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San Mateo County trial document templates

Not legal advice. Rules checked against the code on August 20, 2026. Verify every date yourself. Read the full disclaimer

Core CCP rules were checked against Westlaw (via CoCounsel legal research) on August 20, 2026. County local rules are paraphrased summaries. Individual department and judge standing orders are included only where the court publishes them and we have read the document, so assume your own department has requirements beyond what you see here. Verify every date against the operative code sections, your court’s rules and your department’s own order before relying on it. Using this site creates no attorney-client relationship.

14 documents, 27 required sections, taken from Superior Court of California, County of San Mateo’s own published rules and read 2026-09-14. Each one downloads as California pleading paper with this court’s required sections already placed, so the document cannot silently omit one.

A blank template is easy to find anywhere. What is hard to find is which sections this court requires inside the document, because that lives in a local rule nobody indexes. Every heading below is cited to the subdivision it came from, and the rule’s own sentence prints beside it in the reference sheet so you can check your work.

Download these as templates

The reference sheet below carries everything this court requires, each rule quoted from its own text and cited to the subdivision. The pleading paper templates are temporarily down while the line numbering is rebuilt, because the rail did not line up with the body text and a pleading whose lines cannot be cited is worse than no template at all.

Your details optional, blanks print as ruled lines

These stay in this browser. They are not sent anywhere, and the file is built on this machine, so a case name never reaches our server.

  • Case Management and Trial Setting Conference Statementeach party, 1 required sections. at least 15 calendar days before the Case Management and Trial Setting Conference
    Pleading paper is being corrected
  • Mandatory Settlement Conference Statementeach party, 1 required sections. no later than five court days before the initial date set for the Mandatory Settlement Conference
    Pleading paper is being corrected
  • Motions in Limine and Oppositionseach party, 3 required sections. e-filed no later than 21 days before the Pretrial Conference in the departments that publish a pretrial order; under the county rule, served at least 5 days before trial and filed with the trial department on assignment
    Pleading paper is being corrected
  • Joint Pretrial Conference Statementjointly, 1 required sections. e-filed at least 14 days before the Pretrial Conference
    Pleading paper is being corrected
  • Joint Set of Proposed Jury Instructionsjointly, 3 required sections. with the Joint Pretrial Conference Statement, at least 14 days before the Pretrial Conference
    Pleading paper is being corrected
  • Joint Proposed Verdict Formsjointly, 1 required sections. with the Joint Pretrial Conference Statement, at least 14 days before the Pretrial Conference
    Pleading paper is being corrected
  • Joint Proposed Statement of the Casejointly, 2 required sections. with the Joint Pretrial Conference Statement, at least 14 days before the Pretrial Conference
    Pleading paper is being corrected
  • Joint Witness Listeach party, 2 required sections. with the Joint Pretrial Conference Statement, at least 14 days before the Pretrial Conference
    Pleading paper is being corrected
  • Joint Deposition Designations, Objections and Responsesjointly, 2 required sections. with the Joint Pretrial Conference Statement, at least 14 days before the Pretrial Conference
    Pleading paper is being corrected
  • Joint Exhibit Listjointly, 2 required sections. with the Joint Pretrial Conference Statement, at least 14 days before the Pretrial Conference
    Pleading paper is being corrected
  • Trial Briefeach party, 2 required sections. Department 20: at least 14 days before the Pretrial Conference. Elsewhere: no deadline is set, and any brief a party chooses to file goes to the trial department on assignment
    Pleading paper is being corrected
  • Tabbed Binders of the Motions in Limine and Supporting Paperseach party, 2 required sections. delivered with the Joint Pretrial Conference Statement, at least 14 days before the Pretrial Conference
    Pleading paper is being corrected
  • Courtesy Copy Binder of the Trial Documentsjointly, 2 required sections. delivered with the Joint Pretrial Conference Statement, at least 14 days before the Pretrial Conference
    Pleading paper is being corrected
  • Hard Copy Trial Exhibit Binders and Thumb Driveeach party, 3 required sections. at least 14 days before the trial date
    Pleading paper is being corrected

Everything this court requires in one editable document, with each rule quoted and cited.

