Judge Chi Soo Kim
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Exhibits
- Before Trial
Joint Pretrial Statement, Witness List, Exhibit List, Proposed Voir Dire Questions, Proposed Jury Instructions, Proposed Verdict Forms, Motions in Limine, Trial Briefs
- 2 copies • By Noon After Filing Deadline
Communication
Chambers
Page & Word Limits5 rules
Prisoner case motions limited to 20 pages, oppositions to 20 pages, replies to 10 pages. Exceeding limits without leave will not be considered.
- Motion
- Up to 20 pages
- Opposition
- Up to 20 pages
- Reply
- Up to 10 pages
Exception
More pages with leave of court
Court's wording
all motions and oppositions in prisoner cases are limited to 20 pages, and replies are limited to 10 pages. Only in rare instances and for good cause shown will requests to expand these page limits. Any such requests must be filed in writing at least seven (7) days before the filing. The pages of motions filed that exceed the page limits without prior leave of court will not be considered.
Social Security summary judgment briefs have specific page limits: 25 pages (plaintiff), 30 pages (commissioner), 15 pages (reply).
- Brief
- Up to 25 pages
- Opposition
- Up to 30 pages
- Reply brief
- Up to 15 pages
- Format
- Double-spaced; 12-point
Court's wording
Plaintiff’s motion for summary judgment is limited to 25 pages; the Commissioner’s opposition and cross-motion for summary judgment is limited to 30 pages; and Plaintiff’s optional reply brief is limited to 15 pages. All briefs must use a minimum of 12 point font, double-spaced.
Besides cross motions for summary judgment (see Section I.C), all other motions and oppositions are limited to 20 pages, and replies are limited to 10 pages.
- Motion
- Up to 20 pages
- Opposition
- Up to 20 pages
- Reply
- Up to 10 pages
Pages that exceed the page limits, supplemental briefs, or sur-replies filed without prior leave of court will not be considered.
Page limit expansions and supplemental briefs require good cause and 7-day advance request.
Court's wording
Only in rare instances and for good cause shown will requests to expand these page limits or to file a supplemental brief or sur-reply be granted. Any such requests must be filed in writing at least seven (7) days before the filing.
Document Format Requirements7 rules
The parties should use the most current version of the Ninth Circuit Model Civil Jury Instructions, which are available on the Ninth Circuit website, where possible. If a model instruction is used, the parties shall clearly reference the number of the model instruction. Any modifications to a model instruction must be plainly identified to the Court. Any language a party proposes to be removed from a model instruction must be designated with a strikethrough and language proposed to be added to a model instruction must be underlined. The parties shall provide citation to legal authority in support of proposed changes. All blanks in model instructions shall be completed and all brackets removed.
- Proposed jury instructions
Formatting
- •Reference model instruction number
- •Plainly identify modifications
- •Strikethrough removed language
- •Underline added language
- •Provide legal authority for changes
- •Complete all blanks
- •Remove all brackets
The exhibits lists submitted by the parties must use the following table format.
Courtesy copies must be double-sided, three-hole punched, ECF stamped, tabbed, and marked “Chambers Copy – Do Not File”.
- Binding
- Binder
Formatting
- •Labeled side tabs
Court's wording
These courtesy copies must be double-sided, three-hole punched at the left margin, and marked with the ECF stamp (case number, document number, date, and page number) on the top of each page. These binders shall include labeled side tabs, and be clearly marked “Chambers Copy – Do Not File” with Judge Kim’s name, the case number, and the case name.
Pursuant to Local Rule 138(l), all photographs and other visual images must be submitted electronically in JPG, PNG, or TIFF format.
Typed briefs must be submitted using a minimum of 12 point font for all text, including footnotes, and must be double-spaced.
- Font size
- At least 12 points
- Line spacing
- Double
Briefs must be submitted using a minimum of 12 point font for all text, including footnotes, and must be double-spaced.
- Font size
- At least 12 points
- Line spacing
- Double
Multi-page exhibits must be internally paginated, with the pagination for each exhibit beginning at one (1) (for example, Exh. A-1, Exh. A-2, etc.).
Document Filing Requirements11 rules
The jury will consist of 9 jurors with no alternate jurors. Any request to deviate from this practice must be made in writing.
Each side gets 3 peremptory challenges; jury empaneled after two consecutive passes.
Court's wording
Each side will be given 3 peremptory challenges, which will be made in writing on a peremptory challenges sheet. Peremptory challenges may be used as to any of the 15 potential jurors in the box. If there are two consecutive passes (e.g., pass by Plaintiffs and pass by Defendants), the jury will be empaneled.
Joint filing of proposed jury instructions with TOC, objections noted, and Word copy emailed.
- Document
- Proposed jury instructions
Must include
- •Single document
- •Legal basis for objections
- •Table of contents with page numbers
Court's wording
Proposed jury instructions must be filed jointly in a single document and arranged in the order the parties propose the Court give the instructions. The document shall include a table of contents with page numbers at the beginning of the document. Where a party objects to an instruction, that instruction should be included in the proposed jury instructions with the opposing party’s objection noted. Along with the contested proposed instruction, the opposing party may provide a brief statement of the legal basis for its objection with citation to legal authority and propose an alternate jury instruction, as appropriate. At the time of filing, the parties shall also e-mail a copy of the proposed jury instructions as a Word document to cskorders@caed.uscourts.gov.
