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Key Traps — Where Counsel Gets Caught

  1. 1. Discovery disputes require a Consolidated/Joint Discovery Statement with structured party-position format filed on the CM/ECF docket — not a letter or standalone motion.
  2. 2. Statement page limits are tiered: 6 pages for 1-4 issues, 10 pages for 5-10, 12 pages for 10+.
  3. 3. No discovery motions without prior court permission.
  4. 4. R&R objections capped at 15 pages.
  5. 5. Motions in limine: 21 days before pretrial; responses due 9 days after filing; replies due 5 days after responses.
  6. 6. Must request permission before approaching a witness or the bench.

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 Consolidated/Joint Discovery Statement on the case docket. Statement limited to 6 pages for 4 or fewer issues; 10 pages for 5-10 issues; 12 pages for more than 10 issues. Statement must use a structured format: identify each issue, then each party's position, then party replies. No discovery motions without prior court permission. [Judge Ross 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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