Pre-Motion Conference Requirements

Parties must confer with adversary before seeking TRO unless Rule 65(b) requirements are met.

Pre-motion conference required before filing motions, with specific exceptions.

Pre-motion conference requests for summary judgment motions must be made within 14 days after fact discovery closes.

Opposing party must respond via ECF (max 3 pages) within 3 business days.

Opposing party must submit response letter within 3 business days, limited to 3 pages.

If a party fails to respond to a claim, the party asserting the claim should promptly move for entry of default judgment if appropriate.

Sur-replies require prior court permission.

Opposition papers due within 30 days; reply papers due within 2 weeks.

Extensions and adjournments must be requested via letter-motion, not proposed stipulations or orders.

Two sets of pre-motion letters required for motions to dismiss.

Joint letter required within 14 days of discovery close for summary judgment motions.

Pre-motion letters required for most motions before Judge Willis except specified exemptions

Meet and confer required before filing motions or ex parte applications.

No party may file more than one motion pursuant to Fed. R. Civ. P. 56 regardless of whether such motion is denominated as a motion for summary judgment or summary adjudication.

Parties in every case must complete a Settlement Conference or ADR procedure before the Court will hold a final pretrial conference or trial.

Reply briefs not permitted for ex parte applications.

Motion without required certification may be stricken or summarily denied.

Counsel must meet and confer in real-time per Local Rule 7-3 before filing any motion; letters/email insufficient, non-compliance may result in strike/denial.

Parties must check closed motion dates on Judge Murillo’s Procedures and Schedules Page immediately before filing a motion; no need to clear date with Courtroom Deputy first.

Replies to motions in limine are not allowed and will be stricken.

Pre-motion conference required before filing motions in limine.

Mandatory pre-filing conference of counsel required for discovery motions, with format based on opposing counsel's county location; written electronic communications cannot substitute for the conference.

Cross-motions on same issues not allowed; parties must meet and confer to decide who moves.

Pre-filing meet and confer required for all motions and disputed matters, including pro se cases; must be by videoconference or in person.

Parties' counsel and any self-represented parties must meet and confer no later than 11 calendar days before the Final Status Conference to prepare the required trial documents and binders and to make a good faith effort to stipulate.

Parties must first meet and confer on discovery issues and, if unresolved, schedule an Informal Discovery Conference with the Court Reservation System or Courtroom Assistant.

Counsel and any self-represented parties with full authority to stipulate must participate in the informal discovery conference.

Before filing the joint exhibit list, the parties must meet and confer about stipulations or objections for each exhibit.

Before scheduling an IDC, parties to a discovery dispute must confer person-to-person in real time by phone, videoconference, or in person.

Parties must meet and confer before filing any motion in limine per Local Rule 3.57.

Motions to Compel Further require an Informal Discovery Conference scheduled by the moving party, who must confer with opposing counsel to obtain three available dates and notice the court.

Parties intending to file a summary judgment or summary adjudication motion must reserve a hearing date immediately, since reservation dates fill quickly and may not be available at least 30 days before trial.

Parties and counsel are ordered to meet and confer in good faith to informally resolve discovery disputes before involving the Court.

Law and motion hearings must be scheduled through the Court Reservation System (CRS), and reserving more than one hearing date for the same motion is prohibited.

Trial counsel must hold a real-time meeting well before the final status conference regarding submission of joint trial readiness documents.

Meet and confer before drafting MILs.

Daubert and Rule 12 pre-motion letters and responses are limited to three pages, responses are due within one week, and Rule 12 responses must address leave to amend.

For discovery or other non-dispositive motions, parties must try in good faith to resolve disputes in person or by phone before filing a motion.

Discovery motions under Rules 26-37 require an informal conference request before the motion will be heard.

In criminal cases, contemplated motions must be raised at a status conference or by a written pre-motion conference request stating grounds before filing.

Pre-motion conference required for most motions except specified exceptions.

Pre-motion conferences are required only for non-venue Rule 12 motions.

After the Rule 12 pre-motion decision order, plaintiffs have 21 days to amend as of right; amendments after that require leave under Rule 15(a)(2).

Pre-motion request letters are limited to 3 pages, and response letters are also limited to 3 pages and due within 7 days.

In summary judgment pre-motion practice, responses are due in 15 business days, 56.1 reply statements in 10 business days, and reply letters are not allowed.

Proposed summary judgment briefing schedule must be submitted within 30 days after close of discovery or the right is waived.

A party seeking a restraining order must identify a mutually agreeable hearing time with the adversary so the Court can hear from both sides before deciding temporary injunctive relief.

A party may bypass timing aspects of these practices and file within federal-rule deadlines if delay would forfeit a substantive right, but must include an explanatory basis.

Before bringing a discovery dispute to the Court, parties must first meet and confer in person or by videoconference; letters, emails, or phone calls alone are insufficient.

Moving party's counsel must confer with opposing counsel about a mutually convenient hearing date before noticing any motion.

Case management conferences are held via Zoom webinar unless noted otherwise; all other hearings are in person unless noted or leave is granted.

Motions in limine must be filed at least 14 days before the final pretrial conference; oppositions at least 7 days before; reply briefs are prohibited; argument at the final pretrial conference.

Discovery disputes require meet and confer in person or by phone before filing any discovery-related letter.

Before submitting the Exhibit List, the parties must meet and confer and attempt to stipulate to the admissibility of each exhibit.

The parties must meet and confer and agree on numeric exhibit designations.

Civil motions are heard only on Wednesdays at 9:00 a.m. in Courtroom 3, 5th Floor, 280 S. First St, San Jose, CA, by reservation only.

Civil motions require reservation for Wednesday 9:00 a.m. hearings in San Jose.

Sanctions motions under Rule 37 must follow Civil L.R. 37-4, not expedited discovery dispute procedure.

Pre-filing conferences must be attended in person; remote appearances not permitted.

Sanctions motions require compliance with meet-and-confer requirements first.

Motions to withdraw guilty/nolo pleas must be filed within 14 days of plea hearing; objections to Magistrate Judge’s R&R must be filed within 14 days of R&R execution; hearing must be scheduled within 30 days of filing.

Amicus briefs require leave by motion with the brief attached as an exhibit; party responses to amicus briefing are freely allowed.

Civil motion responses due 21 calendar days after filing; replies due 7 days after response, no sur-replies without permission.

Ex parte restraining order applications will not be considered by the Court unless all FRCP 65(b) requirements are satisfied.

Motions to Dismiss, Sever, and for Separate Trial must be specific and brought to the Court’s attention at least 30 days before jury selection.

Parties must first obtain leave of court by motion before filing a surreply or sur-surreply, and unauthorized surreplies and sur-surreplies will be struck.

The opposing party should promptly submit a responsive letter of similar length identifying any disagreement. Do not submit a reply letter.

Responses to dispositive and non-dispositive motions must be filed within 21 days of the motion's filing.

When a party believes an opponent has misused its privilege log, it may request that the Court make in camera inspection of not more than twenty documents. Bring any request by letter not to exceed approximately three single-spaced pages. Lead counsel must confer in good faith to resolve the dispute prior to any letter. In the letter, identify the documents for review, state the grounds for challenge, specify the conference between lead counsel, and summarize the results. This letter establishes consent to ex parte contact between the Court and the party’s opponent regarding the nature and verity of the asserted privilege. Each party may freely submit only a single letter requesting in camera inspection. Submit any letter at least sixty days before the end of discovery or promptly upon receipt of any later privilege log.

Motion responses due 21 days after motion filing; replies due 7 days after response; no sur-replies permitted without court leave.

Parties must discuss electronic discovery disputes in person/phone/video before seeking court intervention; resisting parties must have a person to discuss burdens.

Pre-motion letter required for discovery/scheduling dispute motions, must include nature of dispute, issues, and contested matters; lead counsel must confer before involving court.

Discovery motions require a prior discovery conference unless the movant obtains leave of Court, and the Court will strike any non-compliant discovery motion.

Failure to comply with meet-and-confer results in denial.

Before filing a sealing motion, the parties must meet and confer to agree on the narrowest possible sealing order.

Meet-and-confer required before filing sealing motions.

Mandatory meet and confer required before bringing any matter to court

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

Party seeking amendment must provide proposed amended pleading and explanation to opposing counsel.

Meet and confer required before contacting court; in-person if same district, phone/video if different districts.

Joint statement of disputed/undisputed facts required 10 days before hearing, filed with reply brief.

Discovery motions may not be filed until pre-motion conference is held, unless leave of court is obtained.

In order to ensure that civil litigation is “just, speedy, and inexpensive” as required by Fed. R. Civ. P. 1, attorneys and parties must collaborate in the discovery process. Attorneys and pro se litigants should review the topics set forth in this Checklist at the initial conference required under Fed. R. Civ. P. 26(f).

Motion hearing dates must be obtained from law clerk before filing; sur-replies require ex parte leave.

