Judge Caroline Goldner Cinquanto
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- 2 copies • Before Trial
- In Advance of Court
Adjournments
- Deadlines must be strictly followed unless compelling reason exists.
- Telephone attendance not acceptable without prior approval; sanctions may apply for adjournments.
- Extension requests must be emailed in advance with detailed basis and party positions.
- +1 more
Request must include
Communication
Chambers
Phone
Chambers
Phone
Page & Word Limits5 rules
Case synopsis (max 5 pages, single spaced) due 2 weeks before conference.
- Case synopsis for attorneys
- Up to 5 pages
- Format
- Single-spaced
Court's wording
Counsel for all parties must submit the attached summary and their confidential case synopsis to Chambers_of_Magistrate_Judge_ Goldner_Cinquanto@paed.uscourts.gov on or before [two weeks before the conference]. The synopsis should be no more than five (5) pages in length, single spaced.
Attachments to synopsis limited to 30 pages with labeled dividers.
- Synopsis attachments
- Up to 30 pages
Court's wording
• The synopsis should attach key summary expert reports, policy language excerpts, photographs, sketches, diagrams, charts, etc. Only attach excerpts which are most relevant to the claims at issue. Relevant portions must be delineated. Attachments should be no more than thirty (30) pages and should be separated with labeled divider pages.
Motion briefs limited to 30 pages, reply briefs to 15 pages.
- Motion
- Up to 30 pages
- Reply brief
- Up to 15 pages
Exception
More pages with leave of court
Court's wording
Briefs accompanying motions and responses to motions are limited to thirty pages absent leave of Court. Any reply brief is limited to the issues raised in the response, may not raise theories or issues not discussed in the original motion, and shall not exceed fifteen pages absent leave of Court.
Memoranda limited to 30 pages (excluding TOC/appendices), double-spaced, 12-point font; TOC and TOA required for memos over 15 pages.
- Memorandum
- Up to 30 pages
- Format
- Double-spaced; 12-point
Excluded from page count
- •Table of contents
- •Appendices
Court's wording
Memoranda must not exceed 30 pages in length (excluding table of contents and appendices), must be double spaced, and must use 12-point font. Memoranda over 15 pages in length must include a table of contents and table of authorities.
The synopsis should attach key summary expert reports, policy language excerpts, photographs, sketches, diagrams, charts, etc. Only attach excerpts which are most relevant to the claims at issue. Relevant portions must be delineated. Attachments should be no more than thirty (30) pages and should be separated with labeled divider pages Judge Goldner Cinquanto may require hard copies of lengthy materials.
Document Format Requirements1 rule
Counsel are expected to confer about exhibits and provide Joint Exhibits (marked J-1, etc.) and additional exhibits (marked as P-1 or D-1, etc.).
- Joint exhibits
- Additional exhibits
Formatting
- •Joint Exhibits marked J-1, etc.
Document Filing Requirements49 rules
Joint voir dire questions document with three sections must be filed.
Court's wording
Whether proceeding by Joint Pretrial Stipulation or complying with Local Rule 16.1, the parties jointly must: 1. File one document titled “Proposed Joint Voir Dire Questions” containing three sections: (1) agreed voir dire questions; (2) additional questions proposed by Plaintiff(s); and (3) additional questions proposed by Defendant(s).
Joint jury verdict form document with agreed and alternative forms must be filed.
Court's wording
3. File one document titled “Proposed Joint Jury Verdict Form,” containing: (1) an agreed verdict form; and, if necessary, (2) any alternative verdict form Plaintiff(s) propose; and (3) any alternative verdict form Defendant(s) propose.
Joint jury instructions document with three sections must be filed, citing authority for each instruction.
Court's wording
2. File one document titled “Proposed Joint Jury Instructions,” containing three sections: (1) agreed jury instructions; (2) additional instructions proposed by Plaintiff(s); and (3) additional questions proposed by Defendant(s). Third Circuit standard instructions should be used, if available. Parties must cite the underlying authority for each instruction they propose, even if using the Third Circuit model.
