Central District of California Document Filing Requirements

Plaintiff must promptly serve the complaint and file proof of service.

Source text: Plaintiff shall promptly serve the complaint in accordance with Fed. R. Civ. P. 4 and file the proofs of service pursuant to Local Rule 5-3.1.

Discovery-related documents must include “DISCOVERY MATTER” in the caption.

Source text: All discovery-related documents must include the words “DISCOVERY MATTER” in the caption to ensure proper routing.

Motions to amend must explain the amendment’s effect and specify page/line and wording of each proposed change or addition.

Source text: In addition to the requirements of Local Rule 15-1, all motions to amend pleadings shall: (1) state the effect of the amendment and (2) identify the page and line number(s) and wording of any proposed change or addition of material.

Counsel must e-file a Notice of Lodging and attach the proposed amended pleading as a separate document from the motion.

Source text: Counsel shall electronically file a “Notice of Lodging,” attaching the proposed amended pleading as a document separate from the motion,

Moving papers must include an appendix with a redlined proposed amended pleading showing all additions and deletions.

Source text: and shall attach as an appendix to the moving papers a “redlined” version of the proposed amended pleading indicating all additions and deletions of material.

In the separate statement, the left column must contain each allegedly undisputed fact and the right column must cite supporting evidence.

Source text: The left-hand column sets forth the allegedly undisputed fact. The right-hand column sets forth the evidence that supports the factual statement.

In the opposing statement, the left column must restate each asserted fact and the right column must mark it as undisputed or disputed.

Source text: The left- hand column must restate the allegedly undisputed fact, and the right hand column must state either that it is undisputed or disputed.

If disputing only part of a fact statement, the opposing party must identify the disputed part and provide a brief citation to controverting evidence.

Source text: The opposing party may dispute all or only a portion of the statement, but if disputing only a portion, it must clearly indicate what part is being disputed, followed by a brief citation to the opposing party’s evidence controverting the fact.

To show a factual dispute, the opposing party must explain why, cite relevant evidence, and describe how that evidence refutes the asserted fact.

Source text: To demonstrate that a fact is disputed, the opposing party must briefly state why it disputes the moving party’s asserted fact, cite to the relevant exhibit or other piece of evidence, and describe what it is in that exhibit or evidence that refutes the asserted fact.

A moving party must file a reply response that restates each fact and indicates whether it is disputed, with no further response needed for undisputed facts.

Source text: With its Reply, the moving party shall file a Response to the Statement of Genuine Disputes of Material Fact and Additional Material Facts. For each fact, the Response shall restate the allegedly undisputed fact and state whether the fact is disputed or undisputed by the opposing party. If the fact is undisputed, no further response is required.

The response must include all asserted facts and cited evidence, and parties must not repeat evidence descriptions or citations already provided.

Source text: All facts asserted by either party, whether disputed or undisputed, and all supporting evidence cited, shall be included in the Response. DO NOT REPEAT DESCRIPTIONS OF AND CITATIONS TO THE EVIDENCE. If you have already described and cited the evidence once, simply refer to the earlier citation succinctly (e.g., See supra, Fact # 1).

Any party filing or opposing a motion must serve and electronically lodge a proposed order stating requested relief and a brief cited rationale.

Source text: Each party filing or opposing a motion or seeking the determination of any matter shall serve and electronically lodge a proposed order setting forth the relief or action sought and a brief statement of the rationale for the decision with appropriate citations.

Ex parte applications must comply with Local Rules 7-19/7-19.1 and include opposing counsel’s position unless specific good cause is shown.

Source text: Ex parte applications that fail to conform to Local Rule 7-19 and 7-19.1, including a statement of opposing counsel’s position, will not be considered except on a specific showing of good cause.

Continuance/extension requests must be filed by stipulation and include a proposed order with a detailed declaration of grounds.

Source text: Counsel requesting a continuance or extension of time must electronically file a stipulation and lodge a proposed order including a detailed declaration of the grounds for the requested continuance or extension of time.

Joint jury instructions and verdict form must be submitted.

Source text: The parties must submit JOINT jury instructions and a JOINT proposed verdict form.

Chambers copies and proposed orders are mandatory for sealed documents.

Source text: Mandatory Chambers Copies & Proposed Orders

Plaintiff's counsel must serve this order on all parties; if removed, removing defendant must serve.

Source text: COUNSEL FOR PLAINTIFFS SHALL SERVE THIS ORDER IMMEDIATELY ON ALL PARTIES AND/OR THEIR COUNSEL, INCLUDING ANY NEW PARTIES TO THE ACTION. IF THIS CASE WAS REMOVED FROM STATE COURT, DEFENDANT WHO REMOVED THE CASE SHALL SERVE THIS ORDER ON ALL OTHER PARTIES.

Plaintiff must serve complaint under FRCP 4 and file proof of service; unserved defendants dismissed without prejudice.

Source text: Plaintiff shall promptly serve the complaint in accordance with Fed. R. Civ. P. 4 and file the proofs of service pursuant to Local Rule 5-3.1. Any defendant not timely served under Fed. R. Civ. P. 4(m) shall be dismissed from the action without prejudice.

All discovery matters referred to Magistrate Judge; include 'DISCOVERY MATTER' in caption.

Source text: All discovery matters have been referred to the assigned United States Magistrate Judge, who will hear all discovery disputes. The Magistrate Judge's initials follow the District Judge's initials next to the case number. All discovery-related documents must include the words 'DISCOVERY MATTER' in the caption to ensure proper routing.

Motions to amend must state effect, identify changes by page/line, and be serially numbered.

Source text: In addition to the requirements of Local Rule 15-1, all motions to amend pleadings shall: (1) state the effect of the amendment and (2) identify the page and line number(s) and wording of any proposed change or addition of material. The proposed amended pleading shall be serially numbered to differentiate it from previously amended pleadings.

Notice of Lodging required with proposed amended pleading and redlined version as appendix.

Source text: Counsel shall electronically file a “Notice of Lodging,” attaching the proposed amended pleading as a document separate from the motion, and shall attach as an appendix to the moving papers a “redlined” version of the proposed amended pleading indicating all additions and deletions of material.

Summary judgment motions can be filed anytime before final pretrial conference; one per side allowed.

Source text: Parties need not wait until the motion cutoff to bring motions for summary judgment or partial summary judgment. The hearing on any such motion shall be set for a date in advance of the Final Pretrial Conference. Each side may bring one motion for summary judgment or partial summary judgment.

To dispute a fact, must state reason, cite evidence, and describe how evidence refutes the fact.

Source text: To demonstrate that a fact is disputed, the opposing party must briefly state why it disputes the moving party’s asserted fact, cite to the relevant exhibit or other piece of evidence, and describe what it is in that exhibit or evidence that refutes the asserted fact.

Proposed order required for all motions, emailed to chambers in Word/WordPerfect format on filing day.

Source text: Each party filing or opposing a motion or seeking the determination of any matter shall serve and electronically lodge a proposed order setting forth the relief or action sought and a brief statement of the rationale for the decision with appropriate citations. In addition, a copy of the Proposed Order in Word or WordPerfect format shall be emailed to Judge Gee's generic chambers e-mail address using the CM/ECF System on the day the document is e-filed.

Ex parte applications must conform to Local Rules 7-19 and 7-19.1 or will not be considered

Source text: Ex parte applications that fail to conform to Local Rule 7-19 and 7-19.1, including a statement of opposing counsel's position, will not be considered except on a specific showing of good cause.

Ex parte applications must be electronically served if possible; service complete upon e-filing

Source text: The moving party shall electronically serve the opposing party, if possible. A party is considered served once the ex parte application has been e-filed (all parties set up for electronic service are sent a notification of ECF filing each time a document is e-filed with a link to the document).

Opposing papers must be e-filed within 24 hours of ex parte service

Source text: Following service of the ex parte papers by electronic service, fax, or personal service, the moving party shall notify the opposition that opposing papers must be e-filed no later than twenty-four (24) hours following service.

Counsel must meet 21 days before scheduling conference and submit joint report 14 days before.

Source text: Counsel shall meet at least twenty-one (21) days in advance of the Scheduling Conference to prepare a jointly signed report for the court to be submitted no less than fourteen (14) days before the Scheduling Conference.

Joint report must include items from Fed. R. Civ. P. 26(f), 16(b)(1)-(6), and 16(c).

Source text: The joint report to be submitted shall contain the items listed in Fed. R. Civ. P. 26(f), the parties’ recommendations and agreements, if any, about the final scheduling order as listed in Fed. R. Civ. P. 16(b)(1) through (6), and those items listed in Fed. R. Civ. P. 16(c) which counsel believe will be useful to discuss at the Scheduling Conference.

Joint report must address discovery plan, motion schedule, settlement efforts, and trial timing.

Source text: Items which must be addressed are the following: (1) initial disclosures, preservation of discoverable information, and a discovery plan, including a listing and proposed schedule of written discovery, depositions, and a proposed discovery cut-off date; (2) a listing and proposed schedule of law and motion matters, and a proposed dispositive motion cut-off date; (3) a statement of what efforts have been made to settle or resolve the case to date and what settlement procedure is recommended pursuant to Local Rule 16-15.4 (specifically excluding any statement of the terms discussed); (4) an estimated length of trial and a proposed date for the final pretrial conference and for trial;

Joint Scheduling Report must comply with Fed. R. Civ. P. 16, 26(f), and this Order; non-compliance may result in continuance and sanctions.

Source text: The report to the Court as to the above items should be preceded by a thorough and frank discussion among the attorneys for the parties. A Joint Scheduling Report which does not comply with Fed. R. Civ. P. 16, 26(f), and this Order may cause continuance of the Scheduling Conference and a possible award of sanctions under Rule 16(f) against the party or parties responsible.

Plaintiff's counsel must immediately serve this Order on all parties, including new parties.

Source text: Counsel for plaintiff shall immediately serve this Order on all parties, including any new parties to the action.

Disputed jury instructions must be submitted at least one week before trial.

Source text: Where the parties cannot agree, disputed instructions shall be submitted at least one week before trial as follows: (1) JOINT jury instructions (those instructions agreed to by all parties), and (2) DISPUTED jury instructions (those instructions propounded by a party to which another party objects).

Opposing party must state basis for objection to disputed instructions.

Source text: On a separate page following each disputed jury instruction, the party opposing the instruction shall briefly state the basis for the objection, any authority in support thereof and, if applicable, an alternative instruction.

Proposing party must respond to objections with supporting authority.

Source text: On the following page, the party proposing the disputed instruction shall briefly state its response to the objection, and any authority in support of the instruction.

Each jury instruction must be numbered and cited on separate page.

Source text: Each requested jury instruction shall be numbered and set forth in full on a separate page, citing the authority or source of the requested instruction.

Index page required for jury instructions with specific details.

Source text: An index page shall accompany all jury instructions submitted to the Court. The index page shall indicate the following: a. The number of the instruction; b. A brief title of the instruction; c. The source of the instruction; and d. The page number of the instruction.

Documents filed under seal must be linked to the court order granting permission.

Source text: Any document filed under seal must also be linked to the court order granting permission to so file. See L.R. 79-5.2.2 (c) (eff. 12/1/15).

Protective order declarations must use "Sealed Declaration in Support" event.

Source text: Note that, if you are the party that has designated a document confidential pursuant to a protective order, L.R. 79-5.2.2(b)(i) requires you to file a Declaration explaining why the documents should be filed under seal. You should use the "Sealed Declaration in Support" event to file this declaration.

Application for Leave to File Under Seal must include declaration, proposed order, redacted and unredacted documents.

Source text: Your Application must be accompanied by: (1) a declaration; (2) a proposed order; (3) a redacted version of any documents of which only a portion is proposed to be filed under seal; and (4) an unredacted version of the documents proposed to be filed under seal. L.R. 79-5.2.2(a)-(b) (eff. 12/1/15).

Proposed orders must be emailed to chambers; sealed documents require sealed envelopes with title page.

Source text: A Word Perfect or Microsoft Word version of the proposed order must be emailed to chambers as required by L.R. 5-4.4.2, and mandatory chambers copies of e-filed sealed documents must be provided to chambers pursuant to L.R. 5-4.5, just as with any e-filed documents. However, mandatory chambers copies must be provided in sealed envelopes, with a copy of the title page attached to the front of each envelope. L.R. 79-5.2.2(a).

Application for Leave to File Under Seal requires declaration, proposed order, redacted and unredacted documents.

Source text: Local Rule 79-5.2.2 requires that certain documents be filed with the Application: (1) a declaration; (2) a proposed order; (3) a redacted version of any documents of which only a portion is proposed to be filed under seal; and (4) an unredacted version of any documents proposed to be filed under seal.

Document caption must be entered in a free text field and must not contain confidential information.

Source text: On the next screen, enter the document caption in the free text field. Remember that this text will be publicly visible, so do not include confidential information here. Click “Next.”

Complaints must list all causes of action on face-page in numbered list.

Source text: The face-page of the Complaint must state the title of all of its causes of action in a numbered list below the case number. If the initial Complaint lacks this list, it need not be re-filed, but amended Complaints must include this list.

Lead counsel must appear for scheduling and final pretrial conferences.

Source text: The Court requires lead counsel to appear for scheduling conferences and the Final Pretrial Conference.

Proposed orders required with any motion, must follow template format and specific formatting rules.

Source text: A party seeking any court order on any matter must include with their filing a Proposed Order setting forth the relief or action sought and a brief statement of the rationale for the decision with appropriate citations. See Local Rules 7-20, 52-4.1. A Proposed Order template is available on Judge Birotte’s webpage. Proposed Orders should substantially comply with the template’s format. Proposed Orders must be on pleading paper and must not include attorney information on the caption page, a footer, a watermark, or any text after the lines for the Judge’s signature on the last page.

Motion must include prominent statement of compliance with Local Rule 7-3.

Source text: A Notice of Motion must include a statement of compliance with Local Rule 7-3. The statement of compliance must be prominent, as the Court will not search a filing for the statement.

Evidence must be marked with brackets to identify cited portions.

Source text: Marking Evidence: Parties must mark evidence they file in connection with any motion or other proceeding so that the Court can readily identify the portion the party wants the Court to consider. For example, use brackets in the margins of transcripts to denote the cited portions.

Motions to amend must comply with Local Rule 15-1 and include specific requirements.

Source text: Motions to amend pleadings must comply with Local Rule 15-1, and must:(1) state the effect of the proposed amendment; (2) be serially numbered to differentiate the amendment from previous amendments; (3) state the page and line number(s) and wording of any proposed change or addition of material; and (4) include as an attachment a redlined version of the proposed amended pleading indicating all additions and deletions of material.

Motions for default judgment must include evidence and proposed order addressing specific requirements.

Source text: Motions for default judgment under Fed. R. Civ. P. 55(b) must be supported by evidence and must be accompanied by a full proposed Order addressing the procedural requirements of Local Rule 55-1 and the factors set forth in Eitel v. McCool, 782 F.2d 1470, 1471-72 (9th Cir. 1986). Motions omitting any of these will be denied.

Summary judgment motions must comply with Local Rule 56.

Source text: Summary Judgment/Rule 56 Motions must comply with Local Rule 56, which was substantially revised on June 1, 2023.

No party may file more than one Rule 56 motion without leave of court.

Source text: No party may, without leave of Court, file more than one motion under Fed. R. Civ. P. 56, regardless of whether such motion is denominated a motion for...

Ex parte applications must be served by email, fax, or personal service in addition to Local Rule 5-3.

Source text: Service must be made in compliance with Local Rule 5-3, and the moving party must also serve the nonmoving party by email, fax, or personal service.

Rule 56 motions require Statement of Uncontroverted Facts, Statement of Genuine Disputes, and Response to Statement of Genuine Disputes, all complying with Local Rule 56 format.

Source text: Local Rule 56 was substantially revised on June 1, 2023 to require as follows: A party moving under Fed. R. Civ. P. 56 must file with the motion a Statement of Uncontroverted Facts, the opposing party must file a Statement of Genuine Disputes, and the moving party must file a Response to Statement of Genuine Disputes. The parties MUST file these documents, and the documents MUST comply with the format set forth in Local Rule 56. The Court may disregard non-compliant filings.

Only file specific evidence with brackets marking relevant portions; unmarked transcripts will be disregarded.

Source text: A party must file only the specific evidence necessary to support or controvert a proposed undisputed fact. Counsel must use brackets to mark the relevant portions of transcripts. The Court will disregard unmarked transcripts.

Evidence must be filed by stipulation or as exhibits to declarations, not attached to the memorandum.

Source text: Evidence must be filed either by stipulation or as exhibits to declarations sufficient to authenticate the proffered evidence, and must not be attached to the memorandum.

Blanket or boilerplate objections to opponent's evidence will be disregarded.

Source text: Do not submit blanket or boilerplate objections to an opponent’s evidence. They will be disregarded.

Ex parte applications must conform to Local Rules 7-19 and 7-19.1 or will not be considered.

Source text: Applications that do not conform with Local Rules 7-19 and 7-19.1, such as by omitting a statement of opposing counsel’s position, will not be considered.

Reply papers for ex parte applications are not permitted without leave of Court.

Source text: Absent leave of Court, the Court will not consider reply papers in support of an ex parte application.

Preliminary or emergency injunctive relief must comply with Fed. R. Civ. P. 65 and Local Rule 65.

Source text: Parties seeking preliminary or emergency injunctive relief must comply with Fed. R. Civ. P. 65 and Local Rule 65.

Court will not hear summary judgment motions in ERISA cases without an agreed statement of facts.

Source text: Absent an agreed upon statement of facts, the court will not hear motions for summary judgment.

Bankruptcy appeals must comply with the Notice Regarding Appeal from Bankruptcy Court.

Source text: Counsel must comply with the Notice Regarding Appeal from Bankruptcy Court issued at the time the appeal is filed in the District Court.

Counsel must include contact info on all papers

Source text: Counsel must include on all papers their email address, telephone number, and fax number to facilitate communication with the CRD.

Must use Court-provided templates for specified filings

Source text: The Court's Standing Order, Order Setting Scheduling Conference, Schedule of Pretrial and Trial Dates Worksheet, Order Re: Jury/Court Trial, and templates for Proposed Orders and the Proposed Final Pretrial Conference Order and certain trial filings are available on Judge Birotte's webpage. If the Court has provided a template for any filing, the parties must follow it.

Order must be served on all parties by plaintiff or removing defendant

Source text: Counsel for plaintiff (or plaintiff, if appearing pro se) must immediately serve this Order on all parties, including any new parties to the action. If this case was removed to this Court from state court, the removing defendant(s) must serve this Order on all other parties.

