San Diego Superior Court Filing Bundling Requirements

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Motions to compel initial responses should be filed as a single motion regardless of the number of discovery sets; motions to compel further responses and motions to deem facts admitted should be filed as separate motions for each set.

Motions to compel initial responses should be reserved and filed as a single motion, regardless of the number of sets of discovery at issue. However, 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.

Checked and corrected to match the court's document on Sep 21, 2026WARNING

Civil cases

Parties should submit a second notebook containing Motions in Limine followed by Oppositions, not separate notebooks.

Parties should also submit a second notebook containing Motions in Limine (MIL), followed by Oppositions, if any (not separate notebooks).

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

Civil cases

Counsel must provide a three-ring binder with tabs to the Court on the Friday before trial that includes the following: Trial Briefs, All Pre-Trial Motions (including opposition and reply), All proposed jury instructions with brackets removed and edits made as to the specific case as needed, A proposed verdict form, Exhibit list, Witness list

Summary: Counsel must provide a three-ring binder with tabs to the Court on the Friday before trial containing trial briefs, pre-trial motions, jury instructions, verdict form, exhibit list, and witness list.

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

Civil cases

Motions to compel initial responses should be reserved and filed as a single motion regardless of the number of sets of discovery at issue.

Summary: Motions to compel initial responses must be filed as a single motion regardless of the number of discovery sets at issue.

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

Civil cases

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.

Summary: Motions to compel further responses and motions to deem facts admitted must be filed as separate motions for each set of discovery.

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

Civil cases

Do not combine multiple parties, from whom discovery is sought to be compelled, into one joint motion. Each party should have its own separate discovery motion(s).

Summary: Discovery motions must not combine multiple parties; each party must file its own separate discovery motion.

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

Civil cases

Required

Always ?

Each party must submit to the court one set of 3-ring binders containing your exhibits. This copy is for the clerk The Judge's copy must be uploaded using the electronic evidence portal. Each party must also provide one set of exhibit binders to the other party/counsel and must have binders available to any witnesses at court or at their locations, including those who will be appearing on MS Teams only.

Summary: Each party must submit one set of 3-ring exhibit binders to the court (clerk), provide one set to the other party/counsel, and have binders available for witnesses.

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

Civil cases

Exhibit binders: If there are more than 50 pages of exhibits, they must be compiled in 3-ring binders. If you are submitting more than one binder, identify on the front and spine of the binder the exhibits contained therein.

Summary: Exhibits exceeding 50 pages must be compiled in 3-ring binders, and multiple binders must identify their contents on the front and spine.

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

Civil cases

Five court days before the trial or hearing, the Court requires a trial notebook (notebook may be joint or individual) that includes the following be delivered to the courtroom Clerk.

Summary: A trial notebook containing the trial brief, pre-marked exhibits, exhibit list, and witness list must be delivered to the courtroom Clerk five court days before trial or hearing; two notebooks are required (one for the Court, one for the Clerk).

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

Civil cases

Exhibit binders: If there are more than 50 pages of exhibits, they must be compiled in 3-ring binders.

Summary: Exhibits exceeding 50 pages must be compiled in 3-ring binders.

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

Civil cases

Trial briefs should be separated from binders and/or boxes when delivered to Department 704 otherwise there is a high likelihood they will not be filed and/or reviewed by the Court prior to the start of the Trial/Evidentiary hearing.

Summary: Trial briefs must be delivered separately from binders/boxes to ensure filing and review.

Machine summary. Not checked yet.CRITICAL?

Civil cases

Motions to compel initial responses should be reserved and filed as a single motion regardless of the number of sets of discovery at issue.

Summary: Motions to compel initial responses must be filed as a single motion regardless of the number of discovery sets.

Machine summary. Not checked yet.CRITICAL?

Civil cases

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.

Summary: Motions to compel further responses and motions to deem facts admitted must be filed separately for each set of discovery.

Machine summary. Not checked yet.CRITICAL?

Civil cases

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).

Summary: Discovery motions must not combine discovery sought from multiple parties; each party must file its own separate motion.

Machine summary. Not checked yet.CRITICAL?

Civil cases

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)

Summary: Motions in Limine and their oppositions must be placed in a separate binder with an index, separate from all other Trial Checklist items.

Not confirmed. Read the court's wording below.CRITICAL?

As set forth in the Advance Trial Review Order, the parties must bring a separate binder containing the motions in limine together with any opposition, arranged in order.

Summary: Parties must bring a separate binder with motions in limine and opposition, arranged in order, to trial call.

Machine summary. Not checked yet.CRITICAL?

Civil cases

Motions to compel initial responses should be reserved and filed as a single motion, regardless of the number of sets of discovery at issue.

Summary: Motions to compel initial responses must be filed as a single motion regardless of number of sets.

Machine summary. Not checked yet.CRITICAL?

Civil cases

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.

Summary: Motions to compel further responses and motions to deem facts admitted must be filed as separate motions for each set of discovery.

Not confirmed. Read the court's wording below.CRITICAL?

Civil cases

At least two (2) court days before trial, the parties are expected to provide the following materials: A Trial Binder with the following included: 1. Table of contents 2. Joint Trial Readiness Report 3. Limine motions and oppositions and index of Limine motions 4. Copy of Joint Witness List. Listing the witness as either percipient or expert. 5. Copy of Joint Exhibit List (follow grids format – see attachment to ADR, with objections noted) 6. Copy of Trial Briefs 7. Copy of the Operative Pleadings, e.g., Complaints and Answers.

Summary: At least two court days before trial, parties must provide a Trial Binder containing specified documents.

Machine summary. Not checked yet.WARNING?

Civil cases

Parties must also submit a second notebook containing Motions in Limine (MIL), followed by Oppositions, if any (not separate notebooks).

Summary: Motions in Limine and any oppositions must be combined in a second notebook, not filed as separate notebooks.

Machine summary. Not checked yet.WARNING?

Civil cases

No replies to MILs.

Summary: Replies to Motions in Limine are not permitted.

Not confirmed. Read the court's wording below.WARNING?

Civil cases

Parties should also submit a second notebook containing Motions in Limine (MILs), followed by Oppositions, if any (not separate notebooks). No replies to MILs should be submitted.

Summary: MILs and oppositions should be submitted in a second combined notebook (not separate notebooks), and no replies to MILs should be submitted.