
Judge Eumi K. Lee
Individual Rules, Standing Orders & Policies
- Rules last changed:

Limits & Logistics
Document Limits
Courtesy Copies
Administrative Record
- 1 copy • Mail Or Hand Delivery • Within 5 Court Days
- 1 copy • Within 5 Court Days After Electronic Filing
Courtesy copies
Exhibits
- 1 copy
Motion, Brief
- 2 copies • Within 2 Court Days After Briefing Concludes

Adjournments
- Emergency relief requires reasonable effort to notify opposing party and counsel.
- Briefing schedules must allow 14 days (28 days for SJ/Daubert/class cert) between final filing and hearing unless good cause shown.
- Zoom appearance requests must be filed and served at least 1 week before hearing.
- +6 more
Request must include
- Continuance requests must be filed at least 3 court days before the deadline.
- Page limit enlargement requests require 3-5 court days advance notice depending on type.
- Demonstratives must be exchanged and submitted 48 hours before hearing (by Friday 5pm if weekend).
- Requests for continuances or extensions requiring a court order must be filed no later than 3 court days before the deadline being extended.
- Stipulated requests to enlarge page limits are rarely granted and must be filed at least three court days before the underlying motion.
- Administrative motions to enlarge page limits must be filed at least five court days before the underlying motion, with any opposition due at least three court days before the underlying motion or within the Civil L.R. 7-11 time, whichever is sooner.

Communication
Chambers
Chambers
Phone
Chambers
Letter via ECF
Chambers
Chambers
Zoom
Chambers
Page & Word Limits28 rules
The quote is in the court's document. The summary is not checked yet.Mandatory?
The Court may set a deadline for the filing of a mid-discovery case management statement, not to exceed ten (10) pages, at the approximate midpoint of the fact discovery period.
Summary: If the Court sets a deadline for a mid-discovery case management statement, the statement must not exceed 10 pages.
Mid Discovery Case Management Statement
10 pages
The quote is in the court's document. The summary is not checked yet.Mandatory?
No later than fourteen (14) days before the further case management conference, the parties shall file a joint case management statement, not to exceed ten (10) pages, containing the following information:
Summary: The joint case management statement must not exceed ten (10) pages.
Joint Case Management Statement
10 pages
The quote is in the court's document. The summary is not checked yet.Mandatory?
Absent leave of court, the page limits for the following types of motions and proceedings shall be 25 pages for the motion or opening brief, 25 pages for the opposition or response brief, and fifteen (15) pages for the reply brief: motions brought under Federal Rules of Civil Procedure 12, 23, 50, 56, 59, or 65; motions for certification of a collective action under the Fair Labor Standards Act; motions brought under California's anti-SLAPP statute; Social Security appeals; and claim construction briefing.
Summary: Absent leave of court, specified motions (FRCP 12, 23, 50, 56, 59, 65; FLSA collective certification; anti-SLAPP; Social Security appeals; claim construction) are limited to 25 pages for the motion/opening brief, 25 pages for the opposition, and 15 pages for the reply brief.
Motion Or Opening Brief
25 pages
Opposition Or Response Brief
25 pages
Reply Brief
15 pages
The quote is in the court's document. The summary is not checked yet.Mandatory?
Absent leave of court, the page limits for all other types of motions and proceedings, except for those addressed above or those for which specific page limits are set forth in the Civil Local Rules or the Court's Standing Orders, shall be ten (10) pages for the motion or opening brief, ten (10) pages for the opposition or response brief, and five (5) pages for the reply brief. Motions subject to these limits include motions for sanctions, motions for attorneys' fees, motions to stay, motions to compel arbitration, and motions to remand.
Summary: Absent leave of court, all other motions (e.g., sanctions, attorneys' fees, stay, compel arbitration, remand) are limited to 10 pages for the motion/opening brief, 10 pages for the opposition, and 5 pages for the reply brief.
Motion Or Opening Brief
10 pages
Opposition Or Response Brief
10 pages
Reply Brief
5 pages
The quote is in the court's document. The summary is not checked yet.Mandatory?
The first two briefs are limited to 25 pages; the third brief is limited to twenty (20) pages; and the fourth brief is limited to fifteen (15) pages.
Summary: Cross-motion summary judgment briefs are limited to 25 pages for the first two briefs, 20 pages for the third brief, and 15 pages for the fourth brief.
Opening Brief
25 pages
Opposition Reply Brief
20 pages
Reply Brief
15 pages
The quote is in the court's document. The summary is not checked yet.Important?
These page limits are maximums, not minimums. Counsel and parties are encouraged to be concise. Excess pages will not be considered by the Court.
Summary: All motion page limits are maximums rather than minimums, and excess pages will not be considered by the Court.
Motion Or Brief
The quote is in the court's document. The summary is not checked yet.Important?
In most cases, the statement should not exceed fifteen (15) pages.
Summary: The moving separate statement should generally not exceed 15 pages (guideline, not a hard cap).
Moving Separate Statement
15 pages
The quote is in the court's document. The summary is not checked yet.Important?
In most cases, the responsive separate statement should add no more than five (5) pages to the moving separate statement.
Summary: The responsive separate statement should generally add no more than 5 pages to the moving separate statement (guideline, not a hard cap).
Responsive Separate Statement
5 pages
Machine summary. Not checked yet.Mandatory?
Deadline to Complete Initial ADR Session - Generally 120 days after the initial case management conference
Summary: Initial ADR session must be completed within 120 days of initial case management conference.
Structured details unavailable. See the source text.
Machine summary. Not checked yet.Mandatory?
Hearing on Summary Judgment, Daubert, and Class Certification - Four (4) weeks after the final brief is submitted
Summary: Hearing on summary judgment, Daubert, and class certification is 4 weeks after final brief.
Structured details unavailable. See the source text.
Machine summary. Not checked yet.Mandatory?
Close of Expert Discovery - No more than four (4) months after the close of fact discovery
Summary: Expert discovery closes no more than 4 months after fact discovery closes.
Structured details unavailable. See the source text.
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Trial - Twelve to twenty (12-20) months after the initial case management conference
Summary: Trial is scheduled 12-20 months after initial case management conference.
Trial
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Close of Fact Discovery - Four to eight (4-8) months after the initial case management conference
Summary: Fact discovery closes 4-8 months after initial case management conference.
Fact Discovery
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Mid-Discovery Case Management Statement: In cases involving at least six (6) months of fact discovery, the Court will set a deadline for the filing of a further case management statement not to exceed ten (10) pages.
Summary: Mid-discovery case management statement (max 10 pages) required for cases with 6+ months of fact discovery.
Mid Discovery Case Management Statement
10 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Pretrial Conference - At least twelve (12) weeks after the last day to hear summary judgment and Daubert motions, and at least four (4) weeks before trial begins, with a joint pretrial statement due two (2) weeks before the conference
Summary: Pretrial conference is 12 weeks after summary judgment/Daubert hearing and 4 weeks before trial, with joint pretrial statement due 2 weeks prior.
Structured details unavailable. See the source text.
Machine summary. Not checked yet.Mandatory?
Close of Briefing on Summary Judgment, Daubert, and Class Certification - No more than ten (10) weeks after the close of expert discovery
Summary: Briefing on summary judgment, Daubert, and class certification closes 10 weeks after expert discovery.
Structured details unavailable. See the source text.
Machine summary. Not checked yet.Mandatory?
Deadline to Request Leave to Amend Pleadings (per Fed. R. Civ. P. 15) - No later than 60 days after the initial case management conference
Summary: Deadline to request leave to amend pleadings is 60 days after initial case management conference.
Structured details unavailable. See the source text.
Machine summary. Not checked yet.Mandatory?
