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E.D. Pa. · Judge Kenney · Practice Guide

Hon. Chad F. Kenney

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

Know Before You Go
👤 Judge Kenney — practice notes
  • 1. Pre-filing conference required for Rule 12 motions: Before filing any motion under Fed. R. Civ. P. 12(b)(6), (e), or (f), moving counsel must first contact opposing counsel at least seven days before filing; the Court will deny any motion that fails to include a certification of that conference.
  • 2. No litigation by letter: All substantive communications must be by filed motion or pleading -- letters and emails on case merits are not permitted unless the Court requests them.
  • 3. MSJ: 14-day meet-and-confer required before filing: Parties must meet and confer about material facts at least 14 days before filing the Rule 56 motion, and must include an exhibit index with exact ECF/exhibit/page references.
  • 4. Motions to compel first-set discovery often immediately granted: Kenney frequently grants motions to compel without awaiting a response when the opposing party failed to respond to a first set of discovery requests.
  • 5. Extensions affecting MSJ/trial dates require motion and will likely be denied: Continuances affecting summary judgment, motions in limine, or trial dates require a formal motion and should be expected to be denied absent unforeseeable, insurmountable cause.
Get updates when Judge Kenney's procedures change
Discovery Motions
Who decides discovery disputes in this judge's cases: the judge themself, a referral to a magistrate (always / usually / case-by-case), or a special master?
🏛 E.D. Pa. local rule

In accordance with procedures adopted by the Board of Judges, each district judge shall have an assigned magistrate judge. (p. 50)

Matters shall be referred to magistrate judges at the direction of the district judge to whom the case is assigned. (p. 50)

Local R. Civ. P. 72.1(II)

👤 Judge Kenney — standing order

“In most instances, the assigned Magistrate Judge will conduct settlement conferences, and Judge Kenney will preside over all other litigation matters, including discovery issues.” · Policies and Procedures for Counsel

Pre-motion conferral: required? Format (in person / live / written OK)? Who arranges it, deadline, number of attempts?
🏛 E.D. Pa. local rule

No motion or other application pursuant to the Federal Rules of Civil Procedure governing discovery or pursuant to this rule shall be made unless it contains a certification of counsel that the parties, after reasonable effort, are unable to resolve the dispute. (p. 30)

Local R. Civ. P. 26.1(f)

👤 Judge Kenney — standing order

“Judge Kenney expects the parties to timely confer in good faith and resolve discovery disputes to avoid case management extensions.” · Policies and Procedures for Counsel

“In general, Judge Kenney expects counsel to bring matters to his attention only after such matters have been discussed with opposing counsel.” · Policies and Procedures for Counsel

“When communicating with the Court, counsel shall be prepared to state the position of opposing counsel.” · Policies and Procedures for Counsel

What proof of conferral must be filed or stated (certification, letter, dates, participants, duration)?
🏛 E.D. Pa. local rule

it contains a certification of counsel that the parties, after reasonable effort, are unable to resolve the dispute. (p. 30)

Local R. Civ. P. 26.1(f)

👤 Judge Kenney — standing order

Nothing posted.

Must (or may) the parties get a conference with the court before a written motion (IDC, pre-motion conference, discovery hotline, teleconference)? Required / optional / not offered?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Kenney — standing order

Nothing posted.

The vehicle and contents for raising a dispute with the court: letter / letter-motion / email / form / joint submission. Joint or unilateral? Page or word limits, required contents, attachments.
🏛 E.D. Pa. local rule

Every motion pursuant to the Federal Rules of Civil Procedure governing discovery (p. 29)

Local R. Civ. P. 26.1(b)

👤 Judge Kenney — standing order

“Parties should not email Chambers on substantive matters.” · Policies and Procedures for Counsel

“The Court does not do litigation by letter.” · Policies and Procedures for Counsel

“Disputes that reach an impasse must be brought to the Court's attention by motion as soon as possible.” · Policies and Procedures for Counsel

“Counsel shall file a simple motion briefly explaining the discovery dispute.” · Policies and Procedures for Counsel

“If a dispute is particularly complex, a motion with specific citation to the record, if any, should be filed.” · Policies and Procedures for Counsel

