Judge Michael B. Wilson
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- 1 copy • At Final Status Conference
- 3 copies • On First Day Of Trial
E Filed Documents
- Hand Delivery • Upon Filing
Joint Statement Discovery In Dispute
- 1 copy • Three Court Days Before Idc
Powerpoint Slides
- 1 copy
Adjournments
- Continuances of hearings or trials require a written stipulation and order stating the complaint filing date, proposed continuance date(s), and good-cause grounds.
- Without a stipulation, continuances may be sought by noticed motion or ex parte application, and the court will not continue hearing/trial dates over opposition without a good-cause showing by the requesting party.
- Litigants should minimize shortening-time requests, and failure to timely schedule motion practice will not be treated as a basis for ex parte relief.
- +3 more
Request must include
Communication
Phone
Chambers
Chambers
Chambers
Phone
Court-wideClerk
Phone
Court-wideClerk
Phone
Court-widePhone
Court-wideClerk
Page & Word Limits2 rules
A court-ordered IDC joint statement of discovery in dispute must not exceed five pages.
If the Court orders an IDC a joint statement of discovery in dispute (no more than five pages) shall be filed and a courtesy copy delivered to Department E three (3) court days before the IDC.
Joint Statement Discovery In Dispute
5 pages
Joint discovery dispute statements for IDC must not exceed 5 pages.
If the Court orders an IDC a joint statement of discovery in dispute (no more than five pages) shall be filed and a courtesy copy delivered to Department E three (3) court days before the IDC.
Joint Discovery Statement
5 pages
Applies to: Attorney
Document Format Requirements9 rules
Proposed jury instructions must be prepared on LASC form LACIV 129 or a Word document in the same format, including the disposition box.
The proposed jury instructions shall be prepared on Los Angeles Superior Court form LASC LACIV 129 or in a Word document that is in the same format including the disposition box.
DOCX
Each party must bring an electronic copy of its proposed verdict form in Word format to the Final Status Conference, ready to be edited in the courtroom.
each party must separately file a proposed verdict form, and bring an electronic copy of their proposed verdict form in Word to the FSC, ready to be edited in the courtroom
DOCX
Parties must attach copies of designated transcript pages to the joint chart with numbered tabs separating each transcript, and each designation or counter-designation must be highlighted using a different color highlighter per party.
The parties shall attach copies of the pages of the transcripts of the deposition or former testimony they are designating or counter-designating to the Joint Chart of Page and Line Designations for Deposition and Former Testimony, with numbered tabs separating each deposition or trial transcript. Each designation or counter-designation shall be highlighted, with each party using a different color highlighter.
Copies of documentary exhibits must be one-sided.
Copies of documentary exhibits shall be one-sided copies.
Motions in Limine Binder must be two-sided, conformed copies in 3" three-ring binders, tabbed, indexed, with colored separators.
The Motions in Limine Binder shall include two-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders not to exceed 3" per binder, indexed and tabbed in numerical order with the opposition papers and reply papers for each motion placed directly behind the moving papers with a colored sheet of paper separating the moving, opposition, and reply papers.
The Motions in Limine Binder must contain two-sided conformed copies in 3-inch three-ring binders, indexed and tabbed numerically with colored separator sheets, and must not include proposed orders.
The Motions in Limine Binder shall include two-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders not to exceed 3" per binder, indexed and tabbed in numerical order with the opposition papers and reply papers for each motion placed directly behind the moving papers with a colored sheet of paper separating the moving, opposition, and reply papers. Proposed orders should not be included in the Motions in Limine Binder.
The Trial Binder must consist of one-sided conformed copies, tabbed, organized in a three-ring binder with a table of contents.
consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents
Trial binder must include a joint chart of deposition page/line designations behind Tab H and copies of the current operative pleadings behind Tab I.
TabH: Joint Chart of Page/Line Designations for Deposition/Former Testimony; Tab I: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).
Proposed jury instructions must be organized behind Tab F into three labeled groups: agreed-upon instructions, plaintiff's requested instructions to which defendant objects, and defendant's requested instructions to which plaintiff objects.
The parties shall organize proposed jury instructions into groups behind Tab F in the following order (labeled by cover sheets): (1) the agreed-upon instructions, (2) plaintiff's requested instructions to which defendant objects, and (3) defendant's requested instructions to which plaintiff objects.
Document Filing Requirements33 rules
If no court reporter is used at trial, the parties must jointly prepare a summary of the day's proceedings and lodge it in the courtroom the next morning before proceedings resume.
If no court reporter is used, the parties must jointly prepare a summary of the day's proceedings, and lodge it in the courtroom the next morning before proceedings resume.
Document Type
Joint Summary Of Daily Proceedings
All trial documents, except exhibits, must be filed in compliance with the Court's TRIAL PREPARATION REQUIREMENTS.
