BRIEN McMAHON FEDERAL BUILDING United States Courthouse 915 Lafayette Boulevard Bridgeport, Connecticut 06604
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Location: Courtroom 4
To safeguard the rule against ex parte communications, and to further the public’s interest in pending court proceedings, Judge Russell does not review letters sent by a party (whether they be addressed to the Clerk of Court or the judge herself), and instead asks that the Clerk of Court return any such letters to the sender. This policy is designed to avoid ex parte communications, and to ensure proper documentation of filed materials.
Communications to the court should be docketed as a motion for specific relief, or as a notice of specific information. The motion or notice should have a caption that includes the name of the case and the case number, and should comply with the Federal Rules of Civil Procedure and the District of Connecticut Local Rules (particularly Local Rule 7, which addresses several common motions). Only motions or notices that comply with the Rules will be filed on the docket and will be reviewed by the judge.
Judge Russell considers the filing of Rule 26(f) Reports to be critical to the efficient administration of litigation. If a Rule 26(f) Report has not been filed within the time required by the rules, a notice shall be generated by her Courtroom Deputy for failure to comply.
The Rule 26(f) Report should provide the Court with a meaningful overview of the case and should serve as a vehicle for parties to consider: the factual and legal nature and basis for the claims and defenses asserted or to be asserted; the possibilities of settlement; and the desired discovery. Judge Russell independently determines whether a scheduling conference with the Court is necessary, but she will take into account whether the parties have requested a scheduling conference in their Rule 26(f) Report.
Provided counsel are reasonable and efficient in the selection of deadlines for the completion of discovery and the filing of dispositive motions, the Rule 26(f) Report will usually serve as the basis for the initial scheduling order in the case. Generally, Judge Russell prefers that the parties propose a schedule that will allow for the close of all discovery between six to nine months from the date of the filing of the Rule 26(f) Report. If the parties believe that more than nine months is required to complete discovery, then they should explain why additional time is needed. Absent an explanation from the parties why more than nine months is needed, Judge Russell may enter an order to complete discovery at the end of nine months even if the parties have requested additional time. Once a scheduling order is entered, Judge Russell expects parties to follow the schedule and will modify it only upon a showing of good cause.
Rule 26(f) Reports must include actual deadline dates, even if such deadlines are tied to earlier events in a case.
Judge Russell requires that any motions for extension of time be filed strictly in accordance with D. Conn. Local Rule 7(b), which requires that any motion be filed at least three business days in advance of the due date; that it reflect the opposing party’s position on the motion; that it indicate the number of motions for extension of time the movant has previously filed with respect to the same time limitation; and that it establish particularized good cause for the extension request. Counsel should include the specific date to which they seek an extension. Motions for extension of time that do not comply with D. Conn. Local Rule 7(b) may be denied.
Judge Russell may decide discovery disputes herself or may refer them to a U.S. Magistrate Judge.
Even after a discovery dispute has been briefed, Judge Russell expects the parties to continue to attempt to resolve the dispute themselves prior to Court intervention.
Unless otherwise ordered, within three business days after a document is filed electronically by counsel in a civil matter, counsel must provide chambers with two paper copies of the following e-filed documents, including all exhibits and attachments:
Chambers copies may be printed double-sided. All chambers copies should be printed from the docket and should bear the ECF header of the Court’s electronic filing system. All chambers copies must be properly ordered and tabbed. Any chambers copy that cannot be securely stapled must be placed in a three-ring binder.
Chambers copies of brief, routine procedural motions should not be provided to chambers unless requested.
Chambers copies delivered via mail, FedEx, or UPS shall be addressed to: Chambers of The Hon. Sarah F. Russell; United States District Court; 915 Lafayette Boulevard – Suite 266; Bridgeport, Connecticut 06604. Chambers copies that are hand-delivered by a representative of a party shall be delivered to: Hon. Sarah F. Russell, c/o Clerk’s Office, United States District Court; 915 Lafayette Boulevard; Bridgeport, Connecticut 06604.
Judge Russell does not allow letter briefs or sur-reply briefs. In lieu of filing a letter brief, a party should file a formal motion. If a lawyer wants to call the Court’s attention to new authority, the lawyer should file a notice of supplemental authority on the docket.
Judge Russell believes in the value of oral argument and often schedules oral argument on dispositive motions. In deciding whether to hold oral argument, Judge Russell gives strong consideration to whether the parties have requested argument. If Judge Russell concludes that oral argument would not be helpful, then she may rule on a dispositive motion without oral argument.
If a party intends to use a PowerPoint or other exhibits that were not previously filed on the docket during an oral argument, the presentation and/or new exhibits must be shared with opposing counsel at least twenty-four hours in advance of the oral argument. Counsel will generally be prohibited from using any presentation and/or exhibits that are not disclosed by this deadline.
