Judge Ronda J. McKaig
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Attorney filings
Exhibits
- 1 copy
- 1 copy • On First Day Of Trial
Courtesy copies
Court-wide- Email • Upon Filing
Joint Request For Idc
Court-wideAdjournments
Court-wideRequest must include
Communication
Chambers
Phone
Court-wideClerk
Phone
Court-widePage & Word Limits3 rules
Informal discovery conference requesting and responding papers are limited to five pages, excluding exhibits, which should contain only information necessary to explain the dispute.
Requesting and responding papers shall not exceed five (5) pages in length, excluding exhibits, and exhibits should include only such information as is necessary to explain the discovery dispute.
Discovery Request
5 pages
Discovery Response
5 pages
Motions in limine are limited to five pages.
Motions shall not exceed five (5) pages.
Motion In Limine
5 pages
Trial briefs are limited to five pages, must be served on all parties, and must be emailed to the court three court days before trial.
Trial briefs shall be no more than five (5) pages and shall be served on all parties and emailed to courtroom42@ventura.courts.ca.gov three (3) court days before the trial.
Trial Brief
5 pages
Document Format Requirements8 rules
All exhibits, including impeachment materials, must be pre-marked with numbers, and each party must use a unique number range.
All exhibits, including impeachment materials, shall be pre-marked using numbers, with each party assigned a unique number range to avoid duplication.
The parties must agree on a master exhibit set, excluding impeachment materials, and place it in numerically tabbed binders no thicker than two inches.
The parties shall agree on a master set of exhibits, excluding impeachment materials, and shall place such exhibits into numerically tabbed binders, which binders shall not be more than two inches.
Each exhibit binder's spine must be labeled with the exhibit numbers contained in it.
The spine of the binder shall be appropriately labeled and shall indicate the exhibit numbers contained therein.
Each page of a multi-page exhibit must be numbered at the bottom with the exhibit number and consecutive page number.
Multi-page exhibits shall be numbered at the bottom of the page with the exhibit number plus the consecutive page number of the exhibit (i.e. Ex. 17-003 to refer to page 3 of exhibit 17).
A party using slides must provide printed hard copies to counsel and the clerk no later than 15 minutes before the presentation.
Any party showing a PowerPoint or similar presentation to the jury in opening statements or closing arguments shall provide a printed hard copy of the slides to counsel and the clerk not later than 15 minutes before the presentation.
Paper
Parties should include only exhibits relevant and necessary to the motion and highlight the relevant portions.
Parties should limit exhibits to only those relevant and necessary to the motion, with relevant portions highlighted.
Exhibits supporting or opposing motions should be consecutively numbered at the bottom of each page, and exhibit references in briefs or declarations should include the page number.
All pages of exhibits submitted in support of or opposition to motions should be consecutively numbered at the bottom of the page and references to exhibits in briefs or declarations should include the page number.
Pages intended for separate admission should be individually tabbed and numbered as standalone exhibits.
If the parties wish to admit only certain pages of an exhibit, those pages should be separately tabbed and numbered as standalone exhibits.
Document Filing Requirements16 rules
Litigants must timely file complete and accurate case-management statements.
• (e) timely file complete and accurate case management statements.
Document Type
Case Management Statement
IDC requesting papers must use the subject line “REQUEST FOR IDC,” be emailed to the Courtroom 42 address, and include a simultaneous email copy to all other counsel or self-represented parties.
To request an IDC, requesting papers with the subject line “REQUEST FOR IDC” must be emailed, with a simultaneous email copy to all other counsel/self-represented parties, to courtroom42@ventura.courts.ca.gov .
Document Type
Idc Requesting Papers
The Joint ADR Status Conference Statement must be filed and served at least five court days before the ADR Status Conference.
The ADR Status Conference Statement shall be filed and served at least five (5) court days before the ADR Status Conference and must contain the following:
Document Type
Joint Adr Status Conference Statement
Deposition transcripts intended for use at trial must be lodged on the first day of trial, with a separate notice of lodging for each transcript.
Deposition transcripts on which the parties intend to refer to or read from at trial must be lodged with the Court on the first day of trial, and each transcript shall have its own notice of lodging.
Document Type
Deposition Transcript
Prevailing parties must serve and file proposed judgments consistent with the jury’s verdicts and applicable rules.
The Court will direct the prevailing party(ies) to serve and file a proposed judgment(s) consistent with the jury’s verdict(s) and in conformity with the Rules of Court and the Code of Civil Procedure.
Document Type
Proposed Judgment
The ADR statement must briefly summarize the case, causes of action, primary monetary damages or other relief sought, and primary defenses asserted.
