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Court Rules
Judge Yvonne Gonzalez Rogers
Chief Judge

Judge Yvonne Gonzalez Rogers

Individual Rules, Standing Orders & Policies

Rules last changed:
Northern District of California

Limits & Logistics

Document Limits

Disputed Excerpts
6 pgs
Brief
2 pgs
Motion in Limine
4 pgs
Summary Judgment Motion
25 pgs
Cross Motion
25 pgs
Motion
5 pgs

Courtesy Copies

Audio Visual Demonstrative

  • At Least 24 Hours Before Hearing

Briefing

Courtesy copies

  • 2 copies • Chambers Drop Off
  • Email
  • Encouraged
  • On a Rolling Basis During Trial
  • Upon Filing
  • Within 2 Business Days

Exhibit

Adjournments

  • ADA claims must follow General Order 56 deadlines; extensions require 1-week advance notice and good cause.
  • An extension of a General Order 56 deadline must be requested at least one week before the deadline and supported by a concrete, particularized showing of good cause.
Reason for Request
  • Changes to the Court’s schedule require a signed court order and a showing of good cause.
  • A continuance requires good cause, with particular attention to the requesting party’s diligence and potential prejudice if the request is denied.
  • A Motion for Administrative Relief seeking more time to file should be filed sufficiently before the deadline for the Court to respond, not on the due date or immediately before it.
  • +5 more

Request must include

Reason for Request
  • ADA litigation deadline extensions must be sought one week in advance with a showing of good cause.
Reason for Request

Communication

Email

Chambers

ygrpo@cand.uscourts.gov
Phone

Clerk, Chambers

(510) 637-3540
EmergenciesSchedulingTechnical Issues
No status inquiries
Cases:
Filters:

Page & Word Limits35 rules

Page LimitsCivil cases

Parties are advised that the Court will not resolve more than six pages of disputed excerpts (in total) and the parties must give the Court sufficient information to resolve the dispute, including information on the deponent and any context for the dispute.

Disputed excerpts
Up to 6 pages in total
YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 4
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Page LimitsCivil cases

“Brief” is defined as not exceeding two double-spaced pages per side. The Court will order additional briefing if necessary.

Brief
Up to 2 pages per side
Format
Double-spaced
Page LimitsCivil cases

Each motion may not exceed more than four (4) pages.

Page limit
Up to 4 pages
Page LimitsCivil cases

Supporting Separate Statement limited to 15 pages; Responsive Separate Statement limited to 5 pages beyond opening statement.

Supporting separate statement
Up to 15 pages
Applies to
  • Responsive separate statement

Court's wording

Unless a party has obtained prior permission from this Court, the Supporting Separate Statement is limited to no more than fifteen (15) pages, and the Responsive Separate Statement is limited to no more than five (5) additional pages beyond the number of pages in the opening statement.

YGR-Civil-StandingOrder-10-17-25) · Nov 2025 · p. 7
|SectionPage Limits for Separate Statements
Page LimitsCivil cases

Cross-motion for summary judgment limited to 25 pages, filed within opposition, due 14 days after motion.

Cross-motion
Up to 25 pages

Court's wording

Any cross-motion for summary judgment shall be contained within the opposition to any motion for summary judgment, shall contain twenty- five (25) pages or less, and shall be filed fourteen (14) days after the filing of the motion.

Page LimitsCivil cases

Each side is limited to three Daubert motions throughout the entire case absent leave of court.

Page LimitsCivil cases

The reply to a motion may contain up to fifteen (15) pages, shall include the opposition to any cross-motion, and shall be filed seven (7) days after the filing of the opposition.

Reply
Up to 15 pages
Page LimitsCivil cases

Within 5 business days of the oppositions being filed, moving parties shall file replies of no more than five pages, unless leave is granted per the procedures described above.

Reply
Up to 5 pages
Applies to
  • Sealing motions

Exception

More pages with leave of court

YGR-Civil-StandingOrder-10-17-25) · Nov 2025 · p. 11
|SectionOmnibus Motions on Sealing Disputes
Page LimitsCivil cases

Oppositions to sealing motions limited to 5 pages unless leave granted.

Opposition
Up to 5 pages per party
Applies to
  • Sealing motions

Exception

More pages with leave of court

Court's wording

Within 5 business days of the motions being filed, each party may file one opposition, of no more than 5 pages, unless leave is granted per the procedures identified above, in response to the sealing motions.

YGR-Civil-StandingOrder-10-17-25) · Nov 2025 · p. 11
|SectionOmnibus Motions on Sealing Disputes
Page LimitsCivil cases

Each party may file one motion addressing all disputed documents and information. Each motion shall be no longer than 5 pages unless leave from the Court is granted.

Motion
Up to 5 pages
Applies to
  • Sealing motions

Exception

More pages with leave of court

YGR-Civil-StandingOrder-10-17-25) · Nov 2025 · p. 11
|SectionOmnibus Motions on Sealing Disputes
Page LimitsCivil cases

All issues shall be contained within one motion, may not exceed twenty-five pages in length, and shall conform to Civil Local Rule 7-2.

Page limit
Up to 25 pages
Applies to
  • Rule 56 motions
Page LimitsCivil cases

Claim construction briefs have page limits: opening/opposition (25 pages), reply (15 pages)

Opening brief
Up to 25 pages
Opposition brief
Up to 25 pages
Reply brief
Up to 15 pages
Applies to
  • Claim construction brief

Court's wording

Claim construction briefs shall address each disputed term, but only those that are truly disputed, following the order of the joint statement. The opening and opposition briefs shall not exceed 25 pages; the reply brief shall not exceed 15 pages.

Page Limits

All other requests for discovery relief must be summarized by the parties in one joint letter brief no longer than four pages (two pages per side).

Page Limits

Summary judgment issues must be presented in one motion per side, limited to 25 pages and compliant with Civil Local Rule 7-2; additional motions require court leave, which may be requested when a side includes multiple parties.

Motion
Up to 25 pages

Exception

More pages with leave of court

Court's wording

All issues shall be contained within one motion, may not exceed twenty-five pages in length, and shall conform to Civil Local Rule 7-2. Only one summary judgment motion may be filed collectively per side, absent leave of court. Leave of court to file more than one motion may be requested if multiple parties comprise one or both sides. This issue will be addressed at the Pre-filing Conference.

Page Limits

The Supporting Separate Statement is limited to no more than fifteen (15) pages, and the Responsive Separate Statement is limited to no more than five (5) additional pages beyond the number of pages in the opening statement.

Supporting separate statement
Up to 15 pages
Page Limits

Any cross-motion for summary judgment shall be contained within the opposition to any motion for summary judgment, shall contain twenty- five (25) pages or less, and shall be filed fourteen (14) days after the filing of the motion.

Cross-motion
Up to 25 pages
Page Limits

The reply to a motion may contain up to fifteen (15) pages, shall include the opposition to any cross-motion, and shall be filed seven (7) days after the filing of the opposition.

Reply
Up to 15 pages
Page Limits

Within 5 business days of the oppositions being filed, moving parties shall file replies of no more than five pages, unless leave is granted per the procedures described above.

Reply
Up to 5 pages

Exception

More pages with leave of court

Page Limits

Each party may file one motion addressing all disputed documents and information. Each motion shall be no longer than 5 pages unless leave from the Court is granted.

Motion
Up to 5 pages

Exception

More pages with leave of court

Page Limits

Within 5 business days of the motions being filed, each party may file one opposition, of no more than 5 pages, unless leave is granted per the procedures identified above, in response to the sealing motions.

Opposition
Up to 5 pages per party

Exception

More pages with leave of court

Page LimitsCriminal cases

Parties may not file more than five motions per side or exceed page limitations without leave of the Court.

Page limit
Up to 5 pages per side

Exception

More pages with leave of court

Page LimitsCriminal cases

Parties should address a single, separate topic in each motion in limine, and contain no more than seven pages of briefing per side.

Motion in limine
Up to 7 pages per side
Page LimitsCivil cases

The parties must include the following information in their statement which, except in unusually complex cases, should not exceed ten pages:

Page limit
Up to 10 pages
Standing Order All Judges-11-30-2023 · Nov 2023 · p. 1
|SectionCONTENTS OF JOINT CASE MANAGEMENT STATEMENT
Page LimitsCivil cases

The parties must include the following information in their statement which, except in unusually complex cases, should not exceed ten pages:

Page limit
Up to 10 pages
Applies to
  • Case management statement
Page LimitsCivil cases

All other requests for discovery relief must be summarized by the parties in one joint letter brief no longer than four pages (two pages per side).

Joint letter brief
Up to 4 pages per side

Document Format Requirements45 rules

FormattingCivil cases

The parties shall provide a labeled tab to identify the document(s) being added to the binder.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 3
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
FormattingCivil cases

This information shall be presented in chart format and organized by party.

Formatting

  • Present the information in chart format and organize it by party
YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 3
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
FormattingCivil cases

Further, they shall be highlighted, underlined or otherwise marked for ease of the Court's reference and contain sufficient contextual information.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 4
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
FormattingCivil cases

EACH disputed designation shall be separately numbered and shall correspond to the materials provided to the Court for resolution of the dispute.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 4
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
FormattingCivil cases

This information shall be presented in chart format and organized numerically.

Formatting

  • Present the information in chart format and organize it numerically
YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 4
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
FormattingCivil cases

Requested instructions should generally use the Model Instructions or state equivalent, with each typed in full on a separate page followed by authority annotations or citations; instructions must be brief, clear, plain English, and nonargumentative, with explanations of authorities and revisions.

Applies to
  • Jury instructions

Formatting

  • Include annotations or citations to the supporting authorities below the instruction

Court's wording

(D) In general, parties shall provide the Court with instructions from the Model Instructions or the relevant state equivalent. Each requested instruction shall be typed in full on a separate page with annotations or citations to the authorities upon which the instruction is based included below the instruction. Instructions shall be brief, clear, written in plain English, and free of argument. Model Instructions shall be revised to address the particular facts and issues of this case. The parties shall give a brief explanation of their authorities and any revisions to Model Instructions.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 6
|Sectionii. Substance and Format of Instructions.
FormattingCivil cases

The listed trial documents must be sent electronically in MS Word format to the specified court email address.

