Central District of California Document Filing Requirements

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint rule 26f report

The plaintiff must draft the Report unless the plaintiff is pro se or the parties agree otherwise, and the parties must submit and sign one joint report.

The Report shall be drafted by the plaintiff (unless plaintiff is a pro se litigant or the parties agree otherwise) but shall be submitted and signed jointly. “Jointly” means a single report, regardless of how many separately represented parties exist in the case.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint rule 26f report

The Report must identify the Scheduling Conference date on its caption page and list specified case-event dates under the title.

The Joint Rule 26(f) Report shall specify the date of the Mandatory Scheduling Conference on the caption page. Under the title, it shall list the dates of the (1) Original Complaint; (2) Removal (if removed); (3) Responsive Pleading; and (4) Trial (proposed).

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint rule 26f report

The Report must address matters specified in Federal Rule of Civil Procedure 26(f) and Local Rule 26, as well as the additional listed matters.

The Joint Rule 26(f) Report shall address the matters set forth in Fed. R. Civ. P. 26(f) and Local Rule 26, some of which are enumerated below, and shall also contain the following:

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint rule 26f report

The Report must address the likelihood of specified procedural motions and describe issues or claims that may be decided on a motion to dismiss or summary judgment.

7. Motions. a. Procedural Motions. A statement of the likelihood of motions to add other parties or claims, file amended pleadings, transfer venue, challenge the Court’s jurisdiction, etc. b. Dispositive Motions. A description of the issues or claims that any party believes may be determined by motion to dismiss or motion for summary judgment.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint rule 26f report

The Report must include a detailed Rule 26(f) discovery plan addressing specified disclosure, scope, phasing, limitation, and court-order issues; vague general statements are unacceptable.

(b) Discovery Plan. A detailed discovery plan, as contemplated by Fed. R. Civ. P. 26(f). State what, if any, changes in the disclosures under Fed. R. Civ. P. 26(a) should be made, the subjects on which discovery may be needed, whether discovery should be conducted in phases or otherwise be limited, whether applicable limitations should be changed or other limitations imposed, and whether the Court should enter other orders. A statement that discovery will be conducted as to all claims and defenses, or other vague description is not acceptable.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint rule 26f report

The Report must propose a discovery cutoff date covering completion of all fact discovery and resolution of all discovery motions.

(c) Discovery Cutoff. A proposed discovery cut-off date governing the completion of all fact discovery, including resolution of all discovery motions.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint rule 26 f report

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

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.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Joint rule 26 f report

The parties must complete the worksheet jointly and file it with the Joint Rule 26(f) Report.

Please complete this worksheet jointly and file it with your Joint Rule 26(f) Report.

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Applies to

Answer

An answer filed in state court must be refiled in this Court as a supplement to the Notice of Removal.

Any answers filed in state court must be refiled in this Court as a supplement to the Notice of Removal.

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Applies to

Motion or request for determination

Must include

proposed order

A party filing or opposing a motion or seeking a determination must serve and lodge a proposed order stating the requested relief, rationale, and appropriate citations.

Each party filing or opposing a motion or seeking the determination of any matter shall serve and lodge a proposed order setting forth the relief or action sought and a brief statement of the rationale for the decision with appropriate citations.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Filing

Must include

ai disclosure

A party using generative AI to generate any portion of a filing must attach a separate declaration disclosing the use and certifying review, accuracy, and Rule 11 compliance.

Any party who uses generative artificial intelligence (such as ChatGPT, Harvey, CoCounsel, or Google Bard) to generate any portion of a brief, pleading, or other filing must attach to the filing a separate 11 declaration disclosing the use of artificial intelligence and certifying 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.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Filed or lodged document

Declarations, exhibits, and other attachments must be filed as separately docketed attachments to the main entry, each with a description.

If a filed or lodged document has declarations, exhibits, or other attachments, each of these must be filed as a separately docketed attachment to the main docket entry with a description of the attachment (e.g., Dkt. 29-1 Smith Declaration).

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Motion to amend

Motions to amend pleadings must state the amendment's effect, be serially numbered, and identify the page, line, and wording of each proposed change or addition.

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; and (3) state the page and line number(s) and wording of any proposed change or addition of material.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Motion to amend

The proposed amended pleading must be a separate document from the motion, and its redlined version must be an appendix to the moving papers.

Counsel shall electronically file a “Notice of Lodging” attaching the proposed amended pleading as a document separate from the motion, as well as a “redlined” version of the proposed amended pleading identifying all additions and deletions of material as an appendix to the moving papers.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Default judgment motion

A plaintiff seeking fees and costs with default judgment must include a properly supported request in the default-judgment motion; later fee motions will be struck absent good cause if omitted.

A plaintiff who moves for default judgment and wishes to seek attorney’s fees and costs must include in the motion a properly supported request for attorney’s fees and costs together with the motion for default judgment. Failure to do so will result in the striking of any subsequent motion for attorney’s fees and costs absent a showing of good cause.

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Applies to

Attorney fee motion

An attorney-fee motion must include documentation of the billed hours sought for recovery.

A motion for attorney’s fees must be supported by documentation of the billed hours for which the movant seeks to recover ===== PAGE 12 ===== fees.

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Applies to

Attorney fee motion

For a motion seeking more than $50,000 in fees, the movant must email the CRD an Excel spreadsheet documenting the hours sought, in the example’s format.

For any motion requesting more than $50,000 in fees, the movant shall additionally provide by email to the CRD an Excel spreadsheet documenting the hours for which the movant seeks recovery, using the format in the following example:

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Summary judgment motion

Parties filing or opposing summary-judgment motions must comply with Rule 56, Local Rule 56, and the Court’s Standing Order for Civil Cases.

When filing or opposing a motion for summary judgment, a party must comply with Fed. R. Civ. P. 56, Local Rule 56, and the Court’s Standing Order for Civil Cases.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint brief

The Joint Brief should include a table of contents, table of authorities, statement of facts, and issue-organized arguments with each moving-party argument immediately followed by the opposing party’s supported response; an introduction is optional.

(b) Content and Organization of Joint Brief. The Joint Brief should contain the following: (1) a table of contents; (2) a table of authorities; (3) an optional brief introduction section stated jointly or, if stated separately by each party, stated under an appropriate subheading identifying the party (e.g., “ACME Co.’s Introduction” or “Defendant’s Introduction”); (4) a statement of facts section stated jointly or, if stated separately by each party, stated under an appropriate subheading identifying the party (e.g., “ACME Co.’s Statement of Facts” or “Defendant’s Statement of Facts”); (5) an analysis or argument section that sets forth the arguments organized by issue that present the parties’ competing positions on an issue-by-issue basis. For each issue, the moving party shall present legal argument, citation to authority where applicable, and citation to the Joint Appendix of Facts, see below, followed immediately by the opposing party’s response that similarly must be supported by legal argument, citation to authority, and citation to the Joint Appendix of Facts.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint brief

The Joint Brief must be accompanied by one table-form Joint Appendix of Facts listing undisputed and disputed facts.

The Joint Brief shall be accompanied by a single statement of undisputed and disputed facts contained in a JAF presented in a table.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint appendix of evidence

The JAE must include a table of contents.

The JAE shall include a table of contents.

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Applies to

Joint appendix of evidence

If the JAE requires multiple PDFs, each file must be titled by part and exhibit series.

In the event multiple PDFs are necessary to file the JAE, each file shall be titled by part and exhibit series (e.g., JAE Part 1, Exhibits 1–50).

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint appendix of evidence

Each JAE exhibit must be bookmarked with its exhibit number and a brief description.

Each exhibit within the JAE must be bookmarked; the bookmark should include the exhibit number and a brief description of the exhibit (e.g., Ex. 1 – Jones Depo. Excerpts).

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Applies to

Memorandum of points and authorities

Evidence should be included only in the JAE and not attached to a memorandum of points and authorities.

No evidence should be attached to a memorandum of points and authorities or included anywhere other than in the JAE.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint rule 26 f report

The Court will reject a Joint Rule 26(f) Report filed without a fully completed Exhibit A, and the parties may be subject to sanctions.

A Joint Rule 26(f) Report that is filed without a fully completed Exhibit A will be rejected by the Court and may subject the parties to sanctions.

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Applies to

Client delivery

Counsel must deliver copies of this Order, the Court’s trial order, and the Scheduling Order to their respective clients.

Counsel are ordered to deliver to their respective clients a copy of this Order, the Court’s trial order, and the Scheduling Order.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Rule 26 f report

The parties must include a detailed discovery plan addressing the specified Rule 26(f) topics and any other Rule 16(b) or 16(c) issues.

The parties must set forth a detailed discovery plan that discusses all the Federal Rule of Civil Procedure 26(f)(3)(A)-(F) topics, including topics related to initial disclosures, the anticipated subjects of discovery, the time needed for discovery, issues related to electronically stored information (“ESI”), issues related to privileged materials, whether changes to limitations on discovery should be made, issues related to protective orders, and any other Rule 16(b) or 16(c) issues.

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Civil cases

Applies to

Pretrial documents

Counsel must lodge the specified memoranda and proposed final pretrial conference order in accordance with the cited local rules.

Counsel shall lodge carefully prepared Memoranda of Contentions of Fact and Law (which may also serve as the trial briefs) and a (Proposed) Final Pretrial Conference Order in accordance with the provisions of Local Rules 16-4 and 16-7.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Proposed final pretrial conference order

The proposed final pretrial conference order must conform to the form in Appendix A to the Local Rules.

The form of the (Proposed) Final Pretrial Conference Order shall be in conformity with the form set forth in Appendix A to the Local Rules.

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Civil cases

Applies to

Motion in limine

Each side may file no more than four noncompound motions in limine, each addressing one item or witness or one category when common grounds apply.

Each side is limited to four motions in limine and each motion shall not be compound; i.e., each motion shall address only one item of evidence or witness or, if common grounds for exclusion or admission apply to multiple items of evidence or witnesses, only one category of evidence or witnesses.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion in limine

A party must request leave of court to file more than four motions in limine.

A party seeking to file more than four motions in limine must request leave of court to do so.

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Civil cases

Applies to

Witness list

The witness list must present witnesses in expected testimony order and include, to the extent possible, estimated examination time and a brief testimony summary for each witness.

Counsel are to submit the names of the witnesses in the order that they are expected to testify, and provide, to the extent possible, an accurate estimate of the time needed for each witness for direct, cross, redirect and re- cross. Counsel will also provide a brief summary of each witness’ testimony.

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Civil cases

Applies to

Joint witness list

The parties must prepare a joint witness list in compliance with the provided example and Local Rule 16-5.

A joint witness list will be prepared in compliance with the example below and Local Rule 16-5.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Jury instructions

The parties must meet and confer sufficiently in advance of the filing deadline to prepare joint jury instructions.

The parties are to meet and confer sufficiently in advance of the required filing deadline to prepare joint jury instructions.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Jury instructions

If the parties cannot agree, counsel must file jury instructions in the specified order: agreed instructions, plaintiff’s opposed proposals, then defendant’s opposed proposals.

In the event that agreement cannot be reached, counsel will file instructions in the 3 following format: (1) the agreed-upon instructions; (2) the instructions proposed by plaintiff and opposed by defendant; and (3) the instructions proposed by defendant and opposed by plaintiff.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Joint exhibit list

The parties must prepare a joint exhibit list in compliance with the provided example and Local Rule 16-6.1.

A joint exhibit list shall be prepared in compliance with the example below and Local Rule 16-6.1.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Joint exhibit list

The joint exhibit list must contain the information required by Federal Rule of Civil Procedure 26(a)(3)(A).

The joint exhibit list shall contain the information required by Federal Rule of Civil Procedure 26(a)(3)(A).

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Exhibit binders

The parties must prepare two exhibit-binder sets for the Court and one for the opposing party and bring the sets to the Exhibit Conference.

The parties shall prepare two sets of exhibit binders for the Court, and another set of binders for the opposing party. Both sets must be brought to the Exhibit Conference.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Exhibits

Trial counsel must attend the Exhibit Conference at the stated time and place unless otherwise ordered, and submit exhibits to the CRD then.

AN EXHIBIT CONFERENCE REQUIRING THE ATTENDANCE OF TRIAL COUNSEL WILL BE HELD AT 3:30 P.M. ON THE FRIDAY BEFORE THE SCHEDULED TRIAL DATE IN COURTROOM 8A, UNLESS THE COURT ORDERS OTHERWISE. Exhibits are to be submitted to the CRD at the time of the Exhibit Conference.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Proposed findings conclusions

Unless the Court expressly orders otherwise, counsel must file proposed findings of fact and conclusions of law after trial in matters requiring them.

Notwithstanding Local Rule 52, for any matter requiring findings of fact and conclusions of law, unless otherwise expressly ordered by the Court, 1 counsel will be required to file (Proposed) Findings of Fact and Conclusions of Law after the conclusion of the trial.

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Civil cases

Applies to

Proposed findings conclusions

Proposed findings of fact must cite admitted evidence.

The proposed Findings of Fact must include citations to admitted evidence.

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Civil cases

Applies to

Proposed findings conclusions

If witness trial testimony is necessary to establish a fact, the party must obtain the transcript and file relevant excerpts with the proposed findings and conclusions.

Where witness trial testimony is necessary to establish a given fact, the party must obtain a transcript of the proceedings and file relevant excerpts of those transcripts with the (Proposed) Findings of Fact and Conclusions of Law.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Proposed findings conclusions

Counsel must email Microsoft Word versions of proposed findings and conclusions to chambers in addition to filing them.

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.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Pretrial order

The proposed Pretrial Conference Order must include a status report on the settlement procedure followed and the status of settlement efforts.

Counsel shall include in the proposed Pretrial Conference Order a status report detailing what procedure has been followed and the status of settlement efforts.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Pretrial order

The proposed Pretrial Conference Order must conform to the form in Appendix A to the Local Rules.

the proposed Pretrial Conference Order shall be in conformity with the form set forth in Appendix A to the Local Rules.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Pretrial order

Each party must identify its expert witnesses in the proposed Final Pretrial Conference Order; an omitted expert may not be called at trial.

Each party shall list and identify its respective expert witnesses, if any. Failure of a party to list and identify an expert witness in the Proposed Final Pretrial Conference Order shall preclude a party from calling that expert witness at trial.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Jury instruction

Each requested jury instruction must cite its source, be stated in full on a separate numbered page, address only one legal subject, and avoid duplicating another instruction.

Each requested instruction (a) shall cite the authority or source of the instruction; (b) shall be set forth in full; (c) shall be on a separate page; (d) shall be numbered; (e) shall cover only one subject or principle of law; and (f) shall not repeat principles of law contained in any other requested instruction.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Jury instructions

On the first day of trial, parties must file a clean set of joint and/or proposed jury instructions with the Courtroom Deputy Clerk and email it to chambers, with only the full instruction text on each page and the specified caption.

Accordingly, in addition to the file copies described above, the parties shall file with the Courtroom Deputy Clerk and shall email to chambers on the first day of the trial a “clean set” of joint and/or proposed jury instructions that contain only the text of each instruction set forth in full on each page, with the caption “Court’s Instruction Number ” (eliminating titles, supporting authority, indication of party proposing, etc.).

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Joint statement of the case

Counsel must prepare a joint statement of the case of no more than three paragraphs and file it 14 calendar days before the Final Pretrial Conference.

Counsel shall prepare a joint statement of the case which will be read by the Court to the prospective panel of jurors prior to the commencement of voir dire. The statement should not be longer than three paragraphs. The statement shall be filed with the Court fourteen calendar days before the Final Pretrial Conference.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Motion

Oral motions are not accepted; motions must be presented by written notice in compliance with the Local Rules.

Furthermore, pursuant to Local Rule 6-1, the Court will not accept oral motions; all motions shall be presented by written notice in compliance with the Local Rules.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Witness list

Counsel must file a joint witness list at least 21 days before the Final Pretrial Conference, including each witness’s phonetic name, anticipated testimony, and direct- and cross-examination time estimates.

