Pre-Motion Conference Requirements

Parties must confer with adversary before seeking TRO unless Rule 65(b) requirements are met.

Pre-motion conference required before filing motions, with specific exceptions.

Pre-motion conference requests for summary judgment motions must be made within 14 days after fact discovery closes.

Opposing party must respond via ECF (max 3 pages) within 3 business days.

Opposing party must submit response letter within 3 business days, limited to 3 pages.

Prompt motion for default judgment required when party fails to respond.

Sur-replies require prior court permission.

Opposition papers due within 30 days; reply papers due within 2 weeks.

Extensions and adjournments must be requested via letter-motion, not proposed stipulations or orders.

Two sets of pre-motion letters required for motions to dismiss.

Joint letter required within 14 days of discovery close for summary judgment motions.

Pre-motion letters required for most motions before Judge Willis except specified exemptions

Meet and confer required before filing motions or ex parte applications.

Only one Rule 56 motion for summary judgment or adjudication is allowed per party.

Parties in every case must complete a Settlement Conference or ADR procedure before the Court will hold a final pretrial conference or trial.

Reply briefs not permitted for ex parte applications.

Motion without required certification may be stricken or summarily denied.

Counsel must meet and confer in real-time per Local Rule 7-3 before filing any motion; letters/email insufficient, non-compliance may result in strike/denial.

Parties must check closed motion dates on Judge Murillo’s Procedures and Schedules Page immediately before filing a motion; no need to clear date with Courtroom Deputy first.

Replies to motions in limine are not allowed and will be stricken.

Pre-motion conference required before filing motions in limine.

Mandatory pre-filing conference of counsel required for discovery motions, with format based on opposing counsel's county location; written electronic communications cannot substitute for the conference.

Cross-motions on same issues not allowed; parties must meet and confer to decide who moves.

Pre-filing meet and confer required for all motions and disputed matters, including pro se cases; must be by videoconference or in person.

Parties' counsel and any self-represented parties must meet and confer no later than 11 calendar days before the Final Status Conference to prepare the required trial documents and binders and to make a good faith effort to stipulate.

Parties must first meet and confer on discovery issues and, if unresolved, schedule an Informal Discovery Conference with the Court Reservation System or Courtroom Assistant.

Counsel and any self-represented parties with full authority to stipulate must participate in the informal discovery conference.

Before filing the joint exhibit list, the parties must meet and confer about stipulations or objections for each exhibit.

Before scheduling an IDC, parties to a discovery dispute must confer person-to-person in real time by phone, videoconference, or in person.

Parties must meet and confer before filing any motion in limine per Local Rule 3.57.

Motions to Compel Further require an Informal Discovery Conference scheduled by the moving party, who must confer with opposing counsel to obtain three available dates and notice the court.

Parties intending to file a summary judgment or summary adjudication motion must reserve a hearing date immediately, since reservation dates fill quickly and may not be available at least 30 days before trial.

Parties and counsel are ordered to meet and confer in good faith to informally resolve discovery disputes before involving the Court.

Law and motion hearings must be scheduled through the Court Reservation System (CRS), and reserving more than one hearing date for the same motion is prohibited.

Trial counsel must hold a real-time meeting well before the final status conference regarding submission of joint trial readiness documents.

Counsel must meet and confer with opposing counsel before drafting motions in limine.

Daubert and Rule 12 pre-motion letters and responses are limited to three pages, responses are due within one week, and Rule 12 responses must address leave to amend.

For discovery or other non-dispositive motions, parties must try in good faith to resolve disputes in person or by phone before filing a motion.

Discovery motions under Rules 26-37 require an informal conference request before the motion will be heard.

In criminal cases, contemplated motions must be raised at a status conference or by a written pre-motion conference request stating grounds before filing.

Pre-motion conference required for most motions except specified exceptions.

Pre-motion conferences are required only for non-venue Rule 12 motions.

After the Rule 12 pre-motion decision order, plaintiffs have 21 days to amend as of right; amendments after that require leave under Rule 15(a)(2).

Pre-motion request letters are limited to 3 pages, and response letters are also limited to 3 pages and due within 7 days.

In summary judgment pre-motion practice, responses are due in 15 business days, 56.1 reply statements in 10 business days, and reply letters are not allowed.

Proposed summary judgment briefing schedule must be submitted within 30 days after close of discovery or the right is waived.

A party seeking a restraining order must identify a mutually agreeable hearing time with the adversary so the Court can hear from both sides before deciding temporary injunctive relief.

A party may bypass timing aspects of these practices and file within federal-rule deadlines if delay would forfeit a substantive right, but must include an explanatory basis.

Before bringing a discovery dispute to the Court, parties must first meet and confer in person or by videoconference; letters, emails, or phone calls alone are insufficient.

Moving party's counsel must confer with opposing counsel about a mutually convenient hearing date before noticing any motion.

Case management conferences are held via Zoom webinar unless noted otherwise; all other hearings are in person unless noted or leave is granted.

Motions in limine must be filed at least 14 days before the final pretrial conference; oppositions at least 7 days before; reply briefs are prohibited; argument at the final pretrial conference.

Discovery disputes require meet and confer in person or by phone before filing any discovery-related letter.

Before submitting the Exhibit List, the parties must meet and confer and attempt to stipulate to the admissibility of each exhibit.

The parties must meet and confer and agree on numeric exhibit designations.

Civil motions are heard only on Wednesdays at 9:00 a.m. in Courtroom 3, 5th Floor, 280 S. First St, San Jose, CA, by reservation only.

Civil motions require reservation for Wednesday 9:00 a.m. hearings in San Jose.

Sanctions motions under Rule 37 must follow Civil L.R. 37-4, not expedited discovery dispute procedure.

Pre-filing conferences must be attended in person; remote appearances not permitted.

Sanctions motions require compliance with meet-and-confer requirements first.

Motions to withdraw guilty/nolo pleas must be filed within 14 days of plea hearing; objections to Magistrate Judge’s R&R must be filed within 14 days of R&R execution; hearing must be scheduled within 30 days of filing.

Amicus briefs require leave by motion with the brief attached as an exhibit; party responses to amicus briefing are freely allowed.

Civil motion responses due 21 calendar days after filing; replies due 7 days after response, no sur-replies without permission.

Ex parte restraining order applications will not be considered by the Court unless all FRCP 65(b) requirements are satisfied.

Motions to Dismiss, Sever, and for Separate Trial must be specific and brought to the Court’s attention at least 30 days before jury selection.

Parties must first obtain leave of court by motion before filing a surreply or sur-surreply, and unauthorized surreplies and sur-surreplies will be struck.

For discovery/pretrial dispute letters, opposing party must submit a responsive letter of similar length; reply letters are prohibited.

Responses to dispositive and non-dispositive motions must be filed within 21 days of the motion's filing.

Letter (max 3 single-spaced pages) required to request in camera review of privilege logs; lead counsel must confer first, limited to 20 documents, one letter per party.

Motion responses due 21 days after motion filing; replies due 7 days after response; no sur-replies permitted without court leave.

Parties must discuss electronic discovery disputes in person/phone/video before seeking court intervention; resisting parties must have a person to discuss burdens.

Pre-motion letter required for discovery/scheduling dispute motions, must include nature of dispute, issues, and contested matters; lead counsel must confer before involving court.

Discovery motions require a prior discovery conference unless the movant obtains leave of Court, and the Court will strike any non-compliant discovery motion.

Failure to comply with meet-and-confer results in denial.

Before filing a sealing motion, the parties must meet and confer to agree on the narrowest possible sealing order.

Meet-and-confer required before filing sealing motions.

Mandatory meet and confer required before bringing any matter to court

Meet and confer required before filing most motions; statement of compliance required in notice of motion.

Party seeking amendment must provide proposed amended pleading and explanation to opposing counsel.

Meet and confer required before contacting court; in-person if same district, phone/video if different districts.

Joint statement of disputed/undisputed facts required 10 days before hearing, filed with reply brief.

