Judge Michael Valenzuela
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Deposition Transcript, Objections, Response Chart
Emergency Pleading
Exhibits
Jury Exhibit Notebook
Communication
Chambers
Phone
Chambers
Phone
Chambers
Page & Word Limits2 rules
Motions in Limine are to be no more than four pages in length and responses are to be no more than four pages in length.
- Motion in limine
- Up to 4 pages
- Response
- Up to 4 pages
Page limits will not be exceeded without leave of Court.
Document Format Requirements5 rules
Motions or stipulations shall be filed with a proposed order in Word format.
- File type
- Word
- Proposed order
Motions, responses, and related pleadings shall comply with the page length, font type, and other requirements set by the Rules.
The Court has the capability of conducting a "hybrid" hearing, such that some participants can be in the courtroom, and others can be participating virtually.
Formatting
- •Hybrid hearings may include both in-person and virtual participants
However, video appearance is the preference of the Court.
The Court will provide extended Wi-Fi access for all jury trials.
Document Filing Requirements64 rules
If a proposed order is applicable to the motion, and it is not submitted with the motion, the Court reserves the right to reject the motion until it is accompanied by a proposed form of order.
Motions or stipulations shall be filed with a proposed order in Word format.
- Document
- Motion or stipulation
Must include
- •Proposed order
The Court will not schedule, reschedule, or vacate hearings without the filing of a proper motion.
The Court requires a written motion or stipulation to schedule, reschedule, or vacate hearings.
In all cases, a further prerequisite to setting a Trial or Evidentiary Hearing is that all discovery shall be completed. Completion of discovery includes resolution of all discovery disputes.
All counsel and parties should be vigilant to ensure that no witnesses enter the courtroom, or dial-in or link-in to the courtroom while other witnesses are testifying, which is a violation of the rule.
In the event evidence or testimony is objected to on the basis of non-disclosure or untimely disclosure, the parties must be prepared to demonstrate compliance or non-compliance with Rule 26.1.
Objections should be short and succinct.
Motions in Limine should not be filed in bench trials without leave of Court.
For admitted lengthy exhibits, the Court considers only the portions referenced during the hearing or trial.
Court's wording
If the Court admits lengthier exhibits, such as bank statements, medical records, etc., the Court will only consider those specific portions of the exhibits that are referenced during the hearing or trial.
Confirm all facts are true and supported by evidence in the record.
The Court may sanction a party that makes unfounded disclosure objections as well.
This applies equally to depositions that have been submitted but not filed as exhibits.
The parties will need to comply with Rule 8(c) and (d) to effectuate such a request.
When the Rule of Exclusion, Ariz. R. Evid. 615, has been invoked, all counsel should inform the witnesses of its invocation and meaning.
Objections should be stated only as legal objections (e.g. "hearsay") and not as speaking objections.
Lawyers and parties are expected to act respectfully and professionally, and specified forms of harassment, bias, and prejudice are prohibited.
Court's wording
The Court expects lawyers and all parties to treat each other, opposing parties, court staff, and everyone with respect and professionalism. Harassment, bias, or prejudice on the basis of race, sex, gender, religion, national origin, ethnicity, disability, age, sexual orientation, marital status, socioeconomic status, or affiliation is strictly prohibited.
Independently and carefully verify every citation and legal authority using official or reliable legal sources. Again, the party using AI is responsible for false citations.
The Court will not grant blanket admission of exhibits, even if counsel stipulate to their admission.
The Court will only consider those portions of a deposition to which the party has specifically referred during the trial or hearing.
Motions in Limine should address only matters that are extremely prejudicial and could result in a mistrial.
All cell phones must remain silent and on "do not disturb" mode.
This is usually done by showing disclosure statements, emails, or other relevant documents. The parties must have them available in the courtroom.
No cameras are allowed in the courtroom, absent court order.
Water, coffee and other beverages are allowed, however, no food or chewing gum is permitted in the courtroom.
Motions in Limine asking the Court to enforce a particular rule of evidence should not be filed.
The Court permits only one Motion for Summary Judgment per party absent leave of Court for good cause shown.
Hearings begin on schedule, and parties are generally held to their allotted time except in extraordinary circumstances.
