Sacramento County trial binder and trial document requirements

The Court will issue a minute order setting the Mandatory Settlement Conference in Department 59, a Final Status Conference, a Final Pre-Trial Conference, and the trial date. The minute order will also address deadlines for trial-related tasks and filings, including motions in limine, witness and exhibit lists, proposed jury instructions, jury questionnaires, etc.

Where a complex construction defect or class matter actually lives, and the only place in Sacramento that a Final Status Conference exists. The complex department is also the trial department, paragraph 16(b): "Pursuant to the Presiding Judge's Notice and Order of Complex Case Determination, this Court is the trial department for this case. This Court remains the trial court unless subsequently ordered otherwise." No interval before trial is published for the FSC or the Final Pre-Trial Conference, so the minute order is the only source and the lead time is case by case. Standing order numbered 2024; the signature date extracts as "DATED: ___, 2024" with the month and day illegible in the PDF text layer. Verified independently against the court's standing order index: SSC-24-6 is the only civil trial-related standing order published, the other trial orders being SSC-20-6 and SSC-22-4, both criminal.

All long cause civil matters heard at the Tani Cantil-Sakauye Sacramento Courthouse shall participate in the Mandatory Settlement Conference program, unless ordered exempt by the court. The mandatory settlement conference shall be scheduled in the Civil Settlement Conference Center on the 6th floor, approximately 30 court days before trial.

The rule says "approximately," so 30 court days is a planning figure and not a computed deadline. Full final sentence of the subdivision, which the draft shortened: "A trial date settlement conference may be scheduled at the discretion of the Supervising Settlement Judge or the Presiding Judge or their designee." Note the scope conflict: Rule 2.80 opens "All long cause civil matters shall be included in the Mandatory Settlement Conference Program" with no courthouse limitation, while this subdivision limits it to the Tani Cantil-Sakauye Courthouse. Long cause only; short cause civil trials are outside this program. Rule 2.93 revised July 1, 2026.

The declaration shall be submitted to the Supervising Settlement Judge at least 20 days prior to the scheduled Mandatory Settlement Conference.

Added on review. The draft cited Rule 2.80 only as a note reading "Rule 2.80 covers exemption from the program" and omitted the deadline entirely. Calendar days, anchored to the MSC and not to trial. Rule 2.80 sits in Chapter 2 Part Five (Alternative Dispute Resolution), not Part Seven, but it governs the MSC program. Its opening sentence is the one in tension with Rule 2.93(B): "All long cause civil matters shall be included in the Mandatory Settlement Conference Program." Prior mediation participation is a precondition to asking. Revised January 1, 2025.

Not less than 10 days prior to the scheduled settlement conference, each party shall ensure that an original and one copy of the Settlement Conference Statement is received by the clerk of the Supervising Settlement Judge and received by every other party.

Calendar days, and the anchor is the MSC, not trial. Receipt, not service or mailing, is the operative event. Same subdivision: "The Supervising Settlement Judge, in his/her discretion, may order a settlement conference statement stricken that fails to comply with these rules (including untimely filing) and may impose appropriate sanctions." Rule 2.94(H) provides the court "shall not waive the provisions of subdivision (D) relating to settlement conference statements in the absence of extraordinary circumstances." A format example is on the court's website. Rule 2.94 revised July 1, 2026.

Prior to the first day of trial, the parties shall prepare binders containing copies of the agreed exhibits for use by the trial judge, clerk, and counsel during trial.

A joint obligation ("the parties shall prepare binders"), not one binder per side, and the contents are the agreed exhibits. No number of sets stated, only three named users. No tabs, index, table of contents, cover format or pagination specified, and no electronic alternative. No delivery location or hour. "Prior to the first day of trial" fixes no number of days. The Presiding Judge page tightens the timing: "At or before the pretrial conference, the parties shall submit binders containing copies of the agreed-upon exhibits for use by the judge, clerk, and counsel during trial." Rule 2.99.03 lets the assigned trial judge impose different requirements, so confirm with the department.

The above rules shall not prevent any trial judge to whom a case is assigned from adopting such supplemental, additional or different pretrial orders as may appear necessary or appropriate.

