Standing Order for Criminal Cases Assigned to Judge Valenzuela Rev. 3-18-25; Standing Order for Civil Cases Assigned to Judge Valenzuela - Rev. 3-13-25; Order Setting Scheduling Conference - Rev. 3-13-25; Civil Scheduling Worksheets Revised 3-31-25; Scheduling and Trial Order for Civil Cases Assigne

=== Standing Order for Criminal Cases Assigned to Judge Valenzuela Rev. 3-18-25 ===

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Case No. 0:00-cr-00000-CV Plaintiff, v. DEFENDANT, et al., Defendant/s. STANDING ORDER FOR CRIMINAL CASES ASSIGNED TO JUDGE VALENZUELA PLEASE READ THIS ORDER CAREFULLY. IT GOVERNS THE CASE AND DIFFERS IN SOME RESPECTS FROM THE LOCAL RULES. PLEASE BE SURE TO USE THE MOST UPDATED VERSION LOCATED ON JUDGE VALENZUELA’S WEBPAGE.1 1 Judge Valenzuela’s webpage can be found at https://www.cacd.uscourts.gov/honorable-cynthia-valenzuela Rev. 03/18/25 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CONTENTS I. INTRODUCTION ................................................................................................. 4 II. GENERAL REQUIREMENTS ........................................................................... 4 A. Filings .............................................................................................................. 4 1. Formatting ................................................................................................ 4 2. Warning re: Filing Under Seal ................................................................. 5 B. Chambers Courtesy Copies ............................................................................ 6 C. Calendar Conflicts ........................................................................................... 6 D. Attorney of Record at Hearings ....................................................................... 7 III. PRE-TRIAL PROCEDURES .............................................................................. 7 A. Continuances ................................................................................................... 7 B. Motions ............................................................................................................ 8 C. Ex Parte Applications ...................................................................................... 9 D. Motions in Limine .......................................................................................... 10 E. Notice and Discovery .................................................................................... 11 F. Bail Review ................................................................................................... 12 IV. PLEA AGREEMENTS ....................................................................................... 12 A. Digital Courtesy Copy ................................................................................... 12 B. Rule 11 Hearing ............................................................................................. 12 V. TRIAL PROCEDURES ...................................................................................... 13 A. Final Pretrial Conference Requirements ....................................................... 13 1. Trial Memorandum ................................................................................ 14 2. Witness Lists .......................................................................................... 14 3. Exhibit Lists ........................................................................................... 14 4. Case-Specific Glossary .......................................................................... 15 5. Jury Instructions ..................................................................................... 15 Joint Verdict Form ................................................................................. 17 6. 7. Proposed Voir Dire Questions ............................................................... 17 B. Trial Requirements ........................................................................................ 17 1. Timing of Government Materials .......................................................... 18 2. Timing of Defense Materials ................................................................. 18 3. Trial Exhibits ......................................................................................... 19 VI. CONDUCT OF ATTORNEYS AND PARTIES ............................................... 21 A. Meeting and Conferring Throughout Trial .................................................... 21 B. Opening Statements, Witness Examinations, and Summation ..................... 21 C. Objections to Questions ................................................................................. 21 D. Special Accommodations .............................................................................. 22 E. General Decorum While in Session .............................................................. 22 Rev. 03/18/25 2 F. Punctuality ..................................................................................................... 23 G. Exhibits .......................................................................................................... 24 VII. SENTENCING .................................................................................................... 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 03/18/25 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I. INTRODUCTION This action has been assigned to the calendar of United States District Judge Cynthia Valenzuela. Both the Court and the parties’ counsel bear responsibility for the progress of this action. To ensure the just determination of this action, “to secure simplicity in procedure and fairness in administration, and to eliminate unjustifiable expense and delay,” Fed. R. Crim. P. 2, all parties or their counsel, including pro se (without an attorney) defendants,2 are ordered to be familiar with this Order, the Federal Rules of Criminal Procedure, the Local Criminal Rules, the Local Civil Rules, this Court’s online Procedures and Schedules, and the law governing the issues in this case. 3 II. GENERAL REQUIREMENTS A. Filings 1. Formatting The captioned title of every filing shall contain: a. the name of the first-listed defendant as well as the name(s) and number(s) (in the order listed in the Indictment) of the particular defendant(s) to whom the filing applies, unless the document applies to all defendants; b. the individual defendant’s registration number when applicable to the relief requested (e.g., requests for transfer, medical requests); and c. the milestone dates for Indictment, Final Pretrial Conference, Trial, and Last Day of the speedy trial period. All parties shall docket items only as to the particular defendant(s) to whom the 2 Parties appearing pro se must comply with the Federal Rules of Civil Procedure and the Local Rules. Local Civil Rules 1-3 and 83-2.2.3. 3 “When applicable directly or by analogy, the Local [Civil] Rules of the Central District of California shall govern the conduct of criminal proceedings before the District Court, unless otherwise specified.” Local Criminal Rule 57-1. Rev. 03/18/25 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 item pertains, rather than all defendants, unless the item pertains to all. Except for documents filed under seal or in camera, every document shall be filed electronically in such a way that it is clear from the docketing entry to which defendant(s) it applies. The outer envelope containing any document filed under seal or in camera should identify the case title by the first-listed defendant and case number only and should state that the document is being filed under seal or in camera. Pursuant to Local Civil Rule 11-3.1.1, either a proportionally spaced or monospaced face may be used. Typeface shall comply with Local Civil Rule 11-3.1.1. Times New Roman font must be no less than fourteen (14) point, and Courier font must be no less than twelve (12) point. Footnotes shall be in the same font and the same size as the text in the body of the document. Each declaration, exhibit, or other attachment accompanying a document must be filed as a separately docketed attachment to the main docket entry with a clear description (e.g., Dkt. 29-1, Smith Decl.; Dkt. 29-2, Ex. 1: Photograph). Proposed orders must state the relief sought, the defendant(s) affected, and, when relevant, the supporting rationale and authority—and must be submitted in a form that would originate from the Court. Do not include: (a) any attorney information on the caption page; (b) any information in the footer (except pagination); or (c) any watermark or firm designation anywhere. Counsel must follow the Central District’s Local Rules and General Orders concerning electronic filing, unless superseded by this Order. Counsel shall adhere to Local Civil Rule 5-4.3 with respect to the conversion of all documents to .pdf so that when a document is e-filed, it is in the proper size and is .pdf searchable. Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document. See Local Civil Rule 5-4.3.1. 2. Warning re: Filing Under Seal Parties should pay close attention to the title in the caption of every document submitted to the Court for filing under seal. The title of the document will become part Rev. 03/18/25 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 of the public docket text when it is entered on the docket, even though the document itself will be sealed. If the title of the document contains confidential information that should not be reflected on the public docket, parties must submit the document with two cover sheets. The first cover sheet must contain a generic title (e.g.: “SEALED APPLICATION”; “SEALED MOTION”; “SEALED PROPOSED ORDER”; or “SEALED DOCUMENT”), rather than the actual title of the document. The second cover sheet must contain the full, unredacted title of the document. Docket entries for documents filed under seal will include only the generic title. All documents pertaining to the notice of manual filing must be emailed to the chambers email address: [email protected]. Additional information is available at: https://www.cacd.uscourts.gov/court-procedures/filing-procedures/criminal-filing- procedures. B. Chambers Courtesy Copies The processing of unnecessary chambers copies wastes resources and burdens the Court. Chambers copies should not be submitted unless requested. This order, however, is not intended to affect the parties’ ability to file and lodge documents and materials that are exempt from electronic filing under Local Criminal Rule 49-1.2. The Court refers the parties to the trial requirements listed below for details regarding mandatory chambers copies of trial exhibits. C. Calendar Conflicts If any counsel discovers a calendar conflict with a scheduled appearance in a court of a more senior district judge, counsel must inform opposing counsel and the Courtroom Deputy Clerk (“CRD”) via chambers email address ([email protected]) as soon as possible and not later than three (3) business days before the scheduled appearance. Counsel must email the CRD to indicate the time of the appearance, the case name, and the name of the other judge. Counsel should appear before the most senior judge first and request priority. On the day of the appearance, if possible, ask the other judge’s CRD to update Judge Rev. 03/18/25 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Valenzuela’s CRD as to when counsel is likely to be released from the other judge’s courtroom. D. Attorney of Record at Hearings The Court requires an attorney of record to appear at all hearings and will not permit others to stand in on his or her behalf. If an attorney of record cannot appear at a scheduled hearing due to unforeseen circumstances, the parties should attempt to agree on a new date to accommodate the calendar conflict. Counsel must propose a new date by Stipulation and [Proposed] Order as soon as possible and preferably not later than three (3) business days before the scheduled appearance. III. PRE-TRIAL PROCEDURES A. Continuances Requests for continuances of pretrial and trial dates must be by motion, stipulation, or application. Each request must include a detailed factual showing of good cause and due diligence demonstrating the necessity for the continuance, stating whether any previous requests for continuances have been made and whether these requests were granted or denied by the Court. The Court will not grant requests to continue pretrial and trial dates absent the detailed showing. General statements are insufficient to establish good cause. To the extent the request to continue dates is joint, it should state clearly that the government and defendant(s) agree. To the extent the action is complex, one or more parties require additional time to prepare for trial, or other circumstances apply necessitating a continuance, the request should so state and describe in detail. A list of counsel’s upcoming scheduled trials in other actions will not support a showing of good cause absent the following information regarding each such action listed: (1) the case name, case number, court where the action is pending, and the initials of the district judge or name of the state court judge assigned to the action; (2) the age of the action; (3) the nature of the offense(s) charged and complexity of the action; (4) the scheduled trial date; (5) the estimated length of trial; (6) the number of continuances Rev. 03/18/25 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 previously granted; (7) the parties’ trial readiness; (8) the estimated likelihood a future continuance will be requested; and (9) the likelihood the trial will proceed on the scheduled date. Counsel shall file requests for continuance of trial at least one (1) week prior to the Final Pretrial Conference. A request to continue dates that have already expired constitutes a presumptive lack of due diligence. Requests extending dates set by the Court are not effective unless approved by the Court. B. Motions Motions shall be filed in accordance with Fed. R. Crim. P. 47 and Local Criminal Rule 49, et seq., unless superseded by this Order. Counsel must meet and confer with opposing counsel “to discuss thoroughly … the substance of the contemplated motion and any potential resolution” thereof. Local Criminal Rule 57-1; Local Civil Rule 7-3. Counsel shall discuss the issues to a sufficient degree that if a motion is still necessary, the briefing may be directed to those substantive issues requiring resolution by the Court. The Court hears motions in criminal actions on Friday, beginning at 10:30 a.m. Pretrial motions, including motions to suppress evidence, motions to bifurcate or sever, and motions concerning character evidence under Fed. R. Evid. 404(b), shall be noticed for a Friday that is mutually agreed to by counsel and that is not closed on the Court’s calendar. Before filing a motion, the moving party should check the Court’s webpage for available hearing dates. The parties should not calendar a matter on a date that is closed on the Court’s webpage. If this occurs, the court will re-calendar the matter for another day. Pretrial motions that require an evidentiary hearing shall be noticed for a non-Friday that is mutually agreed to by counsel and that is cleared with the Courtroom Deputy Clerk before the filing of the motion. For all motions other than motions in limine, the briefing schedule is as follows:  motions shall be filed five (5) weeks prior to the hearing;  oppositions or notices of non-opposition shall be filed three (3) weeks Rev. 03/18/25 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 prior to the hearing; and  replies, if any, shall be filed two (2) weeks prior to the hearing. All motions must be properly noticed for hearing no later than the date of the Final Pretrial Conference. The parties should not calendar a matter on a Friday that is a Court holiday. If this occurs, the Court will re-calendar the matter for another Friday. The parties must adhere to the briefing schedule set forth herein to afford the Court adequate time to prepare for the hearing; however, the parties may stipulate to an alternate briefing schedule contingent upon approval by the Court. Failure to comply with these deadlines may result in the Court declining to consider the untimely memorandum or other document. Local Criminal Rule 57-1; Local Civil Rule 7-12. Memoranda of points and authorities in support of or in opposition to motions (besides motions in limine) shall not exceed 7,000 words. See Local Rule 11-6.1. A handwritten brief or a brief prepared using a typewriter may not exceed 25 pages, excluding the caption (if on a separate cover page), the table of contents, the table of authorities, the signature block, and any indices and exhibits. All submitted briefs must be accompanied by a Certificate of Compliance as set forth in Local Civil Rule 11-6.2. Replies shall not exceed 4,200 words or fifteen (15) pages for handwritten briefs and briefs prepared using a typewriter. Only in rare instances and for good cause shown will the Court grant an application to extend these word and page limitations. No supplemental brief shall be filed without prior leave of Court. C. Ex Parte Applications Ex parte applications are disfavored. The Court considers ex parte applications on the papers and does not usually set these matters for hearing. If a hearing is necessary, the parties will be notified. Ex parte applications are solely for extraordinary relief and should be used with discretion. Sanctions may be imposed for misuse of ex parte applications. See Mission Power Eng’g Co. v. Cont’l Cas. Co., 883 F. Supp. 488 (C.D. Cal. 1995). Rev. 03/18/25 9 Ex parte applications that fail to conform to Local Civil Rules 7-19 and 7-19.1, including a statement of opposing counsel’s position, will not be considered except upon a specific showing of good cause. The moving party shall serve the opposing party electronically, if possible. A party is considered served once the ex parte application has been e-filed. All parties registered for electronic service are sent a notification of ECF filing each time a document is e-filed with a link to the document for one free view. Defendants exempt from electronic service must be served the ex parte application by facsimile or personal service. See Local Criminal Rules 49-1.2, 49-1.3.2(b); Local Civil Rule 5-3. Following service of the ex parte application by electronic, facsimile, or personal service, the moving party shall notify the opposing party that any opposition must be filed no later than twenty-four (24) hours following service. Counsel will be notified by ECF of the Court’s ruling. If a party does not intend to oppose an ex parte application, counsel must promptly inform the Courtroom Deputy Clerk. Ex parte applications to allow defendants to travel should be made well in advance of the proposed date of travel. Counsel should state whether the Pretrial Services Officer has approved the travel, and what, if any, conditions the Pretrial Services Officer has proposed. Applications by defendants with appointed counsel must indicate who will pay for the travel and related expenses. If these expenses are not to be paid by the defendant’s employer, the Court may require declarations under penalty of perjury from the persons paying the expenses. D. Motions in Limine Motions in limine fall outside the scope of Fed. R. Crim. P. 12 and address only the admission or exclusion of evidence at trial. Motions in limine will generally be heard and ruled upon at the Final Pretrial Conference. The Court may rule orally instead of in writing. Each side is limited to five (5) motions in limine unless the Court grants leave to file additional motions. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 03/18/25 10 All motions in limine must be filed at least twenty-eight (28) days before the Final Pretrial Conference. Oppositions must be filed at least fourteen (14) days before the Final Pretrial Conference. There shall be no replies. Motions in limine and oppositions must not exceed 2,800 words in length, or ten (10) pages for handwritten briefs and briefs prepared using a typewriter. Before filing a motion in limine, the parties must meet and confer. The moving party must identify the evidence to be excluded or admitted, the specifics terms of the order sought, and the rationale and supporting authority. The nonmoving party shall state whether the party intends to introduce the evidence sought by the moving party to be excluded or oppose the moving party’s motion to admit the evidence and provide the rationale and supporting authority if the nonmoving party opposes the motion. Both parties are required to meet and confer in good faith in an effort to reach a resolution without the need for a motion. Motions in limine should address specific issues (e.g., not “to exclude all hearsay”). The Court may strike without further notice excessive, unvetted, or untimely motions in limine. E. Notice and Discovery Counsel shall comply with all notice and discovery obligations set forth in Fed. R. Crim. P. 12, 12.1, 12.2, 12.3, 12.4, 15, and 16. The government shall promptly produce to counsel for the defendant any evidence falling within the scope of Fed. R. Crim. P. 16(a), Brady v. Maryland, 373 U.S. 83 (1963), Giglio v. United States, 405 U.S. 150 (1972), Roviaro v. United States, 353 U.S. 53 (1957), and United States v. Henthorn, 931 F.2d 29 (9th Cir. 1991). Counsel for the government shall also disclose to counsel for defendant the existence or non-existence of: (1) evidence obtained by electronic surveillance; and (2) testimony by a government informant. Defense counsel shall comply with its reciprocal discovery obligations pursuant to Fed. R. Crim. P. 16(b) and promptly produce such materials. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 03/18/25 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 The parties shall make expert witness disclosures in accordance with Fed. R. Crim. P. 16(a)(1)(G) and (b)(1)(C) at least thirty-five (35) days before the Final Pretrial Conference. The parties are encouraged to produce witness statements pursuant to 18 U.S.C. § 3500 and Fed. R. Crim. P. 26.2 sufficiently in advance of trial or other proceeding to avoid delays. A violation by any party of this order, or by the government in connection with its obligations under Brady, Giglio, Roviaro, or Henthorn, may lead to a finding of contempt, imposition of sanctions, referral to a disciplinary authority, adverse jury instructions, exclusion of evidence, or dismissal of charges. Counsel shall meet and confer to resolve discovery disputes informally prior to filing a motion to compel discovery. All discovery motions shall state with particularity what is requested, the basis for the request, whether the discovery at issue has been requested, and opposing counsel’s response to such request. The Court may decline to hear discovery motions made without prior consultation with opposing counsel. F. Bail Review Any request for bail review based on changed circumstances or information not previously presented to the Magistrate Judge shall be addressed in the first instance to the Magistrate Judge and shall be served on both opposing counsel and the United States Probation and Pretrial Services Office. IV. PLEA AGREEMENTS A. Digital Courtesy Copy The government should send a text-searchable digital copy of the plea agreement to chambers at [email protected]. B. Rule 11 Hearing 1. Fully Signed Agreement: Defense counsel shall bring a hard copy of the fully signed plea agreement to the hearing (because the Court will refer the defendant to specific portions of the Rev. 03/18/25 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 agreement.) Government counsel is also required to bring a hard copy of the fully signed agreement to the hearing. 2. Open Court: The Rule 11 hearing will be conducted in open court. Any request to close the courtroom or seal the record (in whole or in part) must be made by the requesting party when checking in on the day of the hearing. 3. Detention Request: If the government intends to request detention of a defendant who is out on bond, it should file a request, stating and applying the applicable standard, at least two days before the hearing. 