At least twenty-one (21) days before the Final Pretrial Conference , counsel shall file their joint witness list, which shall include a phonetic spelling of each witness’s name, a brief description of each witness’s anticipated testimony, and time estimates for direct examination and cross examination of each witness:

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Witness list

On the first day of trial, counsel must provide the CRD three witness-list copies ordered by the witnesses’ anticipated sequence of testimony.

On the first day of trial, counsel shall provide three copies of witness lists, in the order in which the witnesses may be called to testify to the CRD, in the following form:

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint exhibit list

Counsel must file a Joint Exhibit List in the specified form at least 21 days before the Final Pretrial Conference.

At least twenty-one (21) days before the Final Pretrial Conference , counsel shall file their Joint Exhibit List in the following form:

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint exhibit stipulation

Counsel must file a Joint Exhibit Stipulation at least 14 days before the Final Pretrial Conference, stating exhibit objections, their grounds and explanation, and the offering party’s response.

At least fourteen (14) days before the Final Pretrial Conference , counsel shall file their Joint Exhibit Stipulation, which shall include objections to exhibits, the basis of the objection, and the offering party’s response. Each objection must include the grounds for the objection (e.g., a Federal Rule of Evidence) and an explanation of why the disputed exhibit is not admissible.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Exhibits

Counsel must submit exhibits in both hard-copy and electronic format at least seven days before trial.

At least seven (7) days before Trial, counsel shall submit their exhibits in both hard copy and electronic (e.g., USB) format.

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Applies to

Exhibit binders

Counsel must prepare three exhibit binders: an original for the CRD with exhibit tags on the upper-right corner of each exhibit’s first page, one copy for the Court, and one for the witness.

Counsel shall prepare three exhibit binders: (1) an original for the CRD, which shall be tagged with the appropriate exhibit tags in the upper right hand corner of the first page of each exhibit, (2) one copy for the Court, and (3) one copy for the witness.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Exhibit list

Counsel must provide three copies of the exhibit list to the CRD on the first day of trial.

On the first day of Trial, counsel shall provide three copies of the exhibit list to the CRD.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Pretrial order

Must include

proposed order

The proposed Final Pretrial Conference Order must be filed at least 14 days before the conference.

At least fourteen (14) days before the Final Pretrial Conference , counsel shall file a proposed Final Pretrial Conference Order.

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Applies to

Stipulation of facts

Counsel must file a separate Stipulation of Facts identifying uncontested facts.

Counsel shall file a separate Stipulation of Facts identifying the uncontested facts.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Stipulation of facts

Include the Stipulation of Facts as an exhibit in the Joint Exhibit Stipulation, Joint Exhibit List, and exhibit binders.

The Stipulation of Facts shall be included as an exhibit in the parties’ Joint Exhibit Stipulation, Joint Exhibit List, and exhibit binders.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Jury instructions

Counsel must meet and confer by the Rule 16-2 meeting to seek agreement on joint, undisputed jury instructions and verdict forms.

Prior to or at the time of the Rule 16-2 meeting, counsel shall meet and confer with the goal of reaching agreement as to one set of joint, undisputed jury instructions and one joint, undisputed verdict form or set of verdict forms.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Jury instructions

The parties must jointly submit one agreed set of jury instructions and a separate disputed set containing instructions on which they disagree.

the parties must act jointly to submit proposed jury instructions. The parties must submit one set of agreed-upon jury instructions. The parties must also submit a disputed set of jury instructions containing the instructions upon which the parties disagree.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Jury instructions

Disputed jury instructions must include redlined edits of the disputed language when applicable.

If applicable, the disputed jury instructions shall include redlined edits of the language over which the parties disagree.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Jury instructions

For each disputed instruction, the opposing party must attach a one-to-two-paragraph objection statement and the submitting party must attach a supporting statement, each on a separate page immediately after the instruction.

The party opposing the instruction must attach a short (i.e., one to two paragraphs) statement supporting the objection, and the party submitting the instruction must attach a short statement supporting the instruction. Each statement should be on a separate page and should follow directly after the disputed instruction.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Jury instruction

Each requested jury instruction must cite its source, be set out in full on a separate numbered page, address only one subject, and avoid repeating principles in other instructions.

Each requested instruction shall (a) cite the authority or source of the instruction, (b) be set forth in full, (c) be on a separate page, (d) be numbered, (e) cover only one subject or principle of law, and (f) not repeat principles of law contained in any other requested instruction.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint statement of the case

Counsel must prepare a Joint Statement of the Case for the Court to read to prospective jurors before voir dire.

Counsel shall also prepare a Joint Statement of the Case which will be read by the Court to the prospective panel of jurors prior to the commencement of voir dire.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Deposition transcript

Counsel must identify on each deposition transcript the testimony to be offered and whether it is for impeachment or in lieu of live testimony.

Counsel shall identify on the deposition transcript(s) the testimony the party intends to offer and whether the testimony will be offered for impeachment or in lieu of live testimony.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Stipulation of fact

A stipulation of fact requires the opposing party’s concurrence and must be submitted to the Court in writing for approval.

Any stipulation of fact will require the opposing party’s concurrence and shall be submitted to the Court in writing for approval.

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Civil cases

Applies to

Motion

The title page of every motion must state the Pretrial Conference date and Trial date.

The title page of all motions must state the Pretrial Conference date and the Trial date.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Must include

local rule certificate

Counsel must include a certificate stating that the document complies with Local Rule 11-6.1 and the Court’s type-volume limitations.

Counsel must also comply with Local Rule 11-6, which requires counsel to include a certificate that the document complies with the type-volume limitation of Local Rule 11-6.1 and this Court.

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Civil cases

Applies to

Motion to amend

Motions to amend must explain the amendment’s effect, be serially numbered, and identify the page, line numbers, and wording of each proposed change or addition.

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

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Memorandum

Evidentiary objections must be presented in a separate memorandum filed with the party’s opposition or reply brief, organized by Separate Statement paragraph, and identifying the evidence, objection ground, and brief supporting argument with authority.

Evidentiary objections should be addressed in a separate memorandum to be filed with the opposition or reply brief of the party. This memorandum should be organized to track the paragraph numbers of the Separate Statement in sequence. It should identify the specific item of evidence to which objection is made, the ground for the objection, and a very brief argument with citation to authority as to why the objection is well taken.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion in limine

Each motion in limine must identify the challenged matter and specific prejudice, followed by the movant’s contentions and supporting authorities.

Each Motion in Limine shall contain a clear identification of the testimony, exhibits, or other specific matters alleged to be inadmissible and/or prejudicial and a statement of the specific prejudice that will be suffered by the moving party if the motion is not granted. The identification of the matters in dispute shall be followed by the moving party’s contentions and memorandum of points and authorities.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion in limine

Must include

certificate of conference

A motion in limine seeking to prevent mention or display of prejudicial or inadmissible matter before the jury must include a declaration identifying the matter, documenting counsel’s discussion and opposing counsel’s position, and explaining specific prejudice.

Motions in Limine made for the purpose of precluding the mention or display of inadmissible and/or prejudicial matter in the presence of the jury shall be accompanied by a declaration that includes the following: (1) a clear identification of the specific matter alleged to be inadmissible and/or prejudicial; (2) a representation to the Court that the subject of the motion in limine has been discussed with opposing counsel, and that opposing counsel has either indicated that such matter will be mentioned or displayed in the presence of the jury before it is admitted in evidence or that counsel has refused to stipulate that such matter will not be mentioned or displayed in the presence of the jury unless and until it is admitted in evidence; and (3) a statement of the specific prejudice that will be suffered by the moving party if the motion in limine is not granted.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Pretrial order

If a party intends to call expert witnesses at trial, it must list and identify all retained and non-retained experts in the PTCO; omission may result in exclusion at trial.

(ix) If expert witnesses are to be called at trial, each party must list and identify its respective expert witnesses, both retained and non- retained. Failure of a party to list and identify an expert witness in the PTCO could result in a court order which precludes the party from calling that expert witness at trial.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Joint witness list

The joint witness list must be filed when counsel lodge the PTCO.

The joint witness list shall be filed at the same time counsel lodge the PTCO.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Deposition testimony designation

A party offering deposition testimony at trial must designate the portions to be read and advise opposing counsel.

If a party intends to offer deposition testimony into evidence at trial, the party shall designate the relevant portions of the deposition testimony to be read at trial and advise opposing counsel of same.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Deposition testimony objections

Objections to designated deposition testimony must be written and filed when counsel lodge the PTCO.

All objections to any such designated deposition testimony shall be made in writing and filed at the same time counsel lodge the PTCO so that the Court may consider whether ruling on the objections will facilitate trial or result in the disposition of evidentiary matters that may assist continuing settlement negotiations.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Expert witness list

A party intending to call expert witnesses at trial must list and identify them.

If expert witnesses are to be called at trial, each party shall list and identify their respective expert witnesses.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Expert witness narrative statement

When expert witnesses will testify, the parties must exchange short narrative statements at the PTC describing each expert’s qualifications and expected testimony.

If expert witnesses are to be called at trial, the parties shall exchange at the PTC short narrative statements of the qualifications of the expert and the testimony expected to be elicited at trial.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Witness list

On the first day of trial, the parties must lodge three copies of a witness list arranged in approximate order of testimony.

On the first day of trial, the parties must lodge with the Court three (3) copies of the witness list, which shall include the names of the witness in the approximate order in which they may be called to testify.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Pretrial exhibit stipulation

The parties must prepare a joint exhibit stipulation with each party’s numbered exhibit list, any objections and their grounds, and the offering party’s response.

The parties shall prepare a joint Pretrial Exhibit Stipulation that shall contain each party’s numbered list of all trial exhibits, with objections, if any, to each exhibit including the basis of the objection and the offering party’s response.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Pretrial exhibit stipulation

The parties must stipulate to exhibit authenticity whenever possible and identify unstipulated exhibits with specific reasons for the failure to stipulate.

The parties shall stipulate to the authenticity of exhibits whenever possible, and the Pretrial Exhibit Stipulation shall identify any exhibits for which authenticity has not been stipulated and the specific reasons for the parties’ failure to stipulate.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Pretrial exhibit stipulation

The Pretrial Exhibit Stipulation must be filed when counsel lodge the proposed PTCO.

The Pretrial Exhibit Stipulation shall be filed at the same time counsel lodge the proposed PTCO.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Exhibit stipulation

Counsel must meet no later than ten days before trial to stipulate, where possible, to authenticity, foundation, best-evidence-rule waiver, and exhibits admissible at the start of trial.

All counsel are to meet not later than ten (10) days before trial and to stipulate so far as is possible as to authenticity, foundation, waiver of the best evidence rule, and to those exhibits which may be received into evidence at the start of trial.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Final exhibit list

On the first day of trial, the parties must lodge three copies of the final exhibit list with the Court Clerk.

On the first day of trial, the parties must lodge with the Court Clerk three (3) copies of the of the final exhibit list.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Jury instruction

Each requested jury instruction must follow Local Rule 51-2, appear in full on a separately captioned and numbered page, address one legal subject without repetition, and cite its authority.

Each requested instruction shall be in the format specified by Local Rule 51-2 and shall be set forth in full; be on a separate page with the caption "COURT’S INSTRUCTION NUMBER ___”; be numbered; cover only one subject or principle of law; not repeat principles of law contained in any other requested instructions; and cite the authority for a source of the requested instruction.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Jury instructions

Each party must file a clean set of requested duplicate jury instructions with the CRD on the first day of trial, without citations to their sources.

In addition to the foregoing, each party shall file with the Courtroom Deputy Clerk (CRD) on the first day of trial a “clean set” of the aforesaid requested duplicate jury instructions. The “clean set” shall not cite the authority for a source of the requested instruction.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Trial exhibits

Counsel must deliver two sets of trial exhibits to the Court Clerk on the morning of the first trial day.

Counsel must deliver two sets of exhibits to the Court Clerk (one for witnesses and one for the Judge) on the morning of the first day of trial as follows:

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Deposition transcript

The complete original transcript of every deposition to be used at trial must be lodged with the Court on the first trial day.

The complete original transcript of any depositions to be used at trial shall be lodged with the Court on the first day of trial.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Court reporter document

Each party must file a Court Reporter document listing likely proper names and unusual, scientific, foreign, or uncommon words when counsel lodges the PTCO.

Each party must file with the Court, at the same time counsel lodges the PTCO, a document for the Court Reporter that contains proper names, unusual or scientific terms, or any other foreign or uncommon words that are likely to be used by the parties during the PTC and the Trial.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Status report

When lodging the proposed PTCO, the parties must file a Status Report describing settlement efforts without disclosing offers or demands and identifying the Settlement Officer by name and phone number.

The parties must file a Status Report regarding settlement at the time they lodge the proposed PTCO. This Report shall not disclose the parties’ settlement positions, i.e. the terms of any offers or demands. It shall merely describe the efforts made by the parties to resolve the dispute informally, i.e. the occasions and dates when the parties participated in mediation or settlement conferences. The Status Report shall also include the name and phone number of the Settlement Officer who assisted the parties with their settlement conference.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint rule 26f report

Unless otherwise ordered, counsel must file the Joint Rule 26(f) Report at least 14 days before the scheduling conference.

Unless otherwise ordered, no later than fourteen (14) days before the 14 Scheduling Conference, counsel shall file a Joint Rule 26(f) Report.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint rule 26f report

The Joint Rule 26(f) Report must address matters listed in Rule 26(f) and the court’s scheduling-conference order.

The Joint Rule 26(f) Report shall address the matters set forth in Federal Rule of Civil Procedure 26(f), as well as those enumerated in the court’s Order Setting Scheduling Conference.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Discovery document

Discovery documents must include “DISCOVERY MATTER” in the caption.

All discovery documents must include the words “DISCOVERY MATTER” in the caption to ensure proper routing.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Motion for review and reconsideration

A review motion must identify the challenged portions as clearly erroneous and contrary to law and include supporting points and authorities.

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

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Memorandum of points and authorities

Memoranda of Points and Authorities exceeding ten pages must include a Table of Authorities and a Table of Contents.

Pursuant to Local Rule 11-8, all 10 Memoranda of Points and Authorities exceeding ten (10) pages must be accompanied by a Table of Authorities and a Table of Contents.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Attachment

Declarations, exhibits, and other attachments must be separately docketed with descriptions; noncompliant filings may be struck or disregarded.

If a filed or lodged document has declarations, exhibits, or other attachments, each attachment must be filed as a separately-docketed attachment to the main docket entry with a description of the attachment (e.g., Dkt. 20-1 Declaration of Joe Smith; Dkt. 20-2 Ex. 1 - License Agreement; Dkt. 29-3 Evidentiary Objections). The court may strike or decline to consider motions, stipulations, or other documents with attachments that are not filed in accordance with this Order.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Motion to amend

Motions to amend must state the amendment’s effect, be serially numbered, and identify the pages, line numbers, and wording of proposed changes.

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 (i.e., “First Amended Complaint,” “Second Amended Complaint”); and (3) identify the pages, line numbers, and wording of any proposed change or addition of material.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Default judgment motion

A plaintiff seeking fees and costs with default judgment must include a properly supported request with the default-judgment motion.

A plaintiff who moves for default judgment and wishes to seek attorney’s fees and costs must include in the motion a properly supported request for attorney’s fees and costs together with the motion for default judgment.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Motion for leave

A party seeking permission for multiple summary-judgment motions or increased page limits must move by noticed motion and provide a detailed showing of good cause.

If a party believes this is one of the rare instances in which good cause exists for more than one motion for summary judgment or to increase page limits, the party shall seek leave by noticed motion setting forth a detailed showing of good cause.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Attorneys fee motion

Attorney-fee motions or requests must attach two tabular summaries of each attorney’s hours and billing rate, identifying each attorney’s title.

Any motion or request for attorneys’ fees shall attach two summaries, in table form, of the hours worked by and billing rate of each attorney with title (e.g., partner, counsel, associate, etc.).

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Attorneys fee motion

The first attorney-fee table must summarize each attorney’s hours organized by task.

The first table shall include a summary of the hours worked by each attorney, organized by task (e.g., discovery, motion to dismiss, motion for summary judgment).

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Attorneys fee motion

The second attorney-fee table must summarize hours organized by attorney.

