Judge Allison H. Goddard
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Adjournments
- Any administrative request to the Court (i.e., extension of time, continuance of ENE, etc.) should be made to the Court by joint motion. If only one party is making the request and the other party or parties do not oppose, they should indicate that in the joint motion. If the other party or parties oppose the request, they should set forth their position in the joint motion. Ex parte applications are disfavored, and any unopposed request should be filed as a joint motion rather than an ex parte application. Counsel who force an ex parte application by refusing to participate in the filing of a joint motion will be subject to sanctions.
- Continuance requests must include the number of previous requests, good cause, whether the request is opposed, effect on other case management dates, and a declaration about compliance steps and why deadlines cannot be met.
- A Scheduling Order may be modified only with Court approval based on a showing of good cause.
- +4 more
Request must include
- Continuance requests must be made by joint motion at least seven calendar days before the affected date.
Communication
Chambers
Phone
Chambers
Page & Word Limits5 rules
The Settlement Conference Statement shall not exceed 10 pages of text. There is not a page limit on exhibits.
- Settlement conference statement
- Up to 10 pages
The Confidential Settlement Letter may not exceed 5 pages of text.
- Confidential settlement letter
- Up to 5 pages
The Settlement Conference Statement shall not exceed 10 pages of text.
- Settlement conference statement
- Up to 10 pages
The Confidential Settlement Letter may not exceed 5 pages of text.
- Confidential settlement letter
- Up to 5 pages
There is not a page limit on exhibits.
Document Format Requirements4 rules
The parties must email a copy of the proposed order in Word format to efile_goddard@casd.uscourts.gov.
- File type
- Word
- Proposed order
Both the Statement and the Letter must be lodged in .pdf format via email to efile_goddard@casd.uscourts.gov (not filed), and must be received no later than 10 calendar days prior to the conference.
- File type
- Settlement conference statement
- Confidential settlement letter
The parties must email a copy of the proposed order in Word format to efile_goddard@casd.uscourts.gov.
- Proposed order
Formatting
- •Word format
Exhibits must be bookmarked within the .pdf file.
- File type
Document Filing Requirements59 rules
Any protective order submitted for the Court's signature must contain the following two provisions: 1. No document shall be filed under seal unless counsel secures a court order allowing the filing of a document, or portion thereof, under seal. An application to file a document under seal shall be served on opposing counsel, and on the person or entity that has custody and control of the document, if different from opposing counsel. If opposing counsel, or the person or entity who has custody and control of the document, wishes to oppose the application, they must contact the chambers of the judge who will rule on the application to notify the Court that an opposition to the application will be filed. 2. The Court may modify the protective order sua sponte in the interests of justice or for public policy reasons.
If the parties reach a settlement, counsel must promptly file a Notice of Settlement or an appropriate Motion to Dismiss.
Before the initial CMC, the parties must lodge a compliant Joint CMC Statement with the Court by email.
Court's wording
Prior to the initial CMC, the parties must lodge a Joint CMC Statement with the Court at efile_goddard@casd.uscourts.gov that complies with the Court’s Requirements for Joint Case Management Statements (https://www.casd.uscourts.gov/Judges/goddard/docs/Goddard%20Joint%20Case%20Management%20Statement%20Rules.pdf).
For a continuance sought to pursue private mediation, the parties must lodge a Joint Mediation Plan by email on the day they file the joint motion, stating the mediation date, mediator, agreed informal discovery, and exchange deadline.
Court's wording
Should the parties request a continuance based on the plan to pursue private mediation, in addition to the joint motion outlined above, the parties shall also lodge (not file) a Joint Mediation Plan via email at efile_goddard@casd.uscourts.gov on the same date they filed the joint motion. The joint plan must state: A. The firm date of mediation; B. The identity of the mediator; C. A complete list of informal discovery the parties agree to exchange before mediation; and D. A firm deadline by which the parties will exchange the informal discovery.
A protective order submitted for signature must require a court order before sealing, service of any sealing application on opposing counsel and any different custodian, and notice to the judge’s chambers if an opposition will be filed.
Court's wording
Any protective order submitted for the Court’s signature must contain the following two provisions: 1. No document shall be filed under seal unless counsel secures a court order allowing the filing of a document, or portion thereof, under seal. An application to file a document under seal shall be served on opposing counsel, and on the person or entity that has custody and control of the document, if different from opposing counsel. If opposing counsel, or the person or entity who has custody and control of the document, wishes to oppose the application, they must contact the chambers of the judge who will rule on the application to notify the Court that an opposition to the application will be filed.
3. Legal Issues: A brief statement, without extended legal argument, of the disputed points of law, including citations to specific statutes and relevant cases.
4. Motions: All past and pending motions relating to this case, their current status, and any anticipated future motions.
The joint case management statement must include a Rule 26(f) checklist certification and a summary of any checklist disputes.
Court's wording
6. Checklist for Rule 26(f) Conference: A certification that the parties have reviewed the Court’s Checklist for Rule 26(f) Conference, which can be found at https://www.casd.uscourts.gov/Judges/goddard/docs/Goddard%20Rule%2026(f)%20Conference%20Checklist.pdf, and a summary of any actual or anticipated disputes regarding items on the Checklist.
The parties must file a Joint Case Management Statement no later than ten calendar days before the initial Case Management Conference scheduled pursuant to CivLR 16.1.d that includes the following information:
The joint case management statement must include jurisdiction, service status, and any proposed service deadline.
Court's wording
1. Jurisdiction and Service: The basis for this Court’s subject matter jurisdiction over plaintiff’s claims and defendant’s counterclaims; whether any parties remain to be served; and a proposed deadline for service if any parties remain to be served.
