Judge John A. Kronstadt

Chambers copies required only for non-ECF materials

Mandatory chambers’ copies are to be submitted pursuant to Local Rule 5-4.5 (Civil). However, the Court only requires copies of materials that have not been filed on the electronic docket for this case (e.g., CD-ROMs, DVDs, USB drives, documents electronically filed in other cases or other districts). Mandatory chambers’ copies must be

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Page 2 | GENERAL REQUIREMENTS

3 copies of witness lists needed at trial (testimony order and alphabetical).

At the time of trial, counsel shall provide three (3) copies of the witness lists in the order in which the witnesses will be called to testify and three (3) copies of witness lists in alphabetical order.

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Page 59 | Witness Lists

Discovery papers must be delivered to Magistrate Judge's chambers, not District Judge.

Counsel are directed to contact the Magistrate Judge's Courtroom Deputy Clerk to schedule matters for hearing. Please deliver mandatory chambers' copies of discovery-related papers to the Magistrate Judge assigned to this case rather than to this Court.

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Chambers copies must be printed from CM/ECF with header visible; prefer single staple in upper left corner.

Mandatory chambers’ copies of documents that have been electronically filed must be printed from CM/ECF, and must include the CM/ECF-generated header (consisting of the case number, document control number, date of filing, page number, etc.). Any stapling or binding should not obscure the CM/ECF-generated header. The Court prefers that chambers’ copies not be two-hole punched or blue-backed; when possible, staple each copy only in the upper left hand corner.

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Class settlement motions require editable Excel courtesy copy emailed to chambers.

An editable, electronic courtesy copy shall be prepared in Microsoft Excel and emailed to the Court’s Chambers’ email at: jak_chambers@cacd.uscourts.gov formatted for use with Microsoft Excel.

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Courtesy copy of attorney fees tables must be emailed in editable Excel format.

The courtesy copy of the table shall be emailed to the Court’s Chambers’ email at: jak_chambers@cacd.uscourts.gov, which shall be prepared in Microsoft Excel and have all restrictions removed so that the spreadsheet can be edited.

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Chambers copies required only for materials not filed on electronic docket (e.g., external media, documents from other cases).

Mandatory chambers’ copies are to be submitted pursuant to Local Rule 5-4.5. However, the Court only requires copies of materials that have not been filed on the electronic docket for this case (e.g., CD-ROMs, DVDs, USB drives, documents electronically filed in other cases or other districts).

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Chambers copies must be delivered by 12:00 PM next day (same day for TROs).

Mandatory chambers’ copies must be delivered to the Clerk's Office, located in the First Street Courthouse, no later than 12:00 P.M. on the day following the filing of the document, with the exception of a document(s) relating to a temporary restraining order, which is to be submitted the day it is filed.

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Chambers copies required only for materials not filed on electronic docket, such as physical media or documents filed in other cases/districts.

Mandatory chambers' copies are to be submitted pursuant to Local Rule 5-4.5 (Civil). However, the Court only requires copies of materials that have not been filed on the electronic docket for this case (e.g., CD-ROMs, DVDs, USB drives, documents electronically filed in other cases or other districts).

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Page 2 | A. GENERAL REQUIREMENTS - 2. Mandatory Chambers' Copies

Mandatory chambers copies must include CM/ECF header, not obscure it with binding, and should be stapled in upper left corner without two-hole punching or blue-backing.

Mandatory chambers' copies must be printed from CM/ECF, and must include the CM/ECF-generated header (consisting of the case number, document control number, date of filing, page number, etc.). Any stapling or binding should not obscure the CM/ECF-generated header. The Court prefers that chambers' copies not be two-hole punched or blue-backed; when possible, staple each copy only in the upper left hand corner.

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Page 3 | GENERAL REQUIREMENTS

Chambers copies required only for non-ECF materials per Local Rule 5-4.5

Mandatory chambers’ copies are to be submitted pursuant to Local Rule 5-4.5 (Civil). However, the Court only requires copies of materials that have not been filed on the electronic docket for this case (e.g., CD-ROMs, DVDs, USB drives, documents electronically filed in other cases or other districts). Mandatory chambers’ copies must be

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Page 2 | A. GENERAL REQUIREMENTS

No courtesy copies required for applications, proposed orders, or other documents filed electronically, even if redacted or sealed.

(iii) No courtesy copy is necessary of the application, proposed order, or any other document(s), even if redacted or sealed, filed on the electronic docket for this case.

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Under seal applications require meet-and-confer 7 days before filing, with confirmation within 2 days.

Counsel shall comply with L. Cr. R. 49-1 with respect to serving and filing criminal documents under seal. All applications must provide the reason(s) why the parties’ interest in maintaining the confidentiality of the document(s) outweighs the public’s right of access to materials submitted in connection with a judicial proceeding. Counsel are ordered to meet and confer in person or by telephone at least seven (7) calendar days prior to the filing of an application in which the basis for the requested sealing is stated to determine if they can agree on the proposed under seal filing. Not later than two (2) calendar days after the meet and confer process has concluded, the non-proposing party shall confirm whether it agrees to having such information designated as confidential or whether it opposes an under seal filing. Any application for under seal filing, whether or not opposed, shall contain the dates and method by which the parties met and conferred. If such information is not provided, the application will be denied without prejudice to an amended application being filed that complies with the foregoing terms.

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Page 4 | UNDER SEAL DOCUMENTS

Must specify action if seal application is denied: file publicly, pick up chambers copies within 24 hours, or request destruction.

Indicate which of the three following actions will be taken if the application is denied: (i) Counsel will file the document(s) in their entirety for public view and consideration by the Court; (ii) Counsel will contact the Courtroom Deputy Clerk to pick up any chambers' copy(ies) of the document(s) within 24 hours; or (iii) Counsel will request that the Courtroom Deputy Clerk destroy any chambers' copy(ies) of the document(s).

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Page 5 | 1. For Requests to Seal Documents Only, Not the Application and Order

Government must file in camera witness list 14 days before Final Pretrial Conference

The Government shall file in camera a witness list no later than fourteen (14) calendar days prior to the Final Pretrial Conference.

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Page 10 | G. TRIAL REQUIREMENTS

Transcripts with designated material must have legend and page list with protection levels.

