Judge Thomas D. Long
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- 5 copies • At Trial
- Not required
Exhibits
- 1 copy • Hand Delivery • At Final Status Conference
All filings
Court-wide- Chambers Drop Off • Upon Filing
- Hand Delivery
Joint Discovery Statement
Court-wide- 1 copy • 3 Court Days Before Idc
Communication
Chambers5 contacts
- smcdept506@lacourt.ca.gov
- (213) 310-7011
- 213-310-7127
- 213-310-7128
- (213) 633-0689
Clerk2 contacts
- 213-830-0800 (Stanley Mosk); 213-310-7000 (Spring St)
- 213-830-0845
Page & Word Limits1 rule
Supplemental memoranda are limited to five pages.
A supplemental memorandum may not exceed five pages in length.
Supplemental Memorandum
5 pages
Document Format Requirements11 rules
Parties must attach tabbed copies of designated transcript pages to the joint chart, highlight each designation with a party-distinct color, and label lodged transcript spines with witness name, date, and volume number.
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. Deposition transcripts lodged with the Court should be labeled with the witness's name, date, volume number on the spine (e.g., "John Doe, 12/24/20, Vol. 1 of 3"), as well as the case name and number if it fits.
Parties must jointly prepare at least five sets of tabbed, numerically organized three-ring exhibit binders: one for the Court, the Judicial Assistant, the witnesses, and each party.
The parties’ counsel and any self-represented parties shall work together to jointly prepare at least five sets of tabbed, exhibit binders organized numerically in three-ring binders (Exhibit Binders): a set for the Court, a set for the Judicial Assistant, a set for the witnesses, and a set for each party.
The Motions in Limine Binder must be marked with the case caption, number, and title, contain conformed copies of all MIL papers, and be organized in tabbed three-ring binders with opposition/reply papers directly behind each motion separated by colored sheets.
The Motions in Limine Binder shall be marked with the case caption, number, and title on its front and spine and shall include conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders, 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.
Full-text jury instructions must be in a jury-ready form with no footers, headers, or titles except CACI references, no identification of the proposing party, and no tear-off form boxes.
The full text jury instructions should be in a form suitable to be provided to the jury. There should be no footers or headers or titles except references to CACI. The party proposing an instruction should not be identified on the instruction and the boxes provided when the tear-off forms were in use should not be used.
When many exhibits are stipulated into admission, the parties should prepare an Admitted Exhibits notebook for the clerk.
Where the parties have stipulated to the admission of a good number of exhibits, they should prepare an Admitted Exhibits notebook for the clerk.
The direct-examining attorney should prepare a witness notebook containing the exhibits to be used on direct when a witness will testify on exhibits from multiple volumes.
Where a witness will be testifying on a number of exhibits from different volumes, the attorney conducting the direct examination should prepare a notebook for the witness with the exhibits to be used on direct.
Exhibits must be three-hole punched in notebooks marked with the case caption, number, and title, with each exhibit paginated sequentially at the bottom center of each page.
Exhibits should be three-hole punched in notebooks marked with the case caption, number, and title on the front and spine of the notebook and with each exhibit paginated sequentially at the bottom center of each page. For example, Exhibit 1 should be paginated 1 - 1, 1 - 2, 1 - 3, etc.
Exhibits must clearly identify the offering party and be pre-marked using clearly identified number and/or letter sequences.
Exhibits should be clearly identified as to the party offering them and the parties should use clearly identified number and/or letter sequences to pre-mark exhibits.
Electronic exhibits must each be on a separate thumb drive, with a stipulated clean laptop provided to the jury and the courtroom attendant instructed on its use.
Where electronic exhibits are being used, each exhibit should be on a separate thumb drive and the parties should stipulate to a clean laptop to be provided to the jury for viewing electronic exhibits and should instruct the courtroom attendant as to its use.
There are no page limitations for joint discovery dispute statements, though they should be as concise as the subject matter permits.
Although the statement should present the disputed issues as concisely as the subject matter permits, no page limitations apply to statements regarding discovery disputes.
The Court permits the parties to propose an alternative identification method, including electronically marked deposition transcripts showing markings, counter-markings, and objections, in lieu of the paper joint chart format.
