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Court Rules
Judge

Judge Todd W. Robinson

Individual Rules, Standing Orders & Policies

Rules last changed:
Southern District of California

Limits & Logistics

Document Limits

Opposition Brief
25 pgs
Closing Brief
25 pgs
Motions in Limine
25 pgs
Omnibus Brief
25 pgs

Courtesy Copies

Filings > 20 pages

  • Hand Delivery • As Soon as Practicable

Adjournments

24Hoursnotice
  • Opposing ex parte applications requires 24-hour notice of intent to oppose.
3Court Daysnotice
  • Continuance/extension requests require meet-and-confer, joint motion if agreed, ex parte if not, filed 3 court days before deadline.

Communication

Email

Chambers

efile_robinson@casd.uscourts.gov
Technical Issues
Phone

Chambers

Scheduling
No status inquiries
Cases:
Filters:

Page & Word Limits5 rules

Page LimitsMandatoryCivil cases

File all motions in limine, including all trial-related Daubert motions, in a single, omnibus brief not to exceed twenty-five (25) pages.

Omnibus brief
Up to 25 pages
Applies to
  • Motion in limine
  • Daubert motions
Civil Standing Order · p. 8
|SectionVI. Final Pretrial Conference and Motions in Limine
Page LimitsMandatoryCivil cases

Closing briefs (max 25 pages) may be filed instead of closing arguments within 4 weeks of transcript availability.

Closing brief
Up to 25 pages

Court's wording

Rather than hear closing arguments, unless otherwise ordered, the parties will be permitted to file closing briefs not to exceed twenty-five (25) pages within four (4) weeks of the date on which all relevant transcripts become available.

Civil Standing Order · p. 8
|SectionVII. Trial Procedures
Page LimitsMandatoryCivil cases

File all oppositions to motions in limine, including all trial-related Daubert motions, in a single, omnibus brief not to exceed twenty-five (25) pages.

Opposition brief
Up to 25 pages
Applies to
  • Motion in limine
  • Daubert motions
Civil Standing Order · p. 8
|SectionVI. Final Pretrial Conference and Motions in Limine
Page LimitsMandatoryCivil cases

Maximum 5 motions in limine per side, filed as single 25-page omnibus brief.

Motions in limine
Up to 25 pages
Applies to
  • In limine motions
  • Daubert motions

Exception

More pages with leave of court

Court's wording

absent extraordinary circumstances and without leave of the Court, the Court will entertain no more than five (5) motions in limine—including trial-related Daubert motions—per side. All motions in limine must be filed in a single, omnibus brief not to exceed twenty-five (25) pages.

Civil Standing Order · p. 9
|SectionMotions in Limine
Page LimitsNoteCivil cases

If voir dire by counsel is permitted, fifteen (15) minutes per side on non-complex cases generally will be allowed.

Civil Standing Order · p. 10
|SectionJury Selection

Document Format Requirements8 rules

FormattingMandatoryCriminal cases

Proposed orders should be submitted simultaneously with the accompanying motion in Word format.

File type
Word
Applies to
  • Proposed order
Criminal Chambers Rules · p. 2
|SectionII. Communications with Chambers
FormattingMandatoryCriminal cases

Proposed jury instructions must be submitted in Word format to the Judge’s efile email and cc the Courtroom Deputy Clerk.

File type
Word
Applies to
  • Jury instructions

Court's wording

The proposed preliminary and final jury instructions must be filed and submitted to the Court in Word format directly to the Judge’s official email address, which is efile_Robinson@casd.uscourts.gov, as well as copy the Courtroom Deputy Clerk at Jessica_A_Ortiz@casd.uscourts.gov.

Criminal Chambers Rules · p. 3
|SectionVI.B. Jury Instructions
FormattingMandatoryCriminal cases

Proposed forms of verdict must be submitted by email in Word format on the day set for motions in limine.

File type
Word
Applies to
  • Verdict form
Criminal Chambers Rules · p. 4
|SectionVI.D. Proposed Voir Dire Questions and Verdict Forms
FormattingMandatoryCriminal cases

A binder of exhibits shall be provided for the bench.

FormattingMandatoryCivil cases

All exhibits submitted in support of motions should be excerpted to include only relevant material. All exhibits must also be clearly labeled, dated, tabbed, and indexed.

Civil Standing Order · p. 2
|SectionA. Generally Applicable Rules
FormattingNoteCriminal cases

When referring to an exhibit, counsel should refer to its exhibit number whenever possible to keep a complete record.

FormattingNoteCriminal cases

Exhibit stickers may be obtained from the Clerk of the Court in advance of trial, or exhibits may be marked electronically with the case number and exhibit numbers.

FormattingNoteCivil cases

Defendants must number exhibits starting at 500 instead of using alphabetic letters.

Court's wording

The Court modifies the manner of numbering trial exhibits set forth in Civil Local Rule 16.1(f)(2)(c) as follows: Rather than mark exhibits using alphabetic letters, defendant(s) must number their exhibits beginning at number 500 (or any other number agreed upon with opposing counsel).

Document Filing Requirements31 rules

Filing RequirementsMandatoryCriminal cases

Motions to seal must include a description of documents to seal, applicable legal standard and analysis, supporting affidavits/declarations, and the documents to be sealed.

Court's wording

Any motion to seal must set forth: (1) a description of the particular document(s) or part of the document(s) the party seeks to seal; (2) the correct legal standard and an analysis of why the standard has been satisfied with respect to the particular document(s); (3) affidavits or declarations in support of the motion; and (4) the documents to be sealed.

