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N.D. Cal. · Judge Keulen · Practice Guide

Hon. Susan van Keulen

All local rules for N.D. Cal., integrated with this judge's published requirements.

Get updates when Judge Keulen's procedures change
Discovery Motions
Who decides discovery disputes in this judge's cases: the judge themself, a referral to a magistrate (always / usually / case-by-case), or a special master?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

“Discovery disputes in cases in which Judge van Keulen is the assigned discovery referral judge and in cases that are assigned to Judge van Keulen for all purposes through consent of the parties shall follow the same procedures set forth below:” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

Pre-motion conferral: required? Format (in person / live / written OK)? Who arranges it, deadline, number of attempts?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

“For all discovery disputes, the parties must meet and confer to attempt to resolve the dispute.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“The meet and confer must be in person or by videoconference and conducted by counsel with authority to negotiate and compromise.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“A mere exchange of letters, emails, telephone calls, or voicemail messages does not satisfy the requirement to meet and confer.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

What proof of conferral must be filed or stated (certification, letter, dates, participants, duration)?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

Nothing posted.

Must (or may) the parties get a conference with the court before a written motion (IDC, pre-motion conference, discovery hotline, teleconference)? Required / optional / not offered?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

“Any requests for Court action must be filed on the docket.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“Parties must refrain from contacting the Courtroom Deputy by email or telephone unless (1) required to do so by one of the Court's standing orders; (2) instructed to do so by the Court; or (3) necessary to inform the Court about a time-sensitive matter.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“Contact with the Courtroom Deputy must be limited to purely administrative matters, such as scheduling and general case management.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“Parties are not to communicate with the Courtroom Deputy regarding substantive or procedural issues, such as requests for legal advice or for interpretation of procedural rules.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

The vehicle and contents for raising a dispute with the court: letter / letter-motion / email / form / joint submission. Joint or unilateral? Page or word limits, required contents, attachments.
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

“• If the parties are unable to reach a resolution, they must file a joint statement not to exceed 10 pages, exclusive of the caption page, double-spaced with 12-point font and in text-searchable PDF format.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“• The joint statement must be filed in ECF under the Civil Events category of Motions and Related Filings > Motions: General > Discovery Letter Brief.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

If a written motion is filed: form (joint stipulation, standard motion, letter brief), length, required contents (e.g., verbatim requests and responses), briefing schedule
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

“• If the parties are unable to reach a resolution, they must file a joint statement not to exceed 10 pages, exclusive of the caption page, double-spaced with 12-point font and in text-searchable PDF format.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“• In the opening paragraph, the joint statement must: (1) state the dates for the close of fact discovery and, if set, start of trial; (2) briefly describe each unresolved issue without undue argument; and (3) set forth each party’s proposed compromise with respect to each unresolved issue.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“• In addition, when specific discovery requests are disputed, the parties must include as an exhibit a joint chart, in landscape format, summarizing the basis of the dispute.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“Specifically, the chart must set forth in columns only the following: the disputed request, the response thereto, the parties’ respective proposed compromises and a blank column for the Court’s use.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“The chart must not contain argument; the Court considers only arguments set forth in the joint statement.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“• The joint statement must also include each party’s proposed order as an exhibit.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“• Absent prior leave of Court, the only additional exhibit(s) permitted to the joint statement are a copy of the specific discovery request(s) at issue and the response(s) to it (e.g., requests for production, interrogatories, privilege log, nonparty subpoena, deposition excerpts, initial disclosures, contentions, etc.)” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

Replies, supplemental memos, sur-replies: allowed? Limits?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

“• Upon review of the joint statement, the Court will advise the parties regarding the need, if any, for more briefing, a hearing, or a telephonic conference.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

Must disputes be filed / heard / decided before the discovery cutoff? Any lead-time requirement?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

“• For all cases, the joint statement must be filed no later than 7 days after the discovery cut-off date(s) pursuant to Civil Local Rule 37-3.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

Is there a hearing? When, how (in person / phone / video), decided on papers?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

“All civil discovery and motion hearings will be in person unless otherwise noticed by the Court in Courtroom 6, 4th Floor, San Jose Federal Courthouse.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“Any deviation from the appearance standards above requires prior approval of the Court.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“The requesting party must file an administrative motion to appear by Zoom video link or telephonic link at least 5 days before the hearing.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“Upon review of the joint statement, the Court will advise the parties regarding the need, if any, for more briefing, a hearing, or a telephonic conference.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

Emergency / ex parte discovery relief (e.g., disputes during a deposition): allowed? How?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

Nothing posted.

Stated consequences for not following the procedure ⚠
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

“Argument in footnotes will not be considered by the Court.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“The Court may strike any filing that includes excessive or improper footnotes.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“Footnotes, if any, must comply with section 6(e)(i) above.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“The chart must not contain argument; the Court considers only arguments set forth in the joint statement.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

Hearings & Calendar
When does the judge hear civil motions?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

“Civil motions are heard on Tuesdays at 10:00 a.m.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

How do you get a hearing date? Self-notice on the motion day, reserve with the courtroom deputy first, or the court sets it? Notice period? Closed dates?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

“Parties are not required to reserve a hearing date but should confirm at cand.uscourts.gov that the Court is not unavailable on the date selected.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“Hearings and motions may be reset by the Court as its calendar requires.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

Is there oral argument by default, or is it decided on the papers? Can the court vacate the hearing?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

“• Upon review of the joint statement, the Court will advise the parties regarding the need, if any, for more briefing, a hearing, or a telephonic conference.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

How do you request oral argument (or a hearing) if it isn't automatic?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

Nothing posted.

