Contra Costa County trial binder and trial document requirements

Conduct Trial Readiness Conference

The deadline cell for this row reads As Scheduled by the Court in advance of the trial. Verified by rendering chart page 1 at 170 dpi, because pdftotext interleaves the two columns. The chart's first row separately schedules an Issue Conference with the Court's Settlement Mediator or a Settlement Conference with a Judicial Officer, so in Dept. 16 the phrase Issue Conference denotes the settlement proceeding and the trial-document anchor is the trial date itself.

Please note that this issue conference is, in all other ways, not the "Issue Conference" mentioned in Local Rule 3.11. Importantly, deadlines relating to the "Issue Conference" are applicable to the Pretrial Conference below. Proposed jury instructions are due at the Pretrial Conference.

Offset token wednesday_before_trial means the Wednesday immediately preceding the trial date. Section IV reads: The Wednesday prior to the trial date, the Court will hold a Pretrial Conference. Counsel must appear in person at the pretrial conference unless the Court, for good cause shown, authorizes virtual appearance in advance. This is the single biggest trap in the county, because the phrase Issue Conference means something different here than it does in Rule 3.11.

Within fourteen (14) calendar days before the trial date, unless otherwise ordered, an Issue Conference will be held during which all matters necessary to be resolved before trial will be before the Court. All trial counsel must be present, along with all principals or clients and claims representatives with settlement authority.

Page 52 of 201, marked revised effective 1/1/16. Title Three, Chapter 1. Rule 3.1 limits Title Three to civil cases and excludes juvenile, probate, family law, extraordinary writs, asset forfeiture, and CRC 3.740 collections cases. The unless otherwise ordered clause is the hook every department uses, and the conference is not guaranteed: Judge Marquez's published departmental policies say Not all cases are set for an Issue Conference and the dates and times will vary. Confirm from the trial setting order before counting any deadline off this conference.

Approximately one month prior to trial, the Court will set an issue conference. Each party taking part in the trial shall file an issue conference statement in accordance with local rule 3.11, with only the exceptions set forth below. Issue conference statements shall be filed by all parties no later than 10 calendar days before the scheduled conference.

Ten calendar days, not the five court days Local Rule 3.11(c) gives. The order opens section II with At the time of setting trial, the Court will have set an Issue Conference, Settlement Conference, and a Pretrial Conference. If you do not see all three dates, please request clarification. The department also sets mandatory settlement conferences about one month before trial and will consider vacating one on a showing that it is not an efficient use of time. Judge Campins took Dept. 10 effective 3/2/26.

Each party shall lodge with the assigned department, at the time of filing of the Issue Conference Statement, a settlement statement in the form and content described in Local Rule 3.101.

Lodged, not filed. Marked revised effective 1/1/08. The complex sample order waives it: The parties need not file settlement conference statements as provided in Local Rule 3.11(d).

On the Court's own motion, all cases, other than short causes, may be calendared for mandatory settlement conferences, upon written or oral notice to all parties involved.

No fixed interval before trial. Chapter 5 is headed Settlements and Settlement Conferences (Not Applicable To Family Law and Probate Matters), which confirms civil scope. Dept. 10 sets an MSC about one month before trial as a matter of practice. Many Contra Costa settlement conferences go to a settlement mentor under Rule 3.203 rather than to a bench officer.

(1) Have endorsed by the Clerk of the Court and served on all parties five (5) court days before the conference, a written statement of the facts, law and respective contentions of the parties to prove or disprove the right of recovery, items and amount of special damages, nature and extent of injuries incurred and claimed residuals documented by medical report when possible, any wage loss claim showing methods of computation, and any claim for future medical expenses and earnings loss;

Endorsed by the clerk first, then served. This same content is what Rule 3.11(d) requires lodged with the Issue Conference Statement.

(2) Have in attendance all principals or clients. Claims representatives shall be in attendance, unless excused in writing, by the Presiding Judge before the Settlement Conference;

Under (4), failing to file the statement, prepare, appear or participate may be considered as an unlawful interference with the proceedings of the court, and the court may impose costs, actual expenses and counsel fees, and may vacate the trial date or order the case to trial on the date assigned.

Counsel of record should take note the Court has and will continue to impose monetary sanctions on attorneys who file documents lacking proper tabs or bookmarks where required, regardless of whether such documents were fax-filed through an attorney service, and in some instances will disregard those documents or drop a hearing from calendar based on the rule violation.

