Southern District of California Page & Word Limits

Attorney limit

25 pages

Applies to

Trial brief

Trial briefs are limited to 25 pages.

Trial briefs are limited to twenty-five (25) pages.

Attorney limit

10 pages

Applies to

Motion for reconsideration

Reconsideration motions limited to 10 pages, no attachments or exhibits.

The motion for reconsideration must be no more than ten (10) pages in length and may not include attachments or exhibits;

Attorney limit

5 pages

Applies to

Evidentiary and procedural objections

Evidentiary/procedural objections limited to 5 pages if filed separately.

If filed as a separate document, evidentiary and procedural objections may not exceed five (5) pages in length.

Attorney limit

5 pages

Applies to

Motion in limine

Motions in limine limited to 5 motions per side, 5 pages each, single subject.

Motions in limine will typically be heard in advance of the first day of trial, on a date set by the Court. Each side is allowed a maximum of five (5) motions in limine. Each motion must be limited to a single subject. Each motion and each opposition are limited to five (5) pages in length. Attachments are also limited to a maximum of five (5) pages for any motion or opposition.

Limit

10 pages

Applies to

Motion

Motions for reconsideration are limited to 10 pages and cannot include attachments or exhibits.

3. The motion for reconsideration must be no more than ten (10) pages in length and may not include attachments or exhibits;

Limit

5 pages

Applies to

Motion

Motions in limine limited to 5 per side, single subject only, with 5-page limit for motion, opposition, and attachments.

Motions in limine will typically be heard in advance of the first day of trial, on a date set by the Court. Each side is allowed a maximum of five (5) motions in limine. Each motion must be limited to a single subject. Each motion and each opposition are limited to five (5) pages in length. Attachments are also limited to a maximum of five (5) pages for any motion or opposition.

Limit

25 pages

Applies to

Trial brief

Trial briefs are limited to 25 pages and may not include attachments or exhibits.

Trial briefs are limited to twenty-five (25) pages. Attachments or exhibits may not be appended.

Attorney limit

15 pages

Applies to

Separate statement

Summary judgment separate statements limited to 15 pages.

Absent leave of court, separate statements shall be limited to 15 pages and must comply with the font requirements of Civil Local Rule 5.1.

Limit

10 pages

Applies to

Motion in limine

Motions in limine and oppositions limited to 10 pages; attachments also limited to 10 pages.

Absent leave of court, each motion in limine and each opposition thereto shall be limited to ten pages in length. Attachments to any motion in limine or opposition thereto shall also be limited to ten pages in length.

Limit

5 motions

Applies to

Motion in limine

Maximum of five motions in limine per side.

Each side is limited to five motions in limine.

Limit

5 pages

Applies to

Motion in limine

Each side may file max 5 motions in limine; motions and responses limited to 5 pages; replies are prohibited.

Unless the Court grants permission otherwise, each side is limited to five motions in limine and the motions and the responses to the motions will not exceed five pages. No replies to motions in limine are permitted.

Attorney limit

25 pages

Applies to

Trial brief

Trial briefs are limited to 25 pages.

Trial briefs are limited to twenty-five (25) pages.

Attorney limit

15 pages

Applies to

Separate statement

Separate statements for summary judgment motions limited to 15 pages.

Absent leave of court, separate statements shall be limited to fifteen (15) pages and must comply with the font requirements of Civil Local Rule 5.1.

Attorney limit

5 count

Applies to

Motion in limine

Each side limited to 5 motions in limine, each filed separately on the docket.

Each side is limited to a maximum of five (5) motions in limine. Each motion in limine must be filed separately on the docket.

Attorney limit

10 pages

Applies to

Motion in limine

Motions in limine and oppositions limited to 10 pages; attachments also limited to 10 pages.

Each motion in limine and each opposition shall not exceed ten (10) pages in length. Attachments to any motion in limine or opposition shall also be limited to ten (10) pages in length.

Attorney limit

10 pages

Applies to

Motion in limine

Motions in limine and oppositions limited to 10 pages.

Each motion in limine and each opposition shall not exceed ten (10) pages in length.

Attorney limit

10 pages

Applies to

Attachment

Attachments to motions in limine limited to 10 pages.

Attachments to any motion in limine or opposition shall also be limited to ten (10) pages in length.

Attorney limit

5 count

Applies to

Motion in limine

Maximum of 5 motions in limine per side.

Each side is limited to a maximum of five (5) motions in limine.

Attorney limit

10 pages

Applies to

Motion in limine

Exceeding page limits or filing multiple motions without leave will result in striking.

Unless the parties obtain leave of Court to exceed the limitations contained herein prior to filing, multiple filings and filings that exceed the page limitations will be stricken.

Attorney limit

10 pages

Applies to

Motion in limine

5 motions in limine max per side, 10 pages each, no replies unless directed.

