Judge Lopez Criminal Chambers Rules; Lopez Civil Chambers Rules

=== Judge Lopez Criminal Chambers Rules ===

HONORABLE LINDA LOPEZ UNITED STATES DISTRICT JUDGE CRIMINAL PRETRIAL & TRIAL PROCEDURES I. Court Calendar Criminal matters will generally be heard on Fridays at 9:00 a.m., unless otherwise scheduled by the Court. II. Communications with Chambers A. Letters/Emails. Letters and emails to chambers are prohibited, unless specifically requested by the Court. If letters and/or emails are requested, copies of the same shall be simultaneously delivered to all counsel. Copies of correspondence between counsel shall not be sent to the Court. B. Telephone Calls. Telephone calls to chambers are permitted. For matters other than docketing, scheduling, or calendaring, call chambers at (619) 557-5585, and address your inquiries to Law Clerks. For docketing, scheduling and calendaring matters, call Courtroom Deputy Clerk Rhea Andrews at (619) 557-6412 or email her at [email protected]. C. Requests for Continuances. All requests for continuances should be made as soon as counsel become aware of the need for a continuance by contacting the Courtroom Deputy Clerk at the number above or by email. If counsel stipulate to the continuance, a joint motion should be filed with chambers and a proposed order should be emailed. The joint motion should include the original date, the requested date for continuance (obtained from the Courtroom Deputy Clerk prior to filing), the grounds for continuance and, if applicable, an exclusion of time under the Speedy Trial Act. All motions shall be filed no later than 2 business days prior to the scheduled hearing. D. Proposed Orders. In accordance with Section 2(h) of the Electronic Case Filing Administrative Policies and Procedures Manual, counsel shall email proposed orders on motions directly to the Judge's official email address, which is efile [email protected]. Proposed orders should be submitted simultaneously with the motion, no later than 2 days prior to the scheduled hearing. The proposed order must also include a requirement that any defendant on pretrial release sign and file an acknowledgement of the new court date within 48 hours of the continuance motion being granted. E. Transcripts. Requests for transcripts should be directed to Jessica Borynack, Court Reporter, [email protected]. III. Motions A. Scheduling a Hearing Date. The magistrate judge will set a date for pretrial motions. Any changes to that date or any other hearing date for motions shall be obtained from the Courtroom Deputy Clerk. Criminal Local Rule 47.l(a). Motions are generally heard on the Court's Friday calendar. 1 B. Courtesy Copies. Unless otherwise ordered by the Court, for any document which exceeds 20 pages in length (including attachments and exhibits), the filing party must deliver a file-stamped courtesy copy directly to chambers within 24 hours after filing. If a filing has more than three exhibits, the exhibits must be tabbed and listed in a table of exhibits. C. Notice to Court of Disposition. Any time a case is calendared for motions and counsel for either side knows that a disposition is to take place, counsel has a duty to call or email the Courtroom Deputy Clerk at the earliest available time to inform the Court of the disposition. IV. Dispositions and Sentencing A. Dispositions. Generally, Rule 11 guilty pleas may be taken by the magistrate judges on a report and recommendation. Because the magistrate judge may have a more flexible schedule, the Court encourages pleas before the magistrate judge assigned to the case. B. Immediate Sentencing. Upon request, the Court will proceed with immediate sentencing in certain immigration cases if it has adequate information in the record to perform a meaningful exercise of sentencing authority. Such dispositions are encouraged. C. Sentencing Materials. The parties are expected to follow Criminal Local Rule 32.1. Additionally, the parties must ensure that their respective Sentencing Guideline recommendations are supported by the record before the Court. Both parties must file a Sentencing Summary Chart. All sentencing documents must be filed the Tuesday before the scheduled sentencing hearing (6 days in advance of the hearing). No party shall submit more than five sentencing exhibits without leave of Court. V. Trial Procedures A. Motions in Limine. At the pretrial motions date, the Court will generally schedule a hearing date for motions in limine in advance of trial. Motions in limine are due two weeks before the hearing, with any opposition due one week before the hearing. B. Jury Instructions. The parties should each submit proposed jury instructions to the Court on the first day of trial, unless otherwise ordered by the Court. Supplemental instructions must be filed and served as soon as the need for them becomes apparent. If counsel request the model Ninth Circuit jury instructions, counsel may list the number of the instruction and edition without citing the text. The Court prefers to use the