How to Cite Unpublished Court Orders
<p>I have looked for this online, but have come up with inconsistent results. Here is one example from California:</p>

<blockquote>
  <p><em>Tsukroff v. Hedgeside Property &amp; Inv. Co.</em>, California Superior Court, Napa County, case no. 26-25117 (order dated 01/19/05) (unpublished)</p>
</blockquote>

<p>Can anyone confirm if this is correct? Since courts differ in their rules from one state to another, please provide several examples. If Bluebook has a point of view on this, I'd appreciate it if you would share that as well. Thanks in advance.</p>

<p>In the Federal Court's we's normally do something like:</p>

<p><em>Tsukroff v. Hedgeside Property &amp; Inv. Co.</em>, No. 26-25117, Order (COURT ABBREVIATION, Jan. 19, 2005).</p>

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