Judge José R. Arteaga
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Lengthy Materials
Adjournments
- Parties adjourning a conference to obtain settlement authority may incur sanctions including opposing counsel fees.
- Parties must request extensions or continuances via email in advance with detailed justification, opposing party position, and proposed new dates; requests for trial or dispositive motion deadlines are rarely granted.
Request must include
Communication
Chambers
Phone
Chambers
Page & Word Limits8 rules
The case synopsis should be no more than five-pages in length.
- Case synopsis
- Up to 5 pages
Attachments should be no more than 15 pages and should be separated with labeled divider pages.
- Attachment
- Up to 15 pages
Memoranda must not exceed 30 pages in length (excluding table of contents and appendices), must be double spaced and must use 12-point font.
- Page limit
- Up to 30 pages
- Format
- Double-spaced; 12-point
Excluded from page count
- •Table of contents
- •Appendices
The summary should be no more than five pages in length, single spaced.
- Page limit
- Up to 5 pages
- Format
- Single-spaced
Attachments must be no more than 15 pages in total.
- Attachment
- Up to 15 pages in total
Case synopsis for settlement conference must not exceed 5 single-spaced pages.
- Case synopsis
- Up to 5 pages
- Format
- Single-spaced
Court's wording
The synopsis will include a candid discussion of the submitting party’s factual and legal strengths and weaknesses in the case as well as an offer/demand settlement proposal and IS STRICTLY LIMITED TO NO MORE THAN FIVE (5) PAGES SINGLE SPACED.
Motion and response briefs are limited to 30 pages, reply briefs to 15 pages, both absent court leave; reply briefs may not raise new issues.
- Brief
- 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.
Attachments should be no more than thirty (30) pages
- Attachment
- Up to 30 pages
Document Format Requirements5 rules
Attachments should be no more than 15 pages and should be separated with labeled divider pages.
- Attachment
Formatting
- •Separated with labeled divider pages
Only attach excerpts which are most relevant to the claims at issue.
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_Arteaga@paed.uscourts.gov.
- File type
- Word
- Proposed jury instructions
- Verdict form
should be separated with labeled divider pages
Formatting
- •Attachments to case synopsis must be separated with labeled divider pages
Document Filing Requirements20 rules
The synopsis should attach key summary expert reports, policy language excerpts, photographs, sketches, diagrams, charts, etc., to the conference memos.
In addition, the synopsis should address whether there are any outstanding lien holders or other third parties who should be invited to participate in the settlement conference.
Discovery motions must include certifications under FRCP 37 and Local Rule 26.1(f) confirming good faith confer efforts.
- Document
- Discovery motion
Must include
- •Certificate of conference
Court's wording
Parties are reminded that 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.” Fed. R. Civ. P. 37(a)(1). 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.” E.D. Pa. Local R. Civ. P. 26.1(f).
As Federal Rule of Civil Procedure 26(c) requires, a motion seeking a protective order must explain why there is good cause for the Court to issue the order.
A proposed order attached to the motion must itself also state the reasons good cause exists and state that the private interests in nondisclosure outweigh the public interests in disclosure.
Protective orders must include language reserving the Court's power to modify the order for justice interests.
Court's wording
Judge Arteaga will not approve any protective order unless it contains language providing that “the Court reserves its inherent power to modify the terms of this agreement and permit the disclosure of information where the interest of justice so requires.”
Parties must file a formal motion to memorialize a confidentiality agreement, not just a stipulated proposed order.
Court's wording
If parties who form a mutually acceptable confidentiality agreement want a Court order to memorialize their agreement, they must make a formal motion. Judge Arteaga will not accept stipulated proposed orders in lieu of a motion.
Memoranda over 15 pages in length must include a table of contents and table of authorities.
Must include
- •Table of contents
- •Table of authorities
Joint appendices must have consecutively numbered appendix pages, TOC, and memoranda must reference appendix page numbers.
- Document
- Joint appendix
Must include
- •Table of contents
Court's wording
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.
Supplemental joint appendices require court permission, must include original appendix, continue page numbering, and have updated TOC.
- Document
- Supplemental joint appendix
Must include
- •Table of contents
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.
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.
Motions for leave to file under seal must articulate why secrecy interests outweigh public access and identify specific serious injuries from disclosure.
Court's wording
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 Arteaga will not grant a motion for leave to file under seal that fails to identify the movant’s interests in nondisclosure with specificity.
For summary judgment responses, the responding party must file a separate Counterstatement of Facts accepting or rejecting each paragraph with appendix citations.