Three pretrial documents must be filed on ECF simultaneously and submitted to chambers in Word format.
Court's wording
The three jointly filed documents must be filed on ECF at the same time as Pretrial Memoranda [or Pretrial Stipulation]. At the time of filing the parties must submit to chambers an electronic version of the three documents, in Word format.
• Plaintiff(s) must make a precise and specific written settlement demand, inclusive of all attorney’s fees, costs, and damages, on or before [three weeks before the conference].
- Document
- Settlement demand
Must include
- •Costs
- •Damages
- •Attorney fees
• Defendant(s) must make a precise and specific written settlement offer on or before [two weeks before the conference].
- Document
- Settlement offer
Must include
- •Precise and specific written settlement offer
Parties must email Word versions of proposed jury instructions and verdict form to chambers.
Court's wording
In addition to filing the proposed jury instructions and verdict form on the Court’s docket, the parties must e-mail Word versions of the documents to Chambers_of_Magistrate_Judge_Goldner_Cinquanto@paed.uscourts.gov.
Joint Pretrial Stipulation must include 8 specific elements
- Document
- Joint pretrial stipulation
Must include
- •Exhibit list
- •Relief sought
- •Claims defenses
- •Other disclosures
- •Trial time estimate
- •Summary of applicable law
Court's wording
The Joint Pretrial Stipulation shall be signed by trial counsel for each party and shall set forth: (1) a realistic, good faith estimate of the total time for trial; (2) the parties’ agreed-upon facts and their disputed facts; (3) their respective claims and defenses; (4) the relief sought; (5) a list of lay and expert witnesses that identifies the subject(s) of their expected testimony and any expected objections to admissibility; (6) a list of exhibits to be used or introduced into evidence and any objections to their authenticity; (7) a summary of applicable law, including, in diversity cases, the basis for choosing the applicable law; and (8) any other disclosures required under Federal Rule of Civil Procedure 26(a)(3).
Findings of fact and conclusions of law due 14 days before trial with 2 exhibit copies
- Document
- Pretrial stipulation
Must include
- •Findings of fact
- •Conclusions of law
- •Citations to relevant authority
Court's wording
findings of fact and conclusions of law, with citations to relevant authority, on or before [fourteen days prior to date certain]. Counsel shall also provide binders containing two copies of their exhibits, marked for trial.8 All objections to the authenticity of exhibits are waived unless noted in the Pretrial Stipulation.
Joint appendix required for summary judgment motions, consecutively numbered, with TOC, filed by movant when motion is docketed.
Court's wording
Joint Appendix: A party who plans to file a motion for summary judgment must meet and confer with all other parties and develop a single, joint appendix of all exhibits that may be referenced in their respective memoranda. All pages of the joint appendix must be consecutively numbered with an appendix page number. Page references in the memoranda must be to the appendix page number, not internal document page numbers. The joint appendix must include a table of contents. The joint appendix must be filed by the movant no later than the date the initial motion for summary judgment is docketed.
Local Rule 26.1(f) requires certification that parties are unable to resolve discovery dispute after reasonable effort.
Court's wording
Rule 26.1(f) of the Eastern District of Pennsylvania Local Rules of Civil Procedure also requires discovery motions to include "a certification of counsel that the parties, after reasonable effort, are unable to resolve the dispute."
Insurer representatives with settlement authority must attend if insurer approval is required.
Court's wording
If a party requires approval by an insurer to settle, a representative of the insurer with full and complete settlement authority consistent with the most recent demand must be present in addition to the relevant party principal.
Exhibits must be provided in two tabbed loose leaf books (judge and law clerk copies).
Court's wording
Exhibits are to be provided to the Court in the form of two jointly prepared loose leaf exhibit books—one for the judge and one for her law clerk—each book containing tabbed Joint Exhibits, Plaintiffs Exhibits, and Defendant’s Exhibits.
