Judge Stephanie Tañada
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- At Least 72 Hours Before Hearing
Ex Parte Application
- Chambers Drop Off • Before 2pm Day Prior
Exhibits
- 1 copy
Summary Judgment Motions, Summary Adjudication Motions, Anti-SLAPP Motions
- Within One Court Day
Binding: Tabbed Three Ring
Communication
Clerk7 contacts
- aarroyo@sb-court.org
- (909) 708-8678
- (909) 521-3085
- (909) 708-8853
- (909) 521-3447
- (909) 708-8756
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- (909) 285-3753
Chambers2 contacts
- mamiranda@sb-court.org
- 909-708-8850
Other Contacts1 contacts
- probatenotes@sb-court.org
Page & Word Limits3 rules
The joint informal discovery conference statement must outline the impasse and may not exceed five pages.
Further, IDCs are limited in time and therefore limited in scope. The parties will submit a joint IDC statement outlining the impasse that is no more than five pages long.
Joint Idc Statement
5 pages
The parties must submit a joint IDC statement outlining the discovery impasse, and the statement may not exceed five pages.
The parties will submit a joint IDC statement outlining the impasse that is no more than five pages long.
Joint Idc Statement
5 pages
Disputes exceeding the five-page IDC scope must be addressed across multiple IDC dates.
Disputes that are beyond the five-page scope must be spread over multiple IDC dates.
Joint Idc Statement
5 pages
Document Format Requirements8 rules
Exhibits must be premarked in numerical order and bates stamped at the bottom of every page, with former bates stamps removed.
(Exhibits shall be pre-marked in numerical order and if multiple pages, bate stamped at the bottom of each page; former bate stamps must be removed)
At the Trial Readiness Conference, the moving party must present motions in limine in tabbed, indexed binders arranged numerically, with moving papers, opposing papers, and replies back-to-back for each motion.
At the Trial Readiness Conference, the moving party is to present their MILs in a tabbed and indexed binder (or binders) in numerical order. Each number shall have the moving papers, opposing papers, and replies back-to- back, for ease of the Court reference.
Exhibits must be placed in three-ring binders with one copy each for the court, the witness, and all other parties.
Exhibits shall be place in 3-ring binders with 1 copy for the Court, 1 for the witness and 1 for all other parties to the action.
Remote witnesses may not testify using a tablet, cellular phone, or other small personal device, or from a public place.
No witness will be allowed to testify from a tablet, cellular phone, or other small, personal device, or testify from a public place, e.g. a coffee shop, a library, outdoors, etc.
Remote witnesses must use a laptop or desktop with a secure isolated connection and have live technical support throughout testimony.
Remote witnesses must testify from a laptop or desktop computer with a secure, isolated connection and have live technical support available during the entirety of the witness's testimony.
An exhibit, demonstrative, or other court material created or drafted with AI assistance must identify that use in its title or caption and in a table preceding its body.
Any exhibit, demonstrative, or other material to be filed or presented to the Court which was created or drafted with any assistance or use of an Al tool shall be identified as suchin its title or caption, in a table preceding the body of exhibit, demonstrative, or other material, and by a separate Notice filed contemporaneously with the document or material.
Every electronically filed document must be text searchable and bookmarked.
All electronically filed documents must be text searchable and bookmarked.
Exhibits should not contain sub-exhibits.
Exhibits should not have “sub-exhibits.”
Document Filing Requirements82 rules
Before the Trial Readiness Conference, counsel must meet and confer and attempt to stipulate to the authentication and admissibility of the exhibits.
Prior to the Trial Readiness Conference, counsel shall meet and confer and attempt to stipulate to (1) authentication and (2) admissibility.
Document Type
Exhibits
The parties must exchange and inspect all exhibits that were not furnished during discovery.
Exhibits- The parties shall exchange and inspect all exhibits not furnished during discovery.
Document Type
Exhibits
A complete jury-instruction set cannot contain unfilled brackets or blank spaces and must be agreed to by the parties.
“Complete” means all brackets and blank spaces must be filled in and agreed to by the parties.
Document Type
Joint Jury Instructions
The rule addresses joint jury instructions.
Joint Jury Instructions; and
Document Type
Joint Jury Instructions
The joint exhibit list must describe each exhibit and identify its presenting witness, and the exhibits must be premarked in numerical order, bates stamped on every page, and stripped of former bates stamps.