Court's wording
Be on time for your hearing. The Court will start the clock at the scheduled time, whether the parties are present or not. Budget your time and finish on time. Except in extraordinary circumstances, you will be held to your allotted time, even if you are in the middle of cross-examination. You will know beforehand how much time has been allotted to you. The Court will occasionally notify you of your remaining time, but you may ask at any time for a time check.
No speaking objections are allowed.
A party who is irresponsible with the use of these tools, or (worse) knowingly submits pleadings with non-existent facts/caselaw, shall be subject to sanctions.
Pursuant to Rule 611(a) of the Rules of Evidence, the Court limits redirect examination of a witness to issues that were raised during cross-examination of that witness.
Counsel will need to separately offer any exhibits that are relevant to the case.
No party should file supplemental briefing without leave of Court.
Trials and Evidentiary Hearings: Rule 8(c), (d), (e), and (f) will apply.
The Court expects filers using AI to:
If you file a motion for leave to exceed the page length of a pleading, you will need to provide specific reasons. A generic statement that you need more pages may result in denial of your motion.
If the Court deems the speaking objection to be unduly long, it may assess time against the objecting party.
The Court expects the parties to complete trial within the time allotted.
The Court may overrule an objection for untimely disclosure or non-disclosure if no documentary evidence is provided.
If a party asserts that the disclosure came in a deposition, then that party must be prepared to point to the relevant portion of the deposition.
A party defending against a disclosure challenge must be prepared to immediately show the Court where and when that party disclosed the relevant subject matter.
Anyone who records or photographs court hearings without prior approval may be subject to involvement with security and/or contempt proceedings.
The Court will not review the entire exhibit to try to locate a relevant portion. You will have to tell the Court where you want it to look.
Absent leave of Court for good cause shown, each party may file no more than five Motions in Limine.
The calendar begins at 9:00 a.m. unless specified and ends at 4:30 p.m.
There will be a 10-minute mid-morning break and a 10-minute mid-afternoon break during trial.
If the Court wants a response or further discussion, the Court will ask.
When calling a virtual witness during a trial or hearing, please ensure you or co-counsel are in communication with the witness, so they are aware of when to connect to the virtual proceeding.
Please note that court employed court reporters are assigned first to Rule 30 mandated criminal matters. Therefore, obtaining a court employed court reporter for a civil matter is not always possible.
Counsel may move around the courtroom, however, should request permission to approach the witness.
A record of all court proceedings is made using an audio/video recording system and through Microsoft Teams.
The parties are therefore, encouraged to utilize a private court reporter and may file a Notice of Intent to use a private court reporter.
Typically, when scheduling trial, the Court will defer to the parties concerning the amount of courtroom time the parties require to adequately present their respective cases.
Generally, each side will be allotted half of the time to present their case.
The Court breaks for lunch daily from noon to 1:30 p.m.
The Court still reserves its discretion to set the amount of trial time.
Trial begins at 8:30 a.m. on Jury Selection Day.
Tell the AI tool to provide only real and verifiable citations with links to the cases when possible.
Although this section pertains to "Trial Practice," these protocols apply to any trial or evidentiary hearing.
The Court sets oral arguments for a specific period of time, and the parties will usually receive equal time within that period.
The Court will typically seat 8-10 jurors and counsel are asked to seriously consider having the alternate deliberate.
Trials are held Tuesday through Friday from 9:30 a.m. to 4:30 p.m.
Counsel is provided a short period of time to ask follow-up questions. This generally should not exceed 15 to 30 minutes.
Filing & Service rules
Electronic Filing Rules
All exhibits must be submitted through Case Center.
All exhibits must be submitted through Case Center.
Civil cases
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections
Each party must register with Case Center at the listed website.
Each party must register with Case Center at: https://digitalevidence.azcourts.gov.
Civil cases
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections
Filing Timing and Cure Windows
Interpreter requests for people with limited English proficiency must be made 10 days before the hearing.
Requests for an interpreter for persons with limited English proficiency must be made 10 days in advance of the hearing.
Civil cases
Page 1 | Other Courtroom Policies and Recommendations
Requests for disability accommodations must be made five days before the hearing.
Requests for reasonable accommodations for persons with disabilities must be made five days before the hearing.
Civil cases
Page 1 | Other Courtroom Policies and Recommendations
A party requesting a court reporter must file a Request for Court Reporter 10 days before the hearing.