This is the only tabbing and bookmarking rule in the county rules, and it governs filed papers rather than trial binders. Rule 3.42(3) expressly departs from California Rules of Court, rule 3.1110(f). Rule 3.42(3)(A) refers repeat offender attorney services to the Presiding Judge. Marked revised effective 1/1/24.

No later than 4:00 pm two (2) court days in advance of the trial date (typically the Thursday before a Monday trial date) . When using binders, courtesy copies of all filed motions in limine shall be provided to the Court in a tabbed binder together with any opposition and/or related filed papers. Each binder shall have an index of the papers. Each Party is responsible for assembling and providing such binder to the Court as to their own filed motions in limine (with any related papers as set forth above). Failure to do so may result in denial of the motion. This provision supersedes the provisions regarding lodging courtesy copies as set forth in Local Rule 3.11(b).

The stray space before the period is in the original. Each party assembles its own, not a joint one. At the same 4:00 pm deadline the chart requires Lodge thumb drives and/or binder(s) of all trial exhibits, including joint exhibit list. Make appointment with Court Clerk (925) 608-1116. The chart's deadline cell for that row reads 4:00 pm one (2) court days in advance of the trial, a typographical error against the body's two (2) court days, confirmed by page render.

Each Party is responsible for providing, at first appearance for trial, at least three binders, with copies of their trial exhibits (one for the Clerk of the Court, one for the witness stand, and one for the Judge) conforming to the Master Exhibit List. All parties are admonished that a failure to lodge a Master Exhibit List and exhibit binders or digital copies on thumb drive in conformance with the foregoing may result in a rescheduling of the trial to a later date in the Court's discretion.

The same paragraph requires removing duplicates, pre-marking every exhibit, and consolidating the lists into one Master Exhibit List, with each exhibit carrying a separate numerical identifier and indexed electronically, if submitted electronically through a thumb drive. The chart also shows Lodge Trial Exhibits, including Master Exhibits under the four calendar day row, which does not square with the body's first-appearance timing; that conflict is unresolved on the face of the order.

It is Department 16's preference to accept electronic or digital copies of documents referred in these pre-trial orders. The term "binder" or "binders" used herein also refers to and includes to electronic or digital copies of the documents requested downloaded onto a thumb drive and properly indexed for easy access by the Court.

Verified by rendering chart page 2 at 170 dpi; pdftotext interleaves the note's left and right columns so a plain text search on this passage fails. The note continues: Department 16 prefers electronic copies of documents loaded on a thumb drive or other solid state memory device that may be plugged into a USB port. (No CD or DVD ROM discs.) Courtesy copies of binders of physical paper copies will be accepted by the Court, but are not necessary if electronic copies are provided on thumb drives. Typographical errors are the court's. Counsel are told to make an appointment with the clerk to test the For the Record courtroom equipment before trial.

The Parties shall meet and confer regarding any stipulations regarding the qualification of any expert(s) and the preparation of a binder with all expert designations and declarations which shall be provided in a binder and lodged at first appearance for trial.

The chart phrases the same item as Lodge thumb drive or memory drive device / and/or binders with copy of all expert designations and declarations. In a construction defect case this is usually the largest binder.

Binders to be Prepared with Courtesy Copies of MILs. No later than 4:00 pm one (1) court day in advance of the trial date (typically the Friday before a Monday trial date) (the "Court Day Before Trial Deadline"), courtesy copies of all filed motions in limine shall be provided to the Court in a tabbed binder together with any opposition and/or related filed papers. Each binder shall have an index of the papers. Each Party is responsible for assembling and providing such binder to the Court as to their own filed motions in limine (with any related papers as set forth above). Failure to do so may result in denial of the motion. This provision supersedes the provisions regarding lodging courtesy copies as set forth in Local Rule 3.11(b). However, the Court encourages, but does not require, the parties to prepare a single binder compiling all of the motion in limine papers.

Offset token -1_court_days means one court day before the trial date. One court day, not the two Dept. 16 gives, and Dept. 34 says nothing about a thumb drive substitute. Para. 7 allows papers on uncontested motions to be left out of the binder if the index flags them. The Court Day Before Trial Deadline defined here also governs objections to deposition and discovery excerpts and to audio or visual presentations.

