Judge Haydee Vargas
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Deposition Designations
Court-wide- As Directed in Pretrial Order
Filings >= 500 pages
Court-wide- Hand Delivery
Adjournments
- The Court grants motions to continue a trial, other than the 28-day adjustment authorized by LCR 40(e)(1), only based on good cause. The motion should come with a declaration describing the nature of the case, the discovery and other trial preparation completed, what remains to be accomplished, and an explanation of why the case could not be completed within the original case schedule. The assertion that more time is needed for discovery or negotiation, without more, will not usually constitute good cause.
- Motions to change the trial date filed after the final date in the Case Schedule will not be granted except upon a showing of extraordinary circumstances with no alternative means of preventing a substantial injustice.
- Requests to change the trial date must be made by motion, filed and noted on a nine-day calendar.
- +1 more
Request must include
Communication
Chambers
Phone
Court-wideChambers
Document Format Requirements1 rule
Department 12 strives to be a paperless court. Judge Vargas requests a Word version of all proposed orders. You may submit your proposed order via the e-filing portal by using the e-working copies application.
- File type
- Word
- Proposed order
Document Filing Requirements11 rules
Any request for a dispositive motion hearing must be emailed to the court and include at minimum: Case number and caption in the subject line Names, phone numbers and email addresses of all counsel and parties Nature of motion
- Document
- Dispositive motion hearing request
Must include
- •Caption
- •Case number
In addition, Judge Vargas requires all parties and counsel to work together to complete the Witness Examination Time Form (188KB), and that form must be submitted together with other pretrial memoranda five court days prior to trial.
If the parties intend to use depositions in trial, designations and objections shall be marked according to the guidelines provided here.
All motions must be noted pursuant to LCR 7(b) and filed with the clerk.
Responses are required on all motions and should be submitted in accordance with LCR 7(b).
Parties must comply with all the requirements of KCLR 7 and any emergency orders in place when setting motions without oral argument. All motions should be submitted with proposed orders in Word format, submitted via eWorking Copies.
- Document
- Motion
Must include
- •Proposed order
All working copies shall also include a proposed order(s) in Word format.
- Document
- Working copy
Must include
- •Proposed order
- •Proposed order(s) in Word format
Follow the requirements of LCR 7. Do not send a stipulation and order to Judge Vargas' bailiff. If the parties agree on the request for a continuance, the moving party or parties should describe the motion as an "agreed motion" or a "stipulated motion" in the caption and set forth that agreement in the body.
- Document
- Continuance motion
- Placement
- Caption
A party may request oral argument on a non-dispositive motion by noting "Oral Argument Requested" in the upper right-hand corner of the working papers.
- Document
- Working copy
Should include
- •Oral Argument Requested
Court's wording
Note: Most non-dispositive motions do not require oral argument under the Civil or Local Rules. If a party would like to request oral argument, the motion should be noted pursuant to the applicable court rules, and you may request argument by simply noting in the upper right-hand corner of the working papers "Oral Argument Requested."
Please make sure Judge Vargas' name and the case information is clearly marked.
Working copies should have the judge's name and the date and time of the hearing in the upper right-hand corner of the first page of the motion.
- Document
- Working copy
- Placement
- First page
Should include
- •Judge name
Filing & Service rules
Electronic Filing Rules
Department 12 is a paperless court and reviews materials requests receipt all working copies submitted via eWorking Copies. The Court does not accept working copies of pleadings by email absent prior authorization.
Department 12 is a paperless court and reviews materials requests receipt all working copies submitted via eWorking Copies. The Court does not accept working copies of pleadings by email absent prior authorization.
Page 1 | Working Copies for Civil Motions
Judge Vargas also prefers that working copies of motions and declarations be submitted electronically via the Clerk's e-filing portal. Parties may submit paper working copies as provided in LCR 7(b)(4)(F)(iii). The Court does not accept delivery of working papers by email. Filing documents into KC SCRIPT does not route e-working copies to the Court. In addition to filing into KC SCRIPT, you must also submit e-working copies via the e-working copies application.
Judge Vargas also prefers that working copies of motions and declarations be submitted electronically via the Clerk's e-filing portal. Parties may submit paper working copies as provided in LCR 7(b)(4)(F)(iii). The Court does not accept delivery of working papers by email. Filing documents into KC SCRIPT does not route e-working copies to the Court. In addition to filing into KC SCRIPT, you must also submit e-working copies via the e-working copies application.
Page 1 | Proposed Orders and Working Papers
Department 12 is a paperless Court and prefers working copies submitted via eWorking Copies. Please make sure Judge Vargas' name and the case information is clearly marked. The Court does not accept working copies via email, absent prior authorization.
Department 12 is a paperless Court and prefers working copies submitted via eWorking Copies. Please make sure Judge Vargas' name and the case information is clearly marked. The Court does not accept working copies via email, absent prior authorization.
Page 1 | Criminal Motions and Sentencing Hearings
Self-represented parties may submit physical working copies to Judge Vargas' mailroom in C-203 at the King County Superior Courthouse, clearly marked for Judge Vargas.
Self-represented parties may submit physical working copies to the judge's mailroom in C-203 at the King County Superior Courthouse clearly marked for Judge Vargas.
Page 1 | Non-dispositive civil motions
Filing Timing and Cure Windows
Deposition designations and objections must be provided to the Court at least 5 days prior to trial along with all other pretrial materials.
Deposition designations and objections shall be provided to the Court at least 5 days prior to trial, along with all other pretrial materials.
