Certification of Disclosures

Within seven (7) days after the completion of claim construction briefing, the parties, having met and conferred on claim construction, shall file a Joint Claim Construction Statement which shall contain the following information: i. The construction of those claims and terms on which the parties agree; ii. Each party’s proposed construction of each disputed claim and term; iii. Each party’s position on whether a technical tutorial is necessary; and iv. For any party who proposes to call one or more witnesses at any claim construction hearing, the identity of each such witness, the subject matter of his or her testimony, and an estimate of the time required for the testimony.

2. Cases Seeking Correction of Inventors (35 U.S.C. § 256) and Cases Alleging False Marking (35 U.S.C. § 292) Fifty-six (56) days from the date of the Scheduling Order, the parties, having met and conferred on claim construction, shall report to the Court as to whether there are any contested issues of claims construction and, if so, shall propose a schedule for serving Claim Construction Statements and Responsive Claim Construction Statements and filing a Joint Claim Construction Statement, opening claim construction briefs, and responsive claim construction briefs. RULE 806.

CERTIF ICATION OF DISCLOSURES

All statements, disclosures, and charts served in accordance with L.R. 804 and 805 shall be dated and signed by counsel of record. Counsel’s signature shall constitute a certification that to the best of his or her knowledge, information, and belief – formed after an inquiry that is reasonable under the circumstances – the information contained in the statement, disclosure, or chart is complete and correct at the time it is made. U.S. District Court of Maryland Local Rules (December 1, 2025) 98 Local Admiralty Rule (a): Scope, Citation, and Definitions LAR(a)(1) Scope Local Admiralty Rule (b): Maritime Attachment and Garnishment LAR(b)(1) “Found Within the District” IX. SUPPLEMENTAL ADMIRALTY AND MARITIME RULES LOCAL ADMIRALTY RULE (A): SCOP E, CITATION, AND DEFIN ITIONS LAR(a)(1) Scope These local admiralty rules apply only to civil actions that are governed by the Supplemental Rules for Certain Admiralty and Maritime Claims (Supplemental Rule or Rules).

All other local rules are applicable in these cases, but to the extent that another local rule is inconsistent with the applicable local admiralty rules, the local admiralty rules shall govern. LAR(a)(2) Citation The local admiralty rules may be cited by the letters “LAR” and the lower case letters and numbers in parentheses that appear at the beginning of each section. The lower case letter is intended to associate the local admiralty rule with the Supplemental Rule that bears the same capital letter. LAR(a)(3) Definitions As used in the local admiralty rules, “Court” means the United States District Court for the District of Maryland; “judicial officer” means a United States District Judge or a United States Magistrate Judge; “Clerk of Court” means the Clerk of the United States District Court and includes deputy clerks of court; “Marshal” means the United States Marshal and includes deputy marshals; “keeper” means any person or entity appointed by the Marshal to take physical custody of and maintain the vessel or other property under arrest or attachment; and “substitute custodian” means the individual or entity who, upon motion and order of the Court, assumes the duties of the Marshal or keeper with respect to the vessel or other property arrested or attached.

LOCAL ADMIRALTY RULE (B): MARITIME ATTACHMEN T AND GARN ISHMENT LAR(b)(1) “Found Within the District” A defendant is not found within the District unless the defendant can be personally served therein by delivering process (i) in the case of an individual, to the individual personally, or by leaving a copy thereof at the individual’s dwelling house or usual place of abode with some person of suitable age and discretion; (ii) in the case of a corporation, trust or association, to an officer, trustee, managing, or general agent thereof; (iii) in the case of a partnership, to a general partner thereof; and (iv) in the case of a limited liability company, to a manager thereof. U.S. District Court of Maryland Local Rules (December 1, 2025) 99 Local Admiralty Rule (b): Maritime Attachment and Garnishment LAR(b)(2) Affidavit that Defendant is Not Found Within the District Local Admiralty Rule (c): Actions In Rem: Special Provisions LAR(c)(2) Publication of Notice of Action and Arrest LAR(b)(2) Affidavit that Defendant is Not Found Within the District The affidavit required by Supplemental Rule B(1) to accompany the complaint shall specify with particularity the efforts made by and on behalf of the plaintiff to find and serve the defendant within the District. LAR(b)(3) Use of State Procedure When the plaintiff invokes a state procedure in order to attach or garnish under Fed. R. Civ. P. 4(n)(2), the process of attachment or garnishment shall so state. LAR(b)(4) Notice to Defendant In default applications, the affidavit or other proof required by Supplemental Rule B(2)(c) from the plaintiff or the garnishee shall specify with particularity the efforts made to give notice of the action to the defendant.

LOCAL ADMIRALTY RULE (C): ACTIONS IN REM: SPECIAL PROVISIONS LAR(c)(1) Intangible Property The summons to show cause why property should not be deposited in the Court, issued pursuant to Supplemental Rule C(3)(c), shall direct the person having control of intangible property to show cause no later than fourteen (14) days after service why the intangible property should not be delivered to the Court to abide further order of the Court. A judicial officer for good cause shown may lengthen or shorten the time. Service of the warrant shall have the effect of arresting the intangible property and bringing it within the control of the Court. Service of the summons to show cause requires a garnishee wishing to retain possession of the property to establish grounds for doing so, including specification of the measures taken to segregate and safeguard the intangible property arrested.

Upon order of the Court, the person who is served may deliver or pay over to the Clerk of Court the intangible property proceeded against to the extent sufficient to satisfy the plaintiff ’s claim. If such delivery or payment is made, the person served is excused from the duty to show cause. LAR(c)(2) Publication of Notice of Action and Arrest The notice required by Supplemental Rule C(4) shall be published at least once in a newspaper of general circulation in the division of the District where the property has been seized. The Clerk of Court shall maintain and make available a list of newspapers of general circulation for each division of the District.

The plaintiff ’s attorney shall file with the Clerk of Court a copy of the notice as it was published. The notice shall contain: a. The court, title, and number of the action; U.S. District Court of Maryland Local Rules (December 1, 2025) 100 Local Admiralty Rule (c): Actions In Rem: Special Provisions LAR(c)(2) Publication of Notice of Action and Arrest Local Admiralty Rule (c): Actions In Rem: Special Provisions LAR(c)(3) Notice Requirements b. c. d. e. f. g. The date of the arrest; The identity of the property arrested; The name, address, telephone number, and bar number of the attorney for the plaintiff; A statement that a person asserting ownership interest in the property or a right of possession pursuant to Supplemental Rule C(6) must file a statement of such interest with the Clerk and serve it on the attorney for the plaintiff within fourteen (14) days after publication; A statement that an answer to the complaint must be filed and served within twenty-one (21) days after the filing of the statement of interest and that otherwise default may be entered and condemnation ordered; A statement that motions to intervene under Fed. R. Civ. P. 24 by persons asserting maritime liens or other interests shall be filed within a time fixed by the Court; and h. The name, address, and telephone number of the Marshal and the keeper or substitute custodian. LAR(c)(3) Notice Requirements a) Default Judgments i) Notice Given. A party seeking a default judgment in an action in rem must satisfy the judge that due notice of the action and arrest of the property has been given (1) by publication as required in LAR(c)(2); (2) by service of the complaint and warrant of arrest upon the Marshal and keeper, substitute custodian, master, or other person having custody of the property; and (3) by mailing such notice to every other person who has not appeared in the action and is known to the party seeking the default judgment to have an ownership interest in the property. ii) Notice Attempted.

(1) If the defendant property is a vessel documented under the laws of the United States, the plaintiff must attempt to notify all persons identified as having an interest in the vessel in the United States Coast Guard Certificate of Ownership or the General Index or Abstract of Title. U.S. District Court of Maryland Local Rules (December 1, 2025) 101 Local Admiralty Rule (c): Actions In Rem: Special Provisions LAR(c)(3) Notice Requirements Local Admiralty Rule (d): Possessory, Petitory, and Partition Actions Return Date LAR(d) (2) If the defendant property is a vessel numbered as provided in the Federal Boat Safety Act, the plaintiff must attempt to notify the owner as named in the records of the issuing authority. b) Ship Mortgage Act For purposes of the Ship Mortgage Act, 46 U.S.C. § 31325, notice to the Master of a vessel, or the person having physical custody thereof, by service of the Warrant of Arrest and Complaint shall be deemed in compliance with the notice requirements of such Act, as to all persons, except as to those who have recorded a notice of claim of lien. c) Mailing The notification requirement is satisfied by mailing copies of the warrant of arrest and complaint to the person’s address using any form of mail requiring a return receipt. LAR(c)(4) Entry of Default and Default Judgment After the time for filing a claim or answer has expired, the plaintiff may move for entry of default under Fed. R. Civ. P. 55(a). Default will be entered upon showing by affidavit or certificate of counsel that: Notice has been given as required by LAR(c)(3)(a)(i); and a. Notice has been attempted as required by LAR(c)(3)(a)(ii), where appropriate; and b. The time to answer by any person asserting a right of possession or any ownership interest in the property has expired; and c. No answer has been filed and no one has appeared to defend on behalf of the property.

The plaintiff may move for judgment under Fed. R. Civ. P. 55(b) at any time after default has been entered. LOCAL ADMIRALTY RULE (D): POSSESSORY, PETITORY, AND PARTITION ACTIONS LAR(d) Return Date In an action under Supplemental Rule D, a judicial officer may order that the statement of interest and answer be filed on a date earlier than twenty-one (21) days after arrest. The order may also set a date for expedited hearing of the action. U.S. District Court of Maryland Local Rules (December 1, 2025) 102 Local Admiralty Rule (e): Actions In Rem and Quasi In Rem: General Provisions LAR(e)(1) Itemized Demand for Judgment Local Admiralty Rule (e): Actions In Rem and Quasi In Rem: General Provisions LAR(e)(5) Exigent Circumstances LOCAL ADMIRALTY RULE (E): ACTIONS IN REM AND QUASI IN REM: GENERAL PROVISIONS LAR(e)(1) Itemized Demand for Judgment The demand for judgment in every complaint filed under Supplemental Rules B or C shall allege the dollar amount of the debt or damages for which the action was commenced.

The demand for judgment shall also allege the nature of other items of damage. LAR(e)(2) Salvage Action Complaints In an action for a salvage award, the complaint shall allege the dollar value of the vessel, cargo, freight, and other property salved or any other basis for an award. The complaint shall also state the dollar amount of the award claimed. LAR(e)(3) Verification of Pleadings Every complaint in Supplemental Rules B, C, and D actions shall be verified upon oath or solemn affirmation, or in the form provided by 28 U.S.C. § 1746, by a party or by an authorized officer of a corporate party.