1. A brief summary of the nature of the case; the causes of action in the complaint/ cross- complaint; the primary monetary damages and/or other relief sought; and the primary defenses asserted.
Document Type
Joint Adr Status Conference Statement
An IDC request should describe the discovery dispute, identify the interrogatory or request and related response or objections, and explain the significance and compliance burden or expense of the information sought.
1. The nature of the discovery dispute, including the interrogatory or request number at issue, the response and objections thereto, the significance of the information sought, and the burden or expense of compliance.
Document Type
Idc Requesting Papers
An IDC request should identify any timing issues concerning the disputed discovery.
3. Any issues of timing concerning the disputed discovery.
Document Type
Idc Requesting Papers
The ADR statement must summarize all efforts the parties have made to resolve the case.
2. A summary of any and all efforts made by the parties to resolve the case to date.
Document Type
Joint Adr Status Conference Statement
The ADR statement must describe trial readiness and identify issues potentially requiring Court involvement, including specified procedural and evidentiary matters.
4. The parties’ readiness for trial and identification of any issues that may require court involvement, such as bifurcation, consolidation, dispositive motions, or particularly complicated evidentiary issues that will need to be decided before trial.
Document Type
Joint Adr Status Conference Statement
An IDC request should summarize the parties’ discovery-resolution efforts and any proposed resolutions.
2. A summary of efforts made by the parties to resolve the discovery dispute, including any proposals for resolution.
Document Type
Idc Requesting Papers
The ADR statement must identify planned additional resolution steps and explain whether the parties seek any assistance from the Court.
3. Additional steps the parties plan to take to resolve the case going forward and whether there is anything the Court can do to assist.
Document Type
Joint Adr Status Conference Statement
An IDC request should state the parties’ willingness to modify the discovery request or response to address the dispute.
4. The willingness of the parties to modify the discovery request or response to address the discovery dispute.
Document Type
Idc Requesting Papers
Exhibits must be specifically identified and authenticated by a compliant supporting declaration.
Document Type
Exhibits
Emails submitting trial documents should identify the case name, case number, and document description in the subject line, and all parties must be copied.
When trial documents are emailed to the Court, the subject line should include the name of the case, the case number and a description of the document being emailed as authorized herein. All parties shall be copied on any email to the Court.
Document Type
Trial Document Email
A responsive pleading should use the party’s name as identified in the complaint and, when the names differ, state that the response is made on behalf of both names using “ESA.”
4. Take care to respond to pleadings with reference to the name by which the party was identified in the complaint (i.e. if a defendant’s name is “John W. Smith” but the complaint identifies him as “John Smith,” the answer would appropriately state it is made on behalf of “John W. Smith ESA John Smith.”)
Document Type
Responsive Pleading
Filing & Service rules
Electronic Filing Rules
Trial documents do not need to be resubmitted if the trial is continued.
Once trial documents are received by the Court, they do not need to be resubmitted in the event the trial trails.
Page 3 | V. Trial Rules and Procedures
Filing Timing and Cure Windows
Litigants must timely file and serve their responses to complaints.
• (b) timely file and serve responses to complaints,
Page 1 | I. Case Management
Litigants must timely file requests for entry of default and default judgment.
• (c) timely file requests for entry of default and default judgment,
Page 1 | I. Case Management
IDC responding papers must be emailed to Courtroom 42 no later than five days after the requesting papers.
Responding papers must be emailed to courtroom42@ventura.courts.ca.gov not later than five (5) days after the requesting papers are
Page 2 | III. Informal Discovery Conferences
The Joint ADR Status Conference Statement must be filed at least five court days before the ADR Status Conference.
The ADR Status Conference Statement shall be filed and served at least five (5) court days before the ADR Status Conference and must contain the following:
Page 2 | II. Alternative Dispute Resolution Status Conferences
At least 80 copies of an approved pre-screening jury questionnaire must be lodged with the court on the first day of trial.
For pre-screening, at least 80 copies of the approved questionnaire shall be lodged with the court on the first day of trial.
Page 5 | V. Trial Rules and Procedures
A joint proposed jury questionnaire, including all written instructions to jurors, must be served and lodged with the judicial assistant by the trial-call date.
Thereafter, the requesting party shall serve and lodge with the judicial assistant a joint proposed jury questionnaire (including all written instructions to jurors) by the date of the trial call.
Page 5 | V. Trial Rules and Procedures
The parties' agreed-upon joint jury instructions and verdict forms must be lodged with the judicial assistant by the first day of trial.
A joint set of agreed-upon jury instructions and verdict forms shall be lodged with the judicial assistant no later than the first day of trial.
