Fresno County trial binder and trial document requirements

At the Case Management Conference, all at issue cases will be assigned a date for trial, mandatory settlement conference, and trial readiness hearing.

Chapter 2, Civil Rules, page 2-3. Verified against the July 1, 2026 master publication. Rule 2.1.9(B) deems all cases except complex litigation at issue and ready to be set for trial at the time of the CMC. Trial dates follow Plan assignment under Rule 2.1.10: Plan 1 approximately 330 days after the complaint is filed, Plan 2 approximately 480 days, Plan 3 approximately 630 days.

Except for short cause cases, the Civil Supervising Judge shall set and conduct a trial readiness hearing on the Friday prior to the date set for trial. The Civil Supervising Judge, in their discretion, may excuse a case from the trial readiness hearing.

Chapter 2, page 2-19. Offset token friday_before_trial means the Friday immediately preceding the assigned trial date, three days out for a Monday trial and four for a Tuesday trial. Rule 1.1.4 defines a short cause case as one in which the time estimated for trial by all parties is five hours or less. The rule text prints Effective January 1, 2026; the publication's own table of contents prints Eff. 01.01.25 for this rule. The court's Civil Division page adds 9:30 a.m. in Department 501 and says the hearing is required absent prior approval from the CJAP or Civil Presiding Judge. That page cites the requirement to Local Rule 2.5.8, which does not exist (Rule 2.5 runs 2.5.1 through 2.5.7); the substance is Rule 2.6.2.

Per Local Rules 2.5.5 and 2.6.2(B), and unless otherwise excused (see Local Rule 2.6.2(C)), all attorneys and parties shall be personally present for all trial related dates including Mandatory Settlement Conferences, Trial Readiness, and Trial.

Chapter 4, Rules of General Application, page 4-4 to 4-5, inside the Electronic Filing rule's Remote Appearance item. This is broader than Rule 2.6.2(B), which speaks only to the trial attorney, and it is the provision that puts the client in the room. It matters because Rule 2.6.2(E) holds a mandatory settlement conference at the time and place of the trial readiness hearing and Rule 2.5.5 governs who has to attend one. The subdivision continues: "The Court has determined that in person appearances for those matters would materially assist the Court in the determination of the proceeding and in the effective management or resolution of the case. (Local Rule 1.1.12 and Code Civ. Proc. section 367.75, subd. (b)(3).)"

No party may appear remotely unless previously approved by the Civil Supervising Judge on a showing of extenuating circumstances.

Rule 2.6.2(B) reads in full: "The trial attorney for the case shall be personally present. The only exception shall be where the trial attorney is engaged in another trial at the same time as the settlement conference, in which case another attorney from the trial attorney's office shall attend, who is fully familiar with the facts of the case and has full authority to settle and who has discussed the case thoroughly with the client prior to the settlement conference." The court's Civil Division page states that after the July 1, 2026 change, trial-related hearings including Trial Readiness still require the RA-020 Order on Notice of Remote Appearance and court approval, while ordinary hearings no longer do.

In the event that the differing versions cannot be resolved by the parties, they shall alert the Presiding Judge at the trial readiness hearing to reserve an appropriate amount of time in the assigned trial court to settle the dispute before summoning a jury panel.

The rule says Presiding Judge, while Rule 2.6.2(A) puts the Civil Supervising Judge on the trial readiness calendar. Rule 1.1.4 defines Presiding Judge as the elected Presiding Judge or a designee unless the case is filed in or assigned to a division other than the Central Division, in which case it means the judge of that division. Practically the flag goes to whoever is conducting the Friday hearing.

The court shall maintain the trial date until the trial readiness hearing unless: (1) a continuance has been granted pursuant to (D) above, or (2) a continuance is otherwise approved by the Court.

Effective July 1, 2025. The same subdivision first requires that "any party who has a conflict with the trial date shall, immediately upon having knowledge of the conflict, submit a letter to the Civil Supervising Judge and to all other parties notifying them of the conflict." Rule 2.1.10(D): "No trial date may be continued merely on stipulation of the parties. On a showing of good cause, the trial date may be continued by court order, obtained by noticed motion or by ex parte application presented to the assigned Civil Judge for All Purposes, at least five (5) court days before trial." Rule 2.1.10(E) requires a detailed factual declaration showing good cause for the delay if the application comes in with less than five court days left.