The first two briefs are limited to 25 pages; the third brief is limited to twenty (20) pages; and the fourth brief is limited to fifteen (15) pages.
Summary: Summary judgment briefs have page limits: first two at 25 pages, third at 20 pages, fourth at 15 pages.
Brief
25 pages
Applies to: Attorney
20 pages
Applies to: Attorney
15 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
In most cases, the statement should not exceed fifteen (15) pages.
Summary: Moving separate statement for summary judgment should not exceed 15 pages.
Moving Separate Statement
15 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Each party is limited to filing one (1) motion for summary judgment. Any party wishing to exceed this limit must request leave of court.
Summary: Each party limited to one summary judgment motion; additional motions require leave of court.
Structured details unavailable. See the source text.
Machine summary. Not checked yet.Mandatory?
In most cases, the responsive separate statement should add no more than five (5) pages to the moving separate statement.
Summary: Responsive separate statement should add no more than 5 pages to moving statement.
Responsive Separate Statement
5 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Absent leave of court, the page limits for all other types of motions and proceedings, except for those addressed above or those as to which specific page limits are set forth in the Civil Local Rules or the Court’s Standing Orders, shall be ten (10) pages for the motion or opening brief, ten (10) pages for the opposition or response brief, and five (5) pages for the reply brief. Motions subject to these limits include motions for sanctions, motions to stay, and motions to compel arbitration.
Summary: Other motions limited to 10/10/5 pages (motion/opposition/reply).
Motion
10 pages
Machine summary. Not checked yet.Mandatory?
Absent leave of court, the page limits for the following types of motions and proceedings shall be 25 pages for the motion or opening brief, 25 pages for the opposition or response brief, and fifteen (15) pages for the reply brief: motions brought under Federal Rules of Civil Procedure 12, 23, 50, 56, 59, or 65; motions for certification of a collective action under the Fair Labor Standards Act; motions brought under California’s anti-SLAPP statute; Social Security appeals; and claim construction briefing.
Summary: Major motions limited to 25/25/15 pages (motion/opposition/reply).
Motion
25 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
As an initial matter, the Court will construe only those terms designated by the parties as 'most significant' pursuant to Patent Local Rule 4-3(c). Therefore, the Court will generally construe no more than ten (10) terms. If multiple terms present identical issues, they may be grouped together or a representative term may be chosen, and each group or representative term may be considered a single term for purposes of the ten-term limit. If more than ten (10) terms are at issue, the parties must meet and confer before the preparation of the joint claim construction statement to narrow the number of terms that are to be construed by the Court and shall jointly propose the ten (10) terms requiring construction.
Summary: The Court will construe no more than ten terms, grouping identical issues; parties must meet and confer if more than ten terms are at issue.
Structured details unavailable. See the source text.
Machine summary. Not checked yet.Mandatory?
The opening and responsive briefs shall not exceed 25 pages; the reply brief shall not exceed fifteen (15) pages.
Summary: Opening and responsive briefs limited to 25 pages; reply briefs limited to 15 pages.
Brief
25 pages
Applies to: Attorney
Reply Brief
15 pages
Applies to: Attorney
Machine summary. Not checked yet.Important?
If a party files its own motion and joins in another party’s motion, both the party’s own motion and the joined motion will count toward the party’s page limits. Where multiple parties are represented by the same counsel, all motions filed by those parties are limited to a single brief which complies with the page limits set forth above, absent leave of court.
Summary: Joined motions and multiple parties count toward page limits.
Motion
Machine summary. Not checked yet.Important?
These page limits are maximums, not minimums. Counsel and parties are encouraged to be concise. Excess pages will not be considered by the Court.
Summary: Page limits are maximums; excess pages will not be considered.
Machine summary. Not checked yet.Note?
This deadline shall be set at the approximate midpoint of the fact discovery period.
Summary: Mid-discovery statement deadline set at approximate midpoint of fact discovery period.
Structured details unavailable. See the source text.
Document Format Requirements14 rules
The quote is in the court's document. The summary is not checked yet.Mandatory?
The moving separate statement must be organized in the form of a chart as shown in Attachment A.
The quote is in the court's document. The summary is not checked yet.Mandatory?
The responsive separate statement must be organized in the form of a chart as shown in Attachment A.
The quote is in the court's document. The summary is not checked yet.Important?
Proposed orders should be filed in PDF format on ECF and sent in Microsoft Word format to eklpo@cand.uscourts.gov.
Summary: Proposed orders (in sealing motions) must be filed in PDF format on ECF and also sent in Microsoft Word format to eklpo@cand.uscourts.gov.
The quote is in the court's document. The summary is not checked yet.Important?
authorities or evidence shall be in the body of the brief. Excessive footnotes will be disregarded. In general, no more than five (5) footnotes per brief should be necessary.
Summary: Briefs must keep authorities and evidence in the body rather than footnotes, should contain no more than five footnotes, and excessive footnotes will be disregarded.
The quote is in the court's document. The summary is not checked yet.Important?
Each proposed order should be filed in PDF format on ECF.
Summary: Proposed orders should be filed in PDF format on ECF.
The quote is in the court's document. The summary is not checked yet.Important?
The Court's signature block should not appear on a standalone page.
Summary: In proposed orders, the Court's signature block should not appear on a standalone page.
Machine summary. Not checked yet.Mandatory?
The moving separate statement must be organized in the form of a chart as shown in Attachment A.
Summary: Moving separate statement must be organized in chart format as shown in Attachment A.
Machine summary. Not checked yet.Mandatory?
The responsive separate statement must be organized in the form of a chart as shown in Attachment A.
Summary: Responsive separate statement must be organized in chart format as shown in Attachment A.
Machine summary. Not checked yet.Mandatory?
Chambers copies should be double-sided and should bear the ECF filing “stamp” (case number, docket number, date, and ECF page number) along the top of the page.
Summary: Chambers copies must be double-sided with ECF stamp.
Machine summary. Not checked yet.Mandatory?
All exhibits shall be clearly delineated with labels along the right side.
Summary: Exhibits must have labels along the right side.
Machine summary. Not checked yet.Mandatory?
If the filing includes exhibits over two-inches thick, the parties shall place the copies in a binder. Binders should not exceed three inches.
Summary: Exhibits over 2 inches thick require binder (max 3 inches).
Machine summary. Not checked yet.Mandatory?
The chambers copy should be placed in one or more binders. Each document should be tabbed with labels along the right side.
Summary: Social Security chambers copies require binders with tabbed documents.
Machine summary. Not checked yet.Important?
Proposed notices must be written in plain language without unnecessary acronyms.
Summary: Class action notices must use plain language without unnecessary acronyms.
Machine summary. Not checked yet.Note?
If they so choose, litigants and lawyers may indicate their pronouns (e.g., she/her, he/him, they/their) and honorifics (e.g., Mr., Ms., Mx., Dr.) by adding the information in the name block or signature line of the pleadings, by filing a letter on the public docket, or by informing the Court at the start of a hearing.
Summary: Litigants may optionally indicate pronouns and honorifics in pleadings, letters, or at hearings.
Document Filing Requirements71 rules
The quote is in the court's document. The summary is not checked yet.Mandatory?
All requests for the Court to take action shall be made either by stipulation and proposed order or by an appropriate motion filed pursuant to the Civil Local Rules.
Summary: Requests for the Court to take action must be made by stipulation with proposed order or by an appropriate motion, not by letter.
Document Type
Request For Court Action
The quote is in the court's document. The summary is not checked yet.Mandatory?
No later than fourteen (14) days before the further case management conference, the parties shall file a joint case management statement, not to exceed ten (10) pages, containing the following information:
Summary: The joint case management statement must contain specified information on motions, discovery status, settlement/ADR, bifurcation, and trial readiness.