4. Sentencing Date: Counsel for both parties shall confer and provide a proposed sentencing date to the courtroom deputy (CRD) upon checking in. Absent good cause, the sentencing date shall be approximately 14 weeks after the defendant’s conviction. The parties should not assume that the sentencing date, once set, will be continued at their request. V. TRIAL PROCEDURES A. Final Pretrial Conference Requirements No later than one (1) week before the Final Pretrial Conference, the government shall file and email the documents described below in Microsoft Word format to [email protected]:  A trial memorandum;  A witness list;  An exhibit list;  A joint case-specific glossary for the Courtroom Deputy Clerk;  Joint jury instructions in the form described below;  A joint proposed verdict form; and  Proposed voir dire questions, if any. Rev. 03/18/25 13 1. Trial Memorandum The government’s trial memorandum shall set forth: (i) a factual summary of the government’s case-in-chief; (ii) a statement of the charges and the elements of each charge; (iii) a time estimate of the length of the government’s case-in-chief, including anticipated cross-examination; and (iv) a discussion of relevant legal and evidentiary issues as applied to the facts of the particular case. The government shall specify, after a meet and confer, whether the parties agree or disagree on matters (i) through (iv). 2. Witness Lists Witness lists must identify all potential witnesses and must be in the format specified in Local Civil Rule 16-5. If the defense objects to identifying a potential witness (not already on the government’s list), the objection must be raised at the final pre-trial conference. The lists must include for each witness: (i) a brief description of the testimony; (ii) the reasons the testimony is unique and not redundant; and (iii) a time estimate in hours for direct and cross-examination. The parties should use the template posted to Judge Valenzuela’s webpage. Any Amended Witness List must be filed by 5:00 p.m. on the Friday before trial and emailed to [email protected] in Microsoft Word format. 3. Exhibit Lists Exhibit Lists must: (1) be in the format specified in Local Civil Rule 16-6; (2) include an additional column stating any objections to authenticity and/or admissibility; and (3) state the reasons for the objections. The parties should use the template posted to Judge Valenzuela’s webpage. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, 1.3, etc. See Local Civil Rule 16-6. The list should include defense exhibits to the extent the defense does not object to disclosure. Any Amended Exhibit List must be filed by 5:00 p.m. on the Friday before trial and emailed to [email protected] in Microsoft Word format. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 03/18/25 14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4. Case-Specific Glossary The parties must provide a case-specific glossary for the court reporter that includes applicable medical, scientific, or technical terms, gang terms, slang, the names and spellings of case names likely to be cited, street/city/country names, all parties/agents/departments/entities involved in the case, names of people interviewed/deposed, names of family members, friends, or others who might be mentioned, and other case-specific terminology. 5. Jury Instructions The parties shall file clean and redline sets of their (1) Joint Agreed Upon Proposed Jury Instructions, and (2) Disputed Jury Instructions. The redline sets shall include all modifications made by the parties to pattern or model jury instructions, any disputed language, and the factual or legal basis for each party’s position as to each disputed instruction. Sources: When possible, all instructions must be taken from the Manual of Model Criminal Jury Instructions for the Ninth Circuit (West Publishing Co., current edition). Where no applicable Ninth Circuit model instruction is available, counsel should consult the instructions from O’Malley, Grenig & Lee (formerly Devitt, et al.), Federal Jury Practice and Instructions (West Publishing Co., current edition). When submitting instructions other than Ninth Circuit model instructions, counsel should ensure the law on which the instruction is based is consistent with Ninth Circuit case law on the subject. Counsel may submit alternatives to the Ninth Circuit model jury instructions or O’Malley, Grenig & Lee instructions only if counsel has a reasoned argument that those instructions do not properly state the law or are incomplete. The Court seldom gives instructions derived solely from case law. Format: Each requested instruction shall (1) cite the authority or source of the instruction, (2) be set forth in full, (3) be on a separate page, (4) be numbered, (5) cover only one subject or principle of law, and (6) not repeat principles of law contained in any other requested instruction. Jury instructions should be modified as Rev. 03/18/25 15 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 necessary to fit the facts of the case (e.g., inserting names of defendant(s) or witness(es) to whom an instruction applies). Where language appears in brackets in the model instruction, counsel shall select the appropriate text and eliminate the inapplicable bracketed text. It is counsel’s duty to conform the instructions to the case (e.g., inserting names of defendant(s) or witness(es) to whom the instruction applies and selecting the appropriate bracketed text, but not changing the standard language of the instruction). For any disputed instruction, the opponent shall state on a separate page following the disputed instruction: (a) the basis for the objection; (b) authority supporting the objection; and (c) an alternative instruction (if applicable). On the following page, the proponent shall briefly respond to the objection with supporting authority. Where appropriate, the disputed instructions shall be organized by subject, so that instructions that address the same or similar issues are presented sequentially. If there are excessive or frivolous disagreements over jury instructions, the Court will order the parties to meet and confer immediately until they substantially narrow their disagreements. Index: All proposed jury instructions must have a consecutively numbered joint index that lists the instructions in the order they will be given. Disputed instructions should be included in the index. The Court will renumber the jury instructions once they are finalized. The joint index should include (i) the number of the instructions; (ii) a brief title of the instruction; (iii) the source of the instruction; and (iv) the page number of the instruction. Example: Number Title Source Page # #1 Conspiracy-Elements 9th Cir. 8.5.1 1 Counsel also shall list the instructions in the order they will be given and indicate whether the instruction should be read before opening statements, during trial, or before closing arguments. Rev. 03/18/25 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Copies of the instructions will be given to the jury during deliberations. Accordingly, counsel must email [email protected] a “clean” set of all instructions in Microsoft Word format, containing only the text of each instruction, set forth in full on each page, with the caption “Court’s Instruction No. ___” (eliminating the title and source of the instruction, supporting authority, etc.). 6. Joint Verdict Form The parties shall make every effort to agree on a verdict form before submitting proposals to the Court. If the parties are unable to agree on a verdict form, the parties shall file and email to Chambers ([email protected]) one document titled “Competing Verdict Forms” which shall include: (1) the parties’ respective proposed verdict form; (2) a redline of any disputed language; and (3) the factual or legal basis for each party’s respective position. 7. Proposed Voir Dire Questions The Court will conduct the voir dire. The Court will ask prospective jurors basic biographical questions (jurors’ place of residence, employment, whether familiar with the parties or counsel, etc.), as well as questions regarding their ability to be fair, impartial, and carry out the duties required. The Court may ask additional case-specific questions. The parties may file and email to Chambers ([email protected]) any proposed case-specific voir dire questions for the Court’s consideration. All challenges for cause and all Batson challenges shall be made at side bar or otherwise outside the prospective jurors’ presence. The Court will not necessarily accept a stipulation to a challenge for cause. B. Trial Requirements Trial days are generally Tuesday through Friday, from 9:00 a.m. through 4:30 p.m. with two 15-minute breaks and a one-hour lunch break. The parties must appear at 8:30 a.m. to discuss preliminary matters with the Court. On the first day of trial, the Court will first address preliminary matters and will call a jury panel only when it is satisfied the case is ready for trial. Jury selection usually takes a few hours. The Rev. 03/18/25 17 parties should be prepared to proceed with opening statements and witness examination immediately after jury selection. Fridays are usually reserved for the Court’s calendar. In the event the Court’s calendar allows trial to proceed on Friday, the Court will inform the parties during the Final Pretrial Conference. Once the trial concludes, the jury will be expected to deliberate Monday through Friday. Any party requesting special court reporter services (i.e., “RealTime” transmission, daily transcripts) shall notify the reporter at least two (2) weeks in advance. 1. Timing of Government Materials The government must present the following materials to the Courtroom Deputy Clerk before trial begins on the first day: 1. Three (3) copies of the indictment/information; 2. Three (3) copies of the government’s witness list; 3. Three (3) copies of the government’s exhibit list; and 4. All government exhibits in accordance with Section IV.B.3 (“Trial Exhibits”) below. 2. Timing of Defense Materials The Court prefers the defense counsel deliver defense exhibits to the Courtroom Deputy Clerk on the first day of trial, but counsel are not required to do so unless these exhibits have previously been provided to the government. Defense counsel shall provide the government and the Courtroom Deputy the defense witness list and exhibit list at the start of the defense case, at the latest. Defense counsel shall also simultaneously email [email protected] a Microsoft Word version of the defense witness list and defense exhibit list. Defense exhibits shall be submitted together in accordance with Section V.B.3 below. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 03/18/25 18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3. Trial Exhibits Trial exhibits that consist of documents and photographs must be submitted to the Court in three-ring binders. The parties shall submit to the Court three sets of binders: one (1) original set of trial exhibits, and two (2) copies of trial exhibits. The original set of exhibits shall be for use by the jury during its deliberations, and the two copies are for the Court. The parties should prepare additional copies of exhibits for their own use and for use by witnesses. Before the admitted exhibits will be given to the jury for deliberation, the parties must review the exhibit list and exhibit binders with the Courtroom Deputy Clerk after closing arguments. All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc. See Local Civil Rule 16-6. Every page of a multi-page exhibit must be numbered. Defendant’s exhibit numbers shall not duplicate the government’s numbers. The spine of each binder shall indicate the volume number and the range of exhibit numbers included in the volume. An enlargement of an existing exhibit shall use the original exhibit number followed by an “A.” Counsel shall not attempt to display or use any charts or enlargements of exhibits unless all counsel have agreed to their use or objections have been heard and a ruling has been made by the Court. The original exhibits shall bear the official exhibit tags (yellow tags for the government’s exhibits and blue tags for defendant’s exhibits) affixed to the front upper right-hand corner of the exhibit, with the case number, case name, and exhibit number stated on each tag. The copy of exhibits must bear copies of the official exhibit tags that were placed on the original exhibits and be indexed with tabs or dividers on the right side. Tags may be obtained from the Clerk’s Office, or the parties may print their own exhibit tags using Forms G-14A and G-14B on the “Court Forms” section of the Court’s website at: https://www.cacd.uscourts.gov/forms/exhibit-tags-plaintiff-g-14a-defendant-g-14b- joint-g-14c. Rev. 03/18/25 19 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 The government must also submit to the Court a USB flash drive containing electronic versions of all exhibits before trial begins. Defense counsel must provide a USB flash drive containing electronic versions of all exhibits at the start of the defense case, at the latest. The document file names should include the exhibit number and a brief description of the document, for example: “Ex. 1 - Smith Declaration.pdf” or “Ex. 105 - Letter Dated 1-5-20.pdf.” Audio, video files, and digital evidence must be contained on a flash drive, unless otherwise directed by the Court. The party introducing the evidence is responsible for ensuring that the flash drive contains only admitted evidence. The parties should meet and confer in an effort to reach an agreement as to the admissibility of such evidence in its original form, as well as any excerpts thereof. Exhibits consisting of audio recordings should be accompanied by appropriate transcripts to assist the trial participants in following along. The party seeking to admit an audio recording should provide transcripts to the opposing party well in advance of trial and, during trial, to the Court, court reporter, each juror, and opposing counsel before the audio recording is played. The transcripts shall use the original exhibit number of the audio recording followed by an “A” for identification purposes. The transcripts will not be admitted into evidence and should be collected after the audio recording has been played. The Court provides audio/visual equipment for use during trial. The parties are encouraged to familiarize themselves with the equipment if they wish to use it. More information is available at: http://www.cacd.uscourts.gov/clerk-services/courtroom- technology. If any counsel wishes to arrange for the use of additional equipment, counsel shall contact (213) 894-3061 to verify and/or reserve demonstrative equipment and notify the Courtroom Deputy Clerk no later than 4:00 p.m. at least one (1) week before trial so that the necessary arrangements may be made. The Court does not permit exhibits to be “published” to the jurors before they are admitted into evidence. Once admitted, exhibits may be displayed electronically Rev. 03/18/25 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 using the equipment and screens in the courtroom. Counsel shall not attempt to display or use any charts or enlargements of exhibits unless all counsel have agreed to their use or objections have been heard and a ruling has been made by the Court. Exhibits such as weapons and narcotics must remain in the custody of a law enforcement agent during the pendency of the trial. It shall be the responsibility of the agent to produce any such items for court, secure them at night, and guard them at all times while in the courtroom. The United States Marshals Service shall be advised well in advance if weapons or contraband are to be brought into the courthouse. VI. CONDUCT OF ATTORNEYS AND PARTIES The Court expects counsel to act in a courteous, reasonable, and professional manner. The Court expects that counsel will adhere strictly to the Central District of California’s Civility and Professionalism Guidelines. See https://www.cacd.uscourts.gov/attorneys/admissions/civility-and-professionalism- guidelines. A. Meeting and Conferring Throughout Trial The parties must continue to meet and confer on all issues that arise during trial. The Court will not rule on any such issue unless the parties have first attempted to resolve it informally. B. Opening Statements, Witness Examinations, and Summation Counsel shall not discuss the law or argue the case in opening statements. Counsel must use the lectern. Counsel should not consume jury time by writing out words and drawing charts or diagrams. All such aids must be prepared in advance. When appropriate, the Court will establish and enforce time limits for all phases of trial, including opening statements, closing arguments, and the examination of witnesses. C. Objections to Questions Counsel must not make speaking objections before the jury or otherwise make speeches, restate testimony, or attempt to guide a witness. Rev. 03/18/25 21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 When objecting, counsel must rise to state the objection and state only that counsel objects and the legal grounds for the objection. If counsel desires to argue an objection further, counsel must seek permission from the Court to do so at sidebar or outside the jury’s presence. Sidebar conferences are generally not permitted at the request of counsel for evidentiary objections, especially for issues that could have been anticipated. Counsel should anticipate significant issues and schedule a hearing when the jury is not waiting—e.g., before the jurors arrive or after they leave for the day. D. Special Accommodations Counsel must notify the CRD one week prior to the final pre-trial conference if a witness or party requires an interpreter or an accommodation under the Americans with Disabilities Act (or for any other reason). The Court prefers any special accommodations to be addressed in the government’s Trial Memorandum. E. General Decorum While in Session 1. Counsel must not approach the Courtroom Deputy Clerk, the jury box, or the witness stand without court authorization and must return to the lectern when the purpose for the approach has been accomplished. 2. Counsel must rise when addressing the Court and when the Court or the jury enters or leaves the courtroom, unless directed otherwise. 3. Counsel must address all remarks to the Court. Counsel must not address the Courtroom Deputy Clerk, the court reporter, persons in the audience, or opposing counsel. Any request to re-read questions or answers shall be addressed to the Court. Counsel must ask the Court’s permission to speak with opposing counsel. 4. Counsel must not address or refer to witnesses or parties by first names alone, except for witnesses who are below age fourteen (14). 5. Counsel must not offer a stipulation unless counsel have conferred with opposing counsel and have verified that the stipulation will be acceptable. Any stipulation of fact will require the defendant’s personal concurrence and shall be Rev. 03/18/25 22 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 submitted to the Court in writing for approval. A proposed stipulation should be explained to the defendant in advance. 6. Counsel must remain at counsel table throughout trial except to examine witnesses or as otherwise needed to present evidence. Counsel must not leave counsel table to sit in the gallery or confer with any person in the back of the courtroom without the Court’s permission. 7. Counsel must not make facial expressions, nod, shake their heads, comment, or otherwise exhibit in any way any agreement, disagreement, or other opinion or belief concerning the testimony of a witness or argument by opposing counsel. Counsel shall instruct their clients and witnesses not to engage in such conduct. 8. When the trial is not in session, counsel must not speak to jurors under any circumstance, and must not speak to co-counsel, opposing counsel, witnesses, or clients if the conversation can be overheard by jurors. Counsel must instruct their clients and witnesses to avoid such conduct. 9. Where a party has more than one lawyer, only one attorney may conduct the direct or cross-examination of a particular witness or make objections as to that witness. 10. Bottled water is permitted in the courtroom but may not be placed on counsel table or the lectern. Food and other beverages are not permitted. Cell phones must be silenced or may be confiscated. F. 1. Punctuality The Court expects the parties, counsel, and witnesses to be punctual. Once the parties and their counsel are engaged in trial, the trial must be their priority. The Court will not delay progress of the trial or inconvenience jurors. 2. If a witness was on the stand at the time of a recess or adjournment, the party that called the witness shall ensure the witness is back on the stand and ready to proceed as soon as trial resumes. Rev. 03/18/25 23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3. No presenting party may be without witnesses. If a party’s remaining witnesses are not immediately available, thereby causing an unreasonable delay, the Court may deem that party to have rested. 4. The Court generally will accommodate witnesses by permitting them to be called out of sequence. Counsel should meet and confer in advance and make every effort to resolve the matter. G. Exhibits 1. No document shall be placed before a witness unless a copy has been provided to the Court and opposing counsel. 2. Once they are admitted in evidence, exhibits may be displayed to the jury using the monitors in the courtroom. The Court ordinarily does not permit exhibits to be handed to the jurors in the jury box. In the event an exhibit cannot be displayed properly via the monitors in the courtroom, counsel must secure approval by the Court before handing an exhibit to the jury. 3. Counsel must keep track of their exhibits and exhibit list, and record when each exhibit has been admitted into evidence. 4. Counsel are responsible for any exhibits they secure from the Courtroom Deputy Clerk and must return them before leaving the courtroom. 5. Any exhibit not previously marked must be accompanied by a request that it be marked for identification at the time of its first mention. Counsel must show a new exhibit to opposing counsel before the court session in which it is mentioned. 6. Counsel must inform the Courtroom Deputy Clerk of any agreements reached regarding any proposed exhibits, as well as those exhibits that may be received into evidence without a motion to admit. 7. When referring to an exhibit, counsel must refer to its exhibit number. Counsel should instruct their witnesses to do the same. Counsel should make every effort to correctly identify for the record the exhibit being referred to and should use specific descriptions when directing witnesses to identify items within the exhibit Rev. 03/18/25 24 (e.g., “turning your attention to the bottom right-hand corner of exhibit 1 . . .,” instead of “take a look at this right here”). 8. Counsel should not ask witnesses to draw charts or diagrams or ask the Court’s permission for a witness to do so. All demonstrative aids must be prepared fully in advance of the day’s trial session. 9. Counsel are required to seek the admission of any items of evidence whose admissibility has not been stipulated to while the witness authenticating the exhibit is on the stand. VII. SENTENCING Original Sentencing: Once set, the sentencing hearing shall not be continued absent a showing of good cause. No later than fourteen (14) days before the hearing, each party shall submit either a sentencing memorandum or a written notice of intent not to file one. Absent leave of court based upon a showing of good cause, the Court does not permit submission or playing of sentencing videos. The Court does not permit sentencing documents to be filed under seal except as strictly necessary and justified. When necessary, a sentencing document may be filed under seal along with a redacted version that deletes the confidential information and that justifies each deletion (e.g., “medical information”). Supervision Violation: Any material submitted for a hearing on an alleged or adjudicated violation of supervision shall be filed, when possible, seven (7) days before the hearing, and otherwise no later than two (2) court days, absent a showing of good cause set forth in a supporting declaration and court approval. IT IS SO ORDERED. Dated: March 20, 2025 ______________________________ HON. CYNTHIA VALENZUELA UNITED STATES DISTRICT JUDGE 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 03/18/25 25

