Judge Teresa A. Beaudet
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Ex Parte Application
- Hand Delivery • Upon Filing
Filings > 15 pages
- Chambers Drop Off • Upon Filing
Motion, Opposition, Reply
- Upon Filing
All filings
Court-wide- Chambers Drop Off • Upon Filing
- Hand Delivery
Communication
Phone
Chambers
Phone
Court-wideClerk
Phone
Court-wideClerk
Phone
Court-widePhone
Court-wideClerk
Document Format Requirements8 rules
All declarations and exhibits attached to motions must be tabbed; motions may be rejected for failure to comply with tabbing rules.
PLEASE PROVIDE TABS FOR ALL DECLARATIONS AND EXHIBITS ATTACHED TO MOTIONS. IT IS VERY DIFFICULT TO FIND EVIDENCE WHEN IT IS NOT TABBED. YOUR MOTION COULD BE REJECTED FOR FAILURE TO COMPLY WITH THE RULES REGARDING TABBING.
Parties must jointly prepare three sets of tabbed, internally paginated, properly marked exhibits organized numerically in three-ring binders (one each for the witness, courtroom clerk, and Court).
For the trial, the parties must jointly prepare three sets of tabbed, internally paginated and properly marked exhibits (i.e., the exhibit numbers must correspond to those on the joint exhibit list), organized numerically in three-ring binders (i.e., one for the witness, one for the courtroom clerk, and one for the Court).
The IDC form must not include attachments, miniscule font, or more than the allotted space, and needs to state only the basic issue in contention.
Do not attach any documents, do not type in miniscule font and do not use more than the allotted space on the IDC form to describe the dispute. The Court does not need a lot of information on the IDC form – just the basic issue in contention.
The Trial Readiness Binder must be an indexed and tabbed three-ring binder, and the Exhibit Binders must be indexed and tabbed.
Simultaneously with the filing of the Trial Documents, the parties also must lodge by 4 p.m., an indexed and tabbed three-ring Trial Readiness Binder containing copies of all of the Trial Documents and the motions in limine and indexed and tabbed Exhibit Binders.
If the parties cannot agree on the wording of a sentence in the Joint Statement of the Case, they must put the alternative versions in brackets and bold for the Court to rule on.
If for some reason the parties cannot agree upon the wording of a sentence, they must put the alternative versions of the sentence in brackets and bold and the Court will rule on it.
Proposed jury instructions must be in a format ready for submission to the jury containing only the instruction number, title and text, with no boxes or other indications on the printed instructions.
The parties must prepare instructions in a format ready for submission to the jury with the instruction number, title and text only (i.e., there should be no boxes or other indication on the printed
The proposed verdict form must be prepared in WORD format.
The proposed verdict form should be prepared in WORD and, when final, emailed to Dept. 508.
DOCX
Proposed jury instructions (continuation of prior section) should be prepared in WORD and, when final, emailed to Dept. 508.
should be prepared in WORD and, when final, emailed to Dept. 508.
DOCX
Document Filing Requirements29 rules
Declarations regarding ex parte notice must contain all the information listed in CRC 3.1204(b).
The declarations regarding notice must contain all the information listed in CRC 3.1204(b).
Document Type
Ex Parte Notice Declaration
When a matter is resolved by an executed settlement agreement, the parties must promptly file a Notice of Settlement under CRC Rule 3.1385.
If a matter is resolved by an executed settlement agreement, the parties must promptly file a Notice of Settlement pursuant to Rule 3.1385 of the California Rules of Court.
Document Type
Notice Of Settlement
A declaration re meet and confer must be filed with any demurrer, motion to strike, or motion for judgment on the pleadings.
The parties are reminded to “meet and confer” in person, via telephone or video conference (not via email, texts or letters) regarding demurrers, motions to strike and motions for judgment on the pleadings and to file the requisite declaration re same with the pleading motions.
