Chambers Practices of
The Honorable Christopher F. Droney
United States District Judge

PRETRIAL PREFERENCES

Oral Argument on Motions
Judge Droney holds hearings on dispositive motions on Fridays, beginning at 10:OO a.m. He initiates the scheduling of oral argument when he believes it will be helpful. If counsel requests oral argument, he usually grants it, especially when requested with a reasonable explanation for its need.

Referral to Magistrate Judges/Special Masters
Magistrate Judge Smith is paired with Judge Droney. Judge Droney refers most discovery issues to Magistrate Judge Smith.

Rulings from the Bench
Judge Droney does not rule from the bench following argument on dispositive motions, but customarily rules from the bench on discovery motions.

26(f) Reports
Judge Droney finds that the 26(f) Report is very helpful and has been working well, particularly with its new, more detailed form. He encourages the inclusion of detail because it causes lawyers to discuss the issues in a case. He suggests, in particular, that more emphasis be given to issues not in dispute and to the identification of factual disputes that will be the subject of discovery.

Resolution by Conference Call
Judge Droney uses conference calls to resolve issues that arise during a case and for preparation of Rule 26(f) Reports. He rarely holds oral argument by telephone.

Sur-reply Briefs
Judge Droney generally allows sur-reply briefs, but will look at any objection filed by the other side before granting permission.

Letter Briefs
Judge Droney does not encourage letter briefs, but permits them to bring to his attention newly decided cases while a motion is pending.

Chambers' Copies
The Judge requires chamber's copies of any court filing, either electronically or by hard copy, in excess of 10 pages.

Motions for Extension of Time
Judge Droney usually grants reasonable requests for extensions of time if they do not materially affect the 26(f) schedule.

Motions for Reconsideration
Judge Droney generally grants motions for reconsideration only upon a showing of newly discovered law or facts.

Special Proceedings
Judge Droney will issue a show cause order for preliminary injunctions and requires each party to submit proposed findings of fact and conclusions of law before the hearing. Prejudgment Remedies are customarily referred to Magistrate Judge Smith.

Joint Trial Memoranda
Judge Droney has his own form for both jury and court trials.

Lawyer Affidavits
Judge Droney discourages the submission of affidavits by counsel. He prefers an affidavit from a party or other witness if an issue is appropriate for submission by affidavit.

Dispositive Motions
Judge Droney does not require pre-filing conferences. He believes that there has been an increase in the number of dispositive motions because of the nature of the cases filed in federal court. In employment cases, for example, many summary judgment motions and motions to dismiss are being filed. He believes that most of these motions have merit and need to be considered by the court.

Judge Droney has adopted the practice of issuing endorsement orders denying certain motions for summary judgment and motions to dismiss. In his view, there is no need to write a long decision once he has determined that there are genuine issues of material fact that preclude the entry of summary judgment. He does not want these orders to be viewed as an indication that he has not given serious thought to the motion. In fact, he has given serious consideration to the motions and believes that a written decision, which takes time, will not inform the parties but instead will delay decisions on the large number of pending dispositive motions.

Discovery
Judge Droney deals with specific discovery disputes himself and refers matters that may require ongoing supervision to Magistrate Judge Smith. Judge Droney reminds lawyers that the court does not have discovery materials in the file, so it is important to comply with the Local Rules to be sure the court has all the information necessary to rule on a discovery issue.

Settlement
Judge Droney uses three resources to refer cases for settlement conferences: Magistrate Judge Smith; the special masters panel (only for employment matters to this point); and three para-judicial officers, to whom cases are referred generally on the basis of their areas of expertise. Judge Droney rarely conducts settlement conferences himself.

TRIAL PREFERENCES

Hours of Day for Trial
Trials are scheduled from 10:OO a.m. to 5:00 p.m., lunch is from 1:00 p.m. to 2:00 p.m., and meetings with trial counsel, as necessary, are at 9:30 a.m.

Days of Week for Trial
Trials are held Monday through Thursday (and Fridays if necessary because of the particular circumstances of the case).

