Court Rules
Magistrate Judge

Judge Caroline Goldner Cinquanto

Individual Rules, Standing Orders & Policies

Eastern District of Pennsylvania

Limits & Logistics

Document Limits

Memorandum
30 pgs
Case Synopsis
5 pgs
Synopsis Attachments
30 pgs
Motion
30 pgs

Courtesy Copies

All filings

  • Hand Delivery • In Advance Of Court

Courtesy copies

  • 2 copies • Before Trial

Adjournments

  • Deadlines must be strictly followed unless compelling reason exists.
  • Adjournments for additional settlement authority may result in sanctions including opposing party's attorney fees.
  • Telephone attendance not acceptable without prior approval; sanctions may apply for adjournments.
  • +1 more

Request must include

Reason For RequestProposed New DatesAdversary Position

Communication

Letter via ECF

Chambers

Scheduling
No status inquiries
Email

Chambers

SchedulingTechnical IssuesDiscovery Disputes
No status inquiries
Phone

Chambers

Emergencies
No status inquiries
Phone

Opposing Party

Discovery Disputes
No status inquiries
Conference

Opposing Counsel

SettlementNarrowing Disputes
Conference

Court

Pretrial ConferenceSettlement Authority
Letter via ECF

Court

Settlement Notification
Filters:AllMandatoryImportantFormattingSettlementConferencesExhibitsMemorandaJuryTOC/TOADiscovery

Page & Word Limits5 rules

Page Limits

Machine summary. Not checked yet.Mandatory?

• Counsel for all parties must submit the attached summary and their confidential case synopsis to Chambers_of_Magistrate_Judge_Goldner_Cinquanto@paed.uscourts.gov on or before [two weeks before the conference]. The synopsis should be no more than five (5) pages in length, single spaced.

Summary: Case synopsis (max 5 pages, single spaced) due 2 weeks before conference.

Case Synopsis

5 pages

Applies to: Attorney

cgcpol · p. 12
|SecMODEL SETTLEMENT CONFERENCE ORDER
Page Limits

Machine summary. Not checked yet.Mandatory?

• The synopsis should attach key summary expert reports, policy language excerpts, photographs, sketches, diagrams, charts, etc. Only attach excerpts which are most relevant to the claims at issue. Relevant portions must be delineated. Attachments should be no more than thirty (30) pages and should be separated with labeled divider pages.

Summary: Attachments to synopsis limited to 30 pages with labeled dividers.

Synopsis Attachments

30 pages

Applies to: Attorney

cgcpol · p. 12
|SecMODEL SETTLEMENT CONFERENCE ORDER
Page Limits

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Briefs accompanying motions and responses to motions are limited to thirty pages absent leave of Court. Any reply brief is limited to the issues raised in the response, may not raise theories or issues not discussed in the original motion, and shall not exceed fifteen pages absent leave of Court.

Summary: Motion briefs limited to 30 pages, reply briefs to 15 pages.

30 pages

Applies to: Attorney

Reply Brief

15 pages

Applies to: Attorney

cgcpol · p. 16
|SecSCHEDULING ORDER
Page Limits

Machine summary. Not checked yet.Mandatory?

Memoranda must not exceed 30 pages in length (excluding table of contents and appendices), must be double spaced, and must use 12-point font. Memoranda over 15 pages in length must include a table of contents and table of authorities.

Summary: Memoranda limited to 30 pages (excluding TOC/appendices), double-spaced, 12-point font; TOC and TOA required for memos over 15 pages.

Memorandum

30 pages

Applies to: Attorney

30 pages

Applies to: Pro Se

Page Limits

Machine summary. Not checked yet.Mandatory?

The synopsis should attach key summary expert reports, policy language excerpts, photographs, sketches, diagrams, charts, etc. Only attach excerpts which are most relevant to the claims at issue. Relevant portions must be delineated. Attachments should be no more than thirty (30) pages and should be separated with labeled divider pages Judge Goldner Cinquanto may require hard copies of lengthy materials.

Summary: Settlement conference synopsis limited to 5 pages single-spaced with max 30 pages of attachments.

Settlement Conference Synopsis

Document Format Requirements1 rule

Formatting

Machine summary. Not checked yet.Mandatory?

Counsel are expected to confer about exhibits and provide Joint Exhibits (marked J-1, etc.) and additional exhibits (marked as P-1 or D-1, etc.).

Summary: Joint Exhibits must be marked J-1, etc.; additional exhibits marked P-1/D-1

cgcpol · p. 22
|SecExhibit Marking Requirements

Document Filing Requirements49 rules

Filing Requirements

Machine summary. Not checked yet.Mandatory?

