Court Rules
Judge

Judge Paul R. Wallace

Individual Rules, Standing Orders & Policies

Rules last changed:
Superior Court of Delaware, New Castle County

Limits & Logistics

Document Limits

Letter
1,000 wds
Brief
750 wds
Motion
2,500 wds
Response
2,500 wds
Motion In Limine
2,500 wds
Case Dispositive Motion
6 pgs

Courtesy Copies

Case Dispositive Motion, Response, Reply

  • 1 copy

Complaint, Cross Claim, Counterclaim, Exhibits

  • 1 copy

Courtesy copies

  • Not required

Motion

  • 1 copy

Communication

Phone

Chambers

255-0660
Scheduling
Phone
(302) 655-0586 or (302) 255-0587
Technical Issues
Email
Court-wide

Duty Judge

Emergencies
Filters:AllMandatoryImportantFormattingMemorandaDiscoveryConferencesLettersExhibitsBinders/TabsJury

Page & Word Limits26 rules

Page LimitsCivil cases

Checked and corrected to match the court's document on Oct 1, 2026Mandatory

A discovery motion or other non-dispositive, non-in-limine motion must be a speaking motion limited to 2,500 words, comply with Rule 107(b)’s typeface requirement, and ordinarily be noticed on a Monday 9:00 a.m. routine motions calendar.

As for a discovery motion or any motion other than a dispositive motion or motion in limine, such motion shall be a “speaking motion” limited to 2,500 words that comply with the typeface requirement of Rule 107(b) and shall be noticed for presentation on one of the Court’s routine motions calendars (Mondays at 9:00 a.m.) unless the Court orders a different hearing date.

Motion

2,500 words

New Castle De:fc2f6e52b243892f4971533c · p. 6
|SecVI. MOTIONS PRACTICE — B. DISCOVERY AND OTHER MOTIONS
Page LimitsCivil cases

Checked and corrected to match the court's document on Oct 1, 2026Mandatory

A defendant’s separate joinder or supporting brief must be served within three business days and may not exceed 750 words, excluding appendices.

Subject to the requirements of this Order, any defendant may file a separate joinder or brief ===== PAGE 6 ===== adopting or supporting a motion or opposition of another defendant provided it is served within three (3) business days after service of the motion or opposition and does not exceed 750 words that comply with the typeface requirement of Superior Court Civil Rule 107(b), exclusive of appendices.

Brief

750 words

New Castle De:fc2f6e52b243892f4971533c · p. 6
|SecVI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS
Page LimitsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

Each motion in limine and each response is limited to 2,500 words.

Each motion in limine shall be a “speaking motion” limited to 2,500 words that comply with the typeface requirement of Rule 107(b) and shall be noticed for presentation at the Pre-Trial Conference. The response to a motion in limine is also limited to 2,500 words.

Motion In Limine

2,500 words

Opposition

2,500 words

Page LimitsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

A letter to the court may not exceed 1,000 words.

A letter to the Court shall not exceed 1,000 words.

Letter

1,000 words

Page LimitsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

Responses to motions are limited to 2,500 words, and no reply submission may be filed.

calendar days after the filing of the motion and in no case later than the Wednesday prior to the motion’s hearing—such responses shall also be limited to 2,500 words; and no reply submission shall be filed.

Response

2,500 words

Page LimitsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

Each motion in limine must be a speaking motion limited to 2,500 words, comply with the typeface requirement of Rule 107(b), and be noticed for presentation at the Pre-Trial Conference.

Each motion in limine shall be a “speaking motion” limited to 2,500 words that comply with the typeface requirement of Rule 107(b) and shall be noticed for presentation at the Pre-Trial Conference.

Motion In Limine

2,500 words

Page LimitsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

A response to a motion in limine is limited to 2,500 words.

The response to a motion in limine is also limited to 2,500 words.

Response

2,500 words

Page LimitsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

A letter to the Court may not exceed 1,000 words.

A letter to the Court shall not exceed 1,000 words.

Letter

1,000 words

Page LimitsCivil cases

Checked and corrected to match the court's document on Oct 1, 2026Mandatory

A discovery motion or other non-dispositive, non-in-limine motion must be a speaking motion limited to 2,500 words and comply with Rule 107(b)'s typeface requirement.

As for a discovery motion or any motion other than a dispositive motion or motion in limine, such motion shall be a “speaking motion” limited to 2,500 words that comply with the typeface requirement of Rule 107(b)

Speaking Motion

2,500 words

New Castle De:06555bb71f89ec5b0ac64dc4 · p. 7
|SecB. Discovery and Other Motions
Page LimitsCivil cases

Checked and corrected to match the court's document on Oct 1, 2026Mandatory

A response to a motion in limine is limited to 2,500 words.

The response to a motion in limine is also limited to 2,500 words.

Response

2,500 words

Page LimitsCivil cases

Checked and corrected to match the court's document on Oct 1, 2026Mandatory

Each motion in limine must be a speaking motion limited to 2,500 words and comply with Rule 107(b)'s typeface requirement.

Each motion in limine shall be a “speaking motion” limited to 2,500 words that comply with the typeface requirement of Rule 107(b) and shall be noticed for presentation at the Pre-Trial Conference.

Speaking Motion

2,500 words

Page LimitsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

A letter to the Court may not exceed 1,000 words.

A letter to the Court shall not exceed 1,000 words.

Letter

1,000 words

Page LimitsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

A defendant’s separate joinder or supporting brief must be served within three business days after service of the motion or opposition and may not exceed 750 words, excluding appendices.

Subject to the requirements of this Order, any defendant may file a separate joinder or brief adopting or supporting a motion or opposition of another defendant provided it is served within three (3) business days after service of the motion or opposition and does not exceed 750 words that comply with the typeface requirement of Superior Court Civil Rule 107(b), exclusive of appendices.

Joinder Brief

750 words

New Castle De:f2d6704ae7fe2355a5fa5719 · p. 5
|SecVI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS
Page LimitsCivil cases

Checked and corrected to match the court's document on Oct 1, 2026Mandatory

Each motion in limine and its response may not exceed 2,500 words, and each motion in limine must comply with Rule 107(b).

Each motion in limine shall be a “speaking motion” limited to 2,500 words that comply with the typeface requirement of Rule 107(b) and shall be noticed for presentation at the Pre-Trial Conference. The response to a motion in limine is also limited to 2,500 words.

Motion In Limine

2,500 words

Response Brief

2,500 words

New Castle De:f2d6704ae7fe2355a5fa5719 · p. 6
|SecVI. MOTIONS PRACTICE — C. MOTIONS IN LIMINE
Page LimitsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

A discovery motion or other non-dispositive, non-in-limine motion must be a speaking motion of no more than 2,500 words that complies with Rule 107(b).

As for a discovery motion or any motion other than a dispositive motion or motion in limine, such motion shall be a “speaking motion” limited to 2,500 words that comply with the typeface requirement of Rule 107(b) and shall be noticed for presentation on one of the Court’s routine motions calendars (Mondays at 9:00 a.m.) unless the Court orders a different hearing date.

Speaking Motion

2,500 words

New Castle De:f2d6704ae7fe2355a5fa5719 · p. 6
|SecVI. MOTIONS PRACTICE — B. DISCOVERY AND OTHER MOTIONS
Page LimitsCivil cases

Checked against the court's document on Oct 1, 2026Important

A letter to the Court is limited to 1,000 words.

A letter to the Court shall not exceed 1,000 words.

Letter

1,000 words

Page LimitsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

such motion shall be a “speaking motion” limited to 2,500 words

Summary: Discovery and other non-dispositive, non-in-limine motions must be speaking motions limited to 2,500 words.

Motion

2,500 words

New Castle De:fc2f6e52b243892f4971533c · p. 6
|SecVI. MOTIONS PRACTICE — B. DISCOVERY AND OTHER MOTIONS
Page LimitsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

such responses shall also be limited to 2,500 words

Summary: Responses to discovery and other motions are limited to 2,500 words.

Response

2,500 words

New Castle De:fc2f6e52b243892f4971533c · p. 6
|SecVI. MOTIONS PRACTICE — B. DISCOVERY AND OTHER MOTIONS
Page LimitsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

The motion and the response shall not exceed 6 pages in length and shall have a notice page indicating the date and time of the motion hearing.

Summary: Case-dispositive motions and responses may not exceed 6 pages and must include a notice page showing the motion hearing date and time.

Motion

6 pages

Response

6 pages

New Castle De:e9b6b25f2160aa0737a92e83 · Sep 2025 · p. 5
|SecADDITIONAL INFORMATION AND PROCEDURES — Case Dispositive Motions
Page LimitsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

As for a discovery motion or any motion other than a dispositive motion or motion in limine, such motion shall be a “speaking motion” limited to 2,500 words that comply with the typeface requirement of Rule 107(b) and shall be noticed for presentation on one of the Court’s routine motions calendars (Mondays at 9:00 a.m.) unless the Court orders a different hearing date.

Summary: Discovery motions and other non-dispositive, non-in-limine motions must be speaking motions limited to 2,500 words and complying with Rule 107(b)'s typeface requirement.

Speaking Motion

2,500 words

New Castle De:b5ce745c21f8c0d2f43a88e2 · p. 6
|SecVII. MOTIONS PRACTICE — B. DISCOVERY AND OTHER MOTIONS
Page LimitsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

Subject to the requirements of this Order, any defendant may file a separate joinder or brief adopting or supporting a motion or opposition of another defendant provided it is served within three (3) business days after service of the motion or opposition and does not exceed 750 words that comply with the typeface requirement of Superior Court Civil Rule 107(b), exclusive of appendices.

Summary: A defendant's separate joinder or supporting brief must be served within three business days and may not exceed 750 words, excluding appendices.

Joinder Brief

750 words

New Castle De:b5ce745c21f8c0d2f43a88e2 · p. 6
|SecVII. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS — 2. Opening Brief on a Dispositive Motion
Page LimitsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

Any defendant may file a separate joinder or brief adopting or supporting a motion or opposition of another defendant provided it is served within three (3) business days after service of the motion or opposition and does not exceed 750 words that comply with the typeface requirement of Superior Court Civil Rule 107(b), exclusive of appendices.

Summary: A defendant’s separate joinder or supporting brief may be filed only if it is served within three business days after service of the motion or opposition and contains no more than 750 words, excluding appendices.

Brief

750 words

New Castle De:06555bb71f89ec5b0ac64dc4 · p. 6
|SecVII. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS — 2. Opening Brief on a Dispositive Motion
Page LimitsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

such responses shall also be limited to 2,500 words;

Summary: Responses to discovery and other covered motions are limited to 2,500 words.