All parties to Unlimited and Limited Civil Cases for which a Trial Readiness Hearing has been calendared are required to attend a mandatory settlement conference at the time and place of the Trial Readiness Hearing. The settlement conference shall be subject to the provisions of Local Rule 2.5.5.

Rule 2.5.5 is the attendance rule, so clients, entity representatives with full authority to settle, and insurance claims employees have to be present at the Friday hearing too, not just counsel, which lines up with Rule 4.1.2(D)(7). This is a second MSC on top of the one set at the CMC under Rule 2.1.9(C), and under Rule 2.5.6(A) a settlement conference statement must be submitted anew for each additional settlement conference. Caution: the court's Civil Division page describes the same event differently, saying that at the hearing "the parties will be assigned to a further mandatory settlement conference (see Local Rule 2.6.2)," which reads as a later date rather than one held on the spot. The rule text is quoted here; the conflict is unresolved.

A mandatory settlement conference shall be held pursuant to Rule 2.5 for every civil case set for trial on the master calendar, except as follows:

Chapter 2, pages 2-14 and 2-15. Exceptions A through F: small claims, unlawful detainer and family law; short cause cases; a written stipulation filed at least 30 days before trial that the parties already did one court-supervised settlement conference; a written stipulation filed at least 30 days before trial that the parties mediated before a neutral mediator; an order for good cause on a petition to the Civil Supervising Judge filed and served at least 30 days before trial, with any opposition due within 10 days of service and no oral argument; and failure to comply with Rule 2.4.2. Requests to move an MSC date go to the ADR Department at least 30 days out under Rule 2.5.4(A).

In all cases set for a settlement conference where the parties are not excused from attending the settlement conference, the parties shall meet and confer prior to the date set for the settlement conference in a good faith attempt to settle all issues. The requirement of this rule is met by a face-to-face meeting between the parties, or by engaging in mediation before a neutral mediator.

The rule sets no number of days, only that it happen before the conference date, which is why the offset is see_rule. The last sentence of subdivision (A) reads "Communication by writing will not suffice." Subdivision (B) requires that the fact of compliance and the results be set out in the settlement conference statement.

Each party shall submit their settlement conference statement to the ADR Department and serve on all parties, in pleading or letter form, preferably at least ten (10) days prior to the settlement conference, but no later than five (5) court days prior to the settlement conference.

Submitted to the ADR Department, not filed. The same subdivision adds: "Settlement conference statements will be marked as received and will not be kept in the court file, and must be submitted anew for each additional settlement conference." That clause matters because of the second MSC at the trial readiness hearing under Rule 2.6.2(E). Rule 2.5.6(B) requires eight items beyond California Rule of Court 3.1380(c): names of parties and attorneys; whether an insurance carrier employee must appear and the carrier's identity; whether a board, council or committee must approve settlement and its identity; whether a non-party's consent is needed and who; the fact and results of the Rule 2.5.2 meet and confer and of prior mediation or arbitration; prior settlement negotiations; Code of Civil Procedure section 998 demands; and whether further discovery is contemplated and a description of it.

At least ten (10) court days prior to the Mandatory Settlement Conference, the parties shall file an Alternative Dispute Resolution Status Report (TADR-03 form) designated by the Court. Parties who fail to file the ADR Status Report may be subject to sanctions at an OSC hearing held on the same date as the Trial Readiness hearing, or as otherwise set by the Court.

Chapter 2, page 2-14. The sanction hearing is expressly tied to the trial readiness hearing date, so an unfiled TADR-03 turns that Friday into an OSC.

All parties must engage in some form of Alternative Dispute Resolution (ADR), such as mediation. The selected ADR process must be completed prior to the Mandatory Settlement Conference. Failure to do so may result in the Court imposing sanctions, unless excused by the Court upon a timely showing of good cause by written declaration.

