King County Superior Court Document Filing Requirements

CRITICAL

Applies to

Deposition objections

Objections must state the reason by citing the applicable rule (e.g., Hearsay, ER904) without lengthy narratives.

Reason for objections should be noted by citing the applicable rule. (ie. Hearsay, ER904, etc.) Do not include lengthy narratives about objections.

CRITICAL

Applies to

Jury instructions

Counsel must meet and confer and prepare one set of all-party agreed jury instructions plus a separate set from each party of disputed proposed instructions.

Counsel is requested to meet and confer over jury instructions and prepare the following sets for the Court: One set of agreed (by all parties) instructions. One set from each party of their own proposed instructions, which are not agreed by all parties.

CRITICAL

Applies to

Proposed order

Must include

proposed order

Proposed orders should be submitted in Word format. The Court does not accept working copies via email, except proposed orders when working copies have been submitted in hard copy and not through the Clerk’s E-Working Copies system.

Proposed orders should be submitted in Word format. The Court does not accept working copies via email, except proposed orders when working copies have been submitted in hard copy and not through the Clerk’s E-Working Copies system.

CRITICAL

Applies to

Motion for revision

This Court is considering all Motions for Revision without oral argument at this time. The moving party shall re-note their Motion for Revision without oral argument pursuant to LCR 7. This includes providing the index/list of submissions that were considered by the Commissioner as well as hard copies or eworking copies of those documents. A response is requested from the non-moving party.

This Court is considering all Motions for Revision without oral argument at this time. The moving party shall re-note their Motion for Revision without oral argument pursuant to LCR 7. This includes providing the index/list of submissions that were considered by the Commissioner as well as hard copies or eworking copies of those documents. A response is requested from the non-moving party.

CRITICAL

Applies to

Jury instructions

Proposed verdict forms must accompany proposed instructions, with parties attempting a single agreed verdict form or otherwise proposing their own.

Proposed verdict forms must be provided with proposed instructions. Parties should attempt to get a single, agreed verdict form, if possible. Alternatively, each party should propose their own verdict form.

CRITICAL

Applies to

Court materials

AI may not be used to prepare materials presented in court cases.

AI may not be used in preparation of materials presented in court cases.

CRITICAL

Applies to

Motion

Must include

proposed order

All motions should be submitted with proposed orders in Word format, submitted via eWorking Copies.

All motions should be submitted with proposed orders in Word format, submitted via eWorking Copies.

CRITICAL

Applies to

Response to motion

Responses are required on all motions and should be submitted in accordance with LCR 7(b).

Responses are required on all motions and should be submitted in accordance with LCR 7(b).

CRITICAL

Applies to

Working copy

Must include

proposed order

All working copies must include a proposed order in Word format.

All working copies shall also include a proposed order(s) in Word format.

CRITICAL

Applies to

Working copy

Must include

judge name, case number

Please make sure Judge Scott's name and the case information is clearly marked.

Please make sure Judge Scott's name and the case information is clearly marked.

CRITICAL

Applies to

Witness examination time form

All parties and counsel must jointly complete the Witness Examination Time Form and submit it with the pretrial memoranda five court days before trial.

In addition, Judge Scott requires all parties and counsel to work together to complete the Witness Examination Time Form (188KB), and that form must be submitted together with other pretrial memoranda five court days prior to trial.

CRITICAL

Applies to

Motion

Must include

proposed order

A proposed order must be provided in Word format and emailed to the bailiff for non-dispositive motions.

Please provide a copy of the proposed order in Word format by emailing them to the bailiff.

CRITICAL

Applies to

Settlement memorandum

Parties must submit a settlement memorandum or letter at least 5 court days before the settlement conference outlining the factual background, prior negotiations, positions on outstanding issues, other relevant information, and their settlement proposal.

All parties must provide a brief 3 to 5 pages typewritten memorandum or letter at least 5 court days prior to the settlement conference. This should outline the factual background, any prior negotiations and positions taken on the outstanding issues between the parties, and any other relevant information. Please include your proposal for settlement.

