Magistrate Judge Alka Sagar -- United States District Court, Central District of California

Courtroom 540, 5th Floor, Edward R. Roybal Federal Building and United States Courthouse, Los Angeles

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Key Traps — Where Counsel Gets Caught

1. Any use of generative AI (ChatGPT, Harvey, CoCounsel, Bard) in any filing requires a separate declaration disclosing use, verifying accuracy, and certifying Rule 11 compliance.
2. Boilerplate objections to interrogatories/RFPs are summarily rejected or DEEMED WAIVED; using 'disproportionality' as a synonym for boilerplate is treated the same.
3. Two attempts to resolve the dispute (not one) are required before parties may request an Informal Discovery Conference.
4. IDC request goes to AS_Chambers@cacd.uscourts.gov via the completed 'Request for Informal Discovery Conference' form — no ad hoc emails.
5. IDC request must include 3 proposed dates, a 1-2 paragraph neutral dispute statement, and BOTH meet-and-confer dates — position summaries capped at 5 pages per party.
6. IDC letter briefs capped at 5 pages per party with attachments limited to 25 pages per party — a hard cap most magistrates don't specify.
7. Discovery motions expected to exceed 50 pages must present the challenged discovery in an APPENDIX immediately behind the joint brief.
8. Remote appearance requests must be filed in writing at least 5 court days before hearing; telephonic appearances not allowed absent good-cause showing.
9. Video appearances require formal court attire and a professional/quiet setting — no vehicles, events, outdoors, or speakerphones; noncompliance may terminate the hearing.
10. Chambers copies required ONLY if the filing exceeds 25 pages, delivered by 12:00 noon the following business day to the drop box outside suite 1200 — miss it and the motion may go off calendar.
11. Chambers copies must be printed from CM/ECF (not attorney work copies); stipulated protective orders require an emailed Word version PLUS a redline against the model order.
12. Settlement conferences scheduled by contacting the CRD at least 4 weeks in advance; conferences typically set for Tuesdays/Thursdays at 10 a.m.
13. Civil motions heard Tuesdays and Thursdays at 10 a.m.; LR 7-3 meet-and-confer must occur at least 7 days before filing.
14. Ex parte applications must identify OPPOSED or UNOPPOSED in the caption; opposition due within 24 hours; conformed paper copies delivered to Judge Sagar's drop box outside suite 1200.

Quick Reference

Topic	Rule
Motion Days	Civil Motions: Unless otherwise directed by the Court, civil motions shall be heard on Tuesdays and Thursdays at 10:00 a.m. It is not necessary to clear a civil motion hearing date with the Court prior to filing a motion; however, counsel shall check the Closed Motion Dates before filing a motion. The Court may continue a motion sua sponte or take a motion under submission without oral argument. See Local Civil Rule 7-15. The parties are reminded of their obligation under Local Civil Rule 7-3, if applicable, to meet and confer about the subject of a motion at least 7 days before filing. [Judge Sagar Procedures Page]
Motion Limit	Discovery Motions: The Court recognizes that Local Civil Rule 37-2.1 exempts discovery motions from the 25-page limit. For any motion that the parties reasonably believe will exceed 50 pages, they should present the challenged discovery in an appendix attached immediately behind their joint brief. Informal Discovery Conference letter briefs: no more than 5 pages per party. Attachments: limited to no more than 25 pages per party. [Judge Sagar Procedures Page]
Chambers Copies	Conditional EFFECTIVE JANUARY 1, 2023: No paper courtesy copies of documents in civil cases are required unless the filing is over 25 pages. Such... [Judge Sagar Procedures Page]
Remote Appearances	Court Appearances by Counsel: Unless otherwise ordered, counsel of record must appear in person for all court proceedings. Counsel wishing to request a remote appearance in civil cases must file a request in writing by no later than five court days before the noticed hearing date. Telephonic Appearances: Not allowed absent permission of the Court given on showing of good cause. Video Appearances: Formal court attire is required. Parties must participate from a professional setting or a quiet location, not from vehicles, events, or outdoors. Parties may not use speakerphones; headsets are preferred. Failure to comply may result in immediate termination of the hearing. [Judge Sagar Procedures Page]

Procedural Briefing by Motion Type

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Before You File

Motion Days & Times

Civil Motions: Unless otherwise directed by the Court, civil motions shall be heard on Tuesdays and Thursdays at 10:00 a.m. It is not necessary to clear a civil motion hearing date with the Court prior to filing a motion; however, counsel shall check the Closed Motion Dates before filing a motion. The Court may continue a motion sua sponte or take a motion under submission without oral argument. See Local Civil Rule 7-15. The parties are reminded of their obligation under Local Civil Rule 7-3, if applicable, to meet and confer about the subject of a motion at least 7 days before filing. [Judge Sagar Procedures Page]

Motion Page / Word Limit

Discovery Motions: The Court recognizes that Local Civil Rule 37-2.1 exempts discovery motions from the 25-page limit. For any motion that the parties reasonably believe will exceed 50 pages, they should present the challenged discovery in an appendix attached immediately behind their joint brief. Informal Discovery Conference letter briefs: no more than 5 pages per party. Attachments: limited to no more than 25 pages per party. [Judge Sagar Procedures Page]

