Court Rules
Judge

Judge Michelle Williams Court

Individual Rules, Standing Orders & Policies

Central District of California

Limits & Logistics

Document Limits

Memorandum Of Points And Authorities
25 pgs
Brief
25 pgs
Reply Brief
12 pgs
Motion In Limine
10 pgs
Joint Statement Of The Case
1 pgs
Document
10 pgs

Courtesy Copies

Courtesy copies

  • Not required

Exhibits, Deposition Transcripts Excerpts

  • 1 copy • Chambers Drop Off • By 12:00 Pm On Friday Before Start Of Trial
  • 1 copy • Hand Delivery • Promptly On First Day Of Trial

Joint Rule 26f Report

  • Discouraged

Motion, Exhibits

  • Not required

Adjournments

  • Continuance of Scheduling Conference requires good cause.
  • Discovery adequacy motions must be filed early enough to obtain responses before cut-off.
  • Stipulations continuing dates set by the Court will not be approved.
  • +9 more

Request must include

Reason For RequestNumber Of Previous RequestsPrevious Requests Granted Or DeniedDeclaration Supporting Request
1Weeknotice
  • Requests for continuance of trial must be submitted at least one week before the Final Pretrial Conference.
24Hoursnotice
  • Oppositions to ex parte applications must be filed within 24 hours.
28Daysnotice
  • Motions in limine must be filed at least 28 days before the Final Pretrial Conference.
14Daysnotice
  • Oppositions to motions in limine must be filed at least 14 days before the Final Pretrial Conference.

Communication

Email

Chambers

mwc_chambers@cacd.uscourts.gov
Technical IssuesScheduling
Hours: as soon as possible and no later than three (3) business days before the scheduled appearance
Email

Chambers

chambers@cacd.uscourts.gov
Scheduling
Email

Chambers

Scheduling
No status inquiries
Phone

Clerk

SchedulingEmergencies
Phone

Chambers

Emergencies
Hours: 8:30 AM, during breaks, or at end of day
Email

Clerk

Technical Issues
Hours: 24/7
Letter via ECF

Clerk

Technical Issues
Other

Clerk

Scheduling
Telephone
Notice
Filters:AllMandatoryImportantFormattingExhibitsMemorandaJuryTRO/InjunctionBinders/TabsTypographyEvidence/Witnesses

Page & Word Limits12 rules

Page Limits

The quote is in the court's document. The summary is not checked yet.Mandatory?

Memoranda of points and authorities in support of or in opposition to motions shall not exceed 25 pages. Replies shall not exceed 12 pages. Only in rare instances and for good cause shown will the Court grant an application to extend these page limitations.

Summary: Moving and opposition memoranda are limited to 25 pages and reply memoranda to 12 pages, with extensions granted only in rare instances for good cause.

Memorandum In Support Or Opposition

25 pages

Reply Memorandum

12 pages

Page Limits

The quote is in the court's document. The summary is not checked yet.Mandatory?

Motions in limine and oppositions must not exceed ten (10) pages in length.

Summary: Motions in limine and their oppositions are each limited to 10 pages.

Motion In Limine

10 pages

Opposition

10 pages

Apps Cacd Uscourts Gov 128695ac 0286 448b 6fe6 08df031bfdc2 · p. 6
|SecB. Requirements for Pretrial Documents - 1. Motions in Limine
Page Limits

The quote is in the court's document. The summary is not checked yet.Mandatory?

The joint statement should be brief and neutral and must not be more than one page in length.

Summary: The Joint Statement of the Case must not exceed one page and should be brief and neutral.

Joint Statement Of The Case

1 pages

Apps Cacd Uscourts Gov 128695ac 0286 448b 6fe6 08df031bfdc2 · p. 10
|Sec6. Joint Statement of the Case (Jury Trials Only)
Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

The identification must be filed and served within 60 days from the date of this order.

Summary: Trade secret identification must be filed and served within 60 days.

Structured details unavailable. See the source text.

Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

Memoranda of points and authorities in support of or in opposition to motions shall not exceed 25 pages.

Summary: Motion memoranda limited to 25 pages.

Brief

25 pages

Applies to: Attorney

Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

Replies shall not exceed 12 pages.

Summary: Reply memoranda limited to 12 pages.

Reply Brief

12 pages

Applies to: Attorney

Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

Motions in limine and oppositions must not exceed ten (10) pages in length.

Summary: Motions in limine and oppositions are limited to 10 pages.

Motion In Limine

10 pages

Opposition

10 pages

Apps Cacd Uscourts Gov 1531e6c0 1457 4d54 9932 08ddf094e071 · p. 6
|SecB. Requirements for Pretrial Documents - 1. Motions in Limine
Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

The parties shall file and email to Chambers a Joint Statement of the Case fourteen (14) days before the FPTC for the Court to read to the prospective jurors before commencement of voir dire. The joint statement should be brief and neutral and must not be more than one page in length.

Summary: Parties must file and email a Joint Statement of the Case (max 1 page) 14 days before FPTC.

Joint Statement Of The Case

1 pages

Apps Cacd Uscourts Gov 1531e6c0 1457 4d54 9932 08ddf094e071 · p. 10
|SecJoint Statement of the Case (Jury Trials Only)
Page Limits

Machine summary. Not checked yet.Mandatory?

Motions in limine and oppositions must not exceed ten (10) pages in length.

Summary: Motions in limine and oppositions are limited to 10 pages.

Motion In Limine

10 pages

Applies to: Attorney

Page Limits

Machine summary. Not checked yet.Mandatory?

Memoranda of points and authorities in support of or in opposition to motions (besides motions in limine) shall not exceed twenty-five (25) pages. Replies shall not exceed twelve (12) pages.

Summary: Motion memoranda limited to 25 pages; replies limited to 12 pages.

Brief

25 pages

Applies to: Attorney

Reply Brief

12 pages

Applies to: Attorney

Page LimitsCivil cases

Machine summary. Not checked yet.Important?

Only in rare instances and for good cause shown will the Court grant an application to extend these page limitations.

Summary: Page limits may be extended only for good cause shown.

Page LimitsCivil cases

Machine summary. Not checked yet.Note?

Should the parties wish, they may agree to a later deadline, and should state as such in the 26(f) report.

Summary: Parties may agree to a later deadline for trade secret identification.

Document Format Requirements47 rules

Formatting

The quote is in the court's document. The summary is not checked yet.Mandatory?

Pursuant to the Local Rules, either a proportionally spaced or monospaced font may be used. A proportionally spaced face must be 14-point or larger, or as the Court may otherwise order. A monospaced face may not contain more than 10½ characters per inch. These typeface requirements apply to footnoted material.

Summary: Motion papers may use a proportionally spaced font of at least 14 points or a monospaced font of no more than 10.5 characters per inch, and these requirements apply to footnotes.

Typography
Size14 pt
Formatting

The quote is in the court's document. The summary is not checked yet.Mandatory?

Counsel shall adhere to Local Rule 5-4.3 with respect to the conversion of all documents to PDF format so that when a document is electronically filed, it is in proper size and is text-searchable. Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document. See C.D. Cal. Local Rule 5-4.3.1. Failure to comply with formatting requirements may result in the Court striking the motion.

Summary: All electronically filed documents must be converted to PDF per Local Rule 5-4.3, be text-searchable, and allow text to be selected, copied, and pasted, or risk the motion being struck.

Required Format

PDF

Formatting

The quote is in the court's document. The summary is not checked yet.Mandatory?

The opposing party's statement of genuine issues 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. The opposing party may dispute all or only a portion of the statement, but if disputing only a portion, it must clearly indicate which part is being

Summary: Opposing party's statement of genuine issues must be two-column, track the movant's statement exactly, and clearly indicate which portions are disputed.

Formatting

The quote is in the court's document. The summary is not checked yet.Mandatory?

The separate statement of undisputed facts 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. The factual statements should be set forth in sequentially numbered paragraphs. Each paragraph should contain a narrowly focused statement of fact. Each numbered paragraph should address a single subject as concisely as possible.

Summary: Separate statement of undisputed facts must use a two-column format with sequentially numbered, narrowly focused paragraphs.

Formatting

The quote is in the court's document. The summary is not checked yet.Mandatory?

Proposed Orders must be on pleading paper and must not include attorney information on the caption page, should not contain a footer with the document name or other information, and should not contain a watermark or designation of the firm name in the margin.

Summary: Proposed orders must be on pleading paper with no attorney information on the caption page, no footer with document name or other information, and no watermark or firm-name designation in the margin.

Formatting

The quote is in the court's document. The summary is not checked yet.Mandatory?

A template for the Proposed FPTCO is available on Judge Court's webpage. The parties must use this template.

Summary: Parties must use the court-provided template, available on Judge Court's webpage, for the Proposed FPTCO.

Formatting

The quote is in the court's document. The summary is not checked yet.Mandatory?

Format: Each requested instruction shall: (1) cite the authority or source of the instruction; (2) be set forth in full; (3) be on a separate page; (4) be numbered; (5) cover only one subject or principle of law; and (6) not repeat principles of law contained in any other requested instruction.

Summary: Each proposed jury instruction must cite its authority, be set forth in full, be on a separate page, be numbered, cover only one subject, and not repeat principles from other instructions.

Formatting

The quote is in the court's document. The summary is not checked yet.Mandatory?

In addition to filing, counsel must email Microsoft Word versions of their Proposed Findings of Fact and Conclusions of Law to the chambers email address.

Summary: Counsel must email Microsoft Word versions of their Proposed Findings of Fact and Conclusions of Law to the chambers email address in addition to filing them.

Required Format

DOCX

Apps Cacd Uscourts Gov 128695ac 0286 448b 6fe6 08df031bfdc2 · p. 11
|SecProposed Findings of Fact and Conclusions of Law (Bench Trials Only)
Formatting

The quote is in the court's document. The summary is not checked yet.Mandatory?

The copies of exhibits must bear copies of the official exhibit tags that were placed on the original exhibits and be indexed with tabs or dividers on the right side. For electronic exhibits, the copies should not include any physical flash drives or CDs.

Summary: Trial exhibit binder copies must bear the official exhibit tags and be indexed with tabs or dividers on the right side, and electronic exhibit copies must not include physical flash drives or CDs.

Layout & Binding
Binding Style
Tabbed Three Ring
Formatting

The quote is in the court's document. The summary is not checked yet.Important?

All emailed submissions to Chambers referred to in this Order must be in Word format and emailed to MWC_Chambers@cacd.uscourts.gov.

Summary: All emailed submissions to Chambers must be in Word format and sent to MWC_Chambers@cacd.uscourts.gov.

Required Format

DOCX

Formatting

The quote is in the court's document. The summary is not checked yet.Important?

All trial filings must be both filed with the Court and emailed in Word version to the chambers email box at MWC_Chambers@cacd.uscourts.gov.

Summary: The emailed chambers copies of trial filings must be in Word format.

Required Format

DOCX

Formatting

The quote is in the court's document. The summary is not checked yet.Important?

If both parties intend on proffering the same witness to support their case, the Joint Witness should indicate that fact (e.g., by highlighting the witness's name in yellow or using red font for the witness' name).

Summary: Witnesses proffered by both parties must be flagged on the Joint Witness List, e.g., by highlighting the name in yellow or using red font.