Response

2,500 words

New Castle De:06555bb71f89ec5b0ac64dc4 · p. 7
|SecB. Discovery and Other Motions
Page LimitsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

The motion, response and reply shall not exceed 6 pages (unless permission has previously been granted to exceed the page limit) and shall include a notice page indicating the time for argument.

Summary: Each dispositive motion, response, and reply may not exceed six pages unless prior permission is granted.

Case Dispositive Motion

6 pages

Response

6 pages

Reply

6 pages

New Castle De:801f86417aed11e10bda745b · Sep 2026
|SecMotions & Briefing – Dispositive Motions
Page LimitsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

The motion and the response shall not exceed 6 pages in length and shall have a notice page indicating the date and time of the motion hearing.

Summary: A case-dispositive motion and its response may not exceed six pages and must include a notice page stating the hearing date and time.

Motion

6 pages

Response

6 pages

Document Format Requirements21 rules

FormattingCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

Every brief on a dispositive motion must conform to Superior Court Civil Rule 107.

All briefs on dispositive motions shall conform to the requirements of Superior Court Civil Rule 107.

New Castle De:fc2f6e52b243892f4971533c · p. 6
|SecVI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS
FormattingCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

Each motion in limine must comply with the typeface requirements of Rule 107(b).

Each motion in limine shall be a “speaking motion” limited to 2,500 words that comply with the typeface requirement of Rule 107(b) and shall be noticed for presentation at the Pre-Trial Conference.

FormattingCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

All briefs on dispositive motions must comply with Superior Court Civil Rule 107.

All briefs on dispositive motions shall conform to the requirements of Superior Court Civil Rule 107.

New Castle De:06555bb71f89ec5b0ac64dc4 · p. 7
|SecA. Formatting of Dispositive Motion Briefs
FormattingCivil cases

Checked and corrected to match the court's document on Oct 1, 2026Mandatory

Discovery motions and other motions outside the stated exceptions must comply with the typeface requirement of Rule 107(b).

As for a discovery motion or any motion other than a dispositive motion or motion in limine, such motion shall be a “speaking motion” limited to 2,500 words that comply with the typeface requirement of Rule 107(b)

New Castle De:06555bb71f89ec5b0ac64dc4 · p. 7
|SecB. Discovery and Other Motions
FormattingCivil cases

Checked and corrected to match the court's document on Oct 1, 2026Mandatory

Each motion in limine must comply with the typeface requirement of Rule 107(b).

Each motion in limine shall be a “speaking motion” limited to 2,500 words that comply with the typeface requirement of Rule 107(b) and shall be noticed for presentation at the Pre-Trial Conference.

FormattingCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

All motions must comply with Superior Court Civil Rule 78(b).

All motions shall be formatted in the manner set forth in Superior Court Civil Rule 78(b).

New Castle De:801f86417aed11e10bda745b · Sep 2026
|SecMotions & Briefing – Formatting
FormattingCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

Briefs, exhibits, and appendices cannot be fastened with prohibited clips or metal rings and must be stapled or bound.

No briefs, exhibits, or appendices may be clipped or fastened with paper clips, binder clips, or metal three-ring fasteners, but must be stapled or bound.

New Castle De:801f86417aed11e10bda745b · Sep 2026
|SecMotions & Briefing – Formatting
FormattingCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

All briefs must comply with Superior Court Civil Rules 107(b), (d), (e), and (h).

All briefs shall be formatted in the manner set forth in Superior Court Civil Rules 107(b), (d), (e), and (h).

New Castle De:801f86417aed11e10bda745b · Sep 2026
|SecMotions & Briefing – Formatting
FormattingCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

Every page of a Confidential Filing must bear the specified footer prohibiting access except by court order.

which may be accomplished by submitting documents, every page of which shall have a footer stating: THIS DOCUMENT IS A CONFIDENTIAL FILING. ACCESS IS PROHIBITED EXCEPT AS AUTHORIZED BY COURT ORDER.

FormattingCivil cases

Checked and corrected to match the court's document on Oct 1, 2026Mandatory

Any paper copy of a confidential filing submitted to the court must be placed in a sealed envelope or package marked with the litigation title and the specified confidentiality statement.

If a paper copy of that document is to be submitted to the Court for any reason, that document shall be submitted in a sealed envelope or package marked with the title of the Litigation and bearing a statement substantially in the following form: CONFIDENTIAL FILED UNDER SEAL PURSUANT TO A PROTECTIVE ORDER DATED _____, 20__, GOVERNING CONFIDENTIALITY OF DOCUMENTS AND INFORMATION OBTAINED DURING THE COURSE OF THIS LITIGATION. THIS ENVELOPE IS NEITHER TO BE OPENED NOR THE CONTENTS THEREOF DISPLAYED OR REVEALED EXCEPT BY OR TO QUALIFIED PERSONS OR BY COURT ORDER.

FormattingCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

The joinder or supporting brief must comply with the typeface requirement of Superior Court Civil Rule 107(b).

does not exceed 750 words that comply with the typeface requirement of Superior Court Civil Rule 107(b), exclusive of appendices.

New Castle De:f2d6704ae7fe2355a5fa5719 · p. 5
|SecVI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS
FormattingCivil cases

Checked and corrected to match the court's document on Oct 1, 2026Mandatory

Each motion in limine must comply with the typeface requirement of Rule 107(b).

Each motion in limine shall be a “speaking motion” limited to 2,500 words that comply with the typeface requirement of Rule 107(b)

New Castle De:f2d6704ae7fe2355a5fa5719 · p. 6
|SecVI. MOTIONS PRACTICE — C. MOTIONS IN LIMINE
FormattingCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

All briefs on dispositive motions must comply with Superior Court Civil Rule 107.

All briefs on dispositive motions shall conform to the requirements of Superior Court Civil Rule 107.

New Castle De:f2d6704ae7fe2355a5fa5719 · p. 6
|SecVI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS
FormattingCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

Any paper copy submitted to the court must be enclosed in a sealed envelope or package marked with the litigation title and the prescribed under-seal statement.

If a paper copy of that document is to be submitted to the Court for any reason, that document shall be submitted in a sealed envelope or package marked with the title of the Litigation and bearing a statement substantially in the following form: CONFIDENTIAL FILED UNDER SEAL PURSUANT TO A PROTECTIVE ORDER DATED _____, 20__, GOVERNING CONFIDENTIALITY OF DOCUMENTS AND INFORMATION OBTAINED DURING THE COURSE OF THIS LITIGATION.

Required Format

Paper

FormattingCivil cases

Checked against the court's document on Oct 1, 2026Important

All briefs on dispositive motions must comply with Superior Court Civil Rule 107.

All briefs on dispositive motions shall conform to the requirements of Superior Court Civil Rule 107.

New Castle De:b5ce745c21f8c0d2f43a88e2 · p. 6
|SecVII. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS — 5. Formatting of Dispositive Motion Briefs
FormattingCivil cases

Checked against the court's document on Oct 1, 2026Important

Each motion in limine must comply with the typeface requirement of Rule 107(b).

Each motion in limine shall be a “speaking motion” limited to 2,500 words that comply with the typeface requirement of Rule 107(b) and shall be noticed for presentation at the Pre-Trial Conference.

FormattingCivil cases

Checked against the court's document on Oct 1, 2026Important

Proposed jury instructions and voir dire questions should be submitted to chambers in Word format.

Court submissions that are likely to be revised by the Court, i.e., proposed jury instructions and voir dire questions, should be submitted in Word format via digital media or other means arranged with Judge Wallace's chambers staff.

Required Format

DOCX

New Castle De:801f86417aed11e10bda745b · Sep 2026
|SecTrials & Courtroom Proceedings
FormattingCivil cases

Not confirmed. Read the court's wording below.Mandatory?

such motion shall be a “speaking motion” limited to 2,500 words that comply with the typeface requirement of Rule 107(b)

Summary: Discovery and other non-dispositive, non-in-limine motions must be speaking motions limited to 2,500 words and comply with Rule 107(b)’s typeface requirement.

New Castle De:fc2f6e52b243892f4971533c · p. 6
|SecVI. MOTIONS PRACTICE — B. DISCOVERY AND OTHER MOTIONS
FormattingCivil cases

Not confirmed. Read the court's wording below.Mandatory?

does not exceed 750 words that comply with the typeface requirement of Superior Court Civil Rule 107(b), exclusive of appendices.

Summary: A separate joinder or supporting brief is limited to 750 words and must comply with Superior Court Civil Rule 107(b)’s typeface requirement, excluding appendices.

New Castle De:fc2f6e52b243892f4971533c · p. 6
|SecVI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS
FormattingCivil cases

Not confirmed. Read the court's wording below.Mandatory?

Exhibits to briefs, courtesy copies of motions, or letters must all be individually tabbed.

Summary: Brief exhibits, motion courtesy copies, and letters must each be individually tabbed.

New Castle De:801f86417aed11e10bda745b · Sep 2026
|SecMotions & Briefing – Formatting
FormattingCivil cases

Not confirmed. Read the court's wording below.Mandatory?

such motion shall be a “speaking motion” limited to 2,500 words that comply with the typeface requirement of Rule 107(b)

Summary: A discovery motion or other non-dispositive, non-in-limine motion must comply with the Rule 107(b) typeface requirement.

New Castle De:f2d6704ae7fe2355a5fa5719 · p. 6
|SecVI. MOTIONS PRACTICE — B. DISCOVERY AND OTHER MOTIONS

Document Filing Requirements31 rules

Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

Every dispositive motion must be accompanied by an opening brief supporting it.

Each dispositive motion shall be accompanied by an opening brief supporting the motion.

Document Type

Opening Brief

Specific requirements detailed in rule text.
New Castle De:fc2f6e52b243892f4971533c · p. 5
|SecVI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

If the parties cannot agree on every term, they must file one proposed pretrial order identifying all disputed areas.

In the event the parties cannot reach agreement on all the terms of the Pre-Trial Stipulation and Order a single proposed order shall be filed and any areas of disagreement shall be appropriately noted in the one proposed order submitted.

Document Type

Pretrial Order

Content & Formatting
Proposed Order
New Castle De:b5ce745c21f8c0d2f43a88e2 · p. 5
|SecVI. PRETRIAL STIPULATION AND ORDER; TRIAL — B. PRE-TRIAL STIPULATION AND ORDER, SPECIAL INTERROGATORIES, AND PRE-TRIAL CONFERENCE
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

The parties must submit a proposed Pre-Trial Stipulation and Order to the court by the stated deadline.

On or before _____________, the parties shall submit to the Court a proposed Pre-Trial Stipulation and Order.