=== Standing Order for Civil Cases Assigned to Judge Valenzuela - Rev. 3-13-25 ===

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA PLAINTIFF’S NAME, et al., Case No. 0:00-cv-00000-CV ( x) Plaintiff/s, v. STANDING ORDER FOR CIVIL CASES ASSIGNED TO JUDGE VALENZUELA DEFENDANT’S NAME, et al., Defendant/s. PLEASE READ THIS ORDER CAREFULLY. IT GOVERNS THE CASE AND DIFFERS IN SOME RESPECTS FROM THE LOCAL RULES. WHEN CONSULTING THE COURT’S CIVIL STANDING ORDER, PLEASE BE SURE TO USE THE MOST UPDATED VERSION LOCATED ON JUDGE VALENZUELA’S WEBPAGE. 1 Counsel for Plaintiff(s) shall serve this order immediately on all parties and/or their attorney(s), including any new parties to the action. If this action has been removed from the state court, the defendant who removed the action shall serve this order on all other parties. 1 Judge Valenzuela’s webpage can be found at https://www.cacd.uscourts.gov/honorable-cynthia-valenzuela. Rev. 3/13/25 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CONTENTS I. INTRODUCTION ............................................................................................ 4 A. Civility and Professionalism ......................................................................... 4 B. Pro Se Litigants (people without an attorney) .............................................. 5 C. Consent to Magistrate Judge for Entire Civil Case ...................................... 6 D. Service of the Complaint .............................................................................. 6 E. Removed Actions .......................................................................................... 6 F. Status of Fictitiously Named Defendants ..................................................... 6 G. Counsel Calendar Conflicts .......................................................................... 7 II. DISCOVERY .................................................................................................... 7 A. Discovery Matters Referred to United States Magistrate Judge .................. 7 B. Compliance with Federal Rule of Civil Procedure 26(a) ............................. 8 III. MOTIONS – GENERAL REQUIREMENTS ............................................... 8 A. Time for Filing and Hearing Motions ........................................................... 8 B. Pre-Filing Requirement to Meet and Confer ................................................ 9 C. Length and Format of Motion Papers ......................................................... 10 D. Citations to Case Law ................................................................................. 10 E. Citations to Other Sources .......................................................................... 10 F. Oral Argument ............................................................................................ 11 IV. SPECIFIC MOTION REQUIREMENTS.................................................... 11 A. Motions Pursuant to Federal Rule of Civil Procedure 12 .......................... 11 B. Motions to Amend ...................................................................................... 11 C. Motions for Class Certification .................................................................. 12 D. Motions for Default Judgment .................................................................... 12 E. Summary Judgment Motions ...................................................................... 12 F. Motions In Limine ...................................................................................... 12 G. Daubert Motions ......................................................................................... 12 H. Motions for Attorney Fees .......................................................................... 12 I. PLRA Exhaustion Motions ......................................................................... 14 J. ERISA Cases (Benefits Claims) ................................................................. 14 V. ADDITIONAL REQUIREMENTS .............................................................. 14 A. Electronic Filing ......................................................................................... 14 B. Documents with Declarations, Exhibits, and other Attachments ............... 15 C. Proposed Orders ......................................................................................... 15 D. Mandatory Chambers Copies ..................................................................... 15 E. Filings Under Seal ...................................................................................... 16 F. Appearance at Hearings .............................................................................. 17 G. Ex Parte Applications ................................................................................. 17 H. Continuances............................................................................................... 18 Rev. 3/13/25 2 I. Communications with Chambers ............................................................... 19 J. Order Setting Scheduling Conference ........................................................ 19 K. Settlement Conference / Alternative Dispute Resolution (“ADR”) ........... 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 3/13/25 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I. INTRODUCTION This action has been assigned to the calendar of United States District Judge Cynthia Valenzuela. Both the Court and counsel bear responsibility for the progress of this action. To “secure the just, speedy, and inexpensive determination” of the action, Fed. R. Civ. P. 1, all parties or their counsel, including pro se (people without an attorney) litigants,2 are ordered to be familiar with the Federal Rules of Civil Procedure, the Local Rules of the Central District of California (“Local Rules”), and this Court’s standing orders, online procedures, and schedules. A. Civility and Professionalism As set forth in the preamble to the Central District of California’s Civility and Professionalism Guidelines, “[u]ncivil behavior does not constitute effective advocacy; rather, it serves to increase litigation costs and fails to advance the client’s lawful interests. Perhaps just as importantly, this type of behavior causes the public to lose faith in the legal profession and its ability to benefit society. For these reasons, . . . civility and professionalism among advocates, between lawyer and client, and between bench and bar are essential to the administration of justice.” All counsel who appear in this action must immediately review and comply with the Civility and Professionalism Guidelines, which can be found on the Court’s website at http://www.cacd.uscourts.gov/attorneys/admissions/civility-and- professionalism-guidelines. At a minimum, the Court expects the following from counsel: (1) being punctual and prepared for all Court appearances; (2) being civil and respectful in all oral and written communications with the Court, court personnel, and other parties; (3) refraining from interrupting any person in the courtroom when that person is speaking; (4) refraining from making gestures, facial expressions, or audible comments indicating approval or disapproval of testimony 2 Parties appearing pro se must comply with the Federal Rules of Civil Procedure and the Local Rules. See Local Rules 1-3 and 83-2.2.3. Rev. 3/13/25 4 or argument; and (5) being considerate of the time constraints and pressures on the Court and Court staff inherent in their efforts to administer justice. B. Pro Se Litigants (people without an attorney) Only individuals may represent themselves. A corporation or other entity must be represented by counsel. If counsel seeks to withdraw, counsel must advise the entity of the dire consequences of failing to obtain substitute counsel before seeking withdrawal—i.e., a plaintiff entity’s case will be dismissed or a defendant entity will default. See Local Rule 83-2.3.4. The following links may be helpful to pro se litigants: (a) General information on how parties may represent themselves in civil cases in the Central District of California can be found at https://prose.cacd.uscourts.gov/; (b) Local Civil Rules for the Central District of California can be found at http://www.cacd.uscourts.gov/court-procedures/local-rules; (c) Federal Rules of Civil Procedure can be found at https://www.law.cornell.edu/rules/frcp. Parties proceeding pro se often face special challenges in federal court. The Public Service Law Corporation runs a free Federal Pro Se Clinic at the following federal courthouses where pro se litigants can get information and guidance: (1) Roybal Federal Building and Courthouse, 255 East Temple Street, Suite 170, Los Angeles, California 90012. For more information, pro se litigants may call (213) 385-2977, ext. 270, or visit http://prose.cacd.uscourts.gov/los-angeles. (2) George E. Brown Federal Building, 3470 Twelfth Street, Room 125, Riverside, CA 92501. For more information, pro se litigants may call (951) 682-7968 or visit http://prose.cacd.uscourts.gov/riverside. (3) Ronald Reagan Federal Building and United States Courthouse, 411 W. 4th Street, Room 1055, Santa Ana, CA 92701. For more information, pro se litigants may call (714) 541-1010, ext. 222, or visit http://prose.cacd.uscourts.gov/santa-ana. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 3/13/25 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 C. Consent to Magistrate Judge for Entire Civil Case The parties may consent to have a Magistrate Judge preside over the entire civil case, including trial, rather than just discovery. The parties are free to select from among all Magistrate Judges available for this purpose, not just the Magistrate Judge assigned to the parties’ case. If the parties agree to consent to proceed before a Magistrate Judge, the parties should consult the Central District website (https://www.cacd.uscourts.gov/judges-requirements/court-programs/voluntary- consent-magistrate-judges) for the list of available Magistrate Judges and should submit the appropriate consent form. D. Service of the Complaint Plaintiff shall promptly serve the complaint in accordance with Fed. R. Civ. P. 4 and file the proofs of service pursuant to Local Rule 5-3.1. Any defendant not timely served under Fed. R. Civ. P. 4(m), including “Doe” or fictitiously named defendants, shall be dismissed from the action. E. Removed Actions All documents filed in state court, including documents appended to the complaint, answers, and motions, must be re-filed in this Court as a supplement to the notice of removal. See 28 U.S.C. § 1447(a) and (b). Any pending motions must be re-noticed in accordance with Local Rule 7. Counsel shall file with his or her first appearance a Notice of Interested Parties in accordance with Local Rule 7.1-1. If an action removed to this Court contains a state court Judicial Council form pleading (i.e., a pleading in which a party selects claims or defenses by checking boxes), the party that filed the form pleading must file a revised pleading that complies with Fed. R. Civ. P. 7, 7.1, 8, 9, 10 and 11, within thirty (30) days of receipt of the Notice of Removal. F. Status of Fictitiously Named Defendants Plaintiff must identify and serve any fictitiously named or Doe defendant(s) before the deadline set forth in the Court’s Order Setting Scheduling Conference. Rev. 3/13/25 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Before moving to substitute a defendant for a Doe defendant, plaintiff must seek the consent of counsel for all defendants, including counsel for a represented Doe defendant. If denied consent, plaintiff must file a regularly noticed motion. In diversity cases, plaintiff’s motion must address whether the addition of the newly named party destroys diversity jurisdiction. See 28 U.S.C. § 1447(c), (e). G. Counsel Calendar Conflicts The Court expects that counsel will conduct themselves professionally and will not deliberately schedule any proceeding when counsel of record are unavailable. If any counsel discovers a calendar conflict with a scheduled appearance, counsel must inform opposing counsel and the Court’s courtroom deputy (CRD) via Chambers email at [email protected]. If the conflict is with another hearing before a judge in the Central District of California Western Division, counsel shall notify the CRD for each judge as soon as possible and not later than three (3) days before the scheduled appearance. Counsel should appear before the most senior judge first and request priority. For all other conflicts, Counsel should attempt to agree on a new date to accommodate the calendar conflict. Counsel must propose a new date by Stipulation and Proposed Order as soon as possible and not later than three (3) days before the scheduled appearance. A “Notice of Unavailability” has no legal effect and should not be filed. II. DISCOVERY A. Discovery Matters Referred to United States Magistrate Judge All discovery matters are hereby referred to the assigned Magistrate Judge, who will hear all discovery disputes. All discovery-related documents must include the words “DISCOVERY MATTER” in the caption to ensure proper routing. Counsel are directed to follow the Magistrate Judge’s procedures for scheduling matters for hearing. These procedures are stated on each Magistrate Judge’s webpage. In accordance with 28 U.S.C. § 636(b)(1)(A), the Magistrate Judge’s Rev. 3/13/25 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 decision shall be final, and this Court will not reverse any order of the Magistrate Judge unless it has been shown that the Magistrate Judge’s order is clearly erroneous or contrary to law. See Local Rule 72-2. B. Compliance with Federal Rule of Civil Procedure 26(a) The Court allows discovery to commence as soon as the first answer or motion to dismiss is filed. The parties should note that, unless otherwise ordered, discovery shall not be stayed while any motion is pending, including any motion to dismiss, motion for protective order or motion to stay. The parties are directed to conduct any necessary discovery as soon as possible, as the Court is not inclined to grant any extensions of the discovery or other case-related deadlines. Unless there is a likelihood that, upon motion by a party, the Court would order that discovery be stayed, the parties should begin to propound discovery before the Scheduling Conference. The parties must comply fully with the letter and spirit of Fed. R. Civ. P. 26(a) and produce discovery promptly. At the Scheduling Conference, the Court will impose deadlines governing the completion of discovery. III. MOTIONS – GENERAL REQUIREMENTS A. Time for Filing and Hearing Motions Motions shall be filed in accordance with Local Rules 6 and 7. The Court hears motions in civil actions on Fridays, beginning at 1:30 p.m. It is not necessary to clear a hearing date with the Courtroom Deputy Clerk before filing a motion, except for motions for summary judgment, temporary restraining orders, or motions for a preliminary injunction. The parties must adhere to the briefing schedule set forth in Local Rules 7-9 and 7-10, and the schedule in Judge Valenzuela’s Order re Motions for Summary Judgment for Fed. R. Civ. P. 56 motions, to afford the Court adequate time to prepare for the hearing. If the motion hearing date selected is not available, the Court will issue an order continuing the hearing. Professional Rev. 3/13/25 8 courtesy dictates, and the Court fully expects, the parties will accommodate each other’s schedules, including vacations and holidays, whenever possible. The parties should not calendar a matter on a Friday that is a Court holiday. If this occurs, the Court will re-calendar the matter for another Friday. B. Pre-Filing Requirement to Meet and Confer Counsel must comply with Local Rule 7-3, which requires counsel to engage in a pre-filing conference “to discuss thoroughly … the substance of the contemplated motion and any potential resolution.” Counsel must meet and confer in person or by telephone or videoconference; an exchange of written correspondence is insufficient. Counsel shall discuss the issues to a sufficient degree that if a motion is still necessary, the briefing may be directed to those substantive issues requiring resolution by the Court. Counsel shall resolve minor procedural or other non-substantive matters during the conference. The Court may strike or deny a motion if counsel fail to meet and confer in good faith. The Notice of Motion must include a statement of compliance with Local Rule 7-3. In addition, if the parties are unable to reach a resolution that eliminates the necessity for a hearing, counsel for the moving party must include a declaration, under penalty of perjury, that sets forth at a minimum the date(s) the conference took place and the position of each party with respect to each disputed issue that will be the subject of the motion. Failure to include such a declaration may result in the motion being denied. The following are exempted from Local Rule 7-3 and the pre-filing requirements to meet and confer set forth in this subsection III.B: (1) cases where at least one party is appearing pro se; (2) cases listed as exempt in Local Rule 16-12, (3) discovery motions governed by Local Rules 37-1 through 37-4, (4) applications under Fed. R. Civ. P. 65 for temporary restraining orders or preliminary injunctions, and (5) motions to retax costs under Local Rule 54-2.5. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 3/13/25 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 C. Length and Format of Motion Papers Unless otherwise stated by the Court, memoranda of points and authorities in support of or in opposition to motions shall not exceed twenty-five (25) pages. Replies shall not exceed fifteen (15) pages.3 Only rarely and for good cause shown will the Court grant an application to extend these page limitations. Pursuant to Local Rule 11-3.1.1, either a proportionally spaced or monospaced face may be used. Typeface shall comply with Local Rule 11-3.1.1. Times New Roman font must be no less than 14 point; Courier font must be no less than 12 point. Footnotes shall be in the same font and the same size as the body of the memorandum. Counsel shall adhere to Local Rule 5-4.3 with respect to the conversion of all documents to .pdf format so that when a document is electronically filed, it is in proper size and is .pdf searchable. Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document. See Local Rule 5-4.3.1. D. Citations to Case Law Bluebook style is required. Citations to case law must identify not only the case cited, but the specific page referenced. For example, if a quotation is presented, the associated page citation shall be provided. Similarly, if a case is cited in support of a proposition based on language in the opinion, the page on which such language appears shall be provided. E. Citations to Other Sources Bluebook style is required. Statutory references must identify with specificity the sections and subsections referenced. Citations to treatises, manuals, and other materials should include the volume, section, and pages being referenced. Citations 3 See Judge Valenzuela’s Order Re: Motions for Summary Judgment regarding the length and format of motions for summary judgment. Rev. 3/13/25 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 to prior filings in the same action shall include the docket entry number, section, and pages referenced. F. Oral Argument If the Court deems a matter appropriate for decision without oral argument, the Court will take the matter under submission and notify the parties before the hearing. IV. SPECIFIC MOTION REQUIREMENTS A. Motions Pursuant to Federal Rule of Civil Procedure 12 Many motions to dismiss or strike can be avoided if the parties confer in good faith as required by Local Rule 7-3, especially for perceived defects in a complaint, answer, or counterclaim that can be corrected by amendment. See Chang v. Chen, 80 F.3d 1293, 1296 (9th Cir. 1996) (where a motion to dismiss is granted, a district court should grant leave to amend unless it is clear the complaint cannot be saved by amendment). Moreover, a party has the right to amend the complaint “once as a matter of course within: (A) 21 days after serving it, or (B) if the pleading is one to which a responsive pleading is required, 21 days after service of a responsive pleading or 21 days after service of a motion under Rule 12(b), (e), or (f), whichever is earlier.” Fed. R. Civ. P. 15(a)(1). Even after a complaint has been amended or a responsive pleading has been served, leave to amend shall be “freely give[n] ... when justice so requires.” Fed. R. Civ. P. 15(a)(2). Indeed, the Ninth Circuit requires the policy favoring amendment to be applied with “extreme liberality.” Morongo Band of Mission Indians v. Rose, 893 F.2d 1074, 1079 (9th Cir. 1990). Thus, parties should carefully consider and weigh an opponent’s contentions as to the deficiencies in a pleading. In most instances, the parties should agree to any amendment that would cure the defect. B. Motions to Amend In addition to the requirements of Local Rule 15-1, all motions to amend pleadings shall include “clean” and “redlined” versions of the proposed amended Rev. 3/13/25 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 pleading, identifying all additions and deletions of material, as attachments to the moving papers. C. Motions for Class Certification Notwithstanding Local Rule 23-3, the deadline for the filing of a motion for class certification will be set pursuant to the parties’ stipulation during the Scheduling Conference or in a Scheduling Order. No request for relief from Local Rule 23-3 is necessary. D. Motions for Default Judgment Unless otherwise ordered, motions for default judgment shall be filed no later than 14 days after the later of (1) entry of default against the last remaining defendant, or (2) resolution of all claims against all defendants who have not defaulted. A motion for default judgment must include a showing of both subject matter jurisdiction and personal jurisdiction. See In re Tuli, 172 F.3d 707, 712 (9th Cir. 1999). E. Summary Judgment Motions The Parties shall refer to Judge Valenzuela’s Order Re: Motions for Summary Judgment for the appropriate procedures for motions for summary judgment. F. Motions In Limine Motions in limine shall be noticed for hearing not later than four (4) weeks before the Final Pretrial Conference date. Unless leave of Court is granted, each party is limited to five motions in limine. G. Daubert Motions Daubert motions shall be noticed for hearing not later than nine (9) weeks before the Final Pretrial Conference date. H. Motions for Attorney Fees Before filing a motion for attorney fees, counsel must meet and confer thoroughly pursuant to Local Rule 7-3 to attempt in good faith to agree on the Rev. 3/13/25 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 reasonable amount of fees and expenses to be awarded (if the Court decides to award fees). Motions for attorney fees shall be electronically filed and set for hearing according to Local Rule 6-1 and this Order. Any motion or request for attorney fees shall attach two summaries, in table form, of the hours worked by and billing rate of each attorney with title (i.e., partner, counsel, associate, etc.). The table shall include a summary of the hours worked by each attorney, organized by attorney. The table shall list all the tasks on which the attorney worked, the hours worked on each task, and the hourly rate of each attorney. If the hourly rate charged by any individual attorney changed while the action was ongoing, the party shall provide separate calculations for the total number of hours the attorney spent in connection with each task at each hourly rate. The table shall be attached to the motion and electronically filed. The mandatory chambers copies of the table shall be prepared in Excel, have all restrictions removed so the spreadsheets can be edited, and be emailed to opposing counsel and the Court’s chambers email address at [email protected]. An opposing party shall specify its objections to the fee requests and time spent in the form set forth below: Attorney Date Description Attorney A 1/1/25 T/C with consultant Time Challenged 3.0 Reduce By 3.0 Attorney B 1/10/25 Research Notice of Related Cases 2.5 2.3 Rev. 3/13/25 13 Vague Objection Reason for Objection Fails to articulate who the consultant was and what the conversation concerned. Notice of Related Cases is a form document. Excessive 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Attorney C 1/20/25 Calendared 1.3 1.3 Dates Clerical Work Attorney should not charge for basic research. Attorney cannot charge for clerical work. I. PLRA Exhaustion Motions The issue of exhaustion under the Prison Litigation Reform Act (“PLRA”) must be raised at the beginning of the litigation. Albino v. Baca, 747 F.3d 1162, 1170 (9th Cir. 2014). A party seeking to obtain a judicial determination of any material fact dispute precluding summary judgment on the exhaustion issue must file before this Court a request for a hearing within fourteen (14) days of the filing of the order denying summary judgment. The failure to file a timely request may be construed as a waiver of the exhaustion issue. J. ERISA Cases (Benefits Claims) Claims to recover benefits under ERISA will be resolved by a court trial (usually confined to briefing and possible oral argument) on the administrative record. Absent an agreed upon statement of facts, the Court will not hear motions for summary judgment. However, the Court will hear motions to determine the standard of review and the scope of the administrative record. See Kearney v. Standard Ins. Co., 175 F.3d 1084 (9th Cir. 1999). V. ADDITIONAL REQUIREMENTS A. Electronic Filing Pursuant to Fed. R. Civ. P. 5(d)(3), L.R. 5-4, and General Order 10-07, counsel shall electronically file (“e-file”) all filings. Items that do not require the Court’s signature shall be e-filed in .pdf format. Proposed orders shall be e-filed in .pdf format as an attachment to the main documents. Rev. 3/13/25 14 Pro se litigants may submit documents for filing through the Court’s Electronic Document Submission System (EDSS) instead of mailing or bringing documents to the Clerk’s Office. Only internet access and an email address are required. Documents are submitted in .pdf format through an online portal on the Court’s website. To access EDSS and for additional information, visit the Court’s website at https://apps.cacd.uscourts.gov/edss. B. Documents with Declarations, Exhibits, and other Attachments If a filed or lodged document has declarations, exhibits, or other attachments, each attachment must be filed as a separately docketed attachment to the main docket entry with a description of the attachment (e.g., Dkt. 29-1 Smith Declaration, 29-2 Ex. 1 - License Agreement, 29-3 Request for Judicial Notice). The Court may strike or decline to consider motions, stipulations, or other documents with attachments that are not filed in accordance with this Order. C. Proposed Orders Each party filing or opposing a motion or seeking the determination of any matter shall serve and electronically lodge a proposed order setting forth the relief or action sought and a brief statement of the rationale for the decision with appropriate citations. In addition, a copy of the proposed order in Word format shall be emailed directly to the Court’s chambers email address at [email protected] on the day the document is e-filed. The parties must use the template for proposed orders available on Judge Valenzuela’s Procedures and Schedules page on the Court’s website. The proposed order must include the entire relief the parties seek. Failure to email a proposed order in Word format using the Court’s template may result in the Court striking the motion, application, or stipulation without consideration of the request on its merits. D. Mandatory Chambers Copies The Court does not require chambers copies of any motion papers or 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 3/13/25 15 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 exhibits and discourages the parties from sending chambers copies, with the following exceptions: the Court requires (1) one mandatory chambers copy of motions for summary judgment and motions for class certification, as well as any associated briefing, including oppositions and replies, and (2) one mandatory chambers copy of overlength briefs when the Court has granted a party’s request for leave to file an overlength brief. Chambers copies shall be delivered to Judge Valenzuela’s “Mandatory Chambers Copies” box, located on the fourth floor of the United States District Courthouse, 350 W 1st Street, Los Angeles, CA 90012. A mandatory chambers copy must comply with Local Rule 11-3 (i.e., font size, page numbering, exhibit tabbing, etc.) but need not be blue-backed. The mandatory chambers copy must be prominently labeled MANDATORY CHAMBERS COPY on the face page. This order, however, is not intended to affect the parties’ ability to file and lodge documents and materials that are exempt from electronic filing under Local Rule 5-4.2. The Court refers the parties to the Scheduling and Trial Order for details regarding mandatory chambers copies for pretrial documents and trial exhibits. E. Filings Under Seal Local Rule 79-5 governs applications to file documents under seal. Local Rule 79-5.2.2 explains how to apply to file under seal and how to proceed if leave is granted. Parties must comply with all provisions of Local Rule 79-5. There is a strong presumption of access in civil actions. Foltz v. State Farm Mut. Auto. Ins. Co., 331 F.3d 1122, 1135 (9th Cir. 2003). For each document or other type of information a party seeks to file under seal, the party must identify and discuss the factual and/or legal justification that establishes “good cause” or “compelling reasons” for the information to be protected. Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1179–80 (9th Cir. 2006). Documents that are not confidential or privileged in their entirety should not Rev. 3/13/25 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 be filed under seal if the confidential portions can be redacted and filed separately with a reasonable amount of effort. The parties should file a complete version of the documents under seal and a redacted version for public viewing, omitting only the portions that the Court has authorized to be filed under seal. Sealing must be justified for each individual item: blanket claims of confidentiality will result in the application to seal being denied. Counsel is strongly encouraged to consider carefully whether sealing or redaction is absolutely required for a given piece of evidence or argument. An application to seal that includes meritless requests to seal or redact documents will be denied. The parties also must meet and confer before filing an application to seal. F. Appearance at Hearings The Court requires lead counsel to appear for scheduling conferences, settlement conferences, and the Final Pretrial Conference. The Court requires in- person attendance for all hearings and trials, unless otherwise instructed by the Court. The Court may permit appearances by telephone or video conference for status conferences upon a showing that a personal appearance will cause undue hardship. If you wish to appear by telephone or video conference, you must: 1. email the Courtroom Deputy Clerk and copy opposing counsel at least three (3) court days in advance of the scheduled appearance and provide a detailed statement of undue hardship; 2. use a landline to call into the bridge line provided by the Courtroom Deputy Clerk or use a hardline internet connection to connect to the Zoom link for the Court; and 3. be available and ready to call in for at least fifteen (15) minutes before the time of the scheduled hearing. G. Ex Parte Applications The Court considers ex parte applications on the papers and does not usually set these matters for hearing. The parties will be notified if the Court deems a Rev. 3/13/25 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 hearing necessary. Ex parte applications are solely for extraordinary relief and should be used with discretion. Sanctions may be imposed for misuse of ex parte applications. See Mission Power Eng’g Co. v. Cont’l Cas. Co., 883 F. Supp. 488 (C.D. Cal. 1995). Ex parte applications that fail to conform to Local Rules 7-19 and 7-19.1, including a statement of opposing counsel’s position, will not be considered except upon a specific showing of good cause. The applicant shall serve the opposing party electronically, if possible. All parties registered for electronic service are sent a notification of ECF filing each time a document is e-filed with a link to the document for one free view. Accordingly, parties registered for electronic service are considered served once an ex parte application has been e-filed. Parties enrolled for service by facsimile or mail must be served the ex parte application by facsimile or personal service. Following service of the ex parte application by electronic, facsimile, or personal service, the applicant shall notify the opposing party that any opposition must be filed no later than twenty-four (24) hours following service. Counsel will be notified by the clerk of the Court’s ruling. If counsel does not intend to oppose an ex parte application, counsel must inform the Courtroom Deputy Clerk at (213) 894-0239. All ex parte applications must include a proposed order. See Local Rules 7- 19 and 7-19.1. H. Continuances The Court has a strong interest in keeping scheduled dates certain. Changes in dates are disfavored. Trial dates set by the Court are firm and will not readily be changed. Therefore, a request to continue or extend the date of any matter before this Court must be supported by a sufficient factual basis that demonstrates good cause why the change in the date is essential. Without such compelling factual support and a showing of due diligence, requests continuing dates will not be Rev. 3/13/25 18 approved. Counsel requesting a continuance or extension of time must file electronically a request or, if the parties are in agreement, a stipulation which includes a detailed declaration of the grounds for the requested continuance or extension of time. A proposed order in Word format must be emailed directly to the Court’s chambers email address at [email protected] on the day the document is e-filed. The proposed order must include the entire relief the parties seek. Failure to comply with the Local Rules and this Order will result in rejection of the request without further notice to the parties. Requests extending scheduling dates do not become effective unless and until this Court so orders. Counsel shall avoid submitting requests for continuance or extension of time less than five (5) business days prior to the expiration of the scheduled date. A request to continue or extend dates or deadlines that have already expired constitutes a presumptive lack of due diligence. I. Communications with Chambers Counsel must not attempt to contact the Court or chambers staff by email, telephone, or ex parte means. For appropriate matters only, counsel may contact the Courtroom Deputy Clerk via chambers email address at [email protected], or by telephone at (213) 894-0239. Counsel must not contact the Courtroom Deputy Clerk regarding the status of any matter before the Court. Counsel must include on all papers his or her email address and telephone number to facilitate communication with the Courtroom Deputy Clerk. J. Order Setting Scheduling Conference Pursuant to Fed. R. Civ. P. 16(b), the Court will issue an order setting a scheduling conference as required by Fed. R. Civ. P. 26 and the Local Rules of this Court. Strict compliance with Fed. R. Civ. P. 16 and 26 is required. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 3/13/25 19 K. Settlement Conference / Alternative Dispute Resolution (“ADR”) As stated in Local Rule 16-15, the parties in every action must participate in a Settlement Conference or Alternative Dispute Resolution (“ADR”) procedure. The Court will not hold a final pretrial conference or convene a trial unless and until all parties, including the principals of all corporate parties, have completed ADR. This Court participates in the Court-Directed ADR Program whereby the Court refers the parties to the Magistrate Judge, the Court Mediation Panel, or private mediation. See General Order 11-10, § 5.1. If a Notice to Parties of Court- Directed ADR Program (ADR-08) has been filed in this action, counsel must furnish and discuss it with their clients in preparation for the Fed. R. Civ. P. 26(f) conference. Counsel should state their preferred ADR procedure in their Joint Rule 26(f) Report. The Court will refer the action to a procedure at the initial scheduling conference or in a Scheduling and Trial Order. More information about the Court’s ADR Program, the Mediation Panel, and mediator profiles is available on the Court’s website at https://www.cacd.uscourts.gov/attorneys/adr. IT IS SO ORDERED. Dated: ______________________________ HON. CYNTHIA VALENZUELA UNITED STATES DISTRICT JUDGE 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 3/13/25 20

