Central District of California Document Format Requirements

Case citations must use Bluebook format with pinpoint citations.

Citations to cases must be in Bluebook format and must include pinpoint citations (citations to page numbers).

Citations must appear in the body, not footnotes.

Citations must be in the body of a memorandum, not in the footnotes.

Motion papers must use Times New Roman 14pt or Courier 12pt font.

Typeface must comply with Local Rule 11-3.1.1. Times New Roman font must be at least 14 point; Courier font must be at least 12 point.

Margins

1 in

Format

PDF

Use brackets to mark relevant portions of transcripts; unmarked transcripts will be disregarded.

Counsel must use brackets to mark the relevant portions of transcripts. The Court will disregard unmarked transcripts.

Each proposed amended pleading must be serially numbered to distinguish it from prior amended pleadings.

The proposed amended pleading shall be serially numbered to differentiate it from previously amended pleadings.

The Local Rule 56-1 Separate Statement of Uncontroverted Facts must be formatted in two columns.

The Separate Statement of Uncontroverted Facts required under Local Rule 56-1 shall be prepared in a two-column format.

The opposing party’s Statement of Genuine Disputes must use a two-column format and exactly track the movant’s separate statement.

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.

Under-seal chambers copies must be grouped together in a manila envelope labeled “UNDER SEAL.”

Chambers copies of under seal documents shall all be placed together in a manila envelope labeled "UNDER SEAL."

Separate Statement of Uncontroverted Facts must use two-column format with fact and supporting evidence.

The Separate Statement of Uncontroverted Facts required under Local Rule 56-1 shall be prepared in a two-column format. The left-hand column sets forth the allegedly undisputed fact. The right-hand column sets forth the evidence that supports the factual statement.

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

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.

Times New Roman 14pt or Courier 12pt font required for motions.

Typeface must comply with Local Rule 11-3.1.1. Times New Roman font must be at least 14 point; Courier font must be at least 12 point.

Case citations must use Bluebook format with pinpoint citations.

Citations to cases must be in Bluebook format and must include pinpoint citations (citations to page numbers). Counsel may omit parallel citations. For unreported cases, the Court prefers Westlaw citations.

Statutory citations must follow Bluebook and specify sections/subsections.

Statutes should be cited in accordance with the Bluebook. Statutory references should identify with specificity the sections and subsections referenced (e.g., “Plaintiff alleges that Defendant infringed on his trademark in violation of the Lanham Act, 15 U.S.C. § 1114(a).”) Avoid statutory citations that do not specifically indicate the appropriate section and subsection

Required

Always

Pretrial documents must be delivered binder-ready with specific formatting.

Copies of all pretrial documents must be delivered to the Court "binder-ready" (three-hole punched on the left side, without blue-backs, and stapled only in the top left corner).

Counsel must use brackets to mark relevant portions of transcripts or the Court will disregard them.

Counsel must use brackets to mark the relevant portions of transcripts. The Court will disregard unmarked transcripts.

Required

Always

Format

DOCX

Email submissions to Chambers must be in Word format

All emailed submissions to Chambers referred to in this Order must be in Word format and emailed to AH_Chambers@cacd.uscourts.gov.

Format

DOCX

Trial filings must be emailed in Word format to chambers.

All trial filings must be filed as well as emailed in Word version to the chambers email box at AH_Chambers@cacd.uscourts.gov.

Format

DOCX

Email pretrial documents to chambers in Word format; deliver chambers copies to Judge Hwang's mailbox

All pretrial documents listed above, including any amended documents, shall be filed and emailed to Chambers the day set forth in the schedule that they are due. Except for motions in limine and oppositions, the Joint Status Report Regarding Settlement, and Declarations containing direct testimony, Counsel shall email all of the above, including any amended documents, in Microsoft Word format to AH_Chambers@cacd.uscourts.gov. Mandatory Chambers Copies of electronically filed pretrial documents shall be delivered to Judge Hwang's mailbox outside the Clerk's Office on the fourth floor of the First Street Courthouse.

Each jury instruction must cite authority, be on separate page, numbered, cover one subject, and not repeat.

Each requested instruction shall (i) cite the authority or source of the instruction; (ii) be set forth in full; (iii) be on a separate page; (iv) be numbered; (v) cover only one subject or principle of law; and (vi) not repeat.

Three-ring binders required for trial exhibits (1 original + 2 copies)

Trial exhibits that consistent of documents and photographs must be submitted to the Court in three-ring binders. The parties shall submit to the Court three (3) sets of binders: one (1) original set of trial exhibits and two (2) copies of trial exhibits.

Exhibits must be indexed with tabs and numbered sequentially

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc.

All pages of multi-page exhibits must be numbered; no duplicate exhibit numbers

Every page of a multi-page exhibit must be numbered. Defendant’s exhibit numbers shall not duplicate plaintiff’s numbers.

Original exhibits require official yellow (plaintiff) or blue (defendant) tags

The original exhibits shall bear the official exhibit tags (yellow tags for plaintiff’s exhibits and blue tags for defendant’s exhibits)

Copy exhibits must have copies of original tags and be indexed with tabs

The copies of exhibits must bear copies of the official exhibit tags that were placed on the original exhibits and be indexed with tabs or dividers on the right side.

PDF exhibits must be in separate folders by party with specific naming convention

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.”

Format

PDF

Electronic filing required in PDF format; pro se may use EDSS

Items that do not require the Court’s signature shall be e-filed in PDF format. Pro se litigants may submit documents for filing through the Court’s Electronic Document Submission System (“EDSS”) instead of mailing or bringing documents to the Clerk’s Office.

Required font is 14-point Times New Roman.

Typeface and spacing shall comply with Local Rule 11-3.1.1, except that the parties are required to use only 14-point Times New Roman font.

Footnotes must use same font and size as body text.

Footnotes shall be in the same font and the same size as the body of the memorandum.

Format

PDF

All documents must be converted to PDF format and be text searchable.

Counsel shall adhere to Local Rule 5-4.3 with respect to the conversion of all documents to PDF format so that when a document is electronically filed, it is in proper size and is text searchable.

Format

PDF

Filed documents must allow text selection, copying, and pasting.

Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document.

Case citations must include specific page and use Bluebook format.

Citations to case law must identify not only the case cited, but the specific page referenced. Citations to cases must be in Bluebook format.

Each JAE exhibit must be bookmarked with exhibit number and brief description.

Each exhibit within the JAE must be bookmarked; the bookmark should include the exhibit number and a brief description of the exhibit (e.g., Ex. 1 – Jones Depo. Excerpts).

Citations to JAE must reference page and line within the specific exhibit.

Citations to the JAE shall be to the page and line within the particular exhibit.

Required

Always

Caption titles must include defendant names based on applicability to all or specific defendants.

The caption title of every pleading shall contain the name of the first-listed defendant if the pleading applies to all defendants. If the document applies only to certain defendants, the caption shall list the name of the first defendant followed by the name(s) and number(s) of the remaining defendants involved (in the order listed on the docket). In an effort to create a docket that is clear and that can be searched easily, the title of every pleading shall include the name of the defendant(s) to which it refers. However, if the pleading applies to all defendants or if there is only a single defendant, the name(s) of the defendant(s) do not need appear in the title.

Required

Always

Format

PDF

All filings must be e-filed in PDF format; pro se defendants may use EDSS system.

Counsel shall electronically file (“e-file”) all filings pursuant to the Central District’s Local Rules and General Orders concerning electronic filing, unless superseded by this Order. Items that do not require the Court’s signature shall be e-filed in PDF format. Pro se defendants may submit documents for filing through the Court’s Electronic Document Submission System (“EDSS”) instead of mailing or bringing documents to the Clerk’s Office. Only internet access and an email address are required. Documents are submitted in PDF format through an online portal on the Court’s website. To access EDSS and for additional information, visit the Court’s website at https://apps.cacd.uscourts.gov/edss.

Required

Always

Exhibits must be in labeled binders with case name, party, and volume number.

The exhibits shall be presented in a binder. Each binder shall be clearly labeled on the spine to include the case name, party and volume umber.

Required

Always

Exhibits must be Bates stamped and separated with numbered dividers.

The Court does not require specific exhibit tags so long as each document is Bates stamped and separated with a divider that is numbered.

Required

Always

Parties must use different number sequences and comply with Local Civil Rule 26-3.

Each party shall use a different number sequence and shall comply with Local Civil Rule 26-3.

Required

Always

Format

DOCX

Emailed submissions to Chambers must be in Word format.

All emailed submissions to Chambers referred to in this Order must be in Word format and emailed to AH_Chambers@cacd.uscourts.gov.

Trial exhibits must be submitted in three-ring binders with 3 sets (1 original, 2 copies), indexed with tabs, sequentially numbered, pages numbered, spine labeled with volume and exhibit range.

Trial exhibits that consist of documents and photographs must be submitted to the Court in three-ring binders. The parties shall submit to the Court three (3) sets of binders: one (1) original set of trial exhibits and two (2) copies of trial exhibits. The original set of exhibits shall be for use by the jury during its deliberations, and the copies are for the Court. The parties should prepare additional copies of exhibits for their own use and for use by witnesses. The parties must review the exhibit list and exhibit binders with the CRD before the admitted exhibits will be given to the jury. All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc. See Local Rule 16-6. Every page of a multi-page exhibit must be numbered. Defendant’s exhibit numbers shall not duplicate plaintiff’s numbers. The spine of each binder shall indicate the volume number and the range of exhibit numbers included in the volume.

Original trial exhibits must have official exhibit tags (yellow for plaintiff, blue for defendant) stapled to upper right corner with case info.

The original exhibits shall bear the official exhibit tags (yellow tags for plaintiff’s exhibits and blue tags for defendant’s exhibits) stapled to the front of the exhibit on the upper right corner with the case number, case name, and exhibit number placed on each tag. Tags may be obtained from the Clerk’s Office, or the parties may print their own exhibit tags using Forms G-14A and G-14B on the “Court Forms” section of the Court’s website.

Format

DOCX

Emailed submissions to Chambers must be in Word file format.

All emailed submissions to Chambers referred to in this Order must be in Word format and emailed to AH_Chambers@cacd.uscourts.gov.

Trial exhibits must be submitted in three-ring binders, with three sets total (one original for the jury and two copies for the Court).

Trial exhibits that consistent of documents and photographs must be submitted to the Court in three-ring binders. The parties shall submit to the Court three (3) sets of binders: one (1) original set of trial exhibits and two (2) copies of trial exhibits.

Required

Always

Times New Roman 14pt or Courier 12pt required; footnotes same size as body text.

Pursuant to Local Rule 11-3.1.1, either a proportionally spaced or monospaced face may be used. Typeface shall comply with Local Rule 11-3.1.1. Times New Roman font must be no less than 14 point; Courier font must be no less than 12 point. Footnotes shall be in the same font and the same size as the body of the memorandum.

Required

Always

Format

PDF

All documents must be converted to searchable PDF format with selectable text.

Counsel shall adhere to Local Rule 5-4.3 with respect to the conversion of all documents to .pdf format so that when a document is electronically filed, it is in proper size and is .pdf searchable. Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document.

Required

Always

Bluebook style required; case citations must include specific page numbers.

Bluebook style is required. Citations to case law must identify not only the case cited, but the specific page referenced. For example, if a quotation is presented, the associated page citation shall be provided. Similarly, if a case is cited in support of a proposition based on language in the opinion, the page on which such language appears shall be provided.

Required

Always

Bluebook style required; statutory citations must specify sections/subsections; other sources need volume, section, and pages.

Bluebook style is required. Statutory references must identify with specificity the sections and subsections referenced. Citations to treatises, manuals, and other materials should include the volume, section, and pages being referenced.

Required

Always

Format

PDF

All filings must be electronically filed in PDF format; proposed orders attached to main documents.

Pursuant to Fed. R. Civ. P. 5(d)(3), L.R. 5-4, and General Order 10-07, counsel shall electronically file (“e-file”) all filings. Items that do not require the Court’s signature shall be e-filed in .pdf format. Proposed orders shall be e-filed in .pdf format as an attachment to the main documents.

Required

Always

Every filing must include specific caption requirements: defendant names/numbers, registration number when applicable, and milestone dates.

The captioned title of every filing shall contain: a. the name of the first-listed defendant as well as the name(s) and number(s) (in the order listed in the Indictment) of the particular defendant(s) to whom the filing applies, unless the document applies to all defendants; b. the individual defendant’s registration number when applicable to the relief requested (e.g., requests for transfer, medical requests); and c. the milestone dates for Indictment, Final Pretrial Conference, Trial, and Last Day of the speedy trial period.

Required

Always

Font requirements: Times New Roman 14pt or Courier 12pt minimum, footnotes same size as body text.

Pursuant to Local Civil Rule 11-3.1.1, either a proportionally spaced or monospaced face may be used. Typeface shall comply with Local Civil Rule 11-3.1.1. Times New Roman font must be no less than fourteen (14) point, and Courier font must be no less than twelve (12) point. Footnotes shall be in the same font and the same size as the text in the body of the document.

Each jury instruction must cite authority, be on separate page, numbered, cover one subject, and not repeat other instructions.

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.

Trial exhibits must be submitted in three-ring binders with one original set for jury and two copies for the Court.

Trial exhibits that consist of documents and photographs must be submitted to the Court in three-ring binders. The parties shall submit to the Court three sets of binders: one (1) original set of trial exhibits, and two (2) copies of trial exhibits. The original set of exhibits shall be for use by the jury during its deliberations, and the two copies are for the Court.

Exhibits must be indexed with tabs, numbered sequentially, and defendant's numbers must not duplicate government's.

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc. See Local Civil Rule 16-6. Every page of a multi-page exhibit must be numbered. Defendant’s exhibit numbers shall not duplicate the government’s numbers.

Binder spines must indicate volume number and exhibit number range.

The spine of each binder shall indicate the volume number and the range of exhibit numbers included in the volume.

Enlargements must use original number plus 'A' and require agreement or court ruling before use.

An enlargement of an existing exhibit shall use the original exhibit number followed by an “A.” Counsel shall not attempt to display or use any charts or enlargements of exhibits unless all counsel have agreed to their use or objections have been heard and a ruling has been made by the Court.

Original exhibits must have official yellow (government) or blue (defendant) tags with case info.

The original exhibits shall bear the official exhibit tags (yellow tags for the government’s exhibits and blue tags for defendant’s exhibits) affixed to the front upper right-hand corner of the exhibit, with the case number, case name, and exhibit number stated on each tag.

Copy exhibits must have copies of official tags and be indexed with tabs.

The copy of exhibits must bear copies of the official exhibit tags that were placed on the original exhibits and be indexed with tabs or dividers on the right side.

Format

PDF

Defense must provide USB with electronic exhibits at start of defense case with numbered filenames.

Defense counsel must provide a USB flash drive containing electronic versions of all exhibits at the start of the defense case, at the latest. The document file names should 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.”

Format

FLASH_DRIVE

Audio/video/digital evidence must be on flash drive and only contain admitted evidence.

Audio, video files, and digital evidence must be contained on a flash drive, unless otherwise directed by the Court. The party introducing the evidence is responsible for ensuring that the flash drive contains only admitted evidence.

Transcripts must use original exhibit number plus 'A' and are not admitted into evidence.

The transcripts shall use the original exhibit number of the audio recording followed by an “A” for identification purposes. The transcripts will not be admitted into evidence and should be collected after the audio recording has been played.

Required

Always

Specific formatting requirements for each jury instruction.

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.

Exhibit numbering and indexing requirements for three-ring binders

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc. See Local Rule 16-6. Every page of a multi-page exhibit must be numbered. Defendant's exhibit numbers shall not duplicate Plaintiff's numbers. The spine of each binder shall indicate the volume number and the range of exhibit numbers included in the volume.

Format

USB_FLASH_DRIVE

Electronic exhibit submission required on USB flash drive with specific naming convention

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.'

Margins

1 in

Counsel must use lectern; demonstrative aids must be prepared in advance.

Counsel must use the lectern. Counsel should not consume jury time drawing or writing; all demonstrative aids must be prepared fully in advance of the day's trial session. Counsel should not ask witnesses to draw charts or diagrams or ask the Court's permission for a witness to do so.

Black ink for plaintiff, blue ink for defendant for all deposition markings.

For all depositions offered in the case, the parties shall consistently use different colored ink—black for plaintiff and blue for defendant—for designations, counter-designations, objections, and responses to objections.

Each party is limited to a maximum of eight footnotes in MSJ joint briefs.

Each party is limited to the use of a total of eight footnotes.

Required

Always

Times New Roman font must be at least 14 point, Courier font at least 12 point; footnotes must match body font and size; typeface must comply with Local Civil Rule 11-3.1.1.

Pursuant to Local Civil Rule 11-3.1.1, either a proportionally spaced or monospaced face may be used. Typeface shall comply with Local Civil Rule 11-3.1.1. Times New Roman font must be no less than fourteen (14) point, and Courier font must be no less than twelve (12) point. Footnotes shall be in the same font and the same size as the text in the body of the document.

Proposed orders must not include attorney information on the caption page, footer information except pagination, or watermarks/firm designations.

Do not include: (a) any attorney information on the caption page; (b) any information in the footer (except pagination); or (c) any watermark or firm designation anywhere.

Defense counsel must bring a hard copy of the fully signed plea agreement to the Rule 11 hearing.

Defense counsel shall bring a hard copy of the fully signed plea agreement to the hearing (because the Court will refer the defendant to specific portions of the

Format

DOCX

Required Final Pretrial Conference documents must be submitted in Microsoft Word format.

No later than one (1) week before the Final Pretrial Conference, the government shall file and email the documents described below in Microsoft Word format to CV_Chambers@cacd.uscourts.gov:

Format

DOCX

Amended witness lists must be submitted in Microsoft Word format.

Any Amended Witness List must be filed by 5:00 p.m. on the Friday before trial and emailed to CV_Chambers@cacd.uscourts.gov in Microsoft Word format.

Format

DOCX

Amended exhibit lists must be submitted in Microsoft Word format.

Any Amended Exhibit List must be filed by 5:00 p.m. on the Friday before trial and emailed to CV_Chambers@cacd.uscourts.gov in Microsoft Word format.

Jury instructions must cite authority, be set forth in full, on separate page, numbered, cover one subject, and not repeat principles.

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.

Format

DOCX

Jury instructions must be a clean set in Microsoft Word format, with only the text of each instruction, captioned 'Court’s Instruction No. ___'.

Accordingly, counsel must email CV_Chambers@cacd.uscourts.gov a “clean” set of all instructions in Microsoft Word format, containing only the text of each instruction, set forth in full on each page, with the caption “Court’s Instruction No. ___” (eliminating the title and source of the instruction, supporting authority, etc.).

Format

DOCX

Defense witness and exhibit lists emailed to Chambers must be in Microsoft Word format.

Defense counsel shall also simultaneously email CV_Chambers@cacd.uscourts.gov a Microsoft Word version of the defense witness list and defense exhibit list.

