King County Superior Court Document Filing Requirements

Checked against the court's document on Sep 21, 2026CRITICAL

Applies to

Notice of court date

The hearing-requesting party must file the motion and affidavits separately together with the notice.

Party requesting hearing must file motion & affidavits separately along with this notice.

Checked against the court's document on Oct 3, 2026CRITICAL

Applies to

Motion

Must include

proposed order

A filed motion must be accompanied by a working copy of the motion and a Word version of the proposed order for the judge.

When a motion is filed with the Court, a copy of the motion along with a word version of the proposed order you wish the judge to sign is required as a “working copy” for the judge.

Checked against the court's document on Oct 3, 2026CRITICAL

Applies to

Sentencing memorandum

The court will not proceed with a scheduled sentencing hearing unless it has received sentencing memoranda from both the State and the Defense.

Judge Robertson will not proceed with a pre-scheduled sentencing hearing unless a memorandum on sentencing has been received from both State and Defense.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Motion or opposition

A party requesting oral argument must put “ORAL ARGUMENT REQUESTED” on the front page of its motion or opposition.

The Court or a party in the case may request oral argument. If you wish to request oral argument, please include "ORAL ARGUMENT REQUESTED" on the front page of your motion or opposition.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Proposed order

Must include

proposed order

All parties must provide proposed orders in MS Word format at least one day before the scheduled hearing.

All parties must provide any proposed orders to the court in MS Word format at least 1 day prior to your scheduled hearing.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Notice striking hearing

If the moving party will not proceed, it must immediately notify the court to strike the hearing and file a Notice Striking Hearing.

If the moving party elects for any reason not to proceed with the motion, that party shall notify the court to strike the hearing immediately, per KCLCR 7(b)(4)(H) and file a Notice Striking Hearing in the court file.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

All motions must be noted pursuant to LCR 7(b) and filed with the clerk.

All motions, including stipulated motions, must be noted pursuant to LCR 7(b) and filed with the clerk.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

proposed order

Both sides must submit a proposed order for every motion.

For every motion, both sides must submit a proposed order.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Proposed order

Judge Petersen requires a Word version of all proposed orders; may be submitted by email to petersen.court@kingcounty.gov or through the e-Working Copies application.

Judge Petersen requires a Word version of all proposed orders. You may submit a Word version of your proposed order: By email to petersen.court@kingcounty.gov, or Through the e-filing portal using the e-Working Copies application.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

certificate of service

Parties must comply with all KCLR 7 requirements when setting motions without oral argument, including filing proof of service.

Parties must comply with all the requirements of KCLR 7 when setting motions without oral argument, including providing and filing proof of service of the motion.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Notice of hearing

The Notice of Hearing must be filed.

File the Notice of Hearing.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Proposed order

Proposed orders must be submitted in Word format via e-working copies (Portal).

Submit Proposed Orders (Word Format) via e-working copies (Portal)

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Motion

Must include

proposed order

Proposed orders must accompany all motions and opposition submissions.

Per local court rules, proposed orders must accompany all motions and opposition submissions and should be submitted in Word (.docx) format.

Checked against the court's document on Sep 21, 2026CRITICAL

Applies to

Confirmation

If ADR with a neutral third party was not accomplished, the confirmation must explain why and identify arrangements to complete ADR before trial, and failure may lead to sanctions.

If ADR with a neutral third party WAS NOT accomplished, you must provide a detailed explanation and identify what arrangements have been made to complete ADR before trial. Counsel/party(ies) may be sanctioned for failure to comply with this requirement.

Checked against the court's document on Oct 3, 2026CRITICAL

Criminal cases

Applies to

Electronically filed working copy

Must include

proposed order

Electronically filed working copies must include the proposed order in Word format.

All electronically filed working copies shall also include a proposed order(s) in Word format

Checked against the court's document on Sep 21, 2026WARNING

Applies to

Notice of court date

The notice must list the names, addresses, and telephone numbers of all parties requiring notice, including any guardians ad litem.

List the names, addresses and telephone numbers of all parties requiring notice (including GAL) on this page.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Working copy

Must include

judge name

Working copies must include the judge's name and hearing date/time in the upper right-hand corner of the first page.

Working copies should have the judge’s name and the date and time of the hearing in the upper right-hand corner of the first page of the motion.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Motion

Requests for oral argument must be indicated on the front page of the motion or opposition.

If you wish to request oral argument, please indicate this request on the front page of your motion or opposition.

Checked against the court's document on Oct 3, 2026WARNING

Applies to

Motion

A party requesting oral argument should note the motion under applicable court rules and place “Oral Argument Requested” in the upper-right corner.

If a party would like to request oral argument, the motion should be noted pursuant to the applicable court rules, simply noting in the upper right-hand corner "Oral Argument Requested."

Checked against the court's document on Sep 21, 2026INFO

Civil cases

Applies to

Proposed order

For contested motions, proposed orders are accepted via e-Working Copies or in Word format via email with all parties copied.

For contested motions, the Court will accept proposed order(s) via e-Working Copies or in Word format via email with all parties copied on that email.

Checked against the court's document on Sep 21, 2026INFO

Civil cases

Applies to

Stipulation

Stipulations and agreed orders may be submitted via email, e-Working copies, or the Judges' mailroom.

Stipulations and agreed orders may be submitted via email, to the court via e-Working copies, or to the Judges’ mailroom.

Checked against the court's document on Sep 21, 2026INFO

Civil cases

Applies to

Motion

If a party requests oral argument, the motion should be noted as 'Oral Argument Requested.'

If a party requests oral argument, the motion should be noted as "Oral Argument Requested."

Checked against the court's document on Sep 21, 2026INFO

Civil cases

Applies to

CD Request Form

To obtain a recording copy from the Clerk's Office Copy Center, submit a completed CD Request Form.

If you decide after the hearing or trial that you need a copy of the recording, you may obtain it directly from the Clerk’s Office Copy Center. You will need to submit a completed CD Request Form to the Clerk’s Office.

Checked against the court's document on Sep 21, 2026INFO

Applies to

Confirmation

The confirmation must state the name, mailing address, and telephone number of any unrepresented party.

If any party is not represented by counsel, state that party’s name, current mailing address, and telephone number.

Checked against the court's document on Sep 21, 2026INFO

Applies to

Confirmation

If the parties cannot confirm jointly, each party must file a separate confirmation.

If parties are unable to confirm jointly each party is required to file a separate confirmation.

Checked against the court's document on Sep 21, 2026INFO

Applies to

Confirmation

If counsel has another trial at the same time, the confirmation must identify the case name, cause number, venue, and trial dates.

If counsel has another trial scheduled at the same time, identify name, cause number, venue of case, and dates of trial.

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Civil cases

Applies to

Proposed order

A proposed order in substantially the following format should also be provided to the Court in Word format at least five court days prior to trial.

Summary: A proposed order substantially in the specified format must accompany the deposition designations submitted to the Court.

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Applies to

Working papers

If a party would like to request oral argument, the motion should be noted pursuant to the applicable court rules, with "ORAL ARGUMENT REQUESTED" noted in the upper right-hand corner of the working papers. If, after reviewing all briefing, the Court determines oral argument is appropriate, the bailiff will contact the parties and set a mutually acceptable time for oral argument.

Summary: To request oral argument on a motion, 'ORAL ARGUMENT REQUESTED' must be noted in the upper right-hand corner of the working papers, and the Court will set argument through the bailiff if it deems argument appropriate.

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Applies to

Motion to shorten time

When a party wishes to request that the court consider a motion on shortened time, the underlying motion must be noted in the regular course, and a separate motion to shorten time submitted as well.

Summary: A motion for shortened time requires the underlying motion to be noted in the regular course plus a separate motion to shorten time.

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Applies to

Certification of defense counsel ?

Per the standard, attorneys are to submit one certificate per quarter.

Summary: Attorneys must submit one Supreme Court certification of defense counsel per quarter.

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Applies to

Omnibus hearing order

Must include

proposed order ?

Prior to the trial track Omnibus Hearing date, counsel shall meet, prepare a proposed Omnibus Hearing order, identify unresolved motions to be heard at trial, and exchange any additional discovery.

