Judge Dolly M. Gee
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Courtesy Copies
All filings
- Chambers Drop Off • By 5 00 P M On First Court Date After Filing
- Not required
Chambers Copy
- Upon request
Courtesy copies
- 1 copy
- Chambers Drop Off
- Hand Delivery
Discovery Motion
- Upon Filing
Adjournments
- Continuances are disfavored, and trial dates are firm and rarely changed.
- Requests to continue or extend dates must show essential good cause, compelling factual support, and due diligence.
- Continuance requests without compelling factual support and due diligence will not be approved
- +6 more
Request must include
- Continuance or extension requests should be submitted at least 5 court days before the scheduled date expires.
- Continuance requests should not be submitted less than 5 court days before expiration
Communication
Phone
Chambers
Phone
Clerk
Chambers
Page & Word Limits2 rules
Machine summary. Not checked yet.Mandatory?
See Local Rule 11-6. Only in rare instances and for good cause shown will the Court grant an application to extend these page limitations. No supplemental brief shall be filed without prior leave of Court.
Summary: Page limitations are strictly enforced with rare exceptions for good cause; supplemental briefs require prior leave.
Machine summary. Not checked yet.Note?
Short briefs (no more than five pages) addressing such disputed issues are welcome.
Summary: Short briefs (max 5 pages) addressing disputed issues are welcome.
Brief
5 pages
Applies to: Attorney
Document Format Requirements17 rules
Machine summary. Not checked yet.Mandatory?
The proposed amended pleading shall be serially numbered to differentiate it from previously amended pleadings.
Summary: Each proposed amended pleading must be serially numbered to distinguish it from prior amended pleadings.
Machine summary. Not checked yet.Mandatory?
The opposing party’s Statement of Genuine Disputes of Material Fact must be in two columns and track the movant’s separate statement exactly as prepared.
Summary: The opposing party’s Statement of Genuine Disputes must use a two-column format and exactly track the movant’s separate statement.
Machine summary. Not checked yet.Mandatory?
The Separate Statement of Uncontroverted Facts required under Local Rule 56-1 shall be prepared in a two-column format. The left-hand column sets forth the allegedly undisputed fact. The right-hand column sets forth the evidence that supports the factual statement.
Summary: Separate Statement of Uncontroverted Facts must use two-column format with fact and supporting evidence.
Machine summary. Not checked yet.Mandatory?
The opposing party’s Statement of Genuine Disputes of Material Fact must be in two columns and track the movant’s separate statement exactly as prepared. The left-hand column must restate the allegedly undisputed fact, and the right hand column must state either that it is undisputed or disputed.
Summary: Opposing party's Statement of Genuine Disputes must use two-column format tracking movant's statement.
Machine summary. Not checked yet.Mandatory?
The Separate Statement of Uncontroverted Facts required under Local Rule 56-1 shall be prepared in a two-column format.
Summary: The Local Rule 56-1 Separate Statement of Uncontroverted Facts must be formatted in two columns.
Machine summary. Not checked yet.Mandatory?
Chambers copies of under seal documents shall all be placed together in a manila envelope labeled "UNDER SEAL."
Summary: Under-seal chambers copies must be grouped together in a manila envelope labeled “UNDER SEAL.”
Machine summary. Not checked yet.Important?
Each document or sets of documents shall have a title page pursuant to Local Rule 11-3.8
Summary: Each sealed document or set must have a title page per Local Rule 11-3.8.
Machine summary. Not checked yet.Important?
If such evidence exceeds 200 pages, the documents shall be placed in a Slant D-Ring binder, with an index and with each item of evidence separated by a tab divider on the right side.
Summary: If documentary evidence exceeds 200 pages, it must be filed in a Slant D-Ring binder with an index and right-side tab dividers separating each item.
Machine summary. Not checked yet.Important?
If between 50-200 pages, the evidence must be separately bound and tabbed and include an index.
Summary: For documentary evidence between 50 and 200 pages, it must be separately bound, tabbed, and indexed.
Machine summary. Not checked yet.Important?
Each paragraph should contain a narrowly focused statement of fact. Each numbered paragraph should address a single subject as concisely as possible.
Summary: Each numbered paragraph should contain a narrowly focused fact and address only one subject concisely.
Machine summary. Not checked yet.Important?
The factual statements should be set forth in sequentially numbered paragraphs.
Summary: Factual statements should be presented in sequentially numbered paragraphs.
Machine summary. Not checked yet.Important?
The parties should prepare papers in a fashion that will assist the Court in absorbing the mass of facts (e.g., generous use of tabs, tables of contents, headings, indices, pinpoint citations, etc.).
Summary: Summary judgment papers should use organizational aids like tabs, tables of contents, headings, indices, and pinpoint citations.
Machine summary. Not checked yet.Important?
The opposing party may submit additional material facts that bear on or relate to the issues raised by the movant, which shall follow the format described above for the moving party’s separate statement.
Summary: If the opposing party submits additional material facts, they must follow the same format required for the moving party’s separate statement.
Machine summary. Not checked yet.Important?
If the fact is disputed, the Response shall restate the opposing party’s evidence and reason for disputing the asserted fact. The moving party may provide a response to the opposing party’s reason for dispute, including any reason why the evidence cited by the opposing party does not create a genuine dispute and/or any additional evidence relevant to the asserted fact. This response may either be presented in three columns, with the response appearing in the right-hand column, or in two columns, with a response provided below each fact.
Summary: For disputed facts, the response must address the opposing evidence/reason and may be formatted in either a three-column or two-column layout.
