Instructions for Self-Selecting Hearing Dates; Communicating with Judge Baisier's Chambers; Content of Motions to Approve Loan Modification and Related Orders; Content of Stay Relief Motions; Content of Motions to Avoid Liens; Service Requirements of Motions to Extend or Impose Stay; Checklist for B

Hon. Paul M. Baisier · U.S. Bankruptcy Court for the Northern District of Georgia

Role: Bankruptcy Judge

Bluebook Citation: Hon. Paul M. Baisier, Instructions for Self-Selecting Hearing Dates; Communicating with Judge Baisier's Chambers; Content of Motions to Approve Loan Modification and Related Orders; Content of Stay Relief Motions; Content of Motions to Avoid Liens; Service Requirements of Motions to Extend or Impose Stay; Checklist for B, U.S. Bankruptcy Court for the Northern District of Georgia

Judge Profile: Hon. Paul M. Baisier profile and standing orders


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=== Instructions for Self-Selecting Hearing Dates ===

INSTRUCTIONS FOR SELF-SELECTING HEARING DATES (Effective November 14, 2025) Set forth below are instructions for self-selecting hearing dates and times for most motions, applications and objections (referred to generically below as a “motion”) in cases assigned to Judge Baisier. 1. Selecting a Hearing Date. a. General Rule. The party filing a motion must choose a hearing date pursuant to these Instructions. b. Exclusions. DO NOT use these Instructions for: i. Matters that will take more than twenty (20) minutes to hear, matters that require more than one (1) witness, matters in adversary proceedings, or emergency matters, all of which will need to be specially set by Chambers (See Item 1(c) below); OR ii. Any of the following types of matters: • Certain stay relief motions (see Item 1(f) below); • Motions to avoid liens or to redeem property (see Item 1(g) below); • Reaffirmation matters (see Item 5 below); • Applications to employ professionals in Chapter 7 or 13 cases (filer should upload proposed order; forms of order are available under “Forms” on the Chambers’ webpage); • Motion for an examination under Federal Rule of Bankruptcy Procedure (FRBP) 2004; (filer should upload proposed order; form of order is available under “Forms” on the Chambers’ webpage); • Motion to extend time to file schedules or statement of affairs or to pay filing fee (filer should upload proposed order); • Motion for emergency ex-parte relief from the stay pursuant to Bankruptcy Local Rule (BLR) 4001-1, provided that the debtor or trustee may use these Instructions to set a hearing pursuant to an order granting such a motion (filer should upload proposed order); • Motion to vacate or terminate employer deduction order (filer should upload proposed order); • Motion in Chapter 11 cases to set bar date to file proofs of claim (filer should upload proposed order; order form is available under both “Chapter 11 Matters” and “Forms” on the Chambers’ webpage); and • Matters on which all the necessary parties have agreed to a proposed is uploaded the proposed consent order consent order, contemporaneously with the filing of the motion. if c. Special Setting. i. E-mail Chambers, copying any known opposing counsel or opposing party, to request a special setting for all matters described in 1(b)(i) above except emergency matters (see Item 6 below regarding e-mails to Chambers). ii. For emergency matters, please file a motion requesting an emergency hearing and upload a proposed order granting the motion. A form of such an order is under “Forms” on the Chambers’ webpage. Then e-mail Chambers regarding the filed emergency motion, complying with Item 6 below. iii. Please note that even if a matter has been specially set on a particular date, you must consult with Chambers before adding any additional matters to that date. d. Available Dates. A list of currently available hearing dates for Judge Baisier’s matters is available on the Court’s website at http://www.ganb.uscourts.gov. Available dates and times are grouped by the Chapter under which the case is filed and the type of matter to be heard. ALWAYS CHECK THE LIST OF CURRENTLY AVAILABLE DATES WHEN SETTING A HEARING BECAUSE A DATE MAY BE REMOVED FROM THE LIST AT ANY TIME. Also, as noted in 1(c) above, the date that a matter is specially set for in a case is not automatically an available date for hearing other matters in that case. Matters set on a specially set date without prior consultation with Chambers may not be heard. e. Notice Requirements. Notwithstanding FRBP 9006(d), the hearing date you select must be at least fourteen (14) days after the date on which you serve the motion and notice of hearing, except that a hearing on motion to extend or impose - 2 - the automatic stay under 11 U.S.C. §§ 362(c)(3)(B) and (c)(4)(B) may be set on a day that is at least ten (10) days after service. Some types of matters may require a longer lead time between the date of service and the date of the hearing. See, e.g., FRBP 2002 and 3007 and BLR 7007-1(b). Motions for a final decree in a Chapter 11 case require thirty (30) days notice to the United States Trustee. If a rule gives a respondent a period of time to file a response, the hearing date picked must be at least two (2) business days after the last day on which a response could be timely filed. Also, remember that if a motion that is served by mail requires the filing of a response or some other act, Federal Rule of Bankruptcy Procedure 9006(f) adds three (3) days to prescribed period. f. Consent to Continuation of Stay. If there is no available hearing date for a stay relief motion that is at least fourteen (14) days but less than thirty-one (31) days after the filing of the motion, and a movant is unwilling to consent to continue the stay, the movant’s