All filings must include counsel's contact information.

Source text: Counsel must include on all papers their email address, telephone number, and fax number to facilitate communication with the CRD.

Proposed orders required with any court order request, must follow template format and specific formatting rules.

Source text: A party seeking any court order on any matter must include with their filing a Proposed Order setting forth the relief or action sought and a brief statement of the rationale for the decision with appropriate citations. See Local Rules 7-20, 52-4.1. A Proposed Order template is available on Judge Birotte’s webpage. Proposed Orders should substantially comply with the template’s format. Proposed Orders must be on pleading paper and must not include attorney information on the caption page, a footer, a watermark, or any text after the lines for the Judge’s signature on the last page.

Motions to amend must comply with Local Rule 15-1 and include specific requirements.

Source text: All motions to amend pleadings must comply with Local Rule 15-1, and must:(1) state the effect of the proposed amendment; (2) be serially numbered to differentiate the amendment from previous amendments; (3) state the page and line number(s) and wording of any proposed change or addition of material; and (4) include as an attachment a redlined version of the proposed amended pleading indicating all additions and deletions of material.

Motions for default judgment must include evidence and a full proposed order addressing Local Rule 55-1 and Eitel factors.

Source text: Motions for default judgment under Fed. R. Civ. P. 55(b) must be supported by evidence and must be accompanied by a full proposed Order addressing the procedural requirements of Local Rule 55-1 and the factors set forth in Eitel v. McCool, 782 F.2d 1470, 1471-72 (9th Cir. 1986). Motions omitting any of these will be denied.

Summary judgment motions must comply with Local Rule 56 (revised June 1, 2023).

Source text: Summary Judgment/Rule 56 Motions must comply with Local Rule 56, which was substantially revised on June 1, 2023.

Local Rule 56 requires Statement of Uncontroverted Facts, Statement of Genuine Disputes, and Response to Statement of Genuine Disputes for summary judgment motions.

Source text: Local Rule 56 was substantially revised on June 1, 2023 to require as follows: A party moving under Fed. R. Civ. P. 56 must file with the motion a Statement of Uncontroverted Facts, the opposing party must file a Statement of Genuine Disputes, and the moving party must file a Response to Statement of Genuine Disputes. The parties MUST file these documents, and the documents MUST comply with the format set forth in Local Rule 56. The Court may disregard non-compliant filings.

Proposed FPTCO must be emailed to chambers as Microsoft Word file.

Source text: The parties must email a Microsoft Word file of the Proposed FPTCO to chambers at AB_Chambers@cacd.uscourts.gov .

Most pretrial documents must be emailed as Microsoft Word files to chambers.

Source text: Except for motions in limine, oppositions, the Joint Status Report Regarding Settlement, and Declarations containing direct testimony, Counsel must email Microsoft Word files of all of the below pretrial documents, including any amended documents, to chambers at AB_Chambers@cacd.uscourts.gov .

Pretrial documents have specific filing deadlines.

Source text: The schedule for filing pretrial documents is as follows:

Requested jury instructions must cite source, be complete, on separate pages, numbered, cover one subject, and not repeat other instructions.

Source text: Format: Each requested instruction must (1) cite the authority or source of the instruction, (2) be set forth in full, (3) be on a separate page, (4) be numbered, (5) cover only one subject or principle of law, and (6) not repeat principles of law contained in any other requested instruction. If a standard instruction has blanks or offers options (i.e. “he/she”), the parties must fill in the blanks or make the appropriate selections in their proposed instructions so that the proposed instruction is ready to use as-is.

Proposed jury instructions must include an index with instruction number, title, source, and page number.

Source text: Index: The Proposed Instructions must have an index that includes the following for each instruction, as illustrated in the example below:  the number of the instruction;  the title of the instruction;  the source of the instruction and any relevant case citations; and  the page number of the instruction.

Joint Proposed Verdict Form due 14 days before FPTC; if parties disagree, file Competing Proposed Verdict Forms with redlines and legal basis.

Source text: The parties must file a Joint Proposed Verdict Form no later than 2 weeks (14 days) before the FPTC. The parties must make every attempt to agree upon a verdict form. If the parties are unable to agree on a verdict form, the parties must file one document titled “Competing Proposed Verdict Forms” which must include: (i) the parties’ respective proposed verdict form; (ii) a “redline” of any disputed language; and (iii) the factual or legal basis for each party’s respective position.

Joint Proposed Statement of the Case due 14 days before FPTC; must be brief neutral statement, no more than one page.

Source text: The parties must file a Joint Proposed Statement of the Case by 2 weeks (14 days) before the FPTC. This is the statement the Court will read to the panel of prospective jurors before commencement of voir dire. This should be a brief neutral statement, no more than one page long.

Stipulation of factual basis for open plea due 7 days before hearing.

Source text: If the parties agree to proceed with an open plea, counsel shall confer and file a stipulation as to the factual basis no later than seven days prior to the hearing.

Audio/visual equipment requests must be made to CRD by 4:00 PM Wednesday before trial

Source text: counsel shall notify the CRD no later than 4:00 p.m. on the Wednesday before trial so that the necessary arrangements can be made.

Trial counsel must meet and confer in person 40 days before FPTC

Source text: trial counsel for each party are required to meet and confer in person forty (40) days in advance to prepare for the FPTC.

Pretrial documents due 28 days before FPTC

Source text: At least twenty-eight (28) days before the FPTC:

Oppositions to Motions in Limine due 14 days before FPTC

Source text: At least fourteen (14) days before the FPTC:

Joint Witness List due 28 days before FPTC with specific format and content

Source text: The Joint Witness List must be filed at least twenty-eight (28) days before the FPTC. It must be in the format specified in Local Rule 16-5 and must include for each witness (i) a brief description of the testimony, (ii) the reasons the testimony is unique and not redundant, and (iii) a time estimate in hours for direct and cross-examination.

Amended Witness List due noon Friday before trial in Word format

Source text: Any Amended Witness List must be filed by 12:00 p.m. (noon) on the Friday before trial and emailed to AH_Chambers@cacd.uscourts.gov in Microsoft Word format.

Joint Exhibit List due 28 days before FPTC with objections column

Source text: The Joint Exhibit List must be filed at least twenty-eight (28) days before the FPTC. It must be in the format specified in Local Rule 16-6 and shall include an additional column stating any objections to authenticity and/or admissibility and the reasons for the objections.

Amended Joint Exhibit List must be filed by noon Friday before trial in Word format via email.

Source text: The parties shall meet and confer to fully discuss any objections and attempt to reach agreements on exhibits. Any Amended Joint Exhibit List must be filed by 12:00 p.m. (noon) on the Friday before trial and emailed to AH_Chambers@cacd.uscourts.gov in Microsoft Word format.

Joint proposed jury instructions must be filed 14 days before FPTC.

Source text: Joint agreed upon proposed jury instructions must be filed no later than fourteen (14) days prior to the FPTC.

Parties must file clean and redlined versions of jury instructions with modifications and legal basis for disputes.

Source text: The parties shall file clean and redlined sets of their (i) Joint Agreed Upon Proposed Jury Instructions and (ii) Disputed Jury Instructions. The redlined sets shall include all modifications made by the parties to pattern or model jury instructions, any disputed language, and the factual or legal basis for each party's position as to each disputed instruction.

Proposed jury instructions must include an index with instruction number, title, source/citations, and page number.

Source text: The Proposed Instructions must have an index that includes the following for each instruction, as illustrated in the example below: (1) the number of the instruction; (2) the title of the instruction; (3) the source of the instruction and any relevant case citations; and (4) the page number of the instruction.

Proposed joint verdict form must be filed 14 days before FPTC.

Source text: The parties shall file a proposed joint general or special verdict form fourteen (14) days before the FPTC.

If parties cannot agree on verdict form, must file 'Competing Verdict Forms' with redlines and basis for each position.

Source text: If the parties are unable to agree on a verdict form, the parties shall file one document titled 'Competing Verdict Forms' which shall include: (i) the parties' respective proposed verdict form; (ii) a 'redline' of any disputed language; and (iii) the factual or legal basis for each party's respective position.

Proposed Findings of Fact and Conclusions of Law must be filed 28 days before FPTC in LR 52-3 format.

Source text: For any trial requiring findings of fact and conclusions of law, each party shall file and serve on the opposing party, no later than twenty-eight (28) days before the FPTC, its Proposed Findings of Fact and Conclusions of Law in the format specified in Local Rule 52-3.

Counsel and witnesses must refer to exhibits by their exhibit number.

Source text: (e) When referring to an exhibit, counsel must refer to its exhibit number. Counsel should instruct their witnesses to do the same.

Opposing party's proposed findings must be marked (strike/bold/underline) 14 days before trial.

Source text: Fourteen (14) days before the trial date or by a date ordered by the Court, each counsel shall file with the Court and serve on opposing counsel a copy of the opposing party's proposed findings of fact and conclusions of law, marked as follows: a) Strike through those portions the party disputes; b) Bold those portions the party admits; and c) Underline those portions the party admits but considers irrelevant.

Declarations of direct testimony must be filed 28 days before trial per LR 16-2.7 and 43-1.

Source text: The parties shall comply with Local Rules 16-2.7 and 43-1. At least 28 days before trial, for each witness a party intends to call at trial, counsel for that party shall either (a) file and serve personally or by fax or electronic mail an executed declaration in lieu of

USB flash drive with PDF exhibits due by noon Wednesday before trial

Source text: In addition to the three (3) sets of binders above, the parties must also submit to the court a USB flash drive containing PDF versions of all exhibits. The USB flash drive must be delivered to the Judge Hwang’s courtesy box located outside the Clerk’s Office on the fourth floor of the First Street Courthouse by 12:00 p.m. on the Wednesday before the start of trial.

Parties must meet and confer 10 days before trial to stipulate to foundation and exhibits

Source text: The parties must meet and confer at least ten (10) days before trial to stipulate as much as possible to foundation, waiver of the best evidence rule, and exhibits that may be received into evidence at the start of the trial.

First day trial materials: 3 binder sets and deposition excerpts for CRD

Source text: The parties must present the following materials to the CRD on the first day of trial: (1) the three sets of binders described above, with one original set of trial exhibits for the jury and two copies of trial exhibits for the court; and (2) any excerpts of deposition transcripts to be used at trial, either as evidence or for impeachment.

Only one attorney per party may conduct examination or make objections for a witness.

Source text: (i) Where a party has more than one (1) lawyer, only one (1) attorney may conduct the direct or cross-examination of a particular witness or make objections as to that witness.

Parties, counsel, and witnesses must be punctual; trial is priority; Court will not delay for tardiness.

Source text: (a) The Court expects the parties, counsel, and witnesses to be punctual. Once the parties and their counsel are engaged in trial, the trial must be their priority. The Court will not delay progress of the trial or inconvenience jurors.

Witnesses must return promptly after recess/adjournment if they were on stand.

Source text: (b) If a witness was on the stand at the time of a recess or adjournment, the party that called the witness shall ensure the witness is back on the stand and ready to proceed as soon as trial resumes.

Parties must have witnesses available; unreasonable delays may result in party being deemed to have rested.

Source text: (d) No presenting party may be without witnesses. If a party’s remaining witnesses are not immediately available, thereby causing an unreasonable delay, the Court may deem that party to have rested.

Counsel must track exhibits and record admission into evidence.

Source text: (a) Counsel must keep track of their exhibits and exhibit list, and record when each exhibit has been admitted into evidence.

Counsel must return CRD exhibits before leaving courtroom.

Source text: (b) Counsel are responsible for any exhibits they secure from the CRD and must return them before leaving the courtroom.

Unmarked exhibits must be requested for identification and shown to opposing counsel before mention.

Source text: (c) Any exhibit not previously marked must be accompanied by a request that it be marked for identification at the time of its first mention. Counsel must show a new exhibit to opposing counsel before the court session in which it is mentioned.

Demonstrative aids must be prepared in advance; witnesses should not draw charts/diagrams.

Source text: (f) Counsel should not ask witnesses to draw charts or diagrams or ask the Court’s permission for a witness to do so. All demonstrative aids must be prepared fully in advance of the day’s trial session.

Counsel must seek admission of unadmitted evidence while authenticating witness is on stand.

Source text: (g) Counsel are required to seek to admit any items of evidence whose admissibility has not yet been stipulated to while the witness authenticating the exhibit is on the stand, so that any issues or concerns that arise may be addressed immediately.

Questioning at witness stand requires specific court approval.

Source text: Counsel must not engage in questioning a witness at the witness stand absent specific approval by the Court.

Application to seal must be filed electronically with proof of service and proposed order attached.

Source text: Electronically file the application to seal with proof of service. Counsel are required to comply with Local Rule 5-4.4.1 and attach the proposed order to the application.

Proposed order must include specific language for rejected seal filings.

Source text: PROPOSED ORDER MUST CONTAIN THE FOLLOWING LANGUAGE FOR THE COURT'S USE IF THE UNDER SEAL FILING IS REJECTED: 1. Counsel shall publicly file the document(s). (For use if the party wants the Court to consider the document(s); 2. Counsel shall file redacted versions of the documents on the docket. The Court will consider the unredacted mandatory paper chambers copy.

Notice of Manual Filing must be electronically filed with specific attachments.

Source text: Electronically file a NOTICE OF MANUAL FILING. which contains the PDF version of the application to seal, the Notice of Manual Filing, the Word version of the proposed order (with the language set forth above), and an Adobe PDF of the document(s) to be filed under seal with a caption page, clearly marked "UNDER SEAL." The subject line of the email should have the case number, plus the words "UNDER SEAL REQUEST."

Plaintiff must serve complaint and file proof of service within 3 days.

Source text: If Plaintiff has not already served the operative complaint on all Defendants, Plaintiff shall do so promptly and shall file proofs of service of the summons and complaint within three (3) days thereafter. See Fed. R. Civ. P. 4.

Pro se litigants must comply with all rules and attend scheduling conference.

Source text: "Counsel," as used in this Order, includes parties who have elected to appear without counsel and are representing themselves in this litigation (hereinafter referred to as "pro se litigants"). Pro se litigants must comply with this Order, the Federal Rules of Civil Procedure, and the Local Rules of the Central District of California. See Local Rules 1-3, 83-2.2.3. Pro se litigants are required to participate in the Scheduling Conference.

Superseding information/indictment must have separate docket entry, not attached to plea agreement.

Source text: A superseding information or indictment shall not be attached to the end of the plea agreement. It shall be filed pursuant to the Local Rules and have its own docket entry.

Corporations and entities must be represented by counsel; withdrawal requires advising of dire consequences.

Source text: Only individuals may represent themselves. A corporation or other entity must be represented by counsel, and if counsel seeks to withdraw, counsel must advise the entity of the dire consequences of failing to obtain substitute counsel before seeking withdrawal—i.e., a plaintiff entity’s case will be dismissed, or a defendant entity will default. See Local Rule 83-2.3.4.

Immediate notification required for case resolution or serious settlement negotiations; sanctions for non-compliance.

Source text: Counsel must advise the Court immediately if (1) the case or any pending matter has been resolved or (2) a motion is pending, and the parties are engaged in serious negotiations that appear likely to resolve the case or the pending motion. Failure to provide timely notice of settlement may result in sanctions.

Form pleadings must be revised within 30 days of removal to comply with FRCP 7, 7.1, 8, 9, 10, 11.

Source text: Any answers filed in state court must be refiled in this Court as a supplement to the Notice of Removal. Any pending motions must be re-noticed in accordance with the Local Rules. If an action is removed to this Court that contains a form pleading (i.e., a pleading in which boxes are checked), the party shall file with the Notice of Removal a revised pleading that complies with Fed. R. Civ. P. 7, 7.1, 8, 9, 10, and 11. An amended complaint filed within thirty (30) days after removal to replace a form complaint pursuant to this instruction shall be deemed an amended complaint with “the court’s leave” pursuant to Fed. R. Civ. P. 15(a)(2).

Discovery matters referred to Magistrate Judge; must include “DISCOVERY MATTER” in caption.

Source text: All discovery matters are referred to the assigned Magistrate Judge. All documents relating to discovery matters must include the words “DISCOVERY MATTER” in the caption to ensure proper routing. Counsel must follow the Magistrate Judge’s procedures for scheduling matters for a hearing.

Attachments must be filed as separately docketed attachments with descriptions

Source text: If a filed or lodged document has declarations, exhibits, or other attachments, each attachment must be filed as a separately docketed attachment to the main docket entry with a description of the attachment (e.g., Dkt. 29-1 Smith Declaration, 29-2 Ex. 1 -

Court will not consider documents with improperly filed attachments

Source text: The Court will decline to consider motions, stipulations, or other documents with attachments that are not filed in accordance with this Order.

Proposed orders must be lodged and served with motions

Source text: (a) Proposed Orders Must be Lodged and Served. Each party filing or opposing a motion or seeking the determination of any matter shall serve and lodge a proposed order setting forth the relief or action sought and a brief statement of the rationale for the decision with appropriate citations.

Court will not consider requests without compliant proposed order

Source text: The Court will not consider a stipulation, ex parte application, or other request for relief until a compliant proposed order is received by email.

AI-generated content must be disclosed with certification of accuracy and Rule 11 compliance.

Source text: Any party who uses generative artificial intelligence (such as ChatGPT, Harvey, CoCounsel, or Google Bard) to generate any portion of a brief, pleading, or other filing must attach to the filing a separate declaration disclosing the use of artificial intelligence and certifying that the filer has reviewed the source material and verified that the artificially generated content is accurate and complies with the filer’s Rule 11 obligations.

Declarations, exhibits, and attachments must be separately docketed with descriptions.

Source text: If a filed or lodged document has declarations, exhibits, or other attachments, each of these must be filed as a separately docketed attachment to the main docket entry with a description of the attachment (e.g., Dkt. 29-1 Smith Declaration).

Joint brief required for summary judgment motions (moving + opposition papers combined).

Source text: The parties shall work cooperatively to submit a single Joint Brief, that is including moving and opposition papers, for any summary judgment motion brought by any moving party(ies).

Attorney’s fees request must be included with default judgment motion or will be struck.

Source text: A plaintiff who moves for default judgment and wishes to seek attorney’s fees and costs must include in the motion a properly supported request for attorney’s fees and costs together with the motion for default judgment. Failure to do so will result in the striking of any subsequent motion for attorney’s fees and costs absent a showing of good cause.

Attorney’s fees motions must include Excel spreadsheet of billed hours emailed to CRD.

Source text: A motion for attorney’s fees must be supported by documentation of the billed hours for which the movant seeks to recover additionally provide by email to the CRD an Excel spreadsheet documenting the hours for which the movant seeks recovery, using the format in the following example:

Joint brief must include TOC, TOA, intro, facts, and issue-by-issue argument with moving party first.

