San Diego Superior Court Document Filing Requirements

CRITICALCivil cases

Applies to

Trial call submission

At Trial Call, counsel must provide agreed jury instructions, verdict forms, Joint Trial Notebook, and In Limine Motion Notebook.

Counsel must provide agreed upon jury instructions and verdict forms. Additionally, counsel must provide a Joint Trial Notebook and an Inlimine Motion Notebook on this date (See Department 74 Trial Requirements). Failure to show up at Trial Call with these four items will result in a finding that you are not ready for trial.

CRITICALCivil cases

Applies to

Joint trial readiness conference report

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.

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).

CRITICALCivil cases

Applies to

Pro hac vice application

Must include

proposed order, certificate of service

Pro hac vice applications must comply with CRC 9.40 and include proof of service, proof of fee payment, and a proposed order.

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.

CRITICALCivil cases

Applies to

Joint trial notebook

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)

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)

CRITICALCivil cases

Applies to

Stipulated advisory to continue

Must include

proposed order

The stipulation should include a proposed order.

The stipulation should include a proposed order.

CRITICALCivil cases

Applies to

Guardian ad litem application

Guardian ad litem applications must include form CIV-383 unless the applicant is an adult dependent.

Guardian Ad Litem applications shall include attachment form CIV-383, except if an adult dependent.

CRITICALCivil cases

Applies to

Motion to seal

Must include

proposed order

A proposed sealing order must be provided to the Court setting forth the facts and legal basis.

A proposed sealing order must be provided to the Court setting forth the facts and legal

CRITICALCivil cases

Applies to

Application for determination of good faith settlement

Must include

proposed order

A proposed order must be submitted concurrently with a good-faith-settlement application and notice.

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).

CRITICALCivil cases

Applies to

Case management statement

Counsel must file a Case Management Statement per CRC rule 3.725.

Counsel shall file a Case Management Statement pursuant to California Rules of Court (“CRC”), rule 3.725.

CRITICALCivil cases

Applies to

Trial call documents

On the first day of trial, counsel must provide a Joint Witness List, Joint Exhibit List, Joint Statement of the Case, and Jury Instructions.

On the first day of trial, counsel/parties must provide to the Court: 1. Joint Witness List with a short sentence describing the witness (i.e. “Dr. Joe Smith, an internist from Mercy Hospital”); 2. Joint Exhibit List (follow grid format on attachment to the Advance Trial Review Orders); 3. Joint Statement of the Case; 4. Jury Instructions - in sequential order with a post-it note indicating who objects to the instruction;

CRITICALCivil cases

Applies to

Appearance

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

Persons ordered to appear to show cause why sanctions should not be imposed for violation of a Court Order or Rule (failure hearings) and witnesses for hearings where they are expected to testify are to appear in person unless expressly excused by the Court.

CRITICALCivil cases

Applies to

Appearance

In-person appearance is required for Ex Partes, TRCs, Trial Call, Motions in Limine, Trial, and TRO hearings.

You must appear in person for Ex Parte's, TRCs, Trial Call, Motions in Limine, Trial, and Hearings on Temporary Restraining Orders.

CRITICALCivil cases

Applies to

Cmc statement

Counsel must file a Case Management Conference statement per CRC Rule 3.725 and related rules.

Counsel shall file a CMC statement pursuant to CRC Rule 3.725 See CRC 3.700 et seq. particularly CRC 3.722, Local Rule 2.1.9 and CRC 3.110 and include CRC 3.727 issues.

CRITICALCivil cases

Applies to

Settled statement

If no court reporter is present, the parties must submit a daily settled statement.

In the absence of a court reporter, the parties must submit a daily settled statement.

CRITICALCivil cases

Applies to

Trial notebook

The Court requires a trial notebook containing an agreed statement of case, joint witness list, joint exhibit list with objections, joint jury instructions with index and objections, and proposed verdict forms.

The Court requires a trial notebook with an agreed statement of case, joint witness list, joint exhibit list with objections (otherwise waived) joint jury instructions with index, in order requested to be given (accompanied by objections including points and authorities), and proposed verdict forms/ special verdict forms.

CRITICALCivil cases

Applies to

Guardian ad litem form

Include form ADM-430 for Guardian Ad Litem (except adult dependent) and follow Local Rule 2.4.6; for publication see CCP 415.50(a).

Include form ADM-430 except for adult dependent. See Local Rule 2.4.6 for GAL requirements. For Publication see CCP 415.50(a)

CRITICALCivil cases

Applies to

Ex parte declaration

An ex parte declaration must state the issues in dispute, copies of requests, responses given, and the meet and confer.

A declaration stating the issues in dispute, copies of what has been requested, responses given and the meet and confer is required.

CRITICALCivil cases

Applies to

Proposed order

Must include

certificate of service

Documents submitted to the Court for review must include a proof of service; filings without one will not be reviewed, except for stipulations signed by all parties.

Documents submitted to the Court for review must be accompanied by a proof of service.

CRITICALCivil cases

Applies to

Trial notebook

Counsel must bring a joint trial notebook to trial call containing ten specified items, and failure to limit special verdict form disputes results in a general verdict form.

At trial call, counsel must bring a joint trial notebook, which should be comprised of the following: 1. Table of Contents 2. Copy of Joint Trial Readiness Report 3. Copies of Motion in Limine and Oppositions (in order) 4. Joint Witness List (with description of witnesses' expected testimony) 5. Joint Exhibit List 6. Copies of Trial Briefs (if any) 7. Joint Statement of the Case 8. Proposed Voir Dire Questions (if any) 9. Jury Instructions (packet agreed upon and packet of those not agreed upon, with indication of who is offering and objecting) 10. Special Verdict Form (either an agreed upon form or each side's proposed forms). If the parties fail to make a genuine effort to limit disputes on the form of the special verdict, a general verdict form will be utilized.

CRITICALCivil cases

Applies to

Proposed order

The proposed order should contain the following language: The determination by the court that the settlement was made in good faith shall bar any other joint tortfeasor or co-obligor from any further claims against the settling tortfeasor or co-obligor for equitable comparative contribution, or partial or comparative indemnity, based on comparative negligence or comparative fault. CCP §877.6(c).

The proposed order should contain the following language: The determination by the court that the settlement was made in good faith shall bar any other joint tortfeasor or co-obligor from any further claims against the settling tortfeasor or co-obligor for equitable comparative contribution, or partial or comparative indemnity, based on comparative negligence or comparative fault. CCP §877.6(c).

CRITICALCivil cases

Applies to

Application for good faith settlement

Must include

proposed order

For good faith settlement applications, the proposed order must be submitted concurrently with the notice and application.

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).

CRITICALCivil cases

Applies to

Joint trc report

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.

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.

