Judge Gregory W. Alarcon
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
All filings
Court-wide- Chambers Drop Off • Upon Filing
- Hand Delivery
Courtesy copies
Court-wide- 3 copies
Exhibits
Court-wide- 3 copies • Hand Delivery • At Final Status Conference
Joint Discovery Statement
Court-wide- 1 copy • 3 Court Days Before Idc
Adjournments
Court-wideRequest 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
Clerk2 contacts
- 213-830-0800 (Stanley Mosk); 213-310-7000 (Spring St)
- 213-830-0845
Document Format Requirements14 rules
Exhibits must be prepared in three-ring binders with numbered divider tabs, with copies for court, clerk, witnesses, and counsel, prior to trial.
Three-ring binders with numbered divider tabs containing all exhibits marked for identification must be prepared prior to trial, including copies for the Court, Clerk, testifying witnesses and all counsel.
Tabbed three-ring binders containing all marked exhibits must be prepared before trial, with copies for the Court, Clerk, testifying witnesses, and all counsel.
Three-ring binders with numbered divider tabs containing all exhibits marked for identification must be prepared prior to trial, including copies for the Court, Clerk, testifying witnesses and all counsel.
Demonstrative evidence and blow-ups must be marked for identification and shown or played for opposing counsel before trial.
Demonstrative evidence and blow-ups must be marked for identification and shown to or played for opposing counsel before trial.
Exhibit marking must conform to S.C.L.A.C. Rule 3.53: Arabic numerals in sequential party-number blocks, with multi-page documentary exhibits internally paginated in sequential order.
Your joint exhibit list must conform to S.C.L.A.C. Rule 3.53, which provides: "The most efficient method of marking exhibits is the use of Arabic numerals in which each party is allocated a block of numbers to be used sequentially. For instance, plaintiff may be allocated numbers 1 to 200, the first defendant numbers 201 to 400, and the second defendant numbers 401 to 600. Documentary exhibits consisting of more than one page must be internally paginated in sequential numerical order to facilitate reference to the document during interrogation of witnesses."
Hard copies of agreed and not-agreed jury instructions must be filed 5 court days before the final status conference.
Five court days before the final status conference, please file a “hard copy” of jointly agreed instructions, and each counsel's separate statement set of "not-agreed-upon" instructions with your objections.
Paper
A computer disk in Word format containing the agreed-upon jury instructions must be brought to court on the first day of trial.
A computer disk in Word format of the agreed upon instructions should be brought to court on the first day of trial.
DOCX
Any submitted jury instructions must be in proper format per California Rules of Court, rule 2.1055, with correct party references and no blanks, brackets, empty spaces, or inapplicable options.
a set of agreed jury instructions (and, if necessary, a separate set of instructions to which there is disagreement), in the proper format with all changes and modifications applicable to the case in accordance with California Rules of Court, rule 2.1055, (i.e., correct references to the parties, no blanks, brackets, empty spaces, or inapplicable options);
Counsel must premark exhibits and produce the requisite number of exhibit books, and may not rely on the clerk to track exhibits or produce exhibits at trial that opposing counsel has never seen (except for impeachment).
Please do not: • Fail to premark your exhibits. • Expect the clerk to keep track of your exhibits. • Produce exhibits at trial which opposing counsel has never seen, unless they are used for impeachment. • Fail to produce the requisite numbers of exhibit books.
Exhibits with original or deposition page numbers must be re-numbered, letters must not be used for exhibits, and each photograph requires its own exhibit number presented separately.
Documents with original page numbers, or numbers which were attached to deposition transcripts, should be re-numbered (e.g., 31-1, 31-2, etc.). Avoid using letters for exhibits. Each photograph should have its own exhibit number and be presented separately (e.g., Ex. 1-1, Ex. 1-2, etc.).
A CD in Word format containing the proposed verdict form should be brought to court on the first day of trial.
A CD in Word format should be brought to court on the first day of trial.
DOCX
Counsel must prepare a computer disk of the proposed verdict form and have it ready at trial.
As with jury instructions, prepare a computer disk of the proposed verdict form and have it ready at trial.
A Word-format computer disk of agreed jury instructions must be brought to court on the first day of trial.
A computer disk in Word format of the agreed upon instructions should be brought to court on the first day of trial.
DOCX
Special verdict forms should follow the suggested formats in the CACI instructions.
In drafting a form of special verdict, counsel should rely upon the suggested formats set forth in the CACI instructions.
A Word-format CD of the proposed verdict form must be brought to court on the first day of trial.
A CD in Word format should be brought to court on the first day of trial.