If no party or authorized corporate officer is readily available, verification of a complaint may be made by an agent, attorney in fact, or attorney of record, who shall state the sources of the knowledge, information, and belief contained in the complaint; declare that the document verified is true to the best of that knowledge, information, and belief; state why verification is not made by the party or an authorized corporate officer; and state that the affiant or declarant is authorized so to verify. If the verification was not made by a party or authorized corporate officer, any interested party may move, with or without requesting a stay, for the personal oath of a party or an authorized corporate officer, which shall be procured by commission or as otherwise ordered. LAR(e)(4) Review by Judicial Officer Unless otherwise required by the judicial officer, the review of complaints and papers called for by Supplemental Rules B(1) and C(3) does not require the affiant or declarant, party, or attorney to be present. Any complaint presented to a judicial officer for review shall be accompanied by a form of order to the Clerk which, upon signature by the judicial officer, shall direct the arrest, attachment, or garnishment sought by the applicant.

LAR(e)(5) Exigent Circumstances The certification of exigent circumstances by the plaintiff or his attorney under Supplemental Rules B and C shall consist of an affidavit or a declaration pursuant to 28 U.S.C. § 1746 describing in detail the facts establishing the exigent circumstances. U.S. District Court of Maryland Local Rules (December 1, 2025) 103 Local Admiralty Rule (e): Actions In Rem and Quasi In Rem: General Provisions LAR(e)(6) Instructions to the Marshal Local Admiralty Rule (e): Actions In Rem and Quasi In Rem: General Provisions LAR(e)(10) Intervenors’ Claims and Sharing of Marshal’s Fees and Expenses LAR(e)(6) Instructions to the Marshal The party who requests a warrant of arrest or process of attachment or garnishment shall provide instructions to the Marshal. LAR(e)(7) Property in Possession of United States Officer When the property to be attached or arrested is in the custody of an employee or officer of the United States, the Marshal shall deliver a copy of the complaint and warrant of arrest or summons and process of attachment or garnishment to that officer or employee if present, and otherwise to the custodian of the property. The Marshal shall instruct the officer or employee or custodian to retain custody of the property until ordered to do otherwise by a judicial officer.

LAR(e)(8) Adversary Hearing An adversary hearing provided for in Supplemental Rule E(4)(f) following arrest or attachment or garnishment shall be conducted by the Court within three (3) days after a request for such hearing, unless otherwise ordered. LAR(e)(9) Security Deposit for Seizure of Vessels The party(ies) who seek(s) arrest or attachment of a vessel or property aboard a vessel shall deposit with the Marshal $3,000 for vessels more than sixty-five (65) feet in length overall or $500 for vessels sixty-five (65) feet in length overall or less. These deposits shall be used to cover the expenses of the Marshal including, but not limited to, dockage, keepers, maintenance, and insurance. The party(ies) shall advance additional sums from time to time as requested by the Marshal to cover the estimated expenses until the property is released or disposed of as provided in Supplemental Rule E. LAR(e)(10) Intervenors’ Claims and Sharing of Marshal’s Fees and Expenses a) Intervention Before Sale When a vessel or other property has been arrested, attached, or garnished, and is in the hands of the Marshal or custodian substituted therefore, anyone having a claim against the vessel or property is required to present the claim by filing an intervening complaint under Fed. R. Civ. P. 24, and not by filing an original complaint, unless otherwise ordered by a judicial officer.

An order permitting intervention may be signed ex parte at the time of filing the motion, subject to the right of any party to object to such intervention within fourteen (14) days after receipt of a copy of the motion and proposed pleading. Such motions shall not be subject to the provisions of L.R. 105. Upon the signing of an order permitting intervention, the Clerk shall forthwith deliver a conformed copy of the intervening U.S. District Court of Maryland Local Rules (December 1, 2025) 104 Local Admiralty Rule (e): Actions In Rem and Quasi In Rem: General Provisions LAR(e)(10) Intervenors’ Claims and Sharing of Marshal’s Fees and Expenses Local Admiralty Rule (e): Actions In Rem and Quasi In Rem: General Provisions LAR(e)(11) Custody of Property complaint to the Marshal, who shall deliver the copy to the vessel or custodian of the property. Intervenors shall thereafter be subject to the rights and obligations of parties, and the vessel or property shall stand arrested, attached, or garnished by the intervenor.

An intervenor shall not be required to advance a security deposit to the Marshal for seizure of a vessel as required by LAR(e)(9). Property arrested, attached, or garnished by an intervenor shall be released in accordance with Supplemental Rule E(5). b) Sharing Marshal’s Fees and Expenses Before Sale Upon motion by any party, security deposits may be ordered to be paid or shared by any party who has arrested, attached, or garnished a vessel or property aboard a vessel in amount or proportions to be determined by a judicial officer. c) Intervention After Sale After ratification of sale and payment of the purchase price, any person having a claim against the vessel or property that arose before ratification must present the same by intervening complaint, pursuant to LAR(e)(10)(a), against the proceeds of the sale and may not proceed against the vessel unless a judicial officer shall otherwise order for good cause shown. Where an intervening complaint prays service of process in rem, the filing of such intervening complaint with the Clerk shall be deemed to be a claim against such proceeds without the issuance of an in rem process, unless a judicial officer shall otherwise order for good cause shown. The judicial officer shall allow a period of at least thirty (30) days after due ratification of the sale for the submission of such claims.

LAR(e)(11) Custody of Property a) Safekeeping of Property When a vessel or other property is brought into the Marshal’s custody by arrest or attachment, the Marshal shall arrange for adequate safekeeping, which may include the placing of keepers on or near the vessel. A substitute custodian in place of the Marshal may be appointed by order of the Court. b) Insurance The Marshal may order insurance to protect the Marshal, his deputies, keepers, and substitute custodians, from liabilities assumed in arresting and holding the vessel, cargo, or other property, and in performing whatever services may be undertaken to protect the vessel, cargo, or other property, and in maintaining the Court’s custody. The premiums charged for the liability insurance shall be paid out of the security deposits advanced to the Marshal in accordance with LAR(e)(9). U.S. District Court of Maryland Local Rules (December 1, 2025) 105 Local Admiralty Rule (e): Actions In Rem and Quasi In Rem: General Provisions LAR(e)(11) Custody of Property Local Admiralty Rule (e): Actions In Rem and Quasi In Rem: General Provisions LAR(e)(12) Sale of Property c) Employment of Vessel’s Officers and Crew by Marshal All officers and members of the crew employed on a vessel of 750 gross tons or more shall be deemed employees of the Marshal for the period of seven (7) days after the attachment or arrest of the vessel unless the Marshal, pursuant to a court order, has notified the officers and members of the crew that they are not so employed or unless the vessel is released from attachment or arrest.

If the vessel is not released within seven (7) days, the Marshal shall, on request of the seizing party, immediately thereafter designate which, if any, officers and members of the crew he is continuing to employ to preserve the vessel and shall promptly notify the remaining officers and members of the crew that they are no longer in his employ and are no longer in the service of the vessel and are free to depart from the vessel. The notice required by the preceding sentence shall be by written notice posted in a prominent place in each of the mess rooms or dining salons used by the officers and unlicensed personnel aboard the vessel. d) Normal Vessel Operations and Movement of the Vessel Following arrest, attachment, or garnishment of a vessel or property aboard a vessel, normal vessel operations shall be permitted to commence or continue unless otherwise ordered by the Court. No movement of the vessel shall take place unless authorized by order of a judicial officer. e) Procedure for Filing Claims by Suppliers for Payment of Charges A person who furnishes supplies or services to a vessel, cargo, or other property in custody of the Court who has not been paid and claims the right to payment as an expense of administration shall submit an invoice to the Clerk in the form of a verified claim within the time period set by the Court for intervention after sale pursuant to LAR(e)(10)(c). The supplier must serve copies of the claim on the Marshal, substitute custodian if one has been appointed, and all parties of record.

The Court may consider the claims individually or schedule a single hearing for all claims. LAR(e)(12) Sale of Property a) Notice Notice of sale of property in an action under Supplemental Rules B or C shall be published under such terms and conditions as set by the Court. b) Payment of Bid These provisions apply unless otherwise ordered in the order of sale: The person whose bid is accepted shall immediately pay the Marshal the full purchase price if the bid is $1,000 or less. If the bid exceeds $1,000, the bidder shall immediately pay a deposit of at least U.S. District Court of Maryland Local Rules (December 1, 2025) 106 Local Admiralty Rule (e): Actions In Rem and Quasi In Rem: General Provisions LAR(e)(12) Sale of Property Local Admiralty Rule (e): Actions In Rem and Quasi In Rem: General Provisions LAR(e)(12) Sale of Property $1,000 or 10% of the bid, whichever is greater, and shall pay the balance within seven (7) days after the day on which the bid was accepted. If an objection to the sale is filed within that seven (7) day period, the bidder is excused from paying the balance of the purchase price until seven (7) days after the sale is confirmed.

Payment shall be made by certified check, by cashier’s check drawn on banks insured by the Federal Deposit Insurance Corporation or the Federal Savings and Loan Insurance Corporation, or as otherwise authorized by the Marshal. c) Default If the successful bidder does not pay the balance of the purchase price within the time allowed, the bidder shall be in default. In such a case, the judicial officer may accept the second highest bid or arrange a new sale. The defaulting bidder’s deposit shall be forfeited and applied to any additional costs incurred by the Marshal because of the default, the balance being retained in the registry of the Court awaiting its order. d) Report of Sale by Marshal At the conclusion of the sale, the Marshal shall forthwith file a written report with the Court of the fact of sale, the date, the price obtained, the name and address of the successful bidder, and any other pertinent information. e) Time and Procedure for Objection to Sale An interested person may object to the sale by filing a written objection with the Clerk within seven (7) days following the sale, serving the objection on all parties of record, the successful bidder, and the Marshal, and depositing such sum with the Marshal as determined by him to be sufficient to pay the expense of keeping the property for at least seven (7) days. Payment to the Marshal shall be made by certified check, by cashier’s check drawn on banks insured by the Federal Deposit Insurance Corporation or the Federal Savings and Loan Insurance Corporation, or as otherwise authorized by the Marshal. f) Confirmation of Sale A sale shall be confirmed by order of the Court within seven (7) days, but no sooner than three (3) days, after the sale.

