San Bernardino Superior Court Filing Rules
Official filing rules, court-wide sources, and procedure resources for San Bernardino Superior Court
For San Bernardino Superior Court filings, start with the official local rules and court-level instructions. Then confirm any division, department, clerk, or assigned-officer procedure that applies to the case.
- Court-level rules
Every court-appointed attorney must file a verified written report stating bar status and disciplinary history, professional liability coverage, and prior representations, including the represented party's name and an explanation of the representation; reports for private professional conservators or fiduciaries must be included.
- Judge Stephanie Tañada
All parties must submit a complete set of joint jury instructions with a generic pleading cover sheet and an itemized list of any CACI and special instructions.
- Judge Kevin C. Lee
The proposed order must include approval of any third-party administrator.
- Judge Carlos Cabrera
Trial brief.
- Judge Joseph T. Ortiz
If counsel agree to stay formal proceedings, each defendant must file either a Notice of General Appearance or, when challenging personal jurisdiction, a Notice of Special Appearance.
- Court-level rules
The parties must immediately notify the court and file the Notice of Settlement after settling the case.
- Judge Stephanie Tañada
The parties must meet and confer, exchange necessary documents, and file the required joint trial documents directly in Department 33 on the Trial Setting Conference date.
- Judge Kevin C. Lee
The mandatory Settlement Conference Statement is due in S26 three court days before the scheduled conference.
- Judge Joseph T. Ortiz
The joint report must be filed through the Clerk's office before the hearing, and one courtesy copy must be submitted directly to Department S17 to ensure timely receipt.
- Judge Khymberli S. Apaloo
At least five days before the Mandatory Settlement Conference, MSC Briefs containing the four CRC 3.1380 elements must be filed directly in Department S-25 and served on opposing parties.
- Court-level rules
A proof of service must be filed at least 10 days before the examination for motions or ORAPS to avoid removal from the calendar.
- Judge Carlos Cabrera
Serve opposing counsel pursuant to statute or at least five calendar days before the Trial Readiness Conference, whichever deadline is sooner.
- Judge Stephanie Tañada
Moving papers and oppositions—and not replies—must be served and filed under Code of Civil Procedure section 1005(b).
- Judge Kevin C. Lee
All PowerPoint slides used in opening or closing must be shared with the opposing side.
- Judge Tony Raphael
Motions in limine must be filed directly in Department R14, with service completed at least eight days before the Trial Readiness Conference.
- Judge Stephanie Tañada
Exhibits must be premarked in numerical order and bates stamped at the bottom of every page, with former bates stamps removed.
- Court-level rules
Correction fluid or tape is prohibited on documents submitted for filing, and the Clerk may refuse such documents unless the Court orders otherwise.
- Judge Kevin C. Lee
Exhibits must be pre-marked in numerical order and Bates-stamped at the bottom of each page when they contain multiple pages.
- Judge Lily L. Sinfield
Parties must bring a three-ring Joint Trial Binder to the Trial Readiness Conference.
- Judge Carlos Cabrera
All exhibits must be digital and saved on a flash drive containing a table of contents for the court.
- Judge Gilbert G. Ochoa
Before filing any discovery motion, the moving party must schedule a discovery conference with all parties and the Court, preferably by video.
- Judge Stephanie Tañada
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.
- Judge Joseph T. Ortiz
A party must request an informal discovery conference with the court before filing a discovery motion.
- Judge Kevin C. Lee
Informal Discovery Conferences are offered but are not required before the Court hears discovery motions.
- Judge David E. Driscoll
The propounding and responding parties must attend the IDC telephonically without CourtCall, while attendance is optional for other parties not involved in the dispute.
- Court-level rules
A party may obtain a tentative ruling by accessing the court website after 3:00 p.m. on the court day before the hearing or by telephoning the court’s Administrative Assistants.
- Judge Stephanie Tañada
If parties/counsel are going to be late for a hearing, please contact the court staff.
- Judge David E. Driscoll
The Judicial Assistant may be contacted by phone at (909) 521-3529.
- Judge Joseph B. Widman
The Judicial Assistant must email the exhibit-list template to counsel.
- Judge Tony Raphael
Counsel must provide their email addresses to the Judicial Assistant so the exhibit list template can be emailed to them.
- Judge Stephanie Tañada
Department S33 requests courtesy copies.
- Judge Michael A. Dauber
Courtesy copies are required for ex parte applications and supporting documents, motions, oppositions, replies and their supporting documents, and all trial documents.
- Judge Malalai Farooqi
Two courtesy copies of the Joint Exhibit List must be provided to the Clerk.
- Judge Joseph T. Ortiz
a courtesy copy of the report will be submitted directly into Department S17.
- Judge Lily L. Sinfield
The Joint Witness List must identify each witness, provide a brief description and time estimate, and include two courtesy copies provided to the clerk.
- Court-level rules
A continuance of the first-set trial date must be requested by a written stipulation of all parties, without an ex parte application, filed at least 15 days before the trial date.
- Judge David E. Driscoll
Witness unavailability supports a continuance only if the witness was subpoenaed or beyond subpoena, had agreed to attend, and is absent because of an unavoidable emergency that counsel neither knew nor reasonably could have known when trial was set.
- Judge Stephanie Tañada
Unless a formal request is made at the Trial Readiness Conference, each party has three minutes for its mini-opening, subject to extension for good cause.
- Judge Gilbert G. Ochoa
(Be prepared with appropriate financial documentation/declarations at this time of the IDC or request an extension at the time of the IDC).
- Judge Joseph T. Ortiz
A continuance of the initial case management conference may be jointly requested by submitting a stipulation and proposed order directly to Department S-17 no later than five court days before the hearing.
- Court-level rules
Form RA-010 may be filed electronically or submitted in person at the court location where the petition is or will be filed.
- Judge Carlos Cabrera
Attorneys must use electronic filing for ex parte pleadings.
- Judge Donald Alvarez
Upon assignment to trial, but not before, the listed trial-readiness items must be submitted electronically with one courtesy copy delivered to the department.
- Judge Joseph B. Widman
Counsel must electronically file or personally hand-deliver all identified trial documents to Department S-36 by the non-appearance Trial Document Filing Date.
- Judge Kevin C. Lee
The Notice of Hearing must be filed electronically at least seven court days before the conference.
- Judge Lily L. Sinfield
An Answer to a Request for Informal Discovery Conference may not exceed two pages and must summarize why the requested relief should be denied.
- Judge Stephanie Tañada
The joint informal discovery conference statement must outline the impasse and may not exceed five pages.
- Court-level rules
Mediation briefs are optional, but an elected brief may not exceed 10 pages, including all photos and exhibits.
- Judge Joseph T. Ortiz
Counsel should lodge, rather than file, a one-page statement identifying the issues in dispute.
- Judge Charlie L. Hill Jr.
The discovery-issue summary is limited to two pages.
- Judge Stephanie Tañada
Any provided trial brief must be included in the judge's working binder with the other trial documents.
- Judge Winston Keh
The parties must meet and confer and bring two complete Joint Exhibit Binders to the first day of trial, allocating the premarked original to the witness and one copy to the Court.
- Judge Charlie L. Hill Jr.
Substantive discovery documents must not be submitted for the conference, although they should be available for reference, preferably electronically.
- Court-level rules
The parties should jointly submit trial-readiness documents, but may submit individual documents if they cannot agree.
- Judge Khymberli S. Apaloo
Documents should be jointly submitted.