DOCX
Document Filing Requirements10 rules
At least five days before the final status conference, counsel must serve and file pre-marked exhibit lists, jury instruction requests, trial witness lists, and a proposed short statement of the case.
(1) At least five days prior to this conference, counsel must serve and file lists of pre-marked exhibits to be used at trial [see Local Rules 3.151, 3.53 and 3.149], jury instruction requests, trial witness lists, and a proposed short statement of the case to be read to the jury panel explaining the case. S.C.L.A.C. Rule 3.25 (f) (1).
Document Type
Pretrial Documents
Counsel must comply with S.C.L.A.C. Rule 3.25(f)-(h) regarding preparation for the final status conference and trial.
You are required to comply with S.C. L.A.C. Rule 3.25(f)-(h) concerning preparation for the final status conference and trial.
Document Type
Pretrial Documents
Counsel must meet and confer to prepare a joint list of exhibits that will be marked for identification and introduced at trial.
Counsel must meet and confer to prepare a joint list of exhibits, which will be marked for identification and introduced at trial.
Document Type
Joint Exhibit List
All original depositions must be lodged with the court before trial begins.
All original depositions must be lodged with the court prior to the beginning of trial.
Document Type
Original Depositions
The court may, in its discretion, require an in-person meeting of counsel and joint trial documents (early submission of trial documents, joint jury statement, joint witness list, joint exhibit list, agreed jury instructions in proper format, and an agreed special verdict form with interrogatories).
S.C.L.A.C. Rule 3.25(g)(2)-(8) allows the court, in its discretion, to require: "an 'in person" meeting of counsel before the final status conference concerning the submission to the court of joint trial documents: the submission of trial documents to the court more than five days before the final status conference; a joint statement to be read to the jury; a joint witness list; a joint exhibit list; a set of agreed jury instructions (and, if necessary, a separate set of instructions to which there is disagreement), in the proper format with all changes and modifications applicable to the case in accordance with California Rules of Court, rule 2.1055, (i.e., correct references to the parties, no blanks, brackets, empty spaces, or inapplicable options); and an agreed special verdict form with interrogatories."
Document Type
Joint Trial Documents
Objections to jury instructions must be noted in a separate document filed for the court.
Be certain to note objections filed in a separate document for the court.
Document Type
Jury Instruction Objections
An opposition to a motion in limine must state the grounds for opposition in the caption and provide reasons supported by legal authorities and factual reasons.
The opposing party should not only state the grounds for opposition in the caption but also provide the reasons for the opposition with pertinent legal authorities and factual reasons.
Document Type
Opposition
Points and authorities supporting a motion in limine must avoid boilerplate and vague 'exclude testimony' requests and use appropriate, brief citations.
The memorandum of points and authorities in support of the motion in limine should avoid boilerplate verbiage and citations. Vague motions to “exclude testimony” without specifics do not assist the Court. Use appropriate and brief citations to support legal authorities and evidence.
Document Type
Motion In Limine
Parties must make additional copies of the witness list for each juror and confer with opposing counsel about drafting a single witness list for trial.
Make additional copies of the witness list for each juror. Confer with opposing counsel regarding drafting a single list of witnesses for trial.
Document Type
Witness List
If counsel cannot agree on a verdict form in advance, alternative verdict forms should be submitted.
If counsel cannot agree in advance on a verdict form, alternative verdict forms should be submitted.
Document Type
Verdict Form
Filing & Service rules
Filing Timing and Cure Windows
Pre-trial documents must be filed 5 court days before the final status conference.
You are required to file your pre-trial documents five (5) court days before the final status conference.
Page 1 | FINAL TRIAL PREPARATION
Pre-trial documents must be filed five court days before the final status conference.
You are required to file your pre-trial documents five (5) court days before the final status conference.
Page 1 | FINAL TRIAL PREPARATION
Counsel must serve and file pre-marked exhibit lists, jury instruction requests, trial witness lists, and proposed case statement 5 days before the final status conference.
At least five days prior to this conference, counsel must serve and file lists of pre-marked exhibits to be used at trial [see Local Rules 3.151, 3.53 and 3.149], jury instruction requests, trial witness lists, and a proposed short statement of the case to be read to the jury panel explaining the case. S.C.L.A.C. Rule 3.25 (f) (1).
Page 1 | FINAL TRIAL PREPARATION
A joint exhibit list must be filed five court days before the final status conference.
A joint exhibit list is required to be filed five (5) court days before the final status conference.
Page 3 | VI. EXHIBIT LIST
A joint exhibit list must be filed 5 court days before the final status conference.