CRITICAL

Applies to

Estimate of witness examinations

Judge Straley requires submission of the witness examination estimate information in every case.

Submission of the following information is required by Judge Straley, in every case.

CRITICAL

Applies to

Motion to seal

Must include

proposed order

The moving party on a motion to seal must submit a proposed order containing the required findings.

The moving party shall provide a proposed order that includes the required findings.

CRITICAL

Applies to

Motion opposition reply brief

Motions, oppositions, replies, and briefs must cite to the consecutive attachment page numbers (other citation information may be added in addition).

All motions, oppositions, replies, and briefs shall cite to these page numbers. A party may include other citation information, such as exhibit numbers, corresponding exhibit pages or paragraph numbers, in addition to the consecutive page cite.

CRITICAL

Applies to

Working papers

If a party would like to request oral argument, the motion should be noted pursuant to the applicable court rules, simply noting in the upper right-hand corner of the working papers “Oral Argument Requested.”

If a party would like to request oral argument, the motion should be noted pursuant to the applicable court rules, simply noting in the upper right-hand corner of the working papers “Oral Argument Requested.”

CRITICAL

Applies to

Discovery motion

Must include

certificate of conference

A certification of the meet-and-confer conference, setting out with particularity its nature, extent, and time, is required with the motion.

A certification by counsel that the conference requirements of these rules have been met is required, and should set out with particularity the nature, extent, and time of the conference.

CRITICAL

Applies to

Confirmation

If ADR with a neutral third party was not accomplished, the confirmation must explain why and identify arrangements to complete ADR before trial, and failure may lead to sanctions.

If ADR with a neutral third party WAS NOT accomplished, you must provide a detailed explanation and identify what arrangements have been made to complete ADR before trial. Counsel/party(ies) may be sanctioned for failure to comply with this requirement.

CRITICALCivil cases

Applies to

Witness time estimates

Submission of the witness time estimates form is mandatory in cases before Judge Crisalli.

Submission of the this form is required by Judge Crisalli.

CRITICAL

Applies to

Motion or brief

Motions, oppositions, replies, and briefs must cite to the consecutive attachment page numbers, though exhibit numbers, exhibit pages, or paragraph numbers may be added.

You must cite to these page numbers in all motions, oppositions, replies, and briefs. A party may include other citation information, such as exhibit numbers, corresponding exhibit pages or paragraph numbers, in addition to the consecutive page cite.

CRITICAL

Applies to

Dispositive motion hearing request email

Must include

case number

An email request for a dispositive motion hearing must include the case name and cause number, the nature of the motion(s) to be heard, and a preferred date range.

Any email request for a dispositive motion hearing must include the following: Case name and cause number; Nature of the motion(s) to be heard; and A preferred date range.

CRITICAL

Applies to

Dispositive motion hearing request

Must include

caption, case number

A dispositive motion hearing request must include the case number and caption in the subject line, the nature of the motion, and the type of hearing and date(s) requested.

Any request for a dispositive motion hearing must be emailed to the court with all parties cc’d and include at minimum: Case number and caption in the subject line Nature of motion Type of hearing and date(s) requested

CRITICAL

Applies to

Motion

Working Papers must be submitted with every motion.

Working Papers are required for all motions.

CRITICAL

Applies to

Motion or opposition

Only summary judgment motions are entitled to oral argument. If you want oral argument on a motion other than a summary judgment motion, please note the motion without oral argument. State "ORAL ARGUMENT REQUESTED" on the first page of your motion or opposition.

Only summary judgment motions are entitled to oral argument. If you want oral argument on a motion other than a summary judgment motion, please note the motion without oral argument. State "ORAL ARGUMENT REQUESTED" on the first page of your motion or opposition.

CRITICALCivil cases

Applies to

Witness examination time form

In civil cases, all parties and counsel must jointly complete the Witness Examination Time Form and submit it with the pretrial memoranda five court days before trial.

In civil cases, Judge Parisien requires all parties and counsel to work together to complete the Witness Examination Time Form, and that form must be submitted together with other pretrial memoranda five court days prior to trial.

