Western District of Washington Document Filing Requirements

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Discovery motion

A discovery motion must specifically state its grounds and requested relief or it will be denied.

If a discovery motion is filed, the moving party must clearly state—in specific terms—the grounds for seeking an order and the relief requested. Motions that lack the requisite specificity will be denied.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Motion

Must include

certificate of conference

A Rule 12(b) motion must include a certification of conferral.

If a Rule 12(b) motion is filed, it must include a certification of conferral.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Joint claim chart and prehearing statement

Infringement and invalidity allegations must be filed in a Joint Claim Chart and Prehearing Statement.

All allegations of infringement and invalidity will be filed with the Court in the form of a Joint Claim Chart and Prehearing Statement.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Prehearing statement

A party claiming infringement must list all allegedly infringed claims in the Prehearing Statement.

A Party claiming patent infringement must provide a list of all allegedly infringed claims in the Prehearing Statement.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Joint claim chart

The Joint Claim Chart must include each party’s proposed constructions, specified intrinsic-evidence references, and descriptions of extrinsic evidence.

This Chart will include each Party’s proposed construction of disputed terms, together with specific references to the relevant portions of the specification and the prosecution history, and descriptions of the extrinsic evidence to be used.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Joint claim chart

The parties must attach a Claim Chart Appendix containing copies of all disputed patents and relevant prosecution history.

The Parties will attach to the Joint Claim Chart a Joint Appendix (“Claim Chart Appendix”) with copies of all patents in dispute, together with the relevant prosecution history.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Joint claim chart

If a party proposes a new construction, the Joint Claim Chart must be amended to reflect it.

If a Party must propose a new construction, the Joint Claim Chart must be amended to reflect that change.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Joint claim chart

The Joint Claim Chart before the Court at the Markman hearing must contain the most up-to-date proposed constructions.

At the time of the Markman hearing, the Joint Claim Chart before the Court must reflect the most up-to-date proposed constructions.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Joint claim construction brief

The parties must combine their served briefs into one joint brief, arranging their positions on each claim term in sequential order and substantially following the specified form.

The Parties shall copy and paste their served briefing into one brief, with their positions on each claim term in sequential order, in substantially the form below:

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Jury instructions

Counsel are expected to submit agreed further instructions and each side’s disputed proposed instructions, with explanations and citations supporting differing positions.

Counsel will be expected to submit to the Court (1) any further instructions upon which the opposing parties have conferred and agreed and (2) each side's proposed jury instructions upon which no agreement has been reached, along with explanations and any citations supporting differing positions.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Jury instructions

Each side’s set of proposed jury instructions should include a proposed verdict form.

Each side's set of proposed instructions should also include a proposed verdict form.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion

The motion’s noting date must appear in the caption.

The motion’s noting date shall be placed in the caption.

Checked against the court's document on Oct 4, 2026CRITICAL

Criminal cases

Applies to

Exhibit and witness lists

The parties must file their exhibit and witness lists, including any revisions, with the Court.

The parties shall file their exhibit and witness lists and any revisions with the Court.

Checked against the court's document on Oct 4, 2026CRITICAL

Criminal cases

Applies to

Motion

Motions to extend time must set forth specific facts establishing that an extension is appropriate or the Court will deny them.

The Court will deny motions to extend time unless the parties set forth specific facts that establish an extension is appropriate.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Voir dire submission

Counsel must submit proposed voir dire questions in every case.

In all cases, counsel shall submit a list of proposed voir dire questions.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Exhibit and witness lists

The parties must file their exhibit and witness lists, including any revisions, with the Court.

The parties shall file their exhibit and witness lists and any revisions with the Court.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Peremptory challenge

Each party must submit a written list of the panelists it wishes to excuse when exercising peremptory challenges simultaneously.

Peremptory challenges will be exercised simultaneously, with each party submitting a written list of the panelists it wishes to excuse.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion to seal

Must include

proposed order

Motions to seal, including stipulated motions, must comply with Local Rule CR 5(g), specifically identify the documents, provide supporting facts, and include a proposed order.

Par�es moving to file documents under seal must comply with Local Rule CR 5(g). All mo�ons to seal, including s�pulated mo�ons, must describe with specificity the documents sought to be protected, provide facts jus�fying sealing, and include a proposed order.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion to seal

If the Court denies a request to seal, counsel must advise the Court how the confidential material should be handled.

Counsel shall advise the Court of the requested disposi�on of confiden�al maters in the event the Court denies a request to seal (e.g., should the informa�on be removed from the docket rather than be unsealed).

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Civil rights complaint

The complaint must identify the second right allegedly violated and who violated it.

Identify the second right you believe was violated and by whom:

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Civil rights complaint

The second claim must state all important facts, specify dates, times, locations, and people involved, describe each defendant’s conduct, and include facts explaining why it was wrongful.

State the facts of your second claim below. Include all the facts you consider important. Be specific about dates, times, locations, and the names of the people involved. Describe exactly what each specific defendant did or failed to do that caused you injury or violated your rights, and include any other facts that show why you believe what happened was wrong.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Civil rights complaint

The complaint must specify the injury, harm, or damages allegedly resulting from the Count II events and continue paragraph numbering.

State with specificity the injury, harm, or damages you believe you suffered as a result of the events you described above in Count II. Continue to number your paragraphs.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Civil rights complaint

The complaint must identify the third right allegedly violated and who violated it.

Identify the third right you believe was violated and by whom:

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Civil rights complaint

The third claim must state all important facts, specify dates, times, locations, and people involved, describe each defendant’s conduct, and include facts explaining why it was wrongful.

State the facts of your third claim below. Include all the facts you consider important. Be specific about dates, times, locations, and the names of the people involved. Describe exactly what each specific defendant did or failed to do that caused you injury or violated your rights, and include any other facts that show why you believe what happened was wrong.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Stipulated motion

Must include

proposed order

A stipulated motion must be presented to the court with a proposed order.

“Stipulated Motion” is a stipulation (agreement) between or among the parties presented to the court with a proposed order.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Memorandum

A summary-judgment motion or response must include the statement of material facts or opposing statement of facts within its memorandum.

A party filing a motion for summary judgment or a response thereto shall not separately file a statement of material facts or opposing statement of facts but shall include them within the memorandum

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Civil action

Civil actions must be accompanied by a Civil Cover Sheet, Form JS-44 revised, except specified actions filed by persons in custody.

Every civil action, except civil actions filed by persons in state or federal custody challenging conviction, sentence, or conditions of confinement, shall be accompanied by a Civil Cover Sheet, Form JS-44 revised.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Civil action

Civil actions invoking jurisdiction under 28 U.S.C. § 1338 must include Form AO 120 in patent and trademark matters and Form AO 121 in copyright matters.

All civil actions in which jurisdiction is invoked in whole or in part under 28 U.S.C. § 1338 (regarding patents, copyrights and trademarks) shall be accompanied by the required notice to the Patent and Trademark Office, Form AO 120, in patent and trademark matters, and by the required notice, Form AO 121, in copyright matters.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

In forma pauperis application

Applicants seeking to proceed without prepaying fees must complete the district-approved application for their case type and file written consent concerning payment from any recovery.

At the time application is made under 28 U.S.C. § 1915 or other applicable acts of Congress for leave to commence any civil action or to file any petition or motion without being required to prepay fees and costs or give security for them, each petitioner, movant or plaintiff shall: (1) Complete the in forma pauperis application approved for use in this district for the specific type of case; and (2) File a written consent that the recovery, if any, in the action, to such amount as the court may direct, shall be paid to the clerk who may pay therefrom all unpaid fees and costs taxed against the plaintiff, and to his attorney the amount which the court allows or approves as compensation for the attorney’s services.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Civil cover sheet

A plaintiff must list related cases in the Civil Cover Sheet and file a Notice of Related Cases with its first appearance if related cases exist.

(1) A plaintiff must list all related cases in the Civil Cover Sheet and, if there are any, file a Notice of Related Cases, with its first appearance;

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Civil cover sheet

A removing defendant must list related cases in the civil cover sheet and file a Notice of Related Cases with its first appearance.

(2) A removing defendant must list all related cases in the civil cover sheet and file a notice of Related Cases with its first appearance;

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Notice of related cases

Unless the related action was already listed, parties who have appeared must notify the court of a potentially related district action within five days of learning of it.

(3) Unless an action is listed as related in the Civil Cover Sheet or the original Notice of Related Cases, parties who have appeared must file a Notice of Related Cases alerting the court within five days of learning of any other action that was or is pending in this district that may be related to the party’s case.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Notice of pendency of other action

A party must file a Notice of Pendency of Other Action within five days of learning of a qualifying action in another court, administrative body, or arbitration forum.

Whenever a party knows or learns that its pending case involves all or a material part of the same subject matter and all or substantially the same parties as another action that is pending in any other federal or state court, before an administrative body, or before an arbitrator, the party must file a Notice of Pendency of Other Action within five days of learning of the other action.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Notice of pendency of other action

A Notice of Pendency of Other Action must include identifying details, the relationship between the actions, and statements about possible transfer and coordination.

The Notice must contain the title and case number of the other action, a brief description of the other action, the title and location of the court or other forum in which the other action is pending, a statement of any relationship between the two actions, a statement regarding whether transfer should be effected pursuant to 28 U.S.C. § 1407 (Multi District Litigation Procedures) if the action is pending in another U.S. District Court, and a statement regarding whether coordination between the actions might avoid conflicts, conserve resources and promote an efficient determination of the action.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Sealed document

A sealed document’s first page must be prominently marked “FILED UNDER SEAL.”

A party filing a document under seal shall prominently mark its first page with the phrase “FILED UNDER SEAL.”

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion to seal

Must include

certificate of conference

A motion to seal must include a detailed meet-and-confer certification and a statement of the legal standard and reasons supporting sealing, including interests, potential injury, and why less restrictive alternatives are insufficient.

A motion to seal a document, even if it is a stipulated motion, must include the following: (A) A certification that the party has met and conferred with all other parties in an attempt to reach agreement on the need to file the document under seal, to minimize the amount of material filed under seal, and to explore redaction and other alternatives to filing under seal; this certification must list the date, manner, and participants of the conference; (B) A specific statement of the applicable legal standard and the reasons for keeping a document under seal, including an explanation of: i. the legitimate private or public interests that warrant the relief sought; ii. the injury that will result if the relief sought is not granted; and iii. why a less restrictive alternative to the relief sought is not sufficient

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

proposed order

The movant must serve and file the motion and proposed order and email chambers an editable Word-compatible version of the proposed order.

The moving party shall serve the motion and a proposed order on each party that has appeared in the action, shall file the motion and proposed order with the clerk, and shall submit an editable version of the proposed order, in a format compatible with Microsoft Word, to chambers via email as provided in the Electronic Filing Procedures manual.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion

A motion’s supporting argument must be included in the motion rather than filed separately.

The argument in support of the motion shall not be made in a separate document but shall be submitted as part of the motion itself.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion

If a motion relies on facts outside the record, the movant must serve and file copies of the supporting affidavits, declarations, photographs, or other evidence.

If the motion requires consideration of facts not appearing of record, the movant shall also serve and file copies of all affidavits, declarations, photographic or other evidence presented in support of the motion.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion

Every motion must state its noting date in the caption immediately below the motion title.

All motions shall include in the caption (immediately below the title of the motion) the date the motion is to be noted for consideration upon the court’s motion calendar.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion

The noting-date caption must use the specified “NOTE ON MOTION CALENDAR” wording and date format.

The form for this notation shall be as follows: NOTE ON MOTION CALENDAR: [insert date noted for consideration]

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion

A party seeking oral argument must place “ORAL ARGUMENT REQUESTED” in the caption of its motion or responsive memorandum.

A party desiring oral argument shall so indicate by including the words “ORAL ARGUMENT REQUESTED” in the caption of its motion or responsive memorandum.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

certificate of conference

A motion in limine must certify that the movant in good faith conferred or attempted to confer with affected parties to resolve disputed matters.

Any motion in limine must include a certification that the movant has in good faith conferred or attempted to confer with other affected parties in an effort to resolve which matters really are in dispute.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion for reconsideration

A motion for reconsideration must be plainly labeled as a motion for reconsideration.

A motion for reconsideration shall be plainly labeled as such.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion for reconsideration

A reconsideration motion must specifically identify overlooked or misapprehended matters, new matters, and the requested modifications to the prior ruling.

The motion shall point out with specificity the matters which the movant believes were overlooked or misapprehended by the court, any new matters being brought to the court’s attention for the first time, and the particular modifications being sought in the court’s prior ruling.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Amicus brief

An amicus may file a brief only with court permission, which may follow a motion for leave or the Court’s own initiative.

An amicus curiae may file a brief only upon leave of Court, which may be granted after the submission of a motion for leave to file or upon the Court’s own initiative.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion for leave to file amicus brief

Must include

proposed order

A motion for leave to file an amicus brief must state specified information and party positions and include a proposed order and the proposed brief.

A motion for leave to file an amicus brief shall concisely state the nature of the movant’s interest; identify the party or parties supported, if any; and set forth the reasons why an amicus brief is desirable, why the movant’s position is not adequately represented by a party, and why the matters asserted are relevant to the disposition of the case. The motion shall state the position of each party as to the filing of such a brief and be accompanied by a proposed order and a copy of the proposed amicus brief.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Amicus brief

An amicus brief must include the information required by the specified provisions of Federal Rule of Appellate Procedure 29.

The amicus brief shall contain the information required by Fed. R. App. P. 29(a)(4)(A), (D), and (E).

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Corporate disclosure statement

Covered nongovernmental parties must file a corporate disclosure statement identifying specified ownership interests or stating that none must be identified.

Any nongovernmental party, or any nongovernmental corporation that seeks to intervene, other than an individual or sole proprietorship, must file a corporate disclosure statement. The corporate disclosure statement must do one of the following: (1) Identify any parent corporation and any publicly held corporation owning more than 10% of its stock; any member or owner in a joint venture or limited liability corporation (LLC); all partners in a partnership or limited liability partnership (LLP); and any corporate member, if the party is any other unincorporated association; or (2) State that there “is no parent, shareholder, member, or partner to identify as required by LCR 7.1(a)(1).

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Corporate disclosure statement

In diversity actions, the corporate disclosure statement must list the citizenship states of the party and identified owners, partners, or members.

In diversity actions, for any person or entity identified in (a)(1) above, the corporate disclosure statement must also list those states in which the party, owners, partners, or members are citizens.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Complaint

A diversity-jurisdiction complaint must identify the parties’ citizenship and, for an LLC, LLP, or partnership, the citizenship of its owners, partners, or members.

If plaintiff is asserting that this court has jurisdiction based on diversity, the complaint must identify the citizenship of the parties, and, if any of the parties is a limited liability corporation (LLC), a limited liability partnership (LLP), or a partnership, identify the citizenship of the owners/partners/members of those entities to establish the court’s jurisdiction.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Pleading

A pleading asserting a claim cognizable only in admiralty must place “IN ADMIRALTY” in capital letters above the cause number on its first page.

The words “IN ADMIRALTY” shall be typed in capital letters above the cause number on the first page of a pleading setting forth a claim which is cognizable only in admiralty.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Pleading

A pleading asserting an admiralty claim also within the court’s jurisdiction on another ground must place “AT LAW AND IN ADMIRALTY” in capital letters above the cause number on its first page.

The words “AT LAW AND IN ADMIRALTY” shall be typed in capital letters above the cause number on the first page of a pleading setting forth a claim for relief within the admiralty and maritime jurisdiction that is also within the jurisdiction of the court on some other ground.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Pleading

When a party contends that a three-judge-court hearing is required, the pleading making that allegation must display “THREE JUDGE COURT” in capital letters in the specified first-page location, unless the court rules the cause is not properly before such a court.

If the case is such that any party contends that it will require a hearing before a three judge court, the words “THREE JUDGE COURT” shall be typed in capital letters on the first page of the complaint, answer, or other pleading making such allegation immediately below the name of the pleading to the right of the name of the cause, unless the court rules that the cause is not properly before a three judge court.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Filing

Each pleading, motion, or other filing must include the specified court name on its first page and a title identifying the paper’s purpose and presenting party below the docket number.

Each pleading, motion or other filing shall contain the words “United States District Court, Western District of Washington” on the first page and, in the space below the docket number, a title indicating the purpose of the paper and the party presenting it.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Document requiring court signature

A document requiring the court’s signature must include the presenting attorney’s signature preceded by “Presented by” on the left side of the last page, followed by the specified date and judicial-signature form.