Time Limitations for Trial
Judge Droney has not imposed limitations regarding counsels' presentations. At the final pretrial conference, which usually occurs three weeks before trial, he reviews with counsel their trial estimates. He believes that it is important to give prospective jurors an accurate estimate as to the length of the trial, and he therefore expects the time estimates of counsel to be reasonable and reasonably accurate. If it appears that the time may be exceeded, he may impose time limitations.

Opening Statements
Although Judge Droney questions the effectiveness of opening statements, he has allowed them.

Closing Arguments
Judge Droney usually grants each party one hour to make a final argument. The plaintiff typically reserves fifteen minutes for rebuttal. He informs the jury about the length of each closing statement.

Demonstrative Exhibits
If the parties agree that certain demonstrative exhibits can be admitted as full exhibits and given to the jury, Judge Droney usually accepts that agreement. If there is no agreement, the exhibits should be marked for identification only and not given to the jury. If counsel expect that there will be an objection to any exhibit, they should confer prior to trial and, if necessary, bring the dispute to the judge's attention before the seating of the jury. Unless there is an objection, exhibits may be used during the opening statement.

Moving Exhibits into Evidence
Judge Droney attempts to resolve disputes about exhibits during the pretrial conference. As a part of the process, the exhibits are pre-marked for use at trial. The judge may defer rulings of particular exhibits until the time of trial. During the trial, the pre-marked exhibits must be individually moved into evidence, even if there is no objection as to admissibility.

Procedural Motions and Arguments
At the pretrial conference, Judge Droney stresses the obligations of counsel to use the jury's time efficiently. He directs counsel to raise procedural issues and arguments with him before or after the trial day or during breaks. He understands that unexpected disputes may arise, hut he expects them to be kept to a minimum.

Objections
Judge Droney does not want arguments in front of the jury The objecting party should stand to be recognized and then concisely indicate the nature of the objections (e.g. "relevance," "hearsay," etc.). The objector does not need to recite the rule. The opposing counsel will then be asked to respond.

Jury Profiles
Jury selection typically occurs on a Wednesday. The preceding Monday, Judge Droney will instruct the jury clerk to assemble an array of fifty, seventy, or one hundred venirepersons. On Tuesday afternoon, the profiles of those potential jurors are available for inspection.

Jury Selection
During the introductions, all counsel will be expected to identify the other members of their firms. If they practice with a large firm, they may present a written list of the other members of the firm. The judge will ask the voir dire questions submitted by counsel. Thereafter, he will invite counsel to submit additional questions directed either to individual venirepersons or to the whole panel. The "wheel" has been replaced with a computer-generated random list of potential jurors. Judge Droney uses the strike method of jury selection.

Participation of Alternates
In a civil case, all remaining jurors participate in the deliberations. There are no distinctions between the jurors and the alternates.

Juror Notebook
Judge Droney typically does not permit counsel to provide individual juror notebooks.

Juror Notes
Judge Droney typically does not permit jurors to take notes.

Jury Charge
One copy of the charge is provided to the jurors when they commence their deliberations.

Post-verdict Communications with Jurors
Judge Droney has not been asked, pursuant to Local Rule 12(e), for permission to communicate with jurors, and he would be quite reluctant to grant such a request.

Motions in limine
Judge Droney encourages counsel to anticipate evidentiary and other legal issues and to raise them in motions in limine. He will consider these issues during the pretrial conference or at an assigned hearing, and he will generally issue written rulings on the motions.

Technology
Judge Droney presides in the North Courtroom which is the Electronic Courtroom in Hartford in which all equipment necessary for the electronic presentation of evidence is available. Attorneys need only bring their own laptops. Training on the equipment is available through Steve Watkins, a member of the Systems Department. Contact Steve Watkins directly at 860-240-3769 to coordinate the scheduling of such training.

Position of Counsel During Examination
Counsel are not restricted to the podium; with permission of the court, they may approach the witness or the jury, as long as they do not do so in an intimidating or invasive manner.

Miscellaneous
At the pretrial, Judge Droney will ask counsel about their efforts to settle the matter. If requested, he will become involved with further settlement discussions or he will refer the matter to the magistrate judge, otherwise, he will assume the matter is proceeding to trial.