If an objection to the sale has been filed pursuant to LAR(e)(12)(e), the Court shall hold a hearing on the confirmation of the sale. The Marshal shall transfer title to the purchaser upon the order of the Court. U.S. District Court of Maryland Local Rules (December 1, 2025) 107 Local Admiralty Rule (e): Actions In Rem and Quasi In Rem: General Provisions LAR(e)(12) Sale of Property Local Admiralty Rule (f): Limitation of Liability LAR(f)(2) Order of Proof at Trial g) Disposition of Deposits i) Objection Sustained If an objection is sustained, sums deposited by the successful bidder will be returned to the bidder forthwith. The sum deposited by the objector will be applied to pay the fees and expenses incurred by the Marshal in keeping the property until it is resold, and any balance remaining shall be returned to the objector.

The objector will be reimbursed for the expense of keeping the property from the proceeds of a subsequent sale. ii) Objection Overruled If the objection is overruled, the sum deposited by the objector will be applied to pay the expense of keeping the property from the day the objection was filed until the day the sale is confirmed, and any balance remaining will be returned to the objector forthwith. LAR(e)(13) Discharge of Stipulations for Value and Other Security When an order is entered in any cause marking the case “Dismissed” or “Agreed and Settled,” or “Agreed, Settled, and Satisfied,” the entry shall operate as a cancellation of all stipulations for value or other security provided to release the property seized that were filed in the case, unless otherwise provided in the order or by the Court. LOCAL ADMIRALTY RULE (F): LIMITATION OF LIABILITY LAR(f)(1) Security for Costs The amount of security for costs under Supplemental Rule F(1) shall be $1,000, and it may be combined with the security for value and interest, unless otherwise ordered. LAR(f)(2) Order of Proof at Trial Where the vessel interests seeking statutory limitation of liability have raised the statutory defense by way of answer or complaint, the plaintiff in the former or the party asserting a claim against the vessel or owner in the latter shall proceed with its proof first, as is normal at civil trials.

U.S. District Court of Maryland Local Rules (December 1, 2025) 108 APPENDIX A APPENDIX A DISCOVERY GUIDELINES OF THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND Guideline 1: Conduct of Discovery a. The purpose of these Guidelines is to facilitate the just, speedy, and inexpensive conduct of discovery in civil cases before the Court, and these Guidelines will be construed and administered accordingly, with respect to all attorneys, parties, and non-parties involved in discovery of civil cases before the Court. Fed R. Civ. P. 26 requires that discovery be relevant to any party’s claim or defense; proportional to what is at issue in a case; and not excessively burdensome or expensive as compared to the likely benefit of obtaining the discovery being sought. The parties and counsel have an obligation to cooperate in planning and conducting discovery to tailor the discovery to ensure that it meets these objectives. Counsel have a duty to confer early and throughout the case as needed to ensure that discovery is planned and conducted consistent with these requirements and, where necessary, make adjustments and modifications in discovery as needed.

During the course of their consultation, counsel are encouraged to think creatively and to make proposals to one another about alternatives or modifications to the discovery otherwise permitted that would permit discovery to be completed in a more just, speedy, inexpensive way. By way of illustration only, such alternatives could include different or additional deadlines for the filing of motions or the completion of all or part of discovery; accelerated exchanges of disclosures, additional data, or descriptions of the parties’ claims and defenses; sampling techniques; and substantial limitations on, or even the elimination of, depositions, coupled with alternative methods of exchanging or obtaining factual information or the equivalent of deposition testimony. b. The parties and their counsel are encouraged to submit to the Court for approval their agreements to expand or limit discovery. If, however, counsel are unable to reach agreement on a discovery plan that substantially modifies the normal course of discovery, and either side believes that the Court’s assistance would be helpful in framing or implementing such a plan, then the Court will make itself available with reasonable promptness, in response to a brief, written request for a discovery management conference that identifies the issues for consideration. c. Counsel are expected to have read the Federal Rules of Civil Procedure, Local Rules of the Court, these Guidelines, and, with respect to discovery of electronically stored information, the Principles for the Discovery of Electronically Stored Information in Civil Cases, posted on the Court’s website, www.mdd.uscourts.gov. Compliance with these U.S. District Court of Maryland Local Rules (December 1, 2025) 109 APPENDIX A Guidelines will be considered by the Court in resolving discovery disputes, including whether sanctions should be awarded pursuant to Fed. R. Civ. P. 37, or the Court’s inherent powers. d. Attorneys are expected to behave professionally and with courtesy towards all involved in the discovery process, including but not limited to opposing counsel, parties, and non-parties.

This includes cooperation and civil conduct in an adversary system. Cooperation and civility include, at a minimum, being open to, and reasonably available for, discussion of legitimate differences in order to achieve the just, speedy, and inexpensive resolution of the action and every proceeding. Cooperation and communication can reduce the costs of discovery, and they are an obligation of counsel. e. All discovery requests, responses, and objections are governed by the requirements of Fed. R. Civ. P. 26(g) and counsel and parties are expected to be familiar with the requirements of the Rule. f. Whenever possible, attorneys are expected to communicate with each other in good faith throughout the discovery process to resolve disputes without the need for intervention by the Court, and should do so promptly after becoming aware of the grounds for the dispute. In the event that such good faith efforts are unsuccessful, an unresolved dispute should be brought to the Court’s attention promptly after efforts to resolve it have been unsuccessful.

A failure to do so may result in a determination by the Court that the dispute must be rejected as untimely. Counsel may bring the unresolved dispute to the Court’s attention by filing a letter, in lieu of a written motion, that briefly describes the dispute, unless otherwise directed by the Court. g. Upon being notified by the parties of the unresolved discovery dispute, the Court will promptly schedule a conference call with counsel, or initiate other expedited procedures, to consider and resolve the discovery dispute. If the Court determines that the issue is too complicated to resolve informally, it may set an expedited briefing schedule to ensure that the dispute can be resolved promptly. h. To the extent that any part of these Guidelines conflicts with any Local Rule of the Court, or an order of the Court in a particular case, then the conflicting rule or order should be considered to be governing. Guideline 2: Stipulations Setting Discovery Deadlines Subject to approval by the Court, attorneys are encouraged to enter into written discovery stipulations to supplement the Court’s scheduling order.

During the scheduling process, the Court will consider requests to impose milestone dates for motions, such as spoliation motions, and motions in limine (including Daubert motions) that do not normally otherwise have automatically-imposed deadlines. The Court encourages parties to submit to U.S. District Court of Maryland Local Rules (December 1, 2025) 110 the Court for approval joint suggestions made pursuant to the Principles for the Discovery of Electronically Stored Information in Civil Cases. Guideline 3: Expert Witnesses APPENDIX A a. Unless counsel agree that each party will pay its own experts, the party taking an expert witness’s deposition ordinarily pays the expert’s fees for the time spent in deposition and related travel. See L.R. 104.11.a. Accordingly, counsel for the party that designated the expert witness should try to assure that the fee charged by the expert to the party taking the deposition is fair and reasonable.

In the event a dispute arises as to the reasonableness or other aspects of an expert’s fee, counsel should promptly confer and attempt in good faith to resolve the dispute without the involvement of the Court. If counsel are unsuccessful, the expert’s deposition should proceed on the date noted, unless the Court orders otherwise, and the dispute respecting payment should be brought to the Court’s attention promptly. The factors that may be considered in determining whether a fee is reasonable include, but are not limited to: (1) the expert’s area of expertise; (2) the expert’s education and training; (3) the fee being charged to the party who designated the expert; and (4) the fees ordinarily charged by the expert for non-litigation services, such as office consultations with patients or clients. b. Recognizing that a treating physician may be considered both a fact witness and an expert, the Court has chosen to impose a specific limitation on the fee a treating physician may charge to either party. It is implicit in L.R. 104.11.b, which requires counsel to estimate the hours of deposition time required, that the physician may charge a fee for the entire time he or she reserved in accordance with the estimate, even if counsel conclude the deposition early.

Further, unless the physician received notice at least two business days in advance of a cancellation, the physician is entitled to be paid for any time reserved that cannot reasonably be filled. Every effort should be made to schedule depositions at a time convenient for the witness, and to use videotaped or other visually recorded de bene esse depositions rather than requiring the physician’s presence at trial. Note that this Discovery Guideline does not limit the reasonable fee a treating physician may charge if required to testify in Court. c. The parties are encouraged not to designate multiple experts on the same or similar topics. d. Guideline 4.d is applicable to expert witness depositions. Guideline 4: Scheduling Depositions a. Attorneys are expected to make a good faith effort to coordinate deposition dates with opposing counsel, parties, and non-party deponents, before noting a deposition.

U.S. District Court of Maryland Local Rules (December 1, 2025) 111 APPENDIX A b. Before agreeing to a deposition date, an attorney is expected to attempt to clear the date with his/her client if the client is a deponent, or wishes to attend the deposition, and with any witnesses the attorney agrees to attempt to produce at the deposition without the need to have the witness served with a subpoena. c. An agreed-upon deposition date is presumptively binding. An attorney seeking to change an agreed-upon date has a duty to coordinate a new date before changing the agreed date. Noncompliance with Guideline 4.d may rebut the presumption contained herein. d. If an attorney making a good faith effort to coordinate deposition dates under Guideline 4.a anticipates requesting that the deponent produce electronically stored informed at the deposition, that anticipated request should be disclosed to the opposing counsel, parties, and non-party deponents at the time of the Guideline 4.a coordination effort, or as soon thereafter as it becomes anticipated. At a minimum, the discovering/requesting party should describe the scope and form of electronically stored information that will be requested.

Counsel are encouraged to review and, if applicable, comply with the Principles for the Discovery of Electronically Stored Information in Civil Cases. e. Upon reasonable request, and where reasonably practicable, in order to expedite the deposition questioning, a deponent should produce documents including electronically stored information, properly requested in a notice of deposition and accompanying subpoena, if any, a reasonable time prior to the deposition. Noncompliance with a reasonable and timely request for production of such documents prior to a deposition may be considered by the Court in a motion or request made pursuant to Fed. R. Civ. P. 30(d)(1) to determine whether additional time is needed to fairly examine the deponent or if the deponent, another person, or any other circumstance has impeded or delayed the examination. Guideline 5: Designation by an Organization of Someone to Testify on Its Behalf a. A Fed. R. Civ. P. 30(b)(6) deposition notice or subpoena to a public or private corporation, partnership, association, governmental agency, or other entity should describe with reasonable particularity the matters for examination. The serving party should consider listing the matters for examination in a manner that groups related topics together. b. Before or promptly after serving a notice or subpoena pursuant to Fed. R. Civ. P. 30(b)(6), the serving party and the organization to be deposed must confer in good faith about the matters for examination. c. A subpoena to a nonparty organization must advise the nonparty organization of its duty to confer with the serving party and to designate each person who will testify.