2. Joint exhibit list (Exhibits shall be pre-marked in numerical order and if multiple pages, bate stamped at the bottom of each page; former bate stamps must be removed) with a description of the exhibit and the name of the witness who will testify regarding the exhibit;
Document Type
Joint Exhibit List
A joint witness list must include time estimates for direct examination, cross-examination, re-direct, and re-cross.
1. Joint witness list with time estimates for direct examination, cross-examination, re-direct, and re-cross;
Document Type
Joint Witness List
Parties appearing without the required joint documents will be ordered to meet and confer at the courthouse and return to Department 33 with those documents.
If the parties appear without joint documents, the Court will order the parties to meet and confer in the courthouse and return to $33 with the required joint documents.
Document Type
Joint Trial Documents
Failure to comply with the joint-document requirement may result in sanctions.
Failure to comply with the joint document requirement is cause for sanctions.
Document Type
Joint Trial Documents
Trial briefs are required only for bench trials, and the court will request a stipulation using the trial brief instead of an opening statement.
TRIAL BRIEFS- Trial briefs are only required for bench trials and the Court will request that you stipulate to use the trial brief in lieu of an opening statement.
Document Type
Trial Brief
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.
All parties shall submit, in compliance with CRC RULE 2.1055, a complete set of joint jury instructions (with a generic pleading cover sheet) with an itemized list of the CACI Instructions and Special Instructions, if any.
Document Type
Joint Jury Instructions
A joint statement of the case is required only if the parties do not anticipate giving mini-openings.
3. Joint Statement ofthe Case (only if the parties do not anticipate giving mini-openings);
Document Type
Joint Statement Of The Case
A joint general or special verdict must be filed in a jury trial.
5. Joint General or Special Verdict in a jury trial.
Document Type
Joint General Or Special Verdict
The court will impose a $250 sanction for each motion that violates the stated local rule or cases or is already addressed by a sua sponte ruling.
This constitutes notice that the Court will issue sanctions in the amount of $250 per motion for any motion that violates the Local Rule, cases, or is already addressed by a sua sponte ruling.
Document Type
Motion In Limine
Motions in limine must comply with Local Rule 415, and the parties are expected to be familiar with the cited cases and the court's sua sponte rulings.
MILs shall comply with Local Rule 415 and the parties are expected to read and be familiar with Amtower v Photon Dynamics Inc., (2008) 158 CA4th 1582; Kelly v New West Financial Services (1996) 49 CA4th 659; and R&B Auto Center Inc. v Farmers Group Inc. (2006) 140 CA4th 327, as well as the Court’s sua sponte rulings below
Document Type
Motion In Limine
Out-of-court demonstrative evidence or site inspections require a formal written request by the earlier of the Trial Readiness Conference or one week beforehand, including specified logistical and safety information.
Demonstrative evidence and/or site inspections taking place outside of the courtroom shall not be allowed unless the requesting party makes a formal, written request at the earlier of the Trial Readiness Conference or at least one week prior to the viewing/inspection. The request shall include the proposed location of the viewing, a time estimate including travel to and from the location, whether all parties are waiving a court reporter for the inspection, and proposed safety measures for the jurors, attorneys, courtroom staff, and judge.
Document Type
Request For Out Of Court Evidence Or Site Inspection
AI-generated evidentiary material may not be considered unless timely disclosed or produced in discovery, or, for demonstrative exhibits, provided by the Trial Readiness Conference.
If a Party or counsel seeks to file or otherwise present to the Court any such Al- generated evidentiary material, no such material shall be considered unless previously disclosed or produced timely in discovery (or, with respect to demonstrative exhibits, by the Trial Readiness Conference).
Document Type
Ai Generated Evidentiary Material
Counsel must serve contemporaneous notice identifying AI-generated evidence sufficiently for the opposing side to locate it; material lacking accompanying notice will not be considered.
Contemporaneous with the production or disclosure of any such Al-generated evidentiary material, counsel shall serve a Notice to the opposing Party or side identifying such material with sufficient specificity to locate it (such as by Bates or production number, by attaching a copy to such Notice, by promptly responding to any request for counsel to provide a copy of such material, or by any other means which reasonably permits the other Party or side to identify and locate the material promptly). Any such Al-generated material which does not have an accompanying Notice shall not be considered by the Court.
Document Type
Ai Generated Evidentiary Material Notice
All parties must give the remote witness hard copies of the exhibits to be used, except impeachment exhibits, before the witness is sworn in.
All parties must provide the remote witness with a hard copy of all exhibits to be used during testimony (with the exception of impeachment exhibits) prior to the clerk swearing in the witness.
