Judge Mónica Ramírez Almadani
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
All filings
- Upon request
Binding: Tabbed Three Ring
Courtesy copies
- 1 copy
Adjournments
- The pretrial schedule may only be modified for good cause and with the judge's consent.
- Continuance requests for pretrial/trial dates must be via motion/stipulation/application with a serially numbered title, supporting declaration showing good cause and due diligence, and disclosure of prior continuances.
- Final Pretrial Conference and trial dates will not be rescheduled solely due to incomplete expert discovery.
Request must include
- Counsel must notify chambers of calendar conflicts at least 3 days before scheduled appearances and propose new dates via Stipulation and Proposed Order.
Communication
Chambers
Clerk
Page & Word Limits3 rules
Machine summary. Not checked yet.Mandatory?
Motions in limine and oppositions must not exceed ten (10) pages in length. There shall be no replies.
Summary: Motions in limine and oppositions are limited to 10 pages; reply briefs are prohibited.
Structured details unavailable. See the source text.
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The joint statement should be brief and neutral and should not be more than one page in length.
Summary: Joint Statement of the Case is limited to one page in length.
Joint Statement Of Case
1 pages
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Short briefs (no more than five pages) addressing such disputed issues are highly encouraged.
Summary: Disputed issue briefs during trial are highly encouraged to be no more than 5 pages.
Brief
5 pages
Applies to: Attorney
Document Format Requirements29 rules
Machine summary. Not checked yet.Mandatory?
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.
Summary: Defense counsel must provide two three-ring binders of exhibits if expecting to admit more than 20 exhibits, tabbed if possible.
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c. One set of three-ring binder(s) containing all of the government’s original exhibits, with official exhibit tags attached and bearing the same number shown on the exhibit list. Digital exhibit tags are available on the Court’s website under Court Forms > General Forms > Form G-14A (plaintiff) and G-14B (defendant). Digital exhibit tags may be used in place of the tags obtained from the Clerk’s Office. Exhibits shall be numbered 1, 2, 3, etc., NOT 1.1, 1.2, etc. If a “blow-up” is an enlargement of an existing exhibit, it shall be designated with the number of the original exhibit followed by an “A”;
Summary: Government original exhibits must be in three-ring binders with attached exhibit tags matching the exhibit list number, numbered sequentially (no decimals), with blow-ups designated as original number + 'A'; digital tags per Form G-14A/G-14B are allowed.
Machine summary. Not checked yet.Mandatory?
Defense counsel are responsible for affixing completed exhibit tags with the case name and case number to all exhibits to be used in defendant’s case.
Summary: Defense counsel must affix completed exhibit tags containing the case name and number to all defense exhibits.
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Accordingly, counsel must submit to the Chambers e-mail (MRA_chambers@cacd.uscourts.gov) a “clean” set of all instructions in Word format, containing only the text of each instruction, set forth in full on each page, with the caption “Instruction No. ____” (eliminating titles, supporting authority, indication of party proposing, etc.).
Summary: Jury instructions must be submitted in Word (DOCX) format.
DOCX
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Any stipulation of fact will require defendant’s personal concurrence and shall be submitted to the Court in writing for approval.
Summary: Stipulations of fact must be submitted to the Court in paper (written) format and require defendant personal concurrence.
Paper
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All expert disclosures must be made in writing.
Summary: Expert disclosures are required to be made in writing.
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ready” state, meaning they must be three-hole punched on the left side, without blue-backs, and clipped, not stapled, only in the top left corner.
Summary: Chambers copies of pretrial documents must be three-hole punched left, without blue-backs, and clipped (not stapled) top left.
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(b) Red-lined Copy. The parties shall file clean and redline sets of their (i) Joint Agreed Upon Proposed Jury Instructions, and (ii) 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. Where appropriate, the disputed instructions shall be organized by subject, so that instructions that address the same or similar issues are presented sequentially.
Summary: Parties must file clean and redline versions of jury instructions, with redline sets including required content and disputed instructions organized by subject.
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(c) Sources. When the Manual of Model Jury Instructions for the Ninth Circuit provides an applicable jury instruction, the parties should submit the most recent version, modified and supplemented to fit the circumstances of the case. Where California law applies, the parties should use the current edition of the Judicial Council of California Civil Jury Instructions. If neither applies, the parties should consult the current alternatives to these instructions only if there is a reasoned argument that they do not properly state the law or are incomplete.
Summary: Jury instructions must use specified sources: Ninth Circuit Manual if applicable, CA Civil Jury Instructions if CA law, else alternatives only with reasoned argument.
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(d) Format. Each requested instruction shall (i) cite the authority or source of the instruction; (ii) be set forth in full; (iii) be on a separate page; (iv) be numbered; (v) cover only one subject or principle of law; and (vi) not repeat principles of law contained in any other requested instruction. If a standard instruction has blanks or offers options (e.g., for gender), the parties must fill in the blanks or make the appropriate selections in their proposed instructions.
Summary: Each requested jury instruction must cite authority, be full text, on separate page, numbered, single subject, no repetition, and fill blanks in standard instructions.
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each party shall file and serve on the opposing party its Proposed Findings of Fact and Conclusions of Law in the format specified in L.R. 52-3.
Summary: Proposed Findings of Fact and Conclusions of Law must be filed and served in the format required by Local Rule 52-3 for bench trials.
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Trial exhibits that consist of documents and photographs must be submitted to the Court in three-ring binders.
Summary: Document and photograph trial exhibits must be submitted in three-ring binders.
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Every page of a multi-page exhibit must be numbered.
Summary: All pages of multi-page trial exhibits must be numbered.
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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.
Summary: Parties must submit three sets of trial exhibit binders: one original and two copies.
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The original exhibits shall bear the official exhibit tags (yellow tags for Plaintiff’s exhibits and blue tags for Defendant’s exhibits) stapled to the front of the exhibit on the upper right corner with the case number, case name, and
Summary: Original trial exhibits must have color-coded official tags stapled to the upper right front with case details.
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Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc. See L.R. 16-6.
Summary: Trial exhibits must be numbered sequentially without decimal points per Local Rule 16-6.
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All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side.