However, if a party prefers the presence of a court reporter, a "Request for Court Reporter" must be filed 10 days before the hearing.
Civil cases
Page 1 | Other Courtroom Policies and Recommendations
Motions to strike are strongly discouraged; parties should instead raise the point in a responsive pleading within 10 days.
Motions to Strike are strongly discouraged and often are not even countenanced by the Rules. Make your point in your responsive pleading within 10 days.
Civil cases
Page 1 | Motion Practice
Non-emergency filings are addressed in the normal course within 1 to 2 business days.
Non-emergency filings will be addressed in the normal course (1 to 2 business days).
Civil cases
Page 1 | Specific Requirements or Preferences
Filing Fees and Waivers
The court reporter deposit, usually the cost of the first day, must be paid no later than two judicial days before the hearing.
The party must pay the court reporter's deposit (usually the cost of the first day) no later than two judicial days before the hearing.
Civil cases
Page 1 | Other Courtroom Policies and Recommendations
Court reporter rates for a minimum half-day and full day are available on the Court’s website.
The cost for a minimum half day and for a full day are available on the Court's website.
Civil cases
Page 1 | Other Courtroom Policies and Recommendations
Courtesy Copy Requirements
Special requests must be filed and an emailed courtesy copy sent to the Division.
All special requests must be in filed and a courtesy copy emailed to the Division: CVJ21@JBAZMC.MARICOPA.GOV
Civil cases
Page 1 | Other Courtroom Policies and Recommendations
The Court does not use bench copies of exhibits.
The Court does not use bench copies of exhibits.
Civil cases
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections
Courtesy hard copies are not required for pleadings, except for deposition designations under the Trial Setting Minute Entry procedure.
Judge Valenzuela does not require courtesy hard copies of any pleading, unless you are submitting deposition designations per the procedure noted in the Trial Setting Minute Entry.
Civil cases
Page 1 | Motion Practice
Do not email courtesy copies of non-emergency pleadings.
Please do not email courtesy copies of non-emergency pleadings, as this will overload the email system and delay the time to respond to emergencies.
Civil cases
Page 1 | Specific Requirements or Preferences
The Court does not use jury exhibit notebooks.
The Court does not use jury exhibit notebooks.
Civil cases
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections
The Court accepts emailed courtesy copies of emergency pleadings, but generally rules only on properly filed pleadings outside true emergencies.
The Court will accept a courtesy copy of emergency pleadings by email. Except in true emergency situations, the Court will rule only on properly filed pleadings.
Civil cases
Page 1 | Specific Requirements or Preferences
For deposition designations under the specified procedure, paper copies of designated transcripts with objections and response charts or annotations are helpful.
Only then are paper copies of designated deposition transcripts with objections and response charts/annotations helpful.
Civil cases
Page 1 | Motion Practice
Filing Bundling Requirements
Motions, responses, replies, and other court-requested filings must be submitted individually; combined filings and omnibus motions will not be accepted.
The Division requires that all motions, responses, replies, and other Court requested filings in this case be submitted individually. Do not combine any motion with a responsive pleading (No omnibus motions). All motions are to be filed separately and designated as such. No pleadings will be accepted if filed in combination with another.
Civil cases
Page 1 | Motion Practice
Pre-Motion Conference Requirements
The Court may permit full briefing under Rule 26(d)(1), but parties may not undertake full briefing without advance permission.
The Court may decide to later permit full briefing under Ariz. R. Civ. P. 26(d)(1), but the parties may not engage in full briefing without the advance permission of the Court.
Civil cases
Page 1 | Discovery or Disclosure Disputes and/or Sanctions
The Division requires strict compliance with Arizona Rule of Civil Procedure 26(d) for discovery and disclosure disputes.
This Division requires strict compliance with Ariz. R. Civ. P. 26(d), the Expedited Procedure for Resolving Discovery and Disclosure Disputes.
Civil cases
Page 1 | Discovery or Disclosure Disputes and/or Sanctions
Disputes suitable for Rule 26(c) protective orders or Rule 37(a) motions to compel must first proceed under Rule 26(d).
All disputes between parties that could be addressed in motions for protective order under Rule 26(c) or motions to compel discovery or disclosure under Rule 37(a) must first proceed pursuant to Rule 26(d).
