Judge Charmaine H. Buehner
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Administrative Record
Brief, Opposition, Reply
- At 8:30 A.M. The Court Day After Filing
Trial Documents
- After Submission Next Court Day By 8:30 Am
Trial Exhibits
- 3 copies
Communication
Phone
Phone
Court-wideClerk
Page & Word Limits2 rules
Each motion in limine is limited to five pages, and its attached exhibits are limited to 20 pages.
Each motion has a 5-page limit, attached exhibits to each motion must be no more than 20 pages
Motion In Limine
5 pages
Exhibits
20 pages
Trial briefs are optional but strongly preferred and, when submitted, may not exceed five pages and must be emailed to the court and served on all parties.
Trial Briefs are strongly preferred but not required. Trial briefs must be a maximum of 5 pages, emailed to court and served on all parties.
Trial Brief
5 pages
Document Format Requirements13 rules
Relevant portions must be highlighted on any exhibit exceeding five pages.
If an exhibit is more than five pages, highlight the relevant portions.
Every page of every exhibit must be numbered in an exhibit-and-page format.
Page Numbering: Each page of each exhibit must be numbered (e.g., Exh. A, Page 1).
Paper copies of exhibits must be tabbed by exhibit number.
Paper copies must be tabbed by exhibit number.
Electronically submitted exhibits must be bookmarked and text searchable.
Trial-document chambers copies must be placed in a labeled, tabbed three-ring binder with a document index.
The chambers copies shall be placed in a labeled and tabbed 3-ring binder with an index of documents.
All trial exhibits must be pre-marked with numbers using a unique number range for each party.
Pre-mark all exhibits with numbers (unique number ranges per party)
Trial exhibits must be placed in numerically tabbed binders whose spines show the exhibit-number ranges.
Place exhibits in numerically tabbed binders with binder spines to reflect exhibit number ranges
An electronic administrative record must be lodged on a thumb drive inside an 8½-by-11-inch envelope bearing a case-caption page on its front.
Electronic administrative records must be lodged with the Court on a thumb drive contained in an 8 ½ x 11 envelope with a case caption page on the front of the envelope.
If a paper administrative record is submitted, it must be delivered to Department 44 and comply with Rule 3.1110(f)(1)-(3).
If a paper copy of the administrative record is provided, the record shall be delivered to Department 44 and must comply with Rule 3.1110(f) (1)-(3).
Paper
Duplicate trial exhibits are prohibited.
No duplicate exhibits
Electronic exhibits must be indexed and bookmarked, should be text-searchable when possible, and each record page must be identified by its Administrative Record page number and index description.
Electronic exhibits must have an index, be bookmarked, text searchable (whenever possible), and each page of the record must be identified by the page number of the Administrative Record, and according to the index description.
Every exhibit page must bear an exhibit and page number, and standalone unattached pages will not be admitted.
Each page of every exhibit must be marked by exhibit and page number (e.g., Exh. 1-001, or Exh. 1, p. 1.). Standalone pages will not be admitted from an exhibit.
When an administrative record is divided into volumes, each page should identify its volume, exhibit number, and page number.
To the extent the record is broken up into volumes, each page of the Administrative Record should reflect the Volume, Exhibit Number, and Page Number.
Document Filing Requirements7 rules
The joint PTC statement must summarize the case and resolution efforts, confirm the trial estimate, identify witnesses and examination estimates, detail issues requiring court involvement, and include trial counsel's certification of compliance.
Required Joint PTC Statement Contents: 1. Case Summary (claims, damages, defenses) 2. Resolution efforts to date and status of same 3. Confirm trial time estimate; provide a list of witnesses and examination estimates 4. Detail issues that may require court involvement, such as bifurcation, consolidation, or particularly complicated evidentiary issues that should be decided before trial 5. Trial counsel certification that they have read and will adhere to these rules
Document Type
Joint Pretrial Conference Statement
The joint stipulations must identify issues that need not be tried, or the parties must state that no stipulations exist.
Stipulations must detail any issues that do not need to be tried. If there are no stipulations, the parties must so state.
Document Type
Joint Stipulations
The Joint Witness List must include each witness's name, relationship to the case, brief offer of proof, and examination time estimates.