Summary: Trial exhibits in three-ring binders must be indexed with tabs or dividers on the right side.
Machine summary. Not checked yet.Mandatory?
Such objections shall be submitted in the following three-column format: (i) the left column should contain a verbatim quote of each statement objected to (including page and line number); (ii) the middle column should set forth a concise legal objection (e.g., hearsay, lacks foundation, etc.) with a citation to the corresponding Federal Rule of Evidence or, where applicable, a case citation; and (iii) the right column should provide space for the Court’s ruling on the objection.
Summary: Evidentiary objections to direct testimony declarations must be submitted in a three-column format with specific content requirements.
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The spine of each binder shall indicate the volume number and the range of exhibit numbers included in the volume.
Summary: Trial exhibit binder spines must display the volume number and range of exhibit numbers.
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Defendant’s exhibit numbers shall not duplicate Plaintiff’s numbers.
Summary: Defendant exhibit numbers cannot duplicate plaintiff exhibit numbers.
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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, for example: “Ex. 1 - Smith Declaration.pdf” or “Ex. 105 - Letter Dated 1-5-20.pdf.”
Summary: Plaintiff and defendant exhibits must be stored in separate USB folders, with file names including the exhibit number and a brief description.
Machine summary. Not checked yet.Mandatory?
The Court does not permit exhibits to be “published” to the jurors before they are admitted into evidence. Once admitted, exhibits may be displayed electronically using the equipment and screens in the courtroom.
Summary: Exhibits may not be shown to jurors before being admitted into evidence; admitted exhibits may be displayed electronically.
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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: Exhibit copies must include official exhibit tags and be indexed with right-side tabs or dividers.
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These lodged depositions are for the Court’s use. The parties must use their own copies during trial.
Summary: Lodged depositions are for the court’s use only; parties must use their own copies during trial.
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Counsel must use the lectern. Counsel should not consume jury time by writing out words and drawing charts or diagrams. All such aids must be prepared in advance.
Summary: Counsel must use the lectern during trial; trial aids must be prepared in advance, and counsel may not write or draw charts during jury time.
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All such exhibits should be noted as admitted on the court and CRD’s copy of the exhibit list.
Summary: Admitted exhibits must be noted on the court’s and CRD’s copies of the exhibit list.
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counsel should list their email addresses along with their telephone numbers on all papers.
Summary: Counsel should include their email address and telephone number on all court papers.
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parties may print their own exhibit tags using Forms G-14A and G-14B on the “Court Forms” section of the court’s website.
Summary: Parties may print their own exhibit tags using Forms G-14A and G-14B from the court's website.
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When appropriate, the Court will establish and enforce time limits for all phases of trial, including opening statements, closing arguments, and the examination of witnesses.
Summary: The Court may establish and enforce time limits for opening statements, closing arguments, and witness examinations.
Document Filing Requirements33 rules
Machine summary. Not checked yet.Mandatory?
Please complete this worksheet jointly and file it with your Joint Rule 26(f) Report.
Summary: Parties must jointly complete the pretrial dates worksheet and file it with the Joint Rule 26(f) Report.
Document Type
Pretrial Dates Worksheet
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All discovery motions shall state with particularity what is requested, the basis for the request, whether discovery has been requested, and opposing counsel’s response to such request.
Summary: Discovery motions must specifically state the request, basis, prior discovery request status, and opposing counsel's response.
Document Type
Discovery Motion
Machine summary. Not checked yet.Mandatory?
a trial memorandum setting forth a factual summary of the government’s case, a statement of the charges and the elements of each charge, an estimate of the length of the government’s case in chief, including anticipated cross-examination, the names of witnesses the government intends to call, and a discussion of relevant legal and evidentiary issues as applied to the facts of the particular case.
Summary: Trial memoranda must include a factual summary, statement of charges and elements, case length estimate, witness names, and legal/evidentiary issues discussion.
Document Type
Trial Memorandum
Machine summary. Not checked yet.Mandatory?
which shall also be sent in Word format to the Chambers e-mail box;
Summary: Government counsel must send a Word-format electronic copy of the witness list to the Chambers email box.
Document Type
Witness List
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Defense counsel shall provide the CRD and the court reporter with the defense witness list and defense exhibit list in both electronic and paper formats.
Summary: Defense counsel must provide the defense witness list to the CRD and court reporter in both electronic and paper formats.
Document Type
Defense Witness List
Machine summary. Not checked yet.Mandatory?
Should government counsel wish to order transcripts, they shall provide agency authorization to the court reporter at the time the request is made.
Summary: Government counsel ordering transcripts must provide agency authorization to the court reporter when requesting.
Document Type
Transcript Request
Machine summary. Not checked yet.Mandatory?
The parties must submit JOINT jury instructions and a JOINT proposed verdict form. In order to produce these joint instructions, the parties shall meet and confer sufficiently in advance of the required submission date with the goal of agreeing on instructions and verdict forms. Where the parties cannot agree, disputed instructions shall be submitted at least one week before trial as follows: (1) JOINT jury instructions (those instructions agreed to by all parties) and (2) DISPUTED jury instructions (those propounded by a party to which another party objects).
Summary: Jury instructions and verdict forms must be joint; disputed instructions must be submitted with joint agreed instructions one week before trial.
Document Type
Jury Instructions
Machine summary. Not checked yet.Mandatory?
An index page shall accompany all jury instructions submitted to the Court. The index page shall indicate the following: a. The number of the instruction; b. A brief title of the instruction; c. The source of the instruction; d. The page number of the instruction.
Summary: All submitted jury instructions must be accompanied by an index page listing each instruction's number, title, source, and page number.
Document Type
Jury Instructions
Machine summary. Not checked yet.Mandatory?
On a separate page following each disputed jury instruction, the party opposing the instruction shall briefly state the basis for the objection, any authority in support thereof and, if applicable, an alternative instruction. On the following page, the party proposing the disputed instruction shall briefly state its response to the objection, and any authority in support of the instruction. Each requested jury instruction shall be numbered and set forth in full on a separate page, citing the authority or source of the requested instruction.
Summary: Disputed jury instructions must include objecting party's basis, authority, alternative, and proponent's response; each instruction on separate page, numbered, full text, cited.