Criminal Chambers Rules · p. 2
|SectionIV. Under Seal Filing Procedures B.
Filing RequirementsMandatoryCriminal cases

Parties must follow Criminal Local Rule 32.1 and ensure Sentencing Guideline recommendations are supported by the record.

Court's wording

The parties are expected to follow Criminal Local Rule 32.1. Additionally, the parties must ensure that their respective Sentencing Guideline recommendations are supported by the record before the Court.

Criminal Chambers Rules · p. 3
|SectionV.C. Sentencing Materials
Filing RequirementsMandatoryCriminal cases

any proposed modification of an instruction from statutory authority or the Ninth Circuit Models must state specifically the modification and the authority supporting the modification.

Criminal Chambers Rules · p. 3
|SectionVI.B. Jury Instructions
Filing RequirementsMandatoryCriminal cases

The Court expects defense counsel, in any felony matter, to read, explain, and provide their client with a copy of the Standard Conditions of Supervised Release prior to sentencing.

Criminal Chambers Rules · p. 3
|SectionV.D. Supervised Release
Filing RequirementsMandatoryCriminal cases

Government counsel must provide a list of exhibits and give it to the Courtroom Deputy Clerk on the first day of trial. All exhibits must be pre-marked on the first day of trial.

Document
Exhibit

Must include

  • Exhibit list
Filing RequirementsMandatoryCivil cases

Objections to evidence must be in opposition or reply brief; no separate objection statements allowed.

Court's wording

Objections to evidence submitted in support of a motion must be contained within the opposition brief, and objections to evidence submitted in support of an opposition must be contained within the reply brief. No separate statements of objections will be allowed or considered.

Civil Standing Order · p. 3
|SectionB. Rules for Noticed Motions
Filing RequirementsMandatoryCivil cases

Rule 11 requires reasonable inquiry and certification of well-grounded filings.

Court's wording

“Rule 11 imposes a duty on attorneys [and pro se litigants] to certify that they have conducted a reasonable inquiry and have determined that any papers filed with the court are well grounded in fact[ and] legally tenable.”

Civil Standing Order · p. 6
|SectionD. Use of Generative Artificial Intelligence
Filing RequirementsMandatoryCivil cases

Failure to exercise due care with AI-generated work may result in Rule 11 violations and sanctions.

Court's wording

Accordingly, failure to exercise due care in reviewing and filing work product created with the assistance of generative AI tools may violate Rule 11 and other applicable standards of practice and expose the filer to sanctions or other corrective or disciplinary action.

Civil Standing Order · p. 6
|SectionD. Use of Generative Artificial Intelligence
Filing RequirementsMandatoryCivil cases

Dismissal motions retaining jurisdiction require signed Magistrate Judge Consent Form.

Document
Joint motion to dismiss

Include

  • Consent to jurisdiction

Court's wording

Any joint motion for dismissal or notice of dismissal that includes a provision that the Court retain jurisdiction will be rejected unless it is accompanied by a Consent to Jurisdiction by a United States Magistrate Judge form ("Consent Form") over all disputes arising out of the settlement agreement, including interpretation and enforcement of the settlement agreement, signed by all parties and their counsel.

Civil Standing Order · p. 7
|SectionV. Settlement
Filing RequirementsMandatoryCivil cases

Proposed jury instructions due 2 weeks before PTC.

Court's wording

Unless otherwise ordered by the Court, the parties shall serve their proposed preliminary and final jury instructions on each other with sufficient time to meet, confer, and jointly file a complete set of agreed-upon instructions no later than two (2) weeks before the PTC.

Civil Standing Order · p. 9
|SectionJury Instructions
Filing RequirementsMandatoryCivil cases

Joint jury questionnaire and verdict form due 2 weeks before PTC.

Court's wording

Unless otherwise ordered by the Court, following meet-and-confer efforts, counsel shall serve, file, and lodge in Word format to the E-file Email a joint proposed jury questionnaire for use during voir dire and a joint proposed verdict form no later than two (2) weeks before the PTC.

Civil Standing Order · p. 9
|SectionProposed Jury Questionnaire and Verdict Forms
Filing RequirementsMandatoryCivil cases

Objections to supplemental jury instructions due 1 week before PTC.

Court's wording

If the parties file supplemental sets of instructions not agreed upon, any objections shall be due no later than one (1) week before the PTC. Any objection shall contain a concise statement of argument concerning the objection, including citations to authority.

Civil Standing Order · p. 9
|SectionJury Instructions
Filing RequirementsMandatoryCivil cases

Email jury instructions in Word format to E-file Email.

Court's wording

In addition to filing the proposed preliminary and final jury instructions on the docket, the parties shall email the agreed-upon instructions and any supplemental instructions not agreed upon in Word format to the E-file Email.

Civil Standing Order · p. 9
|SectionJury Instructions
Filing RequirementsMandatoryCivil cases

Stipulations and agreements must be reduced to writing and marked as an exhibit. All facts that are not contested must be listed in a form suitable to be read to the jury.

Civil Standing Order · p. 10
|SectionStipulations
Filing RequirementsMandatoryCivil cases

Even if the parties stipulate to their admission, the Court will not receive into evidence any exhibits that have not been the subject of witness testimony.

Filing RequirementsMandatoryCivil cases

Email jury questionnaire and verdict form in Word format to E-file Email.

Court's wording

In addition to filing the proposed jury questionnaire(s) and verdict form(s) on the docket, the parties shall email the proposed jury questionnaire(s) and verdict form(s) in Word format to the E-file Email.

Civil Standing Order · p. 10
|SectionProposed Jury Questionnaire and Verdict Forms
Filing RequirementsMandatoryCivil cases

Any written objections to the other party’s proposed jury questionnaire and/or verdict form must be filed no later than one (1) week before the PTC.

