Judge Carolyn M. Caietti
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Ex Parte Application
Ex Parte Papers, Pro Hac Vice Application, Noticed Motion, Motion in Limine, Trial Brief, Trial Readiness Conference Report, IDC Brief, Settlement Conference Brief, Proposed Judgment, Proposed Order
Joint Trial Notebook, Motion in Limine Binder
- Hand Delivery
Joint Trial Readiness Conference Report
- 1 copy
Adjournments
- Stipulated requests to continue any applicable dates (trial, trial readiness, motion cut-off) and deadlines may be made by written stipulation setting forth good cause for a continuance.
Request must include
Communication
Phone
Chambers
Phone
Clerk
Page & Word Limits1 rule
In advance of the IDC, each party shall submit a concise brief (no more than five pages) of the party’s position regarding the dispute.
- Page limit
- Up to 5 pages per party
Document Format Requirements1 rule
Motion papers must comply with CRC 3.1110 et seq. and San Diego Local Rule 2.1.4.1 for formatting, bookmarking, and filing.
Court's wording
The parties are reminded to comply with California Rule of Court 3.1110 et. seq. and San Diego Superior Court local rule 2.1.4.1 regarding formatting, bookmarking, and filing requirements of motion papers.
Document Filing Requirements9 rules
A proposed sealing order must be provided to the Court setting forth the facts and legal
The Trial Readiness Conference report must contain an agreed statement of the case, joint witness list, joint exhibit list, joint jury instructions list with index, and proposed verdict forms.
- Document
- Joint trial readiness conference report
Include
- •Exhibit list
Court's wording
The Court expects the TRC report to contain the following: a) Agreed upon, non-argumentative statement of the case; b) Joint witness list in alphabetical order; c) Joint exhibit list with objections or stipulations noted on the exhibit list, numbered sequentially (see exemplar). NOTE: the Court expects the parties to have met in person or remotely and exchanged/reviewed ALL exhibits except for true impeachment, prior to submitting the TRC Report; d) Joint list of jury instructions, together with an index, in the order in which they are requested to be given, with objections noted; and e) Proposed verdict form(s).
Pro hac vice applications must comply with CRC 9.40 and include proof of service, proof of fee payment, and a proposed order.
- Document
- Pro hac vice application
Must include
- •Proposed order
- •Certificate of service
Court's wording
Applications for pro hac vice must comply with California Rules of Court Rule 9.40. Applications must include proof of service on the State Bar of California, proof of payment of the required fee, and a proposed order.
The stipulation should include a proposed order.
- Document
- Stipulated advisory to continue
Should include
- •Proposed order
Guardian Ad Litem applications shall include attachment form CIV-383, except if an adult dependent.
The proposed order shall be submitted concurrently with the notice and application for determination of good faith settlement pursuant to Code of Civil Procedure § 877.6 (a)(2).
The notebook will be prepared by plaintiff’s counsel. The notebook should be joint and contain: a) Table of Contents; b) Joint Trial Readiness Report; c) Operative Pleadings (i.e. complaint, answer, cross complaint); d) Expert Designations; e) Trial Briefs; f) Motions in Limine and Oppositions (in order) and index of the MILs (MILs should be in separate binder from rest of items in Dept. 70’s Trial Checklist 1 – 12); g) Joint Witness List (alpha order, brief description of witnesses’ expected testimony); h) Joint Exhibit List (follow grid format; see Dept. 70 link on web page); i) Joint Statement of the Case; j) Proposed Voir Dire questions counsel wish the Court to ask; k) Jury Instructions in one packet (full text in sequential order with objections identified); and l) Special Verdict Form(s)
- Document
- Joint trial notebook
Should include
- •Exhibit list
- •Table of contents
Proposed stipulated protective orders for protection of confidential information will only be approved by the Court if the language in the proposed order is consistent with the Court’s stated policy.