Each Party is responsible for providing, at first appearance for trial, at least four binders, with copies of their trial exhibits (one for the Court, one for the witness stand, and one for each side) conforming to the Master Exhibit List. The Court encourages, but does not require, the Parties to prepare a single set of master exhibit binders. All parties are admonished that a failure to lodge a Master Exhibit List and exhibit binders in conformance with the foregoing may result in a rescheduling of the trial to a later date in the Court's discretion.

Four binders in Dept. 34 against three in Dept. 16. The long cause court trial order carries the identical four-binder sentence. The same paragraph requires removing duplicates, pre-marking, and consolidating into a single Master Exhibit List with separate numerical identifiers.

Motions in Limine are to be served on opposing party [not filed] 10 court days in advance of issue conf; answers to MILs to be served 3 court days in advance of issue conference. You must include your own MILs and the opposition thereto in a tabbed section of your trial binder.

The only department that uses the phrase trial binder, and the only one that says motions in limine are served rather than filed. That departs from Local Rule 3.11(b), which requires them filed and served, and from the calendar-day count the county rule uses.

While the Court generally does not desire hard copy courtesy copies during the litigation, binders of Motions in Limine and oppositions should be prepared by the moving party for each. Uncontested Motions in Limine need not be printed out and included in the binder, but they should be identified on a cover page. These binders should be provided immediately after the oppositions have been filed.

Anchor trc_date means the Pretrial Conference the Wednesday before trial. Section III.C, headed At least three days before the Pretrial Conference, repeats No later than this date, the Court requires preparation of the Motions in Limine binders discussed elsewhere. Dept. 10 otherwise does not want courtesy copies. The order also states The Court will assume that any Motion not opposed is conceded.

If there are more than a small number of exhibits, the sides are to put all exhibits into one or more binders with appropriate tabs.

Same section: There is to be unified numbering of the exhibits. In other words, all exhibits for both parties must bear consecutive numbering. Gaps are acceptable, such that, for example Plaintiff(s) may have exhibits 1-50, and Defendant(s) may have exhibits 100-150. And: At the trial besides copies for counsel, you must prepare two for the court: a bench set for the judge, and a set for the witnesses. Electronic exhibits require the party to supply the jury a clean laptop with no internet access. For cases with a very large number of exhibits, and especially court trials, the court is amenable to all exhibits being electronic.

Counsel will be required to provide two sets of exhibit binders to the Court. One is for use by the witnesses; one is for use by the Court. The spine of each binder shall identify the range of exhibit numbers contained in that binder. Binders should not be filled to capacity; there should be room for additional exhibits if any need to be added later.

Posted on the current Complex Litigation page but signed by Hon. Edward G. Weil and routing courtesy copies to the chambers of Department 39. Complex is now Department 16 under Judge Reyes, whose 2025 order states These Pre-Trial Orders supersede any prior orders provided to Counsel and/or the Parties. The PDF has no text layer; all nine pages were rendered at 150 dpi and read as images. Same paragraph requires all-numeric exhibit numbering: All sides should use numbers; none should use letters, and a joint exhibit list delivered to the clerk on the first morning of trial and e-mailed in Excel to cxlit@contracosta.courts.ca.gov.

If more than two motions in limine are filed by a party, a binder containing the motions (separated by tabs) and an index of the motions shall be provided.

The binder is not given its own deadline; it attaches to the 15 calendar day filing deadline in the same paragraph. Oppositions are due 5 court days before the conference. Both the motions and the opposition should consist only of a brief synopsis of the parties' positions. Read as a rendered image, the PDF having no text layer. Same currency caveat as the row above: signed by Hon. Edward G. Weil, routed to Department 39, and superseded in a live Dept. 16 case.

Parties must file with the court and serve all parties an Issue Conference Statement (Local Court Form CV-659(c)) of not more than ten (10) pages at least five (5) court days before the Issue Conference. In limited civil cases only, use of the local Issue Conference Statement form (Local Court Form CV-659(c)) is mandatory.

Court days here, unlike the calendar days used for motions in limine. In an unlimited civil case the form is optional but the four content items in (c)(1) through (c)(4) are not. Dept. 10 moves this to 10 calendar days before its own issue conference. The complex sample order says statements may exceed ten pages in length and sets 10 calendar days.

Not less than three (3) court days in advance of the trial date, the Parties shall meet and confer in a face-to-face or Zoom or other remote conference (the "Advance Trial Conference") as to the following:

The summary chart reads At Least Three (3) Calendar days in advance of Trial for the same event, which conflicts with the body's court days. Court days is the body text and is the safer reading. Verified against the rendered chart page, so this is the court's own inconsistency, not an extraction artifact.

