Los Angeles Superior Court
Court-Level Rules, Filing Procedures & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
All filings
- Chambers Drop Off • Upon Filing
- Hand Delivery
Courtesy copies
- 3 copies
Exhibits
- 3 copies • Hand Delivery • At Final Status Conference
Joint Discovery Statement
- 1 copy • 3 Court Days Before Idc
Adjournments
- If both parties agree, they may file a stipulation and proposed order to continue a status conference at least five court days in advance, explaining why the continuance is warranted.
- Motions must be taken off calendar no later than two business days before the hearing.
- Law and motion matters may be continued by CRS, Stipulation and Order, or Ex Parte Application, but telephone continuances are not permitted.
- A stipulation and order for continuance must state the complaint filing date, proposed continuance dates, and good-cause grounds, and must be submitted with the required fees.
- Absent a stipulation, continuances may be sought by noticed motion or ex parte application.
- +3 more
Request must include
Communication
Chambers6 contacts
- sscdept27@lacourt.ca.gov
- sscd@t28@lacourt.ca.gov
- (213) 310-7011
- 213-310-7127
- 213-310-7128
- (213) 633-0689
Clerk2 contacts
- 213-830-0800 (Stanley Mosk); 213-310-7000 (Spring St)
- 213-830-0845
Page & Word Limits4 rules
Memoranda are strictly limited to 15 pages (20 pages for summary adjudication motions) under CRC 3.113(d).
Parties must strictly adhere to the page limitations in California Rules of Court 3.113(d). Parties must file an application under Rule 3.113(e) to obtain permission to file a memorandum longer than 15 pages (20 pages for summary adjudication motions).
Memorandum
15 pages
Summary Adjudication Motion
20 pages
When the court orders an IDC, the joint statement of discovery in dispute must be no more than five pages.
If the Court orders an IDC a joint statement of discovery in dispute (no more than five pages) shall be filed and a courtesy copy delivered to Department W three (3) court days before the IDC.
Joint Discovery Statement
5 pages
Trial briefs shall not exceed fifteen (15) pages.
TRIAL BRIEFS: File and lodge five (5) court days before the FSC and shall not exceed fifteen (15) pages.
Trial Brief
15 pages
Each side's position in the joint statement must be set forth in less than one page of text.
If there are more than a few issues in dispute, the Court will ask the parties to cooperatively prepare a joint statement that (a) identifies each overarching disputed issue (e.g., the relevant time frame for discovery, the scope of discovery on an issue involving alleged privacy rights); and (b) very briefly sets forth (in less than one page of text) each side's position with respect to it.
Joint Statement
1 pages
Document Format Requirements13 rules
For the TRC, the parties must jointly prepare three sets of tabbed, internally paginated, properly marked exhibits organized numerically in three-ring binders (for the court, Judicial Assistant, and witnesses), with written descriptions inserted behind tabs for non-documentary exhibits.
The parties shall jointly prepare, and be fully prepared to lodge at the TRC, three sets of tabbed, internally paginated and properly marked exhibits, organized numerically in three-ring binders (a set for the court, the Judicial Assistant and the witnesses). The parties shall mark non-documentary exhibits and insert a simply written description of the exhibit behind the corresponding numerical tab in the exhibit binder.
Parties filing multiple motions in limine must number them consecutively.
Parties filing more than one motion in limine shall number them consecutively.
Trial readiness binders must organize motions in limine behind tabs by moving/opposition/reply papers and proposed jury instructions behind tabs separating approved instructions, objected-to instructions, special instructions, and verdict forms.
The parties shall organize motions in limine behind tabs identifying the moving, opposition and reply papers to each motion. The parties shall organize proposed jury instructions behind tabs separating (A) the parties' jointly approved jury instructions; (B) the proposed instructions that have elicited an objection; (C) any proposed special instructions; and (D) any agreed-upon special verdict form, or the competing proposed special or general verdict forms.
Special jury instructions must be formatted for submission to the jury, with citations of authority and the requesting party's identity placed above the text.
The parties shall prepare special instructions in a format suitable for submission to the jury (placing citations of authority and the identity of the requesting party above the text pursuant to Local Rules 3.170 and 3.171).
Document exhibits must be placed in tabbed binders with each page numbered within each tab.
All document exhibits MUST be placed in binders under tabs, and each page must be numbered within each tab.
Trial exhibits must be Bates stamped, tabbed, and provided in 3 binders for opposing counsel, witness, and court.
Counsel must bring to trial at least 3 notebooks or binders of exhibits: one for opposing counsel, one for the witness and one for the court. The exhibits must be Bates stamped and tabbed with exhibit numbers that correspond to those on the updated joint exhibit list.
Counsel must bring at least 3 Bates-stamped, tabbed exhibit binders to trial (one each for opposing counsel, the witness, and the court), with exhibit numbers matching the updated joint exhibit list.
Counsel must bring to trial at least 3 notebooks or binders of exhibits: one for opposing counsel, one for the witness and one for the court. The exhibits must be Bates stamped and tabbed with exhibit numbers that correspond to those on the updated joint exhibit list.
Exhibits must be pre-marked with Arabic numerals, with each page of multi-page exhibits numbered sequentially (Local Rules 3.52 and 3.53).
Pursuant to Local Rules 3.52 and 3.53, the exhibits must be pre-marked using Arabic numerals and in instances where exhibits consist of multiple pages, each page must be numbered sequentially.
Discovery disputes not resolved at informal discovery conferences are litigated through streamlined proceedings using joint statements that present opposing positions in a point/counterpoint format.
If the parties cannot resolve their disputes, the court will invite them to litigate their disagreements by way of informal, streamlined proceedings, using joint statements presenting opposing positions in a point/counterpoint format.
Portions of depositions, interrogatories, or requests for admission to be used at trial must be extracted and marked as exhibits.
Portions of the depositions, interrogatories and/or requests for admissions sought to be introduced at trial shall be extracted and marked as exhibits. (CCP §2025.620; SCLAC Rule 3.158)
Exhibits must be placed in binders that are three-hole punched, tabbed, and paginated.
Place exhibits in binders, three-hold punched, tabbed and paginated.
Each requested jury instruction must identify the requesting party at the top, state whether it is submitted as requested or modified, and include a signature line for the Court.
All requested instructions shall be submitted in the proper form which includes: 1. At the top of each requested jury instruction, identification of the party/parties requesting the instruction; 2. Whether the instruction to be given as requested or as modified; 4. A signature line for the Court.
Each motion in limine must be numbered sequentially, per party (e.g., Plaintiff's Motion in Limine No. 1).
Each motion must be numbered sequentially (i.e., Plaintiff's Motion in Limine No.1, Defendant's Motion in Limine No.1, etc.)
Document Filing Requirements60 rules
Upon assignment to Department 11, an ISC Order stays all proceedings and the parties must submit a joint ISC statement as directed in that Order.
As soon as a new case is assigned to Department 11, the Court issues an Initial Status Conference ('ISC") Order that stay all proceedings pending the parties' appearance at the ISC. The Parties must submit a joint ISC statement as directed in that Order.
Document Type
Joint Isc Statement
The parties must file a joint statement outlining recent progress in the case before every status conference.
The Court requires the parties to file a joint statement outlining recent progress in the case five court days prior to every status conference.
Document Type
Joint Status Conference Statement
Parties must make joint bulletin board postings rather than unilateral postings, which are treated as prohibited ex parte communications.
The Court requires the parties to make joint postings rather than unilateral postings on the bulletin boards because the Court cannot ethically receive ex parte communications from one side or the other. Even though both sides can view the bulletin board postings, unilateral postings are technically ex parte communications.
