Judge Barbara A. Meiers
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Exhibits
- At Trial
Pleading, Ex Parte Motion, Opposition, Reply
- Within Two Days
Pleadings, Ex Parte Motion, Opposition, Reply
- Within 2 Days Of Efiling
All filings
Court-wide- Chambers Drop Off • Upon Filing
- Hand Delivery
Adjournments
- For fully stipulated law and motion continuances, the attorney appearing on the hearing date should request priority so the Court can accommodate counsel quickly.
- Continuances may only be sought by written ex parte application, noticed motion, or oral request, and no continuance request or stipulation is effective until the court grants it.
- Continuance requests must be made in writing before the original date set, except for emergencies or matters arising during a hearing.
- +3 more
Request must include
Communication
Phone
Chambers
Phone
Clerk
Phone
Court-wideDocument Format Requirements1 rule
Motions in limine should be numbered sequentially by each side for easy reference.
Document Filing Requirements17 rules
The lodged original order must not say 'proposed' in the caption and must not have a proof of service attached to it.
It should not say "proposed" in the caption and should not have a proof of service attached to it.
Document Type
Original Order Or Judgment
Proposed orders must be included in the moving papers package and served on parties.
A “proposed order” should continue to be included in the package of moving papers and served upon the parties.
Document Type
Motion
A proposed order must be included in the package of moving papers and served upon the parties.
A "proposed order" should continue to be included in the package of moving papers and served upon the parties.
Document Type
Motion
Original orders/judgments submitted for signature in Dept 636 must not be marked 'proposed' and must not have a proof of service attached.
The Court asks that all moving parties lodge the original order or judgment that they wish the Judge in Department 636 to sign no later than the hearing set on a motion or as requested by the court after trial. It should not say “proposed” in the caption and should not have a proof of service attached to it. Do not put “Proposed” on that original order or judgment, and most importantly, DO NOT ATTACH A PROOF OF SERVICE TO THE ORIGINAL!
Document Type
Original Order For Signature
Moving parties must lodge the original order or judgment they want signed no later than the motion hearing (or as requested by the court after trial).
The Court asks that all moving parties lodge the original order or judgment that they wish the Judge in Department 636 to sign no later than the hearing set on a motion or as requested by the court after trial.
Document Type
Original Order Or Judgment
In summary judgment papers, every factual statement must be supported by a citation to the supporting declaration(s) and/or exhibit(s) placed next to the statement; citing only the 'statement of undisputed facts' is not permitted.
When a factual claim is made in these documents, just as is the case with regard to all other kinds of motions and responsive papers, a citation to the declaration(s) and/or exhibit(s) supporting that claim assertion must be set forth next to the factual statement, NOT A REFERENCE TO THE "STATEMENT OF UNDISPUTED" FACTS WHICH HAS THE EFFECT OF DIRECTING THE COURT TO SEARCH ONE SOURCE IN ORDER TO GET TO ANOTHER SOURCE FOR EVIDENTIARY SUPPORT FOR THE FACTS IN ISSUE!
Document Type
Summary Judgment Papers
Motions and briefs must include evidentiary citations next to factual claims, not just references to separate statement of undisputed facts.
When a factual claim is made in these documents, just as is the case with regard to all other kinds of motions and responsive papers, a citation to the declaration(s) and/or exhibit(s) supporting that claim assertion must be set forth next to the factual statement, NOT A REFERENCE TO THE “STATEMENT OF UNDISPUTED” FACTS WHICH HAS THE EFFECT OF DIRECTING THE COURT TO SEARCH ONE SOURCE IN ORDER TO GET TO ANOTHER SOURCE FOR EVIDENTIARY SUPPORT FOR THE FACTS IN ISSUE!
Document Type
Brief
Notice of settlement must not be filed until all parties have signed the settlement agreement.
BUT DO NOT FILE A NOTICE OF SETTLEMENT UNTIL ALL PARTIES ON BOTH SIDES HAVE SIGNED THE SETTLEMENT AGREEMENT.
