San Mateo Superior Court Pre-Motion Conference Requirements
52 rules from official source documents
22 of 52 checked against the court's document. Each rule says how far it was checked. A value with a question mark is not in the court's wording on its card.
Pre-motion conference and letter requirements before filing motions, including sequential steps. This page is scoped to San Mateo Superior Court; use the court rules overview to switch categories without leaving this court.
Checked and corrected to match the court's document on Oct 1, 2026CRITICAL
Civil cases
The parties must meet and confer at least 35 days before the Pretrial Conference to determine whether evidentiary issues can be resolved by stipulation.
The parties shall meet and confer no later than thirty-five (35) days before the Pretrial Conference to determine whether any evidentiary issues may be resolved by stipulation.
Checked and corrected to match the court's document on Oct 1, 2026CRITICAL
Civil cases
A party must make a good-faith effort to resolve the evidentiary issue with the opposing party before filing a motion in limine.
No party may file a motion in limine without first making a good faith effort to resolve the evidentiary issue with the opposing party.
Checked against the court's document on Oct 1, 2026CRITICAL
Before filing a motion in limine, parties or counsel must meet and confer in good faith to attempt to reach a stipulation, preferably through an in-person meeting, telephone call, or video conference; exchanging letters, emails, or voicemail is insufficient.
Parties and/or counsel MUST meet and confer in good faith prior to filing Motions in Limine ("MIL") in an attempt to reach a stipulation, which should include an in-person meeting, or a telephone or video conference call. Merely exchanging letters, emails or voice-mail messages is insufficient.
Checked and corrected to match the court's document on Oct 1, 2026CRITICAL
Civil cases
Parties must make a good-faith effort to resolve evidentiary issues with the opposing party through meet-and-confer no later than 35 days before the Pretrial Conference before filing a motion in limine.
The parties are encouraged to resolve trial issues with one another as soon as possible. The parties shall meet and confer no later than thirty-five (35) days before the Pretrial Conference to determine whether any evidentiary issues may be resolved by stipulation. No party may file a motion in limine without first making a good faith effort to resolve the evidentiary issue with the opposing party.
Checked and corrected to match the court's document on Oct 1, 2026CRITICAL
Civil cases
Except for pro hac vice applications and counsel-withdrawal motions, counsel and self-represented parties must confer in good faith at least three calendar days before the hearing, and moving counsel must submit a declaration of the conference and agreements at least one day before the hearing.
Before the hearing of any motion, petition, or application, except applications to appear pro hac vice and motions to withdraw as counsel of record, all counsel and persons appearing in propria persona shall confer in a good faith attempt to eliminate the necessity of the hearing or to resolve as many disputes as possible. Counsel for the moving party shall arrange the conference to meet and confer at least three (3) calendar days before the hearing and shall submit to the Court at least one (1) day before the hearing a declaration establishing that the meet and confer conference occurred and describing any agreements that counsel have reached.
Checked and corrected to match the court's document on Oct 1, 2026CRITICAL
Civil cases
At least 21 days before the pretrial conference, the parties must meet and confer, and no motion in limine may be filed without a prior good-faith effort to resolve or narrow the evidentiary issue.
The parties shall meet and confer no later than twenty-one (21) days before the PTC to determine whether any evidentiary issues may be resolved by stipulation. No party may file a motion in limine (“MIL”) without first making a good faith effort to resolve/narrow the evidentiary issue with the opposing party.
Checked and corrected to match the court's document on Oct 1, 2026CRITICAL
Civil cases
The parties must meet and confer at least 21 days before the pretrial conference, and no party may file a motion in limine without first making a good-faith effort to resolve or narrow the evidentiary issue.
The parties shall meet and confer no later than twenty-one (21) days before the PTC to determine whether any evidentiary issues may be resolved by stipulation. No party may file a motion in limine (“MIL”) without first making a good faith effort to resolve/narrow the evidentiary issue with the opposing party.
