Judge Ashfaq G. Chowdhury
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
All filings
- 0 copies • Upon Specific Request
Courtesy copies
- Not required
Ex Parte Opposition
- 1 copy • Hand Delivery • Day Of Hearing
Exhibits
- 1 copy • At Final Status Conference
Adjournments
Court-wideRequest must include
Communication
Phone
Chambers
Phone
Clerk, Other
Phone
Chambers
Chambers
Chambers
Phone
Court-widePhone
Court-widePage & Word Limits2 rules
Individual IDC statements are limited to 2 pages and joint IDC statements to 5 pages (preferred), both filed without attachments.
Five days before the IDC, each counsel shall file and serve an IDC statement no longer than 2 pages, without attachments, or a joint IDC statement no longer than 5 pages, without attachments (preferred).
Individual Idc Statement
2 pages
Joint Idc Statement
5 pages
Individual IDC statements limited to 2 pages; joint IDC statements limited to 5 pages, both without attachments.
Five days before the IDC, each counsel shall file and serve an IDC statement no longer than 2 pages, without attachments, or a joint IDC statement no longer than 5 pages, without attachments (preferred).
Idc Statement
2 pages
Applies to: Attorney
Joint Idc Statement
5 pages
Applies to: Attorney
Document Format Requirements13 rules
CMC statements must be filed on Judicial Council Form CM-110 within 5 days of the hearing.
file a CMC statement on Judicial Council Form CM-110 within five (5) days of the hearing.
Trial binders must be three-ring binders with tabs labeled A, B, C, D, F, G, H, I, J as specified.
By no later than 3 calendar days before the Final Status Conference, the parties are to submit to the Court a hard copy binder containing these previously filed documents under the following tabs: Tab A – Trial Briefs, Tab B – Joint Witness List, Tab C – Joint Exhibit List, Tab D – Joint Statement to Be Read to the Jury, Tab F – Full Text Jury Instructions (Joint and Contested), Tab G – Joint Verdict Form, Tab H – Joint Page and Line Designation for Deposition and Former Testimony, Tab I – Copies of the Current Operative Pleadings, Tab J – Motions in Limine (unless they are voluminous enough to merit their own binder).
Proposed jury instructions must be prepared on Los Angeles Superior Court form SCLAC LACIV 129 or in a Word document in the same format.
The proposed jury instructions shall be prepared on Superior Court of Los Angeles County form SCLAC LACIV 129 or in a Word document that is in the same format.
DOCX
Parties must attach copies of the designated transcript pages to the Joint Chart with numbered tabs separating each transcript, and all designated pages for each transcript must appear in page order behind a single tab.
The parties shall attach a copy of the pages of the transcripts of the deposition or former testimony they are designating or counter-designating to the Joint Chart of Page and Line Designations for Deposition and Former Testimony, with numbered tabs separating each deposition or trial transcript. For each transcript, all pages containing the designations and counter-designations shall be included in a single document in page order behind a single tab.
Copies of motions in limine, opposition, and reply papers must be organized in one or more three-ring binders, tabbed numerically, with opposition and reply papers placed directly behind the moving papers and separated by colored sheets (sentence continues from prior page).
copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders, tabbed in numerical order with the opposition papers and reply papers for each motion placed directly behind the moving papers with a colored sheet of paper separating the moving, opposition, and reply papers.
Counsel and self-represented parties must jointly prepare four sets of tabbed, internally paginated, properly marked exhibits organized numerically in three-ring binders (sets for the court, the Judicial Assistant, and the witnesses).
The parties' counsel and any self-represented parties shall work together to jointly prepare four sets of tabbed, internally paginated by document, and properly marked exhibits, organized numerically in three-ring binders (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) ("Exhibit Binders").
Each designation and counter-designation in the Joint Chart must be highlighted, with each party using a different color highlighter.
Each designation and counter-designation shall be highlighted, with each party using a different color highlighter.
Parties filing more than one motion in limine must number the motions consecutively.
Parties filing more than one motion in limine shall number them consecutively.
All non-documentary exhibits must be marked and a simple written description of each inserted behind the corresponding numerical tab in the Exhibit Binders.
The parties' counsel and any self-represented parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the Exhibit Binders.
The court's yellow evidence tags (filled in with only the case number and exhibit number) must be placed on each exhibit in the Judicial Assistant's copy of the Exhibit Binder.
The parties' counsel and any self-represented parties shall also place the court's yellow evidence tags (with only the case number and exhibit number filled in) on each exhibit in the Judicial Assistant's copy of the Exhibit Binder.
