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The complex civil page: assignment of complex cases for all purposes to Department 8A or 8B; SB 549 Tribal Nations Access to Justice Act matters; complex case designation and assignment under California Rules of Court 3.400; case management conferences; complex law and motion; informal discovery conferences; discovery disputes during depositions; the class action and PAGA settlement checklist and model agreements; court reporters; remote appearances; and civility and professionalism.
California > Third Appellate District > Sacramento County > Superior Court of California, County of Sacramento
Complex Civil Cases are assigned for all purposes to either: Hon. Jill H. Talley Department 8A 916-874-5754 Dept 8A@saccourt.ca.gov Hon. Peter K. Southworth Department 8B 916-874-5762 Dept 8B@saccourt.ca.gov The information provided here is designed to assist you in managing your complex civil case. The court strongly encourages parties to review the standing orders and department guidelines before directly contacting their assigned department. If you need additional information, each department’s e-mail address and phone number are listed above. E-mail correspondence is preferred and will likely lead to a quicker response. SB 549: Tribal Nations Access to Justice Act Matters that include a cause of action for declaratory and/or injunctive relief pursuant to the Tribal Nations Access to Justice Act (Government Code section 98020) are complex within the meaning of California Rules of Court 3.400 and assigned for all purposes to the Hon. Peter K. Southworth. Refer to SB 549 Tribal Nations Access to Justice Standing Order for more information. Complex Case Designation and Assignment California Rules of Court 3.400 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 California Rules of Court 3.400. The Presiding Judge or their designee will then review the case pursuant to California Rules of Court 3.400 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 whom the case has been assigned. This is an all-purpose assignment under California Rules of Court 3.400. 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 Friday 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. on 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, refer to 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 Friday at 9 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 refer to the Informal Discovery Conference section below and the General Complex Case Standing Order. Informal Discovery Conferences (IDC) 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 3.400) 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, refer to 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 Class Action and/or PAGA Settlements. Failure to provide the required information wastes judicial resources, 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 that 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) Model Class Action and/or PAGA Settlement Agreements For the ease of the parties and to assure compliance with the requirements of the court’s most recent checklist, the court provides the following model class action and PAGA settlement agreements. Model Class Action Settlement Agreement and Class Notice Model Private Attorney General Act (“PAGA”) Settlement Agreement Model Class Action and Private Attorney General Act (“PAGA”) Settlement Agreement and Class Notice Use of these model agreements is strongly encouraged but not required. The model agreements include blanks and bracketed language to provide options and opportunities for customization. When the parties use a model agreement, moving counsel shall provide a redline version showing any modifications to the model agreement. The parties should avoid merely cutting and pasting from other settlement agreements, even previous settlement agreements based on these model agreements. Typographical errors due to quick copy and pasting is more likely to cause approval delay as the court must spend additional time comparing and verifying key terms. Finally, the court is aware that other Superior Courts also provide model settlement agreements. While helpful, those model agreements may not reflect the requirements and/or preferences of the Sacramento Superior Court. 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 and California Rules of Court, Rule 2.956. Requirements for requesting a court reporter are listed on the Court Reporters page. 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 encourage all parties to appear remotely, subject to Code of Civil Procedure § 367.75 whenever possible. To appear remotely, please use the following: Department 8A Join Department 8A by Zoom link Join by phone, dial (833) 568-8864 ID 16108301121 Department 8B Join Department 8B by Zoom link Join by phone, dial (833) 568-8864 ID 16184738886 Civility and Professionalism Uncivil or unprofessional behavior will not be tolerated. The court expects the parties to be familiar with and follow the California Attorney Guidelines of Civility and Professionalism and the Sacramento County Bar Association Standards of Professional Conduct. The court expects parties to resolve all disputes regarding scheduling or time extensions without the necessity of court involvement.
Complex Civil Cases are assigned for all purposes to either: Hon. Jill H. Talley Department 8A 916-874-5754 Dept 8A@saccourt.ca.gov Hon. Peter K. Southworth Department 8B 916-874-5762 Dept 8B@saccourt.ca.gov The information provided here is designed to assist you in managing your complex civil case. The court strongly encourages parties to review the standing orders and department guidelines befor
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