Judge George H. Wu

At the FPTC, the Court will discuss with the parties which of the causes of action and affirmative defenses will, in fact, need to be tried to the jury. At that time, the Court will review the time estimate for the trial and, if necessary, set a specified time table for each party to present its claims/defenses (including the imposition of time limits on opening statements and closing arguments). Since the Court’s allotment of time to try the case will inevitably be less than the parties’ estimate, the Court will allocate the time generally giving the plaintiff’s side 55% to 60% and the defendant’s side 45% to 40%.

The proposed jury instructions are to be placed in the order in which they are to be read to the jury and printed in booklet form (i.e., fitting multiple instructions sequentially on each page).

Within seven (7) days of the initial arraignment before the Magistrate Judge, the Assistant United States Attorney assigned to the trial of the case and the defendant’s attorney shall meet and confer on the issue of discovery in this case including, but not limited, the items referenced in Federal Rules of Criminal Procedure 12, 12.1, 12.2, 12.3, 15 and 16.

(i) Disclose to defendant’s attorney its intent to use any statements or confessions made by the defendant. If defendant questions the admissibility of such statement or confession, the hearing required by Jackson v. Denno, 378 U.S. 368 (1964), shall be scheduled at the first status conference with the court;

(c) Permit defendant’s attorney to inspect and copy or photograph any relevant recorded testimony of the defendant before a grand jury;

(g) Advise defendant’s attorney of the existence or non-existence of any evidence in the possession of the Government obtained as the result of any electronic surveillance or wiretap;

(f) Permit defendant’s attorney to inspect, copy, or photograph any evidence favorable to the defendant;

(d) Permit defendant’s attorney to inspect and copy or photograph books, papers, documents, tangible objects, buildings, or places which are the property of the defendant and which are within the possession, custody, or control of the Government;

(e) Make known to the defendant’s attorney the defendant’s prior criminal record in the possession of the attorney for the Government;

(b) Permit defendant’s attorney to inspect and copy or photograph any relevant results or reports of physical or mental examinations, and of specific tests or experiments made in connection with the case, or copies thereof, within the possession, custody, or control of the Government, the existence of which is known, or may become known, to the attorney for the Government, and which are material to the defendant’s case;

(h) Advise defendant’s attorney of the contemplated use of informer testimony (fact of informer only, not name or testimony);

(a) Permit defendant’s attorney to inspect and copy or photograph any relevant written or recorded statements or confessions made by the defendant, or copies thereof, within the possession, custody, or control of the Government, the existence of which is known, or by the exercise of due diligence may become known, to the attorney for the Government;

(j) Give to defendant’s counsel a copy of the statements of all witnesses the government intends to call in its case in chief.

A moving party who files a reply/response to an opposition to a motion for summary judgment (where the opposing party has filed a “Statement of Genuine Disputes”) shall file a “Response to Statement of Genuine Disputes” using the format delineated below. Said Response will include each initially designated uncontroverted fact (and supporting evidence), and, if the opposing party has raised a dispute to the moving party’s fact, the moving party’s response (and any supporting evidence) to rebut the opposing party’s contentions.

Any evidentiary objections to materials filed in connection with summary judgment motions (for which a party desires the Court to specifically make a ruling) shall be delineated in a separate document (or documents) entitled 'Request for Evidentiary Ruling on Specified Objections.' Each objection shall: (1) cite to the evidentiary item and state its precise location by document name and Docket Number plus the page and line(s) where it appears, and (2) concisely articulate the bases for the objection(s). Objections will only be raised as to evidence (not to factual statements or factual characterizations in the opposing party's brief(s)). The Court will disregard any evidentiary objection(s) that do not comply with this instruction.

Indicate which of the three following actions will be taken if the application is denied: (1) Counsel will publically file the document(s) for consideration by the Court; (2) Attorney will retrieve the chambers copy of the document(s); or (3) Clerk will destroy the chambers copy of the document(s).

Attach a proposed order to the electronically filed application (standard procedure for filing application with a proposed order).

Electronically file the application to seal and the declaration giving notice or proof of service.

Electronically file a NOTICE OF MANUAL FILING indicating that the following have been submitted to the Court: (1) an application to seal; (2) a declaration giving notice or a proof of service; (3) a proposed order; and (4) the documents to be placed under seal.

All applications must provide reason(s) as to why the parties' interest to file the document(s) under seal outweighs the public's right to access.

If a party submits an application to file under seal pursuant to a protective order only (i.e., no other reason is given), the application will be denied unless the Court receives within 48 hours from the notice of filing a document providing (1) the reasons the document should be filed under seal; and (2) the portions within the document that are confidential. This document shall be entitled: "ADDENDUM TO APPLICATION TO FILE UNDER SEAL PURSUANT TO PROTECTIVE ORDER".

All applications must indicate which portions of the documents to be filed under seal are confidential.

At least ten (10) days before the FPTC, all counsel and pro se litigants will meet and confer in person so that at least five (5) days before the FPTC, the parties will have filed and provided to the Court “joint” versions of the following:

By “joint”, the Court means that the materials will be contained in a single document signed by all counsel and pro per litigants. In the preparation of said document, no party shall have the right to veto (i.e., exclude from the document) material proffered by any other party. However, areas of dispute or other differences shall be noted.

The most recent version of any form instruction is to be utilized.

Modifications of established jury instructions from the various sources must specifically indicate the change(s) made to the original form instruction and cite to the authority supporting the modification(s).

Any blanks or spaces are to be filled in by the parties.

At least twenty-one (21) days prior to the Final Pre-Trial Conference (henceforth “FPTC”), counsel for each party and pro per litigants1 must have prepared and exchanged with each other all of the following:

In addition to the joint proposed jury instruction booklet, the parties are to provide the court with a table listing each proposed instruction and the following information (at the time of the FPTC, only the first two columns need to be filled out):

During the trial, each party must advise its opponent(s) at least 24 hours in advance of the witnesses which it plans to call for the next day. Likewise, any chart or other item of demonstrative evidence (which is otherwise not a pre-marked exhibit) must be shown to the opponent(s) at least 48 hours before its intended use so that a hearing can conveniently be heard outside the presence of the jury, if necessary.

In numbering and marking the exhibits, the parties are to follow Local Rules 16-6 and 26-3.