Eastern District of Pennsylvania Local Rules and Judge Filing Requirements

Joint proposed jury instructions and verdict forms required.

The required pretrial submissions also include jointly proposed jury instructions and verdict sheet, motions in limine, and final pretrial memoranda under Local Civil Rule 16.1(c).

Counsel must identify where each exhibit referenced in a motion or response can be found in the record.

Pretrial memoranda must detail the substance of each witness's testimony, not just identify their role.

Deposition transcripts must be attached to summary judgment motions when cited.

Limited correspondence must include specific situation description and opposing party's position.

Counsel may communicate directly with law clerks on procedural matters.

Judge does not typically give jury copies of written instructions, but may in appropriate cases.

Contact Courtroom Deputy Nancy DeLisle for scheduling inquiries; law clerks may assist if unavailable but cannot provide legal advice.

Re-cross examination only allowed when new evidence is introduced on re-direct.

Final pretrial conference is conducted on the record.

Continuance requests must identify other court, judge, and docket number if conflict exists

Threshold motions must be filed at least 7 days before Rule 16 conference.

Continuance requests exceeding 90 days will not be considered.

Extension requests must be filed as motions with good cause shown, made as far in advance as possible.

Summary judgment reply limited to 25 pages with specific record citations.

Supporting memoranda in multi-defendant criminal cases limited to 20 double-spaced pages.

Post-trial support memoranda limited to 25 pages, due within 30 days of transcript receipt.

Discovery motions limited to 5 pages, no exhibits or memorandum of law.

Factual statements on summary judgment do not count toward 25-page limit unless substantially argumentative.

Reply briefs require leave of court, filed within 5 days with email courtesy copy.

Counsel expected to resolve objections before motions in limine deadlines.

By the Rule 16 conference, Rule 26(a) disclosures are expected to be complete and initial interrogatories and document requests served (and answered or soon to be answered), with discovery begun without waiting for the conference.

Discovery disputes require motion to compel after failed resolution attempts.

Parties must request a pre-filing conference with the Court before filing any discovery motion requiring intervention.

Judge's courtroom is not electronic

Exhibits must be taped and submitted in binders for the Court’s use.

Do not submit pleadings from the current case before Judge Wolson (cite instead); do not submit pleadings from other federal cases (cite by court, case number, docket number instead).

Trial exhibits must be in three-ring binder with tabbed table of contents in 12-point font.

Transcripts must be full-sized pages with cover page identifying witness and relevant pages; entire transcript only if relevant.

One courtesy copy of motion papers required, stapled or neatly bound with dividers.

Chambers may request a courtesy copy when a motion or its exhibits are voluminous.

Two courtesy copies required for all motions and related briefs filed electronically; two copies required for all pleadings if not filed electronically or when requested.

Prior to trial, each party must submit two marked copies of exhibits and three copies of the exhibit list to chambers.

If settlement summary attachments exceed 20 pages, a hard copy must be sent to chambers by the date the summaries are due.

Motion to seal must identify specific injuries if materials are not sealed.

Once granted, file complete unredacted sealed documents on ECF docket and highlight non-public portions

Non-emergency documents cannot be filed under seal without leave.

When filing a redacted document, the party must submit an unredacted version with highlighted proposed redactions to Chambers or via CM/ECF.

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

Both the government's attorney and the defense attorney must file sentencing memoranda, motions, and exhibits at least 7 days before the sentencing hearing.

Counsel must file the completed Rule 26(f) meeting report with the Clerk at least five business days before the Rule 16 conference.

Settlement summary and confidential case summary are due 2 weeks prior to the settlement conference.

All parties must file sentencing memoranda no later than 7 calendar days before the scheduled sentencing date.

Sentencing memoranda (exclusive of motions) must be filed no later than 7 days before scheduled sentencing date.

Cases should be tried within 1 year of filing, or 2 years if extended pretrial proceedings are necessary.

Discovery must be completed before arbitration; no discovery or dispositive motions after arbitration unless motion was filed before and unresolved.

All grounds for relief must be presented in a single, comprehensive motion rather than divided into separate motions for each count.

Exhibits must be pre-marked, exchanged, and compiled into a joint exhibit book with electronic copy for final pretrial conference.

All motions in limine must be consolidated and filed together as a single omnibus motion.

Court encourages assigning court presentations and arguments to less experienced attorneys.

Judge encourages junior attorneys who worked on briefs to participate in oral argument.

Oral argument and motions encouraged in criminal cases.

Counsel are encouraged to let other trial team members argue all or parts of motions, participate in Rule 16 conferences, and prepare ancillary witnesses, provided they have access to the client and all information needed to prepare.

Court encourages junior lawyers to argue and will accommodate them with additional time.

Attorneys of record must maintain current contact information in their ECF user accounts and update all contact information displayed on the docket as needed.

Attorneys must file searchable briefs on the CM/ECF electronic system.

Counsel must be registered on ECF to participate in the conference.

Communications addressing substantive issues must also be filed on ECF, and advocacy during ex parte contacts with the judge's staff is prohibited.

All counseled parties must use ECF; proposed orders attached to motions; no Chambers submissions except via ECF; court won't act on non-docketed submissions.

Counsel must disclose, serve, and maintain copies of all exhibits under the Federal and Local Rules whether or not the exhibits are filed on ECF, and must retain copies after proceedings conclude or the action terminates.

All correspondence to the Court must be copied to all other counsel in the matter.

Counsel must mark and exchange exhibits before a hearing or trial begins.

Moving parties must serve the statement of undisputed material facts on all parties at least 28 days before the summary judgment motion deadline.

Rule 56 moving parties must provide a Word document of the Statement of Undisputed Material Facts to opposing counsel.

Pro hac vice counsel must pay the associated fee before the conference.

The pro hac vice admission fee must be submitted at the time the application is filed on the docket, or the application will be denied pending payment.

Pro hac vice motions submitted without the required fee will be denied.

Pro hac vice motions will be denied if the required filing fee is not submitted.