The Trial Binder must consist of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents.
a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents
Documentary exhibit copies must be one-sided.
Copies of documentary exhibits shall be one-sided copies.
Name on signature line of Joint Case Management Conference Statement Addendum must be typed or printed.
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Document Filing Requirements31 rules
Parties must file a CMC statement on Judicial Council Form CM-110 within five days of the case management conference hearing.
The parties are to (1) meet and confer—in person or by telephone—no later than 30 days before the hearing, and (2) file a CMC statement on Judicial Council Form CM-110 within five (5) days of the hearing.
Document Type
Cmc Statement
Ex parte applications must include a proposed order with the moving papers.
the notice must be included in the declaration and a proposed order must be presented with the moving papers.
Document Type
Ex Parte Application
Ex parte applications must include the notice in the declaration and present a proposed order with the moving papers.
The notice must be included in the declaration and a proposed order must be presented with the moving papers.
Document Type
Ex Parte Application
Parties without a court reporter must prepare a joint statement of each day's witness testimony at the close of the session and lodge it with the Court the next morning before proceedings resume — no exceptions.
Parties who do not provide a court reporter for trial are directed to meet at the close of each session and prepare a joint statement of the witness testimony presented that day. The joint statement must be lodged with the Court the next morning before proceedings resume. No exceptions.
Document Type
Joint Statement Of Witness Testimony
The joint witness list must contain seven specified columns (witness name/expert status/accommodations, calling party, expected testimony, direct/cross/total time estimates in hours) plus a grand total, and any witness not listed is subject to being excluded.
The joint witness list shall be organized with columns (in the format set forth below) which state (1) the name of each witness (in alphabetical order), if the witness is being called to testify as an expert, and any special requirements or accommodations needed for the witness (e.g., interpreter), (2) the party calling the witness, (3) whether the witness is actually expected to testify, (4) a brief description of the witness's expected testimony, (5) an estimate of the length of direct examination (in hours), (6) an estimate of the length of cross-examination (in hours), and (7) the total estimated length of examination (in hours). At the end of the joint witness list, the parties and any self-represented parties shall add up the estimated times for all witnesses' testimony and state the grand total in the last column. Any witness who is not included on the joint witness list is subject to being excluded from
Document Type
Joint Witness List
Each party must file a trial brief identifying the disputed claims and defenses, major legal issues with supporting authorities, relief and damages calculation, and any other information assisting the court at trial.
Each party shall file a trial brief succinctly identifying: (1) the claims and defenses that remain in dispute for trial; (2) the major legal issues (with supporting points and authorities); (3) the relief and calculation of damages sought; and (4) any other information that may assist the court at trial.
Document Type
Trial Brief
Parties' counsel and self-represented parties must jointly prepare and file a list of all trial witnesses, excluding impeachment and rebuttal witnesses (Local Rule 3.25(g)(5)).
The parties' counsel and any self-represented parties shall work together to prepare and file a joint list of all witnesses whom any party intends to call at trial, excluding impeachment and rebuttal witnesses.
Document Type
Joint Witness List
For jury trials, the parties must jointly prepare and file a brief written statement of the case for the court to read to the jury.
For jury trials, the parties' counsel and any self-represented parties shall work together to prepare and file a brief, joint written statement of the case for the court to read to the jury. (Local Rule 3.25, subd. (g)(4).)
Document Type
Joint Statement Of Case
Counsel and self-represented parties must jointly prepare and file an exhibit list stating eight specified items for each trial exhibit and must meet and confer to resolve authenticity and admissibility objections.
The parties' counsel and any self-represented parties shall work together to prepare and file a joint exhibit list organized with columns (in the format set forth below) which state, as to each exhibit any party intends to offer at trial: (1) the exhibit number, (2) a brief description of the exhibit, (3) which party is offering the exhibit, (4) whether the parties have stipulated to authentication of the exhibit, (5) whether the parties have stipulated to admissibility of the exhibit, (6) any evidentiary objections to admission of the exhibit, (7) the date the exhibit was marked for identification, and (8) the date the exhibit was admitted into evidence. (Local Rule 3.25, subd. (g)(6).) As set forth above, the parties' counsel and any self-represented parties shall meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit.
Document Type
Joint Exhibit List
For jury trials, the parties must jointly prepare a complete set of full-text proposed jury instructions, editing CACI instructions, inserting party names, and removing blanks and irrelevant material.
For jury trials, the parties' counsel and any self-represented parties shall work together to prepare a complete set of full text proposed jury instructions, editing all proposed Judicial Council of California Civil Jury Instructions ("CACI") instructions, inserting party names, and eliminating blanks and other irrelevant or inapplicable material.