Document Type
Exhibits
At the time an AI-generated material is submitted or filed, the offering party or counsel must file and serve declarations, affidavits, or sworn testimony addressing its evidentiary authenticity.
time of the submission or filing of any such material to the Court, the Party or counsel proffering such Al-generated material to the Court shall file and serve any declarations, affidavits, or sworn testimony to address the material's authenticity under the Evidence Code.
Document Type
Ai Generated Material
A separate notice of AI assistance or use must be filed contemporaneously with any exhibit, demonstrative, or other material created or drafted with AI.
Any exhibit, demonstrative, or other material to be filed or presented to the Court which was created or drafted with any assistance or use of an Al tool shall be identified as suchin its title or caption, in a table preceding the body of exhibit, demonstrative, or other material, and by a separate Notice filed contemporaneously with the document or material.
Document Type
Notice Of Ai Assistance
Any filing containing text created or drafted with an AI tool must be identified through its title or caption, a preceding table, or a contemporaneously filed separate notice.
Any brief, pleading, or other document submitted to the Court the text of which was created or drafted with any use of an AI tool shall be identified as such in its title or pleading caption, in a table preceding the body text of such brief or pleading, or by a separate Notice filed contemporaneously with the brief, pleading, or document.
Document Type
Ai Assisted Document
Evidentiary objections filed with summary-judgment or summary-adjudgment motions must comply with CRC rule 3.1354.
Counsel filing evidentiary objections in connection with a motion for summary judgment or summary adjudication shall comply with CRC, rule 3.1354.
Document Type
Evidentiary Objections
A moving party that withdraws a calendared motion must immediately notify the Court and is encouraged to remove the matter from the Court Reservation System calendar.
If a moving party takes a motion off the Court’s calendar, the moving party must notify the Court immediately and should remove the item from the Court’s calendar on CRS.
Document Type
Motion Withdrawal Notice
A party seeking a transcript must retain a private reporter and submit the required stipulation and order for use of a certified shorthand reporter.
Parties who wish to have a transcript must retain their own private reporter and must submit a “Stipulation and Order to Use Certified Shorthand Reporter.”
Document Type
Stipulation And Order To Use Certified Shorthand Reporter
Parties and counsel may not file AI-hallucinated, fictitious, nonexistent, or uncorroborated legal citations or assertions of law or fact.
Parties and counsel shall not file or otherwise present to the Court any briefs, pleadings, materials, other documents, or argument which contain AI-hallucinated citations to law, case or legal citations which are fictitious or nonexistent, or any uncorroboratable assertions of law or fact.
Document Type
Court Filing
Settling parties must file both a motion for preliminary approval and a motion for final approval of a class or PAGA settlement.
The Court requires settling parties to file a Motion for Preliminary Approval of any settlement in addition to a Motion for Final Approval.
Document Type
Settlement Approval Motion
An ex parte applicant must comply with CRC rule 3.1200, submit a proposed order, and pay the filing fee before the court appearance.
Applicants must comply with CRC, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in court.
Document Type
Ex Parte Application
A moving party must reserve a hearing date through the San Bernardino Superior Court's online Court Reservation System before filing a motion, subject to the stated motion-in-limine exception.
Moving parties must secure a hearing date via the online Court Reservation System on the San Bernardino Superior Court website.
Document Type
Motion
An ex parte applicant must include a declaration making an affirmative, competent, personally informed factual showing of irreparable harm, immediate danger, or another statutory basis for relief.
The applicant shall comply with CRC, rule 3.1202(c): “An applicant must make an affirmative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte.”
Document Type
Ex Parte Application
Failure to submit the required Joint IDC statement will result in removal of the IDC from the court calendar.
Failure to submit a joint IDC statement will result in the IDC being taken off-calendar.
Document Type
Joint Idc Statement
A final-approval motion must include a proposed final-approval order and proposed judgment retaining jurisdiction to implement the settlement and require a final distribution report.
A proposed Order Granting Final Approval of Settlement, and a proposed Judgment, including retaining jurisdiction over implementing the terms of the settlement, such as requiring the filing of a final report on distributions made to the class members.
Document Type
Final Approval Motion
A motion must include all information on the applicable settlement-approval checklist.
The Court requires all of the information on the checklist specific to the motion.
Document Type
Class Action Settlement Motion
If the class is not certified, the motion must include declarations addressing preliminary certification findings, class-counsel experience, and each representative’s services, participation, and lack of conflict.
