Judge Ashley Kilbane
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Filings > 50 pages
Communication
Chambers
Phone
Court-wideClerk
Document Format Requirements4 rules
Excel Documents: if an attachment to a filing or trial exhibit includes an Excel document, an electronic copy in Excel format shall be emailed to the staff attorney.
If any disputes relating to the testimony remain after the good faith conference, the parties shall send hard copies of their respective designations with objections either annotated in the margins or outlined in a separate document to the Court's staff attorney at least fourteen (14) days in advance of trial.
- Deposition testimony designations
Formatting
- •Mark objections in the margins or outline them in a separate document
The proposed jury instructions and interrogatories shall be submitted in Microsoft Word format to the Court's staff attorney.
- File type
- Word
- Jury instructions
- Jury interrogatories
Privilege logs shall be prepared via Microsoft Excel and submitted to both opposing counsel and the Court electronically in Excel format.
Document Filing Requirements11 rules
After the deadline for responses, Counsel and pro se parties shall confer to resolve the motions in limine, and, at least (3) days prior to trial, the parties shall file a joint notice informing the Court which motions in limine are unopposed or resolved, and which remain opposed.
If any disagreement remains, the parties shall highlight disagreements to the Court.
Counsel and pro se parties shall confer regarding jury instructions and interrogatories in order to submit a joint proposed set of jury instructions and interrogatories.
Where privileged documents are submitted for in-camera review, each document shall be stamped with Document ID, and the Court will instruct whether the documents are to be hand-delivered or emailed depending upon the number of pages.
The party challenging the proposed expert testimony shall file a complete copy of the expert’s report(s) and complete deposition transcripts, if the expert was deposed.
Each party must file a final pretrial statement seven days before the conference containing facts, legal issues, stipulations, witnesses, exhibits, unique issues, trial length, contemplated motions, and logistical needs.
Court's wording
The parties shall each file a final pretrial statement seven days before the final pretrial and shall include the following: • A brief statement of facts and legal issues; • Stipulations; • List of witnesses with brief summary of expected testimony; • List of exhibits expected to be used a trial; • Any anticipated unique legal issues; • An estimated length of trial; • Any contemplated pretrial motions; and • Special equipment or potential logistical requests.
The settlement conference statements need not be filed, but instead emailed to the staff attorney.
The Excel file should, at a minimum, have the following column headings: Document ID; Document Custodian; Date of Email/Document; Email Subject or Document Title; Title of Attachment to Email; From and To columns; Description; Type of Privilege Claimed; Basis for Objection/No Objection; Court’s Ruling.
The final pretrial statement shall update the previously-provided settlement statement.
Opposing counsel shall review the privilege log and note where there is no objection or the basis of their objection. The party claiming the privilege will then review the objections and submit to the Court only the remaining objections.
The parties should try to submit attachments to emails as one Document ID with the email, or else note and cross-reference the Document ID of the email and attachment
Filing & Service rules
Filing Timing and Cure Windows
motions in limine must be filed 21 days before trial begins.
Motions in limine shall be filed twenty-one (21) days before the start of trial.
Page 1 | Trials
The parties must exchange trial exhibits no later than seven days before trial.
The parties shall exchange trial exhibits no later than seven (7) days before trial.
Page 1 | Settlement Conference
Seven days before a settlement conference, each party must provide a statement covering the claims for discussion, factual basis of disputes, and prior offers or settlement discussions.
Seven days before the settlement conference, each party shall provide the court with a brief statement outlining the claims to be discussed, the factual support of any disputes, and any offers or settlement discussion had to date.
Page 1 | Settlement Conference
Deposition testimony offered instead of a deponent’s attendance must be exchanged by counsel at least 30 days before trial.
Any party wishing to proffer deposition testimony at trial in lieu of the deponent's attendance shall exchange such deposition testimony by counsel at least thirty (30) days in advance of trial.
Page 1 | Trials
The joint notice on unresolved motions in limine must be filed at least three days before trial.
at least (3) days prior to trial, the parties shall file a joint notice informing the Court which motions in limine are unopposed or resolved, and which remain opposed.
Page 1 | Trials
A Daubert or expert-related motion must be filed by the Court’s deadline or, when no deadline was set, at least 45 days before trial.
Any motion challenging purported expert testimony shall be filed by the Expert Motion deadline set by the Court. If no Expert Motion deadline was set, then any motion challenging purposed expert testimony shall be filed at least forty-five (45) days before trial.
Page 1 | Motion Practice
Proposed jury instructions and jury interrogatories are due seven days before trial.
Proposed jury instructions and jury interrogatories are due seven (7) days before trial.
Page 1 | Trials
The joint proposed jury instructions must be submitted to the staff attorney at least one day before trial.
The parties shall submit a joint proposed set of jury instructions to the Court's staff attorney at least one (1) day before trial.
Page 1 | Trials
Any remaining disputed deposition-testimony designations must be sent to the staff attorney at least 14 days before trial.
If any disputes relating to the testimony remain after the good faith conference, the parties shall send hard copies of their respective designations with objections either annotated in the margins or outlined in a separate document to the Court's staff attorney at least fourteen (14) days in advance of trial.
Page 1 | Trials
Courtesy Copy Requirements
A party must provide the staff attorney one hard copy when a document, aggregate set of trial exhibits, motion including exhibits, or response or reply brief exceeds 50 pages, and noncompliance may cause delay.
Courtesy Copies: Where a document exceeds 50 pages, the parties shall provide a hard copy to the Court’s staff attorney. This applies to trial exhibits where the total page number for all exhibits exceed 50 pages, and upon filing any motion that exceeds 50 pages in length, including exhibits. The same applies for response and reply briefing. Failure to comply with this order may result in delay.
Page 1 | Motion Practice
Pre-Motion Conference Requirements
Responses to motions in limine are due under Civil Rule 6(c), and reply briefs are not permitted.
Responses due pursuant to Civ. R. 6(c). No replies are permitted.
Page 1 | Trials
Adjournment & Extension Requirements
Counsel and pro se parties seeking a trial continuance must comply with Supreme Rule 41 and Local Rule 17.
Trial Continuances. Counsel and pro se parties shall follow Sup. R. 41 and Local Rule 17 regarding continuance of trial.
Page 1 | Trials
A party seeking an extension or continuance should file a motion identifying whether it is joint, unopposed, or opposed.
In the event that a party or all parties wish to extend a deadline or continue a hearing, court conference, or trial, the party or parties should file a motion that states whether the motion is joint, unopposed, or opposed.
Page 1 | Calendaring and Continuances
Chambers Communication Rules
After a good-faith effort fails, parties should email the Court’s staff attorney a proposed Zoom-conference date and time and a brief description of the dispute, after which the Court may order briefing.
If after a good-faith attempt to resolve the issues a dispute remains, the parties should contact the Court’s staff attorney by email with a suggested date and time for a Zoom conference with the Court, and include a brief description of the issues to be discussed. Thereafter, the Court may order a briefing.
Page 1 | General