Judge Mark A. McCannon
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- 1 copy • First Day Of Trial
- 1 copy • Upon Filing
- 3 copies • Day Of Trial
- Hand Delivery
- Two Court Days Before Ex Parte Appearance
Pretrial Order, Trial Document
- Hand Delivery
Proposed Order
Complaint Form
Court-wideCommunication
Chambers, Clerk
Chambers
Chambers, Clerk
Clerk
Phone
Clerk
Phone
Court-widePhone
Court-widePage & Word Limits17 rules
An informal-conference brief may not exceed three pages.
For these informal conferences, briefs on court pleading paper not to exceed three (3) pages – which must be served – may be submitted by email to the Court at dept2@sanmateocourt.org and complexcivil@sanmatecourt.org.
Informal Conference Brief
3 pages
Each side must serve and email the Court a short IDC brief, on court pleading paper, no more than five pages long, at least three court days before the IDC.
For the IDC, each side must serve and email to the Court at both dept2@sanmateocourt.org and complexcivil@sanmateocourt.org a short brief on court 3 pleading paper, limited to no more than five (5) pages, at least three (3) court days before the 5 IDC.
Idc Short Brief
5 pages
Each party’s explanation following a disputed jury instruction may not exceed one page.
Following each disputed instruction, each party shall explain, in no more than one page, why the Court should give that party’s proposed instruction or why the instruction should or should not be given.
Jury Instructions
1 pages
Each opposition to a motion in limine may not exceed five pages unless the court permits otherwise.
Each opposition is also limited to five (5) pages unless otherwise permitted by the Court.
Opposition
5 pages
Each motion in limine must address one separate topic and may not exceed five pages unless the court permits otherwise.
Each MIL should address a single, separate topic and shall be limited to five (5) pages in length unless otherwise permitted by the Court.
Motion In Limine
5 pages
If an overlapping-exhibit dispute is not informally resolved, each party must submit the disputed exhibit with the Joint Pretrial Conference Statement and explain its position in no more than one double-spaced page.
If the parties are unable to informally resolve the dispute, then each party shall submit its disputed exhibit with the Joint Pretrial Conference Statement and explain, in no more than one double-spaced page, why the Court should use its proposed exhibit.
Disputed Exhibit Explanation
1 pages
Each deposition-designation objection or response may not exceed one page.
Objections or responses may be no longer than one page.
Deposition Designation Objections
1 pages
Deposition Designation Responses
1 pages
Each party’s explanation for a disputed jury instruction may not exceed one page.
Following each disputed instruction, each party shall explain, in no more than one page, why the Court should give that party’s proposed instruction or why the instruction should or should not be given.
Disputed Instruction Explanation
1 pages
Each motion in limine is limited to five pages and should address one separate topic unless the court permits otherwise.
45. Each MIL should address a single, separate topic and shall be limited to five (5) pages in length unless otherwise permitted by the Court.
Motion In Limine
5 pages
Each opposition to a motion in limine is limited to five pages unless the court permits otherwise.
46. Each opposition is also limited to five (5) pages unless otherwise permitted by the Court.
Opposition
5 pages
If an overlapping-exhibit dispute is not informally resolved, each party must submit the disputed exhibit with the Joint Pretrial Conference Statement and provide an explanation in no more than one double-spaced page.
If the parties are unable to informally resolve the dispute, then each party shall submit its disputed exhibit with the Joint Pretrial Conference Statement and explain, in no more than one double-spaced page, why the Court should use its proposed exhibit.
Disputed Exhibit Submission
1 pages
Objections or responses to proposed deposition designations may not exceed one page.
Objections or responses may be no longer than one page.
Deposition Designations Objections Or Responses
1 pages
Each motion in limine is limited to five pages unless the court permits otherwise.
36. Each MIL should address a single, separate topic and shall be limited to five (5) pages in length unless otherwise permitted by the Court.
Motion In Limine
5 pages
Each opposition to a motion in limine is limited to five pages unless the court permits otherwise.
22 Each opposition is also limited to five (5) pages unless otherwise permitted by the 37. Court.
Opposition
5 pages
Objections and responses to proposed deposition designations may not exceed one page.
Objections or responses may be no longer than one page.
Objections Or Responses
1 pages
Unless the case is very complex, the proposed statement of the case may not exceed one double-spaced page.
Unless the case is very complex, this statement should not exceed one-page double spaced.
Proposed Statement Of The Case
1 pages
Unless the case is very complex, the proposed statement of the case should not exceed one page and should be double spaced.
Unless the case is very complex, this statement should not exceed one-page double spaced.
Statement Of The Case
1 pages
Document Format Requirements39 rules
Exhibits accompanying electronically filed briefs, declarations, or other documents must be electronically bookmarked.
Please note that any exhibits to electronically filed briefs, declarations, or other documents must be electronically “bookmarked” as required by CRC Rule 3.1110(f)(4).
The parties must submit joint tabbed binders containing the proposed deposition designations and objections, with one tab per witness, yellow highlighting for designations, red brackets for objections, and the related pleading included.
The parties must also submit to the Court joint tabbed binder(s) with the proposed deposition designations. Each tab should represent the testimony of a single witness. The proposed deposition designations must be highlighted in yellow with any objections bracketed in red. The binders must include the pleading with the proposed designations and objections.
Court-ordered changes to proposed verdict forms must be submitted in Word format by the applicable Court-set deadline.
Any changes to the proposed verdict form(s) ordered by the Court must be made by the parties and submitted to the Court in Word format by the deadline set at the PTC or by any other deadline set by the Court.
Word Perfect
The exhibit list must be a table containing the exhibit number, description and Bates numbers if any, sponsoring witness, identification date, admission date, and stipulation status.
The exhibit list must be in tabular form and contain the following: a. Exhibit number; b. Brief description of the exhibit (with any bates numbers if they exist); c. Sponsoring witness; d. Date marked for identification (left blank); e. Date admitted into evidence (left blank); and f. Whether admissibility is stipulated.
Each party must place the official exhibit stamp on every trial document, and exhibit tabs may be obtained from the courtroom clerk.
Each party will be expected to place the official exhibit stamp on each document; the exhibit tabs may be obtained from the courtroom clerk.
Exhibits must use numerical designations, and letters are prohibited.
Exhibits shall be numbered. NO letters may be used.
The defendant's exhibit-number sequence must begin after the plaintiff's sequence.
The defendant’s exhibit numbers shall be sequenced to begin after the plaintiff’s exhibit numbers.
Every multi-page exhibit must be paginated or Bates numbered.
Multi-page exhibits must be paginated or bates numbered.
Every trial exhibit must be clearly premarked with its trial exhibit number.
Each trial exhibit shall be clearly pre-marked with the trial exhibit number.
All exhibits must be marked and referred to as “Trial Exhibit No. ___,” not as a plaintiff's or defendant's exhibit.
To avoid any party claiming “ownership” of an exhibit, all exhibits shall be marked and referred to as “Trial Exhibit No. ___” – and NOT as “Plaintiff’s Exhibit” or “Defendant’s Exhibit.”
The parties must submit joint tabbed binders containing the deposition-designation pleading, one witness per tab, yellow-highlighted designations, and red-bracketed objections.
The parties must also submit to the Court joint tabbed binder(s) with the proposed deposition designations. Each tab should represent the testimony of a single witness. The proposed deposition designations must be highlighted in yellow with any objections bracketed in red. The binders must include the pleading with the proposed designations and objections.
Motions in limine must be submitted in tabbed binders in numerical order, with each opposition in the same tab immediately behind its motion and separated by a colored sheet of paper.
44. Each party must submit a tabbed binder with its MILs in numerical order with the opposition immediately behind the motion within the same tab. The MIL and its opposition must be separated by a colored sheet of paper.
Each party must submit a hard copy of every proposed order.
47. Each party must also submit a hard copy and a Word version of all proposed orders.
Paper
Each trial exhibit must be clearly pre-marked with its trial exhibit number, and the defendant’s numbering must begin after the plaintiff’s numbering.
