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Key Traps — Where Counsel Gets Caught

  1. 1. MANDATORY AI disclosure required within 7 days for any AI-assisted filing — must name the specific AI tool used and certify independent review under penalty of perjury.
  2. 2. Meet-and-confer for discovery disputes must be IN PERSON — phone and email do not satisfy the requirement.
  3. 3. RFPs and RFAs are each limited to 25 absent prior approval from the court.
  4. 4. MSJ deposition transcripts must be filed FIRST (before briefs) to get docket numbers, then cited in the briefs by docket number.
  5. 5. Motions in limine cannot be consolidated or filed as omnibus motions.
  6. 6. SMFs limited to 50 facts with no subparts.
  7. 7. Courtesy copies required for MSJ — tabbed binder with case caption on cover, hand-delivered to Room 1767.

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

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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). [N.D. Ga. LR 7.1(E)]
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Background Rules

Discovery Dispute Procedure Submission-first
Parties must file a Notice of Discovery Dispute jointly on the docket. Statement is limited to 5 pages for 4 or fewer issues; 10 pages for 5-10 issues; 12 pages for more than 10 issues. Statement must follow a structured format: identify each issue, then each party's position on the issue. [Judge Johnson 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)]
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AI & Style Preferences

Additional Notes
Mandatory AI disclosure requirement. Strictest meet-and-confer requirement in GA-ND (in-person only). RFP and RFA limits of 25 each.

Sources & Currency

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