Judge Nicole S. Healy
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
All Motions
- 1 copy
- 1 copy • Within 2 Court Days
Case Management Conference Statement, Non Motion Pleading, Non Motion Paper
Courtesy copies
Exhibits
- 3 copies • At Least 14 Days Before Trial
Adjournments
- Those who wish to change document due dates should submit a proposed order explaining why they want to change the deadlines.
- Any necessary continuance of a hearing or trial date requires prior Court approval, and a stipulated continuance may proceed only to a date already approved by the Court.
- Moving-party counsel must promptly notify Department 28 by telephone and email about matters taken off calendar or continued, and the movant must provide all hearing-continuance notices.
Request must include
Communication
Chambers, Clerk
Chambers, Clerk
Phone
Clerk
Page & Word Limits9 rules
Each motion in limine should address a single, separate topic and shall be limited to five (5) pages in length unless otherwise permitted by the Court.
- Motion
- Up to 5 pages
Each opposition is also limited to five (5) pages unless otherwise permitted by the Court.
- Opposition
- Up to 5 pages
Each party’s explanation following a disputed jury instruction is limited to one page.
- Page limit
- Up to 1 page per party
- Jury instructions
Court's wording
Following each disputed instruction, each party shall explain, in no more than one page, why the Court should give that party’s proposed instruction or why the instruction should or should not be given.
The explanation supporting a party’s proposed treatment of a disputed exhibit is limited to one double-spaced page.
- Disputed exhibit submission
- Up to 1 page per party
- Format
- Double-spaced
Court's wording
If the parties are unable to informally resolve the dispute, then each party shall submit its disputed exhibit with the Joint Pretrial Conference Statement and explain, in no more than one double-spaced page, why the Court should use its proposed exhibit.
Each opposition is also limited to five (5) pages unless otherwise permitted by the Court.
- Opposition
- Up to 5 pages
Each motion in limine should address a single, separate topic and shall be limited to five (5) pages in length unless otherwise permitted by the Court.
- Motion in limine
- Up to 5 pages
- Motion
If the parties are unable to informally resolve the dispute, then each party shall submit its disputed exhibit with the Joint Pretrial Conference Statement and explain, in no more than one double-spaced page, why the Court should use its proposed exhibit.
- Disputed exhibit explanation
- Up to 1 page per party
- Format
- Double-spaced
Unless the case is very complex, this statement should not exceed one-page double spaced.
- Page limit
- Up to 1 page
- Format
- Double-spaced
For these informal conferences, briefs on court pleading paper not to exceed three (3) pages – which must be served – may be submitted by email to the Court at dept28@sanmateocourt.org and complexcivil@sanmateocourt.org.
- Informal conference brief
- Up to 3 pages
Document Format Requirements41 rules
The joint witness list must be in tabular form and contain the following:
- Witness list
Formatting
- •Tabular form
Any changes to the proposed verdict form(s) ordered by the Court must be made by the parties and submitted to the Court in Word format by the deadline set at the Pretrial Conference or by any other deadline set by the Court.
- File type
- Word
- Proposed verdict form
Each trial exhibit must be clearly pre-marked with the trial exhibit number.
The trial exhibit list must begin with the plaintiff’s first exhibit number. Defendant’s exhibit numbers must be sequenced to begin after the plaintiff’s exhibit numbers. DO NOT identify the exhibits as plaintiff’s or defendant’s.
The deposition binder must use tabs for each witness, highlight designations in yellow, and bracket objections in red.
- Binding
- Tabbed binder
- Deposition designations
Formatting
- •Use one tab for each witness
- •Highlight designations in yellow
- •Bracket objections in red
Court's wording
The parties must jointly submit one binder with a joint pleading that has the designations, objections and responses followed by tabs for each witness with the designation highlighted in yellow and any objections bracketed in red.
The back of the last page of each trial exhibit must include the completed Court exhibit tag.
Each party must provide the Court with at least three (3) complete sets of hard copy exhibits in tabbed BINDERS NO MORE THAN 2½ INCHES WIDE that the party intends to introduce at trial
- Binding
- Tabbed binder
- Exhibits
The parties must also email the proposed jury instructions, proposed verdict form(s), proposed jury questionnaire (if any), proposed statement of the case, and proposed orders in Word format to the Court at dept28@sanmateocourt.org.
- File type
- Word
- Jury instructions
- Verdict forms
- Jury questionnaire
- Proposed statement of the case
- Proposed order
trial exhibits in BINDERS NO MORE THAN 2½ INCHES WIDE – and on a thumb drive
The joint witness list must be submitted in tabular form and include witness names, titles, anticipated testimony subjects, and estimated examination lengths.
Court's wording
The joint witness list must be in tabular form and contain the following: a. Name of the witness; b. Title of the witness, if any; c. Brief description of the subject matter of the witness’ anticipated testimony; and d. Estimated length of the direct examination, cross-examination, and any redirect, and cross-redirect.
The parties shall also submit their deposition designations and objections with the Joint Pretrial Conference Statement. The parties must submit copies of the excerpts of the designated portions of the deposition transcripts, NOT a list of page and line numbers.
- Deposition designations
Formatting
- •Do not submit only a list of page and line numbers
The parties must jointly submit one binder with a joint pleading that has the designations, objections and responses followed by tabs for each witness with the designation highlighted in yellow and any objections bracketed in red.
Exhibits shall be numbered sequentially. NO letters may be used.
- Trial exhibits
Formatting
- •Letters may not be used for exhibit numbers
The joint exhibit list must be in tabular form and contain the following: a. Exhibit number; b. Brief description of the exhibit (with any bates numbers if they exist); c. Sponsoring witness;
- Joint exhibit list
Formatting
- •The list must contain the exhibit number
- •The list must identify the sponsoring witness for each exhibit
To avoid any party claiming “ownership” of an exhibit, all exhibits shall be marked and referred to as “Trial Exhibit No. ___” – and NOT as “Plaintiff’s Exhibit” or “Defendant’s Exhibit.”
- Trial exhibits
Formatting
- •Mark and refer to each exhibit as "Trial Exhibit No. "
- •Do not label an exhibit as "Plaintiff's Exhibit" or "Defendant's Exhibit"
Each trial exhibit must be clearly pre-marked with the trial exhibit number.
The back of the last page of each trial exhibit must include the completed Court exhibit tag.
The binders MUST NOT be identified as “plaintiff’s exhibits” or “defendant’s exhibits.”
- Trial exhibit binders
Formatting
- •Do not identify binders as "plaintiff's exhibits" or "defendant's exhibits"
At least 14 days before trial, each party must provide three complete hard-copy exhibit sets in tabbed binders no wider than 2½ inches and one complete thumb-drive set.
