Judge Cunningham's rules set a pre-motion procedure for discovery. Parties must meet and confer twice before requesting an IDC; joint bulletin board posting required for IDC request.
Judge Cunningham's rule states these limits: 15 pages; 20 pages. Memoranda limited to 15 pages; summary adjudication motions limited to 20 pages; application required for longer, per CRC 3.113.
Judge Cunningham's formatting rule includes binding three ring binder, tabbed, internally paginated, organized numerically, and three sets required. Three sets of tabbed, internally paginated exhibits in three-ring binders required for TRC.
The rule requires case number. Parties must submit joint ISC statement as directed in the Initial Status Conference Order.
The rule requires case number and proposed order. Stipulation and proposed order to continue status conference must explain reason, filed at least 5 court days prior.
Parties may contact Judge Cunningham's chambers by phone only as allowed by the rule. The rule lists phone (213) 310-7011. Moving party must immediately notify court (phone + bulletin board) when matter is taken off calendar, per CRC 3.1306(b).
A motion to seal is required for covered sealed filings before Judge Cunningham. Process: file redacted on ecf and file unredacted to chambers. All sealing must comply with CRC 2.550/2.551; court requires specific findings for each sentence, legal justification, narrowly tailored to privacy, trade secrets, or other protected info.
The rule addresses filing timing, filing status, or cure windows. Joint status conference statement must be filed 5 court days prior to every status conference.
The rule addresses service method, recipient, or timing requirements. Details: method: e-service, recipient: all parties. After ISC, court appoints e-service provider; parties must effectuate service via the provider, which is not a substitute for court filing.
Courtroom phone number is (213) 310-7011 for scheduling, informal conferences, and other court communications.
After ISC, court appoints e-service provider; parties must effectuate service via the provider, which is not a substitute for court filing.
Parties must submit joint ISC statement as directed in the Initial Status Conference Order.
Joint status conference statement must be filed 5 court days prior to every status conference.
Stipulation and proposed order to continue status conference must explain reason, filed at least 5 court days prior.
Parties must meet and confer twice before requesting an IDC; joint bulletin board posting required for IDC request.
Parties must meet and confer real time before filing motions to challenge/amend pleadings; must also confer with court via status conference or joint posting for pleadings conference.
Memoranda limited to 15 pages; summary adjudication motions limited to 20 pages; application required for longer, per CRC 3.113.
All sealing must comply with CRC 2.550/2.551; court requires specific findings for each sentence, legal justification, narrowly tailored to privacy, trade secrets, or other protected info.
Confidential discovery motion materials must be redacted, unredacted version in sealed envelope behind caption page, redacted version filed publicly.
Moving party must immediately notify court (phone + bulletin board) when matter is taken off calendar, per CRC 3.1306(b).
Evidentiary objections in summary judgment motions must be formatted per CRC 3.1354, each objection to a single sentence with specific identification and basis.
Reply briefs for summary judgment/adjudication motions must be filed 5 calendar days prior to hearing per CCP.
Trial Readiness Documents must be served and filed at least 5 calendar days prior to TRC.
Three sets of tabbed, internally paginated exhibits in three-ring binders required for TRC.
Motions in limine must have caption identifying subject and evidence sought to be precluded; numbered consecutively if multiple.
Parties must meet and confer before and after filing motions in limine to resolve evidence disputes and limit number.
Jury trials require joint case statement per Local Rule 3.25(i)(4) or agreed mini-opening statements (5 mins per side).
Joint witness list (excluding impeachment/rebuttal) required per Local Rule 3.25(i)(5).
Joint exhibit list with objection columns required; parties must meet and confer to resolve exhibit objections.
Joint proposed jury instructions required, edited CACI, special instructions with citations and requesting party above text per Local Rules 3.170/3.171.
Joint verdict form required; separate forms if no agreement, per Local Rule 3.25(i)(7)/(8).
Tabbed 3-ring trial readiness binder required for TRC; USB drive with electronic copies recommended.
Hearing dates for motions must be reserved by telephoning the courtroom assistant at (213) 310-7011.