U.S. District Court of Maryland Local Rules (December 1, 2025) 112 APPENDIX A d. Depending on the circumstances of the case and content of the conference, the participants should consider engaging in more than one conference. e. The purpose of the description of matters for examination and conference(s) should be to focus the examination and preparation of the designated witness or witnesses. f. In the good faith conference or conferences pursuant to subsections (b) and (d), the parties should meet in person or by video or telephonic means for a reasonable period of time to discuss the description of the matters for examination and whether they have been described with reasonable particularity, as well as any objections to those descriptions. In addition to any other relevant factors, the parties may consider the nature, business, size, and complexity of the organization being asked to testify, and should consider the proportionality factors in Fed. R. Civ. P. 26(b). g. The named organization must designate one or more officers, directors, or managing agents, or designate other persons who consent to testify on its behalf. The parties may choose to discuss the identity or identities of the designee or designees who will testify if the parties deem it reasonable and appropriate to voluntarily do so. The choice of designee or designees should remain with the organization designating the witness.

The named organization should identify the specific topics or groups of topics on which each designated witness will testify. The designating organization should make a diligent inquiry to determine which individual(s) is (are) best suited to testify. h. In many circumstances, it may be reasonable for the named organization to make a subsection (g) designation only after a subsection (b) conference or conferences. i. If the parties are unable to resolve a dispute or disputes under subsection (f), the parties may consider presenting the dispute or disputes to the Court prior to the deposition. j. Guideline 5 does not preclude a deposition by any other procedure allowed by the Federal Rules of Civil Procedure. k. Guideline 5 does not apply to a deposition under Fed. R. Civ. P. 31(a)(4). Guideline 6: Deposition Questioning, Objections, and Procedure a. An attorney should not intentionally ask a witness a question that misstates or mischaracterizes the witness’s previous answer. b. During the taking of a deposition, it is presumptively improper for an attorney to make objections which are not consistent with Fed. R. Civ. P. 30(c)(2). Objections should be stated as simply, concisely, and non-argumentatively as possible to avoid coaching or making suggestions to the deponent, and to minimize interruptions in the questioning of the deponent (for example: “objection, leading;” “objection, asked and answered;” “objection, U.S. District Court of Maryland Local Rules (December 1, 2025) 113 APPENDIX A compound question;” “objection, form”).

If an attorney desires to make an objection for the record during the taking of a deposition that reasonably could have the effect of coaching or suggesting to the deponent how to answer, then the deponent, at the request of any of the attorneys present, or, at the request of a party if unrepresented by an attorney, should be excused from the deposition during the making of the objection. c. An attorney should not repeatedly ask the same or substantially identical question of a deponent if the question already has been asked and fully and responsively answered by the deponent. Upon objection by counsel for the deponent, or by the deponent if unrepresented, it is presumptively improper for an attorney to continue to ask the same or substantially identical question of a witness unless the previous answer was evasive or incomplete. d. It is presumptively improper to instruct a witness not to answer a question during the taking of a deposition unless under the circumstances permitted by Fed. R. Civ. P. 30(c)(2). However, it is also presumptively improper to ask questions clearly beyond the scope of discovery permitted by Fed. R. Civ. P. 26(b)(1), particularly of a personal nature, and continuing to do so after objection shall be evidence that the deposition is being conducted in bad faith or in such a manner as unreasonably to annoy, embarrass, or oppress the deponent or party, which is prohibited by Fed. R. Civ. P. 30(d)(3). e. If requested to supply an explanation as to the basis for an objection, the objecting attorney should do so, consistent with Guideline 6(b) above. f. While the interrogation of the deponent is in progress, neither an attorney nor the deponent should initiate a private conversation except for the purpose of determining whether a privilege should be asserted. To do so otherwise is presumptively improper. g. During breaks in the taking of a deposition, no one should discuss with the deponent the substance of the prior testimony given by the deponent during the deposition.

Counsel for the deponent may discuss with the deponent at such time whether a privilege should be asserted or otherwise engage in discussion not regarding the substance of the witness’s prior testimony. h. Unless otherwise ordered by the Court, the following persons may, without advance notice, attend a deposition: individual parties, a representative of non-individual parties, and expert witnesses of parties. Except for the persons identified above, counsel should notify other parties not later than seven (7) days before the taking of a deposition if counsel desires to have a non-party present during a deposition. If the parties are unable to agree to the attendance of this person, then the person shall not be entitled to attend the deposition unless the party desiring to have the person attend obtains a court order permitting him/her to do so. Unless ordered by the Court, however, a dispute regarding who may attend a deposition should not be grounds for delaying the deposition.

All persons present during U.S. District Court of Maryland Local Rules (December 1, 2025) 114 APPENDIX A the taking of a deposition should be identified on the record before the deposition begins. Other than the deponent, counsel representing a party or unrepresented party, persons attending a deposition may not ask or answer questions during, or otherwise participate in the process of, the deposition. i. Except for the person recording the deposition in accordance with Fed. R. Civ. P. 30(b), during the taking of a deposition no one may record the testimony without the consent of the deponent and all parties in attendance, unless otherwise ordered by the Court. Guideline 7: Assertions of Privilege at Depositions a. When a claim of privilege is asserted during a deposition, and information is not provided on the basis of such assertion: b. In accordance with Fed. R. Civ. P. 26(b)(5), the person asserting the privilege should identify during the deposition the nature of the privilege (including work product) that is being claimed. c. After a claim of privilege has been asserted, the person seeking disclosure should have reasonable latitude during the deposition to question the witness to establish other relevant information concerning the assertion of privilege, including (i) the applicability of the particular privilege being asserted; (ii) any circumstances that, under Fed. R. Evid. 502, may demonstrate that a prior disclosure was or was not permitted without waiver of the privilege; (iii) any circumstances that may constitute an exception to the assertion of the privilege; and (iv) any circumstances which may result in the privilege having been waived. d. In accordance with Fed. R. Civ. P. 26(b)(5), the party asserting the privilege, in providing the foregoing information, should not be required to reveal the information that is itself privileged or protected from disclosure. Guideline 8: Making a Record of Improper Conduct During a Deposition Upon request of any attorney, party unrepresented by an attorney, or the deponent if unrepresented by an attorney, the person recording the deposition in accordance with Fed. R. Civ. P. 30(b) should enter on the record a description by the requesting person of conduct of any attorney, party, or person attending the deposition which violates these Guidelines, the Federal Rules of Civil Procedure, or the Local Rules of the Court.

Guideline 9: Delay in Responding to Discovery Requests a. Interrogatories, Requests for Production of Documents, and Requests for Admission of Facts and Genuineness of Documents U.S. District Court of Maryland Local Rules (December 1, 2025) 115 APPENDIX A The Federal Rules of Civil Procedure designate the time prescribed for responding to Interrogatories, Requests for Production of Documents, and Requests for Admission of Facts and Genuineness of Documents. Nothing contained in these Guidelines modifies the time limits prescribed by the Federal Rules of Civil Procedure. Attorneys should make good faith efforts to respond to discovery requests within the time prescribed by those rules. Absent exigent circumstances, attorneys seeking additional time to respond to discovery requests should contact opposing counsel as soon as practical after receipt of the discovery request, but not later than three (3) days before the response is due.

In multiple party cases, the attorney wanting additional time should contact the attorney for the party propounding the discovery. A request for additional time which does not conflict with a scheduling deadline imposed by the Federal Rules of Civil Procedure, the Local Rules of the Court, or a court order should not be unreasonably refused. If a request for additional time is granted, the requesting party should promptly prepare a writing which memorializes the agreement, which shall be served on all parties but need not be submitted to the Court for approval. Unless otherwise provided by the Local Rules of the Court, no stipulation that modifies a court-imposed deadline shall be deemed effective unless and until the Court approves the stipulation. b. Depositions Unless otherwise ordered by the Court or agreed upon by the parties, fourteen (14) days’ notice should be deemed to be “reasonable notice” within the meaning of Fed. R. Civ. P. 30(b)(1) for the noting of depositions.

Guideline 10: Interrogatories, Requests for Production of Documents, Answers to Interrogatories, and Written Responses to Document Requests a. A party may object to an interrogatory, document request, or part thereof, while simultaneously providing partial or incomplete answers to the request. If a partial or incomplete answer is provided, the answering party shall state that the answer is partial or incomplete. b. No part of an interrogatory or document request should be left unanswered merely because an objection is interposed to another part of the interrogatory or document request. c. In cases where a party is represented by more than one attorney of record, no discovery motion, response, or opposition should be filed unless a senior attorney of record has read the contents of the motion and any supporting memorandum and exhibits. U.S. District Court of Maryland Local Rules (December 1, 2025) 116 d. In accordance with Fed. R. Civ. P. 26(b)(5), where a claim of privilege is asserted objecting to any interrogatory, document request, or part thereof, and information is not provided on the basis of such assertion: APPENDIX A i. The party asserting the privilege shall, in the objection to the interrogatory, document request, or part thereof, identify with specificity the nature of the privilege (including work product) that is being claimed. ii. The following information should be provided in the objection, if known or reasonably available, unless divulging such information would cause disclosure of the allegedly privileged information: a. For oral communications: (i) the name of the person making the communication and the names of persons present while the communication was made, and, where not apparent, the relationship of the persons present to the person making the communication; (ii) the date and place of the communication; and (iii) the general subject matter of the communication. b. For documents: (i) (ii) the type of document; the general subject matter of the document; (iii) the date of the document; and (iv) such other information as is sufficient to identify the document, including, where appropriate, the author, addressee, custodian, and any other recipient of the document, and, where not apparent, the relationship of the author, addressee, custodian, and any other recipient to each other. iii.

The above information should be provided separately for each document for which privilege/protection is asserted, unless doing so would be excessively burdensome or expensive. In such instances, the party asserting privilege/protection should particularize why providing separate designations would be excessively burdensome or expensive, and then may identify by categories the voluminous documents or communications for which privilege/protection is asserted, providing U.S. District Court of Maryland Local Rules (December 1, 2025) 117 APPENDIX A the above information for each category. A party may only designate documents as privileged/protected by category if each document (1) is within the privilege/protection claimed and (2) shares common characteristics such as sender, receiver, author, or specific subject matter. Where only part of a document or communication is privileged/protected, the unprivileged/unprotected portion should be disclosed if otherwise discoverable and within the scope of the discovery request. iv.

