Honorable Gail J. Standish

1. Discovery Motions:
   1. Generally.
      Discovery motions are to be scheduled before the Magistrate Judge unless otherwise ordered by the District Judge. The parties are advised to review the procedures and standing orders of the assigned District Judge before filing any discovery motion, as the District Judge’s order may set forth the Magistrate Judge’s jurisdiction over discovery disputes. While some District Judges permit the assigned Magistrate Judge to decide a motion and order relief after the discovery cutoff, others require that any discovery disputes be completely briefed, argued, decided, and any relief ordered by the Magistrate Judge completed prior to expiration of the discovery period. There are other variations as well.
   2. ​Briefing of Discovery Motions.
      Compliance with Local Civil Rule 37 is generally required; however, the Court dispenses with the joint stipulation requirement under Local Civil Rule 37-2 and instead requires parties to file traditional motions, opposition briefs, and replies pursuant to Local Civil Rules 6-1 and 7. The Court may take a motion under submission without oral argument. See Local Civil Rule 7-15. 
   3. Timing of Discovery Motions.
      Discovery motions shall be filed with the Clerk not later than twenty-eight days (28) before the date set for hearing.  See Local Civil Rule 6.  The parties are advised that any motion challenging the adequacy of responses to discovery must be heard sufficiently in advance of the discovery cut-off date to permit the responses to be obtained before that date if the motion is granted.  A party’s failure to have a discovery dispute heard sufficiently in advance of the discovery cutoff may result in denial of the motion as untimely.  
   4. Discovery Motion Practice.
        Unless otherwise directed by the Court, any discovery motion set for hearing must be set for a Monday at 3:00 p.m. and will be conducted via telephonic conference.  Counsel shall provide the names, telephone numbers and email addresses of counsel appearing at the hearing to the Court Clerk at the chambers email address​
      1. All discovery motions must set forth the existing discovery cutoff date and/or the discovery motion cutoff date in the caption. 
      2. Discovery motions filed within six weeks of the discovery cutoff date shall include an initial statement explaining whether the District Judge’s case management order specifies whether the discovery cutoff date (or the discovery motion cutoff date) is the last day for complete production of all discovery (including taking of depositions), to file discovery motions, or the last day to hear discovery motions.   A copy of the District Judge’s standing order regarding discovery as well as the presently controlling schedule set by the District Judge must be attached to the motion.
      3. No discovery motion may exceed 15 pages in length unless leave of Court is obtained in advance. 
      4. Any opposition may not exceed 15 pages in length unless leave of Court is obtained in advance.
      5. Any reply is limited to 5 pages in length.
      6. Unless otherwise ordered by the Court, if the Court continues the hearing date, the parties must still complete briefing as would be required pursuant to the original hearing date.
      7. The discovery motion must be timely or it will be stricken.  Check the discovery deadlines of the District Judge's case management order/civil jury trial order to ensure compliance with the deadline.
      8. Copies of all filed documents, including declarations, exhibits or any other attachment(s), must be emailed to the Court's chamber's email address at [email protected]. Also, copies of all documents, including exhibits must be submitted to chambers in a binder.
2. ​​Settlement Conferences: As part of her practice for settlement conferences, the Court holds a brief telephonic conference (pre-settlement conference telephone call) before the settlement conference has been scheduled. Parties should contact the CRD via email at [email protected] to set up this initial telephonic conference. Counsel shall also confer to select se​veral proposed dates for the actual settlement conference, which dates will be discussed during the initial call. In the email request to the CRD, counsel shall provide three mutually agreeable times for the initial conference call with the Court, of which at least two must be on different days, and all of which are no earlier than 10:00 a.m. Once the settlement conference has been scheduled, all settlement conference papers should be delivered directly to the magistrate judge’s chambers. In addition to mailed mandatory chambers courtesy copies, settlement conference papers may also be emailed to [email protected] if the total number of pages being emailed is 20 or less.
3. Ex Parte Applications: Strict compliance with Local Civil Rules 7-19 and 7-19.1 is required. An opposition should be served and filed within 24 hours of the electronic filing of the application.  However, if the 24-hour period would end on a Saturday, Sunday or legal holiday, the period continues to run until the same time on the next day that is not a Saturday, Sunday or legal holiday. Conformed paper copies of the filed application and any opposition should be delivered directly to chambers. Ex parte applications will ordinarily be decided on the papers without oral argument. The Court will notify the parties if it desires a hearing. Absent an emergency, ex parte applications are not an acceptable method of bringing a discovery dispute to the attention of the Court. Local Civil Rule 37-3. Ex parte applications must identify in the caption whether “OPPOSED” or “UNOPPOSED” and must also identify in the caption whether the relief being sought has been previously sought via ex parte application (e.g., “FIRST ex parte application for extension of time,” “SECOND ex parte application for extension of time”).
4. Continuances: To request to reschedule a hearing, conference, or other court proceeding, the parties should submit a signed stipulation and proposed order at least three court days prior to the scheduled hearing date. If opposing counsel will not agree to a continuance, the requesting party should file an ex parte application setting forth its and opposing counsel’s position. In addition, the parties should notify the CRD as soon as the need to reschedule a hearing is discovered.
