Judge David B. Gelfound
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
All filings
- Chambers Drop Off • Upon Filing
Courtesy copies
- 4 copies
Exhibits
- 5 copies • First Day Of Trial
- First Day Of Trial
Jury Instructions, Proposed Verdict Form
- 1 copy • Hand Delivery • At Time Of Electronic Filing
Adjournments
- Continuances of hearing and trial dates may be sought by written Stipulation and Order stating the complaint filing date, current trial date, and proposed Final Status Conference and trial dates, or alternatively by noticed motion or ex parte application if there is no stipulation.
- Continuances require a written Stipulation and Order stating complaint filing date, current trial date, and proposed FSC and trial dates; if no stipulation, use noticed motion or ex parte.
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
Other Contacts1 contacts
- (213) 830-0400
Clerk1 contacts
- (818) 407-2249
Page & Word Limits2 rules
Trial briefs are mandatory for all court and jury trials and must not exceed 20 pages.
Trial briefs are mandatory for all (both Court and jury) trials and must include the following information and not exceed 20 pages:
Trial Brief
20 pages
Trial briefs are mandatory for all trials and must not exceed 20 pages.
Trial briefs are mandatory for all (both Court and jury) trials and must include the following information and not exceed 20 pages:
Trial Brief
20 pages
Document Format Requirements13 rules
Self-represented litigants must staple all papers separately before filing or the filings will be rejected.
All papers filed by self-represented litigants must be stapled separately before filing, or they will be rejected.
Self-represented litigants must staple all papers separately before filing, or they will be rejected.
All papers filed by self-represented litigants must be stapled separately before filing, or they will be rejected.
All 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.
Identical copies of the Exhibit List and all exhibits must be provided in 3-ring binders, one for each party, one for the Court, and one for the witness stand.
Identical copies of the Exhibit List and all exhibits must be provided in 3-ring binders as follows: one for each party, one for the Court, and one for the witness stand.
Exhibits must be numbered or lettered using pre-agreed party ranges, each exhibit and subpart separately identified and listed, and each page of multi-page exhibits consecutively paginated.
Each exhibit shall be numbered or lettered. All parties shall agree in advance that their respective party will have a range of exhibit numbers or letters (e.g. Plaintiff No. 1: 1-99; Plaintiff No. 2: 100-199; Defendant: A-Z). Each exhibit must be separately identified. Subparts to an exhibit (e.g., 1A, 1B, etc.) must also be identified and listed separately. Each page of a multi-page exhibit must be consecutively paginated.
The printed hard copy of jury instructions delivered to Department F49 must be on 2-hole punched, perforated paper so instruction identification can be separated from instruction text for jury deliberation.
The printed, hard copy of the jury instructions delivered directly to Department F49 shall be submitted on 2-hole punched, perforated paper so as to allow for separation of the identification of the instruction from the text of the instruction, to be submitted to the jury for reference during deliberation.
Printed jury instructions delivered to Dept F49 must be on 2-hole punched, perforated paper.
The printed, hard copy of the jury instructions delivered directly to Department F49 shall be submitted on 2-hole punched, perforated paper so as to allow for separation of the identification of the instruction from the text of the instruction, to be submitted to the jury for reference during deliberation.
Jury trial binders must be jointly prepared, tabbed and organized into 3-ring binders with a Table of Contents in the front, containing the required documents behind Tabs A through G.
For all jury trials, the parties/counsel shall jointly prepare and lodge a trial binder with the Court at least two (2) calendar days before the FSC, containing the required trial documents, tabbed and organized into 3-ring binders, with a Table of Contents in the front of each binder, as follows: Tab A: Trial Briefs of all parties Tab B: Joint Witness List Tab C: Joint Statement to be Read to the Jury Tab D: Joint Exhibit List Tab E: Joint List of Jury Instructions (identifying the agreed upon and contested instructions) Tab F: Joint and Contested Jury Instructions Tab G: Joint and/or Contested Verdict Forms
The motions in limine notebook must include a Table of Contents and tab dividers separating each numbered motion and its corresponding opposition and reply.
The notebook must have both a Table of Contents and tab dividers to separate each numbered motion and its corresponding opposition and reply.
Oppositions to motions in limine must refer to the numbers used by the moving party.
The opposition must refer to the numbers used by the moving party.
Motions in limine must be in writing and numbered.
All motions in limine, if any, must be in writing, numbered, and shall be served on all opposing parties and counsel and electronically filed at least ten (10) calendar days before the FSC.
Exhibits should be numbered consecutively in the lower right-hand corner, with each page delineated by a dash (e.g., Exhibit 1-1, 1-2, 1-3).