Document Type
Pleading Motion
Motions in limine must comply with L.A. Superior Court Rule 3.57 and Kelly v. New West Federal Savings.
Motions in limine must comply with L.A. Superior Court Rule 3.57 and Kelly v. New West Federal Savings, 49 Cal.App.4th 659, 670-71 (1996).
Document Type
Motion In Limine
Each party must assign distinct numbers or letters to its motions in limine (e.g., plaintiff numbered, defendant lettered) to avoid duplication and confusion.
THE PARTIES MUST ASSIGN DIFFERENT NUMBERS OR LETTERS TO THEIR MOTIONS IN LIMINE (e.g., Plaintiff’s motions in limine may be numbered 1-5; Defendant’s motions in limine may be lettered A-E; additional parties may use double numbers or letters or some other agreed-upon designation to avoid duplication and confusion.)
Document Type
Motion In Limine
Parties must file a Joint Statement of Relief Requested itemizing all elements of damages claimed by each party and the amounts, with no itemization required for emotional distress and punitive damages.
The parties must file a Joint Statement of Relief Requested, including itemization of all elements of damages claimed, if any, by each party, and the amount; no itemization is required for emotional distress and punitive damages.
Document Type
Joint Statement Of Relief Requested
Parties must file a joint list of all relevant undisputed facts, which for jury trials must be in a plain form and tone (not legalese) that can be read to the jury as stipulated facts.
The parties must file a joint list of all relevant facts not in dispute. For jury trials, the Joint List of Stipulated Facts must be in a form and tone (i.e., not "legalese") that can be read to the jury as stipulated facts.
Document Type
Joint List Of Stipulated Facts
Parties must file a Joint List of Proposed Jury Instructions in numerical order identifying agreed and contested instructions, with a space for the Court to mark each instruction given, not given or given as modified, and a place for the Court to date and sign.
The parties must file a Joint List of Proposed Jury Instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any. The Joint List of Jury Instructions must include a space by each instruction for the Court to indicate whether the instruction was given, not given or given as modified. It must also provide a place for the Court to date and sign the list.
Document Type
Joint List Of Proposed Jury Instructions
Parties must file a Joint Witness List with each testifying witness's name, fact/expert designation, and time estimates for direct, redirect, cross, recross and total, plus overall totals including jury selection, opening and closing, and must come to the FSC prepared to give realistic trial time estimates using 4.5-hour days for jury trials and 2.45 hours for court trials.
The parties must file a Joint Witness List, identifying the witnesses each party intends to call, except for impeachment witnesses. The Joint Witness List must include the name of each witness who is actually going to testify, whether that person is a fact witness or an expert witness, and the expected length of the direct and redirect, the cross-examination and recross-examination, and the total time for that witness. At the end of the list, the parties must provide a total time for the witnesses plus the time estimates for jury selection, opening and closing. The parties must come to the FSC prepared to give a realistic time estimate for the trial, using 4.5-hour days for jury trials and 2.45 hours for court trials.
Document Type
Joint Witness List
Parties must prepare a complete set of full-text proposed jury instructions, editing all proposed CACI instructions to insert party names and eliminate blanks and irrelevant material.
The parties must prepare a complete set of full-text proposed Jury Instructions, editing all proposed Judicial Council of California Civil Jury Instructions ("CACI") to insert party names and eliminate blanks and irrelevant material.
Document Type
Jury Instructions
The initial Joint Exhibit List exchange must include a column indicating whether each exhibit may be admitted without objection or the ground for objection.
The initial exchange of the Joint Exhibit List must include a column in which the parties indicate whether the particular exhibit may be admitted without objection or, if not, the ground for the objection.
Document Type
Joint Exhibit List
Parties must file and serve any objections to the proposed jury instructions and verdict form, which the Court will rule on at the FSC.
The parties must file and serve their objections, if any, to the proposed jury instructions and to the proposed verdict form. The parties may explain the reasons for their objections. The Court will rule on the objections at the FSC.