If a written motion is filed: form (joint stipulation, standard motion, letter brief), length, required contents (e.g., verbatim requests and responses), briefing schedule
🏛 E.D. Pa. local rule

Every motion pursuant to the Federal Rules of Civil Procedure governing discovery shall identify and provide, verbatim, the relevant parts of the interrogatory, request, answer, response, objection, notice, subpoena, or depositions in the party’s memorandum. (p. 29)

Counsel may also identify the disputed discovery in an attached exhibit, provided that the exhibit clearly identifies the relevant portions. (p. 29)

Any party responding to the motion shall provide, verbatim, any other part that the party believes necessary to the court's consideration of the motion. (p. 29)

A routine motion to compel answers to interrogatories or to compel compliance with a request for production under Federal Rule of Civil Procedure 34, wherein it is averred that no response or objection has been timely served, need have no accompanying brief, and need have no copy of the interrogatories or Federal Rule of Civil Procedure 34 request attached. (p. 30)

Every motion shall be accompanied by a form of order which, if approved by the court, would grant the relief sought by the motion. (p. 18)

Every motion not certified as uncontested, or not governed by Local Civil Rule 26.1(g), shall be accompanied by a brief containing a concise statement of the legal contentions and authorities relied upon in support of the motion. (p. 18)

Unless the Court directs otherwise, any party opposing the motion shall serve a brief in opposition together with such answer or other response that may be appropriate, within fourteen (14) days after service of the motion and supporting brief. (p. 18)

Counsel are directed to consult each judge’s policies and procedures. (p. 18)

Local R. Civ. P. 26.1(b), 26.1(g), 7.1(a), 7.1(c)

👤 Judge Kenney — standing order

“Any brief or memorandum filed in support of the motion must be limited to twenty-five pages.” · Policies and Procedures for Counsel

“Motions to compel for failure to respond to a first set of discovery requests are often granted immediately without a response.” · Policies and Procedures for Counsel

“Responses to motions to compel and motions to quash subpoenas shall be filed within fourteen days unless otherwise ordered.” · Policies and Procedures for Counsel

Replies, supplemental memos, sur-replies: allowed? Limits?
🏛 E.D. Pa. local rule

The Court may require or permit additional briefs or submissions if the Court deems them necessary. (p. 18)

Local R. Civ. P. 7.1(c)

👤 Judge Kenney — standing order

“Once a Motion and a Response are filed, parties can file reply or surreply briefs without seeking permission from the court.” · Policies and Procedures for Counsel

“There is no timeline for these filings, but the court will not delay a decision on the motion in anticipation of receiving these filings unless the court has itself requested this further briefing.” · Policies and Procedures for Counsel

Must disputes be filed / heard / decided before the discovery cutoff? Any lead-time requirement?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Kenney — standing order

Nothing posted.

Is there a hearing? When, how (in person / phone / video), decided on papers?
🏛 E.D. Pa. local rule

Any interested party may request oral argument on a motion. The court may dispose of a motion without oral argument. (p. 18)

Local R. Civ. P. 7.1(f)

👤 Judge Kenney — standing order

“They are conducted in the courtroom unless there are exigent circumstances that allow for them to be conducted electronically.” · Policies and Procedures for Counsel

“The Court will schedule oral argument when it believes argument will be helpful.” · Policies and Procedures for Counsel

“The Court will on occasion hold telephone conferences to resolve scheduling matters or discovery disputes.” · Policies and Procedures for Counsel

“A motion explaining the dispute and requesting a phone conference should first be filed on the record unless it is a dispute arising during a deposition.” · Policies and Procedures for Counsel

Emergency / ex parte discovery relief (e.g., disputes during a deposition): allowed? How?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Kenney — standing order

“A motion explaining the dispute and requesting a phone conference should first be filed on the record unless it is a dispute arising during a deposition.” · Policies and Procedures for Counsel

“If impertinent or demeaning conduct is demonstrated either by counsel or a witness during the deposition, Judge Kenney is available to address such misconduct and encourages counsel to contact Judge Kenney immediately and not to wait until after the deposition is completed.” · Policies and Procedures for Counsel

Stated consequences for not following the procedure
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Kenney — standing order

Nothing posted.

Hearings & Calendar
When does the judge hear civil motions?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Kenney — standing order

Nothing posted.