Document Type
Joint Case Management Statement
The quote is in the court's document. The summary is not checked yet.Mandatory?
All amended pleadings shall attach as an exhibit a redlined or highlighted document showing the changes made to the previously-filed pleading.
Summary: Amended pleadings must attach a redlined or highlighted exhibit showing the changes made to the previously filed pleading.
Document Type
Amended Pleading
The quote is in the court's document. The summary is not checked yet.Mandatory?
In addition, the motion must be accompanied by a proposed order that complies with Civil Local Rule 79-5 and is organized in the following format.
Summary: Each motion to seal must be accompanied by a proposed order complying with Civil Local Rule 79-5 and organized in the specified ECF No./Document/Portion(s) to Seal/Granted-Denied format.
Document Type
Motion To Seal
The quote is in the court's document. The summary is not checked yet.Mandatory?
In addition to complying with Civil Local Rule 79-5, each motion to seal must include a chart, in the format set forth below, that includes the following columns: (1) ECF number or exhibit number of the document sought to be sealed; (2) description or name of the document sought to be sealed; (3) portion(s) of the document to seal; and (4) reason(s) why the document should be sealed, including citation to the applicable declaration. Each separate document for which sealing is sought shall have its own row in the table.
Summary: Every motion to seal must include a chart listing, for each document, the ECF/exhibit number, description, portions to be sealed, and reasons for sealing with citation to the supporting declaration, with a separate row for each document.
Document Type
Motion To Seal
The quote is in the court's document. The summary is not checked yet.Mandatory?
In the notice of motion, counsel for the moving party must certify that this meet-and-confer requirement has been satisfied, citing specifically to this section of the Civil Standing Order. If the notice of motion does not include such a certification, the Court may strike the motion and order the moving party to re-file the motion with a certification once the meet-and-confer requirement has been met.
Summary: The notice of motion must certify that the meet-and-confer requirement was satisfied (citing this Standing Order section), and the Court may strike a motion lacking this certification.
Document Type
Notice Of Motion
The quote is in the court's document. The summary is not checked yet.Mandatory?
All factual and legal bases for a party's position with respect to a motion must be presented in the briefing on that motion. Arguments presented in earlier-filed briefs or documents may not be incorporated by reference.
Summary: All factual and legal bases for a motion must be presented in that motion's briefing; arguments from earlier-filed briefs or documents may not be incorporated by reference.
Document Type
Brief
The quote is in the court's document. The summary is not checked yet.Mandatory?
Where the parties submit cross-motions for summary judgment, only the following briefs will be allowed: (1) opening brief by the plaintiff side; (2) opening/opposition brief by the defense side; (3) opposition/reply brief by the plaintiff side; and (4) reply brief by the defense side. The parties may agree to reverse the order, and to have the defense side file its opening brief first, without order of the Court.
Summary: Cross-motions for summary judgment permit only four briefs in a set sequence (plaintiff opening, defense opening/opposition, plaintiff opposition/reply, defense reply), though the parties may agree to reverse the order without a court order.
Document Type
Brief
The quote is in the court's document. The summary is not checked yet.Mandatory?
Before the first brief is filed, the parties must submit a stipulation and proposed order setting a briefing schedule for the cross-motions.
Summary: Before the first cross-motion summary judgment brief is filed, the parties must submit a stipulation and proposed order setting the briefing schedule.
Document Type
Stipulation
The quote is in the court's document. The summary is not checked yet.Mandatory?
Any party moving for summary judgment, partial summary judgment, or summary adjudication must include a separate, short and concise statement identifying each claim or defense for which the moving party contends there is no genuine issue to be tried.
Summary: A motion for summary judgment, partial summary judgment, or summary adjudication must include a separate statement identifying each claim or defense for which the movant contends there is no genuine issue to be tried.
Document Type
Motion For Summary Judgment
The quote is in the court's document. The summary is not checked yet.Mandatory?
At least seven (7) days before the opening brief is filed, the parties shall file a concise joint status report that identifies: (1) the claims, counterclaims, and defenses that remain to be decided; (2) the pleading in which each claim, counterclaim, or defense is asserted; and (3) each claim, counterclaim, defense, or issue for which a party will move for summary judgment.
Summary: The joint status report must identify the remaining claims, counterclaims, and defenses, the pleading in which each is asserted, and each claim or issue that will be the subject of a summary judgment motion.
Document Type
Joint Status Report
The quote is in the court's document. The summary is not checked yet.Mandatory?
Use of generative artificial intelligence tools is not prohibited, but counsel must personally confirm for themselves the accuracy of any research conducted by these means, and counsel alone bears ethical responsibility for all statements made in filings. Any submission containing AI-generated content must include a certification that lead trial counsel has personally verified the content's accuracy. Failure to include this certification or comply with this verification requirement will be grounds for sanctions.
Summary: Any submission containing AI-generated content must include a certification that lead trial counsel personally verified the content's accuracy, and failure to include it is grounds for sanctions.
Document Type
Submission Containing Ai Generated Content
The quote is in the court's document. The summary is not checked yet.Mandatory?
For each claim, defense, or part thereof, the moving separate statement must: (a) identify the relevant elements or issues; (b) list the asserted material facts establishing or negating those elements or issues; and (c) cite to record evidence demonstrating that the asserted material facts are undisputed (e.g., deposition testimony, declaration, or discovery response).
Summary: The moving separate statement must identify the relevant elements or issues, list the asserted material facts, and cite record evidence showing those facts are undisputed.
Document Type
Moving Separate Statement
The quote is in the court's document. The summary is not checked yet.Mandatory?
Each party is limited to filing one (1) motion for summary judgment. Any party wishing to exceed this limit must request leave of court.
Summary: Each party may file only one motion for summary judgment, and exceeding that limit requires leave of court.
Document Type
Motion For Summary Judgment
The quote is in the court's document. The summary is not checked yet.Mandatory?
partial summary judgment, or summary adjudication must include a responsive separate statement which: (a) incorporates the moving separate statement; (b) indicates whether each of the facts listed in the moving separate statement is disputed or undisputed; and (c) identifies any additional material facts the party contends will establish a genuine issue to be tried. If the opposing party contends that a fact is in dispute, the opposing party must cite to evidence in the record establishing the dispute.
Summary: The opposing party must include a responsive separate statement that incorporates the moving separate statement, indicates whether each fact is disputed or undisputed, identifies additional material facts, and cites record evidence for any fact claimed to be in dispute.
Document Type
Responsive Separate Statement
The quote is in the court's document. The summary is not checked yet.Mandatory?
Parties requesting a protective order are encouraged to base any proposed order on the model protective orders on the Northern District of California's website. When filing a proposed protective order, at the very beginning of their stipulation or motion, parties must indicate whether they have based their proposed order on one of the Northern District's model orders.
Summary: At the very beginning of a stipulation or motion filing a proposed protective order, parties must state whether the proposed order is based on one of the Northern District of California's model protective orders (use of the model orders is encouraged).
Document Type
Stipulation Or Motion For Protective Order
The quote is in the court's document. The summary is not checked yet.Mandatory?
Each separate statement must be signed by counsel or unrepresented party who has reviewed the document and attests as follows: I attest that the evidence cited herein fairly and accurately supports or disputes the facts as asserted.
Summary: Each separate statement must be signed by counsel or an unrepresented party and include the attestation that the cited evidence fairly and accurately supports or disputes the asserted facts.
Document Type
Separate Statement
The quote is in the court's document. The summary is not checked yet.Mandatory?
