Judge André M. Espinosa
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- 1 copy • Mail
Adjournments
- Adjournment requests must be filed at least five business days before a scheduled conference.
- Extensions must be requested in writing at least five business days before the deadline.
- Adjournment requests must be made at least 5 business days before conference.
- +3 more
- Extension requests must identify current and proposed dates.
- Extension requests must state whether party consent was obtained.
- After the standard extension window, conference-date extensions require unforeseen emergent circumstances and leave of Court even with consent.
- +2 more
Request must include
Communication
Chambers
Phone
Chambers
Page & Word Limits5 rules
Machine summary. Not checked yet.Mandatory?
the matter shall be brought to the Court’s attention via a joint letter, not to exceed five pages, that sets forth:
Summary: Unresolved discovery disputes must be presented by joint letter limited to five pages.
Joint Discovery Dispute Letter
5 pages
Machine summary. Not checked yet.Mandatory?
Each party shall submit, by email to AME_orders@njd.uscourts.gov, a confidential settlement memorandum of no more than five double-spaced pages no later than five business days before the conference.
Summary: Settlement memoranda limited to 5 double-spaced pages, due 5 business days before conference.
Settlement Memorandum
5 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Each party shall submit, by email to AME_orders@njd.uscourts.gov, a confidential settlement memorandum of no more than five double-spaced pages no later than five business days before the conference.
Summary: Settlement memoranda are limited to five pages.
Settlement Memorandum
5 pages
Machine summary. Not checked yet.Mandatory?
Should counsel fail in their good faith efforts to resolve the dispute by conferring pursuant to Rule 37.1, the matter shall be brought to the Court’s attention via a joint letter, not to exceed five pages, that sets forth: a) the request; b) the response; c) efforts to resolve the dispute; d) the position of the complaining party; e) the position of the responding party; and, if applicable, f) the efforts of a party to contact a non-responsive party to meet and confer and submit the joint letter.
Summary: Discovery dispute joint letters are limited to five pages.
Discovery Dispute Letter
5 pages
Applies to: Attorney
Machine summary. Not checked yet.Important?
Each party shall submit, by email to AME_orders@njd.uscourts.gov, a confidential settlement memorandum of no more than five double-spaced pages no later than five business days before the conference.
Summary: Settlement memorandum limited to 5 double-spaced pages, due 5 business days before settlement conference.
Settlement Memorandum
5 pages
Document Format Requirements1 rule
Machine summary. Not checked yet.Important?
Each party shall submit, by email to AME_orders@njd.uscourts.gov, a confidential settlement memorandum of no more than five double-spaced pages no later than five business days before the conference.
Summary: Settlement memoranda must be double-spaced.
Document Filing Requirements26 rules
Machine summary. Not checked yet.Mandatory?
Motions to amend pleadings must include as an exhibit a black- or red-lined proposed amended complaint, which clearly indicates the proposed changes.
Summary: Motions to amend must attach a blacklined or redlined proposed amended complaint showing the proposed changes.
Document Type
Motion To Amend
Machine summary. Not checked yet.Mandatory?
Pursuant to Local Civil Rule 15.1, motions to amend pleadings must include as an exhibit a black- or red-lined proposed amended complaint, which clearly indicates the proposed changes. Failure to do so will result in administrative termination of the motion.
Summary: Motions to amend must include black/red-lined proposed amended complaint; failure results in administrative termination.
Document Type
Motion To Amend
Machine summary. Not checked yet.Mandatory?
The request shall indicate the current and proposed dates and include a proposed form of order.
Summary: Extension requests must include a proposed order.
Document Type
Extension Request
Machine summary. Not checked yet.Mandatory?
The application must contain a letter indicating consent, a certification of admission and good standing, and a certification of local counsel stating that counsel shall comply with Local Civil Rule 101.1(c).
Summary: A consent-based pro hac vice application must include a consent letter and required certifications, including local counsel's Local Rule 101.1(c) certification.
Document Type
Pro Hac Vice Application
Machine summary. Not checked yet.Mandatory?
(2) an additional version that shall indicate in what respect(s) it differs from Appendix S by bracketing or striking through materials to be deleted and underlining materials to be added.
Summary: If parties submit a non-Appendix S confidentiality order, they must also submit a marked comparison copy showing deletions and additions.
Document Type
Proposed Confidentiality Order
Machine summary. Not checked yet.Mandatory?
A proposed form of order must be submitted.
Summary: Pro hac vice applications must include a proposed order.
