Judge Carolyn M. Caietti
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- Chambers Drop Off
Ex Parte Application
- Chambers Drop Off • Upon Filing
Ex Parte Papers, Pro Hac Vice Application, Noticed Motion, Motion In Limine, Trial Brief, Trial Readiness Conference Report, Idc Brief, Settlement Conference Brief, Proposed Judgment, Proposed Order
- Chambers Drop Off
Joint Trial Notebook, Motion In Limine Binder
- Hand Delivery • Day Before Trial Call By Noon
Adjournments
- Stipulated requests to continue dates or deadlines may be made by written stipulation and must state good after cause.
Request must include
Communication
Phone
Clerk
Phone
Chambers
Page & Word Limits1 rule
Machine summary. Not checked yet.Mandatory?
In advance of the IDC, each party shall submit a concise brief (no more than five pages) of the party’s position regarding the dispute.
Summary: Each party must submit a concise IDC brief no longer than five pages before the Informal Discovery Conference.
Informal Discovery Conference Brief
5 pages
Document Format Requirements1 rule
Machine summary. Not checked yet.Mandatory?
The parties are reminded to comply with California Rule of Court 3.1110 et. seq. and San Diego Superior Court local rule 2.1.4.1 regarding formatting, bookmarking, and filing requirements of motion papers.
Summary: Motion papers must comply with CRC 3.1110 et seq. and San Diego Local Rule 2.1.4.1 for formatting, bookmarking, and filing.
Document Filing Requirements9 rules
Machine summary. Not checked yet.Mandatory?
A proposed sealing order must be provided to the Court setting forth the facts and legal
Summary: A proposed sealing order must be provided to the Court setting forth the facts and legal basis.
Document Type
Motion To Seal
Machine summary. Not checked yet.Mandatory?
The Court expects the TRC report to contain the following: a) Agreed upon, non-argumentative statement of the case; b) Joint witness list in alphabetical order; c) Joint exhibit list with objections or stipulations noted on the exhibit list, numbered sequentially (see exemplar). NOTE: the Court expects the parties to have met in person or remotely and exchanged/reviewed ALL exhibits except for true impeachment, prior to submitting the TRC Report; d) Joint list of jury instructions, together with an index, in the order in which they are requested to be given, with objections noted; and e) Proposed verdict form(s).
Summary: The Trial Readiness Conference report must contain an agreed statement of the case, joint witness list, joint exhibit list, joint jury instructions list with index, and proposed verdict forms.
Document Type
Joint Trial Readiness Conference Report
Machine summary. Not checked yet.Mandatory?
Applications for pro hac vice must comply with California Rules of Court Rule 9.40. Applications must include proof of service on the State Bar of California, proof of payment of the required fee, and a proposed order.
Summary: Pro hac vice applications must comply with CRC 9.40 and include proof of service, proof of fee payment, and a proposed order.
Document Type
Pro Hac Vice Application
Machine summary. Not checked yet.Mandatory?
The stipulation should include a proposed order.
Summary: A stipulation to continue a date must include a proposed order.
Document Type
Stipulated Advisory To Continue
Machine summary. Not checked yet.Mandatory?
Guardian Ad Litem applications shall include attachment form CIV-383, except if an adult dependent.
Summary: Guardian ad litem applications must include form CIV-383 unless the applicant is an adult dependent.
Document Type
Guardian Ad Litem Application
Machine summary. Not checked yet.Mandatory?
The proposed order shall be submitted concurrently with the notice and application for determination of good faith settlement pursuant to Code of Civil Procedure § 877.6 (a)(2).
Summary: A proposed order must be submitted concurrently with a good-faith-settlement application and notice.
Document Type
Application For Determination Of Good Faith Settlement
Machine summary. Not checked yet.Mandatory?
The notebook will be prepared by plaintiff’s counsel. The notebook should be joint and contain: a) Table of Contents; b) Joint Trial Readiness Report; c) Operative Pleadings (i.e. complaint, answer, cross complaint); d) Expert Designations; e) Trial Briefs; f) Motions in Limine and Oppositions (in order) and index of the MILs (MILs should be in separate binder from rest of items in Dept. 70’s Trial Checklist 1 – 12); g) Joint Witness List (alpha order, brief description of witnesses’ expected testimony); h) Joint Exhibit List (follow grid format; see Dept. 70 link on web page); i) Joint Statement of the Case; j) Proposed Voir Dire questions counsel wish the Court to ask; k) Jury Instructions in one packet (full text in sequential order with objections identified); and l) Special Verdict Form(s)
Summary: Plaintiff's counsel must prepare a joint Trial Notebook containing the table of contents, trial readiness report, pleadings, expert designations, trial briefs, motions in limine with index, witness and exhibit lists, proposed voir dire, jury instructions, and special verdict forms.