Discovery motions may not be filed until pre-motion conference is held, unless leave of court is obtained.

Rule 26(f) conference required for civil cases to discuss discovery topics.

Motion hearing dates must be obtained from law clerk before filing; sur-replies require ex parte leave.

Landlord-tenant motions, defendants' claims of exemption, reconsideration, re-hearing, attorney's fees, entitlement, tax costs, summary judgment (except credit card/collection cases), 57.105, emergency motions, and case management or status conferences may not be scheduled for or heard on the Motion Calendar.

To coordinate a hearing, confer with opposing counsel or the self-represented litigant, then submit the notice of hearing and schedule through courtMAP once a date is coordinated.

The court will not notice hearings; the moving party must confer with the opposing party and notice the hearing under the Rules of Judicial Administration.

Motions for rehearing/reconsideration must be set on the special set calendar for at least 30 minutes.

Unilateral setting of hearings is prohibited unless Court approval is first obtained.

Before scheduling and noticing a Motion Calendar or Special Set hearing, the movant must meet and confer with opposing counsel to try to resolve the issues.

A law firm may set no more than two motions per day per office, even across separate files, and add-on hearings are not permitted.

Motion calendar hearings are scheduled through CourtMAP on Tuesday, Wednesday, and Thursday at 9:30, 10:00, or 10:30 a.m., and the moving party must first coordinate the date/time with opposing counsel based on the Court's availability.

Special set hearings must be coordinated with opposing counsel in CourtMAP and approved by Chambers, with virtual sets on Zoom, on-camera appearance for testimony, and no doubling up of time slots.

All cases must attend mediation before trial unless the judge has ruled otherwise.

Before scheduling a special set hearing, the movant must confer with opposing counsel or the self-represented litigant to coordinate a date, then schedule via CourtMAP.

A case management conference is required before trial can be set; attorneys may schedule it on CourtMAP, while self-represented litigants should call chambers.

Meet and confer required before filing most motions; declaration of conference required.

Non-compliant motions in limine may be summarily stricken without prior permission.

Opposition to extension motions due within 2 business days.

Before filing motions in limine, parties must make a good-faith meet and confer with the opposing party and comply with LCR 7(d)(5).

Joint statement (max 3 pages) required before discovery conference.

Opposition papers for 28-day motions must be filed within 21 days.

Same-day motions include stipulated, joint, unopposed motions, and specific motion types.

Pretrial motions (except dispositive) must follow LCR 37 individualized procedure.

Meaningful conferral required before filing dispositive motions with 3 business day buffer.

Parties must contact the Magistrate Judge and learn their procedures before filing opposed discovery motions in referred cases.

The Court will deny or strike a discovery motion if the parties fail to meet and confer in good faith.

Parties must note all motions, except those specifically listed in LCR 7(d)(1), 7(d)(2), 7(d)(4), 7(d)(5), and 7(o), including motions to exclude expert testimony for failure to satisfy Fed. R. Evid. 702/Daubert, for consideration no earlier than 21 days from filing.

Before filing any motion, attorneys must comply with Local Rule 2.119(B), make reasonable and diligent personal-contact attempts, and request concurrence.

Motions in limine must be heard by one week before trial unless an issued scheduling or pretrial order governs.

After a dispositive motion is filed, the Court issues a scheduling order, and the moving party must praecipe the assigned hearing date.

Objections to orders entered under the 7-day rule must be praeciped for hearing.

Parties must meet and confer on an expedited basis in good faith to resolve objections to a Confidential designation before bringing an unresolved dispute to the Court.

A party must file a motion to request an evidentiary hearing before the judge.

An attorney seeking to withdraw within 30 days of a trial or evidentiary hearing must file a motion.

Motions to enter judgment cannot be heard on return-of-judgment dates and must be noticed for regular motion call.

The Court may dismiss a motion if the moving party fails to attend the pre-motion conference.

To request an evidentiary hearing on an issue involving a factual dispute, file a motion before the Judge.

Proposed exhibits should be stipulated before trial or an evidentiary hearing; objections must be raised by formal motion and noticed by the Court’s last regular motion call before the proceeding.

A moving party’s failure to attend the pre-settlement conference may result in dismissal of the motion.

A telephone conference with Judge Wolson is required before filing any responsive brief for a discovery motion.

Sur-reply briefs may not be filed unless the Court grants leave upon a party's motion.

Reply briefs require leave of court, filed within 5 days with email courtesy copy.

Parties must attempt to resolve expert report disputes promptly; unresolved disputes must be raised via the Discovery Dispute Procedure or the objection is waived.

Discovery disputes must be presented by letter after meet-and-confer, without formal motions unless directed.

Pre-motion certification required for Rule 12 motions that opposing counsel was given opportunity to cure.

Opposition to summary judgment due in 21 days; reply/surreply due in 10 days; no leave required.

Merely reporting unavailability or reasonable efforts is insufficient; motion will be denied.

Meaningful conference required before threshold motions, except for pro se parties.

Joint Rule 26(f) report required at least one day before initial pretrial conference.

Motions that fail to meet meet-and-confer requirements will be denied.

Before filing a discovery motion to compel, lead counsel must meet and confer in good faith and the party must contact the law clerk with opposing counsel to arrange a telephone conference with the Court; the Court will decide whether further briefing is required.

Motions to modify, vacate, alter, or extend CMC orders are only heard on CMC dates, not Regular or Emergency Motion Calls.

Emergency motions require presenting a copy to court staff for approval before scheduling, and must comply with local Rule 2.2.

A piggy-backed motion may be heard on a previously scheduled date only if separately scheduled with the Case Coordinator at least one week beforehand.

Contested motions require a briefing schedule including a Clerk's Status date; Clerk's Status is held via Zoom on Wednesdays at 9:00 AM; hearing date set at Clerk's Status; motion stricken if movant fails to appear.

A motion to move a contested proceeding from a remote hearing to an in-person courtroom hearing must be heard at least two weeks before the proceeding.

Piggy-backing a motion onto an existing hearing requires prior leave of the law clerk, courtesy copies, and proper notice of the motion to all parties.

Motions to consolidate must be presented on the Presiding Judge of the Chancery Division’s calendar.

No judgment motion may be filed or noticed, and no judgment entered, until case management is stricken by the Court (4331), applying to residential and commercial properties, and noticing judgment motions before a continued case management conference is strictly prohibited.

Contested motions that are not piggy-backed must be spindled through Odyssey to obtain a presentment date and time.

Emergency motions must meet two criteria, be scheduled with the coordinator, and include specified documents submitted to the law clerk via email.

A piggy-backed motion that is not properly set and scheduled through the Case Coordinator will not be heard.

Motions must be filed with and scheduled through the Clerk of the Circuit Court to be heard.

Counsel for both sides must meet and confer to try to resolve instruction disagreements no later than 10 calendar days before trial.

The parties must meet and confer on all motions in limine before filing.

The parties must meet and confer at least seven days before the Pretrial Order is due to discuss their drafts and seek agreement where possible.

Failure to meet the telephonic-hearing requirements results in personal appearances unless the Court grants a motion for leave to appear telephonically.

Before seeking judicial intervention, a party challenging a confidentiality designation must confer directly and in good faith with the designating party, explain the basis for the challenge, and the designating party must respond within 5 business days.

Motions in limine must be thoroughly briefed; the Court will set a briefing schedule.

Parties must conduct Rule 26(f) planning conference.

Motions in limine must be filed with the pretrial order or on a court-specified date, and the parties must meet and confer before filing them.

Replies may not be filed unless the Court orders otherwise.

Parties challenging confidentiality designation must confer directly with designating party in good faith before judicial intervention.

Substantial exhibit objections must be filed as motions in limine.

Counsel primarily responsible for representing each party at the settlement conference must participate in the status hearing or call.

Sur-reply papers and motion practice by correspondence are prohibited without express permission from the Court.