Document Type
Pro Hac Vice Application
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(1) a clean version of the proposed order that is ready for signature,
Summary: If parties submit a confidentiality order differing from Appendix S, they must provide a clean signature-ready proposed order.
Document Type
Proposed Confidentiality Order
Machine summary. Not checked yet.Mandatory?
Any such request shall include a proposed order.
Summary: Discovery extension or amended scheduling requests must include a proposed order.
Document Type
Discovery Extension Request
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If admission pro hac vice is sought on consent, the request should be made by informal application filed on CM/ECF. The application must contain a letter indicating consent, a certification of admission and good standing, and a certification of local counsel stating that counsel shall comply with Local Civil Rule 101.1(c). A proposed form of order must be submitted. If not consented, the party making the application must proceed by motion.
Summary: Pro hac vice applications on consent require informal CM/ECF filing with consent letter, admission certification, local counsel certification, and proposed order; if not consented, proceed by motion.
Document Type
Pro Hac Vice Application
Machine summary. Not checked yet.Mandatory?
a) the request; b) the response; c) efforts to resolve the dispute; d) the position of the complaining party; e) the position of the responding party; and, if applicable, f) the efforts of a party to contact a non-responsive party to meet and confer and submit the joint letter.
Summary: The joint discovery dispute letter must include specified content items, including positions of both sides and meet-and-confer efforts.
Document Type
Joint Discovery Dispute Letter
Machine summary. Not checked yet.Mandatory?
Any request for an extension or an amended scheduling order shall indicate the current and proposed dates as well as whether the request is made on consent. Any such request shall include a proposed order.
Summary: Extension/amended scheduling order requests must indicate current/proposed dates, consent status, and include proposed order.
Document Type
Extension Request
Machine summary. Not checked yet.Mandatory?
must include a proposed order and proposed findings of fact and conclusions of law.
Summary: The sealing-related motion/request must include a proposed order and proposed findings of fact and conclusions of law.
Document Type
Motion To Seal
Machine summary. Not checked yet.Mandatory?
must include a proposed order and proposed findings of fact and conclusions of law. Failure to comply with Local Civil Rule 5.3(c) will result in administrative termination of the motion.
Summary: Motions must include proposed order and proposed findings of fact and conclusions of law; failure to comply results in administrative termination.
Document Type
Motion
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Discovery disputes shall proceed in accordance with Local Rules 16.1 and 37.1. Should counsel fail in their good faith efforts to resolve the dispute by conferring pursuant to Rule 37.1, the matter shall be brought to the Court's attention via a joint letter, not to exceed five pages, that sets forth: a) the request; b) the response; c) efforts to resolve the dispute; d) the position of the complaining party; e) the position of the responding party; and, if applicable, f) the efforts of a party to contact a non-responsive party to meet and confer and submit the joint letter.
Summary: Discovery disputes must follow Local Rules 16.1 and 37.1; unresolved disputes brought via joint letter (max 5 pages) with specific content requirements.
Document Type
Discovery Dispute Joint Letter
Machine summary. Not checked yet.Mandatory?
Each party shall submit, by email to AME_orders@njd.uscourts.gov, a confidential settlement memorandum of no more than five double-spaced pages no later than five business days before the conference.
Summary: Each party must submit a confidential settlement memorandum before the settlement conference.
Document Type
Settlement Memorandum
Machine summary. Not checked yet.Mandatory?
The parties shall submit, by email and regular mail, a copy of the joint proposed final pretrial order no later than five business days before the conference.
Summary: Parties must submit a joint proposed final pretrial order before the final pretrial conference.
Document Type
Joint Proposed Final Pretrial Order
Machine summary. Not checked yet.Mandatory?
The parties shall submit, by email and regular mail, a copy of the joint proposed final pretrial order no later than five business days before the conference.
Summary: Joint proposed final pretrial order due 5 business days before conference.
Document Type
Joint Proposed Final Pretrial Order
Machine summary. Not checked yet.Mandatory?
The request shall indicate the current and proposed dates and include a proposed form of order. Counsel should endeavor to seek the consent of all parties prior to making such requests and must note in the request whether consent has been obtained.
Summary: Extension requests must include current and proposed dates, a proposed order, and note whether consent was obtained.
Document Type
Extension Request
Machine summary. Not checked yet.Mandatory?
Pursuant to Local Civil Rule 15.1, motions to amend pleadings must include as an exhibit a black- or red-lined proposed amended complaint, which clearly indicates the proposed changes. Failure to do so will result in administrative termination of the motion.
Summary: Motions to amend must include a black- or red-lined proposed amended complaint showing changes.