Does the judge issue tentative rulings? When and where are they posted, and what do you do if you submit on one?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

Nothing posted.

Can you appear remotely (phone/video)? How and when to request it?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

“The parties must check ECF to confirm whether any hearing will be in-person or by Zoom video link.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“• All civil discovery and motion hearings will be in person unless otherwise noticed by the Court in Courtroom 6, 4th Floor, San Jose Federal Courthouse.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“• Initial case management conferences, status conferences, and order to show cause hearings in re settlement/dismissal will be by Zoom video link.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“• Any deviation from the appearance standards above requires prior approval of the Court.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

“The requesting party must file an administrative motion to appear by Zoom video link or telephonic link at least 5 days before the hearing.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

Does the judge encourage or guarantee argument by newer attorneys?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

Nothing posted.

How do you continue/adjourn a hearing?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

Nothing posted.

Courtroom technology and devices: equipment available; phones/laptops allowed; testing in advance
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

Nothing posted.

Stated consequences for hearing-related noncompliance
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

Nothing posted.

Summary Judgment
How many SJ motions may each party (or side) file, and how do you get leave for more?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

“Unless otherwise permitted by the Court, only one Motion for Summary Judgment, Partial Summary Judgment, or Summary Adjudication may be filed by each party.” · Judge van Keulen's Civil & Discovery Referral Matters Standing Order

What page limits apply to SJ briefs, where they differ from the general motion limits?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

Nothing posted.

Do you need the court's permission, a pre-motion conference or letter, a status report, or advance notice before filing?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

Nothing posted.

Can you move for SJ before discovery closes?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

Nothing posted.

When must the motion be filed or heard, and on what briefing schedule?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

Nothing posted.

Before filing, must the movant confer with or serve SJ papers on the opponent, and how far ahead?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

Nothing posted.

What kind of fact statement does the judge want?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

Nothing posted.

Is there a cap on the fact statement (and the response)?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

Nothing posted.

How must the fact statement and responses be laid out?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

Nothing posted.

How do you raise evidentiary objections to the other side's SJ evidence?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

Nothing posted.

How must SJ evidence be assembled?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

Nothing posted.

Do you file full deposition transcripts or only the cited excerpts?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

Nothing posted.

In the brief, do you cite the record, the fact statement, or both? Must the brief carry its own statement of facts?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

Nothing posted.

If the motion or opposition depends on excluding an expert, how and when must the challenge be raised?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

Nothing posted.

How are cross-motions handled?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

Nothing posted.

Will the judge entertain SJ in a non-jury case?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

Nothing posted.

What consequences does the judge's own text state for SJ noncompliance?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

Nothing posted.

Pro Hac Vice
What does PHV admission cost, who pays it, and is it ever waived?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

Nothing posted.

Must PHV counsel associate with local counsel (a member of this court's bar), and who qualifies?
🏛 N.D. Cal. local rule

(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)

👤 Judge Keulen — standing order

Nothing posted.

Who files the PHV motion or application: the applicant, or local or sponsoring counsel?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

Nothing posted.

What proof of good standing is required (a certificate or a sworn statement), from which bars, and how recent?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

Nothing posted.

What must the PHV motion or application contain, and must (or may not) a particular form be used?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

Nothing posted.

By when must the PHV motion be filed or granted: before a filing, before a conference, or at the first appearance? Is an oral motion allowed?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

Nothing posted.

Must PHV counsel register for ECF (or is it barred), and by when?
🏛 N.D. Cal. local rule

admission page

👤 Judge Keulen — standing order

Nothing posted.

What must local counsel do once PHV counsel is in the case (attend conferences or hearings, sign filings, know the case, accept service, answer for PHV counsel)?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

Nothing posted.

Must the PHV motion state the other parties' position or consent, or confer with them first? When may the other side oppose?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

Nothing posted.

What consequences does the judge's own text state for PHV problems (revocation of PHV status, denial, a duty to bring in local counsel)?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

Nothing posted.

Are attorneys who live, work, or are barred in this state excluded from PHV and sent to full admission?
🏛 N.D. Cal. local rule

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)

👤 Judge Keulen — standing order

Nothing posted.

Is there a cap on how often an attorney may appear PHV, or a required disclosure of past PHV applications?
🏛 N.D. Cal. local rule

(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)

👤 Judge Keulen — standing order

Nothing posted.

Do government attorneys need PHV admission, and are they exempt from the fee or local counsel?
🏛 N.D. Cal. local rule

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

👤 Judge Keulen — standing order

Nothing posted.

