judge console · D. Mass.
D. Mass. · Judge Hedges · Practice Guide

Hon. Jessica D. Hedges

All local rules for D. Mass., integrated with this judge's published requirements.

Drafting the Motion
Length limits — motion, opposition, reply
👤 Judge Hedges — standing order
Motion

Page Limit. Counsel are reminded of the 20-page limit set forth in Local Rule 7.1(b)(4). Any papers exceeding this limit may be filed only with leave of the Court.

Reply

The moving party may file a reply as of right within seven days of the filing of the opposition, except as to motions for summary judgment, where a reply may be filed within fourteen days after the opposition is served. A reply shall not exceed five pages. A sur-reply is not permitted.

Filing & Scheduling
Briefing schedule & hearing date
👤 Judge Hedges — standing order
Notice period

An opposition is due within fourteen days of service of the motion, except as to motions for summary judgment, where oppositions may be filed within twenty-one days. See Local Rules 7.1, 56.1.

Chambers / courtesy copies
👤 Judge Hedges — standing order
Standing order

In connection with dispositive motions, do you require the filing of any courtesy copies of exhibits, depositions and/or other materials in addition to the electronic versions that are filed on ECF? A23: No. If, in a particular case, I would like the parties to provide courtesy copies, my Courtroom Deputy will contact the parties and make this request.

Filing under seal
👤 Judge Hedges — standing order

Privacy Policy. Federal Rule of Civil Procedure 5.2 restricts the publication of certain personal data in documents filed with the Court. The rule requires limiting Social Security and financial account numbers to the last four digits, using initials for the names of minor children, and limiting dates of birth to the year.

The Hearing
Oral argument
👤 Judge Hedges — standing order
Default practice

Requests for Hearings. Any party making or opposing a motion may include a request for oral argument in a separate paragraph of that motion or opposition. See Local Rule 7.1(d). The Court will determine whether a hearing is necessary and set a hearing date as needed. Otherwise, the Court will decide the motion on the papers.

Decided on the papers?

Yes — motions decided on the papers without oral argument.

Remote appearances
👤 Judge Hedges — standing order

counsel should contact the Court's courtroom deputy and request a brief conference with the Court. The conference will be conducted remotely (via Zoom) and will allow the Court to discuss the discovery dispute with the parties before counsel devotes significant time and resources to motion practice.

Continuances & calendar conflicts
👤 Judge Hedges — standing order

Extension of Deadlines. Motions to extend or modify deadlines will be granted only for good cause shown. All motions to extend shall contain a brief statement of the reasons for the request; a summary of the discovery, if any, that remains to be taken; and a specific date when the requesting party expects to complete additional discovery, join other parties, amend the pleadings, or file a motion.

Discovery
Discovery dispute procedure
👤 Judge Hedges — standing order

Meet and Confer Requirement. Before requesting a discovery hearing, the parties must first confer in a good-faith effort to resolve or narrow the dispute in compliance with Local Rule 7.1(a)(2) and Local Rule 37.1(a). Counsel must certify that they made good-faith efforts to confer. An adequate certificate of conference requires at least one personal communication (e.g., in person, by videoconference, or by telephone), if not more, between counsel.

The parties shall file a brief joint memorandum, not to exceed three pages, outlining the areas in dispute three days before the conference. The parties shall attach to the memorandum the underlying discovery document(s) in dispute. If, after the conference, a party still wishes to file a discovery-related motion, such motion must be filed no later than the close of fact discovery or the close of expert discovery, whichever deadline is relevant.

More from Judge Hedges’s procedures
👤 Judge Hedges — standing order
Argument counsel requirement

Encouraging Participation by Less-Experienced Lawyers. Ordinarily, only one lawyer for each party may argue at a hearing. Nevertheless, the Court has a strong commitment to supporting the development of our next generation of lawyers. The Court encourages parties and senior attorneys to allow less-experienced practitioners the opportunity to argue motions in court. If a lawyer of five or fewer years of experience will be arguing, a party should advise the Court prior to the beginning of the hearing. In that event, the Court will allow multiple lawyers to argue on behalf of that party. Source ↗

Citation preference

ECF Citations. When citing to documents filed on the Court's electronic docket, e.g., the complaint, another party's memorandum, or an exhibit to a prior submission, parties shall use the following format: (Docket No. ___). This convention shall be used instead of formats using the title of the cited document, e.g., Bluebook format. Source ↗

MSJ limitation

5. Motions for Summary Judgment. Counsel shall review and adhere to Local Rule 56.1, in addition to the procedures set forth below. 6. Cross-Motions for Summary Judgment. Notwithstanding the provisions of Section 4, supra, if both sides are filing motions for summary judgment, they shall do so as set forth below. a. Defendant shall file its motion, with a memorandum not to exceed twenty pages, on or before the date for filing dispositive motions set forth in this Scheduling Order. b. Within thirty days of Defendant's submission pursuant to the previous paragraph, Plaintiff shall file a single memorandum as both its memorandum in opposition to Defendant's motion and its memorandum in support of its cross-motion, not to exceed thirty pages; c. Within twenty-one days of Plaintiff's submission pursuant to the previous paragraph, Defendant shall file a single memorandum as both its reply in support of its motion and its opposition to Plaintiff's cross-motion, not to exceed fifteen pages; and d. Within fourteen days of Defendant's submission pursuant to the previous paragraph, Plaintiff may file a memorandum as its reply in support of its cross-motion, not to exceed five pages. Source ↗

Pre motion conference required

After the parties have met and conferred pursuant to Local Rules 7.1(a)(2) and 37.1(a), and prior to drafting or filing motions to compel discovery, motions for protective orders, motions to quash, motions to strike discovery responses, or similar discovery-related motions, counsel should contact the Court's courtroom deputy and request a brief conference with the Court. Source ↗

Pre motion procedure

Obligation to Confer. Counsel are reminded of their obligation to confer in good faith to resolve or narrow any issues prior to filing any motion, as set forth in Local Rules 7.1(a)(2) and 37.1(a). Source ↗

content assembled from published local rules & standing orders · click any section in the rail for the full treatment
Get updates on Judge Hedges's procedures
Standing order changes, new key traps, and C.D. Cal. practice intelligence.