Offset token before_msc means completed at some point before the MSC date, with no fixed interval given. Read with Rule 2.5.1(F), which makes failure to comply with 2.4.2 an exception to holding an MSC at all. Rule 2.4.3 separately requires a Stipulation regarding ADR on form TADR-01 filed at least ten court days before the Case Management Conference, with sanctions at an OSC for failing to file it.

Petitioner shall prepare a "hard copy" trial notebook that must be submitted when its opening brief is filed. The trial notebook must consist of the petition, all answers, the opening brief, any motions set to be heard at trial, the statement of issues, and any other documents agreed upon by the parties.

Chapter 2, Rule 2.11, Cases Involving the California Environmental Quality Act, page 2-30, effective January 1, 2021. A civil rule in the civil chapter, but confined to CEQA writ proceedings. It does not reach an ordinary civil trial. Offset token with_opening_brief resolves through Rule 2.11.5(A) to at least 45 calendar days before the merits hearing. Rule 2.11.5(A) confirms the carve-out: "Except for the trial notebook and appendix of excerpts requirement in Local Rule 2.11.6, papers must be filed in the same manner as for general civil unlimited cases."

The trial notebook shall contain a table of contents, tabbed sections consistent with the table of contents, and an index of the documents in the notebook referencing page numbers. The notebook's pages shall be sequentially numbered in the lower right-hand corner of each page and be bound in a "D-ring" binder no more than three (3) inches thick. Should documents dictate, further notebooks with the same features should be used.

This is the only physical binder specification printed anywhere in the Fresno local rules, and it applies to CEQA only. One copy, hard copy, prepared by the petitioner. Nothing equivalent exists for a general civil trial, where the closest analogue is the electronic bookmark and index requirement in Rule 4.1.2(D)(5).

The court requires that each party filing a brief prepare and submit a separate "hard copy" appendix of excerpts that contains the documents or pages of the record of proceedings cited in that party's brief. The appendix shall be submitted when that party's brief is filed.

Unlike the trial notebook, this binds every briefing party, not just the petitioner, and the due date moves with that party's own brief: opening at least 45 days before the hearing, opposition at least 25 days, reply at least 15 days under Rule 2.11.5(A). The subdivision allows a cover page or other pertinent pages for context even if not cited.

The trial notebook and appendix of excerpts of exhibits are neither lodged nor filed. Instead, the party responsible for preparing the notebook and appendix shall call the Research Department Office Assistant at (559) 457-4945 to arrange delivery of the items. Do not send items via mail or overnight delivery service without prior arrangement.

The subdivision's first sentence states the purpose: "The court requires a separate trial notebook and separate appendix of excerpts to provide the court with easy-to-use binders containing the pleadings, motions, briefs, and cited portions of the record of proceedings supporting the parties' respective positions." The record of proceedings itself goes the other way and is filed electronically with bookmarks under Rule 2.11.4.

All exhibits, regardless of who marks them, shall be marked in numerical order. The exhibits must be separated by tabs indicating their number.

This is the actual trial-binder answer for Department 501, and it comes off the court's own website, not the local rules. Two sentences later the department adds, in a separate sentence: "Exhibits shall be provided to the court in one or more binders, as necessary." The department also requires: "Exhibits shall be exchanged between counsel before commencement of trial and must be pre-marked; preferably in the anticipated order or presentation to the extent possible. Trial will not begin until this is completed." Photographs are marked as separate exhibits. No copy count is given.

The court should be provided with 5 sets** from each proponent, or one if joint: 1) Official, 2) Court, 3) Witness, 4) Opposing Counsel, 5) Proponent.

Identical sentence on both department listings. Department 502 appends the footnote "(** this does not apply to photographs that will be shown electronically )"; Department 503 carries the asterisks with no footnote text. Both add: "The court does not separate, nor receive into evidence, part of an exhibit," and both direct counsel to have five extra copies of any single page they may need offered as the next exhibit in order. This is the only exhibit copy count published anywhere by this court.

At the outset of the pretrial conference, all exhibits must be exchanged between counsel and submitted to the clerk.