Alternatively, the Court invites the parties to agree on and propose to the Court a different way of identifying proposed deposition testimony to be used at trial. The Court can work with electronically marked deposition transcripts that present the parties' markings, counter-markings and objections in a way that the Court can efficiently make rulings and a proper record can be made of those rulings.
Document Filing Requirements43 rules
Parties must prepare joint statements when briefing discovery disputes on motions to compel further responses.
The Court requires parties to prepare joint statements to brief discovery disputes on motions to compel further responses. See Exhibit A.
Document Type
Motion To Compel Further Responses
Parties must arrange for a Trial notebook to be delivered to the courtroom and lodged prior to the Final Status Conference, prepared consistently with the Trial Preparation Order.
The parties shall arrange for a Trial notebook to be delivered to the courtroom and lodged prior to the FSC. Los Angeles Superior Court, Local Rule 3.25(g). The notebooks should be prepared consistently with the Trial Preparation Order. See Exhibit B.
Document Type
Trial Notebook
If the parties cannot agree on a joint settled statement, each party must submit its own version highlighting the differences and lodge the competing proposals the next morning before proceedings resume.
If the parties cannot agree on a joint form of the settled statement, they must each submit their own version and must highlight the differences and lodge their competing proposals the next morning before proceedings resume.
Document Type
Settled Statement
If no court reporter is used at trial, the parties must jointly prepare a summary of the day's proceedings (including detailed witness testimony summaries) 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, including a detailed summary of the testimony of any witness, and lodge it in the courtroom the next morning before proceedings resume.
Document Type
Settled Statement
The joint discovery dispute statement must be a single document signed by both counsel.
The joint discovery dispute statement must be set forth in one document signed by both counsel.
Document Type
Joint Discovery Dispute Statement
Neither party may file any separate memorandum of points and authorities in connection with the motion other than the permitted supplemental memorandum.
No other separate memorandum of points and authorities may be filed by either party in connection with the motion.
Document Type
Motion To Compel Further Responses
A motion to compel further responses may be supported only by the joint discovery dispute statement and supplemental memoranda; no other memoranda of points and authorities may be filed in support.
The motion shall be supported only by the joint discovery dispute statement and supplemental memoranda described below. No other memoranda of points and authorities shall be filed in support of the motion.
Document Type
Motion To Compel Further Responses
The joint statement must contain every disputed discovery request plus each party's contentions and points and authorities as to each request.
The statement must contain all discovery requests in dispute and, as to each such request, the contentions and points and authorities of each party.
Document Type
Joint Discovery Dispute Statement
The title page of the joint statement must state the discovery cutoff date, final status conference date, and trial date.
The title page of the statement must state the discovery cutoff date, the final status conference date, and the trial date.
Document Type
Joint Discovery Dispute Statement
Disputed interrogatories and answers must be quoted verbatim in the joint statement, followed by each party's separately stated contentions.
For example, if the sufficiency of an answer to an interrogatory is at issue, the statement must contain, verbatim, both the interrogatory and the allegedly insufficient answer, followed by each party's contentions as to that particular interrogatory, separately stated.
Document Type
Joint Discovery Dispute Statement
The joint discovery dispute statement may not refer the Court to any other documents.
The statement may not refer the Court to any other documents.
Document Type
Joint Discovery Dispute Statement
Parties must prepare the Motions in Limine Binder, Exhibit Binders, and Trial Binder required under Sections 3-5 of the Trial Preparation Order.
discuss and prepare the documents required in Sections 3.B. – H., below, and the Motions in Limine Binder, Exhibit Binders, and Trial Binder required in Sections 3 - 5, below
Document Type
Trial Binder
Counsel and self-represented parties must jointly prepare and file a witness list containing only witnesses actually intended to be called at trial, excluding impeachment or rebuttal witnesses.
The parties' counsel and any self-represented parties shall work together to prepare and file a joint list of all witnesses whom any party actually intends to call at Trial and is actually expected to testify (please do not include other potential witnesses), excluding witnesses being called only for impeachment or rebuttal.
Document Type
Joint Witness List
The joint witness list must be organized into six specified columns covering witness name/expert status/accommodations, calling party, testimony description, and estimated direct, cross, and total examination times in minutes.
The joint witness list shall be organized with columns (in the format set forth below) which state (1) the name of each witness (in alphabetical order by last name), if the witness is being called to testify as an expert, and any special requirements or accommodations needed for the witness (e.g., interpreter, remote connection), (2) the party calling the witness, (3) a brief description of the witness's expected testimony, (4) an estimate of the length of direct examination (in minutes), (5) an estimate of the length of cross-examination (in minutes), and (6) the total estimated length of examination (in minutes).