Machine summary. Not checked yet.Important?
The Response may also include any response to additional material facts asserted by the non-moving party, and this response shall follow the format described above for the Statement of Genuine Disputes of Material Fact. The response to these additional facts shall continue in sequentially numbered paragraphs, and shall not restart the numbering.
Summary: Responses to additional material facts must follow the same format and continue sequential paragraph numbering without restarting.
Machine summary. Not checked yet.Important?
All exhibits, declarations, etc. to chambers copies must be tabbed, where applicable. Blue-backs and hole punches are not required.
Summary: Chambers copies must include tabbed exhibits/declarations where applicable, and blue-backs and hole punches are not required.
Machine summary. Not checked yet.Note?
The parties should prepare papers in a fashion that will assist the Court in absorbing the mass of facts (e.g., generous use of tabs, tables of contents, headings, indices, pinpoint citations, etc.).
Summary: Summary judgment papers should use tabs, tables of contents, headings, indices, and pinpoint citations.
Document Filing Requirements56 rules
Machine summary. Not checked yet.Mandatory?
Any document filed under seal must also be linked to the court order granting permission to so file. See L.R. 79-5.2.2 (c) (eff. 12/1/15).
Summary: Documents filed under seal must be linked to the court order granting permission.
Document Type
Sealed Document
Machine summary. Not checked yet.Mandatory?
Note that, if you are the party that has designated a document confidential pursuant to a protective order, L.R. 79-5.2.2(b)(i) requires you to file a Declaration explaining why the documents should be filed under seal. You should use the "Sealed Declaration in Support" event to file this declaration.
Summary: Protective order declarations must use "Sealed Declaration in Support" event.
Document Type
Sealed Declaration
Machine summary. Not checked yet.Mandatory?
Your Application must be accompanied by: (1) a declaration; (2) a proposed order; (3) a redacted version of any documents of which only a portion is proposed to be filed under seal; and (4) an unredacted version of the documents proposed to be filed under seal. L.R. 79-5.2.2(a)-(b) (eff. 12/1/15).
Summary: Application for Leave to File Under Seal must include declaration, proposed order, redacted and unredacted documents.
Document Type
Application For Leave To File Under Seal
Machine summary. Not checked yet.Mandatory?
A Word Perfect or Microsoft Word version of the proposed order must be emailed to chambers as required by L.R. 5-4.4.2, and mandatory chambers copies of e-filed sealed documents must be provided to chambers pursuant to L.R. 5-4.5, just as with any e-filed documents. However, mandatory chambers copies must be provided in sealed envelopes, with a copy of the title page attached to the front of each envelope. L.R. 79-5.2.2(a).
Summary: Proposed orders must be emailed to chambers; sealed documents require sealed envelopes with title page.
Document Type
Sealed Document
Machine summary. Not checked yet.Mandatory?
Local Rule 79-5.2.2 requires that certain documents be filed with the Application: (1) a declaration; (2) a proposed order; (3) a redacted version of any documents of which only a portion is proposed to be filed under seal; and (4) an unredacted version of any documents proposed to be filed under seal.
Summary: Application for Leave to File Under Seal requires declaration, proposed order, redacted and unredacted documents.
Document Type
Application For Leave To File Under Seal
Machine summary. Not checked yet.Mandatory?
Mandatory Chambers Copies & Proposed Orders
Summary: Chambers copies and proposed orders are mandatory for sealed documents.
Document Type
Sealed Document
Machine summary. Not checked yet.Mandatory?
On the next screen, enter the document caption in the free text field. Remember that this text will be publicly visible, so do not include confidential information here. Click “Next.”
Summary: Document caption must be entered in a free text field and must not contain confidential information.
Document Type
Sealed Document
Machine summary. Not checked yet.Mandatory?
Items which must be addressed are the following: (1) initial disclosures, preservation of discoverable information, and a discovery plan, including a listing and proposed schedule of written discovery, depositions, and a proposed discovery cut-off date; (2) a listing and proposed schedule of law and motion matters, and a proposed dispositive motion cut-off date; (3) a statement of what efforts have been made to settle or resolve the case to date and what settlement procedure is recommended pursuant to Local Rule 16-15.4 (specifically excluding any statement of the terms discussed); (4) an estimated length of trial and a proposed date for the final pretrial conference and for trial;
Summary: Joint report must address discovery plan, motion schedule, settlement efforts, and trial timing.
Document Type
Scheduling Meeting Report
Machine summary. Not checked yet.Mandatory?
Counsel shall meet at least twenty-one (21) days in advance of the Scheduling Conference to prepare a jointly signed report for the court to be submitted no less than fourteen (14) days before the Scheduling Conference.
Summary: Counsel must meet 21 days before scheduling conference and submit joint report 14 days before.
Document Type
Scheduling Meeting Report
Machine summary. Not checked yet.Mandatory?
The joint report to be submitted shall contain the items listed in Fed. R. Civ. P. 26(f), the parties’ recommendations and agreements, if any, about the final scheduling order as listed in Fed. R. Civ. P. 16(b)(1) through (6), and those items listed in Fed. R. Civ. P. 16(c) which counsel believe will be useful to discuss at the Scheduling Conference.
Summary: Joint report must include items from Fed. R. Civ. P. 26(f), 16(b)(1)-(6), and 16(c).
Document Type
Scheduling Meeting Report
Machine summary. Not checked yet.Mandatory?
Counsel for plaintiff shall immediately serve this Order on all parties, including any new parties to the action.
