Chambers Practices of
The Honorable Janet C. Hall
United States District Judge

PRETRIAL PREFERENCES

Oral Argument on Motions
Judge Hall will hear oral argument on dispositive motions if she has questions for counsel. She will not conduct such argument by telephone. She does not have a motion day, but hears oral arguments as her schedule permits. A request for oral argument does not affect the timing of decisions.

Referral to Magistrate Judges/Special Masters
Magistrate Judge Fitzsimmons is paired with Judge Hall. Judge Hall does not refer dispositive motions, but does refer settlement conferences. She also refers some discovery disputes, although she likes to resolve those herself when time permits.

Rulings from the Bench
Judge Hall will occasionally rule from the bench.

26(f) Reports
Rule 26(f) Reports must include actual deadline dates; deadlines tied to previous events are not acceptable.

Resolution by Conference Call
Judge Hall encourages counsel to contact her chambers when discovery disputes arise. Typically she requests short letters explaining the nature of the dispute (this is an exception to her disapproval of letter briefs) and then schedules a telephone conference to attempt to resolve the dispute short of a formal motion. She will not conduct argument on dispositive motions by telephone.

Sur-reply Briefs
Judge Hall observes that the Local Rules contemplate a brief in support of a motion, a responsive brief, and a reply brief. She expects that any subsequent briefing will be accompanied by a motion for permission to file. She is skeptical of the need for such additional briefing, particularly in light of her use of oral argument.

Letter Briefs
Judge Hall does not favor letter briefs. She prefers that formal motions be filed. If a lawyer wants to call the court's attention to new authority, the appropriate procedure is to file a notice of supplemental authority with the clerk. In circumstances where counsel has a legitimate need for immediate attention to a motion, the motion should be filed with the clerk, with a copy to chambers accompanied by a brief cover letter explaining the need for immediate attention. However, Judge Hall may request short letters explaining the nature of discovery disputes.

Chambers' Copies
Unless otherwise ordered, on the business day next following the day on which a document is filed electronically, counsel must provide Chambers with one paper copy of the following
e-filed documents, including briefs and exhibits, relating to the following:

a. Applications for temporary restraining orders, preliminary injunctions or prejudgment     remedies;
b. Dispositive motions (motions to dismiss, motion for judgment on the pleadings, or for     summary judgment);
c. Requested jury instructions;
d. Compliance with Pretrial Orders
e. Trial briefs, including proposed findings of fact and conclusions of law; and
f.  Any other motion, request or application which, taking it together with all related filings    (e.g., memo in support, affidavits) are in excess of 20 pages.

Motions for Extension of Time
Judge Hall has no specific procedures concerning motions to extend time, but such motions should be filed with the clerk in the usual fashion. Requests for an extension of time made by telephone are never granted. If counsel require an expedited decision on a motion to extend time, they must supply Judge Hall's chambers with a courtesy copy of the motion and a cover letter explaining the need for a quick decision.

Motions for Reconsideration
Judge Hall expects that counsel will comply with Local Rule (7)(c).

Special Proceedings
Judge Hall finds that an application for an order to show cause, and proposed order, are helpful for motions for preliminary injunction and temporary restraining orders. She urges counsel to make it clear in their findings whether they want ex parte relief, an immediate hearing, or some other action by the court.

Joint Trial Memoranda
Judge Hall generally places a case on a trial-ready call of calendar after the dispositive motion deadline passes or a ruling is issued on a dispositive motion. At the call of that calendar, she sets final deadlines and makes referrals for settlement conferences, among other actions. Judge Hall issues a final pretrial order, with the 26(f) order, which is similar but not identical to that required by the standing order. She requires that any motions in limine be filed with the pretrial memorandum. Counsel are specifically required to attempt to enter into (and include in the pretrial memorandum) a written stipulation of uncontroversial facts and an agreed statement of the contested issues of fact and law. Proposed findings and conclusions (in court cases) and proposed instructions (in jury cases) must be submitted on diskette in Wordperfect 6.1 format. Judge Hall's order sets a date for a pretrial conference. She requires counsel to mark exhibits numerically, to exchange copies no later than seven calendar days before filing the pre-trial memoranda, and to submit the originals and one set of copies to the deputy clerk three calendar days before the pretrial conference. Objections to the admissibility of exhibits (other than relevance objections) must be filed with the court at least seven days before the pretrial conference.

Lawyer Affidavits
Lawyer affidavits are not necessary to identify documentary exhibits and deposition transcripts submitted in connection with dispositive motions.

Dispositive Motions
Judge Hall currently has no individualized rules or procedures concerning dispositive motions. Pre-filing conferences are not required for summary judgment motions, but are for Rule 12(b)(6) motions.

Discovery
See "Resolution by Conference Call" section. Judge Hall refers some discovery disputes to Magistrate Judge Fitzsimmons, but she will resolve them herself when time permits.

Settlement
Judge Hall generally refers settlement conferences to Magistrate Judge Fitzsimmons, the special masters panel, and Para Judiciary Officers.