The separate statements shall not include argument in support of the summary judgment motion and shall not be used to circumvent the page limits that apply to summary judgment briefing. Parties should include only those facts that are actually cited in the briefs. Facts that are not cited in the summary judgment briefs will not be considered.
Summary: Separate statements must not include argument or be used to circumvent briefing page limits, and should include only facts actually cited in the briefs, since uncited facts will not be considered.
Document Type
Separate Statement
The quote is in the court's document. The summary is not checked yet.Mandatory?
Objections to evidence shall be contained within the objecting party's brief.
Summary: Objections to evidence must be contained within the objecting party's summary judgment brief.
Document Type
Brief
The quote is in the court's document. The summary is not checked yet.Mandatory?
If they have, they must identify any deviations from the model order by submitting as an exhibit a redlined or highlighted comparison of their proposed order and the model order.
Summary: If a proposed protective order is based on a model order, parties must submit as an exhibit a redlined or highlighted comparison identifying any deviations from the model order.
Document Type
Proposed Protective Order
The quote is in the court's document. The summary is not checked yet.Mandatory?
The proposed notices, claims forms, and other documents associated with preliminary approval should be sent in Microsoft Word format to eklpo@cand.uscourts.gov.
Summary: Proposed notices, claims forms, and other preliminary approval documents should be sent in Microsoft Word format to eklpo@cand.uscourts.gov.
Document Type
Class Settlement Preliminary Approval Documents
The quote is in the court's document. The summary is not checked yet.Mandatory?
Template for Moving Separate Statement Claim or Defense Moving Party’s Undisputed Facts Opposing Party’s Response & & Supporting Evidence Supporting Evidence
Summary: Moving separate statements must follow the court's template: a three-column table organized by claim or defense and issue, listing the moving party's numbered undisputed facts with record citations and leaving a column for the opposing party's response.
Document Type
Separate Statement
The quote is in the court's document. The summary is not checked yet.Important?
The joint case management statement shall comply with the "Standing Order for All Judges of the Northern District of California – Contents of Joint Case Management Statement" and Civil Local Rule 16-9. In their joint case management statement for the initial case management conference, the parties must propose a full litigation schedule, including a proposed last day to amend pleadings as well as a deadline to complete ADR.
Summary: Joint case management statements must comply with the Standing Order on CMC statement contents and Civil Local Rule 16-9, and the initial statement must propose a full litigation schedule including a last day to amend pleadings and an ADR completion deadline.
Document Type
Joint Case Management Statement
The quote is in the court's document. The summary is not checked yet.Important?
If any party believes a conference is needed, the party shall identify the issue(s) that require the Court's attention and detail the efforts that the parties have made to resolve the issue. Such requests should be made on an extremely limited basis after extensive efforts to meet and confer in person or by videoconference.
Summary: Requests for a mid-discovery conference must identify the issues requiring the Court's attention and detail the parties' meet-and-confer efforts, and should be made only sparingly after extensive meet-and-confer efforts in person or by videoconference.
Document Type
Mid Discovery Conference Request
The quote is in the court's document. The summary is not checked yet.Important?
Proposed orders submitted in connection with motions for injunctive relief should state the specific relief sought.
Summary: Proposed orders filed with motions for injunctive relief should state the specific relief sought.
Document Type
Proposed Order
The quote is in the court's document. The summary is not checked yet.Important?
Counsel is responsible for maintaining records of all prompts or inquiries submitted to any generative AI tools in the event those records become relevant at any point.
Summary: Counsel must maintain records of all prompts or inquiries submitted to any generative AI tools in case those records become relevant.
Document Type
Generative Ai Prompt Records
Machine summary. Not checked yet.Mandatory?
Parties must prepare a joint case management statement fourteen (14) days prior to the date of any case management or status conference. The joint case management statement shall comply with the “Standing Order for All Judges of the Northern District of California – Contents of Joint Case Management Statement” and Civil Local Rule 16-9.
Summary: Joint case management statement required 14 days before any case management conference.
Document Type
Joint Case Management Statement
Machine summary. Not checked yet.Mandatory?
The caption of any request for a continuance or extension shall indicate how many previous extensions have been requested (e.g., “First Request for Extension”). The request must state whether the Court has granted those extensions and whether the Court has stated that no further extensions will be granted.
Summary: Continuance requests must specify previous extension history in the caption.
Document Type
Continuance Request
Filing & Service rules
Electronic Filing Rules
A declaration and its exhibits should generally be filed as one docket entry, with the declaration as the Main Document and each exhibit as a separate Attachment.
A declaration, along with any exhibits, should generally be filed as one docket entry, with the declaration as the “Main Document” in ECF, and each exhibit filed separately as an “Attachment.”
The quote is in the court's document. The summary is not checked yet.
Page 6 | VII. FILINGS AND CHAMBERS COPIES - B. Documents Filed on ECF
Each motion, supporting declaration, and exhibit must be filed on ECF as a separate text-searchable PDF.
When filing documents on ECF, each motion, supporting declaration, and exhibit should be filed as a separate text-searchable PDF.
The quote is in the court's document. The summary is not checked yet.
Page 6 | VII. FILINGS AND CHAMBERS COPIES - B. Documents Filed on ECF
The ECF Description field for each filed motion, declaration, and exhibit must include the name of the document.
When filing motions, declarations, and exhibits, the ECF “Description” of each document should include the name of the document.
The quote is in the court's document. The summary is not checked yet.
Page 6 | VII. FILINGS AND CHAMBERS COPIES - B. Documents Filed on ECF
The later-filing party must cite to the earlier-filed exhibit and must not file a duplicate exhibit when both parties rely on the same exhibit.
Where each party relies on the same exhibit, the later-filing party should cite to the earlier-filed exhibit and should not file a duplicate exhibit.
The quote is in the court's document. The summary is not checked yet.
Page 6 | VII. FILINGS AND CHAMBERS COPIES - B. Documents Filed on ECF
Filing Timing and Cure Windows
Motions must be filed within 14 days after a hearing date is reserved, or the reservation expires without notice and a new reservation must be obtained before filing.
Once a hearing date is reserved, the motion(s) shall be filed within fourteen (14) days thereafter. Failure to timely file any motion will result in the expiration of the hearing reservation without further notice to the parties, and the moving party must obtain a new reservation before filing the motion(s).
The quote is in the court's document. The summary is not checked yet.
Page 3 | V. SCHEDULING
A joint case management statement must be prepared and filed 14 days before any case management or status conference.
Parties must prepare and file a joint case management statement fourteen (14) days prior to the date of any case management or status conference.
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Page 3 | VI. CASE MANAGEMENT CONFERENCES
The parties must file a joint case management statement no later than fourteen (14) days before the further case management conference.
No later than fourteen (14) days before the further case management conference, the parties shall file a joint case management statement, not to exceed ten (10) pages, containing the following information:
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Page 5 | VI. CASE MANAGEMENT CONFERENCES
Summary judgment, Daubert, and class certification motions must have briefing schedules allowing at least 28 days between the final filing and the hearing.
The briefing schedule for summary judgment, Daubert, and class certification motions shall allow at least 28 days between the final filing and the hearing date.
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Page 9 | D. Briefing Schedules
Motion briefing schedules must generally allow at least 14 days between the final filing and the hearing, though parties may stipulate to a different schedule with Court approval.
The parties may stipulate to and request Court approval of a briefing schedule that differs from that set forth in the Civil Local Rules, noting the differences in their stipulation. Generally, the briefing schedule for any motion shall allow at least fourteen (14) days between the final filing and the hearing date.
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Page 9 | D. Briefing Schedules
Demonstratives and audio-visual presentations must be exchanged with opposing counsel and submitted to the Court at least 48 hours before the hearing, or by Friday at 5:00 p.m. if the deadline falls on a weekend.