- Binding
- Tabbed binder
- Trial exhibits
Court's wording
Each party must provide the Court with at least three (3) complete sets of hard copy exhibits in tabbed BINDERS NO MORE THAN 2½ INCHES WIDE that the party intends to introduce at trial and one (1) complete set of exhibits on a thumb drive at least fourteen (14) days before the Trial Date.
All e-mails must be sent in at least 12-point type and copied to all parties or their counsel of record.
The documents (other than exhibits) must be text searchable.
Exhibits to electronically filed documents must be electronically bookmarked, with only the first page of each exhibit bookmarked.
Court's wording
Please note that any exhibits to electronically filed briefs, declarations, or other documents must be electronically “bookmarked” as required by Cal. Rules of Court, rule 3.1110(f)(4). All parties are reminded to bookmark only the first page of each exhibit and not to bookmark every page of each filed document.
Courtesy copies of electronic exhibits must be submitted on a flash drive under the cited rules, and file-sharing methods are not accepted.
Court's wording
Courtesy copies of any electronic exhibits must be submitted on a flash drive in conformity with the requirements of the California Rules of Court, rules 2.256(b) and 3.1110(f)(4). The Court cannot receive documents through any type of file sharing.
You must also email an editable version of the Proposed Order in Word format (not PDF) to dept28@sanmateocourt.org and complexcivil@sanmateocourt.org so that the judge can modify it prior to signing, if needed.
- File type
- Word
- Proposed order
Formatting
- •Editable version required
- •PDF version prohibited for this email submission
Deliver to the Court at least three (3) sets of trial exhibits in BINDERS NO MORE THAN 2½ INCHES WIDE – and on a thumb drive
Parties must file joint pretrial conference statement, and provide to the Court one (1) set of BINDERS NO MORE THAN 2½ INCHES WIDE – with the following:
- Pretrial binder
Formatting
- •Binder must be no more than 2½ inches wide
Any modifications made to a form instruction must be plainly identified.
the top of the first page of each instruction should include only the CACI number and title. The footer may include the case name and number and page number.
The binders MUST NOT be identified as “plaintiff’s exhibits” or “defendant’s exhibits.”
- Exhibits
Formatting
- •Do not identify binders as “plaintiff’s exhibits” or “defendant’s exhibits.”
Each party must place the official exhibit tag on the back of the final page of each exhibit document.
Court's wording
Each party will be expected to place the official exhibit tag on the back of the last page of each document; the exhibit tags may be obtained from the courtroom clerk, or the parties may copy the template at Appendix A.
Document Filing Requirements49 rules
The parties shall file a joint set of proposed jury instructions, arranged in the order the parties propose the Court give the instructions, with the Joint Pretrial Conference Statement. The parties must include copies of the actual instructions and NOT merely a list of instruction numbers.
Each party must also submit a hard copy and a Word version of all proposed orders.
Each party must file a joint list of all the witnesses that the party intends to call at trial with the Joint Pretrial Conference Statement.
If the parties wish to use a jury questionnaire, the parties must file a joint proposed jury questionnaire or, if they disagree, separate proposed jury questionnaires with the Joint Pretrial Conference Statement.
The parties shall file either joint proposed verdict form(s) or, if they disagree, separate proposed verdict forms with the Joint Pretrial Conference Statement.
The parties must file a joint proposed statement of the case to be read to the jury during voir dire with the Joint Pretrial Conference Statement.
The parties shall also submit their deposition designations and objections with the Joint Pretrial Conference Statement.
The parties must submit copies of the excerpts of the designated portions of the deposition transcripts, NOT a list of page and line numbers.
The tabular joint witness list must state each witness's name, title if any, anticipated subject matter, and estimated examination lengths.
Court's wording
The joint witness list must be in tabular form and contain the following: a. Name of the witness; b. Title of the witness, if any; c. Brief description of the subject matter of the witness’ anticipated testimony; and d. Estimated length of the direct examination, cross-examination, and any redirect, and cross-redirect.
Each party that cannot informally resolve a disputed overlapping exhibit must submit the exhibit with the Joint Pretrial Conference Statement and explain its position in no more than one double-spaced page.
Court's wording
If there is any dispute over which portions of an overlapping exhibit should be introduced into evidence, the parties shall meet and confer in an attempt to informally resolve the issue. If the parties are unable to informally resolve the dispute, then each party shall submit its disputed exhibit with the Joint Pretrial Conference Statement and explain, in no more than one double-spaced page, why the Court should use its proposed exhibit.
The parties must file a joint exhibit list identifying all the exhibits that the party intends to introduce at trial with the Joint Pretrial Conference Statement.
The Joint Pretrial Conference Statement must describe the remaining claims and defenses, requested relief and damages, undisputed facts, settlement discussions, estimated trial length, and other matters facilitating resolution.
- Document
- Joint pretrial conference statement
Include
- •Statement of facts
Court's wording
a. Substance of the Action: A brief description of the parties, the claims and defenses that remain to be decided (including whether any issues are for the Court to decide rather than the jury), and the operative pleading, including the date of filing, that raises these claims and defenses. b. Relief Requested: A detailed statement of all requested relief that itemizes all elements of damages that are claimed. c. Undisputed Facts: A plain and concise statement of all relevant facts to which the parties will stipulate for incorporation into the record without supporting testimony or exhibits or that are undisputed. d. Settlement Discussions: A brief description of the efforts the parties have made to settle the case and a brief statement about whether the parties believe that further negotiations are likely to be productive and what, if anything, would facilitate settlement. e. Estimate of Trial Length: An estimate of the number hours needed for the presentation of each party’s case. f. Miscellaneous: Any other matters that will facilitate the just, speedy, and efficient resolution of the case.
If they wish to change any of the dates that documents are due to the Court, they should submit a proposed order specifying the reasons why they want to change the deadlines.
The joint pretrial conference statement must include witness lists, exhibit lists, limine papers, and deposition designations and objections.
- Document
- Joint pretrial conference statement
Must include
- •Exhibit list
Court's wording
Parties must file joint pretrial conference At least 14 days before the Pretrial statement, and provide to the Court one (1) Conference set of BINDERS NO MORE THAN 2½ INCHES WIDE – with the following: 14 1. Witness lists; 2. Exhibit lists, including any disputed exhibits; 3. Motions in limine, oppositions, and supporting declarations or requests for judicial notice; and 4. Deposition designations and objections
No replies will be permitted without leave of the Court.
Each party must also submit a hard copy and a Word version of all proposed orders. Each proposed order must provide enough specificity that a witness will be able to understand what testimony is prohibited.