Document Type
Notice Of Settlement
Motions in limine seeking to restrict opposing counsel's conduct require prior contact with opposing counsel confirming intent to engage in the conduct.
No motion in limine is to be filed asking the court to order that opposing counsel not do “x,” “y,” or “z,” unless that opposition attorney has first been contacted and stated that they intend to do what the moving party wants to prevent.
Document Type
Motion In Limine
Parties/counsel of record must participate by phone unless a waiver of participation is filed earlier.
of record must be on the phone unless a waiver of participation is earlier filed.
Document Type
Waiver Of Participation
Counsel must agree on allocated blocks of exhibit numbers (per LASC Local Rule 3.53), and the exhibit list must include the exhibit number and a brief description of each exhibit.
Counsel are to agree on a block of numbers to be allocated to each party for exhibits. (See LASC Local Rule 3.53) The exhibit list shall include the exhibit number and a brief description of the exhibit.
Document Type
Exhibit List
The parties must meet and confer and file any special verdict forms.
The parties are ordered to meet and confer and file any special verdict forms.
Document Type
Special Verdict Forms
If the parties do not agree, each party must submit its own proposed special verdict (or special fact finding) forms accompanied by points and authorities supporting the request.
If no agreement is reached, each party is to submit their own proposed special verdict (or special fact finding) forms along with points and authorities supporting what is requested.
Document Type
Proposed Special Verdict Forms
Trial briefs are optional (appreciated but not required) at the case management conference, but if submitted they must include a statement of facts with expected evidence and pertinent law on all causes of action and affirmative defenses.
The court appreciates trial briefs at or before the time for appearance at the case management conference, but such briefs are not required. If provided, the brief is to include a statement of the facts with a summary of what it is expected the evidence will show along with all pertinent law in support of and/or against all cause of action contentions as well as with respect to affirmative defense matters.
Document Type
Trial Brief
The court strongly prefers BAJI jury instructions over CACI.
The court has a strong preference for BAJI Instructions, not CACI.
Document Type
Jury Instructions
Case management statements are not required for initial case management conferences.
NO CASE MANAGEMENT STATEMENT IS REQUIRED.
Document Type
Case Management Statement
No case management statement is required in this department, notwithstanding the CRC 3.700 case management rules.
NO CASE MANAGEMENT STATEMENT IS REQUIRED.
Document Type
Case Management Statement
Filing & Service rules
Electronic Filing Rules
All parties must comply with mandatory electronic filing requirements for civil cases per the operative General Order.
All parties are to be governed by the operative General Order Re Mandatory Electronic Filing of Civil and amendments thereto posted on the court website at 636www.lacourt.ca.gov.
Page 3 | Filings
All parties must follow the court's mandatory electronic filing General Order for civil cases, as posted on the court website.
All parties are to be governed by the operative General Order Re Mandatory Electronic Filing of Civil and amendments thereto posted on the court website at 636www.lacourt.ca.gov.
Page 3 | Filings
Original orders/judgments for signature must be submitted directly to Department 636 courtroom, not e-filed.
When an order or judgment is submitted for the judge’s signature in Department 636 (as should be the case in all departments), the correct process is to submit the original directly to the courtroom (or in the courtroom at the time of hearing when the signature is sought right after a ruling) where it will be lodged pending the affixing of the judge’s signature.
Page 5 | Orders
Filing Timing and Cure Windows
Ex parte motions must be given to the clerk at 8:30 a.m., Monday through Friday.
8:30 a.m. Monday through Friday, Ex Parte motions are to be given to the clerk.
Page 1 | III. GENERAL PROVISIONS
Ex parte motions must be submitted to the clerk at 8:30 a.m. Monday through Friday.
8:30 a.m. Monday through Friday, Ex Parte motions are to be given to the clerk.
Page 1 | Hearing times:
A notice of settlement must not be filed until all parties on both sides have signed the settlement agreement.
BUT DO NOT FILE A NOTICE OF SETTLEMENT UNTIL ALL PARTIES ON BOTH SIDES HAVE SIGNED THE SETTLEMENT AGREEMENT.