attorney must e-mail Chambers to obtain a special date and time for a hearing (see Item 6 below regarding such e-mails). Failure to do so will be considered to be consent of movant to the continuance of the stay through the date on which the matter is actually heard and resolved by appropriate order or other ruling. g. Avoid Lien or Redeem. BLR 6008-1 applies to motions to avoid a lien and to redeem. That rule has its own forms for notice, which do not require that a hearing be noticed. The Court will notice a hearing on those matters if a response is filed. The Court will use a single standard form of order to grant a motion for the avoidance of a lien. That form is available under “Forms” on the Chambers’ webpage. h. Date Selection Is Electronic When You File. You do not choose a hearing date through this web site, or by calling Chambers (unless the matter is specially set). Instead, the Court is informed of your selection of a date when you input the date and time selected during the electronic filing of the motion. Please do not call Chambers to confirm that a matter has been set on a calendar. i. Voluntary Notice Procedure. If you want to avoid the need to attend a hearing if your matter is not opposed in a variety of matters, please use the procedure set out in the Fifth Amended and Restated General Order 24-2018 for appropriate matters. - 3 - 2. Document Preparation and Filing. a. Preparation of Motion. Prepare the motion in compliance with all applicable rules. Include as exhibits any documents that are necessary to support the relief requested, redacting them as required. Affidavits or verifications should be provided where evidence is required to support the motion. b. Notice of Hearing and Filing. Prepare the notice of hearing, inserting the date, time, address and courtroom. Combine the notice, the motion, any brief, and the certificate of service into one (1) document for filing. The certificate of service must mention service of both the motion and the notice of hearing. For an objection to claim, please comply with Bankruptcy Local Rule 3007-1. A form Notice of Hearing is available under both “Hearing Information” and “Forms” tabs on the Chambers’ webpage. 3. Serving the Motion or Application. a. General Service. Serve the motion and the notice on all parties required to receive same by the Bankruptcy Code (11 U.S.C. § 101 et. seq.), the FRBP, and the BLR. The motion and related notice of hearing should be filed no later than one (1) business day after it is served. For guidance on service in contested matters and objections to claims, see http://www.ganb.uscourts.gov/service- pleadings b. Specific Service. If the motion seeks relief against a particular party, service should also be made on any attorney having filed a notice of appearance for that party, as well as to the notice address on any proof of claim filed by that party as of the date of the motion. Motions to strip liens or to determine the status of a claim, and objections to claim, should also be served specifically on the person that signed any related proof of claim. c. Service of Motions to Extend or Impose Stay. Motions under 11 U.S.C. § 362(c) should be served on all creditors as to whom the requested stay is applicable. For any creditor, such service would include service on: (1) the person and at the address shown on any proof of claim filed by that creditor in the prior case(s); (2) any attorney who entered an appearance for that creditor in the prior case(s); and (3) any proper individual or entity pursuant to FRBP 7004. Timely proof of service of both the motion and the notice of hearing is required. - 4 - 4. Rescheduling. ECF Participants/Attorneys may use the Forms of Notice that are available under both “Hearing Information” and “Forms” tabs on the Chambers’ webpage to reset a hearing date (by filing and serving an amended notice of hearing and supplying the date and time when filing), but only if all parties consent. 5. Reaffirmations. All hearings on reaffirmation agreements are heard on a single day each month before either Judge Jordan or Judge Cavender, regardless of which judge is assigned to the case. When self-calendaring a hearing on a reaffirmation agreement, use one of the dates on the Reaffirmation Agreement Hearing Dates page and DO NOT use a regular mass calendar date. 6. E-Mails to Chambers. a. E-mails to Chambers sent pursuant to these Instructions requesting a specially set hearing shall be addressed to the attention of the Courtroom Deputy and contain in the subject line (i) the notation “Request for Special Setting”, (ii) the name of the debtor, and (iii) the case number. E-mails regarding adversary proceedings shall also contain the adversary proceeding number. The body of the e-mail shall outline in brief the need for the special setting and shall provide a list of dates on which requesting counsel is available during the thirty (30) days after the first day on which the related motion could be heard. No e-mails addressed to the court should contain any argument. b. All e-mails to Chambers shall comply with in “Communications with Judge Baisier’s Chambers By E-mail” under “General Information” on the Chambers’ webpage. the policies set forth 7. Consequences for Failure to Comply With These Instructions. Any motions that do not comply with these Instructions will not be heard including, without limitation, (i) motions scheduled with insufficient lead time, (ii) motions set for the wrong date, time or location, (iii) motions not served on all the required parties, (iv) motions set for a date not included in the Court’s available dates (except for motions specially set as provided for herein), and (v) motions set on a date after that date has been removed from the available dates. - 5 -