CRITICAL

Applies to

Motion for revision

Consistent with the above standard, and given that revision must be based only on the issues and evidence before the Commissioner, the motion should only: (1) provide the hearing information required by LCR 7(b)(8)(B)(iii); (2) identify the error(s) claimed; (3) specify where exactly in the record the issue was argued below; and (4) specify all evidence in the record relevant to the issue (whether in support or opposition). The Court will then determine whether or not to call for supplemental briefing or argument.

Consistent with the above standard, and given that revision must be based only on the issues and evidence before the Commissioner, the motion should only: (1) provide the hearing information required by LCR 7(b)(8)(B)(iii); (2) identify the error(s) claimed; (3) specify where exactly in the record the issue was argued below; and (4) specify all evidence in the record relevant to the issue (whether in support or opposition). The Court will then determine whether or not to call for supplemental briefing or argument.

CRITICAL

Applies to

Written submission

Written submissions must support disputed material assertions with particularized citations (specific page/section/paragraph), docket citations with specific docket number and page, and legal authority with pincites and parentheticals where needed.

The use of clear, specific citations is of utmost importance in written submissions to the Court. Parties cannot and should not rely on the Court to pore over the record to confirm their assertions. Instead, any disputed, material assertions should be supported with a particularized citation to supporting materials. This should include a specific page number, section, or paragraph for each citation. References to prior filings should be supported with particularized citation to the docket (referenced as "Dkt.," "Sub No.," or equivalent) that indicates the specific docket number and specific page (e.g., "Dkt. 1 at 22"). Any disputed or distinctive legal propositions should be supported with citation to legal authority, including a pincite (page number), and when not already apparent, a parenthetical briefly describing the holding or significance of the cited authority. Legal citations need not include parallel citation to regional reporters or the like; citation to the Washington reporter or the U.S. reporter is sufficient and preferred.

CRITICALCivil cases

Applies to

Motion for revision

Each error in a motion for revision must include a 1-3 sentence issue statement and specify record locations for argument and evidence.

For each error, include a short issue statement of 1-3 sentences, specify exactly where in the record the issue was argued to the Commissioner, and exactly where all relevant evidence before the Commissioner may be found, by docket number and page range.

CRITICAL

Applies to

Motion for revision

The motion should NOT present further argument or factual assertions, which generally will be disregarded. The opposing party need not submit a motion to strike such extraneous information and is urged not to do so; such a motion itself will likely be struck as moot.

The motion should NOT present further argument or factual assertions, which generally will be disregarded. The opposing party need not submit a motion to strike such extraneous information and is urged not to do so; such a motion itself will likely be struck as moot.

CRITICAL

Applies to

Motion for revision

Motions for revision of a Commissioner's order shall only identify the error(s) claimed per Local Rule 7(b)(8)(A).

All parties moving for revision of a Commissioner's order will be held to the requirement under Local Rule 7(b)(8)(A) that the motion "shall only identify the error(s) claimed."

CRITICAL

Applies to

Declaration

Factual declarations submitted in support of motions or other briefing should meet the requirements of General Rule 13 (certification), Local Civil Rule 7(b)(5)(B) (form), and Evidence Rule 701 (lay opinion).

Factual declarations submitted in support of motions or other briefing should meet the requirements of General Rule 13 (certification), Local Civil Rule 7(b)(5)(B) (form), and Evidence Rule 701 (lay opinion).

CRITICAL

Applies to

Request for attorney fees

Any request for attorney fees must specify the legal grounds for the requested award, and usually should be accompanied by a fee declaration explaining counsel's relevant experience and rates, with a log of time entries indicating tasks performed and time spent on each. The fee declaration should also indicate whether or not the time entries were created contemporaneously, and whether or not the entries have actually been or will be paid.

Any request for attorney fees must specify the legal grounds for the requested award, and usually should be accompanied by a fee declaration explaining counsel's relevant experience and rates, with a log of time entries indicating tasks performed and time spent on each. The fee declaration should also indicate whether or not the time entries were created contemporaneously, and whether or not the entries have actually been or will be paid.

