Judge Maame Ewusi-Mensah Frimpong -- United States District Court, Central District of California

Courtroom 8B, 8th Floor, First Street Courthouse, Los Angeles

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Key Traps — Where Counsel Gets Caught

1. MODIFIED briefing schedule DIFFERS from L.R. 7-9/7-10: Motion filed 42 days before hearing; Opposition due 14 days after motion; Reply due 7 days after opposition
2. If hearing continued, briefing deadlines DO NOT change — defaults remain even after continuance
3. MSJ SoUF/Genuine Disputes must be submitted in EXCEL (restrictions removed for editing) emailed to MEMF_Chambers@cacd.uscourts.gov — not just PDF
4. Font minimum is 12-point Times New Roman (10-point footnotes) — LOWER than the 14-point most CACD judges require
5. Civil motions heard Thursdays 10:00 a.m. — specific hearing times assigned prior to Thursday
6. NO chambers copies except for MSJ (one courtesy copy, prefers binders with exhibit tabs); do not send unrequested paper
7. Scheduling conferences default to IN PERSON — Zoom requires e-filed request by the Friday before, with L.R. 7-3 meet-and-confer statement
8. Zoom requests for motion hearings must be e-filed by Friday before hearing with L.R. 7-3 meet-and-confer certification
9. Proposed order template MUST be used — failure to submit Word-format proposed order may result in motion/application/stipulation being stricken without merits consideration
10. Table of Contents AND Table of Authorities required for any Memorandum exceeding 10 pages (per L.R. 11-8)

Quick Reference

Topic	Rule
Motion Days	Time for Filing and Hearing Motions: Motions shall be filed in accordance with Local Rule 7. This Court hears civil motions on Thursdays, beginning at 10:00 a.m. While all hearings are set for Thursdays initially at 10:00 a.m., the Court will assign specific hearing times prior to the Thursday of the hearing. If Thursday is a national holiday, motions will be heard on the next Thursday. [frimpong-maame \| motion_hearing_days]
Motion Limit	Length and Format of Motion Papers: With the exception of Rule 56 Motions which have specific requirements as set forth in Section IX.D, absent leave of Court, Memoranda of Points and Authorities in support of or in opposition to motions must comply with the limitations set forth by Local Rule 11-6. Only in rare instances and for good cause shown will the Court grant an application to extend these limitations. Pursuant to Local Rule 11-8, all Memoranda of Points and Authorities exceeding ten (10) pages must be accompanied by a Table of Authorities and a Table of Contents. [frimpong-maame \| page_limits_motions]
Reply Limit	Length and Format of Motion Papers: With the exception of Rule 56 Motions which have specific requirements as set forth in Section IX.D, absent leave of Court, Memoranda of Points and Authorities in support of or in opposition to motions must comply with the limitations set forth by Local Rule 11-6. Only in rare instances and for good cause shown will the Court grant an application to extend these limitations. [frimpong-maame \| page_limits_replies]
Chambers Copies	Conditional Chambers Courtesy Copies: The Court does not require chambers copies of any motion papers or exhibits and discourages the parties from... [frimpong-maame \| chambers_copies_details]
Tentative Rulings	Silent on tentative rulings. Not applicable: federal court does not issue tentative rulings. [frimpong-maame \| tentative_rulings]
Remote Appearances	By default, all scheduling conferences shall proceed in-person, unless a request is made by the parties and granted by the Court. Requests to appear via Zoom must be e-filed by the Friday before the conference and must indicate that counsel has met and conferred per Local Rule 7-3. [frimpong-maame \| remote_appearances]
Discovery	Discovery: All discovery matters have been referred to a magistrate judge, who will hear all discovery disputes. The magistrate judge's initials follow the district judge's initials next to the case number. All discovery documents must include the words "DISCOVERY MATTER" in the caption to ensure proper routing. Please do not deliver courtesy copies of discovery documents to Judge Frimpong's chambers. [frimpong-maame \| discovery_referral]

