Court Rules

Court-wide rules

Applies court-wide

These 36 rules apply across King County Superior Court. Where this judge's own standing orders above address the same topic, the judge's requirement controls.

Communication

All 14
  • Contact
    Email to chambers

    Counsel/parties must jointly complete the witness examination estimate form and email it to the bailiff at scott.court@kingcounty.gov as soon as possible.

  • Contact
    Email to chambers

    Each courtroom has a designated email address in the form [judge's last name.court]@kingcounty.gov that counsel (or their staff) must use when communicating with court staff by email.

  • Contact
    Email to chambers

    Commissioners' departments have no individual email addresses; the family law, ex parte, and mental health departments each share a single departmental email address.

Formatting

All 8
  • Time estimates on the form must be expressed in tenths of hours and the completed form must be totaled.

  • Trial length estimates must assume a 5-hour trial day and account for witness exams, jury questions in civil cases, opening and closing arguments, voir dire, and motions in limine.

  • Parties may use the court's form or their own form, provided it includes the requested information.

Filing Requirements

All 7
  • Applies to
    Witness examination estimate

    Counsel must confer to determine cross-examination time estimates for each party's witnesses and jointly prepare the form.

  • Applies to
    Witness examination estimate

    Each additional party must create and complete the witness examination information for that party's witnesses.

  • Applies to
    Witness examination estimate

    Failure to complete the form and disclose witnesses may result in exclusion of witnesses or other sanctions.

E-Filing

All 3
  • Applies to
    Witness examination estimate

    The witness examination estimate form must not be filed with the clerk's office; it is submitted to the bailiff by email instead.

  • Applies to
    Working copies of legal pleadings

    Email may not be used to deliver working copies of legal pleadings, including jury instructions, without prior permission of the court.

  • Applies to
    Exhibits

    Exhibits may be submitted digitally or in hardcopy, and the Order from Pretrial Conference in each case specifies which format is ordered.

About Judge Michael K. Ryan

Judge Michael K. Ryan serves on the King County Superior Court, Washington's trial court of general jurisdiction for King County, which handles a wide range of civil, criminal, and family matters.

This judge's published procedures include guidance on witness time forms, practice pointers, protective order attachments, deposition designation guidelines with ruling pages, attorney guidelines for jury instructions, and rules of conduct.

Common questions about Judge Michael K. Ryan's rules

Are courtesy copies required for Judge Michael K. Ryan?

Courtesy copies are required for working copys. Details: delivery on day of service to other parties, by chambers drop off. Department 37 is a hardcopy court; working copies must be submitted to the Judge's mailroom C-203 with Judge Ryan's name and case information clearly marked in the upper right hand corner.

View ruleSource: page 1, section Working Copies and Proposed Orders

Does Judge Michael K. Ryan require a pre-motion conference or letter before filing a motion?

Judge Michael K. Ryan's rules set a pre-motion procedure for discovery. Before discovery motions, counsel must meet and confer in person or by telephone per LCR 37(e) and CR 26(i); email is not a substitute for the conference.

View ruleSource: page 1, section Motions to Compel Discovery

What formatting rules apply to filings before Judge Michael K. Ryan?

Judge Michael K. Ryan's formatting rule includes mark objections using brackets around the portion objected to, use ink-pen (blue or black) or an electronic text box, write objections on the page next to the highlighted portion being objected to, tab the page with a post-it note, and write objections on the page, not on the tabs.

View ruleSource: page 1, section Marking of Deposition Designations for trial

What must be included with jury instructions filings before Judge Michael K. Ryan?

The rule identifies required filing content or certificates. Proposed verdict forms must be submitted together with proposed jury instructions.

View ruleSource: page 1, section Attorney Guidelines for Preparing Jury Instructions for the Court

What must be included with exhibits filings before Judge Michael K. Ryan?

The rule identifies required filing content or certificates. All exhibits must be marked and logged with the Clerk before trial begins, in accordance with the pre-trial order.

View ruleSource: page 1, section C. Testimony

How may parties contact Judge Michael K. Ryan's chambers?

Parties may contact Judge Michael K. Ryan's chambers by email only as allowed by the rule. The rule lists email ryan.court@kingcounty.gov. Counsel and parties must jointly complete the Estimate of Witness Examinations form and email it to the bailiff at ryan.court@kingcounty.gov as soon as possible.

View ruleSource: page 1, section Estimate of Witness Examinations

How does Judge Michael K. Ryan handle sealed or redacted filings?

Judge Michael K. Ryan's rules set procedures for sealed or redacted filings. Documents containing substantive redactions may not be filed without prior permission of the Court.