The second table shall include a summary of the hours worked by each attorney, organized by attorney.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Attorneys fee motion

Both attorney-fee tables must list all tasks, hours per task, and each attorney’s hourly rate.

Both tables shall list all the tasks on which the attorney worked, the hours worked on each task, and the hourly rate of each attorney.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Attorneys fee motion

If an attorney’s rate changed during the action, separate calculations must show hours for each task at each rate.

If the hourly rate charged by any individual attorney changed while the action was ongoing, the party shall provide separate calculations for the total number of hours the attorney spent in connection with each task at each hourly rate.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Motion

Must include

proposed order

A party filing or opposing a motion, or seeking a matter’s determination, must file, serve, and electronically lodge a proposed order stating the requested relief or action and a brief, appropriately cited rationale.

Each party filing or opposing a motion or seeking the determination of any matter shall file, 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.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Motion, stipulation, ex parte application, or other request for relief

Must include

proposed order

A compliant proposed order must be emailed for the court to consider a motion, stipulation, ex parte application, or other request for relief; noncompliance may result in striking the filing.

The court will not consider a motion, stipulation, ex parte application, or other request for relief unless a compliant proposed order is received by email. A filing may be stricken for failure to timely comply.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Proposed final pretrial conference order

The Proposed FPTCO must be filed and emailed to Chambers at least two weeks before the FPTC, using the court’s template.

A proposed Final Pretrial Conference Order (“Proposed FPTCO”) must be filed and emailed to Chambers at least two (2) weeks before the FPTC. A template for the Proposed FPTCO is available on Judge Sykes’ webpage. The parties must use this template.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Declarations

When ordered in a case, each party must file and email Chambers declarations containing the direct testimony of each intended trial witness.

When ordered by the Court in a particular case, each party must file and email to Chambers declarations containing the direct testimony of each witness whom that party intends to call at trial.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint witness list

The Joint Witness List must follow Local Rule 16-5’s format and provide specified testimony, uniqueness, and examination-time information for each witness.

The Joint Witness List must be in the format specified in Local Rule 16-5 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.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint witness list

The parties must use Judge Sykes’ webpage template, and any amended Joint Witness List must be filed and emailed to Chambers by noon on the Friday before trial.

The parties must use the template posted on Judge Sykes’ webpage. Any Amended Joint Witness List must be filed and emailed to Chambers by 12:00 p.m. (noon) on the Friday before trial.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint exhibit list

The Joint Exhibit List must follow Local Rule 16-6’s format and include a column stating objections to authenticity or admissibility and their reasons.

The Joint Exhibit List must be in the format specified in Local Rule 16-6 and must include an additional column stating any objections to authenticity and/or admissibility and the reasons for the objections.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Jury instructions

Redline jury-instruction sets must show modifications to pattern or model instructions, disputed language, and each party’s factual or legal basis for its position on each dispute.

The redline sets must 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.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Jury instructions

Counsel must list proposed instructions in delivery order and indicate when each is to be read.

Counsel also must list the instructions in the order they will be given and indicate whether the instruction must be read before opening statements, during trial, or before closing arguments.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Verdict form

If the parties cannot agree on a verdict form, they must file and email Chambers one document titled “Competing Verdict Forms” containing each proposal, a redline of disputed language, and the factual or legal basis for each position.

If the parties are unable to agree on a verdict form, the parties must file and email to Chambers one document titled “Competing Verdict Forms” which must 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.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Proposed findings conclusions

In trials requiring findings and conclusions, each party must file and email proposed findings and conclusions to Chambers in the Local Rule 52-3 format.

For any trial requiring findings of fact and conclusions of law, each party must file and email to Chambers its Proposed Findings of Fact and Conclusions of Law in the format specified in Local Rule 52-3.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Trial exhibits

The parties must submit three sets of trial-exhibit binders: one original and two copies.

The parties must submit to the Court three (3) sets of binders: one (1) original set of trial exhibits, and two (2) copies of trial exhibits.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Trial exhibits

Exhibits may not be published to jurors before admission into evidence.

The Court does not permit exhibits to be “published” to the jurors before they are admitted into evidence.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Applies to

Joint index

When lodging deposition evidence under L.R. 32-1, the offering party must serve and file a joint index on all parties and the Court containing the specified designation and objection information.

d. and, at the time of lodging under L.R. 32-1, the party 3 offering the evidence must serve and file a joint index on all 4 parties and the Court that reflects (1) the portions of the 5 depositions offered, (2) which party is offering them, (3) the pages and lines being offered, (4) any objections to each designation, and (5) the grounds for all objections.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Worksheet

The parties must complete the worksheet jointly and file it with their Joint Rule 26(f) Report.

Please complete this worksheet jointly and file it with your Joint Rule 26(f) Report.

Checked against the court's document on Oct 4, 2026WARNING

Applies to

Stipulation

Must include

proposed order

To seek dates for additional events, the parties may file a separate stipulation and proposed order.

The parties may seek dates for additional events by filing a separate stipulation and proposed order.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Statutory citations should specify sections and subsections, and citations to treatises, manuals, and other materials should include volume, section, and pages.

(c) Citations to Other Sources. Statutory references should identify with specificity the sections and subsections referenced. Citations to treatises, manuals, and other materials should include the volume, section, and pages being referenced.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Applies to

Notice of motion

If no timely opposition is filed, the Court may vacate the default-judgment hearing, and the notice of motion should state this possibility.

The Court may vacate the hearing on a motion for default judgment if no opposition is timely filed, and the notice of motion should so state.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Applies to

Joint rule 26 f report

In class actions, the parties must discuss scheduling issues in their Joint Rule 26(f) Report.

As explained in further detail on the web page, the parties are directed to discuss class action scheduling issues in their Joint Rule 26(f) Report.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Applies to

Joint rule 26 f report

In patent cases, counsel should prepare and attach the utility patent-specific Exhibit B to the Joint Rule 26(f) Report instead of Exhibit A.

In patent cases, counsel should review, prepare, and attach the Court’s Joint Rule 26(f) Report utility patent-specific Exhibit B (in lieu of the Exhibit A).

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Civil cases

Applies to

Motion in limine

Motions in limine must not be used as disguised motions for summary adjudication.

Motions in limine should not be disguised motions for summary adjudication of issues.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Civil cases

Applies to

Witness list

When multiple witnesses are offered on the same subject, their summaries must be detailed enough for the Court to determine whether the testimony is cumulative.

If more than one witness is offered on the same subject, the summary should be sufficiently detailed to allow the Court to determine if the testimony is cumulative.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Civil cases

Applies to

Witness list

The witness list must follow the specified name, description, time-estimate, and comments conventions; handwritten entries are allowed only if very neat and legible.

(1) List witnesses (last name first); (2) for description, be extremely brief, e.g., “eyewitness to accident,” or “expert on standard of care”; (3) use estimates within fractions of an hour, rounded off to closest quarter of an hour (e.g., 25 minutes becomes .5 hour, and 45 minutes would be .75 hour); (4) note special considerations in “Comments” column (e.g., “needs interpreter”); and (5) entries may be in handwriting only if the handwriting is very neat and legible.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Civil cases

Applies to

Jury instructions

Jury instructions should be submitted in the order the parties want them read.

The instructions should be submitted in the order in which the parties wish to have the instructions read.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Civil cases

Applies to

Jury instructions

Disputed jury instructions should reflect the parties’ basic disagreements about the law.

Instructions upon which agreement cannot be reached should reflect the basic disagreements among the parties as to the law.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Civil cases

Applies to

Jury instructions

For each disputed instruction, a party should state its objections and reasons for its alternative on pages following that alternative instruction.

For disputed instructions, a party should note its objections to a proposed instruction and its reasons for putting forth its alternative on pages placed after its own alternative instruction.

Checked against the court's document on Oct 4, 2026WARNING

Applies to

Motion to dismiss

After the plaintiff amends the complaint, a defendant with a pending motion to dismiss must file a Notice of Withdrawal under L.R. 7-16 without waiting for further action.

If a defendant files a motion to dismiss a complaint and the plaintiff subsequently amends that complaint, then the defendant shall file a Notice of Withdrawal of its motion to dismiss in accordance with L.R. 7-16, without waiting for the plaintiff or the Court to take action on the motion.

Checked against the court's document on Oct 4, 2026WARNING

Applies to

Pretrial order

Counsel must make a good-faith effort to agree on and include as many uncontested facts as possible in the proposed Final Pretrial Conference Order.

In drafting the Proposed Final Pretrial Conference Order, counsel shall make a good faith effort to agree on, and to set forth, as many uncontested facts as possible.

Checked against the court's document on Oct 4, 2026WARNING

Applies to

Pretrial order

Factual issues in the proposed order should track claim or defense elements and be stated as ultimate facts, not evidentiary disputes.

In drafting the factual issues in dispute for the Proposed Final Pretrial Conference Order, the issues of fact should track the elements of a claim or defense upon which the jury would be required to make findings. Counsel should attempt to state issues in ultimate fact form, not in the form of evidentiary fact issues (i.e., “was the defendant negligent?”; “was such negligence the proximate cause of injury to the plaintiff?”; “was the plaintiff negligent?”; not, “was the plaintiff standing on the corner of 5th Street and Spring Avenue at 10:00 a.m. on May 3?”). Counsel may list sub-issues under the headings of ultimate fact issues, but shall not use this as a device to list disputes over evidentiary matters.

Checked against the court's document on Oct 4, 2026WARNING

Applies to

Pretrial order

Issues of law in the proposed order should identify legal issues for the Court to decide and should not include ultimate fact issues for the trier of fact.

Issues of law should state legal issues upon which the Court will be required to rule after the Pretrial Conference, including during the trial, and should not list ultimate fact issues to be submitted to the trier of fact.

Checked against the court's document on Oct 4, 2026WARNING

Applies to

Exhibit index

Must include

exhibit list

Provide four copies of the exhibit index.

Four copies of the exhibit index.

Checked against the court's document on Oct 4, 2026WARNING

Applies to

Jury instructions

For each disputed instruction, the opposing party must attach a one-to-two-paragraph statement supporting the objection, and the submitting party must attach a short supporting statement.

Where the parties disagree on an instruction, the party opposing the instruction must attach a short (i.e., one to two paragraphs) statement supporting the objection and the party submitting the instruction must attach a short statement supporting the instruction.

Checked against the court's document on Oct 4, 2026WARNING

Applies to

Motions in limine

Each side may file no more than five motions in limine.

Each side is limited to five (5) motions in limine.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Applies to

Exhibit binder

Each exhibit binder must show its volume number on the spine and contain an index of the exhibits in that volume.

The spine portion of the binder shall indicate the volume number of the binder. Each binder shall contain an index of the exhibits included in the volume.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Applies to

Exhibits

An exhibit should contain only the specific excerpt or pages a party seeks to introduce, rather than the longer recording or document.

For example, if a party seeks to introduce a five-minute excerpt of a longer video or audio recording, the exhibit should be of the five-minute version. Similarly, if a party seeks to introduce ten pages of a forty-page document, the exhibit should consist of only the ten pages to be introduced.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Applies to

Joint exhibit list

The Joint Exhibit List provided to the Court must use exhibit designations consistent with the exhibit labels.

The Joint Exhibit List provided to the Court shall be consistent with this directives. In other words, if the Exhibit is labeled 101-1, the Joint Exhibit List shall list the Exhibit as 101-1.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Civil cases

Applies to

Summary judgment evidence

Summary judgment evidence should be submitted by stipulation or as exhibits to an authenticating declaration, not attached to the memorandum of points and authorities.

Evidence submitted in support of or in opposition to a motion for summary judgment should be submitted either by way of stipulation or as exhibits to a declaration sufficient to authenticate the proffered evidence, and should not be attached to the memorandum of points and authorities.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Civil cases

Applies to

Memorandum of points and authorities

The movant’s memorandum must include a narrative statement of relevant facts, with each fact supported by a citation to the corresponding Separate Statement paragraph.

The movant’s memorandum of points and authorities should be in the usual form required under Local Rule 7 and should contain a narrative statement of facts as to those aspects of the case that are before the Court. All facts should be supported with citations to the paragraph number in the Separate Statement that supports the factual assertion.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Civil cases

Applies to

Opposition memorandum

An opposition memorandum stating facts must cite the Separate Statement for undisputed facts, contrary evidence for disputed facts, or the paragraph number of a contravening additional fact in the Statement of Genuine Issues of Material Fact.

Where the opposition memorandum sets forth facts, the memorandum should cite to paragraphs in the Separate Statement if they are not in dispute, to the evidence that contravenes the fact where the fact is in dispute, or, if the fact is contravened by an additional fact in the Statement of Genuine Issues of Material Fact, the citation should be to such fact by paragraph number.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Civil cases

Applies to

Motion in limine

The title page of a motion in limine must state the pretrial conference, motions-in-limine hearing, and trial dates.

The title page of the Motion in Limine must state the Pretrial Conference date, hearing date for the motions in limine, and the Trial date.

Checked against the court's document on Oct 4, 2026WARNING

Civil cases

Applies to

Pretrial order

The PTCO must include a table of contents at the beginning.

(ii) Include a Table of Contents at the beginning.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Civil cases

Applies to

Exhibit objections

Blanket or boilerplate objections to opposing exhibits must not be submitted.

However, do not submit blanket or boilerplate objections to the opposing party’s exhibits.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Civil cases

Applies to

Witness list

Counsel must prepare a joint witness list that includes specified information for each witness.

Counsel shall prepare a joint list of their witnesses, including a brief summary (two to three paragraphs) of each witness’s expected testimony, what makes the testimony unique from any other witness testimony, an estimate of the length of time needed for direct examination of each side’s own witnesses and an estimate for the cross

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Civil cases

Applies to

Expert witness narrative statement

Previously exchanged expert reports do not satisfy the requirement for narrative statements.

Previously prepared and exchanged expert reports shall not substitute for the narrative statements required.

Checked against the court's document on Oct 4, 2026WARNING

Civil cases

Applies to

Pretrial exhibit stipulation

The Pretrial Exhibit Stipulation must substantially follow the form provided by the Court.

The Pretrial Exhibit Stipulation shall be substantially in the following form:

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Civil cases

Applies to

Jury instructions

The parties must make every attempt to agree on jury instructions before submitting them to the Court.

The parties shall make every attempt to agree upon the jury instructions before submitting them to the Court.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Civil cases

Applies to

Preliminary jury instructions

If the parties elect to give preliminary substantive jury instructions, they should provide them to the Court on the first day of trial.

Should the parties elect to give preliminary instructions, those substantive instructions should be produced to the Court on the first day of trial.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Applies to

Joint rule 26f report

A late or nonconforming Joint Rule 26(f) Report may result in sanctions, including dismissal.

A Joint Rule 26(f) Report which is not timely filed or does not conform with this Order, Federal Rule of Civil Procedure 26(f), and/or applicable Local Rules will interfere with preparation by the court and its staff and may result in the assessment of sanctions, including dismissal.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Applies to

Notice of motion

The court may vacate a default-judgment hearing if no timely opposition is filed, and the notice of motion should state that possibility.

The court may vacate the hearing on a motion for default judgment if no opposition is timely filed, and the notice of motion should so state.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Applies to

Evidentiary objections

Evidentiary objections should be presented in a separate two-column statement identifying the challenged material and stating a concise, cited objection.

If a party disputes a fact based in whole or in part on an evidentiary objection, the ground for the objection should be stated succinctly in a separate statement of evidentiary objections in a two column format. The left column should identify the items objected to (including page and line number if applicable) and the right column should set forth a concise objection (e.g., hearsay, lack of foundation, etc.) with a citation to the Federal Rules of Evidence or, where applicable, a case citation.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Counsel must include their email address, telephone number, and fax number on all papers.

Counsel must include on all papers their email address, telephone number, and fax number to facilitate communication with the Courtroom Deputy.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Applies to

Stipulation

Must include

proposed order

Parties seeking additional dates may file a stipulation and proposed order.

If the parties1 seek to set additional dates, they may file a Stipulation and Proposed Order.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Applies to

Verdict form

The parties must make every effort to agree on a general or special verdict form before submitting proposals to the Court.

