Southern District of California Document Format Requirements

First copy must include instruction number, text, and authority.

The first copy should indicate the number of the proposed instruction, the instruction, and the authority supporting the instruction.

Second copy must be plain paper with only instructions, no marks.

The second copy should contain only the proposed instructions on plain paper, that is, not on pleading paper. No other marks or writings should be present.

Format

WORDPERFECT

Electronic copy must be in WordPerfect format.

This copy also should be presented electronically in WordPerfect format (any version).

Separate statement must be in table format with enumerated facts and citations.

The separate statement should be prepared in a table format, with each undisputed material fact individually enumerated and supported by citations to evidence in the record.

Format

DOCX

Proposed orders and documents must be submitted in Microsoft Word format; Word Perfect is rejected.

All proposed orders and other documents submitted to the Court should be emailed to efile_cheeks@casd.uscourts.gov in Microsoft Word format. Documents submitted in Word Perfect will be rejected by the Court.

Format

DOCX

Proposed jury instructions and verdict forms must be emailed in Word format to chambers.

email a copy in Word format to efile_cheeks@casd.uscourts.gov

Exhibits must be excerpted, labeled, dated, tabbed, indexed; do not include documents already on docket.

All exhibits submitted in support of motions should be excerpted to include only relevant material. All exhibits must be clearly labeled, dated, tabbed, and indexed. Copies of documents already contained on the electronic docket will not be included as exhibits. Such documents should be cited in the text of the motion as [Doc. No. ___ at ___] referencing the docket number of the document cited and using the ECF generated page number for pinpoint cites.

Required

Always

All formatting requirements in Civil Local Rule 5.1 must be followed.

The parties must comply with all of the formatting requirements in Civil Local Rule 5.1 unless otherwise ordered by the Court.

Documents must be scanned with OCR if filing electronically.

In addition, the parties must scan any documents, including exhibits, to be filed on the docket using Optical Character Recognition ("OCR"). The OCR requirement only applies to parties with electronic-case-filing privileges.

Required

Always

Civil trials must use numbers only for exhibit identification, not letters.

In preparing trial exhibits, the parties are directed to contact the Clerk’s Office for exhibit stickers. Parties may create their own exhibit stickers as long as the stickers include the exhibit number and case number. Civil trials must only use numbers for identifying exhibits and not letters, unless otherwise ordered by the Court.

Filings with more than 3 exhibits must have tabbed exhibits.

If a filing has more than three (3) exhibits, the exhibits must be tabbed.

Separate statements must use two-column format with specific content requirements.

The separate statement must be in a two-column format with the moving party providing in numerical sequence the undisputed material facts in the first column followed by the evidence citation that establishes those undisputed facts. In opposition, the opposing party shall indicate in the second column whether the fact is 'disputed' or 'undisputed.' If disputed, the opposing party must state in the second column, directly opposite the fact in dispute, the reasons for the dispute and cite the evidence that supports the position that the fact is controverted.

Courtesy copies must include CM/ECF document header on each page.

The courtesy copy shall contain the CM/ECF document header on the top of each page.

Format

DOCX

Proposed orders must be in Word (.doc) format.

Counsel must email proposed orders in Word (.doc) format to efile_ohta@casd.uscourts.gov

Exhibits in support of motions must be excerpted to relevant material, clearly labeled, dated, tabbed, and indexed.

All exhibits submitted in support of motions should be excerpted to include only relevant material. All exhibits must be clearly labeled, dated, tabbed, and indexed.

Format

DOCX

Proposed orders for agreed continuances must be in Word (.doc) format, emailed to specified address, and include current and proposed dates.

The parties must also email a proposed order in Word (.doc) format to efile_ohta@casd.uscourts.gov. See Civil Chambers Rule II.B. The proposed order must set forth the currently scheduled date and the new, proposed date.

Party-provided exhibit stickers must include exhibit number and case number.

Parties may use their own exhibit stickers if the stickers include the exhibit number and case number.

