Judge Wesley L. Hsu

Counsel must e-file all filings; items not requiring court signature in PDF; proposed orders as PDF attachments.

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.

Page 5 | FILING REQUIREMENTS

Motions for attorneys’ fees must be electronically filed and set for hearing per Local Rule 6-1.

Motions for attorneys’ fees shall be electronically filed and set for hearing according to L.R. 6-1 and this Order.

Page 15 | 8. Motions for Attorneys’ Fees

Answers filed in state court must be refiled in federal court as a supplement to the Notice of Removal.

Any Answers filed in state court must be refiled in this Court as a supplement to the Notice of Removal.

Page 4 | B. PLEADING REQUIREMENTS

Counsel must e-file all filings in PDF format; proposed orders must be e-filed as PDF attachments.

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.

Page 5 | C. FILING REQUIREMENTS

Motions for attorneys' fees must be electronically filed.

Motions for attorneys’ fees shall be electronically filed and set for hearing according to L.R. 6-1 and this Order.

Page 15

Pro se litigants may file documents via EDSS instead of mail or in-person; requires internet and email; 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. Only internet access and an email address are required. Documents are submitted in PDF format through an online portal on the Court’s website.

Page 5 | FILING REQUIREMENTS

Pro se litigants may use EDSS to file documents in PDF format instead of mailing or bringing to Clerk's Office.

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. Only internet access and an email address are required. Documents are submitted in PDF format through an online portal on the Court’s website.

Page 5 | C. FILING REQUIREMENTS

Motions for summary judgment must be filed at least 6 weeks before the cut-off date.

MSJ must be filed at least six (6) weeks before the cut-off date).

Civil cases

Page 3 | 2. Non-Discovery Motions Deadline

Non-discovery motions (except MSJ) must be filed at least 28 days before the deadline.

all non-discovery motions, except for MSJ, must be filed at least twenty-eight (28) days before the deadline in accordance with the requirements of L.R. 6-1;

Civil cases

Page 3 | 2. Non-Discovery Motions Deadline

Parties must notify the Court of any settlement no later than the Monday before the trial date.

In all cases set for jury trial, the parties must notify the Court no later than the Monday preceding the trial date, of any settlement, so that the necessary arrangements can be made to bring in a different case for trial or to notify the members of the public who would otherwise be reporting for jury duty that their services are not needed that date.

Civil cases

Page 4 | 3. Settlement Proceedings/Alternative Dispute Resolution (ADR) Deadline

Proposed FPTCO must be filed at least 14 days before the Final Pretrial Conference.

A proposed Final Pretrial Conference Order (“Proposed FPTCO”) shall be filed and emailed to Chambers at least fourteen (14) days before the FPTC.

Civil cases

Page 6 | 3. Final Pretrial Conference/Proposed Final Pretrial Conference.

Pretrial documents must be filed on the due date set in the schedule.

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.

Civil cases

Page 8 | B. TRIAL PREPARATION

Oppositions to motions in limine must be filed at least 14 days before the Final Pretrial Conference.

Oppositions must be filed at least fourteen (14) days before the FPTC.

Civil cases

Page 9 | (b) Motions in Limine

Witness lists must be filed at least 28 days before the Final Pretrial Conference.

Witness lists must be filed at least twenty-eight (28) days before the FPTC.

Civil cases

Page 9 | (c) Witness Lists

Amended Witness Lists must be filed by noon on the Friday before trial and emailed to chambers in Microsoft Word format.

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

Civil cases

Page 9 | (c) Witness Lists

Joint Exhibit List must be filed at least 28 days before the Final Pretrial Conference.

The Joint Exhibit List must be filed at least twenty-eight (28) days before the FPTC.

Civil cases

Page 9 | (d) Joint Exhibit List

Amended Joint Exhibit Lists must be filed by noon on the Friday before trial and emailed to chambers in Microsoft Word format.

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

Civil cases

Page 9 | (d) Joint Exhibit List

Motions in limine must be filed at least 28 days before the Final Pretrial Conference.

All motions in limine must be filed at least twenty-eight (28) days before the FPTC.

Civil cases

Page 9 | (b) Motions in Limine

Joint agreed proposed jury instructions must be filed no later than 14 days before the Final Pretrial Conference.

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

Civil cases

Page 10 | (e) Jury Instructions

Joint verdict form must be filed 14 days before the Final Pretrial Conference.

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

Civil cases

Page 12 | (f) Joint Verdict Forms

Joint Statement of the Case must be filed 14 days before the Final Pretrial Conference.

The parties must file a Joint Statement of the Case fourteen (14) days before the FPTC for the Court to read to the prospective jurors before commencement of voir dire.

Civil cases

Page 12 | (g) Joint Statement of the Case

Objections to declarations must be filed at least 14 days before FPTC.

If such declarations are filed, each party shall file any evidentiary objections to the declarations submitted by any other party at least fourteen (14) days before the FPTC.

Civil cases

Page 13 | (j) Declarations of Direct Testimony (Bench Trial Only)

Proposed Findings of Fact and Conclusions of Law must be filed no later than 28 days before the Final Pretrial Conference.

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

Civil cases

Page 13 | (i) Proposed Findings of Fact and Conclusions of Law (Bench Trial Only)

Declarations of direct testimony must be filed at least 28 days before FPTC.

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

Civil cases

Page 13 | (j) Declarations of Direct Testimony (Bench Trial Only)

USB flash drive with exhibits must be delivered to judge's courtesy box by 12:00 p.m. on Wednesday before trial.

The USB flash drive must be delivered to the judge’s courtesy box located outside the Clerk’s Office on the 4th floor of the First Street Courthouse by 12:00 p.m. on the Wednesday before the start of trial.

Civil cases

Page 14 | 3. Trial Exhibits (b) Exhibit Copies

Parties who filed a form pleading in state court must file a revised pleading in federal court within 30 days of receiving the Notice of Removal, complying with FRCP 7, 7.1, 8, 9, 10, and 11.

