San Mateo Superior Court Document Format Requirements

Each party must submit both a hard copy and a Word version of every proposed order.

Each party must also submit a hard copy and a Word version of all proposed orders.

Court-ordered changes to proposed verdict forms must be submitted in Word format by the Pretrial Conference deadline or another 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 Pretrial Conference or by any other deadline set by the Court.

The joint witness list must be tabular and state each witness’s name, title if any, anticipated subject matter, and estimated examination, cross-examination, redirect, and cross-redirect durations.

The joint 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 any redirect, and cross-redirect.

The parties must jointly submit one tabbed binder containing a joint pleading with designations, objections, and responses, using yellow highlighting for designations and red brackets for objections.

The parties must jointly submit one binder with a joint pleading that has the designations, objections and responses followed by tabs for each witness with the designation highlighted in yellow and any objections bracketed in red.

Each trial exhibit must be clearly marked with its trial exhibit number and bear the completed Court exhibit tag on the back of its last page.

Each trial exhibit must be clearly pre-marked with the trial exhibit number. The back of the last page of each trial exhibit must include the completed Court exhibit tag.

Trial exhibits must be numbered numerically, with no letters used in exhibit numbers.

Exhibits shall be numbered. NO letters may be used. Neither party shall use letters — 2 e.g., the exhibits must be numbered 1, 2, 3, NOT 1(a), 1(b), 1(c).

Each party must provide at least three complete hard-copy exhibit sets in tabbed binders no wider than 2½ inches and one complete thumb-drive set at least 14 days before trial.

Each party must provide the Court with at least three (3) complete sets of hard copy exhibits in tabbed BINDERS NO MORE THAN 2½ INCHES WIDE that the party intends to introduce at trial and one (1) complete set of exhibits on a thumb drive at least fourteen (14) days before the Trial Date.

A tag must be attached to the back of the last page of every exhibit.

The tag must be attached to the back of the last page of each exhibit

Required

Always

All documents subject to electronic filing, except exhibits, must be text searchable.

The documents (other than exhibits) must be text searchable.

Only the first page of each exhibit attached to an electronically filed document must be electronically bookmarked.

Please note that any exhibits to electronically filed briefs, declarations, or other documents must be electronically “bookmarked” as required by Cal. Rules of Court, rule 3.1110(f)(4). ALL PARTIES ARE REMINDED TO BOOKMARK ONLY THE FIRST PAGE OF EACH EXHIBIT AND NOT TO BOOKMARK EVERY PAGE OF EACH FILED DOCUMENT.

Department 11 emails must use at least 12-point type and be copied to every party or its counsel of record.

All e-mails must be sent in at least 12-point type and copied to all parties or their counsel of record.

The Judge’s Copy binder must be delivered to Department 11 within two court days by hand or overnight mail, and all exhibits must be separated by exhibit tabs.

The binder must be delivered within two court days of filing directly to Department 11 by hand or overnight mail to Courtroom G, 800 No. Humboldt St., San Mateo, California 94401. All exhibits must be separated by exhibit tabs.

Format

DOCX

The editable proposed-order submission must use Word format and must not use PDF.

You must also email an editable version of the Proposed Order in Word format (not PDF) to dept11@sanmateocourt.org and complexcivil@sanmateocourt.org so that the judge can modify it prior to signing, if needed.

Each trial exhibit must be clearly pre-marked with its trial exhibit number.

Each trial exhibit must be clearly pre-marked with the trial exhibit number.

Trial exhibits must be numbered sequentially using numbers only, with no letters or subdivisions.

Exhibits shall be numbered sequentially. NO letters may be used. Neither party shall use letters — e.g., the exhibits must be numbered 1, 2, 3, NOT 1(a), 1(b), 1(c).

Hard-copy trial-exhibit binders must be tabbed and no more than 2.5 inches wide.

at least three (3) complete sets of hard copy exhibits in tabbed BINDERS NO MORE THAN 2½ INCHES WIDE

A tag must be attached to the back of the last page of every exhibit.

The tag must be attached to the back of the last page of each exhibit

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.

Format

WORD_PERFECT

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.

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.

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.

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.

Exhibits must use numerical designations, and letters are prohibited.

Exhibits shall be numbered. NO letters may be used.

Every multi-page exhibit must be paginated or Bates numbered.

Multi-page exhibits must be paginated or bates numbered.

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.”