How do you get a hearing date? Self-notice on the motion day, reserve with the courtroom deputy first, or the court sets it? Notice period? Closed dates?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Kenney — standing order

“Arguments and hearings are scheduled on a case-by-case basis as warranted.” · Policies and Procedures for Counsel

“If the Judge believes oral argument will be helpful in deciding a matter, he will schedule it, particularly when it involves a dispositive motion.” · Policies and Procedures for Counsel

Is there oral argument by default, or is it decided on the papers? Can the court vacate the hearing?
🏛 E.D. Pa. local rule

The court may dispose of a motion without oral argument. (p. 18)

Local R. Civ. P. 7.1(f)

👤 Judge Kenney — standing order

“Arguments and hearings are scheduled on a case-by-case basis as warranted.” · Policies and Procedures for Counsel

“If the Judge believes oral argument will be helpful in deciding a matter, he will schedule it, particularly when it involves a dispositive motion.” · Policies and Procedures for Counsel

“The Court will schedule oral argument when it believes argument will be helpful.” · Policies and Procedures for Counsel

How do you request oral argument (or a hearing) if it isn't automatic?
🏛 E.D. Pa. local rule

Any interested party may request oral argument on a motion. (p. 18)

Local R. Civ. P. 7.1(f)

👤 Judge Kenney — standing order

Nothing posted.

Does the judge issue tentative rulings? When and where are they posted, and what do you do if you submit on one?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Kenney — standing order

Nothing posted.

Can you appear remotely (phone/video)? How and when to request it?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Kenney — standing order

“Telephone Rule 16s are not favored and are granted only upon exigent circumstances.” · Policies and Procedures for Counsel

“They are conducted in the courtroom unless there are exigent circumstances that allow for them to be conducted electronically.” · Policies and Procedures for Counsel

“Counsel are advised that Judge Kenney does not conduct any court proceedings remotely, virtually or telephonically.” · Policies and Procedures for Counsel

“Consequently, all attorneys and case participants are required to appear in person for all hearings, conferences, trials, and other official court proceedings.” · Policies and Procedures for Counsel

“On rare occasion, Judge Kenney may permit the attorneys and other case participants to appear virtually or telephonically, provided there are extenuating circumstances and good cause is shown.” · Policies and Procedures for Counsel

“However, counsel shall note that any request to appear remotely may or may not be granted.” · Policies and Procedures for Counsel

Does the judge encourage or guarantee argument by newer attorneys?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Kenney — standing order

“Counsel are encouraged to have other trial team members argue all or parts of motions, as well as participate in Rule 16 conferences as long as counsel is giving the team member access to the client and to all information needed to properly prepare.” · Policies and Procedures for Counsel

“On occasion, during a hearing, the court will turn to any one of the trial team members in the courtroom and ask a question about the issue being argued.” · Policies and Procedures for Counsel

“The Court encourages parties to consider some hearings on discovery disputes as an opportunity for associates to argue issues on the record and develop effective advocacy skills.” · Policies and Procedures for Counsel

How do you continue/adjourn a hearing?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Kenney — standing order

Nothing posted.

Courtroom technology and devices: equipment available; phones/laptops allowed; testing in advance
🏛 E.D. Pa. local rule

No judicial proceedings may be broadcast by radio or television, or filmed by still or motion-picture camera or other electronic device, (p. 52)

Except as provided by any applicable standing court order concerning electronic devices, no cameras, broadcasting mechanisms, or electronic device capable of filming or recording may be brought into, or retained or operated within, any district court courtroom or any hall on the same floor as such courtroom. (p. 52)

Local R. Civ. P. 83.3(a), (b)

👤 Judge Kenney — standing order

“Courtroom 11B is not equipped with audio and video systems for the presentation of exhibits.” · Policies and Procedures for Counsel

“As such, if the attorneys would like to use any electronic presentation technology, then counsel must supply their own equipment.” · Policies and Procedures for Counsel

“The deputy clerk will need to provide security clearance for those individuals or firms delivering any technology systems to the courtroom.” · Policies and Procedures for Counsel

“The Court also prefers that counsel coordinate the operational use of one technology system.” · Policies and Procedures for Counsel

