Judge David H. Emadi
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Filings > 45 pages
Communication
Chambers
Phone
Court-wideClerk
Page & Word Limits3 rules
Responses to the discovery motion shall be filed within 1 week of the filing of the discovery motion and shall be limited to no more than 10 pages, double spaced.
- Discovery response
- Up to 10 pages
- Format
- Double-spaced
The motion shall be limited to no more than 10 pages, double spaced.
- Page limit
- Up to 10 pages
- Format
- Double-spaced
Except upon written permission of the Court, briefs and responsive briefs shall be limited to twenty-five (25} pages in length, excluding exhibits. Approval to exceed this page length may be requested informally by email.
- Brief
- Up to 25 pages
Excluded from page count
- •Exhibits
Exception
More pages with leave of court
Document Filing Requirements14 rules
Attorneys and pro se litigants must include a certification disclosing any AI-assisted preparation and verifying accuracy of the document and its citations, placed at the end of the document before the signature block.
- Document
- Filing
- Placement
- Certificate section
Court's wording
se litigants): Certification: Any attorney or pro se litigant who uses Al in any capacity to prepare, draft, or review a filing shall disclose such use in the document with the following certification: This document was generated with the assistance of [identify Al tool(s) used, e.g., Chat GPT, Perplexity, Claude, etc.1. | hereby certify under penalty of perjury that, despite reliance on an Al tool, have independently reviewed this document to confirm accuracy, legitimacy, and use of good and applicable law. | hereby certify under penalty of perjury that every citation to law, case, statute, or the record in this document has been verified as accurate and that it exists as cited and for the proposition cited. The above certification must appear at the end of the document, before the signature block.
A certificate of conference must be filed with a discovery motion if the parties could not resolve the dispute.
- Document
- Discovery motion
Must include
- •Certificate of conference
Court's wording
If the good faith efforts to resolve the dispute are not successful, then at the time of filing the motion, "counsel shall also file a statement certifying that such conference has occurred and that the effort to resolve by agreement the issues raised failed." U.S.C.R. 6.4(8).
Parties must submit a fully consolidated pre-trial order by email to the Staff Attorney no later than one week before the trial calendar begins.
- Document
- Pretrial order
Must include
- •Fully consolidated pre-trial order
Court's wording
If a party files a jury demand, or if a party anticipates wanting a trial by jury, then the parties shall submit, by email, a fully consolidated pre-trial order directly to the Staff Attorney no later than one week before the trial calendar begins.
No party may submit their own individual portions of the pre-trial order to the Court without written certification detailing their good-faith efforts to present the Court with a fully consolidated order.
Parties shall email proposed jury charges in Word version to the Staff Attorney at least three business days before the beginning of the trial calendar.
The attorneys shall submit any proposed verdict forms to the Staff Attorney by email in Word format no later than one week prior to the beginning of the trial calendar.
Please include your email address on all Court submissions.
Parties relying on deposition testimony must confer and, if they cannot agree, jointly prepare a list of disputed page and line numbers to provide with their motions in limine.
Court's wording
at Trial If the parties intend to rely on deposition testimony, they shall confer prior to trial and attempt to agree on the testimony to be presented. If they cannot agree on what portions of the deposition testimony should be excluded, they are instructed to jointly prepare alist of page and line numbers at issue and provide it to the Court at the time they file their motions in limine, along with the relevant text from the
In requesting non-pattern charges, parties shall provide the cite to applicable statutory or case authority and shall provide a physical copy of the published case.
Each party shall list by title and pattern number the applicable pattern charges that they request be given, using the current pattern charges published by the Council of Superior Court Judges.
All exhibits and demonstrative evidence shall be marked with exhibit labels and exchanged among the parties prior to the beginning of the trial of the case.
Regarding DVD/CD exhibits, parties shall provide the court reporter with the original and one copy of the DVD/CD. They will need to be contained in a hard case (e.g., jewel case).
Parties shall mark with exhibit labels and provide all documentary evidence to the court reporter in digital format at the time of tender, unless otherwise ordered by the court.
For oversized or non-paper exhibits, e.g., guns, poster boards, etc., parties may submit a digital photograph of the object marked with an exhibit sticker.
Filing & Service rules
Electronic Filing Rules
Electronic filing is mandatory for all parties, who must register with eFileGA and add a service contact to the case.
Electronic filing (e-filing) is mandatory in Fulton County Superior Court. All parties shall create an account with eFileGA and add a service contact to this case to ensure consistent service of orders and other notices from the Court.
Page 1 | SECTION 1. E-FILING NOTICE
Due to eFileGa size limits, parties must scan exhibits individually and email them to the court reporter or place them on a disk.
Due to the size limits of eFileGa, parties are required to: (1) scan all exhibits individually and email them to the court reporter; or (2) scan all exhibits individually and place them on a disk for the court reporter.
Page 8 | 12.6
Filing Timing and Cure Windows
Responses to discovery motions must be filed within 1 week of the motion.
Responses to the discovery motion shall be filed within 1 week of the filing of the discovery motion
Page 4 | SECTION 6. DISCOVERY
All motions, including dispositive motions, must be filed within 30 days after the close of fact discovery, unless otherwise provided by law or Court order.
Except as otherwise provided in the Civil Practice Act or ordered by the Court, all motions, including dispositive motions such as motions for summary judgment and Daubert motions, must be filed within 30 days after the close of fact discovery.
Page 5 | SECTION 8. MOTIONS
Filing a pre-Answer O.C.G.A. § 9-11-12(b) motion postpones the Answer deadline until 15 days after the Court rules on the motion.
