San Bernardino County trial binder and trial document requirements

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

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

Superior Court of California, County of San Bernardino · Effective July 1, 2026. · Court rules · Rules read 2026-09-14

The short answer

What the deadlines run off: Trial Readiness Conference (TRC)
Departments with their own order: 21 publish their own order
County trial binder rule: None in the county rules 21 of its departments require one.
Rules this court publishes: 29

The county rule is a floor. Where your department publishes its own order, that order controls and it is usually stricter.

Find your department

21 departments in this county publish their own trial preparation order. Each one below links directly, so you can send a colleague straight to theirs.

Departments publishing their own trial preparation order, San Bernardino County
Department	Courthouse	Judge as published
S17	San Bernardino Justice Center, Complex Litigation Program	Hon. Joseph T. Ortiz
S22	San Bernardino Justice Center	Hon. David E. Driscoll
S23	San Bernardino Justice Center	Hon. Donald Alvarez
S24	San Bernardino Justice Center	Hon. Carlos Cabrera
S-25	San Bernardino Justice Center	Hon. Khymberli S. Apaloo
S26	San Bernardino Justice Center	Hon. Kevin C. Lee
Dept S27	San Bernardino Justice Center	Hon. Thomas Garza
Dept. S-28	San Bernardino Justice Center	Hon. Michael A. Sachs
Dept. S-29	San Bernardino Justice Center	Hon. Nicole Quintana Winter
S30	San Bernardino Justice Center	Hon. Charlie L. Hill, Jr.
S31	San Bernardino Justice Center	Not published
S32	San Bernardino Justice Center	Hon. Wilfred J. Schneider, Jr.
Dept S33	San Bernardino Justice Center	Hon. Stephanie Tanada
S35	San Bernardino Justice Center	Hon. Michael A. Dauber
Dept. S-36	San Bernardino Justice Center	Hon. Joseph B. Widman
Dept S37	San Bernardino Justice Center	Hon. Winston S. Keh
Dept. R12	Rancho Cucamonga Courthouse	Hon. Kory Mathewson
Dept R14	Rancho Cucamonga Courthouse	Hon. Tony Raphael
R-17	Rancho Cucamonga Courthouse	Hon. Gilbert G. Ochoa
V11	Victorville Courthouse	Commissioner Malalai Farooqi
V12	Victorville Courthouse	Hon. Jeffery R. Erickson

Department by department

Department S17, San Bernardino Justice Center, Complex Litigation Program, Hon. Joseph T. Ortiz

Trial documents: Everything is filed directly in Department S17 three days before the trial readiness conference, not at it: written motions in limine, a complete joint witness list, a complete joint exhibit list plus the exhibits, a joint statement of the case, plaintiff's jury instructions and verdict forms, and a trial brief. All mandatory except the trial brief, which is optional in jury trials. Trial counsel declaring ready must appear in person, with no special appearance attorneys and no remote appearances unless approved in advance. Depositions are lodged on the readiness date along with the balance of court reporter and jury fees. Failure to file may get the trial continued because the court will treat counsel as not ready. A separate Complex Initial Case Management Conference Order sits at s17complexinitialcasemanagementorder.pdf.
Binder: Three-ring binders, four sets of the same exhibits: original for the clerk, one for the opposing party, one for the witness stand, one for the bench. The bench copy must be in hand no later than the trial readiness conference. Exhibits start at one and run to conclusion with no duplicates. A written anti grab bag rule bars tabbing discovery by subject matter and bars any exhibit labelled miscellaneous. Jury instructions come in two packets, the first the 100 series plus 200, the second starting again at 200, plus the proposed instructions in Word on a flash drive, with caption only cover sheets and no firm attribution.
In limine: In writing, in compliance with SBC Local Rule 415, citing Kelly v. New West Financial Services, 49 Cal.App.4th 659. Served on the opposing party 8 days in advance, which matches the county rule.
Difference: Local Rule 411.2 has the parties appear and submit the trial documents on the date of the trial readiness conference. S17 pulls the filing three days earlier and adds requirements the county rule does not contain at all: four exhibit binder sets, the Word flash drive, the two packet CACI structure, and the anti grab bag exhibit rule enforced by a not ready finding. It also bars special appearances and remote appearances at the conference, which the county rule does not address.

The order in its own words

The parties are ordered to meet and confer with respect to all issues arising from this Order and exchange all necessary documents such that, on the date of the TRC, the following documents are filed directly in Department S17, three days prior to the TRC. Failure to file may result in your trial being continued as the Court will consider counsel "not ready" for trial.

Trial Setting Orders for Department S17 · Undated. File Last-Modified Fri, 11 Sep 2026. · The order

Department S22, San Bernardino Justice Center, Hon. David E. Driscoll

Trial documents: Motions in limine, a statement of stipulated facts, trial briefs and a joint statement of the case are filed with the court upon the case being assigned to trial at the readiness calendar. Counsel must meet and confer before the readiness calendar on motions in limine, the statement of stipulated facts and the joint statement of the case. An original and two copies of the joint witness list and the joint exhibit list are filed at the readiness calendar. The CACI instruction checklist, pinpoint instructions and the special verdict form go to the court on the first day of trial, with disputed instructions submitted separately. Voir dire questions or an agreed questionnaire are submitted before the first day of trial.
Binder: A joint exhibit book with duplication eliminated, exhibits pre-marked before trial. Flash or thumb drives are encouraged in addition to the books. Sub-exhibits such as transcripts of audio or video take the primary exhibit number with a sub number, for example 1-1 and 1-2. Voluminous exhibits must be flagged to the court early. Exhibits are returned to the propounding party at the end of trial.
In limine: Filed with the court upon the case being assigned to trial at the readiness calendar, preceded by a meet and confer. The department order does not restate the county 8 day service deadline.
Difference: The county rule sets one deadline for motions in limine, filed with service completed at least 8 days before the conference. S22 instead ties the filing to the moment the case is assigned to trial at the readiness calendar and imposes a pre-readiness meet and confer on three separate categories. It adds a paper count the county rule has no equivalent of, an original plus two copies of each joint list, requires a joint exhibit book with duplication removed, and moves jury instructions and the verdict form to the first day of trial rather than the conference where Rule 411.2 puts them.

The order in its own words

An original and two copies of JOINT Witness List and JOINT Exhibit List are required to be filed with the court at the Readiness Calendar.

Trial & Continuance Guidelines, Department S22 · 1/19/23, printed at the top of each page. File Last-Modified Fri, 28 Mar 2025. · The order

Department S23, San Bernardino Justice Center, Hon. Donald Alvarez

Trial documents: Nothing is submitted until the case is assigned to trial. Then, by e-file with a courtesy copy hand delivered to the department: motions in limine with no proposed orders included, a joint witness list carrying a name, brief description and time estimate for each witness, a joint exhibit list and the exhibits, proposed CACI instructions with a face page listing all requested instructions in sequential order, a joint statement of the case, a proposed special verdict form if requested, and a trial brief. Joint is defined to mean the court works from one set of documents, not that the parties agree. All mandatory except the trial brief. The parties provide the court reporter and realtime is required.
Binder: Exhibits in a 3-ring binder, two sets for the court, one for the witness and one for the court. Pre-marked in numerical order and bates stamped at the bottom of each page if multi-page. The court prepares the actual exhibit labels. A flash drive to the judicial assistant on the first day of trial is encouraged. The judicial assistant emails the exhibit list template and counsel return one completed joint list by email and also e-file a joint exhibit list.
In limine: In writing, submitted at the readiness calendar once the case is assigned to trial, with no orders to be signed included. The county 8 day rule is not restated.
Difference: Rule 411.2 says nothing about when documents may be lodged. S23 affirmatively forbids submitting anything before the case is assigned to trial. It requires both e-filing and a hand delivered courtesy copy, adds a per witness time estimate, defines joint to mean one set of documents rather than agreement, imposes bates stamping and a two set binder, takes exhibit labelling away from counsel, and bars proposed orders from the in limine papers. Realtime reporting is required, which no county rule imposes.

The order in its own words

ALL OF THE ITEMS BELOW ARE TO BE SUBMITTED WITH THE COURT UPON THE CASE BEING ASSIGNED TO TRIAL, NOT BEFORE. (Must be submitted by efile, and a courtesy copy delivered to the department)

Requirements for Trial, Department S23. Linked on the court index as "Trial Rules". · Undated. File Last-Modified Thu, 06 Nov 2025. · The order

Department S24, San Bernardino Justice Center, Hon. Carlos Cabrera

Trial documents: Presented at the trial readiness conference, with service on opposing counsel per statute or five calendar days before the conference, whichever is sooner: written motions in limine, a complete joint witness list, a complete joint exhibit list and the exhibits, a joint statement of the case, proposed jury instructions with a face page of CACI instructions in sequential order and the full instructions attached, a proposed special verdict form if requested, and a trial brief. All mandatory except the use of a court reporter, which the parties supply. The non-jury order drops the instructions and verdict form and substitutes a list of controverted issues and stipulations.
Binder: No binders. All exhibits are in digital format on a flash drive that includes a table of contents, one drive to the clerk and one to the court on the first day of trial, plus exactly one original pre-marked paper set for the court to mark as its original. Non-impeachment exhibits are pre-marked and delivered on day one. Counsel meet and confer on admissibility and give the court a joint statement of admissibility of each exhibit on day one.
In limine: In writing, presented at the trial readiness conference, service per statute or five calendar days before the conference, whichever is sooner. Counsel are directed to R&B Auto Center, Kelly and Amtower before filing.
Difference: The sharpest format departure in the county. Rule 411.2 says nothing about exhibit media and every other San Bernardino civil department orders paper binders. S24 orders the opposite, a digital flash drive with a table of contents and a single original paper set. It is also the only department requiring a joint statement of admissibility of each exhibit on day one. The service trigger, statutory notice or five calendar days before the conference whichever is sooner, is earlier than anything in the county rule.

The order in its own words

All exhibits shall be in a digital format and saved onto a flash drive that includes a table of contents for use by the court. A flash drive shall be provided to the clerk of the court and to the court on the first day of trial. There shall only be one (1) original pre-marked set of exhibits provided to the court to mark as its original set.

Jury Trial Orders for Department S24. Companions on the same index row: Non-Jury Trial Orders (s24nonjurytrialorders.docx), Courtroom Rules and Procedures (s24courtroomrulesandprocedures.pdf), Jury Trial Schedule (s24jurytrialschedule.doc). · Undated. File Last-Modified Tue, 22 Apr 2025. · The order

Department S-25, San Bernardino Justice Center, Hon. Khymberli S. Apaloo

Trial documents: No less than three court days before the trial readiness conference the parties file in the department: oppositions to motions in limine, jury instructions, proposed verdict forms, witness and exhibit lists with exhibits listed in numerical order only and in the anticipated order of presentation, proposed voir dire questions or questionnaires, a brief statement of the case to be read to the jury, and a trial brief for bench trials only. Documents should be jointly submitted. All trial counsel and self-represented parties must appear at the conference. MSC briefs are filed directly in the department no less than five days before the settlement conference with all four CRC 3.1380 elements, and all parties and adjusters must appear. Violation may bring monetary sanctions or exclusion of evidence or witnesses.
Binder: Exhibits exchanged and inspected before the conference and placed in a 3-ring binder with one set for the court, one for the witness and one for each party, so the count scales with the number of parties. The judicial assistant emails the exhibit list template and counsel return one completed joint list by email.
In limine: In writing, filed with the department, service completed at least eight days before the conference, complying with Local Rule 415. That matches the county deadline. What is department-specific is that oppositions are separated out and put on the three court day clock. A list of sua sponte orders is attached that do not require in limine motions.
Difference: Rule 411.2 has the parties submit at the conference. S25 requires filing three court days ahead of it. It adds an exhibit ordering rule the county rule has no counterpart to, numerical order only and in the anticipated order of presentation, scales the binder count to the number of parties rather than a fixed two or three, and writes the sanction into the order. Oppositions to motions in limine get the three court day deadline while the motions themselves keep the county eight day rule.