File type
Word
Applies to
  • Proposed order
  • Jury instructions
  • Proposed juror questionnaire
  • Proposed verdict form

Court's wording

Parties shall send an electronic copy in MS Word format to ygrpo@cand.uscourts.gov of the following documents listed above: (i) Proposed Order Re: Trial Stipulations; (ii) Proposed Order Re: Discovery Excerpts; (iii) Joint Set of Jury Instructions; (iv) any revised or supplemental jury instructions; (v) Proposed Juror Questionnaire (if any); (vi) Proposed Verdict Forms; and (vii) Proposed Order(s) on Motions in limine.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 8
|Section5. ELECTRONIC COPIES OF TRIAL DOCUMENTS
FormattingCivil cases

All groups of exhibits containing multiple parts (including photographs) shall be marked separately for each part (e.g., 1-A, 1-B, and 1-C).

FormattingCivil cases

Each exhibit shall be pre-marked with an exhibit tag placed in the top right corner of the first page of a document. Parties are to use different colors than white for the exhibit tags.

Applies to
  • Exhibits

Formatting

  • Use an exhibit-tag color other than white
FormattingCivil cases

In addition to the copy in the binder, parties shall send an electronic copy in Word format to ygrpo@cand.uscourts.gov.

FormattingCivil cases

Proposed Findings shall be brief, written in plain English and free of pejorative language, conclusions, and argument.

FormattingCivil cases

Questions should not be indented or numbered, and the answers should not be bulleted, lettered, or otherwise structured in any way.

Applies to
  • Questionnaire

Formatting

  • Do not indent or number questions
  • Do not bullet, letter, or otherwise structure answers
FormattingCivil cases

**Parameters:** No formatting at all in the document you send us. This means that questionnaires should not be on pleading paper, but in an unformatted word document.

File type
Word
Applies to
  • Questionnaire

Formatting

  • Do not use pleading paper
  • Submit the questionnaire as an unformatted Word document with no formatting
FormattingCivil cases

Counsel must familiarize themselves with NDCA e-filing guidance, even when using staff.

Formatting

  • Familiarize with ECF guidance

Court's wording

It is imperative that counsel know what their filings will look like on ECF once submitted to the Court. Accordingly, counsel shall familiarize themselves with this District's guidance on e-filing available online at https://www.cand.uscourts.gov/cases-e-filing/cm-ecf/. This applies even if counsel will be relying extensively on staff to finish filings.

FormattingCivil cases

Incorporation by reference is a narrow exception applicable to certain pleadings. Parties shall never... creates substantial administrative burdens and may be construed as circumventing limits on pagination.

Formatting

  • Incorporation by reference prohibited
FormattingCivil cases

All chambers’ copies must be 3-hole punched in the left margin in a manner suitable for placement in a 3-ring binder. They shall not be stapled.

Binding
Three-ring binder
FormattingCivil cases

Chambers copies must include tabs between exhibits and fasten individual documents.

Binding
Tabbed binder

Court's wording

Chambers copies must include tabs between exhibits and must fasten or attach pages of individual documents together so as to distinguish between separate documents. Do not use bottom tabs as they do not work well in binders.

Formatting

Moreover, parties shall underline, highlight, or otherwise specify lines of the documents and transcripts upon which they rely in support of or opposition to a motion.

FormattingCivil cases

Summary judgment motion and opposition materials must be submitted in 3-ring binders with tabs separating documents; exemption applies to habeas, ERISA, and Social Security summary judgment cases.

Binding
Tabbed three-ring binder
Applies to
  • Motion
  • Opposition
  • Separate statement
  • Declarations
  • Exhibits

Formatting

  • Chambers copies submitted without meeting requirements may be rejected and require re-submission

Court's wording

summary judgment motions and oppositions (including the brief, separate statement, declarations, exhibits, and other supporting documents) are required to be provided by the filing party in a 3-ring binder or binders with tabs separating documents. This requirement does not apply to habeas corpus petitions or summary judgment motions in ERISA or Social Security cases.

FormattingCivil cases

Parties filing or opposing summary judgment motions must submit a separate statement in the required format, except pro se plaintiffs are exempt.

Court's wording

Any party moving for summary judgment or opposing summary judgment is required to submit a separate statement as set forth herein. Pro se plaintiffs, however, are not required to submit a separate statement. 1. Supporting Separate Statement: Parties moving for summary judgment must include a separate, short and concise statement of the material facts as to which the moving party contends there is no genuine issue to be tried (“Supporting Separate Statement”). The Supporting Separate Statement must: (1) identify the issue or claim number(s) to which the fact relates; and (2) list each asserted material fact and the record evidence with specific pincites (e.g., deposition, declaration, discovery response). The Supporting Separate Statement must follow this format: Opposing Party’s Moving Party’s Undisputed Material Facts Issue No. Response and and Supporting Evidence Supporting Evidence Issue 1 Fact 1. Doe Co. and Acme Co. entered into a (Doe cannot written contract for sale of widgets. establish Roe Declaration at 2:17-21 and Exh. A [contract]. breach of contract) Issue 1 Fact 2. Widgets were received by Doe’s headquarters on December 1, 2010. Roe Declaration at 3:14-19 and Exh. B [signed invoice].

FormattingCivil cases

Parties must cite to the record and underline/highlight specific lines relied upon.

Applies to
  • Motion
  • Opposition

Formatting

  • Particular citations to the record

Court's wording

parties shall provide particular citations to the record. Moreover, parties shall underline, highlight, or otherwise specify lines of the documents and transcripts upon which they rely in support of or opposition to a motion.

FormattingCivil cases

This shall be in chart form with a column identifying the document(s), a column describing the action to be taken (seal, portions to redact, unseal), and a column for the Court’s order.

Applies to
  • Proposed order sealing

Formatting

  • Agreed PHI/PII need not be included in the proposed order chart

Document Filing Requirements131 rules

Filing RequirementsCivil cases

To comply with this requirement, trial counsel shall meet and confer at least twenty-one (21) days in advance of the Pretrial Conference.

Filing RequirementsCivil cases

The parties shall file a joint Pretrial Conference Statement containing the information listed below.

Filing RequirementsCivil cases

A Proposed Order outlining all such stipulations shall be presented to the Court.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 3
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Filing RequirementsCivil cases

Witnesses not included on the list will be excluded from testifying unless the Court orders otherwise.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 3
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Filing RequirementsCivil cases

The list shall identify by an asterisk or other notation whether the witness listed is viewed as a primary witness or only included as a precautionary measure.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 3
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Filing RequirementsCivil cases

If the expert has prepared a report in preparation for the testimony, a copy thereof shall be furnished to opposing counsel and included in a separate Trial Readiness Binder.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 3
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Filing RequirementsCivil cases

A list of all expert witnesses with a summary plainly stating the expert's theories and conclusions and the basis therefore, accompanied by a curriculum vitae.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 3
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Filing RequirementsCivil cases

The witness list must identify likely trial witnesses, except those called solely for impeachment or rebuttal, and provide the specified testimony, examination-time, and presentation details for each.

Court's wording

A list of all witnesses likely to be called at trial (other than solely for impeachment or rebuttal), with a brief statement following each name that describes the substance of the testimony to be given, provides a time estimate of the direct and cross examinations, and specifies for each witness whether the plan is to present by live testimony, video deposition, or reading of a deposition transcript.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 3
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Filing RequirementsCivil cases

The parties shall either issue trial notices to witnesses controlled by the other party or stipulate as to the manner of notification that the witness is being called.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 3
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Filing RequirementsCivil cases

A party may not rely on an opposing party's identification of a witness for their own case in chief.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 3
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Filing RequirementsCivil cases

A paper copy of the parties Pretrial Conference Statement shall be included in the Trial Readiness Binders.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 3
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Filing RequirementsCivil cases

That is, should a party need to call a given witness at trial, they must identify that witness themselves in the witness list.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 3
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Filing RequirementsCivil cases

The Joint Trial Readiness Binders shall contain copies of filed documents with the ECF header reflecting the item's docket number and filing date.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 3
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Filing RequirementsCivil cases

The parties shall (i) identify any remaining legal objections to the excerpts on the list itself, and (ii) attach in a separate appendix copies of the disputed excerpts/transcripts so that the Court can review the disputed materials.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 4
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Filing RequirementsCivil cases

The Exhibit List shall specify for each exhibit: (1) if it is being marked for identification only, not for admission; (2) whether the parties stipulate to its admission; and (3) the grounds for any objection to its admission.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 4
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Filing RequirementsCivil cases

As part of the Trial Readiness Binder, the parties shall include a list of all documents and other items to be offered as exhibits at the trial (other than solely for impeachment or rebuttal).

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 4
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Filing RequirementsCivil cases

The agreed-upon designations shall be noted for the Court.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 4
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Filing RequirementsCivil cases

Each entry shall include a brief description of the contents, and the identity of each sponsoring witness.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 4
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Filing RequirementsCivil cases

The parties shall provide a single proposed order with each disputed designation which will allow the Court to rule whether permission to use each is granted, granted with modification, or denied.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 4
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Filing RequirementsCivil cases

The parties shall list (i) those excerpts from depositions, from interrogatory answers, or from responses to requests for admission (other than those solely for impeachment or rebuttal) and (ii) any other audio or video likely to be used at trial.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 4
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Filing RequirementsCivil cases

The Exhibit List shall also include an additional column so that the Court can track the date on which each exhibit is admitted.

YGR-Civil-Pretrial-Order-Revised-January-2025 · Mar 2025 · p. 4
|Section3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON
Filing RequirementsCivil cases

(C) If the parties resolve any disputes prior to the Pretrial Conference, the parties must immediately inform the Court which proposed instructions are withdrawn, and submit the stipulated instruction to the Court.

Filing RequirementsCivil cases

The parties must prepare an index showing whether each instruction is stipulated or objected to and sequencing competing instructions for comparison.

Court's wording

(B) The parties shall prepare an index which identifies: (i) whether the parties stipulate or object to each instruction; and (ii) the competing instruction(s) preferred on a given topic must be sequenced such that the Court can readily compare and contrast the same.

Filing & Service rules

Electronic Filing Rules

For exhibit sets exceeding seven binder volumes, parties must provide an electronic version of all documents.

An electronic version of all the documents.

Civil cases

Page 10 | 6. EXHIBITS

Discovery letter briefs must be electronically filed using the specified Civil Events category and docket entry.

Discovery letter briefs must be e-filed under the Civil Events category of Motions and Related Filings: Motions—General: “Discovery Letter Brief.”