If an action removed to this Court contains a form pleading, i.e., a pleading in which boxes are checked, the party or parties that filed the form pleading must file in this Court within thirty (30) days of receipt of the Notice of Removal a revised pleading that complies with Fed. R. Civ. P. 7, 7.1, 8, 9, 10 and 11. An amended complaint filed within thirty (30) days after removal to replace a form complaint pursuant to this instruction shall be deemed an amended complaint with “the court’s leave” pursuant to Fed. R. Civ. P. 15(a)(2).

Page 4 | PLEADINGS REQUIREMENTS

Plaintiff's counsel must immediately serve this Order on all parties; if the case was removed, the removing defendant must serve it.

Counsel for the plaintiff must immediately serve this Order on all parties, including any new parties to the action. If this case was removed from state court, the defendant that removed the case must serve this Order on all other parties.

Page 2 | A. GENERAL REQUIREMENTS

The plaintiff(s) shall promptly serve the Complaint in accordance with Fed. R. Civ. P. 4 and file the proofs of service pursuant to Fed R. Civ. P. 4(l). Any defendant(s), including “DOE” or fictitiously-named defendant(s), not served within ninety (90) days after the case is filed shall be dismissed pursuant to Fed. R. Civ. P. 4(m) and by operation of this Order without further notice, unless plaintiff requests and justifies the need for additional time in the joint report and the Court grants an extension.

The plaintiff(s) shall promptly serve the Complaint in accordance with Fed. R. Civ. P. 4 and file the proofs of service pursuant to Fed R. Civ. P. 4(l). Any defendant(s), including “DOE” or fictitiously-named defendant(s), not served within ninety (90) days after the case is filed shall be dismissed pursuant to Fed. R. Civ. P. 4(m) and by operation of this Order without further notice, unless plaintiff requests and justifies the need for additional time in the joint report and the Court grants an extension.

Page 4 | PLEADINGS REQUIREMENTS

Ex parte moving party must serve opposing party by email, fax, or personal service.

The moving party must also serve the opposing party by email, fax, or personal service,

Page 17 | EX PARTE APPLICATIONS

Defendants not served within 90 days of filing will be dismissed unless plaintiff requests and justifies additional time in the joint report and the Court grants an extension.

Any defendant(s), including “DOE” or fictitiously-named defendant(s), not served within ninety (90) days after the case is filed shall be dismissed pursuant to Fed. R. Civ. P. 4(m) and by operation of this Order without further notice, unless plaintiff requests and justifies the need for additional time in the joint report and the Court grants an extension.

Page 4 | B. PLEADING REQUIREMENTS

Plaintiff must promptly serve the complaint per FRCP 4 and file proof of service per FRCP 4(l).

The plaintiff(s) shall promptly serve the Complaint in accordance with Fed. R. Civ. P. 4 and file the proofs of service pursuant to Fed R. Civ. P. 4(l).

Page 4 | B. PLEADING REQUIREMENTS

Plaintiff must identify and serve Doe defendants before the deadline in the Order Setting Scheduling Conference.

Plaintiff must identify and serve any fictitiously named or “Doe” defendant(s) before the deadline set forth in the Court’s Order Setting Scheduling Conference.

Page 4 | B. PLEADING REQUIREMENTS

Moving party must serve opposing party by email, fax, or personal service and notify them of the opposition deadline (48 hours or 3:00 PM next court day).

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

Page 17 | RESTRAINING ORDERS AND APPLICATIONS FOR INJUNCTIVE RELIEF

Plaintiff must identify and serve Doe defendants before the scheduling conference deadline.

Plaintiff must identify and serve any fictitiously named or “Doe” defendant(s) before the deadline set forth in the Court’s Order Setting Scheduling Conference.

Page 4 | PLEADINGS REQUIREMENTS

Opposing party must deliver integrated motion to moving party within 14 days after receiving moving party's papers.

No later than fourteen (14) days after receiving the moving party’s papers, the opposing party shall personally deliver or email to the moving party an electronic copy of the integrated motion,

Civil cases

Page 7 | (c) Opposing Party's Portion of the Joint Brief

Moving party must deliver its portion of joint brief to opposing party within 14 days after meet and confer.

No later than fourteen (14) days after the meet and confer, the moving party shall personally deliver or email to the opposing party an electronic copy of the moving party's portion of the Joint Brief

Civil cases

Page 7 | (b) Moving Party's Portion of the Joint Brief

Chambers copies must be delivered to 4th floor box by noon next business day, printed from CM/ECF with header.

All Mandatory Chambers Copies must be delivered to Judge Hsu’s Chambers copy box, which is located outside of the Clerk’s Office on the fourth floor of the First Street Courthouse. Mandatory Chambers Copies must be delivered no later than 12:00 p.m. (noon) the following business day after the document is electronically filed. Mandatory 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

Page 6 | FILING REQUIREMENTS

One mandatory chambers copy required for summary judgment motions and 26(f) reports only.

The parties must provide one (1) Mandatory Chambers Copy only of Motions for Summary Judgment filings and the 26(f) Report. Please do not send paper copies of any other documents unless requested by the Court.

Page 6 | FILING REQUIREMENTS

Chambers copies of TRO-related documents must be provided on the same day filed.

The parties must provide chambers copies of TRO-related documents on the same day they are filed.

Counsel shall provide the Magistrate Judge chambers copies of the moving papers and responses.

Counsel shall provide the Magistrate Judge chambers copies of the moving papers and responses.

Mandatory chambers copy required for MSJ and 26(f) Reports, delivered by noon next business day; voluminous documents (>500 pages) allowed second business day.

The parties must deliver to Judge Hsu’s chambers copy box located outside of the Clerk’s Office on the fourth floor of the First Street Courthouse one (1) Mandatory Chambers Copy (a paper copy that is sent to Chambers upon electronic filing of the motion) only for Motions for Summary Judgment filings and 26(f) Reports. Mandatory Chambers Copies must be delivered no later than 12:00 p.m. (noon) the following business day after the document is electronically filed. If, however, the electronically filed document is particularly voluminous (more than 500 pages), Mandatory Chambers Copies may be delivered no later than 12:00 p.m. on the second business day after the document is filed.