Page 5 | V. Trial Rules and Procedures
The printed presentation-slides hard copy must be provided to counsel and the clerk no later than 15 minutes before the presentation.
Any party showing a PowerPoint or similar presentation to the jury in opening statements or closing arguments shall provide a printed hard copy of the slides to counsel and the clerk not later than 15 minutes before the presentation.
Page 6 | V. Trial Rules and Procedures
The parties should establish a schedule for serving motions in limine and oppositions that allows briefing to be completed at least seven days before trial.
The parties should agree upon an acceptable schedule for the service of motions and oppositions, such that the parties can complete this briefing at least seven (7) days before trial.
Page 4 | V. Trial Rules and Procedures
Service and Proof of Service Rules
Litigants must comply with deadlines for serving summons of complaint and filing the resulting proofs of service.
• (a) comply with deadlines related to service of summons of complaints and filing proofs of service thereof,
Page 1 | I. Case Management
Litigants must timely serve their responses to complaints.
• (b) timely file and serve responses to complaints,
Page 1 | I. Case Management
The Joint ADR Status Conference Statement must be served at least five court days before the ADR Status Conference.
The ADR Status Conference Statement shall be filed and served at least five (5) court days before the ADR Status Conference and must contain the following:
Page 2 | II. Alternative Dispute Resolution Status Conferences
IDC requesting papers must include a simultaneous email copy to every other counsel or self-represented party.
To request an IDC, requesting papers with the subject line “REQUEST FOR IDC” must be emailed, with a simultaneous email copy to all other counsel/self-represented parties, to courtroom42@ventura.courts.ca.gov .
Page 2 | III. Informal Discovery Conferences
The master witness and exhibit lists must be emailed to the court three court days before trial.
The master witness and exhibit lists shall be emailed to courtroom42@ventura.courts.ca.gov three (3) court days before trial.
Page 4 | V. Trial Rules and Procedures
All motion in limine briefing must be emailed to the court three court days before trial.
All motion in limine briefing shall be emailed to courtroom42@ventura.courts.ca.gov three (3) court days prior to the date of the trial.
Page 4 | V. Trial Rules and Procedures
Trial briefs must be served on all parties three court days before trial.
Trial briefs shall be no more than five (5) pages and shall be served on all parties and emailed to courtroom42@ventura.courts.ca.gov three (3) court days before the trial.
Page 4 | V. Trial Rules and Procedures
Witness and exhibit lists should be exchanged at least 14 days before trial.
Witness and exhibit lists should be exchanged at least fourteen (14) days before trial.
Page 4 | V. Trial Rules and Procedures
Courtesy Copy Requirements
Counsel must maintain their own copies of the exhibit binders.
Counsel shall have their own copies.
Page 5 | V. Trial Rules and Procedures
One copy of each exhibit binder must be given to the judicial assistant on the first day of trial for marking and the judge's use.
On the first day of trial, one copy of any binder shall be provided to the judicial assistant for marking and for use by the judge.
Page 5 | V. Trial Rules and Procedures
One copy of the exhibit binder must be placed on the witness stand for testifying witnesses.
One copy shall be placed on the witness stand for use by testifying witnesses.
Page 5 | V. Trial Rules and Procedures
Pre-Motion Conference Requirements
A party may not file more than five motions in limine without leave of court.
No party shall bring more than five (5) motions in limine motions without leave of Court.
Page 4 | V. Trial Rules and Procedures
Parties must meet and confer about the necessity of motions in limine and are encouraged to stipulate to avoid them when possible.
The parties shall meet and confer on the necessity of any motions in limine and are encouraged to stipulate to the maximum extent possible to avoid the need for motions.
Page 4 | V. Trial Rules and Procedures
Motions seeking orders compelling compliance with existing law generally should not be filed.
Motions that seek orders compelling compliance with existing law should generally not be asserted.
Page 4 | V. Trial Rules and Procedures
Chambers Communication Rules
IDC responding papers must be emailed to Courtroom 42 at courtroom42@ventura.courts.ca.gov.
Responding papers must be emailed to courtroom42@ventura.courts.ca.gov not later than five (5) days after the requesting papers are
Page 2 | III. Informal Discovery Conferences
IDC requesting papers must be emailed to Courtroom 42 at courtroom42@ventura.courts.ca.gov.
To request an IDC, requesting papers with the subject line “REQUEST FOR IDC” must be emailed, with a simultaneous email copy to all other counsel/self-represented parties, to courtroom42@ventura.courts.ca.gov .
Page 2 | III. Informal Discovery Conferences