Checked and corrected to match the court's document on Oct 1, 2026CRITICAL
Civil cases
Except for pro hac vice applications and motions to withdraw counsel, counsel must hold a good-faith conference at least three calendar days before the hearing and submit a declaration describing the conference and agreements at least one day before the hearing.
25. This Court believes that pre-filing conferences between counsel may be useful in avoiding unnecessary motions. Therefore, before the hearing of any motion, petition, or application, except applications to appear pro hac vice and motions to withdraw as counsel of record, all counsel and persons appearing in propria persona shall confer in a good faith attempt to eliminate the necessity of the hearing or to resolve as many disputes as possible. Counsel for the moving party shall arrange the conference to meet and confer at least three (3) calendar days before the hearing and shall submit to the Court at least one (1) day before the hearing a declaration establishing that the meet and confer conference occurred and describing any agreements that counsel have reached.
Checked and corrected to match the court's document on Oct 1, 2026CRITICAL
Before filing a motion in limine, parties or counsel must confer in good faith through an in-person meeting, telephone call, or video conference in an attempt to reach a stipulation.
Parties and/or counsel MUST meet and confer in good faith prior to filing Motions in Limine ("MIL") in an attempt to reach a stipulation, which should include an in-person meeting, or a telephone or video conference call. Merely exchanging letters, emails or voice-mail messages is insufficient.
Checked against the court's document on Oct 1, 2026CRITICAL
The party preparing a written order must make a good-faith effort to confer with the other parties before submitting it to the court.
The party preparing the written order must make a good faith effort to meet and confer with the other party(ies) about the order before submitting it to the Court.
Checked and corrected to match the court's document on Oct 1, 2026CRITICAL
Civil cases
Parties must meet and confer at least 35 days before the Pretrial Conference and make a good-faith effort to resolve evidentiary issues before filing a motion in limine.
The parties shall meet and confer no later than thirty-five (35) days before the Pretrial Conference to determine whether any evidentiary issues may be resolved by stipulation. No party may file a motion in limine without first making a good faith effort to resolve the evidentiary issue with the opposing party.
Checked and corrected to match the court's document on Oct 1, 2026CRITICAL
Civil cases
Before most hearings, counsel and self-represented parties must make a good-faith conference to eliminate the hearing or resolve disputes; pro hac vice applications and counsel-withdrawal motions are excepted.
Therefore, before the hearing of any motion, petition, or application, except applications to appear pro hac vice and motions to withdraw as counsel of record, all counsel and persons appearing in propria persona shall confer in a good faith attempt to eliminate the necessity of the hearing or to resolve as many disputes as possible.
Checked against the court's document on Oct 1, 2026WARNING
A party opposing an ex parte order may appear remotely unless the court orders otherwise under subdivision (d).
Parties opposing an ex parte order may appear remotely except as ordered by the court under subdivision (d).
Checked against the court's document on Oct 1, 2026WARNING
Parties are encouraged to hold an informal discovery conference before a motion to compel or another discovery motion, and counsel must exhaust all meet-and-confer obligations first.
In all probate cases, parties and non-parties are encouraged to hold an Informal Discovery Conference with the Court prior to filing a motion to compel or any other discovery motion. Counsel must have exhausted all meet and confer obligations before the Informed Discovery Conference.
Checked against the court's document on Oct 1, 2026WARNING
Parties are encouraged to hold an informal discovery conference before filing a discovery motion, but counsel must exhaust all meet-and-confer obligations before the conference.
(a) Informal Discovery Conference. In all family law proceedings as defined by CRC Rule 5.2(b)(3), parties are encouraged to hold an Informal Discovery Conference with the Court prior to filing a motion to compel or any other discovery motion. Counsel must have exhausted all meet and confer obligations before the Informal Discovery Conference.