Document Type
Bulletin Board Posting
A joint posting is required even if one side contends that an IDC is premature or unnecessary.
Judge Cunningham requires the parties to make a joint posting even if one side contends that an IDC is premature or unnecessary.
Document Type
Joint Posting
An application under CRC Rule 3.113(e) is required to obtain permission to file a memorandum longer than 15 pages (20 pages for summary adjudication motions).
Parties must file an application under Rule 3.113(e) to obtain permission to file a memorandum longer than 15 pages (20 pages for summary adjudication motions).
Document Type
Application To File Overlength Memorandum
A motion or application for PAGA settlement approval must establish the settlement is fair to the aggrieved employees, the LWDA, the employer, the plaintiff, and plaintiff's counsel, and a PAGA plaintiff may only release civil penalties recoverable for violations alleged in the original LWDA notice.
Court approval is required for "any proposed settlement of any civil action filed pursuant to" PAGA. (Labor Code § 2699(1)(2). To obtain court approval, the parties must demonstrate that the terms of the settlement are "fair to those affected." (Williams v. Superior Court (2017) 3 Ca.5th 531, 549.) A motion or application for approval must therefore establish the settlement is fair to the aggrieved employees, the LWDA, the employer, the plaintiff and plaintiff's counsel. A PAGA plaintiff can only release claims for civil penalties that the LWDA could have recovered for the violations alleged in the plaintiff's original notice to the LWDA.
Document Type
PAGA Settlement Approval Motion
Requests to dismiss class claims must comply with CRC 3.770, including filing a declaration describing the consideration in detail.
Parties seeking to dismiss class claims must carefully follow Rule 3.770 which, among other things, requires a filed declaration describing the consideration "in detail."
Document Type
Request To Dismiss Class Claims
In summary judgment/adjudication filings, each evidentiary objection must be directed to a single objectionable sentence with specific identification of the statement and the basis, and the Court will overrule objections aimed at paragraphs or series of sentences.
Please carefully review and strictly comply with California Rules of Court Rule 3.1350. Please remember to address evidentiary objections to a single objectionable sentence using one of the formats set forth in CRC 3.1354 (requiring specific identification of each "objectionable statement" and the basis for each objection "to that statement"). The Court will overrule multiple objections directed to a paragraph or to a series of sentences because this formatting improperly delegates to the Court Counsel's obligation to specify which objection is made to each statement.
Document Type
Evidentiary Objections
Plaintiffs must prepare a PAGA trial management plan, analogous to the class certification trial management plan.
The Court similarly requires plaintiffs to prepare a PAGA trial management plan.
Document Type
Paga Trial Management Plan
Any motion for class certification must attach, as an exhibit, a Duran-compliant class action trial management plan identifying witnesses, offers of proof, common proof, and treatment of affirmative defenses.
Before granting motions for class certification, Judge Cunningham requires the moving party to submit a class action trial management plan as described by the California Supreme Court in Duran v. U.S. Bank National Association (2014) 59 C. 4th 1 and its progeny. The trial management plan should identify witnesses and make specific offers of proof on each element of each cause of action and the damages to be tried. It should identify matters of common proof and address presentation of evidence for relevant affirmative defenses whether or not the defenses turn on individualized issues. Please attached the trial management plan as an exhibit to any motion for class certification.
Document Type
Motion For Class Certification
Before the TRC, the parties must meet and confer to jointly prepare the Trial Readiness Documents and work toward stipulations on ultimate facts, legal issues, motions in limine, and exhibit authenticity/admissibility.
In preparation for the TRC, the parties shall meet and confer and jointly prepare the Trial Readiness Documents to be filed and lodged with the court. The parties shall also work to reach stipulations to ultimate facts, legal issues, motions in limine and the authenticity/admissibility of exhibits.
Document Type
Trial Readiness Documents
Parties must file a joint witness list identifying each witness and expert witness by name (excluding impeachment and rebuttal witnesses); calling an unlisted witness requires a showing of good cause.
The parties shall file a joint list of all witnesses that each party intends to call (excluding impeachment and rebuttal witnesses). Local Rule 3.25(i)(5). The joint witness list shall identify each witness by name, each expert witness, the expected ... any potential scheduling problems or special requirements. Any party who seeks to elicit testimony from a witness not identified on the joint witness list will have to make a showing of good cause.
Document Type
Joint Witness List
In jury trials, parties must file a joint statement of the case to be read to the jury, or may alternatively agree to mini-opening statements of five minutes or less per side.
For jury trials only, the parties shall file a joint statement of the case to be read to the jury (Los Angeles County Court Rules, Rule ("Local Rule") 3.25(i)(4)). Alternatively, the parties may agree to provide Mini-Opening Statements (five minutes or less per side).
Document Type
Joint Statement Of Case
Opposition papers to motions in limine must identify in the caption the number of each motion being responded to.
Parties filing opposition papers shall identify, in the caption, the number of each motion to which it responds.
Document Type
Opposition
Each motion in limine caption must concisely identify the subject of the motion and designate the specific evidence sought to be precluded.
The caption of each motion in limine shall concisely identify the subject of the motion and designate the specific evidence sought to be precluded.
Document Type
Motion In Limine
Each party must file a trial brief succinctly identifying the claims and defenses, the major legal issues with supporting points and authorities, the relief claimed and damages calculation, and any other information assisting the Court at trial.
Each party shall file a trial brief succinctly identifying: i) the claims and defenses subject to litigation; ii) the major legal issues (with supporting points and authorities); iii) the relief claimed and calculation of damages sought; and iv) any other information that may assist the Court at trial.
Document Type
Trial Brief
Parties must prepare and file a joint exhibit list with columns identifying exhibits offered without objection or each party's evidentiary objections to admission.
The parties shall prepare and file a joint exhibit list that includes columns identifying each exhibit offered without objection or specifying each party's evidentiary objections to its admission.
Document Type
Joint Exhibit List
Parties must jointly file a proposed general or special verdict form with interrogatories; if they cannot agree, each party must separately file a proposed verdict form.
The parties shall prepare and jointly file a proposed general or special verdict form with interrogatories. If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form. Local Rule 3.25(i)(7) and (8).
Document Type
Proposed Verdict Form
Parties must jointly prepare and file a list of jury instructions and a complete set of full-text proposed instructions, editing CACI instructions to insert party names and remove blanks and irrelevant material.
The parties shall jointly prepare and file a list of jury instructions and a complete set of full-text proposed jury instructions, editing all CACI instructions to insert party names, remove blanks and remove irrelevant material.
Document Type
Proposed Jury Instructions
Ex parte applications must comply with California Rules of Court, rules 3.1203 and 3.1204.
Counsel and self-represented litigants must comply with California Rules of Court, rule 3.1203. Please carefully review California Rules of Court, rule 3.1204 regarding “notice.”
Document Type
Ex Parte Application
Each party's trial brief must succinctly identify the claims and defenses, major legal issues with supporting authorities, relief claimed and damages calculation, and any other trial-assisting information.
Trial Briefs - Each party shall file a trial brief succinctly identifying: (1) the claims and defenses subject to litigation, (2) the major legal issues (with supporting points and authorities), (3) the relief claimed and the calculation of damages sought, and (4) any other information that may assist the Court at trial.
Document Type
Trial Brief
A stipulation requesting an informal discovery conference must include a brief joint report describing the dispute, the necessity for the discovery, the justification for nonproduction, the status of discovery, and any dispositive issues.
If the parties cannot resolve the issue, they may request an IDC by filing a stipulation. The stipulation shall include a brief joint report that succinctly sets forth the nature of the dispute, the necessity for the discovery, the justification for its nonproduction, and the overall status of discovery, as well as any dispositive issues.