Document Type

Pretrial Order

Content & Formatting
Proposed Order
New Castle De:b5ce745c21f8c0d2f43a88e2 · p. 5
|SecVI. PRETRIAL STIPULATION AND ORDER; TRIAL — B. PRE-TRIAL STIPULATION AND ORDER, SPECIAL INTERROGATORIES, AND PRE-TRIAL CONFERENCE
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

Every dispositive motion must include an opening brief supporting it.

Each dispositive motion shall be accompanied by an opening brief supporting the motion.

Document Type

Dispositive Motion

Content & Formatting
Legal Argument
New Castle De:b5ce745c21f8c0d2f43a88e2 · p. 6
|SecVII. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS — 2. Opening Brief on a Dispositive Motion
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

Each dispositive motion must be accompanied by an opening brief supporting the motion.

Each dispositive motion shall be accompanied by an opening brief supporting the motion.

Document Type

Dispositive Motion

Specific requirements detailed in rule text.
New Castle De:06555bb71f89ec5b0ac64dc4 · p. 6
|SecVII. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS — 2. Opening Brief on a Dispositive Motion
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

Only counsel may write directly to Judge Wallace, and counsel’s correspondence must be signed by an attorney from the attorney of record’s law firm.

Only counsel, not legal staff, may write directly to Judge Wallace. All correspondence must be signed by an attorney in the law firm of the attorney of record.

Document Type

Correspondence

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

A nonmotion letter requesting court action must state every other party’s position or explain that the party could not be reached.

Any letter to the Court requesting Court action of some kind (in instances where a motion is otherwise not appropriate) must state the position of each other party or otherwise represent that opposing counsel or the self-represented party could not be reached.

Document Type

Letter Requesting Court Action

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

Every Confidential Filing must include a cover page identifying the litigation and filing and displaying the specified unauthorized-access warning and contact information.

In addition, every Confidential Filing must be submitted with a cover page bearing the title of the Litigation, the title of the Confidential Filing, and stating: YOU ARE IN POSSESSION OF A CONFIDENTIAL FILING FROM THE SUPERIOR COURT OF THE STATE OF DELAWARE. If you are not authorized by Court order to view or retrieve this document, read no further than this page. You should contact the following person: [Filing Attorney or Party Name] [Filing Attorney Law Firm] [Filing Attorney or Party Address]

Document Type

Confidential Filing

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

Every dispositive motion must be accompanied by an opening brief supporting it.

Each dispositive motion shall be accompanied by an opening brief supporting the motion.

Document Type

Opening Brief

Specific requirements detailed in rule text.
New Castle De:f2d6704ae7fe2355a5fa5719 · p. 5
|SecVI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

If the parties cannot agree on all terms of the pretrial stipulation and order, they must file one proposed order noting their disagreements.

In the event the parties cannot reach agreement on all the terms of the Pre-Trial Stipulation and Order a single proposed order shall be filed and any areas of disagreement shall be appropriately noted in the one proposed order submitted.

Document Type

Pretrial Order

Content & Formatting
Proposed Order
New Castle De:f2d6704ae7fe2355a5fa5719 · p. 5
|SecV. PRETRIAL STIPULATION AND ORDER; TRIAL
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

When a public version will be filed, the Confidential Filing's cover page must state the public-version filing deadline.

If a public version of the Confidential Filing will be filed in accordance with Superior Court Civil Rule 5(g), then the cover page shall also state: A public version of this document will be filed on or before [DATE]

Document Type

Confidential Filing

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Mandatory

The motion seeking continued confidential treatment certifies that its signer personally reviewed the confidential filing and that continued treatment is appropriate.

The filing of the motion constitutes a certification that the signer of the motion personally reviewed the Confidential Filing and that continued Confidential Treatment is appropriate.

Document Type

Motion

Content & Formatting
Local Rule Certificate
New Castle De:c00b83ec0afd56c7cf04b23b · p. 15
|SecConfidential and Highly Confidential Designations
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Important

Motions in limine must include all supporting authority.

Motions in Limine must include all supporting authority with the motion.

Document Type

Motion In Limine

Specific requirements detailed in rule text.
New Castle De:e9b6b25f2160aa0737a92e83 · Sep 2025 · p. 2
|SecTRIAL SCHEDULING ORDER (c)(2) Filing of Motions in Limine
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Important

The Interim Status Report must describe the matters in issue, discovery progress, and mandatory ADR results, must not include offers or demands, and should reflect input from both parties.

The interim report will advise the Court on the nature of the matters in issue, the progress of discovery to date, and the results of mandatory alternate dispute resolution used to date to resolve this matter. Do not include information on offers or demands. This document should reflect input from both parties.

Document Type

Interim Status Report

Specific requirements detailed in rule text.
New Castle De:e9b6b25f2160aa0737a92e83 · Sep 2025 · p. 5
|SecADDITIONAL INFORMATION AND PROCEDURES — Interim Status Report
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Important

In a complex case, the court may require proposed jury instructions to be filed with the pretrial stipulation for discussion at the pretrial conference.

In complex cases, the Court may require that instructions be filed with the Pretrial Stipulation so they may be discussed at the Pretrial Conference.

Document Type

Jury Instructions

Specific requirements detailed in rule text.
New Castle De:801f86417aed11e10bda745b · Sep 2026
|SecPretrial/Evidentiary Matters – Pretrial Conferences
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Important

An unopposed motion must state in the motion that it is unopposed, eliminating the need for separate notice.

An unopposed motion should represent that non-opposition in the motion itself, in which event no further notification is necessary.

Document Type

Routine Motion

Specific requirements detailed in rule text.
New Castle De:801f86417aed11e10bda745b · Sep 2026
|SecMotions & Briefing – Routine Motions
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Important

When the opponent’s position is unknown, the motion must include a clear averment describing counsel’s prefiling good-faith effort to obtain it.

If the position of the opposing party is unknown at the time of filing, filing counsel should include a clear averment explaining the good faith effort engaged to obtain the opponent's position prior to filing.

Document Type

Routine Motion

Specific requirements detailed in rule text.
New Castle De:801f86417aed11e10bda745b · Sep 2026
|SecMotions & Briefing – Routine Motions
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Important

A response to a motion must substantively address each argument rather than use complaint-answer language in matching numbered paragraphs.

When responding to a motion, avoid using terms and phrases typically used in answers to complaints (Admitted, Denied as Stated, etc.) in numbered paragraphs corresponding to the numbered paragraphs in the motion. Instead each argument in the motion should be addressed substantively.

Document Type

Motion Response

Specific requirements detailed in rule text.
New Castle De:801f86417aed11e10bda745b · Sep 2026
|SecMotions & Briefing – Formatting
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Important

A motion or stipulation extending discovery or expert deadlines without affecting other scheduled dates must state that limitation.

If a party seeks to extend discovery or expert deadlines, without affecting remaining scheduled dates, the motion or stipulation should so state.

Document Type

Motion Or Stipulation

Specific requirements detailed in rule text.
New Castle De:801f86417aed11e10bda745b · Sep 2026
|SecInitial Stages – Trial Scheduling Orders
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Important

Counsel should use Superior Court Civil Form 46 for the pretrial stipulation.

Counsel is expected to utilize Superior Court Civil Form 46 for Pretrial Stipulations.

Document Type

Pretrial Stipulation

Specific requirements detailed in rule text.
New Castle De:801f86417aed11e10bda745b · Sep 2026
|SecPretrial/Evidentiary Matters – Pretrial Stipulations
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Important

Every email must identify the subject case and civil action number and be addressed to Judge Wallace’s staff.

All emails should include the name of the subject case, the civil action number, and should be addressed to Judge Wallace's staff.

Document Type

Email

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Important

Depositions and other pretrial testimony may be designated by counsel’s statement on the record or by written notice to all parties within five business days after receipt of the rough or final transcript, whichever is received first.

B. In the case of depositions or other pretrial testimony: (i) by a statement on the record, by counsel, at the time of such disclosure or before the conclusion of the deposition or testimony; or (ii) by written notice, sent to all Parties within five (5) business days of receipt of the rough or final transcript (whichever is received first) designating the entire transcript or portions thereof; provided that only those portions of the transcript designated as Confidential or Highly Confidential Discovery Material shall be deemed

Document Type

Deposition Or Pretrial Testimony

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Checked against the court's document on Oct 1, 2026Important

Documents and other non-testimonial discovery materials must be designated by the legend “Confidential” or “Highly Confidential” on each page, except that a permanently bound multi-page document may be marked only on its first page; native electronic information must be designated in the file or directory name or on the media.

A. In the case of documents or other materials (apart from depositions or other pre-trial testimony): (i) by affixing the legend “Confidential” or “Highly Confidential” to each page containing any Confidential or Highly Confidential Discovery Material, except that in the case of multi-page documents bound together by staple or other permanent binding, the word “Confidential” or “Highly Confidential” need only be stamped on the first page of the document in order for the entire document to be treated in accordance with its designation; or (ii) in the case of electronically stored information produced in native format, by including “Confidential” or “Highly Confidential” in the file or directory name, or by affixing the legend “Confidential” or “Highly Confidential” to the media containing the Discovery Material (e.g., CD-ROM, DVD, flash drive) as applicable.

Document Type

Discovery Material

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

The motion and the response shall not exceed 6 pages in length and shall have a notice page indicating the date and time of the motion hearing.

Summary: A case-dispositive motion must include a notice page indicating the date and time of the motion hearing.

Document Type

Motion

Specific requirements detailed in rule text.
New Castle De:e9b6b25f2160aa0737a92e83 · Sep 2025 · p. 5
|SecADDITIONAL INFORMATION AND PROCEDURES — Case Dispositive Motions

Filing & Service rules

Electronic Filing Rules

The original dispositive motion, response, and reply should be electronically filed with one courtesy copy promptly delivered to chambers.

The original motion, response, and reply should be e-filed with 1 courtesy copy promptly delivered to chambers.

Not confirmed. Read the court's wording below. · Civil cases

Page 1 | Motions & Briefing – Dispositive Motions

A substantive email must be docketed by the sender and may be sent only with Judge Wallace’s approval or in exigent circumstances.

Substantive emails must be docketed by the sending party and may be sent only when (a) Judge Wallace has approved such email filing in the subject case or (b) exigent circumstances exist.

Not confirmed. Read the court's wording below. · Civil cases

Page 1 | Communications

A letter to Judge Wallace must be electronically docketed, need not be delivered as a chambers courtesy copy, and should be emailed to specified chambers staff.

A letter to Judge Wallace need only be docketed electronically in the subject case. No courtesy copy need be delivered to Judge Wallace's chambers. Instead, an electronic copy, as docketed, should be transmitted via email to Judge Wallace's Administrative Specialist, Civil Case Manager and Law Clerk.

Not confirmed. Read the court's wording below. · Civil cases

Page 1 | Communications

Administrative emails must not be docketed.

