Judge Michael K. Ryan
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Jury Instructions
- With Electronic Submission
Working Copies
- Hand Delivery • Upon Filing
All filings
Court-wide- Chambers Drop Off
Deposition Designations
Court-wide- Email • As Directed In Pretrial Order
Adjournments
- Requests to continue or strike a motion must be emailed to the bailiff with case name, cause number, and noting date, and a Notice Striking Motion must be filed.
Request must include
Communication
Chambers
Phone
Court-wideChambers
Document Format Requirements21 rules
The quote is in the court's document. The summary is not checked yet.Mandatory?
NOTE: Failure to complete this form and disclose witnesses may result in exclusion of witnesses or other sanctions.
Summary: Failing to complete the form and disclose witnesses may result in exclusion of witnesses or other sanctions.
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Uncited instructions SHOULD NOT have any identifying headers or footers or page numbers on them.
Summary: Uncited jury instructions must not contain identifying headers, footers, or page numbers.
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Double-spaced (Do not add space between paragraphs. Everything should be double spaced consistenty.)
Summary: Jury instructions must be double-spaced throughout with no extra space added between paragraphs.
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Justified 1-inch margins
Summary: Jury instructions must use justified text with 1-inch margins.
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Size 12 Times New Roman font
Summary: Jury instructions should be prepared in Size 12 Times New Roman font.
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Uncited instructions SHOULD NOT be numbered or titled
Summary: Uncited jury instructions must not be numbered or titled.
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All sets should be provided to the bailiff electronically, via email in Word format, both cited and uncited for the Court's use and reference.
Summary: Jury instruction sets emailed to the bailiff must be in Word format.
DOCX
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Moving Party marks their objections using brackets to demonstrate which portion they object to and a different color of ink-pen (black or blue) or text box, on the page, next to the highlighted portion of the counter-designation to which they are objecting and tabs the page with a post-it note. (Please write your objections on the page and not on the tabs.) Reason for objections should be noted by citing the applicable rule. (ie. Hearsay, ER904, etc.)
Summary: The moving party must mark objections to counter-designations with brackets in a different color of ink-pen (black or blue) or text box on the page, tab with a post-it note, write objections on the page (not the tabs), and cite the applicable rule for each objection.
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Opposing Party marks their objections using brackets to demonstrate which portion they object to and in ink-pen (blue or black) or electronic text box, on the page, next to the highlighted portion to which they are objecting and tabs the page with a post-it note. (Please write your objections on the page and not on the tabs.)
Summary: The opposing party must mark objections with brackets in blue or black ink-pen or an electronic text box on the page next to the highlighted portion, tab the page with a post-it note, and write objections on the page rather than on the tabs.
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Email a copy of the completed deposition designation charts for each deposition in Word format to the bailiff for rulings and entry by the Court.
Summary: Completed deposition designation charts for each deposition must be emailed to the bailiff in Word format for rulings and entry by the Court.
DOCX
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Moving Party (party initially introducing the deposition for designation) marks their designations by highlighting each section being designated in a particular color (i.e. yellow highlighter)
Summary: The moving party must highlight each designated deposition section in a single color (e.g., yellow highlighter).
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USE ONE SET OF DEPOSITIONS TO MARK FOR THE JUDGE'S CONSIDERATION, as follows:
Summary: Parties must use one set of depositions to mark for the judge's consideration.
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Opposing Party marks their counter-designations by highlighting each section being designated in a different color from that used by the moving party (i.e. green highlighter)
Summary: The opposing party must highlight counter-designations in a color different from the moving party's color (e.g., green highlighter).
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Department 37 is a hardcopy (paper) court and prefers working copies submitted to the Judge’s mailroom C-203, with Judge Ryan’s name and the case information clearly marked in the upper right hand corner, pursuant to the local court rules. This can be accomplished by submitting them through the working copies portal in the Clerk’s E-Filing system or having them delivered to the mailroom via a courier or alternative method. The Court does not accept working copies via email, absent prior authorization.
Summary: Department 37 requires hardcopy working copies delivered to mailroom C-203 (or via the working copies portal), marked with the judge's name and case information in the upper right corner; email submission is not accepted absent prior authorization.
