Judge Michael Herrod
Individual Rules, Standing Orders & Policies
Document Filing Requirements1 rule
If motions contain out of state cases, that party shall provide the Court with copies of those cases.
Filing & Service rules
Electronic Filing Rules
All pleadings must be filed electronically.
All pleadings must be e-filed.
Civil cases
Page 1 | Motion Practice
Filing Timing and Cure Windows
A written request for a court reporter must reach the Court at least three court days before the proceeding begins.
If a court reporter is required, the Court must receive a written request at least (3) court days before the commencement of the proceeding.
Civil cases
Page 1 | Trial Schedule
Counsel must present all exhibits and a list of exhibit descriptions to the Clerk at least ten judicial days before trial.
Counsel shall present all exhibits with a list of exhibit descriptions to the Clerk of the Court no less than ten (10) judicial days before trial.
Civil cases
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections
Counsel must present original depositions for filing when presenting the exhibits and exhibit list.
Counsel shall also present original depositions for filing at that time.
Civil cases
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections
The Joint Pretrial Statement is due five days before the Final Trial Management Conference.
In accordance with Rule 16(d), A.R.C.P., a Joint Pretrial Statement is due five (5) days before the Final Trial Management Conference.
Civil cases
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections
A written response to a motion in limine may be filed no later than 10 days after receiving the motion.
Written responses to a motion in limine may be filed no later than ten (10) days after receipt of such motion.
Civil cases
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections
Motions in limine are due at least 30 days before the Final Pre-Trial Management Conference and will not be heard until the pre-trial conference, especially if dispositive.
Motions in limine are due no less than thirty (30) days prior to the Final Pre-Trial Management Conference and will not be heard until the pre-trial conference, especially if the case is dispositive.
Civil cases
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections
Service and Proof of Service Rules
Documents and pleadings must be delivered to opposing counsel on the date they are filed with the Court.
All documents and pleadings shall be delivered to opposing counsel on the date they are filed with the Court.
Civil cases
Page 1 | Motion Practice
Sealing & Redaction Procedures
Sealed filings are discouraged and require a significant reason to shield records from public view.
Filings under seal are discouraged. There must be a significant reason to shield records from public view and to create administrative hardships for court access via such designation.
Civil cases
Page 1 | Discovery or Disclosure Disputes and/or Sanctions
Filing Bundling Requirements
The Court prefers single-subject motions over omnibus motions.
Motions should be single subject over omnibus.
Civil cases
Page 1 | Motion Practice
Pre-Motion Conference Requirements
Before seeking a motion to compel, parties must make every effort to confer in good faith, including speaking by telephone; correspondence alone is insufficient except in extraordinary circumstances.
However a motion to compel will not be honored, unless parties make every effort to speak with each other. Civil Rule 37(a)(2)(c) provides that an exchange of correspondence is not sufficient to satisfy the “personal consultation” requirement of the Rule, except in extraordinary circumstances. At a minimum, counsel must speak to each other by telephone to attempt to resolve the dispute in good faith before involving the Court.
Civil cases
Page 1 | Discovery or Disclosure Disputes and/or Sanctions
Replies on motions in limine are not permitted.
There are to be no replies.
Civil cases
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections
Chambers Communication Rules
Copy the judge’s division directly only for emergency measures.
My division should be copied directly only on emergency measures.
Civil cases
Page 1 | Motion Practice
The Court is open to resolving minor disputes raised during depositions by telephone.
In accordance with Rule 1, Ariz. R. Civ. P., this Court is open to resolving minor disputes, raised during deposition, over the phone.
Civil cases
Page 1 | Discovery or Disclosure Disputes and/or Sanctions