Those exhibits can be numbered consecutively in the lower, right-hand corner of each document. Each page should be given an exhibit number, so that if an exhibit contains multiple pages, it should have a "-"(dash) delineating each page. For example, if Exhibit 1 consists of 3 pages, it would be numbered as follows: Exhibit 1-1, 1-2, and 1-3.
Proposed jury instructions must be organized behind Tab F with agreed instructions first, followed by contested instructions.
The parties shall organize proposed jury instructions behind Tab F, with the agreed upon instructions first in order followed by the contested instructions (including special instructions) submitted by each party.
Document Filing Requirements19 rules
Ex parte applications must include a proposed order and be e-filed by 10:00 a.m. the court day before the hearing.
Ex Parte applications, supporting documents, and a proposed order must be electronically filed no later than 10:00 a.m. the court day before the Ex Parte hearing.
Document Type
Ex Parte Application
Ex parte filings must include a proposed order.
Ex Parte applications, supporting documents, and a proposed order must be electronically filed no later than 10:00 a.m. the court day before the Ex Parte hearing.
Document Type
Ex Parte Application
The Court will not consider an Ex Parte application unless it is submitted with a proposed order.
Please note that the Court may not consider Ex Parte applications submitted/filed without a proposed order.
Document Type
Ex Parte Application
The exhibit binders must include the exhibit list.
The exhibit list must be included in the binders.
Document Type
Exhibit Binder
Jury trials require the filing of Motions in Limine (if any), Trial Briefs, Joint Witness List, Joint Exhibit List, Joint Statement of the Case, Joint Jury Instructions, and Joint Verdict Form before the FSC, with the enumerated list appearing to continue beyond this excerpt.
a. Motions in Limine (if any), b. Trial Briefs, c. Joint Witness List, d. Joint Exhibit List, e. Joint Statement of the Case, f. Joint Jury Instructions, g. Joint Verdict Form, and,
Document Type
Jury Trial Fsc Filings
All parties must meet and confer and/or exchange information at least 15 court days before the FSC, and failure to timely comply with any item of the FSC order may result in sanctions including monetary sanctions, exclusion of evidence, issue preclusion, denial of a claim or defense, dismissal, or contempt.
All parties shall meet and confer and/or exchange information at least fifteen (15) court days before the FSC as required by this order and Los Angeles County Court Rules, Rule 3.25(g). Any failure to timely comply with any item required by this order shall subject any such non-complying party to the imposition of appropriate sanctions, including but not limited to monetary, exclusion of evidence, issue preclusion, denial of a claim or defense, dismissal, or contempt (pursuant to CCP §§128.5, 177.5, 575.5 and 583.410; Government Code §68608, CRC Rule 526).
Document Type
Final Status Conference Preparation
Court trials require the filing of Motions in Limine (if any), Trial Briefs, a Joint Witness List, and a Joint Exhibit List before the FSC.
a. Motions in Limine (if any), b. Trial Briefs, c. Joint Witness List, and d. Joint Exhibit List.
Document Type
Court Trial Fsc Filings
Trial briefs are mandatory for all court and jury trials and must include eight specified content items, including descriptions of causes of action and defenses, stipulated facts, contested issues of fact and law with points and authorities, anticipated evidentiary issues, and a detailed damages breakdown.
Trial briefs are mandatory for all (both Court and jury) trials and must include the following information and not exceed 20 pages: 1) A brief description of each cause of action and key affirmative 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; admissions by discovery and/or stipulation of the parties; 4) All contested issues of fact; 5) All contested issues of law, together with points and authorities supporting the position of the parties; 6) A list of major evidentiary issues anticipated, any relevant points and authorities supporting the position of the parties; 7) A detailed statement of the damages and relief claimed, including a specific breakdown of the elements of damages claimed and the amount sought; and, 8) Any other information that will assist the Court.
Document Type
Trial Brief
Parties must jointly prepare and exchange a completed Exhibit List identifying each document and item of physical evidence and any stipulations to authenticity or admissibility.
All parties must jointly prepare and exchange a completed Exhibit List, indicating each document and item of physical evidence, and whether there is a stipulation to authenticity and/or admissibility.
Document Type
Exhibit List
Jury instructions must be submitted as a jointly submitted packet of unopposed instructions, with each party's disputed instructions separately submitted and inserted into that packet for the Court's consideration.
A jointly submitted packet of all requested and properly edited jury instructions to which there is no objection. Each party shall also submit specifically requested and properly edited instructions not requested by the opposing counsel/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 pendency of the trial.
