Judge Cherol J. Nellon
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Case Dispositive Motion
- Hand Delivery • Upon Filing
Non Trial Documents
- Upon request
Rule 56 Motions
- Hand Delivery • Upon Filing
- On Date Of Electronic Filing
Trial Document
- Hand Delivery • Upon Filing
Adjournments
- The court will not continue its trial dates merely because counsel has another case set on or near the same date; the conflict must become imminent before the court will continue.
- The court will generally adjust its dates to accommodate counsel's vacation plans only if those plans are disclosed in a timely fashion.
- The court will not advance a hearing date unless the motion is both reserved and filed, and failure to timely reserve a motion date does not constitute irreparable harm.
- +2 more
Request must include
Communication
Chambers
Phone
Clerk
Phone
Phone
Chambers
Phone
Page & Word Limits2 rules
The IDC joint statement, including any attached exhibits, may not exceed 7 pages.
The joint statement and any attached exhibits should be no more than 7 pages long.
Idc Joint Statement
7 pages
Joint statement for IDC and attached exhibits limited to 7 pages.
The joint statement and any attached exhibits should be no more than 7 pages long.
Joint Statement
7 pages
Applies to: Attorney
Document Format Requirements2 rules
Jury instructions and verdict forms must be submitted as editable Word (DOCX) files to the court’s resource email.
Please send an editable Word version to the court’s resource account SMCDept300@lacourt.ca.gov in the final format that will be actually presented to the jury.
DOCX
Multi-page documentary exhibits must be internally paginated in sequential numerical order.
Documentary exhibits consisting of more than one page must be internally paginated in sequential numerical order.
Document Filing Requirements19 rules
Counsel must meet and confer and file a joint statement of the issues to be discussed at the IDC.
The court requires counsel to meet and confer and file a joint statement of the issues to be discussed at the IDC.
Document Type
Idc Joint Statement
Reply separate statements will not be considered by the court.
Reply separate statements are not provided for in the Rules of Court and will not be considered.
Document Type
Reply Separate Statement
Motion hearing dates must be reserved via CRS; reservation number included on caption page.
Hearing dates must be reserved through the Court’s Reservation System (CRS). Counsel shall include the reservation number of the motion on the CAPTION page.
Document Type
Motion
The motion's CRS reservation number must appear on the caption page.
Counsel shall include the reservation number of the motion on the CAPTION page.
Document Type
Motion
Ex parte applications must include affirmative showing of irreparable harm, immediate danger, or statutory basis.
There must be an affirmative showing of “irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte.” (See Cal. Rules of Court, rule 3.1202 (c).)
Document Type
Ex Parte Application
Ex parte applications must affirmatively show irreparable harm, immediate danger, or another statutory basis for relief, and must demonstrate why relief cannot be sought by other means such as a noticed motion.
PLEASE CAREFULLY REVIEW WHETHER YOU HAVE A PROPER BASIS TO SEEK EX PARTE RELIEF. There must be an affirmative showing of “irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte.” (See Cal. Rules of Court, rule 3.1202 (c).) You will need to demonstrate to the court the reason(s) why you cannot seek the requested relief by other means, such as a noticed motion.
Document Type
Ex Parte Application
Foreign-language exhibits must be accompanied by a certified English translation.
Exhibits written in a foreign language must be accompanied by a certified English translation. Cal. Rule of Court 3.1110(g).
Document Type
Foreign Language Exhibits
The joint witness list must list each witness once, with expected testimony time (direct, cross, re-direct) and total estimated time stated for each witness.
All witnesses must be listed on one list. Do not repeat the name of a witness. Indicate the total time expected for that testimony, including direct, cross, and re-direct. At the end of the list, state the total time estimated for each witness's testimony.
Document Type
Joint Witness List
Joint jury instructions must be submitted with all information filled in (no brackets or blanks), and disputed instructions must be submitted in separate sets identifying the proposing and opposing parties.