Document Type
Stipulation Requesting Idc
Ex parte applications are reserved for exigent circumstances and must include a declaration with an affirmative factual showing of irreparable harm, immediate danger, or another statutory basis for ex parte relief.
Ex parte applications are reserved for exigent circumstances. The applicant shall comply with Cal. Rules of Court, rule 3.1202(c): "An applicant must make an affirmative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte."
Document Type
Ex Parte Application
Ex parte applicants must submit a proposed order and pay the filing fee before appearing in court.
Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in court.
Document Type
Ex Parte Application
The caption of each motion in limine must concisely identify the evidence the moving party seeks to admit or exclude.
Motions in Limine - The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to admit or exclude.
Document Type
Motion In Limine
The parties must file a signed joint witness list (excluding impeachment and rebuttal witnesses) identifying each witness by name, expert status, estimated examination times, total testimony hours, and any scheduling issues or special requirements.
Joint Witness List - The parties shall work together and file a joint list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. The joint witness list shall identify each witness by name, specify which witnesses are experts, estimate the length of direct examination, cross-examination, and re-direct examination of each, and include a total of the number of hours for all witness testimony. The parties shall identify all potential witness scheduling issues and special requirements. The parties/counsel shall sign the joint witness list.
Document Type
Joint Witness List
The parties must meet and confer and then file a signed joint exhibit list with columns for the exhibit, offering party, stipulations or objections to authenticity/admissibility, and identification and admission dates.
Joint Exhibit List - The parties shall prepare and file a joint exhibit list organized with columns identifying: (1) the exhibit, (2) which party is offering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) the date on which the exhibit was identified, and (5) the date on which the exhibit was admitted. Prior to filing the joint exhibit list, the parties shall meet-and-confer to determine whether they will stipulate to the authenticity and/or admissibility of each exhibit or whether there are objections to any exhibit. If there are stipulations, the parties shall note that in the respective column. If not, the objecting party shall specify all objections in the respective column. The parties/counsel shall sign the joint exhibit list.
Document Type
Joint Exhibit List
The parties must prepare a complete set of full-text proposed jury instructions, with special instructions formatted for submission to the jury containing only the instruction number, title, and text.
Jury Instructions (Joint and Contested) - The parties shall prepare a complete set of full-text proposed jury instructions. The parties shall prepare special instructions in a format ready for submission to the jury with the instruction number, title, and text only.
Document Type
Jury Instructions
If deposition or former testimony will be used in lieu of live testimony, the parties must meet and confer and file a signed chart of page/line designations, objections, counter-designations, responses, and the Court's rulings.
Page and Line Designations for Deposition and Former Testimony-If the parties intend to use deposition testimony or former trial testimony in lieu of any witness's live testimony, the parties shall meet-and-confer and jointly prepare and file a chart with columns for each of the following: (1) the page and line designations of the deposition or former testimony requested for use, (2) objections, (3) counter-designations, (4) any responses thereto, and (5) the Court's rulings. The objecting party shall specify all objections in the respective column. The parties/counsel shall sign the designations.
Document Type
Deposition Designation Chart
The parties must jointly file a signed list of proposed jury instructions in numerical order identifying agreed and contested instructions, with a space by each instruction for the Court to indicate whether it was given.
Joint List of Proposed Jury Instructions -The parties shall jointly prepare and file a list of proposed jury instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any. The list of proposed jury instructions must include a space by each instruction for the Court to indicate whether the instruction was given. The parties/counsel shall sign the joint list of proposed jury instructions.
Document Type
Joint List Of Proposed Jury Instructions
The parties must file a joint proposed general or special verdict form; if they cannot agree, each party must separately file a proposed verdict form.
Joint Verdict Forms -The parties shall prepare and file a joint proposed general verdict form or special verdict form (with interrogatories). If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.
Document Type
Verdict Form
In jury trials, the parties must prepare and sign a joint written statement of the case for the Court to read to the jury.
Joint Statement - For jury trials, the parties shall prepare a joint written statement of the case for the Court to read to the jury. The parties/counsel shall sign the joint statement.
Document Type
Joint Statement Of Case
The motions in limine binder must include a table of contents identifying each motion, opposition, and reply with its corresponding tab.
The binder also must contain a table of contents identifying each motion in limine, opposition, and reply, and the corresponding tab for each.
Document Type
Motions In Limine Binder
Counsel must provide at least three sets of tabbed exhibit binders (sentence continues across a page break) and must also supply an exhibit binder to each opposing party.
At least three sets of exhibit binders - tabbed and witness. Counsel must also supply an exhibit binder to each opposing party.
Document Type
Exhibit Binder
Counsel must provide a joint trial binder to the Court at the FSC organized with the mandated Tabs A through J.
Counsel must provide a joint trial binder for the Court at the FSC. The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Blank Tab C: Joint Statement of the case Tab D: Joint Witness List Tab E: Joint List of Jury Instructions Tab F: Joint and Contested Jury Instructions Tab G: Joint and/or Contested Verdict Forms Tab H: Joint Exhibit List Tab I: Page and Line Designations for Deposition and Former Testimony Tab J: Stipulations
Document Type
Joint Trial Binder
Every ex parte application must include a proposed order submitted separately from the application.
All ex parte applications require a proposed order, which shall be submitted separate from the ex parte application.
Document Type
Ex Parte Application
The exhibit list must be included in the exhibit binders.
The exhibit list must be included in the binders.
Document Type
Exhibit Binder
Counsel must meet and confer to prepare a joint, short, non-argumentative Statement of the Case suitable to be read to the jury and lodge it five court days before the FSC.
Counsel shall meet and confer to prepare a JOINT short, non-argumentative written statement of the case suitable to be read to the jury and shall lodge the Statement of the Case five (5) court days prior to the FSC. (See SCLAC Rules 3.25(g)(4); 3.73)
Document Type
Statement Of The Case
Trial briefs are mandatory in all cases and must include ten specified elements, including description of claims and defenses, stipulated facts, contested issues of fact and law, relief and damages breakdown, and opening statement time estimates.
Trial briefs are mandatory in all cases and shall include: 1. A brief description of the claims and defenses presented and the issues to be decided. 2. Statement of ultimate facts or issues to which you will stipulate. 3. Those facts established by admissions in pleadings, by discovery and/or stipulation by counsel. 4. All contested issues of fact. 5. All contested issues of law, together with points and authorities supporting the party’s position. 6. A list of major evidentiary issues anticipated and points and authorities in support of the party’s position. 7. A detailed statement of the relief claimed including a breakdown of the elements of damages claimed. 8. Any other information that will assist the Court. 9. Time estimate of opening statement. 10. Confirm whether the party and/or counsel intends to make a mini opening statement (applies only to jury trials).
Document Type
Trial Brief
Motions in limine seeking to preclude inadmissible or prejudicial matter in the jury's presence must be accompanied by a declaration complying with LACCR Rule 3.57(a).
Each motion in limine for the purpose of precluding the mention or display of inadmissible and prejudicial matter in the presence of the jury shall be accompanied by a declaration in compliance with the requirements of Rule 3.57(a) of the LACCR.
Document Type
Motion In Limine
Counsel must provide reasonable trial time estimates and be familiar with Local Rule 3.25(h).
Counsel must provide the court with reasonable time estimates and be familiar with Local Rule 3.25(h) regarding trial time estimate.
Document Type
Trial Time Estimate
Parties must submit a joint set of agreed jury instructions plus each side's objected-to instructions, with blanks filled in and modifications made before delivery.
