Filing Instructions

Motions heard in the Presiding Judge’s department are electronically filed, filed at the Civil Front Counter, placed in the civil drop box, or may be submitted by mail.

Alternatives to Appearing at a Hearing

The court strongly encourages all parties to appear remotely, either telephonically or by video conference via the Zoom video/audio conference platform, subject to Code of Civil Procedure 367.75 whenever possible.

If appearing remotely, parties are required to participate in the hearing using a device that has video and/or audio capability (i.e., computer, smartphone, or tablet). Although remote participation is not required, the Court will presume all parties are appearing remotely for non-evidentiary civil hearings. Requirements for noticing remote appearances depend on whether the civil hearing is evidentiary or non-evidentiary.

• Join by Zoom link.
• To join by phone, dial (833) 568-8864and enter ID 16173813009

Oppositions and Replies

All papers opposing a motion shall be e-filed, filed at the Civil Front Counter, or placed in the civil drop box.

All replies shall be e-filed, filed at the Civil Front Counter, or placed in the civil drop box.

Failure to comply with the requirements concerning filing and serving opposing and reply papers may, in the discretion of the court, be deemed cause for acting on the matter without consideration of the document filed in violation of the requirements and may be deemed cause for imposing sanctions.

Ex Parte Motions

All ex parte applications sought in the presiding judge's department shall be filed electronically, at the Civil Front Counter, or in the civil drop box.

Ex parte applications for emergency relief that are properly directed to the presiding judge shall be electronically filed, filed at the civil front counter, or placed in the civil drop box, or may be submitted by mail. The appropriate civil filing fees and all supporting papers must be submitted together. The time and date for the ex parte hearing shall be indicated as “TBD”. The parties shall otherwise comply with Local Rule section 1.07.

Such applications must include a written supporting declaration stating whether the opposing party is represented by counsel, whether that party has been contacted and has agreed to the requested order, or why the order should be issued without such notice. The adequacy of the application for temporary relief will be determined on the papers submitted. If the application is deemed adequate, the court may allow supplemental argument, either oral or written, by either party.

If the court determines that a hearing is necessary prior to ruling, the court will advise the applicant, who shall then provide appropriate notice of the hearing and file the necessary declaration in conformity with California Rules of Court 3.1203 and 3.1204.

Opposition papers may also be filed electronically, at the civil front counter, or in the civil drop box. Reply filings are not permitted.

Tentative Ruling Information

All parties appearing on the law and motion calendar in the presiding judge’s department shall utilize the tentative ruling system. The presiding judge will publish a tentative ruling at 2 p.m. two (2) days prior to the matter being heard. Parties may access the tentative ruling on the Public Portal or by telephoning 916-874-5487. The tentative ruling shall become the ruling of the court, unless a party desiring to be heard so advises the department clerk at 916-874-5487 no later than 12 p.m. on the court day preceding the hearing of their intent to appear at the hearing, and further advises the clerk that such party has notified the other side of its intention to appear. Where appearance has been requested by counsel or invited by the court, limited argument will be entertained.

All noticed motions in the presiding judge’s department shall include the notice language set forth in Local Rule 1.05.

Long Cause Civil Trial/Jury Trial Assignment

Stipulations for Pre-Assignment of Long-Cause Civil Trial

Effective July 8, 2024, the court implements a civil pre-assignment process for civil long cause trials anticipated to last longer than seven (7) court days in an effort to improve scheduling efficiency and reduce the occurrence of trailing civil trials causing delays, increased costs, and scheduling conflicts for civil litigants. Counsel seeking pre-assignment should submit a Stipulation and Proposed Order for Pre-Assignment pursuant to California Rule of Court 3.734. Stipulations shall be filed electronically, filed at the civil front counter, placed in the civil drop box, or may be submitted by mail between 10 and 15 court days before the trial assignment date.