Joint Witness List must include: (a) name, (b) relationship to the case, (c) brief offer of proof, (d) time estimates for direct, cross and re-direct examination.
Document Type
Joint Witness List
The joint jury-instruction list must provide agreed-upon CACI numbers and identify each disputed CACI instruction and its offering party.
Joint LIST of Jury Instructions. A list of agreed-upon CACI instruction numbers shall be provided. Any disputed CACI instructions must also be included and identified by the offering party.
Document Type
Joint Jury Instruction List
The Joint Exhibit List must eliminate duplicate exhibits and include descriptions, admissibility stipulations, and objections.
Joint Exhibit List must remove all duplicate exhibits, and include: (a) brief exhibit description, (b) any stipulations for admissibility, (c) objections.
Document Type
Joint Exhibit List
The parties must ensure that every party has sufficient copies of the exhibits.
The parties are responsible to ensure that all parties have sufficient copies of exhibits.
Document Type
Trial Exhibits
Parties are advised to avoid motions in limine that merely enforce existing law or restate general legal propositions without tying them to evidence to be excluded.
Avoid MILs that seek compliance with existing law or restate general propositions of law without reference to the evidence to be excluded (e.g., Motion to exclude all settlement discussions, Motion to exclude all evidence not produced in discovery).
Document Type
Motion In Limine
Filing & Service rules
Electronic Filing Rules
A joint written request emailed to courtroom44@ventura.courts.ca.gov is required for an informal discovery conference, which is held Tuesday through Friday at 1:30 p.m. and limited to 15 minutes for basic disputes or 30 minutes for complex disputes.
Joint Written Request Required: email courtroom44@ventura.courts.ca.gov Held: 1:30 p.m., Tuesday - Friday Time Limits: 15 minutes (basic disputes); 30 minutes (complex disputes) Compliance Required: LR 8.10
Page 3 | E. Informal Discovery Conferences
Trial documents must not be resubmitted if the trial is continued.
Do not resubmit trial documents if the trial trails.
Page 5 | II. TRIAL RULES & PROCEDURES — A. Trial Documents — 1. E-Mail Trial Documents
Trial documents other than writ-proceeding trial documents must be emailed to the specified courtroom email address between 5 and 30 days before trial.
All trial documents (other than writ proceeding trial documents) must be e-mailed to courtroom44@ventura.courts.ca.gov at least 5 court days before trial but no more than 30 days prior to trial.
Page 5 | II. TRIAL RULES & PROCEDURES — A. Trial Documents — 1. E-Mail Trial Documents
Trial documents other than writ trial documents must not be filed with the court because the clerk will reject them.
Except for writ trial documents, DO NOT FILE trial documents with the Court; they will be rejected by the Court clerk.
Page 5 | II. TRIAL RULES & PROCEDURES — A. Trial Documents — 1. E-Mail Trial Documents
If fewer than all parties submit on the tentative ruling, the hearing will proceed and the tentative ruling may change.
If fewer than all parties submit on the tentative ruling, the hearing will be conducted and the tentative may change.
Page 4 | I. Tentative Rulings
A submission on a tentative ruling must be emailed to courtroom44@ventura.courts.ca.gov before 8:00 a.m. on hearing day using the prescribed subject line.
To submit on the tentative: Email courtroom44@ventura.courts.ca.gov before 8:00 a.m. on hearing day. Subject line: “SUBMISSION ON TENTATIVE,” [Case Number], [Title], and [Party].
Page 4 | I. Tentative Rulings
The court strongly prefers, but does not require, an electronic administrative record.
The Court strongly prefers an electronic administrative record.
Page 6 | II. TRIAL RULES & PROCEDURES — B. Writ Trial Documents — 2. Administrative Record
Filing Timing and Cure Windows
An ex parte application must be filed by noon on the court day before its hearing.
Filing Deadline Noon the court day before hearing
Page 2 | I. PRE-TRIAL RULES & PROCEDURE — C. Ex-Parte Applications
The joint pretrial conference statement must be submitted five court days before the pretrial conference.
Joint PTC statement due 5 court days in advance of the PTC
Page 4 | J. Pretrial Conferences (PTC)
A tentative-ruling submission must be made before 8:00 a.m. on hearing day.