Summary: Plaintiff's counsel must immediately serve this Order on all parties, including new parties.
Document Type
Order
Machine summary. Not checked yet.Mandatory?
The report to the Court as to the above items should be preceded by a thorough and frank discussion among the attorneys for the parties. A Joint Scheduling Report which does not comply with Fed. R. Civ. P. 16, 26(f), and this Order may cause continuance of the Scheduling Conference and a possible award of sanctions under Rule 16(f) against the party or parties responsible.
Summary: Joint Scheduling Report must comply with Fed. R. Civ. P. 16, 26(f), and this Order; non-compliance may result in continuance and sanctions.
Document Type
Joint Scheduling Report
Machine summary. Not checked yet.Mandatory?
Proposed order shall have an alternative signature line in case it's denied: (Add an option below for return of documents) 1. Attorney shall retrieve the chambers copy of the document(s); or, 2. Clerk destroys the chambers copy of the document(s).
Summary: Proposed order must include an alternative signature line with options for return of documents.
Document Type
Proposed Order
Machine summary. Not checked yet.Mandatory?
COUNSEL FOR PLAINTIFFS SHALL SERVE THIS ORDER IMMEDIATELY ON ALL PARTIES AND/OR THEIR COUNSEL, INCLUDING ANY NEW PARTIES TO THE ACTION. IF THIS CASE WAS REMOVED FROM STATE COURT, DEFENDANT WHO REMOVED THE CASE SHALL SERVE THIS ORDER ON ALL OTHER PARTIES.
Summary: Plaintiff's counsel must serve this order on all parties; if removed, removing defendant must serve.
Document Type
Standing Order
Machine summary. Not checked yet.Mandatory?
Plaintiff shall promptly serve the complaint in accordance with Fed. R. Civ. P. 4 and file the proofs of service pursuant to Local Rule 5-3.1. Any defendant not timely served under Fed. R. Civ. P. 4(m) shall be dismissed from the action without prejudice.
Summary: Plaintiff must serve complaint under FRCP 4 and file proof of service; unserved defendants dismissed without prejudice.
Document Type
Complaint
Machine summary. Not checked yet.Mandatory?
All discovery matters have been referred to the assigned United States Magistrate Judge, who will hear all discovery disputes. The Magistrate Judge's initials follow the District Judge's initials next to the case number. All discovery-related documents must include the words 'DISCOVERY MATTER' in the caption to ensure proper routing.
Summary: All discovery matters referred to Magistrate Judge; include 'DISCOVERY MATTER' in caption.
Document Type
Discovery Motion
Machine summary. Not checked yet.Mandatory?
All discovery-related documents must include the words “DISCOVERY MATTER” in the caption to ensure proper routing.
Summary: Discovery-related documents must include “DISCOVERY MATTER” in the caption.
Document Type
Discovery Related Document
Machine summary. Not checked yet.Mandatory?
Plaintiff shall promptly serve the complaint in accordance with Fed. R. Civ. P. 4 and file the proofs of service pursuant to Local Rule 5-3.1.
Summary: Plaintiff must promptly serve the complaint and file proof of service.
Document Type
Proof Of Service
Machine summary. Not checked yet.Mandatory?
In addition to the requirements of Local Rule 15-1, all motions to amend pleadings shall: (1) state the effect of the amendment and (2) identify the page and line number(s) and wording of any proposed change or addition of material. The proposed amended pleading shall be serially numbered to differentiate it from previously amended pleadings.
Summary: Motions to amend must state effect, identify changes by page/line, and be serially numbered.
Document Type
Motion To Amend
Machine summary. Not checked yet.Mandatory?
Counsel shall electronically file a “Notice of Lodging,” attaching the proposed amended pleading as a document separate from the motion,
Summary: Counsel must e-file a Notice of Lodging and attach the proposed amended pleading as a separate document from the motion.
Document Type
Motion To Amend
Machine summary. Not checked yet.Mandatory?
Counsel shall electronically file a “Notice of Lodging,” attaching the proposed amended pleading as a document separate from the motion, and shall attach as an appendix to the moving papers a “redlined” version of the proposed amended pleading indicating all additions and deletions of material.
Summary: Notice of Lodging required with proposed amended pleading and redlined version as appendix.
Document Type
Motion To Amend
Machine summary. Not checked yet.Mandatory?
and shall attach as an appendix to the moving papers a “redlined” version of the proposed amended pleading indicating all additions and deletions of material.
Summary: Moving papers must include an appendix with a redlined proposed amended pleading showing all additions and deletions.
Document Type
Motion To Amend
Machine summary. Not checked yet.Mandatory?
Parties need not wait until the motion cutoff to bring motions for summary judgment or partial summary judgment. The hearing on any such motion shall be set for a date in advance of the Final Pretrial Conference. Each side may bring one motion for summary judgment or partial summary judgment.
Summary: Summary judgment motions can be filed anytime before final pretrial conference; one per side allowed.
Document Type
Motion For Summary Judgment
Machine summary. Not checked yet.Mandatory?
In addition to the requirements of Local Rule 15-1, all motions to amend pleadings shall: (1) state the effect of the amendment and (2) identify the page and line number(s) and wording of any proposed change or addition of material.
Summary: Motions to amend must explain the amendment’s effect and specify page/line and wording of each proposed change or addition.
Document Type
Motion To Amend
Machine summary. Not checked yet.Mandatory?
The opposing party may dispute all or only a portion of the statement, but if disputing only a portion, it must clearly indicate what part is being disputed, followed by a brief citation to the opposing party’s evidence controverting the fact.
