Judge Paul M. Crisalli
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
Communication
Chambers
Phone
Court-wideChambers
Document Format Requirements4 rules
If a party’s submission exceeds the 500-page limit, you may request prior permission from Judge Crisalli’s bailiff to deliver the working copies in PDF format, either on disk or thumb drive (and delivered to the Judge’s Mailroom). Prior permission should be requested by sending an email to crisalli.court@kingcounty.gov.
- More than 500 pages
Deposition designations for trial must be prepared as one cooperative set using a color-coding convention (moving party highlights, opposing party notes objections and counter-designations in distinct colors), preferably on PDF.
- Deposition designations
Formatting
- •PDF format recommended (generally easiest) for designations and objections
Court's wording
Please follow these guidelines when designating deposition testimony for use at trial. The parties must cooperate to provide one set of deposition designations. It is generally easiest to make the designations and objections electronically on a PDF. Moving Party marks their designations with brackets / highlights in a particular color (e.g., yellow). Opposing Party notes their objections in text of a particular color (e.g., blue) on the page next to the highlighted portion to which they are objecting, referencing a rule or using a code for which a coding convention is provided. Opposing Party marks their counter-designations with brackets / highlights in a different color from that used by the moving party (e.g., green). Moving Party notes their objections in text of a different color (e.g., black) on the page next to the highlighted portion of the counter-designation to which they are objecting, referencing a rule or using a code for which a coding convention is provided.
A party may utilize hyperlinks in briefs if they determine it will assist the court.
Attachments or exhibits exceeding 25 pages must be numbered consecutively (without restarting) on the bottom center or right-hand corner of each page, and noncompliance can delay the hearing or matter.
- Exhibits
- Attachments
- More than 25 pages
Formatting
- •Consecutive numbering on the bottom center or right-hand corner of each document
Court's wording
Attachments or exhibits in excess of 25 pages, including attachments to motions, oppositions, replies, briefs, declarations, and affidavits, shall be numbered consecutively on the bottom center or right-hand corner of each document. This aids the court and the parties in navigating through the voluminous document. The number shall not restart for each attachment but shall run consecutively through all the attachments to the document. Failure to follow this rule can result in the Court delaying your hearing or matter until all parties have complied.
Document Filing Requirements12 rules
You must cite to these page numbers in all motions, oppositions, replies, and briefs. A party may include other citation information, such as exhibit numbers, corresponding exhibit pages or paragraph numbers, in addition to the consecutive page cite.
Any email request for a dispositive motion hearing must include the following: Case name and cause number; Nature of the motion(s) to be heard; and A preferred date range.
Submission of the this form is required by Judge Crisalli.
The email should—as succinctly and non-argumentatively as possible—describe the nature of the dispute and the positions of the parties. You must copy all parties on any email to the Court.
If you wish to have oral argument on a non-dispositive motion, please note the motion without oral argument and note "ORAL ARGUMENT REQUESTED" on the first page of your motion or opposition.
- Document
- Motion or opposition
- Placement
- First page
Pleadings referring to previously filed materials must reference the pleading by both document title and submission number within the court docket.
Court's wording
Please note: if your pleadings refer to materials which were previously filed within the court record, please reference the pleading by both the document title and submission number (eg: Declaration of Bob Jones, Sub. 5) within the court docket.
Please put in the upper right corner of the working copies the note date of consideration or hearing, Judge Crisalli’s name, and by whom the documents are being presented (“moving party,” “opposing party,” or other descriptive or identifying term).
If there are additional parties, complete the information for that party's witnesses on an additional page.
Counsel are to confer prior to the pretrial conference to determine time estimations for witness testimony and to prepare this document.
PETITIONER(S) Witness Name: Time Direct Exam: Time for Cross-Exam: Time for Re-Direct Exam: Total Time per Witness: Total time for Petitioner: RESPONDENT(S) Witness Name: Time for Direct Exam: Time for Cross-Exam: Time for Re-Direct Exam: Total Time per Witness: Total time for Respondent:
Use tenths of an hour for estimates, i.e., .1, .2, .5, 1.0, etc.
To request a copy of a recording, submit a completed CD Request Form to the Clerk’s Office.
Filing & Service rules
Electronic Filing Rules
Counsel should review LGR 30, which requires e-filing of most documents and requires attorneys to “promptly register to accept e-service via the Clerk’s eFiling application” unless a waiver is obtained.