Paper
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Use tenths of hours for estimates, i.e. .1, .2, .5, 1.0 etc. and TOTAL this form, when it has been completed.
Summary: Time estimates on the form must be expressed in tenths of hours (e.g., .1, .5, 1.0), and the form must be totaled once completed.
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Counsel are to confer to determine estimations for cross-examination time for each party's witnesses and prepare this document.
Summary: Counsel must confer to determine cross-examination time estimates for each party's witnesses and jointly prepare the document.
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Participants shall not use the chat function, unless asked to respond by the meeting host.
Summary: Zoom participants may not use the chat function unless asked by the host.
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Observers shall join with video disabled and their microphone on MUTE. Failure to comply with this may result in the participant being removed from the meeting.
Summary: Zoom observers must join with video disabled and microphone muted or risk removal.
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Please note that there are 5 hours in a full trial day and consider your witness exam totals, jury questions for the witnesses in civil cases, opening and closing arguments, voir dire, time for motions in limine, etc. when estimating the total trial length for your case.
Summary: Trial length estimates must assume 5 hours per full trial day and account for witness examinations, jury questions in civil cases, opening and closing arguments, voir dire, and motions in limine.
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If there are additional parties, each party should create and complete the required information for that party's witnesses.
Summary: Each additional party must create and complete the witness estimate information for its own witnesses.
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You may use this form, or create one of your own, as long as it includes the requested information.
Summary: Parties may use the court's form or their own equivalent form, provided it includes the requested information.
Document Filing Requirements19 rules
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Counsel is requested to meet and confer over jury instructions and prepare the following sets for the Court: One set of agreed (by all parties) instructions. One set from each party of their own proposed instructions, which are not agreed by all parties.
Summary: Counsel must meet and confer and prepare one set of all-party agreed jury instructions plus a separate set from each party of disputed proposed instructions.
Document Type
Jury Instructions
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Proposed verdict forms must be provided with proposed instructions. Parties should attempt to get a single, agreed verdict form, if possible. Alternatively, each party should propose their own verdict form.
Summary: Proposed verdict forms must accompany proposed instructions, with parties attempting a single agreed verdict form or otherwise proposing their own.
Document Type
Jury Instructions
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List all designations, counter-designations, objections on the Court-provided deposition designation charts-one completed chart for each deposition.
Summary: All designations, counter-designations, and objections must be listed on the Court-provided deposition designation charts, with one completed chart per deposition.
Document Type
Deposition Designation Chart
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A Key should be included on the front page of the deposition, showing what each marking stands for (ie. Plaintiff designations - yellow highlighter, Defendant objections - Black pen, Defendant Counter-designations - Green highlighter, Plaintiff objections - Blue pen)
Summary: A key explaining what each marking stands for must be included on the front page of the deposition.
Document Type
Marked Deposition
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Reason for objections should be noted by citing the applicable rule. (ie. Hearsay, ER904, etc.) Do not include lengthy narratives about objections.
Summary: Objections must state the reason by citing the applicable rule (e.g., Hearsay, ER904) without lengthy narratives.
Document Type
Deposition Objections
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Motions for exceptional sentences shall be accompanied by proposed findings and submitted 7 days prior to the hearing pursuant to CrR 7.1(b).
Summary: Motions for exceptional sentences must include proposed findings and be submitted 7 days before the hearing.
Document Type
Motion For Exceptional Sentence
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Please pay careful attention to the “meet and confer” requirements of LCR 37(e) and CR26(i). The conference of counsel must be in person or by telephone. Email is not a substitute for a dialogue on these issues. A certification by counsel that the conference requirements of these rules have been met is required, and should set out with particularity the nature, extent, and time of the conference.
Summary: Discovery motions require an in-person or telephone meet-and-confer under LCR 37(e)/CR 26(i) (email insufficient) and a certification describing the conference with particularity.
Document Type
Motion To Compel Discovery
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Presentence Reports are required on all felonies pursuant CrR 7.1(a). This Court also requests them on all misdemeanors, regardless of whether the recommendation is agreed.
Summary: Presentence reports are required for all felonies and requested for all misdemeanors.