Document Type
Objections To Jury Instructions And Verdict Form
The initial Joint Exhibit List exchange must occur sufficiently in advance of the final filing to allow a serious, good-faith meet-and-confer on all exhibit objections.
This exchange must take place sufficiently in advance of the day that the final Joint Exhibit List is to be filed and included in the Trial Readiness Binder so the parties will have had time to meet and confer in a serious and good faith effort to resolve all objections to each exhibit to be offered at trial.
Document Type
Joint Exhibit List
Parties offering discovery materials in lieu of live testimony must identify all excerpts in writing (including both question and answer for deposition testimony, excluding impeachment), and opposing parties must state their objections.
If depositions, responses to written discovery or other discovery materials are to be used in lieu of live testimony, the party proposing to do so must identify and state in writing all such excerpts to be used (other than for impeachment). Parties must be sure to include both a question and an answer when identifying deposition testimony. Opposing parties must state their objections, if any.
Document Type
Identification Of Discovery Offered As Testimony
Any remaining unresolved exhibit objections must be listed on the Joint Exhibit List.
Any remaining unresolved objections must be listed on the Joint Exhibit List.
Document Type
Joint Exhibit List
Parties must file a proposed Joint General Verdict form or a proposed Joint Special Verdict form (with interrogatories) acceptable to all sides.
The parties must file a proposed Joint General Verdict form or a proposed Joint Special Verdict form (with interrogatories) acceptable to all sides.
Document Type
Proposed Verdict Form
If parties cannot agree on the verdict form after good-faith efforts, each party must insert disputed wording in bold brackets or separately file a proposed verdict form.
If, after making a good faith effort to resolve differences, the parties cannot agree on the verdict form, each party must either (a) insert the disputed wording in bold brackets, or (b) separately file a proposed verdict form if too much of the verdict form is in dispute (e.g., because a ruling on a motion in limine is needed to resolve the issue).
Document Type
Proposed Verdict Form
Any jury questionnaire must be joint and exchanged sufficiently in advance of the FSC so opposing parties may propose additional questions.
If either party requests a jury questionnaire, it must be exchanged sufficiently in advance of the FSC so the opposing parties may propose additional questions. The questionnaire filed must be a joint questionnaire.
Document Type
Jury Questionnaire
Parties must provide a court reporter for any trial or submit agreed statements/proposed settled statements daily.
The parties must provide a court reporter for any trial or submit agreed statements/proposed settled statements daily.
Document Type
Agreed Or Settled Statements
All non-documentary exhibits must be marked and a brief written description inserted behind the corresponding numerical tab in the exhibit binder.
The parties must mark all non-documentary exhibits (e.g. a CD) and insert a brief written description of the exhibit behind the corresponding numerical tab in the exhibit binder.
Document Type
Exhibit Binders
Exhibits or visual/auditory aids for opening statement must be shown to each other party at or in advance of the FSC.
Any exhibit or other visual or auditory aid that counsel wishes to use in opening statement must be shown to each other party at or in advance of the FSC.
Document Type
Opening Statement Exhibits
Parties should prepare written oppositions to ex parte applications because there is rarely a court reporter and the Court relies on the written record.
Please prepare written oppositions. There rarely is a court reporter, so the Court needs to have parties make a written record of their opposition; additionally, the written opposition is very helpful to the Court in understanding why you are opposing the ex parte application.
Document Type
Ex Parte Opposition
Citations to deposition testimony must reference both the question and the answer, and both must be marked even when separated by intervening colloquy.
Be sure to include a reference to both a question and an answer when identifying deposition testimony (not just the answer) and be sure to mark the question and answer even if the question appears five pages before the answer as a result of intervening colloquy.
Document Type
Motion
The Trial Documents must comply with LA Superior Court Rule 3.25 (f)-(h).
Document Type
Trial Documents
Parties must identify any potential witness scheduling issues and special requirements.