CRITICALCivil cases

Applies to

Proposed order

A proposed sealing order must be provided to the Court setting forth the facts and legal basis supporting the sealing of each item.

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.

CRITICALCivil cases

Applies to

Trial notebook

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.

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

CRITICALCivil cases

Applies to

Default judgment

Default judgment papers must comply strictly with CRC Rule 3.1800; non-complying papers will be returned.

Papers must comply strictly with CRC Rule 3.1800. Non-complying papers will be returned with a notation of defects.

CRITICALCivil cases

Applies to

Guardian ad litem application

Guardian ad litem applications will not be granted unless the moving party submits the documents required by San Diego Superior Court Local Rules, Rule 2.4.6.

Applications for appointment of guardians ad litem will not be granted unless the moving party submits the documents required by the San Diego Superior Court Local Rules, Rule 2.4.6.

CRITICALCivil cases

Applies to

Trial brief

Trial briefs must be exchanged by the parties per California Rules of Court Rule 5.394 using form D-241 unless the court orders otherwise.

They are to be exchanged by the parties according to Rule 5.394 of the California Rules of Court unless specifically ordered otherwise by the court. The trial brief form (D-241) can be located on the court’s website.

CRITICALCivil cases

Applies to

Exhibits

Parties and witnesses appearing remotely must have copies of all necessary exhibits in advance of the hearing.

You must ensure that any parties or witnesses appearing remotely have copies of all necessary exhibits in advance of the hearing.

CRITICALCivil cases

Applies to

Income and expense declaration

Income and Expense Declarations must be complete per statutory requirements, follow FL-150 directions, include proof of income, and the most recent tax return must be brought to the hearing.

Please be sure Income and Expense Declarations are complete per statutory requirements and follow directions on the form FL-150, providing proof of income and bringing your most recent tax return to the hearing.

CRITICALCivil cases

Applies to

Expert report

Experts must meet and confer before trial and provide the court a side-by-side comparison showing differences, reasons for differences, and agreements on the issues covered by their reports.

Experts must meet and confer prior to the trial. They must prepare a side-by-side comparison that must be provided to the court showing the differences and the reasons for the differences and any agreements on the same issues for which they have submitted a report to the court for the trial (i.e. income available for support, business valuation).

CRITICALCivil cases

Applies to

Exhibits

Parties must provide their own laptop or equipment to present electronically stored evidence at trial because the Court cannot insert storage devices into its computers.

Be advised that the Court does not have the capability of presenting electronically stored evidence using its own equipment. The Court has a screen on which evidence can be shown, and cables that can be connected to a laptop, but will not be able to insert flash drives, memory sticks, CDs, or other storage devices into court computers or laptops. Therefore, you must provide your own laptop or other equipment to show that evidence during the trial.

CRITICALCivil cases

Applies to

Trial readiness report

A completed joint trial readiness conference report must be filed in advance of the hearing per local rule 2.1.15.

A completed joint trial readiness conference report shall be filed in advance of the hearing pursuant to local rule 2.1.15.

CRITICALCivil cases

Applies to

Pro hac vice application

Must include

proposed order, certificate of service

Pro hac vice applications must include proof of service on the State Bar of California, proof of payment of the required fee, and a proposed order.

Applications must include proof of service on the State Bar of California, proof of payment of the required fee, and a proposed order.

CRITICALCivil cases

Applies to

Motion in limine

All motions in limine must be filed per local rule 2.1.18.

All motions in limine must be filed per local rule 2.1.18.

CRITICALCivil cases

Applies to

Joint trial notebook

At trial call, counsel must bring a joint trial notebook containing the enumerated pretrial materials.

At trial call, counsel must bring a joint trial notebook, which should be comprised of the following: 1. Table of Contents 2. Copy of Joint Trial Readiness Report 3. Copies of Motion in Limine and Oppositions (in order) 4. Joint Witness List (with description of witnesses’ expected testimony) 5. Joint Exhibit List 6. Copies of Trial Briefs (if any) 7. Joint Statement of the Case 8. Proposed Voir Dire Questions (if any) 9. Jury Instructions (packet agreed upon and packet of those not agreed upon, with indication of who is offering and objecting)

CRITICALCivil cases

Applies to

Exhibit book

All exhibits must be pre-marked in an up-to-date exhibit book.

All exhibits must be pre-marked in an up-to-date exhibit book.

CRITICALCivil cases

Applies to

Default judgment papers

Default judgment papers must strictly comply with California Rules of Court rule 3.1800; non-complying papers will be returned with a notation of defects.

Papers must comply strictly with California Rules of Court, rule 3.1800. Non- complying papers will be returned with a notation of defects.

CRITICALCivil cases

Applies to

Default judgment

Default judgment papers must comply with CRC rule 3.1800; noncomplying papers will be returned with defects noted.

Papers must comply with California Rules of Court, rule 3.1800. Noncomplying papers will be returned with a notation of defects.

CRITICALCivil cases

Applies to

Joint trial notebook

Virtual appearance at Trial Call requires prior submission of a Joint Trial Notebook containing ten specified items.

The Court allows virtual appearances at Trial Call only if parties previously submitted a Joint Trial Notebook, containing: 1. Table of Contents 2. Copy of Joint Trial Readiness Report 3. Copies of Motion in Limine and Oppositions (in order) 4. Joint Witness List (with description of witnesses' expected testimony) 5. Joint Exhibit List (with objections noted) 6. Copies of Trial Briefs (if any) 7. Joint Statement of the Case 8. Proposed Voir Dire Questions (if any) 9. Jury Instructions (packet agreed upon and packet of those not agreed upon, with indication of who is offering and objecting) 10. Special Verdict Form (either an agreed upon form or each side's proposed forms). If the parties fail to make a genuine effort to limit disputes on the form of the special verdict, a general verdict form will be utilized.

CRITICALCivil cases

Applies to

Exhibit binder

All exhibits must be pre-marked in an up-to-date exhibit binder.

All exhibits must be pre-marked in an up-to-date exhibit binder.

CRITICAL

Applies to

Joint trial notebook

For virtual trial call appearance, the Court must have the joint trial notebook containing agreed statement, witness list, exhibit list, jury instructions, and proposed verdict forms.

for parties to appear virtually at Trial Call, the Court must have in hand the joint trial notebook containing the following: 1. Agreed upon statement of the case; or a request for mini-opening per CCP§ 222.5(d) 2. 3 copies of the Joint Witness List (all witnesses in alphabetical order on one list.) 3. 3 copies of the Joint Exhibit List with objections, numbered sequentially. (Absent good cause, a party who has offered no objection(s) to an exhibit is forestalled from objecting to the exhibit at trial.) 4. Joint set of jury instructions, together with index, in the order in which they are requested to be given, with objections noted 5. Proposed verdict form(s)

CRITICAL

Applies to

Guardian ad litem application

Guardian ad litem applications must include attachment form CIV-383, except for adult dependents.

