Protocol and Practice of Persons Appearing in the Court of Judge Jennifer Ryan-Touhill
Specific Comments or Advice for Litigants
Specific Requirements or Preferences
The judicial system is the mechanism by which our society upholds the law. This system requires respect, courtesy, impartiality, and fairness. While I understand litigation is an adversarial process, I expect the professionals and litigants participating in this system will show each other and the judicial institution itself the respect and courtesy one would show a friend, family member, or stranger on the street.Everyone involved in the judicial system is important and valued--this includes security officers at entrances to the courthouse, employees at the clerk's office, judge's staff, and everyone else with a role at court. I expect these individuals will receive the same level of respect and courtesy provided to me, the judge. Likewise, I expect the court employees to treat you with respect and courtesy.
Pre-Trial Practice and Management Issues
Motion Practice
Use spellcheck. Your reputation matters.Confirm the case is assigned to this division.
Make sure your form of order matches the content contained in your motion.
When you file a motion you must communicate with the other party/parties to obtain their position in the motion.
Talk. Talk again. Or if talking isn't working. . . write. Narrow the scope of the disputes--I rarely see a situation where parties cannot resolve anything at all and must have the judge decide every issue pending. Be prepared to negotiate--no one will be 100% happy but both parties should feel the outcome is reasonable under the circumstances.
To the extent you have not talked (or written). . . please be prepared to explain to me why you have failed to do so. To the extent you have not responded to the other party's efforts to talk (or write). . . please be prepared to explain to me why you have failed to do so.
Please remember you need at least two lines of text on a signature page, including a form of order.
Discovery or Disclosure Disputes and/or Sanctions
Discovery dispute:If you have a discovery dispute please put it in writing--a quick motion will suffice--and ask this Court to set a virtual hearing for me to address the matter. This way everyone is aware of the dispute and what is alleged to have happened/not happened.
Court expectations for the use of artificial intelligence (AI) in court filings:
Parties and attorneys may use AI tools (such as ChatGPT, Copilot, Gemini, or similar programs) to help prepare pleadings, motions, or other filings.
While these tools may assist in drafting or explaining legal concepts, all parties remain fully responsible for the accuracy and truthfulness of their filings.
AI tools sometimes generate incorrect or “hallucinated” case citations, statutes, or facts that appear genuine but are not. While these citations look real, they are not. Submitting inaccurate or fabricated material may result in denial of relief, sanctions, or other consequences.
To reduce errors (and minimize the risk of sanctions), the Court expects filers using AI to:
Independently and carefully verify every citation and legal authority using official or reliable legal sources. Again, the party using AI is responsible for false citations.
Confirm all facts are true and supported by evidence in the record.
Tell the AI tool to provide only real and verifiable citations with links to the cases when possible.
Remember: AI tools are not lawyers and cannot give legal advice.
The Court supports responsible use of technology, but every filer is accountable for ensuring the accuracy of what is filed. A party who is irresponsible with the use of these tools, or (worse) knowingly submits pleadings with non-existent facts/caselaw, shall be subject to sanctions.
Other Pre-trial Practice Guidelines or Comments
Submit a form of order with your motion and please ensure you send a copy to my Judicial Assistant via email.Read the minute entry. I expect you to follow the orders. They are orders, not suggestions. Having provided this admonition, please understand I do not strive to elevate form over function, but I do believe in the importance of doing your best work.
Trial Practice and Protocol
Joint Pre-Trial Memo and/or Conference; Exhibits and Objections
Please read the Scheduling Order and any minute entry applicable to the hearing(s) or deadline(s). The documents contain comprehensive instructions.Jury Selection
Remote electronic questionnaires are used.The Court conducts a brief group voir dire and then individual voir dire.
Strikes for hardship or cause are a balancing test because preemptory strikes are no longer available.
Trial Practice and Procedure
Speaking objections are not allowed.The Court does not micromanage a party's presentation of evidence. The Court will discuss procedure with the parties prior to trial.
Courtroom Etiquette
My courtroom is a balance of informality and respect.Court is open to the public but this does not mean the public has a right to be heard as they choose. Both verbal and non-verbal communication is unacceptable and I will excuse a person from the courtroom if I believe they fail to show the judicial institution the respect it deserves.