Submit a joint set of instructions with all information filled in – no remaining brackets or blanks. If instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction.
Document Type
Joint Jury Instructions
All exhibits must be exchanged and pre-numbered, except exhibits anticipated in good faith to be used for impeachment or rebuttal.
Pursuant to California Rule of Court 3.1110(f) and Local Rules 3.52 and 3.53, all exhibits must be exchanged and pre-numbered, except for those anticipated in good faith to be used for impeachment or during rebuttal.
Document Type
Exhibits
A disposition table listing all jury instructions by number, proposing parties, and court disposition columns must be submitted with the jury instructions.
Submit a disposition table which lists all jury instructions by number, the identity of the party or parties proposing the instruction, and columns for the court to indicate whether the instruction is given, modified, withdrawn, or refused.
Document Type
Jury Instruction Disposition Table
A party intending to call an expert at trial must present to the Court and opposing counsel a CCP section 2034.260 declaration stating the substance of the proffered opinion.
If counsel or any unrepresented party intends to call an expert at trial, counsel shall present to the Court and opposing counsel a copy of the Code of Civil Procedure section 2034.260 declaration that states the substance of the proffered opinion.
Document Type
Ccp 2034 260 Expert Declaration
If the parties cannot agree on a verdict form, each party must submit its own proposed verdict form, and any special verdict must be simple and easy for the jury to use.
If the parties cannot agree on the verdict form, each party must submit their own proposed verdict form. Any proposed special verdict should be in a form that is easily used and understood by the jury, and which does not require the jury to answer unnecessary questions.
Document Type
Proposed Verdict Form
Motions in limine must include a sworn declaration confirming meet and confer with opposing party and their position.
All motions in limine must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party and setting forth the opposing party’s position regarding the motion(s) and must be submitted with timely statutory notice.
Document Type
Motion In Limine
Parties must meet and confer before filing any motion in limine, and every motion in limine must be accompanied by a sworn declaration attesting to the discussion and stating the opposing party's position.
Local Rule 3.57 requires the parties to meet and confer before filing any motion in limine. All motions in limine must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party and setting forth the opposing party's position regarding the motion(s)
Document Type
Motion In Limine
The parties must submit a joint exhibit list and a joint witness list.
The parties must submit a joint exhibit list and joint witness list as described above.
Document Type
Joint Exhibit List
The court requests that all parties sign and file a general stipulation, using language similar to Item 5 of Optional Form LACIV 036, tolling the discovery motion filing deadline between the request for and holding of a conference.
To avoid issues with jurisdictional filing deadlines, the court requests that all parties sign and file a general stipulation containing language similar to that of Item 5 in Optional Form LACIV 036, tolling the deadline to file any discovery motion during the period between the date a conference is requested and the date that conference is held.
Document Type
Stipulation
In separate statements supporting alternative summary adjudication issues, counsel must not repeat facts verbatim or restart numbering, but must list repeated facts by number and incorporate them by reference beneath each issue heading.
Where counsel intends to move for summary adjudication in the alternative, the court asks counsel not to repeat verbatim facts that were previously given or to re-start the numbering sequence for each issue. Counsel should simply list the relevant repeated facts by number and incorporate them by reference beneath each issue heading.
Document Type
Separate Statement
For exhibits a party intends to admit into evidence, the party must indicate the moving party, stipulations on admissibility, or the basis for any objection.
For exhibits a party intends to admit into evidence, please indicate the moving party, stipulations on admissibility, and if not, the basis for any objection i.e., authentication, hearsay, etc.
Document Type
Exhibits
Filing & Service rules
Electronic Filing Rules
Parties using e-filing must accept electronic service, except where personal service is required by law or any party is self-represented.
Pursuant to CCP § 1010.6 and Local Rule 3.4 which references General Order 2020-GEN-018-00 issued June 11, 2020, the Court orders all parties who use e-filing to accept electronic service, except in those circumstances when personal service is required by law or where any of the parties are self-represented.
