Court Rules

San Francisco Superior Court Pre-Motion Conference Requirements

37 rules from official source documents

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

Attorneys must meet and confer before filing any noticed motion, and the moving party’s counsel must file a declaration describing those efforts.

All attorneys must meet and confer prior to filing any noticed motion. All motions must be supported by a declaration by counsel for the moving party concerning efforts to meet and confer.

Court-level rulesCRITICALOfficial source

A representative submitting a W&I section 388 petition must meet and confer with other counsel and use Judicial Council Form JV-180.

Any person submitting such a petition on behalf of a currently represented party must meet and confer with other counsel concerning the request for the proposed change of order and use Judicial Council Form JV-180 (Request to Change Court Order).

Court-level rulesCRITICALOfficial source

If a will offered for probate has face alterations by interlineation or deletion, the personal representative must obtain a court determination of entitlement before seeking final distribution.

Where the will offered for probate contains alterations by interlineation or deletion on the face, the personal representative must obtain court determination of entitlement before petitioning for final distribution.

Court-level rulesCRITICALOfficial source

A defendant withdrawing a general time waiver must schedule a pretrial conference in the department where the case is pending.

Defendant shall also schedule a pretrial conference in the department where the matter is pending

Court-level rulesCRITICALOfficial source

Parties must meet and confer and participate in an IDC with the judge or court designee before any discovery motion is heard, and the IDC requirement applies to all discovery disputes.

Specifically, participation in the IDC does not negate the requirements of CCP § 2016.040 which requires parties to meet and confer before filing a Discovery Motion. The IDC must apply to all discovery disputes whether or not a discovery motion has been filed with the Court. No Discovery Motion will be heard until the parties have participated in an IDC with the Judge or a Court designee.

Court-level rulesCRITICALOfficial source

The parties must meet and confer on each motion in limine before filing it with the court.

Before any motions in limine (MIL) are filed with the Court, the parties must meet and confer on each MIL.

Court-level rulesCRITICALOfficial source

A discovery motion may not be filed until the parties have an informal discovery conference with the Court and the Court authorizes the motion.

No party may move to compel discovery, or file any other discovery motion, until the parties have had an informal discovery conference with the Court and the Court has authorized the motion(s).

Court-level rulesCRITICALOfficial source

Counsel must complete all meet-and-confer obligations and reach an impasse before requesting an informal discovery conference.

Counsel must have completed all meet and confer obligations and reached impasse before scheduling an informal discovery conference.

Court-level rulesCRITICALOfficial source

At least three court days before the informal discovery conference, counsel must email a joint dispute letter limited to five pages and single-spaced.

At least three court days before the informal discovery conference, counsel must email a joint letter outlining the discovery dispute, not exceeding 5 pages, single-spaced.

Court-level rulesCRITICALOfficial source

Attorneys must meet and confer before filing any noticed motion, and the moving party must provide counsel's declaration describing those efforts.

All attorneys must meet and confer prior to filing any noticed motion. All motions must be supported by a declaration by counsel for the moving party concerning efforts to meet and confer.

Court-level rulesCRITICALOfficial source

A represented party's person filing a W&I § 388 petition must meet and confer with other counsel and use Judicial Council Form JV-180.

Any person submitting such a petition on behalf of a currently represented party must meet and confer with other counsel concerning the request for the proposed change of order and use Judicial Council Form JV-180 (Request to Change Court Order).

Court-level rulesCRITICALOfficial source

A discovery motion cannot be heard until the parties participate in an informal discovery conference with the judge or court designee.

No Discovery Motion will be heard until the parties have participated in an IDC with the Judge or a Court designee.

Court-level rulesCRITICALOfficial source

A party intending to file a discovery motion must confer with the opposing party about IDC scheduling and provide mutually agreeable dates to the judge’s clerk.

The party intending to bring a discovery motion must confer with the opposing party regarding scheduling of the IDC and must provide mutually agreeable dates to the Judge’s clerk.

Court-level rulesCRITICALOfficial source

Counsel authorized to resolve the discovery dispute for the moving and opposing parties, including parties who joined or opposed the motion, must attend and participate in good faith at the IDC.