=== Order Setting Scheduling Conference - Rev. 3-13-25 ===

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA PLAINTIFF’S NAME, et al., Case No. 0:00-cv-00000-CV ( x) Plaintiff/s, v. ORDER SETTING SCHEDULING CONFERENCE DEFENDANT’S NAME, et al., Defendant/s. Date: Time: 1:30 p.m. Courtroom: 5D PLEASE READ THIS ORDER CAREFULLY. IT CONTROLS THIS ACTION AND DIFFERS IN SOME RESPECTS FROM THE LOCAL RULES. WHEN CONSULTING THIS ORDER, PLEASE BE SURE TO USE THE MOST UPDATED VERSION LOCATED ON JUDGE VALENZUELA’S WEBPAGE. 1 1 Judge Valenzuela’s webpage can be found at https://www.cacd.uscourts.gov/honorable-cynthia-valenzuela. Rev. 3/13/25 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I. Introduction This case has been assigned to United States District Judge Cynthia Valenzuela. This matter is set for a Scheduling Conference on the above date in Courtroom 5D of the First Street Courthouse, 350 West 1st Street, Los Angeles, CA, 90012. If Plaintiff has not already served the operative complaint on all Defendants, Plaintiff shall do so promptly and shall file proofs of service of the summons and complaint within three (3) days thereafter. See Fed. R. Civ. P. 4; Local Rule 4. Defendants also shall timely serve and file their responsive pleadings and comply with the requirements of Local Rule 5-3.2. At the Scheduling Conference, the Court will set a date by which motions to amend the pleadings or add parties must be heard. The Scheduling Conference will be held pursuant to Fed. R. Civ. P. 16(b). The parties are reminded of their obligations under Fed. R. Civ. P. 26(a)(1) to make initial disclosures without awaiting a discovery request, and under Fed. R. Civ. P. 26(f) to confer regarding a discovery plan at least twenty-one (21) days before the Scheduling Conference. The Court allows discovery to commence as soon as the first answer or motion to dismiss is filed. The parties should note that, unless otherwise ordered, discovery shall not be stayed while any motion is pending, including any motion to dismiss, motion for protective order or motion to stay. The parties are directed to conduct any necessary discovery as soon as possible, as the Court is not inclined to grant any extensions of the discovery or other case- related deadlines. Counsel and parties appearing pro se (without an attorney) are expected to comply with the Federal Rules of Civil Procedure and all Local Rules concerning discovery. Whenever possible, the Court expects counsel to resolve discovery disputes among themselves in a courteous, reasonable, and professional manner. The Court expects that counsel will adhere strictly to the Central District of California’s Civility and Professionalism Guidelines. See Rev. 3/13/25 2 https://www.cacd.uscourts.gov/attorneys/admissions/civility-and-professionalism- guidelines. II. Joint Rule 26(f) Report The Joint Rule 26(f) Report must be filed at least fourteen (14) days before the Scheduling Conference. The Court does not require and discourages the submission of courtesy chambers copies of Joint Reports that have been electronically filed. The Joint Rule 26(f) Report shall be drafted by Plaintiff’s counsel or, if Plaintiff is appearing pro se, Defendants’ counsel (unless the parties agree otherwise) but shall be submitted and signed jointly. “Jointly” means a single report regardless of the number of separately represented parties involved in the case. The Joint Rule 26(f) Report shall specify the date of the Scheduling Conference on the caption page and shall report on all matters described below as specified by Fed. R. Civ. P. 26(f) and Local Rule 26: a. Statement of the Case: A short synopsis (not to exceed two pages) of the main claims, counterclaims, and affirmative defenses. b. Subject Matter Jurisdiction: A statement of the specific basis of federal jurisdiction, including supplemental jurisdiction. If there is a federal question, cite the federal law under which the claim arises. c. Legal Issues: A brief description of the key legal issues, including any unusual substantive, procedural, or evidentiary issues. d. Parties and Evidence: A list of parties, percipient witnesses, and key documents or other evidence concerning the main issues in the case. For conflict purposes, corporate parties must identify all subsidiaries, e. f. parents, and affiliates. Damages: The realistic range of provable damages. Insurance: Whether insurance coverage exists, the extent of coverage, and whether there has been or will be a reservation of rights. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 3/13/25 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 g. Motions: A statement of the likelihood of motions seeking to add other parties or claims, file amended pleadings, transfer venue, or challenge the Court’s jurisdiction. h. Dispositive Motions: A description of the issues or claims any party believes may be determined by motion to dismiss or motion for summary judgment. i. Manual for Complex Litigation: Whether all or part of the procedures of the Manual for Complex Litigation should be utilized. j. Status of Discovery: A discussion of the present state of discovery, including a summary of pending and completed discovery, and any current or anticipated disputes. k. Discovery Plan: A detailed discovery plan, as contemplated by Fed. R. Civ. P. 26(f). State what, if any, changes in the disclosures under Fed. R. Civ. P. 26(a) should be made, the subjects on which discovery may be needed and whether discovery should be conducted in phases or otherwise be limited, whether applicable limitations should be changed or other limitations imposed, and whether the Court should enter other orders. A statement that discovery will be conducted as to all claims and defenses or other vague description is not acceptable. l. Discovery Cut-off: A proposed discovery cut-off date governing the completion of all fact discovery, including resolution of all discovery motions. m. Expert Discovery: Proposed dates for initial and rebuttal expert witness disclosures and expert discovery cut-off under Fed. R. Civ. P. 26(a)(2). n. Settlement Conference / Alternative Dispute Resolution (“ADR”): A statement of what settlement negotiations have occurred, excluding any statement of the terms discussed. If a Notice to Parties of Court-Directed ADR Program (Form ADR-08) was filed in this case, the Court will Rev. 3/13/25 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 refer it to the Magistrate Judge, the Court Mediation Panel, or to private mediation at the parties’ expense. The parties must state their preference in the Joint Rule 26(f) Report. The Court will exercise its discretion to select an ADR option for the parties if they fail to state a preference. No case will proceed to trial unless all parties, including an officer with full settlement authority for corporate parties, have appeared personally at an ADR proceeding. o. Trial Estimate: A realistic estimate, in days, of the Court time required for trial and whether trial will be by jury or by the Court. Each side should specify by number, not by name, the number of witnesses it contemplates calling. If the time estimate for trial given in the Joint Rule 26(f) Report exceeds four court days, counsel must address in detail in the Report the basis for the estimate. p. q. Trial Counsel: The names of the attorneys who will try the case. Independent Expert or Master: Whether the Court should consider appointing a master pursuant to Fed. R. Civ. P. 53 or an independent scientific expert at the parties’ expense. The appointment of a master may be appropriate in cases where the parties anticipate substantial discovery disputes, numerous claims to be construed in connection with a summary judgment motion, a lengthy Daubert hearing, or a resolution of a difficult computation of damages. r. Schedule Worksheet: The parties must make every effort to agree on all pretrial and trial dates and must complete the appropriate Schedule of Pretrial and Trial Dates Worksheet (“Worksheet”) and include it with their Joint Rule 26(f) Report. The entries in the “Weeks Before FPTC” column reflect what the Court believes is appropriate for most cases and will allow the Court to rule on potentially dispositive motions sufficiently in advance of the Final Pretrial Conference. However, the Rev. 3/13/25 5 parties may propose other dates by which the key requirements must be completed. Each date should be stated as month, day, and year, e.g., 1/15/2020. The Final Pretrial Conference and other hearings shall be held on Fridays at 1:30 p.m. Other deadlines that do not involve the Court can be any day of the week. The parties must avoid holidays. The Court may order different dates from those the parties propose. The discovery cut-off date is the last day by which all depositions must be completed, responses to previously served written discovery must be provided, and motions concerning discovery disputes must be heard. The cut-off date for motions is the last date on which motions must be heard, not filed. If the parties would like the Court to set dates in addition to those listed on the Worksheet, they may so request by separate Stipulation and Proposed Order. Separate Worksheets are provided for class actions, patent cases, cases under the Freedom of Information Act (“FOIA”), and cases for benefits under the Employee Retirement Income Security Act of 1974 (“ERISA”). s. Other Issues: A statement of any other issues affecting the status or management of the case, including unusually complicated technical or technological issues, disputes over protective orders, extraordinarily voluminous document production, non-English speaking witnesses, reasonable ADA accommodations, discovery in foreign jurisdictions, the applicability of foreign law, the advanced age or health of parties or key witnesses, and any proposals concerning severance, bifurcation, or other ordering of proof. The Joint Rule 26(f) Report should set forth the above-described information under section headings corresponding to those in this Order. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 3/13/25 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 III. Scheduling Conference The Court may vacate the Scheduling Conference and issue the Scheduling Order based solely on the parties’ Joint Rule 26(f) Report pursuant to Fed. R. Civ. P. 16(b). If the Court elects to conduct a scheduling conference, lead trial counsel must attend unless excused by the Court for good cause before the conference. The failure to submit a joint report in advance of the Scheduling Conference or to attend the Scheduling Conference may result in the dismissal of the action, the striking of the Answer and entering a default, and/or the imposition of sanctions. A request to continue the Scheduling Conference will be granted only for good cause. IV. Notice to be Provided by Counsel Plaintiff’s counsel or, if Plaintiff is appearing pro se, Defendant’s counsel, shall provide this Order to any parties who first appear after the date of this Order and to parties who are known to exist but have not yet entered appearances. V. Disclosures to Clients Counsel are ordered to deliver to their clients a copy of this Order and the Court’s forthcoming Scheduling and Trial Order, which will contain the pretrial and trial schedule for this action. VI. Court’s Website This and all other generally applicable Orders of this Court are available on Judge Valenzuela’s webpage: https://www.cacd.uscourts.gov/honorable-cynthia- valenzuela. The Local Rules are also available on the Court’s website: https://www.cacd.uscourts.gov/court-procedures/local-rules. IT IS SO ORDERED. Dated: March 18, 2025 ______________________________ HON. CYNTHIA VALENZUELA UNITED STATES DISTRICT JUDGE Rev. 3/13/25 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 3/13/25 8 STANDARD SCHEDULE OF PRETRIAL AND TRIAL DATES WORKSHEET Please complete this worksheet jointly and file it with your Joint Rule 26(f) Report. The parties must make every effort to agree on dates or the Court will set them. Case No. Case Name: Trial and Final Pretrial Conference Dates Pl(s)’ Date mm/dd/yyyy Def(s)’ Date mm/dd/yyyy Check one: ☐ Jury Trial or ☐ Bench Trial [Tuesday at 9:00 a.m. within 13–16 months of Scheduling Conference] Estimated Duration: _______ Days Final Pretrial Conference (“FPTC”) [L.R. 16], Hearing on Motions in Limine [Friday at 1:30 p.m. at least 17 days before trial] Event Note: Hearings shall be on Fridays at 1:30 p.m. Other dates can be any day of the week. Time Computation Pl(s)’ Date mm/dd/yyyy Def(s)’ Date mm/dd/yyyy Last Date to Hear Motion to Amend Pleadings or Add Parties [Friday] Fact Discovery Cut-Off [Friday] (no later than deadline for filing dispositive motion) Expert Disclosure (Initial) Expert Disclosure (Rebuttal) Expert Discovery Cut-Off Last Date to Hear Motions [Friday]  Joint Brief due at least 28 days before hearing  Supplemental Memoranda (if any) due 14 days before hearing Deadline to Complete Settlement Conference [L.R. 16-15] Select one: ☐ 1. Magistrate Judge (with Court approval) ☐ 2. Court Mediation Panel ☐ 3. Private Mediation Trial Filings (first round) [Friday]  Motions in Limine  Memoranda of Contentions of Fact and Law [L.R. 16-4]  Witness Lists [L.R. 16-5]  Joint Exhibit List [L.R. 16-6.1]  Joint Status Report Regarding Settlement  Proposed Findings of Fact and Conclusions of Law [L.R. 52] (bench trial only)  Declarations Containing Direct Testimony, if ordered (bench trial only) Trial Filings (second round) [Friday]  Oppositions to Motions in Limine  Joint Proposed Final Pretrial Conference Order [L.R. 16-7]  Joint Agreed Upon Proposed Jury Instructions (jury trial only)  Disputed Proposed Jury Instructions (jury trial only)  Joint Proposed Verdict Forms (jury trial only)  Joint Proposed Statement of the Case (jury trial only)  Proposed Voir Dire Questions, if any (jury trial only)  Evidentiary Objections to Declarations of Direct Testimony (bench trial only) 91 days after scheduling conference 21 weeks before FPTC 20 weeks before FPTC 18 weeks before FPTC 16 weeks before FPTC 9 weeks before FPTC 5 weeks before FPTC 4 weeks before FPTC 2 weeks before FPTC Rev. 3/13/25 CLASS ACTION SCHEDULE OF PRETRIAL AND TRIAL DATES WORKSHEET Please complete this worksheet jointly and file it with your Joint Rule 26(f) Report. The parties must make every effort to agree on dates or the Court will set them. Case No. Case Name: Trial and Final Pretrial Conference Dates Check one: ☐ Jury Trial or ☐ Bench Trial Estimated Duration: _______ Days Final Pretrial Conference (“FPTC”) [L.R. 16], Hearing on Motions in Limine Pl(s)’ Date mm/dd/yyyy Def(s)’ Date mm/dd/yyyy To be set by the Court To be set by the Court To be set by the Court To be set by the Court Event Note: Hearings shall be on Fridays at 1:30 p.m. Other dates can be any day of the week. Time Computation Pl(s)’ Date mm/dd/yyyy Def(s)’ Date mm/dd/yyyy Last Date to Hear Motion to Amend Pleadings or Add Parties [Friday] Last Date to Hear Motion for Class Certification [Friday] Fact Discovery Cut-Off [Friday] (no later than deadline for filing dispositive motion) Expert Disclosure (Initial) Expert Disclosure (Rebuttal) Expert Discovery Cut-Off 91 days after scheduling conference 39 weeks after scheduling conference 68 weeks after scheduling conference 69 weeks after scheduling conference 71 weeks after scheduling conference 73 weeks after scheduling conference Last Date to Hear Motions [Friday]  Joint Brief due at least 28 days before hearing  Supplemental Memoranda (if any) due 14 days before hearing To be set by the Court To be set by the Court To be set by the Court Deadline to Complete Settlement Conference [L.R. 16-15] Select one: ☐ 1. Magistrate Judge (with Court approval) ☐ 2. Court Mediation Panel ☐ 3. Private Mediation Trial Filings (first round) [Friday]  Motions in Limine  Memoranda of Contentions of Fact and Law [L.R. 16-4]  Witness Lists [L.R. 16-5]  Joint Exhibit List [L.R. 16-6.1]  Joint Status Report Regarding Settlement  Proposed Findings of Fact and Conclusions of Law [L.R. 52] (bench trial only)  Declarations Containing Direct Testimony, if ordered (bench trial only) Trial Filings (second round) [Friday]  Oppositions to Motions in Limine  Joint Proposed Final Pretrial Conference Order [L.R. 16-7]  Joint Agreed Upon Proposed Jury Instructions (jury trial only)  Disputed Proposed Jury Instructions (jury trial only)  Joint Proposed Verdict Forms (jury trial only)  Joint Proposed Statement of the Case (jury trial only)  Proposed Voir Dire Questions, if any (jury trial only)  Evidentiary Objections to Declarations of Direct Testimony (bench trial only) Rev. 3/13/25 84 weeks after scheduling conference To be set by the Court To be set by the Court To be set by the Court To be set by the Court To be set by the Court To be set by the Court PATENT ACTION SCHEDULE OF PRETRIAL AND TRIAL DATES WORKSHEET Please complete this worksheet jointly and file it with your Joint Rule 26(f) Report. The parties must make every effort to agree on dates or the Court will set them. Case No. Case Name: Trial and Final Pretrial Conference Dates Pl(s)’ Date mm/dd/yyyy Def(s)’ Date mm/dd/yyyy Check one: ☐ Jury Trial or ☐ Bench Trial [Monday at 8:15 a.m. within 15–21 months of Scheduling] Estimated Duration: _______ Days Final Pretrial Conference (“FPTC”) [L.R. 16], Hearing on Motions in Limine [Friday at 1:30 p.m. at least 17 days before trial] Event Note: Hearings shall be on Fridays at 1:30 p.m. Other dates can be any day of the week. Time Computation Pl(s)’ Date mm/dd/yyyy Def(s)’ Date mm/dd/yyyy Last Date to Hear Motion to Amend Pleadings or Add Parties [Friday] 91 days after scheduling conference Deadline to Serve Infringement Contentions & Related Disclosures [Patent Rules 2(a), (b)] 14 days after scheduling conference Deadline to Serve Invalidity Contentions & Related Disclosures [Patent Rules 2(c), (d)] Deadline to Exchange Proposed Terms for Construction [Patent Rule 3(a)] Deadline to Exchange Preliminary Claim Constructions and Extrinsic Evidence [Patent Rule 3(b)] Deadline to Submit Joint Claim Construction and Prehearing Statement, and Expert Reports [Patent Rule 3(c)] Claim Construction Discovery Cut-Off [Patent Rule 3(d)] Deadline to File Opening Claim Construction Briefs [Patent Rule 3(e)(i)] Deadline to File Responsive Claim Construction Briefs [Patent Rule 3(e)(ii)] Deadline to File Reply Claim Construction Briefs [Patent Rule 3(e)(iii)] Deadline to Serve Damages Contentions [Patent Rule 2(h)] Deadline to Serve Responsive Damages Contentions [Patent Rule 2(i)] Rev. 3/13/25 59 days after scheduling conference 14 days after deadline to serve Invalidity Contentions; 42 days after deadline to serve Infringement Contentions (if validity is not at issue); or 14 days after service of Answer in declaratory judgment actions not based on validity). 21 days after deadline to exchange proposed claim construction terms 46 days after deadline to exchange proposed claim construction terms 76 days after deadline to exchange proposed claim construction terms 91 days after deadline to exchange proposed claim construction terms 105 days after deadline to exchange proposed claim construction terms 112 days after deadline to exchange proposed claim construction terms 109 days after scheduling conference 139 days after scheduling conference Deadline to Complete Damages Contentions Meeting (Patent Rule 2(j Fact Discovery Cut-Off [Friday] (no later than deadline for filing dispositive motion) Expert Disclosure (Initial) Expert Disclosure (Rebuttal) Expert Discovery Cut-Off Last Date to Hear Motions [Friday]  Joint Brief due at least 28 days before hearing  Supplemental Memoranda (if any) due 14 days before hearing Deadline to Complete Settlement Conference [L.R. 16-15] Select one: ☐ 1. Magistrate Judge (with Court approval) ☐ 2. Court Mediation Panel ☐ 3. Private Mediation Trial Filings (first round) [Friday]  Motions in Limine  Memoranda of Contentions of Fact and Law [L.R. 16-4]  Witness Lists [L.R. 16-5]  Joint Exhibit List [L.R. 16-6.1]  Joint Status Report Regarding Settlement  Proposed Findings of Fact and Conclusions of Law [L.R. 52] (bench trial only)  Declarations Containing Direct Testimony, if ordered (bench trial only) Trial Filings (second round) [Friday]  Oppositions to Motions in Limine  Joint Proposed Final Pretrial Conference Order [L.R. 16-7]  Joint Agreed Upon Proposed Jury Instructions (jury trial only)  Disputed Proposed Jury Instructions (jury trial only)  Joint Proposed Verdict Forms (jury trial only)  Joint Proposed Statement of the Case (jury trial only)  Proposed Voir Dire Questions, if any (jury trial only)  Evidentiary Objections to Declarations of Direct Testimony (bench trial only) 199 days after scheduling conference 21 weeks before FPTC 20 weeks before FPTC 18 weeks before FPTC 16 weeks before FPTC 9 weeks before FPTC 5 weeks before FPTC 4 weeks before FPTC 2 weeks before FPTC Rev. 3/13/25 FOIA ACTION SCHEDULE OF PRETRIAL DATES WORKSHEET Please complete this worksheet jointly and file it with your Joint Rule 26(f) Report. The parties must make every effort to agree on dates or the Court will set them. Case No. Case Name: Event Note: Hearings shall be on Fridays at 1:30 p.m. Other dates can be any day of the week. Time Computation Pl(s)’ Date mm/dd/yyyy Def(s)’ Date mm/dd/yyyy Last Date to Hear Motion to Amend Pleadings or Add Parties [Friday] 91 days after scheduling conference Last Date to Hear Motions [Friday]  Joint Brief due at least 28 days before hearing  Supplemental Memoranda (if any) due 14 days before hearing 10–15 months after scheduling conference Rev. 3/13/25 ERISA ACTION SCHEDULE OF PRETRIAL AND TRIAL DATES WORKSHEET Please complete this worksheet jointly and file it with your Joint Rule 26(f) Report. The parties must make every effort to agree on dates or the Court will set them. Case No. Case Name: Trial and Final Pretrial Conference Dates Pl(s)’ Date mm/dd/yyyy Def(s)’ Date mm/dd/yyyy Bench Trial [Friday at 1:30 p.m. within 10–12 months of Scheduling Conference] Estimated Duration: _______ Days Event Note: Hearings shall be on Fridays at 1:30 p.m. Other dates can be any day of the week. Time Computation Pl(s)’ Date mm/dd/yyyy Def(s)’ Date mm/dd/yyyy Last Date to Hear Motion to Amend Pleadings or Add Parties [Friday] Lodge Administrative Record & Plan Documents Fact Discovery Cut-Off (if necessary) [Friday] (no later than deadline for filing dispositive motion) 91 days after scheduling conference 63 days after scheduling Conference 24 weeks before trial Last Date to Hear Motions [Friday]  Joint Brief due at least 28 days before hearing  Supplemental Memoranda (if any) due 14 days before hearing 16 weeks before trial Deadline to Complete Settlement Conference [L.R. 16-15] Select one: ☐ 1. Magistrate Judge (with Court approval) ☐ 2. Court Mediation Panel ☐ 3. Private Mediation 9 weeks before trial File & Exchange Opening Trial Briefs 8 weeks before trial File & Exchange Responsive Trial Briefs (not to exceed 15 pages) 4 weeks before trial Rev. 3/13/25