Administrative emails are not docketed.

Not confirmed. Read the court's wording below. · Civil cases

Page 1 | Communications

Filing Timing and Cure Windows

Unless an alternative schedule applies, an answering brief must be filed and served by the later of 30 days after motion service or 30 days after a separate joinder or supporting brief is filed.

Unless an alternative schedule has been agreed to by the parties or ordered by the Court, such answering brief shall be filed and served the later of thirty (30) days after any service of the motion, or thirty (30) days after any defendant files a separate joinder or brief adopting or supporting a motion or opposition of another defendant.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 6 | VI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS

Absent leave of the Court, discovery and other motions must be filed at least 15 calendar days before the noticed hearing date.

Absent leave of the Court, all discovery and other motions shall be filed no less than fifteen (15) calendar days prior to the noticed hearing date

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 6 | VI. MOTIONS PRACTICE — B. DISCOVERY AND OTHER MOTIONS

Responses must be filed no later than seven (7) calendar days after the motion is filed.

responses shall be filed no later than seven (7) calendar days after the filing of the motion

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 6 | VI. MOTIONS PRACTICE — B. DISCOVERY AND OTHER MOTIONS

Unless a specific order provides otherwise, a response to a motion in limine with all supporting authority is due no later than 7 business days after filing.

Unless a specific order entered in this case provides otherwise, a Response (with all supporting authority) is due no later than 7 business days after the filing of the motion in limine.

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 2 | TRIAL SCHEDULING ORDER (c)(2) Filing of Motions in Limine

A response to a dispositive motion is due no later than 30 days after the motion is filed, with briefing and further proceedings governed by Section VII-A.

Any response to a dispositive motion is due no later than thirty (30) days after the filing of the dispositive motion and briefing and further proceedings on dispositive motions are to proceed in accord with Section VII-A of this Order.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 4 | V. DISPOSITIVE MOTIONS DUE

Unless the parties agree to or the Court orders a different schedule, the answering brief must be filed and served by the later of thirty (30) days after service of the motion or thirty (30) days after a defendant files a separate joinder or supporting brief.

Unless an alternative schedule has been agreed to by the parties or ordered by the Court, such answering brief shall be filed and served the later of thirty (30) days after any service of the motion, or thirty (30) days after any defendant files a separate joinder or brief adopting or supporting a motion or opposition of another defendant.

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 6 | VII. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS — 3. Answering Brief on a Dispositive Motion

Absent court leave, discovery and other motions must be filed at least fifteen calendar days before the noticed hearing date; the text provided does not state the unit for the response deadline.

Absent leave of the Court, all discovery and other motions shall be filed no less than fifteen (15) calendar days prior to the noticed hearing date; responses shall be filed no later than seven (7)

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 6 | VII. MOTIONS PRACTICE — B. DISCOVERY AND OTHER MOTIONS

A defendant’s separate joinder or brief supporting another defendant’s motion or opposition must be served within three business days after service of the motion or opposition.

any defendant may file a separate joinder or brief adopting or supporting a motion or opposition of another defendant provided it is served within three (3) business days after service of the motion or opposition

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 6 | VII. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS — 2. Opening Brief on a Dispositive Motion

Unless an alternative schedule is agreed to or ordered, an answering brief must be filed and served at the later of 30 days after service of the motion or 30 days after a defendant files a separate joinder or supporting brief.

Unless an alternative schedule has been agreed to by the parties or ordered by the Court, such answering brief shall be filed and served the later of thirty (30) days after any service of the motion, or thirty (30) days after any defendant files a separate joinder or brief adopting or supporting a motion or opposition of another defendant.

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 6 | VII. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS — 3. Answering Brief on a Dispositive Motion

Without leave of court, discovery and other covered motions must be filed at least fifteen calendar days before the noticed hearing date.

Absent leave of the Court, all discovery and other motions shall be filed no less than fifteen (15) calendar days prior to the noticed hearing date;

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 7 | B. Discovery and Other Motions

A dispositive-motion reply may be filed fourteen days after responses are received and must be filed at least fourteen days before the hearing.

A reply brief on a dispositive motion may be filed fourteen (14) days after responses are received, but no later than fourteen (14) days before any hearing on the motion.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 7 | A. Reply Brief on a Dispositive Motion

Proposed jury instructions ordinarily must be filed on the Wednesday before trial.

Ordinarily, proposed jury instructions must be filed the Wednesday before the trial date.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 1 | Pretrial/Evidentiary Matters – Pretrial Conferences

A dispositive-motion response with all supporting authority is due no later than 14 days after filing, excluding weekends and holidays.

a response (with all supporting authority) to any dispositive motion is due no later than 14 days (excluding weekends and holidays) after the filing of the motion.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 1 | Motions & Briefing – Dispositive Motions

A reserved dispositive-motion oral-argument time may be canceled if the motion is not filed within four days after obtaining the time.

If a party then does not file a dispositive motion within 4 days after obtaining the date and time for oral argument, the scheduled time may be canceled.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 1 | Motions & Briefing – Dispositive Motions

A routine-motion response is due within seven calendar days after filing and, in all cases, no later than the Wednesday before the hearing.

(2) responses are due no later than 7 calendar days after the filing of the motion and in no case later than the Wednesday prior to the motion's hearing.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 1 | Motions & Briefing – Routine Motions

After postponement, plaintiff’s counsel must submit a status report within 60 days of the postponed conference date.

Plaintiff's counsel must then submit a status report within sixty days of the date of the postponed conference.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 1 | Initial Stages – Initial Scheduling Conferences

A routine motion must be filed at least 15 calendar days before its noticed hearing date.

The provisions of Paragraph IV of the NCC Plan and Superior Court Civil Rule 107(b) to the contrary notwithstanding, in Judge Wallace's cases: (1) routine Motions must be filed no less than 15 calendar days prior to the noticed date

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 1 | Motions & Briefing – Routine Motions

Unless a case-specific order states otherwise, a response with supporting authority to a motion in limine is due within seven business days after filing, and an untimely response may result in the motion being deemed unopposed.

Unless a specific order entered in this case provides otherwise, a Response (with all supporting authority) is due no later than 7 business days after the filing of the motion in limine. Failure to file a timely Response may result in the Court deeming the motion as unopposed.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 2 | Trial Scheduling Order — Filing of Motions in Limine

Unless the parties agree or the court orders otherwise, an answering brief must be filed and served at the later of 30 days after service of the motion or 30 days after a defendant’s separate joinder or supporting brief is filed.

Unless an alternative schedule has been agreed to by the parties or ordered by the Court, such answering brief shall be filed and served the later of thirty (30) days after any service of the motion, or thirty (30) days after any defendant files a ===== PAGE 6 ===== separate joinder or brief adopting or supporting a motion or opposition of another defendant.

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 5 | VI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS

A dispositive-motion reply brief may be filed 14 days after responses are received and must be filed no later than seven days before the hearing.

A reply brief on a dispositive motion may be filed fourteen (14) days after responses are received, but no later than seven (7) days before any hearing on the motion.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 6 | VI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS

Without leave of court, discovery and other covered motions must be filed at least 15 calendar days before the noticed hearing date.

Absent leave of the Court, all discovery and other motions shall be filed no less than fifteen (15) calendar days prior to the noticed hearing date

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 6 | VI. MOTIONS PRACTICE — B. DISCOVERY AND OTHER MOTIONS

A response to a dispositive motion is due no later than 30 days after the motion is filed, with briefing and further proceedings governed by Section VI-A.

Any response to a dispositive motion is due no later than thirty (30) days after the filing of the dispositive motion and briefing and further proceedings on dispositive motions are to proceed in accord with Section VI-A of this Order.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 4 | IV. DISPOSITIVE MOTIONS DUE

A reply brief on a dispositive motion may be filed fourteen days after responses are received.

A reply brief on a dispositive motion may be filed fourteen (14) days after responses are received

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 6 | VI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS

If a reply brief is filed on a dispositive motion, it may be filed 14 days after responses are received but no later than seven days before the hearing.

A reply brief on a dispositive motion may be filed fourteen (14) days after responses are received, but no later than seven (7) days before any hearing on the motion.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 6 | VI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS

The order establishes separate filing deadlines for motions in limine and their responses, but the dates are left blank.

All motions in limine shall be filed no later than _____________ and all responses to those motions shall be filed no later than _____________.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 7 | C. MOTIONS IN LIMINE

A separate joinder or supporting brief must be served within three business days after service of the motion or opposition.

provided it is served within three (3) business days after service of the motion or opposition

Not confirmed. Read the court's wording below. · Civil cases

Page 6 | VI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS

A reply brief must be filed no later than seven days before the motion hearing.

but no later than seven (7) days before any hearing on the motion.

Not confirmed. Read the court's wording below. · Civil cases

Page 6 | VI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS

Responses to discovery and other motions must also be filed no later than the Wednesday before the motion hearing.

and in no case later than the Wednesday prior to the motion’s hearing

Not confirmed. Read the court's wording below. · Civil cases

Page 6 | VI. MOTIONS PRACTICE — B. DISCOVERY AND OTHER MOTIONS

Responses to dispositive motions are due 14 business days after filing.

later than . Responses are due 14 business days after filing.

Not confirmed. Read the court's wording below. · Civil cases

Page 2 | TRIAL SCHEDULING ORDER (c)(1) Filing of Dispositive Motions

Routine civil motions must be filed at least 15 calendar days before the noticed presentation date, with one courtesy copy including exhibits delivered to Judge Wallace’s chambers.

Motions must be filed no less than fifteen 15 calendar days prior to the noticed presentation date with one courtesy copy (with exhibits) delivered to Judge Wallace in chambers.

Not confirmed. Read the court's wording below. · Civil cases

Page 5 | ADDITIONAL INFORMATION AND PROCEDURES — Routine Civil Motions

The response to a case-dispositive motion is due no later than 14 days after the motion is filed, excluding weekends and holidays.

The response is due no later than fourteen 14 days (excluding weekends and holidays) after the filing of the motion.

Not confirmed. Read the court's wording below. · Civil cases

Page 5 | ADDITIONAL INFORMATION AND PROCEDURES — Case Dispositive Motions

Routine-motion responses are due within 7 calendar days after filing and no later than the Wednesday before the hearing, with one courtesy copy including exhibits delivered to chambers.

Responses are due no later than 7 calendar days after the filing of the motion and in no case later than the Wednesday prior to the motion’s hearing, with one courtesy copy of a response (with exhibits) delivered to Judge Wallace in chambers.

Not confirmed. Read the court's wording below. · Civil cases

Page 5 | ADDITIONAL INFORMATION AND PROCEDURES — Routine Civil Motions

Dispositive motions may be filed by the case-specific deadline stated in the scheduling order.