Apps Cacd Uscourts Gov 128695ac 0286 448b 6fe6 08df031bfdc2 · p. 6
|SecB. Requirements for Pretrial Documents - 2. Joint Witness List
Formatting

The quote is in the court's document. The summary is not checked yet.Important?

Such objections shall be submitted in the following three-column format: (1) the left column should contain a verbatim quote of each statement objected to (including page and line number); (2) the middle column should set forth a concise legal objection (e.g., hearsay, lacks foundation) with a citation to the corresponding Federal Rule of Evidence or, where applicable, a case citation; and (3) the right column should provide space for the Court's ruling on the objection.

Summary: Evidentiary objections to declarations must use a three-column format: verbatim quote with page/line in the left column, concise legal objection with rule or case citation in the middle column, and space for the Court's ruling in the right column.

Apps Cacd Uscourts Gov 128695ac 0286 448b 6fe6 08df031bfdc2 · p. 11
|Sec9. Declarations of Direct Testimony (Bench Trials Only)
Formatting

The quote is in the court's document. The summary is not checked yet.Important?

For electronic exhibits, the parties should provide a physical caption page with the exhibit tag and attach the physical flash drive or CD containing the electronic exhibits.

Summary: For electronic exhibits, the parties should provide a physical caption page with the exhibit tag attached to the physical flash drive or CD containing the exhibits.

Formatting

The quote is in the court's document. The summary is not checked yet.Important?

Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc. See C.D. Cal. L.R. 16-6. Every page of a multi-page exhibit must be numbered.

Summary: Exhibits must be numbered sequentially (1, 2, 3, not 1.1, 1.2) and every page of a multi-page exhibit must be numbered.

Formatting

The quote is in the court's document. The summary is not checked yet.Important?

All exhibits placed in the three-ring binder must be indexed by exhibit number with tabs or dividers on the right side. All exhibit tabs are to be stapled to the first page of the exhibit.

Summary: Exhibits in the three-ring binder must be indexed by exhibit number with tabs or dividers on the right side, and each exhibit tab must be stapled to the first page of the exhibit.

Layout & Binding
Binding Style
Tabbed Three Ring
Formatting

The quote is in the court's document. The summary is not checked yet.Important?

The spine of each binder shall indicate the volume number and the range of exhibit numbers included in the volume.

Summary: Each exhibit binder's spine must indicate the volume number and the range of exhibit numbers included in that volume.

Formatting

The quote is in the court's document. The summary is not checked yet.Important?

The original exhibits shall bear the official exhibit tags (green tags for joint exhibits) affixed to the front upper right-hand corner of the exhibit, with the case number, case name, and exhibit number stated on each tag. Tags may be obtained from the Clerk's Office, or the parties may print their own exhibit tags using Forms G-14A and G-14B on the "Court Forms" section of the Central District of California's website.

Summary: Original exhibits must bear official exhibit tags (green for joint exhibits) on the front upper right-hand corner stating the case number, case name, and exhibit number; tags come from the Clerk's Office or may be printed using Forms G-14A and G-14B.

Formatting

The quote is in the court's document. The summary is not checked yet.Important?

Plaintiff's exhibits must be placed in a separate folder from Defendant's exhibits, and the document file names must include the exhibit number and a brief description of the document (e.g., “Ex. 1 – Smith Declaration.pdf” or “Ex. 105 –Letter Dated 1-5-20.pdf”).

Summary: In the emailed exhibit zip file, Plaintiff's and Defendant's exhibits must be in separate folders and file names must include the exhibit number and a brief description.

Formatting

The quote is in the court's document. The summary is not checked yet.Note?

Where appropriate, the disputed instructions shall be organized by subject, so that instructions that address the same or similar issues are presented sequentially.

Summary: Disputed jury instructions should be organized by subject so related instructions are presented sequentially.

FormattingCivil cases

Machine summary. Not checked yet.Mandatory?

Counsel shall adhere to Local Rule 5-4.3 with respect to the conversion of all documents to PDF format so that when a document is electronically filed, it is in proper size and is text-searchable. Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document.

Summary: All documents must be converted to PDF format, text-searchable, and allow text selection/copy/paste.

Required Format

PDF

FormattingCivil cases

Machine summary. Not checked yet.Mandatory?

Pursuant to the Local Rules, either a proportionally spaced or monospaced font may be used. A proportionally spaced face must be 14-point or larger, or as the Court may otherwise order. A monospaced face may not contain more than 10½ characters per inch.

Summary: Font requirements: proportionally spaced 14-point or larger, or monospaced not exceeding 10½ characters per inch.

Typography
Font FamilyOther
Size14 pt
Formatting

Machine summary. Not checked yet.Mandatory?

Trial exhibits that consist of documents and photographs must be submitted to the Court in three-ring binders. The parties shall submit to the Court three (3) sets of binders: one (1) original set of trial exhibits, and two (2) copies of trial exhibits. The original set of exhibits shall be for use by the jury during its deliberations, and the copies are for the Court.

Summary: Trial exhibits must be submitted in three-ring binders (1 original + 2 copies).

Layout & Binding
Binding Style
Three Ring Binder
Formatting

Machine summary. Not checked yet.Mandatory?

The copies of exhibits must bear copies of the official exhibit tags that were placed on the original exhibits and be indexed with tabs or dividers on the right side.

Summary: Copy exhibits must have copies of official tags and be indexed with tabs.

Layout & Binding
Binding Style
Three Ring Binder
Formatting

Machine summary. Not checked yet.Mandatory?

All memoranda of points and authorities and replies in support of or in opposition to motions must use Times New Roman or Courier font. Text must be no less than twelve (12) point font; footnotes shall be no less than eleven (11) point font.

Summary: Motion memoranda must use Times New Roman or Courier font, 12 pt text, 11 pt footnotes.

Typography
Font FamilyTimes New Roman
Size12 pt
Formatting

Machine summary. Not checked yet.Mandatory?

The original exhibits shall bear the official exhibit tags (yellow tags for Plaintiff’s exhibits and blue tags for Defendant’s exhibits) affixed to the front upper right-hand corner of the exhibit, with the case number, case name, and exhibit number stated on each tag. Tags may be obtained from the Clerk’s Office, or the parties may print their own exhibit tags using Forms G-14A and G-14B on the “Court Forms” section of the Central District of California’s website.

Summary: Original exhibits must have official yellow/blue tags with case info.

Layout & Binding
Binding Style
Three Ring Binder
Formatting

Machine summary. Not checked yet.Mandatory?

The Government’s exhibits must be placed in a separate folder from Defendant’s exhibits, and the document file names must include the exhibit number and a brief description of the document (e.g., “Ex. 1 – Smith Declaration.pdf” or “Ex. 105 –Letter Dated 1-5-20.pdf”).

Summary: Government and defense exhibits must be in separate folders with descriptive filenames.

Layout & Binding
Binding Style
Three Ring Binder
Formatting

Machine summary. Not checked yet.Mandatory?

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc.

Summary: Exhibits must be indexed with tabs and numbered sequentially (1, 2, 3, etc.).

Layout & Binding
Binding Style
Three Ring Binder
FormattingCivil cases

Machine summary. Not checked yet.Important?

All emailed submissions to Chambers referred to in this Order must be in Word format and emailed to MWC Chambers@cacd.uscourts.gov.

Summary: Emailed submissions to Chambers must be in Word format.

Required Format

DOCX

Document Filing Requirements148 rules

Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

Federal Rule of Civil Procedure 11(b) requires that all parties who present papers to the Court certify "that to the best of the person's knowledge, information, and belief, formed after an inquiry reasonable under the circumstances," the factual and legal contentions are "warranted," "nonfrivolous," and "have evidentiary support." Fed. R. Civ. P. 11(b)(2)-(3).

Summary: All parties presenting papers to the Court must include the Fed. R. Civ. P. 11(b) certification that factual and legal contentions are warranted, nonfrivolous, and have evidentiary support.

Document Type

Papers Presented To Court

Specific requirements detailed in rule text.
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

a. Declaration Certifying Use or Non-Use of Artificial Intelligence............ 3

Summary: The standing order contemplates a required declaration certifying use or non-use of artificial intelligence, detailed in Section 1.a on page 3.

Document Type

Declaration Certifying Ai Use Or Non Use

Content & Formatting
Ai Disclosure
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

Every motion, pleading, or other paper must attach to the filing a separate declaration, signed under penalty of perjury, disclosing the use or non-use of generative Artificial Intelligence (“AI”) (e.g., Claude, ChatGPT, Harvey, CoCounsel, or Google Board). The preparer of the filing must certify that either (a) no portion of the filing was drafted by AI, or that (b) AI was used in drafting a portion of the filing, and that the filer has reviewed the source material and verified that the artificially generated content is accurate and complies with the filer’s Rule 11 obligations. The declaration must identify which, if any, portion of the filing incorporates Generative AI outputs. The Court warns that a party who presents to the Court a pleading, written motion, or other paper incorporating inaccurate or undeclared Generative AI outputs may be subject to sanctions, including referral to the State Bar, without further warning. See Fed. R. Civ. P. 11(c). Failure to submit a declaration attesting to the use or non-use of AI may result in the Court striking the filing.

Summary: Every motion, pleading, or other paper must attach a separate declaration under penalty of perjury certifying the use or non-use of generative AI and identifying any AI-drafted portions; failure to submit the declaration may result in the filing being struck, and inaccurate or undeclared AI content may result in sanctions including State Bar referral.

Document Type

Motion Pleading Or Other Paper

Content & Formatting
Ai Disclosure
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

All documents must include the words "DISCOVERY MATTER" in the caption to ensure proper routing.

Summary: All discovery-related documents must include the words "DISCOVERY MATTER" in the caption to ensure proper routing.

Document Type

Discovery Document

Specific requirements detailed in rule text.
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

The motion must specify which portions of the text are clearly erroneous or contrary to law, and the claim must be supported by points and authorities.

Summary: A motion for review must specify which portions of the ruling are clearly erroneous or contrary to law and must be supported by points and authorities.

Document Type

Motion For Review Reconsideration

Content & Formatting
Legal Argument
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

The Court strongly prefers in-person appearances. Requests for a remote appearance will only be considered upon a written application filed at least seven (7) days before the hearing and supported by an appropriate declaration establishing good cause.

Summary: Remote appearance requests require a written application, supported by a declaration establishing good cause, filed at least 7 days before the hearing.

Document Type

Remote Appearance Application

Specific requirements detailed in rule text.
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

Declaration Certifying Artificial Intelligence Use or Non-Use: All motions require attaching a separate declaration, adhering to the requirements in Section 1(a) of this Court's Standing Order, certifying the filer's use or non-use of generative AI in preparing the filing. The Court may strike any filing that does not comply with this requirement.

Summary: All motions must attach a separate declaration certifying the filer's use or non-use of generative AI, or risk being stricken.

Document Type

Motion

Content & Formatting
Ai Disclosure
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

Motions to Amend: In addition to the requirements of Local Rule 15-1, all motions to amend pleadings shall: (1) state the effect of the amendment; (2) be serially numbered to differentiate the amendment from previous amendments; (3) state the page and line number(s) and wording of any proposed change or addition of pleading indicating all additions and deletions of material.

