Judge Joshua D. Wolson
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
All filings
- Upon Filing
Courtesy copies
Adjournments
- Requests to reschedule the Rule 16 conference must be made as early as possible and based on a pre-existing commitment.
- Continuances of court events are granted only in extreme circumstances; other extension requests require an appropriate showing of good cause.
- Extension and continuance requests are made by letter emailed to Chambers, must include 'request for continuance' or 'request for extension' in the subject line, and must state opposing counsel's position after conferring.
- +3 more
Request must include
- Requests to exceed a page limit must be received at least seven days before the filing is due, emailed to Chambers with 'page limits' in the subject line, and reflect conferral with opposing counsel and state opposing counsel's position.
- Extension or continuance requests must be made at least seven days before the applicable deadline.
Communication
Chambers
Phone
Chambers
Page & Word Limits4 rules
Machine summary. Not checked yet.Mandatory?
Opening briefs in support of and in opposition to a motion shall not exceed 25 pages, unless counsel includes a certification that the brief contains no more than 8,750 words. Replies shall not exceed 10 pages or 3,500 words, and sur-replies shall not exceed seven pages or 2,450 words.
Summary: Opening briefs are limited to 25 pages or 8,750 words (with certification); replies to 10 pages or 3,500 words; sur-replies to 7 pages or 2,450 words.
Brief
25 pages
Applies to: Attorney
Brief
8,750 words
Applies to: Attorney
Reply
10 pages
Applies to: Attorney
Reply
3,500 words
Applies to: Attorney
Sur Reply
7 pages
Applies to: Attorney
Sur Reply
2,450 words
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Any motion for reconsideration of a discovery order must itself comply with the page limits in Section II.C.1., below.
Summary: Reconsideration motions of discovery orders must comply with discovery motion page limits in Section II.C.1.
Motion For Reconsideration
Machine summary. Not checked yet.Mandatory?
The applicable page limits for individual parties shall apply for joint pleadings absent leave of Court.
Summary: Joint pleadings are subject to the same page limits as individual parties.
Joint Pleading
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with Local Civil Rule 26.1(b), with a form order and short brief, not to exceed five pages or 1,750 words (not including exhibits), describing the dispute.
Summary: Discovery motion briefs are limited to five pages or 1,750 words, excluding exhibits.
Discovery Motion
5 pages
Applies to: Attorney
1,750 words
Applies to: Attorney
Document Format Requirements5 rules
Machine summary. Not checked yet.Mandatory?
The parties shall not include substantive arguments in footnotes. Judge Wolson will not consider substantive arguments made in footnotes, nor will he deem those arguments preserved.
Summary: Parties must not put substantive arguments in footnotes; the Court will not consider or deem such arguments preserved.
Machine summary. Not checked yet.Mandatory?
All written submissions to Judge Wolson must be double-spaced, in at least 12-point font with at least one-inch margins. A party may use any proportionally spaced font. All footnotes shall appear in the same font and font size as the body of the submission.
Summary: All written submissions must be double-spaced, in at least 12-point font, with at least one-inch margins; any proportionally spaced font may be used, and footnotes must match the body font and size.
Machine summary. Not checked yet.Important?
Parties should submit deposition testimony and other transcripts to Judge Wolson as full-sized pages, not miniscripts.
Summary: Deposition testimony and transcripts must be submitted as full-sized pages, not miniscripts.
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Parties should submit stipulations and proposed Orders as Word documents.
Summary: Stipulations and proposed orders should be submitted to Chambers as Word documents.
DOCX
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Counsel must file text-searchable versions of their briefs on the CM/ECF system.
Summary: Briefs must be filed on CM/ECF as text-searchable versions.
Document Filing Requirements37 rules
Machine summary. Not checked yet.Mandatory?
By signing below, counsel for each Party and/or each pro se Party represents that he or she has reviewed the Judge's Policies and Procedures and acknowledges the requirements contained therein, including the Policies governing keywords to use when emailing Chambers. The Parties and their counsel further acknowledge by signing below that Judge Wolson will strike pleadings and other submissions that do not comply with his Policies and Procedures.
Summary: Signing the Rule 16 statement certifies review of and compliance with Judge Wolson's Policies and Procedures, including email-chambers keyword rules; non-compliant pleadings and submissions will be stricken.
Document Type
Case Management Statement
Machine summary. Not checked yet.Mandatory?
