San Diego Superior Court Document Filing Requirements

WARNINGCivil cases

Applies to

Proposed order

Parties must prepare proposed orders, judgments, and other required documents.

Parties are responsible for preparing proposed orders, judgments, and other required documents.

WARNINGCivil cases

Applies to

Witness list

A witness list is required as part of the trial notebook.

Witness List

WARNINGCivil cases

Applies to

Exhibit list

An exhibit list in grid format is required as part of the trial notebook.

Exhibit List - Grid format – see below for example

WARNINGCivil cases

Applies to

Stipulation

Parties must meet and confer on evidence admissibility before submitting trial briefs or exhibit lists and prepare a written stipulation if issues are agreed.

The parties are ordered to meet and confer as to the admissibility of evidence prior to the submission of trial briefs or exhibit lists and to attempt to settle as many issues as possible. If there is agreement as to some issues, the parties are ordered to prepare a written stipulation in advance of trial.

WARNINGCivil cases

Applies to

Witness list

WITNESS LIST

WITNESS LIST

WARNINGCivil cases

Applies to

Exhibit list

The exhibit list must have objections noted.

The exhibit list is to have objections noted.

WARNING

Applies to

Special verdict form

Special verdict forms should follow CACI, include all causes of action and all parties, be complete, and be on pleading paper without any firm's name.

Special Verdict Forms - either an agreed-upon forms or each side’s proposed forms. The forms should follow CACI as closely as possible and include all cause of actions and all parties. The verdict forms should be complete and on pleading paper without any firm’s name.

WARNING

Applies to

Proposed protective order

Proposed stipulated protective orders are approved only if their language is consistent with the Court's stated policy.

Proposed Stipulated Protective Orders for protection of confidential information will only be approved by the Court if the language in the proposed order is consistent with the Court's stated policy.

WARNING

Applies to

Witness list

The Joint Witness List must include a short description of each witness.

Copy of Joint Witness List with a short description of the witness (i.e. "Dr. Jane Smith, an internist from Mercy Hospital");

WARNING

Applies to

Jury instructions

Jury instructions must be submitted in sequential order, with post-it notes marking any objected-to instructions and indicating who objects and the basis.

Jury Instructions - One set in sequential order with post-it notes on any objected-to instructions, indicating who objects, and the basis for the objection;

WARNING

Applies to

Exhibit list

The Joint Exhibit List must follow the grid format from the Advance Trial Review Orders.

Copy of Joint Exhibit List (follow grid format on attachment to the Advance Trial Review Orders);

WARNINGCivil cases

Applies to

Case management statement

Parties must meet and confer before the CMC and file a Case Management Statement per California Rules of Court Rules 3.724 and 3.725.

Parties and counsel must comply with California Rules of Court and San Diego Superior Court Local Rules, including the requirements that the parties meet and confer prior to the CMC and file a Case Management Statement. (California Rules of Court, Rule 3.724 and 3.725.)

WARNINGCivil cases

Applies to

Stipulation to continue

Must include

proposed order

Please provide a proposed order with any stipulation.

Please provide a proposed order with any stipulation.

WARNINGCivil cases

Applies to

Default judgment

Must include

proposed order

Plaintiff should submit a proposed judgment in connection with any request for entry of a default judgment.

Plaintiff should submit a proposed judgment in connection with any request for entry of a default judgment.

WARNINGCivil cases

Applies to

Case management statement

Parties must file and serve a Case Management Statement in compliance with Rule 3.725.

The parties are expected to file and serve a Case Management Statement in compliance with Rule 3.725 of the California Rules of Court.

WARNINGCivil cases

Applies to

Trial call materials

At trial call for jury trials, parties must provide verdict form, jury instructions, exhibit list, witness list, statement of the case, joint trial notebook, and in limine motion notebook.

At the trial call for jury trials, the parties shall provide the following materials: (1) the verdict form(s), in final format, so that the form(s) can be photocopied and given to the jury; (2) the jury instructions, in final format, so that the instructions can be photocopied and given to jury; (3) the exhibit list, in the format identified in the Local Rules; (4) a list of witnesses expected to be called at trial, in a format that is suitable for photocopying to give to prospective jurors; and (5) a statement of the case to be read to prospective jurors. Additionally, counsel must provide a joint trial notebook and an in limine motion notebook, tabbed by motion and including objections.