Landlord-tenant motions, defendants' claims of exemption, reconsideration, re-hearing, attorney's fees, entitlement, tax costs, summary judgment (except credit card/collection cases), 57.105, emergency motions, and case management or status conferences may not be scheduled for or heard on the Motion Calendar.

To coordinate a hearing, confer with opposing counsel or the self-represented litigant, then submit the notice of hearing and schedule through courtMAP once a date is coordinated.

The court will not notice hearings; the moving party must confer with the opposing party and notice the hearing under the Rules of Judicial Administration.

Motions for rehearing/reconsideration must be set on the special set calendar for at least 30 minutes.

Unilateral setting of hearings is prohibited unless Court approval is first obtained.

Before scheduling and noticing a Motion Calendar or Special Set hearing, the movant must meet and confer with opposing counsel to try to resolve the issues.

A law firm may set no more than two motions per day per office, even across separate files, and add-on hearings are not permitted.

Motion calendar hearings are scheduled through CourtMAP on Tuesday, Wednesday, and Thursday at 9:30, 10:00, or 10:30 a.m., and the moving party must first coordinate the date/time with opposing counsel based on the Court's availability.

Special set hearings must be coordinated with opposing counsel in CourtMAP and approved by Chambers, with virtual sets on Zoom, on-camera appearance for testimony, and no doubling up of time slots.

All cases must attend mediation before trial unless the judge has ruled otherwise.

Before scheduling a special set hearing, the movant must confer with opposing counsel or the self-represented litigant to coordinate a date, then schedule via CourtMAP.

A case management conference is required before trial can be set; attorneys may schedule it on CourtMAP, while self-represented litigants should call chambers.

Meet and confer required before filing most motions; declaration of conference required.

Motions in limine that do not comply with the applicable requirements, including the certification of conferral (LCR 7(d)(4)) or the word limit (LCR 7(e)(5)), without prior permission of the Court may be summarily stricken.

Opposition to extension motions due within 2 business days.

Before filing motions in limine, parties must make a good-faith meet and confer with the opposing party and comply with LCR 7(d)(5).

Joint statement (max 3 pages) required before discovery conference.

Opposition papers for 28-day motions must be filed within 21 days.

Same-day motions include stipulated, joint, unopposed motions, and specific motion types.

Pretrial motions (except dispositive) must follow LCR 37 individualized procedure.

Meaningful conferral required before filing dispositive motions with 3 business day buffer.

Should the case be referred to a Magistrate Judge for discovery-related issues, no opposed discovery motions shall be filed until the Party has contacted the Magistrate Judge and has been informed of that judge’s procedures for resolving discovery disputes.

The Court will deny or strike a discovery motion if the parties fail to meet and confer in good faith.

Parties must note all motions, except those specifically listed in LCR 7(d)(1), 7(d)(2), 7(d)(4), 7(d)(5), and 7(o), including motions to exclude expert testimony for failure to satisfy Fed. R. Evid. 702/Daubert, for consideration no earlier than 21 days from filing.

Before filing any motion, attorneys must comply with Local Rule 2.119(B), make reasonable and diligent personal-contact attempts, and request concurrence.

Motions in limine must be heard by one week before trial unless an issued scheduling or pretrial order governs.

After a dispositive motion is filed, the Court issues a scheduling order, and the moving party must praecipe the assigned hearing date.

Objections to orders entered under the 7-day rule must be praeciped for hearing.

Should any party object to a designation of any information, documents, or things as “Confidential,” the parties or the producing party shall, on an expedited basis, meet and confer in a good faith attempt to reach an agreement regarding the status of the information, documents, or things. If an objection is not thereby resolved, a party may bring the dispute before the Court on an expedited basis for a determination.

A party must file a motion to request an evidentiary hearing before the judge.

An attorney seeking to withdraw within 30 days of a trial or evidentiary hearing must file a motion.

Motions to enter judgment cannot be heard on return-of-judgment dates and must be noticed for regular motion call.

The Court may dismiss a motion if the moving party fails to attend the pre-motion conference.

To request an evidentiary hearing on an issue involving a factual dispute, file a motion before the Judge.

Proposed exhibits should be stipulated to prior to trial or evidentiary hearing, with objections raised by formal motion and noticed for no later than the Court’s last regular motion call preceding the trial/evidentiary hearing.

A moving party’s failure to attend the pre-settlement conference may result in dismissal of the motion.

The parties may not file a memorandum of law without leave.

Replies are optional and may be ruled on before filing; a reply may be filed without leave only within seven days, on newly raised issues, and without a proposed order, while sur-replies require leave.

For a motion to strike, the opposing party must file a responsive letter within seven days, and the moving party may reply within three days thereafter; the parties must request a teleconference by the reply date.

Motions to amend pleadings and motions to strike pleadings must follow the discovery dispute procedure in Paragraph 6(g).

An opposing party may file a letter explaining its opposition no later than 48 hours before the conference or argument.

For a motion to amend, an opposing party must file a responsive letter within 7 days after the motion, and the moving party may file a reply within 3 days thereafter; the parties may also request a teleconference by that date.

Letter filing deadline: 72 hours before conference, max 4 pages, double-spaced, 12pt font

Should counsel find they are unable to resolve a discovery matter or a dispute relating to a protective order, 2 the moving party (i.e., the party seeking relief from the Court) shall file a “[Joint] Motion for Teleconference to Resolve [Protective Order or Discovery] Dispute.” The suggested text for this motion can be found in Magistrate Judge Fallon’s section of the Court’s website in the “Forms” tab, under the heading “Discovery Matters–Motion to Resolve Discovery Dispute.” The Court will thereafter order a discovery telephone conference and deadlines for submissions.

A discovery motion filed without compliance with the specified procedures will be denied without prejudice to renewal.

After complying with Local Rule 7026-1(a)'s meet-and-confer obligations, parties may use docketed letters instead of formal motion papers for the listed discovery and case-administration matters.

Should counsel find, after good faith efforts—including verbal communication among Delaware and Lead Counsel for all parties to the dispute—that they are unable to resolve a dispute regarding the initial drafting of a protective order, the parties involved in the dispute shall file a joint letter in substantially the following form:

Should counsel find it will be necessary to apply to the Court for a protective order specifying terms and conditions for the disclosure of confidential information, counsel should confer and attempt to reach an agreement on a proposed form of order and submit it to the Court within ten days from the date of this Order. Should counsel be unable to reach an agreement on a proposed form of order, counsel must follow the provisions of Paragraph 3(g) above.

A telephone conference with Judge Wolson is required before filing any responsive brief for a discovery motion.

Sur-reply briefs may not be filed unless the Court grants leave upon a party's motion.

Reply briefs require leave of court, filed within 5 days with email courtesy copy.

Parties must attempt to resolve expert report disputes promptly; unresolved disputes must be raised via the Discovery Dispute Procedure or the objection is waived.

After counsel have met and conferred, they may present discovery disputes to the court via letters emailed to chambers and copied to the other side without filing formal motions unless otherwise directed by the court.

Pre-motion certification required for Rule 12 motions that opposing counsel was given opportunity to cure.

Opposition to summary judgment due in 21 days; reply/surreply due in 10 days; no leave required.

Merely reporting unavailability or reasonable efforts is insufficient; motion will be denied.

Meaningful conference required before threshold motions, except for pro se parties.

Joint Rule 26(f) report required at least one day before initial pretrial conference.

Motions that fail to meet meet-and-confer requirements will be denied.

Before filing a discovery motion to compel, lead counsel must meet and confer in good faith and the party must contact the law clerk with opposing counsel to arrange a telephone conference with the Court; the Court will decide whether further briefing is required.

Motions to modify, vacate, alter, or extend CMC orders are only heard on CMC dates, not Regular or Emergency Motion Calls.

Emergency motions require presenting a copy to court staff for approval before scheduling, and must comply with local Rule 2.2.

A piggy-backed motion may be heard on a previously scheduled date only if separately scheduled with the Case Coordinator at least one week beforehand.

Contested motions require a briefing schedule including a Clerk's Status date; Clerk's Status is held via Zoom on Wednesdays at 9:00 AM; hearing date set at Clerk's Status; motion stricken if movant fails to appear.

A motion to move a contested proceeding from a remote hearing to an in-person courtroom hearing must be heard at least two weeks before the proceeding.

Piggy-backing a motion onto an existing hearing requires prior leave of the law clerk, courtesy copies, and proper notice of the motion to all parties.

Motions to consolidate must be presented on the Presiding Judge of the Chancery Division’s calendar.

No judgment motion may be filed or noticed, and no judgment entered, until case management is stricken by the Court (4331), applying to residential and commercial properties, and noticing judgment motions before a continued case management conference is strictly prohibited.

Contested motions that are not piggy-backed must be spindled through Odyssey to obtain a presentment date and time.

Emergency motions must meet two criteria, be scheduled with the coordinator, and include specified documents submitted to the law clerk via email.

A piggy-backed motion that is not properly set and scheduled through the Case Coordinator will not be heard.

Motions must be filed with and scheduled through the Clerk of the Circuit Court to be heard.

