Pre-Motion Conference Requirements
2394 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.
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.
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.
Opposition papers due within 4 weeks; reply papers due within 2 weeks of opposition.
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.
Parties must confer and propose briefing structure, schedule, and page limits for summary judgment motions.
Expert testimony exclusion motions must be filed by dispositive motion deadline, not as motions in limine.
Default judgment motions must not be filed as orders to show cause.
Extensions/adjournments require letter-motion, not proposed stipulations
Conference with adversary required before TRO application unless Rule 65(b)(1) applies
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 dispute letter (max 3 single-spaced pages) required after meet-and-confer.
Response to discovery dispute letter due within 3 business days.
Pre-motion conferences required only for discovery and summary judgment motions.
Summary judgment pre-motion letter (max 3 single-spaced pages) due 14 days after discovery closes.
Adjournments, extensions, and pre-motion conferences must be filed as letter-motions.
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 in limine: opposition due 1 week after service, reply due 3 days after opposition, fully briefed 2 weeks before trial.
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.
Pre-motion conference required before any motion except FRAP 4(a)(4)(A) motions and pro hac vice motions.
Pre-motion letter must not exceed 3 pages (double-spaced) and must state bases for anticipated motion.
Pre-trial documents must be scheduled by court conference after discovery completion.
Discovery disputes require letter-motion (max 3 pages) and 5-day response.
All adjournment, extension, and pre-motion conference requests must be filed as ECF letter-motions.
Non-moving party must notify Court within 10 days of motion to dismiss whether it will amend or rely on current pleading.
Summary judgment motions must be submitted within 30 days of close of discovery unless Court orders otherwise.
Pre-motion conference required for summary judgment before discovery closes; 2-page letter and 3-day response allowed.
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.
Pre-motion letter required for summary judgment motions (14 days after discovery closes)
Pre-motion conference required for non-incarcerated pro se cases.
Discovery disputes require meet-and-confer before filing 5-page ECF letter motion; responsive letters due within 3 business days.
Pre-motion letter required at least 4 days before conference.
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 conference required before filing motions
Counsel must be prepared to discuss all pending motions at initial conference.
Patent cases require Rule 16 conference with pre-conference scheduling discussion.
Patent cases: claim construction first, intrinsic evidence only before discovery.
FLSA cases require Rule 16 conference without standard case management form.
Post-discovery qualified immunity motions require pleading as affirmative defense and full discovery.
Plaintiff deposition required before briefing pre-discovery qualified immunity motion.
30 days to file brief after plaintiff deposition for qualified immunity motion.
14 days to file omnibus reply brief addressing qualified immunity and other grounds.
Pre-answer qualified immunity motions converted to summary judgment; only plaintiff deposition considered.
Answering papers due 14 days after moving papers; reply papers due 5 days after that. No return date to be set.
Letter motions only accepted if allowed under Local Rule 7.1(d) or Clerk's “Text Only Orders” program.
Requests must be made via ECF, not fax or mail. Includes various motion types like extensions, adjournments, protective orders, etc.
In limine motions must be filed within 5 days after final pretrial conference notice.
Discovery motions must follow Local Civil Rule 37.2.
Pre-motion conference required for most motions except specified exceptions.
Motions to dismiss require pre-motion letter with arguments/case law, stay answer deadline, and allow 7-day response.
Pre-motion conference letters limited to 3 pages; responses due within 7 days.
Discovery disputes require conference before filing letter-motion (max 3 pages)
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
Pre-motion conference required before most motions, with specific exceptions.
Pre-motion letter (max 3 pages) required from moving party; opposition letter (max 3 pages) due within 3 business days.
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.
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.
Letters requesting relief must be filed as letter-motions via ECF.
Pre-motion conference required for most motions except specified exceptions.
Pre-motion letter (max 5 pages) required; opposition letter (max 5 pages) due within 5 business days; no reply letters without permission.
Filing pre-motion letter under Rule 12(b) stays time to answer or move to dismiss.
Order to Show Cause requires conference with parties before signing.
Request Order to Show Cause conference via letter-motion under Rule 2(C).
Conference with adversary required before emergency relief/TRO unless Rule 65(b) applies.
File letter-motion via ECF when seeking TRO, stating notice/consent status or Rule 65(b) applicability.
If adversary notified but doesn't consent to emergency relief, provide alternative dates for Court conference.
One week before preliminary injunction hearing, submit counsel contact information.
One week before preliminary injunction hearing, submit claim elements with evidentiary support.
One week before preliminary injunction hearing, submit witness list with descriptions and time estimates.
One week before preliminary injunction hearing, submit exhibit list with objections and pre-marking designations.
Motions to exclude expert testimony must be made as motions in limine for trial unless good cause shows they're needed to resolve summary judgment or other dispositive motions.
Single motion in limine allowed, must comply with Individual Practices Rule 4.
Motions in limine must be filed via ECF with specific briefing deadlines.
Discovery motions require pre-motion conference with Court.
Discovery motions require a pre-motion conference per Local Rule 37.2.
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.
Parties must get Court approval for alternate briefing schedules via notice of motion or Letter-Motion.
Pre-motion conference required for most motions except specified exceptions.
Pre-motion letters limited to 1,050 words (moving/non-moving) and 700 words (reply), with 3 business day response time.
Sur-reply memoranda are prohibited unless permitted for good cause in extraordinary situations.
Pre-motion letters/conferences required only for discovery disputes and SJ in non-jury cases.
Summary judgment motions in non-jury cases require prior leave via ECF letter.
Only one summary judgment motion permitted without prior Court approval.
Default judgment must be sought by motion on ECF, not by order to show cause.
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.
TRO applications require notice to adversary unless notice would cause immediate and irreparable injury.
Discovery disputes require meet-and-confer before filing 3-page letter-motion, with 3-page response due within 3 business days.
Pre-motion letter (max 3 pages) required before filing motions, with 3-page response due within 3 business days.
Post-discovery dispositive motions require letter submission per Rule 4(A), with opposition due 3 business days later.
Adjournment, extension, and pre-motion conference requests must be filed as letter-motions via ECF.
Motion briefing limited to three rounds: supporting, opposing, and reply.
Motion briefing is limited to three rounds: opening, opposition, and reply.
Motions in limine require certification of good faith conference between parties before filing.
Pre-motion conference required before any motion except specified exceptions.
Discovery motions require pre-conference letter (max 3 pages) certifying good faith conference and adversary position.
Pre-motion letter limited to 3 pages before motions.
Motions in limine must be fully briefed 3 business days before final pretrial conference.
Pre-motion conference request letter limited to 5 pages.
Moving party must serve pre-motion letter to other parties.
Pre-motion conferences required for specific motion types.
Other parties must respond to pre-motion letter within 3 business days (max 5 pages).
Pre-motion letters must follow Rule I(A) filing requirements.
Oral argument requests must follow Rule I(A) filing requirements.
Discovery motions require an informal conference request before filing.
Discovery-motion practice requires strict compliance with the Rule 37(a)(1) meet-and-confer requirement.
A pre-motion conference is required for motions generally, with specific listed motion-type exceptions.
For reargument or reconsideration motions, opposition is due in 14 days and reply is due in 7 days.
The moving party must submit a pre-motion letter limited to 3 pages, excluding letterhead and signature blocks, explaining the basis for the anticipated motion.
The opposing party must submit a responsive pre-motion letter within 3 business days, with a 3-page limit.
Counsel must hold at least a one-hour good-faith settlement meeting at least 14 days before filing the joint pretrial order.
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
Pre-motion conference required only for motions to dismiss, amend, or summary judgment.
Opposing parties must respond to non-consented letter-motions within 2 business days.