Page 4 | 8. Discovery and Discovery Motions

Discovery letter briefs must be e-filed under the specified category in the court’s electronic filing system.

Note: Discovery letter briefs must be e-filed under the Civil Events category of Motions and Related Filings: Motions—General: “Discovery Letter Brief.”

Civil cases

Page 4 | Discovery Disputes (b)

Parties must submit a redline comparison with the model standard litigation stipulated protective order and the electronic proposed order to ygrpo@cand.uscourts.gov.

The parties shall submit a redline comparison with the model Stipulated Protective Order for Standard Litigation, along with their electronic form of proposed order, to ygrpo@cand.uscourts.gov.

Civil cases

Page 5 | Discovery Disputes

Proposed orders on sealing requests must be filed electronically and emailed to the Court’s proposed order inbox.

Parties shall file and email to the Court’s proposed order inbox, a proposed order addressing all sealing requests.

Civil cases

Page 12 | Sealing

Names assigned to individual attachments and documents should be as descriptive as possible to help the Court identify them on the docket.

These names shall be as descriptive as possible to help the Court identify pertinent documents on the docket.

Page 14 | 21. Formatting Considerations — d. Electronic Filing

The Court may strike burdensome or illegible filings and direct that they be refiled in accordance with district guidance.

Parties are on notice that the Court may strike burdensome and/or illegible filings and direct them to be refiled consistent with the District’s guidance.

Page 14 | 21. Formatting Considerations — d. Electronic Filing

Pro se litigants may, but are not required to, register as ECF users.

While not required, pro se litigants may sign up to be registered ECF users.

Page 14 | 21. Formatting Considerations — d. Electronic Filing

Filing Timing and Cure Windows

The parties must file a Joint Statement five business days before the compliance deadline, confirming timely meet-and-confer compliance or explaining any failure to comply.

Five (5) business days prior to the date of the compliance deadline, the parties shall file a Joint Statement confirming they have complied with this requirement or explaining their failure to comply.

Civil cases

Page 1 | 2. PRETRIAL CONFERENCE STATEMENT

The joint Pretrial Conference Statement is due 15 days before the Pretrial Conference.

The Statement is due fifteen (15) days prior to the Pretrial Conference.

Civil cases

Page 1 | 2. PRETRIAL CONFERENCE STATEMENT

The binder is due by noon at least seven days before the Pretrial Conference for cases to be tried in a week, or fourteen days before for all other cases.

To provide the Court with sufficient time to prepare, the binder of documents is due by noon no less than seven (7) days prior to the Pretrial Conference for cases to be tried in a week and fourteen (14) days for all other cases.

Civil cases

Page 3 | 3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON

Opposition papers must be filed and served at least 9 days before the Pretrial Conference for cases tried in a week, or 16 days before it for all other cases.

Any party opposing such a motion in limine shall file and serve its opposition papers no later than nine (9) days prior to the Pretrial Conference for cases to be tried in a week and sixteen (16) days for all others.

Civil cases

Page 8 | 4. MOTIONS IN LIMINE

Motions in limine to be heard before trial must be exchanged, but not filed, at least 28 days before the Pretrial Conference.

Any party wishing to have motions in limine heard prior to the commencement of trial must exchange (but not file) the same no later than twenty-eight (28) days prior to the date set for the Pretrial Conference.

Civil cases

Page 8 | 4. MOTIONS IN LIMINE

Unresolved motions in limine must be filed with the Pretrial Conference Statement.

Any motions in limine not resolved shall be filed at the same time as the Pretrial Conference Statement.

Civil cases

Page 8 | 4. MOTIONS IN LIMINE

A joint case management statement must be filed seven days before the initial case management conference.

Joint case management statements are required and must be filed seven days in advance of the initial case management conference date.

Page 3 | 6. Case Management Conference

An updated joint case management statement must be filed seven days before every other case management conference.

Updated joint case management statements are required and must be filed seven days in advance of all other case management conferences.

Page 3 | 6. Case Management Conference

A designating party that fails to file the discovery dispute letter within the applicable 21- or 14-day period automatically waives confidentiality for each challenged designation.

Failure by a Designating Party to file such discovery dispute letter within the applicable 21- or 14-day period (set forth above) with the Court shall automatically waive the confidentiality designation for each challenged designation.

Page 4 | 8. Discovery and Discovery Motions

The reply must be filed 7 days after the opposition is filed.

The reply to a motion may contain up to fifteen (15) pages, shall include the opposition to any cross-motion, and shall be filed seven (7) days after the filing of the opposition.

Page 8 | Cross-Motions

The cross-motion must be filed 14 days after the summary-judgment motion is filed.

Any cross-motion for summary judgment shall be contained within the opposition to any motion for summary judgment, shall contain twenty- five (25) pages or less, and shall be filed fourteen (14) days after the filing of the motion.

Page 8 | Cross-Motions

Each designating party or third party must communicate with the filing party about the sealing designations within 10 calendar days after receiving service.

Within 10 calendar days of receiving service, each designating party or third party shall communicate with the filing party regarding the sealing designations made.

Page 10 | 12. Motions to Seal—Service and Opportunity for Dedesignation

After meeting and conferring about proposed sealing and redactions, the parties must file the required omnibus sealing materials within 14 calendar days after briefing concludes on the motion or other filing.

Within 14 calendar days following the conclusion of briefing on the motion or other filing 2 for which the sealing requests were made, the parties shall file, after the filing and designating parties meet and confer regarding the proposed sealing and redactions:

Page 10 | Post-Briefing Omnibus Sealing Procedures

Each party may file one opposition within 5 business days after the sealing motions are filed; the opposition is limited to 5 pages unless leave is granted.

Within 5 business days of the motions being filed, each party may file one opposition, of no more than 5 pages, unless leave is granted per the procedures identified above, in response to the sealing motions.

Page 11 | Omnibus Motions on Sealing Disputes

Moving parties must file replies within 5 business days after oppositions are filed; replies are limited to 5 pages unless leave is granted.

Within 5 business days of the oppositions being filed, moving parties shall file replies of no more than five pages, unless leave is granted per the procedures described above.

Page 11 | Omnibus Motions on Sealing Disputes

When the Court orders changes to redactions or sealing, the parties must jointly file within 14 days a stipulation attaching all modified documents and a chart matching them to docket entries.

If the Court orders modifications to the redaction/sealing of documents, within 14 days of the Court’s order the parties shall jointly file a stipulation with all modified documents attached. The stipulation shall include a chart which identifies the docket entries to which each modified document corresponds.

Page 12 | Procedures After Court Issues Sealing Orders

Within 14 days after service of the complaint or consolidated complaint, the plaintiff must file a chart containing the specified operative-complaint allegations.

Within 14 days of service of the complaint (or consolidated complaint), the plaintiff shall file a chart summarizing the information required by 15 U.S.C. § 78u-4(b)(1) and (2), specifically identifying the allegations in the operative complaint as follows: (a) each statement alleged to have been false or misleading; (b) the speaker, date, and medium by which the statement was made; (c) the reason(s) the statement was false or misleading when made; and (d) the facts alleged to show that defendant(s) knew the statement false and/or misleading.

Page 12 | 14. Securities Cases

Unresolved motions in limine must be filed at least 7 days before the pretrial conference.

Any motions not resolved shall be filed not less than seven (7) days prior to the pretrial conference.

Criminal cases

Page 2 | Pre-trial Motions in Limine

A joint pretrial conference statement must be filed at least 7 days before the pretrial conference, addressing all 15 issues in Local Rule 17.1-1(b).

Counsel shall comply with Local Rule 17.1-1(b) and file a joint pretrial conference statement not less than seven (7) days prior to the pretrial conference addressing all fifteen (15) issues identified therein.

Criminal cases

Page 2 | Joint Pretrial Conference Statements

Motions in limine must be served (not filed) 21 days before the pretrial conference; oppositions 14 days before.

Unless otherwise ordered, not less than twenty-one (21) days prior to the pretrial conference, the parties shall serve, but not file, motions in limine. Not less than fourteen (14) days prior to the pretrial conference, the parties shall serve, but not file, any oppositions thereto.

Criminal cases

Page 2 | Pre-trial Motions in Limine

Joint case management statements must be filed 7 days before initial CMC; updated joint statements 7 days before subsequent CMCs. Pro se litigants may file separate statements.

Joint case management statements are required and must be filed seven days in advance of the initial case management conference date. Updated joint case management statements are required and must be filed seven days in advance of all other case management conferences. In cases involving litigants unrepresented by counsel, the parties may file separate case management statements.

Civil cases

Page 3 | Case Management Conference

The proposed order should be submitted at the same time as the motion or opposition,

The proposed order should be submitted at the same time as the motion or opposition,

Civil cases

Page 3 | Proposed Orders Required

Joint letter briefs for confidentiality designations must be filed within 21 days of challenge or 14 days after agreeing meet and confer won't work; failure waives the confidentiality designation.

The parties may file a joint letter brief regarding retaining confidentiality within 21 days of the initial notice of challenge or within 14 days of the parties agreeing that the meet and confer process will not resolve their dispute, whichever is earlier. Failure by a Designating Party to file such discovery dispute letter within the applicable 21- or 14-day period (set forth above) with the Court shall automatically waive the confidentiality designation for each challenged designation.

Civil cases

Page 4 | Discovery Disputes (c)

Cross-motions for summary judgment limited to 25 pages and must be filed 14 days after the motion.

Any cross-motion for summary judgment shall be contained within the opposition to any motion for summary judgment, shall contain twenty- five (25) pages or less, and shall be filed fourteen (14) days after the filing of the motion.

Civil cases

Page 8 | Cross-Motions

Service and Proof of Service Rules

A transcript of each audio or video recording intended for trial must be delivered to opposing counsel 28 days in advance and discussed during meet and confer.

A written transcript of all audio or video recordings to be used at trial must be delivered to opposing counsel twenty-eight (28) days in advance, and discussed during the meet and confer process.

Civil cases

Page 9 | 6. EXHIBITS

At least 28 days before the Pretrial Conference, parties must exchange one trial-ready set of proposed exhibits and related materials, along with a complete exhibit list.

At least twenty-eight (28) days before the Pretrial Conference, the parties shall exchange with every other party one set of all proposed exhibits, charts, schedules, summaries, diagrams, recordings, and other similar documentary materials *in the form to be used at trial*, together with a complete list of all such proposed exhibits.