Civil Standing Order · p. 10
|SectionProposed Jury Questionnaire and Verdict Forms
Filing RequirementsMandatoryCivil cases

Witness and exhibit lists due to Ms. Ortiz on first day of trial, all exhibits must be pre-marked.

Court's wording

On the first day of trial, each party shall provide Ms. Ortiz with two (2) copies of its witness and exhibit lists in the form specified in Civil Local Rules 16.1(f)(2)(c) and (d). All exhibits must be pre-marked on the first day of trial.

Civil Standing Order · p. 12
|SectionWitness and Exhibit Lists
Filing RequirementsMandatoryCivil cases

Demonstrative exhibits must be exchanged 7 days before trial, objections due 3 court days before trial.

Court's wording

No later than seven (7) calendar days before the start of trial, the parties shall exchange any demonstrative exhibits that will be used during opening statements or during the testimony of any expert witness. Any objections to the demonstrative exhibits must be filed no later than three (3) court days before the first day of trial.

Civil Standing Order · p. 12
|SectionDemonstrative Exhibits
Filing RequirementsImportantCivil cases

Do not file exhibits already on electronic docket; avoid duplication; use precise citations.

Document
Exhibits

Must include

  • Precise citations
  • Avoid duplication

Court's wording

Copies of documents already contained on the electronic docket must not be filed as exhibits. The parties must also avoid duplication of exhibits as much as possible. If the same exhibit is referred to in more than one motion noticed for the same day, the exhibit should be filed only once. Similarly, if more than one party refers to the same exhibit relative to a motion noticed for the same day, only one party should file the exhibit. The parties must use precise citations to assist the Court in locating all exhibits.

Civil Standing Order · p. 2
|SectionA. Generally Applicable Rules
Filing RequirementsImportantCivil cases

Factual matters or legal arguments raised by a party for the first time in their reply brief, unless directly in response to the opposition, may not be considered.

Civil Standing Order · p. 3
|SectionB. Rules for Noticed Motions
Filing RequirementsImportantCivil cases

If no oral argument requested, include phrase on caption; non-moving party may request oral argument.

Document
Motion
Placement
Caption

Must include

  • No oral argument requested

Court's wording

If the moving party desires to submit on the papers, the phrase “No Oral Argument Requested” should appear on the caption. Even if no oral argument is requested, the moving party must still obtain a hearing date from chambers, which will remain on calendar unless and until the Court vacates it by separate Order. If the moving party indicates that no oral argument is requested, the non-moving party may request that the Court hold oral argument in its opposition.

Civil Standing Order · p. 3
|SectionB. Rules for Noticed Motions
Filing RequirementsImportantCivil cases

AI tools not prohibited but unqualified reliance may result in sanctions.

Court's wording

Although the use of ChatGPT and other such generative artificial intelligence (“AI”) tools is not prohibited, unqualified reliance on such tools may result in filings “replete with misrepresentations and fabricated case law.”

Civil Standing Order · p. 6
|SectionD. Use of Generative Artificial Intelligence
Filing RequirementsNoteCivil cases

Settlement requires Notice of Settlement and Joint Motion to Dismiss within 28 days if no deadline set.

Court's wording

If a case settles, the parties must notify the Court and the assigned Magistrate Judge as soon as practicable by filing a Notice of Settlement. If the Magistrate Judge does not set a deadline for the filing of a Joint Motion to Dismiss, the parties must file a Joint Motion to Dismiss within twenty-eight (28) calendar days of the settlement.

Civil Standing Order · p. 7
|SectionV. Settlement
Filing RequirementsNoteCivil cases

Peremptory challenges use blind strike method.

Court's wording

The exercise of peremptory challenges will follow. Counsel will exercise their respective challenges using the “blind strike” method. That is, each side will exercise their peremptory challenges simultaneously and confidentially by marking those jurors they wish to excuse on the provided strike sheet.

Civil Standing Order · p. 10
|SectionJury Selection
Filing RequirementsNoteCivil cases

Counsel must meet and confer in advance of trial and waive the authentication requirement where the authenticity of a document is not at issue.

Filing RequirementsNoteCivil cases

Only exhibits referenced during trial will be provided to jurors for deliberations.

Court's wording

Absent extraordinary circumstances and regardless of any stipulation by the parties, only those exhibits which have been referenced/utilized during trial will be provided to the jurors for their use during deliberations.

Filing RequirementsNoteCivil cases

Voluminous documents or exhibits must be culled of unnecessary pages so that only relevant pages, or pages supplying context to the relevant pages, are admitted. Counsel should use summaries or charts to prove the content of voluminous documents, writings, or recordings that cannot be conveniently examined in court. See Fed. R. Evid. 1006.

Filing RequirementsNoteCivil cases

When referring to an exhibit, counsel should refer to its exhibit number whenever possible to keep a complete record.

Filing RequirementsNoteCivil cases

Counsel must move for admission before publishing exhibits to jury.

Court's wording

Before publishing an exhibit to the jury, counsel must move for admission of the exhibit and allow the Court to inquire whether the opposing side has any objection to the exhibit being received in evidence.

Filing RequirementsNoteCivil cases

If an exhibit is being used and counsel’s view is obstructed, counsel may relocate for better viewing without requesting permission from the Court.

Filing & Service rules

Electronic Filing Rules

The motion to seal, the proposed sealed document(s), and a proposed order in Word format, should be submitted for review directly to the Judge’s official email address, which is efile_Robinson@casd.uscourts.gov, as well as copy the Courtroom Deputy Clerk at Jessica_A_Ortiz@casd.uscourts.gov.