Summary: Motions to amend pleadings must state the amendment's effect, be serially numbered, and identify page/line numbers and wording of all changes.

Document Type

Motion To Amend

Specific requirements detailed in rule text.
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

No party may file more than one motion pursuant to Fed. R. Civ. P. 56, regardless of whether such motion is denominated as a motion for summary judgment or summary adjudication, without leave from the Court.

Summary: Only one Rule 56 motion (summary judgment or adjudication) may be filed without leave of court.

Document Type

Summary Judgment Motion

Specific requirements detailed in rule text.
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

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. These additional facts shall continue in sequentially numbered paragraphs and shall set forth in the right-hand column the evidence that supports that statement. For example, if the movant’s separate statement of undisputed facts continues from Fact Number 1 until Fact Number 100, then the opposing party’s additional material facts should begin at Fact Number 101.

Summary: The opposing party’s additional material facts must follow the movant’s format, continue sequential numbering (e.g., starting at Fact Number 101 if the movant ended at 100), and cite supporting evidence in the right-hand column.

Document Type

Additional Material Facts Separate Statement

Content & Formatting
Statement Of Facts
Filing Requirements

The quote is in the court's document. The summary is 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. No legal argument should be set forth in this document.

Summary: The opposition’s separate statement must briefly state why each fact is disputed, cite the relevant evidence, and describe what refutes the fact, with no legal argument included.

Document Type

Opposition Separate Statement Of Undisputed Facts

Content & Formatting
Statement Of Facts
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

No party shall submit evidence other than the specific items of evidence or testimony necessary to support or controvert a proposed statement of undisputed fact. For example, entire deposition transcripts, entire sets of interrogatory responses, and documents that do not specifically support or controvert material in the separate statement shall not be submitted in support of opposition to a motion for summary judgment. The court will not consider such material.

Summary: Only evidence specifically supporting or controverting facts in the separate statement may be submitted with summary judgment papers; entire transcripts and non-specific documents will not be considered by the court.

Document Type

Summary Judgment Evidence

Specific requirements detailed in rule text.
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

The court will accept counsel’s authentication of deposition transcripts, written discovery responses and the receipt of documents in discovery if the fact that the document was in the opponent’s possession is of independent significance. Documentary evidence as to which there is no stipulation regarding foundation must be accompanied by the testimony, either by declaration or properly authenticated deposition transcript, of a witness who can establish authenticity.

Summary: Counsel’s authentication is accepted for deposition transcripts, written discovery responses, and discovery receipts where the opponent’s possession has independent significance; otherwise documentary evidence without a foundation stipulation must be accompanied by testimony (declaration or authenticated deposition transcript) establishing authenticity.

Document Type

Documentary Evidence

Specific requirements detailed in rule text.
Filing Requirements

The quote is in the court's document. The summary is 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: Every party filing or opposing a motion (or seeking any determination) must serve and electronically lodge a proposed order stating the relief sought and a brief rationale with citations.

Document Type

Motion

Content & Formatting
Proposed Order
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

a party asserting an evidentiary objection in a separate statement may provide “Objection: [Basis for Objection],” e.g., “Objection: Hearsay.” Both the grounds and legal argument underlying the evidentiary objection shall be contained in a separate filing.

Summary: Evidentiary objections should be noted in the separate statement using the format “Objection: [Basis for Objection]” (e.g., “Objection: Hearsay”), while the grounds and legal argument must be filed separately.

Document Type

Separate Statement Of Undisputed Facts

Specific requirements detailed in rule text.
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

In addition to the information required by Local Rule 7-19.1, the notice must advise the other parties of the anticipated deadline to oppose the application.

Summary: The ex parte notice must state the anticipated opposition deadline in addition to the information required by Local Rule 7-19.1.

Document Type

Ex Parte Application Notice

Specific requirements detailed in rule text.
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

Parties seeking emergency or provisional relief shall comply with Fed. R. Civ. P. 65 and Local Rule 65.

Summary: Parties seeking emergency or provisional relief must comply with Fed. R. Civ. P. 65 and Local Rule 65.

Document Type

Application For Emergency Or Provisional Relief

Specific requirements detailed in rule text.
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

Ex parte applications that fail to conform to Local Rule 7-19 will not be considered, except on a specific showing of good cause.

Summary: Ex parte applications must conform to Local Rule 7-19 or they will not be considered, except on a specific showing of good cause.

Document Type

Ex Parte Application

Specific requirements detailed in rule text.
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

Counsel requesting a continuance must lodge a proposed stipulation and order including a detailed declaration of the grounds for the requested continuance or extension of time.

Summary: Continuance requests must be lodged as a proposed stipulation and order with a detailed declaration of the grounds for the continuance or extension.

Document Type

Stipulation And Order

Content & Formatting
Proposed Order
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

Pursuant to Fed. R. Civ. P. 16(b), the Court will issue an Order setting a Scheduling Conference as required by Fed. R. Civ. P. 26 and the Local Rules of this Court. Strict compliance with Fed. R. Civ. P. 16 and 26 is required.

Summary: The Court will set a scheduling conference under FRCP 16(b), and strict compliance with Fed. R. Civ. P. 16 and 26 is required.

Document Type

Scheduling Conference Submissions

Specific requirements detailed in rule text.
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

Requests to appear via Zoom must be e-filed seven (7) days before the hearing and must indicate that counsel has met and conferred per Local Rule 7-3.

Summary: A Zoom appearance request must indicate that counsel has met and conferred per Local Rule 7-3.

Document Type

Request To Appear Via Zoom

Content & Formatting
Certificate Of Conference
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

The Joint Witness List must be in the format specified in Local Rule 16-5 and in this Order, below, and must include for each witness (1) a brief description of the testimony; (2) the reasons the testimony is unique and not redundant; and (3) a time estimate in hours for direct and cross-examination.

Summary: The Joint Witness List must follow Local Rule 16-5 format and include, for each witness, a brief description of testimony, reasons the testimony is unique and not redundant, and a time estimate in hours for direct and cross-examination.

Document Type

Joint Witness List

Specific requirements detailed in rule text.
Apps Cacd Uscourts Gov 128695ac 0286 448b 6fe6 08df031bfdc2 · p. 6
|SecB. Requirements for Pretrial Documents - 2. Joint Witness List
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

The Joint Exhibit List shall be filed and emailed to Chambers twenty-eight (28) days before the FPTC. It must be in the format specified in Local Rule 16-6 and shall include additional columns stating any objections to authenticity and/or admissibility and the reasons for the objections, as well as responses to the objections.

Summary: Joint Exhibit List must be filed and emailed to Chambers 28 days before the FPTC in Local Rule 16-6 format with objection and response columns.

Document Type

Joint Exhibit List

Content & Formatting
Exhibit List
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

The parties shall file and email to Chambers clean and redline sets of: (1) their Joint Agreed Upon Proposed Jury Instructions; and (2) their Disputed Jury Instructions. The redline sets shall include all modifications made by the parties to pattern or model jury instructions, any disputed language, and the factual or legal basis for each party's position as to each disputed instruction.

Summary: Jury instruction submissions must include clean and redline sets showing modifications to pattern instructions, disputed language, and the basis for each party's position.

Document Type

Jury Instructions

Specific requirements detailed in rule text.
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

The parties shall meet and confer regarding jury instructions according to the following schedule: Thirty-five (35) days before the FPTC: The parties shall exchange proposed general and special jury instructions. Twenty-eight (28) days before the FPTC: The parties shall exchange any objections to the instructions. Twenty-one (21) days before the FPTC: The parties shall meet and confer with the goal of reaching agreement on one set of Joint Proposed Jury Instructions.

Summary: Parties must exchange proposed instructions 35 days before the FPTC, exchange objections 28 days before, and meet and confer 21 days before to reach agreement.

Document Type

Jury Instructions

Specific requirements detailed in rule text.
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

If a standard instruction has blanks or offers options (e.g., for gender 10), the parties must fill in the blanks or make the appropriate selections in their proposed instructions.

Summary: Parties must fill in blanks or make the appropriate selections in proposed instructions when using a standard instruction that contains blanks or options.

Document Type

Proposed Jury Instructions

Specific requirements detailed in rule text.
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

Index: All proposed jury instructions must have an index that includes the following for each instruction, as illustrated in the example below: • the number of the instruction; • the title of the instruction; • the source of the instruction and any relevant case citations; and • the page number of the instruction.

Summary: All proposed jury instructions must include an index listing, for each instruction, its number, title, source with case citations, and page number.

Document Type

Proposed Jury Instructions

Content & Formatting
Table Of Contents
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

The parties must submit a completed copy of the attached Schedule of Pretrial and Trial Dates Worksheet ("Worksheet") with their Joint Rule 26(f) Report.

Summary: Joint Rule 26(f) Report must include completed Schedule Worksheet.

Document Type

Joint Rule 26(F) Report

Content & Formatting
Proposed Order
Exhibit List
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

The Joint Rule 26(f) Report must be filed no later than seven (7) days after the meeting of counsel and fourteen (14) days before the Scheduling Conference.

Summary: Joint Rule 26(f) Report due 7 days after meet-and-confer and 14 days before scheduling conference.

Document Type

Joint Rule 26f Report

Content & Formatting
Case Number
Judge Name

Filing & Service rules

Electronic Filing Rules

Attorneys required to manually file under the Local Rules must mail their filings to the Clerk of Court.

Attorneys who are required to manually file documents pursuant to the Local Rules must mail their filings to the Clerk of Court at the above address.

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Page 5 | Filing

Non-paper physical exhibits exempted from e-filing must be sent to the Clerk of Court via U.S. Mail or other commercial delivery.

Non-paper physical exhibits exempted from electronic filing shall be sent via U.S. Mail or other commercial delivery to the Clerk of Court at the above address.

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Page 5 | Filing

Unrepresented litigants who cannot e-file may mail filings to the Clerk of Court or submit documents through EDSS.

Unrepresented litigants who cannot electronically file their documents in the CM/ECF system may mail their filings to the Clerk of Court at 255 E. Temple Street, Suite TS-134, Los Angeles, CA 90012-3332 or submit documents for filing through the Court's Electronic Document Submission System (EDSS).

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Page 5 | Filing

The Court's CM/ECF system is available 24/7 for electronic filing of documents.

The Court's CM/ECF system is available 24/7 for electronic filing of documents.

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Page 5 | Filing

Zoom requests must be e-filed.

Requests to appear via Zoom must be e-filed seven (7) days before the hearing and must indicate that counsel has met and conferred per Local Rule 7-3.

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Page 3 | SCHEDULE OF PRETRIAL AND TRIAL DATES

All pretrial documents must be filed and emailed in Word format to chambers on the due date.

All pretrial documents listed above, including any amended documents, shall be filed and emailed in Word version to MWC_Chambers@cacd.uscourts.gov the day they are due.

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Page 6 | A. Schedule for Filing Pretrial Documents

Filing Timing and Cure Windows

Adherence to the motion timing requirements is mandatory for chambers' preparation of motion matters.

Adherence to the timing requirements is mandatory for chambers' preparation of motion matters.

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Page 6 | Motions - General Requirements

Motions are heard only on Fridays beginning at 1:30 p.m.; unavailable dates are continued to the next available date, and counsel should confirm date availability immediately before filing.