Document Type
Jury Instructions
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Jury instructions should be modified as necessary to fit the facts of the case (e.g., inserting names of defendant(s) or witness(es) to whom instruction applies). Where language appears in brackets in the model instruction, counsel shall select the appropriate text and eliminate the inapplicable bracketed text.
Summary: Jury instructions must be modified to fit case facts; bracketed model text must be edited to remove inapplicable options.
Document Type
Jury Instructions
Machine summary. Not checked yet.Mandatory?
Counsel shall submit a joint proposed verdict form with the jury instructions.
Summary: Counsel must submit a joint proposed verdict form along with jury instructions.
Document Type
Verdict Form
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Accordingly, counsel must submit to the Chambers e-mail (MRA_chambers@cacd.uscourts.gov) a “clean” set of all instructions in Word format, containing only the text of each instruction, set forth in full on each page, with the caption “Instruction No. ____” (eliminating titles, supporting authority, indication of party proposing, etc.).
Summary: Jury instructions must contain only instruction text, full text on each page, caption “Instruction No. ____”, and no titles or supporting authority.
Document Type
Jury Instructions
Machine summary. Not checked yet.Mandatory?
Counsel should not offer a stipulation without having conferred with opposing counsel and having reached an agreement.
Summary: Counsel must confer with opposing counsel and reach agreement before offering any stipulation.
Document Type
Stipulation
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must propose a new date by Stipulation and Proposed Order.
Summary: Continuance requests must include a Stipulation and Proposed Order.
Document Type
Continuance Request
Machine summary. Not checked yet.Mandatory?
A “Notice of Unavailability” has no legal effect and should not be filed.
Summary: Notices of Unavailability are invalid and must not be filed.
Document Type
Notice Of Unavailability
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In addition to meeting the requirements of L.R. 15-1, counsel shall attach as an appendix to the moving papers a “redlined” version of the proposed amended pleading indicating all additions and deletions of material.
Summary: Motions to amend pleadings must include a redlined appendix showing all changes to the proposed amended pleading.
Document Type
Motion To Amend Pleading
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All motions to amend pleadings shall: (1) state the effect of the amendment and (2) identify the page and line number(s) and wording of any proposed change or addition of material.
Summary: Motions to amend pleadings must state the amendment's effect and identify all proposed changes by page, line, and wording.
Document Type
Motion To Amend Pleading
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If leave to amend is granted, the filing party must comply with L.R. 15-1 through L.R. 15-3 in filing the amended pleading.
Summary: Parties granted leave to amend must comply with Local Rules 15-1 through 15-3 when filing the amended pleading.
Document Type
Amended Pleading
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The proposed amended pleading shall be serially numbered to differentiate it from previously amended pleadings (e.g., “Second Amended Complaint” or “Third Amended Answer and Counterclaims”).
Summary: Proposed amended pleadings must be serially numbered to distinguish them from prior amended pleadings.
Document Type
Proposed Amended Pleading
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A party seeking such relief must strictly comply with the ex parte procedures under Local Rule 7-19.
Summary: Ex parte applications must strictly adhere to Local Rule 7-19 procedures.
Document Type
Ex Parte Application
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All discovery-related documents, including motions, must include the words “DISCOVERY MATTER” in the caption to ensure proper routing.
Summary: Discovery-related documents must display “DISCOVERY MATTER” in the caption for proper routing.
Document Type
Discovery Related Document
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The parties must use this template. A template for the Proposed FPTCO is available on Judge Ramírez Almadani’s webpage.
Summary: Parties must use the provided template for the Proposed Final Pretrial Conference Order.
Document Type
Proposed Final Pretrial Conference Order
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In specifying the surviving pleadings under section I, the parties are to state which claims or counterclaims have been dismissed or abandoned (e.g., “Plaintiff’s second cause of action for breach of fiduciary duty has been dismissed.”). Additionally, in multiple-party cases where not all claims or counterclaims will be prosecuted against all remaining parties on the opposing side, the parties are to specify to which party or parties each claim or counterclaim is directed.
Summary: Proposed Final Pretrial Conference Order must state dismissed/abandoned claims and specify parties for each claim in multi-party cases.
Document Type
Proposed Final Pretrial Conference Order
Machine summary. Not checked yet.Mandatory?
Witness lists must be in the format specified in L.R. 16-5 and include for each witness (i) a brief description of the testimony, (ii) the reasons the testimony is unique and not redundant, and (iii) a time estimate in hours for direct and cross-examination. The parties must use the template posted to Judge Ramírez Almadani’s webpage. Any Amended Witness List must be filed by 12:00 p.m. (noon) on the Friday before trial and emailed to MRA_Chambers@cacd.uscourts.gov in Microsoft Word format.
Summary: Witness lists must follow L.R. 16-5 format, use the judge’s template, and include required witness details; amended lists due noon Friday before trial in Word format emailed to Chambers.
Document Type
Witness List
Machine summary. Not checked yet.Mandatory?
The Joint Exhibit List must be in the format specified in L.R. 16-6 and shall include an additional column stating any objections to authenticity and/or admissibility and the reasons for the objections. The parties must use the template posted to Judge Ramírez Almadani’s webpage. Any Amended Joint Exhibit List must be filed by 12:00 p.m. (noon) on the Friday before trial and emailed to MRA_Chambers@cacd.uscourts.gov in Microsoft Word format.
Summary: Joint exhibit lists must follow L.R. 16-6 format, use the judge’s template, include objection column; amended lists due noon Friday before trial in Word format emailed to Chambers.
Document Type
Joint Exhibit List
Machine summary. Not checked yet.Mandatory?
(e) Index: The Proposed Instructions must have an index that includes the following for each instruction, as illustrated in the example below: o the number of the instruction; o the title of the instruction; o the source of the instruction and any relevant case citations; and o the page number of the instruction.
Summary: Proposed Jury Instructions must include an index with instruction number, title, source/citations, and page number.
Document Type
Jury Instructions
Machine summary. Not checked yet.Mandatory?
