Counsel or pro se parties may correspond with the Court by letter, email or telephone concerning routine scheduling and administrative matters. The Court expects counsel and pro se parties to copy opposing counsel or pro se parties on their written communications with the Court. All communications with the Court should be directed to the deputy clerk or chambers. Counsel should not communicate with the law clerks unless directly contacted by a law clerk or instructed by the Court to do so. Law clerks may not render advice to counsel and have no authority to grant continuances or to give advice on substantive or procedural matters.

Opening briefs filed in support of and in opposition to a motion should be limited to twenty pages. This includes the table of contents and any attachments or addenda. If a party requires more than twenty pages to explain its position to the Court, a motion to exceed the page limit should be filed setting forth good cause for granting an exception to this rule.

Opening briefs filed in support of and in opposition to a motion should be limited to twenty pages. This includes the table of contents and any attachments or addenda.

Replies and sur-replies are not permitted unless leave to file them is granted upon motion of a party. Such briefs should be attached to a motion for leave as an exhibit, must be concise and address only new issues raised by opposing counsel. The Court discourages any replies or sur-replies that repeat or rehash previous arguments. Any replies or sur-replies must be filed as soon as practicable, but in any event, no later than seven days after the previous filing. Replies and sur-replies, where granted, must be limited to ten and seven pages, respectively.

Yes

Do not send copies--physical or digital--of filings to chambers. If the Court desires a courtesy copy of any particular filing, the Court will reach out and request one specifically.

Contrary to Local Civil Rule 5.1.2(10), all stipulations and proposed orders must be emailed to chambers rather than sent to the Clerk of Court.

Except in emergency situations, no documents may be filed under seal without first obtaining leave. All motions for leave to file documents under seal should be filed on the public docket. In recognition of the common law right of public access to judicial records, a motion for leave to file under seal must articulate, clearly and specifically, why the moving party's "interest in secrecy" outweighs the "presumptive right of public access." In re Avandia Mktg., Sales Pracs. & Prod. Liab. Litig., 924 F.3d 662, 672 (3d Cir. 2019). The motion--and the proposed order attached to the motion--must identify "clearly defined and serious injur[ies]" the movant will suffer if the materials are not kept under seal. Even when the Court grants a motion for leave to file under seal, the Court will generally still expect the parties to file redacted versions of the sealed documents on the public docket unless the redactions would be so extensive as to render the document unreadable. The Court will not approve a protective order containing language that gives the parties discretion to file materials under seal without the Court's prior and specific approval.

If the judge believes oral argument will be helpful in deciding a matter, he will schedule it, particularly when it involves a dispositive motion. A party desiring oral argument should request it by letter.

Unless there is good cause to justify a change, the parties are expected to adhere to the dates contained in the scheduling order. The Court will not entertain extension requests that are based on developments that could reasonably have been anticipated at the time of the Rule 16 conference. Parties' failure to conduct discovery in a timely manner is not good cause for an extension or continuance. If an extension does not affect the deadlines for dispositive motions or trial dates, the parties may present their request for an extension via signed stipulation. Pursuant to Local Rule of Civil Procedure 7.4(b)(2), no stipulation of counsel regarding an extension shall be effective until approved by the Court. If an extension will affect the deadline for filing dispositive motions or the trial dates, counsel must make a written request that sets forth the basis for the extension and indicates whether the other parties agree to or oppose the request and proposes amended dates. A request for an extension of the deadline for filing dispositive motions or a continuance of the trial date must be made sufficiently prior to the due date to allow time for the Court to consider it.

The Court urges the parties to settle discovery disputes among themselves. If Court assistance is required, Judge Gallagher prefers that simple disputes be addressed by telephone conferences. Counsel should provide the Court with a brief letter explaining the discovery dispute and requesting a conference. Such letters should be filed on ECF. For complex disputes, if the parties remain unable to resolve the dispute after the reasonable efforts required by Local Civil Rule 26.1(f), the Court will consider a motion to compel under Local Civil Rule 26.1(b). Counsel for the aggrieved party shall file with the Court a motion in conformity with Local Civil Rule 26.1(b). The motion shall not exceed five pages and shall not contain exhibits and shall not include a brief or memorandum of law. Once a motion to compel is filed, the Court will schedule a telephone or in-person conference with counsel as soon as possible to resolve the dispute. The responding party must file a response within five days. The response should also be limited to five pages and shall not include exhibits or a brief or memorandum of law.