Judge Vince Chhabria
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Chambers Copy
- Not required
Courtesy copies
- Not required
- Upon request
Exhibits, Declarations, Motions
- 1 copy • Flash Drive • Within 7 Business Days
Binding: Flash Drive
Motion Brief, Supporting Document
- Upon request
Adjournments
- Requests to extend case management deadlines must be submitted 72 hours prior to the deadline.
- Requests to reschedule a case management conference must be submitted at least 72 hours prior to the conference.
- Motions to continue hearings or case management conferences must be filed at least 72 hours before the scheduled appearance; no schedule changes are permitted without a court order.
- +10 more
- Extension requests must include a proposed order with future deadlines and extensions, a chart of current and proposed deadlines, and if parties disagree, details of prior extension requests.
- Trial dates are firm and will not be continued except in extraordinary circumstances.
- Continuances of case schedules for mediation or settlement are usually not granted.
- +3 more
Request must include
- Case management conference can be moved to 15 days after dispositive motion to dismiss hearing.
- Hearings are typically vacated no later than three days before the scheduled date if not needed.
Communication
Clerk
Chambers
Phone
Clerk
Chambers
Chambers
In Person
Chambers
Page & Word Limits43 rules
Machine summary. Not checked yet.Mandatory?
Emergency applications do not have to comply with Judge Chhabria’s default 15-page limit for briefs.
Summary: Briefs are limited to 15 pages, with emergency applications exempt from this limit.
Brief
15 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
If the parties cannot resolve their discovery dispute after a good faith effort, they shall prepare and file a joint letter of no longer than 5 pages stating the nature and status of their dispute.
Summary: Joint discovery dispute letters are limited to 5 pages.
Joint Discovery Letter
5 pages
Machine summary. Not checked yet.Mandatory?
Briefs in support of and in opposition to a preliminary injunction motion cannot exceed 25 pages, and reply briefs cannot exceed 15 pages.
Summary: Preliminary injunction briefs (support/opposition) limited to 25 pages; reply briefs to 15 pages.
Brief
25 pages
Applies to: Attorney
Reply Brief
15 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Unless permitted by the Court, briefs in support of and in opposition to all substantive motions (except for preliminary injunction motions, summary judgment motions, class certification motions, motions for approval of class settlements, and summary judgment / claim construction motions in patent cases, as discussed below) may not exceed 15 pages, and reply briefs may not exceed 10 pages. These page limits include summaries of argument and exclude the title page, table of contents, table of authorities, and exhibits.
Summary: Briefs in support/opposition to most substantive motions are limited to 15 pages; reply briefs to 10 pages, excluding title page, TOC, TOA, and exhibits.
Brief
15 pages
Applies to: Attorney
Reply Brief
10 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Unless permitted by the Court, briefs in support of and in opposition to summary judgment motions cannot exceed 25 pages, and reply briefs cannot exceed 15 pages.
Summary: Summary judgment briefs (support/opposition) limited to 25 pages; reply briefs to 15 pages.
Brief
25 pages
Applies to: Attorney
Reply Brief
15 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
The only exception is when the party moving to exclude is the party opposing summary judgment, in which case that party may file a reply brief (not to exceed 5 pages and filed no later than 7 days after the other party’s reply in support of summary judgment) in support of the Daubert motion.
Summary: Daubert reply briefs filed by the party opposing summary judgment are limited to 5 pages.
Reply Brief
5 pages
Machine summary. Not checked yet.Mandatory?
The first two briefs are limited to 25 pages, the third brief is limited to 20 pages, and the fourth brief is limited to 15 pages.
Summary: For cross-motions for summary judgment, the four sequential briefs are limited to 25 pages (first two), 20 pages (third), and 15 pages (fourth).
Opening Brief
25 pages
Opening Opposition Brief
25 pages
Opposition Reply Brief
20 pages
Reply Brief
15 pages
Machine summary. Not checked yet.Mandatory?
The only exception is when the party moving to exclude is the party opposing class certification, in which case that party may file a reply brief (not to exceed 5 pages and filed no later than 7 days after the other party’s reply in support of class certification) in support of the Daubert motion.
Summary: Reply briefs in support of a Daubert motion filed by the party opposing class certification are limited to 5 pages.
Reply Brief
5 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Briefs in support of or opposition to class certification motions cannot exceed 25 pages, and reply briefs cannot exceed 15 pages. These limits also apply to motions for preliminary or final approval of class settlements (although, if the parties believe they need more space to adequately explain the basis for a class action settlement, this is the one type of brief for which a request for additional pages is likely to be granted).
Summary: Briefs supporting or opposing class certification motions and class settlement approval motions are limited to 25 pages; reply briefs for these matters are limited to 15 pages, with additional pages likely granted for settlement briefs upon request.
Brief
25 pages
Applies to: Attorney
Reply Brief
15 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
The opening summary judgment (and claim construction) brief, as well as the opposition brief, cannot exceed 40 pages. The reply brief cannot exceed 20 pages.
Summary: Opening and opposition summary judgment/claim construction briefs limited to 40 pages; reply briefs limited to 20 pages.
Brief
40 pages
Applies to: Attorney
Reply Brief
20 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
is limited to 50 pages, the third brief is limited to 30 pages, and the fourth brief is limited to 20 pages.
Summary: For cross-motions for summary judgment, first brief limited to 50 pages, third to 30 pages, fourth to 20 pages.
Brief
50 pages
Applies to: Attorney
Brief
30 pages
Applies to: Attorney
Brief
20 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Unless expressly permitted by the Court, briefs in support of and in opposition to all substantive motions (except for preliminary injunction motions, summary judgment motions,
Summary: Briefs limited to 15 pages (support/opposition) and 10 pages (reply) for most substantive motions.
Brief
Machine summary. Not checked yet.Mandatory?
Unless expressly permitted by the Court, briefs in support of and in opposition to summary judgment motions cannot exceed 25 pages, and reply briefs cannot exceed 15 pages.
Summary: Summary judgment briefs limited to 25 pages (support/opposition) and 15 pages (reply).
Brief
25 pages
Applies to: Attorney
Reply Brief
15 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Briefs in support of and in opposition to a preliminary injunction motion cannot exceed 25 pages, and reply briefs cannot exceed 15 pages.
Summary: Preliminary injunction briefs limited to 25 pages (support/opposition) and 15 pages (reply).
Brief
25 pages
Applies to: Attorney
Reply Brief
15 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Briefs in support of or opposition to class certification motions cannot exceed 25 pages, and reply briefs cannot exceed 15 pages.
Summary: Class certification briefs limited to 25 pages (support/opposition) and 15 pages (reply).
Brief
25 pages
Applies to: Attorney
Reply Brief
15 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
The only exception is when the party moving to exclude is the party opposing class certification, in which case that party may file a reply brief (not to exceed 5 pages and filed no later than 7 days after the other party’s reply in support of class certification) in support of the Daubert motion.
Summary: Opposing party may file 5-page Daubert reply brief within 7 days of class certification reply.
Reply Brief
5 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
If the parties cannot resolve their discovery dispute after a good faith effort, they shall prepare and file a joint letter of no longer than 5 pages stating the nature and status of their dispute. Both sides must submit proposed orders as well.
Summary: Discovery disputes require joint letter (max 5 pages) with proposed orders.
Joint Discovery Letter
5 pages
Machine summary. Not checked yet.Mandatory?
The opening summary judgment (and claim construction) brief, as well as the opposition brief, cannot exceed 40 pages. The reply brief cannot exceed 20 pages.
Summary: Summary judgment briefs limited to 40 pages (opening/opposition) and 20 pages (reply).
Brief
40 pages
Applies to: Attorney
Reply Brief
20 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Following each set of proposed versions of a disputed instruction, each party shall explain, in no more than one page, why the Court should give that party’s proposed instruction. Following the disputed instruction, each party shall explain, in no more than one page, why the instruction should or should not be given.
Summary: Explanations of disputed jury instructions must not exceed one page.
Jury Instruction Explanation
1 pages
Machine summary. Not checked yet.Mandatory?
The memoranda in support of and in opposition to each motion in limine shall be no longer than five pages.
Summary: Memoranda in support of and opposition to motions in limine are limited to 5 pages.
Motion In Limine Support
5 pages
Motion In Limine Opposition
5 pages
Machine summary. Not checked yet.Mandatory?
Unless the case is extremely complex, this statement should not exceed one page (double-spaced).
Summary: The proposed Statement of the Case is limited to one double-spaced page unless the case is extremely complex.
Statement Of The Case
1 pages
Machine summary. Not checked yet.Mandatory?
If a party objects to prospective jurors’ viewing this video, the party must file a short statement (not to exceed one page double-spaced) explaining its objection.