Motions shall be filed in accordance with Local Rules 6 and 7. This Court only hears motions on Fridays, beginning at 1:30 p.m. If the motion date selected is not available, the Court will continue the hearing to the next available date on the Court's calendar. (Counsel are advised to check the availability of a selected date immediately prior to filing the motion.)

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Page 6 | Motions - General Requirements

Opposition or reply papers due on a holiday must be filed the preceding business day (Thursday), not the following business day (Monday).

Opposition or reply papers due on a holiday must be filed the preceding business day (i.e., Thursday)—not the following business day (i.e., Monday)—and must be hand-delivered or emailed to opposing counsel on the preceding business day.

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Page 6 | Motions - General Requirements

A motion for review and reconsideration of a Magistrate Judge ruling must be filed and served within 14 days of service of a written ruling or within 14 days of an oral ruling that will not be followed by a written ruling.

Any party may file and serve a motion for review and reconsideration before this Court. The moving party must file and serve the motion within fourteen (14) days of service of a written ruling or within fourteen (14) days of an oral ruling that the Magistrate Judge states will not be followed by a written ruling.

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Page 6 | Discovery

Summary judgment motions must be filed 49 days before hearing, oppositions 21 days before, and replies 14 days before the hearing date.

A motion under Rule 56 must be filed at least forty-nine (49) days prior to the date on which the motion is noticed for hearing. The opposition is due not later than twenty-one (21) days before the date designated for the hearing of the motion, and the reply not later than fourteen (14) days before the date designated for the hearing of the motion.

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Page 10 | Specific Motion Requirements

The Court will not rule on TRO or injunction applications for at least 24 hours after service on the responding party, unless service is excused, and the responding party may file opposition papers in the interim.

The Court will not rule on any application for such relief for at least twenty-four hours after the party subject to the requested order has been served, unless service is excused. Such party may file opposing or responding papers in the interim.

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Page 13 | TROs and Injunctions

Oppositions to ex parte applications are due within 24 hours of the application's filing, subject to Rule 6(a)(2).

Oppositions to ex parte applications must be filed within 24 hours of the filing of the application, subject to Rule 6(a)(2).

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Page 13 | Ex Parte Applications

Discovery motions must be heard (not merely filed) by the discovery cut-off date, so they must be timely filed, served, and calendared sufficiently in advance of that date.

The parties are advised that the discovery cut-off date is the last day by which all depositions must be completed, responses to previously served written discovery must be provided, and motions concerning discovery disputes must be heard, not filed. In other words, any motion challenging the adequacy of discovery responses must be timely filed, served, and calendared sufficiently in advance of the relevant discovery cut-off date to permit the responses to be obtained before that date, if the motion is granted.

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Page 2 | A. Scheduling Order

Hearings proceed in-person by default, and any request to appear via Zoom must be e-filed at least seven (7) days before the hearing.

By default, all hearings shall proceed in-person, unless a request is made by the parties and granted by the Court. Requests to appear via Zoom must be e-filed seven (7) days before the hearing and must indicate that counsel has met and conferred per Local Rule 7-3.

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Page 3 | Schedule of Pretrial and Trial Dates

Requests for additional trial days must be made by the Trial Filings (First Round) deadline, and the Court makes the final determination on trial days at the FPTC.

Any requests for additional trial days must be made at the time of the deadline for Trial Filings (First Round). The Court will make a final determination on the days needed for trial at the FPTC.

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Page 3 | Schedule of Pretrial and Trial Dates

Motions to compel must be filed and heard before the discovery cutoff.

Any motions to compel must be filed and heard before the discovery cutoff.

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Page 3 | Schedule of Pretrial and Trial Dates

The Proposed Final Pretrial Conference Order must be filed and emailed to Chambers at least fourteen (14) days before the FPTC.

A proposed Final Pretrial Conference Order ("Proposed FPTCO") shall be filed and emailed to Chambers at least fourteen (14) days before the FPTC.

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Page 4 | Final Pretrial Conference

Motions in limine, memoranda of contentions of fact and law, joint witness and exhibit lists, the joint settlement status report, and (bench trials only) proposed findings/conclusions and direct testimony declarations are due at least 28 days before the FPTC.

At least twenty-eight (28) days before the FPTC: o Motions in Limine o Memoranda of Contentions of Fact and Law o Joint Witness list o Joint Exhibit list o Joint Status Report Regarding Settlement o Proposed Findings of Fact and Conclusions of Law (bench trial only) o Declarations containing Direct Testimony (bench trial only)

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Page 5 | A. Schedule for Filing Pretrial Documents

Oppositions to motions in limine, the joint proposed FPTCO, (jury trials only) agreed and disputed proposed jury instructions, proposed verdict forms, proposed statement of the case, and proposed voir dire questions, and (bench trials only) evidentiary objections to direct testimony declarations are due at least 14 days before the FPTC.

At least fourteen (14) days before the FPTC: o Oppositions to Motions in Limine o Joint Proposed FPTCO o Joint Agreed Upon Proposed Jury Instructions (jury trial only) o Disputed Proposed Jury Instructions (jury trial only) o Joint Proposed Verdict Forms (jury trial only) o Joint Proposed Statement of the Case (jury trial only) o Proposed Voir Dire Questions, if any (jury trial only) o Evidentiary Objections to Declarations of Direct Testimony (bench trial only)

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Page 5 | A. Schedule for Filing Pretrial Documents

The Joint Witness List must be filed and emailed to Chambers in Word format 28 days before the FPTC.

The parties shall file a Joint Witness List and email a copy in Word format to Chambers twenty-eight (28) days before the FPTC.

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Page 6 | B. Requirements for Pretrial Documents - 2. Joint Witness List

Amended Joint Witness Lists must be filed and emailed to Chambers by 12:00 p.m. (noon) on the Friday before trial.

Any Amended Joint Witness List must be filed and emailed to Chambers by 12:00 p.m. (noon) on the Friday before trial.

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Page 6 | B. Requirements for Pretrial Documents - 2. Joint Witness List

All motions in limine must be filed and emailed to Chambers at least 28 days before the FPTC.

All motions in limine shall be filed and emailed to Chambers at least twenty-eight (28) days before the FPTC.

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Page 6 | B. Requirements for Pretrial Documents - 1. Motions in Limine

Oppositions to motions in limine must be filed and emailed to Chambers at least 14 days before the FPTC.

Oppositions shall be filed and emailed to Chambers at least fourteen (14) days before the FPTC.

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Page 6 | B. Requirements for Pretrial Documents - 1. Motions in Limine

Joint Proposed Jury Instructions must be filed and emailed to Chambers at least 14 days before the FPTC.

Joint Proposed Jury Instructions shall be filed and emailed to Chambers no later than fourteen (14) days prior to the FPTC.

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Page 7 | 4. Jury Instructions (Jury Trials Only)

Amended Joint Exhibit Lists must be filed and emailed to Chambers by noon on the Friday before trial.

Any Amended Joint Exhibit List shall be filed and emailed to Chambers by 12:00 p.m. (noon) on the Friday before trial.

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Page 7 | 3. Joint Exhibit List

14 days before the FPTC, parties must file and email to Chambers both Joint Agreed Upon Proposed Jury Instructions and Disputed Jury Instructions.

Fourteen (14) days before FPTC: The parties shall file and email to Chambers: (1) their Joint Agreed Upon Proposed Jury Instructions and (2) their Disputed Jury Instructions.

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Page 8 | 4. Jury Instructions (Jury Trials Only)

Declarations of direct testimony, when ordered, are due at least 28 days before the FPTC.

When ordered by the Court in a particular case, each party shall file and email to Chambers declarations containing the direct testimony of each witness whom that party intends to call at trial at least twenty-eight (28) days before the FPTC.

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Page 11 | 9. Declarations of Direct Testimony (Bench Trials Only)

Evidentiary objections to direct-testimony declarations are due at least 14 days before the FPTC.

If such declarations are filed, each party shall file and email to Chambers any evidentiary objections to the declarations submitted by any other party at least fourteen (14) days before the FPTC.

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Page 11 | 9. Declarations of Direct Testimony (Bench Trials Only)

Proposed Findings of Fact and Conclusions of Law are due no later than 28 days before the FPTC.

For any trial requiring findings of fact and conclusions of law, each party shall file and email to Chambers its Proposed Findings of Fact and Conclusions of Law in the format specified in Local Rule 52-3 no later than twenty-eight (28) days before the FPTC.

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Page 11 | Proposed Findings of Fact and Conclusions of Law (Bench Trials Only)

The case-specific glossary must be filed and emailed in Word version to Chambers no later than the Friday before trial.

The case-specific glossary shall be filed and emailed in Word version to Chambers no later than the Friday before trial.

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Page 12 | 10. Case-Specific Glossary

The joint exhibit list is due 28 calendar days before the Final Pretrial Conference.

A joint exhibit list, the format of which shall comply with Local Rule 16-6.1, shall be filed twenty-eight (28) calendar days prior to the Final Pretrial Conference.

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Page 12 | III. Trial Exhibits

The attorney attending any proceeding, including status and settlement conferences, must be lead trial counsel, and requests to substitute another attorney must be filed at least 7 days before the proceeding.

The attorney attending any proceeding before this Court, including all status and settlement conferences, must be the lead trial counsel. All requests to substitute another attorney in place of lead counsel must be filed at least seven (7) days prior to the Court proceeding.

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Page 4 | Presence of Lead Counsel

In removed actions, Defendant must submit a complete copy of the state court docket sheet within 7 days after the case is assigned to this Court.

Upon removing the action to federal court, and within seven (7) days after the case is assigned to this Court, Defendant must submit a complete copy of the Superior Court action’s docket sheet that details every state court filing and action that took place prior to removal.

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Page 4 | Removed Actions

In removed actions containing form pleadings, the party must file an appropriate pleading complying with Fed. R. Civ. P. 7, 7.1, 8, 9, 10 and 11 within 30 days of receipt of the Notice of Removal.

If an action removed to this Court contains a form pleading (i.e., a pleading in which boxes are checked), the party or parties utilizing the form pleading must file an appropriate pleading with this Court within thirty (30) days of receipt of the Notice of Removal. The appropriate pleading referred to must comply with the requirements of Fed. R. Civ. P. 7, 7.1, 8, 9, 10 and 11.

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Page 4 | Removed Actions

Moving parties should avoid filing motions whose opposition deadline falls on the Thursday before a holiday, as such filings are likely to result in granted continuances.

Professional courtesy dictates that moving parties should, whenever possible, avoid filing motions for which opposition papers will be due the Thursday preceding a holiday. Such a filing is likely to cause a requested continuance to be granted.

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Page 6 | Motions - General Requirements

Parties must timely submit a Joint Rule 26(f) Report or the Court will issue a Civil Trial Order without it.

Upon receipt of the parties' Joint Rule 26(f) Report, the Court generally issues the Civil Trial Order containing the deadlines for the case. If the parties fail to timely submit a Rule 26(f) Report, the Court will issue a Civil Trial Order without a Rule 26(f) Report.

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Page 14 | Order Setting Scheduling Conference

Parties may file and email proposed case-specific voir dire questions to Chambers no later than 14 days before the FPTC for the Court's consideration.

The parties may file and email to Chambers any proposed case-specific voir dire questions for the Court’s consideration no later than fourteen (14) days before the FPTC.

