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Protocol and Practice of Persons Appearing in the Court of Judge Timothy J. Ryan << return to previous page
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.  
Resolution Management Conferences and 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 Respect and the Courtesy you expect in return.  
Family Court cases are very important, affecting the lives of tens of thousands in Maricopa County each year.  
Temporary Orders are sensitive matters, often filed without notice to the opposing party. It is important to be very specific. It is important to include all information. Omissions of material fact is not a good idea, remember, in Family Court, I am the Finder of Fact as well as the Judge.  
Continuances are generally denied. The Family Court calendar is very congested, with some people waiting months for their day in court. When I set court dates, I try to check with counsel and the parties to make sure that the selected date is realistic. If a party waits until the last minute to retain counsel, I usually do not find that to be a reason for a continuance.  
Trial Practice and Protocol Trial Schedule I am available for trial between 9 a.m. and 5 p.m. I reserve the time between 8 a.m. and 9 a.m. for resolution management conferences. Joint Pre-Trial Memo and/or Conference; Exhibits and Objections You will get a detailed minute entry, outlining in specific detail, your obligations and responsibilities for trial preparation and attendance. It is in your interest 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 There is no voir dire in Family Court. Trial Practice and Procedure Trial notebooks are not useful in the manner presented by most attorneys. They are often too big, and contain hundreds of pages of documents, when I only need to look at a dozen or so exhibits.  
More often than not, they do not match up with the clerk's exhibit numbers. Most attorneys breeze through their presentation without showing me a single admitted exhibit. Remember, the Judge is the Trier of Fact in Family Court. If you want to hand me a copy of the exhibit as you have it introduced into evidence, that would be helpful.
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