Document Type
Proposed Jury Instructions
For jury trials, the parties must jointly prepare and file a list of proposed jury instructions stating six specified items for each instruction.
For jury trials, the parties' counsel and any self-represented parties shall work together to prepare and file a joint list of proposed jury instructions (in the format set forth below) which states, as to each proposed jury instruction: (1) the jury instruction number (listed in numerical order), (2) the title of the jury instruction, (3) the party requesting the jury instruction, (4) whether the jury instruction is agreed upon or contested, (5) a concise statement of any objection, and (6) whether the jury instruction was given by the court ("Joint List of Proposed Jury Instructions").
Document Type
Joint List Of Proposed Jury Instructions
For jury trials, parties must jointly file a proposed verdict form acceptable to all parties, or, if they cannot agree, each party must separately file a proposed verdict form.
For jury trials, the parties' counsel and any self-represented parties shall work together to prepare and file a joint proposed general verdict form or a joint proposed special verdict form acceptable to all parties. (Local Rule 3.25, subd. (g)(8).) If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.
Document Type
Proposed Verdict Form
Parties intending to use deposition or former trial testimony must meet and confer and jointly prepare and file a Joint Chart of Page and Line Designations.
If any parties intend to use deposition testimony or former trial testimony in lieu of or in addition to a witness's live testimony, the parties' counsel and any self-represented parties shall meet and confer to discuss, and work together to prepare and file, a joint chart in the format set forth below ("Joint Chart of Page and Line Designations for Deposition and Former Testimony").
Document Type
Joint Chart Of Page And Line Designations
Motions in limine must be accompanied by declarations that comply with Los Angeles County Court Rule 3.57(a).
The parties' counsel and any self-represented parties shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and file declarations that comply with the requirements of Los Angeles County Court Rule 3.57, subdivision (a).
Document Type
Motion In Limine
The Trial Binder must contain tabbed sections for Trial Briefs, Joint Witness List, Joint Exhibit List, Joint Statement to the Jury, Jury Instructions, Verdict Forms, Deposition Designation Chart, Operative Pleadings, and Motions in Limine (unless too voluminous for the binder).
Tab A: Trial Briefs Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Statement to Be Read to the Jury Tab F: Joint and Contested Jury Instructions Tab G: Joint or Contested Verdict Form(s) Tab H: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab I: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint). Tab J: Motions in Limine, unless they are too voluminous and require their own binder.
Document Type
Trial Binder
Parties must serve verification with all produced discovery documents.
Plaintiff and defendant shall serve verification with the documents they produce.
Document Type
Discovery Production
The list of substantially similar customer complaints must be in chart or spreadsheet form including VIN, repair visit date, location, and complaint text, and must exclude all other customers' personal identifying information.
The list provided by defendant may be in the chart or spreadsheet format, and shall include the VIN, date of repair visit, dealership or other reporting location, and text of the other customers' reported complaint, but shall not include the other customers' names, addresses, phone numbers, e-mail addresses, or other personal identifying information.
Document Type
Customer Complaint List
Both plaintiff and defendant must serve a verification along with the documents they produce.
Plaintiff and defendant shall serve verification with the documents they produce.
Document Type
Document Production
All parties must meet and confer in person or by telephone and respond to the addendum's questions, stating their respective positions.
You are ordered to meet and confer in person or by telephone and to respond to the following questions, stating your respective positions.
Document Type
Joint Case Management Conference Statement Addendum
The case management conference addendum must include a signed certification that the signer is fully familiar with the case, prepared to discuss discovery, ADR, and other addendum issues, and possesses authority (including written party authority where required) to enter stipulations at the initial case management conference.
l am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this addendum, and will possess the authority to enter into stipulations on these issues at the time of the initial case management conference, including the written authority of the party where required.
Document Type
Case Management Conference Addendum
The case management conference addendum must bear the typed or printed name and signature of the party or attorney, with two signature blocks provided.
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Document Type
Case Management Conference Addendum
Joint Case Management Conference Statement Addendum must include a statement that the signer is familiar with the case and has authority to enter into stipulations.
l am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this addendum, and will possess the authority to enter into stipulations on these issues at the time of the initial case management conference, including the written authority of the party where required.
Document Type
Joint Case Management Conference Statement Addendum
If any defendant remains unserved, plaintiff or plaintiff's counsel must submit a declaration to the court explaining what service efforts have been undertaken.
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.
Document Type
Declaration Of Service Efforts
When an appropriate CACI instruction exists on a point of law, the court expects the parties to request it instead of a specially prepared instruction.