Civil cases

Page 4 | 2. Non-Discovery Motions Deadline

Mandatory chambers copies of pretrial documents must be delivered to the chambers copy box, in binder-ready state (three-hole punched, no blue-backs, stapled top left).

Mandatory Chambers Copies of electronically filed pretrial documents shall be delivered to Judge Hsu’s Chambers copy box outside of the Clerk’s Office on the fourth floor of the First Street Courthouse. Chambers copies must be delivered in a “binder-ready” state, meaning they must be three-hole punched on the left side, without blue-backs, and stapled only in the top left corner.

Civil cases

Page 8 | B. TRIAL PREPARATION

One mandatory chambers copy required only for MSJ filings, 26(f) Report, and post-trial motions; do not send other paper copies unless requested.

The parties must provide one (1) Mandatory Chambers Copy only of Motions for Summary Judgment filings the 26(f) Report and any post-trial motion filings. Please do not send paper copies of any other documents unless requested by the Court.

Page 6 | FILING REQUIREMENTS

Mandatory chambers copies must be delivered to the designated copy box by noon the next business day after e-filing.

All Mandatory Chambers Copies must be delivered to Judge Hsu’s Chambers copy box, which is located outside of the Clerk’s Office on the fourth floor of the Felicitas and Gonzalo Mendez United States Courthouse. Mandatory Chambers Copies must be delivered no later than 12:00 p.m. (noon) the following business day after the document is electronically filed.

Page 7 | Delivery Location, Timeliness, and Form

Ex parte applications require a mandatory chambers copy before consideration.

The application will not be considered until a Mandatory Chambers Copy has been provided.

Page 18 | EX PARTE APPLICATIONS

Chambers copies of TRO-related documents must be provided on the same day as filing.

The parties must provide chambers copies of TRO-related documents on the same day they are filed.

Page 18 | EX PARTE APPLICATIONS

Parties should submit one (1) paper copies of all MSJ filings to Judge Hsu’s mailbox on the Fourth Floor of the First Street Courthouse. Pro Se litigants are exempt from this requirement.

Parties should submit one (1) paper copies of all MSJ filings to Judge Hsu’s mailbox on the Fourth Floor of the First Street Courthouse. Pro Se litigants are exempt from this requirement.

Civil cases

Page 4 | 8. Mandatory Chambers Copies

Mandatory chambers copies must be binder-ready and delivered by 5:00 PM next court day.

The government must provide a Mandatory Chambers Copy of each document delivered to Judge Hsu’s mailbox outside the Clerk’s Office on the Fourth Floor of the First Street Courthouse no later than 5:00 p.m. on the first court day after the filing date. The Mandatory Chambers Copies must be “binder ready” (three-hole punched on the left side, without blue-backs or staples).

Mandatory chambers copies must be printed from CM/ECF with CM/ECF header.

Mandatory 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

Page 6 | FILING REQUIREMENTS

One mandatory chambers copy required for Summary Judgment motions and 26(f) Reports.

The parties must provide one (1) Mandatory Chambers Copy only of Motions for Summary Judgment filings and the 26(f) Report.

Page 6 | FILING REQUIREMENTS

Mandatory chambers copies must be delivered by noon next business day.

Mandatory Chambers Copies must be delivered no later than 12:00 p.m. (noon) the following business day after the document is electronically filed.

Page 6 | FILING REQUIREMENTS

Mandatory chambers copy required for ex parte applications.

The application will not be considered until a Mandatory Chambers Copy has been provided.

Chambers copies of TRO documents required same day as filing.

The parties must provide chambers copies of TRO-related documents on the same day they are filed.

Courtesy copies of the fee tables must be in editable Excel format and emailed to chambers.

The courtesy 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 WLH_Chambers@cacd.uscourts.gov.

Page 15

Ex parte application will not be considered until a mandatory chambers copy is provided.

The application will not be considered until a Mandatory Chambers Copy has been provided.

Page 17 | RESTRAINING ORDERS AND APPLICATIONS FOR INJUNCTIVE RELIEF

Protective orders must be submitted to magistrate; cannot allow sealing without court order.

Proposed protective orders for discovery must be submitted to the assigned Magistrate Judge. Such orders should not purport to allow, without further order of the Court, the filing under seal of pleadings or documents filed in connection with a dispositive motion, a class certification motion, or trial before the Court.

(b) Redacted Version and Unredacted Version. Documents that are not confidential or privileged in their entirety should not be filed under seal if the confidential portions can be redacted and filed separately with a reasonable amount of effort. The parties should file an unredacted version of the document under seal, and a

(b) Redacted Version and Unredacted Version. Documents that are not confidential or privileged in their entirety should not be filed under seal if the confidential portions can be redacted and filed separately with a reasonable amount of effort. The parties should file an unredacted version of the document under seal, and a

Local Rule 79-5 governs sealing applications with strong presumption of access to court records.

(a) Local Rule 79-5. L.R. 79-5 governs applications to file under seal. Parties must comply with all sections of L.R. 79-5. There is a “strong presumption of access to court records” in civil cases. Foltz v. State Farm Mut. Auto. Ins. Co., 331 F.3d 1122, 1135 (9th Cir. 2003). For each document or other type of information a party seeks to file under seal, the party must identify and discuss the factual and/or legal justification that establishes “good cause” or “compelling reasons” for the document’s protection. Kamakana v. City and Cnty. of Honolulu, 447 F.3d 1172, 1179-80 (9th Cir. 2006).

Each item must be individually justified for sealing; blanket claims denied; meet and confer required.

(c) Justification. Sealing must be justified for each individual item; blanket claims of confidentiality will result in the application to seal being denied. Counsel is strongly encouraged to consider carefully whether sealing or redaction is required for a given piece of evidence or argument. An application to seal that includes clearly meritless requires to seal or redact documents may be denied in its entirety. The parties must also meet and confer before filing an application to seal.

Protective order alone does not justify sealing pleadings or documents.