The order in its own words

No less than three (3) court days prior to the TRC, the parties shall file in this Department: 1) Any oppositions to Motions in limine, 2) Jury Instructions, as set forth below, 3) Proposed verdict forms, 4) Witness and Exhibit lists (Exhibits listed in numerical order only, in the anticipated order of presentation) 5) Any proposed voir dire questions and/or questionnaires, 6) A brief Statement of the Case to be read to the jury, if applicable and 7) A trial brief (for bench trials only, per Local Rule 411). Documents should be jointly submitted.

MSC and Trial Orders for Department S-25 · Undated scanned order. File Last-Modified Wed, 15 Apr 2026. Image only PDF with no text layer, read by rendering the pages. · The order

Department S26, San Bernardino Justice Center, Hon. Kevin C. Lee

Trial documents: Jury track, under the document at this URL: the parties meet and confer and file, at least 5 court days before trial, a joint witness list, a joint exhibit list, a joint statement of the case, plaintiff's jury instructions and special verdict, trial briefs, and motions in limine. MSC statements go directly to S26 three court days before the MSC. Counsel start every jury trial day at 9:30 a.m. because instructions are worked through each morning. Any timely propounded discovery not timely responded to before the cut-off is excluded at trial. Bench track, under the separate non-jury standing order: meet and confer on all pre-trial matters at least 10 court days before the conference and carry an assembled three-ring Joint Trial Binder to it.
Binder: Two regimes. Jury trials: exhibits pre-marked in numerical order, bates stamped, marked and reviewed by all counsel before testimony starts, in 3-ring binders with one copy for the court and one for the witnesses. Bench trials, from the non-jury standing order: a three-ring Joint Trial Binder brought to the conference in a fixed order, table of contents, trial brief, printed copies of the current operative pleadings, joint exhibit list, joint witness list with two courtesy copies to the clerk, joint list of the issues, and motions in limine with oppositions in order. Then a separate Joint Exhibit Binder, two copies, one for the court and one for the clerk, presented on day one with exhibits pre-marked and bate stamped with exhibit tags. Then a third, a Transcript Binder, holding labeled deposition transcripts if deposition testimony will be used.
In limine: Must comply with Local Rule 415. In the bench track counsel meet and confer in good faith before filing and serving, and the motions, oppositions and replies sit in the Joint Trial Binder in order. Counsel must advise witnesses of the rulings. The county 8 day rule is not restated.
Difference: The county rule contains no binder requirement of any kind and never mentions a trial brief or the operative pleadings. S26 requires three physically assembled binders for a bench trial in a fixed order, including the pleadings and a table of contents, plus a dedicated transcript binder that exists nowhere else in the county. The jury track filing deadline also differs in kind: Rule 411.2 keys everything to the trial readiness conference while S26 keys it to 5 court days before trial. The bench track meet and confer, 10 court days, is longer than any county requirement and is measured in court days where the S31, S37 and V11 versions of the same form say calendar days.

The order in its own words

The parties are ordered to meet and confer with respect to all issues arising from this Order and to exchange all necessary documents such that on the date of the Trial Readiness Conference (TRC). The following documents are filed at least 5 Court Days prior to the trial:

Courtroom Rules, Trial Orders, and Sua Sponte Rulings, Dept S26. Bench trials are governed by a separate Standing Trial Order and Trial Procedures for Non-Jury Trial at s26trialorderfornonjurytrials.pdf. · Courtroom Rules and Trial Orders dated July 1, 2026. The separate non-jury Standing Trial Order is dated January 20, 2026. · The order

Dept S27, San Bernardino Justice Center, Hon. Thomas Garza

Trial documents: Filed directly in Department S27 on the date of the trial readiness conference: a joint witness list, a joint exhibit list with exhibits pre-marked in numerical order and bates stamped at the bottom of each page if multi-page, a joint statement of the case, plaintiff's jury instructions and special verdict, and trial briefs. Plaintiff submits a complete set of instructions under CRC 2.1055 with a generic pleading cover sheet and an itemized list. Defendant's instructions are filed on the first day of trial and carry only additional instructions plus objections. Sua sponte rulings are attached and apply to all trials. The parties provide the court reporter and realtime is required.
Binder: The parties exchange and inspect all exhibits not furnished during discovery before the conference. Exhibits go in 3-ring binders, one copy for the court, one for the witness and one for the opposing party.
In limine: Must comply with Local Rule 415, with counsel expected to know Amtower, Kelly and R&B Auto Center. The county 8 day rule is not restated in the department order.
Difference: The county rule prescribes no exhibit format, no pre-marking, no bates stamping and no binder. S27 adds all four, plus a pre-conference exchange and inspection of exhibits not produced in discovery, plus direct filing in the department rather than general filing. It adds an evidentiary consequence the county rule does not create, automatic exclusion at trial of any timely propounded discovery not answered before the cut-off, and it requires realtime reporting.

The order in its own words

EXHIBITS - The parties shall exchange and inspect all exhibits not furnished during discovery. Exhibits shall be placed in 3-ring binders with 1 copy for the Court, 1 for the witness and 1 for opposing party.

Trial Setting Orders, San Bernardino Superior Court, Dept S27 · Undated, signature date line blank. File Last-Modified Wed, 15 Apr 2026. · The order

Dept. S-28, San Bernardino Justice Center, Hon. Michael A. Sachs

Trial documents: Presented at the readiness calendar with service on opposing counsel per SBC Local Rule 411 et seq.: motions in limine, a joint witness list, a joint exhibit list, a joint statement of the case, a joint set of proposed jury instructions with every instruction completely filled out and a pleading cover sheet in sequential order, a proposed special verdict form if requested, and a trial brief. Joining the instruction set does not waive the right to object. The statement of the case, the instruction set and the verdict form are marked unnecessary in a court trial. All mandatory except the trial brief. Counsel must participate in an alternative dispute resolution before trial. Court reporters are not provided. A separate order governs permissible discovery in Lemon Law cases at s28permissiblediscoveryinlemonlawcases.pdf.
Binder: No binder is required, which sets S28 apart from most of the justice center. Exhibits are pre-marked in numerical order and bates stamped at the bottom of each page if multi-page, and counsel must use the court's own exhibit list template rather than their own form.
In limine: Must comply with San Bernardino County Local Rules 411.2 and 415, with the parties expected to be familiar with Kelly v. New West Federal Savings (1996) 49 Cal.App.4th 659. The county 8 day rule applies through the cross-reference rather than being restated.
Difference: Two additions the county rule does not make. First, a single joint set of jury instructions with every instruction completely filled out and a pleading cover sheet, coupled with an express statement that joining the set does not waive the right to object. Rule 411.2 asks only for proposed instructions and does not say they must be joint or that objection rights survive. Second, a mandatory court-issued exhibit list template. S28 also adds a pre-trial ADR obligation. What it does not do is require exhibit binders, so a party moving from S27 or S33 into S28 can drop the binder sets.

The order in its own words

Exhibits shall be pre-marked in numerical order and if multiple pages, shall be Bate stamped at the bottom of each page.

Trial Setting Orders, Dept. S-28, Unlimited Civil Matters. Linked on the court index as "Trial Requirements". · Undated. File Last-Modified Tue, 01 Apr 2025. · The order

Dept. S-29, San Bernardino Justice Center, Hon. Nicole Quintana Winter

Trial documents: Presented at the readiness calendar with service on opposing counsel per SBC Local Rule 411 et seq.: motions in limine, a joint witness list, a joint exhibit list, a joint statement of the case, a joint set of proposed jury instructions, a proposed special verdict form, any deposition designations and counter designations with attached copies of the depositions highlighted and tabbed, and a trial brief. The statement of the case, the instruction set and the verdict form are unnecessary in a court trial.
Binder: No 3-ring binder requirement. Exhibits are pre-marked in numerical order and bates stamped at the bottom of each page if multi-page. All exhibits must be marked before testimony starts and reviewed by each party. Deposition copies supporting the designations must be highlighted and tabbed. PowerPoint slides for opening or closing must be shown to the other side in advance, with objections handled in chambers.
In limine: Must comply with San Bernardino County Local Rules 411.2 and 415, with counsel expected to know Kelly v. New West Federal Savings, Amtower v. Photon Dynamics, and R&B Auto Center v. Farmers Group at 371 to 372. The county 8 day rule is not restated.
Difference: S29 adds a document Rule 411.2 does not list at all: deposition designations and counter designations with the transcripts themselves attached, highlighted and tabbed. It also builds a publication protocol the county rule is silent on, requiring the words "Permission to Publish exhibit X" before any document reaches the jury and requiring counsel to identify the exhibit on the record every time it is published even if previously identified. No binder is required, unlike S17, S23, S26, S27, S31, S33, S36, S37, R14 and V11.

The order in its own words

ANY DEPOSITION DESIGNATIONS AND COUNTER DESIGNATIONS WITH ATTACHED COPIES OF THE DEPOSITIONS, HIGHLIGHTED AND TABBED

Trial Setting Orders, Dept. S-29 · Undated. File Last-Modified Wed, 09 Apr 2025. · The order

Department S30, San Bernardino Justice Center, Hon. Charlie L. Hill, Jr.

Trial documents: Filed with the court and served on opposing counsel per statute or 5 court days before the trial readiness conference, whichever is sooner: written motions in limine, a complete joint witness list, a complete joint exhibit list with exhibits starting at 1 and running to conclusion with no duplicates, a joint statement of the case, proposed jury instructions with a face page, a proposed joint special verdict form if requested, and a trial brief. Depositions are lodged on the readiness date along with the balance of court reporter and jury fees. Subpoenaed documents do not reach the courtroom unless the clerk is told at readiness. MSC briefs are due at least five days before the MSC. The parties provide the court reporter with realtime preferred, available from readiness through the verdict.
Binder: Original exhibit set for the clerk, one for the witness stand and one for the bench. Special instruction requests must be provided in two formats, a working copy with case or statutory authority and a clean CACI format copy ready for the jury. Both instruction sets and the verdict form carry cover sheets with the case caption only and no firm attribution.
In limine: In writing. The parties are required to meet and confer and to review Local Rule 415, R&B Auto Center, Kelly and Amtower before submitting. Filed on the same statutory or 5 court day trigger as the rest of the trial documents. The county 8 day rule is not restated.
Difference: Rule 411.2 has the parties appear and submit at the conference and says nothing about the firmness of trial dates. S30 states twice in capitals that all trial counsel must appear in person for the conference and trial and that trial dates are firm. It front-loads the filing to 5 court days before the conference, makes a meet and confer a precondition to filing any motion in limine, and requires the two format treatment of special instructions with firm attribution stripped, none of which appears in the county rule.

The order in its own words

ALL TRIAL COUNSEL ARE REQUIRED TO APPEAR IN PERSON FOR THE TRIAL READINESS CONFERENCE. TRIAL DATES ARE FIRM.

Trial Court Orders for Department S30 · Undated. File Last-Modified Thu, 16 Apr 2026. · The order

Department S31, San Bernardino Justice Center

Who is sitting here

Hon. Lily L. Sinfield per the court's index dated 8 September 2026. Both published orders are signed by Hon. Stephanie Thornton-Harris.