The parties must make every effort to agree on a general or special verdict form before submitting proposals to the Court.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Applies to

Trial exhibits

The original exhibit set is for jury deliberations, and the copies are for the Court.

The original set of exhibits must be for use by the jury during its deliberations, and the copies are for the Court.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Applies to

Trial exhibits

The parties must prepare additional exhibit copies for their own use and for witnesses.

The parties must prepare additional copies of exhibits for their own use and for use by witnesses.

Checked and corrected to match the court's document on Oct 4, 2026WARNING

Applies to

Discovery response excerpts

When counsel expects to offer a group of answers extracted from lengthy discovery responses, counsel should prepare a document listing each question and answer and its source, and provide copies to the Court and opposing party.

Whenever counsel expects to offer a group of answers to interrogatories or requests for admissions 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. Copies of this new document must be provided to the Court and the opposing party.

Checked and corrected to match the court's document on Oct 4, 2026INFO

Civil cases

Applies to

Witness binders

Witness binders need not be provided to the CRD or opposing side until the witness is called.

As such, they need not be given to the Courtroom Deputy Clerk (“CRD”) or the opposing side until each witness is called.

Checked and corrected to match the court's document on Oct 4, 2026INFO

Civil cases

Applies to

Pretrial order

Factual issues in the PTCO should be stated as ultimate facts, track the elements of claims or defenses, and not be framed as evidentiary fact issues.

(vi) In drafting the factual issues in dispute for the PTCO, the parties should attempt to state issues in ultimate fact form, not in the form of evidentiary fact issues. The issues of fact should track the elements of a claim or defense on which the jury will be required to make findings.

Checked and corrected to match the court's document on Oct 4, 2026INFO

Civil cases

Applies to

Pretrial order

The PTCO’s issues of law should identify legal issues for the Court to decide at trial and should not list ultimate fact issues for the trier of fact.

(vii) Issues of law should state legal issues on which the Court will be required to rule during the trial, and should not list ultimate fact issues to be submitted to the trier of fact.

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Applies to

Complaint

Complaints must include a numbered list of all causes of action on the face-page.

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Applies to

Motion

Must include

proposed order

Notice of Supplemental Authority, Marking Evidence, Pending Dispositive Motions; Motions for Default Judgment require complete proposed Orders.

Summary: Motions for Default Judgment must include complete proposed orders.

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Applies to

Motion

Summary Judgment / Rule 56 Motions must comply with Local Rule 56, which was substantially revised as of June 1, 2023; clarification about cross-motions.

Summary: Summary judgment / Rule 56 motions must comply with Local Rule 56.

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Applies to

Notice of motion

Must include

local rule certificate ?

A Notice of Motion must include a statement of compliance with Local Rule 7-3. The statement of compliance must be prominent, as the Court will not search a filing for the statement. The Court may strike or outright deny a motion that lacks a prominent statement of compliance with Local Rule 7-3, or if counsel fail to meet and confer in good faith.

Summary: A Notice of Motion must include a prominent statement of compliance with Local Rule 7-3, or the motion may be struck or denied.

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Applies to

Exhibits ?

Entire deposition transcripts, entire sets of interrogatory responses, and documents that do not specifically support or controvert material in the separate statement must not be filed.

Summary: Entire deposition transcripts, entire sets of interrogatory responses, and non-supporting documents must not be filed.

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Applies to

Evidence

Evidence must be filed either by stipulation or as exhibits to declarations sufficient to authenticate the proffered evidence, and must not be attached to the memorandum.

Summary: Evidence must be filed by stipulation or as exhibits to authenticating declarations, not attached to the memorandum.

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Applies to

Ex parte application ?

Must include

certificate of conference ?

Applications that do not conform with Local Rules 7-19 and 7-19.1, such as by omitting a statement of opposing counsel's position, will not be considered.

Summary: Ex parte applications must conform with Local Rules 7-19 and 7-19.1, including a statement of opposing counsel's position, or they will not be considered.

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Applies to

Continuance request ?

Must include

proposed order

Requests for continuances must be made before the date to be continued and by motion or stipulation, along with a proposed order.

Summary: Every continuance request by motion or stipulation must include a proposed order.

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Applies to

Ex parte application ?

Any party seeking ex parte relief must comply with Local Rule 7-19.

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Applies to

Ex parte application ?

The moving party must indicate whether an opposition is anticipated and the nature of the dispute.

Summary: An ex parte application must indicate whether an opposition is anticipated and the nature of the dispute.

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Applies to

Trial memorandum

The Government shall file a trial memorandum that shall set forth (1) a factual summary of the Government's case-in-chief; (2) a statement of the charges and the

Summary: The Government's trial memorandum must include a factual summary of the Government's case-in-chief and a statement of the charges (list continues beyond excerpt).

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Applies to

Disputed joint statement of the case

If the parties cannot agree on such a joint statement, they shall file a “Disputed Joint Statement of the Case,” which shall include each party’s respective proposed statement, together with a “redline” comparing the parties’ respective statements.

Summary: If the parties cannot agree, they must file a Disputed Joint Statement of the Case containing each party's proposed statement plus a redline comparing them.

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Applies to

Witness list ?

The list shall include the witnesses in the order that they are expected to testify and, to the extent possible, an accurate estimate of the time needed for each witness for direct testimony. It shall also include a brief summary of each witness’s testimony. If more than one witness is offered on the same subject, the summary should be sufficiently detailed to allow the Court to determine if the testimony is cumulative.

Summary: The witness list must list witnesses in expected order of testimony, estimate time needed for each direct testimony, and include summaries detailed enough to assess cumulativeness.

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Applies to

Jury instructions

If the parties disagree over any proposed jury instruction(s), the parties shall file: (i) one set of proposed jury instructions to which all parties agree and (ii) one set of disputed jury instructions, which shall include a “redline” of any disputed language and the factual or legal basis for each party’s respective position as to each disputed instruction. Where appropriate, the disputed instructions shall be organized by subject, so that the instructions that address the same or similar issues are presented sequentially.

Summary: On disagreement, parties must file an agreed instruction set plus a disputed set with a redline and each party's factual/legal basis, organized by subject where appropriate.

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Applies to

Final clean jury instructions ?

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

Summary: The final clean version of the jury instructions must contain only the text of each instruction (no titles, authority, or proposing-party indications).

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Applies to

Competing verdict forms

"Competing Verdict Forms" which shall include: (i) the parties' respective proposed verdict form; (ii) a "redline" of any disputed language; and (iii) the factual or legal basis for each party's respective position if the entire form is being disputed.

Summary: Competing verdict form submissions must include each party's respective proposed verdict form, a redline of any disputed language, and the factual or legal basis for each party's position if the entire form is disputed.

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Applies to

Exhibit list

Counsel shall each prepare an exhibit list in compliance with Local Civil Rule 16-6.

Summary: Each party's counsel must prepare an exhibit list in compliance with Local Civil Rule 16-6.

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Applies to

Discovery documents ?

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

Summary: All documents relating to discovery matters must include the words 'DISCOVERY MATTER' in the caption to ensure proper routing.

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Applies to

Motion

Must include

proposed order

Each party filing or opposing a motion or seeking the determination of any matter shall serve and lodge a proposed order setting forth the relief or action sought and a brief statement of the rationale for the decision with appropriate citations. Any request for action by the Court shall be made by appropriate motion or stipulation and shall be accompanied by a proposed order.

Summary: Every party filing or opposing a motion or seeking any determination must serve and lodge a proposed order stating the relief sought and a brief rationale with citations, and every request for court action must be made by motion or stipulation accompanied by a proposed order.

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Applies to

Stipulation ex parte application or request for relief ?

Must include

proposed order

The Court will not consider a stipulation, ex parte application, or other request for relief until a compliant proposed order is received by email.

Summary: The Court will not consider any stipulation, ex parte application, or other request for relief until a compliant proposed order is received by email.

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Applies to

Filing

Must include

ai disclosure ?

Any party who uses generative artificial intelligence (such as ChatGPT, Harvey, CoCounsel, or Claude) to generate any portion of a brief, pleading, or other filing must attach to the filing a separate declaration disclosing the use of artificial intelligence and certifying 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.

Summary: Any filing containing generative-AI-generated content must attach a separate declaration disclosing the AI use and certifying that the filer verified the content's accuracy and Rule 11 compliance.

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Applies to

Motion

Must include

certificate of conference ?

(b) Certification. The moving party shall include a signed ... parties met in person or by videoconference or telephone, thoroughly discussed each and every issue raised in the motion, and attempted in good faith to resolve the motion in whole or in part.

Summary: Motions must include a signed certification stating that the parties met in person, by videoconference, or by telephone, thoroughly discussed every issue raised in the motion, and attempted in good faith to resolve it.

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Applies to

Motion 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; and (3) state the page and line number(s) and wording of any proposed change or addition of material.

Summary: All motions to amend pleadings must state the amendment's effect, be serially numbered, and identify the page and line numbers and wording of each proposed change.

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Applies to

Motion to amend ?

Counsel shall electronically file a "Notice of Lodging" attaching the proposed amended pleading as a document separate from the motion, as well as a "redlined" version of the proposed amended pleading identifying all additions and deletions of material as an appendix to the moving papers.

Summary: Motions to amend must be accompanied by an electronically filed Notice of Lodging attaching the proposed amended pleading as a separate document plus a redlined version identifying all additions and deletions as an appendix.

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Applies to

Motion or stipulation for continuance ?

Must include

proposed order

Requests for continuances must be made before the date to be continued and by motion or stipulation, along with a proposed order.

Summary: Continuance requests made by motion or stipulation must include a proposed order.

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Applies to

Motion for default judgment ?

The motion must include a showing of both subject-matter and personal jurisdiction. See In re Tuli, 172 F.3d 707, 712 (9th Cir. 1999).

Summary: A motion for default judgment must include a showing of both subject-matter and personal jurisdiction.

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Applies to

Motion for default judgment

A plaintiff who moves for default judgment and wishes to seek attorney's fees and costs must include in the motion a properly supported request for attorney's fees and costs together with the motion for default judgment. Failure to do so will result in the striking of any subsequent motion for attorney's fees and costs absent a showing of good cause.

Summary: A request for attorney's fees and costs must be included with the motion for default judgment, or any later fee motion will be struck absent good cause.

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Applies to

Motion for attorneys fees ?

For any motion requesting more than $50,000 in fees, the movant shall additionally provide by email to the CRD an Excel spreadsheet documenting the hours for which the movant seeks recovery, using the format in the following example:

Summary: Fee motions requesting more than $50,000 must be accompanied by an Excel time spreadsheet (Date, Name, Position, Task, Hours, Rate, Amount) emailed to the CRD.

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Applies to

Joint brief

Each party's arguments in the Joint Brief shall be responsive to the opposing party's arguments. Accordingly, the parties shall provide their portions of the Joint Brief to the opposing parties sufficiently in advance of the motion filing deadline

Summary: Each party's Joint Brief arguments must be responsive to the opponent's arguments, and each party must exchange its portions of the Joint Brief with opposing parties sufficiently in advance of the filing deadline.

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Applies to

Joint brief ?

For each issue, the moving party shall present legal argument, citation to authority where applicable, and citation to the Joint Appendix of Facts, see below, followed immediately by the opposing party's response that similarly must be supported by legal argument, citation to authority, and citation to the Joint Appendix of Facts.

Summary: In the Joint Brief, each issue must present the moving party's legal argument with citations to authority and the Joint Appendix of Facts, followed immediately by the opposing party's equally supported response.

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Applies to

Joint brief

The Joint Brief shall be accompanied by a single statement of undisputed and disputed facts contained in a JAF presented in a table.

Summary: The Joint Brief must be accompanied by a single statement of undisputed and disputed facts contained in a Joint Appendix of Facts (JAF) presented in a table.

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Applies to

Joint appendix of exhibits ?

Physical evidence (e.g., video recordings) shall be lodged separately. No evidence should be attached to a memorandum of points and authorities or included anywhere other than in the JAE.

Summary: Evidence supporting or opposing summary judgment must be included in the Joint Appendix of Exhibits (with physical evidence lodged separately) and must not be attached to the memorandum of points and authorities.

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Applies to

Joint appendix of exhibits ?

The JAE shall include a table of contents.

Summary: The Joint Appendix of Exhibits must include a table of contents.

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Applies to

Joint appendix of exhibits ?

Citations to the JAE shall be to the page and line within the particular exhibit.

Summary: Citations to the JAE must refer to the page and line within the particular exhibit.

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Applies to

Declaration

Declarations shall set out admissible facts without any argument, and evidence must be submitted either by stipulation or as exhibits to declarations sufficient to authenticate the proffered evidence and must not be attached to the Joint Brief.

Summary: Declarations submitted with summary judgment papers must contain only admissible facts without argument.

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Applies to

Documentary evidence

Documentary evidence for which there is no stipulation regarding authenticity must be accompanied by testimony, either by declaration or deposition transcript, of a witness who can establish authenticity.

Summary: Unstipulated documentary evidence must be accompanied by declaration or deposition testimony from a witness who can establish authenticity.

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Applies to

Joint appendix of exhibits ?

No party shall submit evidence other than the specific evidence necessary to support or controvert a proposed statement of undisputed fact. Do not, for example, submit the entire deposition transcripts or an entire set of interrogatory responses when relying on only a portion of such documents.

Summary: Parties may submit only the specific evidence necessary to support or controvert a proposed statement of undisputed fact (e.g., no entire deposition transcripts when only a portion is relied upon).

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Applies to

Joint appendix of objections ?

The Joint Brief shall be accompanied by a separate JAO, if any. In other words, evidentiary objections, if any, shall be made in a single, separate document presented in a four-column table.

Summary: Evidentiary objections must be submitted in a single, separate Joint Appendix of Objections presented in a four-column table accompanying the Joint Brief.

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Applies to

Ex parte application ?

The moving party must indicate whether an opposition is anticipated and the nature of the dispute.

Summary: The moving party's ex parte application must indicate whether an opposition is anticipated and the nature of the dispute.

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Applies to

Joint rule 26f report ?

The Report shall be drafted by the plaintiff (unless the plaintiff is a pro se litigant or the parties agree otherwise) but shall be submitted and signed jointly. "Jointly" means a single report, regardless of how many separately represented parties exist in the case.

Summary: The Joint Rule 26(f) Report is drafted by the plaintiff (unless the plaintiff is pro se or the parties agree otherwise) but must be submitted and signed jointly as a single report.

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Applies to

Joint rule 26f report

The Joint Rule 26(f) Report shall specify the date of the Mandatory Scheduling Conference on the caption page. Under the title, it shall list the dates of the (1) original complaint; (2) removal (if removed); (3) responsive pleading; and (4) trial (proposed).

Summary: The Joint Rule 26(f) Report's caption page must state the Mandatory Scheduling Conference date and, under the title, list the dates of the original complaint, removal (if any), responsive pleading, and proposed trial.

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Applies to

Joint rule 26f report

The Joint Rule 26(f) Report shall address the matters set forth in Fed. R. Civ. P. 26(f) and Local Rule 26, some of which are enumerated below, and shall also contain the following:

Summary: The Joint Rule 26(f) Report must address Fed. R. Civ. P. 26(f) and Local Rule 26 matters and contain the judge's enumerated sections (statement of the case, subject-matter jurisdiction, legal issues, conflicts, damages, insurance, motions, Manual for Complex Litigation, and discovery status/plan/cutoff).

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Applies to

Joint rule 26f report ?

A statement of what settlement negotiations have occurred, excluding any statement of the terms discussed. The parties must state their preference for mediation before: (i) the Magistrate Judge, (ii) the Court Mediation Panel, or (iii) a private mediator (at the parties’ expense). The Court will exercise its discretion to select an ADR option for the parties if they fail to state a preference. No case will proceed to trial unless all parties, including an officer of all corporate parties (with full authority to settle the case), have appeared personally and participated in an ADR proceeding.

Summary: The Joint Rule 26(f) Report must include a settlement-negotiation statement (excluding terms discussed) and a stated mediation preference, and no case may proceed to trial unless all parties (including authorized corporate officers) personally participate in an ADR proceeding.

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Applies to

Joint rule 26f report ?