Summary: Before the trial track Omnibus Hearing, counsel must meet, prepare a proposed Omnibus Hearing Order, identify unresolved motions to be heard at trial, and exchange any additional discovery.

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Applies to

Omnibus hearing

Must include

proposed order ?

The parties shall propose an Omnibus Hearing Order at the Omnibus Hearing.

Summary: Parties must propose an Omnibus Hearing Order at the Omnibus Hearing.

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Applies to

Motion re bail or conditions of release ?

If a request to address bail or other condition of release is made at arraignment, a subsequent motion should set forth a change of circumstances. Upon receipt of such a motion, the court will determine whether a subsequent bond hearing will be set.

Summary: A motion addressing bail or conditions of release must set forth a change of circumstances, after which the court decides whether to set a bond hearing.

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Applies to

Certification of compliance

The Washington Supreme Court adopted Standards for Indigent Defense Services which mandate the filing of a certification of compliance with the courts by public defenders practicing in adult criminal and juvenile offender case types.

Summary: Public defenders practicing in adult criminal and juvenile offender cases must file a certification of compliance with the courts under the Standards for Indigent Defense Services.

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Applies to

Bond hearing

At a bond hearing, counsel must provide the court with the certification for determination of probable cause, Prosecutor bail request, criminal history, and the Court Services pretrial release interview form.

Summary: Counsel must provide the court with the certification for determination of probable cause, Prosecutor bail request, criminal history, and the Court Services pretrial release interview form at every bond hearing.

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Applies to

Motion for review de novo ?

Must include

caption ?

Should the request for services be denied in whole or in part for any reason, defendant may move for review de novo before the Chief Criminal Judge or Chief MRJC Judge, in accordance with LCrR 3.1. Such a motion shall be in writing, and shall include a declaration of indigency; appointment of counsel does not establish indigency per se. The motion shall also include all documents that were presented to DPD and a copy of DPD's denial and documents regarding indigency.

Summary: A written motion for review of a DPD denial of services must include a declaration of indigency, all documents presented to DPD, and a copy of DPD's denial and indigency documents.

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Applies to

Order authorizing expert services

Must include

proposed order ?

Trial judges can authorize expert services during a trial up to a maximum of $250 per individual expert. Authorization for these services will be granted only if the urgency of the request is demonstrated. The judge's order authorizing expert services at public expense must be submitted to DPD

Summary: Trial judges may authorize expert services up to $250 per expert only upon demonstrated urgency, and the authorizing order must be submitted to DPD.

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Applies to

Proposed order to seal

When submitting a proposed order sealing documents, counsel must assure that the name of the document contained in the proposed order to seal and a proposed protective order, if any, must exactly match the name of the document in the caption and the date submitted; the clerk will not seal a document without an exact matching title; the document will be filed unsealed.

Summary: The document name in the proposed order to seal must exactly match the document name in the caption and the date submitted, or the clerk will not seal the document and it will be filed unsealed.

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Applies to

Proposed order to seal

The date of the proposed order to seal will have two dates: submitted date and date OPD signs it. The submitted date for the order must be on the order to seal. Failure to do so may result in the clerk not sealing the documents in spite of an order to seal.

Summary: The proposed order to seal must bear the submitted date; omission may result in the clerk not sealing the documents despite an order to seal.

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Applies to

Request for services at public expense ?

When retained counsel seeks appointment of expert services at public expense, the request to DPD shall be accompanied by the retainer agreement between counsel and defendant or between counsel and any party to the agreement, and a sworn declaration setting forth defendant’s assets, income and liabilities.

Summary: A retained counsel's request for expert services at public expense must be accompanied by the retainer agreement and a sworn declaration of the defendant's assets, income and liabilities.

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Applies to

Waiver of appearance ?

For pre-trial omnibus hearings, the defendant must either appear in-person, remotely, or through counsel. To appear through counsel, counsel must provide a waiver signed by the Defendant or counsel must affirm that the Defendant prefers to appear through counsel.

Summary: At pre-trial omnibus hearings the defendant must appear in person, remotely, or through counsel, and to appear through counsel counsel must provide a signed waiver or affirm the defendant's preference to appear through counsel.

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Applies to

Omnibus hearing ?

Counsel will certify, on the record, that the trial date will be met and that no foreseeable issues will result in future requests for a continuance of the trial date.

Summary: Counsel must certify on the record at the Omnibus Hearing that the trial date will be met and that no foreseeable issues will lead to future continuance requests.

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Applies to

Order on omnibus hearing

At the conclusion of the Omnibus Hearing, an Order on Omnibus Hearing shall be entered memorializing the agreements of counsel and the rulings of the court.

Summary: An Order on Omnibus Hearing must be entered at the conclusion of the Omnibus Hearing memorializing counsel's agreements and the court's rulings.

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Applies to

Order on omnibus hearing ?

The Omnibus Hearing Order shall be in substantially the same form as specified in CrR 4.5(h). The order shall be signed by the court.

Summary: The Omnibus Hearing Order must substantially follow the form specified in CrR 4.5(h) and must be signed by the court.

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Applies to

Expedited motion scheduling request ?

Must include

case number ?

The following information is needed to set an expedited motion: • The case name • Cause number • Prosecutor and defense attorneys' names • The type of motion

Summary: To set an expedited motion, the party must provide the case name, cause number, prosecutor and defense attorneys' names, and the type of motion.

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Applies to

Note for criminal motion

The moving party must file a Note for Criminal Motion and must provide notice to opposing counsel.

Summary: The moving party must file a Note for Criminal Motion to set a criminal motion.

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Applies to

Criminal motion scheduling request ?

Must include

case number ?

The following information is needed to set a criminal motion: • The case name • Cause number • Prosecutor and defense attorneys’ names • Custody status • Trial date • Expiration date • The Uniform Control Number (UCN) if defendant is in custody • Type and length of motion

Summary: To set a criminal motion, the party must provide the case name, cause number, prosecutor and defense attorneys' names, custody status, trial date, expiration date, UCN (if defendant is in custody), and the type and length of the motion.

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Applies to

Plea scheduling email ?

Your scheduling email should include: • Defendant’s name • Case number • Charges Defendant is pleading to • Charges being dismissed, if any • If the plea is a credit for time served (CFTS) resolution • If the plea is a Barr/Zhao or Alford plea • At least three dates and times (9:00 AM or 1:00 PM) that the attorney is available

Summary: Plea scheduling emails must include the defendant's name, case number, charges pleaded to and dismissed, CFTS/Barr/Zhao/Alford status, and at least three available dates/times (9:00 AM or 1:00 PM).

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Applies to

Plea paperwork

Prior to receiving a plea date, counsel must affirm that they have reviewed plea paperwork with their client via e-mail confirmation to the plea coordinator.

Summary: Counsel must email the plea coordinator confirming client review of plea paperwork before receiving a plea date.

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Applies to

Agreed certificate of trial readiness ?

The Certificate of Trial Readiness should be completed and signed by the parties, filed with the clerk's office and copy provided to the Criminal Department Supervisor of the respective courthouse of the case's designation. Readiness should be submitted to the court no later than the close of business one week prior to the date the case is scheduled for trial.

Summary: Agreed Certificate of Trial Readiness must be signed by the parties, filed with the clerk, copied to the Criminal Department Supervisor, and submitted no later than close of business one week before trial.

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Applies to

Motion for pre assignment ?

The Chief Criminal Judge and Chief MRJC Judge may pre-assign a case to a judge for pretrial management and/or for trial, on motion by a party (written motion and declaration) or on the court's own motion.

Summary: A party seeking pre-assignment of a case must do so by written motion accompanied by a declaration (the court may also pre-assign on its own motion).

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Applies to

Findings of fact and conclusions of law

Prepare Findings of Fact and Conclusions of Law supporting the exceptional sentence and submit them to the sentencing judge and opposing counsel with the pre-sentence report;

Summary: Counsel moving for an exceptional sentence must prepare Findings of Fact and Conclusions of Law and submit them to the sentencing judge and opposing counsel with the pre-sentence report.

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Applies to

Material witness certificate ?

It shall state the facts upon which the certificate is based and specify the number of days the witness will be required to attend.

Summary: An out-of-state witness certificate must state the facts on which it is based and specify the number of days the witness will be required to attend.

