Judge Kerstin Lemaire
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Communication
Phone
Chambers
Page & Word Limits4 rules
The joint statement may not exceed three pages and contain a certificate of good faith consultation. The summaries may not include exhibits.
- Page limit
- Up to 3 pages
Absent leave of Court for good cause shown, each party may file no more than five Motions in Limine.
Page limits should not be exceeded without leave of court. This will be strictly enforced.
Motions in limine are barred in bench trials absent leave, limited to five per party absent leave for good cause, and limited to four pages; responses are also limited to four pages, with no replies permitted.
- Motion in limine
- Up to 4 pages
Exception
More pages with leave of court
Court's wording
Motions in Limine shall not be filed in bench trials without leave of the Court. Absent leave of Court for good cause shown, each party may file no more than five Motions in Limine. Motions in Limine should address only extremely prejudicial matters, which could result in a mistrial. Motions in Limine should not be filed on routine evidentiary matters. Motions in Limine asking the Court to enforce a particular rule of evidence should not be filed. Motions in Limine are to be no more than four pages in length, and responses are no more than four pages in length. There are no replies.
Document Format Requirements5 rules
Final jury instructions must be fully written out in Word format; a list of RAJI numbers will not be accepted.
- File type
- Word
- Jury instructions
Court's wording
Proposed Verdict Forms and proposed Final Jury Instructions are due by noon on the first full day of trial. These can be amended as necessary as evidence is presented at trial. Again, the Final Jury Instructions must be fully written out in WORD format; a list of RAJI numbers will not be accepted.
Preliminary Jury Instructions must be explicitly spelled out, in WORD format, and submitted by 8:00 a.m. on the morning of the Trial Management Conference. The Court will not accept a list of RAJI numbers.
- File type
- Word
- Jury instructions
Before the pretrial management conference in a jury-eligible case, the listed trial materials should be emailed in Word format to the judicial assistant.
- File type
- Word
- Jury instructions
- Proposed voir dire
- Jury questionnaire
- Joint statement of the case
- Deposition designations
Court's wording
Before the pre-trial management conference in a jury-eligible case, all jury instructions, proposed voir dire, proposed jury questionnaire, joint statement of the case (to be read to the jury), and deposition designations should be emailed in Word to the Court's judicial assistant.
Typed documents must use at least 13-point type and double spacing; serif proportional fonts are preferred, while monospaced and sans serif fonts are discouraged.
- Font size
- 13 points
- Line spacing
- Double
Formatting
- •Font size must be at least 13 points
- •Proportionally spaced serif fonts are preferred
Court's wording
Every typed document must use at least a 13-point type size, and text must be double-spaced. The court prefers proportionally spaced serif fonts, such as Times New Roman, Bookman, Century, Garamond, or Book Antiqua. It discourages monospaced or sans serif fonts such as Arial, Helvetica, Courier, or Calibri.
Footnotes must be in at least a 13-point type size and must not appear in the space required for the bottom margin. Footnotes and endnotes will be included in the applicable limits.
- Font size
- 13 points
Document Filing Requirements4 rules
The joint statement may not exceed three pages and contain a certificate of good faith consultation. The summaries may not include exhibits.
No party should file supplemental briefing without leave of the Court.
Fully drafted proposed forms of order SHALL be submitted with all motions. Please do not argue with my staff over whether the rules require this. I require it.
If you file a motion and wish to have an oral argument, please note the request in the caption, or the Court will likely rule on the pleadings.
Filing & Service rules
Filing Timing and Cure Windows
Exhibits are due to the Clerk at least one week before trial unless permission is granted to submit them later.
Exhibits are due to the Clerk at least one week prior to the start of the trial unless permission has been given to bring them in later.
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections
Proposed verdict forms and final jury instructions are due by noon on the first full day of trial; final instructions must be fully written in Word format, though they may be amended as evidence is presented.
Proposed Verdict Forms and proposed Final Jury Instructions are due by noon on the first full day of trial. These can be amended as necessary as evidence is presented at trial. Again, the Final Jury Instructions must be fully written out in WORD format; a list of RAJI numbers will not be accepted.
Page 1 | Jury Selection
Preliminary jury instructions are due by 8:00 a.m. on the morning of the Trial Management Conference.
Preliminary Jury Instructions must be explicitly spelled out, in WORD format, and submitted by 8:00 a.m. on the morning of the Trial Management Conference. The Court will not accept a list of RAJI numbers.
Page 1 | Jury Selection
Proposed jury-questionnaire questions are due by 5:00 p.m. on the evening before the Trial Management Conference.
Proposed questions for the jury questionnaires are due at 5:00 p.m. the evening before the Trial Management Conference.
Page 1 | Jury Selection
Filing Bundling Requirements
No party should include more than one motion in a single filing or combine a response and a motion or a reply and a motion in one filing (with the exception of a true cross-motion for summary judgment). This applies to requests for attorneys' fees or sanctions. A separate petition/application/motion should make such requests.
No party should include more than one motion in a single filing or combine a response and a motion or a reply and a motion in one filing (with the exception of a true cross-motion for summary judgment). This applies to requests for attorneys' fees or sanctions. A separate petition/application/motion should make such requests.
Page 1 | Motion Practice
Pre-Motion Conference Requirements
For specified discovery, compel, or sanctions disputes, counsel must confer by phone or in person in good faith; if unresolved, the parties must file a joint dispute statement and provide it to the judicial assistant.
The Court's dispute resolution procedures outlined below shall apply to the following circumstances: (1) the parties have a discovery dispute that needs to be addressed; (2) one party seeks to compel another party to take some action; or (3) a party intends to seek sanctions against another party. Under any of these circumstances, counsel must personally speak to each other (by phone or in person) and make genuine good-faith attempts to resolve the dispute. If they cannot do so, the parties must file a "joint statement of discovery or disclosure dispute" and provide a copy to the division's judicial assistant.
Page 1 | Discovery or Disclosure Disputes and/or Sanctions
Motions in limine may not be filed in bench trials without leave of court.
Motions in Limine shall not be filed in bench trials without leave of the Court.
Page 1 | Motion Practice
Chambers Communication Rules
If you file a time-sensitive motion, please immediately email the division a copy and note the opposing party/counsel's position.
If you file a time-sensitive motion, please immediately email the division a copy and note the opposing party/counsel's position.
Page 1 | Motion Practice
The judicial assistant will contact the parties to schedule a telephonic conference after the dispute statement is reviewed.
The Court's Judicial Assistant will contact the parties to schedule a telephonic conference.
Page 1 | Discovery or Disclosure Disputes and/or Sanctions