The strictest of the four departments on timing: the exhibits themselves, not just the list, are due at the pretrial conference. Later sentences in the same block: "Multiple page exhibits must be separately bound or included under a separate tab in a binder and each page must be separately numbered"; "Duplicate sets of exhibits must be prepared for each counsel, the court, the clerk and the witness"; and "Photographs shall be Bates-stamped, presented in clear slip-covers or 3-hole punched so that they may be placed in an exhibit binder." Anchored to department_order rather than trc_date because the department page never uses the local rule's name for the event. All four departments use the phrase pretrial conference, the local rules never do, and whether the two are the same event is unresolved. Confirm with the department before computing a date.

In all civil cases, except short cause cases, the attorneys for the parties shall meet and confer at least five (5) days prior to the date set for trial in order to accomplish the following:

Chapter 2, page 2-18. The rule says days without qualifier, and Rule 1.1.4 defines court day and business day separately, so calendar days is the reading, but the rule does not say so. Rule 1.1.4 also defines meet and confer as a telephone conference or, whenever reasonably possible, a face-to-face meeting, and says an exchange of letters does not satisfy it. Practical squeeze: the trial readiness hearing is the Friday before trial, so the five-day meet and confer falls one day before that hearing for a Tuesday trial and two days before it for a Monday trial.

The foregoing papers shall be e-filed before trial readiness and submitted to the assigned trial judge immediately after trial readiness per Local Rule 2.6.2D.

This is the closest thing Fresno has to a trial-binder delivery rule, and it is two steps: e-file first, then get the papers into the assigned trial judge's hands right after the Friday hearing. The rule fixes no clock time for the e-filing and does not say whether the submission to the trial judge is paper or electronic. Electronic filing is mandatory for represented parties in all civil actions under Rule 4.1.2(A)(1), and the e-filed version must meet the Rule 4.1.2(D)(5) format. Under Rule 4.1.2(D)(4), anything received electronically between 12:00 a.m. and 11:59:59 p.m. on a court day is deemed filed that day.

The Court requires that electronic filing of documents be effected using a fully searchable .pdf file and include electronic bookmarks to each heading, subheading and component (including the table of contents, table of authorities, petition, verification, points and authorities, declaration, and proof of service if included), and to the first page of each exhibit or attachment, if any.

Chapter 4, Rules of General Application, page 4-3. Applies to the Rule 2.6.1 papers because Rule 2.6.1(E) requires them e-filed and Rule 4.1.2(A)(1) makes e-filing mandatory for represented parties in all civil actions. The subdivision continues: "Each bookmark to an exhibit or attachment shall include the letter or number of the exhibit or attachment and a description of the exhibit or attachment. If exhibits or attachments are submitted in multi-part electronic files, each separate file must have its own table or index of the contents of the file." This is the electronic analogue of tabs and an index, and it is the only such requirement that reaches an ordinary civil trial set.

The parties shall provide the Court with the following documents at the Trial Readiness Hearing: motions in limine, motions for judgment on the pleadings, proposed jury instructions, a joint neutral statement of the case, trial briefs, exhibit lists and witness lists.

This is the operative trial-document list for Fresno and the row a practitioner needs most. It is a delivery obligation at the Friday hearing, not a filing deadline; the filing deadline is Rule 2.6.1(E). This subdivision itself specifies no copy count, no tabs, no index, no binder and no paper-or-electronic instruction. Format for the e-filed version comes from Rule 4.1.2(D)(5). Verdict forms are not on this list, which is a real gap against Rule 4.1.9(E) and against all four departments, each of which requires verdict forms with the instructions. The court's Civil Division page describes the hearing as one where the parties are expected to acknowledge that they met and conferred under Rule 2.6.1 and are "prepared to provide all pre trial documents to the court including Trial Briefs, in limine motions, jury instructions etc."

If lodged for trial, is marked "LODGED FOR TRIAL [date] [department] - DO NOT FILE;"

Chapter 4, page 4-7, effective January 1, 2021. Rule 4.1.4(B) opens: "Records may be lodged with the court by submitting them to the court electronically through the court's e-filing system or physically through the clerk's office or drop box." Subdivision (B)(1) requires the cover sheet to contain all the information required on a caption page under California Rule of Court 2.111. Rule 4.1.4(D) requires lodged records to arrive with a self-addressed envelope with sufficient postage or an attorney service pick-up slip, because they are returned after the calendared matter resolves. This is the nearest Fresno gets to a delivery-and-return procedure for a trial set of materials.