Source text: (b) Content and Organization of Joint Brief. The Joint Brief should contain the following: (1) a table of contents; (2) a table of authorities; (3) an optional brief introduction section stated jointly or, if stated separately by each party, stated under an appropriate subheading identifying the party (e.g., “ACME Co.’s Introduction” or “Defendant’s Introduction”); (4) a statement of facts section stated jointly or, if stated separately by each party, stated under an appropriate subheading identifying the party (e.g., “ACME Co.’s Statement of Facts” or “Defendant’s Statement of Facts”); (5) an analysis or argument section that sets forth the arguments organized by issue that present the parties’ competing positions on an issue-by-issue basis. For each issue, the moving party shall present legal argument, citation to authority where applicable, and citation to the Joint Appendix of Facts, see below, followed immediately by the opposing party’s response that similarly must be supported by legal argument, citation to authority, and citation to the Joint Appendix of Facts.

Joint brief must include Joint Appendix of Facts (JAF) in table format.

Source text: (g) Joint Appendix of Facts (“JAF”). The Joint Brief shall be accompanied by a single statement of undisputed and disputed facts contained in a JAF presented in a table.

Evidentiary objections must be made in a single separate JAO document in four-column table format.

Source text: The Joint Brief shall be accompanied by a JAO—i.e., evidentiary objections, if any, shall be made in a single, separate document presented in a four-column table.

Failure to file timely request for PLRA exhaustion hearing may be construed as waiver.

Source text: The failure to file a timely request may be construed as a waiver of the exhaustion issue.

Moving party must serve opposing party by email/fax/personal service and notify of 48-hour deadline for opposing papers.

Source text: The moving party must also serve the opposing party by email, fax, or personal service, and notify that party that opposing papers must be filed not later than forty-eight (48) hours following service or by 3:00 p.m. on the first court day after the service, whichever is later.

Reply briefs are not permitted for ex parte applications.

Source text: Reply briefs in support of ex parte applications are not permitted.

PLRA exhaustion issue must be raised at beginning of litigation.

Source text: The issue of exhaustion under the PLRA must be raised at the beginning of the litigation.

Failure to comply with court orders or rules may result in dismissal, default, monetary sanctions, or revocation of pro hac vice status.

Source text: If, without satisfactory explanation, counsel fail to file the required Joint Rule 26(f) report or the required pretrial documents, fail to appear at any scheduled proceeding, or otherwise fail to comply with the Court’s orders or rules, the Court shall take any action it deems appropriate, including: (i) dismissal of the case for failure to prosecute, if the failure occurs on the part of the plaintiff; (ii) striking the answer resulting in default if such failure occurs on the part of the defendant; (iii) imposing monetary sanctions against the offending party and counsel, and/or (iv) where applicable, revoking the pro hac vice status of attorneys so admitted.

Chambers copies required for initial pleadings, motions, trial documents, plea agreements, and sentencing position papers.

Source text: Mandatory chambers copies are to be submitted pursuant to Local Civil Rule 5-4.5. The Court requires copies of: (i) initial pleadings (information, indictment, superseding information or indictment); (ii) motion papers (motions, oppositions, replies, non-oppositions, and any related document); (iii) trial documents (joint statement of the case, proposed voir dire, jury instructions, verdict form, joint exhibit list, joint witness list, and any disputes relating to any of the foregoing); (iv) plea agreements; and (v) sentencing position papers.

Plaintiff's counsel or defense counsel (if pro se) must provide order to all parties.

Source text: The plaintiff's counsel or, if the plaintiff is appearing pro se, defense counsel, shall provide this Order to all known parties who have not yet appeared or who appear after the date of this Order.

Parties must make initial disclosures and confer on discovery plan 21 days before scheduling conference.

Source text: The parties are reminded of their obligations to (i) make initial disclosures "without awaiting a discovery request" (Fed. R. Civ. P. 26(a)(1)) and (ii) confer on a discovery plan at least twenty-one (21) days before the Scheduling Conference (Fed. R. Civ. P. 26(f)).

Joint Rule 26(f) Report must be filed 14 days before Scheduling Conference.

Source text: The Joint Rule 26(f) Report must be filed not later than fourteen (14) days before the Scheduling Conference.

Joint Rule 26(f) Report must include specific dates on caption page.

Source text: The Joint Rule 26(f) Report shall specify the date of the Mandatory Scheduling Conference on the caption page. Under the title, it shall list the dates of the (1) Original Complaint; (2) Removal (if removed); (3) Responsive Pleading; and (4) Trial (proposed).

Joint Rule 26(f) report must be filed on original due date even if Scheduling Conference is continued.

Source text: The parties should plan to file the Joint Rule 26(f) report on the original due date even if a continuance of the Scheduling Conference is granted.

Lead trial counsel must attend Scheduling Conference in person unless excused for good cause.

Source text: Lead trial counsel must attend the Scheduling Conference, unless excused by the Court for good cause. Remote appearances are not permitted except for good cause shown.

Failure to submit Joint Rule 26(f) Report or attend Scheduling Conference may result in dismissal, default, or sanctions.

Source text: The failure to timely submit a Joint Rule 26(f) Report or to attend the Scheduling Conference may result in dismissal of the action, striking of the answer and entry default, and/or imposition of sanctions.

Proposed orders must be emailed to chambers with Word and PDF copies for all motions and requests.

Source text: Each party filing or opposing a motion or seeking the determination of any matter shall serve and lodge a proposed order setting forth the relief or action sought and a brief statement of the rationale for the decision with appropriate citations. The Court enforces strict compliance with Local Rule 5-4.4.2, which instructs: 'After a document requiring a judge's signature has been lodged under L.R. 5-4.4.1, a. . . Microsoft Word copy of the proposed document, along with a PDF copy of the electronically filed main document, must be emailed to the assigned judge's generic chambers email address,' namely, AH_chambers@cacd.uscourts.gov. The Court will not consider a stipulation, ex parte application, or other request for relief until a compliant proposed order is received by email.

AI-generated content requires separate disclosure declaration certifying accuracy and Rule 11 compliance.

Source text: Any party who uses generative artificial intelligence (such as ChatGPT, Harvey, CoCounsel, or Google Bard) to generate any portion of a brief, pleading, or other filing must attach to the filing a separate declaration disclosing the use of artificial intelligence and certifying that the filer has reviewed the source material and verified that the artificially generated content is accurate and complies with the filer's Rule 11 obligations.

Government must promptly produce Brady/Giglio/Roviaro/Henthorn evidence to defense counsel.

Source text: Counsel shall comply promptly with discovery and notice pursuant to Rules 12, 12.1, 12.2, 12.3, 12.4, 15, and 16. of the Federal Rules of Criminal Procedure. The Government shall promptly produce to counsel for the defendant any evidence falling within the scope of Brady v. Maryland, 373 U.S. 83 (1963), Giglio v. United States, 405 U.S. 150 (1972), Roviaro v. United States, 353 U.S. 53 (1957) and United States v. Henthorn, 931 F.2d 29 (9th Cir. 1991). Upon government counsel's discovery of any evidence within the scope of Brady v. Maryland, 373 U.S. 83 (1963), such evidence shall be produced forthwith to counsel for the defendant.

Government must produce trial evidence discovery 2 weeks before trial; late evidence requires ex parte application and court approval.

Source text: The Government shall produce to defendant(s) the discovery related to evidence it seeks to introduce at trial no later than two (2) weeks prior to the scheduled trial date. If there is discovery related to trial evidence that is produced after this date, such evidence will not be admitted at trial subject to an ex parte application being filed by the Government seeking such relief that is approved by the Court.

Ex parte applications are considered on papers only, for extraordinary relief, and must comply with Local Rule 7-19.

Source text: The Court considers ex parte applications on the papers and does not usually set these matters for a hearing. If a hearing is necessary, the parties will be notified. Ex parte applications are solely for extraordinary relief and should be used with discretion. Any party seeking ex parte relief must comply with Local Rule 7-19.

Reply briefs are not permitted for ex parte applications.

Source text: Reply briefs in support of ex parte applications are not permitted.

Government trial memorandum must include factual summary, charges/elements, time estimate, and legal/evidentiary discussion.

Source text: The government shall file a trial memorandum that shall set forth (1) a factual summary of the government's case-in-chief; (2) a statement of the charges and the elements of each charge; (3) a time estimate of the length of the government's case-in-chief, including anticipated cross-examination; and (4) a discussion of relevant legal and evidentiary issues as applied to the facts of the particular case.

Joint statement of case must be filed 14 days before final pretrial conference.

Source text: Counsel shall file the joint statement of the case no later than 14 calendar days prior to the Final Pretrial Conference.

Disputed joint statement requires redline comparison of parties' proposals.

Source text: If the parties cannot agree on such a joint statement, they shall file a “Disputed Joint Statement of the Case,” which shall include each party’s respective proposed statement, together with a “redline” comparing the parties’ respective statements.

Proposed verdict forms must be filed 14 days before final pretrial conference.

Source text: Counsel shall file a proposed verdict form(s) no later than 14 calendar days prior to the Final Pretrial Conference.

Competing verdict forms require redline and legal basis for disputes.

Source text: If the parties are unable to agree on a verdict form, the parties shall file one document titled “Competing Verdict Forms” which shall include: (i) the parties’ respective proposed verdict form; (ii) a “redline” of any disputed language; and (iii) the factual or legal

Jury instructions must be filed 14 days before final pretrial conference.

Source text: Jury instructions shall be filed no later than 14 calendar days prior to the Final Pretrial Conference.

Proposed jury instructions must be exchanged 28 days before final pretrial conference.

Source text: Counsel shall exchange proposed jury instructions (general and special) 28 calendar days prior to the Final Pretrial Conference.

Objections to jury instructions must be exchanged 21 days before final pretrial conference.

Source text: Counsel shall exchange any objections to the instructions 21 calendar days prior to the Final Pretrial Conference.

Joint jury instructions must be filed 14 days before final pretrial conference.

Source text: Counsel shall meet and confer with the goal of reaching an agreement on one set of joint jury instructions, which shall be filed no later than 14 calendar days before the Final Pretrial Conference.

Disputed jury instructions require redline and legal basis for disputes.

Source text: If the parties disagree over any proposed jury instruction(s), the parties shall file: (i) one set of proposed jury instructions to which all parties agree; and (ii) one set of disputed jury instructions, which shall include a “redline” of any disputed language and/or the factual or legal basis for each party’s respective position as to each disputed instruction.

Final clean jury instructions must be emailed to chambers on first day of trial.

Source text: A final “clean” version of the jury instructions, which shall include the text of each instruction (eliminating titles, supporting authority, indication of party proposing, etc.), shall be provided to the Court on the first day of trial and sent via email in Word to AH_Chambers@cacd.uscourts.gov.

Witness lists must be emailed to chambers by noon Friday before trial.

Source text: Not later than 12:00 pm on the Friday before the commencement of trial, the Government and defense counsel shall each email their respective witness lists in Word to AH_Chambers@cacd.uscourts.gov.

Defendant must state if no witnesses will be called.

Source text: If the defendant does not intend to call any witnesses, the email shall so state.

Final joint statement must be provided on first day of trial.

Source text: A final version of the joint statement shall be provided to the Court on the first day of trial.

Final verdict form must be emailed to chambers on first day of trial.

Source text: A final version of the verdict form shall be provided to the Court on the first day of trial and sent via email in Word to AH_Chambers@cacd.uscourts.gov.

Exhibit lists must comply with Local Civil Rule 16-6.

Source text: Counsel shall each prepare an exhibit list in compliance with Local Civil Rule 16-6.

Exhibit lists must comply with Local Civil Rule 16-6.1.

Source text: The exhibit list shall comply with Local Civil Rule 16-6.1.

Government must file exhibit list 14 calendar days before Final Pretrial Conference.

Source text: The Government shall file its exhibit list 14 calendar days prior to the Final Pretrial Conference.

Exhibit lists must be emailed to chambers by noon Friday before trial.

Source text: Not later than 12:00 pm on the Friday before the commencement of trial, the Government and defense counsel shall each email their respective exhibit list in Word to AH_Chambers@cacd.uscourts.gov.

Defendant must email statement if not offering exhibits.

Source text: If the defendant does not intend to offer any exhibits, then the email shall so state.

One original and two copies of exhibits must be presented to Courtroom Deputy Clerk on first day of trial.

Source text: One original (witness copy) and two copies (bench and courtroom deputy copy) shall be presented to the Courtroom Deputy Clerk on the first day of trial.

Voluminous exhibits require Space & Facilities approval.

Source text: Arrangements for bringing voluminous trial materials or exhibits into the courthouse must be made through the Space & Facilities Help Desk at (213) 894-1400.

Security pass requires prior approval from Courtroom Deputy Clerk.

Source text: Before contacting Space & Facilities for a required security pass, prior approval of delivery time must be coordinated with the Courtroom Deputy Clerk.

Delivery information must be provided to Space & Facilities 48 hours before arrival.

Source text: Once approval from the Clerk is received, logistical delivery information must be provided to Space & Facilities no later than 48 hours prior to the date of arrival to create and issue the required security pass.

Dangerous exhibits must remain in law enforcement custody during trial.

Source text: Exhibits such as firearms, narcotics, etc., must remain in the custody of a law enforcement agent during the pendency of the trial.

Law enforcement agent must secure and guard dangerous exhibits.

Source text: It shall be the responsibility of the agent to produce any such items for the Court, secure them at all times that the Court is not in session, and guard them at all times while in the courtroom.

US Marshals Service must be notified of weapons/contraband.

Source text: The United States Marshals Service shall be advised whenever weapons or contraband are to be brought into the courthouse.

Only portions of video exhibits played to jury may be admitted.

Source text: Counsel shall seek admission only of the portions of video exhibits played before the jury.

Court will exclude extraneous video portions and control cumulative exhibits under Rule 403.

Source text: The Court will not admit extraneous portions of videos and will strictly control the admission of any wasteful or cumulative video exhibits under Rule 403.

Parties must file glossary of terms one week before trial.

Source text: At least one week before trial, the parties much confer and file a glossary of terms for the court reporter that includes applicable medical, scientific, or technical terms, gang terms, slang, the names and spellings of names likely to be cited, and any other case-specific terminology.

Punctuality required; trial is priority; no delays or juror inconvenience.

Source text: The Court expects the parties, counsel, and witnesses to be punctual. Once the parties and their counsel are engaged in trial, the trial must be their priority. The Court will not delay progress of the trial or inconvenience jurors.

Calling party must ensure witness is ready after recess/adjournment.

Source text: If a witness was on the stand at the time of a recess or adjournment, the party that called the witness shall ensure the witness is back on the stand and ready to proceed as soon as trial resumes.

Parties must have witnesses available; unreasonable delay may result in deemed rest.

Source text: No presenting party may be without witnesses. If a party's remaining witnesses are not immediately available, thereby causing an unreasonable delay, the Court may deem that party to have rested.

Objections must be stated standing with legal ground; sidebar requires permission.

Source text: When objecting, counsel must stand to state the objection and state only that counsel objects and the legal ground for objection. If counsel wishes to argue an objection further, counsel must ask for permission to do so; the Court may or may not grant a request for conference at sidebar.

Counsel must not approach clerk or witness stand without permission.

Source text: Counsel must not approach the Courtroom Deputy Clerk or the witness stand without permission. When permission is given, counsel shall return to the lectern when the task has been completed.

All remarks must be addressed to the Court, not to clerk, reporter, audience, or opposing counsel.

Source text: Counsel must address all remarks to the Court. Counsel are not to address the Courtroom Deputy Clerk, the Reporter, persons in the audience or opposing counsel.

Parties must exchange trial preparation materials 21 days before FPTC

Source text: At least twenty-one (21) days prior to the Final Pre-Trial Conference (henceforth “FPTC”), counsel for each party and pro per litigants1 must have prepared and exchanged with each other all of the following:

Parties must meet and file joint documents 5 days before FPTC

Source text: At least ten (10) days before the FPTC, all counsel and pro se litigants will meet and confer in person so that at least five (5) days before the FPTC, the parties will have filed and provided to the Court “joint” versions of the following:

Joint documents must include all materials with disputes noted

Source text: By “joint”, the Court means that the materials will be contained in a single document signed by all counsel and pro per litigants. In the preparation of said document, no party shall have the right to veto (i.e., exclude from the document) material proffered by any other party. However, areas of dispute or other differences shall be noted.

Parties must follow Local Rules 16-6 and 26-3 for exhibit numbering and marking.

Source text: In numbering and marking the exhibits, the parties are to follow Local Rules 16-6 and 26-3.

Electronically file application to seal and declaration.

Source text: Electronically file the application to seal and the declaration giving notice or proof of service.

Proposed order required with application to seal.

Source text: Attach a proposed order to the electronically filed application (standard procedure for filing application with a proposed order).

Must specify action if application to seal is denied.

Source text: Indicate which of the three following actions will be taken if the application is denied: (1) Counsel will publically file the document(s) for consideration by the Court; (2) Attorney will retrieve the chambers copy of the document(s); or (3) Clerk will destroy the chambers copy of the document(s).

Defense and prosecution must meet and confer on discovery within 7 days of initial arraignment.

Source text: Within seven (7) days of the initial arraignment before the Magistrate Judge, the Assistant United States Attorney assigned to the trial of the case and the defendant’s attorney shall meet and confer on the issue of discovery in this case including, but not limited, the items referenced in Federal Rules of Criminal Procedure 12, 12.1, 12.2, 12.3, 15 and 16.

Government must permit inspection of defendant's relevant statements or confessions.

Source text: (a) Permit defendant’s attorney to inspect and copy or photograph any relevant written or recorded statements or confessions made by the defendant, or copies thereof, within the possession, custody, or control of the Government, the existence of which is known, or by the exercise of due diligence may become known, to the attorney for the Government;

Government must permit inspection of relevant examination results and test reports.

Source text: (b) Permit defendant’s attorney to inspect and copy or photograph any relevant results or reports of physical or mental examinations, and of specific tests or experiments made in connection with the case, or copies thereof, within the possession, custody, or control of the Government, the existence of which is known, or may become known, to the attorney for the Government, and which are material to the defendant’s case;

Government must permit inspection of defendant's grand jury testimony.

Source text: (c) Permit defendant’s attorney to inspect and copy or photograph any relevant recorded testimony of the defendant before a grand jury;

Government must permit inspection of defendant's property in government possession.