Transcripts containing designated material shall have a legend on the title page noting the presence of designated material, and the title page shall be followed by a list of all pages (including line numbers as appropriate) that have been designated, and the level of protection being asserted.

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Designation is allowed only if necessary to protect material from competitive or recognized harm.

Designation under this Order is allowed only if the designation is necessary to protect material that, if disclosed to persons not authorized to view it, would cause competitive or other recognized harm.

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Confidential/privileged information in sealed documents must be highlighted or bracketed.

Any sealed document must clearly mark the information that is confidential or privileged via highlighting in color and/or using brackets.

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If sealing granted, file redacted version with “Redacted” in title.

(ii) The redacted version of the entire document as its own docket entry. Unless otherwise stated in the order granting the application, a redacted version is required of all sealed documents. The title shall include “Redacted” as the first word of the title of the document.

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Parties must give advance notice for depositions with designated material.

Parties shall give advance notice if they expect a deposition or other proceeding to include designated material so that the other parties can ensure that only authorized individuals are present at those proceedings when such material is disclosed or used.

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Designators have up to 21 days from deposition to designate protected testimony.

For testimony given in deposition or other proceeding, the designator shall specify all protected testimony and the level of protection being asserted. It may make that designation during the deposition or proceeding, or may invoke, on the record or by written notice to all parties on or before the next business day, a right to have up to 21 days from the deposition or proceeding to make its designation.

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Filing designated material under seal requires court order or designator permission, not just designation.

Without written permission from the designator or a Court order, a party may not file in the public record in this action any designated material. A party seeking to file under seal any designated material must comply with Local Rule 79-5. Filings may be made under seal only pursuant to a court order authorizing the sealing of the specific material at issue. The fact that a document has been designated under this Order is insufficient to justify filing under seal.

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Sealed document titles must begin with “Unredacted” or “Sealed”.

The title shall include “Unredacted” or “Sealed” as the first word of the title of the document.

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File a separate redacted docket entry with declaration and all exhibits, including redacted exhibits.

• a separate redacted docket entry with the documents to include the declaration with all exhibits, including redacted exhibits, e-filed as an attachment to the declaration.

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If sealing granted, file unredacted version with highlighting/brackets for redacted content.

If the application is granted, counsel shall file: (i) The unredacted version of the entire document as its own docket entry. The title shall include “Unredacted” or “Sealed” as the first word of the title of the document. Any information that has been redacted or omitted from the public filing must be clearly marked via highlighting in color and/or using brackets.

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File one unredacted/sealed docket entry with declaration and all exhibits, including sealed exhibits.

• one unredacted/sealed docket entry with the documents to include the declaration with all exhibits, including sealed exhibits, e-filed as an attachment to the declaration;

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Denied sealing requests may be filed publicly unless designator seeks reconsideration within 4 days.

If a receiving party's request to file designated material under seal pursuant to Local Rule 79-5.1 is denied by the Court, then the receiving party may file the material in the public record unless (1) the designator seeks reconsideration within four (4) days of the denial, or (2) as otherwise instructed by the Court.

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Return or destroy all designated material within 60 days of final disposition with written certification.

Within 60 days after the final disposition of this action, each party shall return all designated material to the designator or destroy such material, including all copies, abstracts, compilations, summaries and any other format reproducing or capturing any designated material. The receiving party must submit a written certification to the designator by the 60-day deadline that (1) identifies (by category, where appropriate) all the designated material that was returned or destroyed, and (2) affirms that the receiving party has not retained any copies, abstracts, compilations, summaries or any other format reproducing or capturing any of the designated material.

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Filing under seal requires compliance with Local Rule 79-5.1 and this Order.

This Order does not automatically authorize the filing under seal of material designated under this Order. Instead, the parties must comply with Local Rule 79-5.1 and this Order if they seek to file anything under seal.

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Sealing applications must be filed on public docket with proposed order.

The application for leave to file under seal shall be filed on the public docket and shall attach a proposed order pursuant to Local Rule 5-4.4.1 and Local Rule 5-4.4.2.

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Closely related materials filed together must be considered a single document for sealing purposes.

Closely related materials filed at the same time where some are proposed to be filed under seal and others will not be sealed shall be considered as a single document and filed as a single docket entry containing multiple attachments.

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Meet and confer required at least 7 days before filing sealing application.

Counsel are ordered to meet and confer in person or by telephone at least seven (7) calendar days prior to the filing of an application in which the basis for the requested sealing is stated to determine if they can agree on the proposed under seal filing.

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Confidential/privileged information must be blacked out or document marked as entirely sealed.

Any information that is confidential or privileged must be blacked out or a page shall be inserted with the title of the document that indicates that the entire document is sealed.

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Designators must promptly notify parties when withdrawing mistaken designations.

If a designator learns that information or items that it designated for protection do not qualify for protection at all or do not qualify for the level of protection initially asserted, that designator must promptly notify all parties that it is withdrawing the mistaken designation.

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Only specific material qualifying under appropriate standards may be designated for protection.

Any party or non-party who designates information or items for protection under this Order as "CONFIDENTIAL," "HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY," or "HIGHLY CONFIDENTIAL – SOURCE CODE" (a "designator") must only designate specific material that qualifies under the appropriate standards.

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Unredacted documents must be filed under seal, either attached to sealed declaration or as separate entry.

The unredacted version of any document(s) shall be filed under seal. It may be attached to the declaration that supports the application, if the declaration is sealed and is filed as its own docket entry. Otherwise, it shall be filed as its own docket entry.

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Do not produce confidential material until protective order determination unless designator permits.

If the designator promptly seeks a protective order, the party served with the subpoena or court order shall not produce any information designated in this action as CONFIDENTIAL, HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY or HIGHLY CONFIDENTIAL – SOURCE CODE before a determination by the court where the subpoena or order issued, unless the party has obtained the designator’s permission.

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Non-proposing party must confirm agreement/opposition to sealing within 2 days after meet and confer.

Not later than two (2) calendar days after the meet and confer process has concluded, the non-proposing party shall confirm whether it agrees to having such information designated as confidential or whether it opposes an under seal filing.

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Applications to file under seal must explain why confidentiality outweighs public access rights.

Counsel shall comply with Local Rule 79-5. All applications must provide the reason(s) why the parties’ interest in maintaining the confidentiality of the document(s) outweighs the public’s right of access to materials submitted in connection with a judicial proceeding.