Ninth Circuit Criminal Jury Instructions whenever possible. The Court will accept other proposed jury instructions, but counsel must cite the authority supporting the proposed instruction. Any non-model instructions must be submitted to the Court in Word format directly to the Judge's official email address, which is [email protected]. Any proposed modification of an instruction from statutory 2 authority or the Ninth Circuit Models must state specifically the modification and the authority supporting the modification. Before the case is submitted to the jury, the Court will provide each party with the jury instructions the Court intends to use. It is each party's responsibility to carefully review the instructions and make suggestions to the Court if modifications appear necessary. C. 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 foreseeable procedural and evidentiary issues. D. Proposed Voir Dire Questions and Verdict Forms. Counsel may serve and file proposed voir dire questions and forms of verdict on the day set for motions in limine. E. Jury Selection. The Courtroom Deputy Clerk will provide counsel with a numerical list of the jury panel ("strike sheet") at the start of voir dire . The Court will conduct the initial jury voir dire. The Court will 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. After the Court and counsel have voir dired the panel, counsel may exercise challenges for cause outside the presence of the prospective jurors. The exercise of peremptory challenges will follow. Counsel will exercise their respective challenges by alternating peremptory challenges orally outside the presence of the prospective jurors. 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. 3 Where a party has more than one lawyer, only one lawyer may conduct the examination of a given witness and that lawyer alone may make objections concerning that witness. When objecting, state only the legal ground for the objection; e.g., "Objection, hearsay," or "Objection, Rule 802." Speaking objections are not permitted, unless the Court requests further information from counsel. Refrain from talking to each other in the presence of the jury. If clarification on a matter is needed, please seek clarification from the Court and not directly from counsel. G. Bench Conferences. Sidebar conferences are disfavored. If counsel desire to speak to the Court outside the jury's presence, counsel may request to do so at the start of a recess or at the end of the day. Requests to see the Court outside the presence of the jury when the Court is about to begin the day of trial or reconvene following a recess generally will not be granted. These matters usually can wait until the next recess. H. Exhibits. Government counsel must provide a list of exhibits and give it to the Courtroom Deputy Clerk on the first day of trial. All exhibits must be pre-marked on the first day of trial. Exhibit stickers may be obtained from the Clerk of the Court or from the Courtroom Deputy Clerk, in advance of trial. Before publishing an exhibit to the jury, counsel must either move for admission of the exhibit or allow the Court to inquire whether the opposing side has any objection to publication. When referring to an exhibit, counsel should refer to its exhibit number whenever possible to keep a complete record. If an exhibit is being used and counsel's view is obstructed, counsel may relocate for better viewing without requesting permission from the Court. Pursuant to Local Criminal Rule 1.1(e) and Local Civil rule 79.1, all exhibits will be returned to the party who produced them at the end of trial. 4

=== Lopez Civil Chambers Rules ===

HONORABLE LINDA LOPEZ UNITED STATES DISTRICT JUDGE CIVIL CHAMBERS RULES For questions regarding filing and/or docketing, contact: • The Clerk’s Office at (619) 557-5600; • The CM/ECF Helpline at (866) 233-7983; and/or • The CASD CM/ECF Helpdesk at [email protected] Courtroom Deputy • Rhea Andrews: (619) 557-6412 Court Reporter • Jessica Borynack: [email protected] Chambers • United States District Court Southern District of California 333 West Broadway, Suite 1480 San Diego, CA 92101 Tel: (619) 557-5585 Courtroom 14B [email protected] Unless otherwise ordered by the Court, counsel and pro se litigants are expected to follow the Federal Rules of Civil Procedure, the Local Rules for the Southern District of California (“Civil Local Rules”), the Electronic Case Filing Administrative Policies and Procedures Manual (“ECF Manual”), and any other applicable rules. The Civil Local Rules and the ECF Manual are available on this district’s website: www.casd.uscourts.gov. 1. Communications with Chambers Parties seeking a hearing date must refer to the procedure for doing so below in Section 3B. In light of the Court’s procedure for setting motion hearing dates, telephone calls to chambers are rarely necessary. Such calls may only be made by counsel with knowledge of the case. Counsel should not call chambers with procedural questions. The Court does not give time