AI-generated exhibits/illustrative aids require written pre-trial notice and must be identified as AI Generated on exhibit lists.
- Document
- Exhibits list
Must include
- •AI disclosure
- •AI Generated
Court's wording
Artificial Intelligence (AI) Generated Exhibits and Illustrative Aids: Parties must provide written pre-trial notice of AI generated exhibits and illustrative aids, and such exhibits must also be identified on the exhibit lists submitted by the parties as AI Generated.
Illustrative aids must be marked as exhibits and provided to Court; allowed aids entered into record.
- Document
- Illustrative aids
Must include
- •Exhibit label
- •Provided to court
- •Entered into record
Court's wording
Pursuant to Federal Rule of Evidence 107, illustrative aids a party may seek to use during trial must be marked with an exhibit label and provided to the Court. Illustrative aids that the Court allows a party to use during trial will be entered into the record.
For jury trials, during jury deliberations, trial counsel and pro se parties must be within 30 minutes of the courthouse to ensure that they can promptly return to the courthouse.
If a party makes reference to or cites a deposition in a filing or a settlement conference statement, the party must simultaneously attach as an exhibit only the excerpts of the relevant portion of the deposition transcript referenced or cited. Entire deposition transcripts should not be filed through CM/ECF. Under Local Rule 133(j), parties are required to submit a courtesy copy of the entire deposition transcript either as a hard copy to the Clerk of Court or as an electronic copy by email to chambers.
- Document
- Filing
Must include
- •Exhibit
Deposition transcripts must be submitted electronically via email with specific subject line format.
Court's wording
this requirement by submitting the deposition transcript as an electronic copy only by email to CSKorders@caed.uscourts.gov. The email subject line must contain the case number, the words “deposition transcript,” and the last name of the deponent.
The box will be filled with 15 potential jurors.
At the Court’s discretion, each side will typically be given 20 minutes to conduct additional voir dire after the Court performs its voir dire.
Court will give specific Ninth Circuit Model Civil Jury Instructions as preliminary instructions.
Court's wording
The Court will give the following Ninth Circuit Model Civil Jury Instructions as preliminary instructions to the jury: 1.2 & 1.3 – Duty of Jury (modified, no written copies) 1.5 – Claims and Defenses 1.6 or 1.7 – Burden of Proof 1.9 – What is Evidence 1.10 – What is Not Evidence 1.12 – Direct and Circumstantial Evidence 1.13 – Ruling on Objections 1.14 – Credibility of Witnesses 1.15 – Conduct of the Jury
Filing & Service rules
Courtesy Copy Requirements
Two sets of courtesy copies required for multiple trial documents by noon after filing deadline.
Two sets of courtesy copies of the Joint Pretrial Statement, witness lists, exhibit lists, proposed voir dire questions, proposed jury instructions, proposed verdict forms, motions in limine, and trial briefs must be delivered in two separate binders to the Clerk’s office by noon the day after the filing deadline for such documents. For bench trials, courtesy copies must include the proposed findings of fact and conclusions of law. Parties do not need to provide courtesy copies of the motion in limine oppositions.
Civil cases
Page 5 | Trial Procedures
Final Pretrial Order will contain additional exhibit instructions including courtesy copy requirements.
The Final Pretrial Order will provide further instructions on exhibits, including instructions regarding courtesy copies of exhibits to be provided to the Court before trial.
Civil cases
Page 4 | C. Exhibits
Filing Bundling Requirements
Parties should coordinate this submission so that only two sets total are submitted.
Parties should coordinate this submission so that only two sets total are submitted.
Civil cases
Page 5 | Trial Procedures
Chambers Communication Rules
Parties, including parties proceeding without an attorney, should refrain from emailing Judge Kim or her staff except as provided for in these standing orders (for example, to submit proposed orders or settlement conference statements, request a settlement conference or an informal discovery conference, etc.), Judge Kim’s orders (for example, to submit certain trial documents in Word format), or the Local Rules (for example, Local Rule 141 sealing documents). Judge Kim and her staff will not otherwise respond to email communications.
Parties, including parties proceeding without an attorney, should refrain from emailing Judge Kim or her staff except as provided for in these standing orders (for example, to submit proposed orders or settlement conference statements, request a settlement conference or an informal discovery conference, etc.), Judge Kim’s orders (for example, to submit certain trial documents in Word format), or the Local Rules (for example, Local Rule 141 sealing documents). Judge Kim and her staff will not otherwise respond to email communications.
Civil cases
Page 7 | C. Email Communications
Junior Lawyer Participation Incentives
Court will hold hearing if junior attorney (under 5 years) requests oral argument 10 days in advance.
If a written request for oral argument is filed at least 10 days before the scheduled hearing and states that an attorney with less than five (5) years of experience as a practitioner will present oral argument, the Court will hold a hearing.
Civil cases