The parties must file a joint exhibit list identifying all the exhibits that the party intends to introduce at trial with the Joint Pretrial Conference Statement.
Each party will be expected to place the official exhibit tag on the back of the last page of each document; the exhibit tags may be obtained from the courtroom clerk, or the parties may copy the template at Appendix A.
The applicant MUST provide a proposed order or the application will be denied.
- Document
- Ex parte application
Must include
- •Proposed order
must file a Notice of Settlement, Request for Dismissal, Stipulation for Entry of Judgment, or a Judgment on Stipulation, that is ready for the Court’s signature.
If preliminary approval is given, a written stipulation must be provided before the hearing or trial date.
Accordingly, the parties shall file a joint case management conference statement no later than six (6) calendar days before the hearing for each conference that includes the following:
and shall submit to the Court at least one (1) day before the hearing a declaration establishing that the meet and confer conference occurred and describing any agreements that counsel have reached.
Proposed Orders must be submitted electronically through the Clerk’s office with the information required by California Rule of Court, rule 3.1312.
When amending after a sustained demurrer or motion to strike with leave, the plaintiff or cross-complainant must attach a redline to any successive opposition unless the court orders otherwise.
Court's wording
When the Court sustains a demurrer or grants a motion to strike with leave to amend and an amended pleading is filed, the plaintiff or cross-complainant must file with its opposition to any successive demurrer or motion to strike a redline comparing the amended pleadings to the previous version of the pleading unless otherwise ordered by the Court.
A discovery motion must attach the disputed discovery requests or deposition questions and any written responses to the supporting declaration and include a concise outline of the dispute.
Court's wording
Instead, the parties must (1) attach the discovery request(s) or deposition question(s) at issue and the written response(s), if any, to the declaration submitted in support of the discovery motion; and (2) submit a concise outline of the discovery request and each response in dispute pursuant to Code of Civil Procedure section 2030.300, subdivision (b)(2).
Any cited authority not reported in an official reporter must use a WESTLAW-accessible citation or be emailed to both listed Department 28 addresses.
Court's wording
Because the Court only has access to non-California authorities via WESTLAW – and NOT via LEXIS – any authorities that are not reported in an official reporter and that are cited must either be: (1) cited using the WESTLAW citation or a citation accessible through WESTLAW; or (2) provided to Department 28 by email at dept28@sanmateocourt.org and complexcivil@sanmateocourt.org.
Each motion should be clearly identified as “__________’s Motion in Limine No. ___ Re: ____________,” with the blanks filled in as appropriate.
Instructions upon which the parties agree shall be identified as “Stipulated Instruction No. ___ Re: _____________,” with blanks filled in as appropriate.
Each proposed order must provide enough specificity that a witness will be able to understand what testimony is prohibited.
For disputed instructions, each party must provide an identified proposed version, and all versions of the same instruction must bear the same number.
Court's wording
If the parties disagree on an instruction, each party’s proposed version of the disputed instruction shall be provided and identified as “Disputed Instruction No. ___ Re: ________ Offered by __________,” with blanks filled in as appropriate. All proposed versions of the same instruction shall bear the same number.
Filing & Service rules
Electronic Filing Rules
Motions in limine and their oppositions must be electronically filed with the Clerk’s Office no later than 21 days before the Pretrial Conference.
Motions in limine and their oppositions must be e-filed with the Clerk’ Office no later than twenty-one (21) days before the Pretrial Conference.
Civil cases
Page 3 | Motions in Limine
The parties must electronically file a Joint Pretrial Conference Statement at least 14 days before the Pretrial Conference.
The parties shall e-file with the Court a Joint Pretrial Conference Statement at least fourteen (14) days before the Pretrial Conference that contains the following:
Civil cases
Page 9 | PRETRIAL CONFERENCE STATEMENT
The parties must email the proposed jury instructions, verdict forms, jury questionnaire, statement of the case, and proposed orders to the Court.
The parties must also email the proposed jury instructions, proposed verdict form(s), proposed jury questionnaire (if any), proposed statement of the case, and proposed orders in Word format to the Court at dept28@sanmateocourt.org.
Civil cases
Page 10 | PRETRIAL CONFERENCE STATEMENT
Motions in limine and their oppositions must be electronically filed with the Clerk’s Office at least 21 days before the Pretrial Conference.
Motions in limine and their oppositions must be e-filed with the Clerk’ Office no later than twenty-one (21) days before the Pretrial Conference.
Civil cases
Page 3 | MOTIONS IN LIMINE
The parties must electronically file a Joint Pretrial Conference Statement at least 14 days before the Pretrial Conference.
The parties shall e-file with the Court a Joint Pretrial Conference Statement at least fourteen (14) days before the Pretrial Conference that contains the following:
Civil cases
Page 7 | PRETRIAL CONFERENCE STATEMENT
The parties must email the proposed orders to the Court at dept28@sanmateocourt.org.
The parties must also email the proposed orders in Word format to the Court at dept28@sanmateocourt.org.
Civil cases
Page 8 | PRETRIAL CONFERENCE STATEMENT
All ex parte filings must be electronically filed unless the filing party is unrepresented.
Local Rule 3.500 has been revised mandating that all ex parte filings be e-filed unless a party is not represented by counsel.
Page 1 | Communications to Department 28
Proposed orders must be submitted electronically through the Clerk's Office and include the information required by California Rule of Court 3.1312.
Proposed Orders must be submitted electronically through the Clerk’s office with the information required by California Rule of Court, rule 3.1312.
Civil cases
Page 9 | GENERAL MATTERS
The listed proposed pretrial submissions must be served rather than filed at least 42 days before the Pretrial Conference.
At least forty-two (42) days before the Pretrial Conference each party must serve on all other parties (but NOT file) its proposed motions in limine, proposed jury instructions, proposed verdict form(s), proposed witness list, and proposed exhibit list.
Civil cases
Page 8 | MEET AND CONFER
A party ordered to prepare a written order should electronically file it.
When Judge Healy orders a party to prepare a written order, that party should e-file the order.
Page 1 | Pretrial Order - Jury Trials
Filing Timing and Cure Windows
Motions in limine and their oppositions must be filed and served at least 21 days before the pretrial conference.
File and serve motions in limine and At least 21 days before the Pretrial oppositions to motions in limine Conference
Civil cases
Page 2 | INTRODUCTION
At least three sets of trial exhibits must be delivered to the court in qualifying binders and on a thumb drive at least 14 days before trial.
Deliver to the Court at least three (3) sets of trial exhibits in BINDERS NO MORE THAN 2½ INCHES WIDE – and on a thumb drive — At least 14 days before the Trial Date
Civil cases
Page 2 | INTRODUCTION
At least 14 days before the pretrial conference, parties must file a joint statement and provide the court one binder no more than 2½ inches wide containing the eight listed categories of pretrial materials.