Time Estimate. A realistic estimate, in days, of the court time required for trial and whether trial will be by jury or by the Court. Each side should specify (by number, not by name) how many witnesses it contemplates calling.

Summary: The report must provide a realistic estimate in days of trial time, state whether trial will be by jury or the Court, and specify the number (not names) of witnesses each side contemplates calling.

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Applies to

Joint rule 26f report ?

The name of the attorney who will serve as lead trial counsel, as well as other attorneys who will participate in the trial. Only one (1) attorney for a party may be designated as lead trial counsel unless otherwise permitted by the Court. If a second lead trial counsel is permitted by the Court, both counsel must attend the Pretrial Conference.

Summary: The report must identify lead trial counsel and other trial attorneys; only one lead trial counsel per party is allowed absent Court permission, and if a second is permitted, both must attend the Pretrial Conference.

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Applies to

Joint rule 26f report

The parties must make every effort to agree on all pretrial and trial dates. 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. The entries in the “Time Computation” column reflect what the Court believes is appropriate for most cases and will allow the Court to rule on potentially dispositive motions sufficiently in advance of the Final Pretrial Conference. However, the parties may propose earlier dates by which the key requirements must be completed.

Summary: A completed Schedule of Pretrial and Trial Dates Worksheet must be submitted with the Joint Rule 26(f) Report, with the parties making every effort to agree on dates, though earlier dates may be proposed.

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Applies to

Application to seal ?

Must include

proposed order, certificate of service ?

Counsel are required to comply with Local Rule 5-4.4.1 and attach the proposed order to the application.

Summary: Counsel must comply with Local Rule 5-4.4.1 and attach the proposed order to the application to seal.

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Applies to

Proposed order

PROPOSED ORDER MUST CONTAIN THE FOLLOWING LANGUAGE FOR THE COURT'S USE IF THE UNDER SEAL FILING IS REJECTED: 1. Counsel shall publicly file the document(s). (For use if the party wants the Court to consider the document(s).) 2. Counsel shall file redacted versions of the documents on the docket. The Court will consider the unredacted mandatory paper chambers copy.

Summary: The proposed order accompanying an application to seal must contain the Court's specified rejection language allowing either public filing or filing of redacted versions with the unredacted paper chambers copy considered.

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Civil cases

Applies to

Trial filings first round

Trial Filings (first round) • Motions In Limine • Memoranda of Contentions of Fact and Law [L.R. 16-4] • Witness Lists [L.R. 16-5] • Joint Exhibit List [L.R. 16-6.1] • Joint Status Report Regarding Settlement • Proposed Findings of Fact and Conclusions of Law [L.R. 52] (court trial only) • Declarations containing Direct Testimony (court trial only)

Summary: First-round trial filings must include motions in limine, memoranda of contentions of fact and law, witness lists, the joint exhibit list, a joint status report regarding settlement, and (court trials only) proposed findings of fact and conclusions of law and declarations containing direct testimony.

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Civil cases

Applies to

Trial filings second round

Trial Filings (second round) • Oppositions to Motions In Limine • Joint Proposed Final Pretrial Conference Order [L.R. 16-7] • Joint/Agreed Proposed Jury Instructions (jury trial only) • Disputed Proposed Jury Instructions (jury trial only) • Joint Proposed Verdict Forms (jury trial only) • Joint Proposed Statement of the Case (jury trial only) • Proposed Additional Voir Dire Questions, if any (jury trial only) • Evidentiary Objections to Decls. of Direct Testimony (court trial only)

Summary: Second-round trial filings must include oppositions to motions in limine and the joint proposed final pretrial conference order, plus (jury trials only) proposed jury instructions, verdict forms, statement of the case, and voir dire questions, and (court trials only) evidentiary objections to declarations of direct testimony.

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Civil cases

Applies to

Joint report

Counsel shall file a Joint Report regarding the outcome of settlement discussions, the likelihood of possible further discussions, and any help the Court may provide with regard to settlement negotiations, by 7 days after the settlement conference.

Summary: Counsel must file a Joint Report describing the outcome of settlement discussions, the likelihood of further discussions, and any help the Court may provide with settlement negotiations.

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Civil cases

Applies to

Witness list ?

They must be in the format specified in Local Rule 16-5, and must also include for each witness (i) a brief description of the testimony, (ii) what makes the testimony unique, and (iii) a time estimate in hours for direct and cross-examination (separately stated).

Summary: Witness lists must include, for each witness, a brief description of the testimony, what makes the testimony unique, and separate time estimates in hours for direct and cross-examination.

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Civil cases

Applies to

Joint exhibit list ?

It must be in the format specified in Local Rule 16-6, and shall include an additional column stating any objections to authenticity and/or admissibility, and the reasons for the objections. Please follow the template posted to Judge Scarsi's webpage.

Summary: The Joint Exhibit List must include an additional column stating any objections to authenticity and/or admissibility and the reasons for the objections.

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Civil cases

Applies to

Jury instructions

2 weeks (14 days) before FPTC: counsel shall file their (1) Joint/Agreed Proposed Jury Instructions and their (2) Disputed Jury Instructions. If the parties disagree on any proposed jury instructions, they shall file: (i) 1 set of Joint/Agreed Proposed Jury Instructions to which all parties agree; and (ii) 1 set of Disputed Jury Instructions, which shall include a "redline" of any disputed language and/or the factual or legal basis for each party's position as to each disputed instruction.

Summary: At 14 days before the FPTC, parties must file one set of Joint/Agreed Proposed Jury Instructions and one set of Disputed Jury Instructions that includes a redline of disputed language and/or the factual or legal basis for each party's position.

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Civil cases

Applies to

Proposed jury instructions ?

Index: The Proposed 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: The Proposed Jury Instructions must include an index listing each instruction's number, title, source and relevant case citations, and page number.

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Civil cases

Applies to

Competing verdict forms

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 verdict form; (ii) a "redline" of any disputed language; and (iii) the factual or legal basis for each party's respective position if the entire form is being disputed.

Summary: If the parties cannot agree on a verdict form, they must file a single document titled 'Competing Verdict Forms' containing their respective proposed forms, a redline of disputed language, and the factual or legal basis for each party's position.

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Civil cases

Applies to

Trial exhibits ?

Must include

case number

The original set of exhibits shall have 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 counsel may print their own exhibit tags using Forms G-14A and G-14B on the "Court Forms" section of the Court's website.

Summary: Original-set exhibits require official exhibit tags (yellow for plaintiff, blue for defendant) affixed to the front upper right-hand corner stating case number, case name, and exhibit number, obtained from the Clerk's Office or printed using Forms G-14A/G-14B.

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Civil cases

Applies to

First day of trial materials ?

Counsel must present these materials to the CRD on the first day of trial: 1. The two sets of exhibit binders (one original, one copy) described above. 2. Any deposition transcripts to be used at trial, either as evidence or for impeachment. These lodged depositions are for the Court's use; counsel must bring additional copies during trial for witnesses' and their own use.

Summary: On the first day of trial, counsel must present the CRD with both sets of exhibit binders and any deposition transcripts to be used at trial, bringing additional copies for witnesses and themselves.

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Applies to

Pretrial filings ?

File Memorandum of Contentions of Fact and Law, Exhibit and Witness Lists, Status Report regarding settlement, and all Motions in Limine

Summary: By the scheduled pretrial deadline, parties must file a Memorandum of Contentions of Fact and Law, exhibit and witness lists, a status report regarding settlement, and all motions in limine.

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Applies to

Pretrial filings ?

Lodge Pretrial Conference Order; file agreed set of Jury Instructions and Verdict forms, statement regarding Disputed Instructions and Verdict Forms, and Oppositions to Motions in Limine

Summary: By the scheduled pretrial deadline, parties must lodge the Pretrial Conference Order and file the agreed set of jury instructions and verdict forms, a statement regarding disputed instructions and verdict forms, and oppositions to motions in limine.

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Applies to

Pretrial documents ?

Must include

proposed order ?

STRICT COMPLIANCE WITH LOCAL RULE 16 IS REQUIRED. THIS ORDER SETS FORTH SOME DIFFERENT AND SOME ADDITIONAL REQUIREMENTS. THIS COURT DOES NOT EXEMPT PRO PER PARTIES FROM THE REQUIREMENTS OF RULE 16. Carefully prepared memoranda of contentions of fact and law, witness lists, a joint exhibit list, and a proposed final pretrial conference order shall be submitted in accordance with the Rules, and the format of the proposed final pretrial conference order shall conform to the format set forth in Appendix A to the Local Rules. Failure to comply with these requirements may result in the final pretrial conference being taken off-calendar or continued, or in other sanctions.

Summary: Pretrial documents (memoranda of contentions of fact and law, witness lists, joint exhibit list, and proposed final pretrial conference order) must be submitted in strict compliance with Local Rule 16, which applies to pro per parties; noncompliance may result in the final pretrial conference being taken off-calendar or continued, or in other sanctions.

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Applies to

Witness list

In addition to the requirements of Local Rule 16, the witness lists must include a brief description (one or two paragraphs) of the testimony and a time estimate for both direct and cross-examination (separately stated).

Summary: Witness lists must include a brief description (one or two paragraphs) of the testimony and a time estimate for both direct and cross-examination, stated separately.

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Applies to

Motion in limine

Each party is limited to five (5) motions in limine, unless the Court grants leave to file additional motions.

Summary: Each party may file at most five motions in limine unless the Court grants leave to file additional motions.

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Applies to

Joint jury instructions ?

At the time of filing the proposed final pretrial conference order, counsel shall file with the Court a JOINT set of jury instructions on which there is agreement. All blanks in standard forms should be filled in. The Court expects counsel to agree on the substantial majority of jury instructions, particularly when pattern or model instructions provide a statement of applicable law.

Summary: When filing the proposed final pretrial conference order, counsel must file a joint set of agreed jury instructions with all blanks in standard forms filled in.

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Applies to

Unilateral jury instructions ?

If one party fails to comply with the provisions of this section, the other party must file a unilateral set of jury instructions.

Summary: If one party fails to comply with the jury instruction provisions, the other party must file a unilateral set of jury instructions.

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Applies to

Disputed jury instructions ?

At the same time, each party shall file its proposed jury instructions that are objected to by any other party.

Summary: Each party must simultaneously file its proposed jury instructions that are objected to by any other party.

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Applies to

Disputed jury instructions ?

Each disputed instruction must have attached a short statement (one or two paragraphs), including points and authorities, in support of the instruction and a brief statement, including points and authorities, in support of any objections. If applicable, a proposed alternative instruction must be provided.

Summary: Each disputed jury instruction must include a short statement with points and authorities supporting the instruction, a brief statement with points and authorities supporting objections, and a proposed alternative instruction if applicable.

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Applies to

Requested jury instructions ?

Each requested instruction shall (a) cite the authority or source of the instruction, (b) be set forth in full, (c) be on a separate page, (d) be numbered, (e) cover only one subject or principle of law, and (f) not repeat principles of law contained in any other requested instruction.

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

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Applies to

Jury instructions

Therefore, in addition to the copies described above, the Chambers email version must contain a "clean" set of jury instructions, containing only the text of the instruction (one per page) with the caption "Instruction No. __" at the top (eliminating titles, supporting authority, etc.).

Summary: The Chambers email version of the jury instructions must include a clean set containing only the text of each instruction, one per page, captioned 'Instruction No. __' at the top.

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Applies to

Jury instruction index ?

Counsel must provide an index of all instructions submitted, which must include the following: a. the number of the instruction; b. the title of the instruction; c. the source of the instruction and any relevant case citations; and d. the page number of the instruction.

Summary: Counsel must provide an index of all submitted jury instructions listing each instruction's number, title, source with case citations, and page number.

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Applies to

Exhibits

All of the exhibits (except those to be used for impeachment only), with official exhibit tags attached and bearing the same number shown on the exhibit list. Exhibit tags may be obtained from the Clerk's Office Window, 4th Floor, Mendez United States Courthouse, located at 350 West First Street, Los Angeles, California 90012. Digital exhibit tags are also now 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.

Summary: All exhibits (except impeachment-only exhibits) must have official exhibit tags attached bearing the same number shown on the exhibit list; tags may be obtained from the Clerk's Office Window or via digital Forms G-14A/G-14B on the Court's website.

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Applies to

Exhibit list

A copy of the exhibit list with all admitted exhibits will be given to the jury during deliberations. Counsel shall review and approve the exhibit list with the CRD before the list is given to the jury.

Summary: Counsel must review and approve the exhibit list with the courtroom deputy (CRD) before the list is given to the jury during deliberations.

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Applies to

Discovery document ?

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.

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Applies to

Papers presented to court ?

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.

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Applies to

Declaration certifying ai use or non use ?

Must include

ai disclosure ?

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.

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Applies to

Motion pleading or other paper

Must include

ai disclosure ?

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.

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Applies to

Motion for review reconsideration ?

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.

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Applies to

Remote appearance application ?

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.

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Applies to

Motion

Must include

ai disclosure ?

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.

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Applies to

Motion to amend

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.

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Applies to

Summary judgment motion ?

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.

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Applies to

Opposition separate statement of undisputed facts ?

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.

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Applies to

Additional material facts separate statement ?

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.

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Applies to

Summary judgment evidence ?

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.

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Applies to

Documentary evidence

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.

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Applies to

Separate statement of undisputed facts ?

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.

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Applies to

Motion

Must include

proposed order

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.

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Applies to

Ex parte application

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.

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Applies to

Ex parte application notice ?

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.

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Applies to

Application for emergency or provisional relief ?

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.

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Applies to

Stipulation and order

Must include

proposed order ?

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.

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Applies to

Scheduling conference submissions ?

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.

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Applies to

Request to appear via zoom

Must include

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.

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

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Applies to

Joint witness list

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.

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Applies to

Joint exhibit list

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.

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Applies to

Jury instructions

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.

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Applies to

Jury instructions

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.

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Applies to

Proposed jury instructions ?

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.

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Applies to

Proposed jury instructions

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.

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Applies to

Proposed jury instructions ?

Counsel also shall list the instructions in the order they will be given and indicate whether the instruction shall be read before opening statements, during trial, or before closing arguments.

Summary: Counsel must list proposed jury instructions in the order they will be given and indicate whether each will be read before opening statements, during trial, or before closing arguments.

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Applies to

Proposed verdict form ?

The parties shall make every effort to agree on a general or special verdict form before submitting proposals to the Court. The parties shall file and email to Chambers a proposed joint general or special verdict form fourteen (14) days before the FPTC.

Summary: Parties must make every effort to agree on a verdict form and must file and email to Chambers a proposed joint general or special verdict form 14 days before the FPTC.

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Applies to

Competing verdict forms

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.

Summary: If parties cannot agree on a verdict form, they must file and email to Chambers a single document titled 'Competing Verdict Forms' containing each party's proposed form, a redline of disputed language, and the factual or legal basis for each position.

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Applies to

Joint statement of the case

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.

Summary: In jury trials, parties must file and email to Chambers a Joint Statement of the Case 14 days before the FPTC for the Court to read to prospective jurors.

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Applies to

Trial exhibits ?

The parties must review the exhibit list and exhibit binders with the Courtroom Deputy Clerk before the admitted exhibits will be given to the jury.

Summary: The parties must review the exhibit list and exhibit binders with the Courtroom Deputy Clerk before admitted exhibits will be given to the jury.

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Applies to

Proposed findings conclusions ?

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.

Summary: In bench trials requiring findings of fact and conclusions of law, each party must file and email to Chambers its Proposed Findings of Fact and Conclusions of Law in Local Rule 52-3 format no later than 28 days before the FPTC.

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Applies to

Proposed findings conclusions ?

Notwithstanding Local Rule 52, for any matter requiring findings of fact and conclusions of law, unless otherwise expressly ordered by the Court, counsel will also be required to file Proposed Findings of Fact and Conclusions of Law after the conclusion of the trial.

Summary: Unless otherwise expressly ordered by the Court, counsel must also file Proposed Findings of Fact and Conclusions of Law after the conclusion of trial, notwithstanding Local Rule 52.

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Applies to

Proposed findings conclusions ?