Each trial exhibit shall be clearly pre-marked with the trial exhibit number. The defendant’s exhibit numbers shall be sequenced to begin after the plaintiff’s exhibit numbers.
Exhibits must use numbers rather than letters, and the parties must agree on separate number blocks and make a good-faith effort to avoid duplicate markings.
Exhibits shall be numbered. NO letters may be used. The parties must agree on a block of numbers to fit the needs of the case (e.g., the plaintiff has exhibits 1-100; the defendant has exhibits 101-200), and make a good faith effort to avoid marking the same exhibit in their respective blocks.
The exhibit list must be tabular and include the exhibit number, description and any Bates numbers, sponsoring witness, identification date, admission date, and stipulation to admissibility.
The exhibit list must be in tabular form and contain the following: a. Exhibit number; b. Brief description of the exhibit (with any bates numbers if they exist); c. Sponsoring witness; d. Date marked for identification (left blank); e. Date admitted into evidence (left blank); and f. Stipulation to admissibility.
Multi-page exhibits must be paginated or Bates numbered.
Multi-page exhibits must be paginated or bates numbered.
All exhibits must be labeled and referred to as “Trial Exhibit No.” rather than as a plaintiff’s or defendant’s exhibit.
To avoid any party claiming “ownership” of an exhibit, all exhibits shall be marked and referred to as “Trial Exhibit No. ___” – and NOT as “Plaintiff’s Exhibit” or “Defendant’s Exhibit.”
The parties must submit joint tabbed binders containing the proposed deposition designations, with each tab covering one witness's testimony.
The parties must also submit to the Court joint tabbed binder(s) with the proposed deposition designations. Each tab should represent the testimony of a single witness.
Proposed deposition designations must be highlighted in yellow, objections bracketed in red, and the binder must include the related pleading.
The proposed deposition designations must be highlighted in yellow with any objections bracketed in red. The binders must include the pleading with the proposed designations and objections.
The binder must be tabbed, arrange each motion in limine with its opposition in the same tab, separate them with a colored sheet, and be submitted with the Joint Pretrial Conference Statement.
35. Each party must submit a tabbed binder with its MILs in numerical order with the opposition immediately behind the motion within the same tab. The MIL and its opposition must be separated by a colored sheet of paper. The binders must be submitted to the Court with the Joint Pretrial Conference Statement.
Each party must submit both a hard copy and a Word version of every proposed order.
38. Each party must also submit a hard copy and a Word version of all proposed orders.
Witness lists, exhibit lists, and proposed orders must be provided to the Court in Word format.
The parties shall also email the witness lists, exhibit lists, and proposed orders in Word format to the Court.
DOCX
Electronically filed documents other than exhibits must be text searchable.
The documents (other than exhibits) must be text searchable.
An informal-conference brief must be prepared on court pleading paper.
For these informal conferences, briefs on court pleading paper not to exceed three (3) pages – which must be served – may be submitted by email to the Court at dept2@sanmateocourt.org and complexcivil@sanmatecourt.org.
The exhibit list must be tabular and include the exhibit number, description, sponsoring witness, identification-marking date, admission date, and stipulation of admissibility.
The exhibit list must be in tabular form and contain the following: a. Exhibit number; b. Brief description of the exhibit (with any bates numbers if they exist); c. Sponsoring witness; d. Date marked for identification (left blank); e. Date admitted into evidence (left blank); f. Stipulation to admissibility.
Document Filing Requirements74 rules
A proposed order must disclose any opposing-party response, and the preparing party must make a good-faith effort to meet and confer before submission.
Judge McCannon will reject proposed orders that do not inform him of the opposing party's response, if any, to the proposed order. The party preparing the written order must make a good faith effort to meet and confer with the other parties about the order before submitting it to the Court.
Document Type
Proposed Order
The parties must file a Joint Trial Setting/Case Management Conference Statement.
Judge McCannon requires that the parties file a Joint Trial Setting/Case Management Conference Statement.
Document Type
Joint Trial Setting Case Management Conference Statement
An ex parte application will be denied unless the applicant provides a proposed order.
The applicant MUST provide a proposed order or the application will be denied. (See Cal. Rules of Court, rule 3.1201.)
Document Type
Ex Parte Application
After preliminary continuance approval, the parties must provide a written stipulation before the scheduled hearing or trial date.
If preliminary approval is given, a written stipulation must be provided before the hearing or trial date.
Document Type
Continuance Stipulation
Each joint CMC statement must include the specified case, orders, discovery, motion, procedural, settlement, management, and other relevant information.
Accordingly, the parties shall file a joint CMC statement no later than six (6) calendar days before the hearing for each conference that includes the following:
Document Type
Joint Cmc Statement
Department 2 email correspondence must identify the case name, case number, and judge’s last name in the subject line and be copied to all counsel or pro se persons.
All email correspondence to Department 2 at dept2@sanmateocourt.org and complexcivil@sanmateocourt.org must include the case name, case number, and judge’s last name – i.e., Smith v. Jones, 18CIV1234, MCCANNON – in the “subject line” header and be copied to all counsel or persons appearing in propria persona.
Document Type
Email Correspondence
Counsel who is thoroughly familiar with the case must attend every case management conference.
Counsel thoroughly familiar with the case must attend all CMCs.
Document Type
Cmc Participant
Moving counsel must submit to the Court at least one day before the hearing a declaration confirming the meet-and-confer conference and describing any agreements reached.
Counsel for the moving party shall arrange the conference to meet and confer at least three (3) calendar days before the hearing and shall submit to the Court at least one (1) day before the hearing a declaration establishing that the meet and confer conference occurred and describing any agreements that counsel have reached.
Document Type
Meet And Confer Declaration
The requesting party's IDC brief must attach the relevant discovery requests and any discovery responses as exhibits.
The requesting party’s brief shall include the subject discovery requests and discovery responses (if any) attached as exhibits.
Document Type
Idc Short Brief
When an amended pleading has been filed after leave to amend, the plaintiff or cross-complainant must attach a redline comparison to any successive demurrer or motion to strike unless the Court orders otherwise.
When the Court sustains a demurrer or grants a motion to strike with leave to amend and an amended pleading is filed, the plaintiff or cross-complainant must file with its opposition to any successive demurrer or motion to strike a redline comparing the amended pleadings to the previous version of the pleading unless otherwise ordered by the Court.
Document Type
Opposition To Successive Demurrer Or Motion To Strike
For discovery motions, no separate statement is required; instead, the supporting declaration must include the discovery requests or deposition questions and written responses, and the parties must submit a concise outline of the request and disputed responses.
As to discovery motions, the parties are relieved of their obligation under rule 3.1345 of the California Rules of Court to file a separate statement. Instead, the parties must (1) attach the discovery request(s) or deposition question(s) at issue and the written response(s), if any, to the declaration submitted in support of the discovery motion; and (2) submit a concise outline of the discovery request and each response in dispute pursuant to Code of Civil Procedure section 2030.300, subdivision (b)(2).
Document Type
Discovery Motion
Unreported authorities cited in a memorandum must use a WESTLAW-accessible citation or be emailed to both Department 2 addresses.
any authorities that are not reported in an official reporter and that are cited must either be: (1) cited using the WESTLAW citation or a citation accessible through WESTLAW; or (2) provided to Department 2 by email at both dept2@sanmateocourt.org and complexcivil@sanmatecourt.org.
Document Type
Memorandum
A request to waive personal appearance at a mandatory settlement conference must be made by written application to the court.
Any request for a waiver of the requirement to personally appear at the Mandatory Settlement Conference, whether conducted by a judge or a special master, must be made by written application to the Court.
Document Type
Waiver Application
Agreed deadline changes may be submitted through a joint stipulation and proposed order explaining the reasons, while disputed changes may be pursued through ex parte relief.
