Judge Winston Keh
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Joint Exhibit List
- 2 copies
Joint Witness List
- 2 copies
Civil Unlimited Complaint
Court-wide- 1 copy
Adjournments
Court-wideRequest must include
Communication
Other Contacts7 contacts
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Chambers1 contacts
Clerk1 contacts
Document Format Requirements3 rules
Each exhihit shall be marked with a discrete number and shall be correctly identified.
Formatting
- •Each exhibit must be marked with a discrete number and correctly identified
The Joint Trial Binder must be a three-ring binder.
- Binding
- Three-ring binder
- Joint trial binder
Court's wording
On the date of the TRC, the paities shall bring with them /' a three-ring Joint Trial Binder that contains the following, if applicable: 1. Table of Contents 2. Printed copies of the current operative pleadings (including the operative complaint; answer; cross- complaint, if any; and answer to cross-complaint); 3. Joint Witness List listing the name, brief description, and time estimate for each witness. Two (2) courtesy g copies of the Joint Witness List shall be provided to the Clerk. 4. Joint List of Controverted Issues. 5. Stipul.ations. 6. Joint Exhibit List. Two (2) courtesy copies of the Joint Exhibit List shall be provided to the Clerk. 7. Trial Briefs 8. Motions in Limine and oppositions (if any):
Exhibits shall be placed in A 3-ring binder with 2 sets for the Court, 1 set for the witness and 1 set for the opposing party.
- Binding
- Three-ring binder
- Exhibits
Formatting
- •Exhibits shall be pre-marked in numerical order
Document Filing Requirements13 rules
Joint exhibit list (In the form attached)
- Document
- Joint exhibit list
Include
- •Exhibit list
Plaintiff shall submit, in compliance with CRC Rule 2.1055, a complete set ofjury instructions {with a generic pleading cover sheet) with an itemized list of the CACI Instructions and Special Instructions, if any.
Joint Statement of the Case.
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.
Counsel for the moving party shall file declaration showing compliance with the court's meet and confer requirements.
Joint witness list
5. Trial briefs
Plaintiff's Jury Instructions/Special Verdict
The parties must also provide copies of any deposition transcripts that will be used during the trial.
If a Party or counsel seeks to file or otherwise present to the Court any such Al-generated evidentiary material, no such material shall be considered unless previously disclosed as Al generated.
Material created or drafted with AI assistance or use must be identified as such in its title or caption, in a table preceding the body, and by a separate contemporaneous notice.
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 Al 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.
Counsel must provide email addresses to the judicial assistant and return one completed joint exhibit list by email.
- Document
- Joint exhibit list
Include
- •Exhibit list
Court's wording
The Courts Judicial Assistant will email the exhibit list template to Counsel. Please provide the JA with your email addresses, Counsel are to return one completed joint list via email to the JA at LMariscal@sb-court.org
Counsel shall maintain records sufficient to identify, if requested by the Court, those portions of that exhibit, document, or material created or drafted by use of an Al tool.
Filing & Service rules
Filing Timing and Cure Windows
All motions in limine and oppositions must be filed and served directly to Department S-37 at least five days before the Trial Readiness Conference.
All motions in limine and opposition shall be filed and served directly to Dept S-37 at least 5 days before the Trial Readiness Conference.
Civil cases
Page 1 | TRIAL SETTING ORDERS.
The parties must meet and confer on all pretrial matters at least 10 calendar days before the Trial Readiness Conference.
The parties must meet and confer on all pre-trial matters at least 10 calendar days before the Trial Readiness Conference ("TRC").
Civil cases
Page 1 | I. JOINT TRIAL BINDER
Service and Proof of Service Rules
All motions in limine and oppositions must be served directly to Department S-37 at least five days before the Trial Readiness Conference.
All motions in limine and opposition shall be filed and served directly to Dept S-37 at least 5 days before the Trial Readiness Conference.
Civil cases
Page 1 | TRIAL SETTING ORDERS.
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.
Absent stipulation between the Parties or other order of the Court on scheduling, at the time of the submi.ssion or filing of any such material to the Court, the Party or counsel proffering such Al-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.
Page 1 | GENERAL ORDER — AI Materials Intended as Evidence
Courtesy Copy Requirements
Two courtesy copies of the Joint Exhibit List must be provided to the Clerk.
Two (2) courtesy copies of the Joint Exhibit List shall be provided to the Clerk.
Civil cases
Page 1 | I. JOINT TRIAL BINDER
Two courtesy copies of the Joint Witness List must be provided to the Clerk.
Two (2) courtesy g copies of the Joint Witness List shall be provided to the Clerk.
Civil cases
Page 1 | I. JOINT TRIAL BINDER
Filing Bundling Requirements
At the Trial Readiness Conference, the parties must bring a three-ring Joint Trial Binder containing the listed pretrial documents when applicable.
On the date of the TRC, the paities shall bring with them /' a three-ring Joint Trial Binder that contains the following, if applicable: 1. Table of Contents 2. Printed copies of the current operative pleadings (including the operative complaint; answer; cross- complaint, if any; and answer to cross-complaint); 3. Joint Witness List listing the name, brief description, and time estimate for each witness. Two (2) courtesy g copies of the Joint Witness List shall be provided to the Clerk. 4. Joint List of Controverted Issues. 5. Stipul.ations. 6. Joint Exhibit List. Two (2) courtesy copies of the Joint Exhibit List shall be provided to the Clerk. 7. Trial Briefs 8. Motions in Limine and oppositions (if any):
Civil cases
Page 1 | I. JOINT TRIAL BINDER
The parties must meet and confer and bring two complete Joint Exhibit Binders to the first day of trial, allocating the premarked original to the witness and one copy to the Court.
The parties shall meet and confer and bring to Court on the first day of trial, two complete copies of the Joint Exhibit Binder. One set, the original, shall be for the witness, pre- marked with Court Exhibit tags. One copy shall be for the Court.
Civil cases
Page 1 | II. JOINT EXHIBIT BOOK
Pre-Motion Conference Requirements
The parties must meet and confer by telephone or in person before filing or serving any motion in limine.
The parties are required to meet and confer via telephone or in person before filing and serving any motions in limine.
Civil cases
Page 1 | TRIAL SETTING ORDERS.
Counsel must meet and confer in good faith before filing and serving any motion in limine and must comply with Local Rule 415.
Motions in Limine and oppositions (if any): Counsel shall meet and confer in good faith before filing and �erving the Motions in Limine. Couns�l shall comply with Local Rule 415 and the parties are expected to read and be familiar with Amtower v. Photon Dynamics Inc. (2008)158 Cal.App.4th 1582, Kelly v. New West Financial Services (1996) 49 Cal.App.4th 659, and R&B Auto Center Inc. v. Farmers Group Inc. (2006 140 Ca1. App.4th 327.
Civil cases
Page 1 | I. JOINT TRIAL BINDER
Chambers Communication Rules
Questions may be directed to the judicial assistant by telephone at (909) 708-8707 or by email at LMariscal@sb-court.org.
IF YOU HAVE ANY QUESTIONS, PLEASE CALL OR EMAIL MY JUDICIAL ASSISTANT, LILIANA MARISCAL at: (909) 708-8707. LMariscal@sb-court.org
Civil cases
Page 1 | TRIAL SETTING ORDERS.