Applications for orders for publication of summons may be submitted for review without an appearance. Please use the local forms CIV 48, CIV 49.
Filing & Service rules
Filing Timing and Cure Windows
Ex parte papers must be filed by 12:00 p.m. at least one court day before the hearing, with the appropriate fee.
Ex parte matters will not be heard unless papers are filed by 12:00 p.m. at least one court day prior to the hearing, with the appropriate fee. All ex parte applications must comply with California Rules of Court, rule 3.1200 et. seq.
Civil cases
Page 1 | Ex Parte
The Joint Trial Readiness Conference Report must be E-filed no later than five court days before the scheduled TRC.
Parties must submit by E-filing their completed Joint Trial Readiness Conference Report five court days before the scheduled TRC with a courtesy copy provided to the department.
Civil cases
Page 2 | Trial Readiness Conference (TRC)
A proposed good faith settlement order will be held for 20 days if service is personal or 25 days if by mail; if uncontested, it may be signed or set for hearing.
The proposed order will be held the requisite statutory period (20 days if personally served, 25 days if served by mail). If no motion to contest is filed within the statutory period, the application will be reviewed and the order may be signed; or the Court will set a hearing.
Civil cases
Page 2 | Applications for Determination of Good Faith Settlement
Motions to seal should preferably be heard at least two weeks before the related substantive motions.
The Court prefers any motion to seal be heard at least two weeks before the corresponding substantive motions.
Civil cases
Page 2 | Sealing Records
Filing Fees and Waivers
Filing an ex parte application requires payment of the appropriate fee.
Ex parte matters will not be heard unless papers are filed by 12:00 p.m. at least one court day prior to the hearing, with the appropriate fee.
Civil cases
Page 1 | Ex Parte
Courtesy Copy Requirements
Proposed orders and proposed judgments (other than default judgments) require a courtesy copy to Dept. 70.
Proposed Orders, Proposed Judgments (other than default judgments): A courtesy copy must be provided to Dept. 70 in order to ensure timely processing.
Civil cases
Page 1 | Proposed Orders, Proposed Judgments
All motion hearing documents require a courtesy copy to Dept. 70, and courtesy copies must have tabbed exhibits.
The Court requires courtesy copies of all E-filed documents on all motion hearings (moving, opposing, etc.) delivered directly to the Dept. 70 drop box in the Hall of Justice. On courtesy copies, please tab exhibits.
Civil cases
Page 1 | Law and Motion
Courtesy copies of all E-filed ex parte papers must be delivered to the Dept. 70 drop box.
The Court requires courtesy copies of all E-filed ex parte papers delivered directly to the Dept. 70 drop box in the Hall of Justice.
Civil cases
Page 1 | Ex Parte
A courtesy copy of the Joint Trial Readiness Conference Report must be provided to the department.
Parties must submit by E-filing their completed Joint Trial Readiness Conference Report five court days before the scheduled TRC with a courtesy copy provided to the department.
Civil cases
Page 2 | Trial Readiness Conference (TRC)
A separate binder containing Motions in Limine, oppositions (in sequential order), and an index of MILs must be delivered to the courtroom by noon the day before the trial call whether the parties appear remotely or in person.
A separate binder for Motions in Limine and Oppositions (in sequential order) and index of the MILs are to be provided by noon the day before trial call regardless of whether the parties are appearing remotely or in person for trial call.
Civil cases
Page 3 | Trial Call
Courtesy copies of the following documents should be placed in the Department 70 drop box, located outside the business office on the second floor of the Hall of Justice: Ex Parte Papers (moving, opposing) Pro Hac Vice Applications Noticed Motions (moving, opposing, replies) Motions in Limine Trial Briefs Joint Trial Readiness Conference Reports IDC, Settlement Conference Briefs Proposed Judgment Proposed Order Other than the above documents, the Court does not require courtesy copies of other E-filed documents.