If the parties agree on the proposed change(s), then they may submit a joint stipulation and proposed order explaining the reasons for the proposed change(s). If the parties do not agree, then the party seeking to change the deadline(s) may seek ex parte relief.
Document Type
Joint Stipulation And Proposed Order
Each party must prepare an exhibit list identifying each discrete trial exhibit and submit it with one extra copy to the courtroom clerk on the first day of trial.
Each party must prepare a list of all exhibits to be offered at trial, other than those to be used for impeachment or rebuttal, for submission with one extra copy to the courtroom clerk on the first day of trial. The list must identify as separate exhibits each discrete document or item to be offered at trial and must include a brief description of each exhibit sufficient to distinguish it from the other exhibits.
Document Type
Exhibit List
Parties must exchange exhibit lists at least five days before the pretrial conference.
Exhibit lists must be exchanged by parties, at least 5 days before the PTC.
Document Type
Exhibit List
If both parties mark the exact same exhibit, the defendant must withdraw the duplicative exhibit without renumbering the defendant's exhibit list.
If the exact same exhibit is marked by more than one party, then the defendant shall withdraw the duplicative exhibit (but should not renumber its portion of the exhibit list).
Document Type
Exhibit List
For disputes concerning overlapping exhibit portions, the parties must first meet and confer informally; if unresolved, each must submit the disputed exhibit with the Joint Pretrial Conference Statement and provide an explanation in no more than one double-spaced page.
If there is any dispute over which portions of an overlapping exhibit should be introduced into evidence, the parties shall meet and confer in an attempt to informally resolve the issue. If the parties are unable to informally resolve the dispute, then each party shall submit its disputed exhibit with the Joint Pretrial Conference Statement and explain, in no more than one double-spaced page, why the Court should use its proposed exhibit.
Document Type
Joint Pretrial Conference Statement
Each party must file a tabular witness list with the Joint Pretrial Conference Statement identifying each witness, title, anticipated testimony, and estimated examination time.
Each party must file a list of all the witnesses the party intends to call at trial with the Joint Pretrial Conference Statement. The witness list must be in tabular form and contain the following: a. Name of the witness; b. Title of the witness, if any; c. Brief description of the subject matter of the witness’ anticipated testimony; and d. Estimated length of the direct examination, cross-examination, and rebuttal.
Document Type
Witness List
For disputed instructions, each party must provide and identify its proposed version, and all versions of the same instruction must use the same number.
If the parties disagree on an instruction, each party’s proposed version of the disputed instruction shall be provided and identified as “Disputed Instruction No. ___ Re: ________ Offered by __________,” with blanks filled in as appropriate. All proposed versions of the same instruction shall bear the same number.
Document Type
Jury Instructions
The parties must file a joint set of proposed jury instructions in the order they propose the Court give them.
66. The parties shall file a joint set of proposed jury instructions, arranged in the order the parties propose the Court give the instructions.
Document Type
Jury Instructions
Agreed-upon instructions must be identified using the specified stipulated-instruction format with the blanks completed.
Instructions upon which the parties agree shall be identified as “Stipulated Instruction No. ___ Re: _____________,” with blanks filled in as appropriate.
Document Type
Jury Instructions
The parties must file joint proposed verdict forms, or separate proposed forms if they disagree, with the Joint Pretrial Conference Statement.
71. The parties shall file either joint proposed verdict form(s) or, if they disagree, separate proposed verdict forms with the Joint Pretrial Conference Statement.
Document Type
Verdict Forms
If the parties use a jury questionnaire, they must file a joint proposed questionnaire, or separate proposals if they disagree, with the Joint Pretrial Conference Statement.
If the parties wish to use a jury questionnaire, the parties must file a joint proposed jury questionnaire or, if they disagree, separate proposed jury questionnaires with the Joint Pretrial Conference Statement.
Document Type
Jury Questionnaire
A motion in limine seeking to preclude evidence must identify the specific evidence at issue.
MILs seeking to preclude evidence must specify it. “Motions in limine are properly used to determine whether specific evidence should be admitted or precluded.”
Document Type
Motion In Limine
The required binder of motions in limine must be submitted with the Joint Pretrial Conference Statement.
The binders must be submitted to the Court with the Joint Pretrial Conference Statement.
Document Type
Joint Pretrial Conference Statement
Each party must instruct its witnesses about the relevant orders in limine.
Parties must instruct their witnesses on the relevant in limine orders.
Document Type
Trial Preparation
Filing & Service rules
Electronic Filing Rules
Paper copies of ex parte documents are required, while emailing those documents to the hearing department is encouraged.
Parties are encouraged to ALSO email their ex parte documents to the department hearing the ex parte, but paper copies are required as stated above.
Page 1 | Law and Motion
A party ordered to prepare a written order should e-file it and email the Word-format order to Department 2, copying the other parties.
When Judge McCannon orders a party to prepare a written order, that party should e-file the order. The party should also email the order in Word format to Department 2 at Dept2@sanmateocourt.org. That email must include the other parties.
Page 1 | Law and Motion
Beginning January 1, 2026, represented parties seeking an ex parte hearing must e-file their papers.
Effective 1/01/2026, Amended Local Rule 3.500(c) requires represented parties seeking an ex parte hearing to e-file their papers.
Page 1 | Law and Motion
Proposed orders must not be e-filed or sent as courtesy copies; they may be e-filed only after the matter is heard.
Please do not e-file nor send courtesy copies of proposed orders. Orders shall ONLY be e-filed AFTER the matter has been heard.
Page 1 | Law and Motion
All ex parte filings must be e-filed unless the filing party is unrepresented.
Local Rule 3.500 has been revised mandating that all ex parte filings be e-filed unless a party is not represented by counsel. Please review and comply with all requirements stated in the rule.
Page 1 | Law and Motion
All documents in Complex Civil actions must be filed electronically except the original documents identified in paragraph 8.
Pursuant to Code of Civil Procedure section 1010.6, subdivision (c), all documents in Complex Civil actions (with the exception of the original documents specified in paragraph 8 below) must be filed electronically.
Page 3 | GENERAL -- FILINGS AND CORRESPONDENCE
The listed original documents must continue to be filed or lodged as hardcopy paper with the Civil Clerk's Office.
Until further order of this Court, the following original documents must still be filed or lodged in hardcopy paper with the Civil Clerk’s Office located in the Hall of Justice, First Floor, Room A, 400 County Center, Redwood City, California:
Page 3 | GENERAL -- FILINGS AND CORRESPONDENCE
Papers necessary to decide an ex parte application may be submitted by email to Department 2 and both listed addresses by noon on the preceding court day.
All papers necessary to the determination of the application, including any proposed pleading, motion, or order, must be submitted, preferably by email to both dept2@sanmateocourt.org and complexcivil@sanmateocourt.org, directly to Department 2 by noon the court day before the scheduled ex parte hearing date.
Page 7 | EX PARTE APPLICATIONS
Motions in limine and their oppositions must be electronically filed with the Clerk's Office no later than three court days before the pretrial conference.
MILs and their oppositions must be e-filed with the Clerk’ Office no later three (3) court days before the PTC.
Page 21 | MOTIONS IN LIMINE
Motions in limine and their oppositions must be electronically filed with the Clerk's Office no later than three court days before the pretrial conference.
43. MILs and their oppositions must be e-filed with the Clerk’ Office no later three (3) court days before the PTC.
Page 11 | PRETRIAL ORDER NO. 1
Motions in limine and oppositions must be electronically filed with the Clerk’s Office no later than three court days before the pretrial conference.
34. MILs and their oppositions must be e-filed with the Clerk’ Office no later three (3) court days before the PTC.
Page 9 | PRETRIAL ORDER NO. 1
Filing Timing and Cure Windows
For remote ex parte appearance, the applicant must serve the moving papers and proposed order on all parties, submit paper copies to the assigned judge, and pay the clerk's fee by 10:00 a.m. two court days before the appearance.