Dispositive motions may be filed on or before _____________.

Not confirmed. Read the court's wording below. · Civil cases

Page 4 | V. DISPOSITIVE MOTIONS DUE

A dispositive-motion reply may be filed fourteen days after responses are received.

A reply brief on a dispositive motion may be filed fourteen (14) days after responses are received, but no later than fourteen (14) days before any hearing on the motion.

Not confirmed. Read the court's wording below. · Civil cases

Page 6 | VII. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS — 4. Reply Brief on a Dispositive Motion

Responses to discovery and other covered motions are due within seven calendar days after filing and no later than the Wednesday before the hearing.

responses shall be filed no later than seven (7) calendar days after the filing of the motion and in no case later than the Wednesday prior to the motion’s hearing—such responses shall also be limited to 2,500 words;

Not confirmed. Read the court's wording below. · Civil cases

Page 7 | B. Discovery and Other Motions

No reply submission may be filed in response to a discovery motion or other covered motion.

and no reply submission shall be filed.

Not confirmed. Read the court's wording below. · Civil cases

Page 7 | B. Discovery and Other Motions

Responses to dispositive motions are due within 14 business days after filing.

Responses are due 14 business days after filing.

Not confirmed. Read the court's wording below. · Civil cases

Page 1 | Trial Scheduling Order — Filing of Dispositive Motions

The response to a case-dispositive motion is due no later than fourteen days after filing, excluding weekends and holidays.

The response is due no later than fourteen 14 days (excluding weekends and holidays) after the filing of the motion.

Not confirmed. Read the court's wording below. · Civil cases

Page 4 | Case Dispositive Motions

A response to a routine motion is due no later than seven calendar days after filing and in all events no later than the Wednesday before the hearing; one courtesy copy including exhibits must be delivered to Judge Wallace in chambers.

Responses are due no later than 7 calendar days after the filing of the motion and in no case later than the Wednesday prior to the motion’s hearing, with one courtesy copy of a response (with exhibits) delivered to Judge Wallace in chambers.

Not confirmed. Read the court's wording below. · Civil cases

Page 4 | Routine Civil Motions

Routine motions must be filed at least fifteen calendar days before the noticed presentation date, with one courtesy copy including exhibits delivered to Judge Wallace in chambers.

Motions must be filed no less than fifteen 15 calendar days prior to the noticed presentation date with one courtesy copy (with exhibits) delivered to Judge Wallace in chambers.

Not confirmed. Read the court's wording below. · Civil cases

Page 4 | Routine Civil Motions

Responses to discovery and other covered motions are due no later than seven calendar days after filing and in no event later than the Wednesday before the hearing; each response is limited to 2,500 words, and no reply may be filed.

responses shall be filed no later than seven (7) calendar days after the filing of the motion and in no case later than the Wednesday prior to the motion’s hearing—such responses shall also be limited to 2,500 words; and no reply submission shall be filed.

Not confirmed. Read the court's wording below. · Civil cases

Page 6 | VI. MOTIONS PRACTICE — B. DISCOVERY AND OTHER MOTIONS

A person challenging confidential treatment has seven days to file an opposition.

The person challenging Confidential Treatment shall have seven (7)

Not confirmed. Read the court's wording below. · Civil cases

Page 15 | Confidential and Highly Confidential Designations

Dispositive motions may be filed on or before the date stated in the scheduling order.

Dispositive motions may be filed on or before _____________.

Not confirmed. Read the court's wording below. · Civil cases

Page 4 | IV. DISPOSITIVE MOTIONS DUE

The interim status report is due no more than 14 days after mandatory ADR is conducted.

An Interim Status Report will be due no more than 14 days after ADR has been conducted.

Not confirmed. Read the court's wording below. · Civil cases

Page 2 | TRIAL SCHEDULING ORDER (e) Interim Status Report

If no timely response is filed, the Court may deem the routine motion unopposed, grant it before the hearing, and notify the parties.

If no response is timely filed, the Court may deem the motion unopposed, grant the motion before the hearing, and will so notify the parties.

Not confirmed. Read the court's wording below. · Civil cases

Page 5 | ADDITIONAL INFORMATION AND PROCEDURES — Routine Civil Motions

Motions to join parties or amend or supplement pleadings must be filed by the specified deadline.

Motions seeking to join other parties and motions to amend or supplement the pleadings must be filed and served on or before _____________.

Not confirmed. Read the court's wording below. · Civil cases

Page 2 | I. GENERAL — D. ADDITION OF PARTIES; AMENDMENTS OR SUPPLEMENTS OF PLEADINGS

A joint application to amend the initial Trial Scheduling Order must be made within seven days after the order is first docketed.

First amendment of this initial Trial Scheduling Order will be liberally granted upon the parties’ joint application made within 7 days of its first docketing.

Not confirmed. Read the court's wording below. · Civil cases

Page 3 | Trial Scheduling Order

Judge Wallace hears routine civil motions on Mondays at 9:00 a.m.

Judge Wallace’s routine civil motions are on Mondays at 9:00 a.m.

Not confirmed. Read the court's wording below. · Civil cases

Page 5 | ADDITIONAL INFORMATION AND PROCEDURES — Routine Civil Motions

Judge Wallace’s routine civil motions are heard on Mondays at 9:00 a.m.

Judge Wallace’s routine civil motions are on Mondays at 9:00 a.m.

Not confirmed. Read the court's wording below. · Civil cases

Page 4 | Routine Civil Motions

Service and Proof of Service Rules

When a new party is added, the party adding it must serve the new party with the Case Management Order at the same time it serves the pleading joining the new party.

Upon the addition of any party to the Action, the party adding the new party to the Action shall serve a copy of this Case Management Order at the same time that it serves a copy of the pleading joining such new party.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 1 | I. GENERAL

Documents initiating specified discovery requests and responses to them must be served electronically through LEXIS/NEXIS, excluding the actual production of documents.

except that documents initiating discovery requests (interrogatories, requests for production of documents, and requests for admission) and responses to such discovery requests (excluding the actual production of documents) shall be served electronically through LEXIS/NEXIS.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 2 | II. LEXIS/NEXIS E-FILING PROCEDURES

Discovery requests and responses, but not the actual production of documents, must be served electronically through LEXIS/NEXIS.

except that documents initiating discovery requests (interrogatories, requests for production of documents, and requests for admission) and responses to such discovery requests (excluding the actual production of documents) shall be served electronically through LEXIS/NEXIS.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 2 | II. LEXIS/NEXIS E-FILING PROCEDURES

A separate joinder or supporting brief must be served within three business days after service of the underlying motion or opposition.

Subject to the requirements of this Order, any defendant may file a separate joinder or brief adopting or supporting a motion or opposition of another defendant provided it is served within three (3) business days after service of the motion or opposition and does not exceed 750 words that comply with the typeface requirement of Superior Court Civil Rule 107(b), exclusive of appendices.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 6 | VII. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS — 2. Opening Brief on a Dispositive Motion

A party adding a new party must serve the new party with the Case Management Order when it serves the pleading joining that party.

Upon the addition of any party to the Action, the party adding the new party to the Action shall serve a copy of this Case Management Order at the same time that it serves a copy of the pleading joining such new party.

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 1 | I. GENERAL — B. SERVICE OF CASE MANAGEMENT ORDER ON NEW PARTIES

Documents initiating discovery requests and their responses, excluding actual document production, must be served electronically through LEXIS/NEXIS.

The filing and service of documents shall be in accordance with Rule 79.1 of the Superior Court Civil Rules and the Administrative Directive of the President Judge of the Superior Court of the State of Delaware, No. 2007-6, E-File Administrative Procedures, dated December 13, 2007, published by the Prothonotary, except that documents initiating discovery requests (interrogatories, requests for production of documents, and requests for admission) and responses to such discovery requests (excluding the actual production of documents) shall be served electronically through LEXIS/NEXIS.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 2 | II. LEXIS/NEXIS E-FILING PROCEDURES

A party receiving a court notice concerning release of sealed documents containing another producing party's confidential discovery material must deliver the notice to that producing party's counsel by hand, email, or facsimile within three business days after receipt if the court did not send it directly.

When any Party receives a notice from the Court pursuant to Rule 5(g)(5) concerning the release of sealed documents that were filed with the Superior Court by such Party but contain Discovery Material designated as Confidential Discovery Material by another Producing Party, the Party receiving the notice shall deliver a copy of such notice (by hand, email, or facsimile transmission) to counsel for the Producing Party (or Producing Parties) within three (3) business days of the receipt of such notice, if such notice is not otherwise sent to such Producing Party by the Superior Court,

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 12 | Paragraph 13

Filing and service generally must comply with Superior Court Civil Rule 79.1 and the referenced E-File Administrative Procedures, but discovery-request documents and responses, excluding the actual document production, must be served electronically through LEXIS/NEXIS.

The filing and service of documents shall be in accordance with Rule 79.1 of the Superior Court Civil Rules and the Administrative Directive of the President Judge of the Superior Court of the State of Delaware, No. 2003-8, E-File Administrative Procedures, dated August 12, 2003, published by the Prothonotary, except that documents initiating discovery requests (interrogatories, requests for production of documents, and requests for admission) and responses to such discovery requests (excluding the actual production of documents) shall be served electronically through LEXIS/NEXIS.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 2 | II. LEXIS/NEXIS E-FILING PROCEDURES

A party issuing a subpoena to a nonparty must enclose the stipulation and notify the nonparty that its protections are available.

Any Party issuing a subpoena to a non-Party shall enclose a copy of this Stipulation and notify the non-Party that the protections of this Stipulation are available to such non-Party.

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 12

Requests for production must be served by the first specified deadline, and the requested documents must be produced by the second specified deadline.

Requests f or Production of documents shall be served on or before _____________, with all documents to be produced on or before _____________.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 2 | III. DISCOVERY SCHEDULE — A. DOCUMENT PRODUCTION

A party receiving notice must deliver a copy to the producing party's counsel by hand, email, or facsimile within three business days after receipt, unless the Prothonotary already sent the notice to the producing party.

the Party receiving the notice shall deliver a copy of such notice (by hand, email, or facsimile transmission) to counsel for the Producing Party (or Producing Parties) within three (3) business days of the receipt of such notice, if such notice is not otherwise sent to such Producing Party by the Prothonotary

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 15 | Confidential and Highly Confidential Designations

Process may be served by certified mail, return receipt requested, addressed to a party or its registered agent, or by any other method authorized by law.