The motion to seal, the proposed sealed document(s), and a proposed order in Word format, should be submitted for review directly to the Judge’s official email address, which is efile_Robinson@casd.uscourts.gov, as well as copy the Courtroom Deputy Clerk at Jessica_A_Ortiz@casd.uscourts.gov.

Criminal cases

Page 2 | IV. Under Seal Filing Procedures C.

counsel shall email proposed orders on motions directly to the Judge’s official email address, which is efile_Robinson@casd.uscourts.gov, as well as copy the Courtroom Deputy Clerk at Jessica_A_Ortiz@casd.uscourts.gov. Proposed orders should be submitted simultaneously with the accompanying motion in Word format.

counsel shall email proposed orders on motions directly to the Judge’s official email address, which is efile_Robinson@casd.uscourts.gov, as well as copy the Courtroom Deputy Clerk at Jessica_A_Ortiz@casd.uscourts.gov. Proposed orders should be submitted simultaneously with the accompanying motion in Word format.

Criminal cases

Page 2 | II. Communications with Chambers

Filing Timing and Cure Windows

Supplemental jury instructions must be filed and served immediately upon need.

Supplemental instructions must be filed and served as soon as the need for them becomes apparent.

Criminal cases

Page 3 | VI.B. Jury Instructions

Proposed preliminary and final jury instructions due 1 week before in limine motion hearing unless otherwise ordered.

The parties must submit proposed preliminary and final jury instructions to the Court no later than one (1) week prior to the in limine motion hearing date, unless otherwise ordered by the Court.

Criminal cases

Page 3 | VI.B. Jury Instructions

five (5) court days before the date of trial, serve and file briefs on all significant disputed issues of law, including foreseeable procedural and evidentiary issues.

five (5) court days before the date of trial, serve and file briefs on all significant disputed issues of law, including foreseeable procedural and evidentiary issues.

Criminal cases

Page 4 | VI.C. [Disputed Issues Briefs]

Proposed verdict forms must be submitted on the day set for motions in limine.

Proposed forms of verdict must be submitted by email in Word format on the day set for motions in limine.

Criminal cases

Page 4 | VI.D. Proposed Voir Dire Questions and Verdict Forms

Proposed voir dire questions may be served and filed on the day of motions in limine.

Counsel may serve and file proposed voir dire questions on the day set for motions in limine.

Criminal cases

Page 4 | VI.D. Proposed Voir Dire Questions and Verdict Forms

Service and Proof of Service Rules

Government counsel must deliver the exhibit list to the Courtroom Deputy Clerk on the first day of trial.

Government counsel must provide a list of exhibits and give it to the Courtroom Deputy Clerk on the first day of trial.

Criminal cases

Page 5 | Exhibits

Courtesy Copy Requirements

Any document exceeding 20 pages (including attachments/exhibits) requires a file-stamped courtesy copy delivered to the Clerk’s Office within 24 hours of filing; filings with over 3 exhibits must have tabbed exhibits and a table of exhibits.

Unless otherwise ordered by the Court, for any document that exceeds twenty (20) pages in length (including attachments and exhibits), the filing party must deliver a file-stamped courtesy copy to the Clerk’s Office within twenty-four (24) hours after filing. If a filing has more than three exhibits, the exhibits must be tabbed and listed in a table of exhibits.

Criminal cases

Page 2 | III. Motions B. Courtesy Copies

Courtesy copies required for filings over 20 pages; single-sided preferred; exhibits tabbed and listed if over 3.

Parties must provide the Court with courtesy copies of any filings exceeding twenty (20) pages in length, including all attachments and exhibits, as soon as practicable after filing. Courtesy copies may be delivered by mail, express package delivery service, courier, or hand to chambers at 333 W. Broadway, Suite 1410, San Diego, CA 92101, or the Clerk’s Office at 333 W. Broadway, Suite 420, San Diego, CA 92101. The Court prefers courtesy copies of memoranda to be printed single-sided. If a filing has more than three (3) exhibits, the exhibits must be tabbed and listed in a table of exhibits.

Civil cases

Page 2 | A. Generally Applicable Rules

Sealing & Redaction Procedures

Must meet and confer before sealing based on another party's confidential designation.

If the moving party seeks to file a document under seal based on another party’s designation of the document as “confidential” under a protective order, the moving party must first meet and confer with the designating party to determine whether the designating party maintains that any portion of the document must be filed under seal.

Civil cases

Page 6 | 4. Motions for Leave to File Documents Under Seal

Proposed redactions must be highlighted or bracketed in sealed lodgment.

The proposed redactions must be evident (either highlighted or bracketed) from the sealed lodgment.

Civil cases

Page 6 | 4. Motions for Leave to File Documents Under Seal

Motions to seal require specific document description and declaration of compelling reasons.

Any party filing a motion for leave to file documents under seal must provide the Court with (1) a specific description of each document or portion of a document they seek to protect, and (2) a declaration showing sufficiently compelling reasons or good cause to protect those documents from disclosure.

Civil cases

Page 6 | 4. Motions for Leave to File Documents Under Seal

Sealing standard strictly applied; redactions must be narrowly tailored.

The standard for filing documents under seal will be strictly applied, and all proposed redactions must be as narrowly tailored as possible.

Civil cases

Page 6 | 4. Motions for Leave to File Documents Under Seal

Filing Bundling Requirements

Multiple motions by same party on same date must be briefed together in single 25-page memorandum.

When the same party (or more than one party represented by the same counsel) notices multiple motions for the same hearing date, the motions must be briefed together in a single memorandum of points and authorities not to exceed twenty-five (25) pages in length.

