Courtesy copies are required for exhibits. Details: 2 copies, delivery upon filing, by chambers drop off. Two sets of exhibits must be submitted.
Judge Edward M. Chen's rules set a pre-motion procedure for motions in limine. Motions in limine require specific timing for service and filing.
Judge Edward M. Chen's rule states these limits: 15 pages. Trial briefs limited to 15 pages unless court orders otherwise.
Judge Edward M. Chen's rule states these limits: 3 pages. Discovery disputes must be filed as joint letter briefs (max 3 pages).
Judge Edward M. Chen's formatting rule includes premarked, tagged, three hole punched, and submitted to chambers not filed. Exhibits must be premarked, tagged, three-hole punched, and submitted in binders to chambers (not filed).
The rule requires caption, judge name, and case number. Joint pretrial conference statement due 21 days before final pretrial conference
The rule requires notice of electronic filing. Discovery letter briefs must be e-filed in specific ECF category.
Parties may contact Judge Edward M. Chen's opposing counsel by in person only as allowed by the rule. Lead counsel must meet and confer 42 days before final pretrial conference
Requests should be made at least 10 calendar days in advance when this rule applies before Judge Edward M. Chen. Depositions must be noticed at least 10 days in advance.
Meet and Confer required 21 days before Pretrial Conference Statement
Last day to hear dispositive motions is 10 Thursdays before Pretrial Conference
Last day to file dispositive motions is 35 days before hearing
Expert discovery closes 21 days after rebuttal expert disclosure
Rebuttal expert disclosure due 21 days after expert disclosure
Expert disclosure due same as close of non-expert discovery
Trial scheduled for Monday at 8:30 a.m., approximately one year from first CMC
Pretrial Conference scheduled for 4 Tuesdays prior to trial at 2:30 pm
Objections due 10 days before Pretrial Conference
Joint Pretrial Conference Statement/Trial Briefs due 21 days before Pretrial Conference
Non-expert discovery closes Thursday after 10 Thursdays before last day to hear dispositive motions
Lead counsel must meet and confer 42 days before final pretrial conference
Trial briefs limited to 15 pages unless court orders otherwise.
Joint pretrial conference statement due 21 days before final pretrial conference
Joint pretrial conference statement must contain specific information
Joint pretrial statement must include brief description of claims and defenses
Joint pretrial statement must itemize all relief and damages sought
Joint pretrial statement must list all stipulated undisputed facts
Joint pretrial statement must list disputed factual issues organized by counts
Joint pretrial statement must include trial time estimates for each party
Joint pretrial statement must summarize settlement negotiation status
Joint pretrial statement must address magistrate judge consent and feasibility
Joint pretrial statement must address proposed amendments or dismissals
Joint pretrial statement must address bifurcation or separate trial of issues
Joint pretrial statement must include witness list with testimony substance and length estimates
Motions in limine require specific timing for service and filing.
Exhibits must be premarked, tagged, three-hole punched, and submitted in binders to chambers (not filed).
Two sets of exhibits must be submitted.
Simplified jury statement limited to one paragraph unless case is extremely complex.
Discovery disputes must be filed as joint letter briefs (max 3 pages).