PRACTICES AND PROCEDURES BEFORE
JUDGE JAMES PATRICK HANLON
Counsel are expected to have read and to comply with these Practices and
Procedures. Counsel may seek modification of any part of these Practices and
Procedures as appropriate in a specific case. The Court may also alter them as
appropriate in any case. Inquiries should be directed to the Courtroom Deputy
Clerk, Carina Weed, at 317-229-3962 or
[email protected].
INDEX
I. General Courtroom Expectations …………………..………………….. 2
II. Motions Practice ……………………..………………………..…………… 2
A. Filing Motions with Supporting Briefs and Exhibits …….... 2
B. Rule 12 Motions ……………………………………………………. 2
C. Summary Judgment Motions …………………………………… 3
D. Motions for Preliminary Injunctive Relief …………………….. 4
E. Objections under Fed. R. Civ. P. 72(a) ………………………… 4
F. Oral Argument ……………………………………………………… 4
G. Pending Ripe Motions ………..………………………......……… 4
III. Trial ………….……………………………………………………………….. 5
A. Trial Dates in Civil Cases ………………………………………… 5
B. The Final Pretrial Conference …………………………………… 5
C. The Venire and Voir Dire …………………….…………………… 6
D. Opening Statements and Closing Argument ………......…… 6
E. Examination of Witnesses …………..…………...……………… 7
F. Objections to Questions ………………..……………………..…. 7
G. Difficult Issues—Advance Notice ……………………..……..…. 8
H. Stipulations ……………...……..………………………..………… 8
I. Use of Depositions ………………..……………..………………… 8
J. Exhibits ……………………………..…..…………………………… 9
K. Jury Instructions and Verdict Forms ………………....……… 11
L. Experts ………………..…………..………….……………………… 12
M. Jurors ……………....………..……….…………………………….. 12
N. Logistics and Housekeeping ……………..………..……………. 12
O. Facilities ……………..………..…………………………………….. 13
P. Transcripts …………..………..……………………………………. 14
Appendix A: Procedure for Filings Exhibits and Citation Form …………. 15
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I. GENERAL COURTROOM EXPECTATIONS
A. Be in the courtroom at least 15 minutes before the scheduled starting
time of the hearing or proceeding. This ensures that counsel have time
to confer if needed and otherwise be prepared for the hearing to start on
time.
B. Know the Federal Rules of Civil and/or Criminal Procedure, the Federal
Rules of Evidence, and the Local Rules of the United States District
Court for the Southern District of Indiana.
C. Stand when speaking and address the Court, not opposing counsel.
D. Conversation between counsel and/or parties when opposing counsel is
questioning or arguing must not be distracting to others.
E. Silence your cell phones and similar devices and do not use them when
court is in session.
II. MOTIONS PRACTICE
A. Filing Motions with Supporting Briefs and Exhibits
Motions and exhibits must be filed before supporting briefs so that the brief's
citations refer back to the motion's and exhibits' docket numbers. Exhibits
may be attached to the motion, as Appendix A shows, or filed separately. If
filed separately, the motion must be filed before the exhibits.
When electronically filing exhibits, number the exhibits and add a descriptive
identifier. E.g., "Ex. 1 – Smith Dep." or "Ex. 3 – Smith Employment Agreement"
instead of just "Exhibit 1" or "Exhibit 3."
See Appendix A to these Practices and Procedures for examples of proper
descriptive identifiers for electronically filed exhibits.
B. Rule 12 Motions
Plaintiffs may generally amend their complaints "once as a matter of course"
within "21 days after service of a motion under Rule 12(b), (e), or (f)." Fed. R.
Civ. P. 15(a)(1). When a complaint is amended, the Court's standard practice is
to deny a Rule 12 motion without prejudice as moot.
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C. Summary Judgment Motions
1. Counsel planning to move for summary judgment must contact counsel
for the other parties to determine if any other party also plans to move
for summary judgment. If opposing parties plan to move for summary
judgment, the following modified briefing process applies:
a. Motion and Brief in Support by Party A (limited to 30 pages);
b. Cross-Motion, Brief in Support, and Response in Opposition by
Party B (limited to 45 pages);
c. Reply in Support of Motion and Response in Opposition to Cross-
Motion by Party A (limited to 30 pages);
d. Reply in Support of Cross-Motion by Party B (limited to 15 pages).
2. In other situations, or if a party believes that a different process is
appropriate, counsel may file a motion with a proposed briefing process
that states the position of all other counsel.