Trial documents: Filed directly in Dept S31 on the date of the trial readiness conference: a joint witness list with time estimates broken out for direct examination, cross-examination, re-direct and re-cross; a joint exhibit list with exhibits pre-marked in numerical order and stamped at the bottom of each page; a joint statement of the case, but only if the parties do not anticipate giving mini-openings; and plaintiff's jury instructions and special verdict. Trial briefs are required for bench trials and required in a jury trial only if the time estimate is over eight days. MSC briefs no less than five days before the settlement conference with all four CRC 3.1380 elements. Bench track, under the separate standing order: meet and confer on all pre-trial matters at least 10 calendar days before the conference and carry an assembled Joint Trial Binder to it.
Binder: Jury trials: exhibits in 3-ring binders, one copy for the court, one for the witness and one for all other parties to the action. Bench trials, from the standing order: a three-ring Joint Trial Binder carried to the conference containing, in order, a table of contents, printed copies of the current operative pleadings, a joint witness list with two courtesy copies to the clerk, a joint list of controverted issues, stipulations, a joint exhibit list with two courtesy copies to the clerk, trial briefs, and motions in limine with oppositions and replies in order. Separately, two complete copies of a Joint Exhibit Binder on the first day of trial, the original for the witness and one copy for the court, plus copies of any deposition transcripts that will be used.
In limine: Filed directly in Dept. S31 at least 8 days before the trial readiness conference, which matches the county deadline but adds the direct filing requirement. Must comply with Local Rule 415, with a good faith meet and confer before filing and serving in the bench track, and counsel are expected to know Amtower, Kelly and R&B Auto Center.
Difference: The county rule requires witness and exhibit lists but says nothing about how they are broken down. S31 requires the witness time estimate split four ways by examination phase, language it shares with S33 and with no other department in the county. It conditions the joint statement of the case on whether mini-openings are planned, which Rule 411.2 does not contemplate, and sets an eight day trial length threshold for whether a jury trial brief is required. For bench trials it requires a fully assembled Joint Trial Binder including the pleadings, which the county rule never mentions.

The order in its own words

1. Joint witness list with time estimates for direct examination, cross-examination, re-direct, and re-cross; 2. Joint exhibit list (Exhibits shall be pre-marked in numerical order and if multiple pates, date stamped at the bottom of each page; 3. Joint Statement of the Case (if the parties do not anticipate giving mini-openings); 4. Plaintiff's Jury Instructions/Special Verdict.

MSC and Trial Setting Orders for Department S31. Companion for bench trials: Standing Trial Order and Trial Procedures for Non-Jury Trial, Department S-31 (s31standingtrialorders.pdf), effective May 13, 2024. The index also links an IDC Stipulation and an IDC Request and Answer form. · Undated. File Last-Modified Wed, 15 Apr 2026. Image only PDF with no text layer, read by rendering the pages. · The order

Department S32, San Bernardino Justice Center, Hon. Wilfred J. Schneider, Jr.

Trial documents: Filed in the department at the readiness calendar and not before, citing CRC 3.1548 and SBC LR 411: motions in limine in writing having been served on the opposing party 8 days before, plus any oppositions, with no orders to be signed included; a joint witness list for jury and court trials; a joint exhibit list and exhibits with no separate lists from plaintiff and defendant and with stipulations on authenticity or foundation if any; proposed CACI instructions for jury trials; a joint statement of the case; a proposed special verdict form if requested; proposed voir dire questions or a questionnaire; a statement of stipulated facts; and a trial brief. All mandatory except the trial brief. Settlement conference briefs are filed at least 5 days before the settlement conference and parties with authority must appear.
Binder: Two binders for marked exhibits, one for the witness and one for the court. The court prepares the actual exhibit labels. Transcripts are not exhibits and are not lodged; if used at trial one copy goes to the judge and is returned. Prepared instructions are attached with no heading and no indication of which party or attorney is requesting each one, with any cited authority moved to a separate page.
In limine: In writing, served on the opposing party 8 days before, which matches the county deadline. Oppositions are submitted at the same readiness calendar. Counsel are directed to Kelly v. New West Federal Savings and SBC LR 415. Proposed orders must not be included.
Difference: Two rules that exist nowhere in the county rule and nowhere else in the county. First, deposition transcripts are not exhibits and are not lodged, which is the direct opposite of S29 and R12 where highlighted and tabbed transcripts are a required trial document. Second, prepared jury instructions must be attached with no heading and no indication of which party or attorney is requesting each instruction, with cited authority on a separate page. S32 also bars any submission before the readiness hearing, which Rule 411.2 does not address.

The order in its own words

TRANSCRIPTS are not exhibits nor are they lodged. If used in trial one copy of transcript needed for the judge which will be returned.

Requirements for Trial, Department S32 · Rev 090916, printed at the foot of page 1, meaning September 2016. Oldest posted policy in the county. File Last-Modified Wed, 15 Apr 2026. Image only PDF with no text layer, read by rendering the pages. · The order

Dept S33, San Bernardino Justice Center, Hon. Stephanie Tanada

Trial documents: Filed directly in Dept S33 on the date of the trial readiness conference: a joint witness list with time estimates for direct, cross, re-direct and re-cross; a joint exhibit list with exhibits pre-marked in numerical order, bates stamped at the bottom of each page if multi-page and former bates stamps removed, with a description and the name of the witness who will testify to each; a joint statement of the case only if mini-openings are not anticipated; joint jury instructions; and a joint general or special verdict in a jury trial. Joint means combined and integrated, so each witness and each exhibit appears once across the whole case. Trial briefs are required for bench trials only and are not wanted in jury trials unless the estimate is over ten days. Appearing without joint documents brings a meet and confer in the courthouse and is cause for sanctions, and the court will not continue the trial date for it.
Binder: A working copy for the judge in a tabbed binder. Exhibits in 3-ring binders, one copy for the court, one for the witness and one for all other parties. Counsel meet and confer before the conference and attempt to stipulate to authentication and admissibility. Motions in limine go in a separate tabbed and indexed binder by motion number with the moving papers, opposition and reply back to back. Trial briefs, when provided, are included in the judge's working binder with the lists.
In limine: Heard on the first day of trial, but for service and filing purposes the trial readiness conference is the notional hearing date. Moving papers and oppositions only are served and filed under CCP 1005(b). Replies are due on the date of the conference. At the conference the moving party presents the motions in a tabbed and indexed binder in numerical order with the briefing back to back. Must comply with Local Rule 415, with Amtower, Kelly and R&B Auto Center. Sanctions of $250 per motion for any motion that violates the local rule, the cases, or is already covered by a sua sponte ruling.
Difference: The most demanding civil department in the county and the one most likely to catch out a filer working from Rule 411.2. It defines joint to forbid a defendant's list copy-and-pasted after the plaintiff's; it requires former bates stamps to be removed; it runs motions in limine on CCP 1005(b) using the conference as the hearing date rather than the county's flat 8 day rule; it requires a tabbed and indexed motion binder assembled by motion number; it publishes a $250 per motion sanctions schedule; and it caps mini-openings at three minutes absent a formal request. It also carries a generative AI evidence protocol in sua sponte ruling 12 requiring prior disclosure or timely production, a Notice identifying the AI-generated material with enough specificity to locate it, and exclusion of any such material that arrives without the Notice.

The order in its own words

At the Trial Readiness Conference, the moving party is to present their MILs in a tabbed and indexed binder (or binders) in numerical order. Each number shall have the moving papers, opposing papers, and replies back-to-back, for ease of the Court reference.

Trial Setting Orders, Dept S33. Companions: Judge Tanada's Courtroom Jury/Bench Trial Rules and Court's Trial Orders (s33courtroomrulesandorders.docx), Courtroom Information Sheet (s33courtroominfosheet.docx), Guidelines for Approval of Class Action and PAGA Settlements, Song-Beverly Act Production of Documents. · Dated December 29, 2025, page footer Ver. 12/29/25. File Last-Modified Thu, 13 Aug 2026. The order itself tells counsel to re-check the rules within a month of the trial setting conference because they change. · The order

Department S35, San Bernardino Justice Center, Hon. Michael A. Dauber

Trial documents: At the Final Status Conference counsel of record appear in person and hand the court trial briefs, a witness list, verdict forms, an exhibit list, proposed CACI instructions without use notes, the exhibits, a joint statement of the case, courtesy copies of all motions in limine and oppositions, a time estimate for witnesses, and stipulated categories or topics for expert witnesses with page and line references for each category. Opening and closing arguments are e-filed by the close of trial for appellate purposes with a courtesy copy delivered. Courtesy copies are required for all ex parte applications, all motions, oppositions and replies, and all trial documents, must be one-sided, and ex parte courtesy copies must arrive by noon the day before the hearing. The court index adds that joint stipulations to continue trial are not accepted and ex parte applications are required for all trial continuances.
Binder: No binder requirement. The exhibits themselves are provided at the Final Status Conference. Courtesy copies must be one-sided.
In limine: Courtesy copies of all motions in limine and of all oppositions are provided at the Final Status Conference. The department order does not restate the county 8 day service deadline.
Difference: S35 calls the event a Final Status Conference rather than the Trial Readiness Conference named in Rule 411.2, and requires two things no other department in San Bernardino requires: proposed CACI instructions stripped of use notes, and stipulated expert witness categories or topics with page and line references for each category. It also requires opening and closing arguments to be e-filed by the close of trial for the appellate record. The one-sided courtesy copy rule and the refusal to accept stipulated trial continuances have no county counterpart.

The order in its own words

At the Final Status Conference date, counsel of record are to appear in person and provide the Court with the following items: trial briefs; witness list; verdict forms; exhibit list; proposed CACI instructions without use notes; exhibits; joint statement of the case; courtesy copies of all motions in limine and oppositions to motions in limine; time estimate for witnesses; stipulated categories/topics for expert witnesses with page and line references for each category.

Trial Setting Orders, Department S35. Companion: Courtesy Copy Requirements, Department S35 (s35courtesycopyrequirements.docx). · Undated. Trial setting orders Last-Modified Mon, 31 Aug 2026; courtesy copy requirements Last-Modified Mon, 08 Sep 2026. · The order

Dept. S-36, San Bernardino Justice Center, Hon. Joseph B. Widman

Trial documents: Two non-appearance milestones. The Trial Document Exchange Date, two weeks before the trial readiness conference, is when counsel exchange the documents. The Trial Documents Filing Date, the Monday before trial, is when they must be e-filed or hand delivered directly to Dept. S-36, no fax filing: a joint witness list, a joint exhibit list in the attached form with exhibits pre-marked in numerical order and bates stamped, a joint statement of the case in jury cases only, plaintiff's jury instructions and special verdict in jury cases only, and trial briefs in non-jury cases only. Motions in limine are the express exception and stay on the county clock.
Binder: A 3-ring binder with two sets for the court, one set for the witness and one set for the opposing party, four in all. The judicial assistant emails the exhibit list template and counsel return one completed joint list by email. The exhibit binders must be provided no later than 10:00 on the first day of trial.
In limine: Carved out of the two date structure. Pursuant to Local Rule 411.2 all motions in limine are filed directly in Dept. S-36 with service completed at least 8 days before the trial readiness conference. That is the county deadline, restated, plus the direct filing requirement.
Difference: Rule 411.2 keys every trial document to a single event, the trial readiness conference, and has the parties submit them there in person. S-36 splits the work into an exchange two weeks before the conference and a filing on the Monday before trial, both non-appearance dates, so most trial documents land after the conference rather than at it. It inverts the trial brief into a non-jury document only, where the county rule does not address trial briefs at all, and it fixes a clock time, 10:00 on day one, for binder delivery.

The order in its own words

Exhibits: The parties shall exchange and inspect all exhibits to be used at trial. Exhibits shall be placed in A 3-ring binder with two sets for the Court, one set for the witness and one set for the opposing party. . . . Counsel are ordered to provide the exhibit binders no later than 10:00 on the first day of trial.