estimates for its written rulings. Court personnel are prohibited from giving legal advice or discussing the merits of 1 Revised 9/15/2025 a case. When calling chambers, be prepared to identify your case name and number so your call may be directed to the appropriate law clerk. If your call is not answered, you may leave a voicemail—including your name, contact information, case number, case name, and detailed message. Upon reviewing the voicemail, the Court may return the phone call if necessary. Letters, faxes, and emails are prohibited unless otherwise authorized by the Court. The Court’s e-file email account must only be used to lodge or submit proposed orders, required trial documents, or other documents requested by the Court. It is generally not to be used for communication purposes (e.g., asking questions). 2. Discovery Counsel must contact the magistrate judge’s chambers directly for all matters pertaining to discovery. Any objection to a discovery ruling of the magistrate judge must be filed as a motion pursuant to Civil Local Rule 7.1. 3. Motion Practice A. Conference of Counsel Prior to Filing Noticed Motions Any party contemplating the filing of any noticed motion before this Court must first contact opposing counsel to discuss thoroughly—preferably in person—the substance of the contemplated motion and any potential resolution. The conference must take place at least seven (7) days prior to the filing of the motion. If the parties are unable to reach a resolution that eliminates the need to file the anticipated motion, counsel for the moving party must include in the notice of motion a statement to the following effect: “This motion is made following the conference of counsel that took place on [date].” The only exceptions to this meet-and-confer requirement are: (1) in cases where the plaintiff is appearing pro se and is not an attorney; (2) for applications for temporary restraining orders or preliminary injunctions; and (3) motions and cross-motions for summary judgment. Ex parte applications, 2 Revised 9/15/2025 which have separate requirements below, and joint motions are exempt from this rule as they are not noticed motions. B. Motion Hearing Dates Parties filing a noticed motion must set the hearing to be thirty-five (35) days from the motion’s filing date.1 Parties intending to file a motion may not contact chambers for a hearing date. This rule supersedes the requirement of Civil Local Rule 7.1(b). Opposition and reply briefs are due based on the noticed hearing date. See CivLR 7.1(e). The hearing date does not indicate a date for when appearances are necessary; rather, it sets the briefing schedule for the motion pursuant to the applicable local rules including Civil Local Rule 7.1(e). Consequently, the filing party will not specify a hearing time on its motion and must include the following language in the caption of the motion: PER CHAMBERS RULES, NO ORAL ARGUMENT UNLESS SEPARATELY ORDERED BY THE COURT. A party may request oral argument by filing a separate request that explains why oral argument would be helpful to the Court. If the Court grants a request for oral argument or sua sponte decides to hear oral argument, the Court will issue an order setting forth the date and time for oral argument. Parties must contact the assigned magistrate judge’s chambers for hearing and scheduling dates needed for cases referred—either by operation of local rule or by order—to the magistrate judge. See S.D. Cal. CivLR 72.3. Motions that do not comply with the requirements set forth above will be stricken from the docket. C. Proposed Orders A proposed order, if required, must be submitted simultaneously with the relevant motion. 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. to Counsel must [email protected], and include the case number and case name in the subject line of the email. Proposed orders or other documents requiring the judge’s signature must not be filed on the docket. in Word proposed format orders email 1 For example, if the motion is filed on August 4, 2025, the motion date should be September 8, 2025. 3 Revised 9/15/2025 D. E. Briefing If multiple parties are moving for substantially the same relief, they must make every effort to obtain the same hearing date for their motions. If multiple parties are moving for substantially the same relief or opposing a motion seeking substantially the same relief sought against them, and noticed for the same hearing date, counsel must make every effort to coordinate and consolidate the briefing or use the notice of joinder procedure to avoid duplication in briefing. If the briefing is not coordinated or consolidated, counsel for each party must file a declaration concurrently with the briefing describing the efforts and explaining why they were not successful. Sur-Replies and Notices of Supplemental Authority Sur-replies and notices of supplemental authority may not be filed unless leave of court has been granted. The parties must obtain leave of court by filing an ex parte request