If the class is not already certified, then a declaration by counsel addressing the necessary findings for settlement class certification, i.e., the settlement class is sufficiently numerous and ascertainable, the plaintiff’s claims are typical with the class, and common questions predominate. Also, a declaration by class counsel addressing the lawyer’s knowledge and experience handling class actions and related complex litigation. Lastly, a declaration from each class representative stating what the representative did as services to the class and participation in the litigation, and his/her lack of conflict with any putative class members.
Document Type
Preliminary Approval Motion
A preliminary-approval motion must include a proposed order granting preliminary approval of the class settlement.
A proposed order granting preliminary approval of the class settlement which includes:
Document Type
Preliminary Approval Motion
The proposal must state the proposed fee award to class counsel, explain why the fee is appropriate, and say whether defendants or settlement proceeds will pay the fees and costs.
The proposed fee award to class counsel, including an analysis why the fee is appropriate, and whether the attorney fee and costs will be paid directly by defendants as part of the settlement, or whether the fee award and costs will be paid out of the settlement proceeds.
Document Type
Preliminary Approval Motion
The settlement must identify the claims being resolved, including claims not specifically alleged in the class action complaint, and describe the release provisions binding class members and defendants.
What claims are being settled, including any claims which are not specifically alleged in the class action complaint, and the scope of the release provisions which will bind the class members and the defendants.
Document Type
Preliminary Approval Motion
The fee-support declaration must state each attorney’s hourly billing rate and that it is the reasonable and usual rate for the attorney’s services.
The hourly billing rate for each attorney who worked on the case, and a statement that this is the reasonable and usual hourly rate charged by that attorney for services.
Document Type
Final Approval Fee Declaration
If claim forms were sent, a final-approval motion must include declarations verifying timely forms, correction efforts, submitted and untimely claims, distribution, remaining procedures, and processing expenses.
If claim forms were sent to class members, declarations of class counsel or the claims administrator verifying the timely sending of the claim forms, efforts to obtain corrected claim forms on defective claims, the number of claims submitted, the amount of anticipated settlement distribution pursuant to the claims, the number of untimely claims and whether they will or will not be included in the settlement distribution, and any other remaining claims procedures which have not yet been completed, and the final expenses incurred for processing of class claims.
Document Type
Final Approval Motion
A final-approval motion must include a supporting declaration from each class-representing law firm addressing fees, costs, and expenses.
A declaration by counsel from each law firm representing the class in support of the fee award and reimbursement of costs and expenses setting forth:
Document Type
Final Approval Motion
The fee-support declaration must state the total hours worked by each attorney on the case.
The total number of hours worked by each attorney on the case.
Document Type
Final Approval Fee Declaration
A preliminary-approval motion must identify any cy pres distribution of excess funds and, if applicable, include a declaration supporting the recipient and distribution.
Whether the settlement provides for a cy pres distribution of excess funds and, if so, a declaration demonstrating the propriety of the cy pres recipient and distribution under Code of Civil Procedure section 384.
Document Type
Preliminary Approval Motion
If fees or costs are sought for a non-attorney service provider, the declaration must identify the provider’s experience, reasonable fee or cost, and services.
If fees or costs are sought for services by a person other than of one of the identified attorneys under sub-section (a) (e.g., paralegal, expert), then define that person’s experience, reasonable fee/cost, and services provided.
Document Type
Final Approval Fee Declaration
A preliminary-approval motion must include the proposed class notice and explain notice procedures and any language used; cost is not an adequate reason for English-only notice.
A copy of the proposed written class notice, and its discussion of the procedures to be used for providing notice to the class, including if the class notice will be provided in any language other than English (e.g., Spanish), and, if not, the reasonable/justifiable reason why the class notice is only being provided in English (and the court will not accept cost as a reasonable excuse).
Document Type
Preliminary Approval Motion
The fee-support declaration must detail tasks and hours or include time records and billing statements documenting the work.
Either the specific tasks performed on the case on behalf of the named plaintiffs and the class, and the hours spent on each task, or copies of time records/billing statements documenting the work performed and time spent.
Document Type
Final Approval Fee Declaration
A preliminary-approval motion must define the class and aggrieved employees, class and PAGA periods, any statute-of-limitations excess and its reason, estimated class size, and any periodic payment periods.
The definition of the class and aggrieved employees, the class and PAGA periods and whether they exceed the statute of limitation period(s), and if yes, then why, the estimated number of class members and aggrieved employees, and if settlements shares are to be paid on a “weeks worked” or other periodic basis, the number of such periods.
Document Type
Preliminary Approval Motion
The fee-support declaration must provide itemized details of expenses and costs for which reimbursement is sought.