Source text: (d) Permit defendant’s attorney to inspect and copy or photograph books, papers, documents, tangible objects, buildings, or places which are the property of the defendant and which are within the possession, custody, or control of the Government;

Government must disclose defendant's prior criminal record.

Source text: (e) Make known to the defendant’s attorney the defendant’s prior criminal record in the possession of the attorney for the Government;

Most recent version of form instructions must be used.

Source text: The most recent version of any form instruction is to be utilized.

Parties must fill in all blanks and spaces in form instructions.

Source text: Any blanks or spaces are to be filled in by the parties.

Modifications to form instructions must indicate changes and cite supporting authority.

Source text: Modifications of established jury instructions from the various sources must specifically indicate the change(s) made to the original form instruction and cite to the authority supporting the modification(s).

Parties must provide a table listing proposed instructions with specific information.

Source text: In addition to the joint proposed jury instruction booklet, the parties are to provide the court with a table listing each proposed instruction and the following information (at the time of the FPTC, only the first two columns need to be filled out):

Parties must disclose next day's witnesses 24 hours in advance and demonstrative evidence 48 hours in advance.

Source text: During the trial, each party must advise its opponent(s) at least 24 hours in advance of the witnesses which it plans to call for the next day. Likewise, any chart or other item of demonstrative evidence (which is otherwise not a pre-marked exhibit) must be shown to the opponent(s) at least 48 hours before its intended use so that a hearing can conveniently be heard outside the presence of the jury, if necessary.

File Notice of Manual Filing for sealing application and documents.

Source text: Electronically file a NOTICE OF MANUAL FILING indicating that the following have been submitted to the Court: (1) an application to seal; (2) a declaration giving notice or a proof of service; (3) a proposed order; and (4) the documents to be placed under seal.

Applications must justify sealing over public access.

Source text: All applications must provide reason(s) as to why the parties' interest to file the document(s) under seal outweighs the public's right to access.

Applications must specify confidential portions.

Source text: All applications must indicate which portions of the documents to be filed under seal are confidential.

Protective order-only applications denied unless addendum filed within 48 hours.

Source text: If a party submits an application to file under seal pursuant to a protective order only (i.e., no other reason is given), the application will be denied unless the Court receives within 48 hours from the notice of filing a document providing (1) the reasons the document should be filed under seal; and (2) the portions within the document that are confidential. This document shall be entitled: "ADDENDUM TO APPLICATION TO FILE UNDER SEAL PURSUANT TO PROTECTIVE ORDER".

Government must permit inspection of evidence favorable to defendant.

Source text: (f) Permit defendant’s attorney to inspect, copy, or photograph any evidence favorable to the defendant;

Government must advise about electronic surveillance or wiretap evidence.

Source text: (g) Advise defendant’s attorney of the existence or non-existence of any evidence in the possession of the Government obtained as the result of any electronic surveillance or wiretap;

Government must advise about contemplated use of informer testimony.

Source text: (h) Advise defendant’s attorney of the contemplated use of informer testimony (fact of informer only, not name or testimony);

Government must disclose intent to use defendant's statements or confessions.

Source text: (i) Disclose to defendant’s attorney its intent to use any statements or confessions made by the defendant. If defendant questions the admissibility of such statement or confession, the hearing required by Jackson v. Denno, 378 U.S. 368 (1964), shall be scheduled at the first status conference with the court;

Government must provide witness statements for case in chief.

Source text: (j) Give to defendant’s counsel a copy of the statements of all witnesses the government intends to call in its case in chief.

Exhibits cannot be passed to jury; may be displayed on courtroom screens briefly.

Source text: The Court does not permit exhibits to be “published” by passing them up and down the jury box. Exhibits may be displayed briefly using the screens in the courtroom, unless the process becomes too time-consuming.

Non-conforming filings may not be considered.

Source text: Filings that do not conform to the Local Rules and this Order may not be considered.

Government must submit exhibit list in Word format to Chambers email by noon Thursday before trial.

Source text: b. The government's exhibit list in the form specified in Local Rule 16-5 (Civil), which shall be sent in Word format to the Chambers email box no later than noon on the Thursday before trial;

Counsel must comply promptly with criminal discovery rules 12, 12.1, 12.2, 12.3, 12.4, 15, and 16.

Source text: Counsel shall comply promptly with discovery and notice pursuant to Rules 12, 12.1, 12.2, 12.3, 12.4, 15, and 16 of the Federal Rules of Criminal Procedure.

Brady evidence must be produced forthwith to defense counsel.

Source text: On government counsel’s discovery of any evidence within the scope of Brady v. Maryland, 373 U.S. 83 (1963), and related cases, such evidence shall be produced forthwith to defense counsel.

Government must disclose electronic surveillance evidence and government informant testimony.

Source text: Government counsel shall also disclose to defense counsel the existence or non-existence of: (1) evidence obtained by electronic surveillance; and (2) testimony by a government informant.

Government must file trial memorandum one week before trial with specific content requirements.

Source text: No later than one week before trial, counsel for the government shall file with the Court a trial memorandum setting forth a factual summary of the government’s case, a statement of the charges and the elements of each charge, an estimate of the length of the government’s case in chief, including anticipated cross-examination, the names of witnesses the government intends to call, and a discussion of relevant legal and evidentiary issues as applied to the facts of the particular case.

Counsel must arrive at courtroom by 8:30 AM on first day of trial.

Source text: Counsel shall arrive at the Courtroom no later than 8:30 a.m. on the first day of trial.

Government must submit witness list in Word format to Chambers email by noon Thursday before trial.

Source text: Counsel for the government shall provide to the courtroom deputy clerk (CRD) the following (electronically and in paper form): a. The government's witness list, which shall be sent in Word format to the Chambers email box no later than noon on the Thursday before trial;

Government must provide exhibits with official tags on first day of trial, numbered 1, 2, 3, etc.

Source text: c. All of the government's exhibits, with official exhibit tags attached and bearing the same number shown on the exhibit list. Exhibit tags may be obtained from the receptionist in the Public Intake Section, located on the 1st Floor of the Edward R. Roybal Federal Building at 255 East Temple Street, Room 180. Exhibits shall be numbered 1, 2, 3, etc., NOT 1.1, 1.2, etc. These items (and the items listed in d and e below) shall be provided on the first day of trial;

Government must provide three-ring binder with indictment, reproducible exhibits, and witness list, with exhibits tabbed.

Source text: d. A three-ring binder containing a copy of the indictment/information, a copy of all exhibits that can be reproduced, and a copy of the witness list. Each exhibit shall be tabbed with the exhibit number for easy reference;

Government must provide three-ring binder with all exhibits for witness use.

Source text: e. A three-ring binder containing a copy of all exhibits for use by witnesses.

Law enforcement agents must maintain custody of sensitive exhibits during trial and secure them at night.

Source text: Exhibits such as firearms, narcotics, etc., must remain in the custody of a law enforcement agent during the pendency of the trial. It shall be the responsibility of the agent to produce any such items for court, secure them at night and guard them at all times while in the courtroom. The United States Marshals Service shall be advised well in advance if weapons or contraband is to be brought into the courthouse.

Defense counsel must attach exhibit tags with case name/number and avoid duplicating government exhibit numbers.

Source text: Defense counsel are responsible for attaching completed exhibit tags with the case name and case number to all exhibits to be used in defendant's case. Defense counsel should be sure that defense exhibit numbers do not duplicate government exhibit numbers.

Defense must provide two three-ring binders for >20 exhibits, tabbed with exhibit numbers, and provide copies as introduced.

Source text: In trials where the defense expects to admit more than 20 exhibits, defense counsel shall provide two three-ring binders (one for the Court and one for witnesses), tabbed if possible with numbers to correspond to the exhibits counsel expects to introduce. Defense counsel shall provide the Court with a copy of defense exhibits as they are introduced during trial, if they have not previously been provided.

Defense must email witness/exhibit lists to Chambers and provide to CRD/court reporter at start of defense case if not already done.

Source text: Defense counsel shall email to the Chambers email box and provide the CRD and the court reporter with the defense witness list and defense exhibit list at the start of the defense case, if they have not previously done so.

Parties must provide case-specific glossary to court reporter at least one week before trial with technical terms, names, and terminology.

Source text: At least one week before trial, the parties must provide a case-specific glossary for the court reporter that includes applicable medical, scientific, or technical terms, gang terms, slang, the names and spellings of case names likely to be cited, street/city/country names, all parties/agents/departments/entities involved in the case, names of people interviewed/deposed, names of family members, friends, or others who might be mentioned, and other case-specific terminology.

Admitted exhibits (except contraband) given to jury during deliberations after counsel review and approve with CRD.

Source text: All admitted exhibits other than contraband will be given to the jury during deliberations. Government and defense counsel shall review and approve the exhibit list and exhibits with the CRD before the exhibits are given to the jury.

Exhibits, charts, or enlargements require agreement or ruling before use.

Source text: Counsel shall not attempt to display or use any exhibits, charts, or enlargements of exhibits unless all counsel have agreed to their use or objections have been heard and a ruling has been made.

Counsel must advise court of concerns/accommodations for parties/witnesses as soon as information is available.

Source text: Before trial begins, and as soon as the information becomes available to counsel, counsel should advise the court of any concerns or accommodations that are requested for parties or witnesses.

Jury instructions must be submitted by Tuesday two weeks before trial.

Source text: No later than the Tuesday two weeks before trial, counsel shall submit both general and substantive jury instructions in the form described below.

Parties must meet and confer to agree on instructions; single set filed electronically and in paper form.

Source text: The parties shall meet and confer sufficiently in advance of the required submission date for the purpose of agreeing on instructions whenever possible. A single set of instructions shall be filed and submitted (electronically to the Chambers email box and in paper form).

Submit clean jury instructions in Word format to Chambers email with paper copy.

Source text: Counsel must submit to the Chambers email box a “clean” set of all instructions in Word format, containing only the text of each instruction, set forth in full on each page, with the caption “Instruction No. ____” (eliminating titles, supporting authority, indication of party proposing, etc.). The “clean set” should not have a table of contents. A paper chambers copy must also be submitted.

Do not refer to witnesses over 14 by first name during trial.

Source text: Counsel shall not refer to any witness -- including a client -- more than 14 years of age by his/her first name during trial.

Do not discuss law or argue case in opening statements.

Source text: Counsel shall not discuss the law or argue the case in opening statements.

Objections must state only legal grounds; no arguing before jury.

Source text: Counsel shall not use objections for the purpose of making a speech, repeating testimony, or attempting to guide the witness. When objecting, counsel shall stand, state only the legal ground of the objection, e.g., hearsay, irrelevant, etc. Counsel shall not argue an objection before the jury. Requests to approach sidebar to further argue an objection should be made sparingly, and may not be granted.

No facial expressions or gestures showing agreement/disagreement with testimony.

Source text: Counsel shall not make facial expressions, nod, or shake their heads, comment, or otherwise exhibit in any way any agreement, disagreement, or other opinion or belief concerning the testimony of a witness. Counsel shall admonish their clients, clients family and friends, witnesses, and observers not to engage in such conduct.

Do not talk to jurors or anyone where jurors can overhear.

Source text: Counsel should not talk to jurors at all, and should not talk to co-counsel, opposing counsel, witnesses, clients or their family or friends where the conversation can be overheard by jurors. Each counsel should admonish counsel’s own clients and their family members, investigators, paralegals, witnesses, etc. to avoid such conduct.

Question witnesses from lectern; do not approach witness box without permission.

Source text: Counsel shall question witnesses from the lectern. Counsel shall not approach the witness box or enter the well without the Court’s permission, and shall return to the lectern when counsel’s purpose has been accomplished.

No document shall be placed before a witness or shown to the jury unless a copy...

Source text: No document shall be placed before a witness or shown to the jury unless a copy...

File application to seal electronically with proof of service and proposed order.

Source text: Electronically file the application to seal with proof of service. Counsel are required to comply with Local Rule 5-4.4.1 and attach the proposed order to the application.

Strict compliance with Local Rule 16 required; no exemptions for pro se parties.

Source text: STRICT COMPLIANCE WITH LOCAL RULE 16 IS REQUIRED. THIS ORDER SETS FORTH SOME DIFFERENT AND SOME ADDITIONAL REQUIREMENTS. THIS COURT DOES NOT EXEMPT PRO PER PARTIES FROM THE REQUIREMENTS OF RULE 16.

Pretrial documents must conform to Local Rules format (Appendix A).

Source text: Carefully prepared memoranda of contentions of fact and law, witness lists, a joint exhibit list, and a proposed pretrial conference order must be submitted in accordance with the Rules and this Order, and the format of the proposed pretrial conference order must conform to the format set forth in Appendix A to the Local Rules.

Witness lists require testimony description and time estimates; explain multiple witnesses on same topics.

Source text: In addition to the requirements of Local Rule 16, the witness lists must include a brief (one or two paragraph) description of the testimony, and a time estimate for both direct and cross-examination (separately stated). If two or more witnesses will testify on the same topics, counsel must explain why more than one witness is necessary.

Simplified witness list and joint exhibit list required in Word format via email; paper copies also required.

Source text: A separate version of the witness list containing only the names of the witnesses and a separate column to insert the dates on which the witness testified, and the joint exhibit list, must be submitted to the Chambers email box in Word format. Mandatory paper chambers copies must also be submitted.

ADR proceeding must be completed by Court-set deadline.

Source text: Counsel must complete an ADR proceeding no later than the date set by the Court.

Motions in limine must be filed by the Court-established deadline.

Source text: All motions in limine must be filed by the date established by the Court.

Counsel must meet and confer to attempt agreement on disputed evidence before filing motions in limine.

Source text: Counsel are to meet and confer to determine whether opposing counsel intends to introduce the disputed evidence, etc. and to attempt to reach an agreement that would obviate the motion.

Opposition to motions in limine must be filed by the Court-established deadline.

Source text: Opposition must be filed by the date established by the Court.

Motions in limine must address specific issues, not broad categories.

Source text: Motions in limine should address specific issues (i.e., not “to exclude all hearsay,” etc.).

Plaintiff must serve proposed jury instructions and verdict forms 14 days before Rule 16-2 meeting.

Source text: At least fourteen days before the meeting of counsel required by Local Rule 16-2 (which must occur at least 40 days before the date set for the pretrial conference), plaintiff(s) counsel must serve on defense counsel proposed jury instructions and proposed verdict/special verdict forms.

Defense must serve objections to jury instructions within 7 days of receiving plaintiff's proposals.

Source text: Within 7 days, defense counsel must serve objections, if any, to those instructions and verdict forms, as well as any proposed alternative or additional instructions and verdict forms.

Counsel must attempt to agree on jury instructions at or before Rule 16-2 meeting.

Source text: Before or at the Rule 16-2 meeting, counsel must attempt to come to agreement on the proposed jury instructions and verdict forms.

Parties must use most recent Ninth Circuit model jury instructions, modified for case specifics.

Source text: When the Manual of Model Jury Instructions for the Ninth Circuit provides an applicable jury instruction, the parties should submit the most recent version, modified and supplemented to fit the circumstances of this case.

Bracket language must be selected and all blanks completed in jury instructions.

Source text: Where language appears in brackets, the appropriate language should be selected. All blanks should be completed.

California law cases must use current BAJI or CACI jury instructions.

Source text: Where California law applies, counsel should use the current edition of California Jury Instructions -- Civil (BAJI or CACI).

Non-standard instructions must be based on same law as Ninth Circuit/California/other applicable law.

Source text: When submitting other than Ninth Circuit or California instructions, counsel should be sure that the law on which the instruction is based is the same as Ninth Circuit law (or California or other state law, if applicable) on the subject.

Alternatives to standard instructions only allowed with reasoned argument they're incomplete or incorrect.

Source text: Counsel may submit alternatives to the Ninth Circuit model jury instructions, or BAJI or CACI, only if counsel has a reasoned argument that those instructions do not properly state the law or they are incomplete.

Court provides its own introductory instructions; counsel must provide only post-evidence instructions.

Source text: The Court has its own introductory instructions (instructions read before opening statements). Counsel should provide only instructions to be read after the evidence has been submitted or that may be appropriate during trial.

Joint jury instructions must be filed electronically to Chambers email and in paper form by Court-set date.

Source text: By the date set by the Court, counsel must file with the Court and submit (electronically to the Chambers email box and in paper form) a JOINT set of jury instructions on which there is agreement.

Disputed jury instructions must be filed with supporting statements and authorities, plus alternative instructions if applicable.

Source text: At the same time, each party must file with the Court and submit (electronically to the Chambers email box and in paper form) its proposed jury instructions that are objected to by any other party. Each disputed instruction must have attached a short (one or two paragraph) statement, including points and authorities in support of the instruction as well as a brief statement, including points and authorities, in support of any objections. A proposed alternative instruction must be provided, if applicable.

Index of all jury instructions must include number, title, source, and page number.

Source text: Counsel must provide an index of all instructions submitted, which must include the following: a. The number of the instruction; b. The title of the instruction; c. the source of the instruction and any relevant case citations; d. The page number of the instruction.

Non-compliance with jury instruction provisions results in sanctions and waiver of jury trial.

Source text: FAILURE TO FOLLOW THE PRECEDING PROVISIONS OF THIS SECTION WILL SUBJECT THE NON-COMPLYING PARTY AND ATTORNEY TO SANCTIONS AND WILL BE DEEMED TO CONSTITUTE A WAIVER OF JURY TRIAL.

Joint one or two page case statement must be filed with proposed pretrial conference order.

Source text: At the time of lodging the proposed pretrial conference order, counsel should file a jointly prepared one or two page statement of the case to be read by the Court to the prospective panel of jurors before commencement of voir dire.

Counsel must meet 10 days before trial to stipulate on foundation, best evidence rule waiver, and exhibits.

Source text: All counsel are to meet not later than ten days before trial and to stipulate, so far as is possible, to foundation, to waiver of the best evidence rule, and to those exhibits that may be received into evidence at the start of the trial.

One week before trial, counsel must email Chambers: glossary, witness list, and joint exhibit list.

Source text: At least one week before trial, counsel must send to the Chambers email box in Word format: a. A case-specific glossary for the court reporter that includes applicable medical, scientific, or technical terms, slang, the names and spellings of case names likely to be cited, street/city/country names, all parties/entities involved in the case, names of people interviewed/deposed, names of family members, friends, or others who might be mentioned, and other case-specific terminology; b. The party’s witness list, with a column to add the date on which the witness testified; c. The joint exhibit list in the form specified in Local Rule 16-6. An annotated exhibit list identifying the exhibits to be received into evidence at the start of the trial must also be provided.

First morning of trial: submit original exhibits with tags, numbered 1, 2, 3, etc., no duplicates, blow-ups as A.