The parties must identify any potential witness scheduling issues and special requirements.
Document Type
Joint Witness List
The Joint Written Statement of the Case to be read to the jury panel should be no more than one or two paragraphs informing the jury of the nature of the case and each party's basic claim.
This statement should be no more than one or two paragraphs that simply inform the jury panel of the nature of the case and each party's basic claim (e.g., a contract dispute, a discrimination claim, etc.)
Document Type
Joint Statement Of The Case
If the parties decide not to provide a court reporter, Dept. 508 requires them to provide initial drafts of partial proposed settled statements (text continues beyond excerpt).
Should the parties decide not to provide a court reporter, Dept. 508 requires the parties to provide initial drafts of partial proposed
Document Type
Initial Drafts Of Partial Proposed Settled Statements
Parties are encouraged to include a stipulation for the Court to retain jurisdiction under CCP § 664.6 when the settlement is conditional.
The parties are encouraged to include a stipulation for the Court to retain jurisdiction pursuant to CCP section 664.6 if the settlement is conditional.
Document Type
Settlement Stipulation
Trial briefs are optional though strongly encouraged; if filed, each party's Trial Brief must succinctly identify the claims and defenses to be tried, the major legal issues with supporting points and authorities, and any other information that may assist the Court at trial.
Trial Briefs (optional though strongly encouraged) Each party may file a Trial Brief succinctly identifying the following: (1) The claims and defenses to be tried. (2) The major legal issues with supporting points and authorities. (3) Any other information that may assist the Court at trial.
Document Type
Trial Brief
Filing & Service rules
Electronic Filing Rules
Parties must reserve motion hearing dates and times online via the Court Reservation System (CRS); motions are heard Monday through Friday.
Motions are heard on Monday through Friday. Parties must obtain and reserve a motion hearing date and time via the online Court Reservation System (CRS) on the L. A. Superior Court website.
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Filing Timing and Cure Windows
The party seeking additional discovery must file Dept. 508's one-page IDC form in the department seven days before the IDC.
The party seeking the additional discovery must file Dept. 508's one-page IDC form in the department seven days prior to the IDC, and the responding party may file the same form in the department setting forth a response three days prior to the IDC.
Page 2 | Discovery Issues
Motions in limine and order-of-proof motions (CCP 597, 598, 1048) must be filed and served with sufficient CCP Section 1005 statutory notice so they can be heard no later than the FSC.
All motions in limine and motions that affect the order of proof, such as motions pursuant to CCP Sections 597 (trial of special defenses), 598 (change in the order of proof or bifurcation of the trial), and 1048 (consolidation or severance), must be filed and served with sufficient statutory notice under CCP Section 1005 so that they may be heard no later than at the FSC.
Page 4 | All Motions
Parties must meet and confer and file and serve the Trial Documents on the fifth court day before the FSC, except motions in limine which are filed and served per code.
Except as to motions in limine, which must be filed and served per code, the parties have a joint obligation to meet and confer, and to file and serve on the fifth court day prior to the FSC, the documents described below (the "Trial Documents").
Page 5 | The FSC: Trial Documents and Exhibit Binders
One complete set of all exhibit binders must be lodged by 4 p.m. five court days prior to the FSC.
Five court days prior to the FSC, the parties must lodge by 4 p.m. one complete set of all exhibit binders.
Page 8 | m) Joint Exhibit Binders
The responding party may file the IDC form with a response in the department three days prior to the IDC.
the responding party may file the same form in the department setting forth a response three days prior to the IDC
Page 2 | Discovery Issues
Service and Proof of Service Rules
Notice of an ex parte application must be given by telephone, in person, electronically (if permitted by the CCP or CRC), by other agreed-upon methods evidenced in writing, or, if time permits, with five days of mail time.
Notice must be given via telephone, in person, electronically if permitted by the CCP or CRC, by other agreed-upon methods evidenced in writing, or, if time permits, with five days of mail time.
