Court Rules
Visiting

Judge Stephanos Bibas

Individual Rules, Standing Orders & Policies

District of Delaware

Limits & Logistics

Document Limits

Letter
3 pgs
Letter
5 pgs
Letter
2 pgs
Brief
3 pgs
Reply Brief
1 pgs

Courtesy Copies

Brief, Appendices, Exhibits, Declarations, Affidavits, Papers Filed Under Seal

  • Not required
Filters:AllMandatoryFormattingLettersConferencesMemorandaDiscoveryJuryElectronics

Page & Word Limits10 rules

Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

Within seven days after receipt of this letter, all adversaries must submit a written response, not to exceed three single-spaced pages.

Summary: Response to pre-motion letter limited to 3 single-spaced pages.

Letter

3 pages

Applies to: Attorney

SB Civil PreMotion Conf 2023 0 · p. 1
|SecCivil Pre-Motion Conference
Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

On that date, the party seeking relief shall file with the Court a letter, not to exceed three pages, outlining the issues in dispute and its position on those issues. Within three days, any party opposing the application for relief may file a letter, not to exceed three pages, outlining that party's

Summary: Letters filed in connection with discovery teleconferences are limited to 3 pages for both seeking relief and opposing parties.

Letter

3 pages

Applies to: Attorney

Scheduling Order · p. 4
|Secg. Discovery Matters and Disputes Relating to Protective Orders
Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

Within three days thereafter, the moving party may file a reply letter, not to exceed two pages, and, by this same date, the parties shall file a letter requesting a teleconference to address the motion to amend.

Summary: Reply letter for motion to amend must not exceed 2 pages.

Reply Letter

2 pages

Scheduling Order · p. 5
|Sec5. Motions to Amend
Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

Within seven days after the filing of a motion in compliance with this Order, any party opposing such a motion shall file a responsive letter, not to exceed five pages.

Summary: Responsive letter opposing motion to amend must not exceed 5 pages.

Opposition Letter

5 pages

Scheduling Order · p. 5
|Sec5. Motions to Amend
Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

Any motion to strike any pleading or other document shall not be accompanied by an opening brief but shall, instead, be accompanied by a letter , not to exceed three pages, describing the basis for the requested relief, and shall attach the document to be stricken.

Summary: Letter accompanying motion to strike must not exceed 3 pages.

Motion To Strike Letter

3 pages

Scheduling Order · p. 5
|Sec6. Motions to Strike
Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

Any motion to amend (including a motion for leave to amend) a pleading shall not be accompanied by an opening brief but shall, instead, be accompanied by a letter, not to exceed three pages, describing the basis for the requested relief, and shall attach the proposed amended pleading as well as a "blackline" comparison to the prior pleading.

Summary: Letter accompanying motion to amend must not exceed 3 pages.

Motion To Amend Letter

3 pages

Scheduling Order · p. 5
|Sec5. Motions to Amend
Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

Within three days thereafter, the moving party may file a reply letter, not to exceed two pages, and, by this same date, the parties shall file a letter requesting a teleconference to address the motion to strike.

Summary: Reply letter for motion to strike must not exceed 2 pages.

Reply Letter

2 pages

Scheduling Order · p. 6
|Sec6. Motions to Strike
Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

each in limine request may be supported by a maximum of three (3) pages of argument and may be opposed by a maximum of three (3) pages of argument.

Summary: In limine support and opposition arguments are each limited to 3 pages.

In Limine Support

3 pages

Applies to: Attorney

In Limine Opposition

3 pages

Applies to: Attorney

Scheduling Order · p. 8
|Sec§ G. Motions in Limine
Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

If more than one party is supporting or opposing an in limine request, such support or opposition shall be combined in a single three (3) page submission (and, if the moving party, a single one (1) page reply), unless otherwise ordered by the Court.

Summary: When multiple parties support or oppose an in limine request, their submissions must be combined into a single 3-page brief; moving party reply in such cases is limited to 1 page, unless otherwise ordered by the Court.