Document Type
Jury Instructions
Each party must prepare a list of discovery material intended for use at trial, specifically identifying the date, document, page and line for each item.
Each party must prepare a list of discovery material intended to be used at trial, including but not limited to interrogatories and requests for admissions and any responses thereto as well as deposition(s), all of which shall specifically identify the date, document, page and line.
Document Type
Discovery Material List
Originals of depositions or other discovery responses intended for use at trial must be lodged with the Court at the time of trial.
If depositions or other discovery responses are intended to be used at trial, originals shall be lodged with the Court at the time of trial.
Document Type
Depositions
Parties must submit a printed copy of a jointly prepared, short, non-argumentative written statement of the case to be read to the jury.
The parties shall submit a printed copy of the jointly prepared, short, non-argumentative written statement of the case to be read to the jury.
Document Type
Joint Statement Of The Case
Each proposed jury instruction must identify who requested it, whether it is to be given as requested or modified, whether it is withdrawn, and must include a signature line for the Court.
requesting the instruction; B) Whether the instruction is to be given as requested or modified; C) Whether the instruction is withdrawn; and D) A signature line for the Court.
Document Type
Jury Instruction
A joint special verdict form is mandatory and must be prepared in final form adapted to CACI.
A special verdict form is mandatory and shall be jointly prepared in final form. This special verdict form shall be adapted to CACI with proper spacing, particularly noted to allow for both clarity and direction.
Document Type
Special Verdict Form
A proffering party must identify in writing the deponent's name and the page and line numbers of any deposition video excerpt proposed for use at trial.
For example, if a party proposes to read or show a video excerpt from a deposition, the proffering party must identify in writing the name of the deponent, page, and line numbers to opposing counsel
Document Type
Discovery Designation
Objections to the use of discovery material must be raised by way of an in limine motion.
Any objections to the use of discovery material shall be done by way of an in limine motion.
Document Type
In Limine Motion
Parties using a court reporter must file Form LACIV237 (reporter listed on the Pro Tempore Directory) or Form LACIV236 (reporter not listed) in the courtroom before the judge calls the case.
The following forms must be filed in the courtroom prior to the judge calling your case: Form LACIV237, if the court reporter is listed on the court's Pro Tempore Court Reporter Directory; or, Form LACIV236, if the court reporter is not listed on said directory.
Document Type
Court Reporter Form
The Court strongly encourages (but does not require) the use of CACI jury instructions.
The Court strongly encourages the use of CACI jury instructions.
Document Type
Jury Instructions
Filing & Service rules
Electronic Filing Rules
Parties e-filing documents must comply with the Technical Requirements in the General Order Re Mandatory Electronic Filing for Civil.
When eFiling documents, parties and counsel must comply with the “Technical Requirements” which are set forth in the General Order Re Mandatory Electronic Filing for Civil.
Page 1
Represented litigants must electronically file all documents through an approved Electronic Filing Service Provider.
Represented litigants are required to electronically file all documents with the Court through the approved Electronic Filing Service Provider. See the General Order Re Mandatory Electronic Filing for Civil.
Page 1 | Filings by Represented Litigants
Self-represented parties must either electronically file ex parte papers by 10:00 a.m. (source sentence is truncated; remaining filing options not stated).
Self-represented parties must either electronically file by 10:00
Page 1 | Ex Parte Applications
Parties and counsel e-filing documents must comply with the Technical Requirements in the General Order Re Mandatory Electronic Filing for Civil.
When eFiling documents, parties and counsel must comply with the "Technical Requirements" which are set forth in the General Order Re Mandatory Electronic Filing for Civil.
Page 1 | Motions
Represented litigants must electronically file all documents through the approved Electronic Filing Service Provider.
FILINGS BY REPRESENTED LITIGANTS: Represented litigants are required to electronically file all documents with the Court through the approved Electronic Filing Service Provider. See the General Order Re Mandatory Electronic Filing for Civil.
Page 1
Self-represented litigants are exempt from mandatory electronic filing requirements.
FILINGS BY SELF-REPRESENTED LITIGANTS: Self-represented litigants are exempt from mandatory electronic filing requirements.
Page 1
Represented parties must e-file all trial documents except exhibits per the Final Status Conference Order.
All trial documents filed by represented parties must be electronically filed pursuant to the Final Status Conference Order (except for exhibits).
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Self-represented litigants must file all trial documents directly in Department F49 (paper filing at the department) pursuant to the Final Status Conference Order.
All trial documents filed by self-represented litigants must be filed directly in Department F49 pursuant to the Court’s Final Status Conference Order.