Civil cases

Page 9 | 6. EXHIBITS

In non-jury cases, each party must serve and lodge proposed findings of fact and conclusions of law on all material issues 14 days before the Pretrial Conference.

In non-jury cases, each party shall serve and lodge with the Court **fourteen (14) days** prior to the Pretrial Conference, proposed Findings of Fact and Conclusions of Law on all material issues.

Civil cases

Page 10 | 7. NON-JURY TRIALS

The filing party must serve all documents sought to be sealed on all parties and any designating third party whose confidential information is included.

The filing party shall serve all documents to be sealed upon all parties and on any designating third party whose confidential information is included.

Page 10 | 12. Motions to Seal—Service and Opportunity for Dedesignation

The plaintiff, or a removing defendant in a removed action, must promptly serve the specified orders on all parties, including subsequently joined parties, and file a certificate of service.

Plaintiff (or in the case of removed actions, any removing defendant) is directed to serve copies of this Standing Order in Civil Cases and the CAND CMC Order at once upon all parties to their action, and upon those subsequently joined, in accordance with the provisions of Federal Rules of Civil Procedure, Rules 4 and 5, and to file with the Clerk of the Court a certificate reflecting such service, in accordance with Civil Local Rule 5-6(a).

Page 13 | 16. Service of Standing Orders

Demonstrative exhibits must be provided to opposing parties and the Court at least 24 hours before hearing, with printed copies brought to the hearing.

if a party intends to use demonstrative exhibits (including PowerPoint presentation), it shall provide a copy to opposing parties and the Court no fewer than 24 hours in advance of the hearing and bring printed copies of the demonstrative(s) to the hearing.

Civil cases

Page 2 | Scheduling days

Upon filing, the moving party shall provide the separate statement to all other parties in an electronic, word-processing format for ease of response thereto.

Upon filing, the moving party shall provide the separate statement to all other parties in an electronic, word-processing format for ease of response thereto.

Civil cases

Page 6 | Motions for Summary Judgment

Filing party must serve all documents to be sealed on all parties and any designating third party whose confidential information is included in the documents.

d. Service and Opportunity for Dedesignation i. The filing party shall serve all documents to be sealed upon all parties and on any designating third party whose confidential information is included.

Civil cases

Page 10 | Procedures for Filing Under Seal / Service and Opportunity for Dedesignation

Plaintiff (or in the case of removed actions, any removing defendant) is directed to serve copies of this Standing Order in Civil Cases and the CAND CMC Order at once upon all parties to their action, and upon those subsequently joined, in accordance with the provisions of Federal Rules of Civil Procedure, Rules 4 and 5, and to file with the Clerk of the Court a certificate reflecting such service, in accordance with Civil Local Rule 5-6(a).

Plaintiff (or in the case of removed actions, any removing defendant) is directed to serve copies of this Standing Order in Civil Cases and the CAND CMC Order at once upon all parties to their action, and upon those subsequently joined, in accordance with the provisions of Federal Rules of Civil Procedure, Rules 4 and 5, and to file with the Clerk of the Court a certificate reflecting such service, in accordance with Civil Local Rule 5-6(a).

Civil cases

Page 14 | Service of Standing Orders

By joint agreement, parties may exchange only a complete list identifying the proposed exhibits by Bates label or other identification instead of the documents themselves.

By joint agreement only, the parties may exchange the above-referenced documents by providing only a complete list of proposed exhibits through reference to bates labels or other identification.

Civil cases

Page 9 | 6. EXHIBITS

Courtesy Copy Requirements

The parties must file each listed document and deliver two copies of the joint trial readiness binder to chambers.

The parties shall file each of the documents listed below and deliver to chambers two copies of a JOINT TRIAL READINESS BINDER.

Civil cases

Page 3 | 3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON

The parties must provide two copies of any revised or updated trial documents for insertion into the Court's binders.

It is the responsibility of the parties to provide two copies of revised or updated trial documents to insert into the Court's Trial Readiness Binders.

Civil cases

Page 3 | 3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON

The parties must provide the Court a copy or representative samples of exhibits requiring discussion at the Pretrial Conference.

The parties shall also provide the Court with a copy of any exhibit or representative samples of any exhibits which require discussion at the Pretrial Conference.

Civil cases

Page 4 | 3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON

The binder must include the motions and oppositions with ECF headers showing each item’s docket number and filing date.

The binder shall include copies of the motions and oppositions with the ECF header reflecting the item's docket number and filing date.

Civil cases

Page 8 | 4. MOTIONS IN LIMINE

Chambers copies must be provided in a separate binder titled “MOTIONS IN LIMINE,” with opposition papers collated after the motion papers.

Chambers copies shall be provided in a separate binder entitled MOTIONS IN LIMINE and collated with the opposition papers following the motion papers.

Civil cases

Page 8 | 4. MOTIONS IN LIMINE

The motions-in-limine binder must be delivered with the Pretrial Conference binders.

Said binder shall be delivered with the Pretrial Conference binders.

Civil cases

Page 8 | 4. MOTIONS IN LIMINE

When the exhibits total no more than seven binder volumes, the parties must follow the specified binder-set delivery requirements.

In cases where the totality of the exhibits do not exceed seven (7) volumes of binders, the parties shall deliver:

Civil cases

Page 9 | 6. EXHIBITS

Unless the Court orders otherwise, parties must provide the Court with a final exhibit set on the Friday before trial.

Unless otherwise ordered, a final set of exhibits shall be provided to the Court on the **Friday prior to the trial date**.

Civil cases

Page 9 | 6. EXHIBITS

For exhibit sets totaling no more than seven binder volumes, the Court must receive marked, tabbed, indexed binders labeled with the party and exhibit-number range; a copy of a witness binder is sufficient if that format is used.

A set for the Court which shall be provided in binders, marked, tabbed, and indexed. The side label of the binders shall include the party designation and identify the exhibit number range. However, if a party prefers to use witness binders, a copy of the witness binder for the Court is sufficient.

Civil cases

Page 9 | 6. EXHIBITS

When the exhibits total more than seven binder volumes, the parties must follow the specified electronic and rolling-delivery requirements.

In cases where the totality of the exhibits exceeds seven (7) volumes of binders, the parties shall deliver:

Civil cases

Page 10 | 6. EXHIBITS

The parties shall use witness binders and provide the Court with its own copy on a rolling basis during trial.

The parties shall use witness binders and provide the Court with its own copy on a rolling basis during trial.

Civil cases

Page 10 | 6. EXHIBITS

Exhibit sets must be delivered to Chambers in coordination with the Courtroom Deputy.

Exhibits sets shall be delivered to Chambers in coordination with the Courtroom Deputy.

Civil cases

Page 10 | 6. EXHIBITS

Chambers copies required for motions over 15 pages, due by noon second business day after filing.

Chambers copy of all motions in excess of 15 pages, inclusive of exhibits and attachments, whether electronically filed or manually filed at the Clerk’s Office, shall be submitted to the Clerk’s Office in an envelope clearly marked with the case number and “YGR Chambers Copy” for receipt by no later than 12:00 noon the second business day after the document is filed.

Civil cases

A party using audio-visual demonstratives must provide them to opposing parties and the Court at least 24 hours before the hearing and bring printed copies to the hearing.

If a party intends to use audio-visual demonstratives during a hearing (e.g., PowerPoint presentation), it shall provide a copy to opposing parties and the Court no fewer than 24 hours in advance of the hearing and bring printed copies of the demonstrative(s) to the hearing.

Page 2 | 2. Scheduling days

For filings over 15 pages including exhibits and attachments, a chambers copy must be delivered to the Clerk’s Office in a marked envelope by noon on the second business day after filing; overnight delivery is sufficient.

Chambers copy of all filings in excess of 15 pages, inclusive of exhibits and attachments, whether electronically filed or manually filed at the Clerk’s Office, shall be submitted to the Clerk’s Office in an envelope clearly marked with the case number and “YGR Chambers Copy” for receipt by no later than 12:00 noon the second business day after the document is filed. Submission by overnight delivery such as Federal Express or UPS is sufficient.

Page 2 | 5. Chambers Copies

Filing parties must provide chambers copies of summary judgment motions and oppositions in tabbed three-ring binders.

Chambers copies of all summary judgment motions and oppositions (including the brief, separate statement, declarations, exhibits, and other supporting documents) are required to be provided by the filing party in a 3-ring binder or binders with tabs separating documents.

Page 3 | 5. Chambers Copies

Chambers copies of all filed documents must be delivered to the Clerk's Office by noon on the second business day after filing.

Unless otherwise specifically ordered, a chambers copy of all documents filed, whether electronically filed or manually filed at the Clerk's Office, shall be submitted to the Clerk's Office in an envelope clearly marked with the case number and "YGR Chambers Copy" for receipt no later than 12 noon the second business day after the document is filed.

Criminal cases

Page 1 | Chambers Copies of Motions and Trial-Related Filings

Chambers copies of motions over 15 pages (including exhibits/attachments) must be submitted to the Clerk’s Office by noon the second business day after filing, formatted for 3-ring binder with tabs, except for pro se litigants.

This requirement does not apply to self-represented litigants. Chambers copy of all motions in excess of 15 pages, inclusive of exhibits and attachments, whether electronically filed or manually filed at the Clerk’s Office, shall be submitted to the Clerk’s Office in an envelope clearly marked with the case number and “YGR Chambers Copy” for receipt by no later than 12:00 noon the second business day after the document is filed. Submission by overnight delivery such as Federal Express or UPS is sufficient. a. All chambers’ copies must be 3-hole punched in the left margin in a manner suitable for placement in a 3-ring binder. They shall not be stapled. b. Chambers copies must include tabs between exhibits and must fasten or attach pages of individual documents together so as to distinguish between separate documents. Do not use bottom tabs as they do not work well in binders.

Civil cases

Page 2 | Chambers Copies

with a courtesy copy emailed to ygrpo@cand.uscourts.gov.

with a courtesy copy emailed to ygrpo@cand.uscourts.gov.

Civil cases

Page 3 | Proposed Orders Required

Filing party must provide an electronic copy of sealed material on a USB or flash drive to the Court.

c. Chambers Copies i. The filing party shall provide the Court with electronic copies (on a USB or flash-drive) that contains the sealed material.

