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

Hon. Gerald A. McHugh

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

Know Before You Go
👤 Judge McHugh — deviations that burn people
  • 1. No SUMF unilaterally filed: Unlike most federal judges, McHugh prohibits unilateral Statements of Undisputed Facts on MSJ -- facts must be embedded in the memorandum with record cites, or the motion may be denied or filing stricken.
  • 2. Discovery disputes require a motion, not a letter: McHugh no longer permits letter submissions for discovery disputes -- a full motion must be filed after good-faith meet-and-confer.
  • 3. Courtesy copies triggered at 4+ exhibits: Any filing with more than 3 exhibits requires a physical three-hole-punched copy to chambers with all exhibits individually tabbed and labeled.
  • 4. Substantive communications must be ECF-filed: Any communication with chambers that addresses a substantive issue must also be filed on ECF -- no substantive advocacy during ex parte staff contact.
  • 5. Magistrate referrals are strictly limited: Judge McHugh is paired with Magistrate Judge Jose Arteaga, but strictly limits referrals to settlement conferences and will not refer routine diversity cases -- do not assume broad discovery-dispute referral to the magistrate.
Get updates when Judge McHugh'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 McHugh — standing order

“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.” · Guidelines 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 McHugh — standing order

“The vast majority of discovery disputes should be settled by the parties through civility and common sense.” · Guidelines for Counsel

“Judge McHugh expects the parties to have met and conferred in good faith before submitting a discovery dispute.” · Guidelines 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 McHugh — 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 McHugh — 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 McHugh — standing order

“He no longer permits counsel to submit such disputes by letter; a motion must be filed.” · Guidelines 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 McHugh — standing order

“Joint or unopposed motions should be clearly identified as such in the title of the pleading, so that they can be given expedited consideration.” · Guidelines for Counsel

“Each document filed as an exhibit on ECF must be filed as a separately numbered attachment to the main document and must be clearly titled with an objective description of the document (e.g., 6/14/19 Deposition of John Doe; 10/14/21 Letter from Smith to Jones; 3/15/20-3/23/20 Email Thread between Doe and Roe) so that the nature of the exhibit and its relevance are clearly discernible without the need to open the file.” · Guidelines for Counsel

“All filings must also separately include an index providing the above information.” · Guidelines for Counsel

“In all motions and pleadings, references to other documents on the docket, e.g. "Plaintiff's Second Amended Complaint," should identify those documents by their ECF number to facilitate retrieval.” · Guidelines 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 McHugh — standing order

“Supplemental briefs, reply briefs, and sur-reply briefs may be filed without seeking leave, but once an initial opposition brief has been filed, the Court will begin considering the merits of the issue.” · Guidelines 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 McHugh — 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 McHugh — standing order

“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.” · Guidelines 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 McHugh — standing order

“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.” · Guidelines 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 McHugh — 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 McHugh — 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 McHugh — standing order

Nothing posted.

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 McHugh — standing order

“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.” · Guidelines 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 McHugh — 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 McHugh — 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 McHugh — standing order

“Lead trial counsel must appear in person.” · Guidelines for Counsel

“If lead trial counsel is absolutely unable to attend, the conference will be rescheduled.” · Guidelines for Counsel

“Pro hac vice motions are liberally granted, but any counsel so admitted must be prepared to participate in person in all proceedings from the inception of the case.” · Guidelines 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 McHugh — standing order

Nothing posted.

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 McHugh — standing order

“Counsel should be mindful that every continuance of a hearing increases the work of the Clerk's Office and disrupts the schedules of the lawyers who volunteer to sit as arbitrators because of the need to appoint a new panel.” · Guidelines for Counsel

“Judge McHugh may direct the Clerk's Office not to assign a new hearing date until the parties report that they are ready to proceed.” · Guidelines for Counsel

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 McHugh — standing order

Nothing posted.

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 McHugh — standing order

Nothing posted.

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 McHugh — 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 McHugh — 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 McHugh — 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 McHugh — 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 McHugh — standing order

Nothing posted.

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 McHugh — standing order

Nothing posted.

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 McHugh — standing order

“When filing a Motion for Summary Judgment, except for a formal stipulation setting forth facts agreed to in their entirety by all parties, no party shall unilaterally file a "Statement of Undisputed Facts" setting forth its interpretation of the record, or any separate "Statement of Facts" apart from its memorandum of law.” · Guidelines for Counsel

“All references to the facts must be contained within the party's memorandum and cite to the record.” · Guidelines for Counsel

“Failure to abide by this instruction may result in the motion being denied or a filing being stricken.” · Guidelines 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 McHugh — 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 McHugh — standing order

Nothing posted.

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 McHugh — 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 McHugh — standing order

Nothing posted.

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 McHugh — 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 McHugh — standing order

“When filing a Motion for Summary Judgment, except for a formal stipulation setting forth facts agreed to in their entirety by all parties, no party shall unilaterally file a "Statement of Undisputed Facts" setting forth its interpretation of the record, or any separate "Statement of Facts" apart from its memorandum of law.” · Guidelines for Counsel

“All references to the facts must be contained within the party's memorandum and cite to the record.” · Guidelines for Counsel

“Failure to abide by this instruction may result in the motion being denied or a filing being stricken.” · Guidelines for Counsel

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 McHugh — 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 McHugh — 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 McHugh — 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 McHugh — standing order

“Failure to abide by this instruction may result in the motion being denied or a filing being stricken.” · Guidelines for Counsel

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 McHugh — standing order

Nothing posted.

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 McHugh — 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 McHugh — standing order

Nothing posted.

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 McHugh — 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 McHugh — standing order

Nothing posted.

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 McHugh — 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 McHugh — 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 McHugh — standing order

Nothing posted.

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 McHugh — 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 McHugh — standing order

Nothing posted.

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 McHugh — 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 McHugh — 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 McHugh — standing order

Nothing posted.

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

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.

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) ↗

Filing & Scheduling
Chambers / courtesy copies
👤 Judge McHugh — standing order
Standing order

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.

Details

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.

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 McHugh — standing order

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.

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

When filing a Motion for Summary Judgment, except for a formal stipulation setting forth facts agreed to in their entirety by all parties, no party shall unilaterally file a "Statement of Undisputed Facts" setting forth its interpretation of the record, or any separate "Statement of Facts" apart from its memorandum of law. All references to the facts must be contained within the party's memorandum and cite to the record. Failure to abide by this instruction may result in the motion being denied or a filing being stricken. Source ↗

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