex parte travel applications must be filed well in advance with probation officer input.
Motions to dismiss/strike can often be avoided through good-faith meet-and-confer under Local Rule 7-3.
Court may order immediate meet-and-confer for excessive or frivolous jury instruction disputes.
Ex parte applications disfavored; counsel must attempt to obtain opposing counsel's position before filing.
Motions in limine must address specific issues, not broad categories.
Court may strike excessive, unvetted, or untimely motions in limine without notice.
Motions to dismiss/strike should be avoided through good faith conference under Local Rule 7-3 when defects can be cured by amendment.
Exception to single motion rule requires leave by noticed motion with detailed showing of good cause.
Default briefing schedule is minimum; parties may stipulate to extended schedule with at least 2 weeks between reply and hearing.
Court may disregard disputes that are not clearly stated or violate Local Rules or this Order.
Summary judgment motions may be filed before motion cut-off date and must be heard before Final Pretrial Conference.
ERISA cases: summary judgment motions require agreed statement of facts; court hears motions on standard of review and administrative record scope.
When multiple parties move for summary judgment, they must designate one moving party; defendant defaults if no agreement.
Cross-motions on the same legal issues are highly disfavored.
Parties may stipulate to extended briefing schedules but must maintain at least 21 days between reply deadline and hearing date.
Ex parte applications only for extraordinary relief; sanctions for misuse.
Motions to dismiss can often be avoided through meet and confer under Local Rule 7-3.
Motions to dismiss/strike can often be avoided through good-faith meet-and-confer under Local Rule 7-3.
Ex parte applications disfavored; counsel must attempt to obtain opposing counsel's position before filing.
Court may decline to hear discovery motions filed without prior consultation with opposing counsel.
Must adhere to briefing schedule; late filings may be declined.
In ERISA cases, only motions on standard of review, discovery, and administrative record scope are permitted; summary judgment motions are discouraged.
Parties must follow briefing schedule unless Court approves alternate schedule.
Motions may be denied if the moving party fails to meet the meet-and-confer requirement.
Ex parte applications are decided on submitted papers; no hearing date is required.
Refer to Standing Order for motion requirements
Civil motions are heard Wednesdays at 1:30 PM; parties need not clear hearing dates with CRD before filing.
Replies to motions in limine are not required.
Court will meet with parties to settle instructions before closing argument, allowing oral objections.
Ex parte applications are decided on papers without hearing.
Summary judgment motions can be filed before motion cutoff date; hearing must be before Final Pretrial Conference.
All in limine motions heard on scheduled pretrial date.
Court may sua sponte enter summary judgment under Rule 56(f) and expects parties to seek intervention if needed.
Court will deem facts admitted according to Local Rule 56-4.
Opposing party may dispute all or part of factual statements but should not dispute immaterial portions.
Motions to dismiss can often be avoided through good faith conference; leave to amend should be granted unless complaint cannot be saved.
Parties may modify pre-filing deadlines by agreement without court leave if all parties agree and MSJ is timely filed.
If Pretrial Conference is waived, counsel must follow Local Rule 16-11.
Ex parte applications are decided on papers without hearing.
Default briefing schedule is minimum; parties may stipulate to extended schedule with at least 2 weeks between reply and hearing.
Pre-filing conference should resolve issues to focus briefing on substantive matters.
Minor procedural matters should be resolved during pre-filing conference.
Motions in limine will be ruled on at final pretrial conference.
Hearings on ex parte applications only if deemed necessary by the Court.
Motions in limine hearing scheduled 1 week and 1 day before trial.
Pretrial conference scheduled 3 weeks and 1 day before trial.
Motions for class certification follow Local Rule 23-3.
All in limine motions heard on scheduled pretrial date.
Motions in limine will be heard on the scheduled pretrial date unless otherwise ordered.
Motions to dismiss can often be avoided through good faith conference; leave to amend should be granted unless complaint cannot be saved.
Good faith conferences under Local Rule 7-3 can avoid many motions to dismiss or strike.
Court meets with counsel to settle instructions before closing argument.
Motions with hearing <35 days follow Local Rules 6-1 and 7 for briefing.
Parties may stipulate to briefing schedule for hearings >70 days out if reply filed 5 weeks before hearing; stipulation due within 7 days with specific caption.
Scheduling conference will be held pursuant to Fed. R. Civ. P. 16 and 26(a).
Bankruptcy appeals are considered on the papers without hearing.
Parties may stipulate to a different briefing schedule if at least two weeks elapse between reply filing and hearing date.
Civil motions are heard Wednesdays at 1:30 PM; parties need not clear hearing dates with CRD before filing.
Replies to motions in limine are not required.
Cross-motions on the same legal issues are highly disfavored; non-moving parties should include arguments in response instead of filing cross-motions.
Ex parte applications are decided on papers; court sets hearings if needed, counsel should not schedule hearings.
Motions in limine are heard at the final pretrial conference; court may rule orally.
All discovery motions are assigned to the case's assigned magistrate judge.
Counsel seeking to hear a motion earlier than the Pretrial Conference should meet and confer to agree on an earlier briefing schedule.
Counsel should obtain opposing counsel's agreement or position before filing ex parte applications, which are disfavored.
Counsel must review the assigned magistrate judge’s procedures and schedules to schedule discovery matters.
Parties must check the court’s webpage for additional motion requirements.
Ex parte applications are restricted to extraordinary relief and are generally disfavored.
Ex parte applications are decided on submitted papers; no hearing date is required.
Parties may agree to an alternate briefing schedule only with prior court approval.
Ex parte applications are disfavored, limited to extraordinary relief, and usually decided on the papers without a hearing.
Eastern District of New York
View all rules for EDNY.Motions in limine are due 30 days before jury selection, responses are due 10 days after filing, and replies are not due unless the Court requests them.
Before seeking court intervention on a discovery dispute, parties must file a joint pre-motion letter requesting an informal discovery conference with specified content.
Before judicial intervention on other discovery disputes, parties must file a single joint letter on ECF as a motion seeking a discovery conference.
Discovery-dispute joint letters must include the dispute nature, each party’s factual/legal position, and good-faith meet-and-confer efforts.
Pre-motion conferences are mandatory before specified dispositive and venue/amendment motions, except in Social Security and habeas cases.
Filing a pre-motion letter for leave to make a pre-answer dismissal motion stays the deadline to answer or otherwise move against the complaint until the conference date.
Opposing parties must file a response letter within five business days, limited to three pages, and no replies are allowed.
For anticipated Rule 56 motions, no full Local Rule 56.1 statement is required with the pre-motion letter, but the letter must describe the general undisputed material facts.
A Rule 56 pre-motion response letter must describe factual disputes and identify admissible supporting evidence.
In limine motions must be filed 15 days before trial with disputed documents attached, responses are due 5 days later, and oral argument is scheduled if needed.
Pre-motion conference required for dispositive motions and venue change motions (except discovery motions, habeas/prisoner cases, Social Security/Bankruptcy appeals).
Pre-motion conference letter limited to 3 pages; response letter limited to 3 pages within 7 days.
Parties cannot serve motion papers until court approves the briefing schedule.
Pre-motion conference required before Rule 12/56 motions and venue changes, except for certain case types.
Motions in limine must be filed 30 days before jury selection.
Responses to motions in limine are due 10 days after filing.
Pre-motion conference required for dispositive motions (except default judgment), change of venue, and FRCP 15 motions to amend.
Movant must write requesting pre-motion conference with brief description; opposing party may file letter; submissions due 2 business days before conference.
Parties may not serve motion papers before obtaining court approval for the briefing schedule.
When all parties are represented, pre-motion conferences are required before FRCP 12, FRCP 56, and venue-change motions.
Pre-motion requests and responses must be letter submissions capped at three pages, with responses due within seven days.
FRCP 56 pre-motion conference requests must be made within 30 days after close-of-discovery certification, absent court order or good cause.
Parties must obtain court approval of the motion schedule before serving motion papers and cannot change that schedule without a court order.
Pre-motion conference and full-briefing-before-filing requirements are waived when strict deadlines must be met to preserve rights.
In criminal cases, contemplated motions must be raised at a status conference or by a written pre-motion conference request stating grounds before filing.
In criminal cases, motions in limine are due 14 days before jury selection, responses are due five days later, and oral argument is scheduled at the Court’s convenience.
Pre-motion conferences are required only for non-venue Rule 12 motions.
A pre-motion settlement conference is required before filing summary judgment motions.
Rule 12 motions require pre-motion conference with 1750-word letters; non-moving party has 7 days to respond; no replies; counsel must appear.
A settlement conference with the assigned magistrate judge is mandatory before filing any motion for summary judgment; telephone conferences do not comply.
Proposed summary judgment briefing schedule must be submitted within 30 days after close of discovery or the right is waived.
Motions in limine briefing schedule: oppositions due 14 days after opening brief, replies due 7 days after opposition.
Motions in limine must be filed 45 days before trial, opposition 14 days later, reply 7 days after that.
Before seeking court intervention on a discovery dispute, parties must file a joint pre-motion letter requesting an informal discovery conference with specified content.
Pre-motion conference requests are required for Daubert and Rules 12/56 motions, with listed case-type and pro se exceptions, and pro se cases must submit a joint proposed briefing schedule instead.
Daubert and Rule 12 pre-motion letters and responses are limited to three pages, responses are due within one week, and Rule 12 responses must address leave to amend.
Rule 56 pre-motion letters and responses are capped at three pages, Rule 56.1 statements are required on both sides, and the response package is due within two weeks.
Motions in limine must be filed thirty days before trial, and responses are due ten days after filing.
Pre-motion conferences are required before Rule 12, Rule 56, and Daubert motions in civil cases, except in specified exempt categories.
A pre-motion conference request must be made by a letter from the moving party limited to three pages and stating the basis for the anticipated motion.
For Rule 56 motions, the moving party must file a Rule 56.1 statement with the pre-motion letter and file cited evidence as declaration exhibits.
Any party served with a pre-motion conference letter must file and serve a response letter.
For Daubert and Rule 12 motions, response letters are due within one week, limited to three pages, and must include amendment-position details for anticipated dismissal motions.
For Rule 56 motions, response letters are due within two weeks, capped at three pages, and must include a responsive Rule 56.1 statement with cited evidence attached as exhibits.
Section III.A pre-motion procedures apply only to Daubert, Rule 12, and Rule 56 motions, and do not require pre-motion letters for Rule 50, 59, or 60 motions.
Except for emergency motions, parties must wait for a court-entered briefing schedule before serving motion papers, cannot change that schedule without court approval, and may not file sur-replies.
Motions in limine must be filed 30 days before trial, responses are due 10 days after filing, and replies are not allowed unless the Court orders otherwise.
In criminal motions, parties must wait for a court-set briefing schedule before serving motion papers, and schedule changes require court approval.
Discovery motions must follow Local Civil Rules 6.4 and 37.3 and the assigned magistrate judge’s individual rules.
Premotion conferences are required for motions not listed as exempt, with strict pre-motion letter limits, response timing, and no reply or exhibits.
Default judgment motions are exempt from the pre-motion conference requirement.
Motions in limine require a pre-motion conference request before filing the JPTO.
When all parties are represented, pre-motion conferences are required before FRCP 12, FRCP 56, and venue-change motions.
Pre-motion requests and responses must be letter submissions capped at three pages, with responses due within seven days.
FRCP 56 pre-motion conference requests must be made within 30 days after close-of-discovery certification, absent court order or good cause.
Parties must obtain court approval of the motion schedule before serving motion papers and cannot change that schedule without a court order.
Pre-motion conference and full-briefing-before-filing requirements are waived when strict deadlines must be met to preserve rights.
In criminal cases, contemplated motions must be raised at a status conference or by a written pre-motion conference request stating grounds before filing.
In criminal cases, motions in limine are due 14 days before jury selection, responses are due five days later, and oral argument is scheduled at the Court’s convenience.
Motions in limine are due 30 days before jury selection, responses are due 10 days after filing, and replies are not due unless the Court requests them.
A pre-motion conference is required before filing motions, with discovery motions and listed case categories excluded from this requirement.
A pre-motion conference request requires a moving-party letter of up to 3 pages, and other parties may optionally file a response letter of up to 3 pages within 7 days.
Pre-motion conferences are required for motions, subject to exceptions, and are scheduled by letter request.
A pre-motion letter requesting a pre-motion conference is required before filing any motion returnable before Judge Brown.
A summary judgment movant must submit a Rule 56.1 statement with evidentiary citations together with the pre-motion letter.
Before seeking a pretrial conference or filing non-dispositive pre-trial motions, parties must meet and confer to try to narrow disputes.
Civil discovery disputes require a single jointly composed pre-motion letter capped at five pages, and separate/successive letters are not accepted.
A detailed pre-motion letter of up to three pages is required before filing non-discovery motions.
For Rule 56 motions, the movant must include a Rule 56.1 statement with the pre-motion letter.
Response letters are due within five business days for non-summary-judgment pre-motion letters.
For summary-judgment pre-motion letters, response letters are due within 21 days of service.
Pre-motion letters for summary judgment and Daubert-type expert-exclusion motions must be filed within 30 days after fact or expert discovery closes, whichever is later.
The moving party is not permitted to file a reply letter in the pre-motion letter process.
Cross-motions are prohibited, and motions omitted from timely pre-motion letters will not be considered.
Motions in limine must be filed 30 days before trial, oppositions are due 10 business days after filing, all in limine motions must be consolidated, and replies are barred unless the Court orders otherwise.
Daubert expert-exclusion motions must follow dispositive-motion deadlines and are not treated as motions in limine.
Letter-motion practice requires an opposition within four days and does not permit replies.
Rule 12 and Rule 56 dispositive motions require a pre-motion letter and a pre-motion conference motion.
Parties must submit an agreed proposed briefing schedule with the pre-motion letter, cannot file papers until court approval, and opposing letters are due within five business days except for summary judgment motions.
A summary judgment movant must file a Local Civil Rule 56.1 statement with evidentiary citations together with the pre-motion letter.
In summary judgment practice, the opposing party must respond within 15 days with a pre-motion response letter and Rule 56.1 response, and the moving party must respond to additional Rule 56.1(b) paragraphs within 7 days.
A pre-motion conference is required for motions (with listed exceptions), and pre-motion letters and responses are capped at 3 pages with responses due in 7 days.
Pre-motion conferences are generally required before motions to Judge Azrack, with 3-page letter/response requirements, specific exemptions, and court-discretion exceptions.
If a motion requires a pre-motion conference request, the Court sets the briefing schedule at that conference; otherwise parties must submit a proposed briefing schedule.
When strict time limits are necessary to preserve rights, pre-motion conference and pre-filing full-briefing requirements do not apply.
In civil cases, Rule 12 dismissal and Rule 56 summary-judgment motions require a pre-motion conference, and the Court may set briefing at that conference.
A pre-motion conference request must be made by a letter motion capped at four pages and must briefly state the basis for the anticipated motion.
Filing a pre-motion request does not stay deadlines, except that a request tied to a proposed motion to dismiss stays the defendant’s time to answer or otherwise move.
Pre-motion conference requests must be filed before the dispositive-motion deadline set by the assigned Magistrate Judge.
For proposed motions to dismiss, the pre-motion response is due within seven days after receipt of the movant’s request.
For proposed summary-judgment motions, the pre-motion response is due within twenty-one days and Local Civil Rule 56.1 compliance is required.
A party seeking summary-judgment leave must file a Local Rule 56.1 statement together with the pre-motion conference request.
The opposing party must serve a Rule 56.1(b) counterstatement within twenty-one days after receiving the movant’s Rule 56.1 statement.
For objected pro hac vice motions, opposition is due two business days before return date and replies are not allowed.
Before discovery motions, parties must confer in good faith and, if unresolved, file a jointly composed single dispute letter on ECF as a motion.
Dispositive motions go to the presiding District Judge unless the parties have consented to Judge Marutollo or the court directs otherwise.
Pre-motion conferences are required for specified dispositive and related motions except in Social Security, habeas, and pro se matters.
A party requesting a pre-motion conference must file a pre-motion letter capped at three pages with legal citations and a brief motion overview.
Opposing parties must respond to pre-motion letters within five business days in a three-page response, include specified Rule 12 response positions, and may not file replies.
A party may bypass timing aspects of these practices and file within federal-rule deadlines if delay would forfeit a substantive right, but must include an explanatory basis.
In limine motions must be filed 30 days before trial, responses are due 7 days later, and oral argument is scheduled when needed.
A pre-motion conference is required before filing motions, except for listed habeas, default, social security, and bankruptcy matters.
The moving party must submit a pre-motion letter (max three pages) stating the motion basis and proposed briefing schedule.
Responses to pre-motion letters are limited to three pages due within three business days, and replies are barred absent specific authorization.
Summary judgment pre-motion conference requests require a 56.1 statement (except pro se), with 15 business days for response, 10 business days for reply 56.1, and no reply letter.
Parties must obtain Court approval of the briefing schedule before serving motion papers, either at a pre-motion conference or by subsequent ECF letter.
Parties must meet and confer in good faith before filing a discovery motion, and noncompliance can lead to denial.
For dispositive motions, parties must seek a pre-motion conference by letter, with five-page limits for request and response, a seven-day response deadline, and no reply letters without permission.
In civil cases, parties must request a pre-motion conference before Rule 12, Rule 56, venue-change, or Rule 15-leave motions, with stated exceptions.
A moving party seeking a pre-motion conference must file and serve a pre-motion letter capped at three pages that states the motion basis, and timely Rule 12 pre-motion service counts as timely Rule 12(b) motion service.
Unless modified by the summary-judgment subsection, non-movants must file a pre-motion response letter within five business days, limited to three pages.
For Rule 56 motions, the pre-motion letter deadline is fifteen business days after discovery closes unless the Court orders otherwise.
Parties have 15 business days to respond to a pre-motion letter and accompanying 56.1 statement.
Parties have 10 business days to file a reply 56.1 statement, and reply letters are not allowed.
Motion papers cannot be served before the Court enters a briefing schedule, and schedule changes require Court approval.
Appeals of magistrate discovery determinations are due within 14 days, oppositions are due within 14 days after service, and replies are not allowed unless the Court requests one.
Counsel must raise anticipated motions at a status conference or request a written pre-motion conference request stating grounds if no status conference is set.
A moving party must file a brief pre-motion letter, and other parties may optionally respond within five business days.
Motion papers cannot be served until the Court sets a briefing schedule after the pre-motion conference, and schedule changes require Court approval.
For motions in limine, responses are due in ten business days, replies are not allowed, and oral argument is scheduled only if the Court deems it necessary.
Pre-motion conference letter (max 3 pages) required before filing any dispositive motion.
Pre-motion letter responses due within 7 days; affidavits, exhibits, and replies are not permitted.
In limine motion opposition due 10 business days before trial; reply due 5 days before trial.
Parties must make good faith efforts to resolve discovery disputes before filing a motion.
Pro hac vice motions must be filed at least 7 days before the return date.
Opposition to pro hac vice motions due 2 days before return date; reply papers not permitted.
Proposed Joint Pretrial Order must be submitted within 60 days after discovery completion.
Pre-motion conference required for Rule 12, Rule 56, venue change, and Rule 15 motions (except habeas, prisoner, Social Security, and bankruptcy appeals).