A joint set of agreed upon instructions and a set of instructions from each side to which there are objections shall be submitted. Before delivery of instructions, counsel shall fill in the blanks and make all modifications.
Document Type
Jury Instructions
Long Cause Trial Package must include reasonable trial time estimates complying with Local Rule 3.25(h).
The parties are to meet and confer and submit a Long Cause Trial Package to the Court. TRIAL TIME ESTIMATE: Counsel must provide the court with reasonable time estimates and be familiar with Local Rule 3.25(h) regarding trial time estimate.
Document Type
Long Cause Trial Package
The parties must meet and confer and file proposed general or special verdict forms.
The parties are to meet and confer and file any proposed general or special verdicts.
Document Type
Proposed Verdict Forms
The parties must meet and confer and submit a Long Cause Trial Package to the Court.
The parties are to meet and confer and submit a Long Cause Trial Package to the Court.
Document Type
Long Cause Trial Package
Parties must submit an updated joint witness list by the final status conference.
Parties are to submit an updated joint list of all witnesses that each party intends to call by the final status conference.
Document Type
Joint Witness List
A party resisting discovery on privilege grounds should prepare a privilege log identifying each communication, its originator, and all recipients.
If there is an issue of attorney-client or work product privilege, the party resisting discovery should prepare a privilege log identifying the communication, the person originating each communication., and all persons who received it.
Document Type
Privilege Log
A unilateral IDC posting is permitted only when the other side ignored or refused repeated meet-and-confer requests, and it must be limited to describing the impasse and the facts substantiating the refusal.
A unilateral posting requesting an IDC is only appropriate when the other side has completely ignored or refused repeated requests to meet and confer; it should not include any argument or information beyond a description of the impasse and the facts substantiating the other side's failure or refusal to meet and confer.
Document Type
Unilateral Posting
When more than a few issues are in dispute, the parties must prepare a joint statement identifying each overarching disputed issue and briefly stating each side's position.
If there are more than a few issues in dispute, the Court will ask the parties to cooperatively prepare a joint statement that (a) identifies each overarching disputed issue (e.g., the relevant time frame for discovery, the scope of discovery on an issue involving alleged privacy rights); and (b) very briefly sets forth (in less than one page of text) each side's position with respect to it.
Document Type
Joint Statement
A joint posting to the Court should very succinctly describe the nature of the impasse.
The parties' joint posting should very succinctly describe the nature of the impasse.
Document Type
Joint Posting
Motions for preliminary or final approval of class action settlements must adhere to the guidelines posted on the Court's website.
Parties seeking preliminary or final approval for class action settlements should carefully adhere to the guidelines posted on the Court's website.
Document Type
Class Action Settlement Approval Motion
Parties filing motions for preliminary approval of class action settlements must consult and carefully comply with the guidelines and checklists on the Complex Court tab of the Court's website.
Under the Complex Court's tab on the Court's website are guidelines and checklists for motions for preliminary approval of class action settlements. Please consult and carefully comply with the guidelines and checklists.
Document Type
Motion For Preliminary Approval Of Class Action Settlement
Motions in limine may not be used to exclude large categories of evidence; where the Court cannot rule without hearing foundational evidence, parties must file a bench brief on the evidentiary issue instead of a motion in limine.
Please remember that motions asking the court to exclude large categories of evidence (e.g., "all evidence not disclosed in discovery") are not appropriate for adjudication in limine. The Court cannot decide whether a party unfairly withheld information in discovery until it receives an offer of specific evidence, an objection to that evidence, the discovery requests asking for the specific evidence, and the objections raised by the responding party. Please also recognize that in many cases, the Court is not in a position, at the outset of trial, before hearing preliminary or foundational evidence, to issue an order excluding evidence in limine. When that is the case, please file a bench brief addressing the evidentiary issue rather than a motion in limine.
Document Type
Bench Brief
Filing & Service rules
Electronic Filing Rules
Documents must be filed with the court in accordance with the Code of Civil Procedure and the Rules of Court; the Court will not download documents from e-service providers for filing.
To property file a document in Court, a party should file it in accordance with the Code of Civil Procedure and the Rules of Court. The Court will not download documents from the e-service providers for filing.
Page 2 | 3) E-Service Providers
Self-represented litigants and parties exempt from electronic filing must file ex parte applications and oppositions in the Spring Street Courthouse Clerk’s Office on the hearing date.
If a party is a self-represented litigant or is exempt from electronic filing, the party must file their ex parte application or opposition in the Clerk’s Office of the Spring Street Courthouse on the date of the requested hearing.
Page 2
Self-represented litigants and parties exempt from electronic filing must file ex parte applications or oppositions in paper in the Clerk's Office of the Spring Street Courthouse on the date of the requested hearing.
If a party is a self-represented litigant or is exempt from electronic filing, the party must file their ex parte application or opposition in the Clerk's Office of the Spring Street Courthouse on the date of the requested hearing.
Page 2 | EX PARTE APPLICATIONS
Attorneys must comply with electronic filing; self-represented litigants without e-filing means may file their documents in the courtroom.
Compliance with electronic filing is required for attorneys. Please refer to the Court's website for electronic filing orders. Self-Represented Litigants without means for filing electronically may file their documents in the courtroom.
Page 2 | FILINGS
Represented litigants must electronically file all documents in limited and unlimited non-complex civil matters through an approved Electronic Filing Service Provider.
The Los Angeles County Superior Court has implemented electronic filing of all documents filed in the Limited and Unlimited Non-Complex Civil matters by litigants represented by attorneys pursuant to the operative General Order re Mandatory Electronic Filing for Civil. Pursuant to California Rules of Court, Rule 2.253(b), represented litigants are required to electronically file documents with the Court through an approved Electronic Filing Service Provider.
Page 1 | FILINGS
Los Angeles Superior Court requires electronic filing of all civil documents effective January 2, 2019.
Since January 2, 2019, the Los Angeles Superior Court mandates electronic filing of all documents in all Civil matters. Please review the latest Amended General order on Electronic Filing.
Page 1 | PRE-TRIAL INFORMATION
Electronic filing is mandatory for all documents in all civil matters in the Los Angeles Superior Court.
Since January 2, 2019, the Los Angeles Superior Court mandates electronic filing of all documents in all Civil matters. Please review the latest Amended General order on Electronic Filing.
Page 1 | PRE-TRIAL INFORMATION
Only self-represented litigants may file ex parte applications on the day of the hearing at the Clerk's Office.
Only self-represented litigants may file ex parte applications on the day of the ex parte in the Clerk's Office.
Page 1 | HEARINGS
Self-represented litigants are exempt from mandatory e-filing and should file their papers at the filing window.
Pursuant to California Rules of Court, Rule 2.253(b)(2), self-represented litigants are exempt from mandatory Electronic Filing requirements and papers should be filed at the filing window.
Page 1 | FILINGS
Filing Timing and Cure Windows
The joint status conference statement must be filed at least five court days before every status conference.
The Court requires the parties to file a joint statement outlining recent progress in the case five court days prior to every status conference.
Page 2 | Initial Status Conference / Status Conferences (p. 2, before Section 3)
Reply briefs in summary judgment/adjudication motions are due five calendar days before the hearing, a deadline the Court notes does not leave enough time to prepare a written tentative ruling.
Please note that the time allotted by the Code of Civil Procedure for reply briefs in summary judgment/adjudication motions (five calendar days prior to the hearing) does not give the Court enough time to prepare a written tentative ruling.
Page 6 | 12) MOTIONS FOR SUMMARY JUDGMENT OR ADJUDICATION
The parties must serve and file the Trial Readiness Documents at least 5 calendar days before the TRC.