The existence of a protective order does not alone justify the filing of pleadings or other documents under seal, in whole or in part.

Meet and confer required 7 days before sealing application; opposing party must respond within 2 days.

Because a party other than the designator will often be seeking to file designated material, cooperation between the parties in preparing, and in reducing the number and extent of, requests for under seal filing is essential. Accordingly, counsel are ordered to meet and confer in person or by telephone at least seven (7) calendar days prior to the filing of an application wherein the basis for the sealing is that it has been deemed confidential by the other party. Not later than two (2) calendar days after the meet and confer process, the opposing party shall confirm whether such information shall be designated as confidential or whether it can be made available to the public.

Civil cases

Filing under seal requires court order or designator permission; must comply with Local Rule 79-5; designation alone insufficient.

Without written permission from the designator or a Court order, a party may not file in the public record in this action any designated material. A party seeking to file under seal any designated material must comply with Local Rule 79-5. Filings may be made under seal only pursuant to a court order authorizing the sealing of the specific material at issue. The fact that a document has been designated under this Order is insufficient to justify filing under seal. Instead, parties must explain the basis for confidentiality of each document sought to be filed under seal.

Civil cases

Written request required to disclose HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY to in-house counsel; SOURCE CODE not authorized.

A party seeking to disclose to in-house counsel any material designated HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY must first make a written request to the designator providing the full name of the in-house counsel, the city and state of such counsel’s residence, and such counsel’s current and reasonably foreseeable future primary job duties and responsibilities in sufficient detail to determine present or potential involvement in any competitive decision-making. In-house counsel are not authorized to receive material designated HIGHLY CONFIDENTIAL – SOURCE CODE.

Civil cases

Written request with detailed expert information required to disclose HIGHLY CONFIDENTIAL material to experts.

A party seeking to disclose to an expert retained by outside counsel of record any information or item that has been designated HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY or HIGHLY CONFIDENTIAL – SOURCE CODE must first make a written request to the designator that (1) identifies the general categories of HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY or HIGHLY CONFIDENTIAL – SOURCE CODE information that the receiving party seeks permission to disclose to the expert, (2) sets forth the full name of the expert and the city and state of his or her primary residence, (3) attaches a copy of the expert’s current resume, (4) identifies the expert’s current employer(s), (5) identifies each person or entity from whom the expert has received compensation or funding for work in his or her areas of expertise (including in connection with litigation) in the past five years, and (6) identifies (by name and number of the case, filing date, and location of court) any litigation where the expert has offered expert testimony, including by declaration, report or testimony at deposition or trial, in the past five years.

Civil cases

Filing under seal requires compliance with Local Rule 79-5.1 and this Order.

This Order does not automatically authorize the filing under seal of material designated under this Order. Instead, the parties must comply with Local Rule 79-5.1 and this Order if they seek to file anything under seal.

Civil cases

Sealing application must include meet and confer dates/method or will be denied without prejudice.

Such an application shall contain the dates and method by which the parties met and conferred otherwise it will be denied without prejudice to an amended application being filed after counsel have completed this process.

Civil cases

Sealing applications must comply with Local Rule 79-5 and provide factual/legal justification for each item.

Local Rule 79-5 governs applications to file under seal. Parties must comply with all sections of L.R. 79-5. There is a "strong presumption of access to court records" in civil cases. For each document or other type of information a party seeks to file under seal, the party must identify and discuss the factual and/or legal justification that establishes "good cause" or "compelling reasons" for the document's protection.

Page 7 | Filings Under Seal

Sealing must be justified per item; blanket confidentiality claims will be denied; parties must meet and confer before filing a sealing application.

Sealing must be justified for each individual item; blanket claims of confidentiality will result in the application to seal being denied. Counsel is strongly encouraged to consider carefully whether sealing or redaction is required for a given piece of evidence or argument. An application to seal that includes clearly meritless requests to seal or redact documents may be denied in its entirety. The parties must also meet and confer before filing an application to seal.

Page 8 | Justification

Must justify sealing for each individual item; blanket claims not allowed.

Sealing must be justified for each individual item to be sealed or redacted; blanket claims of confidentiality are not allowed and will result in a denial of the application to seal.

Criminal cases

Bracket and highlight redacted portions on unredacted copies sent via email.

***On the un-redacted copies (sent via e-mail) the parties ARE ORDERED to place in brackets and highlight the portion[s] of the document text and/or exhibits that have been redacted.***

Criminal cases

Documents that are not confidential or privileged in their entirety should not be filed under seal if the confidential portions can be redacted and filed separately with a reasonable amount of effort. The parties should file an unredacted version of the document under seal, and a

Documents that are not confidential or privileged in their entirety should not be filed under seal if the confidential portions can be redacted and filed separately with a reasonable amount of effort. The parties should file an unredacted version of the document under seal, and a

Each item must be individually justified for sealing; blanket confidentiality claims are not permitted.

Sealing must be justified for each individual item; blanket claims of confidentiality will result in the application to seal being denied.

Parties must meet and confer before filing an application to seal.

The parties must also meet and confer before filing an application to seal.

Documents that are not confidential or privileged in their entirety should not be filed under seal if the confidential portions can be redacted and filed separately with a reasonable amount of effort. The parties should file an unredacted version of the document under seal, and a redacted version on the public docket.

Documents that are not confidential or privileged in their entirety should not be filed under seal if the confidential portions can be redacted and filed separately with a reasonable amount of effort. The parties should file an unredacted version of the document under seal, and a redacted version on the public docket.

Page 7 | A. GENERAL REQUIREMENTS

Only one joint summary judgment motion may be filed without leave of court; additional motions require court permission.

No more than one joint motion may be filed under Fed. R. Civ. P. 56 without leave of court, regardless of whether such motion is denominated a motion for summary judgment or summary adjudication.

Civil cases

Page 2 | A. GENERAL REQUIREMENTS

Parties must file a single joint brief containing both moving and opposition papers for any summary judgment motion.