=== Communicating with Judge Baisier's Chambers ===

COMMUNICATING WITH JUDGE BAISIER’S CHAMBERS (10/5/2021) Chambers receives hundreds of calls, letters and personal visits from attorneys or messengers each month. Much of that communication can be done more rapidly, more efficiently and more economically by e-mail. You may communicate with Chambers by e-mail at [email protected] Please follow the procedures in formatting e-mail messages. 1. Subject Line. The subject line of every message must begin with the case or adversary proceeding number, followed by the name of the Debtor, followed by a brief description of the subject matter. For example, a subject line might read as follows, following the word “subject” on the e-mail form: 99-54321; John Doe; Motion for Relief from Stay (Doc. 6) - OR – AP 00-1234; Doe v. Smith; Motion to Compel (Doc. 11) If the Debtor is a company and the name is long, such as Doe Mechanical and Electrical Contractors Company, Inc., put in enough to indicate the name; e.g., Doe Mech. Contractors. 2. Text. The text of an e-mail message should begin with the name of the person for whom the e- mail is intended. For almost all communications, this will either be the Courtroom Deputy Clerk or the Law Clerk. For example: To: Ashleigh Marchant. 3. Rule 9003. Federal Rule of Bankruptcy Procedure 9003(a) states: “Except as otherwise permitted by applicable law, any examiner, any party in interest, and any attorney, accountant, or employee of a party in interest shall refrain from ex parte meetings and communications with the court concerning matters affecting a particular case or proceeding.” Every message sent to Chambers must be sent to all parties in the contested matter or adversary proceeding (or specific dispute in an adversary proceeding), where Rule 9003 would require that a communication to Chambers sent by conventional means be served on other parties. If a party does not have an e-mail address, an indication that a copy was transmitted to that party and the method of transmission should be shown at the beginning of the text of the e-mail. For example: To: Law Clerk cc: John Doe, Debtor (by regular U.S. Mail at {address}) cc: Richard Roe, Attorney for xyz, Inc. (by facsimile at {number}) 4. Attachments. Keep attachments under 25MB in total. The primary word processing software used by the court is Microsoft Word. Please submit all documents in Word. The Court may also permit Portable Document Format (PDF) submissions for documents the Court will not need to alter or revise. 1 Unless directed to do so by the Judge, attorneys may not use e-mail to submit proposed orders, but should instead upload the orders via ECF. Refer to BLR 5005-1 and 9013-2 for proposed order requirements. 5. E-mail is not a way to avoid filing pleadings. Attorneys are not to use e-mail as a substitute for filing appropriate motions in the case. Refer to BLR 9003-2 for further detail. 6. Routine Matters. Attorneys may use e-mail to communicate with the Courtroom Deputy Clerk about routine non-substantive matters but should not send e-mails to inquire regarding whether a matter is on the calendar, whether an order has been entered, or for such other information that can be ascertained on ECF. Attorneys may use e-mail to request a hearing for a matter not subject to the Open Calendar Procedure, or to alert Chambers regarding the filing of an emergency motion or other matter that needs expedited treatment. Nonetheless, these rules must be followed in all respects and when in doubt about whether Rule 9003 is implicated, send a copy of your e-mail to the other party’s attorney (or to the party if they are not represented).

