Judge Gonzalo P. Curiel

Absent leave of court, each motion in limine and each opposition thereto shall be limited to ten pages in length. Attachments to any motion in limine or opposition thereto shall also be limited to ten pages in length.

Absent leave of court, separate statements shall be limited to 15 pages and must comply with the font requirements of Civil Local Rule 5.1.

The courtesy copy shall contain the CM/ECF document header on the top of each page.

The separate statement must be in a two-column format with the moving party providing in numerical sequence the undisputed material facts in the first column followed by the evidence citation that establishes those undisputed facts. In opposition, the opposing party shall indicate in the second column whether the fact is 'disputed' or 'undisputed.' If disputed, the opposing party must state in the second column, directly opposite the fact in dispute, the reasons for the dispute and cite the evidence that supports the position that the fact is controverted.

If a filing has more than three (3) exhibits, the exhibits must be tabbed.

Proposed orders shall be submitted in Word format simultaneously with all motions, except motions that are fully noticed and set for hearing at least 28 days beyond the date of filing. In accordance with Section 2(h) of the Electronic Case Filing Administrative Policies and Procedures Manual, proposed orders shall not contain the name and law firm information of the filing party and shall not contain the word “proposed” in the caption. Counsel shall email proposed orders to opposing counsel and to the following email address: efile_curiel@casd.uscourts.gov, and include the docket number and case name in the subject line of the email.

The joint proposed jury instructions, trial briefs, proposed verdict form, voir dire questions, statement of the case, and exhibit lists are to be placed in a trial notebook, and are due seven (7) days before the motion in limine hearing date unless the Court orders otherwise.

Pursuant to Civil Local Rule 16.1(f)(6), the Court requires that the parties email to Chambers a proposed pretrial order in Word format at least seven (7) days before the pretrial conference. The proposed pretrial order must include all elements set out in Civil Local Rule 16.1(f)(6)(c) and any other issues relevant to the trial.

The proposed jury instructions, proposed verdict form, and statement of the case shall also be emailed to the Court in Word format.

All parties are required to cooperate in completing the proposed pretrial order.

Any AI-generated material that does not have an accompanying notice shall not be considered by the Court.

Counsel shall serve a notice to the opposing party identifying AI-generated evidentiary material with sufficient specificity to locate it (i.e., via production number, attaching a copy to the notice, providing a copy on request). This notice should be served with the production or disclosure of any AI-generated evidentiary material.

In terms of AI-generated documents or materials that may become exhibits or evidence in an action, a pro se party or counsel shall follow the below procedures:

Parties and counsel shall not file, proffer, or present to the Court exhibits, demonstratives, or other evidentiary or factual material that contain AI-hallucinated assertions of fact.

Failure to confirm the accuracy or basis for an assertion of fact or evidence created by an AI tool is grounds for potential sanctions.

If the parties settle a case, counsel shall file a “Notice of Settlement” and immediately inform the magistrate judge of the settlement. If the magistrate judge does not set a deadline for the filing of a “Joint Motion to Dismiss,” the parties shall file the “Joint Motion to Dismiss” and email a proposed order to this Court within twenty-eight (28) days of the settlement.

Seven (7) days before trial, counsel will submit proposed Findings of Fact and Conclusions of Law by hard copy and an electronic copy of the proposed Findings of Fact and Conclusions of Law shall be emailed in Word format to efile_curiel@casd.uscourts.gov.

Proposed orders for preliminary approval of class certification and/or preliminary settlement approval must be supported by an affidavit and memorandum

In addition to the above information, where class members are entitled to non-monetary relief, such as discount coupons, debit cards, or similar instruments, the number of class members availing themselves of such relief and the aggregate value redeemed by the class members and/or by any assignees or transferees of the class members’ interests.

Where injunctive and/or other non-monetary relief has been

The total settlement fund, the total number of class members, the total number of class members to whom notice was sent and not returned as undeliverable, the number and percentage of claim forms submitted, the number and percentage of opt-outs, the number and percentage of objections, the average and median recovery per claimant, the largest and smallest amounts paid to class members, the method(s) of notice and the method(s) of payment to class members, the number and value of checks not cashed, the amounts distributed to each cy pres recipient, the administrative costs, the attorneys’ fees and costs, the attorneys’ fees in terms of percentage of the settlement fund, and the multiplier, if any.

Within 21 days after the distribution of the settlement funds and payment of attorneys’ fees, the parties should file a Post-Distribution Accounting, which provides the following information:

Despite the spread of generative AI tools, counsel and pro se parties are responsible for providing the Court with complete and accurate representations of any submission, including filings, demonstratives, evidence, or oral argument, consistent with Federal Rule of Civil Procedure 11, the California Rules of Professional Conduct, and any other applicable legal or ethical guidance. Use of generative AI tools is not prohibited, but counsel and pro se parties must, at all times, personally confirm for themselves the accuracy of any content generated by these tools.

Any opposition to a summary judgment motion shall include a response to the separate statement that responds to each of the material facts contended by the moving party to be undisputed, indicating if the opposing party agrees or disagrees that those facts are undisputed.

Additionally, any submission containing AI-generated content must include a certification that counsel or the pro se party has personally verified the content’s accuracy. Failure to include this certification or comply with this verification requirement will be grounds for sanctions.

All motions for summary judgment shall be accompanied by a separate statement setting forth plainly and concisely all material facts that the moving party contends are undisputed. Each of the material fact shall be followed by a reference to the supporting evidence.

Pursuant to Criminal Local Rule 23.1, the parties may, no later than five court days before the date of trial, serve and file briefs on all significant disputed issues of law, including foreseeable procedural and evidentiary issues.

The parties should each submit in Word format and hardcopy, proposed jury instructions to the Court on the first day of trial, unless otherwise ordered by the Court.

Counsel shall file the completed sentencing summary charts required by Criminal Local Rule 32.1.a.8 in the record no later than seven calendar days before the sentencing hearing.