Judge John Milton Younge
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- Upon request
Deposition Transcript
Exhibits
- 1 copy • On Date Set at Final Pretrial Conference
- 2 copies
- At Trial
- On First Day of Trial or Jury Selection
- Three Weeks Prior to Trial or Trial Pool Ready Date
Adjournments
- A trial-continuance request must be filed as a motion stating its reasons at least 14 days before trial.
Communication
Chambers
Phone
Chambers
Page & Word Limits3 rules
Reply briefs and sur-reply briefs are each limited to ten pages.
- Reply
- Up to 10 pages
- sur-reply
- Up to 10 pages
Court's wording
Reply briefs and sur-reply briefs, addressing only issues raised in the brief in opposition and not repeating arguments in briefs that were previously filed by the movant, may be filed within seven days of service of the opponent’s brief in opposition/reply and shall be limited to ten pages.
After a response, also limited to ten pages, is filed, the Court will either: (1) issue a ruling; (2) hold a teleconference or hearing; (3) refer the dispute to a U.S. Magistrate Judge for a determination; or (4) order additional briefing.
- Page limit
- Up to 10 pages
However, if, after making a good faith effort, counsel are unable to resolve a disputed issue, counsel for the aggrieved party shall file with the Court a motion in conformity with Local Civil Rule 26.1(b), with a proposed order, and a brief not to exceed ten pages.
- Brief
- Up to 10 pages
Document Format Requirements11 rules
Exhibits shall be taped and submitted in binders for ease of use by the Court.
- Exhibits
Formatting
- •Exhibits shall be taped
The Court’s courtesy copy shall be clearly marked, tabbed, and bound in a 3-ring binder or other binding method that allows the exhibit book to open and lay flat on an even surface.
- Binding
- Tabbed three-ring binder
- Chambers copy
Formatting
- •Clearly mark the courtesy copy
- •Tab the courtesy copy
The above listed documents must be submitted in Microsoft Word format; .pdf format is not acceptable.
- File type
- Word
Documents must be submitted via e-mail to Chambers_Younge@paed.uscourts.gov in Microsoft Word format - .pdf format is not acceptable.
- File type
- Word
In addition to filing a guilty plea memorandum with the Clerk of Court – and unless the matter is sealed – counsel shall simultaneously send a digital copy of the same in Microsoft Word format directly to Judge Younge’s Deputy, Ms. Dedra Brannan. Counsel’s failure to strictly adhere to this protocol will likely result in sanctions.
Counsel must simultaneously send the Deputy a digital Microsoft Word copy of sentencing motions and memoranda, unless the matter is sealed; noncompliance will likely result in sanctions.
Court's wording
In addition to filing any such motions and/or sentencing memoranda with the Clerk of Court – and unless the matter is sealed – counsel shall simultaneously send a digital copy of same in Microsoft Word format directly to Judge Younge’s Deputy, Ms. Dedra Brannan. Counsel’s failure to strictly adhere to this protocol will likely result in sanctions.
The videotape must be edited prior to trial to eliminate pauses and speed-ups so there are no interruptions.
Exhibits shall be arranged and tabbed in a binder.
- Binding
- Tabbed binder
- Exhibits
If counsel modifies a model jury instruction, additions shall be underlined and deletions shall be placed in brackets.
Each proposed point for charge shall be numbered and on a separate sheet of paper, with citation to the applicable authority.
Counsel are encouraged to post searchable briefs to ECF and, when possible, use OCR for scanned briefs.
Court's wording
Counsel are encouraged to post searchable versions of their briefs to ECF. If counsel posts a scanned copy of a physical brief, that brief should, if possible, be save in a digital format using Optical Character Recognition software.
Document Filing Requirements54 rules
Pro hac vice applications must be submitted in writing on the Court’s website forms and include a signed affidavit or certification of good standing in another jurisdiction’s bar.
Court's wording
Judge Younge expects applications for pro hac vice admissions to be submitted in writing using the forms found on the Court’s website at www.paed.uscourts.gov. He requires the attorney seeking such admission to (1) submit the signed affidavit or certification stating that he or she is a member in good standing of the bar of another jurisdiction.
Judge Younge requires a proposed order to be filed along with every motion and response.