The parties shall work cooperatively to submit a single joint brief, that is including moving and opposition papers, for any MSJ brought by any moving party(ies).

Civil cases

Page 2 | A. GENERAL REQUIREMENTS

Joint Appendix of Evidence must accompany the Joint Brief.

The Joint Brief shall be accompanied by a Joint Appendix of Evidence (JAE) (e.g., a separate, tabbed appendix of all evidence in support of or opposition to the MSJ, including declarations, deposition excerpts, documents, photographs, etc.).

Civil cases

Page 11 | D. JOINT APPENDIX OF EVIDENCE (JAE)

Evidence must not be attached to the Joint Brief; it must be in the JAE.

No evidence should be attached to a memorandum of points and authorities or included anywhere other than in the JAE.

Civil cases

Page 11 | D. JOINT APPENDIX OF EVIDENCE (JAE)

Joint Appendix of Objections must accompany the Joint Brief.

The Joint Brief shall be accompanied by a Joint Appendix of Objections (JAO)—i.e., evidentiary objections, if any, shall be made in a single, separate document presented in a four-column table as follows:

Civil cases

Page 11 | E. JOINT APPENDIX OF OBJECTIONS (JAO)

Parties must submit three sets of 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.

Civil cases

Page 13 | 3. Trial Exhibits

Physical evidence must be lodged separately from the JAE.

Physical evidence (e.g., video recordings) shall be lodged separately.

Civil cases

Page 11 | D. JOINT APPENDIX OF EVIDENCE (JAE)

Motions in limine must be scheduled for the Final Pretrial Conference.

Motions in limine shall be noticed for hearing on the Final Pretrial Conference Date.

Meet and confer required for disputed matters before court presentation.

This Court requires parties through Counsel to meet and confer about any potentially disputed matter (except those identified in L.R. 7-3 and 16-12) before presenting it to the Court, including requests to continue any matter, applications to file under seal, and other filings seeking a court order.

Extended briefing schedule required for class certification motions.

This Court requires an extended briefing schedule for motions for class certification.

Daubert motions must be noticed for hearing at least 8 weeks before Final Pretrial Conference.

Daubert motions shall be noticed for hearing not later than eight (8) weeks before the Final Pretrial Conference date.

Pre-filing meet and confer required for all motions, including pro se cases.

The Court strictly enforces L.R. 7-3, which requires counsel to engage in a prefiling conference “to discuss thoroughly . . . the substance of the contemplated motion and any potential resolution.” This requirement applies in all cases, including those with Pro Se Litigants.

Before moving to substitute a Doe defendant, plaintiff must seek consent; if denied, file a noticed motion; in diversity cases, motion must address diversity jurisdiction.

Before moving to substitute a defendant for a Doe defendant, plaintiff must seek the consent of counsel for all defendants, including counsel for a represented Doe defendant. If denied consent, plaintiff must file a regularly noticed motion. In diversity cases, plaintiff's motion must address whether the addition of the newly named party destroys diversity jurisdiction. See 28 U.S.C. § 1447(c), (e).

Page 5 | Doe Defendant Substitution

Pre-filing meet and confer required for all motions and disputed matters, including pro se cases; must be by videoconference or in person.

The Court strictly enforces L.R 7-3, which requires counsel to engage in a prefiling conference “to discuss thoroughly . . . the substance of the contemplated motion and any potential resolution.” This requirement applies in all cases, including those with Pro Se Litigants. This Court requires parties through Counsel to meet and confer about any potentially disputed matter (except those identified in L.R. 7-3 and 16-12) before presenting it to the Court, including requests to continue any matter, applications to file under seal, and other filings seeking a court order.

Page 10 | G. MOTIONS

Moving party must arrange a meet-and-confer meeting or videoconference at least 60 days before the MSJ hearing cutoff.

For an MSJ to be timely filed, the moving party must arrange for an in-person meeting or videoconference to take place no later than sixty (60) days before the motion hearing cutoff set forth in the case management order. The parties shall thoroughly discuss each issue to be raised and the law and evidence relevant to that issue.

Civil cases

Page 2 | A. GENERAL REQUIREMENTS

Moving party must arrange a meet and confer (in-person or videoconference) no later than 60 calendar days before the MSJ hearing cutoff.

For an MSJ to be timely filed, the moving party must arrange for an in-person meeting or videoconference to take place no later than sixty (60) days before the motion hearing cutoff set forth in the case management order.

Civil cases

Page 6 | Briefing Schedule

Discovery motions must state meet and confer compliance and detail request specifics.

All discovery motions shall state whether the meet and confer requirement has been satisfied and state with particularity what is requested, the basis for the request, whether the discovery at issue has been requested, and opposing counsel’s response to such request.

Page 5 | GENERAL REQUIREMENTS

Court may decline discovery motions without prior consultation.

Both parties are required to meet and confer in good faith in an effort to reach a resolution without the need for a motion. The Court may decline to hear discovery motions made without prior consultation with opposing counsel.

Page 5 | GENERAL REQUIREMENTS

Meet and confer required for pre-trial motions (except motions in limine).

Counsel must meet and confer with opposing counsel “to discuss thoroughly… the substance of the contemplated pre-trial motion and any potential resolution” thereof. Local Criminal Rule 57-1; Local Civil Rule 7-3.

Page 6 | Pre-trial Motions (except motions in limine)

Good faith meet and confer required to resolve issues without motion.

Both parties are required to meet and confer in good faith in an effort to reach a resolution without the need for a motion.

Page 6 | Pre-trial Motions (except motions in limine)

Failure to meet deadlines may result in court declining to consider untimely documents.

Failure to comply with these deadlines may result in the court declining to consider the untimely memorandum or other document.

Page 7 | GENERAL REQUIREMENTS

Briefing schedule: motions 3 weeks, oppositions 2 weeks, replies 1 week before hearing.

For all motions, other than motions in limine, the briefing schedule is as follows: motions shall be filed three (3) weeks prior to the hearing; oppositions or notices of non-opposition shall be filed two (2) weeks prior to the hearing; and replies, if any, shall be filed one (1) week prior to the hearing.