3. Motions to exceed page limitations are disfavored. Similarly, "[c]ollateral
motions in the summary judgment process, such as motions to strike,
are disfavored. Any dispute regarding the admissibility or effect of
evidence should be addressed in the briefs." S.D. Ind. L.R. 56-1(i).
4. Briefs on Summary Judgment shall comply with Local Rule 56-1(e):
"A party must support each fact the party asserts
in a brief with a citation to a discovery response,
a deposition, an affidavit, or other admissible
evidence. The evidence must be in the record or
in an appendix to the brief. The citation must
refer to a page or paragraph number or otherwise
similarly specify where the relevant information
can be found in the supporting evidence."
See also Fed. R. Civ. P. 56(e). Parties therefore must specifically cite
evidence for each fact in the fact and argument sections. Unsupported
facts may be disregarded. See Bluestein v. Cent. Wisconsin
Anesthesiology, S.C., 769 F.3d 944 n.1 (7th Cir. 2014).
5. Deposition Citations & Excerpts
Deposition cites must include specific page and line numbers. The cited
pages—and at least the three pages immediately preceding and
following—must be included as an exhibit. The Court may decline to
consider evidence that does not include the entire excerpts.
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6. Citation Form
See Appendix A to these Practices and Procedures for examples of proper
citation format. In a supporting brief, cite the docket number, the
attachment number (if any), and the .pdf page number. For example:
Mr. Smith signed an employment agreement with ABC
Corporation on May 1, 2012. Dkt. 42-8 at 5.
That citation would refer to page five of attachment eight to the item filed
as docket number 42.
D. Motions for Preliminary Injunctive Relief
In addition to the requirements set forth in Federal Rule of Civil Procedure 65,
motions for a temporary restraining order or preliminary injunction shall also
address:
1. When the alleged irreparable harm will occur.
2. Whether discovery will be required, with a brief explanation of the
discovery sought.
3. Whether counsel seeks an evidentiary or argument hearing.
4. A proposed timeline for any discovery, hearings, and rulings.
E. Objections under Federal Rule of Civil Procedure 72(a)
Objections to a Magistrate Judge's non-dispositive pretrial ruling under Federal
Rule of Civil Procedure 72(a) should follow the briefing schedule in Local Rule
7-1(c)(3).
F. Oral Argument
Oral argument on civil motions will be granted only in exceptional cases.
G. Pending Ripe Motions
If a motion for summary judgment has been fully briefed for 180 days or any
other motion has been fully briefed for 90 days—or in exceptional
circumstances—counsel may file a status update explaining the effect of the
pending motion on the parties and case progress. Counsel may not ask off the
record about when the Court may rule on a substantive motion.
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III. TRIAL
A. Trial Dates in Civil Cases
Ordinarily, the Court will not automatically set a trial date in civil cases until
after the dispositive motion deadline has passed and rulings on any dispositive
motions. If counsel believes that a trial date should be set at an earlier point,
they may file a motion to set a trial date.
A motion to set a trial date must include:
1. Whether the trial is by jury,
2. The number of days anticipated for trial,
3. Proposed trial dates, and
4. The position of opposing counsel.
If the dispositive motion deadline has not passed, proposed trial dates should
be at least 180 days after the deadline to provide time for any motion to be
resolved.
B. The Final Pretrial Conference
1. Counsel shall meet and confer before the final pretrial conference to
attempt to agree on items in the final pretrial order and below.
2. Counsel must be prepared to address any pending motions, objections,
and issues related to voir dire and jury instructions at the final pretrial
conference.
3. About four weeks before the final pretrial conference, the Court will issue
an order setting deadlines for certain filings. Those deadlines are
intended to be consistent with CMP deadlines, but if they differ, the order
controls.
4. The parties are expected to work together to prepare the filings required
by the final pretrial order.
5. Motions in limine should be filed as one document numerically listing
each issue to be addressed. The opposing party must respond to each
issue with either "no objection," or "objection" with supporting argument.
6. The agenda for the final pretrial conference typically includes the
following items:
a. Discuss voir dire process, length of opening statements, and length
of closing arguments.
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b. Review witness lists to determine who will testify and the subjects
of their testimony.
c. Discuss stipulations.
d. Review exhibit lists and discuss admissibility and objections.