If there is an appropriate CACI jury instruction on a point of law, the court expects the parties to request the CACI instruction instead of a specially prepared jury instruction.
Document Type
Proposed Jury Instructions
The Joint Chart must include specified columns for both designations (witness name/number, date and type of testimony, page/line designations, objections, counter-designation info, and court ruling) and counter-designations (witness name/number, date and type of testimony, page/line counter-designations, objections, related designation number, and court ruling).
In the joint chart, each designating party's designations of deposition or former testimony shall include columns which state: (1) the designation number and name of the witness, (2) the date and type of testimony (e.g., deposition or trial testimony), (3) the page and line designations of the deposition or former testimony requested to be used, (4) any objections, (5) whether the other party has counter-designated any additional deposition or former testimony of the witness that relates to the designation, and, if so, the designation number of the counter-designation, and (6) the court's ruling. In the joint chart, each counter-designating party's counter-designations of additional deposition or former testimony of the witness that relates to the designations shall include columns which state: (1) the designation number and name of the witness, (2) the date and type of testimony (e.g., deposition or trial testimony), (3) the page and line counter-designations of the deposition or former testimony requested to be used, (4) any objections, (5) the designation number of the other party's designation to which the counter-designation relates, and (6) the court's ruling.
Document Type
Joint Chart Of Page And Line Designations
Where an appropriate CACI special verdict form exists, the court expects the parties to use it for causes of action, affirmative defenses, or other findings.
there is an appropriate CACI special verdict form for a cause of action, affirmative defense, or other finding, the court expects the parties to use the CACI special verdict form.
Document Type
Special Verdict Form
Opposition and reply papers on motions in limine must identify the corresponding motion number in the caption.
Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.
Document Type
Motion In Limine Opposition And Reply Papers
Each motion in limine caption must concisely identify the evidence the moving party seeks to exclude.
The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to exclude.
Document Type
Motion In Limine
In bench trials (trial by the court without a jury), the Trial Binder includes only Tabs A, B, C, H, and I, with the other sections left empty.
for trials by the court without a jury, the Trial Binder shall include only the documents listed under Tabs A, B, C, H, and I with the other sections left empty
Document Type
Trial Binder
Proposed jury instructions must be grouped behind Tab F in order (labeled by cover sheets): agreed-upon instructions, plaintiff's contested requests, then defendant's contested requests.
The parties shall organize proposed jury instructions into groups behind Tab F in the following order (labeled by cover sheets): (1) the agreed-upon instructions, (2) plaintiff's requested instructions to which defendant objects, and (3) defendant's requested instructions to which plaintiff objects.
Document Type
Jury Instructions
For vehicle-related cases, the case management conference addendum must address the basis for the claim, per se negligence, vehicle code violations, whether the defendant will admit liability, and any pending or contemplated criminal charges or investigations.
d. If so, what is the basis for the claim? e. Is there a claim for per se negligence? f. Is there a claim for violations of the vehicle code? g. If so, what section of the vehicle code? h. Will the defendant admit liability? i. Are there any criminal charges pending or contemplated? j. Is there a criminal investigation on-going?
Document Type
Case Management Conference Addendum
Filing & Service rules
Electronic Filing Rules
Attorneys must e-file ex parte applications by 10 a.m. court day prior to hearing; pro se litigants may file in person on day of hearing.
Ex parte applications must be e-filed and noticed no later than 10 a.m. the court day prior to the hearing. Self-represented litigants must still give proper notice but may file their ex parte application at 8:30 a.m. on the day of the hearing in the Clerk’s Office on the first floor, Room 102.
Page 5 | D. Ex Parte Applications
Ex parte applications must be e-filed and noticed no later than 10 a.m. the court day before the hearing.
Ex parte applications must be e-filed and noticed no later than 10 a.m. the court day prior to the hearing.
Page 5 | III. Pretrial Matters — D. Ex Parte Applications
Parties must electronically file the trial preparation documents (trial briefs, joint lists, jury instructions, verdict form, deposition designations, pleadings, and motions in limine) no later than 5 calendar days before the Final Status Conference.
As set forth in more detail in the Trial Preparation Order, no later than 5 calendar days before the Final Status Conference, the parties must electronically file the documents listed below.
Page 5 | IV. Final Status Conferences
All trial documents must be filed electronically pursuant to the General Order re Mandatory Electronic Filing for Civil dated November 5, 2018.
All trial documents are to be filed pursuant to the General Order re Mandatory Electronic Filing for Civil dated November 5, 2018.
Page 10 | 2. TRIAL DOCUMENTS TO BE FILED
Attorneys must e-file trial documents per 2018 Mandatory E-Filing Order; self-represented litigants are exempt.