Summary: If disputing only part of a fact statement, the opposing party must identify the disputed part and provide a brief citation to controverting evidence.
Document Type
Statement Of Genuine Disputes Of Material Fact
Machine summary. Not checked yet.Mandatory?
To demonstrate that a fact is disputed, the opposing party must briefly state why it disputes the moving party’s asserted fact, cite to the relevant exhibit or other piece of evidence, and describe what it is in that exhibit or evidence that refutes the asserted fact.
Summary: To show a factual dispute, the opposing party must explain why, cite relevant evidence, and describe how that evidence refutes the asserted fact.
Document Type
Statement Of Genuine Disputes Of Material Fact
Machine summary. Not checked yet.Mandatory?
To demonstrate that a fact is disputed, the opposing party must briefly state why it disputes the moving party’s asserted fact, cite to the relevant exhibit or other piece of evidence, and describe what it is in that exhibit or evidence that refutes the asserted fact.
Summary: To dispute a fact, must state reason, cite evidence, and describe how evidence refutes the fact.
Document Type
Statement Of Genuine Disputes
Machine summary. Not checked yet.Mandatory?
The left-hand column sets forth the allegedly undisputed fact. The right-hand column sets forth the evidence that supports the factual statement.
Summary: In the separate statement, the left column must contain each allegedly undisputed fact and the right column must cite supporting evidence.
Document Type
Separate Statement Of Uncontroverted Facts
Machine summary. Not checked yet.Mandatory?
The left- hand column must restate the allegedly undisputed fact, and the right hand column must state either that it is undisputed or disputed.
Summary: In the opposing statement, the left column must restate each asserted fact and the right column must mark it as undisputed or disputed.
Document Type
Statement Of Genuine Disputes Of Material Fact
Machine summary. Not checked yet.Mandatory?
With its Reply, the moving party shall file a Response to the Statement of Genuine Disputes of Material Fact and Additional Material Facts. For each fact, the Response shall restate the allegedly undisputed fact and state whether the fact is disputed or undisputed by the opposing party. If the fact is undisputed, no further response is required.
Summary: A moving party must file a reply response that restates each fact and indicates whether it is disputed, with no further response needed for undisputed facts.
Document Type
Summary Judgment Reply Response
Machine summary. Not checked yet.Mandatory?
All facts asserted by either party, whether disputed or undisputed, and all supporting evidence cited, shall be included in the Response. DO NOT REPEAT DESCRIPTIONS OF AND CITATIONS TO THE EVIDENCE. If you have already described and cited the evidence once, simply refer to the earlier citation succinctly (e.g., See supra, Fact # 1).
Summary: The response must include all asserted facts and cited evidence, and parties must not repeat evidence descriptions or citations already provided.
Document Type
Summary Judgment Reply Response
Machine summary. Not checked yet.Mandatory?
Each party filing or opposing a motion or seeking the determination of any matter shall serve and electronically lodge a proposed order setting forth the relief or action sought and a brief statement of the rationale for the decision with appropriate citations. In addition, a copy of the Proposed Order in Word or WordPerfect format shall be emailed to Judge Gee's generic chambers e-mail address using the CM/ECF System on the day the document is e-filed.
Summary: Proposed order required for all motions, emailed to chambers in Word/WordPerfect format on filing day.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
Each party filing or opposing a motion or seeking the determination of any matter shall serve and electronically lodge a proposed order setting forth the relief or action sought and a brief statement of the rationale for the decision with appropriate citations.
Summary: Any party filing or opposing a motion must serve and electronically lodge a proposed order stating requested relief and a brief cited rationale.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
Ex parte applications that fail to conform to Local Rule 7-19 and 7-19.1, including a statement of opposing counsel's position, will not be considered except on a specific showing of good cause.
Summary: Ex parte applications must conform to Local Rules 7-19 and 7-19.1 or will not be considered
Document Type
Ex Parte Application
Machine summary. Not checked yet.Mandatory?
Following service of the ex parte papers by electronic service, fax, or personal service, the moving party shall notify the opposition that opposing papers must be e-filed no later than twenty-four (24) hours following service.
Summary: Opposing papers must be e-filed within 24 hours of ex parte service
Document Type
Ex Parte Application
Machine summary. Not checked yet.Mandatory?
Ex parte applications that fail to conform to Local Rule 7-19 and 7-19.1, including a statement of opposing counsel’s position, will not be considered except on a specific showing of good cause.
Summary: Ex parte applications must comply with Local Rules 7-19/7-19.1 and include opposing counsel’s position unless specific good cause is shown.
Document Type
Ex Parte Application
Machine summary. Not checked yet.Mandatory?
The moving party shall electronically serve the opposing party, if possible. A party is considered served once the ex parte application has been e-filed (all parties set up for electronic service are sent a notification of ECF filing each time a document is e-filed with a link to the document).
Summary: Ex parte applications must be electronically served if possible; service complete upon e-filing
Document Type
Ex Parte Application
Machine summary. Not checked yet.Mandatory?
Counsel requesting a continuance or extension of time must electronically file a stipulation and lodge a proposed order including a detailed declaration of the grounds for the requested continuance or extension of time.
Summary: Continuance/extension requests must be filed by stipulation and include a proposed order with a detailed declaration of grounds.
Document Type
Continuance Or Extension Request
Machine summary. Not checked yet.Mandatory?
On the following page, the party proposing the disputed instruction shall briefly state its response to the objection, and any authority in support of the instruction.
Summary: Proposing party must respond to objections with supporting authority.