before filing any sur-replies or notices of supplemental authority. The only exception to this requirement is if there is a change in binding intervening law that is directly on point issued after the filing. Under these circumstances, parties may file a notice of supplemental authority that includes a copy of the order or opinion and any case-identifying information. Counsel may not include any argument in the notice. F. Motions and Cross-Motions for Summary Judgment Cross motions for summary judgment have the same filing deadline as a motion for summary judgment. To the extent possible, the parties shall coordinate the filings of a motion and cross motion for summary judgment so that a consolidated briefing schedule may be applied. The Court requires no duplication of briefing and exhibits. No later than fifteen (15) days before the deadline for filing dispositive motions, all parties on the same side of the case (i.e., all defendants or all plaintiffs), must meet and confer about whether they intend to file a motion for summary judgment, and if so, the bases for that motion. If multiple parties are moving for substantially the same relief or opposing a motion seeking substantially the same relief sought against them, counsel must make every 4 Revised 9/15/2025 effort to coordinate and consolidate the briefing or use the notice of joinder procedure to avoid duplication in briefing. If necessary, parties jointly moving for or opposing summary judgment may request an expanded page limit upon a showing of good cause. If the briefing is not coordinated or consolidated, counsel for each party must file a declaration concurrently with the briefing describing the efforts and explaining why they were not successful. If the Court finds that briefing should have been consolidated but was not, it may strike the briefs and require them to be resubmitted as a joint motion for summary judgment. All motions for summary judgment shall be accompanied by a separate statement setting forth plainly and concisely all material facts that the moving party contends are undisputed. Each material fact shall be followed by a reference to the supporting evidence. The parties should avoid using the separate statements as a means of presenting or repeating legal arguments that are or should be made in the memorandum of points and authorities in support of the motion for summary judgment. Separate statements assist the Court in identification of the material facts as well as pinpointing the evidence that proves those facts. The failure to comply with this requirement of a separate statement may in the Court’s discretion constitute a sufficient ground for denying the motion. Any opposition to a summary judgment motion shall include a response to the separate statement that responds to each of the material facts contended by the moving party to be undisputed, indicating if the opposing party agrees or disagrees that those facts are undisputed. Each material fact contended by the opposing party to be disputed shall be followed by a reference to the supporting evidence. The statement shall also set forth plainly and concisely any other material facts the opposing party contends are disputed. The parties should avoid using the separate statements as a means of presenting or repeating legal arguments that are or should be made in the memorandum of points and authorities in opposition to the motion for summary judgment. Failure to comply with this requirement of a separate statement may in the Court’s discretion constitute a sufficient ground for granting the motion. The separate statement must be in a two-column format with the moving party providing in labeled numerical sequence the undisputed material facts 5 Revised 9/15/2025 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. If any opposing party fails to indicate whether a fact is disputed or undisputed, the Court will consider the fact undisputed. 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. All material facts referenced in a summary-judgment memorandum must cite to that party’s separate statement of facts by number, or if not included in a separate statement of facts, to the specific pages in the evidentiary record. G. H. I. List of Terms/Names For technical motions (especially in patent cases), the parties must send an email (not to be filed) to chambers one week prior to the hearing with a list of pertinent technical terms and/or proper names to assist the court reporter. Exhibits 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, tabbed, and indexed. Courtesy Copies Courtesy copies of filings that exceed 75 pages in length, including attachments and exhibits, must be submitted in accordance with Section 2(e) of the ECF Manual via United States Postal Service mail, courier, or delivery to the Clerk’s Office at 333 West Broadway, Suite 420, San Diego, CA 92101. Courtesy copies must be received by the Court no later than three days after the filing date. The courtesy copy must contain the CM/ECF document header on the top of each page. The Court prefers courtesy copies to be printed double-sided but will accept single-sided. If a filing has more than three (3) exhibits, the exhibits must be tabbed. Parties need not provide courtesy copies for filings that do not exceed 75 pages in length. 