Judge D. Thomas Ferraro

Unless otherwise ordered, no later than seven (7) days before the ENE, the parties shall lodge confidential statements of five pages or less directly with the chambers of Magistrate Judge Ferraro at efile_Ferraro@casd.uscourts.gov.

If the total number of pages including exhibits is fifty (50) pages or less, you may lodge the ENE statement via email at efile_Ferraro@casd.uscourts.gov. If the submission exceeds fifty (50) pages the document must be delivered to: United States District Court Southern District of California Attn: Magistrate Judge D. Thomas Ferraro 333 West Broadway, Suite 1010 San Diego, CA 92101

If the parties fail to resolve their dispute through the meet and confer process, then counsel for all three pages and shall include: 1. A statement as to whether the moving party has complied with the 30-day Rule; 2. Each discovery request in dispute; 3. A brief, non-argumentative statement, not exceeding 100 words of each party’s position on the dispute; 4. Three dates within the next 10 days on which counsel for all parties are available for a conference with the Court or the Court’s staff if the Court so orders; 5. A statement describing the parties in-person or telephonic meet-and-confer efforts; and 6. Attached exhibits of the discovery responses at issue that include the text of the request, the response, and any objections. Counsel should provide excerpts of only the discovery responses at issue, not the entire set of responses.

If the dispute arises during a deposition, counsel should suspend the deposition and immediately meet and confer. If the dispute is not resolved after meeting and conferring, counsel may call Judge Ferraro’s chambers to potentially receive an immediate ruling on the dispute. If Judge Ferraro is available, he will either rule on the dispute or give counsel further instructions on how to proceed. If he is unavailable, counsel must mark the deposition at the point of the dispute and continue with the deposition. Thereafter, counsel must further meet and confer regarding all disputed issues pursuant to the requirements of Civil Local Rule 26.1(a). If counsel have not resolved their disputes through the meet and confer process, they must proceed as noted in these Chambers Rules.

When an Order directs you to “lodge” documents with chambers (usually, your ENE brief or your MSC statement), if the total number of pages including exhibits is fifty (50) pages or less, you may lodge the document via email at efile_Ferraro@casd.uscourts.gov. If the submission exceeds fifty pages, the document must be delivered directly to the Court through the intake window on the fourth floor of the Carter-Keep Courthouse.

Proposed orders must not include an attorney or law firm caption on the title page or side margin.