Any demonstratives or audio-visual presentations to be used at a hearing must be exchanged with opposing counsel and submitted to the Court at least 48 hours before the hearing. If this date falls on a weekend, parties are required to exchange and submit them by Friday at 5:00 p.m.
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Page 10 | F. Demonstratives and Presentations
The fourth brief in cross-motion summary judgment briefing must be filed at least 28 days before the hearing.
The fourth brief must be filed at least 28 days before the hearing.
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Page 11 | IX. SUMMARY JUDGMENT
The parties must file a joint status report at least 7 days before the opening summary judgment brief is filed.
At least seven (7) days before the opening brief is filed, the parties shall file a concise joint status report that identifies: (1) the claims, counterclaims, and defenses that remain to be decided; (2) the pleading in which each claim, counterclaim, or defense is asserted; and (3) each claim, counterclaim, defense, or issue for which a party will move for summary judgment.
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Page 11 | IX. SUMMARY JUDGMENT
In class settlements, the motion for attorneys' fees must be filed at least 35 days before the objection deadline, or the Court will order notices re-sent.
In proposing a schedule for final approval of a class settlement, the parties must ensure that the motion for attorneys’ fees is filed at least 35 days before the deadline for objecting to the settlement. The Court will order parties to re-send notices if the motion for attorneys’ fees is filed late.
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Page 13 | XI. CLASS ACTION SETTLEMENTS - C. Final Approval
Class counsel must file a Post-Distribution Accounting within 21 days after settlement funds are fully distributed to class members (before cy pres distribution).
Within 21 days after the settlement funds have been fully distributed to class members (but before distribution to cy pres recipients), class counsel will be required to file a Post-Distribution Accounting, as described in the Northern District’s Procedural Guidance for Class Action Settlements.
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Page 14 | XI. CLASS ACTION SETTLEMENTS - C. Final Approval
Service and Proof of Service Rules
Parties moving for emergency relief must make every reasonable effort to notify the opposing party and its counsel at the earliest possible time, or the request will likely be denied.
A party moving for emergency relief must demonstrate that it made every reasonable effort to notify the opposing party and the opposing party's counsel, at the earliest possible time, of its intent to seek emergency relief. Failure to do so will likely result in denial of the request.
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Page 2 | III. EMERGENCY APPLICATIONS
Notices of deposition must be served at least 30 days before the close of fact discovery.
Notice of depositions must be given at least 30 days prior to the close of fact discovery.
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Page 5 | VI. CASE MANAGEMENT CONFERENCES - Close of Fact Discovery
Upon filing, the moving party must provide the moving separate statement to all other parties in Microsoft Word format.
Upon filing, the moving party shall provide the moving separate statement to all other parties in Microsoft Word format for ease of response.
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Page 11 | IX. SUMMARY JUDGMENT
Discovery requests must be served sufficiently in advance of the close of fact discovery to allow time to move to compel and receive responses before the cut-off date.
Accordingly, all discovery requests shall be served sufficiently in advance of the close of fact discovery to allow the discovering party enough time prior to the cut-off date to challenge allegedly deficient responses via motion to compel and to receive the necessary responses if the motion is granted.
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Page 5 | VI. CASE MANAGEMENT CONFERENCES - Close of Fact Discovery
Courtesy Copy Requirements
The moving party must deliver two complete chambers copies of motion briefing (except administrative motions) within two court days after briefing concludes.
The moving party is required to deliver two (2) complete chambers copies of the briefing on a motion, except for administrative motions, within two (2) court days after briefing concludes.
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Page 6 | VII. FILINGS AND CHAMBERS COPIES - C. Chambers Copies
Chambers copies must be double-sided, bear the ECF stamp, have exhibits labeled on the right side, be placed in binders (max three inches) when exhibits exceed two inches thick, be marked 'Chambers Copy,' and be submitted to the Clerk's Office in an envelope marked with 'Judge Lee,' the case number, and 'Chambers Copy.'
Chambers copies should be double-sided and should bear the ECF filing “stamp” (case number, docket number, date, and ECF page number) along the top of the page when possible. All exhibits shall be clearly delineated with labels along the right side. If the filing includes exhibits over two-inches thick, the parties shall place the copies in a binder. Binders should not exceed three inches. The copies shall be marked “Chambers Copy” and submitted to the Clerk’s Office in an envelope marked with “Judge Lee,” the case number, and “Chambers Copy.”
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Page 6 | VII. FILINGS AND CHAMBERS COPIES - C. Chambers Copies
Chambers copies of sealing motions must contain only unredacted documents, and chambers copies of redacted documents shall not be submitted to the Court.
Chambers copies of sealing motions shall include only unredacted documents; chambers copies of redacted documents need not and shall not be submitted to the Court.
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Page 7 | VII. FILINGS AND CHAMBERS COPIES
In Social Security appeals, the Commissioner must submit one tabbed, binder-format chambers copy of the administrative record to the Clerk's Office within five court days after e-filing it, labeled with the case number, 'Judge Lee,' and 'Chambers Copy.'
For Social Security appeals, the Court requests that the Commissioner submit one chambers copy of the administrative record within five court days after electronically filing it. The chambers copy should be placed in one or more binders. Each document should be tabbed with labels along the right side. The chambers copy should be submitted to the Clerk’s Office and labeled with the case number, “Judge Lee,” and “Chambers Copy.”
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Page 6 | VII. FILINGS AND CHAMBERS COPIES - C. Chambers Copies
Chambers copies must be marked and submitted to Clerk's Office.
The copies shall be marked “Chambers Copy” and submitted to the Clerk’s Office, in an envelope marked with “Judge Lee,” the case number, and “Chambers Copy.”
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Social Security appeals require chambers copy within 5 court days.
For Social Security appeals, the Court requests that the Commissioner submit one chambers copy of the administrative record within five court days after electronically filing it.
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One chambers copy required for all filings except administrative motions.
The parties are required to submit one (1) chambers copy of all filings except for administrative motions.
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Chambers copies of sealing motions must include unredacted documents with yellow highlighting.
Chambers copies of sealing motions shall include only unredacted documents; chambers copies of redacted documents need not and shall not be submitted to the Court. Chambers copies of unredacted documents shall clearly indicate with yellow highlighting the portions that the party is requesting to seal.
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Social Security chambers copies must be labeled and submitted to Clerk.
The chambers copy should be submitted to the Clerk’s Office and labeled with the case number, “Judge Lee,” and “Chambers Copy.”
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Exhibits and visual aids must be exchanged and bound copies submitted to the Court at least one week before the tutorial or hearing.
No later than one (1) week prior to the tutorial and/or claim construction hearing, counsel shall exchange copies of any exhibits and visual aids and shall submit to the Court bound copies of the exhibits and visual aids.
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Page 4 | C. Claim Construction Hearing
Chambers copies required within 2 court days, double-sided with ECF stamp.
Unless the Court specifically orders otherwise, one chambers copy of all law and motion papers shall be submitted to the Clerk’s Office. Chambers copies should be double-sided and should bear the ECF filing “stamp” (case number, docket number, date, and ECF page number) along the top of the page. All exhibits shall be clearly delineated with labels along the right side. If the filing includes exhibits over two (2) inches thick, the parties shall place the copies in a binder. The copies shall be marked “Chambers Copy” and submitted to the Clerk’s Office in an envelope marked with the case number and “Chambers Copy.” Chambers copies shall be mailed for receipt or delivered to the Clerk’s Office within two (2) court days after the materials are filed.
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Page 2 | V. CHAMBERS COPIES
Sealing & Redaction Procedures
Strict compliance with Civil Local Rule 79-5 is required: the filing party must make a specific showing for each statement or document to be sealed, and overbroad or generic sealing requests may be denied in their entirety.