Civil cases
Page 1 | Discovery or Disclosure Disputes and/or Sanctions
Full briefing on a discovery or disclosure dispute without advance Court permission may result in summary denial of the motion.
Attempted full briefing without advance permission of the Court subjects any such motion by a party to summary denial.
Civil cases
Page 1 | Discovery or Disclosure Disputes and/or Sanctions
The Court expects parties to attempt settlement before trial.
The Court expects the parties to have attempted settlement prior to trial.
Civil cases
Page 1 | Other Pre-trial Practice Guidelines or Comments
Replies are not permitted for motions in limine.
There are no replies.
Civil cases
Page 1 | Motion Practice
For substantive evidentiary hearings or oral arguments not set during a hearing, the Court will schedule a virtual status conference to set the date and time.
In regard to any substantive evidentiary hearings or oral arguments that are not set during a hearing, the Court will set a virtual status conference in order to schedule a date and time for the substantive hearing.
Civil cases
Page 1 | Motion Practice
The Court will schedule oral argument if it believes argument may assist in deciding the matter.
If the Court believes that oral argument may assist in making a decision, the Court will schedule one.
Civil cases
Page 1 | Motion Practice
Adjournment & Extension Requirements
The Court generally denies same-day requests for additional trial time unless parties acted in good faith, used their allotted time appropriately, and still need time to fairly present evidence.
Generally, the Court will deny a request for additional trial time on the day of trial unless the parties have acted in good faith, made appropriate use of the time allotted, and still require additional time to fairly present evidence to the Court.
Civil cases
Page 1 | Other Pre-trial Practice Guidelines or Comments
If additional trial time is granted, the trial may be continued to a later date.
If additional time is granted, the trial may likely be continued to a later date.
Civil cases
Page 1 | Other Pre-trial Practice Guidelines or Comments
For an extension of response or reply time, parties are encouraged to seek agreement and submit a stipulation.
If an extension of response or reply time is necessary, try to reach an agreement among the parties, and submit a stipulation.
Civil cases
Page 1 | Motion Practice
Chambers Communication Rules
Ex parte emails will be deleted without action.
Emails that are ex parte will be deleted with no further action taken.
Civil cases
Page 1 | Specific Requirements or Preferences
After settling, parties should immediately notify the Court and email Court staff the stipulated Notice of Settlement so the trial or hearing can be vacated.
If you settle your case, please notify the Court immediately and send Court Staff an email with your stipulated Notice of Settlement, so the Court can vacate the trial/hearing.
Civil cases
Page 1 | Other Pre-trial Practice Guidelines or Comments
Court staff respond only to urgent matters and emergencies, in the order received.
Due to a high volume of emails received daily, Court staff will only respond to urgent matters and emergencies, and in the order that they were received.
Civil cases
Page 1 | Specific Requirements or Preferences
If a participant has technical difficulties appearing by video, the participant may appear by phone using the listed number and conference ID.
If you have technical difficulties appearing by video, you may appear by phone by dialing: 1 917-781-4590 Conference ID: 105 414 319#
Civil cases
Page 1 | Specific Requirements or Preferences
If you need assistance with the electronic equipment, please schedule an appointment with the Courtroom Assistant.
If you need assistance with the electronic equipment, please schedule an appointment with the Courtroom Assistant.
Civil cases
Page 1 | Other Courtroom Policies and Recommendations
Contact Electronic Recording Services to order an audio/video recording after a hearing.
To order a copy of the audio/video recording after a hearing, please contact Electronic Recording Services. https://superiorcourt.maricopa.gov/court-resources/services/for-the-record/
Civil cases
Page 1 | Other Courtroom Policies and Recommendations
The Division’s email address is CVJ21@JBAZMC.Maricopa.gov.
The Division’s email address is: CVJ21@JBAZMC.Maricopa.gov
Civil cases
Page 1 | Specific Requirements or Preferences
The Division may be contacted by phone at 602-372-5812.
Judge Valenzuela’s Division may be reached by phone at 602-372-5812.
Civil cases
Page 1 | Specific Requirements or Preferences
The courtroom clerk will email a case-specific link for uploading exhibits to each party or attorney of record.
The courtroom clerk will email each party (or attorney of record) a case-specific link that the party will use to upload exhibits.
Civil cases
Page 1 | Joint Pre-Trial Memo and/or Conference; Exhibits and Objections