A discovery-dispute motion may not be filed until a pre-motion conference has been requested and held as required.

No motion concerning the underlying residential foreclosure action may be filed with the RJI or while the action remains pending in the FSCP.

Before filing a discovery motion, counsel must make a good-faith effort to resolve the dispute and must then notify the court by a letter of no more than three pages describing the dispute and resolution efforts.

A preliminary conference must be scheduled if no acceptable executed stipulation is timely uploaded or if a party requests one.

A motion challenging the Note of Issue or trial readiness may not be filed until a pre-motion conference has been requested and held.

A discovery-related motion, including a discovery-violation dismissal motion or cross-motion, may not be interposed or electronically filed until a pre-motion conference has been requested and held.

Cross-petitions may not be filed without the Court’s permission.

The Court must address a properly submitted pre-motion conference request within two business days after receiving a complete submission.

A motion filed before the required pre-motion conference may be denied unless good cause justifies obtaining relief before the conference.

A party seeking a motion must file and upload through NYSCEF a pre-motion conference request on notice to all other parties that states the anticipated motion’s basis and is no more than two pages.

The MDPM Part must give NYSCEF notice of the conference date and time, and the conference ordinarily must be held in person unless another format is designated.

Juvenile motions must be in writing, be heard before jeopardy, and ordinarily be heard at least five court days after notice unless the Court orders otherwise; the moving party must clear the hearing date with the juvenile court clerk before filing.

A party invoking the identified privilege or good-cause discovery exception must proceed by noticed motion heard before the first readiness conference.

Except in domestic-violence cases, parties must meet before a Request for Order hearing to discuss all issues, attempt settlement in good faith, and exchange relevant hearing materials.

A request for relief from the governing rules must be submitted to the Court with a showing of good cause before the relevant papers are filed.

Juvenile motions must be written, heard before jeopardy and, absent a contrary court order, at least five court days after notice; the moving party must clear the hearing date with the juvenile-court clerk before filing.

Parties in the listed Civil and Probate Departments must participate in the Discovery Facilitator Program before filing a motion to compel discovery, including under CCP Section 1987.1, unless an exception applies or the Court orders otherwise.

A party invoking a statutory privilege exception or a good-cause discovery exception must proceed by noticed motion and have it heard before the first readiness conference.

Except in domestic violence cases, parties must meet before the hearing on a Request for Order to discuss issues, attempt settlement, and exchange relevant documents and information.

Except in domestic-violence cases, parties must meet before the Request for Order hearing, discuss all issues, attempt settlement in good faith, and exchange hearing materials.

Except in domestic-violence cases, parties must meet before a Request for Order hearing, make a good-faith settlement attempt, and exchange relevant hearing materials.

For writs of mandate other than those naming the Department of Motor Vehicles, the filing party must provide the petition and proposed order to the assigned department and obtain a status conference establishing the hearing date and briefing schedule.

A party asserting a work-product or other privilege exception, or a discovery exception based on good cause under the cited Penal Code provisions, must proceed by noticed motion heard before the first readiness conference.

Discovery motions require a pre-motion conference procedure: file a motion for teleconference, then submit a 3-page letter with proposed order and exhibits at least 72 hours before the conference.

Discovery motions require a pre-motion conference; must file a Motion for Teleconference before filing a discovery motion.

Rule 56 motions must be filed within 10 days of deadline without leave.

Letter filing deadline: 72 hours before conference, max 4 pages, double-spaced, 12pt font

Responses to discovery motions are due within 3 days absent a court order.

Counsel must confer, agree on proposed protective order, and submit within 10 days of this Order; if no agreement, follow Paragraph 3(g).

Oppositions to pro hac vice motions must be filed within one business day of the motion's filing.

Pre-conference letter sequencing: moving party files 72 hours before conference, opposing party may file 48 hours before conference.

Discovery motions must follow meet-and-confer procedures or be denied.

Motions to strike must be accompanied by a 3-page letter, not an opening brief.

Absent a case-specific order, responses to pre-trial or post-trial motions are due in 21 calendar days, and any reply is due 10 calendar days after the response.

Meet and confer required 3-2 weeks before claim construction hearing to file Amended Joint Claim Construction Chart.

A discovery motion requires a prior pre-motion conference request and good-faith efforts to resolve the dispute, unless the Court directs otherwise.

Before involving the court or filing a discovery motion, parties must meet and confer through a genuine exchange rather than a one-sided letter or threat.

A request for a discovery-related conference must use the Pre-Motion Discovery Conference Request Form and be emailed to chambers.

Absent extremely unusual circumstances causing significant prejudice, opponents must receive at least 24 hours' advance notice of an OSC seeking a TRO or other emergency relief and be told of the right to be heard.

Counsel must make every effort to resolve discovery disputes with the opposing party before engaging in discovery motion practice.

A discovery motion may not be submitted unless the required conference has occurred.

Motions and orders to show cause ordinarily are decided on the filed submissions without oral argument unless the court directs otherwise.

A cross-motion set beyond the original motion's return date does not adjourn the original motion.

No discovery motion may be filed or served without prior written permission from the court.

Before filing a motion, the moving party generally must serve written notice stating the intended motion and requested relief and offering a good-faith attempt to resolve the matter, subject to emergency and significant-prejudice exceptions.

Before making or filing any motion, moving counsel must arrange a conference call with the opposing party and the Court to discuss the issues and possible resolution.

Before filing any discovery motion in this part, the requesting party must submit the pre-motion discovery conference form and confer with the court about the matter.

A mandatory meet-and-confer, including in matters involving pro se litigants, must occur before requesting a hearing on unresolved issues.

Before filing a Rule 1.380 motion to compel seeking attorney’s fees, counsel must confer in good faith with opposing counsel and any pro se parties to resolve the discovery issue.

Counsel must confer in good faith before a hearing, and failure to do so may result in cancellation, summary denial, or sanctions.

Before seeking disposition of a filed motion, counsel with settlement authority must complete a meaningful in-person or telephone conference under Administrative Order 2012-03-01.

Before a Motion in Limine is set for hearing, counsel—not support staff—must confer with opposing counsel by telephone or in person concerning every evidentiary matter raised.

Discovery motions must be set for hearing, submitted with an agreed order, or submitted under Section A(4)(b); merely filing the motion is insufficient.

A party may not file a discovery objection without an accompanying motion.

Before filing any motion, the moving party must confer with opposing counsel in a good-faith effort to resolve the motion and file a certification of the conference and lack of agreement.

Filing a protective-order motion without attempting to obtain an immediate hearing does not by itself protect against pending discovery.

Failure to comply with the meet-and-confer requirement may result in the court declining to consider the motion.

Discovery motions, motions to compel, and motions for protective orders must be filed and set for hearing within a reasonable period.

Before setting an ex parte or short-matter hearing, satisfy the Administrative Order 2012-03-01 meet-and-confer requirement and include a Certificate of Compliance in the notice of hearing.

A discovery motion may not be filed unless the party complies with 22 NYCRR §§ 202.7 and 202.20-f.

A discovery motion requires a prior court conference, a written request of no more than two pages stating the meet-and-confer history and basis for the motion, and any response must be filed within two business days and may not exceed two pages.

A request for pendente lite relief will be addressed only at the preliminary conference and must be accompanied by a motion.

No discovery motion may be filed without the express permission of the court.

Before presenting an OSC seeking a temporary restraining order or other interim relief, the movant must contact the Part Clerk to obtain a date and time, except for ex parte order-of-protection applications.

A party may not argue for denial of summary judgment solely based on failure to negotiate and file a joint statement of facts.

When a matrimonial OSC is filed before a preliminary conference is scheduled, the conference will occur on the OSC return date, counsel must appear with clients, and counsel must confer and comply with the cited rule beforehand.

In matrimonial cases, a preliminary conference must be held within 45 days after filing the Request for Judicial Intervention.

CPLR 3213 motions do not require a joint statement, and competing Rule 19-a statements may not be submitted for them.