Document Type
Motion To Amend
Machine summary. Not checked yet.Mandatory?
Motions to seal must comply with Local Civil Rule 5.3(c) and must include a proposed order and proposed findings of fact and conclusions of law. Failure to comply with Local Civil Rule 5.3(c) will result in administrative termination of the motion.
Summary: Motions to seal must comply with Local Rule 5.3(c) and include a proposed order and proposed findings of fact and conclusions of law.
Document Type
Motion To Seal
Machine summary. Not checked yet.Mandatory?
If admission pro hac vice is sought on consent, the request should be made by informal application filed on CM/ECF. The application must contain a letter indicating consent, a certification of admission and good standing, and a certification of local counsel stating that counsel shall comply with Local Civil Rule 101.1(c). A proposed form of order must be submitted. If not consented, the party making the application must proceed by motion.
Summary: Pro hac vice applications on consent must include consent letter, certifications, and proposed order; if not consented, proceed by motion.
Document Type
Pro Hac Vice Application
Machine summary. Not checked yet.Mandatory?
Any request for an extension or an amended scheduling order shall indicate the current and proposed dates as well as whether the request is made on consent. Any such request shall include a proposed order.
Summary: Discovery extension requests must include current and proposed dates, consent note, and proposed order.
Document Type
Discovery Extension Request
Machine summary. Not checked yet.Important?
Counsel shall make every effort to secure the consent of opposing counsel regarding the request to seal.
Summary: Counsel must make every effort to obtain opposing counsel's consent for a sealing request.
Document Type
Motion To Seal
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The parties are encouraged to use the form discovery confidentiality order found at Appendix S of the Local Rules. If the parties submit their own version of a confidentiality order, which differs from Appendix S, they must submit: (1) a clean version of the proposed order that is ready for signature, and (2) an additional version that shall indicate in what respect(s) it differs from Appendix S by bracketing or striking through materials to be deleted and underlining materials to be added.
Summary: Use Appendix S confidentiality order form; if submitting own version, must provide clean version and version showing differences with brackets/strikes/underscores.
Document Type
Confidentiality Order
Machine summary. Not checked yet.Important?
If the parties submit their own version of a confidentiality order, which differs from Appendix S, they must submit: (1) a clean version of the proposed order that is ready for signature, and (2) an additional version that shall indicate in what respect(s) it differs from Appendix S by bracketing or striking through materials to be deleted and underlining materials to be added.
Summary: If submitting a confidentiality order different from Appendix S, parties must submit a clean version and a version showing changes.
Document Type
Confidentiality Order
Machine summary. Not checked yet.Note?
If admission pro hac vice is sought on consent, the request should be made by informal application filed on CM/ECF.
Summary: When pro hac vice admission is on consent, it should be requested by informal CM/ECF application.
Document Type
Pro Hac Vice Application
Filing & Service rules
Filing Timing and Cure Windows
Joint proposed final pretrial order must be submitted by email and regular mail no later than 5 business days before the final pretrial conference.
The parties shall submit, by email and regular mail, a copy of the joint proposed final pretrial order no later than five business days before the conference.
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Page 3 | 13. Final pretrial conferences
Settlement memorandum must be submitted no later than 5 business days before the settlement conference.
Each party shall submit, by email to AME_orders@njd.uscourts.gov, a confidential settlement memorandum of no more than five double-spaced pages no later than five business days before the conference.
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Page 3 | 12. Settlement conferences
Courtesy Copy Requirements
One courtesy copy is required for submissions over 20 pages and must be sent to chambers by mail or courier.
Courtesy copies. One courtesy copy of all submissions exceeding 20 pages shall be sent by regular mail or other courier addressed to chambers.
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Page 3 | Courtesy copies
Courtesy copies required for submissions over 20 pages.
One courtesy copy of all submissions exceeding 20 pages shall be sent by regular mail or other courier addressed to chambers.
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Page 3 | 11. Courtesy copies
One courtesy copy required for submissions over 20 pages, sent by mail or courier to chambers.
One courtesy copy of all submissions exceeding 20 pages shall be sent by regular mail or other courier addressed to chambers.
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Page 3 | 11. Courtesy copies
Sealing & Redaction Procedures
Settlement and discovery dispute letters under confidentiality order may be emailed to AME_orders@njd.uscourts.gov.
Settlement letters and discovery dispute letters containing information subject to a Discovery Confidentiality Order may be submitted to the Court by email to AME_orders@njd.uscourts.gov.