Document Type
Joint Witness List
The joint witness list must end with a grand total of all estimated witness testimony times, stated in weeks, days, hours, and minutes as appropriate.
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 in weeks, days, hours and minutes as appropriate.
Document Type
Joint Witness List
Parties must meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit before trial.
As set forth above, the parties' counsel and any self-represented parties shall meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit.
Document Type
Joint Exhibit List
Counsel and self-represented parties must jointly prepare and file an exhibit list with eight specified columns for each exhibit any party actually intends to offer at trial.
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 actually 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, (7) the date the exhibit was marked for identification, and (8) the date the exhibit was admitted into evidence.
Document Type
Joint Exhibit List
For jury trials, the parties must jointly prepare a complete set of full-text proposed jury instructions edited from CACI (with party names inserted and blanks removed), and must request CACI instructions where available, clearly explaining any departure.
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. 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. Any departure from CACI instructions should be clearly explained.
Document Type
Full Text Proposed Jury Instructions
For jury trials, the 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
Proposed Verdict Form
For jury trials, the parties must jointly prepare and file a joint list of proposed jury instructions stating, for each instruction, its 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: (1) the jury instruction number (listed in numerical order), (2) the title of the jury instruction, (3) the party 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
For 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, focusing on their own contentions rather than the other parties' wording.
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).) Parties should not insist on particular wording for the other parties' contentions but should simply focus on their own contentions and their responses.
Document Type
Joint Statement Of The Case
Counter-designations in the joint chart must include columns for the 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 columns which state: (1) 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 Of Page And Line Designations
Designations in the joint chart must include columns for the witness number/name, date and type of testimony, page and line designations, objections, related counter-designations, and the Court's ruling.
In the joint chart, each designating party's designations of deposition or former testimony shall include columns which state: (1) 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 Of Page And Line Designations
Parties intending to use deposition or former trial testimony must meet and confer and jointly file a chart of page and line designations; testimony used only for impeachment need not be included.
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). The parties do not, however, need to include in the joint chart deposition testimony or former Trial testimony they plan on using for impeachment purposes only.
Document Type
Joint Chart Of Page And Line Designations
Motions in limine must be noticed for hearing at the Final Status Conference, comply with CCP §1005 notice provisions, and include declarations complying with Local Rule 3.57.
Motions in Limine shall be noticed 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 §1005 and file declarations that comply with the requirements of Local Rule 3.57
Document Type
Motion In Limine
Multiple motions in limine must be numbered consecutively.
Parties filing more than one motion in limine shall number them consecutively.
Document Type
Motion In Limine
Opposition and reply papers on motions in limine must identify the corresponding motion number in the caption.
Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.
Document Type
Motion In Limine Opposition And Reply
Proposed jury instructions must be organized behind Tab F into three labeled groups in order: agreed 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) the Plaintiff's requested instructions to which the Defendant objects, and (3) the Defendant's requested instructions to which the Plaintiff objects.
Document Type
Proposed Jury Instructions
Trial binders must include the specified documents under Tabs A through I, with bench (non-jury) trials requiring only Tabs A, B, C, H, and I.
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 (Optional. If no Trial briefs are filed, leave Tab A empty.) 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 (full text adapted to the case and with all decisions as to bracketed matter duly incorporated). Tab G: Joint or Contested Verdict Form(s) Tab H: Joint Chart of Page and Line Designations for Deposition and 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.)
Document Type
Trial Binder
The trial binder must be labeled on its front and spine with the notebook title, case caption, and case number.
The Trial binder shall be labelled on its FRONT and SPINE with the notebook title, the case caption, and case number.
Document Type
Trial Binder
Privilege claims must be asserted no later than the deadline for providing the underlying information and must be supported by a privilege log.
Any claims of privilege relating to the information required to be provided under this Order shall be made no later than the time information is required to be provided under this Order and shall be supported by a privilege log.
Document Type
Discovery Responses
The witness list time totals, combined with estimates for jury selection, openings, closings, and jury instructions, should match the parties' total estimated trial time and any time limits set at the Case Management Conference.