Reasonably promptly after receiving the information contained in Guideline 10.d.ii., the party seeking disclosure should notify the party from whom disclosure is sought of any deficiencies in the particularization of the basis for any privilege/protection asserted, including any “category designations” under Guideline 10.d.iii. Once done, the party from whom disclosure was sought shall, with reasonable promptness, provide sufficient factual information, including by affidavit, to establish the factual basis for each claim of privilege or protection that has been claimed. Failure to do so may result in a determination by the Court that the party asserting the privilege or work product protection has failed to particularize it as required by Fed. R. Civ. P. 26(b)(5), resulting in the waiver of any privilege/protection that has been claimed. v. The parties are encouraged to confer and reach agreement regarding how to assert privilege/protection claims with respect to email “chains” or “strings,” and if unable to do so, to bring to the attention of the Court their disagreement for prompt resolution. e. If a party asserts in response to an interrogatory, request for production of documents, or request for admission of facts, that electronically stored information is not reasonably accessible because of undue burden or cost, within the meaning of Fed. R. Civ. P. 26(b)(2)(B), or otherwise asserts that requested discovery is unduly burdensome or expensive, the party making that assertion is expected to disclose, promptly and with particularity, the facts on which it relies to support that contention. f. In addition to paper copies, parties are encouraged to exchange discovery requests and responses in a commonly-accepted word processing format, if requested, in order to reduce the clerical effort required to prepare responses and motions. U.S. District Court of Maryland Local Rules (December 1, 2025) 118 APPENDIX B APPENDIX B RULES AND GUIDELINES FOR DETERMINING ATTORNEYS’ FEES IN CERTAIN CASES* 1.

Mandatory Rules Regarding Billing Format, Time Recordation, and Submission of Quarterly Statements a. Time shall be recorded by specific task and lawyer or other professional performing the task as set forth more fully in L.R. 109.1.b. b. Fee applications, accompanied by time records, shall be submitted in the following format organized by litigation phase:† i. case development, background investigation, and case administration (includes initial investigations, file setup, preparation of budgets, and routine communications with client, co-counsel, opposing counsel, and the Court); ii. pleadings; iii. interrogatories, document production, and other written discovery; iv. depositions (includes time spent preparing for depositions); v. motions practice; vi. attending court hearings; vii. trial preparation and post-trial motions; viii. attending trial; * These rules and guidelines apply to cases in which a prevailing party would be entitled, by applicable law or contract, to reasonable attorneys’ fees based on a set of criteria including hours and rates. They do not apply to cases in which statutes or contracts authorize fees based on a fixed percentage or other formula, such as social security and Prisoner Litigation Reform Act cases. †In general, preparation time and travel time should be reported under the category to which they relate. For example, time spent preparing for and traveling to and from a court hearing should be recorded under the category “court hearings.” Factual investigation should also be listed under the specific category to which it relates. For example, time spent with a witness to obtain an affidavit for a summary judgment motion or opposition should be included under the category “motions practice.” Similarly, a telephone conversation or a meeting with a client held for the purpose of preparing interrogatory answers should be included under the category “Interrogatories, Document Production, and Other Written Discovery.” Of course, each of these tasks must be separately recorded in the back-up documentation in accordance with Guideline 1.a. U.S. District Court of Maryland Local Rules (December 1, 2025) 119 APPENDIX B ix.

ADR; x. fee petition preparation; and xi. time spent on appeals. c. Counsel for the parties are encouraged to meet and confer (preferably within fifteen (15) days of the issuance of the court’s scheduling order) to discuss their intent to seek fees. The parties are to discuss: i. Whether counsel for the party intending to seek fees will submit to opposing counsel periodic (but no more frequently than quarterly) statements showing the amount of time spent on the case and the total value of that time. ii. Whether the parties will stipulate to the rate guidelines set forth in Section 3 of this Appendix or to any other rates counsel for a party intending to seek fees may propose. d. Counsel for a party intending to seek fees if the party prevails is encouraged, but not required, to submit to opposing counsel a current statement of fees during the meeting described in Guideline 1.c. The failure to submit a statement of fees to opposing counsel at that meeting shall not be considered as a factor in determining whether to award fees pursuant to a fee petition. e. Counsel for a party intending to seek fees if the party prevails shall provide fee statements to opposing counsel, if requested.* These statements shall reflect the amount of fees and number of hours worked to date. The statements need not be in the “litigation phase” format provided in Guideline 1.b. or otherwise reflect how time has been spent.

Reasonable time spent compiling these statements may be compensable if a prevailing party succeeds in obtaining fees. f. Upon request by the judge (or private mediator agreed upon by the parties) presiding over a settlement conference, counsel for all parties (with the exception of public lawyers who do not ordinarily keep time records) shall turn over to that officer (or mediator) statements of time and the value of that time in the “litigation phase” format provided in Guideline 1.b. * A party may not seek a denial or reduction of fees on the ground that periodic fee statements were not provided to their counsel if counsel did not first request that such statements be provided. U.S. District Court of Maryland Local Rules (December 1, 2025) 120 APPENDIX B g. If during the course of a fee award dispute, a judge orders that the billing records of counsel for the party opposing fees must be turned over to the party requesting fees, those billing records shall be submitted in the “litigation phase” format. 2. Guidelines Regarding Compensable and Non-Compensable Time When considering whether time is compensable, the Court may consider the following factors:* a. The time and labor required for a given activity or task; b. The novelty and difficulty of the questions at issue in the case; c. The skill requisite to perform the legal service properly; d. Time limitations imposed by the client or other circumstances; e. The amount involved and the results obtained; f. The need for more than one attorney to attend a proceeding; and g. The necessity for travel: i. Whenever possible time spent in traveling should be devoted to doing substantive work for a client and should be billed (at the usual rate) to that client.

If the travel time is devoted to work for a client other than the matter for which fees are sought, then the travel time should not be included in any fee request. If the travel time is devoted to substantive work for the client whose representation is the subject of the fee request, then the time should be billed for the substantive work, not travel time. ii. Up to two (2) hours of travel time (each way and each day) to and from a court appearance, deposition, witness interview, or similar proceeding that cannot be devoted to substantive work may be charged at the lawyer’s hourly rate. iii. Time spent in long-distance travel above the two (2) hours limit each way, that cannot be devoted to substantive work, may be charged at one-half of the lawyer’s hourly rate.

The above list of factors is not exhaustive. * The first five factors were enumerated by the Fifth Circuit in Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974), and adopted by the Fourth Circuit, see e.g., McAfee v. Boczar, 738 F.3d 81 (4th Cir. 2013). Should the case law on the relevant factors vary in the future, the prevailing case law shall apply and govern the Court’s analysis.

U.S. District Court of Maryland Local Rules (December 1, 2025) 121 APPENDIX B 3. Guidelines Regarding Hourly Rates Reasonable hourly rates should be determined by the Court using declarations, affidavits, stipulations by the parties, or other evidence. A useful guideline for hourly rates may be provided by the Fitzpatrick Matrix* as adjusted annually, with a reduction of 5% to 20% (to reflect differences between the legal markets in Washington, D.C. and Maryland). These guideline rates are intended solely to provide practical guidance to lawyers and judges when requesting, challenging, and awarding fees.

The factors established by case law govern. These guidelines do not create any presumptions regarding reasonable rates. The Court recognizes that a fee award should be determined in accordance with relevant case law.† 4. Reimbursable Expenses a. Generally, reasonable out-of-pocket expenses (including long-distance telephone calls, express and overnight delivery services, computerized online research, and faxes) are compensable at actual cost. b. Mileage is compensable at the rate of reimbursement for official government travel in effect at the time the expense was incurred. c. Copy work is compensable at the rate established by the Court for taxation of costs. * The Fitzpatrick Matrix is available at https://www.mdd.uscourts.gov/sites/mdd/files/fitzpatrick-matrix.pdf † See, e.g., Blum v. Stenson, 465 U.S. 886 (1984); Hensley v. Eckerhart, 461 U.S. 424 (1983); De Paredes v. Zen Nails Studio LLC, 134 F.4th 750 (4th Cir.

2025); Rum Creek Coal Sales, Inc. v. Caperton, 31 F.3d (4th Cir. 1994). Should the case law vary in the future, the prevailing case law shall apply and govern the Court’s analysis. U.S. District Court of Maryland Local Rules (December 1, 2025) 122 APPENDIX C APPENDIX C REGULATIONS GOVERNING THE REIMBURSEMENT OF EXPENSES IN PRO BONO CASES IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND I. Eligibility for Reimbursement When an attorney has been appointed to represent an indigent party in a civil case before this Court, that attorney shall be allowed to petition the Court for reimbursement of certain expenses, incurred in the preparation and presentation of the case, subject to these regulations.

The limit applicable to such expenses, unless otherwise requested by counsel and approved by the Court’s Attorney Admissions Fund Committee, is fifteen thousand dollars ($15,000). During the representation, the Court may request that counsel prepare and propose for approval a budget of anticipated expenses. Counsel shall prepare and propose for approval a budget of anticipated expenses whenever counsel reasonably expects that total expenses will exceed $15,000. II.

Restrictions on Eligibility Any costs that are either waived or recoverable under the provisions of Title 18, U.S. Code or Title 28, U.S. Code, or which have been otherwise recovered shall not be reimbursed from the Admissions Fund. In no case shall an appointed attorney for a party who has been awarded costs and/or fees pursuant to a judgment in a suit before this Court be eligible for reimbursement of those costs and/or fees from the Admissions Fund. Only those costs associated with the preparation or presentation of a civil action in the United States District Court for the District of Maryland shall be approved for reimbursement. No costs associated with the preparation or presentation of an appeal to the U.S. Court of Appeals or the U.S. Supreme Court shall be reimbursed from the Admissions Fund.

III.

Procedures for Petitioning for Reimbursement A. Within thirty (30) days of the entry of a judgment, the appointed attorney shall file with the judge a request for reimbursement of costs on a form approved by the Court and available from the Clerk. Where it is considered necessary and appropriate, the judge may approve an interim reimbursement of extraordinary and substantial expenses. B. In cases in which an appointed attorney has withdrawn or has been dismissed prior to the entry of a judgment, that attorney shall file a request for reimbursement within thirty (30) days of such withdrawal or dismissal. Any work product obtained with expenditures U.S. District Court of Maryland Local Rules (December 1, 2025) 123 APPENDIX C from the Admissions Fund shall subsequently be provided to the newly-appointed counsel or, where no new counsel is appointed, to the party for whom counsel was appointed.

In cases where interim reimbursements are approved and paid and appointed counsel subsequently recovers previously reimbursed expenses, counsel shall, within thirty (30) days from said recovery, return to the Admissions Fund an amount up to the amount previously reimbursed, depending on the amount of the recovery. IV. Reimbursable Expenses The following out-of-pocket expenses may be reimbursed upon approval by the judge: 1. Depositions and Transcripts The costs of depositions and transcripts may be reimbursed up to the rates, and subject to the limitations, established by the Court for the taxation of costs.