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Designators must affix applicable legend to each page containing protected material.

Designation under this Order requires the designator to affix the applicable legend ("CONFIDENTIAL," "HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY," or "HIGHLY CONFIDENTIAL – SOURCE CODE") to each page that contains protected material.

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Material available for inspection is treated as HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY until designation.

A party or non-party that makes original documents or materials available for inspection need not designate them for protection until after the inspecting party has identified which material it would like copied and produced. During the inspection and before the designation, all material shall be treated as HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY.

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Meet and confer required 7 days before sealing application; opposing party must respond within 2 days.

Because a party other than the designator will often be seeking to file designated material, cooperation between the parties in preparing, and in reducing the number and extent of, requests for under seal filing is essential. Accordingly, counsel are ordered to meet and confer in person or by telephone at least seven (7) calendar days prior to the filing of an application wherein the basis for the sealing is that it has been deemed confidential by the other party. Not later than two (2) calendar days after the meet and confer process, the opposing party shall confirm whether such information shall be designated as confidential or whether it can be made available to the public. Such an application shall contain the dates and method by which the parties met and conferred otherwise it will be denied without prejudice to an amended application being filed after counsel have completed this process.

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Sealing applications must include meet and confer dates and methods.

Any application for under seal filing, whether or not opposed, shall contain the dates and method by which the parties met and conferred.

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Transcripts prepared before 21-day designation period are treated as HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY.

Any transcript that is prepared before the expiration of the 21-day period for designation shall be treated during that period as if it had been designated HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY unless otherwise agreed.

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Under seal filings require compliance with L. Cr. R. 49-1, justification for confidentiality, and a 7-day meet-and-confer process with 2-day response deadline; applications must document the meet-and-confer process.

Counsel shall comply with L. Cr. R. 49-1 with respect to serving and filing criminal documents under seal. All applications must provide the reason(s) why the parties' interest in maintaining the confidentiality of the document(s) outweighs the public's right of access to materials submitted in connection with a judicial proceeding. Counsel are ordered to meet and confer in person or by telephone at least seven (7) calendar days prior to the filing of an application in which the basis for the requested sealing is stated to determine if they can agree on the proposed under seal filing. Not later than two (2) calendar days after the meet and confer process has concluded, the non-proposing party shall confirm whether it agrees to having such information designated as confidential or whether it opposes an under seal filing. Any application for under seal filing, whether or not opposed, shall contain the dates and method by which the parties met and conferred. If such information is not provided, the application will be denied without prejudice to an amended application being filed that complies with the foregoing terms.

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Page 4 | UNDER SEAL DOCUMENTS

Sealing applications must specify action if denied: public filing, pickup within 24 hours, or destruction; uncollected documents destroyed after 24 hours.

Indicate which of the three following actions will be taken if the application is denied: (i) Counsel will file the document(s) in their entirety for public view and consideration by the Court; (ii) Counsel will contact the Courtroom Deputy Clerk to pick up any chambers' copy(ies) of the document(s) within 24 hours; or (iii) Counsel will request that the Courtroom Deputy Clerk destroy any chambers' copy(ies) of the document(s). Note: If counsel opt for (b) above and do not contact the Courtroom Deputy Clerk within 24 hours, the documents will be destroyed.

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Page 5 | UNDER SEAL DOCUMENTS

Redacted documents must include the word 'redacted' in the title.

Redacted documents shall conform to paragraph (b) above. However, the document shall include the word redacted in the title, i.e., JOHN DOE'S (2) MEMORANDUM [REDACTED].

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Sealed documents must clearly mark confidential/privileged information via highlighting and/or brackets.

Any sealed document must clearly mark the information that is confidential or privileged via highlighting in color and/or using brackets.

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Sealed documents must comply with L. Cr. R. 49-1 and justify confidentiality over public access.

Counsel shall comply with L. Cr. R. 49-1 with respect to serving and filing criminal documents under seal. All applications must provide the reason(s) why the parties’ interest in maintaining the confidentiality of the document(s) outweighs the public’s right of access to materials submitted in connection with a judicial proceeding.

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Page 4 | D. UNDER SEAL DOCUMENTS

Sealing applications must include meet and confer dates and method; missing information results in denial without prejudice.

Any application for under seal filing, whether or not opposed, shall contain the dates and method by which the parties met and conferred. If such information is not provided, the application will be denied without prejudice to an amended application being filed that complies with the foregoing terms.

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Page 4 | D. UNDER SEAL DOCUMENTS

Meet and confer required 7 days before sealing application; non-proposing party must respond within 2 days.

Counsel are ordered to meet and confer in person or by telephone at least seven (7) calendar days prior to the filing of an application in which the basis for the requested sealing is stated to determine if they can agree on the proposed under seal filing. Not later than two (2) calendar days after the meet and confer process has concluded, the non-proposing party shall confirm whether it agrees to having such information designated as confidential or whether it opposes an under seal filing.

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Page 4 | D. UNDER SEAL DOCUMENTS

Chambers copies will be destroyed if not picked up within 24 hours of seal denial.

If counsel opt for (b) above and do not contact the Courtroom Deputy Clerk within 24 hours, the documents will be destroyed.

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Page 5 | 1. For Requests to Seal Documents Only

CONFIDENTIAL material may be disclosed without further approval only to specified categories of persons who have signed the Agreement to Be Bound.

Unless otherwise ordered by the Court or permitted in writing by the designator, a receiving party may disclose any material designated CONFIDENTIAL only to: 4.2.1 The receiving party's outside counsel of record in this action and employees of outside counsel of record to whom disclosure is reasonably necessary; 4.2.2 The officers, directors, and employees of the receiving party to whom disclosure is reasonably necessary, and who have signed the Agreement to Be Bound (Exhibit E-1); 4.2.3 Experts retained by the receiving party's outside counsel of record to whom disclosure is reasonably necessary, and who have signed the Agreement to Be Bound (Exhibit E-1); 4.2.4 The Court and its personnel; 4.2.5 Outside court reporters and their staff, professional jury or trial consultants, and professional vendors to whom disclosure is reasonably necessary, and who have signed the Agreement to Be Bound (Exhibit E-1); 4.2.6 During their depositions, witnesses in the action to whom disclosure is reasonably necessary and who have signed the Agreement to Be Bound (Exhibit E-1); and 4.2.7 The author or recipient of a document containing the material, or a custodian or other person who otherwise possessed or knew the information.