Brief

3 pages

Applies to: Attorney

Reply Brief

1 pages

Applies to: Attorney

Scheduling Order · p. 9
|SecMotions in Limine
Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

maximum of one (1) additional page in reply in support of its request.

Summary: Reply briefs in support of in limine requests are limited to 1 additional page, unless otherwise ordered by the Court.

Reply Brief

1 pages

Applies to: Attorney

Scheduling Order · p. 9
|SecMotions in Limine

Document Format Requirements1 rule

FormattingCivil cases

Machine summary. Not checked yet.Note?

The parties should also email Word versions of each document to Chambers.

Summary: Emailed copies of proposed voir dire, jury instructions, and special verdict forms sent to Chambers must be in Word (DOCX) format.

Required Format

DOCX

Scheduling Order · p. 9
|SecJury Instructions, Voir Dire, and Special Verdict Forms

Document Filing Requirements9 rules

Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Should counsel find, after good faith efforts—including oral communication among Delaware and Lead Counsel for all parties to the dispute—that they are unable to resolve a discovery matter or a dispute relating to a protective order, the parties involved in the discovery matter or protective order dispute shall submit a joint letter in substantially the following form: Dear Judge Bibas: The parties in the above­referenced matter write to request the scheduling of a discovery teleconference. The following attorneys, including at least one Delaware Counsel and at least one Lead Counsel per party, participated in a verbal meet-and-confer (in person and/or by telephone) on [INSERT DATES]. The disputes requiring judicial attention are listed below: [A NON-ARGUMENTATIVE LIST OF DISPUTES REQUIRING JUDICIAL ATTENTION]

Summary: Joint letter in specified form required to request discovery teleconference after good faith meet and confer with required participant representation.

Document Type

Joint Discovery Letter

Specific requirements detailed in rule text.
Scheduling Order · p. 4
|Secg. Discovery Matters and Disputes Relating to Protective Orders
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Within three days thereafter, the moving party may file a reply letter, not to exceed two pages, and, by this same date, the parties shall file a letter requesting a teleconference to address the motion to amend.

Summary: Parties must file a teleconference request letter for motion to amend by the reply letter deadline.

Document Type

Letter

Specific requirements detailed in rule text.
Scheduling Order · p. 5
|Sec5. Motions to Amend
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Within three days thereafter, the moving party may file a reply letter, not to exceed two pages, and, by this same date, the parties shall file a letter requesting a teleconference to address the motion to strike.

Summary: Parties must file a teleconference request letter for motion to strike by the reply letter deadline.

Document Type

Letter

Specific requirements detailed in rule text.
Scheduling Order · p. 6
|Sec6. Motions to Strike
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Any proposed protective order must include the following paragraph: Other Proceedings. By entering this order and limiting the disclosure of information in this case, the Court does not intend to preclude another court from finding that information may be relevant and subject to disclosure in another case. Any person or party subject to this order who becomes subject to a motion to disclose another party's information designated "confidential" [the parties should list any other level of designation, such as "highly confidential," which may be provided for in the protective order] pursuant to this order shall promptly notify that party of the motion so that the party may have an opportunity to appear and be heard on whether that information should be disclosed.

Summary: Proposed protective orders must include the specified 'Other Proceedings' paragraph.

Document Type

Proposed Protective Order

Specific requirements detailed in rule text.
Scheduling Order · p. 6
|Sec7. Application to Court for Protective Order
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Any non-dispositive motion should contain the statement required by Local Rule 7.1.1.

Summary: Non-dispositive motions must include the statement required by Local Rule 7.1.1.

Document Type

Non Dispositive Motion

Content & Formatting
Local Rule Certificate
Scheduling Order · p. 7
|Sec§ G. Applications by Motion
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

11. Interim Status Report. On ___, 2021, counsel shall submit a joint letter to the Court with an interim report on the nature of the matters in issue and the progress of discovery to date. Then, if the Court deems it necessary, it will schedule a status conference.

