Protocol and Practice of Persons Appearing in the Court of Judge Todd Lang

Pre-Trial Practice and Management Issues

Discovery or Disclosure Disputes and/or Sanctions

Discovery Disputes or Motions for Sanctions.  
 
Parties shall not contact the Court concerning a discovery dispute or motion for sanctions without first seeking to resolve the matter through personal in-person consultation and sincere effort.  

Other Pre-trial Practice Guidelines or Comments

Motions  
 
Please let the Court know if you did not get a ruling on a motion you filed either by addressing it in open court or by contacting the Judicial Assistant. The paper filing system is not perfect, and sometimes motions are not delivered to the division and there is no way of knowing that a motion was filed if we do not receive it. The Court welcomes a call to the Judicial Assistant to ask why you have not yet received a ruling.  
 
Expedited or Emergency Review  
 
If you are filing a motion which is time sensitive or truly requires emergency or expedited consideration, you must include the phrase "expedited consideration requested" to the right of the caption, and you must state in the motion the basis for your request for expedited relief. Please do not request expedited relief unless there is a genuine need for an expedited ruling. Because the response deadline for electronic services is already short (five days) there are times Judge Lang will simply wait five court days and rule on the sixth day. The course of action is dependent on the nature of the motion and the requested relief.  
 
Please be specific in your proposed orders by specifically stating the exact title of the motion being ruled upon. Do not attach mailing certificates to proposed orders as we do not distribute orders in the same manner that you serve motions.  

Trial Practice and Protocol

Trial Practice and Procedure

 
Judge Lang expects counsel to try to stipulate to non-contested issues. He would appreciate citations to authorities if they are being relied upon in oral argument.