The proposed Findings of Fact must include citations to admitted evidence. Where witness trial testimony is necessary to establish a given fact, the party must obtain a transcript of the proceedings and file relevant excerpts of those transcripts with the Proposed Findings of Fact and Conclusions of Law.

Summary: Proposed findings must cite admitted evidence, and where witness trial testimony is needed to establish a fact, the party must obtain a transcript and file relevant transcript excerpts with the proposed findings.

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Applies to

Declarations of direct testimony ?

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.

Summary: When ordered by the Court, each party must file and email to Chambers declarations of direct testimony for each witness it intends to call at trial at least 28 days before the FPTC.

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Applies to

Evidentiary objections

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.

Summary: If direct-testimony declarations are filed, each party must file and email to Chambers any evidentiary objections to other parties' declarations at least 14 days before the FPTC.

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Applies to

Case specific glossary

The parties must provide a case-specific glossary for the Court Reporter that includes applicable medical, scientific, or technical terms, jargon, the names and spellings of case names likely to be cited, street/city/country names, all parties/agents/departments/entities involved in the case, case-specific terminology. The case-specific glossary shall be filed and emailed in Word version to Chambers no later than the Friday before trial.

Summary: The parties must file and email a Word-version case-specific glossary for the Court Reporter containing technical terms, jargon, case names, place names, parties/entities, and case-specific terminology.

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Applies to

Trial exhibits

Trial exhibits that consist of documents and photographs must be submitted to the Court in the following two ways. First, the parties shall provide one set of binders containing a joint submission of exhibits on the first day of trial. Second, the parties shall jointly submit either a flash drive, hard drive, or other easily accessible portable storage device that contains the parties' joint submission of exhibits.

Summary: Document and photograph trial exhibits must be submitted jointly in two ways: one set of exhibit binders on the first day of trial and a jointly submitted portable storage device (flash drive, hard drive, or similar).

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Applies to

Joint exhibit list

The parties shall not provide separate exhibit lists. 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.

Summary: Parties may not file separate exhibit lists; instead a single joint exhibit list complying with Local Rule 16-6.1 must be filed 28 calendar days before the Final Pretrial Conference.

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Criminal cases

Applies to

Joint statement of case ?

Counsel shall also file a Joint Statement of the Case, which the Court will read to prospective jurors prior to the commencement of voir dire.

Summary: Counsel must file a Joint Statement of the Case that the Court will read to prospective jurors before voir dire.

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Criminal cases

Applies to

Supplemental brief

No supplemental brief shall be filed without prior leave of court.

Summary: Supplemental briefs may not be filed without prior leave of court.

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Criminal cases

Applies to

Motion in limine ?

Must include

certificate of conference ?

The motion papers must include a declaration showing a good faith meet and confer effort.

Summary: Motion in limine papers must include a declaration showing a good faith meet and confer effort.

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Criminal cases

Applies to

Motion in limine

Neither party may file more than five (5) Motions in Limine absent leave of Court upon a showing of good cause, and leave of Court will be granted sparingly. Motions in Limine in excess of a party’s first five will be stricken.

Summary: Each party is limited to five motions in limine; excess motions will be stricken, and further leave is granted sparingly.

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Criminal cases

Applies to

Jury instructions

An index page shall accompany all jury instructions submitted to the Court. The index page shall indicate the following: a. The number of the instruction; b. A brief title of the instruction; c. The source of the instruction; and d. The page number of the instruction.

Summary: All jury instructions submitted to the Court must be accompanied by an index page listing each instruction's number, brief title, source, and page number.

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Criminal cases

Applies to

Jury instructions ?

Must include

caption

One or more copies of the instructions will be given to the jury during deliberations. Accordingly, counsel shall summit a “clean” set of all instructions, containing only the text of each instruction, set forth in full on each page, with the caption “Court’s Instruction No. ____” (eliminating supporting authority, indication of party proposing, etc.).

Summary: Counsel must submit a clean set of jury instructions for the jury containing only each instruction's full text on a page with the caption "Court's Instruction No. ____", without supporting authority or party attribution.

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Criminal cases

Applies to

Motion for juror questionnaire ?

If counsel wish to submit a written questionnaire to prospective jurors, a motion shall be made in writing, with the proposed questionnaire attached, no later than eight weeks before the trial date. The Court does not routinely use questionnaires. Counsel should attempt to discuss this issue and reach a proposed agreement before submitting the motion to the Court.

Summary: A motion for a written prospective juror questionnaire must be made in writing with the proposed questionnaire attached, filed no later than eight weeks before trial, after counsel attempt to reach agreement.

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Applies to

Pending motion

Any pending motions must be re-noticed in accordance with Local Rule 6-1.

Summary: Motions pending at the time of removal must be re-noticed in this Court in accordance with Local Rule 6-1.

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Applies to

Motion

Must include

proposed order

Each party filing a motion, opposing a motion, or seeking the determination of any matter must serve and electronically lodge a proposed order setting forth the relief or action sought and a brief statement of the

Summary: Any party filing or opposing a motion must serve and electronically lodge a proposed order.

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Applies to

Proposed order

Must include

proposed order

A template for proposed orders is available on Judge Sykes’ webpage at https://apps.cacd.uscourts.gov/Jps/honorable-sunshine-s-sykes. The parties must use this template. Failure to submit a proposed order via email in Word format may result in the Court striking the motion, application, or stipulation without consideration of the request on its merits.

Summary: Parties must use the Judge Sykes proposed order template, and failure to email a proposed order in Word format may result in the motion being struck without consideration.

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Applies to

Ex parte application

Counsel are reminded that ex parte applications are solely for extraordinary relief. Applications that do not explain why ex parte relief is justified and/or fail to satisfy the requirements established under Local Rule 7-19 will not be considered. Sanctions may be imposed for misuse of ex parte applications.

Summary: Ex parte applications are solely for extraordinary relief; applications that do not justify relief or satisfy Local Rule 7-19 will not be considered, and misuse may result in sanctions.

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Applies to

Ex parte application

Must include

local rule certificate ?

Counsel must include a statement in the ex parte application a statement to the following effect: “This ex parte application complies with Local Rule 7-19’s requirements.”

Summary: Every ex parte application must include the statement: 'This ex parte application complies with Local Rule 7-19's requirements.'

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Applies to

Continuance request ?

Must include

certificate of conference ?

Counsel are required to meet and confer with opposing counsel regarding the substance of the continuance before filing the anticipated request, and any request must include a statement of compliance with Local Rule 7-3 (see supra VII.A). Failure to meet and confer in good faith in compliance with the Local Rules and this Order may result in denial of the request for continuance.

Summary: Counsel must meet and confer on the continuance before filing, and the request must include a statement of Local Rule 7-3 compliance or risk denial.

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Applies to

Stipulation to amend pleading ?

Must include

proposed order

Parties filing an amended pleading pursuant to Federal Rule of Civil Procedure 15(a)(2) must file the stipulation to amend the pleading. The parties must attach to the stipulation a clean and redlined version of the proposed amended pleading and a proposed order. The parties’ proposed order should address any hearing affected by the filing of the amended pleading.

Summary: Stipulations to amend under FRCP 15(a)(2) must attach clean and redlined versions of the proposed amended pleading plus a proposed order addressing any affected hearing.

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Applies to

Discovery related document

All discovery-related 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.

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Applies to

Joint rule 26f report

the parties must file a Joint Rule 26(f) Report, which must include a completed Scheduling Worksheet that can be found at https://apps.cacd.uscourts.gov/JpsApi/file/38193e58-42e6-4025-9ec4-08df0dc2fdc2

Summary: The Joint Rule 26(f) Report must include a completed Scheduling Worksheet available at the court's provided URL.

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Applies to

Joint rule 26f report

The Joint Rule 26(f) Report must address the matters set forth in Federal Rule of Civil Procedure 26(f), as well as those enumerated in the Court’s Order Setting Scheduling Conference.

Summary: The Joint Rule 26(f) Report must address the matters in FRCP 26(f) and those enumerated in the Court's Order Setting Scheduling Conference.

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Applies to

Motion for review and reconsideration ?

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

Summary: A motion for review of a Magistrate Judge's ruling must identify the portions of the ruling that are clearly erroneous and contrary to law and must be supported by points and authorities.

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Applies to

Notice of motion

Must include

certificate of conference ?

The notice of motion or other request must include a statement of compliance with the meet and confer requirements set out in Local Rule 7-3. The Court may strike or deny a motion or other relief if counsel fails to meet and confer in good faith.

Summary: Every notice of motion or request must include a statement of compliance with the L.R. 7-3 meet and confer requirements, and the Court may strike or deny the motion if counsel failed to meet and confer in good faith.

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Applies to

Notice of motion

Must include

certificate of conference ?

Consistent with Local Rule 7-3, the moving party's Counsel is required to include the following statement in their notice of motion: "This motion is made following the conference of counsel pursuant to L.R. 7-3 which took place on (date)."

Summary: The notice of motion must contain the exact statement that the motion follows a conference of counsel under L.R. 7-3 held on a specified date.

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Applies to

Notice of motion ?

Must include

certificate of conference ?

In addition to the previous statement, this Court requires counsel to include: (1) the names of the counselor's present at the conference, (2) when the conference was held, (3) how long the conference lasted, (4) the manner in which the conference was held, (5) what issues were discussed, and (6) what issues the parties were unable to resolve.

Summary: The notice of motion must additionally state the names of counsel present, when and how long the conference was held, the manner in which it was held, what issues were discussed, and what issues remain unresolved.

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Applies to

Application to seal

Sealing must be justified for each individual item. Blanket claims of confidentiality will result in the application to seal being denied.

Summary: Each sealed item must be individually justified, and blanket claims of confidentiality will cause the application to seal to be denied.

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Applies to

Application to seal

Must include

certificate of conference ?

The parties must also meet and confer before filing an application to seal.

Summary: Parties must meet and confer before filing an application to seal.

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Applies to

Memorandum of points and authorities exceeding ten pages ?

Pursuant to Local Rule 11-8, all Memoranda of Points and Authorities exceeding ten (10) pages must be accompanied by a Table of Authorities and a Table of Contents.

Summary: Memoranda of Points and Authorities exceeding 10 pages must include a Table of Authorities and a Table of Contents.

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Applies to

Motion to amend

In addition to the requirements of Local Rule 15-1, all motions to amend pleadings must: (1) state the effect of the amendment; (2) be serially numbered to differentiate the amendment from previous amendments; and (3) identify the pages, line numbers, and wording of any proposed change or addition of material.

Summary: All motions to amend pleadings must state the effect of the amendment, be serially numbered, and identify the pages, line numbers, and wording of any proposed changes.

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Applies to

Motion to amend ?

Counsel must file a 'Notice of Lodging' attaching the proposed amended pleading as a document separate from the motion, as well as a 'redlined' version of the proposed amended pleading identifying all additions and deletions of material as an appendix to the moving papers.

Summary: Motions to amend must include a Notice of Lodging with the proposed amended pleading as a separate document and a redlined version as an appendix to the moving papers, applying equally to complaints, answers, cross-complaints, supplemental pleadings, and Rule 15(a)(1) amendments.

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Applies to

Motion for default judgment

Must include

proposed order

Any Motion for Default Judgment must be accompanied by a detailed proposed order that the Court can adopt.

Summary: Every motion for default judgment must be accompanied by a detailed proposed order that the Court can adopt.

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Applies to

Statement of genuine disputes ?

The opposing party may dispute all or only a portion of the statement, but if disputing only a portion, it must clearly indicate what portion is being disputed, followed by a brief citation to the opposing party’s evidence controverting the fact. 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 evidence, and describe the reason(s) the exhibit or evidence refutes the asserted fact. No legal argument should be set forth in this document.

Summary: Partial disputes must clearly identify the disputed portion with a citation to controverting evidence; each dispute must state why the fact is disputed, cite the evidence, and explain how it refutes the asserted fact, with no legal argument in the document.

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Applies to

Additional material facts

The opposing party may submit additional material facts that bear on or relate to the issues raised by the moving party, which must follow the format described above for the moving party’s separate statement. These additional facts must continue in sequentially numbered paragraphs with the evidence that supports each statement set forth in the right column.

Summary: The opposing party may submit additional material facts, which must follow the movant's separate statement format, continue the sequential paragraph numbering, and place supporting evidence in the right column.

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Applies to

Response to genuine disputes ?

With its reply, the moving party must file a response to the statement of genuine disputes of material fact and additional material facts. For each fact, the response must restate the allegedly undisputed fact and state whether the fact is disputed or undisputed by the opposing party. If the fact is undisputed, no further response is required.

Summary: The movant's reply must include a response to the statement of genuine disputes and additional material facts, restating each fact and stating whether it is disputed; undisputed facts require no further response.

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Applies to

Response to genuine disputes ?

If the fact is disputed, the response must restate the opposing party’s evidence and reason for disputing the asserted fact. The moving party may provide a response to the opposing party’s reason for dispute, including any reason why the evidence cited by the opposing party does not create a genuine dispute and/or any additional evidence relevant to the asserted fact. This response may either be presented in three columns, with the response appearing in the right column, or in two columns, with a response provided below each fact.

Summary: For disputed facts, the reply response must restate the opponent's evidence and reason for dispute, may rebut with argument or additional evidence, and may be presented in three columns or two columns with the response below each fact.

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Applies to

Response to genuine disputes ?

The response may also include any response to additional material facts asserted by the non-moving party, and this response must follow the format described above for the statement of genuine disputes of material fact. The response to these additional facts must continue in sequentially numbered paragraphs and must not

Summary: Any response to the non-moving party's additional material facts must follow the genuine disputes format and continue in sequentially numbered paragraphs (sentence continues beyond this excerpt).

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Applies to

Response separate statement ?

All facts asserted by either party, whether disputed or undisputed, and all supporting evidence cited, must be included in the response. Do not repeat descriptions of and citations to the evidence. If you have already described and cited the evidence once, simply refer to the earlier citation succinctly (e.g., “See supra, Fact #1.”).

Summary: Responses to the separate statement must include all facts asserted by either party and all supporting evidence cited, without repeating evidence descriptions and citations that can be cross-referenced (e.g., 'See supra, Fact #1.').

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Applies to

Evidence summary judgment ?

No party must 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 must not be submitted in support of or in opposition to a motion for summary judgment.

Summary: Parties must not submit evidence beyond the specific items needed to support or controvert proposed undisputed facts — entire deposition transcripts, entire interrogatory response sets, and non-specific documents must not be filed with a summary judgment motion.

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Applies to

Documentary evidence summary judgment ?

Documentary evidence for 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: Documentary evidence lacking a foundation stipulation must be accompanied by authentication testimony via declaration or properly authenticated deposition transcript.

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Applies to

Evidentiary objections

Must include

proposed order

A proposed order must be filed and attached to the evidentiary objections as a separate

Summary: A proposed order must be filed and attached to the evidentiary objections as a separate document (sentence truncated in source excerpt).

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Applies to

Summary judgment motion ?

Counsel are discouraged from filing motions for summary judgment or partial summary judgment on any other issue. If they choose to do so, they must distinguish Kearney v. Standard Insurance Co., 175 F.3d 1084, 1093-95 (9th Cir. 1999) (en banc) in the moving papers and explain why summary judgment is not precluded.

Summary: In ERISA cases, counsel are discouraged from filing summary judgment motions on issues other than the standard of review, discovery, and the scope of the administrative record; if they do, the moving papers must distinguish Kearney v. Standard Insurance Co. and explain why summary judgment is not precluded.

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Applies to

Bankruptcy appeal ?

Counsel must comply with the Notice Regarding Appeal from Bankruptcy Court issued at the time the appeal is filed in the District Court.

Summary: Counsel handling bankruptcy appeals must comply with the Notice Regarding Appeal from Bankruptcy Court issued when the appeal is filed in the District Court.

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Applies to

Joint rule 26f report and pretrial documents ?

If, without satisfactory explanation, counsel fail to file the required Joint Rule 26(f) Report or the required pretrial documents, fail to appear at any scheduled proceeding, or otherwise fail to comply with the Court’s orders or rules, the Court must take any action it deems appropriate, including: Where the failure occurs on the part of the plaintiff, dismissal of the case for failure to prosecute; Where the failure occurs on the part of the defendant, striking the answer resulting in default; and/or Imposing monetary sanctions against the offending party and counsel.