5. Joint Verdict Forms (Jury Trial Only). The parties shall make every effort to agree on a general or special verdict form before submitting proposals to the Court. If the parties are unable to agree on a verdict form, the parties shall file one document titled “Competing Verdict Forms” which shall include: (i) the parties’ respective proposed
Summary: If parties cannot agree on verdict forms, they must file a single document titled 'Competing Verdict Forms' with their respective proposals.
Document Type
Competing Verdict Forms
Machine summary. Not checked yet.Mandatory?
When ordered by the Court in a particular case, each party shall file declarations containing the direct testimony of each witness whom that party intends to call at trial.
Summary: Parties must file declarations of direct testimony for each witness when ordered by the court in bench trials.
Document Type
Declaration Of Direct Testimony
Machine summary. Not checked yet.Mandatory?
At the exhibit conference, the parties shall present the following materials to the CRD: 1. The three sets of binders described above, with one (1) original set of trial exhibits for the jury, and two (2) copies of trial exhibits for the Court.
Summary: Parties must present three sets of exhibit binders (1 original jury set, 2 court copies) to the CRD at the exhibit conference.
Document Type
Exhibit Binder
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If possible, all instructions should be taken from the Manual of Model Criminal Jury Instructions for the Ninth Circuit (West Publishing, current edition). Where no applicable Ninth Circuit model instruction is available, counsel should consult the instructions from O’Malley, Grenig & Lee current edition). Counsel may submit alternatives to the Ninth Circuit model jury instructions or O’Malley, Grenig & Lee instructions only if counsel has a reasoned argument that those instructions do not properly state the law or they are incomplete.
Summary: Jury instructions should use Ninth Circuit model or O’Malley instructions, with alternatives allowed only with a reasoned argument.
Document Type
Jury Instructions
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If the parties prefer an ADR procedure other than the one ordered by the Court (either Judge Ramírez Almadani or the prior judge if the case was reassigned), they shall file a Stipulation and Proposed Order. The parties’ request may not necessarily be granted.
Summary: Parties seeking an ADR procedure different from the court-ordered type must file a Stipulation and Proposed Order.
Document Type
Stipulation
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Whenever counsel expects to offer a group of answers to interrogatories or requests for admission extracted from one or more lengthy discovery responses, counsel should prepare a new document listing each question and answer and identifying the document from which it has been extracted.
Summary: Counsel should prepare a summary document listing each interrogatory or admission answer and its source when offering multiple such answers from lengthy discovery responses.
Document Type
Discovery Response Summary
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Counsel should have available for the Court and the witness extra copies of the deposition transcript for this purpose.
Summary: Counsel should have extra copies of deposition transcripts available for the Court and witness when using depositions for impeachment.
Document Type
Deposition Transcript
Filing & Service rules
Electronic Filing Rules
Counsel must comply with Central District electronic filing General Orders and Local Rules, unless this Order supersedes them.
Counsel must follow the Central District’s General Orders and Local Rules concerning electronic filing, unless superseded by this Order.
Machine summary. Not checked yet. · Criminal cases
Page 1 | A. MOTIONS
Filing Timing and Cure Windows
Government counsel must file a trial memorandum with specified content no later than 2 weeks before trial, and attempt to obtain defense counsel’s agreement on specified elements.
No later than two (2) weeks before trial, government counsel shall file the following two documents with the Court: a trial memorandum setting forth a factual summary of the government’s case, a statement of the charges and the elements of each charge, an estimate of the length of the government’s case in chief, including anticipated cross-examination, the names of witnesses the government intends to call, and a discussion of relevant legal and evidentiary issues as applied to the facts of the particular case. Government counsel shall attempt to obtain defense counsel’s agreement to the factual summary, statement of the charges, time estimate for cross-examination of the government’s witnesses, and legal and evidentiary issues.
Machine summary. Not checked yet. · Criminal cases
Page 3
Jury instructions must be submitted no later than one week (7 days) before trial.
No later than one week before trial, counsel shall submit both general and substantive jury instructions in the form described below.
Machine summary. Not checked yet. · Criminal cases
Page 5 | E. JURY INSTRUCTIONS, VERDICT FORMS & QUESTIONNAIRES, 1.
Parties requesting special court reporter services must notify the reporter at least 2 weeks before the hearing.
Any party requesting special court reporter services for any hearing (e.g., real time transmission, daily transcripts) shall notify the reporter at least two weeks before the hearing date.
Machine summary. Not checked yet. · Criminal cases
Page 5 | 14. Special Court Reporter Services
Proposed questions for prospective jurors must be filed at least one week before trial.
At least one week before trial, each counsel must file any proposed questions to be asked of prospective jurors.
Machine summary. Not checked yet. · Criminal cases
Page 7 | E. JURY INSTRUCTIONS, VERDICT FORMS & QUESTIONNAIRES
Written discovery and depositions must start early enough to allow time for motion practice on deficient responses before the discovery cut-off.
Thus, written discovery must be served, and depositions must begin sufficiently in advance of the discovery cut-off date to permit the propounding party enough time, if the party chooses, to challenge via motion practice any responses the party asserts are deficient.
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Page 5 | C. Discovery Cut-Off and Discovery Motions 1. Fact and Expert Discovery Cut-Offs
Discovery cut-off date is the deadline for all discovery and related motion hearings to be completed.
The cut-off date for discovery is not the date by which discovery requests must be served; it is the date by which all discovery, including all hearings on any related motions, must be completed.
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Page 5 | C. Discovery Cut-Off and Discovery Motions 1. Fact and Expert Discovery Cut-Offs
Oppositions to ex parte applications must be filed within 24 hours of the application.
Any opposition to an ex parte application must be filed within 24 hours.
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Page 6 | D. Non-Discovery and Daubert Motions Deadline 2. Ex Parte Applications
Motions challenging discovery responses must be filed early enough to obtain responses by the discovery cut-off date if granted.
Any motion challenging the adequacy of discovery responses must be filed, served, and calendared before the assigned magistrate judge 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 6 | C. Discovery Cut-Off and Discovery Motions 3. Discovery Motions
Replies to Rule 56 summary judgment motions must be filed and served no later than 21 calendar days before the hearing date.