All trial documents must be filed pursuant to the TRIAL PREPARATION REQUIREMENTS (except for exhibits).
Document Type
Trial Documents
Each party must file a trial brief identifying disputed claims and defenses, major legal issues with supporting authorities, relief and damages calculations, and other trial-assisting information.
Each party is required to file a trial brief succinctly identifying: (I) the claims and defenses that remain in dispute for trial; (2) the major legal issues (with supporting points and authorities); (3) the relief and calculation of any damages sought; and (4) any other information that may assist the court at trial.
Document Type
Trial Brief
Parties must jointly prepare and file a witness list in a prescribed column format (name, expert status, accommodations, calling party, expected testimony, examination time estimates) excluding impeachment and rebuttal witnesses, with a grand total of estimated testimony hours.
The parties' counsel and any self-represented parties shall work together to prepare and file a joint list of all witnesses whom any party intends to call at trial, excluding impeachment and rebuttal witnesses. (Los Angeles County Court Rule ("Local Rule") 3.25, subd. (g)(5).) The joint witness list shall be organized with columns (in the format set forth below) which state (I) the name of each witness (in alphabetical order), if the witness is being called to testify as an expert, and any special requirements or accommodations needed for the witness (e.g., interpreter),-(2) the party calling the witness, (3) whether the witness is actually expected to testify, (4) a brief description of the witness's expected testimony, (5) an estimate of the length of direct and redirect examination (in hours), (6) an estimate of the length of cross-examination (in hours), and (7) the total estimated length of examination (in hours). At the end of the joint witness list, the parties and any self-represented parties shall add up the estimated times for all witnesses' testimony and state the grand total in the last column.
Document Type
Joint Witness List
Counsel and self-represented parties must jointly prepare and file an exhibit list stating, for each exhibit, the exhibit number, description, offering party, authentication and admissibility stipulations, evidentiary objections, and marking/admission dates.
The parties' counsel and any self-represented parties shall work together to prepare and file a joint exhibit list organized with columns (in the format set forth below) which state, as to each exhibit any party intends to offer at trial: (1) the exhibit number, (2) a brief description of the exhibit, (3) which party is offering the exhibit, (4) whether the parties have stipulated to authentication of the exhibit, (5) whether the parties have stipulated to admissibility of the exhibit, (6) any evidentiary objections to admission of the exhibit with reference to the applicable evidence code section(s) or other legal authority, (7) the date the exhibit was marked for identification, and (8) the date the exhibit was admitted into evidence. (Local Rule 3.25, subd. (g)(6).)
Document Type
Joint Exhibit List
At the end of each trial day, counsel must meet and confer and submit an agreed-upon list of all exhibits admitted that day to the Court's judicial assistant.
At the end of each trial day counsel must meet and confer and submit to the Court's judicial assistant an agreed-upon list of all exhibits admitted that day.
Document Type
List Of Exhibits Admitted
Parties must meet and confer in good faith to resolve exhibit objections, and any objection not articulated on the exhibit list may result in the exhibit being deemed admitted.
As set forth above, the parties' counsel and any self-represented parties shall meet and confer in good faith an effort to resolve objections to the authenticity and admissibility of each exhibit. If an objection to an exhibit is not articulated on the exhibit list, the trial court may deem the exhibit admitted.
Document Type
Joint Exhibit List
After the jury instruction conference, one party must submit the final court-approved set of jury instructions, including court-ordered modifications and excluding the disposition table from the top of each instruction.
After the jury instruction conference, the court will require one of the parties to submit a final set of jury instructions approved by the court, including any modifications ordered by the court, and excluding the disposition table from the top of each instruction.
Document Type
Final Jury Instructions
In jury trials, parties must jointly prepare a complete set of full-text proposed jury instructions, editing CACI instructions to insert party names and eliminate blanks and irrelevant material.
For jury trials, the parties' counsel and any self-represented parties shall work together to prepare a complete set of full-text proposed jury instructions, editing all proposed Judicial Council of California Civil Jury Instructions ("CACI") instructions, inserting party names, and eliminating blanks and other irrelevant or inapplicable material.
Document Type
Proposed Jury Instructions
In jury trials, counsel and self-represented parties must jointly prepare and file a brief written statement of the case for the court to read to the jury.
For jury trials, the parties' counsel and any self-represented parties shall work together to prepare and file a brief, joint written statement of the case for the court to read to the jury. (Local Rule 3.25, subd. (g)(4).)
Document Type
Joint Statement Of Case
In jury trials, parties must jointly prepare and file a proposed general or special verdict form acceptable to all parties.
For jury trials, the parties' counsel and any self-represented parties shall work together to prepare and file a joint proposed general verdict form or a joint proposed special verdict form acceptable to all parties. (Local Rule 3.25, subd. (g)(8).)