Except as ordered by the court under subdivision (d), applicants seeking an ex parte order may appear remotely provided that the moving papers, including a proposed order, have been served on all parties, and submitted in paper form to the assigned judge, and the fee paid to the clerk’s office, by at least 10:00 a.m. two court days before the ex parte appearance.
Page 1 | Law and Motion
The parties must file a joint CMC statement no later than six calendar days before each CMC hearing.
Accordingly, the parties shall file a joint CMC statement no later than six (6) calendar days before the hearing for each conference
Page 5 | CASE MANAGEMENT CONFERENCES
Papers necessary for an ex parte application must reach Department 2 by noon on the court day before the hearing.
All papers necessary to the determination of the application, including any proposed pleading, motion, or order, must be submitted, preferably by email to both dept2@sanmateocourt.org and complexcivil@sanmateocourt.org, directly to Department 2 by noon the court day before the scheduled ex parte hearing date.
Page 7 | EX PARTE APPLICATIONS
Any reply must be filed no later than two weeks before the hearing.
Any reply must be filed at least two (2) weeks before the hearing date.
Page 10 | LAW AND MOTION
Settlement Conference Statements must be filed at least five court days before the scheduled conference.
Settlement Conference Statements must be filed at least five (5) court days before the scheduled conference.
Page 12 | SETTLEMENT CONFERENCES AND MEDIATIONS
Three sets of joint trial exhibit binders and thumb drives must be delivered to the court on the day of trial.
Deliver three (3) sets of joint trial exhibit binders and The day of Trial
Page 13 | PRETRIAL DEADLINES AND REQUIREMENTS
The joint pretrial conference statement must be filed and hard copies delivered to the court three court days before the pretrial conference.
File and deliver hard copies to the court: 3 court days before 1. Joint pretrial conference statement
Page 13 | PRETRIAL DEADLINES AND REQUIREMENTS
The parties must meet and confer regarding specified pretrial conference matters 21 days before the pretrial conference.
Meet and confer regarding pretrial conference, including witness and exhibit lists, exhibits, motions in limine, deposition designations, jury instructions, verdict forms, jury questionnaire (if any), statement of the case.
Page 13 | PRETRIAL DEADLINES AND REQUIREMENTS
One set of binders and a binder with motions in limine and oppositions must be filed with hard copies delivered to the court three court days before the pretrial conference, while the joint deposition binder must be delivered but not filed.
File and deliver hard copies to the court: 3 court days before PTC 2. One (1) set of binders with the following: a) Statement of the case b) Exhibit list c) Witness list d) List of jury instructions e) Proposed jury instructions f) Proposed verdict form g) Deposition designations with objections and responses 3. Joint binder with deposition designations and objections, and highlighted transcripts (deliver, not file) 4. Binder with motions in limine and oppositions.
Page 13 | PRETRIAL DEADLINES AND REQUIREMENTS
All parties must conduct a meaningful in-person or videoconference meet-and-confer concerning the listed pretrial and trial issues no later than 21 days before the pretrial conference.
All parties must meet and confer in person or videoconference regarding motions in limine, jury instructions, verdict form(s), jury questionnaire (if any), a statement of the case, witness lists, deposition designations, exhibit lists, exhibits, and a pretrial conference statement, 21 and any other issues that may arise at trial no later than 21 days before the PTC.
Page 14 | MEET AND CONFER
Any change to an established filing or submission deadline requires an order from the court.
Any changes to the deadlines established by this order for filings or submissions to the Court REQUIRE an order from the Court.
Page 14 | PRETRIAL DEADLINES AND REQUIREMENTS
The parties must file a joint pleading containing proposed deposition designations, objections, and responses three court days before the pretrial conference, and objections or responses may not exceed one page.
The parties must file a joint pleading with their proposed deposition designations, any objections to those designations, and any responses to those objections, 3 court days before PTC. Objections or responses may be no longer than one page.
Page 18 | DEPOSITION DESIGNATIONS
Court-ordered changes to proposed jury instructions must be submitted by the deadline set at the PTC or another deadline set by the Court.
Any changes to the proposed jury instructions ordered by the Court must be made by the parties and submitted to the Court by the deadline set by the Court at the PTC or by any other deadline set by the Court.
Page 19 | JURY INSTRUCTIONS
Court-ordered changes to proposed verdict forms must be submitted by the deadline set at the PTC or another deadline set by the Court.
Any changes to the proposed verdict form(s) ordered by the Court must be made by the parties and submitted to the Court in Word format by the deadline set at the PTC or by any other deadline set by the Court.
Page 20 | VERDICT FORM(S)
The electronic-filing deadline for motions in limine and their oppositions is three court days before the pretrial conference.
MILs and their oppositions must be e-filed with the Clerk’ Office no later three (3) court days before the PTC.
Page 21 | MOTIONS IN LIMINE
Each party must file a Joint Pretrial Conference Statement at least 14 days before the Pretrial Conference.
The parties shall file a Joint Pretrial Conference Statement at least 14 days before the PTC that contains:
Page 23 | JOINT PRETRIAL CONFERENCE STATEMENT
The joint pretrial conference statement, required binders, and related pretrial materials must be filed or delivered as specified three court days before the pretrial conference.
File and deliver hard copies to the court: 3 court days before 1. Joint pretrial conference statement 2. One (1) set of binders with the following: a) Statement of the case b) Exhibit list c) Witness list d) List of jury instructions e) Proposed jury instructions f) Proposed verdict form g) Deposition designations with objections and responses 3. Joint binder with deposition designations and objections, and highlighted transcripts (deliver, not file) 4. Binder with motions in limine and oppositions.
Page 3 | PRETRIAL DEADLINES AND REQUIREMENTS
The parties must exchange exhibit lists at least five days before the pretrial conference.
Exhibit lists must be exchanged by parties, at least 5 days before the PTC.
Page 5 | EXHIBITS AND EXHIBIT LIST
Each party must file its complete intended-trial-witness list with the Joint Pretrial Conference Statement.
Each party must file a list of all the witnesses the party intends to call at trial with the Joint Pretrial Conference Statement.
Page 7 | WITNESS LIST
Three court days before PTC, the parties must file a joint pleading containing proposed deposition designations, objections, and responses.
The parties must file a joint pleading with their proposed deposition designations, any objections to those designations, and any responses to those objections, 3 court days before PTC.
Page 8 | DEPOSITION DESIGNATIONS
The e-filing deadline for motions in limine and their oppositions is three court days before the pretrial conference.
43. MILs and their oppositions must be e-filed with the Clerk’ Office no later three (3) court days before the PTC.
Page 11 | PRETRIAL ORDER NO. 1
The parties must file the Joint Pretrial Conference Statement at least 14 days before the pretrial conference.
50. The parties shall file a Joint Pretrial Conference Statement at least 14 days before the PTC that contains:
Page 12 | JOINT PRETRIAL CONFERENCE STATEMENT
The Pretrial Conference must occur at least 14 days before the Trial Date.
53. A Pretrial Conference will occur at least 14 days before the Trial Date.
Page 14 | PRETRIAL CONFERENCE
Parties must exchange exhibit lists at least five days before the pretrial conference.
Exhibit lists must be exchanged by parties, at least 5 days before the PTC.
Page 5 | EXHIBITS AND EXHIBIT LIST
A party designating deposition testimony in lieu of live testimony must provide the proposed designations to the opposing party at least five days before the pretrial conference.
If any party wishes to designate deposition testimony in lieu of live testimony for any witness, then that party must provide their proposed designations to the opposing parties at least 5 days before PTC.
Page 7 | DEPOSITION DESIGNATIONS
The parties must file a joint pleading containing proposed deposition designations, objections, and responses three court days before the pretrial conference.
The parties must file a joint pleading with their proposed deposition designations, any objections to those designations, and any responses to those objections, 3 court days before PTC.
Page 7 | DEPOSITION DESIGNATIONS
The electronic filing deadline for motions in limine and oppositions is three court days before the pretrial conference.