Page 3 | Trials
Self-represented litigants must file all trial documents directly in Department F49.
All trial documents filed by self-represented litigants must be filed directly in Department F49 pursuant to the Court’s Final Status Conference Order.
Page 3
Self-represented parties may file ex parte oppositions electronically by 8:30 a.m. hearing day or in person the day of the hearing.
Oppositions by self-represented parties, if any, shall either be filed electronically by no later than 8:30 a.m. the day of the Ex Parte hearing or be brought to the courtroom on the day of the Ex Parte hearing.
Page 3
Represented parties must e-file all trial documents pursuant to the Final Status Conference Order, except exhibits.
All trial documents filed by represented parties must be electronically filed pursuant to the Final Status Conference Order (except for exhibits).
Page 3 | Trials
In court trials, Motions in Limine, Trial Briefs, Joint Witness List, and Joint Exhibit List must be filed electronically at least 10 calendar days before the FSC, with exempt parties permitted to file by paper.
For all Court trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC. a. Motions in Limine (if any), b. Trial Briefs, c. Joint Witness List, and d. Joint Exhibit List.
Page 5 | Final Status Conference Order - Court Trials
In jury trials, Motions in Limine, Trial Briefs, Joint Witness List, Joint Exhibit List, Joint Statement of the Case, Joint Jury Instructions, and Joint Verdict Form must be filed electronically at least 10 calendar days before the FSC, with exempt parties permitted to file by paper.
For all jury trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC. a. Motions in Limine (if any), b. Trial Briefs, c. Joint Witness List, d. Joint Exhibit List, e. Joint Statement of the Case, f. Joint Jury Instructions, g. Joint Verdict Form, and,
Page 5 | Final Status Conference Order - Jury Trials
A Request for Dismissal or Notice of Settlement must be electronically filed at least 2 court days before the FSC to excuse appearance, with exempt parties permitted to file and serve a printed paper copy instead.
If the action is settled or otherwise resolved before the FSC, no appearance will be necessary as long as either a Request for Dismissal of the entire action or a Notice of Settlement under California Rules of Court Rule 3.1385 is electronically filed with this Court at least two (2) court days before the scheduled FSC. If a party is exempt from the electronic filing requirements, that party shall file and serve a printed copy of the Request for Dismissal or Notice of Settlement at least two (2) court days before the scheduled FSC.
Page 5 | Final Status Conference Order
Represented parties must electronically file oppositions to motions in limine, while exempt (self-represented) parties may file by conventional means on printed paper directly in Department F49.
An opposition to any motion in limine must be in writing, numbered, and served and electronically filed by represented parties at least five (5) calendar days prior to the FSC. (Exempt parties may file same by conventional means on printed paper directly in Department F49.)
Page 7 | REQUIREMENTS FOR SPECIFIC TRIAL DOCUMENTS - MOTIONS IN LIMINE
Motions in limine must be electronically filed.
All motions in limine, if any, must be in writing, numbered, and shall be served on all opposing parties and counsel and electronically filed at least ten (10) calendar days before the FSC.
Page 7 | REQUIREMENTS FOR SPECIFIC TRIAL DOCUMENTS - MOTIONS IN LIMINE
Represented parties must submit jury instructions both by electronic filing and by printed copy delivered directly to Department F49.
Jury Instructions shall be submitted by both electronic filing and by a printed copy delivered directly to Department F49.
Page 9 | JOINT JURY INSTRUCTIONS
Self-represented parties need only submit jury instructions by delivering a printed copy directly to Department F49.
However, non-represented parties are only required to submit jury instructions by delivering a printed copy directly to Department F49.
Page 9 | JOINT JURY INSTRUCTIONS
Represented parties must e-file jury instructions and deliver printed copy to Dept F49; self-represented only need printed copy.
Jury Instructions shall be submitted by both electronic filing and by a printed copy delivered directly to Department F49. However, non-represented parties are only required to submit jury instructions by delivering a printed copy directly to Department F49.
Page 9
Exhibits must be in Exhibit Notebooks, 5 copies submitted first day of trial; exhibits prohibited from e-filing.
All exhibits sought to be admitted by the parties shall be placed in Exhibit Notebooks. On the first day of trial, the parties are ordered to jointly submit five identical copies of the Exhibit Notebooks as follows: one for each party, two for the Court, and one for the witness stand. Trial and evidentiary hearing exhibits shall not be filed electronically.
Page 11
Trial and evidentiary hearing exhibits must not be filed electronically.
Trial and evidentiary hearing exhibits shall not be filed electronically.
