Protocol and Practice of Persons Appearing in the Court of Judge Timothy J. Ryan

Specific Comments or Advice for Litigants

Specific Requirements or Preferences

Please check in with my bailiff when you arrive. If you are going to be delayed for any reason it is imperative that you let us know. I greatly appreciate counsel, parties,witnesses and family members of the parties being cordial while in the court room, and being courteous to the court staff.

Pre-Trial Practice and Management Issues

Motion Practice

Motions should provide a concise statement of what you want, and why your position should prevail.  
It is helpful if you include a separate Appendix of applicable case law in support of your position.  
If you intend to provide a Proposed Findings of Fact and Conclusions of Law, you must provide a CD disc in Word format, without your firm's letterhead on the formatted document.  
If oral argument is not requested, I will not set the matter for oral argument. If I can understand what is written in the pleadings, I will rule without oral argument. If I set oral argument, there will usually be some questions I have regarding the facts, or the application of the law to the facts. Oral argument is not an invitation to read your motion to me, it is primarily an opportunity for me to ask you some questions.  

Discovery or Disclosure Disputes and/or Sanctions

Most discovery disputes can be resolved with a telephone call between parties. If such a dispute arises, please call me on the phone and tell me, in five minutes or less, your positions on a given discovery issue, and I will give you my input. If it is immediately apparent that one, some or all of the participants are being outrageous or unecessarily unreasonable, then sanctions will be considered and imposed in the same telephonic conference.  
Pre-Trial Conferences are excellent ways to address discovery and disclosure issues, so feel free to bring up discovery/disclosure issues at any of those conferences.  

Other Pre-trial Practice Guidelines or Comments

ALWAYS treat the people who work in the Court system, no matter the title, with the same courtesy and respect you should expect in return.  
You will be receiving minute entries from your Initial Pretrial Conference, your Comprehensive Pretrial Conference and your Final Trial Management Conference. It is expected that you will comply with the deadlines and orders set forth in those minute entries.  
Continuances will not be granted absent a showing of extraordinary circumstances or other grounds under Rule 8. Firm trials cannot be continued on the eve of trial with an untimely motion, absent truly unforeseen, extraordinary circumstances.  
Given the high number of cancelled settlement conferences, this Division will no longer schedule settlement conferences except those scheduled through Settlement on Demand.  

Trial Practice and Protocol

Trial Schedule

I am available for trial between 10:30 a.m. and 4:30 p.m. I reserve the time between 8 a.m. and 10 a.m. for the morning calendar, which typically begins at 8:30 a.m..

Joint Pre-Trial Memo and/or Conference; Exhibits and Objections

You will receive detailed minute entries, outlining in specific detail, your obligations and responsibilities for trial preparation and attendance. It is in your interest to meet these outlined obligations and responsibilities in order to be effectively prepared for trial. Continuances will not be granted for failure to properly prepare for your day in court.

Jury Selection

The Court will conduct voir dire, and will allow reasonable voir dire by counsel.  

Trial Practice and Procedure

I expect trial lawyers to be ready for trial, and to keep with the anticipated schedule of trial.

Courtroom Etiquette

You do not have to use the podium.  
Please do not stand behind the opposing counsel's table unless you have their permission to do so.  
You need permission to approach a witness on the stand the first time, but you do not need to continue asking to approach the same witness. If an expert has his folder up on the stand with him, please don't remove his folder and start quizzing him about what is in his folder, unless you have cleared it with the Court first. No exceptions.  
I will give you fair latitude to try your case, but that is not an invitation to try and take over the court room.