Pre-motion conference letters are limited to 3 pages.
Pre-motion conference required before filing Rule 12, Rule 56, venue change, compel arbitration, or remand motions, with exemptions for habeas, prisoner, social security, and bankruptcy cases.
Pre-motion letter limited to 3 pages; opposing response limited to 3 pages and due within 7 days.
Rule 56 pre-motion letters must attach LR 56.1 statement; responses must attach counter-statement.
Pre-motion conference required for dispositive motions (except default judgment), change of venue, and FRCP 15 motions to amend.
Movant must write requesting pre-motion conference with brief description; opposing party may file letter; submissions due 2 business days before conference.
Parties may not serve motion papers before obtaining court approval for the briefing schedule.
Pre-motion conference required for dispositive motions and venue change motions (except discovery motions, habeas/prisoner cases, Social Security/Bankruptcy appeals).
Pre-motion conference letter limited to 3 pages; response letter limited to 3 pages within 7 days.
Parties cannot serve motion papers until court approves the briefing schedule.
Pre-motion conferences required for Rule 12, Rule 56, venue change, and Rule 15 motions, except in bankruptcy/social security/habeas appeals or pro se cases.
Pre-motion conference letters limited to 4 pages (6 pages for Rule 56 motions).
Non-Rule 56 pre-motion conference letters require a response within 5 business days, limited to 4 pages.
Rule 56 pre-motion conference letters require a response within 14 business days, limited to 6 pages.
When pre-motion conference is waived, parties must submit joint letter with proposed briefing schedule within 3 days.
For motions exempt from bundling and pre-motion conference, moving party must confer and submit proposed briefing schedule before filing.
If parties do not propose a briefing schedule, they must follow Local Civil Rule 6.1(b) timing absent good cause.
Moving party must submit proposed briefing schedule with explanatory letter when parties cannot agree.
Parties must confer before initial pretrial conference about anticipated motions in limine.
Pre-motion conference required for specific motion types including Rule 12, 56, 15, venue change, arbitration, remand, and expert challenges.
Rule 56 motions require Local Rule 56.1 statement with pre-motion letter.
Pre-motion conference required for Rule 12, Rule 56, Rule 15 leave, venue change, arbitration, remand, and Daubert motions.
Parties must meet and confer before filing any motion or requesting a pre-motion conference.
Failure to attend required settlement conference precludes filing Rule 56 motions.
Pre-motion letter motion limited to 3 single-spaced pages required to request conference.
Letter response to pre-motion letter limited to 3 single-spaced pages, due within 7 days.
Pre-motion letters for Rule 56 and Daubert motions must be filed within 10 business days after discovery completion.
Rule 56 summary judgment motions require good faith participation in a settlement conference with the magistrate judge before the Court will grant a briefing schedule.
For anticipated Rule 56 motions, pre-motion conference letters must include LR 56.1 statements from both the movant and the opposing party.
Before a TRO motion, the party must file an ECF letter (under seal if ex parte) addressing notice/consent or Rule 65(b)(1) no-notice grounds.
A party seeking a restraining order must identify a mutually agreeable hearing time with the adversary so the Court can hear from both sides before deciding temporary injunctive relief.
The Court will not discuss the JPTO unless parties first participate in a good-faith settlement conference with the assigned magistrate judge, and failure to do so is not grounds for a JPTO deadline extension.
Oppositions to motions in limine must be filed within 7 days of the joint pre-trial order.
Before a Rule 56 briefing schedule or JPTO conference, parties must first participate in a good-faith settlement conference with the assigned magistrate judge.
In cases with a pro se litigant, counsel must submit a proposed briefing schedule for all motions under Individual Rule 5.2.2.
In civil cases, represented movants must request a pre-motion conference before filing specified non-discovery motions, with listed case-type exceptions.
Pre-motion request letters are limited to 3 pages, and response letters are also limited to 3 pages and due within 7 days.
For summary judgment, pre-motion response-letter timing follows the Counter 56.1 schedule and reply letters are prohibited.
Responses to pre-motion requests must be filed under the ECF Letter event, not the pre-motion conference event.
For intended summary judgment motions, pre-motion conference requests must include a Local Rule 56.1 statement, except for pro se parties.
In summary judgment pre-motion practice, responses are due in 15 business days, 56.1 reply statements in 10 business days, and reply letters are not allowed.
Parties must submit a joint briefing schedule for Court approval, and no schedule changes are allowed without Court approval.
For motions with strictly enforced deadlines needed to preserve rights, no pre-motion conference or full-briefing-before-filing requirement applies.
In criminal cases, counsel must raise intended motions at a status conference, or request a written pre-motion conference stating grounds if no status conference is set.
Criminal motion papers cannot be served before a court-ordered briefing schedule, and schedule changes require court approval.
Civil appeals of magistrate discovery determinations have 14-day appeal and opposition deadlines, no reply as of right, and any further reply/briefing only by court direction.
In limine motions must be filed at least 30 days before jury selection, with responses due 14 days after filing, and parties must propose a briefing schedule.
Expert-evidence exclusion motions (including Daubert motions) must be filed at least 45 days before jury selection, and responses are due 14 days after filing.
Counseled civil parties must request a pre-motion conference before specified Rule 12/56 and similar listed motions, with stated case-type exceptions.
Pre-motion conference requests require a 3-page letter motion stating the anticipated motion basis, and non-pro se recipients must file a 3-page response within 7 days.
Parties must attempt to resolve discovery disputes in good faith before filing a discovery motion.
Unresolved discovery disputes must be presented in a single joint ECF filing requesting an informal discovery conference.
Counsel must confer in person or by telephone before seeking court intervention on a discovery dispute.
Before filing a non-dispositive non-discovery motion, the movant must notify other parties at least two days in advance and offer an opportunity to consent.
Oppositions to non-dispositive non-discovery motions are due in 10 business days, and replies are due 5 business days later, unless otherwise ordered.
For dispositive motions on consent before Judge Kuo, a pre-motion conference request is required with a 3-page motion summary, 3-page responses due in 5 business days, no replies, and modifiable response timing.
Pre-motion conferences are required for specified civil motions, with explicit exemptions for certain case categories and pro se matters.
Except in listed exempt case categories, pre-motion conferences are required before specified Rule 12, Rule 56, venue-change, and Rule 15 leave motions.
A pre-motion conference request must be made by a served letter of no more than three pages explaining the anticipated motion basis.
Rule 56 pre-motion letters must include the movant’s Local Rule 56.1 statement.
Parties receiving a pre-motion-conference letter must file a response within five business days, limited to three pages.
For proposed Rule 56 motions, the response pre-motion letter must include a Local Rule 56.1 counterstatement.
Motions in limine must be filed 30 days before trial and responses are due two weeks later, unless the Court orders otherwise.
Pre-motion conferences are required before specified motions in covered cases, with exemptions for bankruptcy, social security, habeas, and pro se matters.
A pre-motion request requires a letter capped at four pages, with additional Rule 56.1 materials for summary judgment motions, and timely service of the letter counts as timely service of the motion under Rules 12 or 56.
Parties must file a pre-motion response within five business days, limited to three pages, and include a Rule 56.1 counterstatement for Rule 56 motions.
Motions in limine must be filed 30 days before trial, and responses are due 2 weeks after filing unless the Court orders otherwise.
In civil cases, dispositive and venue-change motions require a pre-motion conference, with a 3-page pre-motion letter and 7-day responses (also capped at 3 pages), subject to listed exceptions.
Parties must set a briefing schedule before serving motion papers, and court approval is required for the schedule and any changes.
Before a discovery motion proceeds, parties must submit a jointly composed single letter describing the dispute.
In consent cases, dispositive motions generally require a pre-motion conference, with 3-page pre-motion and response letters and a 7-day response deadline, subject to stated exemptions.
Pre-motion conferences are required only for non-venue Rule 12 motions.
A pre-motion settlement conference is required before filing summary judgment motions.
Rule 12 motions require pre-motion conference with 1750-word letters; non-moving party has 7 days to respond; no replies; counsel must appear.
A settlement conference with the assigned magistrate judge is mandatory before filing any motion for summary judgment; telephone conferences do not comply.
Proposed summary judgment briefing schedule must be submitted within 30 days after close of discovery or the right is waived.
Motions in limine briefing schedule: oppositions due 14 days after opening brief, replies due 7 days after opposition.
Motions in limine must be filed 45 days before trial, opposition 14 days later, reply 7 days after that.
Before judicial intervention on other discovery disputes, parties must file a single joint letter on ECF as a motion seeking a discovery conference.
Discovery-dispute joint letters must include the dispute nature, each party’s factual/legal position, and good-faith meet-and-confer efforts.
Pre-motion conferences are mandatory before specified dispositive and venue/amendment motions, except in Social Security and habeas cases.
Filing a pre-motion letter for leave to make a pre-answer dismissal motion stays the deadline to answer or otherwise move against the complaint until the conference date.
Opposing parties must file a response letter within five business days, limited to three pages, and no replies are allowed.
For anticipated Rule 56 motions, no full Local Rule 56.1 statement is required with the pre-motion letter, but the letter must describe the general undisputed material facts.
A Rule 56 pre-motion response letter must describe factual disputes and identify admissible supporting evidence.
In limine motions must be filed 15 days before trial with disputed documents attached, responses are due 5 days later, and oral argument is scheduled if needed.
For discovery or other non-dispositive motions, parties must try in good faith to resolve disputes in person or by phone before filing a motion.
Letter motion briefing requires opposition within four days and does not permit replies.
For summary judgment in represented-party cases, a pre-motion letter is required and no pre-motion conference is required.
In consent cases (except pro se cases), a pre-motion conference letter is required before Rule 12, Rule 56, venue-change, or pleading-amendment motions.
The moving party must submit a pre-motion conference letter, not docketed as a motion, with a three-page maximum.
For letter motions, opposition is due within five business days and no reply is allowed.
Before filing a discovery/non-dispositive motion, parties must meet and confer in good faith by phone or in person.
Represented parties must request and complete a pre-motion conference before dispositive motions, with two-page pre-motion/response letters and a court-approved briefing schedule.
Motions in limine follow a set sequence with opposition due seven days before jury selection and reply due three days before jury selection.
Discovery motions under Rules 26-37 require an informal conference request before the motion will be heard.
A pre-motion conference is mandatory before filing specified motions, including Rule 12, Rule 56, venue change, arbitration, Rule 24 intervention, and Rule 15 leave-to-amend motions.
A pre-motion conference request requires a three-page letter stating the motion basis, and optional responses are limited to three pages within five business days.
For Rule 12 timing purposes, the pre-motion conference letter is treated as the motion itself.
After the Rule 12 pre-motion decision order, plaintiffs have 21 days to amend as of right; amendments after that require leave under Rule 15(a)(2).
Rule 56 motions must be made within 30 days of discovery completion absent good cause, and a timely pre-motion letter satisfies timely service.
Default judgment motions must be noticed after the certificate of default is docketed and set returnable 20 days after service of notice.
Parties must obtain Court approval of a briefing schedule before serving motion papers, and schedule changes require court order.
In criminal cases, counsel must raise contemplated motions at a status conference or submit a written pre-motion conference request stating the grounds before filing.
Sentencing applications must be filed in writing by defense counsel at least five business days before sentencing, and any government response is due at least two business days before sentencing.
Civil motions in limine must be filed by the stated pretrial deadline, with responses due five days later unless otherwise ordered.
Motions to compel filed later than 30 days before discovery closes are untimely absent unforeseen circumstances.
For other non-dispositive motions, parties should first attempt good-faith resolution, then file a letter motion or request a conference before moving.
Pre-motion letters should include legal citations and a brief overview of the anticipated motion.
A party may bypass delay from these procedures and file on the federal deadline if good-faith delay would forfeit a substantive right, but must explain why.
A pre-motion letter served within FRCP 12(a) timing counts as timely service for an FRCP 12(b) motion.
Pre-motion conferences are exempted in listed categories (including pro se and several case types), and discovery motions follow Local Civil Rules 6.4 and 37.3.
Early summary judgment motions require a letter of no more than 700 words explaining why early practice should be permitted, with 700-word responses allowed within 7 days.
Daubert motions must be made by summary judgment briefing deadline, not treated as motions in limine; parties may request suspension of expert briefing if good cause exists.
For motions, the Court sets the briefing schedule and parties may request oral argument.
The Court sets briefing schedules, and parties are encouraged to submit joint schedule proposals.
A pre-motion letter served within FRCP 12(a) timing counts as timely service for an FRCP 12(b) motion.
Pre-motion conferences are exempted in listed categories (including pro se and several case types), and discovery motions follow Local Civil Rules 6.4 and 37.3.
Pre-motion conference letter requirements do not apply to Rule 50, Rule 59, and Rule 60 motions.
In appropriate cases, pre-motion submissions and conference argument may be treated as the motion itself, and unraised arguments are deemed waived.
Serving a pre-motion letter within Rule 12 or Rule 56 deadlines counts as timely motion service under those rules.
A party may bypass the pre-motion letter requirement to avoid loss of rights but must file an explanatory letter with the motion.
In appropriate cases, the Court may treat the pre-motion letter as the motion itself.
Oral argument is not available on letter motions unless the Court specifically orders it.
Sur-replies are prohibited unless the Court grants prior leave.
Motions implicating time-limiting rules are exempt from pre-motion conference requirements.
The Court may treat pre-motion letters as the motion and opposition, hold a hearing, and deem unraised arguments waived.
A Local Civil Rule 56.1 statement is not required at the pre-motion-letter stage for anticipated Rule 56 motions.
The Court may treat the pre-motion materials as the motion and may bypass a pre-motion conference by setting a briefing schedule directly.
In pro se cases, the court may waive pre-motion conference requirements case-by-case, but default practice still requires using the standard pre-motion request procedure unless another exception applies.
In criminal cases, counsel must raise contemplated motions at a Court-scheduled status conference or as directed by pretrial order.
Parties must make good faith efforts to resolve disputes before filing other non-dispositive motions.
Response to pre-motion conference letter is optional, limited to 3 pages, due within 7 days.
Parties may bypass pre-motion conference if delay would deprive substantive right, by filing within FRCP time with explanation.
Any opposition to a pre-trial memorandum must be filed within one week of the joint pre-trial order filing.
Using the wrong ECF event for a pre-motion conference request can lead to denial without prejudice.
Serving the pre-motion letter within applicable Rule 12/56 deadlines counts as timely service of the motion.
Pre-motion conference letters are not required for Rule 50, 59, or 60 motions.
Pre-motion conferences are generally not required for criminal motions except as stated in Section IV.A(1).
Pre-motion conference letter requests are not required for Rule 50, 59, and 60 motions.
Parties must submit a briefing schedule for court approval, and any changes require further court approval.
Non-dispositive pretrial applications should generally be made by letter motion first, with formal motion briefing only if the Court directs it.
When parties consent to Judge Cross-Goldenberg, dispositive motions do not require a pre-motion conference.
When needed, the court sets the dispositive-motion briefing schedule at the pre-motion conference.
Briefing schedules are set at the pre-motion conference when applicable.
A party may bypass pre-motion timing requirements to protect a substantive right if it files within federal deadlines and explains the basis.
When a pre-motion conference is held, the Court sets the briefing schedule there, with prompt post-conference motion filing expected.
A party may bypass pre-motion procedures and file directly if delay would in good faith deprive a substantive right, but must include an explanation.
Early summary judgment motions require a letter of no more than 700 words explaining why early practice should be permitted, with 700-word responses allowed within 7 days.
Daubert motions must be made by summary judgment briefing deadline, not treated as motions in limine; parties may request suspension of expert briefing if good cause exists.
Motions to compel filed later than 30 days before discovery closes are untimely absent unforeseen circumstances.
For other non-dispositive motions, parties should first attempt good-faith resolution, then file a letter motion or request a conference before moving.
Pre-motion letters should include legal citations and a brief overview of the anticipated motion.
A party may bypass delay from these procedures and file on the federal deadline if good-faith delay would forfeit a substantive right, but must explain why.
A joint discovery-dispute letter used to request a conference is limited to five pages.
Pre-motion conferences are not required for listed categories of motions and case types, and the Court may waive them when unnecessary.
Criminal motion filing and scheduling follow the civil motion rules except for sentencing motions, unless the Court orders otherwise.
When parties consent to Judge Kaminsky’s jurisdiction, dispositive motions do not require a pre-motion conference.
Motions for reconsideration and Fed. R. App. P. 4(a)(4)(A) motions do not require pre-motion conference.
Briefing schedule approval can be granted at pre-motion conference or by letter.
Pre-motion conference not required for post-trial motions, remand, reconsideration, habeas/prisoner petitions, social security appeals, bankruptcy appeals, or R&R objections.
Motions for reconsideration are exempt from Rules IV(A) and IV(B).
All criminal motions are set for oral argument on a date determined by the Court.
In non-jury cases, parties may submit a 700-word joint letter explaining why summary judgment practice should be permitted.
When parties consent to Judge Kaminsky’s jurisdiction, dispositive motions do not require a pre-motion conference.
The Court may skip a pre-motion conference and may, in appropriate cases, treat the pre-motion submission and conference arguments as the motion itself.
Oral argument on criminal motions is discretionary with the Court, though parties may request it.
All criminal motions are set for oral argument on a date determined by the Court.
The pre-motion conference may be the only oral-argument opportunity, and counsel should expect a short post-conference motion filing schedule.
Discovery and other non-dispositive letter motions do not require a pre-motion conference.
Pre-motion conference requests are not required for motions other than those specifically covered elsewhere.
Pre-motion conference letters are not required for non-enumerated motions, including Rules 50, 59, and 60 motions.
Oral argument is the default for all motions unless the Court directs otherwise.
Pre-motion conference letters are not required for Rule 50, 59, and 60 motions.
Pre-motion conference not required for post-trial motions, remand, reconsideration, habeas/prisoner petitions, social security appeals, bankruptcy appeals, or R&R objections.
Motions for reconsideration are exempt from Rules IV(A) and IV(B).
Motions for reconsideration and Fed. R. App. P. 4(a)(4)(A) motions do not require pre-motion conference.
Briefing schedule approval can be granted at pre-motion conference or by letter.
Requests for adjournments or extensions in arbitration/mediation are referred to Magistrate Judge.
Rule 56.1 Statement not required with pre-motion conference letter (effective November 13, 2025).
Responding party need not file Rule 56.1 Statement when responding to pre-motion conference request.
Emergency exception allows filing without pre-motion compliance if delay would deprive substantive right or cause statutory deadline miss.
Pre-motion conference letter motions are not required for motions for judgment as a matter of law (Rule 50), new trial (Rule 59), or relief from judgment (Rule 60).
The Court may bypass a pre-motion conference and set a motion schedule directly when a conference would not be useful.
No court pre-motion conference is required for non-dispositive non-discovery motions.
The Court may dispense with a pre-motion conference and set a briefing schedule directly.
The Court may skip the conference and set briefing directly, and if a conference occurs the Court sets the briefing schedule there with prompt motion filing expected.
In non-jury cases, parties may submit a 700-word joint letter explaining why summary judgment practice should be permitted.
No pre-motion conference is required for these non-dispositive motion procedures.
No pre-motion conference is required for motions submitted to Magistrate Judge Scanlon.
In criminal cases, oral argument dates for motions are set by the Court.