Parties must file joint pretrial conference statement, and provide to the Court one (1) set of BINDERS NO MORE THAN 2½ INCHES WIDE – with the following: 1. Proposed jury instructions; 2. Proposed verdict form(s); 3. Proposed voir dire and juror questionnaire (if any); 4. Proposed statement of the case; 5. Witness lists; 6. Exhibit lists, including any disputed exhibits; 7. Motions in limine, oppositions, and supporting declarations or requests for judicial notice; and 8. Deposition designations and objections — At least 14 days before the Pretrial Conference
Civil cases
Page 2 | INTRODUCTION
Motions in limine and their oppositions are due for electronic filing no later than 21 days before the Pretrial Conference.
Motions in limine and their oppositions must be e-filed with the Clerk’ Office no later than twenty-one (21) days before the Pretrial Conference.
Civil cases
Page 3 | Motions in Limine
The parties must submit Court-ordered changes to proposed verdict forms by the deadline set at the Pretrial Conference or another deadline set by the Court.
Any changes to the proposed verdict form(s) ordered by the Court must be made by the parties and submitted to the Court in Word format by the deadline set at the Pretrial Conference or by any other deadline set by the Court.
Civil cases
Page 5 | VERDICT FORM(S)
The parties must submit Court-ordered changes to proposed jury instructions by the applicable Pretrial Conference or court-set deadline.
Any changes to the proposed jury instructions ordered by the Court must be made by the parties and submitted to the Court by the deadline set by the Court at the Pretrial Conference or by any other deadline set by the Court.
Civil cases
Page 5 | Introduction
The parties must meet and confer about deposition objections at least five days before the binder is due.
The parties shall then meet-and-confer about any objections at least five days before the binder is due.
Civil cases
Page 6 | WITNESS LISTS
Each party must provide one complete set of trial exhibits on a thumb drive at least 14 days before the trial date.
and one (1) complete set of exhibits on a thumb drive at least fourteen (14) days before the Trial Date.
Civil cases
Page 7
The Joint Pretrial Conference Statement is due at least 14 days before the Pretrial Conference.
The parties shall e-file with the Court a Joint Pretrial Conference Statement at least fourteen (14) days before the Pretrial Conference that contains the following:
Civil cases
Page 9 | PRETRIAL CONFERENCE STATEMENT
The parties must file the joint pretrial conference statement at least 14 days before the pretrial conference.
Parties must file joint pretrial conference At least 14 days before the Pretrial statement
Civil cases
Page 2 | INTRODUCTION
Motions in limine and oppositions must be filed at least 21 days before the pretrial conference.
File and serve motions in limine and At least 21 days before the Pretrial oppositions to motions in limine
Civil cases
Page 2 | INTRODUCTION
The designating party must provide the opposing parties with the designations and highlighted sections two weeks before the Joint Pretrial Conference Statement is due.
The designating party shall provide the opposing parties the designation(s) and highlighted sections two weeks before the statement is due.
Civil cases
Page 4 | WITNESS LISTS
The parties must meet and confer about deposition objections at least five days before the binder is due.
The parties shall then meet-and-confer about any objections at least five days before the binder is due.
Civil cases
Page 4 | WITNESS LISTS
The Joint Pretrial Conference Statement is due at least 14 days before the Pretrial Conference.
The parties shall e-file with the Court a Joint Pretrial Conference Statement at least fourteen (14) days before the Pretrial Conference that contains the following:
Civil cases
Page 7 | PRETRIAL CONFERENCE STATEMENT
A hearing date must be obtained from Department 28 before filing a complex-case motion, or the clerk will reject the motion.
To schedule a hearing, contact Department 28 rather than the Civil Clerk's office. The clerk's office will reject the motion in complex cases if a hearing date has not been obtained first from Department 28.
Page 1 | Communications to Department 28
All briefing in a complex law and matter hearing must be completed at least three weeks before the hearing.
All briefing must be completed at least three (3) weeks before the hearing date.
Page 1 | Communications to Department 28
Remote appearance at an ex parte hearing requires service of the moving papers and proposed order on all parties, paper submission to the assigned judge, and payment of the fee by 10:00 a.m. two court days before the appearance.
Except as ordered by the court under subdivision (d), applicants seeking an ex parte order may appear remotely provided that the moving papers, including a proposed order, have been served on all parties, and submitted in paper form to the assigned judge, and the fee paid to the clerk’s office, by at least 10:00 a.m. two court days before the ex parte appearance.
Page 1 | Communications to Department 28
The parties must file a joint case management conference statement no later than six calendar days before each conference hearing.
18. Judicial Council Form CM-110, Civil Case Management Statement (required by Cal. Rules of Court, rule 3.725(c)) is not well-suited for complex cases. Accordingly, the parties shall file a joint case management conference statement no later than six (6) calendar days before the hearing for each conference that includes the following:
Civil cases
Page 5 | CASE MANAGEMENT CONFERENCES
All papers needed for an ex parte application must be submitted to Department 28, preferably by email, by noon on the preceding court day.
20. All papers necessary to the determination of the application, including any proposed pleading, motion, or order, must be submitted to Department 28, preferably by email (to dept28@sanmateocourt.org and complexcivil@sanmateocourt.org), by noon the court day 20 before the scheduled ex parte hearing date.
Civil cases
Page 6 | EX PARTE APPLICATIONS
The meet-and-confer declaration must be submitted at least one day before the hearing.
and shall submit to the Court at least one (1) day before the hearing a declaration establishing that the meet and confer conference occurred and describing any agreements that counsel have reached.
Civil cases
Page 8 | LAW AND MOTION
Service and Proof of Service Rules
Motions in limine and their oppositions must be filed and served at least 21 days before the pretrial conference.
File and serve motions in limine and At least 21 days before the Pretrial oppositions to motions in limine Conference
Civil cases
Page 2 | INTRODUCTION
Proposed motions in limine, jury instructions, verdict forms, witness lists, and exhibit lists must be served but not filed at least 42 days before the pretrial conference.
Serve (but not file): 1. Proposed motions in limine; 2. Proposed jury instructions; 3. Proposed verdict form(s); 4. Proposed witness lists; and 5. Proposed exhibit lists — At least 42 days before the Pretrial Conference
Civil cases
Page 2 | INTRODUCTION
The designating party must provide opposing counsel with the designations and highlighted sections two weeks before the statement is due.
The designating party shall provide the opposing parties the designation(s) and highlighted sections two weeks before the statement is due.
