Judge A. Ashley Tabaddor
Individual Rules, Standing Orders & Policies
Communication
Document Format Requirements1 rule
In matters involving lengthy exhibits, business records, contracts, account statements, or other voluminous documentary evidence, parties should Bates stamp all exhibit pages using a single, consecutive numbering sequence throughout the entire submission, rather than restarting the numbering with each exhibit.
- Exhibits
- Business records
- Contracts
- Account statements
Formatting
- •Do not restart numbering with each exhibit
Document Filing Requirements6 rules
All pleadings, motions, applications, stipulations, requests, proposed orders, and other filings should clearly and specifically identify the relief sought in both the title of the filing and, where appropriate, the accompanying proposed order. Generic titles such as "Motion," "Application," “Declaration” or "Request" should be avoided. Instead, the title should describe the specific relief requested.
Declarations, memoranda, and briefs should cite specific Bates-numbered pages supporting each factual assertion instead of referencing an exhibit as a whole.
Court's wording
Declarations, memoranda, and briefs should cite to the specific Bates-numbered pages supporting each factual assertion rather than making generalized references to an entire exhibit. For example, instead of stating that "the account statement is attached as Exhibit A," the declaration should identify the precise pages, such as "Exhibit A, Bates Nos. 0012-0015," rather than simply referring to the exhibit as a whole.
Filings containing multiple exhibits should also include a table of contents identifying each exhibit and the corresponding Bates-number range (or beginning Bates number) for that exhibit.
- Document
- Filing with multiple exhibits
Should include
- •Table of contents
exchange trial documents sufficiently in advance of trial to permit meaningful review and preparation. Such submissions should identify the anticipated trial witnesses and include the proposed trial exhibits.
The parties should also submit a Memorandum of Costs and a Proposed Judgment. The parties may submit a trial brief for the Court's review.
- Document
- Trial submission
Should include
- •Proposed order
Individuals requiring accommodations should notify the courtroom as early as practicable. Requests may be submitted using Judicial Council Form MC-410 or any other written request sufficient to advise the Court of the accommodation sought.
Filing & Service rules
Service and Proof of Service Rules
Parties should not submit documents, correspondence, or other materials to the Court that have not first been served on all other appearing parties, except as expressly authorized by law or court rule. Unserved communications may constitute an improper ex parte communication. As a general practice, materials that have not been served on all parties will not be presented to the judicial officer for consideration and may be disregarded or otherwise disposed of without review.
Parties should not submit documents, correspondence, or other materials to the Court that have not first been served on all other appearing parties, except as expressly authorized by law or court rule. Unserved communications may constitute an improper ex parte communication. As a general practice, materials that have not been served on all parties will not be presented to the judicial officer for consideration and may be disregarded or otherwise disposed of without review.
Page 4 | B. Proper Service of Filings
The Court cannot consider any filing unless it has been properly served under the applicable statutes and rules of court.
The Court cannot consider a filing unless it has been properly served in accordance with the applicable statutes and rules of court.
Page 4 | B. Proper Service of Filings
Parties should carefully review proofs of service to ensure they accurately identify the documents served, the method of service, the persons served, and the correct service addresses. Defective or incomplete proofs of service may delay consideration of the requested relief or require the matter to be continued or denied without prejudice.
Parties should carefully review proofs of service to ensure they accurately identify the documents served, the method of service, the persons served, and the correct service addresses. Defective or incomplete proofs of service may delay consideration of the requested relief or require the matter to be continued or denied without prejudice.
Page 4 | B. Proper Service of Filings
Counsel should file the proof of service concurrently with the document being served whenever possible.
Whenever possible, counsel should file the proof of service concurrently with the document being served.
Page 4 | B. Proper Service of Filings
Collections trials may proceed based on the submission and timely service of a CCP § 98 declaration, party stipulations, or defendant's admissions.
Collections trials can proceed with live witnesses (in person or remote) and evidence, based on the submission and timely service of a California Code of Civil Procedure § 98 Declaration, via stipulations of the parties when both are present, or based on admissions made by Defendant in the pleadings or in discovery.
Page 5 | X. TRIAL PROCEDURES
Filing Fees and Waivers
The Court may decline to award filing fees and related expenses for a summary judgment motion as recoverable costs if they were not reasonably necessary under CCP § 1033.5.
In determining recoverable costs following judgment, the Court will independently evaluate whether the filing fee and related expenses associated with a summary judgment motion were reasonably necessary to the conduct of the litigation. The Court may decline to award such costs where they were not reasonably necessary within the meaning of Code of Civil Procedure section 1033.5.
Page 5 | IX. MOTIONS FOR SUMMARY JUDGMENT
Chambers Communication Rules
Each party must promptly notify the Court and all other parties of any change in mailing address or other contact information, an obligation especially important for self-represented litigants.
It is each party's responsibility to promptly notify the Court and all other parties of any change in mailing address or other contact information. This obligation is especially important for self-represented litigants, who are responsible for ensuring that they receive all notices and communications regarding their case.
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Counsel and self-represented litigants are encouraged to ensure the Court has their current email address so the Court can reach them regarding scheduling or matters requiring immediate attention.
The Court occasionally must communicate with counsel or parties regarding scheduling or other matters requiring immediate attention. Counsel and all self-represented litigants are encouraged to ensure that the Court has current email addresses and direct telephone numbers whenever available.
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