Summary: Counsel must submit a joint interim status letter by a specified 2021 date, including an interim report on the issues and discovery progress.

Document Type

Letter

Specific requirements detailed in rule text.
Scheduling Order · p. 7
|Sec§ G. Interim Status Report
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Motions in limine shall not be separately filed. All in limine requests and responses thereto shall be set forth in the proposed pretrial order.

Summary: Motions in limine must be included in the proposed pretrial order, not filed separately.

Document Type

Motions In Limine

Specific requirements detailed in rule text.
Scheduling Order · p. 8
|Sec§ G. Motions in Limine
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

The parties shall file with the Court the joint proposed final pretrial order with the information required by the form of Final Pretrial Order which accompanies this Scheduling Order on or before ___, 2021.

Summary: Parties must file a joint proposed final pretrial order with the required form information by a specified 2021 date.

Document Type

Pretrial Order

Specific requirements detailed in rule text.
Scheduling Order · p. 8
|Sec§ G. Pretrial Conference
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

The in limine request and any response shall contain the authorities relied upon;

Summary: In limine requests and responses must include all authorities relied upon.

Document Type

Motions In Limine

Specific requirements detailed in rule text.
Scheduling Order · p. 8
|Sec§ G. Motions in Limine

Filing & Service rules

Filing Timing and Cure Windows

Pre-motion letter tolls motion/answer deadline until conference or Court decision; if no conference, additional 7 days after Rule 12(a) deadline.

A party's submission of a pre-motion letter will toll that party's time to file its motion (or answer) through (i) the date of the pre-motion conference or (ii) the Court's decision not to conduct such a conference. If the Court determines that a pre-motion conference would not be helpful and instructs a party to proceed with filing its proposed motion without a conference, that party shall have an additional seven days to file after its Fed. R. Civ. P. 12(a) deadline, unless additional time is stipulated or the Court so orders.

Machine summary. Not checked yet. · Civil cases

Page 1 | Civil Pre-Motion Conference

Courtesy Copy Requirements

No courtesy copies are required for briefs, supporting documents, or papers filed under seal.

9. Courtesy Copies. The parties need not provide to the Court any courtesy copies of briefs, any other document filed in support of any briefs (such as appendices, exhibits, declarations, and affidavits), or papers filed under seal.

Machine summary. Not checked yet. · Civil cases

Page 7 | § G. Courtesy Copies

Sealing & Redaction Procedures

Redacted version of sealed documents must be filed electronically within 7 days of filing the sealed document.

A redacted version of any sealed document shall be filed electronically within seven days of the filing of the sealed document.

Machine summary. Not checked yet. · Civil cases

Page 6 | 8. Papers Filed Under Seal

Filing Bundling Requirements

No separate briefing on in limine requests is permitted; submissions must be combined, unless the Court allows otherwise.

No separate briefing shall be submitted on in limine requests, unless otherwise permitted by the Court.

Machine summary. Not checked yet. · Civil cases

Page 9 | Motions in Limine

Pre-Motion Conference Requirements

Before filing certain motions, parties must submit a pre-motion letter (max 3 pages single-spaced) with basis and citations; adversaries respond within 7 days (max 3 pages single-spaced); no reply unless directed; affidavits/exhibits not permitted; Court may hold teleconference; if unresolved, motion may be filed.

In an effort to resolve cases expeditiously, before bringing a motion to dismiss, motion for a more definite statement, motion to remand, motion for change of venue, or motion for judgment on the pleadings, a party must submit a letter, not to exceed three single-spaced pages, requesting a pre-motion conference. The letter must set forth the basis for the anticipated motion and include citations to relevant authority. Within seven days after receipt of this letter, all adversaries must submit a written response, not to exceed three single-spaced pages. No party may submit a reply letter unless directed by the Court. Affidavits and exhibits are not permitted unless directed by the Court. A proffer by the attorney, however, of the contents of any such affidavit or exhibit shall suffice. To the extent possible, the Court will attempt to resolve the dispute at a pre-motion teleconference. If the dispute cannot be resolved at the pre-motion conference (or if the Court determines that a conference would not be helpful), the moving party may proceed with filing its motion.