The express delegation covering all of Part Nine. "The above rules" reaches Rules 2.95 through 2.99.02. This is why the Presiding Judge page can reset the Part Nine deadlines from "first day of trial" to "at or before the pretrial conference." Rule 2.99.04, the next rule in the part, is "(Suspended effective March 31, 2022)" and carries no text, so the operative Part Nine span is 2.95 through 2.99.03 even though the Presiding Judge page cites "Local Rules 2.95 through 2.99.04."

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

The most important practical point for Sacramento. Read the rules alone and everything looks due on the first day of trial. The court's own page says the trial department expects all of it at or before the pretrial conference, a date set department by department after trial assignment or pre-assignment. The page closes the section: "Please refer to Local Rules 2.95 through 2.99.04 for specific information on filing guidelines and requirements for civil trials." The page also warns that trial may not start immediately on assignment: "The trial department may not be able to start jury selection immediately if, for example, there are several motions in limine to resolve, the court orders one or more Evidence Code section 402 hearings, a jury panel is not available, or if the trial judge has other matters on its calendar that must fit into the schedule."

Transcripts of Recordings: If any electronic sound, including video, audio recordings, or computer animations, will be presented, provide the Court and counsel with a transcript at the pretrial conference. Notify the court and opposing counsel before trial if you are requesting to provide the jury with a transcript of any recording to be played. Have 20 copies of the transcript available for the court, clerk, jurors, alternates, counsel, and the court reporter.

The only place the court publishes a hard copy count for anything at trial, and it is 20 for recording transcripts, not for exhibit binders. Same source: "Per California Rules of Court 2.1040 , the court reporter need not transcribe any audio or video where a transcript is provided."

The following documents shall be filed directly in the assigned complex department: i. Post trial motions, oppositions, and replies ii. Documents for trial iii. Final pretrial readiness conference statements iv. Class action and PAGA requests for dismissal

Roman numerals reconstructed from the PDF text layer, which renders them as 1, 11, 111, 1v. The substance of the four items is exact. A "final pretrial readiness conference statement" is a complex-only document and appears nowhere in the local rules, with no published content, length or deadline. Same paragraph: "Courtesy copies shall be emailed directly to the assigned department." The filing addresses in that paragraph point to the Civil Filing Counter at the Gordon D. Schaber County Courthouse, 720 9th Street, Room 102, while SSC Rule 2.02 gives the general civil filing address as 500 G Street, so confirm the counter before delivering in person.

(A) The parties shall meet and confer and prepare a joint witness list. (B) On the first day of trial, the parties shall submit to the court an alphabetized, joint witness list.

That is the complete text of Rule 2.99, two subdivisions and nothing more. Note what it does not require: no advance exchange deadline, no offer of proof, no time estimate per witness, no expert designation. The Presiding Judge page moves the submission forward: "the parties shall submit this list to the trial department at or before the pretrial conference," and separately requires the parties to be ready to discuss "The approximate anticipated length of each witness's testimony, and any need for interpreters, claim of privilege, child witness, etc." at the conference.

The parties shall meet and confer to identify those exhibits that may be admitted without objection and those exhibits as to which admissibility is contested.

No deadline stated, but it has to precede the binders under subdivision (B), which are due prior to the first day of trial. This subdivision requires no exhibit list. The joint exhibit list requirement comes from the Presiding Judge page only (separate row).

At or before the pretrial conference, the parties shall submit binders containing copies of the agreed-upon exhibits for use by the judge, clerk, and counsel during trial. The parties shall also submit a joint exhibit list in Word format.

The joint exhibit list is NOT in SSC Rule 2.98. It exists only in the court's department guidance, which SSC Rule 2.02 directs practitioners to. Word format, same as the jury instructions. Long cause track; short cause civil trials have their own exhibit submission deadlines under a different section of the same page (separate row).