Itemized details for expenses and costs for which reimbursement is sought.
Document Type
Final Approval Fee Declaration
A final-approval motion must include declarations verifying timely notice, bad-address efforts, objections, opt-outs, and final notice expenses.
Declarations of class counsel or the settlement administrator verifying the timely sending of class notice, efforts to find class members with bad addresses, the number of objections from class members (including copies of the objections), the number of opt-outs from class members (including copies of the requests for exclusion, or a list of the names of the class members opting-out), and the final expense incurred for providing class notice.
Document Type
Final Approval Motion
A preliminary-approval motion must state whether the settlement depends on class-member claims and whether the remainder reverts to defendants.
Whether the settlement amount is dependent upon the number and amount of claims made by class members, with the remainder reverting to defendants.
Document Type
Preliminary Approval Motion
If objections were submitted, a final-approval motion must include a brief by class counsel responding to them.
If there were objections to the settlement, a brief by class counsel responding to the objections.
Document Type
Final Approval Motion
A preliminary-approval motion must state the estimated highest, lowest, and average settlement distribution for class members and aggrieved employees.
The estimated highest, lowest, and average amount that class members and aggrieved employees will receive as their share of the settlement distribution.
Document Type
Preliminary Approval Motion
A preliminary-approval motion must include a counsel declaration describing settlement negotiations, mediation, discovery, and the reasons the settlement is fair, adequate, and reasonable.
A declaration by counsel addressing how the settlement was reached, that the settlement was negotiated at arms-length, whether a mediator was used in reaching the settlement terms, whether discovery (formal or informal) was conducted, the type of discovery (formal or informal) conducted, and why the settlement is fair, adequate, and reasonable for the class.
Document Type
Preliminary Approval Motion
A preliminary-approval motion must include a case summary covering claims, merits, discovery, investigation, potential trial recovery, and impediments to recovery.
A summary of the case, including the causes of action, the legal and factual basis for the claims, the discovery conducted to date, counsel’s investigation of the merits of the claims, the anticipated recovery if the case were to proceed to trial, and counsel’s assessment of any impediments to such recovery.
Document Type
Preliminary Approval Motion
The fee-support declaration must identify each attorney who worked on the case, the attorney’s status, and years of experience.
The name of each attorney who worked on the case, and the lawyer’s status (e.g., partner, associate, of-counsel, etc., including the years of experience).
Document Type
Final Approval Fee Declaration
A final-approval motion must include a memorandum supporting any proposed incentive or service award to named plaintiffs and explaining its reasonableness.
A memorandum of points and authorities supporting any proposed “incentive” or “service award” to the named plaintiff(s), i.e., any payment to representative plaintiffs in addition to their proportional share of the settlement, including an analysis why the proposed amount is appropriate, as compared to the amounts that absent class members will receive from the settlement.
Document Type
Final Approval Motion
A final-approval motion must include a table of class-member, claim, opt-out, objection, returned-mailing, re-mailing, and undelivered-notice counts.
A table of the number of class members and aggrieved employees, the number who submitted a claim form (if required), the number of opt-outs, the number of objections, the number of returned mailings, the number of re-mailed notices, and the number of undelivered notices.
Document Type
Final Approval Motion
A final-approval motion must define the settlement’s gross amount, each deduction in exact amounts, and net amount.
The defining of the key financial terms of the settlement, including the gross settlement amount, each deduction from the gross amount (the requested attorney fees, litigation costs, settlement administrator fees, incentive fees, and all other deductions) in exact amounts, and the net settlement amount.
Document Type
Final Approval Motion
The proposed preliminary-approval order must set a final-approval briefing schedule and hearing date, including supplemental declarations, objection procedures, response deadlines, and fee-award submissions.
A briefing schedule and hearing date for final approval of settlement, including a filing of supplemental declarations by counsel and third-party administrators verifying proper service of class notice, and receipt of filing of written objections, and setting a schedule for any written response to objections, and submission for declarations and briefs in support of the requested fee award.
Document Type
Preliminary Approval Proposed Order
A final-approval motion must include the information specifically required by the final-approval checklist.
A motion for final approval of a proposed class action settlement should include the following information:
Document Type
Final Approval Motion
A preliminary-approval motion must define the settlement’s gross amount, deductions, whether amounts are exact or not-to-exceed, and net amount.
The defining of the key financial terms of the settlement, including the gross settlement amount, each deduction from the gross amount (attorney fees, litigation costs, settlement administrator fees, incentive fees, and all other deductions), whether exact or in a “not to exceed” amount, and the net settlement amount.