- Document
- Motion and response
Must include
- •Proposed order
As a reminder, all discovery motions must contain the certification required under Local Civil Rule 26.1(f).
All summary judgment motions and oppositions to such motions must contain a recitation of facts with complete and accurate citation to the record.
A summary judgment motion must include a separate, numbered Statement of Undisputed Material Facts limited to facts bearing on dispositive material issues.
- Document
- Summary judgment motion
Must include
- •Statement of facts
Court's wording
Any motion summary judgment shall include a separate Statement of Undisputed Material Facts which sets forth, in numbered paragraphs, the material facts that the moving party contends are undisputed and entitle the movant to judgment as a matter of law. Only those facts which bear on dispositive material issues shall be included in the Statement of Undisputed Material Facts.
To this end, Judge Younge requires the parties to file separate statements of material facts (i.e., not simply a factual narration section of a brief), as follows:
Confidentiality orders must contain the stated reservation-of-rights language or substantially similar language.
Court's wording
All such orders must contain the following language or language substantially similar: “The Court retains the right to allow disclosure of any subject covered by this stipulation or to modify this stipulation at any time in the interest of justice.”
Summary judgment statements of material facts must support each fact with specific record references and pinpoint citations; unsupported fact descriptions will not be considered.
Court's wording
5. The Court will not consider any description of a fact that is not supported by citation to the record. Statements of Material Facts in support of or in opposition to a motion for summary judgment must include specific and not general references to the parts of the record that support each of the statements, such as the title of or numbered reference to a document, the name of a deponent and the page(s) of the deponent’s deposition, or the identity of an affidavit or declaration and the specific paragraph relied upon. Pinpoint citations are required.
4. Without exception, all facts set forth shall be deemed admitted unless addressed by the opposing party as set forth herein
Summary judgment motion practice that fails to follow these procedures to the letter will be stricken.
Unless otherwise specified, Judge Younge requires the parties to submit the following by a date set by the Court, which is normally approximately three weeks prior to the trial date: 1. Jointly-proposed voir dire questions; 2. Jointly-proposed brief statement of the case;
Opposition papers to summary judgment must include a separate statement responding to the moving party’s numbered facts; respondents may also list additional disputed material facts in separate numbered paragraphs.
- Document
- Summary judgment opposition
Must include
- •Statement of facts
Court's wording
2. The papers opposing a motion for summary judgment shall include a separate Statement of Undisputed and/or Disputed Material Facts that responds to the numbered paragraphs set forth in the moving party’s Statement of Undisputed Material Facts, either admitting those facts are undisputed, or contending they are disputed and, as such, are genuine issues to be tried. The responding party may also set forth, in separate numbered paragraphs, any Additional Disputed Material Facts which the respondent contends preclude summary judgment.
3. Jointly-proposed jury instructions; 4. Jointly-proposed verdict sheet; 5. Motions in limine; and 6. Final pretrial memoranda pursuant to Local Civil Rule 16.1(c).
b. Each proposed point for charge shall be numbered and on a separate sheet of paper.
c. Where counsel cannot agree on a particular point for charge or interrogatory, the joint submissions shall provide the alternative version proposed by each party and the rationale for each.
If a party objects to a proposed point for charge or interrogatory in its entirety, the joint submission must note the objection and include that party’s rationale.
Court's wording
d. Where one party proposed a point for charge or interrogatory and the other party objects to the proposal in its entirety (i.e, wishes nothing be used, as opposed to an alternative version), the joint submission shall note such and include the objecting party’s rationale.
Judge Younge requires the submission of proposed findings of fact and conclusions of law in injunction cases, in accordance with Fed. R. Civ. P. 52(a).
Written ===== PAGE 16 ===== notification must set forth the page and line numbers of the challenged testimony and a clear statement for the basis of the objection.
In a non-jury trial, the parties shall file a stipulation of uncontested facts.
Each party shall submit proposed findings of fact and conclusions of law.
Judge Younge requires all counsel to be present unless the urgency of circumstances precludes notice to opposing counsel.
A continuance motion must include a proposed order with a detailed proposed ends-of-justice finding consistent with the Speedy Trial Act.