Other procedures for Judge Keulen
Before You File
Ex parte applications
🏛 N.D. Cal. local rule

7-10. Ex Parte Motions 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. The motion must include a citation to the statute, rule, or order which permits the use of an ex parte motion to obtain the relief sought. Civ. L.R. 7-10 ↗

Drafting the Motion
Length limits — motion, opposition, reply
🏛 N.D. Cal. local rule
Opposition

(b) Length. 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. Civ. L.R. 7-4(b) ↗

Reply

(b) Length. 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. Civ. L.R. 7-4(b) ↗

Footnote policy
👤 Judge Keulen — standing order

Use of footnotes in Court filings is to be limited to providing brief points of clarification or cross-references. Argument in footnotes will not be considered by the Court. The form of footnotes must comply with Civil Local Rule 3-4(c)(2). The Court may strike any filing that includes excessive or improper footnotes.

AI use & disclosure requirements
👤 Judge Keulen — standing order

Use of generative AI tools, such as ChatGPT, Claude, Gemini, etc., in preparing submissions to the Court is not prohibited, but counsel and self-represented parties must at all times personally confirm for themselves the accuracy of any content generated by these tools. The signature of counsel or a self-represented party on any submission containing AI-generated content, including citations generated by AI, constitutes a certification that the signing attorney (or self-represented party) has personally verified the content's accuracy. The Court will impute any errors by such AI tools to the attorney or party whose signature appears on the document containing those errors. Failure to verify the accuracy of submissions, particularly the accuracy of citations to law and evidence, may be grounds for sanctions. Counsel is responsible for maintaining records of all prompts or inquiries submitted to any generative AI tools in the event those records become relevant at any point. Judge van Keulen's Civil and Discovery Referral Matters Standing Order (Feb. 2026), ¶ 10 ↗

Filing & Scheduling
Chambers / courtesy copies
👤 Judge Keulen — standing order
Details

Pursuant to Civil Local Rule 5-1(d)(7), no chambers copies are required unless specifically requested by the Court.

Proposed orders
🏛 N.D. Cal. local rule

(f) Proposed Orders Proposed orders submitted by an ECF user in an ECF case shall be filed in PDF format, and attached to the applicable motion or other document. In addition, proposed orders shall be submitted in a standard word processing format (such as Microsoft Word) to the specific address on the Court’s website for emailing proposed orders to the assigned Judge. Proposed orders must conform to the requirements of the assigned Judge’s standing orders. Civ. L.R. 5-1(f) ↗

👤 Judge Keulen — standing order

All stipulations and proposed orders are to be emailed in Word format to svkcrd@cand.uscourts.gov on the same day as the documents are e-filed.

Filing under seal
👤 Judge Keulen — standing order

Motions to seal shall be filed in accordance with Civil Local Rule 79-5. When submitting a proposed order pursuant to Civil Local Rule 79-5(c)(3), the table format included in the order shall comply with the below format: Document | Text to be Sealed | Basis for Sealing [redacted portions to be identified by page and line number]. Where a party ('Filing Party') files a motion to consider whether another party's ('Designating Party') materials should be sealed pursuant to Civil Local Rule 79-5(f), the Designating Party's statement and/or declaration in support of sealing pursuant to Civil Local Rule 79-5(f)(3) shall attach as exhibit(s) the proposed, public, redacted version of the document(s) sought to be sealed to the extent the proposed redactions differ from the redactions proposed by the Filing Party.

More from Judge Keulen’s procedures
👤 Judge Keulen — standing order
Meet and confer

The meet and confer must be in person or by videoconference and conducted by counsel with authority to negotiate and compromise. A mere exchange of letters, emails, telephone calls, or voicemail messages does not satisfy the requirement to meet and confer. Source ↗

MSJ limitation

Unless otherwise permitted by the Court, only one Motion for Summary Judgment, Partial Summary Judgment, or Summary Adjudication may be filed by each party. Source ↗

Know Before You Go
👤 Judge Keulen — deviations that burn people
  • Discovery joint statement must include a landscape-format joint chart of each disputed discovery request -- this is a hard format requirement, not optional.
  • Discovery joint statement word version of chart AND each party's proposed order must be emailed to svkcrd@cand.uscourts.gov in addition to ECF filing.
  • Discovery joint statement must be filed no later than 7 days after the discovery cut-off date per Civ. L.R. 37-3.
  • Footnotes used for argument will not be considered by the Court and may result in the filing being stricken.
  • Motions to strike affirmative defenses may NOT be filed without leave of Court -- seek leave via Civ. L.R. 7-11 administrative motion.
  • AI-generated content: counsel must personally verify all citations; errors by AI tools are imputed to the signing attorney and may result in sanctions.
  • Consent/declination must be filed simultaneously with any dispositive motion if not yet submitted.
  • Only one MSJ/PSJ/summary-adjudication motion per party absent Court permission.
  • Amended pleadings must be filed with a redline exhibit showing changes from the most-recent version (self-represented parties exempt).
  • Privilege logs must specify author, recipient(s), date, title/description, subject matter, purpose, and specific privilege basis for each document/category -- due no later than 14 days after discovery responses are due.
content assembled from published local rules & standing orders · click any section in the rail for the full treatment
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