Document Type
Preliminary Approval Motion
Filing & Service rules
Electronic Filing Rules
Electronic filing is mandatory except for self-represented litigants and parties or attorneys with an electronic-filing exemption.
Except for self-represented litigants, or parties or attorneys who have obtained an exemption from mandatory electronic filing, parties must electronically file documents.
Page 1 | ELECTRONIC FILING
Ex parte applications must be filed electronically.
Ex Partes must be e-filed.
Page 1 | EX PARTE APPLICATIONS
Filing Timing and Cure Windows
The joint IDC statement must be filed and lodged directly in S33 by 3:00 p.m. no later than one week before the informal discovery conference.
The Joint IDC statement shall be filed and lodged directly in S33 by 3:00 p.m. no later than one week prior to the IDC.
Page 2 | III. Procedure
Replies to motions in limine are due on the Trial Readiness Conference date.
Replies are due on the date of the Trial Readiness Conference.
Page 1 | MOTIONS IN LIMINE
Motions in limine will be heard on the first day of trial, but the Trial Readiness Conference should be treated as the hearing date for service and filing deadlines.
MOTIONS IN LIMINE- Motions in limine (“MILs”) will be heard on the first day of trial. However, the parties should consider the Trial Readiness Conference the hearing date for purposes of service and filing dates.
Page 1 | MOTIONS IN LIMINE
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.
TRIAL DOCUMENTS- The parties are ordered to meet and confer with respect to all issues arising from this Order and to exchange all necessary documents such that on the date of the TRC, the following documents are filed directly in DEPT $33:
Page 1 | TRIAL DOCUMENTS
A motion seeking permission to mention other claims or actions must be served and filed as if the Trial Readiness Conference were the hearing date; an untimely or mid-trial motion requires a showing of good cause.
5. Evidence of, or reference to, other claims or actions against any party to the litigation shall not be allowed without permission of the court. Any motion seeking permission must be served and filed as if the Trial Readiness Conference were the hearing date. Untimely motions or motions made mid-trial will not be considered without a showing of good cause.
Page 2 | SUA SPONTE RULINGS OF THE COURT FOR TRIAL
A motion seeking permission to reference a party's financial position or wealth must be served and filed as if the Trial Readiness Conference were the hearing date; an untimely or mid-trial motion requires a showing of good cause.
6. Evidence of, or reference to, the financial position or wealth, or lack thereof, of any party to the litigation, shall not be allowed without permission from the court. Any motion seeking permission must be served and filed as if the Trial Readiness Conference were the hearing date. Untimely motions or motions made mid-trial will not be considered without a showing of good cause.
Page 2 | SUA SPONTE RULINGS OF THE COURT FOR TRIAL
If the parties do not arrange a trial reporter, no trial activity may commence until the Court receives a signed Joint Settled Statement by 10:00 a.m. the following court day.
The Court will not continue the trial until it receives a Joint Settled Statement, i.e. if the Court does not receive a signed Joint Settled Statement by 10:00 a.m. the following court day, no openings, testimony, closings, etc. may commence.
Page 1 | COURTROOM OPERATIONS
A party with a CRC rule 3.55(7) fee waiver may request an official court reporter by filing local form LACIV 2699 at least ten calendar days before the hearing or trial.
A party who has received a fee waiver pursuant to CRC, rule 3.55(7) may request an official court reporter by filing local form LACIV 2699 at least 10 calendar days before the hearing or trial.
Page 1 | COURTROOM OPERATIONS
The Joint IDC statement must be filed and lodged directly in S33 by 3:00 p.m. no later than one week before the IDC.
The Joint IDC statement shall be filed and lodged directly in S33 by 3:00 p.m. no later than one week prior to the IDC.
Page 1 | Procedure
An electronically filed document may take one to two business days to appear on the docket and up to 120 days to reach chambers.
Please be aware that it may take 1-2 business days for an electronically filed document to appear on the Court’s docket and it may take up to 120 days for the document to be delivered to chambers.
Page 1 | ELECTRONIC FILING
Service and Proof of Service Rules
Notice of the IDC must be provided to all parties.
Notice of the IDC must be given to all parties.
Page 3 | IV. Notice and Attendance
Moving papers and oppositions—and not replies—must be served and filed under Code of Civil Procedure section 1005(b).
Moving papers and oppositions ONLY shall be served and filed according to Code of Civil Procedure § 1005(b).