Guardian ad litem applications shall include attachment form CIV-383, except if adult dependent.

CRITICAL

Applies to

Joint trial notebook

Unless virtual permission is granted, parties must appear in person at trial call and bring the Joint Trial Notebook.

Unless permission to appear virtually is granted (usually at the trial readiness conference), the parties are to appear in person at the trial call and bring with them the Joint Trial Notebook as ordered in the Trial Requirements section of the Advance Trial Review Order.

CRITICAL

Applies to

Advance trial review order

Parties announcing ready must review and sign the Court's Advance Trial Review Order.

Parties announcing ready will be required to review and sign the Court's Advance Trial Review Order, a copy of which is included on the court website.

CRITICALCivil cases

Applies to

Brief

The joint IDC brief must identify the specific matters in dispute.

The parties must submit a joint brief, no longer than 5 pages, by the Friday before the IDC, listing the specific matters in dispute.

CRITICALCivil cases

Applies to

Joint trial notebook

Counsel must provide a Joint Trial Notebook at Trial Call containing the ten listed items and following the stated requirements for witness descriptions, exhibits, jury instructions, and verdict forms.

Counsel are required to provide a Joint Trial Notebook at Trial Call that includes: 1. Table of Contents; 2. Joint Trial Readiness Report; 3. Motions In Limine / Oppositions with an index of the motions; 4. Joint Witness List with a short sentence describing the witness (i.e. "Dr. Jane Smith, an internist from Mercy Hospital"); 5. Joint Exhibit List (follow grid format on attachment to the Advance Trial Review Orders); 6. Trial Briefs; 7. Joint Statement of the Case (if not in Joint Trial Readiness Report); 8. Proposed Voir Dire questions counsel want the Court to ask; 9. Jury Instructions - One set in sequential order with a post-it note indicating who objects to the instruction; 10. Special Verdict Forms - either agreed upon forms or each side’s proposed forms. The forms should follow CACI as closely as possible and include all cause of actions and all parties. The verdict forms should be complete and on pleading paper without the firm name.

CRITICALCivil cases

Applies to

Application for good faith settlement

Must include

proposed order

Application for good faith settlement and proposed order must be concurrently filed.

The application for good faith settlement pursuant to Code of Civil Procedure section 877.6(a)(2) and proposed order shall be concurrently filed, after which it will be held the requisite statutory period (20 days plus 5 for mailing).

CRITICALCivil cases

Applies to

Trial notebook

Counsel must bring a joint trial notebook to trial call with specified contents.

At trial call, counsel must bring a joint trial notebook, which should include the following: 1. Table of Contents 2. Copy of the Joint Trial Readiness Report 3. Copies of Motions in Limine and Oppositions (in order) 4. 3 copies of the Joint Witness List (with description of witnesses’ expected testimony) 5. 2 copies of the Joint Exhibit List 6. Copies of Trial Briefs (if any) 7. Joint Statement of the Case, in neutral language suitable to be read to prospective jurors. 8. Voir Dire questions counsel requests court to ask 9. Jury Instructions (packet agreed upon and packet of those not agreed upon, with indication of who is offering and objecting) 10. Special Verdict Form - either an agreed upon form or each side’s proposed forms. If the parties fail to make a genuine effort to limit disputes over the form of the special verdict, a general verdict form will be used.

CRITICALCivil cases

Applies to

Motion cutoff date request

Must include

proposed order

Motion cutoff dates may be requested by submitting a written Stipulation and Proposed Order, and upon a good cause finding will be granted without an appearance.

Motion cutoff dates may be requested by submitting a written Stipulation and Proposed Order, and upon a good cause finding will be granted without an appearance.

CRITICALCivil cases

Applies to

Default judgment papers

Default judgment papers must comply strictly with CRC 3.1800; non-complying papers will be returned.

Papers must comply strictly with California Rules of Court, rule 3.1800. Non-complying papers will be returned with a notation of defects.

CRITICALCivil cases

Applies to

Increased bid open court

An overbidding party must present proof of an appropriate deposit when submitting the SDSC PR-65 form at the hearing.

Any overbidding party must present proof of an appropriate deposit when submitting the SDSC PR-65 form at the hearing.

CRITICALCivil cases

Applies to

Ex parte application

A request to waive notice will not be considered when the recipient or address is unknown unless the CRC 7.52 declaration is submitted.

The Court will not consider a request to waive notice when the recipient or the recipient's address is unknown unless the declaration required by California Rule of Court 7.52 is submitted.

CRITICALCivil cases

Applies to

Ex parte application

Must include

proposed order

Ex parte applicants must comply with SDSC Rules 4.7.5 and 4.7.6, including submitting a separately prepared proposed order.

In addition to compliance with California Rules of Court 3.1200 et seq., all applicants for ex parte relief must comply with San Diego Superior Court Rules 4.7.5 and 4.7.6, including submission of a separately prepared proposed order.

CRITICALCivil cases

Applies to

Ex parte application

An Ex Parte Application requires an affirmative factual showing, by declaration of competent, personal-knowledge testimony, of irreparable harm, immediate danger, or another statutory basis for relief.

Counsel are reminded that, per California Rule of Court 3.1202(c), an Ex Parte Application requires an affirmative factual showing by declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger or some other statutory basis for ex parte relief.

CRITICALCivil cases

Applies to

Ex parte application

Every request for an Ex Parte order must include a Declaration of Notice complying with CRC 3.1204.

A separate Declaration of Notice that complies with California Rule of Court 3.1204 must accompany every request for an Ex Parte order.

CRITICAL

Applies to

Increased bid form

A successful overbidder must complete, sign, and file the Increased Bid in Open Court form (SDSC PR-065) before the hearing concludes or confirmation fails.

When there is a successful overbid in open court on a sale of real property, an “Increased Bid in Open Court” (SDSC PR-065) must be completed, signed, and filed with the court before the conclusion of the hearing; otherwise, confirmation is not effective.

CRITICAL

Applies to

Exhibits

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

Each party must provide a complete hardcopy set of their exhibits no later than two (2) court days before the first day of the trial/evidentiary hearing.

CRITICAL

Applies to

Exhibits

The clerk must receive one complete set of each party's exhibits, and witnesses must have a complete set (hardcopy or IPad); remote witnesses must be provided relevant exhibits in advance.

The clerk must in all cases be provided one complete set of each party's exhibits. Each party is also required to ensure that the witnesses have a complete set of exhibits to use, either in hardcopy, or on an IPad. If a witness is appearing remotely, that witness must previously have been provided with a set of all exhibits relevant to their testimony.

CRITICAL

Applies to

Trial readiness conference statement

Parties must provide a joint statement before each Trial Readiness Conference unless excused by the Court.