Stated consequences for hearing-related noncompliance ⚠
🏛 E.D. Pa. local rule

No attorney shall, without just cause, fail to appear when that attorney's case is before the court on a call, motion, pretrial proceeding, or trial, (p. 66)

Any attorney who fails to comply with (a) or (b) may be disciplined as the court shall deem just. (p. 66)

Local R. Civ. P. 83.6.1(b), (c)

👤 Judge Kenney — standing order

“If the 26(f) is not timely filed, the Rule 16 may be cancelled with an Order that counsel file a status report addressing the failure to file.” · Policies and Procedures for Counsel

Summary Judgment
How many SJ motions may each party (or side) file, and how do you get leave for more?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Kenney — standing order

Nothing posted.

What page limits apply to SJ briefs, where they differ from the general motion limits?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Kenney — standing order

Nothing posted.

Do you need the court's permission, a pre-motion conference or letter, a status report, or advance notice before filing?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Kenney — standing order

Nothing posted.

Can you move for SJ before discovery closes?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Kenney — standing order

Nothing posted.

When must the motion be filed or heard, and on what briefing schedule?
🏛 E.D. Pa. local rule

Unless the Court directs otherwise, any party opposing the motion shall serve a brief in opposition together with such answer or other response that may be appropriate, within fourteen (14) days after service of the motion and supporting brief. (p. 18)

Local Civ. R. 7.1(c)

👤 Judge Kenney — standing order

“Unless there is extremely good cause to justify change, the parties are expected to strictly adhere to the dates contained in the scheduling order.” · Policies and Procedures for Counsel

“The Court will grant a continuance or extension based on a stipulation of all parties if the continuance or extension will not affect the deadlines for filing motions for summary judgment, motions in limine, or the trial date.” · Policies and Procedures for Counsel

“A continuance or extension that may affect the deadlines for filing motions for summary judgment, motions in limine, or the trial date must be made by motion sufficiently in advance of the deadline date.” · Policies and Procedures for Counsel

“Parties should expect these motions will be DENIED unless unforeseeable, insurmountable causes are established.” · Policies and Procedures for Counsel

Before filing, must the movant confer with or serve SJ papers on the opponent, and how far ahead?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Kenney — standing order

“No later than fourteen days before filing any summary judgment motion pursuant to Rule 56, the parties shall meet and confer about the material facts.” · Policies and Procedures for Counsel

What kind of fact statement does the judge want?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Kenney — standing order

“The movant's initial filing must include a concise statement of stipulated material facts, setting forth in numbered paragraphs the material facts and important background facts that are not in dispute for purposes of summary judgment.” · Policies and Procedures for Counsel

“To the extent that any party seeks to rely on facts not included in the concise statement of material facts, it shall set forth those facts in a concise statement of additional facts.” · Policies and Procedures for Counsel

Is there a cap on the fact statement (and the response)?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Kenney — standing order

Nothing posted.

How must the fact statement and responses be laid out?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Kenney — standing order

“The movant's initial filing must include a concise statement of stipulated material facts, setting forth in numbered paragraphs the material facts and important background facts that are not in dispute for purposes of summary judgment.” · Policies and Procedures for Counsel

“Citations to the summary judgment record should be included for each stipulated fact where possible.” · Policies and Procedures for Counsel

“Like the statement of stipulated facts, the statement of additional facts shall be organized in numbered paragraphs.” · Policies and Procedures for Counsel

“The party shall provide citations to the precise page of the summary judgment record that supports each factual assertion in the statement of additional facts.” · Policies and Procedures for Counsel

How do you raise evidentiary objections to the other side's SJ evidence?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Kenney — standing order

Nothing posted.

How must SJ evidence be assembled?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Kenney — standing order

“Counsel must identify where an exhibit referred to in the Motion or Response can be found in the record pursuant to the instructions set forth herein in the Summary Judgment section.” · Policies and Procedures for Counsel

“Counsel must include with their Rule 56 Motion an index clearly identifying each referenced exhibit and indicating where it can be found in the filing.” · Policies and Procedures for Counsel

“Parties, when referring to a document in their motion, must identify exactly by ECF number and exhibit number and page number in the exhibit where the court can find the document referred to.” · Policies and Procedures for Counsel

“The best practice is to file an index of exhibits referenced in the Motion or Response with the Motion or Response, identifying the exhibit, its content, and where it can be found on the ECF (see Local Rule 5.1.2, Subsection 5(b)).” · Policies and Procedures for Counsel

Do you file full deposition transcripts or only the cited excerpts?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Kenney — standing order

Nothing posted.