2. Investigative, Expert, or Other Services A. Counsel may request (in an ex parte application) investigative, expert, or other services necessary for the adequate preparation of a matter. The Court, upon finding after appropriate ex parte inquiry that the services are necessary, may authorize them. B. Without prior request, counsel may obtain, subject to later review, investigative, expert, or other services necessary for the adequate preparation of the case.

Counsel should note that approval of this type of expenditure is not automatic and should be prepared to defend his/her reasons for not requesting prior approval. 3. Travel Expenses Travel may be reimbursed at actual cost if public transportation is used, or if a private vehicle is used, at the rate of reimbursement for official government travel in effect at the time the expense was incurred, plus parking, tolls, and similar expenses. 4.

Service/Witness Fees Service and witness fees that are not otherwise avoided, waived, or recoverable may be reimbursed from the Admissions Fund. 5. Interpreter Services Costs of interpreter services not otherwise avoided, waived, or recoverable may be reimbursed from the Admissions Fund. U.S. District Court of Maryland Local Rules (December 1, 2025) 124 APPENDIX C 6.

Photocopies, Photographs, Telephone Long Distance Calls, etc. Actual out-of-pocket expenses incurred for items such as photographs, long distance calls, express and overnight delivery services, and computerized online research necessary for the preparation of the case may be reimbursed from the Admissions Fund. Copy work may be reimbursed at the rate established by the Court for taxation of costs. 7. Other Expenses Expenses other than those in sections one through six, above, may be approved by the judge.

When requesting reimbursement under this section, a detailed description of the expenses should be attached to the petition filed with the judge. V. Restrictions on Reimbursement A. General office overhead is not reimbursable from the Admissions Fund. B. The judge may disallow reimbursement for any expense that is not documented. C. The judge may disallow reimbursement of expenses if he or she determines that appointed counsel did not pursue reasonable courses of recovery of expenses, including seeking statutorily permitted costs and fees, prior to application for reimbursement from the Admissions Fund.

D. Under no circumstances shall Admissions Fund funds be authorized to pay for costs or fees taxed against a party or appointed counsel, as a result of a court ruling or as part of a judgment obtained by an adverse party in a civil action before this Court. U.S. District Court of Maryland Local Rules (December 1, 2025) 125 STANDARD FORMS APPENDIX D Guidelines for Uniform Instructions and Definitions for Use in Discovery Requests APPENDIX D These Guidelines set forth the full text of instructions and definitions for Interrogatories and Requests for Production of Documents. Parties may use any instructions, definitions, or rules of construction that are consistent with the Federal Rules of Civil Procedure. This Court has stated that the use of reasonable definitions may be helpful.

Diversified Products Corp. v. Sports Center Co., 42 F.R.D. 3, 4 (D. Md. 1967). This Court has also stated that unreasonable definitions may render interrogatories so burdensome that objections to the entire series should be sustained, with sanctions. Id. “[L]awyers customarily serve requests that are far broader, more redundant and burdensome than necessary to obtain sufficient facts to enable them to resolve the case through motion, settlement or trial.” Mancia v. Mayflower Textile Servs.

Co., 253 F.R.D. 354, 358 (D. Md. 2008). The purpose of the Guidelines is to provide a presumptively proper “safe harbor.” The Guidelines are appropriate for many cases and their use is encouraged. The Guidelines may not be appropriate in certain cases and Rule 26(g) requires the exercise of independent professional judgment in propounding discovery.

The use of these forms is purely and wholly optional. If they are used, the Court will likely consider them presumptively proper and a party objecting to them will have the burden of demonstrating that they are not proper. Compliance with the Guidelines will be considered by the Court in resolving discovery disputes, including whether sanctions should be awarded pursuant to Fed. R. Civ. P. 37. The Guidelines are not intended to broaden or narrow the scope of discovery permitted by the Federal Rules of Civil Procedure.

The Instructions and Definitions of the Guidelines may be incorporated into a party’s Interrogatories or Request for Production of Documents by the following statement: “The Uniform Instructions and Definitions for Use in Discovery Requests are incorporated herein.” If this statement, or a substantially similar statement, is placed in the party’s Interrogatories or Request for Production of Documents, the Court will deem the Instructions and Definitions of these Guidelines to be incorporated by reference therein. If a specific discovery request is incorporated without modification into a party’s Interrogatories or Request for Production of Documents, the request should state “(Standard Interrogatory No. __)” or “(Standard Document Request No. ___).” U.S. District Court of Maryland Local Rules (December 1, 2025) 126 APPENDIX D Standard Interrogatories _____________________, IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND * Plaintiff * v. * Civil Action No.:________________ ______________________, Defendant * * * * * * * * * * * * * INTERROGATORIES Pursuant to Fed. R. Civ. P. 33, L.R. 104, and Appendix A to the Local Rules (Discovery Guidelines), ________________________, by its undersigned attorneys, propounds these Interrogatories, to which ________________________ shall respond separately and fully, in writing and under oath, within the time prescribed by the Federal Rules of Civil Procedure, in accordance with the Instructions and Definitions set forth hereinafter.

INSTRUCTIONS 1.

These instructions and definitions should be construed to require answers based upon the knowledge of, and information available to, the responding party as well as its agents, representatives, and, unless privileged, attorneys. It is intended that the following discovery requests will not solicit any information protected either by the attorney/client privilege or work product doctrine which was created or developed by, counsel for the responding party after the date on which this litigation was commenced. If any inquiry is susceptible of a construction which calls for the production of such information, that material need not be provided and no privilege log pursuant to Fed. R. Civ. P. 26(b)(5) or Discovery Guideline 10(d) will be required as to such information. U.S. District Court of Maryland Local Rules (December 1, 2025) 127 APPENDIX D 2.

These Interrogatories are continuing in character, so as to require that supplemental answers be filed seasonably if further or different information is obtained with respect to any interrogatory. 3. Pursuant to Discovery Guideline 10(b), no part of an interrogatory should be left unanswered merely because an objection is interposed to another part of the interrogatory. Pursuant to Discovery Guideline 10(a), if a partial or incomplete answer is provided, the responding party shall state that the answer is partial or incomplete.

4. Pursuant to Discovery Guideline 10(d), in accordance with Fed. R. Civ. P. 26(b)(5), where a claim of privilege is asserted in objecting to any interrogatory or part thereof, and information is not provided on the basis of such assertion: A. In asserting the privilege, the responding party shall, in the objection to the interrogatory, or part thereof, identify with specificity the nature of the privilege (including work product) that is being claimed. B. The following information should be provided in the objection, if known or reasonably available, unless divulging such information would cause disclosure of the allegedly privileged information: (1) For oral communications: a. the name of the person making the communication and the names of persons present while the communication was made, and, where not apparent, the relationship of the persons present to the person making the communication; b. c. the date and place of the communication; and the general subject matter of the communication. U.S. District Court of Maryland Local Rules (December 1, 2025) 128 APPENDIX D (2) For documents: a. b. c. d. the type of document, the general subject matter of the document, the date of the document, and such other information as is sufficient to identify the document, including, where appropriate, the author, addressee, custodian, and any other recipient of the document and, where not apparent, the relationship of the author, addressee, custodian, and any other recipient to each other.

5. If the responding party elects to specify and produce business records in answer to any interrogatory, the specification shall be in sufficient detail to permit the interrogating party to locate and identify, as readily as the responding party can, the business records from which the answer may be ascertained or, if produced electronically, produced in a manner consistent with Guideline 2.04 of the ESI Principles. 6. If, in answering these Interrogatories, the responding party encounters any ambiguities when construing a question, instruction, or definition, the responding party’s answer shall set forth the matter deemed ambiguous and the construction used in answering.

DEFINITIONS

Notwithstanding any definition below, each word, term, or phrase used in these Interrogatories is intended to have the broadest meaning permitted under the Federal Rules of Civil Procedure. 1. Concerning: The term “concerning” means relating to, referring to, describing, evidencing, or constituting. U.S. District Court of Maryland Local Rules (December 1, 2025) 129 APPENDIX D 2.

Communication: The term “communication” means the transmittal of information by any means. 3. Document: The terms “document” and “documents” are defined to be synonymous in meaning and equal in scope to the term “items” in Fed. R. Civ. P. 34(a)(1) and include(s), but is not limited to, electronically stored information. The terms “writings,” “recordings,” and “photographs” are defined to be synonymous in meaning and equal in scope to the usage of those terms in Fed. R. Evid. 1001.

A draft or non-identical copy is a separate document within the meaning of the term “document.” 4. Identify (with respect to persons): When referring to a person, to “identify” means to state the person’s full name, present or last known address, and, when referring to a natural person, the present or last known place of employment. If the business and home telephone numbers are known to the answering party, and if the person is not a party or present employee of a party, said telephone numbers shall be provided. Once a person has been identified in accordance with this subparagraph, only the name of the person need be listed in response to subsequent discovery requesting the identification of that person.

5. Identify (with respect to documents): When referring to documents, to “identify” means to state the: (i) type of document; (ii) general subject matter; (iii) date of the document; and, (iv) author(s), addressee(s), and recipient(s) or, alternatively, to produce the document. 6. Occurrence/Transaction: The terms “occurrence” and “transaction” mean the events described in the Complaint and other pleadings, as the word “pleadings” is defined in Fed. R. Civ. P. 7(a).

7. Parties: The terms “plaintiff ” and “defendant” (including, without limitation, third- party plaintiff, third-party defendant, counter claimant, cross-claimant, counter-defendant, and cross-defendant), as well as a party’s full or abbreviated name or a pronoun referring to a party, U.S. District Court of Maryland Local Rules (December 1, 2025) 130 APPENDIX D mean that party and, where applicable, its officers, directors, and employees. This definition is not intended to impose a discovery obligation on any person who is not a party to the litigation or to limit the Court’s jurisdiction to enter any appropriate order. 8.

Person: The term “person” is defined as any natural person or any business, legal or governmental entity or association. 9. You/Your: The terms “you” or “your” include the person(s) to whom these requests are addressed, and all of that person’s agents, representatives, and attorneys. 10.

The present tense includes the past and future tenses. The singular includes the plural, and the plural includes the singular. “All” means “any and all;” “any” means “any and all.” “Including” means “including but not limited to.” “And” and “or” encompass both “and” and “or.” Words in the masculine, feminine, or neuter form shall include each of the other genders. STANDARD INTERROGATORIES TO A PLAINTIFF STANDARD INTERROGATORY NO. 1: Identify all persons who are likely to have personal knowledge of any fact alleged in the pleadings, and state the subject matter of the personal knowledge possessed by each such person.