TRIAL PREFERENCES

Hours of Day for Trial
Typical trial hours are 9:15 a.m. to 3:30 p.m., with a forty-five-minute lunch break and a fifteen minute break in the morning.

Days of Week for Trial
Trials are held five days a week. For certain long cases, Judge Hall may have longer trial days (i.e. 9:00 to 5:00) four days a week.

Time Limitations for Trial
Judge Hall typically does not impose time limitations. She works with the attorneys to develop a reasonable estimate for the time required for a trial and schedules the trial accordingly.

Time Limitations for Individual Examinations of Witnesses
Judge Hall generally does not limit individual examinations of witnesses.

Opening Statements
Judge Hall permits opening statements in civil cases. They may not be argumentative and must be limited to what the evidence will show. They are typically required to be very short (i.e. five minutes or less). In criminal cases, Judge Hall only permits opening arguments if both sides agree.

Closing Arguments
Judge Hall generally allows closing statements of thirty minutes, with some additional time for very complicated cases or cases with multiple parties.

Demonstrative Exhibits
Parties must disclose demonstrative evidence before it is presented in the courtroom so that objections may be dealt with in advance. Demonstrative evidence may not be used during closing argument unless it has been marked as an exhibit or has been shared with the other parties at least one day before closing.

Moving Exhibits into Evidence
Pursuant to Judge Hall's standing Pretrial Order, proposed exhibits are to be pre-marked and exchanged at least seven days prior to the pretrial compliance, with objections to be included in the pretrial compliance. Memoranda addressing evidentiary issues are to be filed at least three days prior to the pretrial conference. Objections not made in this manner will likely be deemed waived absent a showing of excusable neglect or extreme prejudice. Exhibits are to be pre-marked and provided to the deputy clerk.

Pre-marking of Exhibits
See "Moving Exhibits into Evidence" section.

Procedural Motions and Arguments
Judge Hall's Pretrial Order requires in limine motions to be filed in conjunction with the final pretrial memorandum. Because of this, she deals with many of these motions at the pretrial. Judge Hall has revised her pretrial order to clarify that Daubert motions must also be made no later than the dispositive motion deadline, and that failure to comply will result in waiver of such motions.

Other procedural motions and arguments that come up prior to or during trial are argued before the commencement of the trial day or during breaks. Judge Hall rarely permits sidebars and does not excuse the jury to entertain motions or objections.

Objections
Judge Hall requires short objections citing a supporting rule or brief ground for the objection. She generally does not take argument.

Jury Profiles
Under the recently revised system, attorneys receive basic information about jurors the day before trial.

Jury Selection
Judge Hall uses the strike method in civil cases. The computer randomly selects the order of jurors to be chosen for questioning. Judge Hall calls the number of jurors required for a complete panel in the case plus the number of jurors to be stricken. Those people are seated in the jury box and she questions them generally. She then asks case-specific questions that have been requested by the attorneys. Then each venireperson is asked a few individual questions about himself or herself. If one of the attorneys request individual follow-up with any venireperson, that person is questioned further at sidebar and attorneys may ask additional questions if necessary. At this point, each party exercises any desired strikes (alternating parties).

In very complicated or lengthy trials, there may be a modified strike system where the entire pool for the day is pre-screened simultaneously on issues such as hardship (e.g. the length/dates of the trial), or their knowledge of parties or issues in the case.

Judge Hall generally requires attorneys to identify all attorneys in a local office only (e.g. for a large firm, the Stamford office, but not all offices).

Jurors in a Civil Case
In a trial anticipated to take a week or less, eight jurors are typically selected. For longer cases, ten to twelve may be selected. All jurors deliberate in civil cases. In criminal cases, Judge Hall has never been asked to permit alternates to deliberate.

Juror Notebooks
Attorneys who want to provide exhibits to the jurors in "juror notebooks" are permitted to do so.

Juror Notes
The court permits note taking by jurors and supplies notebooks for juror use.

Juror Charge
Judge Hall's standing pretrial order requires proposed charges to be submitted. She prepares a draft of her charge, provides it to counsel prior to the trial, and holds a charge conference a day or two before the charge is given.

Post-verdict Communications with Jurors
Judge Hall does not permit lawyers to communicate with jurors, but she routinely speaks with jurors after the trial is over.

Motions in Lirnine
See "Procedural Motions and Arguments" section.

Technology
Judge Hall allows attorneys to use technology-enhanced evidence, provided demonstrative and other exhibits are exchanged in advance as required in her pretrial order. Her courtroom is an "e-Courtroom," in which aIl equipment necessary for the electronic presentation of evidence is in place; attorneys will only need to bring a laptop.

Counsel Placement in Court
Attorneys are typically required to stand at a podium while questioning witnesses, though they are permitted to approach the witness as necessary.

Miscellaneous
Judge Hall expects re-direct examination to be brief and limited to new issues arising out of cross examination. She rarely allows re-cross examination.

Judge Hall stressed that she always prefers to deal with issues in advance of and outside the scope of the trial day. She encourages attorneys to raise issues requiring her attention as far in advance as possible so that they can be dealt with at the beginning or end of the trial day or during a break.