Pre-Motion Conference Requirements

Contested motions in limine require a response filed within three business days after the Joint Pretrial Order is filed.

Pre-motion letter required for discovery/scheduling dispute motions, must include nature of dispute, issues, and contested matters; lead counsel must confer before involving court.

For discovery/pretrial dispute letters, opposing party must submit a responsive letter of similar length; reply letters are prohibited.

For e-discovery disputes, each party must have a person with detailed knowledge of relevant systems available at any conference.

Counsel’s designated attorney-in-charge must appear at the Scheduling Conference; substitution requires good cause and motion filed well in advance.

Conference attendees must be familiar with the case, prepared to discuss motions/ADR, and authorized to bind the client.

Discovery and scheduling motions require prior permission via a 2-page pre-motion letter after lead counsel confer, with responsive letters allowed but no replies.

Restraining order applications are presented to the Court by the Case Manager after counsel affirms opposing party contact and both parties' availability for conference.

Ex parte restraining order applications are only entertained if they meet Federal Rule of Civil Procedure 65(b) requirements.

Opposed motions require response within 21 days, reply within 10 days after response; sur-replies allowed per local rules, and court may rule when motion is ripe.

Pre-motion conference is required before filing motions or briefs related to disputed discovery or pretrial matters.

Pre-motion conference required before filing specified motions (except in habeas, prisoner, Social Security, Bankruptcy appeals), with mandatory 3-page pre-motion letter and optional 3-page response due within 5 days.

Pre-motion conference letters are not required for motions under Fed. R. Civ. P. 50, 59, or 60.

Parties must confer with opposing counsel on all motions to reach agreement on requested relief.

Nonmovant responses due 21 days after motion filing, replies due 7 calendar days after response; no sur-replies without leave of court.

Parties filing discovery or scheduling motions must arrange a pre-motion conference with the Court before submitting motion papers.

Counsel must confer in good faith to resolve discovery/scheduling disputes; if unresolved, must seek Court conference via joint letter with required content.

Counsel must confer with opposing counsel on all motions; failure to comply may result in denial or striking of the filing.

Opposed motions: responses due 21 calendar days after motion filing, replies due 7 calendar days after response; considered after 28 days.

Counsel must confer in good faith to resolve discovery and scheduling disputes before filing motions.

Counsel must confer with opposing counsel on all motions to reach agreement before filing.

Motions to Dismiss, Sever, and for Separate Trial must be specific and brought to the Court’s attention at least 30 days before jury selection.

Parties must conduct timely plea negotiations, review plea agreements before FPTC, and be ready to plead or proceed to trial at FPTC; monthly FPTC is held to rule on motions and conduct re-arraignments.

Counsel must confer with opposing counsel on all motions to reach agreement on requested relief.

Opposed motions are considered 28 days after filing; non-movant responses due 21 days after motion, replies due 7 days after response.

Counsel must confer in good faith to resolve discovery and scheduling disputes.

Counsel must confer with opposing counsel on all motions to reach agreement on requested relief.

Motions to Dismiss, Sever, and for Separate Trial must be brought to the Court's attention at least 30 days before jury selection.

Opposing parties must respond to opposed filings requesting relief within 7 days of filing.

The Government has 14 days to respond to motions to suppress evidence.

Ex parte TRO applications are only entertained if the initiating party satisfies Rule 65(b) requirements.

Counsel must confer by phone/video before requesting court conference on discovery dispute; must file 3-page letter with required content.

Discovery disputes must be addressed at a conference before filing a motion, with briefing schedule set during the conference if motion is necessary.

Parties must discuss options to reduce e-discovery burdens before seeking court intervention for electronic data disputes.

Counsel resisting e-discovery must be prepared to discuss search/production burdens or have a knowledgeable person available.

Discovery motions must follow Section III Discovery Disputes procedures and fail to resolve the dispute before being filed.

Parties must make good faith attempt to resolve all discovery and scheduling disputes without court intervention; sanctions for bad faith.

Lead counsel must personally confer on all discovery and scheduling disputes before involving the Court.

