Updated: June 2026
RENÉE MARIE BUMB
CHIEF UNITED STATES DISTRICT JUDGE
INDIVIDUAL RULES AND PROCEDURES
Chambers Courtroom Deputy
United States District Court Larry MacStravic
District of New Jersey (856) 757-5433
Mitchell H. Cohen Building & U.S. Courthouse
4th & Cooper Streets
Camden, New Jersey 08101
Tel: (856) 757-5020
Courtroom: 3D
Unless otherwise ordered, the following rules and procedures apply to all matters
before this Court:
I. Civil Motion Practice
A. Pre-Motion Conference
In an effort to resolve cases expeditiously, before filing a motion to dismiss,
motion for a more definite statement, motion to remand, motion for change of
venue, or motion for judgment on the pleadings, a party must submit a letter,
not to exceed three (3) single-spaced pages, requesting a pre-motion conference.
The letter must set forth the basis for the anticipated motion and include
citations to relevant authority. Within five (5) business days after receipt of this
letter, all adversaries must submit a written response, not to exceed three (3)
single-spaced pages. No party may submit a reply letter unless directed by the
Court. Affidavits and exhibits are not permitted unless directed by the Court. A
proffer by the attorney, however, of the contents of any such affidavit(s) and/or
exhibit(s) shall suffice.
The Court will attempt to resolve the dispute(s) at a pre-motion conference (in
person or via telephone/videoconference), to the extent possible. If the dispute
cannot be resolved at the pre-motion conference (or if the Court determines that
a conference would not be helpful), the moving party may proceed with filing
its motion. To be clear, this procedure does not preclude a party from filing any
of the above motions pursuant to Local Civil Rule 12.1. Rather, the Court hopes
to use this procedure to advance the case efficiently and minimize the costs of
litigation to the parties. In addition, compliance with this procedure shall not
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be deemed a waiver of any parties’ defenses as to lack of personal jurisdiction,
improper venue, insufficient process, or insufficient service of process.
A party’s submission of a pre-motion letter will toll that party’s time to file its
motion (or answer) through (i) the date of the pre-motion conference or (ii) the
Court’s decision not to conduct such a conference. If the Court determines that
a pre-motion conference would not be helpful and instructs a party to proceed
with filing its proposed motion without a conference, that party shall have an
additional five (5) business days to file its motion after its deadline pursuant to
Federal Rule of Civil Procedure 12(a), unless additional time is so stipulated or
the Court so orders.
This letter exchange does not apply in cases in which either side is pro se or in
bankruptcy or social security appeals.
B. Motion Days and Oral Argument
The only purpose of a motion’s return date or “motion day” is to determine the
briefing schedule for that motion. The Court generally will not hear oral
argument on the motion’s return date. Rather, if the Court decides to hear oral
argument on any issue, it will advise counsel of the argument date. See L. Civ.
R. 78.1(b) (“All motions and other applications will be decided on the papers
submitted unless: (1) a party requests oral argument and the request is granted
by the Judge; or (2) the Court, sua sponte, directs that oral argument be held.”).
C. Adjournments
All requests for adjournments or extensions of time, other than those pursuant
to Local Civil Rule 7.1(d)(5), must comport with Local Civil Rule 6.1 and
include: (1) the date or dates sought to be extended; (2) the number of previous
requests for extensions and the Court’s rulings; (3) the reason for the current
request; and (4) whether the adversary consents and, if not, the reasons given
by the adversary for refusing to consent. If consent is unreasonably withheld,
the Court may impose attorneys’ fees and costs. If the requested extension
affects any other scheduled dates/deadlines, the request must list the proposed
change for all such other dates/deadlines.
D. Exhibits
To the extent any party submits exhibits to support a motion, such exhibits shall
be clearly labeled, dated, tabbed, and indexed. The Court may strike a party’s
submission for failure to comply with this rule. See also infra Section II.D.
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E. Summary Judgment
1. Pre-Motion Conference
Before filing a motion for summary judgment, a party must first comply
with the same pre-motion conference procedure as outlined above. See
supra Section I.A. In general, the same rules apply. If the Court
determines that a pre-motion conference would not be helpful and
instructs a party to proceed with filing its proposed motion without a
conference, that party shall have an additional five (5) business days to
file its motion after its deadline pursuant to Federal Rule of Civil
Procedure 56(b), unless additional time is so stipulated or the Court so
orders.
2. Statements of Material Fact
Chief Judge Bumb requires strict compliance with Federal Rule of Civil
Procedure 56 and Local Civil Rule 56.1 in seeking or opposing summary
judgment. A motion for summary judgment must be accompanied by a
separately filed statement of material facts. Each fact must include a
citation to the record evidence with a pin cite that supports that fact. Facts
without citation to record evidence may be disregarded by the Court.