CRITICAL

Applies to

Discovery motion

Must include

certificate of conference

Discovery motions require a certification that the CR 26(i) meet-and-confer conference occurred, detailing its time, nature, and extent; the conference must be contemporaneous communication and email alone does not suffice.

Parties must pay careful attention to the "meet and confer" requirement of Civil Rule 26(i). The conference must consist of contemporaneous communication, whether in-person, virtual, or by telephone. Email is not a substitute for a dialogue on disputed issues. A certification by counsel that the conference requirement has been met is required, and should set out with particularity the time, nature, and extent of the conference.

CRITICALCriminal cases

Applies to

Electronically filed working copy

Must include

proposed order

Electronically filed working copies must include the proposed order in Word format.

All electronically filed working copies shall also include a proposed order(s) in Word format

CRITICAL

Applies to

Daily witness disclosure

At the end of each trial day, all counsel and parties must be prepared to disclose all witnesses they intend to call the following day.

The Court requires all counsel and parties to be prepared at the end of each day to disclose all witnesses that party is intending to call the following day in trial.

CRITICAL

Applies to

Hearing request email

Email requests for a dispositive motion hearing must include the case name and cause number, counsel names with phone numbers and email addresses, and the hearing type with requested date(s).

Any email request for a dispositive motion hearing must include the following: Case name and cause number Names, phone numbers and email addresses of all counsel Type of hearing and date(s) requested from the available dates on the above calendar

CRITICAL

Applies to

Motion

Per KCLCR 7(b)(4)(C), if a party would like to request oral argument for a matter typically handled without oral argument, the motion should be noted pursuant to the applicable court rules and paperwork should include in the upper right-hand corner "Oral Argument Requested." If, after reviewing all briefing, the Court determines oral argument is appropriate, the Bailiff will contact the parties and set a mutually acceptable time for oral argument.

Per KCLCR 7(b)(4)(C), if a party would like to request oral argument for a matter typically handled without oral argument, the motion should be noted pursuant to the applicable court rules and paperwork should include in the upper right-hand corner "Oral Argument Requested." If, after reviewing all briefing, the Court determines oral argument is appropriate, the Bailiff will contact the parties and set a mutually acceptable time for oral argument.

WARNING

Applies to

Estimate of witness examinations

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

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

WARNING

Applies to

Estimate of witness examinations

If there are additional parties, each party should create and complete the required information for that party's witnesses.

If there are additional parties, each party should create and complete the required information for that party's witnesses.

WARNING

Applies to

Estimate of witness examinations

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

Counsel are to confer to determine estimations for cross-examination time for each party's witnesses and prepare this document.

WARNING

Applies to

Estimate of witness examinations

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

Use tenths of hours for estimates, i.e. .1, .2, .5, 1.0 etc. and TOTAL this form when it has been completed.

WARNING

Applies to

Working papers

To request oral argument on a non-dispositive motion, the motion should be scheduled under the applicable rules and the working papers should be marked “ORAL ARGUMENT REQUESTED” in the upper right-hand corner.

If a party would like to request oral argument, the motion should be “noted” (scheduled) pursuant to the applicable court rules, and you may request that the judge allow oral argument by simply noting in the upper right-hand corner of the working papers “ORAL ARGUMENT REQUESTED.”

WARNING

Applies to

Sentencing memorandum

If the sentencing memoranda are not received, the court will reschedule the sentencing hearing.

If these submissions are not received, the Court will proceed with rescheduling the sentencing hearing.

WARNING

Applies to

Notice of court date

The notice must list the names, addresses, and telephone numbers of all parties requiring notice, including any guardians ad litem.

List the names, addresses and telephone numbers of all parties requiring notice (including GAL) on this page.

WARNING

Applies to

Bond motion

To note a bond hearing, the moving party must provide the defendant's name, defense attorney's name, UCN, charges, arraignment date, trial date, and current bail amount.

For proper identification of an inmate, the following information is needed to note a bond hearing: • The name of the defendant • The defense attorney's name • The UCN (Uniform Control Number) • The charges • Date of arraignment • Trial date • Current bail amount