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.

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.

Format

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.

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.

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.

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.

Format

DOCX

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.

Discovery requests and responses may not be attached to an IDC brief without leave of court.

Do not attach the discovery requests and responses unless leave of Court is obtained.

Format

DOCX

An editable Word-format proposed order, rather than a PDF, must also be emailed to both Department 20 addresses for possible modification before signing.

You must also email an editable version of the Proposed Order in Word format (not PDF) to dept20@sanmateocourt.org and complexcivil@sanmateocourt.org so that the judge can modify it prior to signing, if needed.

Format

DOCX

The written order must also be emailed to Department 20 in Word format.

The party must also email the order in Word format to Department 20 at Dept20@sanmateocourt.org.

The last page of each trial exhibit must include the completed Court exhibit tag.

last page of each trial exhibit must include the completed Court exhibit tag. (See Appendix A.)

Exhibits must be numbered, and alphabetic exhibit designations may not be used.

27. Exhibits shall be numbered. No letters may be used.

Exhibits must be marked and referred to as “Exhibit No. _____,” not as a party's exhibit.

To avoid any party claiming “ownership” of an exhibit, all exhibits shall be marked and referred to as “Exhibit No. _____” – and NOT as “Plaintiff’s Exhibit” or “Defendant’s Exhibit.”

The official exhibit tag must be placed on the back of the last page of each trial document.

Each party will be expected to place the official exhibit tag on the back of the last page of each document; the exhibit tags may be obtained from the courtroom clerk, or the parties may copy the template at Appendix A.

Format

DOCX

The parties must email the proposed orders to the Court in Word format.

The parties must also email the proposed orders in Word format to the Court at dept20@sanmateocourt.org.

A tag identifying the exhibit, case number, and exhibit status must be attached to the back of the last page of each exhibit.

This tag must be attached to the back of the last page of each exhibit:

Format

PAPER

The moving papers, including a proposed order, must be submitted in paper form to the assigned judge by 10:00 a.m. two court days before the ex parte appearance.

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.

Format

DOCX

Each party must submit both a hard copy and a Word version of all proposed orders.

Each party shall also submit a hard copy and a Word version of all proposed orders.

The joint witness list must be tabular and state each witness's name, title if any, anticipated subject matter, and estimated examination lengths.

The joint 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, redirect, and cross-redirect.

The parties must jointly submit one binder containing the designations, objections, responses, witness-specific tabs, yellow-highlighted designations, and objections bracketed in red.

They shall jointly submit one binder with a joint pleading that has the designations, objections and responses followed by tabs for each witness with the designation highlighted in yellow and any objections bracketed in red.

Each trial exhibit must be clearly pre-marked with its trial exhibit number, with the defendant's sequence beginning after the plaintiff's sequence.

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 numeric designations, and letters may not be used.

Exhibits shall be numbered. NO letters may be used.

The parties must agree on exhibit-number blocks sufficient for the case and make a good-faith effort to avoid assigning the same number to multiple exhibits.

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 joint exhibit list must be tabular and include the exhibit number, description and any Bates numbers, sponsoring witness, and blank spaces for the identification and admission dates.

The joint 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); and e. Date admitted into evidence (left blank).

At least seven days before trial, each party must provide the court a complete set of intended trial exhibits in tabbed hard-copy binders and on a thumb drive.

Each party must provide the Court with a complete set of exhibits that the party intends to introduce at trial in both hard copy in tabbed binders and on a thumb drive at least seven (7) days before the Trial Date.

Each party must apply the official exhibit stamp to each exhibit document, and exhibit tabs are available 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.

Format

DOCX

Court-ordered changes to proposed verdict forms must be submitted in Word format by the applicable Pretrial Conference or 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 Pretrial Conference or by any other deadline set by the Court.

The joint witness list must be presented in tabular form.

The joint witness list must be in tabular form and contain the following:

The deposition binder must use tabs for each witness, highlight designations in yellow, and bracket objections in red.

The parties must jointly submit one binder with a joint pleading that has the designations, objections and responses followed by tabs for each witness with the designation highlighted in yellow and any objections bracketed in red.

Each trial exhibit must be clearly pre-marked with its trial exhibit number.

Each trial exhibit must be clearly pre-marked with the trial exhibit number.

The completed Court exhibit tag must appear on the back of the last page of each trial exhibit.

