San Diego Superior Court Filing Rules

Parties are reminded to submit attachment form ADM-430 (formerly CIV-383, now repealed), except if for an adult dependent.

Each party must provide a complete hardcopy set of their exhibits no later than two court days before the first day of trial.

Parties must file an Interpreter Request/Cancellation Form (SDSC ADM-348) as soon as possible if an interpreter is needed.

Persons ordered to appear at failure hearings and witnesses expected to testify must appear in person unless expressly excused by the Court.

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.

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 papers must be filed by noon the day before the hearing; the court may not consider any late-filed papers.

Continued CMCs do not require a new statement unless there are substantial changes or trial availability changes.

Motions in limine follow local rule 2.1.18; trial briefs must be filed five court days before trial and are mandatory for court trials lasting more than one day.

An IDC does not toll the statutory deadline to file a motion to compel.

Each counsel must telephone the Courtroom Clerk before 10:00 am the day before the initial trial date and any continued trial call date to report readiness, estimated trial length, and jury requirement.

Parties are not required to reserve a hearing date for a pro hac vice application.

Ex parte appearances require a reservation with the Calendar Clerk and are held Tuesdays and Thursdays at 8:30 a.m.

Informal discovery conferences may be set by calling the calendar clerk.

Petitions for minor's compromise require telephone reservation with the calendar clerk; hearings are Mondays at 8:30 a.m.

All exhibits should be pre-marked and tabbed as: Petitioner - numbers; Respondent letters. If Respondent has more than 26 exhibits, Petitioner shall use 1-400 and Respondent shall use 401-800. Minor’s Counsel may use the Court’s Exhibit tags (brown) and shall begin with number 801.

Exhibits must be tabbed with exhibit number/letter in all binders and tagged with an exhibit sticker tag on the Clerk's copy.

All exhibits should be pre-marked and tabbed as: Petitioner - numbers; Respondent letters. If Respondent has more than 26 exhibits, Petitioner shall use 1-400 and Respondent shall use 401-800. Minor’s Counsel may use the Court’s Exhibit tags (brown) and shall begin with number 801.

Exhibit binders must not exceed 1 ½ inches thick; thicker binders may be returned to the party for reorganization.

Bank records and similar financial documents should be broken down into monthly periods, each labeled as a separate exhibit.

A courtesy copy of the Joint Trial Readiness Conference Report must be provided to the department.

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.

If depositions may be referenced at trial, a copy must be lodged with the clerk with the deponent's name written on it.

Trial Briefs

Exhibit lists must be provided to the court in three copies (for the court, the court clerk, and the court reporter if one is obtained).

The demurring party must meet and confer with the opposition to resolve objections and comply with CCP 430.41.

Counsel must meet and confer before any ex parte hearing to pare down disputed issues.

Meet and confer with the responding party before filing a discovery motion to compel.

Meaningful meet and confer required before filing any in limine motion.

Parties may be ordered to attend an IDC to discuss a discovery dispute that is the subject of a pending motion to compel.

Stipulated continuance requests require a written stipulation stating good cause; disputed requests should be made by ex parte application or noticed motion.

Non-stipulated continuance requests should be made by noticed motion or ex parte application, per Rules 3.1200-3.1207.

A trial date will not be continued on an ex parte application to advance a motion unless requested in the alternative or stipulated to.

Request to continue Trial, Trial Readiness Conference, and Motion Cut-off dates may be requested by Stipulation and Proposed Order. The Court will review the Stipulation and Proposed Order and if necessary, will call the parties to schedule an Ex-Parte hearing.

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.

Motions to compel initial responses must 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 reserved and filed as separate motions for each set of discovery at issue.

Replies to Motions in Limine are not permitted.

Each party must submit one set of 3-ring exhibit binders to the court (clerk), provide one set to the other party/counsel, and have binders available for witnesses.

Trial briefs should be separated from binders and/or boxes when delivered to Department 704 otherwise there is a high likelihood they will not be filed and/or reviewed by the Court prior to the start of the Trial/Evidentiary hearing.

No filing fee is required for a Declaration Re: Discovery Meet and Confer.

Ex parte papers require the appropriate fee.

No filing fee is charged for a minor's compromise hearing.

No fee is charged to file a Declaration Re: Discovery Meet and Confer.

Ex-Parte fees are due on or before 12:00 p.m. the day before the hearing in the Civil Business office.

Motion briefing filed with redactions or under seal requires a noticed motion to seal, and the motion will not be adjudicated until it is decided.

Documents may be filed under seal only in compliance with California Rules of Court Rule Nos. 2.550 and 2.551.

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.

Sealing requests must comply with CRC 2.550 and 2.551; records may not be sealed based solely on party stipulation.

Protective orders and motions to seal must comply with CRC rules 2.550/2.551; records are not sealed by stipulation alone, and substantive motions are held until the sealing hearing is resolved.

Trial briefs, witness lists, exhibit lists, and binders must be directly filed in Department 603; e-filing of trial documents is prohibited.

All pleadings, lodgments, and hardcopies of exhibits must be filed directly in Department 904; trial documents must not be e-filed, except exhibits which must be uploaded on the proper portal before trial.

All motion should be filed digitally, and a courtesy copy placed in Department 75's mailbox on the second floor in the Hall of Justice Civil Business Office.

All trial-related documents must be filed directly in Department 704; e-filing of trial documents is prohibited.

Trial documents must not be e-filed.

Parties must adhere to the page limitations set forth in CRC Rule 3.1113(d).

Parties must adhere to the page limitations for memoranda of points and authorities set forth in CRC 3.1113(d).

Each party must submit a concise IDC brief no longer than five pages before the Informal Discovery Conference.

Trial briefs are limited to 15 pages without leave of court.

Informal Discovery Conference briefs are limited to 5 pages.

Affidavits for service by publication will be scrutinized for reasonable diligence in attempting service by another manner, per CCP § 415.50(a).

Applications for orders to serve by publication may be submitted without an appearance; supporting affidavits are scrutinized for compliance with CCP 415.50(a).

Each party must serve all exhibits on every other party, either electronically or in hardcopy, at least five days before the trial or evidentiary hearing.

Each party must provide one set of exhibit binders to opposing counsel and have binders available to witnesses, with advance delivery of all exhibits to remote MS Teams witnesses.

All exhibits, demonstrative aids, and other material for opening statements must be shared with opposing counsel in advance.

The Court encourages law firms and government agencies to allow less experienced attorneys to argue motions, examine witnesses, conduct voir dire, and open/close a case.