5. Amendment of Pleadings: The extent to which current parties, claims, or defenses are expected to be modified (i.e., added or dismissed), and a proposed deadline for amending the pleadings.
7. Disclosures: Whether there has been full and timely compliance with the initial disclosure requirements of Fed. R. Civ. P. 26(a)(1).
Joint Case Management Statement due 10 calendar days before initial Case Management Conference
Court's wording
The parties must file a Joint Case Management Statement no later than ten calendar days before the initial Case Management Conference scheduled pursuant to CivLR 16.1.d that includes the following information:
2. Facts: A brief chronology of the facts and a statement of the principal factual issues in dispute.
The joint case management statement must detail all requested relief and damages calculations, including the responding party’s damages-calculation basis if liability is found.
Court's wording
10: Relief: All relief sought through complaint or counterclaim, including the amount of any damages sought and a description of the bases on which damages should be calculated. Additionally, any party from whom damages are sought must describe the bases upon which it contends damages should be calculated if liability is established.
15. Professional Conduct: Confirmation that all attorneys who will be listed in the pleadings or motions for any party have reviewed CivLR 2.1 and agree to abide by the Court’s Code of Conduct.
16. Patent Cases: Proposed modifications to the deadlines provided in the Patent Local Rules; the need for, and specific limits on, discovery relating to claim construction; and whether there is a need to phase damage discovery.
12. Scheduling: Proposed dates for expert disclosures, discovery and motion cutoffs, pretrial conference, and trial.
13. Trial: Whether the case will be tried to a jury or to the Court, and the expected length of the trial.
9. Related Cases: Any related cases or proceedings pending before another judge of this Court, or before another court or administrative body.
- Placement
- Body of the document
17. Other Matters: Any other matters that may facilitate the just, speedy, and inexpensive disposition of this matter.
14. Disclosure of Non-Party Interested Entities or Persons: If applicable, whether each party has filed a Notice of Party with Financial Interest required by CivLR 40.2.
11. Settlement: Summary of any formal or informal settlement discussions, including dates, participants, and outcomes.
The defendant must respond to the plaintiff in writing with a specific offer amount prior to the Meet and Confer discussion.
The parties should confirm that they are preserving relevant evidence, including electronically stored information (“ESI”), and that proper litigation holds are in place.
The parties should discuss the sources of relevant information, including corporate and personal accounts, and disclose all software and applications that are used to generate, manage, and store that information.
Rather, the parties must include their written settlement proposals in their respective Settlement Conference Statements to the Court.
Exhibits must be bookmarked within the .pdf file.
The Settlement Conference Statement must address the suit’s facts, claims and defenses, procedural history and motions, undisputed facts, disputed facts and relevant evidence, and discrete issues that could facilitate resolution.
- Document
- Settlement conference statement
Must include
- •Statement of facts
Court's wording
The Settlement Conference Statement shall include the following: A. Substance of the Suit i. A brief statement of the facts of the case. ii. The claims and defenses, including the statutory or other grounds upon which the claims are founded. iii. A summary of the proceedings to date, including a list of the motions previously made, their dispositions, and any pending motions. iv. A statement of facts not reasonably in dispute. v. A list of the key facts in dispute and the specific evidence relevant to a determination of those facts. vi. Any discrete issue that, if resolved, would facilitate the resolution of the case.
The parties must submit the additional information below either in the Settlement Conference Statement or the Confidential Settlement Letter.
Bond documents must be presented to CRD for review before chambers; must include Court's Order of Conditions of Release.
Court's wording
Counsel must present all bond documents in the form approved by the Court to Judge Goddard's CRD for review before bringing them to chambers. See Crim.LR. 46.1 for more information. The bond documents must include a copy of the Court’s Order of Conditions of Release applicable to the defendant.
In Class A Misdemeanor cases, counsel shall file a sentencing summary chart and/or sentencing memorandum no later than 2 days before the sentencing hearing or change of plea hearing.
The Joint Case Management Statement must address jurisdiction and service, facts, disputed legal issues, motions, anticipated pleading amendments, Rule 26(f) checklist review and disputes, and initial disclosure compliance.
Court's wording
The parties must file a Joint Case Management Statement no later than ten calendar days before the initial Case Management Conference scheduled pursuant to CivLR 16.1.d that includes the following information: 1. Jurisdiction and Service: The basis for this Court’s subject matter jurisdiction over plaintiff’s claims and defendant’s counterclaims; whether any parties remain to be served; and a proposed deadline for service if any parties remain to be served. 2. Facts: A brief chronology of the facts and a statement of the principal factual issues in dispute. 3. Legal Issues: A brief statement, without extended legal argument, of the disputed points of law, including citations to specific statutes and relevant cases. 4. Motions: All past and pending motions relating to this case, their current status, and any anticipated future motions. 5. Amendment of Pleadings: The extent to which current parties, claims, or defenses are expected to be modified (i.e., added or dismissed), and a proposed deadline for amending the pleadings. 6. Checklist for Rule 26(f) Conference: A certification that the parties have reviewed the Court’s Checklist for Rule 26(f) Conference, which can be found at https://www.casd.uscourts.gov/Judges/goddard/docs/Goddard%20Rule%2026(f)% 20Conference%20Checklist.pdf, and a summary of any actual or anticipated disputes regarding items on the Checklist. 7. Disclosures: Whether there has been full and timely compliance with the initial disclosure requirements of Fed. R. Civ. P. 26(a)(1).