Civil cases

Page 3 | B. Rules for Noticed Motions

Summary judgment and Daubert motions consolidated on single hearing date; 25-page limit without leave.

Absent leave of the Court, all motions for summary judgment and summary-judgment- related Daubert motions will be set for a single hearing date in the interests of judicial economy and efficiency. Accordingly, pursuant to Civil Local Rule 7.1(h), no party (or more than one party represented by the same counsel) may file a memorandum exceeding twenty-five (25) pages without requesting from the Court an extension of the default page limits at least three (3) court days before the memorandum is to be filed.

Civil cases

Page 4 | B. Rules for Noticed Motions

If multiple parties are moving for substantially the same relief, they must make every effort to obtain the same hearing date for their motions. If multiple parties are moving for substantially the same relief or opposing a motion seeking substantially the same relief sought against them and noticed for the same hearing date, counsel must make every effort to coordinate and consolidate the briefing or use the notice-of-joinder procedure to avoid duplication in briefing.

If multiple parties are moving for substantially the same relief, they must make every effort to obtain the same hearing date for their motions. If multiple parties are moving for substantially the same relief or opposing a motion seeking substantially the same relief sought against them and noticed for the same hearing date, counsel must make every effort to coordinate and consolidate the briefing or use the notice-of-joinder procedure to avoid duplication in briefing.

Civil cases

Page 3 | B. Rules for Noticed Motions

All stipulations must be filed as joint motions.

All stipulations must be filed as joint motions.

Civil cases

Page 5 | 2. Joint Motions

Pre-Motion Conference Requirements

Motions in limine due 2 weeks before hearing, opposition due 1 week before hearing unless otherwise ordered.

Motions in limine are due two (2) weeks before the hearing, with any opposition due one (1) week before the hearing, unless otherwise ordered by the Court.

Criminal cases

Page 3 | VI.A. Motions in Limine

Meet and confer required before filing most motions; statement of compliance required in notice of motion.

Unless otherwise excused by the Court, before filing any motion except a motion in a case involving an incarcerated pro se party, the parties must meet and confer in good faith, preferably in person and not by email, to attempt to resolve the issue without involving the Court. The movant(s) must include a statement of compliance with this provision in their notice of motion. Failure to include a statement of compliance may result in the striking or summary denial of the motion.

Civil cases

Page 2 | A. Generally Applicable Rules

Motion hearing dates must be obtained from chambers before filing; papers due within 3 days of obtaining date.

Pursuant to Civil Local Rule 7.1(b), all dates for motion hearings must be obtained by calling chambers before filing any motion. Motion papers must be filed and served within three (3) calendar days of obtaining a motion hearing date from chambers. Failure to comply with this requirement may result in the forfeiture of the assigned hearing date.

Civil cases

Page 3 | B. Rules for Noticed Motions

Failure to timely oppose a motion may be construed as consent to granting.

An opposing party’s failure timely 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). Take note that the Court’s default briefing schedule differs from that appearing in the District’s Civil Local Rules. See infra Section III.B.2.

Civil cases

Page 2 | A. Generally Applicable Rules

Surreplies and notices of supplemental authority require leave of Court unless binding law changes.

Surreplies and notices of supplemental authority may not be filed without leave of Court, unless there is a subsequent change in binding law that is directly on point. Under these circumstances, the party may file a notice of supplemental authority that includes a copy of the order or opinion and any case-identifying information. Counsel may not include any argument in the notice; the Court will request supplemental briefing if necessary.

Civil cases

Page 3 | B. Rules for Noticed Motions

Civil motions scheduled for Thursday afternoons at 1:30 PM; oral argument typically held.

Civil motions will generally be scheduled for Thursday afternoons, beginning at 1:30 p.m. The Court typically hears oral argument on all civil motions. If the Court determines that a matter may be resolved on the papers without oral argument in accordance with Civil Local Rule 7.1(d)(1), the Court will issue an Order vacating the hearing.

Civil cases

Page 3 | B. Rules for Noticed Motions

If opposing parties intend to move for summary judgment, cross-motions and a consolidated briefing schedule are appropriate. As discussed through the meet-and-confer process, see supra Section III.A.1, one party (or more than one party represented by the same counsel) shall file its motion for summary judgment together with any summary-judgment-related Daubert motions by the deadline for pre-trial motions set by the Magistrate Judge in the operative scheduling order. Within three (3) calendar days of being served with the summary judgment motion, the opposing party (or more than one party represented by the same counsel) shall file an

If opposing parties intend to move for summary judgment, cross-motions and a consolidated briefing schedule are appropriate. As discussed through the meet-and-confer process, see supra Section III.A.1, one party (or more than one party represented by the same counsel) shall file its motion for summary judgment together with any summary-judgment-related Daubert motions by the deadline for pre-trial motions set by the Magistrate Judge in the operative scheduling order. Within three (3) calendar days of being served with the summary judgment motion, the opposing party (or more than one party represented by the same counsel) shall file an

Civil cases

Page 4 | B. Rules for Noticed Motions

Court prefers opposing party be served and given opportunity to oppose TRO motions.

The Court’s strong preference is for the opposing party to be served and afforded a reasonable opportunity to file an opposition.

Civil cases

Page 5 | 1. Temporary Restraining Orders

Adjournment & Extension Requirements

All requests for continuances should be made as soon as counsel become aware of the need for a continuance by contacting the Courtroom Deputy Clerk by email. If counsel stipulate to the continuance, a joint motion should be filed with chambers and a proposed order should be emailed. The joint motion must include the original date, the requested date for continuance (obtained from the Courtroom Deputy Clerk prior to filing), the grounds for continuance, and, if applicable, the basis for an exclusion of time under the Speedy Trial Act. All motions shall be filed no later than two (2) business days prior to the scheduled hearing. An acknowledgment of the next court date must be filed by all out of custody defendants simultaneously with the motion.