Any document requiring the signature of the court shall bear the signature of the attorney(s) presenting it preceded by the words “Presented by” on the left- hand side of the last page and shall provide as follows: “Dated this ___ day of (Insert Month), (Insert Year). “_______________________________________ “UNITED STATES DISTRICT JUDGE [or UNITED STATES MAGISTRATE JUDGE]”

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion exhibits

Exhibits supporting or opposing a motion must be clearly marked with divider pages.

All exhibits submitted in support of or opposition to a motion must be clearly marked with divider pages.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Court filing with hyperlinks

Parties using hyperlinks in court filings must also provide traditional citations to the cited authority.

To preserve the integrity of the court record, parties wishing to include hyperlinks in court filings shall continue to use the traditional citation method for the cited authority, in addition to the hyperlink.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Subsequent pleadings motions and other filings

All later pleadings, motions, and other filings must reflect the updated address, telephone number, and email.

All subsequent pleadings, motions or other filings shall reflect the new address, telephone number, and email.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Stipulated motion

A stipulated motion changing court-set dates or schedules must clearly state the reasons justifying the proposed change.

If a stipulated motion would alter dates or schedules previously set by the court, the parties shall clearly state the reasons justifying the proposed change.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Proposed amended pleading

A proposed amended pleading may not incorporate any part of the preceding pleading by reference, including exhibits.

The proposed amended pleading must not incorporate by reference any part of the preceding pleading, including exhibits.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Joint notice

When amending by written consent, the party must file a joint notice memorializing consent with a redlined amended pleading attached.

A party who amends a pleading by obtaining the opposing party’s written consent shall file with the court a joint notice memorializing the parties’ consent to the amended pleading and shall attach a redlined version of the amended pleading showing how it differs from the pleading that it amends.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Proposed pretrial order

Must include

proposed order

Unless otherwise ordered, the proposed pretrial order must bear counsel’s signatures for each party and be filed 30 days before trial.

The proposed pretrial order, bearing the signatures of counsel for each party, shall be filed 30 days prior to the scheduled trial date, unless otherwise ordered by the court.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Pretrial order

Counsel must assemble one properly paginated pretrial order.

Counsel shall assemble a single pretrial order, properly paginated.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Pretrial order

The prescribed pretrial-order form should be used as far as possible in all trials except land-condemnation cases.

The following form of pretrial order shall be used, insofar as possible, in the trial of all cases except those involving land condemnation.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Pretrial order

The pretrial order must enumerate every agreed fact, regardless of admissibility, and note any admissibility objections.

The following facts are admitted by the parties: (Enumerate every agreed fact, irrespective of admissibility, but with notation of objections as to admissibility. List 1, 2, 3, etc.)

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Pretrial order

The pretrial order must list and state each legal issue; a simple statement of the ultimate issue is not accepted, and parties who cannot agree may provide separate statements.

The following are the issues of law to be determined by the court: (List 1, 2, 3, etc., and state each issue of law involved. A simple statement of the ultimate issue to be decided by the court, such as “Is the plaintiff entitled to recover?” will not be accepted.) If the parties cannot agree on the issues of law, separate statements may be given in the pretrial order.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Pretrial order

The pretrial order must identify each party’s trial experts by name and address and state the issue on which each will testify.

The name(s) and addresses of the expert witness(es) to be used by each party at the trial and the issue upon which each will testify is:

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Pretrial order

The pretrial order must identify each party’s non-expert trial witnesses by name and address and describe generally their testimony.

The names and addresses of witnesses, other than experts, to be used by each party at the time of trial and the general nature of the testimony of each are:

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Pretrial order

For every witness, indicate whether the witness will testify or is only a possible witness and identify deposition witnesses; rebuttal witnesses whose need cannot reasonably be anticipated before trial need not be named.

(As to each witness, expert or others, indicate “will testify,” or “possible witness only.” Also indicate which witnesses, if any, will testify by deposition. Rebuttal witnesses, the necessity of whose testimony cannot reasonably be anticipated before trial, need not be named.)

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Complaint

A class-action complaint must place the legend “Complaint—Class Action” next to its caption.

The complaint shall bear next to its caption the legend, “Complaint—Class Action.”

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Complaint

A class-action complaint must include a separate heading styled “Class Action Allegations.”

The complaint shall contain under a separate heading, styled “Class Action Allegations”:

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Complaint

The class-action allegations must identify the portion or portions of Federal Rule of Civil Procedure 23 supporting maintenance of the suit as a class action.

A reference to the portion or portions of Fed. R. Civ. P. 23 under which it is claimed that the suit is properly maintainable as a class action.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Complaint

The class-action allegations must state the size or approximate size and definition of the alleged class.

The size (or approximate size) and definition of the alleged class,

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Complaint

The class-action allegations must state the basis for the plaintiff’s claim to be an adequate representative, or, for a defendant class, the basis for the named parties’ adequate representation.

The basis upon which the plaintiff (or plaintiffs) claims (i) to be an adequate representative of the class, or (ii) if the class is composed of defendants, that those named as parties are adequate representatives of the class.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Complaint

For a class action claimed to be maintainable under Rule 23(b)(3), the class-action allegations must include allegations supporting the findings required by that subdivision.

In actions claimed to be maintainable as class actions under Fed. R. Civ. P. 23(b)(3), allegations thought to support the findings required by that subdivision.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion for protective order

Must include

certificate of conference

A motion for a protective order must include a certification of a good-faith meet-and-confer, listing its date, manner, and participants.

(1) Any motion for a protective order must include a certification, in the motion or in a declaration or affidavit, that the movant has engaged in a good faith meet and confer conference with other affected parties in an effort to resolve the dispute without court action. The certification must list the date, manner, and participants to the conference.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Petition

A petition to perpetuate testimony must specify how the deposition will be taken and recorded; if remote, it must include specified remote-deposition provisions in the proposed order.

The petition must state the specific means by which the proponent seeks to take and record the deposition, including whether it will be remote or in person. If remote, the petition must include in the proposed order how exhibits will be handled, by what means persons including the deponent shall participate, other particulars necessary to the taking of a remote deposition, and that the deposition may be used in the same way as any other deposition.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Court order

When a deposition under FRCP 27(a)(3) will be remote, the court’s order must address exhibit handling, participation, other necessary particulars, and use of the deposition.

If the court issues an order as provided in FRCP 27(a)(3) and the deposition will be taken remotely, the court’s order shall include provisions for how exhibits will be handled, by what means persons including the deponent shall participate, any other particulars necessary to the taking of a remote deposition, and that the deposition may be used in the same way as any other deposition.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Discovery motion

Must include

proposed order

The moving party must file the motion containing both parties’ positions, submitted declarations, and the proposed order.

The moving party shall be responsible for filing the motion containing both parties’ positions on the discovery disputes, any declarations submitted by the parties, and the proposed form of order.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Discovery motion

Must include

certificate of conference

A motion to compel disclosure or discovery must include a certification describing the good-faith conference or attempted conference, including its date, manner, and participants.

Any motion for an order compelling disclosure or discovery must include a certification, in the motion or in a declaration or affidavit, that the movant has in good faith conferred or attempted to confer with the person or party failing to make disclosure or discovery in an effort to resolve the dispute without court action. The certification must list the date, manner, and participants to the conference.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Proposed order

Must include

proposed order

The moving party must prepare a proposed order identifying each disputed discovery request and leaving space for the court’s decision.

The moving party shall prepare a proposed order that identifies each of the discovery requests at issue, with space following each of the requests for the court’s decision.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

proposed order

For other motions using the expedited procedure, the same timing and procedure apply, except the moving party sets out the requested relief and supporting authority instead of a discovery dispute and must submit a proposed order stating the requested relief.

The timing and procedure shall be the same as set forth above except that (1) instead of setting forth the disputed discovery request and the opposing party’s objection/response thereto, the moving party should set forth the relief requested and the legal authority that supports the requested relief, and (2) the moving party must submit a proposed order that sets forth the relief requested.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Arbitration agreement

An arbitration agreement must certify that the parties had access to program materials and agreed freely and knowingly.

Any agreement shall include a certification that the parties have been provided access to materials describing the arbitration program, and agree to arbitration freely and knowingly.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Arbitration agreement

An agreement waiving trial de novo must specifically state that the arbitration is final and conclusive.

If the parties agree that the arbitration is to be final and conclusive, with trial de novo waived, the agreement shall specifically so provide.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Arbitration award

The arbitrator’s award must be written and signed by the arbitrator.

The award shall be in writing and signed by the arbitrator.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Trial exhibits

Must include

exhibit list

Unless the court orders otherwise, appearing parties must provide the clerk with marked and tagged trial exhibits on the morning of trial, including an original and a copy of each, although leave to dispense with copies may be sought when copying or using copies would be impractical.

Unless otherwise ordered by the court, on the morning of trial each party appearing shall present marked and tagged trial exhibits to the clerk. Exhibits shall be marked in accordance with the Pretrial Order or other order of the court. The clerk shall be provided with an original and a copy of each exhibit; provided, that leave may be sought from the court to dispense with providing copies of exhibits where bulk or other considerations would make copying, or the use of copies, impractical.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Electronic exhibits

Electronic exhibits must be provided on a secure electronic device unless the court orders otherwise.

Electronic exhibits must be provided via a secure electronic device (e.g., USB stick) unless otherwise ordered by the court.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Electronic exhibits

The party offering electronic exhibits must provide a paper index with them.

The party offering the electronic exhibit(s) must include an index on paper with the electronic exhibits.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Jury instructions

If the parties cannot agree on a complete set, they must file a Joint Instructions document and a Joint Statement of Disputed Instructions in the specified order.

If the parties cannot agree on one complete set of instructions, verdict forms, and interrogatories, they shall file two documents with the court. The first document, titled “Joint Instructions,” shall reflect all agreed-upon instructions, verdict forms, and interrogatories. The second document, titled “Joint Statement of Disputed Instructions,” shall present each disputed instruction, verdict form, and/or interrogatories in the following order:

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Jury instructions

The parties must propose instructions from the most recent version of the Manual of Model Jury Instructions.

The parties shall propose instructions from the most recent version of the Manual of Model Jury

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Jury instructions

All jury instructions submitted to the court must include a table of contents identifying each instruction’s number, title, source, page number, and proposing party.

A table of contents shall be included with all jury instructions submitted to the court. The table of contents shall set forth the following information: (1) the number of the instruction; (2) a brief title of the instruction; (3) the source of the instruction; (4) the page number of the instruction; and (5) the proposing party(ies).

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion for costs

A motion for costs must include a declaration under penalty of perjury verifying the accuracy and necessity of requested costs and charged services.

The movant shall verify, in a declaration sworn under penalty of perjury by the party, an attorney of record, or an agent having knowledge of the facts, that each requested cost is correct and has been necessarily incurred in the case and that the services for which fees have been charged were actually and necessarily performed.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Default judgment

A motion for default judgment must include a declaration and evidence establishing entitlement to the requested monetary and nonmonetary relief.

Plaintiff must support a motion for default judgment with a declaration and other evidence establishing plaintiff’s entitlement to a sum certain and to any nonmonetary relief sought.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

proposed order

A temporary restraining order motion must include a proposed order specifying the requested relief and describing in reasonable detail the acts to be restrained or required.

A motion for a temporary restraining order must include a proposed order specifically setting forth the relief requested and describing in reasonable detail the act or acts to be restrained or required.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Registry deposit

Must include

proposed order

Each deposit into the Court Registry must be accompanied by a judge-signed order approving the deposit.

All deposits into the Registry of the Court must be accompanied by an order approving the deposit signed by a judge.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Registry deposit order

Each signed order for a registry deposit must include the specified deposit direction language.

Each signed order shall contain the following language: “the Clerk is directed to deposit funds into the Registry of the Court in the principal amount of $____.”

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion for disbursement

A motion to disburse registry funds must state the initial principal deposit, the principal amount to be disbursed, and the recipient.

All motions for disbursement of registry funds shall specify the principal sum initially deposited, the amount(s) of principal funds to be disbursed and to whom the disbursement is to be made.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Proposed order for disbursement

Each proposed order for disbursement of registry funds must include the specified check-drawing and payment language.

Each proposed order seeking disbursement of registry funds shall contain the following language: “... the clerk is authorized and directed to draw a check(s) on the funds deposited in the registry of this court in the principal amount of $ plus all accrued interest, payable to (name of payee) and mail or deliver the check(s) to (name of payee).”

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Proposed order for disbursement

When one order directs multiple checks, it must separately state the principal and interest due to each payee.

If more than one check is to be issued pursuant to a single order, the portion of principal and interest due each payee must be separately stated.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion

A motion for interpleader deposit is required and must identify the funds as being deposited into CRIS for the Disputed Ownership Fund.

A Motion for Interpleader Deposit is required. The motion must clearly identify that the funds are to be deposited into the Court Registry Investment System (CRIS) for Disputed Ownership Fund.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Proposed order

The proposed order accompanying the motion must identify the interpleader funds using the specified language.

The proposed order accompanying the motion must correctly identify the interpleader funds by stating that the funds are to be “deposited into the Court Registry Investment System as Disputed Ownership Funds (DOF) interpleader funds under 28 U.S.C. § 1335.”

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Petition for admission

The admission petition must include good-character certificates from two reputable members of the court’s bar.

The petition must include the certificates of two reputable members of the bar of this court attesting to the petitioner’s good moral character.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Petition for conditional admission

A qualifying federal attorney who is not a member of the Washington State Bar must file a conditional-admission petition stating their agency and the circumstances justifying admission.

In the case of an attorney for the United States or one of its agencies who is not a member of the Washington State Bar, he or she must file a Petition for Conditional Admission to Practice, which can be downloaded from the court’s website, and state the department or agency by which he or she is employed and the circumstances justifying the proposed admission to the bar of this court.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Petition for admission

When a conditionally admitted attorney ceases qualifying federal employment, the attorney must file a regular admission petition and pay the applicable fee.

If a conditionally admitted attorney ceases to be employed as an attorney for the United States or one of its agencies, the conditional admission will be revoked and the attorney must file a petition for admission as set forth in LCR 83.1(c)(1) and pay the applicable fee.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Pro hac vice application

A pro hac vice application must be filed promptly with the clerk and include the specified firm, need, rule-compliance, and disciplinary information.

An application for leave to appear pro hac vice shall be promptly filed with the clerk and shall set forth: (1) the name and address of the applicant’s law firm; (2) the basis upon which “particular need” is claimed; (3) a statement that the applicant understands that he or she is charged with knowing and complying with all applicable local rules; (4) a statement that the applicant has not been disbarred or formally censured by a court of record or by a state bar association; and (5) a statement that there are no pending disciplinary proceedings against the applicant.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Pro hac vice application

Local counsel must review, sign, and electronically file the applicant’s pro hac vice application.

Local counsel must review, sign, and electronically file the applicant’s pro hac vice application.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motions and other filings

Unless the court waives the requirement, local counsel must review and sign all motions and other filings, ensure compliance with local rules, and remind pro hac vice counsel of the court’s professionalism and civility expectations.

Unless waived by the court in addition to those responsibilities and any assigned by the court, local counsel must review and sign all motions and other filings, ensure that all filings comply with all local rules of this court, and remind pro hac vice counsel of the court’s commitment to maintaining a high degree of professionalism and civility from the lawyers practicing before this court as set forth in the Introduction to the Civil Rules.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Withdrawal motion

Must include

certificate of service

A withdrawal motion must be noted under LCR 7(d)(3) and certify service on the client and opposing counsel.

A motion for withdrawal shall be noted in accordance with LCR 7(d)(3) and shall include a certification that the motion was served on the client and opposing counsel.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Withdrawal motion

A withdrawal motion that would leave a party unrepresented must include that party’s address and telephone number.

If a withdrawal will leave a party unrepresented, the motion to withdraw must include the party’s address and telephone number.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Withdrawal stipulation and proposed order

A withdrawal stipulation and proposed order must be signed by all opposing counsel or pro se parties and, as appropriate, the party’s new counsel or the party.

A stipulation and proposed order for withdrawal must (1) be signed by all opposing counsel or pro se parties, and (2) be signed by the party’s new counsel, if appropriate, or by the party.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Notice of withdrawal

When withdrawal will not leave the client unrepresented, court leave is unnecessary, but a Notice of Withdrawal must state that the client remains represented, identify the attorneys, and be signed by the withdrawing and remaining attorneys unless the notice details why the withdrawing attorney’s signature cannot be obtained.