Court reporter not present at Initial Pretrial Conferences unless requested via letter-motion 1 week before.
Initial Pretrial Conferences are via teleconference unless Court directs otherwise; in-person requests must be made 1 week before.
Discovery disputes require good faith meet-and-confer attempt before filing 3-page single-spaced letter-motion on ECF.
Pro se discovery disputes may be resolved via informal conference if meet-and-confer fails or non-moving party unavailable.
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.
Motion for default judgment required under FRCP 55(b)(2) and LCR 55.2(b); order to show cause not permitted.
Opposition papers must be filed within 30 days; reply papers within 2 weeks.
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 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.
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.
Opposition papers due within 30 days; reply papers due within 2 weeks.
Pre-motion conference required for dispositive motions, with pre-motion letter due at least two weeks before conference.
Motions in limine require certification of good faith conference with opposing counsel before filing.
Sur-replies require prior court permission.
Letter-motions must comply with S.D.N.Y. Local Rules and ECF Rules; adjournments, extensions, and pre-motion conferences should be filed as letter-motions.
Pre-motion conferences required for motions before Judge Ricardo, except for specified motion types.
Discovery motions require good faith conference with opposing parties before filing.
After failed discovery conference, moving party must file letter-motion requesting court conference.
Discovery letter-motion must certify conference and include date, participants, adversary positions, and impasse notification.
Opposing party must respond to discovery letter-motion within 3 business days as a letter, not letter-motion.
Pre-motion letter (max 3 pages) required for non-discovery motions.
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 conference required before filing motion for summary judgment.
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.
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 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.
Pre-motion letter (max 750 words, single-spaced) required before motions to dismiss.
Parties must confer on discovery disputes before contacting the Court.
Pre-motion conference required for summary judgment and dispositive motions, to be requested in writing at least 2 weeks before deadline.
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.
Declining to amend after fully briefed motion to dismiss may waive right to cure defects through amendment.
Sur-reply memoranda require prior court permission.
Sur-reply memoranda require prior permission from the Court.
If adversary notified but doesn’t consent to TRO, application must be heard at mutually agreeable time.
Discovery disputes must be addressed in pre-motion conference
Initial conference not automatically cancelled if fully briefed motion is pending, even with stipulated case management plan.
Oral argument requests must be made by letter when filing papers; rarely granted; Court decides case-by-case.
Leave to amend unlikely if non-moving party doesn't amend and motion to dismiss is granted.
Pre-motion conference request for motion to dismiss stays deadline to move or answer.
Parties may agree to alternate briefing schedule but must get Court approval.
Opposing party may respond to discovery dispute motion within 2 business days electronically.
A pending motion to dismiss cancels any scheduled initial scheduling conference.
Cross-motions are prohibited.
Pre-motion letters don't stay deadlines except for motions to dismiss.
Requesting a pre-motion conference for a proposed motion to dismiss stays the requesting party’s deadline to move or answer.
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
Incomplete rule about deposition requirements for summary judgment motions.
Declining to amend after motion to dismiss may waive right to cure defects later.
Remote conference requests require letter-motion and Court approval even if on consent
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.
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 and pre-motion letters are not required in pro se cases.
Oral argument may be requested by letter when filing motion papers.
Pre-motion conferences not required except for discovery disputes.
Court typically sets consolidated briefing schedule for summary judgment motions with initial motion, cross-motion, and replies.
Pre-conference phone call scheduled approximately one week before conference.
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.
Final pretrial conference scheduled 2 weeks before trial; counsel must attend and be prepared for settlement discussions.
Court responds to pre-motion letter within 3 business days indicating whether conference will be scheduled.
Most motions are resolved on submission; oral argument may be requested at pre-motion conference.
Pre-motion submissions not required for pro se parties.
Oral argument may be requested by letter when filing motion papers.
Court will deny original motion to dismiss as moot without notice if moving party files answer or new motion.
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.
Summary judgment motions may be filed directly (28 days after discovery closes)
Oral argument not permitted unless otherwise ordered.
Initial Rule 16 conference scheduled within one month of Answer filing.
Initial pretrial conferences are automatically scheduled by phone unless parties request in-person.
Court may hold or adjourn initial conference to discuss pending motion that is not fully briefed.
Decision on fully-briefed motion may be announced at conference, or case management plan entered pending resolution.
Patent cases require discussion of ownership and chain of title if patent holder is not inventor.
FLSA cases: discuss merits and conditional certification at Rule 16 conference.
Pre-motion conferences are not required for substantive motions.
Motions for reconsideration are reviewed by Judge McMahon who decides if response is needed; opposing party only responds if directed.
Date calculations follow FRCP 6 for civil matters and FRCrP 45 for criminal matters.
Pre-motion conferences are not required.
Motions can be returnable on any day of the week.
Counsel should not appear in Court on the return date.
Court schedules oral argument if desired.
No pre-motion conference or permission required; motions may be filed at attorney discretion.
Oral argument may be requested by letter when filing motion papers; Court decides whether to grant.
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.
Oral argument not ordinarily heard on motions but encouraged for substantive motions; parties may request by letter when filing motion papers.
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.
Pre-motion conferences are optional for non-discovery motions; may be requested by letter motion.
Parties encouraged to agree on briefing schedule before filing formal motions.
Pre-motion conference not required for non-discovery motions but may be requested by Letter-Motion.
Opposition and reply papers due per Local Civil Rule 6.1 unless otherwise ordered.
Oral argument requests must be made by Letter-Motion via ECF.
Oral argument rarely held; request by marking cover page or filing letter on ECF explaining benefit.
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.
Pre-motion conference is not required.
Motions (except Orders to Show Cause) should be filed without a return date.
Multiple motion types are exempt from standard pre-motion requirements
Pre-motion conferences not required except for discovery motions.
Oral argument may be requested by letter when filing motion papers.
Court contacts parties for oral argument after motion is fully briefed.
Pre-motion conferences not required in pro se cases.
Oral argument may be requested by letter when filing motion papers.
Court decides whether to grant oral argument and sets date.
Counsel are encouraged to request a settlement conference before the assigned magistrate judge.
Parties may request oral argument; Court will advise if granted and schedule date
Pre-motion letters and conferences are not required unless ordered by the Court.
Court sets date for Joint Pretrial Order at Initial Pretrial Conference or Post-Discovery Status Conference.
Oral argument is not heard in pro se matters unless ordered.
Oral argument will not be heard in pro se matters unless the Court orders otherwise.
Pre-motion conferences required only for discovery disputes.
Pre-motion conferences are not required except for discovery disputes.
Pre-motion conference requirement is waived for motions in limine.
Central District of California
View all rules for CDCA.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.
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).
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.
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.
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.
Lead trial counsel must meet and confer in person 6 weeks before FPTC.
Motions in limine must be noticed 1 week before FPTC and 1 week after trial filings.
Parties limited to 5 motions in limine each unless Court grants leave.
Replies to motions in limine are not allowed and will be stricken.
Parties must meet and confer before filing motions in limine.
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.
Pre-filing conference required before filing motions, must be in person or by phone/video, not written correspondence.
Meet and confer required before filing motions for attorney fees.
PLRA exhaustion issues must be raised at litigation start; hearing requests due within 14 days of summary judgment denial.
ERISA benefit claims resolved on administrative record; no summary judgment motions without agreed facts; standard of review motions allowed.
Motions (except in limine) briefing schedule: motions 5 weeks, oppositions 3 weeks, replies 2 weeks before hearing.
Pre-filing conference required 7 days before filing any motion.
Meet and confer required before filing motions or ex parte applications.