Counsel with full authority to resolve the discovery dispute on behalf of the moving and opposing parties, including any parties who have either joined or opposed the motion, must appear and participate in good faith at the IDC.

Court-level rulesCRITICALOfficial source

If the informal discovery conference does not resolve the dispute, counsel who participated must attend the discovery-motion hearing on those issues unless the court excuses them.

If the discovery dispute cannot be resolved at the IDC, then counsel for the parties who have participated at the IDC must attend the Discovery Motion hearing on those issues, if any, unless excused by the Court.

Court-level rulesCRITICALOfficial source

The parties must meet and confer on every motion in limine before filing it.

Before any motions in limine (MIL) are filed with the Court, the parties must meet and confer on each MIL.

Court-level rulesCRITICALOfficial source

Parties must attend an informal discovery conference and obtain court authorization before filing a discovery motion.

No party may move to compel discovery, or file any other discovery motion, until the parties have participated in an informal discovery conference with the court and the court has authorized the motion(s).

Court-level rulesCRITICALOfficial source

Counsel must complete meet-and-confer efforts through an in-person, video, or telephone meeting and reach impasse before requesting an informal discovery conference; email exchange alone is insufficient.

Counsel must complete all meet and confer obligations and reach impasse before scheduling an informal discovery conference. Counsel shall meet in person, by videoconference, or telephone; the exchange of emails is not sufficient.

Court-level rulesCRITICALOfficial source

At least five court days before the conference, counsel must email a single-spaced joint letter outlining the discovery dispute, limited to five pages, and deliver a courtesy copy to Department 613.

At least five court days before the informal discovery conference, counsel must email a joint letter outlining the discovery dispute—not exceeding 5 pages, single-spaced—and deliver a courtesy copy to department 613.

Court-level rulesCRITICALOfficial source

All ex parte applications require an appearance except applications for leave to serve a summons by posting and stipulated requests to restrict access to records.

3) All ex parte applications (except for (a) Application for Leave to Serve a Summons by Posting and (b) Stipulated Requests to Restrict Access to Records per C.C.P. 1161.2) require an appearance.

Court-level rulesCRITICALOfficial source

All attorneys must meet and confer before filing a noticed motion in a juvenile dependency case.

All attorneys must meet and confer prior to filing any noticed motion.

Court-level rulesCRITICALOfficial source

Every noticed motion must include the moving party’s counsel declaration describing the counsel’s meet-and-confer efforts.

All motions must be supported by a declaration by counsel for the moving party concerning efforts to meet and confer.

Court-level rulesCRITICALOfficial source

A person filing a W&I section 388 petition for a represented party must meet and confer with other counsel about the proposed order change and use form JV-180.

Any person submitting such a petition on behalf of a currently represented party must meet and confer with other counsel concerning the request for the proposed change of order and use Judicial Council Form JV-180 (Request to Change Court Order).

Court-level rulesCRITICALOfficial source

All parties must participate in an Informal Discovery Conference for every discovery dispute, and no discovery motion will be heard before the conference; parties must also make good-faith efforts to meet and confer before the IDC.

All parties must participate in the Court’s Informal Discovery Conference (“IDC”) as set forth below. The IDC does not limit or expand the rights of any party as set forth in CCP, CRC and LRSF. Specifically, participation in the IDC does not negate the requirements of CCP § 2016.040 which requires parties to meet and confer before filing a Discovery Motion. The IDC must apply to all discovery disputes whether or not a discovery motion has been filed with the Court. No Discovery Motion will be heard until the parties have participated in an IDC with the SAJ or a Court designee. The parties must make good-faith efforts to meet and confer in person or by remote technology prior to the IDC.

Court-level rulesCRITICALOfficial source

Parties must meet and confer on each motion in limine before filing it with the court.

Before any motions in limine (MIL) are filed with the Court, the parties must meet and confer on each MIL.

Court-level rulesCRITICALOfficial source

A motion hearing date and time must be reserved with the CEQA clerk and approved by the court before filing the motion.

All motion hearing dates must be reserved with the clerk of CEQA Department 606 prior to filing. Parties may not file a motion without the court’s approval of the hearing date and time.