When submitting records for lodging through e-filing, the filing party must provide the following information in the "Comments to Court" field, as applicable: 1) the reason for lodging (ex. pending motion to seal, lodged for trial); and 2) any related court date (ex. motion on [date], trial: [date]). Records not designated "confidential" in the e-filing process will automatically be accessible to the public.

Rule 4.1.4(C) adds a hard limit that matters for large trial sets: "The clerk's office will not accept electronic storage media for lodging in any unlimited civil or limited civil action, unless pursuant to a court order." The rule defines the term to include internal and external hard drives, CDs, DVDs, floppy disks, USB drives, ZIP disks, magnetic tapes and SD cards. Rule 4.1.4(B)(3) also directs that nothing be mailed or sent by overnight service to a clerk's office or department without prior arrangement, and Rule 4.1.4(B) carries a rejection consequence for failing to use the California Rule of Court 2.551(d) lodging procedure.

If a party cites to out-of-state cases, statutes or rules, or authority cited through a "Lexis" or "Westlaw" citation, a copy of each authority shall be lodged in a separately bound appendix of authorities, and each authority shall be tabbed and indexed as an exhibit as required by California Rules of Court, rule 3.1110(f).

Chapter 2, page 2-13, under Rule 2.2 Civil Law and Motion, effective January 1, 2013. This is the only physical tabbing and indexing requirement in the Fresno civil rules outside the CEQA trial notebook. (The two other tabbing rules in the publication, 3.3.2(D) and its companion, are criminal.) It travels with the paper it supports, so a motion in limine relying on an unreported or out-of-state case picks it up.

The parties shall provide the Court with the following documents at the Trial Readiness Hearing: motions in limine, motions for judgment on the pleadings, proposed jury instructions, a joint neutral statement of the case, trial briefs, exhibit lists and witness lists.

Separated out because the witness list is the one document on the 2.6.2(D) list that appears nowhere in Rule 2.6.1. No county rule requires witness lists to be exchanged between counsel beforehand and none states what a witness list must contain. Departments 502 and 503 require a joint alphabetical list by last name, 503 wants 30 paper copies on one sheet, 502 wants MS Excel, 403 wants a manipulable electronic format, 501 wants it Elmo-displayable or on a thumb drive, and 502, 503 and 403 require a separate joint statement carrying a witness-by-witness time estimate.

Counsel must jointly prepare and provide the clerk with a list of prospective witnesses prior to beginning jury selection. The list should be provided in a manner that can be displayed on the Elmo machine in the courtroom. Alternatively, counsel may submit a thumb drive or other disc with the prospective witnesses' names for display to the jury.

Separate from the Rule 2.6.2(D) witness list handed up at the trial readiness hearing. The department also requires: "Counsel must identify which witnesses will be testifying each day. Counsel must notify opposing counsel which witnesses will be called the next day before leaving the courtroom for the day."

The parties must file the joint statement or separate statements described above no less than five (5) days prior to the trial date or pretrial conference

The quoted sentence ends with a dashed clause reading "whichever is first," elided here to hold house style; nothing else is cut. Whichever is FIRST means the earlier of the two computed dates, and since the pretrial conference precedes the trial date, five days before the pretrial conference is always earlier than five days before trial. If the pretrial conference is the Friday trial readiness hearing, the deadline lands roughly eight or nine days before trial. Do NOT compute this as five days before trial. The three required contents are quoted as printed: "The total number of hours needed, per party, to try the case; A witness list with the name of each witness to be called on direct, a brief description of the general subject matter of the witness' testimony, the number of hours of direct examination that will be required for that witness, and The total number of hours of cross-examination contemplated/required by opposing party(ies)." Department 403 has the same instrument under the name Joint Statement re Trial Time Estimates and takes it at the outset of the pretrial conference. Whether the pretrial conference is the Rule 2.6.2 trial readiness hearing is unresolved; confirm with the department.

