Motion Practice
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Motion Calls/Courtesy Copies
Until further notice, due to the COVID-19 Emergency, Judge
Valderrama will not be holding motions calls. Parties are not to schedule
motion presentment hearings or deliver courtesy copies to the courthouse.
Conferral with Opposing Party
Before filing a motion, the movant’s counsel must ask opposing counsel whether there is an objection to the motion. The motion should clearly indicate whether it is opposed or unopposed. This requirement does not apply to: motions to withdraw as counsel, motions to dismiss, motions to remand, motions for summary judgment, and motions for leave to file a sur-response (where such request is based upon the argument that the opposing party raised new arguments in its reply).
Electronic Filing
The Court strongly recommends counsel to convert any
word-processed document (e.g., briefs and memoranda) into a PDF document by
printing or publishing it to PDF rather than manually scanning a paper copy
into PDF format. The former method of conversion generates searchable
optical character recognition (OCR) text; the latter does not. For other
filings (including exhibits in support of a motion or any Local Rule 56.1
Statement), the Court also strongly recommends counsel to run an OCR conversion
on it before uploading it onto CM/ECF. To do this in Adobe, go to Tools, Text
Recognition, In This File, and select All Pages. If you see the message,
“Acrobat could not perform recognition (OCR) on this page because this page
contains renderable text,” click “Ignore future errors in this document,” and
click OK.
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