- Document
- Response to motion for summary judgment
Must include
- •Counterstatement of facts
- •Statement of facts
Court's wording
At the same time a response to the motion for summary judgment is filed, the responding party must file a separate Counterstatement of Facts that responds to each paragraph of the Statement by accepting or rejecting the contention in the paragraph. If a contention is rejected, the responding party must supply facts supporting the rejection by specific page reference(s) from the joint appendix.
For summary judgment motions, the moving party must file a separate Statement of Facts with numbered paragraphs citing the joint appendix.
- Document
- Motion for summary judgment
Must include
- •Statement of facts
Court's wording
At the same time as its motion for summary judgment, the moving party must also file a separate Statement of Facts (the “Statement”) containing a numbered, paragraph-by-paragraph recitation of the facts that the moving party contends are undisputed, with specific page references to the joint appendix in support of each paragraph. Each paragraph shall deal with one fact.
Parties should ordinarily file a joint pretrial stipulation instead of complying with Local Rule 16.1.
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 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.
Any exhibits should be docketed in compliance with Local Rule of Civil Procedure 5.1.2(5)(b).
Joint Pretrial Stipulation must be signed by trial counsel, include 8 specified sections, and objections to testimony/exhibits must state grounds and authority.
- Document
- Joint pretrial stipulation
Must include
- •Exhibit list
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). Any objections to anticipated testimony or exhibits shall describe with particularity the ground and the authority for the objection.
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.
Attorneys and pro se parties using generative AI to prepare specified filings must disclose AI use, identify AI-used portions, and certify citation accuracy under Rule 11.
- Document
- 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 Arteaga shall: (1) disclose that generative artificial intelligence was used to prepare the filing; (2) identify precisely what portion or portions of the 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.
Filing & Service rules
Electronic Filing Rules
Proposed jury instructions and verdict form must be filed on the Court’s docket.
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_Arteaga@paed.uscourts.gov.
Page 17
Filing Timing and Cure Windows
Counsel must notify the Court of a lack of settlement possibility at least one week before the scheduled settlement conference via call or email.
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.
Page 2 | II. SETTLEMENT CONFERENCES
Counsel must submit a confidential settlement summary and case synopsis via email two weeks before the scheduled settlement conference.
Counsel for all parties must submit a confidential settlement summary and case synopsis via email (to Chambers_of_Magistrate_Judge_Arteaga@paed.uscourts.gov) two weeks before the conference.
Page 2 | II. SETTLEMENT CONFERENCES
Plaintiffs must submit a written settlement demand at least three weeks before the scheduled settlement conference.
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.
Page 2 | II. SETTLEMENT CONFERENCES
Defendants must submit a written settlement offer at least two weeks before the scheduled settlement conference.
Defendant(s) must make an updated, precise, and specific written settlement offer at least two weeks before the conference.
Page 2 | II. SETTLEMENT CONFERENCES
Joint appendix must be filed by the movant no later than the initial summary judgment motion docket date.
The joint appendix must be filed by the movant no later than the date the initial motion for summary judgment is docketed.
Page 6 | E.3.a
Settlement summary and confidential case summary are due 2 weeks prior to the settlement conference.
Counsel for all parties must submit the attached summary and their confidential case summary to Chambers_of_Magistrate_Judge_Arteaga@paed.uscourts.gov on or before (2 weeks prior to the conference).
Page 12 | II. SETTLEMENT CONFERENCES
Defendant's settlement offer is due 2 weeks prior to the settlement conference.
Defendant(s) must make an updated, precise, and specific written settlement offer on or before (2 weeks prior to the conference).
Page 12 | II. SETTLEMENT CONFERENCES
Plaintiff's settlement demand is due 3 weeks prior to the settlement conference.
Plaintiff(s) must make an updated, precise, and specific written settlement demand, inclusive of all attorney’s fees, costs, and damages, on or before (3 weeks prior to the conference).
Page 12 | II. SETTLEMENT CONFERENCES
Joint settlement position letter is due 1 week prior to the settlement conference.
Counsel shall submit a joint letter setting forth the most recent settlement positions of the parties on or before (1 week prior to the conference).
Page 12 | II. SETTLEMENT CONFERENCES
Plaintiff expert reports due by fact discovery deadline; Defendant expert reports due [+2 weeks]; all expert discovery due [+2 weeks].
Plaintiff shall produce any and all expert reports on or before [fact discovery deadline]. Defendant shall produce its expert reports on or before [+2 weeks]. All expert discovery, including rebuttal reports and depositions shall be completed on or before [+2 weeks].