Counsel shall provide the clerk and the reporter with a list of prospective witnesses in alphabetical order

The sentence continues, after a dashed aside reading "by last name" that is elided here for house style: "in MS Excel format so that they may be shown through the court's electronic display for jury selection." The exhibit companion reads: "Counsel shall provide the clerk with a list of exhibits by number and unique name in MS Excel format." Department 503 wants the exhibit list "by number" with no Excel requirement.

The list should be reduced to one side of a single piece of paper. Counsel should provide 30 copies of the witness list for purposes of jury selection.

The preceding sentence reads "Counsel shall provide the clerk and the reporter with a joint list of prospective witnesses in alphabetical order" followed by a dashed "by last name" aside. This is the only paper copy count for a witness list published by the court.

At the outset of the pretrial conference, counsel must provide to the court a jointly prepared list of prospective witnesses in an electronic format suitable for the court to manipulate for eventual publication to the jury panel during voir dire.

Paired with the department's Joint Statement re Trial Time Estimates, also due at the outset of the pretrial conference, which must set out "A witness list with the name of each witness to be called on direct and the number of hours of direct examination that will be required for each witness, and The total number of hours of cross-examination and re-direct examination contemplated for each witness." Same caveat as the row above on whether the pretrial conference is the Rule 2.6.2 trial readiness hearing.

The parties shall identify and list the proposed exhibits, and exchange such lists.

The county rule requires lists only, not the exhibits themselves and not a joint list. Every one of the four published department procedures goes further: Departments 501 and 403 require a single joint exhibit list, 502 requires the list by number and unique name in MS Excel, 503 requires it by number, and 502 and 503 require five physical sets of the exhibits.

Counsel shall jointly prepare a single, joint exhibit list which accurately describes each exhibit being marked.

Two sentences down, after the binders sentence and a meet-and-confer sentence on foundational issues, the department continues: "The specific objection and which party is objecting shall be listed next to the description of the exhibit on the joint exhibit list. If objections are not noted on the joint exhibit list, objections may be waived. This must be submitted to the court prior to the parties calling their first witness." The waiver consequence is stated by the department and appears nowhere in the local rules. Department 403 has the parallel requirement: "Counsel must jointly prepare a single exhibit list which accurately describes each exhibit submitted to the clerk."

If a jury has been requested, the parties shall prepare and exchange proposed jury instructions and shall prepare a jointly signed neutral statement of the case.

Rule 2.6.1(B) conditions the instructions on a jury having been requested. Rule 2.6.2(D) lists proposed jury instructions among the documents handed to the court at the trial readiness hearing without repeating that condition. Rule 4.1.9(A) separately requires proposed instructions submitted to the trial judge on the first day of trial. Three provisions, three different moments, and the departments add a fourth.

Where there is a trial by jury, the parties shall request instructions by submitting proposed instructions to the trial judge on the first day of trial. The latest edition of CALCRIM or CACI (Judicial Council of California Civil Jury Instructions) forms shall be used wherever applicable.

Chapter 4, Rule 4.1 Rules of General Application, page 4-11. Applies to civil and criminal alike, and subdivision (E) expressly addresses civil cases. This is later than Rule 2.6.2(D), which puts proposed instructions in the hands of the Civil Supervising Judge at the Friday hearing, and later than three of the four departments, which want them before the first witness is called. Rule 4.1.9(B) requires modified pattern instructions to clearly indicate the change, and 4.1.9(C) requires every blank in a CACI form to be filled in.

Instructions shall be submitted either on a form with a detachable top or in a multi-page format. If a form with a detachable top is used, the top portion of the instruction shall contain the name of the party upon whose behalf it is requested and citation to supporting authority. If that instruction is used, the detachable bottom of the form will be given to the jury for use during deliberations.

The subdivision continues: "If a multi-page format is used, one page shall contain the name of the party upon whose behalf it is requested and citation to supporting authority. A separate page or pages shall contain the instruction itself. If that instruction is used, only the page or pages containing the instruction itself will be given to the jury for use during deliberations." Departments 502, 503 and 403 add a requirement of two packets, agreed and objected to, and require the objecting party to submit a non-objectionable alternative or a written legal basis.

