Judge Allison H. Goddard's rules set a pre-motion procedure for covered motions. Rule 26(f) conference required for civil cases to discuss discovery topics.
The rule identifies required filing content or certificates. Parties must file the joint case management statement at least ten calendar days before the initial case management conference.
The rule requires certificate of service. Litigation holds required for preserving ESI.
Parties may contact Judge Allison H. Goddard's chambers by phone only as allowed by the rule. The rule lists phone (619) 557-7749. Criminal calendars held Tuesdays/Thursdays at 9:30 AM; notify CRD of conflicts/priority requests in advance.
Requests should be made at least 24 hours in advance when this rule applies before Judge Allison H. Goddard. The request must include reason for request and proposed new dates. Nebbia/surety hearings require 24-hour advance calendaring and notice; defense must provide bail package to CRD and USAO 24 hours in advance.
Parties must file the joint case management statement at least ten calendar days before the initial case management conference.
The joint case management statement must include jurisdiction, service status, and any proposed service deadline.
The joint case management statement must provide a brief factual chronology and identify principal factual disputes.
The joint case management statement must briefly identify disputed legal issues with statute and case citations, without extended argument.
The joint case management statement must list past and pending motions, their status, and anticipated future motions.
The joint case management statement must address expected pleading amendments and propose a deadline to amend pleadings.
The joint case management statement must include a Rule 26(f) checklist certification and a summary of any checklist disputes.
The joint case management statement must state whether parties fully and timely complied with initial disclosure obligations under Rule 26(a)(1).
The joint case management statement must disclose related cases or proceedings in this court or other tribunals.
The joint case management statement must detail all requested relief and damages calculations, including the responding party’s damages-calculation basis if liability is found.
The joint case management statement must summarize settlement discussions with dates, participants, and outcomes.
The joint case management statement must propose dates for expert disclosures, discovery and motion cutoffs, pretrial conference, and trial.
The joint case management statement must specify jury or bench trial and estimated trial length.
The joint case management statement must address whether each party filed any required notice of party with financial interest under CivLR 40.2.
The joint case management statement must confirm that all listed attorneys reviewed CivLR 2.1 and agree to follow the court’s code of conduct.
In patent cases, the joint case management statement must address proposed patent-rule deadline changes, claim-construction discovery limits, and whether damage discovery should be phased.
The joint case management statement must include other matters that may help resolve the case justly, quickly, and inexpensively.
Joint Case Management Statement due 10 calendar days before initial Case Management Conference
Rule 26(f) conference required for civil cases to discuss discovery topics.
Protective order discussion required before discovery exchange.
Litigation holds required for preserving ESI.
Litigation hold scope must include sources, date ranges, and custodians.
Discussion of ESI categories exempt from preservation/production.
Automatic destruction programs must be addressed.
Discovery prioritization and storage location must be identified.
Sources of relevant information and software applications must be disclosed.
Search methodologies for ESI must be discussed.
Parties must discuss ESI production format, metadata, threading, de-duplication, privilege, redactions, and timing.
Parties must discuss whether to jointly submit ESI discovery order.
Parties must discuss alternative privilege logs and clawback agreements.