The stipulation must include:

• Whether the matter will be a court or jury trial
• Estimated length of trial
• Would further MSC be beneficial?
• Will there be a request to bifurcate?
• Are the parties willing to stipulate to the use of an 8-person jury?
• The nature and complexity of the case, including the number of pre-trial issues and the number of witnesses (including experts).
• Is travel time to the Tani Cantil-Sakauye Downtown Courthouse for any party, attorney, or witness traveling more than 45 minutes for trial?

If the court grants the stipulation for pre-assignment, parties will be notified of their assigned trial department and should contact the department to schedule a pre-trial conference and motions in limine. Motions pursuant to Code of Civil Procedure §170.6 should be made as soon as possible after the Order on Stipulation for Pre-Assignment is made.

Parties may file an ex parte application or motion for pre-assignment of trial if unable to obtain a stipulation from all parties to the case.

Trial Readiness Notification

Counsel shall notify the court of their readiness to begin their Long Cause Civil Trial and provide information as to the status of the case electronically via the Civil Trial Readiness tab on the Public Portal. Readiness notifications shall be submitted from 10 court days before the trial date to 4 p.m. on the Tuesday before the trial date (prior week). Resending a submission will not overwrite any previously submitted information. All submissions will be read and considered.

Assigned Trial Department / Pretrial Conference

Note: While the parties shall be prepared to proceed with trial once assigned to the trial department, some flexibility in the schedule may be required. The trial department may not be able to start jury selection immediately if, for example, there are several motions in limine to resolve, the court orders one or more Evidence Code section 402 hearings, a jury panel is not available, or if the trial judge has other matters on its calendar that must fit into the schedule.

The trial department will expect the parties to comply with Chapter 2, Part Nine of the Local Rules related to trial procedures. Thus, the trial court will expect the following at the first pretrial conference with the assigned trial judge.

1. Motions in Limine (Local Rule 2.95): The parties should have met and conferred at least seven (7) days prior to the first date scheduled for trial to exchange motions in limine and identify the motions that are contested. The parties shall file their motions, oppositions, if any, and a list of disputed motions in the trial department at or before the pretrial conference. Refer to Local Rule 2.96 for motions that shall be deemed filed, served, and granted.
2. Jury Instructions (Local Rule 2.97): The parties should have met and conferred regarding jury instructions. At or before the pretrial conference, the parties shall submit to the assigned trial judge in Word format: (1) a fully completed set of agreed-upon jury instructions; and (2) all jury instructions that the parties cannot agree upon. If pinpoint or special jury instructions are offered, counsel shall provide case or statutory authority for the offered instruction following the text of the instruction.
3. Exhibits (Local Rule 2.98): The parties should have met and conferred to identify exhibits that may be admitted without objection and those exhibits as to which admissibility is contested. At or before the pretrial conference, the parties shall submit binders containing copies of the agreed-upon exhibits for use by the judge, clerk, and counsel during trial. The parties shall also submit a joint exhibit list in Word format.
4. Witness List (Local Rule 2.99): The parties should have met and conferred to prepare an alphabetized joint witness list, and the parties shall submit this list to the trial department at or before the pretrial conference.
5. Trial Briefs (Local Rule 2.99.01): Each party shall submit a trial brief at or before the pretrial conference.
6. Joint Statement of the Case (Local Rule 2.99.02): The parties should have met and conferred to agree on a joint statement of the case. The parties shall submit the joint statement to the assigned judge at or before the pretrial conference. If the parties cannot agree on a joint statement, each party shall submit its proposed statement to the trial judge.

In addition to the items above, the parties shall be prepared to discuss the following at the pretrial conference:

1. Schedule: The estimated length of the trial and any scheduling conflicts.
2. Witnesses: The approximate anticipated length of each witness's testimony, and any need for interpreters, claim of privilege, child witness, etc.
3. Voir Dire: Whether the parties are:
   1. requesting to provide a brief opening statement prior to voir dire;
   2. proposing the use of a juror questionnaire; or
   3. proposing any special voir dire questions for the Court to pose to the jury panel.
4. Proposed Stipulations: All matters to which the parties will stipulate, including but not limited to, witness testimony, admissibility of exhibits, procedural and legal issues, and any other matters pertaining to this case.
5. Verdict Forms: Whether special verdict forms are necessary, and if so, what language the parties propose.
6. Testimony through Discovery: If either party wishes to introduce into evidence deposition testimony or written discovery responses during the trial, the offering party shall file copies of the relevant documents, highlighting the transcript or portions of the documents it seeks to introduce, with a brief explanation of how the matter is to be used at trial. Counsel shall exchange the marked documents. Any objections to the use of this material at trial shall be heard on the first day scheduled for trial. Please note this does not apply to the use of deposition testimony or written discovery responses that will be used to impeach a witness on cross-examination.
7. Transcripts of Recordings: If any electronic sound, including video, audio recordings, or computer animations, will be presented, provide the Court and counsel with a transcript at the pretrial conference. Notify the court and opposing counsel before trial if you are requesting to provide the jury with a transcript of any recording to be played. Have 20 copies of the transcript available for the court, clerk, jurors, alternates, counsel, and the court reporter. Per California Rules of Court 2.1040, the court reporter need not transcribe any audio or video where a transcript is provided.
8. Other Evidentiary Issues: Any other evidentiary issues not identified above, including, for example, demonstrative evidence, recordings, electronic animations, or demonstrations to be used in the opening statement or closing argument.

Please refer to Local Rules 2.95 through 2.99.04 for specific information on filing guidelines and requirements for civil trials.

Short Cause Trial Assignment

Requests for Short Cause Civil Trial

Requests for short cause civil trials shall be filed electronically, filed at the Civil Front Counter, placed in the civil drop box, or submitted by mail. After the required filings are complete and the court determines that a short cause civil trial should be scheduled, the parties will receive a case-specific Notice of Hearing from the court indicating the date and time of the short cause civil trial, pretrial requirements, and Zoom information.

Appearances

The court continues to allow and strongly encourages all parties to appear remotely, subject to Code of Civil Procedure 367.75 whenever possible. If a party has no internet access or other justifiable basis such that appearing via Zoom is not possible, that party must call the clerk in Department 17A no later than 14 days prior to the trial to arrange for a telephonic appearance.

Appearance of Witnesses

Before the scheduled date for the short cause civil trial, parties shall provide the Zoom meeting information for Department 17A to anyone they intend to call as a witness during their trial. If any party fails to notify witnesses, the Court may not consider the party’s exhibits or continue the short cause trial.

Submission of Exhibits Before Short Cause Trial

Before your trial date, parties must provide to the court and the opposing party any exhibits (e.g., relevant documents) to be used at trial. Provide copies only. Copies of documents may be submitted by email or by mail. Do not submit original documents to the court because the court will not return any evidence after the trial. Keep original documents in the event of an appeal.

• By email (preferred method): Scanned exhibits must be emailed at least seven (7) calendar days prior to the scheduled trial date to CivilTrialExhibits@saccourt.ca.gov.
  • In the subject line of the email, you must include your case number with the trial date and time. You must copy (CC) the opposing party in your email sent to the Court. If you do not have an email address for the opposing party, please follow the mailing instructions below for delivering your exhibits to the opposing party.
• By Mail: If a party does not have an email address, internet access, or an email address for the opposing party, mail physical copies of exhibits to the court and to the opposing party.

All exhibits sent by mail must be postmarked at least fourteen (14) calendar days prior to the scheduled trial date. Include with the exhibits the case number, the trial date, and time. Parties are to complete a Proof of Service by First-Class Mail form (POS-030), which must be received by the court at least seven (7) calendar days prior to your scheduled court date.

If any party fails to submit their exhibits to the court and to the opposing party in compliance with the deadlines indicated in the Notice of Hearing, such failure may result in the court not considering the party’s exhibits or in a continuance of the short cause trial.

Parties Requesting Court Reporters

Parties requesting services of a court reporter will need to arrange for private court reporter services at their own expense, pursuant to Government Code § 68086 and California Rules of Court, Rule 2.956. Requirements for requesting a court reporter are listed on the Court Reporters page.