The Joint Case Management Statement must address discovery, related cases, requested relief and damages, settlement discussions, proposed scheduling dates, trial mode and length, applicable interested-entity disclosures, attorney professional conduct, patent-case issues, and other matters that may facilitate disposition.
Court's wording
8. Discovery: Discovery served to date, if any, and any proposed limitations or modifications of the discovery rules 9. Related Cases: Any related cases or proceedings pending before another judge of this Court, or before another court or administrative body. 10: Relief: All relief sought through complaint or counterclaim, including the amount of any damages sought and a description of the bases on which damages should be calculated. Additionally, any party from whom damages are sought must describe the bases upon which it contends damages should be calculated if liability is established. 11. Settlement: Summary of any formal or informal settlement discussions, including dates, participants, and outcomes. 12. Scheduling: Proposed dates for expert disclosures, discovery and motion cutoffs, pretrial conference, and trial. 13. Trial: Whether the case will be tried to a jury or to the Court, and the expected length of the trial. 14. Disclosure of Non-Party Interested Entities or Persons: If applicable, whether each party has filed a Notice of Party with Financial Interest required by CivLR 40.2. 15. Professional Conduct: Confirmation that all attorneys who will be listed in the pleadings or motions for any party have reviewed CivLR 2.1 and agree to abide by the Court’s Code of Conduct. 16. Patent Cases: Proposed modifications to the deadlines provided in the Patent Local Rules; the need for, and specific limits on, discovery relating to claim construction; and whether there is a need to phase damage discovery. 17. Other Matters: Any other matters that may facilitate the just, speedy, and inexpensive disposition of this matter.
Counsel shall have the written consent to Rule 11 Plea form signed by their client prior to the scheduled hearing.
Counsel shall have the written Waiver of Indictment signed by their client prior to the scheduled hearing and shall provide it to the Courtroom Deputy prior to the commencement of the calendar.
The Court will accept written stipulations for modification of bail conditions if they are in the form of a “joint motion”signed by all counsel, the defendant, the bond sureties, and the Pretrial Services Officer supervising the defendant.
A copy of the Order of Conditions of Release must be attached to the joint motion and the filing party must submit a separate proposed order for the judge to sign.
- Document
- Joint motion
Must include
- •Proposed order
Material Witness bonds must include a notation, in the upper right hand corner of the bond, of the arraignment date and the initials of counsel for the material witness.
The bond documents must include a copy of the Court’s Order of Conditions of Release applicable to the defendant.
Counsel must present all bond documents in the form approved by the Court to Judge Goddard's CRD for review before bringing them to chambers.
Material witness bonds must also be presented to Judge Goddard’s CRD for review.
A continuance based on private mediation requires lodging, not filing, a Joint Mediation Plan by email the same day as the joint motion, with the mediation date, mediator, informal discovery list, and exchange deadline.
Court's wording
Should the parties request a continuance based on the plan to pursue private mediation, in addition to the joint motion outlined above, the parties shall also lodge (not file) a Joint Mediation Plan via email at efile_goddard@casd.uscourts.gov on the same date they filed the joint motion. The joint plan must state: A. The firm date of mediation; B. The identity of the mediator; C. A complete list of informal discovery the parties agree to exchange before mediation; and D. A firm deadline by which the parties will exchange the informal discovery.
If only one party is making the request and the other party or parties do not oppose, they should indicate that in the joint motion.
If the other party or parties oppose the request, they should set forth their position in the joint motion.
The parties should not file or otherwise copy the Court on these exchanges. Rather, the parties must include their written settlement proposals in their respective Settlement Conference Statements to the Court.
The parties should consider and discuss the following: The scope of any litigation hold, including, but not limited to, a description of information sources to be preserved, date ranges for any ESI to be preserved, and names, job titles, or descriptions of custodians for whom ESI will be preserved;
The parties should discuss whether a protective order is necessary prior to exchanging information in discovery and the timing for submitting a proposed order to the Court.
- Document
- Protective order
Should include
- •Proposed order
Whether to continue any automatic destruction program, such as ongoing erasures of e-mails, voicemails, videos, or other electronically stored material;
The Court may modify the protective order sua sponte in the interests of justice or for public policy reasons.
Whether certain categories of ESI need not be reviewed, preserved or produced because they are inaccessible, burdensome, not proportional, or unlikely to yield relevant information;
The parties should discuss what search methodologies will be used to identify responsive ESI, including the use of search terms, technology assisted review
Identification of systems or sources from which discovery will be prioritized; and Location of systems in which potentially discoverable information is stored.
The parties should discuss how ESI will be produced, including but not limited to: The format of production, i.e., native files, PDF files, TIFF+ files, etc.; Whether the production will include a load file; The extent, if any, to which metadata will be produced and the fields of metadata to be produced; The scope of messages to be produced from text messages and collaborative apps, i.e., the entire thread or a portion based on proximity to the responsive information; Threading of emails; Any applicable process for de-duplication of information; Whether hyperlinked documents will be included in the production, and (where applicable) whether they will be produced in a family relationship with the underlying communication (e.g., email, chat message, text message, etc.); How to resolve any claims of privilege, and whether a separate order under Fed. R. Evid. 502(d) is appropriate; How redactions will be handled and logged; and Production methods and timing, including any plans for supplemental or rolling productions.
The parties should discuss whether the case warrants the joint submission of a proposed order governing discovery of ESI.
The parties should discuss whether they intend to present any evidence that is created or enhanced by a GenAI tool at trial, such as video enhancement or scene reconstructions, and whether specific deadlines should be set in the case schedule for challenging the admission of such evidence.
