Judge Elaine W. Mandel
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- Not required
All filings
Court-wide- Chambers Drop Off • Upon Filing
- Hand Delivery
Exhibits
Court-wide- 3 copies • Hand Delivery • At Final Status Conference
Joint Discovery Statement
Court-wide- 1 copy • 3 Court Days Before Idc
Adjournments
- Trial continuances may be sought by noticed motion, ex parte application, or stipulation and order, and require a mandatory declaration showing good cause, including plans for ADR.
- Trial continuances require a mandatory declaration showing good cause and ADR plans.
Request must include
Communication
Phone
Chambers, Clerk
Chambers
Chambers
Phone
Court-widePhone
Court-wideDocument Format Requirements2 rules
FSC Exhibit Books must be 5 tabbed, indexed sets delivered to Dept. B.
6. Exhibit Books, 5 sets, tabbed and indexed, delivered to Dept. B
Motions in limine must be placed in binders organized by MIL (plaintiff's MIL, defendant's opposition, reply), with the party filing more MILs providing the binders for the court.
Motions in Limine in binders in the following format: (1) plaintiffs MIL#1;(2) defendant's opposition to MIL#1; (3) reply to MIL #1, for all plaintiffs MILs, then the same format for all defendants MILs. The party who files more MILs is to provide binders for the court.
Document Filing Requirements19 rules
Parties securing private court reporters must submit a proposed order designating the reporter as official.
Any party may secure a private court reporter with a proposed order designating the reporter as the official reporter.
Document Type
Proposed Order
Depositions must be lodged with a Notice of Lodging Depositions that includes all page/line designations.
Depositions shall be lodged 5 court days before trial with a Notice of Lodging Depositions, including all page/line designations.
Document Type
Notice Of Lodging Depositions
Notice of Lodging Depositions must include all page/line designations.
Depositions shall be lodged 5 court days before trial with a Notice of Lodging Depositions, including all page/line designations.
Document Type
Notice Of Lodging Depositions
Proposed orders for motions to withdraw as counsel must include client address, phone number, and email.
MOTIONS TO WITHDRAW AS COUNSEL: Proposed order must contain the address, telephone number and email address of the client(s).
Document Type
Proposed Order
Notices of related cases must comply with California Rules of Court 3-300 and be filed in both the older and the newer case.
Comply with California Rules of Court 3-300 regarding Notice of Related Cases. Notice must be filed in the low-number (older) case, as well as the higher-number (younger) case.
Document Type
Notice Of Related Cases
Proposed orders must be submitted for all motions and ex parte applications.
Please submit proposed orders for all motions and ex parte applications.
Document Type
Motion
Proposed orders must be submitted for all motions.
PROPOSED ORDERS: Please submit proposed orders for all motions and ex parte applications.
Document Type
Motion
A proposed order on a motion to withdraw as counsel must state the client's address, telephone number, and email address.
Proposed order must contain the address, telephone number and email address of the client(s).
Document Type
Motion To Withdraw As Counsel
A joint proposed verdict form must be efiled five court days before the FSC.
Joint Proposed Verdict Form
Document Type
Joint Proposed Verdict Form
A joint statement of the case must be efiled five court days before the FSC unless the parties request mini-openings.
Joint Statement of the Case (unless parties request mini opening)
Document Type
Joint Statement Of The Case
Joint proposed jury instructions must be submitted in three categories (agreed; plaintiff-requested/defendant-objected; defendant-requested/plaintiff-objected), fully edited, printed out and delivered to Dept. B.
Joint Proposed jury instructions in three categories: (1) agreed by counsel; (2) plaintiff requests/defendant objects; (3) defendant requests/plaintiff objects. All instructions, fully edited, printed out and delivered to Dept. B
Document Type
Joint Proposed Jury Instructions
Depositions must be lodged before trial with page and line designations.
Depositions must be lodged prior to trial, with page/line designations
Document Type
Depositions
Five sets of exhibit books, tabbed and indexed, must be delivered to Dept. B.
Exhibit Books, 5 sets, tabbed and indexed, delivered to Dept. B
Document Type
Exhibit Books
A joint witness list including testimony time estimates must be efiled five court days before the FSC.
Joint Witness List, including testimony time estimates.
Document Type
Joint Witness List
The joint exhibit list must include columns for the date the exhibit was identified and the date it was admitted.