Bring copies of proposed exhibits to the conference.
e. Discuss testimony that will be offered through a deposition.
f. Discuss motions in limine and objections.
g. Discuss preliminary instructions and objections.
h. Discuss status of final jury instructions, objections, and verdict
forms.
i. In criminal cases, potential forfeiture.
j. In civil cases, discuss status of possible settlement.
C. The Venire and Voir Dire
1. Copies of questionnaires which the venire has completed will be available
to counsel at noon on the business day before the trial starts. The
questionnaires must be returned to the Courtroom Deputy as soon as
the jury has been chosen.
2. A seating chart will be available on the morning of trial.
3. Jurors are assigned numbers and must always be referred to by Juror
Number rather than name.
4. The Court will question the entire panel. The Court's proposed questions
will be provided to counsel before the final pretrial conference. The Court
will ask follow-up questions as appropriate and may allow counsel to ask
follow-up questions to individual responses.
5. In civil cases, each side will generally have three peremptory challenges
for the entire venire. After all challenges, the appropriate number of
jurors will be chosen in order of lowest draw numbers.
6. In civil cases, the Court ordinarily seats eight jurors with all jurors to
deliberate, and no alternate jurors.
7. In criminal cases, ordinarily, the government will have six peremptory
challenges, and the defense will have ten peremptory challenges, plus
any additional challenges for alternate jurors. Fed. R. Crim. P. 24.
D. Opening Statements and Closing Argument
1. Counsel should remain near the lectern during opening statement and
closing argument.
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2. The amount of time for opening statements will ordinarily be set at the
final pretrial conference, and the amount for closing arguments will be
set at trial.
3. When opposing counsel is speaking, never divert the attention of the
Court or the jury. Instruct clients and witnesses to do the same.
4. During opening statements, do not use an exhibit without the Court's
approval unless admissibility is stipulated.
5. Confine opening statements to what you expect the evidence to show. It
is not proper to use the opening statement to argue the case, to instruct
as to the law, or to express counsel's personal opinion.
6. If Plaintiff is going to suggest a damages number to the jury in closing
argument, it must be stated in the opening segment of the argument so
that Defendant can respond.
7. Closing arguments must be based on the evidence and reasonable
inferences from the evidence. Do not attack opposing counsel, offer
personal beliefs or opinions, or make arguments likely to inflame passion
or prejudice. Know what's proper in closing argument and what's not.
See United States v. Klebig, 600 F.3d 700, 718–19 (7th Cir. 2009).
E. Examination of Witnesses
1. Witnesses are to be asked questions, not argued with or given editorial
commentary about their answers.
2. Do not display an exhibit to the jury until it has been admitted into
evidence.
3. Counsel shall examine witnesses from the lectern.
4. Have all witnesses spell their names on the record.
F. Objections to Questions
1. Stand when making objections.
2. When making an objection, state only that you are objecting and specify
the ground or grounds for that objection.
3. Objections must be brief and shall not recapitulate testimony or attempt
to guide the witness.
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4. The Court will ordinarily ask for a brief response from opposing counsel.
Counsel shall not argue further without permission.
5. Only the attorney who handles the direct examination of a witness may
raise objections when other counsel is examining the witness. Only the
attorney who will cross-examine a witness may raise objections during
direct examination.
G. Difficult Issues—Advance Notice
If counsel anticipate that any question of law or evidence is not routine, will
provoke an extensive argument, or will require a proffer outside the jury's
presence, counsel should confer and attempt to resolve the matter. If
agreement is not possible, counsel should give advance notice to the Court to
allow for appropriate scheduling arrangements.
H. Stipulations
1. Stipulations concerning exhibit admissibility and authenticity, as well as
stipulations of fact, are expected.
2. The preferred exhibit stipulation for jury trials is that exhibits are
admissible and may be used at any place in the trial.
3. The preferred exhibit stipulation for bench trials is that exhibits are
admissible and may be used at any place in the trial. Only exhibits
mentioned during the trial will be considered as having been admitted
into evidence unless the parties specifically stipulate otherwise.
I. Use of Depositions
1. When referring a witness to her prior testimony, be clear whether you are
doing so to refresh recollection or to impeach.
2. When a deposition is read for impeachment, the relevant excerpts must
be identified orally for the record by line and page reference. Counsel
should ordinarily allow the witness to read the excerpts after the
identification has been made for the record. A deposition used for
impeachment need not be filed or marked as an exhibit.
3. Confer with opposing counsel to edit depositions to be used at trial,
including video depositions, and remove unnecessary material.