Parties may not make additional submissions, whether captioned as a brief, a letter, a notice, or anything else, other than to notify Judge Wolson of subsequent binding authority.
Summary: No additional submissions (brief, letter, notice, or otherwise) are permitted, except to notify the Court of subsequent binding authority.
Document Type
Additional Submissions
Machine summary. Not checked yet.Mandatory?
A summary judgment motion must be accompanied by (a) a single, consolidated statement of facts that the parties will prepare jointly and that will be separately filed on the docket and (b) a joint set of all exhibits cited in the statement of facts.
Summary: Summary judgment motions must be accompanied by a jointly prepared consolidated statement of facts and a joint set of cited exhibits.
Document Type
Summary Judgment Motion
Machine summary. Not checked yet.Mandatory?
At least 14 days before the deadline to file a motion, any responding party must serve on all other parties (but not file) a response to the statement of facts that includes the following: (a) the responding party's response to each factual assertion, which shall be directly under the original paragraph and must include citation to any evidence that the responding party contends creates a material factual dispute and/or any argument for why the evidence that the moving party has cited does not support the factual assertion or is not admissible; and (b) any additional facts that the responding party intends to submit as part of the summary judgment briefing;
Summary: A responding party's statement of facts response must respond to each factual assertion directly under the original paragraph with citations/argument and include any additional facts for summary judgment briefing.
Document Type
Response To Statement Of Facts
Machine summary. Not checked yet.Mandatory?
If a party's motion for summary judgment, or an opposition thereto, is based in whole or in part on an argument that expert testimony is not admissible, then the party must raise such argument in a contemporaneous Daubert motion. That is, the party may not simply include arguments about expert inadmissibility within the summary judgment briefing. The argument must be the subject of a separate motion.
Summary: If summary judgment motion or opposition includes expert admissibility arguments, party must file a separate Daubert motion.
Document Type
Motion For Summary Judgment
Machine summary. Not checked yet.Mandatory?
The moving party must file the consolidated statement of facts and the joint set of exhibits with its motion. The joint set of exhibits must conform with Section I.C. of these Policies And Procedures.
Summary: Summary judgment movant must file consolidated statement of facts and joint exhibits conforming to Section I.C.
Document Type
Motion For Summary Judgment
Machine summary. Not checked yet.Mandatory?
Parties may not incorporate by reference arguments from other briefs in the case, including briefs filed by other parties or briefs filed earlier in the case. If a party needs to repeat an argument that was made earlier in the case, then that party must include the substance of the argument in the brief. If a party purports to incorporate an argument by reference, Judge Wolson will not consider the argument.
Summary: Parties may not incorporate arguments by reference; must include substance in the brief.
Document Type
Brief
Machine summary. Not checked yet.Mandatory?
Parties shall not respond to a motion for reconsideration absent a Court Order.
Summary: Parties may not respond to a motion for reconsideration without a court order.
Document Type
Motion For Reconsideration
Machine summary. Not checked yet.Mandatory?
In filing a discovery motion, the certificate of counsel must provide specific details of the parties’ efforts to resolve the dispute informally. These efforts must include verbal communications, whether by phone or in person. Exchanges of letters or e-mails are not sufficient. It is not sufficient to report that opposing counsel was not available or that the parties made “reasonable efforts.” Judge Wolson will deny a discovery motion that does not meet these requirements.
Summary: Discovery motions require a certificate detailing informal resolution efforts, including verbal communications; letters or emails are insufficient and non-compliance results in denial.
Document Type
Discovery Motion
Machine summary. Not checked yet.Mandatory?
All discovery motions must attach the discovery requests at issue, as well as the written response.
Summary: Discovery motions must attach the discovery requests at issue and the corresponding written response.
Document Type
Discovery Motion
Machine summary. Not checked yet.Mandatory?
All motions must contain the certification required under Local Civil Rule 26.1(f).
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
When a party submits a pretrial memorandum, it must include all matters set forth in Local Rule of Civil Procedure 16.1, as well as its position on whether Judge Wolson should impose time limits on each side's trial presentation and, if Judge Wolson does impose a time limit, what that limit should be.
Summary: Pretrial memoranda must include all matters set forth in LR 16.1 and the party's position on trial time limits.
Document Type
Pretrial Memorandum
Machine summary. Not checked yet.Mandatory?
