Last revised June 16, 2025
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8 UNITED STATES DISTRICT COURT
9 NORTHERN DISTRICT OF CALIFORNIA
10 San Francisco Division
11 STANDING ORDER FOR CIVIL TRIALS BEFORE MAGISTRATE JUDGE BEELER
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Northern District of California
United States District Court
13 OVERALL DEADLINES ............................................................................................................... 1
14 PRETRIAL FILINGS ..................................................................................................................... 1
1. Collated Motions in Limine: Twenty-One Days Before Pretrial Conference ....................... 1
15 2. Pretrial Filings: Twenty-One Days Before Pretrial Conference............................................ 2
2.1 Joint Jury Questionnaire ............................................................................................... 2
16 2.2 Joint Proposed Pretrial Order ....................................................................................... 2
2.2.1 Signed Stipulations ............................................................................................ 2
17 2.2.2 Joint Exhibit List ................................................................................................ 2
2.2.3 Witness Lists ...................................................................................................... 2
18 2.2.4 Joint Proposed Verdict Form ............................................................................. 2
2.2.5 Joint Jury Instructions (Disputed and Undisputed) and Memoranda of Law .... 3
19 2.2.6 Trial Briefs on Remaining Issues ....................................................................... 3
2.2.7 Copies of Federal Rule of Civil Procedure 26(a)(3) Disclosures ...................... 3
20 2.2.8 Chambers Copies ............................................................................................... 3
3. Exhibits and Designations: Fourteen Days Before Pretrial Conference ............................... 3
21 4. Other Procedures for Exhibit Organization ........................................................................... 4
5. Deposition Designation for Witnesses Appearing by Deposition ......................................... 5
22 5.1 Designating Counsel .................................................................................................... 5
5.2 Reviewing Counsel ...................................................................................................... 5
23 5.3 Counsel to Meet and Confer Regarding Adjustments .................................................. 5
5.4 Designating Counsel to Assemble Final Packet ........................................................... 5
24 5.5 Counter-Designations ................................................................................................... 6
6. Video Depositions ................................................................................................................. 6
25 7. Requests for Admissions and Interrogatories ........................................................................ 6
26 TRIAL PROCEDURES .................................................................................................................. 6
1. Trial Schedule and Court Reporters ...................................................................................... 6
27 2. Jury Selection ........................................................................................................................ 7
3. Other Trial Logistics.............................................................................................................. 7
28 3.1 Juror Notes and Questions............................................................................................ 7
3.2 Trial Time Limits ......................................................................................................... 8
1 3.3 Advance Notice at Trial: Opening Statements and Witness Order of Proof ................ 8
3.4 Witness Examinations .................................................................................................. 8
2 3.5 Expert Testimony ......................................................................................................... 9
3.6 Use of Depositions to Impeach a Trial Witness ........................................................... 9
3 3.7 Use of Depositions of Party-Opponents ..................................................................... 10
3.8 Use of Depositions for Witnesses Appearing Only by Deposition ............................ 10
4 3.9 Exhibits....................................................................................................................... 10
3.10 Stipulations ............................................................................................................... 11
5 3.11 Objections................................................................................................................. 11
3.12 Sidebar Conferences ................................................................................................. 11
6 3.13 Charging Conference................................................................................................ 11
4. Additional Procedures for Bench Trials .............................................................................. 11
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2 OVERALL DEADLINES
3 The following are the presumptive deadlines.
4 Case Event No-Later-Than Date
5 Parties to meet and confer about pretrial filings Forty-five days before the Pretrial Conference
6 Serve (but do not file) motions in limine Thirty days before the Pretrial Conference
7 Serve oppositions to motions in limine Twenty-three days before the Pretrial Conference
8 Pretrial filings due (motions in limine, joint
pretrial order, stipulations, witness and exhibit Twenty-one days before the Pretrial Conference
9 lists, proposed jury instructions, verdict forms,
and jury questionnaire, and trial briefs)
10 Lodge exhibits, deposition designations,
admissions and interrogatories designations, and Fourteen days before the Pretrial Conference