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Page 2 | Confidential submissions
Pre-Motion Conference Requirements
Formal motions require prior leave from court except for Rule 12 motions, timely remand motions, and those expressly permitted.
Other than motions filed under Federal Rule of Civil Procedure 12, motions to remand within the time provided by 28 U.S.C. § 1447(c), and motions expressly permitted by this Case Management Order, formal motions shall not be filed without prior leave from this Court.
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Page 1 | Formal motions
Formal motions require prior leave of Court except Rule 12 motions, timely remand motions, and motions expressly allowed by the Case Management Order.
Other than motions filed under Federal Rule of Civil Procedure 12, motions to remand within the time provided by 28 U.S.C. § 1447(c), and motions expressly permitted by this Case Management Order, formal motions shall not be filed without prior leave from this Court.
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Page 1 | Formal motions
A pro hac vice application without consent must be filed as a formal motion.
If not consented, the party making the application must proceed by motion.
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Page 2 | Pro hac vice applications
Third-party subpoena enforcement or quash motions do not require meet-and-confer, but still require leave of court before filing.
Motions to secure enforcement of a subpoena or to quash a subpoena involving third parties may be made without meeting and conferring, but counsel must obtain leave of Court before filing any such motion.
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Page 3 | Discovery extensions, disputes, and motions
Discovery motions require leave of court and prior compliance with Local Rules 16.1 and 37.1 before filing.
Discovery motions may be filed only upon leave of Court and only after the parties have proceeded in accordance with Local Rules 16.1 and 37.1.
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Page 3 | Discovery extensions, disputes, and motions
Formal motions (except Rule 12 motions, motions to remand, and motions permitted by this Order) require prior leave of Court.
Other than motions filed under Federal Rule of Civil Procedure 12, motions to remand within the time provided by 28 U.S.C. § 1447(c), and motions expressly permitted by this Case Management Order, formal motions shall not be filed without prior leave from this Court.
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Page 1 | 4. Formal motions
Discovery disputes must be brought to the Court via a joint letter not exceeding five pages with specified content after conferring.
Should counsel fail in their good faith efforts to resolve the dispute by conferring pursuant to Rule 37.1, the matter shall be brought to the Court’s attention via a joint letter, not to exceed five pages, that sets forth: a) the request; b) the response; c) efforts to resolve the dispute; d) the position of the complaining party; e) the position of the responding party; and, if applicable, f) the efforts of a party to contact a non-responsive party to meet and confer and submit the joint letter.
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Page 2 | 10. Discovery extensions, disputes, and motions
Subpoena enforcement/quash motions involving third parties exempt from meet-and-confer but require leave of Court.
Motions to secure enforcement of a subpoena or to quash a subpoena involving third parties may be made without meeting and conferring, but counsel must obtain leave of Court before filing any such motion.
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Page 3 | Subpoena motions
Discovery motions require leave of Court and compliance with Local Rules 16.1 and 37.1 before filing.
Discovery motions may be filed only upon leave of Court and only after the parties have proceeded in accordance with Local Rules 16.1 and 37.1.
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Page 3 | Discovery motions
Adjournment & Extension Requirements
After the standard extension window, conference-date extensions require unforeseen emergent circumstances and leave of Court even with consent.
Thereafter, no extensions of any conference date will be granted except upon a showing unforeseen, emergent circumstances and by leave of Court, even if there is consent of all counsel.
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Page 1 | Extensions
Adjournment requests must be made at least 5 business days before conference.
Adjournment requests must be made no later than five business days before the scheduled conference.
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Page 1 | Adjournments
Extension requests must identify current and proposed dates.
The request shall indicate the current and proposed dates and include a proposed form of order.
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Page 1 | Extensions
Extensions must be requested 5 business days before deadline with current/proposed dates and proposed order; consent of parties required; no extensions for conferences except for emergent circumstances.
Extensions of time as provided in court-ordered schedules must be requested in writing at least five business days prior to the expiration of deadlines. The request shall indicate the current and proposed dates and include a proposed form of order. Counsel should endeavor to seek the consent of all parties prior to making such requests and must note in the request whether consent has been obtained. Thereafter, no extensions of any conference date will be granted except upon a showing unforeseen, emergent circumstances and by leave of Court, even if there is consent of all counsel.
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Page 1 | Extensions
Adjournment requests must be filed at least five business days before a scheduled conference.
Adjournment requests must be made no later than five business days before the scheduled conference.
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Page 1 | Adjournments
Extensions must be requested in writing at least five business days before the deadline.
Extensions of time as provided in court-ordered schedules must be requested in writing at least five business days prior to the expiration of deadlines.