Southern District of Texas
View all rules for SDTX.Before filing a discovery dispute motion, the complaining party must submit a maximum 2-page letter to the Case Manager and Law Clerks including a certificate of conference with specified good-faith resolution effort details.
Default judgment requires first filing Request for Entry of Default, then Motion for Default Judgment after default entry.
Parties must confer and identify unopposed requests before filing Motions in Limine.
Pre-motion letter required for discovery/scheduling dispute motions, must include nature of dispute, issues, and contested matters; lead counsel must confer before involving court.
For discovery/pretrial dispute letters, opposing party must submit a responsive letter of similar length; reply letters are prohibited.
For e-discovery disputes, each party must have a person with detailed knowledge of relevant systems available at any conference.
Counsel’s designated attorney-in-charge must appear at the Scheduling Conference; substitution requires good cause and motion filed well in advance.
Conference attendees must be familiar with the case, prepared to discuss motions/ADR, and authorized to bind the client.
Applications for restraining orders or immediate relief must be submitted through the Case Manager, with affirmation that opposing party was contacted and both parties are available for an in-chambers conference.
Ex parte restraining order applications are only considered if they meet Federal Rule of Civil Procedure 65(b) requirements.
Telephone appearances prohibited at initial pretrial/scheduling conferences; initial conferences held by videoconference unless parties prefer otherwise.
Mandatory pre-motion conference required for discovery/scheduling disputes; joint letter (max 3 pages) must be emailed to Case Manager.
Pre-motion conference required before filing discovery or scheduling motions; court resolves disputed issues, determines need for written submissions, and sets filing schedule.
Motion responses due 21 days after motion filing; replies due 7 days after response; no sur-replies permitted without court leave.
Lead counsel must personally confer on all discovery and scheduling disputes before involving the Court.
Pre-motion letter (max 2 pages) required to seek permission to file discovery/scheduling dispute motions, must include specified content and copy all parties.
Discovery and scheduling motions require prior permission and lead counsel conference before filing.
Pre-motion letters are limited to 2 pages, must include specified content, require responsive letters of similar length, prohibit replies, and copies must be sent to all counsel and unrepresented parties.
Discovery and scheduling motions require prior court permission via a max 2-page pre-motion letter after lead counsel personally confers with opposing counsel.
Pre-motion letters must be served on all counsel and unrepresented parties.
Opposing party must promptly submit a responsive letter of similar length to the initial pre-motion letter, identifying any disagreement.
Reply letters to responsive pre-motion letters are prohibited.
Adversary proceeding motions are governed by FRCP and FRBP, not subject to negative notice, court sets hearing and response deadline, may rule without hearing after response deadline.
Court deviates from BLR 3007(d) for proof of claim objections; evidentiary hearing proceeds on initial date if objection and response are filed.
Debtors must provide at least 48 hours notice of cash collateral motions and expedited hearings to specified parties via email/phone/fax and Fed. R. Bank. P. 7004.
Restraining order applications require affirmation of opposing party contact/availability or explanation of why contact is not required.
Ex parte restraining order applications are only allowed if Fed. R. Civ. P. 65(b) requirements are met.
Parties must seek resolution of motions to seal in advance of applicable filing deadlines.
Discovery and scheduling motions require prior permission via a 2-page pre-motion letter after lead counsel confer, with responsive letters allowed but no replies.
Ex parte restraining order applications are only permitted if they meet Federal Rule of Civil Procedure 65(b) requirements.
In minor plaintiff cases with potential conflict of interest, counsel must jointly move to appoint attorney ad litem prior to mediation or ADR.
In settled minor plaintiff cases with no conflict, counsel must jointly move to appoint attorney ad litem for the settlement hearing.
Parties challenging Confidential Information designations must attempt good-faith dispute resolution before seeking court intervention.
Responses to trustee motions for payment defaults must be filed within 20 days of service and comply with Federal Rule of Bankruptcy Procedure 9011.
Government has 14 days to respond to motions to suppress evidence.
Counsel must confer with opposing counsel on all motions to attempt to reach agreement before filing.
Motions to Dismiss, Sever, and for Separate Trial must be specific and filed at least 30 days before jury selection.
Opposed filings requesting relief trigger a 7-day response deadline for opposing parties.
Motions in limine optional for unique evidentiary disputes; court may strike boilerplate motions; counsel must seek permission for potentially prohibited trial conduct via motion in limine.
Restraining order applications are presented to the Court by the Case Manager after counsel affirms opposing party contact and both parties' availability for conference.
Ex parte restraining order applications are only entertained if they meet Federal Rule of Civil Procedure 65(b) requirements.
Opposed motions require response within 21 days, reply within 10 days after response; sur-replies allowed per local rules, and court may rule when motion is ripe.
Pre-motion conference is required before filing motions or briefs related to disputed discovery or pretrial matters.
Ex parte restraining order applications will not be considered by the Court unless all FRCP 65(b) requirements are satisfied.
Restraining order/immediate relief applications require a pre-court conference, with counsel affirming both parties are available for the conference.
Pre-motion letter (max 2 pages) required before filing discovery dispute motions, emailed to Case Manager and Law Clerks with opposing counsel included; opposing counsel has 3 days to respond.
Motion responses must be filed within 21 days per Local Rule 7.4, unless the Court orders an expedited response.
Reply briefs must be submitted within 7 days of non-movant’s response to the motion.
Sur-replies are rarely considered and require leave of court to file.
Default judgment seekers must first file Request for Entry of Default per Rule 55(a), then Motion for Default Judgment upon default entry.
Motion responses due 21 days after filing; replies due 7 days after response.
Surreplies and sur-surreplies require leave of court by motion.
Criminal motions to suppress must be filed before pretrial conference unless the court orders otherwise.
Motions to compel discovery may not be filed without first submitting the required joint dispute letter.
Applications for restraining orders/immediate relief must be submitted via Case Manager with affirmation of opposing party contact and availability for in-chambers conference; ex parte TROs require Rule 65(b) compliance.
Unsuccessful conference attempts less than two full business days before motion filing do not satisfy the conference requirement; parties should begin conferring at least two full business days before motion deadlines.
Replies must be filed within 7 days of the response filing date.
Parties must confer on any continuance request in criminal cases before filing.
Parties must confer in good faith before filing a motion for a protective order differing from the standard Form 9.
Parties must jointly confer in good faith before filing a motion for a different ESI order.
Lead counsel must personally confer on all discovery and scheduling disputes before involving the Court.
Pre-motion letters (~2 single-spaced pages) required for discovery/scheduling disputes, with responsive opponent letters, no replies allowed.
Lead counsel must confer in good faith to resolve privilege log disputes before submitting in camera inspection request letters, and letter must identify conference and results.
Rule 12(b)(6) and 12(c) motions require pre-filing good faith conference with opposing party identifying issues, and certificate of conference must reference this.
Mediation or settlement conference with Magistrate Judge required within 45 days of Rule 56 summary judgment motion filing; joint report of success/impasse required before motion is considered.
Motions on discovery or scheduling disputes require alternate permission under Section 15 before filing.
Civil case motion responses due 21 calendar days after motion filing, replies due 10 calendar days after response; surreplies prohibited without advance permission.
Criminal case motion submission and briefing deadlines follow CrLR12 and Federal Rule of Criminal Procedure 12.
Amicus briefs require leave by motion with the brief attached as an exhibit; party responses to amicus briefing are freely allowed.
Prior permission required to file a surreply.
Responses to motions in limine must be filed within 7 days of the motion; optional replies within 4 days.
Parties must seek resolution of motions to seal in advance of applicable filing deadlines.
Parties must jointly confer in good faith on protective order terms before filing a motion for entry of a protective order.
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.
Letter (max 3 single-spaced pages) required to request in camera review of privilege logs; lead counsel must confer first, limited to 20 documents, one letter per party.
Parties must make good faith efforts to resolve disputes before filing any motion.
Before filing Rule 12(b)(6) or 12(c) motions, parties must identify issues and confer in good faith.
Rule 56 motions require mediation/settlement conference within 45 days of filing, joint report after, motion not considered before report.
Discovery or scheduling dispute motions may not be filed without prior permission under Section 13.
Civil motion responses due 21 calendar days after motion, replies 10 days after response, sur-replies prohibited without advance permission.
Contested motions in limine require a response filed within three business days after the Joint Pretrial Order is filed.
Pre-motion letter required for discovery/scheduling dispute motions, must include nature of dispute, issues, and contested matters; lead counsel must confer before involving court.
For discovery/pretrial dispute letters, opposing party must submit a responsive letter of similar length; reply letters are prohibited.
For e-discovery disputes, each party must have a person with detailed knowledge of relevant systems available at any conference.
Counsel’s designated attorney-in-charge must appear at the Scheduling Conference; substitution requires good cause and motion filed well in advance.
Conference attendees must be familiar with the case, prepared to discuss motions/ADR, and authorized to bind the client.
Discovery and scheduling motions require prior permission via a 2-page pre-motion letter after lead counsel confer, with responsive letters allowed but no replies.
Restraining order applications are presented to the Court by the Case Manager after counsel affirms opposing party contact and both parties' availability for conference.
Ex parte restraining order applications are only entertained if they meet Federal Rule of Civil Procedure 65(b) requirements.
Opposed motions require response within 21 days, reply within 10 days after response; sur-replies allowed per local rules, and court may rule when motion is ripe.
Pre-motion conference is required before filing motions or briefs related to disputed discovery or pretrial matters.
Pre-motion conference required before filing specified motions (except in habeas, prisoner, Social Security, Bankruptcy appeals), with mandatory 3-page pre-motion letter and optional 3-page response due within 5 days.
Pre-motion conference letters are not required for motions under Fed. R. Civ. P. 50, 59, or 60.
Parties must confer with opposing counsel on all motions to reach agreement on requested relief.
Nonmovant responses due 21 days after motion filing, replies due 7 calendar days after response; no sur-replies without leave of court.
Parties filing discovery or scheduling motions must arrange a pre-motion conference with the Court before submitting motion papers.
Counsel must confer in good faith to resolve discovery/scheduling disputes; if unresolved, must seek Court conference via joint letter with required content.
Counsel must confer with opposing counsel on all motions; failure to comply may result in denial or striking of the filing.
Opposed motions: responses due 21 calendar days after motion filing, replies due 7 calendar days after response; considered after 28 days.
Counsel must confer in good faith to resolve discovery and scheduling disputes before filing motions.
Counsel must confer with opposing counsel on all motions to reach agreement before filing.
Motions to Dismiss, Sever, and for Separate Trial must be specific and brought to the Court’s attention at least 30 days before jury selection.
Parties must conduct timely plea negotiations, review plea agreements before FPTC, and be ready to plead or proceed to trial at FPTC; monthly FPTC is held to rule on motions and conduct re-arraignments.
Counsel must confer with opposing counsel on all motions to reach agreement on requested relief.
Opposed motions are considered 28 days after filing; non-movant responses due 21 days after motion, replies due 7 days after response.
Counsel must confer in good faith to resolve discovery and scheduling disputes.
Counsel must confer with opposing counsel on all motions to reach agreement on requested relief.
Motions to Dismiss, Sever, and for Separate Trial must be brought to the Court's attention at least 30 days before jury selection.
Opposing parties must respond to opposed filings requesting relief within 7 days of filing.
The Government has 14 days to respond to motions to suppress evidence.
Ex parte TRO applications are only entertained if the initiating party satisfies Rule 65(b) requirements.
Counsel must confer by phone/video before requesting court conference on discovery dispute; must file 3-page letter with required content.
Discovery disputes must be addressed at a conference before filing a motion, with briefing schedule set during the conference if motion is necessary.
Parties must discuss options to reduce e-discovery burdens before seeking court intervention for electronic data disputes.
Counsel resisting e-discovery must be prepared to discuss search/production burdens or have a knowledgeable person available.
Discovery motions must follow Section III Discovery Disputes procedures and fail to resolve the dispute before being filed.
Parties must make good faith attempt to resolve all discovery and scheduling disputes without court intervention; sanctions for bad faith.
Lead counsel must personally confer on all discovery and scheduling disputes before involving the Court.
Initiating letter (max ~2 single-spaced pages) required to obtain permission to bring motion on discovery/scheduling disputes, must include specific content.
Opposing party must submit responsive letter (similar length to initiating letter) to discovery/scheduling dispute initiating letter; reply letters prohibited.
Parties must have a person with detailed knowledge of relevant electronic systems available at conferences for electronic data discovery disputes.
Motions on discovery or scheduling disputes prohibited without permission obtained under Section 13.c.
Requests for in camera inspection of privilege log documents require a letter (max ~3 single-spaced pages) with specific content, after lead counsel conference.
Only one in camera inspection request letter allowed per party, due 60 days before discovery ends or promptly on receipt of later privilege log.
Good faith efforts to seek agreement required for all disputed matters except dispositive motions.
Pre-filing conference and issue identification required for Rule 12(b)(6) and 12(c) motions in civil cases; certificate of conference must include this.
Opposed motions are considered 28 days after filing; responses due 21 days post-motion, replies 7 days post-response; no sur-replies without permission.
Telephone appearances prohibited at initial pretrial/scheduling conferences; initial conferences held by videoconference unless parties prefer otherwise.
Mandatory pre-motion conference required for discovery/scheduling disputes; joint letter (max 3 pages) must be emailed to Case Manager.
Pre-motion conference required before filing discovery or scheduling motions; court resolves disputed issues, determines need for written submissions, and sets filing schedule.
Motion responses due 21 days after motion filing; replies due 7 days after response; no sur-replies permitted without court leave.
Counsel must confer with opposing counsel on all motions to reach agreement on requested relief.
Opposed motions are considered after 28 days, with non-movant responses due in 21 days and replies in 7 days after response; court may consider earlier if needed.
Counsel must confer in good faith to resolve discovery and scheduling disputes before seeking court intervention.
Government has 14 days to respond to motions to suppress evidence.
Counsel must confer with opposing counsel on all motions to attempt to reach agreement before filing.
Motions to Dismiss, Sever, and for Separate Trial must be specific and filed at least 30 days before jury selection.
Opposed filings requesting relief trigger a 7-day response deadline for opposing parties.
Motions in limine optional for unique evidentiary disputes; court may strike boilerplate motions; counsel must seek permission for potentially prohibited trial conduct via motion in limine.
Ex parte restraining order applications are only considered if FRCP 65(b) requirements are met.
Oppositions to motions must be filed within 21 days of the motion's filing with the District Clerk.
Replies to oppositions must be filed within 10 days of the opposition's filing with the District Clerk.
Surreplies must be filed within 10 days of the reply's filing with the District Clerk.
Failure to respond to an opposed motion constitutes no opposition; Court rules when motion is ripe regardless of response.
Discovery motions must state that counsel conferred in good faith with opposing counsel and jointly telephonically conferred with the Court, or recite attempt facts if opposing counsel was unavailable/unwilling.
Discovery motions must be filed more than 21 days before the discovery deadline to allow opposing counsel time to respond.
Counsel must obtain advance leave from the Court to offer evidence or testimony at a motion hearing.
Joint motion for appointment of attorney ad litem required before ADR if conflict exists between parent/guardian and minor.
Joint motion for appointment of attorney ad litem required upon settlement to represent minor at settlement hearing.
Responses to dispositive and non-dispositive motions must be filed within 21 days of the motion's filing.
Motions to withdraw guilty/nolo pleas must be filed within 14 days of plea hearing; objections to Magistrate Judge’s R&R must be filed within 14 days of R&R execution; hearing must be scheduled within 30 days of filing.
Counsel who waives a motion hearing must obtain leave of court to file subsequent motions.
Motions to Dismiss (Rule 12) and Motions to Sever must be in writing, state their basis with supporting authority, follow the Scheduling Order, and hearings are granted at the Court’s discretion.
Ex parte restraining order applications are only permitted if they meet Federal Rule of Civil Procedure 65(b) requirements.
In minor plaintiff cases with potential conflict of interest, counsel must jointly move to appoint attorney ad litem prior to mediation or ADR.
In settled minor plaintiff cases with no conflict, counsel must jointly move to appoint attorney ad litem for the settlement hearing.
Emergency applications are presented to the Court only after counsel confirms the opposing party is contacted and both parties are available for a conference.
Responses to opposed motions due 21 days after filing; replies due 10 days after response; no response deemed consent.
Motions to Dismiss, Sever, and Separate Trial must be specific and filed 30+ days before jury selection.
Parties challenging Confidential Information designations must attempt good-faith dispute resolution before seeking court intervention.
Pre-motion initiating letter (max ~2 single-spaced pages) required to obtain permission to file motions on discovery or scheduling disputes.
Letter (max ~3 single-spaced pages) required to request in camera inspection of up to 20 privilege log documents, with lead counsel conferring beforehand.
Before filing Rule 12(b)(6) or 12(c) motions in civil cases, counsel must identify pleading issues and confer in good faith; certificate of conference must confirm this.
Discovery or scheduling dispute motions may only be filed with prior permission under Section 13.c.
Civil motion responses due 21 calendar days after filing; replies due 7 days after response, no sur-replies without permission.
Parties must confer in good faith before filing motions in limine to resolve undisputed issues.
Lead counsel must personally confer on all discovery and scheduling disputes before involving the Court.
Pre-motion letter (max 2 pages) required to seek permission to file discovery/scheduling dispute motions, must include specified content and copy all parties.
Discovery and scheduling motions require prior permission and lead counsel conference before filing.
Pre-motion letters are limited to 2 pages, must include specified content, require responsive letters of similar length, prohibit replies, and copies must be sent to all counsel and unrepresented parties.
Discovery, scheduling, compel, quash, protection, and extension motions require court permission before submission; lead counsel must personally confer prior to involving the court.
Pre-motion letters are required (max 2 pages) with specific content; responsive letters of similar length due promptly, no reply letters allowed, and copies sent to all parties.
Applications for restraining orders or immediate relief must be submitted through the Case Manager, with affirmation that opposing party was contacted and both parties are available for an in-chambers conference.
Ex parte restraining order applications are only considered if they meet Federal Rule of Civil Procedure 65(b) requirements.
Counsel and pro se parties must confer with opposing counsel regarding all motions before filing.
Discovery dispute conference materials must be filed at least 24 hours before the conference date.
Discovery disputes are resolved at initial conference; if motion is needed, issues and briefing schedule are set at the conference.
Parties must discuss electronic discovery disputes in person/phone/video before seeking court intervention; resisting parties must have a person to discuss burdens.
Discovery motions may only be filed after completing and failing to resolve the dispute via Section III discovery procedures.
Pre-motion permission via letter required for discovery and scheduling dispute motions; lead counsel must confer personally before seeking court intervention.
Pre-motion letter (max 2 pages) and lead counsel conference required for discovery/scheduling motions including compel, quash, protection, extension.
Discovery and scheduling motions require prior court permission via a max 2-page pre-motion letter after lead counsel personally confers with opposing counsel.
Pre-motion letters must be served on all counsel and unrepresented parties.
Opposing party must promptly submit a responsive letter of similar length to the initial pre-motion letter, identifying any disagreement.
Reply letters to responsive pre-motion letters are prohibited.
Movant must attempt a pre-filing conference before filing relevant motions.
Movant must provide a contact person with direct telephone number for future conferences.
Respondent must respond to pre-filing conference within two days.