Counsel for both sides must meet and confer to try to resolve instruction disagreements no later than 10 calendar days before trial.

The parties must meet and confer on all motions in limine before filing.

The parties must meet and confer at least seven days before the Pretrial Order is due to discuss their drafts and seek agreement where possible.

Failure to meet the telephonic-hearing requirements results in personal appearances unless the Court grants a motion for leave to appear telephonically.

Before seeking judicial intervention, a party challenging a confidentiality designation must confer directly and in good faith with the designating party, explain the basis for the challenge, and the designating party must respond within 5 business days.

Motions in limine must be thoroughly briefed; the Court will set a briefing schedule.

Parties must conduct Rule 26(f) planning conference.

Motions in limine must be filed with the pretrial order or on a court-specified date, and the parties must meet and confer before filing them.

Replies may not be filed unless the Court orders otherwise.

Parties challenging confidentiality designation must confer directly with designating party in good faith before judicial intervention.

Substantial exhibit objections must be filed as motions in limine.

Counsel primarily responsible for representing each party at the settlement conference must participate in the status hearing or call.

Sur-reply papers and motion practice by correspondence are prohibited without express permission from the Court.

A discovery-dispute motion may not be filed until a pre-motion conference has been requested and held as required.

No motion concerning the underlying residential foreclosure action may be filed with the RJI or while the action remains pending in the FSCP.

Before filing a discovery motion, counsel must make a good-faith effort to resolve the dispute and must then notify the court by a letter of no more than three pages describing the dispute and resolution efforts.

A preliminary conference must be scheduled if no acceptable executed stipulation is timely uploaded or if a party requests one.

A motion challenging the Note of Issue or trial readiness may not be filed until a pre-motion conference has been requested and held.

A discovery-related motion, including a discovery-violation dismissal motion or cross-motion, may not be interposed or electronically filed until a pre-motion conference has been requested and held.

Cross-petitions may not be filed without the Court’s permission.

The Court must address a properly submitted pre-motion conference request within two business days after receiving a complete submission.

A motion filed before the required pre-motion conference may be denied unless good cause justifies obtaining relief before the conference.

A party seeking a motion must file and upload through NYSCEF a pre-motion conference request on notice to all other parties that states the anticipated motion’s basis and is no more than two pages.

The MDPM Part must give NYSCEF notice of the conference date and time, and the conference ordinarily must be held in person unless another format is designated.

Juvenile motions must be in writing, be heard before jeopardy, and ordinarily be heard at least five court days after notice unless the Court orders otherwise; the moving party must clear the hearing date with the juvenile court clerk before filing.

A party invoking the identified privilege or good-cause discovery exception must proceed by noticed motion heard before the first readiness conference.

Except in domestic-violence cases, parties must meet before a Request for Order hearing to discuss all issues, attempt settlement in good faith, and exchange relevant hearing materials.

A request for relief from the governing rules must be submitted to the Court with a showing of good cause before the relevant papers are filed.

Juvenile motions must be written, heard before jeopardy and, absent a contrary court order, at least five court days after notice; the moving party must clear the hearing date with the juvenile-court clerk before filing.

Parties in the listed Civil and Probate Departments must participate in the Discovery Facilitator Program before filing a motion to compel discovery, including under CCP Section 1987.1, unless an exception applies or the Court orders otherwise.

A party invoking a statutory privilege exception or a good-cause discovery exception must proceed by noticed motion and have it heard before the first readiness conference.

Except in domestic violence cases, parties must meet before the hearing on a Request for Order to discuss issues, attempt settlement, and exchange relevant documents and information.

Except in domestic-violence cases, parties must meet before the Request for Order hearing, discuss all issues, attempt settlement in good faith, and exchange hearing materials.

Except in domestic-violence cases, parties must meet before a Request for Order hearing, make a good-faith settlement attempt, and exchange relevant hearing materials.

For writs of mandate other than those naming the Department of Motor Vehicles, the filing party must provide the petition and proposed order to the assigned department and obtain a status conference establishing the hearing date and briefing schedule.

The assigned judge will set a status conference during designated ex parte hours to establish a hearing date and briefing schedule for an in-scope writ of mandate.

File a motion with the Clerk before scheduling it online or contacting the office for hearing time.

direct that before moving for an order relating to discovery, the movant must request a conference with the court;

UMC hearings are non-evidentiary, limited to ten minutes per case with five minutes per side, and allow one motion per slot.

Before filing a motion, the movant must make a good-faith effort to confer with the opposing party; failure to include the required certificate may result in the motion or hearing being stricken.

Before filing a non-dispositive motion, the movant must confer in good faith and include the specified certificate of conferral in the motion.

A motion for rehearing or reconsideration may not be set for hearing without the Court’s prior permission.

Hearing time will not be granted until the CMPO is filed, and the court will not hold time for motions that are not ripe.

Parties must attend mediation before setting a Temporary Relief Hearing.

A motion must be filed before its hearing is scheduled.

A party must first work cooperatively with the other party to resolve a dispute before filing a motion to compel.

Before filing a non-dispositive motion, the movant must confer in good faith with the opposing party or counsel to try to resolve the motion’s issues.

Coordinate a hearing with the opposing party before noticing it.

A discovery motion requires a prior pre-motion conference request and good-faith efforts to resolve the dispute, unless the Court directs otherwise.

Before involving the court or filing a discovery motion, parties must meet and confer through a genuine exchange rather than a one-sided letter or threat.

A request for a discovery-related conference must use the Pre-Motion Discovery Conference Request Form and be emailed to chambers.

Absent extremely unusual circumstances causing significant prejudice, opponents must receive at least 24 hours' advance notice of an OSC seeking a TRO or other emergency relief and be told of the right to be heard.

Counsel must make every effort to resolve discovery disputes with the opposing party before engaging in discovery motion practice.

A discovery motion may not be submitted unless the required conference has occurred.

Motions and orders to show cause ordinarily are decided on the filed submissions without oral argument unless the court directs otherwise.

A cross-motion set beyond the original motion's return date does not adjourn the original motion.

No discovery motion may be filed or served without prior written permission from the court.

Before filing a motion, the moving party generally must serve written notice stating the intended motion and requested relief and offering a good-faith attempt to resolve the matter, subject to emergency and significant-prejudice exceptions.

Before making or filing any motion, moving counsel must arrange a conference call with the opposing party and the Court to discuss the issues and possible resolution.

Before filing any discovery motion in this part, the requesting party must submit the pre-motion discovery conference form and confer with the court about the matter.

A mandatory meet-and-confer, including in matters involving pro se litigants, must occur before requesting a hearing on unresolved issues.

Before filing a Rule 1.380 motion to compel seeking attorney’s fees, counsel must confer in good faith with opposing counsel and any pro se parties to resolve the discovery issue.

Counsel must confer in good faith before a hearing, and failure to do so may result in cancellation, summary denial, or sanctions.

Before seeking disposition of a filed motion, counsel with settlement authority must complete a meaningful in-person or telephone conference under Administrative Order 2012-03-01.

Before a Motion in Limine is set for hearing, counsel—not support staff—must confer with opposing counsel by telephone or in person concerning every evidentiary matter raised.

Discovery motions must be set for hearing, submitted with an agreed order, or submitted under Section A(4)(b); merely filing the motion is insufficient.

A party may not file a discovery objection without an accompanying motion.

Before filing any motion in the Business Court, the moving party shall confer with counsel for the opposing party in a good faith effort to resolve the issues raised by the motion, and shall file with the motion a statement certifying that the moving party has conferred with opposing counsel and that counsel have been unable to agree on the resolution of the motion.

Filing a protective-order motion without attempting to obtain an immediate hearing does not by itself protect against pending discovery.

The failure to comply with the “meet and confer” requirement will result in the Court declining to consider the motion.

Discovery motions, motions to compel, and motions for protective orders must be filed and set for hearing within a reasonable period.

Before setting an ex parte or short-matter hearing, satisfy the Administrative Order 2012-03-01 meet-and-confer requirement and include a Certificate of Compliance in the notice of hearing.

A discovery motion may not be filed unless the party complies with 22 NYCRR §§ 202.7 and 202.20-f.

A discovery motion requires a prior court conference, a written request of no more than two pages stating the meet-and-confer history and basis for the motion, and any response must be filed within two business days and may not exceed two pages.

A request for pendente lite relief will be addressed only at the preliminary conference and must be accompanied by a motion.

No discovery motion may be filed without the express permission of the court.

Before presenting an OSC seeking a temporary restraining order or other interim relief, the movant must contact the Part Clerk to obtain a date and time, except for ex parte order-of-protection applications.

A party may not argue for denial of summary judgment solely based on failure to negotiate and file a joint statement of facts.

When a matrimonial OSC is filed before a preliminary conference is scheduled, the conference will occur on the OSC return date, counsel must appear with clients, and counsel must confer and comply with the cited rule beforehand.

In matrimonial cases, a preliminary conference must be held within 45 days after filing the Request for Judicial Intervention.