At least 5 calendar days prior the TRC, the parties shall serve and file the following Trial Readiness Documents:
Page 8 | 14) FINAL STATUS/TRIAL READINESS CONFERENCES ('TRCs') - c) Trial Readiness Documents
Motions in limine must comply with the statutory notice provisions of Code of Civil Procedure Section 1005 and Local Rule 3.57(a).
Before filing motions in limine, the parties shall comply with the statutory notice provisions of Code of Civil Procedure Section 1005 and the requirements of Local Rules 3.57(a).
Page 9 | e) Motions In Limine
Motions must be taken off calendar at least two business days prior to the hearing.
The deadline to take any motions off calendar is two business days before the hearing.
Page 1
Ex parte applications or oppositions by self-represented litigants or e-filing-exempt parties must be filed on the date of the requested hearing.
If a party is a self-represented litigant or is exempt from electronic filing, the party must file their ex parte application or opposition in the Clerk's Office of the Spring Street Courthouse on the date of the requested hearing.
Page 2 | EX PARTE APPLICATIONS
Trial readiness documents must be served and filed at least five court days before the Final Status Conference.
At least five (5) court days prior to the FSC, the parties/counsel shall serve and file the following trial readiness documents:
Page 3 | F. TRIAL PROCEDURES
Exhibits must be exchanged at least five calendar days before the FSC and lodged with the Court on the first day of trial.
The exhibits must be exchanged at least five (5) calendar days before the FSC and lodged with the Court on the first day of trial.
Page 5 | 4. Exhibits
The moving party must e-file all ex parte documents by 10:00 a.m. on the court day before the hearing.
The moving party must e-file all documents by 10:00 a.m. on the court day prior to the hearing.
Page 1 | HEARINGS
Trial documents must be e-filed 5 days prior to the Final Status Conference.
Trial documents due 5 days prior to FSC via e-filing.
Page 2 | FILINGS
Represented litigants must e-file ex parte applications and supporting documents no later than 10:00 a.m. the court day before the ex parte hearing.
Represented litigants: All ex parte applications and documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the ex parte hearing.
Page 1 | EX PARTE APPLICATIONS
Self-represented litigants must submit ex parte applications no later than 8:30 a.m. on the day of the hearing.
Self-Represented Litigants: ex parte applications must be submitted no later 8:30 a.m. the day of the hearing.
Page 1 | EX PARTE APPLICATIONS
Motions for Summary Judgment and/or Adjudication must be timely filed and served because the court will not continue the trial date to hear them.
The Court will not continue the Trial date to hear any Motions for Summary Judgment and/or Adjudication. Therefore, any Motions for Summary Judgment and/or Adjudication MUST BE TIMELY FILED AND SERVED.
Page 2 | MOTIONS FOR SUMMARY JUDGMENT AND/OR ADJUDICATION
Trial briefs must be filed and lodged five court days before the Final Status Conference.
TRIAL BRIEFS: File and lodge five (5) court days before the FSC and shall not exceed fifteen (15) pages.
Page 4 | 1. TRIAL BRIEFS
The Statement of the Case must be filed and lodged five court days before the FSC.
STATEMENT OF THE CASE: File and lodge five (5) court days before the FSC.
Page 4 | 2. STATEMENT OF THE CASE
Parties must serve and file proposed Voir Dire questions five court days before the FSC.
Five (5) court days prior to the FSC the parties shall serve and file proposed Voir Dire questions for the Court.
Page 4 | 3. VOIR DIRE
The exhibit list must be filed and lodged five court days before the Final Status Conference.
EXHIBIT LIST: File and Lodge five (5) court days before the FSC.
Page 5 | Exhibits
Jury instructions must be filed and lodged five court days before the FSC.
JURY INSTRUCTIONS: File and Lodge five (5) court days before the FSC.
Page 5 | Trials
Written exhibit objections stating the grounds must be filed at least two court days before the FSC, and objections not so filed are deemed waived absent good cause.
Any party objecting to any listed exhibit, either as to foundation or admissibility, shall file the objection in writing together with a brief statement of the ground(s) for objection at least two (2) court days before the FSC. Any objections not so stated as per the foregoing shall be deemed waived except upon a showing of good cause.
Page 5 | Exhibits
The verdict form must be filed and lodged five court days before the FSC.
VERDICT FORM: File and Lodge five (5) court days before the FSC.
Page 6 | Trials
Ex parte applications and all supporting documents must be filed no later than 10:00 a.m. on the court day before the ex parte hearing.
Ex parte application and all documents in support thereof must be filed no later than 10:00 a.m. the court day before the ex parte hearing.
Page 1 | PRE-TRIAL INFORMATION
Ex parte applications and supporting documents must be filed by 10:00 a.m. the court day prior to the hearing.
Ex parte application and all documents in support thereof must be filed no later than 10:00 a.m. the court day before the ex parte hearing.
Page 1 | PRE-TRIAL INFORMATION
The Court's order scheduling an IDC stays any deadline to file a motion to compel under CCP 2016.080(c)(2).
IN accordance with Section 2016.080(c)(2), the Court's order scheduling the IDC will stay any deadline to file a motion to compel.
Page 4 | 5) Informal Discovery Conferences (IDCs)
The Court cannot shorten the notice period for summary judgment/adjudication motions, though it may hear such motions fewer than 30 days before trial.
The Court does not have discretion to order a shortened notice period; it does have discretion to hear a motion for summary judgment or adjudication fewer than 30 days before the trial date.
Page 6 | 12) MOTIONS FOR SUMMARY JUDGMENT OR ADJUDICATION
Case Management Conference statements must be filed no later than 15 calendar days before the conference.
Case Management Conference statements are required no later than 15 calendar days prior to the conference pursuant to rule 3.725 of the California Rules of Court.
Page 2 | HEARINGS
A Request for Court Reporting Services must be filed at least 10 calendar days before the hearing or trial.
The Request for Court Reporting Services by a Party with a Fee Waiver should be filed at least ten calendar days before the hearing or trial for which the reporter is requested.
Page 3 | MISCELLANEOUS
In trials without a court reporter or electronic recording, a joint daily summary of testimony must be submitted by 4:00 p.m. of the next court day.
For trials in which there is no court reporter or electronic recording, Department S25 requires that a joint daily summary of testimony must be completed and submitted to the Court by 4:00 p.m. of the next court day, unless otherwise directed by the Court.
Page 3 | MISCELLANEOUS
In unlimited civil proceedings, fee-waiver parties may request an official court reporter on form LACIV269 at least 10 calendar days before the hearing or trial.
In unlimited civil proceedings, parties who have received a fee waiver pursuant to California Rules of Court Rule 3.55(7) may timely request an official court reporter pursuant to California Rules of Court Rule 2.956(b)(3) at least 10 calendar days prior to the hearing or trial on court form LACIV269.
Page 1 | COURT REPORTERS
Service and Proof of Service Rules
All defendants must be served with the complaint no later than the case management conference.
All defendants must be served with the complaint by the case management conference.
Page 1 | B. CASE MANAGEMENT CONFERENCES
If any defendant remains unserved by the case management conference, plaintiff must submit a declaration at least five days before the hearing explaining the efforts made to accomplish service.
If all defendants have not been served, plaintiff or plaintiff's counsel must submit a declaration to the court five (5) days prior to the hearing explaining what efforts have been undertaken to accomplish service.
Page 1 | B. CASE MANAGEMENT CONFERENCES
All exhibit-list items must be exchanged and reviewed by counsel before the FSC.
All items on the exhibit list shall be exchanged and reviewed by counsel prior to the FSC.
Page 5 | Exhibits
Written oppositions to motions in limine must be served at least five court days before the FSC.
