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Court Rules
Judge

Judge Lily L. Sinfield

Individual Rules, Standing Orders & Policies

Rules last changed:
San Bernardino Superior Court

Limits & Logistics

Document Limits

Informal Discovery Conference Answer
2 pgs
Informal Discovery Conference Request
2 pgs
Informal Discovery Conference Statement
2 pgs
Mediation BriefCourt-wide
10 pgs

Courtesy Copies

Joint Exhibit List

  • 2 copies

Joint Witness List

  • 2 copies

Civil Unlimited Complaint

Court-wide
  • 1 copy

Adjournments

Court-wide

Request must include

Reason for Request
2Court Daysnotice
Reason for Request
Filters:

Page & Word Limits3 rules

Page LimitsMandatoryCivil cases

Include a brief summary of why the requested relief should be denied (no longer than two pages);

Page limit
Up to 2 pages
s31idcstipulation
|SectionAny Answer to a Request for Informal Discovery Conference must
Page LimitsMandatoryCivil cases

An informal discovery conference statement must not exceed two pages.

Informal discovery conference statement
Up to 2 pages

Court's wording

For a Request for Informal Discovery Conference, briefly describe the nature of the discovery dispute, including the facts and legal arguments at issue. For an Answer to Request for Informal Discovery Conference, briefly describe why the Court should deny the requested discovery, including the facts and legal arguments at issue. (Do not attach more than two pages. File directly in S31, five days prior to the conference.)

s31idcrequestanswer
|SectionInformal Discovery Conference Statement
Page LimitsImportantCivil cases

Include a brief summary of the dispute and specify the relief requested. This should not consist of more than two pages;

Page limit
Up to 2 pages
s31idcstipulation
|SectionThe party requesting the Informal Discovery Conference will

Document Format Requirements6 rules

FormattingMandatoryCivil cases

On the date of the TRC, the parties shall bring with them, a three-ring Joint Trial Binder that contains the following, if applicable:

Binding
Three-ring binder
s31standingtrialorders · May 2024 · p. 1
|SectionI. JOINT TRIAL BINDER
FormattingMandatoryCivil cases

The parties shall meet, confer, and bring to Court on the first day of trial, two complete copies of the Joint Exhibit Binder.

s31standingtrialorders · May 2024 · p. 2
|SectionII. JOINT EXHIBIT BOOK
FormattingMandatoryCivil cases

No other pleadings, including but not limited to exhibits, declarations, or attachments, will be accepted, unless after receipt of the Request and Answer the Court requests it.

s31idcstipulation
|SectionAny Answer to a Request for Informal Discovery Conference must
FormattingMandatoryCivil cases

AI-assisted exhibits, demonstratives, and other court materials must identify the AI assistance in the title or caption, in a preceding table, and in a separate contemporaneously filed notice.

Applies to
  • Exhibits
  • Demonstratives

Formatting

  • AI assistance must be identified in the title or caption
  • A table identifying AI assistance must precede the body of the material

Court's wording

Any exhibit, demonstrative, or other material to be filed or presented to the Court which was created or drafted with any assistance or use of an AI tool shall be identified as such in its title or caption, in a table preceding the body of exhibit, demonstrative, or other material, and by a separate Notice filed contemporaneously with the document or material.

s31mscandtrialsettingorders · p. 4
|SectionTHE COURT FURTHER ORDERS AS FOLLOWS
FormattingImportantCivil cases

Each Exhibit shall be marked with a discrete number, and shall be correctly identified.

Applies to
  • Joint exhibit book

Formatting

  • Each exhibit must be marked with a discrete number and correctly identified
s31standingtrialorders · May 2024 · p. 2
|SectionII. JOINT EXHIBIT BOOK
FormattingImportantCivil cases

Exhibits shall be place in 3-ring binders with 1 copy for the Court, 1 for the witness and 1 for all other parties to the action.

