Court Rules
Judge

Judge Loren G. Freestone

Individual Rules, Standing Orders & Policies

Rules last changed:
San Diego Superior Court

Limits & Logistics

Courtesy Copies

Pro Hac Vice Application, Motion, Opposition, Reply, Trial Readiness Report, Trial Brief

  • Chambers Drop Off • Upon Filing
Filters:AllMandatoryImportantExhibitsConferencesProposed OrdersMemorandaTOC/TOAJuryEvidence/Witnesses

Document Filing Requirements8 rules

Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

A completed joint trial readiness conference report shall be filed in advance of the hearing pursuant to local rule 2.1.15.

Summary: A completed joint trial readiness conference report must be filed in advance of the hearing per local rule 2.1.15.

Document Type

Trial Readiness Report

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

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 include proof of service on the State Bar of California, proof of payment of the required fee, and a proposed order.

Document Type

Pro Hac Vice Application

Content & Formatting
Certificate Of Service
Proposed Order
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

All motions in limine must be filed per local rule 2.1.18.

Document Type

Motion In Limine

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

At trial call, counsel must bring a joint trial notebook, which should be comprised of the following: 1. Table of Contents 2. Copy of Joint Trial Readiness Report 3. Copies of Motion in Limine and Oppositions (in order) 4. Joint Witness List (with description of witnesses’ expected testimony) 5. Joint Exhibit List 6. Copies of Trial Briefs (if any) 7. Joint Statement of the Case 8. Proposed Voir Dire Questions (if any) 9. Jury Instructions (packet agreed upon and packet of those not agreed upon, with indication of who is offering and objecting)

Summary: At trial call, counsel must bring a joint trial notebook containing the enumerated pretrial materials.

Document Type

Joint Trial Notebook

Content & Formatting
Exhibit List
Statement Of Facts
Table Of Contents
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

All exhibits must be pre-marked in an up-to-date exhibit book.

Document Type

Exhibit Book

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

Papers must comply strictly with California Rules of Court, rule 3.1800. Non-complying papers will be returned with a notation of defects.

Summary: Default judgment papers must strictly comply with California Rules of Court rule 3.1800; non-complying papers will be returned with a notation of defects.

Document Type

Default Judgment Papers

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Important?

10. Special Verdict Form (either an agreed upon form or each side’s proposed forms). If the parties fail to make a genuine effort to limit disputes on the form of the special verdict, a general verdict form will be utilized.

Summary: If the parties fail to make a genuine effort to limit disputes on the special verdict form, the court will utilize a general verdict form.

Document Type

Special Verdict Form

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Important?

Proposed default judgments claiming punitive damages and/or non-economic damages will usually require a hearing.

Summary: Proposed default judgments claiming punitive or non-economic damages will usually require a hearing.

Document Type

Proposed Default Judgment

Specific requirements detailed in rule text.

Filing & Service rules

Filing Timing and Cure Windows

Trial briefs must be filed five court days before trial call.

Trial briefs must be filed five court days prior to trial call.

The quote is in the court's document. The summary is not checked yet. · Civil cases

Page 3 | Trial Calls

A party opposing an application may appear ex parte within five days to request a briefing schedule.

If a party opposes an application, that party may appear ex parte within five days to request a briefing schedule.

The quote is in the court's document. The summary is not checked yet. · Civil cases

Page 3

Service and Proof of Service Rules

All exhibits, demonstrative aids, and other material for opening statements must be shared with opposing counsel in advance.

All exhibits, demonstrative aids, or other material to be used in opening statements must be shared with opposing counsel in advance.

The quote is in the court's document. The summary is not checked yet. · Civil cases

Page 3 | Trial Calls

Filing Fees and Waivers

A required fee applies to pro hac vice applications, and proof of its payment must accompany the application.

proof of payment of the required fee

The quote is in the court's document. The summary is not checked yet. · Civil cases

Page 3

Courtesy Copy Requirements

Courtesy copies of pro hac vice applications, noticed motions, oppositions, replies, joint trial readiness conference reports, and trial briefs should be placed in the Department 64 drop box outside the Business Office.

Courtesy copies of the following documents should be placed in the Department 64 drop box, located outside the Business Office on the second floor of the Hall of Justice: • Ex parte applications (delivered no later than 12:00 p.m. the day before the hearing) • Pro hac vice applications • Noticed motions, oppositions, and replies • Joint trial readiness conference reports • Trial briefs

The quote is in the court's document. The summary is not checked yet. · Civil cases

Page 3 | Courtesy Copies

About Judge Loren G. Freestone

Judge Loren G. Freestone is a judge on the Superior Court of California, County of San Diego, the state trial court serving San Diego County.

Practitioners will find department-specific policies and procedures for Department 64 in this judge's published procedures.

Common questions about Judge Loren G. Freestone's rules

Are courtesy copies required for Judge Loren G. Freestone?

Courtesy-copy rule applies for pro hac vice applications, motions, oppositions, replys, trial readiness reports, and trial briefs. Details: delivery upon filing, by chambers drop off. Courtesy copies of pro hac vice applications, noticed motions, oppositions, replies, joint trial readiness conference reports, and trial briefs should be placed in the Department 64 drop box outside the Business Office.

View ruleSource: page 3, section Courtesy Copies

What must be included with pro hac vice application filings before Judge Loren G. Freestone?

The rule requires proposed order and certificate of service. Pro hac vice applications must include proof of service on the State Bar of California, proof of payment of the required fee, and a proposed order.

View ruleSource: page 3

What must be included with trial readiness report filings before Judge Loren G. Freestone?

The rule identifies required filing content or certificates. A completed joint trial readiness conference report must be filed in advance of the hearing per local rule 2.1.15.

View ruleSource: page 3, section Trial Readiness Conferences

Are filing fees or waivers addressed before Judge Loren G. Freestone?

A fee is required for covered filings. A required fee applies to pro hac vice applications, and proof of its payment must accompany the application.

View ruleSource: page 3

What filing deadlines does Judge Loren G. Freestone set?

Trial briefs must be filed five court days before trial call.

View ruleSource: page 3, section Trial Calls

What rule applies to serving the opposing party before Judge Loren G. Freestone?

The rule addresses service method, recipient, or timing requirements. Details: recipient: the opposing party. All exhibits, demonstrative aids, and other material for opening statements must be shared with opposing counsel in advance.

View ruleSource: page 3, section Trial Calls
Complete rules summary for Judge Loren G. Freestone

Pro hac vice applications must include proof of service on the State Bar of California, proof of payment of the required fee, and a proposed order.

A required fee applies to pro hac vice applications, and proof of its payment must accompany the application.

A party opposing an application may appear ex parte within five days to request a briefing schedule.

A completed joint trial readiness conference report must be filed in advance of the hearing per local rule 2.1.15.

At trial call, counsel must bring a joint trial notebook containing the enumerated pretrial materials.

If the parties fail to make a genuine effort to limit disputes on the special verdict form, the court will utilize a general verdict form.

All exhibits must be pre-marked in an up-to-date exhibit book.

All exhibits, demonstrative aids, and other material for opening statements must be shared with opposing counsel in advance.

All motions in limine must be filed per local rule 2.1.18.

Trial briefs must be filed five court days before trial call.

Default judgment papers must strictly comply with California Rules of Court rule 3.1800; non-complying papers will be returned with a notation of defects.

Proposed default judgments claiming punitive or non-economic damages will usually require a hearing.

Courtesy copies of pro hac vice applications, noticed motions, oppositions, replies, joint trial readiness conference reports, and trial briefs should be placed in the Department 64 drop box outside the Business Office.

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