Document Type
Verdict Form
In jury trials, parties must jointly prepare and file a joint list of proposed jury instructions stating, for each instruction, the number, title, requesting party, agreed/contested status, any objection, and whether it was given.
For jury trials, the parties' counsel and any self-represented parties shall work together to prepare and file a joint list of proposed jury instructions (in the format set forth below) which states, as to each proposed jury instruction: (I) the jury instruction number (listed in numerical order), (2) the title of the jury instruction, (3) the party/parties requesting the jury instruction, (4) whether the jury instruction is agreed upon or contested, (5) a concise statement of any objection, and (6) whether the jury instruction was given by the court ("Joint List of Proposed Jury Instructions").
Document Type
Joint List Of Proposed Jury Instructions
If the parties cannot agree on a joint verdict form, each party must separately file its own proposed verdict form.
efforts the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form
Document Type
Proposed Verdict Form
Each party's counter-designations in the joint chart must include six columns: witness number/name, date and type of testimony, page and line counter-designations, objections, the related designation number, and the court's ruling.
In the joint chart, each counter-designating party's counter-designations of additional deposition or former testimony of the witness that relates to the designations shall include colunms which state: (!) the designation number and name of the witness, (2) the date and type of testimony (e.g., deposition or trial testimony), (3) the page and line counter-designations of the deposition or former testimony requested to be used, (4) any objections, (5) the designation number of the other party's designation to which the counter-designation relates, and (6) the court's ruling.
Document Type
Joint Chart Page Line Designations
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.
If any parties intend to use deposition testimony or former trial testimony in lieu of or in addition to a witness's live testimony, the parties' counsel and any self-represented parties shall meet and confer to discuss, and work together to prepare and file, a joint chart in the format set forth below ("Joint Chart of Page and Line Designations for Deposition and Former Testimony").
Document Type
Joint Chart Page Line Designations
Each party's designations in the joint chart must include six columns: witness number/name, date and type of testimony, page and line designations, objections, related counter-designations (if any), and the court's ruling.
In the joint chart, each designating party's designations of deposition or former testimony shall include columns which state: (I) the designation number and name of the witness, (2) the date and type of testimony (e.g., deposition or trial testimony), (3) the page and line designations of the deposition or former testimony requested to be used, (4) any objections, (5) whether the other party has counter-designated any additional deposition or former testimony of the witness that relates to the designation, and, if so, the designation number of the counter-designation, and (6) the court's ruling.
Document Type
Joint Chart Page Line Designations
Motions in limine captions must identify evidence to exclude, be numbered consecutively; opposition/reply must include motion number; uncontested motions note 'uncontested'.
The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to exclude. Parties filing more than one motion in limine shall number them consecutively. Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers. Uncontested motions should note "uncontested" in the caption.
Document Type
Motion In Limine
The court's yellow evidence tags, filled in with only the case number and exhibit number, must be placed on each exhibit in the Judicial Assistant's copy of the Exhibit Binder.
The parties' counsel and any self-represented parties shall also place the court's yellow evidence tags (with only the case number and exhibit number filled in) on each exhibit in the Judicial Assistant's copy of the Exhibit Binder.
Document Type
Exhibit
All non-documentary exhibits must be marked and a simple written description inserted behind the corresponding numerical tab in the Exhibit Binders.
The parties' counsel and any self-represented parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the Exhibit Binders, and shall comply with Paragraph 5, infra.
Document Type
Exhibit
Motion in limine captions must identify the evidence to be excluded, motions must be numbered consecutively, and opposition/reply papers must identify the corresponding motion number in the caption.
The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to exclude. Parties filing more than one motion in limine shall number them consecutively. Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.
Document Type
Motion In Limine
The proffering party is responsible for ensuring a method of promptly displaying electronic media trial exhibits in the jury room during deliberations upon the jury's request.
It is the proffering patty's responsibility to ensure a method of promptly displaying any electronic media trial exhibit in the jury room during deliberations upon request of the jury.
Document Type
Electronic Media Exhibit
Flash drives or CD/DVDs containing unmarked photographs must be accurately described on the Exhibit List.
If the flash drive or CD/DVD contains photographs that are not individually marked as an exhibit, it must be described accurately on the Exhibit List, for example Plaintiff's Exhibit 2 (flash drive or CD/DVD containing 3 photographs).
Document Type
Exhibit List
Recordings must be described as to whether they contain an audio file, and a transcript of the audio must be filed with the CD/DVD when the exhibit is offered.
If the flash drive or CD/DVD contains a recording, the description on the Exhibit List must state whether it contains an audio file, and the submitting party must confirm that a transcript of the audio has been filed with the CD/DVD at the time the exhibit is offered to the court. [CRC, Rule 2.1040]
Document Type
Electronic Media Exhibit
Flash drives or CD/DVDs offered into evidence must be listed on the Exhibit List, have a placeholder in the Exhibit Book, be marked as an exhibit, and contain an exhibit tag.