Document Type
Joint Trial Notebook
Machine summary. Not checked yet.Important?
Proposed stipulated protective orders for protection of confidential information will only be approved by the Court if the language in the proposed order is consistent with the Court’s stated policy.
Summary: Proposed stipulated protective orders must use language consistent with the Court's stated policy for protection of confidential information.
Document Type
Proposed Stipulated Protective Order
Machine summary. Not checked yet.Important?
Applications for orders for publication of summons may be submitted for review without an appearance. Please use the local forms CIV 48, CIV 49.
Summary: Applications for orders to serve by publication must use local forms CIV 48 and CIV 49 and may be submitted without an appearance.
Document Type
Application For Order For Publication Of Summons
Filing & Service rules
Filing Timing and Cure Windows
Ex parte papers must be filed by 12:00 p.m. at least one court day before the hearing, with the appropriate fee.
Ex parte matters will not be heard unless papers are filed by 12:00 p.m. at least one court day prior to the hearing, with the appropriate fee. All ex parte applications must comply with California Rules of Court, rule 3.1200 et. seq.
Machine summary. Not checked yet. · Civil cases
Page 1 | Ex Parte
The Joint Trial Readiness Conference Report must be E-filed no later than five court days before the scheduled TRC.
Parties must submit by E-filing their completed Joint Trial Readiness Conference Report five court days before the scheduled TRC, and with a courtesy copy provided to the department.
Machine summary. Not checked yet. · Civil cases
Page 2 | Trial Readiness Conference (TRC)
A proposed good faith settlement order will be held for 20 days if service is personal or 25 days if by mail; if uncontested, it may be signed or set for hearing.
The proposed order will be held the requisite statutory period (20 days if personally served, 25 days if served by mail). If no motion to contest is filed within the statutory period, the application will be reviewed and the order may be signed; or the Court will set a hearing.
Machine summary. Not checked yet. · Civil cases
Page 2 | Applications for Determination of Good Faith Settlement
Motions to seal should preferably be heard at least two weeks before the related substantive motions.
The Court prefers any motion to seal be heard at least two weeks before the corresponding substantive motions.
Machine summary. Not checked yet. · Civil cases
Page 2 | Sealing Records
Filing Fees and Waivers
Filing an ex parte application requires payment of the appropriate fee.
Ex parte matters will not be heard unless papers are filed by 12:00 p.m. at least one court day prior to the hearing, with the appropriate fee.
Machine summary. Not checked yet. · Civil cases
Page 1 | Ex Parte
Courtesy Copy Requirements
Proposed orders and proposed judgments (other than default judgments) require a courtesy copy to Dept. 70.
Proposed Orders, Proposed Judgments (other than default judgments): A courtesy copy must be provided to Dept. 70 in order to ensure timely processing.
Machine summary. Not checked yet. · Civil cases
Page 1 | Proposed Orders, Proposed Judgments
All motion hearing documents require a courtesy copy to Dept. 70, and courtesy copies must have tabbed exhibits.
The Court requires courtesy copies of all E-filed documents on all motion hearings (moving, opposing, etc.) delivered directly to the Dept. 70 drop box in the Hall of Justice. On courtesy copies, please tab exhibits.
Machine summary. Not checked yet. · Civil cases
Page 1 | Law and Motion
Courtesy copies of all E-filed ex parte papers must be delivered to the Dept. 70 drop box.
The Court requires courtesy copies of all E-filed ex parte papers delivered directly to the Dept. 70 drop box in the Hall of Justice.
Machine summary. Not checked yet. · Civil cases
Page 1 | Ex Parte
A courtesy copy of the Joint Trial Readiness Conference Report must be provided to the department.
Parties must submit by E-filing their completed Joint Trial Readiness Conference Report five court days before the scheduled TRC with a courtesy copy provided to the department.
Machine summary. Not checked yet. · Civil cases
Page 2 | Trial Readiness Conference (TRC)
A separate binder containing Motions in Limine, oppositions (in sequential order), and an index of MILs must be delivered to the courtroom by noon the day before the trial call whether the parties appear remotely or in person.
A separate binder for Motions in Limine and Oppositions (in sequential order) and index for the MILs are to be provided by noon the day before trial call and regardless of whether the parties are appearing remotely or in person for trial call.