Ex parte applications require strict procedures, 24-hour opposition deadline, no replies without authorization, and are decided on papers unless hearing ordered.
Summary judgment motions can be filed before motion cutoff with 35 days’ notice required.
Pre-motion conference required before filing motions in limine.
Pre-motion conference for motions in limine must occur within 10 days of request letter and at least 21 days before Pre-Trial Conference.
Motions in Limine filing and hearing dates specified in Schedule of Trial and Pre-trial Dates
Class certification motions must follow Local Rule 23-3 and deadline on last page of order
Motions in limine hearing scheduled 1 week and 4 days before trial.
Pretrial conference scheduled 3 weeks and 4 days before trial at 1:30 p.m.
Motions in limine must be filed 4 weeks and 2 days before trial.
Last date to hear motions is 10 weeks and 4 days before trial.
Last date to conduct settlement conference is 11 weeks and 4 days before trial.
Last date to hear motions to amend pleadings or add parties is 12 weeks after notice of scheduling date.
Pretrial motions must be noticed for mutually agreed Friday.
Briefing schedule: motions 5 weeks, oppositions 3 weeks, replies 2 weeks before hearing.
Motions must be filed 14 days before hearing with 10-page limit; oppositions 7 days before with 10-page limit; replies optional 3 days before with 5-page limit; proposed orders not required.
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.
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.
Extended briefing schedule for summary judgment motions: motion 5 weeks before hearing, opposition 3 weeks before, reply 2 weeks before.
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.
Counsel must meet with opposing counsel to resolve discovery disputes before filing motion.
Criminal motion hearings are Tuesdays at 8:00 a.m.; include time estimate for hearings over 30 minutes; meet and confer before filing.
Pretrial motions: file motion 4 weeks before hearing, opposition 3 weeks before, reply 2 weeks before.
Motions in Limine (MILs) are heard at pretrial conference and require Joint MIL and meet-and-confer declaration.
Before filing Joint MIL, moving party must email evidence issues and meet within 5 days; JMIL must include bold relief statement and underlined party contentions.
Moving party's JMIL portion must be provided to opposing party 28 days before pretrial conference.
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.
JMIL briefing schedule: moving party 25 days before PTC, opposing party 18 days before PTC, reply 14 days before PTC.
Pre-filing conference required before filing any motion under Local Rule 7-3.
Daubert motions due within 7 days after expert discovery cut-off
Daubert motions must be noticed for first available motions date at filing
Pre-filing conference required before filing any motion per Local Rule 7-3, applies to attorneys and pro se parties.
Multiple summary adjudication motions by same party require leave of court; subsequent motions without leave will 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.
Counsel must hold a pre-filing meet-and-confer under Local Rule 7-3 before motion practice.
The pre-filing meet-and-confer requirement still applies even if one or more parties are pro se.
L.R. 7-3 requires prefiling conference to discuss motion substance and potential resolution.
Motions in limine must be noticed for hearing on the Final Pretrial Conference Date.
Daubert motions must be noticed for hearing at least 8 weeks before Final Pretrial Conference.
In class actions, parties must begin discovery immediately to file class certification motion expeditiously.
Extended briefing schedule required for class certification motions.
PLRA exhaustion motions must be raised at litigation beginning and filed within 14 days.
Opposing party must file opposition papers within 48 hours or by 3pm next court day, whichever is later.
Reply briefs not permitted for ex parte applications.
Class certification motions must be filed expeditiously without scheduling conference unless court orders otherwise.
ERISA summary judgment motions must distinguish Kearney v. Standard Insurance and explain why not precluded.
ERISA cases: prepare administrative record and briefing immediately upon complaint service.
ERISA court trial scheduled within 6 months of complaint filing unless good cause shown.
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.
Meet and confer required 60 days before motion hearing cutoff for MSJs.
Meet and confer required at least 60 days before MSJ hearing cutoff
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-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.
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.
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.
Pre-filing conference required to discuss motion substance and potential resolution.
Rule 56 motions require 35-day filing deadline, 21-day opposition deadline, and 14-day reply deadline.
Opposition to ex parte applications must be filed within 24 hours of service.
Opposition to TRO applications must be filed within 24 hours of service.
Court will not rule on TRO applications for at least 24 hours after service unless notice is excused.
Court will issue scheduling conference order; strict compliance with FRCP 16 and 26 required.
Settlement conference or ADR required in every case.
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).
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.
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.
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.
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.
Pre-filing conference required before filing motions.
Pre-filing conference requirement applies even with pro se parties.
Pretrial motions must be filed 28 days before hearing with specific deadlines for opposition (21 days) and reply (14 days).
Discovery motions require meet-and-confer and specific content about prior requests.
Emergency relief requests must comply with FRCP 65 and Local Rules 7-19 and 65.
Motions pending in state court must be re-noticed under Local Rule 7 after removal.
ERISA cases: Court will not hear summary judgment motions without agreed statement of facts.
Class certification motions must be filed within 120 days of service or removal notice.
Local Rule 7-3 requires a pre-filing conference to discuss the motion's substance and potential resolution.
Pre-motion letter briefs (max 5 pages) required for summary judgment motions; opposition briefs due within 7 days; no reply without permission.
Opposing parties have 48 hours to file opposition papers after receiving ex parte application.
Must seek consent before substituting defendant for Doe; if denied, file motion addressing diversity jurisdiction.
Discovery motions require compliance with pre-motion telephonic discovery conference procedure.
Discovery motions filed without compliance or leave will be stricken.
Pre-filing conference required to discuss motion substance and potential resolution.
Meet and confer must be by phone, videoconference, or in person; email insufficient.
Motion notice must include compliance statement for meet-and-confer requirement.
Cross-motions on same issues prohibited; parties must agree on single motion or file joint submission 45 days before deadline.
Rule 56 briefing schedule: Motion 12 weeks before hearing, Opposition 4 weeks after Motion, Reply 2 weeks after Opposition.
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.
Conference of Counsel required at least 7 days before filing most motions.
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.
Opposition to summary judgment must be filed at least 5 weeks before hearing.
Reply to summary judgment must be filed at least 4 weeks before hearing.
Multiple motions cannot be used to evade page limits.
Summary judgment motions must be filed at least 7 weeks before hearing.
Reply to class certification must be filed at least 4 weeks before hearing.
Meet and confer required before filing any motion.
Meet and confer must occur at least 7 days before filing motion.
Only one Rule 56 motion allowed without leave of court.
Motions in limine must be scheduled for hearing one week before Final Pretrial Conference.
Replies to motions in limine are not allowed and will be stricken.
Class certification motions must be filed at least 7 weeks before hearing.
Opposition to class certification must be filed at least 5 weeks before hearing.
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.
Ex parte applications only for extraordinary relief; sanctions for misuse.
In ERISA cases, only motions on standard of review, discovery, and administrative record scope are permitted; summary judgment motions are discouraged.
Motions to dismiss can often be avoided through meet and confer under Local Rule 7-3.
Unopposed ex parte applications may be denied; denial doesn't excuse deadlines.
ERISA cases: only motions for standard of review, discovery, or administrative record scope permitted.
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.
Parties must follow briefing schedule unless Court approves alternate schedule.
Ex parte applications allowed only for extraordinary relief; misuse may result in sanctions.
Failure to file class certification motion timely may result in sanctions including striking class allegations.
ERISA cases: summary judgment motions require agreed statement of facts; court hears motions on standard of review and administrative record scope.
Good faith meet-and-confer under Local Rule 7-3 can avoid many motions to dismiss or strike.
Summary judgment motions may be filed before motion cut-off date and must be heard before Final Pretrial Conference.