Document Type
Presentence Report
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Parties must comply with all the requirements of KCLR 7 when setting and submitting motions without oral argument. Please provide a copy of all proposed orders in Word format to the Court through the eworking copies portal.
Summary: Non-dispositive motions must comply with KCLR 7, and all proposed orders must be submitted in Word format through the eworking copies portal.
Document Type
Proposed Order
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When a party is seeking an Order to Show Cause, the Motion for Order to Show Cause should be submitted to the Court and must include the underlying motion for which the party would be expected to show cause on.
Summary: Motions for Orders to Show Cause must include the underlying motion.
Document Type
Motion For Order To Show Cause
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It is not sufficient to refer to materials in your briefing without including them in your submissions to the Court. To be considered by the Court, working copies must include all materials referenced therein and must not be redacted. (see also LCR 7 (b)(5)(B)) Additionally, out of state authorities must be provided.
Summary: Working copies must include all referenced materials unredacted, and out-of-state authorities must be provided.
Document Type
Working Copies
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Judge Ryan requires all parties and counsel to work together to complete the witness time examination form, which must be submitted together with responses to case management emails from the bailiff, prior to setting a pretrial conference. All other pretrial materials are due five court days prior to trial, unless otherwise requested by the Court.
Summary: The witness time examination form must be submitted with case management email responses before setting a pretrial conference; all other pretrial materials are due five court days before trial.
Document Type
Pretrial Materials
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Proposed orders should be submitted in Word format. The Court does not accept working copies via email, except proposed orders when working copies have been submitted in hard copy and not through the Clerk’s E-Working Copies system.
Summary: Proposed orders must be in Word format; email is accepted only for proposed orders when working copies were submitted in hard copy rather than through the E-Working Copies system.
Document Type
Proposed Order
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This Court is considering all Motions for Revision without oral argument at this time. The moving party shall re-note their Motion for Revision without oral argument pursuant to LCR 7. This includes providing the index/list of submissions that were considered by the Commissioner as well as hard copies or eworking copies of those documents. A response is requested from the non-moving party.
Summary: Motions for Revision are decided without oral argument; the movant must re-note under LCR 7 with the Commissioner's submission index and copies, and a response is requested from the non-moving party.
Document Type
Motion For Revision
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AI may not be used in preparation of materials presented in court cases.
Summary: AI may not be used to prepare materials presented in court cases.
Document Type
Court Materials
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Witnesses appearing by deposition shall also be included on this form and designated as "appearing by deposition."
Summary: Witnesses who will appear by deposition must be listed on the form and designated as 'appearing by deposition.'
Document Type
Estimate Of Witness Examinations
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There should be no duplication in these sets, unless there is an issue over the language for a specific instruction.
Summary: There should be no duplication between the agreed and proposed instruction sets unless the dispute concerns the language of a specific instruction.
Document Type
Jury Instructions
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DATED this _____ day of ___________, 2025. The Honorable _______________ Submitted by: By:
Summary: The deposition designation chart template must be dated and include the judge's name and a submitted-by signature block.
Document Type
Deposition Designation Chart
The quote is in the court's document. The summary is not checked yet.Note?
Please note that the Court always prefers to use Washington State Pattern Instructions, if one is applicable.
Summary: The Court prefers the use of Washington State Pattern Instructions whenever one is applicable.
Document Type
Jury Instructions
Filing & Service rules
Electronic Filing Rules
The witness examination estimate form must not be filed with the Clerk's Office; it is submitted directly to the bailiff by email instead.
DO NOT FILE THIS DOCUMENT WITH THE CLERK'S OFFICE.
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Page 1 | Estimate of Witness Examinations
All jury instruction sets, both cited and uncited, must be emailed to the bailiff in Word format for the Court's use and reference.
All sets should be provided to the bailiff electronically, via email in Word format, both cited and uncited for the Court's use and reference.
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Page 1 | Attorney Guidelines for Preparing Jury Instructions for the Court
Filing Timing and Cure Windows
Marked depositions must be provided to the bailiff as close to the beginning of trial as possible and well in advance of intended use, or as directed by the Court.
Provide the marked depositions to the bailiff as close to the beginning of the trial as possible, and well in advance of intended use, or as directed by the Court.