4. In bench trials, relevant deposition portions should be introduced as an
exhibit rather than read. In jury trials, reading portions of a deposition
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for reasons other than impeachment should be rare. The party seeking
to use the deposition shall place a person in the witness box and read
the selected questions, with the person in the box reading the answers of
the deposed witness to those questions. The portions of a deposition to
be read shall be marked on the transcript and it marked and offered as
an exhibit at trial. If objections were made at the deposition, counsel
should confer before the final pretrial conference and raise any disputed
issues at the final pretrial conference. The exhibit shall not be included
with the exhibits provided to the jury for deliberations.
5. If a video deposition is to be shown at trial, both the video and the
original transcript of the deposition (with the portions to be shown
marked) shall be marked and offered as exhibits but shall not be
included with the exhibits provided to the jury for its deliberations.
6. The parties should stipulate, if possible, that the reporter does not take
the reading of depositions.
7. Summaries of deposition transcripts are acceptable only by stipulation.
8. Medical experts who have been deposed and routinely examine and treat
patients in their practices will be presumed "unavailable" for in-court
testimony under Fed. R. Civ. P. 32(a)(4) so that their deposition
testimony may be offered into evidence at trial in that case by any party.
This presumption applies even if their deposition testimony is being
offered as firsthand observations rather than as expert opinion. This
presumption is to avoid inconvenience and delay to jurors, health care
providers, and patients caused by the scheduling of in-court testimony.
If a party objects to this presumption and the admissibility of deposition
testimony instead of in-court testimony, a written objection must be filed
at least 30 days before the trial date. A party opposing such an objection
can still attempt to demonstrate under Fed. R. Civ. P. 32 that the
deposition testimony ought to be admitted.
J. Exhibits
1. All exhibits should be identified by number only ("Exhibit 1" as opposed
to "Plaintiff's Exhibit 1" for example). Counsel shall confer and agree on
a numbering system from the beginning of discovery that avoids
confusion and duplication. The recommended numbering system marks
the first deposition exhibit No. 1 and so on up to No. 8, for example, for
the last one. The first exhibit in the second deposition should be marked
No. 9 and so on. Thus, for example, the employment contract would be
the same exhibit with the same number for all depositions. Then, the
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same exhibit numbers would be used for trial purposes. Numbers for
trial exhibits need not be consecutive.
2. Counsel should move for the admission of stipulated exhibits at the
beginning of trial. Other exhibits should be offered in evidence when
they become admissible, rather than at the end of a witness' testimony or
counsel's case.
3. Counsel shall prepare an electronic file containing PDF files of the
exhibits identified by exhibit number and provide that file to the Court by
one week before trial. Counsel shall also provide three binders with the
documentary exhibits to the Court at the final pretrial conference.
Oversized exhibits may be excluded.
4. Demonstrative exhibits should be shown to opposing counsel before trial.
The parties must object to a demonstrative exhibit at the first
opportunity. Only unopposed demonstrative exhibits may be shown to
the jury without leave of Court.
5. During trial, exhibits admitted into evidence are kept on the table in
front of the jury box or at the witness stand if exhibits are contained in a
notebook or notebooks. Each counsel is responsible for exhibits taken
from the table or the witness stand. Counsel must return all exhibits to
the table or witness stand at each recess or adjournment. Exhibits that
have been offered but not admitted are also part of the record of the case
and are kept by the Courtroom Deputy.
6. Each counsel shall keep a list of admitted exhibits. Counsel and the
Courtroom Deputy shall confer at the close of the evidence to ensure that
only admitted exhibits are sent to the jury. Counsel shall substitute
photographs for controlled substances, currency, firearms, and other
dangerous materials.
7. If an exhibit must be marked for identification in open Court, counsel
should state for the record what they are doing and briefly describe the
nature of the exhibit. Counsel should not expect the Court to provide
exhibit labels.
8. When counsel or witnesses refer to an exhibit, mention should also be
made of the exhibit number so that the record will be clear.
9. When maps, diagrams, pictures, or similar materials are used as
exhibits, and witnesses or counsel point out locations or features on
such documents, those locations should be appropriately marked on the
documents if they are not clear from the exhibits themselves.
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Unnecessary markings should be avoided. Counsel may use exhibits
with overlays or moveable parts. Markings on exhibits should be made
only after conferring with opposing counsel and receiving the Court's
permission. Counsel should describe the markings for the record.