All such motions must satisfy the requirements of In re Avandia Mktg., Sales Practices & Prod. Liab. Litig., 924 F.3d 662 (3d Cir. 2019) and Pansy v. Borough of Stroudsberg, 23 F.3d 772 (3d Cir. 1994).
Summary: Motions for protective orders or confidentiality agreements must satisfy the requirements of Avandia and Pansy.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
Any request for a protective order or approval of a confidentiality agreement must be made by motion. Judge Wolson will not accept stipulated proposed orders in lieu of a motion.
Summary: Requests for protective orders or confidentiality agreement approvals must be made by motion; stipulated proposed orders are not accepted in lieu of a motion.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
If the parties want Judge Wolson to retain jurisdiction to enforce a settlement, they must place the agreement on the docket or include all material terms in a stipulation of dismissal.
Summary: To retain jurisdiction to enforce a settlement, parties must place the agreement on the docket or include all material terms in a stipulation of dismissal.
Document Type
Settlement Agreement
Machine summary. Not checked yet.Mandatory?
If a defendant is responsible for restitution, then the Government must submit information in its sentencing memorandum to enable Judge Wolson to determine entitlement, the name and the address of each victim, the amount of loss for each victim, and documentary support for each amount. If liability for restitution is joint and several, then the Government shall itemize the restitution amount for which each defendant is responsible.
Summary: The Government's sentencing memorandum must include restitution details, including victim names/addresses, loss amounts, documentary support, and itemization for joint and several liability.
Document Type
Sentencing Memorandum
Machine summary. Not checked yet.Important?
Per my Policies and Procedures, lead counsel for a case must participate in the Rule 26(f) conference. If the person listed as lead counsel does not attend the Rule 26(f) conference, then I will designate the lawyer who attended the Rule 26(f) conference as lead counsel.
Summary: Lead counsel must attend the Rule 26(f) conference; otherwise, the Court will designate the attending lawyer as lead counsel.
Document Type
Rule 26f Report
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In addition, the Parties should not default to the limits in the Federal Rules of Civil Procedure when providing the numbers of interrogatories or depositions they expect in the case.
Summary: The Rule 26(f) report must state the parties' actual expected numbers of interrogatories and depositions rather than defaulting to FRCP limits.
Document Type
Rule 26f Report
Machine summary. Not checked yet.Important?
Default statements like “Discovery about all claims and defenses” are not acceptable.
Summary: The Rule 26(f) report must provide a thoughtful, specific discovery scope; default statements are not acceptable.
Document Type
Rule 26f Report
Machine summary. Not checked yet.Important?
When completing this section, the Parties should make a good faith effort to reach agreement on proposed deadlines. To the extent there is disagreement, the Parties shall identify the dispute and their respective positions.
Summary: Parties must make a good faith effort to agree on proposed case management deadlines and must identify any disagreements and their respective positions.
Document Type
Case Management Statement
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The Parties must summarize the status of discovery to-date. If nothing has been done in terms of discovery, the Parties should explain why.
Summary: The case management statement must summarize the status of discovery to date and explain why if no discovery has occurred.
Document Type
Case Management Statement
Machine summary. Not checked yet.Important?
Has each Party provided written notice to the client of the obligation to preserve all relevant material, including electronic records?
Summary: The case management statement must indicate whether each party has provided written notice to its client of the obligation to preserve all relevant material, including electronic records.
Document Type
Case Management Statement
Machine summary. Not checked yet.Important?
Parties should not submit pleadings from the case before Judge Wolson. For example, there is no need to attach a copy of a complaint to a Motion to Dismiss. Judge Wolson can retrieve those documents from the CM/ECF system. Nor should parties submit pleadings from other federal cases. It is enough to cite the pleading by court, case number, and docket number. Judge Wolson will retrieve the pleading from the CM/ECF
Summary: Parties should not attach pleadings from the case or other federal cases; instead they should cite the pleading by court, case number, and docket number.
Document Type
Pleadings
Machine summary. Not checked yet.Important?
In addition, parties submitting deposition transcripts should provide only a cover page identifying the witness and relevant pages from the transcripts. Parties should not submit the entire transcript unless the entire transcript is relevant to the issue.
Summary: Deposition transcript submissions should include only a cover page and relevant pages; entire transcripts should not be submitted unless fully relevant.
Document Type
Deposition Transcript
Machine summary. Not checked yet.Important?