Where a party is represented by multiple attorneys from the same or different firms and one or more attorneys wish to withdraw but will not leave the client without representation, leave of the court to withdraw is not required. The remaining or withdrawing attorney(s) shall file a Notice of Withdrawal, which shall include a statement that the client remains represented and identifies the withdrawing and remaining attorneys. The Notices shall be signed by the withdrawing attorney(s) and the remaining attorney(s) of record to confirm that fact. If circumstances prevent obtaining the signature of the withdrawing attorney(s), the Notice must state those circumstances in sufficient detail to satisfy the court that those circumstances in fact preventing obtaining signature.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Withdrawal filing

An attorney withdrawing from representation of a business entity other than a sole proprietorship must certify that the entity was advised of its counsel requirement and the potential consequences of failing to obtain replacement counsel by the effective withdrawal date.

A business entity, except a sole proprietorship, must be represented by counsel. If the attorney for a business entity, except a sole proprietorship, is seeking to withdraw, the attorney shall certify to the court that he or she has advised the business entity that it is required by law to be represented by an attorney admitted to practice before this court and that failure to obtain a replacement attorney by the date the withdrawal is effective may result in the dismissal of the business entity’s claims for failure to prosecute and/or entry of default against the business entity as to any claims of other parties.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion to proceed pro se

Must include

certificate of service

A represented party may not act pro se until moving to proceed on their own behalf, certifying service of the motion on current counsel and the opposing party, and obtaining a substitution order, although the court may hear the party in open court at its discretion.

When a party is represented by an attorney of record in a case, the party cannot appear or act on his or her own behalf in that case, or take any step therein, until after the party requests by motion to proceed on his or her own behalf, certifies in the motion that he or she has provided copies of the motion to his or her current counsel and to the opposing party, and is granted an order of substitution by the court terminating the party’s attorney as counsel and substituting the party in to proceed pro se; provided, that the court may in its discretion hear a party in open court, notwithstanding the fact that he or she is represented by an attorney.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Court filing

An attorney certifies current eligibility to practice before the court by signing a court filing or participating in a matter.

By signing any document filed with the court or otherwise participating in any matter before the court, an attorney certifies that he or she is currently eligible to practice before this court.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Notice of change in status

An attorney whose status changes so that they no longer meet LCR 83.1(b) requirements must notify the Clerk of Court in writing within 10 days.

Should the status of an attorney change so that he or she no longer meets the requirements of LCR 83.1(b), he or she shall notify the Clerk of Court in writing no later than 10 days after the change in status.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Order to show cause

The order to show cause must warn that failing to respond timely may be deemed acquiescence to discipline.

The order to show must also state that the failure to file a timely response may be deemed acquiescence to the imposition of discipline.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Reinstatement petition

A reinstatement petition must be filed with the Clerk of Court and include the specified prior orders and a concise statement of facts justifying reinstatement.

Petitions for reinstatement shall be filed with the Clerk of Court, who will transmit the petition to the Chief Judge. The petition must include a copy of this court’s prior order of suspension or disbarment, a copy of an order of reinstatement from another jurisdiction if the petitioner is seeking reinstatement based on such an order, and a concise statement of facts claimed to justify reinstatement.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Legal document

A legal intern’s signature must be followed by “legal intern,” and court-presented or filed documents must also be signed by the supervising lawyer or a qualified lawyer from the same office.

When a legal intern signs any correspondence or legal document, the intern’s signature shall be followed by the title “legal intern” and, if the document is prepared for presentation to a court or for filing with the clerk thereof, the document shall also be signed by the supervising lawyer or lawyer from the same office as the supervising lawyer.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Notice of bankruptcy filing

A Notice of Bankruptcy Filing must identify the filing party, filing date and court, and state the party’s position on whether the automatic stay applies.

The Notice must identify the filing party, the date of the filing, the court where the filing occurred, and set forth the party’s position regarding whether the action is subject to the automatic stay of 11 U.S.C. § 362.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Habeas petition or 2255 motion

Habeas petitions and § 2255 motions must use or substantially follow the district’s forms.

Petitions for habeas corpus and motions filed pursuant to 28 U.S.C. § 2255 must use or substantially follow this district’s forms, which are available on the court’s website.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Notice of removal

For diversity removals, the notice of removal must identify party citizenship and, where possible, the citizenship of LLC owners or partnership members or partners.

If the removal is based on diversity, the notice of removal must also, to the extent possible, identify the citizenship of the parties, and, if any of the parties is a limited liability corporation (LLC), a limited liability partnership (LLP), or a partnership, identify the citizenship of the owners/partners/members of those entities to establish the court’s jurisdiction.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Habeas petition or 2255 motion

If someone other than the party in custody makes and verifies the petition or motion, that person must explain why and state the basis of their knowledge, including information sources when relying on information and belief.

If a petition or motion is not made and verified by the party in custody, the person making such petition or motion shall verify the same on behalf of such party in custody, and shall set forth therein the reason why it is not made and verified by the party in custody, and shall state he or she knows the facts set forth therein, or if upon information and belief, the sources of his or her information shall be stated.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Notice of removal

Must include

certificate of service

Removing defendants must file specified documents and copies contemporaneously with the notice of removal, including a certificate of service, with the stated attachment, labeling, verification, and certification-cost conditions.

In cases removed from state court, the removing defendant(s) shall file contemporaneously with the notice of removal (1) A copy of the operative complaint, which must be attached as a separate “attachment” in the electronic filing system and labeled as the “complaint” or “amended complaint.” (2) A certificate of service which lists all counsel and pro se parties who have appeared in the action with their contact information, including email address. (3) A copy of any Jury Demand filed in the state court, which must be filed as an attachment and labeled “Jury Demand.” (4) A completed Civil Cover Sheet (AO44). (5) Black-on-white copies of all additional records and proceedings in the state court, together with defendant’s or defense counsel’s verification that they are true and complete copies of all the records and proceedings in the state court proceeding. The copies need not be certified or exemplified by the state court, and the added cost of certification or exemplification will not be allowed as a cost item under 28 U.S.C. § 1920(4) unless certification is required after an opposing party challenges the accuracy of the copies.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

LCR 37 submission

Must include

certificate of conference

An LCR 37 submission must certify that it includes the responding party’s full response and that the parties conferred to attempt to resolve the discovery dispute.

I certify that the full response by the responding party has been included in this submission, and that prior to making this submission the parties conferred to attempt to resolve this discovery dispute in accordance with LCR 37(a).

Checked against the court's document on Oct 4, 2026CRITICAL

Civil casesProposed or draft document; may not be in force

Applies to

Joint claim construction and prehearing statement

The Joint Claim Construction and Prehearing Statement must include the parties’ agreed and disputed constructions, supporting references and evidence, prioritized disputed terms, hearing information, and the parties’ positions on testimony, a tutorial, a pre-hearing conference, and an independent expert.

Not later than 45 days after service of the “Preliminary Claim Constructions,” the parties shall complete and file a Joint Claim Construction and Prehearing Statement, which shall contain the following information: (a) The construction of those claim terms, phrases, or clauses on which the parties agree; (b) Each party’s proposed construction of each disputed claim term, phrase, or clause, together with an identification of all references from the specification or prosecution history that support that construction, and an identification of any extrinsic evidence on which it intends to rely either to support its proposed construction of the claim or to oppose any other party’s proposed construction of the claim in the format of the Sample Joint Claim Chart in Appendix 2 to these Local Patent Rules; (c) The ten most important disputed claim terms. If the parties cannot agree on such terms, then they shall set forth the disputed terms upon which they agree, and each party shall identify any additional terms it believes should be construed, with a brief explanation as to why it believes the construction of such terms are important. The Court will construe a maximum of ten claim terms at the initial Markman hearing, unless the Court determines otherwise. Prioritization should be guided by the twin goals of narrowing the issues and choosing the ten claim terms for which a claim construction would be most productive in terms of setting the groundwork for possible settlement. (d) The anticipated length of time necessary for the Claim Construction Hearing; (e) The proposed order of presentation at the Claim Construction Hearing; (f) The parties’ position on whether, why, and the extent to which the Court should consider live testimony at the Claim Construction Hearing, including the identity of any witnesses a party proposes to call, and for each expert, the disclosure required by Fed. R. Civ. P. 26(a)(2)(B) as to opinions to be offered at the Claim Construction Hearing; (g) The parties’ position as to whether there should be a tutorial on the subject matter of the patent(s) at issue and, if so, the timing of such a tutorial; (h) Whether a pre-hearing conference, prior to the Claim Construction Hearing, is necessary and, if so, the proposed subjects to be addressed and proposed dates for such conference; and (i) Whether the parties believe the Court should appoint an independent expert.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil casesProposed or draft document; may not be in force

Applies to

Opening brief

The cover page of each opening brief must state the responsive brief’s due date beneath the title.

The cover page of an opening brief shall note, under the title, “Due Date: [Date],” where the date shall be the date that the responsive brief is due.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Jury instructions

Must include

legal argument

Counsel are expected to submit agreed additional instructions and each side’s disputed proposed instructions with explanations and supporting citations.

Counsel will be expected to submit to the Court (1) any further instructions upon which the opposing parties have conferred and agreed and (2) each side's proposed jury instructions upon which no agreement has been reached, along with explanations and any citations supporting differing positions.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Stipulation

Must include

proposed order

Stipulations must include a proposed order for the Judge to sign.

When filing stipulations, include a proposed order for the Judge to sign

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Exhibits

Exhibits must be presented to the Court before the trial date.

Exhibits must be presented to the Court prior to the trial date.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Exhibits

Exhibits must use the specified numbering formats for plaintiff and defendant exhibits.

Exhibits must be numbered as follows: Plaintiff: 00001 Defendant: A0001 00002 A0002 00003 A0003 00003a A0003a

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Exhibit or witness list

If an exhibit or witness list is revised after filing, counsel must file the revised list with the court.

If the exhibit or witness list is revised at any time after it is filed with the court, counsel shall file a revised list with the court.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Exhibits

Exhibits must be numbered and named using the exhibit number and a brief description.

Exhibits must be numbered and named. The naming convention for each exhibit must include the exhibit number and a brief description.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Exhibit list

An exhibit list in Microsoft Word format must be emailed to the Courtroom Deputy Clerk at the stated address.

An exhibit list in Microsoft Word format must be emailed to Grant Cogswell, Courtroom Deputy Clerk at: Grant_Cogswell@wawd.uscourts.gov

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Motion

Must include

proposed order

A motion requiring the Court’s signature must be accompanied by a proposed order.

Under Local Rule 7(b)(1), any motion requiring the signature of the Court must be presented along with a proposed order.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Jury instructions

Jury instructions must be submitted pursuant to LR 51.

Jury Instructions: Shall be submitted pursuant to LR 51.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Default judgment

A motion for default judgment must be supported by a declaration.

Plaintiff shall support a motion for default judgment with a declaration.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Default judgment

The motion must include all interest calculations and, for prejudgment interest, identify its accrual start date and the basis for selecting that date.

Plaintiff shall include all interest calculations in the motion for default judgment. For prejudgment interest, Plaintiff shall state the date on which prejudgment interest began to accrue and the basis for selecting that date.

Checked and corrected to match the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

certificate of conference

Every motion must include counsel’s declaration briefly describing the parties’ discussion, their attempt to avoid the motion, and the date of the discussion.

All motions must include a declaration by counsel briefly describing the parties’ discussion and attempt to eliminate the need for the motion and the date of such discussion.

Checked against the court's document on Oct 4, 2026CRITICAL

Civil cases

Applies to

Deposition objections

Failure to designate an objection as specified waives it, even if it was previously stated at the deposition.

A failure to designate objections as set forth above shall constitute a waiver, even if the objection was previously stated at the deposition.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Exhibits

Plaintiff’s exhibits must be numbered consecutively from 1, and Defendant’s exhibits consecutively from A-1.

Plaintiff’s exhibits shall be numbered consecutively beginning with number 1. Defendant’s exhibits shall be numbered consecutively beginning with number A-1.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Exhibits

Counsel must pre-mark all trial exhibits and may obtain labels from the Clerk’s Office or create their own.

All trial exhibits must be pre-marked by counsel. Exhibit labels may be obtained from the Clerk’s Office or counsel may create their own.

Checked against the court's document on Oct 4, 2026CRITICAL

Applies to

Exhibits

Exhibits must be numbered and named according to the Judge’s instructions and naming convention, which can be obtained from the Courtroom Deputy.

Exhibits must be numbered and named. Exhibit numbering should be per the Judge’s instructions. Contact the Courtroom Deputy for the Judge’s naming convention

Checked against the court's document on Oct 4, 2026WARNING

Applies to

Brief

A party may not propose a construction that the other party cannot respond to without first obtaining leave of Court.

A Party may not propose a construction when the other Party is unable to respond without leave of Court (e.g., in a response brief).

Checked against the court's document on Oct 4, 2026WARNING

Applies to

Construction brief appendix

If the parties wish to submit supporting materials, they must submit them in a joint Construction Brief Appendix.

To the extent the Parties wish to submit materials supporting their position, the Parties shall submit them in a Joint Appendix (“Construction Brief Appendix”).

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Applies to

Construction brief appendix

Intrinsic evidence already included in the Claim Chart Appendix must not be repeated in the Construction Brief Appendix; the parties must cite to the Claim Chart Appendix instead.

However, to the extent any intrinsic evidence (including copies of the patent(s) at issue) was previously provided in the Claim Chart Appendix, any such evidence shall not be repeated in the Construction Brief Appendix. Instead, the Parties shall cite to the Claim Chart Appendix for such materials.

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Criminal cases

Applies to

Motion

Boilerplate reasons alone—including party agreement, a speedy-trial waiver, or time to negotiate—are insufficient grounds for an extension.

The Court strongly discourages motions that only contain “boiler-plate” reasons. Thus, reasons such as “the agreement of the parties,” “the defendant has filed a speedy trial waiver,” or “the parties need time to negotiate” are, without more, insufficient grounds to grant an extension.

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Civil cases

Applies to

Pretrial communication

Counsel should advise the Court whether an extra-large jury pool or individual questioning of prospective jurors is needed.

Pre-Trial Counsel should advised the Court whether the case requires an extra-large jury pool and whether the case requires each prospective juror be individually questioned.

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Civil cases

Applies to

Exhibits

Each exhibit must be clearly marked.

Each exhibit shall be clearly marked.

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Civil cases

Applies to

Exhibits

Plaintiff’s exhibits must be numbered consecutively starting at 1, and defendant’s exhibits must continue with the next unused number.

Plaintiff’s exhibits shall be numbered consecutively beginning with 1; defendant’s exhibits shall be numbered consecutively beginning with the next number not used by plaintiff.

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Applies to

Complaint

Number paragraphs using count-specific numbering, continuing the numbering provided for the first two paragraphs of each count.

Number your paragraphs. For example, in Count I, paragraphs should be numbered 1.1, 1.2, 1.3, etc., and in Count II, paragraphs should be numbered 2.1, 2.2, 2.3, etc. The first two paragraphs of each Count have been numbered for you.

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Applies to

Complaint

If the complaint includes more than three counts, attach additional pages and use the same format for each count.

If you have more than three counts, attach additional pages and follow the same format for each count.

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Applies to

Complaint

When attaching supporting documents, identify the page and paragraph relied on for each specific fact; otherwise, the Court may disregard the documents.

If you attach documents to support the facts of your claim(s), you must specify which portion of the document(s) (i.e., page and paragraph) you are relying on to support the specific fact(s) of your claim(s). If you do not specify the portion of the supporting document(s), the Court may disregard your document(s).

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Applies to

Complaint

The complaint must state exactly what relief the plaintiff seeks.

State exactly what you want the Court to do for you. For example, you may be seeking money damages from an individual defendant, you may want the Court to order a defendant to do something or to stop doing something, or you may want both kinds of relief.

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Applies to

Complaint

By signing the complaint, the plaintiff represents that the allegations are true to the best of their knowledge, show a violation of law, and are not filed for harassment or another improper purpose.

By signing this complaint, you represent to the Court that you believe the facts alleged to be true to the best of your knowledge, that you believe those facts show a violation of law, and that you are not filing this complaint to harass another person or for any other improper purpose.

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Civil cases

Applies to

Motion

Must include

proposed order

Proposed orders are not required for motions identified in LCR 7(d)(4), except motions seeking preliminary injunction.

Except for motions seeking preliminary injunction, proposed orders are not required for motions identified in LCR 7(d)(4).

