Judge A. Joel Richlin
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Page & Word Limits2 rules
The statement shall not exceed one page. The statement must be filed with the Court no later than five (5) court days before the Final Pretrial Conference date.
- Page limit
- Up to 1 page
Motions in limine limited to 2,800 words; reply briefs limited to 2,100 words.
- Motion in limine
- Up to 2,800 words
- Reply brief
- Up to 2,100 words
Court's wording
Motions in limine and oppositions thereto may be no more than 2,800 words, absent approval from the Court for an oversized brief upon a showing of good cause. Reply briefs, if any, may be no more than 2,100 words, absent approval for good cause.
Document Format Requirements1 rule
Trial schedule: 8:30 AM - 2:30 PM, Mon-Fri, with three 15-minute breaks.
Court's wording
On the day of jury selection, Counsel must be prepared to go on the record at 8:30 a.m.; trial will begin at 9:00 a.m. Thereafter, trial days are generally Monday through Friday, 8:30 a.m. to 2:30 p.m., with three fifteen-minute breaks.
Document Filing Requirements21 rules
Joint witness list due 5 court days before Final Pretrial Conference with witness names, order, and time estimates.
Court's wording
the parties shall file a joint witness list no later than five (5) court days prior to the Final Pretrial Conference. The list shall include the full names of the witnesses in the order that they are expected to testify and provide, to the extent possible, an accurate estimate of the time needed for each witness for direct, cross, redirect, and re-cross.
Proposed Findings of Fact must include citations to admitted evidence and relevant transcript excerpts.
- Document
- Proposed findings of fact
Must include
- •Citations to admitted evidence
Court's wording
The (Proposed) Findings of Fact must include citations to admitted evidence. Where witness trial testimony is necessary to establish a given fact, the party must obtain a transcript of the proceedings and file relevant excerpts of those transcripts with the (Proposed) Findings of Fact and Conclusions of Law.
Plaintiff must serve proposed jury instructions 14 days before Rule 16-2 meeting; defense has 7 days to object.
Court's wording
At least 14 days before the meeting of counsel required by Local Rule 16-2 (which must occur at least 40 days before the date set for the Final Pretrial Conference), counsel for plaintiff(s) must serve on defense counsel proposed jury instructions and proposed verdict/special verdict forms. Within seven (7) days, defense counsel must serve objections, if any, to those instructions and verdict forms, as well as any proposed alternative or additional instructions and verdict forms.
In addition to filing, counsel must email Microsoft Word versions of their (Proposed) Findings of Fact and Conclusions of Law to the chambers email address: AJR_Chambers@cacd.uscourts.gov.
Unless otherwise ordered by the Court, all proposed jury instructions and verdict forms are to be filed no later than five (5) days prior to the Final Pretrial Conference date.
Case-specific glossary due 5 court days before Final Pretrial Conference.
Court's wording
No later than five (5) court days before the Final Pretrial Conference, the parties are to file a case-specific glossary for the Court and reporter that includes applicable medical, scientific, or technical terms, slang, the names and spellings of case names likely to be cited, street/city/country names, all parties/entities involved in the case, names of people interviewed/deposed, names of family members, friends, or others who might be mentioned, and other case-specific terminology.
Counsel must not use objections for the purpose of making a speech, recapitulating testimony, or attempting to guide the witness.
Counsel should not address or refer to witnesses or parties by first name alone. Young witnesses (under 14) may, however, be addressed and referred to by first name.
Lead trial counsel or pro se party must attend Final Pretrial Conference.
Court's wording
Each party appearing in this action must be represented at the Final Pretrial Conference by lead trial counsel or the party if appearing pro se, unless excused for good cause. If a party is represented by co-lead trial counsel, all co-lead trial counsel must attend the Final Pretrial Conference.
Counsel must use the lectern for opening statements, examination of witnesses, and summation arguments.
When objecting, counsel must rise and state only the objection and legal ground.
Court's wording
When objecting, counsel must rise to state the objection and state only that counsel objects and the legal ground of objection. If counsel wishes to argue an objection further, counsel must ask for permission to do so.
Counsel should address all remarks to the Court. Counsel are not to address the Courtroom Deputy Clerk, the court reporter, persons in the audience, or opposing counsel while on the record. If counsel wish to speak with opposing counsel, counsel must ask permission to do so.
Must include
- •Address remarks to court
Parties must comply with Local Rules, FRCP, and Court procedures for discovery.
Court's wording
The parties are expected to comply with all Local Rules and the Federal Rules of Civil Procedure concerning discovery, as well as this Court’s procedures, found at http://www.cacd.uscourts.gov/honorable-joel-richlin.
Counsel and parties should rise when addressing the Court and when the jury enters or leaves the courtroom.
Strict compliance with Local Rule 16 required; non-compliance may result in sanctions.
Court's wording
Strict compliance with Local Rule 16 is required. Note that the Court does not exempt parties without attorneys from the requirements of Rule 16. Failure to comply with these requirements may result in the Final Pretrial Conference being taken off calendar or continued, or other sanctions.
Counsel must not offer a stipulation unless counsel has conferred with
Counsel should not approach the Courtroom Deputy Clerk or the witness box without specific permission. If permission is given, counsel should return to the lectern when the purpose has been accomplished. Counsel should not question a witness at the witness stand.
In addition, counsel must submit electronic versions (in Microsoft Word format) of all proposed instructions to the chambers email address.
Index required with jury instructions including number, title, source, and page.
Court's wording
With each set of instructions filed, counsel must provide an index of all instructions submitted per the example below, which must include the following: (1) the number of the instruction; (2) the title of the instruction; (3) the source of the instruction and any relevant case citations; and (4) the page number of the instruction.
All unserved parties will be dismissed at the time of the Final Pretrial Conference pursuant to Local Rule 16-8.1.
Failure to comply with this notification requirement will cause the parties to be charged for the costs related to processing potential jurors.
Filing & Service rules
Adjournment & Extension Requirements
Discovery cut-off date established for completion of all discovery.
The Court has established a cut-off date for fact and expert discovery. These are not the dates by which discovery requests must be served. They are the dates by which all discovery, including all hearings on any related motions, must be completed.
Civil cases
Motion deadline established; Daubert motions included, motions in limine excluded.
The Court has established a deadline for the hearing of motions. All motions, including motions to determine the admissibility of expert testimony pursuant to Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993), but excluding motions in limine, must be noticed so that the hearing takes place on or before the motion deadline.
Civil cases
Motions to add parties or amend pleadings must be noticed by the deadline.
All motions to add parties or to amend the pleadings must be noticed to be heard on or before the deadline.
Civil cases
Deadline set for completion of settlement conference or mediation.
The Court has set a deadline for the parties to complete a settlement conference or mediation. No case will proceed to trial until the parties have exhausted their efforts at alternative dispute resolution.
Civil cases
Chambers Communication Rules
Settlement notification required by Wednesday before trial week.
In all cases set for jury trial, the parties must notify the Court of any settlement no later than the Wednesday preceding the week that trial is set to start so that the necessary arrangements can be made to notify the members of the public who would otherwise be reporting for jury duty that their services are not needed on that date.
Civil cases