The back of the last page of each trial exhibit must include the completed Court exhibit tag.

The trial exhibit list must begin with plaintiff's first exhibit number, continue with defendant's numbering after plaintiff's numbers, and avoid party-specific exhibit labels.

The trial exhibit list must begin with the plaintiff’s first exhibit number. Defendant’s exhibit numbers must be sequenced to begin after the plaintiff’s exhibit numbers. DO NOT identify the exhibits as plaintiff’s or defendant’s.

Each party must provide at least three complete hard-copy sets of trial exhibits in tabbed binders no wider than 2½ inches.

Each party must provide the Court with at least three (3) complete sets of hard copy exhibits in tabbed BINDERS NO MORE THAN 2½ INCHES WIDE that the party intends to introduce at trial

Format

DOCX

The proposed jury instructions, verdict forms, jury questionnaire, statement of the case, and proposed orders must be emailed to the Court in Word format.

The parties must also email the 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 at dept28@sanmateocourt.org.

Trial exhibits must also be provided on a thumb drive.

trial exhibits in BINDERS NO MORE THAN 2½ INCHES WIDE – and on a thumb drive

Each trial exhibit must be clearly pre-marked with its trial exhibit number.

Each trial exhibit must be clearly pre-marked with the trial exhibit number.

The joint witness list must be submitted in tabular form and include witness names, titles, anticipated testimony subjects, and estimated examination lengths.

The joint 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 any redirect, and cross-redirect.

The parties must submit deposition designations and objections with the Joint Pretrial Conference Statement and include transcript excerpts rather than only page-and-line references.

The parties shall also submit their deposition designations and objections with the Joint Pretrial Conference Statement. The parties must submit copies of the excerpts of the designated portions of the deposition transcripts, NOT a list of page and line numbers.

The parties must jointly submit one binder containing a joint pleading with designations, objections, responses, and separate witness tabs using yellow highlighting for designations and red brackets for objections.

The parties must jointly submit one binder with a joint pleading that has the designations, objections and responses followed by tabs for each witness with the designation highlighted in yellow and any objections bracketed in red.

The completed Court exhibit tag must appear on the back of the last page of each trial exhibit.

The back of the last page of each trial exhibit must include the completed Court exhibit tag.

Trial exhibits must be numbered sequentially and may not use letters.

Exhibits shall be numbered sequentially. NO letters may be used.

All exhibits must be marked and referred to as “Trial Exhibit No. ___,” not as plaintiff’s or defendant’s exhibits.

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 joint exhibit list must be tabular and state each exhibit’s number, brief description and Bates numbers if any, and sponsoring witness.

The joint 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;

At least 14 days before trial, each party must provide three complete hard-copy exhibit sets in tabbed binders no wider than 2½ inches and one complete thumb-drive set.

Each party must provide the Court with at least three (3) complete sets of hard copy exhibits in tabbed BINDERS NO MORE THAN 2½ INCHES WIDE that the party intends to introduce at trial and one (1) complete set of exhibits on a thumb drive at least fourteen (14) days before the Trial Date.

Trial exhibit binders must not be labeled as plaintiff’s exhibits or defendant’s exhibits.

The binders MUST NOT be identified as “plaintiff’s exhibits” or “defendant’s exhibits.”

Electronically served documents other than exhibits must be text searchable.

The documents (other than exhibits) must be text searchable.

Exhibits to electronically filed documents must be electronically bookmarked, with only the first page of each exhibit bookmarked.

Please note that any exhibits to electronically filed briefs, declarations, or other documents must be electronically “bookmarked” as required by Cal. Rules of Court, rule 3.1110(f)(4). All parties are reminded to bookmark only the first page of each exhibit and not to bookmark every page of each filed document.

Department 28 emails must use at least 12-point type and be copied to all parties or their counsel of record.

All e-mails must be sent in at least 12-point type and copied to all parties or their counsel of record.

Courtesy copies of electronic exhibits must be submitted on a flash drive under the cited rules, and file-sharing methods are not accepted.

Courtesy copies of any electronic exhibits must be submitted on a flash drive in conformity with the requirements of the California Rules of Court, rules 2.256(b) and 3.1110(f)(4). The Court cannot receive documents through any type of file sharing.

Format

DOCX

An editable Word-format version of each proposed order, rather than a PDF, must be emailed to both Department 28 addresses for possible judicial modification.