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Civil cases

Applies to

Amicus reply brief

An amicus may file a reply brief or participate in oral argument only with court permission.

An amicus curiae may file a reply brief or participate in oral argument only with the court’s permission.

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Civil cases

Applies to

Filing

Each page should include the abbreviated filing title and case number at bottom left, a page number in the specified position, and the preparer’s firm (if any), mailing address, and telephone number at bottom right.

At the left side of the bottom of each page, an abbreviated title of the pleading, motion or other filing should be repeated, followed by the case number. The page number should be placed after the abbreviated title or in the middle of the bottom of each page. At the right side of the bottom of each page, the law firm (if any), mailing address and telephone number of the attorney or party preparing the paper should be printed or typed.

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Civil cases

Applies to

Pleadings motions and other filings

When the court reviews agency proceedings, parties should, insofar as possible, cite the page and line of each referenced transcript or record portion.

In all cases where the court is to review the proceedings of an administrative agency, transcripts, deposition testimony, etc., the parties shall, insofar as possible, cite the page and line of any part of the transcript or record to which their pleadings, motions or other filings refer.

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Civil cases

Applies to

Filings referencing motion exhibits

References to motion exhibits should identify specific pages, paragraphs, lines, or similarly precise locations whenever possible.

References in the parties’ filings to such exhibits should be as specific as possible (i.e., the reference should cite specific page numbers, paragraphs, line numbers, etc.).

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Civil cases

Applies to

Court filing with hyperlinks

Neither a hyperlink nor the site it links to is part of the court record.

Neither a hyperlink, nor any site to which it refers, is considered part of the record.

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Civil cases

Applies to

Stipulated motion

Parties seeking a court order related to a stipulation should file a stipulated motion under LCR 7(d)(1).

If the parties seek a court order related to their stipulation, they should file a stipulated motion pursuant to LCR 7(d)(1).

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Civil cases

Applies to

Stipulation or stipulated motion

Stipulations and stipulated motions bind the court only if the court adopts them through an order.

Stipulations and stipulated motions shall be binding on the court only if adopted by the court through an order.

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Civil cases

Applies to

Stipulation

An order based on a stipulation is sufficient if “It is so ordered” or equivalent is endorsed at the end of the stipulation and signed by the court.

An order based upon a stipulation shall be sufficient if the words “It is so ordered,” or their equivalent, are endorsed on the stipulation at the close thereof and if this endorsement is signed by the court.

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Civil cases

Applies to

Proposed stipulated protective order

Use of the district’s model protective order is encouraged, and parties departing from it must provide a redline identifying the departures.

Parties are encouraged to use this district’s model protective order, available on the court’s website. Parties that wish to depart from the model order must provide the court with a redlined version identifying departures from the model.

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Civil cases

Applies to

Deposition designations

An objection not designated in the prescribed manner is waived even if it was stated at the deposition.

A failure to designate an objection in this manner shall constitute a waiver, even if the objection was previously stated at the deposition.

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Civil cases

Applies to

Pretrial order

Parties may request electronic presentation of exhibits to jurors by including the request in the pretrial order and reiterating it to the assigned judge before or during the final pretrial conference.

The parties may request to present exhibits in electronic format to jurors by including the request in their pretrial order as set forth in LCR 16 and by reiterating the request to the assigned judge prior to or during the final pretrial conference.

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Civil cases

Applies to

Counsel substitution

For a change of counsel within the same law firm, no substitution order is required; the new attorney should file a Notice of Appearance and the withdrawing attorney should file a Notice of Withdrawal.

Where there has simply been a change of counsel within the same law firm, an order of substitution is not required; the new attorney should file a Notice of Appearance and the withdrawing attorney should file a Notice of Withdrawal.

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Applies to

Exhibit list

The Word exhibit list should number plaintiff and defendant exhibits using the specified formats.

Exhibits should be numbered as follows on the Word list: Plaintiff: 1 Defendant: A-1 2 A-2 3 A-3 3a A-3a

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Applies to

Trial exhibits

Counsel must pre-mark and number trial exhibits in consecutive, party-specific series; duplicate documents may not appear twice on the exhibit list, and an identified exhibit may be used by any party.

All trial exhibits must be pre-marked by counsel. Plaintiff’s exhibits shall be numbered consecutively beginning with number 1. Defendant’s exhibits shall be numbered consecutively beginning with the next number series (i.e. 200) not used by the plaintiff. If multiple parties, each parties exhibits shall be numbered consecutively beginning with the next number series not used. Duplicate documents shall not be listed twice on the exhibit list. Once a party has identified an exhibit on the exhibit list or in the pretrial order, any party may use it.

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Applies to

Exhibits and depositions

Deliver the original and one copy of exhibits and depositions to the courtroom deputy clerk by the Thursday before trial, unless other arrangements are made; if JEEPS is used, only one paper set is required.

The original and one copy of the exhibits/depositions are to be delivered to Grant Cogswell, Courtroom Deputy Clerk, the Thursday prior to trial or upon other arrangements made with the clerk. If JEEPS (Jury Electronic Evidence Presentation) is being used, only one set of paper exhibits is required.

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Applies to

Proposed order

The proposed-order email subject should include the case number, case name, and motion title, not just “Proposed Order.”

The subject heading of the email should include the case number, the case name, and the title of the motion (i.e., it should not simply read “Proposed Order”).

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Civil cases

Applies to

Video deposition

The party offering a video deposition must know how to use the courtroom technology and ensure the video is appropriately edited after the Court rules on objections.

The party offering the video is responsible for being familiar with the courtroom technology necessary to play it and for ensuring that the video is edited appropriately after the Court makes its rulings on any objections.

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Applies to

Exhibit list

Duplicate documents should appear only once on the exhibit list, and any party may use an exhibit identified on a party’s list or in the pretrial order.

Duplicate documents should not be listed twice on the exhibit list. Once a party has identified an exhibit on the exhibit list or in the pretrial order, any party may use it.

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Applies to

Tutorial

The parties are encouraged to use visual aids and suggest a reasonable volume of reading materials for the tutorial.

Visual aids and suggestions for reading materials of a reasonable volume are encouraged.

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Civil cases

Applies to

Jury instructions

Parties need not submit instructions that are included in the Court’s standard set.

Any instructions included in the standard set need not be submitted by any party.

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Civil cases

Applies to

Notice of supplemental authority

Before a pending motion is decided, a party may serve and file a Notice of Supplemental Authority attaching later-issued relevant authority without argument.

Before the court rules on a pending motion, a party may bring to the court’s attention relevant authority issued after the date the party’s last brief was filed by serving and filing a Notice of Supplemental Authority that attaches the supplemental authority without argument.

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Civil cases

Applies to

Motion exhibits

A party may timely file appropriate additional exhibit excerpts with a reply brief, and responding parties may timely file additional excerpts they believe are directly germane.

Parties who file excerpts do so without prejudice to their right to timely file additional excerpts of the exhibit with reply briefs if otherwise appropriate. Responding parties may also timely file additional excerpts of the exhibit that they believe are directly germane.

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Civil cases

Applies to

Declaration

Each party may submit declarations to attach documents for consideration and provide information sufficient for assessment of expenses and sanctions.

Each party may submit declarations for the purpose of attaching documents to be considered in connection with the submission and to provide sufficient information to permit the court to assess expenses and sanctions, if appropriate.

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Civil cases

Applies to

Habeas petition or 2255 motion

Upon request, the clerk must provide blank court forms for habeas petitions and § 2255 motions.

Upon request, the clerk shall provide blank copies of forms prescribed by this court for petitions for writs of habeas corpus and motions filed pursuant to 28 U.S.C. § 2255.

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Applies to

Exhibits

Each exhibit must be clearly pre-marked.

Summary: Each trial exhibit must be clearly pre-marked before delivery.

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Applies to

Motion for temporary restraining order

All motions for temporary restraining orders must meet the requirements of Federal Rule of Civil Procedure 65 and Local Civil Rule 65.

Summary: All motions for temporary restraining orders must comply with Federal Rule of Civil Procedure 65 and Local Civil Rule 65.

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Civil cases

Applies to

Motion

Must include

certificate of conference ?

Except for dispositive motions, motions shall contain a certification that the parties have met and conferred. (But see Section II(F) infra, for conferral requirements as to motions to dismiss pursuant to Fed. R. Civ. P. 12(b).) The certification should be clearly visible within either the first substantive paragraph or the final paragraph of the motion. Parties must make a meaningful effort to confer prior to filing a motion. Parties should provide for at least three (3) business days between attempts to confer and a motion's filing.

Summary: Motions (except dispositive) must include a certification of conferral, with at least 3 business days between conferral attempts and filing.

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Applies to

Jury instructions ?

The parties should identify whether a proposed instruction is Preliminary (i.e., to be given at the start of trial), In-Trial (i.e., to be given, as necessary, during trial), or Final (i.e., to be given at the conclusion of evidence).

Summary: Proposed jury instructions should be identified as Preliminary, In-Trial, or Final.

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Civil cases

Applies to

Motion

A motion and the legal argument supporting the motion shall be filed as a single document. Motions shall not contain a table of cases or a table of authorities.

Summary: Motions must be a single document without a table of cases or authorities.

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Civil cases

Applies to

Administrative record

In matters requiring that an administrative record be filed with the Court, parties must provide a copy of the record to the Court in an electronic format. No physical copy of the record shall be filed.

Summary: Administrative records must be filed electronically; no physical copies accepted.

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Civil cases

Applies to

Discovery motion

If the Court permits the filing of an opposed discovery motion, the motion shall contain a verbatim recitation of the discovery request and objection at issue or shall attach a copy of such.

Summary: Opposed discovery motions must include a verbatim recitation of the discovery request and objection at issue, or attach a copy.

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Civil cases

Applies to

Joint status report and discovery plan

Unless specific circumstances require it, the Court will not hold a Fed. R. Civ. P. 16(b) Initial Status Conference. Instead, the Court will review the parties' combined Joint Status Report and Discovery Plan as required by FRCP 26(f) and Local Civil Rule 26(f) and issue a Scheduling Order as soon as practicable thereafter.

Summary: The Court will not hold a Rule 16(b) Initial Status Conference absent specific circumstances; instead, the parties must file a combined Joint Status Report and Discovery Plan under FRCP 26(f) and Local Civil Rule 26(f), after which the Court will issue a Scheduling Order.

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Civil cases

Applies to

Notice of settlement

If the matter settles, in whole or in part, the parties shall promptly file a notice of settlement and advise the Court how much time is needed to file dismissal papers.

Summary: If a case settles in whole or in part, the parties must promptly file a notice of settlement and advise the Court how much time they need to file dismissal papers.

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Applies to

Jury instructions

As much as possible, the parties should agree on one stipulated set of proposed jury instructions. Only true uncertainty about the binding substantive law should prevent such agreement.

Summary: Parties should agree on one stipulated set of proposed jury instructions unless true uncertainty about binding substantive law prevents agreement.

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Applies to

Petition

A petition filed by a registered ECF filer must include the signature of the debtor (and joint debtor if applicable) in accordance with Local Bankruptcy Rule 5005-1(c)(1) or be subject to dismissal within 1 business day, without further notice, as to the debtor whose signature is not provided.

Summary: Petitions by ECF filers must include debtor's signature; missing signature may result in dismissal within 1 business day.

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Applies to

Petition

A petition submitted for filing by an unrepresented individual must include the signature of the debtor (and joint debtor if applicable) in accordance with Local Bankruptcy Rule 5005-1(c)(2) or be subject to rejection by the clerk of court and returned to the debtor with no bankruptcy case opened. Joint petitions filed without the signature of a joint debtor will be issued a 7-day deficiency notice to provide the missing signature.

Summary: Petitions by unrepresented individuals must include debtor's signature; missing signature results in rejection or 7-day deficiency notice for joint petitions.

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Applies to

Petition

A debtor shall file or submit with the voluntary petition a verified statement setting out the debtor’s social security number, taxpayer identification number, or a statement that the debtor does not have a social security number or taxpayer identification number.

Summary: Debtor must file a verified statement of social security number or taxpayer identification number with the petition.

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Applies to

List of creditors

A debtor in a voluntary case shall file or submit a list of creditors in the format required by the office of the clerk of court, containing the names and addresses of each entity included or to be included on Schedules D, E/F, G and H, as required by 11 U.S.C. § 521(a)(1)(A) and Fed. R. Bankr. P. 1007(a)(1), no later than 7 days from the date of the filing of the petition.

Summary: Debtor must file a list of creditors within 7 days of petition filing.

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Applies to

Schedules and statements

A debtor in a voluntary case shall file or submit with the petition the items required by Fed. R. Bankr. P. 1007(b) and 11 U.S.C. ... Failure to file or submit these schedules and statements may result in dismissal of the debtor’s case, provided that the docket shows that the debtor was given 15 days' notice of this provision.

Summary: Debtor must file schedules and statements with the petition; failure may result in dismissal after 15 days' notice.

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Applies to

Motion

If the request for a continued hearing or alternate appearance is denied by the trustee or United States Trustee, the debtor may file a motion seeking court approval of the continuance or alternate appearance. Any motion must contain an explanation of the need for the modification and a certification that the debtor sought a continuance from the trustee or United States Trustee under paragraphs (b)(1) and (b)(2) of this Rule.

Summary: Motion after denial must include explanation of need and certification of prior continuance request.

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Applies to

Fee application ?

Must include

proposed order

All applications shall conform to Local Bankruptcy Form 13-9. All applications for compensation for services and for reimbursement of necessary costs and expenses shall be served on the debtor and the chapter 13 trustee. A notice of hearing on the application shall be served on the debtor, the chapter 13 trustee, and all creditors holding allowed claims. The application shall include an itemized time record that identifies the date the service was rendered, the identity of the person who performed the service and the hourly rate of the person, a detailed description of the service rendered and the time spent performing the service, and the total number of hours spent and the total compensation requested. A copy of a proposed order approving the application shall be attached to the application as a separate document and the order shall conform to Local Bankruptcy Form 13-10.

Summary: Fee applications must use Local Form 13-9, include an itemized time record, attach a proposed order (Local Form 13-10), and be served on the debtor and trustee.

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Applies to

Rights and responsibilities disclosure

Attorneys representing debtors in chapter 13 cases shall provide debtors with a copy of Local Bankruptcy Form 13-5 entitled “Rights and Responsibilities of Chapter 13 Debtors and Their Attorney” (“Rights and Responsibilities Disclosure”). The Rights and Responsibilities Disclosure shall be signed by each debtor, certifying receipt, and by the debtor’s attorney. Failure to provide a copy of the Rights & Responsibilities Disclosure may result in denial or disgorgement of attorney fees.

Summary: Attorneys must provide the Rights and Responsibilities Disclosure to chapter 13 debtors, signed by debtor and attorney; non-compliance may result in fee denial or disgorgement.

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Applies to

Motion to withdraw ?

Any motion or stipulation filed pursuant to subsection (b) must contain: (1) the client’s mailing address, telephone number and email address or a certification by the attorney that the attorney made all reasonable efforts to obtain the contact information of the client without success, (2) a statement that no deadlines, hearings or trials will be automatically continued as a result of the attorney’s withdrawal, and (3) if the client is not an individual, a certification by the attorney that the attorney has notified the client that the client may not appear or file pleadings pro se.

Summary: Withdrawal motions or stipulations must include client contact info (or certification of unsuccessful efforts), a statement that no deadlines are automatically continued, and a certification about pro se restrictions for non-individual clients.

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Applies to

Chapter 13 plan ?

All plans shall conform to Local Bankruptcy Form 13-4. All appropriate blanks on the form shall be completed. The debtor and the debtor’s attorney (if represented by counsel) shall sign and date where indicated.

Summary: Chapter 13 plans must use Local Bankruptcy Form 13-4, with all blanks completed and signed by debtor and attorney.

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Applies to

Plan

complete Section IV.C. of the plan and include both "See X" on the line titled "Collateral" before describing the collateral and the proposed monthly payment on the line titled "Monthly Payment" (if the plan completely strips the lien, the monthly payment will be $0);

Summary: Debtor must complete Section IV.C. of the plan with specific formatting for collateral and monthly payment lines.