Settlement conference requires principals with full settlement authority to be present for entire duration.
Court's wording
Judge Goldner Cinquanto requires a principal for each party with an interest in the case who has full and complete settlement authority (i.e., authority consistent with the most recent demand) to be present (either on the Zoom, or in person, as applicable) for the entire duration of the conference.
Judge Goldner Cinquanto expects counsel to: Organize and bring critical evidence (policy language, photographs, sketches, diagrams, charts, etc.) to the conference. Judge Goldner Cinquanto may want to see them.
- Document
- Settlement conference
Include
- •Critical evidence
Memoranda over 15 pages in length must include a table of contents and table of authorities.
- Document
- Memorandum
Must include
- •Table of contents
- •Table of authorities
Discovery dispute request must describe prior efforts, summarize matters in dispute, and attach relevant information.
Court's wording
The request shall: (1) describe the parties’ prior efforts to resolve their dispute in detail; (2) summarize the matters in dispute; and (3) attach any information relevant to Judge Goldner Cinquanto’s consideration of the dispute.
Counsel for all parties must submit a confidential settlement summary and case synopsis via email (to Chambers_of_Magistrate_Judge_Goldner_Cinquanto@paed.uscourts.gov) two weeks before the conference. The case synopsis should be no more than five-pages in length.
Defendant(s) must make an updated, precise, and specific written settlement offer at least two weeks before the conference.
Every assertion of fact in a memorandum must be supported by a citation to the record where that fact may be found. Both legal citations and citations to the record must include pinpoint cites.
Rule 37 requires certification of good faith conferment before filing discovery motions.
Court's wording
Federal Rule of Civil Procedure 37 requires parties who file discovery motions to certify "that the movant has in good faith conferred or attempted to confer with the person or party failing to make disclosure or discovery in an effort to obtain it without court action."
Principal with full settlement authority must attend entire settlement conference.
Court's wording
Judge Goldner Cinquanto requires a principal for each party with an interest in the case who has full and complete settlement authority (i.e., authority consistent with the most recent demand) to be present (either on the Zoom, or in person, as applicable) for the entire duration of the conference. If a party requires approval by an insurer to settle, a representative of the insurer with full and complete settlement authority consistent with the most recent demand must be present in addition to the relevant party principal.
AI disclosure and certification required for all filings, including identifying AI tool, portions generated, and verifying citations.
- Document
- Any filing
Must include
- •AI disclosure
Court's wording
Any attorney for a party or any pro se party who uses generative artificial intelligence ("A.I.") to prepare any complaint, answer, motion, brief, or other paper filed with the Court in a matter assigned to Judge Goldner Cinquanto shall: (1) disclose that generative artificial intelligence was used to prepare the filing; (2) identify precisely what portion or portions of the filing was generated by A.I.; (3) identify the A.I. tool that was used; and (4) certify that each and every citation to the law or the record in the filing was verified as accurate in accordance with the obligations set forth in Rule 11 of the Federal Rules of Civil Procedure.
Counsel must be prepared to attend entire settlement conference day with clients.
Court's wording
Judge Goldner Cinquanto expects counsel to: Be prepared to be present for the entire day (with their client(s)) for as long as needed to make substantial progress towards a mutually agreeable resolution.
Plaintiff(s) must make an updated, precise, and specific written settlement demand, inclusive of all attorney’s fees, costs, and damages, at least three weeks before a scheduled settlement conference.
- Document
- Settlement demand
Must include
- •Costs
- •Damages
- •Attorney fees
Rule 26(f) report must be emailed to chambers at least 5 days before scheduling conference if not already on docket.
- Document
- Scheduling conference
Must include
- •Rule 26(f) report
Court's wording
If a Rule 26(f) report is not already on the docket when a case is assigned to Judge Goldner Cinquanto, the parties shall submit a copy of their Rule 26(f) report via email (to Chambers_of_Magistrate_Judge_Goldner_Cinquanto@paed.uscourts.gov) at least five days before the scheduled conference.