The parties must comply with the requirements of Local Rule 5.8.3 and provide a joint statement before each TRC, unless excused by the Court.

CRITICAL

Applies to

Trial brief

Trial brief, exhibit list, and witness list must be delivered to the Department no later than seven court days before the trial or evidentiary hearing.

Unless the Court states otherwise at the TRC, a trial/evidentiary hearing brief, exhibit list, and witness list are requi red and must be delivered directly to this Department no later than seven court days (not calendar days) in advance of the trial/evidentiary hearing.

CRITICAL

Applies to

Exhibits

Each party must ensure sufficient copies of all impeachment and rebuttal documents used at trial for the Court, witnesses, and other parties.

each party must ensure there is a sufficient number of copies of all impeachment and rebuttal documents used at trial, for use by the Court, the witness, and the other parties.

CRITICAL

Applies to

Exhibits

Exhibit binders must include a cover page listing all exhibits with a column for the Court to mark admission status and date.

Your binder must include a cover page listing all exhibits with a column in which the Court can mark whether it was admitted or not, and on what date.

CRITICALCivil cases

Applies to

Discovery motion

Discovery motions must include copies of the relevant discovery requests and responses.

Include a copy of the relevant discovery requests and responses with your discovery motion.

CRITICALCivil cases

Applies to

Trial brief

Parties must serve and file SDSC Form D-241 (or a substantially similar brief) at least 5 court days before the long cause hearing or trial.

Copy of Trial/RFO Brief - Pursuant to California Rules of Court 5.393 and 5.394 and San Diego Superior Court Local Rule 5.8.2, the parties are to serve and file San Diego Superior Court Form D-241 (or a separate brief containing the same information in substantially the same format) at least 5 court days before the long cause hearing or trial.

CRITICALCivil cases

Applies to

Trial brief

Trial briefs must be filed per CRC 5.393/5.394 and Local Rule 5.8.2, using Form D-241 or an equivalent brief, at least five court days before the hearing.

Trial briefs are required be filed in accordance with 5.394 California Rules of Court 5.393 and 5.394 and San Diego Superior Court Local Rule 5.8.2. The parties are to file and serve San Diego Superior Court Form D-241 (or a separate brief containing the same information in substantially the same format) at least five (5) court days prior to the hearing.

CRITICALCivil cases

Applies to

Exhibit list

An exhibit list in grid format with the required heading must be included.

EXHIBIT LIST - Grid format (see below for example) containing the required heading.

CRITICAL

Applies to

Trial plan statement

Parties requesting a TSC must submit a joint or separate trial plan statement including time estimate, issues, witness count, remote/in-person status, and expert witness information.

If the parties are asking for a TSC, they must submit a joint statement (preferred) or separate statements on their trial plans, including time estimate, the issues expected to be tried, the number of witnesses, whether the witnesses will be remote or in person, and whether there will be experts witnesses.

CRITICAL

Applies to

Supervisor form

Supervisors must file FL-324P or FL-324NP before court-ordered visitations.

Professional and nonprofessional supervisors must fill out and file forms FL-324P (professional) or FL-324NP (nonprofessional) prior to any court-ordered visitations taking place.

CRITICALCivil cases

Applies to

Exhibits

Witness exhibit copies must be marked like clerk exhibits and pre-filled with exhibit #, case #, and department #; no additional judge copy is needed.

Parties shall provide a copy of the exhibits for the witnesses to refer to during testimony that shall be marked in the same manner as the exhibits provided to the clerk, and must be pre-filled with exhibit #, case # and department #. An additional copy for the judge is not necessary.

CRITICALCivil cases

Applies to

Guardian ad litem application

Guardian Ad Litem applications are not granted ex parte unless the moving party submits a declaration with specified showings.

Guardian Ad Litem applications will not be granted ex parte unless the moving party submits a declaration showing: a) the minor is not the subject of a juvenile dependency proceeding; b) the minor is not the subject of a probate guardianship; c) if the parents are not living together, attaching a copy of the current child custody order.

CRITICALCivil cases

Applies to

Jury trial materials

For jury trials, parties must also provide a Joint Statement of the Case, Voir Dire questions, Jury Instructions packets, and a Special Verdict Form.

For Jury Trials, the parties are also expected to provide the following: 8. Joint Statement of the Case 9. Voir Dire questions counsel requests Court to ask 10. Jury Instructions – packet of agreed upon instructions and packet of not agreed upon instructions with a post-it note indicating who opposes the instruction 11. Special Verdict Form – either an agreed upon form or each side's proposed Special Verdict Form

CRITICAL

Applies to

Joint trial notebook

The Joint Trial Notebook presented at Trial Call must contain a Table of Contents.

At Trial Call, trial counsel and self-represented litigants are required to present their Joint Trial Notebook, which must contain the following: 1. Table of Contents;

CRITICAL

Applies to

Trial readiness conference report

The Joint Trial Readiness Conference Report must include a statement of the case, witness list, exhibit list, jury instructions, and proposed verdict form.

The Joint Trial Readiness Conference Report must 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. 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).

CRITICALCivil cases

Applies to

Joint trial readiness conference report

If the case is not resolved, a completed Joint Trial Readiness Conference Report must be filed.

If the case is not resolved, a completed Joint Trial Readiness Conference Report shall be filed five (5) days before the scheduled TRC.

CRITICALCivil cases

Applies to

Joint trial notebook

A Joint Trial Notebook with ten specified components must be provided at Trial Call.

Counsel are to provide a Joint Trial Notebook on this date that includes: 1. Table of Contents; 2. Joint Trial Readiness Report; 3. Motions In Limine / Oppositions with an index of the motions; 4. Joint Witness List with a short sentence describing the witness (i.e. "Dr. Jane Smith, an internist from Mercy Hospital"); 5. Joint Exhibit List (follow grid format on attachment to the Advance Trial Review Orders); 6. Trial Briefs; 7. Joint Statement of the Case (if not in Joint Trial Readiness Report); 8. Proposed Voir Dire questions counsel want the Court to ask; 9. Jury Instructions - One set in sequential order with a post-it note indicating who objects to the instruction; 10. Special Verdict Forms - either agreed upon forms or each side’s proposed forms. The forms should follow CACI as closely as possible and include all cause of actions and all parties. The verdict forms should be complete and on pleading paper without the firm name.

CRITICALCivil cases

Applies to

Joint trial readiness report

A complete joint trial readiness conference report is required.

A complete joint trial readiness conference report must be filed five days prior to the scheduled hearing.

CRITICALCivil cases

Applies to

Ex parte declaration

Ex parte filings must include a declaration stating disputed issues and attaching requests and responses.

A short declaration stating the issues in dispute along with attached copies of what has been requested and any responses given must be filed.