Summary: Objections to the unconscious bias jury video must be filed as a statement not exceeding one double-spaced page.
Objection Statement
1 pages
Machine summary. Not checked yet.Mandatory?
They must include trial briefs not to exceed 10 pages each
Summary: Trial briefs in non-jury civil cases are limited to 10 pages.
Trial Brief
10 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
The opening summary judgment (and claim construction) brief, as well as the opposition brief, cannot exceed 40 pages. The reply brief cannot exceed 20 pages.
Summary: Summary judgment briefs have 40-page limit for opening/opposition and 20-page limit for reply.
Summary Judgment Brief
40 pages
Applies to: Attorney
20 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Following the disputed instruction, each party shall explain, in no more than one page, why the instruction should or should not be given.
Summary: Explanation of disputed jury instruction limited to one page.
Jury Instructions
1 pages
Applies to: Attorney
Document Format Requirements39 rules
Machine summary. Not checked yet.Mandatory?
The name of each uploaded PDF file should adhere to the naming convention described above and should include the docket number of the docket number 60-2 should be uploaded with the file name “[60-2] Decl Doe Ex 1 - News Release.”
Summary: Uploaded PDF attachments must follow the required naming convention, including the docket number and document description.
Machine summary. Not checked yet.Mandatory?
The flash drive should be labeled with the name and number of the case. The flash drive should contain the ECF version of each attachment, with its ECF header. The name of each PDF file on the flash drive should include the type of document, a brief description of the document, and the docket number. Each PDF document must be text-searchable. This requirement is waived for people proceeding pro se.
Summary: Flash drives delivered to chambers must be labeled with the case name and number; PDF attachments must be text-searchable, include the ECF header, and follow proper file naming, except for pro se litigants.
Machine summary. Not checked yet.Mandatory?
All briefs must use Times New Roman font (size 12) and must be double spaced.
Summary: All briefs must use Times New Roman size 12 font and double spacing.
Machine summary. Not checked yet.Mandatory?
If the proposed notices are not carefully written and in plain English, the Court will reject the motion for preliminary approval.
Summary: Proposed notices must be carefully written and in plain English, or the motion for preliminary approval will be rejected.
Machine summary. Not checked yet.Mandatory?
These page limits include summaries of argument and exclude the title page, table of contents, table of authorities, and exhibits. All briefs must use Times New Roman font (size 12) and must be double spaced.
Summary: Briefs must use Times New Roman 12pt, double-spaced, with specific exclusions from page count.
Machine summary. Not checked yet.Mandatory?
When filing motions on ECF, each motion, supporting declaration, and attachment to a declaration (such as an exhibit) should be filed as a separate PDF. That is, a declaration must be filed separately from the motion, and each exhibit to a declaration must be filed separately from the declaration and from the other exhibits.
Summary: Motions and declarations must be filed as separate PDFs on ECF.
Machine summary. Not checked yet.Mandatory?
Word Versions of Pretrial Filings
Summary: Pretrial filings must be submitted in Word (DOCX) format.
DOCX
Machine summary. Not checked yet.Mandatory?
The parties shall jointly file, and send in Word format to vcpo@cand.uscourts.gov, a list of people involved in the case.
Summary: The Involved Individuals List must be sent in Word format.
DOCX
Machine summary. Not checked yet.Mandatory?
The proposed supplemental jury questions, Joint Pretrial Conference Statement, jury instructions, involved individuals list, and verdict form(s) shall be submitted in Microsoft Word format via e-mail to vcpo@cand.uscourts.gov when they are filed.
Summary: Specified pretrial documents must be in Microsoft Word format.
DOCX
Machine summary. Not checked yet.Mandatory?
Exhibits shall be sequentially numbered (not lettered). If possible, parties shall use the same number to mark an exhibit for trial as that used in depositions. Blocks of numbers should be assigned to fit the needs of the case (e.g., Plaintiff has 1 to 100, Defendant A has 101 to 200, Defendant B has 201 to 300, etc.).
Summary: Exhibits must be sequentially numbered without letters, using deposition numbers if possible and party-specific blocks.
Machine summary. Not checked yet.Mandatory?
No later than 5 days before trial, the parties shall upload official copies of all exhibits to an online location designated by the Clerk’s Office, with each exhibit as a separate file, and with each file named so that the exhibits appear sequentially when sorted by file name.
Summary: All trial exhibits must be uploaded as separate files named sequentially to sort in order.
Machine summary. Not checked yet.Mandatory?
To avoid any party claiming “ownership” of an exhibit, all exhibits shall be marked and referred to as “Trial Exhibit No. _____,” not as “Plaintiff’s Exhibit” or “Defendant’s Exhibit.”
Summary: All exhibits must be marked and referred to as 'Trial Exhibit No. _____' rather than party-specific names.
Machine summary. Not checked yet.Mandatory?
Exhibit tags shall be placed on or near the lower right-hand corner of each exhibit, unless the exhibit is a photograph, in which case the tag shall be placed on the back. If an exhibit is a multipage document and there is no room on the front of the first page then the exhibit sticker must be placed on the back of the last page of the document in the lower left corner.
Summary: Exhibit tags must be placed in specified locations based on exhibit type and page count.
Machine summary. Not checked yet.Mandatory?
exhibit, the defendant should not re-mark the same document with another number. Different versions of the same document (e.g., versions of a document with and without additional handwriting), however, must be treated as different exhibits and marked with different numbers.
Summary: Defendants should not re-mark the same document with a new number; different document versions are separate exhibits.
Machine summary. Not checked yet.Mandatory?
Publication must be by poster blow-up, transmission via courtroom technology, or such other method as is allowed in the circumstances. It is permissible to highlight, circle, or underscore in the enlargements as long as it is clear that it was not on the original.
Summary: Exhibits must be published via poster blow-up, courtroom technology transmission, or other allowed method, and highlighting/circling/underscoring enlargements is permitted if clearly not on the original.
Machine summary. Not checked yet.Mandatory?
The parties shall provide the materials on a thumb drive and shall also submit one hard-copy set. The hard-copy set shall be organized and formatted in a manner that allows the Court to review the transcripts and identify the corresponding objections and responses without the need to reference a separate spreadsheet.
Summary: Deposition/discovery designation materials must be submitted on a thumb drive and as one hard-copy set organized to match objections/responses without a separate spreadsheet.
Machine summary. Not checked yet.Mandatory?
During trial, counsel may wish to use laser-disk/computer graphics, poster blow-ups, or models. Such equipment must be provided by the parties. Equipment should be shared by all counsel to the maximum extent possible. For electronic equipment, parties should be prepared to maintain the equipment or have a technician handy at all times. The parties shall tape extension cords to the carpet for safety.
Summary: Parties must provide their own evidence presentation equipment, share equipment where possible, maintain electronic equipment or have technician support, and tape extension cords to the carpet for safety.
Machine summary. Not checked yet.Mandatory?
all factual findings must be supported by citations to all pertinent portions of the record. If the citation is to witness testimony and a rough or final transcript is not yet available, the citation can simply be to the date of the testimony. The parties should hyperlink the citations in the proposed findings of fact to the exhibits and trial transcripts. Proposed findings shall be brief, written in plain English, and free of pejorative language.
Summary: Proposed findings of fact and conclusions of law must include record citations, be brief, in plain English, free of pejorative language, and have hyperlinked citations where possible.
Machine summary. Not checked yet.Mandatory?
The proposed notices, claims forms, and other documents associated with preliminary approval should be sent in Microsoft Word format to vcpo@cand.uscourts.gov.
Summary: Preliminary approval documents must be sent in Word format to specified email.
DOCX
Machine summary. Not checked yet.Mandatory?
To avoid any party claiming “ownership” of an exhibit, all exhibits shall be marked and referred to as “Trial Exhibit No. ,” not as “Government’s Exhibit” or “Defendant’s Exhibit”.
Summary: Exhibits must be marked as 'Trial Exhibit No. [number]', not party-specific names.
Machine summary. Not checked yet.Mandatory?
A single exhibit should be marked only once. If the government has marked an exhibit, the defendant should not re-mark the same document with another number. Different versions of the same document (e.g., versions of a document with and without additional handwriting), however, must be treated as different exhibits and marked with different numbers.
Summary: Exhibits must be marked only once; different versions of the same document are separate exhibits.
Machine summary. Not checked yet.Mandatory?
Exhibits shall be sequentially numbered (not lettered). Blocks of numbers should be assigned to fit the needs of the case (e.g., the government has 1 to 100, Defendant A has 101 to 200, Defendant B has 201 to 300, etc.).
Summary: Exhibits must be sequentially numbered (not lettered), with blocks assigned per party.
