Part Four: Pretrial Procedures, Dispositions and Production at Trial · Last amended 2021 · Last verified July 16, 2026
In one sentenceRule 4:15 sets the general procedure for scheduling, noticing, briefing, and arguing civil motions in Virginia circuit court, requiring advance notice and a good-faith conferral certification before a hearing and setting default page limits and deadlines for supporting briefs.
All civil case motions in circuit court will be scheduled and heard using the following procedures:
(a)Scheduling — All civil case motions in circuit court will be scheduled and heard using the following procedures:
1. Presenting the motion on a day the court designates for motions hearings, or 2. Contacting designated personnel in the office of the clerk of the court or the chambers of the judge or judges of the court.
(b)Notice — Reasonable notice of the presentation of a motion must be served on all counsel of record. Absent leave of court, and except as provided in paragraph (c) of this Rule, reasonable notice must be in writing and served at least seven days before the hearing. Counsel of record must make a reasonable effort to confer before giving notice of a motion to resolve the subject of the motion and to determine a mutually agreeable hearing date and time. The notice must be accompanied by a certification that the movant has in good faith conferred or attempted to confer with other affected parties in an effort to resolve the dispute without court action. In an Electronically Filed Case, the notice provisions of this paragraph and the filing and service requirements of paragraph (c) of this Rule is accomplished in accord with Rule 1:17.
(c)Filing and Service of Briefs — Counsel of record may elect or the court may require the parties to file briefs in support of or in opposition to a motion. Any such briefs should be filed with the court and served on all counsel of record sufficiently before the hearing to allow consideration of the issues involved. Absent leave of court, if a brief in support of a motion is five or fewer pages in length, the required notice and the brief must be filed and served at least 14 days before the hearing and any brief in opposition to the motion must be filed and served at least seven days before the hearing. If a brief will be more than five pages in length, an alternative hearing date, notice requirement, and briefing schedule may be determined by the court or its designee. Absent leave of court, the length of a brief may not exceed 20 pages, double spaced.
(d)Hearing — Except as otherwise provided in this subparagraph, upon request of counsel of record for any party, or at the court's request, the court will hear oral argument on a motion. Oral argument on a motion for reconsideration or any motion in any case where a pro se incarcerated person is counsel of record will be heard orally only at the request of the court. A court may place reasonable limits on the length of oral argument. No party may be deprived of the opportunity to present its position on the merits of a
motion solely because of the unfamiliarity of counsel of record with the motions procedures of that court. A court, however, at the request of counsel of record, or in the judge's discretion, may postpone the hearing of the motion, or require the filing of briefs to assure fairness to all parties and the ability of the court to review all such briefs in advance of the hearing.
(e)Definition of Served — For purposes of this Rule, a pleading is deemed served when it is actually received by, or in the office of, counsel of record through delivery, mailing, facsimile transmission or electronic mail as provided in Rule 1:12.
Plain-English Summary
Rule 4:15 supplies the procedural backbone for civil motions generally in circuit court — not just discovery motions, though the discovery rules lean on it constantly. A motion gets scheduled either by presenting it on a day the court has designated for motions hearings, or by contacting the clerk’s office or the judge’s chambers directly.
Reasonable written notice of a motion must go to all counsel of record at least seven days before the hearing, absent leave of court, and counsel must make a reasonable effort to confer beforehand — both to try to resolve the issue and to agree on a hearing date — with the notice carrying a certification of that effort. Supporting or opposing briefs may be required by the court or chosen by counsel; a short brief of five pages or fewer must be filed and served, along with the notice, at least 14 days before the hearing, with any opposition brief due at least seven days out, while longer briefs get their own schedule set by the court. Absent leave, briefs are capped at 20 double-spaced pages.
Oral argument follows on request of counsel or the court, except that argument on a motion for reconsideration, or in a case where a pro se incarcerated person is counsel of record, happens only if the court itself asks for it. A court can limit argument’s length, but no party may lose the chance to be heard on the merits merely because counsel is unfamiliar with a particular court’s motions procedures — the judge may instead postpone the hearing or order briefing to keep things fair. For purposes of the rule, a pleading counts as served once it is received, or reaches the office of counsel of record, by delivery, mail, fax, or email under Rule 1:12.
Frequently Asked Questions
How much notice does a motion require in Virginia circuit court?
At least seven days before the hearing, in writing, absent leave of court (Rule 4:15(b)).
Do counsel have to confer before noticing a motion in Virginia?
Yes. Rule 4:15(b) requires a reasonable effort to confer beforehand, both to try to resolve the issue and to agree on a hearing date, and the notice must certify that effort.
Is there a page limit on motion briefs in Virginia circuit court?
Yes, absent leave of court — briefs are capped at 20 double-spaced pages, and a brief of five pages or fewer follows a set filing schedule of 14 days before the hearing for the moving brief and seven for any opposition (Rule 4:15(c)).
Is oral argument guaranteed on a motion in Virginia?
Generally yes, on request of counsel or the court, except for motions for reconsideration and cases where a pro se incarcerated person is counsel of record, where argument happens only if the court requests it (Rule 4:15(d)).
What counts as being “served” for purposes of Virginia’s motions procedure?
Actual receipt, or receipt in the office of counsel of record, by delivery, mailing, fax, or email as provided in Rule 1:12 (Rule 4:15(e)).
Amendment History
Last amended by Order dated November 23, 2020; effective March 1, 2021.
Source & verification. Rule text and amendment history are
reproduced verbatim from the Rules of Supreme Court of Virginia, published by the
Supreme Court of Virginia. Last verified July 16, 2026.
· Official source
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