11 objections
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13 PRETRIAL FILINGS
14 The following are the procedures and deadlines for pretrial filings.
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16 1. Collated Motions in Limine: Twenty-One Days Before Pretrial Conference
17 No later than thirty days before the pretrial conference, the parties must serve (but not file)
18 their motions in limine, which generally should not exceed five motions, are limited to seven
19 pages each (absent leave of court), must be limited to circumstances requiring advance ruling, and
20 must be titled “[Party’s Name]’s Motion in Limine [#] to Exclude [Subject].” Seven days later (no
21 later than twenty-three days before the final pretrial conference), the opposing party must serve its
22 separate oppositions, each in a separate memorandum entitled “[Party’s Name]’s Opposition to
23 Motion in Limine [#] to Exclude [Subject],” and limited to seven pages each (absent leave of
24 court). There will be no reply briefs. The moving party must collate and file each motion and
25 opposition in paired sets two days later, meaning, no later than twenty-one days before the pretrial
26 conference, and notice them for a hearing at the pretrial conference. Collated chambers copies
27 must be submitted in a binder, labeled on the front and spine with the case name and “Motions in
28 Limine,” with labeled tabs for the individual motions.
STANDING ORDER FOR CIVIL TRIALS 1
1 2. Pretrial Filings: Twenty-One Days Before Pretrial Conference
2 2.1 Joint Jury Questionnaire
3 The jury office will send prospective jurors an online questionnaire with standard questions
4 that are asked in every case, including a statement of involved persons. Parties may propose a total
5 of ten additional questions, which also must be emailed to
[email protected].
6 2.2 Joint Proposed Pretrial Order
7 The parties’ joint proposed order must have (1) a description of the claims and defenses to be
8 decided, (2) a statement of the relief sought, (3) all stipulated facts, (4) a list of disputed fact issues
9 to be tried, organized by claim and described with the same specificity as any contested element in
10 the model jury instructions, (5) the parties’ trial estimates, including attorney voir dire, opening
11 statements, examination of witnesses, and closing arguments (informed by the witness
12 examination times contained in their witness lists, discussed below), and (6) the status of
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13 settlement negotiations. It must attach the following:
14 2.2.1 Signed Stipulations
15 These must be in a form that can be introduced as evidence at trial.
16 2.2.2 Joint Exhibit List
17 The list must have columns for exhibit number, description and bates range, offered into
18 evidence, admitted into evidence, sponsoring witness, and limits on use.
19 2.2.3 Witness Lists
20 The parties must exchange their witness lists thirty days before the pretrial conference. They
21 must file witness lists for their case-in-chief witnesses (including those appearing by deposition)
22 with a short summary of the testimony, an estimated time for direct and cross-examinations, and
23 any special issues such as use of an interpreter and why, if multiple witnesses are proposed on the
24 same topic, the testimony is not duplicative. Absent good cause, experts and witnesses not
25 included on the witness list may not be used in a party’s case-in-chief.
26 2.2.4 Joint Proposed Verdict Form
27 The parties can offer separate proposals when they disagree and must include any model
28 verdict forms (such as CACI forms). They must submit word copies to
[email protected].
STANDING ORDER FOR CIVIL TRIALS 2
1 2.2.5 Joint Jury Instructions (Disputed and Undisputed) and Memoranda of Law
2 The parties must file joint instructions, using model instructions when possible, in the order
3 that they should be given, and include separate proposed preliminary instructions and final
4 instructions. They must submit word copies to
[email protected].
5 The instructions must include a table of contents and be supported by citations to the authority
6 for the instruction (e.g., to the Ninth Circuit Model Jury Instructions or CACI). If undisputed, an
7 instruction must be labeled “Stipulated Instruction.” If disputed, the parties’ versions must bear the
8 same instruction number, be labeled with the sponsoring party’s name, and be inserted back to back
9 in the logical place in the overall sequence. If the opposing party does not have a counter instruction
10 and instead contends that no instruction should be given, the party must say so in a separate page
11 inserted in lieu of the alternate instruction. If the parties modify a model instruction, they must
12 identify the modification clearly in a blackline and include the model instruction in the packet.
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13 The parties must include a short statement of the case to be read to the jury during voir dire as
14 part of the preliminary instructions.
15 Each party must file a memorandum of law — organized by instruction number — regarding
16 disputed jury instructions.
