Preference for the use of telephone conferences rather than in-person conferences for any category of conferences scheduled in connection with a case.
Judge Rambo prefers conferences by telephone except pre-trial conferences and settlement conferences.

Courtesy copies of motions, briefs, and other writings for chambers.
Local rules require filing of an original and two copies of motions and briefs–the copies automatically are sent to chambers by the Clerk's Office. Judge Rambo does not wish to be copied on letters between counsel.

Federal Rule 26 and M.D. Pa. Local Rule 26.1 et seq. (including your approach to initial disclosures, discovery prior to the Rule 16 conference) and preferences as to the matters encompassed within those Rules.
Judge Rambo prefers that discovery commence before the Rule 16 conference. Judge Rambo directs that counsel not file discovery motions unless conflicts cannot be resolved by telephone conference.

The extent to which counsel may influence the length of the discovery period, extensions, trial dates, etc.
Judge Rambo discourages alterations of the case management order and does not allow them without good cause shown.

The average amount of time allowed for discovery in a standard track case and the extent to which the standard amount of time is varied.
Judge Rambo typically allows six to eight months from the filing of the complaint.

Procedure for scheduling trials, including whether a date certain for trial is assigned; if so, the amount of time prior to trial that such a date certain is assigned; and the extent to which it may be moved during the month in which it has been scheduled.
Judge Rambo determines dates for trials at the pre-trial conference unless trial will involve a large number of counsel, will involve experts, and is to be over a week in length. In such a case, Judge Rambo will make prior arrangements by request. Once set, Judge Rambo does not change trial dates.

Trial briefs submitted by counsel.
Judge Rambo prefers to receive trial briefs at least two business days before the trial is to begin.

Counsel participation in voir dire.
In criminal cases, Judge Rambo conducts the voir dire but allows written submissions of proposed questions. In civil cases, Judge Rambo allows counsel to conduct voir dire based on questions submitted to and approved by her. Counsel submit proposed voir dire questions as part of pretrial memoranda.

Whether more than one attorney may handle trial for a party.
Judge Rambo permits more than one attorney to handle trial for a party.

Pre-marking of documentary and photographic exhibits and other demonstrative evidence for trial and the date upon which exchange of exhibits is to take place, if any.
Judge Rambo requires pre-marking of exhibits at the meeting of counsel preceding the pre-trial conference, as required by the local rules.

Practice for the receipt of proposed jury instructions, including the form of jury instruction, and any divergence from the number of jury instructions permitted by the Middle District local rules.
Judge Rambo requires submission of proposed jury instructions as part of pretrial memoranda. Judge Rambo does not require submission of standard instructions; i.e., burden of proof, credibility, etc. She prefers points on the substantive law. Judge Rambo will not permit a party to file more proposed instructions than the local rules permit, except in a complex case and with leave of court.

Written verdict forms (in the form of interrogatory questions) to the jury.
Judge Rambo routinely submits verdict forms. She will accept counsels' proposed verdict forms but will usually alter them.

General approach to settlement and non-jury cases and use of magistrate judges.
In non-jury cases, Judge Rambo refers settlement discussions to the magistrate judge. She tries to encourage mediation. In jury cases, either Judge Rambo or the magistrate judge will conduct settlement discussions.

PLEASE NOTE: These Preferences are courtesy of the Pennsylvania Bar Institute's Middle District Manual (4^th ed., April 2001). More complete Preferences for each Middle District Judicial Officer are contained in the Middle District Manual. For more information on purchasing the Manual, visit the PBI's home page.

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