Civil cases
Page 6 | WITNESS LISTS
At least 42 days before the Pretrial Conference, each party must serve—but not file—its proposed motions in limine, jury instructions, verdict forms, witness list, and exhibit list on every other party.
At least forty-two (42) days before the Pretrial Conference each party must serve on all other parties (but NOT file) its proposed motions in limine, proposed jury instructions, proposed verdict form(s), proposed witness list, and proposed exhibit list.
Civil cases
Page 8 | MEET AND CONFER
Proposed motions in limine, witness lists, and exhibit lists must be served but not filed at least 42 days before the pretrial conference.
Serve (but not file): At least 42 days before the Pretrial Conference 1. Proposed motions in limine; 2. Proposed witness lists; and 3. Proposed exhibit lists
Civil cases
Page 2 | INTRODUCTION
File and serve motions in limine and At least 21 days before the Pretrial oppositions to motions in limine
File and serve motions in limine and At least 21 days before the Pretrial oppositions to motions in limine
Civil cases
Page 2 | INTRODUCTION
At least 42 days before the Pretrial Conference, each party must serve but not file its proposed motions in limine, witness list, and exhibit list on every other party.
At least forty-two (42) days before the Pretrial Conference each party must serve on all other parties (but NOT file) its proposed motions in limine, proposed witness list, and proposed exhibit list.
Civil cases
Page 6 | MEET AND CONFER
All briefs, including reply briefs, in complex matters must also be emailed to the designated complex civil address.
Also, please note that this requirement is in addition to any separate requirement individual Judges have regarding the delivery of courtesy copies to their chambers, as well as the obligation to email all briefs, including reply briefs, to the complexcivil@sanmateocourt.org email address for complex matters.
Page 1 | Department Info of Judge Nicole S. Healy
A copy of any reply brief, unlawful detainer opposition, or motion for summary judgment must be emailed to the Court at the designated address.
In order to ensure your reply brief is received by the Court in a timely manner, you must email a copy of any reply brief, or any Unlawful Detainer Opposition or Motion for Summary Judgment to lawandmotionreplybriefs@sanmateocourt.org.
Page 1 | Department Info of Judge Nicole S. Healy
All parties and counsel must electronically serve and accept electronic service of documents unless a statute or rule requires another method.
Except where another method of service is required by statute or rule, all parties and counsel shall serve and shall accept service of all documents electronically, in conformity with Code of Civil Procedure, section 1010.6 and the California Rules of Court.
Civil cases
Page 3 | FILINGS AND CORRESPONDENCE
Plaintiff's counsel is responsible for maintaining and updating the email service list.
Plaintiff’s counsel is responsible for maintaining and updating the email service list
Civil cases
Page 4 | CASE MANAGEMENT CONFERENCES
By the initial case management conference, every party must provide the clerk with an email service list and be prepared to state whether it agrees to email service from the court.
By the date of the initial Case Management Conference, the parties shall provide the Clerk with an email service list as required by this Order and shall be prepared to indicate whether they agree to email service from the Court.
Civil cases
Page 4 | CASE MANAGEMENT CONFERENCES
Unless the court orders otherwise, plaintiff must give all other parties notice of the initial case management conference date.
Plaintiff is required to give notice of this conference date to all other parties unless otherwise ordered by the Court.
Civil cases
Page 4 | CASE MANAGEMENT CONFERENCES
Discovery requests under the Code of Civil Procedure must be served electronically on counsel for all parties.
All discovery sought pursuant to the Code of Civil Procedure, including but not limited to notices of deposition, special interrogatories, form interrogatories, requests for production of documents, and requests for admission, must be served electronically upon counsel for the parties.
Civil cases
Page 6 | DISCOVERY
Discovery responses must be provided electronically unless the parties agree in writing to another method.
All discovery responses by a party in response to discovery propounded by another party must be provided in electronic form, unless the parties agree otherwise in writing.
Civil cases
Page 6 | DISCOVERY
All pleadings must be emailed to the specified Department 28 address on the filing date, independently of any courtesy-copy requirement.
The requirement to submit courtesy copies is separate from the requirement to email all pleadings to Department 28 at complexcivil@sanmateocourt.org on the date of filing.
Civil cases
Page 9 | GENERAL MATTERS
A party intending to contest a tentative ruling must email the other parties and both Department 28 addresses by 4:00 p.m. at least one court day before the hearing; otherwise, the ruling becomes the order.
If any party intends to contest the tentative ruling at the hearing, that party must notify the other parties and Department 28 by email at both dept28@sanmateocourt.org and complexcivil@sanmateocourt.org by 4:00 p.m. at least one court day before the scheduled hearing. Otherwise, the tentative ruling will become the order of the Court.
Civil cases
Page 10 | GENERAL MATTERS
Plaintiffs must serve the order on all previously unrepresented parties or their designated counsel, including parties later added, and file proof of service.
Plaintiff(s) shall serve a copy of this order upon all parties or their designated counsel, who have not yet appeared in this case, including any and all parties added to this action and/or cross-action(s) after the issuance of this order, and shall file a proof of service.
Civil cases
Page 11 | Complex Case Management Order
For these informal conferences, briefs on court pleading paper not to exceed three (3) pages – which must be served – may be submitted by email to the Court at dept28@sanmateocourt.org and complexcivil@sanmateocourt.org.
For these informal conferences, briefs on court pleading paper not to exceed three (3) pages – which must be served – may be submitted by email to the Court at dept28@sanmateocourt.org and complexcivil@sanmateocourt.org.
Civil cases
Page 4 | FILINGS AND CORRESPONDENCE
Filing Fees and Waivers
A party electronically filing ex parte papers must pay the application fee when filing.
Parties who e-file their ex parte papers must pay their ex parte application fee at time of filing.
Page 1 | Payment of Fees
Self-represented parties who are not registered for e-filing and appear in person at the Central Courthouse may pay ex-parte fees by phone before the hearing, and must submit their application, supporting papers, and payment proof to the assigned department’s courtroom clerk no later than 15 minutes from the hearing time; checks may be submitted to the clerk at the hearing.
Self-represented parties who have not signed up for e-filing and who are appearing in person at the Central Courthouse may pay their ex-parte fees by phone with a Credit or Debit card before the ex parte hearing, and must submit their ex parte applications, supporting papers, and proof of payment directly to the courtroom clerk for the Department of the assigned Civil Judge no later than 15 minutes from the time set for ex parte hearing. Payments in the form of a check can be submitted directly to the Courtroom Clerk, at the time of the hearing.
Page 1 | Payment of Fees
Self-represented parties not enrolled in e-filing and appearing in person at the Northern Courthouse may pay ex-parte fees before the hearing at the Clerk’s Office or by phone; they must give the assigned judge’s courtroom clerk their applications, supporting papers, and proof of payment within 15 minutes of the hearing time, while check payments may be submitted at the hearing.