Trial exhibits consisting of documents or photographs must be submitted in three-ring binders, with 1 original and 2 copy sets provided to the court.

Trial exhibits that consist of documents and photographs must be submitted to the Court in three-ring binders. The parties shall submit to the Court three sets of binders: one (1) original set of trial exhibits, and two (2) copies of trial exhibits.

Exhibits in three-ring binders must be indexed with right-side tabs, numbered sequentially, have all pages of multi-page exhibits numbered, avoid duplicate exhibit numbers between parties, and binder spines must show volume and exhibit range.

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc. See Local Civil Rule 16-6. Every page of a multi-page exhibit must be numbered. Defendant’s exhibit numbers shall not duplicate the government’s numbers. The spine of each binder shall indicate the volume number and the range of exhibit numbers included in the volume.

Enlargements of existing exhibits must be numbered with the original exhibit number followed by an 'A'.

An enlargement of an existing exhibit shall use the original exhibit number followed by an “A.”

Original trial exhibits must have official color-coded exhibit tags affixed to the front upper right corner with required case information; copy exhibits must have tag copies and right-side indexing.

The original exhibits shall bear the official exhibit tags (yellow tags for the government’s exhibits and blue tags for defendant’s exhibits) affixed to the front upper right-hand corner of the exhibit, with the case number, case name, and exhibit number stated on each tag. The copy of exhibits must bear copies of the official exhibit tags that were placed on the original exhibits and be indexed with tabs or dividers on the right side.

Defense counsel must submit a USB flash drive with electronic versions of all exhibits at the start of the defense case, at the latest.

Defense counsel must provide a USB flash drive containing electronic versions of all exhibits at the start of the defense case, at the latest.

Audio, video, and digital evidence must be stored on a flash drive unless the Court directs otherwise.

Audio, video files, and digital evidence must be contained on a flash drive, unless otherwise directed by the Court.

Party introducing audio, video, or digital evidence must ensure the flash drive only contains admitted evidence.

The party introducing the evidence is responsible for ensuring that the flash drive contains only admitted evidence.

Transcripts of audio recording exhibits must be numbered with the original exhibit number followed by an 'A'.

The transcripts shall use the original exhibit number of the audio recording followed by an “A” for identification purposes.

Memoranda must use Times New Roman (≥14pt) or Courier (≥12pt) font, with footnotes matching the body font and size.

Pursuant to Local Rule 11-3.1.1, either a proportionally spaced or monospaced face may be used. Typeface shall comply with Local Rule 11-3.1.1. Times New Roman font must be no less than 14 point; Courier font must be no less than 12 point. Footnotes shall be in the same font and the same size as the body of the memorandum.

Required

Always

Format

PDF

All documents must be filed as searchable PDF with selectable, copyable, and pasteable text per Local Rule 5-4.3 and 5-4.3.1.

Counsel shall adhere to Local Rule 5-4.3 with respect to the conversion of all documents to .pdf format so that when a document is electronically filed, it is in proper size and is .pdf searchable. Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document. See Local Rule 5-4.3.1.

Required

Always

Format

PDF

E-filed items that do not require the Court’s signature must be submitted in PDF format.

Items that do not require the Court’s signature shall be e-filed in .pdf format.

Format

PDF

Proposed orders must be e-filed in PDF format as an attachment to the main filing document.

Proposed orders shall be e-filed in .pdf format as an attachment to the main documents.

Required

Always

Format

PDF

Documents submitted via the EDSS online portal must be in PDF format.

Documents are submitted in .pdf format through an online portal on the Court’s website.

Attachments to filed or lodged documents must be separately docketed with a description; non-compliant documents may be struck.

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 - License Agreement, 29-3 Request for Judicial Notice). The Court may strike or decline to consider motions, stipulations, or other documents with attachments that are not filed in accordance with this Order.

Proposed orders must use the court’s template and include all relief sought by the parties; failure to comply may result in the motion being struck.

The parties must use the template for proposed orders available on Judge Valenzuela’s Procedures and Schedules page on the Court’s website. The proposed order must include the entire relief the parties seek.

Mandatory chambers copies must comply with Local Rule 11-3, do not need to be blue-backed, and must be labeled MANDATORY CHAMBERS COPY on the face page.

A mandatory chambers copy must comply with Local Rule 11-3 (i.e., font size, page numbering, exhibit tabbing, etc.) but need not be blue-backed. The mandatory chambers copy must be prominently labeled MANDATORY CHAMBERS COPY on the face page.

JAF must use the specified table format with columns for SUF number, fact, supporting evidence, and defendant's response.

The table below illustrates the format that must be used. Fact Supporting Def.’s Response SUF No. Evidence Issue No. 1. Plaintiff’s Claim for Breach of Contract is Barred by the Statute of Limitations. 1. Witness 1and Witness 3 Decl. ¶ 5, Disputed. Witness 2 Witness 2 signed a Ex. 6. testified that the contract contract for the was for a lease, not a sale and purchase purchase. Witness 2 Depo. of property. 29:4-8, Ex. 1. 2. Witness 2 mailed Witness 3 Decl. ¶ 8, Disputed in Part. Witness the contract in Ex. 21. 2 testified she mailed the May 2017. contract in January 2017. Witness 2 Depo. 3:4-6, Ex. 1.

Applies to

Joint appendix of evidence

JAE must be a tabbed appendix.

The joint brief shall be accompanied by a JAE—i.e., a separate, tabbed appendix of all evidence in support of or opposition to the MSJ, including declarations, deposition excerpts, documents, photographs, etc.

Applies to

Joint appendix of evidence

Format

PDF

JAE must be filed as a single combined PDF; multiple PDFs allowed only for file size constraints, each must be titled by part and exhibit series.

The JAE shall be filed as a single, combined PDF; more than one PDF may be filed if file-size constraints preclude filing the JAE as a single PDF. In the event multiple PDFs are necessary to file the JAE, each file shall be titled by part and exhibit series (e.g., JAE Part 1, Exhibits 1–50).

Applies to

Exhibit

Each JAE exhibit must be bookmarked with the exhibit number and a brief description.

Each exhibit within the JAE must be bookmarked; the bookmark should include the exhibit number and a brief description of the exhibit (e.g., Ex. 1 – Jones Depo. Excerpts).

JAO must follow specified table format with Objector, Evidence, and Objection/Response columns; non-compliance waives objections, blanket objections are overruled.

Objector Evidence Objection (O)/Response (R) Plaintiff 1. “Witness 2 mailed the O: Lacks foundation. contract in May 2017.” (Witness R: Witness 1 saw Witness 2 mail it. 1 Decl. ¶ 8.) (Party 1 Decl. ¶ 8.) Failure to comply with this formatting requirement will result in a waiver of the objections. Blanket or boilerplate objections will be overruled and disregarded.

JAO objections and responses must be brief, limited to evidence admissibility, and exclude substantive legal arguments.

The parties’ objections and responses in the JAO shall be brief and strictly limited to the admissibility of the evidence. No substantive legal arguments will be permitted. If an evidentiary dispute is dispositive of a claim or argument, it should be addressed in the briefing on that claim or argument.

Format

DOCX

Proposed FPTCO must be emailed to chambers in Microsoft Word (DOCX) format.

The parties shall email the Proposed FPTCO in Microsoft Word format to chambers at CV_Chambers@cacd.uscourts.gov.

Witness lists must follow Local Rule 16-5 format, include required witness details, and use the judge’s template.

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. The parties should use the template posted to Judge Valenzuela’s webpage.

Joint exhibit lists must follow Local Rule 16-6 format, include an objections column, and use the judge’s template.

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. The parties should use the template posted to Judge Valenzuela’s webpage.

Format

DOCX

Parties must email specified trial documents to chambers in Microsoft Word format the day they are due.

The parties shall email copies of: (1) the Witness Lists, (2) the Joint Exhibit List, (3) the Joint Proposed FPTCO, (4) the Joint Agreed Upon Proposed Jury Instructions, (5) the Disputed Proposed Jury Instructions, (6) Joint Proposed Verdict Forms, and (7) Proposed Voir Dire Questions, including any amended documents, in Microsoft Word format to chambers the day they are due to Chambers at: CV_Chambers@cacd.uscourts.gov.

Jury instructions must use specified sources: Ninth Circuit Model, CACI, or O'Malley.

Sources: 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 use the current edition 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.

Each jury instruction must cite authority, be full text, on separate page, numbered, cover one subject, and not repeat other instructions.

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 must include a consecutively numbered joint index.

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

Trial exhibits consisting of documents or photographs must be submitted in three-ring binders (3 sets: 1 original for jury deliberation, 2 copies for the Court); voluminous exhibits may use electronic tablets instead of binders.

Trial exhibits that consist of documents and photographs must be submitted to the Court in three-ring binders. The parties shall submit to the Court three (3) sets of binders: one (1) original set of trial exhibits, and two (2) copies of trial exhibits. The original set of exhibits shall be for use by the jury during its deliberations, and the copies are for the Court. In the event the exhibits are voluminous, the parties should consider the use of electronic tablets for the Court and the witnesses thereby avoiding the need for binders.

Exhibits in three-ring binders must be indexed with right-side tabs, sequentially numbered, have no duplicate defendant/plaintiff exhibit numbers, binder spines labeled with volume and exhibit range, and multi-page exhibits must have numbered pages.

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc. See Local Rule 16-6. Every page of a multi-page exhibit must be numbered. Defendant’s exhibit numbers shall not duplicate Plaintiff’s numbers. The spine of each binder shall indicate the volume number and the range of exhibit numbers included in the volume.

Parties must bracket deposition testimony they intend to offer in margins of original transcript; opposing party must counter-designate intended testimony in margins.

Identify on the original transcript the testimony the party intends to offer by bracketing the questions and answers in the margins. The opposing party shall likewise counter-designate any testimony it plans to offer.

Objections to proffered deposition evidence must be noted in margins of deposition transcript with ground for objection and response.

Identify any objections to the proffered evidence in the margins of the deposition by briefly providing the ground for the objection and the response to the objection.

Parties must use black ink (plaintiff) and blue ink (defendant) for deposition designations, counter-designations, objections, and responses.

For all depositions offered in the case, the parties shall consistently use different colored ink—black for plaintiff and blue for defendant—for designations, counter-designations, objections, and responses to objections.

Each deposition must include an index behind the first page identifying pages with designations or counter-designations.

Provide an index for each deposition, placed behind the first page of the deposition, identifying each page that contains a designation or counter-designation.

Parties must provide an electronic copy of deposition designations, counter-designations, and objections to the CRD.

Provide to the CRD an electronic copy of the above materials, including all designations, counter-designations, and objections.

Required

Always

Counsel must refer to exhibits by exhibit number when referencing them, and should instruct witnesses to do the same.

When referring to an exhibit, counsel must refer to its exhibit number. Counsel should instruct their witnesses to do the same.

Margins

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Summary judgment moving party must use two-column format for uncontroverted facts.

The uncontroverted facts shall be set forth in a two column format. The left hand column shall set forth the allegedly undisputed fact. The right hand column shall set forth the evidence that supports the factual statement. The fact statements shall be set forth in sequentially numbered rows. Each cell should contain a narrowly focused statement of fact, and address a single subject in as concise a manner as possible.

Margins

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Opposing party's statement must use two-column format tracking moving party's facts.

The first part of the opposing party’s Statement of Genuine Disputes shall track the moving party’s Statement of Uncontroverted Facts. It shall be set forth in a two column format. The left hand column shall restate the allegedly undisputed fact and supporting evidence, and the right hand column shall state either that the fact is undisputed or disputed. The opposing party may dispute all or only a portion of the allegedly undisputed fact, but if disputing only a portion, the opposing party must specify clearly what portion is being disputed.

Margins

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Opposing party may add additional facts in two-column format with sequential numbering.

The opposing party may also specify additional material facts that bear on or relate to the issues raised by the moving party, which shall follow the same two column format described above for the moving party’s Statement of Uncontroverted Facts. These additional facts shall continue in sequentially numbered paragraphs (i.e., if the moving party’s last allegedly undisputed fact was set forth as ¶ 30, then the first new allegedly undisputed fact specified by the opposing party shall be set forth as ¶ 31).

Evidence must be organized with tabs, indices, and highlighting for easy court access.

Evidence in support of or in opposition to a motion shall be presented to the Court in a way that makes it easy for the Court to find cited evidence. For instance, the parties should make generous use of tabs and indices for hard copies of exhibits. The parties should highlight the testimony or portions of exhibits on which they are relying.

Required

Always

Margins

1 in

Format

PDF

Proposed FPTCO must follow format in Appendix A to Local Rules.

The form of the proposed Final Pretrial Conference Order shall be in conformity with the format set forth in Appendix A to Local Rules.

Margins

1 in

Exhibits must be in loose leaf binders with tabs and marked spine.

All exhibits will be placed in loose leaf binders which are tabbed down the right side with exhibit numbers. The spine of the binder is to be marked with the case name and number and the numbers of the exhibits contained therein.

Required

Always

Moving party's Statement of Uncontroverted Facts must use a two-column format with sequentially numbered rows, each cell addressing a single subject concisely.

The uncontroverted facts shall be set forth in a two column format. The left hand column shall set forth the allegedly undisputed fact. The right hand column shall set forth the evidence that supports the factual statement. The fact statements shall be set forth in sequentially numbered rows. Each cell should contain a narrowly focused statement of fact, and address a single subject in as concise a manner as possible.

Required

Always

Opposing party's Statement of Genuine Disputes must use a two-column format tracking the moving party's SUF, with left column restating fact and evidence and right column indicating disputed or undisputed.

The first part of the opposing party’s Statement of Genuine Disputes shall track the moving party’s Statement of Uncontroverted Facts. It shall be set forth in a two column format. The left hand column shall restate the allegedly undisputed fact and supporting evidence, and the right hand column shall state either that the fact is undisputed or disputed.

Required

Always

Moving party's reply must respond to additional facts using the same two-column format as the opposing party's SGD.

The moving party, in its reply, shall respond to the additional allegedly undisputed facts in the same manner and format that the opposing party is required to adhere to in responding to the moving party’s Statement of Uncontroverted Facts, as described above.

Times New Roman minimum 14pt, Courier minimum 12pt.

Pursuant to Local Rule 11-3.1.1, either a proportionally spaced or monospaced face may be used. Typeface shall comply with Local Rule 11-3.1.1. Times New Roman font must be no less than fourteen (14) point, and Courier font must be no less than twelve (12) point.

Footnotes must match body font and size.

Footnotes shall be in the same font and the same size as the body of the memorandum.

Format

PDF

All documents must be converted to .pdf for e-filing.

Counsel shall adhere to Local Rule 5-4.3 with respect to the conversion of all documents to .pdf so that when a document is e-filed, it is in the proper size, is

Required

Always

Times New Roman 14pt or Courier 12pt required; footnotes same size as body text.

Pursuant to Local Civil Rule 11-3.1.1, either a proportionally spaced or monospaced face may be used. Typeface shall comply with Local Civil Rule 11- 3.1.1. Times New Roman font must be no less than fourteen (14) point, and Courier font must be no less than twelve (12) point. Footnotes shall be in the same font and the same size as the text in the body of the document.

Required

Always

Margins

0 in

Trial exhibits must be submitted in three-ring binders with 1 original set for jury and 2 copies for court.

Trial exhibits that consist of documents and photographs must be submitted to the court in three-ring binders. The parties shall submit to the court three sets of binders: one (1) original set of trial exhibits, and two (2) copies of trial exhibits. The original set of exhibits shall be for use by the jury during its deliberations, and the two copies are for the court.

Required

Always

Margins

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Exhibits must be indexed with tabs, numbered sequentially, and defendant's numbers must not duplicate government's.

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc. See Local Civil Rule 16-6. Every page of a multi-page exhibit must be numbered. Defendant's exhibit numbers shall not duplicate the government's numbers.

Required

Always

Binder spines must indicate volume number.

The spine of each binder shall indicate the volume number

Required

Always

Original exhibits require official yellow/blue tags; copies must have duplicate tags and tabs.

The original exhibits shall bear the official exhibit tags (yellow tags for the government's exhibits and blue tags for defendant's exhibits) affixed to the front upper right-hand corner of the exhibit, with the case number, case name, and exhibit number stated on each tag. The copy of exhibits must bear copies of the official exhibit tags that were placed on the original exhibits and be indexed with tabs or dividers on the right side.

Required

Always

Electronic exhibit file names must include exhibit number and brief description.

The document file names should 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."

Font requirements: Times New Roman 14pt or Courier 12pt; footnotes same size as body.

Pursuant to Local Rule 11-3.1.1, either a proportionally spaced or monospaced face may be used. Typeface shall comply with Local Rule 11-3.1.1. Times New Roman font must be no less than fourteen (14) point, and Courier font must be no less than twelve (12) point. Footnotes shall be in the same font and the same size as the body of the memorandum.

Format

PDF

All documents must be converted to .pdf format for e-filing.

Counsel shall adhere to Local Rule 5-4.3 with respect to the conversion of all documents to .pdf so that when a document is e-filed, it is in the proper size, is

Trial exhibits must be submitted in three-ring binders, with three sets: one original and two copies.

Trial exhibits that consist of documents and photographs must be submitted to the court in three-ring binders. The parties shall submit to the court three (3) sets of binders: one (1) original set of trial exhibits, and two (2) copies of trial exhibits.

Format

DOCX

Proposed FPTCO must be emailed to chambers in Microsoft Word format.

The parties shall email the Proposed FPTCO in Microsoft Word format to chambers at FLA_Chambers@cacd.uscourts.gov.

Format

DOCX

Multiple trial documents must be emailed to chambers in Microsoft Word format by the due date.

The parties shall email copies of: (1) the Witness Lists, (2) the Joint Exhibit List, (3) the Joint Proposed FPTCO, (4) the Joint Agreed Upon Proposed Jury Instructions, (5) the Disputed Proposed Jury Instructions, (6) Joint Proposed Verdict Forms, and (7) Proposed Voir Dire Questions, including any amended documents, in Microsoft Word format to chambers the day they are due at: FLA_Chambers@cacd.uscourts.gov.

Margins

1 in

Trial exhibits must be submitted in three-ring binders with 1 original set and 2 copies.

Trial exhibits that consist of documents and photographs must be submitted to the court in three-ring binders. The parties shall submit to the court three (3) sets of binders: one (1) original set of trial exhibits, and two (2) copies of trial exhibits.

Margins

1 in

Exhibits must be indexed with right-side tabs, numbered sequentially (1, 2, 3), with every page numbered and no duplicate numbers between parties.

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc. See Local Rule 16-6. Every page of a multi-page exhibit must be numbered. Defendant’s exhibit numbers shall not duplicate Plaintiff’s numbers.

Binder spines must indicate volume number and exhibit number range.

The spine of each binder shall indicate the volume number and the range of exhibit numbers included in the volume.

Original exhibits must have official yellow (Plaintiff) or blue (Defendant) tags with case number, name, and exhibit number.