Source text: On the first morning of trial, counsel must submit to the CRD: a. All original exhibits (except those to be used for impeachment only), with official exhibit tags attached and bearing the same number shown on Intake Section, located on the 1st floor of the Edward R. Roybal Federal Building at 255 East Temple St., Room 180. Digital exhibit tags are also available on the Court’s website under Court Forms > General forms > Form G-14A (plaintiff) and G-14B (defendant). Exhibits must be numbered 1, 2, 3, etc., NOT 1.1, 1.2, etc. and in accordance with Local Rule 16-6. The defense exhibit numbers must not duplicate plaintiff’s numbers. If a “blow-up” is an enlargement of an existing exhibit, it must be designated with the number of the original exhibit followed by an “A.”;

Exhibit list with admitted exhibits must be given to jury and approved by counsel.

Source text: A copy of the exhibit list with all admitted exhibits will be given to the jury during deliberations. Counsel must review and approve the exhibit list with the CRD before the list is given to the jury.

When objecting, counsel must rise, state objection and legal ground only; must ask permission to argue further.

Source text: When objecting, counsel must rise to state the objection and state only that counsel objects and the legal ground of objection. If counsel wishes to argue an objection further, counsel must ask for permission to do so.

Must confer with opposing counsel before offering a stipulation.

Source text: Counsel must not offer a stipulation unless counsel has conferred with opposing counsel and has verified that the stipulation will be acceptable.

Must get advance permission to leave counsel table during court session.

Source text: While Court is in session, counsel must not leave counsel table to confer with any personnel or witnesses unless permission has been granted in advance.

Exhibits/charts/enlargements require agreement or ruling before use.

Source text: Counsel shall not attempt to display or use any exhibits, charts, or enlargements of exhibits unless all counsel have agreed to their use or objections have been heard and a ruling has been made.

Must not talk to jurors or have conversations overheard by jurors.

Source text: Counsel should not talk to jurors at all, and should not talk to co-counsel, opposing counsel, witnesses, or clients where the conversation can be overheard by jurors. Each counsel should admonish counsel's own clients and witnesses to avoid such conduct.

Only one lawyer per party may conduct examination or make objections for a particular witness.

Source text: Where a party has more than one lawyer, only one may conduct the direct or cross-examination of a particular witness, or make objections as to that witness.

Witness on stand at recess must be ready when court resumes.

Source text: If a witness was on the stand at a recess or adjournment, counsel must have the witness back on the stand, ready to proceed, when the court session resumes.

Must notify CRD in advance about witness accommodations.

Source text: Counsel must notify the CRD in advance if any witness should be accommodated based on a disability or for other reasons.

Presenting party must have witnesses; may be deemed to have rested if no witnesses available.

Source text: No presenting party may be without witnesses. If counsel has no more witnesses to call and there is more than a brief delay, the Court may deem that party to have rested.

Counsel responsible for CRD exhibits and must return them before leaving courtroom.

Source text: Each counsel is responsible for any exhibits that counsel secures from the CRD and must return them before leaving the courtroom at the end of the session.

Unmarked exhibits must be marked by CRD and shown to opposing counsel before mention.

Source text: An exhibit not previously marked should, at the time of its first mention, be accompanied by a request that the CRD mark it for identification. To save time, counsel must show a new exhibit to opposing counsel before it is mentioned in court.

Brady and discovery obligations under Federal Rules of Criminal Procedure.

Source text: Counsel shall comply promptly with discovery and notice pursuant to Rules 12, 12.1, 12.2, 12.3, 12.4, 15, and 16 of the Federal Rules of Criminal Procedure. On government counsel’s discovery of any evidence within the scope of Brady v. Maryland, 373 U.S. 83 (1963), and related cases, such evidence shall be produced forthwith to defense counsel. Government counsel shall also disclose to defense counsel the existence or non-existence of: (1) evidence obtained by electronic surveillance; and (2) testimony by a government informant.

Government must file trial memorandum one week before trial with specific content requirements.

Source text: No later than one week before trial, counsel for the government shall file with the Court a trial memorandum setting forth a factual summary of the government’s case, a statement of the charges and the elements of each charge, an estimate of the length of the government’s case in chief, including anticipated cross-examination, the names of witnesses the government intends to call, and a discussion of relevant legal and evidentiary issues as applied to the facts of the particular case. Government shall attempt to obtain defense counsel’s agreement.

Government must submit witness list in Word format to Chambers email by noon Thursday before trial

Source text: Counsel for the government shall provide to the courtroom deputy clerk (CRD) the following (electronically and in paper form): a. The government's witness list, which shall be sent in Word format to the Chambers email box no later than noon on the Thursday before trial;

Government must submit exhibit list in Word format to Chambers email by noon Thursday before trial

Source text: b. The government's exhibit list in the form specified in Local Rule 16-5 (Civil), which shall be sent in Word format to the Chambers email box no later than noon on the Thursday before trial;

Government exhibits must have official tags, be numbered 1, 2, 3, etc., and provided on first day of trial

Source text: c. All of the government's exhibits, with official exhibit tags attached and bearing the same number shown on the exhibit list. Exhibit tags may be obtained from the receptionist in the Public Intake Section, located on the 1st Floor of the Edward R. Roybal Federal Building at 255 East Temple Street, Room 180. Exhibits shall be numbered 1, 2, 3, etc., NOT 1.1, 1.2, etc. These items (and the items listed in d and e below) shall be provided on the first day of trial;

Government must provide three-ring binder with indictment, reproducible exhibits, and witness list, with exhibits tabbed

Source text: d. A three-ring binder containing a copy of the indictment/information, a copy of all exhibits that can be reproduced, and a copy of the witness list. Each exhibit shall be tabbed with the exhibit number for easy reference;

Government must provide three-ring binder with all exhibits for witness use

Source text: e. A three-ring binder containing a copy of all exhibits for use by witnesses.

Defense counsel must attach exhibit tags with case name/number and ensure no duplicate exhibit numbers with government

Source text: Defense counsel are responsible for attaching completed exhibit tags with the case name and case number to all exhibits to be used in defendant's case. Defense counsel should be sure that defense exhibit numbers do not duplicate government exhibit numbers.

Defense must provide two three-ring binders (Court and witnesses) for trials with >20 exhibits, tabbed with exhibit numbers

Source text: In trials where the defense expects to admit more than 20 exhibits, defense counsel shall provide two three-ring binders (one for the Court and one for witnesses), tabbed if possible with numbers to correspond to the exhibits counsel expects to introduce. Defense counsel shall provide the Court with a copy of defense exhibits as they are introduced during trial, if they have not previously been provided.

Defense must email witness/exhibit lists to Chambers and provide to CRD/court reporter at start of defense case if not previously done

Source text: Defense counsel shall email to the Chambers email box and provide the CRD and the court reporter with the defense witness list and defense exhibit list at the start of the defense case, if they have not previously done so.

Parties must provide case-specific glossary to court reporter at least one week before trial with medical, technical, gang terms, names, etc.

Source text: At least one week before trial, the parties must provide a case-specific glossary for the court reporter that includes applicable medical, scientific, or technical terms, gang terms, slang, the names and spellings of case names likely to be cited, street/city/country names, all parties/agents/departments/entities involved in the case, names of people interviewed/deposed, names of family members, friends, or others who might be mentioned, and other case-specific terminology.

Admitted exhibits (except contraband) given to jury during deliberations after government/defense review and approve with CRD

Source text: All admitted exhibits other than contraband will be given to the jury during deliberations. Government and defense counsel shall review and approve the exhibit list and exhibits with the CRD before the exhibits are given to the jury.

Jury instructions due Tuesday two weeks before trial.

Source text: No later than the Tuesday two weeks before trial, counsel shall submit both general and substantive jury instructions in the form described below.

Index page required for jury instructions with number, title, source, and page number.

Source text: An index page shall accompany the jury instructions and shall indicate the following: a. The number of the instruction; b. A brief title of the instruction; c. The source of the instruction; and d. The page number of the instruction.

Clean Word set of jury instructions required for chambers (no TOC), plus paper copy.

Source text: Counsel must submit to the Chambers email box a "clean" set of all instructions in Word format, containing only the text of each instruction, set forth in full on each page, with the caption "Instruction No. ____" (eliminating titles, supporting authority, indication of party proposing, etc.). The "clean set" should not have a table of contents. A paper chambers copy must also be submitted.

Proposed verdict form required with jury instructions; no specific counts or code sections.

Source text: Counsel shall submit a proposed verdict form with the jury instructions. The proposed verdict form should not refer to specific counts or to specific code sections.

Voir dire questions due Monday one week before trial; 5 minutes additional time allowed.

Source text: If counsel wish to submit proposed questions to be asked of prospective jurors, they must do so no later than the Monday one week before the jury trial. A Word version of the proposed voir dire must be submitted. Counsel will usually be allowed five minutes of voir dire in addition to the Court’s voir dire.

Witnesses over 14 years old must not be referred to by first name during trial.

Source text: Counsel shall not refer to any witness -- including a client -- more than 14 years of age by his/her first name during trial.

No discussion of law or argument in opening statements.

Source text: Counsel shall not discuss the law or argue the case in opening statements.

Objections limited to legal grounds; no arguing before jury; sidebar requests sparingly.

Source text: Counsel shall not use objections for the purpose of making a speech, repeating testimony, or attempting to guide the witness. When objecting, counsel shall stand, state only the legal ground of the objection, e.g., hearsay, irrelevant, etc. Counsel shall not argue an objection before the jury. Requests to approach sidebar to further argue an objection should be made sparingly, and may not be granted.

No facial expressions or reactions to witness testimony; counsel must admonish others.

Source text: Counsel shall not make facial expressions, nod, or shake their heads, comment, or otherwise exhibit in any way any agreement, disagreement, or other opinion or belief concerning the testimony of a witness. Counsel shall admonish their clients, clients family and friends, witnesses, and observers not to engage in such conduct.

No talking to jurors or conversations overheard by jurors; counsel must admonish others.

Source text: Counsel should not talk to jurors at all, and should not talk to co-counsel, opposing counsel, witnesses, clients or their family or friends where the conversation can be overheard by jurors. Each counsel should admonish counsel’s own clients and their family members, investigators, paralegals, witnesses, etc. to avoid such conduct.

Witnesses questioned from lectern; no approaching witness box without permission.

Source text: Counsel shall question witnesses from the lectern. Counsel shall not approach the witness box or enter the well without the Court’s permission, and shall return to the lectern when counsel’s purpose has been accomplished. Counsel should speak clearly when questioning witnesses, making objections, etc.

Parties must comply with Local Rule 56, Standing Order, and this order for summary judgment motions.

Source text: When filing or opposing a motion for summary judgment, a party is to comply precisely with Local Rule 56, the Court’s general Standing Order, and this order.

Separate statement must be in two-column format with numbered paragraphs for undisputed facts and supporting evidence.

Source text: Separate Statement of Uncontroverted Facts and Conclusions of Law: The separate statement shall be prepared in a two-column format. The left-hand column sets forth -- in sequentially-numbered paragraphs -- the allegedly undisputed fact. The right-hand column sets forth the evidence that supports that fact. Each paragraph should contain a narrowly-focused statement of fact addressing a single subject as concisely as possible. The moving, opposing, and reply papers should refer to the numbered paragraphs in the separate statement, rather than the underlying evidence.

Opposing party's statement of genuine disputes must be in two-column format tracking moving party's separate statement.

Source text: Statement of Genuine Disputes: The opposing party’s statement of genuine disputes must be in two columns. The left-hand column must restate the opposing party’s allegedly undisputed fact and track the moving party’s separate statement exactly as filed. The right-hand column must state whether the fact is undisputed or disputed. The opposing party may dispute all or only a portion of the statement of fact. If disputing only a portion, the statement of genuine disputes must clearly indicate what part is being disputed, followed by the opposing party’s evidence

Opposing party may submit additional material facts in sequentially-numbered paragraphs with supporting evidence in right-hand column.

Source text: The opposing party may also submit additional material facts that bear on or relate to the issues raised by the movant, which shall follow the format described above for the moving party’s separate statement. These additional facts shall continue in sequentially-numbered paragraphs and shall set forth in the right-hand column the evidence that supports that statement.

Only specific evidence necessary to support/controvert undisputed facts should be submitted; entire transcripts/responses not allowed.

Source text: Supporting Evidence: No party should submit evidence other than the specific items of evidence or testimony necessary to support or controvert a proposed statement of undisputed fact. For example, entire deposition transcripts, entire sets of interrogatory responses, and documents that do not specifically support or controvert material in the separate statements should not be submitted in support of or opposition to a motion for summary judgment. The Court will not consider such material.

Evidence must be submitted by stipulation or as exhibits to declarations, not attached to memorandum.

Source text: Evidence submitted in support of or in opposition to a motion should be submitted either by way of stipulation or as exhibits to declarations sufficient to authenticate the proffered evidence, and should not be attached to the memorandum of points and authorities.

Pleadings must refer to exhibits by number only or number plus title, not title alone.

Source text: The pleadings should refer to the exhibits by exhibit number only, or by exhibit number and title of document -- not merely by the title of the document. For example, if Exhibit 1 is the License Agreement, the papers should refer to “the License Agreement attached as Exhibit 1,” or “Exhibit 1,” not “the License Agreement.”

Evidentiary objections must be stated in separate statement but argued in separate memorandum with opposition/reply brief.

Source text: If a party disputes a fact based in whole or in part on an evidentiary objection, the ground of the objection, as indicated above, should be stated in the separate statement, but not argued in that document. Evidentiary objections are to be addressed in a separate memorandum to be filed with the opposition or reply brief.

Blanket or boilerplate objections to undisputed facts will be overruled and disregarded.

Source text: Do not submit blanket or boilerplate objections to the opponent’s statements of undisputed fact. The objections will be overruled and disregarded.

Proposed order must include specific language for rejected seal filings.

Source text: PROPOSED ORDER MUST CONTAIN THE FOLLOWING LANGUAGE FOR THE COURT’S USE IF THE UNDER SEAL FILING IS REJECTED:

File Notice of Manual Filing electronically.

Source text: Electronically file a NOTICE OF MANUAL FILING.

Ex parte applications must comply with Local Rules 7-19/7-19.1 and include opposing counsel’s position, absent specific good cause.

Source text: Ex parte applications that fail to conform to Local Rule 7-19 and 7-19.1, including a statement of opposing counsel’s position, will not be considered except on a specific showing of good cause.

A declaration with competent evidence is required to justify filing documents under seal.

Source text: Declaration setting forth competent evidence explaining why the document(s) should be filed under seal.

Mandatory in-person appearance required at all court appearances until stipulation of dismissal is filed, even if settlement reached.

Source text: Under no circumstances should counsel, or a party if the party is appearing pro se, fail to appear at a court appearance unless their appearance has been waived by prior order of the Court. Even if a settlement has been reached, counsel for all parties, or the party if appearing pro se, must appear at court appearances until a stipulation of dismissal signed by all parties has been lodged with the Court.

Ex parte applications must conform to Local Rules 7-19 and 7-19.1 and include opposing counsel's position

Source text: Ex parte applications that fail to conform to Local Rule 7-19 and 7-19.1, including a statement of opposing counsel’s position, will not be considered except on a specific showing of good cause.

Counsel must include contact information on their papers.

Source text: Counsel should list their email addresses and phone numbers on their papers in order to facilitate communication by the Courtroom Deputy Clerk.

Parties must immediately notify court of settlement by phone, email, or notice filing.

Source text: If settlement is reached at any time in this litigation, the parties shall immediately notify the Court by telephone, email, or by filing a notice of settlement. Local Rule 40-2.

Deliver 1 conformed application copy, 1 proposed order copy, and 1 under seal document copy to intake window without envelopes.

Source text: The filer will deliver the following documents to the intake window: one conformed copy of the application, one copy of the proposed order, and one copy of the proposed under seal document. (These are the Court's mandatory chambers copies). NO envelopes are used. The intake clerk will put a red sheet of paper (under seal filing) on top of the papers and put the stack into the Judge's box at Intake. The intake clerk will not stamp or review the papers.

Deliver chambers copies to Clerk's Office intake in Santa Ana, not Judge Carter's 9th floor drop box.

Source text: ALWAYS deliver the mandatory chambers copies of under seal documents to the intake section of the Clerk's Office in Santa Ana. DO NOT deliver mandatory chambers copies of under seal documents to Judge Carter's drop box on the 9th Floor.

Serve conformed under seal documents on all parties and file proof of service within 24 hours after court rules.

Source text: After the Court rules on the application, the courtroom deputy will e-mail conformed copies of the necessary documents to the filer.* The filer is required to serve copies of the conformed under seal documents on all other parties, as necessary, and file a proof of service within 24 hours of the courtroom deputy returning the conformed copies of the documents.

Deliver 1 application copy, 1 proposed order copy, 1 under seal document copy, and Notice of Manual Filing to intake window without envelopes.

Source text: The filer delivers the following documents to the intake window: one copy of the application, one copy of the proposed order, one copy of the proposed under seal document, and the Notice of Manual Filing. (These are the Court's mandatory chambers copies). NO envelopes are used. The intake clerk will put a red sheet of paper (under seal filing) on top of the papers and put the stack into the Judge's box at intake. The Intake Clerk will not stamp or review the papers.

Deliver chambers copies to Clerk's Office intake in Santa Ana, not Judge Carter's 9th floor drop box.

Source text: ALWAYS deliver the mandatory chambers copies of under seal documents to the intake section of the Clerk's Office in Santa Ana, DO NOT deliver mandatory chambers copies of under seal documents to Judge Carter's drop box on the 9th Floor.

Serve conformed under seal documents on all parties and file proof of service within 24 hours after court rules.

Source text: After the Court rules on the application, the courtroom deputy will e-mail conformed copies of the documents to the filer.* The filer is required to serve copies of the conformed under seal documents on all other parties, as necessary, and file a proof of service within 24 hours of the courtroom deputy returning the conformed copies of the documents.

Plaintiff's counsel or plaintiff must serve this order on all parties; removing defendants must serve if case came by removal.

Source text: Plaintiff’s counsel or plaintiff (if appearing on his or her own behalf) shall immediately serve this Order on all parties, including any new parties to the action. If this case came to the Court by a Notice of Removal, the removing defendant(s) shall serve this Order on all other parties.

Scheduling conference required under FRCP 16(b).

Source text: The parties are hereby ordered to appear before this Court for a Scheduling Conference on the above-listed date and time, pursuant to Federal Rule of Civil Procedure 16(b).

Opposing party must explain why disputed facts are controverted with citations.