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Applies to

Plan

include the following language in Section X of the plan: "____________[creditor] holds a security interest or lien against ___________[collateral]. The value of the collateral is $_________. The claims of other creditors holding higher priority security interests or liens against the collateral total $________. Accordingly, the amount of _________[creditor's] secured claim is $___________[collateral value minus total amount of higher priority secured claims]. The balance of ________[creditor's] claim is an unsecured claim. The monthly payment on the secured claim under the plan is $_______. The final avoidance and/or determination of the secured status of a creditor’s lien in this plan is contingent upon the debtor’s completion of the plan. If this case is converted to another chapter of the Bankruptcy Code or if this case is dismissed, the relevant provisions of 11 U.S.C. §§ 348 and 349 control the validity of the lien avoidance and/or determination."

Summary: Debtor must include specific language in Section X of the plan regarding valuation of secured claim.

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Applies to

Plan

file, with the plan, evidence (e.g. a declaration) supporting the debtor's factual assertions regarding the value of the collateral and the amount of the relevant liens;

Summary: Debtor must file supporting evidence (e.g., declaration) with the plan for valuation assertions.

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Applies to

Proof of service

Must include

certificate of service ?

file, with the plan, a proof of service showing compliance with subsection (f)(4).

Summary: Debtor must file a proof of service with the plan showing compliance with the service requirement.

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Applies to

Plan

complete Section IV.C. of the plan and include both "See X" on the line titled "Collateral" before describing the collateral and the proposed monthly payment on the line titled "Monthly Payment" (if the plan completely avoids the lien, the monthly payment will be $0);

Summary: Debtor must complete Section IV.C. of the plan with specific formatting for collateral and monthly payment lines for lien avoidance.

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Applies to

Plan

include the following language in Section X of the plan: "____________[creditor] holds a judicial lien or security interest avoidable under 11 U.S.C. § 522(f) against ___________[collateral]. The value of the collateral is $_________. The claims of other creditors holding higher priority security interests or liens against the collateral total $________. The Debtor is entitled to an exemption under 11 U.S.C. § 522(b) of $_______. Accordingly, the amount of _________[creditor's] secured claim is $___________[collateral value minus total amount of higher priority secured claims minus the Debtor’s exemption]. The balance of ________[creditor's] claim is an unsecured claim. The monthly payment on the secured claim under the plan is $______."

Summary: Debtor must include specific language in Section X of the plan regarding avoidance of judicial lien or security interest.

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Applies to

Plan

file, with the plan, evidence (e.g. a declaration) supporting the debtor's factual assertions regarding the value of the collateral, the amount of the debtor’s exemption and the amount of relevant liens;

Summary: Debtor must file supporting evidence (e.g., declaration) with the plan for avoidance assertions.

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Applies to

Proof of service

Must include

certificate of service ?

file, with the plan, a proof of service showing compliance with subsection (g)(4).

Summary: Debtor must file a proof of service with the plan showing compliance with the service requirement for lien avoidance.

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Applies to

Chapter 13 information sheet

At the time the petition is filed, the debtor shall submit to the trustee a complete Chapter 13 Information Sheet (Local Bankruptcy Form 13-2).

Summary: Debtor must submit a complete Chapter 13 Information Sheet to the trustee at the time of petition filing.

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Applies to

Plan modification motion ?

Must include

proposed order

A debtor seeking post-confirmation plan modification shall file an amended plan, a motion requesting approval of the amended plan, and a declaration of the debtor explaining the need for the modification. The debtor shall identify in the motion all proposed changes by reference to the plan section number and with the specific changes listed. Contemporaneously with filing the motion and declaration, the debtor shall file supplemental Schedules I and J and provide the trustee copies of all payment advices or other evidence of proof of income received within the last 30 days. A proposed order approving the amended plan shall be attached to the motion as a separate document and shall substantially comply with Local Bankruptcy Form 13-6.

Summary: Debtor must file amended plan, motion, declaration, identify changes, file supplemental schedules, provide payment advices, and attach proposed order for plan modification.

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Applies to

Certification of domestic support ?

debtors must file certifications stating either (1) that they are not liable for any domestic support obligation; or (2) that all domestic support obligations payable by them that became due on or before the date of the certification (including amounts due before the petition was filed, but only to the extent provided for by the plan) under any judicial or administrative order, or by statute, have been paid. Failure to file the certification will result in the case being closed without a discharge.

Summary: Debtors must file a certification regarding domestic support obligations; failure results in case closure without discharge.

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Applies to

Motion

Must include

local rule certificate ?

The Guidelines for Cash Collateral and Financing Stipulations (Appendix A to these Local Bankruptcy Rules, as may be modified from time to time and posted on the court’s website) apply to all motions for approval of such stipulations, interim and final, and all motions for approval thereof must contain the certification of counsel required by the Guidelines.

Summary: Motions for approval of cash collateral and financing stipulations must contain the certification of counsel required by the Guidelines.

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Applies to

Request for tax information

Must include

specific language ?

Requests for tax information filed with the court must contain the following language: Movant is hereby advised that the tax information obtained is confidential and may not be disseminated except as appropriate under the circumstances of the case. Movant is further advised that substantial monetary sanctions (up to $10,000 per disclosure without further notice) and other sanctions may be imposed by the Court for an improper use, disclosure, or dissemination of the tax information.

Summary: Requests for tax information filed with the court must include specific language about confidentiality and sanctions.

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Applies to

Motion for hardship discharge ?

Must include

proposed order

Motions for discharge under 11 U.S.C. § 1328(b) shall be filed with the court and served on the trustee, United States trustee, and all creditors at least 21 days preceding the date fixed for hearing. The motion shall set forth the basis for the discharge and provide evidence (including a sworn declaration from the debtor) in support of the motion. Contemporaneously with filing the motion and declaration, the debtor shall file supplemental Schedules I and J and provide the trustee copies of all payment advices or other evidence of proof of income received within the last 30 days. A copy of a proposed order shall be attached as an exhibit to the motion as a separate document and the order shall conform with Local Bankruptcy Form 13-7.

Summary: Motions for hardship discharge must include a sworn declaration, supplemental Schedules I and J, and a proposed order conforming to Local Bankruptcy Form 13-7.

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Applies to

Hardship discharge order ?

Must include

certificate of service

Hardship Discharge (Local Bankruptcy Form 13-7), debtor or debtor’s counsel shall serve the entered order on all creditors in the manner provided in Fed. R. Bankr. P. 2002 and shall file a certificate of service that service has been effected.

Summary: Debtor must serve hardship discharge order on all creditors and file a certificate of service.

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Applies to

Reaffirmation agreement

The Administrative Office of the United States Courts has issued Director’s Reaffirmation Agreement forms (available on the court’s website) which must be completed for all reaffirmation agreements, and shall be filed with the Reaffirmation Agreement Cover Sheet, Official Form B 427.

Summary: Reaffirmation agreements must use Director's Reaffirmation Agreement forms and be filed with Reaffirmation Agreement Cover Sheet, Official Form B 427.

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Applies to

Reaffirmation agreement

Copies of any agreements which the debtor has agreed to continue to perform or pay, together with any modifications of those agreements, shall be attached to the reaffirmation agreement together with documentation of any security interest and the perfection of such security interest or a memorandum setting forth why perfection is unnecessary and supporting declaration(s) establishing any required facts. If the reaffirmation is of a debt claimed to be nondischargeable, the creditor shall file a memorandum setting forth the basis for the nondischargeability, together with a declaration(s) establishing a prima facie case.

Summary: Reaffirmation agreements must include copies of underlying agreements, modifications, and documentation of security interest or nondischargeability basis.

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Applies to

Application for deposit into registry ?

a party desiring to deposit funds into the registry of the court must file an application, which shall include a detailed explanation of the facts and circumstances necessitating the deposit of estate funds into the registry.

Summary: Parties must file an application with detailed explanation to deposit funds into court registry.

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Applies to

Proposed order for deposit ?

A proposed order directing the clerk of court to deposit funds into the registry of the court must include the following: (1) the amount to be deposited; (2) a direction to the clerk of court to deposit registry funds totaling $25,000 or more into an interest-bearing account; and (3) a direction to the clerk of court to deposit registry funds totaling less than $25,000 into a non-interest-bearing account with the U.S. Treasury.

Summary: Proposed order for deposit must include amount and direction for interest-bearing or non-interest-bearing account based on amount.

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Applies to

Motion to reopen

A motion to reopen a case shall state the purpose for reopening the case, whether assets were administered in the case, whether a deadline was established for filing proofs of claim, and whether a trustee needs to be appointed. Except as provided for in subsection (b), the motion shall be noted for hearing in accordance with Local Bankruptcy Rule 9013-1, with notice to the case trustee and any affected parties.

Summary: Motion to reopen must state purpose, asset administration, proof of claim deadline, and trustee need; must be noted for hearing.

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Applies to

Motion for withdrawal of reference

Must include

caption ?

A motion for withdrawal of reference shall be designated: 'Motion for Withdrawal of Reference.'

Summary: Motion for withdrawal of reference must have specific caption.

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Applies to

Initial pleading

In an adversary proceeding before a bankruptcy judge, in addition to the statements in the pleadings required by Fed. R. Bankr. P. 7008(a) and 7012(b), each party shall file a separate document with its initial pleading (the complaint, counterclaim, cross-claim, third party complaint, answer or other responsive pleading) to be entitled Notice Regarding Final Adjudication and Consent. The Notice Regarding Final Adjudication and Consent shall include a repetition of the statements required by Fed. R. Bankr. P. 7008(a) and 7012(b). Failure by a party to file a Notice Regarding Final Adjudication and Consent as required by this rule or by a date certain fixed by court order shall constitute that party’s consent to entry of final orders or judgments by the bankruptcy judge.

Summary: Parties must file a Notice Regarding Final Adjudication and Consent with their initial pleading in adversary proceedings; failure to file constitutes consent to final orders by the bankruptcy judge.

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Applies to

Motion for default judgment

The party seeking a default judgment must support a motion for default judgment with a declaration and other evidence establishing that party’s entitlement to a sum certain and/or to any nonmonetary relief sought. (A) The party shall provide a concise explanation of how all amounts were calculated and shall support this explanation with evidence establishing the entitlement to and amount of the principal claim, and, if applicable, any liquidated damages, interest, attorney’s fees, or other amounts sought. If the claim is based on a contract, plaintiff shall provide the court with a copy of the contract and cite the relevant provisions.

Summary: Motions for default judgment must be supported by a declaration and evidence, including a concise explanation of calculations and, if based on contract, a copy of the contract.

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Applies to

Motion to shorten time ?

Must include

proposed order ?

The motion requesting an order shortening time or limiting notice along with the underlying motion papers and a proposed form of order shortening time or limiting notice, shall be filed and served on all parties entitled to notice of the underlying motion unless otherwise ordered by the court.

Summary: Motions to shorten time must include a proposed order and be filed with the underlying motion papers.

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Applies to

Default order ?

Must include

proposed order, certificate of service ?

If no opposition to a motion has been timely filed and served, in accordance with Local Bankruptcy Rule 9013-1(d)(5), the court in its discretion may: (1) grant the motion by default at the hearing, or (2) grant the motion prior to the time set for hearing, upon the moving party’s uploading of a received unsigned order, accompanied by proof of the service and a declaration of no objection stating the date of service of the notice of the motion and that no objections were timely received.

Summary: To obtain a default judgment without a hearing, the moving party must upload an unsigned order, proof of service, and a declaration of no objection.

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Applies to

Ex parte motion ?

administrative orders, shall (A) allege specific facts forming the basis of the request, (B) cite the statute or rule authorizing the court to act, and (C) state specific reasons why the court should proceed without notice or a hearing. If the motion arises in an adversary proceeding or a contested matter as defined in Fed. R. Bankr. P. 9014, the moving party shall, in addition, describe (D) what immediate and irreparable injury, loss or damage will result to the movant before the adverse party or his attorney can be heard in opposition; and (E) the efforts, if any, which have been made to give notice to the adverse party and his attorney.

Summary: Ex parte motions must include specific facts, statutory authority, reasons for ex parte treatment, and for adversary proceedings, irreparable injury and notice efforts.

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Applies to

Ex parte order

Ex parte orders. An ex parte order shall contain the words "ex parte" in its title.

Summary: Ex parte orders must include 'ex parte' in the title.

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Applies to

Response to motion for reconsideration ?

The opposing party shall not respond to a motion for reconsideration unless requested to do so by the court.

Summary: Opposing parties may not respond to a motion for reconsideration unless the court requests a response.

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Applies to

Objection to order ?

Any such objection shall state with particularity the reasons for the objection and shall include as an attachment an alternate order.

Summary: Objections to an order must state reasons with particularity and include an alternate order as an attachment.

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Applies to

Chapter 13 dismissal order ?

An order dismissing a chapter 13 case on motion by the debtor shall conform to Local Bankruptcy Form 13-1.

Summary: Chapter 13 voluntary dismissal orders must conform to Local Bankruptcy Form 13-1.

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Applies to

Chapter 13 dismissal order ?

If the motion is ex parte, (1) the words “ex parte” shall be added to the title of the order and (2) the debtor shall obtain the chapter 13 trustee’s authorization prior to filing the order as a received unsigned order.

Summary: Ex parte chapter 13 dismissal orders must include 'ex parte' in the title and require trustee authorization before filing.

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Applies to

Motion for sale ?

A chapter 13 debtor seeking to sell real property shall file a motion requesting approval to sell the property, the purchase and sale agreement and any amendments, and a declaration of the debtor indicating whether the sale is an arm’s length transaction for fair market value.

Summary: Chapter 13 debtors seeking to sell real property must file a motion, purchase agreement, and declaration of arm's length transaction.

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Applies to

Jury demand ?

Where a jury trial is demanded as permitted by Fed. R. Civ. P. 38, said demand shall be made, whether or not also made in a pleading, in a separate document entitled “Demand for Jury Trial”

Summary: Jury trial demands must be made in a separate document titled 'Demand for Jury Trial'.

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Applies to

Motion to seal ?

Must include

proposed order

An electronic filer who seeks to file a document under seal must file a motion. The motion to file under seal must include a specific statement of the applicable legal standards and basis, with evidentiary support in the form of declarations where necessary. A proposed order shall be uploaded through ECF.

Summary: Electronic filers must file a motion to seal with specific legal standards, evidentiary support, and a proposed order uploaded through ECF.

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Applies to

Proposed order ?

Must include

proposed order ?

A proposed form order or judgment, including one requested ex parte or by stipulation, must be filed on a document separate from its attendant motion or stipulation.

Summary: Proposed orders and judgments must be filed as separate documents from the motion or stipulation.

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Applies to

Pro hac vice application ?

The application must include: (1) a certificate of good standing from the state bar of each state in which the applicant is admitted to practice, dated within 30 days of the application; (2) a statement that the applicant is a member in good standing of the bar of the highest court of the state in which the applicant maintains his or her principal office; (3) a statement that the applicant has read and will comply with the applicable local rules; (4) a statement that the applicant has not been disbarred or formally censured by a court of record or by a state bar association; and (5) a statement that there are no pending disciplinary proceedings against the applicant.

Summary: Pro hac vice application must include a certificate of good standing and specific statements.

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Applies to

Stipulation or agreement for cash collateral or financing ?

Must include

local rule certificate ?

counsel for the debtor (or trustee) must certify whether the agreement contains any provision listed in part A, identify any such provision, and explain its justification.

Summary: Counsel must certify whether the cash collateral or financing agreement contains any disapproved provision from Part A, identify it, and explain its justification.

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Applies to

Stipulated notice

Must include

signature blocks ?

If all conditions are met, the parties may file a Stipulated Notice signed by all parties, stating as follows:

Summary: A qualifying Stipulated Notice must be signed by all parties and state the agreed deadline changes.

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Civil cases

Applies to

Pretrial order

Must include

word version

When filing the pretrial order, the parties must also send a Microsoft Word version of the proposed order, including witness and exhibit lists, to whiteheadorders@wawd.uscourts.gov.

Summary: Microsoft Word version of pretrial order must be emailed to chambers.

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Civil cases

Applies to

Jury selection ?

Must include

judge name, case number ?

The jury will consist of no fewer than seven (7) and no more than 12 members, and there will be no alternates. The Court will advise the parties at the pretrial conference how many jurors will be empaneled.

Summary: Jury will have 7-12 members with no alternates.

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Civil cases

Applies to

Jury selection ?

Must include

certificate of service ?

The Court will examine the prospective jurors using 'screening' questions to identify hardships and conflicts. (Judge Whitehead's standard screening questions can be found on his court web page). These questions can generally be answered with a 'yes' or 'no' response.

Summary: Court will use yes/no screening questions to identify hardships and conflicts.

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Civil cases

Applies to

Jury selection ?

Must include

certificate of conference ?

