JIN vs LIU

Any person seeking to appear at the MSC by telephone must file with the clerk's office a formal ex parte application with a proposed order and proof of service showing service on all parties. A courtesy copy of the application and proposed order must be delivered directly to the settlement department. The application will not be granted unless the party shows good cause and delivers to the settlement department its SCS that fully complies with CRC 3.1380(c) and includes a good faith settlement demand or offer as of the date the settlement conference statement is signed. If the application is granted, the person appearing by telephone must be immediately available by telephone throughout the conference until released by the court.

FAILURE TO BE IMMEDIATELY AVAILABLE, INCLUDING AFTER BUSINESS HOURS, CONSTITUTES A NON-APPEARANCE BY THAT PERSON.

If the case settles before the MSC, Plaintiff must promptly notify this department and the settlement department.

FAILURE TO COMPLY WITH THIS ORDER MAY RESULT IN SANCTIONS. The Mandatory Settlement Conference in Dept. 301/302/303 will be conducted remotely via Zoom Video Conference.

Prior to the scheduled MSC date, the court will send out a Zoom Video Conference Invitation Link that will include a Meeting ID and other pertinent information that will enable parties/counsels to participate in the specific conference/hearing. Once received please familiarize yourselves with the software and please conduct a test to make sure your specific electronic equipment that you will be using that day (Smartphone, Laptop, Desktop etc.) is fully updated and both video / audio capabilities are functional.

Settlement Conference Statements

To comply with Rule3.1380(c), each party must email the court at least five court days prior to the conference a settlement conference statement no more than five pages in length. Do not file the settlement conference statement. Send the statement to the court clerk's email address. Your statement must include:

Hearing date for any dispositive motion; Summary of remaining discovery; Summary of all liability facts and issues; List of all economic damages claimed; Current good faith settlement offer or demand of each party; Name, date, and description of each alternative dispute resolution neutral's attempt to resolve this case.

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

25CV132752: JIN vs LIU 06/30/2026 Case Management Conference in Department 20 Because of technical and printing limitations, do not include any attachments or exhibits. Make sure you send a copy of your settlement conference statement to all opposing parties. The statements will not be filed and will be destroyed at the completion of the settlement conference and will be destroyed at the completion of the settlement conference.

Please proceed in sending the required Mandatory Settlement Conference Statement via email to: Dept.301@alameda.courts.ca.gov at least five days prior to your conference or submit directly to Dept. 301's Drop Box located outside of the courtroom.

Please proceed in sending the required Mandatory Settlement Conference Statement via email to: Dept.302@alameda.courts.ca.gov at least five days prior to your conference or submit directly to Dept. 302's Drop Box located outside of the courtroom.

Please proceed in sending the required Mandatory Settlement Conference Statement via email to: Dept.303@alameda.courts.ca.gov and trasch@alameda.courts.ca.gov at least five days prior to your conference or submit directly to Dept. 303's Drop Box located outside of the courtroom.

Please provide all email addresses of all parties/counsels/claims representative etc. that will be active participants at the upcoming settlement conference.

TRIAL SETTING ORDER SCHEDULING The date set for the jury trial/court trial shall be the date of the Pre-Trial Conference. Jury selection and/or evidence presentation will start the second Monday after (or Tuesday if Monday is a court holiday) the Pre-Trial Conference. LEAD TRIAL COUNSEL MUST ATTEND ALL PRETRIAL CONFERENCES. Motions in limine will be heard at the Pre-Trial Conference and trial procedures will be discussed. This is the first day of trial for all purposes, including for purposes of the Local Rules, the discovery cut-off periods prescribed in the Code of Civil Procedure and other deadlines derived from the date set for trial. This means, among other things, that the parties must have served their witness lists, exhibit lists, and motions in limine on all other parties prior to the Trial Readiness Conference. Trial days are generally Monday-Thursday, 8:30 a.m. to 1:30 p.m.

MEDIATION

Pursuant to the parties' obligation to participate in alternative dispute resolution, the parties are ordered and referred to private mediation which shall be completed no later than one week before the ADR/Mediation Compliance Hearing/Case Management Conference, which is specified above (and which typically is set approximately 2-3 months before trial). If, for any reason, the parties are unwilling to participate in private mediation, they must contact Department 20 at least four months before trial to arrange court mediation - for which there is no charge to the parties for the first two hours - and complete court mediation consistent with this

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

25CV132752: JIN vs LIU 06/30/2026 Case Management Conference in Department 20 order. (See Alameda eCourt Public Portal Court Mediation Program.)

