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Key Traps — Where Counsel Gets Caught
- 1. ALL litigation activity — including JPRP, initial disclosures, and discovery — is automatically stayed upon filing of a dispositive motion, unless all parties agree in writing to proceed.
- 2. Extension motion titles MUST include whether the motion is opposed/unopposed AND how many prior extensions have been requested — failure is grounds for automatic denial.
- 3. Proposed orders are generally NOT required and should NOT be submitted unless the court requests them, except for TRO orders.
- 4. Do not include the word 'Proposed' in the title of any order submitted to this court.
- 5. Discovery disputes are resolved by Zoom conference after a max 3-page email statement — no formal motions without prior permission.
- 6. Multiple MSJs are prohibited without prior leave of court.
Quick Reference
| Topic | Rule |
|---|---|
| Chambers Copies | Conditional |
| Tentative Rulings | Not issued. N.D. Ga. does not use a tentative ruling system. |
Procedural Briefing by Motion Type
C.D. Cal. · Standing Orders
Procedural Requirements
Key Traps
Compare to Other C.D. Cal. Judges
Procedural facts only. Judges shown to illustrate variance in this district.
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Before You File
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At Filing
Chambers Copies
Conditional
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Before the Hearing
Tentative Rulings
Not issued. N.D. Ga. does not use a tentative ruling system.
Prohibition / Ex Parte Contact Re Tentatives
N/A.
Oral Argument
Court decides motions without oral hearing unless a hearing is ordered. Per N.D. Ga. LR 7.1(E). File a standalone motion to request oral argument. [N.D. Ga. LR 7.1(E)]
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Background Rules
Discovery Dispute Procedure Submission-first
Email chambers a statement of no more than 3 pages (all parties copied). The opposing party may submit a response of no more than 3 pages within 24 hours before any scheduled conference. Disputes are resolved by Zoom conference. No discovery motions against a party without prior court permission. [Judge Grimberg Civil Standing Order § Discovery Disputes]
Ex Parte Applications
Per N.D. Ga. LR 7.5(B). Prior notice to adversary required; emergency and FRCP-authorized ex parte excepted. [N.D. Ga. LR 7.5(B)]
Settlement Notification
Notify chambers immediately upon settlement. [Judge Grimberg Civil Standing Order § Settlement]
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AI & Style Preferences
Additional Notes
Standing order effective February 10, 2026. Among the strictest GA-ND judges on MTD auto-stay, extension motion titling, and proposed order practice.
Sources & Currency
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