Judge R. Gary Klausner -- United States District Court, Central District of California

Courtroom 850, 8th Floor, Edward R. Roybal Federal Building and United States Courthouse, 255 East Temple Street, Los Angeles, CA 90012

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Key Traps — Where Counsel Gets Caught

1. Notice window is 28-35 days out (not just "at least 28") — notice filed earlier than 28 days or later than 35 days before hearing is non-compliant
2. Page/word limits BOTH apply and are cumulative: 20 pages AND 5,600 words for motions/oppositions — hit either cap and you're over
3. Footnotes, headings, and quotations ALL count toward the 5,600-word cap — no separate footnote allowance
4. Reply cap is 10 pages (tighter than default LR 11-6.1 practice)
5. Zero remote appearances: telephonic AND video appearances are NOT permitted — in-person or nothing
6. Motion date must be a Monday at 9:00 a.m. (civil) — different from most CACD judges who set civil at 1:30 p.m.
7. Ex parte: opposition due by 3:00 p.m. the first business day after service — not 24 hours
8. Sealing motion under a protective order is auto-DENIED unless the designating party files a separate L.R. 79-5.2.2(b)(i) declaration
9. Every motion, opposition, and ex parte MUST be accompanied by a proposed order with a brief rationale statement and citations — not just relief sought
10. Each supporting document must be filed as an INDIVIDUAL ECF attachment (not concatenated); PDFs must be searchable per L.R. 5-4.3.1

Quick Reference

Topic	Rule
Motion Days	SO 6: "this Court hears motions on Mondays commencing at 9:00 a.m. If Monday is a national holiday, this Court will hear motions on the succeeding Tuesday. If the date the motion was noticed for hearing is not available, the Court will issue a minute order resetting the date. Any opposition or reply papers due on a holiday are due the preceding Friday, not the following Tuesday." JPS: Civil = Mondays 9:00 a.m.; Criminal = Mondays 10:00 a.m. (or 1:30 p.m. upon court approval). Trials commence Tuesdays. [klausner-gary \| motion_hearing_days]
Motion Limit	SO 6: "Memoranda of Points and Authorities, pretrial briefs, trial briefs, and postrial briefs (including oppositions thereto) shall not exceed 20 pages, nor exceed 5,600 words, including headings, footnotes, and quotations... These page and word count limitations exclude the caption, table of contents, table of authorities, signature block, and certification required by Local Rule 11-6.2. Only in rare instances and for good cause shown will the Court agree to extend these limitations." [klausner-gary \| page_limits_motions]
Reply Limit	SO 6: "Replies shall not exceed 10 pages." Same word/page exclusions apply (caption, table of contents, table of authorities, signature block, and L.R. 11-6.2 certification). [klausner-gary \| page_limits_replies]
Chambers Copies	Conditional SO 16: "Chambers copies are not required at this time with exception of any copies specifically requested by the Court, any physical items... [klausner-gary \| chambers_copies_details]
Tentative Rulings	JPS: "Tentative rulings on motions are not issued." [klausner-gary \| tentative_rulings]
Remote Appearances	SO 10: "The Court does not permit appearances or arguments by way of telephone conference calls or remote video appearance." JPS: "Telephonic and video appearances are NOT permitted." [klausner-gary \| remote_appearances]
Discovery	SO 5: "All discovery matters have been referred to a United States Magistrate Judge to hear all discovery disputes. (The Magistrate Judge's initials follow the Judge's initials next to the case number.) All documents must include the words 'DISCOVERY MATTER' in the caption to ensure proper routing." JPS: "Discovery motions are to be calendared before the Magistrate Judge assigned." [klausner-gary \| discovery_referral]

Procedural Briefing by Motion Type

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Before You File

Motion Days & Times

SO 6: "this Court hears motions on Mondays commencing at 9:00 a.m. If Monday is a national holiday, this Court will hear motions on the succeeding Tuesday. If the date the motion was noticed for hearing is not available, the Court will issue a minute order resetting the date. Any opposition or reply papers due on a holiday are due the preceding Friday, not the following Tuesday." JPS: Civil = Mondays 9:00 a.m.; Criminal = Mondays 10:00 a.m. (or 1:30 p.m. upon court approval). Trials commence Tuesdays. [klausner-gary | motion_hearing_days]

