All local rules for D.N.J., integrated with this judge's published requirements.
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 ↗
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 ↗
11. Settlement Conferences. Trial counsel as well as individuals with full settlement authority must appear at settlement conferences unless the Court has granted prior permission to participate by telephone.
1. Communications with the Court. Unless directed by the Court or permitted by this Order, all communications with the Court shall be in writing and filed via CM/ECF. Telephone calls to chambers will be permitted only as to administrative and procedural matters.
11. Settlement Conferences. Trial counsel as well as individuals with full settlement authority must appear at settlement conferences unless the Court has granted prior permission to participate by telephone. No later than five (5) business days before the settlement conference, each party shall submit to the Court via email to jbd_orders@njd.uscourts.gov a confidential settlement submission of no more than five (5) single-spaced pages (exclusive of any exhibits). The settlement submission should outline the party's respective position(s); identify information on what is important to the client and any barriers to settlement; identify the contemplated terms material to a settlement; and set forth any demands and offers made to date.
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) ↗
40 pages maximum for brief in opposition (same limit applies to cross-motion briefs in opposition). D.N.J. Civ. R. 7.2(b) ↗
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) ↗
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) ↗
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) ↗
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) ↗
Yes
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) ↗
7. Motions to Seal. Motions to seal must comply in all respects with Local Civil Rule 5.3(c) and must include a proposed order that includes findings of fact and conclusions of law, and which includes references to the docket entries that are the subject of the motion. Contemporaneously with the motion, counsel should submit to the Court, via email to jbd_orders@njd.uscourts.gov, any proposed redacted documents to be filed if the motion is granted. Counsel shall make every effort to secure the consent of all parties regarding the request to seal and the movant shall certify as to whether all parties consent in its application. Parties may file a motion to seal without obtaining leave of Court.
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 ↗
Yes — motions decided on the papers without oral argument.
2. Adjournments and Extensions. Requests for adjournments and extensions should be made in writing through a letter request filed via CM/ECF. The party seeking an adjournment or extension should attempt to obtain the consent of all other parties before filing the request. The letter request should set forth the date of the conference/hearing or relevant deadline; the basis for the request; whether all parties consent to or oppose the request; the length of the adjournment or extension sought; and whether the request, if granted, would impact other scheduled dates or deadlines. Absent exigent circumstances, the Court will consider adjournment and extension requests only if made at least two (2) business days before a scheduled conference or deadline.
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 ↗
5. Discovery Disputes. Discovery disputes and other case-management applications shall proceed in accordance with Local Civil Rules 16.1(f)(1) and 37.1(a)(1). Consistent with their obligation under the rules, the parties shall meet and confer in good faith to resolve any discovery disputes before raising them with the Court. Email exchanges are not sufficient to satisfy the meet-and-confer requirement: Before raising a dispute with the Court, the parties must meet and confer in person, via video-conference, or by telephone. Should counsel fail in their good-faith efforts to resolve the dispute, the matter should be brought to the Court's attention through a single joint letter that sets forth the following: (i) the request; (ii) the response; (iii) efforts to resolve the dispute; (iv) the position of the complaining party; (v) the position of the responding party; and (vi) if applicable, the efforts of a party to contact a non-responsive party to meet and confer and submit the joint letter. No further letter submissions regarding the dispute may be submitted without prior leave of Court. The joint letter should be filed via CM/ECF unless it contains information subject to a discovery confidentiality order, in which case it may be submitted to chambers via email to jbd_orders@njd.uscourts.gov.