5. Requests for Filing Extensions: Requests to extend any scheduled filing date (by either ex parte application or stipulation) shall be filed no later than three (3) court days prior to the scheduled date. Extensions are not allowed absent permission of the Court given on showing of good cause.
6. Stipulated Protective Orders.
   
   1. General Standard: Parties frequently file stipulated protective orders that do not satisfy Rule 26 of the Federal Rules of Civil Procedure, the Ninth Circuit’s standards for protective orders, or the Local Rules of this Court. For example, the Court may only enter a protective order upon a showing of good cause. Kamakana v. City and Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006) (parties must make a "particularized showing" under Rule 26(c)’s good cause requirement for court to enter protective order). In addition, the Court will not enter a protective order that provides for the automatic sealing of all confidential documents. If confidential material is included in any papers to be filed in Court, such papers shall be accompanied by an application, pursuant to Local Civil Rule 79-5.1, to file the papers—or the confidential portion thereof—under seal. Also, in the event of a dispute regarding the designation of confidential information, the procedure for obtaining a decision from the Court is that set forth in Local Civil Rule 37. Attached below is a model protective order that satisfies these and other requirements.
   2. Form of Protective Order and Proposed Order: It is mandatory that Parties submitting a stipulated protective order for the Court’s approval use the Court’s model protective order, attached below, to which they may propose limited modifications; the Court does not allow changes to the Duration section (4) of the protective order. When filing a stipulated protective order, the parties shall provide the Court via e-mail to [email protected] (link sends e-mail) the following:
      1. A Redlined version in PDF format comparing the original model and the filed stipulated protective order. The redlined version is only for the judge’s review and, therefore, shall not be filed; and
      2. a Proposed Order in Word format. The Word version should contain the attorneys' signatures and the full text of the stipulated protective order. Further, the protective order shall be on pleading paper, must not contain attorney names, addresses, etc. on the caption page, and should not contain a footer with the document name or other information, such as a watermark designation of the firm name, etc. in the margin.
7. Petitions for Guardian ad Litem: Parties should take note that Judge Standish will not approve a petition to appoint a Guardian ad Litem (“GAL”) if the proposed GAL is also a named plaintiff or party to the action. Such a situation presents the immediate appearance of, and potential for actual, conflict of interest. In addition, a separate Proposed Order Document must be submitted as a separate attachment to the petition for appointment of GAL.
8. Parties in Custody.
   1. Hearing Dates: If any party is in state or federal custody, the moving party must file the motion without requesting a hearing date. The Court will review the pleadings to determine whether a hearing is necessary.
   2. Ex Parte Applications: A party submitting an ex parte application need not provide a party in custody with oral notice prior to filing, but must make all reasonable efforts to provide notice as quickly as practicable consistent with Local Civil Rules 7-19 and 7-19.1. Any party relying on this policy must include in the application (1) that the party in custody is incarcerated, and (2) all steps that have or will be taken to provide the person in custody with prompt notice. Under Seal Documents (Civil and Criminal):
9. Civil and Criminal Under Seal Procedures.
   
   1. Civil Case Procedures: A party seeking to file materials under seal must file the Application, redacted document(s), proposed order, and Declaration with attached unredacted document(s) electronically via the Court’s CM/ECF system. Only the Application, redacted document(s) and proposed order will be viewable by the public. The Declaration with attached unredacted document(s) will not be viewable by the public and will be filed under seal. After electronically filing the necessary documents, the filing party will send to the Chambers e-mail address at ([email protected]) a PDF of all the document(s), along with a Microsoft Word version of the proposed order. The subject line of the e-mail must bear the case name and number, and include the phrase “REQUEST FOR UNDER SEAL FILING.”
      DO NOT deliver copies to the Judge’s drop box on the 12th floor, Roybal Building. If the Court grants the Application to file under seal, the CRD will docket the Order and counsel will be notified. It is the responsibility of the filing party to serve the other party(ies) as applicable with a copy of the filing party’s application, proposed order and redacted document(s). Relying on the Court’s CM/ECF system for service is no longer acceptable. The filing party shall file a proof of service within 24 hours verifying service of the required document(s) on the applicable party(ies). If the Court grants the Application, it will be the responsibility of the filing party to seal the document(s) on the Court’s CM/ECF system. Please review Local Rule 79-5.2.2 for full details regarding filing under seal.
   2. Criminal Case Procedures: Please follow the same procedures as referenced above.
10. In Camera Review: A party seeking to have the Court review document(s) in camera, must file a Request and proposed order via the Court’s CM/ECF system. The Request and proposed order will be viewable by the public. After electronically filing the Request and proposed order, the filing party shall send a PDF of the Request and proposed order, along with a Microsoft Word version of the proposed order to the Chambers e-mail address at ([email protected]). The subject line of the e-mail must bear the case name and number, and include the phrase “REQUEST FOR IN CAMERA REVIEW.”