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Page 10 | 7. Proposed Voir Dire Questions (Jury Trials Only)

Damages Contentions must be served within 50 days after service of Invalidity Contentions and include categories and good faith explanation.

Not later than 50 days after service of the Invalidity Contentions, each party asserting infringement shall identify each of the category(-ies) of damages it is seeking for the asserted infringement (e.g., lost profits, reasonable royalty, price erosion, convoyed sales, etc.), and for each category of damages sought, provide a good faith explanation of the theory of damages and the factual basis for damages.

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Page 9 | 3-8

Parties must meet and submit a Damages Meeting Certification within 60 days after the response date for disclosures under Rule 3-9.

Not later than 60 days after the response date for any required disclosure under Rule 3-9, the parties shall (a) meet, with or without counsel of record, and shall disclose their good faith estimate of damages, assuming infringement and validity; and (b) submit a Damages Meeting Certification that certifies the meeting has taken place and identifies the individuals who participated in the meeting.

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Page 9 | 3-10

Responsive Damages Contentions must be served within 30 days after service of Damages Contentions and disclose material facts.

Not later than 30 days after service of the Damages Contentions served pursuant to S.P.R 3-8, each party denying infringement shall disclose in good faith material facts of which it is aware that are relevant to a category of damages disclosed under Rule 3-8.

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Page 9 | 3-9

Parties must serve a list of claim terms for construction within 14 or 42 days depending on the trigger.

Not later than 14 days after service of the "Invalidity Contentions" pursuant to S.P.R 3-3, not later than 42 days after service upon it of the "Disclosure of Asserted Claims and Infringement Contentions" in those actions where validity is not at issue (and S.P.R 3-3 does not apply), or, in all cases in which a party files a complaint or other pleading seeking a declaratory judgment not based on validity, not later than 14 days after the defendant serves an answer that does not assert a claim for patent infringement (and S.P.R 3-1 does not apply), each party shall serve on each other party a list of claim terms which that party contends should be construed by the Court, and identify any claim term which that party contends should be governed by 35 U.S.C. § 112(6).

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Page 10 | 4-1(a)

Preliminary Claim Constructions must be exchanged within 21 days after exchange of lists, including identification of structure for §112(6) terms.

Not later than 21 days after the exchange of the lists pursuant to S.P.R 4-1, the parties shall simultaneously exchange proposed constructions of each term identified by either party for claim construction. Each such "Preliminary Claim Construction" shall also, for each term which any party contends is governed by 35 U.S.C. § 112(6), identify the structure(s), act(s), or material(s) corresponding to that term's function.

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Page 10 | 4-2(a)

Joint Claim Construction and Prehearing Statement must be filed within 60 days after service of Invalidity Contentions and include agreed constructions, disputed constructions with supporting references and extrinsic evidence.

Not later than 60 days after service of the "Invalidity Contentions," the parties shall complete and file a Joint Claim Construction and Prehearing Statement, which shall contain the following information: (a) The construction of those terms on which the parties agree; (b) Each party's proposed construction of each disputed term, together with an identification of all references from the specification or prosecution history that support that construction, and an identification of any extrinsic evidence known to the party on which it intends to rely either to support its proposed construction or to oppose another party's proposed construction.

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Page 10 | 4-3

Reply claim construction brief must be filed within 7 days after service of the responsive brief.

Not later than 7 days after service upon it of a responsive brief, the party claiming patent infringement, or the party asserting invalidity if there is no infringement issue present in the case, shall serve and file any reply brief and any evidence directly rebutting the supporting evidence contained in an opposing party’s response.

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Page 11 | 4-5(c)

Responsive claim construction brief must be filed within 14 days after service of the opening brief.

Not later than 14 days after service upon it of an opening brief, each opposing party shall serve and file its responsive brief and supporting evidence.

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Page 11 | 4-5(b)

Opening claim construction brief must be filed within 45 days after serving and filing the Joint Claim Construction and Prehearing Statement.

Not later than 45 days after serving and filing the Joint Claim Construction and Prehearing Statement, the party claiming patent infringement, or the party asserting invalidity if there is no infringement issue present in the case, shall serve and file an opening brief and any evidence supporting its claim construction.

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Page 11 | 4-5(a)

Zoom requests must be e-filed 7 days before the hearing and include a certificate of conference.

Requests to appear via Zoom must be e-filed seven (7) days before the hearing and must indicate that counsel has met and conferred per Local Rule 7-3.

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Page 3 | SCHEDULE OF PRETRIAL AND TRIAL DATES

Proposed FPTCO must be filed and emailed to Chambers at least 14 days before the FPTC, using the court's template.

A proposed Final Pretrial Conference Order ("Proposed FPTCO") shall be filed and emailed to Chambers at least fourteen (14) days before the FPTC. A template for the Proposed FPTCO is available on Judge Court's webpage. The parties must use this template.

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Page 4 | B. Final Pretrial Conference/Proposed Final Pretrial Conference Order

Motions in limine, memoranda, witness list, joint exhibit list, status report, proposed findings, and direct testimony declarations must be filed at least 28 days before FPTC.

At least twenty-eight (28) days before the FPTC: o Motions in Limine o Memoranda of Contentions of Fact and Law o Witness list o Joint Exhibit list o Joint Status Report Regarding Settlement o Proposed Findings of Fact and Conclusions of Law (bench trial only) o Declarations containing Direct Testimony (bench trial only)

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Page 5 | A. Schedule for Filing Pretrial Documents

Service and Proof of Service Rules

DOE or fictitiously-named defendants must be identified and served within 90 days after the case is filed, or they will be dismissed without prejudice.

Any “DOE” or fictitiously-named Defendant(s) who is not identified and served within 90 days after the case is filed shall be dismissed without prejudice pursuant to Fed. R. Civ. P. 4(m).

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Page 4 | Service of the Complaint

Plaintiff must promptly serve the Complaint per Fed. R. Civ. P. 4 and file proofs of service; defendants not timely served will be dismissed without prejudice.

The Plaintiff(s) shall promptly serve the Complaint in accordance with Fed. R. Civ. P. 4 and file the proofs of service pursuant to the Local Rules. Any Defendant(s) not timely served shall be dismissed from the action without prejudice.

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Page 4 | Service of the Complaint

Opposition or reply papers due on a holiday must be hand-delivered or emailed to opposing counsel on the preceding business day.

Opposition or reply papers due on a holiday must be filed the preceding business day (i.e., Thursday)—not the following business day (i.e., Monday)—and must be hand-delivered or emailed to opposing counsel on the preceding business day.

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Page 6 | Motions - General Requirements

Advance notice of an ex parte application must be provided to all other parties by telephone and email.

Counsel for the applicant must provide advance notice of the application by telephone and email to all other parties.

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Page 13 | Ex Parte Applications

Ex parte applications must be served by facsimile, email, or personal service even if electronic service is effected under Local Rule 5-3.2.1.

The applicant must serve the application by facsimile, email, or personal service, even if electronic service is effected under Local Rule 5-3.2.1.

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Page 13 | Ex Parte Applications

Plaintiff's counsel or a self-represented plaintiff must immediately serve this Order on all parties, including any new parties to the action.

Counsel for plaintiff or plaintiff (if appearing on their own behalf) shall immediately serve this Order on all parties, including any new parties to the action.

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Page 15 | Notice of this Order

In removed actions, the removing defendant(s) must serve this Order on all other parties.

If this case came to the Court by a Petition for Removal, the removing defendant(s) shall serve this Order on all other parties.

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Page 15 | Notice of this Order

Courtesy Copy Requirements

Chambers/courtesy copies must not be provided; the Court will issue an order requesting them only in the rare instances it wants them.

Please do not provide chambers/courtesy copies. In the rare instance in which the Court would like chambers copies for a particular situation, the Court will issue an order requesting them.

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Page 12 | Chambers Copies

Parties must deliver a portable storage device (e.g., USB flash drive) containing electronic versions of all trial exhibits and deposition excerpts to the judge's courtesy box outside the Clerk's Office by 12:00 p.m. on the Friday before trial.

In addition to providing the single set of three-ring binders discussed above, the parties must also submit to the Court an easily accessible portable storage device (e.g., a USB flash drive) containing electronic versions of all exhibits and any excerpts of deposition transcripts to be used at trial, either as evidence or for impeachment. The storage device must be delivered to the judge's courtesy box located outside the Clerk's Office on the 4th floor of the courthouse by 12:00 p.m. on the Friday before the start of trial.

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Page 13 | Final Pretrial Conference

On the first day of trial, parties must promptly deliver to the Courtroom Deputy Clerk the exhibit binder set and one copy of deposition transcript excerpts for the Court's use.

The parties must promptly present the following materials to the Courtroom Deputy Clerk on the first day of trial: 1. The single set of binders described above 2. One copy of any excerpts of deposition transcripts to be used as trial as evidence. This copy is for the Court's use. The parties must use their own copies during trial.

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Page 14 | IV. Materials to Present on First Day of Trial

Counsel must provide the Magistrate Judge with chambers copies of moving papers and responses consistent with the corresponding judge's procedures.

Counsel shall provide the Magistrate Judge with chambers copies of the moving papers and responses consistent with the corresponding judge's procedures.

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Page 6 | Discovery

Courtesy chambers copies of electronically filed Joint Rule 26(f) Reports are discouraged.

The Court discourages the submission of courtesy chambers copies of Joint Rule 26(f) Reports that have been electronically filed.

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Chambers copies not required for motion papers or exhibits.

The Court does not require chambers copies of any motion papers or exhibits and discourages the parties from sending chambers courtesy copies, unless otherwise specified.

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Sealing & Redaction Procedures

Trade secret cases require special identification procedures.

This provision shall apply in any case in which there is a claim, counterclaim, or crossclaim for misappropriation of trade secrets in violation of either the California Uniform Trade Secret Act ("CUTSA," Cal. Civ. Code. § § 3426–3426.11) or Defend Trade Secrets Act ("DTSA," 18 U.S. Code §§ 1836–1839).

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Page 6 | Trade Secret Cases

Sentencing documents may be filed under seal only when strictly necessary, with redacted version justifying deletions.

The Court does not permit sentencing documents to be filed under seal except as strictly necessary and justified. When necessary, a sentencing document may be filed under seal along with a redacted version that deletes the confidential information and that justifies each deletion (e.g., "medical information").

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Filing Bundling Requirements

Defense must provide two tabbed three-ring binders for exhibits if more than 20 exhibits expected.

In trials where the defense expects to admit more than 20 exhibits, defense counsel shall provide two three-ring binders (one for the Court and one for witnesses) tabbed, if possible, with numbers to correspond to the exhibits counsel expects to introduce.

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Court may issue Scheduling Order without conference based on Joint Rule 26(f) Report.

The Court may vacate the Scheduling Conference and issue the Scheduling Order based solely on the parties’ Joint Rule 26(f) Report pursuant to Federal Rule of Civil Procedure 16(b).

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Pre-Motion Conference Requirements

Counsel must comply with Local Rule 7-3 and engage in a pre-filing conference before filing motions (source text cut off mid-sentence).