If a summary judgment motion is opposed, the opposing party shall set
forth, in a separately filed document, each paragraph of the moving
party’s statement of material facts. Directly below each paragraph, the
opposing party shall denote whether that fact is disputed or undisputed.
If the fact is disputed, the opposing party must include a citation to record
evidence with a pin cite that supports the dispute. Any explanation must
include a citation to record evidence with a pin cite. The opposing party
shall not include legal argument or extraneous detail outside the scope of
the moving party’s statement.
In addition to filing a responsive statement of material facts, the opposing
party may submit a separately filed supplemental statement of material
facts setting forth any relevant facts in support of its position, which the
moving party shall respond to in turn. The Court may ignore a
supplemental statement of material facts if it fails to include citation to
record evidence.
If a party fails to comply with these rules, the Court will likely strike that
party’s submission.
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3. Patent Cases
Chief Judge Bumb does not permit the filing of summary judgment
motions in ANDA patent cases. A party may, however, submit a letter
to the Court, not to exceed three (3) single-spaced pages, seeking a waiver
of this rule if the party believes that a summary judgment motion would
assist the Court in expeditiously resolving the case and would resolve
more than mere tangential issues. The letter must set forth the basis for
the proposed motion for summary judgment, with citations to relevant
authority, and the issue(s) expected to be resolved by the motion. Within
five (5) business days after receipt of this letter, all adversaries must
submit a written response, not to exceed three (3) single-spaced pages.
No party may submit a reply letter unless directed by the Court. This rule
is intended to be read in concert with Section I.E.1.
II. Submissions
A. Electronic Submissions (CM/ECF)
All parties, with the exception of pro se parties, shall file all documents, in both
civil and criminal matters, electronically via CM/ECF. All papers electronically
submitted shall, to the extent possible, be submitted in a text-searchable PDF
format.
B. Pro Se Filings
Parties appearing pro se must file all documents, applications, and motions
directly with the Clerk’s Office. Pro se parties are strongly encouraged to consent
to receive documents and notices electronically and may, with good cause, be
ordered to do so.
C. Proposed Orders
If any relief is being sought, a proposed order must accompany the party’s
submission.
D. Courtesy Copies and Exhibits
Unless otherwise directed by the Court, the parties shall provide one (1)
courtesy copy of their supporting briefs only; courtesy copies of all exhibits and
other supporting papers shall be filed electronically on CM/ECF only. Exhibits
shall be clearly labeled. Exhibits shall be separately filed as related attachments
to the document they support (i.e., a declaration/certification summarizing the
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exhibits). Exhibits shall not be compiled into a single PDF unless that PDF
properly hyperlinks and bookmarks the location of each exhibit within that
PDF. The Court will strike electronic submissions that fail to comply with this
rule.
III. Communications with Chambers
A. Telephone Calls
Please do not contact Chambers with legal or procedural questions that are
covered by these Rules, the Local Rules of this Court, or the Federal Rules of
Civil or Criminal Procedure.
B. Fax and E-Mail
Chambers does not accept fax or e-mail.
C. Letters
All communications with Chambers shall be by letter electronically filed via
CM/ECF. No hard copies or courtesy copies of letters shall be delivered to the
Court. Pro se parties are exempt from this requirement.
D. Docketing, Scheduling, or Calendar Matters
For docketing, scheduling, or calendar matters, please contact Courtroom
Deputy Larry MacStravic at (856) 757-5433 between 9:00 a.m. and 4:00 p.m.
IV. RICO Cases
In all matters in which the complaint contains a RICO claim, pursuant to 18 U.S.C.
§§ 1961–1968, the plaintiff(s) must file a RICO Case Statement within thirty (30) days
of filing the complaint, in accordance with Appendix O of the Local Rules &
Appendices found at: http://www.njd.uscourts.gov/LocalRules.html.
V. Class Action Cases
It is the Court’s practice to conduct a preliminary settlement approval hearing in
advance of the final settlement approval hearing required by Fed. R. Civ. P. 23(e). At
the preliminary approval hearing the parties shall be prepared to address, in a
reasonably comprehensive manner, all of the factors the Court will consider at the final
approval hearing, including but not limited to the factors enumerated in Fed. R. Civ.
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P. 23(e), Girsh v. Jepson, 521 F.2d 153, 157 (3d Cir. 1975), and In re Prudential Ins. Co.
Am. Sales Practice Litig. Agent Actions, 148 F.3d 283, 323 (3d Cir. 1998).