Document Filing Requirements156 rules
Machine summary. Not checked yet.Mandatory?
In their 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, regardless of whether they have received a ruling on any motion to dismiss. The only exception is proposed class actions, in which case the parties can propose a schedule through the first phase of the case, as discussed in the class action section of this standing order.
Summary: Initial case management statements must include a full litigation schedule with last day to amend pleadings, except class actions may propose a schedule through the first phase.
Document Type
Case Management Statement
Machine summary. Not checked yet.Mandatory?
If they have, they must identify any deviations from the model order by submitting as an exhibit a redline comparison of their proposed order and the model order.
Summary: Parties must submit a redline comparison of their proposed order and the model order as an exhibit if the proposed order is based on a Northern District model order.
Document Type
Proposed Order
Machine summary. Not checked yet.Mandatory?
Both sides must submit proposed orders as well.
Summary: Both parties must submit proposed orders with their joint discovery dispute letter.
Document Type
Joint Discovery Letter
Machine summary. Not checked yet.Mandatory?
No exhibits may be submitted with the letter other than any discovery request or response that is the subject of the letter.
Summary: Only the discovery request or response that is the subject of the dispute may be submitted as an exhibit with a joint discovery dispute letter.
Document Type
Joint Discovery Letter
Machine summary. Not checked yet.Mandatory?
When filing a proposed 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: Parties must indicate at the beginning of a stipulation or motion for a protective order or ESI order whether the proposed order is based on a Northern District model order.
Document Type
Stipulation Or Motion
Machine summary. Not checked yet.Mandatory?
In any motion for class certification, plaintiffs’ counsel must include a section called “Manageability of the Class Action Trial” in which they explain precisely how the Court should handle any potentially individualized issues to ensure that they don’t render the trial unmanageable. This section should generally include a discussion of jury instructions, especially jurisdictions.
Summary: Class certification motion briefs must include a section titled “Manageability of the Class Action Trial” discussing individualized issues and jury instructions to address manageability concerns.
Document Type
Class Certification Brief
Machine summary. Not checked yet.Mandatory?
The Court’s scrutiny of the proposed settlement will be as rigorous at the preliminary approval stage as at the final approval stage. Any motion for preliminary approval should explain why the settlement survives this level of scrutiny, and any proposed order should recite this standard.
Summary: Motions for preliminary approval of class settlements must explain why the settlement survives rigorous scrutiny equivalent to final approval, and the proposed order must recite this standard.
Document Type
Preliminary Settlement Approval Motion
Machine summary. Not checked yet.Mandatory?
The proposed settlement administrator must submit a declaration in support of the motion for preliminary approval that describes (a) any money or thing of value the administrator will receive in connection with the settlement beyond the fee described in the preliminary approval papers, including interest or float on settlement deposits,
Summary: Settlement administrators must submit a declaration with the preliminary approval motion detailing any compensation beyond the fee stated in the preliminary approval papers.
Document Type
Settlement Administrator Declaration
Machine summary. Not checked yet.Mandatory?
Proposed class counsel’s declaration shall describe what due diligence counsel performed regarding the proposed administrator’s approach to each of the above issues, any potential conflict of interest or potential appearance of conflict of interest for counsel in the selection of the administrator (including any financial relationship), and the basis for counsel’s conclusion that the proposed administration arrangements serve the best interests of the settlement class.
Summary: Proposed class counsel's declaration must describe due diligence on the proposed administrator, conflict of interest disclosures, and the basis for concluding the administration arrangements serve the settlement class's best interests.
Document Type
Declaration
Machine summary. Not checked yet.Mandatory?
If a proposed notice to class members (or prospective class members) requires a written objection as a prerequisite to appearing in court to object to the settlement, the notice must specify that this requirement may be excused upon a showing of good cause.
Summary: Proposed notices requiring written objection as a prerequisite to court appearance must state that good cause can excuse this requirement.
Document Type
Proposed Notice
Machine summary. Not checked yet.Mandatory?
In a proposed settlement involving the distribution of money to a class, the parties should consider whether unclaimed funds should be redistributed to class members who claimed their share. If a provision of this type is absent, the parties should be prepared to explain why.
Summary: Proposed class action settlements involving monetary distribution should include a provision for redistributing unclaimed funds to class members who claimed their share, or include an explanation for the absence of such provision.
Document Type
Settlement Agreement
Machine summary. Not checked yet.Mandatory?
The parties should consider whether theirs is the type of settlement that requires class members to file claims, as opposed to simply receiving funds. The motion for preliminary approval should address this issue.
Summary: Motions for preliminary approval of class settlements must address whether the settlement requires class members to file claims or simply receive funds.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
The proposed order granting final approval should list all dates relating to the administration of the settlement, including the dates for when the checks distributing the settlement fund payments will be mailed to class members.
Summary: Proposed orders granting final approval of class settlements must list all settlement administration dates, including check mailing dates.
Document Type
Proposed Order
Machine summary. Not checked yet.Mandatory?
The proposed order granting final approval should also include language describing the Post-Distribution Accounting that class counsel will file, including, as relevant, when payments were made to class members, the number of members who were sent payments, the total amount of money paid out to members, the average and median recovery per class member, the largest and smallest amount paid to class members, the number and value of cashed and uncashed checks, the number of members who could not be contacted, the number of objections and opt-outs, the amount to be distributed to each cy pres recipient, any significant or recurring concerns communicated by members to the settlement administrator and counsel since final approval, any other issues in settlement administration since final approval, and how any concerns or issues were resolved.
Summary: Proposed orders granting final approval of class settlements must include language describing the required content of the Post-Distribution Accounting.
Document Type
Proposed Order
Machine summary. Not checked yet.Mandatory?
The proposed order granting final approval should specify what percentage class counsel believes it is appropriate to withhold.
Summary: Proposed orders granting final approval of class settlements must specify the percentage of attorneys' fees to be withheld pending Post-Distribution Accounting.
Document Type
Proposed Order
Machine summary. Not checked yet.Mandatory?
With the Post-Distribution Accounting, class counsel should submit a proposed order releasing the remainder of the fees.
Summary: Class counsel must submit a proposed order releasing remaining fees with Post-Distribution Accounting.
Document Type
Post Distribution Accounting
Machine summary. Not checked yet.Mandatory?
Post-Distribution Accounting should also describe the number of class members availing themselves of such relief and the aggregate value redeemed by the class members and/or by an assignees or transferees of the class members’ interests. Where class members are entitled to injunctive and/or other non-monetary relief, the Post-Distribution Accounting should discuss the progress made on fulfilling the terms of that relief.
Summary: Post-Distribution Accounting must describe class member redemption details and progress on non-monetary relief.
Document Type
Post Distribution Accounting
Machine summary. Not checked yet.Mandatory?
If a defendant chooses instead to file a motion to dismiss a Monell claim, the defendant should be prepared to explain why the claim should not be stayed instead.
Summary: Defendants filing a motion to dismiss a Monell claim must be prepared to explain why the claim should not be stayed.
Document Type
Motion To Dismiss
Machine summary. Not checked yet.Mandatory?
not simply file a notice of voluntary dismissal. The parties must file a motion for settlement approval explaining why the proposed settlement is a fair and reasonable resolution of a bona fide dispute. See Alder v. County of Yolo, No. 16-1682-VC, Dkt. No. 25 (E.D. Cal. Nov. 20, 2017).
Summary: In wage and hour cases, parties must file a motion for settlement approval with an explanation of the settlement's fairness, reasonableness, and bona fide dispute resolution instead of a notice of voluntary dismissal.
Document Type
Motion For Settlement Approval
Machine summary. Not checked yet.Mandatory?
The final brief for any motion should be filed at least 14 days prior to the hearing on the motion.
Summary: Final briefs must be filed at least 14 days before the hearing.
Document Type
Brief
Machine summary. Not checked yet.Mandatory?
In any motion for class certification, plaintiffs’ counsel must include a section called “Manageability of the Class Action Trial” in which they explain precisely how the Court should handle any potentially individualized issues to ensure that they don’t render the trial unmanageable.
Summary: Class certification motions must include “Manageability of the Class Action Trial” section.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
In cases that involve individualized issues, plaintiffs’ counsel must file a proposed verdict form in connection with the motion for class certification.
Summary: Proposed verdict form required for class certification motions with individualized issues.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
Proposed orders are not necessary for most substantive motions, such as motions for summary judgment, motions to dismiss, or preliminary injunction motions. The parties should submit proposed orders only in connection with administrative motions, ex parte applications, discovery disputes, and rulings that call upon the court to make factual findings (such as a motion to approve a class settlement or a motion for attorneys’ fees). All proposed orders should be sent in Microsoft Word format to vcpo@cand.uscourts.gov.