Each side is limited to a maximum of five (5) motions in limine. Each motion in limine must be filed separately on the docket. Each motion in limine and each opposition shall not exceed ten (10) pages in length. Attachments to any motion in limine or opposition shall also be limited to ten (10) pages in length. No replies shall be filed unless directed by the Court.

Attorney limit

25 pages

Applies to

Omnibus brief

Motions in limine and Daubert motions must be filed as single omnibus brief (max 25 pages).

File all motions in limine, including all trial-related Daubert motions, in a single, omnibus brief not to exceed twenty-five (25) pages.

Attorney limit

25 pages

Applies to

Opposition brief

Oppositions to motions in limine and Daubert motions must be filed as single omnibus brief (max 25 pages).

File all oppositions to motions in limine, including all trial-related Daubert motions, in a single, omnibus brief not to exceed twenty-five (25) pages.

Attorney limit

25 pages

Required

Always

Applies to

Closing brief

Closing briefs (max 25 pages) may be filed instead of closing arguments within 4 weeks of transcript availability.

Rather than hear closing arguments, unless otherwise ordered, the parties will be permitted to file closing briefs not to exceed twenty-five (25) pages within four (4) weeks of the date on which all relevant transcripts become available.

Attorney limit

25 pages

Applies to

Motions in limine

Maximum 5 motions in limine per side, filed as single 25-page omnibus brief.

absent extraordinary circumstances and without leave of the Court, the Court will entertain no more than five (5) motions in limine—including trial-related Daubert motions—per side. All motions in limine must be filed in a single, omnibus brief not to exceed twenty-five (25) pages.

Attorney limit

21 days_before_hearing

Applies to

Motion

Motions must be filed 21 days before hearing; oppositions 7 days before.

All motions shall be filed at least 21 calendar days before the hearing date, except motions in limine and those pertaining to sentencing matters. Opposition briefs shall be filed at least 7 calendar days before the hearing date.

Attorney limit

14 days_before_hearing

Applies to

Motion in limine

Motions in limine due 2 weeks before hearing; oppositions 1 week before.

Motions in Limine. At the pretrial motions date, the Court will schedule a hearing date for motions in limine. Motions in limine are due two weeks before the hearing, with any opposition due one week before the hearing.

Attorney limit

5 days_before_trial

Applies to

Trial brief

Trial briefs due 5 court days before trial.

Trial Briefs. Pursuant to Criminal Local Rule 23.1, the parties may, no later than five court days before the date of trial, serve and file briefs on all significant disputed issues of law, including forseeable procedural and evidentiary issues.

Attorney limit

15 pages

Required

Always

Applies to

Discovery motion

Discovery motions and oppositions limited to 15 pages; reply briefs not permitted.

Unless otherwise authorized, discovery motions and oppositions may not exceed 15 pages, exclusive of exhibits. Reply briefs are not permitted unless requested and authorized by the Court.

Limit

7 pages

Applies to

Confidential ene statement

Font

Times New Roman 14 pt

Spacing

Double

ENE Statements limited to 7 pages with specific formatting.

Unless pre-approved by the Court, ENE Statements must not exceed seven (7) pages formatted in accordance with Local Rule 5.1(a), including use of line-numbered pleading paper, double spaced, 14-point Times New Roman, Calibri, or

Limit

10 pages

Applies to

Confidential settlement statement

Confidential Settlement Statements limited to 10 pages excluding exhibits.

The Confidential Settlement Statement may not exceed ten (10) pages, excluding exhibits, and must be formatted according to the requirements of Local Rule 5.1(a).

Limit

5 pages

Applies to

Confidential settlement letter

Optional Confidential Settlement Letter limited to 5 pages for Court review only.

Each party may also submit an optional Confidential Settlement Letter (not to exceed 5 pages) that will be for the Court’s review only.

Attorney limit

10 pages

Applies to

MSC statement

MSC statements limited to 10 pages (exhibits excluded); courtesy copy required if exceeds 40 pages with exhibits.

MSC statements are not to exceed 10 pages, exclusive of exhibits. If any statement exceeds 40 pages with exhibits, a courtesy copy is required.

Attorney limit

7 pages

Applies to

Joint discovery statement

Joint Discovery Statement limited to 7 pages (excluding exhibits).

The Joint Discovery Statement shall be no more than 7 pages excluding exhibits

Attorney limit

10 pages

Applies to

Discovery motion

Discovery motion and opposition limited to 10 pages each (excluding exhibits).

Unless the Court directs otherwise, a discovery motion and any opposition thereto shall be no more than 10 pages each, exclusive of exhibits.

Attorney limit

5 pages

Applies to

Reply brief

Reply briefs in discovery disputes limited to 5 pages.

Requested or authorized reply briefs shall be no more than 5 pages.

Limit

10 depositions

Required

Always

Applies to

Deposition

Each side is limited to 10 depositions unless court grants leave.