Initiating letter (max ~2 single-spaced pages) required to obtain permission to bring motion on discovery/scheduling disputes, must include specific content.

Opposing party must submit responsive letter (similar length to initiating letter) to discovery/scheduling dispute initiating letter; reply letters prohibited.

Parties must have a person with detailed knowledge of relevant electronic systems available at conferences for electronic data discovery disputes.

Motions on discovery or scheduling disputes prohibited without permission obtained under Section 13.c.

Requests for in camera inspection of privilege log documents require a letter (max ~3 single-spaced pages) with specific content, after lead counsel conference.

Only one in camera inspection request letter allowed per party, due 60 days before discovery ends or promptly on receipt of later privilege log.

Good faith efforts to seek agreement required for all disputed matters except dispositive motions.

Pre-filing conference and issue identification required for Rule 12(b)(6) and 12(c) motions in civil cases; certificate of conference must include this.

Opposed motions are considered 28 days after filing; responses due 21 days post-motion, replies 7 days post-response; no sur-replies without permission.

Telephone appearances prohibited at initial pretrial/scheduling conferences; initial conferences held by videoconference unless parties prefer otherwise.

Mandatory pre-motion conference required for discovery/scheduling disputes; joint letter (max 3 pages) must be emailed to Case Manager.

Pre-motion conference required before filing discovery or scheduling motions; court resolves disputed issues, determines need for written submissions, and sets filing schedule.

Motion responses due 21 days after motion filing; replies due 7 days after response; no sur-replies permitted without court leave.

Counsel must confer with opposing counsel on all motions to reach agreement on requested relief.

Opposed motions are considered after 28 days, with non-movant responses due in 21 days and replies in 7 days after response; court may consider earlier if needed.

Counsel must confer in good faith to resolve discovery and scheduling disputes before seeking court intervention.

Government has 14 days to respond to motions to suppress evidence.

Counsel must confer with opposing counsel on all motions to attempt to reach agreement before filing.

Motions to Dismiss, Sever, and for Separate Trial must be specific and filed at least 30 days before jury selection.

Opposed filings requesting relief trigger a 7-day response deadline for opposing parties.

Motions in limine optional for unique evidentiary disputes; court may strike boilerplate motions; counsel must seek permission for potentially prohibited trial conduct via motion in limine.

Ex parte restraining order applications are only considered if FRCP 65(b) requirements are met.

Oppositions to motions must be filed within 21 days of the motion's filing with the District Clerk.

Replies to oppositions must be filed within 10 days of the opposition's filing with the District Clerk.

Surreplies must be filed within 10 days of the reply's filing with the District Clerk.

Failure to respond to an opposed motion constitutes no opposition; Court rules when motion is ripe regardless of response.

Discovery motions must state that counsel conferred in good faith with opposing counsel and jointly telephonically conferred with the Court, or recite attempt facts if opposing counsel was unavailable/unwilling.

Discovery motions must be filed more than 21 days before the discovery deadline to allow opposing counsel time to respond.

Counsel must obtain advance leave from the Court to offer evidence or testimony at a motion hearing.

Joint motion for appointment of attorney ad litem required before ADR if conflict exists between parent/guardian and minor.

Joint motion for appointment of attorney ad litem required upon settlement to represent minor at settlement hearing.

Responses to dispositive and non-dispositive motions must be filed within 21 days of the motion's filing.

Motions to withdraw guilty/nolo pleas must be filed within 14 days of plea hearing; objections to Magistrate Judge’s R&R must be filed within 14 days of R&R execution; hearing must be scheduled within 30 days of filing.

Counsel who waives a motion hearing must obtain leave of court to file subsequent motions.

Motions to Dismiss (Rule 12) and Motions to Sever must be in writing, state their basis with supporting authority, follow the Scheduling Order, and hearings are granted at the Court’s discretion.

Ex parte restraining order applications are only permitted if they meet Federal Rule of Civil Procedure 65(b) requirements.

In minor plaintiff cases with potential conflict of interest, counsel must jointly move to appoint attorney ad litem prior to mediation or ADR.