Procedural Briefing by Motion Type

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Before You File

Motion Days & Times

Time for Filing and Hearing Motions: Motions shall be filed in accordance with Local Rule 7. This Court hears civil motions on Thursdays, beginning at 10:00 a.m. While all hearings are set for Thursdays initially at 10:00 a.m., the Court will assign specific hearing times prior to the Thursday of the hearing. If Thursday is a national holiday, motions will be heard on the next Thursday. [frimpong-maame | motion_hearing_days]

Notice Period

All Motions must be filed in accordance with the following modified briefing schedule, which differs from the timing of the Local Rules: Motion: Must be filed no later than forty-two (42) days prior to the hearing date on the Motion; Opposition: Must be filed no later than fourteen (14) days after the filing of the initial Motion; Reply: Must be filed no later than seven (7) days after the Opposition. If at any time the hearing date on a motion is continued, there is no change to the default briefing schedule set forth above. [frimpong-maame | motion_notice_days]

Motion Page / Word Limit

Length and Format of Motion Papers: With the exception of Rule 56 Motions which have specific requirements as set forth in Section IX.D, absent leave of Court, Memoranda of Points and Authorities in support of or in opposition to motions must comply with the limitations set forth by Local Rule 11-6. Only in rare instances and for good cause shown will the Court grant an application to extend these limitations. Pursuant to Local Rule 11-8, all Memoranda of Points and Authorities exceeding ten (10) pages must be accompanied by a Table of Authorities and a Table of Contents. [frimpong-maame | page_limits_motions]

Opposition Limit

Reply Limit

Font & Formatting

Length and Format of Motion Papers: All briefing must use Times New Roman font. Text must be no less than twelve (12) point font; footnotes shall be no less than ten (10) point font. Counsel shall adhere to Local Rule 5-4.3 with respect to the conversion of all documents to .pdf format so that when a document is electronically filed, it is in proper size and is .pdf searchable. Further, all documents shall be filed in a format so that text can be selected, copied, and pasted directly from the document. [frimpong-maame | font_formatting]

Footnote Policy

Length and Format of Motion Papers: All briefing must use Times New Roman font. Text must be no less than twelve (12) point font; footnotes shall be no less than ten (10) point font. [frimpong-maame | footnote_policy]

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At Filing

Chambers Copies

Conditional Chambers Courtesy Copies: The Court does not require chambers copies of any motion papers or exhibits and discourages the parties from sending chambers courtesy copies, with the exception of documents related to motions for summary judgment (see supra Section IX.D). The Court only requires one courtesy copy of motions for summary judgment and prefers binders with exhibit tabs for larger filings. Parties are required to submit any Statements of Uncontroverted Facts and Genuine Disputes in Excel, have all restrictions removed so the spreadsheets can be edited, and be emailed to the Court's chambers email address at MEMF_Chambers@cacd.uscourts.gov. [frimpong-maame | chambers_copies_details]

ECF Stamp Requirements

Electronic Filings: Counsel shall e-file all filings pursuant to Federal Rules of Civil Procedure 5(d)(3) and Local Rule 5-4 as follows: All non-signature items shall be e-filed in PDF format. All proposed signature items shall be e-filed as an attachment to the main document in PDF format. All proposed signature items shall be emailed to the courtroom deputy email address at MEMF_Chambers@cacd.uscourts.gov in Microsoft Word format. Only proposed order signature items should be emailed to the chambers' email address. Do not email other associated documents and do not use this email address for communication with the Court or the Clerk. [frimpong-maame | ecf_stamp_requirements]

Proposed Orders

Proposed Orders: Each party filing or opposing a motion or seeking the determination of any matter shall serve and electronically lodge a proposed order setting forth the relief or action sought and a brief statement of the rationale for the decision with appropriate citations. In addition, a copy of the proposed order in Microsoft Word format shall be emailed directly to the Court's chambers email address at MEMF_Chambers@cacd.uscourts.gov on the day the document is electronically filed. All emails to chambers should include the case name and number in the subject line. A proposed order template is available on the bottom of Judge Frimpong's webpage. The parties must use this template. Failure to submit a proposed order in Word format may result in the Court striking the motion, application, or stipulation without consideration of the request on its merits. [frimpong-maame | proposed_orders]