Notice Period

SO 6: "Motions shall be filed and set for hearing in accordance with Local Rule 6-1, except: (1) the notice of motion shall be filed with the Clerk not earlier than twenty-eight (28) days, and no later than thirty-five (35) days, before the date set for hearing." JPS: "Movants shall set their motion hearing dates on the next Monday after the required 28 day notice period per local rules of Court." [klausner-gary | motion_notice_days]

Motion Page / Word Limit

SO 6: "Memoranda of Points and Authorities, pretrial briefs, trial briefs, and postrial briefs (including oppositions thereto) shall not exceed 20 pages, nor exceed 5,600 words, including headings, footnotes, and quotations... These page and word count limitations exclude the caption, table of contents, table of authorities, signature block, and certification required by Local Rule 11-6.2. Only in rare instances and for good cause shown will the Court agree to extend these limitations." [klausner-gary | page_limits_motions]

Opposition Limit

Reply Limit

SO 6: "Replies shall not exceed 10 pages." Same word/page exclusions apply (caption, table of contents, table of authorities, signature block, and L.R. 11-6.2 certification). [klausner-gary | page_limits_replies]

Font & Formatting

SO 6: "Pursuant to Local Rule 11-3.1.1, either a proportionally spaced or monospaced font may be used. A proportionally spaced font must be 14-point or larger, or as the Court may otherwise order. A monospaced font may not contain more than 10½ characters per inch." [klausner-gary | font_formatting]

Footnote Policy

SO 6 (page/word limits): "Memoranda of Points and Authorities, pretrial briefs, trial briefs, and postrial briefs (including oppositions thereto) shall not exceed 20 pages, nor exceed 5,600 words, including headings, footnotes, and quotations." Footnotes counted toward word/page limits but no separate footnote length limit. [klausner-gary | footnote_policy]

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At Filing

Chambers Copies

Conditional SO 16: "Chambers copies are not required at this time with exception of any copies specifically requested by the Court, any physical items including CD's or flash drives, and any sealed documents and criminal documents as set forth below. Any paper copy or physical item to be delivered to the Court shall be delivered to and placed in the Judge's courtesy box, located outside of the Clerk's office, on the 12th floor of the Roybal Federal Building, 255 East Temple Street, Los Angeles. Under seal copies together in manila envelope labeled 'UNDER SEAL.' Criminal: sentencing memoranda > 20 pages. Exhibits tabbed. Blue-backs not required." [klausner-gary | chambers_copies_details]

ECF Stamp Requirements

SO 6: "Motions, Oppositions, and Replies shall be electronically filed only. With the exception of physical exhibits, all documents supporting the motion, opposition, or reply (e.g., declarations, exhibits, statements of undisputed or disputed facts, judicial notices) shall also be electronically filed only, and filed as attachments to the corresponding brief. Furthermore, each supporting document shall be filed as an individual attachment, such that each document can be accessed by its own individual link. Each attachment shall be designated by the title of the document." SO 9: PDFs must be searchable per L.R. 5-4.3.1. [klausner-gary | ecf_stamp_requirements]

Proposed Orders

SO 8: "Each party filing or opposing a motion or seeking the determination of any matter (e.g., ex parte applications, stipulations, and general requests) shall electronically file 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." JPS Important Notice: "PROPOSED ORDERS in MSWord (.doc/x) or WordPerfect (.wpd) format must be sent to rgk_chambers@cacd.uscourts.gov" [klausner-gary | proposed_orders]

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Before the Hearing

Tentative Rulings

JPS: "Tentative rulings on motions are not issued." [klausner-gary | tentative_rulings]

Prohibition / Ex Parte Contact Re Tentatives

JPS: "Tentative rulings on motions are not issued." [klausner-gary | tentative_ruling_prohibition]

Oral Argument

JPS: "Tentative rulings on motions are not issued. Telephonic and video appearances are NOT permitted." SO 10: "The Court does not permit appearances or arguments by way of telephone conference calls or remote video appearance." [klausner-gary | oral_argument_default]

