Judge Judy S. Bae
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Brief
- Within 24 Hours
Ex Parte Application
- Day Before Hearing by Noon
- Within 24 Hours
IDC Brief
- Day Before Hearing by Noon
Motion
- Chambers Drop Off
Adjournments
- Ex parte applications to advance hearings are discouraged and should be based on an affirmative showing of good cause for an earlier date.
- Parties may stipulate to extend discovery deadlines to facilitate resolution without a motion.
- Parties may appear ex parte to request a hearing on a motion to seal in advance of a pending substantive motion, or to continue the substantive motion.
- +1 more
Request must include
Communication
Phone
Clerk
Phone
Clerk
Phone
Clerk
Page & Word Limits3 rules
Parties are expected to adhere to the page limitations set forth in CRC Rule 3.1113(d).
In advance of the IDC, each party should submit a concise brief (no more than three (3) pages) of the party's position regarding the dispute and be filed by 12:00 p.m. the day before the IDC.
- Brief
- Up to 3 pages per party
If there is good cause to file an oversized brief, parties must obtain leave in advance.
Document Format Requirements3 rules
All exhibits must be pre-marked in an up-to-date exhibit binder(s). If photographs are submitted, each photograph must have an individual exhibit number and tag.
Parties are to comply with CRC Rule 3.1110, et. seq. and San Diego County Superior Court Local Rule (LR) 2.1.4.1 regarding formatting, bookmarking, and filing requirements for motion papers.
Parties should not manipulate the font size or line spacing to circumvent the page limitations.
Document Filing Requirements18 rules
A proposed sealing order must be provided to the Court setting forth the facts and legal basis which supports the sealing of each item subject to the sealing request.
The proposed order shall be submitted concurrently with the notice and application for determination of good faith settlement pursuant to CCP § 877.6(a)(2).
The Joint TRC Report must include a joint witness list, joint jury instructions, disputed instructions and witnesses, and a joint exhibit list with objections and stipulations.
- Document
- Joint TRC report
Must include
- •Exhibit list
Court's wording
In addition to the usual requirements, the TRC report must include: • A joint list of witnesses. • A joint list of jury instructions • A list of disputed jury instructions, noting the requesting party • A list of disputed witnesses, noting the requesting party. • A joint list of exhibits using the format shown in the Court's ATRO, noting any objections and stipulations.
Counsel must bring a Joint Trial Notebook to Trial Call containing specified documents including TOC, TRC report, pleadings, expert designations, motions in limine, witness and exhibit lists, trial briefs, statement of the case, voir dire, jury instructions, and special verdict form.
- Document
- Trial notebook
Must include
- •Exhibit list
- •Table of contents
Court's wording
At Trial Call, counsel must bring a Joint Trial Notebook, which should be comprised of the following: 3 ===== PAGE 4 ===== 1. Table of Contents 2. Joint Trial Readiness Report 3. Operative pleadings (i.e. complaint, cross-complaint, answer, etc.) 4. Expert designations 5. Motions in Limine and Oppositions (in order) with an index 6. Joint Witness List (with description of witnesses’ expected testimony) 7. Joint Exhibit List. The list must be carefully reviewed to ensure the description of the exhibit matches the exhibit and that there are no duplicates. 8. Trial Briefs (if any) 9. Joint Statement of the Case, in a neutral form suitable to be read to prospective jurors. 10. Proposed Voir Dire Questions (if any) 11. Jury Instructions (packet agreed upon and packet of those not agreed upon, with indication of which party is offering and objecting) 12. Special Verdict Form (either an agreed upon form or each
Papers must comply strictly with CRC Rule 3.1800. Non-complying papers will be returned with a notation of defects.
Lodged materials must be accompanied by an addressed envelope with sufficient postage for return mailing per CRC Rule 3.1302(b).
Court's wording
If documents or other materials are lodged in support of/opposition to a motion, CRC Rule 3.1302(b) requires the lodgment be accompanied by an addressed envelope with sufficient postage for mailing the material back to the lodging party.
All ex parte applications must comply with California Rules of Court (CRC) Rule 3.1200, et seq.
Parties are reminded to submit attachment form ADM-430 (formerly CIV-383, now repealed), except if for an adult dependent.
For motions to compel further responses, the moving party may submit a concise outline of the discovery request and each response in dispute instead of a separate statement; copies of the actual requests and responses must be submitted as exhibits or lodged.
Court's wording
In lieu of submitting a separate statement with a motion to compel further responses, the moving party may submit a concise outline of the discovery request and each response in dispute. In accordance with LR 2.1.21, a prior order permitting the concise outline is not required. However, in the event the moving party elects to submit a concise outline, copies of the actual requests and responses shall be submitted as exhibits or lodged in support of the motion.
Guardians ad litem must appear at the time of the hearing.
Applications for admission pro hac vice must comply with CRC 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.
- Document
- Pro hac vice application
Must include
- •Proposed order
- •Certificate of service
The party requesting an IDC should first meet and confer with the opposing party to discuss scheduling.
No notice of intent to appear is required to appear for oral argument.