In the brief, do you cite the record, the fact statement, or both? Must the brief carry its own statement of facts?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Kenney — standing order

Nothing posted.

If the motion or opposition depends on excluding an expert, how and when must the challenge be raised?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Kenney — standing order

Nothing posted.

How are cross-motions handled?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Kenney — standing order

Nothing posted.

Will the judge entertain SJ in a non-jury case?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-17).

👤 Judge Kenney — standing order

Nothing posted.

What consequences does the judge's own text state for SJ noncompliance?
🏛 E.D. Pa. local rule

In the absence of a timely response, the motion may be granted as uncontested except as provided under Federal Rule of Civil Procedure 56, or otherwise prohibited by law. (p. 18)

Local Civ. R. 7.1(c)

👤 Judge Kenney — standing order

Nothing posted.

Pro Hac Vice
What does PHV admission cost, who pays it, and is it ever waived? ⚠
🏛 E.D. Pa. local rule

No admission shall be effective until such time as the fee has been paid, except that any counsel appearing in a case transferred pursuant to an Order of the Judicial Panel on Multidistrict Litigation need not pay such a fee. (p. 56)

Standing Order (Feb. 13, 2023); LCvR 83.5.2(b); form

👤 Judge Kenney — standing order

“If the admission fee is not submitted at the time the application for pro hac vice is filed on the docket, the application will be denied pending submission of payment.” · Policies and Procedures for Counsel

Must PHV counsel associate with local counsel (a member of this court's bar), and who qualifies?
🏛 E.D. Pa. local rule

(a) Except for attorneys appearing on behalf of the United States Government or a department or agency thereof pursuant to Local Civil Rule 83.5(e), any attorney who is not a member of the bar of this court shall, in each proceeding in which that attorney desires to appear, have as associate counsel of record a member of the bar of this court upon whom all pleadings, motions, notices and other papers can be served conformably to the Federal Rules of Civil Procedure and the local rules of this court. (p. 56)

LCvR 83.5.2(a)

👤 Judge Kenney — standing order

Nothing posted.

Who files the PHV motion or application: the applicant, or local or sponsoring counsel?
🏛 E.D. Pa. local rule

(b) An attorney who is not a member of the bar of this Court shall not actively participate in the conduct of any trial or pre-trial or post-trial proceeding before this Court unless, upon motion of a member of the bar of this Court containing a verified application, leave to do so shall have been granted. (p. 56)

LCvR 83.5.2(b)

👤 Judge Kenney — standing order

“To be admitted pro hac vice, local counsel of record should submit the "Attorney Admission Application (Pro Hac Vice)" available at https://www.paed.uscourts.gov/attorneys.” · Policies and Procedures for Counsel

What proof of good standing is required (a certificate or a sworn statement), from which bars, and how recent?
🏛 E.D. Pa. local rule

C. I state that I am at present a member of the aforesaid bar(s) in good standing, and that I will demean myself as an attorney of this court uprightly and according to law, and that I will support and defend the Constitution of the United States. (p. 2)

The undersigned member of the bar of the United States District Court for the Eastern District of Pennsylvania hereby moves for the admission of _______________________________________________ to practice in said court pursuant to Local Rule of Civil Procedure 83.5.2(b), and certify that I know (or after reasonable inquiry believe) that the applicant is a member in good standing of the above-referenced state and federal court(s) and that the applicant's private and personal character is good. (p. 3)

Court form

👤 Judge Kenney — standing order

Nothing posted.

What must the PHV motion or application contain, and must (or may not) a particular form be used?
🏛 E.D. Pa. local rule

(b) An attorney who is not a member of the bar of this Court shall not actively participate in the conduct of any trial or pre-trial or post-trial proceeding before this Court unless, upon motion of a member of the bar of this Court containing a verified application, leave to do so shall have been granted. (p. 56)

LCvR 83.5.2(b); court form

👤 Judge Kenney — standing order

“To be admitted pro hac vice, local counsel of record should submit the "Attorney Admission Application (Pro Hac Vice)" available at https://www.paed.uscourts.gov/attorneys.” · Policies and Procedures for Counsel

By when must the PHV motion be filed or granted: before a filing, before a conference, or at the first appearance? Is an oral motion allowed?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Kenney — standing order

Nothing posted.