All trial documents are to be filed pursuant to the General Order re Mandatory Electronic Filing for Civil dated November 5, 2018. Pursuant to California Rules of Court, Rule 2.253 (b)(2), self-represented litigants are exempt from the mandatory electronic filing requirement.
Page 10 | 2. TRIAL DOCUMENTS TO BE FILED
Self-represented litigants may file their ex parte application in paper at the Clerk's Office (Room 102) at 8:30 a.m. on the hearing day, but must still give proper notice.
Self-represented litigants must still give proper notice but may file their ex parte application at 8:30 a.m. on the day of the hearing in the Clerk's Office on the first floor, Room 102.
Page 5 | III. Pretrial Matters — D. Ex Parte Applications
Self-represented litigants are exempt from the mandatory electronic filing requirement under California Rules of Court, Rule 2.253(b)(2).
Pursuant to California Rules of Court, Rule 2.253 (b)(2), self-represented litigants are exempt from the mandatory electronic filing requirement.
Page 10 | 2. TRIAL DOCUMENTS TO BE FILED
Filing Timing and Cure Windows
The CMC statement must be filed within five (5) days of the case management conference hearing.
The parties are to (1) meet and confer—in person or by telephone—no later than 30 days before the hearing, and (2) file a CMC statement on Judicial Council Form CM-110 within five (5) days of the hearing.
Page 3 | III. Pretrial Matters – A. Case Management Conferences
IDC statements must be filed and served five days before the Informal Discovery Conference.
Five days before the IDC, each counsel shall file and serve an IDC statement no longer than 2 pages, without attachments, or a joint IDC statement no longer than 5 pages, without attachments (preferred).
Page 4 | III. Pretrial Matters – C. Discovery Motions—Informal Discovery Conferences
Oppositions to ex parte applications must be e-filed no later than 8:30 a.m. on the day of the hearing.
Oppositions must be e-filed no later than 8:30 a.m. on the day of the hearing and courtesy copies are required directly in the courtroom.
Page 5 | III. Pretrial Matters — D. Ex Parte Applications
The hard copy trial binder must be submitted to the Court no later than 3 calendar days before the Final Status Conference.
By no later than 3 calendar days before the Final Status Conference, the parties are to submit to the Court a hard copy binder containing these previously filed documents under the following tabs:
Page 5 | IV. Final Status Conferences
Ex parte applications must be e-filed by 10 a.m. the court day prior to the hearing.
Ex parte applications must be e-filed and noticed no later than 10 a.m. the court day prior to the hearing.
Page 5 | D. Ex Parte Applications
Ex parte oppositions must be e-filed by 8:30 a.m. on the day of the hearing.
Oppositions must be e-filed no later than 8:30 a.m. on the day of the hearing and courtesy copies are required directly in the courtroom.
Page 5 | D. Ex Parte Applications
The filing and notice deadline for ex parte applications is 10 a.m. on the court day prior to the hearing.
Ex parte applications must be e-filed and noticed no later than 10 a.m. the court day prior to the hearing.
Page 5 | III. Pretrial Matters — D. Ex Parte Applications
The deadline to electronically file the FSC trial preparation documents is 5 calendar days before the Final Status Conference.
As set forth in more detail in the Trial Preparation Order, no later than 5 calendar days before the Final Status Conference, the parties must electronically file the documents listed below.
Page 5 | IV. Final Status Conferences
Deposition transcripts and discovery responses must be lodged with the Court before trial begins.
Prior to the commencement of the trial, deposition transcripts and discovery responses shall be lodged with the Court (SCLAC Local Rule 3.56).
Page 7 | H. Use of Deposition Transcripts and Discovery Responses
Trial documents must be filed no later than five calendar days before the Final Status Conference.
No later than five calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall file and serve the following documents:
Page 10 | 2. TRIAL DOCUMENTS TO BE FILED
Trial documents must be filed and served no later than 5 calendar days before the Final Status Conference.
No later than five calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall file and serve the following documents:
Page 10 | 2. TRIAL DOCUMENTS TO BE FILED
If motions in limine are too voluminous to fit behind Tab J in the Trial Binder, a separate motion in limine must be submitted no later than three calendar days before the hearing (sentence continues beyond this excerpt).
If the motions in limine are too voluminous to fit behind Tab J in the Trial Binder, the parties must submit a separate motion in limine no later than three calendar days before the
Page 14 | 3. Motions in Limine
The Trial Binder must be jointly prepared and lodged in Department E no later than three calendar days before the Final Status Conference.
