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SUPERIOR COURT OF CALIFORNIA,
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COUNTY OF SACRAMENTO
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Aleeza Khan
11 CASE NO: 34-2022-00319499
Plaintiffs,
12 NOTICE OF CASE MANAGEMENT
13 V. CONFERENCE AND ORDERS RE:
COMPLEX CASE MANAGEMENT
14 Nextgen Laboratories PROCEDURES
15 Defendants.
Complex Civil Dept.: 25
16 Judge: Jill Talley
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19 THIS NOTICE SHALL BE SERVED BY PLAINTIFF'S COUNSEL ON ALL
20 OTHER PARTIES. ANY PARTY WHO HEREAFTER SERVES SUMMONS IN THIS
21 ACTION UPON A NEW PARTY SHALL SERVE A COPY OF THIS NOTICE ON THE
22 NEW PARTY ALONG WITH THE SUMMONS AND COMPLAINT OR CROSS-
23 COMPLAINT.
24 1. Pursuant to the Presiding Judge's Nofice and Order of Complex Case
25 Determination, the above-referenced case has been designated as complex, assigned
26 to this department for complex case management, and pre-assigned to this department
27 for trial. This is an all-purpose assignment under California Rule of Court 3.734, such
41 that law and mofion matters, motions for consolidation, severance, bifurcation,
1
1 inten/enfion and to confinue trial shall be heard in this department unless othenwise
2 directed by this Court. Other motions i^eferenced in Local Rule 1.05 shall also be heard
3 in this department.
4 2. The Court orders all parties to appear for a Case Management
5 Conference on 2/9/2023, at 1:30:00 PM, in Department 25.
6 Please check the Civil Tentative Ruling search at www.saccourt.ca.gov
7 prior to the above hearing date to confirm appearances and/or any updates
8 (including updates to the hearing date/time).
9 Effective January 3, 2022, civil hearings will be open for in-person appearances.
10 However, the Court will continue to allow and strongly encourages all
11 parties to appear remotely, subject to Code of Civil Procedure § 367.75 whenever
12 possible. Additional information can be found at:
13 https://www.saccourt.ca.gov/civil/docs/pn-civil-remote-andin-person-
14 proceedings-effective-mondav-ianuarv-3-2022.pdf.
15 To join by Zoom link - https://saccourt-ca-gov.zoomgov.com/my/sscdept25
16 To join by Room: Dept25a
17 To join by phone dial (833) 568-8864 ID 16113421868.
18
19 3. The Court orders the parties to meet and confer in good faith at least 30
20 calendar days prior to all CMCs pursuant to California Rules of Court, Rule
21 3.724. The parties shall discuss the issues oufiined in Rule 3.724 and 3.750,
22 with particular attenfion to the following, as applicable:
23 a. Generally, what facts and issues are in dispute;
24 b. Pleading and service issues, including:
25 i. Whether all parties named in the complaint or cross-complaint
26 have been served, have appeared, or have been dismissed;
27 ii. Whether any additional parties may be added or the pleadings
41 may be amended;
1 iii. The deadline for thefilingof any remaining pleadings and
2 service of any additional parties;
3 c. The impact of any related cases and/or other matters (e.g. bankruptcy
4 proceedings), and whether severance, consolidafion, or coordinafion
5 with other actions is desirable;
6 d. The possibility of eariy settlement, including:
7 i. Whether private mediation is appropriate;
8 ii. Proposed mediators and available dates for mediafion; and
9 iii. Whether the parties agree to infonnally exchange discovery in
10 advance of mediafion;
11 e. Discovery issues, including, for example:
12 i. The general subjects on which discovery may be needed;
13 ii. A proposed discovery schedule that avoids duplicafion;
14 iii. Whether discovery should be stayed unfil all parties are brought
15 into the case (or for any other reason);
16 iv. Whether discovery should be conducted in phases or be limited
17 to or focused on particular issues;
18 V. Any issues related to preserving discoverable information and
19 the need for presen/ation notices;
20 vi. Any issues about disclosure, discovery, or preservafion of
21 electronically stored information, including the form or forms in
22 which it should be produced and possible allocation of costs, as
23 well as whether it may be appropriate to adopt a Protocol for
24 Discovery of Electronically Stored Information
25 vii. Any issues related to privacy, confidentiality, and/or trade
26 secrets, and whether to stipulate to a Protective Order to
27 facilitate the exchange of information and documents that may
41 be subject to these limitafions;
1 viii. Any issues about claims of privilege;
2 ix. Anficipated depositions and the subjects to be addressed in
3 each deposifion;
4 X. The method for exchange of documents and whether to
5 establish an electronic document depository;
6 xi. Any anticipated discovery motions;
7 f. The schedule for motion practice and trial, including anticipated dates
8 for:
9 i. Discovery mofions
10 ii. Dispositive mofions
11 iii. Class certification
12 ' iv. Settlement conference
13 V. Pre-trial conference
14 vi. Trial
15 g. Issues related to counsel, including:
16 i. Whether to appoint liaison or lead counsel;
17 ii. Whether to establish a case-based Web site and other means to
18 provide a current master list of addresses and telephone
19 numbers of counsel;
20 h. Whether the parties have consented to electronic service in this action
21 pursuant to California Code of Civil Procedure secfion 1010.6.