Binding
Three-ring binder
Applies to
  • Exhibits
s31mscandtrialsettingorders · p. 1
|SectionTHE COURT FURTHER ORDERS AS FOLLOWS

Document Filing Requirements12 rules

Filing RequirementsMandatoryCivil cases

Joint Statement of the Case (if the parties do not anticipate giving mini-openings);

s31mscandtrialsettingorders · p. 1
|SectionTHE COURT FURTHER ORDERS AS FOLLOWS
Filing RequirementsMandatoryCivil cases

Joint exhibit list (Exhibits shall be pre-marked in numerical order and if multiple pates, date stamped at the bottom of each page;

s31mscandtrialsettingorders · p. 1
|SectionTHE COURT FURTHER ORDERS AS FOLLOWS
Filing RequirementsMandatoryCivil cases

Joint witness list with time estimates for direct examination, cross-examination, re-direct, and re-cross;

s31mscandtrialsettingorders · p. 1
|SectionTHE COURT FURTHER ORDERS AS FOLLOWS
Filing RequirementsMandatoryCivil cases

Trial briefs are required for bench trials.

s31mscandtrialsettingorders · p. 1
|SectionTHE COURT FURTHER ORDERS AS FOLLOWS
Filing RequirementsMandatoryCivil cases

No less than five (5) days prior to the Settlement Conference, MSC Briefs must be filed directly in Department S-31 and served on opposing parties that include all four (4) elements enumerated in CRC 3.1380, including, but not limited to settlement discussions.

s31mscandtrialsettingorders · p. 1
|SectionMANDATORY SETTLEMENT CONFERENCE
Filing RequirementsMandatoryCivil cases

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.

s31mscandtrialsettingorders · p. 1
|SectionTHE COURT FURTHER ORDERS AS FOLLOWS
Filing RequirementsMandatoryCivil cases

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.

s31mscandtrialsettingorders · p. 1
|SectionTHE COURT FURTHER ORDERS AS FOLLOWS
Filing RequirementsMandatoryCivil cases

Plaintiff's Jury Instructions/Special Verdict.

s31mscandtrialsettingorders · p. 1
|SectionTHE COURT FURTHER ORDERS AS FOLLOWS
Filing RequirementsMandatoryCivil cases

Counsel must contemporaneously serve a sufficiently specific notice identifying AI-generated evidentiary material when it is produced or disclosed, and untagged material will not be considered by the Court.

Document
AI-generated evidentiary material notice

Must include

  • AI disclosure

Court's wording

Contemporaneous with the production or disclosure of any such AI-generated evidentiary material, counsel shall serve a Notice to the opposing Party or side identifying such material with sufficient specificity to locate it (such as by Bates or production number, by attaching a copy to such Notice, by promptly responding to any request for counsel to provide a copy of such material, or by any other means which reasonably permits the other ===== PAGE 4 ===== Party or side to identify and locate the material promptly). Any such AI-generated material which does not have an accompanying Notice shall not be considered by the Court.

s31mscandtrialsettingorders · p. 4
|SectionTHE COURT FURTHER ORDERS AS FOLLOWS
Filing RequirementsMandatoryCivil cases

A separate notice identifying AI assistance must be filed contemporaneously with any AI-assisted exhibit, demonstrative, or other court material.

Document
AI-assistance notice

Must include

  • AI disclosure

Court's wording

Any exhibit, demonstrative, or other material to be filed or presented to the Court which was created or drafted with any assistance or use of an AI tool shall be identified as such in its title or caption, in a table preceding the body of exhibit, demonstrative, or other material, and by a separate Notice filed contemporaneously with the document or material.

s31mscandtrialsettingorders · p. 4
|SectionTHE COURT FURTHER ORDERS AS FOLLOWS
Filing RequirementsMandatoryCivil cases

Unless the parties stipulate or the court orders otherwise, authenticity declarations, affidavits, or sworn testimony must be filed and served when AI-generated material is submitted or filed.

Court's wording

Absent stipulation between the Parties or other order of the Court on scheduling, at the time of the submission or filing of any such material to the Court, the Party or counsel proffering such AI-generated material to the Court shall file and serve any declarations, affidavits, or sworn testimony to address the material's authenticity under the Evidence Code.

s31mscandtrialsettingorders · p. 4
|SectionTHE COURT FURTHER ORDERS AS FOLLOWS
Filing RequirementsImportantCivil cases

Trial briefs are only required for jury trials if the time estimate is over eight days.

s31mscandtrialsettingorders · p. 1
|SectionTHE COURT FURTHER ORDERS AS FOLLOWS

Filing & Service rules

Filing Timing and Cure Windows

The informal discovery conference statement must be filed directly in S31 five days before the conference.

