Judge Phu Nguyen
Individual Rules, Standing Orders & Policies
Document Format Requirements5 rules
Exhibits must be pre-numbered, exchanged (except impeachment exhibits), placed in tabbed three-ring binders with party-specific numbering and no letter designations.
- Binding
- Tabbed three-ring binder
- Exhibit
Formatting
- •Pre-numbered (1, 2, 3, etc.)
- •Plaintiffs use Exhibit 1+ numbering, defendants use Exhibit 101+ numbering
- •No letters for exhibit numbers or subparts
- •Separate documents may not be grouped as a single exhibit or subpart
Exception
Those anticipated in good faith to be used for impeachment
Court's wording
2. Exhibits. All Exhibits must be pre-numbered (1, 2, 3, etc.) and exchanged except for those anticipated in good faith to be used for impeachment. (Rule 3.52.) The Parties shall place exhibits in three ring binders, with tabs to separate each exhibit. There shall be a binder for each party, the Court Clerk, the Judge and the witness stand. In a typical two-party case this shall require 5 separate, fully numbered and tabbed exhibit binders. Plaintiffs shall number exhibits beginning with Exhibit 1 and Defendants shall number exhibits beginning with Exhibit 101. Letters shall not be used. Letters shall not be used to designate subparts. Each separate exhibit shall bear only a numeric designation. (Rule 3.53.) Multiple page exhibits shall have page numbers on each page so as to facilitate reference to the document during interrogation of the witnesses. Separate documents shall not be grouped together as one exhibit or as subparts to one exhibit. Each shall be separately numbered.
The Parties shall place exhibits in three ring binders, with tabs to separate each exhibit. There shall be a binder for each party, the Court Clerk, the Judge and the witness stand. In a typical two-party case this shall require 5 separate, fully numbered and tabbed exhibit binders.
- Binding
- Tabbed three-ring binder
- Exhibits
Plaintiffs shall number exhibits beginning with Exhibit 1 and Defendants shall number exhibits beginning with Exhibit 101. Letters shall not be used. Letters shall not be used to designate subparts. Each separate exhibit shall bear only a numeric designation. (Rule 3.53.)
- Exhibits
Formatting
- •Plaintiff exhibits are numbered beginning with Exhibit 1
- •Defendant exhibits are numbered beginning with Exhibit 101
Separate documents shall not be grouped together as one exhibit or as subparts to one exhibit. Each shall be separately numbered.
Multiple page exhibits shall have page numbers on each page so as to facilitate reference to the document during interrogation of the witnesses.
Document Filing Requirements6 rules
Counsel must prepare and submit proposed jury instructions, meet and confer, and identify which instructions are agreed and which are disputed (with legal briefs encouraged for disputed instructions).
Court's wording
Counsel shall prepare and submit proposed jury instructions. (See C.C.P. § 607a.) Counsel shall meet and confer in an attempt to reach agreement on the proposed jury instructions. Counsel must identify those jury instructions that they agree shall be given and shall identify those proposed instructions as to which there is disagreement. As to disputed proposed instructions the parties are encouraged to submit legal briefs setting forth the legal basis for the request and objection.
Documents required by Paragraph 15 of the Fifth Amended Standing Order must be prepared before the first trial date.
Court's wording
Counsel shall fully comply with the Standing Order (Fifth Amended Standing Order (effective as of June 1, 2021)) as it relates to trials, paragraphs 14, 15, 16 and 17. All documents required by Paragraph 15 of the Standing Order shall be prepared in advance of the first trial date.
Counsel must prepare, submit, and meet and confer on proposed jury instructions, identifying agreed and disputed instructions; briefs for disputed instructions are encouraged.
Court's wording
3. Jury Instructions and Verdict Form: Counsel shall prepare and submit proposed jury instructions. (See C.C.P. § 607a.) Counsel shall meet and confer in an attempt to reach agreement on the proposed jury instructions. Counsel must identify those jury instructions that they agree shall be given and shall identify those proposed instructions as to which there is disagreement. As to disputed proposed instructions the parties are encouraged to submit legal briefs setting forth the legal basis for the request and objection.
5. In Limine Motions. All Motions in limine must be in writing and be accompanied by a declaration in compliance with Local Rule 3.57.
All Motions in limine must be in writing and be accompanied by a declaration in compliance with Local Rule 3.57.
Trial briefs are encouraged but not required. In cases where an issue is not typical or may be technical in nature, the parties should prepare trial briefs that address important issues in the case.
Filing & Service rules
Filing Timing and Cure Windows
Counsel must comply with Standing Order paragraphs 14-17, and all documents required by Paragraph 15 of the Standing Order must be prepared in advance of the first trial date.
Counsel shall fully comply with the Standing Order (Fifth Amended Standing Order (effective as of June 1, 2021)) as it relates to trials, paragraphs 14, 15, 16 and 17. All documents required by Paragraph 15 of the Standing Order shall be prepared in advance of the first trial date.
Civil cases
Page 1 | Compliance with Rules for Civil Trial Procedure and Standing Order for Limited Jurisdiction Unlawful Detainer Cases
Service and Proof of Service Rules
All exhibits must be pre-numbered and exchanged between the parties, except exhibits anticipated in good faith to be used for impeachment.
All Exhibits must be pre-numbered (1, 2, 3, etc.) and exchanged except for those anticipated in good faith to be used for impeachment. (Rule 3.52.)
Civil cases
Page 1 | Exhibits