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Inadvertent failures to designate do not waive protection; recipients must treat material according to the order upon correction.

An inadvertent failure to designate does not, standing alone, waive protection under this Order. Upon timely assertion or correction of a designation, all recipients must make reasonable efforts to ensure that the material is treated according to this Order.

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Designated material may only be used for this litigation and disclosed to specified categories of persons.

A receiving party may use designated material only for this litigation. Designated material may be disclosed only to the categories of persons and under the conditions described in this Order.

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HIGHLY CONFIDENTIAL material may be disclosed without further approval only to specified categories of persons who have signed the Agreement to Be Bound.

Unless permitted in writing by the designator, a receiving party may disclose material designated HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY or HIGHLY CONFIDENTIAL – SOURCE CODE without further approval only to: 4.3.1 The receiving party's outside counsel of record in this action and employees of outside counsel of record to whom it is reasonably necessary to disclose the information; 4.3.2 The Court and its personnel; 4.3.3 Outside court reporters and their staff, professional jury or trial consultants, and professional vendors to whom disclosure is reasonably necessary, and who have signed the Agreement to Be Bound (Exhibit E-1); and 4.3.4 The author or recipient of a document containing the material, or a custodian or other person who otherwise possessed or knew the information.

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Disclosure of HIGHLY CONFIDENTIAL material to in-house counsel or experts requires written agreement from the designator.

Unless agreed to in writing by the designator:

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Challenges to confidentiality designations must follow Local Rules 37-1 through 37-4.

All challenges to confidentiality designations shall proceed under Local Rule 37-1 through Local Rule 37-4.

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Archival copies of certain materials may be retained despite containing designated material.

This provision shall not prevent counsel from retaining an archival copy of all pleadings, motion papers, trial, deposition and hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work product, and consultant and expert work product, even if such materials contain designated material. Any such archival copies remain subject to this Order.

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Motions must be filed 14 days before hearing with 10-page limit; oppositions 7 days before with 10-page limit; replies optional 3 days before with 5-page limit; proposed orders not required.

All motions shall be filed fourteen (14) days prior to the hearing date. The supporting memorandum shall not exceed ten (10) pages. Any opposition shall be filed seven (7) days prior to the hearing date and shall not exceed ten (10) pages. The Court does not require a reply. However, if a party elects to file one, it shall be filed three (3) days prior to the hearing date by 12:00 p.m., and shall not exceed five (5) pages. Proposed orders for motions are not required to be filed or submitted to the Judge's Chambers' email.

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Pre-filing conference required to discuss motion substance and potential resolution; pro se status doesn't exempt.

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.” Counsel should discuss the issues to a sufficient degree that if a motion is still necessary, the briefing may be directed to those substantive issues requiring resolution by the Court. Counsel should resolve minor procedural or other non-substantive matters during the conference. The in propria persona status of one or more parties does not alter this requirement.

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For hearings >70 days out: opposition due 21 days after filing, reply due 35 days after filing.

(b). Any motion that is filed and set for a hearing more than 70 days from the date of the filing of the motion: (i) any opposition must be filed no later than 21 days after the filing of the motion; and (ii) any reply must be filed no later than 35 days after the filing of the motion.

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For hearings 35-70 days out: opposition due 14 days after filing, reply due 21 days after filing.

(a). Any motion that is filed and set for a hearing between 35 and 70 days from the date of the filing of the motion: (i) any opposition must be filed no later than 14 days after the filing of the motion; and (ii) any reply must be filed no later than 21 days after the filing of the motion.

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Motions must be filed 14 days before hearing; support/opposition limited to 10 pages; reply (optional) limited to 5 pages and due 3 days before hearing.

All motions shall be filed fourteen (14) days prior to the hearing date. The supporting memorandum shall not exceed ten (10) pages. Any opposition shall be filed seven (7) days prior to the hearing date and shall not exceed ten (10) pages. The Court does not require a reply. However, if a party elects to file one, it shall be filed three (3) days prior to the hearing date by 12:00 p.m., and shall not exceed five (5) pages. Proposed orders for motions are not required to be filed or submitted to the Judge's Chambers' email.

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Scheduling conference will be held pursuant to Fed. R. Civ. P. 16 and 26(a).

The Court is prepared to issue a scheduling order in this matter. If a hearing is necessary, the scheduling conference will be held on the date listed in the caption. The conference will be held pursuant to Fed. R. Civ. P. 16 and Fed. R. Civ. P. 26(a).

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Page 40 | ORDER SETTING RULE 16(b)/26(f) SCHEDULING CONFERENCE

Motions with hearing <35 days follow Local Rules 6-1 and 7 for briefing.

Any motion that is filed and set for a hearing to be held fewer than 35 days from the date of the filing of the motion shall be briefed pursuant to Local Rule 6-1 and Local Rule 7.

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Parties may stipulate to briefing schedule for hearings >70 days out if reply filed 5 weeks before hearing; stipulation due within 7 days with specific caption.

The Court will permit the parties to stipulate, without a court order, to a briefing schedule for any motion that is set for a hearing to be held more than 70 days from the date it was filed so long as the reply is filed no later than five (5) weeks prior to the hearing date. A stipulation regarding the agreed-upon briefing schedule shall be filed with the Court within seven (7) calendar days from the date the motion is filed. The stipulation shall include in the caption “STIPULATED PER STANDING ORDER.”

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Settlement conference or mediation must be completed within 30 days of final ruling on all motions.

Last day to conduct settlement conference or mediation (within 30 days of the Court’s final ruling on all motions)

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Page 7 | EXHIBIT A - SCHEDULE OF DATES FOR CIVIL JURY TRIALS

All pretrial documents and motions in limine must be filed 2 weeks after completing settlement.

Last day to file all pretrial documents and motions in limine (2 weeks after last day to complete settlement)

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Page 7 | EXHIBIT A - SCHEDULE OF DATES FOR CIVIL JURY TRIALS

Notice of Settlement or Joint Report must be filed 1 week after completing settlement.

Notice of Settlement / Joint Report re Settlement (1 week after last day to complete settlement)

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Page 7 | EXHIBIT A - SCHEDULE OF DATES FOR CIVIL JURY TRIALS

Jury trial scheduled 6 weeks after settlement completion on Tuesday at 9:00 a.m.