=== Content of Motions to Approve Loan Modification and Related Orders ===

CONTENT OF MOTIONS TO APPROVE LOAN MODIFICATION AND RELATED ORDERS (10/5/2021) The Court is aware that, in connection with the modification of existing loans, lenders often desire, or require, approval of the modification by the Court. The Court is willing to provide such comfort, but to do so, it needs some basic information on the benefit to the debtor of the modification. In a motion to approve a loan modification, the motion should apprise the Court, without resort to a detailed review of attached documents, of the benefits the debtor of the proposed modification. Such information should include all of the following (to the extent applicable): a) The existing arrearage is being rolled into the loan, in whole or in part (stating the size of the arrearage, the amount or portion being rolled into the loan and any portion being forgiven); b) The interest rate is being lowered (stating both the old and new rates); c) The term is being extended (stating the length of the current remaining term and the length of the extended term); d) Principal or other amounts owed are being forgiven (stating how much is being forgiven); e) The monthly payment is being decreased (stating the amount of the old and new payments). In the absence of sufficient information in the motion to determine the benefit of the loan modification to the debtor, such a motion will be heard, even in the absence of objection, so that such information can be obtained on the record. Orders granting such motions can contain stipulations of facts regarding the existing or revised loan (amount owed, interest rate, payment etc.) but such stipulations should not purport to be findings by the Court unless the matter is actually heard and evidence presented. Also, the Order should not order or direct the debtor to enter into the modification or make the corresponding payments – it should merely authorize the debtor to do so. Finally, if the modification results in the satisfaction of the arrearage, the Order must authorize and direct the Chapter 13 trustee to cease funding the arrearage under the plan, if the plan provides for such funding.

=== Content of Stay Relief Motions ===

CONTENT OF STAY RELIEF MOTIONS (10/5/2021) Motions for Relief Regarding Loans I. When requesting relief from the automatic stay to take action regarding collateral (whether real or personal), it is necessary to include in the motion, at minimum, the following information: a) The basis for the movant’s assertion that it is entitled to exercise the rights and remedies under the relevant security documents (i.e., normally because it owns the loan or security agreement or is a servicer for the owner); b) The amount of principal and interest owed as of a recent date; c) The number of missed periodic (usually monthly) payments (if any), including the number of post-petition payments missed, and the aggregate amount of the arrearage (if any)(stating the types of obligations, if any, not included in the figure); d) The movant’s evidence as to the value of the property (it is not sufficient to say that the movant does not know the value but assumes the value does not exceed the debt); e) Whether there is any other collateral for the debt being foreclosed upon; f) The nature and amount of any other debt secured by the property that is relevant to the relief requested (i.e. if a second mortgage or lien exists and consumes any available equity in the property); and g) Copies of all relevant loan documents, provided that if copies of these documents are attached to a filed proof of claim, movants may refer to such documents by specifically identifying the proof of claim number and date of filing of the claim in the text of the motion. Motions for Relief Regarding Leases II. When requesting relief from the automatic stay to take action regarding enforcement of residential, commercial, or automobile leases, it is necessary to include in the motion, at minimum, the following information: a) The basis for the movant’s assertion that it is entitled to exercise the rights and remedies under the relevant lease documents; b) The amount owed as of a recent date; c) The number of missed periodic (usually monthly) payments (if any), including the number of post-petition payments missed, and the aggregate amount of the arrearage (if any)(stating the types of obligations, if any, not included in the figure); and d) Copies of all relevant lease documents, provided that if copies of these documents are attached to a filed proof of claim, movants may refer to such documents by specifically identifying the proof of claim number and date of filing of the claim in the text of the motion. Motions not complying with these requirements will be heard, so that the required information can be obtained on the record, even in the absence of objection.