22 i. Whether a special master should be appointed and the purposes for
23 such appointment; and
24 j. Any other relevant case management issues.
25 4. A joint Case Management Conference Statement must befiledno later
26 than 15 calendar days prior to all CMCs. All matters discussed during the meet-and-
27 confer session shall be itemized and reported in the joint CMC Statement. Individual
41 statements will not be considered. Do not use Judicial Council Fonn CM-110 for the
1 joint CMC Statement. The purpose of the joint statement is to require counsel to confer.
2 It shows the Court that the parties have been in direct communicafion. The CMC
3 Statement shall include a declaration that the parties have met and conferred in good
4 faith on all appropriate subjects set forth under #3. If no meet-and-confer session
5 occurs, or if some of the issues under #3 are not discussed, the parties shall provide the
6 Court with a brief and reasonable explanafion.
7 5. CMC Statements shall be filed at the Civil Filing Counter located in the
8 Gordon D. Schaber County Courthouse, 720 9th Street, Room 102, Sacramento, CA
9 95814 or placed in a Gordon D. Schaber Civil Drop Box, with courtesy copies delivered
10 directly to Department 25 via email at dept25@saccourt.ca.gov.
11 6. Counsel for each party and each self-represented party who appears at
12 the CMC shall be thoroughly familiar with the case, and must be prepared to discuss
13 and commit to the party's posifion on the issues oufiined in #3 above.
14 7. Should the parties sfipulate and request a continuance of the CMC, they
15 shall make the request in their CMC Statement with the heading "CONTINUANCE
16 REQUESTED" on the front page. They shall oufiine the reasons for the request and
17 provide at least three agreeable Thursdays at 1:30 p.m. for the continued CMC. The
18 Court may or may not approve the stipulated request. If the Court grants the request,
19 the order will be refiected in the Court's tentative ruling. Alternatively, if the parties are
20 seeking an eariier ruling on the request for confinuance, they may submit a separate
21 Sfipulation and Proposed Order to the Court for its considerafion.
22 8. Tentative Rulings: The Court may or may not issue a tentafive ruling prior
23 to the scheduled hearing. Counsel shall check the Court's tentative rulings after 2:00
24 p.m. the court day prior to the scheduled hearing. Tentative rulings are posted on the
25 Court's website at www.saccourt.ca.qov. It is imperative for the parties to review the
26 tentative ruling in its entirety. The ruling may include important updates for the
27 parties, including possible updates to the date/fime of the CMC. The parties shall be
41 prepared to address all issues oufiined in the Court's ruling. If no tentative ruling is
1 posted, the hearing will proceed as scheduled. If a tentative ruling is posted and the
2 Court indicates that no appearance is required, the ruling shall become thefinalorder of
3 the Court, and no hearing shall occur unless the party seeking a hearing contacts the
4 department clerk by 4:00 p.m. on the court day preceding the hearing and advises the
5 clerk that they have provided nofice to all other parties. In such event, the hearing will
6 proceed as scheduled or as othenwise indicated by the Court in its tentative ruling.