Trial Setting Order, Dept. S-36 · Undated blank template with the dates filled in by the judge. File Last-Modified Mon, 28 Apr 2025. · The order

Dept S37, San Bernardino Justice Center, Hon. Winston S. Keh

Trial documents: Two non-appearance milestones, a Trial Document Exchange date and a Trial Documents Filing Date, with everything filed directly in Dept S37 by the filing date: a joint witness list, a joint exhibit list in the attached form with exhibits pre-marked in numerical order and stamped at the bottom of each page, a joint statement of the case, plaintiff's jury instructions and special verdict, and trial briefs. Plaintiff submits a complete instruction set under CRC 2.1055 with a generic pleading cover sheet; defendant's instructions are filed on the first day of trial with only additional instructions and objections. Bench track, under the separate standing order: meet and confer at least 10 calendar days before the conference and carry a three-ring Joint Trial Binder to it.
Binder: Jury trials: a 3-ring binder with 2 sets for the court, 1 for the witness and 1 for the opposing party, four in all. The judicial assistant emails the exhibit list template and counsel return one completed joint list by email. Bench trials, from the standing order: a three-ring Joint Trial Binder in fixed order, table of contents, printed copies of the current operative pleadings, joint witness list with two courtesy copies to the clerk, joint list of controverted issues, stipulations, joint exhibit list with two courtesy copies, trial briefs, and motions in limine with oppositions. Then two complete copies of a Joint Exhibit Binder on the first day of trial, the original for the witness and one for the court, plus copies of any deposition transcripts to be used.
In limine: All motions in limine and oppositions are filed and served directly to Dept S-37 at least 5 days before the trial readiness conference, which is shorter than the county's 8 days. The parties must meet and confer by telephone or in person before filing and serving, and the moving party must file a declaration showing compliance. Must comply with Local Rule 415, with Amtower, Kelly and R&B Auto Center.
Difference: S37 shortens the county motion in limine deadline. Rule 411.2 says all motions in limine shall be filed with service completed at least 8 days before the conference; S37 sets 5 days and adds a meet and confer declaration the county rule does not require, so a filer following the county rule will be early on the motion but missing the declaration. For bench trials it requires an assembled Joint Trial Binder including the operative pleadings and a table of contents, which the county rule never mentions. It also carries a standing AI general order that has no county counterpart.

The order in its own words

All motions in limine and opposition shall be filed and served directly to Dept S-37 at least 5 days before the Trial Readiness Conference. . . . The parties are required to meet and confer via telephone or in person before filing and serving any motions in limine. Counsel for the moving party shall file declaration showing compliance with the court's meet and confer requirements.

Trial Setting Orders, Dept S37. Companions: Standing Trial Order and Trial Procedures for Non-Jury Trial (s37courtstandingtrialordernonjury.docx), AI General Order (s37aigeneralorder.docx). · Jury trial setting orders undated, File Last-Modified Wed, 29 Jul 2026. The non-jury Standing Trial Order is effective and dated May 26, 2026. · The order

Dept. R12, Rancho Cucamonga Courthouse, Hon. Kory Mathewson

Trial documents: Presented at the readiness calendar with service on opposing counsel per statute or 5 calendar days before the readiness date, whichever is sooner: motions in limine, a joint witness list, a joint exhibit list with exhibits pre-marked in numerical order and bates stamped at the bottom of each page if multi-page, a joint statement of the case, a joint set of proposed jury instructions completely filled out with a pleading cover sheet in sequential order and an express non-waiver of objections, a proposed special verdict form, any deposition designations and counter designations with attached copies of the depositions highlighted and tabbed, and a trial brief. MSC briefs are due at least five days before the MSC. The separate Trial Schedule sets a 9:45 a.m. start with counsel present by 9:30, breaks about 10:45 a.m. and 2:45 p.m., lunch noon to 1:30, and the day ending about 4:00 to 4:15 p.m.
Binder: No binder requirement. The exhibit rule sits in the separate one-page Exhibits for Trial document: counsel must use the court's own exhibit list, filled out with all exhibits and their descriptions, requested by emailing the judicial assistant at DRodriguez@sb-court.org with the case number and returned by email before the trial date. Multiple different documents grouped under one number must be lettered 2a, 2b and so on; a single large document takes one number.
In limine: Must comply with San Bernardino County Local Rules 411.2 and 415, with the parties expected to know Kelly v. New West Federal Savings, Amtower v. Photon Dynamics, and R&B Auto Center v. Farmers Group at 371 to 372. The county 8 day rule applies through the cross-reference rather than being restated.
Difference: Rule 411.2 prescribes no exhibit list format at all. R12 requires the court's own list, obtained by emailing the judicial assistant, and imposes a sub-lettering convention for grouped documents. It adds deposition designations and counter designations with the transcripts attached, highlighted and tabbed, which the county rule does not list. It sets the service trigger at statutory notice or 5 calendar days before readiness, whichever is sooner, which is earlier than the county rule's submission-at-the-conference default.

The order in its own words

REQUIRED DOCUMENTS FOR PRESENTATION TO COURT AT READINESS CALENDAR WITH SERVICE ON OPPOSING COUNSEL PURSUANT TO STATUTE OR 5 CALENDAR DAYS BEFORE READINESS DATE, WHICHEVER IS SOONER:

Trial Setting Orders, Rancho Cucamonga Superior Court, Dept. R12. Companions: Exhibits for Trial (r12exhibitsfortrial.docx), Trial Schedule (r12trialschedule.docx). · Undated. Files Last-Modified Wed, 09 Apr 2025. Legacy binary .doc format. · The order

Dept R14, Rancho Cucamonga Courthouse, Hon. Tony Raphael

Trial documents: Two non-appearance milestones, the same structure S-36 uses. The trial document exchange date is when counsel exchange the documents. The trial documents filing date is when all of them must be e-filed or hand delivered directly to the department, no fax filing: a joint witness list, a joint exhibit list on the attached form with exhibits pre-marked in numerical order and bates stamped, a joint statement of the case in jury cases only, plaintiff's jury instructions and special verdict in jury cases only, trial briefs in non-jury cases only, and oppositions to motions in limine. Separately, plaintiff emails the judicial assistant an editable Microsoft Word copy of the jury instructions, verdict forms and joint statement of the case by that same date; defendant emails Word copies of any additional instructions and a list of objections on the first day of trial. Parties who do not retain a Certified Shorthand Reporter and submit a Stipulation and Order for Appointment of Official Reporter Pro Tempore are deemed to have waived an official reporter.
Binder: A 3-ring binder with two sets for the court, one set for the witness and one set for the opposing party, four in all. Courtesy copies of all trial documents and of all motions in limine must be delivered to Dept. R14 on top of the e-filing. The judicial assistant emails the exhibit list template and counsel return one completed joint list by email to SScott@sb-court.org.
In limine: Expressly carved out of the two date structure. Pursuant to Local Rule 411.2 they are filed directly in Dept. R14 with service completed at least 8 days before the trial readiness conference, which is the county deadline restated. Must comply with Local Rules 411.2 and 415, with counsel expected to know Amtower, Kelly, and R&B Auto Center at 371 to 372 including the Rylaarsdam concurrence. Oppositions are a listed trial document due on the filing date.
Difference: Three additions to Rule 411.2. First, an editable Word submission of the instructions, verdict forms and joint statement of the case emailed directly to the judicial assistant, a deliverable the county rule does not contemplate in any format. Second, a courtesy copy of every trial document and every motion in limine delivered to the department on top of the electronic filing. Third, the two date exchange-then-file structure, which moves most trial documents off the conference date the county rule keys to. The trial brief is also inverted, required in non-jury cases only, and the four set exhibit binder has no county counterpart.

The order in its own words

Plaintiff shall email the Judicial Assistant an electronic copy in Microsoft Word format of the jury instructions, verdict forms, and joint statement of the case by the Trial Documents Filing Date.

Trial Setting Orders, Dept R14 · Undated blank template with the dates filled in by the judge. File Last-Modified Tue, 22 Apr 2025. · The order

Department R-17, Rancho Cucamonga Courthouse, Hon. Gilbert G. Ochoa

Trial documents: Presented at the readiness calendar with service on opposing counsel per statute or 5 calendar days before the readiness date, whichever is sooner: motions in limine in writing, a complete joint witness list, a complete joint exhibit list, a joint statement of the case, proposed jury instructions with a face page of CACI instructions in sequential order and the full instructions and specials attached, a proposed special verdict form if requested, and a trial brief. Joint means the court works from one set of documents, not that the parties agree. All mandatory except the trial brief, which is optional in jury trials under SBC Local Rule 411. MSC briefs are due at least five days before the MSC. The parties provide the court reporter, preferably with realtime, available from the evidence portion through the verdict.
Binder: No binder requirement in the trial court orders. The companion courtroom rules require all exhibits marked before the start of testimony with each party or counsel having reviewed them, PowerPoint slides for opening or closing shown to the opposing side with objections handled in chambers, no publication of any document without prior court permission, identification of each exhibit on the record every time it is published, and jury instructions submitted to the court on the first day of trial.
In limine: In writing. Counsel are directed to review R&B Auto Center v. Farmers Group at 371, Kelly v. New West Financial Services, and Amtower v. Photon Dynamics before submitting. The county 8 day rule is not restated in either document.
Difference: R-17 is the thinnest of the three Rancho Cucamonga trial orders and the closest to the county baseline. Its real departure sits in the companion courtroom rules: Rule 411.2 puts proposed jury instructions among the documents submitted at the trial readiness conference, while rule 11 of the companion states that jury instructions are to be submitted to the court on the first day of trial. It also sets the service trigger at statutory notice or 5 calendar days before the readiness date, whichever is sooner, and adds no binder, no bates stamping and no exhibit template, so a party coming from S33 or S36 can drop those.

The order in its own words

Required documents for presentation to court at readiness calendar; Service on opposing counsel pursuant to statute or 5 days calendar days before readiness date, whichever is sooner:

Trial Court Orders for Department R-17. Companion: Judge Ochoa's Courtroom Jury/Bench Trial Rules and Court's Trial Orders (r17courtroomjurybenchtrialrulesandcourtstrialorders.pdf). · Undated. Trial court orders Last-Modified Wed, 09 Apr 2025; the companion courtroom rules PDF Last-Modified Wed, 15 Apr 2026. · The order

Department V11, Victorville Courthouse, Commissioner Malalai Farooqi

Trial documents: Non-jury track. The parties meet and confer on all pre-trial matters at least 10 calendar days before the trial readiness conference and bring to the conference a three-ring Joint Trial Binder containing a table of contents, printed copies of the current operative pleadings including the operative complaint, answer, cross-complaint and answer to cross-complaint, a joint witness list with name, brief description and time estimate for each witness plus two courtesy copies to the clerk, a joint list of controverted issues and a joint list of stipulated facts, stipulations, a joint exhibit list plus two courtesy copies to the clerk, and trial briefs. Parties must have witnesses available, raise out of order testimony or scheduling accommodations with the court, and raise interpreter needs before trial starts. Continuances require prior notice under the local rules and the California Rules of Court.
Binder: Two binders. The Joint Trial Binder above, carried to the conference. Then three complete copies of the Joint Exhibit Binder brought to court on the first day of trial, one set for the witness pre-marked with Court Exhibit tags and two copies for the court. Each exhibit is marked with a discrete number and correctly identified. The parties must also provide copies of any deposition transcripts that will be used at trial.
In limine: Not addressed. The V11 standing order contains no motion in limine provision, so Local Rules 411.2 and 415 govern unmodified, which means filing with service completed at least 8 days before the conference.
Difference: Rule 411.2 requires no binder, no pleadings, no table of contents, no controverted issues list and no trial brief. V11 requires all five, assembled and carried to the conference. It is the only department in the county asking for three copies of the joint exhibit binder, two of them for the court. It separates the joint list of controverted issues from the joint list of stipulated facts, where the county rule asks only for a statement of any stipulated facts. The 10 calendar day meet and confer has no county counterpart.

