Court Rules

Court-wide rules

Applies court-wide

These 188 rules apply across Los Angeles Superior Court. Where this judge's own standing orders above address the same topic, the judge's requirement controls.

Filing Requirements

All 60
  • Applies to
    Joint isc statement

    Upon assignment to Department 11, an ISC Order stays all proceedings and the parties must submit a joint ISC statement as directed in that Order.

  • Applies to
    Joint status conference statement

    The parties must file a joint statement outlining recent progress in the case before every status conference.

  • Applies to
    Bulletin board posting

    Parties must make joint bulletin board postings rather than unilateral postings, which are treated as prohibited ex parte communications.

Filing Timing

All 28
  • Deadline
    5 business days

    The joint status conference statement must be filed at least five court days before every status conference.

  • The Court's order scheduling an IDC stays any deadline to file a motion to compel under CCP 2016.080(c)(2).

  • The Court cannot shorten the notice period for summary judgment/adjudication motions, though it may hear such motions fewer than 30 days before trial.

Communication

All 20
  • Contact
    Phone to chambers
    Phone
    (213) 310-7011

    To reserve a hearing date for a motion, a party must telephone the Courtroom Assistant at (213) 310-7011.

  • Contact
    Phone to chambers

    The moving party must notify the Court as early as possible that a matter will go off calendar under CRC 3.1306(b), by posting the announcement on the e-service bulletin board and telephoning the courtroom.

  • Contact
    Phone

    Parties at an impasse during a deposition may telephone the courtroom at (213) 310-7011 to arrange an immediate conference call with the Court.

Pre-Motion Conferences

All 18
  • For discovery disputes (other than deposition impasses), parties may request an informal conference by making a joint posting on the e-service bulletin board.

  • Before preparing an ex parte application for emergency relief, parties must post a joint request for an informal conference on the e-service bulletin board and contact courtroom staff to obtain a time and date.

  • Parties must meet and confer twice by telephone or video before requesting an IDC, and are expected to extend motion-to-compel deadlines to accommodate the process.

About Judge Kristin S. Escalante

Judge Kristin S. Escalante is a judge in the Superior Court of California, County of Los Angeles, serving in the district. The Superior Court of California, County of Los Angeles is the state trial court serving Los Angeles County.

This judge's procedures are published through the court's general rules.

Common questions about Judge Kristin S. Escalante's rules

Are courtesy copies required for Judge Kristin S. Escalante?

Courtesy-copy rule applies for exhibit binders. Details: 1 copy, delivery at final status conference. Parties must bring one set of the Exhibit Binders to the Final Status Conference for the court to review.

View ruleSource: page 10, section 4. EXHIBIT BINDERS

Does Judge Kristin S. Escalante require a pre-motion conference or letter before filing a motion?

Judge Kristin S. Escalante's rules set a pre-motion procedure for covered motions. All law and motion hearing dates must be reserved in advance through the Court Reservation System (CRS).

View ruleSource: page 2, section LAW&MOTION

What page or word limits apply to idc memorandum before Judge Kristin S. Escalante?

Judge Kristin S. Escalante's rule states these limits: 2 pages; 2 pages. IDC memoranda are limited to two pages for the moving party and two pages for the responding party's responsive memorandum.

View ruleSource: page 3, section Discovery Motions and Informal Discovery Conferences

What page or word limits apply to memorandum before Judge Kristin S. Escalante?

Judge Kristin S. Escalante's rule states these limits: attorney: 2 pages; attorney: 2 pages. IDC memoranda are limited to 2 pages for both moving and responding parties.

View ruleSource: page 3

What formatting rules apply to filings before Judge Kristin S. Escalante?

Judge Kristin S. Escalante's formatting rule includes binding three ring binder, four sets of exhibit binders must be jointly prepared (a set for the court, a set for the judicial assistant, and a set for the witnesses), exhibits must be tabbed, internally paginated by document, properly marked, and organized numerically, copies of documentary exhibits must be one-sided, and all non-documentary exhibits must be marked with a simple written description inserted behind the corresponding numerical tab.

View ruleSource: page 10, section 4. EXHIBIT BINDERS

What must be included with joint witness list filings before Judge Kristin S. Escalante?

The rule identifies required filing content or certificates. The parties must jointly prepare and file a witness list identifying all trial witnesses, excluding impeachment and rebuttal witnesses.

View ruleSource: page 5, section TRIAL DOCUMENTS TO BE FILED - JOINT WITNESS LIST

What must be included with joint exhibit list filings before Judge Kristin S. Escalante?

The rule requires exhibit list. The parties must jointly prepare and file an exhibit list with specified columns for each trial exhibit and must meet and confer to resolve objections to the authenticity and admissibility of each exhibit.

View ruleSource: page 6, section TRIAL DOCUMENTS TO BE FILED - JOINT EXHIBIT LIST

How may parties contact Judge Kristin S. Escalante's chambers?

The rule addresses phone communications. When continuing or withdrawing a motion via CRS, parties must also call the courtroom at (213) 310-7002 to notify it of the change.

View ruleSource: page 2, section LAW&MOTION

How do I request an adjournment or extension before Judge Kristin S. Escalante?

Advance notice is not fully stated in the structured details. Motions may be continued or withdrawn only via CRS, and parties must also call the courtroom so the court is aware of the change.