Machine summary. Not checked yet. · Civil cases
Page 3 | Trial Call
Courtesy copies for Department 70 must be placed in the second-floor drop box for the listed documents (ex parte papers, pro hac vice applications, noticed motions, motions in limine, trial briefs, TRC reports, IDC/settlement conference briefs, proposed judgments, and proposed orders); no courtesy copies are required for other E-filed documents.
Courtesy copies of the following documents should be placed in the Department 70 drop box, located outside the business office on the second floor of the Hall of Justice: Ex Parte Papers (moving, opposing), Pro Hac Vice Applications, Noticed Motions (moving, opposing, replies), Motions in Limine, Trial Briefs, Joint Trial Readiness Conference Reports, IDC, Settlement Conference Briefs, Proposed Judgment, and Proposed Order. Other than the above documents, the Court does not require courtesy copies of other E-filed documents.
Machine summary. Not checked yet. · Civil cases
Page 3 | Courtesy Copies
Remote appearance at trial call is permitted only if the Joint Trial Notebook and Motion in Limine binders are physically in the courtroom by noon the day before trial call; otherwise all trial counsel and pro se parties must appear in person unless the Court permits remote appearance.
While it is preferred trial counsel be personally present, the Court allows for a remote appearance only if the Joint Trial Notebook and Motion in Limine binders are physically in the courtroom by noon the day prior to trial call. Otherwise, ALL trial counsel and pro se parties are to be physically present at trial call unless the Court allows for a remote appearance.
Machine summary. Not checked yet. · Civil cases
Page 3 | Trial Call
Sealing & Redaction Procedures
Sealing requests must comply with CRC 2.550 and 2.551; records may not be sealed based solely on party stipulation.
Requests to seal court records must comply with CRC 2.550 and 2.551. Note: "The court must not permit a record to be filed under seal based solely on the agreement or stipulation of the parties." CRC 2.551(a).
Machine summary. Not checked yet. · Civil cases
Page 1 | Sealing Records
Filing Bundling Requirements
Motions to compel initial responses must be filed as a single motion regardless of the number of discovery sets.
Motions to compel initial responses should be reserved and filed as a single motion regardless of the number of sets of discovery at issue.
Machine summary. Not checked yet. · Civil cases
Page 1 | Discovery Motions
Motions to compel further responses and motions to deem facts admitted must be filed separately for each set of discovery.
Motions to compel further responses, and motions to deem facts admitted, should be reserved and filed as separate motions for each set of discovery at issue.
Machine summary. Not checked yet. · Civil cases
Page 1 | Discovery Motions
Discovery motions must not combine discovery sought from multiple parties; each party must file its own separate motion.
Do not combine into one joint motion multiple parties, from whom discovery is sought to be compelled. Each party should have its own separate discovery motion(s).
Machine summary. Not checked yet. · Civil cases
Page 1 | Discovery Motions
Motions in Limine and their oppositions must be placed in a separate binder with an index, separate from all other Trial Checklist items.
Motions in Limine and Oppositions (in order) and their index (Motions should be in a separate binder from rest of items in Department 70’s Trial Checklist 1 – 12)
Machine summary. Not checked yet. · Civil cases
Page 3 | Trial Call
Adjournment & Extension Requirements
Stipulated requests to continue dates or deadlines may be made by written stipulation and must state good after cause.
Stipulated requests to continue any applicable dates (trial, trial readiness, motion cut-off) and deadlines may be made by written stipulation setting forth good cause for a continuance.
Machine summary. Not checked yet. · Civil cases
Page 2 | Continuances
Chambers Communication Rules
Law and motion hearings require a reservation made by phone or online.
All law and motion matters are heard by reservation only. To reserve a date, contact the calendar clerk at the number above or utilize the online reservation system.
Machine summary. Not checked yet. · Civil cases
Page 1 | Law and Motion
Ex parte hearings are reserved by calling the calendar clerk at (619) 450-7325 during 8:00 a.m. to 3:00 p.m.
Calendar Clerk Anthony Shirley: (619) 450-7325 Phone hours: 8:00 a.m. to 3:00 p.m. To reserve an ex parte hearing, contact the calendar clerk at the number above.
Machine summary. Not checked yet. · Civil cases
Page 1 | Department Staff / Ex Parte
Parties must telephone the department by noon the day before trial call, at (619) 450-7070, to report trial readiness, time estimate, and whether a jury is requested.
The day before trial call, the Court expects the parties to call into the department by noon to report their readiness for trial, time estimate, and whether a jury is requested. (619) 450-7070.
Machine summary. Not checked yet. · Civil cases
Page 3 | Trial Call