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Court Rules
Judge

Judge Khymberli S. Apaloo

Individual Rules, Standing Orders & Policies

San Bernardino Superior Court

Limits & Logistics

Document Limits

Mediation BriefCourt-wide
10 pgs

Courtesy Copies

Civil Unlimited Complaint

Court-wide
  • 1 copy

Adjournments

Court-wide

Request must include

Reason for Request
2Court Daysnotice
Reason for Request

Communication

Clerk1 contacts

Filters:

Document Format Requirements2 rules

Formatting

All Motions in Limine shall be in writing and filed with this Department and with service completed at least eight (8) days prior to the conference, and shall comply with Local Rule 415.

Applies to
  • Motions in limine

Formatting

  • Must be in writing
s25mscandtrialorders · p. 1|SectionMotions In Limine
Formatting

Exhibits shall be placed in a 3-ring binder with 1 set for the Court, 1 set for the witness and 1 set for each party.

Binding
Three-ring binder
Applies to
  • Exhibits

Formatting

  • 1 set for the Court
  • 1 set for the witness
  • 1 set for each party
s25mscandtrialorders · p. 1|SectionExhibits

Filing & Service rules

Filing Timing and Cure Windows

At least five days before the Mandatory Settlement Conference, MSC Briefs containing the four CRC 3.1380 elements must be filed directly in Department S-25 and served on opposing parties.

No less than five (5) days prior to the Settlement Conference, MSC Briefs must be filed directly in Department S-25 and served on opposing parties that include all four (4) elements enumerated in CRC 3.1380, including, but not limited to settlement discussions.

Page 1 | Mandatory Settlement Conference

Defendant's jury instructions must be filed on the first day of trial and should contain only additional instructions and objections to Plaintiff's instructions.

Defendant's jury instructions are due filed on the first day of trial and should only include **additional instructions** not previously submitted by Plaintiff and a list of **objections** to Plaintiff's instructions.

Page 1 | Jury Instructions

Plaintiff must submit a complete set of jury instructions with a generic pleading cover sheet and an itemized list of CACI and special instructions no later than three days before the Trial Readiness Conference.

No less than 3 days prior to the TRC, Plaintiff shall submit, in compliance with **CRC Rule 2.1055**, a complete set of jury instructions (with a generic pleading cover sheet) with an itemized list of the CACI Instructions and Special Instructions, if any.

Page 1 | Jury Instructions

At least three court days before the Trial Readiness Conference, the parties must file the listed opposition, instruction, verdict, witness, exhibit, voir dire, statement, and bench-trial brief materials.

No less than three (3) court days prior to the TRC, the parties shall file in this Department: 1) Any oppositions to Motions *in limine*, 2) Jury Instructions, as set forth below, 3) Proposed verdict forms, 4) Witness and Exhibit lists (Exhibits listed in **numerical order only**, in the anticipated order of presentation) 5) Any proposed *voir dire* questions and/or questionnaires, 6) A brief Statement of the Case to be read to the jury, if applicable and 7) A trial brief (for bench trials only, per Local Rule 411).

Page 1 | Trial Readiness Conference

Service and Proof of Service Rules

Service of a motion in limine must be completed at least eight days before the conference.

All Motions in Limine shall be in writing and filed with this Department and with service completed at least eight (8) days prior to the conference, and shall comply with Local Rule 415.

Page 1 | Motions In Limine

Filing Bundling Requirements

Documents should be jointly submitted.

Documents should be jointly submitted.

Page 1 | Trial Readiness Conference

Court-wide rules

Applies court-wide

These 248 rules apply across San Bernardino Superior Court. Where this judge's own standing orders above address the same topic, the judge's requirement controls.

Filing Requirements

All 129
  • Applies to
    Appointed attorney written report

    Every court-appointed attorney must file a verified written report stating bar status and disciplinary history, professional liability coverage, and prior representations, including the represented party's name and an explanation of the representation; reports for private professional conservators or fiduciaries must be included.