Joint Exhibit List: include columns for DATE ID’d and DATE ADMITTED
Document Type
Joint Exhibit List
When requested, the joint status conference report must address service/answers/party status, discovery, proposed ADR, contemplated significant motions, and proposed trial date.
Joint status conference reports (JSR) are typically requested to address: status of service/answers/parties, discovery (what will be done/timeline), proposed ADR, whether significant motions are contemplated (e.g.: MSA/MSJ), proposed trial date.
Document Type
Joint Status Conference Report
Parties must exchange any PowerPoint or similar trial presentation 3 court days before trial commences, with objections discussed at the FSC or first day of trial.
The parties must exchange any power-point or similar presentation 3 court days prior to commencement of trial; if a party objects, the matter will be discussed at the FSC or first day of trial.
Document Type
Trial Presentation
If the parties cannot cooperate on joint FSC documents, individual documents may be filed with a declaration explaining the difficulty.
If there is a lack of cooperation in preparing joint documents, file individual documents with a declaration explaining the difficulty.
Document Type
Final Status Conference Documents
A proposed juror questionnaire must be submitted with the FSC documents only if requested.
Proposed Juror Questionnaire, if requested
Document Type
Proposed Juror Questionnaire
Filing & Service rules
Electronic Filing Rules
The joint status conference report must be completed jointly by all parties and uploaded to the eCourt system by plaintiff's counsel.
The JSR is to be completed jointly by all parties, uploaded to the eCourt system by plaintiff's counsel.
Page 1 | CASE MANAGEMENT CONFERENCES
Joint Status Conference Reports (JSR) must be uploaded to the eCourt system by plaintiff's counsel.
The JSR is to be completed jointly by all parties, uploaded to the eCourt system by plaintiff's counsel.
Page 1 | CASE MANAGEMENT CONFERENCES
IDC statements must be uploaded to the eCourt system.
The party seeking the IDC is responsible for uploading the IDC statement to the eCourt system 5 court days prior to the IDC.
Page 2 | DISCOVERY DISPUTES/INFORMAL DISCOVERY CONFERENCES (IDC)
FSC required documents must be efiled 5 court days prior to FSC, with physical binders provided on FSC date.
Five court days prior to the FSC, the following shall be efiled and binders to be physically provided to Dept. B on the date of the FSC.
Page 4 | FINAL STATUS CONFERENCE ORDERS
Filing Timing and Cure Windows
CMC Statements must be filed 5 court days prior to the Case Management Conference.
CASE MANAGEMENT CONFERENCES: CMC Statements are required no later than 5 court days prior to the CMC per CRC 3.725.
Page 1 | CASE MANAGEMENT CONFERENCES
CMC statements must be filed no later than 5 court days before the case management conference, and the parties must meet and confer per CRC 3.724 and 3.727.
CMC Statements are required no later than 5 court days prior to the CMC per CRC 3.725. Meet and confer per CRC 3.724 and 3.727.
Page 1 | CASE MANAGEMENT CONFERENCES
Deadlines for filing motions to compel are tolled until the IDC is held.
The court TOLLS deadlines for filing motions to compel prior to holding an IDC.
Page 2 | DISCOVERY DISPUTES/INFORMAL DISCOVERY CONFERENCES (IDC)
A joint IDC statement listing all issues to be discussed must be uploaded to the eCourt system 5 court days before the IDC by the party seeking the IDC.
The parties are to file a joint IDC statement five days prior to the IDC, stating all issues to be discussed at the IDC. The party seeking the IDC is responsible for uploading the IDC statement to the eCourt system 5 court days prior to the IDC.
Page 2 | DISCOVERY DISPUTES/INFORMAL DISCOVERY CONFERENCES (IDC)
Depositions must be lodged 5 court days before trial.
Depositions shall be lodged 5 court days before trial with a Notice of Lodging Depositions, including all page/line designations.
Page 2 | LODGING DEPOSITIONS
Joint IDC statements must be filed and uploaded to eCourt 5 court days before the IDC.
The parties are to file a joint IDC statement five days prior to the IDC, stating all issues to be discussed at the IDC. The party seeking the IDC is responsible for uploading the IDC statement to the eCourt system 5 court days prior to the IDC.
Page 2 | DISCOVERY DISPUTES/INFORMAL DISCOVERY CONFERENCES (IDC)
Ex parte applications and TRO/preliminary injunction requests are heard Monday through Friday at 8:30 a.m.
