Court Rules
About United States District Judge Michael W. Fitzgerald

**Judge Michael W. Fitzgerald** was appointed to the Central District of California by President Barack Obama in 2012. Fitzgerald graduated magna cum laude from Harvard University and earned his law degree from the University of California, Berkeley School of Law (Boalt Hall), where he was elected to the Order of the Coif and served as Managing Editor of the Industrial Relations Law Journal. He clerked for Judge Irving R. Kaufman of the Second Circuit, served as an Assistant U.S. Attorney in the Criminal Division, and later became a named partner at Corbin, Fitzgerald & Athey LLP in Los Angeles. He also served as Deputy Chief Counsel to the Rampart Independent Review Panel examining LAPD practices. **Education** - University of California, Berkeley School of Law (Boalt Hall), J.D., 1985 - Harvard University, B.A., 1981 (magna cum laude) **Career** - Law clerk, Judge Irving R. Kaufman, U.S. Court of Appeals for the Second Circuit, 1985–1988 - Assistant U.S. Attorney, Criminal Division, Central District of California, 1988–1991 - Associate, Heller Ehrman White & McAuliffe LLP, Los Angeles, 1991–1995 - Attorney, Law Offices of Robert L. Corbin PC, Los Angeles, 1995–1998 - Named partner, Corbin, Fitzgerald & Athey LLP, Los Angeles, 1998–2012 - Deputy Chief Counsel, Rampart Independent Review Panel - U.S. District Judge, Central District of California, 2012–present

**Courthouse:** First Street U.S. Courthouse, 350 W. 1st Street, Los Angeles, CA 90012 **Division:** Western Division (Los Angeles) **Chambers Staff** - Chambers Email: MWF_Chambers@cacd.uscourts.gov

Common questions about Judge Michael W. Fitzgerald's rules

Are courtesy copies required for Judge Michael W. Fitzgerald?

Courtesy copies are required for all covered filings. Details: 1 copy, delivery upon filing. Counsel must provide Chambers with conformed copies of all filed documents.

View ruleSource: page 4, section C. LAW AND MOTION

Does Judge Michael W. Fitzgerald require a pre-motion conference or letter before filing a motion?

Judge Michael W. Fitzgerald's rules set a pre-motion procedure for discovery. Planned motions to compel discovery must be discussed with opposing counsel at least six weeks before the discovery cut-off date.

View ruleSource: page 3, section B. DISCOVERY AND DISCOVERY CUT-OFF

What page or word limits apply to motion in limine before Judge Michael W. Fitzgerald?

Judge Michael W. Fitzgerald's rule states these limits: 10 pages; 10 pages. Motions in limine and oppositions to such motions are limited to 10 pages.

View ruleSource: page 7, section C. LAW AND MOTION

What page or word limits apply to motions in limine before Judge Michael W. Fitzgerald?

Judge Michael W. Fitzgerald's rule states these limits: 10 pages. Each party limited to 5 motions in limine (10 pages each) unless leave granted.

What formatting rules apply to filings before Judge Michael W. Fitzgerald?

Judge Michael W. Fitzgerald's formatting rule includes binding three ring binder, without blue-backs, and stapled only in the top left corner. Pretrial document copies delivered to the court must be binder-ready (three-hole punched left, no blue-backs, stapled top left).

View ruleSource: page 5, section II. TRIAL PREPARATION A. PRETRIAL DOCUMENTS 1

What must be included with witness list filings before Judge Michael W. Fitzgerald?

The rule identifies required filing content or certificates. Witness lists must include a brief testimony description and separate time estimates for direct and cross-examination.

View ruleSource: page 6, section II. TRIAL PREPARATION A. PRETRIAL DOCUMENTS 4

What must be included with proposed findings conclusions filings before Judge Michael W. Fitzgerald?

The rule identifies required filing content or certificates. Marked copies of opposing party's proposed findings must strike through disputed portions, bold admitted portions, and underline admitted but irrelevant portions.

View ruleSource: page 7, section C. PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW

How may parties contact Judge Michael W. Fitzgerald's chambers?