Whether proceeding by Joint Pretrial Stipulation or complying with Local Rule 16.1, the parties jointly must: 1. File one document titled 'Proposed Joint Voir Dire Questions' containing three sections: (1) agreed voir dire questions; (2) additional questions proposed by Plaintiff(s); and (3) additional questions proposed by Defendant(s).

Summary: Joint voir dire questions document with three sections must be filed.

Document Type

Proposed Joint Voir Dire Questions

Content & Formatting
Caption
Case Number
Judge Name
cgcpol · p. 8
|SecG. Pretrial Procedure
Filing Requirements

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3. File one document titled 'Proposed Joint Jury Verdict Form,' containing: (1) an agreed verdict form; and, if necessary, (2) any alternative verdict form Plaintiff(s) propose; and (3) any alternative verdict form Defendant(s) propose.

Summary: Joint jury verdict form document with agreed and alternative forms must be filed.

Document Type

Proposed Joint Jury Verdict Form

Content & Formatting
Caption
Case Number
Judge Name
cgcpol · p. 8
|SecG. Pretrial Procedure
Filing Requirements

Machine summary. Not checked yet.Mandatory?

2. File one document titled 'Proposed Joint Jury Instructions,' containing three sections: (1) agreed jury instructions; (2) additional instructions proposed by Plaintiff(s); and (3) additional questions proposed by Defendant(s). Third Circuit standard instructions should be used, if available. Parties must cite the underlying authority for each instruction they propose, even if using the Third Circuit model.

Summary: Joint jury instructions document with three sections must be filed, citing authority for each instruction.

Document Type

Proposed Joint Jury Instructions

Content & Formatting
Caption
Case Number
Judge Name
cgcpol · p. 8
|SecG. Pretrial Procedure
Filing Requirements

Machine summary. Not checked yet.Mandatory?

The three jointly filed documents must be filed on ECF at the same time as Pretrial Memoranda [or Pretrial Stipulation]. At the time of filing the parties must submit to chambers an electronic version of the three documents, in Word format.

Summary: Three pretrial documents must be filed on ECF simultaneously and submitted to chambers in Word format.

Document Type

Pretrial Documents

Content & Formatting
Caption
Case Number
Judge Name
cgcpol · p. 8
|SecG. Pretrial Procedure
Filing Requirements

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• Plaintiff(s) must make a precise and specific written settlement demand, inclusive of all attorney’s fees, costs, and damages, on or before [three weeks before the conference].

Summary: Plaintiff must submit written settlement demand 3 weeks before conference.

Document Type

Settlement Demand

Content & Formatting
Caption
Case Number
cgcpol · p. 12
|SecMODEL SETTLEMENT CONFERENCE ORDER
Filing Requirements

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• Defendant(s) must make a precise and specific written settlement offer on or before [two weeks before the conference].

Summary: Defendant must submit written settlement offer 2 weeks before conference.

Document Type

Settlement Offer

Content & Formatting
Caption
Case Number
cgcpol · p. 12
|SecMODEL SETTLEMENT CONFERENCE ORDER
Filing Requirements

Machine summary. Not checked yet.Mandatory?

In addition to filing the proposed jury instructions and verdict form on the Court’s docket, the parties must e-mail Word versions of the documents to Chambers_of_Magistrate_Judge_Goldner_Cinquanto@paed.uscourts.gov.

Summary: Parties must email Word versions of proposed jury instructions and verdict form to chambers.

Document Type

Jury Instructions

Specific requirements detailed in rule text.
cgcpol · p. 18
|Secjury instructions and verdict form
Filing Requirements

Machine summary. Not checked yet.Mandatory?

The Joint Pretrial Stipulation shall be signed by trial counsel for each party and shall set forth: (1) a realistic, good faith estimate of the total time for trial; (2) the parties’ agreed-upon facts and their disputed facts; (3) their respective claims and defenses; (4) the relief sought; (5) a list of lay and expert witnesses that identifies the subject(s) of their expected testimony and any expected objections to admissibility; (6) a list of exhibits to be used or introduced into evidence and any objections to their authenticity; (7) a summary of applicable law, including, in diversity cases, the basis for choosing the applicable law; and (8) any other disclosures required under Federal Rule of Civil Procedure 26(a)(3).