Surreply papers will not be accepted without leave of court.

A party seeking immediate injunctive relief when an OSC is signed must appear in person with all affected adversaries or prove proper notice, and must contact the part clerk to schedule the appearance.

An unauthorized discovery motion or one lacking demonstrated good-faith efforts will generally be denied, and email alone is insufficient to establish those efforts.

Parties must request a conference before filing any discovery motion.

The court will schedule an in-person appearance for every compliant discovery motion, while a noncompliant discovery motion will be denied without prejudice.

No motions in this Part may be submitted without oral argument, and every motion must be orally argued without exception.

Parties should resolve discovery disputes through informal procedures and must seek a court conference before filing any discovery-related motion.

Before filing a discovery-related motion, counsel must make good-faith efforts to resolve the dispute and then seek a conference with the Court.

When court intervention is necessary after a good-faith discovery effort, the parties must file an NYSCEF letter requesting an in-person discovery conference and briefly describe the issue.

Each discovery action must include a preliminary conference and compliance conference, additional status conferences as needed, and the parties must consult before each such conference.

When good-faith efforts fail to resolve a discovery dispute, the parties must apply for a pre-motion conference addressing the dispute and related discovery issues.

Email exchange alone is insufficient unless the affirmation documents the communication history or the other party’s refusal to communicate by telephone, virtually, or in person.

A discovery motion filed without a prior Rule 14 Conference will be held in abeyance until the conference occurs.

Before filing a discovery motion, a party must request a pre-motion conference by filing a letter request to NYSCEF and emailing it to the listed chambers address.

All motions must be brought by Order to Show Cause, and parties must request a conference before filing motion papers; good-faith consultation with one another is strongly suggested.

Before seeking court involvement in a dispute, parties must personally consult and make a good-faith effort to resolve it; email does not qualify, and possible resolutions should be discussed before the hearing.

The Court may permit full briefing under Rule 26(d)(1), but parties may not undertake full briefing without advance permission.

Discovery and disclosure disputes that could be addressed under Rules 26(c) or 37(a) must first follow Rule 26(d)’s expedited procedure.

A trial date will not be set until ADR or mediation, discovery, and dispositive motions are complete; if they are incomplete before the trial-setting conference, the parties must seek to vacate and reset it.

The Court will not schedule, reschedule, or vacate a hearing without a filed motion.

Before seeking a motion to compel, parties must make every effort to confer in good faith, including speaking by telephone; correspondence alone is insufficient except in extraordinary circumstances.

Counsel must make a good-faith effort to resolve discovery disputes and demonstrate that they met and conferred before bringing the dispute to the Court.

Before asking the court to resolve a dispute, parties must personally consult or meet and confer in good faith; email alone does not qualify as personal consultation.

Before seeking court involvement in a discovery dispute, parties must satisfy applicable personal-consultation requirements and make a good-faith effort to resolve the dispute; email does not count as personal consultation.

Before submitting a discovery dispute, parties are expected to confer in good faith through an actual conversation, not merely exchange voicemails or emails.

Counsel must make a good-faith effort to resolve discovery disputes before bringing them to the Court.

The parties should discuss possible resolution of issues before the hearing.

The moving party must meet and confer with opposing counsel or the opposing side before setting a hearing.

Substantive motions and requests will not be heard at Calendar Call without specific permission from the Court.

Court-set pretrial conferences must be attended by the parties or counsel; failure to attend results in sanctions.

The moving party must coordinate with opposing counsel or the opposing side before setting a Motion Calendar hearing.

For special set hearings (15 minutes or longer), the motion must first be filed with the Clerk of Court, and chambers does not accept ex parte communication.

A law firm, including all affiliated attorneys, may not set more than two motions on a single day unless the motions involve separate cases.

Motions for rehearing must not be set for hearing unless the Court instructs the party to do so.

Calendar Call is limited to trial readiness and negotiated pleas; no other substantive motions or requests will be heard at Calendar Call without specific permission from the Court.

Motions for summary judgment must be scheduled for hearing and heard prior to Calendar Call.

Unless a new lawyer is substituting, a motion to withdraw must be set for a UMC hearing with notice to all parties.

Motions subject to legal sufficiency review (e.g., suppress, dismiss, post-conviction) must be provided to the Court before a hearing is set, and the Court may rule on sufficiency before setting any hearing.

Parties must attend mediation before setting any temporary relief matter for an evidentiary hearing.

Before requesting a special-set hearing, the motion must be docketed, availability must be cleared with interested parties, and an email request must be sent to the Division.

A motion requiring an evidentiary hearing cannot be decided without holding that hearing.

Motions for rehearing, clarification, or new trial must not be set for hearing unless the court directs otherwise.

Counsel must make reasonable efforts to communicate in person or by telephone and pursue reasonable compromises to resolve or narrow disputes before seeking court intervention.

Before filing and serving a notice of hearing, the noticing attorney must attempt to resolve the matter and certify that the attempt was made in good faith.

A Notice of Hearing may be filed only after the moving party receives the Judicial Assistant's confirmation email containing the hearing date and time.

Within 45 days after the entitlement determination, the parties must confer item by item about disputed fees and costs and attempt to resolve the dispute through good-faith negotiations.

Every Daubert motion must be scheduled and heard before trial begins.

Email or other written communications may be used, but if they do not resolve the matter, counsel must make reasonable efforts to speak in person or by telephone before filing and serving the notice of hearing.

The parties and their experts must hold a remote conference to discuss the specific fee and cost objections no later than five days before Calendar Call.

Before setting a matter on the motion calendar, the noticing party must attempt to resolve it and certify the good-faith attempt.

Failure to make a good-faith resolution attempt may result in the motion being stricken or sanctions being imposed, although the court may waive the requirement in appropriate circumstances.

Parties must make a good faith attempt to resolve discovery disputes before seeking court intervention.

Before seeking dismissal of indirect or willful infringement claims before fact discovery, a party must meet and confer about dismissing the allegations without prejudice.

Additional briefing beyond motion/response/reply requires a motion for leave.

Scheduling matters in civil cases must be requested by motion.

The parties must meet and confer before filing a motion to seal documents.

Before filing a motion to compel discovery, lead counsel must meet and confer in good faith and the party must contact the Court’s law clerks to summarize the dispute and the parties’ positions.

Meet and confer required before dismissing indirect/willful infringement claims.

Motion to compel requires meet and confer plus contact with law clerk

Before an early motion to dismiss indirect or willful infringement claims, the movant must first meet and confer with the opposing party.

Leave of court is required to file a sur-reply.

Transfer motions have fixed filing and briefing deadlines, and late filing requires good cause plus leave of court.

Witnesses must testify remotely via motion filed at least 7 business days prior, with equipment testing and technical support coordinated.

Pre-motion letter must include basis and citations.

Before filing specified motions (dismiss, more definite statement, strike, remand, venue change, compel arbitration, judgment on pleadings), a party must submit a 3-page single-spaced pre-motion letter stating the basis and citations; adversaries respond within 7 days (max 3 pages); no reply letters or affidavits/exhibits unless directed by the Court.

Discovery motions require leave of Court; parties must first meet and confer in person, via video, or by telephone (email exchanges are insufficient) to resolve discovery disputes.

Pre-motion letter (max 3 single-spaced pages) required before specified civil motions; adversaries have 7 days to respond (max 3 pages).

A pro hac vice application without consent must be filed as a formal motion.

Subpoena enforcement/quash motions involving third parties exempt from meet-and-confer but require leave of Court.

TRO requests require prompt hearing and pre-hearing conference.

Formal motions require prior leave from the court, except for Rule 12 motions, timely remand motions, and those expressly permitted.

Formal motions require prior leave from court except for Rule 12 motions, timely remand motions, and those expressly permitted.

Formal motions require prior leave of Court except Rule 12 motions, timely remand motions, and motions expressly allowed by the Case Management Order.

Party anticipating expert exclusion argument must raise issue to Court to determine motion filing timing relative to summary judgment.

