judge console · E.D. Pa.
E.D. Pa. · Judge Cinquanto · Practice Guide

Hon. Caroline Goldner Cinquanto

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

Before You File
Contacting chambers
👤 Judge Cinquanto — standing order

Judge Goldner Cinquanto permits communications from counsel, both written and oral, with her law clerks on procedural matters only. Parties who are pro se (do not have counsel) may only communicate by mail or email to the chambers address above, unless otherwise directed.

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

Silent on page limits for civil motions. The local rules set no district-wide page limit for motions or supporting briefs. Each judge's individual practices govern; consult the assigned judge's chambers procedures. E.D. Pa. L.R. 7.1 ↗

Opposition

Silent on page limits for opposition briefs. The local rules set no district-wide page limit. Each judge's individual practices govern. E.D. Pa. L.R. 7.1 ↗

Reply

Silent on page limits for reply briefs. The local rules set no district-wide page limit. Each judge's individual practices govern. E.D. Pa. L.R. 7.1 ↗

👤 Judge Cinquanto — standing order
Motion

Memoranda must not exceed 30 pages in length (excluding table of contents and appendices), must be double spaced, and must use 12-point font. Memoranda over 15 pages in length must include a table of contents and table of authorities.

Opposition

Briefs accompanying motions and responses to motions are limited to thirty pages absent leave of Court.

Reply

Any reply brief is limited to the issues raised in the response, may not raise theories or issues not discussed in the original motion, and shall not exceed fifteen pages absent leave of Court.

Filing & Scheduling
Briefing schedule & hearing date
🏛 E.D. Pa. local rule
Notice period

Response to motion due within 14 days of service E.D. Pa. L.R. 7.1(c) ↗

Hearing days

Calendar control and other matters affecting the conduct of court business shall be governed by written policy statements on file in the Clerk's Office, which may be adopted or modified by the court in the implementation of the local rules (but not in derogation thereof), and also in the implementation of operating agreements that may be in effect between this court and certain other courts concerning conflicting engagements of counsel, recognition of busy-slips, and the like. E.D. Pa. L.R. 40.3 ↗

Proposed orders
🏛 E.D. Pa. local rule

Proposed order required with every motion E.D. Pa. L.R. 7.1(a) ↗

👤 Judge Cinquanto — standing order

Judge Goldner Cinquanto will not accept stipulated proposed orders in lieu of a motion.

Filing under seal
👤 Judge Cinquanto — standing order

Except in emergency situations, documents should not be filed under seal without first obtaining leave of court. Any motion for leave to file under seal, including any motion for a proposed confidentiality/protective order that would permit a party to file any material under seal, must articulate, clearly and specifically, why the moving party's "interest in secrecy" outweighs the "presumptive right of public access." Avandia, 924 F.3d at 672. 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. Id. Judge Goldner Cinquanto will not grant a motion for leave to file under seal that fails to identify the movant's interests in nondisclosure with specificity. Even when Judge Goldner Cinquanto grants a motion for leave to file under seal, she 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 Hearing
Oral argument
🏛 E.D. Pa. local rule

Oral argument at court's discretion; no automatic right E.D. Pa. L.R. 7.1(f) ↗

Continuances & calendar conflicts
👤 Judge Cinquanto — standing order

Parties are expected to adhere to all deadlines that the Court has implemented by scheduling order or that are otherwise established by rule or statute absent a compelling reason to justify a change. ... If a party believes a compelling reason exists for an extension or a continuance, Counsel shall request a new deadline or date in advance of the originally scheduled date via email (to Chambers_of_Magistrate_Judge_ Goldner_Cinquanto@paed.uscourts.gov). The request shall describe the basis for the request in detail, state whether all other parties agree or disagree with the request, and identify a suggested new deadline(s) or date(s).

Discovery
Discovery referral procedure
🏛 E.D. Pa. local rule

Discovery disputes referred to assigned magistrate judge E.D. Pa. L.R. 72.1 ↗

Discovery dispute procedure
👤 Judge Cinquanto — standing order

Judge Goldner Cinquanto will not entertain a request for judicial intervention if parties or their counsel have exchanged emails or other correspondence but have not made a good faith effort to speak to each other by telephone or video conference regarding a discovery dispute. If a party still requires Court intervention in a discovery dispute after making good faith efforts to communicate with an opposing party, the requesting party shall email Chambers_of_Magistrate_Judge_Goldner_Cinquanto@paed.uscourts.gov to request a telephone conference before filing any discovery motion on the docket. The request shall: (1) describe the parties' prior efforts to resolve their dispute in detail; (2) summarize the matters in dispute; and (3) attach any information relevant to Judge Goldner Cinquanto's consideration of the dispute. Parties are reminded that Federal Rule of Civil Procedure 37 requires parties who file discovery motions to certify "that the movant has in good faith conferred or attempted to confer with the person or party failing to make disclosure or discovery in an effort to obtain it without court action." Fed. R. Civ. P. 37(a)(1). Rule 26.1(f) of the Eastern District of Pennsylvania Local Rules of Civil Procedure also requires discovery motions to include "a certification of counsel that the parties, after reasonable effort, are unable to resolve the dispute." E.D. Pa. Local R. Civ. P. 26.1(f).

Know Before You Go
👤 Judge Cinquanto — deviations that burn people
  • Any attorney for a party or any pro se party who uses generative artificial intelligence ("A.I.") to prepare any complaint, answer, motion, brief, or other paper filed with the Court in a matter assigned to Judge Goldner Cinquanto shall: (1) disclose that generative artificial intelligence was used to prepare the filing; (2) identify precisely what portion or portions of the document contain the generated content; (3) identify the specific tool used and how it was used; and (4) certify that each and every citation to the law or the record in the filing was verified as accurate in accordance with the obligations set forth in Rule 11 of the Federal Rules of Civil Procedure. Failure to comply with this policy may result in consequences such as referral to the appropriate state bar, monetary sanctions, or any other sanction the Court deems appropriate.
content assembled from published local rules & standing orders · click any section in the rail for the full treatment
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