The parties should discuss whether an alternative form of privilege log, such as a categorical log, metadata log, sample log, or GenAI-generated log would be more efficient than a traditional privilege log. The parties should also discuss the appropriate date range of information to be logged and whether the parties will enter into any sort of clawback agreement under Federal Rule of Evidence 502 regarding inadvertent production of privileged information.
The parties may also lodge updated Confidential Settlement Letters in accordance with Section 7.
The Court recommends that parties produce documents with their Initial Disclosures, rather than just identify documents.
Filing & Service rules
Electronic Filing Rules
The Settlement Conference Statement and optional Confidential Settlement Letter must be lodged as PDFs by email to the stated address, not filed, and received at least 10 calendar days before the conference.
Both the Statement and the Letter must be lodged in .pdf format via email to efile_goddard@casd.uscourts.gov (not filed), and must be received no later than 10 calendar days prior to the conference.
Civil cases
Page 2 | Settlement Conference Statements and Confidential Settlement Letters
The parties should not file or otherwise copy the Court on these exchanges.
The parties should not file or otherwise copy the Court on these exchanges.
Civil cases
Page 1 | Plaintiff Must Make a Formal Settlement Proposal
Filing Timing and Cure Windows
parties have 45 days past the disputed discovery response or the disputed deposition transcript portion to raise a discovery dispute; failure bars the motion, and extensions require a Court-approved joint motion showing good cause.
The parties must bring any discovery dispute to the Court's attention (either by email or filing a motion as outlined above) no later than 45 days after either (1) the date of service of the written discovery response that is in dispute; or (2) the date that the portion of the deposition transcript in dispute is completed. Failure to meet this deadline will bar a party from filing a corresponding discovery motion. The parties must file a joint motion demonstrating good cause if they seek to extend this deadline. The parties cannot extend this deadline by any agreement that is not approved by the Court.
Civil cases
Page 4 | Deadline to Raise Discovery Disputes With the Court
Parties must raise a discovery dispute within 45 days after service of the disputed written response or completion of the disputed deposition transcript portion; missing the deadline bars a corresponding motion.
The parties must bring any discovery dispute to the Court’s attention (either by email or filing a motion as outlined above) no later than 45 days after either (1) the date of service of the written discovery response that is in dispute; or (2) the date that the portion of the deposition transcript in dispute is completed. Failure to meet this deadline will bar a party from filing a corresponding discovery motion.
Page 4 | Deadline to Raise Discovery Disputes With the Court
After settlement, counsel must promptly file a Notice of Settlement or an appropriate Motion to Dismiss.
If the parties reach a settlement, counsel must promptly file a Notice of Settlement or an appropriate Motion to Dismiss.
Page 5 | Notice of Settlement
The Statement and Letter must be received at least 10 calendar days before the conference.
Both the Statement and the Letter must be lodged in .pdf format via email to efile_goddard@casd.uscourts.gov (not filed), and must be received no later than 10 calendar days prior to the conference.
Civil cases
Page 2 | Settlement Conference Statements and Confidential Settlement Letters
Unless excused, parties must lodge updated Settlement Conference Statements 10 days before a further Settlement Conference, addressing the action’s status and developments since the prior conference.
Unless explicitly relieved of this requirement, the parties shall lodge updated Settlement Conference Statements 10 days prior to the further Settlement Conference, in accordance with Sections 6 and 7, to inform the Court of the status of the action and any developments that have occurred since the last Settlement Conference.
Civil cases
Page 4 | Further Settlement Conferences
If the case settles before the Settlement Conference, the parties must immediately file a notice of settlement and notify chambers by phone.
If the case settles prior to the Settlement Conference, the parties shall immediately file a notice of settlement and notify Judge Goddard’s chambers at 619.557.6162.
Civil cases
Page 4 | Notification of Settlement
The Settlement Conference Statement and any Confidential Settlement Letter must be received no later than 10 calendar days before the conference.
Both the Statement and the Letter must be lodged in .pdf format via email to efile_goddard@casd.uscourts.gov (not filed), and must be received no later than 10 calendar days prior to the conference.
Civil cases
Page 2 | Settlement Conference Statements and Confidential Settlement Letters
If the case settles before the Settlement Conference, the parties must immediately file a notice of settlement and notify chambers by telephone.
If the case settles prior to the Settlement Conference, the parties shall immediately file a notice of settlement and notify Judge Goddard’s chambers at 619.557.6162.
Civil cases
Page 4 | Notification of Settlement
Unless excused, parties must lodge updated Settlement Conference Statements 10 days before a further Settlement Conference, following Sections 6 and 7 and reporting case status and developments since the prior conference.
Unless explicitly relieved of this requirement, the parties shall lodge updated Settlement Conference Statements 10 days prior to the further Settlement Conference, in accordance with Sections 6 and 7, to inform the Court of the status of the action and any developments that have occurred since the last Settlement Conference.
Civil cases
Page 4 | Further Settlement Conferences
The parties must file the Joint Case Management Statement at least ten calendar days before the initial Case Management Conference.
The parties must file a Joint Case Management Statement no later than ten calendar days before the initial Case Management Conference scheduled pursuant to CivLR 16.1.d that includes the following information:
Civil cases
Page 1 | Joint Case Management Statement Requirements
Counsel must provide the signed Waiver of Indictment to the Courtroom Deputy before the calendar begins.
Counsel shall have the written Waiver of Indictment signed by their client prior to the scheduled hearing and shall provide it to the Courtroom Deputy prior to the commencement of the calendar.
Criminal cases
Page 1 | Arraignments on Informations
A Waiver of Preliminary Hearing must be filed two days before the preliminary hearing.