Checked and corrected to match the court's document on Oct 1, 2026WARNING
Civil cases
Motions concerning administrative matters or other issues not seeking exclusion of specific evidence should not be presented as motions in limine.
Administrative and other motions not seeking to exclude specific evidence, e.g., excluding witnesses from the courtroom, requesting 24 hours’ notice of calling a witness, a review of demonstrative exhibits to be used at opening or closing, excluding speculative evidence, excluding evidence not produced in discovery (when that is the sole reason offered), precluding “reptile theory” arguments, should not be subject of an MIL.
Checked against the court's document on Oct 1, 2026WARNING
Failure to hold an informal discovery conference before a discovery motion may result in continuance of the motion and an order requiring an IDC.
If parties fail to hold an IDC prior to the filing of any discovery motion, the Court has the discretion to (and very likely will) continue your discovery motion and then Order the parties to an IDC.
Checked and corrected to match the court's document on Oct 1, 2026WARNING
Civil cases
Judge Fineman will hold substantive pretrial conferences to minimize surprises at trial.
Judge Fineman will be holding substantive Pre-Trial Conferences so that surprises at trial are minimized.
Checked against the court's document on Oct 1, 2026INFO
If the Informal Discovery Conference does not resolve a dispute, a party may proceed with a discovery motion in the assigned judge’s department.
If any discovery dispute is not resolved following the Informal Discovery Conference, any party may proceed to file and calendar hearing on a motion to compel or other discovery motion in the department of the Judge assigned to that probate case.
Checked against the court's document on Oct 1, 2026INFO
The Family Law Commissioner schedules and conducts informal discovery conferences; the conference does not adjudicate disputed facts or law, and its outcome does not bar or prejudice a later discovery motion.
(c) Conducted by Family Law Commissioner. Informal Discovery Conferences will be scheduled with and conducted by the Family Law Commissioner. As an Informal Discovery Conference does not involve the adjudication of any issue of disputed law or fact by the Family Law Commissioner, Code of Civil Procedure Section 170.6 does not apply. The outcome of an Informal Discovery Conference does not bar a party from subsequently filing a discovery motion or prejudice the disposition of a discovery motion.
Checked against the court's document on Oct 1, 2026INFO
In general civil cases, parties and non-parties are encouraged to hold an informal discovery conference before filing a discovery motion.
In all general civil cases as defined by CRC Rule 1.6(4), parties and non-parties are encouraged to hold an Informal Discovery Conference with the Court prior to filing a motion to compel or any other discovery motion.
Checked and corrected to match the court's document on Oct 1, 2026INFO
Civil cases
The parties may submit an agreed briefing schedule and proposed order if any reply is filed at least two weeks before the hearing.
So long as any reply is filed at least two (2) weeks before the hearing date, the parties may agree on any briefing schedule and submit a stipulation and proposed order with the agreed-upon schedule for the Court’s signature.
Not confirmed. Read the court's wording below.CRITICAL?
Prior to making a request with the Court, counsel shall obtain the consent of the opposing counsel(s) in writing to engage in an informal discovery conference.
Summary: Counsel must obtain opposing counsel’s written consent before requesting an Informal Discovery Conference from the Court.
Not confirmed. Read the court's wording below.CRITICAL?
Once responsive papers have been filed, the moving party shall contact the opposing party prior to the scheduled hearing and arrange to meet and confer (personally or by telephone) prior to the hearing. All parties and counsel are to make good faith efforts to resolve the issues pending before the court, and to inspect documents and exchange information so that issues may be resolved, facts agreed to by stipulation, and those issues remaining for determination be clearly delineated and expeditiously presented to the court at the time of the hearing. Failure to comply with the meet and confer requirements in good faith may result in the award of attorney’s fees and/or sanctions against the non-cooperating counsel or party. The inability of counsel to get along or communicate effectively is not an excuse for failure to meet and confer. The professional obligation of counsel to meet and confer in an effort to resolve disputes is an obligation owed to clients, the court, witnesses, children, and other litigants. This rule does not apply to harassment or domestic violence matters (See Rule 5.98 of the California Rules of Court).