7 9. Law and Motion: Pursuant to Local Rule 2.30, et seq., this case is
8 assigned to the department for all purposes. This department shall hear all law and
9 motion matters.
10 10. Reserving Hearing Dates. Hearing dates for all mofions must be reserved
11 in advance by emailing this department at dept25@saccourt.ca.gov. The requesfing
12 party shall meet and confer with all other parties to identify mutually agreeable dates for
13 the hearing before emailing this department with the hearing reservafion request. The
14 requesfing party shall copy all parties on the email to the Court. The email shall include
15 the following information: (1) the case number; (2) the type of mofion; and (3) at least
16 three Friday dates at 9:00 a.m. that work for all parties. A mofionfiledwithout a
17 reserved hearing date will be rejected.
18 11. Informal Discovery Conferences under Code of Civil Procedure secfion
19 2016.080 ("IDCs"): The Court strongly encourages parties to request an IDC with the
20 Court before reserving a hearing date for any discovery motion. The Court requires
21 civility and cooperafion in scheduling an IDC, including by agreeing to extend thefimeto
22 file a discovery mofion to allow time for an IDC. If a discovery mofion isfiledwithout
23 scheduling an IDC, it is likely that the Court will order one before hearing the mofion.
24 During an IDC, the Court will meet informally with the parties to try to resolve the
25 dispute. The process is designed to benefit all parties by saving costs and avoiding
26 delay. The following procedures apply to IDCs:
27 a. Counsel must complete all meet and confer obligafions either in
41 person, by phone, or by video conference at least one week before
1 scheduling a discovery conference.
2 b. To schedule an IDC, the prospecfive moving party must contact the
3 department clerk by email at dept25@saccourt.ca.gov. The email shall
4 copy all parties and include a meet-and-confer declaration as
5 described in Code of Civil Procedure section 2016.040. The
6 prospective party, after having conferred with the opposing party, shall
7 advise the Court of the court dates and fimes in the next 30 calendar
8 days when all concerned parties are available for a Zoom
9 conference. Counsel and/or parties with full authority to resolve the
10 discovery issue(s) must appear at the IDC unless excused by the
11 Court. The Court will issue a minute order advising counsel of the fime
12 and date of the Zoom conference.
13 c. At least five court days before the IDC, the requesfing party must file
14 and serve an IDC declaration limited to three pages. The declaration
15 must include a brief summary of the disputed discovery. At least two
16 court days before the IDC, the responding party shall file and serve an
17 IDC response limited to three pages briefly summarizing the basis of
18 its posifion. The parties shall email a courtesy copy of their respective
19 IDC submissions to the assigned department on the same day their
20 submission isfiledand sen/ed.
21 d. No additional documents shall be attached to any IDC statement or
22 response except a privilege log. Where privilege is a basis for refusal
23 to produce documents, a privilege log must be provided.
24 e. Unless othenwise indicated by the Court, the minute order granting an
25 IDC will toll the deadline forfilingthe discovery mofion. The deadline
26 shall be tolled unfil such fime as the Court issues a direcfion or order
27 setting a new deadline forfilinga discovery mofion.
41 f. The Court will not tolerate efforts by the parties to rely on IDCs to
1 resolve every minor discovery dispute that should othenwise be
2 resolved through good faith meet and confer efforts. Should any party
3 abuse the IDC process, the Court will consider issuing sanctions under
4 California Code of Civil Procedure secfion 2023.010, et seq.
5 12. Discovery Disputes during Depositions: If a dispute arises during a
6 deposifion that requires judicial input, the parties are to contact the Court immediately
7 via the department telephone number at (916) 874-8727. If the parties cannot reach
8 Judge Talley through Dept. 25, the parties may contact Dept. 28 at (916) 874-6695.
9 .13. Filings: Allfilingsshall be filed at the Civil Filing Counter located in the
10 Gordon D. Schaber County Courthouse, 720 9th Street, Room 102, Sacramento, CA
11 95814 or placed in a Gordon D. Schaber Civil Drop Box, with courtesy copies delivered
12 directly to Department 25 via email at dept25@saccourt.ca.gov.
