Judge Andrew H. Dowling
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Case Dispositive Motion, Brief
Motion in Limine
Opposition
- Upon Filing
Praecipe
- Immediately Upon Filing
Communication
Chambers
Clerk
Phone
Court-widePhone
Court-widePhone
Court-wideDocument Format Requirements3 rules
When including any Order, DO NOT put “proposed” Order so, if appropriate, the Court can sign the Order submitted.
- Proposed order
Formatting
- •Do not label an included order as "proposed"
Motions for Rule Absolute – preferred format attached as Exhibit 2.
If applicable, also attach Rule to Show Cause. (Preferred format attached as Exhibit 1.)
- Rule to show cause
Formatting
- •Preferred format attached as Exhibit 1
Document Filing Requirements10 rules
A Certificate of Readiness stating whether oral argument is requested must be filed before a dispositive motion is assigned for disposition.
Court's wording
6. A Certificate of Readiness must be filed for the Dispositive Motion to be assigned to the Court for disposition. The Certificate of Readiness must include if Oral Argument is requested or is not requested.
Pre-trial memoranda must name all witnesses, attach all expert reports, and identify agreed and desired stipulations.
Court's wording
In addition to the requirements of L.R. 212.2, Pre-Trial Memoranda shall contain the ===== PAGE 2 ===== names of all witnesses, attach copies of all Expert Reports and indicate Stipulations agreed and Stipulations desired.
Include e-mail for each attorney or pro se litigant.
List/reference lead attorney and party represented.
Bring to conference Points for Charge and proposed Verdict Form.
State concurrence/non-concurrence.
Attach Order on relief sought.
The matter will not be received by the assigned Judge until/unless a party files a Certificate of Readiness.
If Motion references a prior Order and/or seeks modification of a prior Order, ATTACH THE PRIOR ORDER.
If applicable, also attach Rule to Show Cause.
Filing & Service rules
Service and Proof of Service Rules
Counsel for the moving party must serve the rule to show cause on all parties, and the rule is returnable the stated number of days after service.
RULE RETURNABLE _____ days after service. It shall be the obligation of counsel for (moving party) to provide service of this Rule upon all parties.
Civil cases
Page 1 | RULE TO SHOW CAUSE
A Motion to Make Rule Absolute must include evidence demonstrating compliance with applicable service requirements.
A Motion to Make Rule Absolute shall include evidence of compliance of the service requirements of the applicable Pennsylvania Rules of Civil Procedure.
Civil cases
Page 1 | RULE TO SHOW CAUSE
Courtesy Copy Requirements
A courtesy copy of dispositive motions filed with briefs must be served on Judge Dowling’s Chambers.
4. Dispositive Motions with Briefs shall be filed by ___________. A courtesy copy shall be served on Judge Dowling’s Chambers.
Civil cases
Page 1 | CASE MANAGEMENT ORDER
A courtesy copy of briefs responding to motions in limine must be served on Judge Dowling’s Chambers.
9. Briefs in Response to Motions in Limine to be filed by ___________. A courtesy copy shall be served on Judge Dowling’s Chambers.
Civil cases
Page 1 | CASE MANAGEMENT ORDER
A courtesy copy of motions in limine filed with briefs must be served on Judge Dowling’s Chambers.
8. Motions in Limine with Briefs shall be filed by ___________. A courtesy copy shall be served on Judge Dowling’s Chambers.
Civil cases
Page 1 | CASE MANAGEMENT ORDER
A courtesy copy of briefs responding to dispositive motions must be served on Judge Dowling’s Chambers.
5. Briefs in Response to Dispositive Motions shall be filed by ___________. A courtesy copy shall be served on Judge Dowling’s Chambers.
Civil cases
Page 1 | CASE MANAGEMENT ORDER
A courtesy copy of each pre-trial memorandum must be served on Judge Dowling’s Chambers.
10. Pre-Trial Memoranda to be filed by ___________. A courtesy copy shall be served on Judge Dowling’s Chambers.
Civil cases
Page 1 | CASE MANAGEMENT ORDER
A courtesy copy of any praecipe must be provided to chambers immediately upon filing.
Provide Chambers with a courtesy copy of any Praecipes immediately upon filing (e.g.: Praecipe to Discontinue the case; Praecipe to Withdraw a Motion).
Page 1 | Praecipe to Discontinue; Praecipe to Withdraw Motion; etc.
Adjournment & Extension Requirements
A party may request an extension or modification of scheduling or trial deadlines for good cause or by agreement of the parties.
Extension or modification of the foregoing deadlines, including the date for trial, may be granted upon Motion by a party for good cause shown or agreement of the parties.
Civil cases
Page 2 | CASE MANAGEMENT ORDER
A continuance request should be made immediately upon receipt of the scheduling order rather than at the last minute.
Matters are typically scheduled approximately 4 weeks prior. If a continuance is requested, it should be done immediately upon receipt of the Scheduling Order and NOT at the last minute.
Page 1 | Continuances
Chambers Communication Rules
Plaintiff’s attorney must immediately notify Chambers and Court Administration by email if the case settles.
If the case settles, Plaintiff’s attorney shall immediately inform Chambers (vmihailoff@dauphincounty.gov) and Court Administration (sshaffer@dauphincounty.gov).
Civil cases
Page 2 | CASE MANAGEMENT ORDER
The courtroom clerk crier may be emailed at gsmith@dauphincounty.gov to schedule a pre-trial courtroom and equipment technology viewing.
Schedule a time with the Judge’s Courtroom Clerk Crier, Greg Smith, at gsmith@dauphincounty.gov, to have your technology company view the Courtroom and equipment at some time during the week prior to Trial.
Page 1 | Jury Trials