Ex Parte Applications and Requests for Temporary Restraining Orders/Preliminary Injunctions are heard MONDAY through FRIDAY at 8:30 a.m.
Page 2 | EX PARTE APPLICATIONS
Depositions must be lodged 5 court days before trial with a notice including page/line designations.
Depositions shall be lodged 5 court days before trial with a Notice of Lodging Depositions, including all page/line designations.
Page 2 | LODGING DEPOSITIONS
Jury fees must be submitted 30 days before trial.
Jury fees must be posted, or a jury fee waiver order obtained, no later than 30 days before trial.
Page 2 | JURY FEES
Final status conference documents must be efiled five court days before the FSC, with physical binders delivered to Dept. B on the FSC date.
Five court days prior to the FSC, the following shall be efiled and binders to be physically provided to Dept. B on the date of the FSC.
Page 4 | FINAL STATUS CONFERENCE ORDERS
Deadlines for filing motions to compel are tolled until the IDC is held.
The court TOLLS deadlines for filing motions to compel prior to holding an IDC.
Page 2 | DISCOVERY DISPUTES/INFORMAL DISCOVERY CONFERENCES (IDC)
Service and Proof of Service Rules
Orders withdrawing counsel become effective only upon filing the proof of service of the conformed order on all parties and clients.
Orders are effective upon filing the proof of service of the conformed order on all parties and clients.
Page 3 | MOTIONS TO WITHDRAW AS COUNSEL
Motions to withdraw as counsel are effective upon filing proof of service of the conformed order on all parties and clients.
Orders are effective upon filing the proof of service of the conformed order on all parties and clients.
Page 3 | MOTIONS TO WITHDRAW AS COUNSEL
Filing Fees and Waivers
Jury fees must be posted (or a jury fee waiver order obtained) no later than 30 days before trial, and the court may order posting within 5 court days after trial is scheduled.
Jury fees must be posted, or a jury fee waiver order obtained, no later than 30 days before trial. The court may order jury fees to be posted within 5 court days after the trial is scheduled.
Page 2 | JURY FEES
Jury fees must be posted or a waiver order obtained 30 days before trial; court may order posting within 5 days of trial scheduling.
Jury fees must be posted, or a jury fee waiver order obtained, no later than 30 days before trial. The court may order jury fees to be posted within 5 court days after the trial is scheduled.
Page 2 | JURY FEES
Court reporters are provided only with prior request and fee waiver.
The court does not provide court reporters without a prior request and fee waiver.
Page 1 | COURT REPORTERS
Courtesy Copy Requirements
Courtesy copies are accepted but not required.
COURTESY COPIES: Accepted, but not required.
Page 2 | COURTESY COPIES
Courtesy copies are accepted by the court but are not required.
COURTESY COPIES: Accepted, but not required.
Page 2 | COURTESY COPIES
Filing Bundling Requirements
Motions in Limine must be filed in binders with specific formatting and meet and confer required prior to filing.
8. Motions in Limine in binders in the following format: (1) plaintiffs MIL#1;(2) defendant's opposition to MIL#1; (3) reply to MIL #1, for all plaintiffs MILs, then the same format for all defendants MILs. The party who files more MILs is to provide binders for the court. The parties are to meet and confer on ALL MILs prior to filing.
Page 4 | FINAL STATUS CONFERENCE ORDERS
Court prefers consolidation of related discovery motions into a single omnibus motion.
Further, moving party is requested to consolidate discovery motions (e.g. if a party is moving to compel interrogatories, RFPs and RFAs, the court prefers ONE omnibus discovery motion, rather than multiple motions).
Page 2 | DISCOVERY DISPUTES/INFORMAL DISCOVERY CONFERENCES (IDC)
The court requests that moving parties consolidate discovery motions into one omnibus discovery motion rather than filing multiple motions.
Further, moving party is requested to consolidate discovery motions (e.g. if a party is moving to compel interrogatories, RFPs and RFAs, the court prefers ONE omnibus discovery motion, rather than multiple motions).
Page 2 | DISCOVERY DISPUTES/INFORMAL DISCOVERY CONFERENCES (IDC)
Pre-Motion Conference Requirements
Informal Discovery Conferences (IDC) are required before filing or hearing discovery motions.
The parties are to schedule an IDC prior to filing discovery motions. If motions have been filed, an IDC will proceed before the motion will be heard.