Civil trials must use numbers (not letters) for exhibit identifiers unless court ordered.

Civil trials must only use numbers for identifying exhibits and not letters, unless otherwise ordered by the Court.

Disputed jury instructions must be color-coded per specified scheme and both parties' versions submitted.

For all disputed instructions, the parties will prepare their respective proposed instruction and submit both proposals in the one set submitted to the Court. The text of the disputed instructions shall be color-coded as follows a. Model Instruction Text: black ink b. Stipulated Modifications to Model Instructions: red ink c. Plaintiff’s Proposed Edits or Additions: blue ink d. Defendant’s Proposed Edits or Additions: green ink

Competing versions of the same disputed jury instruction must be placed consecutively in the submission set.

if the parties propose different versions of the same instruction, each version of the disputed instruction shall comply with the color coding above. These competing versions of the same instruction should be placed one after another in the one set of proposed instructions submitted to the Court.

Courtesy copies must include CM/ECF header on each page.

The courtesy copy shall contain the CM/ECF document header on the top of each page.

Exhibits over 3 must be tabbed with table of exhibits.

If a filing has more than three (3) exhibits, the exhibits must be tabbed and listed in a table of exhibits.

Proposed orders must not include filer's name or 'proposed' in caption.

proposed orders must not contain the name and law firm information of the filing party, and must not contain the word 'proposed' in the caption.

Required

Always

Trial exhibits must follow specific numbering system (Plaintiff numeric, Defendant alphabetic).

In preparing trial exhibits, the parties are directed to contact the Clerk’s Office for exhibit stickers. Parties may create their own exhibit stickers as long as the stickers include the exhibit number and case number. Pursuant to Civil Local Rule 16.1.f.2.c., Plaintiff’s exhibits must be identified numerically, starting with “1,” and Defendant’s alphabetically, starting with A to Z, then AA to AZ, then BA to BZ, etc., unless otherwise ordered by the Court.

Proposed orders cannot contain filer's name/law firm or word 'proposed' in caption.

In accordance with Section 2(h) of the ECF Manual, proposed orders must not contain the name and law firm information of the filing party, and must not contain the word 'proposed' in the caption.

Format

DOCX

Proposed orders must be emailed in Word format.

Counsel must email proposed orders in Word format to

Format

PDF

Exhibits must be attached to documents and filed as separate CM/ECF attachments.

Unless the physical nature of the exhibit renders it impracticable, exhibits must be attached to the documents to which they belong. Each exhibit should be submitted in CM/ECF as a separate attachment. (For example, if a party is filing five exhibits to Document Number 10, the exhibits should be filed as Doc. 10-1, 10-2, 10-3, 10-4, and 10-5.)

Complete bracketed language in form instructions and use bold font.

If the form instructions contain bracketed language or blanks, the parties should provide the Court with the appropriate language from the brackets, and all blanks should be completed. This new language shall be written in bold font.

Exhibits must be excerpted, clearly labeled, dated, tabbed, and indexed.

All exhibits submitted in support of motions should be excerpted to include only relevant material. All exhibits must also be clearly labeled, dated, tabbed, and indexed.

Format

DOCX

Proposed orders must be submitted in Word (DOCX) format simultaneously with the accompanying motion.

Proposed orders should be submitted simultaneously with the accompanying motion in Word format.

Format

DOCX

Proposed jury instructions must be submitted in Word format to the Judge’s efile email and cc the Courtroom Deputy Clerk.

The proposed preliminary and final jury instructions must be filed and submitted to the Court in Word format directly to the Judge’s official email address, which is efile_Robinson@casd.uscourts.gov, as well as copy the Courtroom Deputy Clerk at Jessica_A_Ortiz@casd.uscourts.gov.

A binder of exhibits must be provided for the bench.

A binder of exhibits shall be provided for the bench.

Format

DOCX

Proposed verdict forms must be submitted in Word format via email on the day of motions in limine.

Proposed forms of verdict must be submitted by email in Word format on the day set for motions in limine.