Source text: To demonstrate that a fact is disputed, the opposing party shall briefly state why it disputes the moving party’s allegedly undisputed fact, cite to the relevant exhibit or other evidence controverting the allegedly undisputed fact, and describe what it is in that exhibit or evidence that controverts the allegedly undisputed fact.

Evidentiary objections must be noted in right column and detailed in separate table.

Source text: If the opposing party objects to the evidence supporting an allegedly undisputed fact, the party shall state in the right hand column the presence of that objection, by simply stating “Evidentiary Objection.” The specific grounds of each objection should be included in a separate table.

No legal arguments allowed in Statement of Genuine Disputes.

Source text: No legal argument shall be set forth in this document.

Extensive deposition citations require lodging transcript with court.

Source text: If a deposition is cited extensively, the parties should lodge a copy of the deposition transcript with the Court.

Evidentiary objections require separate document filed with motion/opposition.

Source text: If a party disputes a fact based in whole or in part on an evidentiary objection, the party should file a separate document entitled “Objections to Evidence Offered in Support of [Party’s] [Motion/Opposition].” The Objections to Evidence should be filed in conjunction with the

Statements of fact must be emailed to chambers in Word or Excel format.

Source text: In addition to filing statements of fact, the Parties should email the Statement of Uncontroverted Facts and Statement of Genuine Disputes in Word or Excel format to DOC_Chambers@cacd.uscourts.gov.

Memoranda of Contentions due 21 days before FPTC; proposed FPTCO due 11 days before.

Source text: The Memoranda of Contentions of Fact and Law are due twenty-one (21) days before the FPTC and the proposed FPTCO is to be lodged eleven (11) days before the FPTC.

Joint statement of the case required 7 days before trial.

Source text: At least seven (7) days prior to trial, the parties shall prepare a joint statement of the case which will be read by the Court to the prospective panel of jurors prior to the commencement of voir dire.

Special voir dire questions must be filed and served 7 days before trial.

Source text: At least seven (7) days prior to trial, each party shall file and serve on opposing parties any special questions requested to be put to prospective jurors on voir dire.

Proposed jury instructions due 7 days before trial with citations.

Source text: Proposed jury instructions must be filed seven (7) days prior to trial, in accordance with Local Rule 51. Parties should cite relevant authorities for each instruction, e.g., CACI, Ninth Cir. Model Jury Instructions. The parties should exchange proposed jury instructions and agree as much as possible on the necessary instructions before filing them with the Court.

Proposed findings of fact and conclusions of law due 7 days before trial.

Source text: The parties shall serve and lodge proposed findings of fact and conclusions of law at least seven (7) days prior to trial and in accordance with Local Rule 52.

Proposed verdict forms due 7 days before trial.

Source text: At least seven (7) days prior to trial, the parties shall file their proposed verdict forms.

Joint exhibit list due 21 days before FPTC.

Source text: A joint exhibit list must be filed at least twenty-one (21) days prior to the Final Pretrial Conference in accordance with Local Rule 16-6.1.

Exhibits must be delivered to Courtroom Deputy Clerk by 8:30 AM on first day of trial.

Source text: Exhibits are to be delivered to the Courtroom Deputy Clerk not later than 8:30 a.m. on the first day of trial.

Two binders required: one for Clerk (tagged) and one for Court.

Source text: Two binders will be prepared: (1) an original for the Clerk, which will be tagged with the appropriate exhibit tags in the upper right-hand corner of the first page of each exhibit, and (2) one copy for the Court.

Exhibits numbered per Local Rule 26-3; tags available at Clerk's Office.

Source text: The exhibits are to be numbered in accordance with Local Rule 26-3. Counsel may obtain exhibit tags (yellow for plaintiff and blue for defendant) at the Clerk's Office, Intake Window.

Rule 26(f) conference required at least 21 days before scheduling conference.

Source text: Counsel shall confer pursuant to Federal Rule of Civil Procedure 26(f). This conference shall occur at least twenty-one (21) days before the Scheduling Conference set by the Court.

Rule 26(f) report due 14 days before scheduling conference.

Source text: The parties shall file their Rule 26(f) report with the Court no later than fourteen (14) days prior to the Scheduling Conference set by the Court.

Rule 26(f) report must include case summary, issues, and amendment likelihood.

Source text: The report shall contain the following: (1) a short factual summary of the case and of claims and defenses; (2) a short synopsis of the principal issues in the case; (3) a statement of whether parties are likely to be added and whether the pleadings are likely to be amended

Motions to join parties or amend pleadings must be filed before Rule 26(f) conference.

Source text: Counsel should note that the Court requires all motions to join other parties, including Doe or Roe defendants, or to amend the pleadings to be filed and served before the Rule 26(f) conference.

Failure to appear at scheduling conference is prohibited unless waived by court order.

Source text: Under no circumstances should counsel, or a party if the party is appearing pro se, fail to appear at the scheduling conference unless the appearance has been waived by prior order of the Court.

Plaintiff must serve copy of order on unserved defendants when serving complaint.

Source text: Plaintiff shall serve a copy of this Order on any as-yet unserved Defendants when Plaintiff serves the Complaint on them.

Plaintiff's counsel must serve this order on all parties immediately.

Source text: Counsel for Plaintiff(s) shall serve this order immediately on all parties and/or their attorney(s), including any new parties to the action. If this action has been removed from the state court, the defendant who removed the action shall serve this order on all other parties.

Proposed orders are required.

Source text: Proposed Orders ......................................................................................... 14

Plaintiff must serve complaint under Rule 4 and file proof of service under Local Rule 5-3.1; unserved defendants dismissed.

Source text: Plaintiff shall promptly serve the complaint in accordance with Fed. R. Civ. P. 4 and file the proofs of service pursuant to Local Rule 5-3.1. Any defendant not timely served under Fed. R. Civ. P. 4(m), including “Doe” or fictitiously named defendants, shall be dismissed from the action.

Removed actions must re-file state court documents and re-notice pending motions under Local Rule 7.

Source text: All documents filed in state court, including documents appended to the complaint, answers, and motions, must be re-filed in this court as a supplement to the notice of removal. See 28 U.S.C. § 1447(a) and (b). Any pending motions must be re-noticed in accordance with Local Rule 7.

Form pleadings in removed actions must be revised to comply with Rules 7, 7.1, 8, 9, 10, and 11 within 30 days.

Source text: If an action removed to this court contains a state court Judicial Council form pleading (i.e., a pleading in which a party selects claims or defenses by checking boxes), the party that filed the form pleading must file a revised pleading that complies with Fed. R. Civ. P. 7, 7.1, 8, 9, 10 and 11, within thirty (30) days of receipt of the Notice of Removal.

All discovery matters referred to Magistrate Judge; include “DISCOVERY MATTER” in caption for proper routing.

Source text: All discovery matters are hereby referred to the assigned Magistrate Judge, who will hear all discovery disputes. The Magistrate Judge’s initials follow the district judge’s initials next to the action number. All discovery-related documents must include the words “DISCOVERY MATTER” in the caption to ensure proper routing.

Motion to reconsider must specify erroneous portions and deliver conformed copies to Courtroom Deputy Clerk.

Source text: The motion must specify which portions of the ruling are clearly erroneous or contrary to law and support the contention with points and authorities. Counsel shall deliver a conformed copy of the moving papers and responses to the Magistrate Judge’s Courtroom Deputy Clerk at the time of filing.

Parties must comply with Fed. R. Civ. P. 26(a) and produce discovery promptly.

Source text: The parties must comply fully with the letter and spirit of Fed. R. Civ. P. 26(a) and produce discovery promptly. At the Scheduling Conference, the court will impose deadlines governing the completion of discovery.

Notice of Motion must include compliance statement with Local Rule 7-3.

Source text: The Notice of Motion must include a statement of compliance with Local Rule 7-3. The court may strike or deny a motion if counsel fail to meet and confer in good faith.

Motions to amend require clean and redlined versions of proposed pleading.

Source text: In addition to the requirements of Local Rule 15-1, all motions to amend pleadings shall include “clean” and “redlined” versions of the proposed amended pleading, identifying all additions and deletions of material, as attachments to the moving papers.

All briefs must include Certificate of Compliance.

Source text: All submitted briefs must be accompanied by a Certificate of Compliance as set forth in Local Rule 11-6.2.

Only one summary judgment motion allowed per party.

Source text: No party may file more than one motion pursuant to Fed. R. Civ. P. 56 regardless of whether such motion is denominated a motion for summary judgment or otherwise.

LR 56-1 statements must use two-column table format with facts and supporting evidence.

Source text: The Separate Statement of Uncontroverted Facts required under Local Rule 56-1 shall be prepared in a two-column table, as shown below. The left-hand column sets forth the allegedly undisputed fact. The right-hand column sets forth the evidence that supports the factual statement.

LR 56-3 statements must use two-column format tracking movant's statement exactly.

Source text: The opposing party's Statement of Genuine Disputes of Material Fact must be in two columns and track the movant's separate statement exactly as prepared. The left-hand column must restate the allegedly undisputed fact and the right-hand column must state either that it is undisputed or disputed.

Proposed order required with evidentiary objections and emailed to chambers.

Source text: A proposed order shall be filed and attached to the evidentiary objections as a separate document consistent with Local Rule 52-4.1 and emailed in Word format directly to the court’s chambers email address at fla_chambers@cacd.uscourts.gov.

Motions for attorney’s fees require two tables summarizing hours and billing rates.

Source text: Motions for attorney’s fees shall be e-filed and set for hearing according to Local Rule 6-1 and this Order. Any motion or request for attorney’s fees shall attach two summaries, in table form, of the hours worked by and billing rate of each attorney with title (i.e., partner, counsel, associate, etc.).

First table must organize hours by attorney and task, with separate calculations for rate changes.

Source text: The first table shall include a summary of the hours worked by each attorney, organized by task (i.e., discovery, motion to dismiss, motion for summary judgment). If the hourly rate charged by any individual attorney changed while the action was ongoing, the party shall provide separate calculations for the total number of hours the attorney spent in connection with each task at each hourly rate.

Second table must organize hours by attorney, listing all tasks and rates.

Source text: The second table shall include a summary of the hours worked by each attorney, organized by attorney. This table shall list all the tasks on which the attorney worked, the hours worked on each task, and the hourly rate of each attorney.

Tables must be emailed to chambers as editable Excel files.

Source text: All tables shall be attached to the motion and electronically filed. The courtesy copy of the table shall be emailed to the court’s chambers email address at fla_chambers@cacd.uscourts.gov as a Microsoft Excel file with all restrictions removed so the spreadsheet can be edited.

Proposed orders required for all motions and emailed to chambers in Word format.

Source text: Each party filing or opposing a motion or seeking the determination of any matter shall serve and electronically lodge a proposed order setting forth the relief or action sought and a brief statement of the rationale for the decision with appropriate citations. In addition, a copy of the proposed order in Word format shall be emailed directly to the court’s chambers email address at fla_chambers@cacd.uscourts.gov on the day the document is e-filed.

Proposed orders must use court template and include all requested relief.

Source text: The parties must use the template for proposed orders available on Judge Aenlle-Rocha’s webpage. The proposed order must include the entire relief the parties seek. Failure to email a proposed order in Word format using the court’s template may result in the court striking the motion, application, or stipulation without consideration of the request on its merits.

Ex parte applications must comply with Local Rules 7-19 and 7-19.1; must include opposing counsel's position.

Source text: 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. The moving party shall serve the opposing party electronically, if possible. All parties registered for electronic service are sent a notification of ECF filing each time a document is e-filed with a link to the

All briefs must include Certificate of Compliance per Local Rule 11-6.2.

Source text: All submitted briefs must be accompanied by a Certificate of Compliance as set forth in Local Rule 11-6.2.

Motions to amend must include clean and redlined versions of proposed amended pleading as attachments.

Source text: In addition to the requirements of Local Rule 15-1, all motions to amend pleadings shall include 'clean' and 'redlined' versions of the proposed amended pleading, identifying all additions and deletions of material, as attachments to the moving papers.

Separate Statement of Uncontroverted Facts must use two-column table format with facts in left column and supporting evidence in right column.

Source text: The Separate Statement of Uncontroverted Facts required under Local Rule 56-1 shall be prepared in a two-column table, as shown below. The left-hand column sets forth the allegedly undisputed fact. The right-hand column sets forth the evidence that supports the factual statement.

Statement of Genuine Disputes must use two-column format tracking movant's statement exactly.

Source text: The opposing party's Statement of Genuine Disputes of Material Fact must be in two columns and track the movant's separate statement exactly as prepared. The left-hand column must restate the allegedly undisputed fact and the right-hand column must state either that it is undisputed or disputed.

Evidentiary objections must include a proposed order emailed in Word format to chambers.

Source text: A proposed order shall be filed and attached to the evidentiary objections as a separate document consistent with Local Rule 52-4.1 and emailed in Word format directly to the court's chambers email address at fla_chambers@cacd.uscourts.gov.

Attorney fee motions must attach two tables summarizing hours and billing rates by attorney.

Source text: Any motion or request for attorney's fees shall attach two summaries, in table form, of the hours worked by and billing rate of each attorney with title (i.e., partner, counsel, associate, etc.).

All motions must include a proposed order with relief sought and rationale.

Source text: Each party filing or opposing a motion or seeking the determination of any matter shall serve and electronically lodge a proposed order setting forth the relief or action sought and a brief statement of the rationale for the decision with appropriate citations.

Proposed orders in Word format must be emailed to chambers on the filing day.

Source text: In addition, a copy of the proposed order in Word format shall be emailed directly to the court's chambers email address at fla_chambers@cacd.uscourts.gov on the day the document is e-filed.

Proposed orders must use the court's template.

Source text: The parties must use the template for proposed orders available on Judge Aenlle-Rocha's webpage.

Ex parte applications must conform to Local Rules 7-19 and 7-19.1 and include opposing counsel's position.

Source text: 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.

Continuance/extension requests and stipulations must include a proposed order.

Source text: Counsel requesting a continuance or extension of time must file electronically a request or, if the parties are in agreement, a stipulation which sets forth the factual basis for the request for an extension of time. A proposed order in Word format must be emailed directly to the court's chambers email address at fla_chambers@cacd.uscourts.gov on the day the document is e-filed. The proposed order must include the entire relief the parties seek.

Counsel must use lectern and prepare visual aids in advance.

Source text: Counsel must use the lectern. Counsel should not consume jury time by writing out words and drawing charts or diagrams. All such aids must be prepared in advance.

Docket items only for specific defendants unless item applies to all.

Source text: All parties shall docket items only as to the particular defendant(s) to whom the item pertains, rather than all defendants, unless the item pertains to all. Except for documents filed under seal or in camera, every document shall be filed electronically in such a way that it is clear from the docketing entry to which defendant(s) it applies.

All briefs must include a Certificate of Compliance.

Source text: All submitted briefs must be accompanied by a Certificate of Compliance as set forth in Local Civil Rule 11-6.2.

Government must email trial documents to chambers one week before Final Pretrial Conference.

Source text: The government shall email copies of: (1) its witness list, (2) its exhibit list, (3) the joint jury instructions, (4) the joint proposed verdict form, and (5) proposed voir dire questions, including any amended documents, in Microsoft Word format to chambers at: FLA_Chambers@cacd.uscourts.gov, no later than one (1) week before the Final Pretrial Conference.

Government trial memorandum must include factual summary, charges/elements, time estimate, and legal discussion.

Source text: The government’s trial memorandum shall set forth: (i) a factual summary of the government’s case-in-chief; (ii) a statement of the charges and the elements of each charge; (iii) a time estimate of the length of the government’s case-in-chief, including anticipated cross-examination; and (iv) a discussion of relevant legal and evidentiary issues as applied to the facts of the particular case. The government shall specify, after a meet and confer, whether the parties agree or disagree on matters (i) through (iv).

Witness lists must follow Local Rule 16-5 format with testimony description, uniqueness, and time estimates.

Source text: Witness lists must identify all potential witnesses and must be in the format specified in Local Civil Rule 16-5. The lists must include for each witness: (i) a brief description of the testimony; (ii) the reasons the testimony is unique and not redundant; and (iii) a time estimate in hours for direct and cross-examination. The parties should use the template posted to Judge Aenlle-Rocha’s webpage. Any Amended Witness List must be filed by 12:00 p.m. (noon) on the Friday before trial and emailed to FLA_Chambers@cacd.uscourts.gov in Microsoft Word format.

Exhibit lists must follow Local Rule 16-6 format with objections column and sequential numbering.

Source text: Exhibit Lists must: (1) be in the format specified in Local Civil Rule 16-6; (2) include an additional column stating any objections to authenticity and/or admissibility; and (3) state the reasons for the objections. The parties should use the template posted to Judge Aenlle-Rocha’s webpage. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, 1.3, etc. See Local Civil Rule 16-6. The list should include defense exhibits to the extent the defense does not object to disclosure. Any Amended Exhibit List must be filed by 12:00 p.m. (noon) on the Friday before trial and emailed to FLA_Chambers@cacd.uscourts.gov in Microsoft Word format.

Parties must provide case-specific glossary for court reporter with technical terms, names, and terminology.

Source text: The parties must provide a case-specific glossary for the court reporter that includes applicable medical, scientific, or technical terms, gang terms, slang, the names and spellings of case names likely to be cited, street/city/country names, all parties/agents/departments/entities involved in the case, names of people interviewed/deposed, names of family members, friends, or others who might be mentioned, and other case-specific terminology.

Parties must file clean and redline sets of joint jury instructions with modifications and disputed language.

Source text: The parties shall file clean and redline sets of their (1) Joint Agreed Upon Proposed Jury Instructions, and (2) Disputed Jury Instructions. The redline sets shall include all modifications made by the parties to pattern or model jury instructions, any disputed language, and the factual or legal basis for each party’s position as to each disputed instruction.

Jury instructions must use Ninth Circuit model instructions when available, otherwise consult Federal Jury Practice and Instructions.

Source text: Sources: When possible, all instructions must be taken from the Manual of Model Criminal Jury Instructions for the Ninth Circuit (West Publishing Co., current edition). Where no applicable Ninth Circuit model instruction is available, counsel should consult the instructions from O’Malley, Grenig & Lee (formerly Devitt, et al.), Federal Jury Practice and Instructions (West Publishing Co., current edition). When submitting instructions other than Ninth Circuit model instructions, counsel should

Government must submit electronic exhibits on USB before trial; defense must submit at start of defense case.

Source text: The government must also submit to the court a USB flash drive containing electronic versions of all exhibits before trial begins. Defense counsel must provide a USB flash drive containing electronic versions of all exhibits at the start of the defense case, at the latest.