Machine summary. Not checked yet. · Civil cases

Page 1 | Civil Pre-Motion Conference

Counsel must confer, agree on proposed protective order, and submit within 10 days of this Order; if no agreement, follow Paragraph 3(g).

Should counsel find it will be necessary to apply to the Court for a protective order specifying terms and conditions for the disclosure of confidential information, counsel should confer and attempt to reach an agreement on a proposed form of order and submit it to the Court within ten days from the date of this Order. Should counsel be unable to reach an agreement on a proposed form of order, counsel must follow the provisions of Paragraph 3(g) above.

Machine summary. Not checked yet. · Civil cases

Page 6 | 7. Application to Court for Protective Order

Chambers Communication Rules

Parties must email Word (DOCX) versions of proposed voir dire, jury instructions, and special verdict forms to Chambers.

The parties should also email Word versions of each document to Chambers.

Machine summary. Not checked yet. · Civil cases

Page 9 | Jury Instructions, Voir Dire, and Special Verdict Forms

About United States District Judge Stephanos Bibas

Visiting Judge Active: Yes

[Skip to main content](https://www.ded.uscourts.gov/judge/judge-stephanos-bibas#main-content) ## You are here - [Home](https://www.ded.uscourts.gov/) United States Court of Appeals for the Third Circuit

Common questions about Judge Stephanos Bibas's rules

Are courtesy copies required for Judge Stephanos Bibas?

The rule limits courtesy-copy delivery rather than stating a blanket requirement before Judge Stephanos Bibas. No courtesy copies are required for briefs, supporting documents, or papers filed under seal.

View ruleSource: page 7, section § G. Courtesy Copies

Does Judge Stephanos Bibas require a pre-motion conference or letter before filing a motion?

Yes. A pre-motion letter is required for rule 12, remand, and venue change. Details: 3 pages, response due in 7 days. Before filing certain motions, parties must submit a pre-motion letter (max 3 pages single-spaced) with basis and citations; adversaries respond within 7 days (max 3 pages single-spaced); no reply unless directed; affidavits/exhibits not permitted; Court may hold teleconference; if unresolved, motion may be filed.

View ruleSource: page 1, section Civil Pre-Motion Conference

What page or word limits apply to letter before Judge Stephanos Bibas?

Judge Stephanos Bibas' rule states these limits: attorney: 3 pages. Response to pre-motion letter limited to 3 single-spaced pages.

View ruleSource: page 1, section Civil Pre-Motion Conference

What page or word limits apply to brief before Judge Stephanos Bibas?

Judge Stephanos Bibas' rule states these limits: attorney: 3 pages; attorney: 3 pages. In limine support and opposition arguments are each limited to 3 pages.

View ruleSource: page 8, section § G. Motions in Limine

What formatting rules apply to filings before Judge Stephanos Bibas?

Judge Stephanos Bibas' formatting rule includes file format docx. Emailed copies of proposed voir dire, jury instructions, and special verdict forms sent to Chambers must be in Word (DOCX) format.

View ruleSource: page 9, section Jury Instructions, Voir Dire, and Special Verdict Forms

What must be included with joint discovery letter filings before Judge Stephanos Bibas?

The rule identifies required filing content or certificates. Joint letter in specified form required to request discovery teleconference after good faith meet and confer with required participant representation.

View ruleSource: page 4, section g. Discovery Matters and Disputes Relating to Protective Orders

What must be included with proposed protective order filings before Judge Stephanos Bibas?

The rule identifies required filing content or certificates. Proposed protective orders must include the specified 'Other Proceedings' paragraph.