Civil cases

Page 10 | Procedures for Filing Under Seal / Chambers Copies

Parties must provide the Court with electronic copies of all sealed material on a USB or flash-drive.

The parties shall provide the Court with electronic copies (on a USB or flash-drive) that contain all sealed material.

Civil cases

Page 13 | Sealing Procedure

If a bench trial, a second set for Court staff may also be required and shall also be in binders, marked, tabbed, and indexed.

If a bench trial, a second set for Court staff may also be required and shall also be in binders, marked, tabbed, and indexed.

Civil cases

Page 9 | 6. EXHIBITS

Chambers copies not meeting requirements may be rejected and require re-submission.

Chambers copies submitted without meeting the above requirements may be rejected, and the party may be required to re-submit.

Civil cases

The proposed order should be submitted at the same time as the motion or opposition, with a courtesy copy emailed to ygrpo@cand.uscourts.gov.

The proposed order should be submitted at the same time as the motion or opposition, with a courtesy copy emailed to ygrpo@cand.uscourts.gov.

Page 3 | 7. Proposed Orders Required

Sealing & Redaction Procedures

File primary motion/brief as separate docket entry before sealing.

Procedures for Filing Under Seal: If a party seeks to file a document under seal the filing party shall: a. File the primary motion, brief, or other docket item (the “Primary Entry”) as its own docket entry, per normal filing procedures.

Civil cases

Page 9 | Procedures for Filing Under Seal

File temporary sealing motion with all attachments when requesting seal.

b. If requesting that the Primary Entry or any attachment be sealed, do not include any attachments to the Primary Entry. 1 Immediately file a motion to file under seal using the event “Administrative Motion to File Under Seal” event (“Temporary Sealing Motion”).

Civil cases

Page 9 | Procedures for Filing Under Seal

Sealing procedures apply to complex cases/motions with considerable sealed material.

12. Motions to Seal. Parties shall adhere to the below sealing procedures for complex cases/motions where considerable material is being filed under seal. The Court will advise parties if such procedures should be followed, although they may also raise the applicability of the below procedures with the Court in the first instance.

Civil cases

Page 9 | Motions to Seal

Designating parties have 10 days to respond to sealing designations.

ii. Within 10 calendar days of receiving service, each designating party or third party shall communicate with the filing party regarding the sealing designations made.

Civil cases

Page 10 | Service and Opportunity for Dedesignation

File omnibus sealing stipulation within 14 days after briefing concludes.

Post-Briefing Omnibus Sealing Procedures a. Within 14 calendar days following the conclusion of briefing on the motion or other filing 2 for which the sealing requests were made, the parties shall file, after the filing and designating parties meet and confer regarding the proposed sealing and redactions:

Civil cases

Page 10 | Post-Briefing Omnibus Sealing Procedures

Serve all sealed documents to parties and third parties with confidential info.

c. Service and Opportunity for Dedesignation i. The filing party shall serve all documents to be sealed upon all parties and on any designating third party whose confidential information is included.

Civil cases

Page 10 | Service and Opportunity for Dedesignation

For administrative motions to seal, provide chambers copies of unredacted documents with proposed redactions highlighted; do not submit redacted versions.

Chambers copies in administrative motions to seal: As noted in paragraph 11 below, parties shall provide chambers copies of the unredacted documents with proposed redacted material highlighted only. Parties shall not submit chambers copies of the redacted versions of documents they seek to seal.

Civil cases

For administrative motions to seal, provide chambers with unredacted documents showing proposed redactions highlighted.

For documents submitted in connection with administrative motions to seal, parties shall provide chambers copies of the unredacted documents with proposed redacted material highlighted, as required Civil Local Rule 79-5(d)(1)(D), only. Do not submit chambers copies of the redacted versions of documents sought to be sealed.

Civil cases

Page 3 | Miscellaneous

For administrative motions to seal, parties must provide chambers copies of unredacted documents with only the proposed redacted material highlighted.

As noted in paragraph 11 below, parties shall provide chambers copies of the unredacted documents with proposed redacted material highlighted only.

Page 3 | 5. Chambers Copies

File the primary item as a separate docket entry; include attachments if nothing is sought to be sealed, but if sealing is requested, omit attachments and immediately file a separate Temporary Sealing Motion.

If a party seeks to file a document under seal the filing party shall: a. File the primary motion, brief, or other docket item (the “Primary Entry”) as its own docket entry, per normal filing procedures. i. If a party does not seek to seal anything in association with the Primary Entry, include all attachments to the primary item as usual. b. If requesting that the Primary Entry or any attachment be sealed, do not include any attachments to the Primary Entry. 1 Immediately file a motion to file under seal using the event “Administrative Motion to File Under Seal” event (“Temporary Sealing Motion”).

Page 9 | 12. Motions to Seal

A Temporary Sealing Motion must attach all items associated with the Primary Entry, state that sealing reasons will be addressed in a forthcoming omnibus motion, and include a chart identifying each attachment and whose confidential information it contains.

The Temporary Sealing Motion shall include as attachments all items associated with the Primary Entry. The Temporary Sealing Motion shall: 1. State that the reasons for sealing will be addressed in a forthcoming omnibus motion. 2. Include a chart: a. Identifying each attachment by docket number and content. (e.g., Dkt. No. 101-3, Exhibit A to Motion for Relief, Sealed). b. Whether each contains the filing party’s confidential information or another party’s confidential information.

Page 9 | 12. Motions to Seal

If a designating party believes a document can be filed with redactions or fewer redactions, it must provide a redacted version to the filing party, who must provide it to the Court under the post-briefing procedures.

If the designating party believes a document may be filed with redactions (rather than entirely under seal) or with fewer redactions, the designating party shall provide the filing party with a redacted version of the document for filing. The filing party will then be responsible for providing the document to the Court in accordance with the Post-Briefing Omnibus Sealing Procedures.

Page 10 | 12. Motions to Seal—Service and Opportunity for Dedesignation

The parties must file an omnibus sealing stipulation addressing all documents and portions sought to be sealed, with a chart identifying each document by a consistent identifier and its sealed docket entry or entries.

Omnibus Sealing Stipulation: Parties shall file an omnibus sealing stipulation addressing all documents and portions of documents sought to be sealed in connection with the underlying motion or other court filing. The omnibus sealing stipulation shall include: 1. A chart listing all documents requested to be seal. The chart shall identify: a. each document by a consistent identifier (e.g., Bates number) as well as by the docket entry(ies) at which it has been filed under seal;

Page 10 | Post-Briefing Omnibus Sealing Procedures

If the designating party determines a document is not entitled to protection, it must provide the filing party a version with confidentiality designations removed for filing.

If the designating party determines that the document is not entitled to protection, the designating party shall provide the filing party with a version of the document with the confidentiality designations removed for filing.

Page 10 | 12. Motions to Seal—Service and Opportunity for Dedesignation

Court inclined to seal PII/PHI; filing under seal requires redacted primary entry, Temporary Sealing Motion with attachments, and no additional docket entry for entirely sealed documents.

As a general matter, the parties are advised that the Court is not inclined to seal competitively sensitive information that is more than three years old, but it is inclined to seal personally identifiable information (“PII”) or protected health information (“PHI”). 12.1 Procedures for Filing Under Seal: If a party seeks to file a document under seal, the filing party shall: a. File the primary motion, brief, or other docket item (the “Primary Entry”) as its own docket entry, per normal filing procedures. b. If requesting that the Primary Entry or any attachment be sealed, do not include any attachments to the Primary Entry. For example, if a party wishes to redact confidential material included in its brief, the party must file the redacted version of the brief as the Primary Entry. Do not include exhibits or attachments to that entry. To file the sealed brief, exhibits, or attachments, next immediately file a motion to file under seal using the event “Administrative Motion to File Under Seal” event (“Temporary Sealing Motion”). i. The Temporary Sealing Motion shall include as attachments all items associated with the Primary Entry. Note that if, like Ex. C above, a document is filed entirely under seal, there is no need to file an additional docket entry with a cover page indicating that it has been filed under seal, as under the standard procedures.

Civil cases

Page 9 | Motions to Seal / Procedures for Filing Under Seal

Parties must not submit chambers copies of the redacted versions of documents they seek to seal.

Parties shall not submit chambers copies of the redacted versions of documents they seek to seal.

Page 3 | 5. Chambers Copies

The sealing procedures apply to complex cases or motions involving considerable sealed material when the Court advises they should be followed, and parties may raise their applicability with the Court.

Parties shall adhere to the below sealing procedures for complex cases/motions where considerable material is being filed under seal. The Court will advise parties if such procedures should be followed, although they may also raise the applicability of the below procedures with the Court in the first instance.

Page 9 | 12. Motions to Seal

Parties must consistently use the same identifier when referring to a confidential document produced by a party or third party.

For ease of reference, the parties shall consistently use the same identifier (e.g., Bates number) when referring to a given document produced by a party or third party containing confidential information.

Page 10 | 12. Motions to Seal

A designating party that agrees with provisional sealing need take no action until the post-briefing omnibus sealing procedures.

If the designating party agrees with the proposed provisional sealing, no action is needed until the omnibus sealing procedures described in the Post-Briefing Omnibus Sealing Procedures.

Page 10 | 12. Motions to Seal—Service and Opportunity for Dedesignation

A document filed entirely under seal does not require an additional docket entry with a cover page identifying it as sealed.

Note that if, like Ex. C above, a document is filed entirely under seal, there is no need to file an additional docket entry with a cover page indicating that it has been filed under seal, as under the standard procedures.

Page 10 | 12. Motions to Seal

For administrative motions to seal, unredacted chambers copies must have proposed redactions highlighted; redacted versions do not require chambers copies.

Chambers copies in administrative motions to seal: As noted in paragraph 11 below, parties shall provide chambers copies of the unredacted documents with proposed redacted material highlighted only. Parties shall not submit chambers copies of the redacted versions of documents they seek to seal.

Civil cases

Page 3 | Chambers Copies (d)

Sealing procedures require meet and confer within 7 calendar days of briefing conclusion; one omnibus stipulation/motion covers all Daubert motions and cross-motions; parties (not Clerk) file improperly sealed documents on public docket after stipulation; agreed PHI/PII need not be in sealing chart or proposed order.