Document Type
Jury Instructions
Machine summary. Not checked yet.Mandatory?
An index page shall accompany all jury instructions submitted to the Court. The index page shall indicate the following: a. The number of the instruction; b. A brief title of the instruction; c. The source of the instruction; and d. The page number of the instruction.
Summary: Index page required for jury instructions with specific details.
Document Type
Jury Instructions
Machine summary. Not checked yet.Mandatory?
The parties must submit JOINT jury instructions and a JOINT proposed verdict form.
Summary: Joint jury instructions and verdict form must be submitted.
Document Type
Jury Instructions
Machine summary. Not checked yet.Mandatory?
Each requested jury instruction shall be numbered and set forth in full on a separate page, citing the authority or source of the requested instruction.
Summary: Each jury instruction must be numbered and cited on separate page.
Document Type
Jury Instructions
Machine summary. Not checked yet.Mandatory?
Where the parties cannot agree, disputed instructions shall be submitted at least one week before trial as follows: (1) JOINT jury instructions (those instructions agreed to by all parties), and (2) DISPUTED jury instructions (those instructions propounded by a party to which another party objects).
Summary: Disputed jury instructions must be submitted at least one week before trial.
Document Type
Jury Instructions
Machine summary. Not checked yet.Mandatory?
On a separate page following each disputed jury instruction, the party opposing the instruction shall briefly state the basis for the objection, any authority in support thereof and, if applicable, an alternative instruction.
Summary: Opposing party must state basis for objection to disputed instructions.
Document Type
Jury Instructions
Machine summary. Not checked yet.Important?
Unless there is a likelihood that upon motion by a party the Court would order that any or all discovery is premature, it is advisable for counsel to begin to conduct discovery actively before the Scheduling Conference required by Fed. R. Civ. P. 16(b). At the very least, the parties shall comply fully with the letter and spirit of Fed. R. Civ. P. 26(a) and thereby obtain and produce most of what would be produced in the early stage of discovery, because at the Scheduling Conference the Court will impose tight deadlines to complete discovery.
Summary: Parties should begin discovery before scheduling conference and comply with Fed. R. Civ. P. 26(a).
Document Type
Discovery Plan
Machine summary. Not checked yet.Important?
No legal argument should be set forth in this document.
Summary: The Statement of Genuine Disputes should not contain legal argument.
Document Type
Statement Of Genuine Disputes Of Material Fact
Machine summary. Not checked yet.Important?
The opposing party may dispute all or only a portion of the statement, but if disputing only a portion, it must clearly indicate what part is being disputed, followed by a brief citation to the opposing party’s evidence controverting the fact.
Summary: When disputing only part of a statement, must clearly indicate disputed portion and cite opposing evidence.
Document Type
Statement Of Genuine Disputes
Machine summary. Not checked yet.Important?
The “Conclusions of Law” portion of the Statement should be inserted after the Statement of Uncontroverted Facts.
Summary: Any Conclusions of Law section in the statement should be placed after the Statement of Uncontroverted Facts.
Document Type
Separate Statement Of Uncontroverted Facts
Machine summary. Not checked yet.Important?
If a party disputes a fact based in whole or in part on an evidentiary objection, the ground of the objection should be succinctly stated in a separate statement of evidentiary objections in a two-column format. The left column should identify the items objected to (including page and line number if applicable) and the right column should set forth a concise objection (e.g., hearsay, lacks foundation, etc.) with a citation to the Federal Rules of Evidence or, where applicable, a case citation.
Summary: Evidentiary objections disputing facts should be filed in a separate two-column statement identifying the challenged material and stating concise, cited objections.
Document Type
Statement Of Evidentiary Objections
Machine summary. Not checked yet.Important?
Ex parte applications are solely for extraordinary relief and should be used with discretion. Sanctions may be imposed for misuse of ex parte applications.
Summary: Ex parte applications are for extraordinary relief only; misuse may result in sanctions
Document Type
Ex Parte Application
Machine summary. Not checked yet.Important?
Citations to case law must identify not only the case cited, but the specific page referenced.
Summary: Case law citations must include specific page numbers.
Document Type
Motion
Filing & Service rules
Electronic Filing Rules
Application to seal must be filed electronically.
Electronically file the application to seal and/or declaration giving notice or proof of service.
Machine summary. Not checked yet. · Criminal cases
Page 1 | INSTRUCTIONS TO ATTORNEYS PROCEDURES FOR FILING UNDER SEAL DOCUMENTS IN CRIMINAL CASES
Notice of manual filing must be filed electronically when sealing the application, proposed order, and documents.
Electronically file a NOTICE Of MANUAL FILING indicating that an application to seal, declaration giving notice or proof of service, proposed order sealing and under seal documents have been submitted to the Court.
Machine summary. Not checked yet. · Criminal cases
Page 2 | INSTRUCTIONS TO ATTORNEYS PROCEDURES FOR FILING UNDER SEAL DOCUMENTS IN CRIMINAL CASES
Courtesy Copy Requirements
Deliver chambers copies of discovery papers to assigned Magistrate Judge, not District Judge.
Counsel are directed to contact the Magistrate Judge's courtroom deputy clerk to schedule matters for hearing. Please comply with Local Rule 37 and deliver mandatory chambers copies of discovery-related papers to the Magistrate Judge assigned to this case rather than to this Court.
Machine summary. Not checked yet. · Civil cases
Page 2 | DISCOVERY
Mandatory chambers copies of discovery-related papers must be delivered to the assigned Magistrate Judge, not this Court.