Summary: Counsel must file the required Joint Rule 26(f) Report and pretrial documents; failure to do so (or to appear/comply) without satisfactory explanation may result in dismissal, default, or monetary sanctions.

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Applies to

Discovery motion ?

All documents relating to discovery matters must include the words “DISCOVERY MATTER” in the caption to ensure proper routing.

Summary: Discovery-related documents must include the words “DISCOVERY MATTER” in the caption for proper routing.

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Applies to

Brief ?

Citations to cases must be in Bluebook format and must include pinpoint citations (citations to page numbers). Counsel may omit parallel citations. For unreported cases, the Court prefers Westlaw citations.

Summary: Case citations must be in Bluebook format with pinpoint citations; parallel citations may be omitted; Westlaw citations preferred for unreported cases.

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Applies to

Brief ?

Statutes should be cited in accordance with the Bluebook. Statutory references should identify with specificity the sections and subsections referenced (e.g., “Plaintiff alleges that Defendant infringed on his trademark in violation of the Lanham Act, 15 U.S.C. § 1114(a).” Avoid statutory citations that do not specifically indicate the appropriate section and subsection (e.g., “Plaintiff alleges that Defendant infringed on his trademark in violation of the Lanham Act, 15 U.S.C. §§ 1051, et. seq.”). Citations to treatises, manuals, and other materials should include the volume, section, and pages being referenced.

Summary: Statutes must be cited per the Bluebook with specific sections/subsections; treatise and manual citations must include volume, section, and pages.

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Applies to

Evidence ?

The Court will accept counsel's authentication of deposition transcripts, written discovery responses, and documents received in discovery if the fact that the document was in the opponent's possession is of independent significance.

Summary: Court will accept counsel's authentication of certain discovery documents if possession is of independent significance.

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Applies to

Objection

If a party disputes a fact based on an evidentiary objection that cannot be overcome, the ground of the objection should be stated in the Statement but not argued in that document. The ground must be argued in a separate document.

Summary: Evidentiary objection grounds must be stated in the Statement but argued in a separate document.

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Applies to

Objection

Do not submit blanket or boilerplate objections to an opponent's evidence. They will be disregarded.

Summary: Blanket or boilerplate objections to evidence will be disregarded.

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Applies to

Protective order

Proposed protective orders pertaining to discovery must be submitted to the assigned Magistrate Judge.

Summary: Proposed discovery protective orders must be submitted to the assigned Magistrate Judge.

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Applies to

Reply

Absent leave of Court, the Court will not consider reply papers in support of an ex parte application.

Summary: Reply papers in support of ex parte applications are not considered absent leave of Court.

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Applies to

Reply ?

As with other ex parte applications, replies are not permitted without leave of Court, and do not call the CRD for status.

Summary: Replies in support of TRO applications are not permitted without leave of Court, and counsel must not call the CRD for status.

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Applies to

All papers

Counsel must include on all papers their email address, telephone number, and fax number to facilitate communication with the CRD.

Summary: All papers must include counsel's email address, telephone number, and fax number.

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Applies to

Any filing with court template ?

If the Court has provided a template for any filing, the parties must follow it.

Summary: Parties must follow any court-provided template for filings.

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Applies to

Pleading

Must include

caption

The caption title of every pleading shall contain the name of the first-listed defendant if the pleading applies to all defendants. If the document applies only to certain defendants, the caption shall list the name of the first defendant followed by the name(s) and number(s) of the remaining defendants involved (in the order listed on the docket). In an effort to create a docket that is clear and that can be searched easily, the title of every pleading shall include the name of the defendant(s) to which it refers. However, if the pleading applies to all defendants or if there is only a single defendant, the name(s) of the defendant(s) do not need to appear in the title.

Summary: Every pleading's caption/title must identify the defendant(s) it concerns — the first-listed defendant if it applies to all defendants, or the first defendant plus the names and docket numbers of the remaining involved defendants if it applies only to certain defendants — except that defendant names need not appear in the title when the pleading applies to all defendants or there is a single defendant.

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Applies to

Government pretrial submissions ?

The Government shall specify, after a meet and confer, whether the parties agree or disagree on matters (1) through (4).

Summary: After a meet and confer, the Government must specify whether the parties agree or disagree on pretrial matters (1) through (4).

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Applies to

Exhibit list

The exhibit list shall comply with Local Civil Rule 16-6.1.

Summary: The exhibit list must comply with Local Civil Rule 16-6.1.

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Applies to

Notice of disputed exhibits

Counsel shall file a "Notice of Disputed Exhibits," if applicable, which shall set forth the basis for any disputed exhibit(s).

Summary: Counsel must file a Notice of Disputed Exhibits, if applicable, setting forth the basis for each disputed exhibit.

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Applies to

Glossary of terms

At least one week before trial, the parties must confer and file a glossary of terms for the court reporter that includes applicable medical, scientific, or technical terms, gang terms, slang, the names and spellings of names likely to be cited, and any other case-specific terminology.

Summary: The glossary of terms must include medical, scientific, or technical terms, gang terms, slang, names and spellings likely to be cited, and other case-specific terminology.

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Applies to

Brief ?

Citations to Other Sources. Statutory references should identify with specificity the sections and subsections referenced. Citations to treatises, manuals, and other materials should include the volume, section, and pages being referenced.

Summary: Statutory citations must identify the specific sections and subsections, and citations to treatises, manuals, and other materials must include the volume, section, and pages referenced.

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Applies to

Application to appear telephonically

The Court seldom permits telephonic appearances. The Court strongly prefers counsel to appear in person. If exceptional circumstances exist, counsel may file an application to appear telephonically detailing such circumstance.

Summary: Telephonic appearances are disfavored and rarely permitted; counsel must file an application detailing the exceptional circumstances to appear telephonically.

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Applies to

Notice of motion

The Court may vacate the hearing on a motion for default judgment if no opposition is timely filed, and the notice of motion should so state.

Summary: The notice of motion for default judgment should state that the Court may vacate the hearing if no opposition is timely filed.

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Applies to

Joint brief

The Joint Brief should contain the following: (1) a table of contents; (2) a table of authorities; (3) an optional brief introduction section stated jointly or, if stated separately by each party, stated under an appropriate subheading identifying the party (e.g., "ACME Co.'s Introduction" or "Defendant's Introduction"); (4) a statement of facts section stated jointly or, if stated separately by each party, stated under an appropriate subheading identifying the party (e.g., "ACME Co.'s Statement of Facts" or "Defendant's Statement of Facts"); (5) an analysis or argument section that sets forth the arguments organized by issue that present the parties' competing positions on an issue-by-issue basis.

Summary: The Joint Brief must contain a table of contents, table of authorities, an optional introduction, a statement of facts, and an issue-by-issue analysis/argument section, with any party-separate sections under subheadings identifying the party.

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Applies to

Schedule worksheet ?

Please complete this worksheet jointly and file it with your Joint Rule 26(f) Report.

Summary: The Schedule of Pretrial and Trial Dates Worksheet must be completed jointly by the parties and filed with the Joint Rule 26(f) Report.

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Applies to

Joint rule 26f report ?

A statement that discovery will be conducted as to all claims and defenses, or other vague description, is not acceptable.

Summary: Vague discovery plan statements, such as that discovery will be conducted as to all claims and defenses, are not acceptable in the Joint Rule 26(f) Report.

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Applies to

Joint rule 26f report ?

For conflict purposes, corporate parties must identify all subsidiaries, parents, and affiliates.

Summary: For conflict purposes, corporate parties must identify all subsidiaries, parents, and affiliates in the Joint Rule 26(f) Report.

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Applies to

Joint rule 26f report

If the time estimate for trial given in the Joint Rule 26(f) Report exceeds four (4) court days, counsel shall be prepared to discuss in detail the basis for the estimate.

Summary: Counsel must be prepared to explain in detail the basis for any reported trial-time estimate exceeding four court days.

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Applies to

Joint rule 26f report ?

Whether the parties agree to try the case (either by jury or court trial) before a Magistrate Judge. See 28 U.S.C. § 636 (requiring party consent). The parties are strongly encouraged to consider consenting to trial before a Magistrate Judge. The parties are free to select from among all Magistrate Judges available for this purpose, not just the Magistrate Judge assigned to the parties’ case.

Summary: The report must state whether the parties consent to trial before a Magistrate Judge; consent is voluntary but strongly encouraged, and parties may choose any available Magistrate Judge.

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Applies to

Schedule worksheet ?

The parties must make every effort to agree on dates or the Court will set them.

Summary: Parties must make every effort to agree on the worksheet dates, failing which the Court will set the dates.

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Applies to

Stipulation and proposed order

Must include

proposed order

If the parties wish the Court to set dates in addition to those on the Worksheet, they may so request by a separate stipulation and proposed order. Additional hearings are often appropriate for class actions, patent cases, and cases for benefits under the Employee Retirement Income Security Act of 1974 (“ERISA”).

Summary: Requests for dates beyond the worksheet must be made by separate stipulation and proposed order, and additional hearings are often appropriate in class action, patent, and ERISA cases.

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Applies to

Joint rule 26f report ?

14. Other Issues. A statement of any other issues affecting case management, including unusually complex technical issues, related litigations, disputes over protective orders, extraordinarily voluminous document production, discovery in foreign jurisdictions, and any proposals concerning severance, bifurcation, or other ordering of proof.

Summary: The Joint Rule 26(f) Report must include a statement of any other issues affecting case management, such as complex technical issues, related litigations, protective order disputes, voluminous document production, foreign discovery, and severance or bifurcation proposals.

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Applies to

Stipulation and proposed order

Must include

proposed order

The parties may seek dates for additional events by filing a separate stipulation and proposed order.

Summary: Requests for additional schedule event dates must be made by filing a separate stipulation and proposed order.

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Civil cases

Applies to

Stipulation and proposed order

Must include

proposed order

If the parties prefer an ADR procedure other than the one ordered by the Court, they shall file a Stipulation and Proposed Order. This request will not necessarily be granted.

Summary: Parties seeking an ADR procedure other than the one ordered by the Court must file a Stipulation and Proposed Order, and the request will not necessarily be granted.

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Civil cases

Applies to

Proposed final pretrial conference order ?

In specifying the surviving pleadings under section 1, 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." Also, in multiple-party cases where not all claims or counterclaims will be prosecuted against all remaining parties on the opposing side, please specify to which party each claim or counterclaim is directed.

Summary: The Proposed FPTCO must identify which claims or counterclaims have been dismissed or abandoned and, in multiple-party cases, specify to which party each claim or counterclaim is directed.

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Civil cases

Applies to

Proposed final pretrial conference order ?

The parties must attempt to agree on and set forth as many uncontested facts as possible. The Court will usually read the uncontested facts to the jury at the start of trial. A carefully drafted and comprehensively stated stipulation of facts will shorten the trial and increase jury understanding of the case.

Summary: The parties must attempt to agree on and set forth as many uncontested facts as possible in the Proposed FPTCO, which the Court will usually read to the jury at the start of trial.

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Civil cases

Applies to

Motion in limine

Motions in limine should address specific issues (e.g., not “to exclude all hearsay”). Motions in limine should not be disguised motions for summary adjudication of issues.

Summary: Motions in limine should address specific disputed issues rather than broad categories of evidence and should not be disguised motions for summary adjudication.

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Civil cases

Applies to

Jury instructions

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 this case. Where California law applies, counsel should use the current edition of the Judicial Council of California Civil Jury Instructions ("CACI"). If neither applies, counsel should consult the current edition of O'Malley, et al., Federal Jury Practice and Instructions. Counsel may submit alternatives to these instructions only if there is a reasoned argument that they do not properly state the law or that they are incomplete. The Court seldom if ever gives instructions derived solely from cases.

Summary: Jury instructions should come from the Ninth Circuit Model Instructions, CACI (for California law), or O'Malley's Federal Jury Practice and Instructions, and alternatives are allowed only with a reasoned argument that they misstate or incompletely state the law.

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Civil cases

Applies to

Interrogatory answers compilation ?

Whenever counsel expects to offer a group of answers to interrogatories or requests for admissions extracted from one or more lengthy documents, counsel should prepare a new document listing each question and answer and identifying the document from which it has been extracted.

Summary: When offering a group of answers to interrogatories or requests for admission extracted from lengthy documents, counsel should prepare a new document listing each question and answer and identifying the source document.

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Civil cases

Applies to

Trial exhibits copy set ?

The copy set of the exhibits shall not have official exhibit tags but must be indexed with tabs or dividers on the right side.

Summary: The copy set of exhibits must not have official exhibit tags but must be indexed with tabs or dividers on the right side.

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Applies to

Joint notice of trial estimate ?

No later than seven weeks prior to the Final Pretrial Conference, counsel must file joint notice of the then current estimate for trial, including the number of hours for testimony (see also ¶ II(A)(4), below).

Summary: The joint notice of trial estimate must state the then current estimate for trial, including the number of hours for testimony.

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Applies to

Motion in limine

Motions in limine should address specific issues

Summary: Motions in limine should address specific issues rather than broad or general requests (source text is truncated mid-example).

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Applies to

Alternative jury instructions ?

Counsel may submit alternatives to these instructions only if counsel has a reasoned argument that they do not properly state the law or they are incomplete.

Summary: Counsel may submit alternative jury instructions only with a reasoned argument that the instructions misstate the law or are incomplete.

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Applies to

Statement of the case

At the time of filing the proposed final pretrial conference order, counsel should file a jointly prepared one- or two-page statement of the case to be read by the Court to the prospective panel of jurors before commencement of voir dire.

Summary: Counsel must file a jointly prepared statement of the case (to be read to the prospective jury panel before voir dire) at the time of filing the proposed final pretrial conference order.

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Applies to

Extracted interrogatory answers ?

Whenever counsel expects to offer a group of answers to interrogatories or requests for admissions extracted from one or more lengthy documents, counsel should prepare a new document listing each question and answer and identifying the document from which it has been extracted. Copies of this new document should be given to the Court and opposing counsel.

Summary: Counsel offering extracted interrogatory or request-for-admission answers should prepare a new document listing each question and answer with its source document identified, and give copies to the Court and opposing counsel.

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Applies to

Documents filed in record ?

Lawyers and pro se litigants who use technology like ChatGPT, Google Bard, Bing AI Chat, or other generative artificial intelligence services to prepare documents that the parties file in the record in this case are cautioned that generative AI technologies sometimes may produce factually or legally inaccurate content.

Summary: Lawyers and pro se litigants using generative AI to prepare documents filed in this case are cautioned that AI may produce factually or legally inaccurate content.

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Applies to

Answer

Any answers filed in state court must be refiled in this Court as a supplement to the Notice of Removal.

Summary: In removed actions, answers filed in state court must be refiled in this Court as a supplement to the Notice of Removal.

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Applies to

Motion

Any pending motions must be re-noticed in accordance with the Local Rules.

Summary: Pending motions in removed actions must be re-noticed in accordance with the Local Rules.

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Applies to

Filed or lodged document

If a filed or lodged document has declarations, exhibits, or other attachments, each of these must be filed as a separately docketed attachment to the main docket entry with a description of the attachment (e.g., Dkt. 29-1 Smith Declaration).

Summary: Declarations, exhibits, and other attachments must each be filed as separately docketed attachments with a description.

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Applies to

Brief ?

Citations to case law must identify not only the case cited, but the specific page referenced. Citations to cases must be in Bluebook Westlaw citations.

Summary: Case law citations must identify both the case cited and the specific page referenced, and must be in Bluebook format with Westlaw citations (this sentence appears truncated in the source).

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Applies to

Motion evidence ?

Evidence submitted in support of or in opposition to a motion should be submitted either by way of stipulation or as exhibits to declarations sufficient to authenticate the proffered evidence, and should not be attached to the memorandum of points and authorities.

Summary: Evidence supporting or opposing a motion must be submitted by stipulation or as exhibits to authenticating declarations, and must not be attached to the memorandum of points and authorities.

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Applies to

Rule 26f report ?