Pursuant to changes implemented by the 2025 Tort Reform Act, if a defendant files a pre- Answer motion pursuant to O.C.G.A. § 9-11-12(b), the deadline to file an Answer is postponed until 15 days after the Court rules on that
Page 2 | SECTION 5. EARLY MOTIONS
Discovery is automatically stayed while a pre-Answer O.C.G.A. § 9-11-12(b) motion is pending (up to 90 days), with defined conditions for lifting the stay.
Additionally, discovery is automatically stayed while any pre-Answer§ 9-11-12(b) motion is pending, up to 90 days. If the defendant files an Answer before the Court rules on the motion, the discovery stay is immediately lifted. If the Court does not rule on the motion within 90 days, either party may move to lift the stay of discovery.
Page 2 | SECTION 5. EARLY MOTIONS
Courtesy Copy Requirements
Motions or response briefs over 45 pages (including exhibits) must be hand delivered or mailed to Chambers.
If é motion or response brief is over forty-five (45} pages in length, including exhibits, it must be hand delivered or mailed to Chambers.
Page 5 | SECTION 8. MOTIONS
Pre-Motion Conference Requirements
Parties must confer before filing a discovery motion.
The motion must conform to the requirements of Uniform Superior Court Rules 6.4(A) and (B), including without limitation the requirement that the parties confer prior to the filing of a motion.
Page 4 | SECTION 6. DISCOVERY
Adjournment & Extension Requirements
Any modification of a deadline or hearing date requires the Court's approval, even if all parties consent.
Modification of any deadline or hearing date requires the Court's approval, even if all parties consent to the change.
Page 2 | SECTION 4. DEADLINE EXTENSIONS, GENERALLY
Continuances are granted only for good cause shown.
No continuances will be granted except for good cause shown.
Page 2 | SECTION 4. DEADLINE EXTENSIONS, GENERALLY
Deadline extension requests must be made as soon as the need arises and before the deadline expires.
Any requests for deadline extensions should be made as soon as the need arises and before the deadline expires.
Page 2 | SECTION 4. DEADLINE EXTENSIONS, GENERALLY
Extensions of discovery deadlines are not granted unless requested with good cause before the discovery period expires.
Except where a request is made and good cause shown prior to the expiration of the discovery period, no extension of time for discovery or other discovery motions will be granted.
Page 4 | SECTION 6. DISCOVERY
Parties must immediately notify the Court of any problem or dispute that could delay Court-set deadlines or hearing dates.
Notify the Court immediately of any problem or dispute (e.g., discovery issues, witness unavailability, illness, or the late addition of parties or claims) that could delay the deadlines or hearing dates set by the Court.
Page 2 | SECTION 4. DEADLINE EXTENSIONS, GENERALLY
Chambers Communication Rules
All case questions and discussions must be sent by email to the Staff Attorney with a copy to opposing counsel to avoid ex parte communications.
To avoid ex parte communications, submit all questions, explanations, and discussions concerning this case by email, with a copy to opposing counsel, to the Staff Attorney, Ms. Romero, at Rupal. Romero@fultoncountvga.gov.
Page 2 | SECTION 3. COMMUNICATING WITH THE COURT
To have trial taken down by the court reporter, contact Ms. Sanders at c.eliseporting@outlook.com no later than noon the day before trial.
If counsel or parties would like trial to be taken down by the court reporter, they shall contact Ms. Sanders at c.eliseporting@outlook.com no later than noon on the day prior to start of trial to arrange for takedown.
Page 6 | SECTION 12. TRIAL AND TRIAL PREPARATION
Parties must notify the court at least one week before trial if over 100 exhibits are anticipated and in dispute.
In the event that over 100 exhibits are anticipated and in dispute, the parties must notify the court at least one week in advance of trial so that the Court can decide whether to schedule a pre-trial hearing.
Page 7 | 12.5
Parties must contact Court Technology Services at least one week before trial to confirm evidence viewing equipment and receive training before day one of trial.
Please prepare for trial by contacting Court Technology Services at: sca.techsupport@fultoncountyga.gov at least one week before trial to make certain the evidence viewing equipment has the associated media player, drivers, and accessories necessary for you to make an effective presentation and that you are trained on use of the equipment before day one of trial.
Page 8 | 12.7
Parties should avoid telephoning the Court except in exceptional circumstances.
For this same reason and to prevent miscommunications, please avoid telephoning except in exceptional circumstances.
Page 2 | SECTION 3. COMMUNICATING WITH THE COURT
Proposed orders may be emailed in Word format to the Staff Attorney, with opposing counsel included and a copy of the filed motion attached.
Proposed orders may be emailed in Word format to the Staff Attorney, with opposing counsel included. Please also attach a copy of the filed motion.
Page 5 | SECTION 9. PROPOSED ORDERS
The Court and court staff do not provide training on how to use courtroom technology.
The Court and Court staff are not available to give training on how to work the courtroom technology.
Page 8 | 12.7
Questions about DVD/CD exhibits may be directed to Ms. Sanders at c.eliseporting@outlook.com.
Questions may be addressed to Ms. Sanders at c.eliseporting@outlook.com.
Page 8 | 12.6
To have voir dire taken down by the court reporter, contact Ms. Sanders no later than noon the day before trial.
If the parties want voir dire taken down by the court reporter, Candice Sanders, they must contact Ms. Sanders no later than noon on the day prior to start of trial.
Page 6 | SECTION 12. TRIAL AND TRIAL PREPARATION