Summary: After responsive papers are filed, the moving party must arrange a pre-hearing meet-and-confer, personally or by telephone, and all parties must negotiate in good faith; harassment and domestic-violence matters are exempt, and noncompliance may result in attorney’s fees or sanctions.
We could not find this wording in the court's document. Open the source before relying on it.CRITICAL?
Civil cases
No replies will be permitted without leave of the Court.
Machine summary
A reply to a motion in limine requires leave of the Court.
Not confirmed. Read the court's wording below.CRITICAL?
Civil cases
21. Discovery meet and confer obligations require an in person or videoconference between counsel and, where a party is appearing in propria persona, the parties, unless otherwise ordered by the Court. If a resolution is not reached, the parties must meet with the Court for all discovery-related matters in an informal discovery conference (IDC) before filing any discovery motion unless otherwise authorized by the Court. No discovery motion will be heard without an IDC.
Summary: Before filing a discovery motion, the parties must participate in an informal discovery conference unless the Court authorizes otherwise, and no discovery motion will be heard without an IDC.
Not confirmed. Read the court's wording below.CRITICAL?
Civil cases
25. This Court believes that pre-hearing conferences between counsel may be useful in avoiding useless, or mitigating inefficient, motion hearings. Therefore, in addition to meeting and conferring pre-filing, before the hearing of any motion, petition, or application, (except applications to appear pro hac vice and motions to withdraw as counsel of record), all counsel and persons appearing in propria persona shall confer in a good faith attempt to eliminate the necessity of the hearing or to resolve as many disputes as possible.
Summary: Before the hearing of any motion, petition, or application other than a pro hac vice application or a motion to withdraw as counsel, counsel and pro se persons must confer in good faith to try to eliminate or narrow the hearing.
Not confirmed. Read the court's wording below.CRITICAL?
Parties must comply with Local Rule 3.700 regarding mandatory Informal Discovery Conference (“IDC”) before filing a discovery motion. All IDCs are conducted by the Case Management Judicial Officer.
Summary: An Informal Discovery Conference conducted by the Case Management Judicial Officer is mandatory before filing a discovery motion.
Not confirmed. Read the court's wording below.CRITICAL?
Civil cases
Discovery meet and confer obligations require an in-person or video conference between counsel and persons appearing in propria persona unless otherwise ordered by the Court. If a resolution is not reached, the parties must meet with the Court for all discovery- related matters in an informal discovery conference (IDC) before filing any discovery motion unless otherwise authorized by the Court. No discovery motion will be heard without in IDC.
Summary: Unless the Court orders otherwise, counsel and pro se persons must meet in person or by video, and the parties must participate in an informal discovery conference before filing any discovery motion if the dispute is unresolved.
Not confirmed. Read the court's wording below.CRITICAL?
Civil cases
The parties shall meet and confer no later than twenty-one (21) days before the PTC to determine whether any evidentiary issues may be resolved by stipulation.
Summary: The parties must meet and confer no later than 21 days before the pretrial conference to determine whether evidentiary issues can be resolved by stipulation.
Not confirmed. Read the court's wording below.CRITICAL?
Civil cases
No party may file a motion in limine (“MIL”) without first making a good faith effort to resolve/narrow the evidentiary issue with the opposing party.
Summary: A party may not file a motion in limine without first making a good-faith effort to resolve or narrow the evidentiary issue with the opposing party.
Not confirmed. Read the court's wording below.CRITICAL?
Civil cases
21. Discovery meet and confer obligations require an in-person or video conference between counsel and, where a party is appearing in propria persona, the parties, unless otherwise ordered by the Court. If a resolution is not reached, the parties must meet with the Court for all discovery-related matters in an informal discovery conference (IDC) before filing any discovery motion unless otherwise authorized by the Court. No discovery motion will be heard without an IDC.