Summary: Proposed orders not needed for most substantive motions; required for administrative motions, ex parte applications, discovery disputes, and factual findings.
Document Type
Proposed Order
Filing & Service rules
Electronic Filing Rules
Declarations must be filed separately from motions; exhibits to declarations must be filed separately from the declaration and other exhibits, except attachments to exhibits need not be filed separately.
declaration must be filed separately from the motion, and each exhibit to a declaration must be filed separately from the declaration and from the other exhibits. However, when an exhibit to a declaration contains an attachment, that attachment need not be filed separately.
Machine summary. Not checked yet. · Civil cases
Page 7 | FILING AND COURTESY COPIES
Proposed orders are only required for specified motion types, must be in Microsoft Word format, and sent to the specified email address; they are not required for most substantive motions.
Proposed orders are not necessary for most substantive motions, such as motions for summary judgment, motions to dismiss, or preliminary injunction motions. The parties should submit proposed orders only in connection with administrative motions, stipulations requiring modifications of the case schedule, ex parte applications, discovery disputes, and rulings that call upon the court to make factual findings (such as a motion to approve a class settlement or a motion for attorneys’ fees). All proposed orders should be sent in Microsoft Word format to vcpo@cand.uscourts.gov.an
Machine summary. Not checked yet. · Civil cases
Page 8 | PROPOSED ORDERS
Parties must submit a Word version of the proposed supplemental juror questionnaire to vcpo@cand.uscourts.gov in addition to filing on the docket.
The parties shall file these questions on the docket and submit a Word version to vcpo@cand.uscourts.gov.
Machine summary. Not checked yet. · Civil cases
Page 3 | Proposed Supplemental Juror Questionnaire (Due 21 Days Before PTC)
Specified pretrial documents must be submitted via email to the provided address with no paper copies required.
The proposed supplemental jury questions, Joint Pretrial Conference Statement, jury instructions, involved individuals list, and verdict form(s) shall be submitted in Microsoft Word format via e-mail to vcpo@cand.uscourts.gov when they are filed. There is no need to submit paper copies.
Machine summary. Not checked yet. · Civil cases
Page 7 | PRETRIAL FILINGS
Proposed findings of fact and conclusions of law must be emailed to vcpo@cand.uscourts.gov in Word format in addition to regular filing.
In addition to being filed, the proposed findings must be emailed to the Court (vcpo@cand.uscourts.gov) in Word format.
Machine summary. Not checked yet. · Civil cases
Page 12 | FINDINGS OF FACT AND CONCLUSIONS OF LAW (FOR BENCH TRIALS)
Proposed jury questionnaire questions must be filed on the docket and a Word version emailed 21 days before the pretrial conference.
At least 21 days before the pretrial conference, the parties shall file the proposed questions on the docket and submit a Word version to vcpo@cand.uscourts.gov.
Machine summary. Not checked yet. · Criminal cases
Page 4 | Jury Questionnaire
Exhibit lists must be sent in Word format to vcpo@cand.uscourts.gov via email.
No later than 7 days before the pretrial conference, each party must file, and send in Word format to vcpo@cand.uscourts.gov, a list of exhibits.
Machine summary. Not checked yet. · Criminal cases
Page 7 | PRETRIAL FILINGS AND DEADLINES
Involved individual lists must be sent in Word format to vcpo@cand.uscourts.gov via email.
No later than 7 days before the pretrial conference, the parties must jointly file, and send in Word format to vcpo@cand.uscourts.gov, a list of people involved in the case.
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Page 7 | PRETRIAL FILINGS AND DEADLINES
Witness lists must be sent in Word format to vcpo@cand.uscourts.gov via email.
No later than 7 days before the pretrial conference, the parties must file, and send in Word format to vcpo@cand.uscourts.gov, lists of potential witnesses to be called at trial, other than solely for impeachment or rebuttal.
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Page 7 | PRETRIAL FILINGS AND DEADLINES
Proposed verdict forms must be sent in Word format to vcpo@cand.uscourts.gov via email.
No later than 7 days before the pretrial conference, the parties must jointly file, and send in Word format to vcpo@cand.uscourts.gov, either an agreed-upon proposed verdict form or competing proposed verdict forms.
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Page 7 | PRETRIAL FILINGS AND DEADLINES
ECF descriptions for motions, exhibits, and declarations should include the document name and a brief description.
When filing motions, exhibits, and declarations, the ECF “Description” of each document should include the name of the document and a brief description of the document. For instance, a news release filed as the first exhibit to a declaration would be, “Decl Doe Ex 1 - News Release.”
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Page 7 | FILING AND COURTESY COPIES
Motions with supporting declarations or exhibits should generally be filed as one ECF docket entry, with the motion as the Main Document and each declaration/exhibit as a separate Attachment.
A motion, along with any supporting declarations or exhibits, should generally be filed as one docket entry, with the motion submitted as the “Main Document” in ECF, and each declaration and exhibit filed separately as “Attachments.”
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Page 7 | FILING AND COURTESY COPIES
Filing Timing and Cure Windows
Final brief for cross-motions for summary judgment must be filed no later than 14 days before the scheduled hearing date.
The final brief should be filed no later than 14 days before the scheduled hearing date.
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Page 2 | TABLE OF KEY DEADLINES
First brief for cross-motions for summary judgment must be filed no later than 7 weeks before the scheduled hearing date.
typically the parties must file the first brief no later than 7 weeks before the scheduled hearing date
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Page 2 | TABLE OF KEY DEADLINES
Joint discovery letters must be filed no later than 7 days after the applicable discovery deadline.
Joint discovery letters: As soon as practicable, but no later than 7 days after applicable discovery deadline
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Page 2 | TABLE OF KEY DEADLINES
Joint discovery dispute letters must be filed no more than 7 days after the applicable discovery cutoff.
The letter must be filed as soon as possible, but under no circumstances may it be filed more than 7 days after the applicable discovery cutoff.
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Page 6 | DISCOVERY
Filings with more than 10 ECF attachments must be uploaded to the Clerk’s designated online location within 3 days of filing.
When a document filed on ECF is accompanied by more than 10 attachments, the filing party must upload those documents within 3 days onto an online location designed by the Clerk’s Office.
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Page 7 | FILING AND COURTESY COPIES
Final briefs for any motion must be filed at least 14 days before the hearing.
The final brief for any motion should be filed at least 14 days prior to the hearing on the motion.
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Page 10 | BRIEFS
Motions to increase page limits must be filed no later than 72 hours before the brief's due date.
Motions to increase page limits will almost never be granted, but any such motion must be filed no later than 72 hours before the brief is due.
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Page 10 | BRIEFS
Daubert reply briefs filed by the summary judgment opponent must be submitted within 7 calendar days after the other party’s reply in support of the summary judgment motion.
The only exception is when the party moving to exclude is the party opposing summary judgment, in which case that party may file a reply brief (not to exceed 5 pages and filed no later than 7 days after the other party’s reply in support of summary judgment) in support of the Daubert motion.
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Page 11 | SUMMARY JUDGMENT
Reply briefs in support of a Daubert motion filed by the party opposing class certification must be submitted no later than 7 days after the other party’s reply in support of class certification.
The only exception is when the party moving to exclude is the party opposing class certification, in which case that party may file a reply brief (not to exceed 5 pages and filed no later than 7 days after the other party’s reply in support of class certification) in support of the Daubert motion.
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Page 13 | CLASS ACTIONS
Motions for attorneys' fees in class settlement final approval must be filed at least 14 calendar days before the objection deadline.
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 14 days before the deadline for objecting to the settlement.
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Page 17 | Final Approval
Class counsel must file a Post-Distribution Accounting within 21 calendar days after full distribution of settlement funds to class members, prior to 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 18 | Final Approval
In FLSA cases, the presumptive deadline to file a motion for conditional certification is 28 days after the initial case management conference, unless a tolling agreement is reached.
In FLSA cases, the presumptive deadline for filing a motion for conditional certification of a collective is 28 days from the date of the initial case management conference, unless the parties reach a tolling agreement.
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Page 21 | WAGE AND HOUR CASES
Filing a stay motion for a Monell claim tolls the deadline to file a motion to dismiss that claim, as does any granted stay.
If the defendant chooses to seek a stay of a Monell claim, the deadline to file a motion to dismiss is tolled by the filing of the stay motion (and by the stay itself, if any).
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Page 22 | SECTION 1983 CASES
Joint pretrial conference statement, motions in limine, and oppositions to motions in limine must be filed 14 days before the pretrial conference.
File joint pretrial conference statement, motions in limine and oppositions to motions in limine 14 Days Before Pretrial Conference
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Page 2 | SUMMARY TABLE OF DEADLINES
Involved individuals list, proposed verdict forms, statement of the case, and exhibit list must be filed 7 days before the pretrial conference.