Failure to meet and confer in good faith may result in motion being struck or denied.
Parties should confer in good faith to avoid motions to dismiss and consider amendments before filing.
Refer to Standing Order for motion requirements
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.
Court may rule orally on motions in limine instead of in writing.
Court prefers Daubert motions heard 4 weeks before other motions in limine.
Ex parte applications are decided on papers without hearing.
Exemptions from pre-filing meet and confer: pro se cases, Local Rule 16-12 exempt cases, discovery motions, TRO/injunction applications, cost retax motions.
Pre-motion conference may be by video/phone if counsel are in different counties in Central District.
Motions for class certification must follow Local Rule 23-3 unless otherwise ordered.
Motions in limine will be ruled on at final pretrial conference.
Bankruptcy appeals are considered on the papers without hearing.
Default briefing schedule is minimum; parties may stipulate to extended schedule with at least 2 weeks between reply and hearing.
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.
Good faith conferences under Local Rule 7-3 can avoid motions to dismiss/strike.
Motions in limine will be heard on the scheduled pretrial date unless otherwise ordered.
Good faith conferences under Local Rule 7-3 can avoid many motions to dismiss or strike.
Court will not rule on TRO/injunction for at least 48 hours after service.
ERISA cases may receive scheduling conference order as matter of course.
ERISA matters may be decided on papers without oral argument if court determines no benefit.
Bankruptcy appeals deemed under submission upon filing of appellant's reply brief.
Bankruptcy appeals usually decided on papers without hearing.
If Pretrial Conference is waived, counsel must follow Local Rule 16-11.
Parties may modify pre-filing deadlines by agreement without court leave if all parties agree and MSJ is timely filed.
Court meets with counsel to settle instructions before closing argument.
Pre-filing conference should resolve issues to focus briefing on substantive matters.
Minor procedural matters should be resolved during pre-filing conference.
Ex parte applications are decided on papers without hearing.
ERISA cases: Court trial will be confined to oral argument on administrative record.
Hearings on ex parte applications only if deemed necessary by the Court.
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.
Reply briefs must be filed within 2 weeks of the opposition brief.
Meet-and-confer required before filing most motions.
Meet-and-confer must be in person or by videoconference.
Motions in limine due 2 weeks before hearing; opposition due 1 week before.
Meet and confer required before filing ex parte motions.
Noticed motions must set hearing date 35 days from filing date.
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.
Request special equipment via joint/ex parte motion at least 7 days before hearing/trial.
Rule 26(f) conference required for civil cases to discuss discovery topics.
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.
Motions in limine must be filed 2 weeks before hearing, opposition 1 week before.
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.
Motions in limine due two weeks before hearing; opposition one week before.
Meet and confer required before filing motions in limine.
Parties must attempt to resolve discovery disputes through meet and confer before filing a motion.
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.
Meet and confer required before discovery dispute can be addressed.
Rule 26(f) conference timing requirements.
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 to compel require completing the Rule 26 meet and confer obligation before filing; applications without it will be rejected.
Written motion required to excuse defendant's appearance, signed by defendant.
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 2 weeks before hearing, opposition 1 week before.
Reply briefs must be filed within 2 weeks of the opposition brief.
Meet and confer requirement before filing any noticed motion (except pro se cases and TRO/preliminary injunction applications).
Meet and confer must occur at least 7 days before filing the motion.
Opposition briefs must be filed within 3 weeks of the motion.
Court's briefing schedule supersedes Civil Local Rule 7.1(e).
Ex parte motions require meet-and-confer, declaration, and service on opposing counsel; unopposed motions may be granted after 2 court days.
Pre-motion conference required for motions in limine with declaration confirming meet and confer.
Meet-and-confer required before filing most motions.
Meet-and-confer must be in person or by videoconference.
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.
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.
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.
Rule 26(f) conference required for civil cases to discuss discovery topics.
Motions in limine due 2 weeks before hearing; opposition due 1 week before.
Three-page single-spaced letter brief required before informal discovery conference.
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.
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.
Counsel must attempt to confer and resolve deposition disputes before contacting the court.
TRO motions must be briefed; ex parte hearings only in extraordinary circumstances.
Exceptions to meet-and-confer: pro se plaintiffs, TROs/PIs, summary judgment motions.
TROs must be briefed; ex parte hearings only in extraordinary circumstances.
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.
10 minutes per side for voir dire on non-complex cases.
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.
Exceptions to meet-and-confer: pro se plaintiffs, TROs/PIs, summary judgment motions.
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
Court may grant bail modification without hearing.
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.
10 minutes per side for voir dire on non-complex cases.
Motion hearing date sets briefing schedule, not appearance requirement.
Motions are heard on Friday at 11:00 AM; changes require Courtroom Deputy approval.
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.
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.
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 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.
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.
Discovery motions require joint pre-motion letter describing meet and confer efforts.
Pre-motion conference required for most motions except specified exceptions.
Pre-motion letter (max 3 pages) required, with 5-day response period.
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.
Discovery motions under Rules 26-37 require an informal conference request before the motion will be heard.
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.
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.
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.
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.
Discovery disputes require joint letter (max 3 pages per party).
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.
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.
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.
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 Rule 12, 56, venue change, or Rule 15 leave motions when all parties are represented.
Pre-motion letter limited to 3 pages; responses due within 7 business days.
Cover letter only filed via ECF "letter" event; papers served but not filed initially.
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.
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 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.
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.
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.
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.
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.
Pre-motion letter (max 3 pages) required to request pre-motion conference.
Opposition to pre-motion letter must be filed within 7 days (max 3 pages).
Pre-motion conference required before dispositive motions and venue change motions.
Summary judgment pre-motion letters must include both parties' Rule 56.1 statements.
Movant must exchange Rule 56.1 statements with opposing counsel before pre-motion conference.
Movant must submit both parties' Rule 56.1 statements with pre-motion conference request.
Pre-motion conference required before summary judgment motion.
Summary judgment pre-motion letter (max 3 pages) must include both parties' LR 56.1 statements.
Briefing schedule set at pre-motion conference or directly by court; no changes without approval.
Audio/video exhibits require short letter motion for leave to file via Box.com.
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.
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.
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.
Summary judgment requires Rule 56.1 statement followed by counter-statement within 7 business days
Pre-motion conference request letter limited to 2 pages with Rule 56 statements
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.
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.
Parties must make good faith efforts to resolve disputes before filing other non-dispositive motions.
A joint discovery-dispute letter used to request a conference is limited to five pages.
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.
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.
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.
Parties may bypass pre-motion conference if delay would deprive substantive right, by filing within FRCP time with explanation.
Briefing schedule approved after pre-motion conference; changes require court approval.
Response to pre-motion conference letter is optional, limited to 3 pages, due within 7 days.
Any opposition to a pre-trial memorandum must be filed within one week of the joint pre-trial order filing.
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.
The Court may treat pre-motion letters as the motion and opposition, hold a hearing, and deem unraised arguments waived.
Oral argument is not available on letter motions unless the Court specifically orders it.
Sur-replies are prohibited unless the Court grants prior leave.
Pre-motion conference letter requirements do not apply to Rule 50, Rule 59, and Rule 60 motions.
Motions implicating time-limiting rules are exempt from pre-motion conference requirements.
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.
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.
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.
No pre-motion conference is required for these non-dispositive motion procedures.
Pre-motion conference not required for criminal motions.
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.
In criminal cases, oral argument dates for motions are set by the Court.
Pre-motion conferences not required for Judge Cho.
Court may order briefing after conference for discovery disputes.
Non-dispositive motions encouraged by letter.
Deposition disputes must first be resolved among parties.
