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

Hon. Joshua D. Wolson

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

Before You File
Contacting chambers
👤 Judge Wolson — standing order

Counsel should direct communications concerning administrative or procedural matters to a Courtroom Deputy or Chambers. Letters (when appropriate) may be submitted to Judge Wolson via email, but such communications should be limited to routine matters for which no opposition is anticipated or required. Responsive letters should only be submitted at Judge Wolson's request.

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 Wolson — standing order
Motion

Opening briefs in support of and in opposition to a motion shall not exceed twenty-five (25) pages, unless counsel includes a certification that the brief contains no more than 8,750 words.

Opposition

Opening briefs in support of and in opposition to a motion shall not exceed twenty-five (25) pages, unless counsel includes a certification that the brief contains no more than 8,750 words. Replies shall not exceed ten (10) pages or 3,500 words, and sur-replies shall not exceed seven (7) pages or 2,450 words.

Reply

Replies shall not exceed ten (10) pages or 3,500 words, and sur-replies shall not exceed seven (7) pages or 2,450 words. Judge Wolson must receive any request to exceed an applicable page limit at least seven (7) days before the filing is due. Any replies or sur-replies must be filed as soon as practicable, but in any event, no later than seven (7) days after the previous filing.

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 ↗

Chambers / courtesy copies
👤 Judge Wolson — standing order
Required?

Yes

Details

Judge Wolson only requires courtesy copies in two circumstances: (1) for any filings made under seal; and (2) for any motions with more than five (5) exhibits. Parties should submit courtesy copies electronically via email to WolsonCourtesyCopy@paed.uscourts.gov and use the case caption, title of the filing, and ECF number in the subject line. Each submission should use the e-filed version that has the CM/ECF system's header at the top of the page. Each document must be a separate file, with a file name that is consistent with the descriptive name that the document has on the CM/ECF system. Parties may not submit courtesy copies via Dropbox, FTP, or some other source that requires Judge Wolson to download files to Judge Wolson's system. Instead, files should be emailed, even if that requires multiple emails. Parties also should not submit paper courtesy copies.

Proposed orders
🏛 E.D. Pa. local rule

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

👤 Judge Wolson — standing order

Contrary to Local Civil Rule 5.1.2(10), parties must email all stipulations and proposed orders to Chambers rather than send them to the Clerk of Court.

Filing under seal
👤 Judge Wolson — standing order

Any party seeking to file material under seal must familiarize itself with the standard set forth in In re Avandia Mktg., Sales Pracs. & Prod. Liab. Litig., 924 F.3d 662 (3d Cir. 2019). A party that seeks to file material under seal must file a sealing motion when it files the material that it seeks to seal. Except in emergency situations, a party may not file a document under seal (or redact necessary and/or substantive information) without a contemporaneous motion to seal the specified information (or without a motion filed in advance that identifies specific information to be placed under seal). A party seeking leave to file material under seal must file its motion of record and provide Judge Wolson via email with courtesy copies of all documents that the party proposes to file under seal. In recognition of the common law right of public access, Judge Wolson requires parties to file a redacted version of any sealed document on the public record, unless the redactions would be so extensive as to render the document unreadable. When filing a redacted document, a party must submit to Chambers or file on CM/ECF an unredacted version that highlights any portion that the party proposes to redact. Judge Wolson expects parties to work together when filing motions to seal. That is, if a party seeks to file under seal material that an opponent has marked "confidential," the parties must work together to prepare the required information (such as affidavits or other material necessary to carry the burden of placing material under seal). If a party fails in this obligation, Judge Wolson will consider imposing the costs of additional proceedings (including responses or reconsideration motions necessary to supplement the record) on that party. For any motion or submission in which parties designate more than 10 individual references (that is, separate exhibits or different excerpts of single exhibits) for sealing, Judge Wolson will likely refer the sealing motion to a special master, and Judge Wolson will determine on a case-by-case basis how to split the special master's costs.

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 Wolson — standing order

Judge Wolson is reluctant to grant continuances of trial dates and other scheduled court events and will only do so in extreme circumstances. Judge Wolson will consider other requests for extensions on an appropriate showing of good cause. Requests for continuances or extensions may be made by letter, which can be emailed to Chambers. Any request for a continuance or extension must include the words "request for continuance" or "request for extension," as appropriate, in the subject line of the email. Judge Wolson expects counsel for the party requesting an extension to confer with opposing counsel and state opposing counsel's position in the letter. Any request for an extension or continuance must be made at least seven (7) days before the applicable deadline or include a showing of good cause as to why the Party making the request could not comply with that requirement.

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 Wolson — standing order

Judge Wolson urges the parties to settle discovery disputes among themselves. However, if the parties remain unable to resolve a dispute despite making a good faith effort, counsel for the aggrieved party shall file with Judge Wolson a motion in conformity with Local Civil Rule 26.1(b), with a form of order and short brief, not to exceed five (5) pages or 1,750 words (not including exhibits), describing the dispute. All discovery motions must attach the discovery requests at issue, as well as the written response. Judge Wolson will schedule a telephone conference with counsel to discuss the motion before the filing of any responsive brief. In filing a discovery motion, the certificate of counsel must provide specific details of the parties' efforts to resolve the dispute informally. These efforts must include verbal communications, whether by phone or in person. Exchanges of letters or e-mails are not sufficient. It is not sufficient to report that opposing counsel was not available or that the parties made "reasonable efforts." Judge Wolson will deny a discovery motion that does not meet these requirements.

Know Before You Go
👤 Judge Wolson — deviations that burn people
  • 1. Pre-motion letter required before any Rule 12 motion: counsel must have a substantive verbal discussion (phone or in person) at least one week before the filing deadline; letters and emails do not satisfy the obligation. Failure to submit the required 5-page pre-motion letter results in no briefing schedule being set.
  • 2. Joint consolidated statement of facts for MSJ: the moving party must serve (not file) its draft SUMF 28 days before the filing deadline; respondent serves its response 14 days before deadline. Skipping either service deadline breaks the entire consolidated-SUMF process.
  • 3. Footnote ban: Judge Wolson will not consider substantive arguments made in footnotes and will not deem them preserved. Moving an argument to a footnote to save space eliminates it from the case.
  • 4. Email subject line discipline: emails lacking required verbiage (e.g., "request for extension," "proposed order," "page limits") will be filtered and may not receive prompt attention.
  • 5. Courtesy copies are emailed only (never paper); filings with a single combined "Exhibits" document will be stricken.
content assembled from published local rules & standing orders · click any section in the rail for the full treatment
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