If a flash drive or CD/DVD is offered into evidence, it must be listed on the Exhibit List, with a placeholder in the Exhibit Book identifying the exhibit and exhibit number, and the flash drive or CD/DVD must be marked as an exhibit. Every exhibit that is marked must contain an exhibit tag.
Document Type
Electronic Media Exhibit
Photos on electronic media that bear separate exhibit numbers must each be printed out and have an exhibit tag affixed.
If the flash drive or CD/DVD is marked as an exhibit and any of the photos contained or presented within the electronic media are also marked with a separate exhibit number, then each of the marked photos must be printed out and have an exhibit tag affixed to each item.
Document Type
Electronic Media Exhibit
CD/DVDs in an envelope, sleeve, or case must be described on the Exhibit List including the container (e.g., Plaintiff's 1 - DVD in a white sleeve containing 5 photographs of the defendant).
If a CD/DVD is in an envelope, sleeve, or case, the description on the Exhibit List must state the following, Plaintiff's 1 - DVD in a white sleeve containing 5 photographs of the defendant.
Document Type
Exhibit List
Objections to PowerPoint slides must be submitted to the court as soon as possible and before the jury is empaneled.
If there are any objections to any slide, the objecting party must submit the objections to the court as soon as possible and before the jury is empaneled.
Document Type
Objections To Visual Aids
Because the court may rule on ex parte papers without oral argument, all necessary information and evidence must be included in the ex parte application itself.
The Court may rule on the ex parte papers without any oral argument if a hearing is deemed unnecessary. With that in mind, please include all necessary information and evidence in the ex parte application; waiting to present evidence at oral argument may result in denial of the application if a hearing is deemed unnecessary.
Document Type
Ex Parte Application
Parties must comply with Paragraph 5 of these requirements regarding electronic media as exhibits.
The parties are required to comply with Paragraph 5, irifra, regarding Electronic Media as Exhibits.
Document Type
Electronic Media Exhibits
Parties should request the applicable CACI instruction instead of a specially prepared instruction, and specially prepared instructions should be used sparingly without repetition of CACI or argument.
If there is an appropriate CACI jury instruction on a point of law, the court expects the parties to request the CACI instruction instead of a specially prepared jury instruction. Specially prepared jury instructions should be used sparingly and should not be repetitive of CACI instructions or argumentative in nature.
Document Type
Jury Instructions
For special verdict forms, the court expects parties to use or incorporate the applicable CACI special verdict form when one exists.
When a special verdict form is requested, if there is an appropriate CACI special verdict form for a cause of action, affirmative defense, or other finding, the court expects the parties to use (or incorporate) the CACI special verdict form.
Document Type
Special Verdict Form
Uncontested motions in limine should be marked "uncontested" in the caption and parties are encouraged to stipulate to them.
The parties/counsel are strongly encouraged to stipulate to uncontested motions. Uncontested motions should note "uncontested" in the caption.
Document Type
Motion In Limine
Generic or merely declaratory motions in limine are strongly disfavored and motions in limine may not be used to seek summary judgment, summary adjudication of issues, or judgment on the pleadings.
Motions in limine that are generic, do not identify the specific evidence sought to be excluded (e.g. exhibits, testimony and/or witnesses), seek rulings which would merely be declaratory of existing law or would not provide any meaningful guidance for the parties or witnesses are strongly disfavored. (See, Kelly v. New West Federal Savings (1996) 49 Cal.App.4th 659.) Motions in limine should not be used to seek summary judgment, summary adjudication of issues, or judgment on the pleadings.
Document Type
Motion In Limine
Filing & Service rules
Electronic Filing Rules
Self-represented litigants are exempt from mandatory electronic filing and should file their papers at the filing window (CRC 2.253(b)(2)).
Pursuant to California Rules of Court, Rule 2.253(b)(2), self-represented litigants are exempt from mandatory Electronic filing requirements and papers should be filed at the filing window.
Page 2 | FILINGS
Represented litigants must electronically file documents with the Court through an approved Electronic Filing Service Provider (CRC 2.253(b)).
Pursuant to California Rules of Court, Rule 2.253(b), represented litigants are required to electronically file documents with the Court through an approved Electronic Filing Service Provider.
Page 2 | FILINGS
All documents filed in Limited and Unlimited Non-Complex Civil matters by attorney-represented litigants must be electronically filed pursuant to the General Order re Mandatory Electronic Filing for Civil.
The Los Angeles County Superior Court has implemented electronic filing of all documents filed in the Limited and Unlimited Non-Complex Civil matters by litigants represented by attorneys pursuant to the operative General Order re Mandatory Electronic Filing for Civil.