17 2.2.6 Trial Briefs on Remaining Issues
18 Trial briefs are optional.
19 2.2.7 Copies of Federal Rule of Civil Procedure 26(a)(3) Disclosures
20 2.2.8 Chambers Copies
21 The chambers copies of these materials must be submitted in a binder, labeled on the front and
22 spine with the case name and “Pretrial Submissions,” with labeled tabs separating the filings by
23 topic to reflect the organization in this section.
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25 3. Exhibits and Designations: Fourteen Days Before Pretrial Conference
26 First, the parties must lodge a joint, single set of all trial exhibits marked “Original Exhibits,”
27 either as a thumb drive or in three-ring binders. If binders, then each exhibit must be tagged and
28 separated by a label divider identifying the exhibit number. The binder spines must identify the
STANDING ORDER FOR CIVIL TRIALS 3
1 exhibits in a particular binder. A thumb drive must reflect a comparable organization. The parties
2 must lodge a hard copy of the exhibits labeled “Chambers Copy” with any updated (and filed)
3 exhibit list in each binder. The parties must confer and weed out extra exhibits along the way.
4 Second, the parties must file and lodge deposition designations for witnesses appearing only
5 by designation, copies of designations of interrogatories and admissions, and objections to exhibits
6 and use of depositions (as set forth in Federal Rule of Civil Procedure 26(a)(3)(B)). Objections not
7 raised are waived.
8 The chambers copies of these materials must be submitted in binders, labeled on the front and
9 spine with the case name and a description of the contents, and have labeled tabs separating the
10 filings to reflect the organization in this section.
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12 4. Other Procedures for Exhibit Organization
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13 Before submitting exhibit lists and binders, counsel must meet and confer to establish usable
14 numbering conventions and eliminate duplicate exhibits. Use numbers only, and if possible,
15 exhibit numbers should be the same numbers used in depositions. Otherwise, the deposition
16 transcript must be conformed to the new exhibit number to avoid jury confusion and to ensure that
17 every exhibit has a unique number. Blocks of numbers should be assigned to fit the needs of the
18 case: e.g., Plaintiff has 1 to 99, Defendant A has 100 to 199, Defendant B has 200 to 299, et
19 cetera. All exhibits must be marked “Trial Exhibit No.,” not Plaintiff’s Exhibit or Defendant’s
20 Exhibit. A single exhibit must be marked just once. The exhibit tag must be in the following form
21 and must be affixed on or near the lower right-hand corner if possible and on the back if it is not.
22 Counsel must fill in the tag but leave the last two lines blank.
23 UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
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TRIAL EXHIBIT 100
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Case No. ________________
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Date Entered _____________
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By______________________
28 Deputy Clerk
STANDING ORDER FOR CIVIL TRIALS 4
1 5. Deposition Designation for Witnesses Appearing by Deposition
2 These procedures apply only to deposition designations for witnesses who appear by
3 deposition and do not apply to reading depositions of live witnesses into the record while the
4 witnesses are testifying.
5 5.1 Designating Counsel
6 To designate deposition testimony, counsel must photocopy the cover page, the page where the
7 witness is sworn, and each page with any proffered testimony (with lines through testimony not
8 proffered). Counsel must put lines through objections or colloquy unless they are needed to
9 understand the question. Any corrections (including conforming exhibit numbers to trial exhibit
10 numbers) must be done by hand. The finished packet must be the script that allows smooth
11 presentation of the witness, the oath, and the testimony. The packet must be provided to the other
12 parties at least thirty days before the pretrial conference. For voluminous designations, the court
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13 requires advance notice by designating counsel because more lead time is required. Counsel must
14 be reasonable.
15 5.2 Reviewing Counsel
16 Reviewing parties must promptly review the packet and highlight in yellow any passages
17 objected to and write in the margin the legal basis for the objections. If a completeness objection is
18 made, the objecting party must insert the additional passages needed to cure the completeness
19 objection. A completeness objection generally should be made only if a few extra lines will cure
20 the problem. Such additions must be highlighted in blue, and an explanation for the inclusion must
21 be legibly handwritten in the margin. Counsel must line out any irrelevant portions of the
22 additional pages. Reviewing counsel must return the packets to the proffering party to consider
23 whether to accept the adjustments.