Please comply with Local Rule 37 and deliver mandatory chambers copies of discovery-related papers to the Magistrate Judge assigned to this case rather than to this Court.
Machine summary. Not checked yet. · Civil cases
Page 2 | DISCOVERY
A conformed copy of moving papers and responses must be delivered to the Magistrate Judge’s courtroom deputy clerk when filed.
Counsel shall deliver a conformed copy of the moving papers and responses to the Magistrate Judge’s courtroom deputy clerk at the time of filing.
Machine summary. Not checked yet. · Civil cases
Page 3 | DISCOVERY
A chambers copy is required when documentary evidence supporting or opposing a motion is more than 50 pages.
If documentary evidence in support of or in opposition to a motion exceeds 50 pages, a Chambers copy is required.
Machine summary. Not checked yet. · Civil cases
Page 4 | MOTIONS - GENERAL REQUIREMENTS
Chambers copies must be delivered to courtesy box by 5:00 PM on first court date after filing
Judge's courtesy box, located outside of the Clerk's office, on the 4th floor, by 5:00 p.m. on the first court date after the filing date.
Machine summary. Not checked yet. · Civil cases
Page 9 | Chambers Copies
Under seal chambers copies must be placed in manila envelope labeled 'UNDER SEAL'
Chambers copies of under seal documents shall all be placed together in a manila envelope labeled 'UNDER SEAL.'
Machine summary. Not checked yet. · Civil cases
Page 9 | Chambers Copies
Courtesy copies must be placed in the Judge’s courtesy box by 5:00 p.m. on the first court date after filing.
Judge's courtesy box, located outside of the Clerk's office, on the 4th floor, by 5:00 p.m. on the first court date after the filing date.
Machine summary. Not checked yet. · Civil cases
Page 9 | COURTESY COPIES
Chambers copy required for motion evidence over 50 pages, with specific binding requirements based on page count.
If documentary evidence in support of or in opposition to a motion exceeds 50 pages, a Chambers copy is required. If between 50-200 pages, the evidence must be separately bound and tabbed and include an index. If such evidence exceeds 200 pages, the documents shall be placed in a Slant D-Ring binder, with an index and with each item of evidence separated by a tab divider on the right side.
Machine summary. Not checked yet. · Civil cases
In civil cases, courtesy copies are not required unless the Court specifically requests them.
No chambers copy is required for CIVIL cases, except at the specific request of the Court.
Machine summary. Not checked yet. · Civil cases
Page 8 | COURTESY COPIES
Exhibits and declarations in chambers copies must be tabbed
All exhibits, declarations, etc. to chambers copies must be tabbed, where applicable.
Machine summary. Not checked yet. · Civil cases
Page 9 | Chambers Copies
No courtesy copies required for civil cases unless specifically requested by the Court.
All original filings are to be filed electronically pursuant to Local Rule 5-4. No chambers copy is required for CIVIL cases, except at the specific request of the Court.
Machine summary. Not checked yet. · Civil cases
Page 8 | COURTESY COPIES
Sealing & Redaction Procedures
Application, proposed order, redacted documents, and docket entry are public; declaration and sealed documents are not.
The Application, the proposed order, any redacted documents, and the text of the docket entry itself will be visible to the public, so be sure to draft them accordingly. The declaration and the document(s) proposed to be filed under seal will not be publicly viewable.
Machine summary. Not checked yet. · Civil cases
Page 4 | OVERVIEW OF E-FILING PROCEDURES
Sealed documents are not accessible via NEF; filing party must serve them separately with certificate of service.
Documents electronically filed under seal will not be accessible through the Notice of Electronic Filing ("NEF"). The filing party is therefore responsible for serving all sealed documents and attachments on opposing counsel by other means. A certificate of service must be included with every sealed filing and a copy of the NEF should be served with the sealed
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Page 4 | OVERVIEW OF E-FILING PROCEDURES
Chambers copies of sealed documents must be in sealed envelopes with title page attached.
A Word Perfect or Microsoft Word version of the proposed order must be emailed to chambers as required by L.R. 5-4.4.2, and mandatory chambers copies of e-filed sealed documents must be provided to chambers pursuant to L.R. 5-4.5, just as with any e-filed documents. However, mandatory chambers copies must be provided in sealed envelopes, with a copy of the title page attached to the front of each envelope. L.R. 79-5.2.2(a).
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Page 5 | Mandatory Chambers Copies & Proposed Orders
Paper filing of sealed documents requires sealed envelopes with title page and PDF on CD.
If you cannot file a sealed document electronically due to a technical failure of CM/ECF, you must file it in paper pursuant to L.R. 5-4.6.2. The original and the judge’s copy of all such documents must be submitted for filing in separate sealed envelopes, with a copy of the title page attached to the front of each envelope. An additional copy must be provided in PDF format on a CD. L.R. 79-5.2.
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Page 6 | Problems Filing a Sealed Document
File Application, proposed order, and redacted documents as non-sealed event; file declaration and unredacted documents as sealed event.
Accordingly, you must file the Application, the proposed order, and any redacted documents using one, non-sealed, event ("Leave to File Under Seal"), and the declaration and unredacted documents using another, sealed event ("Sealed Declaration in Support").
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Page 7 | APPLICATION FOR LEAVE TO FILE UNDER SEAL
Application, proposed order, and redacted documents are publicly viewable; declaration and unredacted documents are sealed.
The rule specifies that the Application, the proposed order, and the redacted documents will be publicly viewable, while the declaration and the unredacted documents will not.