Page 7 | Settlement Conferences
Final Status Conference documents must be filed at least 5 calendar days before the FSC.
Please serve and file all documents at least five (5) days prior to the Final Status Conference. (LASC Local Rule 3.25(f)(1) or otherwise ordered by the court.
Page 9 | Filing and Service of Final Status Conference Documents
All Final Status Conference documents must be served and filed at least five days prior to the FSC.
Please serve and file all documents at least five (5) days prior to the Final Status Conference. (LASC Local Rule 3.25(f)(1) or otherwise ordered by the court.
Page 9 | c) Filing and Service of Final Status Conference Documents
Special verdict forms must be submitted at the time of the final status conference or, if no FSC is held, five days before trial.
They are to be submitted to the court at the time of the final status conference or five days before trial if no FSC is held.
Page 11 | Verdict Forms
Upon settlement, parties must immediately advise the Department 636 courtroom assistant and promptly file a notice of settlement under CRC Rule 3.1385.
If the matter is resolved by settlement, please advise the courtroom assistant in Department 636 of the settlement forthwith, and promptly file a notice of settlement pursuant to CRC Rule 3.1385.
Page 7 | Settlement Conferences
Service and Proof of Service Rules
Final Status Conference documents must be served at least 5 calendar days before the FSC.
Please serve and file all documents at least five (5) days prior to the Final Status Conference. (LASC Local Rule 3.25(f)(1) or otherwise ordered by the court.
Page 9 | Filing and Service of Final Status Conference Documents
The initial case management conference notice goes to plaintiff's counsel, who must thereafter give notice of the conference to all other parties.
The Court generally follows and applies the case management rules specified by CRC 3.700 et seq., but the initial case management conference notice is given to plaintiff's counsel, with notice to all other parties to thereafter be given by plaintiff's counsel.
Page 7 | Case Management
Courtesy Copy Requirements
Department 636 requires courtesy copies of all e-filed pleadings (within 2 days of e-filing) and all ex parte motions, oppositions, and replies.
DEPARTMENT 636 REQUESTS AND REQUIRES THAT COUNSEL PROVIDE THE COURT NOT ONLY WITH ALL “COURTESY COPIES” REQUIRED TO BE SUBMITTED BY THE OPERATIVE GENERAL ORDER DEALING WITH E-FILING ISSUES, BUT ALSO WITH COURTESY COPIES OF ALL PLEADINGS WITH THOSE COPIES TO BE PROVIDED WITHIN TWO (2) DAYS OF THE E-FILING AS WELL AS COURTESY COPIES OF ALL EX PARTE MOTIONS, OPPOSITIONS THERETO AND REPLYS.
Page 1 | I. COURTESY COPIES
Department 636 requires courtesy copies of all pleadings (provided within two days of e-filing) as well as of all ex parte motions, oppositions, and replies, in addition to any courtesy copies required by the e-filing general order.
DEPARTMENT 636 REQUESTS AND REQUIRES THAT COUNSEL PROVIDE THE COURT NOT ONLY WITH ALL "COURTESY COPIES" REQUIRED TO BE SUBMITTED BY THE OPERATIVE GENERAL ORDER DEALING WITH E-FILING ISSUES, BUT ALSO WITH COURTESY COPIES OF ALL PLEADINGS WITH THOSE COPIES TO BE PROVIDED WITHIN TWO (2) DAYS OF THE E-FILING AS WELL AS COURTESY COPIES OF ALL EX PARTE MOTIONS, OPPOSITIONS THERETO AND REPLYS.
Page 1 | I. COURTESY COPIES
An exhibit binder must be provided for the court, the witness, and each counsel even when exhibits are displayed on screen.
Even if the exhibits are being displayed on screen, a binder with the exhibits should be provided for the court, the witness and each counsel.
Page 11 | Exhibits
Filing Bundling Requirements
Parties may submit joint trial documents in all cases, but joint submissions are not required unless specifically ordered by the court.