The total time shown in the witness list may serve as part of the Court's basis for setting time limits at Trial and together with estimated time for jury selection, opening statements, closing arguments, and instructing the jury should match the parties total estimated Trial time and should match the anticipated date to present the case to the jury. The total time should also meet the time limits the Court set (if any) at the Case Management Conference ("CMC").
Document Type
Joint Witness List
Parties should not request CACI instructions that do not apply when trial begins (e.g., CACI 5013 applies only upon a deadlocked jury), but may request additional applicable instructions during trial if circumstances change.
The parties should not request CACI instructions that do not apply when the Trial begins. For example, CACI 5013 shall not apply unless and until there is a deadlocked jury. During Trial, if circumstances change, the parties may request additional applicable jury instructions.
Document Type
Proposed Jury Instructions
Parties must use the CACI special verdict form where an appropriate one exists for a cause of action, affirmative defense, or other finding, and must clearly explain any departure from it.
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 the CACI special verdict form. Any departure from a CACI special verdict form should be clearly explained.
Document Type
Special Verdict Form
An exhibit list must be placed at the front of the first volume of the exhibit binders.
An exhibit list should be provided at the front of the first volume of exhibits.
Document Type
Exhibit Binder
Generic motions in limine are prohibited; each motion must discuss the particular evidence to be excluded, such as specific evidence sought in a discovery request or ordered by the Court but not disclosed.
The parties should not file generic motions in limine untethered to actual anticipated disputes about evidence. Motions in limine that seek rulings “which would merely be declaratory of existing law” and do not include a discussion about the particular evidence the moving party seeks to exclude are not appropriate. (Kelly v. New West Federal Savings (1996) 49 Cal.App.4th 659, 670-671.) A common example is to seek exclusion of all evidence not produced in discovery. Such a motion is too abstract. Instead, a proper motion would seek to exclude specific evidence clearly sought in a particular discovery request or clearly ordered by the Court and yet not disclosed.
Document Type
Motion In Limine
New trial exhibits that were not pre-marked must conform to the exhibit formatting requirements and be identified on a supplemental exhibit list added to each copy.
New exhibits offered in Trial that have not been pre-marked should conform to the requirements above and should be identified on a supplemental exhibit list added to each copy.
Document Type
Trial Exhibits
Exhibits to the joint statement may include declarations, proofs of service of the disputed discovery requests, and other documents.
Exhibits to the statement may include declarations, proofs of service of the discovery requests at issue, and other documents.
Document Type
Joint Discovery Dispute Statement
Relevant allegations from prior filings must be cited by name, date filed, and page and line.
If allegations made in a prior filing are relevant, the filing should be cited by name, date filed, and page and line.
Document Type
Joint Discovery Dispute Statement
Identical arguments for multiple discovery requests should be stated once after the applicable group of requests and responses.
Where the arguments for multiple discovery requests are the same, those arguments should be stated once after the group of requests and responses to which they apply.
Document Type
Joint Discovery Dispute Statement
Trial briefs are optional but encouraged; if filed, they must succinctly identify the disputed claims and defenses, major legal issues with supporting authorities, the relief and damages sought, and other information helpful to the Court.
Each party may, but is not required to, file a Trial Brief succinctly identifying: (1) 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 damages sought; and (4) any other information that may assist the Court at Trial.
Document Type
Trial Brief
A party seeking more trial time than the Court's limits allow should include a discussion of proposed witness testimony in the joint witness list or state how much additional time is requested.
To the extent any party is seeking more time than allowed by the Court's limitations, that party should submit a discussion of proposed witness testimony either in the joint witness list or stating how much additional time is requested.
Document Type
Joint Witness List
Parties should consider and may suggest the order of jury instructions; the Court typically reads CACI 100 and 200 series before opening statements or evidence, other instructions before closing argument, and some CACI 5000 series after closings.
The parties should consider the order in which they want instructions read. The Court typically reads all requested CACI series 100 and 200 instructions before the opening statements or before evidence is taken. All other instructions are usually given before closing argument, although some CACI 5000 series instructions should be given after closings. The Court invites the parties' suggestions on the order of jury instructions.
Document Type
Proposed Jury Instructions
Filing & Service rules
Electronic Filing Rules
All documents must be electronically filed unless the litigant and filing qualify for an exemption under the First Amended General Order re Mandatory Electronic Filing for Civil (May 3, 2019).
