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Key Traps — Where Counsel Gets Caught
- 1. Certificate of Compliance must be signed and filed — failure to file it is a standing order violation.
- 2. MSJ requires complete deposition transcripts (not just excerpts) filed simultaneously with the brief.
- 3. For MSJ and voluminous exhibits, courtesy copies in a tabbed binder are required.
- 4. Word copies of proposed orders must be emailed to Ms. Gardner for: Protective Orders, Consent Decrees, Default Judgment Orders, Orders Approving Settlement.
- 5. Meet-and-confer for discovery disputes must be by phone or in person — email insufficient.
- 6. Discovery statement page limits are tiered: 8 / 12 / 15 pages depending on issue count.
- 7. All exhibits must be labeled with their content (not just 'Ex. A') — required to assist the court in ruling.
- 8. TRO/PI request embedded in complaint is insufficient — file a separate motion.
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
Motions usually decided without oral argument, but Court will consider any request for hearing. Per N.D. Ga. LR 7.1(E). Videoconference appearances for hearings are disfavored and require exceptional circumstances and explicit court permission. [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 via CM/ECF. Statement limited to 8 pages for 4 or fewer issues; 12 pages for 5-10 issues; 15 pages for more than 10 issues. Statement must use a structured format: identify each issue, then each party's position, then party replies. Meet-and-confer must be by telephone or in person; email does not satisfy the obligation unless repeated phone attempts fail. [Judge Totenberg Standing Order § III(f) 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. ADR-related ex parte communication with Ms. Gardner is permitted. [N.D. Ga. LR 7.5(B)]
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AI & Style Preferences
Additional Notes
Senior District Judge. Among the most procedurally detailed standing orders in GA-ND. Certificate of Compliance required — must be signed and filed. Court sessions begin at 9:30 AM.
Sources & Currency
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