CRITICALCivil cases

Applies to

Joint trial notebook

Virtual appearances at Trial Call are allowed only if a joint trial notebook containing specified items was previously submitted.

The Court allows virtual appearances at Trial Call only if parties previously submitted a joint trial notebook, containing: 1. Agreed upon statement of the case; 2. Joint Witness List (all witnesses on one list); 3. Joint Exhibit List, with objections noted; 4. Joint set of jury instructions, in the order they are to be given (with objections noted); 5. Proposed verdict form(s).

CRITICALCivil cases

Applies to

Guardian ad litem application

Guardian ad litem applications will not be granted unless the moving party submits the documents required by Local Rule 2.4.6.

Applications for appointment of guardians ad litem will not be granted unless the moving party submits the documents required by the San Diego Superior Court Local Rule 2.4.6.

CRITICALCivil cases

Parties must comply with the California Rules of Court and San Diego Superior Court Local Rule 2.1.9 for CMCs.

Parties must comply with California Rules of Court and San Diego Superior Court Local Rule 2.1.9.

CRITICALCivil cases

Applies to

Reply

Replies to Motions in Limine are not permitted.

No replies to MILs.

CRITICALCivil cases

Applies to

Ex parte application

All ex parte applications must comply with the California Rules of Court.

All ex parte applications must comply with the California Rules of Court.

CRITICALCivil cases

Applies to

Moving papers

Submit moving papers for review; the court may set a hearing if such hearing is deemed necessary.

Submit moving papers for review; the court may set a hearing if such hearing is deemed necessary.

WARNINGCivil cases

Applies to

Case management order

The Case Management Order must designate dates for Trial and Trial Readiness Conference.

The CMO shall designate a date for both the Trial and Trial Readiness Conference.

WARNINGCivil cases

Applies to

Trial readiness conference report

Trial readiness conference report must include estimated trial length.

The report must include the estimated trial length.

WARNINGCivil cases

Applies to

Case management order

Counsel must prepare a Case Management Order using the standardized CMO unless the case is not complex.

Unless otherwise ordered, counsel are to prepare a Case Management Order using the standardized CMO available on the Court’s website. A CMO is not required if the case is not complex as defined in California Rules of Court, rule 3.400.

WARNINGCivil cases

Applies to

Case management order

The Case Management Order must designate a date for naming new parties.

The CMO shall designate a date by which all new parties are to be named.

WARNINGCivil cases

Applies to

In limine motion

Unopposed in limine motions shall not be filed.

If the motion will be unopposed, the motion shall not be filed.

WARNINGCivil cases

Applies to

Ex parte papers

Ex parte papers must include a declaration of the disputed issues with attached requests and responses.

A short declaration stating the issues in dispute along with attached copies of what has been requested and any responses given must be filed.

WARNINGCivil cases

Applies to

Proposed stipulated protective order

Proposed stipulated protective orders must use language consistent with the Court's stated policy for protection of confidential information.

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.

WARNINGCivil cases

Applies to

Application for order for publication of summons

Applications for orders for publication of summons may be submitted for review without an appearance. Please use the local forms CIV 48, CIV 49.

Applications for orders for publication of summons may be submitted for review without an appearance. Please use the local forms CIV 48, CIV 49.

WARNINGCivil cases

Applies to

Exhibit list

Exhibit lists must be formatted in the court's specified format to ensure correct identification and receipt of exhibits.

To assist the clerk and for the benefit of all to ensure the exhibits are correctly identified and received, please be sure the exhibit list is formatted as follows:

WARNINGCivil cases

Applies to

Exhibit tag

Exhibit sticker tags must have the exhibit number, case number, and department number pre-written.

The exhibit sticker tag is to have the exhibit number, case number and department number pre-written as follows:

WARNINGCivil cases

Applies to

Trial brief

Exhibits referenced in pre-trial filings (trial briefs or Motions in Limine) must be attached to those filings.

However, any exhibits referenced in the respective pre-trial filings (trial briefs and/or Motions in Limine) shall be attached to those briefs.

WARNINGCivil cases

Applies to

Discovery motion

The moving party may submit a concise outline of the discovery request and each response; requests and responses should be submitted as exhibits, tabbed and highlighted.

Moving party may submit a concise outline of the discovery request and each response in the dispute. Local Rule 2.1.21 prior order permitting this is not required. Instead submit the requests and responses as exhibits to the motion, tabbing and highlighting the relevant portions.

WARNINGCivil cases

Applies to

Lodged document

Lodged documents will be discarded or destroyed if not accompanied by an addressed envelope with sufficient postage or picked up within 10 days.

Documents / materials lodged with the court will be discarded/ destroyed if not accompanied by an addressed envelope with sufficient postage or picked up within 10 days See CRC 3.1302(b).

WARNINGCivil cases

Applies to

Proposed order

Proposed stipulated protective orders will only be approved if their language is consistent with the Court's stated sealing policy.

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 discussed above.

WARNINGCivil cases

Applies to

Advanced trial review order

Please review the department Advanced Trial Review Order and Sanchez Waiver prior to any Trial Readiness Conference hearing. The Court requests that a signed copy of these documents be brought to the first day of trial.

Please review the department Advanced Trial Review Order and Sanchez Waiver prior to any Trial Readiness Conference hearing. The Court requests that a signed copy of these documents be brought to the first day of trial.

WARNINGCivil cases

Applies to

Trial readiness report

A completed joint trial readiness conference report must be filed in advance of the hearing per local rule 2.1.15.

A completed joint trial readiness conference report shall be filed in advance of the hearing pursuant to local rule 2.1.15.

WARNINGCivil cases

Applies to

Exhibits

All exhibits must be pre-marked in an up-to-date exhibit book.

All exhibits must be pre-marked in an up-to-date exhibit book.

WARNINGCivil cases

Applies to

Exhibits

Exhibits, demonstrative aids, and other opening statement materials must be shared with opposing counsel in advance.

All exhibits, demonstrative aids, or other material to be used in opening statements must be shared with opposing counsel in advance.

WARNINGCivil cases

Applies to

Motion in limine

All motions in limine must be filed in accordance with local rule 2.1.18.

All motions in limine must be filed per local rule 2.1.18.

WARNINGCivil cases

Applies to

Guardian ad litem application

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

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

WARNINGCivil cases

Applies to

Motion

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.

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.

WARNINGCivil cases

Applies to

Petition for minors compromise

Guardians ad litem must appear at the time of the hearing.

Guardians ad litem must appear at the time of the hearing.

WARNINGCivil cases

Applies to

Lodged material

Lodged materials must be accompanied by an addressed envelope with sufficient postage for return mailing per CRC Rule 3.1302(b).

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.

WARNINGCivil cases

Applies to

Ex parte application

All ex parte applications must comply with CRC Rule 3.1200, et seq.