(Do not attach more than two pages. File directly in S31, five days prior to the conference.)

Civil cases

Page 1 | Informal Discovery Conference Statement

MSC Briefs are due no later than five days before the settlement conference.

No less than five (5) days prior to the Settlement Conference, MSC Briefs must be filed directly in Department S-31

Civil cases

Page 1 | MANDATORY SETTLEMENT CONFERENCE

All motions in limine and their oppositions must be filed directly with Department S31 at least eight days before the Trial Readiness Conference.

Except that all motions in limine and opposition shall be filed directly in Dept. S31 at least 8 days before the Trial Readiness Conference (Local Rule 411)

Civil cases

Page 1 | Footnote 1

Defendant's jury instructions must be filed on the first day of trial.

Defendant's jury instructions are due filed on the first day of trial

Civil cases

Page 1 | THE COURT FURTHER ORDERS AS FOLLOWS

Service and Proof of Service Rules

A Request for Informal Discovery Conference must be served on all parties by an authorized or agreed method no later than the next court day after filing.

Serve all parties pursuant to any authorized or agreed method of service that ensures that the opposing part/ies receive the Request for Informal Discovery Conference no later than the next court day following the filing.

Civil cases

Page 1 | The party requesting the Informal Discovery Conference will

An Answer to a Request for Informal Discovery Conference must be served on the opposing party by an authorized or agreed-upon method no later than the next court day after filing.

Be served on the opposing party pursuant to any authorized or agreed upon method of service that ensures that the opposing party receives the Answer no later than the next court day following the filing.

Civil cases

Page 1 | Any Answer to a Request for Informal Discovery Conference must

Courtesy Copy Requirements

The Joint Witness List must identify each witness, provide a brief description and time estimate, and include two courtesy copies provided to the clerk.

Joint Witness List listing the name, brief description, and time estimate for each witness. Two (2) courtesy copies of the Joint Witness List shall be provided to the clerk.

Civil cases

Page 2 | I. JOINT TRIAL BINDER

Two courtesy copies of the Joint Exhibit List must be provided to the clerk.

Joint Exhibit List. Two (2) courtesy copies of the Joint Exhibit List shall be proved to the clerk.

Civil cases

Page 2 | I. JOINT TRIAL BINDER

Pre-Motion Conference Requirements

Counsel must meet and confer in good faith before filing and serving motions in limine.

Counsel shall meet and confer in good faith before filing and serving the Motions in Limine.

Civil cases

Page 2 | I. JOINT TRIAL BINDER

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.

About Judge Lily L. Sinfield

Department S31, San Bernardino Justice Center, 247 W. Third Street, San Bernardino, CA. 92415

Common questions about Judge Lily L. Sinfield's rules

Are courtesy copies required for Judge Lily L. Sinfield?

Courtesy-copy rule applies for joint witness lists. Details: 2 copies. The Joint Witness List must identify each witness, provide a brief description and time estimate, and include two courtesy copies provided to the clerk.

View ruleSource: page 2, section I. JOINT TRIAL BINDER

Does Judge Lily L. Sinfield require a pre-motion conference or letter before filing a motion?

Counsel must meet and confer in good faith before filing and serving motions in limine.

View ruleSource: page 2, section I. JOINT TRIAL BINDER

What page or word limits apply to informal discovery conference answer before Judge Lily L. Sinfield?

Judge Lily L. Sinfield's rule states these limits: 2 pages. An Answer to a Request for Informal Discovery Conference may not exceed two pages and must summarize why the requested relief should be denied.

View ruleSource: page 1, section Any Answer to a Request for Informal Discovery Conference must

What page or word limits apply to informal discovery conference statement before Judge Lily L. Sinfield?

Judge Lily L. Sinfield's rule states these limits: 2 pages. An informal discovery conference statement must not exceed two pages.

View ruleSource: page 1, section Informal Discovery Conference Statement

What formatting rules apply to filings before Judge Lily L. Sinfield?

Judge Lily L. Sinfield's formatting rule includes binding three ring binder. Parties must bring a three-ring Joint Trial Binder to the Trial Readiness Conference.