A joint exhibit list is required to be filed five (5) court days before the final status conference.
Page 3 | EXHIBIT LIST
All original depositions must be lodged with the court before trial starts.
All original depositions must be lodged with the court prior to the beginning of trial.
Page 4 | EXHIBIT LIST
Motions in limine must be filed 5 court days before the final status conference.
Motions in limine are due five (5) court days before the final status conference.
Page 4 | MOTIONS IN LIMINE
Motions in limine are due five court days before the final status conference and will be heard on the day of trial unless specially set as noticed motions.
Motions in limine are due five (5) court days before the final status conference. Unless specially set as noticed motions, they will be heard on the day of trial.
Page 4 | VII. MOTIONS IN LIMINE
Oppositions to motions in limine must be filed no less than 5 court days before trial.
Oppositions are due no less than five court days before trial.
Page 5 | MOTIONS IN LIMINE
Motions in limine must be filed five court days before the final status conference and will be heard on the day of trial unless specially set.
Although motions in limine must be filed five court days before the final status conference in this department, they will be heard on the day of trial unless specially set.
Page 5 | VII. MOTIONS IN LIMINE
Five court days before the final status conference, parties must file a hard copy of jointly agreed instructions plus each counsel's separate statement of not-agreed-upon instructions with objections.
Five court days before the final status conference, please file a “hard copy” of jointly agreed instructions, and each counsel's separate statement set of "not-agreed-upon" instructions with your objections.
Page 5 | JURY INSTRUCTIONS
A joint set of proposed, accepted, and unaccepted jury instructions is due five court days before the final status conference.
A joint set of proposed, accepted and unaccepted jury instructions are due five (5) court days before the final status conference.
Page 5 | JURY INSTRUCTIONS
Oppositions to motions in limine, including Evidence Code section 402 hearing requests, are due no less than five court days before trial.
Oppositions are due no less than five court days before trial. This includes requests for hearing under Evidence Code section 402.
Page 5 | VII. MOTIONS IN LIMINE
Joint jury instructions must be filed 5 court days before the final status conference.
A joint set of proposed, accepted and unaccepted jury instructions are due five (5) court days before the final status conference.
Page 5 | JURY INSTRUCTIONS
A joint witness list with time estimates for direct and cross-examination is due five court days before the final status conference.
A joint witness list with time estimates for direct and cross-examination is due five (5) court days before the final status conference.
Page 6
Joint witness list with time estimates must be filed 5 court days before the final status conference.
A joint witness list with time estimates for direct and cross-examination is due five (5) court days before the final status conference.
Page 6
An agreed proposed joint special or general verdict form must be filed five court days before the final status conference.
An agreed proposed joint special verdict form with interrogatories or a general verdict form must be filed five (5) court days before the final status conference.
Page 7 | XI. VERDICT FORM
Joint special verdict or general verdict form must be filed 5 court days before the final status conference.
An agreed proposed joint special verdict form with interrogatories or a general verdict form must be filed five (5) court days before the final status conference.
Page 7 | VERDICT FORM
A proposed joint verdict form must be filed together with the pre-trial conference documents.
A proposed joint verdict must be filed with the pre-trial conference documents.
Page 7 | XI. VERDICT FORM
Service and Proof of Service Rules
All exhibits must be exchanged with opposing counsel early, long before trial.
All exhibits are to be exchanged early, long before jury
Page 3 | VI. EXHIBIT LIST
Demonstrative evidence must be marked and shown/played to opposing counsel before trial.
Demonstrative evidence and blow-ups must be marked for identification and shown to or played for opposing counsel before trial.
Page 4 | EXHIBIT LIST
Filing Bundling Requirements
Each motion in limine must be filed separately with its own supporting papers, and pleadings may not be stapled, bundled together, or filed as an omnibus motion.
Each motion should be filed separately with its own points and authorities, supporting declarations and other evidence. Please do not staple or bundle the individual pleadings together with other motions in limine or file them as an “omnibus” series of motions in a single pleading.
Page 5 | VII. MOTIONS IN LIMINE
Bundling or filing omnibus motions in limine is prohibited; each motion must be filed separately.
Please do not staple or bundle the individual pleadings together with other motions in limine or file them as an “omnibus” series of motions in a single pleading.
Page 5 | MOTIONS IN LIMINE
Pre-Motion Conference Requirements
Trial attorneys should meet and confer before filing motions in limine to avoid unnecessary motions.
The trial attorneys should meet and confer before generating unnecessary motions in limine.
Page 4 | VII. MOTIONS IN LIMINE