=== Civil Scheduling Worksheets Revised 3-31-25 ===

STANDARD SCHEDULE OF PRETRIAL AND TRIAL DATES WORKSHEET Please complete this worksheet jointly and file it with your Joint Rule 26(f) Report. The parties must make every effort to agree on dates or the Court will set them. Case No. Case Name: Trial and Final Pretrial Conference Dates Pl(s)’ Date mm/dd/yyyy Def(s)’ Date mm/dd/yyyy Check one: ☐ Jury Trial or ☐ Bench Trial [Tuesday at 9:00 a.m. within 13–16 months of Scheduling Conference] Estimated Duration: _______ Days Final Pretrial Conference (“FPTC”) [L.R. 16], Hearing on Motions in Limine [Friday at 1:30 p.m. at least 17 days before trial] Event Note: Hearings shall be on Fridays at 1:30 p.m. Other dates can be any day of the week. Time Computation Pl(s)’ Date mm/dd/yyyy Def(s)’ Date mm/dd/yyyy Last Date to Hear Motion to Amend Pleadings or Add Parties [Friday] Fact Discovery Cut-Off [Friday] (no later than deadline for filing dispositive motion) Expert Disclosure (Initial) Expert Disclosure (Rebuttal) Expert Discovery Cut-Off Last Date to Hear Motions [Friday]  Joint Brief due at least 28 days before hearing  Supplemental Memoranda (if any) due 14 days before hearing Deadline to Complete Settlement Conference [L.R. 16-15] Select one: ☐ 1. Magistrate Judge (with Court approval) ☐ 2. Court Mediation Panel ☐ 3. Private Mediation Trial Filings (first round) [Friday]  Motions in Limine  Memoranda of Contentions of Fact and Law [L.R. 16-4]  Witness Lists [L.R. 16-5]  Joint Exhibit List [L.R. 16-6.1]  Joint Status Report Regarding Settlement  Proposed Findings of Fact and Conclusions of Law [L.R. 52] (bench trial only)  Declarations Containing Direct Testimony, if ordered (bench trial only) Trial Filings (second round) [Friday]  Oppositions to Motions in Limine  Joint Proposed Final Pretrial Conference Order [L.R. 16-7]  Joint Agreed Upon Proposed Jury Instructions (jury trial only)  Disputed Proposed Jury Instructions (jury trial only)  Joint Proposed Verdict Forms (jury trial only)  Joint Proposed Statement of the Case (jury trial only)  Proposed Voir Dire Questions, if any (jury trial only)  Evidentiary Objections to Declarations of Direct Testimony (bench trial only) 91 days after scheduling conference 21 weeks before FPTC 20 weeks before FPTC 18 weeks before FPTC 16 weeks before FPTC 9 weeks before FPTC 5 weeks before FPTC 4 weeks before FPTC 2 weeks before FPTC Rev. 3/31/25 CLASS ACTION SCHEDULE OF PRETRIAL AND TRIAL DATES WORKSHEET Please complete this worksheet jointly and file it with your Joint Rule 26(f) Report. The parties must make every effort to agree on dates or the Court will set them. Case No. Case Name: Trial and Final Pretrial Conference Dates Check one: ☐ Jury Trial or ☐ Bench Trial Estimated Duration: _______ Days Final Pretrial Conference (“FPTC”) [L.R. 16], Hearing on Motions in Limine Pl(s)’ Date mm/dd/yyyy Def(s)’ Date mm/dd/yyyy To be set by the Court To be set by the Court To be set by the Court To be set by the Court Event Note: Hearings shall be on Fridays at 1:30 p.m. Other dates can be any day of the week. Time Computation Pl(s)’ Date mm/dd/yyyy Def(s)’ Date mm/dd/yyyy Last Date to Hear Motion to Amend Pleadings or Add Parties [Friday] Last Date to Hear Motion for Class Certification [Friday] Fact Discovery Cut-Off [Friday] (no later than deadline for filing dispositive motion) Expert Disclosure (Initial) Expert Disclosure (Rebuttal) Expert Discovery Cut-Off 91 days after scheduling conference 39 weeks after scheduling conference 68 weeks after scheduling conference 69 weeks after scheduling conference 71 weeks after scheduling conference 73 weeks after scheduling conference Last Date to Hear Motions [Friday]  Joint Brief due at least 28 days before hearing  Supplemental Memoranda (if any) due 14 days before hearing To be set by the Court To be set by the Court To be set by the Court Deadline to Complete Settlement Conference [L.R. 16-15] Select one: ☐ 1. Magistrate Judge (with Court approval) ☐ 2. Court Mediation Panel ☐ 3. Private Mediation Trial Filings (first round) [Friday]  Motions in Limine  Memoranda of Contentions of Fact and Law [L.R. 16-4]  Witness Lists [L.R. 16-5]  Joint Exhibit List [L.R. 16-6.1]  Joint Status Report Regarding Settlement  Proposed Findings of Fact and Conclusions of Law [L.R. 52] (bench trial only)  Declarations Containing Direct Testimony, if ordered (bench trial only) Trial Filings (second round) [Friday]  Oppositions to Motions in Limine  Joint Proposed Final Pretrial Conference Order [L.R. 16-7]  Joint Agreed Upon Proposed Jury Instructions (jury trial only)  Disputed Proposed Jury Instructions (jury trial only)  Joint Proposed Verdict Forms (jury trial only)  Joint Proposed Statement of the Case (jury trial only)  Proposed Voir Dire Questions, if any (jury trial only)  Evidentiary Objections to Declarations of Direct Testimony (bench trial only) 84 weeks after scheduling conference To be set by the Court To be set by the Court To be set by the Court To be set by the Court To be set by the Court To be set by the Court Rev. 3/31/25 PATENT ACTION SCHEDULE OF PRETRIAL AND TRIAL DATES WORKSHEET Please complete this worksheet jointly and file it with your Joint Rule 26(f) Report. The parties must make every effort to agree on dates or the Court will set them. Case No. Case Name: Trial and Final Pretrial Conference Dates Pl(s)’ Date mm/dd/yyyy Def(s)’ Date mm/dd/yyyy Check one: ☐ Jury Trial or ☐ Bench Trial [Monday at 8:15 a.m. within 15–21 months of Scheduling] Estimated Duration: _______ Days Final Pretrial Conference (“FPTC”) [L.R. 16], Hearing on Motions in Limine [Friday at 1:30 p.m. at least 17 days before trial] Event Note: Hearings shall be on Fridays at 1:30 p.m. Other dates can be any day of the week. Time Computation Pl(s)’ Date mm/dd/yyyy Def(s)’ Date mm/dd/yyyy Last Date to Hear Motion to Amend Pleadings or Add Parties [Friday] 91 days after scheduling conference Deadline to Serve Infringement Contentions & Related Disclosures [Patent Rules 2(a), (b)] 14 days after scheduling conference Deadline to Serve Invalidity Contentions & Related Disclosures [Patent Rules 2(c), (d)] Deadline to Exchange Proposed Terms for Construction [Patent Rule 3(a)] Deadline to Exchange Preliminary Claim Constructions and Extrinsic Evidence [Patent Rule 3(b)] Deadline to Submit Joint Claim Construction and Prehearing Statement, and Expert Reports [Patent Rule 3(c)] Claim Construction Discovery Cut-Off [Patent Rule 3(d)] Deadline to File Opening Claim Construction Briefs [Patent Rule 3(e)(i)] Deadline to File Responsive Claim Construction Briefs [Patent Rule 3(e)(ii)] Deadline to File Reply Claim Construction Briefs [Patent Rule 3(e)(iii)] Deadline to Serve Damages Contentions [Patent Rule 2(h)] Deadline to Serve Responsive Damages Contentions [Patent Rule 2(i)] Deadline to Complete Damages Contentions Meeting (Patent Rule 2(j Rev. 3/31/25 59 days after scheduling conference 14 days after deadline to serve Invalidity Contentions; 42 days after deadline to serve Infringement Contentions (if validity is not at issue); or 14 days after service of Answer in declaratory judgment actions not based on validity). 21 days after deadline to exchange proposed claim construction terms 46 days after deadline to exchange proposed claim construction terms 76 days after deadline to exchange proposed claim construction terms 91 days after deadline to exchange proposed claim construction terms 105 days after deadline to exchange proposed claim construction terms 112 days after deadline to exchange proposed claim construction terms 109 days after scheduling conference 139 days after scheduling conference 199 days after scheduling conference Fact Discovery Cut-Off [Friday] (no later than deadline for filing dispositive motion) Expert Disclosure (Initial) Expert Disclosure (Rebuttal) Expert Discovery Cut-Off Last Date to Hear Motions [Friday]  Joint Brief due at least 28 days before hearing  Supplemental Memoranda (if any) due 14 days before hearing Deadline to Complete Settlement Conference [L.R. 16-15] Select one: ☐ 1. Magistrate Judge (with Court approval) ☐ 2. Court Mediation Panel ☐ 3. Private Mediation Trial Filings (first round) [Friday]  Motions in Limine  Memoranda of Contentions of Fact and Law [L.R. 16-4]  Witness Lists [L.R. 16-5]  Joint Exhibit List [L.R. 16-6.1]  Joint Status Report Regarding Settlement  Proposed Findings of Fact and Conclusions of Law [L.R. 52] (bench trial only)  Declarations Containing Direct Testimony, if ordered (bench trial only) Trial Filings (second round) [Friday]  Oppositions to Motions in Limine  Joint Proposed Final Pretrial Conference Order [L.R. 16-7]  Joint Agreed Upon Proposed Jury Instructions (jury trial only)  Disputed Proposed Jury Instructions (jury trial only)  Joint Proposed Verdict Forms (jury trial only)  Joint Proposed Statement of the Case (jury trial only)  Proposed Voir Dire Questions, if any (jury trial only)  Evidentiary Objections to Declarations of Direct Testimony (bench trial only) 21 weeks before FPTC 20 weeks before FPTC 18 weeks before FPTC 16 weeks before FPTC 9 weeks before FPTC 5 weeks before FPTC 4 weeks before FPTC 2 weeks before FPTC Rev. 3/31/25 FOIA ACTION SCHEDULE OF PRETRIAL DATES WORKSHEET Please complete this worksheet jointly and file it with your Joint Rule 26(f) Report. The parties must make every effort to agree on dates or the Court will set them. Case No. Case Name: Event Note: Hearings shall be on Fridays at 1:30 p.m. Other dates can be any day of the week. Time Computation Pl(s)’ Date mm/dd/yyyy Def(s)’ Date mm/dd/yyyy Last Date to Hear Motion to Amend Pleadings or Add Parties [Friday] 91 days after scheduling conference Last Date to Hear Motions [Friday]  Joint Brief due at least 28 days before hearing  Supplemental Memoranda (if any) due 14 days before hearing 10–15 months after scheduling conference Rev. 3/31/25 ERISA ACTION SCHEDULE OF PRETRIAL AND TRIAL DATES WORKSHEET Please complete this worksheet jointly and file it with your Joint Rule 26(f) Report. The parties must make every effort to agree on dates or the Court will set them. Case No. Case Name: Trial and Final Pretrial Conference Dates Pl(s)’ Date mm/dd/yyyy Def(s)’ Date mm/dd/yyyy Bench Trial [Friday at 1:30 p.m. within 10–12 months of Scheduling Conference] Estimated Duration: _______ Days Event Note: Hearings shall be on Fridays at 1:30 p.m. Other dates can be any day of the week. Time Computation Pl(s)’ Date mm/dd/yyyy Def(s)’ Date mm/dd/yyyy Last Date to Hear Motion to Amend Pleadings or Add Parties [Friday] Lodge Administrative Record & Plan Documents Fact Discovery Cut-Off (if necessary) [Friday] (no later than deadline for filing dispositive motion) 91 days after scheduling conference 63 days after scheduling Conference 24 weeks before trial Last Date to Hear Motions [Friday]  Joint Brief due at least 28 days before hearing  Supplemental Memoranda (if any) due 14 days before hearing 16 weeks before trial Deadline to Complete Settlement Conference [L.R. 16-15] Select one: ☐ 1. Magistrate Judge (with Court approval) ☐ 2. Court Mediation Panel ☐ 3. Private Mediation 9 weeks before trial File & Exchange Opening Trial Briefs 8 weeks before trial File & Exchange Responsive Trial Briefs (not to exceed 15 pages) 4 weeks before trial Rev. 3/31/25