Page 2 | FILINGS
Represented litigants must e-file all civil documents in Limited and Unlimited Non-Complex Civil matters via approved EFSP; self-represented litigants are exempt and must file at the filing window.
The Los Angeles County Superior Court has implemented electronic filing of all documents filed in the Limited and Unlimited Non-Complex Civil matters by litigants represented by attorneys pursuant to the operative General Order re Mandatory Electronic Filing for Civil. Pursuant to California Rules of Court, Rule 2.253(b), represented litigants are required to electronically file documents with the Court through an approved Electronic Filing Service Provider. Pursuant to California Rules of Court, Rule 2.253(b)(2), self-represented litigants are exempt from mandatory Electronic filing requirements and papers should be filed at the filing window.
Page 2 | FILINGS
All motions to be heard in Department E must be reserved through the Court Reservation System online portal.
Scheduling: All motions to be heard in Department E are to be reserved through the Court Reservation System at https://portal-lasc.iournaltech.com/public-portal/
Page 3 | LAW & MOTION
Under the General Order re Filing for Civil, electronic filing is mandatory in civil cases except for self-represented litigants, persons excused from e-filing, and ex parte applications under CRC Rule 3.1203.
Filing for Civil, filed May 3, 2019, provides that, with the exception of self-represented litigants and other persons excused from filing documents electronically, and with the exception of ex parte applications falling under CRC Rule 3.1203:
Page 5 | FILINGS
Documents produced under the discovery order may, at the producing party's option, be provided to the opposing party electronically as a PDF.
The information required by this Order may be provided to the opposing party in electronic form as a PDF at the option of the producing party.
Page 18 | Discovery
Filing Timing and Cure Windows
Written oppositions to ex parte applications must be e-filed by 8:30 a.m. the day of the ex parte hearing.
Any written opposition to an ex parte application must be electronically filed by 8:30 a.m. the day of the ex parte hearing ...
Page 5 | FILINGS
Ex parte applications and supporting documents must be e-filed by 10:00 a.m. the day before the ex parte hearing, with exceptions for self-represented litigants and CRC Rule 3.1203 applications.
Ex parte applications and all documents in support thereof must be electronically filed no later than 10:00 a.m. the day before the ex parte hearing.
Page 5 | FILINGS
Ex parte applications and all supporting documents must be e-filed no later than 10:00 a.m. the day before the ex parte hearing.
Ex parte applications and all documents in support thereof must be electronically filed no later than 10:00 a.m. the day before the ex parte hearing.
Page 5 | FILINGS
Written opposition to an ex parte application must be e-filed by 8:30 a.m. on the day of the ex parte hearing.
Any written opposition to an ex parte application must be electronically filed by 8:30 a.m. the day of the ex parte hearing ...
Page 5 | FILINGS
Parties must meet and confer no later than 11 calendar days before the Final Status Conference to prepare required trial documents and binders, attempt stipulations on exhibits, motions in limine, and ultimate facts/legal issues, and attempt settlement.
No later than 11 calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall meet and confer to do the following: (I) discuss and prepare the documents required in Sections 2.B-H, below, and the Motions in Limine Binder, Exhibit Binders, and Trial Binder required in Sections 3-5, below, (2) discuss and make a good faith effort to stipulate to the authenticity and admissibility of each trial exhibit, (3) discuss and make a good faith effort to stipulate to resolve each motion in limine, (4) discuss and make a good faith effort to stipulate to ultimate facts and legal issues, and (5) discuss and make a good faith effort to settle the case.
Page 8 | DEPT. E TRIAL PREPARATION REQUIREMENTS - MEET AND CONFER
Required trial documents must be filed and served no later than five calendar days before the Final Status Conference.
No later than five calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall file and serve the following documents:
Page 8 | DEPT. E TRIAL PREPARATION REQUIREMENTS - TRIAL DOCUMENTS TO BE FILED
All trial exhibits must be exchanged no later than 18 calendar days before the Final Status Conference.
No later than 18 calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall exchange all exhibits they intend to introduce at trial.
Page 8 | DEPT. E TRIAL PREPARATION REQUIREMENTS - MEET AND CONFER
The parties must meet and confer to ensure all transcripts identified on the joint chart are lodged with the court before trial begins.
The parties shall meet and confer to ensure that transcripts of each deposition identified on the Joint Chart of Page and Line Designations for Deposition and Former Testimony is lodged with the court prior to the commencement of trial.
Page 11 | H. JOINT CHART OF PAGE AND LINE DESIGNATIONS FOR DEPOSITION AND FORMER TESTIMONY
Motions in limine must be filed with statutory notice under CCP section 1005 and LA County Court Rule 3.57(a) for hearing at the Final Status Conference.