Pre-filing Requirement: Counsel must comply with Local Rule 7-3, which requires counsel to engage in a pre-filing conference "to discuss

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Page 6 | Motions - General Requirements

Parties must confer in compliance with Local Rule 7-3 before filing a motion; pro se status does not excuse this, email alone is insufficient, and noncompliance may result in the motion being struck or denied.

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 pro se status of one or more parties does not negate this requirement. The parties are further advised that email correspondence alone is insufficient to satisfy this requirement. If the parties do not comply with Local Rule 7-3, the Court may strike or deny the motion.

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Page 7 | Motions - General Requirements

Parties must confer in good faith under Local Rule 7-3 before filing Rule 12 motions to dismiss or strike.

Motions Pursuant to Rule 12: Many motions to dismiss or to strike can be avoided if the parties confer in good faith (as required under Local Rule 7-3), especially for perceived defects in a complaint, answer, or counterclaim that could be corrected by amendment.

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Page 9 | Specific Motion Requirements

Each party may file no more than five motions in limine without first seeking leave from the Court.

Each party may file no more than five (5) motions in limine without seeking leave from the Court.

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Page 3 | Schedule of Pretrial and Trial Dates

Lead trial counsel for each party must meet and confer in person 40 days before the FPTC, and failure to comply with Local Rule 16 or this Order may result in the FPTC and trial being taken off calendar or other sanctions.

The parties must comply with Local Rule 16. Pursuant to Local Rule 16-2, lead trial counsel for each party must meet and confer in person forty (40) days in advance to prepare for the FPTC. The parties must comply with Local Rule 16-2, except where the requirements set forth in this Order differ from or supplement those contained in Local Rule 16. The Court may take the FPTC and trial off calendar or impose other sanctions for failure to comply with these requirements.

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Page 5 | II. Trial Preparation

Reply briefs are not permitted for motions in limine.

There shall be no replies.

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Page 6 | B. Requirements for Pretrial Documents - 1. Motions in Limine

Before filing a motion in limine, the parties must meet and confer to determine whether the disputed evidence will actually be introduced and attempt to resolve the issue without the motion.

Before filing a motion in limine, the parties must meet and confer to determine whether the opposing party intends to introduce the disputed evidence and attempt to reach an agreement that would obviate the need for the motion.

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Page 6 | B. Requirements for Pretrial Documents - 1. Motions in Limine

Parties are limited to five motions in limine and must seek leave of Court to file more.

No party may file more than five (5) motions in limine without seeking leave from the Court to do so.

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Page 6 | B. Requirements for Pretrial Documents - 1. Motions in Limine

The parties must meet and confer about the time estimates for each witness on the Joint Witness List.

The parties must also meet and confer about time estimates for each witness.

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Page 6 | B. Requirements for Pretrial Documents - 2. Joint Witness List

Motions in limine are heard and ruled on at the FPTC, and the Court may rule orally instead of in writing.

Motions in limine will be heard and ruled on at the FPTC. The Court may rule orally instead of in writing.

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Page 6 | B. Requirements for Pretrial Documents - 1. Motions in Limine

Pre-filing conference requirement applies even with pro se parties.

The pro per status of one or more parties does not negate this requirement.

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Pre-filing conference required before filing motions.

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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Parties must meet and confer before filing a motion in limine.

Before filing a motion in limine, the parties must meet and confer to determine whether the opposing party intends to introduce the disputed evidence and attempt to reach an agreement that would obviate the need for the motion.

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Page 6 | B. Requirements for Pretrial Documents - 1. Motions in Limine

Briefing schedule: motions 5 weeks, oppositions 3 weeks, replies 2 weeks before hearing.

For all motions other than motions in limine, the briefing schedule is as follows: motions shall be filed five (5) weeks prior to the hearing; oppositions or notices of non-opposition shall be filed three (3) weeks prior to the hearing; and replies, if any, shall be filed two (2) weeks prior to the hearing.

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Pretrial motions must be noticed for mutually agreed Friday.

All pretrial motions, including motions to suppress evidence, motions to bifurcate or sever, and motions concerning character evidence under Federal Rule of Evidence 404(b), shall be noticed for a Friday that is mutually agreed to by counsel.

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Lead trial counsel must meet and confer in person 40 days before the FPTC.

Pursuant to Local Rule 16-2, lead trial counsel for each party are required to meet and confer in person forty (40) days in advance to prepare for the FPTC.

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Page 5 | II. Trial Preparation

Claim Construction Hearing will be held two weeks after submission of the reply brief, subject to court calendar and necessity.

Subject to the convenience of the Court’s calendar, two weeks following submission of the reply brief specified in S.P.R 4-5(c), the Court shall conduct a Claim Construction Hearing, to the extent the parties or the Court believe a hearing is necessary for construction of the claims at issue.

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Page 12 | 4-6

Pre-filing conference should resolve issues to focus briefing on substantive matters.

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.

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Minor procedural matters should be resolved during pre-filing conference.

Counsel should resolve minor procedural or other non-substantive matters during the conference.

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Adjournment & Extension Requirements

A stipulation to continue any matter before the Court must be supported by a sufficient basis demonstrating good cause.

a stipulation to continue the date of any matter before this Court must be supported by a sufficient basis that demonstrates good cause

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Page 13 | Continuances

Proposed stipulations extending scheduling dates are not effective unless and until the Court so orders.

Proposed stipulations extending scheduling dates do not become effective unless and until this Court so orders.

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Page 14 | Continuances

Continuance requests must state prior extension requests, whether they were granted, the requesting party's diligence, and any prejudice if the continuance is denied.

The requesting party must also set forth: (1) whether there have been prior requests for extension, (2) whether these requests were granted by the Court, (3) a description of the diligence of the party seeking the continuance, and (4) any prejudice that may result if the continuance is denied.

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Page 14 | Continuances

Continuance requests that fail to comply with the Local Rules and this Order will be rejected.

Failure to comply with the Local Rules and this Order will result in rejection of the request.

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Page 14 | Continuances

Stipulations extending Court-set dates are not effective unless approved by the Court and will be denied absent compelling factual support and a showing of due diligence.

Stipulations extending dates set by the Court are not effective unless approved by the Court, and without compelling factual support and a showing of due diligence, stipulations continuing dates set by the Court will be denied.

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Page 19 | L. Continuances of Pretrial and Trial Dates

Continuance requests for pretrial and/or trial dates must be by motion, stipulation, or application supported by a declaration containing a detailed showing of good cause and due diligence, the reasons for the request, and the history of any prior continuance requests.

Any request for continuance of pretrial and/or trial dates must be by motion, stipulation, or application, and must be supported by a declaration setting forth the reasons for the requested relief. The declaration must contain a highly detailed factual showing of good cause and due diligence demonstrating the necessity for the continuance and a description of the parties' efforts, dating back to the filing of the complaint, of the steps they have taken to advance the litigation. This detailed showing must demonstrate that the work still to be performed reasonably could not have been accomplished within the applicable deadlines. General statements are insufficient to establish good cause. The declaration should also include whether any previous requests for continuances have been made and whether these requests were granted or denied by the Court.

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Page 19 | L. Continuances of Pretrial and Trial Dates

Continuances are strongly disfavored, rarely granted, and firm trial dates will rarely be changed.

This Court has a strong interest in keeping scheduled dates certain. Changes in dates are strongly disfavored and rarely granted. Trial dates set by the Court are firm and will rarely be changed.

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Page 13 | Continuances

Stipulations continuing dates set by the Court will not be approved.

stipulations continuing dates set by this Court will not be approved.

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Page 14 | Continuances

Discovery adequacy motions must be filed early enough to obtain responses before cut-off.

any motion challenging the adequacy of discovery responses must be filed timely, served, and calendared sufficiently in advance of the discovery cut-off date to permit the responses to be obtained before that date, if the motion is granted.

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Page 5 | Schedule Worksheet

Continuance of Scheduling Conference requires good cause.

A request to continue the Scheduling Conference will be granted only for good cause.

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Requests for continuance of pretrial or trial dates must be by motion or stipulation supported by a detailed declaration showing good cause and due diligence; stipulations require court approval.

L. Continuances of Pretrial and Trial Dates The Court has a strong interest in keeping scheduled dates certain. Accordingly, pretrial and trial dates set by the Court are firm, and rarely will be changed. Any request for continuance of pretrial and/or trial dates must be by motion, stipulation, or application, and must be supported by a declaration setting forth the reasons for the requested relief. The declaration must contain a highly detailed factual showing of good cause and due diligence demonstrating the necessity for the continuance and a description of the parties’ efforts, dating back to the filing of the complaint, of the steps they have taken to advance the litigation. This detailed showing must demonstrate that the work still to be performed reasonably could not have been accomplished within the applicable deadlines. General statements are insufficient to establish good cause. The declaration should also include whether any previous requests for continuances have been made and whether these requests were granted or denied by the Court. Stipulations extending dates set by the Court are not effective unless approved by the Court, and without compelling factual support and a showing of due diligence, stipulations continuing dates set by the Court will be denied.

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Page 19 | L. Continuances of Pretrial and Trial Dates

Continuance requests must be by motion/stipulation/application with supporting declaration.

Any request for continuance of pretrial and/or trial dates must be by motion, stipulation, or application, and must be supported by a declaration setting forth the reasons for the requested relief.

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Oppositions to ex parte applications must be filed within 24 hours.

Oppositions to ex parte applications must be filed within 24 hours of the filing of the application.

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Oppositions to motions in limine must be filed at least 14 days before the Final Pretrial Conference.

Oppositions must be filed at least fourteen (14) days before the Final Pretrial Conference.

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Motions in limine must be filed at least 28 days before the Final Pretrial Conference.

All motions in limine must be filed at least twenty-eight (28) days before the Final Pretrial Conference.

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Sentencing hearings cannot be continued without detailed good cause.

Once set, the sentencing hearing shall not be continued absent a detailed, substantial showing of good cause.

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Requests for continuance of trial must be submitted at least one week before the Final Pretrial Conference.

Counsel shall avoid submitting requests for continuance of trial less than one (1) week prior to the Final Pretrial Conference.

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Chambers Communication Rules

A Word-format copy of each proposed order must be emailed to MWC_Chambers@cacd.uscourts.gov on the date the document is electronically filed.

In addition, a copy of the proposed order in Word format shall be emailed directly to the Court’s chambers email address at MWC_Chambers@cacd.uscourts.gov on the date the document is electronically filed.

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Page 12 | Proposed Orders

The Court prohibits appearances and arguments by telephone conference call.

The Court does not permit appearances or arguments by way of telephone conference calls.

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Page 12 | Telephonic Hearings

Counsel may not contact the Courtroom Deputy Clerk about the status of any matter and may make only appropriate inquiries.

Counsel must not contact the Courtroom Deputy Clerk regarding the status of any matter before the Court. Counsel may contact the Courtroom Deputy Clerk with appropriate inquiries only.

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Page 14 | Communications with Chambers

Counsel may not contact the Court or its staff by telephone or other ex parte means unless chambers staff initiated the contact first.

Counsel shall not attempt to contact the Court or its staff by telephone or by any other ex parte means unless contact has been first initiated by chambers staff.

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Page 14 | Communications with Chambers

Chambers email submissions must be sent to MWC_Chambers@cacd.uscourts.gov in Word format.

All emailed submissions to Chambers referred to in this Order must be in Word format and emailed to MWC_Chambers@cacd.uscourts.gov.