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Applies to

Criminal department manual

Pro se defendants shall receive a copy of the Criminal Department Manual.

Summary: Pro se defendants must be given a copy of the Criminal Department Manual.

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Applies to

Motion

All motions, including stipulated motions, must be noted pursuant to LCR 7(b) and filed with the clerk.

Summary: All civil motions, including stipulated motions, must be noted pursuant to LCR 7(b) and filed with the clerk.

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Applies to

Criminal motion response ?

Responses are required on all criminal motions and should be submitted in accordance with LCR 7(b).

Summary: Responses are mandatory on all criminal motions and must be submitted in accordance with LCR 7(b).

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Applies to

Presentence report

Per LCrR 7.1 Presentence reports are required on all felony cases and requested on all misdemeanors. Please submit your presentence reports to the Court and file them.

Summary: Presentence reports are required in all felony cases and requested in misdemeanors, and must be submitted to the Court and filed.

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Applies to

Motion

Must include

proposed order

All motions should be submitted with a proposed order in Word format to the Court by emailing them to the bailiff at port.court@kingcounty.gov.

Summary: All non-dispositive civil motions must be submitted with a proposed order in Word format.

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Applies to

Working copy ?

Must include

judge name ?

Working copies should have the judge's name and the date and time of the hearing in the upper right-hand corner of the first page of the motion.

Summary: Working copies must show the judge's name and the date and time of the hearing in the upper right-hand corner of the first page of the motion.

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Applies to

Working copy ?

Must include

proposed order

All working copies should also include a proposed order(s) in Word format; the Court will accept proposed order(s) in Word format via email with all parties copied on that email and appreciates updated versions of the proposed order that take into account all documentation filed regarding the pending motion.

Summary: Working copies must include a proposed order in Word format, which may be emailed with all parties copied and should reflect all documentation filed on the pending motion.

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Applies to

Deposition

Depositions are not to be marked as an exhibit since they become part of the court file. Originals should be sealed and published in open court in front of the jury, and when they are used for impeachment of testimony (the clerk opening the original that is sealed), the original deposition will be filed in the case file and not treated as an exhibit. Depositions that are not used (a.k.a. "published") are not filed and returned to counsel. Exhibits to the deposition may be marked as exhibits in evidence.

Summary: Depositions must not be marked as exhibits; originals are sealed, published in open court, and filed in the case file, while unused depositions are returned to counsel.

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Applies to

Proposed order

Must include

proposed order

Parties must submit a Word version of all proposed orders. You may submit your proposed order via the e-filing portal by using the e-working copies application, or by email to wilson.court@kingcounty.gov.

Summary: A Word version of all proposed orders is required and may be submitted via the e-filing portal/e-working copies application or by email to wilson.court@kingcounty.gov.

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Applies to

Oral argument scheduling email ?

Must include

case number ?

Include the case name, number, and name of opposing counsel, and any deadlines that may be approaching if time sensitive and applicable.

Summary: Oral argument scheduling emails must include the case name, case number, opposing counsel's name, and any approaching deadlines if time sensitive and applicable.

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Applies to

Working copy ?

Must include

judge name ?

Please make sure Judge Vargas' name and the case information is clearly marked.

Summary: Criminal working copies must be clearly marked with Judge Vargas' name and the case information.

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Applies to

Motion response ?

Responses are required on all motions and should be submitted in accordance with LCR 7(b).

Summary: Responses are required on all criminal motions and must be submitted in accordance with LCR 7(b).

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Applies to

Dispositive motion hearing request ?

Must include

caption, case number ?

Any request for a dispositive motion hearing must be emailed to the court and include at minimum: Case number and caption in the subject line; Names, phone numbers and email addresses of all counsel and parties; Nature of motion

Summary: Email requests for a dispositive motion hearing must include the case number and caption in the subject line, the names, phone numbers, and email addresses of all counsel and parties, and the nature of the motion.

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Applies to

Working copy ?

Note: Most non-dispositive motions do not require oral argument under the Civil or Local Rules. If a party would like to request oral argument, the motion should be noted pursuant to the applicable court rules, and you may request argument by simply noting in the upper right-hand corner of the working papers "Oral Argument Requested."

Summary: A party may request oral argument on a non-dispositive motion by noting "Oral Argument Requested" in the upper right-hand corner of the working papers.

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Applies to

Motion

Must include

proposed order

Parties must comply with all the requirements of KCLR 7 and any emergency orders in place when setting motions without oral argument. All motions should be submitted with proposed orders in Word format, submitted via eWorking Copies.

Summary: Non-dispositive motions must comply with KCLR 7 and any emergency orders and must be submitted with proposed orders in Word format via eWorking Copies.

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Applies to

Motion

All motions must be noted pursuant to LCR 7(b) and filed with the clerk.

Summary: All civil motions must be noted pursuant to LCR 7(b) and filed with the clerk.

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Applies to

Working copy ?

Must include

judge name ?

Working copies should have the judge's name and the date and time of the hearing in the upper right-hand corner of the first page of the motion.

Summary: Working copies must show the judge's name and the hearing date and time in the upper right-hand corner of the first page of the motion.

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Applies to

Working copy ?

Must include

proposed order

All working copies shall also include a proposed order(s) in Word format.

Summary: All working copies must include a proposed order in Word format.

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Applies to

Continuance motion ?

Follow the requirements of LCR 7. Do not send a stipulation and order to Judge Vargas' bailiff. If the parties agree on the request for a continuance, the moving party or parties should describe the motion as an "agreed motion" or a "stipulated motion" in the caption and set forth that agreement in the body.

Summary: Stipulations and orders may not be sent to Judge Vargas' bailiff; agreed continuances must be captioned as an "agreed motion" or "stipulated motion" with the agreement set forth in the body.

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Applies to

Witness examination time form

In addition, Judge Vargas requires all parties and counsel to work together to complete the Witness Examination Time Form (188KB), and that form must be submitted together with other pretrial memoranda five court days prior to trial.

Summary: All parties and counsel must jointly complete the Witness Examination Time Form and submit it with the pretrial memoranda five court days before trial.

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Applies to

Deposition designations ?

If the parties intend to use depositions in trial, designations and objections shall be marked according to the guidelines provided here.

Summary: Deposition designations and objections intended for use at trial must be marked according to the court's provided guidelines.

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Applies to

Response to criminal motion ?

Responses are required on all criminal motions and must be submitted in compliance with KCLR 7(b).

Summary: Responses are mandatory on all criminal motions and must comply with KCLR 7(b).

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Applies to

Presentence report

Under Local Criminal Rule (LCrR) 7.1, presentence reports are required in all felony cases and requested in all misdemeanor cases. Please submit your presentence report to the Court and file it with the Clerk.

Summary: Presentence reports are required in all felony cases and requested in all misdemeanor cases, and must be submitted to the Court and filed with the Clerk.

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Applies to

Motion

Must include

proposed order

For every motion, both sides must submit a proposed order. Each proposed order must be completed as you would like it signed by the judge.

Summary: Every motion must be accompanied by a proposed order from both sides, each completed as the party wants it signed.

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Applies to

Working papers

If you wish to request oral argument on a particular motion, note and file the motion according to the applicable court rules and write “Oral Argument Requested” in the upper right-hand corner of the first page of the working papers.

Summary: To request oral argument, the words 'Oral Argument Requested' must be written in the upper right-hand corner of the first page of the working papers.

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Criminal cases

Applies to

Witness list

On the first day of trial, the parties must provide a current witness list to the bailiff so it can be incorporated into the juror questionnaire.

Summary: Parties must provide a current witness list to the bailiff on the first day of trial for incorporation into the juror questionnaire.

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Criminal cases

Applies to

Voir dire questions

On the first day of trial, the parties must provide any additional general voir dire questions they wish to have included in the questionnaire on the first day of trial.

Summary: Parties must submit any additional general voir dire questions they want included in the juror questionnaire on the first day of trial.

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Applies to

Non dispositive motion ?

Parties must comply with all the requirements of KCLR 7 when setting motions without oral argument.

Summary: Parties must comply with all requirements of KCLR 7 when setting non-dispositive motions without oral argument.