Motions in limine shall be filed with statutory notice for hearing at the Final Status Conference. The parties' counsel and any self-represented parties shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and the requirements of Los Angeles County Court Rule 3.57, subdivision (a).
Page 12 | 3. MOTIONS IN LIMINE
In Song-Beverly cases, both parties must produce the specified categories of documents to the opposing side within 30 days of the case becoming 'at issue' (the date the Court sets an initial trial date).
Within 30 days of the case becoming "at issue" Plaintiff(s) and Defendant(s) shall provide copies of the following documents, which are in their respective possession, custody and/or control, to the opposing side(s):
Page 17 | Discovery
Motions in limine must be filed and served with proper statutory notice in order to be heard at the Final Status Conference.
Motions in Limine are heard at the Final Status Conference and should be filed and served so that proper statutory notice is given for the Motions in Limine to be heard at the Final Status Conference.
Page 3 | TRIALS
Service and Proof of Service Rules
Ex parte applications require proof of notice, affirmative factual showing of good cause, and cannot be based on emergency from procrastination.
Before bringing an ex parte application, all parties should review California Rules of Court 3.1200 - 3.1207 and Los Angeles County Superior court Rule 3.26. Please pay particular attention to the notice requirements and the requirement of an affirmative factual showing of good cause. Among the most common grounds for denial of an ex parte application is the failure to provide proof of the required notice and/or failure to prove why the application could not be brought as a noticed motion. An "emergency" caused by procrastination or other unexcused delay on the part of the applicant is not grounds for ex parte relief.
Page 4 | EX-PARTE APPLICATIONS
Ex parte applications must include proof of the required notice and an affirmative factual showing of good cause; lack of notice proof or a procrastination-based emergency are common grounds for denial.
Please pay particular attention to the notice requirements and the requirement of an affirmative factual showing of good cause. Among the most common grounds for denial of an ex parte application is the failure to provide proof of the required notice and/or failure to prove why the application could not be brought as a noticed motion. An "emergency" caused by procrastination or other unexcused delay on the part of the applicant is not grounds for ex parte relief.
Page 4 | EX-PARTE APPLICATIONS
Each party must provide a set of properly marked exhibits to each opposing party before trial begins.
A set of properly marked exhibits must also be provided to each opposing party prior to the start of trial.
Page 13 | 4. EXHIBIT BINDERS
Visual aids may not be used in opening statement unless opposing counsel has had the opportunity to review them before trial, and PowerPoint slides must be shared with opposing counsel before presentation with the Court informed at the FSC.
No visual aids shall be used in opening statement without opposing counsel first having been given the opportunity to review the visual aids prior to trial. (LASCR 3.97.) If counsel intends to use PowerPoint, the Court shall be informed at the FSC and a copy of the slides must be shared with opposing counsel prior to the presentation.
Page 15 | 7. VISUAL AIDS DURING OPENING STATEMENT
In Song-Beverly litigation, parties must exchange specified vehicle-related documents within 30 days of case becoming at issue.
Within 30 days of the case becoming "at issue" Plaintiff(s) and Defendant(s) shall provide copies of the following documents, which are in their respective possession, custody and/or control, to the opposing side(s): a. Purchase or lease contracts concerning the subject vehicle... b. Work orders, repair orders, and invoices... c. Rental car or loaner agreements... d. Records of communications... e. Warranty claims... f. Procedures published by Defendant(s)... g. Defendant's written statements of policy... h. A list or compilation of customer complaints... i. Technical Service Bulletins and Recall Notices... j. Copies of any repair instruction... k. Any documents supporting Plaintiff's claim for incidental and/or consequential damages.
Page 17 | Additional Case Management Conference Order (Song-Beverly Litigation)
Each party must serve verifications together with the documents it produces under the discovery order.
Plaintiff and Defendant shall serve verifications with the documents each produces.
Page 18 | Discovery
Filing Fees and Waivers
Continuance stipulations and orders must include payment of the stipulation and order and first appearance fee for all parties.
A stipulation and order shall state the date the complaint was filed, the proposed continuance date(s), grounds showing good cause for the continuance, and be submitted with payment of the stipulation and order and first appearance fee of all parties to the stipulation.
Page 3 | CONTINUANCES
A continuance stipulation and order must be submitted with payment of the stipulation and order fee and the first appearance fee of all parties to the stipulation.
A stipulation and order shall state the date the complaint was filed, the proposed continuance date(s), grounds showing good cause for the continuance, and be submitted with payment of the stipulation and order and first appearance fee of all parties to the stipulation.
Page 3 | CONTINUANCES
Courtesy Copy Requirements
Courtesy copies of e-filed documents must be delivered directly to the courtroom pursuant to the General Order re Mandatory Electronic Filing.