To submit on the tentative: Email courtroom44@ventura.courts.ca.gov before 8:00 a.m. on hearing day. Subject line: “SUBMISSION ON TENTATIVE,” [Case Number], [Title], and [Party].
Page 4 | I. Tentative Rulings
The parties must meet and confer at least 14 days before the joint trial documents are due.
The parties are ordered to meet and confer at least 14 days in advance of when the joint documents are due to the Court:
Page 5 | II. TRIAL RULES & PROCEDURES — A. Trial Documents — 3. Required JOINT Trial Documents
All motion-in-limine briefing must be completed five court days before trial.
Parties must complete all MIL briefing by the day they are due (5 court days before trial)
Page 5 | II. TRIAL RULES & PROCEDURES — A. Trial Documents — Motions in Limine
Ordinary trial documents must be emailed at least five court days before trial.
All trial documents (other than writ proceeding trial documents) must be e-mailed to courtroom44@ventura.courts.ca.gov at least 5 court days before trial but no more than 30 days prior to trial.
Page 5 | II. TRIAL RULES & PROCEDURES — A. Trial Documents — 1. E-Mail Trial Documents
Service and Proof of Service Rules
A tentative-ruling submission must be copied to all parties.
Copy all parties.
Page 4 | I. Tentative Rulings
The prevailing party must serve and file a proposed judgment consistent with the jury verdict.
The prevailing party shall serve and file the proposed judgment consistent with the verdict.
Page 8 | N. Entry of Judgment
Counsel should avoid delayed service or failure to provide proof of service.
• Delayed service or no proof of service. (CRC 3.110, 3.740; Gov’t Code. § 68616(a))
Page 1 | I. PRE-TRIAL RULES & PROCEDURE — B. Case Management — 2. Common Issues to Avoid
Filing Fees and Waivers
Jury fees must be submitted by check to the judicial assistant on the first day of trial.
Submit jury fees by check to the judicial assistant on the first day of trial.
Page 6 | II. TRIAL RULES & PROCEDURES — C. Jury Fees
Parties must timely post jury fees.
• Failure to timely post jury fees. (Code Civ. Proc. § 631)
Page 1 | I. PRE-TRIAL RULES & PROCEDURE — B. Case Management — 2. Common Issues to Avoid
Courtesy Copy Requirements
Copies of summary judgment, adjudication, and class certification motion documents must be delivered to Courtroom 44 at 8:30 a.m. on the court day after filing.
Mandatory Chambers Copies: Deliver to Courtroom 44 at 8:30 a.m. the court day after the documents are filed.
Page 4 | G. Summary Judgment/Adjudication & Class Certification Motions
A chambers copy of the administrative record must be delivered to Department 44.
The Court requires a chambers copy of the administrative record to be delivered to Department 44.
Page 6 | II. TRIAL RULES & PROCEDURES — B. Writ Trial Documents — 2. Administrative Record
Three copies of each exhibit are required: one for the judge, one for the court clerk, and one for the witness stand.
Three copies of exhibit are required (one for the judge, one for the court clerk, and one for the witness stand).
Page 6 | II. TRIAL RULES & PROCEDURES — F. Trial Exhibits
Paper chambers copies of trial documents must be delivered to Courtroom 44 by 8:30 a.m. on the next court day after emailing.
Mandatory Paper Chambers Copies of Trial Documents are to be delivered to Courtroom 44 by 8:30 a.m. the court day after they are emailed.
Adjournment & Extension Requirements
Trial dates are firm, continuances are disfavored, and any continuance must comply with CRC 3.1332.
Trial dates are firm; continuances are disfavored and must comply with CRC 3.1332.
Page 2 | I. PRE-TRIAL RULES & PROCEDURE — B. Case Management — 3. Case Dates
Chambers Communication Rules
To reserve an ex parte application, call the Judicial Secretary at 805-289-8791 by 10 a.m. on the preceding court day.
Call Judicial Secretary 805-289-8791 by 10 a.m. the court day before
Page 2 | I. PRE-TRIAL RULES & PROCEDURE — C. Ex-Parte Applications