Page 15 | Section 4
All fact discovery must be completed by [+90 days] from the scheduling order date.
All fact discovery shall be completed on or before [+90 days].
Page 15 | Section 3
All motion responses must be filed within the timeframe specified in Local Rule 7.1(c).
Responses to all motions are due within the period prescribed by Local Rule 7.1(c).
Page 16 | Footnote 1
Service and Proof of Service Rules
Parties must submit Rule 26(f) report via email to chambers at least 5 days before scheduling conference if not already on docket.
If a Rule 26(f) report is not already on the docket when a case is assigned to Judge Arteaga, the parties shall submit a copy of their Rule 26(f) report via email (to Chambers_of_Magistrate_Judge_Arteaga@paed.uscourts.gov) at least five days before the scheduled conference.
Page 4 | III. CIVIL CONSENT CASES A. Scheduling Conferences
Courtesy Copy Requirements
Judge Arteaga may require hard copies of lengthy materials.
Judge Arteaga may require parties to provide hard copies of lengthy materials.
Page 3 | II. SETTLEMENT CONFERENCES
Sealing & Redaction Procedures
Protective orders may not include language allowing parties to seal materials without prior specific court approval.
Also, Judge Arteaga will not approve a protective order containing language that gives the parties discretion to file materials under seal without the Court’s prior and specific approval.
Page 5 | I. GENERAL MATTERS
Even when sealing is granted, parties must generally file redacted versions on the public docket unless redactions would render the document unreadable.
Even when Judge Arteaga grants a motion for leave to file under seal, he 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 | I. GENERAL MATTERS
Documents should not be filed under seal without first obtaining leave of court, except in emergencies.
Except in emergency situations, documents should not be filed under seal without first obtaining leave of court.
Page 7 | I. GENERAL MATTERS
Categorical protective orders for large scale discovery are allowed if categories are well-defined, with burden on proponent to justify continued protection item-by-item if challenged.
In cases involving large scale discovery, Judge Arteaga will consider motions to approve protective orders that protect discovery materials on a categorical basis so long as each protected category is reasonably well defined. If a party later challenges such an order, the party seeking to maintain protection over the materials will bear the burden of justifying those materials’ continued protection on an item-by-item basis.
Page 5 | I. GENERAL MATTERS
Motions for leave to file under seal should be filed on the public docket with redactions; unredacted copies must be provided to the Court and all parties.
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 7 | I. GENERAL MATTERS
Filing Bundling Requirements
Exhibits must be provided as two tabbed loose-leaf books (one for judge, one for law clerk) with joint, plaintiff's, and defendant's exhibits.
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 his law clerk—each book containing tabbed Joint Exhibits, Plaintiffs Exhibits, and Defendant’s Exhibits.]
Page 19 | JOINT PRETRIAL STIPULATION - section 7
Pre-Motion Conference Requirements
Parties must email chambers to request telephone conference before filing discovery motion, including prior efforts, dispute summary, and relevant attachments.
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_Arteaga@paed.uscourts.gov to request a telephone conference before filing any discovery motion on the docket. 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 Arteaga’s consideration of the dispute.
Page 4 | III. CIVIL CONSENT CASES B. Discovery Conferences and Dispute Resolution
Good faith telephone/video conference required before judicial intervention for discovery disputes.
Judge Arteaga 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.
Page 4 | III. CIVIL CONSENT CASES B. Discovery Conferences and Dispute Resolution
Parties filing summary judgment motions must meet and confer to develop a single joint appendix of exhibits.
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.
Page 6 | E.3.a
Parties must request a pre-filing conference with the Court before filing any discovery motion requiring intervention.
If Court intervention is required, the parties shall request a conference before filing any discovery motion.
Page 16 | Footnote 1
Dispositive motions and Rule 702 expert exclusion motions must be filed by [+4 weeks], responses by [+2 weeks], replies by [+1 week].
Any and all dispositive motions and motions to exclude expert witness evidence pursuant to Federal Rule of Evidence 702 shall be filed on or before [+4 weeks]. Responses to any such motions shall be filed by [+2 weeks] and replies, if any, shall be filed on or before [+1 week].
Page 16 | Section 6
Motions in limine must be filed 14 days prior to Pretrial Stipulation, responses due [+1 week].
All other motions in limine shall be filed on or before [fourteen days prior to Pretrial Stipulation]. Responses shall be filed on or before [+1 week].
Page 16 | Section 7
Parties must confer on discovery confidentiality before seeking court intervention per FRCP 26(c).
Federal Rule of Civil Procedure 26(c) requires parties to confer and attempt to reach an agreement regarding the confidentiality of discovery materials before seeking Court intervention.