Replies must be filed and served not later than twenty-one (21) days before the hearing date.
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Page 7 | II. SCHEDULE OF PRETRIAL AND TRIAL DATES D. Non-Discovery and Daubert Motions Deadline 4. Rule 56 Motions
Daubert motions must be noticed for hearing at least 8 weeks (56 calendar days) before the Final Pretrial Conference (FPTC).
Daubert motions must be noticed to be heard generally at least eight (8) weeks before the FPTC.
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Page 7 | II. SCHEDULE OF PRETRIAL AND TRIAL DATES D. Non-Discovery and Daubert Motions Deadline 5. Daubert Motions
Non-discovery motions must be filed at least 28 calendar days before the pretrial schedule cut-off deadline per L.R. 6-1.
All non-discovery motions must be filed at least 28 days before the deadline in accordance with the requirements of L.R. 6-1.
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Page 7 | II. SCHEDULE OF PRETRIAL AND TRIAL DATES A. Schedule and Deadlines
Oppositions to Rule 56 summary judgment motions must be filed and served no later than 28 calendar days before the hearing date.
Oppositions must be filed and served not later than twenty-eight (28) days before the hearing date.
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Page 7 | II. SCHEDULE OF PRETRIAL AND TRIAL DATES D. Non-Discovery and Daubert Motions Deadline 4. Rule 56 Motions
Rule 56 summary judgment motions must be noticed, served, and filed no later than 42 calendar days before the hearing date.
This Court requires that motions for summary judgment under Rule 56 be noticed, served, and filed not later than forty-two (42) days before the hearing date.
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Page 7 | II. SCHEDULE OF PRETRIAL AND TRIAL DATES D. Non-Discovery and Daubert Motions Deadline 4. Rule 56 Motions
Non-discovery motions must be noticed for hearing on or before the cut-off date in the pretrial schedule.
All non-discovery motions must be noticed to be heard on or before their respective cut-off dates listed in the pretrial schedule.
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Page 7 | II. SCHEDULE OF PRETRIAL AND TRIAL DATES A. Schedule and Deadlines
Parties must report a settlement to the Court immediately upon reaching it, per L.R. 16-15.7, with failure to do so resulting in potential sanctions.
If a settlement is reached, it shall be reported immediately to the Court as required by L.R. 16-15.7. Failure to do so within a reasonable time may result in sanctions.
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Page 8 | E. Settlement Proceedings/Alternative Dispute Resolution (ADR) Deadline
Parties must file a joint settlement report within 7 calendar days after the settlement conference.
the parties shall file a joint report regarding the outcome of settlement negotiations, the likelihood of possible further negotiations, and any assistance the Court may provide concerning settlement negotiations within seven (7) days after the settlement conference.
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Page 8 | E. Settlement Proceedings/Alternative Dispute Resolution (ADR) Deadline
Parties in jury trial cases must notify the Court of any settlement by the Monday preceding the trial date.
In all cases set for jury trial, the parties must notify the Court no later than the Monday preceding the trial date, of any settlement, so that the necessary arrangements can be made to bring in a different case for trial or to notify the members of the public who would otherwise be reporting for jury duty that their services are not needed that date.
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Page 8 | E. Settlement Proceedings/Alternative Dispute Resolution (ADR) Deadline
First round of trial filings must be served and filed at least 28 calendar days before the Final Pretrial Conference (FPTC).
At least twenty-eight (28) days before the FPTC Counsel must serve and file with the Court the first round of trial filings: (1) Motions in Limine (2) Memoranda of Contentions of Fact and Law (3) Witness Lists (4) Joint Exhibit List (5) Joint Status Report Regarding Settlement (6) Proposed Findings of Fact and Conclusions of Law pursuant to L.R. 52 (for bench trials only) (7) Declarations containing Direct Testimony, if ordered (for bench trials only)
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Page 9 | A. Schedule and Deadlines.
Second round of trial filings must be served and filed at least 14 calendar days before the FPTC.
At least 14 days before the FPTC Counsel must serve and file with the Court the second round of trial filings: (1) Joint Proposed Final Pretrial Conference Order (2) Joint/Agreed Upon Proposed Jury Instructions (jury trial only) (3) Disputed Proposed Jury Instructions (jury trial only) (4) Joint Proposed Verdict Forms (jury trial only) (5) Joint Proposed Statement of the Case (jury trial only) (6) Proposed Voir Dire Questions, if any (jury trial only) (7) Evidentiary Objections to Declarations of Direct Testimony (bench trial only)
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Page 9 | A. Schedule and Deadlines.
Oppositions to Motions in Limine must be served and filed at least 21 calendar days before the FPTC.
At least twenty-one (21) days before the FPTC Counsel must serve and file with the Court Oppositions to Motions in Limine.
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Page 9 | A. Schedule and Deadlines.
Proposed Final Pretrial Conference Order must be filed at least 14 calendar 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 10 | A. Schedule and Deadlines.
All pretrial documents and amended versions must be filed and emailed to Chambers on their scheduled due date.
All pretrial documents listed above, including any amended documents, shall be filed and emailed to Chambers the day they are due as set forth in the schedule.
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Page 11 | A. Filing Pretrial Documents
Amended joint exhibit lists must be filed by noon on the Friday before trial.
Any Amended Joint Exhibit List must be filed by 12:00 p.m. (noon) on the Friday before trial
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Page 12 | B.3. Joint Exhibit List
Amended witness lists must be filed by noon on the Friday before trial.
Any Amended Witness List must be filed by 12:00 p.m. (noon) on the Friday before trial
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Page 12 | B.2. Witness Lists
Parties must file Joint Agreed Upon and Disputed Jury Instructions 14 calendar days before the Final Pretrial Conference (FPTC).
Fourteen (14) days before FPTC: The parties shall file their (i) Joint Agreed Upon Proposed Jury Instructions and their (ii) Disputed Jury Instructions.
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Page 13 | II. SCHEDULE OF PRETRIAL AND TRIAL DATES A. Schedule and Deadlines
Parties must file a Joint Statement of the Case before the Final Pretrial Conference (FPTC) in jury trials.
The parties must file a Joint Statement of the Case before the FPTC for the Court to read to the prospective jurors before commencement of voir dire.