Jury Trial (6 weeks after last day to complete settlement: Tuesday at 9:00 a.m.)

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Page 7 | EXHIBIT A - SCHEDULE OF DATES FOR CIVIL JURY TRIALS

Final Pretrial Conference and related hearings scheduled 4 weeks after settlement completion on Monday at 1:30 pm.

Final Pretrial Conference, Status Conference re Disputed Exhibits, and Hearing on Motions in Limine (4 weeks after last day to complete settlement: Monday at 1:30 pm)

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Page 7 | EXHIBIT A - SCHEDULE OF DATES FOR CIVIL JURY TRIALS

Responses to motions in limine must be filed 3 weeks after completing settlement.

Last day to file response to motions in limine (3 weeks after last day to complete settlement)

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Page 7 | EXHIBIT A - SCHEDULE OF DATES FOR CIVIL JURY TRIALS

Court trial scheduled 6 weeks after settlement completion on Tuesday at 9:00 a.m.

Court Trial (6 weeks after last day to complete settlement: Tuesday at 9:00 a.m.)

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Page 8 | EXHIBIT A - SCHEDULE OF DATES FOR CIVIL COURT TRIALS

Ruling on direct testimony declarations anticipated 4 weeks after completing settlement.

Anticipated ruling on direct testimony declarations (4 weeks after last day to complete settlement)

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Page 8 | EXHIBIT A - SCHEDULE OF DATES FOR CIVIL COURT TRIALS

Objections to direct testimony declarations must be filed 3 weeks after completing settlement.

Last day to file objections to direct testimony declarations (3 weeks after last day to complete settlement)

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Page 8 | EXHIBIT A - SCHEDULE OF DATES FOR CIVIL COURT TRIALS

All pretrial documents and direct testimony declarations must be filed 2 weeks after completing settlement.

Last day to file all pretrial documents and direct testimony declarations (2 weeks after last day to complete settlement)

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Page 8 | EXHIBIT A - SCHEDULE OF DATES FOR CIVIL COURT TRIALS

Final Pretrial Conference and related hearings scheduled 4 weeks after settlement completion on Monday at 1:30 pm.

Final Pretrial Conference and Status Conference re Disputed Exhibits (4 weeks after last day to complete settlement: Monday at 1:30 pm)

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Page 8 | EXHIBIT A - SCHEDULE OF DATES FOR CIVIL COURT TRIALS

Continuance requests must be e-filed with proposed order at least 7 days before scheduled date.

Counsel requesting a continuance must e-file any application or stipulation with a proposed order, which shall include a detailed explanation of the grounds for the requested continuance or other extension of time. The Court will not consider any request that does not comply with the Local Rules and this Order. Applications or stipulations extending dates become effective only if, and when, approved by this Court and an associated order is entered. Counsel shall submit requests for a continuance at least seven (7) calendar days prior to the scheduled date.

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Page 4 | CONTINUANCES

48-hour advance notice required for voluminous exhibits; security pass needed for loading dock access.

Arrangements for bringing voluminous trial materials or exhibits into the Courtroom through the Building Vehicle Loading Dock, if required, may be made through the Space & Facilities Help Desk at 213-894-1400. Before contacting Space & Facilities for a required security pass, prior approval of delivery time must be coordinated with the Courtroom Deputy Clerk. Once approval from the Clerk is received, logistical delivery information must be provided to Space & Facilities no later than 48 hours prior to the date of arrival to create and issue the required security pass. Counsel and messengers attempting to access the building parking and loading dock without a required pass will be denied entry.

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Page 13 | Voluminous/Security Prone Trial Exhibits/Materials

Continuance requests must be made at least 7 days before the hearing date.

Any request for a continuance shall be made no later than seven (7) days prior to the date of the hearing.

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Dispositive motions must be filed within 28 days after close of discovery.

All dispositive motions shall be filed no later than 28 days after the close of discovery.

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Page 37 | 4.5 Final Day for Filing Dispositive Motions

Provide delivery information to Space & Facilities within 48 hours of arrival date.

Once approval from the Clerk is received, logistical delivery information must be provided to Space & Facilities no later than 48 hours of the date of arrival to create and issue the required security pass.

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Page 62 | Exhibits

Notice of Settlement or Joint Report must be filed 1 week after completing settlement.

Notice of Settlement / Joint Report re Settlement (1 week after last day to complete settlement)

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Jury trial scheduled 6 weeks after settlement completion on Tuesday at 9:00 a.m.

Jury Trial (6 weeks after last day to complete settlement: Tuesday at 9:00 a.m.)

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Discovery motions must be heard by the discovery cut-off date.

Any motion with respect to the inadequacy of responses to discovery must be heard by the discovery cut-off date.

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Objections to direct testimony declarations must be filed 3 weeks after completing settlement.

Last day to file objections to direct testimony declarations (3 weeks after last day to complete settlement)

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The Court will not rule on TRO/injunction applications for at least 24 hours after service unless service is excused.

The Court will not rule on any application for such relief for at least 24 hours after the party subject to the requested order has been served, unless service is excused.

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Continuance requests for Scheduling Conference require written request with proposed order, e-filed at least 1 week in advance.

Continuance: A continuance of the Scheduling Conference will be granted only for good cause, following a written request with a proposed order to be e-filed at least one (1) week in advance of the Scheduling Conference.

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Court trial scheduled 6 weeks after settlement completion on Tuesday at 9:00 a.m.

Court Trial (6 weeks after last day to complete settlement: Tuesday at 9:00 a.m.)

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Settlement conference or mediation must be completed within 30 days of final ruling on all motions.

Last day to conduct settlement conference or mediation (within 30 days of the Court’s final ruling on all motions)

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Final Pretrial Conference and related hearings scheduled 4 weeks after settlement completion on Monday at 1:30 pm.

Final Pretrial Conference and Status Conference re Disputed Exhibits (4 weeks after last day to complete settlement: Monday at 1:30 pm)

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All pretrial documents and direct testimony declarations must be filed 2 weeks after completing settlement.

Last day to file all pretrial documents and direct testimony declarations (2 weeks after last day to complete settlement)

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Responses to motions in limine must be filed 3 weeks after completing settlement.