Counsel seeking admission pro hac vice should use the form available on the Eastern District of Pennsylvania's website.
Summary: Pro hac vice counsel should use the form available on the Eastern District of Pennsylvania's website.
Document Type
Pro Hac Vice Motion
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Fed. R. Civ. P. 11 only permits parties to assert affirmative defenses for which they have a good faith basis. Parties may not assert affirmative defenses prophylactically.
Summary: Parties may assert affirmative defenses only with a good faith basis and may not assert them prophylactically.
Document Type
Answer
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Parties must submit that report to Judge Wolson via email. The parties must use Judge Wolson's sample Rule 26(f) form that will be attached to the order scheduling the Rule 16 conference.
Summary: Parties must submit the Rule 26(f) report by email using Judge Wolson's sample form.
Document Type
Joint Status Report
Machine summary. Not checked yet.Important?
Any briefs longer than 10 pages must include a table of contents.
Summary: Briefs longer than 10 pages must include a table of contents.
Document Type
Brief
Machine summary. Not checked yet.Important?
Counsel should file replies and sur-replies only when necessary. Such briefs must be concise and address only new issues raised by opposing counsel. Judge Wolson discourages any replies or sur-replies that repeat or rehash previous arguments.
Summary: Replies and sur-replies should be filed only when necessary, must be concise, may address only new issues raised by opposing counsel, and should not repeat or rehash prior arguments.
Document Type
Reply Or Sur Reply
Machine summary. Not checked yet.Important?
Wolson will set, and only cross-examination of experts (and redirect) will occur live.
Summary: In civil bench trials, only cross-examination of experts (and redirect) will occur live; the beginning of this provision is truncated in the source.
Document Type
Trial
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Judge Wolson will generally require the parties to submit a joint proposed set of jury instructions. Judge Wolson's pretrial order will detail how the parties should present contested jury instructions. Each point for charge and proposed jury interrogatory shall be numbered and on a separate sheet of paper. Each proposed instruction must be submitted with corresponding legal authority.
Summary: Jury instructions must generally be submitted jointly, with each point for charge and interrogatory numbered on a separate sheet and supported by corresponding legal authority.
Document Type
Jury Instructions
Machine summary. Not checked yet.Note?
A. Lead Counsel (each Party must designate one lawyer as lead counsel).
Summary: Each party must designate one lawyer as lead counsel in the Rule 26(f) report.
Document Type
Rule 26f Report
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When completing this section, the Parties shall keep in mind the following deadlines that I usually apply in patent cases, as set forth in the chart below. To the extent a departure is necessary.
Summary: Parties should use the Court's usual patent-case deadlines as the baseline when proposing case management deadlines, departing only if necessary.
Document Type
Case Management Statement
Machine summary. Not checked yet.Note?
Do the Parties anticipate the need for any third-party discovery? If so, identify the likely third parties, where those third parties are located, and the discovery to be sought.
Summary: The case management statement must state whether third-party discovery is anticipated and, if so, identify the likely third parties, their locations, and the discovery sought.
Document Type
Case Management Statement
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Does the plaintiff expect to request attorneys’ fees?
Summary: The case management statement must state whether the plaintiff expects to request attorneys' fees.
Document Type
Case Management Statement
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These procedures for a joint statement of facts do not apply to cases in which a party is a pro se prisoner.
Summary: Joint statement of facts procedure is not required for pro se prisoner cases.
Document Type
Motion For Summary Judgment
Machine summary. Not checked yet.Note?
Absent extraordinary circumstances, Judge Wolson will not retain jurisdiction of cases following dismissal due to settlement. Even when he does retain jurisdiction, Judge Wolson will not do so to enforce confidential settlement agreements.
Summary: Judge Wolson will not retain post-settlement jurisdiction absent extraordinary circumstances, and will not retain jurisdiction to enforce confidential settlement agreements.
Document Type
Settlement Agreement
Filing & Service rules
Electronic Filing Rules
Exhibits must be submitted as separate ECF documents; a combined 'Exhibits' filing will be struck.
When submitting exhibits via ECF, parties should submit each exhibit as a separate document on the CM/ECF system, rather than as a single file. If Judge Wolson receives a filing with a single document marked “Exhibits,” he will strike the filing.
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Page 6
Pro hac vice lawyers must register for CM/ECF within seven days of the admission Order; failure results in sua sponte cancellation of the pro hac admission and no mailed orders.