All requests for continuances should be made as soon as counsel become aware of the need for a continuance by contacting the Courtroom Deputy Clerk by email. If counsel stipulate to the continuance, a joint motion should be filed with chambers and a proposed order should be emailed. The joint motion must include the original date, the requested date for continuance (obtained from the Courtroom Deputy Clerk prior to filing), the grounds for continuance, and, if applicable, the basis for an exclusion of time under the Speedy Trial Act. All motions shall be filed no later than two (2) business days prior to the scheduled hearing. An acknowledgment of the next court date must be filed by all out of custody defendants simultaneously with the motion.

Criminal cases

Page 1 | II. Communications with Chambers C. Requests for Continuances

Telephonic appearance requires ex parte motion filed 3 court days before hearing.

Any party requesting to appear telephonically must obtain leave of the Court by filing an ex parte motion at least three (3) court days before the scheduled hearing.

Civil cases

Page 5 | 8. Telephonic Appearances

Opposing ex parte applications requires 24-hour notice of intent to oppose.

If a party intends to oppose an ex parte application, that party must file a notice as soon as practicable and within twenty-four (24) hours of the filing of the ex parte application stating their intent to oppose the ex parte application and the date on which the opposition will be filed.

Civil cases

Page 6 | 3. Ex Parte Applications

Continuance/extension requests require meet-and-confer, joint motion if agreed, ex parte if not, filed 3 court days before deadline.

Parties requesting a continuance of a court date or an extension of a deadline must meet and confer with all other parties who have made an appearance prior to contacting the Court. If all appearing parties reach an agreement, they should file a joint motion. If no other parties have appeared or the appearing parties fail to reach an agreement, the party requesting the continuance or extension must file an ex parte application complying with all applicable rules and satisfying the relevant legal standard. Absent extraordinary circumstances, any request for a continuance or extension must be filed no later than three (3) court days before the relevant date.

Civil cases

Page 7 | V. Settlement

Chambers Communication Rules

Letters and emails to chambers are prohibited, unless specifically requested by the Court. If letters and/or emails are requested, copies of the same shall be simultaneously delivered to all counsel.

Letters and emails to chambers are prohibited, unless specifically requested by the Court. If letters and/or emails are requested, copies of the same shall be simultaneously delivered to all counsel.

Criminal cases

Page 1 | II. Communications with Chambers A. Letters/Emails

Proposed jury instructions must be emailed to the Judge’s official efile address and cc the Courtroom Deputy Clerk.

The proposed preliminary and final jury instructions must be filed and submitted to the Court in Word format directly to the Judge’s official email address, which is efile_Robinson@casd.uscourts.gov, as well as copy the Courtroom Deputy Clerk at Jessica_A_Ortiz@casd.uscourts.gov.

Criminal cases

Page 3 | VI.B. Jury Instructions

Counsel must email the Courtroom Deputy Clerk to inquire before requesting waiver of Criminal History or Pre-Sentence Report preparation.

If the parties jointly wish to waive the preparation of a Criminal History Report or Pre-Sentence Report, counsel must email the Courtroom Deputy Clerk to inquire before making any such request.

Criminal cases

Page 3 | V.B. Immediate Sentencing

Proposed verdict forms must be submitted via email on the day of motions in limine.

Proposed forms of verdict must be submitted by email in Word format on the day set for motions in limine.

Criminal cases

Page 4 | VI.D. Proposed Voir Dire Questions and Verdict Forms

Chambers phone calls limited to scheduling; letters/faxes/emails prohibited unless authorized.

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, giving legal advice (including advice on procedural matters), assisting with filings, or speculating as to when an Order will be issued. Letters, faxes, and emails are prohibited unless otherwise authorized by the Court.

Civil cases

Page 1 | I. Communications with Chambers

Email technical terms/names to chambers one week before technical motion hearings.

For technical motions, the parties must send an email to chambers one (1) week prior to the hearing with a list of pertinent technical terms and/or proper names to assist the court reporter.

Civil cases

Page 5 | 7. List of Terms/Names

Observers must contact chambers one calendar day before hearing for dial-in info.

Any individual requesting to observe telephonically must contact chambers at least one (1) calendar day before the scheduled hearing to obtain the public dial-in information.

Civil cases

Page 5 | 8. Telephonic Appearances

Consent Form must be emailed, not filed on ECF, to efile_robinson@casd.uscourts.gov.

Pursuant to Section 2(h) of the ECF Manual, the fully executed Consent Form must NOT be filed on the docket with the joint motion for dismissal or notice of dismissal, but rather should be emailed to efile_robinson@casd.uscourts.gov (the “E- file Email”).

Civil cases

Page 7 | V. Settlement

Counsel must email the Courtroom Deputy Clerk as soon as possible if a disposition is scheduled in a case calendared for motions or trial.

Any time a case is calendared for motions and/or trial counsel for either side knows that a disposition is to take place, counsel has a duty to email the Courtroom Deputy Clerk at the earliest available time to inform the Court of the disposition.

Criminal cases

Page 2 | III. Motions C. Notice to Court of Disposition

Requests at start of day or after recess generally denied.

Requests to see the Court outside the presence of the jury when the Court is about to begin the day of trial or reconvene following a recess generally will not be granted.

Civil cases

Page 10 | Bench Conferences

Sidebar conferences disfavored; request at recess or end of day.

