San Bernardino Superior Court Pre-Motion Conference Requirements

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

Prior to any party filing any discovery motion in this action, the moving party must schedule a telephonic discovery conference (herein after IDC) with all parties and the Court.

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

Propounding and responding parties to the discovery dispute must be at the conference telephonically.

The propounding and responding parties must attend the IDC telephonically without CourtCall, while attendance is optional for other parties not involved in the dispute.

Propounding and responding parties to the discovery dispute must appear at the IDC telephonically (No CourtCall). Attendance is optional for all other parties not involved in the dispute.

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

Prior to any party filing any discovery motion in this action, the moving party must schedule a telephonic informal discovery conference (herein after IDC) with all parties and the Court.

The prospective moving party must contact Department 22 to schedule the IDC and give notice of the conference to all parties.

The party intending to file a motion must contact Department 22 to schedule the IDC. Notice of the IDC must be given to all parties by the prospective moving party.

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

Prior to any party filing any discovery motion in this action, the moving party must schedule a telephonic or preferably a video discovery conference (herein after IDC) with all parties and the Court.

Notice of the discovery conference must be given to every party.

Notice must be given to all parties.

The parties propounding and responding to the discovery dispute must attend electronically, while other uninvolved parties may attend or abstain.

Propounding and responding parties to the discovery dispute must be at the conference electronically. All other parties not involved in the dispute can attend or not attend the conference.

Failure to obey the discovery-conference order may result in sanctions under CCP 177.5.

Failure to obey this Order will result in Sanctions for the offending party pursuant to CCP 177.5.

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

Motions concerning discovery cannot be filed without first requesting an informal discovery conference (IDC) with the court.

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.

No briefing is allowed for the IDC, but counsel (either jointly or separately) should lodge (not file) a one page statement of the issues in dispute in Department S-17 no later than the day before the IDC.

Parties must meet and confer to impasse on a discovery dispute before seeking an informal discovery conference, and failure to do so may result in removal of the conference from the calendar.

Parties are, however, required to meet and confer to impasse on the discovery dispute prior to seeking an IDC. Failure to meet and confer will result in the IDC being taken off calendar per Local Rule 560.

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

Scheduling an IDC stays the deadline for filing discovery motions in complex matters.

An informal discovery conference is offered before any party files a discovery motion.

Prior to any party filing any discovery motion in this action, the Court offers Informal discovery conferences (herein after IDC).

Counsel must meet and confer in good faith before filing and serving motions in limine.

Counsel shall meet and confer in good faith before filing and serving the Motions in Limine.

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

Prior to any party filing any discovery motion in this action, the moving party must schedule a telephonic or preferably a video discovery conference (herein after IDC) with all parties and the Court.

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.

Within five (5) court days of filing the discovery motion and prior to any party filing an Opposition to a discovery motion in this action, the moving party shall schedule a video informal discovery conference (hereinafter IDC) with all parties and the Court. The purpose of the IDC is to try and resolve the discovery issues without the necessity of a motion and or sanctions. At the IDC, the issues of the discovery dispute will be discussed as well as possible referral of the case out to Judicial Referee (hereinafter JR), pursuant to CCP 639. Timely objections to JR, including but not limited to, economic hardship, will be heard at this time only. (Be prepared with appropriate financial documentation/declarations at this time of the IDC or request an extension at the time of the IDC). Referral to JR is relatively rare but nonetheless, is a possibility after the conference depending on circumstances.

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.

Prior to the IDC, the parties are required to meet and confer to impasse via phone or videoconference on the discovery dispute. The moving party shall schedule and coordinate the meet and confer. The opposing party shall respond to any scheduling attempt within three (3) business days.

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

The Court requires Informal Discovery Conferences for all matters except for those involving self-represented litigants, expert discovery, and motions to compel where no responses have been provided.

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.

This Order does not apply to the following: Discovery disputes involving self-represented individuals; Expert discovery disputes; and Motions to compel discovery in which no responses have been provided whatsoever. All other discovery disputes, including motions to quash, are subject to this Order.

The moving party must schedule a video informal discovery conference with all parties and the Court within five court days after filing the discovery motion and before any opposition is filed.

Within five (5) court days of filing the discovery motion and prior to any party filing an Opposition to a discovery motion in this action, the moving party shall schedule a video informal discovery conference (hereinafter IDC) with all parties and the Court.

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.

Prior to the IDC, the parties are required to meet and confer to impasse via phone or videoconference on the discovery dispute. The moving party shall schedule and coordinate the meet and confer. The opposing party shall respond to any scheduling attempt within three (3) business days.

The parties must meet and confer by telephone or in person before filing or serving any motion in limine.