Must PHV counsel register for ECF (or is it barred), and by when?
🏛 E.D. Pa. local rule

________________ is DIRECTED to request ECF filing access using their PACER Account1. (p. 1)

Court form (proposed order)

👤 Judge Kenney — standing order

Nothing posted.

What must local counsel do once PHV counsel is in the case (attend conferences or hearings, sign filings, know the case, accept service, answer for PHV counsel)?
🏛 E.D. Pa. local rule

At least one associate counsel shall maintain their appearance on the docket until the conclusion of the case or until granted leave to withdraw by the court. (p. 56)

(a) Except for attorneys appearing on behalf of the United States Government or a department or agency thereof pursuant to Local Civil Rule 83.5(e), any attorney who is not a member of the bar of this court shall, in each proceeding in which that attorney desires to appear, have as associate counsel of record a member of the bar of this court upon whom all pleadings, motions, notices and other papers can be served conformably to the Federal Rules of Civil Procedure and the local rules of this court. (p. 56)

LCvR 83.5.2(a)-(b)

👤 Judge Kenney — standing order

“The admission of out-of-the-jurisdiction counsel pro hac vice does not relieve local counsel of responsibility for the matter before the Court.” · Policies and Procedures for Counsel

“Local counsel must have a full grasp of the case and these Policies to ensure compliance and be ready to appear before the Court or respond to Chambers staff if pro hac vice counsel is not available.” · Policies and Procedures for Counsel

Must the PHV motion state the other parties' position or consent, or confer with them first? When may the other side oppose?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Kenney — standing order

Nothing posted.

What consequences does the judge's own text state for PHV problems (revocation of PHV status, denial, a duty to bring in local counsel)? ⚠
🏛 E.D. Pa. local rule

No admission shall be effective until such time as the fee has been paid, except that any counsel appearing in a case transferred pursuant to an Order of the Judicial Panel on Multidistrict Litigation need not pay such a fee. (p. 56)

LCvR 83.5.2(b)

👤 Judge Kenney — standing order

“If the admission fee is not submitted at the time the application for pro hac vice is filed on the docket, the application will be denied pending submission of payment.” · Policies and Procedures for Counsel

Are attorneys who live, work, or are barred in this state excluded from PHV and sent to full admission?
🏛 E.D. Pa. local rule

I, _________________________________________ the undersigned, am an attorney who is not currently admitted to either the bar of this court or the bar of the Supreme Court of Pennsylvania, and I hereby apply for admission to practice in this court pursuant to Local Rule of Civil Procedure 83.5.2(b) to represent ________________________. (p. 2)

Standing Order (Feb. 13, 2023); court form

👤 Judge Kenney — standing order

Nothing posted.

Is there a cap on how often an attorney may appear PHV, or a required disclosure of past PHV applications?
🏛 E.D. Pa. local rule

No local rule on this point (checked, as of 2026-10-24).

👤 Judge Kenney — standing order

Nothing posted.

Do government attorneys need PHV admission, and are they exempt from the fee or local counsel?
🏛 E.D. Pa. local rule

(e) Any attorney who is a member in good standing of the bar of the highest court of any state, territory, or the District of Columbia may, without being admitted generally as an attorney of this Court, act as an attorney in this Court on behalf of the United States Government or any of its departments or agencies. (p. 53)

LCvR 83.5(e); 83.5.2(a)

👤 Judge Kenney — standing order

Nothing posted.