You must also email an editable version of the Proposed Order in Word format (not PDF) to dept28@sanmateocourt.org and complexcivil@sanmateocourt.org so that the judge can modify it prior to signing, if needed.

All exhibits must be marked and referred to as “Trial Exhibit No.” rather than as plaintiff’s or defendant’s exhibits.

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.”

An appendix of non-California authorities ordinarily is not required, but cited authorities not reported in an official reporter must use a Westlaw-accessible citation or be emailed to both stated Department 11 addresses.

Pursuant to Cal. Rule of Court, rule 3.113(i), Department 11 does not require an appendix of non-California authorities in connection with any memoranda submitted in connection with any motion unless otherwise ordered by the Court with the following exception: Because the Court only has access to non-California authorities via WESTLAW – and NOT via LEXIS – 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 11 by email at dept11@sanmatecourt.org and complexcivil@sanmatecourt.org.

Courtesy-copy documents of five pages or fewer may be submitted either in hardcopy or by email to Department 11.

Documents 5 pages or less may be submitted in hardcopy or via email to Dept11@sanmateocourt.org.

The motions-in-limine binders must be tabbed, numerically ordered, and organized by motion and opposition, while declarations, judicial-notice requests, and exhibits must appear in a separate tabbed binder submitted with the Joint Pretrial Conference Statement.

Each party must submit a tabbed binder with its motions in limine in numerical order with the opposition immediately behind the motion within the same tab. Any declarations or requests for judicial notice submitted by the parties in support of or in opposition to the motions in limine along with any attached exhibits must be submitted in a separate tabbed binder. The binders must be submitted to the Court with the Joint Pretrial Conference Statement.

Format

DOCX

Each party must submit both a hard copy and a Word version of every proposed order.

Each party must also submit a hard copy and a Word version of all proposed orders.

The joint deposition binder must use witness-specific tabs, yellow highlighting for designations, and red brackets for objections.

The parties must jointly submit one binder with a joint pleading that has the designations, objections and responses followed by tabs for each witness with the designation highlighted in yellow and any objections bracketed in red.

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.

Multi-page exhibits must be paginated or Bates-numbered.

Multi-page exhibits must be paginated or bates numbered.

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.

Each trial exhibit must be clearly pre-marked, and defendant exhibit numbers must begin after plaintiff exhibit numbers.

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 number blocks while making 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.

Applies to

Jury instructions

The parties may use CACI form instructions, but any modifications must be plainly identified.

67. The parties are invited to use the Judicial Council of California Civil Jury Instructions (CACI). Any modifications made to a form instruction must be plainly identified.

A colored sheet of paper must separate each motion in limine from its opposition.

The MIL and its opposition must be separated by a colored sheet of paper.

Each party must submit both a hard copy and a Word version of every proposed order.

Each party must also submit a hard copy and a Word version of all proposed orders.

Format

DOCX

The specified trial-preparation documents must be submitted in Word format.

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.

The parties must agree on separate exhibit-number blocks and make a good-faith effort to avoid marking the same exhibit in both blocks.

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.

Any modification to a Judicial Council of California Civil Jury Instructions form must be plainly identified.

Any modifications made to a form instruction must be plainly identified.

Changes to proposed verdict forms ordered by the Court must be submitted in Word format by the deadline set at the pretrial conference 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.

The materials emailed to the Court must be in Word format.

in Word format

Each motion in limine must be clearly identified using the specified MIL number and topic format.

Each motion should be clearly identified as “__________’s MIL No. ___ Re: ____________,” with the blanks filled in as appropriate.

Electronically served documents other than exhibits must be text searchable.

The documents (other than exhibits) must be text searchable.

Exhibits to electronically filed briefs, declarations, and other documents must be electronically bookmarked.

Any exhibits to electronically filed briefs, declarations, or other documents must be electronically “bookmarked” as required by Cal. Rules of Court, rule 3.1110(f)(4).

Format

DOCX

A proposed ex parte order should be provided in Word format.

The proposed order should be provided in Word format.

The single pretrial binder provided to the court must be no more than 2-3 inches wide.

provide one (1) binder (no more than 2-3 inches wide) to the Court

Trial exhibits must be delivered in binders no more than 2-3 inches wide and also on a thumb drive.

Deliver to the Court at least four (4) sets of trial exhibits in binders (no more than 2-3 inches wide) and on a thumb drive.