The parties are required to meet and confer via telephone or in person before filing and serving any motions in limine.

Counsel must meet and confer in good faith before filing and serving any motion in limine and must comply with Local Rule 415.

Motions in Limine and oppositions (if any): Counsel shall meet and confer in good faith before filing and �erving the Motions in Limine. Couns�l shall comply with Local Rule 415 and the parties are expected to read and be familiar with Amtower v. Photon Dynamics Inc. (2008)158 Cal.App.4th 1582, Kelly v. New West Financial Services (1996) 49 Cal.App.4th 659, and R&B Auto Center Inc. v. Farmers Group Inc. (2006 140 Ca1. App.4th 327.

The pre-motion conference requirement covers motions to compel depositions, motions to compel document production at depositions, and objections or motions to quash business or medical records subpoenas.

"Discovery" for purposes of this order includes Motions to Compel Depositions and to compel production of documents at depositions; and objections or motions to quash subpoenas for business or medical records.

Before the IDC, the parties must meet and confer in good faith concerning disputed discovery requests, with the length and number of meetings suited to the volume or complexity of the disputes.

The parties are to meet and confer before the IDC to discuss in good faith the disputed discovery requests. The length and number of such meetings should be conducive to the volume and/or complexity ORDER ===== PAGE 2 ===== of the disputed requests.

The discovery conference will address the dispute and possible referral to Judicial Reference, and timely objections to that referral must be made at the conference.

At the IDC, the issues of the discovery dispute will be discussed as well as possible referral of the case out to Judicial Reference (hereinafter JR), pursuant to CCP 639. Timely objections to JR, including but not limited to, economic hardship, will be heard at this time only.

Time to bring a necessary discovery motion is tolled for any delay caused by the discovery conference.

The time for bringing any discovery motion if necessary, will be tolled by any delay caused by the discovery conference.

Informal discovery conferences are conducted by Zoom, with in-person attendance permitted only when all counsel appear in person.

IDCs are conducted by remote video conference, using Zoom. In-person attendance at the IDC is permissible only if all counsel are appearing in person.

All informal discovery conferences are conducted off the record.

All IDCs are off the record.

The joint trial binder must include a joint list of issues and motions in limine with oppositions and replies arranged in order; counsel must meet and confer in good faith before filing and serving motions in limine and comply with Local Rule 415.

6. Joint list of the issues 7. Motions in Limine and Oppositions in order Type of motion followed by any opposition and replies. Counsel is instructed to meet and confer in good faith before filing and serving the Motions in Limine. Counsel shall comply with Local Rule 415.

The IDC is intended to resolve discovery issues without a motion or sanctions, may address referral to a Judicial Referee, and requires parties to prepare financial documentation or request an extension at the conference when raising economic hardship.

The purpose of the IDC is to try and resolve the discovery issues without the necessity of a motion and or sanctions. At the IDC, the issues of the discovery dispute will be discussed as well as possible referral of the case out to Judicial Referee (hereinafter JR), pursuant to CCP 639. Timely objections to JR, including but not limited to, economic hardship, will be heard at this time only. (Be prepared with appropriate financial documentation/declarations at this time of the IDC or request an extension at the time of the IDC). Referral to JR is relatively rare but nonetheless, is a possibility after the conference depending on circumstances.

The discovery conference is intended to resolve discovery disputes without filing a motion.

The purpose of the IDC is to try and resolve the discovery issues without the necessity of a motion.

Neither side must file substantive discovery documents for the conference, but should have them available at the conference, preferably electronically.

No substantive documents on the discovery issues (propounding and/or responsive documents, briefs, etc.) need to be filed for the conference by either side but you should have them available for reference at the conference preferably electronically.

Participants should join the conference link five minutes early to discuss narrowing the issues with opposing counsel before the Court joins.

Please appear on the link 5 minutes early to discuss any narrowing of issues with opposing counsel before the Court logs on.

If all counsel agree, a remote conference may address matters beyond discovery, remains off the record, and will not result in orders unless all parties agree.

If all counsel agree, remote conferences are not limited to discovery issues; counsel may address other matters with the court, with the understanding that the conferences are off the record and that the court will make no orders absent agreement among the parties.

Informal Discovery Conferences are offered but are not required before the Court hears discovery motions.

Informal Discovery Conference ("IDC") are offered, however they are not required to be held prior to the Court hearing discovery motions.

Parties in unlimited civil matters are encouraged, but not required, to stipulate to a stay.

Parties in unlimited civil matters are encouraged to stipulate to a stay.

The informal discovery conference will be held by video conference using Zoom.

This meeting will be held by video conference via zoom.