A Waiver of Preliminary Hearing must be filed 2 days prior to the preliminary hearing.
Criminal cases
Page 1 | Waiver of Preliminary Hearing
The waiver deadline is two days before the preliminary hearing at the same time of day.
For example, if the preliminary hearing is set for 8/8/19 at 9:30 a.m., the waiver must be filed by 9:30 a.m. on 8/6/19.
Criminal cases
Page 1 | Waiver of Preliminary Hearing
Original plea agreements must be submitted to the 12th floor Clerk's Office two days before the hearing.
Original Plea agreements shall be submitted to the 12th floor Clerk's Office 2 days prior to the hearing.
Criminal cases
Page 1 | Plea Documents
Documents to be proffered at a bond-modification hearing must be provided to the Court’s CRD 24 hours beforehand.
Any documents to be proffered at the hearing must be provided to the Court’s CRD 24 hours in advance of the hearing.
Criminal cases
Page 1 | Motions To Modify Bond
Defense counsel must provide the Court’s CRD and the United States Attorney’s Office with the proposed bail package 24 hours before the hearing, including specified supporting documents for a property bond.
Defense counsel must provide the Court’s CRD and the United States Attorney’s Office with a copy of the proposed bail package, including in the case of a property bond, title documents, appraisals, bank loan statements and other relevant documents, 24 hours in advance of the hearing.
Criminal cases
Page 2 | Nebbia and Surety Examination Hearings
In Class A misdemeanor cases, counsel must file a sentencing summary chart and/or sentencing memorandum at least two days before sentencing or, when immediate sentencing is requested, the change-of-plea hearing.
In Class A Misdemeanor cases, counsel shall file a sentencing summary chart and/or sentencing memorandum no later than 2 days before the sentencing hearing or change of plea hearing (if requesting immediate sentencing).
Criminal cases
Page 2 | Misdemeanor Sentencings
If the plea agreement is not timely submitted, the change of plea will be removed from calendar and rescheduled absent extraordinary circumstances.
If not timely submitted and absent extraordinary circumstances, the change of plea will be taken off calendar and rescheduled.
Criminal cases
Page 1 | Plea Documents
A late waiver does not remove the matter from calendar, and all parties must appear at the scheduled preliminary hearing.
If a waiver is filed after deadline, the matter will not be taken off calendar and all parties will be expected to appear at the scheduled preliminary hearing.
Criminal cases
Page 1 | Waiver of Preliminary Hearing
Service and Proof of Service Rules
The plaintiff must serve the defendant a written settlement proposal stating a specific demand amount at least 21 days before the conference.
No later than 21 days before the conference, the plaintiff must serve on the defendant a written settlement proposal, which must include a specific demand amount.
Civil cases
Page 1 | Plaintiff Must Make a Formal Settlement Proposal
Each Settlement Conference Statement must be served on opposing counsel.
The Settlement Conference Statement must be served on opposing counsel.
Civil cases
Page 2 | Settlement Conference Statements and Confidential Settlement Letters
Before the meet-and-confer discussion, the defendant must give the plaintiff a written response stating a specific offer amount.
The defendant must respond to the plaintiff in writing with a specific offer amount prior to the Meet and Confer discussion.
Civil cases
Page 1 | Plaintiff Must Make a Formal Settlement Proposal
The plaintiff must serve the defendant with a written settlement proposal stating a specific demand amount at least 21 days before the conference.
No later than 21 days before the conference, the plaintiff must serve on the defendant a written settlement proposal, which must include a specific demand amount.
Civil cases
Page 1 | Plaintiff Must Make a Formal Settlement Proposal
Each Settlement Conference Statement must be served on opposing counsel.
The Settlement Conference Statement must be served on opposing counsel.
Civil cases
Page 2 | Settlement Conference Statements and Confidential Settlement Letters
Absent extraordinary circumstances, bail modification requests must be calendared in advance and the opposing party, Pretrial Services, and sureties must receive 24 hours' notice.
Absent extraordinary circumstances, bail modification requests will not be heard unless calendared in advance and with 24 hours notice to the opposing party, Pretrial Services, and the sureties.
Criminal cases
Page 1 | Motions To Modify Bond
Nebbia and surety examinations must be calendared in advance with at least 24 hours’ notice to the Court, all parties, and the Pretrial Services Office.
Nebbia and surety examinations will be heard only if calendared in advance with no less than 24 hours notice to the Court, all parties and the Pretrial Services Office.
Criminal cases
Page 2 | Nebbia and Surety Examination Hearings
Sealing & Redaction Procedures
A document or portion may be filed under seal only with a court order; the sealing application must be served on opposing counsel and any different custodian, who must notify the judge’s chambers if opposing it.
No document shall be filed under seal unless counsel secures a court order allowing the filing of a document, or portion thereof, under seal. An application to file a document under seal shall be served on opposing counsel, and on the person or entity that has custody and control of the document, if different from opposing counsel. If opposing counsel, or the person or entity who has custody and control of the document, wishes to oppose the application, they must contact the chambers of the judge who will rule on the application to notify the Court that an opposition to the application will be filed.
Page 4 | Stipulated Protective Orders
A request to file information under seal requires a specific justification; vague references to competitive harm are almost always insufficient.
The Court will scrutinize any request to file information under seal, and a request will only be granted if a specific showing is made that justifies sealing. Generic and vague references to “competitive harm” will almost always be insufficient to justify sealing.
Page 2 | Motions to Seal
Filing Bundling Requirements
Stipulated protective orders must be filed together as a joint motion.
All stipulated protective orders must be filed as a joint motion.