Summary: Joint Pretrial Stipulation must include 8 specific elements

Document Type

Joint Pretrial Stipulation

Content & Formatting
Exhibit List
Legal Argument
cgcpol · p. 21
|SecPretrial Stipulation Requirements
Filing Requirements

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findings of fact and conclusions of law, with citations to relevant authority, on or before [fourteen days prior to date certain]. Counsel shall also provide binders containing two copies of their exhibits, marked for trial.8 All objections to the authenticity of exhibits are waived unless noted in the Pretrial Stipulation.

Summary: Findings of fact and conclusions of law due 14 days before trial with 2 exhibit copies

Document Type

Pretrial Stipulation

Content & Formatting
Exhibit List
cgcpol · p. 21
|SecPretrial Stipulation Requirements
Filing Requirements

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Joint Appendix: A party who plans to file a motion for summary judgment must meet and confer with all other parties and develop a single, joint appendix of all exhibits that may be referenced in their respective memoranda. All pages of the joint appendix must be consecutively numbered with an appendix page number. Page references in the memoranda must be to the appendix page number, not internal document page numbers. The joint appendix must include a table of contents. The joint appendix must be filed by the movant no later than the date the initial motion for summary judgment is docketed.

Summary: Joint appendix required for summary judgment motions, consecutively numbered, with TOC, filed by movant when motion is docketed.

Document Type

Summary Judgment Motion

Content & Formatting
Exhibit List
Filing Requirements

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Rule 26.1(f) of the Eastern District of Pennsylvania Local Rules of Civil Procedure also requires discovery motions to include "a certification of counsel that the parties, after reasonable effort, are unable to resolve the dispute."

Summary: Local Rule 26.1(f) requires certification that parties are unable to resolve discovery dispute after reasonable effort.

Document Type

Discovery Motion

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

If a party requires approval by an insurer to settle, a representative of the insurer with full and complete settlement authority consistent with the most recent demand must be present in addition to the relevant party principal.

Summary: Insurer representatives with settlement authority must attend if insurer approval is required.

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

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Exhibits are to be provided to the Court in the form of two jointly prepared loose leaf exhibit books—one for the judge and one for her law clerk—each book containing tabbed Joint Exhibits, Plaintiffs Exhibits, and Defendant’s Exhibits.

Summary: Exhibits must be provided in two tabbed loose leaf books (judge and law clerk copies).

Document Type

Pretrial Stipulation

Content & Formatting
Exhibit List
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Judge Goldner Cinquanto requires a principal for each party with an interest in the case who has full and complete settlement authority (i.e., authority consistent with the most recent demand) to be present (either on the Zoom, or in person, as applicable) for the entire duration of the conference.

Summary: Settlement conference requires principals with full settlement authority to be present for entire duration.

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Judge Goldner Cinquanto expects counsel to: Organize and bring critical evidence (policy language, photographs, sketches, diagrams, charts, etc.) to the conference. Judge Goldner Cinquanto may want to see them.

Summary: Counsel must bring critical evidence including policy language, photographs, sketches, diagrams, and charts.

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Memoranda over 15 pages in length must include a table of contents and table of authorities.

Summary: Memoranda over 15 pages require table of contents and table of authorities.

Document Type

Memorandum

Content & Formatting
Table Of Authorities
Table Of Contents
Filing Requirements

Machine summary. Not checked yet.Mandatory?

The request shall: (1) describe the parties’ prior efforts to resolve their dispute in detail; (2) summarize the matters in dispute; and (3) attach any information relevant to Judge Goldner Cinquanto’s consideration of the dispute.

Summary: Discovery dispute request must describe prior efforts, summarize matters in dispute, and attach relevant information.

Document Type

Discovery Dispute Request

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Counsel for all parties must submit a confidential settlement summary and case synopsis via email (to Chambers_of_Magistrate_Judge_Goldner_Cinquanto@paed.uscourts.gov) two weeks before the conference. The case synopsis should be no more than five-pages in length.

Summary: Confidential settlement summary (max 5 pages) due 2 weeks before conference.

Document Type

Settlement Summary

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Defendant(s) must make an updated, precise, and specific written settlement offer at least two weeks before the conference.

Summary: Defendant must submit settlement offer at least 2 weeks before conference.

Document Type

Settlement Offer

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Every assertion of fact in a memorandum must be supported by a citation to the record where that fact may be found. Both legal citations and citations to the record must include pinpoint cites.

Summary: Every factual assertion in memoranda must be supported by pinpoint citations to the record.

Document Type

Memorandum

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Federal Rule of Civil Procedure 37 requires parties who file discovery motions to certify "that the movant has in good faith conferred or attempted to confer with the person or party failing to make disclosure or discovery in an effort to obtain it without court action."

