Local Rule 2.30 governs the procedure for the determination of complex case designation. This rule should be read and followed carefully.


The Presiding Judge decides whether an action is complex within the meaning of California Rules of Court, Rule 3.400, subdivision (a), and whether it shall be assigned to a single judge for all purposes. Any party seeking a complex designation must complete, file, and serve a Certificate Re: Complex Case Designation. The certificate must include supporting information showing a reasonable basis for the complex case designation being sought. The Clerk of the Court will then set a Status Conference at which the Presiding Judge shall decide whether or not the action is complex.

If the Presiding Judge designates the action as complex and assigns it to the Complex Judge, counsel will be directed to contact the Complex Judge’s clerk to set a date for the initial Case Management Conference. The regular Case Management Conference date set upon commencement of the action will be vacated.

Model Stipulated Protective Orders.  For the ease of the parties and to assure compliance with the requirements of California Rules of Court, Rules 2.550 and 2.551, the Complex Court has adopted two model stipulated protective orders. If only one level of confidentiality is desired, the Stipulation and Protective Order Regarding Confidential Information (Single Level of Confidentiality) may be used. If there is a need to shield some confidential information from the parties, the Stipulation and Protective Order Regarding Confidential Information (Double Level of Confidentiality) may be used. Use of these model stipulated protective orders is recommended but not required.

Filed Documents and Courtesy Copies.  All pleadings, motions, applications, briefs, and any and all other papers in complex cases shall be filed with (and related filing fees paid to) the Civil Clerk’s Office located in the Hall of Justice, First Floor, Room A, 400 County Center, Redwood City, California. One extra copy of any such filing shall be stamped “Judge’s Copy” and delivered by overnight or first class mail directly to Department 2 located at Courtroom 2E, 400 County Center, Redwood City, California 94063. DO NOT LEAVE THE JUDGE’S COPY WITH THE CLERK’S OFFICE. PLEASE ADD DEPARTMENT 2 TO YOUR MAILING SERVICE LIST IN THE CASE AS TO ANY AND ALL PAPERS FILED WITH THE COURT. All motions and briefs shall conform with the California Rules of Court, especially Rule 3.1113, and indicate on the caption page that this matter is assigned for all purposes to Department 2.

Hearing Dates.  As to any and all motions or other matters requiring a hearing, the hearing date shall be obtained directly from and approved by Department 2 at and not with the Civil Clerk’s Office nor with the Research Attorney), prior to filing of the moving papers or other initial filings.

Ex Parte Applications.  Ex parte applications in this matter shall heard by Department 2, on Tuesdays and Thursday between 2:00 p.m. and 3:30 p.m., and the parties are required to meet the requirements of CRC Rule 3.120 et seq.. With the consent of counsel for all parties, telephone conferences on simple interim case management matters may be scheduled with the Court for a mutually convenient time and date – with the scheduling and logistics of such telephone conferences to be the responsibility of the requesting party/parties.

Discovery.  As to any discovery motions, the parties are relieved of the statutory obligation under California Rules of Court, Rule 3.1345, and thus need not file a separate statement – instead the subject discovery requests (or deposition questions) and written responses (or deposition answers or objections) must be attached to the supporting declaration on the discovery motion.

Given the nature of complex cases, the Court views document production and depositions as the most effective means of discovery for adjudication. Accordingly, no party may propound more than 35 special interrogatories total and no party may propound more than 35 requests for admissions (other than as to the authenticity of documents) total, without prior court order after demonstration of need and a showing that other means of discovery would be less efficient.

In regard to all discovery disputes, counsel for the parties (and any involved third parties) shall meet and confer on any and all discovery disputes and, if there are remaining disputes, then counsel for each side shall serve on each other and mail/deliver directly to Department 2 a letter brief setting forth the dispute and attaching as tabbed exhibits to the letter the subject discovery requests and discovery responses (if any). At the time or prior to submitting (not filing) the letter briefs, counsel for the parties shall also schedule a discovery conference with the Court to occur no sooner than five court days after delivery of the last letter brief to the Court, in order to discuss the dispute. THE DISCOVERY DISPUTE LETTER BRIEFS AND THE DISCOVERY CONFERENCE SHALL BE DONE WELL PRIOR TO THE STATUTORY DEADLINES FOR FILING OF ANY MOTION TO COMPEL OR OTHER DISCOVERY MOTION. No discovery motion may be filed by any party unless and until there is compliance with the requirement of this Order, i.e., (i) substantive meet and confer, (ii) exchange of letter briefs, and (iii) discovery conference with the Court. This requirement does not constitute an extension of time for any statutory time period for filing and serving any motion under the Civil Discovery Act.