Page 11 | EXHIBITS
Self-represented litigants may file judgments, orders, and stipulations directly in the courtroom, provided they include self-addressed stamped envelopes and copies to conform.
Judgments, orders, and stipulations may be filed directly in the courtroom but must include self-addressed, stamped envelopes and copies to conform.
Page 1 | Filings by Self-Represented Litigants
Self-represented litigants are exempt from mandatory electronic filing requirements.
Self-represented litigants are exempt from mandatory electronic filing requirements.
Page 1 | Filings by Self-Represented Litigants
Self-represented parties who timely e-file the required Ex Parte documents may appear at the hearing remotely through LACourtConnect.
If the Self-represented party timely files the required Ex Parte documents electronically, then he or she may appear at the hearing through LACourtConnect.
Page 3 | Ex Parte Applications
Filing Timing and Cure Windows
Written oppositions to ex parte applications must be e-filed by 8:30 a.m. on the day of the hearing.
Written oppositions shall be electronically filed by 8:30 a.m. the day of the Ex Parte hearing.
Page 1 | Ex Parte Applications
Ex parte applications must be e-filed by 10:00 a.m. the court day before the hearing.
Ex Parte applications, supporting documents, and a proposed order must be electronically filed no later than 10:00 a.m. the court day before the Ex Parte hearing.
Page 1
Ex parte applications, supporting documents, and proposed orders must be e-filed no later than 10:00 a.m. the court day before the ex parte hearing.
Ex Parte applications, supporting documents, and a proposed order must be electronically filed no later than 10:00 a.m. the court day before the Ex Parte hearing.
Page 1 | Ex Parte Applications
Written oppositions to ex parte applications must be e-filed by 8:30 a.m. the day of the hearing.
Written oppositions shall be electronically filed by 8:30 a.m. the day of the Ex Parte hearing.
Page 1
The ex parte filing fee must be paid at the Clerk's Office by 8:30 a.m. on the day of the hearing.
proposed order to the Clerk’s Office for payment of the fee by 8:30 a.m. on the day of the hearing
Page 3 | Ex Parte Applications
Exhibits must be brought to Court on the first day of trial.
Exhibits must be brought to Court on the first day of trial.
Page 3 | Exhibits
Self-represented parties' oppositions to ex parte applications must be e-filed by 8:30 a.m. on the hearing day or brought to the courtroom on the day of the hearing.
Oppositions by self-represented parties, if any, shall either be filed electronically by no later than 8:30 a.m. the day of the hearing or be brought to the courtroom on the day of the Ex Parte hearing.
Page 3 | Ex Parte Applications
Settled actions require e-filing Request for Dismissal or Notice of Settlement at least 2 court days before FSC to waive appearance.
If the action is settled or otherwise resolved before the FSC, no appearance will be necessary as long as either a Request for Dismissal of the entire action or a Notice of Settlement under California Rules of Court Rule 3.1385 is electronically filed with this Court at least two (2) court days before the scheduled FSC.
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Jury trial documents (motions in limine, trial briefs, joint lists, statements, instructions, verdict forms) must be filed 10 calendar days before FSC; exempt parties may use paper.
For all jury trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC. a. Motions in Limine (if any), b. Trial Briefs, c. Joint Witness List, d. Joint Exhibit List, e. Joint Statement of the Case, f. Joint Jury Instructions, g. Joint Verdict Form, and;
Page 5
Court trial FSC documents must be filed at least ten (10) calendar days before the FSC.
For all Court trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC.
Page 5 | Final Status Conference Order - Court Trials
Jury trial FSC documents must be filed at least ten (10) calendar days before the FSC.
For all jury trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC.
Page 5 | Final Status Conference Order - Jury Trials
Court trial documents (motions in limine, trial briefs, joint witness/exhibit lists) must be filed 10 calendar days before FSC; exempt parties may use paper.
For all Court trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC. a. Motions in Limine (if any), b. Trial Briefs, c. Joint Witness List, d. Joint Exhibit List.
Page 5
The Request for Dismissal or Notice of Settlement must be filed at least two (2) court days before the scheduled FSC.
a Request for Dismissal of the entire action or a Notice of Settlement under California Rules of Court Rule 3.1385 is electronically filed with this Court at least two (2) court days before the scheduled FSC
Page 5 | Final Status Conference Order
Oppositions to motions in limine must be in writing, numbered, and served and electronically filed by represented parties at least 5 calendar days before the FSC.
An opposition to any motion in limine must be in writing, numbered, and served and electronically filed by represented parties at least five (5) calendar days prior to the FSC.