24 5.3 Counsel to Meet and Confer Regarding Adjustments
25 Counsel must meet and confer to address reviewing counsel’s comments and any other issues.
26 5.4 Designating Counsel to Assemble Final Packet
27 Counsel for the proffering party must collate and assemble a final packet that covers all
28 remaining issues and provide it to the court fourteen days before the pretrial conference. Any
STANDING ORDER FOR CIVIL TRIALS 5
1 objections must be highlighted and annotated as described in this section. If exhibits are needed to
2 resolve the objections, designating counsel must include copies, with the relevant passages
3 highlighted and tagged. The court will read the packet and make its rulings in the margins in a
4 distinctive manner.
5 5.5 Counter-Designations
6 The reviewing party must make any counter-designations by providing a packet with the
7 counter-designated passages to the original designating counsel at the same time as the reviewing
8 party returns its objections to designating counsel. The original designating counsel must supply
9 any objections in the manner described in this section.
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11 6. Video Depositions
12 The parties must follow the same procedures to facilitate ruling on objections. The videos must
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13 omit dead time, objections, and colloquy not necessary to understand the answers.
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15 7. Requests for Admissions and Interrogatories
16 Counsel must designate responses to requests for admissions and interrogatory answers in the
17 same manner and under the same timetable as deposition designations.
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19 TRIAL PROCEDURES
20 1. Trial Schedule and Court Reporters
21 Trials start on Mondays. The pretrial conference is two Thursdays (eleven days) earlier, at 1:00
22 p.m. Lead counsel for each party must attend. Depending on the district’s overall trial schedule,
23 jury selection can occur the week before the official Monday trial start.
24 The parties must arrange daily or real-time reporting at least fourteen days before trial with the
25 court-reporter supervisor at 415-522-2079 and by email to
[email protected]. The parties
26 meet with the court’s courtroom deputy (
[email protected] or 415-522-3140) at least
27 fourteen days before trial to work out all technical and courtroom issues.
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STANDING ORDER FOR CIVIL TRIALS 6
1 The trial day is 8:30 a.m. to 1:30 p.m. (or slightly longer to finish a witness), Monday through
2 Friday, generally with a fifteen-minute break every ninety minutes, depending on the availability
3 of court reporters. Counsel must arrive at 8:15 a.m. The courtroom is open at 8:00 a.m., and the
4 court reserves witness rooms for each side, which also allows storage of equipment. The court will
5 hold an instructions conference during trial.
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7 2. Jury Selection
8 The court’s jury-selection procedures are as follows.
9 Several days before jury selection, the Clerk’s office will provide the parties the responses to
10 the jury questionnaires and a list of the jurors in the order of call (as opposed to a random list). At
11 least a day before jury selection, the court has a short hearing to address any agreed-to challenges
12 for cause or hardship. (Any disputes will be addressed only during jury selection.)
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13 The court’s jury-selection procedures vary depending on the length of the trial and the
14 resulting size of the jury. Assuming the ordinary jury of eight and six peremptory challenges, the
15 court will call twenty-one jurors, which fills the jury box and a row in front of the box. The
16 remaining jurors are seated in order (starting with number twenty-two) in the public benches. The
17 court allows attorney voir dire. Because voir dire usually extends to jurors in the public rows (not
18 just the twenty-one in the box), usually no additional questioning is needed, but the court allows
19 that process if necessary. The court addresses hardship excuses, challenges for cause, and
20 peremptory challenges out of the prospective jurors’ presence. Then, the eight (or other number
21 of) jurors with the lowest numbers will be the final jury.
22 The court may alter these procedures.
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24 3. Other Trial Logistics
25 3.1 Juror Notes and Questions
26 Jurors may take notes. Note pads will be distributed at the beginning of each trial and collected
27 at the end of the day and locked in the jury room. The court will instruct the jury on the use of
28 notes in its preliminary and final jury instructions. The court allows juror questions during trial.
STANDING ORDER FOR CIVIL TRIALS 7
1 3.2 Trial Time Limits
2 At the final pretrial conference, the court will set time limits for opening statements, witness
3 examinations (direct, cross, or re-direct), and closing arguments. The time taken at a sidebar or on
4 objections will be charged to the examining party unless otherwise ordered.