Not less than three (3) court days in advance of the trial date, the Parties shall meet and confer in a face-to-face conference (the "Advance Trial Conference") as to the following:

Face to face, unlike Dept. 16 which allows Zoom or another remote conference. Objections to deposition and discovery excerpts and to audio or visual presentations are due by the Court Day Before Trial Deadline, meaning 4:00 pm one court day before trial.

At least 14 days before the first Pretrial Conference below: The parties must exchange (email is sufficient with confirmation)

Anchor trc_date here means Dept. 10's Pretrial Conference, which sits the Wednesday before trial. The five exchanged items are a bulleted list in the original and are enumerated in the requirement rather than quoted, because the bullets are not a contiguous sentence and they straddle a page break. The order explains the departure in a footnote: The reason this deadline is different than the deadline in Local Rule 3.11 is that this department sets an early issue conference and the Local Rule addresses what this Court calls a Pre-Trial Conference. On motions in limine the same section reads Each party shall file and serve Motions in Limine, numbered consecutively by party, adds Absent good cause, parties are limited to FIVE such Motions, requires attaching the deposition or interrogatory excerpts relied on, and lists thirteen conditionally granted motions that should not be filed.

(2) A witness list, including only those witnesses that each party actually expects to have testify, with a brief statement of anticipated testimony, and exhibit list;

Every department order that addresses witness lists cites this subdivision by number. Depts. 16 and 34 pull the list out of the statement and require it filed and served on their own schedules.

Not less than ten (10) calendar days in advance of the first day of Trial date, the Parties shall file and serve a witness list of the witnesses that they actually expect to call as witnesses at trial (the "Witness List") in accordance with Local Rule 3.11(c)(2).

The awkward first day of Trial date is the order's own wording. The order adds that the list is for voir dire and trial length and that Omitting a name in good faith will not bar the witness from being used; this is not a discovery mechanism. Contrast Dept. 14, where only listed witnesses may testify.

Not less than five (5) calendar days in advance of the Issue Conference date, the Parties shall file and serve a witness list of the witnesses that they actually expect to call as witnesses at trial (the "Witness List") in accordance with Local Rule 3.11(c)(2).

The same paragraph adds A courtesy copy of the Witness List shall be lodged at first appearance for trial. The long cause court trial order (Attachment A, same revision date) carries the identical sentence with the voir dire purpose replaced by among other things, to estimate the length of trial. Calendar days, not the court days Local Rule 3.11(c) uses for the same five-day interval. Important limit: Judge Marquez's departmental policies state Not all cases are set for an Issue Conference and the dates and times will vary, so confirm the conference exists before counting off it.

Witness lists. Parties shall serve and file with court a list of all non-expert witnesses. Parties will be responsible for serving trial subpoenas on witnesses. Only witnesses identified on the witness list will be permitted to testify. Witness lists should include a brief statement / offer of proof summarizing the testimony anticipated to be given by each witness.

The preclusion sentence is the sharpest in the county. Depts. 16 and 34 say the opposite, that omitting a name in good faith will not bar the witness. Court trial order only; no jury trial order is posted for this department.

Witness lists for jury trials must include deposition designation time - i.e. the time to read or play deposition transcripts. For bench trials, deposition designation time estimates need not be included.

Anchor trc_date means the Pretrial Conference. The deposition designation time requirement is limited to jury trials on the face of the order; do not state it as a general witness list requirement. Attachment B gives the table: Witness, Party (P or D), Direct (min.), Cross (min.), Redirect (min.), Total, Subject. Witnesses must be listed last name first. Titles (e.g. Dr., Officer) should be placed after the comma following the last name. The reason given is machine sorting and spreadsheet addition.

(2) A witness list, including only those witnesses that each party actually expects to have testify, with a brief statement of anticipated testimony, and exhibit list;

The county rule says nothing about the form of the exhibit list, the numbering convention, pre-marking, or copies. All of that is department level. Local Court Form CV-659c asks for An exhibit list, which includes a description of each item.

Whenever possible, each party must also: (1) Pre-mark all exhibits; and (2) Give the temporary judge an exhibit list, witness list, and opening statement.

The heading confirms civil scope: Temporary Judge Trial - Civil Division, Applicable to Civil Cases (not including juvenile or family law cases). This is the only pre-marking requirement in the county rules and it reaches only temporary judge trials, which are capped at five court days with no jury option. Marked revised effective 1/1/19. Note the whenever possible qualifier, which makes it hortatory.

