HON. STACEY D. ADAMS, U.S.M.J.
Judicial Preferences
Adjournment Requests: Absent exigent circumstances, adjournment requests shall only be
considered if made at least three (3) business days before the scheduled court proceeding. The
party seeking an adjournment should attempt to gain the consent of all other parties before
submitting said request. The request should be made in writing via CM/ECF as a letter request.
The request must set forth: (a) the date of the court proceeding; (b) the length of adjournment
requested; (c) the basis for the adjournment request; (d) whether all parties consent to or oppose
the request; and (e) whether the adjournment request, if granted, would impact other scheduled
dates or deadlines.
Applications to amend or supplement pleadings: Motions to amend must comply with Local
Civil Rule 15.1 and shall be accompanied with a proposed amended pleading with red-lined edits
that clearly indicate the proposed changes. Counsel shall attempt to gain the consent of all other
parties before filing the application and indicate, in the application, whether consent was obtained.
If a party seeks to file a motion to amend after the deadline set by a Scheduling Order, that party
must show good cause why the amendment could not have been sought earlier pursuant to Federal
Rule of Civil Procedure 16.
Communications with the Court: Direct communication with law clerks is permitted as to
procedural matters only. All other communications shall be made via formal letter filed
electronically via CM/ECF, unless otherwise directed by the Court.
Confidentiality Orders: Any proposed Discovery Confidentiality Order agreed to by the parties
must strictly comply with Federal Rule of Civil Procedure 26(c) and Local Civil Rule 5.3. Unless
good cause is shown, the parties shall use the form included in Appendix S to the Local Civil
Rules. If the proposed order differs from Appendix S, the parties must submit (i) a clean version
of the proposed order that is ready for signature; and (ii) a red-lined version of the proposed order
that delineates how it differs from Appendix S.
Confidential Submissions: Settlement letters and any discovery dispute letters containing
information subject to a Discovery Confidentiality Order shall be submitted by email
to
[email protected].
Correspondence and written submissions not containing confidential information: Shall be
electronically filed via CM/ECF. Papers shall not be submitted by facsimile unless otherwise
directed.
Courtesy Copies: By request of the Court only.
Criminal Matters: The Court will not consider a request for bail or bail modification until after
defense counsel has consulted with the U.S. Attorney's Office and U.S. Pretrial Services has
assessed the proposed bail package.
Discovery Disputes and Applications. Discovery disputes and applications shall proceed in
accordance with Local Civil Rules 16.1 and 37.1. Should counsel fail in their good-faith efforts to
resolve the dispute by conferring pursuant to Local Civil Rule 37.1, the matter shall be brought to
the Court’s attention in the following manner:
(a) The party(ies) seeking relief shall file a letter with the Court, which shall be double-
spaced and not exceed five (5) pages in length. No exhibits shall be attached. The
letter is meant to summarize the issue for the Court for the purpose of having a
conference, and is not meant to be a substitute for a formal letter brief. The letter
shall set forth the efforts taken to resolve the dispute.
(b) The party(ies) opposing the relief sought shall file a response within five (5) days,
which shall be double-spaced and not exceed five (5) pages in length. No exhibits
shall be attached.
(c) Replies are not permitted without leave of Court.
After reviewing the letters, the Court will determine whether it will conduct a conference.
Formal discovery motions may be filed only upon leave of Court and only after the parties have
proceeded in accordance with Local Civil Rules 16.1 and 37.1 and complied with the procedures
set forth herein.
Motions to secure enforcement of a subpoena or to quash a subpoena involving third parties
must be made with notice to the relevant third party.
Extension of Time: Absent exigent circumstances, requests for extensions of time must be
submitted at least three (3) business days before the scheduled deadline, or the request will not be
considered. The request should be made in writing via CM/ECF as a letter request All requests
for an extension of time, other than automatic extensions pursuant to Local Rule 6.1(b) or
7.1(d)(5), must comport with Local Rule 6.1 and include (i) the date(s) sought to be extended; (ii)
the number of previous extensions; (iii) the reason for the current request; and (iv) whether the
adversary consents and, if not, the reason given by the adversary for refusing consent. If the
requested extension affects any other scheduled dates/deadlines, the request must list the proposed
change for all other dates/deadlines.
Final Pretrial Conferences: The Court conducts final pretrial conferences pursuant to Federal
Rule of Civil Procedure 16(e). The parties shall submit, by email to
[email protected]
and regular mail, one (1) copy of the joint proposed final pretrial order no later than fourteen (14)
days before the conference. Counsel shall utilize the Uniform Final Pretrial Order located on
the website for the U.S. District Court for the District of New Jersey. The Court expects counsel to
meet and confer regarding the final pretrial order in an effort to minimize disputes.
The Court expects to engage in meaningful settlement discussions at final pretrial conferences.
Therefore, trial counsel as well as persons with full settlement authority must attend the
conferences. The final pretrial conference will proceed even if there are dispositive motions
pending.
Format for CM/ECF Filings: Pleadings, motions, letters and proposed orders filed on CM/ECF
shall be filed in searchable PDF format. Supporting documents, such as exhibits, may be filed in
non-searchable format.
Motion Practice:
• No formal motions are permitted unless leave of court is first obtained, except for motions
under Federal Rule of Civil Procedure 12(b) or motions to remand that must be filed within
thirty days of removal pursuant to 28 U.S.C. § 1447(c). When seeking leave, the moving
party must first submit a letter, no longer than three pages, summarizing the party’s
argument and certifying what attempts have been made to meet and confer with the
adversary to resolve the dispute. Within one week of the moving party’s letter, the
opposing party must submit a letter, no longer than three pages, summarizing the party’s
argument in opposition.
• Full compliance with Local Civil Rules 7.1, 16.1 and 37.1 is expected.
• All motions must be accompanied by a proposed order in searchable PDF format, filed via
CM/ECF.
Motions to Seal: Motions to seal must comply with Local Civil Rule 5.3(c) and must include a
proposed order and proposed findings of fact and conclusions of law. In addition, the proposed
order must include reference to the docket entries the party seeks to seal. Counsel shall make every
effort to secure the consent of all parties regarding the request to seal and the movant shall certify
as to whether all parties consent in the application.
Oral Argument: The Court will schedule oral argument on an as needed basis. If oral argument
is requested, it shall be indicated in the notice of motion.
Pro hac vice: Requests for admission pro hac vice should be filed as motions and, provided the
defendant(s) have answered and/or defense counsel has entered a notice of appearance, should
indicate whether the other parties consent to the admission. There should also be one motion filed
for each individual applicant for admission pro hac vice. A motion seeking admissions of more
than one applicant will not be considered. Requests should also comply with Local Civil Rule
101.1(c) and enclose a proposed form of Order.
Proposed Orders: In addition to filing via CM/ECF, a copy of any proposed orders should be
submitted in Word format via email to
[email protected].
Settlement Conferences: Absent exigent circumstances, settlement conferences will be held in
person at the Courthouse and must be attended by lead trial counsel as well as all parties and
persons with settlement authority. Each party is required to submit, by email to
[email protected], a confidential settlement memorandum of no more than ten (10)
double spaced pages no later than five (5) business days before the conference. Voluminous
exhibits to settlement letters (exceeding 20 pages) will not be reviewed by the Court unless
submitted in hard copy that is received by Chambers no later than five business days in advance
of the settlement conference.
Telephone Conferences: Are permitted but must be initiated by letter informally outlining the
issues to be discussed.