5 3.3 Advance Notice at Trial: Opening Statements and Witness Order of Proof
6 Counsel must meet and confer about, and exchange, any visuals, graphics, or exhibits to be
7 used in the opening statements, allowing for time to work out objections and any reasonable
8 revisions. Generally, visual presentations must be exchanged at 2 p.m. two business days before
9 opening statements. Objections must be filed by 8:00 a.m. the next day, with a chambers copy
10 delivered by 11:00 a.m. that includes the documents and copies of cited cases. The court may
11 decide the issues on the papers or convene a Zoom conference to discuss them.
12 Generally, by 2:00 p.m. on any court day, counsel must give written notice of the order of
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13 witnesses for the next court day and the exhibits (including illustrative exhibits) to be used on direct
14 examination (other than for true impeachment of a witness). The parties must notify the court by
15 4:00 p.m. of any objections to the exhibits, and the court may schedule a conference that afternoon
16 or the following morning to resolve the dispute. In complex cases, the court may require notice two
17 court days before the testimony by 2:00 p.m. Objections then are due the next day at 8:00 a.m., and
18 chambers copies (including the disputed exhibits and the cited cases) must be delivered by 11:00
19 a.m. The court will address the disputes at the end of the trial day.
20 3.4 Witness Examinations
21 Generally there must be only one examining lawyer per witness per party, and the examining
22 lawyer must make any objections to the opposing counsel’s examination. The parties must have
23 witnesses ready to testify so that trial gaps are avoided. Gaps may be construed as resting one’s
24 case. In cases with multiple parties, counsel must coordinate cross-examination to avoid
25 duplication of testimony.
26 Counsel must place copies of exhibits to be used by a witness on the witness stand before the
27 witness testifies.
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STANDING ORDER FOR CIVIL TRIALS 8
1 Witnesses (except named parties) are excluded from the courtroom except when they are
2 testifying. If a testifying witness has not been excused before a recess, that witness must be seated
3 back on the stand when the court reconvenes. If a new witness is ready to be called immediately
4 after a recess, the witness must be in the first row after the recess.
5 The appropriate party or the court may read into the record the undisputed facts at appropriate
6 points in the trial.
7 3.5 Expert Testimony
8 Direct expert testimony is limited to matters disclosed in the expert’s reports. Omitted material
9 ordinarily may not be added on direct examination. Illustrative animations, diagrams, charts, and
10 models may be used on direct examination only if they were part of the expert report, except that
11 an expert may use simple drawings (such as those drawn by the witness at trial) that plainly
12 illustrate a report’s contents. If cross-examination fairly opens the door, an expert may go beyond
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13 the written report on cross-examination and/or re-direct examination. By written stipulation, all
14 parties may relax these requirements. As to damages studies, the cut-off for past damages is the
15 date of the expert report (or an earlier date selected or used by the expert). Experts may project
16 future damages after this cut-off date if they can meet substantive standards for future damages.
17 With timely leave of court or by written stipulation, the experts may update their reports (or
18 provide supplemental reports) at a date closer to the time of trial.
19 3.6 Use of Depositions to Impeach a Trial Witness
20 The following procedures apply.
21 On the first day of trial, counsel must bring the original and clean copies of the depositions to
22 be used at trial. If counsel might use a deposition against a witness, counsel must provide the court
23 with a copy at the outset of the examination. Opposing counsel must have copies of witness
24 depositions immediately available.
25 Counsel must seek permission from the court before reading a passage into the record. For
26 example, counsel must state, “I ask to read page 210, lines 1 to 10, from the witness’s deposition.”
27 Counsel must pause briefly to allow any objection.
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STANDING ORDER FOR CIVIL TRIALS 9
1 The first time counsel reads a deposition, counsel must state the deponent’s name, the name of
2 the lawyer asking the question, and whether the deposition was a Federal Rule of Civil Procedure
3 30(b)(6) deposition. The first time a deposition is read, the court will instruct the jury about
4 depositions.
5 When reading the passage, counsel must employ the following technique. Counsel must state,
6 “question” and then read the question exactly, and then state, “answer” and read the answer
7 exactly. This will allow the jury and court reporter to follow who said what at the deposition.