34. MILs and their oppositions must be e-filed with the Clerk’ Office no later three (3) court days before the PTC.
Page 9 | PRETRIAL ORDER NO. 1
The parties must file the Joint Pretrial Conference Statement at least 14 days before the pretrial conference.
1. The parties shall file a Joint Pretrial Conference Statement at least 14 days before the PTC
Page 10 | JOINT PRETRIAL CONFERENCE STATEMENT
The deadline for a motion to compel or other discovery motion is tolled when a party emails its IDC request, and the IDC request must be submitted well before the statutory deadline expires.
Pursuant to Code of Civil Procedure section 2016.080, subdivision (c)(2), the time for bringing any motion to compel or any other discovery motion is tolled on the date a party makes the email request for an IDC to the Court. All requests for an IDC must be made well before the expiration of the statutory time to bring a motion to compel or other discovery motion.
Page 9 | EX PARTE APPLICATIONS
The court may modify the pretrial deadlines and requirements in its discretion.
All deadlines and requirements are subject to modification at the discretion of the Court.
Page 14 | PRETRIAL DEADLINES AND REQUIREMENTS
Changes to proposed jury instructions ordered by the Court must be submitted by the deadline set at the pretrial conference or another deadline set by the Court.
Any changes to the proposed jury instructions ordered by the Court must be made by the parties and submitted to the Court by the deadline set by the Court at the PTC or by any other deadline set by the Court.
Page 9 | JURY INSTRUCTIONS
The parties must file and deliver hard copies to the court of the joint pretrial conference statement, exhibit list, witness list, and deposition designations with objections and responses three court days before the pretrial conference.
File and deliver hard copies to the court: 3 court days before 1. Joint pretrial conference statement PTC 2. Exhibit list 3. Witness list 4. Deposition designations with objections and responses
Page 3 | PRETRIAL DEADLINES AND REQUIREMENTS
All parties must meet and confer in person or by videoconference about the listed pretrial matters and other trial issues no later than 21 days before the pretrial conference.
All parties must meet and confer in person or videoconference regarding motions in limine, witness lists, deposition designations, exhibit lists, exhibits, and a pretrial conference statement, and any other issues that may arise at trial no later than 21 days before the PTC.
Page 4 | MEET AND CONFER
Service and Proof of Service Rules
A party intending to appear remotely must give notice of that intent to the court and all persons entitled to notice.
Notice of intent to appear remotely must be given to the court and to all parties or persons entitled to receive notice of the proceedings.
Page 1 | Law and Motion
The ex parte moving papers and proposed order must be served on all parties as a condition of remote appearance.
Except as ordered by the court under subdivision (d), applicants seeking an ex parte order may appear remotely provided that the moving papers, including a proposed order, have been served on all parties, and submitted in paper form to the assigned judge, and the fee paid to the clerk’s office, by at least 10:00 a.m. two court days before the ex parte appearance.
Page 1 | Law and Motion
All parties and counsel must serve documents electronically and accept electronic service from all other parties, except when a statute requires personal service.
Pursuant to Code of Civil Procedure section 1010.6, subdivision (c) and California Rules of Court, rules 2.253(c) and 2.251(c), all parties and their counsel must serve all documents electronically, and accept service of all documents electronically from all other parties, in conformity with Code of Civil Procedure section 1010.6 and the California Rules of Court, except when personal service is required by statute.
Page 4 | GENERAL -- FILINGS AND CORRESPONDENCE
An informal-conference brief must be served and may be emailed to the Court at the listed addresses.
For these informal conferences, briefs on court pleading paper not to exceed three (3) pages – which must be served – may be submitted by email to the Court at dept2@sanmateocourt.org and complexcivil@sanmatecourt.org.
Page 7 | EX PARTE APPLICATIONS
Discovery responses must be provided electronically unless the parties agree in writing to another format.
All discovery responses by a party in response to discovery propounded by another party must be provided in electronic form, unless the parties agree otherwise in writing.
Page 8 | DISCOVERY
All Code of Civil Procedure discovery requests must be served electronically on counsel for the parties.
All discovery methods under the Code of Civil Procedure, including but not limited to notices of deposition, special interrogatories, form interrogatories, requests for production of documents, and requests for admission, must be served electronically upon counsel for the parties.
Page 8 | DISCOVERY
Each side must serve the IDC brief on the Court and email it to both listed court addresses.
For the IDC, each side must serve and email to the Court at both dept2@sanmateocourt.org and complexcivil@sanmateocourt.org a short brief on court 3 pleading paper, limited to no more than five (5) pages, at least three (3) court days before the 5 IDC.
Page 9 | EX PARTE APPLICATIONS
A party intending to contest a tentative ruling must notify the other parties and the Department 2 clerk by email at the stated addresses by 4:00 p.m. at least one court day before the hearing.
If any party intends to contest the tentative ruling at the hearing, that party must notify the other parties and the Clerk for Department 2 by email at both dept2@sanmateocourt.org and complexcivil@sanmateocourt.org by 4:00 p.m. at least one court day before the scheduled hearing.
Page 11 | GENERAL MATTERS
The listed pretrial submissions must be served but not filed five days before the pretrial conference.
Serve, but NOT file: 5 days before PTC 1. Motions in limine 2. Witness lists 3. Exhibit lists 4. Deposition designations 5. Jury Instructions 6. Verdict forms
Page 13 | PRETRIAL DEADLINES AND REQUIREMENTS
Motions in limine must be served five days before the pretrial conference.
MILs must be served 5 days before the PTC.
Page 21 | MOTIONS IN LIMINE
Plaintiffs must serve the order on nonappearing parties or their designated counsel, including parties later added to the action or a cross-action, and file a proof of service.
Plaintiff(s) shall serve a copy of this order upon all parties, or their designated counsel, who have not yet appeared in this case, including any and all parties added to this action and/or cross-action(s) after the issuance of this order, and file a proof of service.
Page 26 | MISCELLANEOUS
The listed pretrial submissions must be served but not filed five days before the pretrial conference.
Serve, but NOT file: 5 days before PTC 1. Motions in limine 2. Witness lists 3. Exhibit lists 4. Deposition designations 5. Jury Instructions 6. Verdict forms
Page 3 | PRETRIAL DEADLINES AND REQUIREMENTS
A party electing deposition testimony instead of live testimony must provide its proposed designations to opposing parties at least five days before the pretrial conference.
If any party wishes to designate deposition testimony in lieu of live testimony for any witness, then that party must provide their proposed designations to the opposing parties at least 5 days before PTC.
Page 8 | DEPOSITION DESIGNATIONS
Motions in limine must be served five days before the pretrial conference.
42. MILs must be served 5 days before the PTC.
Page 11 | PRETRIAL ORDER NO. 1
Motions in limine must be served five days before the pretrial conference.
33. MILs must be served 5 days before the PTC.
Page 9 | PRETRIAL ORDER NO. 1
The parties must email witness lists, exhibit lists, and proposed orders to the Court in Word format.
The parties shall also email the witness lists, exhibit lists, and proposed orders in Word format to the Court.
Page 11 | PRETRIAL DEADLINES AND REQUIREMENTS
Each party must state at the first case management conference whether it agrees to email service, and a party that agrees will receive court orders only by email.
At the first case management conference with Department 2, each party must indicate whether he/she/it/they will agree to email service by the Court. If the party agrees to email service on the record, then that party will only receive the Court’s orders by email and will not receive any orders by mail.
Page 3 | GENERAL MATTERS
A party designating deposition testimony must provide the proposed designations to opposing parties at least five days before the pretrial conference.
If any party wishes to designate deposition testimony in lieu of live testimony for any witness, then that party must provide their proposed designations to the opposing parties at least 5 days before PTC.
Page 18 | DEPOSITION DESIGNATIONS
The parties must serve, but not file, motions in limine, witness lists, exhibit lists, and deposition designations five days before the pretrial conference.