Please deliver courtesy copies directly to the courtroom pursuant to the General Order re Mandatory Electronic Filing.
Page 2 | FILINGS
A courtesy copy of the IDC joint statement of discovery in dispute must be delivered to Department E three court days before the IDC.
If the Court orders an IDC a joint statement of discovery in dispute (no more than five pages) shall be filed and a courtesy copy delivered to Department E three (3) court days before the IDC.
Page 4 | LAW & MOTION
Each party must bring one volume (not a full set) of its Exhibit Binders to the Final Status Conference for court review.
The parties' counsel and any self-represented parties shall each bring one volume (not a full set) of the Exhibit Binders containing their exhibits to the Final Status Conference for the court to review.
Page 14 | 4. EXHIBIT BINDERS
All three sets of exhibit binders must be lodged on the first day of trial.
The parties shall lodge the entire three sets of exhibit binders on the first day of trial.
Page 14 | 4. EXHIBIT BINDERS
A copy of any PowerPoint slides used in opening statement must be lodged with the court.
A copy of the slides must be lodged with the court.
Page 15 | 7. VISUAL AIDS DURING OPENING STATEMENT
If no court reporter is used at trial, the parties must jointly prepare a summary of each day's proceedings and lodge it in the courtroom the next morning before proceedings resume.
If no court reporter is used, the parties must jointly prepare a summary of the day's proceedings, and lodge it in the courtroom the next morning before proceedings resume.
Page 16 | 10. COURT REPORTERS AND SETTLED STATEMENTS
Sealing & Redaction Procedures
A party seeking a protective order for court-ordered discovery information must first meet and confer on agreeable language, and absent a stipulation must file a motion for a protective order.
If a party believes any of this information should be subject to a protective order, that party shall first meet and confer as to agreeable language for the order. Absent a stipulation, the requesting party shall file a motion for a protective order.
Page 18 | Discovery
Filing Bundling Requirements
Parties must jointly prepare and lodge in Department A a Motions in Limine Binder no later than three calendar days before the Final Status Conference.
No later than three calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department A a Motions in Limine Binder which is no larger than 3".
Page 13 | DEPT. E TRIAL PREPARATION REQUIREMENTS
Parties must jointly prepare three sets of tabbed, internally paginated, properly marked exhibits in three-ring binders no larger than 3 inches each: a set for the court, the Judicial Assistant, and the witnesses.
The parties' counsel and any self-represented parties shall work together to jointly prepare three sets of tabbed, internally paginated by document, and properly marked exhibits, organized numerically in three-ring binders (not to exceed 3" per binder) (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) ("Exhibit Binders").
Page 13 | 4. EXHIBIT BINDERS
Motions in limine, opposition, and reply papers must be bound in 3" three-ring binders, tabbed, indexed, lodged 3 calendar days before FSC; no proposed orders.
No later than three calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department A a Motions in Limine Binder which is no larger than 3". The Motions in Limine Binder shall include two-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders not to exceed 3" per binder, indexed and tabbed in numerical order with the opposition papers and reply papers for each motion placed directly behind the moving papers with a colored sheet of paper separating the moving, opposition, and reply papers. Proposed orders should not be included in the Motions in Limine Binder.
Page 13 | MOTIONS IN LIMINE
Three sets of tabbed, numerically organized exhibit binders not exceeding 3" per binder required for court, judicial assistant, witnesses; sets to opposing parties before trial.
The parties' counsel and any self-represented parties shall work together to jointly prepare three sets of tabbed, internally paginated by document, and properly marked exhibits, organized numerically in three-ring binders (not to exceed 3" per binder) (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) ("Exhibit Binders"). A set of properly marked exhibits must also be provided to each opposing party prior to the start of trial.
Page 14 | EXHIBIT BINDERS
Trial Binder with specified tabs, one-sided conformed copies in three-ring binder required, lodged 3 calendar days before FSC.
No later than three calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department A a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following (for trials by the court without a jury, the Trial Binder shall only include the documents listed under Tabs A, B, C, H, and I): Tab A: Trial Briefs; Tab B: Joint Witness List; Tab C: Joint Exhibit List; Tab D: Joint Statement to Be Read to the Jury; Tab E: Joint List of Jury Instructions; Tab F: Joint and Contested Jury Instructions; Tab G: Joint or Contested Verdict Form(s); Tab H: Joint Chart of Page/Line Designations for Deposition/Former Testimony; Tab I: Copies of the Current Operative Pleadings.
Page 14 | TRIAL BINDER
Parties must jointly prepare and lodge a tabbed Trial Binder in Department A no later than three calendar days before the Final Status Conference containing trial briefs, witness and exhibit lists, jury statement, jury instructions, and verdict forms (bench trials require only Tabs A, B, C, H, and I).