In settled minor plaintiff cases with no conflict, counsel must jointly move to appoint attorney ad litem for the settlement hearing.

Emergency applications are presented to the Court only after counsel confirms the opposing party is contacted and both parties are available for a conference.

Responses to opposed motions due 21 days after filing; replies due 10 days after response; no response deemed consent.

Motions to Dismiss, Sever, and Separate Trial must be specific and filed 30+ days before jury selection.

Parties challenging Confidential Information designations must attempt good-faith dispute resolution before seeking court intervention.

Pre-motion initiating letter (max ~2 single-spaced pages) required to obtain permission to file motions on discovery or scheduling disputes.

Letter (max ~3 single-spaced pages) required to request in camera inspection of up to 20 privilege log documents, with lead counsel conferring beforehand.

Before filing Rule 12(b)(6) or 12(c) motions in civil cases, counsel must identify pleading issues and confer in good faith; certificate of conference must confirm this.

Discovery or scheduling dispute motions may only be filed with prior permission under Section 13.c.

Civil motion responses due 21 calendar days after filing; replies due 7 days after response, no sur-replies without permission.

Separate requests for oral argument on motions are not required; the Court will notify counsel if oral argument is warranted.

Oral argument is not required for motions; the Case Manager will notify counsel if oral argument is deemed beneficial.

Oral argument requests for motions are not required; Case Manager will notify counsel if Court determines oral argument is beneficial.

Initiating letter not required for discovery relief against nonparties.

Criminal case motion briefing follows CrLR12 and Federal Rule of Criminal Procedure 12.

The Court may rule on a motion before the response filing deadline expires.

The Court typically rules on opposed motions by submission only, without oral argument.

Oral argument requests are not required; the Court will notify counsel if a motion hearing is deemed beneficial.

All ripe motions will be addressed at the next scheduled status conference unless counsel receives contrary notice.

The Court will issue timely rulings and provide order copies for motions decided without a hearing or taken under advisement.

All pending motions are considered at the Final Pretrial Conference.

Criminal motion briefing deadlines follow CrLR12 and Rule 12 of the Federal Rules of Criminal Procedure.

Case management conferences are held via Zoom webinar unless noted otherwise; all other hearings are in person unless noted or leave is granted.

Bench and jury trials start Mondays at 9:00 a.m., run through Thursday; half-day (4.5h) or full-day (6.5h) schedule based on projected length.

Cross-motions for judgment under Federal Rule of Civil Procedure 52 must adhere to the same briefing and scheduling guidelines applicable to cross-motions for summary judgment.

Parties filing motions in limine must first seek a stipulation from opposing parties to the requested relief.

Prior leave of court is required before filing any discovery dispute motion, except as provided in subsequent subsections.

Joint discovery letter briefs must include meet and confer attestation, summarize unresolved issues; no multiple letters, limited legal authority, no declarations, may attach excerpts.

Pre-filing conference and letter are required before filing summary judgment (Rule 56) motions, except in pro se, habeas, and Social Security cases; letter due 7 business days before proposed conference, opponents have 3 business days to respond; conferences are in person only.

Before seeking leave for additional pages, parties must meet and confer and file a single omnibus motion including all requests.

Moving counsel must confer with opposing counsel on a mutually convenient hearing date before noticing any motion.

Simultaneous briefing is prohibited for all motion types.

Claim construction will only be conducted with a dispositive motion absent compelling reason; Patent Local Rules 4-1 to 4-4 apply, 4-5 and 4-6 are superseded.

For cross-motions for summary judgment, parties must file four briefs sequentially in specified order instead of simultaneous pairs.

Reply papers to motions in limine will not be considered.

Parties must be prepared to address specified issues at the pretrial conference, including raising jury instruction disputes to be resolved before opening statements.

Parties must meet and confer to resolve discovery disputes before filing a motion; unresolved disputes require submission of a joint letter brief.

Parties must submit a stipulation and proposed order setting a briefing schedule for cross-motions before filing the first brief.

Noticed motions require meet and confer with opposing counsel at least 7 days prior to filing, unless exempt; declaration required in motion if no resolution.