=== Scheduling and Trial Order for Civil Cases Assigned to Judge Valenzuela Revised 3-31-25 ===

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA PLAINTIFF’S NAME, et al., Case No. 2:24-cv-00000-CV ( x) Plaintiff/s, v. DEFENDANT’S NAME, et al., Defendant/s. SCHEDULING AND TRIAL ORDER FOR CIVIL CASES ASSIGNED TO JUDGE VALENZUELA Rev. 3/31/25 1 CONTENTS I. SCHEDULE ........................................................................................................... 3 A. Deadlines for Motions ..................................................................................... 5 B. Discovery Cut-Off and Discovery Disputes .................................................... 5 C. Law and Motion and Local Rule 7-3 ............................................................... 5 D. Settlement Conference/Alternative Dispute Resolution Procedures .............. 6 E. Final Pretrial Conference/Proposed Final Pretrial Conference Order ............ 7 II. TRIAL REQUIREMENTS .................................................................................. 8 A. Schedule for Filing Pretrial Documents for Jury and Bench Trials ................ 8 1. Motions in Limine ...................................................................................... 9 2. Witness Lists ............................................................................................ 10 3. Joint Exhibit List ...................................................................................... 10 4. Case-Specific Glossary ............................................................................ 11 5. Jury Instructions (Jury Trial Only) ........................................................... 11 6. Joint Verdict Forms (Jury Trial Only) ..................................................... 13 7. Joint Statement of the Case (Jury Trial Only) .......................................... 13 8. Voir Dire (Jury Trial Only) ...................................................................... 13 9. Proposed Findings of Fact and Conclusions of Law (Bench Trial Only) 14 10. Declarations of Direct Testimony (Bench Trial Only) ............................ 14 B. Trial Exhibits ................................................................................................. 15 C. Materials to Present on First Day of Trial ..................................................... 17 D. Court Reporter ............................................................................................... 17 E. Jury Trial ........................................................................................................ 17 III. CONDUCT OF ATTORNEYS AND PARTIES .............................................. 18 A. Meeting and Conferring Throughout Trial .................................................... 18 B. Opening Statements, Witness Examinations, and Summation ...................... 18 C. Objections to Questions ................................................................................. 18 D. Closing Arguments and Post-Trial Briefs (Bench Trial) ............................... 18 E. General Decorum While in Session .............................................................. 18 F. Punctuality ..................................................................................................... 20 G. Exhibits .......................................................................................................... 20 H. Depositions .................................................................................................... 21 I. Advance Notice of Unusual or Difficult Issues ............................................. 22 J. Continuances of Pretrial and Trial Dates ....................................................... 23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 3/31/25 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I. SCHEDULE The Scheduling Order governing this action is set forth in the Schedule of Pretrial and Trial Dates chart below. The box in the upper right-hand corner of the chart states whether the trial will be by jury or court. If the parties1 seek to set additional dates, they may file a request or, if they are in agreement, a Stipulation and a Proposed Order. The parties should refer to the Court’s Standing Order for requirements regarding specific motions, discovery, certain types of filings, courtesy copies, emailing signature items to chambers, alternative dispute resolution, and other matters pertaining to all cases. A copy of the Court’s Standing Order is available at: https://www.cacd.uscourts.gov/honorable-cynthia-valenzuela. 1 The term “parties” includes people without an attorney and counsel for represented parties. Rev. 3/31/25 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DISTRICT JUDGE CYNTHIA VALENZUELA SCHEDULE OF PRETRIAL AND TRIAL DATES Trial and Final Pretrial Conference Dates Court Order Trial _ at 9:00 a.m. ☒ Jury Trial ☐ Bench Trial Est. _ Days Final Pretrial Conference (“FPTC”) [L.R. 16], Hearing on Motions in Limine _ at 1:30 p.m. Event Note: Hearings shall be on Fridays at 1:30 p.m. Court Order Last Date to Hear Motion to Amend Pleadings or Add Parties [Friday] ☐ 1. Magistrate Judge ☒ 2. Court Mediation Panel ☐ 3. Private Mediation Fact Discovery Cut-Off [Friday] Expert Disclosure (Initial) Expert Disclosure (Rebuttal) Expert Discovery Cut-Off Last Date to Hear Motions [Friday]  Joint MSJ Brief due at least 28 days before hearing  Supplemental Memoranda re MSJ (if any) due 14 days before hearing Deadline to Complete Settlement Conference [L.R. 16-15] Trial Filings (first round)  Motions in Limine  Memoranda of Contentions of Fact and Law [L.R. 16-4]  Witness Lists [L.R. 16-5]  Joint Exhibit List [L.R. 16-6.1]  Joint Status Report Regarding Settlement  Proposed Findings of Fact and Conclusions of Law [L.R. 52] (bench trial only)  Declarations containing Direct Testimony, if ordered (bench trial only) Trial Filings (second round)  Oppositions to Motions in Limine  Joint Proposed Final Pretrial Conference Order [L.R. 16-7]  Joint Agreed Upon Proposed Jury Instructions (jury trial only)  Disputed Proposed Jury Instructions (jury trial only)  Joint Proposed Verdict Forms (jury trial only)  Joint Proposed Statement of the Case (jury trial only)  Proposed Voir Dire Questions, if any (jury trial only)  Evidentiary Objections to Declarations of Direct Testimony (bench trial only) Rev. 3/31/25 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 A. Deadlines for Motions All motions must be noticed to be heard on or before their respective deadlines. All unserved parties will be dismissed at the time of the Final Pretrial Conference (“FPTC”) pursuant to Local Rule 16-8.1. B. Discovery Cut-Off and Discovery Disputes 1. Discovery Cut-off: The cut-off date for discovery is not the date by which discovery requests must be served; it is the date by which all discovery, including all hearings on any related motions, must be completed. Thus, written discovery must be served and depositions must begin sufficiently in advance of the discovery cut-off date to permit the propounding party enough time to challenge responses deemed to be deficient via motion practice. Given the requirements to meet and confer and to give notice, a planned motion to compel must ordinarily be discussed with the opposing party at least six (6) weeks before the cut-off. 2. Expert Discovery: All expert disclosures must be made in writing. The parties should begin expert discovery shortly after the initial designation of experts. The FPTC and trial dates will not be continued merely because expert discovery is not completed. Failure to comply with these or any other orders concerning expert discovery may result in the expert being excluded as a witness. 3. Discovery Disputes/Motions: Discovery disputes are handled by the Magistrate Judge assigned to the case. Any motion challenging the adequacy of discovery responses must be filed, served, and calendared sufficiently in advance of the discovery cut-off date to permit the responses to be obtained before that date if the motion is granted. C. Law and Motion and Local Rule 7-3 Counsel must comply with Local Rule 7-3, which requires counsel to engage in a pre-filing conference “to discuss thoroughly … the substance of the contemplated motion and any potential resolution.” Counsel must meet and confer in person or by telephone or videoconference; an exchange of written correspondence is insufficient. Rev. 3/31/25 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Counsel shall discuss the issues to a sufficient degree that if a motion is still necessary, the briefing may be directed to those substantive issues requiring resolution by the Court. Counsel shall resolve minor procedural or other non- substantive matters during the conference. The Court may strike or deny a motion if counsel fail to meet and confer in good faith. The Notice of Motion must include a statement of compliance with Local Rule 7-3. In addition, if the parties are unable to reach a resolution that eliminates the necessity for a hearing, counsel for the moving party must include a declaration, under penalty of perjury, that sets forth at a minimum the date(s) the conference took place and the position of each party with respect to each disputed issue that will be the subject of the motion. Failure to include such a declaration may result in the motion being denied. The following are exempted from Local Rule 7-3 and the pre-filing requirements to meet and confer set forth in this subsection III.B: (1) cases where at least one party is appearing pro se; (2) cases listed as exempt in Local Rule 16-12, (3) discovery motions governed by Local Rules 37-1 through 37-4, (4) applications under Fed. R. Civ. P. 65 for temporary restraining orders or preliminary injunctions, and (5) motions to retax costs under Local Rule 54-2.5. The parties should review the Court’s Standing Order and the Court’s Order Re: Summary Judgment Motions for instructions regarding motions to dismiss, motions to amend, motions for summary judgment, and other forms of relief. D. Settlement Conference/Alternative Dispute Resolution Procedures Pursuant to Local Rule 16-15, the parties must participate in a Settlement Conference or Alternative Dispute Resolution (“ADR”) procedure. This Scheduling Order indicates the procedure the parties shall use. See Section I supra. If the parties prefer an ADR procedure other than the one ordered by the Court, they shall file a Stipulation and Proposed Order. The parties’ request may not necessarily be granted. No case will proceed to trial unless all parties, including the principals of all Rev. 3/31/25 6 corporate parties, have appeared personally at a settlement conference. In the event the settlement conference is before a Magistrate Judge, the latter shall determine the form, manner, and content of the conference. The parties shall file a Joint Status Report regarding the outcome of settlement negotiations, the likelihood of possible further negotiations, and any assistance the Court may provide concerning settlement negotiations. The Joint Status Report shall not disclose the parties’ settlement positions, i.e., the terms of any offers or demands. If the parties were unable to reach a settlement, the Status Report shall describe the efforts made by the parties to resolve the dispute informally, i.e., the occasions and dates when the parties participated in mediation or settlement conferences. The Status Report shall also include the name of the mediator who assisted the parties with their settlement conference. E. Final Pretrial Conference/Proposed Final Pretrial Conference Order The Court has set a FPTC pursuant to Fed. R. Civ. P. 16 and Local Rule 16-8. The Court requires strict compliance with Fed. R. Civ. P. 16 and 26, and Local Rule 16. Each party appearing in this action must be represented at the FPTC by lead trial counsel. The parties must be prepared to discuss streamlining the trial, including presentation of testimony by deposition excerpts or summaries, time limits, and stipulations to undisputed facts. The parties must file a proposed Final Pretrial Conference Order (“Proposed FPTCO”) at least fourteen (14) days before the FPTC. A template for the Proposed FPTCO is available on Judge Valenzuela’s webpage. The parties must use this template. In specifying the surviving pleadings under section 1, state which claims or counterclaims have been dismissed or abandoned, e.g., “Plaintiff’s second cause of action for breach of fiduciary duty has been dismissed.” Also, in multiple-party cases where not all claims or counterclaims will be prosecuted against all remaining parties 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 3/31/25 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 on the opposing side, state to which party or parties each claim or counterclaim is directed. The parties must attempt to agree on and set forth as many uncontested facts as possible. The Court will read the uncontested facts to the jury at the start of trial. A carefully drafted and comprehensively stated stipulation of facts will shorten the trial and increase jury understanding of the case. In drafting the factual issues in dispute, the parties must state issues as ultimate facts, rather than evidentiary facts. The issues of fact should track the elements of a claim or defense on which the jury will be required to make findings. Issues of law should state legal issues on which the Court will be required to rule during the trial and should not list ultimate fact issues to be submitted to the trier of fact. The parties shall email the Proposed FPTCO in Microsoft Word format to chambers at [email protected]. II. TRIAL REQUIREMENTS The parties must comply with Local Rule 16. Pursuant to Local Rule 16-2, lead trial counsel for each party are required to meet and confer in person forty (40) days in advance to prepare for the FPTC. The parties must comply with Local Rule 16-2, except where the requirements set forth in this Order differ from or supplement those contained in Local Rule 16. The Court may take the FPTC off calendar, continue the trial, and/or impose other sanctions for failure to comply with these requirements. A. Schedule for Filing Pretrial Documents for Jury and Bench Trials The schedule for filing pretrial documents is as follows: ‚ At least twenty-eight (28) days before the FPTC:  Motions in Limine  Memoranda of Contentions of Fact and Law  Witness Lists  Joint Exhibit List Rev. 3/31/25 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28  Joint Status Report Regarding Settlement  Proposed Findings of Fact and Conclusions of Law (bench trial only)  Declarations containing Direct Testimony (bench trial only) ‚ At least fourteen (14) days before the FPTC:  Oppositions to Motions in Limine  Joint Proposed FPTCO  Joint Agreed Upon Proposed Jury Instructions (jury trial only)  Disputed Proposed Jury Instructions (jury trial only)  Joint Proposed Verdict Forms (jury trial only)  Joint Proposed Statement of the Case (jury trial only)  Proposed Voir Dire Questions, if any (jury trial only)  Evidentiary Objections to Declarations of Direct Testimony (bench trial only) The parties shall email copies of: (1) the Witness Lists, (2) the Joint Exhibit List, (3) the Joint Proposed FPTCO, (4) the Joint Agreed Upon Proposed Jury Instructions, (5) the Disputed Proposed Jury Instructions, (6) Joint Proposed Verdict Forms, and (7) Proposed Voir Dire Questions, including any amended documents, in Microsoft Word format to chambers the day they are due to Chambers at: [email protected]. 1. Motions in Limine Motions in limine shall address only the admission or exclusion of evidence at trial. Motions in limine will be heard and ruled on at the FPTC. The Court may rule orally instead of in writing. Each side is limited to five (5) motions in limine unless the Court grants leave to file additional motions. All motions in limine must be filed at least twenty-eight (28) days before the FPTC. Oppositions must be filed at least fourteen (14) days before the FPTC. There shall be no replies. Motions in limine and oppositions must not exceed 2,800 words in length, or ten (10) pages for handwritten briefs and briefs prepared using a typewriter. Challenges to expert testimony and/or Rev. 3/31/25 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 reports should be brought as motions in limine and are subject to the aforementioned schedule and limit. Any challenges to expert testimony or reports brought as separate motions shall be stricken. Before filing a motion in limine, the parties must meet and confer to determine whether the opposing party intends to introduce the disputed evidence and attempt to reach an agreement that would obviate the need for the motion. Motions in limine should address specific issues (e.g., not “to exclude all hearsay”). Motions in limine should not be disguised motions for summary adjudication of issues. The Court may strike excessive or unvetted motions in limine. Counsel are required to advise affected witnesses to comply with the Court’s rulings on motions in limine; counsel may be held responsible if they fail to properly advise them. 2. Witness Lists Witness lists must be filed twenty-eight (28) days before the FPTC. They must be in the format specified in Local Rule 16-5, and must include for each witness (i) a brief description of the testimony, (ii) the reasons the testimony is unique and not redundant, and (iii) a time estimate in hours for direct and cross-examination. The parties should use the template posted to Judge Valenzuela’s webpage. Any Amended Witness List must be filed by 5:00 p.m. on the Friday before trial and emailed to [email protected] in Microsoft Word format. 3. Joint Exhibit List The Joint Exhibit List must be filed twenty-eight (28) days before the FPTC. It must be in the format specified in Local Rule 16-6 and shall include an additional column stating any objections to authenticity and/or admissibility and the reasons for the objections. The parties should use the template posted to Judge Valenzuela’s webpage. Any Amended Joint Exhibit List must be filed by 5:00 p.m. on the Friday before trial and emailed to [email protected] in Microsoft Word format. Rev. 3/31/25 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4. Case-Specific Glossary The parties must provide a case-specific glossary for the court reporter that includes applicable medical, scientific, or technical terms, slang, the names and spellings of case names likely to be cited, street/city/country names, all parties/agents/departments/entities involved in the case, names of people interviewed/deposed, names of family members, friends, or others who might be mentioned, and other case-specific terminology. 5. Jury Instructions (Jury Trial Only) Joint agreed upon proposed jury instructions must be filed no later than fourteen (14) days prior to the FPTC. The parties shall make every effort to agree upon jury instructions before submitting proposals to the Court. The Court expects the parties to agree on the substantial majority of instructions, particularly when pattern or model jury instructions exist and provide a statement of applicable law. The parties shall meet and confer regarding jury instructions according to the following schedule:  Thirty-five (35) days before the FPTC: The parties shall exchange proposed general and special jury instructions.  Twenty-eight (28) days before the FPTC: The parties shall exchange any objections to the instructions.  Twenty-one (21) days before the FPTC: The parties shall meet and confer with the goal of reaching agreement on one set of Joint Agreed Upon Proposed Jury Instructions.  Fourteen (14) days before FPTC: The parties shall file their (1) Joint Agreed Upon Proposed Jury Instructions and their (2) Disputed Jury Instructions. The parties shall file clean and “redline” sets of their (1) Joint Agreed Upon Proposed Jury Instructions, and (2) Disputed Jury Instructions. The “redline” sets shall include all modifications made by the parties to pattern or model jury instructions, any disputed language, and the factual or legal basis for each party’s Rev. 3/31/25 11 position as to each disputed instruction. Where appropriate, the disputed instructions shall be organized by subject, so that instructions that address the same or similar issues are presented sequentially. If there are excessive or frivolous disagreements over jury instructions, the Court will order the parties to meet and confer immediately until they substantially narrow their disagreements. Sources: When the Manual of Model Jury Instructions for the Ninth Circuit provides an applicable jury instruction, the parties should submit the most recent version, modified and supplemented to fit the circumstances of the case. Where California law applies, the parties should use the current edition of the Judicial Council of California Civil Jury Instructions (“CACI”). If neither applies, the parties should consult the current edition of O’Malley, et al., Federal Jury Practice and Instructions. The parties may submit alternatives to these instructions only if there is a reasoned argument that they do not properly state the law or are incomplete. The Court seldom gives instructions derived solely from case law. Format: Each requested instruction shall: (1) cite the authority or source of the instruction, (2) be set forth in full, (3) be on a separate page, (4) be numbered, (5) cover only one subject or principle of law, and (6) not repeat principles of law contained in any other requested instruction. Jury instructions should be modified as necessary to fit the facts of the case (e.g., inserting names of parties or witnesses to whom an instruction applies). Where language appears in brackets in the pattern or model instruction, counsel shall select the appropriate text and eliminate the inapplicable bracketed text. It is counsel’s duty to conform the instructions to the case (e.g., inserting names of defendant(s) or witness(es) to whom the instruction applies and selecting the appropriate bracketed text, but not changing the standard language of the instruction). Index: All proposed jury instructions must have a consecutively numbered joint index that lists the instructions in the order they will be given. Disputed instructions 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 3/31/25 12 should be included in the index. The Court will renumber the jury instructions once they are finalized. The joint index should include (i) the number of the instructions; (ii) a brief title of the instruction; (iii) the source of the instruction; and (iv) the page number of the instruction. Example: Number Title Source Page # #1 Claims and Defenses 9th Cir. 1.5 1 During the FPTC and at trial and before closing argument, the Court will meet with the parties to settle the instructions. At that time, the parties will have an opportunity to make an oral record concerning their objections. 