Court Rules

Limits & Logistics

Document Limits

Settlement Conference StatementCourt-wide
5 pgs
Trial BriefCourt-wide
5 pgs

Courtesy Copies

Pro Hac Vice Application, Motion, Opposition, Reply, Trial Readiness Report, Trial Brief

EEC Request

Court-wide
  • 1 copy

ENE Request, Proposed Order

Court-wide
  • 1 copy

Ex Parte Application, Supporting Document

Court-wide
  • By Noon the Court Day Before the Ex Parte Appearance
  • No Later Than Noon the Court Day Before the Ex Parte Appearance

Adjournments

Court-wide

Request must include

Reason for Request
5Court Daysnotice
2Court Daysnotice

Communication

Phone
Court-wide
(619) 450-7478
Scheduling
Phone
Court-wide

Clerk

Scheduling
Phone
Court-wide

Duty Judge

Emergencies
Filters:

Document Filing Requirements8 rules

Filing RequirementsMandatoryCivil cases

A completed joint trial readiness conference report shall be filed in advance of the hearing pursuant to local rule 2.1.15.

department 64 policies and procedures - honorable loren g freestone · Sep 2025 · p. 3|SectionTrial Readiness Conferences
Filing RequirementsMandatoryCivil cases

Applications must include proof of service on the State Bar of California, proof of payment of the required fee, and a proposed order.

Document
Pro hac vice application

Must include

  • Proposed order
  • Certificate of service
department 64 policies and procedures - honorable loren g freestone · Sep 2025 · p. 3
Filing RequirementsMandatoryCivil cases

All motions in limine must be filed per local rule 2.1.18.

department 64 policies and procedures - honorable loren g freestone · Sep 2025 · p. 3|SectionTrial Calls
Filing RequirementsMandatoryCivil cases

At trial call, counsel must bring a joint trial notebook containing the enumerated pretrial materials.

Document
Joint trial notebook

Must include

  • Exhibit list
  • Table of contents

Court's wording

At trial call, counsel must bring a joint trial notebook, which should be comprised of the following: 1. Table of Contents 2. Copy of Joint Trial Readiness Report 3. Copies of Motion in Limine and Oppositions (in order) 4. Joint Witness List (with description of witnesses’ expected testimony) 5. Joint Exhibit List 6. Copies of Trial Briefs (if any) 7. Joint Statement of the Case 8. Proposed Voir Dire Questions (if any) 9. Jury Instructions (packet agreed upon and packet of those not agreed upon, with indication of who is offering and objecting)

department 64 policies and procedures - honorable loren g freestone · Sep 2025 · p. 3|SectionTrial Calls
Filing RequirementsMandatoryCivil cases

All exhibits must be pre-marked in an up-to-date exhibit book.

department 64 policies and procedures - honorable loren g freestone · Sep 2025 · p. 3|SectionTrial Calls
Filing RequirementsMandatoryCivil cases

Papers must comply strictly with California Rules of Court, rule 3.1800. Non- complying papers will be returned with a notation of defects.

department 64 policies and procedures - honorable loren g freestone · Sep 2025 · p. 3|SectionDefault Judgment by Court
Filing RequirementsImportantCivil cases

10. Special Verdict Form (either an agreed upon form or each side’s proposed forms). If the parties fail to make a genuine effort to limit disputes on the form of the special verdict, a general verdict form will be utilized.

department 64 policies and procedures - honorable loren g freestone · Sep 2025 · p. 3|SectionTrial Calls
Filing RequirementsImportantCivil cases

Proposed default judgments claiming punitive damages and/or non-economic damages will usually require a hearing.

department 64 policies and procedures - honorable loren g freestone · Sep 2025 · p. 3|SectionDefault Judgment by Court

Filing & Service rules

Filing Timing and Cure Windows

Trial briefs must be filed five court days before trial call.

Trial briefs must be filed five court days prior to trial call.

Civil cases

Page 3 | Trial Calls

A party opposing an application may appear ex parte within five days to request a briefing schedule.

If a party opposes an application, that party may appear ex parte within five days to request a briefing schedule.

Civil cases

Page 3

Service and Proof of Service Rules

All exhibits, demonstrative aids, and other material for opening statements must be shared with opposing counsel in advance.

All exhibits, demonstrative aids, or other material to be used in opening statements must be shared with opposing counsel in advance.

Civil cases

Page 3 | Trial Calls

Filing Fees and Waivers

A required fee applies to pro hac vice applications, and proof of its payment must accompany the application.

proof of payment of the required fee

Civil cases

Page 3

Courtesy Copy Requirements

Courtesy copies of pro hac vice applications, noticed motions, oppositions, replies, joint trial readiness conference reports, and trial briefs should be placed in the Department 64 drop box outside the Business Office.