Any opposition to any motion in limine must be in writing and served on opposing party or counsel at least five (5) court days prior to the FSC.
Page 6 | PRE-TRIAL MOTIONS, INCLUDING BUT NOT LIMITED TO MOTIONS IN LIMINE
Motions in limine must be in writing and served on opposing party or counsel at least ten court days before the FSC.
All motions in limine must be in writing and shall be served on the opposing party or counsel at least ten (10) court days prior to the FSC.
Page 6 | PRE-TRIAL MOTIONS, INCLUDING BUT NOT LIMITED TO MOTIONS IN LIMINE
Once the Court appoints the e-service provider (CaseAnywhere, File&ServeXpress, or CaseHomePage), parties should effectuate service through that provider, but e-service does not substitute for filing with the court.
After the Court appoints the e-service provider, the parties should effectuate service through the e-service provider, mindful that the e-service provider is not a substitute for filing documents in court.
Page 2 | 3) E-Service Providers
Pre-trial service deadlines are extended based on the manner of service as set forth in Code of Civil Procedure § 1013, unless otherwise ordered.
Unless otherwise ordered, the following pre-trial filing and service deadlines apply. All deadlines for service are extended based on the manner of service as set forth in Code of Civil Procedure § 1013.
Page 3 | F. TRIAL PROCEDURES
Proposed Voir Dire questions must be served on the other parties in addition to being filed with the Court.
Five (5) court days prior to the FSC the parties shall serve and file proposed Voir Dire questions for the Court.
Page 4 | 3. VOIR DIRE
Filing Fees and Waivers
Motion fees must be paid online at the time the hearing date is reserved through the Court Reservation System.
Motion fee payments are required at the time reservations are made online.
Page 2 | Law and Motion
Ex parte applicants must pay the filing fee before appearing in court.
Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in court.
Page 3 | E. EX PARTE APPLICATIONS
A stipulation and order for continuance must be submitted with payment of the stipulation and order fee and the first appearance fee of all parties to the stipulation.
A stipulation and order shall state the date the complaint was filed, the proposed continuance date(s), grounds showing good cause for the continuance, and be submitted with payment of the stipulation and order fee and first appearance fee of all parties to the stipulation.
Page 2 | Continuances
Jury fees must be paid daily in room 102 on the first floor.
Jury fees must be paid on a daily basis, in room 102, on the first floor.
Page 2 | JURY FEES
Jury fees must be paid daily in room 102 of the first floor.
Jury fees must be paid on a daily basis, in room 102, on the first floor.
Page 2 | TRIAL PROCEDURES
Courtesy Copy Requirements
Parties must jointly lodge one set of tabbed 3-ring binders containing copies of their Trial Readiness Documents at the TRC.
The parties shall jointly prepare and lodge, at the TRC, one set of tabbed 3-ring binders containing copies of the parties' Trial Readiness Documents.
Page 10 | k) Trial Readiness Binder and USB Drive
Courtesy copies of all electronically filed motion-related documents must be delivered to Department 415 within one court day of e-filing.
Courtesy copies of all motion-related documents filed electronically must be delivered to Department 415 within one (1) court day of the electronic filing.
Page 2 | Law and Motion
Counsel must deliver a tabbed binder of all motions in limine, oppositions, and replies in sequential order to the Court five days before the FSC.
Five (5) days before the FSC, counsel must provide a tabbed binder containing all motions in limine, oppositions, and replies in sequential order consistent with the number assigned to each motion in limine.
Page 5 | 3. Motions in Limine
Courtesy copies must be delivered directly to the courtroom, Department W, pursuant to the General Order re Mandatory Electronic Filing.
Please deliver courtesy copies directly to the courtroom, Department W pursuant to the General Order re Mandatory Electronic Filing.
Page 1 | FILINGS
Exhibits must be brought to the Final Status Conference, with three exhibit books provided for the Court, the clerk, and the witness stand.
Exhibits must be brought to court at the Final Status Conference. Three exhibit books must be provided: for the Court, the clerk and the witness stand.
Page 2 | EXHIBITS
A courtesy copy of the IDC joint statement must be delivered to Department W three court days before the IDC.
If the Court orders an IDC a joint statement of discovery in dispute (no more than five pages) shall be filed and a courtesy copy delivered to Department W three (3) court days before the IDC.
Page 2 | INFORMAL DISCOVERY CONFERENCES
Courtesy copies of all documents referred to in the Case Management Conference Order must be lodged in Department W.
All documents referred to in this order must be filed and courtesy copies shall be lodged in Department W.
Page 3 | CASE MANAGEMENT CONFERENCE ORDER
A courtesy copy of a Request for Dismissal of the entire action or Notice of Settlement must be provided to Department W at least two court days before the FSC.
as a Request for Dismissal of the entire action or Notice of Settlement under CRC, Rule 3.1385 has been filed with a courtesy copy provided to Department W at least two court days before the FSC.
Page 4 | CASE MANAGEMENT CONFERENCE ORDER
Three complete sets of exhibits must be lodged: one for the Court, one for the clerk, and one for the witnesses.
Three complete sets of exhibits shall be lodged: one for the Court, one for the clerk and one for the witnesses.
Page 5 | Exhibits
The moving party must deliver a binder containing all motions in limine papers (moving, opposition, and reply) directly to Department W at least two court days before the FSC.
At least two (2) court days prior to the FSC, the moving party shall provide a binder of all motions in limine documents including the moving, opposition and reply papers directly to Department W.
Page 6 | PRE-TRIAL MOTIONS, INCLUDING BUT NOT LIMITED TO MOTIONS IN LIMINE
Parties should provide electronic copies of trial readiness documents to the Court on a USB drive.
The parties should also provide electronic copies of trial readiness documents on a USB drive for the Court.
Page 10 | k) Trial Readiness Binder and USB Drive
Courtesy copies are not required.
Courtesy copies are not required.
Page 2 | FILINGS
Sealing & Redaction Procedures
Sealing is governed by CRC 2.550 and 2.551; party agreement alone is insufficient because the Court must make specific findings for every sentence to be sealed, be persuaded of a legal justification, and enter a narrowly tailored sealing order.
All parties must strictly comply with California Rules of Court 2.550 and 2.551. The Court cannot seal documents filed in Court merely because the parties agree they should be sealed. The Court's obligation to conduct all proceedings with transparency means that the Court must make specific findings as to every sentence in every document that a party wishes to file under seal. The Court must be persuaded that there is a legal justification for sealing. The sealing order must be narrowly tailored to seal only the specific information that is protected by the right to privacy, the trade secrets law, or other applicable protections.
Page 5 | 9) FILING AND LODGING DOCUMENTS UNDER SEAL
Confidential material filed with discovery motions is exempt from CRC 2.550/2.551 and must instead be narrowly redacted, submitted unredacted in a sealed envelope stapled behind a caption page identifying the discovery-motion submission, and filed in redacted public form.
Confidential documents submitted in connection with discovery motions are not governed by Rules 2.550 and 2.551. To file confidential material in connection with discovery motions, the parties should (a) narrowly identify and redact the confidential information from the confidential document; (b) submit an unredacted version in a sealed envelope stapled behind the caption page of the document (making sure that the caption page states that the submission is for a discovery motion); and (c) file a redacted version of the document (making it available to the public in the court file).