All ex parte applications must comply with California Rules of Court (CRC) Rule 3.1200, et seq.

WARNINGCivil cases

Applies to

Pro hac vice application

Must include

proposed order, certificate of service

Pro hac vice applications must comply with CRC Rule 9.40 and include proof of service on the State Bar, proof of payment of the required fee, and a proposed order.

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.

WARNINGCivil cases

Applies to

Exhibits

All exhibits should be pre-marked, with pages numbered.

All exhibits should be pre-marked, with pages numbered.

WARNINGCivil cases

Applies to

Joint trial notebook

Virtual appearance at Trial Call is permitted only if a joint trial notebook has been previously submitted, containing the statement of the case, joint witness list, joint exhibit list, jury instructions, and proposed verdict forms.

The Court allows virtual appearances at Trial Call only if parties previously submitted a joint trial notebook, containing: 1. Agreed upon statement of the case; 2. Joint Witness List (all witnesses on one list); 3. Joint Exhibit List, with objections noted; 4. Joint set of jury instructions, in the order they are to be given with objections noted; 5. Proposed verdict form(s).

WARNINGCivil cases

Applies to

Exhibit list

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

Exhibit lists are to be provided to the court. Three (3) copies are to be provided – for the court, the court clerk, and the court reporter (if one is obtained by the parties).

WARNINGCivil cases

Applies to

Exhibits

Please be sure to include a means of return for all exhibits.

Please be sure to include a means of return for all exhibits.

WARNINGCivil cases

Applies to

Income and expense declaration

Income and expense declarations must be complete per statutory requirements and follow the directions on form FL-150.

Please be sure income and expense declarations are complete per statutory requirements and follow directions on the form FL-150.

WARNINGCivil cases

Applies to

Expert comparison

Experts must meet and confer and provide the court a side-by-side comparison of their reports showing differences, reasons, and agreements.

Experts must meet and confer prior to the trial. They must prepare a side-by-side comparison that must be provided to the court showing the differences and the reasons for the differences and any agreements on the same issues for which they have submitted a report to the court for the trial (i.e. income available for support, business valuation).

WARNINGCivil cases

Applies to

Exhibits

Text messages and social media posts must be identified by date and time on the exhibit.

Any text messages or social media posts must be identified by date and time on the exhibit.

WARNINGCivil cases

Applies to

Exhibits

Bank records and similar documents must be broken down into monthly periods, with each month labeled as a separate exhibit and multi-page documents bates stamped.

Documents such as bank records should be broken down to monthly periods. For example, bank statements for the period 1/1/22 through 1/31/22 shall be labeled as exhibit 1; bank statements for the period 2/1/22 through 2/28/22 shall be labeled as exhibit 2, and so on and so forth. The multi-paged documents should be bates stamped as indicated above.

WARNINGCivil cases

Applies to

Interpreter request form

If an interpreter is needed for a party or witness, please complete and file the Interpreter Request/Cancellation Form (SDSC ADM-348) as soon as possible. Please keep in mind, the Interpreter Request form should be filed at least 3-4 weeks in advance of the hearing/trial or it’s possible an interpreter will not be available.

If an interpreter is needed for a party or witness, please complete and file the Interpreter Request/Cancellation Form (SDSC ADM-348) as soon as possible. Please keep in mind, the Interpreter Request form should be filed at least 3-4 weeks in advance of the hearing/trial or it’s possible an interpreter will not be available.

WARNINGCivil cases

Applies to

Interpreter request form

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

If an interpreter is needed for a party or witness, please complete and file the Interpreter Request/Cancellation Form (SDSC ADM-348) as soon as possible.

WARNINGCivil cases

Applies to

Exhibits

If iPads are used for exhibits, all parties must provide one set of hard copy exhibits for the clerk to mark and for use in the event of equipment failure.

If iPads are utilized, one set of hard copy exhibits shall be provided by all parties, to be marked by the clerk and/or used in the event of equipment failure.

WARNINGCivil cases

Applies to

Trial brief

Trial briefs must be exchanged per California Rule of Court 5.394 unless the court orders otherwise, and must use form D-241.

They are to be exchanged by the parties according to Rule 5.394 of the California Rules of Court unless specifically ordered otherwise by the court. The trial brief form (D-241) can be located on the court’s website.

WARNINGCivil cases

Applies to

Exhibits

Text messages and social media posts must be identified by date and time on the exhibit.

Any text messages or social media posts must be identified by date and time on the exhibit.

WARNINGCivil cases

Applies to

Child testimony

Please provide the Court with a picture of the child/children.

Please provide the Court with a picture of the child/children.

WARNINGCivil cases

Applies to

Income and expense declaration

A current Income and Expense declaration must be filed and served with trial or evidentiary documents when financial relief is requested.

If a child support, spousal support, attorney fee, sanctions (if applicable) or financial request is being request, a current Income and Expense declaration must be filed and served with your trial/evidentiary documents.

WARNINGCivil cases

Applies to

Interpreter request form

File the Interpreter request/cancellation form (SDSC ADM-148) as soon as possible, generally 3-4 weeks before a hearing or trial.

If an interpreter is needed for a party or witness, please complete and file the Interpreter request/cancellation form (SDSC ADM-148) as soon as possible. Generally, it should be filed 3-4 weeks in advance of a hearing/trial.

WARNINGCivil cases

Applies to

Special verdict form

If the parties fail to make a genuine effort to limit disputes on the special verdict form, the court will utilize a general verdict form.

10. Special Verdict Form (either an agreed upon form or each side’s proposed forms). If the parties fail to make a genuine effort to limit disputes on the form of the special verdict, a general verdict form will be utilized.

WARNINGCivil cases

Applies to

Proposed default judgment

Proposed default judgments claiming punitive or non-economic damages will usually require a hearing.

Proposed default judgments claiming punitive damages and/or non-economic damages will usually require a hearing.

WARNINGCivil cases

Applies to

Stipulation

Must include

proposed order

A proposed order must accompany any stipulation to continue dates or deadlines.

Please provide a proposed order with any stipulation.

WARNING

Applies to

Exhibits

All exhibits must be pre-marked and have numbered pages.

All exhibits should be pre-marked, with pages numbered.

WARNINGCivil cases

Applies to

Proposed order

The proposed order should include the dates the parties are agreeing to.

The Proposed Order should have the proposed dates that the parties or agreeing to.

WARNINGCivil cases

Applies to

Application for order to serve by publication

Applications for order to serve by publication may be submitted without appearance; court will scrutinize affidavits for diligence.

Applications requesting an order to serve by publication may be submitted for review without an appearance. The Court will scrutinize affidavits to determine whether the applicant has been reasonably diligent in attempting service in another manner, as required by Code of Civil Procedure section 415.50, subdivision (a) and CRC 379.