Each of the Parties further consents and agrees that process in any suit, action, or proceeding may be served on such Party by certified mail, return receipt requested, addressed to such Party or such Party’s registered agent in the state of its incorporation or organization, or in any other manner provided by law.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 23

A party may be served process by certified mail, return receipt requested, addressed to the party or its registered agent in its state of incorporation or organization.

Each of the Parties further consents and agrees that process in any suit, action, or proceeding may be served on such Party by certified mail, return receipt requested, addressed to such Party or such Party’s registered agent in the state of its incorporation or organization, or in any other manner provided by law.

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 26 | 31

A party adding a new party must serve the new party with the Case Management Order at the same time it serves the pleading joining that party.

Upon the addition of any party to the Action, the party adding the new party to the Action shall serve a copy of this Case Management Order at the same time that it serves a copy of the pleading joining such new party.

Not confirmed. Read the court's wording below. · Civil cases

Page 1 | I. GENERAL, B. SERVICE OF CASE MANAGEMENT ORDER ON NEW PARTIES

When a new party is added, the party adding it must serve a copy of the Case Management Order simultaneously with the pleading joining the new party.

Upon the addition of any party to the Action, the party adding the new party to the Action shall serve a copy of this Case Management Order at the same time that it serves a copy of the pleading joining such new party.

Not confirmed. Read the court's wording below. · Civil cases

Page 1 | I. GENERAL

A separate joinder or supporting brief must be served within three business days after service of the motion or opposition.

Subject to the requirements of this Order, any defendant may file a separate joinder or brief adopting or supporting a motion or opposition of another defendant provided it is served within three (3) business days after service of the motion or opposition

Not confirmed. Read the court's wording below. · Civil cases

Page 5 | VI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS

The parties may serve third-party subpoenas only until the specified deadline.

The parties are permitted to serve third-party subpoenas until _____________.

We could not find this wording in the court's document. Open the source before relying on it. · Civil cases

Page 2 | III. DISCOVERY SCHEDULE — A. DOCUMENT PRODUCTION

Motions to join parties or amend or supplement pleadings must be served by the specified deadline.

Motions seeking to join other parties and motions to amend or supplement the pleadings must be filed and served on or before _____________.

Not confirmed. Read the court's wording below. · Civil cases

Page 2 | I. GENERAL — D. ADDITION OF PARTIES; AMENDMENTS OR SUPPLEMENTS OF PLEADINGS

The notice-delivery requirement may be waived only if the Producing Party gives prior written consent.

The provisions of this Paragraph may be waived only with the prior written consent of the Producing Party.

Not confirmed. Read the court's wording below. · Civil cases

Page 15 | Confidential and Highly Confidential Designations

Filing Fees and Waivers

Plaintiff’s counsel must file the Interim Status Report, provide a copy to the assigned judge, and submit a $150.00 trial fee check payable to the Prothonotary.

The Interim Status Report is to be filed by Plaintiff(s)’s Counsel with a copy to the assigned Judge, together with a check for the $150.00 trial fee made payable to the “Prothonotary.”

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 5 | ADDITIONAL INFORMATION AND PROCEDURES — Interim Status Report

The trial fee must be paid by the date of the pretrial conference.

The trial fee shall be paid no later than the date of the pretrial conference.

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Page 3 | Trial Scheduling Order

Failure to pay the trial fee within two business days after the pretrial conference removes the case from the trial calendar, and a new trial date is scheduled only upon payment.

If the trial fee is not paid within two business days of the pretrial conference, the case will be removed from the Court’s trial calendar. A new trial date will then be scheduled upon payment of the trial fee.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 3 | Trial Scheduling Order

Plaintiff’s counsel must file the Interim Status Report with a copy to the assigned judge and a $150 trial-fee check payable to the Prothonotary.

The Interim Status Report is to be filed by Plaintiff(s)’s Counsel with a copy to the assigned Judge, together with a check for the $150.00 trial fee made payable to the “Prothonotary.”

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 4 | Interim Status Report

The trial fee must be paid no later than the pretrial conference; if unpaid within two business days after the conference, the case will be removed from the trial calendar and a new trial date will be scheduled upon payment.

(g) Trial Fee. The trial fee shall be paid no later than the date of the pretrial conference. If the trial fee is not paid within two business days of the pretrial conference, the case will be removed from the Court’s trial calendar. A new trial date will then be scheduled upon payment of the trial fee.

Not confirmed. Read the court's wording below. · Civil cases

Page 3 | Trial Fee

Courtesy Copy Requirements

The original case-dispositive motion and response must be filed with the Prothonotary, with one courtesy copy including exhibits delivered to Judge Wallace’s chambers.

The original motion and the response thereto shall be filed with the Prothonotary’s Office with one courtesy copy (with exhibits) delivered to Judge Wallace in chambers.

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Page 5 | ADDITIONAL INFORMATION AND PROCEDURES — Case Dispositive Motions

One courtesy copy of a routine-motion response, including exhibits, must be delivered to Judge Wallace’s chambers.

Responses are due no later than 7 calendar days after the filing of the motion and in no case later than the Wednesday prior to the motion’s hearing, with one courtesy copy of a response (with exhibits) delivered to Judge Wallace in chambers.

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Page 5 | ADDITIONAL INFORMATION AND PROCEDURES — Routine Civil Motions

Counsel must provide Judge Wallace’s Chambers one courtesy copy of specified CCLD pleading documents and related exhibits as soon as possible.

Counsel shall file one (1) courtesy copy of their complaints, cross-claims, counterclaims, and any related exhibits with Judge Wallace's Chambers as soon as possible.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 1 | Initial Stages – Complex Commercial Litigation Division (CCLD) Cases

No courtesy copy of the letter must be delivered to Judge Wallace’s chambers.

No courtesy copy need be delivered to Judge Wallace's chambers.

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Page 1 | Communications

One courtesy copy of a routine civil motion, including exhibits, must be delivered to Judge Wallace’s chambers.

Motions must be filed no less than fifteen 15 calendar days prior to the noticed presentation date with one courtesy copy (with exhibits) delivered to Judge Wallace in chambers.

Not confirmed. Read the court's wording below. · Civil cases

Page 5 | ADDITIONAL INFORMATION AND PROCEDURES — Routine Civil Motions

One courtesy copy of the dispositive motion, response, and reply must be promptly delivered to chambers.

The original motion, response, and reply should be e-filed with 1 courtesy copy promptly delivered to chambers.

Not confirmed. Read the court's wording below. · Civil cases

Page 1 | Motions & Briefing – Dispositive Motions

One courtesy copy of a routine motion and response, including exhibits, must be filed in chambers.

One courtesy copy of both the motion and response (with exhibits) must be filed in chambers.

Not confirmed. Read the court's wording below. · Civil cases

Page 1 | Motions & Briefing – Routine Motions

One courtesy copy of a routine-motion response, including exhibits, must be delivered to Judge Wallace in chambers.

Responses are due no later than 7 calendar days after the filing of the motion and in no case later than the Wednesday prior to the motion’s hearing, with one courtesy copy of a response (with exhibits) delivered to Judge Wallace in chambers.

Not confirmed. Read the court's wording below. · Civil cases

Page 4 | Routine Civil Motions

The original case-dispositive motion and response must each be filed with the Prothonotary’s Office, with one courtesy copy including exhibits delivered to Judge Wallace in chambers.

The original motion and the response thereto shall be filed with the Prothonotary’s Office with one courtesy copy (with exhibits) delivered to Judge Wallace in chambers.

Not confirmed. Read the court's wording below. · Civil cases

Page 4 | Case Dispositive Motions

One courtesy copy of a routine motion, including exhibits, must be delivered to Judge Wallace in chambers.

Motions must be filed no less than fifteen 15 calendar days prior to the noticed presentation date with one courtesy copy (with exhibits) delivered to Judge Wallace in chambers.

Not confirmed. Read the court's wording below. · Civil cases

Page 4 | Routine Civil Motions

Sealing & Redaction Procedures

Any court filing that communicates Confidential Discovery Material must be filed confidentially and withheld from public access under Superior Court Civil Rules 5(g) and 79.1.

Any pleading, brief, memorandum, motion, letter, affidavit, exhibit or other document filed with the Court that discloses, summarizes, describes, characterizes, includes or attaches or otherwise communicates Confidential Discovery Material (a “Confidential Filing”) must be filed confidentially and not available for public access (“Confidential Treatment”) in accordance with the provisions of Superior Court Civil Rules 5(g) and 79.1

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 10 | Paragraph 11

Materials filed under Paragraph 11 may be unsealed only as provided by Superior Court Civil Rule 5(g) or by further order of the court.

All materials filed pursuant to Paragraph 11 shall be unsealed by the Prothonotary only as provided in Superior Court Civil Rule 5(g), as applicable, or upon further order of this Court.

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 12 | Paragraph 13

If the motion seeking continued confidential treatment is not timely filed, the confidential filing becomes part of the public record and is accessible on the docket system.

If a motion seeking continued Confidential Treatment is not timely filed, then the Confidential Filing shall become part of the public record, the Prothonotary shall permit access to the Confidential Filing on the docket system to the same extent as any other public filing.

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 13 | Stipulation and [Proposed] Order for the Production and Exchange of Confidential Information

A producing party seeking to continue restricted public access to a confidential filing must file a motion with the court within the seven-day period specified by Superior Court Rule 5(g)(4).

To the extent that the Producing Party seeks to continue the restruction on public access to the Confidential Filing, or any portion thereof, to which a public version is available, the Producing Party shall file a motion with the Court within the seven-day period mandated by Superior Court Rule 5(g)(4) for judicial determination as to whether good cause exists for continued restricted access to the Confidential Filing, or any portion thereof.

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 13 | Stipulation and [Proposed] Order for the Production and Exchange of Confidential Information

If an opposition to the motion is not timely filed, the challenge is withdrawn and the filing continues to receive confidential treatment.

If an opposition to the motion is not timely filed, then the challenge shall be deemed withdrawn and the Confidential Filing shall continue to receive Confidential Treatment.

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 13 | Stipulation and [Proposed] Order for the Production and Exchange of Confidential Information

A producing party seeking continued confidential treatment for a public version of a confidential filing must file a motion with the court within the seven-day period mandated by Superior Court Civil Rule 5.

To the extent that the Producing Party seeks to continue the restriction on public access to the Confidential Filing, or any portion thereof, to which a public version is available, the Producing Party shall file a motion with the Court within the seven-day period mandated by Superior Court Civil Rule 5.

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 15 | Confidential and Highly Confidential Designations

If the challenging party does not timely oppose the motion, the challenge is withdrawn and the confidential filing remains subject to confidential treatment.

If an opposition to the motion is not timely filed, then the challenge shall be deemed withdrawn and the Confidential Filing shall continue to receive Confidential Treatment.

