Standing Orders: No formal motions are permitted unless leave of court is first obtained except for motions under Federal Rule of Civil Procedure 12(b) or motions to remand that must be filed within thirty days of removal under 28 U.S.C. § 1447(c). Full compliance with Local Civil Rules 16.1 and 37.1 will be expected.

Pro hac vice:  If consented, e-file a letter indicating consent and enclosing a proposed form of Order, 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).

Motion Practices:

            Dispositive Motions: Shall comply with the procedures set forth in Local Civil Rule 7.1 for all motions.

            Motions to Seal: In addition to electronically filing materials subject to a motion to seal pursuant to Local Civil Rule 5.3, a copy of such materials shall be submitted by email to JSA_orders@njd.uscourts.gov, identifying them as “Confidential Materials subject to Motion to Seal.”  With motion papers, counsel should submit a form of order containing proposed findings of fact and conclusions of law regarding the Local Civil Rule 5.3(c) factors.

Extensions of Time - If consented, may be done by consent order. If not consented, follow regular motion procedure (electronic filing).

Correspondence and written submissions not containing confidential information:  Shall be electronically filed via CM/ECF.  Papers shall not be submitted by facsimile unless otherwise directed.

Confidential settlement letters and discovery dispute letters containing information subject to a Discovery Confidentiality Order:  May be submitted by email to JSA_orders@njd.uscourts.gov.

Telephone Conferences:  Are permitted but must be initiated by letter informally outlining the issues to be discussed. 

Communications with the Court: Direct communication with law clerks is permitted as to procedural matters only.

Courtesy copies:  One courtesy copy of all submissions exceeding 20 pages should be sent by regular mail to chambers.

Applications to amend or supplement pleadings:  Counsel shall circulate any desired amendment and shall seek written consent of all parties, as per Federal Rule of Civil Procedure 15(a)(2), before pursuing amendment by motion.  Any request for leave of the Court to file a motion to amend must contain a redlined version of the proposed amended pleading as an exhibit.  If a party seeks to file a motion to amend after the deadline set by a Scheduling Order, that party must show good cause why the amendment could not have been sought earlier pursuant to Federal Rule of Civil Procedure 16.