Sidebar conferences are disfavored. If counsel desire to speak to the Court outside the jury’s presence, counsel may request to do so at the start of a recess or at the end of the day.

Civil cases

Page 10 | Bench Conferences

No talking to opposing counsel in front of jury.

Refrain from talking to each other in the presence of the jury. If clarification on a matter is needed, please seek clarification from the Court and not directly from counsel.

Civil cases

Page 10 | Other

For docketing, scheduling, or calendaring matters, contact Courtroom Deputy Jessica Ortiz via phone at 619-321-0777; court personnel cannot give legal advice or discuss case timing/merits.

For docketing, scheduling, and calendaring matters, contact Courtroom Deputy Jessica Ortiz at 619-321-0777 or by email at Jessica_a_ortiz@casd.uscourts.gov. Court personnel are prohibited from giving legal advice or discussing the timing or merits of a case.

Criminal cases

Page 1 | II. Communications with Chambers B. Telephone Calls

Electronic filing questions should be directed to Clerk’s Office, CM/ECF Helpline, or CASD CM/ECF Helpdesk after consulting Local Rules and ECF Manual.

Any questions or concerns regarding electronic filing should be directed to the Clerk’s Office, the CM/ECF Helpline, or the CASD CM/ECF Helpdesk after first consulting the Local Rules and ECF Manual.

Civil cases

Page 1 | I. Communications with Chambers

About United States District Judge Todd W. Robinson

District Judge Todd W. Robinson was appointed to the Southern District of California by President Donald J. Trump in 2020.

Judge Robinson was born in 1967 in Jacksonville, Florida. He was nominated on February 13, 2020, confirmed by the Senate on September 16, 2020, and received his commission on September 18, 2020, filling the seat vacated by Marilyn L. Huff. He served as an operations officer with the Central Intelligence Agency from 2004 to 2005 and as a senior litigation counsel in the U.S. Attorney's Office for the Southern District of California.

Education

  • Georgetown University Law Center, J.D., 1993
  • University of California, Berkeley, B.A., 1989

Career

  • Trial attorney, Narcotic and Dangerous Drug Section, U.S. Department of Justice (1993–1997)
  • Assistant U.S. Attorney, Southern District of California (1997–2003, 2005–2020), including deputy chief, General Crimes Section (2007) and senior litigation counsel (2008–2020)
  • Operations Officer, Central Intelligence Agency (2004)

Courthouse: James M. Carter and Judith N. Keep U.S. Courthouse, 333 W. Broadway, San Diego, CA 92101 Chambers: Courtroom 14A Phone: (619) 321-0975

Chambers Staff

  • Courtroom Deputy: J. Ortiz, (619) 321-0777
  • Court Reporter: C. Kircher, (619) 239-4588
Common questions about Judge Todd W. Robinson's rules

Are courtesy copies required for Judge Todd W. Robinson?

Courtesy-copy rule applies when a filing is > 20 pages. Details: 1 copy, delivery within 24 hours. Any document exceeding 20 pages (including attachments/exhibits) requires a file-stamped courtesy copy delivered to the Clerk’s Office within 24 hours of filing; filings with over 3 exhibits must have tabbed exhibits and a table of exhibits.

View ruleSource: page 2, section III. Motions B. Courtesy Copies

Does Judge Todd W. Robinson require a pre-motion conference or letter before filing a motion?

Motions in limine due 2 weeks before hearing, opposition due 1 week before hearing unless otherwise ordered.

View ruleSource: page 3, section VI.A. Motions in Limine

What page or word limits apply to opposition brief before Judge Todd W. Robinson?

Judge Todd W. Robinson's rule states these limits: attorney: 25 pages. Oppositions to motions in limine and Daubert motions must be filed as single omnibus brief (max 25 pages).

View ruleSource: page 8, section VI. Final Pretrial Conference and Motions in Limine

What page or word limits apply to closing brief before Judge Todd W. Robinson?

Judge Todd W. Robinson's rule states these limits: attorney: 25 pages. Closing briefs (max 25 pages) may be filed instead of closing arguments within 4 weeks of transcript availability.

View ruleSource: page 8, section VII. Trial Procedures

What formatting rules apply to filings before Judge Todd W. Robinson?

Judge Todd W. Robinson's formatting rule includes file format docx. Proposed orders should be submitted simultaneously with the accompanying motion in Word format.

View ruleSource: page 2, section II. Communications with Chambers

What must be included with sentencing guideline recommendation filings before Judge Todd W. Robinson?

Parties must follow Criminal Local Rule 32.1 and ensure Sentencing Guideline recommendations are supported by the record.

View ruleSource: page 3, section V.C. Sentencing Materials

What must be included with exhibit filings before Judge Todd W. Robinson?

The rule requires exhibit list. Government counsel must submit an exhibit list to the Courtroom Deputy Clerk on the first day of trial, and all exhibits must be pre-marked that day.

View ruleSource: page 5, section Exhibits

How may parties contact Judge Todd W. Robinson's chambers?

Counsel must email the Courtroom Deputy Clerk to inquire before requesting waiver of Criminal History or Pre-Sentence Report preparation.

View ruleSource: page 3, section V.B. Immediate Sentencing

How does Judge Todd W. Robinson handle sealed or redacted filings?

Proposed redactions must be highlighted or bracketed in sealed lodgment.

View ruleSource: page 6, section 4. Motions for Leave to File Documents Under Seal

How do I request an adjournment or extension before Judge Todd W. Robinson?