View ruleSource: page 1, section I. JOINT TRIAL BINDER

What must be included with msc brief filings before Judge Lily L. Sinfield?

MSC Briefs must be filed directly with Department S-31 and served on opposing parties at least five days before the settlement conference, with all four CRC 3.1380 elements.

View ruleSource: page 1, section MANDATORY SETTLEMENT CONFERENCE

What must be included with plaintiff jury instructions or special verdict filings before Judge Lily L. Sinfield?

Plaintiff's Jury Instructions/Special Verdict.

View ruleSource: page 1, section THE COURT FURTHER ORDERS AS FOLLOWS

What filing deadlines does Judge Lily L. Sinfield set?

The informal discovery conference statement must be filed directly in S31 five days before the conference.

View ruleSource: page 1, section Informal Discovery Conference Statement

What rule applies to service for informal discovery conference request before Judge Lily L. Sinfield?

Details: recipient: all parties, timing: after filing. A Request for Informal Discovery Conference must be served on all parties by an authorized or agreed method no later than the next court day after filing.

View ruleSource: page 1, section The party requesting the Informal Discovery Conference will
Complete rules summary for Judge Lily L. Sinfield

Parties must bring a three-ring Joint Trial Binder to the Trial Readiness Conference.

The Joint Witness List must identify each witness, provide a brief description and time estimate, and include two courtesy copies provided to the clerk.

Two courtesy copies of the Joint Exhibit List must be provided to the clerk.

Parties must bring two complete copies of the Joint Exhibit Binder to court on the first day of trial.

Counsel must meet and confer in good faith before filing and serving motions in limine.

Each exhibit must bear a discrete identifying number and be correctly identified.

A Request for Informal Discovery Conference must be served on all parties by an authorized or agreed method no later than the next court day after filing.

An Answer to a Request for Informal Discovery Conference may not exceed two pages and must summarize why the requested relief should be denied.

Include a brief summary of the dispute and specify the relief requested. This should not consist of more than two pages;

Exhibits, declarations, attachments, and other pleadings accompanying the Request and Answer will not be accepted unless the Court requests them after receiving both filings.

An Answer to a Request for Informal Discovery Conference must be served on the opposing party by an authorized or agreed-upon method no later than the next court day after filing.

An informal discovery conference statement must not exceed two pages.

The informal discovery conference statement must be filed directly in S31 five days before the conference.

MSC Briefs must be filed directly with Department S-31 and served on opposing parties at least five days before the settlement conference, with all four CRC 3.1380 elements.

Plaintiff's Jury Instructions/Special Verdict.

A joint exhibit list must be filed, and exhibits must be pre-marked in numerical order with each page of multipage exhibits date-stamped at the bottom.

The parties should provide a Joint Statement of the Case if they do not anticipate giving mini-openings.

Trial briefs are mandatory for bench trials.

MSC Briefs are due no later than five days before the settlement conference.

For jury trials, trial briefs are required only when the estimated trial duration exceeds eight days.

Trial exhibits must be placed in three-ring binders with one copy for the court, one for the witness, and one for all other parties.

The plaintiff must submit a complete set of jury instructions with a generic pleading cover sheet and an itemized list of CACI and special instructions.

Defendant's jury instructions are due on the first day of trial and should contain only additional instructions and objections to the plaintiff's instructions.

Defendant's jury instructions must be filed on the first day of trial.

All motions in limine and their oppositions must be filed directly with Department S31 at least eight days before the Trial Readiness Conference.

Counsel must contemporaneously serve a sufficiently specific notice identifying AI-generated evidentiary material when it is produced or disclosed, and untagged material will not be considered by the Court.

Unless the parties stipulate or the court orders otherwise, authenticity declarations, affidavits, or sworn testimony must be filed and served when AI-generated material is submitted or filed.

AI-assisted exhibits, demonstratives, and other court materials must identify the AI assistance in the title or caption, in a preceding table, and in a separate contemporaneously filed notice.

A separate notice identifying AI assistance must be filed contemporaneously with any AI-assisted exhibit, demonstrative, or other court material.

A joint witness list with time estimates for each phase of examination must be filed by the date of the trial readiness conference.

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