Within 7 calendar days following the conclusion of briefing on the motion or other filing for which the sealing requests were made, the parties shall meet and confer regarding the proposed sealing and redactions. All Daubert motions shall be treated as one motion for purposes of this section. This means that though there may be numerous Daubert motions, parties shall file one Omnibus Sealing Stipulation and one set of Omnibus Sealing Motions, as described in this section. Similarly, cross-motions shall be treated as one motion. If the parties agree that a document was improperly sealed, or that redactions should be modified, the parties (and not the Clerk of Court) shall file those documents on the public docket after filing the omnibus sealing stipulation. To the extent the parties agree that information constitutes PHI or PII, the parties need not include this information in the sealing chart or proposed order.

Civil cases

Page 11 | Sealing

Filing Bundling Requirements

Additional instructions must be labeled supplemental; competing supplemental instructions must be filed jointly and their placement in the sequence identified.

(E) If the parties wish to propose additional instructions, they must be clearly identified as “supplemental” instructions. Competing supplemental instructions must be filed jointly such that the Court can readily compare and contrast the same. The parties must identify where in the sequence of previously submitted instructions the supplemental instructions should be added.

Civil cases

Page 5 | i. Meet and Confer.

The parties must meet and confer, prepare one joint set of jury instructions in the stated sequence, and provide authority for every instruction.

(A) The parties shall meet and confer and prepare one Joint Set of Jury Instructions provided to the Court in the logical sequence to be read to the jury AFTER the close of evidence. Authority shall be provided for all instructions.

Civil cases

Page 5 | i. Meet and Confer.

Summary judgment motions and oppositions must be provided in 3-ring binders with tabs; reply documents optional; habeas corpus and ERISA/Social Security cases exempt.

summary judgment motions and oppositions (including the brief, separate statement, declarations, exhibits, and other supporting documents) are required to be provided by the filing party in a 3-ring binder or binders with tabs separating documents. Submitting chambers copies of the reply documents in a binder is optional. This requirement does not apply to habeas corpus petitions or summary judgment motions in ERISA or Social Security cases.

Civil cases

The parties may not file multiple joint letter briefs, regardless of the number of disputes at issue.

The parties may not file multiple joint letter briefs irrespective of the number of disputes then at-issue.

Page 4 | 8. Discovery and Discovery Motions

Pre-Motion Conference Requirements

Before submitting the Exhibit List, the parties must meet and confer and attempt to stipulate to the admissibility of each exhibit.

Prior to submitting the list, the parties shall meet and confer and attempt to stipulate as to the admissibility of each exhibit.

Civil cases

Page 4 | 3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON

The parties must meet and confer and agree on numeric exhibit designations.

Parties shall meet and confer and agree on numeric designations for exhibits, such as plaintiffs shall have numbers 1-99, defendant one: numbers 100-199, defendant two: numbers 200-299, etc.

Civil cases

Page 4 | 3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON

Before submitting the list, the parties must meet and confer and attempt to resolve disagreements about designations or counter-designations.

Prior to submitting the list, the parties shall meet and confer and attempt to resolve any disagreements regarding designations or counter-designations.

Civil cases

Page 4 | 3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON

Pretrial motions other than motions in limine are unauthorized and will be stricken.

No other pretrial motions are authorized and will be stricken as procedurally improper.

Civil cases

Page 8 | 4. MOTIONS IN LIMINE

Reply papers on motions in limine are not permitted.

Reply papers are not permitted.

Civil cases

Page 8 | 4. MOTIONS IN LIMINE

Pre-filing conferences must be attended in person; remote appearances not permitted.

All pre-filing conferences are held in person and appearances via telephone and videoconference will not be allowed.

Civil cases

Opposition parties must respond to pre-filing letter within 3 business days.

Within three (3) business days after receipt of the letter, any party who will oppose the motion must file a written response addressing the substance of the moving party’s letter, with a copy to Chambers.

Civil cases

Pre-filing letter must be submitted 7 business days before proposed conference date.

The moving party’s letter shall be submitted at least seven (7) business days prior to the proposed conference date and must explain the grounds for the motion.

Civil cases

Pre-filing conference required before summary judgment motions.

The moving party must file a letter, with a copy to Chambers and the opposing parties, to request a pre-filing conference, and propose a date and time for such conference.

Civil cases

Discovery dispute motions require prior leave of Court unless specifically exempted.

Except as specifically set forth below, no motions regarding discovery disputes may be filed without prior leave of Court.

Civil cases

Only one summary judgment motion allowed per side without court leave.

Only one summary judgment motion may be filed collectively per side, absent leave of court.

Civil cases

Request for more than 10 claim terms must show good cause and be filed 2 weeks before joint statement deadline

If a party genuinely believes that it will require that more than ten terms be construed, that party may request leave to designate additional terms for construction, pursuant to Civil Local Rule 7-11(b). The requesting party must demonstrate good cause and explain why other methods of limiting the claims at issue (such as the selection of representative claims or any grouping of claims by issues presented) would be ineffective. The request must be filed no later than two weeks before the deadline for filing the joint claim construction statement.

Civil cases

Page 1 | Claim Construction

Except where the standing order provides otherwise, discovery-dispute motions may not be filed without prior court leave.

Except as specifically set forth below, no motions regarding discovery disputes may be filed without prior leave of Court.

Page 4 | 8. Discovery and Discovery Motions

Except for the stated exceptions, a Rule 56 motion requires prior court leave, requested through a letter to Chambers and opposing parties that proposes a conference date and time.

Except as specifically set forth below, no motion for summary judgment pursuant to Rule 56 of the Rules of Civil Procedure may be filed without prior leave of Court. The moving party must file a letter, with a copy to Chambers and the opposing parties, to request a pre-filing conference, and propose a date and time for such conference.

Page 5 | 9. Motions for Summary Judgment

The moving party’s letter is due at least seven business days before the proposed conference and is limited to three single-spaced pages; an opposing party must respond within three business days after receipt, also within three single-spaced pages.

The moving party’s letter shall be submitted at least seven (7) business days prior to the proposed conference date and must explain the grounds for the motion. The letter shall be no more than three single-spaced pages in length, including any attached exhibits or other supporting papers. Within three (3) business days after receipt of the letter, any party who will oppose the motion must file a written response addressing the substance of the moving party’s letter, with a copy to Chambers and the moving party. This response shall also be limited to three single-spaced pages, including any attached exhibits or supporting papers.

Page 5 | 9. Motions for Summary Judgment

Only one summary judgment motion may be filed collectively per side unless the Court grants leave; a side with multiple parties may request leave, an issue addressed at the pre-filing conference.

Only one summary judgment motion may be filed collectively per side, absent leave of court. Leave of court to file more than one motion may be requested if multiple parties comprise one or both sides. This issue will be addressed at the Pre-filing Conference.

Page 6 | 9. Motions for Summary Judgment

Without a stipulation, motions must be filed 21 days before hearing, oppositions 14 days before, and replies 7 days before.

In the absence of a stipulation, motions (except those pertaining to sentencing) shall be filed at least twenty-one (21) days in advance of the hearing date. Opposition briefs shall be filed at least fourteen (14) days in advance of the hearing date. Reply briefs shall be filed at least seven (7) days in advance of the hearing date.

Criminal cases

Page 1 | Motions

Reply briefs are not permitted for motions in limine.

No reply briefs shall be considered.

Criminal cases

Page 2 | Pre-trial Motions in Limine

Joint discovery letter briefs must include meet and confer attestation, summarize unresolved issues; no multiple letters, limited legal authority, no declarations, may attach excerpts.

In the joint letter brief, counsel must attest that, prior to filing the request for relief, counsel met and conferred in person or by videoconference, and then concisely summarize all remaining issues that counsel were unable to resolve. The parties may not file multiple joint letter briefs irrespective of the number of disputes then at-issue. If there are multiple disputes at issue, the parties may provide a list of disputes as part of their joint letter brief. The joint letter brief may cite to limited and specific legal authority only for resolution of dispositive issues. The joint letter brief may not be accompanied by declarations; however any specific excerpt of disputed discovery material may be attached.

Civil cases

Page 4 | Discovery Disputes (b)

Prior leave of court is required before filing any discovery dispute motion, except as provided in subsequent subsections.

Except as specifically set forth below, no motions regarding discovery disputes may be filed without prior leave of Court.

Civil cases

Page 4 | Discovery Disputes

Before seeking leave for additional pages, parties must meet and confer and file a single omnibus motion including all requests.

Before seeking leave for additional pages, a party must meet and confer with all other moving parties and file an omnibus motion that includes all requests. That is, there shall be only one motion and one docket entry regarding requests for additional pages.

Civil cases

Page 13 | Sealing Procedure

The court reporter recording the deposition must attend any such telephone conference.

Any such conference shall be attended by the court reporter recording the deposition.

Page 4 | 8. Discovery and Discovery Motions

Pre-filing conferences are normally set for Wednesday or Friday afternoons at 2:00 p.m. unless circumstances and the Court’s calendar require otherwise, and should be requested sufficiently in advance of the deadlines established in the Court’s initial case management order. All pre-filing conferences are held in person and appearances via telephone and videoconference will not be allowed.

Pre-filing conferences are normally set for Wednesday or Friday afternoons at 2:00 p.m. unless circumstances and the Court’s calendar require otherwise, and should be requested sufficiently in advance of the deadlines established in the Court’s initial case management order. All pre-filing conferences are held in person and appearances via telephone and videoconference will not be allowed.

Page 5 | 9. Motions for Summary Judgment

The Rule 56 pre-filing requirement does not apply when either side has a self-represented party, or to habeas petitions or motions in Social Security appeals.

This pre-filing requirement does not apply to either side in cases where one party is self-represented. This pre-filing requirement also does not apply to habeas corpus petitions or motions in Social Security appeals.

Page 6 | 9. Motions for Summary Judgment

Adjournment & Extension Requirements

ADA claims must follow General Order 56 deadlines; extensions require 1-week advance notice and good cause.

General Order 56 sets forth various deadlines that parties must adhere to in prosecuting claims pursuant to the ADA. Failure to comply with those deadlines may result in sanctions, including dismissals for failure to prosecute. Any extensions of General Order 56's deadlines must be sought no later than one week in advance of the deadline and must be supported by a concrete and particularized showing of good cause.

Civil cases

Page 13 | ADA Litigation

Changes to the Court’s schedule require a signed court order and a showing of good cause.

No changes to the Court’s schedule shall be made except by signed order of the Court and only upon a showing of good cause.

