Judge Frederick S. Chung
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- 17 copies
In Limine Motion, Exhibit List, Witness List, Jury Instruction Request, Proposed Verdict Form, Stipulation, Statement Of Case, Trial Brief, Jury Voir Dire Questions
- Hand Delivery • By Noon Court Day Before Trial
Motion, Brief, Exhibits, Witness List, Jury Instruction Request, Proposed Verdict Form, Stipulation, Statement Of Case, Jury Voir Dire Questions
Any Document Offered At Hearing
Court-wide- 3 copies • At Hearing
Adjournments
Court-wideRequest must include
Communication
Clerk6 contacts
- jssc@scscourt.org
- interpreterrequest@scscourt.org
- appealsclerks@scscourt.org
- complex@scscourt.org
- 4085345644
- (408) 882-5710
Chambers3 contacts
- department5@scscourt.org
- 408-882-2340
- 408-882-2180
Other Contacts1 contacts
- (408) 882-2761
Document Format Requirements1 rule
Counsel must provide the courtroom clerk with an Exhibit List in an editable Word version.
Counsel shall provide the courtroom clerk with an Exhibit List in an editable Word version.
DOCX
Document Filing Requirements6 rules
In bench trials, counsel must provide the court with a complete hard copy of specified pretrial submissions (in limine motions, exhibit/witness lists, stipulations, statement of the case, trial briefs) by noon on the court day before trial.
Unless otherwise ordered by the court, counsel in bench trials shall provide the court with a complete hard copy of the following by noon on the court day before the start of trial: all in limine motions; exhibit lists, except impeachment exhibits; witness lists, except impeachment witnesses; any stipulations on factual or legal issues; statement of the case; and trial briefs.
Document Type
Bench Trial Pretrial Submissions
A list of requested CACI jury instructions must be submitted to the court by noon on the day before trial.
A list of requested jury instructions (CACI) shall be submitted to the court by noon on the day before the start of trial.
Document Type
Jury Instructions
An edited set of jury instructions must be submitted at the earliest possible time after the conclusion of in limine motions.
An edited set of instructions shall be submitted at the earliest possible time after the conclusion of in limine motions.
Document Type
Jury Instructions Edited
Originals of all depositions that may be used at trial must be lodged with the court clerk before trial begins.
Originals of all depositions that may be used during trial are to be lodged with the court clerk before trial begins.
Document Type
Depositions
Non-CACI or pinpoint jury instructions must be submitted in writing.
Any non-CACI or pinpoint instructions shall be submitted in writing.
Document Type
Non Caci Instructions
Exhibit lists must include specific, brief descriptions identifying the substance of each exhibit; general descriptions are not sufficiently informative.
For all trials, on the respective exhibit lists, please provide specific and brief descriptions that identify the substance of each proffered exhibit. General descriptions such as “Documents produced by opponent in discovery” are not sufficiently informative.
Document Type
Exhibit List
Filing & Service rules
Filing Timing and Cure Windows
If no court reporter is retained, counsel must meet and confer daily to agree on a settled statement, which must be filed the following day at or before 8:45 a.m.
If you do not retain a court reporter, the court will order counsel to meet and confer at the end of each trial day to agree on a settled statement. The settled statement will be filed in court the following day at or before 8:45 a.m.
Page 2 | Court Reporters
The prevailing party must prepare and submit the judgment within 5 court days after trial concludes.
After a verdict is rendered by the jury, the prevailing party shall prepare the judgment, unless otherwise directed by the court. The judgment shall be submitted within 5 court days after the trial is concluded.
Page 8 | After Trial
If the parties cannot agree on a settled statement, one side's proposal redlined against the other is submitted, with plaintiffs responsible on even-numbered days and defendants on odd-numbered days.
If the parties cannot agree on a settled statement, they will submit one side's proposal redlined against the other side's proposal. On even numbered days of the month, plaintiffs will be responsible for the submission. On odd numbered calendar days, defendants will be responsible for the submission.