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 not required if any party is pro se.
Pre-motion letter counts as motion for timing purposes under Rules 12(a) and 56(b).
Oral argument may be requested by letter when filing motion papers.
Pre-motion conference letters are not required for Rule 50, 59, and 60 motions.
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 skip the conference and set briefing directly, and if a conference occurs the Court sets the briefing schedule there with prompt motion filing expected.
Pre-motion conference requests are not required for motions other than those specifically covered elsewhere.
Discovery and other non-dispositive letter motions do not require a pre-motion conference.
Pre-motion conference requirement excused for pro se parties and certain case types.
Pre-motion conference letter is considered equivalent to the motion for timing purposes.
Pro se parties exempt from pre-motion conference requirements.
No pre-motion conference is required for motions submitted to Magistrate Judge Scanlon.
The pre-motion conference may be the only oral-argument opportunity, and counsel should expect a short post-conference motion filing schedule.
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.
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 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
Discovery disputes must be addressed by counsel before requesting court intervention, with certification of good faith efforts.
Preliminary pretrial conference scheduled after all defendants appear; lead trial counsel must attend in person; rescheduling requires pre-existing commitment.
Rule 12 motions require contacting opposing counsel at least one week before filing to discuss substance and cure issues.
If no agreement on Rule 12 motion, parties must submit 5-page single-spaced letter to Judge Wolson by answer deadline.
Moving party must serve joint statement of undisputed facts 28 days before summary judgment deadline.
Responding parties must serve responses to factual assertions 14 days before summary judgment motion deadline.
For cross-motions, each movant files separate statement of facts but must prepare single consolidated set of exhibits.
Expert inadmissibility arguments must be raised in separate Daubert motion, not in summary judgment briefing.
Pre-motion conference required 7 days before filing Rule 12(b)(6) motions.
Certification of substantive verbal pre-motion conference required with Rule 12(b)(6) motions.
Insufficient pre-motion efforts will result in denial of Rule 12(b)(6) motion.
Threshold motions must be filed before Rule 16 conference.
Pre-motion conference required 7 days before Rule 12 motions (except pro se, bankruptcy, social security cases).
Moving party must serve statement of undisputed facts 28 days before summary judgment deadline.
Responding party must serve response to undisputed facts 14 days before summary judgment deadline.
Meet-and-confer certification required 7 days before filing dispositive motions under Rules 12, 56, 1441, or 1404.
Sentencing motions must be filed 14 days before sentencing; responses 7 days before; sentencing memoranda 7 days before.
Initial Rule 26(f) conference must occur no later than 21 days before initial Rule 16 conference.
Only one Rule 56 summary judgment motion allowed per party without leave, within page/word limits
Moving party must serve statement of undisputed facts 28 days before motion deadline
Responding party must serve response to statement of facts 14 days before motion deadline
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.
Meet and confer required at least 5 days before filing discovery, 12(b), or dispositive motions.
Lead trial counsel must attend Rule 16 conference; substitute with deep case knowledge if lead is on trial.
Reply briefs require leave of court, filed within 5 days with email courtesy copy.
Meet and confer required before filing any motion in limine.
Parties must conduct substantive verbal communications before filing certain motions, with certification required.
Motions that fail to meet meet-and-confer requirements will be denied.
Meet and confer about material facts required 14 days before Rule 56 motions (except pro se prisoner cases).
Discovery disputes require motion to compel after failed resolution attempts.
Reply/surreply briefs require leave of court, filed within 14 days with proposed brief attached.
Rule 26(f) conference required at least 14 days before Rule 16 scheduling conference; mandatory compliance.
Motions in limine must be filed by Scheduling Order deadline.
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.
Rule 16 conference required after answer; lead counsel must appear in person.
Lead trial counsel must appear in person at Rule 16 conference.
Discovery disputes must be resolved by meet-and-confer; disputes must be filed as motions, not letters.
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.
Meet and confer required at least 5 days before filing discovery, 12(b), or dispositive motions.
Lead trial counsel must attend Rule 16 conference; substitute with deep case knowledge if lead is on trial.
Reply briefs require leave of court, filed within 5 days with email courtesy copy.
Meet and confer required before filing any motion in limine.
Threshold motions must be filed before Rule 16 conference.
Pre-motion conference required 7 days before Rule 12 motions (except pro se, bankruptcy, social security cases).
Moving party must serve statement of undisputed facts 28 days before summary judgment deadline.
Responding party must serve response to undisputed facts 14 days before summary judgment deadline.
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.
Final pretrial conference held at least 30 days after discovery closes and during week before trial.
Pending summary judgment motions must be argued at final pretrial conference.
Motions in limine must meet Scheduling Order deadline; late filings require good cause.
Deposition designation disputes resolved at final pretrial conference; specific exchange deadlines apply.
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.
Meet and confer about material facts required 14 days before Rule 56 motions (except pro se prisoner cases).
Discovery disputes require motion to compel after failed resolution attempts.
Reply/surreply briefs require leave of court, filed within 14 days with proposed brief attached.
Meet-and-confer certification required 7 days before filing dispositive motions under Rules 12, 56, 1441, or 1404.
Sentencing motions must be filed 14 days before sentencing; responses 7 days before; sentencing memoranda 7 days before.
Pre-filing meet and confer required for Rule 12, Rule 56, and venue motions at least 7 days before filing with certification; verbal communication required.
Preliminary pretrial conference scheduled after all defendants appear; lead trial counsel must attend in person; rescheduling requires pre-existing commitment.
Rule 12 motions require contacting opposing counsel at least one week before filing to discuss substance and cure issues.
If no agreement on Rule 12 motion, parties must submit 5-page single-spaced letter to Judge Wolson by answer deadline.
Moving party must serve joint statement of undisputed facts 28 days before summary judgment deadline.
Responding parties must serve responses to factual assertions 14 days before summary judgment motion deadline.
For cross-motions, each movant files separate statement of facts but must prepare single consolidated set of exhibits.
Expert inadmissibility arguments must be raised in separate Daubert motion, not in summary judgment briefing.
Rule 12 motions require pre-motion conference: counsel must confer at least one week before due date; if no agreement, submit 5-page letter to Judge by complaint response deadline; pre-motion conference will be held.
For summary judgment motions, responding party must serve response to statement of facts 14 days before motion deadline, followed by moving party reply, resulting in consolidated statement filed with motion; cross-motions require separate statements but single consolidated exhibits.
Expert admissibility challenges in summary judgment motions must be raised in separate contemporaneous Daubert motion, not within summary judgment briefing.
Parties may not respond to motions for reconsideration unless the Court orders a response.
A telephone conference is scheduled before filing responsive briefs on discovery motions.
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.
Pre-motion conference must include substantive verbal communication, not just emails/letters.
Summary judgment rarely granted in non-jury cases.
Summary judgment rarely granted in non-jury cases.
Reply briefs encouraged, may be filed without leave, must be filed within 7 days of opposition brief
Failure to meet and confer may result in motion denial or sanctions.
Motions for leave to reply must specify issues and not include proposed reply.
Pretrial conferences not generally conducted in criminal cases but available upon request.
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.
Rule 16 conference addresses substantive issues; counsel must discuss case strengths/weaknesses and critical documents.
E-discovery agreement required before Rule 16 conference; default order available if no agreement.
Discovery may begin immediately; not delayed by pending motions to dismiss except for complete dismissal motions.
Failure to meet and confer may result in motion denial or sanctions.
Motions for leave to reply must specify issues and not include proposed reply.
Threshold motions must be filed at least 7 days before Rule 16 conference.
Pretrial conferences not generally conducted in criminal cases but available upon request.