No later than three calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department E a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following
Page 15 | 5. TRIAL BINDER
Plaintiff must file the completed Joint Case Management Conference Statement Addendum no later than 5 court days before the Initial Case Management Conference.
Plaintiff is responsible for filing the completed Joint Case Management Conference Statement Addendum no later than five (5) court days before the date set for the Initial Case Management Conference.
Page 21 | Motor Vehicle Personal Injury Cases - Joint Case Management Conference Statement Addendum
Plaintiff must file completed Joint Case Management Conference Statement Addendum no later than 5 court days before the Initial Case Management Conference.
Plaintiff is responsible for filing the completed JointCase Management Conference Statement Addendum no later than five (5) court days before the date set for the Initial Case Management Conference. (See California Rules of Court, Rules 3.724, 3.725.)
Page 21 | Motor Vehicle Personal Injury Cases Joint Case Management Conference Statement Addendum
The declaration explaining service efforts must be submitted to the court five (5) days prior to the case management conference hearing.
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 3 | III. Pretrial Matters – A. Case Management Conferences
Service and Proof of Service Rules
All defendants must be served with the complaint by the case management conference.
All defendants must be served with the complaint by the case management conference.
Page 3 | III. Pretrial Matters – A. Case Management Conferences
PowerPoint slides must be provided to opposing counsel before the presentation, leaving sufficient time to object.
If a PowerPoint is to be used, a copy of the slides must be shared with the opposing counsel prior to the presentation leaving sufficient time to object.
Page 7 | F. Display of Demonstrative Evidence
Before reading deposition, interrogatory, or request-for-admission material into evidence, the party must notify the Court and opposing party of the specific page/line or numbers to be used.
Before reading into evidence any portion of a deposition, interrogatory, or request for admission, the party shall advise the Court and opposing party of the page and line number of the deposition, or the numbers of the interrogatories or requests for admission to be read or shown to the witness (SCLAC Local Rule 3.158).
Page 7 | H. Use of Deposition Transcripts and Discovery Responses
Visual aids or graphic devices intended for closing argument must be shown to the opposing party before closing argument.
The parties are reminded that any visual aids or graphic devices a party intends to use during closing argument must be shown to the opposing party before the closing argument. (Super. Ct. L.A. County, Local Rules, rule 3.180.)
Page 8 | L. Closing Arguments and Jury Instruction
Parties' counsel and self-represented parties must exchange all trial exhibits no later than 18 calendar days before the Final Status Conference.
No later than 18 calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall exchange all exhibits they intend to introduce at trial.
Page 9 | 1. MEET AND CONFER
Trial documents must be served no later than five calendar days before the Final Status Conference.
No later than five calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall file and serve the following documents:
Page 10 | 2. TRIAL DOCUMENTS TO BE FILED
Motions in limine must comply with the statutory notice provisions of Code of Civil Procedure section 1005.
The parties' counsel and any self-represented parties shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and file declarations that comply with the requirements of Los Angeles County Court Rule 3.57, subdivision (a).
Page 14 | 3. Motions in Limine
In Song-Beverly cases, parties must exchange specified documents within 60 days of service of the CMC Order.
Within 60 days of service of this Order both plaintiff and defendant shall provide copies of the following documents, which are in their respective possession, custody and/or control, to the opposing side(s):
Page 18 | 2. Production of Documents
Plaintiff's attorney must serve this Order and the attached Joint Case Management Conference Statement Addendum on all defense attorneys upon service of the Summons and Complaint.
Plaintiff's attorney is ordered to provide service of this Order and the attached Joint Case Management Conference Statement Addendum to all defense attorneys upon service of the Summons and the Complaint.
Page 20 | III. Pretrial Matters
The Motor Vehicle Personal Injury Case Addendum to the Case Management Conference Statement must be served on all parties/attorneys of record concurrently with the Notice of Case Management Conference.
You are ordered to serve this Motor Vehicle Personal Injury Case Addendum to Case Management Conference Statement on all parties/attorneys of record concurrently with the Notice of Case Management Conference.
Page 21 | Motor Vehicle Personal Injury Cases - Joint Case Management Conference Statement Addendum
Discovery documents may be provided as PDF electronically at the producing party's option.
The information may be provided to the opposing party in electronic form as a PDF at the option of the producing party.
Page 19 | 2. Production of Documents
Discovery information produced under the Order may, at the producing party's option, be provided to the opposing party electronically as a PDF.
The information may be provided to the opposing party in electronic form as a PDF at the option of the producing party.
Page 19 | III. Pretrial Matters
Filing Fees and Waivers
Jury fees must be paid daily, with the daily rate provided by the judicial assistant.
