Judge Mia Roberts Perez
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Adjournments
- Trial pool cases require 48-hour notice; trial date extensions need 30-day written notice.
- Downward departure motions (except § 5K1.1) due 2 weeks before sentencing; § 5K1.1 motions due 1 week before.
- Replies and sur-replies must be filed no later than 7 days after the filing to which it responds, but Judge Perez reserves the right to rule on the motion in the interim.
Communication
Chambers
Page & Word Limits4 rules
Any motion and its supporting memorandum of law, as well as opposition briefs, shall not total more than 20 pages.
- Motion
- Up to 20 pages
A sur-reply may only be filed with permission of the Court upon good cause shown and may not exceed 5 pages.
- sur-reply
- Up to 5 pages
Reply briefs in support of a dispositive motion may be submitted without leave of Court. Replies must be responsive to arguments raised by opposing counsel and shall not exceed 7 pages.
- Reply brief for attorneys
- Up to 7 pages
Exception
More pages with leave of court
Counsel will be permitted a maximum of 30-minutes for opening statements and 45 minutes for closing arguments.
Document Format Requirements1 rule
All writings submitted to Judge Perez’s Chambers should be written in 12-point Times New Roman font with 1-inch page margins.
- Font
- Times New Roman
- Font size
- 12 points
- Margins
- 1 inch
Document Filing Requirements10 rules
ECF filings must be text-searchable; exhibits need descriptive file names; reference documents by docket number; don't use existing docketed documents as exhibits.
- Document
- ECF filing
Must include
- •Text-searchable
Court's wording
All ECF filings must be text-searchable, including exhibits. Exhibits must be given file names that identify what the document is. When referencing a document on the docket, parties shall refer to that document by its docket number. Any document that is already on the docket should not be used as an exhibit.
Motions for pro hac vice admission must be made using the Eastern District of Pennsylvania’s form; this is available on the Court’s website:
Disclosure statements required to identify third-party litigation funding.
Court's wording
Parties and intervenors must file a disclosure statement that identifies any third party that is funding any portion of the litigation. This requirement is in addition to Federal Rule of Civil Procedure 7.1’s requirements.
Certification of pre-motion conference required with Rule 12 motions.
- Document
- Motion
- Placement
- Certificate section
Must include
- •Certificate of conference
Court's wording
If the parties are unable to reach a resolution that eliminates the need for a Rule 12 motion, counsel for the moving party shall include, along with the motion, a certification that the parties met and conferred regarding the alleged pleading deficiencies or matter sought to be stricken. The Court will deny any motion that fails to conform with these requirements.
Summary judgment motions require jointly prepared statement of facts and exhibit list.
- Document
- Motion
Must include
- •Exhibit list
- •Index of exhibits
Court's wording
All summary judgment motions must be accompanied by a statement of facts that the parties will prepare jointly and that must be separately filed on the docket. All parties must attach a joint list of all exhibits referenced in the statement of facts, in addition to an index of the exhibits.
Counsel shall discuss and agree upon voir dire questions. If necessary, disputes regarding voir dire questions may be submitted to Judge Perez for resolution. Prior to the final pretrial conference, counsel shall submit a joint neutral statement of the facts and joint questions for voir dire, highlighting only the disputed questions. Voir dire should not be more than 15 questions.
- Document
- Voir dire
Must include
- •Joint voir dire questions
- •Joint neutral statement of facts
Sentencing memoranda due 1 week before sentencing; restitution details required if applicable.
Court's wording
Both the government and the defendant must submit sentencing memorandum no later than one week prior to sentencing. If a defendant is responsible for restitution, the government must include sufficient information in its memorandum to enable the Court to determine entitlement. This includes the name and address of each victim, and the amount of loss for each victim. Documentary support for each amount should also be included.
This process of serving and responding should not be filed with the Court on the docket but must be realized with all other parties.
Counsel will determine which exhibits will be given to the jury after it retires to deliberate. If counsel cannot agree, they should request a ruling immediately after the jury retires to the deliberation room.
Speaking objections are discouraged and should include only the word “objection” and the relevant rule number. Sidebars will be permitted only sparingly.
Filing & Service rules
Pre-Motion Conference Requirements
All motions to dismiss, transfer, or add parties and other threshold motions should be filed before the Rule 16 conference.