Not less than ten (10) calendar days in advance of the trial date, the Parties shall exchange copies of all potential trial exhibits, including discovery responses, to be used at trial, along with an exhibit list.

Exchange only, no filing. The consolidated Master Exhibit List comes out of the Advance Trial Conference three court days before trial. The order's section numbering is defective in the original: two consecutive sections are both numbered II.

Not less than seven (7) court days in advance of the trial date, the Parties shall exchange copies of all potential trial exhibits, including discovery responses, to be used at trial, along with an exhibit list.

Three court days later than Dept. 16's ten calendar day exchange. The same provision appears verbatim in the Dept. 34 long cause court trial order.

[1] One month prior to Issue Conference: parties must exchange Exhibit Lists, as described below.

Offset token -1_month means one calendar month before the Issue Conference, which is how the order words it. The earliest exhibit deadline of any Contra Costa department. Item [3] reads: When the Exhibit Lists are submitted to the Court with the Trial Brief (five court days in the advance of the Issue Conference), each exhibit must have an indication whether admissibility is stipulated, or if not, the objecting party's objections to admissibility. (E.g., foundation, hearsay, 352.) The list goes in both hard copy and Word, in a table with columns NUMBER, DESCRIPTION OF DOC, NATURE OF ITEM, plus blank IDENTIFIED, ADMISSION STIPULATED and ADMITTED columns. Exhibits themselves to be brought to court on day of trial, not to the Issue conference.

Serve trial exhibits and exhibit list on the other party. The exhibits are to be pre-marked and shall be numbered. Use numbers for Plaintiff and letters for Defendant. Exhibits should be "Bates" stamped or numbered through some sequential numbering program. (PDF generated page numbers are acceptable); If Respondent intends to present more than 26 lettered exhibits, then starting with the 27th Exhibit, Respondent shall use numbers, starting with exhibit "R500, R501, R502, etc.,"

Numbers for plaintiff and letters for defendant, the opposite of Dept. 10 and Dept. 16, which both want unified all-numeric numbering. The same section adds Submit an Exhibit List. Bring your exhibit binders with you on the 1st day of trial. Do not file the original exhibits with the clerk's office, a table of exhibits with Identified and Admitted columns for the clerk, a preference for color copies, joint exhibit marking as JE-1, JE-2, and The Court will destroy all exhibits not admitted into evidence at the close of the trial. No copy count is given for the binders. Scope caution: the only order Dept. 14 publishes is the court trial version, opening Before the long-cause trial or hearing of any issue. No Dept. 14 jury trial order is posted. All trials in Dept. 14 are in person.

No later than the first day of trial, counsel for each side must e-file a complete exhibit list in the format identified in Attachment A and witness list in the format identified in Attachment B, unless there is a stipulated joint list, in which case only one must be e-filed.

Section V carries two headings both lettered A in the original (A. Trial Date and A. Witnesses and Exhibits), so cite it by heading rather than by letter. Attachment A columns: #, Description, Date of Document, Objection to Admission? (Y/N), Date Identified, Date Offered, Date Admitted. The order bars vague entries: Entries such as "files of ABC Company," "all manufacturing formulas," or "photos of injuries" are not acceptable.

(4) A list (index) of proposed CACI jury instructions, as required by California Rules of Court, 2.1055, and copies of any proposed special instructions [note: copies of CACI instructions should not be submitted with the Issue Conference Statement.

The bracketed note is unclosed in the published text; that is the court's typography, not a transcription error. Subdivision (c) is marked revised effective 1/1/17. Dept. 32 reverses this and wants a hard copy of the full text of printed instructions plus a Word version.

(1) If any party intends to request that a specific written questionnaire be submitted to the jury, said party shall, no later than twenty (20) court days before the Issue Conference, serve a proposed questionnaire on the other parties;

The earliest deadline in the county trial-document scheme and the easiest to blow. Twenty court days before a conference that itself sits 14 calendar days before trial puts it roughly six to seven weeks out from trial.

(2) Any party objecting to any question or proposing additional questions, shall serve said objections or proposals on all other parties no later than fifteen (15) court days before the Issue Conference;

Served, not filed.