The original exhibits shall bear the official exhibit tags (yellow tags for Plaintiff’s exhibits and blue tags for Defendant’s exhibits) affixed to the front upper right-hand corner of the exhibit, with the case number, case name, and exhibit number stated on each tag.

Copy exhibits must have copies of official tags and be indexed with right-side tabs.

The copies of exhibits must bear copies of the official exhibit tags that were placed on the original exhibits and be indexed with tabs or dividers on the right side.

Exhibit binders must be three-ring with indexed tabs, sequential numbering, page numbering, no duplicate numbers, and spine labeling.

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc. See Local Rule 16-6. Every page of a multi-page exhibit must be numbered. Defendant’s exhibit numbers shall not duplicate Plaintiff’s numbers. The spine of each binder shall indicate the volume number and the range of exhibit numbers included in the volume.

Original exhibits must have official exhibit tags with case info; copies must have copy tags and be indexed.

The original exhibits shall bear the official exhibit tags (yellow tags for Plaintiff’s exhibits and blue tags for Defendant’s exhibits) affixed to the front upper right-hand corner of the exhibit, with the case number, case name, and exhibit number stated on each tag. Tags may be obtained from the Clerk’s Office, or the parties may print their own exhibit tags using Forms G-14A and G-14B on the “Court Forms” section of the court’s website at: https://www.cacd.uscourts.gov/forms/exhibit-tags-plaintiff-g-14a-defendant-g-14b-joint-g-14c. The copies of exhibits must bear copies of the official exhibit tags that were placed on the original exhibits and be indexed with tabs or dividers on the right side.

Trial exhibits must be bound in three-ring binders indexed by exhibit number with right-side tabs or dividers, and the binder spine must display the volume number and an index of all exhibits in the volume.

Exhibits must be placed in three-ring binders indexed by exhibit number with tabs or dividers on the right side. The spine portion of the binder shall indicate the volume number and contain an index of each exhibit included in the volume.

Exhibit tags must be stapled to the upper right corner of each exhibit, include the case number, case name, and exhibit number, with plaintiff required to use yellow tags and defendant required to use blue tags.

Plaintiff shall use yellow tags and defendant shall use blue tags. The tags shall be stapled to the upper right-hand corner of each exhibit with the case number, case name, and exhibit number placed on each tag.

Trial exhibits must be numbered sequentially (1, 2, 3, etc.), not with decimal sub-numbers, and defense exhibit numbers cannot duplicate plaintiff’s exhibit numbers.

Exhibits shall be numbered 1, 2, 3, etc., not 1.1, 1.2, 1.3, etc. The defense exhibit numbers shall not duplicate plaintiff’s numbers.

Blow-up enlargements of existing trial exhibits must be designated with the original exhibit number followed by an “A”.

Counsel shall designate any “blow-up” enlargement of an existing exhibit with the number of the original exhibit followed by an “A.”

Documentary evidence supporting or opposing a motion over 50 pages must be bound, tabbed, and indexed; evidence over 300 pages must be in a three-ring binder with tab dividers, and counsel must provide an OCR-scanned PDF on a flash drive with labeled bookmarks.

If documentary evidence in support of or in opposition to a motion exceeds 50 pages, the evidence must be separately bound and tabbed and include an index. If such evidence exceeds 300 pages, the documents shall be placed in a three-ring binder, with an index and with each item of evidence separated by a tab divider on the right side. In addition, counsel shall provide a flash drive of the documents in a single, OCR-scanned,.pdf file with each item of evidence separated by labeled bookmarks. Counsel shall ensure that all documents are legible.

All briefing must use Times New Roman, 14-point font (including footnotes).

All briefing must use Times New Roman font. Text must be no less than fourteen (14) point font; footnotes shall be in the same font and the same size as the body of the memorandum.

Required

Always

Format

PDF

All documents must be converted to searchable PDF format with selectable text.

Counsel shall adhere to Local Rule 5-4.3 with respect to the conversion of all documents to .pdf format so that when a document is electronically filed, it is in proper size and is .pdf searchable. Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document.

All documents must be text-searchable (OCR’d).

All documents—including pleadings, motions, and exhibits—submitted to the court must be text-searchable (i.e., “OCR’d”).

Format

PAPER

Sealed documents must be filed electronically only in public/non-sealed civil cases; criminal cases and fully sealed cases require paper filing; pro se parties cannot e-file sealed documents.

Note that the new rules require electronic filing only in PUBLIC/NON-SEALED CIVIL CASES. For now, continue to file sealed documents in criminal cases in paper, or as otherwise directed by your assigned judge’s standing orders. Likewise, continue to file all documents in paper in any case in which the entire case is under seal. And note that pro se parties who have been granted permission to file documents electronically must nonetheless continue to file sealed documents in paper; the CM/ECF system does not allow pro se parties to e-file sealed documents.

Format

PAPER

Pro se parties cannot e-file sealed documents even if they have electronic filing permission.

And note that pro se parties who have been granted permission to file documents electronically must nonetheless continue to file sealed documents in paper; the CM/ECF system does not allow pro se parties to e-file sealed documents.

All briefing must use Times New Roman font, minimum 14 point size, including footnotes.

All briefing must use Times New Roman font. Text must be no less than fourteen (14) point font; footnotes shall be in the same font and the same size as the body of the memorandum.

Format

PDF

All documents submitted to the court must be text-searchable (OCR'd), with text selectable, copyable, and pasteable.

Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document. See Local Rule 5-4.3.1. All documents−including pleadings, motions, and exhibits−submitted to the court must be text-searchable (i.e., “OCR’d”).

Format

DOCX

Proposed orders accompanying evidentiary objections must be in Word-processing format.

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.

Evidentiary objections must be submitted in a two-column format with specified content in each column.

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. 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, etc.) with a citation to the Federal Rules of Evidence or, where applicable, a case citation.

Excel tables accompanying attorney fees motions must be editable.

copies of the tables shall be prepared in Excel, have all restrictions removed so the spreadsheets can be edited, and be emailed to the court’s chambers email address at FWS_Chambers@cacd.uscourts.gov.

Required

Always

All papers must include counsel's email address, telephone number, and fax number.

Counsel must include on all papers their email address, telephone number, and fax number to facilitate communication with the Courtroom Deputy.

Briefing must use Times New Roman or Courier font, 12pt text, 10pt footnotes.

All briefing must use Times New Roman or Courier font. Text must be no less than twelve (12) point font; footnotes shall be no less than ten (10) point font and shall be used sparingly.

Format

PDF

All documents must be converted to text-searchable PDF format.

Counsel shall adhere to Local Rule 5-4.3 with respect to the conversion of all documents to PDF format so that when a document is electronically filed, it is in proper size and is text-searchable.

Filed documents must allow text selection, copying, and pasting.

Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document.

Format requirements for jury instructions: cite source, full text, separate page, numbered, single subject, no repetition.

Each requested instruction shall (i) cite the authority or source of the instruction; (ii) be set forth in full; (iii) be on a separate page; (iv) be numbered; (v) cover only one subject or principle of law; and (vi) not repeat principles of law contained in any other requested instruction.

Counsel must use lectern and prepare all visual aids in advance.

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.

Exhibits must have official tags and internal pagination.

All exhibits presented to the Court by either side shall have the Court’s official exhibit tags attached to the lower right-hand corner of the first page of each exhibit. All exhibits longer than one page shall be internally paginated in the lower right-hand corner.

Briefing must use Times New Roman or Courier font (12 pt text, 10 pt footnotes).

All briefing must use Times New Roman or Courier font. Text must be no less than twelve (12) point font; footnotes shall be no less than ten (10) point font and shall be used sparingly.

Format

PDF

All documents must be converted to searchable PDF format with selectable text.

Counsel shall adhere to Local Rule 5-4.3 with respect to the conversion of all documents to PDF format so that when a document is electronically filed, it is in proper size and is text-searchable. Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document. See Local Rule 5-4.3.1.

Format

EXCEL

Statements of Uncontroverted Facts and Genuine Disputes must be submitted in Excel format with editing enabled and emailed to chambers.

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.

Format

EXCEL

Parties must submit Statements of Uncontroverted Facts and Genuine Disputes in Excel format with editing enabled and email to chambers.

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.

Required

Always

Format

PDF

Non-signature items must be e-filed in PDF; proposed signature items as PDF attachments.

All non-signature items shall be e-filed in PDF format. All proposed signature items shall be e-filed as an attachment to the main document in PDF format.

Required

Always

Format

WORD

Proposed signature items must be emailed to chambers in Word format.

All proposed signature items shall be emailed to the Courtroom Deputy Clerk's email address at HDV_Chambers@cacd.uscourts.gov in Word format.

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

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. If a standard instruction has blanks or offers options (e.g., for gender or pronouns), the parties must fill in the blanks or make the appropriate selections in their proposed instructions.

Required

Always

Original exhibits require official yellow/blue tags with case info.

The original exhibits shall bear the official exhibit tags (yellow tags for the government’s exhibits and blue tags for the defendant’s exhibits) affixed to the front upper right-hand corner of the exhibit, with the case number, case name, and exhibit number stated on each tag. Tags may be obtained from the Clerk’s Office, or the parties may print their own exhibit tags using Forms G-14A and G-14B on the “Court Forms” section of the Central District of California’s website.

Trial exhibits must be in three-ring binders; submit 3 sets (1 original for jury, 2 copies for Court).

Trial exhibits that consist of documents and photographs must be submitted to the Court in three-ring binders. The parties shall submit to the Court three (3) sets of binders: one (1) original set of trial exhibits, and two (2) copies of trial exhibits. The original set of exhibits shall be for use by the jury during its deliberations, and the copies are for the Court.

Required

Always

Each witness requires a three-ring binder with tabbed exhibits.

For each witness, counsel should provide a three-ring binder containing a copy of each exhibit to be used with that witness. Each exhibit in the witness binder shall be tabbed with the exhibit number for easy reference.

Required

Always

Exhibits must be sequentially numbered, tabbed, and indexed in three-ring binders.

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc. Every page of a multi-page exhibit must be numbered. Defendant’s exhibit numbers shall not duplicate the government’s numbers. The spine of each binder shall indicate the volume number and the range of exhibit numbers included in the volume.

Required

Always

Copies of exhibits must have copied official tags and be tabbed.

The copies of exhibits must bear copies of the official exhibit tags that were placed on the original exhibits and be indexed with tabs or dividers on the right side.

Required

Always

Margins

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First trial day: 8:30 AM - 5:00 PM with breaks; parties must appear at 8:30 AM for preliminary matters.

The first day of trial will commence promptly at 8:30 a.m. and conclude at approximately 5:00 p.m., with a one-hour lunch break and two fifteen-minute breaks. The parties must appear at 8:30 a.m. to discuss preliminary matters with the Court.

Required

Always

Margins

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Trial days are Monday-Wednesday and Friday; no trial on Thursdays unless jury deliberating or calendar permits.

Thursdays are usually reserved for the Court's calendar. As a result, trial will not be held on Thursdays unless the jury is deliberating or the Court's calendar allows trial to proceed. Therefore, trial days are generally Monday through Wednesday, and on Friday.

Required

Always

Margins

1 in

Raise matters outside jury presence at 8:30 AM, breaks, or end of day; avoid lengthy sidebars.

All counsel must anticipate matters that may need to be addressed outside of the presence of the jury and raise them at 8:30 a.m., during breaks, or at the end of the day. Unless absolutely necessary, the Court will not entertain lengthy sidebars or attorney conferences during the trial that require the jury to wait.

Required

Always

Margins

1 in

Parties must meet and confer on all trial issues before seeking Court ruling.

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.

Required

Always

Margins

1 in

Counsel must use lectern; visual aids must be prepared in advance.

Counsel must use the lectern. All visual aids must be prepared in advance.

Required

Always

Margins

1 in

No speaking objections, speeches, restating testimony, or guiding witnesses before jury.

Counsel must not make speaking objections before the jury or otherwise make speeches, restate testimony, or attempt to guide a witness.

Required

Always

Margins

1 in

When objecting, counsel must rise and state only objection and legal grounds.

When objecting, counsel must rise to state the objection and state only that counsel objects and the legal grounds for the objection (e.g., "Objection, hearsay").

Required

Always

Margins

1 in

Counsel must seek Court permission to argue objections.

If counsel wishes to argue an objection, counsel must seek permission from the Court to do so.

Each instruction must cite authority, be complete, on separate page, numbered, cover one subject, and not repeat.

Each requested instruction shall (i) cite the authority or source of the instruction; (ii) be set forth in full; (iii) be on a separate page; (iv) be numbered; (v) cover only one subject or principle of law; and (vi) not repeat principles of law contained in any other requested instruction.

Standard instructions with blanks must be completed by parties.

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.

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

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.

Exhibits in binders must be indexed with tabs/dividers on right side.

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side.

Exhibits must be numbered sequentially (1, 2, 3, etc.).

Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc.

Defendant's exhibit numbers must not duplicate plaintiff's numbers.

Defendant’s exhibit numbers shall not duplicate plaintiff’s numbers.

Original exhibits must have official yellow (plaintiff) or blue (defendant) tags with case info.

The original exhibits shall bear the official exhibit tags (yellow tags for plaintiff’s exhibits and blue tags for defendant’s exhibits) stapled to the front of the exhibit on the upper right corner with the case number, case name, and exhibit number placed on each tag.

Copy exhibits must have copies of official tags and be indexed with tabs/dividers.

The copies of exhibits must bear copies of the official exhibit tags that were placed on the original exhibits and be indexed with tabs or dividers on the right side.

Required

Always

Format

PAPER

When technical failure prevents e-filing, submit paper copies: original and judge's copy in separate sealed envelopes with title page attached, plus a PDF copy on CD.

If you cannot file a sealed document electronically due to a technical failure of CM/ECF, you must file it in paper pursuant to L.R. 5-4.6.2. The original and the judge’s copy of all such documents must be submitted for filing in separate sealed envelopes, with a copy of the title page attached to the front of each envelope. An additional copy must be provided in PDF format on a CD. L.R. 79-5.2.

Required

Always

Format

PDF

Mandatory electronic filing implemented January 1, 2008.

As of January 1, 2008, the United States District Court for the Central District of California implemented mandatory electronic filing ("e-filing") of documents

Chambers copies must comply with L.R. 11-3 formatting requirements.

All chambers copies shall comply fully with the document formatting requirements of L.R. 11-3, including the 'backing' and 'tabbing' requirements of Local Rules 11-3.5 and 11-5.3,

Margins

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Documentary evidence over 50 pages must be bound/tabbed with index; over 200 pages requires binder with tab dividers.

If documentary evidence in support of or in opposition to a motion exceeds 50 pages, the evidence must be separately bound and tabbed and include an index. If such evidence exceeds 200 pages, the documents shall be placed in a binder, with an index and with each item of evidence separated by a tab divider.

Required

Always

Format

PDF

Electronically filed documents must be created by publishing to PDF, not by scanning paper.

The Court specifically directs litigants to L.R. 5-4.3.1, requiring that all electronically filed documents be created by publishing the document to PDF, and not by scanning paper documents.

Evidentiary objections to SUF must use a three-column format with fact number, item description, and concise objection.

The evidentiary objections should be presented in a three-column format and include the following columns: i. The first column shall contain the number of the fact objected to, using the numbering submitted in the moving party's SUF if applicable. ii. The second column shall identify the item objected to, including its page and line number if applicable. iii. The third column shall set forth a concise objection (e.g., hearsay, lacks foundation,

Required

Always

Format

PDF

Mandatory electronic filing implemented January 1, 2008.

As of January 1, 2008, the United States District Court for the Central District of California implemented mandatory electronic filing ("e-filing") of documents

Required

Always

Exhibits must be in 3-ring binders with tabs, numbered per Local Rule 26-3, with original for Clerk and bench book for Court.

Counsel are to prepare their exhibits by placing them in 3-ring binders that are tabbed down the right side with exhibit numbers. The spine portion of the binder shall indicate the volume number and contain an index of each exhibit including in the volume. The binders are to be prepared with an original for the Courtroom Deputy Clerk, which shall be tagged with the appropriate exhibit tags in the upper right hand corner of the first page of each exhibit, and one copy for the Court ("bench book"). Each binder shall contain an index of the included exhibits. The exhibits are to be numbered in accordance with Local Rule 26-3.

Jury instructions must cite source, be full text, separate page, numbered, single subject, no repetition.

Each requested instruction shall (a) cite the authority or source of the instruction, (b) be set forth in full, (c) be on a separate page, (d) be numbered, (e) cover only one subject or principle of law, and (f) not repeat principles of law contained in any other requested instruction.

Required

Always

Court dates must be Mondays except trial dates which are Tuesdays.

Each entry proposing Court dates shall fall on a Monday, except the trial date, which is a Tuesday.

Required

Always

Requested dates must not fall on holidays.

Counsel should insure that requested dates do not fall on a holiday.

Required

Always

Motion cut-off date is when motions may be heard, not filed.

The cut-off date for motions is the last date on which motions may be heard, not filed.

Required

Always

Margins

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Chambers copies must comply with L.R. 11-3 formatting requirements.

All chambers copies shall comply fully with the document formatting requirements of L.R. 11-3, including the 'backing' and 'tabbing' requirements of Local Rules 11-3.5 and 11-5.3,

Documentary evidence over 50 pages must be bound/tabbed with index; over 200 pages requires binder with tab dividers.

If documentary evidence in support of or in opposition to a motion exceeds 50 pages, the evidence must be separately bound and tabbed and include an index. If such evidence exceeds 200 pages, the documents shall be placed in a binder, with an index and with each item of evidence separated by a tab divider.

Documentary evidence over 200 pages requires binder with index and tab dividers.

If such evidence exceeds 200 pages, the documents shall be placed in a binder, with an index and with each item of evidence separated by a tab divider.

Required

Always

Format

PDF

Electronically filed documents must be created by publishing to PDF, not by scanning; noncompliance may result in striking.

All documents required to be "e-filed" in this matter can be found in General Order No. 10-07 and L.R. 5-4. The Court specifically directs litigants to L.R. 5-4.3.1, requiring that all electronically filed documents be created by publishing the document to PDF, and not by scanning paper documents. The Court may strike any pleading that does not comply with this requirement.

Proposed orders must be formatted as Word Perfect or Microsoft Word (DOCX) files.

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,

Format

PDF

Sealed Declaration in Support documents must be uploaded in PDF format.

The next screen is where you will upload your PDF documents.

Format

PDF

Sealed documents must be uploaded in PDF format for e-filing.

This is where you will upload your PDF documents.

Format

PDF

Sealed Reply documents must be uploaded in PDF format when e-filing.

If you select “A Court Order” from the screen shown above, clicking “Next” twice will bring you to the document upload screen. This is where you will upload your PDF documents.

Format

PDF

Sealed opposition documents must be uploaded in PDF format; the upload screen must turn red, otherwise stop and restart the docketing process.

If you select “A Court Order” from the screen shown above, clicking “Next” twice will bring you to the document upload screen. The next screen is where you will upload your PDF documents. This screen should turn red. If the screen does not turn red, STOP; your documents will not be filed under seal. Go back to the Civil Events Screen and begin the docketing process for your Sealed Opposition again.