Page 7 | REQUIREMENTS FOR SPECIFIC TRIAL DOCUMENTS - MOTIONS IN LIMINE
Motions in limine must be filed at least 10 calendar days before the Final Status Conference, and untimely motions may not be considered.
All motions in limine, if any, must be in writing, numbered, and shall be served on all opposing parties and counsel and electronically filed at least ten (10) calendar days before the FSC. Untimely motions may not be considered.
Page 7 | REQUIREMENTS FOR SPECIFIC TRIAL DOCUMENTS - MOTIONS IN LIMINE
The motions in limine notebook must be submitted at least 2 calendar days before the FSC, and late notebooks may result in the motions not being considered.
The notebook shall be submitted at least two (2) calendar days prior to the FSC. Late filed notebooks may result in the motions not being considered.
Page 7 | REQUIREMENTS FOR SPECIFIC TRIAL DOCUMENTS - MOTIONS IN LIMINE
All exhibits referenced in the Exhibit List must be exchanged and/or reviewed by counsel or the parties before the Final Status Conference.
All items so referred to in the Exhibit List must be exchanged and/or reviewed by each counsel or the parties prior to the FSC.
Page 9 | JOINT EXHIBIT LIST
Parties intending to use discovery at trial must exchange written particulars no later than 10 court days before the Final Status Conference.
If the parties intend to use any discovery during trial, the parties must exchange in writing no later than 10 court days prior to the FSC the particulars of any such discovery.
Page 11 | DISCOVERY
Trial binders must be lodged with the Court at least 2 calendar days before the Final Status Conference.
For all jury trials, the parties/counsel shall jointly prepare and lodge a trial binder with the Court at least two (2) calendar days before the FSC
Page 11 | TRIAL BINDERS ARE REQUIRED FOR ALL JURY TRIALS BUT ARE DISCRETIONARY FOR ALL COURT TRIALS
No later than 10 court days before the FSC, all parties must submit to the judge a list of all deposition and discovery response excerpts to be used at trial (except impeachment), along with any stipulations to admissibility.
All parties shall submit to the judge no later than 10 court days before the FSC a list of all excerpts from depositions and other discovery responses to be used at trial except for impeachment, along with any stipulations to their admissibility.
Page 13
On the first day of trial, parties must lodge the originals of all deposition transcripts with the courtroom clerk before trial begins.
On the first day of trial, the parties must lodge with the courtroom clerk the originals of all deposition transcripts, to be used for any purpose, before trial begins.
Page 13
Service and Proof of Service Rules
Motions in limine must be written, numbered, served on all parties, and e-filed 10 calendar days before FSC.
All motions in limine, if any, must be in writing, numbered, and shall be served on all opposing parties and counsel and electronically filed at least ten (10) calendar days before the FSC.
Page 7
Oppositions to motions in limine must be written, numbered, served, and e-filed 5 calendar days before FSC.
An opposition to any motion in limine must be in writing, numbered, and served and electronically filed by represented parties at least five (5) calendar days prior to the FSC.
Page 7
Motions in limine must be served on all opposing parties and counsel at least 10 calendar days before the FSC.
All motions in limine, if any, must be in writing, numbered, and shall be served on all opposing parties and counsel and electronically filed at least ten (10) calendar days before the FSC.
Page 7 | REQUIREMENTS FOR SPECIFIC TRIAL DOCUMENTS - MOTIONS IN LIMINE
Parties must serve written excerpts of depositions and discovery responses to be used at trial (other than solely for impeachment) on opposing counsel/pro per parties no later than 10 court days before the FSC, marking each excerpt as an exhibit.
All parties must serve on the opposing attorney/in pro per party in writing and no later than 10 court days before the FSC all excerpts from depositions, responses to interrogatories, responses to requests for admissions, or other discovery responses to be used for any purpose at trial other than solely for impeachment and mark each excerpt as an exhibit.
Page 13
Parties must serve all discovery excerpts for trial (except impeachment) on opposing parties 10 court days before FSC, marked as exhibits.
All parties must serve on the opposing attorney/in pro per party in writing and no later than 10 court days before the FSC all excerpts from depositions, responses to interrogatories, responses to requests for admissions, or other discovery responses to be used for any purpose at trial other than solely for impeachment and mark each excerpt as an exhibit.
Page 13
Filing Fees and Waivers
Self-represented ex parte applicants must pay the fee at the Clerk's Office by 8:30 a.m. on the hearing day and proceed to the courtroom with the Ex Parte application, declaration of notice, proposed order, and proof of payment.
proposed order to the Clerk’s Office for payment of the fee by 8:30 a.m. on the day of the hearing and proceed immediately to the courtroom with the Ex Parte application, declaration of notice, a proposed order, and proof of payment.