INFOCivil cases

Applies to

Cmc statement

Continued CMCs do not require a new statement unless the Court directs otherwise.

Continued CMCs do not require a new statement unless directed by the Court.

INFOCivil cases

Applies to

Discovery motion

The Court permits a moving party to submit a concise outline of the discovery request and each response in dispute without express court order.

Code of Civil Procedure sections 2030.300, 2031.310, and 2033.290 allow a court to authorize a moving party to submit a concise outline of the discovery request and each response in dispute. This Court permits such practice without express court order.

INFOCivil cases

Parties should not refer to IDC discussions in any subsequent papers.

Parties should not refer to any discussions in any subsequent papers.

INFOCivil cases

Applies to

Guardian ad litem application

Guardian ad litem applications may be submitted for review without an appearance.

Applications may be submitted for review without an appearance.

INFOCivil cases

Applies to

Idc request

The party requesting an IDC should first meet and confer with the opposing party to discuss scheduling.

The party requesting an IDC should first meet and confer with the opposing party to discuss scheduling.

INFOCivil cases

Applies to

Notice of intent to appear

No notice of intent to appear is required to appear for oral argument.

No notice of intent to appear is required to appear for oral argument.

INFOCivil cases

Applies to

Guardian ad litem application

Guardian ad litem applications are governed by Local Rule 2.4.6.

Applications for appointment of a guardian ad litem are governed by LR 2.4.6.

INFOCivil cases

Applies to

Stipulation

Must include

proposed order

Stipulated continuance requests should include a proposed order.

The stipulation should include a proposed order.

INFOCivil cases

Applies to

Ex parte application

No appearance is required at an ex parte hearing if all parties stipulate to the requested relief.

No appearance is required if all parties stipulate to the requested relief.

INFOCivil cases

Applies to

Exhibits

Exhibits judicially noticed are not marked 'RECEIVED' on the tag; impeachment exhibits are identified as 'the next in order' and the clerk marks and adheres the tag.

When judicial notice is taken of a document/exhibit, it is not indicated “RECEIVED” on the exhibit tag. If there are impeachment exhibits, they can be identified as “the next in order” and the clerk will mark and adhere the exhibit tag.

INFOCivil cases

Applies to

Exhibits

The Court strongly encourages the parties to agree on the admissibility of exhibits, if possible, and the parties are ordered to meet and confer regarding the same. If parties stipulate to exhibits, note the stipulated exhibits on the cover sheet in the binder.

The Court strongly encourages the parties to agree on the admissibility of exhibits, if possible, and the parties are ordered to meet and confer regarding the same. If parties stipulate to exhibits, note the stipulated exhibits on the cover sheet in the binder.

INFOCivil cases

Applies to

Exhibits

Exhibits must be moved into evidence as presented and are deemed authenticated absent a genuine dispute.

Move exhibits into evidence as you present them at trial. Exhibits are deemed authenticated unless there is a genuine dispute. You need not ask a witness to authenticate a document unless the opposing party objects.

INFOCivil cases

Applies to

Exhibits

Parties must include a means of return for all exhibits.

Please be sure to include a means of return for all exhibits.

INFOCivil cases

Applies to

Exhibits

Please meet and confer in advance as to the admissibility of evidence.

Please meet and confer in advance as to the admissibility of evidence.

INFO

Applies to

Exhibits

Parties are ordered to meet and confer on exhibit admissibility; stipulated exhibits must be noted on the cover sheet or exhibit lists, and the Court will not receive stipulated exhibits en masse.

The Court strongly encourages the parties to agree on the admissibility of exhibits, if possible, and the parties are ordered to meet and confer regarding the same . If parties stipulate to exhibits, note on the cover sheet in the binders or on the exhibit lists which exhibits those are . The Court will not receive stipulated exhibits into evidence en masse, but prior stipulations to the admissibility of exhibits will create greater efficiency and save time during the proceeding.

INFO

Applies to

Exhibits

Parties must include a means of return for all exhibits and lodgments.

Be sure to include a means of return for all exhibits and lodgments.

WARNINGCivil cases

For guardian ad litem, publication, pro hac vice, and default prove-up applications, moving papers must be submitted (with proof of service if applicable) and the court may set a hearing if necessary.

Guardian and Testament/Publication of Summons/Pro Hac Vice/Default prove ups: Submit moving papers for the court, with proof of service, if applicable; the court may set a hearing if deemed necessary.