What each document has to carry

Case Management and Trial Setting Conference Statement

Prepared by each party. Filed and served, at least 15 calendar days before the Case Management and Trial Setting Conference. Applies to general civil cases, after the parties have completed an ADR process. San Mateo County Superior Court Local Rule 3.1000(b)

  1. Required contents of the written statement
    • a written statement in prose and in detail, not Judicial Council form CM-110
    • the matters required by California Rules of Court, rule 3.717
    • the circumstances relevant to trial setting under California Rules of Court, rule 3.729
    • the status of document production
    • the status of party and witness depositions

Mandatory Settlement Conference Statement

Prepared by each party. Lodged and served, no later than five court days before the initial date set for the Mandatory Settlement Conference. Applies to all general civil cases, complex cases in the assigned Civil Judge's discretion, and probate matters under Local Rule 4.3(c). San Mateo County Superior Court Local Rule 3.1100(d)

  1. Required contents of the statement
    • all of the information California Rules of Court, rule 3.1380(c) requires in a settlement conference statement

Motions in Limine and Oppositions

Prepared by each party. Filed and served, e-filed no later than 21 days before the Pretrial Conference in the departments that publish a pretrial order; under the county rule, served at least 5 days before trial and filed with the trial department on assignment. Applies to civil jury trials, with Local Rule 2.20(1) keyed to assignment for trial by a jury and Local Rule 2.21 stated for in limine motions generally. San Mateo Superior Court, Dept. 28 (Healy), Pretrial Order No. 1 (Jury Trial), paras. 4, 6, 7, 8, 9; Dept. 11 (Silberman), same paras.

  1. Deadline for the motions and the oppositions
    • motions in limine e-filed with the Clerk's Office no later than 21 days before the Pretrial Conference
    • oppositions e-filed no later than 21 days before the Pretrial Conference
    • no reply brief without leave of court
  2. Form of each motion and each opposition
    • one topic per motion
    • a caption in the form "___'s Motion in Limine No. ___ Re: ___"
    • five pages maximum per motion
    • five pages maximum per opposition
    • one declaration per party covering all of that party's motions
    • one request for judicial notice per party covering all of that party's motions
  3. The county rule's separate service and filing steps
    • service of the motion on opposing counsel not less than five days before trial
    • service of any response on the proponent of the motion not later than the first appearance in the Department of the Presiding Judge for trial assignment
    • filing of the in limine motions and the responses with the trial department upon assignment for trial by a jury

Joint Pretrial Conference Statement

Prepared jointly. Filed, e-filed at least 14 days before the Pretrial Conference. Applies to civil trials in Depts. 28, 11 and 20, the only departments whose para. 36 is cited for this statement; there is no county local rule requiring it, and the digest does not show the Dept. 4 or Dept. 2 orders imposing it. San Mateo Superior Court, Dept. 28 (Healy), Pretrial Order No. 1 (Jury Trial), para. 36; Dept. 11 (Silberman), same para.; Dept. 20 (Mau), Pre-Trial Order No. 1, para. 36

  1. Required contents of the statement
    • the substance of the action
    • the relief requested, with damages itemized
    • the undisputed facts
    • settlement discussions
    • an estimate of the number of hours for each side's case
    • miscellaneous

Joint Set of Proposed Jury Instructions

Prepared jointly. Filed, with the Joint Pretrial Conference Statement, at least 14 days before the Pretrial Conference. Applies to jury trials. San Mateo Superior Court, Dept. 28 (Healy), Pretrial Order No. 1 (Jury Trial), paras. 11 through 16; Dept. 11 (Silberman), same paras.

  1. Form of the joint set
    • a single joint set of proposed instructions
    • the instructions arranged in the order the parties propose the Court give them
    • copies of the actual instructions, not merely a list of numbers
    • CACI instructions where they apply
    • any modification plainly marked
    • agreed instructions labeled "Stipulated Instruction No. ___ Re: ___"
  2. What is delivered to the judge and opposing counsel
    • every blank filled in before delivery
    • every strikeout, insertion and modification made before delivery
    • a hard copy of the proposed instructions
    • the modified instructions on a CD or USB flash drive
    • a clean copy of the instructions to be given to the jury
  3. Conformity and instructions requested after the evidence closes
    • conformity with California Rules of Court, rule 2.1055
    • any instruction requested after the conclusion of taking evidence in writing