CPLR 3213 motions do not require a joint statement, and competing Rule 19-a statements may not be submitted for them.

Surreply papers will not be accepted without leave of court.

A party seeking immediate injunctive relief when an OSC is signed must appear in person with all affected adversaries or prove proper notice, and must contact the part clerk to schedule the appearance.

An unauthorized discovery motion or one lacking demonstrated good-faith efforts will generally be denied, and email alone is insufficient to establish those efforts.

Parties must request a conference before filing any discovery motion.

The court will schedule an in-person appearance for every compliant discovery motion, while a noncompliant discovery motion will be denied without prejudice.

No motions in this Part may be submitted without oral argument, and every motion must be orally argued without exception.

Parties should resolve discovery disputes through informal procedures and must seek a court conference before filing any discovery-related motion.

Before filing a discovery-related motion, counsel must make good-faith efforts to resolve the dispute and then seek a conference with the Court.

When court intervention is necessary after a good-faith discovery effort, the parties must file an NYSCEF letter requesting an in-person discovery conference and briefly describe the issue.

Each discovery action must include a preliminary conference and compliance conference, additional status conferences as needed, and the parties must consult before each such conference.

When good-faith efforts fail to resolve a discovery dispute, the parties must apply for a pre-motion conference addressing the dispute and related discovery issues.

Email exchange alone is insufficient unless the affirmation documents the communication history or the other party’s refusal to communicate by telephone, virtually, or in person.

A discovery motion filed without a prior Rule 14 Conference will be held in abeyance until the conference occurs.

Before filing a discovery motion, a party must request a pre-motion conference by filing a letter request to NYSCEF and emailing it to the listed chambers address.

All motions must be brought by Order to Show Cause, and parties must request a conference before filing motion papers; good-faith consultation with one another is strongly suggested.

Counsel must discuss the specified case issues and confirm receipt and review of opposing-party discovery; if the conference is incomplete at Calendar Call, it must occur before trial, and jury selection will not begin until completion is confirmed.

In a residential foreclosure case where the owner filed a responsive pleading, mediation must occur before the summary-judgment hearing.

Before the court rules on a motion in limine, the parties must meet and confer and inform the court which items remain disputed.

If counsel cannot obtain the client’s signed consent to withdrawal, the motion must be set for a hearing.

For non-dispositive motions, interested attorneys must meet and confer before filing, before scheduling a hearing, and at least 10 days before the hearing.

Requests to appear using communication technology must be made by motion.

A meet and confer with three attempts is required before setting a motion hearing, except for motions for summary judgment.

A motion for judicial default will not be signed without a hearing.

The attorney scheduling a hearing must arrange the conference, and opposing counsel must respond promptly to inquiries and communications.

If the defendant appears on the day a bench warrant is issued, the Court may recall the warrant and reinstate the case bonds.

Daubert motions are heard virtually, but a party may request to appear in person by submitting a motion and order.

If the Court determines an emergency exists, it will schedule the hearing unilaterally.

Before seeking court involvement in a dispute, parties must personally consult and make a good-faith effort to resolve it; email does not qualify, and possible resolutions should be discussed before the hearing.

The Court may permit full briefing under Rule 26(d)(1), but parties may not undertake full briefing without advance permission.

Discovery and disclosure disputes that could be addressed under Rules 26(c) or 37(a) must first follow Rule 26(d)’s expedited procedure.

A trial date will not be set until ADR or mediation, discovery, and dispositive motions are complete; if they are incomplete before the trial-setting conference, the parties must seek to vacate and reset it.

The Court will not schedule, reschedule, or vacate a hearing without a filed motion.

Before seeking a motion to compel, parties must make every effort to confer in good faith, including speaking by telephone; correspondence alone is insufficient except in extraordinary circumstances.

Counsel must make a good-faith effort to resolve discovery disputes and demonstrate that they met and conferred before bringing the dispute to the Court.

Before asking the court to resolve a dispute, parties must personally consult or meet and confer in good faith; email alone does not qualify as personal consultation.

Before seeking court involvement in a discovery dispute, parties must satisfy applicable personal-consultation requirements and make a good-faith effort to resolve the dispute; email does not count as personal consultation.

Before submitting a discovery dispute, parties are expected to confer in good faith through an actual conversation, not merely exchange voicemails or emails.

Counsel must make a good-faith effort to resolve discovery disputes before bringing them to the Court.

The parties should discuss possible resolution of issues before the hearing.

If the parties cannot resolve an issue through discussion, they must file a motion and schedule a hearing; the court will not consider letters on contested issues.

The parties are strongly encouraged to review the Trial Order and the deadlines set out within. Parties are to confer at least seven (7) days prior to Pre-Trial Conference (PTC) to complete the required documents to tender to the court as identified in the Order.

All known motions and disputes, including unresolved deposition or video-testimony objections, must be heard before the PTC or they will be deemed waived.

Do not set criminal motions for rehearing for hearing; submit them directly to the judge with a cover letter, and the Court will decide whether a hearing is necessary.

All motions, including Daubert, summary judgment, and in limine motions, must be resolved by the Case Management Order deadline and scheduled for hearing before that deadline.

If the parties cannot agree on an issue, file the appropriate motion and set it for hearing.

The prosecutor and defense counsel must confer before trial to resolve disputes over proposed jury instructions.

Schedule discovery-related matters before the general magistrate unless there is a written objection, and submit an Order of Referral.

Before filing a discovery-related motion, the moving attorney must confer or make a reasonable good-faith effort to confer with opposing counsel to resolve the dispute.

Before filing an emergency motion, the moving attorney must confer in good faith with opposing counsel to try to resolve the issue.

The Court may waive mediation after a verified motion and hearing based on hardship, emergency, or a history of domestic violence that would compromise mediation.

No oral or written motions, including motions to continue, will be heard at docket sounding.

The moving party must meet and confer with opposing counsel or the opposing side before setting a hearing.

Substantive motions and requests will not be heard at Calendar Call without specific permission from the Court.

Court-set pretrial conferences must be attended by the parties or counsel; failure to attend results in sanctions.

The moving party must coordinate with opposing counsel or the opposing side before setting a Motion Calendar hearing.

For special set hearings (15 minutes or longer), the motion must first be filed with the Clerk of Court, and chambers does not accept ex parte communication.

A law firm, including all affiliated attorneys, may not set more than two motions on a single day unless the motions involve separate cases.

Motions for rehearing must not be set for hearing unless the Court instructs the party to do so.

Calendar Call is limited to trial readiness and negotiated pleas; no other substantive motions or requests will be heard at Calendar Call without specific permission from the Court.

Motions for summary judgment must be scheduled for hearing and heard prior to Calendar Call.

Unless a new lawyer is substituting, a motion to withdraw must be set for a UMC hearing with notice to all parties.

Motions subject to legal sufficiency review (e.g., suppress, dismiss, post-conviction) must be provided to the Court before a hearing is set, and the Court may rule on sufficiency before setting any hearing.

Parties must attend mediation before setting any temporary relief matter for an evidentiary hearing.

Before requesting a special-set hearing, the motion must be docketed, availability must be cleared with interested parties, and an email request must be sent to the Division.

A motion requiring an evidentiary hearing cannot be decided without holding that hearing.

Motions for rehearing, clarification, or new trial must not be set for hearing unless the court directs otherwise.

Counsel must make reasonable efforts to communicate in person or by telephone and pursue reasonable compromises to resolve or narrow disputes before seeking court intervention.

Before filing and serving a notice of hearing, the noticing attorney must attempt to resolve the matter and certify that the attempt was made in good faith.

A Notice of Hearing may be filed only after the moving party receives the Judicial Assistant's confirmation email containing the hearing date and time.

Within 45 days after the entitlement determination, the parties must confer item by item about disputed fees and costs and attempt to resolve the dispute through good-faith negotiations.

Every Daubert motion must be scheduled and heard before trial begins.

Email or other written communications may be used, but if they do not resolve the matter, counsel must make reasonable efforts to speak in person or by telephone before filing and serving the notice of hearing.

The parties and their experts must hold a remote conference to discuss the specific fee and cost objections no later than five days before Calendar Call.

Before setting a matter on the motion calendar, the noticing party must attempt to resolve it and certify the good-faith attempt.

Counsel must reconfer after all responses and replies are filed so that only issues requiring court resolution are set for hearing.

Parties must make a good faith attempt to resolve discovery disputes before seeking court intervention.

Before seeking dismissal of indirect or willful infringement claims before fact discovery, a party must meet and confer about dismissing the allegations without prejudice.

Yes. The party seeking to file additional briefing should file a motion seeking such leave.

Scheduling matters in civil cases must be requested by motion.

The parties must meet and confer before filing a motion to seal documents.

Before filing a motion to compel discovery, lead counsel must meet and confer in good faith and the party must contact the Court’s law clerks to summarize the dispute and the parties’ positions.

Meet and confer required before dismissing indirect/willful infringement claims.

Motion to compel requires meet and confer plus contact with law clerk

Before an early motion to dismiss indirect or willful infringement claims, the movant must first meet and confer with the opposing party.