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Applies to

Non dispositive motion

All non-dispositive motions will be considered by the Court without oral argument unless a party requests oral argument and the Court deems oral argument to be necessary. If you wish to request oral argument, please so indicate on the front page of your motion or opposition.

Summary: Non-dispositive motions are decided without oral argument unless a request is made and granted, and any request for oral argument must be indicated on the front page of the motion or opposition.

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Applies to

Email request for dispositive motion hearing ?

Must include

case number ?

Any email request for a dispositive motion hearing must include: Case name and cause number; Names, phone numbers and email addresses of all counsel; Type of hearing and dates requested

Summary: Email requests for a dispositive motion hearing must include the case name and cause number, counsel contact information, and the type of hearing and dates requested.

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Applies to

Proposed jury instructions

E-mail a set of cited and un-cited proposed jury instructions in Word format to the court's bailiff.

Summary: Proposed jury instructions (cited and un-cited) must be emailed to the court's bailiff in Word format.

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Applies to

Proposed jury instructions ?

File a set of cited proposed instructions with the court clerk.

Summary: A set of cited proposed jury instructions must be filed with the court clerk.

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Applies to

Exhibits

Please bring sufficient copies of your exhibits to trial. You must have a complete set for the court clerk to mark as the official set of trial exhibits and complete set for the court to use as working copies. Do not ask the staff to make copies of your trial exhibits.

Summary: Parties must bring complete sets of trial exhibits for the clerk and the court, and may not ask staff to make copies.

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Applies to

Motion

Parties must comply with all the requirements of LCR 7(b)(4)(A) when setting motions without oral argument.

Summary: When setting motions without oral argument, parties must comply with all requirements of LCR 7(b)(4)(A).

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Applies to

Note for hearing ?

Parties must note all hearings for motions, including stipulated motions, pursuant to LCR 7(b)(4).

Summary: All motions, including stipulated motions, must be noted for hearing pursuant to LCR 7(b)(4).

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Applies to

Hearing request email ?

Must include

case number ?

Any email request for a dispositive motion hearing must include Case name and cause number Names, phone numbers, and email addresses of all counsel Type of hearing and dates requested

Summary: Email requests for dispositive motion hearings must include the case name and cause number, all counsel's names, phone numbers, and email addresses, and the type of hearing and dates requested.

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Applies to

Non dispositive motion ?

Parties must comply with all the requirements of KCLR 7 when setting motions without oral argument.

Summary: Parties must satisfy all King County Local Rule 7 requirements when setting non-dispositive motions without oral argument.

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Applies to

Motion or opposition

All non-dispositive motions will be considered by the Court without oral argument unless a party requests oral argument and the Court deems oral argument to be necessary. If you wish to request oral argument, please so indicate on the front page of your motion or opposition.

Summary: Non-dispositive motions are decided without oral argument unless a party requests oral argument by indicating the request on the front page of the motion or opposition and the Court deems oral argument necessary.

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Applies to

Email hearing request ?

Must include

case number ?

Any email request for a dispositive motion hearing must include Case name and cause number Names and email addresses of all parties Type of hearing and dates requested

Summary: An email request for a dispositive motion hearing must include the case name and cause number, the names and email addresses of all parties, and the type of hearing and dates requested.

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Applies to

Motion without oral argument

Parties must comply with all the requirements of KCLR 7 when setting motions without oral argument.

Summary: Parties must comply with all KCLR 7 requirements when setting motions without oral argument.

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Applies to

Working copy ?

Must include

proposed order

All working copies should also include proposed orders from each party in Word format.

Summary: Working copies must include proposed orders from each party in Word format.

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Applies to

Estimate of witness examination

The Estimate of Witness Examination (13KB) is required in any trial expected to last longer than 10 trial days.

Summary: An Estimate of Witness Examination must be filed for any trial expected to last longer than 10 trial days.

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Applies to

Witness examination estimate ?

Submission of the following information is required by Judge Ferguson, not later than 10 court days before trial, in every case expected to last more than 4 days.

Summary: In every case expected to last more than 4 days, the witness examination estimate (witness names and direct/cross/re-direct examination time estimates) must be submitted to Judge Ferguson no later than 10 court days before trial.

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Applies to

Witness examination estimate ?

Counsel are to confer not later than ten calendar days prior to the trial date to determine estimations for cross-examination time for each party's witnesses and prepare this document.

Summary: Counsel must confer no later than ten calendar days before trial to determine cross-examination time estimates for each party's witnesses and prepare the witness examination estimate.

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Applies to

Witness examination time form

In civil cases, Judge Lapin requires all parties and counsel to work together to complete the Witness Examination Time Form, and that form must be submitted together with other pre-trial memoranda 14 court days prior to trial.

Summary: In civil cases, all parties and counsel must work together to complete the Witness Examination Time Form.

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Civil cases

Applies to

Motion to continue trial ?

The motion should be accompanied by a declaration as to the nature of the case, the discovery and trial preparation that have been completed, what remains to be accomplished, and an explanation of why the case could not be completed within the original case schedule.

Summary: A motion to continue trial must be accompanied by a declaration describing the nature of the case, completed discovery and trial preparation, remaining work, and why the case could not be completed within the original case schedule.

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Applies to

Motion

If a party would like to request oral argument, the motion should be noted pursuant to the applicable court rules, noting in the upper right-hand corner of the working papers and on the note for motion “Oral Argument Requested.”

Summary: Oral argument requests must be noted in the upper right-hand corner of the working papers and on the note for motion.

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Applies to

Jury instructions

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.

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Applies to

Jury instructions ?

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.

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Applies to

Deposition designation chart

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.

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Applies to

Deposition objections ?

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.

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Applies to

Marked deposition ?

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.

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Applies to

Court materials ?

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.

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Applies to

Proposed order

Must include

proposed order

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.

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Applies to

Motion for order to show cause

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.

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Applies to

Motion for revision

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.

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Applies to

Proposed order

Must include

proposed order

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.

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Applies to

Working copies

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.

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Applies to

Motion to compel discovery ?

Must include

certificate of conference ?

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.

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Applies to

Presentence report

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.

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Applies to

Motion for exceptional sentence

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.

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Applies to

Pretrial materials

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.

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Applies to

Response to motion ?

Responses are required on all motions and should be submitted in accordance with LCR 7(b).

Summary: Responses are required on all criminal motions and must be submitted per LCR 7(b).

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Applies to

Working copy ?

Must include

judge name, case number ?

Please make sure Judge Scott's name and the case information is clearly marked.

Summary: Criminal working copies must be clearly marked with Judge Scott's name and the case information.

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Applies to

Motion

Must include

proposed order

All motions should be submitted with proposed orders in Word format, submitted via eWorking Copies.

Summary: All civil motions must be submitted with proposed orders in Word format via eWorking Copies.

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Applies to

Working copy ?

Must include

proposed order

All working copies shall also include a proposed order(s) in Word format.

Summary: All working copies must include a proposed order in Word format.

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Applies to

Witness examination time form

In addition, Judge Scott requires all parties and counsel to work together to complete the Witness Examination Time Form (188KB), and that form must be submitted together with other pretrial memoranda five court days prior to trial.

Summary: All parties and counsel must jointly complete the Witness Examination Time Form and submit it with the pretrial memoranda five court days before trial.

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Applies to

Motion ?

Must include

proposed order

Please provide a copy of the proposed order in Word format by emailing them to the bailiff.

Summary: A proposed order must be provided in Word format and emailed to the bailiff for non-dispositive motions.

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Applies to

Settlement memorandum ?

All parties must provide a brief 3 to 5 pages typewritten memorandum or letter at least 5 court days prior to the settlement conference. This should outline the factual background, any prior negotiations and positions taken on the outstanding issues between the parties, and any other relevant information. Please include your proposal for settlement.

Summary: Parties must submit a settlement memorandum or letter at least 5 court days before the settlement conference outlining the factual background, prior negotiations, positions on outstanding issues, other relevant information, and their settlement proposal.

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Applies to

Motion opposition reply brief ?

All motions, oppositions, replies, and briefs shall cite to these page numbers. A party may include other citation information, such as exhibit numbers, corresponding exhibit pages or paragraph numbers, in addition to the consecutive page cite.