The Court requires strict compliance with Civil Local Rule 79-5. Public access to court records is a fundamental aspect of our democracy and justice system. The filing party must make a specific showing as to each statement or document to be sealed. Blanket requests that make generic reference to "competitive harm" are almost always insufficient. If a party files a request that is significantly overbroad or fails to provide a specific reason for sealing, the Court may deny the request in its entirety.
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Page 7 | VII. FILINGS AND CHAMBERS COPIES
Documents filed under seal must be highlighted to show the proposed redactions, or labeled to indicate that sealing is sought in full.
Each document filed under seal must be highlighted to show the proposed redactions. If a party believes it is appropriate to seal an entire document, the filed document should be labeled to indicate that sealing is sought in full.
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Page 7 | VII. FILINGS AND CHAMBERS COPIES
Motions to seal must include a chart with specific columns.
In addition to complying with Civil Local Rule 79-5, each motion to seal must include a chart, in the format set forth below, which includes the following columns: (1) ECF number or exhibit number of the document sought to be sealed; (2) description or name of the document sought to be sealed; (3) portion(s) of the document to seal; and (4) reason(s) why the document should be sealed, including citation to the applicable declaration.
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Strict compliance required with Civil Local Rule 79-5 for sealed documents.
The Court requires strict compliance with Civil Local Rule 79-5.
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Sealed documents must be highlighted to show proposed redactions.
Each document filed under seal must be highlighted to show the proposed redactions. If a party believes it is appropriate to seal an entire document, the filed document should be labeled to indicate that sealing is sought in full.
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Sealed documents require paper and electronic courtesy copies with highlighted redactions.
For any documents submitted under seal, the parties shall provide a courtesy paper copy as required by Criminal Local Rule 56-1, and a courtesy electronic copy via flash drive. Chambers copies of sealing motions shall include only unredacted documents, with any proposed redactions highlighted.
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Page 2 | VI. SEALED DOCUMENTS
Parties must provide specific justification for sealing documents and narrowly tailored redactions.
party must make a specific showing explaining why each document that it seeks to seal may justifiably be sealed and why the proposed redactions are as narrowly tailored as possible.
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Page 3 | VI. SEALED DOCUMENTS
Filing Bundling Requirements
Joined motions count toward the filing party's page limits, and parties represented by the same counsel must file a single combined brief complying with the applicable page limits, absent leave of court.
If a party files its own motion and joins in another party's motion, both the party's own motion and the joined motion will count toward the party's page limits. Where multiple parties are represented by the same counsel, all motions filed by those parties are limited to a single brief which complies with the page limits set forth above, absent leave of court.
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Page 8 | VIII. MOTIONS AND HEARINGS - B. Page Limits
Parties are encouraged to meet and confer before filing a motion and to submit a joint appendix of evidence.
If possible, the parties should meet and confer prior to filing a motion and submit a joint appendix of evidence.
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Page 6 | VII. FILINGS AND CHAMBERS COPIES - B. Documents Filed on ECF
Motions must be filed within 14 days of reserving a hearing date or the reservation expires.
Once a hearing date is reserved, the motion(s) shall be filed within fourteen (14) days thereafter. Failure to timely file any motion will result in the expiration of the hearing reservation without further notice to the parties, and the moving party must obtain a new reservation before filing the motion(s).
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Page 3 | MOTIONS AND HEARINGS
Initial case management conference can be moved 21 days after dispositive motion hearing.
If a defendant files a motion to dismiss that is dispositive of the entire case, the parties can stipulate to move the initial case management conference 21 days after the hearing on that motion. Otherwise, the initial case management conference generally will not be moved.
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Page 3 | CASE MANAGEMENT CONFERENCES
Further case management conference scheduled 4-8 weeks before close of fact discovery.
Further Case Management Conference - Four to eight (4-8) weeks before the close of fact discovery
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Page 4 | CASE MANAGEMENT CONFERENCES
Pre-Motion Conference Requirements
Civil motions are only heard if a hearing date is reserved in advance.
Civil motions are heard by reservation only.
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Page 2 | V. SCHEDULING
The moving party must meet and confer with opposing parties in person or by videoconference at least seven days before filing any motion and disclose the bases for the anticipated motion.
At least seven (7) days before filing any motion, the moving party must meet and confer with the opposing party or parties in person or by videoconference. During the conference, the moving party shall disclose the bases for its anticipated motion. The purpose of this conference is to resolve or narrow disputed issues where possible to reduce motion practice.
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Page 8 | VIII. MOTIONS AND HEARINGS - A. Meet and Confer Requirement
Parties must meet and confer to determine whether they will file cross-motions for summary judgment unless otherwise ordered.
Unless otherwise ordered, the parties must meet and confer to determine if they will file cross-motions for summary judgment.
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Page 11 | IX. SUMMARY JUDGMENT
Upon a discovery impasse, counsel must first meet and confer in person or via videoconference; a mere exchange of letters, emails, or telephone calls does not satisfy the requirement.
Upon the development of an impasse with respect to discovery, the parties must first meet and confer; that is, counsel for each party shall meet and confer in person or via videoconference to attempt to resolve their dispute informally. A mere exchange of letters, emails, or telephone calls does not satisfy the meet and confer requirement.
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Page 12 | X. DISCOVERY
Before reserving a civil motion hearing date, parties must meet and confer to identify proposed hearing dates acceptable to all relevant parties (sentence continues beyond this excerpt).
After reviewing the website, parties and counsel shall meet and confer to identify proposed hearing dates that are amenable to all relevant
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Page 2 | V. SCHEDULING
The meet-and-confer requirement is excused only in emergencies where compliance is unreasonable, and even then the moving party must certify advance notice to all relevant parties and detail its meet-and-confer efforts.
The meet-and-confer requirement will be excused only under emergency circumstances where the moving party cannot reasonably comply. In such cases, the moving party must still certify that it has notified all other relevant parties in advance of filing its motion, and must detail the efforts made to meet and confer.
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Page 8 | VIII. MOTIONS AND HEARINGS - A. Meet and Confer Requirement
The Court generally requires completion of an ADR Local Rule 3-4 process (ENE, Mediation, or Private ADR) before referring a case for magistrate judge settlement, with exceptions discussed in the initial case management statement.
The Court generally does not refer cases for settlement with a magistrate judge unless the parties have already completed one of the other processes set forth in ADR Local Rule 3-4 (i.e., Early Neutral Evaluation, Mediation, or Private ADR). Parties who complete one of these processes without reaching a settlement may request referral to a magistrate judge at that time. If the parties believe their case merits an exception to this rule, they should discuss their views in the initial case management statement.
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Page 14 | XII. REQUESTS FOR MAGISTRATE JUDGE SETTLEMENT CONFERENCES
Magistrate judge settlement conferences require prior ADR process completion.
The Court generally does not refer cases for settlement with a magistrate judge unless the parties have already completed one of the other processes set forth in ADR Local Rule 3-4 (i.e., Early Neutral Evaluation, Mediation, or Private ADR).
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Page 14 | Requests for Magistrate Judge Settlement Conferences
Motion notice must certify meet-and-confer requirement was satisfied.
In the notice of motion, counsel for the moving party must certify that this meet-and-confer requirement has been satisfied, citing specifically to this section of the Civil Standing Order. If the notice of motion does not include such a certification, the Court may strike the motion and order the moving party to re-file the motion with a certification once the meet-and-confer requirement has been met.
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Meet and confer required at least 7 days before filing any motion.