Page 1 | MOTIONS IN LIMINE
A motion seeking permission to reference other claims or actions must be served as if the Trial Readiness Conference were the hearing date.
5. Evidence of, or reference to, other claims or actions against any party to the litigation shall not be allowed without permission of the court. Any motion seeking permission must be served and filed as if the Trial Readiness Conference were the hearing date.
Page 2 | SUA SPONTE RULINGS OF THE COURT FOR TRIAL
Unless the court permits an exception, a witness may not be called without notice to all parties of the testimony date, given no later than the end of the court day immediately preceding the witness's testimony.
1, No witness may be called except with court permission in exceptional circumstances, unless notice has been given to all parties of the date when the witness will testify. Such notice shall be given no later than at the end of the court day proceeding the court day before the witness is to testify.
Page 2 | SUA SPONTE RULINGS OF THE COURT FOR TRIAL
A motion seeking permission to reference a party's financial position or wealth must be served as if the Trial Readiness Conference were the hearing date.
6. Evidence of, or reference to, the financial position or wealth, or lack thereof, of any party to the litigation, shall not be allowed without permission from the court. Any motion seeking permission must be served and filed as if the Trial Readiness Conference were the hearing date.
Page 2 | SUA SPONTE RULINGS OF THE COURT FOR TRIAL
Notice of the informal discovery conference must be provided to all parties.
Notice of the IDC must be given to all parties.
Page 1 | Notice and Attendance
Filing Fees and Waivers
The motion fee must be paid when the hearing reservation is made online.
Motion fee payments are required at the time reservations are made online.
Page 1 | LAW AND MOTION
An ex parte filing fee must be paid before the applicant appears in court.
Applicants must comply with CRC, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in court.
Page 1 | EX PARTE APPLICATIONS
Courtesy Copy Requirements
One exhibit copy must be provided to the court, one to the witness, and one to each other party.
Exhibits shall be place in 3-ring binders with 1 copy for the Court, 1 for the witness and 1 for all other parties to the action.
Page 1 | EXHIBITS
Courtesy copies generally must be delivered within one court day after electronic filing, but reply briefs must be delivered on the day the reply is due.
For these motions, courtesy copies must be delivered within one court day of the electronic filing, except for reply briefs which must be delivered on the day the reply is due.
Page 1 | LAW AND MOTION
Courtesy copies are required for summary-judgment and summary-adjudgment filings, Anti-SLAPP filings, and documents containing ten or more exhibits.
Courtesy copies are required for all documents related to motions for summary judgment and/or summary adjudication, all documents related to Anti-SLAPP motions, and all documents with ten exhibits or more.
Page 1 | LAW AND MOTION
Courtesy copies of ex parte applications must be delivered to Department S33 before 2:00 p.m. on the preceding day.
Courtesy copies shall be provided and dropped in Department S33 before 2 p.m. the day prior.
Page 1 | EX PARTE APPLICATIONS
Counsel choosing to file a document close to the hearing must lodge a courtesy copy at least 72 hours before the hearing or the Court will not consider the document.
Should counsel choose to do so, a courtesy copy is mandatory. The courtesy copy must be lodged at least 72 hours prior to the hearing. Otherwise, the Court will not consider the document.
Page 1 | ELECTRONIC FILING
Required courtesy copies must generally comply with CRC rule 3.1110(f), but need not place a tab below each exhibit, and must be lodged in a right-side-tabbed binder.
The courtesy copies must comply with CRC, rule 3.1110(f), except for the requirement that each exhibit be separated by a tab below the bottom. The courtesy copies must be lodged in a binder with tabs on the right side of the page for ease of reference by the Court.
Page 1 | LAW AND MOTION
A working copy should be provided to the judge in a tabbed binder for convenience.
A working copy for the judge’s convenience should be provided in a tabbed binder.
Page 1 | TRIAL DOCUMENTS
Noncompliance with the courtesy-copy binder rule may result in a continuance or the Court disregarding the exhibits.
Failure to comply with this rule may result in the Court continuing the hearing or not considering the exhibits.
Page 1 | LAW AND MOTION
Courtesy copies are not required for electronically filed motions other than those expressly identified in the standing order.
Courtesy copies are not necessary for other electronically filed motions.
Page 1 | LAW AND MOTION
Department S33 requests courtesy copies.
S33 requests courtesy copies.
Page 1 | COURTESTY COPIES
Sealing & Redaction Procedures
Sealed-document filings must strictly comply with CRC rule 2.551 and the following provisions.
Strict compliance with CRC, rule 2.551 et. seq. is required.