All motions to dismiss, transfer, or add parties and other threshold motions should be filed before the Rule 16 conference.
Page 3 | A. RULE 16 CONFERENCES
Pre-motion conference required 7 days before Rule 12 motions (except pro se, bankruptcy, social security cases).
Except in cases where either side is pro se, or in bankruptcy or social security appeals, any party intending to file a motion under Federal Rule of Civil Procedure 12 must contact opposing counsel to discuss the substance of the contemplated motion and to provide an opportunity to cure any alleged pleading deficiencies or strike certain matter. This conference shall take place at least seven days prior to the filing of the motion.
Page 5 | B. Conferences Before Filing Rule 12 Motions
Moving party must serve statement of undisputed facts 28 days before summary judgment deadline.
At least 28 days before the deadline to file a motion, the moving party must serve all other parties a statement of undisputed facts in a numbered, paragraph-by-paragraph statement that contains specific citations to the record that support each factual assertion.
Page 5 | C. Motions for Summary Judgment
Responding party must serve response to undisputed facts 14 days before summary judgment deadline.
At least 14 days before the deadline to file a motion, a responding party must serve on all other parties, a response to the moving party’s statement of facts that responds to each factual assertion. All responses should be directly under the original paragraph of the moving party’s motion and must include citations to any evidence that the responding party believes is necessary to show that the moving party has not cited evidence that supports a factual assertion.
Page 6 | C. Motions for Summary Judgment
Rule 16 conference scheduled after answer or during preliminary motions.
Judge Perez will schedule a Rule 16 conference once an answer is filed, or in some instances, while a motion to dismiss or another preliminary motion is pending.
Page 3 | A. RULE 16 CONFERENCES
Moving party may respond to responding party's submissions under each paragraph.
The moving party may then respond to any statement or arguments in the responding party’s submission, directly under the paragraph in question.
Page 6 | C. Motions for Summary Judgment
Adjournment & Extension Requirements
In civil cases, all motions should be filed in compliance with the Scheduling Order.
In civil cases, all motions should be filed in compliance with the Scheduling Order.
Page 4 | A. LENGTH LIMITATIONS
Trial pool cases require 48-hour notice; trial date extensions need 30-day written notice.
Counsel shall comply with all deadlines set forth in the scheduling order. Counsel for cases in the trial pool must be prepared to commence trial upon 48-hours’ notice. Any requests to extend a trial date must be submitted to Chambers in writing 30-days prior to trial.
Page 6 | A. Scheduling
Downward departure motions (except § 5K1.1) due 2 weeks before sentencing; § 5K1.1 motions due 1 week before.
All motions for downward departure, except motions filed under § 5K1.1 of the U.S. Sentencing Guidelines, must be filed two weeks prior to sentencing. Such motions should include legal and factual support for the proposed departure. A government motion pursuant to § 5K1.1 must be filed at least one week prior to sentencing.
Page 7 | F. Sentencing
Replies and sur-replies must be filed no later than 7 days after the filing to which it responds, but Judge Perez reserves the right to rule on the motion in the interim.
Replies and sur-replies must be filed no later than 7 days after the filing to which it responds, but Judge Perez reserves the right to rule on the motion in the interim.
Page 4 | A. LENGTH LIMITATIONS
Chambers Communication Rules
Pro se litigants must communicate only through Clerks’ Office, not directly with Chambers.
All pro se communications must be directed to the Clerks’ Office to be docketed. Pro se litigants may not contact Judge Perez or her Chambers directly.
Page 2 | B. PRO SE (UNREPRESENTED LITIGANTS) COMMUNICATIONS
Chambers communications limited to scheduling/non-substantive matters via phone/email; substantive matters require motion/filing; no ex parte communications on substantive matters.
Judge Perez permits communications with Chambers by telephone or email regarding scheduling and other non-substantive matters. All other issues must be addressed by motion or other filing. Under no circumstances may any party or counsel communicate ex parte with any Chambers personnel concerning substantive matters.
Page 2 | A. COMMUNICATIONS WITH CHAMBERS
Counsel must meet daily to discuss witness order and inform Court.
During trial, counsel shall meet each morning to discuss between themselves the order in which witnesses will be called and evidence will be presented. Counsel must inform the Court of such order.
Page 6 | C. Exhibits