Summary: Motions, oppositions, replies, and briefs must cite to the consecutive attachment page numbers (other citation information may be added in addition).

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Applies to

Discovery motion ?

Must include

certificate of conference ?

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: A certification of the meet-and-confer conference, setting out with particularity its nature, extent, and time, is required with the motion.

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Applies to

Working papers

If a party would like to request oral argument, the motion should be noted pursuant to the applicable court rules, simply noting in the upper right-hand corner of the working papers “Oral Argument Requested.”

Summary: To request oral argument on a non-dispositive motion, a party must note 'Oral Argument Requested' in the upper right-hand corner of the working papers.

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Applies to

Motion to seal ?

Must include

proposed order

The moving party shall provide a proposed order that includes the required findings.

Summary: The moving party on a motion to seal must submit a proposed order containing the required findings.

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Applies to

Estimate of witness examinations ?

Submission of the following information is required by Judge Straley, in every case.

Summary: Judge Straley requires submission of the witness examination estimate information in every case.

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Applies to

Dispositive motion hearing request email ?

Must include

case number ?

Any email request for a dispositive motion hearing must include the following: Case name and cause number; Nature of the motion(s) to be heard; and A preferred date range.

Summary: An email request for a dispositive motion hearing must include the case name and cause number, the nature of the motion(s) to be heard, and a preferred date range.

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Applies to

Motion or brief ?

You must cite to these page numbers in all motions, oppositions, replies, and briefs. A party may include other citation information, such as exhibit numbers, corresponding exhibit pages or paragraph numbers, in addition to the consecutive page cite.

Summary: Motions, oppositions, replies, and briefs must cite to the consecutive attachment page numbers, though exhibit numbers, exhibit pages, or paragraph numbers may be added.

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Civil cases

Applies to

Witness time estimates ?

Submission of the this form is required by Judge Crisalli.

Summary: Submission of the witness time estimates form is mandatory in cases before Judge Crisalli.

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Applies to

Motion

Working Papers are required for all motions.

Summary: Working Papers must be submitted with every motion.

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Applies to

Dispositive motion hearing request ?

Must include

caption, case number ?

Any request for a dispositive motion hearing must be emailed to the court with all parties cc'd and include at minimum: Case number and caption in the subject line; Nature of motion; Type of hearing and date(s) requested

Summary: A dispositive motion hearing request must include the case number and caption in the subject line, the nature of the motion, and the type of hearing and date(s) requested.

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Applies to

Motion or opposition

Only summary judgment motions are entitled to oral argument. If you want oral argument on a motion other than a summary judgment motion, please note the motion without oral argument. State "ORAL ARGUMENT REQUESTED" on the first page of your motion or opposition.

Summary: Non-summary-judgment motions are noted without oral argument; to request oral argument, the words "ORAL ARGUMENT REQUESTED" must appear on the first page of the motion or opposition.

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Civil cases

Applies to

Witness examination time form

In civil cases, Judge Parisien requires all parties and counsel to work together to complete the Witness Examination Time Form, and that form must be submitted together with other pretrial memoranda five court days prior to trial.

Summary: In civil cases, all parties and counsel must jointly complete the Witness Examination Time Form and submit it with the pretrial memoranda five court days before trial.

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Applies to

Written submission

The use of clear, specific citations is of utmost importance in written submissions to the Court. Parties cannot and should not rely on the Court to pore over the record to confirm their assertions. Instead, any disputed, material assertions should be supported with a particularized citation to supporting materials. This should include a specific page number, section, or paragraph for each citation. References to prior filings should be supported with particularized citation to the docket (referenced as "Dkt.," "Sub No.," or equivalent) that indicates the specific docket number and specific page (e.g., "Dkt. 1 at 22"). Any disputed or distinctive legal propositions should be supported with citation to legal authority, including a pincite (page number), and when not already apparent, a parenthetical briefly describing the holding or significance of the cited authority. Legal citations need not include parallel citation to regional reporters or the like; citation to the Washington reporter or the U.S. reporter is sufficient and preferred.

Summary: Written submissions must support disputed material assertions with particularized citations (specific page/section/paragraph), docket citations with specific docket number and page, and legal authority with pincites and parentheticals where needed.

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Applies to

Declaration

Factual declarations submitted in support of motions or other briefing should meet the requirements of General Rule 13 (certification), Local Civil Rule 7(b)(5)(B) (form), and Evidence Rule 701 (lay opinion).

Summary: Factual declarations must comply with General Rule 13 (certification), Local Civil Rule 7(b)(5)(B) (form), and Evidence Rule 701 (lay opinion).

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Applies to

Motion for revision ?

All parties moving for revision of a Commissioner's order will be held to the requirement under Local Rule 7(b)(8)(A) that the motion "shall only identify the error(s) claimed."

Summary: Motions for revision of a Commissioner's order shall only identify the error(s) claimed per Local Rule 7(b)(8)(A).

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Applies to

Motion for revision ?

Consistent with the above standard, and given that revision must be based only on the issues and evidence before the Commissioner, the motion should only: (1) provide the hearing information required by LCR 7(b)(8)(B)(iii); (2) identify the error(s) claimed; (3) specify where exactly in the record the issue was argued below; and (4) specify all evidence in the record relevant to the issue (whether in support or opposition). The Court will then determine whether or not to call for supplemental briefing or argument.

Summary: Revision motions are limited to four elements: LCR 7(b)(8)(B)(iii) hearing information, the errors claimed, where the issue was argued below, and all relevant record evidence.

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Applies to

Motion for revision ?

The motion should NOT present further argument or factual assertions, which generally will be disregarded. The opposing party need not submit a motion to strike such extraneous information and is urged not to do so; such a motion itself will likely be struck as moot.

Summary: Revision motions must not present further argument or factual assertions (which will be disregarded), and motions to strike such extraneous material will likely be struck as moot.

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Applies to

Request for attorney fees

Any request for attorney fees must specify the legal grounds for the requested award, and usually should be accompanied by a fee declaration explaining counsel's relevant experience and rates, with a log of time entries indicating tasks performed and time spent on each. The fee declaration should also indicate whether or not the time entries were created contemporaneously, and whether or not the entries have actually been or will be paid.

Summary: Attorney fee requests must specify the legal grounds and should include a fee declaration with counsel's experience and rates, a time-entry log, and whether entries were contemporaneous and paid.

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Applies to

Discovery motion ?

Must include

certificate of conference ?

Parties must pay careful attention to the "meet and confer" requirement of Civil Rule 26(i). The conference must consist of contemporaneous communication, whether in-person, virtual, or by telephone. Email is not a substitute for a dialogue on disputed issues. A certification by counsel that the conference requirement has been met is required, and should set out with particularity the time, nature, and extent of the conference.

Summary: Discovery motions require a certification that the CR 26(i) meet-and-confer conference occurred, detailing its time, nature, and extent; the conference must be contemporaneous communication and email alone does not suffice.

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Applies to

Hearing request email ?

Any email request for a dispositive motion hearing must include the following: Case name and cause number Names, phone numbers and email addresses of all counsel Type of hearing and date(s) requested from the available dates on the above calendar

Summary: Email requests for a dispositive motion hearing must include the case name and cause number, counsel names with phone numbers and email addresses, and the hearing type with requested date(s).

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Applies to

Daily witness disclosure ?

The Court requires all counsel and parties to be prepared at the end of each day to disclose all witnesses that party is intending to call the following day in trial.

Summary: At the end of each trial day, all counsel and parties must be prepared to disclose all witnesses they intend to call the following day.

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Applies to

Motion

Per KCLCR 7(b)(4)(C), if a party would like to request oral argument for a matter typically handled without oral argument, the motion should be noted pursuant to the applicable court rules and paperwork should include in the upper right-hand corner "Oral Argument Requested." If, after reviewing all briefing, the Court determines oral argument is appropriate, the Bailiff will contact the parties and set a mutually acceptable time for oral argument.

Summary: To request oral argument on a matter typically decided without argument, the motion paperwork must include "Oral Argument Requested" in the upper right-hand corner, and if the Court finds argument appropriate the Bailiff will contact the parties to set a mutually acceptable time.

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Applies to

Estimate of witness examinations ?

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 and the completed form must be totaled.

