Judge Sherry Powell
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
Communication
Phone
Chambers
Phone
Clerk
Chambers
Phone
Page & Word Limits3 rules
Moving party must file and serve an IDC memorandum no longer than 3 pages at least 5 court days before the IDC.
At least five court days before the IDC, the moving party must file and serve a memorandum no longer than three pages setting forth the outstanding issues.
Memorandum
3 pages
Applies to: Attorney
Responding party may file a responsive IDC memorandum no longer than 3 pages at least 2 court days before the IDC.
The responding party may file and serve a responsive memorandum of no more than three pages at least two court days prior to the IDC.
Responsive Memorandum
3 pages
Applies to: Attorney
IDC memoranda are limited to three pages for both the moving party's memorandum and the responding party's responsive memorandum.
At least five court days before the IDC, the moving party must file and serve a memorandum no longer than three pages setting forth the outstanding issues. The first paragraph shall be formatted as follows: (1) a neutral statement of the dispute; and (2) one to three sentences describing (not arguing) each party's position. The responding party may file and serve a responsive memorandum of no more than three pages at least two court days prior to the IDC.
Idc Moving Party Memorandum
3 pages
Idc Responsive Memorandum
3 pages
Document Format Requirements3 rules
Proposed special jury instructions must have at least 4 inches of blank space at the top of every page.
Leave at least four inches of blank space at the top of every page of any proposed special jury instructions, or any addenda to form instructions.
Each exhibit must be separately numbered to match the joint exhibit list, and multi-page exhibits must have internally numbered pages (e.g., 3.1, 3.2, 3.3).
Each exhibit must be separately numbered, with the numbers corresponding to the number of the exhibit on the joint exhibit list. If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3 etc.
At least four inches of blank space must be left at the top of every page of proposed special jury instructions and addenda to form instructions.
Leave at least four inches of blank space at the top of every page of any proposed special jury instructions, or any addenda to form instructions.
Document Filing Requirements17 rules
IDC requests must be filed online using form LACIV094 and list all disputed discovery issues.
If the dispute remains unresolved, counsel may request an Informal Discovery Conference (IDC) by filing an IDC request online [LACIV094] list all discovery issues that are in dispute.
Document Type
Idc Request
IDC moving memorandum first paragraph must include neutral dispute statement and 1-3 sentences per party’s position.
The first paragraph shall be formatted as follows: (1) a neutral statement of the dispute; and (2) one to three sentences describing (not arguing) each party’s position.
Document Type
Memorandum
Ex parte applications must make an affirmative showing of irreparable harm, immediate danger, or another statutory basis for relief, and must demonstrate why the relief cannot be sought by other means such as a noticed motion or continuance of the trial.
PLEASE CAREFULLY REVIEW WHETHER YOU HAVE A PROPER BASIS TO SEEK EX PARTE RELIEF. There must be an affirmative showing of "irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte." (See Cal. Rules of Court, rule 3.1202 (c).) You will need to demonstrate to the court the reason(s) why you cannot seek the requested relief by other means, such as a noticed motion or continuance of the trial.
Document Type
Ex Parte Application
Ex parte applications must include an affirmative showing of irreparable harm, immediate danger, or other statutory basis for ex parte relief.
There must be an affirmative showing of "irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte." (See Cal. Rules of Court, rule 3.1202 (c).)
Document Type
Ex Parte Application
When no court reporter is retained 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
Summary Of Daily Proceedings
Motions in limine must be accompanied by a sworn declaration attesting the opposing party’s position.
In compliance with LASC Rule 3.57, all motions in limine must be accompanied by a sworn declaration attesting setting forth the opposing party’s position regarding the motions, and must be submitted with timely statutory notice so the motions in limine can be heard at the FSC.
Document Type
Motion In Limine
All motions in limine must be accompanied by a sworn declaration (per LASC Rule 3.57); the source text is truncated mid-sentence.
In compliance with LASC Rule 3.57, all motions in limine must be accompanied by a sworn declaration attesting
Document Type
Motion In Limine
Parties must provide a paper trial notebook to the Court in connection with the FSC/trial.
The parties must provide both a paper "trial notebook" for the Court and submit FSC/trial documents electronically.
Document Type
Trial Notebook
Parties must submit a joint witness list with per-witness and total testimony time estimates and discuss at the FSC which witnesses will appear in person or by video.
The parties must submit a joint list of all witnesses each party actually intends to call. Next to each witness, indicate the total time estimated for that witness’s testimony (including direct, cross, and redirect). Make realistic time estimates. At the end of the list, total the time estimated for testimony. Absent good cause, the total number of hours listed for testimony shall not exceed the trial estimate given at the case management conference, including the allocation of one day of the trial estimate for jury selection and sufficient time for opening statements and closing arguments. The parties shall discuss with the Court at the final status conference which witnesses will appear in person, and which will appear by video.
