1.         Communications with the Court.  In civil cases, all written submissions to the Court, apart from submissions by pro se parties, shall be filed electronically via ECF.  Confidential settlement memoranda, however, should be submitted directly via email to njdnef_pascal@njd.uscourts.gov.  Counsel may contact chambers by telephone with procedural questions but all questions regarding substantive matters should be in writing and electronically filed via ECF.

     2.         Telephone Conferences.  For all telephone conferences, the Court will use the telephone number 1-856-210-8988.  After dialing in, Counsel will need to enter an access code, which changes for each conference.  Counsel should refer to the order scheduling the conference for the specific access code.

     3.         Courtesy Copies.  One (1) copy of all filed papers, briefs, or other submissions exceeding twenty (20) pages per individual document shall be mailed to Chambers.  Exhibits to any papers should be separated with corresponding exhibit tabs.

     4.         Proposed Joint Discovery Plans.  Proposed Joint Discovery Plans should be submitted to the Court via ECF.

     5.         Confidentiality Orders.  The parties are encouraged to use the form Discovery Confidentiality Order found at Appendix S of the Local Civil Rules.  If the parties submit their own version of the Appendix S Discovery Confidentiality Order, they must submit: (1) a clean version of the proposed Order that is ready for signature; and (2) an additional version that indicates in what respect(s) it differs from Appendix S by bracketing or striking through materials to be deleted and underlining materials to be added.  The Order should be signed by all counsel or an accompanying cover letter should state whether all parties consent to the form of order.

     6.         Adjournments.  Adjournment requests shall be made in writing, filed on the docket, and indicate whether all parties consent.

     7.         Extensions.  Extension requests shall be made in writing, filed on the docket, and indicate whether all parties consent.  All applications regarding motions returnable before a District Judge shall be presented to the District Judge.

     8.         Discovery Disputes and Applications.  Counsel shall meet and confer in a good faith attempt to informally resolve all discovery or case management disputes before seeking the Court’s intervention.  See L. Civ. R. 37.1(a)(1).  Absent exigent circumstances, the Court expects parties to “meet and confer” in person, via telephone, or by video conference before making a discovery application.  Any dispute not resolved shall be brought to the Court’s attention by letter filed on the docket after counsel’s good faith attempt to resolve the dispute has failed. The letter shall set forth the specific efforts the parties made to resolve the dispute before contacting the Court. No discovery motion shall be made without prior leave of Court.  See L. Civ. R. 37.1(b).

     9.         Motions to Amend.  Motions to amend must comply with Local Civil Rule 15.1 and shall be accompanied with a proposed amended pleading with red-lined edits that clearly indicate the proposed changes.

     10.       Motions to Seal.  Motions to seal must comply with Local Civil Rule 5.3(c) and shall be filed on the docket.  Counsel shall make every effort to secure the consent of all parties regarding the request to seal and the movant shall certify whether all parties consent to the application.

     11.       Pro Hac Vice Applications.  Counsel shall file a formal motion to admit counsel pro hac vice. The motion should be filed on the docket and indicate whether all counsel consent to the motion. Counsel should follow Local Civil Rule 101.1(c) and the comment thereto.  

     12.       Settlement Conferences.  Unless the Court specifically instructs otherwise, clients with full settlement authority are required to appear in person at the settlement conference.  Each party shall submit a confidential settlement memorandum of no more than five (5) double-spaced pages, including exhibits, via email to njdnef_pascal@njd.uscourts.gov at least three (3) business days before the scheduled conference.  The settlement memorandum shall outline the party’s respective position(s); identify information that is most important to the client and any barriers to settlement; identify the contemplated terms material to a settlement; and detail the demand(s) and offer(s) made to date.

     13.       Final Pretrial Conferences.  The Court conducts final pretrial conferences pursuant to Federal Rule of Civil Procedure 16(e).  The Court expects parties to engage in meaningful settlement discussions at final pretrial conferences.  If the Court directs, clients must attend the conference, but in all circumstances, clients must be on call so that any settlement proposals made at the conference can be immediately conveyed.  Unless the Court directs otherwise, the plaintiff shall be responsible for submitting the joint proposed final pretrial order via email to njdnef_pascal@njd.uscourts.gov.   For cases in the Camden vicinage, the instructions for preparing the Order can be found at http://www.njd.uscourts.gov/sites/njd/files/pretrialorder%20camden.pdf. 

     14.       Participation by Junior Attorneys:  The Court encourages the participation of less experienced attorneys (i.e., those with less than five years’ experience) in all proceedings, including pretrial conferences, hearings on discovery disputes, and oral arguments, particularly where that attorney played a substantial role in drafting the underlying filing.  The Court is also more likely to grant oral argument if a party represents, at the time of the filing of the motion or request for argument, that a junior attorney will present the argument.  The Court is amenable to permitting more than one lawyer to argue for one party if this creates an opportunity for a junior lawyer to participate.