Page 5 | I. GENERAL MATTERS
Motion practice is governed by Local Rule 7.1 subject to these procedures, local rules, standing orders, and supplemental rules for Social Security and Section 2254 cases.
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.
Page 6 | E. Motion Practice
Adjournment & Extension Requirements
Parties adjourning a conference to obtain settlement authority may incur sanctions including opposing counsel 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.
Page 3 | II. SETTLEMENT CONFERENCES
Parties must request extensions or continuances via email in advance with detailed justification, opposing party position, and proposed new dates; requests for trial or dispositive motion deadlines are rarely granted.
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. Circumstances which ordinarily do not constitute compelling summer, counsel’s obligations in other cases, and failing to diligently conduct discovery. If a party believes a compelling reason exists for an extension or a continuance, Counsel shall request a new deadline or date in advance of the originally scheduled date via email (to Chambers_of_Magistrate_Judge_Arteaga@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). A request for an extension or continuance of the date on which a case is listed for trial or the deadline for filing dispositive motions rarely will be granted. If the Court is dissatisfied with the compelling reason provided for the requested extension or continuance, Judge Arteaga may schedule a hearing to address the request.
Page 1 | I. GENERAL MATTERS C. Extensions or Continuances
Chambers Communication Rules
Counsel must contact chambers to schedule settlement conferences when a case is referred for settlement.
When a case is referred to Judge Arteaga for settlement purposes, counsel shall contact chambers to schedule a settlement conference in compliance with the district judge’s referral order.
Page 2 | II. SETTLEMENT CONFERENCES
Counsel shall submit a joint letter setting forth the most recent settlement positions of the parties on or before (1 week prior to the conference).
Counsel shall submit a joint letter setting forth the most recent settlement positions of the parties on or before (1 week prior to the conference).
Page 12 | II. SETTLEMENT CONFERENCES
Plaintiff's settlement demand copy may be submitted to chambers via email.
A copy of the demand shall be submitted to chambers by letter or email.
Page 12 | II. SETTLEMENT CONFERENCES
Settlement summary and confidential case summary must be submitted to the provided chambers email address.
Counsel for all parties must submit the attached summary and their confidential case summary to Chambers_of_Magistrate_Judge_Arteaga@paed.uscourts.gov on or before (2 weeks prior to the conference).
Page 12 | II. SETTLEMENT CONFERENCES
Defendant's settlement offer copy may be submitted to chambers via email.
A copy of the offer shall be submitted to chambers by letter or email.
Page 12 | II. SETTLEMENT CONFERENCES
Routine requests to the Court may be submitted via email (with copies to all parties); all requests must state if made with the other party’s consent. Non-routine requests require a motion per Fed. R. Civ. P. 7(b).
All requests for Court action shall be by motion, see Fed. R. Civ. P. 7(b), except for routine requests, which may be by email to the Court with copies to all parties. Any requests shall state whether it is made with the other party’s consent.
Page 16 | Footnote 1
Parties must email Word versions of proposed jury instructions and verdict form to chambers email address.
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_Arteaga@paed.uscourts.gov.
Page 17
Parties must request video equipment reservation at least two weeks before trial via email to chambers.
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_Arteaga@paed.uscourts.gov.
Page 19 | JOINT PRETRIAL STIPULATION - section 6
Chambers contact information: phone (267) 299-7420, email Chambers_of_Magistrate_Judge_Arteaga@paed.uscourts.gov; Deputy Clerk Danielle Hauger email danielle_hauger@paed.uscourts.gov.
(267) 299-7420 Chambers_of_Magistrate_Judge_Arteaga@paed.uscourts.gov Courtroom Deputy Danielle Hauger danielle_hauger@paed.uscourts.gov
Page 1 | Header
Judge Arteaga is available for ex-parte video conferences before settlement conferences if jointly requested by counsel; contact chambers to arrange.
If jointly requested by counsel, Judge Arteaga is available for ex-parte video conferences before the settlement conference. Please contact chambers to arrange any pre- conference video call.
Page 2 | II. SETTLEMENT CONFERENCES
Chambers email is Chambers_of_Magistrate_Judge_Arteaga@paed.uscourts.gov for submitting Rule 26(f) reports and requesting discovery conferences.
the parties shall submit a copy of their Rule 26(f) report via email (to Chambers_of_Magistrate_Judge_Arteaga@paed.uscourts.gov) at least five days before the scheduled conference.
Page 4 | III. CIVIL CONSENT CASES A. Scheduling Conferences