Requests should be made at least 2 business days in advance when this rule applies before Judge Todd W. Robinson. The request must include original date, reason for request, and proposed rescheduled date. All requests for continuances should be made as soon as counsel become aware of the need for a continuance by contacting the Courtroom Deputy Clerk by email. If counsel stipulate to the continuance, a joint motion should be filed with chambers and a proposed order should be emailed.

View ruleSource: page 1, section II. Communications with Chambers C. Requests for Continuances

Does Judge Todd W. Robinson require motion papers to be bundled?

Yes. Judge Todd W. Robinson requires bundling for covered papers. All stipulations must be filed as joint motions.

View ruleSource: page 5, section 2. Joint Motions

Is electronic filing required before Judge Todd W. Robinson?

Yes. Electronic filing is required for the covered filings. counsel shall email proposed orders on motions directly to the Judge’s official email address, which is efile_Robinson@casd.uscourts.gov, as well as copy the Courtroom Deputy Clerk at Jessica_A_Ortiz@casd.uscourts.gov. Proposed orders should be submitted simultaneously with the accompanying motion in Word format.

View ruleSource: page 2, section II. Communications with Chambers

What filing deadlines apply to jury instructions filings before Judge Todd W. Robinson?

Proposed preliminary and final jury instructions due 1 week before in limine motion hearing unless otherwise ordered.

View ruleSource: page 3, section VI.B. Jury Instructions

What rule applies to service for exhibit list before Judge Todd W. Robinson?

Details: recipient: the clerk. Government counsel must deliver the exhibit list to the Courtroom Deputy Clerk on the first day of trial.

View ruleSource: page 5, section Exhibits
Complete rules summary for Judge Todd W. Robinson

For docketing, scheduling, or calendaring matters, contact Courtroom Deputy Jessica Ortiz via phone at 619-321-0777; court personnel cannot give legal advice or discuss case timing/merits.

Proposed orders should be submitted simultaneously with the accompanying motion in Word format.

All requests for continuances should be made as soon as counsel become aware of the need for a continuance by contacting the Courtroom Deputy Clerk by email. If counsel stipulate to the continuance, a joint motion should be filed with chambers and a proposed order should be emailed. The joint motion must include the original date, the requested date for continuance (obtained from the Courtroom Deputy Clerk prior to filing), the grounds for continuance, and, if applicable, the basis for an exclusion of time under the Speedy Trial Act. All motions shall be filed no later than two (2) business days prior to the scheduled hearing. An acknowledgment of the next court date must be filed by all out of custody defendants simultaneously with the motion.

Any document exceeding 20 pages (including attachments/exhibits) requires a file-stamped courtesy copy delivered to the Clerk’s Office within 24 hours of filing; filings with over 3 exhibits must have tabbed exhibits and a table of exhibits.

counsel shall email proposed orders on motions directly to the Judge’s official email address, which is efile_Robinson@casd.uscourts.gov, as well as copy the Courtroom Deputy Clerk at Jessica_A_Ortiz@casd.uscourts.gov. Proposed orders should be submitted simultaneously with the accompanying motion in Word format.

Counsel must email the Courtroom Deputy Clerk as soon as possible if a disposition is scheduled in a case calendared for motions or trial.

Counsel must email the Courtroom Deputy Clerk to inquire before requesting waiver of Criminal History or Pre-Sentence Report preparation.

Proposed preliminary and final jury instructions due 1 week before in limine motion hearing unless otherwise ordered.

Parties must follow Criminal Local Rule 32.1 and ensure Sentencing Guideline recommendations are supported by the record.

Motions in limine due 2 weeks before hearing, opposition due 1 week before hearing unless otherwise ordered.

Proposed jury instructions must be submitted in Word format to the Judge’s efile email and cc the Courtroom Deputy Clerk.

Supplemental jury instructions must be filed and served immediately upon need.

Proposed voir dire questions may be served and filed on the day of motions in limine.

A binder of exhibits must be provided for the bench.

Proposed jury instructions must be emailed to the Judge’s official efile address and cc the Courtroom Deputy Clerk.

Counsel should refer to exhibits by their exhibit number whenever possible.

Exhibits may be marked with stickers from the Clerk or electronically with case and exhibit numbers.

Proposed verdict forms must be submitted in Word format via email on the day of motions in limine.

Government counsel must submit an exhibit list to the Courtroom Deputy Clerk on the first day of trial, and all exhibits must be pre-marked that day.

Proposed verdict forms must be submitted via email on the day of motions in limine.

Proposed verdict forms must be submitted on the day set for motions in limine.

The motion to seal, the proposed sealed document(s), and a proposed order in Word format, should be submitted for review directly to the Judge’s official email address, which is efile_Robinson@casd.uscourts.gov, as well as copy the Courtroom Deputy Clerk at Jessica_A_Ortiz@casd.uscourts.gov.

Modified jury instructions must specify the modification and supporting authority.

The Court expects defense counsel, in any felony matter, to read, explain, and provide their client with a copy of the Standard Conditions of Supervised Release prior to sentencing.

Government counsel must deliver the exhibit list to the Courtroom Deputy Clerk on the first day of trial.

five (5) court days before the date of trial, serve and file briefs on all significant disputed issues of law, including foreseeable procedural and evidentiary issues.

Motions to seal must include a description of documents to seal, applicable legal standard and analysis, supporting affidavits/declarations, and the documents to be sealed.

Letters and emails to chambers are prohibited, unless specifically requested by the Court. If letters and/or emails are requested, copies of the same shall be simultaneously delivered to all counsel.

Proposed redactions must be highlighted or bracketed in sealed lodgment.

Electronic filing questions should be directed to Clerk’s Office, CM/ECF Helpline, or CASD CM/ECF Helpdesk after consulting Local Rules and ECF Manual.

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