The tabbed binders must be submitted with the Joint Pretrial Conference Statement and should be no more than 2–3 inches wide.

The binders must be submitted to the Court with the Joint Pretrial Conference Statement. Binders should be no more than 2-3 inches wide.

Format

DOCX

Each party must submit both a hard copy and a Word version of all proposed orders.

Each party must also submit a hard copy and a Word version of all proposed orders.

The first page of the final jury instructions should include only the CACI number and title; the footer may include the case name, case number, and page number.

Rather, the top of the first page should include only the CACI number and title. The footer may include the case name and number, and page number.

Format

DOCX

Court-ordered changes to proposed verdict forms must be made by the parties and 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 Pretrial Conference or by any other deadline set by the Court.

Each trial exhibit must be clearly pre-marked with its trial exhibit number.

Each trial exhibit must be clearly pre-marked with the trial exhibit number.

Any modification to a Judicial Council of California Civil Jury Instructions form must be plainly identified.

Any modifications made to a form instruction must be plainly identified.

All proposed versions of the same jury instruction must use the same instruction number.

All proposed versions of the same instruction shall bear the same number.

All exhibits must be marked and referred to as “Trial Exhibit No. ___,” not as plaintiff’s or defendant’s exhibits.

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.”

Format

DOCX

The parties must email the listed proposed trial documents to the Court in Word format.

37. The parties shall also email the 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.

The required pretrial binder may be no more than 2½ inches wide.

Parties must file joint pretrial conference statement, and provide to the Court one (1) set of BINDERS NO MORE THAN 2½ INCHES WIDE – with the following:

The trial-exhibit binders may be no more than 2½ inches wide, and the exhibits must also be provided on a thumb drive.

Deliver to the Court at least three (3) sets of trial exhibits in BINDERS NO MORE THAN 2½ INCHES WIDE – and on a thumb drive

Any modifications to a form jury instruction must be plainly identified.

Any modifications made to a form instruction must be plainly identified.

The first page of each jury instruction should contain only the CACI number and title at the top, while the footer may contain the case name and number and page number.

the top of the first page of each instruction should include only the CACI number and title. The footer may include the case name and number and page number.

Exhibits must be numbered, and letters may not be used for exhibit numbers.

Exhibits shall be numbered. NO letters may be used.

Exhibits must be labeled “Trial Exhibit No. ___” rather than as plaintiff’s or defendant’s exhibits.

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.”

Trial-exhibit binders may not be identified as plaintiffs’ or defendants’ exhibits.

The binders MUST NOT be identified as “plaintiff’s exhibits” or “defendant’s exhibits.”

Each party must place the official exhibit tag on the back of the final page of each exhibit document.

Each party will be expected to place the official exhibit tag on the back of the last page of each document; the exhibit tags may be obtained from the courtroom clerk, or the parties may copy the template at Appendix A.

An exhibit tag must be attached to the back of the last page of every exhibit.

The tag must be attached to the back of the last page of each exhibit

The joint pretrial conference statement must be provided in binders no more than 2½ inches wide.

one (1) set of BINDERS NO MORE THAN 2½ INCHES WIDE

Trial exhibits must be delivered in binders no more than 2½ inches wide.

at least three (3) sets of At least 14 days before the Trial Date trial exhibits in BINDERS NO MORE THAN 2½ INCHES WIDE

Each motion in limine must use the specified motion title with the party name, motion number, and topic completed.

Each motion should be clearly identified as “__________’s Motion in Limine No. ___ Re: ____________,” with the blanks filled in as appropriate.

Format

DOCX

Proposed orders emailed to the Court must be in Word format.

The parties must also email the proposed orders in Word format to the Court at dept28@sanmateocourt.org.

An exhibit tag must be attached to the back of the last page of every exhibit.

The tag must be attached to the back of the last page of each exhibit

An informal-conference brief submitted by email must be prepared on court pleading paper and must be served.

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 dept28@sanmateocourt.org and complexcivil@sanmateocourt.org.

A proposed order should, if possible, be provided in Word format.

The proposed order should be provided in Word format if possible.

Format

DOCX

An ex parte proposed order should be provided in Word format when possible.

The proposed order should be provided in Word format if possible.

Format

DOCX

The proposed order should be provided in Word format when possible.

The proposed order should be provided in Word format if possible.

Stipulations may bear electronic signatures.

Electronic signatures on stipulations are permitted.