Any lawyer admitted pro hac vice must register for the Court's CM/ECF system within seven days of the Order. If a lawyer fails to register, Judge Wolson will sua sponte cancel the pro hac admission. Judge Wolson will not mail orders to lawyers admitted pro hac vice who do not register for CM/ECF.
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Page 10
Stipulations and proposed orders must be emailed to Chambers instead of filed on the docket, departing from Local Civil Rule 5.1.2(9).
Contrary to Local Civil Rule 5.1.2(9), parties must email all stipulations and proposed orders to Chambers rather than filing them on the docket.
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Page 13 | Stipulations and proposed Orders
Exhibit documents filed via ECF must have descriptive names (e.g., 'Contract,' 'Declaration of John Smith') rather than generic labels like 'Exhibit A.'
In addition, when parties submit exhibits via ECF, they must give each document a name identifying the document. Thus, it is not sufficient to label a file “Exhibit A.” Instead, the name should be “Contract,” “Declaration of John Smith,” or some other reference that permits Judge Wolson to identify what the exhibit is without having to open the file.
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Page 6
Filing Timing and Cure Windows
The Rule 26(f) joint status report is due at least seven days before the Rule 16 conference.
A joint status report pursuant to Fed. R. Civ. P. 26(f) is due at least seven days prior to the Rule 16 conference.
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Page 12 | Pretrial conferences
Judge Wolson does not permit additional discovery or summary judgment motions after arbitration is completed.
Judge Wolson does not permit additional discovery or summary judgment motions after the arbitration.
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Page 13 | Arbitration
Replies and sur-replies must be filed as soon as practicable and no later than seven days after the previous filing.
Any replies or sur-replies must be filed as soon as practicable, but in any event, no later than seven days after the previous filing.
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Page 14 | Replies and sur-replies
Sentencing motions must be filed at least 7 days before the sentencing date.
Sentencing motions, including for departures under U.S.S.G. § 5.K1.1 and supporting memoranda must be filed at least seven days prior to the scheduled sentencing date.
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Page 25 | F. Sentencing
Responses to sentencing motions must be filed at least 3 days before the sentencing date.
Responses to any sentencing motions must be filed at least three days prior to the scheduled sentencing date.
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Page 25 | F. Sentencing
Each party must file its sentencing memorandum no later than 7 days before sentencing.
Each party must file its sentencing memorandum no later than seven days prior to the scheduled sentencing date.
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Page 25 | F. Sentencing
In habeas matters other than § 2255, the relevant government agency must respond to motions or objections within 14 days absent a court-ordered extension; a failure to respond may be treated as uncontested.
In all other habeas corpus matters, Judge Wolson will not pre-screen prisoner submissions to determine if it requires a response. Instead, Judge Wolson expects the relevant Government agency (whether a County, the Commonwealth, the United States, or otherwise) to respond to motions or objections within 14 days, absent a Court-ordered extension. In cases in which Judge Wolson is considering a Report and Recommendation, the Government agency may respond by saying that it stands by its prior briefing and/or the Report and Recommendation. Judge Wolson reserves the right to treat a failure to respond as a statement that the motion or objection is uncontested.
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Page 27
The parties are expected to begin discovery before the Rule 16 conference.
In general, Judge Wolson expects the parties to begin discovery prior to the Rule 16 conference.
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Page 3 | IV. Status of Discovery
Service and Proof of Service Rules
The responding party must serve its response to the statement of facts on all other parties at least 14 days before the summary judgment motion deadline.
At least 14 days before the deadline to file a motion, any responding party must serve on all other parties (but not file) a response to the statement of facts that includes the following: (a) the responding party's response to each factual assertion, which shall be directly under the original paragraph and must include citation to any evidence that the responding party contends creates a material factual dispute and/or any argument for why the evidence that the moving party has cited does not support the factual assertion or is not admissible; and (b) any additional facts that the responding party intends to submit as part of the summary judgment briefing;
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Page 16
The moving party must serve a numbered statement of undisputed material facts with citations on all other parties at least 28 days before the summary judgment motion deadline.
At least 28 days before the deadline to file a motion, the moving party must serve on all other parties (but not file) a statement of undisputed material facts in a numbered, paragraph-by-paragraph recitation that contains specific citations to exhibits or testimony supporting each factual assertion;
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Page 16
Parties may consent to email service of pleadings and discovery under FRCP 5(b)(2)(E); non-consenting parties must explain their reasons.