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Page 15 | Joint Statement of the Case (Jury Trial Only)
Evidentiary objections to direct testimony declarations must be filed at least 14 days before the FPTC if declarations are filed.
If such declarations are filed, each party shall file any evidentiary objections to the declarations submitted by any other party at least fourteen (14) days before the FPTC.
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Page 16 | Declarations of Direct Testimony (Bench Trial Only)
Parties must submit a USB flash drive with PDF versions of all exhibits to the judge's courtesy box by 3:00 PM on the Friday before trial starts.
In addition to the three (3) sets of binders above, the parties must also submit to the court a USB flash drive containing .pdf versions of all exhibits. The USB flash drive must be delivered to the judge’s courtesy box (located outside of Courtroom 9B on the 9th floor of the federal courthouse in Santa Ana) by 3:00 p.m. on the Friday before the start of trial.
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Page 17 | 2. Exhibit Copies
Parties must meet and confer at least 10 days before trial to stipulate to exhibit foundations, best evidence rule waivers, and initial exhibit admissions.
The parties must meet and confer at least ten (10) days before trial to stipulate as much as possible to foundation, waiver of the best evidence rule, and exhibits that may be received into evidence at the start of the trial.
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Page 17 | 3. Publishing Exhibits
Parties requesting special court reporter services (e.g., real time, daily transcripts) must notify the court reporter 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 the court reporter at least fourteen (14) days before the hearing date.
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Page 18 | E. Court Reporter
Defense counsel are preferred to deliver defense exhibits to the CRD on the first day of trial; delivery is required only if exhibits were previously provided to the government.
The Court prefers that defense counsel deliver defense exhibits to the CRD on the first day of trial, but counsel are not required to do so unless these exhibits have previously been provided to the government.
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Proposed voir dire questions may be filed at least 14 days before the FPTC, but filing is optional.
The parties may, but are not required to, file any proposed case-specific voir dire questions for the Court’s consideration at least fourteen (14) days before the FPTC.
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Page 15 | Voir Dire (Jury Trial Only)
Service and Proof of Service Rules
Government counsel must disclose to defense counsel whether electronic surveillance evidence or informant testimony exists.
Government counsel shall also disclose to defense counsel the existence or non-existence of (1) evidence obtained by electronic surveillance and (2) testimony by a government informant.
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Page 2 | C. DISCOVERY & NOTICE
Government counsel must immediately produce Brady evidence to defense counsel upon discovery.
On government counsel’s discovery of any evidence within the scope of Brady v. Maryland, 373 U.S. 83 (1963), and its progeny, such evidence shall be produced forthwith to defense counsel.
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Page 2 | C. DISCOVERY & NOTICE
Counsel must promptly comply with discovery and notice requirements under Federal Rules of Criminal Procedure 12, 12.1, 12.2, 12.3, 12.4, 15, and 16.
Counsel shall comply promptly with discovery and notice pursuant to Rules 12, 12.1, 12.2, 12.3, 12.4, 15, and 16 of the Federal Rules of Criminal Procedure.
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Page 2 | C. DISCOVERY & NOTICE
Exhibits must be provided to the Court and opposing counsel before being shown to a witness.
No document shall be placed before a witness unless a copy has been provided to the Court and opposing counsel.
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Page 8 | F. INSTRUCTIONS GOVERNING PROCEDURE DURING TRIAL
Plaintiff’s counsel or pro se plaintiff must immediately serve this order on all parties; removing defendants in state-removed cases must serve all other parties.
NOTICE OF THIS ORDER: Plaintiff’s counsel or plaintiff (if appearing on his or her own behalf) shall immediately serve this Order on all parties, including any new parties to the action. If this case was removed from state court, the removing defendant(s) shall serve this Order on all other parties.
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Page 1 | NOTICE OF THIS ORDER:
Parties must exchange proposed general and special jury instructions at least 35 calendar days before the Final Pretrial Conference (FPTC).
At least thirty-five (35) days before the FPTC: The parties shall exchange proposed general and special jury instructions.
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Page 13 | II. SCHEDULE OF PRETRIAL AND TRIAL DATES A. Schedule and Deadlines
Parties must exchange objections to jury instructions 28 calendar days before the Final Pretrial Conference (FPTC).
Twenty-eight (28) days before the FPTC: The parties shall exchange any objections to the instructions.
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Page 13 | II. SCHEDULE OF PRETRIAL AND TRIAL DATES A. Schedule and Deadlines
Counsel must email a list of unusual words/phrases to the court reporter 7 days before trial starts.
At least seven (7) days before the commencement of trial, counsel for the parties shall provide the court reporter with a list of unusual words, phrases, and spellings that may come up during trial. This information should be emailed to Court Reporter Services at ReportersCACD@cacd.uscourts.gov.
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Page 18 | E. Court Reporter
Counsel must show new exhibits to opposing counsel before the court session where the exhibit is first mentioned.
Counsel must show a new exhibit to opposing counsel before the court session in which it is mentioned.
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Page 21
Copies of summary documents listing interrogatory or admission answers must be provided to the Court and opposing party.
Copies of this new document must be provided to the Court and the opposing party.
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Page 22 | I. Using Numerous Answers to Interrogatories and Requests for Admission
Courtesy Copy Requirements
Government counsel must provide 3 paper copies of the exhibit list (in the attached sample form) to the CRD at the Exhibit Conference.
b. Three copies of the government’s exhibit list in the form specified in the attached sample, which shall also be sent in Word format to the Chambers e-mail box;
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Government counsel must provide 3 paper copies of the witness list to the CRD at the Exhibit Conference.
a. Three copies of the government’s witness list, which shall also be sent in Word format to the Chambers e-mail box;
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The Court does not accept chambers copies of motion papers or exhibits except for trial filings or when directed otherwise; if requested, parties must deliver a formatted copy to the specified chambers copy box by the Court-set deadline.