Following each panel, the parties may challenge for cause. Once all challenges for cause have been heard, the Court will hear peremptory challenges. Each side ordinarily has three peremptory challenges, which will be made using a 'strike sheet' in alternating fashion, beginning with the plaintiff.

Summary: Each side gets 3 peremptory challenges using alternating strike sheet, starting with plaintiff.

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Civil cases

Applies to

Jury selection ?

Must include

certificate of conference ?

Peremptory challenges must not be used to exclude potential jurors for discriminatory reasons. See Batson v. Kentucky, 476 U.S. 79 (1986).

Summary: Peremptory challenges cannot be used for discriminatory reasons (Batson v. Kentucky).

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Civil cases

Applies to

Jury instructions

Must include

certificate of conference ?

As much as possible, the parties should agree on one stipulated set of proposed jury instructions. Only true uncertainty about the binding substantive law should prevent such agreement.

Summary: Parties should agree on one stipulated set of proposed jury instructions.

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Civil cases

Deadline

5 calendar days before trial ?

Applies to

Trial exhibits

Must include

original and copy ?

The parties must deliver the original trial exhibits and one copy to Judge Whitehead’s Courtroom Deputy, Grant Cogswell, five (5) days before the trial date.

Summary: Original trial exhibits and one copy must be delivered to courtroom deputy 5 days before trial.

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Civil cases

Deadline

7 calendar days before trial ?

Applies to

Electronic exhibits ?

In addition, no later than seven (7) days before the trial date, the parties must send an electronic copy of all exhibits in PDF format with Optical Character Recognition (OCR) searchable text to Mr. Cogswell.

Summary: Electronic PDF copies of all exhibits with OCR must be sent 7 days before trial.

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Civil cases

Applies to

Deposition transcripts

Must include

typed objections, highlighted transcript, color coded designations ?

The parties must follow LCR 32(e), except that for each deponent the parties intend to offer deposition testimony instead of, or in addition to, live testimony, they must file (1) a single copy of the highlighted deposition transcript, with designations and counter designations highlighted in different colors, including typed objections

Summary: Highlighted deposition transcripts with color-coded designations required for deposition testimony.

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Civil cases

Applies to

Witness exhibit lists ?

At the close of each trial day, counsel must exchange a list of witnesses and exhibits (other than those used for impeachment of an adverse witness) that may be offered into evidence the next day. The first list should be exchanged two days before the first trial day.

Summary: Witness/exhibit lists must be exchanged daily, first list 2 days before trial.

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Civil cases

Applies to

Stipulated motion

Must include

proposed order

If the parties can reach an agreement on such a schedule and any necessary adjustments to the page/word limits, they shall submit a stipulated motion and proposed order for the Court’s approval.

Summary: Stipulated motion and proposed order required for cross-motion bundling.

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Civil cases

Applies to

Motion in limine

All motions in limine shall be submitted in a joint brief that: (1) contains an introductory statement summarizing the case and the context for any disputes, with each side drafting its own statement if they cannot agree; and (2) presents each motion under a separate heading, below which the moving party will state its position and supporting legal authority, and the opposing party will state its position and supporting legal authority.

Summary: Motions in limine must be submitted as joint brief with specific structure.

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Civil cases

Applies to

Motion in limine

Must include

proposed order ?

All motions in limine shall be submitted in a joint brief that: (1) contains an introductory statement summarizing the case and the context for any disputes, with each side drafting its own statement if they cannot agree; and (2) presents each motion under a separate heading, below which the moving party will state its position and supporting legal authority, and the opposing party will state its position.

Summary: Motions in limine must be submitted in joint brief with intro statement and separate headings for each motion.

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Civil cases

Applies to

Exhibits

The parties must deliver two copies of their respective trial exhibits to Courtroom Deputy Diyana Staples seven days before the trial date. Each exhibit shall be clearly marked.

Summary: Parties must deliver two copies of trial exhibits to Courtroom Deputy 7 days before trial.

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Civil cases

Applies to

Exhibits

In addition, no later than seven days before the trial date, the parties should send an electronic copy of all exhibits in .PDF format with Optical Character Recognition ("OCR") searchable text to Courtroom Deputy Diyana Staples at Diyana_Staples@wawd.uscourts.gov.

Summary: Electronic copies of exhibits in OCR-searchable PDF must be sent 7 days before trial.

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Civil cases

Applies to

Motion in limine

All motions in limine shall be submitted in a joint brief that: (1) contains an introductory statement summarizing the case and the context for any disputes, with each side drafting its own statement if they cannot agree; and (2) presents each motion under a separate heading, below which the moving party will state its position and supporting legal authority, and the opposing

Summary: Motions in limine must be submitted as a joint brief with introductory statement and separate headings for each motion.

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Civil cases

Applies to

Stipulated motion

Must include

proposed order

If the parties can reach an agreement on such a schedule and any necessary adjustments to the page/word limits, they shall submit a stipulated motion and proposed order for the Court’s approval.

Summary: Parties agreeing to alternate cross-motion briefing schedule must submit stipulated motion and proposed order.

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Civil cases

Applies to

Deposition designations

D. Objections to Deposition Designations

Summary: Objections to deposition designations must be filed by deadline.

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Civil cases

Applies to

Exhibits

E. Procedures for Handling Exhibits

Summary: Specific procedures for handling exhibits at trial.

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Civil cases

Applies to

Bench trial

Must include

proposed findings conclusions ?

F. Proposed Findings of Fact and Conclusions of Law Following a Bench Trial

Summary: Proposed findings and conclusions required after bench trial.

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Civil cases

Applies to

Jury instructions

Must include

proposed order ?

A. Jury Instructions

Summary: Jury instructions must be submitted electronically.

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Civil cases

Applies to

Motion ?

Must include

proposed order

Pursuant to this District's Electronic Filing Procedures, the moving party must email a Microsoft Word version of a proposed order to kingorders@wawd.uscourts.gov. Parties may not send requests for substantive relief to this email address.

Summary: Email proposed orders in Word format to specified address.

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Civil cases

Applies to

Motion

Must include

ai disclosure, proposed order, certificate of service +3 more ?

Motions for default judgment must provide sufficient information for the Court to enter judgment. Specifically: 1. The movant must establish subject matter jurisdiction and personal jurisdiction. 2. The movant must support a motion for default judgment with a declaration. 3. The movant must address the factors set forth in Eitel v. McCool, 782 F.2d 1470, 1471–72 (9th Cir. 1986). 4. The movant must separately state the amounts owing on the principal claim, liquidated damages (if applicable), pre- and post-judgment interest on the principal claim (if applicable), and reasonable attorney’s fees (if applicable). 5. The movant must provide a concise explanation of how all amounts were calculated, and must support this explanation with adequate evidence establishing the amount of the principal claim, the interest owing, the attorney’s fees, and other relevant amounts. 6. If the claim is based on a contract, the movant must provide the Court with a copy of the contract and draw the Court’s attention to the relevant provisions. 7. If an interest rate other than that provided by 28 U.S.C. § 1961 applies, the movant must state the rate and the reasons for applying it, and include all interest calculations. 8. In diversity cases, the movant must address what jurisdiction’s law applies to their substantive claims and remedies.

Summary: Motions for default judgment must include specific content requirements.

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Civil cases

Applies to

Jury instructions

Must include

proposed order, notice of electronic filing ?

Proposed jury instructions must be submitted both on the docket and in Word format via e-mail. The Court recommends the latest version of the Ninth Circuit Model Jury Instructions as the preferred proposed instructions. Instructions must comply with LCR 51 and include the parties’ proposals for both preliminary and final instructions. Instructions should be sent to kingorders@wawd.uscourts.gov and natalie_wood@wawd.uscourts.gov. The proposed instructions should also include a proposed verdict form.

Summary: Proposed jury instructions must be submitted on ECF and via email in Word format.

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Civil cases

Applies to

Trial exhibit

Must include

pre marked, clearly marked ?

All trial exhibits must be pre-marked by counsel. Each exhibit must be clearly marked.

Summary: All trial exhibits must be pre-marked and clearly labeled.

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Civil cases

Applies to

Trial exhibit

The original and one copy of the trial exhibits are to be delivered to Natalie Wood, Courtroom Deputy, seven days before the trial date.

Summary: Original and copy of trial exhibits due to Courtroom Deputy 7 days before trial.

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Civil cases

Applies to

Electronic exhibit ?

Exhibits must be delivered to the Courtroom Deputy prior to the trial date. Exhibits are to be delivered in the following format:

Summary: Electronic exhibits must be delivered to Courtroom Deputy before trial.

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Civil cases

Applies to

Proposed findings conclusions

Proposed findings of fact and conclusions of law submitted following a bench trial must contain specific references to the affidavits, declarations, exhibits, transcripts, and other parts of the record and supporting materials relied upon to support the fact described in the proposed finding/conclusion.

Summary: Proposed findings of fact and conclusions of law must cite specific record materials.

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Criminal cases

Applies to

Motion to continue

Must include

speedy trial waiver ?

All motions to continue the trial date except stipulated and unopposed motions shall be accompanied by a waiver of speedy trial beyond the proposed new trial date by the longer of (1) three weeks beyond the noting date of the motion or (2) two weeks beyond the requested trial date.

Summary: Motions to continue trial date require speedy trial waiver except for stipulated/unopposed motions.

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Criminal cases

Applies to

Motion to continue

Must include

speedy trial waiver

The Court will not grant a motion to continue a trial date that is not opposed by defense counsel’s client(s) until a speedy trial waiver has been filed.

Summary: Motion to continue trial date not granted until speedy trial waiver filed if opposed by defense.

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Criminal cases

Applies to

Trial brief

Must include

no motions in limine ?

Motions in limine contained in a trial brief that could have been brought by the pretrial motions deadline will be stricken.

Summary: Motions in limine in trial briefs that should have been filed earlier will be stricken.

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Criminal cases

Applies to

Supervised release sentencing memorandum

Must include

certificate of service ?

Each party shall file its supervised release sentencing memorandum no later than five days in advance of the evidentiary and/or disposition hearing on a supervised release violation.

Summary: Supervised release sentencing memoranda due 5 days before hearing.

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Applies to

Pleading or motion ?

Must include

certificate of no improper purpose ?

By filing a pleading, written motion, or other paper, an attorney or unrepresented party "certifies that to the best of the person's knowledge, information, and belief, formed after an inquiry reasonable under the circumstances": (1) it is not being presented for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation.

Summary: By filing, attorneys and unrepresented parties certify that the filing is not for an improper purpose.

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Applies to

Jury instructions

Must include

proposed order ?

Proposed jury instructions must be submitted both on the docket and in Word format via e-mail. The Court recommends the latest version of the https://www.ce9.uscourts.gov/jury-instructions/ as the preferred proposed instructions. Instructions must comply with LCR 51 and include the parties' proposals for both preliminary and final instructions. Instructions should be sent to kingorders@wawd.uscourts.gov and natalie_wood@wawd.uscourts.gov. The proposed instructions should also include a proposed verdict form.

Summary: Proposed jury instructions must be filed on the docket and emailed in Word format, include preliminary and final instructions, a proposed verdict form, and comply with LCR 51.

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Applies to

All ?

Must include

local rule certificate ?

The terms of this Order shall have the force and effect of orders of the Court from the date of the Order.

Summary: This Order has the force and effect of court orders from its date.

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Applies to

Motion to continue

Must include

speedy trial waiver ?

All motions to continue the trial date shall be accompanied by a waiver of speedy trial at least thirty (30) days beyond the proposed new trial date except that any defendant contesting such a motion need not file a waiver.

Summary: Motion to continue must include 30-day speedy trial waiver.

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Applies to

Motion to continue

Must include

speedy trial act calculation ?

A contested motion to continue the trial date filed by the Government shall be accompanied by a calculation of time under the Speedy Trial Act.

Summary: Government contested motions to continue must include Speedy Trial Act calculation.

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Applies to

Stipulated motion to continue ?

Must include

good cause statement ?

With respect to stipulated or unopposed motions to continue the trial date, Counsel must: a. state facts establishing good cause for the continuance.

Summary: Stipulated motions to continue must state facts establishing good cause.

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Applies to

Stipulated motion to continue ?

Must include

signed speedy trial waivers ?

file speedy trial waivers signed by the Defendant(s) with the stipulation to continue the trial.

Summary: Stipulated motions must include signed speedy trial waivers.

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Applies to

Stipulated motion to continue ?

Must include

speedy trial waiver duration ?

have Defendant(s) waive speedy trial to at least thirty (30) days beyond the requested trial date.

Summary: Defendants must waive speedy trial for 30 days beyond requested trial date.

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Applies to

Exhibit list

Must include

joint final exhibit list

A joint, final exhibit list in Microsoft Word format must be emailed to Kadya Peter, Courtroom Deputy, at Kadya_Peter@wawd.uscourts.gov five (5) days prior to the trial date.

Summary: Joint exhibit list in Word format due 5 days before trial.

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Applies to

Exhibits ?

Must include

original documents available at trial

Each Party will be responsible for having its original documents available at trial.

Summary: Parties must have original documents available at trial.

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Applies to

Equipment testing ?

Must include

equipment testing scheduled at pretrial ?

At the pretrial conference, the Parties must arrange with Kadya Peter, Courtroom Deputy, to schedule a time to test any equipment that the parties wish to use at trial.

Summary: Equipment testing must be scheduled at pretrial conference.

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Applies to

Exhibit list ?

Must include

exhibit list ?

For exhibits to be used during opening statements and the first day of trial, a list of the exhibits and demonstratives shall be emailed to the Courtroom Deputy by 5 p.m. the Friday before the first trial date.

Summary: Exhibit lists for opening statements/first trial day due by 5 PM Friday before trial

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Applies to

Exhibit list ?

Must include

exhibit list ?

Thereafter, the Parties are directed to meet at a mutually agreed upon time during each trial day to exchange a set of proposed exhibits and demonstratives to be used the following day.

Summary: Daily meeting to exchange proposed exhibits for next trial day

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Applies to

Exhibit list

Must include

exhibit list

To the extent any objections remain after this conferral, the exhibit list with all updated stipulations and objections shall be emailed to the Courtroom Deputy by 8 p.m. each day.

Summary: Updated exhibit lists with objections due by 8 PM daily

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Applies to

Revised document

Must include

clean copies, redlined version ?

If the exhibit list, pretrial order, or witness list is revised at any time after it is filed with the Court, Counsel shall promptly file the revised document with the Court and provide the Courtroom Deputy with a redlined version indicating the changes as well as replacement, clean copies of any revised or added exhibits in both electronic and physical format.

Summary: Revised documents must include redlined version and clean copies

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Applies to

Voir dire submission ?

Must include

joint submission, chart of disputed questions ?

The Parties shall file a joint submission (1) informing the Court of which voir dire questions from the Court’s general voir dire the parties wish to use; (2) providing the Court with any additional agreed-upon proposed voir dire questions; and (3) providing a chart of any disputed proposed voir dire questions that includes (a) the proposed question, (b) the objection to the proposed question, and (c) the response to the objection.

Summary: Joint voir dire submission required with chart of disputed questions

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Applies to

Voir dire submission ?

Must include

word format

In addition to being filed on the docket, all of these documents must be submitted in Microsoft Word format via e-mail to linorders@wawd.uscourts.gov and to Kadya Peter, Courtroom Deputy, at Kadya_Peter@wawd.uscourts.gov.

Summary: Voir dire submissions must be emailed in Word format to specific addresses

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Applies to

Joint instructions statement

Must include

proposed verdict form, proposed jury instructions, joint instructions statement ?

The Parties shall submit a Joint Instructions and Joint Statement of Disputed Instructions (“Joint Instructions Statement”), a proposed Jury Instructions (see https://www.wawd.uscourts.gov/judges/lin-procedures), and a proposed verdict form at least twenty-one (21) days before trial.

Summary: Joint instructions and verdict form must be submitted 21 days before trial.

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Applies to

Witness notice ?

Must include

witness list ?

The Court expects the Parties to provide notice to Opposing Counsel of their next-day’s witnesses by 8 p.m. the day before a witness is to be called.

Summary: Witness notice must be provided to opposing counsel by 8 PM the day before.

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Applies to

Witness instructions ?

Must include

witness instructions ?

Counsel shall instruct witnesses not to discuss their testimony with other witnesses, either during or after they complete their testimony.

Summary: Witnesses must be instructed not to discuss testimony with other witnesses.

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Applies to

Impeachment materials ?

Must include

copies to court, copies to witness, copies to opposing counsel ?

