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Esther Salas

U.S. District Court for the District of New Jersey Appointed by Barack Obama (Democratic) 9 signed orders read

How Judge Salas decides

Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.

What persuades

On a factual Rule 12(b)(1) attack the plaintiff bears the burden to establish subject-matter jurisdiction with verified evidence; an unsigned/unverified complaint and unsigned interrogatory responses carry little to no weight.

“Because Liu does not provide any verified evidence to rebut Defendants' factual challenge to the Court's subject-matter jurisdiction over his FLSA claim, he fails to meet his burden of proof.”

Procedural preferences

The mere filing of a dispositive motion is not 'good cause' to stay discovery; the court manages its own docket and will allow class-certification discovery to proceed before deciding a Rule 12(b)(6) motion.

“it is well settled that the mere filing of a dispositive motion does not constitute 'good cause' for the issuance of a discovery stay.”

A plaintiff cannot amend the complaint through its summary-judgment opposition; theories and relief not pleaded (e.g. compensatory relief) are not considered.

“Because Plaintiffs cannot amend their Complaint in opposition to summary judgment, the Court focuses its inquiry on whether the District violated the stay put rule.”

Cautions

Attorney disqualification is a 'hard remedy' the court hesitates to impose except when absolutely necessary, and the movant bears the burden of establishing a Rules-of-Professional-Conduct violation.

“Disqualification is a hard remedy, 'which courts should hesitate to impose except when absolutely necessary.'”

To get the FLSA's 3-year (willful) limitations period, a plaintiff must plead specific facts of willfulness; alleged misclassification or differential recordkeeping sounds in negligence, not willfulness, and the claim is dismissed as time-barred.

“the alleged differences in Defendants' recordkeeping as to Yang and Hsu, without additional factual allegations, do not plausibly reflect an 'indifference toward the requirements imposed by the FLSA.'”

Signed rulings

A grounded sample of orders signed by this judge, with the verbatim dispositive language.

Wisehart v. Wisehart
2:15-cv-02768 · 2015-12-29
Motion to disqualify counsel (plaintiff) Denied

“Plaintiff's motion to disqualify counsel is denied.”

Default judgment (plaintiff) Denied

“the Court concludes that Defendants timely responded to the Complaint. Accordingly, Plaintiff's motion for entry of default and default judgment is denied.”

Motions to dismiss (defendant) Granted

“the Court dismisses the Complaint for improper venue without prejudice.”

H.D. & N.R. v. West Orange Board of Education
2:19-cv-18943 · 2022-01-10
Summary judgment (defendant) Granted

“the Court GRANTS the District's motion for summary judgment. (D.E. No. 63).”

Vanderwerff v. Quincy Bioscience Holding Company, Inc.
2:17-cv-00784 · 2018-11-28
Appeal of magistrate order (defendant) Denied

“Defendants' appeal is DENIED, and the Magistrate Judge's July 26 Order is AFFIRMED.”

Yi Ching Liu v. Cheng Du 23 Inc.
2:17-cv-12867 · 2022-09-13
Judgment on the pleadings (defendant) Granted

“Defendants' motion for judgment on the pleadings is GRANTED as to Yang and Hsu's FLSA claims. Accordingly, their claims are dismissed, with prejudice, as time-barred under the three-year statute of limitations.”

Motions to dismiss (defendant) Granted

“Because Liu does not provide any verified evidence to rebut Defendants' factual challenge to the Court's subject-matter jurisdiction over his FLSA claim, he fails to meet his burden of proof... Accordingly, Liu's claim is dismissed... the dismissal is with prejudice.”

Motion for partial summary judgment (defendant) Moot / procedural

“Defendants' motion for partial summary judgment is DENIED as moot.”

Cresci v. McNamara
2:18-cv-16207-ES-JSA · 2025-06-25
Appeal of magistrate order (plaintiff) Denied

“Plaintiff's Appeal (D.E. No. 65) is DENIED”

Motions to dismiss (defendant) Granted

“Defendants' unopposed Motion (D.E. No. 59) is GRANTED. Moreover, because the June 13 Opinion provided Plaintiff with ‘a final opportunity’ to amend ..., the Court DISMISSES the entirety of Plaintiff's SAC with prejudice.”

Mondelli v. Berkeley Heights Nursing & Rehab. Ctr.
2:16-cv-01569-ES-ESK · 2024-12-03
Motion for leave to appeal ifp (plaintiff) Granted

“Plaintiff's Motion (D.E. No. 79) is GRANTED.”

Role v. PSE&G
2:25-cv-00426-ES-SDA · 2025-04-21
Motion for reconsideration (plaintiff) Denied

“Plaintiff's Motion-whether brought under Rule 59(e) or 60(b)-is DENIED.”

Monroe v. Sieczkowski
2:21-cv-20231 · 2026-06-04
Motions to dismiss (defendant) Denied

“Defendant's Motions to Dismiss the Complaint and for Sanctions are DENIED.”

Motion for sanctions (defendant) Moot / procedural

“Defendant's motion for sanctions, (D.E. No. 53), is likewise DENIED as moot”

Trustees of International Union of Painters & Allied Trades District Council 711 Health & Welfare Fund v. Independent Wallcovering, Inc.
2:20-cv-07084 · 2026-06-05
Motion to enforce settlement (plaintiff) Granted

“The Court will therefore GRANT the Motion and provide that relief.”

Put Judge Salas's record to work

Ezel drafts and answers grounded in this exact profile: how Judge Salas actually rules, not a generic AI guess.

Opens in Ezel Pro. Every answer is grounded in Judge Salas's own signed orders and cites them.