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Page 1 | Marking of Deposition Designations for trial
In civil trials, if ordered, all exhibits must be uploaded to Case Center no later than five court days before trial.
For civil trials, parties must comply with the Court’s pretrial conference order. If ordered, parties must upload all exhibits into Case Center no later than five court days before the scheduled trial date.
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Page 1 | Trial Exhibits
Working copies must be submitted on the day of service per LCR 7(b)(4)(F), include the word count per LCR 7(b)(5)(B)(vi), and must not be held until the reply.
Working copies must be submitted in compliance with LCR 7(b)(4)(F), on the day they are to be served on the other parties and must include the Word Count pursuant to LCR 7(b)(5)(B)(vi). DO NOT wait to submit working copies with your reply.
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Page 1 | Working Copies and Proposed Orders
Service and Proof of Service Rules
Signed orders are delivered electronically when email addresses are on file; otherwise parties may retrieve them via KCScript within 24-48 hours of filing.
Copies of signed orders will be delivered to counsel or the parties electronically if email addresses have been provided to the Court. If no email address is available for an attorney or a party, parties/counsel may access the order through KCScript within 24-48 hours of the order being filed.
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Page 1 | Non-Dispositive Motions
Courtesy Copy Requirements
In addition to the emailed sets, hard copy working copies of the jury instructions must also be presented to the Court.
This does not replace the requirement to present hard copy working copies to the Court as well.
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Page 1 | Attorney Guidelines for Preparing Jury Instructions for the Court
Courtesy copies of working copies must not be sent by email because hard copies are required.
The Court requests that courtesy copies of working copies not be sent through email, since hard copies are required.
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Page 1 | Working Copies and Proposed Orders
Sealing & Redaction Procedures
Protective order sealing must comply with the stated limitations and Washington General Rule (GR) 15 before documents are sealed.
This protective order is therefore subject to these limitations and must comply with these provisions and General Rule (GR) 15 before any documents are sealed in the public file.
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Page 1 | Attachment to Protective Order
Documents with substantive redactions may not be filed without prior court permission.
Documents with substantive redactions shall not be filed without prior permission by of this Court.
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Page 1 | Attachment to Protective Order
Moving parties bear the burden of identifying competing interests and less restrictive alternatives (such as redaction) when seeking to seal documents.
Moving parties seeking to seal any documents filed with the court must meet this burden. Specifically, they must identify specific competing interests of parties and the public or considered alternatives or less restrictive methods, such as redaction of confidential or proprietary information. Finally, the order must be no broader in its application necessary to serve its purpose.
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Page 1 | Attachment to Protective Order
Parties must obtain a sealing/redaction order and receive a court ruling before filing documents containing sealed information.
Before filing any substantive documents that contain information sought to be sealed, the moving party must obtain an order allowing documents to be sealed or redacted. This requires the moving party to allow sufficient time for noting its motion and receiving a ruling from the Court prior to filing the documents.
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Page 1 | Attachment to Protective Order
A court order authorizing sealing must be obtained before any document is filed under seal, via motion noted without oral argument.
each document that is to be filed with the court must be subject to the above analysis and treatment and a court order reflecting the same and authorizing sealing of that pleading and file must be obtained. This may be done by motion noted without oral argument.
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Page 1 | Attachment to Protective Order
Motions to seal must comply with GR 15/LGR 15 and caselaw; party agreement alone is insufficient; a proposed order with required findings is needed; documents may not be filed under seal or redacted without a prior court order.
Motions to seal must comply with GR 15, LGR 15 and controlling caselaw. The agreement of the parties alone is not a sufficient basis for the sealing or redaction of court records. The moving party should provide a proposed order that includes the required findings. Documents must not be ‘”filed under seal” or redacted in the court file without prior permission (order) of the Court, regardless of what that parties believe is allowed by any Protective Order filed in the case.
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Page 1 | Protective Orders and Motions to Seal
Before filing substantive documents containing information sought to be sealed, the movant must obtain a court order allowing sealing/redaction, allowing sufficient time for noting and ruling.
Before filing any substantive documents that contain information sought to be sealed, the moving party must obtain and order allowing documents to be sealed or redacted. This requires the moving party to allow sufficient time for noting its motion and receiving a ruling from the Court prior to filing the documents. Documents with substantive redactions shall not be filed without prior permission of the Court.