Where Counsel seek to impeach a witness by use of that witness’s prior deposition or other discovery materials, copies of the relevant document must be provided to the witness, the Court, and opposing Counsel.

Summary: Copies of impeachment documents must be provided to witness, court, and opposing counsel.

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Civil cases

Applies to

Pretrial order

Must include

notice of electronic filing ?

When filing the pretrial order, the Parties should send a Microsoft Word version of the proposed order to linorders@wawd.uscourts.gov.

Summary: Pretrial order must be submitted as Microsoft Word file to specified email.

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Civil cases

Applies to

Glossary

Must include

notice of electronic filing ?

The glossary must be emailed to Courtroom Deputy Kadya Peter at Kadya_Peter@wawd.uscourts.gov, in Microsoft Word format, no later than three (3) days before the start of trial. Hard copies shall also be provided to the Courtroom Deputy and Court Reporter (if any) on the first day of trial.

Summary: Glossary must be emailed in Word format 3 days before trial and hard copies provided on first day.

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Civil cases

Applies to

Trial exhibits

Must include

exhibit list ?

One physical set and one electronic set of the trial exhibits must be delivered to Judge Lin’s chambers three (3) days before the trial date.

Summary: Trial exhibits must be delivered as one physical and one electronic set 3 days before trial.

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Civil cases

Applies to

Trial exhibits ?

Must include

exhibit list ?

Each exhibit shall be clearly pre-marked by Counsel. Exhibit stickers/labels/tags can be obtained from the Clerk at the pretrial conference or from the Clerk’s Office during business hours.

Summary: Exhibits must be pre-marked and stickers/labels can be obtained from Clerk.

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Civil cases

Applies to

Trial procedure ?

Must include

witness sequestration ?

The rule on exclusion (sequestration) of witnesses will be in effect throughout the trial until the time of closing arguments and instructions. Other than Parties and their representatives, all witnesses must remain out of the courtroom except while testifying.

Summary: Witness sequestration rule in effect until closing arguments.

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Civil cases

Applies to

Trial procedure ?

Must include

witness instruction ?

Counsel shall instruct witnesses to not discuss their testimony with other witnesses, either before or after they complete their testimony.

Summary: Witnesses must not discuss testimony with other witnesses.

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Civil cases

Applies to

Settlement notice ?

Must include

timely notice

Parties shall refer to LCR 39(d) when cases scheduled for jury trial are settled (or agreed to be tried without a jury) for the requirements of providing timely notice. Failure to provide timely notice may result in the assessment of jury expenses to the Parties. See LCR 39(d).

Summary: Timely notice required for settled jury trials per LCR 39(d).

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Civil cases

Applies to

Voir dire submission ?

Must include

joint submission, neutral statement, disputed questions chart ?

The Parties shall file a joint submission with (1) agreed-upon voir dire questions from the Court’s general voir dire; (2) any additional agreed-upon sorting or general proposed voir dire questions; (3) a chart of any disputed proposed voir dire questions that includes: (a) the proposed question, (b) any objection to the proposed question, and (c) the response to the objection; and (4) a proposed joint neutral statement of the case to be read during voir dire.

Summary: Joint submission required for voir dire questions and neutral statement.

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Civil cases

Applies to

Voir dire documents ?

Must include

email submission ?

Format

DOCX ?

In addition to being filed on the docket, all of these documents must be submitted via email in Microsoft Word format linorders@wawd.uscourts.gov and to Courtroom Deputy Kadya Peter at Kadya_Peter@wawd.uscourts.gov.

Summary: Voir dire documents must be submitted via email in Microsoft Word format to specified email addresses.

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Civil cases

Applies to

Joint instructions statement

Must include

email submission ?

Format

DOCX ?

The Joint Instructions Statement, jury instruction chart, and verdict form must be submitted in Microsoft Word format via email to linorders@wawd.uscourts.gov and to Courtroom Deputy Kadya Peter at Kadya_Peter@wawd.uscourts.gov.

Summary: Joint Instructions Statement, jury instruction chart, and verdict form must be submitted via email in Microsoft Word format to specified email addresses.

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Criminal cases

Applies to

Motion to continue trial date ?

Must include

speedy trial waiver, certificate of service, certificate of conference +1 more ?

All motions to continue the trial date shall be accompanied by a waiver of speedy trial, except that any defendant contesting such a motion need not file a waiver. A contested motion to continue the trial date filed by the Government shall be accompanied by a calculation of time under the Speedy Trial Act.

Summary: Motions to continue trial date require speedy trial waiver (except contested by defendant) and Government must include Speedy Trial Act calculation for contested motions.

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Criminal cases

Applies to

Motion to continue trial date ?

Must include

speedy trial waiver, speedy trial act calculation ?

The Court generally will not grant a motion to continue a trial date until a speedy-trial waiver or calculation of time under the Speedy Trial Act has been filed.

Summary: Court will not grant motion to continue trial date without speedy trial waiver or Speedy Trial Act calculation.

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Criminal cases

Applies to

Joint motion

Must include

stipulation, joint motion ?

The Parties shall file either a stipulation (if agreement can be reached) or a joint motion explaining each Party’s respective positions (if agreement cannot be reached).

Summary: Parties must file stipulation or joint motion explaining positions if no agreement on brief length.

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Criminal cases

Applies to

Motion

Must include

proposed order

As a general rule, any motion requiring the signature of the Court should be presented along with a proposed order. See CrR 1(b)(8) (stipulated motions); CrR 12(b)(1) (pretrial motions).

Summary: Motions requiring Court signature must include proposed order.

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Criminal cases

Applies to

Proposed order

Must include

email submission, microsoft word format ?

Pursuant to this District’s Electronic Filing Procedures, the moving Party must email a Microsoft Word version of a proposed order to linorders@wawd.uscourts.gov at the time of filing. The subject heading of the email should include the case number, the case name, and the title of the motion rather than simply 'Proposed Order.'

Summary: Proposed orders must be emailed as Word document to linorders@wawd.uscourts.gov with specific subject line format.

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Criminal cases

Applies to

Stipulated motion to continue trial date ?

Must include

speedy trial waiver, good cause statement, proposed case schedule ?

With respect to stipulated or unopposed motions to continue the trial date, Counsel must: 1. state facts establishing good cause for the continuance. A request for continuance 'in order to provide the Parties more time to prepare' is not a sufficient showing to warrant a trial continuance 'in the interest of justice'; 2. file a waiver of speedy trial at least thirty (30) days beyond the proposed new trial date signed by the Defendant(s). Although not dispositive, these waivers are useful to the Court in establishing that Defendants have been consulted and agree to the requested continuance; and 3. include with the proposed order a proposed case schedule with the following deadlines: a. Expert Discovery (if applicable) b. Pretrial Motions (where possible, this deadline should be set for at least six weeks prior to the pretrial conference) c. Trial Briefs d. Motions in Limine e. Proposed Jury Questionnaire (if applicable) f. Proposed Voir Dire Questions g. Proposed Jury Instructions h. Proposed Verdict Form i. Exhibit Lists j. Witness Lists

Summary: Stipulated/unopposed motions to continue trial date require good cause statement, speedy trial waiver 30 days beyond new date, and proposed case schedule with specific deadlines.

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Criminal cases

Applies to

Voir dire submission ?

Must include

joint submission

The Parties shall file a joint submission with (1) agreed-upon voir dire questions from the Court’s general voir dire; (2) any additional agreed-upon proposed sorting or general voir dire questions; (3) a chart of any disputed proposed voir dire questions that includes: (a) the proposed question; (b) any objection to the proposed question; and (c) the response to the objection. If any Party will be proposing a jury questionnaire, the proposed questionnaire, along with a joint statement including each Party’s position regarding the questionnaire, shall be filed. In addition to being filed on the docket, all of these documents must be submitted via email in Microsoft Word format to linorders@wawd.uscourts.gov and to Courtroom Deputy Kadya Peter at Kadya_Peter@wawd.uscourts.gov.

Summary: Joint voir dire submissions must be filed via email in Word format to specified addresses.

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Criminal cases

Applies to

Joint instructions statement

Must include

joint submission, proposed verdict form ?

The Parties shall submit a Joint Instructions and Joint Statement of Disputed Instructions (“Joint Instructions Statement”), and a proposed verdict form at least twenty-one (21) days before trial. The proposed joint instructions shall contain a chart of proposed instructions (see Sample Criminal Jury Instructions Chart) and contain two sections: (1) Agreed-Upon Instructions; and (2) Disputed Instructions. Each instruction shall begin on a new page. For Disputed Instructions, the proposed and alternate instruction shall be listed one after the other, with argument and authority for the instruction not to exceed two (2) pages for each side collectively per instruction (i.e., Co-Defendants must submit only one set together). To the extent any proposed instruction relates to and modifies a Ninth Circuit Model Jury Instruction, a red-lined version of the Model Instruction must be included with the submission.

Summary: Joint jury instructions and verdict form due 21 days before trial with specific formatting requirements.

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Criminal cases

Applies to

Joint instructions statement

Must include

joint submission ?

The Joint Instructions Statement and verdict form must be submitted via email in Microsoft Word format to linorders@wawd.uscourts.gov and to Courtroom Deputy Kadya Peter at Kadya_Peter@wawd.uscourts.gov.

Summary: Joint Instructions Statement and verdict form must be emailed in Word format to specified addresses.

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Criminal cases

Applies to

Objections

Must include

stand when objecting, no speaking objections ?

“Speaking objections” in the presence of the jury will not be permitted. Counsel must stand when raising objections (unless an accommodation has been provided, see infra Section III.A and

Summary: Speaking objections not permitted; counsel must stand when objecting unless accommodated.

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Criminal cases

Applies to

Jury instruction

Must include

proposed order ?

Counsel requesting that an immediate jury instruction be given to the jury must provide the Court with the proposed text of the jury instruction.

Summary: Counsel must provide proposed text for immediate jury instructions.

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Criminal cases

Applies to

Witness procedure ?

The rule on exclusion (sequestration) of witnesses will be in effect throughout the trial until the time of closing arguments and instructions. Other than Parties and their representatives, all witnesses must remain out of the courtroom except while testifying. After completion of their own testimony, a witness may remain in or return to the courtroom but cannot then be recalled.

Summary: Witness sequestration rule in effect until closing arguments.

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Criminal cases

Applies to

Witness waiver request ?

Must include

certificate of conference ?

Counsel who desire a waiver of the rule with respect to a specific witness (for example, an expert) shall first discuss the matter with opposing Counsel and then present the request to the Court during the preliminary morning session prior to the start of trial on the particular day at issue.

Summary: Waiver requests for witness exclusion must be discussed with opposing counsel first.

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Criminal cases

Applies to

Witness instruction ?

Counsel shall instruct witnesses not to discuss their testimony with other witnesses, either before or after they complete their testimony.

Summary: Witnesses must not discuss testimony with other witnesses.

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Applies to

Motion

A motion and the legal argument supporting the motion shall be filed as a single document.

Summary: Motions must be filed as a single document with legal argument.

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Applies to

Brief

Parties who file a brief that is ten (10) pages or longer shall include a table of contents and a table of authorities (neither of which counts toward the word limit, see LCR 7(e)(6)).

Summary: Briefs 10+ pages require table of contents and authorities.

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Applies to

Motion

Must include

certificate of conference ?

Motions shall contain a certification that the Parties have met and conferred (see also Section III.G for additional requirements as to FRCP 12(b) motions to dismiss). To not count against word limits for motions, the certification shall be attached as a separate page after the signature page of the motion and shall be signed by Counsel or the movant, if pro se.

Summary: Motions require certification of conference, attached as separate page.

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Applies to

Attorney fees motion ?

Must include

certificate of service ?

All motions seeking attorney fees must be accompanied by an appropriate declaration that attaches all relevant timesheets and costs.

Summary: Attorney fee motions must include declaration with timesheets and costs.

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Applies to

Motion

Must include

proposed order

Under LCR 7(b)(1), any motion requiring the signature of the Court must be presented along with a proposed order. However, Parties are not required to submit proposed orders for dispositive motions.

Summary: Proposed orders required for non-dispositive motions requiring Court signature.

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Applies to

Proposed order

Must include

notice of electronic filing ?

Pursuant to this District’s Electronic Filing Procedures, the moving party must email a Microsoft Word version of a proposed order to linorders@wawd.uscourts.gov at the time of filing. The subject heading of the email should include the case number, the case name, and the title of the motion rather than simply, “Proposed Order.”

Summary: Proposed orders must be emailed to linorders@wawd.uscourts.gov with specific subject heading.

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Applies to

Discovery motion

Must include

verbatim recitation

Opposed discovery motions shall contain a verbatim recitation of the discovery request and objection (if any) at issue or shall attach a copy of such.

Summary: Opposed discovery motions must include verbatim discovery request and objection or attach a copy.

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Applies to

Notice of settlement

Must include

settlement in principle

For Parties who do not wish to voluntarily dismiss the action (e.g., a settlement in principle has been reached but not yet finalized) and where court approval of a settlement is not required, Parties must file a Notice of Settlement upon reaching a settlement in principle.

Summary: Notice of Settlement required when settlement in principle reached but not finalized.

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Applies to

Witness notice ?

Must include

testimony scope, witness identity ?

If the Parties intend to call witnesses at a hearing, they must submit a filing declaring their intention to do so at least two (2) business days prior to the hearing. The filing must contain the identity of each witness and the scope of the testimony.

Summary: Witness notice required 2 business days before hearing with witness identity and testimony scope.

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Applies to

Exhibit list ?

Must include

exhibit list, docket numbers for filed exhibits, unfiled exhibits must be supplied 24 hours before hearing ?

All Parties intending to introduce documentary evidence must supply a list of exhibits. For exhibits that have already been filed with the Court, the Party should clearly indicate the applicable docket number. If an exhibit has not been filed, the Party must supply the exhibit via email, in PDF format, to all relevant Parties and to the Court as soon as possible but no later than twenty-four (24) hours before the hearing.

Summary: Exhibit list and filing required 24 hours before hearing.

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Applies to

Exhibit introduction ?

Must include

counsel name for videoconference ?

When the hearing at which exhibits will be introduced will proceed by videoconference, the email to the Court must identify the full name of the Counsel who will be introducing the exhibit, so the Court may authorize the appropriate attorney to share their screen.

Summary: Counsel name required for videoconference exhibit introduction.

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Applies to

Motion

A motion and the legal argument supporting the motion shall be filed as a single document.

Summary: Motions and the legal argument supporting them must be filed as a single document.

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Applies to

Brief ?

When a Party’s briefing refers to or relies on material on the docket or attached as an exhibit, it must include pincites to such material. References or citations to such material or exhibits must include the docket and page numbers.

Summary: Briefs referring to docket or exhibit material must include pincites with corresponding docket and page numbers.

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Applies to

Motion or brief

When filing a motion or brief that cites to a ruling from a court outside this jurisdiction that is not readily available on Lexis or Westlaw (e.g., a transcript containing a bench ruling), Parties must provide a copy of the ruling to the Court as an attachment to the motion.

Summary: Motions or briefs citing out-of-jurisdiction rulings not available on Lexis or Westlaw must attach a copy of the ruling to the filing.

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Applies to

Brief

Parties who file a brief that is ten (10) pages or longer shall include a table of contents and a table of authorities (neither of which counts toward the word limit, see LCR 7(e)(6)).

Summary: Briefs of 10 or more pages must include a table of contents and table of authorities, which are excluded from word count calculations.

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Applies to

Motion

Must include

certificate of conference ?

For a motion that requires a meet-and-confer prior to filing, Parties must make a meaningful effort to meet and confer as defined by LCR 1(c)(6). For example, waiting until the expiration of a deadline, contacting the opposing Party, receiving no immediate response, and then filing the motion, does not satisfy that duty. If contact was not successfully made, Parties shall explain their specific efforts to comply with this requirement. Motions that do not comply may be summarily denied.

Summary: Motions requiring pre-filing meet-and-confer must demonstrate meaningful efforts to confer, with non-compliant motions subject to summary denial.

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Applies to

Motion

Must include

proposed order

As a general rule, any motion requiring the signature of the Court must be presented along with a proposed order. See LCR 7(b)(1). However, Parties are not required to submit proposed orders for dispositive motions.

Summary: Motions requiring the Court’s signature must include a proposed order, except for dispositive motions.

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Applies to

Stipulated protective order

Must include

local rule certificate ?