Updated Case Management Statements that confirm the date on which mediation was completed must be filed no later than fifteen days before the ADR Compliance Hearing. Parties must also confirm the trial readiness of the case. If timely filed ADR/Mediation Compliance/Case Management Statements confirm that mediation was completed and that the case is trial ready, no appearance at the ADR Compliance Hearing is required, unless the parties are advised otherwise. BUT failure to complete mediation without good cause may result in SUBSTANTIAL SANCTIONS and will not change the trial date.

MANDATORY SETTLEMENT CONFERENCES (CRC section 3.1380) typically are set 2-4 weeks before trial and are conducted either in person or remotely in one of the settlement departments at the George E. McDonald Hall of Justice, 2233 Shoreline Drive Alameda, California 94501. MSCs are no longer routinely scheduled in Lemon Law cases.

GENERAL TRIAL ORDERS All parties shall comply with Local Rule of Court 3.35, with the following modifications and clarifications and subject to any further order of the trial judge. All references to jury are provisional i.e. if a jury trial is requested and appropriate.

Dismissal of unserved parties/Doe defendants. All unserved parties, including all Doe parties in the complaint or any cross-complaint, shall be dismissed by no later than the Pretrial Conference/Trial, unless good cause otherwise is shown by a written application to the court by that date.

Demand for Expert Witness Exchange. All parties are deemed to have made a demand for the exchange of expert witness lists pursuant to CCP section 2034. Designations of expert witnesses pursuant to CCP section 2034 must be served at least 50 days before trial.

Pretrial Meet and Confer. At least fourteen (14) days prior to the Conference, the parties are ORDERED to meet-andconfer regarding, and to report any agreements or disputes about, the following subjects: (1) the reservation of exhibit number ranges for each party; (2) which of the parties’ exhibits can be admitted without objection and the elimination of duplicative exhibits; (3) whether there are any evidentiary issues that will require pre-trial hearing; (4) whether any issue in the trial should be bifurcated; (5) the length of the trial; (6) any outstanding discovery and completion dates; (7) deposition designations and counter-designations and any objections thereto; (8) the jury instructions on which they agree and the short list of those in dispute; (9) topics on which they wish the Court to voir dire the jury and the utility of a jury questionnaire; (10) the benefit of additional alternative dispute resolution prior to trial; (11) the need for an interpreter for any witness (Gov’t Code §68560; Evid.

Code §§750-755.5); (12) arrangements the parties intend to make for the provision of a court reporter in light of the fact that Alameda Superior Court no longer supplies reporters for civil trials; (13) a written stipulation in conformity with Government Code section 70044; (14) the possibility of stipulating to an 8-person jury with 6

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

25CV132752: JIN vs LIU 06/30/2026 Case Management Conference in Department 20 required to reach a verdict on any issue (Code Civ. Pro, §§61001 et seq.); (15) a statement of the case to be read to the jury along with a witness list and (16) any other trial readiness issues. Note that the stipulation of the parties to waive or extend the statutory discovery cut-off date is NOT an excuse for failing to satisfy the foregoing requirements.

Joint Submissions. The parties shall deliver physical courtesy copies of the following documents to Department 20 at least three court days prior to the Pre-Trial Conference.

1. Jury Instructions – with ALL BLANKS FILLED IN - which will be given to the jurors at the start (pre-instructions i.e. CACI 100-200 series plus basic cause of action instructions) and conclusion of the trial. This does not mean a set of instructions from each party or side. The court expects the parties to resolve any differences amongst themselves and present a unified set of instruction. It is easier to delete instructions that do not apply after the presentation of evidence than to craft instructions on the eve of argument.

Any proposed jury instruction, including any proposed Special Jury Instruction, not agreed upon shall be separately submitted by each party. NOTE: If there is no attorney on one or both sides of the case, then the court does not require submission of proposed jury instructions by the parties. Instead, the parties may each submit lists of CACI jury instructions and, as appropriate, special jury instructions that they are requesting; the court will prepare the jury instructions.