Jury fees must be paid on a daily basis. The judicial assistant will advise of the daily rate.
Page 6 | V. Trials — C. Jury Fees
Jury fees must be paid daily; judicial assistant provides the daily rate.
Jury fees must be paid on a daily basis. The judicial assistant will advise of the daily rate.
Page 6 | C. Jury Fees
A party with a fee waiver may request an official court reporter by filing form SCLAC LACIV 269 before the hearing or trial, while a party without a fee waiver may arrange a certified shorthand reporter to serve as official pro tempore reporter.
A party who has received a fee waiver may request an official court reporter by filing form SCLAC LACIV 269 before the hearing or trial. A party who has not received a fee waiver may arrange for the presence of a certified shorthand reporter to serve as official pro tempore reporter.
Page 3 | Court Reporters
Courtesy Copy Requirements
Courtesy copies are not required unless specifically requested, except for IDC statements and ex parte oppositions.
The Court does not require courtesy copies of filed documents unless it makes a specific request. The only exceptions are Informal Discovery Conference Statements and ex parte oppositions, as explained below.
Page 2 | B. Courtesy Copies
Courtesy copies of filed documents are not required unless the Court specifically requests them, except for Informal Discovery Conference Statements and ex parte oppositions.
The Court does not require courtesy copies of filed documents unless it makes a specific request. The only exceptions are Informal Discovery Conference Statements and ex parte oppositions, as explained below.
Page 2 | B. Courtesy Copies
Parties must provide the Court with hard-copy courtesy copies of the IDC statement on the day of filing.
The parties shall provide the Court with hard-copy courtesy copies of the IDC statement on the day of filing.
Page 4 | III. Pretrial Matters – C. Discovery Motions—Informal Discovery Conferences
Hard-copy courtesy copies of IDC statements must be provided to the Court on the day of filing.
The parties shall provide the Court with hard-copy courtesy copies of the IDC statement on the day of filing.
Page 4 | C. Discovery Motions—Informal Discovery Conferences
Ex parte oppositions require courtesy copies delivered to the courtroom by the day of the hearing.
Oppositions must be e-filed no later than 8:30 a.m. on the day of the hearing and courtesy copies are required directly in the courtroom.
Page 5 | D. Ex Parte Applications
Courtesy copies of ex parte oppositions are required directly in the courtroom.
Oppositions must be e-filed no later than 8:30 a.m. on the day of the hearing and courtesy copies are required directly in the courtroom.
Page 5 | III. Pretrial Matters — D. Ex Parte Applications
One set of the Exhibit Binders must be brought to the Final Status Conference for the court to review.
The parties' counsel and any self-represented parties shall bring one set of the Exhibit Binders to the Final Status Conference for the court to review.
Page 15 | 4. EXHIBIT BINDERS
Sealing & Redaction Procedures
A party seeking protection for the ordered discovery information must serve and file a proposed protective order within 5 days of the Order, and the parties must meet and confer on language, with the SCLAC standard Protective Order as the default.
If a party believes any of this information should be subject to a protective order, that party shall serve ad file a proposed protective order within 5 days of this Order and the parties shall meet and confer as to agreeable language for the same. The default will be the standard Protective Order provided by the SCLAC in its website.
Page 19 | III. Pretrial Matters
Filing Bundling Requirements
Hard copy trial binder with specified tabs must be submitted to the Court no later than 3 calendar days before the Final Status Conference.
By no later than 3 calendar days before the Final Status Conference, the parties are to submit to the Court a hard copy binder containing these previously filed documents under the following tabs: Tab A – Trial Briefs, Tab B – Joint Witness List, Tab C – Joint Exhibit List, Tab D – Joint Statement to Be Read to the Jury, Tab F – Full Text Jury Instructions (Joint and Contested), Tab G – Joint Verdict Form, Tab H – Joint Page and Line Designation for Deposition and Former Testimony, Tab I – Copies of the Current Operative Pleadings, Tab J – Motions in Limine (unless they are voluminous enough to merit their own binder).
Page 5 | IV. FINAL STATUS CONFERENCES
Parties must submit a hard copy trial binder of the previously e-filed documents, organized under designated tabs A through J, no later than 3 calendar days before the Final Status Conference.
By no later than 3 calendar days before the Final Status Conference, the parties are to submit to the Court a hard copy binder containing these previously filed documents under the following tabs:
Page 5 | IV. Final Status Conferences
Voluminous motions in limine must be submitted in separate three-ring binders tabbed numerically, with opposition/reply papers behind each motion separated by colored paper, due 3 calendar days before FSC.