Format

PDF

Application for Leave for In Camera Review must be uploaded as a PDF document.

You will upload your PDF documents on the next screen. Under “Main Document,” click the “Browse” button, and a file upload box will appear. Navigate to your “Application for Leave for In Camera Review” and select the file, then click “Open.”

Required

Always

Margins

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Exhibits must be in three-ring binders with tabs, volume numbers, indexes, and exhibit tags.

Counsel are directed to prepare their exhibits by placing them in three-ring binders that are tabbed down the right side with exhibit numbers. The spine portion of the binder shall indicate the volume number and shall contain an index of each exhibit included in the volume. The binders are to be prepared with an original for the Courtroom Deputy Clerk, which shall be tagged with the appropriate exhibit tags in the upper right-hand corner of the first page of each

Required

Always

Exhibits must be numbered according to Local Rule 26-3.

The exhibits are to be numbered in accordance with L.R. 26-3.

Required

Always

Original exhibits must have yellow tags (Plaintiff) or blue tags (Defendant) stapled to upper right corner.

The original exhibits with the Court’s exhibit tags. The parties shall use yellow tags for Plaintiff and blue tags for Defendant, which shall be stapled to the front of the exhibit on the upper right corner with the case number, case name, and exhibit number placed on each tag.

Required

Always

Two judge's binders with tabbed exhibit copies required for court (no tags needed).

Two Judge’s binders with a copy of each exhibit for use by the Court, tabbed with numbers as described above. (Court’s exhibit tags not necessary.)

Margins

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Each jury instruction must follow specific formatting requirements.

Each requested instruction (a) shall cite the authority or source of the instruction; (b) shall be set forth in full; (c) shall be on a separate page; (d) shall be numbered; (e) shall cover only one subject or principle of law; and (f) shall not repeat principles of law contained in any other requested instruction.

Required

Always

All documents must use a font size of 14-point or larger.

The Court also specifically directs litigants to L.R. 11-3.1.1, requiring that all documents use a font size of 14-point or larger.

Joint Statement must be in table format.

The Joint Statement shall be presented in a table format.

Local Rule 56-1 Statement of Uncontroverted Facts must be formatted as two columns with moving party's facts in the left column and supporting evidence citations in the right column.

The Statement of Uncontroverted Facts and Conclusions of Law (“Statement of Uncontroverted Facts”), as required by Local Rule 56-1, shall be formatted based on the following example: 1. (Moving party’s first uncontroverted fact) (Supporting evidence citation(s)) 2. (Moving party’s second undisputed fact) (Supporting evidence citation(s))

Local Rule 56-2 Statement of Genuine Disputes must be two-column, track movant's 56-1 statement, with first column combining facts and evidence, second stating disputed status with citations.

The opposing party’s Statement of Genuine Disputes of Material Fact (required by Local Rule 56-2) must be in two columns and track the movant’s Statement of Uncontroverted Facts exactly as prepared, but must combine the moving party’s fact statements and the supporting evidence into one column. Thus, the first column must restate the allegedly undisputed fact and the alleged supporting evidence, and the second column must state either that the fact proffered by the moving party is undisputed or disputed. 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. Whenever all or part of a proffered fact is disputed, the opposing party must briefly state why it disputes the moving party’s proffered fact, cite to the relevant exhibit(s) or other evidence, and must describe what it is in that exhibit or evidence that refutes the proffered fact.

Legal argument is prohibited in Statements of Uncontroverted Facts and Genuine Disputes; objections may be noted but case law/legal argument must be in a separate document.

No legal argument should be set forth in the Statement of Uncontroverted Facts or the Statement of Genuine Disputes of Material Fact. Legal argument should be reserved for the parties’ briefs. Objections and the relevant Federal Rule of Evidence or other basis therefor may be noted, but citations to case law and/or legal argument should be presented in the separate document described below.

Non-moving party's additional material facts must follow 56-1 format, be sequentially numbered, with evidence in right column; reply fact statements must comply with Local Rule 56-3.

Presentation of those additional material facts by the non-moving party shall follow the format described above for the moving party’s Statement of Uncontroverted Facts. These additional facts shall continue in sequentially numbered paragraphs and shall set forth in the right-hand column the evidence that supports that statement. A Reply fact statement may be filed by the moving party in a manner consistent with Local Rule 56-3.

Evidentiary objections must be in a separate two-column statement; responses use the same two-column format as the objections.

If a party relies in whole or in part on an evidentiary objection to dispute a material fact, the ground(s) of the objection(s) shall be succinctly stated in a separate statement of evidentiary objections in a two-column format. The left column should identify and describe the item(s) objected to (including page and line number if applicable) and the right column should set forth a concise objection (e.g., hearsay, lacks foundation, etc.) with a citation to the Federal Rules of Evidence or, where applicable, a case citation. Any response to the objections shall incorporate and build upon the two-column format set forth in the objections in the same manner as the Statement of Genuine Disputes of Material Fact incorporates and builds upon the Statement of Uncontroverted Facts.

Required

Always

Format

PDF

All documents filed on the docket must be in text-searchable PDF format.

All documents to be filed on the docket must conform with e-filing requirements Local Civil Rules 5-4.3, including, most notably, that they be submitted in text-searchable .pdf format.

Format

DOCX

Proposed orders must be submitted in editable Microsoft Word format.

Proposed orders must also be submitted in editable Microsoft Word format.

Format

DOCX

Proposed Final Pretrial Conference Order must be in Microsoft Word (DOCX) format.

Counsel are directed to email to the Court a Microsoft Word version of the (Proposed) Final Pretrial Conference Order on the date it is lodged.

All motions and opposition briefs must include a time estimate adjacent to the caption.

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.

All exhibits from any party must have official exhibit tags attached to the lower right-hand corner of the first page.

All exhibits presented to the Court by either side shall have the Court’s official exhibit tags attached to the lower right-hand corner of the first page of each exhibit.

Exhibits longer than one page must be internally paginated in the lower right-hand corner.

All exhibits longer than one page shall be internally paginated in the lower right-hand corner.

Jury instructions must be submitted in three parts: agreed, government-objection, defense-objection.

The jury instructions shall be submitted as follows: a. Agreed upon JOINT jury instructions; 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 general and substantive instructions.

Counsel shall include both general and substantive instructions.

Format

DOCX

Counsel must email proposed jury instructions in Microsoft Word format to JLS_Chambers@cacd.uscourts.gov.

counsel must email all proposed instructions in Microsoft Word format to the Court at the following email address: JLS_Chambers@cacd.uscourts.gov.

Format

DOCX

Electronic versions of jury instructions must be in Microsoft Word format and submitted to JLS_Chambers@cacd.uscourts.gov.

counsel must submit electronic versions (in Microsoft Word format) to the Court at the following email address: JLS_Chambers@cacd.uscourts.gov

Exhibits must be placed in 3-ring loose-leaf binders with divider tabs, numbered per Local Rule 26-3, with binder face/spine marked with case details.

All exhibits will be placed in 3-ring loose-leaf binders, in numerical order, with divider tabs containing exhibit numbers. The exhibits are to be numbered in accordance with Local Rule 26-3. The face and spine of the notebooks are to be marked with the case name and number, the numbers of the exhibits contained therein, and the volume number.

Parties must prepare three witness binders per witness (Court, opposing party, witness) with only that witness’s exhibits, witness name on binder, numerical order, tabs, delivered to CRD/opposing side when witness is called.

The parties must also prepare individual witness binders: One for the Court; one for the opposing party; and one for the witness. Witness binders are to include only those exhibits that will be used when a particular witness testifies. The name of the witness should appear on the binder, and exhibits must be in numerical order and tabbed so that the witness, the Court, and the opposing party may easily access each exhibit as the witness’s testimony proceeds. Witness binders are used for the convenience of the witness, the Court, and the parties. As such, they need not be given to the Courtroom Deputy Clerk (“CRD”) or the opposing side until each witness is called.

Margins

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In camera documents must be labeled “in camera” on first page and suggested on every page.

Each document must be conspicuously labeled as “in camera” on the first page. Marking such documents on every page (in the footer) as “in camera” is also suggested.

Margins

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File histories must be double-sided, indexed, tabbed, and in three-ring binder.

Each file history shall be printed double-sided, indexed, tabbed, and compiled in a three-ring binder.

Format

PDF

Electronic file histories must be single PDF with bookmarks and highlighting.

Each file history shall be a single PDF file with bookmarks corresponding to the tabs on the paper copy and shall contain the highlighting present on the paper copy.

Required

Always

Exhibits must be numbered according to Local Rule 26-3

All exhibits are to be numbered in accordance with Local Rule 26-3.

Required

Always

Hard copy exhibits must be placed in 3-ring binders

The hard copy exhibits shall be placed in 3-ring binders.

Required

Always

Binder spine must indicate volume number

The spine portion of the binder shall indicate the volume number of the binder.

Required

Always

Original exhibits must use yellow tags (plaintiff) or blue tags (defendant) with case info

The original copy of the exhibits shall be labeled with the Court's exhibit tags. The parties shall use yellow tags for plaintiff and blue tags for defendant, which shall be stapled to the front of the exhibit on the upper right corner with the case number, case name, and exhibit number placed on each tag.

Each jury instruction must cite authority, be on separate page, numbered, cover one subject, and not repeat other instructions.

Each requested instruction shall (a) cite the authority or source of the instruction, (b) be set forth in full, (c) be on a separate page, (d) be numbered, (e) cover only one subject or principle of law, and (f) not repeat principles of law contained in any other requested instruction.

Courtesy copies of fee table must be in Excel format with no editing restrictions.

The courtesy copies of the table shall be prepared in Excel, have all restrictions removed so the spreadsheets can be edited, and be emailed to opposing counsel and the Court’s chambers email address at kk_chambers@cacd.uscourts.gov.

Mandatory chambers copies must comply with Local Rule 11-3 (font size, page numbering, exhibit tabbing) and are not required to be blue-backed.

A mandatory chambers copy must comply with Local Rule 11-3 (i.e. font size, page numbering, exhibit tabbing, etc.) but need not be blue-backed.

All motions must be submitted as written notice; oral motions are prohibited.

pursuant to Local Rule 6-1, the Court will not accept oral motions; all motions shall be presented by written notice in compliance with the Local Rules.

Exhibits must be numbered per Local Rule 26-3 and submitted in hard and electronic formats

At least seven (7) days before Trial, counsel shall submit their exhibits in both hard copy and electronic (e.g., USB) format. All exhibits are to be numbered in accordance with Local Rule 26-3

Hard copy exhibits must be organized in tabbed 3-ring binders with required copies, volume labeling, and an index

The hard copy exhibits shall be placed in 3-ring binders that are tabbed down the right side with exhibit numbers. Counsel shall prepare three exhibit binders: (1) an original for the CRD, which shall be tagged with the appropriate exhibit tags in the upper right hand corner of the first page of each exhibit, (2) one copy for the Court, and (3) one copy for the witness. The spine portion of the binder shall indicate the volume number of the binder. Each binder shall contain an index of the exhibits included in the volume

Exhibits must be tagged with color-coded labels, use precise excerpts, and match Joint Exhibit List labeling

The original copy of the exhibits shall be labeled with the Court’s exhibit tags. The parties shall use yellow tags for plaintiff and blue tags for defendant, which shall be stapled to the front of the exhibit on the upper right corner with the case number, case name, and exhibit number placed on each tag. Each exhibit must be designated by a separate tab and shall be as precise as possible. For example, if a party seeks to introduce a five-minute excerpt of a longer video or audio recording, the exhibit should be of the five-minute version. Similarly, if a party seeks to introduce ten pages of a forty-page document, the exhibit should consist of only the ten pages to be introduced. On the other hand, if the entire recording or entire document will be admitted, the exhibit need not be broken up into separate sections. The Joint Exhibit List provided to the Court shall be consistent with this directives. In other words, if the Exhibit is labeled 101-1, the Joint Exhibit List shall list the Exhibit as 101-1

Each requested jury instruction must cite authority, be full text, on separate page, numbered, single subject, and non-repetitive.

Each requested instruction shall (a) cite the authority or source of the instruction, (b) be set forth in full, (c) be on a separate page, (d) be numbered, (e) cover only one subject or principle of law, and (f) not repeat principles of law contained in any other requested instruction.

Format

DOCX

Joint Statement of the Case and proposed voir dire questions must be submitted in Word format to kk_chambers@cacd.uscourts.gov.

The parties must submit an electronic version (Word format) to the Court at the following e-mail address: kk_chambers@cacd.uscourts.gov.

Trial depositions must be lodged in both hard copy and electronic (USB) format.

counsel shall lodge any deposition(s) that they intend to use at trial in both hard copy and electronic (e.g., USB) format.

Protected material pages must have the applicable confidentiality legend affixed.

Designation under this Order requires the designator to affix the applicable legend (“CONFIDENTIAL,” “HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY,” or “HIGHLY CONFIDENTIAL – SOURCE CODE”) to each page that contains protected material.

Transcripts with designated material must have a title page legend, list of designated pages/lines and protection levels, and designators must inform the court reporter.

Transcripts containing designated material shall have a legend on the title page noting the presence of designated material, and the title page shall be followed by a list of all pages (including line numbers as appropriate) that have been designated, and the level of protection being asserted. The designator shall inform the court reporter of these requirements.

The mandatory chambers copy must comply with Local Rule 11-3 formatting (font size, page numbering, exhibit tabbing), need not be blue-backed, and must be labeled 'MANDATORY CHAMBERS COPY' on the face page.

chambers copy must comply with Local Rule 11-3 (i.e. font size, page numbering, exhibit tabbing, etc.) but need not be blue-backed. The mandatory chambers copy must be prominently labeled MANDATORY CHAMBERS COPY on the face page.

Required

Always

Format

PDF

All documents must be converted to text-searchable PDF with selectable text.

Counsel shall adhere to Local Rule 5-4.3.1 with respect to the conversion of all documents to a PDF so that when a document is filed, it is in the proper size and format that is text-searchable. Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document.

Electronic exhibits must be provided on USB flash drive; CDs/DVDs not accepted.

Electronic nonpaper exhibits lodged under Local Rule 5-4.2(b)(1) (e.g., audio and video files) must be provided on a USB flash drive. The Court will not accept electronic exhibits provided by CD or DVD.

Required

Always

Case law citations must include specific page references and follow Bluebook style.

Citations of case law must identify not only the case cited, but also 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 pages on which such language appears shall be provided. Bluebook style is preferred.

Required

Always

Statutory and other source citations must be specific and follow Bluebook style.

Statutory references should identify with specificity the sections and subsections referenced. Citations of treatises, manuals, and other materials should include the volume, section, and pages that are referenced. Citations of prior filings in the same matter shall include the docket entry number, section, and pages that are referenced. Bluebook style is preferred.

Format

PDF

Electronically filed evidence must be text-searchable with selectable text.

The parties shall ensure that electronically filed copies of evidence in support of, or in opposition to, a motion for summary judgment are in the proper format. Thus, all documents must be text-searchable and have selectable text that may be copied and pasted directly from the filed document.

Testimony in statements must be highlighted and/or underlined.

Additionally, testimony cited in a statement of uncontroverted facts, statement of genuine material facts, or statement of additional material facts shall be highlighted and/or underlined.

Required

Always

Format

PDF

All documents must be converted to text-searchable PDF with selectable, copyable, and pasteable text.

Counsel shall adhere to Local Rule 5-4.3.1 with respect to the conversion of all documents to a PDF so that when a document is filed, it is in the proper size and format that is text-searchable. Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document.

Electronic nonpaper exhibits must be provided on USB flash drive; CD/DVD not accepted.

Electronic nonpaper exhibits lodged under Local Rule 5-4.2(b)(1) (e.g., audio and video files) must be provided on a USB flash drive. The Court will not accept electronic exhibits provided by CD or DVD.

LR 56-2 Statement of Genuine Disputes must be formatted in two columns, tracking the movant's statement format.

The opposing party's Local Rule 56-2 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 alleged supporting evidence, and the right-hand column must state either that it is undisputed or disputed.

Format

PDF

Electronically filed evidence must be text-searchable with selectable text that can be copied and pasted.

The parties shall ensure that electronically filed copies of evidence in support of, or in opposition to, a motion for summary judgment are in the proper format. Thus, all documents must be text-searchable and have selectable text that may be copied and pasted directly from the filed document.

Testimony cited in LR 56 statements must be highlighted and/or underlined.

Additionally, testimony cited in a statement of uncontroverted facts, statement of genuine material facts, or statement of additional material facts shall be highlighted and/or underlined.

Format

DOCX

Attorney fee tables must be in editable Microsoft Excel format.

Any table as set forth above shall be attached to the motion and electronically in Microsoft Excel format and have all restrictions removed so that the spreadsheet can be edited.

Required

Always

Format

PDF

All documents must be filed as text-searchable PDFs allowing text selection, copying, and pasting.

Counsel shall adhere to Local Rule 5-4.3.1 with respect to the conversion of all documents to a PDF so that when a document is filed, it is in the proper size and format that is text-searchable. Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document.

Nonpaper electronic exhibits must be submitted via USB or email link; CD/DVD exhibits are rejected unless the exhibit itself is a CD/DVD.

Electronic nonpaper exhibits lodged under Local Rule 5-4.2(b)(1) (e.g., audio and video files) must be provided on a USB flash drive or by sending a link to an Internet file hosting service (e.g., Dropbox) by email to mcs_chambers@cacd.uscourts.gov. Exhibits provided on a CD or DVD will not be considered and will be destroyed unless the CD or DVD itself is a nonpaper exhibit subject to Local Rule 11-5.1.

Electronically filed evidence for summary judgment motions must be text-searchable with selectable, copyable text.

The parties shall ensure that electronically filed copies of evidence in support of, or in opposition to, a motion for summary judgment are in the proper format. Thus, all documents must be text-searchable and have selectable text that may be copied and pasted directly from the filed document.

Testimony cited in summary judgment fact statements must be highlighted and/or underlined.

Additionally, testimony cited in a statement of uncontroverted facts, statement of genuine material facts, or statement of additional material facts shall be highlighted and/or underlined.

Evidentiary objections must be formatted in a three-column layout with specified content for each column per Exhibit A.

If a party disputes a fact based be succinctly stated in a separate statement of evidentiary objections in a three-column format (see Exhibit A): The left column should include the relevant portions of any declaration or deposition, which shall include the highlighted, underlined, and/or bracketed portions that are being objected to (including page and line number, if applicable). Each objection shall be numbered and located within the copy of the declaration. The middle column should set forth a concise objection (e.g., hearsay, lacks foundation, etc.) with a citation of the Federal Rules of Evidence or, where applicable, a case citation. The right column should provide space for the Court’s entry of its ruling on the objection.

Pro se email filings must comply with Local Rule 11-3 formatting requirements.

(a) The document shall be prepared so that it complies with the requirements set forth in Local Rule 11-3, i.e., legibility, font, paper, pagination, spacing, title page, page limits, etc.