- Document
- Continuance motion
Must include
- •Proposed order
Court's wording
Any such motion must be accompanied by a proposed order consistent with the requirements of the Speedy Trial Act, 18 U.S.C. § 3161. The order shall include a proposed finding that explains in reasonable detail why the ends of justice served by granting the requested continuance outweigh the best interest of the public and the defendant in a speedy trial.
Any motion for a continuance of trial date must be accompanied by a speedy trial waiver. The speedy trial waiver form can be found as an attachment to the first trial listing.
The government must file a trial memorandum at least three weeks before trial or as provided by the scheduling order, and any defense response is due within seven days thereafter.
Court's wording
At least three weeks prior to the trial date and/or in accordance with the scheduling order entered by the Court, the government must file a trial memorandum setting forth the essential elements of the offenses, the facts which it intends to present, the identity of each witness it intends to call, a statement of the substance of each witness’s testimony and any legal issues. Any defense response to the government’s trial memorandum shall be filed within seven (7) days thereafter.
Judge Younge requires the government to submit a guilty plea memorandum and a copy of any plea agreement no later than ten (10) days prior to the guilty plea date.
A government motion to introduce Rule 404(b) evidence is due by the scheduling-order deadline or, absent one, at least six weeks before trial; it must explain the evidence and its proper purpose, include a proposed preceding jury instruction, and any defense response is due within five business days.
Court's wording
If the government expects to introduce Rule 404(b) evidence relating to other crimes, wrongs, or acts, it must file a motion on or before the deadline set by the Court in its scheduling order (or at least six (6) weeks before trial if the Court does not enter a scheduling order). The motion shall include a brief summary of the proposed evidence, identifying the purpose for which the evidence will be offered and explain how the evidence fits into a chain of logical inferences connecting it to a proper purpose, no link of which is an improper propensity inference. See United States v. Davis, 726 F.3d 434, 442 (3d Cir. 2013). The motion shall also include a proposed jury instruction to precede the introduction of such evidence. Any defense response is due within five (5) business days thereafter.
In addition, the plea agreement must inform the defendant and remind the Court, pursuant to Rule 11(c)(3)(B), that the defendant has no right to withdraw the plea if the Court does not follow the recommendation or request if the plea is entered under 11(c)(1)(B).
In no event shall counsel raise objections for the first time in a sentencing memorandum.
The plea agreement must disclose to the defendant and the Court whether the plea is under Rule 11(c)(1)(A), (B), or (C), and identify the applicable type of government obligation or sentencing recommendation.
Court's wording
The guilty plea agreement also must disclose to the defendant and the Court whether the plea is entered pursuant to Federal Rule of Criminal Procedure 11(c)(1)(A), (B) or (C), relating to the obligation of the government regarding other charges under subsection (A), a non-binding sentencing recommendation under subsection (B), or a binding sentencing recommendation under subsection (C).
To avoid delay in sentencing, all objections to the Presentence Investigation Report (PSR) must be sent to the probation officer in advance of sentencing.
The guilty plea agreement and memorandum must state whether the plea is a general plea of guilty, a conditional plea, or a plea of nolo contendere.
A guilty plea memorandum must state the offense elements and citations, statutory penalties, plea agreement terms, and factual basis for the plea.
Court's wording
A guilty plea ===== PAGE 20 ===== memorandum shall include the elements of each offense to which the defendant is pleading guilty and legal citations for such elements; the maximum (and mandatory minimum, if any) statutory penalties for each offense; the terms of any plea agreement; and the factual basis for the plea.
When restitution is at issue, the government’s sentencing memorandum must provide specified victim, loss, and supporting-document information, and itemize each defendant’s share of joint and several liability.
Court's wording
If a defendant is responsible for restitution, the government must submit sufficient information in its sentencing memorandum to enable the Court to determine entitlement, the name and the address of each victim, the amount of loss for each victim, and documentary support for each amount. If liability for restitution is joint and several, the government shall itemize the restitution amount for which each defendant is responsible.
If counsel cannot resolve their disagreements, they should present any outstanding disagreements at least three weeks prior to trial (or trial pool ready date) by providing a transcript of the testimony with the challenged question and answer highlighted, and a list setting forth each objection by page and line numbers and the basis for the objection.
Counsel should provide Judge Younge with two (2) copies of each exhibit and a schedule which briefly describes each exhibit.
Reply and sur-reply briefs may address only issues raised in the opposing brief and may not repeat arguments in the movant’s previously filed briefs.
