Judge Alex G. Tse

the parties shall prepare a joint statement of not more than five pages (12-point or greater font) stating the following:

the parties shall prepare a joint statement of not more than five pages (12-point or greater font) stating the following:

the parties shall prepare a joint statement of not more than five pages (12-point or greater font) stating the following:

Any stipulation or proposed order in a case subject to e-filing should, in addition to being e-filed, be submitted by email to agtpo@cand.uscourts.gov as a Word document on the same day the document is e-filed. This email address should be used only for this stated purpose unless otherwise directed by the Court.

If a party files a dispositive motion (such as a motion to dismiss or a motion to remand), the moving party must file the consent or declination simultaneously with the motion.

In no event shall the consent or declination be filed later than the deadlines specified in Civil Local Rule 73-1.

Any stipulation or proposed order in a case subject to e-filing should, in addition to being e-filed, be submitted by email to agtpo@cand.uscourts.gov as a Word document on the same day the document is e-filed.

When exhibits are included with a motion, opposition brief, or reply brief, the exhibits should be filed separately on ECF. For example, if a motion is Docket No. 30, and a declaration with 10 exhibits is Docket No. 31, Exhibit A should be filed as Docket No. 31-1, Exhibit B should be filed as Docket No. 31-2, and so on.

Any party who files an amended pleading must concurrently file a redlined version comparing the amended pleading to the prior operative pleading.

Prior to an initial or further case management conference, counsel must meet and confer and then, no later than seven days before the conference, file a joint statement, or file separate statements if permitted by Civil Local Rule 16-9.

Any party who files an amended pleading must concurrently file a redlined version comparing the amended pleading to the prior operative pleading.

Prior to an initial or further case management conference, counsel must meet and confer and then, no later than seven days before the conference, file a joint statement, or file separate statements if permitted by Civil Local Rule 16-9.

If specific discovery requests, i.e., interrogatories, requests for production of documents, requests for admission, are in dispute, the parties must attach the following to their joint statement: a copy of the disputed requests, a copy of the disputed responses, and a copy of the definitions of any defined terms used in the disputed requests.

Parties must take the steps needed to preserve information relevant to the issues in the litigation, including suspending document-destruction programs that, if not suspended, could result in evidence spoliation.

If parties believe a protective order is necessary, they must when practicable use one of the model protective orders, available at www.cand.uscourts.gov/forms/model-protective- orders.

If parties believe a protective order is necessary, they must when practicable use one of the model protective orders, available at www.cand.uscourts.gov/forms/model-protective-orders.

When parties ask the Court to approve a stipulated protective order, they must file with the proposed order either (i) a statement in which they confirm that the proposed protective order doesn't differ in any respect from the model order, or (ii) a redline comparing the proposed protective order with the model order, along with an explanation of any changes.

1. an attestation that counsel for the parties met and conferred in person or by videoconference in good faith to resolve their dispute before filing the joint statement; 2. each party’s position, including pertinent factual background, requested relief, and citations to relevant legal authority; and 3. each party’s final proposed compromise.

Relevant declarations and exhibits may be attached to the joint statement. If specific discovery requests, i.e., interrogatories, requests for production of documents, requests for admission, are in dispute, the parties must attach the following to their joint statement: a copy of the disputed requests, a copy of the disputed responses, and a copy of the definitions of any defined terms used in the disputed requests.

Joint statements must be e-filed (unless the case is exempt from e-filing requirements) under the Civil Events category of "Motions and Related Filings > Motions – General > Discovery Letter Brief."

When parties ask the Court to approve a stipulated protective order, they must file with the proposed order either (i) a statement in which they confirm that the proposed protective order doesn’t differ in any respect from the model order, or (ii) a redline comparing the proposed protective order with the model order, along with an explanation of any changes.

Joint statements must be e-filed (unless the case is exempt from e-filing requirements) under the Civil Events category of “Motions and Related Filings > Motions – General > Discovery Letter Brief.”

Privilege logs must be promptly provided and sufficiently detailed and informative to justify the privilege. See Fed. R. Civ. P. 26(b)(5).

Counsel must consult in advance with opposing counsel to schedule depositions at a mutually convenient time and location.

When privilege is claimed, the witness must answer questions relevant to the existence, extent, or waiver of the privilege unless such information is itself privileged.

Speaking objections are prohibited.

Privilege logs must be promptly provided and sufficiently detailed and informative to justify the privilege. See Fed. R. Civ. P. 26(b)(5).

Privilege logs must contain the following: • the title and description of the document, including the number of pages or Bates- number range; • the subject matter addressed in the document; • the identity and position of its author; • the identity and position of all addressees and recipients; • the date the document was prepared and, if different, the date on which it was sent to or shared with persons other than its author; and • the basis for the claim that the document is privileged or protected.

Depositions of fact witnesses must be noticed at least 30 days before the close of fact discovery.

Privilege logs must contain the following: • the title and description of the document, including the number of pages or Bates- number range; • the subject matter addressed in the document; • the identity and position of its author; • the identity and position of all addressees and recipients; • the date the document was prepared and, if different, the date on which it was sent to or shared with persons other than its author; and • the basis for the claim that the document is privileged or protected.

Settlement conference statements must be served on opposing counsel. Any party may email an additional confidential statement to the Court, the contents of which will not be disclosed to the other parties.

The settlement conference statement shall include at least the following:  a brief statement of the facts of the case;  a brief statement of the claims and defenses;  a candid evaluation of the party’s likelihood of prevailing;  a summary of the proceedings to date and any pending motions;  the relief sought;  any discrete issue that, if resolved, would facilitate resolution of the case; and  the party’s position on settlement, including present demands and offers and a history of past settlement discussions.

Each party shall prepare a settlement conference statement, which must be emailed to the Court in .pdf format, at agtsettlement@cand.uscourts.gov, no later than seven days prior to the conference. Paper copies should not be provided.

If a defendant plans to assert that it lacks resources and is unable to offer monetary compensation or that it otherwise does not intend to offer monetary compensation as part of a settlement, it must notify the Court of this in a confidential statement no later than seven days prior to the conference.