Place exhibits in three-ring binders separated by tabs.

Exhibits are to be placed in three-ring binders separated by tabs.

Format

DOCX

Proposed orders must not contain filer's name/law firm or the word 'proposed' in caption.

Proposed orders must be submitted in Word format simultaneously with all motions that are not fully noticed and set for hearing twenty-eight (28) days or more after the date of filing. In accordance with Section 2(h) of the Electronic Case Filing Administrative Policies and Procedures Manual, proposed orders must not contain the name and law firm information of the filing party, and must not contain the word “proposed” in the caption.

Format

PDF

Courtesy copies must include CM/ECF document header on each page.

The courtesy copy must contain the CM/ECF document header on the top of each page.

Format

PDF

Courtesy copies must be bound on top left corner only, no steel prong fasteners.

Please bind courtesy copies on the top left corner only. Please do not use steel prong fasteners at the top.

Format

PDF

Filings with more than 3 exhibits must have tabbed exhibits with table of exhibits.

If a filing has more than three (3) exhibits, the exhibits must be tabbed and listed in a table of exhibits.

Format

DOCX

Proposed orders for stipulated protective orders must be provided in Word format.

The parties must email a copy of the proposed order in Word format to efile_goddard@casd.uscourts.gov.

Proposed orders must not contain attorney/firm names or insignia in the caption, margins, or footer.

should be free of any attorney names, firm names, document management numbers or insignia in the caption, margins or footer.

Format

DOCX

Stipulated protective orders must be filed as joint motions, with a Word copy emailed to chambers; use of model order is encouraged.

All stipulated protective orders must be filed as a joint motion. The parties must email a copy of the proposed protective order in Word format to efile cabral@casd.uscourts.gov. The parties are encouraged to use the District Court’s model protective order, which is available on the District Court’s website.

Format

DOCX

Proposed orders must be in Word format and free of attorney/firm names or insignia in caption, margins, or footer.

All proposed orders should be submitted by email (efile cabral@casd.uscourts.gov) in Word format and should be free of any attorney names, firm names, document management numbers or insignia in the caption, margins or footer.

Format

DOCX

Proposed orders must be lodged in Word format.

Proposed orders must be lodged in Word format.

Legal citations must follow latest Bluebook guidelines.

When citing legal authority, parties should always follow the latest Bluebook guidelines.

Required

Always

Format

THUMB_DRIVE

All exhibits must be digitized and submitted on thumb drive; CDs/DVDs not accepted.

All exhibits, including audio and video exhibits, are to be digitized wherever possible. The digitized exhibits must be submitted on a thumb drive. CDs and DVDs are no longer be accepted.

Only examiner, examinee, and staff may attend psychiatric exams.

Generally, no other person apart from the examiner and the examinee (and possibly the examiner’s staff) may be present at a psychiatric examination, as it would contaminate the examination.

Attorney generally not permitted at medical exams.

Generally, the examinee’s attorney may not be present.

Required

Always

WordPerfect documents will be rejected by the Court; filings must be in Microsoft Word or Adobe PDF.

Documents submitted in Word Perfect will be rejected by the Court.

Pretrial order must follow CivLR 16.1.f.6.c format.

The proposed pretrial order shall be in the format prescribed by CivLR 16.1.f.6.c.

Required

Always

Format

DOCX

Proposed orders must be in Word Perfect or Word format.

Proposed Orders must be submitted in Word Perfect or Word format.

Required

Always

Courtesy copies must be bound at the top.

The pages of each pleading must be firmly bound at the top. In no event shall a courtesy copy of a pleading be delivered unbound.

Exhibits must be tabbed if more than 3.

If a pleading has more than 3 (three) exhibits, the exhibits must be tabbed.

Format

WORD

Proposed orders must include '[PROPOSED]' in brackets and remove all extraneous information from headers, footers, and margins.