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Before the Hearing

Tentative Rulings

Silent on tentative rulings. Not applicable: federal court does not issue tentative rulings. [frimpong-maame | tentative_rulings]

Prohibition / Ex Parte Contact Re Tentatives

Silent on tentative ruling prohibition. Not applicable: federal court does not issue tentative rulings. [frimpong-maame | tentative_ruling_prohibition]

Oral Argument

Oral Argument: Per the Court's website, "Requests for a remote Zoom appearance must be e-filed by the Friday before the hearing and must indicate that counsel has met and conferred with opposing counsel consistent with Local Rule 7-3." If the Court deems a matter appropriate for decision without oral argument, the Court will take the matter under submission and notify the parties before the hearing. [frimpong-maame | oral_argument_default]

Remote Appearances

By default, all scheduling conferences shall proceed in-person, unless a request is made by the parties and granted by the Court. Requests to appear via Zoom must be e-filed by the Friday before the conference and must indicate that counsel has met and conferred per Local Rule 7-3. [frimpong-maame | remote_appearances]

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Background Rules

Chambers Contact

Communications with Chambers: Counsel must not attempt to contact the Court or chambers staff by email, telephone, or by any other ex parte means. Counsel may, for appropriate matters only, contact the Courtroom Deputy via the Court's chambers email at MEMF_Chambers@cacd.uscourts.gov. Any communication with chambers should be directed to this email address. All emails to chambers should include the case name and number in the subject line. Counsel must not contact the Courtroom Deputy regarding the status of any matter before the Court. Calls or emails regarding the status of submitted motions, stipulations, or proposed orders will not be returned. [frimpong-maame | chambers_contact_restrictions]

Discovery Referral

Discovery Motion Process

Discovery: All discovery matters have been referred to a magistrate judge, who will hear all discovery disputes. The magistrate judge's initials follow the district judge's initials next to the case number. All discovery documents must include the words "DISCOVERY MATTER" in the caption to ensure proper routing. Please do not deliver courtesy copies of discovery documents to Judge Frimpong's chambers. In accordance with 28 U.S.C. § 636(b)(1)(A), the magistrate judge's decision shall be final, and this Court will not reverse any order of the magistrate judge unless it has been shown that the magistrate judge's order is clearly erroneous and contrary to law. [frimpong-maame | discovery_motion_process]

Ex Parte Applications

Ex Parte Applications: Counsel are reminded that ex parte applications are solely for extraordinary relief. Applications that do not meet the requirements set forth in Local Rule 7-19 will not be considered. Sanctions may be imposed for misuse of ex parte applications. The parties may request a hearing along with a hearing date in the briefing. However, by default there will be no hearings on ex parte applications unless the Court sets one. [frimpong-maame | ex_parte_notice]

Settlement Notification

Silent on settlement notification. [frimpong-maame | settlement_notification]

Lead Counsel

Presence of Lead Trial Counsel: Lead trial counsel shall attend any proceeding before this Court, including all Scheduling, Pretrial, and Settlement Conferences. [frimpong-maame | lead_counsel_requirement]

Under Seal Filings

Under Seal Filings: The Court requires strict compliance with Local Rule 79-5, which governs applications to file documents under seal. Local Rule 79-5.2.2 explains how to apply to file under seal and how to proceed if leave is granted. There is a strong presumption of access in civil actions. Parties that submit frivolous motions to seal or overly broad motions will be subject to sanction. When submitting a motion to seal, the filing party must state whether the compelling reasons or good cause standard applies and explain why. [frimpong-maame | under_seal_requirements]

Continuances & Calendar Conflicts

Continuances: Counsel requesting a continuance must lodge, prior to the date to be continued, a proposed stipulation and order including a detailed declaration of the grounds for the requested continuance or extension of time. The Court grants continuances only upon a showing of good cause, focusing on the diligence of the party seeking the continuance and any prejudice that may result if the continuance is denied. Counsel are required to first meet and confer with opposing counsel regarding the substance of the continuance and include a statement of compliance with Local Rule 7-3. Failure to meet and confer in good faith in compliance with the Local Rules and this Order may result in denial of the request for continuance. [frimpong-maame | continuances_calendar_conflicts]

Sources & Currency

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