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Page 7 | APPLICATION FOR LEAVE TO FILE UNDER SEAL
Sealed documents must be served by other means; print and serve NEF with sealed document.
Note, however, that while all case participants will receive a NEF, sealed documents will not be accessible through the NEF. All sealed documents will be restricted from viewing. Therefore, you must serve all sealed documents by other means. Print the NEF and serve it and the sealed document on opposing counsel.
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Sealed documents must be served by other means; print and serve NEF with sealed document.
Note, however, that while all case participants will receive a NEF, sealed document(s) will not be accessible through the NEF. All sealed documents will be restricted from viewing. Therefore, you must serve all sealed documents by other means. Print the NEF and serve it and the sealed document on opposing counsel.
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Application for Leave for In Camera Review is publicly visible; confidential documents must be delivered to chambers if granted.
Remember that this event is NOT restricted. Your Application for Leave for In Camera Review will be publicly visible, so do not include confidential information, and do not attach the documents you wish the Court to review in camera. If your Application is granted, you will be responsible for delivering copies of the documents directly to the judge’s chambers, in accordance with the judge’s procedures.
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Page 43 | APPLICATION FOR LEAVE FOR IN CAMERA REVIEW
Sealed documents must be served by printing NEF and serving both NEF and sealed document on opposing counsel.
Therefore, you must serve all sealed documents by other means. Print the NEF and serve it and the sealed document on opposing counsel.
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Sealed documents are restricted from viewing and not accessible through the Notice of Electronic Filing (NEF).
Note, however, that while all case participants will receive a NEF, sealed documents will not be accessible through the NEF. All sealed documents will be restricted from viewing.
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Court order required to authorize filing of any sealed document; Application for Leave to File Under Seal must be filed first if no order exists.
Note that the Local Rule requires a court order to authorize the filing of any sealed document. If you answer the question above by selecting “Statute,” you will see a warning message. If you have not yet obtained a court order, you must first file an Application for Leave to File Under Seal, even if your document is authorized to be filed under seal by statute. You cannot continue with the filing process until you obtain such an order.
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Sealed documents must be linked to an existing order granting leave to file under seal.
You must next link your Sealed Document to an Order granting leave to file the document under seal. The next screen will either inform you that no orders have been filed, so docketing cannot continue, or present a list of orders previously entered in the case. Make a selection from this list, and click “Next.”
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Sealed document must be linked to an Order granting leave to file under seal; optional linking to other case documents.
The Sealed Document you are filing must be linked to an Order granting leave to file the document under seal. First, however, you will be presented with the option to link this Sealed Document to another document previously filed in the case. For instance, if the Sealed Document being filed is an exhibit to a summary judgment motion, check the box indicating that the document should be linked to another document in the case. If the Sealed Document does not need to be linked to another document, leave the box unchecked, and click “Next” to bypass the linking screen.
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Document upload screen must turn red to confirm sealed filing; if not red, restart the filing process.
If you select “A Court Order” from the screen shown above, clicking “Next” twice will bring you to the document upload screen. This is where you will upload your PDF documents. This screen should turn red. If the screen does not turn red, STOP; your documents will not be filed under seal. Go back to the Civil Events Screen and begin the docketing process for your Sealed Document again.
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Serve sealed documents by printing NEF and delivering sealed declaration and unredacted document to opposing counsel.
Print the NEF and serve it, the sealed declaration, and the unredacted document on opposing counsel.
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To seal only the document(s), file the application and proposed order electronically, then email the sealed documents to chambers.
REQUEST TO SEAL DOCUMENT(S) ONLY, NOT THE APPLICATION AND PROPOSED ORDER: Electronically file the application to seal and/or declaration giving notice or proof of service. During the electronic filing process, attach the proposed order to the application. See Local Rule 5-4.4.1.
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Page 1 | INSTRUCTIONS TO ATTORNEYS PROCEDURES FOR FILING UNDER SEAL DOCUMENTS IN CRIMINAL CASES
To seal the application, proposed order, and documents, file a notice of manual filing and email all materials to chambers.
REQUEST TO SEAL THE APPLICATION, PROPOSED ORDER AND DOCUMENT(S): Electronically file a NOTICE Of MANUAL FILING indicating that an application to seal, declaration giving notice or proof of service, proposed order sealing and under seal documents have been submitted to the Court.
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Page 2 | INSTRUCTIONS TO ATTORNEYS PROCEDURES FOR FILING UNDER SEAL DOCUMENTS IN CRIMINAL CASES
Filing Bundling Requirements
Only include materials to be sealed in the PDF; do not include non-sealed exhibits.
A PDF file that is too large to send by email may be split into several smaller PDFs. Each document or sets of documents shall have a title page pursuant to Local Rule 11-3.8, and should only contain the materials to be filed under seal. For example, DO NOT email a PDF of exhibits 1-40 if only exhibits 5, 20 and 39 are to be filed under seal.
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Page 1 | INSTRUCTIONS TO ATTORNEYS PROCEDURES FOR FILING UNDER SEAL DOCUMENTS IN CRIMINAL CASES
Pre-Motion Conference Requirements
Counsel must hold a pre-filing meet-and-confer under Local Rule 7-3 before motion practice.
Counsel must comply with Local Rule 7-3, which requires counsel to engage in a pre-filing conference “to discuss thoroughly . . . the substance of the contemplated motion and any potential resolution.”
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Page 3 | MOTIONS - GENERAL REQUIREMENTS
The pre-filing meet-and-confer requirement still applies even if one or more parties are pro se.