Page 5 | 9) FILING AND LODGING DOCUMENTS UNDER SEAL
Filing Bundling Requirements
Uncontested CACI instructions must be submitted as a single joint packet, with each counsel's individually requested instructions inserted into that same packet.
a. A JOINTLY submitted packet of all requested and properly and fully edited CACI instructions to which there is no objection. (LACCR, Rule 8.25) (Note: Counsel are advised to make all edits necessary to eliminate duplicate instructions and inconsistencies.) b. Each counsel may submit specifically requested and properly edited instructions not requested by the opposing party. These instructions shall be inserted into the aforementioned packet of the jointly submitted jury instructions, all to be considered and discussed by the Court at an appropriate time during the trial.
Page 5 | Trials
Pre-Motion Conference Requirements
Before preparing an ex parte application for emergency relief, parties must post a joint request for an informal conference on the e-service bulletin board and contact courtroom staff to obtain a time and date.
Before investing any time in the preparation of an ex parte application, please post a joint request for an informal conference on the e-service bulletin and contact the courtroom staff to obtain a time and date.
Page 1 | 1) Judge Cunningham's Philosophy - b) Ex Parte Applications Should Not be Necessary
Parties must meet and confer twice by telephone or video before requesting an IDC, and are expected to extend motion-to-compel deadlines to accommodate the process.
Judge Cunningham requires the parties to meet and confer twice via telephone or video conference before requesting an IDC and expects the parties to extend the time for filing motions to compel to accommodate this process.
Page 3 | 5) Informal Discovery Conferences (IDCs)
Parties must meet and confer in real time (video conference or telephone) before preparing any motion challenging or seeking to amend the pleadings.
To avoid the inefficiency of preparing, opposing and potentially hearing demurrers that are moot or to otherwise cannot be granted, the court requires the parties to meet and confer in real time (video conference or telephone) before preparing any motion challenging or seeking to amend the pleadings.
Page 4 | 6) Informal Resolution of Demurrers and Other Motions to Challenge or Amend the Pleadings
Before filing a motion challenging or amending the pleadings, the parties must confer with the Court at a status conference or an informal pleadings conference scheduled via joint bulletin board posting.
Before such a motion is filed, the Court also requires the parties confer with the Court, either at a status conference or an informal pleadings conference scheduled in response to a joint posting on the bulletin board.
Page 4 | 6) Informal Resolution of Demurrers and Other Motions to Challenge or Amend the Pleadings
Counsel must identify all intended motions at status conferences, and before working on a motion not previously discussed with the Court must request an informal conference via the bulletin board or propose the motion at the next status conference.
The Court expects counsel to identify all intended motions when counsel appear for status conferences so that the Court can explore, with counsel, whether the Court can reach the substantive issue such a motion and whether the proposed motion is the most efficient and effective "next step" in the proceedings. The parties should not surprise the court by filing motions they have not proposed to the Court. Before starting work on a motion not previously discussed with eCourt, a party should request, via the bulleting board, an information conference with the court, or porose the motion at the next status conference.
Page 5 | 8) MOTIONS
Parties must meet and confer both before and after filing motions in limine to reach evidentiary stipulations and limit contested motions to a manageable number.
Before and after filing motions in limine, the parties shall meet and confer in an effort to reach stipulations resolving disputes over the admissibility of evidence and to limit the contested motions in limine to a manageable number.
Page 9 | e) Motions In Limine
Parties must meet and confer to resolve objections to the admissibility of each exhibit, per Local Rules 3.52(i)(5) and 3.53.
To comply with Local Rules 3.52(i)(5) and 3.53, the parties shall meet and confer in an effort to resolve objections to the admissibility of each exhibit.
Page 10 | h) Joint Exhibit List
Moving parties must reserve a hearing date through the online civil Court Reservation System before filing any motion, except motions in limine which are heard at the Final Status Conference.
Moving parties must secure a hearing date via the online Court Reservation System on the Superior Court of Los Angeles County website. Please see the "Online Services" section to find the civil Court Reservation System at www.lacourt.ca.gov to reserve a hearing date prior to filing any motion, except for motions in limine, which, by Local Rule, are heard during the Final Status Conference.
Page 2 | Law and Motion
Motions in limine are heard at the FSC (per Local Rule 3.25(f)(2) and CCP sections 1005(b) and 1013) and must not be calendared through the Court Reservation System.
Motions in limine will be heard at the time of the FSC. See Local Rule 3.25(f)(2). Motions in limine are governed by the statutory notice requirements set forth in Code of Civil Procedure sections 1005(b) and 1013. Because motions in limine will be heard at the time of the FSC, they should not be calendared through the Court Reservation System.
Page 5 | 3. Motions in Limine
All motions to be heard in Department W must first be reserved through the Court Reservation System (CRS) on the court's website.
All motions to be heard in Department W are to be reserved through the Court Reservation System. Follow the links Online Services – Court Reservation System (CRS) on the court's website.
Page 2 | MOTIONS
Counsel must meet and confer on all motions in limine, and failure to exchange or discuss them may result in the court refusing to hear the motion.
Counsel shall meet and confer on all motions in limine.
Page 6 | PRE-TRIAL MOTIONS, INCLUDING BUT NOT LIMITED TO MOTIONS IN LIMINE
Parties must meet and confer with opposing counsel to try to agree on recoverable costs before filing a motion to tax costs.
Please meet and confer with opposing counsel in an effort to agree upon recoverable costs and to avoid unnecessary motions to tax costs.
Page 5
For summary judgment/adjudication motions, parties must meet and confer before the motion is filed to avoid a continuance of the hearing date (source sentence is truncated).
To avoid a continuance of the hearing date, please meet and confer before the motion is filed to
Page 6 | 12) MOTIONS FOR SUMMARY JUDGMENT OR ADJUDICATION
Before filing a discovery motion, trial counsel should meet and confer to resolve or narrow the dispute.
Before filing a discovery motion, trial counsel should meet and confer in person, by phone, or by videoconference to resolve, or at least narrow the dispute.
Page 2 | HEARINGS
Counsel must meet and confer on discovery issues; informal discovery conferences with the court are encouraged.
If discovery issues arise, counsel is to fully meet and confer. The parties are encouraged to schedule an informal discovery conference with the court.
Page 2 | DISCOVERY
Counsel must fully meet and confer on discovery issues, and parties are encouraged to schedule an informal discovery conference with the court.
If discovery issues arise, counsel is to fully meet and confer. The parties are encouraged to schedule an informal discovery conference with the court.
Page 2 | PRE-TRIAL INFORMATION
For discovery disputes (other than deposition impasses), parties may request an informal conference by making a joint posting on the e-service bulletin board.
For other discovery disputes, the parties may request an information conference by making a joint posting on the e-service bulletin board.
Page 1 | 1) Judge Cunningham's Philosophy - a) The Court is Available for Informal Conferences on Short Notice
Parties are not required to hold an Informal Discovery Conference before filing a discovery motion.
There is no requirement to hold an IDC prior to filing a discovery motion.
Page 2 | INFORMAL DISCOVERY CONFERENCES
Adjournment & Extension Requirements
Motions must be taken off calendar no later than two business days before the hearing.
The deadline to take any motions off calendar is two business days before the hearing.
Page 2 | TENTATIVE RULINGS
A stipulation and order for continuance must state the complaint filing date, proposed continuance dates, and good-cause grounds, and must be submitted with the required fees.
A stipulation and order shall state the date the complaint was filed, the proposed continuance date(s), grounds showing good cause for the continuance, and be submitted with payment of the stipulation and order fee and first appearance fee of all parties to the stipulation.
Page 2 | Continuances
The court will not continue hearing or trial dates when there is opposition absent a showing of good cause.
PLEASE NOTE THE COURT DOES NOT CONTINUE HEARING/TRIAL DATES IF THERE IS AN OPPOSITION WITHOUT A SHOWING OF GOOD CAUSE.