Last day to file response to motions in limine (3 weeks after last day to complete settlement)

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Ruling on direct testimony declarations anticipated 4 weeks after completing settlement.

Anticipated ruling on direct testimony declarations (4 weeks after last day to complete settlement)

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All pretrial documents and motions in limine must be filed 2 weeks after completing settlement.

Last day to file all pretrial documents and motions in limine (2 weeks after last day to complete settlement)

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Final Pretrial Conference and related hearings scheduled 4 weeks after settlement completion on Monday at 1:30 pm.

Final Pretrial Conference, Status Conference re Disputed Exhibits, and Hearing on Motions in Limine (4 weeks after last day to complete settlement: Monday at 1:30 pm)

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Continuance requests must be e-filed with proposed order and detailed explanation at least 7 calendar days before the scheduled date, and only become effective upon court approval.

Counsel requesting a continuance must e-file any application or stipulation with a proposed order, which shall include a detailed explanation of the grounds for the requested continuance or other extension of time. The Court will not consider any request that does not comply with the Local Rules and this Order. Applications or stipulations extending dates become effective only if, and when, approved by this Court and an associated order is entered. Counsel shall submit requests for a continuance at least seven (7) calendar days prior to the scheduled date.

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Page 4 | CONTINUANCES

Continuance requests must be made at least 7 days before the hearing date.

Any request for a continuance shall be made no later than seven (7) days prior to the date of the hearing.

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Continuance requests must be e-filed with proposed order and detailed explanation at least 7 days before scheduled date.

Counsel requesting a continuance must e-file any application or stipulation with a proposed order, which shall include a detailed explanation of the grounds for the requested continuance or other extension of time. The Court will not consider any request that does not comply with the Local Rules and this Order. Applications or stipulations extending dates become effective only if, and when, approved by this Court and an associated order is entered. Counsel shall submit requests for a continuance at least seven (7) calendar days prior to the scheduled date.

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Page 4 | C. CONTINUANCES

48-hour advance notice required for voluminous exhibit deliveries; security pass required.

Arrangements for bringing voluminous trial materials or exhibits into the Courtroom through the Building Vehicle Loading Dock, if required, may be made through the Space & Facilities Help Desk at 213-894-1400. Before contacting Space & Facilities for a required security pass, prior approval of delivery time must be coordinated with the Courtroom Deputy Clerk. Once approval from the Clerk is received, logistical delivery information must be provided to Space & Facilities no later than 48 hours prior to the date of arrival to create and issue the required security pass. Counsel and messengers attempting to access the building parking and loading dock without a required pass will be denied entry.

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Page 13 | c. Voluminous/Security Prone Trial Exhibits/Materials

Continuance requests must be made at least 7 days before the hearing.

Any request for a continuance shall be made no later than seven (7) days prior to the date of the hearing.

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Stipulations extending discovery beyond cut-off date are not approved except in extraordinary circumstances.

The Court will not approve stipulations between counsel that permit responses to be served after the cut-off date, except in extraordinary circumstances.

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Continuance requests should be submitted at least 7 calendar days before the scheduled date.

Counsel should avoid submitting requests for a continuance less than at least seven (7) calendar days prior to the scheduled date that is the subject of the request.

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Email subject must include case number, represented party name, and "UNDER SEAL REQUEST"; add "Part 1", "Part 2" for multiple emails.

The subject line of the email should include: (a) the case number; (b) the name of the represented party; and (c) the words "UNDER SEAL REQUEST." If the size of the email requires a second email that is a continuation of the under seal document(s), the subject line shall also include "Part 1" or "Part 2," etc.

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Page 5 | 1. For Requests to Seal Documents Only, Not the Application and Order

Email chambers with PDF application, Word proposed order, and PDF sealed documents with "UNDER SEAL" marking.

After electronically filing the application and related documents, send an e-mail to: jak_chambers@cacd.uscourts.gov with an attachment containing: (i) an Adobe PDF version of the application to seal with the CM/ECF-generated header; (ii) a Word or WordPerfect version of the proposed order (including the proposed action to be taken if the application is denied (see 1 above); and (iii) an Adobe PDF of the document(s) to be filed under seal with a caption page clearly marked "UNDER SEAL."

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Page 5 | 1. For Requests to Seal Documents Only, Not the Application and Order

Email chambers with PDF application, Word proposed order, and PDF sealed documents with "UNDER SEAL" marking for full seal requests.

Send an email to the chambers' email at jak_chambers@cacd.uscourts.gov with an attachment containing: (i) an Adobe PDF version of the application to seal with the CM/ECF generated header; (ii) a Word or WordPerfect version of the proposed order (including the proposed action to be taken if the application is denied); and (iii) an Adobe PDF of the document(s) to be filed under seal with a caption page, clearly marked "UNDER SEAL."

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Page 6 | 2. For Requests to Seal the Application, Order and Document(s)

Counsel must meet and confer 21 days before Final Pretrial Conference to discuss mini-opening statements

Counsel shall meet and confer twenty-one (21) calendar days prior to the Final Pretrial Conference to determine if, in lieu of a Joint Statement of the Case, they will stipulate to having each side make a brief (less than five minute) mini-opening statement to the panel of prospective jurors prior to the commencement of voir dire.

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Page 9 | G. TRIAL REQUIREMENTS

Objections to jury instructions must be exchanged 21 days before Final Pretrial Conference

Counsel shall exchange any objections to the instructions twenty-one (21) calendar days prior to the Final Pretrial Conference.

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Page 10 | G. TRIAL REQUIREMENTS

Counsel must meet and confer to agree on joint jury instructions by 14 days before Final Pretrial Conference

Counsel shall meet and confer with the goal of reaching an agreement on one set of joint jury instructions, which shall be filed no later than fourteen (14) calendar days before the Final Pretrial Conference.

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Page 10 | G. TRIAL REQUIREMENTS

If defendant calls no witnesses, email must state this

If the defendant does not intend to call any witnesses, the email shall so state.

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Page 10 | G. TRIAL REQUIREMENTS

Proposed jury instructions must be exchanged 28 days before Final Pretrial Conference

Counsel shall exchange proposed jury instructions (general and special) twenty-eight (28) calendar days prior to the Final Pretrial Conference.