With the exception of trial filings (see Section III of this Order) and unless otherwise directed, the Court does not accept chambers copies of any motion papers or exhibits. If the Court requests a copy of any filing, parties must deliver the mandatory copy by the Court-set deadline to the Court’s chambers copy box located outside of Courtroom 9B on the 9th floor of the federal courthouse in Santa Ana. Mandatory chambers copies must be prominently labeled MANDATORY CHAMBERS COPY on the face page and include the NEF as the last page of the document. Short filings should be three-hole punched and fastened by a staple in a three-ring binder with an index and with each unstapled item of evidence or exhibit separated by a tab divider on the right side. Binders must have both a cover sheet and a spine label that includes the case name and case number.
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Page 7 | II. SCHEDULE OF PRETRIAL AND TRIAL DATES D. Non-Discovery and Daubert Motions Deadline 6. Mandatory Chamber’s Copies
Except for exempt documents, counsel must provide mandatory Chambers copies of pretrial documents, delivered to the specified copy box in required format.
Except for motions in limine and oppositions, the Joint Status Report Regarding Settlement, and Declarations containing direct testimony, counsel shall (2) provide the Court with Mandatory Chambers copies of the same documents. The latter shall be delivered to Judge Ramírez Almadani’s chambers copy box located outside of Courtroom 9B on the 9th floor of the ready” state, meaning they must be three-hole punched on the left side, without blue-backs, and clipped, not stapled, only in the top left corner.
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Page 11 | A. Filing Pretrial Documents
Sealing & Redaction Procedures
Counsel must comply with Court website instructions and section one Electronic Filing and Mandatory Chambers Copies instructions for filings under seal.
Counsel shall comply with the instructions posted on the Court’s website at the “Judges’ Procedures and Schedules” link and the instructions provided under section one: Electronic Filing and Mandatory Chambers Copies.
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Page 2 | B. FILINGS UNDER SEAL
Pre-Motion Conference Requirements
Counsel must meet and confer with opposing counsel to resolve issues before filing any motion.
Counsel must meet and confer with opposing counsel and attempt to resolve the issue before filing a motion.
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Page 1 | A. MOTIONS
Pretrial motions and motions in limine must be filed 28 days before pretrial conference, with opposition 7 days after filing, reply 7 days after opposition (motions in limine reply require leave), and hearing by pretrial conference.
Pretrial motions, including motions in limine, shall be filed no later than four weeks before the Pretrial Conference. Opposition (or notice of non-opposition) shall be filed no later than one week after the filing of the motion. A reply, if any, shall be filed no later than one week after the filing of the opposition. Replies relating to motions in limine are not accepted absent leave of court. Pretrial motions and motions in limine shall be set for hearing no later than the date and time of the Pretrial Conference.
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Page 1 | A. MOTIONS
Discovery motions filed without prior meet and confer with opposing counsel may be denied a hearing.
Motions made without prior consultation with opposing counsel may not be heard.
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Page 2 | A. MOTIONS
Counsel must contact the Courtroom Deputy for a hearing date before filing non-pretrial/post-trial motions.
For all other pre-trial or post-trial motions, counsel must contact the Courtroom Deputy (“CRD”) to obtain an available hearing date and time before filing a motion.
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Page 2 | A. MOTIONS
Counsel must meet and confer to resolve discovery disputes before filing a discovery motion.
Counsel shall meet and confer with opposing counsel to informally resolve discovery disputes prior to filing a motion for discovery.
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Page 2 | A. MOTIONS
Hearings on pretrial motions are held Thursdays at 10:00 a.m. unless the Court sets a different time.
Hearings on such motions are held on Thursdays at 10:00 a.m., unless otherwise set by the Court.
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Page 2 | A. MOTIONS
Parties must meet and confer to resolve discovery disputes before filing a discovery motion.
The parties are expected to meet and confer to attempt to resolve discovery disputes before filing a discovery motion and must use their best effort to resolve all discovery disputes in a courteous, reasonable, and professional manner.
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Page 6 | C. Discovery Cut-Off and Discovery Motions 3. Discovery Motions
Parties must meet and confer at least 7 days before filing non-discovery or Daubert motions.
The parties are required under L.R. 7-3 to meet and confer to attempt to resolve disputes at least seven (7) days prior to filing a motion.
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Page 6 | D. Non-Discovery and Daubert Motions Deadline 1. Meet and Confer Requirement
Replies to ex parte applications are not permitted without court leave.
A reply may not be filed absent leave of the Court.
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Page 6 | D. Non-Discovery and Daubert Motions Deadline 2. Ex Parte Applications
Ex parte applications are decided on the papers without a hearing unless the court orders otherwise.
All ex parte applications shall be decided on the papers without a hearing unless the Court orders otherwise.
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Page 6 | D. Non-Discovery and Daubert Motions Deadline 2. Ex Parte Applications
Parties must meet and confer before filing a motion in limine to attempt to resolve the dispute without filing.
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 12 | B.1. Motions in Limine
Parties must attempt to agree on jury instructions before submitting proposals to the Court.
The parties shall make every effort to agree upon jury instructions before submitting proposals to the Court.
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Page 12 | B.4. Jury Instructions
Motions may be denied if the moving party fails to meet the meet-and-confer requirement.
The Court may deny motions where the moving party has not complied with this requirement.
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Page 6 | D. Non-Discovery and Daubert Motions Deadline 1. Meet and Confer Requirement
Counsel seeking to hear a motion earlier than the Pretrial Conference should meet and confer to agree on an earlier briefing schedule.
If counsel believe that a motion should be heard earlier than the Pretrial Conference, they should meet and confer and agree upon an earlier briefing schedule.
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Page 2 | A. MOTIONS
Counsel should obtain opposing counsel's agreement or position before filing ex parte applications, which are disfavored.
Ex parte applications are disfavored. Counsel should obtain the agreement (or at least the position) of opposing counsel before filing such an application.
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Page 2 | A. MOTIONS
Ex parte applications are restricted to extraordinary relief and are generally disfavored.
Counsel are reminded that ex parte applications are solely for extraordinary relief and generally disfavored.
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Page 6 | D. Non-Discovery and Daubert Motions Deadline 2. Ex Parte Applications
Counsel must review the assigned magistrate judge’s procedures and schedules to schedule discovery matters.
