Hon. Beth Labson Freeman

Motions must be directed to the Judge to whom the action is assigned, except as that Judge may otherwise order. (p. 30)

the initials of the Magistrate Judge to whom the action is referred for discovery or other pretrial activity (p. 12)

by any written order of a District Judge designating a Magistrate Judge to perform specific statutorily authorized duties in a particular action. (p. 70)

Civil L.R. 7-1(b); 3-4(a); 72-1

The Court will not entertain a request or a motion to resolve a disclosure or discovery dispute unless, pursuant to Fed. R. Civ. P. 37, counsel have previously conferred for the purpose of attempting to resolve all disputed issues. (p. 59)

“Meet and confer” or “confer” means to communicate directly and to discuss in good faith the issue(s) required under the particular Rule or order. (p. 10)

Unless these Local Rules otherwise provide or a Judge otherwise orders, such communication may take place by telephone. (p. 10)

The mere sending of a written, electronic, or voice-mail communication, however, does not satisfy a requirement to “meet and confer” or to “confer.” (p. 10)

this requirement can be satisfied only through direct dialogue and discussion – either in a face to face meeting or in a telephone conversation. (p. 10)

Civil L.R. 37-1(a); 1-5(n)

No local rule on this point (checked, as of 2026-10-24).

If a dispute arises during a discovery event the parties must attempt to resolve the matter without judicial intervention by conferring in good faith. (p. 59)

counsel or a party may contact the chambers of the assigned District Judge or Magistrate Judge to ask if the Judge is available to address the problem through a telephone conference during the discovery event. (p. 59)

Civil L.R. 37-1(b)

Any written request to the Court for an order must be presented by one of the following means: (p. 30)

A duly noticed motion pursuant to Civil L.R. 7-2; (p. 30)

In addition to complying with applicable provisions of Civil L.R. 7, a motion to compel further responses to discovery requests must (p. 59)

Civil L.R. 7-1(a); 37-2

a motion to compel further responses to discovery requests must set forth each request in full, followed immediately by the objections and/or responses thereto. (p. 59)

For each such request, the moving papers must detail the basis for the party’s contention that it is entitled to the requested discovery and must show how the proportionality and other requirements of Fed. R. Civ. P. 26(b)(2) are satisfied. (p. 59)

In one filed document not exceeding 25 pages in length, a motion must contain: (p. 30)

The opposition must be filed and served not more than 14 days after the motion was filed. (p. 31)

Unless the Court expressly orders otherwise pursuant to a party’s request made prior to the due date, briefs or memoranda filed with opposition papers may not exceed 25 pages of text (p. 32)

Civil L.R. 37-2; 7-2(b); 7-3(a); 7-4(b)

the reply brief or memorandum may not exceed 15 pages of text. (p. 31)

The reply to an opposition must be filed and served not more than 7 days after the opposition was due. (p. 31)

Once a reply is filed, no additional memoranda, papers or letters may be filed without prior Court approval, except as follows: (p. 31)

Unless the Court expressly orders otherwise pursuant to a party’s request made prior to the due date (p. 32)

Civil L.R. 7-3(c),(d); 7-4(b)

Unless otherwise ordered, as used in any order of this Court or in these Local Rules, a “discovery cut-off” is the date by which all responses to written discovery are due and by which all depositions must be concluded. (p. 59)

Where the Court has set a single discovery cut-off for both fact and expert discovery, no discovery-related motions may be filed more than 7 days after the discovery cut-off. (p. 59)

no motions related to fact discovery may be filed more than 7 days after the fact discovery cut-off, and no motions related to expert discovery may be filed more than 7 days after the expert discovery cut-off. (p. 59)

“Discovery-related motions” encompasses all motions relating to discovery, including motions to compel or protect against discovery, motions regarding the duty to preserve documents, including spoliation motions, motions to quash or enforce subpoenas, and motions for discovery sanctions. (p. 59)

Civil L.R. 37-3

Except as otherwise ordered or permitted by the assigned Judge or these Local Rules, and except for motions made during the course of a trial or hearing, all motions must be filed, served and noticed in writing on the motion calendar of the assigned Judge for hearing not less than 35 days after filing of the motion. (p. 30)

In the Judge’s discretion, or upon request by counsel and with the Judge’s approval, a motion may be determined without oral argument or by telephone conference call. (p. 30)

Civil L.R. 7-2(a); 7-1(b)

If good faith negotiations between the parties fail to resolve the matter, and if disposition of the dispute during the discovery event likely would result in substantial savings of expense or time, counsel or a party may contact the chambers of the assigned District Judge or Magistrate Judge (p. 59)

Unless otherwise ordered by the assigned Judge, a party may file an ex parte motion, that is, a motion filed without notice to opposing party, only if a statute, Federal Rule, local rule, or Standing Order authorizes ex parte filing. (p. 34)

If the motion is to shorten time for the Court to hear a motion: (p. 28)

Civil L.R. 37-1(b); 7-10; 6-3(a)(4)

If counsel for the moving party seeks to arrange such a conference and opposing counsel refuses or fails to confer, the Judge may impose an appropriate sanction, which may include an order requiring payment of all reasonable expenses, including attorney's fees, caused by the refusal or failure to confer.