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Page 10 | G. TRIAL REQUIREMENTS

Witness lists must be emailed to chambers by noon Friday before trial

Not later than 12:00 pm on the Friday before the commencement of trial, the Government and defense counsel shall each email their respective witness lists in Word to the Court’s Chambers’ email at: jak_chambers@cacd.uscourts.gov.

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Page 10 | G. TRIAL REQUIREMENTS

Email Word versions of trial documents to chambers before first day of trial.

Prior to the first day of trial, counsel shall email Word versions of the following documents to the Court’s Chambers’ email (jak_chambers@cacd.uscourts.gov): (i) the witness list in the order in which the witnesses will be called to testify; (ii) the witness list in alphabetical order; (iii) a final set of jury instructions; (iv) a final version of the verdict form; (v) the exhibit list; (vi) proposed voir dire questions; and (vii) a statement of the case, if applicable.

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Page 14 | Emailed Copies

Entry to building parking and loading dock requires a security pass.

Counsel and messengers attempting to access the building parking and loading dock without a required pass will be denied entry.

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Page 62 | Exhibits

Electronic versions of proposed findings must be emailed to chambers.

In addition, counsel must submit electronic versions (in Word or Word Perfect) to the Court at the following email address: jak_chambers@cacd.uscourts.gov.

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Page 62 | Court Trials

Coordinate delivery time with Courtroom Deputy Clerk before contacting Space & Facilities.

Before contacting Space & Facilities for a required security pass, prior approval of delivery time must be coordinated with the Courtroom Deputy Clerk.

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Page 62 | Exhibits

Contact Space & Facilities Help Desk for voluminous exhibit delivery arrangements.

Arrangements for bringing voluminous trial materials or exhibits into the Courtroom through the Building Vehicle Loading Dock, if required, may be made through the Space & Facilities Help Desk at 213-894.1400.

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Page 62 | Exhibits

Must notify Courtroom Deputy Clerk at day’s adjournment of unexpected legal issues requiring research/briefing.

If during trial, counsel has reason to anticipate that a difficult and unexpected question of law or evidence will raise legal argument, requiring research and/or briefing, counsel must give the Court advance notice. Counsel are directed to notify the Courtroom Deputy Clerk at the day’s adjournment if an unexpected legal issue arises that could not have been foreseen and addressed by a motion in limine (see Fed. R. Evid. 103). To the maximum extent possible, such matters shall be taken outside normal trial hours (e.g., recess, before or after the trial day).

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Page 68 | Advance Notice of Evidentiary or Difficult Questions

Counsel must call the Courtroom Deputy Clerk within 30 minutes of e-filing TRO/injunction documents.

Counsel shall call the Courtroom Deputy Clerk no later than 30 minutes after e-filing the documents.

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Counsel must not approach clerk or witness stand without permission; must return to lectern after; cannot question witnesses at stand without approval.

Counsel must not approach the Courtroom Deputy Clerk or the witness stand without permission. When permission is given, counsel shall return to the lectern when the task has been completed. Counsel must not engage in questioning a witness at the witness stand absent specific approval by the Court.

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Telephonic appearance requests for motion hearings require written request, e-filed 7 calendar days in advance with declaration.

Any request for a telephonic appearance at a motion hearing must be made in writing and e-filed at least seven (7) calendar days before the scheduled hearing and shall include a declaration from counsel setting forth the basis for the request with a proposed order.

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Pro se documents must be emailed as PDF to jak_chambers@cacd.uscourts.gov with case number, case name, and 'Pro Se Filing' in subject line.

(b) The document shall be emailed as a PDF document to the Chambers' email: jak_chambers@cacd.uscourts.gov no later than the date it is due. The Court will deem the date the document is emailed as the filed or lodged date. The proceeding line of the email shall contain: (i) the case number; (ii) case name; and (iii) 'Pro Se Filing' to ensure it will be filed/lodged properly.

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All remarks must be addressed to the Court; counsel cannot address clerk, reporter, audience, or opposing counsel without permission; re-reading requests go to Court.

Counsel must address all remarks to the Court. Counsel are not to address the Courtroom Deputy Clerk, the Reporter, persons in the audience, or opposing counsel. If counsel wishes to speak with opposing counsel, counsel must ask permission to talk off the record. Any request for the re-reading of questions or answers shall be addressed to the Court, not to the court reporter.

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Chambers email is only for document filing, not communication. All communications must be through motions/applications.

(c) The Chambers' email will be used solely to accept documents for filing. The Chambers' email is not to be used in any way to communicate with the Judge or Clerk. All parties, including Pro se/Self-represented parties, shall refrain from writing letters to the Court, sending e-mail messages, making telephone calls to chambers, or otherwise communicating with the Court unless opposing counsel is present. All matters must be called to the Court's attention by appropriate application or motion pursuant to Local Rule 83-2.5.

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Sealed document applications require email to chambers with specific attachments and subject line format including case number, party name, and "UNDER SEAL REQUEST".

After electronically filing the application and related documents, send an e-mail to: jak_chambers@cacd.uscourts.gov with an attachment containing: (i) an Adobe PDF version of the application to seal with the CM/ECF-generated header; (ii) a Word or WordPerfect version of the proposed order (including the proposed action to be taken if the application is denied (see 1 above); and (iii) an Adobe PDF of the document(s) to be filed under seal with a caption page clearly marked "UNDER SEAL." The subject line of the email should include: (a) the case number; (b) the name of the represented party; and (c) the words "UNDER SEAL REQUEST." If the size of the email requires a second email that is a continuation of the under seal document(s), the subject line shall also include "Part 1" or "Part 2," etc.

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Page 5 | UNDER SEAL DOCUMENTS

Manual filing notice for sealed applications requires email to chambers with PDF application, Word/WordPerfect proposed order, and PDF documents marked "UNDER SEAL".

Send an email to the chambers' email at jak_chambers@cacd.uscourts.gov with an attachment containing: (i) an Adobe PDF version of the application to seal with the CM/ECF generated header; (ii) a Word or WordPerfect version of the proposed order (including the proposed action to be taken if the application is denied); and (iii) an Adobe PDF of the document(s) to be filed under seal with a caption page, clearly marked "UNDER SEAL." The subject line of the email should include: (a) the case number; (b) the name of the represented party; and (c) the words "UNDER SEAL REQUEST." If the size of the email requires a second email that is a continuation of the under seal document(s), the subject line shall also include "Part 1" or "Part 2," etc.

