Middle District of Tennessee Local Rules: Filing, Motions, Admission

The local rules of the United States District Court for the Middle District of Tennessee sit on top of the Federal Rules of Civil and Criminal Procedure and control how cases are actually filed, briefed, and moved through the court. Ignore them and you can see filings rejected, deadlines missed, or motions treated as unopposed. The current version is dated May 15, 2025, and is published on the court’s website.¹

The rules are organized by subject and numbered to track the corresponding Federal Rules. They do not govern the United States Bankruptcy Court, which operates under its own procedures. Because the court amends the rules periodically, confirm you are working from the current version before relying on any specific provision.

Filing a New Civil Case

Represented parties must file civil complaints, petitions, and notices of removal electronically.² If hard-copy filing becomes necessary under exceptional circumstances, counsel must contact the Clerk’s Office in advance and provide an electronic PDF on a USB drive or other approved media. When the paper and electronic versions conflict, the electronic version controls.

Pro se parties follow the opposite path. If you represent yourself, file your initial complaint or petition in hard copy by mail or in person at the Clerk’s Office.²

Every civil complaint must be accompanied by a civil cover sheet (Form JS-44), available on the court’s website and from the Clerk’s Office.³ Non-governmental business entities must also file a Business Entity Disclosure Statement with the initial pleading, identifying parent, subsidiary, and affiliate corporations. Parties in diversity cases have an additional disclosure obligation under the court’s local version of Federal Rule 7.1.

Electronic Filing Through CM/ECF

All attorneys, including those admitted pro hac vice and those representing the United States, must file through the Case Management/Electronic Case Files (CM/ECF) system.⁴ You register through PACER, and the electronic timestamp on your submission is the official filing date and time. All documents must be in PDF format, and sensitive personal information such as Social Security numbers and dates of birth must be redacted from the public version.

Pro se parties are not required to use CM/ECF but may ask the court for permission to use the separate Pro Se Electronic Filing Portal.⁴ The Pro Se Portal is exclusively for unrepresented parties. Any document an attorney submits through it will be rejected.

Motion Practice

Meet and Confer

Before filing most motions, counsel must confer with opposing counsel and state in the motion whether the relief is opposed.⁵ If you cannot reach opposing counsel, the motion must describe your attempts. The requirement does not apply to motions under Federal Rules 12, 55, 56, 59, or 60, or to motions for pro hac vice admission. In practical terms, motions to dismiss, for default, for summary judgment, for a new trial, and for relief from judgment are all exempt.

Memoranda and Page Limits

Any motion that asks the court to decide a legal question must be accompanied by a memorandum of law citing the relevant authorities.⁵ You can file the memorandum separately or combine it with the motion. If combined, title the filing “Motion and Memorandum of Law.” A separately filed memorandum should not be attached as an exhibit or addendum to the motion.

Page limits are strict and require leave of court to exceed:

Supporting memorandum, or combined motion and memorandum: 25 pages
Response in opposition: 25 pages
Reply: 5 pages

Response and Reply Deadlines

An opposing party has 14 days after service to file a response to most motions.⁵ For summary judgment motions, the response period extends to 21 days under a separate local rule. An optional reply may be filed within 7 days after service of the response.

Missing the response deadline has a direct consequence: the motion is deemed unopposed. The court can also act on any motion before the response deadline expires. If that happens, the affected party has 14 days to file a motion for relief from the ruling.

Case Management Conference and Scheduling

All civil cases that are not specifically exempt are subject to a mandatory initial case management conference.⁶ The Clerk issues notice of the conference when the complaint or notice of removal is filed, and the filing party must serve that notice on all other parties.

Before the conference, the parties must jointly prepare a proposed initial case management order that incorporates the matters required by Federal Rule 26(f), including discovery planning and any issues involving electronically stored information. Individual judges have their own sample orders and supplemental requirements, so check the assigned judge’s practice and procedures manual for the format, delivery method, and deadlines expected on the proposed order.

The resulting scheduling order sets the discovery cutoffs, expert disclosure dates, and dispositive motion deadline. The dispositive motion deadline must be set far enough in advance to allow full briefing and resolution at least 90 days before the target trial date.⁷

Discovery

The default limit is 25 interrogatories per party, with subparts counting toward the cap.⁸ You can submit them in successive sets, but the total cannot exceed 25 without leave of court. A request for additional interrogatories must include the proposed questions and explain why the information cannot be obtained through other means.