VI. Trials
A. Pre-Trial Briefs or Proposed Findings of Fact and Conclusions of Law,
and In Limine Motions
Once the Joint Final Pretrial Order has been filed, each party shall submit its
pre-trial brief or its proposed findings of fact and conclusions of law, and any in
limine motions, at least three (3) weeks before the start of trial. Any responsive
papers shall be submitted at least two (2) weeks before the start of trial.
Exceptions to this rule must be approved by the Court. Failure to adhere to this
rule may result in an adjournment of the trial with imposition of attorneys’ fees
and costs to the offending party(ies).
B. Jury Selection
1. Jury Questionnaire
Counsel for all parties must confer with each other prior to trial and
submit a joint jury questionnaire three (3) weeks before trial in hard copy
form, accompanied by a USB drive containing an electronic version of
the questionnaire, in Word format. Any additional or contested proposed
questions that could not be agreed upon by the parties should be
submitted by the propounding party to the Court at the same time.
Exceptions to this rule must be approved by the Court. Failure to adhere
to this rule may result in an adjournment of the trial with imposition of
attorneys’ fees and costs to the offending party(ies).
2. Juror Voir Dire
At the beginning of the trial, prospective jurors will complete the juror
questionnaire. Chief Judge Bumb conducts voir dire, and any follow-up
questions will be asked at sidebar.
3. Challenges for Cause and Peremptory Challenges
Challenges for cause and any Batson challenges will be heard at sidebar.
Peremptory challenges are exercised in writing with counsel marking
challenges on a sheet presented to them by the Courtroom Deputy.
Peremptory challenges are exercised in turn, with each side exercising
one round of challenge(s) at a time. In the event there are two passes in
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succession, the process ends. A pass is otherwise considered a forfeited
peremptory challenge. Chief Judge Bumb will announce any jurors that
are excused.
C. Jury Charges
Counsel for all parties must confer with each other prior to trial and submit joint
requests to charge three (3) weeks before trial in hard copy form, accompanied
by a USB drive containing an electronic version of the charges, in Word format.
Any additional or contested proposed charges that could not be agreed upon by
the parties should be submitted by the propounding party to the Court at the
same time.
Chief Judge Bumb does not charge the jury on substantive matters at the
beginning of trial or mid-trial but will generally charge the jury before counsel
make their closing arguments. She provides jurors with a written copy of the
jury charge. Counsel are to delineate in their submissions charges they wish to
be given before trial, including a joint preliminary statement of the case, and
charges they wish to be given at the close of trial. Counsel shall cite to the
applicable authority for each proposed charge. Exceptions to this rule must be
approved by the Court. Failure to adhere to this rule may result in an
adjournment of the trial with imposition of attorneys’ fees and costs to the
offending party(ies).
D. Verdict Sheet
Counsel for all parties must confer with each other prior to trial and submit a
joint verdict sheet three (3) weeks before trial in hard copy form, accompanied
by a USB drive containing an electronic version of the verdict sheet, in Word
format. If counsel cannot agree on a joint verdict sheet, counsel shall separately
submit proposed verdict sheets in the same manner. Exceptions to this rule must
be approved by the Court. Failure to adhere to this rule may result in an
adjournment of the trial with imposition of attorneys’ fees and costs to the
offending party(ies).
E. Trial Exhibits
Each party shall submit a list of pre-marked exhibits and a witness list, including
the name and address (city and state only) of each potential witness, one (1)
week prior to trial. All trial exhibits must be pre-marked in accordance with
each party’s exhibit list. The parties shall not send courtesy copies of trial
exhibits unless the Court requests them. Counsel shall retain custody of their
trial exhibits until closings. Chief Judge Bumb does not send weapons,
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narcotics, currency and the like into the jury room. If jurors wish to see such an
exhibit during deliberations, they are permitted to do so in the emptied
courtroom with only a United States Marshal or Courtroom Security Officer
present. The prosecuting attorney and/or investigating agency is generally
required to maintain custody of exhibits such as weapons, narcotics, or currency
during trial.
F. Deposition Designations
If a party anticipates introducing deposition testimony at trial, then such
deposition designations, and any evidentiary objections thereto, must be
submitted to the Court no later than two (2) weeks before trial. A party’s failure
to comply with this rule may result in the Court precluding a party from using
deposition testimony at trial. Thus, the Court strongly encourages the parties
to meet-and-confer on deposition designations and objections with sufficient
time to comply with this rule.
G. Juror Note Taking
Chief Judge Bumb allows juror note taking in most cases.
H. Juror Questioning
Chief Judge Bumb does not permit jurors to submit questions to the Court to be
posed to witnesses.
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