Judge Terrie E. Roberts
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Courtesy Copies
Trial Readiness Conference Report
- Upon Filing
Communication
Phone
Clerk
Phone
Clerk
Phone
Clerk
Document Filing Requirements7 rules
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;
- Document
- Joint trial notebook
Must include
- •Table of contents
The Joint Trial Readiness Conference Report must include a statement of the case, witness list, exhibit list, jury instructions, and proposed verdict form.
- Document
- Trial readiness conference report
Must include
- •Exhibit list
Court's wording
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).
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.
Court's wording
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.
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.
Copy of Joint Witness List with a short description of the witness (i.e. "Dr. Jane Smith, an internist from Mercy Hospital");
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;
Copy of Joint Exhibit List (follow grid format on attachment to the Advance Trial Review Orders);
Filing & Service rules
Filing Timing and Cure Windows
Parties must file a Case Management Conference statement 15 calendar days before the first CMC.
Parties shall file a CMC statement 15 calendar days before the very first CMC.
Page 1 | Calendars - Case Management Conferences
Ex parte moving papers must be filed by 10:00 a.m. the day before the hearing and require the appropriate fee.
Moving papers are due by 10:00 a.m. on the day prior to the hearing, with the appropriate fee.
Page 1 | Calendars - Ex Parte Hearings
Trial counsel and self-represented litigants must file the Joint Trial Readiness Conference Report at least 5 court days before the TRC and provide a courtesy copy to the department.
At least five (5) court days prior to the TRC, trial counsel and self-represented litigants must file their completed Joint Trial Readiness Conference Report with a courtesy copy provided to the department.
Page 2 | Trial Readiness Conferences
Motions in Limine must be filed five court days before trial call.
Motions in Limine must be filed five (5) court days prior to trial call
Page 3 | Trials
Oppositions to Motions in Limine are due two court days before trial.
Opposition to Motions in Limine are due two (2) court days prior to trial
Page 3 | Trials
Continued CMCs do not require a new statement unless there are substantial changes or trial availability changes.
Continued CMC’s do not require a new statement unless there have been substantial changes in the matter or the party’s availability for trial has changed.
Page 1 | Calendars - Case Management Conferences
Filing Fees and Waivers
Ex parte moving papers require the appropriate filing fee.
Moving papers are due by 10:00 a.m. on the day prior to the hearing, with the appropriate fee.
Page 1 | Calendars - Ex Parte Hearings
Courtesy Copy Requirements
A courtesy copy of the Joint Trial Readiness Conference Report must be provided to the department.
At least five (5) court days prior to the TRC, trial counsel and self-represented litigants must file their completed Joint Trial Readiness Conference Report with a courtesy copy provided to the department.
Page 2 | Trial Readiness Conferences
Sealing & Redaction Procedures
Documents may be filed under seal only in compliance with California Rules of Court Rule Nos. 2.550 and 2.551.
The Court requires adherence with statutory procedures to file documents under seal. The Court will not order any document sealed which is not submitted in accordance with California Rules of Court, Rule Nos. 2.550 and 2.551.
Page 3 | Stipulated Protective Orders Re: Confidential Information
Documents submitted conditionally under seal will not be sealed unless the party complies with CRC Rule Nos. 2.550, 2.551, and 3.1302(b).
Documents submitted "conditionally under seal" will not be sealed unless the submitting party complies with CRC Rule Nos. 2.550, 2.551, and 3.1302(b).
Page 3 | Stipulated Protective Orders Re: Confidential Information
Supporting documents filed under seal for any motion are governed by CRC Rules 2.550/2.551, and the motion is not determined until a noticed motion to seal is calendared and decided; Rule 2.550 does not apply to discovery motions.
If a party desires to file supporting documents under seal for any motion, CRC Rule Nos. 2.550 and 2.551 apply. The motion will not be determined until a noticed motion to seal has been calendared and decided. Note: CRC Rule No. 2.550 does not apply to discovery motions and records filed or lodged in connection with discovery motions or proceedings.
Page 3 | Filing Documents under Seal
The Court prefers to accept confidential documents as lodged documents for discovery and other motions, returning them to the submitting party after determination.
For determination of discovery and other motions, the Court prefers to accept confidential documents as "lodged documents." All lodged documents are returned to the submitting party upon the Court's determination of the motion or application. (CRC Rule No. 3.1302(b).)
Page 3 | Lodged Documents
Pre-Motion Conference Requirements
If a party has filed three or more discovery motions, the Court will not hear them until an Informal Discovery Conference is held.
if a party has filed three or more discovery motions, the Court will not hear the motions prior to an IDC being held.
Page 1 | Calendars - (New) Informal Discovery Conferences
Adjournment & Extension Requirements
A trial date will not be continued on an ex parte application to advance a motion unless requested in the alternative or stipulated to.
If the application is to advance a motion date, in the event an earlier date is not available, the trial date will not be continued unless it was requested in the alternative or it is stipulated to.
Page 1 | Calendars - Ex Parte Hearings
Continuance requests may be made by ex parte motion or by stipulation.
Requests for continuances may be done either by ex parte motion or by stipulation.
Page 3 | Continuances
Chambers Communication Rules
Ex parte matters must be scheduled by calling the Calendar Clerk only.
Ex Parte matters are scheduled Tuesdays, Wednesdays, and Thursdays at 8:45 am, by calling the Calendar Clerk only.
Page 1 | Calendars - Ex Parte Hearings
To appear remotely at Trial Call, counsel or self-represented litigants must obtain approval by contacting the courtroom clerk 48 hours before the hearing.
If counsel or the self-represented litigant is unable to personally appear, you must obtain approval to appear remotely by contacting the courtroom clerk at 619-450-7068, 48 hours before the hearing.
Page 2 | Trial Calls
Parties are encouraged to schedule an Informal Discovery Conference by calling the calendar clerk.
Parties are encouraged to schedule an IDC by calling the calendar clerk at 619-450-7328, to help resolve disputes without the need for a formal motion.
Page 1 | Calendars - (New) Informal Discovery Conferences