Judge Jay Polk
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Exhibits
Binding: Tabbed Three Ring
Communication
Phone
Chambers
Page & Word Limits1 rule
Checked against the court's document on Oct 3, 2026Important
Motions must comply with court-rule page limits; a party seeking an extension should file a brief explaining the reason.
All motions must adhere to the page limitations set forth in the court rules. If you believe the page limitation needs to be extended, you should file a brief explaining why.
Motion
Document Filing Requirements10 rules
Checked against the court's document on Oct 3, 2026Mandatory
Joint pretrial statements are required, but separate statements are accepted when the parties cannot agree or work together.
Joint Pretrial Statements are required. Because the information contained in this filing is so important, separate statements are accepted if the parties cannot agree or are unable to work together. I would rather have two, separate pretrial statements than none at all.
Document Type
Joint Pretrial Statement
Checked against the court's document on Oct 3, 2026Mandatory
A motion to withdraw must comply with Arizona Rule 5.3; without the client’s written consent in a pending matter, the court waits until the response period has passed, and counsel must serve the motion on the client and state that service in the certificate of service.
When filing a motion to withdraw as counsel of record, counsel must comply with Rule 5.3, Arizona Rules of Civil Procedure. Pursuant to those rules, if a matter is pending and counsel has not obtained the client’s written consent to counsel’s withdrawal, I will not rule on the motion to withdraw until the time for the filing of a response has passed. In addition, if the motion does not bear the client’s written consent, counsel must be sure to serve a copy of the motion upon the client and reflect such service in the certificate of service.
Document Type
Motion To Withdraw As Counsel Of Record
Checked against the court's document on Oct 3, 2026Important
Any document copy submitted to the division by fax, mail, or hand delivery must be file-stamped; the judge can act only on documents filed with the clerk.
When submitting to our division a copy of a document (regardless of whether you are submitting it by fax, mail, or hand-delivery), only submit a file-stamped copy (i.e., a copy that bears the Clerk of Court’s filing stamp indicating the date the document was filed). I can only act upon documents that have been filed with the Clerk of Court.
Document Type
Document Copy Submitted To The Division
Checked against the court's document on Oct 3, 2026Important
Lawyers and self-represented litigants are expected to know and follow applicable court rules.
I expect all lawyers, regardless of their years of experience, and self-represented litigants to be familiar with, and follow, the applicable court rules. See Higgins v. Higgins, 194 Ariz. 266, 981 P.2d 134 (App. 1999) (holding that a person who represents himself “is held to the same familiarity with court procedures and the same notice of statutes, rules, and legal principles as is expected of a lawyer”).
Requirement
Document requirement
Checked against the court's document on Oct 3, 2026Important
Discovery motions must include the Rule 37(a)(1) certification; absent certification, the judge generally will summarily deny the motion, while a certified motion generally leads to a telephonic conference.
If I receive a motion pertaining to a discovery dispute, I first will check to make sure it contains the certification required by Rule 37(a)(1), Arizona Rules of Civil Procedure. If it does not, I generally will summarily deny the motion. If the motion does contain the required certification, I generally will schedule a telephonic conference, particularly if a hearing is set in the near future.
Document Type
Motion Pertaining To A Discovery Dispute
Checked against the court's document on Oct 3, 2026Important
An accelerated-ruling request must be noted under the motion title and briefly explained in its body, without a separate request motion or proposed order.
When asking for an accelerated ruling on a motion, do not file a separate motion asking for an accelerated ruling and do not lodge a separate form of order granting a request for accelerated ruling. Instead, simply note under the title of the motion that you are requesting an accelerated ruling and, in the body of the motion, briefly explain why an accelerated ruling is necessary.
Document Type
Motion
Checked against the court's document on Oct 3, 2026Important
Parties settling before trial should submit a signed writing identifying the settlement and events to vacate, and state when any not-yet-prepared settlement agreement and proposed order will be filed; otherwise, the court may require an appearance or conference.