Document Type
Joint Witness List
Motions in limine must set forth the opposing party's position and be submitted with timely statutory notice so they can be heard at the FSC.
setting forth the opposing party’s position regarding the motions, and must be submitted with timely statutory notice so the motions in limine can be heard at the FSC. Motions in limine may be heard at the FSC unless the Court orders otherwise.
Document Type
Motion In Limine
Proposed jury instructions must include a joint set plus each side's disputed sets, provide full text, be completed and modified before submission, comply with LASC 3.170 to 3.171, and use CACI for form instructions.
The parties are to submit a joint set of instructions, plus a set of instructions from each side to which there are objections. The parties shall provide the full text of all requested instructions (not just a list). Before submitting the instructions, counsel must fill in the blanks, make appropriate modifications, and comply with LASC 3.170 to 3.171. Use CACI for form instructions.
Document Type
Proposed Jury Instructions
Parties must meet and confer in advance and then file proposed general or special verdict forms, using CACI model forms where applicable; competing proposed verdict forms are discouraged.
The parties are to meet and confer in advance and then file proposed general or special verdict forms. Use CACI model verdict forms where applicable. The Court discourages submission of competing proposed verdict forms.
Document Type
Proposed Verdict Forms
No later than the FSC, counsel must present to the Court and opposing counsel a CCP § 2034.260 declaration stating the substance of the proffered expert opinion for each trial expert.
As to experts that counsel intends to call at trial, no later than the FSC, Counsel shall present to the Court and opposing counsel a copy of the Code of Civil Procedure section 2034.260 declaration that states the substance of the proffered opinion.
Document Type
Ccp 2034 260 Expert Declaration
The first paragraph of the IDC memorandum must contain a neutral statement of the dispute followed by one to three sentences describing (not arguing) each party's position.
The first paragraph shall be formatted as follows: (1) a neutral statement of the dispute; and (2) one to three sentences describing (not arguing) each party's position.
Document Type
Idc Memorandum
Total testimony hours on the joint witness list may not exceed the trial estimate given at the CMC (including one day for jury selection and time for opening and closing) absent good cause.
Absent good cause, the total number of hours listed for testimony shall not exceed the trial estimate given at the case management conference, including the allocation of one day of the trial estimate for jury selection and sufficient time for opening statements and closing arguments.
Document Type
Joint Witness List
Parties must provide a joint statement of the case, which the Court reads to prospective jurors, and be prepared to discuss agreement to mini-opening statements.
JOINT STATEMENT OF THE CASE (which will be read by the Court to the prospective jurors). Counsel should be prepared to discuss whether they are agreeable to mini-opening statements to be given by counsel to the prospective jurors.
Document Type
Joint Statement Of Case
Trial briefs are highly recommended for each party in all cases, whether bench or jury trial.
TRIAL BRIEFS for each party are highly recommended in all cases, whether bench or jury trial.
Document Type
Trial Brief
Filing & Service rules
Electronic Filing Rules
Ex parte applications and supporting documents must be e-filed no later than 10:00 a.m. on the court day before the hearing, with self-represented litigants exempt from these mandatory e-filing requirements under CRC 2.253(b)(2).
All ex parte applications and documents in support thereof must be electronically filed no later than 10:00 a.m. on the court day before the hearing. Any written opposition shall be electronically filed by 8:30 am on the day of the hearing. Pursuant to California Rules of Court, rule 2.253(b)(2), self-represented litigants are exempt from these mandatory Electronic Filing requirements.
Page 4 | Ex Parte Applications
Ex parte applications and supporting documents must be electronically filed by 10:00 a.m. on the court day before the hearing.
All ex parte applications and documents in support thereof must be electronically filed no later than 10:00 a.m. on the court day before the hearing.
Page 4 | Ex Parte Applications
Plaintiff must e-file Notice of Settlement using Judicial Council Form CM-200.
Notice of Settlement must be eFiled by the plaintiff using Judicial Council Form CM-200, even if the case is settled at a Judicial mandatory settlement conference.
Page 5 | NOTICE OF SETTLEMENT / REQUEST FOR DISMISSAL
Plaintiffs must eFile the Notice of Settlement using Judicial Council Form CM-200, even when the case settles at a Judicial mandatory settlement conference.
Notice of Settlement must be eFiled by the plaintiff using Judicial Council Form CM-200, even if the case is settled at a Judicial mandatory settlement conference.