Leave of court is required to file a sur-reply.

Transfer motions have fixed filing and briefing deadlines, and late filing requires good cause plus leave of court.

Witnesses must testify remotely via motion filed at least 7 business days prior, with equipment testing and technical support coordinated.

Pre-motion letter must include basis and citations.

Before filing specified motions (dismiss, more definite statement, strike, remand, venue change, compel arbitration, judgment on pleadings), a party must submit a 3-page single-spaced pre-motion letter stating the basis and citations; adversaries respond within 7 days (max 3 pages); no reply letters or affidavits/exhibits unless directed by the Court.

Discovery motions require leave of Court; parties must first meet and confer in person, via video, or by telephone (email exchanges are insufficient) to resolve discovery disputes.

Pre-motion letter (max 3 single-spaced pages) required before specified civil motions; adversaries have 7 days to respond (max 3 pages).

A pro hac vice application without consent must be filed as a formal motion.

Subpoena enforcement/quash motions involving third parties exempt from meet-and-confer but require leave of Court.

TRO requests require prompt hearing and pre-hearing conference.

Formal motions require prior leave from the court, except for Rule 12 motions, timely remand motions, and those expressly permitted.

Formal motions require prior leave from court except for Rule 12 motions, timely remand motions, and those expressly permitted.

Formal motions require prior leave of Court except Rule 12 motions, timely remand motions, and motions expressly allowed by the Case Management Order.

Party anticipating expert exclusion argument must raise issue to Court to determine motion filing timing relative to summary judgment.

Parties must file a pre-motion letter for summary judgment motions before filing and before setting briefing schedule, with a status/settlement conference, exempting pro se cases.

Parties must meet and confer before filing a motion in a civil case.

A pre-filing conferral must involve a substantive, good-faith conversation in person, by telephone, or through communication technology; an exchange of ultimatums is insufficient, and any assertion of failed conferral must detail at least three attempts during the preceding month.

(v) direct that before moving for an order relating to discovery, the movant must request a conference with the court;

Before filing a discovery motion or scheduling a hearing, the parties must confer in person or by communication technology and make a good-faith effort to resolve the dispute by agreed order.

Counsel for both parties must meet no later than 12 days before the summary judgment hearing to confer, prepare the hearing stipulation, review the record, and narrow issues, and moving-party counsel must schedule the meeting.

Pleadings may not be amended after the final pretrial conference without court approval.

Any timing issue identified in the stipulation must be raised in an appropriate written motion filed and heard before the summary judgment hearing.

Before filing a motion to compel discovery, the moving party must confer in good faith with the non-moving party to attempt to resolve the dispute.

Parties must meet and confer before filing any motion.

A claim that opposing counsel was unavailable does not excuse the conference; the motion must describe attempted conference, the moving party must promptly contact opposing counsel after filing and supplement the motion, and non-moving counsel must promptly respond and provide conference availability.

Counsel must conduct a substantive meet-and-confer before scheduling a hearing on motions in Circuit Civil Division F, subject to the listed motion-type exceptions.

A mandatory meet-and-confer process is required before scheduling a hearing on most motions, with exceptions for specified motion types.

The motion must be filed before setting a hearing.

A motion will not be set for oral hearing without an estimated hearing time.

Parties must consult with one another before filing a discovery-related motion; consultation between lead attorneys is preferred.

Before the Court considers a motion requiring a conference, the movant must confer directly and person-to-person with opposing counsel.

Default judgment motions based on unpaid assessments or deed restriction violations must be set for oral hearing.

The listed motions are considered on submission, except that unliquidated-damages default motions require an oral hearing; the Court may require an oral or phone conference hearing in certain circumstances.

Emergency hearings are granted only if the parties have conferred about the matter.

Excess proceeds hearings are set for Tuesdays at 3:00 PM and require an appearance.

Motions to withdraw as counsel must be set for oral hearing unless the client agrees and signs an acceptance of the notice letter.

Parties are expected to make every reasonable effort to resolve discovery disputes before seeking judicial intervention, and may file a motion to compel if those efforts fail.

Summary judgment motions are heard by submission unless a party requests a hearing.

The first Verified Motion to Retain may be filed without a hearing; subsequent motions to retain must be set for oral hearing.

The parties must meet and confer at least 21 days before the pretrial conference, and no party may file a motion in limine without first making a good-faith effort to resolve or narrow the evidentiary issue.

After responsive papers are filed, the moving party must arrange a pre-hearing meet-and-confer, personally or by telephone, and all parties must negotiate in good faith; harassment and domestic-violence matters are exempt, and noncompliance may result in attorney’s fees or sanctions.

Before the hearing of any motion, petition, or application other than a pro hac vice application or a motion to withdraw as counsel, counsel and pro se persons must confer in good faith to try to eliminate or narrow the hearing.

Except for pro hac vice applications and motions to withdraw counsel, counsel must hold a good-faith conference at least three calendar days before the hearing and submit a declaration describing the conference and agreements at least one day before the hearing.

The party preparing a written order must make a good-faith effort to confer with the other parties before submitting it to the court.

A party may not file a motion in limine without first making a good-faith effort to resolve or narrow the evidentiary issue with the opposing party.

The parties must meet and confer at least 35 days before the Pretrial Conference to determine whether evidentiary issues can be resolved by stipulation.

Unless the Court orders otherwise, counsel and pro se persons must meet in person or by video, and the parties must participate in an informal discovery conference before filing any discovery motion if the dispute is unresolved.

A party must make a good-faith effort to resolve the evidentiary issue with the opposing party before filing a motion in limine.

The parties must begin meeting and conferring well before trial as part of Judge Fineman's pretrial process.

Parties are encouraged to hold an informal discovery conference before filing a motion to compel or another discovery motion.

In general civil cases, parties and non-parties are encouraged to hold an informal discovery conference before filing a discovery motion.

A movant must confer in good faith with the opposing party or counsel to resolve the motion’s issues and file the required detailed certification or face denial without prejudice and cancellation of the hearing.

Represented parties must complete the required Rule 1.202 conferral before filing a motion unless exempt.

All motions must be heard before the pretrial conference.

If requested, counsel must agree to the filing of an amended complaint instead of filing the motion.

Mediation is required before a motion for summary judgment may be scheduled unless the court grants prior leave to proceed.

Attorneys and parties must make genuine good-faith efforts to resolve discovery disputes before filing a motion to compel.

Before filing a motion, the moving party must confer with opposing counsel in a good-faith effort to resolve it and file a certification that the conference occurred without agreement.

A written motion must be filed with the Clerk before requesting or setting a hearing.

Pretrial motions generally must be written and heard before the pretrial conference unless otherwise specified.

A written motion should be filed before requesting a motion-hearing date and time from the judicial assistant.

Before filing a motion to dismiss for failure to state a claim, counsel must give written notice, identify the alleged reasons, and stipulate to an amended complaint if requested.

Attorneys and self-represented parties must attend a case management conference unless the court excuses them in advance.

When a TRO is requested, the Court schedules a conference with counsel before any formal hearings, and all counsel must attend unless urgency precludes notice to opposing counsel.

Upon a TRO request, Judge Hardy schedules a conference as soon as counsel have appeared, requires all counsel to attend unless urgency precludes notice, and rarely grants ex parte TROs.

Civil matters on the Thursday Chambers Calendar are decided without oral argument only after being fully briefed, and prevailing counsel must prepare the written order per EDCR 7.21.

Counsel must meet and discuss exhibits per EDCR 2.67, ensure exhibits comply with EDCR 2.27, and attend the Court-set pre-trial conference during the week before trial.

The EDCR 2.47 conference between counsel must occur at least one week before motions in limine are filed.

Remote appearances are not allowed for arraignments, calendar calls, and sentencing without the Judge's prior approval.

A Rule 2.47 conference between counsel must be held at least one week before filing motions in limine.

Hearing Calendar matters (Prove Ups, Preliminary Injunctions, TROs, Show Cause Hearings, certain Petitions) require prior approval from the Judicial Executive Assistant and/or Judicial Law Clerk, are scheduled Tuesdays at 10:00 a.m., and are coordinated through Master Calendar.

Counsel must meet and discuss exhibits prior to calendar call, and the plaintiff is responsible for scheduling the EDCR 2.67 conference.

Counsel must appear in person for Motions to Dismiss and Motions for Summary Judgment; remote appearances are not permitted.

All matters must be set on the Department’s regular motion calendar.

Rule 16 conferences are mandatory and held from chambers with email notice to all parties, but counsel may request an in-person conference, which will be placed on the regular Civil Law & Motion calendar.

Defense counsel may move to quash a warrant issued on or before the trial date by scheduling a motion to quash the warrant before the Chief Criminal or Chief MRJC Judge. The defendant shall be present at the hearing or the motion shall not be considered, absent extraordinary circumstances.

Before motions to compel discovery or for contempt, counsel must hold a meet-and-confer conference in person or by telephone — email is not a substitute.