The word 'proposed' in brackets (e.g., '[PROPOSED] ORDER GRANTING EX PARTE APPLICATION TO. . .') must appear on the document. This Chambers Rule, mandating the addition of '[PROPOSED],' supersedes Section 2(h) of the ECF Manual. Additionally, all extraneous information shall be removed from the headers, footers, and margins (e.g., contact information and any attorney or firm information, including firm logos).

Proposed orders cannot include attorney or law firm captions.

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

The digital version submitted to chambers must be in Microsoft Word or a similar digital format.

In addition to filing these documents, the parties must email chambers (efile_schopler@casd.uscourts.gov) a Microsoft Word or similar digital version of them.

Format

DOCX

Proposed jury instructions, verdict forms, and voir dire questions must be provided to chambers in Microsoft Word or a similar digital format.

In addition to filing these documents, the parties must email chambers (efile_schopler@casd.uscourts.gov) a Microsoft Word or similar digital version of them.

Exhibits must be non-duplicative, relevant, and properly labeled.

The parties must avoid duplication of exhibits as much as possible. All exhibits submitted in support of motions should be excerpted to include only relevant material. All exhibits must be clearly labeled, dated, and indexed.

Counsel must bring own electronic equipment for courtroom use.

Counsel are required to bring their own computers, laptops, tablets, HDMI or VGA adapters and wireless cards, if necessary. Counsel should contact the CRD for details and instructions and with questions regarding the use of equipment not provided for by the Court.

Proposed orders must not include name and law firm information per ECF Manual.

However, in accordance with Section 2(h) of the ECF Manual, proposed orders shall not contain the name and law firm information of the filing party.

Required

Always

Margins

1 in

Counsel must stay at podium during witness examination except for brief, permitted approaches.

Counsel should not enter the well, except during voir dire, opening statements, and closing arguments. Counsel should conduct all examination of witnesses from the podium, seek permission from the Court before approaching a witness, and keep any visit to the witness stand brief, e.g., by quickly orienting the witness with an exhibit and returning to the podium. After first asking for permission to approach a witness, counsel does not need to seek permission again for the remainder of that witness’ examination.

Required

Always

Witness examinations must be conducted from podium; approaching witnesses requires court permission.

F. Presentation of Evidence. Please abide by the following rules: Do not enter the well, except during voir dire, opening statement and closing argument. Conduct all examinations of witnesses from the podium. Feel free to approach witnesses during examination, but first seek permission from the Court. Please keep your visit to the witness stand brief, e.g., by quickly orienting a witness with an exhibit and returning to the podium.

Exhibits over 3 must be tabbed and listed in table of exhibits.

If a filing has more than three exhibits, the exhibits must be tabbed and listed in a table of exhibits.

Exhibits must be excerpted, labeled, and not duplicate docket documents.

All exhibits submitted in support of motions should be excerpted to include only relevant material. All exhibits must be clearly labeled, dated, tabbed, and indexed. Copies of documents already contained on the electronic docket should not be included as exhibits. Such documents should be cited in the text of the motion as [Doc. No. ___ at ___] referencing the docket number of the document cited and using the ECF-generated page number for pinpoint cites.

Exhibits over 3 must be tabbed and listed in table of exhibits.

If a filing has more than three exhibits, the exhibits must be tabbed and listed in a table of exhibits.

Exhibits over 3 must be tabbed and listed in table.

If a filing has more than three exhibits, the exhibits must be tabbed and listed in a table of exhibits.

Do not submit model instruction numbers or bracketed instructions.

Do not submit a list of model jury instruction numbers and do not submit model instructions with brackets.

Zoom proceedings require appropriate dress and conduct as in-person court proceedings.

A proceeding conducted via Zoom is still a court proceeding and all attendees are expected to dress and conduct themselves in a manner that is appropriate for a court proceeding.

Required

Always

Participants should ensure devices are charged or have charging cable available.

Because Zoom may quickly deplete the battery of a participant’s device, each participant should ensure that their device is plugged in or that a charging cable is readily available during the video conference.