Court's wording
Reply briefs and sur-reply briefs, addressing only issues raised in the brief in opposition and not repeating arguments in briefs that were previously filed by the movant, may be filed within seven days of service of the opponent’s brief in opposition/reply and shall be limited to ten pages.
Proposed orders, although only a proposal, should nonetheless be titled “Order” and should not contain an attorney’s name or address.
If meant to ultimately be filed under seal, please include “File Under Seal” in the caption.
- Placement
- Caption
Include
- •“File Under Seal”
Judge Younge will approve a confidentiality order if the order includes a detailed statement demonstrating that good cause exists.
Parties should identify expert witnesses and engage in expert discovery pursuant to the scheduling order entered in the particular case.
Failure to do so may bar the use of the expert’s testimony at trial.
Proposed points for charge and special jury interrogatories must be prepared and submitted jointly; counsel are expected to seek agreement, and points for charge should include appropriate legal citations, including applicable Third Circuit Model Civil Jury Instructions.
Court's wording
a. The proposed points for charge and special jury interrogatories shall be prepared and submitted jointly. Counsel are expected to work together to achieve agreement on as many items as possible before submission to Judge Younge. Proposed points for charge should be accompanied by appropriate citations of legal authority – including use of the Model Civil Jury Instructions for the Third Circuit, where applicable (see http://www.paed.uscourts.gov, “Third Circuit Model Jury Instructions” bullet).
Counsel will be expected to file findings of fact and conclusions of law no later than ten (10) days after the motion hearing unless otherwise directed by the Court.
Where counsel cannot agree on a particular point for charge or on the verdict form, the joint submissions shall provide the alternative version proposed by each party and the rationale and legal authority for each.
Proposed points for charge must be accompanied by appropriate citations of legal authority.
If a proposed point for charge is a model jury instruction, the submission shall state whether the model jury instruction is unchanged or modified.
Judge Younge’s practice in criminal matters is to personally conduct the voir dire.
However, in civil matters Counsel will usually conduct voir dire with minimal oversight from the Judge and his court deputy.
Counsel are free to submit proposed (by a date set in this Court’s pre- trial order) and supplemental voir dire (on the trial date) to Judge Younge.
Should the need for follow-up questioning arise, Judge Younge may permit counsel to either do so themselves or submit follow-up questions for Judge Younge to ask.
Judge Younge generally permits 3-6 months of discovery, except for more complex litigation.
e. Supplemental points for charge will be permitted during and at the conclusion of trial.
Counsel may submit trial briefs when they are likely to be helpful to the Court.
Counsel are expected to work together to achieve agreement on as many items as possible before submission to Judge Younge.
Filing & Service rules
Filing Timing and Cure Windows
Counsel must file the completed Rule 26(f) meeting report with the Clerk at least five business days before the Rule 16 conference.
Without exception, counsel must, at least five business days prior to the Rule 16 conference, file with the Clerk of Court a completed report of their Rule 26(f) meeting.
Page 9 | A. Pre-trial Procedure
The Rule 26(f) meeting must occur as soon as possible and at least ten days before the Rule 16 conference.
A Rule 26(f) meeting shall take place as soon as possible, and at least ten days prior to the Rule 16 conference.
Page 9 | A. Pre-trial Procedure
Reply and sur-reply briefs may be filed within seven days after service of the opposing brief, must address only issues raised in that brief without repeating the movant’s prior arguments, and are limited to ten pages.
Reply briefs and sur-reply briefs, addressing only issues raised in the brief in opposition and not repeating arguments in briefs that were previously filed by the movant, may be filed within seven days of service of the opponent’s brief in opposition/reply and shall be limited to ten pages.
Page 10 | 5. Reply and Sur-Reply Briefs
If the responding party sets forth additional disputed material facts, the moving party must respond within 7 business days.
3. If a responding party sets forth additional disputed material facts, the moving party shall, within 7 business days, file a response either admitting those facts are disputed, or contending they are undisputed and, as such, are not genuine issues to tried.
Page 13 | Summary Judgment
Motions in limine are usually due three weeks before trial, and responses are due within five business days after the motion is filed.
As noted above, motions in limine usually are due three weeks before trial. A response to any motion in limine is due within five business days of the filing of the motion.