Page 2 | Continuances
Telephonic continuance requests are not accepted, but the Court will entertain stipulated continuance requests and telephonic conferences regarding trial continuance issues.
This Court does not accept telephonic continuances. However, the Court will entertain stipulated continuance requests and telephonic conference to discuss trial continuance issues.
Page 1 | PRE-TRIAL INFORMATION
Telephonic continuances are prohibited; stipulated continuances and telephonic conferences for trial continuances are allowed.
This Court does not accept telephonic continuances. However, the Court will entertain stipulated continuance requests and telephonic conference to discuss trial continuance issues.
Page 1 | PRE-TRIAL INFORMATION
If both parties agree, they may file a stipulation and proposed order to continue a status conference at least five court days in advance, explaining why the continuance is warranted.
If the parties agree that they are making progress and there is no particular reason to appear for a status conference, they may file (at least five court days prior) a stipulation and proposed order to continue the status conference that explains why the conference should be continued.
Page 2 | Initial Status Conference / Status Conferences (p. 2, before Section 3)
Law and motion matters may be continued by CRS, Stipulation and Order, or Ex Parte Application, but telephone continuances are not permitted.
Calendar: Law and motion matters may be continued by the CRS system, by Stipulation and Order, or by Ex Parte Application. Telephone continuances are not permitted. Matters may be taken off- calendar by directly contacting
Page 2 | HEARINGS
Absent a stipulation, continuances may be sought by noticed motion or ex parte application.
If there is no stipulation, the parties may seek a continuance by noticed motion or an ex parte application.
Page 2 | Continuances
Chambers Communication Rules
To reserve a hearing date for a motion, a party must telephone the Courtroom Assistant at (213) 310-7011.
To reserve a hearing date for a motion please telephone the Courtroom Assistant at (213) 310-7011.
Page 5 | 8) MOTIONS
The moving party must notify the Court as early as possible that a matter will go off calendar under CRC 3.1306(b), by posting the announcement on the e-service bulletin board and telephoning the courtroom.
To help the Court avoid unnecessary preparation for motions that will not be heard, the moving party must inform the Court, at the earliest possible moment, that a matter will go off calendar. This is required under California Rules of Court 3.1306(b). Please also post the announcement on the e-service bulletin board and telephone the courtroom.
Page 6 | 11) PROMPTLY TAKE HEARINGS OFF CALENDAR
Counsel submitting on a tentative ruling must email the court at sscdept27@lacourt.ca.gov with the case number, identification of the submitting party, and a cc to opposing counsel.
Counsel who intend to submit on this tentative must send an email to the court at sscdept27@lacourt.c a.gov. If counsel submits on the tentative, counsel's email must include the case number and identify the party submitting on the tentative with a copy (cc) to opposing counsel.
Page 1 | TENTATIVE RULINGS
Chambers email is sscdept27@lacourt.c a.gov; counsel must use this email to submit on tentative rulings with required case number, party identification, and cc to opposing counsel.
E-MAIL: sscdept27@lacourt.c a.gov Counsel who intend to submit on this tentative must send an email to the court at sscdept27@lacourt.c a.gov. If counsel submits on the tentative, counsel's email must include the case number and identify the party submitting on the tentative with a copy (cc) to opposing counsel.
Page 1
Judicial Assistants in Department 27 do not respond to phone calls before 10:30 a.m. unless the call concerns a matter on calendar that morning, and the best time to call is after 3:00 p.m.
Judicial Assistants will not respond to calls before 10:30 a.m. unless the call concerns a matter on calendar that morning. The best time to reach Judicial Assistants is after 3:00 p.m.
Page 1 | GENERAL INFORMATION
Parties or counsel who will be late for a hearing must contact the court staff (Department 415, (213) 633-0159).
If parties/counsel are going to be late for a hearing, please contact the court staff.
Page 1 | A. GENERAL
Judicial Assistants will not respond to phone calls before 10:00 a.m. unless the call concerns a matter on that morning's calendar.
(Judicial Assistants may not respond to phone calls before 10:00 a.m. unless the call concerns a matter on calendar that morning.)
Page 1
Parties at an impasse during a deposition may telephone the courtroom at (213) 310-7011 to arrange an immediate conference call with the Court.
Parties who reach an impasse during a deposition may telephone the courtroom to arrange an immediate conference call with the Court.
Page 1 | 1) Judge Cunningham's Philosophy - a) The Court is Available for Informal Conferences on Short Notice
Judicial assistants will not respond to phone calls before 10:00 a.m. except for matters on that morning's calendar.
(Judicial Assistants may not respond to phone calls before 10:00 a.m. unless the call concerns a matter on calendar that morning.)
Page 1 | GENERAL INFORMATION
Department 27 judicial assistants are available by phone at 213-310-7127 with restricted response hours.
PHONE: 213-310-7127 (Judicial Assistants will not respond to calls before 10:30 a.m. unless the call concerns a matter on calendar that morning. The best time to reach Judicial Assistants is after 3:00 p.m.)
Page 1
Clerk's Office assistance is available by calling 213-830-0800 (Stanley Mosk) or 213-310-7000 (Spring Street).
For Clerk's Office assistance, call the Court Support Service numbers: 213-830-0800 Stanley Mosk & 213-310-7000 Spring St
Page 2 | CLERK'S OFFICE AND COURT SUPPORT SERVICES
Clerk and self-help assistance is available by telephone or in person, with call centers open 8:30 a.m. to 4:30 p.m., Monday through Friday, except court holidays.
There are two ways to meet with a clerk or get self-help information: by telephone or in person. Call centers are available for assistance from 8:30 a.m. - 4:30 p.m., Monday through Friday, except Court holidays.
Page 2 | CLERK'S OFFICE AND COURT SUPPORT SERVICES
Self-Help services are available by phone at 213-830-0845.
For Self-Help services, call the Self-Help Center for assistance at 213-830-0845.
Page 2
Self-Help services are available by calling the Self-Help Center at 213-830-0845.
For Self-Help services, call the Self-Help Center for assistance at 213-830-0845.
Page 2 | CLERK'S OFFICE AND COURT SUPPORT SERVICES
Clerk’s Office assistance is available by phone at 213-830-0800 (Stanley Mosk) and 213-310-7000 (Spring St) during specified weekday hours.
For Clerk’s Office assistance, call the Court Support Service numbers: 213-830-0800 Stanley Mosk & 213-310-7000 Spring St Call centers are available for assistance from 8:30 a.m. - 4:30 p.m., Monday through Friday, except Court holidays.
Page 2
Non-urgent inquiries to Department 415 court staff may only be made between 10:00 a.m.-12:00 p.m. or 2:00 p.m.-5:00 p.m.
For all other inquiries, please contact the court staff between 10:00 a.m. and 12:00 p.m. or between 2:00 p.m. and 5:00 p.m.
Page 1 | A. GENERAL
Chambers email address is sscd@t28@lacourt.ca.gov.
E-MAIL: sscd@t28@lacourt.ca.gov
Page 1
Chambers phone number is 213-310-7128.
PHONE: 213-310-7128
Page 1
Chambers can be contacted via phone at (213) 633-0689 during courtroom hours for scheduling and conferences.
COURTROOM HOURS: 8:30 A.M. to 12:00 P.M. and 1:30 P.M. to 4:30 P.M. TELEPHONE: (213) 633-0689 Please call the Judicial Assistant at (213) 633-0689.
Page 1 | GENERAL INFORMATION
Parties may call the Judicial Assistant at (213) 633-0689 to schedule informal discovery conferences.
Please call the Judicial Assistant at (213) 633-0689.
Page 2 | PRE-TRIAL INFORMATION