Motions with oral argument (summary judgment, restraining orders, preliminary injunctions, and class certification) are heard on Fridays in one-hour calendar slots.

Motions set for oral argument must be confirmed with the bailiff.

To schedule a dispositive motion hearing with oral argument, parties must first check with opposing counsel and then email the bailiff with the case name, cause number and type of hearing requested; hearings are set on Friday mornings with typically an hour for argument.

Parties must comply with all KCLR 7 requirements when setting motions without oral argument.

Counsel must give advance notice to the court and opposing counsel before presenting a motion for an exceptional sentence.

Parties must confer with opposing counsel to confirm date availability before scheduling any hearing.

Dispositive motions are heard on Fridays. Check with the opposing counsel/party before scheduling any hearing in order to make sure that the date is mutually agreeable. Doing so reduces the need to reschedule hearings due to conflicts.

Follow KCLR 7 when setting motions without oral argument; the court considers non-dispositive motions without oral argument.

Parties should confer with opposing counsel before confirming a hearing date to ensure it is mutually agreeable.

A scheduling party should consult the opposing party or counsel before contacting the court.

A temporary restraining order for another justice will be signed only with that justice's or law clerk's approval.

An Order to Show Cause is available only for genuine urgency, a required stay, or a statutory mandate; otherwise, relief must be sought by a Notice of Motion under CPLR § 2214.

An Order to Show Cause will be granted only for genuine urgency, when a stay is required, or when required by statute.

Discovery motions require prior consultation with the law clerk, including an initial email copying opposing counsel and describing the dispute, before the law clerk determines whether a conference or motion practice is required.

A temporary restraining order in a case assigned to another Justice may be granted only with prior approval from the IAS Justice or the IAS Justice’s law clerk.

Sur-reply papers and merit-addressing correspondence are prohibited without advance express permission from the Court and will not be considered.

An in-person preliminary conference must be scheduled within 45 days of receipt of the RJI, with pleadings and an emailed case summary submitted before the conference.

Unless the Court orders otherwise, motions for summary judgment must be timely made under CPLR §3212(a).

Discovery-dispute motions will not be scheduled until the underlying issues have been conferenced with Justice Martoche or Michael Pastrick.

Motions will be heard on the scheduled return date of that matter unless an earlier date is required.

All motions will ordinarily be decided on the submitted papers.

Counsel is expected to consult directly about discovery disputes, and a good-faith letter alone is insufficient.

All Motions for Summary Judgment filed in the 37th District Court are heard in the 37th District Court rather than in Presiding Court.

Each MTE hearing is limited to 15 minutes.

Hearings on these motions must be set per local rules at 8:30 a.m. for non-evidentiary matters or 9:00 a.m. for evidentiary matters.

Before requesting a hearing, counsel must confer with the opposing party about the dispute, with a minimum of three legitimate conferral attempts required on non-emergency issues.

Parties must meaningfully confer before an MTE hearing, including exchanging the proposed order and proposed changes, or risk the MTE being reset or being ordered to confer in a Zoom breakout room.

All hearings before a Visiting Judge must follow these procedures and must be assigned by the Presiding Judge.

Only motions to enter, to reconsider, to clarify, for new trial, and to set aside an order may return to the Visiting Judge who originally ruled the matter.

Attorneys and self-represented litigants must confer before requesting any hearing regarding both the subject of the hearing and available dates and times, and this requirement is enforced.

The parties and all agents with settlement authority must attend mediation unless the Court grants leave excusing attendance.

The parties have 30 minutes total to present and respond to a summary judgment motion at the hearing.

Before setting any MTE, parties must contact the court for available dates and confer with the opposing pro se party or counsel on those dates before filing the setting.

No jury trial may be held until all contested issues have been referred to mediation, which is discretionary, may be requested by the parties, and for which the Court will appoint a mediator if the parties cannot agree.

Counsel with settlement authority must confer before hearing scheduling, include a Certificate of Compliance in the Notice of Hearing, and the counsel scheduling the hearing is responsible for arranging the conference.

Counsel must confer in good faith, certify the unresolved conferral, and attach the correspondence before filing a motion to compel or for a protective order; email alone is insufficient, and noncompliance may result in striking the motion.

All motions must be submitted to the Sumter Clerk of Court and conferred upon between the parties before hearing time may be requested.

I HEREBY CERTIFY that a lawyer in my firm with full authority to resolve this matter attempted in good faith to contact opposing counsel in person or by telephone on:

A mandatory meet-and-confer process applies before scheduling a hearing on motions in the circuit civil division, except for the listed motion types.

The first compliance option requires a certificate stating that a lawyer with settlement authority had a substantive pre-hearing conversation with opposing counsel but could not resolve the motion.

Counsel must meet and confer after filing and serving the detailed Daubert motion, and file a certification of that meeting by the Notice of Hearing.

All unstipulated motions in limine must be filed in accordance with the Court's motion practice procedure order.

Counsel must obtain Court approval and contact the Judge's office before cross-noticing additional motions for a previously scheduled hearing.

Counsel—not support or paralegal personnel—must confer by telephone and/or in person on every requested motion in limine before the court sets it for hearing.

The parties must confer and attempt to resolve by agreement the issues raised in their in limine motions.

Before filing a discovery-dispute motion, attorneys are expected to attempt to resolve the dispute without court intervention.

Objections to Rule 30(b)(6) topics must be resolved through conference or hearing before deposition.

Discovery motions (compel, protective order, sanctions) require Court authorization.

Personal conferral (in person/phone) required unless opposing party refuses after reasonable time; moving party must advise court of refusal.

Failure to confer in good faith is an independent basis to deny discovery motion relief; opposing party's failure to confer is considered for fee awards if motion is granted.

Parties must confer in good faith before seeking discovery relief, with at least one personal communication (in person, videoconference, or telephone).

Sanctions motions must be filed in writing and cannot be resolved via Informal Discovery Hearing.

Non-compliant discovery motions will be denied.

Discovery motions require good-faith conference certification and have expedited briefing with shortened page limits.

No hybrid hearings - all counsel must participate via same method (Zoom or in-person).

Rule 37(a) motions to compel discovery may be resolved via Informal Discovery Hearing.

Joint motions exempt from pre-filing procedures.

A party may petition the Court for formal discovery only after exhausting informal means.

A party may petition for formal discovery only after exhausting informal discovery means.

Before any hearing, counsel and the parties must meet and confer in good faith to try to resolve all issues.

Motions in Limine will be heard at the Readiness Conference.

Unless the Court orders otherwise, it sets trial, Readiness Conference, and motion-related dates at arraignment; the Readiness Conference is 1 to 14 days before trial, and pretrial motions are set for hearing by that conference.

Before filing motions in limine, parties and counsel must meet and confer in good faith; merely exchanging letters is insufficient, and failure may result in summary denial.

Before filing a motion in limine, the parties or counsel must comply with the statutory notice provisions of Code of Civil Procedure section 1005 and Local Rule 4.3.

The making and timing of pretrial motions and oppositions in Superior Court are governed by applicable statutes, Rules of Court, and California Rule of Court 4.111.

Discovery motions must address specific items remaining in dispute after informal requests; boilerplate motions are disfavored, and counsel must meet and confer in good faith.

The court expects counsel to attempt to resolve discovery differences before filing a motion and, if one is filed, again before the hearing.

A party must request an informal discovery conference with the court before filing a discovery motion.

Before filing any discovery motion, the moving party must schedule a discovery conference with all parties and the Court.

Scheduling an Informal Discovery Conference stays the deadline for filing discovery motions in complex civil matters.

Before the IDC, the parties must meet and confer to impasse by phone or videoconference; the moving party must coordinate the meeting, and the opposing party must respond to a scheduling attempt within three business days.

The discovery conference order excludes self-represented discovery disputes, expert discovery disputes, and motions to compel discovery when no responses have been provided, while all other discovery disputes, including motions to quash, are covered.

For pending motions, all counsel and unrepresented parties must make a good-faith meet-and-confer effort, and the moving party must arrange the conference no later than four calendar days before the hearing.

Before the informal discovery conference, the parties must meet and confer to impasse by phone or videoconference, with the moving party coordinating it and the opposing party responding to scheduling attempts within three business days.

Informal discovery conferences are required except in self-represented matters, expert discovery, and motions to compel filed where no responses were provided.

Within five (5) court days of filing the discovery motion and prior to any party filing an Opposition to a discovery motion in this action, the moving party shall schedule a video informal discovery conference (hereinafter IDC) with all parties and the Court. The purpose of the IDC is to try and resolve the discovery issues without the necessity of a motion and or sanctions. At the IDC, the issues of the discovery dispute will be discussed as well as possible referral of the case out to Judicial Referee (hereinafter JR), pursuant to CCP 639. Timely objections to JR, including but not limited to, economic hardship, will be heard at this time only. (Be prepared with appropriate financial documentation/declarations at this time of the IDC or request an extension at the time of the IDC). Referral to JR is relatively rare but nonetheless, is a possibility after the conference depending on circumstances.