2. Verdict Form - A single verdict form which will be used by the jury. Again this does not mean different verdict forms from each party or side. The observation noted above as to the jury instructions applies equally to the verdict form. With both Jury Instructions and Verdict Forms all causes of action and defenses must be included even if counsel expects some may be eliminated on motion or otherwise stricken or modified.

3. Exhibit List - An exhibit list with no duplicate documents. Counsel shall meet and confer to determine an assignment of blocks of exhibit numbers per party. Pre-marked exhibits shall be lodged with the Court on the first day of trial along with an Index identifying each of the numbered exhibits (e.g. 10 page letter from X to Y dated ___). The description on the index will be used by the court to identify in the record the documents that are marked for identification or admitted into evidence during the trial. Exhibits (and if voluminous, exhibit binders) pertaining to each witness shall be presented to the court prior to examination of that witness.

4. Witness List - A common witness list limited to those witnesses which the parties actually expect to call to testify (this list will be used in the Juror Questionnaire).

5. Jury Questionnaire - A common juror questionnaire, if the parties agree to use one, with questions in disagreement to be highlighted. A form “Instructions to Jurors” should be attached as the first page to any submitted questionnaire. A list of all potential witnesses and counsel should be attached to the witness list.

6. Statement of the Case/Mini-Opening - A Statement of the Case to be read to the jury. (Counsel shall advise the court if they are agreeable to making mini-opening statements of no more than 3 minutes each).

7. Time Estimate - A reasonable cumulative time estimate from each side for the number of hours needed to present their case. This reasonable estimate shall include: opening statement, final argument, direct examination of their party’s witnesses and cross examination of opposing witnesses. In other words how much time does each party need for the presentation of their case?

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

25CV132752: JIN vs LIU 06/30/2026 Case Management Conference in Department 20 8. Trial Brief – Limited to 10 pages each side.

Motions In Limine. Absent good cause and leave of the court, each side is limited to a maximum of 4 motions in limine. The following in limine motions shall NOT be filed but shall be deemed already to have been ORDERED: (a) exclude all witnesses until testimony completed; (b) no reference to or evidence of settlement discussions or mediation; (c) no reference to or evidence of insurance; (d) no reference to or evidence of other claims/suits/actions against a party; and (e) no reference to or evidence of wealth or lack thereof of any party except in the punitive damage phase of a case.

Exceptions to the foregoing must be raised by motion. Do NOT file generic motions unrelated to the specific facts of the case (e.g., “motion to exclude evidence not disclosed in discovery”). Such motions asking the court to apply the law without a factual record as to how such principles apply to the current case are a waste of time. (See Kelly v. New West Federal Savings (1996) 49 Cal.App.4th 659, 670.) . Motions shall be filed and served no later than 14 days before the pretrial conference and any opposition 7 days before the conference.

Parties shall meet and confer prior to the pretrial conference on whether any of these motions will be dropped or stipulated to. Parties shall submit a notebook(s) containing each motion and opposition to Department 20 at least three days prior to the pretrial conference for the court along with ONE list of all in limine motions filed – plaintiffs’ listed first and then defendants’ motions in numerical order - with the subject of each motion described in less than 10 words and an indication if the motion is stipulated, withdrawn, deferred or contested and leaving a space for a ruling (grant/denied).

Parties are to comply with revised Local Rule 3.35(e)(2) which states: “Unless otherwise ordered by the trial judge, all motions in limine subject to this rule must be in writing, numbered consecutively and filed in the clerk’s office at least three court days before the pretrial conference or, if there is no pretrial conference, three court days before trial. Motions in limine addressing separate evidence or issues shall not be aggregated into one motion. Reservation numbers are not required for motions in limine subject to this rule.”

Deposition Designations. At least 14 days prior to the Pretrial Conference, counsel shall exchange proposed page and line designations of testimony of witnesses who will not be appearing live at trial. At least 7 days prior to the conference counsel shall exchange objections and counter-designations and shall meet and confer. Deposition designations and counter designations shall not be filed with the court nor shall advance courtesy copies be sent to the court. The parties shall meet and confer prior to the Pretrial Conference in order to narrow the number of depositions, designations and objections.

Where objections cannot be resolved and require court ruling, counsel shall prepare an index for each transcript at issue with columns identifying (1) the page and line designations and counter-designations. (2) the objections, if any, to said page and line designations; (3) the response(s) to said objections; and (4) boxes for the court to check whether the objection(s) to the designated page and lines are "sustained" or "overruled." Counsel shall provide the trial judge with each transcript at issue with the contested page and line designations highlighted with a different color for each party.