6 Revised 9/15/2025 J. K. Failure to Oppose An opposing party’s failure to file an opposition to any motion may be construed as consent to the granting of the motion pursuant to Civil Local Rule 7.1(f)(3)(c). Amended Pleadings Any amended pleading—not just those accompanying a motion for leave to amend—must be accompanied by a redline showing how the amended pleading differs from the operative pleading. Pro se plaintiffs who are incarcerated are excused from this requirement. 4. Seeking Leave to File Documents Under Seal There is a presumptive right of public access to court records based upon common law and first amendment grounds.2 As such, motions to file documents under seal are strongly discouraged. Even where a public right of access exists, such access may be denied by the court in order to protect sensitive personal or confidential information.3 The Court may seal documents to protect sensitive information; however, the documents to be filed under seal will be limited by the Court to only those documents, or portions thereof, necessary to protect such sensitive information. Any document submitted for filing under seal (including motions, responses, declarations, exhibits, etc.) must be accompanied by a motion authorizing such 2 See Nixon v. Warner Comm., Inc., 435 U.S. 589, 597 (1978); Phillips ex rel. Estates of Byrd v. General Motors Corp., 307 F.3d 1206, 1212 (9th Cir. 2002). 3 Although courts may be more likely to order the protection of the information listed in Rule 26(c)(7) of the Federal Rules of Civil Procedure, courts have consistently prevented disclosure of many types of information, such as letters protected under attorney-client privilege which revealed the weaknesses in a party’s position and was inadvertently sent to the opposing side, see KL Grp. v. Case, Kay, and Lynch, 829 F.2d 909, 917-19 (9th Cir. 1987); medical and psychiatric records confidential under state law, see Pearson v. Miller, 211 F.3d 57, 62-64 (3d Cir. 2000); and federal and grand jury secrecy provisions, see Krause v. Rhodes, 671 F.2d 212, 216 (6th Cir. 1982). Most significantly, courts have granted protective orders to protect confidential settlement agreements. See Hasbrouck v. BankAmerica Housing Serv., 187 F.R.D. 453, 455 (N.D.N.Y. 1999); Kalinauskas v. Wong, 151 F.R.D. 363, 365-67 (D. Nev. 1993). 7 Revised 9/15/2025 filing. The motion to seal will be a public entry on the docket and will be available to the public, in accordance with Section 2(j) of the ECF Manual. The motion to seal must provide the Court with a specific description of the particular document or categories of documents to be protected, including, for each document subject to the motion, whether the moving party seeks to seal the document in full or in part (i.e., with redactions). The motion to seal must be accompanied by declaration(s) from individual(s) with knowledge of the content of the documents demonstrating a compelling reason or good cause to protect those documents from disclosure. The standard for filing documents under seal will be strictly applied. The fact that both sides agree to seal or that a protective order was issued at the onset of the case alone is insufficient cause for sealing. After filing a motion to seal, the moving party must immediately file the proposed sealed documents in CM/ECF using the “Sealed Lodged Proposed Document” in accordance with Section 2(j) of the ECF Manual. If the moving party seeks to seal the document in full, the document should be lodged in full, without redactions. If the moving party seeks to seal only portions of the document by using redactions, the document should be lodged with the alleged confidential or privileged information highlighted in yellow for the Court’s consideration. The party requesting sealing must file a "public" version of the document(s) it seeks to file under seal. In the public version, the party may redact only that information that is deemed confidential or privileged. The party shall file the redacted document(s) simultaneously with the motion requesting that the confidential portions of the document(s) be filed under seal. Parties often seek to seal a document only because another party designated the document as sensitive under a protective order, including with a “confidential” or “attorneys’ eyes only” designation. In these circumstances, the moving party must first meet and confer with the designating party to determine whether the designating party maintains that any portion of the document must be filed under seal. If so, the moving party must file a motion to seal. In addition, the designating party must file a response to the sealing motion within seven days that satisfies the sealing standard described above. If no response is filed, the Court may order that the document be filed in the public record. 