Parties may contact Judge Michael W. Fitzgerald's chambers by email only as allowed by the rule. Parties must not communicate with judge without opposing counsel present.

View ruleSource: page 3, section Communications with Chambers

How do I request an adjournment or extension before Judge Michael W. Fitzgerald?

Judge Michael W. Fitzgerald's rules specify what an adjournment or extension request must include. The request must include reason for request, original date, and proposed new dates. Motions to add parties or amend pleadings must be noticed by the cut-off date.

Does Judge Michael W. Fitzgerald require motion papers to be bundled?

Yes. Judge Michael W. Fitzgerald requires bundling for covered papers. Exhibits must be placed in three-ring binders.

View ruleSource: page 9, section D. TRIAL EXHIBITS

Is electronic filing required before Judge Michael W. Fitzgerald?

Yes. Electronic filing is required for the covered filings. Unmarked proposed findings must be submitted to the Chambers email address in Word or WordPerfect format at the time of filing.

View ruleSource: page 8, section C. PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW

When is a filing treated as filed before Judge Michael W. Fitzgerald?

The rule addresses filing timing, filing status, or cure windows. Status Report Regarding Settlement must be filed 21 calendar days before the Final Pretrial Conference (FPTC).

View ruleSource: page 2, section DEADLINES
Complete rules summary for Judge Michael W. Fitzgerald

Chambers copies must not be placed in envelopes.

Status Report Regarding Settlement must be filed 21 calendar days before the Final Pretrial Conference (FPTC).

Memoranda of Contentions of Fact and Law must be filed 21 calendar days before the Final Pretrial Conference (FPTC).

Witness and Joint Exhibit Lists must be filed 21 calendar days before the Final Pretrial Conference (FPTC).

Motions in Limine must be filed 21 calendar days before the Final Pretrial Conference (FPTC).

Pretrial Conference Order must be lodged 14 calendar days before the Final Pretrial Conference (FPTC).

Findings of Fact and Conclusions of Law must be lodged 21 calendar days before trial.

Summaries of Direct Testimony must be filed 21 calendar days before trial.

Trial briefs are optional and must be filed 7 calendar days before trial if submitted.

Oppositions to Proposed Findings of Fact and Conclusions of Law must be filed 7 calendar days before trial.

Motions to add parties or amend pleadings must be heard by the established cut-off date; unserved parties are dismissed at pretrial conference per Local Rule 16-8.1.

All discovery (including expert discovery) and related motion hearings must be completed by the established cut-off date, which is not the discovery request service date.

Motions challenging discovery response adequacy must be filed, served, and calendared early enough to obtain responses before discovery cut-off if granted.

Depositions must start early enough to complete and allow filing of related discovery motions before the discovery cut-off date.

Planned motions to compel discovery must be discussed with opposing counsel at least six weeks before the discovery cut-off date.

Requests for admissions and related documents must be served early enough to allow motion practice on deficient responses before discovery cut-off.

All expert disclosures must be made in writing.

Final pretrial conference and trial dates will not be continued solely due to incomplete expert discovery.

All motions must be noticed for hearing on or before the motion cut-off date; counsel should file early to secure a hearing date.

Pretrial document copies delivered to the court must be binder-ready (three-hole punched left, no blue-backs, stapled top left).

Proposed final pretrial conference order format must conform to Appendix A of the Local Rules.

Memoranda of contentions of fact and law, witness lists, joint exhibit list, and motions in limine must be filed at least 21 days before the final pretrial conference.

Proposed final pretrial conference order, statement of the case, and oppositions to motions in limine must be filed at least 14 days before the final pretrial conference.

Proposed findings of fact and contentions of law (if required) and direct testimony summaries must be filed at least 21 days before trial.

Trial briefs (if desired) and opposing parties’ proposed findings of fact and conclusions of law must be filed at least 7 days before trial.

Witness lists must include a brief testimony description and separate time estimates for direct and cross-examination.

Motions in limine and oppositions to such motions are limited to 10 pages.

Motions in limine must be filed at least 3 weeks prior to the final pretrial conference.

Oppositions to motions in limine must be filed at least 2 weeks prior to the final pretrial conference.

Reply briefs to motions in limine are prohibited.

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