Page 5 | Notice of Settlement / Request for Dismissal
FSC and trial documents must be submitted electronically; a paper trial notebook must also be provided to the Court.
The parties must provide both a paper “trial notebook” for the Court and submit FSC/trial documents electronically.
Page 6 | TRIAL PROCEDURES
FSC and trial documents must be submitted electronically.
The parties must provide both a paper "trial notebook" for the Court and submit FSC/trial documents electronically.
Page 6 | Trial Procedures - Final Status Conference (FSC)
Parties shall work together to provide trial exhibits electronically when feasible.
The parties shall work together to provide exhibits electronically, if feasible.
Page 7 | Joint Exhibit List and Exhibits
Filing Timing and Cure Windows
Case Management Statements must be filed at least 7 calendar days before the scheduled CMC.
Case Management Statements must be filed at least seven (7) calendar days before the date scheduled for the case management conference (CMC).
Page 2 | CASE MANAGEMENT CONFERENCE (CMC)
Case Management Statements must be filed at least 7 calendar days before the scheduled case management conference.
Case Management Statements must be filed at least seven (7) calendar days before the date scheduled for the case management conference (CMC).
Page 2 | Case Management Conference (CMC)
Scheduling an IDC does not toll the deadline for filing a discovery motion unless the parties stipulate to toll deadlines.
California Code of Civil Procedure § 2016.080 has been repealed, therefore, the scheduling of an IDC does not toll the deadline for filing a discovery motion unless the parties stipulate to toll deadlines.
Page 4 | Informal Discovery Conferences
Written opposition to ex parte applications must be electronically filed by 8:30 a.m. on the day of the hearing.
Any written opposition shall be electronically filed by 8:30 am on the day of the hearing.
Page 4 | Ex Parte Applications
Ex parte applications must be filed by 10:00 a.m. on the court day prior to the hearing.
Absent an exemption, you must file the application by 10:00 am on the court day prior to the ex parte hearing.
Page 4 | Ex Parte Applications
The moving party must file and serve the IDC memorandum at least five court days before the IDC.
At least five court days before the IDC, the moving party must file and serve a memorandum no longer than three pages setting forth the outstanding issues.
Page 4 | Informal Discovery Conferences
Written opposition to an ex parte application must be electronically filed by 8:30 a.m. on the day of the hearing.
Any written opposition shall be electronically filed by 8:30 am on the day of the hearing.
Page 4 | Ex Parte Applications
Ex parte applications are heard daily at the end of the morning calendar and, absent an exemption, must be filed by 10:00 a.m. on the court day prior to the hearing in compliance with CRC 3.1200 et seq.
Ex parte applications are heard each day at the end of the morning calendar. Absent an exemption, you must file the application by 10:00 am on the court day prior to the ex parte hearing. Ex parte applications must comply with CRC 3.1200 et seq.
Page 4 | Ex Parte Applications
The responding party may file and serve a responsive IDC memorandum of no more than three pages at least two court days prior to the IDC.
The responding party may file and serve a responsive memorandum of no more than three pages at least two court days prior to the IDC.
Page 4 | Informal Discovery Conferences
Motions in limine and bifurcation motions must be filed and served with proper statutory notice and set for hearing on the FSC date.
MOTIONS IN LIMINE AND BIFURCATION MOTIONS must have been filed and served with proper statutory notice and set for hearing on the FSC date.
Page 6 | Trial Procedures - Final Status Conference (FSC)
Trial binders lodged before settlement must be picked up within two weeks of filing the Notice of Settlement or they will be discarded.
If trial binders were lodged prior to settlement, they must be picked up within two weeks of filing the Notice of Settlement or they will be discarded.
Page 5 | Notice of Settlement / Request for Dismissal
After the Notice of Settlement of the entire case is eFiled, all future appearances are taken off calendar and an OSC re: Dismissal is scheduled approximately 45 days from the filing date.
Once the Notice of Settlement of the entire case is eFiled, all future appearances will be taken off calendar and an OSC re: Dismissal will be scheduled approximately forty-five (45) days from the filing date.
Page 5 | Notice of Settlement / Request for Dismissal
Service and Proof of Service Rules
All parties who use e-filing must accept electronic service, except when personal service is required by law or where any party is self-represented.
Pursuant to Code of Civil Procedure §1010.6, local Rule 3.4, and General Order 2019-GEN-014-00 issued May 3, 2019, the Court orders all parties who use e-filing to accept electronic service, except in those circumstances when personal service is required by law or where any of the parties are self-represented.
Page 3 | General Information
All parties using e-filing must accept electronic service, except when personal service is required by law or any party is self-represented.