Format

PDF

Pro se email filings must be in PDF format and submitted by the document due date.

(b) The document shall be emailed as a PDF document to mcs_chambers@cacd.uscourts.gov no later than the date it is due.

Format

PDF

All documents must be converted to text-searchable PDF with selectable text.

Counsel shall adhere to Local Rule 5-4.3.1 with respect to the conversion of all documents to a PDF so that when a document is filed, it is in the proper size and format that is text-searchable. Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document.

Additional facts must be numbered sequentially after moving party's last fact.

The nonmoving party’s additional facts must be numbered sequentially to follow the last numbered fact presented by the moving party.

Summary judgment evidence must be text-searchable with selectable text.

The parties shall ensure that electronically filed copies of evidence in support of, or in opposition to, a motion for summary judgment are in the proper format. Thus, all documents must be text-searchable and have selectable text that may be copied and pasted directly from the filed document.

Testimony in summary judgment statements must be highlighted/underlined.

Additionally, testimony cited in a statement of uncontroverted facts, statement of genuine material facts, or statement of additional material facts shall be highlighted and/or underlined.

Pro se email filings must comply with Local Rule 11-3 formatting requirements

(a) The document shall be prepared so that it complies with the requirements set forth in Local Rule 11-3, i.e., legibility, font, paper, pagination, spacing, title page, page limits, etc.

Margins

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Trial exhibits: 1 original + 1 copy in labeled binder; Bates stamped; different number sequences per party.

One original (witness copy) and one copy (bench copy) shall be presented to the Courtroom Deputy Clerk on the first day of trial. The exhibits shall be presented in a binder. Each binder shall be clearly labeled on the spine to include the case name, party and volume umber. The Court does not require specific exhibit tags so long as each document is Bates stamped and separated with a divider that is numbered. Each party shall use a different number sequence and shall comply with Local Civil Rule 26-3.

Required

Always

Pretrial documents must be delivered binder-ready (3-hole punched, no blue-backs, stapled top left).

Copies of all pretrial documents shall be delivered to the Court “binder-ready” (three-hole punched on the left side, without blue-backs, and stapled only in the top left corner).

Required

Always

Format

DOCX

Email all pretrial documents (except specified exceptions) in Microsoft Word format to chambers.

Except for motions in limine, oppositions, the Joint Status Report Regarding Settlement, and Declarations containing direct testimony, Counsel shall email all of the below pretrial documents, including any amended documents, in Microsoft Word format to MCS_Chambers@cacd.uscourts.gov.

Margins

1 in

Trial exhibits must be in three-ring binders with one original and one copy.

Trial exhibits that consist of documents must be submitted to the Court in three-ring binders. Counsel shall submit to the Court one original set of exhibit binders, and one copy: the original set shall be for the witnesses, and the copy set is for the Court.

Margins

1 in

Exhibits must be numbered sequentially without duplication between parties.

All exhibits must be placed in three-ring binders indexed by exhibit number with tabs or dividers on the right side. Exhibits shall be numbered 1, 2, 3, etc., not 1.1, 1.2, etc. The defendant’s exhibit numbers shall not duplicate plaintiff’s numbers.

Margins

1 in

Binder spines must show volume number and exhibit number range.

For all 3 sets of binders, the spine of each binder shall indicate the volume number and the range of exhibit numbers included in the volume.

Margins

1 in

Original exhibits require official yellow/blue tags with case info.

The original set of exhibits shall have official exhibit tags (yellow tags for plaintiff’s exhibits, and blue tags for defendant’s exhibits) affixed to the front upper right-hand corner of the exhibit, with the case number, case name, and exhibit number stated on each tag.

Margins

1 in

Copy exhibits must not have official tags but must be properly formatted.

The copy set of the exhibits shall not have official exhibit tags but must be

All expert disclosures must be made in writing.

All disclosures must be made in writing.

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

ALL PRETRIAL DOCUMENT COPIES DELIVERED TO THE COURT SHALL BE “BINDER-READY” (three-hole punched on the left side, without blue-backs, and stapled only in the top left corner).

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

the format of the proposed final pretrial conference order shall conform to the format set forth in Appendix A to the Local Rules.

Proposed findings of fact and conclusions of law must comply with Local Rule 52-3 formatting.

counsel for each party shall, no later than 21 days before trial, file with the Court and serve on opposing counsel that party’s proposed findings of fact and conclusions of law in the format specified in Local Rule 52-3.

Unmarked proposed findings must be in Word or WordPerfect file format.

At the time of filing, each party also must submit its own unmarked proposed findings of fact and conclusions of law to the Chambers e-mail box in Word or WordPerfect format.

Trial exhibits must be organized in three-ring binders with tabs, indexed by exhibit number, and spine marked with volume number and exhibit index.

Exhibits must be placed in three-ring binders indexed by exhibit number with tabs or dividers on the right side. Counsel shall submit to the Court an original and two copies of the binders. The spine portion of the binder shall indicate the volume number and contain an index of each exhibit included in the volume.

Witnesses may not be asked to draw graphic aids; all graphic aids must be fully prepared before the court session.

Counsel must not ask witnesses to draw charts or diagrams nor ask the Court’s permission for a witness to do so. Any graphic aids must be fully prepared before the court session starts.

Pretrial documents must be delivered binder-ready: three-hole punched on left, no blue-backs, stapled top left corner.

All pretrial document copies shall be delivered to the Court "binder-ready" (three-hole punched on the left side, without blue-backs, and stapled only in the top left corner).

Jury instructions must follow specified sources (Ninth Circuit Manual, CACI, or O'Malley) and meet formatting requirements: cite authority, full text, separate page, numbered, one subject, no repetition.

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. Where California law applies, counsel should use the current edition of the Judicial Council of California Civil Jury Instructions ("CACI"). If neither is applicable, counsel should consult the current edition of O'Malley, et al., Federal Jury Practice and Instructions. Each requested instruction shall (a) cite the authority or source of the instruction, (b) be set forth in full, (c) be on a separate page, (d) be numbered, (e) cover only one subject or principle of law, and (f) not repeat principles of law contained in any other requested instruction.

The Chambers email version must include a clean set of jury instructions (text only, one per page, with caption 'Instruction No. __') for jury use during deliberations.

The Court will send one or more copies of the instructions into the jury room for the jury's use during deliberations. Therefore, in addition to the copies described above, the Chambers email version must contain a "clean" set of jury instructions, containing only the text of the instruction (one per page) with the caption "Instruction No. __" at the top (eliminating titles, supporting authority, etc.).

Required

Always

Exhibits must be in three-ring binders, indexed with tabs, spine labeled, and an original and copy submitted.

Exhibits must be placed in three-ring binders indexed by exhibit number with tabs or dividers on the right side. Counsel shall submit to the Court an original and copy of the binders. The spine portion of the binder shall indicate the volume number and contain an index of each exhibit included in the volume.

Required

Always

Original exhibit binder must have exhibit tags (yellow for plaintiff, blue for defendant) stapled to upper right corner with case info.

One (set of) binder(s) of original exhibits with the Court’s exhibit tags, yellow tags for plaintiff and blue tags for defendant, stapled to the front of the exhibit on the upper right-hand corner with the case number, case name, and exhibit number placed on each tag.

Required

Always

All exhibits (except impeachment-only) must have official exhibit tags with matching exhibit list numbers.

All of the exhibits (except those to be used for impeachment only), with official exhibit tags attached and bearing the same number shown on the exhibit list.

Required

Always

Exhibits must be numbered sequentially (1,2,3), defense numbers must not duplicate plaintiff's, blow-ups designated with original number plus 'A'.

Exhibits shall be numbered 1, 2, 3, etc., NOT 1.1, 1.2, etc. The defense exhibit numbers shall not duplicate plaintiff’s numbers. If a “blow-up” is an enlargement of an existing exhibit, it shall be designated with the number of the original exhibit followed by an “A.”

Pretrial documents must be three-hole punched on left side, no blue-backs or staples.

All pretrial document copies delivered to the Court shall be “binder-ready” (three-hole punched on the left side, without blue-backs or staples).

Format

WORD_PERFECT

Submit clean jury instructions in Word/WordPerfect format to Chambers email.

One or more copies of the instructions will be given to the jury during deliberations. Accordingly, counsel must submit to the Chambers' e-mail address a “clean” set of all instructions in Word or WordPerfect format, containing only the text of each instruction, set forth in full on each page, with the caption “Instruction No. ____” (eliminating titles, supporting authority, objections and responses).

Pretrial documents must be binder-ready: three-hole punched, no blue-backs, stapled top left.

ALL PRETRIAL DOCUMENT COPIES DELIVERED TO THE COURT SHALL BE “BINDER-READY” (three-hole punched on the left side, without blue-backs, and stapled only in the top left corner).

Margins

1 in

Exhibits must be in three-ring binders with index, original plus two copies required.

Exhibits must be placed in three-ring binders indexed by exhibit number with tabs or dividers on the right side. Counsel shall submit to the Court an original and two copies of the binders. The spine portion of the binder shall indicate the volume number and contain an index of each exhibit included in the volume.

Pretrial documents must be delivered binder-ready with three-hole punch, no blue-backs, stapled top left.

All pretrial document copies shall be delivered to the Court “binder-ready” (three-hole punched on the left side, without blue-backs, and stapled only in the top left corner).

Required

Always

Parties should use Ninth Circuit Model Jury Instructions or CACI when applicable, cite authority, be on separate pages, numbered, cover one subject, and not repeat other instructions.

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. Where Council of California Civil Jury Instructions (“CACI”). If neither is applicable, counsel should consult the current edition of O’Malley, et al., Federal Jury Practice and Instructions. Each requested instruction shall (a) cite the authority or source of the instruction, (b) be set forth in full, (c) be on a separate page, (d) be numbered, (e) cover only one subject or principle of law, and (f) not repeat principles of law contained in any other requested instruction.

Required

Always

Joint and disputed jury instructions must be emailed to Chambers in Word or WordPerfect 9+ format when filed.

Counsel must provide the documents described in paragraphs 2 and 3 to the Chambers email box in Word or WordPerfect 9 (or above) format at the time they file their proposed jury instructions.

Required

Always

Chambers email version must contain a clean set of jury instructions with only instruction text and "Instruction No. __" caption for jury deliberations.

The Court will send one or more copies of the instructions into the jury room for the jury’s use during deliberations. Therefore, in addition to the copies described above, the Chambers email version must contain a “clean” set of jury instructions, containing only the text of the instruction (one per page) with the caption “Instruction No. __” at the top (eliminating titles, supporting authority, etc.).

Required

Always

Margins

0 in

Exhibits must be in three-ring binders with tabs, indexed by exhibit number, with spine indicating volume number and index.

Exhibits must be placed in three-ring binders indexed by exhibit number with tabs or dividers on the right side. Counsel shall submit to the Court an original and copy of the binders. The spine portion of the binder shall indicate the volume number and contain an index of each exhibit included in the volume.

Required

Always

Exhibits numbered 1, 2, 3, etc.; defense numbers must not duplicate plaintiff's; blow-ups designated with original number + "A".

Exhibits shall be numbered 1, 2, 3, etc., NOT 1.1, 1.2, etc. The defense exhibit numbers shall not duplicate plaintiff's numbers. If a "blow-up" is an enlargement of an existing exhibit, it shall be designated with the number of the original exhibit followed by an "A." These items (and the items listed in d and e below) shall be provided on the first day of trial.

Required

Always

Three-ring binder with all exhibits required for witness use.

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

Font requirements: proportionally spaced 14-point or larger, or monospaced not exceeding 10½ characters per inch.

Pursuant to the Local Rules, either a proportionally spaced or monospaced font may be used. A proportionally spaced face must be 14-point or larger, or as the Court may otherwise order. A monospaced face may not contain more than 10½ characters per inch.

Format

PDF

All documents must be converted to PDF format, text-searchable, and allow text selection/copy/paste.

Counsel shall adhere to Local Rule 5-4.3 with respect to the conversion of all documents to PDF format so that when a document is electronically filed, it is in proper size and is text-searchable. Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document.

Motion memoranda must use Times New Roman or Courier font, 12 pt text, 11 pt footnotes.

All memoranda of points and authorities and replies in support of or in opposition to motions must use Times New Roman or Courier font. Text must be no less than twelve (12) point font; footnotes shall be no less than eleven (11) point font.

Trial exhibits must be submitted in three-ring binders (1 original + 2 copies).

Trial exhibits that consist of documents and photographs must be submitted to the Court in three-ring binders. The parties shall submit to the Court three (3) sets of binders: one (1) original set of trial exhibits, and two (2) copies of trial exhibits. The original set of exhibits shall be for use by the jury during its deliberations, and the copies are for the Court.

Exhibits must be indexed with tabs and numbered sequentially (1, 2, 3, etc.).

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc.

Original exhibits must have official yellow/blue tags with case info.

The original exhibits shall bear the official exhibit tags (yellow tags for Plaintiff’s exhibits and blue tags for Defendant’s exhibits) affixed to the front upper right-hand corner of the exhibit, with the case number, case name, and exhibit number stated on each tag. Tags may be obtained from the Clerk’s Office, or the parties may print their own exhibit tags using Forms G-14A and G-14B on the “Court Forms” section of the Central District of California’s website.

Copy exhibits must have copies of official tags and be indexed with tabs.

The copies of exhibits must bear copies of the official exhibit tags that were placed on the original exhibits and be indexed with tabs or dividers on the right side.

Government and defense exhibits must be in separate folders with descriptive filenames.

The Government’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 (e.g., “Ex. 1 – Smith Declaration.pdf” or “Ex. 105 –Letter Dated 1-5-20.pdf”).

Document and photograph trial exhibits must be submitted in three-ring binders.

Trial exhibits that consist of documents and photographs must be submitted to the Court in three-ring binders.

Government original exhibits must be in three-ring binders with attached exhibit tags matching the exhibit list number, numbered sequentially (no decimals), with blow-ups designated as original number + 'A'; digital tags per Form G-14A/G-14B are allowed.

c. One set of three-ring binder(s) containing all of the government’s original exhibits, with official exhibit tags attached and bearing the same number shown on the exhibit list. Digital exhibit tags are available on the Court’s website under Court Forms > General Forms > Form G-14A (plaintiff) and G-14B (defendant). Digital exhibit tags may be used in place of the tags obtained from the Clerk’s Office. Exhibits shall be numbered 1, 2, 3, etc., NOT 1.1, 1.2, etc. If a “blow-up” is an enlargement of an existing exhibit, it shall be designated with the number of the original exhibit followed by an “A”;

Defense counsel must affix completed exhibit tags containing the case name and number to all defense exhibits.

Defense counsel are responsible for affixing completed exhibit tags with the case name and case number to all exhibits to be used in defendant’s case.

Defense counsel must provide two three-ring binders of exhibits if expecting to admit more than 20 exhibits, tabbed if possible.

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.

Format

DOCX

Jury instructions must be submitted in Word (DOCX) format.

Accordingly, counsel must submit to the Chambers e-mail (MRA_chambers@cacd.uscourts.gov) 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.).

Format

PAPER

Stipulations of fact must be submitted to the Court in paper (written) format and require defendant personal concurrence.

Any stipulation of fact will require defendant’s personal concurrence and shall be submitted to the Court in writing for approval.

Expert disclosures are required to be made in writing.

All expert disclosures must be made in writing.

Chambers copies of pretrial documents must be three-hole punched left, without blue-backs, and clipped (not stapled) top left.

ready” state, meaning they must be three-hole punched on the left side, without blue-backs, and clipped, not stapled, only in the top left corner.

Parties must file clean and redline versions of jury instructions, with redline sets including required content and disputed instructions organized by subject.

(b) Red-lined Copy. 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. Where appropriate, the disputed instructions shall be organized by subject, so that instructions that address the same or similar issues are presented sequentially.

Jury instructions must use specified sources: Ninth Circuit Manual if applicable, CA Civil Jury Instructions if CA law, else alternatives only with reasoned argument.

(c) Sources. 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 use the current edition of the Judicial Council of California Civil Jury Instructions. If neither applies, the parties should consult the current alternatives to these instructions only if there is a reasoned argument that they do not properly state the law or are incomplete.

Each requested jury instruction must cite authority, be full text, on separate page, numbered, single subject, no repetition, and fill blanks in standard instructions.

(d) Format. Each requested instruction shall (i) cite the authority or source of the instruction; (ii) be set forth in full; (iii) be on a separate page; (iv) be numbered; (v) cover only one subject or principle of law; and (vi) not repeat principles of law contained in any other requested instruction. 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.

Proposed Findings of Fact and Conclusions of Law must be filed and served in the format required by Local Rule 52-3 for bench trials.

each party shall file and serve on the opposing party its Proposed Findings of Fact and Conclusions of Law in the format specified in L.R. 52-3.

Evidentiary objections to direct testimony declarations must be submitted in a three-column format with specific content requirements.

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 submit three sets of trial exhibit binders: one original and two copies.

The parties shall submit to the Court three (3) sets of binders: one (1) original set of trial exhibits, and two (2) copies of trial exhibits.

Trial exhibits in three-ring binders must be indexed with tabs or dividers on the right side.

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side.

Trial exhibits must be numbered sequentially without decimal points per Local Rule 16-6.

Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc. See L.R. 16-6.

All pages of multi-page trial exhibits must be numbered.

Every page of a multi-page exhibit must be numbered.

Defendant exhibit numbers cannot duplicate plaintiff exhibit numbers.

Defendant’s exhibit numbers shall not duplicate Plaintiff’s numbers.

Trial exhibit binder spines must display the volume number and range of exhibit numbers.

The spine of each binder shall indicate the volume number and the range of exhibit numbers included in the volume.

Original trial exhibits must have color-coded official tags stapled to the upper right front with case details.

The original exhibits shall bear the official exhibit tags (yellow tags for Plaintiff’s exhibits and blue tags for Defendant’s exhibits) stapled to the front of the exhibit on the upper right corner with the case number, case name, and

Exhibit copies must include official exhibit tags and be indexed with right-side tabs or dividers.

The copies of exhibits must bear copies of the official exhibit tags that were placed on the original exhibits and be indexed with tabs or dividers on the right side.

Plaintiff and defendant exhibits must be stored in separate USB folders, with file names including the exhibit number and a brief description.

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.”

Exhibits may not be shown to jurors before being admitted into evidence; admitted exhibits may be displayed electronically.

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.

Lodged depositions are for the court’s use only; parties must use their own copies during trial.

These lodged depositions are for the Court’s use. The parties must use their own copies during trial.

Counsel must use the lectern during trial; trial aids must be prepared in advance, and counsel may not write or draw charts during jury time.

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.

Required

Always

All exhibits must be pre-marked, bound, and tabbed.

Copies of all exhibits must be pre-marked, bound, and tabbed.

Patent file history must be double-sided in three-ring binder; exclude prior art from paper copy.

The patent file history must be printed double-sided and compiled in a three-ring binder. Prior art references1 should not be included in the paper copy.

