Motion Calls/Courtesy Copies

As stated on the main page, unless ordered by the Court, Judge Valderrama does not hold 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. This conferral requirement also applies to pro se parties (that is, parties not represented by counsel), regardless of whether the pro se party is the movant or opposing party. 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.