Page 7 | GENERAL REQUIREMENTS

Extended briefing schedule required for class certification motions.

This Court requires an extended briefing schedule for motions for class certification.

Page 14 | H. MOTIONS – SPECIFIC REQUIREMENTS

The issue of exhaustion under the Prison Litigation Reform Act (“PLRA”) must be raised at the beginning of the litigation. Albino v. Baca, 747 F.3d 1162, 1170 (9th Cir. 2014). A party seeking to obtain a judicial determination of any material fact dispute precluding summary judgment on the exhaustion issue must file before this Court a request for a hearing within fourteen

The issue of exhaustion under the Prison Litigation Reform Act (“PLRA”) must be raised at the beginning of the litigation. Albino v. Baca, 747 F.3d 1162, 1170 (9th Cir. 2014). A party seeking to obtain a judicial determination of any material fact dispute precluding summary judgment on the exhaustion issue must file before this Court a request for a hearing within fourteen

Page 15 | PLRA Exhaustion Motions

Reply briefs not permitted for ex parte applications.

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

L.R. 7-3 requires prefiling conference to discuss motion substance and potential resolution.

The Court strictly enforces L.R. 7-3, which requires counsel to engage in a prefiling conference “to discuss thoroughly . . . the substance of the contemplated motion and any potential resolution.”

Non-compliance with meet and confer may result in sanctions.

Failure by any party to comply in good faith with the “meet and confer” requirement may result in an order to show cause re: sanctions—including, as appropriate, striking or denying the motion, deeming the motion unopposed, and/or awarding monetary sanctions.

Motion for review of magistrate decision must be filed within 14 days of ruling.

Any motion for review of a Magistrate Judge’s decision must be noticed before the District Court Judge within fourteen (14) days of service of the Magistrate Judge’s written ruling, or within fourteen (14) days of an oral ruling that the Magistrate Judge states will not be followed by a written ruling.

Opposing papers must be filed within 48 hours or by 3pm on first court day after service, whichever is later.

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

Court will not rule on ex parte applications for at least 48 hours after service unless service is excused or interests of justice require.

The Court generally will not rule on any application for such relief for at least forty-eight (48) hours (or two (2) court days) after the party subject to the requested order has been served unless service is excused or unless the interests of justice so require.

Dispositive motions must be filed within 28 days after discovery closes.

All dispositive motions shall be filed no later than twenty-eight (28) days after the close of discovery.

Civil cases

Page 13 | Standing Order for Patent Cases

Continuance requests must be by motion/stipulation/application with a declaration showing good cause and due diligence.

Any request for continuance of case management dates must be by motion, stipulation, or application, and must be supported by a declaration setting forth the reasons for the requested relief. The declaration must contain a detailed factual showing of good cause and due diligence demonstrating the necessity for the continuance and a description of the parties’ efforts taken to advance the litigation.

Civil cases

Page 20 | 11. Continuances of Pretrial and Trial Dates

Continuances require good cause, a motion/stipulation with proposed order, detailed declaration with reasons and precise new dates; stipulations with vague date changes will be denied.

Continuances are granted only on a showing of good cause. Requests for continuances must be made before the date to be continued and by motion or stipulation, along with a proposed order. Motions and stipulations must be accompanied by a detailed declaration setting forth the specific reasons for the requested continuance and the precise deadline(s) the parties propose. A stipulation that fails to list the precise date(s) the parties wish to move, and the new date(s) they propose, will be denied for failure to comply with this Standing Order. For example, if the stipulation improperly proposes that all deadlines be moved by “60 days” without specifying the proposed new dates that would result from that requested continuance, the Court will deny the request.

Page 14 | H.3

Stipulations extending court-set dates require Court approval; continuances are not routinely granted.

Stipulations extending dates set by this Court are not effective unless approved by the Court. Continuances will not be granted routinely.

Page 15 | 3. Continuances

Expert Discovery Cut-Off 14

Expert Discovery Cut-Off 14

Civil cases

Fact Discovery Cut-Off (No later than deadline for filing dispositive motion)

Fact Discovery Cut-Off (No later than deadline for filing dispositive motion)

Civil cases

Last Date to Hear Daubert Motions 8

Last Date to Hear Daubert Motions 8

Civil cases

Rule 56 motions must be filed at least 6 weeks before hearing, with opposition due 2 weeks after and reply due 1 week after opposition

Last Date to Hear Motions • Rule 56 Motion due at least 6 weeks before hearing; • Opposition due 2 weeks after motion is filed before hearing; • Reply due 1 week after Opposition is filed 12

Civil cases

Continuance requests must show good cause, due diligence, and prior request history.

Each request must include a detailed factual showing of good cause and due diligence demonstrating the necessity for the continuance, stating whether any previous requests for continuances have been made and whether these requests were granted or denied by the Court.

Page 5 | Continuances

Continuance requests must be by motion/stipulation/application and signed by defendant and counsel.

Requests for continuances of pretrial and trial dates must be by motion, stipulation, or application. All requests must be signed by both the defendant(s) and counsel.

Page 5 | Continuances

General statements insufficient; detailed showing required for continuances.

The Court will not grant requests to continue pretrial and trial dates absent the detailed showing. General statements are insufficient to establish good cause.

Page 5 | Continuances

Requests to extend Court-set dates are not effective without Court approval.

Requests extending dates set by the Court are not effective unless approved by the Court.

Page 6 | Continuances

Counsel shall avoid submitting requests for continuance of trial less than one (1) week prior to the FTPC. A request to continue dates that have already expired constitutes a presumptive lack of due diligence.

Counsel shall avoid submitting requests for continuance of trial less than one (1) week prior to the FTPC. A request to continue dates that have already expired constitutes a presumptive lack of due diligence.

Page 6 | Continuances

Opposition to ex parte applications must be filed within 24 hours of service.

Following service of the ex parte application by electronic, facsimile, or personal service, the moving party shall notify the opposing party that any opposition must be filed no later than twenty-four (24) hours following service.