  • Applies to
    Stipulation

    All interested persons must sign the written stipulation.

  • Applies to
    Final account

    If there is a pour-over will or distribution to a trust, the entire subject trust instrument and its amendments, attachments, schedules, and exhibits must be filed.

Filing Timing

All 36
  • Deadline
    5 business days

    IFHMB must receive the mediation request form at least five business days before the court-noticed mediation date.

  • The parties must immediately notify the court and file the Notice of Settlement after settling the case.

  • The debtor must promptly file the Notice of Stay after removal to bankruptcy court.

Service

All 33
  • Applies to
    Mediation brief
    Service
    Email

    Mediation briefs are not required.  If you choose to submit a mediation brief, the limit is 10 pages, including all photos and exhibits, and must be sent to mhill@ifhmb.com and amartin@ifhmb.com at least 5 days before the mediation.

  • Applies to
    Motion or oraps

    A proof of service must be filed at least 10 days before the examination for motions or ORAPS to avoid removal from the calendar.

  • Applies to
    Initial trial setting conference statement

    The Initial Trial Setting Conference Statement must be served no later than 10 days before the conference.

Adjournments

All 13

  • A continuance of the first-set trial date must be requested by a written stipulation of all parties, without an ex parte application, filed at least 15 days before the trial date.

  • Requests for continuances are governed by California Rule of Court, Rule 3.1332.

  • A party seeking a continuance or not intending to proceed must notify the Judicial Assistant and opposing counsel as soon as possible and no later than 4:30 p.m. on the second court day before the hearing.

More categories

View all San Bernardino Superior Court rules
About Judge Khymberli S. Apaloo

Department S25, San Bernardino Justice Center, 247 W. Third Street, San Bernardino, CA. 92415

Common questions about Judge Khymberli S. Apaloo's rules

What formatting rules apply to filings before Judge Khymberli S. Apaloo?

Judge Khymberli S. Apaloo's formatting rule includes binding three ring binder, 1 set for the court, 1 set for the witness, and 1 set for each party. Trial exhibits must be placed in three-ring binders containing one set for the court, one for the witness, and one for each party.

View ruleSource: page 1, section Exhibits

Does Judge Khymberli S. Apaloo require motion papers to be bundled?

Bundling is encouraged for covered papers before Judge Khymberli S. Apaloo. Documents should be jointly submitted.

View ruleSource: page 1, section Trial Readiness Conference

What filing deadlines does Judge Khymberli S. Apaloo set?

At least five days before the Mandatory Settlement Conference, MSC Briefs containing the four CRC 3.1380 elements must be filed directly in Department S-25 and served on opposing parties.

View ruleSource: page 1, section Mandatory Settlement Conference

What rule applies to service for motion in limine before Judge Khymberli S. Apaloo?

Service of a motion in limine must be completed at least eight days before the conference.

View ruleSource: page 1, section Motions In Limine
Complete rules summary for Judge Khymberli S. Apaloo

At least five days before the Mandatory Settlement Conference, MSC Briefs containing the four CRC 3.1380 elements must be filed directly in Department S-25 and served on opposing parties.

Motions in limine must be written, comply with Local Rule 415, and be filed in the department at least eight days before the conference.

At least three court days before the Trial Readiness Conference, the parties must file the listed opposition, instruction, verdict, witness, exhibit, voir dire, statement, and bench-trial brief materials.

Defendant's jury instructions must be filed on the first day of trial and should contain only additional instructions and objections to Plaintiff's instructions.

Plaintiff must submit a complete set of jury instructions with a generic pleading cover sheet and an itemized list of CACI and special instructions no later than three days before the Trial Readiness Conference.

Documents should be jointly submitted.

Trial exhibits must be placed in three-ring binders containing one set for the court, one for the witness, and one for each party.

Service of a motion in limine must be completed at least eight days before the conference.

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