The Court will not entertain a request or a motion to resolve a disclosure or discovery dispute unless

Civil L.R. 37-1(a)

No local rule on this point (checked, as of 2026-10-24).

Except as otherwise ordered or permitted by the assigned Judge or these Local Rules, and except for motions made during the course of a trial or hearing, all motions must be filed, served and noticed in writing on the motion calendar of the assigned Judge for hearing not less than 35 days after filing of the motion. (p. 30)

Fed. R. Civ. P. 6(d), which extends deadlines that are tied to service (as opposed to filing), does not apply and thus does not extend this deadline. (p. 30)

On the first page in the space opposite the caption and below the case number, the noticed hearing date and time; (p. 30)

In the first paragraph, notice of the motion including date and time of hearing; (p. 30)

A Judge who will be absent from the District for one court day or more shall post a notice to that effect on the official calendar of the Court. (p. 10)

Civil L.R. 7-2(a), (b)(1)-(2); 1-5(p)

In the Judge’s discretion, or upon request by counsel and with the Judge’s approval, a motion may be determined without oral argument or by telephone conference call. (p. 30)

Unless otherwise ordered, a Motion for Administrative Relief is deemed submitted for immediate determination without hearing on the day after the opposition is due. (p. 34)

Civil L.R. 7-1(b); 7-2(a); 7-11(c)

No local rule on this point (checked, as of 2026-10-24).

No local rule on this point (checked, as of 2026-10-24).

No local rule on this point (checked, as of 2026-10-24).

No local rule on this point (checked, as of 2026-10-24).

a party who has filed a motion may file a notice continuing the originally noticed hearing date for that motion to a later date if: (p. 32)

No opposition has been filed; and (p. 32)

The notice of continuance is filed prior to the date on which the opposition is due pursuant to Civil L.R. 7-3(a). (p. 32)

After an opposition to a motion has been filed, the noticed hearing date may be continued to a subsequent date upon order of the assigned Judge. (p. 32)

Unless otherwise ordered by the Court, the continuance of the hearing of a motion does not extend the time for filing and serving the opposing papers or reply papers. (p. 32)

Any stipulated request or motion which affects a hearing or proceeding on the Court’s calendar must be filed no later than 14 days before the scheduled event. (p. 28)

Civil L.R. 7-7(a), (b), (d); 6-1(b)

No local rule on this point (checked, as of 2026-10-24).

No local rule on this point (checked, as of 2026-10-24).

No local rule on this point (checked, as of 2026-10-17).

In one filed document not exceeding 25 pages in length, a motion must contain: (p. 30)

Unless the Court expressly orders otherwise pursuant to a party’s request made prior to the due date, briefs or memoranda filed with opposition papers may not exceed 25 pages of text and the reply brief or memorandum may not exceed 15 pages of text. (p. 32)

Civil L.R. 7-2(b); 7-4(b)

No local rule on this point (checked, as of 2026-10-17).

No local rule on this point (checked, as of 2026-10-17).

Motions for summary judgment or summary adjudication and opposition to such motions must be noticed as provided in Civil L.R. 7-2 and 7-3. (p. 65)

Except as otherwise ordered or permitted by the assigned Judge or these Local Rules, and except for motions made during the course of a trial or hearing, all motions must be filed, served and noticed in writing on the motion calendar of the assigned Judge for hearing not less than 35 days after filing of the motion. (p. 30)

The opposition must be filed and served not more than 14 days after the motion was filed. (p. 31)

The reply to an opposition must be filed and served not more than 7 days after the opposition was due. (p. 31)

Civil L.R. 56-1; 7-2(a); 7-3(a), (c)

If the assigned Judge orders the submission of a joint statement of undisputed facts, the parties shall confer and submit, on or before a date set by the assigned Judge, a joint statement of undisputed facts. (p. 65)

Civil L.R. 56-2(b)

Unless required by the assigned Judge, no separate statement of undisputed facts or joint statement of undisputed facts shall be submitted. (p. 65)

If the nonmoving party refuses to join in the statement, the moving party will nevertheless be permitted to file the motion, accompanied by a separate declaration of counsel explaining why a joint statement was not filed. (p. 65)

Civil L.R. 56-2(a)-(b)

No local rule on this point (checked, as of 2026-10-17).

No local rule on this point (checked, as of 2026-10-17).

Any evidentiary and procedural objections to the motion must be contained within the brief or memorandum. (p. 31)

Any evidentiary and procedural objections to the opposition must be contained within the reply brief or memorandum. (p. 31)

If new evidence has been submitted in the reply, the opposing party may file and serve an Objection to Reply Evidence, which may not exceed 5 pages of text, stating its objections to the new evidence, which may not include further argument on the motion. (p. 31)

Civil L.R. 7-3(a), (c), (d)(1)

Factual contentions made in support of or in opposition to any motion must be supported by an affidavit or declaration and by appropriate references to the record. (p. 32)

Civil L.R. 7-5(a)

No local rule on this point (checked, as of 2026-10-17).