8 Revised 9/15/2025 5. 6. 7. Ex Parte Applications Before filing any ex parte application, counsel must contact the opposing party to meet and confer regarding the subject of the ex parte application. All ex parte applications must comply with Civil Local Rule 83.3(g) including a declaration from the movant documenting: (1) efforts to contact opposing counsel, (2) counsel’s good faith, in person or by telephone meet-and-confer efforts to resolve differences with opposing counsel, and (3) opposing counsel’s general position regarding the ex parte application. Any ex parte application filed with the Court must be served on opposing counsel via electronic mail with return receipt requested, or overnight mail. The Court may rule on ex parte applications without requiring a response from the opposing party. Any ex parte motion that is not opposed within two (2) Court days will be considered unopposed and may be granted on that ground. Joint Motions / Stipulations Pursuant to Civil Local Rule 7.2 and Section 2(f)(4) of the ECF Manual, all stipulations must be filed as joint motions, except for a properly executed stipulation of dismissal pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii) that does not require a court order to terminate a case. Joint motions must be signed by the Court to have legal effect. At the time of the filing of a joint motion, a proposed order must be submitted to the Court pursuant to Section 3(C) above. Settlement and Dismissal If the parties settle a case, counsel must immediately notify this Court and the magistrate judge of the settlement. If the magistrate judge does not set a deadline for the filing of a “Joint Motion to Dismiss,” the parties must file a stipulation of dismissal signed by all parties who have appeared pursuant to Federal Rule of Civil Procedure 41(a)(1)(A). Any joint motion for dismissal that includes a provision that the court retain jurisdiction will be rejected unless it is accompanied by a consent to Magistrate Judge jurisdiction over all disputes arising out of the settlement agreement, including interpretation and enforcement of the settlement agreement, signed by all parties and their counsel. Please contact chambers for this form. 9 Revised 9/15/2025 8. 9. Temporary Restraining Orders All motions for temporary restraining orders must be briefed. While temporary restraining orders may be heard in true ex parte fashion (i.e., without notice to an opposing party), the Court will do so only in extraordinary circumstances. The Court’s strong preference is for the opposing party to be served and afforded a reasonable opportunity to file an opposition. Absent extraordinary circumstances, the parties shall follow the same procedures required for ex parte applications, as set forth in Section 5 above. In appropriate cases, the Court may issue a limited restraining order to preserve evidence pending further briefing. Pro Se Prisoner Cases In cases involving pro se prisoners as litigants, the Court expects defense counsel and the government entity with which a defendant is associated to cooperate in facilitating the prisoner’s telephonic appearances or personal appearances for any scheduled conference, hearing, or trial. This responsibility includes preparing any writs of habeas corpus ad testificandum for the incarcerated pro se plaintiff and any of his or her incarcerated witnesses, as authorized by the Court. 10. Pretrial Conference Pursuant to Civil Local Rule 16.1(f)(6), the Court requires that the parties lodge by email to chambers a proposed pretrial order at least fourteen (14) days before the pretrial conference. The proposed pretrial order must strictly comply with the requirements set forth in Civil Local Rule 16.1(f)(6)(c). All parties are required to cooperate in completing the proposed pretrial order. For all pretrial dates—including the motions in limine briefing and hearing, final pretrial conference, and other relevant deadlines—parties must refer to the scheduling order issued in their respective case, which is issued by the assigned magistrate judge. Dates in the scheduling order are subject to change by court order. 11. Motions in Limine 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. 10 Revised 9/15/2025 If the case involves multiple plaintiffs or multiple defendants, only one brief per motion in limine per side will be accepted. 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. 12. Telephonic Appearances Telephonic appearances will be permitted only in emergency circumstances upon court approval. If a party needs to appear telephonically before this Court, he or she must contact chambers immediately upon learning of the emergency and leave a voicemail. Upon reviewing the voicemail, the Court will contact the party. Until the Court grants permission for telephonic appearance, the party needing to appear telephonically must arrange to have a colleague appear on his or her behalf. 