Parties must file a pre-motion letter for summary judgment motions before filing and before setting briefing schedule, with a status/settlement conference, exempting pro se cases.

Parties must meet and confer before filing a motion in a civil case.

A pre-filing conferral must involve a substantive, good-faith conversation in person, by telephone, or through communication technology; an exchange of ultimatums is insufficient, and any assertion of failed conferral must detail at least three attempts during the preceding month.

Before moving for an order relating to discovery, the movant must request a conference with the court.

Before filing a discovery motion or scheduling a hearing, the parties must confer in person or by communication technology and make a good-faith effort to resolve the dispute by agreed order.

Counsel for both parties must meet no later than 12 days before the summary judgment hearing to confer, prepare the hearing stipulation, review the record, and narrow issues, and moving-party counsel must schedule the meeting.

Pleadings may not be amended after the final pretrial conference without court approval.

Any timing issue identified in the stipulation must be raised in an appropriate written motion filed and heard before the summary judgment hearing.

Before filing a motion to compel discovery, the moving party must confer in good faith with the non-moving party to attempt to resolve the dispute.

Parties must meet and confer before filing any motion.

A claim that opposing counsel was unavailable does not excuse the conference; the motion must describe attempted conference, the moving party must promptly contact opposing counsel after filing and supplement the motion, and non-moving counsel must promptly respond and provide conference availability.

Counsel must conduct a substantive meet-and-confer before scheduling a hearing on motions in Circuit Civil Division F, subject to the listed motion-type exceptions.

A mandatory meet-and-confer process is required before scheduling a hearing on most motions, with exceptions for specified motion types.

The motion must be filed before setting a hearing.

Parties must consult with each other about an emergency hearing matter, preferably through lead counsel.

A motion will not be set for oral hearing without an estimated hearing time.

Before the Court considers a motion requiring a conference, the movant must confer directly and person-to-person with opposing counsel.

Default judgment motions based on unpaid assessments or deed restriction violations must be set for oral hearing.

Default judgment motions based on unpaid assessments or deed restriction violations must be set for oral hearing.

Emergency hearings are granted only if the parties have conferred about the matter.

Motions to compel and other discovery-dispute motions must be set on the oral hearing docket.

Parties must confer before filing a discovery motion to attempt resolution without court intervention.

Oral hearing is required only for expedited foreclosure default judgments; other default judgments may be set for submission.

Excess proceeds hearings are set for Tuesdays at 3:00 PM and require an appearance.

Motions to withdraw as counsel must be set for oral hearing unless the client agrees and signs an acceptance of the notice letter.

The parties must meet and confer at least 21 days before the pretrial conference, and no party may file a motion in limine without first making a good-faith effort to resolve or narrow the evidentiary issue.

After responsive papers are filed, the moving party must arrange a pre-hearing meet-and-confer, personally or by telephone, and all parties must negotiate in good faith; harassment and domestic-violence matters are exempt, and noncompliance may result in attorney’s fees or sanctions.

Before the hearing of any motion, petition, or application other than a pro hac vice application or a motion to withdraw as counsel, counsel and pro se persons must confer in good faith to try to eliminate or narrow the hearing.

Except for pro hac vice applications and motions to withdraw counsel, counsel must hold a good-faith conference at least three calendar days before the hearing and submit a declaration describing the conference and agreements at least one day before the hearing.

The party preparing a written order must make a good-faith effort to confer with the other parties before submitting it to the court.

A party may not file a motion in limine without first making a good-faith effort to resolve or narrow the evidentiary issue with the opposing party.

The parties must meet and confer at least 35 days before the Pretrial Conference to determine whether evidentiary issues can be resolved by stipulation.

Unless the Court orders otherwise, counsel and pro se persons must meet in person or by video, and the parties must participate in an informal discovery conference before filing any discovery motion if the dispute is unresolved.

A party must make a good-faith effort to resolve the evidentiary issue with the opposing party before filing a motion in limine.

The parties must meet and confer no later than 21 days before the pretrial conference to determine whether evidentiary issues can be resolved by stipulation.

Before filing a motion in limine, parties or counsel must meet and confer in good faith to attempt to reach a stipulation, preferably through an in-person meeting, telephone call, or video conference; exchanging letters, emails, or voicemail is insufficient.

The parties must begin meeting and conferring well before trial as part of Judge Fineman's pretrial process.

A movant must confer in good faith with the opposing party or counsel to resolve the motion’s issues and file the required detailed certification or face denial without prejudice and cancellation of the hearing.

Represented parties must complete the required Rule 1.202 conferral before filing a motion unless exempt.

All motions must be heard before the pretrial conference.

If requested, counsel must agree to the filing of an amended complaint instead of filing the motion.

Mediation is required before a motion for summary judgment may be scheduled unless the court grants prior leave to proceed.

Attorneys and parties must make genuine good-faith efforts to resolve discovery disputes before filing a motion to compel.

Before filing a motion, the moving party must confer with opposing counsel in a good-faith effort to resolve it and file a certification that the conference occurred without agreement.

A written motion must be filed with the Clerk before requesting or setting a hearing.

Pretrial motions generally must be written and heard before the pretrial conference unless otherwise specified.

A written motion should be filed before requesting a motion-hearing date and time from the judicial assistant.

Before filing a motion to dismiss for failure to state a claim, counsel must give written notice, identify the alleged reasons, and stipulate to an amended complaint if requested.

Attorneys and self-represented parties must attend a case management conference unless the court excuses them in advance.

When a TRO is requested, the Court schedules a conference with counsel before any formal hearings, and all counsel must attend unless urgency precludes notice to opposing counsel.

Upon a TRO request, Judge Hardy schedules a conference as soon as counsel have appeared, requires all counsel to attend unless urgency precludes notice, and rarely grants ex parte TROs.

Civil matters on the Thursday Chambers Calendar are decided without oral argument only after being fully briefed, and prevailing counsel must prepare the written order per EDCR 7.21.

Counsel must meet and discuss exhibits per EDCR 2.67, ensure exhibits comply with EDCR 2.27, and attend the Court-set pre-trial conference during the week before trial.

The EDCR 2.47 conference between counsel must occur at least one week before motions in limine are filed.

Remote appearances are not allowed for arraignments, calendar calls, and sentencing without the Judge's prior approval.

A Rule 2.47 conference between counsel must be held at least one week before filing motions in limine.

Hearing Calendar matters (Prove Ups, Preliminary Injunctions, TROs, Show Cause Hearings, certain Petitions) require prior approval from the Judicial Executive Assistant and/or Judicial Law Clerk, are scheduled Tuesdays at 10:00 a.m., and are coordinated through Master Calendar.

Counsel must meet and discuss exhibits prior to calendar call, and the plaintiff is responsible for scheduling the EDCR 2.67 conference.

Counsel must appear in person for Motions to Dismiss and Motions for Summary Judgment; remote appearances are not permitted.

All matters must be set on the Department’s regular motion calendar.

Rule 16 conferences are mandatory and held from chambers with email notice to all parties, but counsel may request an in-person conference, which will be placed on the regular Civil Law & Motion calendar.

A motion to quash a bench warrant issued on or before the trial date must be scheduled before the Chief Criminal or Chief MRJC Judge, and the defendant must be present or the motion will not be considered absent extraordinary circumstances.

Before motions to compel discovery or for contempt, counsel must hold a meet-and-confer conference in person or by telephone — email is not a substitute.

Motions with oral argument (summary judgment, restraining orders, preliminary injunctions, and class certification) are heard on Fridays in one-hour calendar slots.

Motions set for oral argument must be confirmed with the bailiff.

To schedule a dispositive motion hearing with oral argument, parties must first check with opposing counsel and then email the bailiff with the case name, cause number and type of hearing requested; hearings are set on Friday mornings with typically an hour for argument.

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

Counsel must give advance notice to the court and opposing counsel before presenting a motion for an exceptional sentence.