Pursuant to Code of Civil Procedure §1010.6, local Rule 3.4, and General Order 2019-GEN-014-00 issued May 3, 2019, the Court orders all parties who use e-filing to accept electronic service, except in those circumstances when personal service is required by law or where any of the parties are self-represented.
Page 3 | MOTION PRACTICE
Pre-Motion Conference Requirements
Before discovery motions, trial counsel must meet and confer in person, by telephone, or by videoconference to resolve or narrow the dispute; merely exchanging letters or emails is insufficient.
The Court strongly discourages discovery motions and encourages informal resolution of discovery disputes. Trial counsel must meet and confer in person, by telephone, or videoconference to resolve or narrow the discovery dispute. Merely exchanging letters or emails is insufficient.
Page 3 | Informal Discovery Conferences
Informal Discovery Conference (IDC) must be completed before filing a discovery motion, absent a showing of good cause.
Absent a showing of good cause, the Court may continue any discovery motion filed before the IDC process is concluded.
Page 4 | Informal Discovery Conferences
Counsel may request an Informal Discovery Conference (IDC) by filing an online IDC request (form LACIV094) listing all disputed discovery issues; if granted the clerk schedules the IDC, which should eliminate the need for a motion, and absent good cause the Court may continue any discovery motion filed before the IDC process concludes.
If the dispute remains unresolved, counsel may request an Informal Discovery Conference (IDC) by filing an IDC request online [LACIV094] list all discovery issues that are in dispute. The court will review the request and issue an order granting or denying the request. If granted, the clerk will schedule an IDC. The IDC should eliminate any need for a motion. Absent a showing of good cause, the Court may continue any discovery motion filed before the IDC process is concluded.
Page 3 | Informal Discovery Conferences
Adjournment & Extension Requirements
Parties must reserve law and motion hearing dates through the Court Reservation System (CRS) and must use CRS to continue or withdraw motions, informing the courtroom of the change.
Parties must reserve a date for all law and motion hearings via the Court Reservation System (CRS). Parties must use CRS to continue or withdraw motions and inform the courtroom of the change.
Page 3 | General Information
Chambers Communication Rules
Counsel may submit on the tentative by calling the courtroom or emailing the Judicial Assistant by 8:00 a.m. on the hearing day (email must include the case number, identify the submitting party, and cc opposing counsel); if all counsel submit the Court adopts the tentative, and if no notice is received and no one appears the motion may be placed off calendar.
Counsel who intend to submit on the tentative may call the courtroom or send an email to the Judicial Assistant by 8:00 a.m. the day of the hearing. The email must include the case number and identify the party submitting on the tentative with a copy (cc) to opposing counsel. IF ALL counsel submit, the Court will adopt the tentative as the final order. Otherwise, the court will call the matter, and since the ruling is only a Tentative Ruling, the court is free to change the ruling. If the Court does not receive a call/ email indicating all parties are submitting on the tentative and there are no appearances at the hearing, the motion may be placed off calendar.
Page 3 | General Information
Department D (chambers) may be reached by telephone at 562-345-3723 during hours of 8:30 am to 12:00 pm and 1:30 pm to 4:30 pm, Monday through Friday.
Telephone Number: 562-345-3723 Hours: Monday to Friday 8:30 am to 12:00 pm and 1:30 pm to 4:30 pm
Page 1 | General Information
Self-represented litigants seeking assistance from the Clerk's Office must call Court Support Services at 562-345-3700.
For assistance from the Clerk's Office, please call the Court Support Services number at 562-345-3700.
Page 1 | Self-represented Litigants
Counsel may email the Judicial Assistant by 8:00 a.m. on the hearing day to submit on a tentative ruling; email must include case number, submitting party, and cc opposing counsel.
Counsel who intend to submit on the tentative may call the courtroom or send an email to the Judicial Assistant by 8:00 a.m. the day of the hearing. The email must include the case number and identify the party submitting on the tentative with a copy (cc) to opposing counsel.
Page 3 | Tentative Rulings
Counsel may call the courtroom by 8:00 a.m. on the hearing day to submit on a tentative ruling.
Counsel who intend to submit on the tentative may call the courtroom or send an email to the Judicial Assistant by 8:00 a.m. the day of the hearing.
Page 3 | Tentative Rulings
To arrange a voluntary settlement conference before the trial judge, parties must contact the courtroom assistant and contact Mr. Abraham to obtain and execute a Stipulation.
The court is also willing to personally conduct voluntary settlement conferences. Please contact the courtroom assistant to arrange a conference. Contact Mr. Abraham to obtain and execute a Stipulation for settlement conferences conducted by the trial judge.
Page 6 | Settlement Conferences / Settlement Programs