File involved individuals list, proposed verdict forms, statement of the case, exhibit list 7 Days Before Pretrial Conference
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Page 2 | SUMMARY TABLE OF DEADLINES
All designations of deposition testimony must be jointly filed 7 days before trial.
Joint filing of all designations of deposition testimony 7 Days Before Trial
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Page 2 | SUMMARY TABLE OF DEADLINES
Proposed supplemental juror questionnaire and proposed jury instructions must be filed 21 days before the pretrial conference.
File proposed supplemental juror questionnaire and proposed jury instructions 21 Days Before Pretrial Conference
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Page 2 | SUMMARY TABLE OF DEADLINES
Proposed order for bringing exhibit presentation equipment and technology into the building must be filed 14 days before trial.
Filing of proposed order for bringing exhibit presentation equipment and technology into the building 14 Days Before Trial
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Page 2 | SUMMARY TABLE OF DEADLINES
Parties must file the proposed supplemental juror questionnaire 21 days before the pretrial conference.
Proposed Supplemental Juror Questionnaire (Due 21 Days Before PTC)
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Page 3 | Proposed Supplemental Juror Questionnaire (Due 21 Days Before PTC)
Parties must file proposed jury instructions 21 days before the pretrial conference.
Proposed Jury Instructions (Due 21 Days Before PTC)
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Page 3 | Proposed Jury Instructions (Due 21 Days Before PTC)
Parties must file the joint pretrial conference statement 14 days before the pretrial conference.
Joint Pretrial Conference Statement (Due 14 Days Before PTC)
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Page 4 | Joint Pretrial Conference Statement (Due 14 Days Before PTC)
Requests for relief from the five-motion limit for motions in limine must be submitted at least 35 calendar days before the final pretrial conference.
Rather than trying to squeeze multiple topics into one motion in limine, the parties must seek relief from the five-motion limit at least 35 calendar days before the final pretrial conference.
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Page 5 | Motions in Limine with Oppositions (Due 14 Days Before PTC)
Paired sets of motions in limine and oppositions must be filed at least 14 calendar days before the final pretrial conference.
Once the moving party has received the opposition, that party should collate each motion with its opposition, back-to-back, and then file the paired sets at least 14 calendar days before the final pretrial conference.
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Page 5 | Motions in Limine with Oppositions (Due 14 Days Before PTC)
All trial exhibits must be uploaded to the Clerk’s designated online location no later than 5 days before trial.
No later than 5 days before trial, the parties shall upload official copies of all exhibits to an online location designated by the Clerk’s Office, with each exhibit as a separate file, and with each file named so that the exhibits appear sequentially when sorted by file name.
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Page 7 | EXHIBITS
Audio/video exhibit transcripts must be provided by the day the exhibit is offered to avoid exclusion.
The parties must provide agreed-upon written transcripts of the content of any audio or video exhibit to be used at trial. Failure to provide an agreed-upon transcript by the day an exhibit is offered will preclude the exhibit’s admission.
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Page 8 | EXHIBITS
Parties must jointly file all deposition/discovery designations, counter-designations, and objections no later than 7 days before trial unless otherwise ordered.
Unless otherwise ordered, no later than 7 days before trial begins, the parties shall jointly file all designations of deposition testimony or other discovery it wishes to offer, as well as any counter-designations or objections to the deposition testimony or discovery offered by any other party.
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Page 9 | DEPOSITION AND DISCOVERY DESIGNATIONS
Pretrial filings in non-jury civil cases must be submitted 7 days before the pretrial conference.
In non-jury cases, all pretrial filings are due 7 days before the pretrial conference.
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Page 12 | FINDINGS OF FACT AND CONCLUSIONS OF LAW (FOR BENCH TRIALS)
Parties must upload all admitted trial exhibits to the Clerk’s designated online location within 7 days of the admissibility ruling, including files not supported by CM/ECF, and notify the courtroom deputy after uploading.
Within 7 days of the Court ruling on the admissibility of exhibits used at trial, the parties will be required to upload to an online location designated by the Clerk’s office all exhibits admitted into evidence to chambers, and to notify Bhavna Sharma, Judge Chhabria’s Courtroom Deputy, once uploaded. Those files should include any files that are not supported by CM/ECF.
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Page 12 | FINDINGS OF FACT AND CONCLUSIONS OF LAW (FOR BENCH TRIALS)
Jury instructions, verdict form, case description, exhibit lists, witness lists, and individuals involved list must be submitted 7 days before the pretrial conference.
Jury Instructions, Verdict Form, Proposed 7 Days Before Pretrial Conference Description of the Case, Exhibit Lists, Witness Lists, Individuals Involved List
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Page 2 | SUMMARY TABLE OF DEADLINES
Supplemental jury questionnaire questions and objections to the jury questionnaire must be submitted 21 days before the pretrial conference.
Supplemental Jury Questionnaire Questions, 21 Days Before Pretrial Conference Objections to Jury Questionnaire
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Page 2 | SUMMARY TABLE OF DEADLINES
Daily transcript or real-time reporting must be arranged 14 days before trial.
Arrangement of Daily Transcript or Real- 14 Days Before Trial Time Reporting
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Page 2 | SUMMARY TABLE OF DEADLINES
Chambers must be contacted regarding courtroom layout and technology 10 days before trial.
Contact Bhavna Sharma Regarding 10 Days Before Trial Courtroom Layout and Technology
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Page 2 | SUMMARY TABLE OF DEADLINES
Original and copy trial exhibit sets, and lists of names, places, uncommon terms, and acronyms must be delivered 5 days before trial.
Deliver Original and Copy Trial Exhibit Sets, 5 Days Before Trial List of Names, Places, Uncommon Terms and Acronyms
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Page 2 | SUMMARY TABLE OF DEADLINES
Service and Proof of Service Rules
Parties seeking emergency relief must notify opposing party and counsel at the earliest possible time of intent to seek such relief, or relief will be denied.
effort to notify the opposing party and the opposing party’s counsel, at the earliest possible time, of its intent to seek emergency relief, the relief will not be granted.
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Page 3 | EMERGENCY APPLICATIONS
Motions in limine must be served 28 days before the pretrial conference; parties must also meet and confer regarding the pretrial conference.
Meet and confer regarding pretrial conference, serve motions in limine 28 Days Before Pretrial Conference
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Page 2 | SUMMARY TABLE OF DEADLINES
Oppositions to motions in limine must be served 21 days before the pretrial conference.
Serve oppositions to motions in limine 21 Days Before Pretrial Conference
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Page 2 | SUMMARY TABLE OF DEADLINES
Opposition briefs for motions in limine must be served at least 21 calendar days before the final pretrial conference and not filed until paired with the motion.
At least 21 calendar days before the conference, the responding party shall serve, but not file, the opposition.
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Page 5 | Motions in Limine with Oppositions (Due 14 Days Before PTC)
Opening briefs for motions in limine must be served at least 28 calendar days before the final pretrial conference and not filed until paired with the opposition.
At least 28 calendar days before the final pretrial conference, the moving party shall serve, but not file, the opening brief.
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Page 5 | Motions in Limine with Oppositions (Due 14 Days Before PTC)
The Involved Individuals List must be sent to vcpo@cand.uscourts.gov.
The parties shall jointly file, and send in Word format to vcpo@cand.uscourts.gov, a list of people involved in the case.
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Page 6 | Involved Individuals List (Due 7 Days Before PTC)
Counsel must exchange witness lists and direct examination exhibits at the end of each trial day; opposing counsel must respond with objections and cross-examination exhibits within 24 hours.
At the close of each trial day, counsel shall exchange a list of witnesses for the next two full court days and the exhibits that will be used during direct examination (other than for impeachment of an adverse witness). Within 24 hours of receiving such notice, opposing counsel shall provide any objections to such exhibits and shall provide a list of all exhibits to be used with the same witness on cross-examination (other than for impeachment).
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Page 11 | WITNESSES
Courtesy Copy Requirements
Paper courtesy copies are prohibited unless requested by the Court; digital courtesy copies on portable media may be ordered for motion briefs and supporting documents.
Paper courtesy copies shall not be submitted unless the Court requests them. The Court may at times order the parties to provide digital courtesy copies of motion briefs, including supporting documents, on portable media (for example, a CD or flash drive).
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Page 8 | FILING AND COURTESY COPIES
Parties may be required to deliver a flash drive containing all attachments to chambers when requested by the courtroom deputy.
On occasion, the parties may be asked by the courtroom deputy to deliver a flash drive with all the attachments to Judge Chhabria’s chambers.
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Page 8 | FILING AND COURTESY COPIES
Flash drive with attachments required for filings with more than 10 attachments.