Parties must confer with opposing counsel to confirm date availability before scheduling any hearing.

Dispositive motions are heard on Fridays, and parties must check with opposing counsel/party to confirm a mutually agreeable hearing date before scheduling.

Follow KCLR 7 when setting motions without oral argument; the court considers non-dispositive motions without oral argument.

Parties should confer with opposing counsel before confirming a hearing date to ensure it is mutually agreeable.

A scheduling party should consult the opposing party or counsel before contacting the court.

A temporary restraining order for another justice will be signed only with that justice's or law clerk's approval.

An Order to Show Cause is available only for genuine urgency, a required stay, or a statutory mandate; otherwise, relief must be sought by a Notice of Motion under CPLR § 2214.

An Order to Show Cause will be granted only for genuine urgency, when a stay is required, or when required by statute.

Discovery motions require prior consultation with the law clerk, including an initial email copying opposing counsel and describing the dispute, before the law clerk determines whether a conference or motion practice is required.

A temporary restraining order in a case assigned to another Justice may be granted only with prior approval from the IAS Justice or the IAS Justice’s law clerk.

Sur-reply papers and merit-addressing correspondence are prohibited without advance express permission from the Court and will not be considered.

An in-person preliminary conference must be scheduled within 45 days of receipt of the RJI, with pleadings and an emailed case summary submitted before the conference.

Unless the Court orders otherwise, motions for summary judgment must be timely made under CPLR §3212(a).

Discovery-dispute motions will not be scheduled until the underlying issues have been conferenced with Justice Martoche or Michael Pastrick.

A discovery motion filed before a Teams or phone conference is scheduled will be denied upon submission without oral argument.

A civil motion ordinarily is heard on the matter's scheduled return date unless an earlier hearing date is required.

All motions will ordinarily be decided on the submitted papers.

All Motions for Summary Judgment filed in the 37th District Court are heard in the 37th District Court rather than in Presiding Court.

Each MTE hearing is limited to 15 minutes.

Hearings on these motions must be set per local rules at 8:30 a.m. for non-evidentiary matters or 9:00 a.m. for evidentiary matters.

Before requesting a hearing, counsel must confer with the opposing party about the dispute, with a minimum of three legitimate conferral attempts required on non-emergency issues.

Parties must meaningfully confer before an MTE hearing, including exchanging the proposed order and proposed changes, or risk the MTE being reset or being ordered to confer in a Zoom breakout room.

All hearings before a Visiting Judge must follow these procedures and must be assigned by the Presiding Judge.

Only motions to enter, to reconsider, to clarify, for new trial, and to set aside an order may return to the Visiting Judge who originally ruled the matter.

Attorneys and self-represented litigants must confer before requesting any hearing regarding both the subject of the hearing and available dates and times, and this requirement is enforced.

The parties and all agents with settlement authority must attend mediation unless the Court grants leave excusing attendance.

The parties have 30 minutes total to present and respond to a summary judgment motion at the hearing.

Before setting any MTE, parties must contact the court for available dates and confer with the opposing pro se party or counsel on those dates before filing the setting.

No jury trial may be held until all contested issues have been referred to mediation, which is discretionary, may be requested by the parties, and for which the Court will appoint a mediator if the parties cannot agree.

Counsel with settlement authority must confer before hearing scheduling, include a Certificate of Compliance in the Notice of Hearing, and the counsel scheduling the hearing is responsible for arranging the conference.

Counsel must confer in good faith, certify the unresolved conferral, and attach the correspondence before filing a motion to compel or for a protective order; email alone is insufficient, and noncompliance may result in striking the motion.

All motions must be submitted to the Sumter Clerk of Court and conferred upon between the parties before hearing time may be requested.

The second compliance option requires a certificate stating that a lawyer with settlement authority made good-faith attempts to contact opposing counsel in person or by telephone before the motion was noticed for hearing.

A mandatory meet-and-confer process applies before scheduling a hearing on motions in the circuit civil division, except for the listed motion types.

The first compliance option requires a certificate stating that a lawyer with settlement authority had a substantive pre-hearing conversation with opposing counsel but could not resolve the motion.

Counsel must meet and confer after filing and serving the detailed Daubert motion, and file a certification of that meeting by the Notice of Hearing.

All unstipulated motions in limine must be filed in accordance with the Court's motion practice procedure order.

Counsel must obtain Court approval and contact the Judge's office before cross-noticing additional motions for a previously scheduled hearing.

Counsel—not support or paralegal personnel—must confer by telephone and/or in person on every requested motion in limine before the court sets it for hearing.

The parties must confer and attempt to resolve by agreement the issues raised in their in limine motions.

Before filing a discovery-dispute motion, attorneys are expected to attempt to resolve the dispute without court intervention.

Objections to Rule 30(b)(6) topics must be resolved through conference or hearing before deposition.

Discovery motions (compel, protective order, sanctions) require Court authorization.

Personal conferral (in person/phone) required unless opposing party refuses after reasonable time; moving party must advise court of refusal.

Failure to confer in good faith is an independent basis to deny discovery motion relief; opposing party's failure to confer is considered for fee awards if motion is granted.

Parties must confer in good faith before seeking discovery relief, with at least one personal communication (in person, videoconference, or telephone).

Sanctions motions must be filed in writing and cannot be resolved via Informal Discovery Hearing.

Non-compliant discovery motions will be denied.

Discovery motions require good-faith conference certification and have expedited briefing with shortened page limits.

No hybrid hearings - all counsel must participate via same method (Zoom or in-person).

Discovery disputes must be resolved through conference before filing motions; sanctions may be imposed for bad faith.

Informal Discovery Hearing procedures do not apply to written discovery motions.

Parties must meet and confer within 21 days of defendant's response.

A party must request an informal discovery conference with the court before filing a discovery motion.

Before filing any discovery motion, the moving party must schedule a discovery conference with all parties and the Court.

Scheduling an Informal Discovery Conference stays the deadline for filing discovery motions in complex civil matters.

Before the IDC, the parties must meet and confer to impasse by phone or videoconference; the moving party must coordinate the meeting, and the opposing party must respond to a scheduling attempt within three business days.

The discovery conference order excludes self-represented discovery disputes, expert discovery disputes, and motions to compel discovery when no responses have been provided, while all other discovery disputes, including motions to quash, are covered.

For pending motions, all counsel and unrepresented parties must make a good-faith meet-and-confer effort, and the moving party must arrange the conference no later than four calendar days before the hearing.

Before the informal discovery conference, the parties must meet and confer to impasse by phone or videoconference, with the moving party coordinating it and the opposing party responding to scheduling attempts within three business days.

Informal discovery conferences are required except in self-represented matters, expert discovery, and motions to compel filed where no responses were provided.

For discovery motions, the moving party must schedule a video informal discovery conference with all parties and the court within five court days after filing and before any opposition is filed, except for the categories excluded by the order.

The propounding and responding parties must participate in the discovery conference by telephone.

Briefing is prohibited at an IDC, but counsel should jointly or separately lodge a one-page statement of disputed issues in Department S-17 by the day before the conference.

Before filing any discovery motion, the moving party must schedule a telephonic informal discovery conference with all parties and the Court.

Oppositions to extension motions must be filed by 5:00 p.m. the business day after the motion is filed.

Pre-motion conference required for dispositive motions; 4-page notice and 1-week response required.

Motions in limine must be filed by a specified date, with responses and replies due on specified dates.

Court leave is required before filing any discovery motion; failure to comply may result in the motion being stricken.

Discovery-related motions require a prior telephone conference with the Court and opposing counsel.

Discovery motions require prior telephone conference with court and opposing counsel.

Sur-replies require prior leave of the Court.

Motions in limine must be fully briefed with specific timing: 21 days before JPTS for motion, 14 days for opposition, 7 days for reply.

Motions in limine must be fully briefed with Joint Pretrial Statement; opposition due in 5 days, reply in 2 days.