Serve, but NOT file: 5 days before PTC 1. Motions in limine 2. Witness lists 3. Exhibit lists 4. Deposition designations
Page 3 | PRETRIAL DEADLINES AND REQUIREMENTS
Filing Fees and Waivers
Self-represented parties not enrolled in e-filing and appearing in person at the Northern Courthouse may pay ex-parte fees before the hearing at the specified Clerk’s Office window or by phone with a Credit or Debit card; they must give their applications, supporting papers, and proof of payment to the assigned Civil Judge’s courtroom clerk no later than 15 minutes from the hearing time, while check payments may be given to the clerk at the hearing.
Self-represented parties who have not signed up for e-filing and who are appearing in person at the Northern Courthouse may pay their ex-parte fees at the Clerk's Office at the Northern Courthouse, Window 8, or by phone with a Credit or Debit card before the ex parte hearing, and must submit their ex parte applications, supporting papers, and proof of payment directly to the courtroom clerk for the Department of the assigned Civil Judge no later than 15 minutes from the time set for ex parte hearing. Payments in the form of a check can be submitted directly to the Courtroom Clerk at the time of the hearing.
Page 1 | Payment of Fees
Self-represented parties who have not signed up for e-filing and appear in person at the Central Courthouse may pay ex-parte fees by credit or debit card by phone before the hearing, and must submit their applications, supporting papers, and proof of payment to the assigned Civil Judge’s courtroom clerk no later than 15 minutes from the hearing time; check payments may be submitted to the clerk at the hearing.
Self-represented parties who have not signed up for e-filing and who are appearing in person at the Central Courthouse may pay their ex-parte fees by phone with a Credit or Debit card before the ex parte hearing, and must submit their ex parte applications, supporting papers, and proof of payment directly to the courtroom clerk for the Department of the assigned Civil Judge no later than 15 minutes from the time set for ex parte hearing. Payments in the form of a check can be submitted directly to the Courtroom Clerk, at the time of the hearing.
Page 1 | Payment of Fees
A party that e-files ex parte papers must pay the ex parte application fee when filing.
Parties who e-file their ex parte papers must pay their ex parte application fee at time of filing.
Page 1 | Payment of Fees
Courtesy Copy Requirements
Absent permission to email them, courtesy copies for all documents must be delivered to Department 2 by messenger, mail, or overnight delivery.
Unless Judge McCannon gives permission to send courtesy copies by email, all courtesy copies for all documents are to be sent via messenger, mail or overnight delivery to Department 2.
Page 1 | Department Info of Judge Mark A. McCannon
Courtesy copies of pretrial and trial documents must be delivered directly to Courtroom J.
Courtesy copies of pretrial and trial documents shall be delivered directly to Courtroom J, 1050 Mission Road, South San Francisco, CA.
Page 1 | Department Info of Judge Mark A. McCannon
Parties must not send courtesy copies of proposed orders and must wait until the matter is heard before e-filing the resulting order.
Please do not e-file nor send courtesy copies of proposed orders. Orders shall ONLY be e-filed AFTER the matter has been heard.
Page 1 | Law and Motion
An applicant seeking in-person ex parte relief must notify the court and submit courtesy copies two court days before the appearance.
To obtain an Ex Parte relief in person, the applicant must (1) notify the Court and (2) submit courtesy copies two court days before the ex parte appearance.
Page 1 | Law and Motion
One extra copy of every document filed in the action must be served directly on Department 2.
One extra copy of each document filed in this action must be served directly on Department 2.
Page 4 | GENERAL -- FILINGS AND CORRESPONDENCE
One extra copy of the exhibit list must be delivered to the courtroom clerk on the first day of trial.
Each party must prepare a list of all exhibits to be offered at trial, other than those to be used for impeachment or rebuttal, for submission with one extra copy to the courtroom clerk on the first day of trial.
Page 5 | EXHIBITS AND EXHIBIT LIST
Each party must provide the court with three complete sets of its intended trial exhibits in tabbed binders and on a thumb drive on the trial date.
Each party must provide the Court with three (3) complete set of exhibits the party intends to introduce at trial in both hard copy in tabbed binders and on a thumb drive the day of Trial.
Page 6 | EXHIBITS AND EXHIBIT LIST
Each party must provide the court with three complete sets of intended trial exhibits in hard copy in tabbed binders and on a thumb drive on the day of trial.
Each party must provide the Court with three (3) complete set of exhibits the party intends to introduce at trial in both hard copy in tabbed binders and on a thumb drive the day of Trial.
Page 6 | EXHIBITS AND EXHIBIT LIST
Department 2 prefers that the required extra copy be emailed to both Department 2 email addresses.
Department 2 prefers that any such filing be served electronically at the following two email addresses: dept2@sanmateocourt.org and complexcivil@sanmateocourt.org.
Page 4 | GENERAL -- FILINGS AND CORRESPONDENCE
A party unable to email Department 2's extra copy may deliver it by hand or overnight mail directly to Department 2.
If a party is unable to email the filing to those addresses, then that party may deliver the filing by hand or by overnight mail directly to Department 2 located at Courtroom K, 1050 Mission Road, South San Francisco, CA.
Page 4 | GENERAL -- FILINGS AND CORRESPONDENCE
Sealing & Redaction Procedures
A motion or application to seal must be heard no later than a motion that relies on the materials sought to be sealed.
Motions or applications to seal must be heard no later than any motion relying on the materials for which sealing is sought.
Page 10 | LAW AND MOTION
After denial of sealing, the moving party must either notify the Court that the materials will be filed unsealed or decline to rely on them, in which case they will not become part of the record.
Upon denial of a motion or applicat ion to seal, the moving party must notify the Court that the materials are to be filed unsealed (CRC 2.551(b)) or refrain from relying on the materials, which will not be part of the record.
Page 10 | LAW AND MOTION
Parties must redact agreed non-evidentiary information, including insurance information, from medical, personal, or consumer records offered as exhibits, and the proponent must prepare clean copies for evidence.
Redaction of Exhibits. If medical, personal, or consumer records are involved, the parties are to delete any information that the parties agree should not come into evidence, including insurance information, so that such information is not received by the jury. The proponent must then prepare clean copies of the records for submission into evidence.
Page 7 | EXHIBITS AND EXHIBIT LIST
For medical, personal, or consumer records, the parties must delete agreed information that should not be introduced, including insurance information, and the proponent must prepare clean copies for evidence submission.
If medical, personal, or consumer records are involved, the parties are to delete any information that the parties agree should not come into evidence, including insurance information. The proponent must then prepare clean copies of the records for submission into evidence.
Page 6 | EXHIBITS AND EXHIBIT LIST
Filing Bundling Requirements
Each party must provide the court with three complete sets of trial exhibits in hard-copy tabbed binders and on a thumb drive on the day of trial, with an official exhibit stamp on each document.
Each party must provide the Court with three (3) complete set of exhibits the party intends to introduce at trial in both hard copy in tabbed binders and on a thumb drive the day of Trial. Each party will be expected to place the official exhibit stamp on each document; the exhibit tabs may be obtained from the courtroom clerk. The Court may require additional copies of those exhibits for trial, including separate exhibit binders for each witness.
Page 17 | TRIAL EXHIBITS
Each party must submit a tabbed binder containing its motions in limine in numerical order, with each opposition placed immediately behind the corresponding motion in the same tab.
Each party must submit a tabbed binder with its MILs in numerical order with the opposition immediately behind the motion within the same tab.
Page 21 | MOTIONS IN LIMINE
Three sets of joint trial exhibit binders and thumb drives must be delivered to the court on the day of trial.
Deliver three (3) sets of joint trial exhibit binders and The day of Trial thumb drives to the Court.
Page 3 | PRETRIAL DEADLINES AND REQUIREMENTS
A binder containing motions in limine and oppositions must be provided three court days before the pretrial conference.
4. Binder with motions in limine and oppositions.
Page 3 | PRETRIAL DEADLINES AND REQUIREMENTS
One set of pretrial binders must be provided three court days before the pretrial conference.