The parties are welcome to submit joint trial documents in all cases (see LR 3.25(g), but they are not required unless specifically ordered.
Page 9 | b) FSC Settings
Pre-Motion Conference Requirements
A motion in limine seeking to restrain opposing counsel's conduct may not be filed unless the moving party first contacts opposing counsel and that attorney states an intent to do the act; motions in limine must also not be misused or frivolous.
No motion in limine is to be filed asking the court to order that opposing counsel not do “x,” “y,” or “z,” unless that opposition attorney has first been contacted and stated that they intend to do what the moving party wants to prevent. Also, motions in limine should not be misused or frivolous such as general requests to direct an opponent “not to use documents not produced in discovery” or “not to ask leading questions,” etc.
Page 9 | In Limine Motions
Adjournment & Extension Requirements
Continuances require court approval, must be in writing (except emergencies), submitted before original date, with good cause for trial continuances; clerks cannot grant continuances.
Continuances can be sought only by written ex parte applications, noticed motions, or sometimes oral requests to the Court. No continuance request or stipulation is effective until approved (granted) by the court. Parties are asked not to call the clerk to ask the clerk for a continuance. Unless it is something that comes up as an emergency or during a hearing, continuance requests are expected to be made before the original date set and in writing. Department 636 does not favor continuances of trial dates so very, very good cause must support such a continuance request.
Page 5 | Continuances
Continuances may only be sought by written ex parte application, noticed motion, or oral request, and no continuance request or stipulation is effective until the court grants it.
Continuances can be sought only by written ex parte applications, noticed motions, or sometimes oral requests to the Court. No continuance request or stipulation is effective until approved (granted) by the court.
Page 5 | Continuances
Trial date continuances are disfavored and require very, very good cause.
Department 636 does not favor continuances of trial dates so very, very good cause must support such a continuance request.
Page 5 | Continuances
For fully stipulated law and motion continuances, the attorney appearing on the hearing date should request priority so the Court can accommodate counsel quickly.
If all parties have agreed upon a continuance as to a law and motion matter and an attorney comes to court on the hearing date to request same, priority should be requested to enable the Court to accommodate counsel quickly.
Page 5 | Continuances
Continuance requests must be made in writing before the original date set, except for emergencies or matters arising during a hearing.
Unless it is something that comes up as an emergency or during a hearing, continuance requests are expected to be made before the original date set and in writing.
Page 5 | Continuances
In discovery, only one brief time extension should generally be granted for deposition dates or compliance with discovery requests, and if compliance still is not forthcoming, a motion to compel should be made.
All counsel and parties must act in accordance with the “one-year-to-trial rule” set forth in the California Rules of Court. This means, for example, that when opposing counsel says that a deposition date set in a notice is not convenient or a continuance is asked to comply with a date noticed to comply with a discovery request, generally only one brief time extension should be granted and no more. Should compliance not then be forthcoming, a motion to compel should be made.
Page 7 | Discovery
Chambers Communication Rules
Parties must not call the courtroom to schedule motion hearing dates.
Please do not call the courtroom to schedule a motion date.
Page 3
Parties must not call the clerk's office to request a continuance.
Parties are asked not to call the clerk to ask the clerk for a continuance.
Page 5 | Continuances
Parties may arrange a conference call or chambers visit with all counsel and the Court for informal mediation of demurrers, discovery disputes, and other law and motion matters.
The Court is amenable to informally mediating demurrers, discovery disputes and other law and motion matters. Please feel free to set up a conference call or a chambers visit with all counsel and the Court if such a call or visit might be helpful.
Page 9 | Phone Conferences
A letter or email with all parties on notice one day before a joint call is helpful so the court can consider the issues in advance.
A letter or e-mail with all parties on notice thereof is helpful a day before the call to allow the court to consider the issues before the joint call.
Page 9 | Phone Conferences
After the parties waive a Final Status Conference, any party may later call the clerk to request that a FSC be set.
If the parties waive, any party can later call the clerk and ask that a FSC be set.
Page 9 | a) Waiver