Opposition briefs due 3 weeks after motion filing, reply briefs due 2 weeks after opposition; supersedes local rule 7.1(e).

Counsel must meet and confer with opposing party before filing any ex parte motion.

Only motions limited to evidentiary issues are proper in limine motions; specified motion types are excluded.

Counsel must meet and confer before filing motions in limine to resolve issues without court intervention.

Motions in limine due 2 weeks before hearing, opposition due 1 week before hearing unless otherwise ordered.

Lead counsel must comply with Civil Local Rule 26.1.a (meet and confer) before bringing any matter to the Court.

Deposition disputes require immediate meet and confer; unresolved disputes may be called in to chambers for ruling.

After meet and confer exhaustion, movant must email chambers to request pre-motion conference, including required content and copying all counsel.

Lead counsel must promptly meet and confer in person or videoconference before bringing any matter to court; written-only meet and confer is prohibited.

Deposition disputes require immediate meet and confer; unresolved disputes may be brought to chambers for ruling, with follow-up required if judge is unavailable.

Discovery motions may not be filed until pre-motion conference is held, unless leave of court is obtained.

Failure to meet and confer in good faith for motions in limine results in an order to show cause regarding sanctions.

Good faith telephone/video conference required before judicial intervention for discovery disputes.

Parties must email chambers to request telephone conference before filing discovery motion, including prior efforts, dispute summary, and relevant attachments.

Parties filing summary judgment motions must meet and confer to develop a single joint appendix of exhibits.

Parties must request a pre-filing conference with the Court before filing any discovery motion requiring intervention.

Dispositive motions and Rule 702 expert exclusion motions must be filed by [+4 weeks], responses by [+2 weeks], replies by [+1 week].

Motions in limine must be filed 14 days prior to Pretrial Stipulation, responses due [+1 week].

Counsel may request telephone/video conference for simple discovery disputes; must attempt to resolve with opposing counsel first and submit letter via email.

Counsel must meet and confer with opposing counsel at least 7 days before filing Rule 12, 56, removal, or transfer motions; verbal communication required, pro se/bankruptcy/Social Security appeals exempt.

Parties must confer on discovery confidentiality before seeking court intervention per FRCP 26(c).

Motion practice is governed by Local Rule 7.1 subject to these procedures, local rules, standing orders, and supplemental rules for Social Security and Section 2254 cases.

Pre-motion conference with the Court is required for all discovery motions if parties cannot reach agreement.

Before filing motions in limine, parties must make a good-faith meet and confer with the opposing party and comply with LCR 7(d)(5).

Parties must meet and confer in good faith before filing a motion to compel.

Parties must contact the Magistrate Judge and learn their procedures before filing opposed discovery motions in referred cases.

Motions to dismiss under FRCP 12(b) are discouraged if the defect can be cured by an amended pleading; parties should not oppose timely motions to amend.

Motions in limine are discouraged if they do not identify specific evidence to exclude, are overly general, or seek routine FRE application; Daubert issues are prohibited.

Oral argument is decided after briefing is completed on a motion.

File a letter via ECF to Chambers for order of reference to Magistrate Judge upon first discovery dispute; thereafter direct all disputes to Magistrate Judge.

In limine motions require separate notice of motion and brief, omnibus motions prohibited, responses individual, no replies allowed.

Initial pretrial conference is not automatically cancelled if a fully briefed motion is pending; court may adjourn conference if motion is not fully briefed. Counsel must discuss pending motions at conference.

Pre-motion letters required for specified motions, max 3 single-spaced pages; response due 7 days, max 3 pages; exemptions for pro se, bankruptcy, social security cases.

Leave required to file summary judgment motion before close of fact discovery; leave request requires 3-page letter, opposition due 7 days.

Most civil motions require leave via pre-motion letter (max 3 pages) from moving party, with opposing response letter (max 3 pages) within 1 week; Rule 12(b) and remand motions within 30 days of removal are exempt.

Parties must meet and confer on all motions in limine before filing; absent prior leave, each side is limited to 5 total motions in limine.

Motions requiring shortened notice cannot be scheduled before the order shortening time is entered.