A redlined version showing deviations from the model should be attached to and filed along with any proposed stipulated protective order. See LCR 26(c)(2). If there are no differences from the model, the Parties shall include with the stipulation a certification stating as much. (Merely tailoring any of the bracketed information requested in the model order and/or providing a list of specific documents to be designated as confidential in Section 2 is not considered a change or difference from the model.)

Summary: Stipulated protective orders must be filed with a redlined version showing deviations from the district's model protective order, or a certification stating there are no deviations if none exist.

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Applies to

Motion in limine

The brief must contain: (1) an introductory statement summarizing the case and the context relevant to any dispute, with each side drafting its own statement if they cannot agree; (2) a section for agreed motions in limine in which the Parties shall list each issue and the agreement of the Parties as to that issue; (3) a section for any disputed motions in limine with a subsection for the Plaintiff’s disputed motions in limine and a subsection for Defendant’s disputed motions in limine, in which the Parties present each motion under a separate heading, below which the moving Party provides its position with supporting authority, followed by the position and supporting authority of the opposing Party.

Summary: Joint briefs for motions in limine must include an introductory statement, section for agreed motions, and section for disputed motions with separate headings and supporting authority for each party's position.

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Applies to

Motion in limine

Must include

word count, certificate of conference ?

Motions in limine that do not comply with the applicable requirements, including the certification of conferral (LCR 1(c)(6) and LCR 7(d)(5)) or the word limit (LCR 7(e)(5)), without prior permission of the Court, may be summarily stricken.

Summary: Motions in limine must include certification of conferral and comply with word limits, or risk being stricken.

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Applies to

Motion for attorney fees ?

Must include

declaration

Any motion seeking attorney fees must be accompanied by an appropriate declaration that attaches all relevant timesheets and costs.

Summary: Motions for attorney fees must include a declaration with timesheets and costs.

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Applies to

Motion to compel

Must include

certificate of conference ?

A motion to compel must strictly comply with LCR 37(a)(1) and shall include a certification that lists the date, manner, and participants of the conference.

Summary: Motions to compel must include a certification of the meet and confer conference details.

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Applies to

Opposed discovery motion

Must include

verbatim recitation or attachment ?

Any opposed discovery motion shall contain a verbatim recitation of the discovery request and objection (if any) at issue, or shall attach a copy of same.

Summary: Opposed discovery motions must include verbatim recitation or attachment of the discovery request and objection.

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Applies to

Notice of settlement ?

Must include

local rule certificate ?

When cases scheduled for jury trial are settled (or agreed to be tried without a jury), Parties shall refer to LCR 39(d) for the requirements of providing timely notice.

Summary: Parties must provide timely notice of settlement for jury trial cases per LCR 39(d).

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Applies to

Notice of multiple attorneys ?

Parties shall submit notice under this provision by issue and speaker two (2) business days prior to the hearing to Courtroom Deputy Kadya Peter by email at kadya_peter@wawd.uscourts.gov.

Summary: Notice of multiple lawyers intending to argue must be submitted 2 business days before hearing by email.

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Applies to

Witness list ?

Any Party intending to call witnesses at a hearing must submit a filing declaring their intention to do so at least two (2) business days prior to the hearing. The filing must contain the identity of each witness and the scope of the testimony.

Summary: Parties must file witness lists identifying witnesses and testimony scope 2 business days before hearing.

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Applies to

Exhibit list ?

Any Party intending to introduce documentary evidence at a hearing must supply a list of exhibits. For exhibits that have already been filed with the Court, the Party should clearly indicate the applicable docket number. If an exhibit has not been filed, the Party must supply the exhibit via email, in PDF format, to all relevant Parties and to the Court as soon as possible, but no later than twenty-four (24) hours before the hearing.

Summary: Exhibit lists required; unfiled exhibits must be emailed in PDF format by 24 hours before hearing.

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Applies to

Exhibit notice ?

Must include

notice of electronic filing ?

If the hearing will proceed by videoconference, the email to the Court must identify the full name of the counsel who will be introducing the exhibit, so the Court may authorize the appropriate attorney to share their screen.

Summary: For videoconference hearings, email must identify counsel who will introduce exhibits for screen-sharing authorization.

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Applies to

Motion

Must include

proposed order ?

Where a videoconference has been set, Counsel are required to appear via video unless they file, and the Court grants, a motion to appear telephonically.

Summary: Counsel must appear by video for videoconferences unless granted motion to appear telephonically.

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Civil cases

Applies to

Immediate jury instruction

Must include

proposed text

Counsel requesting that an immediate jury instruction be given to the jury must provide the Court with the proposed text of the jury instruction.

Summary: Counsel must provide proposed text for immediate jury instructions.

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Civil cases

Applies to

Trial evidence ?

Must include

daily conference ?

The Parties are required to confer each day following this exchange to make further stipulations and discuss any remaining objections.

Summary: Parties must confer daily after exhibit exchange to make stipulations.

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Civil cases

Applies to

Pretrial order

Must include

word version

When filing the pretrial order, the Parties should send a Microsoft Word version of the proposed order to linorders@wawd.uscourts.gov.

Summary: Parties must email Word version of proposed pretrial order to specific email address.

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Civil cases

Applies to

Trial procedures ?

To ensure that the morning pretrial hearing is productive and efficient, Counsel shall meet after the conclusion of each trial day and attempt to resolve or refine upcoming disputes.

Summary: Counsel must meet after each trial day to resolve upcoming disputes.

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Civil cases

Applies to

Trial procedures ?

The official record of all trials and proceedings will be taken by either electronic sound recording or by a Realtime reporter.

Summary: Official trial record will be taken by electronic recording or Realtime reporter.

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Civil cases

Applies to

Joint glossary

Must include

word format, email submission ?

Where necessary, Counsel shall confer and prepare a joint glossary of (1) any unusual or technical terminology that may assist the Court or jury during trial and (2) any words, technical terms, proper names, acronyms, and case citations that are likely to be used at trial but would not be found in a standard spell check. The glossary in Microsoft Word format must be emailed to Kadya Peter, Courtroom Deputy, at Kadya_Peter@wawd.uscourts.gov no later than three (3) days in advance of the start of trial. Hard copies shall also be provided to the Courtroom Deputy and Court Reporter (if any) on the first day of trial.

Summary: Joint glossary required for unusual/technical terms, emailed to Courtroom Deputy 3 days before trial.

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Civil cases

Applies to

Trial exhibits

Must include

pre marking, physical set, electronic set +1 more ?

One physical set and one electronic set of the trial exhibits are to be delivered to Judge Lin's chambers five (5) days before the trial date. Each exhibit shall be clearly pre-marked by Counsel. Exhibit stickers/labels/tags can be obtained from the clerk at the pretrial conference or from the Clerk's Office. Exhibit tags generated electronically are also acceptable so long as they list the following information: (1) Plaintiff(s)', Defendant(s)', or Joint Exhibit; (2) case number; and (3) exhibit number.

Summary: Physical and electronic trial exhibits due 5 days before trial, pre-marked with specific information.

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Civil cases

Applies to

Trial exhibits

Must include

table of contents

Both the physical and electronic copies of the trial exhibits must be accompanied by a table of contents or index identifying each exhibit. The table of contents or index must include the exhibit number and a brief description of each exhibit.

Summary: Trial exhibits must include table of contents/index with exhibit numbers and descriptions.

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Civil cases

Applies to

Exhibit list

Must include

word format, email submission ?

An exhibit list in Microsoft Word format must be separately emailed to Kadya Peter, Courtroom Deputy, at Kadya_Peter@wawd.uscourts.gov five (5) days prior to the trial date.

Summary: Exhibit list in Word format must be emailed to Courtroom Deputy 5 days before trial.

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Civil cases

Applies to

Trial evidence ?

Must include

daily deadline ?

To the extent any objections remain after this conferral, the exhibit list with all updated stipulations and objections shall be emailed to the Courtroom Deputy by 8 p.m. each day.

Summary: Updated exhibit list with objections due to Courtroom Deputy by 8 PM daily.

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Civil cases

Applies to

Trial evidence ?

Must include

exhibit chart ?

Parties must coordinate to provide the Court with a chart listing any exhibits or demonstratives expected to be used during each trial day along with any stipulations and remaining objection(s) to any exhibit(s) or demonstrative(s).

Summary: Parties must provide exhibit chart with stipulations and objections for each trial day.

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Civil cases

Applies to

Trial evidence ?

Must include

exhibit deadline ?

For exhibits to be used during opening statements and the first day of trial, a list of the exhibits and demonstratives shall be emailed to the Courtroom Deputy by 5 p.m. the Friday before the first trial date.

Summary: Exhibit list for opening/first day due by 5 PM Friday before trial.

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Civil cases

Applies to

Trial evidence ?

Must include

daily exhibit exchange ?

Thereafter, the Parties are directed to meet at a mutually agreed upon time during each trial day to exchange a set of proposed exhibits and demonstratives to be used the following day.

Summary: Parties must meet daily to exchange exhibits for next day.

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Civil cases

Applies to

Trial evidence ?

Must include

pre trial rulings ?

Unless otherwise specified, the Court will rule on the admissibility of any disputed exhibits before the start of each day of trial.

Summary: Court rules on disputed exhibits before each trial day.

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Civil cases

Applies to

Trial evidence ?

Must include

stipulated admission ?

Exhibits which the Parties have stipulate as admissible are not admitted until the Court formally admits them on the record.

Summary: Stipulated exhibits are not admitted until Court formally admits them.

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Civil cases

Applies to

Trial evidence ?

Must include

revised documents

If the exhibit list, pretrial order, or witness list is revised at any time after it is filed with the Court, Counsel shall promptly file the revised document with the Court and provide the Courtroom Deputy with a redlined version indicating the changes as well as replacement, clean copies of any revised or added exhibits in both electronic and physical format.

Summary: Revised documents must be filed with redlined version and clean copies.

Machine summary. Not checked yet.CRITICAL?

Civil cases

Applies to

Trial evidence ?

Must include

additional exhibits

If additional exhibits are marked during trial (for example, for impeachment purposes), Counsel must provide copies of the exhibits for opposing Counsel and at least two (2) copies for the Court.

Summary: Additional trial exhibits must be provided to opposing counsel and Court.

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Civil cases

Applies to

Trial evidence ?

Must include

deposition transcript ?

Pursuant to Local Civil Rule 32, if a Party intends to offer a deposition in lieu of or in addition to live testimony at trial, that Party shall provide to all other Parties a transcript of the deposition with the relevant portions highlighted.

Summary: Deposition transcript with highlighted relevant portions required per LCR 32.

Machine summary. Not checked yet.CRITICAL?

Civil cases

Applies to

Trial evidence ?

Must include

deposition conference ?

No later than three (3) days prior to the due date for deposition designations, the Parties shall meet and confer regarding any disputed deposition designations.

Summary: Parties must meet and confer 3 days before deposition designation deadline.

Machine summary. Not checked yet.CRITICAL?

Civil cases

Applies to

Trial evidence ?

Must include

joint submission ?

No later than the deadline designated by the Court, the Parties shall jointly submit to chambers for each deponent: (1) a single color copy of the highlighted deposition transcript, with typed objections and responses included in the margins of each transcript at the appropriate location; and (2) a Deposition Designations chart setting forth the objections and responses in numerical page order, in the format found on Judge Lin's Chambers Procedures page, at https://www.wawd.uscourts.gov/judges/lin-procedures.

Summary: Joint submission of highlighted transcript and designation chart required by Court deadline.

Machine summary. Not checked yet.CRITICAL?

Civil cases

Applies to

Trial evidence ?

Must include

joint filing ?

The Parties shall then file on the docket, as a single filing, a 'Joint Submission of Deposition Designations,' in which each highlighted deposition transcript and an accompanying deposition designation chart is filed as a separate exhibit.

Summary: Joint Submission of Deposition Designations must be filed as single docket entry.

Machine summary. Not checked yet.CRITICAL?

Civil cases

Applies to

Trial evidence ?

Must include

jury trial deposition ?

For jury trials: Counsel offering the deposition testimony are required to provide a person to read the designated portions of the transcript or present a video recording of the deposition.

Summary: Jury trials require person to read transcript or present video deposition.

Machine summary. Not checked yet.CRITICAL?

Civil cases

Applies to

Trial evidence ?

Must include

video deposition

If a Party intends to offer a video deposition instead of live testimony, the Party must, in addition to complying with the provisions above, submit a copy of the video deposition on a USB flash drive (preferred) or DVD to Chambers and to all other Parties no later than the deadline for filing deposition designations.

Summary: Video depositions must be submitted on USB or DVD to Chambers and parties by deadline.

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Civil cases

Applies to

Witness notice ?

The Court expects the Parties to provide notice to Opposing Counsel of their next-day’s witnesses by 8 p.m. the day before a witness is to be called.

Summary: Parties must notify opposing counsel of next-day witnesses by 8 PM the day before.

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Civil cases

Applies to

Witness exclusion ?

The rule on exclusion of witnesses will be in effect throughout the trial until the time of closing arguments and instructions. Other than Parties and their representatives, all witnesses must remain outside of the courtroom except while testifying.

Summary: Witness exclusion rule in effect until closing arguments.

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Civil cases

Applies to

Witness recall ?

After completion of their own testimony, a witness may remain in the courtroom but cannot then be recalled.

Summary: Witnesses cannot be recalled after completing testimony.

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Civil cases

Applies to

Witness exclusion waiver ?

If Counsel desire a waiver of the rule with respect to a specific witness (for example, an expert), Counsel shall first discuss the matter with opposing Counsel and then present the request to the Court prior to the start of trial on the particular day at issue.

Summary: Waivers of witness exclusion rule require opposing counsel discussion and court approval.

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Civil cases

Applies to

Witness communication ?

Counsel shall instruct witnesses to not discuss their testimony with other witnesses, either during or after they complete their testimony.

Summary: Witnesses must not discuss testimony with other witnesses.

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Civil cases

Applies to

Witness availability ?

Once the trial begins, witnesses will be put on call at the peril of the calling Party. The trial will not be recessed because a witness is unavailable except in extraordinary circumstances.

Summary: Trial will not recess for unavailable witnesses except in extraordinary circumstances.

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Civil cases

Applies to

Impeachment procedure ?

Where Counsel seek to impeach a witness by use of that witness’s prior deposition or other discovery materials, copies of the relevant document must be provided to the witness, the Court, and opposing Counsel.

Summary: Copies of impeachment documents must be provided to witness, court, and opposing counsel.

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Civil cases

Applies to

Verdict requirement ?

Counsel are reminded that, pursuant to Federal Rule of Civil Procedure 48, the verdict must be unanimous.

Summary: Verdict must be unanimous under FRCP 48.

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Civil cases

Applies to

Voir dire time limits ?

Each side (not Party) is limited to time limits set by the Court at the final pretrial conference.

Summary: Each side limited to time limits set at final pretrial conference.

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Civil cases

Applies to

Voir dire submission ?

The Parties shall file a joint submission with (1) agreed-upon voir dire questions from the Court’s general voir dire; (2) any additional agreed-upon proposed voir dire questions; (3) a chart of any disputed proposed voir dire questions that includes (a) the proposed question, (b) the objection to the proposed question, and (c) the response to the objection; and (4) a proposed joint neutral statement of the case to be read during voir dire.

Summary: Parties must file joint submission with voir dire questions and case statement.

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

Applies to

Prehearing statement ?

If more than one allegedly infringing product or process is at issue, the Party shall identify which product(s) or process(es) infringe which claims.

Summary: When multiple products or processes are accused, the Prehearing Statement must identify which claims each infringes.

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

Applies to

Prehearing statement ?

A Party claiming invalidity of a patent or patent claims must provide a list of all claims that are allegedly invalid and must briefly state the basis of each invalidity argument (e.g., obviousness, anticipation, lack of written description, etc.).

Summary: A party claiming invalidity must list all allegedly invalid claims and briefly state the basis for each invalidity argument.

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

Applies to

Prehearing statement ?

Where an invalidity argument is based on prior art, the Party shall briefly identify the prior art reference(s).

Summary: Invalidity arguments based on prior art must briefly identify the prior-art references.

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

Applies to

Joint claim chart and prehearing statement ?

The Parties shall indicate whether any witnesses are to be called at the claim construction hearing, and if so, their identities.

Summary: The parties must state whether witnesses will be called at the claim construction hearing and identify them if so.

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

Applies to

Joint claim chart and prehearing statement ?

For expert witnesses, the Party calling the expert will provide a summary of the opinion to be offered.

Summary: A party calling an expert witness must provide a summary of the opinion the expert will offer.