Washington Cnty. C.P. Local Rules of Civil Procedure (Updated August 1, 2025) Rule 208.3(a)

(1) Scope. As used in this rule, the term “motion” means any application to the Court made

in any civil action or proceeding, except as provided in Pa.R.C.P. 208.1(b)(1) and (2).

(2) This Court specifically declines to adopt the alternative procedures set forth in Pa.R.C.P.

208.3(b), imposing mandatory requirements for the filing of a response or brief with respect

to any motions.

Note: A party may file a brief when it is anticipated that the Court will wish to consider a brief

before deciding an issue; however, there is no requirement to do so.

(3) Procedure. The procedure set forth in this rule shall apply to every request for relief

and/or application to the Court for an order, whether by petition, motion, objections, or

stipulation, that the moving party desires to bring before the Court.

(a) If expedited consideration by the Court is requested or required by statute, rule

of procedure, or other controlling authority, the reason for such consideration shall

be set forth in the motion.

(b) A proposed order granting the relief requested shall be attached to every motion.

(c) The Court shall schedule argument, hearing, or briefing as the Court may

require, and issue a scheduling order. Unless otherwise ordered, docketing and

service of the scheduling order shall be in accordance with these rules.

(4) Presentation of a Motion

(a) In cases that are not assigned to a judge, motions may be presented to the

General Civil Motions Judge in Motions Court. The schedule for Motions Court

shall be set forth annually by Administrative Regulation and is available in

hardcopy in the Office of the Court Administrator and at www.washingtoncourts.us.

(b) All motions in cases that are assigned to a judge shall be presented in the

Motions Court of the assigned judge, except as provided in Wash.L.R.C.P. 208.2(c).

i. The Motions Court schedule for all judges assigned to civil cases shall be

set forth annually by Administrative Regulation and be made available in

hardcopy in the Office of the Court Administrator and at

www.washingtoncourts.us.

(c) All motions shall comply with the standard operating procedures of the judge to

whom presentation is made. Standard operating procedures for the judges of the

Court shall be made available at www.washingtoncourts.us.

(5) Notice of Presentation. The moving party shall provide notice of at least five (5)

business days prior to presentation of a motion, unless the motion has the consent of all

parties. A copy of the motion shall be provided to the chambers of the judge to whom the

motion is being presented at least twenty-four (24) hours in advance.

(a) Every motion that has the consent of all parties shall contain a “Certificate of

Consent” in a substantially similar form:

IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY, PENNSYLVANIA

CIVIL DIVISION

Plaintiffs

Plaintiffs,

vs.

Defendants,

Defendants.

No.

CERTIFICATE OF CONSENT

1. The undersigned, , represents [name of party], the moving party

herein.

2. As evidenced by the below signatures, the parties have consented to the relief sought by this

motion, and request that the Court enter the proposed order.

Respectfully submitted,

Signature

[date]

Consented to by: [name, party name, and signature] [date]

(b) The Certificate of Consent may be entered into in counterparts, and an original

signature is not required of any counsel and/or party except the moving party.

Comment: It is anticipated that counsel and/or a party will provide evidence of consent by email

or facsimile in many instances, and this rule encourages the use of counterparts for the

convenience of the parties.

(c) Nothing in this subsection of the rule shall be read to obviate the standard

operating procedures of a judge concerning the presentation of a motion.

(6) Sanctions. If a moving party misrepresents or falsely asserts that a motion has the

consent of another party, the Court may enter an order levying sanctions and/or any other

appropriate relief against the moving party. Nothing in this rule is intended to obviate the

provisions of Pa.R.C.P. 1023.1.

(7) Dispositional Aid. In the discretion of the Court, a judge may order one, or any, of the

following to aid in the disposition of a motion:

(a) oral argument;

(b) briefs; or

(c) a rule to show cause as set forth in Pa.R.C.P. 208.4.