Joint discovery letters must be filed no later than 7 days after the applicable discovery deadline.

Cross-motions for summary judgment must consist of 4 sequential briefs.

First brief for cross-motions for summary judgment must be filed no later than 7 weeks before the scheduled hearing date.

Final brief for cross-motions for summary judgment must be filed no later than 14 days before the scheduled hearing date.

Requests to extend case management deadlines must be submitted 72 hours prior to the deadline.

Requests to reschedule a case management conference must be submitted at least 72 hours prior to the conference.

Parties seeking emergency relief must notify opposing party and counsel at the earliest possible time of intent to seek such relief, or relief will be denied.

Briefs are limited to 15 pages, with emergency applications exempt from this limit.

Moving counsel must confer with opposing counsel on a mutually convenient hearing date before noticing any motion.

Motions to continue hearings or case management conferences must be filed at least 72 hours before the scheduled appearance; no schedule changes are permitted without a court order.

Requests for extension of deadlines (excluding those parties can agree to without court order) must be filed at least 72 hours before the deadline.

Extension requests must include a proposed order with future deadlines and extensions, a chart of current and proposed deadlines, and if parties disagree, details of prior extension requests.

Trial dates are firm and will not be continued except in extraordinary circumstances.

Continuances of case schedules for mediation or settlement are usually not granted.

Initial case management statements must include a full litigation schedule with last day to amend pleadings, except class actions may propose a schedule through the first phase.

Parties must file a separate stipulation or motion at least 72 hours before a case management conference to request a continuance.

Parties may request an expedited initial case management conference by emailing Judge Chhabria’s Courtroom Deputy.

Joint discovery dispute letters are limited to 5 pages.

Joint discovery dispute letters must be filed no more than 7 days after the applicable discovery cutoff.

Both parties must submit proposed orders with their joint discovery dispute letter.

Only the discovery request or response that is the subject of the dispute may be submitted as an exhibit with a joint discovery dispute letter.

Parties must indicate at the beginning of a stipulation or motion for a protective order or ESI order whether the proposed order is based on a Northern District model order.

Parties must submit a redline comparison of their proposed order and the model order as an exhibit if the proposed order is based on a Northern District model order.

Declarations must be filed separately from motions; exhibits to declarations must be filed separately from the declaration and other exhibits, except attachments to exhibits need not be filed separately.

Motions with supporting declarations or exhibits should generally be filed as one ECF docket entry, with the motion as the Main Document and each declaration/exhibit as a separate Attachment.

ECF descriptions for motions, exhibits, and declarations should include the document name and a brief description.

Filings with more than 10 ECF attachments must be uploaded to the Clerk’s designated online location within 3 days of filing.

Uploaded PDF attachments must follow the required naming convention, including the docket number and document description.

Parties may be required to deliver a flash drive containing all attachments to chambers when requested by the courtroom deputy.

Flash drives delivered to chambers must be labeled with the case name and number; PDF attachments must be text-searchable, include the ECF header, and follow proper file naming, except for pro se litigants.