Summary: Rule 37 requires certification of good faith conferment before filing discovery motions.

Document Type

Discovery Motion

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Judge Goldner Cinquanto requires a principal for each party with an interest in the case who has full and complete settlement authority (i.e., authority consistent with the most recent demand) to be present (either on the Zoom, or in person, as applicable) for the entire duration of the conference. If a party requires approval by an insurer to settle, a representative of the insurer with full and complete settlement authority consistent with the most recent demand must be present in addition to the relevant party principal.

Summary: Principal with full settlement authority must attend entire settlement conference.

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Any attorney for a party or any pro se party who uses generative artificial intelligence ("A.I.") to prepare any complaint, answer, motion, brief, or other paper filed with the Court in a matter assigned to Judge Goldner Cinquanto shall: (1) disclose that generative artificial intelligence was used to prepare the filing; (2) identify precisely what portion or portions of the filing was generated by A.I.; (3) identify the A.I. tool that was used; and (4) certify that each and every citation to the law or the record in the filing was verified as accurate in accordance with the obligations set forth in Rule 11 of the Federal Rules of Civil Procedure.

Summary: AI disclosure and certification required for all filings, including identifying AI tool, portions generated, and verifying citations.

Document Type

Any Filing

Content & Formatting
Ai Disclosure
Filing Requirements

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Judge Goldner Cinquanto expects counsel to: Be prepared to be present for the entire day (with their client(s)) for as long as needed to make substantial progress towards a mutually agreeable resolution.

Summary: Counsel must be prepared to attend entire settlement conference day with clients.

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Plaintiff(s) must make an updated, precise, and specific written settlement demand, inclusive of all attorney’s fees, costs, and damages, at least three weeks before a scheduled settlement conference.

Summary: Plaintiff must submit settlement demand at least 3 weeks before conference.

Document Type

Settlement Demand

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

If a Rule 26(f) report is not already on the docket when a case is assigned to Judge Goldner Cinquanto, the parties shall submit a copy of their Rule 26(f) report via email (to Chambers_of_Magistrate_Judge_Goldner_Cinquanto@paed.uscourts.gov) at least five days before the scheduled conference.

Summary: Rule 26(f) report must be emailed to chambers at least 5 days before scheduling conference if not already on docket.

Document Type

Scheduling Conference

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Important?

Any requests shall state whether it is made with the other party’s consent. Responses to all motions are due within the period prescribed by Local Rule 7.1(c).

Summary: All requests must state if made with other party's consent.

Document Type

Motion

Specific requirements detailed in rule text.
cgcpol · p. 16
|SecSCHEDULING ORDER
Filing Requirements

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Any objections to anticipated testimony or exhibits shall describe with particularity the ground and the authority for the objection.

Summary: Objections must describe ground and authority with particularity

Document Type

Pretrial Stipulation

Specific requirements detailed in rule text.
cgcpol · p. 21
|SecPretrial Stipulation Requirements
Filing Requirements

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All objections to the authenticity of exhibits are waived unless noted in the Pretrial Stipulation.

Summary: Exhibit authenticity objections waived unless noted in Pretrial Stipulation

Document Type

Pretrial Stipulation

Specific requirements detailed in rule text.
cgcpol · p. 21
|SecPretrial Stipulation Requirements
Filing Requirements

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[Counsel shall comply with the format prescribed in my Practices and Procedures].

Summary: Voir dire questions, jury instructions, and verdict form must follow format in Practices and Procedures.

Document Type

Pretrial Stipulation

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Important?

Any objections to exhibits shall describe with particularity the ground and the authority for the objection.

Summary: Objections to exhibits must describe with particularity the ground and authority.

Document Type

Pretrial Stipulation

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Important?

Parties who intend to use video equipment to present the testimony of a witness should either supply that equipment or request, at least two weeks before trial, that the Court reserve equipment for them by email to Chambers_of_Magistrate_Judge_Goldner_Cinquanto@paed.uscourts.gov.

Summary: Video equipment requests must be made at least two weeks before trial via email.

Document Type

Pretrial Stipulation

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Important?

Failure to comply with this policy may result in consequences such as referral to the appropriate state bar, monetary sanctions, or any other sanction the Court deems appropriate.

Summary: Non-compliance with AI policy may result in bar referral, monetary sanctions, or other sanctions.

Document Type

Any Filing

Content & Formatting
Ai Disclosure
Filing Requirements

Machine summary. Not checked yet.Important?