Other procedures for Judge Kenney
Before You File
Contacting chambers
👤 Judge Kenney — standing order

Communications and correspondence regarding civil and criminal cases should be directed to Judge Kenney's Deputy Clerk, Shelli L. MacElderry, at telephone number (267) 299-7541 or email address Chambers_of_Judge_Chad_F_Kenney@paed.uscourts.gov. Any contact should only come after notifying other counsel of the intent to reach out to Chambers. Emails with any Chambers personnel should copy the Chambers email address. Parties should not email Chambers on substantive matters. Parties may contact Chambers via email in the following situations: (1) When counsel are specifically requested by the Court to communicate some information by letter or email or in response to same by the Court; (2) When there is an uncontested request for a continuance of the Rule 16 Scheduling Order deadlines not affecting the summary judgment date and dates thereafter including trial; (3) When the participation of counsel in the case is expected to be affected by a personal matter concerning counsel, a party, a witness, or counsel's immediate family, such as medical problems, vacation plans, or other similarly personal problems or questions; (4) When the parties seek Court approval of stipulated proposals; (5) When the parties have remaining administrative or scheduling questions after reading the Policies; (6) To confirm or advise the Court that a case has been settled, dismissed, or otherwise finally disposed; or (7) If counsel has not received a disposition on a motion for class certification, for summary judgment, or a motion requiring a decision regarding qualified immunity within ninety days of the motion being fully briefed (and argued where applicable); or sixty days for all other motions. All other communications with the Court concerning any case assigned to Judge Kenney's calendar should be made by the filing of a pleading, motion or other filing provided for in the Federal Rules of Civil or Criminal Procedure or the Local Rules. Do not write letters or emails to the Court that are properly the subject of these filings unless given authorization. The Court does not do litigation by letter.

Drafting the Motion
Length limits — motion, opposition, reply
🏛 E.D. Pa. local rule
Opposition

Silent on page limits for opposition briefs. E.D. Pa. L.R. 7.1 (silent) ↗

Reply

Silent on page limits for reply briefs. E.D. Pa. L.R. 7.1 (silent) ↗

👤 Judge Kenney — standing order
Reply

Once a Motion and a Response are filed, parties can file reply or surreply briefs without seeking permission from the court. There is no timeline for these filings, but the court will not delay a decision on the motion in anticipation of receiving these filings unless the court has itself requested this further briefing.

Filing & Scheduling
Chambers / courtesy copies
👤 Judge Kenney — standing order
Details

In the event the Court orders copies to be sent to Chambers or counsel is sending hard courtesy copies to Chambers, counsel must provide two copies which are single-sided, printed in color (if applicable), and if including exhibits - they must be appropriately tabbed/indexed. If the hard copies are over 30 pages, the copies cannot be stapled - the copies should be placed in a three-ring binder.

Proposed orders
🏛 E.D. Pa. local rule

(a) Every motion shall be accompanied by a form of order which, if approved by the court, would grant the relief sought by the motion. Every response in opposition to a motion shall be accompanied by a form of order, which, if approved by the court, will deny or amend the relief sought by the motion. E.D. Pa. L.R. 7.1(a) ↗

Filing under seal
👤 Judge Kenney — standing order

The Court will only approve confidentiality or sealing orders for good cause shown. Public policy favors transparency in judicial proceedings. Protective orders and confidentiality agreements undermine such transparency and complicate the resolution of cases at both the trial and appellate level. They should be used sparingly and be narrowly tailored. The parties may redact highly sensitive Personally Identifiable Information (PII) that is not relevant to the disposition of the case without leave of Court. No protective order or confidentiality order will be approved without language providing that "the Court reserves its inherent power to modify the terms of this agreement and permit the disclosure of information where the interest of justice so requires." Except in exceptional circumstances, documents or evidence that form the basis for judgment in a case are unlikely to be protected against disclosure. Any stipulation for a protective order should be sent to Chambers via email for Court approval.

More from Judge Kenney’s procedures
👤 Judge Kenney — standing order
Summary judgment procedure

No later than fourteen days before filing any summary judgment motion pursuant to Rule 56, the parties shall meet and confer about the material facts. The movant's initial filing must include a concise statement of stipulated material facts, setting forth in numbered paragraphs the material facts and important background facts that are not in dispute for purposes of summary judgment. Citations to the summary judgment record should be included for each stipulated fact where possible. Counsel must include with their Rule 56 Motion an index clearly identifying each referenced exhibit and indicating where it can be found in the filing. Parties, when referring to a document in their motion, must identify exactly by ECF number and exhibit number and page number in the exhibit where the court can find the document referred to. Source ↗

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