Jury instructions and verdict forms must be submitted before the second week of trial, or on the second day of trial if the trial is expected to last less than one week. Counsel must meet and confer and submit a list of all requested instructions to which there is no objection and a separate list of instructions as to which there are objections. If objections are made to any jury instructions on other than relevancy grounds, the objecting party must also submit an instruction that is believed to be non-objectionable.

Department 501 is the outlier. Departments 502, 503 and 403 all require jury instructions and verdict forms before the first witness is called. All four are later than Rule 2.6.2(D), which puts proposed instructions in front of the Civil Supervising Judge at the Friday trial readiness hearing, and Rule 4.1.9(A) puts them in front of the trial judge on the first day of trial.

Jury instructions and verdict forms must be submitted before the first witness is called. Counsel must meet and confer and submit a packet of all requested instructions to which there is no objection and a separate packet of instructions to which there are objections. If objections are made to any jury instruction on other than relevancy grounds, the objecting party must also submit an instruction that is believed to be non-objectionable. Each instruction must indicate the party or parties requesting it and have all blanks properly completed and irrelevant portions redacted.

Quoted from the Department 502 and 503 text, which is word for word identical between those two departments. Department 403's version differs only in small wording ("as to which there are objections," "all blanks must be filled in and any irrelevant portions redacted"). Departments 502 and 503 also carry a second, earlier jury-instruction paragraph under Documents and Court Processes requiring a page or pages listing the CACI numbers requested, separate from the completed forms, and requiring the objecting party to submit its legal basis in writing before the end-of-trial instruction conference.

In civil cases each party shall submit proposed verdict forms suitable for used by the jury in the pending case.

The typographical error "suitable for used by the jury" is in the published rule and is quoted as printed. The subdivision continues, after an intervening sentence on criminal cases: "Each verdict must be submitted on a separate form, must contain the caption of the case, and must not indicate the party upon whose behalf the verdict is submitted." Rule 4.1.9 gives no separate due date for verdict forms, so the first-day-of-trial timing in 4.1.9(A) is the closest anchor the county rule supplies. All four published department procedures pull verdict forms earlier and pair them with the jury instructions.

If a jury has been requested, the parties shall prepare and exchange proposed jury instructions and shall prepare a jointly signed neutral statement of the case.

The rule says prepared and jointly signed. Rule 2.6.2(D) calls it a joint neutral statement of the case among the documents given to the court at the trial readiness hearing. The rule prescribes no length. Departments 501, 502, 503 and 403 each add their own requirement on the same document, and 502, 503 and 403 all say they prefer a mini-opening instead.

A short, non-argumentative statement of the case for reading to the jury during jury selection must be jointly filed at the same time as motions in limine are filed. Alternatively, counsel may prepare and deliver a brief (less than 5 minutes) mini-opening to the jury prior to selection.

Offset token before_trc means at some point before the Friday trial readiness hearing, with no clock time fixed. The department ties this document to when the motions in limine are FILED, and the only provision in the rule set that fixes that is Rule 2.6.1(E), which requires the Rule 2.6.1 papers e-filed before trial readiness. Do not compute this off Rule 2.6.1(A), which sets a five-day EXCHANGE date between counsel, not a filing date. Department 403 puts its version at the pretrial conference: "In the alternative, at the outset of the pretrial conference counsel must submit to the court a short, jointly prepared and neutral statement of the case for reading to the jury panel during jury selection." Departments 502 and 503 prefer mini-openings and take the joint statement only as the alternative.

If a jury has not been requested, the parties shall prepare and exchange trial briefs. The trial court will not accept trial briefs not exchanged except for good cause shown.

By its terms a court-trial requirement only. Rule 2.6.2(D) nevertheless lists trial briefs among the documents to be provided at the trial readiness hearing with no jury-versus-court-trial qualifier, so a jury-trial practitioner should expect to be asked for one. No page limit appears anywhere in the civil rules for a trial brief. Format is not wholly unregulated, though: because Rule 2.6.1(E) routes these papers through e-filing, Rule 4.1.2(D)(5) governs the pdf, bookmarks and exhibit index.