View ruleSource: page 6, section 7. Application to Court for Protective Order

How may parties contact Judge Stephanos Bibas' chambers?

The rule addresses email communications with Judge Stephanos Bibas' chambers. Parties must email Word (DOCX) versions of proposed voir dire, jury instructions, and special verdict forms to Chambers.

View ruleSource: page 9, section Jury Instructions, Voir Dire, and Special Verdict Forms

How does Judge Stephanos Bibas handle sealed or redacted filings?

Judge Stephanos Bibas's rules set procedures for sealed or redacted filings. Process: file redacted on ecf. Redacted version of sealed documents must be filed electronically within 7 days of filing the sealed document.

View ruleSource: page 6, section 8. Papers Filed Under Seal

Does Judge Stephanos Bibas require motion papers to be bundled?

Yes. Judge Stephanos Bibas requires bundling for covered papers. No separate briefing on in limine requests is permitted; submissions must be combined, unless the Court allows otherwise.

View ruleSource: page 9, section Motions in Limine

What filing deadlines apply to letter filings before Judge Stephanos Bibas?

Pre-motion letter tolls motion/answer deadline until conference or Court decision; if no conference, additional 7 days after Rule 12(a) deadline.

View ruleSource: page 1, section Civil Pre-Motion Conference
Complete rules summary for Judge Stephanos Bibas

Before filing certain motions, parties must submit a pre-motion letter (max 3 pages single-spaced) with basis and citations; adversaries respond within 7 days (max 3 pages single-spaced); no reply unless directed; affidavits/exhibits not permitted; Court may hold teleconference; if unresolved, motion may be filed.

Response to pre-motion letter limited to 3 single-spaced pages.

Pre-motion letter tolls motion/answer deadline until conference or Court decision; if no conference, additional 7 days after Rule 12(a) deadline.

Joint letter in specified form required to request discovery teleconference after good faith meet and confer with required participant representation.

Letters filed in connection with discovery teleconferences are limited to 3 pages for both seeking relief and opposing parties.

Letter accompanying motion to amend must not exceed 3 pages.

Responsive letter opposing motion to amend must not exceed 5 pages.

Reply letter for motion to amend must not exceed 2 pages.

Letter accompanying motion to strike must not exceed 3 pages.

Reply letter for motion to strike must not exceed 2 pages.

Proposed protective orders must include the specified 'Other Proceedings' paragraph.

Counsel must confer, agree on proposed protective order, and submit within 10 days of this Order; if no agreement, follow Paragraph 3(g).

Redacted version of sealed documents must be filed electronically within 7 days of filing the sealed document.

Parties must file a teleconference request letter for motion to amend by the reply letter deadline.

Parties must file a teleconference request letter for motion to strike by the reply letter deadline.

No courtesy copies are required for briefs, supporting documents, or papers filed under seal.

Counsel must submit a joint interim status letter by a specified 2021 date, including an interim report on the issues and discovery progress.

Non-dispositive motions must include the statement required by Local Rule 7.1.1.

Parties must file a joint proposed final pretrial order with the required form information by a specified 2021 date.

Motions in limine must be included in the proposed pretrial order, not filed separately.

In limine requests and responses must include all authorities relied upon.

In limine support and opposition arguments are each limited to 3 pages.

Reply briefs in support of in limine requests are limited to 1 additional page, unless otherwise ordered by the Court.

When multiple parties support or oppose an in limine request, their submissions must be combined into a single 3-page brief; moving party reply in such cases is limited to 1 page, unless otherwise ordered by the Court.

No separate briefing on in limine requests is permitted; submissions must be combined, unless the Court allows otherwise.

Parties must email Word (DOCX) versions of proposed voir dire, jury instructions, and special verdict forms to Chambers.

Emailed copies of proposed voir dire, jury instructions, and special verdict forms sent to Chambers must be in Word (DOCX) format.

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