Page 1 | Sealed documents
Filing Bundling Requirements
Any provided trial brief must be included in the judge's working binder with the other trial documents.
If trial briefs are provided, they shall be included in the judge’s working binder with the witness list, exhibit list, etc.
Page 1 | TRIAL BRIEFS
Neither side may file other substantive documents addressing the discovery issues, and disputes exceeding the five-page IDC scope must be addressed across multiple IDC dates.
No other substantive documents on the discovery issues (propounding and/or responsive documents, briefs, etc.) shall be filed by either side. Disputes that are beyond the five-page scope must be spread over multiple IDC dates.
Page 1 | Procedure
Pre-Motion Conference Requirements
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.
Page 2 | III. Procedure
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.
Page 2 | II. General
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.
Page 1 | E. DISCOVERY
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.
Page 1 | Procedure
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.
Page 1 | Application
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.
Page 1 | General
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.
Page 1 | General
Adjournment & Extension Requirements
Except for the specified small-claims matters, the Court does not accept continuance requests made in declarations and will disregard them.
With the exception of small claims collections matters with limited jurisdiction and an unserved Defendant, the Court does not accept declarations requesting to continue hearings, including default prove-up hearings, trial readiness conferences, and trials. The Court will disregard any request made in a declaration.
Page 1 | HEARING CONTINUANCES
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.
Absent a formal request at the Trial Readiness Conference, mini-openings are limited to three minutes per party. The Court may extend the time for mini-openings upon a showing of good cause.
Page 3 | TRIAL DOCUMENTS
Chambers Communication Rules
A discovery conference must be requested by email to the Judicial Assistant and Courtroom Attendant, copied to all participating opposing counsel, and the request must state the case number and name in the subject line and identify the requesting party, discovery issue, and response due date in the body.
To schedule a Discovery Conference, please email the request to the Judicial Assistant at AArroyo@sb-court.org and the Courtroom Attendant at MaMiranda@sb-court.org, with all opposing counsel who is to participate included. The request should include the case number and name in the subject line. Please provide in the body: (1) which party is requesting the conference; (2) what discovery is at issue; and (3) the response due date. Upon receipt of the request, the judicial assistant will respond with the next available conference date, along with further instructions.
Page 2 | II. General
A party needing an accommodation should notify courtroom staff in advance so the court can attempt to facilitate the request.
If you need accommodation, please inform the courtroom staff in advance, so that we can attempt to facilitate your request.
Page 1 | INTERPRETERS, ACCESSIBILITY, AND ACCOMMODATION
Parties or counsel must contact court staff if they will be late for a hearing.
If parties/counsel are going to be late for a hearing, please contact the court staff.
Page 1 | GENERAL
A discovery conference must be scheduled by emailing the Judicial Assistant and Courtroom Attendant, including participating opposing counsel, the case number and case name in the subject line, and the requesting party, discovery issues, and response due date in the body; the Judicial Assistant will provide the next available date and instructions.
To schedule a Discovery Conference, please email the request to the Judicial Assistant at AArroyo@sb-court.org and the Courtroom Attendant at MaMiranda@sb-court.org, with all opposing counsel who is to participate included. The request should include the case number and name in the subject line. Please provide in the body: (1) which party is requesting the conference; (2) what discovery is at issue; and (3) the response due date. Upon receipt of the request, the judicial assistant will respond with the next available conference date, along with further instructions.
Page 1 | General
Questions may be directed by telephone to the judicial assistant or courtroom attendant at the listed numbers.
IF YOU HAVE ANY QUESTIONS, PLEASE CALL MY JUDICIAL ASSISTANT, MS. AMIE ARROYO, AT 909-708-8850 or MY COURTROOM ATTENDANT, MS. MARSHA MIRANDA, AT 909-708-8814.
Page 2 | LOCAL RULES
Before the hearing, the completed reporter stipulation may be emailed to Department S33 at aaroyo@sb-court.org.
Prior to the hearing, you can email the completed Stipulation to Department S33 at aaroyo@sb-court.org.
Page 1 | COURTROOM OPERATIONS
Court staff may be contacted about non-late-related matters only during the stated morning and afternoon windows.
For all other inquiries, please contact the court staff between 10:00 a.m. and 12:00 p.m. or between 2:00 p.m. and 4:30 p.m.
Page 1 | GENERAL
After receiving a discovery conference scheduling request, the Judicial Assistant will provide the next available conference date and additional instructions.
Upon receipt of the request, the judicial assistant will respond with the next available conference date, along with further instructions.
Page 1 | General