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Applies to

Estimate of witness examinations ?

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 form.

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Applies to

Estimate of witness examinations ?

If there are additional parties, each party should create and complete the required information for that party's witnesses.

Summary: In cases with additional parties, each party must create and complete the witness time information for its own witnesses.

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Applies to

Estimate of witness examinations ?

NOTE: Failure to complete this form and disclose witnesses may result in exclusion of witnesses or other sanctions.

Summary: Failure to complete the form and disclose witnesses may result in exclusion of witnesses or other sanctions.

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Applies to

Bond motion ?

For proper identification of an inmate, the following information is needed to note a bond hearing: • The name of the defendant • The defense attorney's name • The UCN (Uniform Control Number) • The charges • Date of arraignment • Trial date • Current bail amount

Summary: To note a bond hearing, the moving party must provide the defendant's name, defense attorney's name, UCN, charges, arraignment date, trial date, and current bail amount.

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Applies to

Order on omnibus hearing

An agreed Order on Omnibus Hearing may be entered at the Omnibus Hearing if the parties agree that the parties have met, all discovery, including witness interviews, is complete, the information will not be amended, all necessary witnesses are available for trial, and that the parties will be prepared for trial on the assigned date.

Summary: An agreed Omnibus Hearing Order may be entered only if the parties confirm they have met, discovery (including witness interviews) is complete, the information will not be amended, all necessary witnesses are available, and they will be ready for trial on the assigned date.

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Applies to

Plea scheduling email ?

If you would like the next date available, please affirmatively state that the next available date will be accepted (no refusal of the next date) and affirmatively state the defendant will accept the next available date (no subsequent claim of unavailability). Please also continue to include dates that the attorney and defendant is available to allow for ease of scheduling.

Summary: Requests for the next available plea date must affirmatively state the attorney and defendant will accept the next available date with no refusal or later claim of unavailability, and must still include availability dates.

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Applies to

Informational forms

A number of informational forms must be provided to the defendant at sentencing, depending on the sentencing options used:

Summary: Various informational forms must be provided to the defendant at sentencing, depending on the sentencing options used.

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Applies to

Order for chemical dependency screening report ?

Unless specifically waived by the Court, the Court shall order the Department of Corrections to complete a chemical dependency screening report before imposing a sentence upon a defendant who has been convicted of a violation of the uniform controlled substances act under chapter 69.50 RCW, a criminal solicitation to commit such a violation under chapter 9A.28 RCW, or any felony where the court finds that the offender has a chemical dependency that has contributed to his or her offense, RCW 9.94A.500.

Summary: Unless specifically waived by the court, a Department of Corrections chemical dependency screening report must be ordered before sentencing for controlled substance violations, criminal solicitation of such violations, or felonies where chemical dependency contributed to the offense.

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Order for presentence investigation report ?

In addition, the Court shall, at the time of plea or conviction, order the Department of Corrections to complete a Presentence Investigation Report (PSI) before imposing a sentence upon a defendant who has been convicted of a felony sexual offense, RCW 9.94A.500.

Summary: At the time of plea or conviction, the court must order a Department of Corrections Presentence Investigation Report before sentencing a defendant convicted of a felony sexual offense.

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Motion

Parties must comply with all the requirements of KCLR 7 and the most recent emergency orders in place because of COVID when setting motions without oral argument.

Summary: Parties setting non-dispositive civil motions without oral argument must comply with KCLR 7 and the most recent COVID emergency orders.

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Applies to

Exhibits

Please comply with LCR 7(b)(5)(B)(iv) which provides: “Parties should highlight those parts [of the exhibits] upon which they place substantial reliance.”

Summary: Parties must highlight the parts of exhibits on which they place substantial reliance per LCR 7(b)(5)(B)(iv).

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Proposed findings conclusions ?

The Findings of Fact should be limited to a statement of the essential ultimate facts and Conclusions of Law should be limited to the essential legal conclusions.

Summary: Findings of Fact must be limited to essential ultimate facts and Conclusions of Law to essential legal conclusions.

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Objections to proposed findings conclusions ?

Objections to proposed Findings and Conclusions should be presented to the court in writing following the conclusion of the trial.

Summary: Objections to proposed Findings and Conclusions must be presented to the court in writing after the trial concludes.

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Civil cases

Applies to

Pretrial conference

At a pretrial conference, the parties should be prepared to address: (1) the parties' readiness for trial; (2) the anticipated length of trial; (3) whether Alternative Dispute Resolution (ADR) has been completed; (4) special scheduling needs, such as the need for interpreters and/or experts;

Summary: At the pretrial conference, parties should be prepared to address trial readiness, anticipated trial length, ADR status, and special scheduling needs such as interpreters or experts.

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Civil cases

Applies to

Working copy ?

Must include

judge name ?

Working copies should have the judge's name and the date and time of the hearing in the upper right-hand corner of the first page of the motion.

Summary: Working copies must show the judge's name and the hearing date and time in the upper right-hand corner of the first page of the motion.

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Civil cases

Applies to

Motion

Most other motions do not require oral argument under the Civil Rules or Local Rules. If a party requests oral argument, the motion should be noted as "Oral Argument Requested."

Summary: Non-dispositive motions generally do not require oral argument; a party requesting oral argument must note the motion as 'Oral Argument Requested.'

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Working copies submission list

Department 40 is a paperless court and Judge Schubert requests that parties file a working copies submission list identifying by Sub. (docket) No. where each filing for the hearing can be found.

Summary: Instead of working copies, parties must file a working copies submission list identifying by docket (Sub.) number where each hearing filing can be found.

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Applies to

Non dispositive motion

Non-dispositive motions will be considered by the Court without oral argument unless requested and the Court agrees oral argument is necessary. To request oral argument, please indicate on the front page of your motion or opposition.

Summary: Non-dispositive motions are decided without oral argument unless a request for argument is indicated on the front page of the motion or opposition.

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Witness examination estimate ?

If there are additional parties, each party should create and complete the required information for that party's witnesses.

Summary: Each additional party should create and complete the required witness examination estimate information for that party's own witnesses.

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Applies to

Motion

If a party would like to request oral argument, the motion should be noted pursuant to the applicable court rules, simply noting in the upper right hand corner "Oral Argument Requested."

Summary: To request oral argument, note the motion with 'Oral Argument Requested' in the upper right-hand corner, and the Court will decide after reviewing all briefing whether to set argument.

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Estimate of witness examinations ?

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.'

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Jury instructions ?

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.

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Deposition designation chart ?

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.

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Applies to

Working copy ?

Must include

judge name ?

Working copies should have the judge's name and the date and time of the hearing in the upper right-hand corner of the first page of the motion.

Summary: Working copies must show the judge's name and the hearing date and time in the upper right-hand corner of the first page of the motion.

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Applies to

Continuance motion ?

If the parties agree on the request for a continuance, the moving party or parties should describe the motion as an "agreed motion" or a "stipulated motion" in the caption and set forth that agreement in the body.

Summary: Agreed continuance requests must be captioned as an "agreed motion" or "stipulated motion" with the agreement set forth in the body.

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Zoom appearance request ?

The request must include an explanation for the need for the virtual connection.

Summary: A Zoom appearance request must include an explanation for the need for the virtual connection.

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Discovery motion ?

In addition to providing the certification, ordinarily, Judge Straley will expect that the moving party provide a copy of all correspondence between the parties relevant to the motion as part of the moving party’s initial filing.

Summary: The movant on a motion to compel discovery should attach all relevant correspondence between the parties to the initial filing.

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Contempt motion ?

Judge Straley will also expect copies of all such correspondence from a party moving for an order of contempt pursuant to CR 45(g).

Summary: A party moving for contempt under CR 45(g) must also provide copies of all relevant correspondence.

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Contempt motion ?

The moving party should also include an explanation of all the efforts that the moving party has undertaken to seek compliance with a subpoena before filing the motion for contempt.

Summary: A contempt motion must explain all efforts undertaken to seek compliance with the subpoena before filing.

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Motion to seal ?

Briefing and proposed orders should fully and clearly include the title of the documents in question.

Summary: Sealing briefing and proposed orders must fully and clearly identify the title of the documents to be sealed.

