Judge A. Joel Richlin

The statement shall not exceed one page. The statement must be filed with the Court no later than five (5) court days before the Final Pretrial Conference date.

Motions in limine and oppositions thereto may be no more than 2,800 words, absent approval from the Court for an oversized brief upon a showing of good cause. Reply briefs, if any, may be no more than 2,100 words, absent approval for good cause.

The parties shall file a joint witness list no later than five (5) court days prior to the Final Pretrial Conference. The list shall include the full names of the witnesses in the order that they are expected to testify and provide, to the extent possible, an accurate estimate of the time needed for each witness for direct, cross, redirect, and re-cross.

The (Proposed) Findings of Fact must include citations to admitted evidence. Where witness trial testimony is necessary to establish a given fact, the party must obtain a transcript of the proceedings and file relevant excerpts of those transcripts with the (Proposed) Findings of Fact and Conclusions of Law.

At least 14 days before the meeting of counsel required by Local Rule 16-2 (which must occur at least 40 days before the date set for the Final Pretrial Conference), counsel for plaintiff(s) must serve on defense counsel proposed jury instructions and proposed verdict/special verdict forms. Within seven (7) days, defense counsel must serve objections, if any, to those instructions and verdict forms, as well as any proposed alternative or additional instructions and verdict forms.

In addition to filing, counsel must email Microsoft Word versions of their (Proposed) Findings of Fact and Conclusions of Law to the chambers email address: AJR_Chambers@cacd.uscourts.gov.

Unless otherwise ordered by the Court, all proposed jury instructions and verdict forms are to be filed no later than five (5) days prior to the Final Pretrial Conference date.

No later than five (5) court days before the Final Pretrial Conference, the parties are to file a case-specific glossary for the Court and reporter that includes applicable medical, scientific, or technical terms, slang, the names and spellings of case names likely to be cited, street/city/country names, all parties/entities involved in the case, names of people interviewed/deposed, names of family members, friends, or others who might be mentioned, and other case-specific terminology.

Counsel must not use objections for the purpose of making a speech, recapitulating testimony, or attempting to guide the witness.

Counsel should not address or refer to witnesses or parties by first name alone. Young witnesses (under 14) may, however, be addressed and referred to by first name.

Each party appearing in this action must be represented at the Final Pretrial Conference by lead trial counsel or the party if appearing pro se, unless excused for good cause. If a party is represented by co-lead trial counsel, all co-lead trial counsel must attend the Final Pretrial Conference.

Counsel must use the lectern for opening statements, examination of witnesses, and summation arguments.

When objecting, counsel must rise to state the objection and state only that counsel objects and the legal ground of objection. If counsel wishes to argue an objection further, counsel must ask for permission to do so.

Counsel should address all remarks to the Court. Counsel are not to address the Courtroom Deputy Clerk, the court reporter, persons in the audience, or opposing counsel while on the record. If counsel wish to speak with opposing counsel, counsel must ask permission to do so.

The parties are expected to comply with all Local Rules and the Federal Rules of Civil Procedure concerning discovery, as well as this Court’s procedures, found at http://www.cacd.uscourts.gov/honorable-joel-richlin.

Counsel and parties should rise when addressing the Court and when the jury enters or leaves the courtroom.

Strict compliance with Local Rule 16 is required. Note that the Court does not exempt parties without attorneys from the requirements of Rule 16. Failure to comply with these requirements may result in the Final Pretrial Conference being taken off calendar or continued, or other sanctions.

Counsel must not offer a stipulation unless counsel has conferred with

Counsel should not approach the Courtroom Deputy Clerk or the witness box without specific permission. If permission is given, counsel should return to the lectern when the purpose has been accomplished. Counsel should not question a witness at the witness stand.