Format

PDF

Electronic patent file history required on flash drive/CD/DVD in single PDF; prior art as separate PDFs.

In addition to the paper copy of the patent file history, the patentee must submit an electronic copy on a flash drive, CD-ROM, or DVD. Each patent file history must be a single electronic file in PDF format. All prior art references must also be included on the flash drive, CD-ROM, or DVD, with each prior art reference appearing as a separate, identifiable PDF file.

Pretrial document chambers copies must be three-hole punched and in three-ring binder.

All courtesy copies of pretrial documents (e.g. witness lists, exhibit lists, pretrial conference orders, jury instructions, etc.) shall be three-hole punched and placed in a three-ring binder as described below.

Summary judgment movant's statement must use two-column format.

The movant’s Separate Statement of Uncontroverted Facts is to be prepared in a two-column format. The left-hand column should set forth the allegedly undisputed fact. The right-hand column should set forth the evidence that supports the factual statement.

Summary judgment opposition must use two-column format matching movant's statement.

The opposing party’s Statement of Genuine Issues of Material Fact must be in two columns and track the movant’s Separate Statement exactly as prepared.

Evidence must be tabbed and bound; 20+ pages requires separate volume with TOC; 50+ pages requires Slant D-Ring binder; USB PDF drives are an alternative.

All evidence in support of or in opposition to a motion for summary judgment, including declarations and exhibits to declarations, shall be separated by a tab divider on the bottom of the page. If evidence in support of or in opposition to a motion for summary judgment exceeds twenty pages, the evidence must be in a separately bound volume and include a Table of Contents. If the supporting evidence exceeds fifty pages, the documents shall be placed in a Slant D-Ring binder with each item of evidence separated by a tab divider on the right side. All documents contained in the binder should be three-hole-punched. Alternatively, parties may submit USB flash drives with supporting evidence in portable document format (PDF) files.

Multi-exhibit PDFs must include TOC and bookmarked exhibits.

If a PDF file contains more than one exhibit, that PDF must include a Table of Contents and each exhibit must be bookmarked with the exhibit nomenclature.

Evidence in Motions in Limine must be tabbed; over 20 pages requires separate bound volume with TOC.

All evidence in support of or in opposition to a motion in limine, including declarations and exhibits to declarations, shall be separated by a tab divider on the bottom of the page. If evidence in support of or in opposition to a motion in limine exceeds twenty pages, the evidence must be in a separately bound volume and include a Table of Contents.

Evidence must be three-hole-punched with tab dividers on right side; USC drives preferred over CDs.

Though strongly discouraged, if by necessity the supporting with each item of evidence separated by a tab divider on the right side. All documents contained in the binder should be three-hole-punched. For items not conducive to paper format, USC drives should be submitted in lieu of compact discs.

Margins

1 in

Jury instructions must follow Local Rule 51-2 format with specific requirements.

Each requested instruction shall be in the format specified by Local Rule 51-2 and shall be set forth in full; be on a separate page with the caption "COURT’S INSTRUCTION NUMBER ___"; be numbered; cover only one subject or principle of law; not repeat principles of law contained in any other requested instructions; and cite the authority for a source of the requested instruction.

Trial exhibits must be in 3-ring binders with 3/8" holes and numeric tabs.

(i) Counsel shall prepare both sets of the exhibits in 3-ring binders. Holes to be 3/8" in diameter. Notebooks to be tabbed down the right side with numeric tabs separating each exhibit.

Plaintiff exhibits numbered 1, 2, 3...; Defendant exhibits numbered 1000, 1001, 1002...

The exhibits are to be numbered sequentially, with Plaintiff’s exhibits numbered 1, 2, 3, etc. and Defendant’s exhibits numbered 1000, 1001, 1002, etc. Exhibit numbering must further comply with Local Rule 26-3.

Pretrial document chambers copies must be three-hole punched and in three-ring binder.

All courtesy copies of pretrial documents (e.g. witness lists, exhibit lists, pretrial conference orders, jury instructions, etc.) shall be three-hole punched and placed in a three-ring binder as described below.

Separate Statement of Uncontroverted Facts must be in two-column format with numbered paragraphs, each addressing single subject concisely.

The movant’s Separate Statement of Uncontroverted Facts is to be prepared in a two column format. The left-hand column should set forth the allegedly undisputed fact. The right-hand column should set forth the evidence that supports the factual statement. The factual statements should be set forth in sequentially numbered paragraphs. Each paragraph should contain a narrowly focused statement of fact. Each numbered paragraph should address a single subject in as concise a manner as possible.

Opposing party’s Statement of Genuine Issues must be in two columns and track movant’s Separate Statement exactly.

The opposing party’s Statement of Genuine Issues of Material Fact must be in two columns and track the movant’s Separate Statement exactly as prepared.

Evidence exceeding 20 pages must be in a separately bound volume with a Table of Contents.

If evidence in support of or in opposition to a motion for summary judgment exceeds twenty pages, the evidence must be in a separately bound volume and include a Table of Contents.

Evidence exceeding 50 pages must be in a Slant D-Ring binder with right-side tab dividers and three-hole-punched.

If the supporting evidence exceeds fifty pages, the documents shall be placed in a Slant D-Ring binder with each item of evidence separated by a tab divider on the right side. All documents contained in the binder should be three-hole-punched.

Required

Always

All evidence must be separated by tab dividers on the bottom of the page.

All evidence in support of or in opposition to a motion for summary judgment, including declarations and exhibits to declarations, shall be separated by a tab divider on the bottom of the page.

Multi-exhibit PDFs must include TOC and bookmarked exhibits.

If a PDF file contains more than one exhibit, that PDF must include a Table of Contents and each exhibit must be bookmarked with the exhibit nomenclature.

Evidence in Motions in Limine must be tabbed; over 20 pages requires separate bound volume with TOC.

All evidence in support of or in opposition to a motion in limine, including declarations and exhibits to declarations, shall be separated by a tab divider on the bottom of the page. If evidence in support of or in opposition to a motion in limine exceeds twenty pages, the evidence must be in a separately bound volume and include a Table of Contents.

Applies to

Motion in limine

Evidence over 20 pages in Motions in Limine requires separate bound volume with TOC.

If evidence in support of or in opposition to a motion in limine exceeds twenty pages, the evidence must be in a separately bound volume and include a Table of Contents.

Evidence must be tabbed on right side, three-hole-punched, or submitted on USC drives.

Though strongly discouraged, if by necessity the supporting with each item of evidence separated by a tab divider on the right side. All documents contained in the binder should be three-hole-punched. For items not conducive to paper format, USC drives should be submitted in lieu of compact discs.

PTCO headings must be in ALL CAPS AND BOLD.

The form of the proposed PTCO shall comply with Appendix A to the Local Rules and the following: (i) Place in “ALL CAPS AND BOLD” the separately numbered headings for each category in the PTCO (e.g., “1. THE PARTIES” or “7. CLAIMS AND DEFENSES OF THE PARTIES”).

Margins

0.375 in

Exhibits must be in 3-ring binders with 3/8" holes and numeric tabs.

(i) Counsel shall prepare both sets of the exhibits in 3-ring binders. Holes to be 3/8" in diameter. Notebooks to be tabbed down the right side with numeric tabs separating each exhibit.

Required

Always

Times New Roman font of at least 14 point size is required, with footnotes at least two sizes smaller and used sparingly.

Typeface shall comply with Local Rule 11-3.1.1. (Civil). NOTE: TIMES NEW ROMAN FONT MUST BE USED; THE SIZE MUST BE NO LESS THAN 14. Footnotes shall be in typeface no less than two sizes smaller than text size and shall be used sparingly.

Required

Always

Format

PDF

Electronic filings must be PDF created from word-processing files, not scanned images.

Pursuant to Local Rule 5-4.3.1, documents filed electronically must be submitted in Portable Document Format (“PDF”), created using word-processing software, and published to PDF from the original word-processing file to permit the electronic version of the document to be searched. Other than signature pages, PDF IMAGES CREATED BY SCANNING PAPER DOCUMENTS ARE PROHIBITED. Violation of Local Rule 5-4.3.1 may result in the striking of the offending document and the imposition of monetary or other sanctions.

Font requirements: Times Roman 14pt or Courier 12pt minimum; footnotes one size smaller.

Typeface shall comply with Local Rule 11-3.1.1. NOTE: If Times Roman font is used, the size must be no less than 14; if Courier is used, the size must be no less than 12. Footnotes shall be in typeface no more than one size smaller than text size and shall be used sparingly.

Non-conforming filings will not be considered.

Filings which do not conform to the Local Rules and this Order will not be considered.

Required

Always

Format

PDF

Electronically filed documents must be PDFs created from word-processing software; scanned PDF images are prohibited except for signature pages.

Pursuant to Local Rule 5-4.3.1, documents filed electronically must be submitted in Portable Document Format ("PDF"), created using word-processing software, and published to PDF from the original word-processing file to permit the electronic version of the document to be searched. Other than signature pages, PDF IMAGES CREATED BY SCANNING PAPER DOCUMENTS ARE PROHIBITED.

Required

Always

Times Roman minimum 14pt, Courier minimum 12pt; footnotes one size smaller max.

Typeface shall comply with Local Rule 11-3.1.1. NOTE: If Times Roman font is used, the size must be no less than 14; if Courier is used, the size must be no less than 12. Footnotes shall be in typeface no more than one size smaller than text size and shall be used sparingly.

Non-conforming filings will not be considered.

Filings which do not conform to the Local Rules and this Order will not be considered.

Required

Always

Electronic evidence files must not exceed 500MB; larger files should be split into multiple files.

Regarding the file size of electronic evidence, individual files should not exceed 500MB. If possible, exhibits approaching or exceeding this size limit should be separated into multiple files. Note: PDF documents can often be reduced significantly in size by using tools such as Adobe's “Reduce File Size” feature. Images can be significantly reduced in file size by lowering their resolution or dimensions, usually with minimal affect to viewing quality. Videos should be separated into 10 minute clips to satisfy the 500 MB limit.

Required

Always

JERS accepts specific file formats for electronic evidence.

JERS will accept electronic evidence only in the following formats as other types cannot be uploaded: Documents and Photographs: .bmp, .gif, .jpg, .pdf, .tif Video and Audio Recordings: .avi, .mpg, .mp3, .wav, .wma, .wmv

Required

Always

Format

PDF

Electronic filings must be PDF from word-processing software; scanned PDFs prohibited except for signature pages.

Pursuant to Local Rule 5-4.3.1, documents filed electronically must be submitted in Portable Document Format (“PDF”), created using word-processing software, and published to PDF from the original word-processing file to permit the electronic version of the document to be searched. Other than signature pages, PDF IMAGES CREATED BY SCANNING PAPER DOCUMENTS ARE PROHIBITED. Violation of Local Rule 5-4.3.1 may result in the striking of the offending document and the imposition of monetary or other sanctions.

Font requirements: Times Roman 14pt or Courier 12pt minimum; footnotes one size smaller.

Typeface shall comply with Local Rule 11-3.1.1. NOTE: If Times Roman font is used, the size must be no less than 14; if Courier is used, the size must be no less than 12. Footnotes shall be in typeface no more than one size smaller than text size and shall be used sparingly.

Required

Always

Non-conforming filings will not be considered by the Court.

Filings which do not conform to the Local Rules and this Order will not be considered.

Required

Always

Format

PDF

Electronic filings must be searchable PDFs from word-processing files; scanned images prohibited except for signature pages.

Pursuant to Local Civil Rule 5-4.3.1, documents filed electronically must be submitted in Portable Document Format (“PDF”), created using word-processing software, and published to PDF from the original word-processing file to permit the electronic version of the document to be searched. Other than signature pages, PDF IMAGES CREATED BY SCANNING PAPER DOCUMENTS ARE PROHIBITED. Violation of Local Rule 5-4.3.1 may result in the striking of the offending document and the imposition of monetary or other sanctions.

Required

Always

Format

PDF

Exhibit list must be provided in PDF and WordPerfect/Word formats to chambers email.

The exhibit list should be provided in both a PDF version and in WordPerfect format (X9 or earlier versions) or Microsoft Word (Word 365 or earlier versions) to the Court’s generic chambers e-mail address (pa_chambers@cacd.uscourts.gov).

Required

Always

Format

PDF

Joint jury instructions, verdict form, and interrogatories must be submitted in WordPerfect/Word formats to chambers email.

The parties shall meet and confer sufficiently in advance of the required filing date with the objective of submitting one set of agreed upon instructions, verdict form and, if necessary, special interrogatories. The parties should also submit a copy of each of these documents in WordPerfect format (X9 or earlier versions) or Microsoft Word (Word 365 or earlier versions) to the Court’s generic chambers e-mail address (pa_chambers@cacd.uscourts.gov).

Jury instructions must be submitted as clean set in WordPerfect or Word format with specific formatting.

submission of jury instructions to the Court’s generic chambers e-mail address shall contain a “clean set” of Joint Proposed and/or Disputed Jury Instructions, containing only the text of each instruction set forth in full on each page, with the caption “Court’s Instruction No. ___” (eliminating titles, supporting authority, indication of party proposing, etc.) in WordPerfect format (X9 or earlier versions) or Microsoft Word (Word 365 or earlier versions).

Each jury instruction must be on separate page with citation.

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.

Format

PDF

Underscore required between exhibit number and description, prohibited elsewhere in filename.

The use of the “underscore” character is required when a description of the exhibit is included and cannot be used elsewhere in the exhibit name.

Format

PDF

Exhibits.txt file must be in same folder as exhibit files.

The “Exhibits.txt” file must be in the same folder or directory as all the exhibits.

Format

PDF

Exhibit descriptions limited to 130 characters including spaces.

IMPORTANT: The exhibit description for either method may not exceed 130 characters, including spaces.

Format

PDF

Prohibited characters in exhibit descriptions: quotation marks, brackets, parentheses, accent marks.

Quotation marks, brackets, parentheses, and foreign language accent marks MAY NOT be used in the exhibit description.

Format

PDF

Exhibit filenames must not begin with a number.

The file name MUST NOT begin with a number.

Format

PDF

Hyphens and underscores must only be used as shown in examples.

Hyphens and underscore characters must be used only as shown in the examples above.

Format

PDF

Motions, oppositions, and replies must be electronically filed only.

Motions, Oppositions, and Replies shall be electronically filed only.

Format

PDF

Supporting documents must be electronically filed as attachments to the corresponding brief.

With the exception of physical exhibits, all documents supporting the motion, opposition, or reply (e.g., declarations, exhibits, statements of undisputed or disputed facts, judicial notices) shall also be electronically filed only, and filed as attachments to the corresponding brief.

Each supporting document must be filed as an individual attachment with its own link and title designation.

Furthermore, each supporting document shall be filed as an individual attachment, such that each document can be accessed by its own individual link. Each attachment shall be designated by the title of the document.

Required

Always

Format

PDF

All documents must be converted to PDF and be PDF searchable.

Counsel shall adhere to Local Rule 5-4.3.1 with respect to the conversion of all documents to a PDF so that when a document is electronically filed, it is in the proper size and format that is PDF searchable.

Required

Always

Format

PDF

Documents must be converted to searchable PDF format per Local Rule 5-4.3.1.

Counsel shall adhere to Local Rule 5-4.3.1 with respect to the conversion of all documents to a PDF so that when a document is electronically filed, it is in the proper size and format that is PDF searchable.

Trial exhibits must be placed in three-ring binders indexed by exhibit number with right-side tabs, spine labeled with volume number, include exhibit index, be numbered per FRCP 16/26 and Local Rules, with original and one copy submitted to court.

Counsel are to prepare their exhibits for presentation at the trial by placing them in binders which are indexed by exhibit number with tabs or dividers on the right side. Counsel shall submit to the Court an original and one copy of the binders. The exhibits shall be in a three-ring binder labeled on the spine portion of the binder as to the volume number and contain an index of each exhibit included in the volume. Exhibits must be numbered in accordance with Fed.R.Civ.P. 16, 26 and the Local Rules.

Original exhibits submitted to Courtroom Deputy on first day of trial must have Court exhibit tags stapled upper right front, with case number/name/exhibit number on tags, obtained from Clerk’s Office Room G-8.

The Court requires that the following be submitted to the Courtroom Deputy Clerk on the first day of trial: • The original exhibits with the Court's exhibit tags shall be stapled to the front of the exhibit on the upper right-hand corner with the case number, case name, and exhibit number placed on each tag. Exhibit tags can be obtained from the Clerk’s Office, Room G-8, 312 North Spring Street, Los Angeles, CA 90012.

Spaced font must be 14-point or larger; monospaced font may not exceed 10.5 characters per inch.

Pursuant to Local Rule 11-3.1.1, spaced font must be 14-point or larger, or as the Court may otherwise order. A monospaced font may not contain more than 10½ characters per inch.

Required

Always

Format

PDF

Counsel must convert all documents to PDF per Local Rule 5-4.3.1 for electronic filing.

Counsel shall adhere to Local Rule 5-4.3.1 with respect to the conversion of all documents to a PDF so that when a document is electronically filed, it is in the proper size and format that is PDF

Exhibits must be in three-ring binders with tabs, spine labeling, and index.

Counsel are to prepare their exhibits for presentation at the trial by placing them in binders which are indexed by exhibit number with tabs or dividers on the right side. Counsel shall submit to the Court an original and one copy of the binders. The exhibits shall be in a three-ring binder labeled on the spine portion of the binder as to the volume number and contain an index of each exhibit included in the volume. Exhibits must be numbered in accordance with Fed.R.Civ.P. 16, 26 and the Local Rules.

Format

PDF

All documents must be converted to PDF format and be searchable.

Preparation of Documents/PDF. Counsel shall adhere to Local Rule 5-4.3.1 with respect to the conversion of all documents to a PDF so that when a document is electronically filed, it is in the proper size and format that is PDF searchable.

Original exhibits must be stapled with Court's exhibit tags on the upper right corner showing case number, case name, and exhibit number, and submitted on the first day of trial.

The Court requires that the following be submitted to the Courtroom Deputy Clerk on the first day of trial: • The original exhibits with the Court’s exhibit tags shall be stapled to the front of the exhibit on the upper right-hand corner with the case number, case name, and exhibit number placed on each tag. Exhibit tags can be obtained from the Clerk’s Office, Civil/Criminal Intake Windows, Roybal Courthouse.

Evidentiary objections must use three-column format with quote, legal objection, and citation.

Such objections shall be submitted in the following three-column format: (1) the left column should contain a verbatim quote of each statement objected to (including page and line number); (2) 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 (3)

Required

Always

Exhibits must be indexed with tabs, numbered sequentially, and pages numbered.

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. All exhibit tabs are to be stapled to the first page of the exhibit. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc. See Local Rule 16-6. Every page of a multi-page exhibit must be numbered. Defendant’s exhibit numbers shall not duplicate Plaintiff’s numbers.

Required

Always

Copy exhibits must have copies of official tags and be indexed with tabs.