The pro se status of one or more parties does not negate this requirement.
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Page 3 | MOTIONS - GENERAL REQUIREMENTS
Adjournment & Extension Requirements
Requests to continue or extend dates must show essential good cause, compelling factual support, and due diligence.
Therefore, a stipulation to continue or extend the date of any matter before this Court must be supported by a sufficient factual basis that demonstrates good cause why the change in the date is essential. Without such compelling factual support and a showing of due diligence, stipulations continuing dates set by this Court will not be approved.
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Page 10 | CONTINUANCES
Continuance requests without compelling factual support and due diligence will not be approved
Without such compelling factual support and a showing of due diligence, stipulations continuing dates set by this Court will not be approved.
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Page 10 | Continuances
Non-compliance with Local Rules and this Order results in rejection without notice
Failure to comply with the Local Rules and this Order will result in rejection of the request without further notice to the parties.
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Page 10 | Continuances
Continuance requests require electronic filing of stipulation and proposed order with detailed declaration
Counsel requesting a continuance or extension of time must electronically file a stipulation and lodge a proposed order including a detailed declaration of the grounds for the requested continuance or extension of time.
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Page 10 | Continuances
Continuance requests must demonstrate good cause with sufficient factual basis
Therefore, a stipulation to continue or extend the date of any matter before this Court must be supported by a sufficient factual basis that demonstrates good cause why the change in the date is essential.
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Page 10 | Continuances
Requests to extend already-expired dates are presumptively a lack of due diligence
A request to continue or extend dates or deadlines that have already expired is presumptively a lack of due diligence.
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Page 10 | Continuances
Continuance or extension requests should be submitted at least 5 court days before the scheduled date expires.
Counsel shall avoid submitting requests for continuance or extension of time less than five (5) court days prior to the expiration of the scheduled date.
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Page 10 | CONTINUANCES
Court strongly disfavors changes to scheduled dates; trial dates are firm
This Court has a strong interest in keeping scheduled dates certain. Changes in dates are disfavored. Trial dates set by the Court are firm and will rarely be changed.
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Page 10 | Continuances
Continuances are disfavored, and trial dates are firm and rarely changed.
This Court has a strong interest in keeping scheduled dates certain. Changes in dates are disfavored. Trial dates set by the Court are firm and will rarely be changed.
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Page 10 | CONTINUANCES
Continuance requests should not be submitted less than 5 court days before expiration
Counsel shall avoid submitting requests for continuance or extension of time less than five (5) court days prior to the expiration of the scheduled date.
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Page 10 | Continuances
Proposed stipulations extending dates are not effective until Court orders
Proposed stipulations extending scheduling dates do not become effective unless and until this Court so orders.
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Page 10 | Continuances
Chambers Communication Rules
A Word or WordPerfect copy of the proposed order must be emailed to chambers the same day it is e-filed.
In addition, a copy of the Proposed Order in Word or WordPerfect format shall be emailed to Judge Gee’s generic chambers e-mail address using the CM/ECF System on the day the document is e-filed.
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Page 8 | PROPOSED ORDERS
Telephonic/video appearance requires 7-day advance notice, landline, and 15-minute early availability
If you wish to appear by telephone or video, you must (a) email the courtroom deputy clerk and copy opposing counsel at least seven (7) days in advance of the scheduled appearance; (b) in the case of telephonic appearances, use a landline to call into the bridge line provided by the clerk; and (c) be available at that number for at least 15 minutes before the time of the scheduled hearing.
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Page 9 | Telephonic and Video Hearings
Email the application, declaration, proposed order, and sealed documents to chambers with subject line including case number and 'UNDER SEAL REQUEST'.
send an email to the chambers email address at dmg_chambers@cacd.uscourts.gov., containing a PDF version of the application to seal, declaration giving notice or a proof of service, Word or WordPerfect version of the proposed order and a PDF version of the document(s) to be filed under seal. The subject line of the email should have the case number, including the words "UNDER SEAL REQUEST."
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Page 1 | INSTRUCTIONS TO ATTORNEYS PROCEDURES FOR FILING UNDER SEAL DOCUMENTS IN CRIMINAL CASES
Hearing dates generally need not be cleared in advance, except summary judgment and preliminary injunction motions must be cleared with the courtroom deputy clerk before filing.
It is not necessary to clear a hearing date with the judge’s courtroom deputy clerk before filing a motion, except for motions for summary judgment or preliminary injunction.
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Page 3 | MOTIONS - GENERAL REQUIREMENTS
Requests to appear by telephone or video require emailing the courtroom deputy clerk (copying opposing counsel) at least 7 days in advance.
If you wish to appear by telephone or video, you must (a) email the courtroom deputy clerk and copy opposing counsel at least seven (7) days in advance of the scheduled appearance;
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Page 9 | TELEPHONIC AND VIDEO HEARINGS
Counsel not opposing an ex parte application must notify the courtroom deputy clerk by phone.
If counsel does not intend to oppose an ex parte application, he or she must inform the courtroom deputy clerk at (213) 894-5452.
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Page 10 | EX PARTE APPLICATIONS
Counsel must notify courtroom deputy clerk if not opposing ex parte application
If counsel does not intend to oppose an ex parte application, he or she must inform the courtroom deputy clerk at (213) 894-5452.
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Page 9 | Ex Parte Applications
Telephonic/video appearances allowed with showing of undue hardship
The Court may permit appearances or arguments by way of telephone or video upon a showing that a personal appearance will cause undue hardship.
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Page 9 | Telephonic and Video Hearings