10. When counsel expect to offer answers to interrogatories or requests for
admissions extracted from separate documents, prepare copies of the
individual materials so that the Court and jury do not wait for counsel
to locate the items. The copies should only be the particular
interrogatory or request to admit with the caption and signature page.
These materials should ordinarily be the subject of stipulations.
11. If a document is not in the exhibit binders but may be admitted into
evidence, have an appropriate number of copies on three-hole punched
paper so that if admitted, the exhibits may be distributed to the Court,
opposing counsel, and the Courtroom Deputy for inclusion in binders.
12. Each page of each exhibit should have an identifying number.
13. If deposition exhibits will be referred to at trial, either during
impeachment or from reading a transcript or showing a video, and their
numbering is not consistent with the numbering system used at trial,
the parties should create a stipulation containing a cross-reference to
trial exhibit numbers and any deposition exhibits.
14. If oversized exhibits are to be used, counsel must make arrangements
with the Courtroom Deputy at least two weeks before trial.
15. Be sure there is a proper line of sight for the jury, Court, witness, and
counsel when using easels, oversized exhibits, and models.
16. Demonstrative exhibits are not sent to the jury room for deliberations
unless the parties agree otherwise.
K. Jury Instructions and Verdict Forms
1. Proposed jury instructions and verdict forms must be filed and served.
2. Proposed instructions must cite their source and, if not a Seventh
Circuit pattern instruction, supporting authority.
3. The Court will hold an instructions conference during trial, generally
near the conclusion of the evidence and at a time that will not
inconvenience the jury. The Court will provide draft jury instructions
and verdict forms to counsel before the conference.
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4. Ordinarily, the Court will read most of the final jury instructions to the
jury before closing arguments.
L. Experts
After establishing qualifications, counsel shall request that the Court designate
the witness is an "expert." See United States v. Jett, 908 F.3d 252, 260 n.1,
266 (7th Cir. 2018).
M. Jurors
1. Do not exhibit familiarity with witnesses, jurors, or opposing counsel.
Jurors should not be addressed individually or by name.
2. No person in the courtroom should ever exhibit, by facial expression,
bodily movement, or other conduct, any opinion—e.g., surprise,
happiness, disbelief, or displeasure—about any testimony, argument, or
ruling. Counsel should admonish their clients and witnesses to avoid
such behavior. Visitors who cannot abide by this requirement will be
asked to leave the courtroom.
3. Jurors are permitted to take notes in notebooks, which will accompany
them during their deliberations.
N. Logistics and Housekeeping
1. Do not ask the Court Reporter to mark testimony. All requests for re-
reading of questions or answers should be addressed to the Court.
2. After trial has begun, documents should be filed electronically or given to
the Courtroom Deputy—not the Clerk's office—for filing.
3. On trial days, the jury will typically be brought in at 9:00 a.m. On the
first day of trial, counsel are expected to be in the courtroom by 8:15
a.m. The time will vary on subsequent days based on whether matters
must be addressed outside the jury's presence, but counsel should arrive
at least by 8:30 a.m. A typical trial day will include a midmorning break,
lunch around noon, and a midafternoon break with the jury leaving
around 5:00 p.m. Counsel should alert the Court whenever any witness
must be held over until the next day.
4. Promptness is expected from counsel and witnesses. Inform the
Courtroom Deputy of any anticipated scheduling problems.
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5. If a witness was on the stand at a recess or adjournment, that witness
should be on the stand ready to proceed when Court is resumed.
6. If a recess or adjournment follows the conclusion of a witness's
testimony, the next witness should be ready to take the stand when trial
resumes.
7. If a witness' testimony is expected to be brief, have the next witness
immediately available, ordinarily in the witness room.
8. Do not run out of witnesses.
9. The Court attempts to cooperate with the schedules of non-party
witnesses and will consider permitting them to testify out of sequence.
Discuss that possibility with opposing counsel and advise the Courtroom
Deputy, including whether there is an objection.
10. If both parties expect to call a witness, the Court will usually require all
questioning of the witness when called in the Plaintiff's case. If a party
believes non-leading questions should be asked of the witness, leave can
be requested under Federal Rule of Evidence 611.
O. Facilities
1. A TV and DVD player may be available if Counsel arranges with the
Courtroom Deputy before trial begins. Counsel should expect to bring
any other equipment, such as overhead projectors, screens, and other
easels that they expect to use.