Any requests shall state whether it is made with the other party’s consent. Responses to all motions are due within the period prescribed by Local Rule 7.1(c).
Any objections to anticipated testimony or exhibits shall describe with particularity the ground and the authority for the objection.
All objections to the authenticity of exhibits are waived unless noted in the Pretrial Stipulation.
[Counsel shall comply with the format prescribed in my Practices and Procedures].
Any objections to exhibits shall describe with particularity the ground and the authority for the objection.
Must include
- •Objections to exhibits
Video equipment requests must be made at least two weeks before trial via email.
Court's wording
Parties who intend to use video equipment to present the testimony of a witness should either supply that equipment or request, at least two weeks before trial, that the Court reserve equipment for them by email to Chambers_of_Magistrate_Judge_Goldner_Cinquanto@paed.uscourts.gov.
Failure to comply with this policy may result in consequences such as referral to the appropriate state bar, monetary sanctions, or any other sanction the Court deems appropriate.
Any objections to anticipated testimony shall describe with particularity the ground and the authority for the objection.
Must include
- •Objections to testimony
The synopsis should attach key summary expert reports, policy language excerpts, photographs, sketches, diagrams, charts, etc., to the conference memos. Judge Goldner Cinquanto will review them. Please attach only those excerpts which are most relevant to the claims at issue. Relevant portions must be delineated. Attachments should be no more than 30 pages and should be separated with labeled divider pages.
Joint pretrial stipulation is preferred over Local Rule 16.1 for pretrial procedure.
Court's wording
The parties should ordinarily expect to file a joint pretrial stipulation, in the form attached, in lieu of complying with Eastern District of Pennsylvania Local Rule 16.1, which otherwise governs pretrial procedure.
The Joint Pretrial Stipulation should also alert the Court of any unusual legal issues which would serve as the basis for a motion for a judgment as a matter of law under Federal Rule of Civil Procedure 50 or any other dispositive motions with citations to relevant legal authority.
- Document
- Joint pretrial stipulation
Should include
- •Unusual legal issues
- •Citations to relevant authority
of Civil Procedure for this District and this Court’s Policies and Procedures. Both are available through the website for the Eastern District of Pennsylvania (https://www.paed.uscourts.gov/).
Judge Goldner Cinquanto may require parties to provide hard copies of lengthy materials.
Supplemental joint appendix must include original appendix, add materials at end, continue page numbering, and update TOC.
Court's wording
If unusual circumstances make it necessary for a party to supplement the joint appendix, the party must move for permission to file a supplemental joint appendix. The supplemental joint appendix must contain the original appendix, add the supplemental materials at the end, continue the appendix page numbering, and provide an updated table of contents.
Judge Goldner Cinquanto expects counsel to: Be prepared to discuss factual and legal points of agreement and disagreement.
Motion practice governed by EDPA Local Rule 7.1 with exceptions noted in this document and other applicable rules.
Court's wording
Motion practice is governed by Eastern District of Pennsylvania Local Rule of Civil Procedure 7.1 except as described elsewhere in these Practices and Procedures, the Local Rules and applicable Standing Orders, or, as relevant, the Supplemental Rules for Social Security Actions under 42 U.S.C. § 405(g), or the Rules Governing Section 2254 Cases in the United States District Courts.
Judge Goldner Cinquanto expects counsel to: Be flexible. Avoid bottom lines or top numbers.
Judge Goldner Cinquanto expects counsel to: Be prepared to discuss the weaknesses, as well as the strengths, of their case.
Judge Goldner Cinquanto expects counsel to: Manage their own expectations.
Judge Goldner Cinquanto expects counsel to: Be patient. Settlement is a process. It takes time.