No appearance is required if all parties stipulate to the requested relief.
Parties should not refer to any discussions in any subsequent papers.
Applications may be submitted for review without an appearance.
Applications for appointment of a guardian ad litem are governed by LR 2.4.6.
- Document
- Guardian ad litem application
Include
- •Governed by LR 2.4.6.
The stipulation should include a proposed order.
- Document
- Stipulation
Should include
- •Proposed order
Filing & Service rules
Filing Timing and Cure Windows
Ex parte matters will not be heard unless supporting papers with the appropriate fee are filed by 12:00 p.m. the day before the hearing.
Ex parte matters will not be heard unless supporting papers with the appropriate fee are filed by 12:00 p.m. the day before the hearing.
Civil cases
Page 1 | Ex Parte Hearings
IDC briefs must be filed by 12:00 p.m. the day before the IDC.
In advance of the IDC, each party should submit a concise brief (no more than three (3) pages) of the party's position regarding the dispute and be filed by 12:00 p.m. the day before the IDC.
Civil cases
Page 1 | Informal Discovery Conferences
Joint TRC Report must be filed five days before the Trial Readiness Conference.
A completed Joint TRC Report shall be filed five (5) days before the TRC pursuant to LR 2.1.15.
Civil cases
Page 3 | Trial Readiness Conferences
Trial briefs must be filed five court days before Trial Call.
Trial briefs must be filed five (5) court days prior to Trial Call.
Civil cases
Page 4 | Trial Calls
Lodged material without a return envelope will be held for 30 days for retrieval, then discarded/destroyed.
Lodged material without a return envelope will be held 30 days, during which time the lodging party may physically retrieve the material from the courtroom clerk. After 30 days, the lodged material will be discarded/destroyed.
Civil cases
Page 1 | Law and Motion
An IDC does not toll the statutory deadline to file a motion to compel.
An IDC does not toll the statutory deadline to file a motion to compel.
Civil cases
Page 2 | Informal Discovery Conferences
Tentative rulings will generally be posted on the court's website by 4:00 p.m. the day prior to the scheduled hearing.
Tentative rulings will generally be posted here on the court's website by 4:00 p.m. the day prior to the scheduled hearing.
Civil cases
Page 1 | Law and Motion
Service and Proof of Service Rules
If the parties are unable to agree on a date, the IDC should be scheduled with at least five (5) days' notice to the opposing party.
If the parties are unable to agree on a date, the IDC should be scheduled with at least five (5) days' notice to the opposing party.
Civil cases
Page 1 | Informal Discovery Conferences
Affidavits for service by publication will be scrutinized for reasonable diligence in attempting service by another manner, per CCP § 415.50(a).
Affidavits will be scrutinized to determine whether the applicant has been reasonably diligent in attempting service in another manner, as required by Code of Civil Procedure (CCP) § 415.50(a).
Civil cases
Page 2 | Orders to Serve by Publication
Applications for an order to serve by publication may be submitted for review without an appearance.
Applications requesting an order to serve by publication may be submitted for review without an appearance.
Civil cases
Page 2 | Orders to Serve by Publication
Filing Fees and Waivers
A filing fee is required for ex parte matters.
Ex parte matters will not be heard unless supporting papers with the appropriate fee are filed by 12:00 p.m. the day before the hearing.
Civil cases
Page 1 | Ex Parte Hearings
Courtesy Copy Requirements
Courtesy copies of all e-filed ex parte papers must be delivered to the Dept. 62 drop box by 12:00 p.m. the day before the ex parte hearing.
Court requires courtesy copies of all e- filed ex parte papers be delivered directly to the Dept. 62 drop box in the Hall of Justice by 12:00 p.m. the day before the ex parte hearing.
Civil cases
Page 1 | Ex Parte Hearings
Courtesy copies of all e-filed documents on all motion hearings must be delivered to the Dept. 62 drop box on the second floor in the Hall of Justice.
The Court requires courtesy copies of all e-filed documents on all motion hearings (moving, opposing, etc.) delivered directly to the Dept. 62 drop box on the second floor in the Hall of Justice.
Civil cases
Page 1 | Law and Motion
Courtesy copies of all e-filed IDC briefs must be delivered to the Dept. 62 drop box by 12:00 p.m. the day before the IDC.
The Court requires courtesy copies of all e-filed briefs delivered directly to the Dept. 62 drop box on the second floor in the Hall of Justice by 12:00 p.m. the day before the IDC.
Civil cases
Page 2 | Informal Discovery Conferences
All e-filed papers must have courtesy copies delivered to the Department 62 drop box on the second floor of the Hall of Justice.
The Court requires courtesy copies of all e-filed papers delivered directly to the Dept. 62 drop box on the second floor in the Hall of Justice.