At least seven (7) days before filing any motion, the moving party must meet and confer with the opposing party or parties in person or by videoconference. During the parties’ conference, the moving party shall disclose the bases for its anticipated motion. The purpose of this conference is to resolve or narrow disputed issues where possible to reduce motion practice.
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Opening claim construction briefs must be filed at least 6 weeks before the hearing.
Opening briefs in support of claim construction must be filed at least six (6) weeks before the date of the claim construction hearing, and the briefing schedule set forth at Patent Local Rule 4-5 will apply.
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Page 3 | D. Timing
Motion briefing deadlines: 21 days for motions, 14 days for opposition, 7 days for reply.
All motions shall comply with Criminal Local Rule 47-2. Unless otherwise ordered, the parties may stipulate to any mutually agreeable briefing schedule so long as all briefing is complete at least seven (7) days in advance of the hearing date. In the absence of a stipulation, motions (except those pertaining to sentencing) shall be filed at least 21 days in advance of the hearing date. Opposition briefs shall be filed at least fourteen (14) days in advance of the hearing date. Reply briefs shall be filed at least (7) seven days in advance of the hearing date.
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Page 2 | IV. MOTIONS
Meet-and-confer requirement excused only for emergencies with notification.
The meet-and-confer requirement will be excused only under emergency circumstances where the moving party cannot reasonably comply. In such cases, the moving party must still certify that it has notified all other relevant parties in advance of filing its motion, and must detail the efforts made to meet and confer.
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Live testimony at claim construction requires a court order obtained via administrative motion filed at least 14 days before the hearing.
Live testimony at claim construction is disfavored; it will be allowed only by court order upon an administrative motion explaining why the testimony would be useful. Such a motion must be filed at least fourteen (14) days before the hearing.
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Page 4 | C. Claim Construction Hearing
Settlement conference referral allowed after unsuccessful ADR completion.
Parties who complete one of these processes without reaching a settlement may request referral to a magistrate judge at that time.
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Page 14 | Requests for Magistrate Judge Settlement Conferences
Adjournment & Extension Requirements
Continuance/extension requests must indicate in the caption the number of previous extensions requested and must state whether the Court granted them and whether it has said no further extensions will be granted.
The caption of any request for a continuance or extension shall indicate how many previous extensions have been requested (e.g., "First Request for Extension"). The request must state whether the Court has granted those extensions and whether the Court has stated that no further extensions will be granted.
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Page 3 | V. SCHEDULING
After the scheduling order issues, continuances in civil cases are granted only upon a showing of good cause under Fed. R. Civ. P. 16(b)(4).
After the Court issues a scheduling order, continuances in civil cases are granted only upon a showing of good cause. See Fed. R. Civ. P. 16(b)(4).
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Page 3 | V. SCHEDULING
Requests for continuances or extensions requiring a court order must be filed no later than 3 court days before the deadline being extended.
Any request for a continuance or extension of time that requires a court order must be filed not later than three (3) court days prior to the deadline that the party wishes to extend.
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Page 3 | V. SCHEDULING
Parties and counsel must actually demonstrate good cause for continuances or extensions and may not merely stipulate that good cause exists.
Parties and counsel must demonstrate good cause; they may not simply stipulate that good cause has been shown.
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Page 3 | V. SCHEDULING
Trial dates will not be continued absent a strong showing of good cause.
Trial dates will not be continued absent a strong showing of good cause.
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Page 6 | VI. CASE MANAGEMENT CONFERENCES
Continuance or extension requests must include a proposed order charting all future deadlines, the proposed extensions, and the impact on the case schedule.
When any party requests a continuance or extension of time, the party must file a proposed order listing, in chart format, all future deadlines and the proposed extensions, illustrating how the requested relief would impact the case schedule.
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Page 9 | C. Proposed Orders
Administrative motions to enlarge page limits must be filed at least five court days before the underlying motion, with any opposition due at least three court days before the underlying motion or within the Civil L.R. 7-11 time, whichever is sooner.
If the request is made by administrative motion rather than stipulation, the motion must be filed at least five (5) court days prior to filing the underlying motion and any opposition must be filed: (a) at least three (3) court days before the underlying motion is filed; or (b) within the time allowed by Civil Local Rule 7-11, whichever is sooner.
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Page 9 | VIII. MOTIONS AND HEARINGS
Stipulated requests to enlarge page limits are rarely granted and must be filed at least three court days before the underlying motion.
Requests to enlarge page limits will rarely be granted. Stipulated requests must be filed at least three (3) court days prior to filing the underlying motion.
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Page 9 | VIII. MOTIONS AND HEARINGS
Parties may stipulate to move the initial case management conference to 21 days after the hearing on a case-dispositive motion to dismiss; otherwise the initial CMC generally will not be moved.
If a defendant files a motion to dismiss that is dispositive of the entire case, the parties can stipulate to move the initial case management conference to 21 days after the hearing on that motion. Otherwise, the initial case management conference generally will not be moved.
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Page 3 | VI. CASE MANAGEMENT CONFERENCES
Emergency relief requires reasonable effort to notify opposing party and counsel.
A party moving for emergency relief must demonstrate that it made every reasonable effort to notify the opposing party and the opposing party's counsel, at the earliest possible time, of its intent to seek emergency relief. Failure to do so will likely result in denial of the request.
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Page 2 | EMERGENCY APPLICATIONS
Continuance requests must be filed at least 3 court days before the deadline.
After the Court issues a scheduling order, continuances in civil cases are granted only upon a showing of good cause. See Fed. R. Civ. P. 16(b)(4). Any request for a continuance or extension of time (other than an extension that the Rules allow the parties to arrange between themselves without a court order) must be filed not later than three (3) court days prior to the deadline that the party wishes to extend.
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Page 3 | MOTIONS AND HEARINGS
Briefing schedules must allow 14 days (28 days for SJ/Daubert/class cert) between final filing and hearing unless good cause shown.
The parties may stipulate to and request Court approval of a briefing schedule that differs from that set forth in the Civil Local Rules, noting the differences in their stipulation. Absent good cause, however, the briefing schedule for any motion shall allow at least fourteen (14) days between the final filing and the hearing date. The briefing schedule for summary judgment, Daubert, and class certification motions shall allow at least 28 days between the final filing and the hearing date.
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Page 9 | Briefing Schedules
Zoom appearance requests must be filed and served at least 1 week before hearing.
Parties wishing to appear via Zoom shall file and serve an administrative request to appear via Zoom and a proposed order at least one (1) week prior to the scheduled hearing date. If all parties wish to appear via Zoom, the parties should file a joint administrative request or indicate that the request is unopposed.
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Page 10 | Hearings on civil motions
Demonstratives must be exchanged and submitted 48 hours before hearing (by Friday 5pm if weekend).
Any demonstratives or audio-visual presentations to be used at a hearing must be exchanged with opposing counsel and submitted to the Court at least 48 hours before the hearing. If this date falls on a weekend, parties are required to exchange and submit them by Friday at 5:00 p.m. Parties shall email electronic copies of the demonstratives or presentations to Judge Lee's Courtroom Deputy at eklcrd@cand.uscourts.gov.
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Page 10 | Demonstratives and Presentations
Continuance requests must be filed 3 court days before hearing with proposed order.
To request a continuance of a scheduled hearing, counsel must file a proposed order, preferably by stipulation, including whether time under the Speedy Trial Act should be excluded, no later than three (3) court days before the scheduled hearing.
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Page 1 | II. SCHEDULING
Discovery cut-off is 14 days before pretrial conference; late disclosure may be excluded unless good cause shown and disclosed within 24 hours.
Absent a contrary order from the Court, the discovery cut-off date is fourteen (14) days before the pretrial conference. Any material disclosed after that date may be excluded unless the disclosing party: (a) can show good cause for why it was not sought, obtained, and disclosed sooner; and (b) discloses it within 24 hours of receipt of the material.