Civil cases
Page 5 | Stipulated Protective Orders
Stipulated protective orders must be filed as joint motions.
All stipulated protective orders must be filed as a joint motion.
Page 5 | Stipulated Protective Orders
Counsel who force an ex parte application by refusing to participate in a joint motion may be sanctioned.
Counsel who force an ex parte application by refusing to participate in the filing of a joint motion will be subject to sanctions.
Page 2 | Joint Motions
Administrative requests, including extensions and ENE continuances, should be made by joint motion.
Any administrative request to the Court (i.e., extension of time, continuance of ENE, etc.) should be made to the Court by joint motion.
Page 2 | Joint Motions
Ex parte applications are disfavored, and unopposed requests should be filed as joint motions instead.
Ex parte applications are disfavored, and any unopposed request should be filed as a joint motion rather than an ex parte application.
Page 2 | Joint Motions
Pre-Motion Conference Requirements
No discovery motion may be filed unless the Court has first held a pre-motion conference or granted leave, and noncompliant discovery motions may be stricken.
No discovery motion may be filed until the Court has conducted its pre-motion conference, unless the movant has obtained leave of Court. The Court may strike any discovery motion that is filed without complying with this process.
Civil cases
Page 3 | Discovery Disputes
A discovery motion may not be filed before the Court conducts a pre-motion conference unless the movant obtains leave; a noncompliant motion may be stricken.
No discovery motion may be filed until the Court has conducted its pre-motion conference, unless the movant has obtained leave of Court. The Court may strike any discovery motion that is filed without complying with this process.
Page 3 | Discovery Disputes
Before contacting the Court about a discovery dispute, parties must meet and confer; if unsuccessful, the movant must email chambers for a conference with three mutually agreed proposed times, a neutral dispute statement, each party’s position, and opposing counsel copied.
The parties must meet and confer in an attempt to resolve any discovery disputes before contacting the Court. After meet and confer attempts have failed, the movant must e-mail chambers at efile_goddard@casd.uscourts.gov seeking a conference (either by telephone or videoconference) with the Court to discuss the discovery dispute. The email must include: (1) at least three proposed times mutually agreed upon by the parties for the telephonic conference; (2) a neutral statement of the dispute; and (3) one sentence describing (not arguing) each parties’ position. The movant must copy opposing counsel on the email.
Page 3 | Discovery Disputes
In order to ensure that civil litigation is “just, speedy, and inexpensive” as required by Fed. R. Civ. P. 1, attorneys and parties must collaborate in the discovery process. Attorneys and pro se litigants should review the topics set forth in this Checklist at the initial conference required under Fed. R. Civ. P. 26(f).
In order to ensure that civil litigation is “just, speedy, and inexpensive” as required by Fed. R. Civ. P. 1, attorneys and parties must collaborate in the discovery process. Attorneys and pro se litigants should review the topics set forth in this Checklist at the initial conference required under Fed. R. Civ. P. 26(f).
Civil cases
Page 1 | I. Protective Order
The discovery-dispute process does not apply when a party is in custody and proceeding pro se; counsel may call chambers to obtain a hearing date on a noticed discovery motion.
This process does not apply where a party is in custody and is proceeding pro se. In that case, counsel may contact chambers by telephone to obtain a hearing date on a noticed discovery motion.
Page 4 | Discovery Disputes
After a Notice of Settlement is filed, the Court schedules a telephonic Settlement Disposition Conference and removes it from the calendar once the case is dismissed.
Once a Notice of Settlement is filed, the Court will schedule a telephonic Settlement Disposition Conference, which will be taken off calendar once the case has been dismissed.
Page 5 | Notice of Settlement
Adjournment & Extension Requirements
A Scheduling Order may be modified only with Court approval based on a showing of good cause.
Modification of the Scheduling Order requires the approval of the Court, which will only be granted on a showing of good cause.
Civil cases
Page 2 | Scheduling Order
Any administrative request to the Court (i.e., extension of time, continuance of ENE, etc.) should be made to the Court by joint motion. If only one party is making the request and the other party or parties do not oppose, they should indicate that in the joint motion. If the other party or parties oppose the request, they should set forth their position in the joint motion. Ex parte applications are disfavored, and any unopposed request should be filed as a joint motion rather than an ex parte application. Counsel who force an ex parte application by refusing to participate in the filing of a joint motion will be subject to sanctions.
Any administrative request to the Court (i.e., extension of time, continuance of ENE, etc.) should be made to the Court by joint motion. If only one party is making the request and the other party or parties do not oppose, they should indicate that in the joint motion. If the other party or parties oppose the request, they should set forth their position in the joint motion. Ex parte applications are disfavored, and any unopposed request should be filed as a joint motion rather than an ex parte application. Counsel who force an ex parte application by refusing to participate in the filing of a joint motion will be subject to sanctions.
Civil cases
Page 2 | Joint Motions
Continuance requests must include the number of previous requests, good cause, whether the request is opposed, effect on other case management dates, and a declaration about compliance steps and why deadlines cannot be met.
2. The number of previous requests for continuances; 3. A showing of good cause for the request; 4. Whether the request is opposed and why; 5. Whether the requested continuance will affect other case management dates; and 6. A declaration from the counsel seeking the continuance that describes the steps taken to comply with the existing deadlines, and the specific reasons why the deadlines cannot be met.
Civil cases
Page 3 | Requests for Continuances
Continuance requests must be made by joint motion at least seven calendar days before the affected date.
All requests for continuances must be made by a joint motion no less than seven calendar days before the affected date.
Page 2 | Requests for Continuances
A continuance request must state the original deadline or date.