Junior members of legal teams representing clients are invited to argue motions they have helped prepare. Opportunities to train young attorneys in oral advocacy are rare. Where junior lawyers are familiar with the matter under consideration, but have little experience arguing before a court, Judge Russell believes that they should be encouraged to speak. To facilitate this practice, Judge Russell is amenable to permitting a second, senior lawyer to argue as well for one party (if deemed necessary), if this will create an opportunity for a junior lawyer to participate. The ultimate decisions of who speaks on behalf of the client are for the lawyer in charge of the case, not the Court.
Judge Russell encourages the parties to discuss settlement as soon as possible. Nearly all civil cases settle, and, at some point in this case, the Court will refer the parties to a U.S. Magistrate Judge to explore the potential for settlement. The sooner the parties look seriously at the possibility for settlement, the less expensive the litigation will be for the parties. The Court understands that sometimes it is necessary to conduct some discovery before the parties can engage in productive mediation. If this is such a case, the Court encourages the parties to discuss exchanging limited discovery before engaging in a formal settlement conference. But the parties may begin settlement discussions at any time, on their own, through a private mediator, or with the assistance of a U.S. Magistrate Judge.
The parties are advised that the Magistrate Judges may not be able to conduct settlement discussions on short notice. Accordingly, counsel should seek a referral for settlement discussions at the earliest possible date. To do so, counsel for any party may file a brief motion for a referral to a Magistrate Judge, representing that counsel for all parties have conferred and agree that such a referral would be appropriate.
Joint Trial Memorandum Instructions (last updated January 30, 2025)
Jury selections are generally scheduled for the second Tuesday of every month.
Judge Russell’s typical trial day lasts from 9:30 a.m. to 4:00 p.m., with a forty-five-minute lunch break and fifteen-minute breaks in the morning and afternoon. Counsel should report at 9:00 a.m. and also be prepared to stay after the trial day is complete as necessary to deal with objections and procedural matters.
Judge Russell ordinarily conducts trial four or five days a week.
For civil cases, Judge Russell allows short opening statements for each side. For criminal jury cases, any party wishing to give an opening statement may file a motion for permission to do so.
Judge Russell will set time limits for closing arguments in consultation with counsel and in view of the complexities of the case.
Judge Russell encourages counsel to agree in advance of trial which exhibits will be admissible without necessity to lay a foundation at trial and that may be deemed automatically admitted as full exhibits upon tender of each exhibit to a witness at trial.
Parties must disclose demonstrative evidence before it is presented in the courtroom so that objections may be dealt with in advance. Demonstrative evidence may not be used during closing argument unless it has been marked as an exhibit or has been shared with the other parties at least one day before closing.
Judge Russell’s Joint Trial Memorandum Instructions provide directions for provision of exhibits to the Court. Further questions can be answered by the Courtroom Deputy.
Judge Russell’s Joint Trial Memorandum Instructions require the parties to file motions in limine at the time the Joint Trial Memorandum is submitted. Because of this, she deals with many of these motions at pretrial conferences or at oral argument before trial. Nonetheless, should additional issues arise at trial, Judge Russell expects counsel to alert her to potential problem areas in advance whenever possible. She hears argument on such matters before the commencement of the trial day or during breaks.
When in the presence of the jury, a party must state the basis for any objections in as few words as possible (e.g., “Objection, hearsay” or “Objection, foundation”) and without argument or further elaboration unless Judge Russell requests more detail. If counsel requests, Judge Russell will explain the basis for her ruling on an objection at the next break and outside the presence of the jury.
Judge Russell’s Joint Trial Memorandum Instructions require the parties to submit proposed jury instructions at the time the Joint Trial Memorandum is submitted. After the parties meet and confer to narrow the range of disputes and submit a list of the disputed instructions, Judge Russell will address the disputes. She will prepare a draft of the jury instructions, provide it to the parties during the trial, and hold a charge conference a day or two before giving the charge.
Judge Russell does not permit lawyers to communicate with jurors, but she sometimes speaks with jurors after the trial is over.
The parties should familiarize themselves with and test-run in advance of trial the courtroom’s technology system for exhibits. It is usually the case that all exhibits except physical objects are shown to the Court and/or the jury during trial through the Court’s technology rather than in paper form. Counsel are encouraged to contact the Courtroom Deputy to set up a pre-trial run through of the technology or for any other technical assistance.
Counsel intending to use their own laptops for presentation of evidence or other materials should advise the Courtroom Deputy ahead of time. They should also be advised that the courtroom has only HDMI (not mini-HDMI) and VGA video input cables. If a computer cannot accept either of these cables, counsel will need to supply their own cable adaptor.
