Court Rules

San Diego Superior Court Pre-Motion Conference Requirements

15 rules from official source documents

Pre-motion conference and letter requirements before filing motions, including sequential steps. This page is scoped to San Diego Superior Court; use the court rules overview to switch categories without leaving this court.

Parties must meet and confer before filing demurrers, motions to strike, and discovery motions.

The parties are hereby ordered to meet and confer before filing demurrers, motions to strike, and discovery motions.

Judge Michael T. SmythCRITICAL

Meet and confer with the responding party before filing a discovery motion to compel.

Before filing a discovery motion to compel further responses, meet and confer with the responding party to attempt to resolve any dispute.

Judge Rachel L. JensenCRITICAL

Parties must meaningfully meet and confer before setting an ex parte hearing; a mere email is insufficient.

Meaningful meet and confer required before setting an Ex parte hearing. Sending an email to opposing counsel stating that the matter has been set for a hearing is not considered meaningful.

Judge Victor M. TorresCRITICAL

Counsel must meet and confer before filing a demurrer.

Counsel must meet and confer prior to filing demurrers (see CCP 430.41).

Judge Victor M. TorresCRITICAL
Required
Always

Parties and counsel must comply with CRC 5.98 mandatory meet and confer and document exchange requirements before the hearing.

The Court expects all parties and counsel to fully comply with California Rule of Court section 5.98 (related to Mandatory meet and confer requirements and document exchange) in advance of the hearing date.

Judge Adam WertheimerWARNING

Counsel must meet and confer before filing a demurrer, per CCP 430.41.

Counsel must meet and confer prior to filing demurrers (see CCP 430.41).

Judge Cynthia A. FreelandWARNING

Counsel must meet and confer before any ex parte hearing to pare down disputed issues.

the court requires that counsel meet and confer prior to any such ex parte hearing so that the disputed issues have been pared down as much as possible by the parties before presentation to the court.

Judge Gregory W. PollackWARNING

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

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

Judge Gregory W. PollackWARNING

Ex parte appearances are not required for stipulations extending arbitration or expert designation dates, or for applications and orders for publication with a declaration of due diligence.

No ex parte appearances are required for the following: -Stipulation for order extending arbitration date. -Stipulation for order extending expert designation dates. -Application and Order for publication with declaration of due diligence.

Judge Michael D. WashingtonWARNING

After three or more discovery motions, an Informal Discovery Conference (IDC) is required before the motion is heard; must contact Calendaring Clerk to schedule.

The Court does not require that an Informal Discovery Conference (IDC) be held prior to counsel reserving a discovery motion date. However, if a party has filed three or more discovery motions the Court will no longer hear such motions prior to an IDC being held. You must contact the Calendaring Clerk to schedule an IDC to be heard in advance of the motion date.

Judge Michael T. SmythWARNING
Required
Always

Parties must meet and confer before trial to attempt settlement.

Before trial, the Court requires the parties to talk by phone or in-person to see if they can reach an agreement to settle the case out of court.

Judge Rachel L. JensenWARNING
Required
Always

Before trial, parties must share exhibits with opposing parties, identify witnesses, and estimate trial time.

Before trial, show your exhibits to the opposing parties, identify your witnesses, and estimate how much time your case will take.

Judge Rachel L. JensenWARNING

A meaningful meet and confer process is required before filing any in limine motion.

A meaningful meet and confer process is required before filing any in limine motion.

Judge William Y. WoodWARNING

Participation in an Informal Discovery Conference before filing discovery motions is encouraged but not required.

Participation in an Informal Discovery Conference (IDC) is not required but is highly encouraged.

Judge Euketa OliverINFO

Guardian ad litem petitions, publication of summons applications, and default prove-up packages may be filed ex parte without a court appearance.

Petitions for appointment of a guardian ad litem, applications for an order for publication of summons, and submissions of a default prove-up package may be filed ex parte without the necessity of a court appearance.

Judge Gregory W. PollackINFO
Common questions about San Diego Superior Court pre-motion conference requirements

Does San Diego Superior Court require a pre-motion conference or letter before filing a motion?

San Diego Superior Court rules set a pre-motion procedure for discovery. Meet and confer with the responding party before filing a discovery motion to compel.

View ruleSource: page 3, section LAW AND MOTION

Does San Diego Superior Court require a pre-motion conference or letter before filing a motion?

San Diego Superior Court rules set a pre-motion procedure for covered motions. Parties must meet and confer before trial to attempt settlement.

View ruleSource: page 2, section TRIALS