Summary: Parties must conduct an in-person or video discovery meet and confer, and any unresolved discovery dispute must be addressed in an informal discovery conference before a discovery motion is filed or heard unless the Court orders otherwise or authorizes an exception.
Not confirmed. Read the court's wording below.CRITICAL?
Civil cases
No party may file a motion in limine without first making a good faith effort to resolve the evidentiary issue with the opposing party.
Summary: A party must make a good-faith effort to resolve an evidentiary issue with the opposing party before filing a motion in limine.
Not confirmed. Read the court's wording below.CRITICAL?
Civil cases
The parties shall meet and confer no later than 35 days before the Pretrial Conference to determine whether any evidentiary issues may be resolved by stipulation.
Summary: The parties must meet and confer at least 35 days before the Pretrial Conference regarding possible stipulation of evidentiary issues.
Not confirmed. Read the court's wording below.CRITICAL?
Civil cases
The parties shall meet and confer no later than thirty-five (35) days before the Pretrial Conference to determine whether any evidentiary issues may be resolved by stipulation. No party may file a motion in limine without first making a good faith effort to resolve the evidentiary issue with the opposing party.
Summary: Parties must meet and confer at least 35 days before the Pretrial Conference and make a good-faith effort to resolve evidentiary issues before filing a motion in limine.
Not confirmed. Read the court's wording below.CRITICAL?
Civil cases
Counsel for the moving party shall arrange the conference to meet and confer at least three (3) calendar days before the hearing
Summary: Counsel for the moving party must arrange the pre-hearing conference to occur at least three calendar days before the hearing.
Not confirmed. Read the court's wording below.WARNING?
Informal Discovery Conferences in general civil cases are conducted remote only by Zoom, and are not recorded by any party and are not reported by any court reporter.
Summary: General civil Informal Discovery Conferences must be conducted remotely by Zoom and may not be recorded by a party or reported by a court reporter.
Not confirmed. Read the court's wording below.WARNING?
(d) Remote Only. Informal Discovery Conferences in family law cases are conducted remote only by Zoom, and are not recorded by any party and are not reported by any court reporter.
Summary: Family law informal discovery conferences must be conducted remotely by Zoom and may not be recorded by a party or reported by a court reporter.
We could not find this wording in the court's document. Open the source before relying on it.WARNING?
Civil cases
An MIL which argues that “no evidence on an issue should be introduced because there is no evidence on the issue” or because “there is other evidence that conflicts with the evidence sought to be suppressed” are not proper MILs.
Machine summary
A motion in limine is improper when it seeks admission or exclusion based merely on the absence of evidence or the existence of conflicting evidence.
Not confirmed. Read the court's wording below.WARNING?
all parties are encouraged to hold an Informal Discovery Conference (IDC) prior to filing a motion to compel or any other discovery motion.
Summary: Parties are encouraged to hold an informal discovery conference before filing a motion to compel or another discovery motion.
Not confirmed. Read the court's wording below.WARNING?
Civil cases
The parties shall meet and confer no later than thirty-five (35) days before the Pretrial Conference to determine whether any evidentiary issues may be resolved by stipulation. No party may file a motion in limine without first making a good faith effort to resolve the evidentiary issue with the opposing party.
Summary: Before filing a motion in limine, the parties must meet and confer no later than 35 days before the pretrial conference and make a good-faith effort to resolve the evidentiary issue.
We could not find this wording in the court's document. Open the source before relying on it.WARNING?
Civil cases
No replies will be permitted without leave of the Court.
Machine summary
Replies to motions in limine are not permitted without the Court’s leave.
We could not find this wording in the court's document. Open the source before relying on it.WARNING?
Civil cases
Her process is similar to the ones required by most federal judges and requires the parties to begin meeting-and-conferring well in advance of trial.