When a document filed on ECF is accompanied by more than 10 attachments, the filing party must deliver a flash drive with all the attachments to Judge Chhabria’s chambers within 7 business days of filing. The flash drive should be labeled with the name and number of the case. The flash drive should contain the ECF version of each attachment, with its ECF header. The name of each PDF file on the flash drive should include the type of document, a brief description of the document, and the docket number. For example, a news release filed as the first exhibit to a declaration, at docket number 60-2, would be, "[60-2] Decl Doe Ex 1 - News Release."
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Original trial exhibit set and flash drive of exhibits must be delivered 5 days before trial.
Deliver original trial exhibit set and flash drive of exhibits 5 Days Before Trial
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Page 2 | SUMMARY TABLE OF DEADLINES
Flash drive with attachments required for ECF filings with more than 10 attachments.
When a document filed on ECF is accompanied by more than 10 attachments, the filing party must deliver a flash drive with all the attachments to Judge Chhabria’s chambers within 7 business days of filing. The flash drive should be labeled with the name and number of the case. The flash drive should contain the ECF version of each attachment, with its ECF header. The name of each PDF file on the flash drive should include the type of document, a brief description of the document, and the docket number.
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Page 7 | FILING AND COURTESY COPIES
Paper courtesy copies are not accepted by the Court.
Paper courtesy copies are not accepted.
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Page 3 | MOTIONS
Chambers copies required for all pretrial filings
Chambers Copies of All Pretrial Filings
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Page 2 | Chambers Copies of All Pretrial Filings
Moving party must deliver courtesy copies of all motions in limine papers.
The moving party is responsible for delivering courtesy copies of all motion papers (both those in support and those in opposition).
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Page 5 | Motions in Limine
Two three-hole punched courtesy copies of all pretrial filings required by noon next day.
Two three-hole punched courtesy copies of all pretrial filings shall be delivered to the Clerk’s office by noon the day after filing.
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Paper courtesy copies are not accepted.
Paper courtesy copies are not accepted.
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Page 3 | Motions
Paper courtesy copies not required unless requested; digital copies may be ordered.
Paper courtesy copies shall not be submitted unless the Court requests them. The Court may at times order the parties to provide digital courtesy copies of motion briefs, including supporting documents, on portable media (for example, a CD or flash drive).
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Paper courtesy copies generally not required; digital copies may be requested.
Paper courtesy copies shall not be submitted unless the Court requests them. The Court may at times order the parties to provide digital courtesy copies of motion briefs, including supporting documents, on portable media (for example, a CD or flash drive).
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Page 7 | FILING AND COURTESY COPIES
Courtesy copies not required for sealed documents filed electronically in unredacted form.
Courtesy copies under Civil Local Rule 79-5(d)(2) are not required, provided that the document at issue is appropriately filed electronically under seal in an unredacted form.
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Sealing & Redaction Procedures
Motions to seal require a specific per-document showing for narrow redactions; overbroad or vague requests risk denial and public docketing of all sought documents.
The filing 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, rather than making a blanket statement about the grounds for sealing. Generic and vague references to “competitive harm” are almost always insufficient justification for sealing. If a party files a request to seal that is significantly overbroad and/or does not provide adequate reasons for concealing information from the public, the party bears the risk that the Court will simply deny the request in its entirety and place all documents sought to be sealed on the public docket.
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Page 9 | MOTIONS TO SEAL
Filing parties must state the applicable sealing standard and explain its application when submitting a motion to seal.
When submitting a motion to seal, the filing party must state whether the compelling reasons or good cause standard applies and explain why.
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Page 9 | MOTIONS TO SEAL
Sealed documents must be highlighted to show proposed redactions; entirely sealed documents must be labeled as such.
Each document filed under seal must be highlighted to show the proposed redactions. In the rare situation where a party believes it is appropriate to seal an entire document, the document filed under seal should be labeled to indicate that sealing is sought in full.
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Page 9 | MOTIONS TO SEAL
Documents filed under seal must be submitted electronically in unredacted form.
the document at issue is appropriately filed electronically under seal in an unredacted form.
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Page 10 | MOTIONS TO SEAL
Strict compliance required with Civil Local Rule 79-5, except for 79-5(d)(2).
The Court requires strict compliance with Civil Local Rule 79-5 (with the exception of 79-5(d)(2), as explained below).
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Strict compliance required with Civil Local Rule 79-5 (except 79-5(d)(2)).
The Court requires strict compliance with Civil Local Rule 79-5 (with the exception of 79-5(d)(2), as explained below).
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Page 8 | MOTIONS TO SEAL
Parties must upload unredacted copies of sealed documents to an online location designated by the Clerk's office.
For any documents submitted under seal, the parties shall upload unredacted copies to an online location designated by the Clerk's office.
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Page 3 | SEALED FILINGS
Filing party must make a specific showing explaining why sealing is justified and redactions are narrowly tailored.
The filing 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 | SEALED FILINGS
Proposed redactions must be highlighted on unredacted document.
The parties should highlight any proposed redactions on the unredacted version of the document.
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Page 3 | Sealed Filings
Sealed documents require paper and electronic courtesy copies.
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. The electronic copy may be provided via a portable flash drive, email, or compact disk.
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Page 3 | Sealed Filings
Filing party must justify sealing with specific showing and narrow redactions.
Federal courts are paid for by the public, and the public has the right to inspect court records, subject to only narrow exceptions. The filing 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 | Sealed Filings
Motions to seal are almost always denied and may result in sanctions if frivolous.
The Court almost always denies motions to seal because they are almost always without merit. Parties that submit frivolous motions to seal or frivolously overbroad motions will be sanctioned. See Nevro Corp. v. Boston Scientific Corp., 2018 WL 2111164 (N.D. Cal. May 8, 2018). Federal courts are paid for by the public, and the public has the right to inspect court records, subject only to narrow exceptions.
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Motions to seal are almost always denied and frivolous submissions will be sanctioned.
The Court almost always denies motions to seal because they are almost always without merit. Parties that submit frivolous motions to seal or frivolously overbroad motions will be sanctioned.
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Page 8 | MOTIONS TO SEAL
Parties should highlight proposed redactions on the unredacted version of the document.
The parties should highlight any proposed redactions on the unredacted version of the document.
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Page 3 | SEALED FILINGS
Filing Bundling Requirements
Cross-motions for summary judgment must consist of 4 sequential briefs.
Because the Court requires the parties to file 4 sequential briefs
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Page 2 | TABLE OF KEY DEADLINES
Daubert motions seeking to preclude expert reliance at the class certification stage, and all related oppositions and replies, must be included in the same brief as the class certification motion or opposition, and in the same brief as the class certification merits argument, respectively.
Any Daubert motion seeking to preclude a party’s reliance on an expert opinion at the class certification stage must be filed in the same brief as the motion for class certification or the opposition to that motion. Oppositions and replies relating to the Daubert motion must also be filed in the same briefs as argument on the merits of the class certification motion.
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Page 13 | CLASS ACTIONS
A proposed verdict form must be filed with the motion for class certification.
In addition, to assist the Court in assessing any manageability concerns, plaintiffs’ counsel must file a proposed verdict form in connection with the motion for class certification.
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Page 14 | CLASS ACTIONS
Simultaneous briefing is prohibited for all motions.
Simultaneous briefing is not permitted for any type of motion.
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Page 10 | BRIEFS
Cross-motions for summary judgment require four sequential briefs, not simultaneous pairs.
In the event of cross-motions for summary judgment, the parties must file a total of four briefs sequentially, rather than three pairs of simultaneous briefs.
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Page 10 | SUMMARY JUDGMENT
Daubert motions must be filed in the same brief as class certification motion.
Any Daubert motion seeking to preclude a party’s reliance on an expert opinion at the class certification stage must be filed in the same brief as the motion for class certification or the opposition to that motion.
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Page 13 | Class Certification Motions
Daubert oppositions/replies must be filed in same briefs as class certification merits.
Oppositions and replies relating to the Daubert motion must also be filed in the same briefs as argument on the merits of the class certification motion.
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Page 13 | Class Certification Motions
Motions in limine and oppositions must be collated back-to-back and filed as paired sets at least 14 calendar days before the final pretrial conference.
Once the moving party has received the opposition, that party should collate each motion with its opposition, back-to-back, and then file the paired sets at least 14 calendar days before the final pretrial conference.
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Page 5 | Motions in Limine with Oppositions (Due 14 Days Before PTC)
Simultaneous briefing prohibited for all motions.
Simultaneous briefing is not permitted for any type of motion.
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Cross-motions for summary judgment require four sequential briefs, not simultaneous.
