Judge James L. Robart
Individual Rules, Standing Orders & Policies
- Rules last changed:
Communication
Phone
Chambers
Page & Word Limits1 rule
Parties must comply with the length restrictions specified in Local Rule 7(e). The court may decline to consider arguments presented beyond the specified word count or page limits.
Document Format Requirements2 rules
Trial exhibits must be pre-marked with consecutive numbering (Plaintiff: 1+, Defendant: A-1+)
- Exhibit
Formatting
- •Defendant's exhibits numbered consecutively starting with A-1
Court's wording
All trial exhibits must be pre-marked by counsel. Plaintiff’s exhibits shall be numbered consecutively beginning with number 1. Defendants exhibits shall be numbered consecutively beginning with the number A-1.
Each set of exhibits shall be submitted in a three-ring binder with appropriately numbered tabs.
- Binding
- Three-ring binder
- Exhibit
Formatting
- •With appropriately numbered tabs
Document Filing Requirements20 rules
Judge Robart will deny motions for default judgment that do not provide sufficient information for the court to enter judgment.
Motions for default judgment must separately state principal claim, liquidated damages, pre/post-judgment interest, and attorney’s fees.
- Document
- Default judgment
Must include
- •Attorney fees
- •Liquidated damages
- •Postjudgment interest
- •Principal claim amount
Court's wording
Plaintiffs shall separately state the amounts owing on the principal claim, liquidated damages (if applicable), pre- and postjudgment interest on the principal claim (if applicable), and reasonable attorney’s fees (if applicable).
Plaintiffs shall support a motion for default judgment with a declaration.
- Document
- Default judgment
Must include
- •Declaration
Plaintiffs shall provide a concise explanation of how all amounts were calculated. If the court is not certain about how a particular amount was calculated, the court will not award that amount.
Motions for default judgment seeking liquidated damages must provide evidence of entitlement and amount.
Must include
- •Liquidated damages
Court's wording
If Plaintiffs seek liquidated damages, Plaintiffs shall provide evidence establishing an entitlement to liquidated damages and any other information needed to determine the amount of liquidated damages.
If an interest rate other than that provided by 28 U.S.C. § 1961 applies, Plaintiffs shall state the rate and the reasons for applying it.
Plaintiffs shall comply with Local Rules W.D. Wash. CR 55.
Motions for default judgment must provide evidence establishing the principal claim amount, including contract portions if applicable.
Must include
- •Declaration
- •Principal claim amount
Court's wording
Plaintiffs shall provide evidence establishing the amount of the principal claim. If the claim is based on one or more contracts, the relevant portion(s) of the contract(s) shall be attached to the declaration. If further information is required to determine the amount of the principal claim (e.g., the number of hours worked under an employment contract), Plaintiffs shall provide that information.
Motions for default judgment seeking attorney’s fees must state basis and include counsel’s declaration.
Must include
- •Declaration
- •Attorney fees
- •Attorney fees basis
Court's wording
If Plaintiffs seek attorney’s fees, Plaintiffs must state the basis for attorney’s fees and must include a declaration from Plaintiffs’ counsel establishing the reasonable amount of fees to be awarded.
For prejudgment interest, Plaintiffs shall state the date on which prejudgment interest began to accrue and the basis for selecting that date.
- Document
- Default judgment
Must include
- •Prejudgment interest
The original and one copy of the exhibits/depositions are to be delivered to the In-Court Clerk one day before the start of the trial.
If the exhibit or witness list is revised at any time after it is filed with the court, counsel shall file a revised list with the court.
The plaintiff will normally have six challenges, and the defense will have ten.
Duplicated documents shall not be listed twice on the exhibit list.
Counsel for each side may ask questions of the whole panel, of individual jurors, or both. Each side (not party) is limited to time limits agreed upon with the court in advance.
Once a party has identified an exhibit on the exhibit list or in the pretrial order, any party may use it.
Jurors have high expectations about the lawyers’ ability to operate the evidence presentation devices in the courtroom. Training is strongly encouraged.
Exhibit tags can be obtained from the clerk at the pretrial conference or from the Clerk’s Office.
- Document
- Exhibit
Include
- •Exhibit tags
The jury will consist of twelve members and one or two alternates.
Counsel should also avoid using a peremptory challenge on a juror whose number is so high that he or she will not be reached in any event.
Filing & Service rules
Courtesy Copy Requirements
In general, Judge Robart does not require courtesy copies. However, parties should submit courtesy copies to the Clerk of Court of any documents that exceed 100 pages in length.
In general, Judge Robart does not require courtesy copies. However, parties should submit courtesy copies to the Clerk of Court of any documents that exceed 100 pages in length.
Page 1 | Courtesy Copies
Filing Bundling Requirements
Dispositive motion cutoff is set 105 days before trial.
Judge Robart sets the dispositive motion cutoff 105 days prior to the trial date.
Page 1 | DISPOSITIVE MOTION CUTOFF - 105-DAY RULE
Schedule modification requires extraordinary basis.
Judge Robart will not modify this schedule unless the parties set forth an extraordinary basis for modifying the scheduling order to decrease the period between the dispositive motion cutoff and the trial date to less than 105 days.
Page 1 | DISPOSITIVE MOTION CUTOFF - 105-DAY RULE
30 days for briefing, 45 days for court decision, 30 days for trial prep.
This allows the parties 30 days to brief the motion; the court 45 days to decide the motion; and the parties 30 days after receiving the ruling to prepare for trial, if necessary.
Page 1 | DISPOSITIVE MOTION CUTOFF - 105-DAY RULE
Pre-Motion Conference Requirements
Before filing a motion to seal, the filing party must make a good-faith effort to meet and confer with the party that produced the confidential document.
In order to avoid unnecessary motions to seal, Judge Robart requires that the party filing the motion make a good faith effort to meet and confer with the party that produced the confidential document before filing a motion to seal.
Civil cases
Page 1 | MOTIONS TO SEAL
Judge Robart follows Local Rules W.D. Wash. LCR 7 in scheduling matters for consideration by the court. Counsel and pro se parties should follow the scheduling guidelines specified in Local Rule 7(d). The court may re-note or strike motions that have been improperly noted for consideration, or take other appropriate action.
Judge Robart follows Local Rules W.D. Wash. LCR 7 in scheduling matters for consideration by the court. Counsel and pro se parties should follow the scheduling guidelines specified in Local Rule 7(d). The court may re-note or strike motions that have been improperly noted for consideration, or take other appropriate action.
Page 1 | Scheduling Matters for Consideration
Adjournment & Extension Requirements
Motions to continue trial date only allowed for exceptional circumstances.
Judge Robart will not consider motions or stipulations to continue the trial date absent exceptional circumstances.
Page 1 | MOTIONS TO CONTINUE TRIAL DATE
Chambers Communication Rules
Parties are encouraged to jointly call chambers about discovery disputes, all parties must participate in the call, and counsel may call chambers at (206) 370-8920.
Judge Robart encourages parties to jointly telephone chambers when presented with disputes regarding discovery issues. In general, Judge Robart is available to resolve discovery disputes via telephonic conferences. This approach resolves the dispute in an expedient manner and avoids the extra costs associated with motions practice. All parties to the discovery dispute must participate in making the call to chambers. See Local Rules W.D. Wash. LCR 7(i). Counsel may telephone chambers at (206) 370-8920.
Civil cases
Page 1 | DISCOVERY DISPUTES