Courtesy copies of the following documents should be placed in the Department 70 drop box, located outside the business office on the second floor of the Hall of Justice: Ex Parte Papers (moving, opposing) Pro Hac Vice Applications Noticed Motions (moving, opposing, replies) Motions in Limine Trial Briefs Joint Trial Readiness Conference Reports IDC, Settlement Conference Briefs Proposed Judgment Proposed Order Other than the above documents, the Court does not require courtesy copies of other E-filed documents.
Civil cases
Page 3 | Courtesy Copies
Remote appearance at trial call is permitted only if the Joint Trial Notebook and Motion in Limine binders are physically in the courtroom by noon the day before trial call; otherwise all trial counsel and pro se parties must appear in person unless the Court permits remote appearance.
While it is preferred trial counsel be personally present, the Court allows for a remote appearance only if the Joint Trial Notebook and Motion in Limine binders are physically in the courtroom by noon the day prior to trial call. Otherwise, ALL trial counsel and pro se are to be physically present at trial call unless the Court allows for a remote appearance.
Civil cases
Page 3 | Trial Call
Sealing & Redaction Procedures
Sealing requests must comply with CRC 2.550 and 2.551; records may not be sealed based solely on party stipulation.
Requests to seal court records must comply with CRC 2.550 and 2.551. Note: "The court must not permit a record to be filed under seal based solely on the agreement or stipulation of the parties." CRC 2.551(a).
Civil cases
Page 1 | Sealing Records
Filing Bundling Requirements
Motions to compel initial responses must be filed as a single motion regardless of the number of discovery sets.
Motions to compel initial responses should be reserved and filed as a single motion regardless of the number of sets of discovery at issue.
Civil cases
Page 1 | Discovery Motions
Motions to compel further responses, and motions to deem facts admitted, should be reserved and filed as separate motions for each set of discovery at issue.
Motions to compel further responses, and motions to deem facts admitted, should be reserved and filed as separate motions for each set of discovery at issue.
Civil cases
Page 1 | Discovery Motions
Discovery motions must not combine discovery sought from multiple parties; each party must file its own separate motion.
Do not combine into one joint motion multiple parties, from whom discovery is sought to be compelled. Each party should have its own separate discovery motion(s).
Civil cases
Page 1 | Discovery Motions
Motions in Limine and their oppositions must be placed in a separate binder with an index, separate from all other Trial Checklist items.
Motions in Limine and Oppositions (in order) and their index (Motions should be in a separate binder from rest of items in Department 70’s Trial Checklist 1 – 12)
Civil cases
Page 3 | Trial Call
Adjournment & Extension Requirements
Stipulated requests to continue any applicable dates (trial, trial readiness, motion cut-off) and deadlines may be made by written stipulation setting forth good cause for a continuance.
Stipulated requests to continue any applicable dates (trial, trial readiness, motion cut-off) and deadlines may be made by written stipulation setting forth good cause for a continuance.
Civil cases
Page 2 | Continuances
Chambers Communication Rules
Law and motion hearings require a reservation made by phone or online.
All law and motion matters are heard by reservation only. To reserve a date, contact the calendar clerk at the number above or utilize the online reservation system.
Civil cases
Page 1 | Law and Motion
Ex parte hearings are reserved by calling the calendar clerk at (619) 450-7325 during 8:00 a.m. to 3:00 p.m.
Calendar Clerk Anthony Shirley: (619) 450-7325 Phone hours: 8:00 a.m. to 3:00 p.m. To reserve an ex parte hearing, contact the calendar clerk at the number above.
Civil cases
Page 1 | Department Staff / Ex Parte
The day before trial call, the Court expects the parties to call into the department by noon to report their readiness for trial, time estimate, and whether a jury is requested. (619) 450-7070.
The day before trial call, the Court expects the parties to call into the department by noon to report their readiness for trial, time estimate, and whether a jury is requested. (619) 450-7070.
Civil cases
Page 3 | Trial Call