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Page 2 | A. Scheduling Order

All trial filings must be filed with the Court and also emailed in Word version to the chambers email box at MWC_Chambers@cacd.uscourts.gov.

All trial filings must be both filed with the Court and emailed in Word version to the chambers email box at MWC_Chambers@cacd.uscourts.gov.

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Page 3 | Schedule of Pretrial and Trial Dates

Pretrial documents must be emailed in Word version to the chambers email address MWC_Chambers@cacd.uscourts.gov on the day they are due.

emailed in Word version to MWC_Chambers@cacd.uscourts.gov the day they are due.

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Page 6 | A. Schedule for Filing Pretrial Documents

Counsel bringing electronic equipment for trial must give notice by email to the Courtroom Deputy Clerk at MWC_Chambers@cacd.uscourts.gov no later than 4 days before trial.

If electronic equipment must be brought into the courtroom for trial, counsel shall make prior arrangements with the Court Security. Notice must be given to the Courtroom Deputy Clerk at MWC_Chambers@cacd.uscourts.gov no later than four (4) days before trial.

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Page 13 | Final Pretrial Conference

By 12:00 p.m. on the Friday before trial, parties must email a zip file of all exhibits to chambers at MWC_Chambers@cacd.uscourts.gov.

By the same date and time, the parties shall deliver a zip file of all exhibits to the Court's email at MWC_Chambers@cacd.uscourts.gov.

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Page 13 | Final Pretrial Conference

When a proposed order is based on a stipulation or ex parte application, counsel must email both documents to chambers; otherwise, accompanying documents such as motions should not be emailed to chambers.

If the proposed order is based on a stipulation or an ex parte application, counsel must email both the order and the stipulation or ex parte application. Otherwise, accompanying documents (such as motions) should not be emailed to chambers.

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Page 12 | Proposed Orders

Counsel must email the Courtroom Deputy Clerk as soon as possible if their party will not oppose an ex parte application.

If an opposing party does not intend to oppose the ex parte application, counsel must inform the Courtroom Deputy Clerk by email as soon as possible.

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Page 13 | Ex Parte Applications

Parties requesting special court reporter services (e.g., Real Time transmission or daily transcripts) must notify Court Reporting Services at least 14 days before the hearing.

Any party requesting special court reporter services for any hearing, such as “Real Time” transmission or daily transcripts, shall notify Court Reporting Services at least fourteen (14) days before the hearing date.

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Page 14 | V. Court Reporter

Parties must give the Court advance notice of anticipated difficult legal issues and must notify the Courtroom Deputy Clerk immediately of unexpected legal issues, including before jurors are excused for the day if the issue must be addressed outside the jury's presence.

If any party anticipates that a difficult question of law or evidence will necessitate legal argument requiring research or briefing, that party must give the Court advance notice. The parties must notify the Courtroom Deputy Clerk immediately of any unexpected legal issue that could not have been foreseen and addressed in advance. To the extent such issue must be addressed outside the jury's presence, the relevant party must inform the Courtroom Deputy Clerk before jurors are excused for the day to minimize the time jurors are kept waiting. The Court expects all parties to work diligently to minimize delays and avoid keeping jurors waiting.

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Page 19 | K. Advance Notice of Unusual or Difficult Issues

Counsel must contact the Magistrate Judge's Courtroom Deputy Clerk to schedule discovery matters for hearing.

Counsel are directed to contact the Magistrate Judge's Courtroom Deputy Clerk to schedule matters for hearing.

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Page 5 | Discovery

The preferred way to contact the Courtroom Deputy Clerk is email to MWC_Chambers@cacd.uscourts.gov.

The preferred method of communication with the Courtroom Deputy Clerk is email to the Chambers email address MWC_Chambers@cacd.uscourts.gov.

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Page 14 | Communications with Chambers

Scheduling conferences are in-person by default; Zoom requests require 7-day advance filing with good cause declaration and meet-and-confer certification.

By default, all scheduling conferences shall proceed in-person, unless a request is made by the parties and granted by the Court. Requests to appear via Zoom must be e-filed seven (7) days before the conference, supported by an appropriate declaration establishing good cause, and must indicate that counsel has met and conferred per Local Rule 7-3.

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Trial filings must be both filed on ECF and emailed in Word format to chambers.

All trial filings must be filed as well as emailed in Word version to the chambers email box at MWC_Chambers@cacd.uscourts.gov.

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Page 3 | SCHEDULE OF PRETRIAL AND TRIAL DATES

Proposed FPTCO must be emailed to Chambers.

A proposed Final Pretrial Conference Order ("Proposed FPTCO") shall be filed and emailed to Chambers at least fourteen (14) days before the FPTC. A template for the Proposed FPTCO is available on Judge Court's webpage. The parties must use this template.

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Page 4 | B. Final Pretrial Conference/Proposed Final Pretrial Conference Order

Parties must email verdict forms to Chambers 14 days before FPTC.

The parties shall file and email to Chambers a proposed joint general or special verdict form fourteen (14) days before the FPTC. If the parties are unable to agree on a verdict form, the parties shall file and email to Chambers one document titled “Competing Verdict Forms” which shall include: (1) the parties’ respective proposed verdict form; (2) a redline of any disputed language; and (3) the factual or legal basis for each party’s respective position.

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Page 10 | Joint Verdict Forms (Jury Trials Only)

Parties must email Joint Statement of the Case to Chambers 14 days before FPTC.

The parties shall file and email to Chambers a Joint Statement of the Case fourteen (14) days before the FPTC for the Court to read to the prospective jurors before commencement of voir dire.

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Page 10 | Joint Statement of the Case (Jury Trials Only)

Proposed trial dates must be cleared with the Courtroom Deputy Clerk via email.

Counsel shall also clear any proposed trial dates with the Courtroom Deputy Clerk by contacting the Court’s chambers email address at MWC_Chambers@cacd.uscourts.gov.

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Calendar conflicts must be reported to chambers via email within 3 business days.

If any counsel discovers a calendar conflict with a scheduled appearance in a court of a more senior district judge, counsel must inform opposing counsel and the Courtroom Deputy Clerk via chambers email address at: MWC_Chambers@cacd.uscourts.gov as soon as possible and no later than three (3) business days before the scheduled appearance.

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Notice required 4 days before trial for electronic equipment in courtroom.

If electronic equipment must be brought into the courtroom for trial, counsel shall make prior arrangements with the Court Security. Notice must be given to the Courtroom Deputy Clerk at MWC_Chambers@cacd.uscourts.gov no later than four (4) days before trial.

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Notice required 14 days before hearing for special court reporter services.

Any party requesting special court reporter services for any hearing, such as "Real Time" transmission or daily transcripts, shall notify Court Reporting Services at least fourteen (14) days before the hearing date.

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Ex parte application notice must be provided by telephone and email to all parties.

Counsel for the applicant must provide notice of the application by telephone and email to all other parties.

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Counsel must check motion date availability immediately before filing.

Counsel are advised to check the availability of a selected date immediately prior to filing the motion.

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Certain trial documents must be emailed to Chambers in addition to filing.

The Joint Exhibit List shall be filed and emailed to Chambers twenty-eight (28) days before the FPTC. Any Amended Joint Exhibit List shall be filed and emailed to Chambers by 12:00 p.m. (noon) on the Friday before trial. Joint Proposed Jury Instructions shall be filed and emailed to Chambers no later than fourteen (14) days prior to the FPTC. The parties shall file and email to Chambers clean and redline sets of: (1) their Joint Agreed Upon Proposed Jury Instructions; and (2) their Disputed Jury Instructions.

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Page 7 | Joint Exhibit List and Jury Instructions

Parties may email proposed voir dire questions to Chambers no later than 14 days before FPTC.

The parties may file and email to Chambers any proposed case-specific voir dire questions for the Court’s consideration no later than fourteen (14) days before the FPTC.

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Page 10 | Proposed Voir Dire Questions (Jury Trials Only)

Notice to Courtroom Deputy Clerk at MWC_Chambers@cacd.uscourts.gov required at least 4 days before trial if bringing electronic equipment.

If electronic equipment must be brought into the courtroom for trial, counsel shall make prior arrangements with the Court Security. Notice must be given to the Courtroom Deputy Clerk at MWC_Chambers@cacd.uscourts.gov no later than four (4) days before trial.

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Page 13 | III. Trial Exhibits

Notice to Court Reporting Services required at least 14 days before hearing for special court reporter services.

Any party requesting special court reporter services for any hearing, such as 'Real Time' transmission or daily transcripts, shall notify Court Reporting Services at least fourteen (14) days before the hearing date.

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Page 14 | V. Court Reporter

Counsel must address non-jury matters at 8:30 AM, breaks, or end of day; not in jury's presence.

All counsel must anticipate matters that may need to be addressed outside of the presence of the jury and raise them at 8:30 a.m., during breaks, or at the end of the day. The Court is not in the practice of requiring jurors to sit idly by while counsel discuss matters that should have been addressed outside of the jury's presence.

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Hearings scheduled on Fridays at 1:30 PM.

Hearings shall be held on Fridays starting at 1:30 p.m.

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Page 5 | Schedule Worksheet

Email is preferred for communicating with Courtroom Deputy Clerk; include email and phone on all papers.

The preferred method of communication with the Courtroom Deputy Clerk is email. To facilitate communication with the Courtroom Deputy Clerk, counsel should list their email addresses along with their telephone numbers on all papers.

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Page 11 | Communication with Courtroom Deputy Clerk

Pro se litigants may mail filings to Clerk or use EDSS if unable to e-file.

Unrepresented litigants who cannot electronically file their documents in the CM/ECF system may mail their filings to the Clerk of Court at 255 E. Temple Street, Suite TS-134, Los Angeles, CA 90012-3332 or submit documents for filing through the Court's Electronic Document Submission System (EDSS). For additional filing information, please visit the Court's website, scroll down to the box labeled 'People without Lawyers,' and click 'Questions and Answers.'

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CM/ECF system available 24/7 for electronic filing; parties may register for PACER access.

The Court's CM/ECF system is available 24/7 for electronic filing of documents. Parties may register for access to PACER. For more information, please visit the Court's website.

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Emailed submissions to Chambers must be sent to MWC Chambers@cacd.uscourts.gov.

All emailed submissions to Chambers referred to in this Order must be in Word format and emailed to MWC Chambers@cacd.uscourts.gov.

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Page 2 | I. Schedule

Pretrial documents must be emailed in Word version to MWC_Chambers@cacd.uscourts.gov on the due date.

All pretrial documents listed above, including any amended documents, shall be filed and emailed in Word version to MWC_Chambers@cacd.uscourts.gov the day they are due.

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Page 6 | A. Schedule for Filing Pretrial Documents

Proposed Findings of Fact and Conclusions of Law must be emailed to Chambers.

For any trial requiring findings of fact and conclusions of law, each party shall file and email to Chambers its Proposed Findings of Fact and Conclusions of Law in the format specified in Local Rule 52-3 no later than twenty-eight (28) days before the FPTC.

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Page 11 | 8. Proposed Findings of Fact and Conclusions of Law (Bench Trials Only)

Counsel must email Microsoft Word versions of Proposed Findings to chambers.