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

25CV132752: JIN vs LIU 06/30/2026 Case Management Conference in Department 20

Trial Procedures. (1) VOIR DIRE: Counsel are reminded that the purpose of voir dire is limited to inquiries while may lead to the discovery of bias. Department 20 usually uses the “6-pack” method, with 18 jurors initially seated in the jury box. Only one counsel per party may voir dire. (2) OPENING STATEMENTS: In opening statements to the jury by counsel, no display to the jury or reference should be made to any document, chart, graph, map, picture, model, video or any other graphic device or presentation except 1) when marked as an exhibit and received in evidence; 2) by stipulation of counsel; or 3) with leave of court.

With prior approval of the court, counsel may use paper for illustrative purposes during opening statements. At least 48 hours in advance of the Opening Statement (and if it is on a Monday, by 5 pm. the prior Friday) parties shall exchange any power point screens or other visual or demonstrative aids (e.g.photographs, maps, charts, excerpts of deposition testimony or documents) they intend to display to the jury in their Opening Statement. Objections to any said materials shall be brought the attention of the trial judge immediately so that the court has reasonable time to rule upon any objections prior to Opening Statements being presented.

The court strictly enforces the view that Opening Statement is the opportunity to explain to the jury what counsel in good faith, expects the evidence to show. It is not the opportunity for counsel to act as an expert in educating the jury as to medical or scientific theories or law; nor is it the time for argument. (3) TRIAL: WITNESSES: Parties shall identify to opposing parties the names of the witnesses they will be calling to the stand and exhibits they intend to introduce (in their direct case) at least 48 hours in advance (and no later than Friday 5 p.m. for Monday witnesses).

Witnesses, including experts, must be ready to testify in court when called. Absent exceptional circumstances, a party who fails to present a witness to testify will be deemed to have rested. Counsel may approach a witness without requesting prior permission until further order of the court. However, please do not approach a witness with a document/exhibit until you have first shown it to opposing counsel. Only one attorney per party will be permitted to question a witness. Counsel are required to assure that witnesses do not violate any ruling on a motion in limine or other sustained evidentiary objection.

Counsel must admonish all witnesses they are not to discuss their testimony with one another prior to testifying, nor are they to discuss any aspect of the case within ear shot of a juror outside of the courtroom. (4) TRIAL: PRESENTATION OF EVIDENCE: Prior to the Pretrial Conference, counsel shall meet and confer to determine which exhibits may be admitted into evidence by stipulation, or as to which exhibits, if any, there is a stipulation as to foundation/authenticity. If you are using an Overhead Projector, Elmo, Power Point, or other audio/visual equipment, do not project any exhibit until it has been admitted into evidence or opposing counsel has stipulated that it may be shown. (5) TRIAL: OBJECTIONS/TRIAL MOTIONS: Speaking or narrative objections are improper.

Please succinctly state the legal grounds for your objection. If further explanation is needed, the court will ask for a bench conference, or you may. Only one attorney per party will be permitted to assert objections. during each witnesses' testimony or opposing counsel's presentation. Any motions made during trial, such as mistrial, nonsuit, sanctions, directed verdict shall be

SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA

25CV132752: JIN vs LIU 06/30/2026 Case Management Conference in Department 20 made in writing, accompanied by trial testimony if available and relevant points and authorities. (6) JURY FEES: In cases in which a jury is demanded, the party making the demand is required to post initial jury fees timely. At the beginning of the second day and each subsequent day of jury service, the demanding party is to post jury fees in the Clerk's Office. If more than one party has demanded a jury, the parties will share equally in the payment of jury fees unless otherwise ordered by the Court.

Failure to do so will result in a waiver of the right to a jury. (7) DAILY SETTLED STATEMENTS PROVIDED BY COUNSEL: If the parties choose not to provide a court reporter for the trial, then counsel shall meet and confer at the end of each day and prepare a joint settled statement of what occurred at trial for that day, including a summary of testimony of each witness, the arguments of counsel (if any) and rulings by the court.

Clerk is directed to serve copies of this order, with proof of service, to counsel and to selfrepresented parties of record.