Machine summary
The parties must begin meeting and conferring well before trial as part of Judge Fineman's pretrial process.
Not confirmed. Read the court's wording below.INFO?
In all general civil cases as defined by CRC Rule 1.6(4), parties and non-parties are encouraged to hold an Informal Discovery Conference with the Court prior to filing a motion to compel or any other discovery motion.
Summary: Parties and non-parties are encouraged, but not required, to hold an Informal Discovery Conference before filing a discovery motion or motion to compel in a general civil case.
Not confirmed. Read the court's wording below.INFO?
Informal Discovery Conferences will be scheduled with and conducted by the Civil Commissioner.
Summary: Informal Discovery Conferences are scheduled and conducted by the Civil Commissioner.
Not confirmed. Read the court's wording below.INFO?
As an Informal Discovery Conference does not involve the adjudication of any issue of disputed law or fact by the Family Law Commissioner, Code of Civil Procedure Section 170.6 does not apply. The outcome of an Informal Discovery Conference does not bar a party from subsequently filing a discovery motion
Summary: Section 170.6 does not apply to an Informal Discovery Conference, and the conference outcome neither bars a later discovery motion nor prejudices its disposition.
Not confirmed. Read the court's wording below.INFO?
The Court waives any requirement for the parties involved in the discovery dispute to file “meet and confer” declarations pursuant to Code of Civil Procedure Sections 2016.040 prior to the Informal Discovery Conference.
Summary: Parties participating in an Informal Discovery Conference need not file a Code of Civil Procedure section 2016.040 meet-and-confer declaration before the conference.
Not confirmed. Read the court's wording below.INFO?
(b) Permissive Informal Discovery Conference with Third Parties. Informal Discovery Conferences are permitted for discovery disputes with non-parties as well, pursuant to the same procedures described below.
Summary: Informal discovery conferences are permitted for discovery disputes involving non-parties under the same procedures that apply to party disputes.
Not confirmed. Read the court's wording below.INFO?
Civil cases
The parties are encouraged to resolve trial issues with one another as soon as possible.
Summary: The parties are encouraged to resolve motions-in-limine issues with each other as soon as possible.
Not confirmed. Read the court's wording below.INFO?
Civil cases
The motions will be heard at the Pretrial Conference or at such other time as the Court may direct.
Summary: Motions in limine will be heard at the Pretrial Conference or at another time directed by the Court.
Not confirmed. Read the court's wording below.INFO?
In all general civil cases as defined by CRC Rule 1.6(4), parties and non-parties are encouraged to hold an Informal Discovery Conference with the Court prior to filing a motion to compel or any other discovery motion.
Summary: Parties and non-parties are encouraged, but not required, to hold an informal discovery conference before filing a motion to compel or another discovery motion in a general civil case.
Not confirmed. Read the court's wording below.INFO?
Civil cases
27. So long as any reply is filed at least two (2) weeks before the hearing date, the parties may agree on any briefing schedule and submit a stipulation and proposed order with the agreed-upon schedule for the Court’s signature.
Summary: If any reply is filed at least two weeks before the hearing, the parties may agree to a custom briefing schedule and submit a stipulation and proposed order for the Court's signature.
Does San Mateo Superior Court require a pre-motion conference or letter before filing a motion?
San Mateo Superior Court rules set a pre-motion procedure for ex parte. A party opposing an ex parte order may appear remotely unless the court orders otherwise under subdivision (d).
Judge Nicole S. Healy's rules set a pre-motion procedure for covered motions. Parties must meet and confer at least 35 days before the Pretrial Conference and make a good-faith effort to resolve evidentiary issues before filing a motion in limine.
Judge Mark A. McCannon's rules set a pre-motion procedure for covered motions. Except for pro hac vice applications and counsel-withdrawal motions, counsel and self-represented parties must confer in good faith at least three calendar days before the hearing, and moving counsel must submit a declaration of the conference and agreements at least one day before the hearing.
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