Page 3 | LAW AND MOTION
Self-represented litigants are exempt from mandatory electronic filing requirements.
Pursuant to California Rules of Court, Rule 2.253(b)(2), self-represented litigants are exempt from these mandatory Electronic Filing requirements.
Page 4 | EX PARTE APPLICATIONS
Ex parte applications and all supporting documents must be electronically filed no later than 10:00 a.m. the court day before the hearing.
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 hearing.
Page 4 | EX PARTE APPLICATIONS
Parties must meet and confer and e-file the joint trial documents five court days before the Final Status Conference.
Pursuant to Local Rule 3.25(f), parties must meet and confer and e-file the following JOINT documents five court days before the FSC:
Page 5 | Trial Documents
Self-represented litigants are exempt from the mandatory electronic filing requirements for ex parte papers under CRC 2.253(b)(2).
Pursuant to California Rules of Court, Rule 2.253(b)(2), self-represented litigants are exempt from these mandatory Electronic Filing requirements.
Page 4 | EX PARTE APPLICATIONS
Filing Timing and Cure Windows
The IDC joint statement must be filed 10 calendar days before the hearing.
The joint statement should be filed 10 calendar days before the hearing.
Page 2 | DISCOVERY
Ex parte papers must be filed by a 10:00 a.m. cutoff on the court day before the hearing.
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 hearing.
Page 4 | EX PARTE APPLICATIONS
Ex parte applications and supporting documents must be e-filed by 10:00 a.m. court day before hearing; oppositions by 8:30 a.m. hearing day.
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 hearing. Any written opposition shall be electronically filed by 8:30 a.m. the day of the hearing.
Page 4 | EX PARTE APPLICATIONS
Written opposition to an ex parte application must be electronically filed by 8:30 a.m. on the day of the hearing.
Any written opposition shall be electronically filed by 8:30 a.m. the day of the hearing.
Page 4 | EX PARTE APPLICATIONS
Joint trial documents must be e-filed 5 court days before Final Status Conference.
Pursuant to Local Rule 3.25(f), parties must meet and confer and e-file the following JOINT documents five court days before the FSC:
Page 5 | TRIAL PREPARATION
Joint trial documents must be e-filed five court days before the Final Status Conference.
Pursuant to Local Rule 3.25(f), parties must meet and confer and e-file the following JOINT documents five court days before the FSC:
Page 5 | Trial Documents
Motions in limine must be submitted with timely statutory notice as required by Local Rule 3.25(f)(2).
and must be submitted with timely statutory notice. See Local Rule 3.25(f)(2).
Page 7 | 5. Motions in Limine
The CCP section 2034.260 expert declaration must be produced at or before the Final Status Conference.
That document shall be produced at or before the Final Status Conference.
Page 7 | Experts
Motions in limine must reach the court in time for it to prepare; argument and rulings occur on the first day of trial, and stipulations shortening the briefing schedule are allowed only if the court retains adequate preparation time.
It is important that the court receive the motions in a timely manner so that it may prepare. However, the court will hear argument and rule on the motions on the first day of trial. The court may entertain a stipulation to shorten the briefing schedule, so long as the proposed schedule leaves the court adequate time to prepare.
Page 7 | 5. Motions in Limine
Service and Proof of Service Rules
All parties who use e-filing must accept electronic service, except when personal service is required by law or any party is self-represented.
Pursuant to CCP § 1010.6 and Local Rule 3.4 which references General Order 2020-GEN-018-00 issued June 11, 2020, the Court orders all parties who use e-filing to accept electronic service, except in those circumstances when personal service is required by law or where any of the parties are self-represented.
Page 3
Expert opinion declarations must be presented to court and opposing counsel by Final Status Conference.