Page 1 | Ex Parte Applications
Objections to email, text, or facsimile notice of an ex parte application are deemed waived if not raised in the opposition, but non-attendance at the hearing does not imply waiver.
A party is deemed to have waived any objection to email, text or facsimile notice if no objection is raised in the opposition to the application. If the party does not attend the ex parte hearing, no waiver is implied.
Page 1 | Ex Parte Applications
Filing Fees and Waivers
Motion fees must be paid at the time the hearing reservation is made online via CRS.
Motion fee payments are required at the time reservations are made online.
Page 3
The Court no longer provides court reporters for civil trials except for litigants with a fee waiver who make a timely request.
The Court no longer provides court reporters for civil trials unless a litigant with a fee waiver makes a timely request for a court reporter.
Page 8 | 6. Trials
Courtesy Copy Requirements
Courtesy conformed copies of filings with points and authorities or exceeding 15 pages must be lodged in Dept. 508 on the filing date (next business day if efiled on a holiday or weekend).
Courtesy conformed copies of any filings with a points and authorities or that exceed 15 pages must be lodged in Dept. 508 on the date of filing or, if the filing is efiled on a holiday or weekend, on the next business day.
Page 3
Courtesy copies of all motion, opposition, and reply papers are required; if the motion is filed more than 30 calendar days before the hearing, courtesy copies of the motion should be filed 16 court days before the hearing.
Please provide courtesy copies of all motion, opposition and reply papers. If your motion has been filed more than 30 calendar days before the hearing date, please wait to file the courtesy copies of the motion until 16 court days before the hearing.
Page 4 | All Motions
Courtesy copies of ex parte papers must be delivered to the courtroom (Department 508).
Please deliver courtesy copies of your papers to the courtroom.
Page 1 | Ex Parte Applications
Filing Bundling Requirements
With the MSJ/MSA reply brief, the moving party must lodge indexed, tabbed binders or spiral-bound compilations of all moving, opposing, and reply papers with supporting papers (excluding proofs of service and proposed orders); no additional courtesy copies are needed.
Concurrently with the filing of the reply brief on an MSJ/MSA, the moving party must lodge binders or spiral-bound compilations containing the moving and supporting papers, the opposing and supporting papers and the reply and supporting papers, all indexed and tabbed. Supporting papers include separate statements, declarations, exhibits, requests for judicial notice and any objections. Do not include proofs of service or proposed orders. It is not necessary to file courtesy copies in addition to the spiral-bound (or binder) compilations.
Page 4 | Motions for Summary Judgment or Summary Adjudication
Simultaneously with filing the Trial Documents, parties must lodge by 4 p.m. an indexed and tabbed three-ring Trial Readiness Binder containing all Trial Documents and motions in limine plus indexed and tabbed Exhibit Binders; voluminous motions in limine may go in a separate binder labeled with the case name with an index and tabs.
Simultaneously with the filing of the Trial Documents, the parties also must lodge by 4 p.m., an indexed and tabbed three-ring Trial Readiness Binder containing copies of all of the Trial Documents and the motions in limine and indexed and tabbed Exhibit Binders. If the motions in limine are too voluminous to fit in the Trial Readiness Binder, they may be filed in a separate binder properly labeled with the case name and with an index and tabs.
Page 5 | The FSC: Trial Documents and Exhibit Binders
Pre-Motion Conference Requirements
Before bringing any discovery motion (including motions to compel), counsel for the parties with full authority must meet and confer in person, by telephone, or by videoconference.
Pursuant to the Court's power to "amend and control its process and orders so as to make them conform to law and justice" (CCP § 128(a)(8)), the Court orders that parties who wish to bring any discovery motion (including motions to compel) must participate in the meet and confer process outlined below. First, the counsel for the parties with full authority must meet and confer in person or via telephone or videoconference to comply with the code requirements
Page 1 | Discovery Issues
If discovery disputes are resolved before the IDC date, the moving party must take both the IDC and any related motions off calendar as soon as possible.