In the event of cross-motions for summary judgment, the parties must file a total of four briefs sequentially, rather than three pairs of simultaneous briefs.
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ECF motions require separate PDFs for motion, declarations, and exhibits (except attachments to exhibits).
When filing motions on ECF, each motion, supporting declaration, and attachment to a declaration (such as an exhibit) should be filed as a separate PDF. That is, a declaration must be filed separately from the motion, and each exhibit to a declaration must be filed separately from the declaration and from the other exhibits. However, when an exhibit to a declaration contains an attachment, that attachment need not be filed separately.
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Pretrial conference is 1-2 weeks before trial; dispositive motions due 2-3 months before pretrial.
The pretrial conference will be 1 or 2 weeks before the trial. The last day for a hearing on dispositive motions will be roughly 2 to 3 months before the pretrial conference.
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Trial dates are typically set 12-16 months after complaint filing.
The trial date will almost always be 12–16 months after the date the original complaint was filed.
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Pre-Motion Conference Requirements
Moving counsel must confer with opposing counsel on a mutually convenient hearing date before noticing any motion.
Counsel for the moving party should confer with opposing counsel about a mutually convenient hearing date before noticing any motion.
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Page 3 | SCHEDULING
Simultaneous briefing is prohibited for all motion types.
Simultaneous briefing is not permitted for any type of motion.
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Page 10 | BRIEFS
For cross-motions for summary judgment, parties must file four briefs sequentially in specified order instead of simultaneous pairs.
In the event of cross-motions for summary judgment, the parties must file a total of four briefs sequentially, rather than three pairs of simultaneous briefs. Unless the parties agree to reverse the order, the opening brief is filed by the party asserting infringement, the opening/opposition brief is filed by the party defending against the infringement claim, the opposition/reply is filed by the party asserting infringement, and the reply is filed by the party is limited to 50 pages, the third brief is limited to 30 pages, and the fourth brief is limited to 20 pages.
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Page 19 | PATENT CASES
Claim construction will only be conducted with a dispositive motion absent compelling reason; Patent Local Rules 4-1 to 4-4 apply, 4-5 and 4-6 are superseded.
Absent a compelling reason, the Court will conduct claim construction only in conjunction with a dispositive motion. Parties should still follow Rules 4-1 through 4-4 of the Patent Local Rules. Rules 4-5 and 4-6, on the other hand, will give way to the details provided in the paragraphs below.
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Page 19 | PATENT CASES
Daubert motions must be filed in the same brief as summary judgment motion or opposition.
Any Daubert motion seeking to preclude a party’s reliance on an expert opinion at the summary judgment stage must be filed in the same brief as the motion for summary judgment or the opposition to that motion.
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Hearings are required for default judgment motions except in highly unusual circumstances.
Judge Chhabria’s rule is to have hearings on motions for default judgment except in highly unusual circumstances.
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Daubert motions must be filed in the same brief as class certification motion.
Any Daubert motion seeking to preclude a party’s reliance on an expert opinion at the class certification stage must be filed in the same brief as the motion for class certification or the opposition to that motion.
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Daubert oppositions and replies must be in same briefs as class certification merits.
Oppositions and replies relating to the Daubert motion must also be filed in the same briefs as argument on the merits of the class certification motion.
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Reply papers to motions in limine will not be considered.
No reply papers will be considered.
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Page 5 | MOTIONS IN LIMINE
Parties must be prepared to address specified issues at the pretrial conference, including raising jury instruction disputes to be resolved before opening statements.
At the pretrial conference, the parties should be prepared to address motions in limine, the written questionnaire, time limits for opening and closing arguments, and any issues relating to exhibits or evidence. If either party believes that a dispute about jury instructions must be resolved before opening statements, it should raise these issues at the pretrial conference. Otherwise, the Court will typically discuss jury instructions with the parties during trial.
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Page 8 | PRETRIAL CONFERENCE
Motions must follow Criminal Local Rule 47-2 for filing and notice.
Motions should be filed and noticed in accordance with Criminal Local Rule 47-2 unless otherwise ordered.
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Page 3 | Motions
Motions in limine due 14 days before pretrial conference; oppositions due 7 days before; no replies.
Any motions in limine must be filed no later than 14 days before the pretrial conference. Oppositions must be filed at least 7 days before the pretrial conference. No reply papers will be considered.
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Page 5 | Motions in Limine
Only one chance to seek class certification; overreaching may prevent renewal.
Plaintiffs’ counsel are warned that they may only have one chance to seek class certification. If a plaintiff grossly overreaches on a motion for class certification, thereby forcing a defendant to waste significant time and money respond to a motion that had virtually no chance of being granted in the first place, the Court will be far less likely to allow a renewed motion.
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Dispositive motion to dismiss allows moving CMC to 15 days after 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 to 15 days after the hearing on that motion. If the motion to dismiss is not dispositive, the initial case management conference will not be moved.
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Adjournment & Extension Requirements
Requests to extend case management deadlines must be submitted 72 hours prior to the deadline.
Request for extension of any case management deadlines: 72 hours prior to the deadline party wishes to extend
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Page 2 | TABLE OF KEY DEADLINES
Requests to reschedule a case management conference must be submitted at least 72 hours prior to the conference.
Request to reschedule a case management conference: At least 72 hours prior to the case management conference
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Page 2 | TABLE OF KEY DEADLINES
Extension requests must include a proposed order with future deadlines and extensions, a chart of current and proposed deadlines, and if parties disagree, details of prior extension requests.
When the parties request an extension of time, the parties must submit a proposed order listing all future deadlines and the proposed extensions. The parties must also submit, alongside any stipulation or administrative motion to change deadlines, a chart that includes the currently scheduled deadlines and the parties’ proposed deadlines. If the parties disagree on what state how many times the parties have requested extensions, 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 | SCHEDULING
Requests for extension of deadlines (excluding those parties can agree to without court order) must be filed at least 72 hours before the deadline.
Any request for an extension of a deadline (other than an extension that the rules allow the parties to arrange between themselves without a court order) must be filed no later than 72 hours prior to the deadline.
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Page 3 | SCHEDULING
Motions to continue hearings or case management conferences must be filed at least 72 hours before the scheduled appearance; no schedule changes are permitted without a court order.
No changes to the Court’s schedule can be made except by order of the Court. Any motion to continue a hearing or case management conference must be made no later than 72 hours prior to the scheduled appearance.
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Page 3 | SCHEDULING
Parties must file a separate stipulation or motion at least 72 hours before a case management conference to request a continuance.
If the parties wish to continue a case management conference, they must file a stipulation or motion—in a separate filing from their joint case management statement—at least 72 hours prior to the conference.
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Page 5 | SCHEDULING
Requests to continue the initial case management conference in FLSA cases are almost never granted, even with a pending motion to dismiss, unless the parties have a tolling agreement.
The court will almost never grant requests to continue the initial case management conference in FLSA cases—even if there is a pending motion to dismiss—unless the parties have reached a tolling agreement.
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Page 21 | WAGE AND HOUR CASES
Page limit increase motions must be filed at least 72 hours before brief deadline.
Motions to increase page limits will almost never be granted, but any such motion must be filed no later than 72 hours before the brief is due.
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Page 10 | BRIEFS
Extension requests must be filed at least 72 hours before deadline.
Any request for an extension of a deadline (other than an extension that the rules allow the parties to arrange between themselves without a court order) must be filed no later than 72 hours prior to the deadline.
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Motion to continue hearing must be filed at least 72 hours before scheduled appearance.
Any motion to continue a hearing or case management conference must be made no later than 72 hours prior to the scheduled appearance.
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Case management conference continuances require separate filing at least 72 hours before.
If the parties wish to continue a case management conference, they must file a stipulation or motion—in a separate filing from their joint case management statement—at least 72 hours prior to the conference.
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Case management conference continuances require separate filing at least 72 hours before conference.
If the parties wish to continue a case management conference, they must file a stipulation or motion—in a separate filing from their joint case management statement—at least 72 hours prior to the conference.
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Motions to continue hearings must be filed at least 72 hours in advance.
Any motion to continue a hearing or case management conference must be made no later than 72 hours prior to the scheduled appearance.
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Extension requests must be filed at least 72 hours before the deadline.
Any request for an extension of a deadline (other than an extension that the rules allow the parties to arrange between themselves without a court order) must be filed no later than 72 hours prior to the deadline.
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Discovery cut-off is 14 days before pretrial conference; late disclosure requires good cause and 24-hour disclosure.
Absent a contrary order from the Court, the discovery cut-off date is 14 days before the pretrial conference. Any material disclosed after that date will be excluded unless the disclosing party: (i) can show good cause for why it was not sought, obtained, and disclosed sooner; and (ii) discloses it within 24 hours of receipt of the material.