Self-represented parties who have not signed up for e-filing and who are appearing in person at the Northern Courthouse may pay their ex-parte fees at the Clerk's Office at the Northern Courthouse, Window 8, or by phone with a Credit or Debit card before the ex parte hearing, and must submit their ex parte applications, supporting papers, and proof of payment directly to the courtroom clerk for the Department of the assigned Civil Judge no later than 15 minutes from the time set for ex parte hearing. Payments in the form of a check can be submitted directly to the Courtroom Clerk at the time of the hearing.
Page 1 | Payment of Fees
Courtesy Copy Requirements
The parties shall include the following documents in accordance with this order with their Joint Pretrial Conference Statement and provide courtesy copies to the Court delivered between the hours of 9:00 a.m. and 4:00 p.m. to the Central Courthouse, Department 28, Courtroom I, 800 North Humboldt St., San Mateo, California 94401: a. Proposed jury instructions; b. Proposed verdict form(s); c. Proposed jury questionnaire (if any); d. Proposed statement of the case; e. Joint witness list; f. Joint deposition designation binders (see paragraph 22(e), above); g. Joint exhibit list, including any disputed exhibits; and h. Binders containing the party’s motions in limine, any oppositions, and any supporting declarations or requests for judicial notice in support of or in opposition to the motions.
The parties shall include the following documents in accordance with this order with their Joint Pretrial Conference Statement and provide courtesy copies to the Court delivered between the hours of 9:00 a.m. and 4:00 p.m. to the Central Courthouse, Department 28, Courtroom I, 800 North Humboldt St., San Mateo, California 94401: a. Proposed jury instructions; b. Proposed verdict form(s); c. Proposed jury questionnaire (if any); d. Proposed statement of the case; e. Joint witness list; f. Joint deposition designation binders (see paragraph 22(e), above); g. Joint exhibit list, including any disputed exhibits; and h. Binders containing the party’s motions in limine, any oppositions, and any supporting declarations or requests for judicial notice in support of or in opposition to the motions.
Civil cases
Page 10 | PRETRIAL CONFERENCE STATEMENT
At least three sets of trial exhibits must be delivered to the court at least 14 days before trial.
Deliver to the Court at least three (3) sets of At least 14 days before the Trial Date trial exhibits
Civil cases
Page 2 | INTRODUCTION
The parties must provide the court with one set of binders for the joint pretrial conference statement.
provide to the Court one (1) set of BINDERS NO MORE THAN 2½ INCHES WIDE
Civil cases
Page 2 | INTRODUCTION
The parties must provide the Court courtesy copies of the joint witness list, deposition designation binders, exhibit list, and motions-in-limine binders between 9:00 a.m. and 4:00 p.m. at the stated courthouse location.
The parties shall include the following documents in accordance with this order with their Joint Pretrial Conference Statement and provide courtesy copies to the Court delivered between the hours of 9:00 a.m. and 4:00 p.m. to the Central Courthouse, Department 28, Courtroom I, 800 North Humboldt St., San Mateo, California 94401: a. Joint witness list; b. Joint deposition designation binders (see paragraph 12(e), above); c. Joint exhibit list, including any disputed exhibits; and d. Binders containing the party’s motions in limine, any oppositions, and any supporting declarations or requests for judicial notice in support of or in opposition to the motions.
Civil cases
Page 7 | PRETRIAL CONFERENCE STATEMENT
Courtesy copies and other court documents must be delivered directly to Courtroom I or, absent permission, sent to Department 28 by messenger, mail, or overnight delivery rather than email.
Courtesy copies, all motions, pretrial, and trial documents shall be delivered directly to Courtroom I in Central Court, 800 North Humboldt St., San Mateo, CA, 94401. Unless Judge Healy gives permission to send courtesy copies by email, all courtesy copies for all documents are to be sent via messenger, mail or overnight delivery to Department 28.
Page 1 | Communications to Department 28
For every motion, the moving party must provide one complete binder set of courtesy copies of all parties' motions and related papers, marked “Judge’s Copy.”
For all motions – the moving party shall provide the Court with one complete set of courtesy copies of all motions and related papers filed by all parties in a binder stamped “Judge’s Copy.”
Civil cases
Page 8 | LAW AND MOTION
Exhibits in the courtesy-copy binder must be tabbed, and the binder must reach Department 28 within two court days by hand or overnight mail.
All exhibits must be separated by exhibit tabs. The binder must be delivered within two court days of filing directly to Department 28 by hand or overnight mail
Civil cases
Page 8 | LAW AND MOTION
The Court may require additional exhibit copies for trial, including separate binders for each witness.
The Court may require additional copies of those exhibits for trial, including separate exhibit binders for each witness.
Civil cases
Page 7
Courtesy copies are not required for Case Management Conference Statements or other non-motion pleadings and papers.
Judge Healy does not need courtesy copies of Case Management Conference Statements or other pleadings or papers that do not relate to a motion.
Civil cases
Page 9 | GENERAL MATTERS
Sealing & Redaction Procedures
A sealing motion or application must be decided no later than a motion that relies on the materials sought to be sealed.
Motions or applications to seal must be heard no later than any motion relying on the materials sought to be sealed.
Civil cases
Page 9 | GENERAL MATTERS
After a sealing request is denied, the movant must either notify the court that the materials will be filed unsealed or refrain from relying on materials excluded from the record.
Upon denial of a motion or application to seal, the moving party must notify the Court that the materials are to be filed unsealed (Cal. Rules of Court, rule 2.551(b)) or refrain from relying on the materials, which will not be part of the record.
Civil cases
Page 9 | GENERAL MATTERS
Filing Bundling Requirements
Parties must file joint pretrial conference statement, and provide to the Court one (1) set of BINDERS NO MORE THAN 2½ INCHES WIDE – with the following: 1. Proposed jury instructions; 2. Proposed verdict form(s); 3. Proposed voir dire and juror questionnaire (if any); 4. Proposed statement of the case; 5. Witness lists; 6. Exhibit lists, including any disputed exhibits; 7. Motions in limine, oppositions, and supporting declarations or requests for judicial notice; and 8. Deposition designations and objections — At least 14 days before the Pretrial Conference
Parties must file joint pretrial conference statement, and provide to the Court one (1) set of BINDERS NO MORE THAN 2½ INCHES WIDE – with the following: 1. Proposed jury instructions; 2. Proposed verdict form(s); 3. Proposed voir dire and juror questionnaire (if any); 4. Proposed statement of the case; 5. Witness lists; 6. Exhibit lists, including any disputed exhibits; 7. Motions in limine, oppositions, and supporting declarations or requests for judicial notice; and 8. Deposition designations and objections — At least 14 days before the Pretrial Conference
Civil cases
Page 2 | INTRODUCTION
Trial exhibits must be provided in at least three binder sets and on a thumb drive.