=== Content of Motions to Avoid Liens ===

CONTENT AND SERVICE REQUIREMENTS FOR MOTIONS TO AVOID LIENS (2/23/2024) SERVICE: SERVICE: In addition to the service required by Bankruptcy Rules of Federal Procedure 9014 and Bankruptcy Local Rule 6008, serve the following: 1. If a notice of appearance has been filed on behalf of the Respondent, service needs to be on that attorney 2. If Respondent filed a proof of claim, service needs to be on the address listed for notices on the POC JUDGMENT LIEN IDENTIFICATION: The motion needs to contain at least two of the following: 1. Court type and county and State (e.g., Magistrate/State/Superior Court of Fulton County, Georgia) 2. Case number 3. Date of Judgment 4. Date and location where Fi Fa was recorded 5. Dollar amount of judgment 6. Date the lower court case was filed NON-POSSESSORY NON-PURCHASE MONEY SECURITY INTEREST IDENTIFICATION: The motion needs to contain at least one, but preferably both, of the following: 1. Date of loan agreement 2. Amount of loan agreement

=== Service Requirements of Motions to Extend or Impose Stay ===

SERVICE REQUIREMENTS OF MOTIONS TO EXTEND OR IMPOSE STAY (10/5/2021) Motions under 11 U.S.C. § 362(c) should be served on all creditors as to whom the requested stay is applicable. For any creditor, such service would include service on: (1) the person and at the address shown on any proof of claim filed by that creditor in the prior case(s); (2) any attorney who entered an appearance for that creditor in the prior case(s); and (3) any proper individual or entity pursuant to FRBP 7004. Timely proof of service of both the motion and the notice of hearing is required.

=== Checklist for BLR 9010-5 - Withdrawal of Counsel ===

CHECKLIST FOR BLR 9010-5 WITHDRAWAL OF COUNSEL WITHOUT CLIENT CONSENT (10/5/2021) To withdraw as counsel, you must do EACH of the following, in order. FAILURE TO COMPLY WITH ALL ELEMENTS OF THIS PROCEDURE WILL RESULT IN A DENIAL OF THE REQUEST TO WITHDRAW. 1) Serve on the client (personally or by United States first class mail to last known address) a letter that does all of the following: a. States that the attorney intends to request the permission of the Court to withdraw as counsel, and includes the attorney’s reasons for doing so; b. Lists the style of the cases(s), adversary proceedings and contested matters from which counsel seeks to withdraw, and as to each such matter, lists the name and (to the extent known to counsel), the telephone number, mailing address and e-mail address of opposing counsel (or the opposing party if not represented)[if withdrawing as debtor’s counsel and there are no pending adversaries or contested matters, a statement to that effect should be included to explain the absence of opposing party information]; c. States the address and telephone number of the Clerk’s office; d. States that the Bankruptcy Court retains jurisdiction of the pending matters; e. States that, if withdrawal is permitted by the Court: (i) The client will have the obligation to promptly file with the Bankruptcy Court, and mail to all adverse parties or their counsel, a written statement showing (A) the names of the parties and the number of each case, adversary proceeding, or contested matter in which the client is a party and (B) the client’s current name, telephone number, mailing address, and e-mail address, and that the statement must be amended promptly if the client’s name, telephone number, mailing address, or e-mail address changes; (ii) The client will have the obligation to respond to any discovery or motions, to take other actions as are appropriate or required, and to prepare for any trial or hearing that may be scheduled in any matter, or to hire other counsel to do so; (iii) The failure or refusal of the client to meet these obligations may result in adverse consequences; (iv) Service of notices, pleadings, and other papers may be made upon the client at the client’s last known address; and (v) [only required if the client is a corporation or other artificial entity] As an entity, the client may only be represented in the Bankruptcy Court by an attorney, an attorney must sign all pleadings submitted to the Bankruptcy Court, an officer may not represent the entity in the Bankruptcy Court unless that officer is also an attorney, and failure to comply with this rule could result in adverse consequences to the client; f. Sets forth the dates of any hearings or trials that have been scheduled and any applicable deadlines (such as deadlines for responding to discovery or motions or for filing pleadings, motions, or other papers), and states that the holding of such hearings or trials and any deadlines will not be affected by the withdrawal of counsel, alternatively, if there are no such hearings or trials, a statement to that effect should be included; and g. Informs the client that the client has fourteen (14) days from the date of service of the letter/notice to contact the attorney and state any objections to the attorney’s withdrawal. AFTER THE 14 DAYS DESCRIBED IN THE LETTER HAVE RUN, THE ATTORNEY MUST THEN: 2) File a motion with the Court that: a. Requests permission to withdraw; b. Attaches a copy of the letter sent to the client; c. States that the attached letter was sent to the client, the date it was sent, and the response received from the client (if any); d. States the last known address, telephone number, and e-mail address for the client; and e. Includes a certificate of service that shows when the motion was served on the client and at what address(es). 3) Either in the motion or by a separate notice, inform the client that the client has fourteen (14) days from the date the motion is served to object to the motion by filing an objection with the Court, and include the address of the Clerk’s office where the objection may be filed. The motion should also advise the client of their responsibilities to file and serve a statement under BLR 9010-5(d). THERE ARE TWO (2) RELEVANT 14 DAY PERIODS INVOLVED IN WITHDRAWAL. Once all requirements have been satisfied, please upload a proposed order. Withdrawal of Counsel with Client Consent There are alternatives to the foregoing process IF THE CLIENT CONSENTS TO THE WITHDRAWAL. They are: 1) Where there is a substituting attorney, file a Certificate of Consent to Withdraw that (i) provides for the withdrawal of prior counsel and the substitution of new counsel, and (ii) is signed by the client, the substituting attorney, and the withdrawing attorney; or 2) Where there is no substituting attorney, file a Certificate of Consent to Withdraw that (i) provides for the withdrawal of existing counsel, (ii) notifies the client of each of the matters set forth in 1(e) above, (iii) notifies the client of their responsibilities to file and serve a statement under BLR 9010-5(d), and (iv) is signed by the withdrawing attorney and the client.