Form M-2 responses may only be filed if no agreement is reached following a required pre-filing conference.
Motions to approve use of non-conforming motions or orders must demonstrate exceptional circumstances.
Non-conforming motions or orders may only be used after obtaining approval via a separate motion.
Exceptional circumstances for approving non-conforming motions or orders are determined by a preponderance of the evidence standard.
Responses to trustee motions for payment defaults must be filed within 20 days of service and comply with Federal Rule of Bankruptcy Procedure 9011.
Discovery disputes that cannot be resolved between parties should ordinarily be submitted by written motion.
Adversary proceeding motions are governed by FRCP and FRBP, not subject to negative notice, court sets hearing and response deadline, may rule without hearing after response deadline.
Court deviates from BLR 3007(d) for proof of claim objections; evidentiary hearing proceeds on initial date if objection and response are filed.
Debtors must provide at least 48 hours notice of cash collateral motions and expedited hearings to specified parties via email/phone/fax and Fed. R. Bank. P. 7004.
Amendment of signed orders requires filing a motion to amend, not just submitting a proposed amended order.
Counsel and pro se parties must cooperate, consult, and exchange discoverable information upon informal written request.
Discovery dispute motions may only be filed after exhausting extrajudicial resolution means.
Oppositions to discovery motions must be filed within 7 days; replies within 7 days of opposition.
Movants must confer with opposing parties and obtain a hearing date from the judge's website before filing a motion for relief from stay.
Applications for restraining orders or immediate relief must be submitted via Case Manager with affirmation of opposing party contact and availability for in-chambers conference; ex parte TROs only allowed if Rule 65(b) satisfied.
Court follows local rules for written motion practice; most motions decided without oral hearing, considered after submission date.
Unsuccessful attempts to confer with opposing counsel less than two full business days before motion filing do not satisfy the conference requirement; parties should begin conferral at least two business days before deadlines.
Counsel for criminal jury trials must confer on non-pattern jury instructions, submit agreed parts and competing versions if unable to agree.
Counsel may schedule optional telephonic conference with court if conferring fails to resolve motion; unresolved motions require hearing with motion listing issues and confirming conferring.
Counsel must jointly move for appointment of attorney ad litem before mediation/ADR if conflict exists between parent/guardian and minor.
Counsel must jointly move for appointment of attorney ad litem upon settlement involving a minor plaintiff.
Before filing a discovery dispute motion, the complaining party must submit a maximum 2-page letter to the Case Manager and Law Clerks including a certificate of conference with specified good-faith resolution effort details.
Default judgment requires first filing Request for Entry of Default, then Motion for Default Judgment after default entry.
Parties must confer and identify unopposed requests before filing Motions in Limine.
Restraining order applications require affirmation of opposing party contact/availability or explanation of why contact is not required.
Ex parte restraining order applications are only allowed if Fed. R. Civ. P. 65(b) requirements are met.
Applications for restraining orders or immediate relief must be submitted through the Case Manager, who will present them after counsel confirms opposing party contact and availability for conference.
Ex parte restraining order applications are only allowed if the requirements of Federal Rule of Civil Procedure 65(b) are met.
Dispositive motions are due 30 days after mediation/settlement conference impasse; such conference with magistrate judge is required before filing dispositive motions.
Pre-motion conference with court required before filing motions for disputed discovery or other pretrial matters, with 1-2 page agenda letter required.
Parties must arrange a pre-motion conference with the court before preparing or submitting discovery motions, including motions to compel, quash, or for protection.
Ex parte restraining order applications will only be considered if the initiating party complies with Rule 65(b) requirements.
Pre-motion letter (max 2 single-spaced pages) required before filing discovery or scheduling dispute motions; responsive letters allowed, no replies.
Discovery or scheduling dispute motions may not be filed without prior permission under Section 13.c.
Civil opposed motions: responses due 21 calendar days after motion filing; replies (if any) due 7 days after response; sur-replies prohibited without permission.
Criminal case motion briefing follows CrLR12 and Federal Rule of Criminal Procedure 12.
Parties must confer in good faith on motions in limine to resolve undisputed issues before filing.
Motions in limine are prohibited in bench trials.
Motions in limine may not raise topics already resolved under Daubert or summary judgment.
Counsel should set Chapter 11 Applications to Employ for hearing and may seek expedited consideration.
Debtors should request emergency consideration for first day motions in Chapter 11 cases.
Counsel who repeatedly fail to return phone calls related to the conference requirement may face sanctions.
Parties must have a person with detailed electronic data knowledge available at conferences on electronic discovery disputes.
Parties must attempt to resolve discovery and scheduling disputes without court intervention; bad faith may result in cost shifting.
Counsel should set Chapter 11 Applications to Employ for hearing and may seek expedited consideration.
Debtors should request emergency consideration for first day motions in Chapter 11 cases.
The Court may rule on a motion before the response filing deadline expires.
Court may resolve discovery/scheduling disputes via letters or telephonic/video conference, and set briefing schedule if motion is allowed.
Court will rule on default judgment motions with no hearing no sooner than 21 days after filing.
Oral argument requests are not required; the Court will notify counsel if oral argument is deemed beneficial.
Initiating letter not required for discovery relief motions against nonparties.
Separate requests for oral argument on motions are not required; the Court will notify counsel if oral argument is warranted.
Oral argument is not required for motions; the Case Manager will notify counsel if oral argument is deemed beneficial.
Oral argument requests for motions are not required; Case Manager will notify counsel if Court determines oral argument is beneficial.
Initiating letter not required for discovery relief against nonparties.
Criminal case motion briefing follows CrLR12 and Federal Rule of Criminal Procedure 12.
The Court may rule on a motion before the response filing deadline expires.
The Court typically rules on opposed motions by submission only, without oral argument.
Oral argument requests are not required; the Court will notify counsel if a motion hearing is deemed beneficial.
All ripe motions will be addressed at the next scheduled status conference unless counsel receives contrary notice.
The Court will issue timely rulings and provide order copies for motions decided without a hearing or taken under advisement.
All pending motions are considered at the Final Pretrial Conference.
Criminal motion briefing deadlines follow CrLR12 and Rule 12 of the Federal Rules of Criminal Procedure.
Court may resolve discovery/scheduling disputes via letters or telephonic/video conference, and set briefing schedule if motion is allowed.
Oral argument requests are not required; the Court will notify counsel via the Case Manager if oral argument is deemed beneficial.
All pending motions may be ruled on during the Final Pretrial Conference.
If counsel cannot agree on attorney ad litem for minor, each submits three names; Court appoints one.
Court follows Local Rules written motion practice; most motions are decided without oral hearing and are considered after the submission date.
Oral argument requests are not required; court will notify counsel if oral argument is beneficial. Counsel must be prepared to discuss pending motions at all conferences, hearings, and docket calls.
Southern District of California
View all rules for SDCA.Meet and confer required before filing most motions; statement of compliance required in notice of motion.
Motion hearing dates must be obtained from chambers before filing; papers due within 3 days of obtaining date.
Meet and confer required before filing ex parte motions.
Motions in limine: 28 days to file, 14 days to oppose.
No reply briefs for motions in limine.
Maximum 10 motions in limine per side.
Motions in limine must be filed 14 days before hearing, opposition 7 days before, no replies
Motions must be filed 14 calendar days before hearing; oppositions 7 days before.
Motions in Limine are due 14 days before hearing, opposition due 7 days before, no replies permitted.
Conference with opposing counsel required at least 7 days before filing any noticed motion.
Sur-replies and notices of supplemental authority require leave of court.
Cross-motion in summary judgment requires ex parte consolidated briefing schedule.
Separate Statements of Fact require leave of court.
Ex parte applications require meet-and-confer with opposing counsel
TRO motions must be briefed; ex parte hearings only in extraordinary circumstances.
Motion hearing dates must be Mondays between 28-45 days after filing.
All arguments must be raised in opening brief; new arguments in reply may be disregarded.
Non-opposition statements must be filed 14 days before hearing.
Meet and confer required before motions to amend pleadings, with declaration if no agreement reached.
Parties must meet and confer to create joint statement of disputed/undisputed facts for summary judgment, filed with reply brief.
TROs and preliminary injunctions must be briefed; ex parte hearings only in extraordinary circumstances.
Meet and confer required before ex parte applications, with declaration documenting efforts and service required.
Motions in limine have strict deadlines: file by 4 weeks before trial, opposition by 2 weeks before trial, no reply briefs allowed.
Meet and confer required before filing motions in limine to resolve disputes.
Hearing date sets briefing schedule only; no oral argument unless separately ordered.
Ex parte motions require meet-and-confer declaration documenting contact efforts and opposing counsel's position.
Motions must be filed at least 14 days before the noticed hearing date.
Pretrial motions filed 14 days before hearing; oppositions 7 days before.
Parties must meet and confer before filing a sealing motion and seek the narrowest possible sealing order.
Before filing specified pretrial submissions, counsel must conduct a face-to-face meet-and-confer, and phone/email/written exchanges are insufficient absent leave of court.
Motions in Limine must be filed after in-person meet-and-confer with declaration of efforts
Motions in limine must be filed three weeks before hearing, responses two weeks before.
Must move for admission or allow Court to inquire about objections before publishing exhibits to jury.
Meet-and-confer required before filing most motions.
Meet-and-confer must be in person or by videoconference.
7-day meet-and-confer conference required before filing most motions.
Ex parte applications require meet-and-confer declaration documenting contact efforts and opposing counsel's position.
Temporary restraining order motions must be briefed; ex parte hearings only in extraordinary circumstances.
Replies to motions in limine not permitted unless directed by Court.
Motion hearing dates must be obtained from law clerk before filing; sur-replies require ex parte leave.
Motions in limine due 2 weeks before hearing; responses due 7 days before.
Motions must be filed 14 days before hearing; oppositions 7 days before.
Motions in limine due 2 weeks before hearing; oppositions due 1 week before.
Meet and confer required before filing ex parte motions.
Motions in limine: 28 days to file, 14 days to oppose.
No reply briefs for motions in limine.
Maximum 10 motions in limine per side.
Rule 12(b) motions require informal conference before filing, with statement due 2 days before.
Motion must be filed when scheduling hearing date with Law Clerk.
Motions in limine must be filed 2 weeks before hearing, oppositions 1 week before, no reply briefs.
Request special equipment via joint/ex parte motion at least 7 days before hearing/trial.
Meet and confer required before filing most motions; statement of compliance required in notice of motion.
Motion hearing dates must be obtained from chambers before filing; papers due within 3 days of obtaining date.
Briefing schedule must follow Civil Local Rule 7.1(e) unless Court orders otherwise.
Motion hearing dates must be obtained from chambers before filing, with 3-day filing deadline.
Meet and confer required 7 days before filing most motions, with declaration requirement.
Leave of Court required before filing sur-replies or notices of supplemental authority.
Separate Statements of Fact prohibited unless leave granted; joint statement required by reply brief.
Parties must meet and confer 15 days before dispositive motion deadline about summary judgment intentions.
Meet and confer required with opposing party before filing ex parte motion.
Motions in limine must be filed three weeks before hearing, responses two weeks before.
Must move for admission or allow Court to inquire about objections before publishing exhibits to jury.
Motion hearing dates must be Mondays between 28-45 days after filing.
All arguments must be raised in opening brief; new arguments in reply may be disregarded.
Non-opposition statements must be filed 14 days before hearing.
Meet and confer required before motions to amend pleadings, with declaration if no agreement reached.
Parties must meet and confer to create joint statement of disputed/undisputed facts for summary judgment, filed with reply brief.
TROs and preliminary injunctions must be briefed; ex parte hearings only in extraordinary circumstances.
Meet and confer required before ex parte applications, with declaration documenting efforts and service required.
Motions in limine have strict deadlines: file by 4 weeks before trial, opposition by 2 weeks before trial, no reply briefs allowed.
Meet and confer required before filing motions in limine to resolve disputes.
Motions must be filed 14 days before hearing; oppositions 7 days before.
Motions due 14 days before hearing; oppositions due 7 days before.
Conference with opposing counsel required at least 7 days before filing any noticed motion.
Sur-replies and notices of supplemental authority require leave of court.
Cross-motion in summary judgment requires ex parte consolidated briefing schedule.
Separate Statements of Fact require leave of court.
Ex parte applications require meet-and-confer with opposing counsel
TRO motions must be briefed; ex parte hearings only in extraordinary circumstances.
Motions in Limine must be filed after in-person meet-and-confer with declaration of efforts
7-day meet-and-confer conference required before filing noticed motions.
Motion must include statement confirming meet-and-confer conference.
Motion hearing dates must be set 35 days from filing date.
Motion caption must include: NO ORAL ARGUMENT UNLESS SEPARATELY ORDERED.
Ex parte motions require meet and confer and declaration documenting efforts.
Motions in limine due 2 weeks before hearing; opposition due 1 week before.
Pre-motion conference with opposing counsel required at least 7 days before filing.
Hearing dates must be Mondays between 30-60 days after filing.
Meet and confer required before filing motions to amend pleadings.
Party seeking amendment must provide proposed amended pleading and explanation to opposing counsel.
Declaration documenting meet and confer efforts required if parties cannot agree on amendment.
Joint statement of disputed/undisputed facts required 10 days before hearing, filed with reply brief.
Separate statements of disputed/undisputed facts will not be considered by the Court.
TRO motions must be briefed; ex parte hearings only in extraordinary circumstances.
Ex parte applications require meet-and-confer and declaration documenting contact efforts.
Ex parte applications unopposed within 3 Court days may be granted unopposed.
Meet and confer required before filing motions in limine, with declaration if unsuccessful.
Motions in limine briefing schedule: file 3 weeks before hearing, oppositions due 2 weeks before.
One brief per motion in limine per side in multi-party cases; excess filings stricken.
Meet and confer required before filing ex parte motions.
Hearing date sets briefing schedule only; no oral argument unless separately ordered.
Ex parte motions require meet-and-confer declaration documenting contact efforts and opposing counsel's position.
Motions in limine due 2 weeks before hearing; opposition due 1 week before.
Rule 26(f) conference timing requirements.
Motions in limine must be filed 14 days before hearing, opposition 7 days before, no replies
Rule 26(f) conference is mandatory unless excluded.
Participation requirements for Rule 26(f) conference.
Format requirements for Rule 26(f) conference.
Discussion requirements for Rule 26(f) conference.
Opposing counsel must be given opportunity to respond to ex parte applications.
Objections to initial disclosure must be discussed at Early Neutral Evaluation Conference in the Southern District of California.
Rule 26(f) conference must address ESI preservation issues including backup tapes, archival data, and preservation of relevant data going forward.
Early Neutral Evaluation Conference required within 45 days of answer (60 days for patent cases)
Case Management Conference required within 90 days of service (or 60 days of appearance)
Meet and confer in person or by phone required before discovery motions; certificate of compliance required.
Failure to meet and confer results in rejection of motion to compel
Motions in limine due two weeks before hearing; opposition one week before.
Meet and confer required before filing motions in limine.
Meet-and-confer required before filing sealing motions.
Telephone/email/written correspondence not permitted for meet-and-confer.
Exceptions to meet-and-confer requirement listed.
Certification of meet-and-confer required with motion.
Certification must include date and type of meet-and-confer.
Failure to comply with meet-and-confer results in denial.
Nonmoving party refusal may result in attorney fee sanctions.
Meet and confer required before filing motion to amend scheduling order; joint motion preferred.
Meet and confer required before contacting court; in-person if same district, phone/video if different districts.
Meet and confer required before seeking court ruling on deposition disputes involving privilege, court-ordered limitations, or Rule 30(d).
Joint Motion required for discovery disputes before filing motion to compel or for protective order.
Opposing party must have reasonable opportunity to contribute to Joint Motion.
Party must file Notice of Intent to Respond within 5 business days of ex parte discovery motion, with declaration explaining why joint motion wasn't used.
Written motion required to excuse defendant's appearance, signed by defendant.
Parties must attempt to resolve discovery disputes through meet and confer before filing a motion.
Mandatory meet and confer required before bringing any matter to court
Strict compliance required with meet and confer requirement
Motion notice must include meet and confer statement with date and format
Discovery conference email to Chambers must include 3 proposed times, neutral dispute statement, parties' positions, and key authorities.
Discovery motions require Court leave, typically granted after pre-motion conference.
Discovery motions require advance Court permission and expedited briefing.
Three-page single-spaced letter brief required before informal discovery conference.
Rule 26(f) conference required for civil cases to discuss discovery topics.
Meet and confer required before discovery dispute can be addressed.
Rule 26(f) conference required for civil cases to discuss discovery topics.
Meet and confer by phone/video/in-person required before raising discovery disputes.
Discovery motions require leave of court and must follow Chambers Rules procedures.
Motions must be filed 14 calendar days before hearing; oppositions 7 days before.
Motions in Limine are due 14 days before hearing, opposition due 7 days before, no replies permitted.
Motions to compel require completing the Rule 26 meet and confer obligation before filing; applications without it will be rejected.
Motions must be filed at least 14 days before the noticed hearing date.
Pretrial motions filed 14 days before hearing; oppositions 7 days before.
Noticed motions must set hearing date 35 days from filing date.
Parties must meet and confer before filing a sealing motion and seek the narrowest possible sealing order.
Before filing specified pretrial submissions, counsel must conduct a face-to-face meet-and-confer, and phone/email/written exchanges are insufficient absent leave of court.
Counsel must meet and confer before filing motions, subject to listed exceptions.
Parties must meet and confer on transcript or exhibit redactions/excerpts before seeking court resolution by motion in limine.
If parties cannot resolve exhibit-use disputes for opening statements after meet-and-confer, they must file a motion in limine.
All temporary restraining order motions must be briefed.
Noticed motions require meet and confer with opposing counsel at least 7 days prior to filing, unless exempt; declaration required in motion if no resolution.
Opposition briefs due 3 weeks after motion filing, reply briefs due 2 weeks after opposition; supersedes local rule 7.1(e).
Counsel must meet and confer with opposing party before filing any ex parte motion.
Only motions limited to evidentiary issues are proper in limine motions; specified motion types are excluded.
Counsel must meet and confer before filing motions in limine to resolve issues without court intervention.
Motions in limine due 2 weeks before hearing, opposition due 1 week before hearing unless otherwise ordered.
Lead counsel must comply with Civil Local Rule 26.1.a (meet and confer) before bringing any matter to the Court.
Deposition disputes require immediate meet and confer; unresolved disputes may be called in to chambers for ruling.
After meet and confer exhaustion, movant must email chambers to request pre-motion conference, including required content and copying all counsel.
Lead counsel must promptly meet and confer in person or videoconference before bringing any matter to court; written-only meet and confer is prohibited.
Deposition disputes require immediate meet and confer; unresolved disputes may be brought to chambers for ruling, with follow-up required if judge is unavailable.
Discovery motions may not be filed until pre-motion conference is held, unless leave of court is obtained.
Failure to timely oppose a motion may be construed as consent to granting.
Surreplies and notices of supplemental authority require leave of Court unless binding law changes.
Court prefers opposing party be served and given opportunity to oppose TRO motions.
Ex parte motions unopposed after 1 court day.
Only one brief per side accepted for multiple parties.
Exceeding page limits or multiple filings will be stricken without leave.
Failure to oppose motion is deemed consent to granting.