Separate numbered motions in limine required for each discrete issue; omnibus motions not accepted.

Parties must confer in good faith before seeking Court involvement in a discovery dispute.

Discovery-dispute motions require leave of Court before filing.

At least three court days before the informal discovery conference, counsel must email a joint dispute letter limited to five pages and single-spaced.

A party intending to file a discovery motion must confer with the opposing party about IDC scheduling and provide mutually agreeable dates to the judge’s clerk.

Counsel must complete meet-and-confer efforts through an in-person, video, or telephone meeting and reach impasse before requesting an informal discovery conference; email exchange alone is insufficient.

If a will offered for probate has face alterations by interlineation or deletion, the personal representative must obtain a court determination of entitlement before seeking final distribution.

Before filing any motion in limine, the parties must meet and confer on all such motions to attempt to reach stipulations.

A represented party's person filing a W&I § 388 petition must meet and confer with other counsel and use Judicial Council Form JV-180.

Every noticed motion must include the moving party’s counsel declaration describing the counsel’s meet-and-confer efforts.

A motion hearing date and time must be reserved with the CEQA clerk and approved by the court before filing the motion.

The parties must meet and confer on every motion in limine before filing it.

All attorneys must meet and confer before filing a noticed motion in a juvenile dependency case.

Counsel authorized to resolve the discovery dispute for the moving and opposing parties, including parties who joined or opposed the motion, must attend and participate in good faith at the IDC.

If the Supervising Asbestos Judge or trial judge allows additional motions in limine, a briefing schedule will then be ordered.

Attorneys wishing to move for change of judge must immediately announce that intention to the presiding judge at call assignment and then follow ORS 14.260, 14.270, and SLR 7.045 for the motion to be timely.

At assignment, an attorney seeking a change of judge must immediately announce that intention to the presiding judge and follow the cited procedures for timeliness.

The listed motion types (e.g., class action certification, compel arbitration, ORCP 21 motions, sanctions, interpleader) must be heard by the motions judge assigned to the case.

All attorneys or self-represented litigants must appear in person for complex case designation request hearings at scheduling conferences.

To get a motions judge assigned before automatic assignment, a party must make an oral request at ex parte, and must be prepared to announce a decision on a change of judge at that time.

On remand, arrange a scheduling conference with the presiding judge to determine next steps.

In cases 'set to follow,' pretrial motions should be made to the assigned trial judge.

Motions judges hear contested pretrial motions other than summary-judgment motions.

Motions in limine are prohibited from being filed before the pretrial conference.

For cross summary judgment motions, plaintiff must file opening brief 14 days before dispositive deadline, notice of motion must indicate cross motions and set hearing 42 days after filing.

Parties must meet and confer in good faith to resolve a discovery dispute without court action before filing a discovery motion or requesting an informal telephonic discovery conference.

Pre-filing meet and confer required before motions; certification of efforts required in notice of motion.

Only four briefs may be filed for cross summary judgment motions regardless of the number of complaints; non-compliance results in denial without prejudice.

Pre-filing meet and confer required for motions where parties are represented by counsel.

Informal discovery conferences are optional alternative to formal motions under Local Rule 251.

Motions to tax costs are taken under submission upon filing with no hearing date set, and briefs/responses must follow Local Rule 292 and the Federal Rules.

Parties must confer with the court before filing any discovery motion.

Before filing a discovery motion, the parties must contact the Staff Attorney and hold a telephone conference with all other parties.

For summary judgment, opposition is due within 28 days and reply within 7 days after opposition; oral argument is available upon request, with disposition posted on the docket absent another arrangement.

For motions other than summary judgment or motions in limine, the opposition brief is due 14 days after filing and the reply brief is due seven days after the opposition brief.

Before filing any discovery motion, the parties must promptly contact the Staff Attorney and arrange a telephone or in-person attorney conference.

Before filing a discovery motion, parties must contact the staff attorney and initiate a telephone conference.

Before contacting the court about a discovery dispute, attorneys must attempt to resolve it with opposing counsel as required by the cited rules.

The Court will hear merits oral argument if requested; otherwise, it will schedule oral hearings as it deems appropriate.

An oral hearing on a motion for summary judgment is available if requested.

Meet and confer with the responding party before filing a discovery motion to compel.

The demurring party must meet and confer with the opposition to resolve objections and comply with CCP 430.41.

Parties must actually discuss a discovery dispute before reserving an informal discovery conference; an email or letter is insufficient.

Counsel must meet and confer before filing a demurrer, per CCP 430.41.

Before trial, parties must share exhibits with opposing parties, identify witnesses, and estimate trial time.

Emailing or notifying the other party of the ex parte hearing does not constitute meeting and conferring.

Participation in an Informal Discovery Conference before filing discovery motions is encouraged but not required.

Parties are strongly encouraged to request an informal discovery conference before filing a discovery motion.

Before setting a final merits hearing in an administrative appeal, all counsel must confer on the hearing date, the amount of time requested, and (if multiple parties) the order of presentation.

Requests to be heard on motions challenging a prior ruling (new trial, modify/correct/reform/reconsider, etc.), except one by default, must be presented to the judge who made the ruling; contact the Court Administrator's office to determine visiting judge availability.

Counsel may not repeat or address subject matter covered by the pre-trial standing order except to seek a modification of the standing order.

Parties must brief administrative appeals before the hearing on the merits.

Motions in limine requesting additional limine relief or modification of the pre-trial standing order will be heard by the trial judge at the time of trial.

Attorneys are strongly encouraged (but not required) to confer by phone or in person before hearings on non-dispositive issues, especially discovery disputes.

A motion or response may request oral argument, and the Court will notify the parties if it wishes to schedule argument.

Beginning June 1, 2026, summary judgment motions are automatically set for hearing by submission on the dates specified in the referenced Travis County standing order.

Before filing a motion to compel or for a protective order, parties must attempt informal resolution, then notify the Court by a Rule 6.4-compliant letter/e-mail and participate in a meaningful telephone conference; non-compliant motions to compel will be denied.

Replies and sur-replies require prior Court approval, requested informally by email with an explanation of need.

Before filing a motion to compel or for a protective order, parties must first discuss the dispute with the Court and opposing parties and submit a letter/e-mail demonstrating compliance with USCR 6.4; non-compliant motions will be denied.

Parties must confer before the motions hearing date to attempt to narrow or resolve issues by agreement and to discuss plea possibilities versus proceeding to the motions hearing and trial.

Parties must confer and complete all plea negotiations well before the Final Plea Calendar so that defense counsel can announce at calendar call whether the case will resolve by guilty plea or proceed to trial; no pre-trying or last-minute negotiations are permitted during the calendar.

Parties must confer before the motions hearing date to narrow or resolve outstanding motions and discuss the State's offer and plea options.

The Court encourages (but does not require) parties to request discovery, pre-trial, or settlement conferences with specific goals, and will meet in chambers, in court, or by phone.

Parties must confer before the Motions Hearing Date to determine whether outstanding motions can be narrowed or resolved and to discuss the State's offer and the defendant's desired course.

A Trial Readiness Conference is required on all cases set for trial, scheduled one week before trial but not less than three days before trial, unless the court orders otherwise or the parties agree otherwise.

All law and motion pleadings must first be set for a short cause hearing, which has a maximum duration of 15 minutes unless extended by leave of court.

In misdemeanor cases, no law and motion matter may be heard until a trial date has been set, and after a non-dispositive law and motion matter the case must be confirmed for trial.

Before filing a demurrer or motion to strike, parties are strongly encouraged to meet and confer about extending the responsive pleading deadline; if no stipulation is reached, the Court reserves June 6, 2025 at 9:00 a.m. for a hearing on such motions.

If a discovery motion is filed without an IDC having been scheduled, the court is likely to schedule an IDC before hearing the motion.

Parties must meet and confer and exchange motions in limine at least seven days before trial, identifying contested motions.