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Joint confirmation of trial readiness form

In preparation for trial, the parties should submit a joint confirmation of trial readiness form and comply with the case schedule provided by the Clerk's Office and the pretrial order.

Summary: Before trial, parties should submit a joint confirmation of trial readiness form and comply with the case schedule and pretrial order.

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Estimate of witness examinations ?

For estimates, please use 15 minute increments. Note that a typical trial day is 9:00 am to noon, 1:30 pm to 4:00 pm. Both morning and afternoon sessions have a 15 minute break. This results in five (5) hours of trial every day.

Summary: Witness examination time estimates must be given in 15 minute increments, based on a typical trial day of five hours of trial time.

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Estimate of witness examinations ?

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 examination estimate information for that party's own witnesses.

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Pleading

Please note: if your pleadings refer to materials which were previously filed within the court record, please reference the pleading by both the document title and submission number (eg: Declaration of Bob Jones, Sub. 5) within the court docket.

Summary: Pleadings referring to previously filed materials must reference the pleading by both document title and submission number within the court docket.

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Electronic working copy ?

Must include

judge name ?

Please put in the upper right corner of the working copies the note date of consideration or hearing, Judge Crisalli’s name, and by whom the documents are being presented (“moving party,” “opposing party,” or other descriptive or identifying term).

Summary: Working copies must show in the upper right corner the note date of consideration or hearing, Judge Crisalli's name, and by whom the documents are being presented.

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Motion or opposition

If you wish to have oral argument on a non-dispositive motion, please note the motion without oral argument and note "ORAL ARGUMENT REQUESTED" on the first page of your motion or opposition.

Summary: A party wanting oral argument on a non-dispositive motion must note the motion without oral argument and write 'ORAL ARGUMENT REQUESTED' on the first page of the motion or opposition.

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Discovery dispute email ?

The email should—as succinctly and non-argumentatively as possible—describe the nature of the dispute and the positions of the parties. You must copy all parties on any email to the Court.

Summary: A discovery dispute email must succinctly and non-argumentatively describe the nature of the dispute and the parties' positions, and all parties must be copied on any email to the Court.

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Civil cases

Applies to

Witness time estimates ?

Counsel are to confer prior to the pretrial conference to determine time estimations for witness testimony and to prepare this document.

Summary: Counsel must confer with each other before the pretrial conference to agree on witness time estimates and prepare the form.

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Civil cases

Applies to

Witness time estimates ?

If there are additional parties, complete the information for that party's witnesses on an additional page.

Summary: For additional parties, witness time estimate information must be completed on an additional page.

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Civil cases

Applies to

Witness time estimates ?

Use tenths of an hour for estimates, i.e., .1, .2, .5, 1.0, etc.

Summary: Witness time estimates must be expressed in tenths of an hour (e.g., .1, .2, .5, 1.0).

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Civil cases

Applies to

Witness time estimates ?

Must include

case number ?

PETITIONER(S) Witness Name: Time Direct Exam: Time for Cross-Exam: Time for Re-Direct Exam: Total Time per Witness: Total time for Petitioner: RESPONDENT(S) Witness Name: Time for Direct Exam: Time for Cross-Exam: Time for Re-Direct Exam: Total Time per Witness: Total time for Respondent:

Summary: The form must list, separately for petitioner(s) and respondent(s), each witness's name and time estimates for direct, cross, and re-direct examination, plus totals per witness and per party.

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Working copy ?

Must include

judge name ?

Working copies should have the judge's name and the date and time of the hearing in the upper right-hand corner of the first page of the motion.

Summary: Working copies must show the judge's name and the hearing date and time in the upper right-hand corner of the first page of the motion.

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Civil cases

Applies to

Motion

If a party would like to request oral argument, the motion should be noted pursuant to the applicable court rules, simply noting in the upper right-hand corner "Oral Argument Requested."

Summary: A party requesting oral argument must note "Oral Argument Requested" in the upper right-hand corner of the motion.

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Motion

Any special relief from the Court—whether in discovery or otherwise—should be sought timely via written motion with supporting materials.

Summary: Unrepresented parties must seek any special relief from the Court timely via written motion with supporting materials.

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Written submission

To promote clarity and ease of comprehension in briefing, declarations, and other written submissions, Parties and other persons should be regularly referred to by individualized name or other unique identifier rather than only generic role (e.g., "Plaintiff Smith" rather than just "Plaintiff"). Reference by first name may be necessary where the Parties share last name; this will not be taken as a sign of disrespect and no disclaimer to that effect is needed. Any person's disclosed or otherwise known personal pronouns should be respected.

Summary: Written submissions should refer to parties and other persons by individualized names or unique identifiers rather than only generic roles.

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Declaration

To promote clarity and compliance with attestation requirements, factual declarations should NOT be combined with legal argument. Instead, whatever a witness is attesting to must be set forth separately and distinctly. Legal argument should then cite (with particularity) to the attested facts in support.

Summary: Factual declarations must not be combined with legal argument; attestations must be set forth separately and legal argument must cite the attested facts with particularity.

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Motion for revision ?

For the purpose of identifying the error(s) claimed, which is subject to de novo review, the moving party should present a single, separate concise statement for each error akin to an assignment of error on appeal. Each statement should be no more than a few sentences long.

Summary: Each claimed error must be presented as a single, separate concise statement (no more than a few sentences), akin to an assignment of error on appeal.

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Motion for revision ?

Citations to the record should specify the specific docket number and page range for each portion of relevant argument or evidence (e.g., "Dkt. 12 at 15-17"), and nothing more.

Summary: Record citations in revision motions must specify the specific docket number and page range for each portion of argument or evidence, and nothing more.

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Stipulated motion ?

Must include

proposed order

To maintain a clear and appropriate record, the motion itself should be filed separately into the docket, and the Parties' proposed order should be presented separately to this Department for review. The proposed orders should comply with the standards set forth above for such submissions.

Summary: Stipulated motions must be filed separately into the docket with the proposed order presented separately to the Department for review.

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Proposed order

Parties should submit proposed orders via Working Copies that make clear precisely what the Party is asking the Court to do.

Summary: Proposed orders must be submitted via Working Copies and make clear precisely what the party is asking the Court to do.

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Post sentencing relief motion ?

Must include

proposed order

Counsel for any party seeking post-sentencing relief should file a Notice of Appearance and any motion papers and submit proposed orders via Working Copies. Whenever possible, the proposed order should be submitted in editable Word (.doc) format, with the proponent's signature included in electronic format—whether a digitally certified signature, "s/" signature, or electronic image of the person's signature. See General Rule 30; RCW 1.80.010(10). For joint motions or stipulated orders, signatures from each and every proponent should be included.

Summary: Post-sentencing relief requires a Notice of Appearance, motion papers, and proposed orders via Working Copies in editable Word format with electronic signatures from all proponents.

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Motion in limine

If the Parties are aware of any significant legal determinations that will need to be made at Trial (rather than leading up to the Pretrial Conference), they should raise those issues through Motions in Limine. This should take the form of a single written submission noted for consideration on the Trial Date and timely prepared, filed, served, and answered in accordance with the requirements of Local Civil Rule 7. Issues raised in this manner usually will be addressed and resolved at the outset of Trial.

Summary: Significant trial determinations should be raised through a single motion in limine submission noted for the Trial Date and handled per Local Civil Rule 7.

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Motion

If you wish to request oral argument, please so indicate on the front page of your motion or opposition.

Summary: A request for oral argument must be indicated on the front page of the motion or opposition.

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Estimate of witness examinations ?

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 should assume 5 hours per full trial day and account for witness examinations, jury questions, opening and closing arguments, voir dire, and motions in limine.

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Applies to

Estimate of witness examinations ?

You may use this form, or create one of your own, as long as it includes the requested information.

Summary: Parties may use the provided form or create their own, provided it includes all requested information.

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Applies to

Working papers submission list

Must include

caption, case number ?

It is often helpful if parties jointly provide a working papers submission list to the judge before the noting date. This list should contain all the pleadings related to the motion, their caption, the docket number and date filed. If your pleadings refer to materials which were previously filed within the court record, please reference the pleading by both the document title and sub number (eg: Declaration of Bob Jones, Sub #5) within the court docket.