13 14. Typical Case Progress:
14 a. After the initial CMC or a subsequent CMC, the Court may or may not
15 issue a formal Case Management Order ("CMO"). In lieu of a formal
16 CMO, the Court may issue minute orders after CMCs addressing case
17 management topics. The breadth of such orders may vary depending
18 upon factors such as the complexity of the case and other
19 circumstances. The Court may issue subsequent CMOs potentially
20 addressing topics such as discovery cut-offs, phased discovery,
21 disclosure dates,fimingof private mediafion, fiming of class
22 certification motions, etc. In some cases, CMOs may be proposed by
23 an appointed special master or referee with case management
24 authority.
25 b. Pursuant to the Presiding Judge's Nofice and Order of Complex Case
26 Determinafion, this Court is the trial department for this case. This
27 Court remains the trial court unless subsequenfiy ordered othenwise.
41 In rare instances, a case may be transferred to Department 47 for
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1 assignment to a different trial department if this Court has scheduling
2 conflicts due to another trial or othenwise is unable to proceed with trial.
3 c. The Court will schedule a Trial Setting Conference at which fime a
4 precise trial date shall be set in this department. The Court will issue a
5 Complex Trial Setting Order ("TSO") which shall set the Mandatory
6 Settlement Conference in Department 59, a Final Status Conference, a
7 Final Pre-Trial Conference, and the trial date. The TSO shall also
8 address deadlines for trial-related tasks and filings, including motions
9 in limine, witness and exhibit lists, proposed jury instrucfions, jury
10 quesfionnaires, etc.
11 15. The following interim orders shall be in effect:
12 a. Plaintiff(s) shall diligently locate and serve each defendant. It is the
13 Court's intenfion, by this order, that all parties shall be sen/ed in
14 sufficient fime to have made an appearance within the fime allowed
15 under law prior to attending the first CMC.
16 b. Counsel shall confinuously ensure that they have no legal confiicts of
17 interest as to any present or anticipated parties so that counsel may
18 participate fully in the CMC and this case.
19 16. The Court strongly encourages the parties to engage in early and
20 meaningful alternative dispute resolufion.
21 17. Uncivil or unprofessional behavior will not be tolerated. The Court expects
22 the parties to be familiar with and follow the California Guidelines of Civility and
23 Professionalism (available at https://www.saccourt.ca.qov/local-rules/docs/quidelines-
24 civilitv-professionalism.pdfi and the Sacramento County Bar Association Standards of
25 Professional Conduct (available at https://www.saccourt.ca.gov/local-
26 rules/docs/standards-professional-conduct.pdf).
27 18. The Court expects parties to resolve all disputes regarding scheduling or
41 fime extensions without the necessity of Court involvement.
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3 IT IS SO ORDERED.
4 DATED:
5 HON. JILLTALLE
JUDGE OF THE SUPERIOR COURT
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2 CERTIFICATE OF SERVICE BY MAILING
( C C P . Sec. 1013a(3))
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1, the Clerk of the Superior Court of California, County of Sacramento, certify that
4 1 am not a party to this cause, and on the date shown below 1 served the foregoing
WOr/C£ OF CASE MANAGEMENT CONFERENCE AND COMPLEX CASE
MANAGEMENT PROCEDURES by depositing true copies thereof, enclosed in
separate, sealed envelopes with the postage fully prepaid, in the United States Mail at
Sacramento, California, each of which envelopes was addressed respectively to the
persons and addresses shown below:
g Gary Basham
Basham Law Group
9 8801 Folsom Blvd. Ste: 280
Sacramento, CA 95826
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1, the undersigned deputy clerk, declare under penalty of perjury that the
13 foregoing is true and correct.