STANDARD INTERROGATORY NO. 2: Identify all persons who have a subrogation interest in any claim set forth in the complaint, and state the basis and extent of such interest. STANDARD INTERROGATORY NO. 3: Itemize and show how you calculate any damages claimed by you in this action, whether economic, non-economic, punitive, or other. STANDARD INTERROGATORIES TO A DEFENDANT STANDARD INTERROGATORY NO. 4: If you contend that the Defendant is improperly identified, state Defendant’s correct identification. U.S. District Court of Maryland Local Rules (December 1, 2025) 131 APPENDIX D STANDARD INTERROGATORY NO. 5: Identify any persons or entities whom Defendant contends are persons needed for just adjudication within the meaning of Fed. R. Civ. P. 19, but who have not been named by Plaintiff.

STANDARD INTERROGATORY NO. 6: Identify all persons who are likely to have personal knowledge of any fact alleged in the complaint or in your answer to the complaint, and state the subject matter of the personal knowledge possessed by each such person. STANDARD INTERROGATORY NO. 7: If you have knowledge of any person carrying on an insurance business that might be liable to satisfy part or all of a judgment that might be entered in this action or to indemnify or reimburse the payments made to satisfy the judgment, identify that person and state the applicable policy limits of any insurance agreement under which the person might be liable. STANDARD INTERROGATORIES TO ANY PARTY STANDARD INTERROGATORY NO. 8: For each witness identified by you in connection with the disclosures required by Fed. R. Civ. P. 26(a)(2)(A), provide a complete statement of the opinions to be expressed and basis and reasons therefore. STANDARD INTERROGATORY NO. 9: For each witness you have retained or specially employed to provide expert testimony in this case, or employed by you whose duties regularly involve giving expert testimony and whom you expect to testify at trial, provide a complete statement of the opinions to be expressed and the basis and reasons therefore.

STANDARD INTERROGATORY NO. 10: State the facts concerning the matters alleged in [paragraph ____ of your Complaint] [paragraph ____ of your Answer to the Complaint] [your affirmative defense no. ___]. STANDARD INTERROGATORY NO. 11: If you contend that __________, state the facts concerning such contention. U.S. District Court of Maryland Local Rules (December 1, 2025) 132 APPENDIX D Standard Requests for Production of Documents _____________________, IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND * Plaintiff * v. * Civil Action No.:________________ ______________________, Defendant * * * * * * * * * * * * * REQUEST FOR PRODUCTION OF DOCUMENTS Pursuant to Fed. R. Civ. P. 34, L.R. 104, and Appendix A to the Local Rules (Discovery Guidelines), __________________, by its undersigned attorneys, requests that _____________________ respond to this Request within the time prescribed by the Federal Rules of Civil Procedure, and produce or make available for inspection and copying the following documents and electronically storied information (“ESI”) on the ____ day of ____________ _____, at ___ o’clock, a.m., and continuing from day to day thereafter, until completed, at the offices of _______________(name and address), or at such time and place as may be agreed upon by all counsel.

INSTRUCTIONS 1.

Pursuant to Rule 34(b)(2)(B), if you object to a request, the grounds for each objection must be stated with specificity. Also pursuant to that Rule, if you intended to produce copies of documents or of ESI instead of permitting inspection, you must so state. 2. If, in responding to this Request for Production, the responding party encounters any ambiguities when construing a request or definition, the response shall set forth the matter deemed ambiguous and the construction used in responding.

U.S. District Court of Maryland Local Rules (December 1, 2025) 133 APPENDIX D 3. Pursuant to Rule 34(b)(2)(C), an objection must state whether any responsive materials are being withheld on the basis of that objection. 4. Whenever in this Request you are asked to identify or produce a document which is deemed by you to be properly withheld from production for inspection or copying: A. If you are withholding the document under claim of privilege (including, but not limited to, the work product doctrine), please provide the information set forth in Fed. R. Civ. P. 26(b)(5) and Discovery Guideline 10(d)(ii)(b).

For electronically stored information, a privilege log (in searchable and sortable form, such as a spreadsheet, matrix, or table) generated by litigation review software, containing metadata fields that generally correspond to the above paragraph is permissible, provided that it also discloses whether transmitting, attached or subsidiary (“parent-child”) documents exist and whether those documents have been produced or withheld.* B. If you are withholding the document for any reason other than an objection that it is beyond the scope of discovery, identify as to each document and, in addition to the information requested in paragraph 4.A, above, please state the reason for withholding the document. If you are withholding production on the basis that ESI is not reasonably accessible because of undue burden or cost, provide the information required by Discovery Guideline 10(e). 5. When a document contains both privileged and non-privileged material, the non- privileged material must be disclosed to the fullest extent possible without thereby disclosing the privileged material.

If a privilege is asserted with regard to part of the material contained in a *Comment: Many commercial “litigation review software” platforms are capable of generating a privilege log. Nothing in this Appendix compels the use of such platforms in general or for privilege logs. A requesting party may choose to include this optional paragraph, which may be appropriate or inappropriate, depending on the needs of the case. U.S. District Court of Maryland Local Rules (December 1, 2025) 134 APPENDIX D document, the party claiming the privilege must clearly indicate the portions as to which the privilege is claimed.

When a document has been redacted or altered in any fashion, identify as to each document the reason for the redaction or alteration, the date of the redaction or alteration, and the person performing the redaction or alteration. Any redaction must be clearly visible on the redacted document. 6. It is intended that this Request will not solicit any material protected either by the attorney/client privilege or by the work product doctrine which was created by, or developed by, counsel for the responding party after the date on which this litigation was commenced.

If any Request is susceptible of a construction which calls for the production of such material, that material need not be provided and no privilege log pursuant to Fed. R. Civ. P. 26(b)(5) or Discovery Guideline 9(a) will be required as to such material.

DEFINITIONS

Notwithstanding any definition set forth below, each word, term, or phrase used in this Request is intended to have the broadest meaning permitted under the Federal Rules of Civil Procedure. As used in this Request, the following terms are to be interpreted in accordance with these definitions: 1. Communication: The term “communication” means the transmittal of information by any means. 2.

Concerning: The term “concerning” means relating to, referring to, describing, evidencing, or constituting. 3. Document: The terms “document” and “documents” are defined to be synonymous in meaning and equal in scope to the usage of the term “items” in Fed. R. Civ. P. 34(a)(1) and include(s), but is not limited to electronically stored information. The terms “writings,” “recordings,” and “photographs” are defined to be synonymous in meaning and equal in scope to U.S. District Court of Maryland Local Rules (December 1, 2025) 135 APPENDIX D the usage of those terms in Fed. R. Evid. 1001.

A draft or non-identical copy is a separate document within the meaning of the term “document.” 4. Form or Forms: If documents are produced as electronically stored information, they shall be produced in the following form or forms: [to be determined by the requesting party consistent with Guideline 2.04 of the ESI Principles].* 5. Occurrence/Transaction: The terms “occurrence” and Atransaction” mean the events described in the Complaint and other pleadings, as the word Apleadings” is defined in Fed. R. Civ. P. 7(a). 6.

Parties: The terms “plaintiff ” and “defendant” (including, without limitation, third- party plaintiff, third-party defendant, counter claimant, cross-claimant, counter-defendant, and cross-defendant), as well as a party’s full or abbreviated name or a pronoun referring to a party, mean that party and, where applicable, its officers, directors, and employees. This definition is not intended to impose a discovery obligation on any person who is not a party to the litigation or to limit the Court’s jurisdiction to enter any appropriate order. 7. Person: The term “person” is defined as any natural person or any business, legal or governmental entity, or association.

8. You/Your: The terms “you” or “your” include the person(s) to whom this Request is addressed, and all of that person’s agents, representatives, and attorneys. 9. The present tense includes the past and future tenses.

The singular includes the plural, and the plural includes the singular. “All” means “any and all;” “any” means “any and all.” *Comment: Pursuant to Fed. R. Civ. P. 34(b)(1)(C), a requesting party “may specify the form or forms in which electronically stored information is to be produced.” A requesting party may choose to include this optional paragraph, which may be appropriate or inappropriate, depending on the needs of the case. U.S. District Court of Maryland Local Rules (December 1, 2025) 136 APPENDIX D “Including” means “including but not limited to.” “And” and “or” encompass both “and” and “or.” Words in the masculine, feminine, or neuter form shall include each of the other genders. 10.

If the requested documents are maintained in a file, the file folder is included in the request for production of those documents.

STANDARD DOCUMENT REQUESTS

The documents referred to in your Answers to Interrogatories. All statements (as that term is used in Fed. R. Civ. P. 26(b)(3)(C which were 1. 2. previously made by this party and any of its present or former directors, officers, or employees, concerning the action or its subject matter. 3.

The documents (including, but not limited to, correspondence, notes, memoranda, and journal entries) which relate to, describe, summarize, or memorialize any communication between you and [Name], or anyone known or believed by you to have been acting under the authority of [Name], concerning the occurrence. 4. All documents (including, but not limited to, fee agreements, reports, and correspondence) provided to, received from, or prepared by each witness identified by you in connection with the disclosures required by Fed. R. Civ. P. 26(a)(2)(A) or in connection with any witness identified in your Answer to Standard Interrogatory No. 8 or 9. 5.

All contracts or agreements entered into between plaintiff and defendant concerning the occurrence or transaction. 6. The documents concerning your claim for damages or the methods used to calculate such alleged damages. 7.

All documents concerning any release, settlement, or other agreement, formal or informal, pursuant to which the liability of any person or any entity for damage arising out of the occurrence which is the subject matter of this lawsuit has been limited, reduced, or released in any U.S. District Court of Maryland Local Rules (December 1, 2025) 137 APPENDIX D manner. This request includes all agreements by one party or person to indemnify another party or person for claims asserted in this litigation. 8. All insurance policies under which a person carrying on an insurance business might be liable to pay to you or on your behalf all or part of the damages sought in this action.

9. All documents received from or provided to any other party to this action or received from any third-party since the filing of the Complaint, whether provided informally or in response to a formal request. 10. All documents referred to in the Complaint and other pleadings, as the word “pleadings” is defined in Fed. R. Civ. P. 7(a).

U.S. District Court of Maryland Local Rules (December 1, 2025) 138 APPENDIX D Stipulated Order Regarding Confidentiality of Discovery Material (Local Rule 104.13) Whereas, the parties have stipulated that certain discovery material be treated as confidential; Accordingly, it is this ____ day of ________________, ____, by the United States District Court for the District of Maryland, ORDERED: 1. Designation of Discovery Materials as Confidential. All documents produced in the course of discovery, all Answers to Interrogatories, all Answers to Requests for Admission, all Responses to Requests for Production of Documents, and all deposition testimony and deposition exhibits shall be subject to this Order concerning confidential information, as set forth below: (a) The designation of confidential information shall be made by placing or affixing on the document, in a manner which will not interfere with its legibility, the word “CONFIDENTIAL.” One who provides material may designate it as “CONFIDENTIAL” only when such person in good faith believes it contains sensitive personal information, trade secrets or other confidential research, development, or commercial information which is in fact confidential. A party shall not routinely designate material as “CONFIDENTIAL,” or make such a designation without reasonable inquiry to determine whether it qualifies for such designation.