Courtesy copies of the following documents should be placed in the Department 64 drop box, located outside the Business Office on the second floor of the Hall of Justice: • Ex parte applications (delivered no later than 12:00 p.m. the day before the hearing) • Pro hac vice applications • Noticed motions, oppositions, and replies • Joint trial readiness conference reports • Trial briefs

Civil cases

Page 3 | Courtesy Copies

Court-wide rules

Applies court-wide

These 304 rules apply across San Diego Superior Court. Where this judge's own standing orders above address the same topic, the judge's requirement controls.

Filing Requirements

All 101
  • Applies to
    Request for court reporter

    A request for a court reporter by a party with a fee waiver should use the designated form.

  • Applies to
    Exhibit exception application

    Applications for specified exhibit exceptions must be made in writing to the Criminal Supervising Judge or designee, with notice to the exhibits custodian and all parties.

  • Applies to
    Exhibit record

    When an exhibit is ordered returned, the submitting party must provide the court with a complete photographic or electronic record of it.

Filing Timing

All 48

  • Unless otherwise specified, references to a day mean a calendar day.

  • Such a request should be made using the Request for Court Reporter by a Party with a Fee Waiver form (SDSC Form #ADM-379), available on the court’s website, www.sdcourt.ca.gov, and must be filed with the clerk at least 10 days before the proceeding. If the requesting party received less than 10 days' notice of the hearing or trial, the requesting party must file the request as soon as practicable.

  • A party seeking to be heard about a transfer ordered without a hearing or outside a hearing must request a hearing within 10 days after notice of transfer.

Service

All 46

  • The exhibits custodian and all parties must receive notice of applications for the specified exhibit exceptions.

  • If further proceedings require a civil-case exhibit, the party that introduced it must promptly deliver it to the court and notify all parties.

  • The judgment creditor receives conformed copies showing the appearance date, time, and place for service.

Communication

All 28

  • Court users are asked to request interpreters as far in advance as possible.

  • Requests for disability accommodations should be made as far in advance as possible and pursuant to California Rules of Court, rule 1.100.

  • Court users are asked to advise the court as soon as possible when an interpreter is no longer needed.

More categories

View all San Diego Superior Court rules
About Judge Loren G. Freestone

Judge Loren G. Freestone is a judge on the Superior Court of California, County of San Diego, the state trial court serving San Diego County.

Practitioners will find department-specific policies and procedures for Department 64 in this judge's published procedures.

Common questions about Judge Loren G. Freestone's rules

Are courtesy copies required for Judge Loren G. Freestone?

Courtesy-copy rule applies for pro hac vice applications, motions, oppositions, replys, trial readiness reports, and trial briefs. Courtesy copies of pro hac vice applications, noticed motions, oppositions, replies, joint trial readiness conference reports, and trial briefs should be placed in the Department 64 drop box outside the Business Office.

View ruleSource: page 3, section Courtesy Copies

What must be included with trial readiness report filings before Judge Loren G. Freestone?

A completed joint trial readiness conference report must be filed in advance of the hearing per local rule 2.1.15.

View ruleSource: page 3, section Trial Readiness Conferences

What must be included with pro hac vice application filings before Judge Loren G. Freestone?

The rule requires proposed order and certificate of service. Pro hac vice applications must include proof of service on the State Bar of California, proof of payment of the required fee, and a proposed order.

View ruleSource: page 3

Are filing fees or waivers addressed before Judge Loren G. Freestone?

A fee is required for covered filings. A required fee applies to pro hac vice applications, and proof of its payment must accompany the application.

View ruleSource: page 3

What filing deadlines does Judge Loren G. Freestone set?

Trial briefs must be filed five court days before trial call.

View ruleSource: page 3, section Trial Calls

What rule applies to serving the opposing party before Judge Loren G. Freestone?

Details: recipient: the opposing party. All exhibits, demonstrative aids, and other material for opening statements must be shared with opposing counsel in advance.

View ruleSource: page 3, section Trial Calls
Complete rules summary for Judge Loren G. Freestone

A completed joint trial readiness conference report must be filed in advance of the hearing per local rule 2.1.15.

Pro hac vice applications must include proof of service on the State Bar of California, proof of payment of the required fee, and a proposed order.

A party opposing an application may appear ex parte within five days to request a briefing schedule.

All exhibits must be pre-marked in an up-to-date exhibit book.

If the parties fail to make a genuine effort to limit disputes on the special verdict form, the court will utilize a general verdict form.

All exhibits, demonstrative aids, and other material for opening statements must be shared with opposing counsel in advance.

At trial call, counsel must bring a joint trial notebook containing the enumerated pretrial materials.

Trial briefs must be filed five court days before trial call.

Proposed default judgments claiming punitive or non-economic damages will usually require a hearing.

Default judgment papers must strictly comply with California Rules of Court rule 3.1800; non-complying papers will be returned with a notation of defects.

Courtesy copies of pro hac vice applications, noticed motions, oppositions, replies, joint trial readiness conference reports, and trial briefs should be placed in the Department 64 drop box outside the Business Office.

A required fee applies to pro hac vice applications, and proof of its payment must accompany the application.

All motions in limine must be filed per local rule 2.1.18.

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