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I \ - I. bnaqqix , uourtroom uierK
^^ Dated: *\'^\ Superior Court of California, County of
16 Sacramento
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Preview
1 2 3 4 5 6 7 SUPERIOR COURT OF CALIFORNIA, 8 COUNTY OF SACRAMENTO 9 10 Aleeza Khan 11 CASE NO: 34-2022-00319499 Plaintiffs, 12 NOTICE OF CASE MANAGEMENT 13 V. CONFERENCE AND ORDERS RE: COMPLEX CASE MANAGEMENT 14 Nextgen Laboratories PROCEDURES 15 Defendants. Complex Civil Dept.: 25 16 Judge: Jill Talley 17 18 19 THIS NOTICE SHALL BE SERVED BY PLAINTIFF'S COUNSEL ON ALL 20 OTHER PARTIES. ANY PARTY WHO HEREAFTER SERVES SUMMONS IN THIS 21 ACTION UPON A NEW PARTY SHALL SERVE A COPY OF THIS NOTICE ON THE 22 NEW PARTY ALONG WITH THE SUMMONS AND COMPLAINT OR CROSS- 23 COMPLAINT. 24 1. Pursuant to the Presiding Judge's Nofice and Order of Complex Case 25 Determination, the above-referenced case has been designated as complex, assigned 26 to this department for complex case management, and pre-assigned to this department 27 for trial. This is an all-purpose assignment under California Rule of Court 3.734, such 41 that law and mofion matters, motions for consolidation, severance, bifurcation, 1 1 inten/enfion and to confinue trial shall be heard in this department unless othenwise 2 directed by this Court. Other motions i^eferenced in Local Rule 1.05 shall also be heard 3 in this department. 4 2. The Court orders all parties to appear for a Case Management 5 Conference on 2/9/2023, at 1:30:00 PM, in Department 25. 6 Please check the Civil Tentative Ruling search at www.saccourt.ca.gov 7 prior to the above hearing date to confirm appearances and/or any updates 8 (including updates to the hearing date/time). 9 Effective January 3, 2022, civil hearings will be open for in-person appearances. 10 However, the Court will continue to allow and strongly encourages all 11 parties to appear remotely, subject to Code of Civil Procedure § 367.75 whenever 12 possible. Additional information can be found at: 13 https://www.saccourt.ca.gov/civil/docs/pn-civil-remote-andin-person- 14 proceedings-effective-mondav-ianuarv-3-2022.pdf. 15 To join by Zoom link - https://saccourt-ca-gov.zoomgov.com/my/sscdept25 16 To join by Room: Dept25a 17 To join by phone dial (833) 568-8864 ID 16113421868. 18 19 3. The Court orders the parties to meet and confer in good faith at least 30 20 calendar days prior to all CMCs pursuant to California Rules of Court, Rule 21 3.724. The parties shall discuss the issues oufiined in Rule 3.724 and 3.750, 22 with particular attenfion to the following, as applicable: 23 a. Generally, what facts and issues are in dispute; 24 b. Pleading and service issues, including: 25 i. Whether all parties named in the complaint or cross-complaint 26 have been served, have appeared, or have been dismissed; 27 ii. Whether any additional parties may be added or the pleadings 41 may be amended; 1 iii. The deadline for thefilingof any remaining pleadings and 2 service of any additional parties; 3 c. The impact of any related cases and/or other matters (e.g. bankruptcy 4 proceedings), and whether severance, consolidafion, or coordinafion 5 with other actions is desirable; 6 d. The possibility of eariy settlement, including: 7 i. Whether private mediation is appropriate; 8 ii. Proposed mediators and available dates for mediafion; and 9 iii. Whether the parties agree to infonnally exchange discovery in 10 advance of mediafion; 11 e. Discovery issues, including, for example: 12 i. The general subjects on which discovery may be needed; 13 ii. A proposed discovery schedule that avoids duplicafion; 14 iii. Whether discovery should be stayed unfil all parties are brought 15 into the case (or for any other reason); 16 iv. Whether discovery should be conducted in phases or be limited 17 to or focused on particular issues; 18 V. Any issues related to preserving discoverable information and 19 the need for presen/ation notices; 20 vi. Any issues about disclosure, discovery, or preservafion of 21 electronically stored information, including the form or forms in 22 which it should be produced and possible allocation of costs, as 23 well as whether it may be appropriate to adopt a Protocol for 24 Discovery of Electronically Stored Information 25 vii. Any issues