Page 3 | Ex Parte Applications
Courtesy Copy Requirements
Courtesy copies must be delivered directly to Department F49.
Please deliver courtesy copies directly to Department F49.
Page 1 | Courtesy Copies
Printed courtesy copies of verdict forms and jury instructions must be delivered to Dept F49 upon e-filing.
Additionally, a printed courtesy copy of all verdict forms and jury instructions shall be filed directly in Department F49 at the time of the electronic filing.
Page 3
A printed courtesy copy of all verdict forms and jury instructions must be delivered directly to Department F49 at the time of electronic filing.
Additionally, a printed courtesy copy of all verdict forms and jury instructions shall be filed directly in Department F49 at the time of the electronic filing.
Page 3 | Trials
A self-represented party bringing a paper opposition on the hearing day must bring enough copies for the court and all other parties.
If a self-represented party elects to bring in his or her opposition to the Court on the day of the hearing, he or she shall bring a sufficient number of copies of the opposition to provide to the court and all other parties.
Page 3 | Ex Parte Applications
All trial exhibits must be placed in Exhibit Notebooks, with five identical copies jointly submitted on the first day of trial: one per party, two for the Court, and one for the witness stand.
All exhibits sought to be admitted by the parties shall be placed in Exhibit Notebooks. On the first day of trial, the parties are ordered to jointly submit five identical copies of the Exhibit Notebooks as follows: one for each party, two for the Court, and one for the witness stand.
Page 11 | EXHIBITS
On the first day of trial, parties must provide sufficient copies for the judge, opposing parties, and witnesses of all excerpts from interrogatories, requests for admission, depositions, and video depositions.
On the first day of trial, the parties must provide sufficient copies for the judge, the opposing parties, and the witness of all excerpts from interrogatories, requests for admission, depositions, and video depositions.
Page 13
Exhibit binders should be provided for the Judge, Judicial Assistant, Opposing Counsel, and the witness stand.
Binders should be provided for the Judge, Judicial Assistant, Opposing Counsel, and witness stand.
Page 3 | Exhibits
Filing Bundling Requirements
Exhibits must be placed in tabbed binders with numbered pages, exhibit list included, and brought to court first day of trial with copies for judge, staff, opposing counsel, and witness stand.
All document exhibits MUST be placed in binders under tabs, and each page must be numbered within each tab. The exhibit list must be included in the binders. Exhibits must be brought to Court on the first day of trial. Binders should be provided for the Judge, Judicial Assistant, Opposing Counsel, and witness stand.
Page 3
Motions in limine must be submitted in a 3-ring binder with table of contents and tabs, due 2 calendar days before FSC.
Separate Notebooks Are Required for All Motions in Limine: In addition to filing electronically, the party filing the motion(s) in limine must also submit a 3-ring binder notebook containing all motions, oppositions, and replies. The notebook must have both a Table of Contents and tab dividers to separate each numbered motion and its corresponding opposition and reply. The notebook shall be submitted at least two (2) calendar days prior to the FSC.
Page 7
Parties filing motions in limine must also submit a 3-ring binder notebook containing all motions in limine, oppositions, and replies.
Separate Notebooks Are Required for All Motions in Limine: In addition to filing electronically, the party filing the motion(s) in limine must also submit a 3-ring binder notebook containing all motions, oppositions, and replies.
Page 7 | REQUIREMENTS FOR SPECIFIC TRIAL DOCUMENTS - MOTIONS IN LIMINE
Jury trial parties must lodge a tabbed 3-ring trial binder with table of contents, containing specified documents, 2 calendar days before FSC.
For all jury trials, the parties/counsel shall jointly prepare and lodge a trial binder with the Court at least two (2) calendar days before the FSC, containing the required trial documents, tabbed and organized into 3-ring binders, with a Table of Contents in the front of each binder, as follows: Tab A: Trial Briefs of all parties; Tab B: Joint Witness List; Tab C: Joint Statement to be Read to the Jury; Tab D: Joint Exhibit List; Tab E: Joint List of Jury Instructions; Tab F: Joint and Contested Jury Instructions; Tab G: Joint and/or Contested Verdict Forms.
Page 11
The trial binder and Motions in Limine binder(s) must be maintained in separate notebooks.
Please note that the trial binder and Motions in Limine binder(s) should be in separate notebooks.