(3) All parties shall meet and confer to attempt resolution of objections and proposals no later than ten (10) court days before the Issue Conference;

(4) The questionnaire shall be submitted with the Issue Conference Statement with any unresolved questions requiring a ruling by the Court clearly identified;

Rides the Issue Conference Statement deadline in Rule 3.11(c).

(5) If the Court approves a questionnaire, it shall be the responsibility of the party submitting a questionnaire to have an adequate number of copies delivered to the office of the Jury Commissioner no later than two (2) court days before the scheduled commencement of trial, and to arrange and pay for prompt copying and distribution of the completed questionnaire to the Court and other parties in the order in which jurors will be called; and

Delivery is to the Jury Commissioner's office, not the department. Rule 3.11(e)(6) provides that noncompliance with (e)(4) or (e)(5) may result in an order that the case be tried without the use of a written questionnaire.

Not less than seven (7) court days in advance of the trial date, the Parties shall exchange copies of proposed jury instructions and jury verdict forms. The Parties may identify the California Jury Instructions approved by the Judicial Counsel by CACI number. Counsel shall meet and confer to jointly prepare proposed jury instructions for unique legal issues and/or causes of action for which CACI instructions are not applicable.

Judicial Counsel is the order's own misspelling. Para. 12 directs compliance with California Rules of Court, rule 2.1050 et seq. on form.

Following the Advance Trial Conference and the meet and confer regarding the proposed jury instructions and jury verdict forms, the Parties shall lodge a list and copies of proposed jury instructions and jury verdict forms at first appearance for trial. The proposed jury instructions and jury verdict forms shall be divided into two sets for the Court. The first set being agreed jury instructions and verdict forms and the other set being disputed jury instructions and verdict forms. Each Party's authorities on contested jury instructions are to be noted on the instructions or verdict forms. No duplicates should be provided. No "blank" or incomplete jury instructions or jury verdict forms should be provided.

The Dept. 34 jury order carries the same two-set requirement and adds a sentence Dept. 16 lacks: No party shall file or lodge jury instructions and/or jury verdict separately in any other manner.

Parties must submit a proposed verdict form both in hard copy and an electronic version in Word.

Item [9] reads: Parties are to submit a numbered list of requested CACI instructions, a hard copy of the full text of printed instructions (excluding "Directions for Use" notes), and an electronic version of the printed instructions in Word. That runs directly contrary to Local Rule 3.11(c)(4), which says copies of CACI instructions should not be submitted with the Issue Conference Statement. Follow the department.

VERDICT FORM. Each side shall attach to its issue conference statement a proposed verdict form.

Para. 4 reads: Only plaintiff need include proposed jury instructions. As to standard, unmodified CACI instructions only the index described in Calif. Rule of Court 2.1055(b)(3), as opposed to copies of the instructions, should be provided at this time. Para. 2 lifts the county page cap: issue conference statements may exceed ten pages in length, filed no later than 10 calendar days before the conference. Para. 10 waives the Rule 3.11(d) settlement statement and excuses clients with settlement authority from attending. Para. 11 requires expert depositions completed thirty days before the issue conference. Read as rendered images. Same currency caveat.

(3) A trial length estimate and a proposed statement of the case to be read to the jury, and proposed voir dire questions; and

The county rule calls for a proposed statement from each party. Depts. 16 and 34 require the parties to meet and confer and lodge a joint statement with disagreements highlighted at first appearance for trial.

The Parties shall meet and confer regarding a joint statement of the case to be read to the jury. A draft of any such statement, with any disagreements highlighted, shall be lodged at first appearance for trial.

Para. 10(h) separately requires an Other Persons List of names that might come before the jury but who will not testify, lodged at first appearance, and para. 10(g) a joint hour by hour Proposed Trial Schedule.

One month prior to Issue Conference: Mini Opening and Opening Statements (including any Powerpoint or electronic presentation proposed for Opening Statement) must be exchanged.

Offset token -1_month means one calendar month before the Issue Conference. Mini openings are capped at two minutes with no electronic presentation. No other Contra Costa department requires opening statements to be exchanged in advance.

(1) A statement of the facts, law and respective contentions of the parties regarding liability, damages (with specific dollar details), nature and extent of injuries, any unusual evidentiary or legal issues anticipated at trial, and all matters of fact believed by any party to be appropriate for stipulation;

This subdivision is the closest the county rule comes to a trial brief. The phrase trial brief appears nowhere in the 201 pages of rule text, verified by grep. Depts. 14, 16 and 32 each require an actual trial brief by their own orders.