If counsel or any unrepresented party intends to call an expert at trial, counsel shall present to the Court and opposing counsel a copy of the Code of Civil Procedure section 2034.260 declaration that states the substance of the proffered opinion. That document shall be produced at or before the Final Status Conference.
Page 7 | TRIAL PREPARATION
Filing Fees and Waivers
The court does not provide an official court reporter to represented parties unless they have a fee waiver, and reporter availability may not be known until the day of the hearing or trial.
The court does not provide a court reporter to represented parties absent a fee waiver. Given the limited availability of official court reporters, the Court may not know whether a reporter is available for any case until the day of the hearing or trial.
Page 10 | Court Reporters
A party with a fee waiver under CRC 3.55(7) may request an official court reporter by filing form FW-020 as soon as possible before the hearing or trial.
A party who has received a fee waiver pursuant to CRC 3.55(7) may request an official court reporter by filing form FW-020 https://www.courts.ca.gov/documents/fw020.pdf as soon as possible before the hearing or trial. (See CRC 2.956(c).)
Page 10 | Court Reporters
Represented parties must have a fee waiver to get a court reporter; fee waiver via form FW-020.
The court does not provide a court reporter to represented parties absent a fee waiver. A party who has received a fee waiver pursuant to CRC 3.55(7) may request an official court reporter by filing form FW-020 as soon as possible before the hearing or trial.
Page 10 | Court Reporters
Courtesy Copy Requirements
Courtesy copies of trial documents required, delivered to Courtroom Assistant; prohibited for other non-trial documents unless requested.
This court requires courtesy copies of trial documents. Department 300 does not maintain a “drop box;” please deliver courtesy copies directly to the Courtroom Assistant. Please do not submit courtesy copies of any other non-trial documents unless specifically requested by the Court.
Page 3 | LAW AND MOTION
Courtesy copies of trial documents and MSJ/MSA papers are required and must be delivered directly to the Courtroom Assistant because Department 300 has no drop box.
This court requires courtesy copies of trial documents and papers submitted in connection with a Motion for Summary Judgment or a Motion for Summary Adjudication, as discussed further below. Department 300 does not maintain a “drop box;” please deliver courtesy copies directly to the Courtroom Assistant.
Page 3
Paper courtesy copies of all MSJ/MSA moving, opposition, and reply papers required, delivered to Courtroom Assistant on filing date.
This court requires courtesy copies of papers submitted in connection with a Motion for Summary Judgment or a Motion for Summary Adjudication. Please submit paper courtesy copies of all moving, opposition, and reply papers submitted in connection with a Motion for Summary Judgment or a Motion for Summary Adjudication. Please lodge these courtesy copies on the date the papers are electronically filed. Department 300 does not maintain a “drop box;” please deliver courtesy copies directly to the Courtroom Assistant.
Page 3 | LAW AND MOTION
Paper courtesy copies of all moving, opposition, and reply papers for MSJ/MSA must be lodged on the same date the papers are electronically filed.
Please submit paper courtesy copies of all moving, opposition, and reply papers submitted in connection with a Motion for Summary Judgment or a Motion for Summary Adjudication. Please lodge these courtesy copies on the date the papers are electronically filed.
Page 4 | SUMMARY JUDGMENT/ADJUDICATION
Counsel must provide the court with a binder containing the joint exhibit and witness lists and copies of the trial exhibits.
Counsel must also supply a binder containing those lists, as well as copies of the trial exhibits, for the use of the court.
Page 8 | Trial Documents
In bench trials, the court requires a copy of each day's trial transcript; no deadline is set, but earlier delivery is preferred.
In a bench trial, the court will require a copy of each day's transcript. The court generally does not set a time deadline for the provision of the transcripts, but sooner is always better.
Page 8 | TRIAL LOGISTICS
Courtesy copies of other non-trial documents must not be submitted unless specifically requested by the Court.
Please do not submit courtesy copies of any other non-trial documents unless specifically requested by the Court.