Any objections to anticipated testimony shall describe with particularity the ground and the authority for the objection.

Summary: Objections to anticipated testimony must describe with particularity the ground and authority.

Document Type

Pretrial Stipulation

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Important?

The synopsis should attach key summary expert reports, policy language excerpts, photographs, sketches, diagrams, charts, etc., to the conference memos. Judge Goldner Cinquanto will review them. Please attach only those excerpts which are most relevant to the claims at issue. Relevant portions must be delineated. Attachments should be no more than 30 pages and should be separated with labeled divider pages.

Summary: Attachments to settlement summary limited to 30 pages with labeled dividers.

Structured details unavailable. See the source text.

Filing Requirements

Machine summary. Not checked yet.Note?

The parties should ordinarily expect to file a joint pretrial stipulation, in the form attached, in lieu of complying with Eastern District of Pennsylvania Local Rule 16.1, which otherwise governs pretrial procedure.

Summary: Joint pretrial stipulation is preferred over Local Rule 16.1 for pretrial procedure.

Document Type

Pretrial Stipulation

Content & Formatting
Caption
Case Number
Judge Name
cgcpol · p. 8
|SecG. Pretrial Procedure
Filing Requirements

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The Joint Pretrial Stipulation should also alert the Court of any unusual legal issues which would serve as the basis for a motion for a judgment as a matter of law under Federal Rule of Civil Procedure 50 or any other dispositive motions with citations to relevant legal authority.

Summary: Unusual legal issues for JMOL or dispositive motions must be cited in Pretrial Stipulation

Document Type

Joint Pretrial Stipulation

Specific requirements detailed in rule text.
cgcpol · p. 21
|SecPretrial Stipulation Requirements
Filing Requirements

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of Civil Procedure for this District and this Court’s Policies and Procedures. Both are available through the website for the Eastern District of Pennsylvania (https://www.paed.uscourts.gov/).

Summary: Local Rules and Court Policies available at Eastern District of Pennsylvania website

Document Type

Local Rules

Specific requirements detailed in rule text.
cgcpol · p. 22
|SecLocal Rules Reference
Filing Requirements

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Judge Goldner Cinquanto may require parties to provide hard copies of lengthy materials.

Summary: Judge may require hard copies of lengthy materials.

Structured details unavailable. See the source text.

Filing Requirements

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If unusual circumstances make it necessary for a party to supplement the joint appendix, the party must move for permission to file a supplemental joint appendix. The supplemental joint appendix must contain the original appendix, add the supplemental materials at the end, continue the appendix page numbering, and provide an updated table of contents.

Summary: Supplemental joint appendix must include original appendix, add materials at end, continue page numbering, and update TOC.

Document Type

Supplemental Joint Appendix

Content & Formatting
Exhibit List
Filing Requirements

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Discovery must be proportional to the needs of the case.

Document Type

Discovery

Specific requirements detailed in rule text.
Filing Requirements

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Judge Goldner Cinquanto expects counsel to: Be prepared to discuss factual and legal points of agreement and disagreement.

Summary: Counsel must be prepared to discuss factual and legal points of agreement and disagreement.

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

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Motion practice is governed by Eastern District of Pennsylvania Local Rule of Civil Procedure 7.1 except as described elsewhere in these Practices and Procedures, the Local Rules and applicable Standing Orders, or, as relevant, the Supplemental Rules for Social Security Actions under 42 U.S.C. § 405(g), or the Rules Governing Section 2254 Cases in the United States District Courts.

Summary: Motion practice governed by EDPA Local Rule 7.1 with exceptions noted in this document and other applicable rules.

Document Type

Motion

Specific requirements detailed in rule text.
Filing Requirements

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Judge Goldner Cinquanto expects counsel to: Be flexible. Avoid bottom lines or top numbers.

Summary: Counsel must be flexible and avoid bottom lines or top numbers.

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Note?

Judge Goldner Cinquanto expects counsel to: Be prepared to discuss the weaknesses, as well as the strengths, of their case.

Summary: Counsel must be prepared to discuss both strengths and weaknesses of their case.

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

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Judge Goldner Cinquanto expects counsel to: Manage their own expectations.

Summary: Counsel must manage their own expectations.

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

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Judge Goldner Cinquanto expects counsel to: Be patient. Settlement is a process. It takes time.

Summary: Counsel must be patient as settlement is a process that takes time.

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

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Judge Goldner Cinquanto expects counsel to: Be creative.

Summary: Counsel must be creative in settlement discussions.