2. One (1) set of binders with the following:
Page 3 | PRETRIAL DEADLINES AND REQUIREMENTS
A joint binder containing deposition designations and objections and highlighted transcripts must be delivered, not filed, three court days before the pretrial conference.
3. Joint binder with deposition designations and objections, and highlighted transcripts (deliver, not file)
Page 3 | PRETRIAL DEADLINES AND REQUIREMENTS
Each party must submit a tabbed binder containing motions in limine in numerical order, each opposition immediately behind its motion in the same tab, and a colored separator sheet.
44. Each party must submit a tabbed binder with its MILs in numerical order with the opposition immediately behind the motion within the same tab. The MIL and its opposition must be separated by a colored sheet of paper. The binders must be submitted to the Court with the Joint Pretrial Conference Statement.
Page 11 | PRETRIAL ORDER NO. 1
Each party must submit a tabbed binder containing motions in limine and oppositions, with each opposition placed immediately behind its motion in the same tab.
35. Each party must submit a tabbed binder with its MILs in numerical order with the opposition immediately behind the motion within the same tab.
Page 9 | PRETRIAL ORDER NO. 1
Absent good cause, all deposition designations must be presented together at one time, with each witness's testimony introduced only once.
Absent good cause, the deposition testimony of each witness shall be introduced only once. In other words, all deposition designations shall be presented together all at once rather than as part of each party’s case.
Page 8 | DEPOSITION DESIGNATIONS
Pre-Motion Conference Requirements
An Informal Discovery Conference conducted by the Case Management Judicial Officer is mandatory before filing a discovery motion.
Parties must comply with Local Rule 3.700 regarding mandatory Informal Discovery Conference (“IDC”) before filing a discovery motion. All IDCs are conducted by the Case Management Judicial Officer.
Page 1 | Law and Motion
Unless the Court orders otherwise, counsel and pro se persons must meet in person or by video, and the parties must participate in an informal discovery conference before filing any discovery motion if the dispute is unresolved.
Discovery meet and confer obligations require an in-person or video conference between counsel and persons appearing in propria persona unless otherwise ordered by the Court. If a resolution is not reached, the parties must meet with the Court for all discovery- related matters in an informal discovery conference (IDC) before filing any discovery motion unless otherwise authorized by the Court. No discovery motion will be heard without in IDC.
Page 8 | DISCOVERY
Except for pro hac vice applications and counsel-withdrawal motions, counsel and self-represented parties must confer in good faith at least three calendar days before the hearing, and moving counsel must submit a declaration of the conference and agreements at least one day before the hearing.
Before the hearing of any motion, petition, or application, except applications to appear pro hac vice and motions to withdraw as counsel of record, all counsel and persons appearing in propria persona shall confer in a good faith attempt to eliminate the necessity of the hearing or to resolve as many disputes as possible. Counsel for the moving party shall arrange the conference to meet and confer at least three (3) calendar days before the hearing and shall submit to the Court at least one (1) day before the hearing a declaration establishing that the meet and confer conference occurred and describing any agreements that counsel have reached.
Page 9 | LAW AND MOTION
At least 21 days before the pretrial conference, the parties must meet and confer, and no motion in limine may be filed without a prior good-faith effort to resolve or narrow the evidentiary issue.
The parties shall meet and confer no later than twenty-one (21) days before the PTC to determine whether any evidentiary issues may be resolved by stipulation. No party may file a motion in limine (“MIL”) without first making a good faith effort to resolve/narrow the evidentiary issue with the opposing party.
Page 20 | MOTIONS IN LIMINE
The parties must meet and confer at least 21 days before the pretrial conference, and no party may file a motion in limine without first making a good-faith effort to resolve or narrow the evidentiary issue.
The parties shall meet and confer no later than twenty-one (21) days before the PTC to determine whether any evidentiary issues may be resolved by stipulation. No party may file a motion in limine (“MIL”) without first making a good faith effort to resolve/narrow the evidentiary issue with the opposing party.
Page 10 | MOTIONS IN LIMINE
A party may not file a motion in limine without first making a good-faith effort to resolve or narrow the evidentiary issue with the opposing party.
No party may file a motion in limine (“MIL”) without first making a good faith effort to resolve/narrow the evidentiary issue with the opposing party.
Page 8 | MOTIONS IN LIMINE
The parties must meet and confer no later than 21 days before the pretrial conference to determine whether evidentiary issues can be resolved by stipulation.
The parties shall meet and confer no later than twenty-one (21) days before the PTC to determine whether any evidentiary issues may be resolved by stipulation.
Page 8 | MOTIONS IN LIMINE
Motions concerning administrative matters or other issues not seeking exclusion of specific evidence should not be presented as motions in limine.
Administrative and other motions not seeking to exclude specific evidence, e.g., excluding witnesses from the courtroom, requesting 24 hours’ notice of calling a witness, a review of demonstrative exhibits to be used at opening or closing, excluding speculative evidence, excluding evidence not produced in discovery (when that is the sole reason offered), precluding “reptile theory” arguments, should not be subject of an MIL.
Page 20 | MOTIONS IN LIMINE
A motion in limine is improper when it seeks admission or exclusion based merely on the absence of evidence or the existence of conflicting evidence.
An MIL which argues that “no evidence on an issue should be introduced because there is no evidence on the issue” or because “there is other evidence that conflicts with the evidence sought to be suppressed” are not proper MILs.
Page 20 | MOTIONS IN LIMINE
Adjournment & Extension Requirements
A trial-date continuance request made within 90 days of trial may not be made by stipulation and must comply with California Rules of Court rule 3.1332.
Any requests for continuance of a trial date made within 90 days of the scheduled trial date may NOT be made through a stipulation and MUST, instead, comply with rule 3.1332 of the California Rules of Court.
Page 1 | Pretrial Conference
A continuance by stipulation requires the Court's prior approval and may receive only a date pre-approved by the Court.
Continuances by stipulation are not permitted without prior approval of the Court, and only to a date pre-approved by the Court.
Page 2 | GENERAL MATTERS
The moving party must provide notice of the continuance of any hearing as soon as possible.
as soon as possible regarding any matter to be taken off calendar or continued. Notices of continuance of any hearing must be provided by the moving party.
Page 11 | GENERAL MATTERS
Continuances of hearing and trial dates are discouraged and require this Court's approval when necessary.
Continuances of hearing and trial dates are discouraged. If a continuance is necessary, it must be approved by this Court.
Page 2 | GENERAL MATTERS
Chambers Communication Rules
A copy of each reply brief, unlawful-detainer opposition, or summary-judgment motion must be emailed to the law-and-motion reply address, and complex-case briefs must also be emailed to the complex civil address.
In order to ensure your reply brief is received by the Court in a timely manner, you must email a copy of any reply brief, or any Unlawful Detainer Opposition or Motion for Summary Judgment to lawandmotionreplybriefs@sanmateocourt.org. If you fail to do so and your reply brief is not available to the Court in a timely manner, please be advised that this may result in your matter being continued. Also, please note that this requirement is in addition to any separate requirement individual Judges have regarding the delivery of courtesy copies to their chambers, as well as the obligation to email all briefs, including reply briefs, to the complexcivil@sanmateocourt.org email address for complex matters.
Page 1 | Hours of Operation
The ex parte applicant must notify Judge McCannon, preferably by email, of any opposition and when it will be filed.
The Applicant MUST inform Judge McCannon, preferably by email, if there will be an opposition and when that opposition will be filed.
Page 1 | Law and Motion
All case correspondence to Department 2, including informal discovery conference briefs, off-calendar requests, and scheduling requests, must be emailed to both listed addresses.
All correspondence to Department 2 regarding this case – including informal discovery conference briefs, requests to take matters off calendar, and requests for scheduling must be submitted by email to the following two addresses: dept2@sanmateocourt.org and complexcivil@sanmateocourt.org.
Page 4 | GENERAL -- FILINGS AND CORRESPONDENCE
Plaintiff must notify all other parties of the first case management conference date unless the Court orders otherwise.