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

Added on review. The draft omitted this entirely while quoting the same page seventeen times, and its negatives read as though nothing is due before a civil trial except the Part Nine documents. Offset token defined here: two alternative methods with different intervals, seven calendar days by email and fourteen calendar days by postmark for mail, and the POS-030 must be RECEIVED seven calendar days before. Calendar days, not court days. Express consequence on the same page: "If any party fails to submit their exhibits to the court and to the opposing party in compliance with the deadlines indicated in the Notice of Hearing, such failure may result in the court not considering the party's exhibits or in a continuance of the short cause trial." That sentence also points to the case-specific Notice of Hearing, which the court says indicates "pretrial requirements," so the notice controls and its contents are not published. Short cause civil trials are heard Thursday at 8:30 a.m. and are excepted from Rule 2.92 readiness notification.

On the first day of trial, the parties shall submit to the assigned trial judge in electronic (word) form: (1) a fully completed set of agreed upon jury instructions; and (2) all jury instructions that the parties cannot agree upon. If pinpoint or special jury instructions are offered, counsel shall provide case or statutory authority for the offered instruction following the text of the instruction.

Subdivision (A) is the meet and confer and carries no stated deadline: "The parties shall meet and confer to identify jury instructions the parties can agree upon and jury instructions the parties cannot agree upon." Word is the only electronic format Part Nine requires anywhere. The Presiding Judge page pulls the submission forward: "At or before the pretrial conference, the parties shall submit to the assigned trial judge in Word format ..." Work to the pretrial conference date where one is set.

Verdict Forms: Whether special verdict forms are necessary, and if so, what language the parties propose.

A readiness-to-discuss item, not a filing deadline. Verified independently: a full-text search of the local rules for "verdict" returns exactly one hit, and it is in Rule 1.08 (Voir Dire Juror Questionnaire) in Chapter 1 General Rules, reading "Upon a verdict being rendered in a criminal case, counsel shall return to the court clerk all of their copies of the juror questionnaire forms of the sworn jurors." That provision concerns juror questionnaire handling, not verdict forms, so no civil verdict form requirement exists in the rules. The draft placed this hit in Chapter 10; it is in Chapter 1. Bring proposed special verdict language to the pretrial conference anyway.

(A) The parties shall meet and confer to agree on a joint statement of the case. (B) The parties shall submit the joint statement to the assigned judge on the first day of trial. If the parties cannot agree on a joint statement, each party shall submit its proposed statement to the trial judge.

The complete text of the rule. Joint by default with a built-in fallback to competing statements. The Presiding Judge page moves it to "at or before the pretrial conference" and keeps the same fallback.

On the first day of trial, each party shall submit a trial brief.

That one sentence is the entire rule. Per party, not joint, and mandatory ("shall"). The Presiding Judge page moves it forward: "Each party shall submit a trial brief at or before the pretrial conference."

Testimony through Discovery: If either party wishes to introduce into evidence deposition testimony or written discovery responses during the trial, the offering party shall file copies of the relevant documents, highlighting the transcript or portions of the documents it seeks to introduce, with a brief explanation of how the matter is to be used at trial. Counsel shall exchange the marked documents. Any objections to the use of this material at trial shall be heard on the first day scheduled for trial. Please note this does not apply to the use of deposition testimony or written discovery responses that will be used to impeach a witness on cross-examination.

Highlighting rather than page and line designation, and no counter-designation procedure. Note the split timing: the marked documents go in at or before the pretrial conference, objections are heard on the first day of trial. Nothing in the local rules addresses this. Chapter 2 separately provides that "Lodging of deposition transcripts is not permitted unless requested by the court. Copies of pertinent portions of depositions shall be attached as exhibits to the motion and incorporated" by reference, which is a law and motion rule, not a trial rule.

At least seven days prior to trial, the parties shall meet and confer and exchange motions in limine and identify the motions that are contested.

Calendar days. The rule requires exchange of the actual motions at this point, not just a conference about them. The Presiding Judge page restates it as "at least seven (7) days prior to the first date scheduled for trial," which clarifies that a continued or trailing trial does not reset the clock to the new date. Rule 2.95 revised January 1, 2025.

The parties shall file their motions, oppositions, if any, and a list of disputed motions at least two court days before the first day of trial, and provide a courtesy hard copy of these documents to the assigned department on the first day of trial.

Two obligations in one subdivision, and the list of disputed motions and the courtesy hard copy are both express. Where a case has been assigned to a trial department, the Presiding Judge page moves the filing into that department and resets the timing: "The parties shall file their motions, oppositions, if any, and a list of disputed motions in the trial department at or before the pretrial conference." Work to the earlier of the two. Rule 2.12 separately provides that motions in limine "shall be made to the trial judge."