[ ] File and serve trial brief not to exceed 20 pages

The deadline cell reads Seven (7) court days in advance of the trial. Verified by page render. The chart's own footnote calls itself a brief summary of the primary deadlines and tells counsel to review the orders and the local rules for additional information, which cuts against treating a chart-only line as the complete statement of the requirement.

Five court days prior to the Issue Conference, each party must file and serve a TRIAL BRIEF with tabbed sections containing:

This tabbed trial brief is functionally Dept. 32's trial binder. The ten items are: [1] statement of case to be read to jury, [2] motions in limine and the opposing party's answers, [3] witness list, [4] estimate of trial days, [5] whether a court reporter is being provided, [6] exhibit list, [7] witness availability, [8] interpreters, [9] CACI jury instructions, [10] proposed verdict form. The document also states All parties are required to attend the Issue Conference in person. The instructions carry no printed revision or effective date, so treat the edition as unknown.

Trial briefs: Serve briefs to each other and must be filed with the Court at least 10 days before trial. Trial briefs must summarize the outstanding issues of facts to be tried. Novel or unique issues of the law should also be briefed. Trial briefs must not exceed twenty (20) pages without leave of court. Trial briefs should contain the contested issues of fact and a statement of the relief requested. Send an electronic courtesy copy of trial brief to Dept14@contracosta.courts.ca.gov

The item sits under the heading 7 days before the date set for trial but its own text says at least 10 days. The conflict is unresolved in the document; 10 days is the safer reading and is what this row uses. The department may also require closing trial briefs, capped at 20 pages, and The Court will not deem the matter submitted until both Parties file and serve the Closing Trial Brief. Court trial order only; no jury trial order is posted for this department.

The Parties shall meet and confer to identify any portions of videotaped or other depositions or discovery to be proffered at trial as to which there are objections. All objections are to be filed and served in writing at least two (2) Court days before trial.

The order sets a deadline for objections but never fixes a deadline for the affirmative designations themselves. Compare Dept. 32, which requires designations one month before the Issue Conference, and Dept. 10, which sets final designations at the Pretrial Conference.

If the witness is to appear by video deposition or by reading of designated testimony: those portions of the video or the of the deposition transcript must be provided in writing to opposing counsel one month in advance of Issue Conference.

the of the is the order's own typographical error. The requirement sits inside the WITNESS LIST item, which also requires name, city of residence, a brief generic description of testimony, anticipated length on direct, and whether the witness appears live, remotely, by video deposition or by reading designated testimony. The order adds: Your video designations / deposition designations must be submitted in writing as part of your Trial Brief. You must indicate whether there is any objection to each portion designated.

For avoidance of doubt, unless the parties agree otherwise, parties must designate deposition designations for all affirmative presentation of evidence, even that of testifying party witnesses. The final designations are due no later than the Pretrial conference. The counter designations and objections are due to be filed no later than the first day of trial. The parties are encouraged to use the format in Attachment C to this Order,

Anchor trc_date means the Pretrial Conference. The trailing comma is in the original. Attachment C format: Proponent, Page/Line Nos., Opponent's Objection/Cross-Designation, Proponent's Response, Court Ruling. The same section sets final designations of interrogatory or RFA responses at the Pretrial Conference as well.

DEPOSITION TRANSCRIPTS. Any party who intends to read from a deposition transcript during trial shall lodge the original transcript with the Court on the first day of trial. The issue conference statement shall identify, by page and line, all excerpts that a party proposes to be read in its case in chief. At the issue conference, the Court will set a schedule for the filing of objections and counter-designations.

The Issue Conference Checklist posted alongside it carries the same practice under Depositions: Lodge originals with clerk, and As to any depositions to be used, deadline to exchange page/line; objections, counter objections; schedule hearing on objections. The checklist says on its face it is not an exclusive list, so it is an agenda rather than a source of requirements. Read as rendered images. Same currency caveat.

All motions in limine must be in writing and are to be filed and served at least ten (10) calendar days before the conference. Motions in limine should be numbered consecutively and if a party files more than five (5) motions, an index must be provided.

Calendar days, not court days, and the anchor is the conference, not the trial date. Dept. 16 re-anchors to the trial date. Dept. 32 requires motions in limine to be served and not filed. Dept. 14 requires them lodged and not filed, in one consolidated document.

Any objections to motions in limine must be filed and served five (5) calendar days before the conference, with a copy lodged with the chambers of the department to which the case is assigned.