6. Joint Verdict Forms (Jury Trial Only) The parties shall make every effort to agree on a general verdict form before submitting proposals to the Court, and shall file a proposed joint general verdict form fourteen (14) days before the FPTC. If the parties are unable to agree on a verdict form, the parties shall file one document titled “Competing Verdict Forms” which shall include: (i) the parties’ respective proposed verdict form; (ii) a “redline” of any disputed language; and (iii) the factual or legal basis for each party’s respective position. 7. Joint Statement of the Case (Jury Trial Only) The parties must file a Joint Statement of the Case fourteen (14) days before the FPTC for the Court to read to the prospective jurors before commencement of voir dire. The joint statement should be brief and neutral and must not be more than one page in length. 8. Voir Dire (Jury Trial Only) Generally, a jury in a civil action will consist of eight (8) jurors. In most cases, the Court will seat eight (8) prospective jurors in the jury box. The Court will conduct the voir dire. The Court uses a written questionnaire that requires prospective jurors 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 3/31/25 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 to answer orally, a copy of which is posted on Judge Valenzuela’s webpage. The parties may file any proposed case-specific voir dire questions for the Court’s consideration at least fourteen (14) days before the FPTC. If it considers the questions proper, the Court will include them in the written questionnaire. At the conclusion of the Court’s voir dire, the parties may suggest additional questions for the Court’s consideration during a sidebar or recess outside the prospective jurors’ presence. See Fed. R. Civ. P. 47. Each side will have three (3) peremptory challenges in total regardless of the number of parties. All challenges for cause shall be made at side bar or otherwise outside the prospective jurors’ presence. The Court will not necessarily accept a stipulation to a challenge for cause. Peremptory challenges shall be made from counsel table in the presence of the prospective jurors. After all challenges have been exercised or the parties accept the panel consecutively, the remaining jurors will be the jury. 9. Proposed Findings of Fact and Conclusions of Law (Bench Trial Only) For any trial requiring findings of fact and conclusions of law, each party shall file and serve on the opposing party, no later than twenty-eight (28) days before the FPTC, its Proposed Findings of Fact and Conclusions of Law in the format specified in Local Rule 52-3. The parties may submit Supplemental Proposed Findings of Fact and Conclusions of Law during the trial. Once trial concludes, the Court may order the parties to file Revised Proposed Findings of Fact and Conclusions of Law with citations to the record. 10. Declarations of Direct Testimony (Bench Trial Only) When ordered by the Court in a particular case, each party shall, at least twenty-eight (28) days before the FPTC, file declarations containing the direct testimony of each witness whom that party intends to call at trial. If such declarations Rev. 3/31/25 14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 are filed, each party shall file any evidentiary objections to the declarations submitted by any other party at least fourteen (14) days before the FPTC. Such objections shall be submitted in the following three-column format: (i) the left column should contain a verbatim quote of each statement objected to (including page and line number); (ii) the middle column should set forth a concise legal objection (e.g., hearsay, lacks foundation, etc.) with a citation to the corresponding Federal Rule of Evidence or, where applicable, a case citation; and (iii) the right column should provide space for the Court’s ruling on the objection. The Court anticipates issuing its ruling on the objections during the FPTC. B. Trial Exhibits Trial exhibits that consist of documents and photographs must be submitted to the Court in three-ring binders. The parties shall submit to the Court three (3) sets of binders: one (1) original set of trial exhibits, and two (2) copies of trial exhibits. The original set of exhibits shall be for use by the jury during its deliberations, and the copies are for the Court. The parties should prepare additional copies of exhibits for their own use and for use by witnesses. The parties must review the exhibit list and exhibit binders with the Courtroom Deputy Clerk before the admitted exhibits will be given to the jury. In the event the exhibits are voluminous, the parties should consider the use of electronic tablets for the Court and the witnesses thereby avoiding the need for binders. All exhibits placed in three-ring binders must be indexed by exhibit number with tabs or dividers on the right side. Exhibits shall be numbered sequentially 1, 2, 3, etc., not 1.1, 1.2, etc. See Local Rule 16-6. Every page of a multi-page exhibit must be numbered. Defendant’s exhibit numbers shall not duplicate Plaintiff’s numbers. The spine of each binder shall indicate the volume number and the range of exhibit numbers included in the volume.  The original exhibits shall bear the official exhibit tags (yellow tags for Plaintiff’s exhibits and blue tags for Defendant’s exhibits) affixed to the Rev. 3/31/25 15 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 front upper right-hand corner of the exhibit, with the case number, case name, and exhibit number stated on each tag. Tags may be obtained from the Clerk’s Office, or the parties may print their own exhibit tags using Forms G-14A and G-14B on the “Court Forms” section of the Court’s website at: https://www.cacd.uscourts.gov/forms/exhibit-tags-plaintiff-g- 14a-defendant-g-14b-joint-g-14c.  The copies of exhibits must bear copies of the official exhibit tags that were placed on the original exhibits and be indexed with tabs or dividers on the right side. The parties must also submit to the Court a USB flash drive containing electronic versions of all exhibits. Plaintiff’s exhibits must be placed in a separate folder from Defendant’s exhibits, and the document file names must include the exhibit number and a brief description of the document, for example: “Ex. 1 - Smith Declaration.pdf” or “Ex. 105 - Letter Dated 1-5-20.pdf.” The Court provides audio/visual equipment for use during trial. The parties are encouraged to use it. More information is available at: http://www.cacd.uscourts.gov/clerk-services/courtroom-technology. The Court does not permit exhibits to be “published” to the jurors before they are admitted into evidence. Once admitted, exhibits may be displayed electronically using the equipment and screens in the courtroom. The Court ordinarily does not permit exhibits to be handed to the jurors in the jury box. In the event an exhibit cannot be displayed properly via the monitors in the courtroom, counsel must secure approval by the Court before handing an exhibit to the jury. The parties must meet and confer at least ten (10) days before trial to stipulate as much as possible to foundation, waiver of the best evidence rule, and exhibits that may be received into evidence at the start of the trial. All such exhibits should be noted as admitted on the Court and Courtroom Deputy Clerk’s copy of the exhibit list. Rev. 3/31/25 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 C. Materials to Present on First Day of Trial The parties must present the following materials to the Courtroom Deputy Clerk on the first day of trial: 1. The three sets of binders described above, with one (1) original set of trial exhibits for the jury, and two (2) copies of trial exhibits for the Court. 2. The USB flash drive containing electronic versions of all exhibits. 3. Any excerpts of deposition transcripts to be used at trial, either as evidence or for impeachment. These lodged depositions are for the Court’s use. The parties must use their own copies during trial. D. Court Reporter Any party requesting special court reporter services for any hearing, such as “RealTime” transmission or daily transcripts, shall notify the court reporter at least fourteen (14) days before the hearing date. Please review the Central District’s webpage on Court Reporting Services for relevant information. See http://www.cacd.uscourts.gov/court-reporting-services. E. Jury Trial Trial days are generally Tuesday through Friday, from 9:00 a.m. through 4:30 p.m. On the first day of trial, the Court will first address logistical matters and call a jury panel only when it is satisfied the case is ready for trial. Jury selection usually takes a few hours. The parties should be prepared to proceed with opening statements and witness examination immediately after jury selection. Fridays are usually reserved for the Court’s calendar. In the event the Court’s calendar allows trial to proceed on Friday, the Court will inform the parties during the Final Pretrial Conference. Once the trial concludes, the jury will be expected to deliberate Monday through Friday. // // Rev. 3/31/25 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 III. CONDUCT OF ATTORNEYS AND PARTIES A. Meeting and Conferring Throughout Trial The parties must continue to meet and confer on all issues that arise during trial. The Court will not rule on any such issue unless the parties have attempted to resolve it first. B. Opening Statements, Witness Examinations, and Summation Counsel must use the lectern. Counsel should not consume jury time drawing or writing; all demonstrative aids must be prepared fully in advance of the day’s trial session. Counsel should not ask witnesses to draw charts or diagrams or ask the Court’s permission for a witness to do so. When appropriate, the Court will establish and enforce time limits for all phases of trial, including opening statements, closing arguments, and the examination of witnesses. C. Objections to Questions Counsel must not make speaking objections before the jury or otherwise make speeches, restate testimony, or attempt to guide a witness. When objecting, counsel must rise to state the objection and state only that counsel objects and the legal grounds for the objection. If counsel desires to argue an objection further, counsel must seek permission from the Court to do so. D. Closing Arguments and Post-Trial Briefs (Bench Trial) For an overview and review of the evidence presented during trial, the Court will rely on the parties’ closing arguments. In delivering closing arguments, the parties shall use their respective proposed findings of fact and conclusions of law as a “checklist” and should identify the evidence that supports their proposed findings. The Court will not accept post-trial briefs unless it finds that circumstances warrant additional briefing and such briefing is specifically authorized. E. General Decorum While in Session 1. Counsel must not approach the Courtroom Deputy Clerk, the jury box, or the witness stand without Court authorization and must return to the lectern Rev. 3/31/25 18 when the purpose for the approach has been accomplished. 2. Counsel must rise when addressing the Court, and when the Court or the jury enters or leaves the courtroom, unless directed otherwise. 3. Counsel must address all remarks to the Court. Counsel must not address the Courtroom Deputy Clerk, the court reporter, persons in the audience, or opposing counsel. Any request to re-read questions or answers shall be addressed to the Court. Counsel must ask the Court’s permission to speak with opposing counsel. 4. Counsel must not address or refer to witnesses or parties by first names alone, except for witnesses who are below age fourteen (14). 5. Counsel must not offer a stipulation unless counsel have conferred with opposing counsel and have verified that the stipulation will be acceptable. 6. Counsel must remain at counsel table throughout trial except to examine witnesses, or as otherwise needed to present evidence. Counsel must not leave counsel table to sit in the gallery or confer with any person in the back of the courtroom without the Court’s permission. 7. Counsel must not make facial expressions, nod, shake their heads, comment, or otherwise exhibit in any way any agreement, disagreement, or other opinion or belief concerning the testimony of a witness or argument by opposing counsel. Counsel shall instruct their clients and witnesses not to engage in such conduct. 8. Counsel must never speak to jurors under any circumstance, and must not speak to co-counsel, opposing counsel, witnesses, or clients if the conversation can be overheard by jurors. Counsel must instruct their clients and witnesses to avoid such conduct. 9. Where a party has more than one lawyer, only one attorney may conduct the direct or cross-examination of a particular witness or make objections as to that witness. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 3/31/25 19 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 10. Bottled water is permitted in the courtroom but may not be placed on counsel table or the lectern. Food and other beverages are not permitted. Cell phones must be silenced or may be confiscated. F. Punctuality 1. The Court expects the parties, counsel, and witnesses to be punctual. Once the parties and their counsel are engaged in trial, the trial must be their priority. The Court will not delay progress of the trial or inconvenience jurors. 2. If a witness was on the stand at the time of a recess or adjournment, the party that called the witness shall ensure the witness is back on the stand and ready to proceed as soon as trial resumes. 3. The parties must notify the Courtroom Deputy Clerk in advance if any party, counsel, or witness requires a reasonable accommodation based on a disability or other reason. 4. No presenting party may be without witnesses. If a party’s remaining witnesses are not immediately available, thereby causing an unreasonable delay, the Court may deem that party to have rested. 5. The Court generally will accommodate witnesses by permitting them to be called out of sequence. Counsel should meet and confer in advance and make every effort to resolve the matter. G. Exhibits 1. Counsel must keep track of their exhibits and exhibit list, and record when each exhibit has been admitted into evidence. 2. Counsel are responsible for any exhibits they secure from the Courtroom Deputy Clerk and must return them before leaving the courtroom. 3. Any exhibit not previously marked must be accompanied by a request that it be marked for identification at the time of its first mention. Counsel must show a new exhibit to opposing counsel before the court session in which it is mentioned. Rev. 3/31/25 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4. Counsel must inform the Courtroom Deputy Clerk of any agreements reached regarding any proposed exhibits, as well as those exhibits that may be received into evidence without a motion to admit. 5. When referring to an exhibit, counsel must refer to its exhibit number. Counsel should instruct their witnesses to do the same. H. Depositions 1. Any party intending to use a deposition for impeachment or in lieu of live testimony must (a) file the deposition designations together with objections 14 days before the Final Pre-trial Conference if there are any objections or disputes requiring a ruling by the Court or (b) lodge the original deposition with the CRD on or before the first day of trial if there are no disputes. The untimely filing of the original deposition may result in exclusion. In addition, each party intending to present evidence by way of deposition testimony shall comply with the following instructions: i. Identify on the original transcript the testimony the party intends to offer by bracketing the questions and answers in the margins. The opposing party shall likewise counter-designate any testimony it plans to offer. ii. Identify any objections to the proffered evidence in the margins of the deposition by briefly providing the ground for the objection and the response to the objection. iii. For all depositions offered in the case, the parties shall consistently use different colored ink—black for plaintiff and blue for defendant—for designations, counter-designations, objections, and responses to objections. iv. Provide an index for each deposition, placed behind the first page of the deposition, identifying each page that contains a designation or counter- designation. v. Provide to the CRD an electronic copy of the above materials, including all designations, counter-designations, and objections. Rev. 3/31/25 21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2. In using deposition testimony for impeachment, counsel may adhere to either one of the following procedures: a. If counsel wish to read the questions and answers as alleged impeachment and ask the witness no further questions on that subject, counsel shall first state the page and line where the reading begins and the page and line where the reading ends and allow time for any objection. Counsel may then read the portions of the deposition into the record. b. If counsel wish to ask the witness further questions on the subject matter, the deposition shall be placed in front of the witness and the witness told to read the relevant pages and lines silently. Counsel may then either ask the witness further questions on the matter and thereafter read the quotations or read the quotations and thereafter ask further questions. Counsel should have available for the Court and the witness extra copies of the deposition transcript for this purpose. 3. Where a witness is absent and the witness’s testimony is to be offered by deposition, counsel may (a) have an individual sit on the witness stand and read the testimony of the witness while the examining lawyer asks the questions, or (b) have counsel read both the questions and the answers. I. Advance Notice of Unusual or Difficult Issues If any party anticipates that a difficult question of law or evidence will necessitate legal argument requiring research or briefing, that party must give the Court advance notice. The parties must notify the Courtroom Deputy Clerk immediately of any unexpected legal issue that could not have been foreseen and addressed in advance. To the extent such issue needs to be addressed outside the jury’s presence, the relevant party must inform the Courtroom Deputy Clerk before jurors are excused for the day to minimize the time jurors are kept waiting. The Court expects all parties to work diligently to minimize delays and avoid keeping jurors waiting. Rev. 3/31/25 22 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 J. Continuances of Pretrial and Trial Dates Requests for continuances of pretrial and trial dates must be by motion, stipulation, or application, and be accompanied by a detailed declaration setting forth the reasons for the requested relief. The declaration should include whether any previous requests for continuances have been made and whether these requests were granted or denied by the Court. Stipulations extending dates set by the court are not effective unless approved by the Court. The Court has a strong interest in keeping scheduled dates certain, and changes in dates are disfavored. Trial dates set by the Court will not readily be changed. Therefore, a request or stipulation to continue a trial or pretrial date must be supported by a detailed factual showing of good cause and due diligence demonstrating the necessity for the continuance and a description of the parties’ efforts, dating back to the filing of the complaint, of the steps they have taken to advance the litigation. This detailed showing must demonstrate that the work still to be performed reasonably could not have been accomplished within the applicable deadlines. General statements are insufficient to establish good cause. Without such compelling factual support and showing of due diligence, requests to continue dates set by the Court may be denied. To the extent the request to continue dates is joint, it should state clearly that the parties agree. To the extent the action is complex, one or more parties require additional time to prepare for trial, or other circumstances apply necessitating a continuance, the request should so state and describe in detail. A list of counsel’s upcoming scheduled trials in other actions will not support a showing of good cause absent the following information regarding each such action listed: (1) the case name, case number, court where the action is pending, and the initials of the district judge or name of the state court judge assigned to the action; (2) the age of the action; (3) the nature of and complexity of the action; (4) the scheduled trial date; (5) the estimated length of trial; (6) the number of continuances previously granted; (7) the parties’ trial Rev. 3/31/25 23 readiness; (8) the estimated likelihood a future continuance will be requested; and (9) the likelihood the trial will proceed on the scheduled date. Counsel shall file requests for continuance of trial at least one (1) week prior to the Final Pretrial Conference. A request to continue dates that have already expired constitutes a presumptive lack of due diligence. Requests extending dates set by the Court are not effective unless approved by the Court. IT IS SO ORDERED. Dated: ______________________________ HON. CYNTHIA VALENZUELA UNITED STATES DISTRICT JUDGE 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 3/31/25 24