Exhibits cannot be shown to jurors before admission; electronic display allowed after admission.

Source text: The court does not permit exhibits to be "published" to the jurors before they are admitted into evidence. Once admitted, exhibits may be displayed electronically using the equipment and screens in the courtroom.

Opening statements must not discuss law or argue the case.

Source text: Counsel must not discuss the law or argue the case in opening statements.

Objections must be stated standing with grounds only; further argument requires sidebar permission.

Source text: When objecting, counsel must rise to state the objection and state only that counsel objects and the legal grounds for the objection. If counsel desires to argue an objection further, counsel must seek permission from the court to do so at sidebar or outside the jury's presence.

Counsel must not approach clerk, jury box, or witness stand without authorization.

Source text: Counsel must not approach the Courtroom Deputy Clerk, the jury box, or the witness stand without court authorization and must return to the lectern when the jury is present.

Counsel must rise when addressing court or when court/jury enters/leaves.

Source text: Counsel must rise when addressing the court and when the court or the jury enters or leaves the courtroom, unless directed otherwise.

All remarks must be addressed to the court, not to clerk, reporter, audience, or opposing counsel.

Source text: Counsel must address all remarks to the court. Counsel must not address the Courtroom Deputy Clerk, the court reporter, persons in the audience, or opposing counsel. Any request to re-read questions or answers shall be addressed to the court.

Counsel must not address witnesses/parties by first names alone, except minors under 14.

Source text: Counsel must not address or refer to witnesses or parties by first names alone, except for witnesses who are below age fourteen (14).

Stipulations require conference with opposing counsel, defendant's concurrence, and court approval.

Source text: Counsel must not offer a stipulation unless counsel have conferred with opposing counsel and have verified that the stipulation will be acceptable. Any stipulation of fact will require the defendant's personal concurrence and shall be submitted to the court in writing for approval. A proposed stipulation should be explained to the defendant in advance.

Counsel must remain at counsel table except when examining witnesses or presenting evidence.

Source text: Counsel must remain at counsel table throughout trial except to examine witnesses or as otherwise needed to present evidence. Counsel must not leave counsel table to sit in the gallery or confer with any person in the back of the courtroom without the court's permission.

Counsel must not make facial expressions or gestures showing agreement/disagreement with testimony or arguments.

Source text: Counsel must not make facial expressions, nod, shake their heads, comment, or otherwise exhibit in any way any agreement, disagreement, or other opinion or belief concerning the testimony of a witness or argument by opposing counsel. Counsel shall instruct their clients and witnesses not to engage in such conduct.

Counsel must never speak to jurors and must avoid conversations that can be overheard by jurors.

Source text: Counsel must never speak to jurors under any circumstance, and must not speak to co-counsel, opposing counsel, witnesses, or clients if the conversation can be overheard by jurors. Counsel must instruct their clients and witnesses to avoid such conduct.

Standing order must be served immediately on all parties by plaintiff's counsel or removing defendant.

Source text: Counsel for Plaintiff(s) shall serve this order immediately on all parties and/or their attorney(s), including any new parties to the action. If this action has been removed from the state court, the defendant who removed the action shall serve this order on all other parties.

Bluebook style required for case law citations with specific page references.

Source text: 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 for all citations with specific references.

Source text: 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. Citations to prior filings in the same action shall include the docket entry number, section, and pages referenced.

Motions to amend require clean and redlined versions of proposed pleading.

Source text: In addition to the requirements of Local Rule 15-1, all motions to amend pleadings shall include 'clean' and 'redlined' versions of the proposed amended pleading, identifying all additions and deletions of material, as attachments to the moving papers.

Only one summary judgment motion allowed per party.

Source text: No party may file more than one motion pursuant to Fed. R. Civ. P. 56 regardless of whether such motion is denominated a motion for summary judgment

Proposed order required with evidentiary objections and emailed to chambers.

Source text: A proposed order shall be filed and attached to the evidentiary objections as a separate document consistent with Local Rule 52-4.1 and emailed in Word format directly to the court’s chambers email address at fla_chambers@cacd.uscourts.gov.

Motions for attorney’s fees require two tables summarizing hours and billing rates.

Source text: Motions for attorney’s fees shall be e-filed and set for hearing according to Local Rule 6-1 and this Order. Any motion or request for attorney’s fees shall attach two summaries, in table form, of the hours worked by and billing rate of each attorney with title (i.e., partner, counsel, associate, etc.).

First table must organize hours by task and separate calculations if rates changed.

Source text: The first table shall include a summary of the hours worked by each attorney, organized by task (i.e., discovery, motion to dismiss, motion for summary judgment). If the hourly rate charged by any individual attorney changed while the action was ongoing, the party shall provide separate calculations for the total number of hours the attorney spent in connection with each task at each hourly rate.

Second table must organize hours by attorney with tasks, hours, and rates.

Source text: The second table shall include a summary of the hours worked by each attorney, organized by attorney. This table shall list all the tasks on which the attorney worked, the hours worked on each task, and the hourly rate of each attorney.

Proposed orders required with motions and emailed to chambers in Word format.

Source text: Each party filing or opposing a motion or seeking the determination of any matter shall serve and electronically lodge a proposed order setting forth the relief or action sought and a brief statement of the rationale for the decision with appropriate citations. In addition, a copy of the proposed order in Word format shall be emailed directly to the court’s chambers email address at fla_chambers@cacd.uscourts.gov on the day the document is e-filed.

Proposed orders must use court template and include all requested relief.

Source text: The parties must use the template for proposed orders available on Judge Aenlle-Rocha’s webpage. The proposed order must include the entire relief the parties seek. Failure to email a proposed order in Word format using the court’s template may result in the court striking the motion, application, or stipulation without consideration of the request on its merits.

All papers must include counsel's contact information (email, phone, fax).

Source text: Counsel must include on all papers his or her email address, telephone number, and facsimile number to facilitate communication with the Courtroom Deputy Clerk.

All motions must be noticed by their respective deadlines.

Source text: All motions must be noticed to be heard on or before their respective deadlines.

Discovery cut-off is when all discovery must be completed, not when requests must be served.

Source text: The cut-off date for discovery is not the date by which discovery requests must be served; it is the date by which all discovery, including all hearings on any related motions, must be completed.

Written discovery and depositions must begin early enough to allow time for motions to compel.

Source text: Thus, written discovery must be served and depositions must begin sufficiently in advance of the discovery cut-off date to permit the propounding party enough time to challenge responses deemed to be deficient via motion practice.

All expert disclosures must be made in writing.

Source text: All expert disclosures must be made in writing.

Proposed Final Pretrial Conference Order must be filed 14 days before FPTC using court-provided template.

Source text: The parties must file a proposed Final Pretrial Conference Order ("Proposed FPTCO") at least fourteen (14) days before the FPTC. A template for the Proposed FPTCO is available on Judge Aenlle-Rocha's webpage. The parties must use this template.

Witness lists must be filed 28 days before FPTC with specific content requirements.

Source text: Witness lists must be filed twenty-eight (28) days before the FPTC. They must be in the format specified in Local Rule 16-5, and must include for each witness (i) a brief description of the testimony, (ii) the reasons the testimony is unique and not redundant, and (iii) a time estimate in hours for direct and cross-examination.

Joint Exhibit List must be filed 28 days before FPTC with objection column.

Source text: The Joint Exhibit List must be filed twenty-eight (28) days before the FPTC. It must be in the format specified in Local Rule 16-6 and shall include an additional column stating any objections to authenticity and/or admissibility and the reasons for the objections.

Joint agreed jury instructions must be filed 14 days before FPTC.

Source text: Joint agreed upon proposed jury instructions must be filed no later than fourteen (14) days prior to the FPTC.

Parties must file clean and redline sets of jury instructions with disputed language and basis.

Source text: The parties shall file clean and “redline” sets of their (1) Joint Agreed Upon Proposed Jury Instructions, and (2) Disputed Jury Instructions. The “redline” sets shall include all modifications made by the parties to pattern or model jury instructions, any disputed language, and the factual or legal basis for each party’s position as to each disputed instruction.

Requested jury instructions must cite authority, be on separate pages, numbered, cover one subject, and not repeat other instructions.

Source text: Format: Each requested instruction shall: (1) cite the authority or source of the instruction, (2) be set forth in full, (3) be on a separate page, (4) be numbered, (5) cover only one subject or principle of law, and (6) not repeat principles of law contained in any other requested instruction.

Proposed jury instructions require a consecutively numbered joint index listing instructions in order.

Source text: Index: All proposed jury instructions must have a consecutively numbered joint index that lists the instructions in the order they will be given.

Joint index must include instruction number, title, source/citations, and page number for each instruction.

Source text: The joint index should include the following for each instruction, as illustrated in the example below:  the number of the instruction;  the title of the instruction;  the source of the instruction and any relevant case citations; and  the page number of the instruction.

Parties must file proposed joint general verdict form 14 days before FPTC.

Source text: The parties shall make every effort to agree on a general verdict form before submitting proposals to the court, and shall file a proposed joint general verdict form fourteen (14) days before the FPTC.

If no agreement on verdict form, file 'Competing Verdict Forms' with proposals, redlines, and legal basis.

Source text: If the parties are unable to agree on a verdict form, the parties shall file one document titled 'Competing Verdict Forms' which shall include: (i) the parties' respective proposed verdict form; (ii) a 'redline' of any disputed language; and (iii) the factual or legal basis for each party's respective position.

Proposed voir dire questions due 14 days before FPTC.

Source text: The parties may file any proposed case-specific voir dire questions for the court's consideration at least fourteen (14) days before the FPTC.

Proposed Findings of Fact and Conclusions of Law must be filed 28 days before FPTC in LR 52-3 format.

Source text: For any trial requiring findings of fact and conclusions of law, each party shall file and serve on the opposing party, no later than twenty-eight (28) days before the FPTC, its Proposed Findings of Fact and Conclusions of Law in the format specified in Local Rule 52-3.

Declarations of direct testimony must be filed 28 days before FPTC when ordered by court.

Source text: When ordered by the court in a particular case, each party shall, at least twenty-eight (28) days before the FPTC, file declarations containing the direct testimony of each witness whom that party intends to call at trial.

Evidentiary objections to declarations must be filed 14 days before FPTC in three-column format with verbatim quotes, legal objections, and space for court ruling.

Source text: If such declarations are filed, each party shall file any evidentiary objections to the declarations submitted by any other party at least fourteen (14) days before the FPTC. Such objections shall be submitted in the following three-column format: (i) the left column should contain a verbatim quote of each statement objected to (including page and line number); (ii) the middle column should set forth a concise legal objection (e.g., hearsay, lacks foundation, etc.) with a citation to the corresponding Federal Rule of Evidence or, where applicable, a case citation; and (iii) the right column should provide space for the court’s ruling on the objection.

USB flash drive with electronic exhibits required; Plaintiff and Defendant exhibits in separate folders with file names including exhibit number and description.

Source text: The parties must also submit to the court a USB flash drive containing electronic versions of all exhibits. Plaintiff’s exhibits must be placed in a separate folder from Defendant’s exhibits, and the document file names must include the exhibit number and a brief description of the document, for example: “Ex. 1 - Smith Declaration.pdf” or “Ex. 105 - Letter Dated 1-5-20.pdf.”

Rule 26(f) meeting must occur 21 days before scheduling conference, can be telephonic, written correspondence insufficient.

Source text: Pursuant to Federal Rules of Civil Procedure 16(b) and 26(f), the court will issue an Order Setting a Scheduling Conference. Counsel shall meet no later than twenty-one (21) days prior to the court-ordered Scheduling Conference pursuant to Federal Rule of Civil Procedure 26(f) and applicable Local Rules. This meeting may occur telephonically and need not occur in person. A written exchange of correspondence will not satisfy this requirement.

Joint Rule 26(f) Report due 14 days before scheduling conference; late/non-conforming reports may result in sanctions including dismissal.

Source text: Unless otherwise ordered, no later than fourteen (14) days before the Scheduling Conference, counsel shall file a Joint Rule 26(f) Report. A Joint Rule 26(f) Report which is not timely filed or does not conform with this Order, Federal Rule of Civil Procedure 26(f), and/or applicable Local Rules will interfere with preparation by the court and its staff and may result in the assessment of sanctions, including dismissal.

Discovery matters referred to Magistrate Judge; must include "DISCOVERY MATTER" in caption; no courtesy copies to Judge Slaughter.

Source text: All discovery matters have been referred to a Magistrate Judge, who will hear all discovery disputes. The Magistrate Judge’s initials follow the District Judge’s initials next to the case number. All discovery documents must include the words “DISCOVERY MATTER” in the caption to ensure proper routing. Please do not deliver courtesy copies of discovery documents to Judge Slaughter’s chambers.

Motion for review of Magistrate Judge's order must be filed within 14 days, specify clearly erroneous portions, and include supporting memorandum.

Source text: Any party may file and serve a motion for review and reconsideration before this court. See Local Rule 72-2. The moving party must file and serve the motion within fourteen (14) days of service of a written ruling or an oral ruling that the Magistrate Judge states will not be followed by a written ruling. The motion must specify which portions of the ruling are clearly erroneous and contrary to law, and the claim must be supported by a memorandum of points and authorities.

Notice of motion must include statement of compliance with Local Rule 7-3.

Source text: The notice of motion or other request must include a statement of compliance with Local Rule 7-3.

Court may strike, deny, or sanction motions if counsel fails to meet and confer in good faith.

Source text: The court may strike, outright deny a motion, or order other relief, including sanctions, if counsel fails to meet and confer in good faith.

Memoranda over 10 pages require Table of Authorities and Table of Contents.

Source text: Pursuant to Local Rule 11-8, all Memoranda of Points and Authorities exceeding ten (10) pages must be accompanied by a Table of Authorities and a Table of Contents.

Declarations, exhibits, and attachments must be filed as separately-docketed attachments with descriptions.

Source text: If a filed or lodged document has declarations, exhibits, or other attachments, each attachment must be filed as a separately-docketed attachment to the main docket entry with a description of the attachment (e.g., Dkt. 20-1 Declaration of Joe Smith; Dkt. 20-2 Ex. 1 - License Agreement; Dkt. 29-3 Evidentiary Objections).

Court may strike documents with improperly filed attachments.

Source text: The court may strike or decline to consider motions, stipulations, or other documents with attachments that are not filed in accordance with this Order.

Case law citations must include page numbers and follow Bluebook style.

Source text: Citations to Case Law 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 is required.

Statutory, treatise, and prior filing citations must be specific and follow Bluebook style.

Source text: 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. Citations to prior filings in the same action shall include the docket entry number, section, and pages referenced. Bluebook style is required.

AI-generated content requires separate disclosure declaration certifying accuracy and Rule 11 compliance.

Source text: Any party who uses generative artificial intelligence (such as ChatGPT, Harvey, CoCounsel, or Google Bard) to generate any portion of a motion, brief, pleading, or other filing must attach to the filing a separate declaration disclosing the use of artificial intelligence and certifying that the filer has reviewed the source material and verified that the artificially generated content is accurate and complies with the filer’s Rule 11 obligations.

Motions to amend must state effect, be serially numbered, and identify proposed changes.

Source text: In addition to the requirements of Local Rule 15-1, all motions to amend pleadings shall: (1) state the effect of the amendment; (2) be serially numbered to differentiate the amendment from previous amendments (i.e., “First Amended Complaint,” “Second Amended Complaint”); and (3) identify the pages, line numbers, and wording of any proposed change or addition of material.

Proposed amended pleading and redlined version must be filed separately with motion.

Source text: Counsel shall electronically file a “Notice of Lodging” attaching the proposed amended pleading as a document separate from the motion, as well as a “redlined” version of the proposed amended pleading identifying all additions and deletions of material as an appendix to the moving papers.

Motions for default judgment must show subject-matter and personal jurisdiction.

Source text: The motion must include a showing of both subject-matter and personal jurisdiction. See In re Tuli, 172 F.3d 707, 712 (9th Cir. 1999).

Attorney's fees request must be included with default judgment motion or subsequent requests will be struck.

Source text: A plaintiff who moves for default judgment and wishes to seek attorney’s fees and costs must include in the motion a properly supported request for attorney’s fees and costs together with the motion for default judgment. Failure to do so will result in the striking of any subsequent motion for attorney’s fees and costs absent a showing of good cause.

Compliance with Local Rules 56-1 and 56-2 required for summary judgment motions.

Source text: The parties shall comply with Local Rules 56-1 and 56-2, in addition to the court’s additional requirements described below.

Separate statements required for summary judgment motions per Local Rules 56-1-56-3.

Source text: The separate statement of uncontroverted facts, statement of genuine disputes of material fact, and response to statement of genuine disputes of material fact shall be prepared in accordance with Local Rules 56-1–56-3.

Only specific evidence necessary to support/controvert facts may be submitted.

Source text: No party shall submit evidence other than the specific items of evidence or testimony necessary to support or controvert a proposed statement of undisputed fact.

Evidence must be submitted as stipulations or declaration exhibits, not attached to briefs.

Source text: Evidence submitted in support of or in opposition to a motion for summary judgment should be submitted either by way of stipulation or as exhibits to declarations sufficient to authenticate the proffered evidence and should not be attached to the memorandum of points and authorities.

Proposed order required for evidentiary objections, emailed to chambers

Source text: A proposed order shall be filed and attached to the evidentiary objections as a separate document in Word-processing format consistent with Local Rule 52-4.1 and emailed directly to the court’s chambers email address at FWS_Chambers@cacd.uscourts.gov.

Proposed orders must be emailed to chambers in Word and PDF format

Source text: a Microsoft Word copy of the proposed document, along with a PDF copy of the electronically filed main document, shall be e-mailed to the assigned judge’s generic chambers e-mail address

Continuance requests must include declaration with reasons.

Source text: Requests for continuances must be by stipulation, motion, or ex parte application and must be accompanied by a declaration setting forth the reasons for the requested continuance.

Continuance declaration must include history of previous requests.

Source text: The declaration also should include whether there have been any previous requests for continuances and whether these requests were granted or denied by the court.

Court must approve stipulations extending court-set dates.

Source text: Stipulations extending dates set by this court are not effective unless approved by the court.

Include contact info on all papers.

Source text: Counsel must include on all papers their email address, telephone number, and fax number to facilitate communication with the Courtroom Deputy.

Trial date must be proposed within 18 months of complaint filing.

Source text: Absent a showing of good cause, the parties must propose a trial date that is within 18 months of the filing of the complaint.

ADR completion required before final pretrial conference or trial.

Source text: The court will not hold a final pretrial conference or convene any trial unless and until all parties, including the principals of all corporate parties, have completed ADR.