The only county-level chambers copy requirement for trial papers. Both the Dept. 16 and Dept. 34 orders state in terms that they supersede it and substitute a tabbed, indexed binder.

Parties should not submit motions in limine upon the following topics as each fast track trial department will issue orders sua sponte as follows:

The six are witness notice by the end of the preceding court day, exclusion of witnesses from the courtroom, no reference to settlement negotiations or mediation or privileged materials, no reference to insurance or to an attorney being paid by an insurer, no reference to other claims or actions against a party without permission, and no reference to a party's financial position or wealth without permission. Dept. 10 and Dept. 16 publish their own longer lists of conditionally granted motions.

Due Date for MILs. Any motions in limine shall be filed and served not less than ten (10) calendar days in advance of the first date of trial.

Para. 5 reads Any opposition or other response to a motion in limine shall be filed and served not less than four (4) calendar days in advance of the first date of trial. The anchor differs from Local Rule 3.11(b), which runs from the conference. The chart puts the oppositions at Four (4) calendar days in advance of trial, consistent with the body.

Due Date for MILs. Any motions in limine shall be filed and served not less than ten (10) calendar days in advance of the Issue Conference date and otherwise in accordance with the provisions of Local Rule 3.11.

Para. 5 reads in full: Any opposition or other response to a motion in limine shall be filed and served not less than five (5) calendar days in advance of the Issue Conference date and otherwise in accordance with the provisions of Local Rule 3.11. This tracks Local Rule 3.11(b) exactly. Identical provisions appear in the Dept. 34 long cause court trial order.

Motions in Limine. Parties may lodge (not file) motions in limine. All motions should appear on one submitted document. By each requested motion, please insert a "decision line" as follows: "Granted ________ Denied _________ Modified ________ Reserved ________" The Parties are ordered to meet and confer in good faith to resolve motions in limine prior to the trial date.

Lettered (A) under the 7-day heading, following items (a) and (b), so the lettering is inconsistent in the original. One consolidated document, the opposite of the separate consecutively numbered motions Local Rule 3.11(b) and every other department contemplate. Court trial order only; no jury trial order is posted for this department.

If a case settles within five (5) calendar days of the trial date, counsel shall have on file a dismissal, stipulated judgment, or conditional settlement or make an appearance at the time and place designated for trial to place the settlement terms on the record.

Earlier settlements get immediate written notice plus a dismissal, stipulated judgment or conditional settlement within 45 calendar days, on pain of an OSC re sanctions, with responsive papers due 5 court days before the hearing. The rule cross-references California Rules of Court, rule 3.1385.

No refund of the jury fees deposited shall be made unless the party making the deposit has given the Jury Commissioner written notice of settlement, of the granting of a motion for continuance, or of the waiving of a jury, at least two (2) court days before the date set for trial, or by Order of Court.

The $150 nonrefundable jury fee is due on or before the date scheduled for the initial case management conference. Rule marked new effective 1/1/18.

Complex cases are subject to the procedures outlined on the Court's website concerning Complex Litigation as well as the Court's Electronic Case Filing Standing Order.

New effective 7/1/20. The rule text still points to the retired cc-courts.org URL. The live page is https://contracosta.courts.ca.gov/divisions/civil/complex-litigation. This is the clearest delegation in the rule set, and it is what makes the Dept. 16 order operative rather than advisory.

If the Court finds that any party has not proceeded with due diligence or has otherwise failed to comply with this Rule, sanctions may be imposed.

Marked revised effective 1/1/15. Rule 3.10 is a standalone rule with no other content and sits immediately before Rule 3.11 in Title Three, Chapter 1, Administration of Civil Litigation. Do not tell a practitioner this rule backstops Rule 3.11; the text does not say so and the referent of this Rule is unresolved on the face of the rule set.

Unless demanded earlier pursuant to CCP § 2034.230, the parties must disclose in writing at least 30 days before trial the identity of any expert witness including any expert report prepared by the expert or a summary of the testimony where no report has been prepared, curriculum vitae, and estimated time for the expert's testimony. Discovery must be complete 30 days before trial, except that any expert witness may be deposed as late as 10 days before trial.

An expert report requirement that the Civil Discovery Act does not itself impose. Worth flagging for any construction defect case assigned to Dept. 10. Compare the complex sample order, which puts expert depositions at thirty days before the issue conference rather than before trial.