Judge Gonzalo P. Curiel
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Filings > 20 pages
Adjournments
- A party seeking a continuance of a sentencing hearing must notify the courtroom deputy clerk at the earliest possible time, but in no event later than close of business three court days before the sentencing hearing.
- Travel modification requests must be filed at least 4 court days in advance.
Communication
Phone
Chambers
Page & Word Limits2 rules
Motions in limine and oppositions limited to 10 pages; attachments also limited to 10 pages.
- Motion in limine
- Up to 10 pages
Exception
More pages with leave of court
Court's wording
Absent leave of court, each motion in limine and each opposition thereto shall be limited to ten pages in length. Attachments to any motion in limine or opposition thereto shall also be limited to ten pages in length.
Absent leave of court, separate statements shall be limited to 15 pages and must comply with the font requirements of Civil Local Rule 5.1.
- Separate statement
- Up to 15 pages
Exception
More pages with leave of court
Document Format Requirements6 rules
The courtesy copy shall contain the CM/ECF document header on the top of each page.
Separate statements must use two-column format with specific content requirements.
Court's wording
The separate statement must be in a two-column format with the moving party providing in numerical sequence the undisputed material facts in the first column followed by the evidence citation that establishes those undisputed facts. In opposition, the opposing party shall indicate in the second column whether the fact is “disputed” or “undisputed.” If disputed, the opposing party must state in the second column, directly opposite the fact in dispute, the reasons for the dispute and cite the evidence that supports the position that the fact is controverted.
If a filing has more than three (3) exhibits, the exhibits must be tabbed.
Formatting
- •Tabbed exhibits if more than 3 exhibits
Counsel must bring own electronic equipment for courtroom use.
Court's wording
Counsel are required to bring their own computers, laptops, tablets, HDMI or VGA adapters and wireless cards, if necessary. Counsel should contact the CRD for details and instructions and with questions regarding the use of equipment not provided for by the Court.
Motion hearing dates are generally set on Fridays at 1:30 p.m.
The Court prefers courtesy copies to be printed double-sided, but will accept single-sided.
Document Filing Requirements33 rules
Proposed orders required in Word format with specific formatting and email submission requirements.
Court's wording
Proposed orders shall be submitted in Word format simultaneously with all motions, except motions that are fully noticed and set for hearing at least 28 days beyond the date of filing. In accordance with Section 2(h) of the Electronic Case Filing Administrative Policies and Procedures Manual, proposed orders shall not contain the name and law firm information of the filing party and shall not contain the word “proposed” in the caption. Counsel shall email proposed orders to opposing counsel and to the following email address: efile_curiel@casd.uscourts.gov, and include the docket number and case name in the subject line of the email.
Trial notebook items due 7 days before motion in limine hearing.
- Document
- Trial notebook
Include
- •Trial briefs
- •Exhibit lists
- •Voir dire questions
- •Proposed verdict form
- •Statement of the case
- •Joint proposed jury instructions
Court's wording
The joint proposed jury instructions, trial briefs, proposed verdict form, voir dire questions, statement of the case, and exhibit lists are to be placed in a trial notebook, and are due seven (7) days before the motion in limine hearing date unless the Court orders otherwise.
Proposed pretrial order in Word format required 7 days before pretrial conference.
- Document
- Proposed pretrial order
Must include
- •Word format
Court's wording
Pursuant to Civil Local Rule 16.1(f)(6), the Court requires that the parties email to Chambers a proposed pretrial order in Word format at least seven (7) days before the pretrial conference. The proposed pretrial order must include all elements set out in Civil Local Rule 16.1(f)(6)(c) and any other issues relevant to the trial.
The proposed jury instructions, proposed verdict form, and statement of the case shall also be emailed to the Court in Word format.
- Document
- Proposed jury instructions
Must include
- •Word format
All parties are required to cooperate in completing the proposed pretrial order.
Any AI-generated material that does not have an accompanying notice shall not be considered by the Court.
Notice required for AI-generated evidentiary material with sufficient specificity.
Court's wording
Counsel shall serve a notice to the opposing party identifying AI-generated evidentiary material with sufficient specificity to locate it (i.e., via production number, attaching a copy to the notice, providing a copy on request). This notice should be served with the production or disclosure of any AI-generated evidentiary material.
In terms of AI-generated documents or materials that may become exhibits or evidence in an action, a pro se party or counsel shall follow the below procedures:
Parties and counsel shall not file, proffer, or present to the Court exhibits, demonstratives, or other evidentiary or factual material that contain AI-hallucinated assertions of fact.
Failure to confirm the accuracy or basis for an assertion of fact or evidence created by an AI tool is grounds for potential sanctions.
Notice of Settlement required immediately; Joint Motion to Dismiss due within 28 days if no deadline set.
- Document
- Settlement
Must include
- •Notice of settlement
- •Joint motion to dismiss
Court's wording
If the parties settle a case, counsel shall file a “Notice of Settlement” and immediately inform the magistrate judge of the settlement. If the magistrate judge does not set a deadline for the filing of a “Joint Motion to Dismiss,” the parties shall file the “Joint Motion to Dismiss” and email a proposed order to this Court within twenty-eight (28) days of the settlement.