Do the parties consent to service of pleadings and discovery via email pursuant to Fed. R. Civ. P. 5(b)(2)(E)? Any party that does not consent must explain its reasons.
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Page 8 | X. Consent to Service via Email
Filing Fees and Waivers
Pro hac vice motions will be denied if no filing fee is submitted.
Judge Wolson will deny pro hac vice motions for which no fee is submitted.
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Page 10
Courtesy Copy Requirements
Courtesy copies must be emailed (even in multiple emails) to the chambers courtesy copy address; Dropbox, FTP, and paper submissions are prohibited.
Parties may not submit courtesy copies via Dropbox, FTP, or some other source that requires Judge Wolson to download files to the Court's system. Instead, files should be emailed, even if that requires multiple emails. Parties also should not submit paper courtesy copies.
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Page 9
Courtesy copies must use the e-filed version with the CM/ECF header and be submitted as separate files with consistent names or include a coversheet identifying the corresponding CM/ECF entry.
Each submission should use the e-filed version that has the CM/ECF system's header at the top of the page. Each document must either (a) be a separate file, with a file name that is consistent with the descriptive name that the document has on the CM/ECF system or (b) include a coversheet that identifies the corresponding entry on the CM/ECF system.
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Page 9
Filing Bundling Requirements
Multiple co-parties must file joint motions unless clear conflicts exist.
When multiple plaintiffs or defendants appear in a case, they must file joint motions with their co-parties unless there are clear conflicts in their position.
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Page 18 | Motion Practice
Pre-Motion Conference Requirements
Before filing a Rule 12 motion, parties must contact opposing counsel for a substantive discussion and an opportunity to cure pleading deficiencies.
Any Party that intends to file a motion under Federal Rule of Civil Procedure 12 must contact opposing counsel to discuss the substance of the contemplated motion and to provide an opportunity to cure any alleged pleading deficiencies.
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Page 15
A telephone conference with counsel is scheduled before any responsive brief is filed on a discovery motion.
Judge Wolson will schedule a telephone conference with counsel to discuss the motion before the filing of any responsive brief.
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Page 19 | Discovery Motions
Summary judgment motions are not permitted in bench trials without prior leave; leave must be requested by letter within seven days after close of discovery.
Judge Wolson does not permit summary judgment motions in bench trials without prior leave of court. A party that seeks leave to file a summary judgment motion in a bench trial must send Judge Wolson a letter no more than seven days after the close of discovery explaining the grounds on which the party seeks leave to move.
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Page 21 | G. Bench Trials
Adjournment & Extension Requirements
Requests to exceed a page limit must be received at least seven days before the filing is due, emailed to Chambers with 'page limits' in the subject line, and reflect conferral with opposing counsel and state opposing counsel's position.
Judge Wolson must receive any request to exceed an applicable page limit at least seven days before the filing is due. Counsel may make such a request via letter emailed to Chambers with the words “page limits” in the subject line. Counsel making such a request should confer with opposing counsel and set forth opposing counsel’s position in the letter.
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Page 14 | Length of briefs
Extension and continuance requests are made by letter emailed to Chambers, must include 'request for continuance' or 'request for extension' in the subject line, and must state opposing counsel's position after conferring.
Requests for continuances or extensions may be made by letter, which can be emailed to Chambers. Any request for a continuance or extension must include the words “request for continuance” or “request for extension,” as appropriate, in the subject line of the email. Judge Wolson expects counsel for the party requesting an extension to confer with opposing counsel and state opposing counsel’s position in the letter.
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Page 20 | D. Extensions
Extension or continuance requests must be made at least seven days before the applicable deadline.
Any request for an extension or continuance must be made at least seven (7) days before the applicable
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Page 20 | D. Extensions
Sentencing continuances are discouraged and granted only for good cause.
Judge Wolson discourages requests for continuances of sentencing and will continue a sentencing for good cause only.
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Page 25 | F. Sentencing
After a 90-day continuance, counsel may jointly request an additional continuance in writing stating good cause; if granted, it is 45 days.
In the rare event of a 90-day continuance, if counsel for both the Government and the defendant(s) believe that good cause exists for an additional continuance beyond the initial 90-day period, then counsel may jointly request in writing an additional continuance. Any such request must state why good cause exists. If Judge Wolson grants 45 days until the sentencing hearing takes place.
