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Judge Cynthia Valenzuela -- United States District Court, Central District of California

Courtroom 10B, 10th Floor, Felicitas and Gonzalo Mendez United States Courthouse, Los Angeles

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Key Traps — Where Counsel Gets Caught

  1. 1. MSJs get a DIFFERENT limit than other motions: MSJ = 7,000 words per separately represented party; all other motions/oppositions = 25 pages; replies = 15 pages — mixed word/page regime by motion type
  2. 2. MSJ, TRO, and preliminary injunction motions REQUIRE clearing a hearing date with the CRD before filing — other motions do not
  3. 3. Hard footnote cap: EIGHT footnotes total per party on MSJ briefing; footnotes must match body font and size
  4. 4. Motion hearings only on Fridays at 1:30 p.m. (afternoon calendar)
  5. 5. Proposed orders MUST use the template on Valenzuela's Procedures page AND be emailed in Word to CV_Chambers@cacd.uscourts.gov — failure may result in the motion being stricken without merits consideration
  6. 6. In-person default for all hearings; telephonic/video only for status conferences on 3-court-day advance email showing undue hardship, using landline or hardline internet, ready 15 minutes early
  7. 7. Chambers copies NOT required except for MSJ, class certification (plus oppositions/replies), and overlength briefs — otherwise the court discourages sending them
  8. 8. Settlement notification after 4:00 p.m. on the last business day before trial triggers jury-fee assessment under L.R. 40-3 absent good cause
  9. 9. Continuance requests less than 5 business days before the deadline are disfavored; a request to continue an ALREADY-EXPIRED deadline is presumptive lack of due diligence
  10. 10. Times New Roman must be 14-point minimum (Courier 12-point) — footnotes match body font and size

Quick Reference

Topic Rule
Motion Days §III.A. Time for Filing and Hearing Motions. Motions shall be filed in accordance with Local Rules 6 and 7. The Court hears motions in civil actions on Fridays, beginning at 1:30 p.m. It is not necessary to clear a hearing date with the Courtroom Deputy Clerk before filing a motion, except for motions for summary judgment, temporary restraining orders, or motions for a preliminary injunction. If the motion hearing date selected is not available, the Court will issue an order continuing the hearing. [valenzuela-cynthia | motion_hearing_days]
Motion Limit §III.C. Length and Format of Motion Papers. Unless otherwise stated by the Court, memoranda of points and authorities in support of or in opposition to motions shall not exceed twenty-five (25) pages. Only rarely and for good cause shown will the Court grant an application to extend these page limitations. [See Judge Valenzuela's Order Re: Motions for Summary Judgment regarding the length and format of motions for summary judgment: MSJ §1.c Word Limit: Each separately represented party shall be limited to 7,000 words, exclusive of tables of contents and authorities.] [valenzuela-cynthia | page_limits_motions]
Reply Limit §III.C. Replies shall not exceed fifteen (15) pages. Only rarely and for good cause shown will the Court grant an application to extend these page limitations. [valenzuela-cynthia | page_limits_replies]
Chambers Copies Conditional §V.D. Chambers copies shall be delivered to Judge Valenzuela's 'Mandatory Chambers Copies' box, located on the fourth floor of the United... [valenzuela-cynthia | chambers_copies_details]
Tentative Rulings Silent on tentative rulings. Not applicable: federal court does not issue tentative rulings. [valenzuela-cynthia | tentative_rulings]
Remote Appearances §V.F. The Court requires in-person attendance for all hearings and trials, unless otherwise instructed by the Court. The Court may permit appearances by telephone or video conference for status conferences upon a showing that a personal appearance will cause undue hardship. If you wish to appear by telephone or video conference, you must: (1) email the Courtroom Deputy Clerk and copy opposing counsel at least three (3) court days in advance of the scheduled appearance and provide a detailed statement of undue hardship; (2) use a landline to call into the bridge line provided by the Courtroom Deputy Clerk or use a hardline internet connection to connect to the Zoom link for the Court; and (3) be available and ready to call in for at least fifteen (15) minutes before the time of the scheduled hearing. [valenzuela-cynthia | remote_appearances]
Discovery §II.A. All discovery matters are hereby referred to the assigned Magistrate Judge, who will hear all discovery disputes. [valenzuela-cynthia | discovery_referral]