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

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Judge Goldner Cinquanto expects counsel to: Be prepared to discuss any impediments to settlement, whether legal, financial, or emotional.

Summary: Counsel must be prepared to discuss legal, financial, or emotional impediments to settlement.

Document Type

Settlement Conference

Specific requirements detailed in rule text.

Filing & Service rules

Courtesy Copy Requirements

Two exhibit copies required in binders for trial

Counsel shall also provide binders containing two copies of their exhibits, marked for trial.

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Page 21 | Pretrial Stipulation Requirements

All relevant documents must be delivered to Chambers in advance of court.

Judge Goldner Cinquanto requires that all relevant documents be delivered to Chambers in advance of court. Counsel may contact Deputy Jeffrey Lucini at (267.299.7750) if there are any questions regarding the matters before the Court.

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Sealing & Redaction Procedures

Motions to seal must clearly explain why secrecy outweighs public access and identify specific injuries from disclosure.

Any motion for leave to file under seal, including any motion for a proposed confidentiality/protective order that would permit a party to file any material under seal, must articulate, clearly and specifically, why the moving party's 'interest in secrecy' outweighs the 'presumptive right of public access.' Avandia, 924 F.3d at 672. The motion—and the proposed order attached to the motion—must identify 'clearly defined and serious injur[ies]' the movant will suffer if the materials are not kept under seal. Id. Judge Goldner Cinquanto will not grant a motion for leave to file under seal that fails to identify the movant's interests in nondisclosure with specificity.

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Page 7 | F. Documents Filed Under Seal

Redacted versions of sealed documents must be filed on public docket unless redactions would make documents unreadable.

Even when Judge Goldner Cinquanto grants a motion for leave to file under seal, she will generally still expect the parties to file redacted versions of the sealed documents on the public docket unless the redactions would be so extensive as to render the document unreadable. Proposed orders attached to motions for leave to file under seal must include language requiring the parties to file redacted versions of the sealed documents to the public docket. If a movant omits this language from its proposed order, the movant must explain in its motion why redaction would render the documents unreadable.

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Page 7 | F. Documents Filed Under Seal

Documents generally require court leave to be filed under seal, except in emergencies.

Except in emergency situations, documents should not be filed under seal without first obtaining leave of court.

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Page 7 | F. Documents Filed Under Seal

Motions to seal must be filed on public docket with redacted copies, and unredacted copies must be provided to court and parties.

All motions for leave to file documents under seal should be filed on the public docket. If a motion contains or refers to information that the movant seeks to file under seal, the movant may redact the relevant information in the copy of the motion filed on the docket. When a movant files a motion with redacted information, the movant must provide the Court and all parties with unredacted copies of all documents that the party proposes to file under seal.

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Page 8 | F. Documents Filed Under Seal

Parties must follow Clerk's general procedures for filing sealed documents.

Parties should also otherwise conform to the Clerk's general procedures for filing documents under seal.

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Page 8 | F. Documents Filed Under Seal

Adjournment & Extension Requirements

Extension requests must be emailed in advance with detailed basis and party positions.

shall request a new deadline or date in advance of the originally scheduled date via email (to Chambers_of_Magistrate_Judge_ Goldner_Cinquanto@paed.uscourts.gov). The request shall describe the basis for the request in detail, state whether all other parties agree or disagree with the request, and identify a suggested new deadline(s) or date(s).

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Deadlines must be strictly followed unless compelling reason exists.

Parties are expected to adhere to all deadlines that the Court has implemented by scheduling order or that are otherwise established by rule or statute absent a compelling reason to justify a change.

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Telephone attendance not acceptable without prior approval; sanctions may apply for adjournments.

Having a client with settlement authority available by telephone is not an acceptable alternative unless compelling circumstances exist and there is prior approval from Judge Goldner Cinquanto. If a conference must be adjourned or continued to allow a party to obtain additional authority up to the most recent demand, that party may incur sanctions, including, but not limited to, payment of the opposing party’s attorney’s fees resulting from a need to reconvene.

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Adjournments for additional settlement authority may result in sanctions including opposing party's attorney fees.

If a conference must be adjourned or continued to allow a party to obtain additional authority up to the most recent demand, that party may incur sanctions, including, but not limited to, payment of the opposing party’s attorney’s fees resulting from a need to reconvene.

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Chambers Communication Rules

Principal with full settlement authority required at final pretrial conference

A principal with full settlement authority shall be in attendance for each party.