All documents must be electronically filed unless the litigants and filings qualify for an exemption pursuant to the First Amended General Order re Los Angeles Superior Court – Mandatory Electronic Filing for Civil, dated May 3, 2019.
Page 2 | General Information
Filing Timing and Cure Windows
Ex Parte Applications must be filed by 10:00 A.M. on the court day prior to the Ex Parte hearing, absent an exemption.
Absent an exemption, you must file the application by 10:00 A.M. on the court day prior to the Ex Parte hearing.
Page 3 | Law & Motion
Case Management Statements must be filed at least seven calendar days before the scheduled Case Management Conference.
Case Management Statements must be filed at least seven calendar days before the date scheduled for the conference.
Page 4 | Case Management
Supplemental memoranda of law must be filed no later than ten days before the hearing date.
After the Joint Statement is filed, each party may file a supplemental memorandum of law not later than ten days before the hearing date.
Page 9 | Supplemental Memorandum
The Final Status Conference documents (trial brief if filed, joint witness list, and joint exhibit list) must be filed and served no later than five court days before the Final Status Conference.
No later than five court days before the Final Status Conference, the parties' counsel and any self-represented parties shall file and serve the following documents:
Page 13 | Trial Procedures - Final Status Conference
Service and Proof of Service Rules
The moving party's counsel must deliver its portion of the joint statement, with all supporting declarations and exhibits, to opposing counsel by personal delivery, e-mail, or fax.
Counsel for the moving party must personally deliver, e-mail, or fax to counsel for the opposing party the moving party's portion of the statement, together with all declarations and exhibits to be offered in support of the moving party's position.
Page 9 | Preparation of Joint Statement
After the moving party assembles the full statement, opposing counsel must sign it and return it by the end of the next business day so it can be filed with the notice of motion.
After the opposing party's material is added to the statement by the moving party's counsel, the statement must be provided to opposing counsel, who must sign it (electronically or otherwise) and return it to counsel for the moving party no later than the end of the next business day, so that it can be filed with the notice of motion.
Page 9 | Preparation of Joint Statement
Within seven days of receiving the moving party's material, opposing counsel must deliver its portion of the joint statement, with supporting declarations and exhibits, unless the parties agree otherwise.
Unless the parties agree otherwise, within seven days of receipt of the moving party's material, counsel for the opposing party must personally deliver, e-mail, or fax to counsel for the moving party the opposing party's portion of the statement, together with all declarations and exhibits to be offered in support of the opposing party's position.
Page 9 | Preparation of Joint Statement
Counsel and self-represented parties must exchange all exhibits they intend to introduce at trial 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 11 | 1. MEET AND CONFER
Both parties must serve verifications along with the documents they produce in discovery.
Plaintiff and Defendant shall serve verifications with the documents they produce.
Page 22 | 3. Production of Documents
Discovery information may, at the producing party's option, be provided to the opposing party electronically as a PDF.
The information may be provided to the opposing party in electronic form as a PDF at the option of the producing party.
Page 22 | 3. Production of Documents
Filing Fees and Waivers
A party with a fee waiver under California Rules of Court, Rule 3.55(7) may request an official court reporter by filing local form LACIV 2699 in advance of the hearing or trial.
A party who has received a fee waiver pursuant to California Rules of Court, Rule 3.55(7) may request an official court reporter by filing local form LACIV 2699 in advance of the hearing or Trial.
Page 2 | General Information
Courtesy Copy Requirements
Courtesy copies are not accepted except for Oppositions to Ex Partes, MSC settlement briefs, or as otherwise requested, and any accepted copies should be emailed to the Department 506 Resource Account.
The Court does not accept courtesy copies except for Oppositions to Ex Partes, settlement briefs for Mandatory Settlement Conferences (MSCs), or as otherwise requested by the Court. Any courtesy copies should be submitted to the Department 506 Resource Account: smcdept506@lacourt.ca.gov.
Page 2 | General Information
One set of all Exhibit Binders must be brought to the Final Status Conference for the Court to review.
The parties’ counsel and any self-represented parties shall bring one set of all of the Exhibit Binders discussed above to the Final Status Conference for the Court to review.
Page 18 | EXHIBIT BINDERS
At least five copies of the exhibits must be brought to trial: one for each party, the witness stand, the Judicial Assistant, and the Court.
