Pre-Trial Documents and Settlement Conference Statements in California Courts

Sacramento Superior Court

  • Local Rules
  • Trial Documents Due:
    • Motions in Limine – Exchange seven (7) days before trial.  File with court on first day of trial.  [Local Rule 13.00]
    • Jury Instructions, Witness Lists, Exhibit Lists, Statement of the Case –  Parties should meet and confer on these before trial, and submit them on the first day of trial.  [Local Rules 13.02 to 13.06]
  • Settlement Conference Statement Template
  • Settlement Conference Statements Due:  Must be received by court at least 10 days before settlement conference.
  • Note:  Settlement Conference Statements should now be e-mailed to  Paper copies are no longer required.

Placer County Superior Court

  • Local Rules
  • Trial Documents Due:
    • Motions in Limine – Must be filed & served 10 days before trial.  Oppositions are due 5 days before trial.  [Local Rule 20.6.1]
    • Trial Briefs, Witness List, Statement of the Case, shall be filed at the Civil Trial Conference [Local Rule 20.6]
    • Exhibits – Presented to court on first day of trial.  [Local Rule 20.6]
  • Settlement Conference Statement Due:  Must file & serve 10 days before settlement conference.  [Local Rule 20.1.10]
  • Settlement Conference Statement Contents:  [Local Rule 20.1.10]
    • 1.  The attorney or party who is submitting the statement and the party whom the attorney represents.
    • 2. Lead counsel and the represented party for all other parties in the case.
    • 3. A statement of the facts, including any background information necessary to understand the case.
    • 4. Any factual stipulations reached by the parties.
    • 5. Contested issues of facts, including detail of the claimed damages and defenses.
    • 6. Contested issues of law.
    • 7. A statement disclosing the highest offer and lowest demand, and the date of the last settlement discussions.
    • 8. The limits of any available insurance coverage.
    • 9. A statement as to whether or not the case has been through arbitration (attach a copy of any arbitrator’s award).
    • 10. A statement as to any special problems relating to settlement.

Yuba County Superior Court

  • Local Rules
  • Trial Documents Due:
    • Motions in Limine and Trial Briefs – Due 5 days before trial.  [Local Rule 2.2(A)(1)]

El Dorado Superior Court

  • Local Rules
  • Trial Documents Due:
    • Motions in Limine – Must be filed and served3 court days before MSRC.  [Local Rule 7.12.11].
    • Statement of the Case, Witness List, Exhibit List, Jury Instructions, Photographs and Reports – Must be filed and served 5 court days before MSRC with the MSRC statement.  [Local Rule 7.12.11].

    Issue Conference[Local Rule 7.12.12.]

      • If no settlement is reached at the MRSC, the officer at the MRSC shall set a date for an ISSUE CONFERENCE.  Attendance by the attorney who will actually try the case is mandatory (no sending a young associate).
      • Before the issue conference, the parties must meet and confer and prepare a joint statement of the following:
        • Legal and Factual Issues of the case and The Sequence of Trail with any appropriate memorandum of points and authorities.
        • Statement of the Case.
        • Propose Voir Dire.
        • Jury Instructions.  Instructions upon which there is no joint agreement must be tabbed.
        • General and Special Verdict Forms.
        • Joint Exhibits.   (Tabbed, numbered, and in 3-ring binders, with a table of contents).  Do not include depositions, requests for admission, or interrogatories.  Exhibits to be used solely for impeachment should not be included, but they should be given to opposing counsel before the first day of trail or they may be excluded at trial.
        • Joint Exhibit List – Including exhibit number, description, proponent, and whether the exhibit may be admitted by stipulation.
        • Whether the parties anticipate and hearings pursuant to Evidence Code 402.