Counsel should review LGR 30, which requires e-filing of most documents and requires attorneys to “promptly register to accept e-service via the Clerk’s eFiling application” unless a waiver is obtained.
Page 1 | Electronic Filing and Service by Attorneys
Judge Crisalli prefers electronic working copies be submitted to the Clerk using the Clerk's e-Filing Application under LCR 7(b)(4)(F)(i).
Judge Crisalli prefers to receive electronic working copies submitted to the Clerk using the Clerk’s e-Filing Application pursuant to LCR 7(b)(4)(F)(i).
Page 1 | Electronic Working Copies
Self-represented parties may optionally use the court's e-filing and e-service services.
Unrepresented parties have the option of utilizing these services.
Page 1 | Electronic Filing and Service by Attorneys
Filing Timing and Cure Windows
If you are striking a motion, please file a notice striking your hearing as soon as possible.
If you are striking a motion, please file a notice striking your hearing as soon as possible.
Page 1 | Settled Cases and to Strike a Motion
Marked deposition designations must be emailed as PDFs to the bailiff as early as possible, preferably at least three days before trial begins.
Provide the marked depositions via email as PDFs to the bailiff as early as possible (preferably at least three days before trial begins), and well in advance of intended use.
Page 1 | Deposition designations
Service and Proof of Service Rules
Counsel should review LGR 30, which requires e-filing of most documents and requires attorneys to “promptly register to accept e-service via the Clerk’s eFiling application” unless a waiver is obtained.
Counsel should review LGR 30, which requires e-filing of most documents and requires attorneys to “promptly register to accept e-service via the Clerk’s eFiling application” unless a waiver is obtained.
Page 1 | Electronic Filing and Service by Attorneys
Filing Bundling Requirements
The Court's practice is to hear multiple parties' dispositive motions on the same date in the interest of judicial economy.
If multiple parties are requesting a dispositive motion to be heard, it is this Court’s practice to hold them on the same date, in the interest of judicial economy.
Page 1 | Dispositive Motions and Hearing Requests
Chambers Communication Rules
The completed witness time estimates form must be emailed to the bailiff at Crisalli.Court@kingcounty.gov at least 2 days before the pretrial conference.
At least 2 days before the pretrial conference, email this completed form to the bailiff at Crisalli.Court@kingcounty.gov.
Civil cases
Page 1 | WITNESS TIME ESTIMATES
Parties must email the bailiff immediately if a case settles or if they wish to strike a filed motion from the court's calendar.
Please email the bailiff immediately if a case settles or if you wish to strike a motion you have filed from the court’s calendar. Trial courts are not notified when a case otherwise resolves through the ex parte department, or when a Notice of Settlement is filed within the Court record.
Page 1 | Settled Cases and to Strike a Motion
Working copies may not be emailed directly to the Court or the bailiff without prior permission.
Please do not email any working copies directly to the Court or to his bailiff without prior permission.
Page 1 | Electronic Working Copies
Discovery disputes requiring immediate resolution should be emailed to the Court rather than proceeding through ordinary motions practice.
If a discovery dispute arises that requires immediate resolution rather than the ordinary motions practice, please email the Court at crisalli.court@kingcounty.gov.
Page 1 | Court involvement in discovery
Dispositive motion hearing dates are requested by emailing the bailiff after first confirming the date with opposing counsel, and parties should contact the Court as soon as possible because timeslots fill months in advance.
Dispositive motions are typically heard on Fridays. Requests for hearing dates are accepted by emailing the bailiff at crisalli.court@kingcounty.gov. Judge Crisalli requires that you check your dates first with opposing counsel before scheduling any hearing to make sure that the date works for all counsel. Doing so reduces the need to reschedule hearings due to conflicts. Parties should contact the Court as soon as possible, as timeslots are limited and generally fill at least a couple months in advance.
Page 1 | Dispositive Motions and Hearing Requests
Junior Lawyer Participation Incentives
New attorneys may email the bailiff to request oral argument for practice on motions that normally do not require it, and the judge will consider the request.
If you are a new attorney and would like practice with oral argument on a motion which normally does not require it, please feel free to email the bailiff to request oral argument and Judge Crisalli will consider the request.
Page 1 | Requests for Oral Argument on Non-Dispositive Motions