The order in its own words

The parties shall meet and confer and bring to Court on the first day of trial, three complete copies of the Joint Exhibit Binder. One set should be for the witness, pre-marked with Court Exhibit tags. Two copies shall be for the Court.

Standing Trial Order and Trial Procedures for Non-Jury Trial, Department V11 · Rev 3/7/26, printed at the foot of the order. File Last-Modified Wed, 29 Apr 2026. · The order

Department V12, Victorville Courthouse, Hon. Jeffery R. Erickson

Trial documents: Presented to the court at the readiness calendar with service on opposing counsel per statute: written motions in limine, a complete joint witness list, conjoint exhibits, a joint statement of the case, jury instructions and a verdict form, and a trial brief which is optional in jury trials. Instructions come in two packets, packet one the CACI 100 and 200 series and packet two starting again at the 200 series through conclusion. Specially requested instructions are submitted in two formats, a working copy with supporting authority and a clean CACI format copy ready for the jury. Each packet and the verdict form carry a cover sheet with the case caption, labeled in bold as JURY INSTRUCTIONS or VERDICT FORM. Depositions are lodged on the readiness date along with remaining court reporter and jury fees. Subpoenaed documents reach the courtroom only if the clerk is told at readiness. Litigants provide one court reporter at their own expense from the readiness calendar through the verdict.
Binder: One unified exhibit set rather than per-party sets: the original for the clerk, one copy for the witness stand and one copy for the bench. Exhibits are numbered consecutively from Exhibit 1 through conclusion with no duplicates.
In limine: In writing, presented at the readiness calendar with service per statute, citing Kelly v. New West Financial Services, 49 Cal.App.4th 659. The county 8 day rule is not restated in the department order.
Difference: V12 flags its own exhibit rule as a change and calls for a meaningful meet and confer to implement it: one conjoint exhibit set numbered straight through with no duplicates, rather than each side numbering its own. Rule 411.2 asks only for witness and exhibit lists jointly submitted where possible and has no numbering rule. The two packet CACI structure with bold labeled cover sheets is department-specific, as is the requirement that the court reporter be engaged from the readiness calendar forward rather than from the start of evidence. V12 also carries a separate general order on AI materials intended as evidence, which has no county counterpart.

The order in its own words

All exhibits shall be CONJOINT. This is a significant change and requires a meaningful meet and confer. Exhibits shall be numbered consecutively, beginning with Exhibit 1 and continuing through conclusion, with no duplicate exhibits.

Trial Requirements for Department V12. Companion: General Order Re AI Materials Intended as Evidence (v12goreaimaterialsintendedasevidence.docx). · Rev.6.26.26, printed in the footer. File Last-Modified Wed, 29 Jul 2026. · The order

Where these departments disagree

Departments in this county state their deadlines in calendar days and court days. Those are not the same thing. Five court days and five calendar days can be eight days apart across a holiday week, so read the convention in your own department’s order rather than carrying a number across from another one.

Only the two points above are compared here. Everything else a department requires is in its own block, because the orders are written as prose and a table that flattened them would say things the orders do not.

Why your department can set a different date

Yes, and heavily. Three separate delegating provisions.

The delegating language in full

First, inside Rule 411.2 itself. The submission obligation is expressly subject to contrary direction from the bench: "On the date set by the Court, the parties and trial counsel shall appear and submit to the Court, unless otherwise directed by the Court, the following documents ..." That clause is not decorative. Departments use it to change both the method and the anchor. Dept S26 orders the same documents "filed at least 5 Court Days prior to the trial" rather than handed up at the TRC. Dept S37's form order has a blank "TRIAL DOCUMENTS FILING DATE" the judge fills in. Dept S33 orders them "filed directly in DEPT S33" on the date of the TRC.

Second, the TRC date itself is delegated: "The date of the trial readiness conference may be set by the Court at the time of the Trial Setting Conference." The county rule states no offset from trial.

Third, complex cases, which in this county includes every construction defect case, are handed off wholesale by Rule 412: "Cases designated as complex shall be governed by the Guidelines for the Complex Litigation Program, posted at https://sanbernardino.courts.ca.gov." The Guidelines then delegate themselves, in terms, at the top of the document: "Below are guidelines only. Judges may or may not choose to follow all or some of these guidelines. Check with the individual department." The Guidelines also contemplate that the real schedule will be a written order: "The court may issue formal, written case management orders. Typically, complex construction defect cases will proceed pursuant to such an order."

The scale of the delegation is visible on the court's own index. The Courtroom Information and Documents page lists trial orders for eighteen civil departments across three courthouses, under titles including Trial Setting Orders, Trial Rules, Trial Requirements, Standing Trial Orders, Jury Trial Court Orders, Trial Court Orders, Courtroom Rules and Trial Orders, Exhibits for Trial, Courtesy Copy Requirements, Trial Order for Non-Jury Trials and Court Standing Trial Order Non-Jury. Sixty department documents in all.

The delegation runs in both directions, and that is the trap. Two sampled departments shorten the county's own motion in limine deadline rather than lengthening it. Rule 411.2 requires filing with service complete at least 8 days before the TRC. Dept S37 requires "All motions in limine and opposition shall be filed and served directly to Dept S-37 at least 5 days before the Trial Readiness Conference." Dept S33 abandons the 8 days entirely and runs moving papers and oppositions on CCP 1005(b) with the TRC as the notional hearing date, replies due on the day of the TRC, with the motions actually heard on the first day of trial. Departments also add documents the county rule does not require: Depts S26, S27 and S37 all require trial briefs, which appear nowhere in the local rules. The county rule is a floor in some departments and a ceiling in others. Calendar off the department order, and use Rule 411.2 only where the department is silent.

Department orders published by this court

How your courthouse changes things

The Local Rules of Court apply countywide and draw no courthouse distinctions in Chapter 4, Chapter 5 or Chapter 6. Civil unlimited cases are filed and heard at three locations: the San Bernardino Justice Center (departments S14 through S37), the Rancho Cucamonga Courthouse (R12, R14, R17) and the Victorville Courthouse (V11, V12). The court publishes a General Order on where civil cases are filed and heard, and the Complex Litigation Program Guidelines direct parties to "review General Order #GO24-004 and the Certificate of Assignment for the proper filing location (San Bernardino Justice Center, Rancho Cucamonga Court, or Victorville Court)."

Courthouse by courthouse

The court also publishes separate calendaring guidelines for the San Bernardino Justice Center civil divisions and for the Barstow, Fontana, Joshua Tree, Needles, Rancho and Victorville districts. I pulled and read all seven. They cover hearing days and times for ex parte, IDCs, motions, summary judgment, ORAPs and court sponsored mediation. None of them says anything about trial documents, trial binders or the TRC, so they do not create a courthouse-by-courthouse trial document rule.

The variation that actually bites is department by department rather than courthouse by courthouse, and it cuts across all three locations. See departmentDelegation and binder above: exhibit binder copy counts of two, three and four in different San Bernardino Justice Center departments; motion in limine deadlines of 8 days (local rule), 5 days (S37) and CCP 1005(b) from the TRC (S33); trial documents due at the TRC (S27, S33), 5 court days before trial (S26) or on a date the judge writes into the order (S37). Rancho Cucamonga's R12 publishes its own "Exhibits for Trial" and "Trial Schedule" documents; Victorville's V11 publishes a "Trial Order and Trial Procedures for Non-Jury Trial." Two judges (S37 and V12) publish their own general orders on AI generated materials offered as evidence, and S33 embeds an AI evidence protocol in its sua sponte trial rulings. There is no countywide AI evidence rule.

County rules, area by area

These are the 29 rules this court publishes county wide. They apply everywhere in the county, and your department can require more.

Trial readiness conference

Set by the court A trial readiness conference is held in all unlimited civil cases and all complex cases. The court may set the date at the trial setting conference. The local rules fix no interval between the TRC and trial, so the actual date comes from the court's order in the individual case.

SBSC Rule 411.2, first paragraph

Rule text and note

A trial readiness conference shall be held in all unlimited civil and complex cases. The date of the trial readiness conference may be set by the Court at the time of the Trial Setting Conference.

Division confirmed. Chapter 4 is captioned CIVIL CASE MANAGEMENT and Rule 411.2 sits under RULE 411 TRIAL CONFERENCE. Rule 411.2 has no lettered or numbered subdivisions, so citation is to the paragraph. Limited civil cases get an initial trial setting conference under Rule 411.1 but are outside 411.2. Do not state a TRC-to-trial interval; the county publishes none.

Issue conference

-30 to 60 days, keyed to trial In a complex case the court may schedule a pretrial conference, generally thirty to sixty days before trial, at which counsel must be prepared to address jury or court trial, anticipated motions in limine, trial length, order of proof and witness scheduling with time estimates, video deposition testimony, evidentiary rulings on lengthy deposition testimony, stipulations of fact, stipulations on admission of exhibits, presentation of a large volume of documents to the jury, trial technology, and unusual legal or evidentiary issues.

Guidelines for the Complex Litigation Program (Updated October 2024), THE PRETRIAL CONFERENCE, incorporated by SBSC Rule 412

Rule text and note

The court may schedule a pre-trial conference, generally thirty to sixty days in advance of the trial.

Offset token -30_to_60_days is a literal token for the range the Guidelines state. "May" and "generally," so it is discretionary and approximate, and the Guidelines are expressly optional for the individual judge. This is the only pretrial proceeding in the county's published materials with any stated relationship to the trial date. It is a discussion agenda, not a filing deadline: the Guidelines list topics and impose no lodging or submission requirement. It is a different proceeding from the Rule 411.2 TRC.

Mandatory settlement conference

Set by the court An MSC is not automatic. The court may order one on dates set at the case management or trial setting conference. General civil cases as defined in CRC 1.6(4) filed before January 1, 2020 are exempt from the rule.

SBSC Rule 410

Rule text and note

The mandatory settlement conference may be ordered on the dates set by the Court at the case management or trial setting conference. All general civil cases, as defined in California Rules of Court, rule 1.6(4), filed before January 1, 2020, are exempted from compliance with this rule.

The MSC is not the trial document anchor in this county; the TRC is. Departments S25 and S31 publish combined MSC and trial orders, so in those two the conferences can be set together. Dept S26 requires MSC statements submitted directly in the department three court days before the MSC, which is shorter than the statewide five court days.

See the rule, keyed to the mandatory settlement conference MSC procedure is the statewide rule. San Bernardino adopts CRC 3.1380, under which each party must submit to the court and serve on every other party a mandatory settlement conference statement no later than five court days before the initial date set for the conference.

SBSC Rule 601, adopting Cal. Rules of Court, rule 3.1380; the statement deadline is rule 3.1380(c)

Rule text and note

The Court adopts California Rules of Court, Rule 3.1380, with respect to Mediations and Mandatory Settlement Conferences.

Corrected subdivision. The five court day statement deadline is CRC 3.1380(c) ("Settlement conference statement"), not 3.1380(b), which is "Persons attending." Verified against the Judicial Council's Title 3 PDF at courts.ca.gov/system/files?file=file/roc-title-3_3.pdf. Rule 601 adds no local statement, no local form, no local content list and no local page limit, so the five court days is an adopted statewide deadline, not a San Bernardino one. CRC 3.1380(c) also provides that the statement "must comply with any additional requirement imposed by local rule," which is where a department order such as Dept S26's three court day rule attaches.

