Judge Beth Labson Freeman
Limits & Logistics
Document Limits
Courtesy Copies
Filings (All filings)
Required • Binding: Three Ring Binder
Filings (Sealing Motion)
Required
Filings (Pleading, Briefing Related To Substantive Motions, Evidence Related To Substantive Motions)
Required
Adjournments
Communication
Chambers
Detailed Drafting Rules
Each side limited to 5 motions in limine, each 5 pages and addressing one issue.
Each side is limited to 5 motions in limine. Each motion in limine is limited to 5 pages and may address only one issue.
Trial briefs are limited to 15 pages and due 7 days before trial.
Each party shall submit a trial brief, not to exceed 15 pages, at least 7 days before commencement of trial.
Civil motions heard Thursdays at 9 AM by reservation only; must file within 14 days of reservation.
Civil motions are heard by reservation only on Thursdays at 9:00 a.m. Hearing dates may be reserved by contacting Judge Freeman’s Courtroom Deputy Clerk, Tiffany Salinas-Harwell, at 408-535-5381 or BLFCRD@cand.uscourts.gov. When reserving a hearing date, the attorney or party must inform Ms. Salinas-Harwell of the number and type(s) of motions to be filed. Once a hearing date is reserved, the motion(s) shall be filed within 14 days thereafter. If no motion has been filed by the 15th day, the reservation will expire and the moving party must obtain a new reservation before filing the motion(s).
Direct to: Chambers
- Hours9:00 AM - 5:00 PM
Case Management Conferences Thursdays at 11 AM via Zoom; joint statement due 7 days prior.
Case Management Conferences are heard on Thursdays at 11:00 a.m. via Zoom Webinar. A joint Case Management Statement shall be filed at least 7 days before each Case Management Conference.
Direct to: Chambers
- Hours9:00 AM - 5:00 PM
Final Pretrial Conferences Thursdays at 1:30 PM; joint pretrial statement due 14 days prior.
Final Pretrial Conferences are heard on Thursdays at 1:30 p.m. A joint Pretrial Statement and Order shall be filed at least 14 days before the final Pretrial Conference in compliance with Judge Freeman’s Standing Order Re Civil Jury Trials or Standing Order re Civil Bench Trials, whichever is applicable.
Direct to: Chambers
- Hours9:00 AM - 5:00 PM
Trials held Mon/Wed/Fri 9 AM-5 PM, Tue 10 AM-5 PM; Thursdays typically dark.
Trial is conducted on Mondays, Wednesdays, and Fridays from 9:00 a.m. to 5:00 p.m. and on Tuesdays from 10:00 a.m. to 5:00 p.m. Thursdays typically are dark.
Direct to: Chambers
- Hours9:00 AM - 5:00 PM
Standard page limits: 25/25/15 pages for motions under FRCP 12, 23, 56, 59, 65, etc.
Absent leave of Court, the page limits for the following types of motions and proceedings shall be 25 pages for the motion or opening brief, 25 pages for the opposition or response brief, and 15 pages for the reply brief: motions brought under Federal Rules of Civil Procedure 12, 23, 56, 59, or 65; motions for judgment on the pleadings; motions for certification of a collective action under the Fair Labor Standards Act; motions brought under California’s anti-SLAPP statute; social security appeals; and claim construction briefing.
Daubert motions limited to 10 pages per expert, 25 pages total per side.
Daubert motions may not exceed 10 pages per expert, and each side is limited to a total of 25 pages for Daubert motions.
Each side limited to 5 motions in limine, 5 pages each.
Each side is limited to 5 motions in limine of 5 pages each.
Post-trial motions limited to 25 pages total per side in a single brief.
Each side is limited to a total of 25 pages for all post-trial motions, which must be presented in a single brief.
Standard page limits: 10 pages for motion/opening brief, 10 pages for opposition/response, 5 pages for reply brief
Absent leave of Court, the page limits for all other types of motions and proceedings, except for those addressed above or those as to which specific page limits are set forth in the Civil Local Rules or the Court’s Standing Orders, shall be 10 pages for the motion or opening brief, 10 pages for the opposition or response brief, and 5 pages for the reply brief.
Joinder of motions counts toward page limits; excess pages will be disregarded
If a party files its own motion and joins in another party’s motion, both the party’s own motion and the joined motion will count toward the party’s page limits. Excess pages will not be considered by the Court.
Page limits are per side, not per party; multiple parties on same side share collective page limits
The page limits stated above are per side, not per party. For example, if multiple plaintiffs or multiple defendants seek summary judgment, the moving parties may jointly file a single motion for summary judgment that does not exceed 25 pages, or the moving parties may file separate motions for summary judgment that do not exceed 25 pages collectively. Opposition and reply briefs are subject to the corresponding collective page limits.
Page limits are maximums; title pages, TOC, indexes, and exhibits excluded; notice of motion included
These page limits are maximums, not minimums – counsel and parties are encouraged to be concise. Title pages, tables of contents, indexes of cases, and exhibits are not included in these page limits. However, the notice of motion is included in the page limits, as set forth in Civil Local Rule 7-2.
All written text must be at least 12-point type and double-spaced
All written text, including footnotes and quotations, shall be no less than 12-point type and shall be double-spaced.
Footnotes must be 12-point, double-spaced, not used for citations, and limited to 5 per brief
Footnotes shall be no less than 12-point type and shall be double-spaced. Footnotes shall not be used to cite to legal authorities or evidence. All citations to legal authorities or evidence shall be in the body of the brief. Excessive footnotes will be disregarded. In general, no more than 5 footnotes per brief should be necessary.
Cited portions of depositions and lengthy documents must be highlighted in yellow; other colors will result in document being stricken
The cited portions of depositions and other lengthy documents shall be highlighted in yellow for ease of reference. Highlighting in colors other than yellow will result in the document being stricken.
Sealing motions and declarations must be submitted in Word format by email on the same day of filing.
Each administrative motion filed pursuant to Civil Local Rule 79-5(c) and declaration filed pursuant to Civil Local Rule 79-5(f)(3) shall be submitted in Word format by email to BLFpo@cand.uscourts.gov on the same day of filing.
DOCX
25-page limit for all post-answer dispositive motions combined; 25 pages for oppositions, 15 pages for replies.
Each side is limited to a total of 25 pages for all post-answer dispositive motions, collectively, including motions for summary judgment and motions for judgment on the pleadings. For example, if both a motion for judgment on the pleadings and a motion for summary judgment are filed by defendants, the total briefing across both motions may not exceed 25 pages. Total page limits for any oppositions and replies shall be limited to 25 and 15 pages, respectively.
Chambers copies must be single-sided, 2-hole punched, stapled, with numbered tabs, and marked “Chambers Copy”.
In general, chambers copies must be single-sided (printed on only one side of the page), 2-hole punched at the top, and stapled or fastened with metal prongs. However, chambers copies of exhibits that are more than six inches thick must be placed in binders, and chambers copies submitted in connection with a final Pretrial Conference must be 3-hole punched on the left side. Whether or not in binders, chambers copies must include numbered bottom tabs between exhibits. Each chambers copy shall be marked “Chambers Copy” and shall be submitted to the Clerk’s Office in an envelope marked with the case number and with the words “Chambers Copy” and “Judge Beth Labson Freeman.”
Courtesy Copies Required
Logistics
Deposition transcripts must be in single-page format; 4-in-1 format will be disregarded.
Deposition transcripts submitted to the Court must be in single-page format. Transcripts in 4-in-1 format, in which 4 pages of the deposition transcript are reduced to fit on a single document page, will be disregarded.