8 Opposing counsel may ask to read additional testimony necessary to complete the context. It is not
9 necessary to ask, “didn’t you say XYZ in your deposition” to lay a foundation.
10 3.7 Use of Depositions of Party-Opponents
11 Subject to Rule 403, a party-opponent’s depositions may be used for “any purpose” and may
12 be read into the record at any time (with no need to contradict a witness and regardless of the
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13 witness currently testifying). For example, a short party deposition excerpt may be used as
14 foundation for questions for a different witness on the stand.
15 3.8 Use of Depositions for Witnesses Appearing Only by Deposition
16 When the packet (see above for procedures to assemble deposition packets) is read to the jury,
17 the examiner must read the questions (and any relevant colloquy) from the lectern while a
18 colleague sits in the witness stand and reads the answers. While reading the deposition, the reader
19 and “witness” must refrain from undue emphasis or dramatization. If a read-in is short, a single
20 attorney can read it all, being careful to say “question” and “answer” for the court reporter’s and
21 jury’s comprehension. Exhibits may be projected onto the screen as they are referenced. Court
22 reporters do not transcribe video excerpts so counsel must file an exact copy of what was shown.
23 3.9 Exhibits
24 At the end of each day, counsel must confer with each other and with the deputy clerk to
25 confirm what exhibits are in evidence and any limitations on their use. Counsel must bring any
26 differences to the court’s attention. Similarly, before closing argument, counsel must confer with
27 each other and the deputy clerk to finalize the exhibits and prepare any final exhibit list. That list
28 may include a brief non-argumentative description of the exhibit to help the jury access the
STANDING ORDER FOR CIVIL TRIALS 10
1 exhibits. The final exhibits must be provided on a thumb drive before closing argument so that
2 they can be loaded onto the jury laptop for deliberations.
3 3.10 Stipulations
4 Counsel must read all stipulations to the jury for them to be part of the record.
5 3.11 Objections
6 Counsel must stand when making objections, give only the legal basis (“objection, calls for
7 speculation” or “objection, hearsay”).
8 3.12 Sidebar Conferences
9 Side-bar conferences are discouraged. If matters must be discussed outside the jury’s presence,
10 then counsel should raise them at the beginning or end of the day or while the jury is on break.
11 3.13 Charging Conference
12 Before the close of evidence, the court will provide draft final jury instructions to the parties
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13 and allow a reasonable time for review. Then, the court will hold one or more charging
14 conferences to address the instructions. The parties must renew any specific instruction request —
15 including those requested pretrial — at the conference or it will be deemed waived. For example,
16 if a party wants to request an instruction that the court omitted from its draft instructions, the party
17 must re-request it at the charging conference or the request will be deemed waived or abandoned.
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19 4. Additional Procedures for Bench Trials
20 The parties must comply with the above procedures, unless they apply only to jury trials (e.g.,
21 instructions and verdict forms). If a case has claims for the jury and claims for the court, then all
22 claims are tried at the same time.
23 The parties must file any stipulated facts and conclusions of law no later than sixty-three days
24 before the final pretrial conference. Then, the parties’ briefs must be sequential so that the party
25 with the burden of proof goes first. The plaintiff’s opening brief (up to twenty-five pages) is due
26 forty-nine days before the pretrial conference. The defendant’s opposition and brief on affirmative
27 defenses and any counterclaims (up to twenty-five pages) is due fourteen days later. The plaintiff’s
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STANDING ORDER FOR CIVIL TRIALS 11
1 reply and opposition (up to twenty-five pages) is due fourteen days later. The defendant’s reply
2 (up to fifteen pages) is due seven days later.
3 Proposed findings of fact must be supported by citations to the evidence that will be offered at
4 trial. Conclusions of law that rely on substantive-law instructions from the Ninth Circuit Manual
5 of Model Jury Instructions, CACI, or other model instructions must be cited, any modifications
6 must be identified, and copies of the model and blacklined modified instructions must be attached.
7 All conclusions of law — disputed or undisputed — must be supported by citation (including pin
8 cites) in the format used by the Ninth Circuit Manual.
9 IT IS SO ORDERED.
10 Dated: June 16, 2025 ______________________________________
LAUREL BEELER
11 United States Magistrate Judge
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STANDING ORDER FOR CIVIL TRIALS 12