related to privacy, confidentiality, and/or trade 26 secrets, and whether to stipulate to a Protective Order to 27 facilitate the exchange of information and documents that may 41 be subject to these limitafions; 1 viii. Any issues about claims of privilege; 2 ix. Anficipated depositions and the subjects to be addressed in 3 each deposifion; 4 X. The method for exchange of documents and whether to 5 establish an electronic document depository; 6 xi. Any anticipated discovery motions; 7 f. The schedule for motion practice and trial, including anticipated dates 8 for: 9 i. Discovery mofions 10 ii. Dispositive mofions 11 iii. Class certification 12 ' iv. Settlement conference 13 V. Pre-trial conference 14 vi. Trial 15 g. Issues related to counsel, including: 16 i. Whether to appoint liaison or lead counsel; 17 ii. Whether to establish a case-based Web site and other means to 18 provide a current master list of addresses and telephone 19 numbers of counsel; 20 h. Whether the parties have consented to electronic service in this action 21 pursuant to California Code of Civil Procedure secfion 1010.6. 22 i. Whether a special master should be appointed and the purposes for 23 such appointment; and 24 j. Any other relevant case management issues. 25 4. A joint Case Management Conference Statement must befiledno later 26 than 15 calendar days prior to all CMCs. All matters discussed during the meet-and- 27 confer session shall be itemized and reported in the joint CMC Statement. Individual 41 statements will not be considered. Do not use Judicial Council Fonn CM-110 for the 1 joint CMC Statement. The purpose of the joint statement is to require counsel to confer. 2 It shows the Court that the parties have been in direct communicafion. The CMC 3 Statement shall include a declaration that the parties have met and conferred in good 4 faith on all appropriate subjects set forth under #3. If no meet-and-confer session 5 occurs, or if some of the issues under #3 are not discussed, the parties shall provide the 6 Court with a brief and reasonable explanafion. 7 5. CMC Statements shall be filed at the Civil Filing Counter located in the 8 Gordon D. Schaber County Courthouse, 720 9th Street, Room 102, Sacramento, CA 9 95814 or placed in a Gordon D. Schaber Civil Drop Box, with courtesy copies delivered 10 directly to Department 25 via email at dept25@saccourt.ca.gov. 11 6. Counsel for each party and each self-represented party who appears at 12 the CMC shall be thoroughly familiar with the case, and must be prepared to discuss 13 and commit to the party's posifion on the issues oufiined in #3 above. 14 7. Should the parties sfipulate and request a continuance of the CMC, they 15 shall make the request in their CMC Statement with the heading "CONTINUANCE 16 REQUESTED" on the front page. They shall oufiine the reasons for the request and 17 provide at least three agreeable Thursdays at 1:30 p.m. for the continued CMC. The 18 Court may or may not approve the stipulated request. If the Court grants the request, 19 the order will be refiected in the Court's tentative ruling. Alternatively, if the parties are 20 seeking an eariier ruling on the request for confinuance, they may submit a separate 21 Sfipulation and Proposed Order to the Court for its considerafion. 22 8. Tentative Rulings: The Court may or may not issue a tentafive ruling prior 23 to the scheduled hearing. Counsel shall check the Court's tentative rulings after 2:00 24 p.m. the court day prior to the scheduled hearing. Tentative rulings are posted on the 25 Court's website at www.saccourt.ca.qov. It is imperative for the parties to review the 26 tentative ruling in its entirety. The ruling may include important updates for the 27 parties, including possible updates to the date/fime of the CMC. The parties shall be 41 prepared to address all issues oufiined in the Court's ruling. If no tentative ruling is 1 posted, the hearing will proceed as scheduled. If a tentative ruling is posted and the 2 Court indicates that no appearance is required, the ruling shall become thefinalorder of 3 the Court, and no hearing shall occur unless the party seeking a hearing contacts the 4 department clerk by 4:00 p.m. on the court day preceding the hearing and advises the 5 clerk that they have provided nofice to all other parties. In such event, the hearing will 6 proceed as scheduled or as othenwise indicated by the Court in its tentative ruling. 