Protocol and Practice of Persons Appearing in the Court of Judge Janice Crawford
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Specific Comments or Advice for LitigantsSpecific Requirements or Preferences
The Division’s phone number is 602-372-0844. The Division’s Judicial Assistant is Valerie Valenzuela. Her email address is email@example.com. The Division’s Bailiff is Martha Fields. Her email address is firstname.lastname@example.org.
I try to schedule hearings promptly and at a time convenient to the parties. You will likely receive an e-mail from my Judicial Assistant, Valerie, asking if you are available on certain dates and times. Please respond promptly and to all recipients.
If you have a motion or request that needs to be addressed quickly or if you file something shortly before a hearing that needs to be addressed at the hearing, please email a copy directly to my Judicial Assistant and my Bailiff. It can take more than 24 hours for an e-filed document to make it to the Division’s e-file inbox.
Temporary Restraining Orders or Preliminary Injunctions: I do not ordinarily set return hearings on applications for Temporary Restraining Orders or Preliminary Injunctions. Instead, I issue an OSC directly setting the application for an evidentiary hearing. If you file an application for a TRO, please be aware that I may not have the time to read, decide, and have a ruling issued the same day you file the application, especially if it is filed after noon or on a day when I am in trial, so please plan accordingly. Please be sure to support your application in the manner required by the applicable statutes and rules. If you fail to comply with the applicable statutes and rules, your application will be summarily denied.
Pre-Trial Practice and Management IssuesMotion Practice General Motion Practice – If a motion and attached exhibits exceeds 25 pages, please mail or hand-deliver a hard copy of the motion, with an index of the tabbed exhibits, to the Division. All proposed forms or judgment need to be provided in WORD format.
Motions for Summary Judgment- I do not set a limit on the number of motions for summary judgment. However, I will exercise my discretion to set limits if the parties begin filing repetitive or meritless motions. Do not combine a response to a motion for summary judgment with a cross-motion for summary judgment. A cross-motion should be filed as a separate motion for summary judgment in a separate pleading with the issue in the caption. If you are filing more than one motion for summary judgment, or if you are responding to one of multiple motions for summary judgment, include the number in the caption- for example – plaintiff’s motion for summary judgment no. 2 or defendant’s response to plaintiff’s motion for summary judgment no. 2. Statements of fact must be presented in concise, numbered paragraphs, preferably with one fact per paragraph. Each paragraph must include a citation to the evidence supporting the fact. Do not file controverting or supplemental statements of fact with a reply.
Discovery or Disclosure Disputes and/or Sanctions Discovery Issues – No written discovery motion should be filed unless the parties have personally conferred and attempted to resolve the dispute. Written correspondence and email exchanges are not personal consultation. Because the rules require personal consultation, I will not consider any discovery motion that is not accompanied by the required certification.
As an alternative to a formal written discovery motion, if the discovery dispute is relatively straightforward, I will attempt to resolve it in an informal and expedited manner by telephonic conference subject to the following conditions: (1) you must first attempt to resolve and/or narrow the issue through personal consultation, either by phone or in person; (2) you and opposing counsel (or a self-represented litigant) must jointly call my Judicial Assistant to obtain a date and time for the telephonic conference; and (3) you must file a statement of the issue and your position on the issue, including facts and relevant legal authority before the conference. The statement of the issue and your position on the issue should not be more than 3-4 paragraphs. You may include exhibits. If a written discovery request is involved, you should include the written discovery request and the response as an exhibit. The total filing should not exceed more than ten pages, including any exhibits. If, after review of your materials, I find that the issue raised is not appropriate for the informal expedited process, I will have my Judicial Assistant notify you and you will have to proceed by formal motion.
Other Pre-trial Practice Guidelines or Comments Oral Argument – I do not routinely schedule oral argument unless I think it will be helpful. I set time limits for oral argument and hold the parties to those limits. I read all filings before oral argument and it is not helpful to me if you simply repeat what is in your filings.
Trial Practice and ProtocolTrial Schedule I rely on your time estimates for trial. Ordinarily, I will divide the total time requested equally. Absent prior arrangement with the court, each party is responsible for keeping track of their own time.
Trials are generally held Monday through Thursday between 9:30 a.m. and 4:30 p.m. Lunch is from noon until 1:30 with a mid-morning and mid-afternoon break.
It is important to our Division that jurors not needlessly wait for us to resolve legal issues that could have been resolved before the jurors arrive for the day or return from lunch. Thus, I will require trial counsel to arrive fifteen minutes prior to the morning and afternoon start of trial each day. If there is an issue that you believe will take longer than fifteen minutes to resolve, please let me know in advance.
Joint Pre-Trial Memo and/or Conference; Exhibits and Objections Exhibits - I will set a deadline for submitting exhibits when I set trial. It takes time for my clerk to mark each exhibit and enter it in the computer. If you do not submit your exhibits timely, the exhibits may not be marked. The exhibits you provide will be consecutively marked. Once marked, you cannot swap out or change an exhibit. You cannot create placeholders for exhibits.
Motions in Limine – Motions in limine and responses thereto should not exceed three pages. No reply is permitted. Each motion in limine should address only one topic and should be numbered as described for motions for summary judgment.
I encourage attorneys to meet and stipulate to the admission of as many exhibits as possible.
Jury Instructions – Counsel must provide proposed jury instructions in WORD format with the joint pretrial statement. I will put together my draft based on my review. My Judicial Assistant, Valerie, will send my draft to all counsel. We will discuss any revisions early in the process so as not to delay trial. The only jury instructions that I will leave to the end of the trial are those instructions that depend on the evidence that is introduced during trial. If a RAJI calls for case specific changes, the parties must provide the proposed language.
Jury Selection You should submit a stipulated short summary of the case prior to trial that I will read to the jury at the beginning of jury selection. Counsel can submit written questions for voir dire with the joint pretrial statement, which I may ask in addition to standard voir dire questions. I initially voir dire the entire panel and then allow the attorneys some time to question the jury. Absent unusual circumstances, I do not use jury questionnaires. I encourage you to agree to allow alternate jurors to deliberate.