The opening memorandum of points and authorities shall be filed at least forty-five (45) calendar days prior to the hearing date; and opposition shall be filed at least twenty-five (25) calendar days prior to the hearing date; and the reply shall be filed at least fifteen (15) calendar days prior to the hearing date.

Included because it fixes the due date for the CEQA trial notebook. The subdivision opens "Unless otherwise ordered by the court." Opening and opposition cap at 30 double-spaced pages (22 at one and a half spacing), reply at 20 double-spaced pages (15 at one and a half), and the court states a preference for double spacing. An application to exceed goes directly to the judge assigned for all purposes without a hearing under Rule 2.7.2 and must attach the party's Public Resources Code section 21167.8 statement of issues. These are the only briefing page limits in the Fresno civil rules.

Counsel shall lodge with the clerk all depositions to be used in the trial. No reading from depositions (other than for purposes of impeachment) is permitted without first giving the court and opposing counsel notice of each page and line reference intending to be read. Certified copies are acceptable as long as the parties so stipulate.

The department adds a waiver consequence for objections: "If deposition transcripts are to be read to the jury, counsel are expected to meet and confer in advance regarding any objections that will be offered to any of such testimony so as not to take up the time of the court or the jury. If objections to any of the testimony are raised, they must be addressed outside of the jury's presence and without inconveniencing the jury. Failure to comply with this rule may result in counsel waiving objections to the testimony." Department 403 has the same structure: "Before reading from any deposition transcript, counsel must lodge with the clerk the original of the deposition transcript to be read from," plus "No reading from deposition transcripts (even for the purpose of impeachment) is permitted without reasonable advance notice of each page and line reference to the court and other counsel." Nothing in the county rules addresses deposition designations at all.

All in limine motions and motions for judgment on the pleadings shall be in writing and exchanged by the parties. The trial court will not hear oral in limine motions or those not exchanged except for good cause shown.

This subdivision sets an exchange obligation and a refusal-to-hear consequence. It sets no filing deadline, no opposition deadline and no page limit. The filing step comes from Rule 2.6.1(E), which requires the papers e-filed before trial readiness, and the delivery step from Rule 2.6.2(D), which requires them handed to the court at the Friday hearing. Do not read the five-day exchange date as a filing date.

Any party intending to offer a sound recording in evidence at trial shall prepare a transcript of the sound recording and serve such transcript and a copy of the recording on all other parties at least two (2) weeks before trial.

Chapter 4, page 4-11, effective January 1, 2025. This is the earliest hard trial-preparation deadline in the Fresno rules, nine days before the Rule 2.6.1 meet and confer. Rule 4.1.10(D) requires the transcript to identify its preparer and, for a non-English recording, to carry a translator's certification. Rule 4.1.10(E) requires the propounding party to prepare a sufficient number of copies for distribution as ordered by the court.

Any party disputing the accuracy of the transcript shall prepare his or her own transcript of the sound recording identifying the disputed portions and serve that transcript on all other parties no later than three (3) days before trial. When disputed, the parties shall meet and confer in a good faith effort to resolve their differences.

Three days before trial falls after the Friday trial readiness hearing for a Monday or Tuesday trial, which is why subdivision (B) requires an unresolved dispute to be flagged at the hearing itself.

Permission from the judge assigned to the hearing or trial must be obtained before a party may bring dangerous, large or bulky exhibits into the courthouse.

Chapter 4, page 4-12. The rule lists inherently dangerous items (firearms, explosive powder, explosive chemicals, explosive devices, flammable liquids, tear gas canisters, soaked rags, liquid drugs, bodily fluids, controlled or toxic substances, corrosive or radioactive substances) and then large and cumbersome items such as a ladder, sewer pipe or automobile chassis. If no substitution is made, "an application for permission must be made in writing and describe the materials to be brought into the courtroom and the reason a substitution should not be made." No lead time is given, so this has to be raised at or before the trial readiness hearing as a practical matter.