7 9. Law and Motion: Pursuant to Local Rule 2.30, et seq., this case is 8 assigned to the department for all purposes. This department shall hear all law and 9 motion matters. 10 10. Reserving Hearing Dates. Hearing dates for all mofions must be reserved 11 in advance by emailing this department at dept25@saccourt.ca.gov. The requesfing 12 party shall meet and confer with all other parties to identify mutually agreeable dates for 13 the hearing before emailing this department with the hearing reservafion request. The 14 requesfing party shall copy all parties on the email to the Court. The email shall include 15 the following information: (1) the case number; (2) the type of mofion; and (3) at least 16 three Friday dates at 9:00 a.m. that work for all parties. A mofionfiledwithout a 17 reserved hearing date will be rejected. 18 11. Informal Discovery Conferences under Code of Civil Procedure secfion 19 2016.080 ("IDCs"): The Court strongly encourages parties to request an IDC with the 20 Court before reserving a hearing date for any discovery motion. The Court requires 21 civility and cooperafion in scheduling an IDC, including by agreeing to extend thefimeto 22 file a discovery mofion to allow time for an IDC. If a discovery mofion isfiledwithout 23 scheduling an IDC, it is likely that the Court will order one before hearing the mofion. 24 During an IDC, the Court will meet informally with the parties to try to resolve the 25 dispute. The process is designed to benefit all parties by saving costs and avoiding 26 delay. The following procedures apply to IDCs: 27 a. Counsel must complete all meet and confer obligafions either in 41 person, by phone, or by video conference at least one week before 1 scheduling a discovery conference. 2 b. To schedule an IDC, the prospecfive moving party must contact the 3 department clerk by email at dept25@saccourt.ca.gov. The email shall 4 copy all parties and include a meet-and-confer declaration as 5 described in Code of Civil Procedure section 2016.040. The 6 prospective party, after having conferred with the opposing party, shall 7 advise the Court of the court dates and fimes in the next 30 calendar 8 days when all concerned parties are available for a Zoom 9 conference. Counsel and/or parties with full authority to resolve the 10 discovery issue(s) must appear at the IDC unless excused by the 11 Court. The Court will issue a minute order advising counsel of the fime 12 and date of the Zoom conference. 13 c. At least five court days before the IDC, the requesfing party must file 14 and serve an IDC declaration limited to three pages. The declaration 15 must include a brief summary of the disputed discovery. At least two 16 court days before the IDC, the responding party shall file and serve an 17 IDC response limited to three pages briefly summarizing the basis of 18 its posifion. The parties shall email a courtesy copy of their respective 19 IDC submissions to the assigned department on the same day their 20 submission isfiledand sen/ed. 21 d. No additional documents shall be attached to any IDC statement or 22 response except a privilege log. Where privilege is a basis for refusal 23 to produce documents, a privilege log must be provided. 24 e. Unless othenwise indicated by the Court, the minute order granting an 25 IDC will toll the deadline forfilingthe discovery mofion. The deadline 26 shall be tolled unfil such fime as the Court issues a direcfion or order 27 setting a new deadline forfilinga discovery mofion. 41 f. The Court will not tolerate efforts by the parties to rely on IDCs to 1 resolve every minor discovery dispute that should othenwise be 2 resolved through good faith meet and confer efforts. Should any party 3 abuse the IDC process, the Court will consider issuing sanctions under 4 California Code of Civil Procedure secfion 2023.010, et seq. 5 12. Discovery Disputes during Depositions: If a dispute arises during a 6 deposifion that requires judicial input, the parties are to contact the Court immediately 7 via the department telephone number at (916) 874-8727. If the parties cannot reach 8 Judge Talley through Dept. 25, the parties may contact Dept. 28 at (916) 874-6695. 