Joint Proposed Verdict Forms

Prepared jointly. Filed, with the Joint Pretrial Conference Statement, at least 14 days before the Pretrial Conference. Applies to jury trials. San Mateo Superior Court, Dept. 28 (Healy), Pretrial Order No. 1 (Jury Trial), paras. 17 and 18; Dept. 11 (Silberman), same paras.; Dept. 4 (Fineman), Pretrial Order, para. 26; Dept. 20 (Mau), Pre-Trial Order No. 1, para. 17; Dept. 2 (McCannon), Pretrial Order No. 1, para. 34

  1. Form of the submission and resubmission after the conference
    • joint proposed verdict forms, or separate proposed verdict forms if the parties disagree
    • any changes the court orders at the Pretrial Conference
    • resubmission of the revised forms in Word by the court's deadline

Joint Proposed Statement of the Case

Prepared jointly. Filed, with the Joint Pretrial Conference Statement, at least 14 days before the Pretrial Conference. Applies to jury trials. San Mateo Superior Court, Dept. 28 (Healy), Pretrial Order No. 1 (Jury Trial), para. 21; Dept. 11 (Silberman), same para.; Dept. 4 (Fineman), Pretrial Order, para. 20

  1. Content and length of the joint statement read during voir dire
    • a joint proposed statement of the case to be read to the jury during voir dire
    • no more than one page double spaced unless the case is very complex
    • neutral rather than argumentative language
    • the names of the attorneys to be read to the jury
    • the names of the witnesses to be read to the jury
  2. The county rule's separate filing on assignment, by each party
    • a concise non-argumentative statement of the case to be read to the jury, filed by each party with the trial department upon assignment for trial by a jury

Joint Witness List

Prepared by each party. Filed, with the Joint Pretrial Conference Statement, at least 14 days before the Pretrial Conference. Applies to civil trials in Depts. 20, 28 and 11, the departments cited for paras. 22 and 23; the county rule's version applies on assignment for trial by a jury. San Mateo Superior Court, Dept. 20 (Mau), Pre-Trial Order No. 1, paras. 22 and 23; same text at Dept. 28 (Healy), Pretrial Order No. 1 (Jury Trial), paras. 22 and 23, and Dept. 11 (Silberman), same paras.

  1. Tabular contents of the list each party files
    • name of the witness
    • title of the witness
    • a brief description of the subject matter of the anticipated testimony
    • an estimate of the time for direct, cross, redirect and cross-redirect
  2. The county rule's separate filing on assignment, by each party
    • a list of possible witnesses who may testify in the trial, filed by each party with the trial department upon assignment, to be read to the jury panel by the court

Joint Deposition Designations, Objections and Responses

Prepared jointly. Filed, with the Joint Pretrial Conference Statement, at least 14 days before the Pretrial Conference. Applies to civil trials in the departments that publish a pretrial order. San Mateo Superior Court, Dept. 28 (Healy), Pretrial Order No. 1 (Jury Trial), paras. 23(e) and 23(f); Dept. 11 (Silberman), same subparas.; Dept. 4 (Fineman), Pretrial Order, para. 22(e); Dept. 20 (Mau), Pre-Trial Order No. 1, para. 23

  1. The joint pleading that fronts the submission
    • the designations
    • the objections
    • the responses to the objections
  2. The joint binder behind the pleading
    • one joint binder
    • a tab for each witness
    • actual excerpts of the transcripts rather than a list of page and line numbers
    • the designation highlighted in yellow
    • any objections bracketed in red

Joint Exhibit List

Prepared jointly. Filed, with the Joint Pretrial Conference Statement, at least 14 days before the Pretrial Conference. Applies to civil trials in the departments that publish a pretrial order. San Mateo Superior Court, Dept. 20 (Mau), Pre-Trial Order No. 1, paras. 30 and the tabular list following; same text at Dept. 28 (Healy), Pretrial Order No. 1 (Jury Trial), paras. 28 and 29, and Dept. 11 (Silberman), same paras.