At the mandatory settlement conference Trial counsel, the parties, and persons with full settlement authority must attend the settlement conference unless the court excuses them for good cause. In malpractice cases where a doctor's or hospital's consent to settle is required, that party either attends or gives the carrier express consent to settle.

SBSC Rule 611

Rule text and note

Trial counsel, parties, and persons with full authority to settle the case must attend the settlement conference unless excused by the court for good cause. In malpractice cases, where a doctor or a hospital's consent to settlement is required, those parties must either be present or must give the insurance company express consent to settle.

The adopted statewide rule is stricter on its face: CRC 3.1380(b) requires those persons to "personally attend." In complex cases the Complex Litigation Program Guidelines add the adjuster: "Parties with full settlement authority, including insurance adjustors with full settlement authority, must attend all mandatory settlement conferences."

At the mandatory settlement conference Unexcused absence from the settlement conference may result in sanctions, striking of pleadings, default proceedings or dismissal. Appearing unprepared is separately sanctionable.

SBSC Rule 615

Rule text and note

Unexcused absence from the conference may result in sanctions, and/or striking of pleadings, and/or default proceedings, and/or dismissal of the case. Failure to be prepared may also result in sanctions.

This is the strongest express noncompliance penalty in the county's civil trial and settlement rules, and it attaches to the settlement conference, not to the TRC. Rule 411.2 has no penalty clause. The only other civil sanction provisions are Rule 416 (failure to file a Notice of Settlement) and Rules 550 and 560 (law and motion calendaring). Verified by reading Chapters 3 through 7 and searching the whole document for "sanction."

Trial documents

At the trial readiness conference On the date the court sets, the parties and trial counsel appear and submit seven categories of trial documents to the court, unless the court directs otherwise. The rule does not say whether the appearance must be in person.

SBSC Rule 411.2, second paragraph

Rule text and note

On the date set by the Court, the parties and trial counsel shall appear and submit to the Court, unless otherwise directed by the Court, the following documents: 1) any oppositions to motions in limine; 2) proposed jury instructions; 3) proposed verdict forms; 4) witness and exhibit lists; 5) a statement of any stipulated facts; 6) proposed voir dire questions and/or questionnaires; and 7) a short statement of the case to be read to the jury, if applicable.

The rule says "shall appear," not "shall personally appear." Rule 411.1 expressly allows a remote appearance at the trial setting conference and Rule 411.2 says nothing, so treat in-person as unresolved. "Unless otherwise directed by the Court" is the delegation hook and the departments use it. Dept S26 orders these documents filed at least 5 court days before trial; Dept S37 orders them filed by a blank TRIAL DOCUMENTS FILING DATE the judge writes in; Depts S27 and S33 order them filed directly in the department on the date of the TRC. Read the department order before calendaring.

At the trial readiness conference Trial documents should be submitted jointly. A party may submit its own version only if the parties cannot agree on a joint one.

SBSC Rule 411.2, second paragraph

Rule text and note

Documents should be jointly submitted. If the parties cannot agree to jointly submitted proposed documents, each party can submit individual documents.

"Should," not "shall," so the county states a preference and gives the fallback in the same breath. Departments harden it. Dept S33 orders joint documents outright, defines joint as combined and integrated rather than one side's list pasted after the other's, orders parties who appear without them to meet and confer in the courthouse and return, calls failure cause for sanctions, and says the court will not continue the trial date over it.

Witness lists

At the trial readiness conference Witness lists are submitted to the court at the TRC. Rule 411.2 pairs witness and exhibit lists in one item and states a preference for joint submission.

SBSC Rule 411.2, second paragraph, item 4)

Rule text and note

On the date set by the Court, the parties and trial counsel shall appear and submit to the Court, unless otherwise directed by the Court, the following documents: 1) any oppositions to motions in limine; 2) proposed jury instructions; 3) proposed verdict forms; 4) witness and exhibit lists; 5) a statement of any stipulated facts; 6) proposed voir dire questions and/or questionnaires; and 7) a short statement of the case to be read to the jury, if applicable.

Rule 411.2 requires no time estimates, no subject of testimony and no preclusion of a witness left off the list; I read the rule in full and the phrase "witness list" appears nowhere else in the local rules except in the optional local form Witness List 13-15500-360, rev. 01/01/25. Dept S33 adds time estimates for direct, cross, redirect and recross, and defines joint to mean each witness is listed once, not once on each side's portion.

Exhibit lists

At the trial readiness conference Exhibit lists are submitted to the court at the TRC, paired with witness lists in the same item and preferably joint.

SBSC Rule 411.2, second paragraph, item 4)

Rule text and note

On the date set by the Court, the parties and trial counsel shall appear and submit to the Court, unless otherwise directed by the Court, the following documents: 1) any oppositions to motions in limine; 2) proposed jury instructions; 3) proposed verdict forms; 4) witness and exhibit lists; 5) a statement of any stipulated facts; 6) proposed voir dire questions and/or questionnaires; and 7) a short statement of the case to be read to the jury, if applicable.

Rule 411.2 requires no numbering scheme, no stamping, no description column and no witness cross-reference. The court publishes an optional local form, Exhibit List 13-15502-360, rev. 01/01/25, marked optional in the local forms index at the back of the rules PDF. The departments supply the detail and differ: Dept S33 requires exhibits pre-marked in numerical order, stamped at the bottom of each page with former stamps removed, plus a description and the name of the testifying witness; Dept S37's judicial assistant emails counsel an exhibit list template and wants one completed joint list returned by email.

At the motion filing In a complex case, exhibits attached to motions and oppositions must be separately tabbed at the bottom so they can be identified and retrieved.

Guidelines for the Complex Litigation Program (Updated October 2024), FORMAT OF PAPERS FILED IN CONNECTION WITH MOTIONS, incorporated by SBSC Rule 412

Rule text and note

Additionally, exhibits attached to motions and oppositions must be separately tabbed at the bottom, so that exhibits can be easily identified and retrieved.

This is the closest the county's own published materials come to a tabbing requirement, and it governs motion exhibits, not trial exhibits and not a trial binder. The same section adds that even where the parties have agreed to electronic service, "parties must still submit 'hard' copies to the court of any pleadings, motions, or other materials that are to be filed."

Jury instructions

At the trial readiness conference Proposed jury instructions are submitted to the court at the TRC. Rule 411.2 states a preference for joint submission.

SBSC Rule 411.2, second paragraph, item 2)

Rule text and note

On the date set by the Court, the parties and trial counsel shall appear and submit to the Court, unless otherwise directed by the Court, the following documents: 1) any oppositions to motions in limine; 2) proposed jury instructions; 3) proposed verdict forms; 4) witness and exhibit lists; 5) a statement of any stipulated facts; 6) proposed voir dire questions and/or questionnaires; and 7) a short statement of the case to be read to the jury, if applicable.

Rule 411.2 says nothing about CACI format, brackets, disputed instructions or who prepares the set. The four sampled department orders fill that in and do not agree. Dept S33 requires a complete set of joint instructions under CRC 2.1055 with all brackets and blanks filled in and disputed instructions clearly marked. Depts S26, S27 and S37 put the whole set on plaintiff and give defendant until the first day of trial for additions and objections.

Verdict forms

At the trial readiness conference Proposed verdict forms are submitted to the court at the TRC. Rule 411.2 states a preference for joint submission.

SBSC Rule 411.2, second paragraph, item 3)

Rule text and note

On the date set by the Court, the parties and trial counsel shall appear and submit to the Court, unless otherwise directed by the Court, the following documents: 1) any oppositions to motions in limine; 2) proposed jury instructions; 3) proposed verdict forms; 4) witness and exhibit lists; 5) a statement of any stipulated facts; 6) proposed voir dire questions and/or questionnaires; and 7) a short statement of the case to be read to the jury, if applicable.

The rule does not say general or special. Dept S33 asks for a "Joint General or Special Verdict in a jury trial." Depts S26, S27 and S37 fold the verdict into plaintiff's package as "Plaintiff's Jury Instructions/Special Verdict."

Statement of the case

At the trial readiness conference A short statement of the case to be read to the jury is submitted to the court at the TRC, if applicable.

SBSC Rule 411.2, second paragraph, item 7)

Rule text and note

On the date set by the Court, the parties and trial counsel shall appear and submit to the Court, unless otherwise directed by the Court, the following documents: 1) any oppositions to motions in limine; 2) proposed jury instructions; 3) proposed verdict forms; 4) witness and exhibit lists; 5) a statement of any stipulated facts; 6) proposed voir dire questions and/or questionnaires; and 7) a short statement of the case to be read to the jury, if applicable.

The rule does not say what "if applicable" excepts. A bench trial is the obvious reading, but Dept S33 uses the same carve-out differently, requiring a Joint Statement of the Case "only if the parties do not anticipate giving mini-openings" and capping mini-openings at three minutes per party absent a formal request at the TRC. Depts S26, S27, S33 and S37 all require a Joint Statement of the Case.

Deposition designations

-30 to 60 days, keyed to trial In a complex case, whether deposition testimony will be presented by video and the need for evidentiary rulings on lengthy deposition testimony are topics counsel must be prepared to address at the complex pretrial conference.

Guidelines for the Complex Litigation Program (Updated October 2024), THE PRETRIAL CONFERENCE, bullets 6 and 7, incorporated by SBSC Rule 412

Rule text and note

Whether deposition testimony will be presented by video. The need for evidentiary rulings on any lengthy deposition testimony to be presented at trial.

Verbatim is two consecutive bullets. This is a topic to be raised, not a designation deadline. The word "deposition" appears zero times in the Local Rules of Court, which I confirmed by searching the full 6,236 line extraction, so the local rules impose no page and line designation schedule, no counter-designation procedure and no lodging requirement. That negative covers the local rules and these Guidelines only. Sixteen department trial orders were not read, so assume a page and line schedule may come from the department order or from a case management order and check both.

Motions in limine

At the trial readiness conference Oppositions to motions in limine are among the documents submitted to the court at the TRC. Rule 411.2 sets no separate earlier deadline for an opposition and does not provide for a reply.

SBSC Rule 411.2, second paragraph, item 1)

Rule text and note

On the date set by the Court, the parties and trial counsel shall appear and submit to the Court, unless otherwise directed by the Court, the following documents: 1) any oppositions to motions in limine; 2) proposed jury instructions; 3) proposed verdict forms; 4) witness and exhibit lists; 5) a statement of any stipulated facts; 6) proposed voir dire questions and/or questionnaires; and 7) a short statement of the case to be read to the jury, if applicable.

Item 1 is the only responsive paper Rule 411.2 addresses; I read the rule in full. Departments override. Dept S33 orders moving papers and oppositions served and filed under CCP 1005(b) treating the TRC as the hearing date, with replies due on the date of the TRC and the motions heard on the first day of trial. Dept S37 requires all motions in limine and oppositions filed and served directly to the department at least 5 days before the TRC.

8 days before the trial readiness conference Every motion in limine must be in writing, and must be filed with service completed at least 8 days before the trial readiness conference. The 8 days run backward from the TRC, not from trial, and the rule says days, not court days.

SBSC Rule 411.2, third paragraph

Rule text and note

All motions in limine shall be in writing and filed with service completed at least 8 days before the conference.

"The conference" is the trial readiness conference, from the rule's own caption and placement. Filing and service both have to be complete by the deadline. Whether calendar days or court days are meant, and whether any extension for electronic service applies, are unresolved on the face of the rule; treat 8 calendar days as the outside limit and calendar earlier. Departments shorten and reshape this. Dept S37 requires all motions in limine and oppositions filed and served directly to the department at least 5 days before the TRC, plus a meet and confer and a declaration of compliance the county rule does not require. Dept S33 discards the 8 days and runs moving papers and oppositions on CCP 1005(b) with the TRC as the hearing date.