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Page 6 | UNDER SEAL DOCUMENTS

Counsel must email Word versions of witness lists, jury instructions, verdict form, exhibit list, voir dire questions, and case statement to chambers before trial.

Prior to the first day of trial, counsel shall email Word versions of the following documents to the Court's Chambers' email (jak_chambers@cacd.uscourts.gov): (i) the witness list in the order in which the witnesses will be called to testify; (ii) the witness list in alphabetical order; (iii) a final set of jury instructions; (iv) a final version of the verdict form; (v) the exhibit list; (vi) proposed voir dire questions; and (vii) a statement of the case, if applicable.

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Page 14 | H. ATTORNEY AND PARTY CONDUCT AT TRIAL

Final verdict form must be emailed in Word format to chambers on the first day of trial.

A final version of the verdict form shall be provided to the Court on the first day of trial and sent via email in Word to the Court's Chambers' email at: jak_chambers@cacd.uscourts.gov.

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Exhibit lists must be emailed to chambers by 12:00 pm Friday before trial in Word format.

Not later than 12:00 pm on the Friday before the commencement of trial, the Government and defense counsel shall each email their respective exhibit list in Word to the Court's Chambers' email at: jak_chambers@cacd.uscourts.gov.

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Final jury instructions must be emailed in Word format to chambers on the first day of trial.

A final "clean" version of the jury instructions, which shall include the preinstructions and the text of each instruction (eliminating titles, supporting authority, indication of party proposing, etc.) shall be provided to the Court on the first day of trial and sent via email in Word to the Court's Chambers' email at: jak_chambers@cacd.uscourts.gov.

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Email subject must include case number, party name, and "UNDER SEAL REQUEST"; use "Part 1", "Part 2" for multiple emails.

The subject line of the email should include: (a) the case number; (b) the name of the represented party; and (c) the words "UNDER SEAL REQUEST." If the size of the email requires a second email that is a continuation of the under seal document(s), the subject line shall also include "Part 1" or "Part 2," etc.

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Page 5 | 1. For Requests to Seal Documents Only

Email application to seal with attachments to chambers email after electronic filing.

After electronically filing the application and related documents, send an e-mail to: jak_chambers@cacd.uscourts.gov with an attachment containing: (i) an Adobe PDF version of the application to seal with the CM/ECF-generated header; (ii) a Word or WordPerfect version of the proposed order (including the proposed action to be taken if the application is denied (see 1 above); and (iii) an Adobe PDF of the document(s) to be filed under seal with a caption page clearly marked "UNDER SEAL."

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Page 5 | 1. For Requests to Seal Documents Only

Email application to seal with attachments to chambers email for manual filing requests.

Send an email to the chambers' email at jak_chambers@cacd.uscourts.gov with an attachment containing: (i) an Adobe PDF version of the application to seal with the CM/ECF generated header; (ii) a Word or WordPerfect version of the proposed order (including the proposed action to be taken if the application is denied); and (iii) an Adobe PDF of the document(s) to be filed under seal with a caption page, clearly marked "UNDER SEAL."

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Page 6 | 2. For Requests to Seal the Application, Order and Document(s)

Email Word versions of trial documents to chambers before first day of trial.

Prior to the first day of trial, counsel shall email Word versions of the following documents to the Court’s Chambers’ email (jak_chambers@cacd.uscourts.gov): (i) the witness list in the order in which the witnesses will be called to testify; (ii) the witness list in alphabetical order; (iii) a final set of jury instructions; (iv) a final version of the verdict form; (v) the exhibit list; (vi) proposed voir dire questions; and (vii) a statement of the case, if applicable.

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Page 14 | H. ATTORNEY AND PARTY CONDUCT AT TRIAL

Counsel must notify clerk in advance about witness accommodations for disabilities.

It is counsel's duty to notify the Courtroom Deputy Clerk in advance if any witness should be accommodated in an appropriate manner due to any disability or other physical need.

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Counsel must advise Court on first day of trial of any commitments causing absence or late arrival.

On the first day of trial counsel shall advise the Court of any commitments that may result in counsel's absence or late arrival on any day of the trial.

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Telephonic appearance not allowed for Scheduling Conference on same date as motion, except in exceptional circumstances.

The Court does not entertain a telephonic appearance if the Scheduling Conference is set at the same date and time as a motion unless it is an exceptional and unanticipated circumstance.

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If not opposing an ex parte application, counsel must notify the Courtroom Deputy Clerk by phone or email promptly.

If counsel do not intend to oppose the ex parte application, counsel must inform the Courtroom Deputy Clerk by telephone or email as soon as possible.

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Review Closed Motion Dates before selecting hearing date; dates may be unavailable.

It is not necessary to clear a hearing date with the Courtroom Deputy Clerk prior to the filing of a motion, but counsel shall review the Court’s Closed Motion Dates prior to selecting a date. Motion dates are closed when the Court’s calendar is full and, therefore, counsel shall not assume that a motion date(s) is available.

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Telephonic appearance requests for Scheduling Conference must be made at least 2 court days in advance.

Use of Conference Telephone: In general, the Court prefers in-person appearances. However, if one or more of the lead counsel has his or her office outside of Los Angeles County, or under other appropriate circumstances, the Court may, upon the request of one or more counsel, conduct the status conference by conference telephone call. Any request for a telephonic appearance must be made at least two (2) court days before the scheduled hearing by contacting the Courtroom Deputy Clerk for further instructions.

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Court does not use Court Call; cell phones and speaker phones prohibited for telephonic appearances.

The Court does not use Court Call. If the request is granted, the order will include the information for the call. Please note that cell phones or the use of speaker phones are not permitted for any telephonic appearance.

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Magistrate Judge orders reversed only if clearly erroneous or contrary to law.

In accordance with 28 U.S.C. § 636(b)(1)(A), the Court will not reverse any order of the Magistrate Judge unless it has been shown that the Magistrate Judge's order is clearly erroneous or contrary to law.

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Motions heard on Mondays at 8:30 AM, or following Monday if holiday.

Motions shall be filed in accordance with Local Rule 6-1 and Local Rule 7. In general, this Court hears motions on Mondays, beginning at 8:30 a.m. If Monday is a national holiday, motions will be heard on the following Monday.

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