Judge Goldner Cinquanto expects counsel to: Be prepared to discuss any impediments to settlement, whether legal, financial, or emotional.
Filing & Service rules
Courtesy Copy Requirements
Two exhibit copies required in binders for trial
Counsel shall also provide binders containing two copies of their exhibits, marked for trial.
Page 21 | Pretrial Stipulation Requirements
All relevant documents must be delivered to Chambers in advance of court.
Judge Goldner Cinquanto requires that all relevant documents be delivered to Chambers in advance of court. Counsel may contact Deputy Jeffrey Lucini at (267.299.7750) if there are any questions regarding the matters before the Court.
Sealing & Redaction Procedures
Motions to seal must clearly explain why secrecy outweighs public access and identify specific injuries from disclosure.
Any motion for leave to file under seal, including any motion for a proposed confidentiality/protective order that would permit a party to file any material under seal, must articulate, clearly and specifically, why the moving party’s “interest in secrecy” outweighs the “presumptive right of public access.” Avandia, 924 F.3d at 672. The motion— and the proposed order attached to the motion—must identify “clearly defined and serious injur[ies]” the movant will suffer if the materials are not kept under seal. Id. Judge Goldner Cinquanto will not grant a motion for leave to file under seal that fails to identify the movant’s interests in nondisclosure with specificity.
Page 7 | F. Documents Filed Under Seal
Even when Judge Goldner Cinquanto grants a motion for leave to file under seal, she will generally still expect the parties to file redacted versions of the sealed documents on the public docket unless the redactions would be so extensive as to render the document unreadable. Proposed orders attached to motions for leave to file under seal must include language requiring the parties to file redacted versions of the sealed documents to the public docket. If a movant omits this language from its proposed order, the movant must explain in its motion why redaction would render the documents unreadable.
Even when Judge Goldner Cinquanto grants a motion for leave to file under seal, she will generally still expect the parties to file redacted versions of the sealed documents on the public docket unless the redactions would be so extensive as to render the document unreadable. Proposed orders attached to motions for leave to file under seal must include language requiring the parties to file redacted versions of the sealed documents to the public docket. If a movant omits this language from its proposed order, the movant must explain in its motion why redaction would render the documents unreadable.
Page 7 | F. Documents Filed Under Seal
Except in emergency situations, documents should not be filed under seal without first obtaining leave of court.
Except in emergency situations, documents should not be filed under seal without first obtaining leave of court.
Page 7 | F. Documents Filed Under Seal
All motions for leave to file documents under seal should be filed on the public docket. If a motion contains or refers to information that the movant seeks to file under seal, the movant may redact the relevant information in the copy of the motion filed on the docket. When a movant files a motion with redacted information, the movant must provide the Court and all parties with unredacted copies of all documents that the party proposes to file under seal.
All motions for leave to file documents under seal should be filed on the public docket. If a motion contains or refers to information that the movant seeks to file under seal, the movant may redact the relevant information in the copy of the motion filed on the docket. When a movant files a motion with redacted information, the movant must provide the Court and all parties with unredacted copies of all documents that the party proposes to file under seal.
Page 8 | F. Documents Filed Under Seal
Parties should also otherwise conform to the Clerk's general procedures for filing documents under seal.
Parties should also otherwise conform to the Clerk's general procedures for filing documents under seal.
Page 8 | F. Documents Filed Under Seal
Adjournment & Extension Requirements
Extension requests must be emailed in advance with detailed basis and party positions.
shall request a new deadline or date in advance of the originally scheduled date via email (to Chambers_of_Magistrate_Judge_ Goldner_Cinquanto@paed.uscourts.gov). The request shall describe the basis for the request in detail, state whether all other parties agree or disagree with the request, and identify a suggested new deadline(s) or date(s).
Deadlines must be strictly followed unless compelling reason exists.
Parties are expected to adhere to all deadlines that the Court has implemented by scheduling order or that are otherwise established by rule or statute absent a compelling reason to justify a change.