WARNINGCivil cases

Applies to

Motion

If a concise outline is submitted, copies of the actual requests and responses must be submitted as exhibits to the motion.

In accordance with local rule 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 to the motion.

WARNINGCivil cases

Applies to

Increased bid open court

To satisfy the 'responsible person' requirement, the overbidding party is expected to have certified funds or cashier's checks equal to at least 10% of the bid plus a loan qualification letter or bank statements at the confirmation hearing.

In making the determination whether the “responsible person” requirement has been met, the court will consider whether the overbidding party has in his or her possession at the confirmation hearing sufficient certified funds or cashier’s checks as a deposit in an amount equal to at least 10% of the amount he or she will bid, and a loan qualification letter or bank statements verifying the buyer’s ability to complete the sale.

WARNINGCivil cases

Applies to

Ex parte application

A reservation for a contested ex parte hearing is obtained by submitting the PR-136 Ex Parte Coversheet with the application and order to the Business Office; the number of reservations is limited.

A reservation may be obtained by submitting to the Business Office the Probate Ex Parte Coversheet (PR-136) with an Ex Parte Application and order. There is a limit on the number of reservations.

WARNINGCivil cases

Applies to

Trial brief

Trial briefs must include enumeration of issues and party positions with relief sought, statements of applicable facts and law including standards and burdens of proof, unusual evidentiary or legal issues, and all stipulated facts.

Trial briefs should include: (a) enumeration of the issues to be tried and the parties’ positions thereon, including the relief sought (and any specific dollar amounts sought) on the enumerated issues; (b) statements of the applicable facts and law, including the applicable standard(s) of proof, the party bearing the burden of proof and any burden shifting; (c) any unusual evidentiary or legal issues anticipated at trial; and (d) all matters of fact to which the parties stipulate.

WARNING

Applies to

Trial brief

Trial briefs should include: (a) enumeration of the issues to be tried and the parties’ positions thereon, including the relief sought (and any specific dollar amounts sought) on the enumerated issues as delineated the original petition; (b) statements of the applicable facts and law, including the applicable standard(s) of proof, the party bearing the burden of proof and any burden shifting; (c) any unusual evidentiary or legal issues anticipated at trial; and (d) all matters of fact to which the parties stipulate.

Trial briefs should include: (a) enumeration of the issues to be tried and the parties’ positions thereon, including the relief sought (and any specific dollar amounts sought) on the enumerated issues as delineated the original petition; (b) statements of the applicable facts and law, including the applicable standard(s) of proof, the party bearing the burden of proof and any burden shifting; (c) any unusual evidentiary or legal issues anticipated at trial; and (d) all matters of fact to which the parties stipulate.

WARNING

Applies to

Stipulation and order

Stipulations and orders must clearly identify the hearings and petitions, including all ROA numbers, to be vacated, dismissed, or taken off calendar.

Any stipulation/orders filed by the parties shall clearly state the hearings and petitions, including all ROA#s to be vacated, dismissed or taken-off calendar.

WARNING

Parties appearing on MS Teams or wishing to present evidence electronically must request at the appropriate time that the Court make them a presenter.

If you will be appearing on MS Teams and/or wish to present your evidence electronically, you will need to request at the appropriate time that the Court make you a presenter so that you can

WARNING

Parties offering electronic sound or sound and video recordings as evidence at trial must comply with CRC rule 2.1040(b), or the evidence may be excluded.

Parties must comply with CRC rule 2.1040(b) if they plan to offer any electronic sound or sound and video recording as evidence at trial. Failure to do so could result in the exclusion of said evidence.

WARNING

Applies to

Exhibits

Parties appearing remotely must have copies of all exhibits in advance of the hearing; testing equipment in advance is strongly encouraged.

remotely) have copies of all such exhibits in advance of the hearing. It is strongly encouraged that the parties test out their equipment in advance of the proceeding to ensure everything is functioning properly and no time is wasted during the proceeding trying to troubleshoot an electronic evidence presentation.

WARNING

Applies to

Interpreter request

Parties must advise the Court at the TRC if interpreters are needed and request them via Form SDSC ADM-348 well in advance.

Advise the Court at the TRC if interpreters will be needed. The parties are responsible for requesting interpreters via Form SDSC ADM-348 well in advance, and this will be confirmed at the TRC.

WARNING

Applies to

Income expense declaration

Income and Expense Declarations must be submitted with the trial briefs when relevant to the proceedings.

All Income and Expense Declarations, if relevant to the proceedings, must be submitted with the briefs.

WARNINGCivil cases

Applies to

Court filing

Absent good cause, you must provide a current address and telephone number to the Court and include your contact information in each court filing.

Absent good cause, you must provide a current address and telephone number to the Court and include your contact information in each court filing.

WARNINGCivil cases

Applies to

Settlement agreement

Put any settlement agreement in writing.

Put any settlement agreement in writing.

WARNINGCivil cases

Applies to

Proposed order

Parties must prepare proposed orders, judgments, and other required documents.

Parties are responsible for preparing proposed orders, judgments, and other required documents.

WARNINGCivil cases

Applies to

Witness list

A witness list is required as part of the trial notebook.

Witness List

WARNINGCivil cases

Applies to

Exhibit list

An exhibit list in grid format is required as part of the trial notebook.

Exhibit List - Grid format – see below for example

WARNINGCivil cases

Applies to

Stipulation

Parties must meet and confer on evidence admissibility before submitting trial briefs or exhibit lists and prepare a written stipulation if issues are agreed.

The parties are ordered to meet and confer as to the admissibility of evidence prior to the submission of trial briefs or exhibit lists and to attempt to settle as many issues as possible. If there is agreement as to some issues, the parties are ordered to prepare a written stipulation in advance of trial.

WARNINGCivil cases

Applies to

Witness list

WITNESS LIST

WITNESS LIST

WARNINGCivil cases

Applies to

Exhibit list

The exhibit list must have objections noted.

The exhibit list is to have objections noted.

WARNING

Applies to

Special verdict form

Special verdict forms should follow CACI, include all causes of action and all parties, be complete, and be on pleading paper without any firm's name.

Special Verdict Forms - either an agreed-upon forms or each side’s proposed forms. The forms should follow CACI as closely as possible and include all cause of actions and all parties. The verdict forms should be complete and on pleading paper without any firm’s name.

WARNING

Applies to

Proposed protective order

Proposed stipulated protective orders are approved only if their language is consistent with the Court's stated policy.

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.

WARNING

Applies to

Witness list

The Joint Witness List must include a short description of each witness.

Copy of Joint Witness List with a short description of the witness (i.e. "Dr. Jane Smith, an internist from Mercy Hospital");

WARNING

Applies to

Jury instructions

Jury instructions must be submitted in sequential order, with post-it notes marking any objected-to instructions and indicating who objects and the basis.