Page 8 | Ex Parte Applications

Motions in limine must be filed 28 days before FTPC; oppositions 14 days before.

All motions in limine must be filed at least twenty-eight (28) days before the FTPC. Oppositions must be filed at least fourteen (14) days before the FTPC.

Email Word and PDF copies of proposed orders to WLH_Chambers@cacd.uscourts.gov; stipulations/ex parte applications must also be emailed.

Email Proposed Orders to Chambers. The Court enforces strict compliance with L.R. 5-4.4.2, which instructs: “After a document requiring a judge’s signature has been lodged in accordance with L.R. 5-4.4.1 . . . , a Microsoft Word copy of the proposed document, along with a PDF copy of the electronically filed main document, shall be e-mailed to the assigned judge’s generic chambers e-mail address using the CM/ECF System,” namely, WLH_Chambers@cacd.uscourts.gov. The Court will not consider a stipulation, ex parte application, or other request for relief until a compliant proposed order is received by email. If the proposed order is based on a stipulation or an ex parte application, counsel must email both the order and the stipulation or ex parte application. Otherwise, accompany documents (such as motions) should not be emailed to Chambers.

Page 6 | FILING REQUIREMENTS

Settlement discussions require 2-week notice; immediate notice if settled.

Counsel must notify the Court at least two (2) weeks before the scheduled hearing if the parties are conducting settlement discussions that may render the motion moot and must notify the Court immediately if a settlement is reached. A belated notice of settlement wastes scarce judicial resources.

Page 16 | 5. Settlement

No ex parte contact with Court or Chambers staff by phone or improper means.

Neither counsel nor a party shall initiate contact with the Court or its Chambers staff by telephone, or by any other improper ex parte means. Counsel may contact the CRD with appropriate inquiries.

Counsel must notify opposing counsel and CRD via email at least 3 days before appearance if there's a conflict.

conflict with a scheduled appearance, counsel must inform opposing counsel and the Court’s Courtroom Deputy (CRD) via Chambers email at WLH_Chambers@cacd.uscourts.gov as soon as possible and not later than three (3) days before the scheduled appearance.

Meet and confer must be by videoconference or in person, not email.

Parties must meet and confer either by videoconference or in person. Email correspondence is insufficient.

Email text-fillable Schedule of Pretrial and Trial Dates Worksheet to Chambers at WLH_Chambers@cacd.uscourts.gov.

In addition to filing the Schedule of Pretrial and Trial Dates Worksheet along with the Joint Rule 26(f) Report, Counsel must email the text-fillable Worksheet to Chambers at WLH_Chambers@cacd.uscourts.gov along with the Joint Rule 26(f) Report.

Page 7 | C. PARTIES MUST PREPARE AND FILE SCHEDULE OF PRETRIAL AND TRIAL DATES WORKSHEET

Paper copies of source code cannot be converted to electronic format except for court documents.

The inspecting party shall not convert any of the information contained in the paper copies into any electronic format other than for the preparation of a pleading, exhibit, expert report, discovery document, deposition transcript, or other Court document.

Civil cases

Source code inspection requires secured computer in secured room; no copying or transferring allowed.

The source code shall be made available for inspection on a secured computer in a secured room, and the inspecting party shall not copy, remove or otherwise transfer any portion of the source code onto any recordable media or recordable device.

Civil cases

Source code must be available for inspection during normal business hours or mutually agreeable times.

Any HIGHLY CONFIDENTIAL – SOURCE CODE produced in discovery shall be made available for inspection, in a format allowing it to be reasonably reviewed and searched, during normal business hours or at other mutually agreeable times, at an office of the designating party’s counsel or another mutually agreeable location.

Civil cases

Party served with subpoena must follow specific procedures for confidential materials.

If a party is served with a subpoena or a court order issued in other litigation that compels disclosure of any information or items received by that party in this action and designated in this action as CONFIDENTIAL, HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY, or HIGHLY CONFIDENTIAL – SOURCE CODE, that party must do the following:

Civil cases

Inspecting party must maintain records of source code inspectors and secure paper copies in locked area.

The inspecting party shall maintain a record of any individual who has inspected any portion of the source code in electronic or paper form, and shall maintain all paper copies of any printed portions of the source code in a secured, locked area.

Civil cases

Paper copies used during depositions must be retrieved daily and not left with unauthorized individuals.

Any paper copies used during a deposition shall be retrieved at the end of each day and must not be left with a court reporter or any other unauthorized individual.

Civil cases

Neither counsel nor a party shall initiate contact with the Court or its Chambers staff by telephone, or by any other improper ex parte means. Counsel may contact the CRD with appropriate inquiries. Contacting the CRD to inquire about the status of a ruling or to continue a proceeding is not appropriate. The preferred method of communication with the CRD is by email at WLH_Chambers@cacd.uscourts.gov. Counsel must copy all parties on any such email. To facilitate communication with the CRD, counsel should list their email addresses along with their telephone numbers on all papers.

Neither counsel nor a party shall initiate contact with the Court or its Chambers staff by telephone, or by any other improper ex parte means. Counsel may contact the CRD with appropriate inquiries. Contacting the CRD to inquire about the status of a ruling or to continue a proceeding is not appropriate. The preferred method of communication with the CRD is by email at WLH_Chambers@cacd.uscourts.gov. Counsel must copy all parties on any such email. To facilitate communication with the CRD, counsel should list their email addresses along with their telephone numbers on all papers.

Page 3 | General Requirements

After lodging, email Word copy of proposed order and PDF of main document to WLH_Chambers@cacd.uscourts.gov; court will not consider until received; do not email other documents.

The Court enforces strict compliance with L.R. 5-4.4.2, which instructs: “After a document requiring a judge’s signature has been lodged in accordance with L.R. 5-4.4.1 . . . , a Microsoft Word copy of the proposed document, along with a PDF copy of the electronically filed main document, shall be e-mailed to the assigned judge’s generic chambers e-mail address using the CM/ECF System,” namely, WLH_Chambers@cacd.uscourts.gov. The Court will not consider a stipulation, ex parte application, or other request for relief until a compliant proposed order is received by email. If the proposed order is based on a stipulation or an ex parte application, counsel must email both the order and the stipulation or ex parte application. Otherwise, accompany documents (such as motions) should not be emailed to Chambers.