Content. In addition to complying with the applicable provisions of Civil L.R. 3-4, a brief or memorandum of points and authorities filed in support, opposition, or reply to a motion must contain: (p. 31)

A succinct statement of the relevant facts; and (p. 31)

Civil L.R. 7-4(a)(4)

No local rule on this point (checked, as of 2026-10-17).

No local rule on this point (checked, as of 2026-10-17).

No local rule on this point (checked, as of 2026-10-17).

An affidavit or declaration not in compliance with this rule may be stricken in whole or in part. (p. 32)

Whether or not sanctions should be imposed for failure to file a joint statement of undisputed facts is a matter within the discretion of the assigned Judge. (p. 65)

Civil L.R. 7-5(b); 56-2(b)

At the time the application is submitted, an attorney requesting to practice under Civil L.R. 11-3 must pay to the Clerk the Pro Hac Vice admission fee set by the Court's fee schedule. (p. 39)

If the assigned Judge rejects the application, the fee will be refunded at the attorney's request. (p. 39)

Fee schedule; Civil L.R. 11-3(d)-(e)

(3) That an attorney, identified by name and office address, who is a member of the bar of this Court in good standing and who maintains an office within the State of California, is designated as co-counsel. (p. 39)

Civil L.R. 11-3(a)(3)

An attorney who is not a member of the bar of this Court may apply to appear pro hac vice in a particular action in this district by submitting to the Clerk, together with the written application, a true and correct copy of a certificate of good standing or other similar official document issued by the appropriate authority governing attorney admissions for the relevant bar. (p. 38)

Civil L.R. 11-3(a); admission page

An attorney who is not a member of the bar of this Court may apply to appear pro hac vice in a particular action in this district by submitting to the Clerk, together with the written application, a true and correct copy of a certificate of good standing or other similar official document issued by the appropriate authority governing attorney admissions for the relevant bar. (p. 38)

must be dated no more than one year prior to the date of application for admission. (p. 39)

Civil L.R. 11-3(a)

The applicant must also submit an oath certifying the following: (1) That he or she is an active member in good standing of the bar of a United States Court or of the highest court of another state or the District of Columbia, specifying such bar; (2) That he or she agrees to abide by the Standards of Professional Conduct set forth in Civil L.R. 11-4, and to become familiar with the Local Rules and Alternative Dispute Resolution Programs of this Court and, where applicable, with the Bankruptcy Local Rules; (3) That an attorney, identified by name and office address, who is a member of the bar of this Court in good standing and who maintains an office within the State of California, is designated as co-counsel. (4) The number of times the applicant has been granted pro hac vice admission by the Court in the 12 months preceding the application. (p. 39)

Civil L.R. 11-3(a)(1)-(4); court form

An attorney seeking to appear pro hac vice must submit the application and admission fee at the time of the filing of a complaint or the attorney's first appearance in the case. A failure to meet this deadline may result in denial of the application. (p. 39)

Except as provided in Civil L.R. 11-2, 11-3, and 11-9, and Fed. R. Civ. P. 45(f), an attorney must be a member of the bar of this Court to practice in this Court and in the Bankruptcy Court of this District. (p. 37)

Civil L.R. 11-3(b); 11-1(a)

admission page

Service of papers on and communications with local co-counsel designated pursuant to Civil L.R. 11-3(a)(3) shall constitute notice to the party. (p. 39)

(2) If not proceeding pro se and if proceeding pro hac vice in conformity with Civil L.R. 11-3, following the information required in Civil L.R. 3-4(a)(1), the name, address, telephone and state bar number of the member of the bar of the Court who maintains an office within the State of California; and (p. 12)

Civil L.R. 11-3(f); 3-4(a)(2)

No local rule on this point (checked, as of 2026-10-24).

A failure to meet this deadline may result in denial of the application. (p. 39)

The Clerk will not present an application to the assigned Judge unless the filing fee has been paid or a request to waive the filing fee has been submitted. (p. 39)

Civil L.R. 11-3(b), (e)

Unless authorized by an Act of Congress or by an order of the assigned Judge, an applicant is not eligible for permission to practice pro hac vice if the applicant: (1) Resides in the State of California; or (2) Is regularly engaged in the practice of law in the State of California. This disqualification shall not be applicable if the pro hac vice applicant (i) has been a resident of California for less than one year; (ii) has registered with, and completed all required applications for admission to, the State Bar of California; and (iii) has officially registered to take or is awaiting results from the California State Bar exam. (p. 39)

Civil L.R. 11-3(c)

(4) The number of times the applicant has been granted pro hac vice admission by the Court in the 12 months preceding the application. (p. 39)

Civil L.R. 11-3(a)(4)

An attorney employed or retained by the United States government or any of its agencies may, without satisfying the membership requirements of LR 11-1, practice in this Court in all actions or proceedings within the scope of his or her employment or retention by the United States. (p. 38)

Civil L.R. 11-2