judge console · D.N.J.
D.N.J. · Judge Bongiovanni · Practice Guide

Hon. Tonianne J. Bongiovanni

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

Before You File
Ex parte applications
🏛 D.N.J. local rule

Applications for emergency relief are returnable on the first regular motion day at least 24 days after filing, unless the court orders otherwise. Seek a court order for shorter timelines — the default emergency mechanism uses the standard motion-day count-back schedule. D.N.J. Civ. R. 65.1 ↗

Lead counsel requirements
🏛 D.N.J. local rule

Pro hac vice is governed by Civ. R. 101.1 — NOT Rule 83 (NJ-D's post-1997 numbering places admission rules in the 100s range). Local counsel association is generally required; local counsel signs pleadings and may be required to attend hearings. Local counsel is substantively responsible, not nominal. D.N.J. Civ. R. 101.1 ↗

Contacting chambers
👤 Judge Bongiovanni — standing order

Judge Bongiovanni permits counsel to email any correspondence that would normally be mailed to chambers to: tjb_orders@njd.uscourts.gov. Materials that are filed through the CM/ECF system should NOT be mailed, emailed or faxed to Chambers. Further, to the extent counsel files a time sensitive document on CM/ECF that they want reviewed the same or next day, counsel must call Chambers to alert it to the filing. Correspondence should only be submitted to chambers via one method: correspondence mailed to chambers should not also be faxed or emailed; similarly correspondence emailed to chambers should not also be mailed or faxed; and correspondence faxed to chambers should not also be mailed or emailed. Judge Bongiovanni permits communications with her law clerks only as to questions regarding chambers' procedures and not as to any substantive matters.

Settlement notification
👤 Judge Bongiovanni — standing order

Unless specifically instructed otherwise by the Court, clients with full settlement authority are required to appear in person at the conference. Counsel alone, even if he possesses full settlement authority, is insufficient. The client must also appear in person unless the Court has specifically instructed otherwise. If submission of a settlement memorandum is required or, even if not required, a settlement memorandum will be submitted, it must be emailed to chambers (tjb_orders@njd.uscourts.gov) at least 3 business days before the scheduled settlement conference and should not exceed 5 pages in length.

Drafting the Motion
Length limits — motion, opposition, reply
🏛 D.N.J. local rule
Motion

40 pages maximum for main brief (excluding table of contents and authorities). If a 12-point proportional font is used instead of the required typeface, the limit is reduced by 25% to 30 pages. D.N.J. Civ. R. 7.2(b) ↗

Opposition

40 pages maximum for brief in opposition (same limit applies to cross-motion briefs in opposition). D.N.J. Civ. R. 7.2(b) ↗

Reply

15 pages maximum for reply brief. Reduced to 11.25 pages if 12-point proportional font is used instead of the required typeface. D.N.J. Civ. R. 7.2(b) ↗

Font & formatting
🏛 D.N.J. local rule

Black lettering; 8.5 x 11 inch paper; one-inch margins; double-spaced text; single-spaced footnotes. Typeface must be 12-point non-proportional (e.g., Courier New 12) or equivalent 14-point proportional (e.g., Times New Roman 14). Using a 12-point proportional font instead reduces all page limits by 25%. Footnotes must be the same size as text. D.N.J. Civ. R. 7.2(c)–(d) ↗

Filing & Scheduling
Briefing schedule & hearing date
🏛 D.N.J. local rule
Notice period

Motion and supporting brief must be filed at least 24 days before the noticed motion day. Opposition due at least 14 days before original motion day (Civ. R. 7.1(d)(2)). Motion day must be noted on the cover page of the motion. D.N.J. Civ. R. 7.1(d)(1) ↗

Hearing days

Motion days are the first and third Monday of each month, excluding holidays. Briefing deadlines count back from the noticed motion day — not forward from service. D.N.J. Civ. R. 78.1(a) ↗

Chambers / courtesy copies
👤 Judge Bongiovanni — standing order
Required?

Yes

Proposed orders
🏛 D.N.J. local rule

All filed motions shall have annexed thereto a proposed order. If the proposed order does not adequately reflect the Court's ruling, the prevailing party, if directed by the Court, shall submit an order within seven days of the ruling on the motion on notice to all other parties. Unless the Court otherwise directs, if no specific objection to that order with reasons therefor is received within seven days of its receipt by the Court, the order may be signed. If such an objection is made, the matter may be listed for hearing at the discretion of the Court. D.N.J. Civ. R. 7.1(e) ↗

👤 Judge Bongiovanni — standing order

Proposed Orders sent by e-mail to tjb_orders@njd.uscourts.gov preferably in Word format. Orders on formally filed motions need not be sent.

The Hearing
Oral argument
🏛 D.N.J. local rule

No oral argument shall be heard except as permitted expressly by the judge assigned to hear the motion. If oral argument is required, parties are notified by the court. Argument may be conducted in open court or by telephone conference at the judge's discretion. Request for oral argument must be clearly marked on the first page of the notice of motion and/or brief. D.N.J. Civ. R. 78.1 ↗

Remote appearances
👤 Judge Bongiovanni — standing order

Judge Bongiovanni does not accept dial-in numbers prior to conference calls. If a dial-in number is necessary, then once all of the attorneys have dialed into a scheduled call, the party initiating the call shall contact chambers and provide the dial-in number at that time.

Continuances & calendar conflicts
👤 Judge Bongiovanni — standing order

Adjournment Requests shall only be considered if made at least 2 business days prior to a scheduled conference. The party seeking an adjournment should attempt to gain the consent of his adversary before submitting said request. The adjournment request should be made in writing and emailed to chambers (tjb_orders@njd.uscourts.gov). Absent exigent circumstances, adjournment requests made the day of or before a conference shall not be granted.

Discovery
Discovery referral procedure
🏛 D.N.J. local rule

Discovery applications may be presented by telephone conference call or letter to the judge before formal motion practice. File a formal discovery motion only after the telephone/letter mechanism has been attempted. Civ. R. 37.2 governs discovery motion sanctions per FRCP 37. D.N.J. Civ. R. 37.1 ↗

Discovery dispute procedure
👤 Judge Bongiovanni — standing order

In addition, to the extent a party intends to submit a status letter or discovery dispute in advance of a scheduled telephone conference, the letter must be submitted at least 3 business days prior to the conference. The letter may be emailed to chambers (tjb_orders@njd.uscourts.gov). Letters submitted after that date likely will not be reviewed or considered prior to or during the conference.

content assembled from published local rules & standing orders · click any section in the rail for the full treatment
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