Proposed Findings of Fact and Conclusions of Law due 7 days before trial by hard copy and Word email.
- Document
- Proposed findings conclusions
Must include
- •Hard copy
- •Electronic copy
Court's wording
Seven (7) days before trial, counsel will submit proposed Findings of Fact and Conclusions of Law by hard copy and an electronic copy of the proposed Findings of Fact and Conclusions of Law shall be emailed in Word format to efile_curiel@casd.uscourts.gov.
Proposed orders for preliminary approval of class certification and/or preliminary settlement approval must be supported by an affidavit and memorandum
- Document
- Proposed order
Must include
- •Affidavit
- •Memorandum
In addition to the above information, where class members are entitled to non- monetary relief, such as discount coupons, debit cards, or similar instruments, the number of class members availing themselves of such relief and the aggregate value redeemed by the class members and/or by any assignees or transferees of the class members’ interests.
Where injunctive and/or other non-monetary relief has been
The total settlement fund, the total number of class members, the total number of class members to whom notice was sent and not returned as undeliverable, the number and percentage of claim forms submitted, the number and percentage of opt- outs, the number and percentage of objections, the average and median recovery per claimant, the largest and smallest amounts paid to class members, the method(s) of notice and the method(s) of payment to class members, the number and value of checks not cashed, the amounts distributed to each cy pres recipient, the administrative costs, the attorneys’ fees and costs, the attorneys’ fees in terms of percentage of the settlement fund, and the multiplier, if any.
Within 21 days after the distribution of the settlement funds and payment of attorneys’ fees, the parties should file a Post-Distribution Accounting, which provides the following information:
AI-generated content must be personally verified for accuracy
Must include
- •AI disclosure
Court's wording
Despite the spread of generative AI tools, counsel and pro se parties are responsible for providing the Court with complete and accurate representations of any submission, including filings, demonstratives, evidence, or oral argument, consistent with Federal Rule of Civil Procedure 11, the California Rules of Professional Conduct, and any other applicable legal or ethical guidance. Use of generative AI tools is not prohibited, but counsel and pro se parties must, at all times, personally confirm for themselves the accuracy of any content generated by these tools.
Summary judgment opposition must respond to separate statement.
Court's wording
Any opposition to a summary judgment motion shall include a response to the separate statement that responds to each of the material facts contended by the moving party to be undisputed, indicating if the opposing party agrees or disagrees that those facts are undisputed.
AI-generated content must include verification certification; failure is grounds for sanctions
Must include
- •AI disclosure
Court's wording
Additionally, any submission containing AI-generated content must include a certification that counsel or the pro se party has personally verified the content’s accuracy. Failure to include this certification or comply with this verification requirement will be grounds for sanctions.
Summary judgment motions require separate statement of undisputed material facts.
Court's wording
All motions for summary judgment shall be accompanied by a separate statement setting forth plainly and concisely all material facts that the moving party contends are undisputed. Each of the material fact shall be followed by a reference to the supporting evidence.
Pursuant to Criminal Local Rule 23.1, the parties may, no later than five court days before the date of trial, serve and file briefs on all significant disputed issues of law, including foreseeable procedural and evidentiary issues.
The parties should each submit in Word format and hardcopy, proposed jury instructions to the Court on the first day of trial, unless otherwise ordered by the Court.
Counsel shall file the completed sentencing summary charts required by Criminal Local Rule 32.1.a.8 in the record no later than seven calendar days before the sentencing hearing.
An opposing party’s failure to file an opposition to any motion may be construed as consent to the granting of the motion pursuant to Civil Local Rule 7.1(f)(3)(c).
Parties must maintain records of AI prompts and bear responsibility for submissions
Include
- •AI disclosure
Court's wording
At all times, counsel and pro se parties bear responsibility for any submission made by the party represented. Counsel and pro se parties are responsible for maintaining records of all prompts or inquiries submitted to any generative AI tools in the event those records become relevant.
The requirement to file a Memoranda of Contentions of Law and Fact, pursuant to Civil Local Rule 16.1(f)(2)(a), is waived.
Court sets time limits for civil trials (excluding jury selection) and tracks remaining time.
Court's wording
In civil trials, it is the practice of the Court to set a reasonable time limit for the entire trial. The time limit set by the Court includes opening statements, arguments, testimony, closing arguments, and any other matters that occur over the course of the trial, excluding jury selection. The Court will keep track of time limits and, upon request, the courtroom deputy will inform the parties of the time spent and remaining for trial. The time limit is subject to exception for good cause shown.
Definition of generative AI and examples of tools
Include
- •AI disclosure
Court's wording
Generative artificial intelligence (AI) denotes a system of algorithms or deep- learning models that can take raw data and generate new, original outputs (e.g., text, images, videos) based on user prompts. Common examples of generative AI tools include ChatGPT, Google Gemini, and Microsoft Copilot.
Court prefers Ninth Circuit Model Jury Instructions; modifications must be cited and identified.
Court's wording
The Court prefers to use the most current Model Jury Instructions for the Ninth Circuit whenever possible. The Court will accept other proposed jury instructions, but counsel must cite the authority supporting the proposed instructions. Counsel must specifically identify any modification made to Ninth Circuit Model Instructions.