9 .13. Filings: Allfilingsshall be filed at the Civil Filing Counter located in the 10 Gordon D. Schaber County Courthouse, 720 9th Street, Room 102, Sacramento, CA 11 95814 or placed in a Gordon D. Schaber Civil Drop Box, with courtesy copies delivered 12 directly to Department 25 via email at dept25@saccourt.ca.gov. 13 14. Typical Case Progress: 14 a. After the initial CMC or a subsequent CMC, the Court may or may not 15 issue a formal Case Management Order ("CMO"). In lieu of a formal 16 CMO, the Court may issue minute orders after CMCs addressing case 17 management topics. The breadth of such orders may vary depending 18 upon factors such as the complexity of the case and other 19 circumstances. The Court may issue subsequent CMOs potentially 20 addressing topics such as discovery cut-offs, phased discovery, 21 disclosure dates,fimingof private mediafion, fiming of class 22 certification motions, etc. In some cases, CMOs may be proposed by 23 an appointed special master or referee with case management 24 authority. 25 b. Pursuant to the Presiding Judge's Nofice and Order of Complex Case 26 Determinafion, this Court is the trial department for this case. This 27 Court remains the trial court unless subsequenfiy ordered othenwise. 41 In rare instances, a case may be transferred to Department 47 for 8 1 assignment to a different trial department if this Court has scheduling 2 conflicts due to another trial or othenwise is unable to proceed with trial. 3 c. The Court will schedule a Trial Setting Conference at which fime a 4 precise trial date shall be set in this department. The Court will issue a 5 Complex Trial Setting Order ("TSO") which shall set the Mandatory 6 Settlement Conference in Department 59, a Final Status Conference, a 7 Final Pre-Trial Conference, and the trial date. The TSO shall also 8 address deadlines for trial-related tasks and filings, including motions 9 in limine, witness and exhibit lists, proposed jury instrucfions, jury 10 quesfionnaires, etc. 11 15. The following interim orders shall be in effect: 12 a. Plaintiff(s) shall diligently locate and serve each defendant. It is the 13 Court's intenfion, by this order, that all parties shall be sen/ed in 14 sufficient fime to have made an appearance within the fime allowed 15 under law prior to attending the first CMC. 16 b. Counsel shall confinuously ensure that they have no legal confiicts of 17 interest as to any present or anticipated parties so that counsel may 18 participate fully in the CMC and this case. 19 16. The Court strongly encourages the parties to engage in early and 20 meaningful alternative dispute resolufion. 21 17. Uncivil or unprofessional behavior will not be tolerated. The Court expects 22 the parties to be familiar with and follow the California Guidelines of Civility and 23 Professionalism (available at https://www.saccourt.ca.qov/local-rules/docs/quidelines- 24 civilitv-professionalism.pdfi and the Sacramento County Bar Association Standards of 25 Professional Conduct (available at https://www.saccourt.ca.gov/local- 26 rules/docs/standards-professional-conduct.pdf). 27 18. The Court expects parties to resolve all disputes regarding scheduling or 41 fime extensions without the necessity of Court involvement. 1 2 3 IT IS SO ORDERED. 4 DATED: 5 HON. JILLTALLE JUDGE OF THE SUPERIOR COURT 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 41 10 1 2 CERTIFICATE OF SERVICE BY MAILING ( C C P . Sec. 1013a(3)) 3 1, the Clerk of the Superior Court of California, County of Sacramento, certify that 4 1 am not a party to this cause, and on the date shown below 1 served the foregoing WOr/C£ OF CASE MANAGEMENT CONFERENCE AND COMPLEX CASE MANAGEMENT PROCEDURES by depositing true copies thereof, enclosed in separate, sealed envelopes with the postage fully prepaid, in the United States Mail at Sacramento, California, each of which envelopes was addressed respectively to the persons and addresses shown below: g Gary Basham Basham Law Group 9 8801 Folsom Blvd. Ste: 280 Sacramento, CA 95826 10 11 12 1, the undersigned deputy clerk, declare under penalty of perjury that the 13 foregoing is true and correct. 14 I \ - I. bnaqqix , uourtroom uierK ^^ Dated: *\'^\ Superior Court of California, County of 16 Sacramento 17 18 19 20 21 22 23 24 25 26 27 41 11