Remote Appearances

SO 10: "The Court does not permit appearances or arguments by way of telephone conference calls or remote video appearance." JPS: "Telephonic and video appearances are NOT permitted." [klausner-gary | remote_appearances]

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Background Rules

Chambers Contact

SO 13: "Counsel shall not attempt to contact the Court or its staff by telephone or by any other ex parte means. Counsel may contact the Courtroom Deputy Clerk with appropriate inquiries only. Counsel shall not contact the Courtroom Deputy regarding status of rulings on motions, ex parte applications or stipulations. Counsel shall not contact the Court to ask if a matter is going forward. Notice will be given if the matter is taken off calendar." JPS: Status of submitted motions/stipulations/proposed orders determined via PACER, not telephone. [klausner-gary | chambers_contact_restrictions]

Discovery Referral

SO 5: "All discovery matters have been referred to a United States Magistrate Judge to hear all discovery disputes. (The Magistrate Judge's initials follow the Judge's initials next to the case number.) All documents must include the words 'DISCOVERY MATTER' in the caption to ensure proper routing." JPS: "Discovery motions are to be calendared before the Magistrate Judge assigned." [klausner-gary | discovery_referral]

Discovery Motion Process

SO 5: "All discovery matters have been referred to a United States Magistrate Judge to hear all discovery disputes... All documents must include the words 'DISCOVERY MATTER' in the caption to ensure proper routing. Counsel are directed to contact the Magistrate Judge's Courtroom Deputy Clerk to schedule matters for hearing. Please do not deliver courtesy copies of these papers to this Court." Review motion must be filed within 10 days of service of a written ruling (or 10 days of an oral ruling that will not be followed by a written ruling). [klausner-gary | discovery_motion_process]

Ex Parte Applications

SO 11: "The Court considers ex parte applications on the papers and does not usually set these matters for hearing. If a hearing is necessary, the parties will be notified. Ex parte applications are solely for extraordinary relief and should be used with discretion. Sanctions may be imposed for misuse of ex parte applications. See Mission Power Engineering Co. v. Continental Casualty Co., 883 F.Supp. 488 (C.D. Cal. 1995)... The moving party shall serve the opposing party and shall notify the opposition that opposing papers must be filed not later than 3:00 p.m. on the first business day following service." [klausner-gary | ex_parte_notice]

Settlement Notification

Silent on settlement notification. [klausner-gary | settlement_notification]

Lead Counsel

SO 4: "The attorney attending any proceeding before this Court, including all status and settlement conferences, must be the lead trial counsel. However, with respect to Scheduling Conferences, any attorney of record who is authorized to request and accept scheduling dates may appear in lieu of the lead trial counsel." [klausner-gary | lead_counsel_requirement]

Under Seal Filings

SO 17: "For detailed instructions... please refer to Local Rule 79-5. With regard to Under-seal Documents in Non-sealed Civil Cases (L.R. 79-5.2.2), the filing party shall not provide a chambers or courtesy copy of the Application or any associated documents. All applications must (1) indicate which portions... are confidential; and (2) provide reasons(s) as to why the parties' interest... outweighs the public's right to access. If a party submits an application to file under seal pursuant to a protective order only... the Court will automatically deny the application if the party designating the material as confidential does not file a declaration pursuant to L.R. 79-5.2.2(b)(i)." [klausner-gary | under_seal_requirements]

Continuances & Calendar Conflicts

SO 12: "This Court has a strong interest in keeping scheduled dates certain. Changes in dates are disfavored. Trial dates set by the Court are firm and will rarely be changed. Therefore, a stipulation to continue the date of any matter before this Court must be supported by a sufficient basis that demonstrates good cause why the change in the date is essential... Counsel requesting a continuance must file a stipulation and lodge a proposed order including a detailed declaration of the grounds for the requested continuance." JPS: If counsel has a CACD calendar conflict, "counsel shall immediately notify the Courtroom Deputy Clerk by email in advance of the hearing date." [klausner-gary | continuances_calendar_conflicts]

Sources & Currency

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