Failure to file opposition may be construed as consent to granting motion.
Shortening time applications require non-conclusory affidavit with specific good cause.
Ex parte motions unopposed after 1 court day.
Only one brief per side accepted for multiple parties.
Exceeding page limits or multiple filings will be stricken without leave.
Failure to timely oppose a motion may be construed as consent to granting.
Surreplies and notices of supplemental authority require leave of Court unless binding law changes.
Court prefers opposing party be served and given opportunity to oppose TRO motions.
Failure to oppose motion is deemed consent to granting.
Exceptions to meet-and-confer: pro se plaintiffs, TROs/PIs, summary judgment motions.
TROs must be briefed; ex parte hearings only in extraordinary circumstances.
Failure to file opposition may be construed as consent to granting motion.
Leave of court required for pre-Rule 26(f) discovery.
Court may require conference before filing discovery motions under Rule 16(b)(3).
Daubert motions should not be filed as in limine motions.
Exchanging letters, faxes, or emails does not satisfy meet and confer requirement.
Failure to meaningfully participate in required meet and confer may result in sanctions.
Counsel must attempt to confer and resolve deposition disputes before contacting the court.
Failure to meet and confer in good faith for motions in limine results in an order to show cause regarding sanctions.
Civil motions scheduled for Thursday afternoons at 1:30 PM; oral argument typically held.
Cross-motions for summary judgment should be consolidated; one party files by pre-trial deadline, other responds within 3 days.
Motions in limine heard at final pretrial conference.
Tentative rulings provided before final pretrial conference.
Exception for binding intervening law changes without argument.
Oral argument may be requested with explanation; summary judgment motions get oral argument if non-moving party requests.
Court may order oral argument with 3-day notice.
Oral argument may be requested with explanation; court will set date if granted.
Discovery disputes unresolved in conference will receive briefing schedule.
Exceptions to meet-and-confer: pro se plaintiffs, TROs/PIs, summary judgment motions.
Motions in limine heard at final pretrial conference.
Tentative rulings provided before final pretrial conference.
Briefing schedules follow Local Rules unless Court sets specific schedule.
Motion hearings scheduled 30-60 days after filing.
5-day notice if oral argument is canceled.
Oral arguments held Fridays at 1:30 PM.
Telephonic argument permitted with advance arrangements.
Civil motions scheduled for Thursday afternoons at 1:30 PM; oral argument typically held.
Cross-motions for summary judgment should be consolidated; one party files by pre-trial deadline, other responds within 3 days.
Meet and confer not required for pro se cases, TROs, preliminary injunctions, or summary judgment motions.
Exception to leave requirement for notices of supplemental authority when binding intervening law changes.
Court may order oral argument with 3-day notice.
Exception for binding intervening law changes without argument.
Motion hearing date sets briefing schedule, not appearance requirement.
Exceptions to pre-motion conference: pro se plaintiffs, TROs/PIs, summary judgment motions.
If hearing Monday is federal holiday, next Tuesday may be selected.
Oral argument may be requested with explanation; summary judgment motions get oral argument if non-moving party requests.
Oral argument may be requested with explanation; court will set date if granted.
Motions are heard on Friday at 11:00 AM; changes require Courtroom Deputy approval.
Patent Local Rules add specific topics to Rule 26(f) conference agenda.
Class actions may limit discovery to class certification issues before hearing.
Early resolution of legal issues should be discussed.
Daubert issues may have early deadlines in patent and non-patent cases.
Parties should discuss desired changes to discovery limitations.
Rule 30(b)(6) witness matters should be discussed early.
Parties should formulate a joint discovery plan to lodge with court.
ESI issues should be addressed early including search terms, production, preservation, and privilege.
Keyword searching is costly and inefficient; search terms must be carefully crafted.
ESI must be discussed at Rule 26(f) conference.
Unopposed ex parte motions may be granted without hearing
Ex parte motions decided without hearing
If court cannot review deposition dispute immediately, proceed with other areas of inquiry.
Court may require joint motion if deposition dispute cannot be readily resolved.
Court may grant bail modification without hearing.
Discovery disputes unresolved in conference will receive briefing schedule.
CMC conducted immediately after ENE if no settlement reached.
Discovery hearings are rare; disputes resolved on pleadings without oral argument unless notified otherwise.
TROs may be heard ex parte only in extraordinary circumstances.
Superior Court of California, County of Los Angeles
View all rules for CA-LOS-ANGELES-SUPERIOR.Parties must reserve a motion date via the online CRS before filing any motion papers.
Parties must meet and confer before filing any motion in limine per local rule.
Discovery motions require pre-filing meet and confer; unresolved disputes require an informal video IDC with the court.
Motions in limine require pre-filing meet and confer, sworn declaration, and 16/9/5 court day briefing schedule.
Counsel must meet and confer in person, by phone, or videoconference to resolve discovery disputes before filing discovery motions; written exchanges are insufficient.
Informal discovery conference (IDC) required prior to filing any discovery motion after meet and confer.
Parties must reserve a motion date via the online CRS prior to filing any motion papers.
Parties must meet and confer before filing any motion in limine.
Demurrers must comply with CCP §430.41 meet-and-confer requirements; non-compliant demurrers will be taken off calendar.
Parties must meet and confer or exchange information 15 court days before the Final Status Conference.
Inmates must file jail condition complaint with facility commander before filing court motion/writ, unless substantial prejudice is shown.
Hearing dates must be reserved before filing a motion by calling the calendar clerk during specified hours.
Ex parte proceeding dates must be reserved via CRS or the Clerk's Office before filing.
Noticed motion hearing dates must be reserved via CRS or the Clerk's Office prior to filing.
Parties must meet and confer no later than 5 days before the first jury trial date to prepare joint trial documents.
Hearing dates for regularly noticed motions must be reserved before filing by calling the calendar clerk during specified hours.
Parties must reserve law and motion hearing dates through CRS, except for Motions in Limine.
Discovery motions filed before IDC process is concluded may be continued unless good cause is shown.
Informal Discovery Conference (IDC) must be scheduled prior to filing any discovery motion.
Motion hearing dates must be reserved by phone (not CRS Online) before filing; hearings are Tuesdays and Thursdays at 1:30 p.m.
Written motions during trial require discussion with opposing counsel first; unresolved matters need a court conference.
Counsel with full authority must meet and confer in person, by telephone, or by videoconference; letters, emails, or texts without a phone call do not comply.
If the initial meet and confer is unsuccessful, parties must participate in an informal discovery conference (IDC) with the Court.
Parties must meet and confer in person, by telephone, or by video conference (not by email, texts, or letters) regarding demurrers, motions to strike, and motions for judgment on the pleadings, and file a declaration with the pleading motions.
Moving parties must reserve motion hearing dates via the online CRS prior to filing any motion, except motions in limine.
The Court will not hear any discovery motion until an Informal Discovery Conference (IDC) takes place, except for motions to compel where no responses were served.
Hearing dates must be reserved via the online CRS before filing any motion except motions in limine.
Demurrers must comply with CCP §430.41 meet-and-confer requirements; non-compliant demurrers will be taken off calendar.
Parties must meet and confer or exchange information 15 court days before the Final Status Conference.
Moving parties must reserve motion hearing dates via the online CRS prior to filing any motion, except motions in limine.
The Court will not hear any discovery motion until an Informal Discovery Conference (IDC) takes place, except for motions to compel where no responses were served.
Parties must reserve a motion date via the online CRS prior to filing any motion papers.
Parties must meet and confer before filing any motion in limine.
All motions in Department F49 must be reserved through the Court Reservation System (CRS).
Parties must meet and confer in person or via phone before filing discovery motions; letters/emails are insufficient.
In-person appearance at the Final Status Conference is mandatory.
Parties must meet and confer or exchange information at least 15 court days before the Final Status Conference.
Parties must meet and confer on all motions in limine before filing.
Parties must reserve a motion date via the online CRS before filing any motion papers.
Parties must meet and confer before filing any motion in limine per local rule.
All motion hearing dates must be reserved in advance using the Court Reservation System (CRS).
Ex parte applications to shorten time require a motion date reservation on CRS prior to filing.
Demurrers without meet and confer compliance will be taken off calendar.
Counsel and self-represented litigants must meet and confer 10 court days before Final Status Conference.
Motion dates must be reserved via online CRS prior to filing motion papers; do not call courtroom to reserve.
All counsel must complete all legally required meet and confer efforts before filing a discovery motion.
Parties must meet and confer before filing any motion in limine per Local Rule 3.57.
Demurrers must comply with meet and confer requirements under CCP §430.41 or will be taken off calendar.
Discovery motions require exhausting meet and confer efforts in person or via phone before filing.
Inmates must file jail condition complaint with facility commander before filing court motion/writ, unless substantial prejudice is shown.
Proposed motions regarding a General Order must be authorized by the Supervising Judge of the Civil Division before filing.
Discovery motions (except initial discovery responses) require scheduling an MCC with Department 410 prior to filing.
Omnibus discovery motions (multiple sets/types of discovery in one motion) prohibited without prior written leave.
Parties filing more than 10 motions in limine must schedule a pre-filing conference with Department 410.
Parties must meet and confer in good faith prior to filing motions in limine.
Motions in limine may not seek dispositive relief that should be requested via summary judgment/adjudication or judgment on pleadings.
All law & motion matters must be reserved via CRS; reserved dates cannot be changed telephonically, and CRS must be used to continue/cancel.
Counsel must meet and confer in person, by phone, or videoconference to resolve discovery disputes before filing a discovery motion.
IDC required before filing most discovery motions; preferred before all discovery motions except motions to compel with no response.
Informal discovery conference (IDC) required after meet and confer before filing discovery motions.
Informal Discovery Conference or court permission required before filing motions to compel discovery.
Informal Discovery Conference (IDC) must be scheduled prior to filing any discovery motion.
Parties must schedule an Informal Discovery Conference (IDC) prior to filing any discovery motion, using Form LACIV-094.
Demurrers, motions to strike, and motions for judgment on the pleadings require a mandatory meet and confer with opposing counsel before filing.
Informal discovery conference (IDC) required prior to filing any discovery motion after meet and confer.
Parties must meet and confer in good faith before filing motions in limine; failure to do so may result in summary denial.
Counsel must meet and confer to resolve discovery disputes before filing IDC request or discovery motion.
Trial counsel must meet and confer 15 calendar days before Case Management Conference.
Ex parte applications related to Law and Motion matters require the underlying motion to be reserved in the Court Reservation System (E-Court) before the ex parte filing.
All motions require a hearing date reserved via E-Court; motions are heard Monday-Thursday at 8:30 a.m. and Friday at 9:00 a.m.
Motions to Compel Further require an Informal Discovery Conference scheduled by the moving party, who must confer with opposing counsel to obtain three available dates and notice the court.
Counsel must meet and confer via telephone or video conference prior to the Informal Discovery Conference to resolve discovery disputes.
Motions to Compel Further will not be assigned a hearing date until the Informal Discovery Conference process is completed.
Trial counsel must meet and confer in person, by phone, or video to resolve discovery disputes before filing discovery motions; letters/emails insufficient.
Parties must file IDC request LACIV094 and complete IDC before filing discovery motion, unless good cause shown.
Ex parte applications related to law and motion matters require prior motion reservation in the Court Reservation System.
All motions require a hearing date reserved through CRS; motions are heard Mon-Thu 8:30 a.m., Fri 9:00 a.m.
Motions to compel further require an informal discovery conference scheduled before the motion is set for hearing.
Motions to Compel Further require an Informal Discovery Conference (IDC) with meet and confer, joint brief (max 5 pages) filed 3 court days prior, and lead counsel appearance.
Meet and confer per CRC 3.724 and 3.727 is required prior to each Case Management Conference.
Discovery motions (except motions to compel initial responses) require verbal meet and confer, then IDC if unsuccessful; joint IDC statement (max 7 pages) filed 10 calendar days before hearing.
Informal Discovery Conference (IDC) must be completed before filing a discovery motion, absent a showing of good cause.
Parties must meet and confer before filing any motion.
CRS is required to schedule law and motion hearings in Department U.
Demurrers must comply with meet and confer requirements under CCP 430.41 or risk being taken off calendar.
Trial counsel must meet and confer before filing discovery motions.
Counsel and self-represented litigants must meet and confer at least 10 court days before FSC to exchange required documents.
Ex parte proceeding dates must be reserved via CRS or the Clerk's Office before filing.
Noticed motion hearing dates must be reserved via CRS or the Clerk's Office prior to filing.
Parties must meet and confer no later than 5 days before the first jury trial date to prepare joint trial documents.
Discovery motions require pre-filing meet and confer; unresolved disputes require an informal video IDC with the court.
Motions in limine require pre-filing meet and confer, sworn declaration, and 16/9/5 court day briefing schedule.
Meet and confer required before filing discovery motions.
Discovery motions filed before IDC process is concluded may be continued unless good cause is shown.
All law and motion hearings must be reserved via the Court Reservation System (CRS).
Counsel must meet and confer in good faith before scheduling an IDC or filing a motion to compel further responses.
Trial counsel must meet and confer no later than 15 calendar days before each Case Management Conference.
Meet and confer per CRC 3.724 and 3.727 required prior to each CMC
Parties must reserve motion dates via CRS before filing any motion papers.
Parties must meet and confer before final status conference.
Parties must reserve a motion date via the online CRS prior to filing any motion papers.
Parties must meet and confer 14 days before TSC, jointly file required documents 7 days before hearing.
Parties must meet and confer twice before requesting an IDC; joint bulletin board posting required for IDC request.
Parties must meet and confer real time before filing motions to challenge/amend pleadings; must also confer with court via status conference or joint posting for pleadings conference.
Parties must meet and confer before and after filing motions in limine to resolve evidence disputes and limit number.
Hearing date must be reserved via online Court Reservation System prior to filing any motion except motions in limine.
Motions in limine are heard at FSC, not calendared via Court Reservation System, and comply with CCP 1005(b) and 1013.
Parties must meet and confer before filing any motion in limine per Local Rule 3.57.
All parties must meet and confer before filing any motion in limine per Local Rule 3.57.
Motion hearing dates must be reserved via the Court Reservation System (CRS).
IDC required before hearing on motion to compel further discovery, preferably before filing motion.
Ex parte applications for law and motion matters require prior hearing reservation in Court Reservation System.
Hearing dates for all motions except motions to compel further must be reserved through E-Court.
Motions to compel further require an Informal Discovery Conference (IDC) before receiving a hearing date.
Parties must meet and confer at least 10 days prior to an Informal Discovery Conference to resolve discovery disputes.
Parties must meet and confer in good faith to resolve discovery disputes before filing discovery motions; declaration of attempt required.
Informal Discovery Conferences (IDC) are required before filing or hearing discovery motions.
Ex parte applications to shorten motion hearing time require reserving the motion date on CRS first.
Motion hearing dates must be reserved via the Court Reservation System (CRS) unless scheduled by the court.
Parties must meet and confer on all Motions in Limine prior to filing.
Parties must meet and confer before filing a demurrer or motion to strike.
All motion hearing dates must be reserved in advance via the Court Reservation System; motions heard at 8:30 AM Mon-Fri.
Informal Discovery Conference (IDC) required before filing discovery motions; scheduling an IDC tolls the filing deadline.
Final Status Conference set at least 10 days before trial; lead trial counsel must appear unless excused.
Parties must meet and confer in good faith to resolve discovery disputes before filing a discovery motion.
Written motions during trial require discussion with opposing counsel first; unresolved matters need a court conference.
Hearing dates for regularly noticed motions must be reserved before filing by calling the calendar clerk during specified hours.
Counsel must meet and confer in person, by phone, or videoconference to resolve discovery disputes before filing discovery motions; written exchanges are insufficient.
In limine motions require meet and confer prior to filing and must be fully briefed on the regular timeline.
Before filing a discovery motion, counsel must meet and confer by phone, video, or in person; letters or emails are insufficient.
An Informal Discovery Conference is required before filing any discovery motion.
Parties must schedule motion hearings via the online Court Reservation System before filing motion papers.
Before filing a discovery motion, counsel must meet and confer and may request an Informal Discovery Conference (IDC); discovery motions filed before IDC process concludes may be continued.
Meet and confer required before filing motion in limine.
Parties must reserve law and motion hearing dates through CRS, except for Motions in Limine.
Counsel with full authority must meet and confer in person, by telephone, or by videoconference; letters, emails, or texts without a phone call do not comply.
If the initial meet and confer is unsuccessful, parties must participate in an informal discovery conference (IDC) with the Court.
Parties must meet and confer in person, by telephone, or by video conference (not by email, texts, or letters) regarding demurrers, motions to strike, and motions for judgment on the pleadings, and file a declaration with the pleading motions.
Motion hearing dates must be reserved in advance on the Court Reservation System.
Moving party must schedule a motion hearing date via the online Court Reservation System.
Hearing dates must be reserved before filing a motion by calling the calendar clerk during specified hours.
Parties must reserve motion hearing dates using CRS.
A hearing must be reserved for any motion through the court reservation system.
FSC is scheduled 10 days before trial at 9:30 a.m.; trial counsel must attend.
Motion hearing dates must be reserved by phone (not CRS Online) before filing; hearings are Tuesdays and Thursdays at 1:30 p.m.
Motions (except motions in limine) must be reserved through the Court Reservation System.
Law and motion hearing dates must be reserved before filing; hearings are Wednesdays and Fridays at 9:30 a.m.
Parties must meet and confer by phone or in person before filing discovery motions; letters/emails are insufficient.
Parties must meet and confer on all motions in limine before filing; failure may result in motion not being heard.
Counsel must meet and confer before filing motions in limine.
Parties must meet and confer by phone or in person before filing discovery motions; letters/emails are insufficient.
Parties must meet and confer on all motions in limine before filing; failure may result in motion not being heard.
Counsel filing demurrers must comply with meet and confer requirements under CCP § 430.41.
Parties must exhaust in-person or phone meet and confer efforts before filing discovery motions.
Trial counsel should meet and confer in person before filing discovery motions.
Trial counsel should meet and confer before filing a discovery motion.
Parties should meet and confer before filing discovery motions; discovery motions are strongly discouraged.
Counsel must meet and confer on discovery issues; informal discovery conferences with the court are encouraged.
Scheduling an Informal Discovery Conference (IDC) is required before filing a Motion to Compel Further Discovery Responses, except for Song-Beverly claims and initial responses.
Parties are encouraged to extend discovery motion deadlines until 21 days after IDC; otherwise IDC will be held before the motion unless good cause shown.
Counsel must meet and confer before filing motions in limine.
To advance a hearing date, first reserve a date via CRS, then file an ex parte application.
Before filing a discovery motion, trial counsel must meet and confer; IDCs are not required and may not be scheduled unless authorized.
Parties must meet and confer before filing any motion.
To request an informal discovery conference, reserve a hearing date on the Court Reservation System and e-file form LACIV 094.
Parties must meet and confer 30 days before the Case Management Conference.
Trial counsel must meet and confer at least 15 calendar days before each Case Management Conference.
Informal Discovery Conference is not required before filing a motion to compel.
Parties are encouraged to stipulate to waive replies to motions in limine.
Ex parte applications do not require a reservation on the Court Reservation System (CRS).
Parties must meet and confer to resolve evidentiary issues before filing motions in limine.