Civil cases
Page 3 | Applications for Determination of Good Faith Settlement
IDC briefs (delivered no later than 12:00 p.m. the day before the hearing)
IDC briefs (delivered no later than 12:00 p.m. the day before the hearing)
Civil cases
Page 4 | Courtesy Copies
Ex parte applications (delivered no later than 12:00 p.m. the day before the hearing)
Ex parte applications (delivered no later than 12:00 p.m. the day before the hearing)
Civil cases
Page 4 | Courtesy Copies
Sealing & Redaction Procedures
Stipulated protective orders and motions to seal must comply with CRC Rules 2.550 and 2.551; records will not be sealed based solely on party agreement or stipulation.
Proposed stipulated protective orders for protection of confidential information will be approved only if the language in the proposed order is consistent with CRC Rules 2.550 and 2.551. Motions and applications to seal must comply with Rules 2.550 and 2.551. Records will not be sealed based solely on the agreement or stipulation of the parties.
Civil cases
Page 2 | Stipulated Protective Orders / Motions to Seal
If documents are lodged conditionally under seal, the substantive motion will not be decided until after the hearing on the motion to seal.
If documents have been lodged conditionally under seal in support of/opposition to a motion, the substantive motion will not be decided until after the hearing on the motion or application to seal.
Civil cases
Page 2 | Stipulated Protective Orders / Motions to Seal
Filing Bundling Requirements
Motions to compel initial responses should be filed as a single motion regardless of the number of discovery sets; motions to compel further responses and motions to deem facts admitted should be filed as separate motions for each set.
Motions to compel initial responses should be reserved and filed as a single motion, regardless of the number of sets of discovery at issue. However, 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 2 | Discovery Motions
Pre-Motion Conference Requirements
Parties may be ordered to attend an IDC to discuss a discovery dispute that is the subject of a pending motion to compel.
On occasion, the parties may be ordered to attend an IDC to discuss a discovery dispute that is the subject of a pending motion to compel.
Civil cases
Page 1 | Informal Discovery Conferences
Parties are encouraged to appear for an informal discovery conference (IDC) before filing a motion to compel.
Parties are encouraged to appear during ex parte hours for an informal discovery conference (IDC) before filing a motion to compel.
Civil cases
Page 1 | Informal Discovery Conferences
Adjournment & Extension Requirements
Stipulated continuance requests require a written stipulation stating good cause; disputed requests should be made by ex parte application or noticed motion.
Stipulated requests to continue any applicable dates (trial, trial readiness, motion cut-off) and deadlines may be made by written stipulation but must set forth the good cause for a continuance. The stipulation should include a proposed order. Disputed requests for continuance should be made, preferably, by an ex parte application or, alternatively, by way of a noticed motion.
Civil cases
Page 3 | Continuance Requests
Ex parte applications to advance hearings are discouraged and should be based on an affirmative showing of good cause for an earlier date.
Ex parte applications to advance hearings are discouraged and should be based on an affirmative showing of good cause for an earlier date.
Civil cases
Page 1 | Ex Parte Hearings
Parties may stipulate to extend discovery deadlines to facilitate resolution without a motion.
However, the parties may stipulate to extend deadlines to help facilitate a resolution of a discovery dispute without the need for a motion.
Civil cases
Page 2 | Informal Discovery Conferences
Parties may appear ex parte to request a hearing on a motion to seal in advance of a pending substantive motion, or to continue the substantive motion.
Parties may appear ex parte to request a hearing on a motion to seal in advance of a pending substantive motion, or alternatively to continue the substantive motion.
Civil cases
Page 2 | Stipulated Protective Orders / Motions to Seal
Chambers Communication Rules
Noticed motion hearings are by reservation only on Fridays at 9:10 a.m.; reservations may be obtained by phone or via the court's website.
Noticed motion hearings are by reservation only and are set on Fridays at 9:10 a.m., or as set by the Court. Counsel may obtain reservations by contacting the calendar clerk by phone or by using the Reserve a Motion Date portion of the court's website (sdcourt.ca.gov).
Civil cases
Page 1 | Law and Motion
An informal discovery conference (IDC) is scheduled by contacting the calendar clerk by phone.
An IDC is scheduled by contacting the calendar clerk by phone.
Civil cases
Page 1 | Informal Discovery Conferences
The courtroom clerk can be reached at (619) 450-7062.
Courtroom Clerk. ................ (619) 450-7062
Civil cases
Page 1 | Courtroom Staff
Ex parte hearings are by reservation only on Tuesday, Wednesday, and Thursday at 8:30 a.m.; reservations are made by contacting the calendar clerk by phone.
Ex parte hearings are by reservation only on Tuesday, Wednesday, and Thursday at 8:30 a.m. or as set by the Court. Reservations are made by contacting the calendar clerk by phone.
Civil cases
Page 1 | Ex Parte Hearings
The calendar clerk can be reached at (619) 450-7051 during phone hours of 8:00 a.m.–12:00 p.m. and 1:00–3:00 p.m.
Calendar Clerk. .................. (619) 450-7051 (Phone hours: 8:00 am – 12:00 p.m. and 1:00 p.m. to 3:00 pm)
Civil cases
Page 1 | Courtroom Staff
Parties are not required to reserve a hearing date for a pro hac vice application.
Parties are not required to reserve a hearing date for the
Civil cases
Page 2 | Pro Hac Vice Applications