Communication with Chambers: Counsel are expected to reply with reasonable promptness to inquiries from Chambers. Any discourtesy toward Chambers staff will be viewed as disrespect toward the Court. Counsel should not hesitate to contact Chambers where necessary to facilitate the progress of a case, by phone (267-299-7301), fax (267-299-5020), or email (Chambers_of_Judge_Gerald_McHugh@paed.uscourts.gov). Any communication addressing a substantive issue should also be filed on ECF, and it should be self-evident that no counsel should seek to engage in advocacy during any ex parte contact with any member of the judge's staff.

Yes

Courtesy Copies: Exhibits filed on ECF are difficult to access in an efficient way. If the number of exhibits accompanying a filing exceeds three, counsel must submit a physical courtesy copy to Chambers. The courtesy copy must be three-hole punched and include all exhibits individually tabbed and labeled.

Protective Orders and Confidentiality Agreements: Public policy favors transparency in judicial proceedings. See Pansy v. Borough of Stroudsburg, 23 F.3d 772, 784 (3d Cir. 1994). 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 narrowly tailored. 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 Protective Order is to be emailed to Chambers at: Chambers_of_Judge_Gerald_McHugh@paed.uscourts.gov.

Oral argument will generally only be heard in those cases where the Judge has concluded that it is likely to facilitate resolution of a motion.

Extensions of time: Counsel may agree to extend any filing or discovery deadline that will not delay the scheduling of trial. Routine extensions as a courtesy to opposing counsel, particularly at the outset of a case, are encouraged but do require court approval. If counsel agree to extend a specific deadline, they should email a Stipulation to Chambers and cite these Guidelines. Such Stipulations will be honored unless they are patently unreasonable and interfere with the orderly progress of the case. Any Stipulation that requires court approval is to be emailed to Chambers at: Chambers_of_Judge_Gerald_McHugh@paed.uscourts.gov.

The vast majority of discovery disputes should be settled by the parties through civility and common sense. Judge McHugh expects the parties to have met and conferred in good faith before submitting a discovery dispute. He no longer permits counsel to submit such disputes by letter; a motion must be filed. If a dispute arises during a deposition, counsel are invited to call Chambers in the event that the Judge is available to supply an immediate ruling.