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At Filing

Chambers Copies

Conditional EFFECTIVE JANUARY 1, 2023: No paper courtesy copies of documents in civil cases are required unless the filing is over 25 pages. Such courtesy copies are to be delivered to Judge Sagar's drop box outside suite 1200 (12th floor) - Roybal Clerk's Office no later than 12:00 noon on the following business day. Copies must be printed from CM/ECF. Failure to deliver timely mandatory chambers copies may result in a delay in hearing a motion or ordering the matter off calendar. Electronic copies of proposed orders (in Microsoft Word format) must be e-mailed to AS_Chambers@cacd.uscourts.gov. [Judge Sagar Procedures Page]

Proposed Orders

Proposed Orders: Pursuant to Local Civil Rule 5-4.4 and Local Criminal Rule 49-1.3.2(c), unless exempted from electronic filing, parties submitting proposed orders or other proposed documents that require the Court's signature must e-mail a word-processing version of the document to AS_Chambers@cacd.uscourts.gov. Proposed Orders must be on pleading paper and should not contain attorney names, addresses, etc. on the caption page, should not contain a footer with the document name or other information, and should not contain a watermark designation of the firm name, etc. in the margin. [Judge Sagar Procedures Page]

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Before the Hearing

Remote Appearances

Court Appearances by Counsel: Unless otherwise ordered, counsel of record must appear in person for all court proceedings. Counsel wishing to request a remote appearance in civil cases must file a request in writing by no later than five court days before the noticed hearing date. Telephonic Appearances: Not allowed absent permission of the Court given on showing of good cause. Video Appearances: Formal court attire is required. Parties must participate from a professional setting or a quiet location, not from vehicles, events, or outdoors. Parties may not use speakerphones; headsets are preferred. Failure to comply may result in immediate termination of the hearing. [Judge Sagar Procedures Page]

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Background Rules

Chambers Contact

Attorneys or parties to any action or proceeding shall refrain from writing letters to the judge, sending e-mail messages to the judge, making telephone calls to chambers, or otherwise communicating with a judge in a pending matter unless opposing counsel is present. All matters must be called to a judge's attention by appropriate application or motion filed in compliance with the Local Rules. General Procedures 1: The parties are not allowed to contact or communicate with the judge or law clerks in any manner without express authorization from the Court. Letters to chambers are strictly forbidden and may lead to sanctions. [Judge Sagar Procedures Page]

Discovery Dispute Procedure

Discovery Motions: Counsel is advised to review the procedures and standing orders of the assigned District Judge before filing any discovery motion. Strict compliance with Local Civil Rule 37 is required. Counsel should be mindful that the Magistrate Judge may not alter discovery cut-off deadlines set by the assigned District Judge. The Court encourages the parties to avail themselves of the Court's Informal Discovery Dispute Resolution process. Disputes brought to the Magistrate Judge's attention without sufficient time for decision within the strictures of the District Judge's scheduling order will be stricken or denied. [Judge Sagar Procedures Page]

Discovery Motion Process

04. Discovery Motions: The Court recognizes that Local Civil Rule 37-2.1 exempts discovery motions from the 25-page limit applicable to most briefs. The Court finds little value in reviewing oversize joint submissions that consist of repetitive recitations. For any motion that the parties reasonably believe will exceed 50 pages, they should present the challenged discovery in an appendix attached immediately behind their joint brief. Disputes brought to the Magistrate Judge's attention without sufficient time for decision within the strictures of the District Judge's scheduling order will be stricken or denied. "Boilerplate objections to discovery requests" — Parties responding to interrogatories or document requests shall not use boilerplate objections that violate Federal Rules of Civil Procedure 33(b)(4) or 34(b)(2). Nor shall responding parties use the concept of "disproportionality" as a synonym for previous boilerplate objections of irrelevance, overbreadth, undue burden, or the like. Conclusory objections based on alleged disproportionality, burden, cost, or overbreadth without any basis in fact shall be summarily rejected and/or deemed waived. [Judge Sagar Procedures Page]

Ex Parte Applications

Ex Parte Applications: Strict compliance with Local Civil Rules 7-19 and 7-19.1 is required. Ex parte applications shall identify in the caption whether OPPOSED or UNOPPOSED. Any opposition shall be served and filed within 24 hours of electronic filing of the application. Conformed paper copies shall be delivered directly to Judge Sagar's drop box located outside suite 1200 - Roybal Clerk's Office. Ex parte applications will ordinarily be decided on the papers without oral argument. Absent an emergency, ex parte applications are not an acceptable method of bringing a discovery dispute to the attention of the Court. [Judge Sagar Procedures Page]

Under Seal Filings

Joint Motion for Stipulated Protective Orders: All stipulated protective orders must be titled JOINT MOTION FOR STIPULATED PROTECTIVE ORDER and must comply with Rule 26 and the Ninth Circuit's standards. Parties submitting a stipulated protective order for the court's approval file a single document entitled Joint Motion for Stipulated Protective Order and email a copy in WordPerfect or Microsoft Word to AS_Chambers@cacd.uscourts.gov. Parties shall prepare their protective orders based on the model protective order. A redline in Microsoft Word format shall also be provided by email that shows all differences. [Judge Sagar Procedures Page]

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AI & Style Preferences

AI Disclosure Requirement

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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