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Page 1 | Protective Orders and Motions to Seal
Filing Bundling Requirements
The Court prefers that all designations, counter-designations, and objections for a single deposition be presented at the same time to avoid confusion or duplication regarding what requires rulings.
**Please note that the Court prefers that all designations, counter-designations and objections for one deposition be presented at the same time, to avoid any confusion or duplication regarding what requires rulings.
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Page 1 | Marking of Deposition Designations for trial
Adjournment & Extension Requirements
Requests to continue or strike a motion must be emailed to the bailiff with case name, cause number, and noting date, and a Notice Striking Motion must be filed.
Please notify the bailiff by e-mail if you need to continue or strike a motion -- always provide the case name, cause number, and the date for which the motion is noted, and file the Notice Striking Motion.
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Page 1 | Please Review the Following Before Contacting the Court
Chambers Communication Rules
Counsel/parties must jointly complete the witness examination estimate form and email it to the bailiff at ryan.court@kingcounty.gov as soon as possible.
Counsel/parties shall work together to complete this form and submit it to the bailiff via email at ryan.court@kingcounty.gov, as soon as possible.
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Page 1 | Estimate of Witness Examinations
Parties must immediately notify the bailiff when a case settles or a scheduled motion needs to be stricken.
Parties are requested to IMMEDIATELY notify the bailiff when a case settles and/or a scheduled motion needs to be stricken.
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Page 1 | Notifying the Court re Settlement and/or Need to Strike Scheduled Motions or Hearings
Parties must communicate with the court by email for scheduling/administrative matters, copy all parties, avoid substantive discussion, and comply with the King County Superior Court Email Policy or face sanctions.
Judge Ryan's court prefers for parties to communicate through email for any scheduling or administrative matters. This allows for all parties/counsel to be included in the correspondence to avoid ex parte communication. Parties shall review and comply with the Email Policy of King County Superior Court and shall not involve any substantive discussion about issues related to the case. Violations of these requirements may result in sanctions.
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Page 1 | Communications with the Court
Recording or photography while the Court is on the record is prohibited without prior permission.
Recording or photography of any kind while the Court is on the record is strictly prohibited without prior permission of the Court.
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Page 1 | Recording/Photography in the Courtroom or on Zoom
Hearing date requests are made by email to the bailiff with case title/cause number in the subject line, motion details in the body, all parties cc'd, and no slot is reserved until all counsel confirm availability.
Oral argument on motions is generally scheduled for Friday mornings. Requests for hearing dates are accepted by emailing the bailiff. It is recommended that parties contact the bailiff as far in advance as possible prior to the hearing. When contacting the bailiff, you should include the case title and cause number in the subject line of the email. In the body of the email advise whose motion and what type of motion it is and if there are other parties in the case intending to file motions for the same hearing, so that timing can be figured out appropriately. All other parties/counsel should be cc’d on the email. The bailiff will provide several dates/times and require the parties to confer and advise which date/time works best for the parties. No slots will be reserved until all counsel’s availability has been confirmed.
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Page 1 | Dispositive Motions and Hearing Requests
Requests for observer Zoom access must be emailed to the bailiff at least 48 hours before the hearing.
Any request for observers to have access via Zoom may be made by emailing the bailiff at least 48-hours prior to the hearing to confirm whether Zoom will be enabled during the hearing.
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Page 1 | Zoom/Virtual Proceedings
Parties may email ryan.court@kingcounty.gov to arrange an informal discovery conference, describing the dispute and each party's position succinctly, copying all parties.
If the parties agree to informal guidance or resolution, please email ryan.court@kingcounty.gov to arrange a conference. The email should – as succinctly and non-argumentatively as possible – describe the nature of the dispute and set forth each parties’ position. (As always, you must copy all parties on any email to the court.)
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Page 1 | Court Involvement in Discovery
Stipulations and agreed orders may be emailed to the bailiff but must be signed by all parties first.
Judge Ryan’s court does accept stipulations and agreed orders for consideration through email. They must be signed by all parties prior to sending to the bailiff.
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Page 1 | Working Copies and Proposed Orders