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Page 21 | Pretrial Stipulation Requirements

Final pretrial conference 7 days before trial with settlement authority required

A final pretrial conference will be held on [seven days before date certain] at __ a.m./p.m. in Courtroom 3D. Counsel shall confer in advance and shall be prepared to discuss all aspects of their Pretrial Stipulation, including any disputed issues. A principal with full settlement authority shall be in attendance for each party.

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Page 21 | Pretrial Stipulation Requirements

Plaintiff’s counsel must promptly advise Court of any settlement

Plaintiff’s counsel shall promptly advise the Court of any settlement.

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Page 22 | Settlement Notification

Judge will not intervene in discovery disputes without good faith telephone/video conference effort.

Judge Goldner Cinquanto will not entertain a request for judicial intervention if parties or their counsel have exchanged emails or other correspondence but have not made a good faith effort to speak to each other by telephone or video conference regarding a discovery dispute.

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Email chambers to request telephone conference before filing discovery motion after good faith efforts.

If a party still requires Court intervention in a discovery dispute after making good faith efforts to communicate with an opposing party, the requesting party shall email Chambers_of_Magistrate_Judge_Goldner_Cinquanto@paed.uscourts.gov to request a telephone conference before filing any discovery motion on the docket.

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Telephone participation by settlement authority clients is prohibited unless compelling circumstances with prior approval.

Having a client with settlement authority available by telephone is not an acceptable alternative unless compelling circumstances exist and there is prior approval from Judge Goldner Cinquanto (e.g., client is located in another state at the time of the conference).

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Counsel must notify court one week before settlement conference if settlement is not possible.

If settlement is not a real possibility (e.g., if defendant will not make an offer or will offer only nuisance value), counsel shall notify the Court (jointly or individually) to request a brief video conference regarding their status on or before [one week before the conference].

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Notify court by call/email at least 1 week before conference if settlement unlikely.

If settlement is not a real possibility (e.g., if the defendant will not make an offer or will offer only nuisance value), counsel shall notify the Court (jointly or individually) by a call or email to request a brief video conference regarding the lack of settlement possibility at least one week before the scheduled settlement conference.

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Counsel must confer to narrow disputed issues before trial

Counsel should work together to narrow any areas of dispute before trial.

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Page 21 | Pretrial Stipulation Requirements

Correspondence permitted from counsel if copies sent to all other parties.

Judge Goldner Cinquanto permits correspondence from counsel on any matters, so long as all other counsel or unrepresented parties are sent copies of such correspondence.

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Ex parte Zoom conferences available before settlement conference upon request.

If requested by counsel, with no opposition, Judge Goldner Cinquanto is available for ex parte Zoom conferences before the settlement conference. Please contact chambers to arrange a pre-conference video call.

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Counsel may communicate with law clerks on procedural matters; pro se parties limited to mail/email.

Judge Goldner Cinquanto permits communications from counsel, both written and oral, with her law clerks on procedural matters only. Parties who are pro se (do not have counsel) may only communicate by mail or email to the chambers address above, unless otherwise directed.

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About United States Magistrate Judge Caroline Goldner Cinquanto

**Magistrate Judge Caroline Goldner Cinquanto** was sworn in as a Magistrate Judge of the Eastern District of Pennsylvania on May 8, 2025. Judge Goldner Cinquanto received her law degree from Columbus School of Law in 1992 and an LL.M. in Trial Advocacy from Temple University's Beasley School of Law in 1998. She began her legal career as a Judge Advocate in the United States Navy, where she received the Navy-Marine Corps Medal of Commendation and the Navy Achievement Medal, and later returned to service as an Air Force JAG after September 11, 2001. She is a Fellow of the American College of Trial Lawyers and teaches Advanced Trial Advocacy at law school. She also instructs for the National Institute of Trial Advocacy and the Pennsylvania Bar Institute and has taught internationally in China, Poland, and throughout Africa. She is a member of the Emeritus Council for the Pennsylvania Innocence Project. **Education** - Temple University Beasley School of Law, LL.M. (Trial Advocacy), 1998 - Columbus School of Law, J.D., 1992 **Career** - Judge Advocate, United States Navy (including post-9/11 service as Air Force JAG) - Civil trial attorney and private practice - Adjunct professor, Advanced Trial Advocacy - U.S. Magistrate Judge, E.D. Pa. (2025–present)

**Courthouse:** James A. Byrne U.S. Courthouse, 601 Market Street, Philadelphia, PA 19106 **Chambers:** Room 3006 **Phone:** (267) 299-7750 **Email:** Chambers_Of_Magistrate_Judge_Goldner_Cinquanto@paed.uscourts.gov **Chambers Staff** - Courtroom Deputy: Jeffrey Lucini, (267) 299-7750, Jeffrey_Lucini@paed.uscourts.gov

Common questions about Judge Caroline Goldner Cinquanto's rules

Are courtesy copies required for Judge Caroline Goldner Cinquanto?