Each “side” (“plaintiffs,” “defendants,” or “third party defendants”) is limited to 10 depositions, absent a court order.

Attorney limit

25 questions

Applies to

Interrogatories

Interrogatories are limited to 25 questions.

25 question limit exists;

Attorney limit

5 pages

Applies to

Motion in limine

Each side may file up to 5 motions in limine, 5 pages each.

Typically, each side will be permitted to file 5 motions in limine limited to 5 pages each.

Attorney limit

60 days

Applies to

Motion

Class certification motions must be filed 60 days before motion cut-off date.

Pursuant to Federal Rule of Civil Procedure 23(c), class certification motions should be determined "at an early practicable time after" a putative class action is filed. Accordingly, any motions for class certification shall be filed no later than 60 calendar days before the motion cut-off date set by the Magistrate Judge in the case management order.

Attorney limit

14 days_before_hearing

Motions must be filed 14 days before the hearing date.

All parties shall adhere strictly to Criminal Local Rule 47.1, which provides that all motions must be filed no later than fourteen (14) days prior to the date for which the motion is noticed unless the Court, by order and for good cause only, shortens that time.

Attorney limit

7 days_before_hearing

Sentencing summary charts must be filed 7 days before sentencing hearing.

All parties must adhere strictly to Criminal Local Rule 32.1(a)(9), which provides that completed sentencing summary charts must be filed no later than seven (7) days prior to a scheduled sentencing hearing.

Attorney limit

3 days_before_trial

Trial briefs must be filed by Thursday before trial.

The parties must file trial briefs on or before the Thursday prior to the date of trial.

Attorney limit

3 days_before_trial

Proposed jury instructions must be filed by Thursday before trial.

The parties must file proposed jury instructions on or before the Thursday prior to the date of trial, unless otherwise directed by the Court.

Attorney limit

2 pages

Applies to

Pretrial letter brief

Informal letter briefs (max 2 single-spaced pages) required for pretrial conference, due Wednesday before at 3:00 PM.

In addition to the Proposed Pretrial Order, the parties shall separately submit informal letter briefs, not exceeding two (2) single-spaced pages, to Judge Whelan's chambers (and not filed in the Clerk's Office). The letter briefs must be submitted no later than 3:00 p.m. on the Wednesday before the pretrial conference.

Limit

5 pages

Applies to

Confidential statement

Confidential ENE statements must be submitted 7 days before ENE, max 5 pages.

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.

Limit

50 pages

Applies to

Confidential statement

ENE statements over 50 pages must be delivered physically to chambers.

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

Attorney limit

5 pages

Applies to

Sentencing letter

Each party limited to 5 sentencing letters.

The parties are welcome to submit letters in support of their sentencing recommendations, but each party is limited to no more than five such letters.

Limit

10 pages

Applies to

Sentencing letter

Parties are limited to ten sentencing letters unless court leave is obtained.

No party shall submit more than ten sentencing letters without leave of Court.

Limit

5 pages

Applies to

Evidentiary objections

Evidentiary and procedural objections filed separately are limited to 5 pages.

If filed as a separate document, evidentiary and procedural objections may not exceed five (5) pages in length.

Attorney limit

0 count

Applies to

Reply

Replies to motions in limine not permitted unless directed by Court.

No replies shall be filed unless directed by the Court.

Attorney limit

1 count

Applies to

Motion in limine

Only one brief per motion in limine per side in multi-party cases.

If the case involves multiple plaintiffs or multiple defendants, only one brief per motion in limine per side will be accepted.

Limit

5 pages

Applies to

Sur reply

Sur-reply brief (max 5 pages) allowed for responding to objections in reply brief.

Responses to objections contained in a reply brief may be made in a sur-reply brief that does not exceed five pages. The scope of such a sur-reply is limited to responses to objections; any additional argument will be disregarded.

Attorney limit

10 minutes

Applies to

Voir dire

Court conducts initial voir dire; counsel may follow up with 10 minutes per side on non-complex cases.

The Court will conduct the initial jury voir dire. On a case by case basis, the Court may permit follow-up voir dire conducted by the attorneys. If voir dire by counsel is permitted, ten minutes per side on non-complex cases generally will be allowed.

Attorney limit

15 minutes

Applies to

Voir dire

15 minutes per side for voir dire in non-complex cases.

If voir dire by counsel is permitted, fifteen (15) minutes per side on non-complex cases generally will be allowed.

Limit

10 depositions

Required

Always

Applies to

Deposition

Rule 30(b)(6) depositions count as one deposition toward the 10-deposition limit.

A Rule 30(b)(6) deposition is treated as a single deposition for the 10-deposition limit even though more than 1 person is designated to testify.

Limit

10 depositions

Required

Always

Applies to

Deposition

Rule 31 depositions upon written questions count toward the 10-deposition limit.

The 10-deposition limit includes Rule 31 depositions upon written questions.