The copies of exhibits must bear copies of the official exhibit tags that were placed on the original exhibits and be indexed with tabs or dividers on the right side. For electronic exhibits, the copies should not include any physical flash drives or CDs.

Required

Always

Plaintiff and Defendant exhibits in separate folders with numbered filenames.

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 (e.g., “Ex. 1 – Smith Declaration.pdf” or “Ex. 105 –Letter Dated 1-5-20.pdf”).

Format

PDF

E-filed items not requiring court signature and proposed orders must be text-searchable PDF format.

Items that do not require the Court’s signature shall be e-filed in text searchable portable document format (PDF). Proposed orders shall be e-filed in text searchable PDF format as an attachment to the main documents.

Proposed orders must use Court’s template, be on pleading paper, and omit attorney info, footers, and watermarks.

Use the “Proposed Order” template located on the Court’s website under “Orders & Additional Documents” at the bottom of the webpage. (https://www.cacd.uscourts.gov/honorable-serena-r-murillo). Failure to do so may result in the striking of the request. Proposed orders must be on pleading paper. Proposed orders should NOT contain any of the following: (1) attorney names, addresses, etc. on the caption page; (2) a footer with the document name or other information; (3) a watermark or designation of the firm name. Proposed orders should be formatted in the same fashion as motions. See infra paragraph G.4.

Exhibits and declarations attached to chambers copies must be tabbed; mandatory chambers copies do not require blue backing.

Where applicable, any exhibits or declarations attached to chambers copies must be tabbed. Mandatory Chambers Copies need NOT be blue backed.

Format

PAPER

Chambers copies must be printed from CM/ECF with CM/ECF headers on each page and NEF as last page, and not left in envelopes or folders.

“Chambers copies must be printed from CM/ECF and must include: (1) the CM/ECF-generated header (consisting of the case number, document control number, date of filing, page number, etc.) at the top of each page; and (2) the NEF [notice of electronic filing] (see L.R. 5-3.2.1) as the last page of the document.” Local Rule 5-4.5 (emphasis added). For security reasons, do not leave chambers copies in envelopes or folders.

Chambers copy exhibits must be tabbed; evidence over 50 pages requires table of contents and tabbed binder with three-hole punched documents.

If chambers copies are ordered, all exhibits should be separated by a tab divider on the right or bottom of the document. If the evidence exceeds 50 pages, the Chambers Copy must (1) include a table of contents and (2) be in a tabbed binder with each exhibit separated by a tab divider on the right or the bottom. All documents in the binder must be three-hole punched, preferably with a larger hole size (13/32”) rather

Chambers copy evidence over 200 pages must be in a Slant D-Ring binder (max 4 inches) with cover sheet and spine label including case details.

200 pages, the table of contents and evidence must be placed in a Slant D-Ring binder. Binders should be no larger than 4 inches. Binders must have both a cover sheet and a spine label that includes the case name, case number, and a description of the contents.

Motion memoranda must use Times New Roman font at least 14 point; footnotes must match body font and size, with proportionally or monospaced typeface permitted per Local Rule 11-3.1.1.

Pursuant to Local Rule 11-3.1.1, either a proportionally spaced or monospaced face may be used. Typeface shall comply with Local Rule 11-3.1.1. Times New Roman font must be no less than 14 point. Footnotes shall be in the same font and the same size as the body of the memorandum.

Required

Always

Format

PDF

All documents must be filed as searchable PDF format with selectable, copyable, and pasteable text per Local Rule 5-4.3 and C.D. Cal. R. 5-4.3.1.

Counsel shall adhere to Local Rule 5-4.3 with respect to the conversion of all documents to PDF format so that when a document is electronically filed, it is in proper size and is PDF searchable. Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document. See C.D. Cal. R. 5-4.3.1.

Briefs must use Times New Roman font at least 14 point; footnotes same font/size, max 8 footnotes total per party.

Pursuant to Local Rule 11-3.1.1, either a proportionally spaced or monospaced face may be used. Times New Roman font must be no less than 14 point. Footnotes shall be in the same font and the same size as the body of the memorandum. Each party is limited to using of a total of eight (8) footnotes.

Required

Always

Format

PDF

All electronically filed documents must be PDF format, searchable, with selectable/copyable/pasteable text.

Counsel shall adhere to Local Rule 5-4.3 with respect to the conversion of all documents to PDF format so that when a document is electronically filed, it is in proper size and is PDF searchable. Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document. See C.D. Cal. L.R. 5-4.3.1.

Applies to

Joint appendix of facts

JAF must be a four-column table with specific content requirements for each column.

The Joint Brief shall be accompanied by a single statement of undisputed and disputed facts contained in a Joint Appendix of Facts (JAF) presented in a table format. 1. Table Format. The JAF table shall contain four columns. (a) Column No. 1. The first (far left) column shall contain the number of the fact alleged to be undisputed. All asserted undisputed facts shall be sequentially numbered and divided into sections according to the element of proof to which the facts relate. (b) Column No. 2. The second column shall contain a plain statement of the fact. Facts shall not be compound (e.g., Mike and Jane signed a contract, and Jane mailed the contract in May 2017). Each fact must be stated separately in its own row, as shown below. Neither legal arguments nor conclusions constitute facts. Facts shall not be repeated if they relate to multiple claims for multiple elements of proof. The first reference to a fact in the Joint Appendix of Facts shall serve and—through incorporation by reference—can be cited to support all subsequent claims (e.g., “See JAF 1–5”). (c) Column No. 3. The third column shall contain a citation to admissible evidence that supports the proffered fact; the evidence cited must be included in the Joint Appendix of Evidence. If citing to a specific page contained within an exhibit, refer to the page number. If citing to statements contained within a deposition transcript, refer to the page number and line number. If citing to an excerpt of an audio recording or video footage, refer to the timestamp. If citing to multiple sources, each should be separated by semicolons. (d) Column No. 4. The fourth column shall contain the opposing party’s

JAE must be a separate, tabbed appendix of all MSJ evidence.

a separate, tabbed appendix of all evidence in support of or opposition to the MSJ,

Applies to

JAE

Format

PDF

JAE must be filed as a single combined PDF unless file size constraints require multiple PDFs, which must be titled by part and exhibit series.

The JAE shall include a table of contents and be filed as a single, combined PDF; more than one PDF may be filed if file-size constraints preclude filing the JAE as a single PDF. In the event multiple PDFs are necessary to file the JAE, each file shall be titled by part and exhibit series (e.g., JAE Part 1, Exhibits 1–50).

Applies to

JAE

Each exhibit in JAE must be bookmarked with exhibit number and brief description.

Each exhibit within the JAE must be bookmarked; the bookmark should include the exhibit number and a brief description of the exhibit (e.g., Ex. 1 – Jones Depo. Excerpts).

Applies to

JAO

JAO must be presented in a four-column table with specified columns.

evidentiary objections, if any, shall be made in a single, separate document presented in a four-column table as follows: Objector Evidence Objection (O) / Response (R) Ruling

Required

Always

Times New Roman font must be at least 14 point; footnotes must match body font and size; typeface must comply with Local Civil Rule 11-3.1.1.

Pursuant to Local Civil Rule 11-3.1.1, either a proportionally spaced or monospaced typeface may be used. Typeface shall comply with Local Civil Rule 11-3.1.1. Times New Roman font must be no less than fourteen (14) point. Footnotes shall be in the same font and the same size as the text in the body of the document.

Required

Always

Format

PDF

All e-filed documents must be converted to searchable PDF with selectable, copyable text per Local Civil Rules 5-4.3 and 5-4.3.1.

Counsel must follow the Local Rules and General Orders concerning electronic filing, unless superseded by this Order. Counsel shall adhere to Local Civil Rule 5-4.3 with respect to the conversion of all documents to portable document format (PDF) so that when a document is e-filed, it is in the proper size and is PDF searchable. Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document. See Local Civil Rule 5-4.3.1.

Format

DOCX

Specified FPTC documents must be in Microsoft Word (DOCX) format.

No later than one (1) week before the FPTC, the government shall file and email the documents described below in Microsoft Word format to SRM_Chambers@cacd.uscourts.gov: • A trial memorandum; • Proposed voir dire questions, if any; • A witness list; • An exhibit list; • A joint case-specific glossary for the CRD;

Disputed jury instructions must be organized by subject, with similar issues presented sequentially.

Where appropriate, the disputed instructions shall be organized by subject, so that instructions that address the same or similar issues are presented sequentially.

Jury instructions must not contain blanks or inapplicable bracketed text; brackets must be filled with case-specific information, standard language unchanged.

Counsel should not leave blanks or inapplicable bracketed text in any instruction. It is counsel’s duty to conform the instructions to the case (e.g., inserting names of defendant(s) or witness(es) to whom the instruction applies and selecting the appropriate bracketed text, but not changing the standard language of the instruction). Where language appears in brackets in the model instruction, counsel must select the appropriate text and eliminate the inapplicable bracketed text.

Format

DOCX

Clean jury instruction set must be in Word format, only instruction text, full on each page, captioned as Instruction No. ___.

Counsel shall submit to the Chambers email SRM_Chambers@cacd.uscourts.gov a “clean” set of all instructions in Word format that will be given to the jury, containing only the text of each instruction, set forth in full on each page, with the caption “Instruction No. ___” (eliminating the title and source of the instruction, supporting authority, etc.).

Contraband exhibits must stay in law enforcement custody; US Marshals must be advised in advance; placeholder page required in exhibit binder.

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 the 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 a weapon or contraband is to be brought into the courthouse. A placeholder page listing the nature of the exhibit (i.e., firearm, methamphetamine, etc.) and exhibit number shall be placed in the exhibit binder.

Defense counsel must affix completed exhibit tags with case name and number to all defense exhibits.

Defense counsel is responsible for affixing completed exhibit tags with the case name and case number to all exhibits to be used in defendant’s case.

Defense counsel must provide three exhibit binders if admitting more than 10 exhibits; exhibits should be tabbed by number.

In trials where the defense expects to admit more than ten (10) exhibits, defense counsel shall provide three exhibit binders, as described below. If possible, the exhibits are to be tabbed with numbers to correspond to the exhibits counsel expects to introduce.

All trial exhibits must be submitted in three three-ring binders (1 original, 2 copies); parties must review with CRD before jury use.

Trial exhibits containing documents and photographs must be submitted to the Court in three-ring binders. The parties must submit to the court three binders: (1) one binder containing the original set of trial exhibits; and (2) two binders containing copies of the trial exhibits. The original set of exhibits will be used by the jury during its deliberations, and the copies are for the Court. The parties must prepare additional copies of exhibits for their own use and for use by witnesses. The parties must review the exhibit list and exhibit binders with the CRD before the admitted exhibits will be given to the jury.

Trial exhibits must be indexed by number with right-side tabs, sequentially numbered, multi-page exhibits page-numbered, binder spines labeled with case details.

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc. See Local Civil Rule 16-6. Every page of a multi-page exhibit must be numbered. Defendant’s exhibit numbers shall not duplicate Plaintiff’s numbers. The spine of each binder shall indicate the name of the case, case number, exhibit volume number, and the range of exhibit numbers included in the volume.

Original exhibits must have official color-coded tags (yellow gov, blue defendant) on front upper right; copy exhibits must have tag copies and be indexed.

The original exhibits shall bear the official exhibit tags (yellow tags for government’s exhibits and blue tags for defendant’s exhibits) affixed to the front upper right-hand corner of the exhibit, with the case number, case name, and exhibit number stated on each tag. The parties may print their own exhibit tags using Forms G-14A and G-14B on the “Court Forms” section of the Central District of California’s website. The copies of exhibits must bear copies of the official exhibit tags that were placed on the original exhibits and be indexed with tabs or dividers on the right side.

Sentencing videos are only permitted with leave of court and good cause, must be under 10 minutes, include a transcript, and be provided to opposing counsel 21 days before hearing.

Absent leave of Court and based upon a showing of good cause, the Court does not permit the submission or playing of sentencing videos. Before considering any sentencing video, the Court requires counsel to justify its submission, limit the video to less than ten (10) minutes, create a transcript, and provide the video and transcript to opposing counsel at least twenty-one (21) days before the hearing.

Required

Always

Format

DOCX

Emailed submissions to Chambers must be in Word format and sent to SRM_Chambers@cacd.uscourts.gov.

All emailed submissions to Chambers referred to in this Order must be in Word format and emailed to SRM_Chambers@cacd.uscourts.gov.

Exhibit binders must be formatted with tabs, sequential numbering, page numbering, spine labels, and official exhibit tags with specific colors and information.

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. All exhibit tabs are to be stapled to the first page of the exhibit. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc. See Local Rule 16-6. Every page of a multi-page exhibit must be numbered. Defendant’s exhibit numbers shall not duplicate Plaintiff’s numbers. The spine of each binder shall indicate the volume number and the range of exhibit numbers included in the volume. The original exhibits shall bear the official exhibit tags (yellow tags for Plaintiff’s exhibits, blue tags for Defendant’s exhibits, and green tags for joint exhibits) affixed to the front upper right-hand corner of the exhibit, with the case number, case name, and exhibit number stated on each tag. Tags may be obtained from the Clerk’s Office, or the parties may print their own exhibit tags using Forms G-14A and G-14B on the “Court Forms” section of the Central District of California’s website. For electronic exhibits, the parties should provide a physical caption page with the exhibit tag and attach the physical flash drive or CD containing the electronic exhibits. If there are voluminous electronic exhibits, the parties should raise the issue with the Court at the Final Pretrial Conference. The copies of exhibits must bear copies of the official exhibit tags that were placed on the original exhibits and be indexed with tabs or dividers on the right side. For electronic exhibits, the copies should not include any physical flash drives or CDs.

USB flash drive must have separate folders for plaintiff and defendant exhibits, and file names must include exhibit number and brief description.

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 (e.g., “Ex. 1 – Smith Declaration.pdf” or “Ex. 105 –Letter Dated 1-5-20.pdf”).

Filings must use proportionally spaced or monospaced typeface per Local Civil Rule 11-3.1.1.

Format of filings. Pursuant to Local Civil Rule 11-3.1.1, either a proportionally spaced or monospaced face may be used. Typeface shall comply with Local

Courier font required at 12 point minimum; footnotes same font/size as body text.

Courier font must be no less than twelve (12) point. Footnotes shall be in the same font and the same size as the text in the body of the document.

Format

PDF

All documents must be converted to searchable PDF with selectable text.

Counsel must follow the Local Rules and General Orders concerning electronic filing, unless superseded by this Order. Counsel shall adhere to Local Civil Rule 5-4.3 with respect to the conversion of all documents to .pdf so that when a document is e-filed, it is in the proper size and is .pdf searchable. Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document. See Local Civil Rule 5-4.3.1.

Required

Always

Margins

1 in

Jury instructions must not contain blanks or bracketed text; counsel must customize instructions to the case.

No Blanks or Bracketed Language. Counsel should not leave blanks or inapplicable bracketed text in any instruction. It is counsel’s duty to conform the instructions to the case (e.g., inserting names of defendant(s) or witness(es) to whom the instruction applies and selecting the appropriate bracketed text, but not changing the standard language of the instruction). Where language appears in brackets in the model instruction, counsel must select the appropriate text and eliminate the inapplicable bracketed text.

Required

Always

Attachments must be filed as separately docketed entries with descriptions.

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 - License Agreement, 29-3 Request for Judicial Notice). The Court may strike or decline to consider motions, stipulations, or other documents with attachments that are not filed in accordance with this Order.

Proposed orders must use court template, be on pleading paper, and avoid attorney info, footers, and watermarks.

Use the “Proposed Order” template located on the Court’s website under “Orders & Additional Documents” at the bottom of the webpage. (http://www.cacd.uscourts.gov/honorable-sherilyn-peace-garnett). Failure to do so may result in the striking of the request. Proposed orders must be on pleading paper. Proposed orders should NOT contain any of the following: (1) attorney names, addresses, etc. on the caption page; (2) a footer with the document name or other information; or (3) a watermark or designation of the firm name. Proposed orders should be formatted in the same fashion as motions. See infra paragraph G.4.

Required

Always

Counsel must ensure witness returns to stand after recess or adjournment.

After a recess or adjournment, counsel shall ensure that his or her witness returns to the stand before trial resumes.

Required

Always

Strict timeliness required for all parties and counsel.

The parties and their counsel are ordered to be on time. The Court requires strict compliance with this order.

All filings must use 14-point Times New Roman font for text and footnotes.

Typeface and spacing shall comply with Local Rule 11-3.1.1, except that the parties must use only 14-point Times New Roman font (for text and footnotes).

Binders over 200 pages require slant D-ring binder.

A binder with more than 200 pages must be placed in a slant D-ring binder.

Required

Always

All trial remarks must be addressed to the Court, not to CRD, court reporter, or opposing counsel.

All remarks at trial shall be addressed to the Court. Counsel shall not directly address the CRD, the court reporter, or opposing counsel without the Court's permission; and all requests to read back questions/answers or to place an exhibit before a witness shall be addressed to the Court.

Required

Always

Food, beverages (except water), and cell phones prohibited in courtroom.

No food or beverage other than water is permitted in the courtroom. No cell phone is permitted in the courtroom unless it is turned off; and it may be confiscated if it interrupts the proceedings.

Required

Always

Specific movement and positioning requirements for counsel during trial.

Counsel shall rise when addressing the Court and when the jury enters or leaves the courtroom. Counsel shall remain at the lectern when questioning a witness or giving an opening statement or closing argument. Counsel shall not approach the witness or enter the well without the Court's permission and shall return to the lectern when the permitted purpose has been accomplished. Counsel shall not leave counsel table to confer with investigators, witnesses, or others while court is in session without the Court's permission.

Required

Always

Objections must be brief and state only legal grounds, no factual argument.

No 'speaking objections' are allowed. Rise and state only the legal grounds of the objection (e.g., 'Objection, hearsay'). If the Court invites either clarification of the legal grounds for the objection or a response, do not abuse the invitation by providing factual argument before the jury.

Required

Always

Exhibit handling rules: must provide copies to Court and opposing counsel, only display admitted exhibits, use electronic projection.

No exhibit shall be placed before a witness unless a copy has been provided to the Court and opposing counsel. Nor shall any exhibit be displayed to the jury unless previously admitted or agreed upon by all counsel. Once approved, an exhibit may be published by electronic projection, not by handing it to the jurors.

Required

Always

Stipulation requirements: agreement with opposing counsel, explanation to defendant, defendant's personal agreement, written submission to Court.

Counsel should not offer a stipulation without having reached agreement with opposing counsel about its precise terms and without it having been fully explained to the defendant(s). Any stipulation of fact requires the defendant's personal agreement and shall be submitted to the Court in writing for approval.

Required

Always

Only one lawyer per party may examine and handle objections for each witness.

For each witness, a party may only have one lawyer who examines, and handles objections for, the witness.

Required

Always

Witnesses 18 or older must be referred to by full name, not first name only.

During trial, counsel shall not refer to any witness 18 years of age or older —including a client— by first name.

Required

Always

Witnesses must be available throughout court day or party risks being deemed to have rested.