If the parties settle before trial, they should not assume that the Court will vacate any upcoming hearings or other court events. The parties should submit a written document, signed by both parties (or their counsel) that, at a minimum, states that the parties have settled and what upcoming court events can be vacated as a result of the settlement. In addition, if the parties have not yet documented the terms of their settlement in a formal settlement agreement and proposed form of order, they should inform the Court of when they expect to file such agreement and lodge such order. Upon receipt of such information, I likely will vacate the upcoming court event(s) and set a deadline for submission of the settlement documents. Absent such information, I likely will either order the parties and counsel to appear in person to put the agreement on the record or hold a brief telephonic conference with counsel.
Document Type
Settlement Notice
Checked against the court's document on Oct 3, 2026Important
Parties should limit exhibits to relevant material, avoid combining unrelated documents, and consecutively number multi-page exhibits.
Parties should be judicious in the volume of exhibits they offer. Offer only those exhibits that are most relevant to your case, and do not make exhibits overly-voluminous. For example, if you subpoena twelve (12) months of bank statements, yet only one (1) month is necessary for Court review, just mark the one (1) month's statement as an exhibit. In addition, do not offer multiple documents as a single exhibit unless the documents have some direct relationship to one another. For example, do not combine an e-mail with a bank statement, but offering two months of bank statements for the same account is acceptable. Last, for ease of reference, if a particular exhibit has multiple pages, be sure the pages are consecutively numbered, even if this means you need to number them yourself.; otherwise, you will waste your trial time trying to direct the witness (or the Court) to the one page of the multi-page exhibit that is critical to your case.
Document Type
Exhibit
Checked against the court's document on Oct 3, 2026Important
Citations must be checked before filing and include pinpoint citations to specific pages of supporting authorities.
Citations should be double checked prior to filing and must include pin cites, directing the Court’s attention to specific pages of supporting authorities.
Document Type
Filing
Checked against the court's document on Oct 3, 2026Important
A single motion generally should address no more than two discrete issues.
Generally, a single motion should not address more than two discrete issues; otherwise, the motion risks confusing the reader and diluting the arguments being made.
Document Type
Motion
Filing & Service rules
Electronic Filing Rules
Because e-filing is unavailable in probate and mental health cases, lawyers and self-represented parties must ensure the division receives file-stamped copies of filed documents; delivery to another court facility may cause several days’ delay.
Currently, e-filing is not available in probate and mental health cases. Consequently, lawyers and self-represented parties need to be sure that my division receives file-stamped copies of all petitions, motions, objections, responses, and similar documents that are filed with the clerk. Also, be aware that inter-office mail is very slow. Therefore, if you or your messenger delivers the division copy of a document to any court facility other the facility where my division is located (currently downtown), my division likely will not receive the document for several days.
Checked against the court's document on Oct 3, 2026
Page 1 | Motion Practice
Filing Timing and Cure Windows
Exhibits must be submitted to the division clerk at least five judicial days before the hearing or risk exclusion or deduction of marking time from the offering party’s trial time.
Exhibits must be timely submitted to the division clerk. If an exhibit is not submitted at least five judicial days before the hearing, I either will not allow the exhibit to be admitted at the hearing or, in the alternative, the time it takes my clerk to mark the exhibit will be deducted from the offering party’s trial time.
Checked against the court's document on Oct 3, 2026
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections
A motion to dismiss or other dispositive motion filed less than five weeks before trial should not be expected to be decided before trial.
As a result of the time frames for responses and replies, do not file a motion to dismiss (or other dispositive motion) less than five (5) weeks before trial and expect it to be ruled upon before the trial.
Checked against the court's document on Oct 3, 2026
Page 1 | Motion Practice
When a pending matter’s motion to withdraw lacks the client’s written consent, the court will not rule until the response-filing period has passed.