=== Discovery Disputes ===

1. Resolution of Discovery Disputes; Required Telephonic Conference Discovery Disputes If a discovery disputes arises,1 an aggrieved party may notify the Court of the dispute by submitting a letter or e- mail (a “Communication”), with a copy to counsel for the opposing party(ies) and to any unrepresented part(ies) by the most expeditious means available to the sender. The Communication must comply with the Court’s policy regarding communication with Chambers,2 must demonstrate compliance with Federal Rule of Civil Procedure 37, applicable herein by and through Federal Rule of Bankruptcy Procedure 7037 (in particular, the obligation to confer regarding discovery disputes), and must provide sufficient information and/or documentation regarding the dispute to permit a meaningful telephone conference between the parties and the Court. The Communication should be succinct and should describe the issue for decision with as little argument as is possible and without disparagement of the opposing party(ies). The opposing party(ies) may submit a reply to the Court, with a copy to counsel for the opposing party(ies) and to any unrepresented part(ies) by the most expeditious means available to the sender, although (depending on the circumstances) the Court may schedule and/or hold the required telephonic conference prior to receiving a reply. If a party or its counsel does not cooperate in scheduling the required telephonic conference, the Court may proceed with the conference with the available party(ies) and counsel. As permitted by Bankruptcy Local Rule 7037-1(e), no party to an Adversary Proceeding may file a motion to compel, a motion for a protective order, or a motion for sanctions (any such motion a “Discovery Motion”) without first having discussed the matter with the Court in a telephonic conference. A Discovery Motion that does not comply with Fed.R.Civ.P. 37, as incorporated by Fed.R.Bankr.P. 7037, or that precedes an initial conference with the Court as required by these procedures, will be denied without a hearing. The requirement of the telephonic conference prior to filing a motion to compel, however, does not apply to the complete failure to respond to discovery requests, and in such circumstances the telephonic conference requirement is inapplicable. The requirement of a prior telephonic conference also does not apply to a non-party that wishes to file a motion for a protective order regarding a subpoena. 2. Deposition Conduct; Court Availability for Resolution. Parties and their counsel may sometimes engage in conduct during depositions that is detrimental to the fact-finding process and to the just, speedy and inexpensive determination of Adversary Proceedings. This conduct can often be avoided or mitigated by access to the Court in real time during the deposition. Consequently, if a participant in a deposition believes that another participant is engaging in particularly egregious conduct during the deposition, that party may pause the deposition and contact the Court by telephone (404-215-1010) for an immediate resolution of the dispute. Prior to pausing the deposition, the aggrieved party should engage in reasonable efforts to cause the conduct to cease and should inform the party engaged in such conduct that if it does not cease that immediate telephonic access to the Court will be sought. If the Court is not immediately available by telephone, the parties should continue with the deposition, continue to try to resolve the dispute themselves, and continue to endeavor to contact the Court regarding the dispute. The Court may assess monetary or other sanctions (i) against attorneys found to have engaged in egregious conduct during a deposition (and their clients), (ii) against attorneys who have asserted that egregious conduct has occurred when there is no reasonable basis for having asserted same (and their clients), (iii) against parties found to have engaged in egregious behavior at depositions or who have asserted that egregious conduct has occurred when there is no reasonable basis for having asserted same, and (iv) in other appropriate circumstances. Without limiting the generality of the foregoing, conduct that may be the subject of this provision includes objecting to all or substantially all of the questions asked to a witness, regularly instructing the witness not to answer questions in the absence of any legitimate basis for doing so, engaging in multiple speaking objections that coach the witness as to the 1 Disputes regarding conduct at a deposition arising at a deposition will be resolved via Item 2. 2 That policy is set forth under the “General Information” on the Chambers web page. answer, repeatedly asking the witness the same question after the question has already been asked and answered, or asking the witness questions regarding information of a personal nature that is not directly relevant to the litigation.