Deliver to the Court at least three (3) sets of trial exhibits in BINDERS NO MORE THAN 2½ INCHES WIDE – and on a thumb drive — At least 14 days before the Trial Date
Civil cases
Page 2 | INTRODUCTION
Declarations, requests for judicial notice, and attached exhibits supporting or opposing motions in limine must be submitted in a separate tabbed binder with the Joint Pretrial Conference Statement.
Any declarations or requests for judicial notice submitted by the parties in support of or in opposition to the motions in limine along with any attached exhibits must be submitted in a separate tabbed binder. The binders must be submitted to the Court with the Joint Pretrial Conference Statement.
Civil cases
Page 3 | Motions in Limine
Each party must submit a tabbed binder containing motions in limine in numerical order with each opposition immediately behind its motion, submitted with the Joint Pretrial Conference Statement.
Each party must submit a tabbed binder with its motions in limine in numerical order with the opposition immediately behind the motion within the same tab. The binders must be submitted to the Court with the Joint Pretrial Conference Statement.
Civil cases
Page 3 | Motions in Limine
The parties must jointly submit one binder containing a joint pleading with designations, objections, responses, and witness-specific tabs and markings.
The parties must jointly submit one binder with a joint pleading that has the designations, objections and responses followed by tabs for each witness with the designation highlighted in yellow and any objections bracketed in red.
Civil cases
Page 6 | WITNESS LISTS
The required tabbed binders must be submitted with the Joint Pretrial Conference Statement.
The binders must be submitted to the Court with the Joint Pretrial Conference Statement.
Civil cases
Page 3 | MOTIONS IN LIMINE
Declarations, requests for judicial notice, and attached exhibits supporting or opposing motions in limine must be submitted in a separate tabbed binder.
Any declarations or requests for judicial notice submitted by the parties in support of or in opposition to the motions in limine along with any attached exhibits must be submitted in a separate tabbed binder.
Civil cases
Page 3 | MOTIONS IN LIMINE
Each party must submit a tabbed binder containing motions in limine in numerical order, with each opposition placed immediately behind its motion in the same tab.
Each party must submit a tabbed binder with its motions in limine in numerical order with the opposition immediately behind the motion within the same tab.
Civil cases
Page 3 | MOTIONS IN LIMINE
Pre-Motion Conference Requirements
Parties must meet and confer at least 35 days before the Pretrial Conference and make a good-faith effort to resolve evidentiary issues before filing a motion in limine.
The parties shall meet and confer no later than thirty-five (35) days before the Pretrial Conference to determine whether any evidentiary issues may be resolved by stipulation. No party may file a motion in limine without first making a good faith effort to resolve the evidentiary issue with the opposing party.
Civil cases
Page 3 | Motions in Limine
Parties must meet and confer at least 35 days before the Pretrial Conference and make a good-faith effort to resolve evidentiary issues before filing a motion in limine.
The parties shall meet and confer no later than thirty-five (35) days before the Pretrial Conference to determine whether any evidentiary issues may be resolved by stipulation. No party may file a motion in limine without first making a good faith effort to resolve the evidentiary issue with the opposing party.
Civil cases
Page 3 | MOTIONS IN LIMINE
Counsel for the moving party must arrange the pre-hearing conference to occur at least three calendar days before the hearing.
Counsel for the moving party shall arrange the conference to meet and confer at least three (3) calendar days before the hearing
Civil cases
Page 8 | LAW AND MOTION
Before most hearings, counsel and self-represented parties must make a good-faith conference to eliminate the hearing or resolve disputes; pro hac vice applications and counsel-withdrawal motions are excepted.
Therefore, before the hearing of any motion, petition, or application, except applications to appear pro hac vice and motions to withdraw as counsel of record, all counsel and persons appearing in propria persona shall confer in a good faith attempt to eliminate the necessity of the hearing or to resolve as many disputes as possible.
Civil cases
Page 8 | LAW AND MOTION
In general civil cases, parties and non-parties are encouraged to hold an informal discovery conference before filing a discovery motion.
In all general civil cases as defined by CRC Rule 1.6(4), parties and non-parties are encouraged to hold an Informal Discovery Conference with the Court prior to filing a motion to compel or any other discovery motion.
Page 1 | Communications to Department 28
The parties may submit an agreed briefing schedule and proposed order if any reply is filed at least two weeks before the hearing.
So long as any reply is filed at least two (2) weeks before the hearing date, the parties may agree on any briefing schedule and submit a stipulation and proposed order with the agreed-upon schedule for the Court’s signature.
Civil cases
Page 8 | LAW AND MOTION
Adjournment & Extension Requirements
Those who wish to change document due dates should submit a proposed order explaining why they want to change the deadlines.
If they wish to change any of the dates that documents are due to the Court, they should submit a proposed order specifying the reasons why they want to change the deadlines.
Civil cases
Page 11 | TRIAL
Any necessary continuance of a hearing or trial date requires prior Court approval, and a stipulated continuance may proceed only to a date already approved by the Court.
Continuances of hearing and trial dates are discouraged. If a continuance is necessary, it must be approved by this Court. Continuances by stipulation are not permitted without prior approval of the Court, and only to a date pre-approved by the Court.
Civil cases
Page 2 | GENERAL MATTERS
Moving-party counsel must promptly notify Department 28 by telephone and email about matters taken off calendar or continued, and the movant must provide all hearing-continuance notices.
Counsel for the moving parties must notify Department 28 by telephone and by email at dept28@sanmatecourt.org and complexcivil@sanmateocourt.org as soon as possible regarding any matter to be taken off calendar or continued. Notices of continuance of any hearing must be provided by the moving party.
Civil cases
Page 9 | GENERAL MATTERS
Chambers Communication Rules
When a case settles before a hearing or trial, the parties must notify Department 28 by telephone and email as soon as the disposition is agreed upon.
If a case settles before a hearing or trial date the parties must notify Department 28 by telephone at (650) 261-5128 and email (dept28@sanmateocourt.org and complexcivil@sanmatecourt.org) as soon as the disposition is agreed upon
Civil cases
Page 2 | GENERAL MATTERS
The subject line of every Department 28 communication must state the department number, case name, case number, and a brief description of the email.
All communications to Department 28 shall include in the header “subject line” the Department Number, Case Name, Case Number, and a brief description of the email (e.g., “Dept. 28 — Smith v. Jones (CIV654321) – Smith’s Request to Set Motion Date”).