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Page 1 | Extensions
Discovery extension or amended scheduling requests must state current and proposed dates and whether the request is on consent.
Any request for an extension or an amended scheduling order shall indicate the current and proposed dates as well as whether the request is made on consent.
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Page 2 | Discovery extensions, disputes, and motions
Adjournment requests must be made at least five business days before the scheduled conference.
Adjournment requests must be made no later than five business days before the scheduled conference.
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Page 1 | 2. Adjournments
Extension requests must be made in writing at least five business days before the deadline.
Extensions of time as provided in court-ordered schedules must be requested in writing at least five business days prior to the expiration of deadlines.
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Page 1 | 3. Extensions
Extensions of conference dates are only granted for unforeseen emergent circumstances and by leave of Court.
Thereafter, no extensions of any conference date will be granted except upon a showing unforeseen, emergent circumstances and by leave of Court, even if there is consent of all counsel.
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Page 1 | 3. Extensions
Extension requests must state whether party consent was obtained.
Counsel should endeavor to seek the consent of all parties prior to making such requests and must note in the request whether consent has been obtained.
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Page 1 | Extensions
Chambers Communication Rules
All communications must be via CM/ECF; phone calls only for administrative matters; mail/email/fax not accepted unless authorized.
All communications to the Court shall be in writing via CM/ECF. Telephone calls to chambers will be permitted as to administrative matters only or as otherwise directed by the Court. Mail, email, and fax communications will not be accepted or considered unless expressly authorized by the Court.
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Page 1 | Communications with the Court
Communications to the Court must be made in writing through CM/ECF.
All communications to the Court shall be in writing via CM/ECF.
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Page 1 | Communications with the Court
Email communications are not accepted unless expressly authorized by the Court.
Mail, email, and fax communications will not be accepted or considered unless expressly authorized by the Court.
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Page 1 | Communications with the Court
The joint proposed final pretrial order must be emailed to chambers at least five business days before the conference.
The parties shall submit, by email and regular mail, a copy of the joint proposed final pretrial order no later than five business days before the conference.
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Page 3 | Final pretrial conferences
Settlement memoranda must be emailed to chambers at the listed address at least five business days before the conference.
Each party shall submit, by email to AME_orders@njd.uscourts.gov, a confidential settlement memorandum of no more than five double-spaced pages no later than five business days before the conference.
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Page 3 | Settlement conferences
Mail, email, and fax communications are not accepted unless expressly authorized by the Court.
Mail, email, and fax communications will not be accepted or considered unless expressly authorized by the Court.
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Page 1 | 1. Communications with the Court
All communications to the Court must be in writing via CM/ECF.
All communications to the Court shall be in writing via CM/ECF.
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Page 1 | 1. Communications with the Court
Telephone calls to chambers are limited to administrative matters unless the Court directs otherwise.
Telephone calls to chambers will be permitted as to administrative matters only or as otherwise directed by the Court.
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Page 1 | Communications with the Court
Telephone calls to chambers are permitted only for administrative matters or as directed by the Court.
Telephone calls to chambers will be permitted as to administrative matters only or as otherwise directed by the Court.
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Page 1 | 1. Communications with the Court
Confidential settlement and discovery dispute letters may be emailed to chambers at AME_orders@njd.uscourts.gov.
Settlement letters and discovery dispute letters containing information subject to a Discovery Confidentiality Order may be submitted to the Court by email to AME_orders@njd.uscourts.gov.
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Page 2 | Confidential submissions
Settlement and discovery dispute letters with confidential information may be submitted by email to AME_orders@njd.uscourts.gov.
Settlement letters and discovery dispute letters containing information subject to a Discovery Confidentiality Order may be submitted to the Court by email to AME_orders@njd.uscourts.gov.
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Page 2 | 8. Confidential submissions
Settlement memoranda must be submitted by email to AME_orders@njd.uscourts.gov.
Each party shall submit, by email to AME_orders@njd.uscourts.gov, a confidential settlement memorandum of no more than five double-spaced pages no later than five business days before the conference.
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Page 3 | 12. Settlement conferences
Joint proposed final pretrial order must be submitted by email and regular mail.
The parties shall submit, by email and regular mail, a copy of the joint proposed final pretrial order no later than five business days before the conference.
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Page 3 | 13. Final pretrial conferences
Parties must contact Chambers to obtain the model joint final pretrial order.
The parties shall contact Chambers for a model version of the joint final pretrial order applicable to the District Judge assigned to the matter.
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Page 3 | 13. Final pretrial conferences