Page 11 | TRIAL BINDERS ARE REQUIRED FOR ALL JURY TRIALS BUT ARE DISCRETIONARY FOR ALL COURT TRIALS
The Court strongly prefers the parties to file a single joint exhibit notebook containing both parties' exhibits.
The Court strongly prefers the parties to file a joint exhibit notebook, containing both parties' exhibits in one notebook.
Page 11 | EXHIBITS
Pre-Motion Conference Requirements
Parties must meet and confer in person or via phone before filing discovery motions; letters/emails are insufficient.
All parties to exhaust meet and confer efforts before filing discovery motions. “Meet and confer” in Department 49 means in person or via phone; A letter or email does not suffice.
Page 1
All motions in Department F49 must be reserved through the Court Reservation System (CRS).
All motions to be heard in Dept. F49 are to be reserved through the Court Reservation System (CRS).
Page 1
Parties must exhaust meet and confer efforts in person or by phone (letters and emails do not suffice) before filing discovery motions.
All parties to exhaust meet and confer efforts before filing discovery motions. "Meet and confer" in Department 49 means in person or via phone; A letter or email does not suffice.
Page 1 | Discovery Motions
All motions to be heard in Dept. F49 must be reserved in advance through the Court Reservation System (CRS).
All motions to be heard in Dept. F49 are to be reserved through the Court Reservation System (CRS). Follow the links on the court's website: Online Services-Court Reservation System (CRS).
Page 1 | Motions
In-person appearance at the Final Status Conference is mandatory.
In-Person appearance at the FSC is mandatory.
Page 5
Parties must meet and confer or exchange information at least 15 court days before the Final Status Conference.
All parties shall meet and confer and/or exchange information at least fifteen (15) court days before the FSC as required by this order and Los Angeles County Court Rules, Rule 3.25(g).
Page 5
Parties must meet and confer on all motions in limine before filing.
All parties must meet and confer on all motions in limine prior to filing said motions.
Page 7
All parties must meet and confer on motions in limine before filing them, and failure to exchange or discuss a motion may result in the Court refusing to hear it.
All parties must meet and confer on all motions in limine prior to filing said motions. Failure by any party or counsel to exchange or discuss any motion in limine may result in the refusal by the Court to hear any such motion in limine, pursuant to applicable court rules. Boilerplate or form motions in limine are disfavored. See “Motions in Limine Best Practices.”
Page 7 | REQUIREMENTS FOR SPECIFIC TRIAL DOCUMENTS - MOTIONS IN LIMINE
Parties must meet and confer before trial regarding objections to listed exhibits, and objections not raised in the meet and confer are waived absent good cause.
Any party objecting to any listed exhibit, whether as to foundation or admissibility, must first meet and confer prior to trial. Any objections not so discussed in the meet and confer shall be deemed waived except upon a showing of good cause.
Page 9 | JOINT EXHIBIT LIST
Ex parte applications are heard Monday through Friday at 8:30 a.m. and do not require a reservation.
Ex Parte applications are heard Monday through Friday at 8:30 a.m. No reservation is needed.
Page 1 | Ex Parte Applications
Adjournment & Extension Requirements
Continuances require a written Stipulation and Order stating complaint filing date, current trial date, and proposed FSC and trial dates; if no stipulation, use noticed motion or ex parte.
All hearing dates, including trial dates, may be considered for a continuance by written Stipulation and Order. Said Stipulation and Order shall state the date the Complaint was filed, the current trial date, as well as the proposed Final Status Conference date and proposed trial date. If there is no stipulation, the parties may seek a continuance by noticed motion or an Ex Parte application.
Page 3
Continuances of hearing and trial dates may be sought by written Stipulation and Order stating the complaint filing date, current trial date, and proposed Final Status Conference and trial dates, or alternatively by noticed motion or ex parte application if there is no stipulation.
All hearing dates, including trial dates, may be considered for a continuance by written Stipulation and Order. Said Stipulation and Order shall state the date the Complaint was filed, the current trial date, as well as the proposed Final Status Conference date and proposed trial date. If there is no stipulation, the parties may seek a continuance by noticed motion or an Ex Parte application.
Page 3 | Continuances
Chambers Communication Rules
Parties are requested to immediately notify the Clerk by phone at (818) 407-2249 upon settlement or resolution of the action.
The parties are also requested to notify the Clerk of this Court immediately by phone, (818) 407-2249, upon settlement or resolution of the action.
Page 5 | Final Status Conference Order
For technical difficulties with LACourtConnect remote appearances, call the service desk at (213) 830-0400.
For any technical difficulties please call the service desk at (213) 830-0400.
Page 1 | Remote Appearances (LACourtConnect)