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 16 | Confidential and Highly Confidential Designations

Confidential or highly confidential discovery material used in open court or lodged as a trial exhibit loses its confidential status and becomes public unless the producing party obtains a court order maintaining its confidentiality.

In the event that any Confidential or Highly Discovery Material is used in open court during any court proceeding or lodged as a trial exhibit, the material shall lose its confidential status and become part of the public record, unless the Producing Party applies for and obtains an order from this Court specifically maintaining the confidential status of particular material.

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 21 | 6. Disclosure of Highly Confidential Discovery Material

Public versions of exhibits, affidavits, declarations, and other attachments ordinarily are not required, unless Rule 5(g), a court order, or the Prothonotary requires one.

For avoidance of doubt, the Parties have no obligation to file public versions of any exhibits, affidavits, declarations or other attachments filed as part of a Confidential Filing, except as required by Superior Court Civil Rule 5(g) or if otherwise ordered by the Court or required by the Prothonotary.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 14 | 13

A party may move on reasonable notice to vacate a confidential or highly confidential designation only after making a good-faith effort to resolve the objection.

any Party objecting to the designation of any Discovery Material as Confidential or Highly Confidential Discovery Material may, after making a good faith effort to resolve any such objection, move on reasonable notice for an order vacating the designation.

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 16 | Inadvertent Failure to Designate

Public versions of exhibits, affidavits, declarations, and other attachments filed with a confidential filing are not required unless Rule 5(g), a court order, or the Prothonotary requires them.

For avoidance of doubt, the Parties have no obligation to file public versions of any exhibits, affidavits, declarations or other attachments filed as part of a Confidential Filing, except as required by Superior Court Civil Rule 5(g) or if otherwise ordered by the Court or required by the Prothonotary.

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 12 | Paragraph 12

When complying with Superior Court Civil Rule 5(g), parties must file a public-inspection copy that omits confidential discovery material when the producing party reasonably and in good faith believes public disclosure would cause harm that outweighs public access.

when complying with Rule 5(g), parties must file a copy of the Confidential Filing for public inspection that omits only such Confidential Discovery Material as to which the Producing Party reasonably and in good faith believes the public interest in access to Court ===== PAGE 12 ===== proceedings is outweighed by the harm public disclosure of such Discovery Material would cause because it contains sensitive, non-public information.

Not confirmed. Read the court's wording below. · Civil cases

Page 11 | Paragraph 12

A person challenging confidential treatment has seven days to file an opposition.

The person challenging Confidential Treatment shall have seven (7) days to file an opposition.

Not confirmed. Read the court's wording below. · Civil cases

Page 13 | Stipulation and [Proposed] Order for the Production and Exchange of Confidential Information

A court filing that communicates Confidential or Highly Confidential Discovery Material must be submitted confidentially and unavailable for public access under Superior Court Civil Rule 5(g), with a footer on every page.

Any pleading, brief, memorandum, motion, letter, affidavit, exhibit or other document filed with the Court that discloses, summarizes, describes, characterizes, includes or attaches or otherwise communicates Confidential or Highly Confidential Discovery Material (a “Confidential Filing”) must be filed confidentially and not available for public access (“Confidential Treatment”) in accordance with the provisions of Superior Court Civil Rule 5(g), which may be accomplished by submitting documents, every page of which shall have a footer stating:

Not confirmed. Read the court's wording below. · Civil cases

Page 12

The Prothonotary may unseal materials governed by Paragraph 12 only under Rule 5(g) or a further court order.

All materials filed pursuant to Paragraph 12 shall be unsealed by the Prothonotary only as provided in Superior Court Civil Rule 5(g), as applicable, or upon further order of this Court.

Not confirmed. Read the court's wording below. · Civil cases

Page 14 | 14

A party must file a public version that redacts only sensitive, non-public Confidential or Highly Confidential Discovery Material that the producing party reasonably and in good faith believes should be withheld.

Nevertheless, when complying with Rule 5(g), parties must file a copy of the Confidential Filing for public inspection that omits only such Confidential or Highly Confidential Discovery Material as to which the Producing Party reasonably and in good faith believes the public interest in access to Court proceedings is outweighed by the harm public disclosure of such Discovery Material would cause because it contains sensitive, non-public information.

Not confirmed. Read the court's wording below. · Civil cases

Page 14 | 13

If the producing party does not timely file a motion seeking continued confidential treatment, the confidential filing becomes part of the public record and is accessible like any other public filing.

If a motion seeking continued Confidential Treatment is not timely filed, then the Confidential Filing shall become part of the public record, and the Prothonotary shall permit access to the Confidential Filing on the docket system to the same extent as any other public filing.

Not confirmed. Read the court's wording below. · Civil cases

Page 16 | Confidential and Highly Confidential Designations

While a motion to vacate a confidentiality designation is pending, the material remains treated as confidential or highly confidential discovery material.

While such a motion is pending, the Discovery Material in question shall be treated as Confidential or Highly Confidential Discovery Material pursuant to this Stipulation.

Not confirmed. Read the court's wording below. · Civil cases

Page 16 | Inadvertent Failure to Designate

Filing Bundling Requirements

A case referred to a special discovery master may use a modified discovery-motion practice protocol.

If the case is referred to a special discovery master, then a modified protocol for discovery motion practice may be entered.

Not confirmed. Read the court's wording below. · Civil cases

Page 6 | VI. MOTIONS PRACTICE — B. DISCOVERY AND OTHER MOTIONS

Pre-Motion Conference Requirements

The parties must actively engage in settlement discussions and determine whether the case can be resolved under Civil Rule 16.

The parties are required actively to engage in settlement discussions and determine whether the matter may be resolved in accordance with Civil Rule 16.

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Page 5 | ADDITIONAL INFORMATION AND PROCEDURES — Settlement Negotiations

The parties must meet and confer in good faith before moving the court for modifications or additional safeguards.

The Parties agree to meet and confer in good faith prior to moving the Court for any modifications or additional safeguards.

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 14 | Stipulation and [Proposed] Order for the Production and Exchange of Confidential Information

A party challenging a confidential-discovery designation must make a good-faith effort to resolve the objection before moving on reasonable notice for an order vacating the designation.

During the pendency of this Litigation, any Party objecting to the designation of any Discovery Material as Confidential Discovery Material may, after ===== PAGE 14 ===== making a good faith effort to resolve any such objection, move on reasonable notice for an order vacating the designation.

Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases

Page 14 | Stipulation and [Proposed] Order for the Production and Exchange of Confidential Information

Before filing a dispositive motion, counsel must obtain possible hearing dates and times from Judge Wallace’s Administrative Specialist, agree on a proposed date and time, and notice the motion accordingly.

Counsel must obtain possible dates and times for hearing of such motions from Judge Wallace’s Administrative Specialist before filing of such motion. The parties shall agree upon a proposed date and time and the motion noticed accordingly.

Not confirmed. Read the court's wording below. · Civil cases

Page 6 | VII. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS — 1. Time of Hearing

Counsel must obtain possible hearing dates and times from the administrative specialist before filing a dispositive motion.

Counsel must obtain possible dates and times for hearing of such motions from Judge Wallace’s Administrative Specialist before filing of such motion.

Not confirmed. Read the court's wording below. · Civil cases

Page 5 | VI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS

Before filing a dispositive motion, counsel must obtain possible hearing dates and times from Judge Wallace’s Administrative Specialist, agree on a proposed date and time, and notice the motion accordingly.

Counsel must obtain possible dates and times for hearing of such motions from Judge Wallace’s Administrative Specialist before filing of such motion. The parties shall agree upon a proposed date and time and the motion noticed accordingly.

Not confirmed. Read the court's wording below. · Civil cases

Page 5 | VI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS

Before moving the court to modify the stipulation or request additional safeguards for discovery material, the parties must meet and confer in good faith.

17. The Parties reserve the right to apply, pursuant to Superior Court Civil rule 5(g)(3), upon short notice, for an order seeking additional safeguards with respect to the use and handling of Discovery Material or to modify the terms of this Stipulation. The Parties agree to meet and confer in good faith prior to moving the Court for any modifications or additional safeguards.

Not confirmed. Read the court's wording below. · Civil cases

Page 17 | Stipulation ¶ 17

Adjournment & Extension Requirements

If all counsel expect an early settlement, plaintiff’s counsel may request postponement of the scheduling conference.

After receiving a Scheduling Conference date and time, if all counsel believe that the case is likely to settle soon, Plaintiff's counsel, speaking for all parties, may write the Court requesting the Scheduling Conference's postponement.

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Page 1 | Initial Stages – Initial Scheduling Conferences

Requests for relief should be made by motion rather than by letter or email.

The Court strongly discourages requests for relief submitted in the form of letters or emails. Such requests should be made by motion.

Not confirmed. Read the court's wording below. · Civil cases

Page 4 | Routine Civil Motions

Chambers Communication Rules

Plaintiff’s counsel must immediately notify chambers by email if the case settles.

In the event the case settles, Plaintiff’s Counsel shall notify chambers immediately by e-mail to Judge Wallace’s Administrative Specialist, Civil Case Manager, and Law Clerk

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 5 | ADDITIONAL INFORMATION AND PROCEDURES — Settlement Negotiations

Case-dispositive motion dates and times must be obtained from Judge Wallace’s chambers by calling 255-0660.

Case dispositive motions will be scheduled by obtaining a date and time from Judge Wallace’s Chambers which can be reached at 255-0660.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 5 | ADDITIONAL INFORMATION AND PROCEDURES — Case Dispositive Motions

Plaintiff’s counsel must immediately email chambers staff when mediation resolves or the case otherwise settles.

If mediation resolves the case or in the event the case settles, Plaintiff's counsel should notify chambers immediately by email to Judge Wallace's Administration Specialist, Civil Case Manager, and Law Clerk.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 1 | Initial Stages – Initial Scheduling Conferences

A date and time for a case-dispositive motion must be obtained from Judge Wallace’s chambers by calling 255-0660.

Case dispositive motions will be scheduled by obtaining a date and time from Judge Wallace’s Chambers which can be reached at 255-0660.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 4 | Case Dispositive Motions

If the case settles, Plaintiff’s counsel must immediately notify the identified chambers personnel by email.

In the event the case settles, Plaintiff’s Counsel shall notify chambers immediately by e-mail to Judge Wallace’s Administrative Specialist, Civil Case Manager, and Law Clerk, all of whom are identified at http://courts.delaware.gov/superior/judgespref/judges pref jwallace.aspx.

Checked against the court's document on Oct 1, 2026 · Civil cases

Page 4 | Settlement Negotiations

Counsel seeking courtroom technology support should call the Bailiffs’ Office several days before trial.