The following motions shall be deemed filed, served and granted unless good cause is otherwise shown by counsel's declaration and request for hearing: (1) motions to exclude all non-party witnesses until called to testify; (2) motions to exclude all reference to settlement negotiations, mediation, and materials related thereto that are privileged under the California Evidence Code; (3) motions to exclude all reference to insurance, or the fact that an attorney is employed by, or has been compensated by, an insurance company; (4) motions to exclude all evidence of, or reference to, other claims or actions against any party to the litigation; and, (5) motions to exclude all reference to the financial position or wealth, or lack thereof, of any party to the litigation.

Not a deadline, but it changes what gets filed. Filing these five as motions in Sacramento is wasted paper. Note the rule's actual title is "General Motions," not motions in limine, though it sits in Part Nine and the Presiding Judge page cross-references it under its Motions in Limine heading: "Refer to Local Rule 2.96 for motions that shall be deemed filed, served, and granted." The settlement and mediation exclusion at (2) is limited to materials "that are privileged under the California Evidence Code." Adopted January 1, 2013, never revised.

Within 60 calendar days of the date of the referral to the Trial Setting Process or the filing of a request for trial de novo after arbitration, the parties must confer and agree on at least three trial dates and three settlement conference dates.

This deadline runs FORWARD from the referral, not backward from trial. The anchor token court_order refers to the referral to the Trial Setting Process. Subdivision (B): if the parties cannot agree or fail to select dates in time, the court picks both dates and serves notice. Rule 2.90 closes the escape hatch: "No referral to the trial setting process may be dropped, extended or continued by stipulation of the parties." Available dates are posted on the court's website and updated daily. Applies to civil cases other than short cause matters. Revised January 1, 2025.

All counsel shall notify the court of their readiness to begin trial, before a trial date, except on short cause trials. Such notification shall be done electronically by accessing the "Civil Trial Readiness Notification" link on the Court's website.

An online notification, not a hearing. Sacramento publishes no civil trial readiness CONFERENCE; this is the civil analogue and it is a form. The rule fixes no interval beyond "before a trial date"; the Presiding Judge page supplies the actual window for long cause trials (separate row). The rule also provides that program rules and instructions are on the court's website. Revised January 1, 2017 and January 1, 2025.

Readiness notifications shall be submitted from 10 court days before the trial date to 4 p.m. on the Tuesday before the trial date (prior week).

Offset token defined here: this is a window, not a single date. It opens at trial minus 10 court days and closes at 4:00 p.m. on the Tuesday of the preceding week. Long cause only; the page ties it to "their Long Cause Civil Trial" and Rule 2.92 excepts short cause. Court-published department information rather than a numbered rule, but SSC Rule 2.02 points practitioners to the department pages. Same source: "Resending a submission will not overwrite any previously submitted information. All submissions will be read and considered."

Stipulations shall be filed electronically, filed at the civil front counter, placed in the civil drop box, or may be submitted by mail between 10 and 15 court days before the trial assignment date.

ANCHOR CORRECTED ON REVIEW. The draft anchored this to the trial date. The page anchors it to the trial assignment date, a distinct event: the same page carries a section headed "Long Cause Civil Trial/Jury Trial Assignment" and states "Long Cause Civil Trial Assignments are heard Monday and Tuesday at 8:30 a.m.," and SSC Rule 2.88(A) refers to cases being "set for trial assignment in the Presiding Judge's Department." Counting from the first day of trial misses the window. The allowed anchor token set has no trial_assignment_date value, so court_order is used and the true anchor is stated in the requirement and the offset token. This is the practical gateway to a pretrial conference date, so it drives every downstream trial-document deadline. Same source: "If the court grants the stipulation for pre-assignment, parties will be notified of their assigned trial department and should contact the department to schedule a pre-trial conference and motions in limine." Also: "Motions pursuant to Code of Civil Procedure 170.6 should be made as soon as possible after the Order on Stipulation for Pre-Assignment is made." A party unable to get a stipulation may file an ex parte application or motion.