    DO NOT deliver the document(s) to the Judge’s drop box on the 12th Floor, Roybal Building. If the Court grants the Request, the filing party will be instructed to deliver the document(s) directly to chambers on the 12th floor for review. Upon review, the Court may require the document(s) to be filed under seal. If so directed, the filing party shall follow the same instructions given when filing documents under seal. If the Court denies the Request, the filing party will be instructed to keep the document(s) until the full disposition of the case.
11. Telephonic Appearances: Any party who wishes to appear at a hearing by telephone shall make such a request at least two court days before the hearing. Telephonic appearances are not allowed absent permission of the Court given on showing of good cause.
12. Special Appearances: The Court does not permit special appearances. Counsel of record shall appear at all court proceedings.
13. Citation Format: When a party wishes to cite a case for which no reporter citation is available, the Court prefers that the party use a Westlaw citation (rather than a LEXIS citation) if one is available.
14. Hyperlinked Filings: In the internet research world, hyperlinks are a standard way of “drilling down” for more detail or specific information. Just as all web pages contain links to other pages, cases downloaded from legal research services such as Westlaw or Lexis contain links to the cases, statutes, articles, or other sources cited within the opinion. The links allow immediate access by the reader to these referenced materials. Attorneys can include links to cited law and CM/ECF filings in their documents filed in CM/ECF, adding another level of persuasion to their writing. Hyperlinks in briefs and other court filings provide quick, easy, and pinpoint access to particular sections of a case, or to specific filings in the court’s record. The attorney can thereby highlight the precise issue presented, and the specific evidence and controlling or persuasive law the court should consider.
    Hyperlinks in court filings are very beneficial for court chambers. Court submissions that include links to relevant case law and case filings are easy for chambers staff to review. The attorneys’ arguments can be immediately verified in the context of the relevant law. The judge or judicial clerk is able to read the text of the cited case law on one screen while reading the attorney’s brief on the other. And if a brief contains links to referenced exhibits, and even to specific pages within those exhibits, the judge or judicial clerk can access the relevant evidence without having to navigate through the CM/ECF record. Particularly when dealing with large and complex cases, links save chambers considerable time and effort. Links make it easy for the court to verify—and adopt—the positions taken by an advocate.
    Although not required, the Court strongly encourages the use of hyperlinks in filings. For technical assistance consult this District’s guide to hyperlinking, available at http://www.cacd.uscourts.gov/sites/default/files/documents/Hyperlinking_Attorneys_Word.pdf.
15. Tentative Rulings: If the Court determines that issuing a tentative ruling is appropriate, the ruling will be provided to counsel when counsel checks in with the CRD.
16. Calendar Conflicts: The parties are to advise the CRD in advance about any calendar conflict and attempt to stipulate to an alternative date and time with opposing counsel. The alternative date and time should be cleared in advance with the CRD.
17. Communication with the Court: Inquiries regarding the status of a motion, stipulation, or proposed order should be made by checking the docket. If the information is unavailable, the parties may contact the CRD via email. Also, please refer to Local Civil Rule 83-2.5. Counsel and the parties must not contact or communicate with the magistrate judge’s law clerks unless expressly authorized by the Court or the Court’s CRD, the Local Rules, or this Court’s rules. Similarly, counsel and the parties may communicate with chambers by means of the Court’s email address only as expressly authorized by the Court or the Court’s CRD, the Local Rules, or this Court’s rules. Letters to chambers are strictly forbidden and may lead to sanctions against the offending party.
18. Electronic Equipment: Counsel should contact the CRD regarding procedures for using or bringing electronic equipment into the courtroom.
19. Interpreters: It is the responsibility of the parties to obtain the services of an interpreter in a civil case if one is needed. If the government is the moving party, contact the CRD. All other parties may contact the Interpreter’s Section at 213-894-4599.
20. Law Enforcement Submissions: Federal law enforcement agents and the U.S. Attorney’s Office are encouraged to advise the CRD in advance of the anticipated submission of warrants, criminal complaints, and other applications for the Court’s review.
21. Employment Opportunities: For inquiries regarding law clerk positions, please visit https://oscar.uscourts.gov. For inquiries regarding extern positions, please communicate via letter to the magistrate judge.
22. Form of Proposed Orders: Proposed Orders must be on pleading paper and should not contain attorney names, addresses, etc. on the caption page, should not contain a footer with the document name or other information, and should not contain a watermark designation of the firm name, etc. in the margin.
23. Criminal E-Filing Pilot Project Requirements: Please follow the procedures set forth in accordance with General Order 19-01, Criminal Duty Matters Expanded Electronic Filing Pilot Project. Counsel are directed to email documents to: GJS_CrimDuty@cacd.uscourts.gov(link(link sends email).
24. Chambers copies must include the CM/ECF header showing that the instant documents for signature have been e-filed.
25. Conformed copies will only be given upon request and will be made using a copy brought by the agent. No copies wil be printed for conforming.
26. Failure to comply with the above requirements may result in a delay in processing

​​​​