At least five copies of the exhibits should be brought to the Trial: one for each party, one for the witness stand, one for the Judicial Assistant, and one for the Court.
Page 18 | EXHIBIT BINDERS
Sealing & Redaction Procedures
Unredacted versions of confidential filings submitted on eCourt must be emailed to the department resource account with a cc to all counsel/parties, except that copying the opposing party is not required for Certificates of Merit or confidential MSC statements.
Any confidential filings (including documents filed under a protective order and documents lodged conditionally) submitted on eCourt must have their unredacted versions emailed to the department resource account at smcdept506@lacourt.ca.gov with a cc to all Counsel/parties involved. However, copying the opposing party is not required for confidential documents related to Certificates of Merit or confidential Mandatory Settlement Conference (MSC) statements.
Page 2 | General Information
A party seeking protection for disclosed information must serve and file a proposed protective order within five days and meet and confer on agreeable language; otherwise the default is the Los Angeles Superior Court's standard protective order.
Confidentiality: If a party believes any of the disclosure of information under this Order should be subject to a protective order, that party shall serve and file a proposed protective order within five days of this order and the parties shall meet and confer as to agreeable language for the same. The default protective order will be the standard protective order provided by the Los Angeles Superior Court on its website.
Page 23 | Confidentiality
Filing Bundling Requirements
Parties must jointly prepare and lodge a Motions in Limine Binder in Department 506 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 506 a Motions in Limine Binder.
Page 18 | MOTIONS IN LIMINE BINDER
Parties must jointly prepare and lodge a physical Trial Binder in Department 506 no later than three calendar days before the Final Status Conference, marked with the case caption, number and title and consisting of one-sided, conformed copies.
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 506 a physical Trial Binder, with the case caption, number and title on the front page and, consisting of one-sided, conformed
Page 18 | TRIAL BINDER
Pre-Motion Conference Requirements
Informal Discovery Conferences are not held in Department 506 (except rarely by special request), so motions to compel further discovery must be accompanied by a joint statement for discovery disputes per Exhibit A, along with a notice of motion and motion to schedule the hearing.
Informal Discovery Conferences (IDCs) are not conducted in Department 506 (except rarely by special request). You may file your motions to compel further discovery. However, the Court now requires the parties to also file a joint statement for discovery disputes (as outlined in Exhibit A) together with your motions. Please note that you still must file a notice of motion and motion to schedule your hearing date.
Page 1 | Revised Guidelines Effective June 1, 2026
Trial Counsel must meet and confer by telephone or video conference (or in person) to resolve or narrow discovery disputes before proceeding with a discovery motion.
Trial Counsel must meet and confer by telephone or video conference (or in person, when consistent with public health recommendations) to resolve or narrow further discovery disputes. If the disputes remain unresolved, Counsel may proceed with a motion.
Page 3 | Law & Motion
For motions to compel further responses, the moving party must meet and confer with opposing counsel, then reserve a hearing date and file a notice of motion and motion to secure the hearing date.
After meeting and conferring with opposing counsel, the moving party shall reserve a hearing date for the motion and file a notice of motion. A notice of motion and motion must be filed to secure a hearing date.
Page 9 | Commencing a Discovery Motion
Counsel and self-represented parties must meet and confer no later than 11 calendar days before the Final Status Conference to prepare required trial documents, attempt stipulations on exhibit authenticity/admissibility, motions in limine, and ultimate facts and legal issues, and attempt to settle the case.
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: (1) discuss and prepare the documents required in Sections 3.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 11 | 1. MEET AND CONFER
Informal Discovery Conferences are not required and may not be scheduled unless specifically authorized by the Court.
Informal Discovery Conferences (IDCs) are not required and may not be scheduled unless specifically authorized by the Court.
Page 3 | Law & Motion
Adjournment & Extension Requirements
Parties must use the Court Reservation System (CRS) to continue or withdraw motions and must also call the courtroom so it is aware of the change.
Parties must use CRS to continue or withdraw motions; please also call the courtroom so we are aware of the change.
Page 3 | Law & Motion
Chambers Communication Rules
Communications with the Court must be emailed to the Resource Account at smcdept506@lacourt.ca.gov with a cc to all counsel and parties involved.
with the Court must be emailed to the Resource Account at smcdept506@lacourt.ca.gov with a cc to all Counsel/parties involved.
Page 3 | General Information