See the rule, keyed to the trial readiness conference Every motion in limine must also comply with Local Rule 415.

SBSC Rule 411.2, fourth paragraph, incorporating SBSC Rule 415

Rule text and note

All motions in limine shall comply with Local Rule 415.

Depts S26, S27, S33 and S37 each repeat the cross reference in their trial orders and each directs counsel to be familiar with Amtower v. Photon Dynamics, Inc. (2008) 158 Cal.App.4th 1582, Kelly v. New West Financial Services (1996) 49 Cal.App.4th 659 and R & B Auto Center, Inc. v. Farmers Group, Inc. (2006) 140 Cal.App.4th 327. Dept S33 attaches a $250 per motion sanction.

8 days before the trial readiness conference A motion aimed at keeping inadmissible and prejudicial matter from being mentioned or displayed in the jury's presence must be accompanied by a declaration that identifies the specific matter, represents that the subject was discussed with opposing counsel and that counsel either said the matter will be put before the jury or refused to stipulate otherwise, states the specific prejudice, and, where the motion seeks to bind a discovery answer, sets out the question and the answer and explains why impeachment will not cure the prejudice.

SBSC Rule 415(a), introductory clause and (a)(1) through (a)(4)

Rule text and note

Motions made for the purpose of precluding the mention or display of inadmissible and prejudicial matter in the presence of the jury shall be accompanied by adeclaration that includes the following: (1) A clear identification of the specific matter alleged to be inadmissible and prejudicial; (2) A representation to the court that the subject of the motion has been discussed with opposing counsel, and that opposing counsel has either indicated that such matter will be mentioned or displayed in the presence of the jury before it is admitted in evidence or that counsel has refused to stipulate that such matter will not be mentioned or displayed in the presence of the jury unless and until it is admitted in evidence; (3) A statement of the specific prejudice that will be suffered by the moving party if the motion is not granted; and (4) If the motion seeks to make binding an answer given in response to discovery, the declaration must set forth the question and the answer and state why the use of the answer for impeachment will not adequately protect the moving party against prejudice in the event that evidence inconsistent with the answer is offered.

"Adeclaration" is a typographical run-together in the court's published PDF, not an extraction error; I confirmed it against the raw text. The scope clause limits the declaration requirement to motions directed at matter in the jury's presence. Subdivision (a)(2) is the trap: an in limine motion filed without a real meet and confer and a declaration saying so does not comply. Rule 415 sets no deadline of its own; the 8 day offset comes from Rule 411.2, third paragraph.

See the rule, keyed to the trial readiness conference A motion in limine may not be used to seek summary judgment or summary adjudication, and may not be used to seek an order trying one issue before another.

SBSC Rule 415(b) and 415(c)

Rule text and note

(b) A motion in limine shall not be used for the purpose of seeking summary judgment or the summary adjudication of an issue or issues. Such motions may only be made in compliance with Code of Civil Procedure section 437c and court rules pertaining thereto. (c) A motion in limine shall not be used for the purpose of seeking an order to try an issue before the trial of another issue or issues. Such motions may only be made in compliance with Code of Civil Procedure section 598.

This is the provision behind the Amtower, Kelly and R & B Auto Center reading list in the department orders. Dept S33 gives advance notice that it will sanction $250 per motion for any motion violating the local rule, the cases, or a matter already covered by its sua sponte rulings.

At the court's order The court may defer ruling on a motion in limine and order that the subject matter not be mentioned or displayed in the jury's presence in the meantime. If it does, or if the motion is granted, counsel must instruct associates, clients, witnesses and others under their control accordingly.

SBSC Rule 415(d)

Rule text and note

The court may defer ruling upon a motion in limine and may order that no mention or display of the matter that is the subject of the motion is to be made in the presence of the jury unless and until the court orders otherwise. If the court so orders, or if the motion is granted, it is the duty of counsel to instruct associates, clients, witnesses, and other persons under their control, that no mention or display be made in presence of the jury of the matter that is the subject of the motion.

Dept S26 restates the duty in its own courtroom rules, requiring counsel to advise witnesses of any rules pertaining to them and of the court's rulings on motions in limine.

Other

At the trial readiness conference A statement of any stipulated facts is submitted to the court at the TRC.

SBSC Rule 411.2, second paragraph, item 5)

Rule text and note

On the date set by the Court, the parties and trial counsel shall appear and submit to the Court, unless otherwise directed by the Court, the following documents: 1) any oppositions to motions in limine; 2) proposed jury instructions; 3) proposed verdict forms; 4) witness and exhibit lists; 5) a statement of any stipulated facts; 6) proposed voir dire questions and/or questionnaires; and 7) a short statement of the case to be read to the jury, if applicable.

By its terms this is a statement of whatever stipulations exist. Rule 411.2 imposes no duty to meet and confer toward stipulations, though every sampled department order does impose one for the trial documents generally. In a complex case the Complex Litigation Program Guidelines put "Stipulations of fact" and "Stipulations regarding the admission of exhibits into evidence" on the pretrial conference agenda.

At the trial readiness conference Proposed voir dire questions, a proposed juror questionnaire, or both, are submitted to the court at the TRC.

SBSC Rule 411.2, second paragraph, item 6)

Rule text and note

On the date set by the Court, the parties and trial counsel shall appear and submit to the Court, unless otherwise directed by the Court, the following documents: 1) any oppositions to motions in limine; 2) proposed jury instructions; 3) proposed verdict forms; 4) witness and exhibit lists; 5) a statement of any stipulated facts; 6) proposed voir dire questions and/or questionnaires; and 7) a short statement of the case to be read to the jury, if applicable.

None of the four department orders sampled (S26, S27, S33, S37) lists this item. Sixteen other departments publishing trial documents were not read, so whether any of them repeats it is unknown. Carry the item regardless, because the local rule requires it and a department form order that omits it does not repeal it.

At the trial readiness conference A party who believes a witness name or an exhibit should stay confidential until it is used at trial tells the judge in camera rather than putting it on the list.

SBSC Rule 411.2, second paragraph

Rule text and note

If a party reasonably believes a witness's name or an exhibit should be confidential until used in trial, he/she shall so indicate to the Judge in camera.

This is the only accommodation for impeachment material in the local rules. It carries no procedure, no notice requirement and no form. Dept S33 separately orders that "Exhibits planned for impeachment should not be in the exhibit books."

10 days before the issue conference An Initial Trial Setting Conference Statement, local form 13-09001-360, must be filed and served no later than 10 days before the initial trial setting conference. The clerk sets that conference when the complaint is filed, for a court date on or before the twenty-sixth week after filing, and it is held without appearances unless good cause is shown or the case is at issue.

SBSC Rule 411.1, fourth paragraph

Rule text and note

The parties shall file and serve, no later than 10 days prior to the Initial Trial Setting Conference an Initial Trial Setting Conference Statement (local form #13-09001-360).

Anchor is a forced fit. San Bernardino has no proceeding called an issue conference; the initial trial setting conference is held "in lieu of a case management conference" and is the proceeding at which the trial date and the TRC date get set, so issue_conference is the closest available token and the row belongs in a trial preparation chart as the upstream event. Rule 411.1 also allows a stipulation to continue that conference if filed at least 30 days before it.

15 days before the issue conference Where the court sets a further trial setting conference after the initial one, an At Issue Memorandum must be filed and served no later than 15 days before that conference.

SBSC Rule 411.1, sixth paragraph

Rule text and note

The court may set further trial setting conferences following the initial trial setting conference. In that event, an At Issue Memorandum shall be filed and served no later than 15 days prior to the trial setting conference.

The court publishes an optional local form, General Civil Case At-Issue Memorandum 13-12390-360, eff. 09/01/13, marked optional in the local forms index at the back of the rules PDF. Do not confuse it with SB-12389, Family Law At-Issue Memorandum for Trial Setting.

15 days before trial Once a trial date is assigned, counsel must tell the assigned judge and all opposing counsel of any fact suggesting the case may not go to trial on that date. The court will accept a stipulation of all parties to continue the first set trial date, without an ex parte application, only if it is filed at least 15 days before the trial date.

SBSC Rule 416, first paragraph

Rule text and note

After a trial date has been assigned, it shall be the duty of counsel to inform the assigned Judge and all opposing counsel of any fact tending to indicate that the case may not proceed to trial on the date to which it has been assigned. The court will entertain, by written stipulation and without ex parte application, a written stipulation by all parties to continue the first set trial date if filed at least 15 days prior to the trial date.

The stipulation route reaches only the first set trial date. Past that, and in any department that refuses stipulations, it is an ex parte application under SBSC Rule 731 and CRC 3.1332 (adopted by SBSC Rule 418). Rule 731 requires the application filed by 12:00 p.m. on the court day before the hearing and notice to all parties by 10:00 a.m. that day. The court's own index states for Dept S35 that "Joint stipulations to continue Trial are not accepted. ExParte Applications are required for ALL Trial continuances."

See the rule, keyed to the court's order Cases designated as complex are governed by the court's Guidelines for the Complex Litigation Program. Construction defect cases are initially assigned as complex whether or not a party designates them, subject to the court's determination at the Initial Case Management Conference.

SBSC Rule 412

Rule text and note

Cases designated as complex shall be governed by the Guidelines for the Complex Litigation Program, posted at https://sanbernardino.courts.ca.gov.

Narrowed. The Guidelines say that "Whether or not the parties designate the case as complex or provisionally complex, the following cases will be initially assigned as Complex Litigation: All Construction Defect Cases." Initial assignment is not the same as Rule 412's trigger, which is designation. At the Initial CMC "the court will determine whether the action is a complex case, as required by California Rules of Court, rule 3.403," and if it is not complex "the case will be retained by the judge, but not treated as a complex case." The Guidelines are also self-limiting: "Below are guidelines only. Judges may or may not choose to follow all or some of these guidelines. Check with the individual department." They contemplate that the operative schedule will be a written order: "The court may issue formal, written case management orders. Typically, complex construction defect cases will proceed pursuant to such an order." Rule 411.2 by its terms still covers "all unlimited civil and complex cases," so whether a complex case gets the TRC in addition to the complex pretrial conference is unresolved in the published text and has to be confirmed with the department.

At the motion filing Any document submitted with exhibits must carry a separator page before each exhibit bearing the word Exhibit and the exhibit number or letter, in at least 14 point type, in the middle or lower third of the page.

SBSC Rule 322 (Chapter 3, Court Business Procedures)

Rule text and note

Parties submitting documents that contain exhibits shall ensure that the pages between exhibits contain the word, "Exhibit", and the number or letter associated with the exhibit in no less than 14 font in the middle or lower third of the page.

Chapter 3 is court-wide business procedure, not civil specific, and it reaches any document containing exhibits. Included because it is the county's only published rule on exhibit separators and the nearest thing in the local rules to a tabbing or indexing requirement. It is not a trial binder rule. The only other copy requirement anywhere in the local rules is Rule 421, which requires one extra copy with each original civil unlimited complaint.

What happens if you miss it

The county rule attaches no consequence to noncompliance with the trial readiness conference obligations. Rule 411.2 has no penalty clause. Rule 415 has none. I read both in full.

The sanction language in full

The published civil consequences that touch trial preparation are these, and none of them is aimed at the TRC:

Settlement conference, SBSC Rule 615: "Unexcused absence from the conference may result in sanctions, and/or striking of pleadings, and/or default proceedings, and/or dismissal of the case. Failure to be prepared may also result in sanctions."

Failure to report a settlement, SBSC Rule 416: "In the event of settlement, the parties shall immediately notify the Court thereof and file and serve a Notice of Settlement. Failure to do so may be cause for imposition of sanctions."