In addition to filing, counsel must email Microsoft Word versions of their Proposed Findings of Fact and Conclusions of Law to the chambers email address.

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Page 11 | 8. Proposed Findings of Fact and Conclusions of Law (Bench Trials Only)

Declarations of direct testimony must be emailed to Chambers.

When ordered by the Court in a particular case, each party shall file and email to Chambers declarations containing the direct testimony of each witness whom that party intends to call at trial at least twenty-eight (28) days before the FPTC.

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Page 11 | 9. Declarations of Direct Testimony (Bench Trials Only)

Evidentiary objections must be emailed to Chambers.

If such declarations are filed, each party shall file and email to Chambers any evidentiary objections to the declarations submitted by any other party at least fourteen (14) days before the FPTC.

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Page 11 | 9. Declarations of Direct Testimony (Bench Trials Only)

Case-specific glossary must be emailed to Chambers.

The case-specific glossary shall be filed and emailed in Word version to Chambers no later than the Friday before trial.

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Page 12 | 10. Case-Specific Glossary

Counsel may indicate pronouns/honorifics via letter, pleadings, or verbal notice.

Counsel may indicate their pronouns and honorifics and those of the defendant by filing a letter, adding the information in the name block or signature line of the pleadings, or verbally informing the Court when making an appearance.

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Non-opposition to ex parte applications must be reported to Courtroom Deputy by email promptly.

If an opposing party does not intend to oppose the ex parte application, counsel must inform the Courtroom Deputy by email as soon as possible.

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Junior Lawyer Participation Incentives

The Court encourages junior counsel to present argument and is more likely to hold oral argument if a party files a notice at least 7 days before the hearing stating that junior counsel will conduct the argument or most of it.

The Court encourages parties to permit less experienced lawyers, including lawyers from historically under-represented groups, to actively participate in the proceedings by presenting argument at motion hearings or examining witnesses at trial. The Court is more likely to hear oral argument if any party files a notice at least seven (7) days before a scheduled hearing stating that junior counsel, including lawyers from historically under-represented groups, will conduct the argument, or most of it.

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Page 8 | Motions - General Requirements

The Court strongly encourages litigants to give less experienced lawyers, or lawyers whose backgrounds further the diversity of the legal profession, opportunities to participate in trial and the FPTC.

The Court has a strong commitment to fostering the development of new and diverse lawyers in the legal community. Consequently, the Court strongly encourages litigants to provide opportunities for less experienced lawyers or lawyers whose identities and/or backgrounds further the diversity of the legal profession to participate in trial and in the FPTC, particularly where they contributed significantly to the underlying issue or prepared the witness. Of course, the ultimate decision of who speaks on behalf of the client is for the client and not the Court.

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Page 4 | Final Pretrial Conference

Junior lawyers from under-represented groups conducting argument may increase likelihood of oral argument.

The Court encourages parties to permit less experienced lawyers, including lawyers from historically under-represented groups, to actively participate in the proceedings by presenting argument at motion hearings or examining witnesses at trial. The Court is more likely to hear oral argument if any party files a notice at least seven (7) days before a scheduled hearing stating that junior counsel, including lawyers from historically under-represented groups, will conduct the argument,

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About United States District Judge Michelle Williams Court

**Judge Michelle Williams Court** was appointed to the Central District of California by President Joe Biden in 2024. She is the fifth Black woman to serve as a lifetime judge on the Central District. Court was born in 1966 in Great Falls, Montana. She earned her undergraduate degree from Pomona College and her law degree from Loyola Law School. She worked at the ACLU of Southern California, then at a civil rights litigation firm, before serving as a Community Builder Fellow at HUD and later at Milberg Weiss on consumer class actions. She spent a decade at Bet Tzedek Legal Services in leadership roles including interim President and CEO. Governor Jerry Brown appointed her to the Los Angeles County Superior Court in 2012, where she rose to Supervising Judge of the Civil Division. **Education** - Loyola Law School, J.D., 1993 - Pomona College, B.A., 1988 **Career** - Project attorney, ACLU of Southern California, 1994–1995 - Associate, Litt & Márquez, 1995–1999 - Community Builder Fellow, Civil Rights Specialist, U.S. Department of Housing and Urban Development, 1999–2000 - Senior associate, Milberg Weiss Bershad Hynes & Lerach, 2000–2002 - Deputy Director and Director of Litigation; interim President and CEO; Vice President and General Counsel, Bet Tzedek Legal Services, 2002–2012 - Adjunct Professor, Loyola Law School, 2006 - Judge, Superior Court of California, Los Angeles County, 2012–2024 (appointed by Governor Jerry Brown; Supervising Judge, Civil Division, 2023) - U.S. District Judge, Central District of California, 2024–present

**Courthouse:** First Street U.S. Courthouse, 350 W. 1st Street, Los Angeles, CA 90012 **Division:** Western Division (Los Angeles) **Chambers Staff** - Chambers Email: MWC_Chambers@cacd.uscourts.gov

Common questions about Judge Michelle Williams Court's rules

Are courtesy copies required for Judge Michelle Williams Court?

The rule limits courtesy-copy delivery rather than stating a blanket requirement before Judge Michelle Williams Court. Chambers/courtesy copies must not be provided; the Court will issue an order requesting them only in the rare instances it wants them.

View ruleSource: page 12, section Chambers Copies

Does Judge Michelle Williams Court require a pre-motion conference or letter before filing a motion?

Judge Michelle Williams Court's rules set a pre-motion procedure for covered motions. Counsel must comply with Local Rule 7-3 and engage in a pre-filing conference before filing motions (source text cut off mid-sentence).

View ruleSource: page 6, section Motions - General Requirements

What page or word limits apply to memorandum of points and authorities before Judge Michelle Williams Court?

Judge Michelle Williams Court's rule states these limits: 25 pages; 12 pages. Moving and opposition memoranda are limited to 25 pages and reply memoranda to 12 pages, with extensions granted only in rare instances for good cause.

View ruleSource: page 7, section Motions - General Requirements

What page or word limits apply to brief before Judge Michelle Williams Court?

Judge Michelle Williams Court's rule states these limits: attorney: 25 pages. Motion memoranda limited to 25 pages.

What formatting rules apply to filings before Judge Michelle Williams Court?

Judge Michelle Williams Court's formatting rule includes 14 point type, either proportionally spaced or monospaced font is permitted, monospaced font may not contain more than 10.5 characters per inch, and typeface requirements apply to footnoted material. Motion papers may use a proportionally spaced font of at least 14 points or a monospaced font of no more than 10.5 characters per inch, and these requirements apply to footnotes.

View ruleSource: page 7, section Motions - General Requirements

What must be included with joint rule 26f report filings before Judge Michelle Williams Court?

The rule requires judge name and case number. Joint Rule 26(f) Report due 7 days after meet-and-confer and 14 days before scheduling conference.

What must be included with joint rule 26(f) report filings before Judge Michelle Williams Court?

The rule requires proposed order and exhibit list. Joint Rule 26(f) Report must include completed Schedule Worksheet.

View ruleSource: page 5, section Schedule Worksheet

How may parties contact Judge Michelle Williams Court's chambers?

The rule addresses email communications with Judge Michelle Williams Court's chambers. Scheduling conferences are in-person by default; Zoom requests require 7-day advance filing with good cause declaration and meet-and-confer certification.

How does Judge Michelle Williams Court handle sealed or redacted filings?

Judge Michelle Williams Court's rules set procedures for sealed or redacted filings. Process: file redacted on ecf and file unredacted to chambers. Trade secret cases require special identification procedures.

View ruleSource: page 6, section Trade Secret Cases

How do I request an adjournment or extension before Judge Michelle Williams Court?

Advance notice is not fully stated in the structured details. Continuance of Scheduling Conference requires good cause.

Does Judge Michelle Williams Court require motion papers to be bundled?

Yes. Judge Michelle Williams Court requires bundling for covered papers. Defense must provide two tabbed three-ring binders for exhibits if more than 20 exhibits expected.

Is electronic filing required before Judge Michelle Williams Court?

Yes. Electronic filing is required for the covered filings. Zoom requests must be e-filed.

View ruleSource: page 3, section SCHEDULE OF PRETRIAL AND TRIAL DATES

What filing deadlines does Judge Michelle Williams Court set?

Damages Contentions must be served within 50 days after service of Invalidity Contentions and include categories and good faith explanation.

View ruleSource: page 9, section 3-8

What rule applies to service for complaint before Judge Michelle Williams Court?

Proof of service is required for the covered service rule. Details: method: personal service, recipient: the opposing party. Plaintiff must promptly serve the Complaint per Fed. R. Civ. P. 4 and file proofs of service; defendants not timely served will be dismissed without prejudice.

View ruleSource: page 4, section Service of the Complaint

Does Judge Michelle Williams Court encourage junior lawyer participation?

Yes. Judge Michelle Williams Court's rules include a junior lawyer participation incentive. The Court encourages junior counsel to present argument and is more likely to hold oral argument if a party files a notice at least 7 days before the hearing stating that junior counsel will conduct the argument or most of it.

View ruleSource: page 8, section Motions - General Requirements
Complete rules summary for Judge Michelle Williams Court

Scheduling conferences are in-person by default; Zoom requests require 7-day advance filing with good cause declaration and meet-and-confer certification.

Joint Rule 26(f) Report due 7 days after meet-and-confer and 14 days before scheduling conference.

Courtesy chambers copies of electronically filed Joint Rule 26(f) Reports are discouraged.

Joint Rule 26(f) Report drafted by Plaintiff or Defendant's counsel; if Plaintiff pro se, Defendant's counsel drafts unless Plaintiff prefers.

Joint Rule 26(f) Report must be a single signed report from all parties.

Joint Rule 26(f) Report must include scheduling conference date on caption page.

Parties must discuss likelihood of additional parties appearing.

All parties must personally attend ADR before trial.

Trial estimates over 4 days require detailed justification.

Parties may consent to magistrate judge for all proceedings including jury trials.

Court defaults to Court Mediation Panel if no ADR method selected.

Joint Rule 26(f) Report must include completed Schedule Worksheet.

Discovery cut-off date is last day for depositions, responses, and discovery motions.

Worksheet completion instructions for agreed/disagreed dates.

Trade secret cases require special identification procedures.

Trade secret identification statement must include numbered list, background, and secrecy efforts.

Trade secret identification must be filed and served within 60 days.

Trade secret discovery cannot begin until identification is filed.

Parties may agree to a later deadline for trade secret identification.

Continuance of Scheduling Conference requires good cause.

Court may issue Scheduling Order without conference based on Joint Rule 26(f) Report.

Lead trial counsel must attend Scheduling Conference unless excused for good cause.

Failure to submit Joint Rule 26(f) Report or attend Scheduling Conference may result in dismissal, default, or sanctions.

Counsel must provide Order to parties appearing after its date.

Counsel must deliver copy of Order to their clients.

Hearings scheduled on Fridays at 1:30 PM.

Discovery adequacy motions must be filed early enough to obtain responses before cut-off.

Damages Contentions may not be amended without leave of court.

Parties must promptly file a Notice of Pendency of Other Action Involving Same Patent when they learn of related actions filed within two years by the same plaintiff.

All patent disclosures must be dated and signed by counsel, with signature certifying completeness and correctness.

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