Once a motion is filed, the Court will issue a scheduling order setting forth a response date, a deadline for reply papers (if requested), and an oral argument date (if requested and if the Court deems it necessary).
Pursuant to L. R. Civ. P. 7(a)(2)(C) and L. R. Crim. P. 12(c), a memorandum of law in support of or in opposition to any motion shall not exceed twenty-five pages in length, and a reply memorandum shall not exceed ten pages in length. However, a party may request leave to exceed this page limit by letter sent by fax or email to Chambers, with copies to all counsel, at least one business day before the filing deadline. The request shall identify the amount of additional pages requested.
The Court strongly encourages parties represented by counsel to include a table of contents and table of authorities with all memoranda of law. Citations to legal authority should be included in the text of the memoranda of law – not footnotes.
Courtesy copies of all motion papers should be provided to Chambers. The Court finds it helpful if the courtesy copies include the headers generated upon filing with CM/ECF. When the copies are voluminous, the Court requests that courtesy copies be three-hold punched, tabbed, and placed in three-ring binders.
A schedule may be modified only for good cause and with the Court’s consent (see Fed. R. Civ. P. 16(b)(4)).
Counsel may submit letter requests for an extension of time to submit papers with consent by opposing counsel.
Similarly, letter requests for an adjournment of a scheduled oral argument date may be submitted with consent of opposing counsel so long as submitted at least seven business days prior to the scheduled oral argument date. When submitting a letter request, the requesting party shall discuss proposed new dates with opposing counsel to confirm counsel’s availability, and those proposed dates shall be included in the letter.
In the absence of consent by opposing counsel, a motion for adjournment or extension of time must be filed with the Court.
Immediately after the filing of a request for injunctive or expedited relief in any case assigned to Judge Wolford, the moving party must telephone Chambers to notify the Court that the motion has been filed. The Court shall determine the briefing schedule and return date applicable to any such motions.
Requests for injunctive relief shall be made in the form and manner set forth in L.R. Civ. P. 65. Requests to have the motion heard on an expedited basis must also comply with L. R. Civ. P. 7(d).
Absent extraordinary or unusual circumstances, the Court will not retain jurisdiction to enforce confidential settlement agreements. If the parties wish to have the Court retain jurisdiction over the case, they must obtain the Court’s approval in advance of the filing of such an agreement.
Judge Wolford prefers citations in the Bluebook style. If a pro se litigant is involved in a case, opposing counsel shall provide copies of unpublished cases cited in any memoranda of law pursuant to L. R. Civ. P. 7(a)(8).
The Court strongly encourages litigants to permit more junior members of the litigation team to examine witnesses at trial and hearings, and to appear for oral argument before the Court. Indeed, in those instances where the Court is inclined to rule on the papers, a representation that the argument would be handled by a more junior lawyer will weigh in favor of holding oral argument. In addition, under circumstances where the more junior attorney is permitted to present the argument to the Court, the Court will entertain reasonable requests for the more senior attorney to supplement any argument that is made. The Court believes it is crucial to provide substantive speaking opportunities to young lawyers, and that the benefits of doing so will accrue to all members of the profession and their clients. Thus, the Court encourages all lawyers practicing before it to keep this goal in mind. It is the way one generation will teach the next to try cases and to maintain our district’s reputation for excellence in trial practice.