Page 2 | DISCOVERY DISPUTES/INFORMAL DISCOVERY CONFERENCES (IDC)
Parties must schedule an informal discovery conference before filing discovery motions, and any filed discovery motion will not be heard until an IDC is held.
The parties are to schedule an IDC prior to filing discovery motions. If motions have been filed, an IDC will proceed before the motion will be heard.
Page 2 | DISCOVERY DISPUTES/INFORMAL DISCOVERY CONFERENCES (IDC)
Ex parte applications to shorten motion hearing time require reserving the motion date on CRS first.
For an Ex Parte Application to shorten time for hearing on a motion, the motion date should first be reserved on CRS before the ex parte hearing.
Page 2 | EX PARTE APPLICATIONS
For an ex parte application to shorten time on a motion, the motion date should first be reserved on CRS before the ex parte hearing.
For an Ex Parte Application to shorten time for hearing on a motion, the motion date should first be reserved on CRS before the ex parte hearing. CRC Rule 3.1203.
Page 2 | EX PARTE APPLICATIONS
Motion hearing dates must be reserved via the Court Reservation System (CRS) unless scheduled by the court.
Hearing dates must be reserved via the Court Reservation System (CRS), unless scheduled by the court.
Page 3 | MOTIONS
Motion hearing dates must be reserved through the Court Reservation System (CRS) unless the court schedules them, and motions are heard daily at 8:30 a.m.
Hearing dates must be reserved via the Court Reservation System (CRS), unless scheduled by the court.
Page 3 | MOTIONS
Parties must meet and confer on all Motions in Limine prior to filing.
The parties are to meet and confer on ALL MILs prior to filing.
Page 4 | FINAL STATUS CONFERENCE ORDERS
Parties must meet and confer on all motions in limine before filing them.
The parties are to meet and confer on ALL MILs prior to filing.
Page 4 | FINAL STATUS CONFERENCE ORDERS
Ex parte applications and TRO/preliminary injunction requests are heard Monday through Friday at 8:30 a.m.
Ex Parte Applications and Requests for Temporary Restraining Orders/Preliminary Injunctions are heard MONDAY through FRIDAY at 8:30 a.m.
Page 2 | EX PARTE APPLICATIONS
Adjournment & Extension Requirements
Trial continuances may be sought by noticed motion, ex parte application, or stipulation and order, and require a mandatory declaration showing good cause, including plans for ADR.
Trial continuances may be heard by noticed motion, ex parte application or by stipulation and order with a mandatory declaration showing good cause for the requested continuance, including plans for ADR.
Page 1 | CONTINUANCES
Trial continuances require a mandatory declaration showing good cause and ADR plans.
CONTINUANCES: Trial continuances may be heard by noticed motion, ex parte application or by stipulation and order with a mandatory declaration showing good cause for the requested continuance, including plans for ADR.
Page 1 | CONTINUANCES
Chambers Communication Rules
The department/chambers telephone number is (818) 901-4614, available 8:30 a.m. to 12:00 p.m. and 1:30 p.m. to 4:30 p.m.
Telephone Number: (818} 901-4614 Hours: 8:30 a.m. to 12:00 p.m.; 1:30 p.m. to 4:30 p.m.
Page 1 | COURTROOM INFORMATION
Chambers phone number is (818) 901-4614, available during 8:30 AM-12 PM and 1:30 PM-4:30 PM.
Telephone Number: (818} 901-4614 Hours: 8:30 a.m. to 12:00 p.m.; 1:30 p.m. to 4:30 p.m.
Page 1 | Telephone Number
For scheduling-only ex parte matters with all counsel's stipulation, parties may call the clerk at (818) 901-4614, who may reschedule without an ex parte filing or appearance.
If the ex parte is for scheduling only with the stipulation of all counsel, contact the court at (818) 901-4614, as the clerk may be able to reschedule the matter without need for an ex parte application and appearance.
Page 2 | EX PARTE APPLICATIONS
For remote call (CourtConnect) technical issues, disconnect and reconnect if not admitted within 10 minutes; if that fails, call the department at (818) 901-4614.
If you are not admitted to the call within 10 minutes, please disconnect and re-connect. If that does not work, please call the department at (818) 901-4614.
Page 2 | COURTCONNECT
For CourtConnect issues, call chambers at (818) 901-4614 after trying to reconnect.
COURTCONNECT: If you are not admitted to the call within 10 minutes, please disconnect and re-connect. If that does not work, please call the department at (818) 901-4614.
Page 2 | COURTCONNECT