Page 2 | 3. Changes to Court Calendar

A briefing schedule may be changed only with Court approval.

Briefing schedules may not be changed without Court approval.

Page 2 | 3. Changes to Court Calendar

A continuance requires good cause, with particular attention to the requesting party’s diligence and potential prejudice if the request is denied.

Continuances will be granted only upon a showing of good cause, particularly focusing on evidence of diligence by the party seeking delay and of prejudice that may result if the continuance is denied.

Page 2 | 3. Changes to Court Calendar

An extension of a General Order 56 deadline must be requested at least one week before the deadline and supported by a concrete, particularized showing of good cause.

Any extensions of General Order 56’s deadlines must be sought no later than one week in advance of the deadline and must be supported by a concrete and particularized showing of good cause.

Page 13 | 20. ADA Litigation

Continuances, extensions, or schedule changes require good cause, signed stipulation + proposed order or Motion for Administrative Relief; motions to enlarge deadlines must be filed before the deadline, and requests without 2 weeks between last brief and hearing are likely denied.

No changes to the Court’s schedule shall be made except by signed order of the Court and only upon a showing of good cause. Parties seeking to continue hearings, request special status conferences, modify briefing schedules, or make any other procedural changes shall submit a signed stipulation and proposed order, or, if a stipulation is not possible, a Motion for Administrative Relief as contemplated by Civil Local Rule 7-11. Continuances will be granted only upon a showing of good cause, particularly focusing on evidence of diligence by the party seeking delay and of prejudice that may result if the continuance is denied. Briefing schedules may not be changed without Court approval. The Court generally will not approve elongated briefing schedules without sufficient explanation. Parties seeking to enlarge a filing deadline by way of a Motion for Administrative Relief are admonished to file such a motion in advance of the filing deadline, with sufficient time for the Court to respond (not on the day the filing is due or immediately prior). Parties are advised that requests which, in effect, do not allow the Court two weeks from the filing of the last brief until the scheduled hearing date are likely to be denied. Requests to accommodate remote appearances for compliance deadlines will be summarily denied. All compliance deadlines are decided on the papers unless otherwise stated by the Court.

Civil cases

Page 2 | Changes to Court Calendar

Parties may stipulate to extend time to file Omnibus Stipulation and Motion to 21 days after briefing concludes; extensions beyond 21 days require court approval.

The parties may, by stipulation filed on the docket, extend the time to file the Omnibus Stipulation and Omnibus Motion to 21 days after the conclusion of briefing. Extensions beyond 21 days must be approved by the Court.

Civil cases

Page 13 | Sealing Procedure

ADA litigation deadline extensions must be sought one week in advance with a showing of good cause.

Any extensions of General Order 56's deadlines must be sought no later than one week in advance of the deadline and must be supported by a concrete and particularized showing of good cause.

Civil cases

Page 15 | ADA Litigation

A Motion for Administrative Relief seeking more time to file should be filed sufficiently before the deadline for the Court to respond, not on the due date or immediately before it.

Parties seeking to enlarge a filing deadline by way of a Motion for Administrative Relief are admonished to file such a motion in advance of the filing deadline, with sufficient time for the Court to respond (not on the day the filing is due or immediately prior).

Page 2 | 3. Changes to Court Calendar

Requests that leave fewer than two weeks between the last brief and the hearing are likely to be denied.

Parties are advised that requests which, in effect, do not allow the Court two weeks from the filing of the last brief until the scheduled hearing date are likely to be denied.

Page 2 | 3. Changes to Court Calendar

The Court may reschedule the hearing on its own or on a Civil L.R. 6-3 motion to allow the moving party time to reply to a cross-motion.

The Court may, sua sponte or pursuant to a motion under Civil L.R. 6-3, reschedule the hearing so as to give a moving party time to file a reply to any cross-motion.

Page 8 | Cross-Motions

Chambers Communication Rules

No direct contact with judge or chambers staff; contact Courtroom Deputy instead.

Parties shall not contact Judge Gonzalez Rogers or her chambers staff directly by telephone, email, or any other ex parte means, but may contact the Courtroom Deputy at (510) 637-3540 with appropriate inquiries with counsel for all parties

Civil cases

Page 12 | Communication with Court

The redline comparison must be emailed to the specified address when the amended complaint or motion for leave to amend is filed; self-represented parties are exempt.

In connection with all amended complaints and motions seeking leave to amend pleadings, parties shall submit a redline comparison with the operative pleading to ygrpo@cand.uscourts.gov upon filing of the amended complaint or motion seeking leave to amend. This requirement does not apply to self- represented parties.

Page 12 | 13. Amended Complaints and Motions for Leave to Amend

Counsel must notify the Court at least 30 days before trial if an interpreter is needed and no certified interpreter is available.

Counsel must notify the Court at least 30 days in advance of trial if any witness requires an interpreter and there is no certified court interpreter available to translate in the necessary language(s).

Criminal cases

Page 3 | Interpreters

If a dispute arises during a deposition and involves a persistent obstruction of the deposition or a refusal to answer a material question on the basis of any ground other than privilege or the work-product doctrine, counsel may arrange a telephonic conference with the Court by contacting the Courtroom Deputy, Aris Garcia, at (510) 637-3540. Any such conference shall be attended by the court reporter recording the deposition.

If a dispute arises during a deposition and involves a persistent obstruction of the deposition or a refusal to answer a material question on the basis of any ground other than privilege or the work-product doctrine, counsel may arrange a telephonic conference with the Court by contacting the Courtroom Deputy, Aris Garcia, at (510) 637-3540. Any such conference shall be attended by the court reporter recording the deposition.

Civil cases

Page 4 | Discovery Disputes (a)

Parties shall not contact Judge Gonzalez Rogers or her chambers staff directly by telephone, email, or any other ex parte means, but may contact the Courtroom Deputy at (510) 637-3540 with appropriate inquiries with counsel for all parties included on the communication. Parties should list their email address as well as their telephone numbers on their papers to facilitate communication with the Courtroom Deputy. All counsel listed on the parties’ briefing must be fully apprised of the status of the pending matter and must be authorized to respond to calendar settings by the Court.

Parties shall not contact Judge Gonzalez Rogers or her chambers staff directly by telephone, email, or any other ex parte means, but may contact the Courtroom Deputy at (510) 637-3540 with appropriate inquiries with counsel for all parties included on the communication. Parties should list their email address as well as their telephone numbers on their papers to facilitate communication with the Courtroom Deputy. All counsel listed on the parties’ briefing must be fully apprised of the status of the pending matter and must be authorized to respond to calendar settings by the Court.

Civil cases

Page 14 | Communication with Court

Counsel must notify the Court at least 30 days in advance of trial if any witness requires an interpreter and there is no certified court interpreter available to translate in the necessary language(s).

Counsel must notify the Court at least 30 days in advance of trial if any witness requires an interpreter and there is no certified court interpreter available to translate in the necessary language(s).

Criminal cases

Page 3 | Interpreters

Transcript requests must be arranged with Court Reporter Coordinator at least one week before trial.

If transcripts will be requested during or immediately after the trial, arrangements must be made with the Court Reporter Coordinator (Telephone No. 510-637-3534) at least one week prior to the commencement of the trial.

Criminal cases

Page 3 | Requests for Transcripts

Do not call Chambers.

Please **DO NOT** call Chambers.

Civil cases

Page 10 | 8. MISCELLANEOUS

Pro se litigants may register for ECF; non-compliance may result in revoked filing privileges.

While not required, pro se litigants may sign up to be registered ECF users. Failing to comply with filings requirements and the Civil Local Rules may result in ECF filing privileges being revoked.

Civil cases

Page 14 | Formatting Considerations

A party needing courtroom audio-visual equipment must arrange a test with the Courtroom Deputy at least one day before the hearing.

If a party requires use of audio-visual equipment in the courtroom, the party shall contact the Courtroom Deputy, Edwin Cuenco, to make an appointment to test that equipment on a date at least one day in advance of the hearing.

Page 2 | 2. Scheduling days

Litigants must not use the stated email address for substantive communications.

This email address should not be used by litigants for substantive communications.

Page 3 | 7. Proposed Orders Required

For persistent deposition obstruction or refusal to answer a material question on grounds other than privilege or work product, counsel may arrange a telephone conference with the Court by calling the Courtroom Deputy.

If a dispute arises during a deposition and involves a persistent obstruction of the deposition or a refusal to answer a material question on the basis of any ground other than privilege or the work-product doctrine, counsel may arrange a telephonic conference with the Court by contacting the Courtroom Deputy, Aris Garcia, at (510) 637-3540.

Page 4 | 8. Discovery and Discovery Motions

Parties must not contact the judge or chambers staff directly by ex parte means; they may contact the Courtroom Deputy with appropriate inquiries if counsel for all parties are included.

Parties shall not contact Judge Gonzalez Rogers or her chambers staff directly by telephone, email, or any other ex parte means, but may contact the Courtroom Deputy at (510) 637-3540 with appropriate inquiries with counsel for all parties included on the communication.

Page 13 | 15. Communication with Court

Transcript requests must be arranged with the Court Reporter Coordinator at least one week before trial.

If transcripts will be requested during or immediately after the trial, arrangements must be made with the Court Reporter Coordinator (Telephone No. 510-637-3534) at least one week prior to the commencement of the trial.

Criminal cases

Page 3 | Requests for Transcripts

Parties may arrange an appropriate equipment-testing time with the Courtroom Deputy by phone.

Arrangements may be made with the Courtroom Deputy, Edwin Cuenco, at (510) 637-3540 as to an appropriate time for doing so.

Civil cases

Page 10 | 8. MISCELLANEOUS

To contact the Courtroom Deputy, call the listed number and leave a message if the Deputy is unavailable.

If you need to contact the Courtroom Deputy, please call (510) 637-3540 and leave a message if the Courtroom Deputy is not available.

Civil cases

Page 10 | 8. MISCELLANEOUS

If a dispute arises during a deposition and involves a persistent obstruction of the deposition or a refusal to answer a material question on the basis of any ground other than privilege or the work-product doctrine, counsel may arrange a telephonic conference with the Court by contacting the Courtroom Deputy, Aris Garcia, at (510) 637-3540. Any such conference shall be attended by the court reporter recording the deposition.