Page 14 | F. Motions in Limine
The parties must file a pretrial memorandum seven days before the final pretrial conference.
The parties shall file a pretrial memorandum in accordance with Local Rule of Civil Procedure 16.1(c) seven days prior to the final pretrial conference.
Page 15 | G. Final Pre-trial Conference
Pre-trial motions must be filed by the scheduling-order deadline and no later than six weeks before trial.
The Parties must file any pre-trial motions, including Starks and Daubert motions or motions to suppress evidence, on or before the deadline established by the scheduling order entered by the Court, and under no circumstances later than six (6) weeks prior to the commencement of trial.
Page 17 | CRIMINAL CASES — A. Motions Practice and Pre-trial Hearings
Hearings on Starks, Daubert, or suppression motions must be held at least 30 days before trial.
Any hearing on Starks/Daubert and/or Suppression Motions will be held at least thirty (30) days prior to trial.
Page 17 | CRIMINAL CASES — A. Motions Practice and Pre-trial Hearings
The opposing party must respond to a pre-trial motion within seven days after it is filed.
The opposing Party must respond to any pre-trial motion no later than seven days after the motion is filed.
Page 17 | CRIMINAL CASES — A. Motions Practice and Pre-trial Hearings
The parties must jointly prepare and submit proposed points for charge and a proposed jury verdict form at least three weeks before the case is listed for trial or as provided in the scheduling order; submissions must be emailed in Microsoft Word format, not PDF.
At least three weeks before the case is listed for trial and/or in accordance with the scheduling order entered by the Court, the Parties shall jointly prepare and submit to the Court proposed points for charge and proposed jury verdict form in accordance with the instructions below. Documents must be submitted via e-mail to Chambers_Younge@paed.uscourts.gov in Microsoft Word format - .pdf format is not acceptable.
Page 18 | CRIMINAL CASES — C. Pre-trial Submissions
Government and defense sentencing memoranda must be filed simultaneously at least seven days before sentencing, and any response must be filed at least five days before sentencing.
Sentencing memoranda (exclusive of motions), by both the government and the defense must be filed simultaneously no later than seven (7) days before the scheduled sentencing date, and any response thereto must be filed at least five (5) days prior to the scheduled sentencing date.
Page 21
Sentencing motions and supporting memoranda, and any responses to them, must be filed at least seven days before sentencing.
Sentencing motions (including motions for downward departure or variance) and supporting memoranda must be filed at least seven (7) days prior to the scheduled sentencing date, and any response thereto must be filed at least seven days prior to the scheduled sentencing date.
Page 21
Motions in limine are usually due three weeks before trial.
As noted above, motions in limine usually are due three weeks before trial.
Page 14 | F. Motions in Limine
The parties are expected to submit objections to witnesses and exhibits, including objections to opposing counsel’s objections, by a date set at the final pre-trial conference, usually three weeks before trial.
At the final pre-trial conference, a date will be set (usually three weeks prior to trial) when the Parties will be expected to submit their objections to witnesses and exhibits, and to opposing counsel’s objections.
Page 15 | G. Final Pre-trial Conference
Service and Proof of Service Rules
Counsel must mark and exchange exhibits before a hearing or trial begins.
Counsel must mark and exchange exhibits before commencement of a hearing or trial.
Page 6 | O. Exhibits
A party intending to use a written or video deposition at trial must notify all other parties in writing one month before the trial date established at the final pretrial conference.
Any party intending to use depositions, written or video, at trial must notify all other Parties in writing one month prior to the trial date established at the final pretrial conference.
Page 15 | G. Final Pre-trial Conference
Courtesy Copy Requirements
A second copy of the exhibits must be provided to the Court on the first day of trial or jury selection.
A second copy shall be provided to this Court on the first day of trial or jury selection.
Page 6 | O. Exhibits
The first copy of the exhibits must be provided three weeks before trial or the trial pool ready date.
The first copy of the exhibits shall be provided three weeks prior to trial or trial pool ready date.
Page 6 | O. Exhibits
When directed to submit a courtesy copy, counsel must deliver it to Chambers by U.S. mail or hand delivery.
If counsel are directed to submit a courtesy copy, please deliver to Chambers via U.S. mail or hand delivery.