The courtroom deputy will seat all prospective jurors (44 prospective jurors will
The courtroom deputy will provide counsel with a list of the jury panel in random order before voir dire.
Counsel may serve and file proposed voir dire questions and verdict forms on the day set for motions in limine.
Filing & Service rules
Courtesy Copy Requirements
Courtesy copies required for filings over 20 pages via mail/courier.
Courtesy copies of filings that exceed 20 pages in length, including attachments and exhibits, shall be submitted in accordance with Section 2(e) of the Electronic Case Filing Administrative Policies and Procedures via United States Postal Service mail, courier, or delivery to the Clerk’s Office.
Sealing & Redaction Procedures
Court may seal documents to protect sensitive information.
The Court may seal documents to protect sensitive personal or confidential information.
Presumptive right of public access to court records.
There is a presumptive right of public access to court records based upon common law and first amendment grounds.
Pre-Motion Conference Requirements
Motion hearing dates must be obtained from law clerk before filing; sur-replies require ex parte leave.
Pursuant to Civil Local Rule 7.1(b), all dates for motion hearings must be obtained by calling the law clerk before filing any motion. Motion papers MUST be filed and served the same day of obtaining a motion hearing date from chambers. A briefing schedule will be issued once a motion has been filed. The parties must obtain leave of Court by filing an ex parte request before filing any sur-replies.
Page 2 | PRETRIAL MOTION PRACTICE
Motions in limine due 2 weeks before hearing; responses due 7 days before.
Unless the Court orders otherwise, all motions in limine are due two weeks before the motion in limine hearing date. All responses are due seven (7) days before the motion in limine hearing date.
Page 5 | PRETRIAL CONFERENCE
Motions must be filed 14 days before hearing; oppositions 7 days before.
All motions shall be filed at least fourteen calendar days before the hearing date. Any Opposition shall be filed at least seven calendar days before the hearing date.
Page 1 | Pretrial Motions
Motions in limine due 2 weeks before hearing; oppositions due 1 week before.
Motions in limine are due two weeks before the hearing, with any opposition due one week before the hearing.
Page 2 | Trial Procedures
Shortening time applications require non-conclusory affidavit with specific good cause.
Applications for an order shortening time are disfavored and must be supported by a non- conclusory affidavit signed by counsel setting forth facts establishing specific good cause.
Page 1 | Pretrial Motions
Adjournment & Extension Requirements
Travel modification requests must be filed at least 4 court days in advance.
A party seeking a modification of their conditions of release to travel must file the request at least four court days in advance of their anticipated date of travel or show good cause why the request was submitted later than that.
Page 4 | Requests to Modify Conditions of Relief
A party seeking a continuance of a sentencing hearing must notify the courtroom deputy clerk at the earliest possible time, but in no event later than close of business three court days before the sentencing hearing.
A party seeking a continuance of a sentencing hearing must notify the courtroom deputy clerk at the earliest possible time, but in no event later than close of business three court days before the sentencing hearing.
Page 4 | Sentencing procedures
Chambers Communication Rules
Chambers communication limited to scheduling; no legal advice or unauthorized letters/faxes/emails.
Telephone calls to chambers are permitted only for scheduling or calendaring motion hearings or as otherwise authorized by the Court. Court personnel are prohibited from interpreting orders, discussing the merits of a case, or giving legal advice, including advice on procedural matters. Letters, faxes, and emails are prohibited unless otherwise authorized by the Court.
Page 1 | COMMUNICATION WITH CHAMBERS
Government counsel must provide exhibit list to courtroom deputy clerk before trial.
Government counsel must provide a list of exhibits to the courtroom deputy clerk prior to the first day of trial.
Page 3 | Exhibits
All exhibits must be pre-marked on the first day of trial.
All exhibits must be pre-marked on the first day of trial.
Page 3 | Exhibits
When objecting, counsel may only state the legal ground for the objection, e.g., “Objection. Hearsay.” Counsel need not provide further information unless the Court requests it.
When objecting, counsel may only state the legal ground for the objection, e.g., “Objection. Hearsay.” Counsel need not provide further information unless the Court requests it.
Page 3 | Presentation of Evidence
Counsel must get permission before approaching witnesses and keep visits brief.
Counsel must seek permission from the Court before approaching witnesses. When permission is granted, counsel must keep his or her visit to the witness stand brief, i.e., by quickly orienting the witness to an exhibit and then returning to the podium.
Page 3 | Presentation of Evidence
Junior Lawyer Participation Incentives
Court encourages opportunities for young lawyers to conduct hearings.
The Court strongly encourages litigants to be mindful of opportunities for young lawyers to conduct hearings before the Court, particularly for motions where
Page 2 | PRETRIAL MOTION PRACTICE
Junior lawyers (under 5 years) arguing may increase likelihood of oral argument.
If a written request for oral argument is made in the moving, opposition or reply briefs stating that an attorney with less than five years of experience after becoming a member of the California bar will argue the oral argument, then such a representation will weigh in favor of holding a hearing.