  1. Tabular contents of the joint list
    • exhibit number
    • a brief description of the exhibit, with Bates numbers if any
    • the sponsoring witness
    • a blank column for the date marked
    • a blank column for the date admitted
  2. Numbering convention
    • exhibit numbers, never letters
    • numbers assigned in agreed blocks by party
    • exhibits pre-marked

Trial Brief

Prepared by each party. Filed, Department 20: at least 14 days before the Pretrial Conference. Elsewhere: no deadline is set, and any brief a party chooses to file goes to the trial department on assignment. Applies to Department 20 requires one; in other departments a trial brief is optional and the county rule sets no content or page limit. San Mateo Superior Court, Dept. 20 (Hon. Michael L. Mau), Pre-Trial Order No. 1, para. 1, Summary Table of Deadlines

  1. Department 20's mandatory brief
    • a trial brief
    • 10 pages maximum
  2. Filing an optional brief under the county rule
    • any trial brief filed with the trial department upon assignment for trial by a jury

Tabbed Binders of the Motions in Limine and Supporting Papers

Prepared by each party. Lodged, delivered with the Joint Pretrial Conference Statement, at least 14 days before the Pretrial Conference. Applies to civil trials in the departments that publish a pretrial order. San Mateo Superior Court, Dept. 28 (Healy), Pretrial Order No. 1 (Jury Trial), para. 5; Dept. 11 (Silberman), same para.; Dept. 4 (Fineman), Pretrial Order, para. 5

  1. Binder of the motions and the oppositions
    • a tabbed binder
    • the party's motions in limine in numerical order
    • each opposition immediately behind its motion inside the same tab
  2. Separate binder for the declarations and requests for judicial notice
    • a separate tabbed binder
    • any declarations submitted in support of or in opposition to the motions
    • any requests for judicial notice
    • the exhibits to those declarations and requests

Courtesy Copy Binder of the Trial Documents

Prepared jointly. Lodged, delivered with the Joint Pretrial Conference Statement, at least 14 days before the Pretrial Conference. Applies to civil trials in the departments that publish a pretrial order. San Mateo Superior Court, Dept. 28 (Healy), Pretrial Order No. 1 (Jury Trial), para. 37; Dept. 11 (Silberman), same para. (Courtroom G); Dept. 20 (Mau), Pre-Trial Order No. 1, para. 37

  1. What goes in the binder set
    • the proposed jury instructions
    • the proposed verdict forms
    • the proposed voir dire and juror questionnaire
    • the proposed statement of the case
    • the joint witness list
    • the joint deposition designation binder
    • the joint exhibit list
  2. Delivery of the courtesy copies
    • binders no more than two and a half inches wide
    • delivery to the courtroom with the Joint Pretrial Conference Statement
    • delivery between 9:00 a.m. and 4:00 p.m. to the Central Courthouse

Hard Copy Trial Exhibit Binders and Thumb Drive

Prepared by each party. Lodged, at least 14 days before the trial date. Applies to civil trials in Depts. 28 and 11, the only departments cited for para. 30; Local Rule 2.22 applies to any party offering an exhibit at trial. San Mateo Superior Court, Dept. 28 (Healy), Pretrial Order No. 1 (Jury Trial), para. 30; Dept. 11 (Silberman), same para.

  1. Sets the court receives
    • at least three complete sets of hard copy exhibits
    • tabbed binders no more than two and a half inches wide
    • one complete set of the exhibits on a thumb drive
  2. Labeling of the binders and the exhibits
    • no plaintiff's or defendant's label on the binders
    • the court's exhibit tag on the back of each exhibit
  3. Originals and copies ready at assignment
    • an original of each exhibit the party intends to offer
    • sufficient copies of each exhibit for all other parties and the court
    • readiness by the time of assignment to a trial department

Start with the joint documents

7 of these are prepared jointly: Joint Pretrial Conference Statement; Joint Set of Proposed Jury Instructions; Joint Proposed Verdict Forms; Joint Proposed Statement of the Case; Joint Deposition Designations, Objections and Responses; Joint Exhibit List; Courtesy Copy Binder of the Trial Documents. A joint document needs a meet and confer before it can be filed, so it sets the real deadline even though the filing date is the same as everything else.

When each one is due

Count each deadline back from the date the rule is actually keyed to rather than from trial. The full rule list for San Mateo County carries every rule with its quoted text, and the trial countdown calculator computes the statewide CCP chain.

How these were built

Every rule was researched from the court’s own published text, then checked a second time by a reader told to assume a rule had been invented. Grouping those rules into the documents a court actually wants was a further pass, and an adversarial check corrected it: the commonest error was a document whose contents the first pass left empty while the rule enumerated them. Templates are generated in your browser, so nothing you type is sent anywhere. See methodology.

Related: All courts with templates · San Mateo trial binder rules · Trial countdown calculator