Page 10 | 4. Motion Practice
On a date set at the final pre-trial conference, usually three weeks before trial, the parties must provide the Court one copy of each exhibit and two copies of a schedule describing each exhibit.
At the final pre-trial conference, a date will be set (usually three weeks prior to trial) at which point the parties will be required to provide the Court with one copy of each exhibit and two copies of a schedule of exhibits which shall describe each exhibit.
Page 15 | G. Final Pre-trial Conference
At trial, the parties must provide the Court one additional copy of each exhibit.
At trial, the parties shall provide the Court with an additional copy of each exhibit.
Page 15 | G. Final Pre-trial Conference
The objecting party must provide the Court a copy of the deposition transcript with the challenged testimony highlighted.
The objecting party must provide the Court with a copy of the deposition transcript with the challenged testimony highlight.
Page 16 | G. Final Pre-trial Conference
Counsel should provide Judge Younge two copies of each exhibit and a brief schedule describing them.
Counsel should provide Judge Younge with two (2) copies of each exhibit and a schedule which briefly describes each exhibit.
Page 6 | O. Exhibits
Chambers may request a courtesy copy when a motion or its exhibits are voluminous.
If the motion or the exhibits to the motion are voluminous, counsel may be contacted by Chambers to request a courtesy copy.
Page 10 | 4. Motion Practice
Sealing & Redaction Procedures
The Court will approve sealing orders upon a showing of good cause, and the Deputy must be notified whenever judicial documents are impounded or proceedings are sealed.
The Court will ===== PAGE 22 ===== approve of sealing orders for good cause shown. Please notify Judge Younge’s Deputy, Ms. Dedra Brannan, whenever any judicial documents are to be impounded, or whenever any court proceedings must be sealed.
Page 22 | H. Sealing of Judicial Documents
Pre-Motion Conference Requirements
When a TRO is requested, the judge will schedule a conference as soon as counsel have appeared and the request can be properly considered, unless the Court can resolve it on the papers.
When a temporary restraining order (“TRO”) is requested, Judge Younge will schedule a conference as soon as counsel have appeared and it is possible to properly consider the request, unless the Court can resolve the TRO on the papers.
Page 16 | H. Injunctions — 1. Scheduling and Expedited Discovery
The judge usually permits expedited discovery when preliminary injunctive relief is requested.
Judge Younge usually permits expedited discovery when preliminary injunctive relief is requested.
Page 16 | H. Injunctions — 2. Hearings
The judge rarely grants ex parte TROs.
Judge Younge rarely grants ex parte temporary restraining orders.
Page 16 | H. Injunctions — 1. Scheduling and Expedited Discovery
The judge schedules preliminary and permanent injunction hearings as soon as practicable and combines them when appropriate.
Judge Younge schedules preliminary and permanent injunctions hearings as soon as practicable and combines the two hearings if appropriate.
Page 16 | H. Injunctions — 2. Hearings
Before a formal hearing, the judge may hold a conference with counsel.
Prior to any formal hearings, Judge Younge may hold a conference with counsel.
Page 16 | H. Injunctions — 2. Hearings
If the Court does not set a pretrial-motion hearing date, counsel may request oral argument on Starks, Daubert, or suppression motions.
In the unusual event that Judge Younge does not establish a motion hearing date, counsel may then submit a request for oral argument on Starks and Daubert motions or motions to suppress.
Page 17 | CRIMINAL CASES — A. Motions Practice and Pre-trial Hearings
The judge may schedule a criminal pretrial conference, typically five days before trial, to address voir dire, motions in limine, jury instructions, and verdict forms.
Judge Younge may schedule a pre-trial conference in a criminal case – typically five (5) days prior to trial. Any issues relating to voir dire, motions in limine, jury instructions, and jury verdict forms will be addressed at that time.
Page 19 | D. Pre-trial Conferences
Adjournment & Extension Requirements
A trial-continuance request must be filed as a motion stating its reasons at least 14 days before trial.
Any request for a continuance must be filed no later than fourteen (14) days in advance of the scheduled trial date. Requests for a continuance must be filed as a motion stating the reasons for the request.
Page 17 | CRIMINAL CASES — B. Continuances of Trial
Continuance requests in criminal cases may not be made by letter.
Continuance requests by letter in criminal cases are not permitted.