When filing a motion to withdraw as counsel of record, counsel must comply with Rule 5.3, Arizona Rules of Civil Procedure. Pursuant to those rules, if a matter is pending and counsel has not obtained the client’s written consent to counsel’s withdrawal, I will not rule on the motion to withdraw until the time for the filing of a response has passed.
Checked against the court's document on Oct 3, 2026
Page 1 | Other Courtroom Policies and Recommendations
Accelerated or expedited rulings should be requested only for unforeseen circumstances; the judge will not expedite when urgency results from the moving party’s delay and generally will not prioritize a motion that could have been filed sooner.
I will not expedite oral argument or a ruling where it appears that the “need for speed” was caused by the moving party’s delay. I also generally will not put a matter ahead of other matters when the moving party could have filed the motion much sooner. Requests for accelerated/expedited rulings should be reserved strictly for unforeseen circumstances.
Not confirmed. Read the court's wording below.
Page 1 | Other Pre-trial Practice Guidelines or Comments
Service and Proof of Service Rules
If a motion to withdraw lacks the client’s written consent, counsel must serve the motion on the client and reflect service in the certificate of service.
In addition, if the motion does not bear the client’s written consent, counsel must be sure to serve a copy of the motion upon the client and reflect such service in the certificate of service.
Not confirmed. Read the court's wording below.
Page 1 | Other Courtroom Policies and Recommendations
Courtesy Copy Requirements
Bench copies of exhibits are appreciated; a tabbed notebook with exhibit numbers matching the actual exhibits is preferred.
Bench copies of exhibits are appreciated. If the Bench copy is a tabbed notebook, with all exhibit numbers matching the actual exhibit numbers, all the better for the Court to follow the line of questioning, make notes, and speed up the proceeding.
Not confirmed. Read the court's wording below.
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections
Sealing & Redaction Procedures
The judge avoids sealing entire files and typically files documents concerning sensitive matters as confidential, allowing case participants and court staff access while shielding them from public disclosure.
I avoid placing an entire file under seal. However, I typically will file documents that pertain to sensitive matters as confidential documents, which allows the parties, their counsel, and court staff to have access to the documents while protecting them from disclosure to the general public.
Not confirmed. Read the court's wording below.
Page 1 | Discovery or Disclosure Disputes and/or Sanctions
Pre-Motion Conference Requirements
Before submitting exhibits, parties should meet with opposing counsel or the opposing party and try to coordinate their submissions.
Before you submit your exhibits, meet with the opposing counsel or party and try to coordinate the exhibits that are submitted. This will avoid duplication of exhibits and the submission of extraneous exhibits and will ensure consistent numbering, which will make it easier for my staff to provide you with an exhibit worksheet prior to the day of trial (see below).
Checked against the court's document on Oct 3, 2026
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections
Disputes concerning discovery sought from a non-party should follow Arizona Rule of Civil Procedure 37.
If discovery is sought from a non-party (e.g., by means of a subpoena duces tecum), the party requesting the discovery should follow the procedure set forth in Rule 37, Arizona Rules of Civil Procedure, for any disputes pertaining to that discovery. See Ariz. R. Civ. P. 45(c)(5)(B)(ii).
Checked against the court's document on Oct 3, 2026
Page 1 | Discovery or Disclosure Disputes and/or Sanctions
Request oral argument only when intending to present information supplemental to the briefs; oral argument is not automatically granted.
Oral argument should not be requested unless you intend to present information supplemental to what is in the written briefs. Oral argument will not automatically be granted. If oral argument is set, it often means that I have questions about the briefs.
Checked against the court's document on Oct 3, 2026
Page 1 | Motion Practice
For party-to-party discovery disputes, counsel may request a telephonic status conference by email to the Judicial Assistant, copying all other counsel or self-represented parties and providing specified neutral dispute information; the judge decides whether to conference or require a formal motion, and this procedure does not apply to non-party discovery.