Procedural Briefing by Motion Type

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Before You File
Motion Days & Times
§III.A. Time for Filing and Hearing Motions. Motions shall be filed in accordance with Local Rules 6 and 7. The Court hears motions in civil actions on Fridays, beginning at 1:30 p.m. It is not necessary to clear a hearing date with the Courtroom Deputy Clerk before filing a motion, except for motions for summary judgment, temporary restraining orders, or motions for a preliminary injunction. If the motion hearing date selected is not available, the Court will issue an order continuing the hearing. [valenzuela-cynthia | motion_hearing_days]
Notice Period
JPS §A. All other motions must be noticed, served, and filed not later than twenty-eight (28) days before the hearing date. See Local Rule 6-1. Oppositions must be filed and served not later than twenty-one (21) days before the hearing date. Replies must be filed and served not later than fourteen (14) days before the hearing date. See Local Rules 7-9, 7-10. [valenzuela-cynthia | motion_notice_days]
Motion Page / Word Limit
§III.C. Length and Format of Motion Papers. Unless otherwise stated by the Court, memoranda of points and authorities in support of or in opposition to motions shall not exceed twenty-five (25) pages. Only rarely and for good cause shown will the Court grant an application to extend these page limitations. [See Judge Valenzuela's Order Re: Motions for Summary Judgment regarding the length and format of motions for summary judgment: MSJ §1.c Word Limit: Each separately represented party shall be limited to 7,000 words, exclusive of tables of contents and authorities.] [valenzuela-cynthia | page_limits_motions]
Opposition Limit
§III.C. Unless otherwise stated by the Court, memoranda of points and authorities in support of or in opposition to motions shall not exceed twenty-five (25) pages. [valenzuela-cynthia | page_limits_oppositions]
Reply Limit
§III.C. Replies shall not exceed fifteen (15) pages. Only rarely and for good cause shown will the Court grant an application to extend these page limitations. [valenzuela-cynthia | page_limits_replies]
Font & Formatting
§III.C. Pursuant to Local Rule 11-3.1.1, either a proportionally spaced or monospaced face may be used. Typeface shall comply with Local Rule 11-3.1.1. Times New Roman font must be no less than 14 point; Courier font must be no less than 12 point. Footnotes shall be in the same font and the same size as the body of the memorandum. [valenzuela-cynthia | font_formatting]
Footnote Policy
§III.C. Footnotes shall be in the same font and the same size as the body of the memorandum. MSJ §1.c: Each party is limited to the use of a total of eight footnotes. [valenzuela-cynthia | footnote_policy]
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At Filing
Chambers Copies
Conditional §V.D. Chambers copies shall be delivered to Judge Valenzuela's 'Mandatory Chambers Copies' box, located on the fourth floor of the United States District Courthouse, 350 W 1st Street, Los Angeles, CA 90012. A mandatory chambers copy must comply with Local Rule 11-3 (i.e., font size, page numbering, exhibit tabbing, etc.) but need not be blue-backed. The mandatory chambers copy must be prominently labeled MANDATORY CHAMBERS COPY on the face page. [valenzuela-cynthia | chambers_copies_details]
ECF Stamp Requirements
§V.A. Electronic Filing. Pursuant to Fed. R. Civ. P. 5(d)(3), L.R. 5-4, and General Order 10-07, counsel shall electronically file ('e-file') all filings. Items that do not require the Court's signature shall be e-filed in .pdf format. Proposed orders shall be e-filed in .pdf format as an attachment to the main documents. [valenzuela-cynthia | ecf_stamp_requirements]
Proposed Orders
§V.C. 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 Word format shall be emailed directly to the Court's chambers email address at CV_Chambers@cacd.uscourts.gov on the day the document is e-filed. The parties must use the template for proposed orders available on Judge Valenzuela's Procedures and Schedules page on the Court's website. Failure to email a proposed order in Word format using the Court's template may result in the Court striking the motion, application, or stipulation without consideration of the request on its merits. [valenzuela-cynthia | proposed_orders]
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Before the Hearing
Tentative Rulings
Silent on tentative rulings. Not applicable: federal court does not issue tentative rulings. [valenzuela-cynthia | tentative_rulings]
Prohibition / Ex Parte Contact Re Tentatives
Silent on tentative ruling prohibition. Not applicable: federal court does not issue tentative rulings. [valenzuela-cynthia | tentative_ruling_prohibition]
Oral Argument
§III.F. Oral Argument. 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. [valenzuela-cynthia | oral_argument_default]