Courtesy-copy rule applies for all covered filings. Details: delivery in advance of court, by hand delivery. All relevant documents must be delivered to Chambers in advance of court.

What page or word limits apply to memorandum before Judge Caroline Goldner Cinquanto?

Judge Caroline Goldner Cinquanto's rule states these limits: attorney: 30 pages; pro se: 30 pages. Excludes table of contents and appendices. Memoranda limited to 30 pages (excluding TOC/appendices), double-spaced, 12-point font; TOC and TOA required for memos over 15 pages.

What page or word limits apply to case synopsis before Judge Caroline Goldner Cinquanto?

Judge Caroline Goldner Cinquanto's rule states these limits: attorney: 5 pages. Case synopsis (max 5 pages, single spaced) due 2 weeks before conference.

View ruleSource: page 12, section MODEL SETTLEMENT CONFERENCE ORDER

What must be included with settlement conference filings before Judge Caroline Goldner Cinquanto?

The rule requires full day attendance. Counsel must be prepared to attend entire settlement conference day with clients.

What must be included with settlement demand filings before Judge Caroline Goldner Cinquanto?

The rule requires costs, damages, and attorney fees. Plaintiff must submit settlement demand at least 3 weeks before conference.

How may parties contact Judge Caroline Goldner Cinquanto's chambers?

The rule addresses phone communications with Judge Caroline Goldner Cinquanto's chambers. Telephone participation by settlement authority clients is prohibited unless compelling circumstances with prior approval.

How does Judge Caroline Goldner Cinquanto handle sealed or redacted filings?

A motion to seal is required for covered sealed filings before Judge Caroline Goldner Cinquanto. Documents generally require court leave to be filed under seal, except in emergencies.

View ruleSource: page 7, section F. Documents Filed Under Seal

How do I request an adjournment or extension before Judge Caroline Goldner Cinquanto?

Advance notice is not fully stated in the structured details. The request must include reason for request, adversary position, and proposed new dates. Extension requests must be emailed in advance with detailed basis and party positions.

Complete rules summary for Judge Caroline Goldner Cinquanto

Counsel must be patient as settlement is a process that takes time.

Counsel must be flexible and avoid bottom lines or top numbers.

Counsel must be creative in settlement discussions.

Counsel must manage their own expectations.

Correspondence permitted from counsel if copies sent to all other parties.

Counsel must be prepared to discuss legal, financial, or emotional impediments to settlement.

Counsel must be prepared to attend entire settlement conference day with clients.

Counsel may communicate with law clerks on procedural matters; pro se parties limited to mail/email.

Deadlines must be strictly followed unless compelling reason exists.

Plaintiff must submit settlement demand at least 3 weeks before conference.

Defendant must submit settlement offer at least 2 weeks before conference.

Notify court by call/email at least 1 week before conference if settlement unlikely.

Confidential settlement summary (max 5 pages) due 2 weeks before conference.

Counsel must bring critical evidence including policy language, photographs, sketches, diagrams, and charts.

Attachments to settlement summary limited to 30 pages with labeled dividers.

Judge may require hard copies of lengthy materials.

Settlement conference requires principals with full settlement authority to be present for entire duration.

Insurer representatives with settlement authority must attend if insurer approval is required.

Telephone participation by settlement authority clients is prohibited unless compelling circumstances with prior approval.

Adjournments for additional settlement authority may result in sanctions including opposing party's attorney fees.

Counsel must be prepared to discuss both strengths and weaknesses of their case.

Counsel must be prepared to discuss factual and legal points of agreement and disagreement.

Rule 26(f) report must be emailed to chambers at least 5 days before scheduling conference if not already on docket.

Discovery must be proportional to the needs of the case.

Judge will not intervene in discovery disputes without good faith telephone/video conference effort.

Email chambers to request telephone conference before filing discovery motion after good faith efforts.

Discovery dispute request must describe prior efforts, summarize matters in dispute, and attach relevant information.

Rule 37 requires certification of good faith conferment before filing discovery motions.

Local Rule 26.1(f) requires certification that parties are unable to resolve discovery dispute after reasonable effort.

Memoranda limited to 30 pages (excluding TOC/appendices), double-spaced, 12-point font; TOC and TOA required for memos over 15 pages.

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