View ruleSource: page 2, section LAW&MOTION

Does Judge Kristin S. Escalante require motion papers to be bundled?

Yes. Judge Kristin S. Escalante requires bundling for covered papers. The Motions in Limine Binder must contain one-sided conformed copies of all motions in limine, opposition papers, and reply papers, tabbed in numerical order in three-ring binders with opposition/reply papers behind the moving papers and colored separator sheets between them.

View ruleSource: page 10, section Motions in Limine

Are filing fees or waivers addressed before Judge Kristin S. Escalante?

The rule identifies fee waiver availability. Fee-waiver parties may request an official court reporter by filing local form LACIV 2699 at least 10 calendar days before the hearing or trial.

View ruleSource: page 1, section GENERAL INFORMATION

When is a filing treated as filed before Judge Kristin S. Escalante?

The rule addresses filing timing, filing status, or cure windows. The moving party must file and serve its IDC memorandum at least five court days before the informal discovery conference.

View ruleSource: page 3, section Discovery Motions and Informal Discovery Conferences

What rule applies to service for exhibits before Judge Kristin S. Escalante?

The rule addresses service method, recipient, or timing requirements. Details: recipient: all parties, timing: 18 calendar days before hearing. All trial exhibits must be exchanged between the parties no later than 18 calendar days before the Final Status Conference.

View ruleSource: page 4, section Trial Preparation Order
Complete rules summary for Judge Kristin S. Escalante

Fee-waiver parties may request an official court reporter by filing local form LACIV 2699 at least 10 calendar days before the hearing or trial.

Disability accommodation requests must be submitted to Department 2 or the ADA Coordinator (ADACoordinator@LACourt.ca.gov) using form MC-410 or any written format, as far in advance as possible.

All law and motion hearing dates must be reserved in advance through the Court Reservation System (CRS).

Motions may be continued or withdrawn only via CRS, and parties must also call the courtroom so the court is aware of the change.

An informal discovery conference is strongly encouraged before filing a motion to compel further responses to written discovery, but is no longer required.

Parties are strongly encouraged to stipulate to extend motion-to-compel filing deadlines to accommodate IDCs, but the court does not toll those deadlines.

Before scheduling an IDC or filing a motion to compel further responses, counsel with authority to compromise the dispute must meet and confer by telephone, videoconference, or in person and make a good-faith attempt to resolve the dispute.

IDC memoranda are limited to two pages for the moving party and two pages for the responding party's responsive memorandum.

The moving party must file and serve its IDC memorandum at least five court days before the informal discovery conference.

The responding party may file and serve a responsive IDC memorandum (max two pages) at least two court days before the IDC.

Ex parte applications must be filed by 10:00 am on the court day prior to the ex parte hearing, absent an exemption.

Trial counsel must meet and confer (by videoconference, telephone, or in person) no later than 15 calendar days before each Case Management Conference to address the issues in CRC Rules 3.724 and 3.727.

Case Management Statements must be filed at least 7 calendar days before the scheduled Case Management Conference.

All trial exhibits must be exchanged between the parties no later than 18 calendar days before the Final Status Conference.

Parties must meet and confer no later than 11 calendar days before the Final Status Conference to prepare required documents and binders and to attempt stipulations regarding trial exhibits.

All trial documents must be filed and served no later than four calendar days before the Final Status Conference.

Trial briefs are optional, but if filed they must identify the disputed claims and defenses, major legal issues with supporting authorities, relief and damages sought, and other information assisting the court.

The parties must jointly prepare and file a witness list identifying all trial witnesses, excluding impeachment and rebuttal witnesses.

The joint witness list must be organized into specified columns (witness name, calling party, expected testimony, and estimated direct/cross/redirect times) with a grand total of estimated testimony times stated in the last column.

Witnesses not listed on the joint witness list may be excluded from testifying except for impeachment or rebuttal, and calling an unlisted witness requires a prior showing of good cause to the court.

The parties must jointly prepare and file an exhibit list with specified columns for each trial exhibit and must meet and confer to resolve objections to the authenticity and admissibility of each exhibit.

In jury trials, the parties must jointly prepare and file a brief written statement of the case for the court to read to the jury.

For jury trials, counsel and self-represented parties must jointly prepare and file a Joint List of Proposed Jury Instructions containing six required items for each instruction (number, title, requesting party, agreed/contested status, objection, and whether given).

For jury trials, the parties must jointly prepare a complete set of full-text proposed jury instructions by editing CACI instructions, inserting party names, and removing blanks and irrelevant material.

When an appropriate CACI jury instruction exists, the court expects the parties to request it rather than a specially prepared instruction.

For jury trials, the parties must jointly prepare and file a proposed general or special verdict form acceptable to all parties.

If the parties cannot agree on a joint verdict form, each party must file its own separate proposed verdict form.

The court expects the parties to use the CACI special verdict form when a special verdict form is needed (sentence appears truncated in the source text).

Parties intending to use deposition or former trial testimony must meet and confer and jointly prepare and file a Joint Chart of Page and Line Designations for Deposition and Former Testimony.

Each designating party’s designations in the joint chart must include six required columns (witness number/name, date and type of testimony, page/line designations, objections, related counter-designations, and court ruling).

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