Summary: Parties are encouraged to jointly provide a working papers submission list before the noting date listing all related pleadings with captions, docket numbers, filing dates, and title-and-sub-number citations for previously filed materials.

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Applies to

Working papers

Most motions do not require oral argument under the Civil or Local Rules. If a party would like to request oral argument, the motion should be noted pursuant to the applicable court rules, simply noting in the upper right-hand corner of the working papers “Oral Argument Requested.” If, after reviewing all briefing, the Court determines oral argument is appropriate, the bailiff will contact the parties and set a mutually acceptable time for oral argument.

Summary: To request oral argument on a non-dispositive motion, a party must note "Oral Argument Requested" in the upper right-hand corner of the working papers, and if the Court agrees, the bailiff will contact the parties to set a time.

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Sentencing form

It is preferable to indicate on the sentencing form that DAJD shall calculate credit for time served, as the court may not be aware at sentencing of all factors that affect the amount of credit.

Summary: It is preferable (though not mandatory) to indicate on the sentencing form that DAJD shall calculate credit for time served.

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Contested competency hearing

Should either party contest the determination, a hearing shall be scheduled on the Friday Criminal Motions Calendar in Kent or on the criminal motions calendar in Seattle. Contested competency hearings expected to last more than three hours will be placed on the trial calendar for assignment to an available trial judge.

Summary: Contested competency determinations are heard on the Friday Criminal Motions Calendar in Kent or Seattle criminal motions calendar, but hearings over three hours go to the trial calendar.

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Motion for expert services

The motion for expert services date is the date counsel signs and dates the motion.

Summary: The date of a motion for expert services is the date counsel signs and dates the motion.

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Applies to

Order for presentence investigation report

Must include

proposed order ?

At the time of plea, the Plea/Sentencing Coordinator prepares the cover page of the Order for Presentence Investigation Report (in cases for which a PSI is required by statute) and routes to the Department of Corrections PSI unit. The original order is routed by the Plea/Sentencing Coordinator to the assigned sentencing court- The original will be signed by the sentencing judge and then filed.

Summary: At the time of plea, the Plea/Sentencing Coordinator prepares the Order for Presentence Investigation Report and routes it to the DOC PSI unit, with the original routed to the assigned sentencing court for the judge's signature and filing.

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Civil cases

Applies to

Proposed order

The Court appreciates updated versions of the proposed order that take into account all documentation filed regarding the pending motion.

Summary: The Court appreciates (as a preference) proposed order versions updated to account for all documentation filed on the pending motion.

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Applies to

Witness examination estimate ?

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 create their own format for the witness examination estimate, provided it includes all requested information.

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Jury instructions ?

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.

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Applies to

Working copy ?

If a party would like to request oral argument, the motion should be noted pursuant to the applicable court rules, and you may request argument by simply noting in the upper right-hand corner of the working papers "Oral Argument Requested." If, after reviewing all briefing, the Court determines oral argument is appropriate, the bailiff will contact the parties and set a mutually acceptable time for oral argument.

Summary: Parties may request oral argument on non-dispositive motions by writing "Oral Argument Requested" in the upper right-hand corner of the working papers.

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Cd request form

After the hearing or trial, if you determine you need a copy of the CD, it may be obtained directly from the Clerk's Office copy center. You will need to submit a completed CD Request Form (40KB).

Summary: Copies of hearing CDs after the proceeding are obtained from the Clerk's Office copy center by submitting a completed CD Request Form.

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Applies to

Estimate of witness examinations ?

You may use this form, or create one of your own, as long as it includes the requested information.

Summary: Counsel may use the court's form or create their own form for the witness examination estimate, provided it includes all requested information.

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Recording copy request ?

To request a copy of a recording, submit a completed CD Request Form to the Clerk’s Office.

Summary: Requests for copies of court recordings must be made by submitting a completed CD Request Form to the Clerk's Office.

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Working papers

Most non-dispositive motions do not require oral argument under the Civil Local Rules. You may request oral argument by noting "Oral Argument Requested" in the upper right-hand corner of the working papers. If, after reviewing all briefing, the Court determines oral argument is appropriate, the bailiff will contact the parties and set a hearing date.

Summary: Parties may request oral argument on non-dispositive motions by noting "Oral Argument Requested" in the upper right-hand corner of the working papers.

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Applies to

Written submission

Consistent with General Rule 43, any and all participants in court proceedings before Department 38 are encouraged to inform the Bailiff of their personal pronouns, to indicate the same within any written submissions, and for virtual proceedings to indicate the same within their Zoom name (as Judge Flevaris does).

Summary: Participants are encouraged to indicate their personal pronouns to the Bailiff, within written submissions, and in their Zoom names.

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Applies to

Motion for revision ?

The moving party is urged to use this Department's Revision Form for the purpose of meeting the above standards. Otherwise, the Court may ask the moving party to fill out the Sheet as a supplement to their motion.

Summary: Moving parties are urged to use the Department's Revision Form; otherwise the Court may require the Sheet to be filled out as a supplement to the motion.

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Applies to

Supplemental revision sheet

If an opposing party believes the moving party's citations to the record are materially incomplete, they may file and serve a supplemental Revision Sheet with additional citations and nothing more.

Summary: Opposing parties may file and serve a supplemental Revision Sheet with additional citations (and nothing more) if the moving party's record citations are materially incomplete.

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Applies to

Motion for revision ?

Any Party may request an exception from the above standards based on a showing of need particular to the case.

Summary: Any party may request an exception from the revision-motion standards upon a showing of case-specific need.

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Applies to

Stipulated briefing schedule ?

The parties are also urged to include proposed word counts.

Summary: Parties are urged to include proposed word counts in stipulated cross-motion briefing schedules.

Not confirmed. Read the court's wording below.CRITICAL?

Civil cases

Applies to

Hearing request email ?

Must include

case number ?

Any email request for a motion with oral argument hearing must include: Case name and cause number Names, phone numbers and email addresses of all counsel or pro se party, if known Type of hearing and dates requested

Summary: An email requesting a motion hearing with oral argument must identify the case, known counsel or pro se party contact details, and the hearing type and requested dates.

Not confirmed. Read the court's wording below.CRITICAL?

Civil cases

Applies to

Witness disclosure ?

Judge Whedbee requires all counsel and parties to be prepared at the end of each day to disclose all witnesses that party is intending to call the following day in trial.

Summary: At the end of each trial day, counsel and parties must be prepared to disclose the witnesses they intend to call the next day.

Not confirmed. Read the court's wording below.CRITICAL?

Civil cases

Applies to

Joint statement of evidence ?

The trial will not begin without a Joint Statement signed by all parties. Local Civil Rule 4(k).

Summary: Trial will not begin unless all parties have signed the Joint Statement of Evidence.

Not confirmed. Read the court's wording below.CRITICAL?

Civil cases

Applies to

Motion for revision ?

For each error, include a short issue statement of 1-3 sentences, specify exactly where in the record the issue was argued to the Commissioner, and exactly where all relevant evidence before the Commissioner may be found, by docket number and page range.

Summary: Each error in a motion for revision must include a 1-3 sentence issue statement and specify record locations for argument and evidence.

Not confirmed. Read the court's wording below.WARNING?

Applies to

Sentencing memorandum ?

If these submissions are not received, the Court will proceed with rescheduling the sentencing hearing.

Summary: If the sentencing memoranda are not received, the court will reschedule the sentencing hearing.

Not confirmed. Read the court's wording below.WARNING?

Applies to

Working papers

If a party would like to request oral argument, the motion should be “noted” (scheduled) pursuant to the applicable court rules, and you may request that the judge allow oral argument by simply noting in the upper right-hand corner of the working papers “ORAL ARGUMENT REQUESTED.”

Summary: To request oral argument on a non-dispositive motion, the motion should be scheduled under the applicable rules and the working papers should be marked “ORAL ARGUMENT REQUESTED” in the upper right-hand corner.

Not confirmed. Read the court's wording below.WARNING?

Applies to

Working papers

To request oral argument on a non-dispositive motion, include “Oral Argument Requested” on the upper right-hand corner of the working papers.

Summary: A request for oral argument on a non-dispositive motion must include “Oral Argument Requested” in the upper right-hand corner of the working papers.