The EEC procedure applies only to PAGA actions commenced on or after June 19, 2024, per Labor Code section 2699.3(g)(l); earlier PAGA actions are not entitled to an EEC.

A Juvenile Dependency Settlement Conference may be ordered by the judicial officer on the court's own motion or requested by any party through a written request to the trial court department; the judicial officer sets the JDSC date upon approving the request.

Under the possible summary-judgment procedure, a party seeking leave must file a summary-judgment letter of no more than 1,250 words identifying the undisputed facts and legal theories supporting the motion.

Case dispositive motions are scheduled only after briefing is complete, with the date and time obtained from Judge Winston’s Chambers.

Motions in limine must be noticed for presentation at the Pretrial Conference and may be resolved there.

The parties must meet and confer in good faith before moving the court for modifications or additional safeguards.

Parties may request, and the Court may adopt, a scheduling-order provision requiring leave before filing a summary-judgment motion.

Further briefing and hearings on motions will occur only as ordered by the court.

Judge Vavala’s routine motion calendar is held on Thursday at 9:00 a.m.

Counsel must make every effort to resolve discovery disputes by agreement before filing a motion with the court.

Before filing a discovery motion, counsel must make reasonable efforts to resolve the dispute, and a single email is insufficient.

A discovery motion filed without a prior status conference will likely be denied because the movant will be presumed not to have made adequate good-faith efforts.

The Court generally will not hold a discovery conference or hearing unless counsel first files a motion certifying its efforts to resolve the dispute.

If the parties remain unresolved after a discovery status conference, the Court will set a briefing schedule for a future discovery motion.

After good-faith efforts fail, parties should request a pre-motion discovery status conference.

Counsel should address Daubert issues among themselves and, absent agreement, with the Court at the final pretrial conference.

A motion in limine may be filed only after good-faith discussions and certification that counsel exhausted efforts to resolve the issues.

Counsel seeking to amend the case schedule should consider the applicable presumptive trial deadlines, comply to the best of their ability, and consult other counsel about conflicts before approaching the Court.

A party may request an advance hearing to consider a motion; otherwise, the motion will be considered on the trial date.

The court will not accept a sur-reply unless good cause is shown and the court grants a request to file it.

After sending the disclosure-dispute letter, the requesting party must contact Chambers to arrange a conference, preferably by telephone, and no discovery motion will be entertained without compliance.

A motion may be decided on default for failure to file papers and appear, submit a consent order, or obtain an adjournment.

For an adjourned motion, fully briefed papers must be submitted one week before the return date.

In-person oral argument is required for every motion.

The court will not conduct a second calendar call.

A fully briefed motion may be placed on the next available oral argument calendar, but oral argument will not occur on the day the application is made.

Once a motion is fully briefed, the parties may apply on the return date to schedule oral argument for the next available Friday morning; argument will not be heard on the application date.

A fully briefed motion may be placed on the next available oral-argument date, but oral argument will not occur on the application date.

A Readiness Conference is required on the court day before the Master Trial Calendar, with trial counsel required to appear and notify the court of trial readiness.

Motions in limine are not heard at the pre-trial conference.

Substantive motions are usually not permitted before the motion for class certification.

All parties and attorneys must meet and confer pursuant to California Rules of Court Rule 5.98.

Pre-filing conference required under Local Rule CV-7(h)/(i); additional lead attorney conference within 72 hours of hearing setting; lead attorney must attend hearing unless excused.

Pretrial motions in criminal cases are referred to magistrate judges, except for specific motions.

Counsel must confer on deposition objections

Review E-Discovery model order before contacting hotline or filing electronic discovery motions.

Parties must comply with Local Rule CV-7(h) and (i) conference requirements before filing any discovery motion.

Motions to compel discovery require good faith conference first.

5-day conference requirement for motions in limine disputes

Each side may propose up to five motions in limine at the Pretrial Conference.

Opposing counsel must confer to resolve deposition objections before court ruling.

Trial counsel must attend every pretrial conference unless excused by the judge.

A summary-judgment opposition with permitted evidence may be filed within 14 days after service, and the movant may reply within 10 days after service of the opposition.

When a claim is at least partly covered by insurance, an authorized representative of the insurer must attend the pretrial conference unless the judge orders otherwise.

After the conference or any hearing, the Court must set a briefing schedule under Rule 19.03.

The judge must assign a firm trial date at the initial pretrial conference.

The additional-evidence procedure does not apply to unemployment compensation appeals; the Court may review only the certified record provided by the Review Commission.

Unless the Court orders otherwise, summary-judgment motions are decided on briefs and permitted evidence without oral argument.

The Court may dismiss a case without prejudice if it determines that the plaintiff is not ready for trial.

If case evaluation is not accepted, counsel and self-represented litigants must appear by Zoom for a first settlement conference 42 days after case evaluation.

Attorneys must discuss motions to compel and other discovery motions with opposing counsel before filing.

Motions to compel discovery must state that the movant conferred or attempted to confer in good faith before filing.

Responses to rehearing or reconsideration motions are not permitted unless the Court specifically allows them.

Summary-judgment motions must be filed and served at least 60 days before the Pre-Trial Conference and heard before it.

Before filing a non-dispositive motion, the movant must confer with the opposing party in good faith to attempt to resolve the motion's issues.

Before filing a motion to compel or for a protective order, counsel must confer in good faith with opposing counsel to attempt resolution and file a certification of that conference and the unresolved dispute.

Before filing a motion to compel or for a protective order, moving counsel must confer with opposing counsel in a good-faith effort to resolve the disputed issues.

Withdrawal of counsel requires a motion and hearing unless the request is accompanied by a stipulation signed by the client and all counsel.

Except for motions in limine, motions generally must be filed and heard before the Pre-Trial Conference, with good-cause motions heard at or after that conference.

Attorneys must attempt conferral by telephone, and an unanswered email does not satisfy the conferral requirement.

Pre-filing conferral is not required when either party is pro se or for the enumerated categories of motions, including default, summary judgment, specified dismissal motions, judgment enforcement, possession, section 51.11 actions, and motions not requiring notice.

The court may require argument of listed pending motions at a case management conference, except summary judgment and evidentiary-hearing matters unless all parties agree and the court approves hearing them in advance.

All motions and petitions (except emergencies) must be placed on the presentment call by contacting the court scheduler before being set for hearing; contested matters are not heard during the call, and unresolved matters receive a briefing schedule and future hearing date.

After 14 days, a Notice of Motion for Leave is required to file a supplemental petition, with notice to all parties and DCFS.

All motions and petitions, except emergencies, must be placed on the Court's presentment call before being set for hearing; unresolved matters get a briefing schedule.

Court-ordered mediation is mandatory for eligible eviction cases, but the judge may waive it, and the mediation program cannot prevent the court from entering a default judgment.

Jury cases subject to arbitration are exempt from the initial case management conference unless and until the Rejection of the arbitration award is rejected.

There is a presumption in favor of court-ordered mediation for all civil cases eligible under these rules.

Local Rule 2.07 requires a meaningful conference between opposing counsel before the Court will intervene.

Counsel must meaningfully confer on discovery issues before any hearing is set.

Parties must discuss exhibits and motions in limine with opposing side beforehand to seek agreements.

Exhibits and motions in limine must be discussed with opposing counsel beforehand to seek agreements that may shorten the pretrial.

Agreed motions are typically set for submission; non-agreed motions are set for oral hearing.

Before filing a fees motion, parties must meet and confer in person or by telephone to resolve fee disputes and request an Informal Fees Conference.

Failure to comply with the MSC rules may result in an Order to Show Cause and sanctions of up to $1500, jointly and severally against counsel and parties.

Before pursuing a discovery motion, parties must meet and confer and, if unresolved, request an IDC; a joint brief of no more than three pages is due three court days before the IDC, and failure to first seek an IDC may result in denial of sanctions.

After repeated discovery-order violations, the Court may order a mandatory informal discovery conference and may prohibit filing discovery motions without leave of court or prior IDC participation.