An Informal Discovery Conference is strongly recommended but not required before filing a discovery motion.
Court issues written tentative rulings for most motions.
Informal Discovery Conference is not required before filing discovery motions; court may hold IDC upon request; written summary required three days before.
Parties are encouraged to schedule an Informal Discovery Conference before filing a discovery motion if dispute is unresolved.
IDCs are considered upon submission of a joint brief (max 5 pages) including three proposed dates and reasons for the request, e-filed by all parties.
Parties are encouraged to stipulate to waive replies to motions in limine.
IDCs are strongly encouraged but not required before filing motions to compel further responses to written discovery.
Ex parte applications and TRO/preliminary injunction requests are heard Monday through Friday at 8:30 a.m.
Ex parte applications do not require a reservation on the Court Reservation System (CRS).
Parties must meet and confer to resolve evidentiary issues before filing motions in limine.
Informal Discovery Conference is not required before filing discovery motions; court may hold IDC upon request; written summary required three days before.
Unresolved discovery disputes may be scheduled for an Informal Discovery Conference (IDC) via email or phone; IDCs are encouraged but not required.
Parties are strongly encouraged to participate in an informal discovery conference before filing a motion to compel.
Court strongly encourages informal discovery conference before filing discovery motions.
Parties should meet and confer (by conversation) before filing any motion.
Informal Discovery Conference is not required before filing a motion to compel further responses.
Parties may jointly request an IDC in writing; court decides on case-by-case basis.
Informal Discovery Conference is not required before filing a motion to compel.
Master calendar motions are heard every Thursday at 8:30 a.m.
Court issues written tentative rulings for most motions.
Parties are urged to schedule an IDC before filing motions to compel further discovery responses.
The court may conduct settlement conferences; parties must contact the Courtroom Assistant and execute a stipulation.
Oral argument is not expected on ex parte applications; the Court will request argument if needed.
An Informal Discovery Conference is strongly recommended but not required before filing a discovery motion.
Western District of Washington
View all rules for WDWA.Motion procedure: file motion with proposed order, note motion for 12 days, opposition due 7 days after filing, reply due 5 days after opposition. Argument must be in motion itself.
Discovery disputes require conference before filing motions.
Joint statement (max 3 pages) required before discovery conference.
Before filing discovery motions, parties must request conference and submit joint statement max 3 pages via CM/ECF.
Before filing motions in limine, parties must make a good-faith meet and confer with the opposing party and comply with LCR 7(d)(5).
Parties must meet and confer in good faith before filing a motion to compel.
Parties must contact the Magistrate Judge and learn their procedures before filing opposed discovery motions in referred cases.
All motions must be filed before the pretrial motions deadline.
In multi-defendant cases, counsel must consult before filing any motion.
Motions in limine must be filed by the pretrial motions deadline.
Meet and confer required before filing most motions; declaration of conference required.
Discovery disputes require conference and 3-page joint statement before filing motions.
Stipulated motions with non-compliant schedules will be denied.
Discovery-related motions must be filed 6 months before trial.
Dispositive and expert testimony challenges must be filed 4 months before trial with hearing set within 4 weeks.
Motions in limine must be filed 37 days before trial.
Good faith conference required to resolve discovery disputes before filing motion.
Discovery disputes require conference before filing motions.
Joint statement (max 3 pages) required before discovery conference.
Plaintiff must request individualized trial conference within 30 days of filing agreement
Pretrial motions (except dispositive) must follow LCR 37 individualized procedure.
Discovery planning conference required before seeking discovery under FRCP 26(f)(d).
Before filing discovery motions, parties must request conference and submit joint statement max 3 pages via CM/ECF.
Discovery motions prohibited until status conference on discovery dispute.
Daubert motions must be filed by dispositive motion deadline and cannot be in limine motions.
Meaningful conferral required before filing dispositive motions with 3 business day buffer.
Proposed briefing schedule required for cross-motions for summary judgment.
Good faith conferral required before filing motions in limine; single omnibus motion allowed.
Non-compliant motions in limine may be summarily stricken without prior permission.
Motion to compel only as last resort; good faith conferral required with certification.
No opposed discovery motions until contacting Magistrate Judge for procedures.
All motions must be filed before the pretrial motions deadline.
In multi-defendant cases, counsel must consult before filing any motion.
Motions in limine must be filed by the pretrial motions deadline.
Pretrial motions must be calendared 12 days after filing.
Opposition to extension motions due within 2 business days.
Replies to extension motions are not permitted.
Replies to motions in limine only if requested by Court.
Additional motions in limine require advance Court approval.
Meet and confer required before filing dispositive motions.
Motions in limine must be filed at least 14 days before trial.
Meet and confer required before filing dispositive motions with certification.
Meet and confer required before filing motions in limine.
Motions in limine must be filed 35 days before trial, noted for 21 days.
Meet and confer required before filing discovery motions.
Good faith conference required to resolve discovery disputes before filing motion.
Discovery disputes require conference and 3-page joint statement before filing motions.
Stipulated motions with non-compliant schedules will be denied.
Discovery-related motions must be filed 6 months before trial.
Dispositive and expert testimony challenges must be filed 4 months before trial with hearing set within 4 weeks.
Motions in limine must be filed 37 days before trial.
Sur-replies require leave of court.
Follow Local Rule 7(d) scheduling guidelines; improper motions may be re-noted or struck.
Reply papers for 21-day motions must be filed within 21 days.
Motions to shorten time are not permitted.
Opposition briefs must be filed and served within time prescribed in LCR 7(d).
Reply briefs must be filed and served within time prescribed in LCR 7(d).
Oral argument is not permitted unless specifically requested in caption with 'ORAL ARGUMENT REQUESTED'.
Motions must be noted for consideration on weekdays, excluding legal holidays.
Same-day motions include stipulated, joint, unopposed motions, and specific motion types.
Motions for relief from deadline and protective orders require 14-day notice.
Opposition papers for 14-day motions must be filed within 9 days.
Reply papers for 14-day motions must be filed within 14 days.
All other motions require 21-day notice.
Opposition papers for 21-day motions must be filed within 15 days.
Major dispositive motions require 28-day notice.
Opposition papers for 28-day motions must be filed within 21 days.
Reply papers for 28-day motions must be filed within 28 days.
Deadlines falling on weekends or holidays are extended to the next business day.
Mail service requires 3-day earlier deadline for opposition papers.
Prisoner cases follow 7-day, 21-day, or 28-day briefing schedules, not 14-day.
Scheduling conference or joint status report required within 14 days of filing or appearance.
Counsel with principal responsibility and all pro se parties must attend scheduling conference.
Conference of attorneys required 10 days before filing proposed pretrial order.
Protective order motions require certification of good faith meet and confer conference.
Mandatory meet and confer conference before initial status conference or joint status report.
Motion to compel discovery must include certification of good faith meet-and-confer attempt with date, manner, and participants.
Motion for new trial required before appeal; only specific grounds allowed after denial.
Parties must meet and confer before filing motion to consolidate; if agreement reached, must file stipulation addressing consolidation and scheduling issues.
Default judgment motion requires prior default entry.
Objections to magistrate judge orders must be noted for consideration on filing day; responses only if court requests.
Objections to magistrate judge recommended dispositions must be filed within 14 days and noted on motions calendar.
Court must set status conference after record filing to determine schedule
Good faith meet and confer required before filing motions to compel.
Good faith meet and confer required before filing motions in limine.
Meet and confer required before filing most motions; declaration of conference required.
Pre-motion conference with the Court is required for all discovery motions if parties cannot reach agreement.
Meet and confer between parties is required before filing dispositive motions.
Counsel must meet and confer before filing dispositive motions; motion must include certification of conferral in first substantive or final paragraph; 3 business days between confer and filing.
Good faith meet and confer with opposing party required before filing motions in limine, plus compliance with LCR 7(d)(5).
Motions in limine must be filed 35 days before trial, noted 21 days after filing; opposition due 15 days after filing; no reply unless ordered.
Good faith meet and confer required before filing motion to compel or protective order.
Dispositive motions raising claim construction issues require advance leave of court and will not be ruled on before Markman Hearing.
Before filing motions in limine, parties must make a good-faith meet and confer with the opposing party and comply with LCR 7(d)(5).
Parties must meet and confer in good faith before filing a motion to compel.
Parties must contact the Magistrate Judge and learn their procedures before filing opposed discovery motions in referred cases.
Leave of court is required to file a sur-reply.
Rule 12(b) motions require pre-filing meet and confer plus certification of conferral; curable defects should use amended pleadings.
Two-party summary judgment motions follow specified briefing order; multi-party cases require proposed schedule before filing.
Opposed discovery motions require Rule 37(a)(1) conferral and court conference before filing.
Discovery-referred cases require contacting Magistrate Judge for procedures before filing opposed discovery motions.
Withdrawal without replacement requires a court order, obtained either by stipulation or by motion with hearing.
Motion procedure: file motion with proposed order, note motion for 12 days, opposition due 7 days after filing, reply due 5 days after opposition. Argument must be in motion itself.
Motion to recuse is reviewed by challenged judge who may voluntarily recuse; if not, motion is referred to chief judge or senior active judge.
Before filing a motion for further discovery, the parties must confer to try to resolve the request without court involvement.
Parties must meet and confer before filing any motion in limine.
Motions to dismiss under FRCP 12(b) are discouraged if the defect can be cured by an amended pleading; parties should not oppose timely motions to amend.
Motions in limine are discouraged if they do not identify specific evidence to exclude, are overly general, or seek routine FRE application; Daubert issues are prohibited.
Motions to dismiss under Rule 12(b) discouraged if defect can be cured by amendment.
Parties must be prepared to discuss ADR procedures at scheduling conference.
Pending state court motions not considered unless refiled in federal court.
Removal timing applies even without specified damages if amount exceeds jurisdiction.
Motions to dismiss under FRCP 12(b) are discouraged if the defect can be cured by an amended pleading; parties should not oppose timely motions to amend.
Motions in limine are discouraged if they do not identify specific evidence to exclude, are overly general, or seek routine FRE application; Daubert issues are prohibited.
Parties must confer meaningfully before filing motions; should allow at least 3 business days between conferral attempts and motion filing (text incomplete).
Motion to recuse is reviewed by challenged judge who may voluntarily recuse; if not, motion is referred to chief judge or senior active judge.
Before filing a motion for further discovery, the parties must confer to try to resolve the request without court involvement.
Parties must meet and confer before filing any motion in limine.
Motions to shorten time are abolished; for immediate action, use telephonic motion procedure; if assigned judge unavailable, any other judge may hear the matter.
Pro se parties are exempt from discovery dispute conference requirement and may file discovery motions directly.
Oral argument is decided after briefing is completed on a motion.
Pretrial motions deadline is typically set six weeks before trial.
Oral argument granted after briefing; Court contacts parties to schedule.
Motion filing procedures section begins
Same-day motions do not permit responses or replies unless ordered.
14-day motions require 9-day response and reply by noting date.
21-day motions require 15-day response and reply by noting date.
28-day motions require 21-day response and reply by noting date.
Motions in limine must be noted between 21 days after filing and 6 days before pretrial conference.
Motions in limine responses due Monday before noting date; replies not permitted unless ordered.
Pro se parties are exempt from discovery dispute conference requirement and may file discovery motions directly.
Specific briefing schedule for cross-motions for summary judgment.
Pro se parties exempt from meet and confer requirement.
Pretrial motions deadline is typically set six weeks before trial.
Motions are normally decided within 30 days of the noting date.
Final pretrial conference may be scheduled at court's discretion.
Expedited joint motion procedure available for discovery motions by agreement.
Expedited joint motion procedure available for motions to seal, relief from deadline, and motions in limine by agreement.
No Rule 16(b) conference; Court reviews joint status report and issues scheduling order.
Oral argument granted after briefing; Court contacts parties to schedule.
Pro se parties are exempt from meet and confer requirements for dispositive motions, unless both sides have attorney representation.
Motions in limine that are general, don't identify specific evidence, or ask to apply FRE are discouraged.
Oral argument is decided after briefing is completed on a motion.
Motions to shorten time are abolished; for immediate action, use telephonic motion procedure; if assigned judge unavailable, any other judge may hear the matter.
Northern District of California
View all rules for NDCA.Discovery disputes require meet and confer in person or by phone before filing any discovery-related letter.
Meet and confer required at least 7 days before filing any motion.
Motion notice must certify meet-and-confer requirement was satisfied.
Magistrate judge settlement conferences require prior ADR process completion.
Pre-motion conference required before filing any motion, per Crim. L.R. 47-2 and 17.1-1(b).
Before bringing a discovery dispute to the Court, parties must first meet and confer in person or by videoconference; letters, emails, or phone calls alone are insufficient.
Meet and confer required before filing any motion or non-stipulated request.
Lead counsel must meet and confer 21 days before final pretrial conference on joint statement, differences, and settlement.
Testimony at claim construction requires motion 7 days in advance.
Discovery disputes must use meet-and-confer process, not formal motions under Civil L.R. 7-2.
Meet-and-confer for discovery disputes must be in person or by phone, not just written correspondence.
Discovery disputes require in-person or telephone meet and confer, not formal motions.
Sanctions motions under Rule 37 must follow Civil L.R. 37-4, not expedited discovery dispute procedure.
Motions in limine must be filed 10 days before final pretrial conference
Opposition to motions in limine must be filed 3 days before final pretrial conference
No replies permitted to motions in limine
Must seek stipulation before filing motions in limine
Settlement conferences with magistrate judges require completion of Early Neutral Evaluation, Mediation, or Private ADR first.
Parties must meet and confer to resolve discovery disputes before filing a motion; unresolved disputes require submission of a joint letter brief.
Parties must submit a stipulation and proposed order setting a briefing schedule for cross-motions before filing the first brief.
Meet and confer in person or videoconference required before discovery disputes.
Motions in limine must be served 20 days before conference, oppositions served 10 days before, then filed 7 days before conference as paired documents.
Motions in limine require specific timing for service and filing.
Motions must follow Criminal Local Rule 47-2 for filing and notice.
Motions in limine due 14 days before pretrial conference; oppositions due 7 days before; no replies.
Parties must meet and confer to narrow terms to ten before preparing joint statement if more than ten terms are at issue.
Counsel must confer before filing any motion under Criminal Local Rule 17.1-1(b).
Motions in limine must be filed 14 days before pretrial conference; oppositions due 7 days before.
Pre-motion conference required before filing any motion, per Crim. L.R. 47-2 and 17.1-1(b).
Testimony at claim construction requires administrative motion 7 days in advance.
Motions must follow Criminal Local Rules 471 and 47-2, with 5:00 PM filing deadlines
21 days before final pretrial conference, lead counsel must meet and confer on joint statement, differences, and settlement.
Meet and confer required 14 days before settlement conference
Discovery dispute motions require prior leave of court.
Testimony at claim construction requires motion 7 days in advance.
Request for more than 10 claim terms must show good cause and be filed 2 weeks before joint statement deadline
Face-to-face videoconference required before court relief for discovery disputes
Joint Letter (max 5 pages) required within 10 business days after videoconference
Motion briefing deadlines: 21 days for motions, 14 days for oppositions, 7 days for replies
Sentencing motions: 7 days for filing, 5 days for responses
Motions must be noticed for hearing per Local Rule 47-1; counsel must check judge's calendar before selecting date.
Motions in limine must be filed 10 days before final pretrial conference
Opposition to motions in limine must be filed 3 days before final pretrial conference
No replies permitted to motions in limine
Must seek stipulation before filing motions in limine
21-day meet and confer on joint pretrial statement and settlement.
Joint statement of undisputed facts required for summary judgment motions on infringement/invalidity.
Motion briefing deadlines: 21 days for motions, 14 days for opposition, 7 days for reply.
Discovery disputes require meet and confer by video conference followed by a joint letter not exceeding 5 pages within 5 business days.
Motions to strike affirmative defenses require leave of Court obtained via administrative motion.
Discovery disputes require live meet and confer (in person/videoconference/phone) before filing motions, unless leave of court is granted.
All civil motions must be noticed for hearing per Civil L.R. 7-2(a, except pro hac vice, time enlargement/shortening, and administrative relief motions, which have no hearings.
Civil motions are heard only on Wednesdays at 9:00 a.m. in Courtroom 3, 5th Floor, 280 S. First St, San Jose, CA, by reservation only.
Moving party counsel must confer with opposing counsel on a hearing date before noticing any motion.
Relief-seeking party prepares joint discovery letter portion first, shares with opposing side, then files the letter.
Discovery disputes may be resolved on papers or via hearing; joint letter process does not apply to third-party disputes.
Rule 52 cross-motions require filing four briefs sequentially, not three pairs of simultaneous briefs.
Only one summary judgment motion per party allowed in patent cases; related entities count as one party.
Parties may not reserve more than two motions or have more than two motions heard per hearing without leave of court; a motion demonstrating good cause is required to exceed.
Motions may not be filed without a reserved hearing date; motions filed without a reservation will be stricken and cannot be refiled until a reservation is obtained.
Case management conferences are held via Zoom webinar unless noted otherwise; all other hearings are in person unless noted or leave is granted.
Bench and jury trials start Mondays at 9:00 a.m., run through Thursday; half-day (4.5h) or full-day (6.5h) schedule based on projected length.
Cross-motions for judgment under Federal Rule of Civil Procedure 52 must adhere to the same briefing and scheduling guidelines applicable to cross-motions for summary judgment.
Parties filing motions in limine must first seek a stipulation from opposing parties to the requested relief.
Prior leave of court is required before filing any discovery dispute motion, except as provided in subsequent subsections.
Joint discovery letter briefs must include meet and confer attestation, summarize unresolved issues; no multiple letters, limited legal authority, no declarations, may attach excerpts.
Pre-filing conference and letter are required before filing summary judgment (Rule 56) motions, except in pro se, habeas, and Social Security cases; letter due 7 business days before proposed conference, opponents have 3 business days to respond; conferences are in person only.
Before seeking leave for additional pages, parties must meet and confer and file a single omnibus motion including all requests.
Moving counsel must confer with opposing counsel on a mutually convenient hearing date before noticing any motion.
Simultaneous briefing is prohibited for all motion types.
Claim construction will only be conducted with a dispositive motion absent compelling reason; Patent Local Rules 4-1 to 4-4 apply, 4-5 and 4-6 are superseded.
For cross-motions for summary judgment, parties must file four briefs sequentially in specified order instead of simultaneous pairs.
Reply papers to motions in limine will not be considered.
Parties must be prepared to address specified issues at the pretrial conference, including raising jury instruction disputes to be resolved before opening statements.
Parties must meet and confer to resolve discovery disputes before filing a motion; unresolved disputes require submission of a joint letter brief.
Parties must submit a stipulation and proposed order setting a briefing schedule for cross-motions before filing the first brief.
Parties must meet and confer in person, videoconference, or by phone for discovery disputes before filing formal motions, unless leave of court is granted.
Rule 37 sanction motions must comply with Civil L.R. 37-4 and cannot use the expedited discovery dispute letter procedure.
Lead counsel must meet and confer at least 42 days before the final pretrial conference.
Motions in limine: serve moving papers 32 days before pretrial conference, serve oppositions 25 days before, then file paired sets 21 days before conference.
Meet and confer must occur 21 days before the pretrial conference statement is due.