Law and motion, SBSC Rule 560: the court may on its own motion take off calendar motions unsupported by a meet and confer declaration, summary judgment motions where the separate statement is missing or deficient or where all exhibits are not included, and ORAP motions without a proof of service filed at least ten days before the examination. Rule 550 adds that failure to give timely notice of a continuance request "may result in the matter being taken off calendar or deemed to have been submitted for the Court's ruling."

Complex cases, Guidelines for the Complex Litigation Program: "Failure to participate meaningfully in the 'meet and confer' process or failure to submit a Joint Statement may result in the imposition of monetary or other sanctions," and the same phrase again for the pre-hearing motion conference.

One caution on a rule that looks like it fits and does not. SBSC Rule 1610 reads "Any attorney who fails to comply with the local rules of Court may be subject to sanctions, including monetary sanctions, and, at the discretion of the Judge of the Juvenile Court, may be reported to the State Bar and/or removed from the appointment list." That is Chapter 16, Juvenile Rules. It is not a general civil sanctions provision and should not be cited as one.

The real exposure for trial documents is again departmental. Dept S33 states it in the order: "If the parties appear without joint documents, the Court will order the parties to meet and confer in the courthouse and return to S33 with the required joint documents. Failure to comply with the joint document requirement is cause for sanctions. The Court will not continue the trial date on account of the parties' failure to prepare joint documents." The same order gives advance notice of a fixed sanction on motions in limine: "This constitutes notice that the Court will issue sanctions in the amount of $250 per motion for any motion that violates the Local Rule, cases, or is already addressed by a sua sponte ruling." It also warns of sanctions for padding the exhibit books, citing a prior instance of 92 identified exhibits against 15 actually offered.

Is a trial binder required at all?

San Bernardino publishes no trial binder or trial notebook requirement in its local rules. I read the Local Rules of Court effective July 1, 2026 in full and searched the entire 6,236 line text: the words "binder" and "notebook" do not appear anywhere in the document, in the civil chapters or in any other chapter. There is no joint binder, no tab requirement for trial documents, no index requirement, no copy count, no paper or electronic specification and no delivery instruction for trial materials in the county rules. The closest published county provisions are Rule 322, which requires a separator page carrying the word "Exhibit" and the number or letter in at least 14 point type between exhibits in any document submitted to the court, and the Complex Litigation Program Guidelines, which require that "exhibits attached to motions and oppositions must be separately tabbed at the bottom, so that exhibits can be easily identified and retrieved." Both govern papers filed with motions, not a trial binder.

How that was tested

What the county rule does say about delivery is in Rule 411.2: the parties and trial counsel "shall appear and submit to the Court, unless otherwise directed by the Court" the seven categories of trial documents, at the TRC, in person. Joint submission is preferred but not mandatory: "Documents should be jointly submitted. If the parties cannot agree to jointly submitted proposed documents, each party can submit individual documents."

The binder requirement exists in this county, but it is departmental. Working the assumption that a practitioner needs the real answer and not just the rule set answer, I pulled the court's own index of civil department standing orders and sampled several. They impose binders and they do not agree with one another:

Dept S33 (Hon. Stephanie Tanada), Trial Setting Orders ver. 12/29/25: "A working copy for the judge's convenience should be provided in a tabbed binder." Trial briefs, where the court has asked for one, "shall be included in the judge's working binder with the witness list, exhibit list, etc." Exhibits "shall be place in 3-ring binders with 1 copy for the Court, 1 for the witness and 1 for all other parties to the action." And separately for motions in limine: "At the Trial Readiness Conference, the moving party is to present their MILs in a tabbed and indexed binder (or binders) in numerical order. Each number shall have the moving papers, opposing papers, and replies back-to-back, for ease of the Court reference."

Dept S27 (Hon. Thomas Garza): "Exhibits shall be placed in 3-ring binders with 1 copy for the Court, 1 for the witness and 1 for opposing party." Three copies.

Dept S26 (Hon. Kevin C. Lee): "Exhibits shall be placed in 3-ring binders with one copy for the Court and one for the witnesses." Two copies.

Dept S37 (Hon. Winston Keh): "Exhibits shall be placed in A 3-ring binder with 2 sets for the Court, 1 set for the witness and 1 set for the opposing party." Four sets, two of them for the bench.

So the copy count alone runs from two to four depending on the department. Dept R12 in Rancho Cucamonga publishes a standing document titled "Exhibits for Trial" that was not sampled. The practical answer for this tab: the county requires no binder, every sampled civil department requires one, paper and three-ring, and the count, the tabbing and whether the judge gets a separate working binder of the trial documents all come from the individual department's trial order. Pull the department order at the trial setting conference and re-pull it near the TRC, since Dept S33's order says in its opening line that "These Orders are constantly evolving based on the Court's needs. Counsel is encouraged to re-check these rules within a month of the Trial Setting Conference to ensure they have not changed."

What this page does not tell you

Not published by this court

Finding

Somebody read this court’s civil rules on each point below and the court publishes nothing. That does not mean no deadline exists, because your department may set one.

No trial binder or trial notebook requirement. The Local Rules of Court effective July 1, 2026 were read in full and the entire 6,236 line text searched. The words "binder" and "notebook" appear zero times in the document, in any chapter. The county publishes no requirement that a binder be prepared, no joint versus per party rule, no tab or index requirement, no copy count, no paper versus electronic specification, and no delivery instruction or location for trial materials.
No trial brief requirement. The word "brief" appears four times in the whole rules document: once in Rule 1320, a Penal Code section 995 motion rule in Chapter 13 (Criminal Rules); once in Chapter 16 (Juvenile Rules) at a report content provision; and twice as the name of an optional family law local form, SB-598 Settlement Conference Brief. Chapter 4, Chapter 5 and Chapter 6 contain no civil trial brief provision. Rule 411.2's enumerated list of seven trial documents does not include one. Note the contrast with practice: Depts S26, S27 and S37 all require trial briefs by standing order, and Dept S33 requires them only for bench trials and states it will not consider unrequested ones.
No deposition designation requirement. The word "deposition" appears zero times in the entire Local Rules of Court. There is no page and line designation deadline, no counter-designation procedure, no objection procedure and no lodging requirement for deposition testimony to be used at trial. The only published county mention of the subject is in the Complex Litigation Program Guidelines, where video presentation of deposition testimony and the need for evidentiary rulings on lengthy deposition testimony appear as agenda items for the complex pretrial conference, not as deadlines.
No courtesy copy rule. The word "courtesy" appears zero times in the Local Rules of Court. Chapter 18 (Electronic Filings and Service) was read in full and contains no trial-specific paper copy requirement. The Complex Litigation Program Guidelines add a general one for complex cases, that parties must still submit hard copies to the court of pleadings, motions or other materials to be filed, but say nothing about trial documents. At department level, Dept S35 publishes a document titled Courtesy Copy Requirements, which confirms the county left this to the departments.
No penalty clause in Rule 411.2. The rule was read in full. It states no sanction, no waiver, no preclusion of unlisted witnesses or exhibits, and no exclusion remedy for late trial documents. The only express noncompliance penalties in the civil rules attach to the settlement conference (Rule 615), the Notice of Settlement (Rule 416) and law and motion calendaring (Rules 550 and 560). Rule 1610, which does supply a general sanction for failing to comply with local rules, is a Chapter 16 juvenile rule and is not available in a civil case.
No county offset between the trial readiness conference and the trial date. Rule 411.2 states only that the date "may be set by the Court at the time of the Trial Setting Conference." There is no published interval, minimum or maximum. The only interval anywhere in the county's published materials is the complex pretrial conference at "generally thirty to sixty days in advance of the trial," and that is a different conference in a different document.
No final status conference and no issue conference by those names. Chapter 4 names three pretrial proceedings: the mandatory settlement conference (Rule 410), the trial setting conference (Rule 411.1) and the trial readiness conference (Rule 411.2). "Final status conference" and "issue conference" do not appear in the rules. The TRC is the trial document anchor in this county.

Still open

Gap

Nobody could resolve these. They are not findings, and they are listed in full rather than collapsed, because an unresolved question is the one thing a reader must not miss.

Whether "at least 8 days" in Rule 411.2 means calendar days or court days. The text says "8 days" with no qualifier, and the rule is silent on how to count. The default under CCP 12 would be calendar days, excluding the first and including the last, but the local rule does not say so and no published county material construes it. Compounding the problem, the deadline is a combined filing and service deadline ("filed with service completed"), so whether the two court day extension for electronic service under CCP 1010.6(a)(3)(B) has any role is also unresolved. Treat 8 calendar days as the outside limit and calendar earlier.
Whether the Rule 411.2 documents are to be filed, lodged or physically handed up. The rule says "submit to the Court," which is neither of the defined terms. Rule 571 governs lodging only for law and motion exhibits and requires a Notice of Lodgment citing the authorizing statute or rule, and Rule 411.2 is not such an authorization on its face. Departments answer this in conflicting ways (S33 and S27 say "filed directly in" the department; S37 has a filing date; S26 says filed before trial), which suggests the county rule leaves it open.
How many copies of the Rule 411.2 documents the county expects, and whether the judge gets a working set. The rule says nothing. Sampled department orders say two, three or four sets for exhibits, and only Dept S33 mentions a working binder of the trial documents themselves. I did not sample all eighteen civil departments.
Whether a case designated complex is excused from the Rule 411.2 TRC or gets both the TRC and the complex pretrial conference. Rule 411.2 by its terms covers "all unlimited civil and complex cases," which reads as both, and Rule 412 says complex cases "shall be governed by" the Guidelines, which reads as the Guidelines displacing ordinary case management. The two provisions are not reconciled in the published text, and the Guidelines' own pretrial conference section does not mention the TRC. For a construction defect case this matters, and it should be confirmed with the assigned department.
Whether General Order GO24-004, referenced in the Complex Litigation Program Guidelines for filing location, carries anything on trial documents. I did not retrieve it. The court's General Orders page lists a general order on where civil cases are filed and heard but the listing does not print order numbers, so I could not confirm which file is GO24-004.
What Dept S31's Standing Trial Orders require. The posted order, s31standingtrialorders.pdf, is a scanned image with no text layer, so its contents could not be read and have to be reviewed by a person.
Whether the eleven civil departments not sampled (S14, S16, S17, S22, S23, S24, S25, S28, S29, S30, S32, S35, S36, R12, R14, R17, V11, V12) impose binder, tab, index or copy requirements different from the four sampled. The court's index shows each publishes trial orders, and the four sampled already disagree with one another on copy count and motion in limine timing, so the spread is probably wider than what is recorded here.
Whether the local Exhibit List form 13-15502-360 (rev. 01/01/25) is ever required rather than optional. The rules' own local forms index marks it optional, but Dept S37 states its judicial assistant emails counsel an exhibit list template and expects one completed joint list returned by email, which may or may not be the same form.

Sources

Superior Court of California, County of San Bernardino. Effective July 1, 2026.

Every document read for this county, 13 items

Effective July 1, 2026. The cover page reads "Local Rules of Court / Effective July 1, 2026" and the index page reads "LIST OF CURRENTLY EFFECTIVE LOCAL RULES / JULY 1, 2026." The PDF is published in redline form (new content underlined, deleted content stricken), which pdftotext flattens, so a struck year can appear run together with its replacement (the small claims chapter heading extracts as "JULY 1, 200326"). Rule 411.2 itself carries no 2026 change; its own history line ends "As amended, eff. January 1, 2017." The Complex Litigation Program Guidelines, which Rule 412 incorporates, print "Updated October 2024."

Court rules change and department assignments change every January. Check the court’s own page and your department’s order before relying on this.

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