Counsel should include their shared or separate views regarding a preference for the Court Mediation Panel or private mediation, and when the mediation should occur, in the written report required by Fed. R. Civ. P. 26(f) and Local Rule 26-1.

Summary: Counsel should include their views on preference for the Court Mediation Panel or private mediation and mediation timing in the Rule 26(f) report.

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Applies to

Proposed final pretrial conference order ?

In specifying the surviving pleadings under section 1 of the Proposed FPTCO, 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: The Proposed FPTCO must state which claims or counterclaims have been dismissed or abandoned and, in multiple-party cases, specify to which party or parties each claim or counterclaim is directed.

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Applies to

Proposed final pretrial conference order ?

The parties must attempt to agree on and set forth as many uncontested facts as possible. The Court will read the uncontested facts to the jury at the start of trial.

Summary: The parties must attempt to agree on and set forth as many uncontested facts as possible in the Proposed FPTCO, which the Court will read to the jury at the start of trial.

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Applies to

Proposed final pretrial conference order ?

In drafting the factual issues in dispute, the parties must state issues in ultimate fact form, not in the form of evidentiary fact issues. The issues of fact should track the elements of a claim or defense on which the jury will be required to make findings.

Summary: Disputed factual issues in the Proposed FPTCO must be stated in ultimate fact form and track the elements of the claims or defenses on which the jury will make findings.

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Applies to

Motion in limine

Motions in limine should address specific issues (e.g., not "to exclude all hearsay"). Motions in limine should not be disguised motions for summary adjudication of issues.

Summary: Motions in limine must be targeted at specific evidentiary issues and may not be used as disguised motions for summary adjudication.

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Applies to

Trial exhibits ?

Counsel shall confer so that there are no duplicate exhibits.

Summary: Counsel must confer to ensure there are no duplicate exhibits.

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Applies to

Jury instructions

If there are excessive or frivolous disagreements over jury instructions, the Court will order the parties to meet and confer immediately until they substantially narrow their disagreements.

Summary: Excessive or frivolous disputes over jury instructions will trigger an immediate court-ordered meet and confer until disagreements are substantially narrowed.

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Applies to

Trial exhibits ?

The parties must prepare additional copies of exhibits for their own use.

Summary: The parties must prepare additional copies of the exhibits for their own use.

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Applies to

Trial exhibits ?

The parties shall agree on exhibit numbers and shall share the same exhibit list.

Summary: The parties must agree on exhibit numbers and share the same exhibit list.

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Applies to

Notice of disputed exhibits

Counsel shall file a "Notice of Disputed Exhibits," if applicable, which shall set forth the basis for any disputed exhibit(s).

Summary: If any exhibits are disputed, counsel must file a Notice of Disputed Exhibits setting forth the basis for each disputed exhibit.

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Applies to

Discovery excerpts ?

Whenever counsel expects to offer a group of answers to interrogatories or requests for admissions 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. Copies of this new document must be provided to the Court and the opposing party.

Summary: Counsel offering extracted answers to interrogatories or requests for admissions must prepare a new document listing each question and answer with its source document and provide copies to the Court and the opposing party.

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Criminal cases

Applies to

Motion

Motions expected to take more than one hour of court time must include a time estimate beneath the hearing date on the face page of the motion.

Summary: Motions expected to take more than one hour of court time must include a time estimate on the face page beneath the hearing date.

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Criminal cases

Applies to

Motion in limine

Must include

caption

If counsel are unable to resolve their differences, they shall prepare a separate, sequentially-numbered Motion in Limine for each issue in dispute which contains a clear caption that identifies the moving party and the nature of the dispute (i.e., “Plaintiff’s Motion in Limine #1 to exclude the testimony of Defendant’s expert”).

Summary: Each disputed issue requires a separate, sequentially-numbered motion in limine with a clear caption identifying the moving party and the nature of the dispute.

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Criminal cases

Applies to

Motion in limine

Each Motion in Limine shall contain a clear identification of the testimony, exhibits, or other specific matters alleged to be inadmissible and/or prejudicial and a statement of the specific prejudice that will be suffered by the moving party if the motion is not granted.

Summary: Each motion in limine must identify the specific matters alleged to be inadmissible or prejudicial and state the specific prejudice the moving party would suffer if denied.

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Criminal cases

Applies to

Exhibit ?

No document shall be placed before a witness unless a copy has been provided to the Court.

Summary: Counsel may not place a document before a witness unless a copy has first been provided to the Court.

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Civil casesCourt notice

Applies to

Application for leave in camera review ?

Please note the warning message on the next screen: NO HEARING is required for this application, so DO NOT set a hearing date.

Summary: No hearing is required for the Application for Leave for In Camera Review, so no hearing date should be set.

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Civil cases

Applies to

Verdict form

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 verdict form; (ii) a “redline” of any disputed language; and (iii) the factual or legal basis for each party’s respective position.

Summary: If the parties cannot agree on a verdict form, they must file one document titled "Competing Verdict Forms" containing each party's proposed verdict form, a redline of disputed language, and the factual or legal basis for each position.

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Civil cases

Applies to

Proposed findings conclusions ?

its Proposed Findings of Fact and Conclusions of Law in the format specified in Local Rule 52-3.

Summary: Proposed Findings of Fact and Conclusions of Law must be formatted as specified in Local Rule 52-3.

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Civil cases

Applies to

Interrogatory answers document ?

Whenever counsel expects to offer a group of answers to interrogatories or requests for admissions 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. Copies of this new document must be provided to the Court and the opposing party.

Summary: Counsel offering excerpts from interrogatory or admission responses must prepare a new document listing each question and answer with its source and provide copies to the Court and the opposing party.

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Applies to

Ex parte application ?

To justify ex parte relief, the moving party must make two showings: (1) “the evidence must show that the moving party’s cause will be irreparably prejudiced if the underlying motion is heard according to regular noticed motion procedures”; and (2) “it must be established that the moving party is without fault in creating the crisis that requires ex parte relief, or that the crisis occurred as a result of excusable neglect.”

Summary: To justify ex parte relief, the movant must show both irreparable prejudice if the motion is heard on regular notice and that the movant is without fault (or the crisis arose from excusable neglect).

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Applies to

Joint rule 26f report

In their Joint Rule 26(f) Report, counsel should state their preferred ADR procedure.

Summary: Counsel should state their preferred ADR procedure in the Joint Rule 26(f) Report.

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Applies to

Brief ?

Citations to case law must identify the case cited and the specific page

Summary: Citations to case law in briefing must identify the case cited and the specific page cited.

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Applies to

Motion for default judgment ?

Moreover, parties are expected to substantively and clearly address the factors outlined in Eitel v. McCool, 782 F.2d 1470, 1471 72 (9th Cir. 1986).

Summary: Motions for default judgment must substantively and clearly address the Eitel v. McCool factors.

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Applies to

Statement of uncontroverted facts ?

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: Factual statements in the separate statement should be set out in sequentially numbered paragraphs, each narrowly focused on a single subject and stated as concisely as possible.

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Applies to

Separate statement ?

The “Conclusions of Law” portion of the statement should be inserted after the statement of uncontroverted facts. For example: “Plaintiff’s Claim for _____ Is Barred by the Applicable Statute of Limitations.”

Summary: The Conclusions of Law portion should be inserted after the statement of uncontroverted facts, using headings such as 'Plaintiff's Claim for _____ Is Barred by the Applicable Statute of Limitations.'

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Applies to

Evidence summary judgment ?

Evidence submitted in support of or in opposition to a motion for summary judgment should be submitted either by way of stipulation or as exhibits to declarations sufficient to authenticate the proffered evidence and should not be attached to the memorandum of points and authorities.

Summary: Summary judgment evidence must be submitted by stipulation or as exhibits to authenticating declarations, and must not be attached to the memorandum of points and authorities.

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Applies to

Joint status report

Because the ordinary pretrial and trial schedule does not apply to these ERISA cases, the parties need only submit a Joint Status Report identifying any special issues that should be considered.

Summary: In ERISA cases, the ordinary pretrial and trial schedule does not apply and the parties need only submit a Joint Status Report identifying any special issues for consideration.

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Applies to

All papers

To facilitate communication with the CRD, counsel should list their email addresses along with their telephone numbers on all papers.

Summary: Counsel should list their email addresses and telephone numbers on all papers to facilitate communication with the CRD.

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Civil cases

Applies to

Stipulation and proposed order

Must include

proposed order

If the parties wish to set additional dates, they may file a separate Stipulation and Proposed Order. This may be especially appropriate in class actions, patent cases, or cases for benefits under the Employee Retirement Income Security Act of 1974 (“ERISA”).

Summary: Parties wishing to set additional schedule dates may file a separate Stipulation and Proposed Order, which is especially appropriate in class actions, patent cases, or ERISA benefits cases.

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Civil cases

Applies to

Proposed final pretrial conference order ?

In drafting the factual issues in dispute, the parties should attempt to state issues in ultimate fact form, not in the form of evidentiary fact issues. The issues of fact should track the elements of a claim or defense on which the jury will be required to make findings.

Summary: Disputed factual issues in the Proposed FPTCO should be stated in ultimate fact form and track the elements of the claims or defenses on which the jury must make findings.

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Civil cases

Applies to

Proposed final pretrial conference order ?

Issues of law should state legal issues on which the Court will be required to rule during the trial and should not list ultimate fact issues to be submitted to the trier of fact.

Summary: Issues of law in the Proposed FPTCO should state only legal issues for the Court to rule on during trial, not ultimate fact issues for the trier of fact.

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Applies to

Jury instructions

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 this case.

Summary: Parties should submit the most recent version of the Ninth Circuit Model Jury Instructions when applicable, modified to fit the case, with CACI and O'Malley's Federal Jury Practice and Instructions referenced as fallback sources in truncated surrounding text.

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Applies to

Brief ?

Statutory references should identify with specificity the sections and subsections referenced

Summary: Statutory citations must identify the specific sections and subsections referenced, and citations to treatises, manuals, and similar materials must include the volume, section, and pages.

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Applies to

All papers

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

Summary: Counsel should include their email addresses and telephone numbers on all papers.

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Applies to

Stipulation and proposed order

Must include

proposed order

If the parties seek to set additional dates, they may file a Stipulation and Proposed Order in accordance with the requirements of this Court's Standing Order. This may be appropriate in class actions, patent cases, or cases for benefits under the Employee Retirement Income Security Act of 1974 ("ERISA").

Summary: Parties seeking to set dates beyond the pretrial/trial schedule may file a Stipulation and Proposed Order in accordance with the Court's Standing Order.

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Applies to

Jury instructions

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 ("CACI").

Summary: Parties should use the most recent Ninth Circuit Model Jury Instructions where applicable, and CACI where California law applies.

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Civil cases

Applies to

Jury instructions ?

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: Parties must fill in blanks or select among options when proposing standard jury instructions that contain blanks or choices.

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Applies to

Pleadings

Litigants and counsel may indicate their pronouns and honorifics 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.

Summary: Litigants and counsel may (optionally) indicate pronouns and honorifics by filing a letter, adding the information to the name block or signature line of pleadings, or verbally informing the Court at an appearance.

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Civil cases

Applies to

Sealed document ?

Must include

chambers copy, proposed order ?

Mandatory Chambers Copies & Proposed Orders

Summary: Chambers copies and proposed orders are mandatory for sealed documents.

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Civil cases

Applies to

Sealed document ?

Must include

local rule certificate ?

Any document filed under seal must also be linked to the court order granting permission to so file. See L.R. 79-5.2.2 (c) (eff. 12/1/15).

Summary: Documents filed under seal must be linked to the court order granting permission.

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Civil cases

Applies to

Sealed declaration

Must include

local rule certificate ?

Note that, if you are the party that has designated a document confidential pursuant to a protective order, L.R. 79-5.2.2(b)(i) requires you to file a Declaration explaining why the documents should be filed under seal. You should use the "Sealed Declaration in Support" event to file this declaration.

Summary: Protective order declarations must use "Sealed Declaration in Support" event.

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Civil cases

Applies to

Application for leave to file under seal ?

Must include

declaration, proposed order, redacted documents +1 more ?

Your Application must be accompanied by: (1) a declaration; (2) a proposed order; (3) a redacted version of any documents of which only a portion is proposed to be filed under seal; and (4) an unredacted version of the documents proposed to be filed under seal. L.R. 79-5.2.2(a)-(b) (eff. 12/1/15).

Summary: Application for Leave to File Under Seal must include declaration, proposed order, redacted and unredacted documents.

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Civil cases

Applies to

Sealed document

Must include

proposed order

A Word Perfect or Microsoft Word version of the proposed order must be emailed to chambers as required by L.R. 5-4.4.2, and mandatory chambers copies of e-filed sealed documents must be provided to chambers pursuant to L.R. 5-4.5, just as with any e-filed documents. However, mandatory chambers copies must be provided in sealed envelopes, with a copy of the title page attached to the front of each envelope. L.R. 79-5.2.2(a).

Summary: Proposed orders must be emailed to chambers; sealed documents require sealed envelopes with title page.

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Civil cases

Applies to

Application for leave to file under seal ?

Must include

declaration, proposed order, redacted documents +1 more ?

Local Rule 79-5.2.2 requires that certain documents be filed with the Application: (1) a declaration; (2) a proposed order; (3) a redacted version of any documents of which only a portion is proposed to be filed under seal; and (4) an unredacted version of any documents proposed to be filed under seal.

Summary: Application for Leave to File Under Seal requires declaration, proposed order, redacted and unredacted documents.

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Civil cases

Applies to

Sealed document ?

Must include

caption

On the next screen, enter the document caption in the free text field. Remember that this text will be publicly visible, so do not include confidential information here. Click “Next.”

Summary: Document caption must be entered in a free text field and must not contain confidential information.

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Civil cases

Applies to

Scheduling meeting report ?

Must include

jointly signed

Counsel shall meet at least twenty-one (21) days in advance of the Scheduling Conference to prepare a jointly signed report for the court to be submitted no less than fourteen (14) days before the Scheduling Conference.

Summary: Counsel must meet 21 days before scheduling conference and submit joint report 14 days before.

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Civil cases

Applies to

Scheduling meeting report ?

Must include

jointly signed ?

The joint report to be submitted shall contain the items listed in Fed. R. Civ. P. 26(f), the parties’ recommendations and agreements, if any, about the final scheduling order as listed in Fed. R. Civ. P. 16(b)(1) through (6), and those items listed in Fed. R. Civ. P. 16(c) which counsel believe will be useful to discuss at the Scheduling Conference.

Summary: Joint report must include items from Fed. R. Civ. P. 26(f), 16(b)(1)-(6), and 16(c).

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Civil cases

Applies to

Scheduling meeting report ?

Must include

jointly signed ?

Items which must be addressed are the following: (1) initial disclosures, preservation of discoverable information, and a discovery plan, including a listing and proposed schedule of written discovery, depositions, and a proposed discovery cut-off date; (2) a listing and proposed schedule of law and motion matters, and a proposed dispositive motion cut-off date; (3) a statement of what efforts have been made to settle or resolve the case to date and what settlement procedure is recommended pursuant to Local Rule 16-15.4 (specifically excluding any statement of the terms discussed); (4) an estimated length of trial and a proposed date for the final pretrial conference and for trial;

Summary: Joint report must address discovery plan, motion schedule, settlement efforts, and trial timing.

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Civil cases

Applies to

Joint scheduling report

Must include

local rule certificate ?

The report to the Court as to the above items should be preceded by a thorough and frank discussion among the attorneys for the parties. A Joint Scheduling Report which does not comply with Fed. R. Civ. P. 16, 26(f), and this Order may cause continuance of the Scheduling Conference and a possible award of sanctions under Rule 16(f) against the party or parties responsible.

Summary: Joint Scheduling Report must comply with Fed. R. Civ. P. 16, 26(f), and this Order; non-compliance may result in continuance and sanctions.

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Civil cases

Applies to

Order

Must include

certificate of service ?

Counsel for plaintiff shall immediately serve this Order on all parties, including any new parties to the action.

Summary: Plaintiff's counsel must immediately serve this Order on all parties, including new parties.

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