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All substantive written communications with Judge Daniel must be filed on the docket. Parties may contact Judge Daniel’s Courtroom Deputy, Vettina Franklin, to address administrative matters. The parties may not contact Mrs. Franklin concerning substantive matters. Mrs. Franklin prefers email to telephone. Any party attempting to contact Mrs. Franklin, whether by email or telephone, must either include all parties on the email or telephone call or obtain all parties’ prior consent to the communication. To avoid ex parte communications, Mrs. Franklin will not share information received from the parties with Judge Daniel.

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Judge Daniel typically does not require courtesy copies. When required, Judge Daniel will enter a minute order directing the parties to submit courtesy copies.

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Judge Daniel prefers that parties appear in person. However, any party may request to appear remotely. To do so, the party must contact the Courtroom Deputy, either by email or telephone, at least twenty-four hours prior to the scheduled appearance.

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Judge Daniel uses OSCAR to hire law clerks. Application materials submitted directly to chambers will be discarded.

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Judge Daniel typically hears motions Tuesdays, Wednesdays, and Thursdays at 9:30 a.m. Parties must notice motions for presentment. Absent exceptional circumstances, parties must file motions at least three business days before Judge Daniel hears the motion.

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Motions for summary judgment must comply with Fed. R. Civ. P. 56, Local Rule 56.1, and the following standing orders:

1. No party may file a motion for summary judgment prior to the close of fact discovery without prior leave of the Court.
2. No party may file more than one motion for summary judgment during the pendency of the case without prior leave of the Court.
3. Any memorandum of law in support of a motion for summary judgment shall not exceed thirty pages; responses shall not exceed thirty pages; replies shall not exceed fifteen pages.
4. Local Rule 56.1(d)-(f) sets forth requirements concerning statements of facts. Each numbered paragraph must assert one material fact. Each asserted fact must be supported by citation(s) to the specific evidentiary material that supports the material fact. The Court will strike any numbered paragraphs that disregard these requirements by, for example, asserting multiple material facts in a single numbered paragraph, failing to cite with specificity to evidence that supports the fact, or by including legal argument in the statement of facts. This list is not exhaustive.
5. Incorporation by reference is permitted; however, the pages incorporated count against the incorporating party’s page limit. For example, if Defendant A moves for summary judgment on Issue A and uses five pages to set forth its position on Issue A, Defendant B can incorporate Defendant A’s Issue A arguments by reference. In this example, Defendant B’s memorandum of law in support of a motion for summary judgment on any other issues Defendant B raises shall not exceed twenty-five pages, which together with the five pages incorporated on Issue A, totals thirty pages. The aim here is to prevent parties in a multiple-plaintiff or multiple-defendant case from skirting the thirty-page limit.

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