Judge Ranjan’s 1 Practices and Procedures (rev. 4/23/25)
These procedures are intended to supplement the local and federal rules of civil
and criminal procedure. They apply to all counsel and pro se parties.
I. General procedures
a. Telephone calls and e-mails to chambers. Counsel may
contact chambers for routine scheduling matters, and to raise any
discovery disputes. In any communications, court staff will not
provide any legal advice or discuss the merits of any cases.
Members of the public may also contact chambers to obtain
information regarding public access to any proceedings, such as
dial-in or videoconference information. All inquiries should be
directed to the Courtroom Deputy, Peter Kosloski, at
[email protected], or (412) 208-7495.
b. Decorum. Counsel shall not exhibit familiarity with witnesses,
jurors, opposing counsel, or the Court. During trial, counsel must
not block the jurors’ view of a witness and must not approach a
witness without permission. Counsel must stand when speaking
for the record and when addressing the Court, except for brief
objections during testimony, or when informally discussing the
case during status conferences.
c. Court reporter. In criminal cases, the Court will have a court
reporter present for all proceedings. In civil cases, the Court will
generally only have a court reporter present for oral arguments on
substantive motions, evidentiary hearings, the final pre-trial
conference, and all trial proceedings. If no court reporter is
present and counsel has an objection, or otherwise desires the
proceeding be on the record for any reason, counsel has the right
to and should request a court reporter to be present and then place
the objection or proceedings on the record.
d. Continuances. If a party seeks to continue a court proceeding, it
is helpful if counsel includes within the motion alternative
proposed dates/times near the original hearing date when all
1 Judge Ranjan pronounces his last name “Ron John.”
counsel are available. Motions to continue court proceedings will
be granted for good cause (such as an illness, medical procedure,
family emergency, pre-paid vacation, or previously scheduled court
proceeding).
II. Civil case procedures
a. Appearances. To ensure efficient communication of early
scheduling orders through ECF, all counsel must enter their
appearances as soon as practicable.
b. Initial case management conference. After all defense counsel
have entered appearances or all Defendants have answered the
complaint, the Court will schedule an initial case management
conference. Before that conference, the parties will be ordered to
confer and submit a Rule 26(f) report and ADR stipulation. Judge
Ranjan prefers to use a shortened form for the Rule 26(f) report,
which is linked on his webpage. In completing the ADR
stipulation, counsel must ensure that the time/date of the ADR
session is within 60 days of the initial case management
conference, the names/titles of the individuals who will attend are
listed, and any representative has full settlement authority. The
Court will strike ADR stipulations that do not comply with these
requirements. The initial case management conference will
typically occur in person, in the courtroom. If any lead counsel are
from out of town, they may file a motion to request that the
conference occur by telephone or videoconference. Counsel must be
prepared to engage in substantive discussion at the initial case
management conference.
c. Commencement of discovery. Counsel shall not propound
written discovery requests or otherwise commence any formal
discovery until after the initial case management conference and
after issuance of a case management order.
d. Rule 12 motions. In a civil case, if a defendant elects to file a
Rule 12 motion, defense counsel must meet and confer with
plaintiff’s counsel before filing to determine whether any
purported defects with the complaint can be cured. Any motion to
dismiss must come with a certificate stating that the defendant
has made good-faith efforts to confer with the plaintiff to
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determine whether the identified pleading deficiencies properly
may be cured by amendment. Rule 12 motions that do not contain
the required certification will be denied. This requirement applies
to all Rule 12 motions, including motions for judgment on the
pleadings under Rule 12(c).
e. Discovery length. The Court has no set period for the completion
of discovery, but the date that is proposed in the Rule 26(f) report
should be a realistic deadline based on the nature of the case—i.e.,
a deadline by which both parties can reasonably complete all
discovery without further extension. The reason for this is that the
Court does not like motions for extensions, and is unlikely to grant
such motions, even consent motions. In cases where the Court has
set a “presumptive trial date” at the onset, the parties’ proposed
discovery deadlines should account for that date.
f. Discovery disputes. For all discovery disputes, if the matter
cannot be resolved after the parties confer in good faith, the parties
shall contact chambers to raise the issue. At that time, the Court
will typically have counsel provide a brief e-mail summary of their
respective positions, and then the Court will provide guidance,
decide the dispute, or order briefing. No discovery-related motions
shall be filed until after the e-mail exchange. In the event
discovery motions are subsequently filed, counsel for each side
should, pursuant to Rule 37, provide support for their reasonable
expenses (including attorneys’ fees), as expenses will be awarded
to the prevailing party when permitted under Rule 37.
g. Routine motions. For routine motions (including motions for
leave to amend the pleadings, extensions of time, or continuances),
counsel for movant must confer with opposing counsel to obtain
consent, and state in the motion whether consent was obtained.