Judge Stephen M. MurphyCRITICAL

Before filing any motion in limine, the parties must meet and confer on all such motions to attempt to reach stipulations.

Before any motions in limine (“MIL”) are filed with the Court, the parties are ordered to meet and confer on all MILs to determine if stipulations can be reached.

Judge Victor HwangCRITICAL

A motion to traverse, quash, or suppress should initially be presented to the judge who signed the search warrant at issue.

1) A motion to traverse, quash, or suppress should first be brought before the judge who signed the search warrant at issue.

Court-level rulesWARNINGOfficial source

After meeting and conferring, a party may request a Case Management Conference to address an unresolved Trial Setting Conference or trial-date issue.

Any party with an issue related to the TSC and/or trial date that has not been resolved after meeting and conferring with opposing counsel may ask the Court to set a Case Management Conference (“CMC”).

Court-level rulesWARNINGOfficial source

The potential moving party must confer with the opposing party about scheduling the IDC and provide mutually agreeable dates to the judge’s clerk.

The party intending to bring a discovery motion must confer with the opposing party regarding scheduling of the IDC and must provide mutually agreeable dates to the Judge’s clerk.

Court-level rulesWARNINGOfficial source

Before scheduling and noticing a law-and-motion hearing, the moving party should confer with all other parties and need not obtain court approval or a reservation number.

For motions to be filed, the moving party should confer with all other parties before scheduling and noticing a hearing, and may then e-file and notice the hearing in accordance with Code of Civil Procedure Section 1005 or other applicable requirements. The moving party does not need to clear the selected hearing date with or obtain a reservation number from the court Dept. 301/ 302 before filing the motion.

Court-level rulesWARNINGOfficial source

Before scheduling and noticing a discovery hearing, the moving party should confer with all other parties and need not obtain court approval or a reservation number.

For discovery motions to be filed, the moving party should confer with all other parties before scheduling and noticing a hearing, and may then e-file and notice the hearing in accordance with Code of Civil Procedure Section 1005 or other applicable requirements. The moving party does not need to clear the selected hearing date with or obtain a reservation number from the court before filing the motion.

Court-level rulesWARNINGOfficial source

The informal discovery procedure is mandatory for parties but optional for interested non-parties in discovery disputes.

The procedures outlined below apply only to parties. With regard to discovery disputes with non-parties, the interested parties may elect to participate in this procedure, but are not required to do so.

Court-level rulesWARNINGOfficial source

Before filing a motion, the moving party must confirm the availability of the hearing dates.

In advance of filing motions, the moving party must confirm the availability of dates set for hearings.

Court-level rulesWARNINGOfficial source

If the Supervising Asbestos Judge or trial judge allows additional motions in limine, a briefing schedule will then be ordered.

Should additional MILs be allowed by either the Supervising Asbestos Judge or the trial judge, a briefing schedule will be ordered at that time.

Judge Victor HwangWARNING

Parties are encouraged to confer with all other parties before scheduling and noticing a hearing.

Parties should confer with all other parties before scheduling and noticing a hearing.

Court-level rulesINFOOfficial source

A party whose request for additional motions in limine is denied may still object at trial when the evidence is presented because the denial is not a merits ruling.

If the right to bring additional MILs is denied, any party may still make trial objections at the time the evidence is proffered because this is not deemed a ruling on the merits.

Judge Victor HwangINFO
Common questions about San Francisco Superior Court pre-motion conference requirements

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

San Francisco Superior Court rules set a pre-motion procedure for covered motions. Attorneys must meet and confer before filing any noticed motion, and the moving party’s counsel must file a declaration describing those efforts.

View ruleSource: page 116, section 12.16 Motions

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

San Francisco Superior Court rules set a pre-motion procedure for covered motions. A representative submitting a W&I section 388 petition must meet and confer with other counsel and use Judicial Council Form JV-180.

View ruleSource: page 117, section 12.17 Procedure for Filing of Petitions Pursuant to W&I § 388

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

San Francisco Superior Court rules set a pre-motion procedure for will with interlineations or deletions. If a will offered for probate has face alterations by interlineation or deletion, the personal representative must obtain a court determination of entitlement before seeking final distribution.

View ruleSource: page 148, section 14.21 Wills with Interlineations or Deletions