Judge Dale S. Fischer — United States District Court, Central District of California

All civil documents must be filed electronically via CM/ECF. Filing deadline is midnight Pacific Time. Electronic signatures using "/s/ [name]" are permitted. CDCA requires mandatory chambers copies — one copy of every e-filed document, delivered by noon the next business day, labeled "MANDATORY CHAMBERS COPY." L.R. 5-3 through 5-4.

Electronic Filing

Service

Electronic service (L.R. 5-3.2.1): CM/ECF filing = service on all registered users. NEF is proof of service. Non-electronic (L.R. 5-3.1): For parties not on CM/ECF, serve per FRCP 5.

Mandatory Chambers Copies (L.R. 5-4.5)

One copy of every e-filed document. Delivered by noon next business day. Must comply with L.R. 11-3 (blue-backed, proper font, tabbed exhibits). Labeled "MANDATORY CHAMBERS COPY" on face page. Include CM/ECF header and NEF as last page. Check judge for delivery location.

Practice tip: Some judges have stopped requiring chambers copies. Check standing order.

CDCA requires 14-point proportionally spaced font (or 10.5 characters/inch monospaced), double spacing including citations and quotations, and a 7,000-word limit for motions. Footnotes may be single-spaced. Every brief over 10 pages needs a table of contents and table of authorities. L.R. 11-3 et seq. and L.R. 11-6.

Document Formatting (L.R. 11-3)

Word/Page Limits (L.R. 11-6.1)

Certificate of compliance required (L.R. 11-6.2): Every brief (except handwritten/typewriter) must include a certificate on the last page stating the word count.

Table of contents and authorities required (L.R. 11-8): For any memorandum or brief exceeding 10 pages.

Only ONE attorney per party may be designated as lead trial counsel unless otherwise permitted by the Court. [Standing Order § 1; Scheduling Order § 1(o).]

Lead trial counsel must attend every proceeding set by the Court, including all scheduling, pretrial, and settlement conferences. [Standing Order § 1.]

No co-lead dodge: Counsel should not claim to be co-lead trial counsel for the purpose of avoiding this requirement. If counsel purport to be co-lead trial counsel, both must attend the pretrial conference and all proceedings set by the Court. [Standing Order § 1.]

Failure to appear: Unless lead counsel's absence is excused for good cause in advance or due to an emergency that prevented prior notice, the Court reserves the right to designate the attorney handling such proceeding as lead counsel for all purposes. Failure of lead counsel to appear will be grounds for sanctions. [Standing Order § 1.]

Scheduling conference specifics: Lead trial counsel must attend the scheduling conference. When seeking permission not to attend, lead counsel must identify the substitute by name and bar number and specify that person's involvement. The Court may choose to postpone rather than permit someone other than lead trial counsel to attend. Neither local counsel nor other counsel designated as trial counsel may appear at a scheduling conference in place of lead trial counsel. [Scheduling Order § 2(a).]

CAVEAT: If lead counsel is not excused by the Court in advance, the attorney who appears at the scheduling conference will be deemed lead counsel. [Scheduling Order Caveat.]

If you have a conflicting appearance before a more senior district judge, you must email the CRD (Patricia Kim) with: (1) the time of the conflicting appearance, (2) the case name, and (3) the name of the other judge. [Fischer Procedure #3.]

On the day of the conflict: If possible, ask the other judge's CRD to update Fischer's CRD (Patricia Kim) as to when you are likely to be released.

For all other reasons for being late or missing an appearance: Good cause must be shown. The procedure does not specify the format, but email to the CRD is the established channel.

Note: This rule only expressly addresses conflicts with "a more senior district judge." It does not state what to do for conflicts with magistrate judges, state courts, or other federal courts. The safe approach: follow the same protocol (email CRD with details) regardless of the conflicting court.

Pinpoint citations required: Citations to case law must identify the specific page referenced, not just the case. [Standing Order § 4d.]

Westlaw preferred over Lexis: When citing to legal databases (which is 'not encouraged'), cite to Westlaw rather than Lexis whenever possible. [Standing Order § 4d.]

Cite the U.S. Code: Statutory references must cite to the United States Code, not solely a section of a particular act (e.g., cite 42 U.S.C. § 1983, not just 'Section 1983 of the Civil Rights Act'). [Standing Order § 4d.]

Treatises and manuals: Include volume, section, and relevant pages. If materials are not readily accessible, copies should be attached — especially important for historical materials (e.g., older legislative history). [Standing Order § 4d.]

Citations in main text, NOT footnotes: Citations that support a statement in the main text must be included in the main text, not in footnotes. [Standing Order § 4d.]

String cites discouraged: String cites are discouraged and generally are not helpful. [Standing Order § 4d.]

Practical guidance: If your firm's standard brief style places citations in footnotes, reformat for Fischer. If you habitually cite to Lexis, switch to Westlaw. If you use act names without U.S. Code references, add the Code citation.

Fischer imposes page limits, not word limits, for motion papers:

[Standing Order § 4c.]

Extensions: Only in rare instances and for good cause shown will the Court grant an application to extend these page limitations. [Standing Order § 4c.]

Key difference: CDCA Local Rule 11-6.1 uses a 7,000-word limit. Fischer uses page limits instead. The reply limit of 12 pages is notably shorter than the opening brief limit of 25 pages (roughly half). Some CDCA judges (e.g., Kronstadt) allow 25 pages for replies — Fischer does not.

Practical impact: If you are accustomed to CDCA's word-count regime, switch to page counts for Fischer. A 25-page brief in 14-point proportionally spaced font with double spacing is approximately 5,000-6,000 words — tighter than the 7,000-word default.

Civil motions are heard Mondays at 1:30 p.m. Criminal motions are heard Mondays at 8:30 a.m. If Monday is a holiday, the next motion date is the following Monday.

It is not necessary to clear a motion date with the Courtroom Deputy Clerk (CRD) before filing the motion.

Key difference from Kronstadt: Kronstadt hears civil motions at 8:30 a.m.; Fischer hears them at 1:30 p.m. Plan travel accordingly.

CDCA baseline (L.R. 6-1): The moving party selects the hearing date and files notice designating that date at least 28 days before (31 if served by mail). Fischer follows this default — no pre-clearance required.

[Fischer Court Page — Law and Motion Schedule]

Stipulated briefing schedules permitted so long as the schedule provides at least two weeks between the filing of the reply and the hearing date. [Standing Order § 4a.]

7-day notification rule: If the parties resolve the issue, or if a party intends to withdraw or declines to oppose a motion, the Court must be notified as soon as possible, but no later than 7 days before the hearing date. [Standing Order § 4a.]

Failure to oppose = immediate grant: Failure to oppose a motion will likely result in the motion being granted immediately after the opposition would have been due. [Standing Order § 4a.] This is stronger than many judges who simply take the motion under submission.

Holiday schedule: Opposition papers due on a Monday holiday may be filed the following Tuesday. Reply papers may then be filed on the next Tuesday. [Standing Order § 4a.]

Pre-filing conferral — no pro per exception: The pro per status of one or more parties does not eliminate the L.R. 7-3 meet-and-confer requirement. Failure to comply will be grounds for sanctions. If fault is attributed to the moving party, the Court may decline to hear the motion. [Standing Order § 4b.]

Motions to dismiss strongly discouraged: See Rule 12 / Motions to Amend component. [Standing Order § 5a.]

Opposition due 21 days before hearing. Reply due 14 days before hearing. Sur-replies not permitted without prior written court order. Discovery motions follow a separate timeline with a mandatory joint stipulation. If a hearing is continued, deadlines automatically reset. L.R. 6-1, 7-9, 7-10, 37-1 through 37-4.

Regular Motions

New Trial Motions (L.R. 7-9)

Opposition: 10 days after service of the motion.

Discovery Motions (L.R. 37-1 through 37-4)

Continuances (L.R. 7-11)

If continued, opposition/reply deadlines reset to 21/14 days before new hearing date.

CDCA follows F.R.Civ.P. 6 for time computation.

The Court does not issue tentative rulings. [Fischer Procedure #4.]

This is a flat prohibition — not "tentative rulings may be issued" (Kronstadt) or "tentative rulings are posted online." Fischer does not provide any advance indication of how the Court is leaning on a motion.

Practical impact: Counsel must prepare for oral argument on every motion without the benefit of a tentative. You will not know the Court's thinking until the hearing itself (or until a written order issues). Prepare for argument in both directions.

CDCA uses a party-selects model — you pick a date from your assigned judge's motion calendar and designate it in your notice of motion. File notice 28 days before hearing (31 if served by mail). The Court may decline any motion that doesn't comply with L.R. 7-3 through 7-8, including the meet-and-confer requirement. L.R. 6-1 through 7-18.

Key point: The Court may decline to consider any motion that doesn't comply with L.R. 7-3 through 7-8 (L.R. 7-4).

Ex Parte Applications (L.R. 7-19)

Must include: name/address/phone/email of opposing counsel, reasons for ex parte relief, points and authorities. Must lodge proposed order. Must make reasonable efforts to orally advise opposing counsel (L.R. 7-19.1).

Motion for Reconsideration (L.R. 7-18)

Grounds: (a) new fact/law not known with reasonable diligence, (b) new facts/law after the order, (c) manifest failure to consider material facts. Deadline: 14 days after entry. Cannot repeat prior arguments.

Proposed orders must not contain: attorney names, addresses, etc. on the caption page; a footer with the document name or other information; a watermark or designation of the firm name in the margin. [Standing Order § 3b.]

Must include Judge Fischer's name spelled correctly and her correct title: Dale S. Fischer, United States District Judge. [Standing Order § 3b; Fischer Procedure #6.]

Consequence: Documents that do not meet these requirements may be stricken. [Standing Order § 3b.] The web page states orders with incorrect spelling or title "will not be signed." [Fischer Procedure #6.]

Correct format:

Dale S. Fischer, United States District Judge

Rule 12 motions are "strongly discouraged." Many can be avoided if the parties confer in good faith per L.R. 7-3, especially for defects correctable by amendment. [Standing Order § 5a.]

If a motion to dismiss is granted with leave to amend:

• Plaintiff must file the amended complaint within the Court's specified time period.
• A redlined version must be delivered to Chambers AND to Chambers email showing all additions and deletions. [Standing Order § 5a.]
• Failure to file within the time allotted = dismissal with prejudice of the action or relevant claims. [Standing Order § 5a.]

Motions to amend pleadings must include:

• Statement of the effect of the amendment.
• Page, line numbers, and wording of any proposed change or addition.
• Redlined version of the proposed amended pleading delivered to Chambers (paper) AND Chambers email.
• All amended pleadings must be serially numbered to differentiate from previous amendments. [Standing Order § 5b.]

Practical guidance: Fischer disfavors motions to dismiss because they waste time when a meet-and-confer could resolve the issue. If you must file one, expect the Court to grant leave to amend rather than dismiss outright. But if your client is the plaintiff and leave to amend is granted, the clock is hard — miss it and the case is over.

L.R. 7-3 requires an in-person, telephone, or video conference at least 7 days before filing any motion. If unresolved, file a declaration under penalty of perjury stating the dates of conference and each party's position. Discovery motions have stricter requirements under L.R. 37-1 — including a mandatory joint stipulation signed by both counsel instead of separate briefs.

L.R. 7-3 — Conference of Counsel Prior to Filing of Motions

L.R. 37-1 — Discovery Meet and Confer (Stricter)

Do not contact the Court or Chambers staff by telephone or by any other ex parte means unless contact has been first initiated by Chambers staff. [Standing Order § 14.] Contact the courtroom deputy clerk with appropriate inquiries only. Preferred method: email (Patricia Kim, Patricia_Kim@cacd.uscourts.gov). List email addresses along with telephone numbers on all papers. [Standing Order § 14.]

Status inquiries: Will not be responded to unless the matter has been pending for more than 90 days. [Fischer Procedure #8.]

“Notice of Unavailability” has no force or effect in this Court and should not be filed. The filing of such a document may result in sanctions. [Standing Order § 16.] This is not a soft suggestion — Fischer treats filing a Notice of Unavailability as sanctionable conduct.

Other restrictions:

• Do not contact chambers or the CRD about law clerk positions — Fischer posts on OSCAR. [Procedure #10.]
• Neither Fischer nor her CRD will respond to media requests. [Procedure #11.]
• For transcripts, interpreter services, or courtroom technology, see the Central District website. [Procedure #12.]
• Do not contact the Court about whether your matter remains on calendar or for Zoom instructions. [Important Notice.]

The single permitted channel: Email the CRD only for scheduling-related matters such as calendar conflicts [Procedure #3] or requesting leave to bring electronic equipment [Procedure #13].

CDCA follows the federal defaults for most discovery rules but requires sequential numbering across all sets of interrogatories, RFPs, and RFAs. Every response must quote the request in full before the answer or objection. Discovery motions require a joint stipulation, not separate briefs. L.R. 33-1, 34-1, 36-1, 37-1 through 37-4.

Discovery Motions (L.R. 37-1 through 37-4)

7,000-word limit does NOT apply to the joint stipulation (L.R. 37-2.1), but joint stips over 10 pages need a TOC. Each party may file a supplemental memo (max 5 pages) 14 days before hearing (L.R. 37-2.3). Discovery motions generally cannot be heard ex parte.

All discovery matters are referred to the assigned magistrate judge. [Standing Order § 2; Fischer Procedure #2.]

All discovery documents must include the words “DISCOVERY MATTER” in the caption to ensure proper routing. Counsel should not deliver chambers copies of discovery documents to Judge Fischer. [Standing Order § 2.]

Protective orders: Proposed protective orders pertaining to discovery must be submitted to the assigned magistrate judge. Protective orders should not purport to allow filing under seal of pleadings or documents filed in connection with a dispositive motion (including class certification) or trial before Judge Fischer without further order. The existence of a protective order does not alone justify filing under seal. [Standing Order § 2.]

Scope: The referral covers all discovery motions AND stipulations. Check the assigned magistrate judge's procedures for hearing dates and briefing requirements.

Default posture: In-person. The Court is "unlikely to agree to a telephonic appearance in the absence of extraordinary circumstances preventing counsel from appearing in person." [Fischer Procedure #1; Standing Order § 6.]

Important Notice: Do not contact the Court to ask if your matter remains on calendar or for Zoom call-in instructions. If the matter will be held by Zoom, the Court will advise you in advance. If you hear nothing, a personal appearance is required. [Web page.]

The standard is "extraordinary circumstances" — a higher threshold than "good cause." [Standing Order § 6.]

CDCA requires a separate Statement of Uncontroverted Facts (SUF) with pinpoint citations. The opposing party must file a Statement of Genuine Disputes in a mandatory two-column format. A Rule 56 motion may NOT be granted solely on failure to oppose. L.R. 56-1 through 56-4.

MSJ follows the standard schedule: notice 28 days, opposition 21 days, reply 14 days.

Practice tip: The two-column format is mandatory. See L.R. 56-2 and the example at Chapter I, pages 74-75.

Class Actions:

• Class cert motion must be filed no later than 120 days from the date initially set for the scheduling conference, without regard to any continuances, unless the Court orders otherwise. [Standing Order § 10; Scheduling Order § 1(s).]
• Parties must act diligently and begin discovery immediately. [Standing Order § 10.]
• A continuance of the scheduling conference date will not extend the time to file the class cert motion. [Scheduling Order § 1(s).]

Fictitiously Named Defendants (Doe Defendants):

• In diversity-removal cases: plaintiff must ascertain identity and serve Does before the Rule 16(b) scheduling conference. [Standing Order § 11.]
• Court generally will dismiss Doe defendants at the scheduling conference because they prevent accurate case tracking. [Standing Order § 11.]
• If more time needed, request must be made in the Joint Rule 26(f) Report with reasons. [Standing Order § 11.]
• To substitute: first seek consent of all defendants; if withheld, file motion on regular notice addressing whether remand is warranted if diversity is destroyed. [Standing Order § 11.]

ERISA Benefit Claims:

• Court will hear motions to determine standard of review, whether discovery is permitted, and scope of administrative record. [Standing Order § 12.]
• Trial will be a court trial (usually confined to oral argument) on the administrative record. [Standing Order § 12.]
• Summary judgment is disfavored. If filing, must distinguish Kearney v. Standard Insurance Co., 175 F.3d 1084, 1095 (9th Cir. 1999) and explain why SJ is not precluded. [Standing Order § 12.]

Removed Cases:

• If a motion was pending in state court, it must be re-noticed per L.R. 7. [Standing Order § 9.]
• If the removed action contains a form pleading (boxes checked), the party must file a proper pleading within 30 days of the notice of removal. [Standing Order § 9.]

Fischer has a separate standing order governing summary judgment motions that adds significant requirements beyond the CDCA baseline.

Multiple MSJs highly disfavored: Multiple motions for summary adjudication by the same party are highly disfavored. Must move for leave of court and explain why issues cannot be addressed in a single motion. If filed without leave, the first motion will be considered and subsequent motions stricken. [SJ Order.]

SUF format — two-column:

• Left column: sequentially-numbered undisputed facts.
• Right column: supporting evidence.
• Each paragraph must contain a narrowly focused statement of fact addressing a single subject as concisely as possible. [SJ Order.]

SGD format — two-column:

• Left column: restate the movant's fact exactly as filed.
• Right column: state whether disputed or undisputed; if disputing, clearly indicate what part is disputed with evidence and a brief explanation.
• Must briefly state why the fact is disputed, cite the exhibit, and describe what refutes it.
• No legal argument in the SGD.
• Do not avoid admitting an undisputed fact by sidestepping the issue. Only good faith disputes. [SJ Order.]

All papers refer to numbered paragraphs in the separate statement, not underlying evidence. [SJ Order.]

Supporting evidence rules:

• Submit only specific items necessary to support or controvert a fact. Entire deposition transcripts, entire interrogatory responses, and non-specific documents will not be considered. [SJ Order.]
• When submitting portions of lengthy documents, provide all pages necessary for context. [SJ Order.]
• Evidence by stipulation or declarations — NOT attached to the memorandum. [SJ Order.]
• Refer to exhibits by number/title (e.g., 'Exhibit 1' or 'the License Agreement attached as Exhibit 1'), not merely by title alone. [SJ Order.]

Evidentiary objections:

• In a separate memorandum filed with the opposition or reply.
• Organized to track paragraph numbers of the separate statement in numerical sequence.
• Identify specific evidence, brief argument with citation to authority.
• No blanket or boilerplate objections — will be overruled and disregarded. [SJ Order.]

Premature motions: Clearly premature motions (e.g., claiming insufficient evidence when discovery closes in 6 months) only waste time. [SJ Order.]

Practical guidance: Fischer's SJ regime is detail-oriented. The two-column format is mandatory and the Court will not search beyond what is cited. Blanket objections are explicitly prohibited. Build your separate statement carefully — it is the backbone of the motion.

Fischer has a separate standing order governing attorneys' fee motions with detailed pre-filing requirements.

Pre-motion meet and confer required: In person or by videoconference per L.R. 7-3. Goal is to agree on fees without 'a second major litigation.' Hensley v. Eckerhart, 461 U.S. 424, 437 (1983). [Attorneys' Fees Order.]

4 pre-conference disclosures by moving party:

1. Billing records specifying entries for which compensation is/is not sought. May redact privileged material, but must submit declaration describing redacted services with sufficient detail for opposing counsel to evaluate.
2. Hourly rates for each lawyer, paralegal, or timekeeper. Must provide records showing rates paid (not charged) in this type of litigation. If relying on other evidence (comparable rates, prior awards), must provide it.
3. Actual cost of any nontaxable expenses.
4. Respond to any reasonable request for additional documentation.

[Attorneys' Fees Order.]

Joint Statement required if no agreement:

• Spreadsheet format (Excel, or table in Word/WordPerfect).
• 7 columns: (1) date, (2) biller, (3) task description, (4) hours requested, (5) hours opposing party believes should be awarded, (6) moving party's position on disputed items, (7) opposing party's position.
• Separate spreadsheet for nontaxable costs with 5 columns.
• Draft to opposing party at least 7 days before conference; final version no more than 14 days before filing; opposing party completes and returns at least 7 days before filing.

[Attorneys' Fees Order.]

Filing requirements:

• File Joint Statement with the motion.
• Email electronic version to chambers ECF inbox.
• Paper chambers copies of invoices should be unredacted (redacted copies should not be provided to Court).

All information treated as confidential by opposing counsel, used solely for fee litigation. [Attorneys' Fees Order.]

Consequences: Noncompliant submissions will not be considered. If the Court concludes counsel have not acted in good faith, it will refer to a special master at the parties' expense. [Attorneys' Fees Order.]

Documents will not be considered until paper chambers copies are submitted. Submit same-day if priority processing is requested. [Standing Order § 3c.]

What requires chambers copies: Initial pleadings (complaints, notices of removal, counterclaims, cross-claims, answers); Joint Rule 26(f) Reports; motion papers including motions in limine (motions, oppositions, replies, and related documents); ex parte applications for TROs; and all pretrial documents (memoranda of fact and law, witness/exhibit lists, pretrial conference statement, jury instructions, verdict forms). [Standing Order § 3c.]

Delivery requirements:

• Deadline: Noon on the first court day after filing. Same day if priority processing requested.
• Location: Fischer's mailbox outside Clerk's Office, 4th Floor, First Street Courthouse.
• Blue backs required with title of document on the lower right corner.
• No deliveries requiring a signature.
• Chambers copies should not require the signature of the recipient.

Binder requirements (critical):

• All exhibits must be separated by tab dividers (right or bottom).
• Over 50 pages: Must be in a separately tabbed binder with Table of Contents.
• Over 200 pages: Must be in a Slant D-Ring binder with Table of Contents, each exhibit separated by tab divider.
• Three-hole punched with oversized 13/32" holes (NOT the standard 9/32"). [Standing Order § 3c.]
• Consequence: Failure to comply may result in the Court striking the motion or declining to consider the exhibits.

Attachments: Each declaration, exhibit, or other attachment must be filed as a separately docketed attachment with a description (e.g., Dkt. 29-1 Smith Declaration, 29-2 Ex. 2 - License Agreement). [Standing Order § 3a.]

Trap for national counsel: The 13/32" hole punch requirement is unusual — standard three-hole punches use 9/32" holes. You need an oversized punch. Missing this, omitting blue backs, or failing to provide a binder for 50+ page exhibits will result in noncompliance with real consequences.

No AI certificate or AI-disclosure requirement. As of April 5, 2026, Judge Fischer's published procedures do not require any certification regarding the use of artificial intelligence in the preparation of filings.

No general filing-authenticity certificate beyond what is required by FRCP 11 (which applies to all federal filings).

Comparison: Some SDTX judges (e.g., Olvera) require a mandatory AI certificate filed with proposed scheduling orders. Fischer has no such requirement. This could change — monitor the court page for updates.

Date stamp: This component reflects Fischer's published procedures as of April 5, 2026.

CDCA pro hac vice admission costs $450 per case (General Order 25-05). Cannot appear PHV if you reside in California, are regularly employed in California, or regularly engaged in business in California. Local counsel must be a CDCA bar member with an office physically in the District. L.R. 83-2.1.3.

Attorney Admission Fees (GO 25-05)

Joint Rule 26(f) Report due 7 days before the scheduling conference (stricter than the typical 14-day default). Must be drafted and filed by plaintiff (unless plaintiff is non-lawyer pro per or parties agree otherwise), signed jointly as a single report regardless of number of parties. [Scheduling Order § 1.]

Chambers copies: Delivered to Fischer's box next to Clerk's Office, 4th Floor, First Street Courthouse. Must be blue-backed with title on lower right corner. Submitted by noon the day after e-filing. [Scheduling Order.]

17 required topics (a-t):

[Scheduling Order § 1.]

Key Fischer-specific rules:

• "Very unlikely" to agree to phased discovery. [Scheduling Order § 1(i).]
• Discovery cut-off = completion of discovery, not just service of requests. [Scheduling Order § 1(j).]
• Court is not likely to continue the motion cut-off date unless trial is also continued. [Scheduling Order § 1(q).]
• Motion cut-off = last date motions may be heard, not filed. [Scheduling Order § 1(q).]
• No more than 5 motions in limine per side without Court permission. [Schedule form.]

Pro per parties: Not exempt from any Local Rules including L.R. 16. "Counsel" includes parties appearing in propria persona. [Scheduling Order.]

CAVEAT: Failure to file the Joint Rule 26(f) Report or appear at the scheduling conference = dismissal (plaintiff) / default (defendant). [Scheduling Order Caveat.]