Page 1 | Desposition Designations
All trial memoranda and other trial submissions are due no later than five court days prior to trial.
Pursuant to KCLR 40(d)(2), all trial memoranda and other trial submissions are due not later than five court days prior to trial.
Page 1 | Pretrial requirements
Service and Proof of Service Rules
Signed orders are delivered electronically to counsel or parties who have provided email addresses to the Court.
Copies of signed orders will be delivered to counsel or the parties electronically if email addresses have been provided to the Court.
Page 1 | Non-dispositive civil motions
Courtesy Copy Requirements
All submissions should be made to Judge Vargas, in care of the judges' mailroom. (See mailing address above.)
All submissions should be made to Judge Vargas, in care of the judges' mailroom. (See mailing address above.)
Page 1 | Pretrial requirements
Pre-Motion Conference Requirements
Judge Vargas encourages the parties to request a CR 16 or CR 26(f) pretrial conference on discovery issues, and may order the parties to participate in a pretrial conference in complex cases or when discovery is not proceeding well.
Judge Vargas encourages the parties to request a pretrial conference under CR 16 or CR 26(f) to consider matters such as The scope and timing of discovery. Limitations of discovery requests and depositions. Procedures and protocols for electronic discovery. Expert witness disclosures and discovery. Anything else that would promote the efficient resolution of the case. In complex cases or when it appears the parties are not working well in discovery on their own, the Court may order the parties to participate in a pretrial conference.
Page 1 | Court involvement in discovery
Adjournment & Extension Requirements
The motion should be served and filed and noted for consideration before the hearing judge two judicial days after filing in accordance with LCR 7(b)(4)(H).
The motion should be served and filed and noted for consideration before the hearing judge two judicial days after filing in accordance with LCR 7(b)(4)(H).
Page 1 | Civil Trial continuances
Motions to change the trial date filed after the final date in the Case Schedule will not be granted except upon a showing of extraordinary circumstances with no alternative means of preventing a substantial injustice.
LCR 40(e)(2) applies to motions filed after the final date to change the trial date in the Case Schedule. That rule provides that "the motion will not be granted except under extraordinary circumstances where there is no alternative means of preventing a substantial injustice." Given that stringent standard, parties should be mindful of the deadline to change the trial date and should make sure a motion filed after that date sets forth extraordinary circumstances that require a continuance to prevent a substantial injustice.
Page 1 | Civil Trial continuances
The Court grants motions to continue a trial, other than the 28-day adjustment authorized by LCR 40(e)(1), only based on good cause. The motion should come with a declaration describing the nature of the case, the discovery and other trial preparation completed, what remains to be accomplished, and an explanation of why the case could not be completed within the original case schedule. The assertion that more time is needed for discovery or negotiation, without more, will not usually constitute good cause.
The Court grants motions to continue a trial, other than the 28-day adjustment authorized by LCR 40(e)(1), only based on good cause. The motion should come with a declaration describing the nature of the case, the discovery and other trial preparation completed, what remains to be accomplished, and an explanation of why the case could not be completed within the original case schedule. The assertion that more time is needed for discovery or negotiation, without more, will not usually constitute good cause.
Page 1 | Civil Trial continuances
Requests to change the trial date must be made by motion, filed and noted on a nine-day calendar.
Requests to change the trial date should be by motion, filed and noted on a nine-day calendar.
Page 1 | Civil Trial continuances
Chambers Communication Rules
All case-related email to the court must be sent only to the courtroom address vargas.court@kingcounty.gov, and the judge's individual email address must not be used absent express invitation.
Parties are to refer to the Superior Court Email Policy prior to sending an email to the Court. The only address to be used by attorneys, self-represented litigants, or others who need to communicate with court staff about a case is the courtroom e-mail address: vargas.court@kingcounty.gov. Absent express invitation by the judge, the judge's individual email address must not be used.
Page 1 | Requests - Email
Dispositive motions are heard on Friday mornings. The scheduling party shall consult with opposing counsel(s) before contacting the court. Doing so reduces the need to reschedule hearings due to conflicts. Parties are encouraged to contact the court far in advance of trial to schedule a dispositive motion, as time slots are limited.
Dispositive motions are heard on Friday mornings. The scheduling party shall consult with opposing counsel(s) before contacting the court. Doing so reduces the need to reschedule hearings due to conflicts. Parties are encouraged to contact the court far in advance of trial to schedule a dispositive motion, as time slots are limited.
Page 1 | Dispositive motions and hearing requests
To arrange an informal discovery-dispute conference, email vargas.court@kingcounty.gov with a succinct, non-argumentative description of the dispute and each party's position, copying all parties.
If the parties agree to informal guidance or resolution, please email vargas.court@kingcounty.gov to arrange a conference. The email should – as succinctly and non-argumentatively as possible – describe the nature of the dispute and set forth each parties' position. (As always, you must copy all parties on any email to the court.)
Page 1 | Court involvement in discovery
Please contact the clerk by email to obtain information on pre-numbering exhibits.
Please contact the clerk by email to obtain information on pre-numbering exhibits.
Page 1 | Pretrial requirements
The Court typically allots 1 hour for dispositive motions. Additional time may be provided on hearings involving multiple parties or complex motions. Please advise the bailiff if additional time is being requested.
The Court typically allots 1 hour for dispositive motions. Additional time may be provided on hearings involving multiple parties or complex motions. Please advise the bailiff if additional time is being requested.
Page 1 | Dispositive motions and hearing requests