=== Pretrial Matters ===

Pretrial Matters in Adversary Proceedings 1. Requirement for an Extension of Deadlines in 26(f) Report If an extension of any of the deadlines established in a Report of Rule 26(f) Conference (a “Report”) that has been approved by the Court is requested, the party seeking the extension shall file a motion to amend the Report. The motion should include all proposed deadline extensions, including the new proposed deadlines for filing dispositive motions and the submission of a pretrial order, as well as a statement indicating whether or not the Court has granted previous extension requests and describing those extensions. All requests for extensions of the discovery period shall include a basic description of discovery conducted thus far, the requested deadline extension, a general description of schedule for the outstanding discovery to be completed during the requested extension, and an explanation regarding why the deadline needs to be extended. The moving party shall attempt to present such request with the consent of the non-moving party. 2. Discovery Must Be Completed by Close of Discovery All written discovery requests must be served early enough so that the responses are due on or before the last day of the discovery period. The Court typically will not enforce private agreements between the parties and/or their counsel to conduct discovery beyond the end of the discovery period, nor will the Court ordinarily compel responses to discovery requests that were not served in time for responses to be made before the discovery period expires. 3. Document Requests Should Be Specific. Document requests should be tailored to describe the specific documents or types of documents sought by the requesting party. Requests for “any and all documents in any way related to” a specific topic are not acceptable, particularly where “related to” is then defined as having anything whatsoever to do with the topic. 4. Rules Governing Discovery Responses. Boilerplate objections in responses to discovery requests are prohibited. Parties may not automatically invoke standard objections, e.g. attorney-client privilege, work product doctrine, overly broad/unduly burdensome, not reasonably calculated to lead to the discovery of admissible evidence, etc. as being applicable to all the requests. The Court may disregard some or all such boilerplate objections. Similarly, parties shall not simply state in response that “the document speaks for itself,” but shall provide a statement of the party’s interpretation or understanding of the document in question if it differs from the statement to which a response is being provided. General objections are also prohibited. In other words, a party shall not include in its written discovery response a section of “general objections” stating that the party objects to each discovery request “to the extent” that it violates some rule pertaining to discovery, e.g. attorney- client privilege, work product doctrine, overly broad/unduly burdensome, not reasonably calculated to lead to the discovery of admissible evidence, etc. The Court may disregard some or all such general objections. Instead of the foregoing, each individual discovery request must be met with a specific objection thereto, and such objection shall include only objections applicable to that request. This will permit the Court and the parties to evaluate the request and the response should a dispute over the request, the response or the related production later arise. A party that objects to a discovery request but then responds to it (i.e. “Subject to these objections and without waiving them, the response is as follows”) must indicate in the response whether additional information or documents would have been provided but for the objection(s). The party must also indicate in the response (i) for interrogatories, the nature of the information withheld to the extent it can be described without waiving the objection, and (ii) for document requests, the type and approximate number of documents that were not produced as a result of each objection. This latter information may be provided by supplemental response but shall be provided as soon as it is reasonably available and in no event later than thirty (30) days prior to the end of the discovery period. Nothing in the foregoing reduces, excuses or eliminates any obligation to provide a privilege log or other list of withheld documents. 5. Production of Documents Promised in Depositions When during a deposition a person being deposed (or their counsel) indicates that a document will be produced, such document shall be considered to have been the subject of a document request that was not objected to and will be produced as promptly as is practicable without further request. Failure to produce such a document after a subsequent written request therefore will subject the appropriate person or entity to sanctions for failure to comply with discovery.