View ruleSource: page 1, section Attachment to Protective Order

How do I request an adjournment or extension before Judge Michael K. Ryan?

Judge Michael K. Ryan's rules specify what an adjournment or extension request must include. The request must include original date. To continue or strike a motion, parties must email the bailiff with the case name, cause number, and the date the motion is noted, and must file the Notice Striking Motion.

View ruleSource: page 1, section Please Review the Following Before Contacting the Court

Does Judge Michael K. Ryan require motion papers to be bundled?

No. The rule prohibits holding covered papers for bundling. Working copies must not be held back and submitted together with reply briefs; they must be submitted promptly.

View ruleSource: page 1, section Working Copies and Proposed Orders

Is electronic filing required before Judge Michael K. Ryan?

No. Electronic filing is prohibited for the covered filings. The Estimate of Witness Examinations form must not be filed with the clerk's office; it is submitted directly to the bailiff via email instead.

View ruleSource: page 1, section Estimate of Witness Examinations

When is a filing treated as filed before Judge Michael K. Ryan?

The rule addresses filing timing, filing status, or cure windows. Marked depositions must be provided to the bailiff as close to the start of trial as possible and well in advance of their intended use, or as directed by the Court.

View ruleSource: page 1, section Marking of Deposition Designations for trial
Complete rules summary for Judge Michael K. Ryan

Counsel and parties must jointly complete the Estimate of Witness Examinations form and email it to the bailiff at ryan.court@kingcounty.gov as soon as possible.

The Estimate of Witness Examinations form must not be filed with the clerk's office; it is submitted directly to the bailiff via email instead.

Time estimates on the form must be expressed in tenths of hours and the completed form must be totaled.

Witnesses who will appear by deposition must be listed on the form and designated as 'appearing by deposition.'

When estimating total trial length, parties must account for the 5-hour trial day plus time for witness examinations, jury questions, opening and closing arguments, voir dire, and motions in limine.

Counsel must confer to agree on cross-examination time estimates for each party's witnesses and jointly prepare the form.

Parties may use the court's form or create their own equivalent form, provided it includes the requested information.

Each additional party must create and complete the witness estimate information for its own witnesses.

Failure to complete the form and disclose witnesses may result in exclusion of witnesses or other sanctions.

The Court prefers the use of Washington State Pattern Instructions whenever one is applicable.

Proposed verdict forms must be submitted together with proposed jury instructions.

Counsel must meet and confer and prepare one set of jury instructions agreed by all parties plus one set of each party's own proposed (unagreed) instructions for the Court.

The agreed and proposed instruction sets must not duplicate one another unless there is a dispute over the language of a specific instruction.

Parties should try to agree on a single verdict form, and if they cannot, each party should propose its own verdict form.

All jury instruction sets, both cited and uncited, must be emailed to the bailiff in Word format for the Court's use and reference.

Electronic email delivery does not replace the separate requirement to present hard copy working copies of the jury instructions to the Court.

Jury instructions should preferably use 12-point Times New Roman font, be double-spaced with no extra space between paragraphs, and have justified text with 1-inch margins.

Uncited jury instructions must not be numbered or titled.

Uncited jury instructions must not contain any identifying headers, footers, or page numbers.

All exhibits must be marked and logged with the Clerk before trial begins, in accordance with the pre-trial order.

Documents containing substantive redactions may not be filed without prior permission of the Court.

Before any sealing or closure, the court must apply the five-step Ishikawa analysis: showing of need, opportunity to object, less-restrictive-means analysis, weighing of competing public and party interests, and an order no broader than necessary.

A court order authorizing sealing must be obtained for each document filed with the court (via motion noted without oral argument), with the burden on the party seeking sealing to provide the information needed for the court to decide whether all, a portion, or none of the document may be sealed.

A motion to seal must identify the competing interests of the parties and the public and consider less restrictive alternatives such as redaction of confidential or proprietary information, and any sealing order must be no broader than necessary.

Before filing any substantive documents containing information sought to be sealed, the moving party must obtain an order allowing sealing or redaction, allowing sufficient time for noting the motion and receiving a ruling before filing.

Before any documents are sealed in the public file, the protective order and sealing process must comply with these provisions and Washington General Rule (GR) 15.

Parties must use a single set of depositions when marking designations for the trial judge's consideration.

The moving party must mark its deposition designations by highlighting each designated section in a particular color (e.g., yellow highlighter).

The opposing party must mark objections with brackets in blue or black ink-pen (or an electronic text box) on the page next to the highlighted portion, tab the page with a post-it note, and write objections on the page rather than on the tabs.

Objections must state the reason by citing the applicable rule (e.g., Hearsay, ER904) and must not include lengthy narratives.

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