Plaintiff is required to give notice of this conference date to all other parties unless otherwise ordered by the Court.
Page 5 | CASE MANAGEMENT CONFERENCES
After meaningful meet and confer, an informal discovery conference request must be emailed to both listed addresses with all counsel copied.
Requests for an IDC may be made, after meaningful meet and confer, by sending an email to both dept2@sanmateocourt.org and complexcivil@sanmateocourt.org, copied to all counsel.
Page 8 | DISCOVERY
The parties must email the listed pretrial materials to the Court in Word format.
52. The parties shall also email the witness lists, exhibit lists, proposed jury instructions, proposed verdict form(s), proposed jury questionnaire (if any), proposed statement of the case, and proposed orders in Word format to the Court.
Page 14 | PRETRIAL ORDER NO. 1
An Informal Discovery Conference in a complex case is conducted by Judge McCannon and must be scheduled with Department 2 by phone or email.
IDCs for complex cases are conducted by Judge McCannon. Contact Department 2 by phone or email to schedule an IDC in a complex case.
Page 1 | Law and Motion
An email to Department 2 should identify the case name, case number, and purpose in its subject line to avoid delay.
If you send an email to Department 2, please include the following information in the "subject line" header: (1) case name; (2) case number; and (3) a brief description of the purpose of the email. For example: Smith v. Jones, 23-CIV-01234, Proposed Order. Otherwise, a response to your email will likely be delayed.
Page 1 | Department Info of Judge Mark A. McCannon
Ex parte applications, oppositions, supporting papers, and proposed orders should be emailed and delivered to Department 2 as soon as available, with the proposed order preferably in Word format.
The parties should email their application or opposition, and any supporting papers, and the proposed order AS SOON AS THEY ARE AVAILABLE to the Court at Dept2@sanmateocourt.org and deliver the documents to Department 2 at the Northern Courthouse located at 1050 Mission Road, South San Francisco. The proposed order should be provided in Word format if possible.
Page 1 | Law and Motion
Central or Northern Courthouse ex parte payments may be made by telephone by calling 650-261-5100, selecting option 0, and entering extension 7243.
To pay by phone for appearances at the Central or Northern Courthouses please dial 650-261-5100, select Option “0” and enter extension 7243 to be connected to a clerk to process your payment.
Page 1 | Payment of Fees
Non-complex motion hearing dates must be scheduled through the court's website rather than by contacting Department 2.
To schedule a hearing date for motions in non-complex cases, please check the Court's web site. Please do not contact Department 2 directly to schedule a hearing date.
Page 1 | Law and Motion
An urgent matter requiring an immediate hearing should be reported to Department 2 by email at Dept2@sanmateocourt.org or by telephone.
If the matter is urgent and requires an immediate hearing, please contact Department 2 preferably by email at Dept2@sanmateocourt.org or by phone.
Page 1 | Payment of Fees
Emails to Department 2 in complex cases should be sent to both Department 2 and the complex civil email addresses.
Department 2 strongly prefers to be contacted by email. As noted in the Initial Case Management Order, all emails in complex cases to Department 2 should be sent to both Dept2@sanmateocourt.org and complexcivil@sanmateocourt.org.
Page 1 | Law and Motion
The emailed written order should be in Word format, sent to Department 2, and include the other parties.
When Judge McCannon orders a party to prepare a written order, that party should e-file the order. The party should also email the order in Word format to Department 2 at Dept2@sanmateocourt.org. That email must include the other parties.
Page 1 | Law and Motion
A complex-case email to Department 2 should state the case name, case number, McCannon, and the email's purpose in the subject line.
For all complex cases in Department 2, please include the following information in the "subject line" header of the email: (1) case name; (2) case number; (3) "McCannon," and (4) a brief description of the purpose of the email. For example: Smith v. Jones, CIV1234, McCannon, Proposed Order.
Page 1 | Law and Motion
Parties must schedule complex-case motions and case management conferences by emailing both Department 2 addresses rather than contacting the Civil Clerk's Office.
To schedule a motion or a case management conference for a complex case, please contact Department 2 directly by email at both dept2@sanmateocourt.org and complexcivil@sanmateocourt.org. Please do NOT contact the Civil Clerk's Office. Judge McCannon does the scheduling for all of his complex cases himself.
Page 1 | Law and Motion
An Informal Discovery Conference in a non-complex case must be scheduled through the court's website by the Case Management Judicial Officer, not Department 2.
To schedule an IDC, please check the Court's web site. Please do not contact Department 2 to schedule an IDC in a non-complex case. Only the Case Management Judicial Officer can schedule an IDC.
Page 1 | Law and Motion
Parties must email both listed Department 2 clerk addresses for available dates before contacting opposing counsel.
Please email the Clerk for Department 2 at both dept2@sanmateocourt.org and complexcivil@sanmateocourt.org for available dates before contacting opposing counsel.
Page 2 | GENERAL MATTERS
Documents must not be faxed to Department 2.
Please do not fax any documents to Department 2.
Page 4 | GENERAL -- FILINGS AND CORRESPONDENCE
Department 2 email addresses may receive correspondence and filings but must not be used for back-and-forth communications with the judge.
solely for the purpose of receiving correspondence and filings. They are not to be used for the purpose of back-and-forth communications with the judge.
Page 5 | GENERAL -- FILINGS AND CORRESPONDENCE
A mutually agreed informal conference with the Court must be scheduled by emailing the Department 2 Clerk at the listed addresses.
To arrange a conference with the Court that all counsel agree is advisable, please contact the Clerk for Department 2 by email at dept2@sanmatecourt.org and complexcivil@sanmateocourt.org to schedule a time for the conference.
Page 7 | EX PARTE APPLICATIONS
Ex parte hearing dates must be coordinated by email with the Department 2 Clerk at the two listed email addresses.
Hearing dates for ex parte applications must be coordinated by email with the Clerk for Department 2 at dept2@sanmateocourt.org and complexcivil@sanmateocourt.org.
Page 7 | EX PARTE APPLICATIONS
Department 2 hearings may be scheduled by emailing the Clerk at both listed addresses.
Hearings may be scheduled by contacting the Clerk for Department 2 by email at both dept2@sanmateocourt.org and complexcivil@sanmateocourt.org.
Page 9 | LAW AND MOTION
Counsel for the moving parties must notify the Department 2 Clerk by telephone.
Counsel for the moving parties must notify the Clerk for Department 2 by telephone and by email at both dept2@sanmatecourt.org and complexcivil@sanmateocourt.org
Page 10 | LAW AND MOTION
Department 2 prefers email at Dept2@sanmateocourt.org, and responsive emails should include all parties.
Department 2 strongly prefers to be contacted by email at Dept2@sanmateocourt.org. If your email requires a response and your inquiry is not answered by Department 2's automatic reply to your email, Department 2 will do its best to respond as quickly as possible. All emails to Department 2 should include all parties.
Page 1 | Department Info of Judge Mark A. McCannon
Department 2 is open Monday through Friday, excluding court holidays, from 8:30 a.m. to 4:00 p.m., with a midday closure.
Monday – Friday (excluding court holidays) 8:30 a.m. – 4:00 p.m., closed 12:00 p.m. – 1:30 p.m.
Page 1 | Hours of Operation
Counsel may contact the Department 2 Clerk to ask whether oral argument will be permitted or the Court will decide on the written papers.
Counsel may contact the Clerk for Department 2 to inquire if oral argument will be permitted, or if the Court will rule based on the written papers.
Page 7 | EX PARTE APPLICATIONS
Junior Lawyer Participation Incentives
The court strongly encourages parties and senior attorneys to allow junior lawyers to participate in proceedings, particularly by arguing motions they drafted or substantially contributed to.
The Court therefore strongly encourages the parties and senior attorneys to allow the participation of junior lawyers in all court proceedings, particularly in arguing motions where the junior lawyer drafted or contributed significantly to the motion or opposition.
Page 11 | GENERAL MATTERS