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Page 3 | VIII. DISCOVERY CUT-OFF
Page limit enlargement requests require 3-5 court days advance notice depending on type.
Requests to enlarge page limits will rarely be granted. Stipulated requests must be filed at least three (3) court days prior to filing the underlying motion. If the request is made by administrative motion rather than stipulation, the motion must be filed at least five (5) court days prior to filing the underlying motion and any opposition must be filed: (a) at least three (3) court days before the underlying motion is filed; or (b) within the time allowed by Civil Local Rule 7-11, whichever is sooner.
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Page 9 | Requests to enlarge page limits
Chambers Communication Rules
Ex parte communication with Judge Lee or her chambers staff by telephone, fax, email, or any other means is prohibited unless authorized in advance.
Parties and counsel shall not engage in any ex parte communication with Judge Lee or her chambers staff by telephone, facsimile, e-mail, or any other means, unless such contact has been authorized in advance.
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Page 2 | II. COMMUNICATION WITH THE COURT
Parties must email chambers to reserve a hearing date and must indicate the number and type(s) of motions to be filed when reserving.
eklcrd@cand.uscourts.gov to reserve a hearing date. When reserving a hearing date, parties must indicate the number and type(s) of motions to be filed.
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Page 3 | V. SCHEDULING
Parties must email electronic copies of demonstratives or presentations to Judge Lee's Courtroom Deputy at eklcrd@cand.uscourts.gov.
Parties shall email electronic copies of the demonstratives or presentations to Judge Lee's Courtroom Deputy at eklcrd@cand.uscourts.gov.
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Page 10 | F. Demonstratives and Presentations
Counsel should call and email the Courtroom Deputy to notify chambers of TRO applications, stipulations requiring a response within 24 hours, or any other emergency request.
Counsel should call and email Judge Lee's Courtroom Deputy at (408) 535-5330 and eklcrd@cand.uscourts.gov to notify her if they submit an application for a temporary restraining order, a stipulation that requires a response from the Court within 24 hours, or any other emergency request.
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Page 2 | III. EMERGENCY APPLICATIONS
All counsel and unrepresented parties must be copied on any email communication with Judge Lee's Courtroom Deputy.
All counsel and unrepresented parties shall be included on any e-mail communications with Judge Lee's Courtroom Deputy.
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Page 2 | II. COMMUNICATION WITH THE COURT
Judge Lee does not review or respond to letters or letter briefs seeking relief or providing case information, even if filed on the docket.
Judge Lee does not review or respond to letters or letter briefs providing case information or seeking relief from the Court, even if the letter is filed on the docket.
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Page 2 | II. COMMUNICATION WITH THE COURT
Parties may email Judge Lee's Courtroom Deputy at eklcrd@cand.uscourts.gov for scheduling and other administrative inquiries.
Parties and counsel may contact Judge Lee's Courtroom Deputy at eklcrd@cand.uscourts.gov with inquiries regarding scheduling or other administrative matters.
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Page 2 | II. COMMUNICATION WITH THE COURT
No ex parte communication with Judge Lee or chambers staff allowed without advance authorization.
Parties and counsel shall not engage in any ex parte communication with Judge Lee or her chambers staff by telephone, facsimile, e-mail, or any other means, unless such contact has been authorized in advance. Parties and counsel may contact Judge Lee's Courtroom Deputy at eklcrd@cand.uscourts.gov with any inquiries regarding scheduling or other administrative matters. All counsel and unrepresented parties shall be included on any e-mail communications with Judge Lee's Courtroom Deputy.
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Page 2 | COMMUNICATION WITH THE COURT
Emergency applications require notification to Courtroom Deputy by phone and email.
Counsel should call and email Judge Lee's Courtroom Deputy at (408) 535-5330 and eklcrd@cand.uscourts.gov to notify her if they submit an application for a temporary restraining order, a stipulation that requires a response from the Court within 24 hours, or any other emergency request.
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Page 2 | EMERGENCY APPLICATIONS
Judge Lee does not review letters or letter briefs seeking relief.
Judge Lee does not review or respond to letters or letter briefs providing case information or seeking relief from the Court, even if the letter is filed on the docket. All requests requiring the Court to take action shall be made either by stipulation and proposed order or by an appropriate motion filed pursuant to the Civil Local Rules.
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Page 2 | COMMUNICATION WITH THE COURT
Civil motions require reservation and meet-and-confer for hearing dates.
Civil motions are heard by reservation only. After reviewing the website, parties and counsel shall meet and confer to identify proposed hearing dates that are amenable to all relevant
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Page 3 | SCHEDULING
Government must email plea agreement to chambers 3 court days before plea.
If a plea is being entered pursuant to a plea agreement, government counsel shall email a copy of the plea agreement to Courtroom Deputy Laura Thomson at eklcrd@cand.uscourts.gov no later than noon three (3) court days before the plea is to be entered.
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Page 1 | III. CHANGE OF PLEA
Motions must be reserved by contacting chambers deputy.
Motions must be noticed for hearing in accordance with Criminal Local Rule 47-1. Criminal motions are heard by reservation only. To reserve a hearing date, parties shall contact Judge Lee’s Courtroom Deputy, Laura Thomson, at (408) 535-5330 or eklcrd@cand.uscourts.gov.
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Page 2 | IV. MOTIONS
Hearings are in-person; Zoom requests require meet-and-confer and are considered case-by-case.
Hearings on civil motions will be held in-person. The Court will consider requests to appear via Zoom on a case-by-case basis. Joint requests are strongly preferred, and parties are required to meet and confer regarding such requests. If a request is granted, it will generally be applicable to all parties participating in the hearing as hybrid hearings are discouraged.
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Page 10 | Hearings on civil motions
The moving party must email a Word copy of each proposed order to eklpo@cand.uscourts.gov with the case number, case name, and order title in the subject line, and that email may not be used for substantive communications.
In addition, the moving party should submit a Microsoft Word copy of the proposed order to eklpo@cand.uscourts.gov. ... The subject line of the email should include the case number and name, along with the title of the order. The email should not be used by litigants for substantive communications.
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Page 9 | C. Proposed Orders
Case management conferences are held remotely via Zoom unless otherwise ordered.
Unless the Court orders otherwise, case management conferences will be held remotely via Zoom. Parties may request an in-person hearing.
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Page 3 | CASE MANAGEMENT CONFERENCES
Pro se parties may contact Federal Pro Se Program for limited legal services.
Parties representing themselves may wish to contact the Federal Pro Se Program, a free program that offers limited legal services to pro se litigants.
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Page 14 | Unrepresented Parties
Parties must email the Courtroom Deputy to arrange audio-visual equipment testing before the tutorial.
Prior to the tutorial, the parties shall contact the Courtroom Deputy via email @cand.uscourts.gov to arrange to test any audio-visual equipment if needed.
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Page 4 | A. Tutorial
Junior Lawyer Participation Incentives
The Court welcomes and encourages oral argument by less-experienced attorneys on any matter, and more experienced counsel for the same party may still argue briefly at the end of the hearing.
The Court welcomes and encourages oral argument by less-experienced attorneys on any matters before the Court. More experienced counsel for the same party may still offer argument for a few minutes at the end of the hearing.
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Page 10 | VIII. MOTIONS AND HEARINGS
Less-experienced attorneys are encouraged to argue; experienced counsel may argue briefly at end.
The Court welcomes and encourages oral argument by less-experienced attorneys on any matters before the Court. More experienced counsel for the same party may still offer argument for a few minutes at the end of the hearing.
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Page 10 | The Court welcomes and encourages oral argument