Pre-Motion Conference (starting 05/01/2022): In an effort to resolve cases expeditiously, before bringing a motion to dismiss, motion for a more definite statement, motion to remand, motion for change of venue, and motion for judgment on the pleadings, a party must submit a letter, not to exceed three (3) single-spaced pages, requesting a pre-motion conference. The letter must set forth the basis for the anticipated motion and include citations to relevant authority. Within seven (7) days after receipt of this letter, all adversaries must submit a written response, not to exceed three (3) single-spaced pages. No party may submit a reply letter. Generally, affidavits and exhibits are not permitted. A proffer by the attorney, however, of the contents of any such affidavit(s) and/or exhibit(s) shall suffice.

The Court will attempt to resolve the dispute(s) at a pre-motion conference (in person or via videoconference or telephone), to the extent possible. If the dispute cannot be resolved at the conference (or the Court determines that a conference would not be helpful), the moving party will file its motion. To be clear, this procedure does not preclude a party from filing one of the above motions pursuant to Local Civil Rule 12.1. Rather, the Court hopes to use this procedure to advance the case efficiently and minimize the costs of litigation to the parties. In addition, compliance with this procedure shall not be deemed a waiver of any parties’ defenses as to insufficient service of process or lack of personal jurisdiction.

A party’s submission of a pre-motion letter will toll that party’s time to file its motion (or answer) through (i) the date of the pre-motion conference or (ii) the Court’s decision not to conduct such a conference. If the Court permits a party to file its proposed motion without a conference, that party shall have an additional 7 days to file after its Fed. R. Civ. P. 12(a) deadline, unless additional time is stipulated.

This letter exchange does not apply to bankruptcy appeals, social security appeals, cases seeking transfers based on Multidistrict Litigation (MDL) orders, or cases in which either side is appearing pro se.

All Submissions: All pleadings and correspondence to the Court (with the exception of confidential settlement position letters) must be electronically filed. Filings and submissions will not be accepted via fax or e-mail without leave of the Court.

Pro se Filings: All filings by pro se litigants shall be mailed to or filed directly with the Clerk's Office. Documents mailed to the courthouse must be addressed to the Clerk's Office, NOT Judge Quraishi.

CM/ECF Filings: Pleadings, motions, letters, and proposed jury charges must be filed in searchable PDF format. Supporting documents, such as exhibits, may be filed in non-searchable PDF format.

Proposed Orders: If any relief is being sought, the CM/ECF filing must be accompanied by a proposed order in searchable PDF format.

Motions for Summary Judgment: Parties may not file an early motion for summary judgment (i.e., prior to the close of fact discovery) without leave from either Judge Quraishi or the Magistrate Judge assigned to the case. When seeking leave from Judge Quraishi, the moving party must first submit a letter, no longer than three pages, summarizing the party’s substantive argument. Within one week of the moving party’s letter, the party opposing the motion must also submit a letter, no longer than three pages, summarizing the party’s substantive argument in opposition.

Courtesy Copies: By request of the Court only.

How to Communicate with Chambers: Parties appearing pro se must file all documents, applications, and motions directly with the Clerk’s Office. For all litigants, calls to chambers are permitted only in urgent situations that require immediate attention. In urgent situations, e-mails to chambers at znq_orders@njd.uscourts.gov are preferred to phone calls. E-mails may not contain substantive content regarding a case. Any substantive content received via e-mail without consent of chambers will be ignored.

Communications with Law Clerks: Judge Quraishi permits communications with his law clerks only as to questions regarding chambers’ procedures and not as to any substantive matters.

Extensions of Time to a Deadline: If consented, extension requests may be done by proposed consent order via CM/ECF. If not consented, follow the regular motion procedure. To adjourn a previously scheduled appearance, obtain consent from your adversary and provide chambers with proposed new dates via CM/ECF.

Adjournment Requests for Hearings/Conferences: Adjournment requests should be made at least two business days before a scheduled hearing or conference. The party seeking an adjournment should attempt to gain the consent of his or her adversary before filing said request by letter. In any such letter, the party should set forth the date of the hearing or conference, the basis for the adjournment request, whether the request is being made with consent, and the length of adjournment being sought. Absent exigent circumstances, adjournment requests made less than two days prior will not be granted.

Motion Day: Unless otherwise notified by the Court via CM/ECF, Judge Quraishi decides all motions on the papers and no appearances are required on the motion day.

Appearances: Notice of any scheduled appearance, including but not limited to status conferences, settlement conferences, and oral arguments, will be posted on the docket. Where counsel are scheduled to appear in-person, all clients or representatives with settlement authority must be available by phone unless otherwise directed by chambers. The Court expects counsel to arrive at least 15 minutes prior to any appearance.