Without a stipulation, motions must be filed 21 days before hearing, oppositions 14 days before, and replies 7 days before.
Reply briefs are not permitted for motions in limine.
Meet-and-confer requirement excused only for emergencies with notification.
Reply briefs to motions in limine are not permitted without prior court order.
Only one motion for summary judgment per party/side allowed unless leave granted; exceptions for statute of limitations and exhaustion defenses.
Magistrate judge settlement conferences require completion of Early Neutral Evaluation, Mediation, or Private ADR first.
Parties must meet and confer to resolve motions in limine before filing unresolved ones.
Unresolved discovery disputes may be filed as joint letter after meet and confer.
Settlement conference referral allowed after unsuccessful ADR completion.
Motions in limine heard at pretrial conference unless oral argument unnecessary
Exceptions to settlement conference rule may be discussed in initial case management statement or through joint early case management conference request.
Court may order additional briefing, telephonic conference, or in-person meet-and-confer at courthouse with lead trial counsel.
Meaningful meet and confer should eliminate need to propose different constructions in briefs.
Pretrial conference scheduled for 1:30 p.m.
Counsel must confer and discuss evidentiary objections and trial simplification with the court.
No prehearing conferences; prehearing issues addressed at tutorial.
Motions in limine heard at pretrial conference unless oral argument unnecessary
If no plaintiff summary judgment motion, defendants may file 5 weeks before cut-off following Local Rule 7-3 schedule.
Discovery motions in civil cases are referred to a Magistrate Judge.
Exceptions to settlement conference rule may be discussed in initial case management statement or via joint early case management conference request.
Parties may stipulate to a briefing schedule if all briefing is complete at least 7 days before the hearing.
District of New Jersey
View all rules for DNJ.Discovery motions require leave of court.
Meet and confer required before discovery disputes.
Joint letter (max 10 pages) required after meet and confer.
Pre-motion letter (max 3 single-spaced pages) required before specified civil motions; adversaries have 7 days to respond (max 3 pages).
Reply papers are prohibited for cross-motions, reconsideration, case management, and discovery motions unless the Court permits otherwise.
Sur-replies are prohibited without prior permission and discouraged unless necessary to rebut new issues.
No briefs other than those permitted may be filed without leave of court for good cause shown.
Party must request conference with magistrate judge to resolve 56.1 statement non-compliance disputes.
Party anticipating expert exclusion argument must raise issue to Court to determine motion filing timing relative to summary judgment.
Submission dates for in limine motions are set during an initial telephone conference with Judge Padin after the Magistrate Judge’s final pretrial conference.
Pre-motion conference required before specific motions (max 3 single-spaced pages).
Adversaries must respond to pre-motion letter within 7 days (max 3 single-spaced pages).
Pre-motion letters required for specified motions, max 3 single-spaced pages; response due 7 days, max 3 pages; exemptions for pro se, bankruptcy, social security cases.
Leave required to file summary judgment motion before close of fact discovery; leave request requires 3-page letter, opposition due 7 days.
Pre-motion letter (max 3 single-spaced pages) required before specific motions.
Response to pre-motion letter must be submitted within 5 business days (max 3 single-spaced pages).
Pre-motion letter submission tolls the deadline to file motion or answer.
If no pre-motion conference is held, party gets 5 additional business days to file motion.
Summary judgment motions prohibited in ANDA patent cases; waiver available via 3-page letter.
Adversaries must respond to ANDA patent case waiver letter within 5 business days.
Pre-motion conference required before specific motions (max 3 single-spaced pages).
Adversaries must respond to pre-motion letter within 7 days (max 3 single-spaced pages).
Discovery motions require leave of court.
Meet and confer required before discovery disputes.
Joint letter (max 10 pages) required after meet and confer.
Formal motions require prior leave from court except for Rule 12 motions, timely remand motions, and those expressly permitted.
Most formal motions require prior leave of court, except Rule 12 motions, timely remand motions, and motions to amend.
Pre-motion letter (max 3 single-spaced pages) required before certain motions.
Response to pre-motion letter must be filed within 7 days (max 3 single-spaced pages).
Formal motions require leave of court except as permitted by Local Rule 12.1.
Reply briefs are prohibited for certain motion types unless Court permits.
TRO requests require prompt hearing and pre-hearing conference.
All pre-trial motions including Daubert and in limine motions must be fully briefed and filed 45 days before trial.
Motions in limine must be filed 4 weeks before trial; responsive papers 3 weeks before.
Motions require email leave request to Angela DiAndrea with proposed schedule.
Pre-motion conference required for specific motions (max 3 pages).
Pre-motion letter must include basis and citations.
Adversaries must respond within 5 business days (max 3 pages).
Summary judgment motions prohibited in ANDA patent cases.
Formal motions require prior leave from the court, except for Rule 12 motions, timely remand motions, and those expressly permitted.
All motions, including discovery motions, require prior leave of the Court.
Pre-motion letter (max 3 single-spaced pages) required before specified civil motions; adversaries have 7 days to respond (max 3 pages).
Reply papers are prohibited for cross-motions, reconsideration, case management, and discovery motions unless the Court permits otherwise.
Sur-replies are prohibited without prior permission and discouraged unless necessary to rebut new issues.
No briefs other than those permitted may be filed without leave of court for good cause shown.
Party must request conference with magistrate judge to resolve 56.1 statement non-compliance disputes.
Party anticipating expert exclusion argument must raise issue to Court to determine motion filing timing relative to summary judgment.
Submission dates for in limine motions are set during an initial telephone conference with Judge Padin after the Magistrate Judge’s final pretrial conference.
Pre-motion letter required for specified motions, max 3 single-spaced pages, must include basis and citations, no affidavits/exhibits unless directed.
Non-movant failure to file response letter within 7 days precludes consideration at pre-motion conference.
All parties must appear and participate in pre-motion conference, even if they did not file pre-motion or response letters.
Parties filing specified motions must submit a pre-motion letter by the FRCP 12(a) deadline, tolling the motion filing deadline until the pre-motion conference or court decision, with exemptions for pro se, bankruptcy, and social security cases.
Parties must file a pre-motion letter for summary judgment motions before filing and before setting briefing schedule, with a status/settlement conference, exempting pro se cases.
Dispositive motions require prior leave of court via letter application.
Pre-motion letters required for specified motions, max 3 single-spaced pages; response due 7 days, max 3 pages; exemptions for pro se, bankruptcy, social security cases.
Leave required to file summary judgment motion before close of fact discovery; leave request requires 3-page letter, opposition due 7 days.
Most civil motions require leave via pre-motion letter (max 3 pages) from moving party, with opposing response letter (max 3 pages) within 1 week; Rule 12(b) and remand motions within 30 days of removal are exempt.
Pre-motion letter requirement does not apply to pro se cases or bankruptcy/social security appeals.
Reply letters to pre-motion letters are not permitted unless directed by the Court.
Affidavits and exhibits are not permitted in pre-motion letters unless directed by the Court.
Reply letters to pre-motion correspondence only allowed if directed by court.
Affidavits and exhibits prohibited in pre-motion letters unless court directs otherwise.
Replies to discovery disputes require leave of court.
Initial pretrial conference held after answer/dispositive motion; final pretrial conference after discovery, using Magistrate Judge's proposed form.
Pre-motion letter tolls filing deadline until conference date or Court's decision not to hold conference.
Letter exchange procedure does not apply to pro se cases or bankruptcy/social security appeals.
Proffer of affidavit/exhibit contents by attorney is permitted in pre-motion letters.
Pre-motion letter tolls filing deadline until conference date or Court's decision not to hold conference.
Letter exchange procedure does not apply to pro se cases or bankruptcy/social security appeals.
Pre-motion letter filing tolls deadline to file motion or answer.
If no pre-motion conference, party gets 7 additional days to file motion after Rule 12(a) deadline.
Pre-motion letter requirement does not apply to bankruptcy appeals, social security appeals, MDL cases, or pro se cases.
Motion practice follows Local Civil Rule 7.1 except as specified.
Judge decides motions on papers; no appearances required.
Pre-motion letter tolls filing deadline until conference or court decision.
7 additional days to file if no conference is held.
Pre-motion letter exchange doesn't apply to pro se, bankruptcy, or social security cases.
3-page letter may seek waiver of summary judgment prohibition.
Initial pretrial conference held after answer/dispositive motion; final pretrial conference after discovery, using Magistrate Judge's proposed form.
Eastern District of Pennsylvania
View all rules for EDPA.Rule 26(f) conference required at least 14 days before Rule 16 scheduling conference; mandatory compliance.
Parties filing Federal Rule of Civil Procedure 12 motions must hold a substantive verbal discussion with opposing counsel before the due date, submit a pre-motion letter if no agreement is reached, attend a pre-motion conference, and receive a briefing schedule if the dispute is unresolved.
A telephone conference with Judge Wolson is required before filing any responsive brief for a discovery motion.
Prior leave of court is required to file a summary judgment motion in a bench trial; leave requests must be sent via letter to Judge Wolson within seven days after the close of discovery, explaining the grounds for the request.
Hearing required for Government continuance requests where defendant does not sign waiver.
Continuance requests may not be submitted by letter.
Preliminary pretrial conference scheduled after all defendants appear; lead counsel must attend in person.
7-day pre-motion conference required before filing Rule 12(b)(6) motions.
Certification of pre-motion conference required with Rule 12(b)(6) motion.
Merely reporting unavailability or reasonable efforts is insufficient; motion will be denied.
Preliminary pretrial conference scheduled after answer; joint Rule 26(f) report due 3 business days prior
Lead counsel must attend Rule 16 conference with authority to settle and discuss all claims/defenses
Rule 16 conference scheduled after all defendants answer; joint Rule 26(f) report with discovery plan due 3 business days before conference.
Reply and sur-reply briefs must be filed within 7 days of the brief they respond to, without seeking leave.
Pre-motion conference required 7 days before filing Rule 12(b)(6), (e), or (f) motions, except in pro se, bankruptcy, or social security cases.
Preliminary pretrial conference scheduled after all defendants appear; lead counsel must attend in person.
7-day pre-motion conference required before filing Rule 12(b)(6) motions.
Certification of pre-motion conference required with Rule 12(b)(6) motion.
Merely reporting unavailability or reasonable efforts is insufficient; motion will be denied.
Status conference required after defense counsel appears in civil cases; covers multiple pretrial matters.
Non-compliance with Rule 26(f) meeting results in no input at initial pretrial conference.
Rule 26(f) meeting must be completed promptly and is substantive.
Joint Rule 26(f) report required at least one day before initial pretrial conference.
Patent non-ANDA cases require specific Markman hearing planning in Rule 26(f) report.
Initial pretrial conference must address multiple substantive topics.
Attending counsel at initial pretrial conference is designated as lead trial counsel unless excused.
Lead trial counsel must have full settlement authority at initial pretrial conference.
Meaningful conference required before threshold motions, except for pro se parties.
Meaningful conference requires sharing arguments and caselaw citations.
Threshold motions must be addressed at initial pretrial conference even if not fully briefed.
Discovery disputes require parties to meet and confer in good faith, and must be filed as motions rather than letters.
Pretrial conferences are not scheduled for arbitration-assigned cases.
Summary judgment motions are generally not addressed before arbitration hearings.
Telephone conference with court required before filing discovery motions.
Discovery motions should not be filed until after a telephone conference with chambers.
Pre-motion certification required for Rule 12 motions that opposing counsel was given opportunity to cure.
TRO requests trigger immediate conference scheduling with all counsel required to attend.
Upon filing any pretrial motion in criminal cases, parties must advise Court of intent to present testimony and expected duration.
Motions in limine must be filed before trial; complex motions 7 business days before final pretrial conference; untimely motions may be refused.
Counsel must attend scheduling conference within 50 days of initial appearance/arraignment in criminal cases.
A motion must be filed before requesting a telephone conference, except for deposition disputes; letter motions are prohibited.
Pre-filing conference with opposing counsel required for Rule 12(b)(6), (e), (f) motions, except in pro se, bankruptcy, or social security appeals; motion must include meet-and-confer certification.
Parties must meet and confer about material facts no later than 14 days before filing any Rule 56 summary judgment motion.
Good faith telephone/video conference required before judicial intervention for discovery disputes.
Parties must email chambers to request telephone conference before filing discovery motion, including prior efforts, dispute summary, and relevant attachments.
Parties filing summary judgment motions must meet and confer to develop a single joint appendix of exhibits.
Parties must request a pre-filing conference with the Court before filing any discovery motion requiring intervention.
Dispositive motions and Rule 702 expert exclusion motions must be filed by [+4 weeks], responses by [+2 weeks], replies by [+1 week].
Motions in limine must be filed 14 days prior to Pretrial Stipulation, responses due [+1 week].
Counsel may request telephone/video conference for simple discovery disputes; must attempt to resolve with opposing counsel first and submit letter via email.
Counsel must meet and confer with opposing counsel at least 7 days before filing Rule 12, 56, removal, or transfer motions; verbal communication required, pro se/bankruptcy/Social Security appeals exempt.
Parties filing Federal Rule of Civil Procedure 12 motions must hold a substantive verbal discussion with opposing counsel before the due date, submit a pre-motion letter if no agreement is reached, attend a pre-motion conference, and receive a briefing schedule if the dispute is unresolved.
A telephone conference with Judge Wolson is required before filing any responsive brief for a discovery motion.
Prior leave of court is required to file a summary judgment motion in a bench trial; leave requests must be sent via letter to Judge Wolson within seven days after the close of discovery, explaining the grounds for the request.
Hearing required for Government continuance requests where defendant does not sign waiver.
Continuance requests may not be submitted by letter.
Sur-reply briefs require prior court permission via letter brief.
Pre-motion conference must include substantive verbal communication, not just emails/letters.
Summary judgment rarely granted in non-jury cases.
Pre-motion conference must include substantive verbal communication, not just emails/letters.
Reply briefs must be filed within 7 days of opposition brief unless Court sets different schedule.
Sur-reply briefs require prior permission by letter brief.
Threshold motions must be filed at least 7 days before Rule 16 conference.
Summary judgment motions typically use alternative method schedule.
Suppression, Starks, and Daubert hearings are typically scheduled at least 14 days before trial.
Pre-hearing conference may be held for injunctions.
Timing for motions in limine will be set at Rule 16 conference and confirmed in Scheduling Order.
Summary judgment rarely granted in non-jury cases.
Conference on proposed jury instructions is usually conducted.
Counsel expected to resolve objections before motions in limine deadlines.
Motions in limine filed after exchange of pretrial memoranda, with reply before pretrial conference.
Prompt conference held for TRO/preliminary injunction requests.
Prompt conference held with counsel for TRO and preliminary injunction motions after affidavit of service.
Oral argument is discretionary and granted only when likely to facilitate resolution.
Final pretrial conference held 7 days before trial; parties must discuss outstanding motions, evidence disputes, scheduling, and settlement efforts.
Parties must confer on discovery confidentiality before seeking court intervention per FRCP 26(c).
Motion practice is governed by Local Rule 7.1 subject to these procedures, local rules, standing orders, and supplemental rules for Social Security and Section 2254 cases.
Suppression, Starks, and Daubert hearings are typically scheduled at least 14 days before trial.
District of Delaware
View all rules for DED.Counsel must confer, agree on proposed protective order, and submit within 10 days of this Order; if no agreement, follow Paragraph 3(g).
Pre-motion letter (max 3 pages, 12-point font) required for discovery disputes, filed 72 hours before conference
Discovery motions and protective order disputes require first filing a Motion for Teleconference before formal motion practice.
Motions to amend or strike must follow the discovery dispute procedure.
Pre-motion letter (max 3 pages) required for discovery disputes, with 7-day and 5-day filing deadlines.
Discovery-related motions filed without leave will be denied without prejudice.
Daubert objections must be filed by dispositive motion deadline unless court orders otherwise.
Contact Case Manager to schedule in-person conference for discovery disputes.
Motions not following procedures will be denied without prejudice.
Meet and confer required 3-2 weeks before claim construction hearing to file Amended Joint Claim Construction Chart.
Meet and confer required 2-3 weeks before claim construction hearing.
Response to motions must be filed within 21 calendar days of filing.
Reply to motions must be filed within 10 calendar days of response.
Letter filing deadline: 72 hours before conference, max 4 pages, double-spaced, 12pt font
Opposition letter deadline: 48 hours before conference, max 4 pages, double-spaced, 12pt font
Joint letter required for discovery disputes after meet-and-confer
Seeking party must file 3-page letter 48 hours before discovery conference
Opposing party may file 3-page opposition letter before discovery conference
Motions to join parties or amend pleadings must follow procedures in Paragraphs 4(g) and 5.
Discovery motions must follow meet-and-confer procedures or be denied.
Party seeking discovery relief must file 3-page letter at least 48 hours before conference.
Opposing parties must file response letter at least 24 hours before conference.
Rule 56 motions must be filed within 10 days of deadline without leave.
Motions to amend require 3-page letter with proposed pleading and blackline
Opposition to motions to amend must file 5-page response within 7 days
Motions to strike must be accompanied by a 3-page letter, not an opening brief.
Motion for Discovery required after verbal meet-and-confer fails to resolve discovery/protective order disputes
Joint letter required for discovery disputes after meet-and-confer
Motion for teleconference required for discovery disputes
Early case dispositive motions require leave with 4-page letter brief; responsive briefs limited to 4 pages within 7 days; no reply briefs.
Daubert objections must be filed by dispositive motion deadline
Pre-motion letter (max 4 pages, 12pt font) required 72 hours before conference with proposed order.
Opposition pre-motion letter (max 4 pages, 12pt font) due 48 hours before conference.
Pre-motion letter (max 3 pages, 12-point font) required for discovery disputes, filed 72 hours before conference
Parties must file a joint letter and a Motion For Teleconference to resolve discovery disputes after good faith meet-and-confer efforts.
Parties unable to resolve initial protective order drafting disputes must file a joint letter requesting scheduling of a conference.
Briefing schedule for motions to amend: opposition due 7 days after filing, reply due 3 days after opposition.
Case dispositive motions in ANDA cases require party agreement and prior Court approval.
Case dispositive motions under Rule 56 cannot be filed more than 10 days before deadline without leave.
For unresolved discovery disputes, parties must schedule a conference with the Case Manager and file a letter (max 3 pages) 72 hours prior, with required attachments.
Discovery disputes require contacting the Court's Case Manager to schedule an in-person conference.
Discovery disputes require filing a Motion for Teleconference after reasonable efforts to resolve under Local Rule 7.1.1.
Motions to amend or strike must follow the discovery dispute procedure.
Discovery motions and protective order disputes require first filing a Motion for Teleconference before formal motion practice.
Motions to amend or strike must follow the discovery dispute procedure.
Daubert objections to expert testimony must be filed by motion within 14 days after the close of expert discovery.
Motions to strike must be accompanied by a letter (max 3 pages) instead of an opening brief, and must attach the document to be stricken.
Case dispositive motions in ANDA cases require party agreement and prior Court approval.
Pre-conference letter sequencing: moving party files 72 hours before conference, opposing party may file 48 hours before conference.
Discovery disputes require contacting the Case Manager to schedule a conference, with pre-conference letters (max 3 pages) due 7 days for moving party and 5 days for opposition.