If a dispute arises during a deposition and involves a persistent obstruction of the deposition or a refusal to answer a material question on the basis of any ground other than privilege or the work-product doctrine, counsel may arrange a telephonic conference with the Court by contacting the Courtroom Deputy, Aris Garcia, at (510) 637-3540. Any such conference shall be attended by the court reporter recording the deposition.

Civil cases

Tutorial scheduled 1-3 weeks before claim construction hearing, 45-60 minutes per side

The Court will schedule a tutorial to occur one to three weeks prior to the claim construction hearing. Each side will be permitted 45-60 minutes to present a short summary and explanation of the technology at issue.

Civil cases

Page 2 | Tutorial and Claim Construction Hearing

Parties needing courtroom AV equipment must contact the Courtroom Deputy at least one day in advance to schedule equipment testing.

If a party requires use of audio-visual equipment in the courtroom, the party shall contact the Courtroom Deputy, Edwin Cuenco, to make an appointment to test that equipment on a date at least one day in advance of the hearing.

Civil cases

Page 2 | Scheduling days

The ygrpo@cand.uscourts.gov email address may not be used for substantive communications.

This email address should not be used by litigants for substantive communications.

Civil cases

Page 3 | Proposed Orders Required

Junior Lawyer Participation Incentives

Junior lawyers (6 or fewer years out of law school) arguing motions increase likelihood of oral argument.

If a written request for oral argument is filed before issuance of a ruling stating that a lawyer six or fewer years out of law school will conduct all or most of the oral argument, the Court will entertain oral argument on the principle that young lawyers need more opportunities for appearances than they typically receive.

Civil cases

The Court will entertain oral argument when a timely written request states that a lawyer six or fewer years out of law school will conduct all or most of the argument.

In addition, if a written request for oral argument is filed before issuance of a ruling stating that a lawyer six or fewer years out of law school will conduct all or most of the oral argument, the Court will entertain oral argument on the principle that young lawyers need more opportunities for appearances than they typically receive.

Page 1 | 2. Scheduling days

Junior lawyers (6 or fewer years experience) who file a written oral argument request stating they will conduct all/most of the argument may have increased likelihood of oral argument being granted.

In addition, if a written request for oral argument is filed before issuance of a ruling stating that a lawyer six or fewer years out of law school will conduct all or most of the oral argument, the Court will entertain oral argument on the principle that young lawyers need more opportunities for appearances than they typically receive.

Civil cases

Page 1 | Scheduling days

About Chief United States District Judge Yvonne Gonzalez Rogers

District Judge Yvonne Gonzalez Rogers was appointed to the Northern District of California by President Barack Obama in 2011.

Judge Gonzalez Rogers was born in 1965 in Houston, Texas. She was nominated on May 4, 2011, confirmed by the Senate on November 15, 2011, and received her commission on November 21, 2011. Before her federal appointment, she served as a judge on the Alameda County Superior Court and spent over a decade in private practice in San Francisco.

Education

  • University of Texas School of Law, J.D., 1991
  • Princeton University, A.B., 1987

Career

  • Private practice, San Francisco (1991–2003)
  • Judge pro tem, Superior Court of California, Alameda County (2007–2008)
  • Judge, Superior Court of California, Alameda County (2008–2011)

Courthouse: Ronald V. Dellums Federal Building & United States Courthouse, 1301 Clay Street, Suite 400 S, Oakland, CA 94612 Chambers: Courtroom 1, 4th Floor Phone: (510) 637-3540

Chambers Staff

  • Courtroom Deputy/Calendar Clerk: ygrcrd@cand.uscourts.gov
Common questions about Judge Yvonne Gonzalez Rogers's rules

Are courtesy copies required for Judge Yvonne Gonzalez Rogers?

Courtesy-copy rule applies for motion in limines and oppositions. Details: delivery with bundled motion. Chambers copies must be provided in a separate binder titled “MOTIONS IN LIMINE,” with opposition papers collated after the motion papers.

View ruleSource: page 8, section 4. MOTIONS IN LIMINE

Does Judge Yvonne Gonzalez Rogers require a pre-motion conference or letter before filing a motion?

Reply papers on motions in limine are not permitted.

View ruleSource: page 8, section 4. MOTIONS IN LIMINE

What page or word limits apply to disputed excerpts before Judge Yvonne Gonzalez Rogers?

Judge Yvonne Gonzalez Rogers' rule states these limits: 6 pages. The Court will resolve no more than six pages of disputed excerpts in total, and the parties must provide sufficient information, including the deponent's identity and dispute context.

View ruleSource: page 4, section 3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON

What page or word limits apply to brief before Judge Yvonne Gonzalez Rogers?

Judge Yvonne Gonzalez Rogers' rule states these limits: 2 pages. Each side’s brief explanation may not exceed two double-spaced pages, but the Court may order additional briefing if necessary.

View ruleSource: page 5, section i. Meet and Confer.

What formatting rules apply to filings before Judge Yvonne Gonzalez Rogers?

Judge Yvonne Gonzalez Rogers' formatting rule includes present the information in chart format and organize it by party.. The witness information must be presented in chart format and organized by party.

View ruleSource: page 3, section 3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON

What must be included with proposed order filings before Judge Yvonne Gonzalez Rogers?

The parties must present the Court with a proposed order outlining their trial stipulations.

View ruleSource: page 3, section 3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON

What must be included with discovery audio video list filings before Judge Yvonne Gonzalez Rogers?

The parties must identify remaining legal objections on the list and attach copies of disputed excerpts or transcripts in a separate appendix for Court review.

View ruleSource: page 4, section 3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON

How may parties contact Judge Yvonne Gonzalez Rogers' chambers?

The rule lists phone (510) 637-3540. No direct contact with judge or chambers staff; contact Courtroom Deputy instead.

View ruleSource: page 12, section Communication with Court

How does Judge Yvonne Gonzalez Rogers handle sealed or redacted filings?

A motion to seal is required for covered sealed filings before Judge Yvonne Gonzalez Rogers. Sealing procedures apply to complex cases/motions with considerable sealed material.

View ruleSource: page 9, section Motions to Seal

How do I request an adjournment or extension before Judge Yvonne Gonzalez Rogers?

The request must include reason for request. ADA claims must follow General Order 56 deadlines; extensions require 1-week advance notice and good cause.

View ruleSource: page 13, section ADA Litigation

Does Judge Yvonne Gonzalez Rogers require motion papers to be bundled?

The parties must meet and confer, prepare one joint set of jury instructions in the stated sequence, and provide authority for every instruction.

View ruleSource: page 5, section i. Meet and Confer.

Is electronic filing required before Judge Yvonne Gonzalez Rogers?

Yes. Electronic filing is required for the covered filings. For exhibit sets exceeding seven binder volumes, parties must provide an electronic version of all documents.

View ruleSource: page 10, section 6. EXHIBITS

What filing deadlines does Judge Yvonne Gonzalez Rogers set?

The binder is due by noon at least seven days before the Pretrial Conference for cases to be tried in a week, or fourteen days before for all other cases.

View ruleSource: page 3, section 3. TRIAL READINESS FILINGS AND BINDER and PROPOSED ORDER THEREON

What rule applies to serving all parties before Judge Yvonne Gonzalez Rogers?

Details: recipient: all parties, timing: 28 calendar days before hearing. At least 28 days before the Pretrial Conference, parties must exchange one trial-ready set of proposed exhibits and related materials, along with a complete exhibit list.

View ruleSource: page 9, section 6. EXHIBITS

Does Judge Yvonne Gonzalez Rogers encourage junior lawyer participation?

Yes. Judge Yvonne Gonzalez Rogers's rules include a junior lawyer participation incentive. Junior lawyers (6 or fewer years out of law school) arguing motions increase likelihood of oral argument.

Complete rules summary for Judge Yvonne Gonzalez Rogers

Reply papers on motions in limine are not permitted.

Chambers copies must be provided in a separate binder titled “MOTIONS IN LIMINE,” with opposition papers collated after the motion papers.

By joint agreement, parties may exchange only a complete list identifying the proposed exhibits by Bates label or other identification instead of the documents themselves.

When the exhibits total more than seven binder volumes, the parties must follow the specified electronic and rolling-delivery requirements.

Motions in limine brought to re-litigate an issue will be denied as procedurally defective.

The parties must present the Court with a proposed order outlining their trial stipulations.

The parties should issue trial notices and witness subpoenas as necessary.

The parties must identify remaining legal objections on the list and attach copies of disputed excerpts or transcripts in a separate appendix for Court review.

The parties must prepare an index showing whether each instruction is stipulated or objected to and sequencing competing instructions for comparison.

Trial counsel must meet and confer at least 21 days before the Pretrial Conference.

The parties must file a joint Pretrial Conference Statement containing the information required by the order.

The binder is due by noon at least seven days before the Pretrial Conference for cases to be tried in a week, or fourteen days before for all other cases.

The joint trial readiness binders must include filed-document copies bearing the ECF header with each item's docket number and filing date.

The parties must file each listed document and deliver two copies of the joint trial readiness binder to chambers.

The parties must provide two copies of any revised or updated trial documents for insertion into the Court's binders.

The parties may provide updated indexes if an index was included with the original binders.

The Trial Readiness Binders must include a paper copy of the parties' Pretrial Conference Statement.

The witness list must identify likely trial witnesses, except those called solely for impeachment or rebuttal, and provide the specified testimony, examination-time, and presentation details for each.

The witness information must be presented in chart format and organized by party.

A witness omitted from the list will be excluded from testifying unless the Court orders otherwise.

The witness list must mark each witness as primary or included only as a precautionary measure, using an asterisk or other notation.

A party that needs to call a witness at trial must identify that witness in its own witness list.

The parties must either issue trial notices to witnesses controlled by the other party or stipulate to how those witnesses will be notified that they are being called.

The expert witness list must include all experts, a plain summary of each expert's theories, conclusions, and bases, and a curriculum vitae.

The parties must note the agreed exhibit designations for the Court.

A party may not rely on the opposing party's witness identification for its own case in chief.

If an expert prepared a report for testimony, a copy must be furnished to opposing counsel and included in a separate Trial Readiness Binder.

The Trial Readiness Binder must include a list of all documents and other items to be offered as trial exhibits, except items offered solely for impeachment or rebuttal.

Each exhibit-list entry must briefly describe the contents and identify each sponsoring witness.

For each exhibit, the list must state whether it is for identification only, whether admission is stipulated to, and the grounds for any objection.

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