13. Trial Practice A. Electronic Equipment for the Courtroom The Court provides the following audio/visual equipment: (1) monitors; (2) an overhead projector; and (3) computer connections. Counsel should make his or her own arrangements for their respective needs. Counsel should contact the Court’s courtroom deputy to arrange a time to allow counsel to review and set up equipment for trial. B. Voir Dire and Jury Selection Counsel may serve and file proposed voir dire questions on the day set for motions in limine. The courtroom deputy will provide counsel with a numerical list of the jury panel (“strike sheet”) at the start of voir dire. The Court will conduct the initial jury voir dire and permit follow-up voir dire conducted by the attorneys. After voir dire has concluded, counsel may exercise challenges for cause outside the presence of prospective jurors. Counsel will then make alternating peremptory challenges orally outside the presence of prospective jurors. 11 Revised 9/15/2025 C. Jury Instructions and Verdict Form The parties should submit proposed joint jury instructions in Word format to the Court via email at [email protected] on the day set for motions in limine. Joint proposed supplemental instructions must be submitted as the need for them becomes apparent. The parties should also submit a joint proposed verdict form in Word format to the Court on the day set for motions in limine. The Court prefers to use the Ninth Circuit Manual of Model Civil Jury Instructions whenever possible. The Court will accept other proposed jury instructions, but counsel must cite supporting authority. Before the case is submitted to the jury, the Court will provide each party with the jury instructions the Court intends to use. It is each party’s responsibility to carefully review the instructions and make suggestions to the Court if modifications appear necessary. D. Trial Exhibits 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. For both bench trial and jury trials, the parties must submit one (1) courtesy copy of the trial exhibits three (3) days before trial is set to begin. Counsel should contact the Court’s courtroom deputy to arrange a time to deliver the courtesy copies. The parties must also submit the trial exhibits on a USB flash drive three (3) days before trial is set to begin. The parties must also exchange their Final Exhibit and Witness Lists seven (7) days before trial. They must also email a copy of their Final Exhibit and Witness Lists to chambers. 12 Revised 9/15/2025 E. Trial Procedures Trial generally proceeds from 9:30 a.m. to 4:30 p.m., Tuesday through Friday, unless the Court schedules otherwise. Jury deliberations also generally proceed from 9:30 a.m. to 4:30 p.m., unless the Court schedules otherwise. In civil trials, it is the practice of the Court to set a reasonable time limit for the entire trial. The time limit set by the Court includes opening statements, arguments, testimony, closing arguments, and any other matters that occur over the course of the trial, excluding jury selection. The Court will keep track of time limits, and upon request, the courtroom deputy will inform the parties of the time spent and remaining for trial. The time limit is subject to exception for good cause shown. Counsel and witnesses are expected to be present for trial except in case of an emergency. Lawyers must make every effort to have their witnesses available on the day they are to testify. The Court attempts to accommodate witnesses’ schedules and may permit counsel to call them out of sequence if warranted. Counsel must anticipate any such possibility and discuss it with opposing counsel and the Court. Counsel must promptly alert the Court to any scheduling problems involving witnesses. Do not enter the well, except during voir dire, opening statements, and closing argument. Conduct all examination of witnesses from the podium. Seek permission from the Court before approaching a witness. Keep your visit to the witness stand brief, i.e., by quickly orienting the witness with an exhibit and returning to the podium. When objecting, state only the legal ground for the objection, i.e., “objection, hearsay.” Speaking objections are not permitted unless the Court requests further information from counsel. When a party has more than one lawyer, only one lawyer may conduct the examination of a given witness. F. Bench Trial Fourteen (14) days before trial, counsel must serve and file proposed Findings of Fact and Conclusions of Law. An electronic copy of the proposed Findings of Fact and Conclusions of Law must be emailed to [email protected] in Word format. 13 Revised 9/15/2025 14. Hearing / Trial Transcripts The court reporter should only be contacted to order hearing or trial transcripts, or to ask transcript-related questions (e.g., inquiring about pricing). The court reporter should not be contacted for any other reason. 15. Courtesy Be courteous and respectful at all times, in all settings. Please be familiar with and abide by Civil Local Rule 2.1. 14 Revised 9/15/2025