Responses to motions must follow Local Rule 7.1(c) timing.
Summary judgment motions typically use alternative method schedule.
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.
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.
Rule 12 pre-motion procedure does not apply in pro se cases.
Moving party may respond to responding party's submissions under relevant paragraphs.
Telephone conference scheduled before responsive brief in discovery motions.
Suppression, Starks, and Daubert hearings held at least 14 days before trial.
Rule 16 conference scheduled after all defendants appear.
Motions in limine filing deadline set at Rule 16 conference and confirmed in scheduling order.
Rule 16 conference scheduled after answer or during preliminary motions.
Moving party may respond to responding party's submissions under each paragraph.
Pretrial conference scheduled at least 3 days before trial if requested or needed
Moving party may respond to responding party's statements directly under relevant paragraphs
Summary judgment rarely granted in non-jury cases.
Rule 16 conference held after all defendants answer; counsel may request if not scheduled.
Pretrial conference scheduled at Rule 16 if no dispositive motions, or after ruling on dispositive motions.
Ruling on reply leave without response; if granted, scope and due date specified.
Oral argument scheduled at Court's discretion; may decide on papers even if requested.
Initial pretrial conference scheduled within 30 days of all defendants filing answers.
Rule 26(f) meeting must occur at least 14 days before scheduling conference.
Counsel must have client authority to speak on settlement at all pretrial conferences.
Counsel must be prepared to argue pending motions at pretrial conferences.
Final pretrial conference typically held during week before trial.
Replies automatically allowed for all motions; surreplies allowed for Rule 56 motions, discouraged for others.
Oral argument held at judge's discretion or upon counsel's request.
Summary judgment motions typically use alternative method schedule.
Parties may agree to a different briefing schedule.
Conference on proposed jury instructions is usually conducted.
Responses to motions must follow Local Rule 7.1(c) timing.
Oral argument is discretionary and granted only when likely to facilitate resolution.
Rule 16 conference held after all defendants answer; counsel may request if not scheduled.
Pretrial conference scheduled at Rule 16 if no dispositive motions, or after ruling on dispositive motions.
Ruling on reply leave without response; if granted, scope and due date specified.
Oral argument scheduled at Court's discretion; may decide on papers even if requested.
Rule 16 conference scheduled after answer or during preliminary motions.
Moving party may respond to responding party's submissions under each paragraph.
Final pretrial conference held 7 days before trial; parties must discuss outstanding motions, evidence disputes, scheduling, and settlement efforts.
Oral argument is generally not required for motions.
Prompt conference held for TRO/preliminary injunction requests.
Prompt conference held with counsel for TRO and preliminary injunction motions after affidavit of service.
Pretrial conferences in criminal cases are generally not held, but may be conducted if counsel requests one.
Parties may agree to a different briefing schedule.
Initial pretrial conference scheduled within 30 days of all defendants filing answers.
Rule 26(f) meeting must occur at least 14 days before scheduling conference.
Counsel must have client authority to speak on settlement at all pretrial conferences.
Counsel must be prepared to argue pending motions at pretrial conferences.
Final pretrial conference typically held during week before trial.
Pretrial conference scheduled at least 3 days before trial if requested or needed
Conference on proposed jury instructions is usually conducted.
Replies automatically allowed for all motions; surreplies allowed for Rule 56 motions, discouraged for others.
Oral argument held at judge's discretion or upon counsel's request.
Rule 12 pre-motion procedure does not apply in pro se cases.
Moving party may respond to responding party's submissions under relevant paragraphs.
Telephone conference scheduled before responsive brief in discovery motions.
Suppression, Starks, and Daubert hearings held at least 14 days before trial.
Rule 12 pre-motion conference requirement does not apply when either party is pro se.
Counsel expected to resolve objections before motions in limine deadlines.
Motions in limine filed after exchange of pretrial memoranda, with reply before pretrial conference.
Southern District of Texas
View all rules for SDTX.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.
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.
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.
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.
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.
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 (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.
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 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.
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.
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.
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 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.
Ex parte TRO applications are only entertained if the initiating party satisfies Rule 65(b) requirements.
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.
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 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.
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.
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.
Discovery disputes that cannot be resolved between parties should ordinarily be submitted by written motion.
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.
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.
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.
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.
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.
Oral argument requests are not required; the Court will notify counsel if oral argument is deemed beneficial.
Criminal motion briefing deadlines follow CrLR12 and Rule 12 of the Federal Rules of Criminal Procedure.
Separate requests for oral argument on motions are not required; the Court will notify counsel if oral argument is warranted.
Initiating letter not required for discovery relief motions against nonparties.
Court will rule on default judgment motions with no hearing no sooner than 21 days after filing.
All pending motions are considered at the Final Pretrial Conference.
Oral argument is not required for motions; the Case Manager will notify counsel 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.
Initiating letter not required for discovery relief against nonparties.
Criminal case motion briefing follows CrLR12 and Federal Rule of Criminal Procedure 12.
Oral argument requests are not required; the Court will notify counsel via the Case Manager if oral argument is deemed beneficial.
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.
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.
Meet and confer required before filing any motion or non-stipulated request, with certification of compliance.
21-day meet and confer on joint pretrial statement and settlement.
Discovery motions must be initiated by filing notice of discovery disputes, not by filing motions directly.
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.
Discovery disputes require live meet and confer (in person/videoconference/phone) before filing motions, unless leave of court is granted.
Motions to strike affirmative defenses require leave of Court via motion for administrative relief under Civil Local Rule 7-11
Motions to strike affirmative defenses require leave of Court obtained via administrative motion.
Request for more than 10 claim terms must show good cause and be filed 2 weeks before joint statement deadline
Non-discovery motions may be noticed for Thursdays at 10:00 AM with 35-day notice period
15 minutes of oral argument time per side for motions
Reply papers cannot raise new points; sur-replies not permitted
Motions must follow Criminal Local Rules 471 and 47-2, with 5:00 PM filing deadlines
Parties must meet and confer to narrow terms to ten before preparing joint statement if more than ten terms are at issue.
Joint statement of undisputed facts required for summary judgment motions on infringement/invalidity.
Motions in limine must be filed 21 days before Final Pretrial Conference; no replies allowed.
Meet and confer required 14 days before settlement conference
Motions in limine require specific timing for service and filing.
Discovery disputes require meet and confer by video conference followed by a joint letter not exceeding 5 pages within 5 business days.
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 (except discovery) must follow Civil Local Rules, except pro se prisoner cases.
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 must meet and confer before filing discovery motions.
Sanctions motions require compliance with meet-and-confer requirements first.
Discovery dispute motions require prior leave of Court unless specifically exempted.
Pre-filing conference required before summary judgment motions.
Pre-filing letter must be submitted 7 business days before proposed conference date.
Opposition parties must respond to pre-filing letter within 3 business days.
Pre-filing conferences must be attended in person; remote appearances not permitted.
Only one summary judgment motion allowed per side without court leave.
Parties must meet and confer 45 days before end of fact discovery to determine cross-motions.
Motion briefing deadlines: 21 days for motions, 14 days for opposition, 7 days for reply.
Discovery dispute motions require prior leave of court.
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.
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.
Motions must be noticed for hearing per Local Rule 47-1; counsel must check judge's calendar before selecting date.
Motions to dismiss and remand are submitted on papers without hearing by default.
Meet and confer in person or by video (or phone if impossible) required 10 business days before filing discovery motion.
Joint letter required within 5 business days after meet and confer for discovery disputes.
Must comply with meet and confer requirements before filing sanctions motion.
Parties filing motions in limine must first seek a stipulation from opposing parties to the requested relief.