Remote Appearances
§V.F. The Court requires in-person attendance for all hearings and trials, unless otherwise instructed by the Court. The Court may permit appearances by telephone or video conference for status conferences upon a showing that a personal appearance will cause undue hardship. If you wish to appear by telephone or video conference, you must: (1) email the Courtroom Deputy Clerk and copy opposing counsel at least three (3) court days in advance of the scheduled appearance and provide a detailed statement of undue hardship; (2) use a landline to call into the bridge line provided by the Courtroom Deputy Clerk or use a hardline internet connection to connect to the Zoom link for the Court; and (3) be available and ready to call in for at least fifteen (15) minutes before the time of the scheduled hearing. [valenzuela-cynthia | remote_appearances]
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Background Rules
Chambers Contact
§V.I. Communications with Chambers. Counsel must not attempt to contact the Court or chambers staff by email, telephone, or ex parte means. For appropriate matters only, counsel may contact the Courtroom Deputy Clerk via chambers email address at CV_Chambers@cacd.uscourts.gov, or by telephone at (213) 894-0239. Counsel must not contact the Courtroom Deputy Clerk regarding the status of any matter before the Court. Counsel must include on all papers his or her email address and telephone number to facilitate communication with the Courtroom Deputy Clerk. [valenzuela-cynthia | chambers_contact_restrictions]
Discovery Referral
§II.A. All discovery matters are hereby referred to the assigned Magistrate Judge, who will hear all discovery disputes. [valenzuela-cynthia | discovery_referral]
Discovery Motion Process
§II.A. Discovery Matters Referred to United States Magistrate Judge. All discovery matters are hereby referred to the assigned Magistrate Judge, who will hear all discovery disputes. All discovery-related documents must include the words 'DISCOVERY MATTER' in the caption to ensure proper routing. Counsel are directed to follow the Magistrate Judge's procedures for scheduling matters for hearing. These procedures are stated on each Magistrate Judge's webpage. [valenzuela-cynthia | discovery_motion_process]
Ex Parte Applications
§V.G. Ex Parte Applications. Following service of the ex parte application by electronic, facsimile, or personal service, the applicant shall notify the opposing party that any opposition must be filed no later than twenty-four (24) hours following service. Counsel will be notified by the clerk of the Court's ruling. If counsel does not intend to oppose an ex parte application, counsel must inform the Courtroom Deputy Clerk at (213) 894-0239. [valenzuela-cynthia | ex_parte_notice]
Settlement Notification
JPS §III.B. Settlement. Counsel shall notify the Courtroom Deputy Clerk as soon as a settlement of the action has been reached. The Court may assess jury fees against each side under Local Rule 40-3 if the notification of settlement occurs after 4:00 p.m. on the last business day prior to trial absent a showing of good cause. [valenzuela-cynthia | settlement_notification]
Lead Counsel
§V.F. Appearance at Hearings. The Court requires lead counsel to appear for scheduling conferences, settlement conferences, and the Final Pretrial Conference. The Court requires in-person attendance for all hearings and trials, unless otherwise instructed by the Court. [valenzuela-cynthia | lead_counsel_requirement]
Under Seal Filings
§V.E. Filings Under Seal. Local Rule 79-5 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. Parties must comply with all provisions of Local Rule 79-5. For each document or other type of information a party seeks to file under seal, the party must identify and discuss the factual and/or legal justification that establishes 'good cause' or 'compelling reasons' for the information to be protected. Sealing must be justified for each individual item: blanket claims of confidentiality will result in the application to seal being denied. The parties also must meet and confer before filing an application to seal. [valenzuela-cynthia | under_seal_requirements]
Continuances & Calendar Conflicts
§V.H. Continuances. The 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 not readily be changed. Therefore, a request to continue or extend the date of any matter before this Court must be supported by a sufficient factual basis that demonstrates good cause why the change in the date is essential. Counsel shall avoid submitting requests for continuance or extension of time less than five (5) business days prior to the expiration of the scheduled date. A request to continue or extend dates or deadlines that have already expired constitutes a presumptive lack of due diligence. [valenzuela-cynthia | continuances_calendar_conflicts]

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