Plaintiff must serve Complaint under FRCP 4 and comply with Local Rule 5-3 for proofs of service.

Source text: The Plaintiff shall promptly serve the Complaint in accordance with Federal Rule of Civil Procedure 4 and shall comply with Local Rule 5-3 with respect to all proofs of service.

Lead trial counsel must attend all proceedings including status and settlement conferences.

Source text: Lead trial counsel shall attend any proceeding before this Court, including all status and settlement conferences.

Counsel must meet personally under FRCP 26(f) before court-ordered scheduling conference.

Source text: Counsel for the parties shall meet personally pursuant to Federal Rule of Civil Procedure 26(f) and applicable Local Rules in anticipation of the court-ordered scheduling conference.

Joint Rule 26(f) Report must be filed no later than 7 days before Scheduling Conference.

Source text: Unless otherwise ordered, no later than seven (7) days before the Scheduling Conference, counsel shall file a Joint Report of Rule 26(f) Meeting.

Memoranda over 10 pages require Table of Authorities and Table of Contents.

Source text: Pursuant to Local Rule 11-8, all Memoranda of Points and Authorities exceeding ten (10) pages must be accompanied by a Table of Authorities and a Table of Contents.

References to filed documents must include citations.

Source text: References to documents or evidence filed with the Court shall include a citation to the

Parties must identify adjudicative facts when requesting judicial notice under FRCP 201.

Source text: Requests for Judicial Notice: Parties requesting judicial notice shall identify the adjudicative fact(s) for which it seeks notice pursuant to Federal Rule of Civil Procedure 201.

Proposed orders required with motions; must include relief and rationale with citations.

Source text: Each party filing or opposing a motion or seeking the determination of any matter shall serve and lodge a Proposed Order setting forth the relief or action sought and a brief statement of the rationale for the decision with appropriate citations. A party objecting to evidence shall similarly lodge a Proposed Order setting forth the specific evidence and basis for the objection(s). All Proposed Orders shall be submitted via e-mail to

Ex parte applications only for extraordinary relief; must comply with LR 7-19.

Source text: Counsel are reminded ex parte applications are solely for extraordinary relief. Applications that do not meet the requirements set forth in Local Rules 7-19 will not be considered. The Court considers ex parte applications on the papers and usually does not set these matters for hearing.

Joint Rule 26(f) Report due 14 days before scheduling conference.

Source text: Unless otherwise ordered, no later than fourteen (14) days before the Scheduling Conference, counsel shall file a Joint Rule 26(f) Report.

Motion notice must include statement of compliance with Local Rule 7-3.

Source text: The notice of motion or other request must include a statement of compliance with Local Rule 7-3.

Briefs over 10 pages require Table of Authorities and Table of Contents.

Source text: Pursuant to Local Rule 11-8, all Memoranda of Points and Authorities exceeding ten (10) pages must be accompanied by a Table of Authorities and a Table of Contents.

Case law citations must include case name and specific page.

Source text: Citations to case law must identify the case cited and the specific page referenced.

Bluebook citation style is required.

Source text: Bluebook style is required.

Statutory citations must specify sections and subsections.

Source text: Statutory references must identify with specificity the sections and subsections referenced.

Citations to treatises must include volume, section, and pages.

Source text: Citations to treatises, manuals, and other materials should include the volume, section, and pages being referenced.

Citations to prior filings must include docket entry number, section, and pages.

Source text: Citations to prior filings in the same action shall include the docket entry number, section, and pages referenced.

Motions to amend pleadings must state effect, be serially numbered, and identify proposed changes with page/line numbers.

Source text: In addition to the requirements of Local Rule 15-1, all motions to amend pleadings shall: (1) state the effect of the amendment; (2) be serially numbered to differentiate the amendment from previous amendments; and (3) identify the pages, line numbers, and wording of any proposed change or addition of material.

Proposed amended pleading and redlined version must be filed separately as Notice of Lodging and appendix.

Source text: Counsel shall electronically file a “Notice of Lodging” attaching the proposed amended pleading as a document separate from the motion, as well as a “redlined” version of the proposed amended pleading identifying all additions and deletions of material as an appendix to the moving papers.

Statements of Uncontroverted Facts and Genuine Disputes must be submitted in Excel format with editing enabled and emailed to chambers.

Source text: Statements of Uncontroverted Facts and Genuine Disputes shall also be in Excel, have all restrictions removed so the spreadsheets can be edited, and be emailed to the Court’s chambers email address at HDV_Chambers@cacd.uscourts.gov.

Parties must submit Statements of Uncontroverted Facts and Genuine Disputes in Excel format with editing enabled and email to chambers.

Source text: Parties are required to also submit any Statements of Uncontroverted Facts and Genuine Disputes in Excel, have all restrictions removed so the spreadsheets can be edited, and be emailed to the Court’s chambers email address at HDV_Chambers@cacd.uscourts.gov.

Joint brief must include one separate, tabbed appendix of declarations and written evidence.

Source text: The joint brief shall be accompanied by one separate, tabbed appendix of declarations and written evidence (including documents, photographs, deposition excerpts, etc.). See Local Rule 7-6.

Joint brief and supporting materials must be submitted as one CM/ECF filing with each item as separate attachment.

Source text: The joint brief and its supporting materials shall be submitted as one CM/ECF filing, with each declaration or item of evidence submitted as a separate attachment to the CM/ECF filing.

Evidentiary appendix must include a table of contents.

Source text: The evidentiary appendix shall include a table of contents.

Only specific evidence necessary to support or controvert undisputed facts may be submitted.

Source text: No party shall submit evidence other than the specific items of evidence or testimony necessary to support or controvert a proposed statement of undisputed fact.

Evidence must be submitted by stipulation or as exhibits to declarations, not attached to memorandum.

Source text: Evidence submitted in support of or in opposition to a motion for summary judgment should be submitted either by way of stipulation or as exhibits to declarations sufficient to authenticate the proffered evidence and should not be attached to the memorandum of points and authorities.

Documentary evidence without stipulation must be accompanied by witness testimony establishing authenticity.

Source text: Documentary evidence for which there is no stipulation regarding foundation must be accompanied by the testimony, either by declaration or properly authenticated deposition transcript, of a witness who can establish authenticity.

Evidentiary objections must be stated in a separate two-column statement.

Source text: If a party disputes a fact based in whole or in part on an evidentiary objection, the ground for the objection should be stated succinctly in a separate statement of evidentiary objections in a two-column format.

Joint Proposed FPTCO must be filed and emailed to Chambers before pretrial conference.

Source text: A joint proposed Final Pretrial Conference Order ("Proposed FPTCO") shall be filed and emailed to Chambers at least pretrial conference.

Evidentiary objection statement must have left column identifying items and right column stating objections.

Source text: The left column should identify the items objected to (including page and line number if applicable) and the right column should set forth a concise objection (e.g., hearsay, lack of foundation).

Proposed orders must be emailed to chambers for evidentiary objections.

Source text: A proposed order shall be filed and attached to the evidentiary objections as a separate Word document consistent with Local Rule 52-4.1 and emailed directly to the Court’s chambers email address at HDV_Chambers@cacd.uscourts.gov.

Proposed orders required for all motions with rationale and citations.

Source text: Each party filing or opposing a motion or seeking the determination of any matter shall serve and electronically lodge a proposed order setting forth the relief or action sought and a brief statement of the rationale for the decision with appropriate citations.

All papers must include counsel's contact information (email, phone, fax).

Source text: Counsel must include on all papers their email address, telephone number, and fax number to facilitate communication with the Courtroom Deputy.

Proposed FPTCO must specify dismissed claims and claim-party relationships.

Source text: The parties must use this template. In specifying the surviving pleadings under section 1, the parties are to state which claims or counterclaims have been dismissed or abandoned (e.g., "Plaintiff's second cause of action for breach of fiduciary duty has been dismissed."). Additionally, in multiple-party cases where not all claims or counterclaims will be prosecuted against all remaining parties on the opposing side, the parties are to specify to which party or parties each claim or counterclaim is directed.

Triable issues must be stated in ultimate fact form, not evidentiary details.

Source text: The remaining triable issues of fact section on the Proposed FPTCO should track the elements of a claim or defense on which the jury will be required to make findings. Counsel should attempt to state issues in ultimate fact form, not in the form of evidentiary fact issues (i.e., "was the defendant negligent?"; "was such negligence the proximate cause of injury to the plaintiff?"; not, "was the defendant driving the vehicle west on Hill Street at 9:00 p.m. on January 1?"). Counsel may list sub-issues under the headings of ultimate fact issues, but shall not use this as a device to list disputes over evidentiary matters.

Legal issues must be stated for Court rulings, not ultimate fact issues.

Source text: Issues of law should state legal issues upon which the Court will be required to rule after the Pretrial Conference, including during the trial, and should not list ultimate fact issues to be submitted to the trier of fact.

Witness lists due 28 days before FPTC with specific content requirements.

Source text: Witness lists must be filed at least twenty-eight (28) days before the FPTC. They must be in the format specified in Local Rule 16-5, and must include for each witness (i) a brief description of the testimony, (ii) the reasons the testimony is unique and not redundant, and (iii) a time estimate in hours for direct and cross-examination.

Joint Exhibit List due 28 days before FPTC with objection columns.

Source text: The Joint Exhibit List must be filed at least twenty-eight (28) days before the FPTC. It must be in the format specified in Local Rule 16-6 and shall include an additional column stating any objections to authenticity and/or admissibility and the reasons for the objections.

Joint proposed jury instructions due 14 days before FPTC.

Source text: Joint proposed jury instructions must be filed no later than fourteen (14) days prior to the FPTC.

Clean and redline sets required for jury instructions with disputed language and legal basis.

Source text: The parties shall file clean and redline sets of their (i) Joint Agreed Upon Proposed Jury Instructions, and (ii) Disputed Jury Instructions. The redline sets shall include all modifications made by the parties to pattern or model jury instructions, any disputed language, and the factual or legal basis for each party’s position as to each disputed instruction.

Required sources for jury instructions: Ninth Circuit Manual, CACI, or O’Malley.

Source text: When the Manual of Model Jury Instructions for the Ninth Circuit provides an applicable jury instruction, the parties should submit the most recent version, modified and supplemented to fit the circumstances of the case. Where California law applies, the parties should submit the most recent version of the Judicial Council of California Civil Jury Instructions (CACI). If neither applies, the parties should consult the current edition of O’Malley, et al., Federal Jury Practice and Instructions.

Standard instructions with blanks/options must be completed by parties.

Source text: If a standard instruction has blanks or offers options, e.g., for gender, the parties must fill in the blanks or make the appropriate selections in their proposed instructions.

Index required for proposed instructions with number, title, source, and page number.

Source text: The Proposed Instructions must have an index that includes the following for each instruction, as illustrated in the example below: (1) the number of the instruction; (2) the title of the instruction; (3) the source of the instruction and any relevant case citations; and (4) the page number of the instruction.

Joint verdict form due 14 days before FPTC; competing forms require redline and legal basis.

Source text: The parties shall make every effort to agree on a general or special verdict form before submitting proposals to the court. The parties shall file a proposed joint general or special verdict form fourteen (14) days before the FPTC. If the parties are unable to agree on a verdict form, the parties shall file one document titled 'Competing Verdict Forms' which shall include: (i) the parties’ respective proposed verdict form; (ii) a 'redline' of any disputed language; and (iii) the factual or legal basis for each party’s respective position.

Joint Statement of the Case (max 1 page) due 14 days before FPTC for jury trials.

Source text: The parties must file a Joint Proposed Statement of the Case fourteen (14) days before the FPTC for the Court to read to the prospective jurors before commencement of voir dire. The joint statement should be brief and neutral and should not be more than one page in length.

Proposed Findings of Fact and Conclusions of Law due 28 days before FPTC for court trials.

Source text: For any trial requiring findings of fact and conclusions of law, each party shall file and serve on the opposing party, no later than twenty-eight (28) days before the FPTC, its Proposed Findings of Fact and Conclusions of Law in the format specified in Local Rule 52-3.

Declarations of Direct Testimony due 28 days before FPTC when ordered by Court.

Source text: When ordered by the Court in a particular case, each party shall, at least twenty-eight (28) days before the FPTC, file

Evidentiary objections to declarations due 14 days before FPTC in three-column format.

Source text: If such declarations are filed, each party shall file any evidentiary objections to the declarations submitted by any other party at least fourteen (14) days before the FPTC. Such objections shall be submitted in the following three-column format: (i) the left column should contain a verbatim quote of each statement objected to (including page and line number); (ii) the middle column should set forth a concise legal objection (e.g., hearsay, lacks foundation, etc.) with a citation to the corresponding Federal Rule of Evidence or, where applicable, a case citation; and (iii) the right column should provide space for the Court’s ruling on the objection.

Parties must meet and confer 10 days before trial to stipulate on exhibit foundation and best evidence rule waivers.

Source text: The parties must meet and confer at least ten (10) days before trial to stipulate as much as possible to foundation, waiver of the best evidence rule, and exhibits that may be received into evidence at the start of the trial.

Three sets of trial exhibits and deposition excerpts must be presented to Courtroom Deputy on first day of trial.

Source text: The parties must present the following materials to the Courtroom Deputy on the first day of trial: (1) the three sets of binders described above, with one original set of trial exhibits for the jury and two copies of trial exhibits for the court; and (2) any excerpts of deposition transcripts to be used at trial, either as evidence or for impeachment.

Court reporter must receive list of unusual words 7 days before trial commencement.

Source text: At least seven (7) days before the commencement of trial, counsel for the parties shall provide the court reporter with a list of unusual words, phrases, and spellings that may come up during trial.

Counsel must arrive at courtroom by 9:00 a.m. each trial day.

Source text: Counsel shall arrive at the Courtroom no later than 9:00 a.m. each day of trial.

Parties must meet and confer on all trial issues before seeking court ruling.

Source text: The parties must continue to meet and confer on all issues that arise during trial. The Court will not rule on any such issue unless the parties have attempted to resolve it first.

Objections must be stated standing with only legal grounds.

Source text: When objecting, counsel must rise to state the objection and state only that counsel objects and the legal grounds for the objection.

Post-trial briefs are only accepted if specifically authorized by court.

Source text: The Court will not accept posttrial briefs unless it finds that circumstances warrant additional briefing and such briefing is specifically authorized.

Time estimates required adjacent to caption for all motions and opposition briefs.

Source text: For all motions, counsel’s estimate of the time required for presentation of the motion must be set forth adjacent to the caption. Opposition briefs shall also set forth a time estimate.

Government must comply with discovery rules and promptly disclose Brady material and electronic surveillance/informant information.

Source text: Counsel for the government and counsel for the defendant shall comply promptly with discovery and notice pursuant to Federal Rules of Criminal Procedure 12, 12.1, 12.2, 12.3, 15 and 16. Upon government counsel's discovery of any evidence within the scope of Brady v. Maryland, 373 U.S. 83 (1963), such evidence shall be produced forthwith to counsel for the defendant. Counsel for the government shall also disclose to counsel for the defendant the existence or non-existence of: (1) evidence obtained by electronic surveillance; and (2) testimony by a government informant.

Government must provide 5 copies of witness/exhibit lists and 3 sets of exhibit binders on first day of trial.

Source text: No later than the first day of trial, Government counsel shall provide the CRD with the following: a. Five copies of the government's witness list; b. Five copies of the government's exhibit list; c. Binders containing the government's original exhibits, separated by divider tabs containing exhibit numbers. Specifically, counsel must deliver two sets for the Court (one for the bench and one for the witness stand (which will be submitted to the jury after trial)), and a set for defense counsel.

Government must provide witness-specific exhibit binders (3 copies each) before each witness testifies.

Source text: Additionally, before each witness takes the stand, Government counsel shall provide the CRD with: d. A separate binder for each witness that contains only those exhibits the government expects to use when examining each witness. Specifically, counsel must provide a copy for the witness, a copy for the Court, and a copy for defense counsel. The witness binders will not be provided to the jury.

Special voir dire questions must be filed 4 court days before trial.

Source text: At least four (4) court days prior to trial, each counsel shall file and serve on opposing counsel any special questions requested to be put to prospective jurors by the Court during voir dire. Counsel will be given a brief period of time, usually approximately ten to fifteen minutes, to ask follow-up questions of the prospective jurors.

Summary of indictment must be filed 4 court days before trial if indictment reading is inappropriate.

Source text: In any case in which reading the entire indictment to the jury during voir dire would be inappropriate, at least four (4) court days prior to trial, the parties shall file a summary of the indictment that may be read by the Court in lieu of the indictment. The summary should be agreed upon by all parties. If the parties cannot agree on a summary of the indictment, they should advise the Court in a joint filing.

Joint jury instructions and verdict form must be submitted 1 week before trial.

Source text: In a jury trial, no later than one (1) week before trial, counsel shall submit JOINT jury instructions and a JOINT proposed verdict form (if a special verdict is desired). In order to prepare these joint documents, counsel shall meet and confer sufficiently in advance of the required submission date with the goal of agreeing upon instructions and a verdict form. The instructions should be submitted in the order in which the parties wish to have the instructions read. This order should reflect a single organized sequence agreed to by all of the parties.

Disputed jury instructions must be separately identified.

Source text: The jury instructions shall be submitted as follows: b. Instructions propounded by the government to which the defendant(s) objects; and c. Instructions propounded by defendant(s) to which the government objects.

Jury instructions must include attribution and case citations.

Source text: Attribution and case citation for each instruction should be placed on pages following a proposed instruction. For disputed instructions, a party should note its objections to a proposed instruction and its reasons for putting forth its alternative on pages placed after its own alternative instruction.

New sentencing materials must be filed and served 2 weeks before sentencing hearing.

Source text: If a defendant is convicted, the sentencing proceedings will be conducted pursuant to Federal Rule of Criminal Procedure 32 and the Local Rules. If any party wishes to present material to the Court which has (a) not been previously filed with the Court or presented at trial, or (b) not been previously provided to the opposing party and the assigned United States Probation Officer, such party must file and serve the information or evidence no later than two (2) weeks before the scheduled sentencing hearing.

Sentencing position statements must be filed and served 2 weeks before sentencing hearing.

Source text: Notwithstanding the foregoing, a statement of each party’s position concerning sentencing shall be filed and served no later than two (2) weeks before the sentencing hearing, and the proof of service shall reflect service on the assigned United States Probation Officer. Timely filing is important to enable the Probation Officer sufficient time to prepare and disclose any addendum to the...

Proposed Order must be emailed to chambers in proper format.

Source text: Email a Proposed Order (in proper format) to the chambers' email address.