Civil motions require hearing except for pro hac vice, time extension, and administrative relief motions.
Civil motions require reservation for Wednesday 9:00 a.m. hearings in San Jose.
Parties must consult website, meet and confer, then jointly contact Courtroom Deputy to reserve hearing.
Maximum 2 motions per party per hearing without leave of court.
Motions must be filed within 3 business days of reservation confirmation.
Failure to file motion within deadline cancels hearing reservation.
Administrative request to appear via Zoom required at least one week before hearing.
Joint case management statement required at least 18 calendar days before case management conference.
21 days before final pretrial conference, lead counsel must meet and confer on joint statement, differences, and settlement.
Joint statement required 7 days before case management conference
Meet-and-confer requirement excused only for emergencies with notification.
Reply briefs to motions in limine are not permitted without prior court order.
Do not request orders where not needed, such as stipulations of dismissal under FRCP 41(a)(1)
Daubert motions must be noticed for hearing by dispositive motion hearing date.
Reply briefs to motions in limine are not permitted without prior court order.
Court will address only one motion for summary judgment per side absent good cause.
Court may reset hearing dates or vacate hearing for matters suitable for decision without oral argument.
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.
If no plaintiff summary judgment motion, defendants may file 5 weeks before cut-off following Local Rule 7-3 schedule.
Meaningful meet and confer should eliminate need to propose different constructions in briefs.
Prehearing conferences not generally held; request case management conference at least two weeks before hearing if witness testimony needed.
Court may order additional briefing, telephonic conference, or in-person meet-and-confer at courthouse with lead trial counsel.
Pre-filing conferences typically scheduled Wednesdays or Fridays at 2:00 PM.
Court strongly prefers four-brief schedule for cross-motions for summary judgment.
Case management conferences held Tuesdays at 9:00 a.m., may be combined with other hearings.
Pre-trial hearings held Wednesdays at 2:00 p.m.
Trials commence Mondays at 9:00 a.m., continue through Thursday, with half-day or full-day schedules.
Filing deadlines are 5:00 p.m. unless otherwise ordered.
Case management conferences via Zoom; other hearings in person unless otherwise noted or leave granted.
Remote participants must follow website directions and ensure good connection without background noise.
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.
Parties must meet and confer before filing any motion; hearing dates must be scheduled via CRS at 9:30 AM Monday-Friday.
Counsel must meet and confer in person, by phone, or videoconference to resolve discovery disputes before filing discovery motions; written exchanges are insufficient.
Law and motion hearing dates must be reserved via phone before filing the motion; hearings are Wednesdays/Fridays at 9:30 AM, no CRS Online system used.
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.
Parties must meet and confer at least 18 days before the Final Status Conference.
Parties must meet and confer at least 15 calendar days before each Case Management Conference.
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.
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.
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.
Written motions during trial require discussion with opposing counsel first; unresolved matters need a court conference.
Motions not assigned to Judge Riff must be scheduled via the online Court Reservation System (CRS).
Informal discovery conference required before filing discovery motion if meet and confer fails.
All motion hearing dates must be reserved in advance via Court Reservation System; hearings held Mon-Fri.
Parties must schedule motion hearing dates via the online CRS before filing any motion papers.
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.
Informal Discovery Conference or court permission required before filing motions to compel discovery.
Discovery motions require Informal Discovery Conference (IDC) before filing, absent good cause.
Parties must meet and confer before filing any motion in limine per LASC Rule 3.57.
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.
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.
Informal discovery conference (IDC) required after meet and confer before filing discovery motions.
Parties must meet and confer in good faith to resolve discovery disputes before filing discovery motions; declaration of attempt required.
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.
Informal Discovery Conference required before filing discovery motions if meet and confer fails.
Meet and confer per CRC 3.724 and 3.727 required prior to each CMC
Motions to compel further discovery require a joint statement for discovery disputes to be filed with the motion.
Simplified Local Rule 37-2 applies to motions to compel further responses (not initial), requiring meet and confer, hearing date reservation, filing notice of motion, and support only via joint dispute statement and supplemental memoranda.
Parties must meet and confer 11 calendar days before Final Status Conference to prepare required documents, stipulate to exhibits/motions in limine/facts, and attempt settlement.
Parties must meet and confer, preferably via conversation, before filing any motion.
Hearing dates must be reserved via the online CRS before filing any motion except motions in limine.
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.
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 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.
An Informal Discovery Conference is required before filing any discovery motion.
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.
Proposed motions regarding a General Order must be authorized by the Supervising Judge of the Civil Division before filing.
Parties must participate in an Informal Discovery Conference (IDC) and meet and confer before filing any discovery motion.
Meet and confer required prior to IDC; disputes resolved before IDC require taking IDC and motions off calendar.
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.
Parties must meet and confer in good faith to resolve discovery disputes before filing a discovery motion.
Regularly noticed motions require hearing date reservation before filing, made by calling the calendar clerk.
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.
Parties must meet and confer in good faith before filing motions in limine; failure to do so may result in summary denial.
In limine motions require meet and confer prior to filing and must be fully briefed on the regular timeline.
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.
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.
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.
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.
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.
Counsel must exhaust meet and confer efforts before filing a discovery motion.
All motion hearing dates must be reserved via the Court Reservation System (CRS) unless leave of court is granted.
IDC required before filing most discovery motions; preferred before all discovery motions except motions to compel with no response.
Parties must meet and confer before filing a demurrer or motion to strike.
Meet and confer per CRC 3.724 and 3.727 is required prior to each Case Management Conference.
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.
Law and motion hearing dates must be reserved via phone call before filing motion; regular calendar Tues/Thurs 1:30 PM; off-calendar motions require written confirmation.
Independent meet and confer is required before filing any motion to compel discovery.
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.
Meet and confer required before filing discovery motions.
Parties must reserve motion dates via CRS before filing any motion papers.
Parties must meet and confer before final status conference.
Motion hearing dates must be scheduled via the online Court Reservation System (CRS).
IDC required before filing Motion to Compel Further Discovery Responses, except Song-Beverly claims; initial response motions exempt.
Motions in limine must comply with CCP 1005 and Local Rule 3.57(a) before filing.
Parties must meet and confer before filing any motion in limine per Local Rule 3.57.
Before filing a discovery motion, counsel must meet and confer; if unresolved, schedule an Informal Discovery Conference, file a 3-page statement 3 days prior, then may file motion if still unresolved.
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.
All parties must meet and confer before filing any motion in limine per Local Rule 3.57.
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.
Trial counsel should meet and confer in person before filing discovery motions.
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.
Counsel must meet and confer on discovery issues; informal discovery conferences with the court are encouraged.
Parties should meet and confer before filing discovery motions; discovery motions are strongly discouraged.
Trial counsel should meet and confer before filing a discovery motion.
Parties are encouraged to stipulate to waive replies to motions in limine.
Parties are encouraged to file no more than five 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.
CRS is not used to schedule motions in cases assigned to Judge Riff for all purposes; call courtroom to schedule.
Motions not assigned to Judge Riff are heard every Thursday at 8:30 a.m.
Informal Discovery Conferences (IDCs) are strongly recommended but not required before filing discovery motions.
Parties are encouraged to meet and confer before filing any motions, including summary judgment/adjudication.
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).
Reply letters only if directed by court.
Affidavits and exhibits not permitted unless directed.
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.
Formal motions require prior leave of Court except Rule 12 motions, timely remand motions, and motions expressly allowed by the Case Management Order.
A pro hac vice application without consent must be filed as a formal motion.
Discovery motions require leave of court and prior compliance with Local Rules 16.1 and 37.1 before filing.
