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 ↗
Communications with the Court. All communications to the Court shall be by CM/ECF or by telephone. Absent permission from Chambers or as otherwise provided herein, the Court will not accept or consider communications by fax, mail, or email. Judge Kiel permits communications with his law clerks only as to questions regarding Chambers' procedures and not as to any substantive matters.
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) ↗
All filed papers shall be in a text-searchable PDF format as required by Local Civil Rule 5.21(h).
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) ↗
Motions to Seal. Motions to seal documents related to a dispositive issue are to be set before Judge Kiel. A motion to seal must comply with Local Civil Rule 5.3(c) and must include a proposed order and proposed findings of fact and conclusions of law. The proposed order must include reference to the docket entries the party seeks to seal.
Electronic Submissions. All parties, with the exception of pro se parties, shall electronically file all documents. All filed papers shall be in a text-searchable PDF format as required by Local Civil Rule 5.21(h). Parties are directed to ensure that all supporting documents to a filing are docketed as attachments to the primary document.
Motions to Seal. Motions to seal documents related to a dispositive issue are to be set before Judge Kiel. A motion to seal must comply with Local Civil Rule 5.3(c) and must include a proposed order and proposed findings of fact and conclusions of law. The proposed order must include reference to the docket entries the party seeks to seal. Counsel shall make every effort to secure the consent of all parties regarding the motion to seal, and the movant shall certify in support of the motion whether all parties consent.
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 ↗
Motion Day. The purpose of a motion's return date or "motion day" is to determine the briefing schedule for that motion, Unless otherwise notified by the Court, Judge Kiel decides all motions on the papers and no appearances are required on the motion day.
Yes — motions decided on the papers without oral argument.
Adjournment Requests. Conferences and hearings, whether telephonic or in-person, are normally scheduled with ample notice to the parties. Accordingly, adjournment requests must be made no later than five business days before the scheduled conference or hearing and shall indicate whether all parties consent.
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 ↗