The propounding and responding parties must participate in the discovery conference by telephone.

No briefing is allowed for the IDC, but counsel (either jointly or separately) should lodge (not file) a one page statement of the issues in dispute in Department S-17 no later than the day before the IDC.

Before filing any discovery motion, the moving party must schedule a telephonic informal discovery conference with all parties and the Court.

Oppositions to extension motions must be filed by 5:00 p.m. the business day after the motion is filed.

Pre-motion conference required for dispositive motions; 4-page notice and 1-week response required.

Motions in limine must be filed by a specified date, with responses and replies due on specified dates.

Court leave is required before filing any discovery motion; failure to comply may result in the motion being stricken.

Discovery-related motions require a prior telephone conference with the Court and opposing counsel.

Discovery motions require prior telephone conference with court and opposing counsel.

Sur-replies require prior leave of the Court.

Motions in limine must be fully briefed with specific timing: 21 days before JPTS for motion, 14 days for opposition, 7 days for reply.

Motions in limine must be fully briefed with Joint Pretrial Statement; opposition due in 5 days, reply in 2 days.

The Court does not accept omnibus motions in limine. Parties should file separate motions in limine for each discrete issue. The motions should be numbered in sequential order.

Parties must confer in good faith before seeking Court involvement in a discovery dispute.

Discovery-dispute motions require leave of Court before filing.

At least three court days before the informal discovery conference, counsel must email a joint dispute letter limited to five pages and single-spaced.

A party intending to file a discovery motion must confer with the opposing party about IDC scheduling and provide mutually agreeable dates to the judge’s clerk.

Counsel must complete meet-and-confer efforts through an in-person, video, or telephone meeting and reach impasse before requesting an informal discovery conference; email exchange alone is insufficient.

If a will offered for probate has face alterations by interlineation or deletion, the personal representative must obtain a court determination of entitlement before seeking final distribution.

Before filing any motion in limine, the parties must meet and confer on all such motions to attempt to reach stipulations.

A represented party's person filing a W&I § 388 petition must meet and confer with other counsel and use Judicial Council Form JV-180.

Every noticed motion must include the moving party’s counsel declaration describing the counsel’s meet-and-confer efforts.

A motion hearing date and time must be reserved with the CEQA clerk and approved by the court before filing the motion.

The parties must meet and confer on every motion in limine before filing it.

All attorneys must meet and confer prior to filing any noticed motion.

If the Supervising Asbestos Judge or trial judge allows additional motions in limine, a briefing schedule will then be ordered.

The informal discovery procedure is mandatory for parties but optional for interested non-parties in discovery disputes.

Before filing a motion, the parties must discuss its issues by email, phone, or text unless discussion would threaten the children's safety.

If the client’s written consent is absent, the motion to withdraw must be set for a hearing.

Before filing a motion, the movant must contact the opposing party and make a good-faith effort to resolve the issues, except for summary-judgment and other case-dispositive motions.

A motion for substitution of counsel must be set for hearing if client consent is not attached.

Emergency hearings are rarely granted.

Whenever possible, parties should contact the opposing party before filing or upon receiving a motion to explore resolving it in whole or in part.

Before filing a motion, parties should make reasonable efforts to contact the opposing party about resolving the matter or submitting a stipulation and proposed order instead of having a hearing.

Labeling a motion emergency or urgent does not increase hearing priority unless the motion states facts establishing a genuine emergency or urgent need for action.

The Court schedules cases for trial at the pretrial conference or CMC.

If the Court determines an emergency exists, it will schedule the hearing unilaterally.

A Penal Code section 995 motion must be heard by a judge other than the assigned trial judge.

The parties and their attorneys must meet and attend the Joint Settlement Conference, except when a current no-contact restraining order exists and both parties are self-represented; experts and professional advisors may attend at each party’s option.

Motion dates must be reserved with the assigned department’s courtroom clerk before filing.

A party requesting an informal discovery conference must file a request for case management conference and specify that an IDC is desired as part of a Family Centered Case Resolution Order.

All parties must meet and confer about contested matters before entering the courtroom.

Law and Motion and contested hearing dates must be reserved with the assigned department’s courtroom clerk before filing, and the reservation must state the estimated time needed for the motion.

After filing the sworn statement, petitioners may submit the matter to the Clerk’s Office for ex parte consideration of dispensing with notice and terminating parental rights.

Counsel must confer before the case is called to assess whether argument will exceed 15 minutes and must advise the assigned department’s clerk if both agree it will.

An IDC must be scheduled no earlier than 1:30 p.m.; represented parties appear through counsel while their clients remain available in person or by telephone, and unrepresented parties appear in person.

The Court may order an informal discovery conference when a discovery motion is filed or, as part of a Family Centered Case Resolution Order, after reasonable notice and an opportunity for the parties to respond.

Failure to appear at or participate in good faith in an IDC may result in monetary or other sanctions if the Court schedules a noticed hearing on the issues.

Parties are expected to narrow issues as much as possible to use court time efficiently.

Any motion for discovery may be treated as premature unless counsel for movant has: 1. Made a good faith effort to obtain such discovery or relief from opposing counsel by agreement; 2. Complied with the applicable Rules of Civil Procedure, and has been unsuccessful, or shows good cause for not making such an effort; and 3. Includes a proposed order and certificate of conference pursuant to Local Rule 3.24

Before filing a motion, counsel must contact opposing counsel to attempt to resolve the matters and make at least three separate contact attempts during regular business hours over at least two days.

A motion may not be filed before the conference without leave of court and a certificate that the movant conferred with opposing counsel in a good-faith effort to resolve the matter.

Any motion for discovery may be treated as premature unless counsel for movant has: 1. Made a good faith effort to obtain such discovery or relief from opposing counsel by agreement; 2. Complied with the applicable Rules of Civil Procedure, and has been unsuccessful, or shows good cause for not making such an effort; and 3. Includes a proposed order and certificate of conference pursuant to Local Rule 3.24

Before filing any motion, counsel must contact opposing counsel to hold or schedule a resolution conference and make at least three separate contact attempts during regular business hours over at least two business days.

Exceptions to conference requirement: Section (A)(1) of this Rule does not pertain to dispositive motions, motions for summary judgment, motions for

For a complex or extraordinary case requiring additional preparation, a motion may be filed in accordance with Rule 3.33.

Attorneys wishing to move for change of judge must immediately announce that intention to the presiding judge at call assignment and then follow ORS 14.260, 14.270, and SLR 7.045 for the motion to be timely.

At assignment, an attorney seeking a change of judge must immediately announce that intention to the presiding judge and follow the cited procedures for timeliness.

The listed motion types (e.g., class action certification, compel arbitration, ORCP 21 motions, sanctions, interpleader) must be heard by the motions judge assigned to the case.

To get a motions judge assigned before automatic assignment, a party must make an oral request at ex parte, and must be prepared to announce a decision on a change of judge at that time.

When a civil case returns to our court via remand, please arrange for a scheduling conference with the presiding judge to determine the next steps.

In cases 'set to follow,' pretrial motions should be made to the assigned trial judge.

Motions in limine are prohibited from being filed before the pretrial conference.

For cross summary judgment motions, plaintiff must file opening brief 14 days before dispositive deadline, notice of motion must indicate cross motions and set hearing 42 days after filing.

Parties must meet and confer in good faith to resolve a discovery dispute without court action before filing a discovery motion or requesting an informal telephonic discovery conference.

Pre-filing meet and confer required before motions; certification of efforts required in notice of motion.

Only four briefs may be filed for cross summary judgment motions regardless of the number of complaints; non-compliance results in denial without prejudice.

Informal discovery conferences are optional alternative to formal motions under Local Rule 251.

Motions to tax costs are taken under submission upon filing with no hearing date set, and briefs/responses must follow Local Rule 292 and the Federal Rules.

Parties must confer with the court before filing any discovery motion.

Before filing a discovery motion, the parties must contact the Staff Attorney and hold a telephone conference with all other parties.

For summary judgment, opposition is due within 28 days and reply within 7 days after opposition; oral argument is available upon request, with disposition posted on the docket absent another arrangement.

For motions other than summary judgment or motions in limine, the opposition brief is due 14 days after filing and the reply brief is due seven days after the opposition brief.

Before filing any discovery motion, the parties must promptly contact the Staff Attorney and arrange a telephone or in-person attorney conference.

Before filing a discovery motion, parties must contact the staff attorney and initiate a telephone conference.

Before contacting the court about a discovery dispute, attorneys must attempt to resolve it with opposing counsel as required by the cited rules.

The Court will hear merits oral argument if requested; otherwise, it will schedule oral hearings as it deems appropriate.

Meet and confer with the responding party before filing a discovery motion to compel.

The demurring party must meet and confer with the opposition to resolve objections and comply with CCP 430.41.

Parties must actually discuss a discovery dispute before reserving an informal discovery conference; an email or letter is insufficient.

Counsel must meet and confer before filing a demurrer, per CCP 430.41.