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Page 4 | Discovery Cut-Off
Trial dates are firm and will not be continued except in extraordinary circumstances.
Once a trial date has been set, the parties should treat it as firm. Absent extraordinary circumstances, the Court will not continue a trial date.
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Page 4 | SCHEDULING
Page limit increase motions must be filed 72 hours before brief deadline.
Motions to increase page limits will almost never be granted, but any such motion must be filed no later than 72 hours before the brief is due.
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Continuances of case schedules for mediation or settlement are usually not granted.
Stipulations or motions to continue case schedules for mediation or settlement purposes will usually not be granted.
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Page 4 | SCHEDULING
Pretrial conference 1-2 weeks before trial; dispositive motions due 2-3 months before pretrial.
The pretrial conference will be 1 or 2 weeks before the trial. The last day for a hearing on dispositive motions will be roughly 2 to 3 months before the pretrial conference.
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Trial dates typically set 12-16 months after complaint filing.
The trial date will almost always be 12–16 months after the date the original complaint was filed.
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Case management conference can be moved to 15 days after dispositive motion to dismiss 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 to 15 days after the hearing on that motion.
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Hearings are typically vacated no later than three days before the scheduled date if not needed.
If the Court determines a hearing is not necessary, it will usually be vacated no later than three days before the hearing.
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Chambers Communication Rules
Notify Bhavna Sharma by call and email for TROs, 24-hour stipulations, or other emergencies.
Counsel should call and email Judge Chhabria's Courtroom Deputy, Bhavna Sharma, 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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Parties desiring daily transcript and/or real-time reporting must arrange with the Court Reporter Supervisor at least 14 days before trial.
Should a daily transcript and/or real-time reporting be desired, the parties shall make arrangements with the Court Reporter Supervisor, at ( Transcripts@cand.uscourts.gov., at least 14 days before the trial date.
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Page 9 | PRETRIAL ARRANGEMENTS
Parties must contact Courtroom Deputy Bhavna Sharma to discuss courtroom layout questions at least 10 days before trial.
The parties should contact the Courtroom Deputy, Bhavna Sharma, at vccrd@cand.uscourts.gov, to discuss any questions or issues about the layout of the courtroom. Parties must contact Ms. Sharma at least 10 days prior to trial.
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Page 10 | PRETRIAL ARRANGEMENTS
Parties must request a U.S. Marshal court order to bring equipment into the courthouse by contacting the Courtroom Deputy no later than 14 days before trial.
The United States Marshal requires a court order to allow equipment into the courthouse. To request such an order, the parties should contact the Courtroom Deputy no later than 14 days before trial.
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Page 10 | PRETRIAL ARRANGEMENTS
Hearings in Social Security cases scheduled 60 days after opposition brief, with 2-3 day notice if canceled.
Judge Chhabria’s default rule is to have hearings in Social Security cases. The Court will schedule a hearing for its civil law and motion calendar for approximately 60 days after an opposition brief is filed. Counsel are free to meet and confer on a mutually acceptable hearing date, and contact Bhavna Sharma, Judge Chhabria’s Courtroom Deputy, to schedule a hearing on that date. If, after reviewing the papers and the record, the Court decides a hearing is not necessary, it will typically notify the parties within 2–3 days of the hearing.
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Page 19 | SOCIAL SECURITY CASES
Hearings in habeas cases (with counsel) scheduled 60 days after answer, with 2-3 day notice if canceled.
Judge Chhabria’s default rule is to have hearings in habeas cases where the petitioner is represented by counsel. The Court will schedule a hearing for its civil law and motion calendar for approximately 60 days after an answer is filed. Counsel are free to meet and confer on a mutually acceptable hearing date, and contact Bhavna Sharma, Judge Chhabria’s Courtroom Deputy, to schedule a hearing on that date. If, after reviewing the papers and the record, the Court decides a hearing is not necessary, it will typically notify the parties within 2–3 days of the hearing.
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Page 19 | HABEAS CASES
Notify Courtroom Deputy Bhavna Sharma by call and email for emergency applications.
Counsel should call and email Judge Chhabria's Courtroom Deputy, Bhavna Sharma, 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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Defense counsel must email a copy of the plea agreement to the specified chambers email address when entering a plea pursuant to a plea agreement.
If a plea is being entered pursuant to a plea agreement, counsel for the defendant shall email a copy of the plea agreement to Bhavna Sharma at vccrd@cand.uscourts.gov no later than noon the business day before the plea is to be entered.
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Page 2 | CHANGE OF PLEA
Contact Bhavna Sharma about courtroom layout and technology
Contact Bhavna Sharma regarding courtroom layout and technology
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Page 2 | Contact Bhavna Sharma regarding courtroom layout and technology
Daily transcript/real-time reporting requires arrangements with Court Reporting Services at least 14 days before trial.
Should a daily transcript and/or real-time reporting be desired, the parties shall make arrangements with Kristen Melen, Supervisor of the Court Reporting Services, at (415) 522-2079, at least 14 days before the trial date.
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Page 10 | PRETRIAL ARRANGEMENTS
Parties must contact Courtroom Deputy Bhavna Sharma at least 10 days before trial for courtroom layout questions.
The parties should contact the Courtroom Deputy, Bhavna Sharma, at vccrd@cand.uscourts.gov, to discuss any questions or issues about the layout of the courtroom. Parties must contact Ms. Sharma at least 10 days prior to trial.
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Page 10 | PRETRIAL ARRANGEMENTS
Counsel must consult with each other and Bhavna Sharma daily about exhibits in evidence.
Counsel must consult with each other and with Bhavna Sharma at the end of each trial day about which exhibits are in evidence and any limitations thereon. If there are any disagreements, counsel should promptly bring them to Judge Chhabria's attention.
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Page 10 | Exhibits
Counsel must confer with Bhavna Sharma before closing arguments to verify exhibits.
At the close of evidence, before closing arguments, counsel must confer with the Bhavna Sharma to make sure the exhibits in evidence are in good order.
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Page 10 | Exhibits
Arrange daily transcript/real-time reporting with Kristen Melen at least 14 days before trial.
Should a daily transcript and/or real-time reporting be desired, the parties shall make arrangements with Kristen Melen, Court Reporter Supervisor, at (415) 522-2079, at least 14 days before the trial date.
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Page 10 | Pretrial Arrangements
Contact Bhavna Sharma within 10 days before trial for courtroom layout questions.
The parties should contact Bhavna Sharma no later than 10 days before trial to discuss any questions or issues about the layout of the courtroom.
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Page 11 | Courtroom Layout
Parties may request an expedited initial case management conference by emailing Judge Chhabria’s Courtroom Deputy.
Parties who would like an expedited initial case management conference can request one by emailing Judge Chhabria’s Courtroom Deputy, Bhavna Sharma.
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Page 5 | SCHEDULING
Claim construction tutorial may be scheduled 7 days before hearing by contacting Courtroom Deputy.
If the parties believe it would be helpful for the Court, they should schedule a claim construction tutorial to occur 7 days prior to the claim construction/summary judgment hearing. The parties should contact Judge Chhabria’s Courtroom Deputy, Bhavna Sharma, to schedule the tutorial.
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Page 19 | PAGE 19
Court does not issue tentative rulings but announces tentative thinking at hearing outset.
The Court ordinarily will not issue tentative rulings, but it typically announces its tentative thinking at the outset of the hearing.
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Parties must discuss exhibit handling with judge and courtroom deputy, including witness binders.
The parties should discuss with Judge Chhabria and the Courtroom Deputy how they will handle showing exhibits to witnesses, including whether witness binders are necessary.
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Junior Lawyer Participation Incentives
Attorneys with 7 or fewer years of experience arguing motions may notify the Courtroom Deputy within 7 days of the hearing to increase the likelihood of an oral hearing; co-counsel with more experience may also present argument.
If a motion will be argued by an attorney who has 7 years or less of experience, counsel may notify the Courtroom Deputy of that fact within 7 days of the hearing. The Court will take this into account in deciding whether to vacate the hearing and submit the motion on the papers, putting a thumb on the scale in favor of a hearing if arguing counsel has 7 years or less of experience. Co-counsel with more than 7 years of experience may still offer argument for a few minutes at the end of the hearing.
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Page 12 | HEARINGS AND TENTATIVE RULINGS
Junior lawyers (7 years or less experience) may notify Courtroom Deputy within 7 days of hearing.
If a motion will be argued by an attorney who has 7 years or less of experience, counsel may notify the Courtroom Deputy of that fact within 7 days of the hearing.
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Senior co-counsel may argue for a few minutes at the end of hearings with junior lawyers.
Co-counsel with more than 7 years of experience may still offer argument for a few minutes at the end of the hearing.
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