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Page 25 | F. Sentencing
Requests to reschedule the Rule 16 conference must be made as early as possible and based on a pre-existing commitment.
If lead trial counsel is unable to attend, then Judge Wolson will reschedule the conference. However, any request to reschedule must be made as early as possible and must be based on a pre-existing commitment.
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Page 11 | Pretrial conferences
Continuances of court events are granted only in extreme circumstances; other extension requests require an appropriate showing of good cause.
Judge Wolson is reluctant to grant continuances of trial dates and other scheduled court events and will only do so in extreme circumstances. Judge Wolson will consider other requests for extensions on an appropriate showing of good cause.
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Page 20 | D. Extensions
Sentencing continuances exceeding 90 days are not considered absent extraordinary circumstances.
Absent extraordinary circumstances, Judge Wolson will not consider any request for a continuance exceeding 90 days.
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Page 25 | F. Sentencing
Chambers Communication Rules
Judge Wolson's Policies and Procedures specify required keywords to use when emailing Chambers, which counsel and pro se parties must acknowledge.
Judge Wolson's Policies and Procedures are available for the Parties to review online. By signing below, counsel for each Party and/or each pro se Party represents that he or she has reviewed the Judge's Policies and Procedures and acknowledges the requirements contained therein, including the Policies governing keywords to use when emailing Chambers.
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Page 8 | XI. Policies and Procedures
Emails to Judge Wolson must include the case name and docket number in the subject line.
Emails to Judge Wolson must include the case name and docket number in the subject line.
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Page 5 | B. Conventions For Emails
Emails to Judge Wolson must use required subject line verbiage: extension requests 'request for extension'; continuance requests 'request for continuance'; proposed orders 'proposed order'; stipulations 'stipulation'; Rule 26(f) reports '26(f) report'; page-limit requests 'page limits'; deposition scheduling 'deposition scheduling'; settlement updates 'settlement status'.
Judge Wolson will filter emails based on certain terminology in the subject line. Therefore, to ensure that emails receive prompt attention, where appropriate, emails to Judge Wolson must also use the following verbiage in the subject line:
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Page 5 | B. Conventions For Emails
Communications about administrative or procedural matters should be directed to a Courtroom Deputy or Chambers.
Counsel should direct communications concerning administrative or procedural matters to a Courtroom Deputy or Chambers.
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Page 5 | A. Correspondence With Chambers
Responsive letters may be submitted only at Judge Wolson's request.
Responsive letters should only be submitted at Judge Wolson’s request.
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Page 5 | A. Correspondence With Chambers
Letters may be emailed to chambers only for routine matters where no opposition is anticipated or required.
Parties may submit letters (when appropriate) via email, but they must limit such communications to routine matters for which no opposition is anticipated or required.
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Page 5 | A. Correspondence With Chambers
Meet-and-confer obligations require a verbal conversation (in person, videoconference, or phone); written correspondence does not satisfy them.
Any time that lawyers must meet and confer, whether pursuant to a statute, a federal or local rule, these Policies and Procedures, or a Court order, the parties must have a verbal conversation to satisfy the obligation. The conversation can be in person, by videoconference, or by phone. The mere exchange of written correspondence, whether letter, email, or otherwise, does not satisfy the obligation.
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Page 9 | F. Meeting And Conferring
Counsel must contact Judge Wolson by phone for deposition issues and must not leave a deposition without first attempting to contact Chambers for guidance.
Counsel should contact Judge Wolson by phone for any issues that arise during depositions. Counsel should not walk out of a deposition before trying to contact Judge Wolson and obtain guidance.
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Page 19 | Discovery Motions
Junior Lawyer Participation Incentives
Judge Wolson encourages assigning court presentations to less-experienced attorneys and may permit two lawyers to argue if requested in advance.
Judge Wolson encourages trial counsel to assign court presentations to less-experienced attorneys, particularly where the less-experienced attorney is more familiar with the matter at hand (e.g., discovery hearings). If necessary, Judge Wolson will permit two lawyers to make an argument to ensure that a more experienced counsel has an opportunity to buttress a younger lawyer’s presentation, if the request is made in advance. Judge Wolson will draw no inference from a party’s decision to have a younger lawyer make a particular presentation, including as to whether the client deems the issue “important.”
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Page 30 | H