In lieu of filing a motion to compel or a motion for protective order, counsel may request a telephonic status conference to discuss a discovery dispute between two or more parties. Any such request should be made by e-mail sent to my Judicial Assistant with all other counsel of record (or a party who is self-represented) copied on the e-mail. The e-mail should state what type of discovery device (e.g., request for admissions, interrogatories, request for production of documents, etc.) is at issue, to whom the discovery device was directed, the date the discovery device was served, and the date the response was due. In addition, the e-mail should briefly describe the nature of the dispute without making any argument. For example, the e-mail may state that the party requesting the status conference is contending: (a) the other party has failed to respond to the discovery device, or (b) the response to the discovery device is incomplete or insufficient. Similarly, the e-mail may state explain any objection to the requested discovery. The purpose of the e-mail simply is to provide the other counsel/parties and me with a general idea as to the nature of the dispute. Upon receipt of the e-mail, I will determine whether to set a status conference or, instead, require the filing of a formal motion to compel or motion for protective order. THIS PROCEDURE SHOULD NOT BE FOLLOWED WHEN DISCOVERY IS REQUESTED FROM A NON-PARTY.
Checked against the court's document on Oct 3, 2026
Page 1 | Discovery or Disclosure Disputes and/or Sanctions
The judge is willing to use settlement conferences or off-the-record conversations with counsel to help resolve disputes efficiently and fairly.
I am willing to work with counsel and the parties on procedures that will help the parties resolve disputes as efficiently and fairly as possible. This includes conducting settlement conferences or off-the-record conversations with counsel.
Checked against the court's document on Oct 3, 2026
Page 1 | Specific Comments or Advice for Litigants
Telephonic proceedings are encouraged, especially for matters lasting no more than 30 minutes that do not require testimony except to place an agreement on the record.
Telephonic proceedings are encouraged, particularly for matters that do not exceed thirty (30) minutes and do not require testimony (other than testimony to place an agreement on the record).
Checked against the court's document on Oct 3, 2026
Page 1 | Other Pre-trial Practice Guidelines or Comments
Adjournment & Extension Requirements
Parties and counsel are encouraged to make stipulations whenever possible, including stipulated continuance requests.
Parties and counsel are encouraged to make stipulations whenever possible (e.g. stipulated requests for continuances).
Checked against the court's document on Oct 3, 2026
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections
Chambers Communication Rules
The judge typically allocates 30 minutes for specified initial and publication hearings and 15 or 30 minutes for Report & Review Hearings, but invites parties to request more or less time when warranted.
I typically set Preliminary Protective Hearings, Initial Dependency Hearings, Initial Guardianship Hearings, Initial Termination (a.k.a. Severance) Hearings, and Publication Hearings for 30 minutes to ensure sufficient time for all parties/counsel to be heard and for me to address all the statutory and rule requirements. I typically will set Report & Review Hearings for either 15 or 30 minutes, depending on the number of attorneys, guardians ad litem, and placements involved; the complexity of the case; and whether an interpreter is required. If you believe a particular hearing requires more or less time than what I typically allocate, please speak up and let me know.
Not confirmed. Read the court's wording below.
Page 1 | Specific Comments or Advice for Litigants
An attorney who will be late or has difficulty connecting to a virtual hearing should notify court staff by email or phone, or notify another attorney in the case.
If you are an attorney and are going to be late to a hearing (or are having difficulty connecting to a virtual hearing), please let either my staff know (by email or phone) or let another attorney in the case know.
Not confirmed. Read the court's wording below.
Page 1 | Specific Comments or Advice for Litigants
If all exhibits are submitted at least five judicial days before the hearing, counsel may call the division a day or two beforehand to request a faxed exhibit worksheet, subject to staff preparation and availability.
If all exhibits are timely submitted (i.e., at least five judicial days prior to the hearing), counsel may call my division a day or two prior to the hearing and request that an exhibit worksheet be faxed to counsel prior to the hearing. If, at the time of the call, my clerk has prepared the exhibit worksheet and if my staff has time, my staff will then fax counsel a copy of the exhibit worksheet,
Not confirmed. Read the court's wording below.
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections