Judge Stanley Blumenfeld Jr. -- United States District Court, Central District of California

Courtroom 6C, 6th Floor, Felicitas and Gonzalo Mendez U.S. Courthouse, Los Angeles

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Key Traps — Where Counsel Gets Caught

1. Word limits apply (7,000/7,000/4,000), NOT the 25/25/15 page limits used by most CACD judges — memo may be stricken if exceeded
2. Footnote cap: max 8 in opening/opposition, max 5 in reply — citations belong in main text, not footnotes
3. Tentative rulings issued day before hearing by 6:00 p.m., but parties are STRICTLY PROHIBITED from filing tentative as an exhibit or otherwise in any case
4. Generative AI disclosure required — separate declaration certifying reviewer verified accuracy and Rule 11 compliance
5. Ex parte opposition due 48 hours after service OR 3:00 p.m. first court day after service, WHICHEVER IS LATER
6. Remote appearances NOT permitted absent good cause shown by declaration filed concurrently with motion/opposition — day-of requests too late
7. Chambers copies required (motions, ex parte TROs, pretrial); >50 pages needs table of contents AND tabbed three-ring binder with spine label
8. Continuance requires SPECIFIC diligence showing: prior work done, remaining work, why not done sooner, why time requested is needed — conclusory declarations denied
9. Belated settlement notice sanctionable; notify Court at least 2 weeks before hearing if settlement discussions may moot the motion
10. Font: only 14-pt Times New Roman including footnotes; footnotes separated by 12-pt spacing

Quick Reference

Topic	Rule
Motion Days	6. General Motion Requirements. b. Time for Filing and Hearing Motions. This Court hears civil motions on Fridays at 8:30 a.m. i. Holidays. If Friday is a court holiday, select another Friday. Opposition or reply papers due on a Friday holiday may be filed the following Monday. ii. Closed Dates. Hearing dates are closed at least four weeks in advance, and closed hearing dates are noted on Judge Blumenfeld's webpage. A motion filed on a closed hearing date will be stricken or continued at the Court's discretion. A party that waits too long and files a motion to be heard on a date that turns out to be unavailable risks having the motion stricken and not considered at all. [Judge Blumenfeld Standing Order]
Motion Limit	6. General Motion Requirements. c. Length, Footnotes, and Format of Motion Papers. i. Length. Unless otherwise expressly permitted, no supporting or opposing memorandum shall exceed 7,000 words (or 25 pages, double spaced, if handwritten), and no reply memorandum shall exceed 4,000 words (or 15 pages, double spaced, if handwritten) — excluding only indices and exhibits. Counsel shall certify compliance with the word count pursuant to Local Rule 11-6.2. Good cause to extend these limitations will rarely be found. A memorandum that exceeds the allowable length may be stricken. [Judge Blumenfeld Standing Order]
Reply Limit	6. General Motion Requirements. c. Length, Footnotes, and Format of Motion Papers. i. Length. No reply memorandum shall exceed 4,000 words (or 15 pages, double spaced, if handwritten). [Judge Blumenfeld Standing Order]
Chambers Copies	Conditional 5. Filing Requirements. e. Chambers Copies. i. Timeliness and location. Deliver chambers copies promptly to Judge Blumenfeld's mailbox... [Judge Blumenfeld Standing Order]
Tentative Rulings	8. Motion Hearings. d. Tentatives. The Court often issues written tentative rulings and makes them available on Judge Blumenfeld's webpage the afternoon before the hearing by 6:00 p.m. The purpose of the tentative ruling is to focus the discussion at the hearing. [Judge Blumenfeld Standing Order]
Remote Appearances	8. Motion Hearings. a. Remote Appearances. Remote appearances are not permitted absent good cause shown in a declaration concurrently filed with the moving papers or the opposition. Absent a concurrent filing, a party requesting to appear remotely must submit a declaration establishing that the party is unable to appear in person due to an unanticipated and unavoidable emergency and that the request was made promptly upon learning of the emergency. Instructions for remote appearance can be found on Judge Blumenfeld's webpage. Counsel appearing remotely are responsible for ensuring that their equipment and the internet connection in the location from which they will be participating are reliable and adequate for uninterrupted video participation. [Judge Blumenfeld Standing Order]
Discovery	4. Discovery. a. Magistrate Judge Referral. All discovery matters are referred to the assigned magistrate judge. All discovery documents must include the words "DISCOVERY MATTER" in the caption to ensure proper routing. Do not deliver chambers copies of these documents to Judge Blumenfeld. [Judge Blumenfeld Standing Order]

Procedural Briefing by Motion Type

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Before You File

Motion Days & Times

6. General Motion Requirements. b. Time for Filing and Hearing Motions. This Court hears civil motions on Fridays at 8:30 a.m. i. Holidays. If Friday is a court holiday, select another Friday. Opposition or reply papers due on a Friday holiday may be filed the following Monday. ii. Closed Dates. Hearing dates are closed at least four weeks in advance, and closed hearing dates are noted on Judge Blumenfeld's webpage. A motion filed on a closed hearing date will be stricken or continued at the Court's discretion. A party that waits too long and files a motion to be heard on a date that turns out to be unavailable risks having the motion stricken and not considered at all. [Judge Blumenfeld Standing Order]

Notice Period

Silent on motion notice days. [Judge Blumenfeld Standing Order]

Motion Page / Word Limit

6. General Motion Requirements. c. Length, Footnotes, and Format of Motion Papers. i. Length. Unless otherwise expressly permitted, no supporting or opposing memorandum shall exceed 7,000 words (or 25 pages, double spaced, if handwritten), and no reply memorandum shall exceed 4,000 words (or 15 pages, double spaced, if handwritten) — excluding only indices and exhibits. Counsel shall certify compliance with the word count pursuant to Local Rule 11-6.2. Good cause to extend these limitations will rarely be found. A memorandum that exceeds the allowable length may be stricken. [Judge Blumenfeld Standing Order]

Opposition Limit

Reply Limit

6. General Motion Requirements. c. Length, Footnotes, and Format of Motion Papers. i. Length. No reply memorandum shall exceed 4,000 words (or 15 pages, double spaced, if handwritten). [Judge Blumenfeld Standing Order]

Font & Formatting

6. General Motion Requirements. c. Length, Footnotes, and Format of Motion Papers. iv. Format. Use only 14-point Times New Roman font, including for footnotes. Footnotes shall be separated by 12-point spacing. [Judge Blumenfeld Standing Order]

Footnote Policy

6. General Motion Requirements. c. Length, Footnotes, and Format of Motion Papers. ii. Footnotes. Use no more than eight footnotes in any supporting or opposing brief, and no more than five footnotes in any reply. Citations that support a statement in the main text should be included in the main text, not in footnotes. [Judge Blumenfeld Standing Order]

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At Filing

Chambers Copies

Conditional 5. Filing Requirements. e. Chambers Copies. i. Timeliness and location. Deliver chambers copies promptly to Judge Blumenfeld's mailbox outside the Clerk's Office on the fourth floor of the First Street Courthouse. Applicable documents will not be considered until chambers copies are submitted. ii. Format. Chambers copies should be copies of the filed document — i.e., they should have the docket information on the top of each page. Filings that include highlighting, color photographs, "redlining," or the like should be printed in color. Short filings should be fastened by a staple or binder clip in the top left corner. Larger filings should be delivered in a three-ring binder. Binders must have both a cover sheet and a spine label that includes the case name, case number, and a description of the contents. iii. Exhibits. Separate all exhibits by a tab divider on the right or bottom of the document. If the evidence exceeds 50 pages, the chambers copy must: (1) include a table of contents; and (2) be in a tabbed three-ring binder with each exhibit separated by a tab divider on the right or the bottom. [Judge Blumenfeld Standing Order]

Proposed Orders

5. Filing Requirements. d. Proposed Orders. Each party filing a motion or seeking the determination of any matter shall serve and lodge a proposed order setting forth the relief or action sought and a brief statement of the rationale for the decision with appropriate citations. i. Templates. Use the "Proposed Order" or the "CMO Continuance Order" template — whichever is applicable — found on the "Orders and Additional Documents" tab on Judge Blumenfeld's webpage. Failure to do so may result in the striking of the request. Proposed orders should not contain: (1) attorney names, addresses, etc. on the caption page; (2) a footer with the document name or other information; or (3) a watermark or designation of the firm name. Proposed orders should be formatted in the same fashion as motions. See § 6(c)(iv), infra. ii. Email. Consistent with Local Rule 5-4.4.2, the Court strictly requires that a Microsoft Word copy of a proposed order, along with a PDF copy of the electronically filed main document, be e-mailed to the chambers e-mail address. The Court will not consider a stipulation, ex parte application, or other request for relief until a compliant proposed order is received by email. A filing may be stricken for failure to timely comply. [Judge Blumenfeld Standing Order]

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Before the Hearing

Tentative Rulings

8. Motion Hearings. d. Tentatives. The Court often issues written tentative rulings and makes them available on Judge Blumenfeld's webpage the afternoon before the hearing by 6:00 p.m. The purpose of the tentative ruling is to focus the discussion at the hearing. [Judge Blumenfeld Standing Order]

Prohibition / Ex Parte Contact Re Tentatives

8. Motion Hearings. d. Tentatives. No party shall file any written response to the tentative ruling without leave of court. A tentative ruling does not represent the final decision of the Court, and the parties are strictly prohibited from filing it as an exhibit or otherwise in any case. [Judge Blumenfeld Standing Order]

Oral Argument

8. Motion Hearings. b. Submission without Argument. The Court may take a motion off calendar if it concludes the decision will not benefit from oral argument. [Judge Blumenfeld Standing Order]

Remote Appearances

8. Motion Hearings. a. Remote Appearances. Remote appearances are not permitted absent good cause shown in a declaration concurrently filed with the moving papers or the opposition. Absent a concurrent filing, a party requesting to appear remotely must submit a declaration establishing that the party is unable to appear in person due to an unanticipated and unavoidable emergency and that the request was made promptly upon learning of the emergency. Instructions for remote appearance can be found on Judge Blumenfeld's webpage. Counsel appearing remotely are responsible for ensuring that their equipment and the internet connection in the location from which they will be participating are reliable and adequate for uninterrupted video participation. [Judge Blumenfeld Standing Order]

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Background Rules

Chambers Contact

2. Communications with Chambers. Counsel shall not contact the courtroom deputy clerk (CRD) to inquire about (1) the status of a pending matter or (2) court procedure addressed in the Local Rules and the Court's standing orders. Any appropriate inquiry directed to the CRD must be by email only, copied to all parties. Email requests for relief that should be filed on the docket—e.g., a request for a remote appearance or continuance—will generally be ignored and will not excuse noncompliance with any applicable rule or order. [Judge Blumenfeld Standing Order]

Discovery Referral

4. Discovery. a. Magistrate Judge Referral. All discovery matters are referred to the assigned magistrate judge. All discovery documents must include the words "DISCOVERY MATTER" in the caption to ensure proper routing. Do not deliver chambers copies of these documents to Judge Blumenfeld. [Judge Blumenfeld Standing Order]

Discovery Motion Process

4. Discovery. a. Magistrate Judge Referral. The decision of the magistrate judge shall be final, subject to limited review requiring a showing that the decision is clearly erroneous or contrary to law. Any party may file and serve a motion for review within 14 days of either (i) service of a written ruling or (ii) an oral ruling that expressly will not be followed by a written ruling. The motion must specify which portions of the ruling are clearly erroneous or contrary to law, supported by points and authorities. [Judge Blumenfeld Standing Order]

Ex Parte Applications

9. Ex Parte Applications. A party seeking ex parte relief, including a temporary restraining order, must comply fully with Local Rule 7-19. a. Notice. The applicant must (1) notify the other party (or parties) that opposing papers are to be filed no later than 48 hours following service or by 3:00 p.m. on the first court day after the service, whichever is later, and (2) advise the Court in a declaration whether any party opposes the application. [Judge Blumenfeld Standing Order]

Settlement Notification

1. Counsel. d. Duty to Notify of Settlement. Counsel must advise the Court immediately if (1) the case or any pending matter has been resolved or (2) a motion is pending and the parties are engaged in serious negotiations that appear likely to resolve the case or the pending motion (as discussed in more detail in § 8(f), infra). Failure to provide timely notice of settlement may result in sanctions. The filing of a settlement notice does not excuse counsel from appearing at any scheduled hearing or conference that has not been vacated. 8. Motion Hearings. f. Settlement. Counsel must notify the Court at least two weeks before the scheduled hearing if the parties are conducting settlement discussions that may render the motion moot and must notify the Court immediately if a settlement is reached. A belated settlement notice wastes scarce judicial resources and will subject the offending parties to sanctions — and it may also result in the release of the tentative ruling. [Judge Blumenfeld Standing Order]

Lead Counsel

1. Counsel. b. Presence of Lead Counsel. Only one attorney for a party may be designated as lead counsel—and the designation must appear on the docket if a party has more than one attorney. Lead counsel must attend all proceedings other than motion hearings. For motion hearings, lead counsel is encouraged to permit junior lawyers to participate. Only one counsel may be designated to argue a motion absent Court approval. [Judge Blumenfeld Standing Order]

Under Seal Filings

7. Specific Motion Requirements. g. Applications to Seal. If the Court has previously granted leave to seal a particular exhibit, the parties need not file a new application to file that exhibit under seal in connection with a new filing. The parties may simply file the exhibit under seal together with a statement that the Court has already permitted sealing of the exhibit, with a citation to the relevant order. [Judge Blumenfeld Standing Order]

Continuances & Calendar Conflicts

10. Continuances. The Court grants continuances of pretrial and trial deadlines only on a timely showing of good cause. The Court applies the same standard of good cause to all extension requests — whether opposed, unopposed, or jointly requested. a. Good Cause. Good cause requires a specific, detailed, and non-conclusory showing of diligence from the outset of the case, describing: (1) all relevant work previously done (including when each item was completed), (2) all relevant work that remains to be done, (3) why the remaining work could not previously have been done (including efforts made to complete each remaining item), and (4) why the amount of time requested is needed to complete the remaining work. [Judge Blumenfeld Standing Order]

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AI & Style Preferences

AI Disclosure Requirement

5. Filing Requirements. c. Artificial Intelligence. Any party who uses generative artificial intelligence (such as ChatGPT, Harvey, CoCounsel, or Google Bard) to generate any portion of a brief, pleading, or other filing must attach to the filing a separate declaration disclosing the use of artificial intelligence and certifying that the filer has reviewed the source material and verified that the artificially generated content is accurate and complies with the filer's Rule 11 obligations.

Sources & Currency

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