Citations must consistently use one legal research database per document.

Within a document, parties should consistently cite to one legal research database (e.g., Westlaw or LEXIS, but not both).

Unreported cases not in database require docket number citation.

If a particular unreported case does not appear on a certain database, the party must include the case docket number, as instructed in the Bluebook.

Filings with more than 3 exhibits must be tabbed.

If a filing has more than three (3) exhibits the exhibits must be tabbed.

Use WESTLAW citations when available; provide copies for cases not in WESTLAW/LEXIS.

For cases not assigned to a reporter for publication, WESTLAW citations should be given, if available. Citations to cases not available in WESTLAW or LEXIS should be accompanied by copies of the cases cited.

Required

Always

Motion hearings are generally scheduled on Fridays at 1:30 p.m.

Motion hearing dates are generally set on Fridays at 1:30 p.m.

Courtesy copies should be double-sided but single-sided accepted.

The Court prefers courtesy copies to be printed double-sided, but will accept single-sided.

Required

Always

Trial schedule is 9 AM - 4 PM, Monday-Thursday, with breaks.

Trial generally proceeds from 9:00 a.m. to 4:00 p.m., Monday through Thursday, unless the Court schedules otherwise. There will be a one-hour break over the noon hour and two 15-minute breaks, one in the morning, one in the afternoon.

Court prefers double-sided printing for courtesy copies.

The Court prefers courtesy copies to be printed double-sided.

Required

Always

Counsel should refer to exhibits by exhibit number when possible.

When referring to an exhibit, counsel should refer to its exhibit number whenever possible to keep a complete record.

Required

Always

Counsel may relocate for better viewing of exhibits without court permission.

If an exhibit is being used and counsel's view is obstructed, counsel may relocate for better viewing without requesting permission from the Court.

Defendants must number exhibits starting at 500 instead of using alphabetic letters.

The Court modifies the manner of numbering trial exhibits set forth in Civil Local Rule 16.1(f)(2)(c) as follows: Rather than mark exhibits using alphabetic letters, defendant(s) must number their exhibits beginning at number 500 (or any other number agreed upon with opposing counsel).

Counsel should refer to exhibits by their exhibit number whenever possible.

When referring to an exhibit, counsel should refer to its exhibit number whenever possible to keep a complete record.

Exhibits may be marked with stickers from the Clerk or electronically with case and exhibit numbers.

Exhibit stickers may be obtained from the Clerk of the Court in advance of trial, or exhibits may be marked electronically with the case number and exhibit numbers.

Format

PDF

Courtesy copies should be double-sided but single-sided is acceptable.

The Court prefers courtesy copies to be printed double-sided, but will accept single-sided.

Format

ZOOM

ENE, MSC, and SC proceedings are primarily conducted via Zoom.

The Court conducts the majority of its ENEs, MSCs, and SCs via Zoom. The order setting the hearing will state whether the hearing is in person or via Zoom and will provide the logistics for accessing the Zoom proceeding.

Discovery dispute briefs should only attach necessary exhibits, excluding meet and confer correspondence.

Where briefing has been ordered by the Court, counsel should attach only those exhibits that are necessary to the resolution of the parties’ dispute. Generally speaking, this does not include counsel’s meet and confer correspondence. The foregoing requirements apply to all discovery disputes.

Required

Always

Laptops/desktops preferred over mobile devices for Zoom conferences.

Participants are encouraged to use laptops or desktop computers for the video conference, if possible, as mobile devices often offer inferior performance.

Required

Always

Format

IN_PERSON

Court may order in-person Rule 26(f) conference when beneficial.

A court may order that the conference take place in person where that would appear to be of significant benefit.

Format

IN_PERSON

Premises liability and ADA Title III cases are ideal for in-person Rule 26(f) conferences at the site.

Premises liability cases or Americans with Disabilities Act Title III cases regarding public access barriers are ideal types of cases for in-person Rule 26(f) conferences between the parties and counsel at the site that is the subject of the action.