Briefs are not necessary.
h. Rule 56 motions. The Court will issue a briefing schedule for all
Rule 56 motions, and will typically not consider any motions filed
before the completion of discovery. For most motions, the Court
excuses the requirements under Local Rule 56, such as having the
parties forego the submission of separate concise statements and
responsive statements of material facts. For cross-motions for
summary judgment, the Court uses a briefing schedule like that
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used in cross-appeals under Federal Rule of Appellate Procedure
28.1. In complex cases, the Court will permit issue-specific briefs
on summary judgment.
i. Briefing schedule. Unless ordered otherwise, the principal brief
in support of a motion should be no more than 20 pages. The Court
will issue briefing schedules for all motions, which will provide the
due dates and page limits for any later briefs.
j. Briefing content. Counsel are free to structure their briefs in the
manner and style that they believe to be most persuasive. Counsel
are encouraged to review the “brief-writing preferences” document,
which is on the Court’s webpage.
k. Oral argument. The Court will entertain requests for oral
argument on any motion. The Court encourages parties to have
junior attorneys argue motions (or aspects of motions).
l. Injunctions. If a complaint seeks a TRO or preliminary
injunction, the Court will typically schedule a telephonic
conference as soon as possible. The plaintiff should make all
efforts to ensure that the defendant is served and has counsel, as
the Court will rarely grant ex parte motions.
m. Class and collective actions. For class and collective actions,
the Court expects the named plaintiffs to attend all court
conferences and hearings (either in person or remotely), and
settlement conferences and mediations. Any request for an
incentive award for a named plaintiff must demonstrate active
involvement of the named plaintiff in the litigation. For classwide
settlements, the parties should be prepared for a fulsome
presentation at the preliminary-approval stage, as the Court will
scrutinize the settlement closely at that stage and before notices
are sent. For individual, non-collective FLSA settlements, the
Court finds that court approval is not necessary; the parties may
simply file a stipulation of dismissal at the appropriate time.
n. Trial. The Court will issue a separate pre-trial order, which
outlines trial procedures. In certain cases (usually personal-
injury, UM/UIM, and non-complex employment and civil rights
cases), the Court will issue an order setting a “presumptive trial
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date,” with the trial to generally occur approximately 10-18
months from the date of the initial case management conference.
In those cases, the trial date will be finalized at the initial case
management conference, and all pre-trial deadlines will be set to
account for that date. Requests to continue the trial date will be
granted only in extraordinary circumstances.
III. Criminal case procedures
a. Initial case conference. The Court will conduct an initial case
conference about 40 days after arraignment, typically with only
counsel present (unless defense counsel requests the defendant’s
presence). After obtaining an extension from the magistrate judge
at arraignment, defense counsel should not file any motions to
extend the pre-trial motion deadline until after the initial
conference. At the conference, counsel should be prepared to
engage in a preliminary, substantive discussion of the case. For
example, in most circumstances, the government should anticipate
being asked to provide the Court with an overview of the evidence
against the defendant and to answer questions about the scope of
discovery.
b. Extensions to file pre-trial motions. The Court will grant
motions to extend the pre-trial motion deadline for good cause,
such as where a case is factually complex, involves multiple
defendants, or involves voluminous discovery. Otherwise, the
Court is not inclined to grant serial extensions, and will require
counsel to work expeditiously towards a plea or trial within the
time frame of the Speedy Trial Act.
c. Change-of-plea hearings. Counsel may call or e-mail chambers
when they are prepared to schedule a change-of-plea hearing. If
there is a plea agreement, the government must e-mail defense
counsel and the Court a copy of the agreement seven days in
advance of the hearing. At the same time, the government will be
ordered to e-mail defense counsel and the Court the summary of
the evidence it would present at trial so that defense counsel can
review it with the defendant before the hearing. While the parties
certainly are free to enter any plea agreements that are authorized
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by law, counsel should be aware that the Court does not prefer
Rule 11(c)(1)(C) plea agreements.
d. Sentencing. The Court follows the schedule for pre-sentencing
submissions and deadlines in the local rules.
e. Trial. The Court will issue a separate pre-trial order, which
outlines pre-trial procedures and deadlines.
Rev. 4/23/25
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