Jury Instructions - One set in sequential order with post-it notes on any objected-to instructions, indicating who objects, and the basis for the objection;

WARNING

Applies to

Exhibit list

The Joint Exhibit List must follow the grid format from the Advance Trial Review Orders.

Copy of Joint Exhibit List (follow grid format on attachment to the Advance Trial Review Orders);

WARNINGCivil cases

Applies to

Case management statement

Parties must meet and confer before the CMC and file a Case Management Statement per California Rules of Court Rules 3.724 and 3.725.

Parties and counsel must comply with California Rules of Court and San Diego Superior Court Local Rules, including the requirements that the parties meet and confer prior to the CMC and file a Case Management Statement. (California Rules of Court, Rule 3.724 and 3.725.)

WARNINGCivil cases

Applies to

Exhibits

All exhibits should be pre-marked, with pages numbered.

All exhibits should be pre-marked, with pages numbered.

WARNINGCivil cases

Applies to

Stipulation to continue

Must include

proposed order

Please provide a proposed order with any stipulation.

Please provide a proposed order with any stipulation.

WARNINGCivil cases

Applies to

Default judgment

Must include

proposed order

Plaintiff should submit a proposed judgment in connection with any request for entry of a default judgment.

Plaintiff should submit a proposed judgment in connection with any request for entry of a default judgment.

WARNINGCivil cases

Applies to

Case management statement

Parties must file and serve a Case Management Statement in compliance with Rule 3.725.

The parties are expected to file and serve a Case Management Statement in compliance with Rule 3.725 of the California Rules of Court.

WARNINGCivil cases

Applies to

Trial call materials

At trial call for jury trials, parties must provide verdict form, jury instructions, exhibit list, witness list, statement of the case, joint trial notebook, and in limine motion notebook.

At the trial call for jury trials, the parties shall provide the following materials: (1) the verdict form(s), in final format, so that the form(s) can be photocopied and given to the jury; (2) the jury instructions, in final format, so that the instructions can be photocopied and given to jury; (3) the exhibit list, in the format identified in the Local Rules; (4) a list of witnesses expected to be called at trial, in a format that is suitable for photocopying to give to prospective jurors; and (5) a statement of the case to be read to prospective jurors. Additionally, counsel must provide a joint trial notebook and an in limine motion notebook, tabbed by motion and including objections.

INFOCivil cases

Applies to

Cmc statement

Continued CMCs do not require a new statement unless the Court directs otherwise.

Continued CMCs do not require a new statement unless directed by the Court.

INFOCivil cases

Applies to

Discovery motion

The Court permits a moving party to submit a concise outline of the discovery request and each response in dispute without express court order.

Code of Civil Procedure sections 2030.300, 2031.310, and 2033.290 allow a court to authorize a moving party to submit a concise outline of the discovery request and each response in dispute. This Court permits such practice without express court order.

INFOCivil cases

Parties should not refer to IDC discussions in any subsequent papers.

Parties should not refer to any discussions in any subsequent papers.

INFOCivil cases

Applies to

Guardian ad litem application

Guardian ad litem applications may be submitted for review without an appearance.

Applications may be submitted for review without an appearance.

INFOCivil cases

Applies to

Idc request

The party requesting an IDC should first meet and confer with the opposing party to discuss scheduling.

The party requesting an IDC should first meet and confer with the opposing party to discuss scheduling.

INFOCivil cases

Applies to

Notice of intent to appear

No notice of intent to appear is required to appear for oral argument.

No notice of intent to appear is required to appear for oral argument.

INFOCivil cases

Applies to

Guardian ad litem application

Guardian ad litem applications are governed by Local Rule 2.4.6.

Applications for appointment of a guardian ad litem are governed by LR 2.4.6.

INFOCivil cases

Applies to

Stipulation

Must include

proposed order

Stipulated continuance requests should include a proposed order.

The stipulation should include a proposed order.

INFOCivil cases

Applies to

Ex parte application

No appearance is required at an ex parte hearing if all parties stipulate to the requested relief.

No appearance is required if all parties stipulate to the requested relief.

INFOCivil cases

Applies to

Exhibits

Exhibits judicially noticed are not marked 'RECEIVED' on the tag; impeachment exhibits are identified as 'the next in order' and the clerk marks and adheres the tag.

When judicial notice is taken of a document/exhibit, it is not indicated “RECEIVED” on the exhibit tag. If there are impeachment exhibits, they can be identified as “the next in order” and the clerk will mark and adhere the exhibit tag.

INFOCivil cases

Applies to

Exhibits

The Court strongly encourages the parties to agree on the admissibility of exhibits, if possible, and the parties are ordered to meet and confer regarding the same. If parties stipulate to exhibits, note the stipulated exhibits on the cover sheet in the binder.

The Court strongly encourages the parties to agree on the admissibility of exhibits, if possible, and the parties are ordered to meet and confer regarding the same. If parties stipulate to exhibits, note the stipulated exhibits on the cover sheet in the binder.

INFOCivil cases

Applies to

Exhibits

Exhibits must be moved into evidence as presented and are deemed authenticated absent a genuine dispute.

Move exhibits into evidence as you present them at trial. Exhibits are deemed authenticated unless there is a genuine dispute. You need not ask a witness to authenticate a document unless the opposing party objects.

INFOCivil cases

Applies to

Exhibits

Parties must include a means of return for all exhibits.

Please be sure to include a means of return for all exhibits.

INFOCivil cases

Applies to

Exhibits

Please meet and confer in advance as to the admissibility of evidence.

Please meet and confer in advance as to the admissibility of evidence.

INFO

Applies to

Exhibits

Parties are ordered to meet and confer on exhibit admissibility; stipulated exhibits must be noted on the cover sheet or exhibit lists, and the Court will not receive stipulated exhibits en masse.

The Court strongly encourages the parties to agree on the admissibility of exhibits, if possible, and the parties are ordered to meet and confer regarding the same . If parties stipulate to exhibits, note on the cover sheet in the binders or on the exhibit lists which exhibits those are . The Court will not receive stipulated exhibits into evidence en masse, but prior stipulations to the admissibility of exhibits will create greater efficiency and save time during the proceeding.

INFO

Applies to

Exhibits

Parties must include a means of return for all exhibits and lodgments.

Be sure to include a means of return for all exhibits and lodgments.

WARNINGCivil cases

For guardian ad litem, publication, pro hac vice, and default prove-up applications, moving papers must be submitted (with proof of service if applicable) and the court may set a hearing if necessary.

Guardian and Testament/Publication of Summons/Pro Hac Vice/Default prove ups: Submit moving papers for the court, with proof of service, if applicable; the court may set a hearing if deemed necessary.