=== Instructions for Appearing by Telephone and Video Conference ===

INSTRUCTIONS FOR APPEARING BY VIDEO CONFERENCE (11/15/2022) • ARRIVE EARLY. Connect via Judge Baisier’s Virtual Hearing Room at least ten (10) minutes before the hearing time. • QUIET PLACE; NO CARS. Make sure you are alone in a quiet place free of any background noises. A car is not an appropriate place from which to participate in a hearing. If you are not alone, you must advise the court who else is in the room with you. • BACKGROUND. Use a plain or blurred background. Make sure your background is not distracting to other participants or embarrassing to you. • APPROPRIATE COURT ATTIRE. Dress for your virtual proceeding as if you were attending your court proceeding in the courtroom. Appropriate attire is mandatory for any appearance in court. • CAMERA ANGLE; DISTANCE FROM CAMERA. The camera should be pointed straight at your face. It should not be pointed up towards the ceiling or down towards the floor. Distance from the camera also matters. Too close is not good and too far away is not good either. • HEADSET ENCOURAGED; CELL PHONES DISCOURAGED; SPEAKERPHONE PROHIBITED. Use a headset if at all possible, to improve your audio and reduce or eliminate background noise. If you use a cell phone to connect to a virtual hearing, you risk a slow connection or disconnection. Use a computer with an internet connection if at all possible. DO NOT use a speakerphone. IDENTIFY YOURSELF. Each time you speak, identify yourself for the audio record. • • VIRTUAL COMPETENCE. Learn how to mute and unmute yourself. If your hearing involves presentation of documents by you, learn how to share your screen before the hearing. • NO SELF RECORDING. Pursuant to BLR 5073-1, you are prohibited from recording or broadcasting the proceedings. • NO COURT REPORTER. In the Bankruptcy Court for the Northern District of Georgia, hearings are recorded by audio and video only. There is no court reporter transcribing the proceedings. • YOUR CONNECTION; YOUR RESPONSIBITY. You are responsible for your connection to the virtual courtroom. The court will not wait for you or reschedule a hearing because your connection is not stable, reliable or otherwise does not permit your participation. Make sure in advance that your connection is adequate to allow you to participate fully. INSTRUCTIONS FOR APPEARING BY TELEPHONIC CONFERENCE (11/15/2022) • ARRIVE EARLY. Dial in at least ten (10) minutes before the hearing time. • QUIET PLACE; NO CARS. Make sure you are alone in a quiet place free of any background noises. A car is not an appropriate place from which to participate in a hearing. If you are not alone, you must advise the court who else is in the room with you. • CELL PHONES DISCOURAGED; SPEAKERPHONE PROHIBITED. If you use a cell phone to connect to a telephonic hearing, you risk a slow connection or disconnection. Use a land line if at all possible. DO NOT use a speakerphone. • IDENTIFY YOURSELF. Each time you speak, identify yourself for the audio record. • NO SELF RECORDING. Pursuant to BLR 5073-1, you are prohibited from recording or broadcasting the proceedings. • NO COURT REPORTER. In the Bankruptcy Court for the Northern District of Georgia, hearings are recorded by audio and video only. There is no court reporter transcribing the proceedings. • YOUR CONNECTION; YOUR RESPONSIBITY. You are responsible for your telephonic connection. The court will not wait for you or reschedule a hearing because your connection is not stable, reliable or otherwise does not permit your participation. Make sure in advance that your telephonic connection is adequate to allow you to participate fully.

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