Counsel are directed to review the magistrate judge’s procedures and schedules on the District’s website to schedule discovery matters for hearing.
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Page 6 | C. Discovery Cut-Off and Discovery Motions 3. Discovery Motions
All discovery motions are assigned to the case's assigned magistrate judge.
Discovery motions are handled by the magistrate judge assigned to the case.
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Page 6 | C. Discovery Cut-Off and Discovery Motions 3. Discovery Motions
Parties must check the court’s webpage for additional motion requirements.
The parties shall consult the Court’s webpage for additional motions requirements.
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Page 6 | D. Non-Discovery and Daubert Motions Deadline 1. Meet and Confer Requirement
Adjournment & Extension Requirements
The pretrial schedule may only be modified for good cause and with the judge's consent.
Once issued, this “schedule may be modified only for good cause and with the judge’s consent.” Fed. R. Civ. P. 16(b)(4).
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Page 1 | Final Pretrial Conference Dates
Counsel must notify chambers of calendar conflicts at least 3 days before scheduled appearances and propose new dates via Stipulation and Proposed Order.
(MRA_Chambers@cacd.uscourts.gov) as soon as possible and not later than three (3) days before the scheduled appearance. Counsel should attempt to agree on a new date to accommodate the calendar conflict and must propose a new date by Stipulation and Proposed Order. A “Notice of Unavailability” has no legal effect and should not be filed.
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Page 3 | C. Counsel Calendar Conflicts
Continuance requests for pretrial/trial dates must be via motion/stipulation/application with a serially numbered title, supporting declaration showing good cause and due diligence, and disclosure of prior continuances.
Any request for continuance of pretrial and/or trial dates shall be by motion, stipulation, or application, and shall be supported by a declaration setting forth the reasons for the requested relief. The title of the request shall be serially numbered to differentiate it from previous requests (e.g., Second Stipulation to Continue Pretrial and Trial Dates). The declaration must contain a detailed factual showing of good cause and due diligence demonstrating the necessity for the continuance and a description of the parties’ efforts taken to advance the litigation. This showing should 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 fact that the case was recently reassigned to Judge Ramírez Almadani is also insufficient. The declaration should include whether any previous requests for continuances have been made and whether the Court granted or denied these requests. Stipulations extending dates set by the Court are not effective unless the Court approves them, and without compelling factual support and a showing of due diligence, the Court will deny stipulations continuing dates set by the Court.
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Page 4 | II.A. Schedule and Deadlines
Final Pretrial Conference and trial dates will not be rescheduled solely due to incomplete expert discovery.
The Final Pretrial Conference (“FPTC”) and trial dates will not be continued merely because expert discovery has not been completed.
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Page 5 | C. Discovery Cut-Off and Discovery Motions 2. Expert Disclosures
Chambers Communication Rules
Counsel must submit jury instructions to the Chambers email address MRA_chambers@cacd.uscourts.gov.
Accordingly, counsel must submit to the Chambers e-mail (MRA_chambers@cacd.uscourts.gov) a “clean” set of all instructions in Word format, containing only the text of each instruction, set forth in full on each page, with the caption “Instruction No. ____” (eliminating titles, supporting authority, indication of party proposing, etc.).
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Page 7 | E. JURY INSTRUCTIONS, VERDICT FORMS & QUESTIONNAIRES
Counsel may only contact the CRD for appropriate inquiries, not for status updates or continuances.
Counsel may contact the CRD with appropriate inquiries. Contacting the CRD to inquire about the status of a ruling or continue a proceeding is not appropriate.
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Page 3 | D. Communications with Chambers
Counsel must copy all parties on all emails sent to the CRD.
Counsel must copy all parties on any such email.
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Page 3 | D. Communications with Chambers
Counsel and parties are prohibited from contacting the Court or Chambers staff by telephone or improper ex parte means.
Neither counsel nor a party shall initiate contact with the Court or its Chambers staff by telephone, or by any other improper ex parte means.
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Page 3 | D. Communications with Chambers
Parties disagreeing on the applicable pretrial schedule must contact the CRD immediately.
If the parties disagree as to the applicable pretrial schedule, they must contact the CRD immediately for direction.
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Page 4 | II.A. Schedule and Deadlines
Moving parties in Rule 56 summary judgment motions must email a copy of the Response to Statements of Genuine Disputes of Material Fact to chambers in Microsoft Word format.
the moving party must email a copy of the Response to Statements of Genuine Disputes of Material Fact to MRA_Chambers@cacd.uscourts.gov in Microsoft Word format.
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Page 7 | II. SCHEDULE OF PRETRIAL AND TRIAL DATES D. Non-Discovery and Daubert Motions Deadline 4. Rule 56 Motions
Proposed Final Pretrial Conference Order must be emailed to Chambers at least 14 calendar 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 10 | A. Schedule and Deadlines.
Parties must email the CRD with mutually agreeable trial dates no later than 4:00 p.m. on the Thursday before the FPTC.
The parties shall email the CRD with their mutually agreeable trial dates no later than 4:00 p.m. on the Thursday before the FPTC.
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Page 10 | A. Schedule and Deadlines.
Except for specified exempt documents, pretrial documents must be emailed to Chambers in Microsoft Word format at the provided email address.
Except for motions in limine and oppositions, the Joint Status Report Regarding Settlement, and Declarations containing direct testimony, counsel shall (1) email all of the above, including any amended documents, in Microsoft Word format to MRA_Chambers@cacd.uscourts.gov
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Page 11 | A. Filing Pretrial Documents
Preferred communication method with the CRD is email at MRA_Chambers@cacd.uscourts.gov.
The preferred method of communication with the CRD is by email at MRA_Chambers@cacd.uscourts.gov.
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Page 3 | D. Communications with Chambers
Junior Lawyer Participation Incentives
Lawyers with 5 or fewer years of experience are encouraged to fully participate in court proceedings, including arguing motions and examining witnesses.
Believing that lawyers with less experience who are typically five or fewer years out of law school need more opportunities for appearances than they usually receive, the Court encourages lead trial counsel to permit junior counsel to fully participate in Court proceedings, including arguing motions and examining witnesses.
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Page 2 | B. Presence of Lead Trial Counsel.