2. If counsel wish to use one of the Video Evidence Presentation Systems
("VEPS") owned by the Southern District of Indiana, they must
coordinate with the Courtroom Deputy at least three weeks before trial.
If a VEPS is unavailable, counsel will need to provide any equipment.
3. Counsel should discuss with the Courtroom Deputy whether a witness
room will be available. If available, witnesses should generally be asked
to report to the witness room.
4. Chambers supplies, including the copier, are not available to counsel.
Counsel should not enter chambers or the jury room unless asked by
Court staff.
5. Cell phones must be on silent or vibrate-only in the courtroom. When
court is in session, cell phones may be used only to coordinate witnesses
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and other trial logistics by text message.
6. On trial days, the courtroom will be opened by 8:15 a.m., but can be
opened earlier if coordinated in advance with the Courtroom Deputy.
7. The courtroom may be locked during the noon recess, and Court staff
may not be present to allow access to any materials left in the courtroom.
8. The courtroom will be locked overnight and counsel will not have access.
9. Food and drinks are not allowed in the courtroom, except for water.
P. Transcripts
1. Daily transcripts of testimony must be arranged directly with the Court
Reporter at least two weeks before trial.
2. Transcripts of Court proceedings must be arranged with the Court
Reporter, preferably before the start of the proceeding.
3. Before trial, counsel shall provide the Court Reporter with a list of words,
terms, technical terminology, proper names, acronyms, and case
citations that would not be found in a typical spell check.
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APPENDIX A: FILING EXHIBITS AND PROPER CITATIONS
Step 1 – Filing Exhibits
• Motions and exhibits must be filed before supporting briefs so that
the brief's citations refer back to the motion's and exhibits' docket
numbers. Exhibits may be attached to the motion, as shown below,
or filed separately. If filed separately, the motion must be filed before
the exhibits.
• If filing an opening brief: First, electronically file the motion, attaching
any exhibits that will be cited in the supporting brief:
03/01/2021 38 MOTION for Summary Judgment, filed by Plaintiff
ROBERT SMITH. (Attachments: # 1 Exhibit 1 Johnson
Aff., # 2 Exhibit 2 Johnson Dep. Excerpts) (Jones,
John) (Entered: 03/01/2021)
• If filing a response, reply, or surreply with exhibits: First, file an
appendix or index of exhibits, attaching any exhibits that will be cited
in the supporting brief:
03/30/2021 42 Appendix of Exhibits in Support of RESPONSE in
Opposition re 38 MOTION for Summary Judgment, filed
by Defendant ABC, INC. (Attachments: # 1 Ex. A: Smith
Dep. Transcript, # 2 Ex. B: Smith Dep. Exhibits 1-5, # 3
Ex. C: Smith Employment Agreement, # 4 Ex. D:
Jackson Decl. with Exhibits 1–3 (Smith, Susan)
(Entered: 03/30/2021)
• When electronically filing exhibits, number the exhibits and add a
descriptive identifier. E.g., "Ex. 1 – Smith Dep." or "Ex. 3 – Smith
Employment Agreement" instead of just "Exhibit 1" or "Exhibit 3."
Example:
Attachment Description
1 Exhibit A: Smith
52 pages 4.1 mb
Dep. Transcript
2 Exhibit B: Smith
32 pages 3.8 mb
Dep. Exhibits 1-5
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3 Exhibit C: Smith
Employment 15 pages 1.3 mb
Agreement
4 Exhibit D:
Jackson Decl. 20 pages 1.7 mb
with Exhibits 1-3
• If a party relies on a deposition excerpt, the cited pages—and at least
the three pages immediately preceding and following—must be
included as an exhibit.
Step 2 – Citing Exhibits
• Briefs must cite the docket number, the attachment number (if any),
and the .pdf page number as it appears in the header at the top of the
previously filed exhibit. For example:
Mr. Smith signed an employment agreement with
ABC Corporation on May 1, 2012. [Dkt. 42-8 at 5.]
That citation would refer to page five of attachment eight to the item
filed as docket number 42.
• When citing deposition transcripts, cite the specific page and line
numbers of the deposition in addition to the docket number and page
number citation format set forth above. For example:
Case 1:19-1234-JPH-MJD Document 38-2 Filed 03/01/21 Page 3 of 24 Page ID #: 239
The proper cite is: Dkt. 38-2 at 3 (Johnson Dep. at 10:4-13).
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