Civil cases
Page 4 | FILINGS AND CORRESPONDENCE
After clearing proposed hearing dates with the other parties, the moving party must email the Clerk of Department 28 at both listed addresses to obtain a hearing date.
With respect to motions or other matters requiring a hearing, after the moving party has cleared the proposed hearing date(s) with the other parties, the moving party must contact the Clerk of Department 28 by email at dept28@sanmateocourt.org and complexcivil@sanmateocourt.org to obtain the hearing date.
Civil cases
Page 8 | LAW AND MOTION
Department 28 emails must identify the case name, case number, and email purpose in the subject line to avoid response delays.
If you send an email to Department 28, please include the following information in the "subject line" header: (1) case name; (2) case number; and (3) a brief description of the purpose of the email. For example: Smith v. Jones, 23-CIV-01234, Proposed Order. Otherwise, a response to your email will likely be delayed.
Page 1 | Communications to Department 28
The application or opposition, supporting papers, and proposed order should be emailed promptly to Department 28 or hand-delivered to the Central Courthouse.
The parties should email their application or opposition, and any supporting papers, and the proposed order AS SOON AS THEY ARE AVAILBLE to the Court at Dept28@sanmateocourt.org or hand deliver the documents to Department 28 at the Central Courthouse located at 800 North Humboldt St., San Mateo.
Page 1 | Communications to Department 28
Parties must email Department 28 to obtain a hearing date for any post-trial motion.
The parties should obtain a hearing date for any post-trial motions by emailing Department 28 at Dept28@sanmateocourt.org.
Page 1 | Pretrial Order - Jury Trials
Copies of all parties must be included on emails to Department 28.
All emails to Department 28 should include all parties.
Page 1 | Communications to Department 28
For an urgent matter requiring an immediate hearing, contact Department 28 preferably by email or by phone.
If the matter is urgent and requires an immediate hearing, please contact Department 28 preferably by email at Dept28@sanmateocourt.org or by phone.
Page 1 | Communications to Department 28
If requested, the Word version of an electronically filed order must be emailed to Department 28 with all parties copied.
If Judge Healy requests a Word version in addition to the e-filed document, the Word version should be emailed to dept28@sanmateocourt.org. All parties must be copied on the email.
Page 1 | Pretrial Order - Jury Trials
Before contacting opposing counsel regarding an available continuance date, email Department 28 and the complex civil address to obtain the dates.
Please email Department 28 at dept28@sanmateocourt.org and complexcivil@sanmateocourt.org for available dates before contacting opposing counsel.
Civil cases
Page 2 | GENERAL MATTERS
Copies and correspondence must not be faxed to Department 28 because it has no dedicated fax line.
Do not fax copies or correspondence to Department 28, as there is no dedicated fax line.
Civil cases
Page 3 | FILINGS AND CORRESPONDENCE
The Department 28 email addresses are for correspondence, not back-and-forth judicial communications or official filings; messages are retained for at least 30 days and then may be destroyed, and email copied to all parties is preferred over telephone communication.
This email address is to receive correspondence, and is not a venue for back-and-forth communications with the judge. Communications to these email addresses are not part of the official court files – just like a paper letter, they are not “filed” documents – and will be retained for at least 30 days and then be subject to deletion (destruction) thereafter. Department 28 prefers to have communication by email (copied to all parties) rather than by telephone.
Civil cases
Page 4 | FILINGS AND CORRESPONDENCE
Informal conferences with the court will be conducted by videoconference unless the court indicates otherwise.
Informal conferences will be conducted by videoconference unless otherwise indicated by the Court.
Civil cases
Page 4 | FILINGS AND CORRESPONDENCE
To arrange a conference with the Court that all counsel agree is advisable, please contact the Clerk for Department 28 by email at dept28@sanmateocourt.org and complexcivil@sanmateocourt.org to schedule a time for the conference.
To arrange a conference with the Court that all counsel agree is advisable, please contact the Clerk for Department 28 by email at dept28@sanmateocourt.org and complexcivil@sanmateocourt.org to schedule a time for the conference.
Civil cases
Page 4 | FILINGS AND CORRESPONDENCE
All papers necessary to the determination of the application, including any proposed pleading, motion, or order, must be submitted to Department 28, preferably by email (to dept28@sanmateocourt.org and complexcivil@sanmateocourt.org), by noon the court day before the scheduled ex parte hearing date.
All papers necessary to the determination of the application, including any proposed pleading, motion, or order, must be submitted to Department 28, preferably by email (to dept28@sanmateocourt.org and complexcivil@sanmateocourt.org), by noon the court day before the scheduled ex parte hearing date.
Civil cases
Page 6 | EX PARTE APPLICATIONS
Parties must coordinate ex parte application hearing dates by email with the Department 28 Clerk at dept28@sanmateocourt.org and complexcivil@sanmateocourt.org.
Hearing dates for ex parte applications must be coordinated by email with the Clerk for Department 28 at dept28@sanmateocourt.org and complexcivil@sanmateocourt.org.
Civil cases
Page 6 | EX PARTE APPLICATIONS
When requesting a hearing date, moving counsel must provide the case name and number, hearing type, requested dates, and the filing attorney's name, telephone number, and email address.
Counsel for the moving party must provide the Court with the case name and number; the type of hearing; the hearing date(s) requested; and the name, telephone number, and email address of the filing attorney.
Civil cases
Page 8 | LAW AND MOTION
Questions about courtroom procedures should be emailed to Department 28, with counsel for all represented parties and pro per parties included.
If counsel or any staff members have questions about these procedures, please email Department 28 at dept28@sanmateocourt.org and include counsel for all represented parties and pro per parties in the email.
Civil cases
Page 9 | PRETRIAL ORDER – COURT TRIAL
Department 28 strongly prefers email communication at Dept28@sanmateocourt.org.
Department 28 strongly prefers to be contacted by email at Dept28@sanmateocourt.org.
Page 1 | Communications to Department 28
Correspondence to Department 28 may be submitted by email to the two listed Department 28 addresses instead of by paper or telephone.
Correspondence to Department 28 may be submitted electronically, rather than by paper or telephone, by e-mail addressed to dept28@sanmateocourt.org and complexcivil@sanmateocourt.org.
Civil cases
Page 3 | FILINGS AND CORRESPONDENCE
Junior Lawyer Participation Incentives
The Court encourages junior lawyers to participate in all proceedings, especially by arguing motions they drafted or substantially contributed to.
The Court therefore encourages the parties and senior attorneys to allow the participation of junior lawyers in all court proceedings, particularly in arguing motions where the junior lawyer drafted or contributed significantly to the motion or opposition.
Civil cases
Page 10 | GENERAL MATTERS