Discovery disputes must be filed as a Joint Motion for Teleconference using specific titling and form; counsel expected to verbally discuss issues before seeking court intervention.
Oppositions to pro hac vice motions must be filed within one business day of the motion's filing.
Memoranda of law related to discovery motions are prohibited without leave of court.
Responses to discovery motions are due within 3 days absent a court order.
Non-parties served with discovery motions may respond within 3 days of service unless otherwise ordered.
Reply briefs do not require leave if filed within 7 days of opposition, no proposed order, limited to new issues.
Prompt conferences required for TRO, preliminary injunction, and expedited discovery motions; pretrial injunctive relief hearings must be scheduled within a month, else expedited discovery must be sought first.
Sentencing motions and supporting memos due 7 days before sentencing, responses due 3 days before, must include legal authority, no replies without leave.
Counsel must confer, agree on proposed protective order, and submit within 10 days of this Order; if no agreement, follow Paragraph 3(g).
Motions requiring shortened notice cannot be scheduled before the order shortening time is entered.
Multiple summary judgment motions must be numbered (#1, #2, etc.) in desired review order; denied motions halt further review except for exceptional reasons.
Multiple Daubert motions must be numbered (#1, #2, etc.) in desired review order; denied motions halt further review except for exceptional reasons; failure to cross-examine after denial reduces trial time.
Judge will not review summary judgment motions if a previous motion by the same party was denied.
Requests to modify mediation attendance requirements must be in writing 14 days before the conference.
Court may order further briefing after discovery conference or resolve dispute beforehand and cancel conference.
No Amended Joint Claim Construction Chart required if no agreements reached in meet and confer.
Replies to motions are encouraged but not mandatory.
Court may order further briefing or resolve dispute before conference
Court may refer case to Magistrate Judge for ADR exploration
Motions to amend or strike follow discovery dispute procedure.
Court may order further briefing after teleconference or may resolve dispute before conference and cancel it.
Court may order further briefing after discovery conference or resolve dispute beforehand and cancel conference.
Post-trial memoranda in support may be filed within 30 days of transcript receipt upon showing good cause.
Western District of Texas
View all rules for WDTX.Brief deadlines governed by Supplemental Rules 6, 7, and 8; no additional briefs without leave
Jury questionnaires require motion for leave filed 7 days before trial.
Follow FRCP and local rules for TRO/expedited relief; notify law clerk.
File motion to modify scheduling order.
For expedited relief motions, follow federal and local rules and notify law clerk.
Coordinate expedited criminal hearing motions with Courtroom Deputy Virginia Cabrera.
Counsel must confer on all motions before filing; reflect conference in motion body/title unless ex parte communication is justified.
Sur-replies require leave of court.
Standing order governs additional motion rules.
Motion required 7 business days before trial for remote witness testimony.
Witnesses must testify remotely via motion filed at least 7 business days prior, with equipment testing and technical support coordinated.
Additional briefing beyond motion/response/reply requires a motion for leave.
Rule 26(f) conference must be held within 14 days, preferably face-to-face unless attorneys are in different cities.
United States must simultaneously orally move for Court review when requesting magistrate judge stay of release
Motion to compel requires meet and confer plus contact with law clerk
Meet and confer required before dismissing indirect/willful infringement claims.
First meet and confer required 26 weeks after Markman hearing to narrow claims and prior art.
Second meet and confer required 39 weeks after Markman hearing to narrow claims to triable limits.
Dispositive and Daubert motions due 40 weeks after Markman hearing.
Brief deadlines governed by Supplemental Rules 6, 7, and 8; no additional briefs without leave
Jury questionnaires require motion for leave filed 7 days before trial.
Leave of court is required to file a sur-reply.
Discovery disputes require a meet and confer via personal conference (phone/video) between lead counsel with decision authority before contacting the Court; email is insufficient.
Motions to transfer must be filed within 3 weeks of CMC or 8 weeks of service, with response and reply deadlines set by rule.
Parties must meet and confer before filing motions to dismiss indirect/willful infringement claims before fact discovery.
Motions to suppress must be coordinated with the Courtroom Deputy.
Parties must make a good faith attempt to resolve discovery disputes before seeking court intervention.
Good faith conference required on contested nondispositive motions.
Hearings not routinely granted; must file formal motion if needed.
Good faith attempt required to resolve discovery disputes before filing motion.
Summary judgment motions disfavored in FTCA and bench trial cases; limited to legal issues.
Summary judgment motions are disfavored in cases without jury trial rights and should be limited to purely legal issues.
Hearings on civil motions are not routinely held; request must be made in opening paragraph with explanation.
Motions in limine must be limited to matters actually in dispute.
Twombly motions and motions for more definite statement should be filed sparingly and do not stay discovery unless court orders otherwise.
Letter briefs should not be submitted in civil cases.
Good faith conference required on contested nondispositive motions.
When filing for expedited relief, attorneys must call the courtroom deputy and notify opposing party.
Requests must be made by motion accompanied by a telephone call to the courtroom deputy.
Social Security appeals routinely referred to magistrate judge.
Court allows letter briefs at its discretion.
No conference required on motions except discovery matters; General Order governs discovery.
Final pretrial conference held one week before trial to address motions in limine and exhibit objections.
The court does not accept briefing beyond motion, response, and reply.
Hearing on dispositive motions scheduled after response/reply deadlines.
Circuit Court of Cook County
View all rules for IL-COOK-CIRCUIT.Sur-replies are only permitted with court approval via a written motion.
Only the listed motion types are considered routine and eligible for email submission without a court appearance.
Emergency motions must meet two criteria, be scheduled with the coordinator, and include specified documents submitted to the law clerk via email.
Regular motions must be spindled for the 9:30 a.m. call or piggybacked on a pre-scheduled date; piggybacking requires filing and courtesy copies two full court dates before presentment.
Emergency motions must be labeled “Emergency”, include a specific showing of emergency, and have file-stamped copies submitted by 3:00 p.m. the day before presentment.
Settlement conferences require a party with settlement authority to be present.
Reply briefs for 2-615, 2-619, 2-622, and discovery motions require specific leave of court.
Parties must confer meaningfully under Supreme Court Rule 201(k) before bringing any discovery dispute to court.
Motions to consolidate must be presented on the Presiding Judge of the Chancery Division’s calendar.
A motion to exceed brief page limits must be filed before the brief's filing deadline.
Emergency motions require presenting a copy to court staff for approval before scheduling, and must comply with local Rule 2.2.
Sur-replies are only permitted with court approval via a written motion.
Only the listed motion types are considered routine and eligible for email submission without a court appearance.
Emergency motions must meet two criteria, be scheduled with the coordinator, and include specified documents submitted to the law clerk via email.
Reply briefs for §2-615, §2-619, §2-622, and motions to compel require specific leave of court.
Routine motions do not require a court appearance; motions and draft orders must be emailed to the Court Coordinator at least two court days before entry.
Only the listed motion types are considered routine motions exempt from appearance requirements.
Emergency motions must be scheduled with the Court Coordinator; movant must submit all supporting documents to the law clerk via email.
Sur-replies are only permitted with court approval via written motion.
Non-routine motions must be scheduled with the Court Coordinator or via e-filing.
Parties must exchange good faith written offers and demands before a settlement conference is scheduled.
Contested motion hearings require in-person appearance in Courtroom 2004.
Parties must inquire with the court prior to filing a summary judgment motion.
All motions are presented only on CMC dates; if no CMC date is set, they are heard on the Regular Motion Call.
Motions to modify, vacate, alter, or extend CMC orders are only heard on CMC dates, not Regular or Emergency Motion Calls.
No briefing schedules for specified motions; continue to a day when the judge is present.
Court screens for 191 discovery in summary judgment and 2-619 motions; if needed, case is continued to status date with order stating specific discovery.
Emergency motions are signed up at 8:45 AM, heard at 9:00 AM; must be true emergencies, else heard on Regular Motion Call.
Routine motions are held in the courtroom unless noted otherwise on the courtroom door.
Focus case management conferences are held on Wednesdays at 11:00 AM.
Cases set for trial or three years old or older are ineligible for routine motion procedure.
Initial CMCs are held Wednesdays at 9:30am; FCMCs are held Wednesdays at 10:00am, 10:30am, and 11:00am.
Briefing schedules are not provided for all motions.
Initial CMCs are held Wednesdays at 9:30am; FCMCs are held Wednesdays at 10:00am, 10:30am, and 11:00am.
Oral argument is available upon request, held at 11:30 AM, 1:30 PM, 2:00 PM, or 2:30 PM.
Pre-trial conferences available 12 PM–3 PM daily, held only if offer made and parties with authority are available; pre-trial memorandums are optional.
Southern District of Florida
View all rules for SDFL.Discovery disputes are resolved via hearing set by Judge Reid without requiring a motion; hearings are held every Wednesday.
Hearings are only set if parties confirm they conferred or attempted to confer.
Personal conferral (in person/phone) required unless opposing party refuses after reasonable time; moving party must advise court of refusal.
Before filing a motion or application seeking relief without a hearing, check Local Rules to confirm it may be considered without a hearing.
Objections require full, reasonable conferral between parties before being raised.
Motion required one week before trial to use electronic equipment in courtroom.
Parties must have good faith in-person, phone, or video conference before filing discovery motions.
Parties must confer in good faith (in person, video, or phone, not just email) before seeking court intervention for discovery disputes.
Discovery motions under Rule 37 are prohibited without court leave; exceptions for stay discovery or extension of time to respond to discovery motions, which go to District Judge.
Objections to Court-entered orders differing from proposed order must use discovery hearing procedures, no motion required.
Counsel must confer in good faith before seeking court intervention for discovery disputes.
Discovery motions require compliance with pre-filing procedures.
Non-compliant discovery motions will be denied.
Discovery disputes require good faith conference and certification under Local Rule 7.1(a)(3).
Parties must confer in good faith to resolve discovery disputes before bringing the dispute before the Court.
Sanctions motions must be filed in writing and cannot be resolved via Informal Discovery Hearing.
Failure to confer in good faith is an independent basis to deny discovery motion relief; opposing party's failure to confer is considered for fee awards if motion is granted.
Informal Discovery Hearing procedures do not apply to written discovery motions.
Parties must confer and identify at least two available hearing dates within 14 days to use Informal Discovery Hearing procedure.
Pre-motion email requesting Informal Discovery Hearing must include required content and certification of good faith conference.
Discovery disputes are resolved via hearing set by Judge Reid without requiring a motion; hearings are held every Wednesday.
Hearings are only set if parties confirm they conferred or attempted to confer.
Personal conferral (in person/phone) required unless opposing party refuses after reasonable time; moving party must advise court of refusal.
Parties must confer in person, by phone, or via Zoom to resolve discovery disputes before filing a discovery motion; email alone is insufficient.
Parties must confer in good faith (in person, video, or phone, not just email) before seeking court intervention for discovery disputes.
Discovery motions under Rule 37 are prohibited without court leave; exceptions for stay discovery or extension of time to respond to discovery motions, which go to District Judge.
Objections to Court-entered orders differing from proposed order must use discovery hearing procedures, no motion required.
Before filing a motion or application seeking relief without a hearing, check Local Rules to confirm it may be considered without a hearing.
Court will sua sponte review motions and determine which require hearings.
Parties may still request oral argument even if Court sets hearings sua sponte.
Joint motions exempt from pre-filing procedures.
Participation in the Informal Discovery Hearing procedure is optional.
Any party may file a written discovery motion without leave of Magistrate Judge Louis; motions are considered in ordinary course unless expedited consideration is warranted.
Rule 37(a) motions to compel discovery may be resolved via Informal Discovery Hearing.
Northern District of Illinois
View all rules for NDIL.Plaintiff must submit settlement letter 14 days before conference; defendant must submit 7 days before.
Parties must conduct Rule 26(f) planning conference.
Propose briefing schedule for pending motions.
Discovery motions require L.R. 37.2 statement; interrogatory limit of 25 without leave.
Daubert motions due 60 days before trial or 10 days before discovery cut-off.
Parties must conduct Rule 26(f) planning conference.
Meet-and-confer required before filing motions in limine.
Parties must conduct Rule 26(f) planning conference.
Propose briefing schedule for pending motions.
Responses to motions in limine due one week after filing; no replies without leave.
Parties must meet and confer on all motions in limine before filing, and state if there is no objection.
Meet and confer required before filing motions in limine; unopposed motions should be described in final pretrial order.
Plaintiff must submit settlement letter 14 days before conference; defendant must submit 7 days before.
Rule 37 meet-and-confer required before filing motions in limine.
Motions in limine must be filed separately, 21 days before pretrial order, with responses due 14 days before.
Parties must meet and confer on all motions in limine before filing; absent prior leave, each side is limited to 5 total motions in limine.
Parties challenging confidentiality designation must confer directly with designating party in good faith before judicial intervention.
Parties challenging confidentiality designation must meet and confer in good faith with the designating party before filing a motion.
Motions in limine must be thoroughly briefed; the Court will set a briefing schedule.
Replies to motions in limine are not permitted unless ordered by the Court.
Parties must confer to try to agree on jury instructions and the verdict form.
Parties should raise exhibit objections at the pretrial conference to resolve them before trial.
Motions in limine typically due with final pretrial order, with briefing to follow Court's schedule.
Daubert motions should be filed separately and as soon as reasonably possible.
Daubert motions should be filed early, separately from other motions.
Eastern District of California
View all rules for EDCA.Pre-filing meet and confer required for motions in cases with represented parties.
Pre-filing meet and confer required for motions in cases with represented parties.
Motions in limine cannot be filed before the pretrial conference.
Pre-filing meet and confer required for motions in cases with represented parties.
Pre-filing meet and confer required before motions; certification of efforts required in notice of motion.
Discovery motions require prior approval before filing.
Discovery motions must be noticed before assigned magistrate judge.
Counsel must conduct a pre-filing meet and confer on motion substance before filing any motion in cases where all parties are represented.
Motions in limine are prohibited from being filed prior to the pretrial conference.
Pre-filing meet and confer required for motions where parties are represented by counsel.
Parties must meet and confer 28 days before the dispositive motions deadline to determine if they will file cross summary judgment motions.
For cross summary judgment motions, plaintiff must file opening brief 14 days before dispositive deadline, notice of motion must indicate cross motions and set hearing 42 days after filing.
Only four briefs may be filed for cross summary judgment motions regardless of the number of complaints; non-compliance results in denial without prejudice.
Motions in limine are prohibited from being filed before the pretrial conference.
Parties must meet and confer in good faith before filing a discovery motion or seeking an informal discovery conference.
Discovery dispute meet and confer requires spoken communication (in person, phone, or video) in addition to written correspondence.
Counsel must confer with courtroom deputy before filing specified motions (Rule 56, Rule 12, TRO, injunctions) to obtain hearing date; motion calendared only upon proper filing.
Timing for filing motions in limine is discussed at pretrial conference; court issues order with instructions after conference.
Discovery matters must be noticed before the assigned Magistrate Judge per Local Rule 302.
Counsel must contact the courtroom deputy to obtain a motion hearing date before filing any criminal motion.
Informal discovery conferences are optional alternative to formal motions under Local Rule 251.
Ex parte applications are typically submitted to the Court without a hearing unless otherwise notified.
Motions to tax costs are taken under submission upon filing with no hearing date set unless otherwise ordered.
District of Columbia
View all rules for DDC.Parties must confer in good faith before seeking Court involvement in a discovery dispute.
Discovery-dispute motions require leave of Court before filing.
Initial Scheduling Conference required after answer in cases under FRCP 26(f).
Sur-replies require leave of court with good cause; motion for leave cannot include the sur-reply itself.
Pre-motion conference required for dispositive motions; 4-page notice and 1-week response required.
Non-dispositive motions require conference with opposing counsel and certificate of conference with at least two personal communications.
Discovery disputes must be resolved informally first, then email Court for teleconference with specific content requirements.
Leave of Court required before filing discovery dispute motions.
Motions in limine must be fully briefed with specific timing: 21 days before JPTS for motion, 14 days for opposition, 7 days for reply.
Separate numbered motions in limine required for each discrete issue; omnibus motions not accepted.
Discovery motions require prior telephone conference approval from chambers.
Discovery disputes must be resolved through meet and confer before filing motions under Local Criminal Rule 16.1.
Discovery disputes require joint email to chambers before telephone conference.
Discovery motions require prior telephone conference with court and opposing counsel.
Discovery-related motions require a prior telephone conference with the Court and opposing counsel.
Oppositions to extension motions must be filed by 5:00 p.m. the business day after the motion is filed.
Court strictly enforces LR 7(h)(1); moving party facts deemed admitted unless controverted in opposition statement.
Parties must confer before filing discovery motions and obtain leave of court.
Counsel seeking briefing schedule for dispositive motions must be prepared to argue why such motions are appropriate and would not waste judicial resources.
Replies to motions in limine require court permission.
Counsel seeking briefing schedule for dispositive motions must be prepared to argue why such motions are appropriate and would not waste judicial resources.
Court may strike statements of material fact that do not conform to rules or comply with instructions.
Eastern District of Texas
View all rules for EDTX.Pretrial motions in criminal cases are referred to magistrate judges, except for specific motions.
Pretrial motions in criminal cases are referred to magistrate judges, except for specific motions.
Counsel must confer on video deposition objections before court
5-day conference requirement for motions in limine disputes
Counsel must confer on deposition objections
Good faith conference required before filing discovery motions, then call hotline if unresolved.
Review E-Discovery model order before contacting hotline or filing electronic discovery motions.
Motions to compel discovery require good faith conference first.
Respond only to objected items in motions in limine; confer within 5 days to resolve disputes.
Opposing counsel must confer to resolve deposition objections before court ruling.
Prepare half-page summary of key points and authorities before calling court on discovery disputes.
18th Judicial Circuit Court, DuPage County
View all rules for IL-DUPAGE-CIRCUIT.Except for emergency matters, motions must be previously scheduled for hearing with the Court or Court’s secretary before being heard.
Petitioners seeking default by publication must first obtain leave of court.
Except for emergency matters, motions must be previously scheduled for hearing with the Court or Court’s secretary before being heard.
Petitioners seeking default by publication must first obtain leave of court.
Adoption, arbitration, family, mental health, and other specified case categories are exempt from Initial Case Management Conference requirements.
Adoption, arbitration, family, mental health, and other specified case categories are exempt from Initial Case Management Conference requirements.
Eastern District of Virginia
View all rules for EDVA.Rule 7(E) does not apply; motions will not be deemed withdrawn for lack of hearing request or waiver, and the Court will decide whether to schedule a hearing after reviewing briefs.
Rule 7(E) does not apply; motions will not be deemed withdrawn for lack of hearing request or waiver, and the Court will decide whether to schedule a hearing after reviewing briefs.
Local Rule 7(E) does not apply; no hearing required unless Court determines necessary.
Local Rule 7(E) does not apply; hearings scheduled only if necessary after brief review.
Northern District of Texas
View all rules for NDTX.Related Rule Categories
Maximum page counts and word limits for motions, briefs, and other filings by judge.
When and how to deliver courtesy copies to chambers, including triggers, timing, and formatting.
Electronic filing requirements, permitted filing channels, EFSP portals, and exceptions.
Filing cutoffs, deemed-filed rules, rejection handling, cure periods, and outage procedures.