No later than three calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department A a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following (for trials by the court without a jury, the Trial Binder shall only include the documents listed under Tabs A, B, C, H, and I): Tab A: Trial Briefs; Tab B: Joint Witness List; Tab C: Joint Exhibit List; Tab D: Joint Statement to Be Read to the Jury; Tab E: Joint List of Jury Instructions; Tab F: Joint and Contested Jury Instructions; Tab G: Joint or Contested Verdict Form(s)
Page 14 | 6. TRIAL BINDER
Pre-Motion Conference Requirements
Meet and confer efforts for motions in limine must consist of more than one email advising the opposing party of the nature of the motion.
Meet and confer efforts shall consist of more than one email advising the opposing party(ies) of the nature of the motion.
Page 12 | 3. MOTIONS IN LIMINE
An informal discovery conference is encouraged but not required before filing a discovery motion.
The Court strongly encourages the parties to request an IDC if there is a discovery dispute, but there is no requirement to hold an IDC prior to filing a discovery motion.
Page 4 | LAW & MOTION
Parties are encouraged to stipulate to waive replies to motions in limine.
The parties are encouraged to stipulate to waive the filing of replies to motions in limine.
Page 13 | MOTIONS IN LIMINE
Adjournment & Extension Requirements
Without a stipulation, continuances may be sought by noticed motion or ex parte application, and the court will not continue hearing/trial dates over opposition without a good-cause showing by the requesting party.
If there is no stipulation, the parties may seek a continuance by noticed motion or an ex parte application. PLEASE NOTE, IF THERE IS AN OPPOSITION TO A REQUEST FOR CONTINUANCE, THE COURT WILL NOT CONTINUE HEARING/TRIAL DATES WITHOUT A SHOWING OF GOOD CAUSE BY THE REQUESTING PARTY.
Page 3 | CONTINUANCES
Continuances of hearings or trials require a written stipulation and order stating the complaint filing date, proposed continuance date(s), and good-cause grounds.
Requests for continuances of hearings or trials will be considered upon written stipulation ahd order. A stipulation and order shall state the date the complaint was filed, the proposed continuance date(s), grounds showing good cause for the continuance, and be submitted with payment of the stipulation and order and first appearance fee of all parties to the stipulation.
Page 3 | CONTINUANCES
Continuance requests require written stipulation stating complaint date, proposed dates, good cause, and payment of fees; opposed requests need good cause showing.
CONTINUANCES: Requests for continuances of hearings or trials will be considered upon written stipulation ahd order. A stipulation and order shall state the date the complaint was filed, the proposed continuance date(s), grounds showing good cause for the continuance, and be submitted with payment of the stipulation and order and first appearance fee of all parties to the stipulation. If there is no stipulation, the parties may seek a continuance by noticed motion or an ex parte application. PLEASE NOTE, IF THERE IS AN OPPOSITION TO A REQUEST FOR CONTINUANCE, THE COURT WILL NOT CONTINUE HEARING/TRIAL DATES WITHOUT A SHOWING OF GOOD CAUSE BY THE REQUESTING PARTY.
Page 3 | CONTINUANCES
Continuances will not be granted because a witness fails to appear in a timely manner; trial proceeds without them.
Continuances will not be granted due to witnesses who do not appear in a timely manner.
Page 15 | 8. WITNESSES
Litigants should minimize shortening-time requests, and failure to timely schedule motion practice will not be treated as a basis for ex parte relief.
Please make every effort to conduct litigation so as to minimize the need for requesting that the Court shorten time to hear a motion. The Court does not consider counsel's or a litigant's failure to timely schedule motion practice an affirmative factual showing of irreparable harm, immediate danger or any other statutory basis for granting relief ex-parte. (CRC § 3.1202(c).)
Page 3 | LAW & MOTION
A party applying ex parte to advance a summary judgment or summary adjudication hearing due to unavailable reservation dates should also include an alternative request to continue the trial until after the hearing.
Because it is usually difficult for the court to advance the hearing on a motion for summary judgment or summary adjudication, if a party files an ex parte application to advance the hearing on such a motion because no hearing dates are available on the Court Reservation System before the trial date, the moving party should also consider including an alternative request that the court continue the trial to a date after the hearing on the motion.
Page 3 | LAW & MOTION
Chambers Communication Rules
For remote appearance sign-in difficulties, call the technical help desk at (213) 830-0400 if on hold more than 10 minutes; if the help desk is unreachable, call the department.
DIFFICULTIES WITH SIGNING IN FOR REMOTE APPEARANCES: If you have difficulty signing in, please completely disconnect and try again. If you are on hold for more than 10 minutes and cannot hear anything, please call the help desk at (213) 830-0400. If you are unable to reach the help desk, please call the department.
Page 2 | DEPARTMENT E RULES