San Diego Superior Court Filing Bundling Requirements

CRITICALCivil cases

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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).

CRITICALCivil cases

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)

CRITICALCivil cases

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.

CRITICALCivil cases

Motions to compel initial responses must be filed as a single motion regardless of the number of discovery sets at issue.

Motions to compel initial responses should be reserved and filed as a single motion regardless of the number of sets of discovery at issue.

CRITICALCivil cases

Discovery motions must not combine multiple parties; each party must file its own separate discovery motion.

Do not combine multiple parties, from whom discovery is sought to be compelled, into one joint motion. Each party should have its own separate discovery motion(s).

CRITICALCivil cases

Counsel must provide a three-ring binder with tabs to the Court on the Friday before trial containing trial briefs, pre-trial motions, jury instructions, verdict form, exhibit list, and witness list.

Counsel must provide a three-ring binder with tabs to the Court on the Friday before trial that includes the following: Trial Briefs All Pre-Trial Motions (including opposition and reply) All proposed jury instructions with brackets removed and edits made as to the specific case as needed A proposed verdict form Exhibit list Witness list

CRITICALCivil cases

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.

Each party must submit to the court one set of 3-ring binders containing your exhibits. This copy is for the clerk The Judge’s copy must be uploaded using the electronic evidence portal. Each party must also provide one set of exhibit binders to the other party/counsel and must have binders available to any witnesses at court or at their locations, including those who will be appearing on MS Teams only.

CRITICALCivil cases

Exhibits exceeding 50 pages must be compiled in 3-ring binders, and multiple binders must identify their contents on the front and spine.

Exhibit binders: If there are more than 50 pages of exhibits, they must be compiled in 3-ring binders. If you are submitting more than one binder, identify on the front and spine of the binder the exhibits contained therein.

CRITICAL

Parties must bring a separate binder with motions in limine and opposition, arranged in order, to trial call.

As set forth in the Advance Trial Review Order, the parties must bring a separate binder containing the motions in limine together with any opposition, arranged in order.

CRITICALCivil cases

Motions to compel initial responses must be filed as a single motion regardless of number of 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.

CRITICALCivil cases

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.

CRITICALCivil cases

A trial notebook containing the trial brief, pre-marked exhibits, exhibit list, and witness list must be delivered to the courtroom Clerk five court days before trial or hearing; two notebooks are required (one for the Court, one for the Clerk).

Five court days before the trial or hearing, the Court requires a trial notebook (notebook may be joint or individual) that includes the following be delivered to the courtroom Clerk.

CRITICALCivil cases

At least two (2) court days before trial, the parties are expected to provide the following materials: A Trial Binder with the following included: 1. Table of contents 2. Joint Trial Readiness Report 3. Limine motions and oppositions and index of Limine motions 4. Copy of Joint Witness List. Listing the witness as either percipient or expert. 5. Copy of Joint Exhibit List (follow grids format – see attachment to ADR, with objections noted) 6. Copy of Trial Briefs 7. Copy of the Operative Pleadings, e.g., Complaints and Answers.

At least two (2) court days before trial, the parties are expected to provide the following materials: A Trial Binder with the following included: 1. Table of contents 2. Joint Trial Readiness Report 3. Limine motions and oppositions and index of Limine motions 4. Copy of Joint Witness List. Listing the witness as either percipient or expert. 5. Copy of Joint Exhibit List (follow grids format – see attachment to ADR, with objections noted) 6. Copy of Trial Briefs 7. Copy of the Operative Pleadings, e.g., Complaints and Answers.

WARNINGCivil cases

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.

WARNINGCivil cases

Replies to Motions in Limine are not permitted.

No replies to MILs.

WARNINGCivil cases

Motions in Limine and any oppositions must be combined in a second notebook, not filed as separate notebooks.

Parties must also submit a second notebook containing Motions in Limine (MIL), followed by Oppositions, if any (not separate notebooks).

WARNINGCivil cases

Exhibits exceeding 50 pages must be compiled in 3-ring binders.

Exhibit binders: If there are more than 50 pages of exhibits, they must be compiled in 3-ring binders.

WARNINGCivil cases

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.

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.

WARNINGCivil cases

MILs and oppositions should be submitted in a second combined notebook (not separate notebooks), and no replies to MILs should be submitted.

Parties should also submit a second notebook containing Motions in Limine (MILs), followed by Oppositions, if any (not separate notebooks). No replies to MILs should be submitted.

WARNINGCivil cases

Parties should submit a second notebook containing Motions in Limine followed by Oppositions, not separate notebooks.

Parties should also submit a second notebook containing Motions in Limine (MIL), followed by Oppositions, if any (not separate notebooks).