Complex Case Designation and Assignment

As defined in California Rule of Court 3.400(a) - external link, “a ‘complex case’ is an action that requires exceptional judicial management to avoid placing unnecessary burdens on the court or the litigants and to expedite the case, keep costs reasonable, and promote effective decision making by the court, the parties, and counsel.”

Rule of Court 3.400 - external link sets forth the factors the Court considers when evaluating whether an action is complex.

If a plaintiff believes that their case is complex, they shall file a completed Civil Case Cover Sheet (CM-010) along with the complaint designating the case as complex under Rule of Court 3.400. The Presiding Judge or their designee will then review the case pursuant to Rule of Court 3.403 - external link to decide whether it is “complex” and issue a Notice and Order of Complex Case Determination.

If the Presiding Judge has deemed the case “complex,” the Notice and Order of Complex Case Determination will indicate the Complex Civil Case Department and the judge to which the case has been assigned. This is an all-purpose assignment under California Rule of Court 3.734 - external link. All law and motion matters and motions for consolidation, severance, bifurcation, intervention and to continue trial shall be heard in the complex department unless otherwise directed by the Court. The case is also pre-assigned to this department for trial. Other motions referenced in Local Rule 1.05 shall also be heard in this department.

The assigned complex department will issue a Notice of Case Management Conference and Orders re: Complex Case Management Procedures. This notice will include the initial Case Management Conference date and time, among other orders and timelines set forth by the assigned complex department.

Any case that is not initially designated by counsel as “complex” upon filing, but thereafter appears to constitute a “complex” case, may be referred from Law and Motion or the General Civil Case Management Program to the Complex Civil Case Departments.

Case Management Conferences

Case Management Conferences are typically scheduled for Fridays at 10:30 a.m. However, you may be ordered to appear at a different time due to a conflict in the Court’s schedule. The Court may or may not issue a tentative ruling prior to the scheduled CMC. Counsel shall check the Court’s tentative rulings after 2:00 p.m. the court day prior to the scheduled CMC. It is imperative for the parties to review the tentative ruling in its entirety. The ruling may include important updates for the parties, including possible updates to the date/time of the CMC. For more information about the Court’s tentative rulings, see the General Complex Case Standing Order.

Complex Law and Motion

Hearing dates for all motions must be reserved in advance by emailing the assigned department with the subject line “MOTION HEARING REQUEST.” Motions are typically heard on Fridays at 9:00 a.m.

The Court strongly encourages parties to request an Informal Discovery Conference with the Court before reserving a hearing date for any discovery motion. For more information, please see the Informal Discovery Conference section below and the General Complex Case Standing Order.

Informal Discovery Conferences

If a discovery dispute arises, the Court strongly encourages parties to request an IDC with the Court before reserving a hearing date for any discovery motion. The Court further encourages civility and cooperation in scheduling an IDC, including by agreeing to extend the time to file a discovery motion to allow time for an IDC. If a discovery motion is filed without scheduling an IDC, it is likely that the Court will schedule one before hearing the motion to “expedite the case, keep costs reasonable, and promote effective decision making by the court, the parties, and counsel.” (California Rules of Court, Rule 3.400.) - external link During an IDC, the Court will meet informally with the parties to try to resolve the dispute. The process is designed to benefit all parties by saving costs and avoiding delay. For IDC procedures, see the General Complex Case Standing Order.

Discovery Disputes During Depositions

If a dispute arises during a deposition that requires judicial input to resolve, the parties are to contact the Court immediately via the assigned department telephone number. If the parties cannot reach the assigned department, the parties may contact the other complex department.

Checklist for Approval of Class Action and/or PAGA Settlements

This checklist provides direction on the information and argument the Court requires to grant a motion for preliminary and final approval of a class action and/or a motion for approval of a PAGA settlement. All parties shall carefully review the checklist and fully comply with each applicable item to ensure a prompt ruling from the Court. The motion shall follow the same order as this checklist, as that is how the Court will review the motion. Checklist for Approval of Class Action Settlements.

Failure to provide the required information wastes judicial resources and imposes unnecessary burdens on the parties and the Court and may lead to an order to show cause regarding sanctions and/or a reduction in the requested attorneys’ fees award.

Moving counsel must attest that they have reviewed the checklist and their briefing complies with the checklist. Failure to do so will result in the denial of the motion without prejudice. (Local Rule 2.99.05.)

Parties Requesting a Court Reporter

Parties requesting services of a court reporter will need to arrange for private court reporter services at their own expense, pursuant to Government code §68086 - external link and California Rules of Court, Rule 2.956 - external link. Requirements for requesting a court reporter are listed on the Court Reporters webpage at https://www.saccourt.ca.gov/court-reporters/court-reporters.aspx.

Remote Appearances and Zoom Links

Effective January 3, 2022, civil hearings will be open for in-person appearances.

However, the Court will continue to allow and strongly encourages all parties to appear remotely, subject to Code of Civil Procedure § 367.75 - external link whenever possible. Additional information can be found at: https://www.saccourt.ca.gov/civil/docs/pn-civil-remote-and-in-person-proceedings-effective-monday-january-3-2022.pdf.

To appear remotely please use the following:

Department 22

To join by Zoom link - https://saccourt-ca-gov.zoomgov.com/my/sscdept22 - external link
To join by Room: Dept22a
To join by phone dial (833) 568-8864 ID 16184738886

Department 23

To join by Zoom link - https://saccourt-ca-gov.zoomgov.com/my/sscdept23 - external link
To join by Room: Dept23a
To join by phone dial (833) 568-8864 ID 16108301121

Civility and Professionalism

Uncivil or unprofessional behavior will not be tolerated. The Court expects the parties to be familiar with and follow the California Guidelines of Civility and Professionalism (available at https://www.saccourt.ca.gov/local-rules/docs/guidelines-civility-professionalism.pdf) and the Sacramento County Bar Association Standards of Professional Conduct (available at https://www.saccourt.ca.gov/local-rules/docs/standards-professional-conduct.pdf).

The Court expects parties to resolve all disputes regarding scheduling or time extensions without the necessity of Court involvement.