Judge Cynthia Valenzuela
Limits & Logistics
Document Limits
Courtesy Copies
Filings
Not Required
Filings (Plea Agreement)
Required
Filings (Motion)
Required
Filings (All filings)
Required • Binding: Stapled
Adjournments
Must Include
- 1Foundation Stipulations
- 2Waiver Of Best Evidence Rule
- 3Exhibits That May Be Received Into Evidence At Start Of Trial
Must Include
- 1Reason For Request
- 2Detailed Declaration
- 3Number Of Previous Requests
- 4Previous Requests Granted Or Denied
- 5Good Cause
- 6Due Diligence
- 7Litigation Efforts Since Filing
- 8Work Could Not Be Accomplished Within Deadlines
- 9Joint Request Agreement
- 10Conflicting Case Details
- 11Case Name
- 12Case Number
- 13Court
- 14Judge
- 15Case Age
- 16Case Nature Complexity
- 17Conflicting Trial Date
- 18Estimated Trial Length
- 19Previous Continuances
Must Include
- 1Reason For Request
- 2Original Date
- 3Proposed New Dates
Communication
Chambers
Letter Ecf
Clerk
Chambers
Letter Ecf
Chambers
In Person
Jurors
Other
Chambers
Phone
Chambers
Phone
Chambers
Chambers
Detailed Drafting Rules
Motions in limine and oppositions limited to 2,800 words or 10 pages.
Motions in limine and oppositions must not exceed 2,800 words in length, or ten (10) pages for handwritten briefs and briefs prepared using a typewriter.
Objections must be noted in margins with grounds and responses.
Identify any objections to the proffered evidence in the margins of the deposition by briefly providing the ground for the objection and the response to the objection.
[Object Object]
Counsel must not approach clerk, jury box, or witness stand without authorization.
Counsel must not approach the Courtroom Deputy Clerk, the jury box, or the witness stand without Court authorization and must return to the lectern
Direct to: Chambers
Parties must bracket designated testimony in margins of original transcript.
Identify on the original transcript the testimony the party intends to offer by bracketing the questions and answers in the margins. The opposing party shall likewise counter-designate any testimony it plans to offer.
[Object Object]
For further questions, place deposition before witness for silent reading; provide extra copies.
If counsel wish to ask the witness further questions on the subject matter, the deposition shall be placed in front of the witness and the witness told to read the relevant pages and lines silently. Counsel may then either ask the witness further questions on the matter and thereafter read the quotations or read the quotations and thereafter ask further questions. Counsel should have available for the Court and the witness extra copies of the deposition transcript for this purpose.
Document Type
Deposition Further Questions
Immediate notification to Courtroom Deputy Clerk for unexpected legal issues.
The parties must notify the Courtroom Deputy Clerk immediately of any unexpected legal issue that could not have been foreseen and addressed in advance.
Letter via ECF
Direct to: Clerk
- Advance Notice Required
- Hours
- Status Inquiries
Inform Courtroom Deputy Clerk before excusing jurors for unexpected issues.
To the extent such issue needs to be addressed outside the jury’s presence, the relevant party must inform the Courtroom Deputy Clerk before jurors are excused for the day to minimize the time jurors are kept waiting.
Letter via ECF
Direct to: Clerk
- Advance Notice Requiredbefore jurors excused
- Hours
- Status Inquiries
Calendar conflicts must be reported to opposing counsel and CRD via email
If any counsel discovers a calendar conflict with a scheduled appearance, counsel must inform opposing counsel and the Court’s courtroom deputy (CRD) via Chambers email at CV_Chambers@cacd.uscourts.gov.
Direct to: Chambers
- Status Inquiries
Discovery documents must include “DISCOVERY MATTER” in caption
All discovery-related documents must include the words “DISCOVERY MATTER” in the caption to ensure proper routing.
Document Type
Discovery Document
Motions heard on Fridays at 1:30 PM
The Court hears motions in civil actions on Fridays, beginning at 1:30 p.m.
Direct to: Chambers
Motions memoranda limited to 25 pages; replies limited to 15 pages.
Unless otherwise stated by the Court, memoranda of points and authorities in support of or in opposition to motions shall not exceed twenty-five (25) pages. Replies shall not exceed fifteen (15) pages.
Times New Roman 14pt or Courier 12pt required; footnotes same size as body text.