When you serve written discovery, you must also provide a copy in an editable electronic format so the responding party can insert answers directly. Pro se parties are exempt.⁹

Discovery disputes follow their own protocol. Before filing a motion to compel, motion for protective order, or motion to quash a subpoena, counsel must confer in good faith.¹⁰ If that fails, the parties must file a joint discovery dispute statement describing their resolution attempts, identifying the exact discovery in dispute, and laying out each side’s position. Filing this statement is a prerequisite to requesting a telephonic discovery conference or filing a discovery motion.

Unless a pretrial order says otherwise, you must supplement your discovery responses no later than 30 days before trial. Evidence within the scope of your responses that you fail to disclose in time can be excluded at trial.¹¹

Filing Under Seal

Court records carry a strong presumption of public access, and the court sets a high bar for sealing. A motion to seal must explain the compelling reasons for secrecy document by document, with supporting facts and legal authority.¹² A vague or conclusory motion will not suffice, and an unopposed motion does not lower the standard.

The CM/ECF filing sequence is specific, and getting it wrong can expose confidential material to the public. First, file the motion to seal without attaching the sensitive document. Then, immediately after, file the proposed sealed document using the “Sealed Document” event in CM/ECF. Access stays restricted until the court rules. If practicable, you must also file a separate redacted version.

One trap for practitioners: proposed protective orders should not include language automatically sealing documents marked “confidential” in discovery. The court may strike that language and deny the entire protective order.

Alternative Dispute Resolution

Every civil case in the district is potentially subject to ADR. ADR here takes two main forms: a judicial settlement conference, in which a judge facilitates negotiations, and mediation, in which a neutral private mediator guides discussions toward a voluntary agreement.¹³ The assigned judge can refer the case to mediation or a settlement conference on motion or on the court’s own initiative, and party consent is not required. Parties can also agree to ADR without a court order, though the court retains supervisory authority.

The court can sanction noncompliance with the ADR rules through attorney’s fees, mediator’s fees, costs, and contempt. If ADR does not resolve the case, it proceeds toward trial under the existing scheduling order without delay.

Attorney Admission

Regular Admission

To practice before the court, you must be admitted to its bar. Eligibility requires good standing in the bar of Tennessee, another state or territory, or the District of Columbia. Applicants who are not Tennessee bar members must also be members of a United States District Court or a United States appellate court.¹⁴

The application must be signed by two members in good standing of this court’s bar who recommend admission. After approval, one of those attorneys must move your admission before a judge, and you take the required oath and sign the roll of attorneys. The enrollment fee is $249.¹⁵ You have six months from approval to complete the admission process; after that, you must start over with a new application.

Pro Hac Vice

Out-of-state attorneys who do not reside in the district and do not maintain an office here may appear in a specific case through pro hac vice admission. That requires a written motion, a $150 fee, and certification of good standing as a member of the bar of another United States District Court or appellate court.¹⁵ A state bar certificate alone will not satisfy this requirement. The applicant must also disclose under oath any disciplinary proceedings, contempt findings, sanctions, or criminal charges.

Local Co-Counsel

Unless you are both a Tennessee bar member and admitted to this court’s bar, you must retain local co-counsel. This applies to all civil cases, which means pro hac vice attorneys always need a local attorney on the case. Attorneys representing the United States are exempt.

1
United States District Court. Local Rules of the Middle District of Tennessee
2
United States District Court Middle District of Tennessee. Middle District of Tennessee Local Rules of Court – LR 3.01
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United States District Court Middle District of Tennessee. Middle District of Tennessee Local Rules of Court – LR 3.03
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United States District Court Middle District of Tennessee. E-Filing
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United States District Court Middle District of Tennessee. Middle District of Tennessee Local Rules of Court – LR 7.01
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United States District Court Middle District of Tennessee. Middle District of Tennessee Local Rules of Court – LR 16.01
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United States District Court Middle District of Tennessee. Middle District of Tennessee Local Rules of Court – LR 16.01
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United States District Court Middle District of Tennessee. Middle District of Tennessee Local Rules of Court – LR 33.01
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United States District Court Middle District of Tennessee. Middle District of Tennessee Local Rules of Court – LR 26.01
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United States District Court Middle District of Tennessee. Middle District of Tennessee Local Rules of Court – LR 37.01
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United States District Court Middle District of Tennessee. Middle District of Tennessee Local Rules of Court – LR 39.01
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United States District Court Middle District of Tennessee. Middle District of Tennessee Local Rules of Court – LR 5.03
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United States District Court Middle District of Tennessee. Middle District of Tennessee Local Rules of Court – LR 16.03
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United States District Court Middle District of Tennessee. Middle District of Tennessee Local Rules of Court – LR 83.01
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Middle District of Tennessee | United States District Court. Fee Schedule