Page 6 | FILING REQUIREMENTS

Email chambers with application, declaration, proposed order, and sealed document.

After electronically filing the application and proof of service, send an e-mail to the chambers e- mail at WLH_Chambers@cacd.uscourts.gov, containing: 1. An Adobe PDF version of the application to seal; 2. Declaration giving notice or a proof of service; 3. Word version of the proposed order (with the proposed denied instructions); and 4. An Adobe PDF of the document(s) to be filed under seal with a caption page clearly marked “UNDER SEAL.”

Criminal cases

The subject line of the e-mail should have the case name and the words “UNDER SEAL REQUEST.”

The subject line of the e-mail should have the case name and the words “UNDER SEAL REQUEST.”

Criminal cases

Motions must be noticed for hearing by FTPC date.

All motions must be properly noticed for hearing no later than the date of the FTPC.

Page 7 | GENERAL REQUIREMENTS

Pretrial motions must be noticed for mutually agreed Friday not closed on calendar.

Pretrial motions, including motions to suppress evidence, motions to bifurcate or sever, and motions concerning character evidence under Fed. R. Evid. 404(b), shall be noticed for a Friday that is mutually agreed to by counsel and that is not closed on the Court’s calendar.

Page 7 | GENERAL REQUIREMENTS

The moving party shall serve the opposing party electronically, if possible. A party is considered served once the ex parte application has been e-filed.

The moving party shall serve the opposing party electronically, if possible. A party is considered served once the ex parte application has been e-filed.

Page 8 | Ex Parte Applications

If, however, a written request for oral argument is filed by any side before a ruling, stating that a lawyer of five or fewer years out of law school will conduct the oral argument or at least the lion’s share, then the Court will hear oral argument, believing that young lawyers need more opportunities for appearances than they usually receive.

If, however, a written request for oral argument is filed by any side before a ruling, stating that a lawyer of five or fewer years out of law school will conduct the oral argument or at least the lion’s share, then the Court will hear oral argument, believing that young lawyers need more opportunities for appearances than they usually receive.

Page 16 | 2. Submission Without Oral Argument

Court encourages lead counsel to allow junior lawyers (5 or fewer years out of law school) to participate in proceedings.

Believing that young lawyers need more opportunities for appearances than they usually receive, the Court encourages lead trial counsel to permit junior counsel, of five or fewer years out of law school, to fully participate in Court proceedings, including arguing motions and examining witnesses.

Court encourages junior counsel (5 or fewer years out of law school) to participate in proceedings

Believing that young lawyers need more opportunities for appearances than they usually receive, the Court encourages lead trial counsel to permit junior counsel, of five or fewer years out of law school, to fully participate in Court proceedings, including arguing motions and examining witnesses.

Court may allow multiple attorneys to argue if junior lawyers (5 or fewer years) participate.

multiple attorneys if it provides an opportunity for lawyers of five or fewer years out of law school to participate in the hearing.

Civil cases

Junior counsel with 5 or fewer years of experience are encouraged to fully participate in court proceedings, including arguing motions and pretrial conferences.

Believing that young lawyers need more opportunities for appearances than they usually receive, the Court encourages lead trial counsel to permit junior counsel, of five or fewer years out of law school, to fully participate in Court proceedings, including arguing motions and participating in the pretrial conference.

Civil cases

Page 5 | 3. Final Pretrial Conference/Proposed Final Pretrial Conference.

trial counsel to permit junior counsel, of five or fewer years out of law school, to fully participate in Court proceedings, including arguing motions and examining witnesses.

trial counsel to permit junior counsel, of five or fewer years out of law school, to fully participate in Court proceedings, including arguing motions and examining witnesses.

Page 3 | General Requirements

A written request for oral argument stating that a lawyer with five or fewer years out of law school will argue will result in the Court granting oral argument.

If, however, a written request for oral argument is filed by any side before a ruling, stating that a lawyer of five or fewer years out of law school will conduct the oral argument or at least the lion’s share, then the Court will hear oral argument, believing that young lawyers need more opportunities for appearances

Page 16 | I. HEARINGS

If a written request for oral argument states that a lawyer with 5 or fewer years out of law school will argue, the Court will grant oral argument.

If, however, a written request for oral argument is filed by any side before a ruling, stating that a lawyer of five or fewer years out of law school will conduct the oral argument or at least the lion’s share, then the Court will hear oral argument, believing that young lawyers need more opportunities for appearances than they usually receive.

Civil cases

Page 12 | F. HEARING / 2. Submission Without Oral Argument

Junior lawyers (5 years or less) may increase likelihood of oral argument.

If, however, a written request for oral argument is filed by any side before a ruling, stating that a lawyer of five or fewer years out of law school will conduct the oral argument or at least the lion’s share, then the Court will hear oral argument, believing that young lawyers need more opportunities for appearances than they usually receive.

Page 16 | Submission Without Oral Argument

Court encourages junior counsel (5 years or less experience) to participate in proceedings

Believing that young lawyers need more opportunities for appearances than they usually receive, the Court encourages lead trial counsel to permit junior counsel, of five or fewer years out of law school, to fully participate in Court proceedings, including arguing motions and examining witnesses.

The Court encourages lead trial counsel to allow young lawyers more opportunities for appearances.

Believing that young lawyers need more opportunities for appearances than they usually receive, the Court encourages lead trial counsel to

Page 2 | A. GENERAL REQUIREMENTS

If a written request states that a lawyer with 5 or fewer years of experience will conduct oral argument, the Court will hear oral argument.

If, however, a written request for oral argument is filed by any side before a ruling, stating that a lawyer of five or fewer years out of law school will conduct the oral argument or at least the lion’s share, then the Court will hear oral argument, believing that young lawyers need more opportunities for appearances than they usually receive.

Page 16