Pursuant to Local Rule 11-3.1.1, either a proportionally spaced or monospaced face may be used. Typeface shall comply with Local Rule 11-3.1.1. Times New Roman font must be no less than 14 point; Courier font must be no less than 12 point. Footnotes shall be in the same font and the same size as the body of the memorandum.
All documents must be converted to searchable PDF format with selectable text.
Counsel shall adhere to Local Rule 5-4.3 with respect to the conversion of all documents to .pdf format so that when a document is electronically filed, it is in proper size and is .pdf searchable. Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document.
Bluebook style required; case citations must include specific page numbers.
Bluebook style is required. Citations to case law must identify not only the case cited, but the specific page referenced. For example, if a quotation is presented, the associated page citation shall be provided. Similarly, if a case is cited in support of a proposition based on language in the opinion, the page on which such language appears shall be provided.
Bluebook style required; statutory citations must specify sections/subsections; other sources need volume, section, and pages.
Bluebook style is required. Statutory references must identify with specificity the sections and subsections referenced. Citations to treatises, manuals, and other materials should include the volume, section, and pages being referenced.
Chambers copies delivered to specific box, must comply with Local Rule 11-3, labeled MANDATORY CHAMBERS COPY.
Chambers copies shall be delivered to Judge Valenzuela’s “Mandatory Chambers Copies” box, located on the fourth floor of the United States District Courthouse, 350 W 1st Street, Los Angeles, CA 90012. A mandatory chambers copy must comply with Local Rule 11-3 (i.e., font size, page numbering, exhibit tabbing, etc.) but need not be blue-backed. The mandatory chambers copy must be prominently labeled MANDATORY CHAMBERS COPY on the face page.
Courtesy Copies Required
Logistics
Appearance
Lead counsel must appear for scheduling, settlement, and final pretrial conferences.
The Court requires lead counsel to appear for scheduling conferences, settlement conferences, and the Final Pretrial Conference.
In Person
Direct to: Chambers
In-person attendance required for all hearings and trials unless court instructs otherwise.
The Court requires in-person attendance for all hearings and trials, unless otherwise instructed by the Court.
In Person
Direct to: Chambers
Telephone/video conference permitted for status conferences with showing of undue hardship.
The Court may permit appearances by telephone or video conference for status conferences upon a showing that a personal appearance will cause undue hardship.
Phone
Direct to: Chambers
Requirements for telephone/video conference appearance: email 3 days in advance with hardship statement, use landline/hardline connection, be ready 15 minutes early.
If you wish to appear by telephone or video conference, you must: 1. email the Courtroom Deputy Clerk and copy opposing counsel at least three (3) court days in advance of the scheduled appearance and provide a detailed statement of undue hardship; 2. use a landline to call into the bridge line provided by the Courtroom Deputy Clerk or use a hardline internet connection to connect to the Zoom link for the Court; and 3. be available and ready to call in for at least fifteen (15) minutes before the time of the scheduled hearing.
Phone
Direct to: Chambers
- Advance Notice Requiredthree (3) court days
- Hoursat least three (3) court days in advance
Ex parte applications considered on papers, not usually set for hearing.
The Court considers ex parte applications on the papers and does not usually set these matters for hearing.
Letter via ECF
Direct to: Chambers
Sanctions may be imposed for misuse of ex parte applications.
Letter via ECF
Direct to: Chambers
Ex parte applications must conform to Local Rules 7-19 and 7-19.1 or will not be considered without good cause.
Ex parte applications that fail to conform to Local Rules 7-19 and 7-19.1, including a statement of opposing counsel’s position, will not be considered except upon a specific showing of good cause.
Letter via ECF
Direct to: Chambers
Opposing party must be served electronically if possible.
The applicant shall serve the opposing party electronically, if possible.
Letter via ECF
Direct to: Chambers
Counsel prohibited from contacting chambers by email, phone, or ex parte.
Counsel must not attempt to contact the Court or chambers staff by email, telephone, or ex parte means.
Direct to: Chambers
- Status Inquiries
Contact Courtroom Deputy Clerk via email or phone for appropriate matters only.
For appropriate matters only, counsel may contact the Courtroom Deputy Clerk via chambers email address at CV_@cacd.uscourts.gov, or by telephone at (213) 894-0239.
Direct to: Chambers
- Status Inquiries
Prohibited from contacting chambers about case status.
Counsel must not contact the Courtroom Deputy Clerk regarding the status of any matter before the Court.
Direct to: Chambers
- Status Inquiries