Before trial, parties must share exhibits with opposing parties, identify witnesses, and estimate trial time.

Participation in an Informal Discovery Conference before filing discovery motions is encouraged but not required.

Parties are strongly encouraged to request an informal discovery conference before filing a discovery motion.

Before setting a final merits hearing in an administrative appeal, all counsel must confer on the hearing date, the amount of time requested, and (if multiple parties) the order of presentation.

Requests to be heard on motions challenging a prior ruling (new trial, modify/correct/reform/reconsider, etc.), except one by default, must be presented to the judge who made the ruling; contact the Court Administrator's office to determine visiting judge availability.

Counsel may not repeat or address subject matter covered by the pre-trial standing order except to seek a modification of the standing order.

Parties must brief administrative appeals before the hearing on the merits.

Motions in limine requesting additional limine relief or modification of the pre-trial standing order will be heard by the trial judge at the time of trial.

Attorneys are strongly encouraged (but not required) to confer by phone or in person before hearings on non-dispositive issues, especially discovery disputes.

A motion or response may request oral argument, and the Court will notify the parties if it wishes to schedule argument.

Before filing a motion to compel or for a protective order, parties must attempt informal resolution, then notify the Court by a Rule 6.4-compliant letter/e-mail and participate in a meaningful telephone conference; non-compliant motions to compel will be denied.

Replies and sur-replies require prior Court approval, requested informally by email with an explanation of need.

Before filing a motion to compel or for a protective order, parties must first discuss the dispute with the Court and opposing parties and submit a letter/e-mail demonstrating compliance with USCR 6.4; non-compliant motions will be denied.

A Trial Readiness Conference is required on all cases set for trial, scheduled one week before trial but not less than three days before trial, unless the court orders otherwise or the parties agree otherwise.

All law and motion pleadings must first be set for a short cause hearing, which has a maximum duration of 15 minutes unless extended by leave of court.

Before filing a demurrer or motion to strike, parties are strongly encouraged to meet and confer about extending the responsive pleading deadline; if no stipulation is reached, the Court reserves June 6, 2025 at 9:00 a.m. for a hearing on such motions.

If a discovery motion is filed without an IDC having been scheduled, the court is likely to schedule an IDC before hearing the motion.

Parties must meet and confer and exchange motions in limine at least seven days before trial, identifying contested motions.

The EEC procedure applies only to PAGA actions commenced on or after June 19, 2024, per Labor Code section 2699.3(g)(l); earlier PAGA actions are not entitled to an EEC.

Under one possible procedure, a party wishing to file a motion for summary judgment must file a letter no longer than 1,250 words setting forth the undisputed facts and legal theories that warrant granting summary judgment.

Case dispositive motions are scheduled only after briefing is complete, with the date and time obtained from Judge Winston’s Chambers.

Motions in limine must be noticed for presentation at the Pretrial Conference and may be resolved there.

The parties must meet and confer in good faith before moving the court for modifications or additional safeguards.

Parties may request, and the Court may adopt, a scheduling-order provision requiring leave before filing a summary-judgment motion.

Further briefing and hearings on motions will occur only as ordered by the court.

Judge Vavala’s routine motion calendar is held on Thursday at 9:00 a.m.

Counsel must make every effort to resolve discovery disputes by agreement before filing a motion with the court.

Before filing a discovery motion, counsel must make reasonable efforts to resolve the dispute, and a single email is insufficient.

A discovery motion filed without a prior status conference will likely be denied because the movant will be presumed not to have made adequate good-faith efforts.

If the parties remain unresolved after a discovery status conference, the Court will set a briefing schedule for a future discovery motion.

After good-faith efforts fail, parties should request a pre-motion discovery status conference.

Counsel should address Daubert issues among themselves and, absent agreement, with the Court at the final pretrial conference.

A motion in limine may be filed only after good-faith discussions and certification that counsel exhausted efforts to resolve the issues.

Counsel seeking to amend the case schedule should consider the applicable presumptive trial deadlines, comply to the best of their ability, and consult other counsel about conflicts before approaching the Court.

The court will not accept a sur-reply unless good cause is shown and the court grants a request to file it.

After sending the disclosure-dispute letter, the requesting party must contact Chambers to arrange a conference, preferably by telephone, and no discovery motion will be entertained without compliance.

A motion may be decided on default for failure to file papers and appear, submit a consent order, or obtain an adjournment.

For an adjourned motion, fully briefed papers must be submitted one week before the return date.

In-person oral argument is required for every motion.

The court will not conduct a second calendar call.

A fully briefed motion may be placed on the next available oral argument calendar, but oral argument will not occur on the day the application is made.

Once a motion is fully briefed, the parties may apply on the return date to schedule oral argument for the next available Friday morning; argument will not be heard on the application date.

A fully briefed motion may be placed on the next available oral-argument date, but oral argument will not occur on the application date.

Except for cases assigned to one judge for all purposes, a Readiness Conference for cases on the Master Trial Calendar will be conducted on the court day immediately preceding the Master Trial Calendar or as designated by the Supervising Judge – Criminal. Privately retained counsel and a representative of the District Attorney, Public Defender, Alternate Defender, and Independent Defender are required to be present. For each case set on the Master Trial Calendar for the following Monday, trial counsel must notify the court of trial readiness at the Readiness Conference, including matters of attorney availability, compliance with Penal Code section 1054 and sections (A)(3) and (A)(4) of this rule (below), exhaustion of settlement negotiations between trial counsel, and preparedness to argue motions in limine and conduct jury selection without delay upon assignment to a trial department.

Motions in limine are not heard at the pre-trial conference.

All parties and attorneys must meet and confer pursuant to California Rules of Court Rule 5.98.

Pre-filing conference required under Local Rule CV-7(h)/(i); additional lead attorney conference within 72 hours of hearing setting; lead attorney must attend hearing unless excused.

Pretrial motions in criminal cases are referred to magistrate judges, except for specific motions.

Counsel must confer on deposition objections

Review E-Discovery model order before contacting hotline or filing electronic discovery motions.

Parties must comply with Local Rule CV-7(h) and (i) conference requirements before filing any discovery motion.

Motions to compel discovery require good faith conference first.

Each side may propose up to five motions in limine at the Pretrial Conference.

Opposing counsel must confer to resolve deposition objections before court ruling.

Trial counsel must attend every pretrial conference unless excused by the judge.

A summary-judgment opposition with permitted evidence may be filed within 14 days after service, and the movant may reply within 10 days after service of the opposition.

The additional-evidence procedure does not apply to unemployment compensation appeals; the Court may review only the certified record provided by the Review Commission.

Unless the Court orders otherwise, summary-judgment motions are decided on briefs and permitted evidence without oral argument.

The Court may dismiss a case without prejudice if it determines that the plaintiff is not ready for trial.

Before filing a discovery motion, the parties must contact the Staff Attorney as soon as possible to set an Attorney Conference with the Court.

The Court will not hear disputes that arise after the discovery deadline.

Criminal motions in limine are due no later than two weeks before trial, and responses are due one week before trial unless otherwise ordered.

Before filing a motion to compel over an unresolved discovery dispute, the parties must contact the Staff Attorney in civil cases or the Bailiff in criminal cases; the court will schedule a conference by telephone, video, or in person.

Criminal bench-trial motions in limine are due 14 days before trial, responses are due 7 days before trial unless otherwise ordered, and replies are prohibited unless directed by the Court.

Before filing a motion to compel, counsel must confer in good faith and, if the dispute remains unresolved, contact the staff attorney to arrange an informal court conference.

Bench-trial motions in limine are due 14 days before trial, opposition responses are due 7 days later, and replies require leave of Court.

After a good-faith conferral fails to resolve a discovery dispute, contact the Staff Attorney for an informal court conference before filing a motion to compel.

The Court generally discourages discovery motions and expects counsel to resolve discovery issues without court intervention.

Civil motions are generally decided on the papers after briefing is complete, without oral argument.

If case evaluation is not accepted, counsel and self-represented litigants must appear by Zoom for a first settlement conference 42 days after case evaluation.

Attorneys must discuss motions to compel and other discovery motions with opposing counsel before filing.

Motions to compel discovery must state that the movant conferred or attempted to confer in good faith before filing.

Responses to rehearing or reconsideration motions are not permitted unless the Court specifically allows them.

Summary-judgment motions must be filed and served at least 60 days before the Pre-Trial Conference and heard before it.

Before filing a non-dispositive motion, the movant must confer with the opposing party in good faith to attempt to resolve the motion's issues.

Before filing a motion to compel or for a protective order, counsel must confer in good faith with opposing counsel to attempt resolution and file a certification of that conference and the unresolved dispute.

Before filing a motion to compel or for a protective order, moving counsel must confer with opposing counsel in a good-faith effort to resolve the disputed issues.

Withdrawal of counsel requires a motion and hearing unless the request is accompanied by a stipulation signed by the client and all counsel.

Except for motions in limine, motions generally must be filed and heard before the Pre-Trial Conference, with good-cause motions heard at or after that conference.