Page 3
Filing Bundling Requirements
One joint binder containing all trial documents required for Final Status Conference.
All counsel and any unrepresented parties should be present in court, with one joint binder containing a complete set of the trial documents as requested below. Counsel must also supply a binder containing those lists, as well as copies of the trial exhibits, for the use of the court.
Page 5 | TRIAL PREPARATION
Counsel and unrepresented parties must attend the Final Status Conference with one joint binder containing a complete set of trial documents, which they take back after the hearing.
Final Status Conferences will be held at 10:00 a.m. All counsel and any unrepresented parties should be present in court, with one joint binder containing a complete set of the trial documents as requested below. Counsel should be prepared to take this binder back with them after the hearing. Trial documents will generally not be stored in the department prior to the first day of trial.
Page 5 | Final Status Conference
Pre-Motion Conference Requirements
Before filing any discovery motion (other than a motion to compel initial responses to party discovery), counsel must first meet and confer verbally, and the court may instruct counsel to meet face-to-face if the verbal meet and confer is not productive.
Should any party wish to file any discovery motion, other than a motion to compel initial responses to party discovery, at any time during the pendency of their case, counsel must first meet and confer verbally (i.e. by telephone, video conference, or in person). If counsel’s conversations are not productive, the court may, in any given case, instruct counsel to meet face-to-face (i.e. by video conference or in person).
Page 2 | DISCOVERY
Discovery motions (except motions to compel initial responses) require verbal meet and confer, then IDC if unsuccessful; joint IDC statement (max 7 pages) filed 10 calendar days before hearing.
Should any party wish to file any discovery motion, other than a motion to compel initial responses to party discovery, at any time during the pendency of their case, counsel must first meet and confer verbally (i.e. by telephone, video conference, or in person). If counsel’s conversations are not productive, the court may, in any given case, instruct counsel to meet face-to-face (i.e. by video conference or in person). If the meeting and conference is unsuccessful, counsel must then schedule an Informal Discovery Conference (IDC) by calling the Courtroom Assistant at the phone number given above. If counsel file their motion without first attending an IDC, the motion may be continued to permit an IDC, or it may be taken off-calendar altogether. The court requires counsel to meet and confer and file a joint statement of the issues to be discussed at the IDC. The joint statement should be filed 10 calendar days before the hearing. The joint statement and any attached exhibits should be no more than 7 pages long.
Page 2 | DISCOVERY
If the meet and confer is unsuccessful, counsel must schedule an Informal Discovery Conference (IDC) before filing the motion, and a motion filed without first attending an IDC may be continued or taken off-calendar altogether.
If the meeting and conference is unsuccessful, counsel must then schedule an Informal Discovery Conference (IDC) by calling the Courtroom Assistant at the phone number given above. If counsel file their motion without first attending an IDC, the motion may be continued to permit an IDC, or it may be taken off-calendar altogether.
Page 2 | DISCOVERY
Law and motion hearings begin at 8:30 a.m., and hearing dates must be reserved in advance through the Court's Reservation System (CRS).
Law and motion hearings are conducted beginning at 8:30 a.m. Hearing dates must be reserved through the Court’s Reservation System (CRS).
Page 3
The court may rule on ex parte applications from chambers without hearing oral argument.
Pursuant General Order 2020-GEN-018-00 and Code of Civil Procedure § 166(a)(l), the court may rule from chambers and may not necessarily hear oral argument for an ex parte application for relief.
Page 4 | EX PARTE APPLICATIONS
Adjournment & Extension Requirements
Continuances to attend mediation or a settlement conference require that the mediation/conference date already be scheduled, and that date must appear in the ex parte papers.
If any party seeks to continue any proceedings so that they can attend mediation or any sort of settlement conference, they must have the date already scheduled. The court will expect to see that date in the ex parte papers.