If the motions in limine are too voluminous to fit behind Tab J in the Trial Binder, the parties must submit a separate motion in limine binder no later than three calendar days before the Final Status Conference, consisting of copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders, tabbed in numerical order with the opposition papers and reply papers for each motion placed directly behind the moving papers with a colored sheet of paper separating the moving, opposition, and reply papers.
Page 14 | 3. MOTIONS IN LIMINE
Pre-Motion Conference Requirements
Before filing any discovery motion, parties must first meet and confer and, if unresolved, the Court requests they schedule and participate in an Informal Discovery Conference (IDC) with the Courtroom Assistant.
The parties must first meet and confer in person, by video conference, or by telephone call to attempt to informally resolve all discovery issues. If the parties cannot agree, the Court requests that the parties schedule an Informal Discovery Conference (IDC) with the Courtroom Assistant and participate in the IDC before filing any discovery motion.
Page 4 | III. Pretrial Matters – C. Discovery Motions—Informal Discovery Conferences
Parties must obtain and schedule a motion hearing date through the online Court Reservation System (CRS) on the Superior Court of Los Angeles County website.
Parties must obtain and schedule a motion hearing date via the online Court Reservation System (CRS) on the Superior Court of Los Angeles County website: “Online Services” tab.
Page 4 | III. Pretrial Matters – B. Law And Motion
Parties must meet and confer no later than 11 calendar days before the Final Status Conference to prepare required trial documents and binders, attempt stipulations on exhibit authenticity/admissibility and motions in limine, and discuss settlement.
No later than 11 calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall meet and confer to do the following: (1) discuss and prepare the documents required in Sections 2.B-H below, and the Motions in Limine Binder, Exhibit Binders, and Trial Binder required in Sections 3-5 below, (2) discuss and make a good faith effort to stipulate to the authenticity and admissibility of each trial exhibit, (3) discuss and make a good faith effort to stipulate to resolve each motion in limine, (4) discuss and make a good faith effort to settle the case.
Page 9 | 1. MEET AND CONFER
Motions in limine must be noticed for hearing at the Final Status Conference.
Motions in limine shall be noticed for hearing at the Final Status Conference.
Page 14 | 3. Motions in Limine
Chambers Communication Rules
The Department E courtroom can be reached by telephone at (818) 265-6423 during courtroom hours of 8:30 a.m.-Noon and 1:30 p.m.-4:30 p.m.
TELEPHONE NUMBER: (818) 265-6423 COURTROOM HOURS: 8:30 a.m. – Noon 1:30 p.m. - 4:30 p.m.
Page 1 | Courtroom Information
Courtroom phone number is (818) 265-6423, available during 8:30 a.m.–Noon and 1:30 p.m.–4:30 p.m.
TELEPHONE NUMBER: (818) 265-6423. COURTROOM HOURS: 8:30 a.m. – Noon; 1:30 p.m. - 4:30 p.m.
Page 2 | COURTROOM INFORMATION
LACourtConnect technical support available at (213) 830-0400, 7:30 a.m.–5:30 p.m. Monday-Friday (except holidays).
there is a dedicated Service Desk for LACourtConnect users. The Service Desk is available at (213) 830-0400, Monday through Friday (except court holidays), between 7:30 a.m. and 5:30 p.m.
Page 2 | A. Court Appearances
LACourtConnect technical issues should be resolved using the LACourtConnect website resources or the dedicated Service Desk at (213) 830-0400, available weekdays 7:30 a.m.-5:30 p.m. (excluding court holidays), and attorneys should do so before the appearance day.
If you are having difficulties turning on your video camera while using LACourtConnect, please visit https://my.lacourt.org/laccwelcome, where you will find tutorials, instructions, and downloads. Also, please be advised that there is a dedicated Service Desk for LACourtConnect users. The Service Desk is available at (213) 830-0400, Monday through Friday (except court holidays), between 7:30 a.m. and 5:30 p.m. Attorneys are strongly advised to consult these resources before the day of an appearance.
Page 2 | A. Court Appearances
If both parties agree to submit on the tentative ruling, they may notify the Court by phone at (818) 265-6422, though if the other party does not agree, the Court may proceed with the hearing and issue a ruling different from the tentative.
If both parties agree to submit on the tentative, you may let the Court know by calling the Court at (818) 265-6422.
Page 4 | III. Pretrial Matters – B. Law And Motion
Parties agreeing to submit on tentative ruling may notify the Court by calling (818) 265-6422.
If both parties agree to submit on the tentative, you may let the Court know by calling the Court at (818) 265-6422.
Page 4 | B. Law And Motion