Page 2 | Court Reporters
Courtesy Copy Requirements
Counsel must email a courtesy copy of all e-filed documents to the court, copying all counsel, at department5@scscourt.org.
Please also email a courtesy copy of all e-filed documents to the court (copying all counsel). Again, the department email is department5@scscourt.org.
Page 2 | Jury Trials:
In jury trials, counsel must provide the court with courtesy hard copies of specified trial documents by noon on the court day before trial starts.
Unless otherwise ordered by the court, counsel in jury trials shall provide the court with courtesy hard copies of the following documents by noon on the court day before the start of trial: all in limine motions; exhibit lists, except impeachment exhibits; witness lists, except impeachment witnesses; jury instruction requests (see further discussion below); proposed verdict forms; any stipulations on factual or legal issues; a statement of the case; trial briefs; and any proposed special jury voir dire questions or proposed jury questionnaires.
Page 2 | Jury Trials:
In bench trials, counsel must email a courtesy copy of all e-filed documents to the court at department5@scscourt.org, copying all counsel.
Please also email a courtesy copy of all e-filed documents to the court (copying all counsel). The department email is department5@scscourt.org.
Page 3 | Bench Trials
Counsel must provide 16-17 copies of the final jury instructions to the court (12 for the jury, 2-3 for alternates, 1 for the judge, and 1 to be filed).
Counsel are responsible for providing 16-17 copies of the final instructions to the court (12 for the jury, two to three for alternates, one for the judge to read, and another copy to be filed).
Page 3 | Jury Instructions
Each party offering exhibits must prepare multiple identical, identically pre-numbered sets of all trial exhibits - one each for the judge, clerk, and witness - unless otherwise agreed upon and approved by the court.
Unless otherwise agreed upon and approved by the court, the court requires that each party offering exhibits be prepared with multiple identical and identically pre-numbered sets of all trial exhibits (other than unique and irreproducible physical objects), one for each of the following: • The judge • The clerk • The witness
Page 6 | Exhibits
Filing Bundling Requirements
A minimum of four full sets of pre-numbered exhibits is required.
Accordingly, this typically means a minimum of four full sets of pre-numbered exhibits.
Page 7
Pre-Motion Conference Requirements
In limine and other pretrial motions are heard on the record before the jury panel is called, absent special circumstances.
Absent special circumstances, in limine and other pretrial motions are to be heard on the record prior to calling a jury panel.
Page 3 | Jury Trials
Chambers Communication Rules
Counsel must inform the courtroom clerk where they can be reached at all times during jury deliberations.
in all cases, it is the responsibility of counsel to inform the courtroom clerk where they can be reached at all times.
Page 7
Attorneys must not contact the judge directly without express permission.
Attorneys should not contact the judge directly without express permission.
Page 1 | Contact
Attorneys must copy the other parties or counsel on any email to Department 5 to avoid ex parte communications.
To avoid ex parte communications, please also copy the other parties or counsel on any email to Department 5.
Page 1 | Contact
Parties must notify the court in advance if they anticipate needing more than four exhibit binders.
If either party anticipates needing more than four exhibit binders, please notify the court in advance to discuss alternative arrangements.
Page 7
Attorneys should email Department 5 at Department5@scscourt.org, which is monitored by the courtroom clerk between 8:30 a.m. and 4:30 p.m.
Attorneys should contact Department 5 by email at Department5@scscourt.org. This email address is typically monitored by the courtroom clerk between 8:30 a.m. and 4:30 p.m.
Page 1 | Contact
The department email is department5@scscourt.org.
The department email is department5@scscourt.org.
Page 3 | Bench Trials
Counsel should let the court know if they wish to visit trial jurors after discharge.
If counsel wish to have an opportunity to visit with trial jurors after they have been discharged, they should let the court know.
Page 8 | After Trial