Page 4 | EX PARTE APPLICATIONS
The court will not advance a hearing date unless the motion is both reserved and filed, and failure to timely reserve a motion date does not constitute irreparable harm.
Failing to timely reserve a motion date does not constitute irreparable harm. If any party wishes to advance a hearing date, the motion must already be both reserved and filed. The court will not advance a motion if it is merely reserved.
Page 4 | EX PARTE APPLICATIONS
The court will not continue its trial dates merely because counsel has another case set on or near the same date; the conflict must become imminent before the court will continue.
The court understands that parties and counsel may have other cases set to proceed on or near the same date. However, the court will not continue its own trial dates on that basis until the conflict becomes imminent.
Page 2 | CASE MANAGEMENT CONFERENCES
The court will generally adjust its dates to accommodate counsel's vacation plans only if those plans are disclosed in a timely fashion.
The court is generally willing to adjust its dates to accommodate the vacation plans of counsel, so long as those plans are disclosed in a timely fashion.
Page 2 | CASE MANAGEMENT CONFERENCES
Continuance requests for mediation/settlement conference must include already scheduled date for same.
If any party wishes to continue any proceedings so that they can attend mediation or any sort of settlement conference, they must have the date already scheduled. The court will expect to see that date in the ex parte papers.
Page 4 | EX PARTE APPLICATIONS
Chambers Communication Rules
Counsel schedule Informal Discovery Conferences by calling the Courtroom Assistant at (213) 633-0514.
If the meeting and conference is unsuccessful, counsel must then schedule an Informal Discovery Conference (IDC) by calling the Courtroom Assistant at the phone number given above.
Page 2 | DISCOVERY
Parties must email an editable Word version of the jury instructions in final presentation format to the court's resource account SMCDept300@lacourt.ca.gov.
Please send an editable Word version to the court's resource account SMCDept300@lacourt.ca.gov in the final format that will be actually presented to the jury.
Page 6 | Joint Jury Instructions
Court-certified interpreters are provided free of charge to limited-English-speaking litigants, must be requested via the court's website or by informing the Judicial Assistant as soon as possible, and must be used when presenting the case in court.
Court-certified language interpreters will be provided to limited English-speaking litigants free of charge. Please make the request at the court's website at http://www.lacourt.ca.gov/irud/UI/ReqInput.aspx or inform the Judicial Assistant as soon as possible. When presenting your case in court, a court-certified language interpreter must be used.
Page 10 | Interpreters
Department 300 phone number is (213) 633-0514, available during courtroom hours Monday-Friday 8:30 AM-12:00 PM, 1:30 PM-4:30 PM, closed for lunch 12:00 PM-1:30 PM.
TELEPHONE NUMBER: (213) 633-0514 COURTROOM HOURS: Monday through Friday 8:30 A.M. – 12:00 P.M. 1:30 P.M. – 4:30 P.M. (Closed for Lunch: 12:00 P.M. – 1:30 P.M.)
Page 1 | COURTROOM INFORMATION
Department 300 email address is SMCDept300@lacourt.ca.gov, used for submitting trial documents.
EMAIL SMCDept300@lacourt.ca.gov
Page 1 | COURTROOM INFORMATION
Department 300's contact email address is SMCDept300@lacourt.ca.gov.
EMAIL SMCDept300@lacourt.ca.gov
Page 1 | COURTROOM INFORMATION
Counsel should call the department to reserve a hearing date (sentence truncated in source document).
Counsel should call the department to reserve a hearing date for any
Page 3 | SUMMARY JUDGMENT/ADJUDICATION
Self-Help services are available by calling the Self-Help Center at 213-830-0845.
For Self-Help services, call the Self-Help Center at 213-830-0845.
Page 10
Clerk's Office assistance is available by calling the Court Support Service at 213-830-0800 (Stanley Mosk).
For Clerk's Office assistance, call the Court Support Service numbers: 213-830-0800 Stanley Mosk.
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