Page 18 | CRIMINAL CASES — B. Continuances of Trial
The Court will consider motions to extend discovery deadlines if good cause is shown.
However, the Court will consider motions for extension of discovery deadlines upon showing of good cause.
Page 10 | 3. Continuances and Extensions
A hearing will be held on a government continuance request if the defendant will not sign the speedy-trial waiver.
For a government continuance request, where the defendant will not sign the waiver, a hearing will be held.
Page 18 | CRIMINAL CASES — B. Continuances of Trial
Continuances of sentencing are discouraged and will be granted only for good cause.
Requests for continuance from sentencing are discouraged, and sentencing will be continued for good cause only.
Page 20 | F. Sentencing
Chambers Communication Rules
Ex parte communications with the Court are prohibited, whether written or otherwise.
Judge Younge does not permit ex parte communication with the Court, written or otherwise.
Page 1 | A. Correspondence with the Court
All listed pretrial submissions must be sent by email to Chambers_Younge@paed.uscourts.gov.
All documents must be sent via e-mail: Chambers_Younge@paed.uscourts.gov.
Page 14 | E. Pre-trial Submissions
Pre-trial submissions must be emailed to Chambers_Younge@paed.uscourts.gov in Microsoft Word format; PDF is not acceptable.
Documents must be submitted via e-mail to Chambers_Younge@paed.uscourts.gov in Microsoft Word format - .pdf format is not acceptable.
Page 18 | CRIMINAL CASES — C. Pre-trial Submissions
Counsel may email the Court about unopposed extensions and scheduling, but disputed matters must proceed through motion practice rather than correspondence.
Counsel may write to Judge Younge to request an unopposed extension of time and for unopposed requests pertaining to scheduling. However, Judge Younge does not permit correspondence in lieu of opposed extension requests, contested discovery or substantive motions, or other disputed substantive matters which should be made of record via motion practice. Correspondence may be e-mailed to Judge Younge at Chambers_Younge@paed.uscourts.gov.
Page 1 | A. Correspondence with the Court
The Court does not accept carbon copies of letters sent to opposing counsel.
Judge Younge does not accept carbon copies of letters to opposing counsel.
Page 1 | A. Correspondence with the Court
Counsel generally may not contact law clerks directly; Chambers communication usually goes through the Judge’s Deputy by phone or email, and clerk-initiated contact is at the Judge’s direction.
Judge Younge generally does not permit counsel to directly communicate with law clerks. If a law clerk contacts counsel, it is at Judge Younge’s direction. Usually, communication with Chambers shall occur via Judge Younge’s Deputy, Ms. Dedra Brannan, at 267-299-7361, or via e-mail to Chambers_Younge@paed.uscourts.gov.
Page 2 | B. Communication with Law Clerks
Counsel must discuss objections to videotaped testimony before trial in an effort to resolve them.
Counsel must discuss in advance of trial all objections to the presentation of videotaped testimony to resolve all conflicts.
Page 3 | K. Videotaped Testimony
Counsel are expected to discuss and attempt to resolve objections to exhibits and testimony before submitting unresolved objections to the Court.
It is expected that counsel have discussed and have attempted to resolve all objections to exhibits and testimony prior to submitting those objections to this Court, leaving only those objections the parties could not resolve.
Page 15 | G. Final Pre-trial Conference
Counsel are advised to provide current telephone and fax numbers to the Clerk’s Office.
Counsel are advised to submit current telephone and fax numbers to the Clerk’s Office.
Page 1 | A. Correspondence with the Court
Counsel of record will receive advance email notice explaining remote connection instructions and whether a conference will be by phone or video.
All counsel of record will be notified via e-mail in advance of the conference on how to connect remotely, and if it will be held telephonically or through use of video conference technology.
Page 2 | C. Video and Telephonic Conferences
Counsel may contact Chambers the day before a hearing or trial to learn the assigned courtroom.
Counsel may contact Chambers the day prior to any hearing or trial to ascertain the assigned courtroom.
Page 4 | L. Hearing and Trial Dates
Counsel are strongly urged to resolve discovery disputes among themselves.
When a discovery dispute arises, counsel are strongly urged to settle it amongst themselves.
Page 11 | B. Discovery Matters — 2. Discovery Disputes