If the parties resolve their discovery disputes before the IDC date, the moving party is ordered to take both the IDC and any motion(s) off calendar as soon as possible.
Page 2 | Discovery Issues
If counsel-level meet and confer fails, the parties must participate in an informal discovery conference (IDC) with the Court, with lead or designated counsel having full authority ordered to attend.
Second, if the in-person, telephone or video conference is not successful, then the parties must participate in another meet and confer with the Court in the form of what is referred to as an "informal discovery conference" or "IDC." Lead or other designated counsel for the parties with full authority are ordered to participate in the IDC.
Page 2 | Discovery Issues
If a discovery motion has already been filed, the moving party must promptly reserve an IDC through the Court's online reservation system after consulting opposing counsel and, if necessary, continue the hearing to a date after the IDC; filing before an IDC is strongly discouraged.
If a motion has been filed (which the Court strongly discourages doing before an IDC has been completed), after consulting with opposing counsel regarding available dates, the moving party must make a prompt reservation for the IDC using the Court's online reservation system and, if necessary, continue the hearing on the motion to a date after the IDC.
Page 2 | Discovery Issues
Parties must meet and confer in person, by telephone, or by video conference (not email, texts, or letters) before filing demurrers, motions to strike, or motions for judgment on the pleadings.
The parties are reminded to “meet and confer” in person, via telephone or video conference (not via email, texts or letters) regarding demurrers, motions to strike and motions for judgment on the pleadings and to file the requisite declaration re same with the pleading motions.
Page 3
Counsel are ordered to have available whatever materials are needed to make the IDC productive, and may have relevant documents on hand.
You may have available any relevant documents for the IDC. Counsel are ordered to have available to them whatever materials are needed to make the IDC session productive and successful.
Page 2 | Discovery Issues
The Court will make itself available, time permitting, for IDCs on other discovery issues the parties agree could benefit from one.
If other discovery issues arise that the parties agree could benefit from an IDC, the Court will make itself available for other discovery issues as well, time permitting.
Page 2 | Discovery Issues
Parties are encouraged (but not required) to meet and confer before filing any motions other than pleading motions, including summary judgment and summary adjudication motions.
The parties encouraged to meet and confer prior to filing any other motions, including summary judgment and summary adjudication motions.
Page 3
Adjournment & Extension Requirements
Parties should seek timely written extensions of discovery motion deadlines, and such extensions should be granted so an IDC can take place.
Parties should seek timely written extensions for discovery motions that have deadlines (e.g., motions to compel further) and such extensions should be granted so an IDC can take place.
Page 2 | Discovery Issues
Chambers Communication Rules
Parties must not call the courtroom to reserve motion hearing dates.
Please do not call the courtroom to reserve a motion date.
Page 3
To schedule a separate hearing for motions in limine, parties must contact the courtroom assistant in Dept. 508.
contact the courtroom assistant in Dept. 508 to schedule a separate hearing for the motions in limine.
Page 5
The final proposed verdict form must be emailed to Dept. 508.
The proposed verdict form should be prepared in WORD and, when final, emailed to Dept. 508.
Page 7 | h) Proposed Verdict Form
When a deposition reaches a breaking point, the parties may call Dept. 508 at (213) 633-0650 to ask the Court to informally resolve the dispute, but this should be reserved for very rare occasions.
Additionally, if the parties have reached a breaking point in a deposition where one party feels that they must adjourn the deposition to immediately bring a discovery motion pertaining to the deposition, the parties may call Dept. 508 - (213) 633-0650 and ask if the Court is available to informally try to resolve the dispute so the deposition can be completed. This type of IDC should be saved for those very rare occasions when counsel cannot work matters out enough to complete the deposition and then seek an IDC regarding the remaining disputed testimony.
Page 2 | Discovery Issues