Except for documents produced for inspection at the party’s facilities, the designation of confidential information shall be made prior to, or contemporaneously with, the production or disclosure of that information. In the event that documents are produced for inspection at the party’s facilities, such documents may be produced for inspection before being marked confidential. Once specific documents have been designated for copying, any documents containing confidential information will then be marked confidential after copying but before delivery to the party who inspected and designated the U.S. District Court of Maryland Local Rules (December 1, 2025) 139 APPENDIX D documents. There will be no waiver of confidentiality by the inspection of confidential documents before they are copied and marked confidential pursuant to this procedure.

(b) Portions of depositions of a party’s present and former officers, directors, employees, agents, experts, and representatives shall be deemed confidential only if they are designated as such when the deposition is taken or within seven business days after receipt of the transcript. Any testimony which describes a document which has been designated as “CONFIDENTIAL,” as described above, shall also be deemed to be designated as “CONFIDENTIAL.” (c) Information or documents designated as confidential under this Order shall not be used or disclosed by the parties or counsel for the parties or any persons identified in subparagraph (d) below for any purposes whatsoever other than preparing for and conducting the litigation in which the information or documents were disclosed (including appeals). The parties shall not disclose information or documents designated as confidential to putative class members not named as plaintiffs in putative class litigation unless and until one or more classes has/have been certified. (d) The parties and counsel for the parties shall not disclose or permit the disclosure of any documents or information designated as confidential under this Order to any other person or entity, except that disclosures may be made in the following circumstances: (i) Disclosure may be made to counsel and employees of counsel for the parties who have direct functional responsibility for the preparation and trial of the lawsuit.

Any such employee to whom counsel for the parties makes a disclosure shall be provided with a copy of, and become subject to, the provisions of this Order requiring that the documents and information be held in confidence. U.S. District Court of Maryland Local Rules (December 1, 2025) 140 APPENDIX D (ii) Disclosure may be made only to employees of a party required in good faith to provide assistance in the conduct of the litigation in which the information was disclosed. (iii) Disclosure may be made to court reporters engaged for depositions and those persons, if any, specifically engaged for the limited purpose of making photocopies of documents. Prior to disclosure to any such court reporter or person engaged in making photocopies of documents, such person must agree to be bound by the terms of this Order.

(iv) Disclosure may be made to consultants, investigators, or experts (hereinafter referred to collectively as “experts”) employed by the parties or counsel for the parties to assist in the preparation and trial of the lawsuit. Prior to disclosure to any expert, the expert must be informed of and agree in writing to be subject to the provisions of this Order requiring that the documents and information be held in confidence. (e) Except as provided in subparagraph (d) above, counsel for the parties shall keep all documents designated as confidential which are received under this Order secure within their exclusive possession and shall take reasonable efforts to place such documents in a secure area. (f) All copies, duplicates, extracts, summaries, or descriptions (hereinafter referred to collectively as “copies”) of documents or information designated as confidential under this Order or any portion thereof shall be immediately affixed with the word “CONFIDENTIAL” if that word does not already appear.

2. Confidential Information Filed with Court. To the extent that any materials subject to this Confidentiality Order (or any pleading, motion, or memorandum disclosing them) are U.S. District Court of Maryland Local Rules (December 1, 2025) 141 APPENDIX D proposed to be filed or are filed with the Court, those materials and papers, or any portion thereof which discloses confidential information, shall be filed under seal (by the filing party) with the Clerk of the Court with a simultaneous motion pursuant to L.R. 104.13(c) (hereinafter the “Interim Sealing Motion”), in accordance with the current version of the Court’s Electronic Filing Requirements and Procedures for Civil Cases. The Interim Sealing Motion shall be governed by L.R. 105.11.

Even if the filing party believes that the materials subject to the Confidentiality Order are not properly classified as confidential, the filing party shall file the Interim Sealing Motion; provided, however, that the filing of the Interim Sealing Motion shall be wholly without prejudice to the filing party’s rights under paragraph (4) of this Confidentiality Order. 3. Party Seeking Greater Protection Must Obtain Further Order. No information may be withheld from discovery on the ground that the material to be disclosed requires protection greater than that afforded by paragraph (1) of this Order unless the party claiming a need for greater protection moves for an order providing such special protection pursuant to Fed. R. Civ. P. 26(c).

4. Challenging Designation of Confidentiality. A designation of confidentiality may be challenged upon motion. The burden of proving the confidentiality of designated information remains with the party asserting such confidentiality.

The provisions of Fed. R. Civ. P. 37(a)(5) apply to such motions. U.S. District Court of Maryland Local Rules (December 1, 2025) 142 APPENDIX D 5. Return of Confidential Material at Conclusion of Litigation. At the conclusion of the litigation, all material treated as confidential under this Order and not received in evidence shall be returned to the originating party.

If the parties so stipulate, the material may be destroyed instead of being returned. The Clerk of the Court may return to counsel for the parties, or destroy, any sealed material at the end of the litigation, including any appeals. [SIGNATURES OF COUNSEL] _______________________________________________ UNITED STATES [DISTRICT] [MAGISTRATE] JUDGE U.S. District Court of Maryland Local Rules (December 1, 2025) 143 APPENDIX D Stipulated Order Regarding Non-Waiver of Attorney-Client Privilege and Work Product Protection (Local Rule 104.14) Whereas, the parties have stipulated, and hereby request the entry of an order providing, that the attorney-client privilege and work product protection shall not be waived under certain circumstances as specified herein; Accordingly, it is this ____ day of ________________, ____, by the United States District Court for the District of Maryland, ORDERED: 1. Non-Waiver of Attorney-Client Privilege and Work Product Protection. Pursuant to Fed. R. Evid. 502(d) and (e), the disclosure during discovery of any communication or information (hereinafter “Document”) that is protected by the attorney-client privilege (“Privilege” or “Privileged,” as the case may be) or work-product protection (“Protection” or “Protected,” as the case may be), as defined by Fed. R. Evid. 502(g), shall not waive the Privilege or Protection in the above-captioned case, or any other federal or state proceeding, for either that Document or the subject matter of that Document, unless there is an intentional waiver of the Privilege or Protection to support an affirmative use of the Document in support of the party’s claim or defense, in which event the scope of any such waiver shall be determined by Fed. R. Evid. 502(a)(2) and (3).

The parties intend that this stipulated order shall displace the provisions of Fed. R. Evid. 502(b)(1) and (2). That is, all disclosures not made to support an affirmative use of the Document in support of a party’s claim or defense shall be regarded as “inadvertent,” and the producing party is hereby deemed to have taken “reasonable steps to prevent disclosure,” regardless of any argument or circumstances suggesting otherwise. 2. Return of Privileged or Protected Materials.

Except when the requesting party contests the validity of the underlying claim of Privilege or Protection (including a challenge to the reasonableness of the timing or substance of the measures undertaken by the producing party to U.S. District Court of Maryland Local Rules (December 1, 2025) 144 APPENDIX D retrieve the Document(s) in question), any Document(s) the producing party claims as Privileged or Protected shall, upon written request, promptly be returned to the producing party and/or destroyed, at the producing party’s option. If the underlying claim of Privilege or Protection is contested, the parties shall comply with, and the requesting party may promptly seek a judicial determination of the matter pursuant to, Fed. R. Civ. P. 26(b)(5)(B). In assessing the validity of any claim of Privilege or Protection, the court shall not consider the provisions of Fed. R. Evid. 502(b)(1) and (2), but shall consider whether timely and otherwise reasonable steps were taken by the producing party to request the return or destruction of the Document once the producing party had actual knowledge of (i) the circumstances giving rise to the claim of Privilege or Protection and (ii) the production of the Document in question. 3.

For purposes of paragraph 2, “destroyed” shall mean that the paper versions are shredded, that active electronic versions are deleted, and that no effort shall be made to recover versions that are not readily accessible, such as those on backup media or only recoverable through forensic means. 4. For purposes of paragraph 2, “actual knowledge” refers to the actual knowledge of an attorney of record or other attorney with lead responsibilities in the litigation (for example, lead counsel, trial counsel, or a senior attorney with managerial responsibilities for the litigation). [SIGNATURES OF COUNSEL] _______________________________________________ UNITED STATES [DISTRICT] [MAGISTRATE] JUDGE U.S. District Court of Maryland Local Rules (December 1, 2025) 145 APPENDIX D Order Sealing Portions of the Court Record (Local Rule 105.11) Whereas, the parties have filed a Joint Motion seeking a Protective Order Sealing Portions of the Court Record (the “Joint Motion”); Whereas, in the Joint Motion, the parties have “proposed reasons supported by specific factual representations to justify the requested sealing,” in accordance with L.R. 105.11; Whereas, the parties have identified the following portion of the record as that portion which is subject to the Joint Motion [describe with particularity the portion to be sealed] (the “Sealed Record”); Whereas, the Court has considered the Joint Motion and any opposition thereto; Whereas, the Court has not ruled on the Joint Motion for at least fourteen (14) days after it was entered on the public Court docket to permit the filing of objections by interested parties; Whereas, the Court has considered any objections by interested parties, pursuant to L.R. 105.11; Whereas, the parties have stated in the Joint Motion why alternatives to sealing would not provide sufficient protection; Whereas, the Court finds and holds that alternatives to sealing would not provide sufficient protection; Whereas, the Court finds and holds that sealing of a portion and/or portions of the record, specified herein, is appropriate; Accordingly, it is this ___ day of _____________________ ____, by the United States District Court for the District of Maryland, ORDERED: 1. That the Joint Motion for Protective Order Sealing Portions of the Record be, and the same hereby is, GRANTED, as specifically set forth herein; U.S. District Court of Maryland Local Rules (December 1, 2025) 146 APPENDIX D 2.

That the Sealed Record (as defined above) be, and hereby is, PLACED UNDER SEAL by the Clerk of the Court and that the Sealed Record shall be placed in an envelope or other container which is marked SEALED, SUBJECT TO ORDER OF COURT DATED _____________. 3. A copy of this Order shall be mailed to all counsel of record and to any other person entitled to notice hereof and shall be docketed in the court file. _______________________________________________ UNITED STATES [DISTRICT] [MAGISTRATE] JUDGE U.S. District Court of Maryland Local Rules (December 1, 2025) 147