Judge Timothy J. Savage

Reply briefs, addressing only issues raised in the brief in opposition and not repeating arguments in the brief, may be filed within seven days of service of the opponent’s brief in opposition and shall be limited to ten pages.

Each party must submit to the Court and serve on opposing counsel proposed points for charge and any proposed jury interrogatories no later than seven days prior to the trial date.

At least one week prior to the trial date, the government must file a trial memorandum setting forth the essential elements of the offenses, the facts which it intends to present, the identity of each witness it intends to call, a statement of the substance of each witness= testimony and any legal issues.

Each point for charge and proposed jury interrogatory shall be numbered and on a separate sheet of paper identifying the name of the requesting party.

If a party modifies a model instruction, additions shall be underlined and deletions shall be placed in brackets.

If a model jury instruction is used, the party submitting it shall state whether the proposed instruction is unchanged or modified. If a party modifies a model instruction, additions shall be underlined and deletions shall be placed in brackets.

At the final pretrial conference, the parties shall provide the Court with one copy of each exhibit and two copies of a schedule of exhibits which shall briefly describe each exhibit. At the trial, the parties must provide the court with an additional copy of each exhibit. Exhibits shall be tabbed in a three-ring binder containing all exhibits numbered consecutively.

The motion must comply with Local Rule 26.1(f). The certification must state in detail what efforts were made to resolve the dispute.

Any party intending to use depositions, written or video, at trial must notify all other parties in the pretrial memorandum.

In the pretrial memoranda, counsel must detail the substance of the testimony of each witness. Identifying a witness as giving testimony on liability and/or damages is insufficient.

Objections to deposition testimony shall be made prior to the pretrial conference in writing, setting forth the page and line numbers of the challenged testimony and a clear statement for the basis of the objection.

Each proposed instruction must be submitted with authority.

The government is required to file proposed findings of fact and conclusions of law prior to the commencement of the hearing.

If a model jury instruction is used, the party submitting it shall state whether the proposed instruction is unchanged or modified.

Counsel are expected to cooperate in the preparation of the joint proposed instructions. Failure to cooperate in the process will result in the imposition of sanctions.

If counsel cannot agree, proposed alternative instructions must be submitted with authority for each instruction.

After the jury has retired to deliberate, counsel shall review the exhibits to determine which exhibits will go out with the jury. If counsel cannot agree, they should request a ruling immediately after the jury retires to the deliberations room.

In a non-jury trial, the parties shall file a stipulation of uncontested facts. Each party shall submit proposed findings of fact and conclusions of law.

Counsel must meet and discuss proposed jury instructions for the purpose of submitting agreed-upon jury instructions and verdict forms.

Speaking objections are not permitted. Objections shall be made by reciting the appropriate rule number or a one word basis.

Exhibits are admitted into evidence at the close of each party=s case-in-chief and not during testimony or after the exhibit is identified. Counsel should review the exhibits in advance so that agreed upon exhibits can be admitted quickly and disputed exhibits ruled upon at the conclusion of the party=s case.

Rebuttal must not be a rehashing of closing argument.

Prior to the Rule 26(f) conference, the parties shall exchange the following information:

Regardless of whether the e-discovery liaison is an attorney (in-house or outside counsel), a third party consultant, or an employee of the party, he or she must be: familiar with the party's electronic systems and capabilities in order to explain these systems and answer relevant questions; knowledgeable about the technical aspects of e-discovery,

To promote communication and cooperation between the parties, each party shall designate a single individual through whom all e-discovery requests and responses are made ("the e-discovery liaison").

The parties shall discuss the parameters of their anticipated e-discovery at the Rule 26(f) conference and shall be prepared to address e-discovery at the Rule 16 scheduling conference with the court.

Discovery of electronic documents shall proceed in the following sequenced fashion: after receiving requests for document production, the parties shall search their documents, other than those identified as limited accessibility electronic documents, and produce responsive electronic documents in accordance with Fed. R. Civ. P. 26(b)(2);

Within the first thirty (30) days of discovery, the parties shall negotiate an agreement that outlines the steps each party shall take to segregate and preserve the integrity of all relevant electronic documents.

The retention coordinators shall: take steps to ensure that e-mail of identified custodians shall not be permanently deleted in the ordinary course of business and that electronic documents maintained by the individual custodians shall not be altered;

When the image file is produced, the producing party must preserve the integrity of the electronic document's contents, i.e., the original formatting of the document, its metadata and, where applicable, its revision history.

provide notice as to the criteria used for spam and/or virus filtering

If, during the course of the Rule 26(f) conference, the parties cannot agree to the format for document production, electronic documents shall be produced to the requesting party as image files (e.g., PDF or TIFF).

If the parties intend to employ an electronic search to locate relevant electronic documents, the parties shall disclose any restrictions as to scope and method which might affect their ability to conduct a complete electronic search of the electronic documents.

After initial production in image file format is complete, a party must demonstrate particularized need for production of electronic documents in their native format.

The parties shall reach agreement as to the method of searching, and the words, terms, and phrases to be searched with the assistance of the respective e-discovery liaisons, who are charged with familiarity with the parties' respective systems.

electronic searches of documents identified as of limited accessibility shall not be conducted until the initial electronic document search has been completed;

documents must be narrowly focused with a factual basis supporting the request; and, on-site inspections of electronic media under Fed. R. Civ. P. 34(b) shall not be permitted, absent exceptional circumstances where good cause and specific need have been demonstrated.