The request must state: 1. The original deadline or date;
Page 2 | Requests for Continuances
Continuance requests must state prior requests, show good cause, explain opposition, and disclose effects on case-management dates.
2. The number of previous requests for continuances; 3. A showing of good cause for the request; 4. Whether the request is opposed and why; 5. Whether the requested continuance will affect other case management dates;
Page 3 | Requests for Continuances
Extending the deadline to raise discovery disputes requires a joint motion demonstrating good cause and Court approval; the parties cannot extend it by an unapproved agreement.
The parties must file a joint motion demonstrating good cause if they seek to extend this deadline. The parties cannot extend this deadline by any agreement that is not approved by the Court.
Page 4 | Deadline to Raise Discovery Disputes With the Court
Nebbia/surety hearings require 24-hour advance calendaring and notice; defense must provide bail package to CRD and USAO 24 hours in advance.
Nebbia and surety examinations will be heard only if calendared in advance with no less than 24 hours notice to the Court, all parties and the Pretrial Services Office. Defense counsel must provide the Court’s CRD and the United States Attorney’s Office with a copy of the proposed bail package, including in the case of a property bond, title documents, appraisals, bank loan statements and other relevant documents, 24 hours in advance of the hearing.
Criminal cases
Page 2 | Nebbia and Surety Examination Hearings
The Court issues a Scheduling Order after the CMC, and modification requires Court approval and good cause.
The Court will issue a Scheduling Order following the CMC. Modification of the Scheduling Order requires the approval of the Court, which will only be granted on a showing of good cause.
Page 2 | Scheduling Order
Chambers Communication Rules
Before contacting the Court, parties must meet and confer; discovered conference e-mail requests must include three mutual times, a neutral statement of the dispute, one sentence on each party's position, and opposing counsel copied.
The parties must meet and confer in an attempt to resolve any discovery disputes before contacting the Court. After meet and confer attempts have failed, the movant must e-mail chambers at efile_goddard@casd.uscourts.gov seeking a conference (either by telephone or videoconference) with the Court to discuss the discovery dispute. The email must include: (1) at least three proposed times mutually agreed upon by the parties for the telephonic conference; (2) a neutral statement of the dispute; and (3) one sentence describing (not arguing) each parties’ position. The movant must copy opposing counsel on the email.
Civil cases
Page 3 | Discovery Disputes
The parties must email a copy of the proposed order to the court email address.
The parties must email a copy of the proposed order in Word format to efile_goddard@casd.uscourts.gov.
Civil cases
Page 5 | Stipulated Protective Orders
After meet-and-confer efforts fail, the movant must contact chambers by email to request a discovery-dispute conference, include specified information, and copy opposing counsel.
After meet and confer attempts have failed, the movant must e-mail chambers at efile_goddard@casd.uscourts.gov seeking a conference (either by telephone or videoconference) with the Court to discuss the discovery dispute. The email must include: (1) at least three proposed times mutually agreed upon by the parties for the telephonic conference; (2) a neutral statement of the dispute; and (3) one sentence describing (not arguing) each parties’ position. The movant must copy opposing counsel on the email.
Page 3 | Discovery Disputes
If a scheduled court date is imminent, counsel must contact chambers to advise of the settlement.
If a scheduled date with the Court is imminent, counsel must also contact chambers to advise of the settlement.
Page 5 | Notice of Settlement
The parties must email a copy of the proposed order in Word format to the specified address.
The parties must email a copy of the proposed order in Word format to efile_goddard@casd.uscourts.gov.
Page 5 | Stipulated Protective Orders
Counsel must meet and confer in person or by phone, not by email, about the specified matters at least 14 days before the Settlement Conference.
Counsel for the parties must meet and confer (in person or by phone, not by email) to discuss the following matters no later than 14 days before the Settlement Conference:
Civil cases
Page 1 | Meet and Confer Requirement
If the case settles before the Settlement Conference, the parties must notify Judge Goddard’s chambers at the stated phone number.
If the case settles prior to the Settlement Conference, the parties shall immediately file a notice of settlement and notify Judge Goddard’s chambers at 619.557.6162.
Civil cases
Page 4 | Notification of Settlement
The Settlement Conference Statement and any Confidential Settlement Letter must be emailed to the Court in PDF format, not filed, and received at least 10 calendar days before the conference.
Both the Statement and the Letter must be lodged in .pdf format via email to efile_goddard@casd.uscourts.gov (not filed), and must be received no later than 10 calendar days prior to the conference.
Civil cases
Page 2 | Settlement Conference Statements and Confidential Settlement Letters
If the case settles prior to the Settlement Conference, the parties shall immediately file a notice of settlement and notify Judge Goddard’s chambers at 619.557.6162.
If the case settles prior to the Settlement Conference, the parties shall immediately file a notice of settlement and notify Judge Goddard’s chambers at 619.557.6162.
Civil cases
Page 4 | Notification of Settlement
Counsel may email chambers at the designated address, but excessive or inappropriate email can result in termination of that privilege.
Counsel may communicate with the Court by emailing efile_goddard@casd.uscourts.gov. This is a privilege that may be terminated at the Court’s discretion in the event of excessive or inappropriate email communications.
Civil cases
Page 1 | Communications with Chambers
Telephone contact with the Court is limited to non-substantive scheduling and calendaring matters, and Court personnel may not give legal advice or discuss the merits.
Attorneys who have appeared in the case may contact the Court by telephone for non-substantive matters such as scheduling and calendaring. Court personnel are prohibited from giving legal advice or discussing the merits of a case.
Civil cases
Page 1 | Communications with chambers
Counsel must contact chambers to advise of the settlement if a scheduled court date is imminent.