Counsel desiring a courtroom with specific technology support should contact the Bailiffs' Office (302) 655-0586 or (302) 255-0587 several days before the trial.

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Page 1 | Trials & Courtroom Proceedings

Counsel must obtain possible dispositive-motion oral-argument dates and times through the Administrative Specialist.

Counsel must obtain possible dates and times for oral argument through Judge Wallace's Administrative Specialist.

Not confirmed. Read the court's wording below. · Civil cases

Page 1 | Motions & Briefing – Dispositive Motions

Chambers or the prothonotary must be notified by phone before or promptly after a fax transmission.

* Please advise the Administrative Specialist or Civil Case Manager by phone or email that a FAX transmission has been or is about to be sent to chambers or the prothonotary.

Not confirmed. Read the court's wording below. · Civil cases

Page 1 | Judicial Preferences

An attorney other than the pleading signatory who plans to attend the scheduling conference must call the Administrative Specialist at least one day beforehand.

If counsel other than a signatory of the complaint or the responsive pleading plans to attend, that counsel should notify chambers at least the day before the Scheduling Conference by phone to Judge Wallace's Administrative Specialist.

Not confirmed. Read the court's wording below. · Civil cases

Page 1 | Initial Stages – Initial Scheduling Conferences

Court-wide rules

Applies court-wide

These 167 rules apply across Superior Court of Delaware, New Castle County. Where this judge's own standing orders above address the same topic, the judge's requirement controls.

Filing Requirements

All 50
  • Applies to
    Pending appeals inventory

    The Prothonotary of each county must prepare a Pending Appeals Inventory at the end of each month.

  • Applies to
    Case information statement

    A party identifies a qualifying case by entering the CCLD civil case code and Complex Commercial Litigation civil case type on the Case Information Statement.

  • Applies to
    Pleadings and other filed papers

    All pleadings and other papers filed with the court must include CCLD.

Filing Timing

All 30
  • A motion opposing CCLD case identification must be filed before the Rule 16 scheduling conference unless the Panel Judge directs otherwise, and filing it does not extend deadlines for other pleadings, motions, or responses.

  • For non-expedited Rule 7(c)(1) motions, the general briefing schedule calls for an opening brief 30 days after filing, an answering brief 30 days later, and a reply 15 days after that.

  • Deadline
    14 calendar days

    For non-expedited motions other than Rule 7(c)(1) motions, the opposition is generally due 14 calendar days after filing and the reply seven calendar days later.

Communication

All 23
  • A lawyer should give all affected parties reasonable notice, whenever possible, before communicating with a court concerning pending or prospective litigation.

  • Ex parte communications with the court on pending matters should be avoided unless permitted by law.

  • Contact
    Email to duty judge

    Direct email to judicial officers is reserved for a true emergency arising outside regular business hours.

Formatting

All 11
  • Appendices and compendia should use tabs.

  • Parties should submit joint exhibits rather than separate plaintiff or defense exhibit sets.

  • Exhibits should be organized chronologically, or, when chronological ordering is not feasible in a highly expedited matter, parties should provide a chronological exhibit list as soon as practicable.

About Judge Paul R. Wallace

The Honorable Paul R. Wallace was appointed to the Superior Court of Delaware by Governor Jack A. Markell and began serving in January 2013.

Administrative contact: Dawn Pillarelli. Chambers phone: (302) 255-0660. Preference page updated September 8, 2026.

Common questions about Judge Paul R. Wallace's rules

Are courtesy copies required for Judge Paul R. Wallace?

Courtesy-copy rule applies for motions and responses. Details: 1 copy. The original case-dispositive motion and response must be filed with the Prothonotary, with one courtesy copy including exhibits delivered to Judge Wallace’s chambers.

View ruleSource: page 5, section ADDITIONAL INFORMATION AND PROCEDURES — Case Dispositive Motions

Does Judge Paul R. Wallace require a pre-motion conference or letter before filing a motion?

Judge Paul R. Wallace's rules set a pre-motion procedure for covered motions. Before filing a dispositive motion, counsel must obtain possible hearing dates and times from Judge Wallace’s Administrative Specialist, agree on a proposed date and time, and notice the motion accordingly.

View ruleSource: page 6, section VII. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS — 1. Time of Hearing

What page or word limits apply to letter before Judge Paul R. Wallace?

Judge Paul R. Wallace's rule states these limits: 1000 words. A letter to the court may not exceed 1,000 words.

View ruleSource: page 7, section D. LETTERS

What page or word limits apply to brief before Judge Paul R. Wallace?

Judge Paul R. Wallace's rule states these limits: 750 words. Excludes appendices. A defendant’s separate joinder or supporting brief must be served within three business days and may not exceed 750 words, excluding appendices.

View ruleSource: page 6, section VI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS

What formatting rules apply to filings before Judge Paul R. Wallace?

Judge Paul R. Wallace's formatting rule includes must be individually tabbed. Brief exhibits, motion courtesy copies, and letters must each be individually tabbed.

View ruleSource: page 1, section Motions & Briefing – Formatting

What must be included with opening brief filings before Judge Paul R. Wallace?

The rule identifies required filing content or certificates. Every dispositive motion must be accompanied by an opening brief supporting it.

View ruleSource: page 5, section VI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS

What must be included with motion filings before Judge Paul R. Wallace?

The rule identifies required filing content or certificates. A case-dispositive motion must include a notice page indicating the date and time of the motion hearing.

View ruleSource: page 5, section ADDITIONAL INFORMATION AND PROCEDURES — Case Dispositive Motions

How may parties contact Judge Paul R. Wallace's chambers?

The rule addresses email communications with Judge Paul R. Wallace's chambers. Plaintiff’s counsel must immediately notify chambers by email if the case settles.

View ruleSource: page 5, section ADDITIONAL INFORMATION AND PROCEDURES — Settlement Negotiations

How does Judge Paul R. Wallace handle sealed or redacted filings?

Judge Paul R. Wallace's rules set procedures for sealed or redacted filings. Any court filing that communicates Confidential Discovery Material must be filed confidentially and withheld from public access under Superior Court Civil Rules 5(g) and 79.1.

View ruleSource: page 10, section Paragraph 11

How do I request an adjournment or extension before Judge Paul R. Wallace?

Advance notice is not fully stated in the structured details. If all counsel expect an early settlement, plaintiff’s counsel may request postponement of the scheduling conference.

View ruleSource: page 1, section Initial Stages – Initial Scheduling Conferences

Does Judge Paul R. Wallace require motion papers to be bundled?

Bundling is optional for covered papers before Judge Paul R. Wallace. A case referred to a special discovery master may use a modified discovery-motion practice protocol.

View ruleSource: page 6, section VI. MOTIONS PRACTICE — B. DISCOVERY AND OTHER MOTIONS

Are filing fees or waivers addressed before Judge Paul R. Wallace?

A fee is required for covered filings. The trial fee must be paid no later than the pretrial conference; if unpaid within two business days after the conference, the case will be removed from the trial calendar and a new trial date will be scheduled upon payment.

View ruleSource: page 3, section Trial Fee

Is electronic filing required before Judge Paul R. Wallace?

Yes. Electronic filing is required for the covered filings. A substantive email must be docketed by the sender and may be sent only with Judge Wallace’s approval or in exigent circumstances.

View ruleSource: page 1, section Communications

What filing deadlines does Judge Paul R. Wallace set?

A separate joinder or supporting brief must be served within three business days after service of the motion or opposition.

View ruleSource: page 6, section VI. MOTIONS PRACTICE — A. DISPOSITIVE MOTIONS

What service or proof of service rules apply before Judge Paul R. Wallace?

The rule addresses service method, recipient, or timing requirements. When a new party is added, the party adding it must serve the new party with the Case Management Order at the same time it serves the pleading joining the new party.

View ruleSource: page 1, section I. GENERAL
Complete rules summary for Judge Paul R. Wallace

A letter to the court may not exceed 1,000 words.

When a new party is added, the party adding it must serve the new party with the Case Management Order at the same time it serves the pleading joining the new party.

Documents initiating specified discovery requests and responses to them must be served electronically through LEXIS/NEXIS, excluding the actual production of documents.

Dispositive motions may be filed on or before the date stated in the scheduling order.

A response to a dispositive motion is due no later than 30 days after the motion is filed, with briefing and further proceedings governed by Section VI-A.

Before filing a dispositive motion, counsel must obtain possible hearing dates and times from Judge Wallace’s Administrative Specialist, agree on a proposed date and time, and notice the motion accordingly.

Every dispositive motion must be accompanied by an opening brief supporting it.

A defendant’s separate joinder or supporting brief must be served within three business days and may not exceed 750 words, excluding appendices.

A separate joinder or supporting brief must be served within three business days after service of the motion or opposition.

A separate joinder or supporting brief is limited to 750 words and must comply with Superior Court Civil Rule 107(b)’s typeface requirement, excluding appendices.

Unless an alternative schedule applies, an answering brief must be filed and served by the later of 30 days after motion service or 30 days after a separate joinder or supporting brief is filed.

If a reply brief is filed on a dispositive motion, it may be filed 14 days after responses are received but no later than seven days before the hearing.

A reply brief on a dispositive motion may be filed fourteen days after responses are received.

A reply brief must be filed no later than seven days before the motion hearing.

Every brief on a dispositive motion must conform to Superior Court Civil Rule 107.

A discovery motion or other non-dispositive, non-in-limine motion must be a speaking motion limited to 2,500 words, comply with Rule 107(b)’s typeface requirement, and ordinarily be noticed on a Monday 9:00 a.m. routine motions calendar.

Discovery and other non-dispositive, non-in-limine motions must be speaking motions limited to 2,500 words and comply with Rule 107(b)’s typeface requirement.

Discovery and other non-dispositive, non-in-limine motions must be speaking motions limited to 2,500 words.

Absent leave of the Court, discovery and other motions must be filed at least 15 calendar days before the noticed hearing date.

Responses must be filed no later than seven (7) calendar days after the motion is filed.

Responses to discovery and other motions must also be filed no later than the Wednesday before the motion hearing.

Responses to discovery and other motions are limited to 2,500 words.

The order establishes separate filing deadlines for motions in limine and their responses, but the dates are left blank.

Each motion in limine and each response is limited to 2,500 words.

Each motion in limine must comply with the typeface requirements of Rule 107(b).

A case-dispositive motion must include a notice page indicating the date and time of the motion hearing.

Responses to dispositive motions are due 14 business days after filing.

Motions in limine must include all supporting authority.

Unless a specific order provides otherwise, a response to a motion in limine with all supporting authority is due no later than 7 business days after filing.

The interim status report is due no more than 14 days after mandatory ADR is conducted.

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