=== Proposed Order Template - Rev. 3-13-25 ===

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA PLAINTIFF’S NAME, et al., Case No. 0:00-cv-00000-CV ( x) Plaintiff/s, v. DEFENDANT’S NAME, et al., Defendant/s. [PROPOSED] ORDER GRANTING NAME OF MOTION / STIPULATION / APPLICATION [DOC. # ___] On [Date], [Plaintiffs/Defendants/the Parties filed …]. [Brief summary of the moving party/parties’ request]. The Court, having considered [Plaintiffs/Defendants’ Motion/Stipulation/Application] and good cause having been found, hereby GRANTS the [Motion/Stipulation/Application] and ORDERS as follows: 1. 2. 3. [Request 1]; [Request 2]; and [Request 3]. IT IS SO ORDERED. 1 Dated: ______________________________ HON. CYNTHIA VALENZUELA UNITED STATES DISTRICT JUDGE 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2

=== Order Re MSJ - Rev. 3-13-25 ===

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA PLAINTIFF’S NAME, et al., Case No. 0:00-cv-00000-CV ( x) Plaintiff(s), v. DEFENDANT’S NAME, et al., Defendant(s). ORDER RE MOTIONS FOR SUMMARY JUDGMENT [Updated 3/13/25] READ THIS ORDER CAREFULLY BECAUSE IT CONTROLS THIS CASE AND DIFFERS IN PART FROM THE LOCAL RULES. WHEN CONSULTING THIS ORDER, PLEASE BE SURE TO USE THE MOST UPDATED VERSION LOCATED ON JUDGE VALENZUELA’S WEBPAGE. 1 1 Judge Valenzuela’s webpage can be found at https://www.cacd.uscourts.gov/honorable-cynthia-valenzuela. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1. GENERAL REQUIREMENTS a. Joint Brief. The parties shall work cooperatively to submit a single joint brief for all motions for summary judgment or adjudication (MSJs) brought by all moving parties. The joint brief shall be organized by issue, presenting the parties’ competing positions on an issue-by-issue basis. For each issue, the moving party shall present legal argument and citation to the Joint Appendix of Facts (JAF), see infra, followed immediately by the opposition’s response that similarly must be supported by legal argument and citation to the JAF. b. Form. Because summary judgment motions are fact-intensive, parties should prepare papers in a fashion that will assist the Court in considering the material (e.g., through use of tabs, tables of contents, headings, indices). The joint brief must cite to the JAF, see infra. c. Word Limit. Each separately represented party shall be limited to 7,000 words, exclusive of tables of contents and authorities. Leave for additional briefing will be given only in extraordinary cases. Each party is limited to the use of a total of eight footnotes. d. Timing. The Court expects the parties to agree to a filing schedule for an MSJ, which must be filed in compliance with the deadlines set forth in Paragraph 1(e). The parties should not wait until the last day to file; on the other hand, the filing of clearly premature motions requiring a continuance to permit discovery wastes resources. e. Briefing Schedule. If multiple parties are moving for summary judgment, the parties should designate only one party as “the moving party” for purposes of the briefing schedule.2 The schedule for the joint brief shall be as follows: 2 The Court expects the parties to work together professionally and agree on which Rev. 3/13/25 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 i. Meet and Confer. For an MSJ to be timely filed, the moving party must arrange for an in-person meeting or videoconference to take place no later than 53 days before the motion hearing cutoff set forth in the case management order. The parties shall thoroughly discuss each issue to be raised and the law and evidence relevant to that issue. A thorough discussion serves a critical function: It often narrows the issues to be adjudicated, and it allows the parties to squarely and fully address the actual issues requiring resolution. ii. Moving Portion. No later than seven days after the meet and confer, the moving party shall provide to the opposing party an electronic copy of the moving party’s portion of the joint brief, together with the moving party’s portion of the JAF and Joint Appendix of Evidence (JAE), see infra. iii. Opposing Portion. No later than 14 days after receiving the moving party’s papers, the opposing party shall provide to the moving party an electronic copy of the integrated motion, which shall include the opposing party’s portion of the joint brief, JAF, and JAE. At this point, the opposing party should sign the joint brief, and include a Certificate of Compliance regarding its portions of the brief. See Local Rule 11-6.2. iv. Filing of Joint Brief. After receiving the integrated version of the motion and related papers, the moving party shall finalize it for filing without making any further revisions to the joint brief and appendices, except to note in the JAF (in the format described in party should be designated the moving party. If the parties are unable to agree, the defendant shall be deemed the moving party. If different parties seek summary judgment on different issues, the parties may agree to modify the pre-filing deadlines in the briefing schedule without leave of Court if and only if (1) all parties agree to the modifications and (2) the summary judgment motion is timely filed under the case management order. Rev. 3/13/25 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 the instructions below) whether any facts added by the opposing party are disputed or undisputed. Once finalized, the moving party’s counsel shall sign and electronically file the joint brief, JAF, and JAE no later than four days after receiving the opposing party’s signed copy. The moving party should include a Certificate of Compliance regarding its portions of the joint brief. See Local Rule 11-6.2. The joint brief shall be accompanied by a Notice of Motion and Motion for Summary Judgment and shall be calendared pursuant to the Local Rules on an available date no later than the motion hearing cutoff in the case management order. f. Supplemental Memoranda. After the joint brief is filed, each party may separately file a supplemental memorandum of points and authorities, not exceeding 3,000 words, no later than 14 days before the scheduled hearing date. A supplemental brief must be accompanied by a Certificate of Compliance pursuant to Local Rule 11-6.2. The parties may not use this filing to supplement the JAF or the JAE in any way. No additional briefing or filing in support of or in opposition to the MSJ is permitted. g. Multiple Motions. No more than one joint motion may be filed under Fed. R. Civ. P. 56, whether brought as a motion for summary judgment or summary adjudication, without leave of Court. In the rare case in which leave of Court is sought, the parties shall file a joint noticed motion setting forth their respective positions on the existence of good cause for the filing of multiple motions. 2. JOINT APPENDIX OF FACTS (JAF) The joint brief shall be accompanied by a single statement of undisputed and disputed facts contained in a JAF presented in a table. This Court’s requirements for the JAF supersede the requirements in Local Rules 56-1, 56-2, and 56-3 for a “Statement of Uncontroverted Facts,” which the parties need not additionally file. Rev. 3/13/25 4 a. Table Format. The JAF table shall contain four columns. i. Column No. 1. The first column shall contain the number of the fact alleged to be undisputed. All asserted undisputed facts shall be sequentially numbered and divided into sections according to the element of proof to which the facts relate. ii. Column No. 2. The second column shall contain a plain statement of the fact.  Facts shall not be compound (e.g., Mike and Jane signed a contract, and Jane mailed the contract in May 2017).  Each fact must be stated separately in its own row as shown below.  Neither legal arguments nor conclusions constitute facts.  Facts shall not be repeated if they relate to multiple claims for multiple elements of proof. The first reference to a fact in the JAF shall serve and—through incorporation by reference—can be cited to support all subsequent claims (e.g., “See JAF 1–5”). iii. Column No. 3. The third column shall contain a citation to admissible evidence that supports the proffered fact; the evidence cited must be included in the JAE. iv. Column No. 4. The fourth column shall contain the opposing party’s response to the fact alleged to be undisputed: (1) stating that the fact is undisputed or disputed, (2) briefly stating why the opposing party disputes the fact, (3) citing with specificity the evidence that refutes the fact, and (4) explaining how the cited evidence refutes the fact; the evidence cited must be included in the JAE. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 3/13/25 5 b. Headers. Where feasible, parties should use headers to group facts relevant to a particular issue. The table below illustrates the format that must be used. SUF No. Fact Supporting Evidence Def.’s Response Issue No. 1. Plaintiff’s Claim for Breach of Contract is Barred by the Statute of Limitations. 1. 2. Witness 1and Witness 2 signed a contract for the sale and purchase of property. Witness 2 mailed the contract in May 2017. Witness 3 Decl. ¶ 5, Ex. 6. Witness 3 Decl. ¶ 8, Ex. 21. Disputed. Witness 2 testified that the contract was for a lease, not a purchase. Witness 2 Depo. 29:4-8, Ex. 1. Disputed in Part. Witness 2 testified she mailed the contract in January 2017. Witness 2 Depo. 3:4-6, Ex. 1. c. Good-Faith Preparation. The parties shall cooperate to prepare the JAF in good faith and otherwise will be subject to appropriate sanctions. i. The parties shall work cooperatively to identify a single set of facts alleged to be undisputed to avoid unnecessary duplication or confusion. ii. The parties shall provide only material facts, in a noncompound form, arranged according to their relevancy to a particular issue. Do not rotely “cut and paste” from the “Background” of the joint brief. iii. If a party disputes a fact in bad faith by offering evidence that does not contradict the proffered fact or by failing to provide a specific citation to the supporting evidence, the Court will deem the fact 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 3/13/25 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 undisputed for purposes of the motion. See Fed. R. Civ. P. 56(e)(2); L.R. 56-4. iv. If a party disputes a fact in part, the disputing party should state “Disputed in Part,” highlight the disputed part in bold italics, and provide the specific evidentiary support for the dispute (see example above). A party that lacks candor in failing to acknowledge the limited extent of the dispute forces the Court to expend needless resources discovering it itself. v. The JAF should be as narrow and concise as the issues on summary judgment properly warrant. If the Court determines that the JAF is unjustifiably long or unwieldy, the Court may strike the JAF and require the parties to refile it (and any document citing it) within two business days. vi. Deliberate gamesmanship designed to abuse the process may result in an order to show cause (OSC) re sanctions against the abusive party and/or counsel, including, if appropriate, terminating and/or monetary sanctions. A party who is the subject of an OSC should be prepared to justify each purportedly disputed fact at the hearing. Abuses that may invite an OSC include but are not limited to the following tactics:   Stating a fact is undisputed when it clearly is not; Disputing a clearly undisputed fact in whole or part;  Manufacturing a dispute by mischaracterizing evidence, reframing the stated fact in order to dispute the fact as reframed, or using an evidentiary objection to dispute an undisputed fact;  Making legal argument in the JAF; and  Introducing clearly irrelevant or immaterial facts for the obvious purpose of obfuscation. Rev. 3/13/25 7 3. JOINT APPENDIX OF EVIDENCE (JAE) The joint brief shall be accompanied by a JAE—i.e., a separate, tabbed appendix of all evidence in support of or opposition to the MSJ, including declarations, deposition excerpts, documents, photographs, etc. Physical evidence (e.g., video recordings) shall be lodged separately. No evidence should be attached to a memorandum of points and authorities or included anywhere other than in the JAE. The JAE shall include a table of contents. The JAE shall be filed as a single, combined PDF; more than one PDF may be filed if file-size constraints preclude filing the JAE as a single PDF. In the event multiple PDFs are necessary to file the JAE, each file shall be titled by part and exhibit series (e.g., JAE Part 1, Exhibits 1–50). Each exhibit within the JAE must be bookmarked; the bookmark should include the exhibit number and a brief description of the exhibit (e.g., Ex. 1 – Jones Depo. Excerpts). Declarations shall set out admissible facts without any argument, and evidence must be properly authenticated by stipulation, declaration, or otherwise. No party shall submit evidence other than the specific evidence necessary to support or controvert a proposed statement of undisputed fact. Do not, for example, submit the entire deposition transcripts or an entire set of interrogatory responses when relying on only a portion thereof. When multiple parties wish to produce different excerpts of the transcript of the same deposition, the excerpts shall be combined into a single exhibit containing all pages to which either party cites. 4. JOINT APPENDIX OF OBJECTIONS (JAO) The parties shall prepare a Joint Appendix of Objections (JAO) containing any evidentiary objections in a single, separate document presented in a three-column table as follows: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 3/13/25 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Objector Evidence Objection (O)/Response (R) Plaintiff 1. “Witness 2 mailed the contract in May 2017.” (Witness 1 Decl. ¶ 8.) O: Lacks foundation. R: Witness 1 saw Witness 2 mail it. (Party 1 Decl. ¶ 8.) Failure to comply with this formatting requirement will result in a waiver of the objections. Blanket or boilerplate objections will be overruled and disregarded. To allow both sides the opportunity to respond to the other’s evidentiary objections, the JAO is due after the joint brief, JAF, and JAE, as follows: The party opposing summary judgment shall provide the moving party with any objections to the moving party’s evidence at the same time that it provides its portion of the joint brief, the JAF, and the JAE. No later than seven days after receiving these materials, the moving party shall provide to the opposing party its responses to the opposing party’s evidentiary objections, together with any objections to the opposing party’s evidence. Within seven days thereafter, the opposing party shall add its responses to the moving party’s objections (without making any other changes) and file the JAO. The parties’ objections and responses in the JAO shall be brief and strictly limited to the admissibility of the evidence. No substantive legal arguments will be permitted. If an evidentiary dispute is dispositive of a claim or argument, it should be addressed in the briefing on that claim or argument. 5. FAILURE TO COMPLY If it appears that the parties have not met and conferred in good faith, have not worked to fully integrate the MSJ, or have otherwise failed to fully comply with this Order, the MSJ may be stricken, and the parties may be required to repeat the process. The deadline for hearing the MSJ will not be continued for failure to comply with this Order, absent good cause. If it appears that one (or more) of the parties is primarily Rev. 3/13/25 9 responsible for the failure to properly file a compliant joint brief, the primarily responsible party or parties shall be subject to appropriate sanctions. IT IS SO ORDERED. Dated: ______________________________ HON. CYNTHIA VALENZUELA UNITED STATES DISTRICT JUDGE 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Rev. 3/13/25 10

=== Judge Valenzuela's Joint Proposed FPTC Order Template Rev. 3-18-25 ===

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA PLAINTIFF’S NAME, et al., Case No. 0:00-cv-00000-CV ( x) Plaintiff/s, v. FINAL PRETRIAL CONFERENCE ORDER DEFENDANT’S NAME, et al., Defendant/s. Trial Date: Final Pretrial Conference: Judge: Hon. Cynthia Valenzuela [Judge Valenzuela’s Template] 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TABLE OF CONTENTS I. THE PARTIES AND PLEADINGS ..................................................................... 3 II. JURISDICTION .................................................................................................... 3 III. TRIAL DURATION .......................................................................................... 3 IV. JURY TRIAL ..................................................................................................... 3 V. ADMITTED FACTS............................................................................................. 3 VI. STIPULATED FACTS ...................................................................................... 3 VII. PARTIES’ CLAIMS AND DEFENSES ........................................................... 3 VIII. REMAINING TRIABLE ISSUES .................................................................... 4 IX. DISCOVERY ..................................................................................................... 4 X. DISCLOSURES AND EXHIBIT LIST ................................................................ 4 XI. WITNESS LISTS ............................................................................................... 5 XII. MOTIONS IN LIMINE ..................................................................................... 5 XIII. BIFURCATION ................................................................................................. 5 XIV. ADMISSIONS ................................................................................................... 5 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Following pre-trial proceedings, pursuant to Federal Rule of Civil Procedure 16 and Local Rule 16, IT IS ORDERED: I. THE PARTIES AND PLEADINGS Plaintiff’s ____ claim for ________ has been dismissed. II. JURISDICTION It is stipulated that subject matter jurisdiction over this action exists under 28 U.S.C. § ___, and venue is proper in this District and this Division pursuant to 28 U.S.C. § ___. III. TRIAL DURATION The trial is estimated to take ___ days. IV. JURY TRIAL The trial is to be by jury. Plaintiff and Defendant shall serve and file “Unopposed/Agreed Upon Set of Jury Instructions and Verdict Forms” as well as the “Joint Statement re: Disputed Instructions and Verdicts” by no later than ___. V. ADMITTED FACTS The following facts are admitted and require no proof: VI. STIPULATED FACTS The following facts, though stipulated, shall be without prejudice to any evidentiary objection: VII. PARTIES’ CLAIMS AND DEFENSES Plaintiff’s Claims: 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 (a) Plaintiff plans to pursue the following claims against Defendant: Claim 1: Claim 2: (b) The elements required to establish Plaintiff’s claims are: Claim 1: Claim 2: (c) The key evidence Plaintiff relies on for each claim is: Claim 1: Claim 2: Defendant’s Affirmative Defenses: (a) Defendant plans to pursue the following affirmative defenses: Defense 1: Defense 2: (b) The elements required to establish Defendant’s affirmative defenses are: Defense 1: Defense 2: VIII. REMAINING TRIABLE ISSUES In view of the admitted facts and the elements required to establish the claims and affirmative defenses, the following issues remain to be tried: IX. DISCOVERY All discovery is complete. X. DISCLOSURES AND EXHIBIT LIST All disclosures under Fed. R. Civ. P. 26(a)(3) have been made. The parties’ joint exhibit list has been filed under separate cover as required by Local Rule 16-6.1 (“Joint Exhibit List”). In view of the volume of exhibits marked by 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 each party, the parties have incorporated in the attached “Joint Exhibit List” all agreements regarding admitted exhibits, and all objections, including the grounds therefor. XI. WITNESS LISTS Witness lists of the parties shall be filed with the court not later than ___. Only the witnesses identified on the lists will be permitted to testify (other than solely for impeachment). XII. MOTIONS IN LIMINE The following motions in limine, and no others, are pending or contemplated: The parties advise the Court that the following law and motion matters may arise during trial. XIII. BIFURCATION Bifurcation of the following issues for trial is ordered: XIV. ADMISSIONS The foregoing admissions having been made by the parties, and the parties having specified the foregoing issues remaining to be litigated, this Final Pretrial Conference Order shall supersede the pleadings, and govern the course of the trial of this cause, unless modified to prevent manifest injustice. IT IS SO ORDERED. Dated: ______________________________ HON. CYNTHIA VALENZUELA UNITED STATES DISTRICT JUDGE 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Approved as to form and content: Dated: Counsel for Plaintiff By: Counsel for Plaintiff Dated: Counsel for Defendant By: Counsel for Defendant 6

=== Judge Valenzuela's Joint Exhibit List Template Rev. 3-18-25 ===

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA PLAINTIFF’S NAME, et al., Case No. 0:00-cv-00000-CV (__x) Plaintiff/s, v. DEFENDANT’S NAME, et al., Defendant/s. JOINT EXHIBIT LIST [Judge Valenzuela’s Template] 1 Ex. # Description 1 1/30/80 letter from Doe to Roe Witness Establishing Foundation Objections and Reasons Date Identified Date Admitted 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 2

=== Judge Valenzuela's Witness List Template Rev. 3-18-25 ===

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA PLAINTIFF’S NAME, et al., Case No. 0:00-cv-00000-CV (__x) Plaintiff/s, v. DEFENDANT’S NAME, et al., Defendant/s. [PLAINTIFF/DEFENDANT’S] WITNESS LIST [Judge Valenzuela’s Template] 1 Witness’s Name*, Title, Affiliation (If Relevant) Summary of Testimony / Why Testimony Is Unique Direct Exam (Hours) Cross Exam (Hours) Dates of Testimony Jane Doe, Supervisor, Employer, Inc. Will Testify what she saw at accident. Unique in that she is the only eyewitness 2 hours 1 hour [Leave blank. To be filled in during trial] *Indicates that witness will be called only if the need arises. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 2

=== Jury Questionnaire Template Rev. 3-18-25 ===

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA HON. CYNTHIA VALENZUELA UNITED STATES DISTRICT JUDGE JUROR QUESTIONNAIRE Instructions: Please read each question carefully. When it is your turn to answer questions, the court will ask you to respond out loud to questions 1 through 5. As to questions 6 through 18, please only respond to those for which your answer is “yes.” 1. What is your general area of residence? How long have you lived in that area? 2. What is your marital status? 3. What is your occupation? 4. What is the occupation of your spouse, former spouse, adult children, and any other adults living in your household? 5. Have you ever served on a jury? a. If so, how many times? b. Was it a criminal or civil case? c. d. e. Did you reach a verdict? (Please answer “yes” or “no.” Do not tell us the verdict.) If it was a civil case, what were the claims against the parties? If it was a criminal case, what were the charges against the defendant? 6. 7. Do you know any of the witnesses in this case or recognize any of their names? Do you know the judge, any of the court staff, the plaintiff(s), the defendant(s), the attorney(s) involved in this case, or anyone else you see in the courtroom? 8. Have you or anyone close to you had any legal training or experience? 1 9. Have you or anyone close to you ever been involved in any civil or criminal case as a plaintiff, defendant, or witness? 10. Have you, any family member, or close friend had any training or experience in law enforcement, either professionally or as a volunteer? 11. Have you or anyone close to you ever been arrested for, charged with, or convicted of a crime? 12. Have you or anyone close to you ever been the victim of a crime? 13. Do you or anyone close to you have frequent contact with individuals involved in the criminal justice system, including prosecutors, criminal defense attorneys, judges, courtroom personnel, probation officers, and correctional officers? 14. [Case-specific questions.] 15. Will you have any difficulty following the law as given to you by the judge, even if you may disagree with it? 16. Is there anything about the nature of this case that would make you favor one side or the other, or which might make it difficult for you to sit as a juror in this case? 17. Do you belong to any group or organization that takes a stand on any issue related to this case? 18. Is there any reason you cannot be a fair and impartial juror in this case? 2

=== Judge Valenzuela's Law Student Externship Posting.pdf ===

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION 350 WEST FIRST STREET, SUITE 4311 LOS ANGELES, CALIFORNIA 90012-4565 CHAMBERS OF CYNTHIA VALENZUELA UNITED STATES DISTRICT JUDGE Re: Judge Cynthia Valenzuela Law Student Externship Posting Judge Cynthia Valenzuela of the United States District Court for the Central District of California hires law student externs for the Spring, Summer, and Fall terms every year. The positions coincide approximately with the academic calendar as described in further detail below. Externships are fully in person, as we are unable to accommodate requests for remote externships at this time. All externships are full time positions. The externship is unpaid, as the Court lacks funding to pay externs. Judge Valenzuela is seeking externs with strong research and writing skills, who are passionate about the law, willing to learn, and dedicated to improving our justice system. Those with a demonstrated commitment to public service are encouraged to apply. Externs will work closely with the law clerks and Judge Valenzuela, and will have the opportunity to draft orders, perform substantive legal research and writing, assist the judge and law clerks in preparation for hearings, and observe criminal and civil hearings and trials. The timelines for each semester are below. Specific start and end dates may be adjusted in some circumstances. Applications are considered on a rolling basis beginning on the dates applications open as described above, and students are encouraged to apply promptly after the applications open. There is no hard deadline to apply, but Judge Valenzuela will cease reviewing applications after all spots have been filled. The likely timeline for when hiring decisions will be made is listed below.  Spring Externship: o Applications open: first week of October o Final decisions on hiring: likely mid-November o Externship dates: third week of January – third week of April  Summer Externship: o Applications open: second week of December o Final decisions on hiring: likely mid-February o Externship dates: third week of May – second week of August  Fall Externship o Applications open: first week of May o Final decisions on hiring: likely mid-June o Externship dates: third week of August – third week of November Interested applicants must submit the following materials in PDF format to [email protected]:  Cover letter: Please indicate the term for which you are applying  Resume  Transcript (even if unofficial)  Writing sample (five to ten pages in length) If you require an accommodation for any part of this process, please contact Judge Valenzuela’s Chambers at [email protected].