If a scheduled date with the Court is imminent, counsel must also contact chambers to advise of the settlement.
Civil cases
Page 5 | Notice of Settlement
Court personnel may not give legal advice or discuss a case’s merits.
Court personnel are prohibited from giving legal advice or discussing the merits of a case.
Page 1 | Communications with Chambers
Counsel may email the Court at the stated address, but the privilege may be terminated for excessive or inappropriate communications.
Counsel may communicate with the Court by emailing efile_goddard@casd.uscourts.gov. This is a privilege that may be terminated at the Court’s discretion in the event of excessive or inappropriate email communications.
Page 1 | Communications with Chambers
For a dispute arising during a deposition, counsel must meet and confer before seeking a ruling; if unsuccessful, counsel may call chambers, and should continue other areas of deposition inquiry if the Court cannot review the matter immediately.
If a dispute arises during the course of a deposition, counsel must meet and confer prior to seeking any ruling from the Court. After meet and confer attempts have failed, counsel may call chambers to seek a ruling. If the Court is unable to review the matter at that moment, counsel should proceed with the deposition in other areas of inquiry and the Court will respond as soon as practicable.
Page 4 | Discovery Disputes
Attorneys who have appeared may call the Court about non-substantive matters such as scheduling and calendaring.
Attorneys who have appeared in the case may contact the Court by telephone for non-substantive matters such as scheduling and calendaring.
Page 1 | Communications with Chambers
For a noticed discovery motion involving a party in custody who is proceeding pro se, counsel may telephone chambers to obtain a hearing date.
This process does not apply where a party is in custody and is proceeding pro se. In that case, counsel may contact chambers by telephone to obtain a hearing date on a noticed discovery motion.
Page 4 | Discovery Disputes
Either party may object to the Court’s use of GenAI by advising the law clerk when submitting the information.
Either party may object to the Court’s use of such tools by advising the Court’s law clerk of that objection when they submit the information.
Civil cases
Page 3 | Additional Settlement Information
The Court prefers that parties file a written motion rather than request a bond hearing. If the request is urgent, counsel may contact the Court’s CRD to request a hearing date.
The Court prefers that parties file a written motion rather than request a bond hearing. If the request is urgent, counsel may contact the Court’s CRD to request a hearing date.
Criminal cases
Page 1 | Motions To Modify Bond
Criminal calendars held Tuesdays/Thursdays at 9:30 AM; notify CRD of conflicts/priority requests in advance.
Criminal calendars are heard on Tuesdays and Thursdays at 9:30 a.m. Counsel should advise the Courtroom Deputy of any scheduling conflicts or requests for priority in advance of the hearing.
Criminal cases
Page 1 | Criminal Calendar
With prior Court approval, an out-of-state surety may appear by telephone if accompanied by a notary and able to present suitable identification.
With prior approval of the Court, out-of-state sureties may appear by telephone if they are accompanied by a notary to whom they can present a driver’s license or other suitable identification.
Criminal cases
Page 2 | Nebbia and Surety Examination Hearings
Junior Lawyer Participation Incentives
The Court encourages parties to allow attorneys with fewer than ten years of experience to argue matters before the Court. To that end, the Court will hold a hearing (either remotely or in person, at the Court’s discretion) on any motion if one party notifies the Court in advance that an attorney with fewer than ten years of experience will be arguing at least a portion of the motion on behalf of that party. The party will be able to have more than one attorney argue their side of the motion if one of the attorneys arguing has fewer than ten years of experience.
The Court encourages parties to allow attorneys with fewer than ten years of experience to argue matters before the Court. To that end, the Court will hold a hearing (either remotely or in person, at the Court’s discretion) on any motion if one party notifies the Court in advance that an attorney with fewer than ten years of experience will be arguing at least a portion of the motion on behalf of that party. The party will be able to have more than one attorney argue their side of the motion if one of the attorneys arguing has fewer than ten years of experience.
Civil cases
Page 2 | Experience Opportunities for Attorneys With Fewer Than Ten Years of Practice
The Court encourages using junior lawyers for discovery dispute arguments and will allow multiple attorneys to argue when at least one has fewer than ten years of practice.
The Court encourages parties to allow attorneys with fewer than ten years of experience to argue a discovery dispute during the pre-motion conference. The Court will allow multiple attorneys for a party to be heard on a dispute if at least one of the attorneys has fewer than ten years of experience.
Civil cases
Page 3 | Discovery Disputes
If a party notifies the Court in advance that an attorney with fewer than ten years’ experience will argue part of a motion, the Court will hold a hearing, and multiple attorneys may argue if one has fewer than ten years’ experience.
The Court encourages parties to allow attorneys with fewer than ten years of experience to argue matters before the Court. To that end, the Court will hold a hearing (either remotely or in person, at the Court’s discretion) on any motion if one party notifies the Court in advance that an attorney with fewer than ten years of experience will be arguing at least a portion of the motion on behalf of that party. The party will be able to have more than one attorney argue their side of the motion if one of the attorneys arguing has fewer than ten years of experience.
Page 2 | Experience Opportunities for Attorneys With Fewer Than Ten Years of Practice
The Court encourages attorneys with fewer than ten years of experience to argue discovery disputes and permits multiple attorneys to be heard when at least one meets that threshold.
The Court encourages parties to allow attorneys with fewer than ten years of experience to argue a discovery dispute during the pre-motion conference. The Court will allow multiple attorneys for a party to be heard on a dispute if at least one of the attorneys has fewer than ten years of experience.
Page 3 | Discovery Disputes