Telephone attendance not acceptable without prior approval; sanctions may apply for adjournments.
Having a client with settlement authority available by telephone is not an acceptable alternative unless compelling circumstances exist and there is prior approval from Judge Goldner Cinquanto. If a conference must be adjourned or continued to allow a party to obtain additional authority up to the most recent demand, that party may incur sanctions, including, but not limited to, payment of the opposing party’s attorney’s fees resulting from a need to reconvene.
Adjournments for additional settlement authority may result in sanctions including opposing party's attorney fees.
If a conference must be adjourned or continued to allow a party to obtain additional authority up to the most recent demand, that party may incur sanctions, including, but not limited to, payment of the opposing party’s attorney’s fees resulting from a need to reconvene.
Chambers Communication Rules
Principal with full settlement authority required at final pretrial conference
A principal with full settlement authority shall be in attendance for each party.
Page 21 | Pretrial Stipulation Requirements
Final pretrial conference 7 days before trial with settlement authority required
A final pretrial conference will be held on [seven days before date certain] at __ a.m./p.m. in Courtroom 3D. Counsel shall confer in advance and shall be prepared to discuss all aspects of their Pretrial Stipulation, including any disputed issues. A principal with full settlement authority shall be in attendance for each party.
Page 21 | Pretrial Stipulation Requirements
Plaintiff’s counsel must promptly advise Court of any settlement
Plaintiff’s counsel shall promptly advise the Court of any settlement.
Page 22 | Settlement Notification
Judge will not intervene in discovery disputes without good faith telephone/video conference effort.
Judge Goldner Cinquanto will not entertain a request for judicial intervention if parties or their counsel have exchanged emails or other correspondence but have not made a good faith effort to speak to each other by telephone or video conference regarding a discovery dispute.
Email chambers to request telephone conference before filing discovery motion after good faith efforts.
If a party still requires Court intervention in a discovery dispute after making good faith efforts to communicate with an opposing party, the requesting party shall email Chambers_of_Magistrate_Judge_Goldner_Cinquanto@paed.uscourts.gov to request a telephone conference before filing any discovery motion on the docket.
Telephone participation by settlement authority clients is prohibited unless compelling circumstances with prior approval.
Having a client with settlement authority available by telephone is not an acceptable alternative unless compelling circumstances exist and there is prior approval from Judge Goldner Cinquanto (e.g., client is located in another state at the time of the conference).
Counsel must notify court one week before settlement conference if settlement is not possible.
If settlement is not a real possibility (e.g., if defendant will not make an offer or will offer only nuisance value), counsel shall notify the Court (jointly or individually) to request a brief video conference regarding their status on or before [one week before the conference].
Notify court by call/email at least 1 week before conference if settlement unlikely.
If settlement is not a real possibility (e.g., if the defendant will not make an offer or will offer only nuisance value), counsel shall notify the Court (jointly or individually) by a call or email to request a brief video conference regarding the lack of settlement possibility at least one week before the scheduled settlement conference.
Counsel should work together to narrow any areas of dispute before trial.
Counsel should work together to narrow any areas of dispute before trial.
Page 21 | Pretrial Stipulation Requirements
Correspondence permitted from counsel if copies sent to all other parties.
Judge Goldner Cinquanto permits correspondence from counsel on any matters, so long as all other counsel or unrepresented parties are sent copies of such correspondence.
Ex parte Zoom conferences available before settlement conference upon request.
If requested by counsel, with no opposition, Judge Goldner Cinquanto is available for ex parte Zoom conferences before the settlement conference. Please contact chambers to arrange a pre-conference video call.
Counsel may communicate with law clerks on procedural matters; pro se parties limited to mail/email.
Judge Goldner Cinquanto permits communications from counsel, both written and oral, with her law clerks on procedural matters only. Parties who are pro se (do not have counsel) may only communicate by mail or email to the chambers address above, unless otherwise directed.