Third-party subpoena enforcement or quash motions do not require meet-and-confer, but still require leave of court before filing.
Formal motions require prior leave from court except for Rule 12 motions, timely remand motions, and those expressly permitted.
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 letter (max 3 pages) required before most motions, with 1-week response window.
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).
Reply letters only if directed by court.
Affidavits and exhibits not permitted unless directed.
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.
Motions in limine must be filed 4 weeks before trial; responsive papers 3 weeks before.
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.
Dispositive motions require prior leave of court via letter application.
ANDA patent cases prohibit summary judgment motions except by waiver letter (3 pages) with 7-day response.
All pre-trial motions including Daubert and in limine motions must be fully briefed and filed 45 days before trial.
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.
Most formal motions require prior leave of court, except Rule 12 motions, timely remand motions, and motions to amend.
Motions require email leave request to Angela DiAndrea with proposed schedule.
Replies to discovery disputes require leave of court.
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.
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.
Proffer of affidavit/exhibit contents by attorney is permitted in pre-motion letters.
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.
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.
Motion practice follows Local Civil Rule 7.1 except as specified.
Western District of Washington
View all rules for WDWA.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.
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.
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
Pre-motion conference with the Court is required for all discovery motions if parties cannot reach agreement.
Sur-replies require leave of court.
Follow Local Rule 7(d) scheduling guidelines; improper motions may be re-noted or struck.
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.
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.
Good faith meet and confer required before filing motions to compel.
Good faith meet and confer required before filing motions in limine.
Discovery motions prohibited until status conference on discovery dispute.
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.
Pro se parties are exempt from discovery dispute conference requirement and may file discovery motions directly.
Pretrial motions deadline is typically set six weeks before trial.
Oral argument granted after briefing; Court contacts parties to schedule.
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.
Specific briefing schedule for cross-motions for summary judgment.
Pro se parties exempt from meet and confer requirement.
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.
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.
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.
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
Pre-conference letter sequencing: moving party files 72 hours before conference, opposing party may file 48 hours before conference.
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.
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.
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 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.
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.
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.
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.
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.
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.
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.
Absent a case-specific order, responses to pre-trial or post-trial motions are due in 21 calendar days, and any reply is due 10 calendar days after the response.
Response to motions must be filed within 21 calendar days of filing.
Reply to motions must be filed within 10 calendar days of response.
Meet and confer required 2-3 weeks before claim construction hearing.
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.
Motion for Discovery required after verbal meet-and-confer fails to resolve discovery/protective order disputes
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.
Discovery disputes require contacting the Court's Case Manager to schedule an in-person 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.
Requests to modify mediation attendance requirements must be in writing 14 days before the conference.
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.
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.
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.
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
No Amended Joint Claim Construction Chart required if no agreements reached in meet and confer.
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.
United States must simultaneously orally move for Court review when requesting magistrate judge stay of release
Additional briefing beyond motion/response/reply requires a motion for leave.
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.
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.
Rule 26(f) conference must be held within 14 days, preferably face-to-face unless attorneys are in different cities.
Before filing a motion to compel discovery, lead counsel must meet and confer in good faith and the party must contact the Court’s law clerk with both sides’ positions.
The responding party must submit its email response within 3 business days.
Transfer motions have fixed filing and briefing deadlines, and late filing requires good cause plus leave of court.
Before an early motion to dismiss indirect or willful infringement claims, the movant must first meet and confer with the opposing party.
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.
Leave of court is required to file a sur-reply.
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.
Hearings on civil motions are not routine; request in opening paragraph if needed.
Motions in limine must be limited to disputed matters.
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.
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.
Hearing on dispositive motions scheduled after response/reply deadlines.
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.
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.
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).
Discovery disputes must be resolved through conference before filing motions; sanctions may be imposed for bad faith.
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.
Parties must meet and confer within 21 days of defendant's response.
Discovery motions require good-faith conference certification and have expedited briefing with shortened page limits.
Responses and replies to discovery motions due within 7 days.
Parties must confer in person or by phone before filing discovery motion.
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 before seeking discovery relief, with at least one personal communication (in person, videoconference, or telephone).
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.
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.
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 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.
Motions in limine cannot be filed before the pretrial conference.
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.
Motions in limine must be filed 3 weeks before hearing, opposition due 2 weeks after, hearing 2-3 weeks before trial.
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.
Pre-filing meet and confer required before motions; certification of efforts required in notice of motion.
Discovery motions must be noticed before assigned magistrate judge.
Informal discovery conferences are optional alternative to formal motions under Local Rule 251.
Motions to tax costs are taken under submission upon filing with no hearing date set unless otherwise ordered.
Ex parte applications are typically submitted to the Court without a hearing unless otherwise notified.
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.
Motions in limine must be fully briefed with Joint Pretrial Statement; opposition due in 5 days, reply in 2 days.
Parties must meet and confer in person on motions in limine.
Oral argument on motions in limine occurs at Pretrial Conference.
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.
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.
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.
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.
Court may strike statements of material fact that do not conform to rules or comply with instructions.
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.
Motions in limine must be filed separately, 21 days before pretrial order, with responses due 14 days before.
Rule 37 meet-and-confer required before filing motions in limine.
Motions in limine must be fully briefed according to court-set schedule.
Motions in limine must be filed 3 weeks before pretrial order; responses due 1 week before.
Parties must meet and confer on jury instructions before filing pretrial order.
Final pretrial conference 1-3 weeks before trial; lead counsel must attend.
Substantial exhibit objections must be filed as motions in limine.
Parties must conduct Rule 26(f) planning conference.
Responses to motions in limine due one week after filing; no replies without leave.
Motions in limine due 3 weeks before pretrial order; responses due 1 week before.
Meet and confer required before filing motions in limine.
Meet and confer required before filing motions in limine; unopposed motions should be described in final pretrial order.
Parties must meet and confer on all motions in limine before filing, and state if there is no objection.
Parties must meet and confer on all motions in limine before filing.
Replies to motions in limine are not permitted unless ordered by the Court.
Daubert motions should be filed early, separately from other motions.
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.
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.
A motion to exceed brief page limits must be filed before the brief's filing deadline.
Reply briefs for §2-615, §2-619, §2-622, and motions to compel require specific leave of court.
Emergency motions require presenting a copy to court staff for approval before scheduling, and must comply with local Rule 2.2.
Reply briefs for 2-615, 2-619, 2-622, and discovery motions require specific leave of court.
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.
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.
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.
Northern District of Texas
View all rules for NDTX.Parties must meet and confer about evidence/exhibits before pretrial conference; only unresolved objections will be considered.
Rule 26(f) conference required in person for represented parties; not required for pro se/prisoner cases.
Pre-motion conference required before filing Rule 12(b)(6) motions.
Written notice of deficiencies required before Rule 12(b)(6) motions.
Advisory of intent to amend required within 7 days; amended complaint due 7 days after advisory.
Rule 12(b)(6) motion permitted if complaint not amended by deadline.
Rule 12(b) motions without certificate of conference will be stricken.
Local Rule 5.1(a) requires moving party's counsel to confer with all affected parties' counsel before filing any motion; conference may be written, refusal to participate is prohibited.
Rule 16 conference will be set unless Court schedules otherwise; scheduling order follows Joint Status Report.
Eastern District of Texas
View all rules for EDTX.Pretrial motions in criminal cases are referred to magistrate judges, except for specific motions.
Motions to compel discovery require good faith conference first.
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.
Prepare half-page summary of key points and authorities before calling court on discovery disputes.
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.
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.
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.
Adoption, arbitration, family, mental health, and other specified case categories are exempt from Initial Case Management Conference requirements.
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.