Counsel shall have witnesses available throughout the court day or risk being deemed to have rested.

Required

Always

Counsel must notify CRD in advance of witness interpreter or ADA accommodation needs.

Counsel must notify the CRD in advance if a witness requires an interpreter or an accommodation under the Americans with Disabilities Act (or for any other reason).

Format

PDF

JAE must include a table of contents, be filed as a single PDF (or multiple if file-size constraints), each file titled by part and exhibit series, and each exhibit bookmarked with number and description.

The JAE shall include a table of contents. The JAE shall be filed as a single, combined PDF; more than one PDF may be filed if file-size constraints preclude filing the JAE as a single PDF. In the event multiple PDFs are necessary to file the JAE, each file shall be titled by part and exhibit series (e.g., JAE Part 1, Exhibits 1–50). Each exhibit within the JAE must be bookmarked; the bookmark should include the exhibit number and a brief description of the exhibit (e.g., Ex. 1 – Jones Depo. Excerpts).

JAO must be formatted as a three-column table with columns for Objector, Evidence, and Objection/Response.

The parties shall prepare a Joint Appendix of Objections (JAO) containing any evidentiary objections in a single, separate document presented in a three-column table as follows: Objector Evidence Objection (O)/Response (R)

Each jury instruction must cite authority, be complete, single-page, numbered, cover one subject, and not repeat other instructions.

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. Counsel may submit alternatives to these instructions only if counsel has a reasoned argument that they do not properly state the law or are incomplete.

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Binder spine must show volume number; each volume needs an exhibit index.

The spine portion of the binder must indicate the volume number, and each volume must contain an index of each exhibit included therein.

14-point Times New Roman font required; footnotes separated by 12-point spacing.

iv. Format. Use only 14-point Times New Roman font, including for footnotes. Footnotes shall be separated by 12-point spacing.

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Exhibits must be placed in three-ring binders with tabs/dividers on the right side.

Exhibits must be placed in three-ring binders indexed by exhibit number with tabs or dividers on the right side.

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Original exhibits must have yellow (plaintiff) or blue (defendant) tags with case info.

One binder (or set of binders) of original exhibits with the Court’s exhibit tags, yellow tags for plaintiff and blue tags for defendant, stapled to the front of the exhibit on the upper right-hand corner with the case number, case name, and exhibit number placed on each tag.

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Exhibits (except impeachment) must have official tags with numbers from Court website.

All exhibits (except those to be used for impeachment only) should have official exhibit tags attached and bear the same number shown on the Court’s website (Form G-14A plaintiff, Form G-14B defendant) and may be used in place of the tags obtained from the Clerk’s office.

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Court copy of exhibits must be tabbed but does not need exhibit tags.

One binder (or set of binders) with a copy of each exhibit tabbed with numbers as described above for use by the Court. (Exhibit tags are not necessary on these copies.)

Different colored ink must be used for designations: black for plaintiff, red for defendant.

For all depositions offered in the case, the parties shall consistently use different colored ink—black for plaintiff and red for defendant—to designate the testimony to be offered, objections, and responses to objections.

Instructions must not contain blanks or bracketed text.

(c) No Blanks/Brackets. Do not leave blanks or inapplicable bracketed text in any instruction. It is counsel’s duty to conform the instructions to the case (e.g., inserting names of defendant(s) or witness(es) to whom the instruction applies and selecting the appropriate bracketed text).

Required

Always

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Format

PDF

Non-signature items must be PDF. Proposed signature items must be PDF attachment plus Word version emailed to chambers on filing day.

Non-Signature Items: must be filed in PDF format. Proposed Signature Items: must be filed as an attachment to the main document in PDF format. All proposed signature items must also be emailed in Microsoft Word ("Word") format to the chambers email at SSS_Chambers@cacd.uscourts.gov on the day the document is filed. Only proposed order signature items should be emailed to the chambers' email address. Do not email other associated documents and do not use this email address for communication with the Court or the Clerk.

Discovery documents must include “DISCOVERY MATTER” in caption

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

Briefing must use Times New Roman, 14pt text, 12pt footnotes.

All briefing must use Times New Roman font. Text must be no less than fourteen (14) point font; footnotes must be no less than twelve (12) point font.

Required

Always

Format

PDF

All documents must be converted to searchable PDF format.

Counsel must adhere to Local Rule 5-4.3 with respect to the conversion of all documents to .pdf format so that when a document is electronically filed, it is in proper size and is .pdf searchable. Further, all documents must be filed in a format so that text can be selected, copied, and pasted directly from the document.

Documentary evidence over 50 pages must be separately bound, tabbed, and indexed.

If documentary evidence in support of or in opposition to a motion exceeds 50 pages, the evidence must be separately bound and tabbed and include an index.

Documentary evidence over 200 pages must be in three-ring binder with index and tab dividers.

If such evidence exceeds 200 pages, the documents must be placed in a three-ring binder, with an index and with each item of evidence separated by a tab divider.

Required

Always

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Case law citations must include specific page numbers and use Bluebook style, preferring Westlaw over Lexis.

Citations to case law must identify the case cited and the specific page referenced. For example, if a quotation is presented, the associated page citation must 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 must be provided. When citing to legal databases, wherever possible cite to Westlaw rather than Lexis. Bluebook style is required.

Required

Always

Statutory and other citations must be specific and use Bluebook style.

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 must include the docket entry number, section, and pages referenced. Bluebook style is required.

Motions in limine require three-ring binder with specific formatting.

The Mandatory Chambers Copy of all motions in limine and associated exhibits must be provided in a three-ring binder. Plaintiffs’ and Defendants’ motions should be placed together in a single 3-inch binder if possible; if these materials do not fit easily into a 3-inch binder, the parties may submit separate binders. In either case, each motion should be tabbed and accompanied by the corresponding Memorandum of Opposition.

Trial exhibits must be submitted in three-ring binders (1 original, 2 copies).

Trial exhibits that consist of documents and photographs must be submitted to the Court in three-ring binders. The parties must submit to the Court three (3) sets of binders: one (1) original set of trial exhibits, and two (2) copies of trial exhibits.

Exhibits must be sequentially numbered with right-side tabs, no duplicates.

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. Exhibits must be numbered sequentially as 1, 2, 3, etc., not 1.1, 1.2, etc. See Local Rule 16-6. Every page of a multi-page exhibit must be numbered. Defendant’s exhibit numbers must not duplicate Plaintiff’s numbers.

Original exhibits require official yellow/blue tags with case info.

The original exhibits must bear the official exhibit tags (yellow tags for Plaintiff’s exhibits and blue tags for Defendant’s exhibits) affixed to the front upper right-hand corner of the exhibit, with the case number, case name, and exhibit number stated on each tag.

Required

Always

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Counsel must use lectern and cannot use PowerPoint during opening statements without stipulation.

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. Counsel are not permitted to use any PowerPoint presentations during opening statement unless stipulated to by both parties.

Required

Always

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Filing titles must include defendant names, registration numbers when applicable, and milestone dates

The captioned title of every filing must contain: (1) the name of the first-listed defendant as well as the name(s) and number(s) of the particular defendant(s) to whom the filing applies (in the order listed in the Indictment), unless the document applies to all defendants; (2) the individual defendant's registration number when applicable to the relief requested (e.g., requests for transfer, medical requests); and (3) the milestone dates for Indictment, Final Pretrial Conference, Trial, and Last Day of the speedy trial period.

Sealed/in camera documents must use first-listed defendant and case number only on outer envelope

The outer envelope containing any document filed under seal or in camera should identify the case title by the first-listed defendant and case number only and should state that the document is being filed under seal or in camera.

All briefing must use Times New Roman, 14pt text, 12pt footnotes

Pursuant to Local Civil Rule 11-3.1.1, either a proportionally spaced or monospaced font may be used. All briefing must use Times New Roman font. Text must be no less than size fourteen (14) point font; footnotes must be no less than size twelve (12) point font.

Required

Always

Format

PDF

All documents must be converted to searchable PDF with selectable text

Counsel must follow the Central District's Local Rules and General Orders concerning electronic filing, unless superseded by this Order. Counsel must adhere to Local Civil Rule 5-4.3 with respect to the conversion of all documents to .pdf so that when a document is filed, it is in the proper size and is .pdf searchable. Further, all documents must be filed in a format so that text can be selected, copied, and pasted directly from the document. See Local Civil Rule 5-4.3.1.

Required

Always

Format

DOCX

Email submissions to Chambers must be in Word format.

Submissions emailed to Chambers pursuant to this Order must be in Microsoft Word (“Word”) format and emailed to SSS_Chambers@cacd.uscourts.gov.

Three-ring binders required for trial exhibits with specific set requirements

Trial exhibits that consist of documents and photographs must be submitted to the Court in three-ring binders. The parties must submit to the Court three (3) sets of binders: one (1) binder with the original set of trial exhibits, and two (2) binders with copies of trial exhibits. The original set of exhibits must be for use by the jury during its deliberations, and the two sets of copies are for the Court.

Exhibit numbering and indexing requirements for three-ring binders

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. Exhibits must be numbered sequentially: 1, 2, 3, etc., not 1.1, 1.2, etc. See Local Civil Rule 16-6. Every page of a multi-page exhibit must be numbered. Defendant's exhibit numbers must not duplicate the government's numbers. The spine of each binder must indicate the volume number and the range of exhibit numbers included in the volume.

Official exhibit tags required with specific color coding

The original exhibits must bear the official exhibit tags (yellow tags for the government's exhibits and blue tags for defendant's exhibits) affixed to the front upper right-hand corner of the exhibit, with the case number, case name, and exhibit number stated on each tag. Tags may be obtained from the Clerk's Office, or the parties may print their own exhibit tags using Forms G-14A and G-14B on the "Court http://www.cacd.uscourts.gov/forms/exhibit-tags-plaintiff-defendant.

Format

PDF

PDF versions of exhibits on USB required one week before trial

In addition to the three (3) sets of binders mentioned above, the parties must also submit to the Court a USB flash drive containing .pdf versions of all exhibits one (1) week before the start of trial. The USB flash drive should be delivered to Judge Sykes' "Courtesy Box" located outside of Courtroom 2 on the 2nd floor at the United States District Court, 3470 12th Street, Riverside, California 92501. The government's exhibits should be placed in a separate electronic folder from defendant's exhibits, if any, 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."

Required

Always

Briefing must use Times New Roman font; all text must be at least 14pt, footnotes at least 12pt; other filings may use proportional or monospaced fonts.

Pursuant to Local Civil Rule 11-3.1.1, either a proportionally spaced or monospaced font may be used. All briefing must use Times New Roman font. Text must be no less than size fourteen (14) point font; footnotes must be no less than size twelve (12) point font.

All briefing must use Times New Roman font.

All briefing must use Times New Roman font.

Required

Always

Format

PDF

All documents must be converted to searchable PDF format with selectable, copyable text.

Counsel must adhere to Local Civil Rule 5-4.3 with respect to the conversion of all documents to .pdf so that when a document is filed, it is in the proper size and is .pdf searchable. Further, all documents must be filed in a format so that text can be selected, copied, and pasted directly from the document. See Local Civil Rule 5-4.3.1.

Required

Always

Format

DOCX

All emailed submissions to Chambers must be in Microsoft Word format and sent to the specified chambers email address.

Submissions emailed to Chambers pursuant to this Order must be in Microsoft Word (“Word”) format and emailed to SSS_Chambers@cacd.uscourts.gov.

Format

DOCX

Proposed orders must use the template from Judge Sykes’ webpage and be in Microsoft Word format, with non-compliance risking strike of the motion.

The parties must use the template for proposed orders available on Judge Sykes’ webpage3 and submit in Word format. Failure to use the provided template or submit in Word format may result in the Court striking the motion, application, or stipulation without consideration of the request on its merits.

Format

DOCX

Amended witness lists must be in Word format when filed and emailed to Chambers.

Any Amended Witness List must be filed and emailed to Chambers in Word format by 12:00 p.m. (noon) on the Friday before trial.

Format

DOCX

Amended exhibit lists must be in Word format when filed and emailed to Chambers.

Any Amended Exhibit List must be filed and emailed to Chambers in Word format by 12:00 p.m. (noon) on the Friday before trial.

Each proposed jury instruction must be numbered, on a separate page, full text, cite authority, cover one subject, not repeat other instructions, and fill blanks in standard instructions.

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

Disputed jury instructions must include objection basis, authority, and alternative on a separate page, be organized by subject, and excessive disagreements trigger a meet and confer order.

For any disputed instruction, the opponent must state on a separate page following the disputed instruction (1) the basis for the objection, (2) authority supporting the objection, and (3) an alternative instruction (if applicable). On the authority. Where appropriate, the disputed instructions must be organized by subject, so that instructions that address the same or similar issues are presented sequentially. If there are excessive or frivolous disagreements over jury instructions, the Court will order the parties to meet and confer until the parties narrow their disputes.

Format

DOCX

Clean set of jury instructions must be in Word format, contain only text, full on each page, captioned “Instruction No. ___”, with no title/source/authority.

Accordingly, counsel must email Chambers 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 the title and source of the instruction, supporting authority, etc.).

Format

DOCX

Defense witness and exhibit lists must be submitted to Chambers in Word (DOCX) format.

Defense counsel must also simultaneously email to Chambers a Word version of the defense’s witness list and exhibit list.

Trial exhibits consisting of documents or photographs must be submitted in three-ring binders, with 3 total sets (1 original, 2 copies).

Trial exhibits that consist of documents and photographs must be submitted to the Court in three-ring binders. The parties must submit to the Court three (3) sets of binders: one (1) binder with the original set of trial exhibits, and two (2) binders with copies of trial exhibits.

Trial exhibits in binders must be indexed with tabs, numbered sequentially, have all pages numbered, avoid duplicate numbers between parties, and have labeled binder spines.

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. Exhibits must be numbered sequentially: 1, 2, 3, etc., not 1.1, 1.2, etc. See Local Civil Rule 16-6. Every page of a multi-page exhibit must be numbered. Defendant’s exhibit numbers must not duplicate the government’s numbers. The spine of each binder must indicate the volume number and the range of exhibit numbers included in the volume.

Original trial exhibits must have official color-coded tags with case details; copy exhibits must have tag copies and be indexed with tabs.

The original exhibits must bear the official exhibit tags (yellow tags for the government’s exhibits and blue tags for defendant’s exhibits) affixed to the front upper right-hand corner of the exhibit, with the case number, case name, and exhibit number stated on each tag. Tags may be obtained from the Clerk’s Office, or the parties may print their own exhibit tags using Forms G-14A and G-14B on the “Court http://www.cacd.uscourts.gov/forms/exhibit-tags-plaintiff-defendant. The copies of exhibits must bear copies of the official exhibit tags that were placed on the original exhibits and be indexed with tabs or dividers on the right side.

Format

PDF

Exhibits on USB must be PDF format, with government and defendant exhibits in separate folders and file names including exhibit number and description.

In addition to the three (3) sets of binders mentioned above, the parties must also submit to the Court a USB flash drive containing .pdf versions of all exhibits one (1) week before the start of trial. The government’s exhibits should be placed in a separate electronic folder from defendant’s exhibits, if any, 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.”

Format

PAPER

Stipulations of fact must be submitted in writing, require defendant's personal concurrence, be explained to the defendant in advance, and approved by the court.

Any stipulation of fact requires the defendant’s personal concurrence, must be explained to the defendant in advance, and must be submitted to the Court in writing for approval.

Sentencing videos are limited to a maximum of 10 minutes.

Videos may not exceed ten (10) minutes.

Format

PDF

Proposed orders must be e-filed in PDF format as attachments.

Proposed orders shall be e-filed in pdf format as an attachment to the main documents.

Proposed orders must follow the same formatting as motions.

Proposed orders should be formatted in the same fashion as motions.

Proposed orders must use the template from Judge Hsu's webpage.

Use the Proposed Order Template located on the Court’s website under “Orders & Additional Documents” at the bottom of Judge Hsu’s webpage

Required

Always

Chambers copy exhibits must be tabbed and three-hole punched with specific requirements for larger exhibits.

(c) Mandatory Chambers Copy Exhibits. All exhibits should be separated by a tab divider on the right or bottom of the document. If the evidence exceeds 50 pages, the Mandatory Chambers Copy must: (1) include a table of contents; and (2) be in a tabbed binder with each exhibit separated by a tab divider on the right or the bottom. All documents in the binder must be three-hole punched, preferably with a larger hole size (13/32”), rather than the standard hole size (9/32”) to facilitate ease of review. If the evidence exceeds 200 pages, the table of contents and evidence must be placed in a Slant D-Ring binder. Binders should be no larger than 4 inches. Binders have both a cover sheet and a spine label that includes the case name, case number, and a description of the contents.

Motion papers must use Times New Roman 14pt or Courier 12pt font.

Pursuant to L.R. 11-3.1.1, either a proportionally spaced or monospaced face may be used. Typeface shall comply with L.R. 11-3.1.1. Times New Roman font must be no less than 14 point; Courier font must be no less than 12 point. Footnotes shall be in the same font and the same size as the body of the memorandum.

Required

Always

Format

PDF

All documents must be converted to searchable PDF format.

Counsel shall adhere to L.R. 5-4.3 with respect to the conversion of all documents to .pdf format so that when a document is electronically filed, it is in proper size and is .pdf searchable.

Format

PDF

JAE must include table of contents, be filed as single PDF (or multiple with proper naming), and exhibits must be bookmarked.

The JAE shall include a table of contents. The JAE shall be filed as a single, combined PDF; more than one PDF may be filed if file-size constraints preclude filing the JAE as a single PDF. In the event multiple PDFs are necessary to file the JAE, each file shall be titled by part and exhibit series (e.g., JAE Part 1, Exhibits 1–50). Each exhibit within the JAE must be bookmarked; the bookmark should include the exhibit number and a brief description of the exhibit (e.g., Ex. 1 – Jones Depo. Excerpts).

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No blanks or bracketed text in jury instructions; must conform to case by inserting names and selecting appropriate bracketed text.

Counsel should not leave blanks or inapplicable bracketed text in any instruction. It is counsel’s duty to conform the instructions to the case (e.g., inserting names of defendant(s) or witness(es) to whom the instruction applies and selecting the appropriate bracketed text, but not changing the standard language of the instruction). Where language appears in brackets in the model instruction, counsel must select the appropriate text and eliminate the inapplicable bracketed text.

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Trial exhibits must be submitted in three-ring binders with one original and two copies.

Trial exhibits that consist of documents and photographs must be submitted to the Court in three-ring binders. The parties must submit to the court three binders: (1) one binder containing the original set of trial exhibits; and (2) two binders containing copies of the trial exhibits. The original set of exhibits will be for use by the jury during its deliberations, and the copies are for the Court.

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Exhibits must be indexed with tabs and numbered sequentially (1, 2, 3, etc.).

All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc.

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Binder spines must show case name, number, volume, and exhibit range.

The spine of each binder shall indicate the name of the case, case number, exhibit volume number, and the range of exhibit numbers included in the volume.