Judge Wendy Chang
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
Ex Parte Application
- Hand Delivery • With Filing
Ex Parte Opposition
- 1 copy • Hand Delivery • By 4 30 Pm Day Before Hearing
Ex Parte Opposition, Ex Parte Motions
- 1 copy • Hand Delivery • By 4 30pm Day Before Hearing
Adjournments
- A party or counsel who takes a motion off calendar must promptly notify the Court and all other parties/attorneys.
- The Court strongly encourages parties to stipulate in writing to extend motion-to-compel deadlines to at least two weeks after the MCC hearing, and will weigh such stipulations in evaluating good faith meet and confer efforts on sanctions requests.
Request must include
Communication
Phone
Chambers, Clerk
Chambers
Chambers
Document Format Requirements19 rules
E-filed documents must be PDF text searchable when technologically feasible.
Documents must be electronically submitted in PDF text searchable format when technologically feasible without impairment of the document’s image.
E-filed documents must be submitted in PDF text-searchable format when technologically feasible without impairment of the document's image.
Documents must be electronically submitted in PDF text searchable format when technologically feasible without impairment of the document's image.
Table of contents for any submitted document must be bookmarked.
The table of contents for any document submitted must be bookmarked.
Electronic documents (declarations, proofs of service, exhibits) must be bookmarked with links to first page and descriptive titles.
Electronic documents, including but not limited to declarations, proofs of service, and exhibits or attachments, must be bookmarked within the document pursuant to California Rules of Court, rule 3.1110(f)(4). Electronic bookmarks must include links to the first page of each bookmarked item (e.g., exhibits, declarations, deposition excerpts) and with bookmark titles that identify the bookmark item and briefly describe the item.
Proposed orders must be submitted in PDF and Word formats, with Word as a separate document in the same electronic transaction.
Proposed Orders must be in both PDF and Word versions. The Word version must be submitted as a separate document in the same electronic envelope/transaction. (Cal. Rules of Court, rule 3.1312.)
Proposed orders must be submitted in both PDF and Word versions, with the Word version filed as a separate document in the same electronic envelope.
Proposed Orders must be in both PDF and Word versions. The Word version must be submitted as a separate document in the same electronic envelope/transaction.
Accompanying documents must be submitted as separate PDF digital documents.
Accompanying documents must be electronically submitted as a separate digital document in PDF format.
Writs and abstracts must be submitted in a separate electronic envelope.
Proposed jury instructions must be printed on one side only, one instruction per page.
Jury Instructions (Joint and Contested) – The parties/counsel shall prepare a complete set of full-text proposed jury instructions, printed on one side only, with one instruction per page, editing all proposed California Civil
Proposed jury instructions must be a complete full-text set printed one side only, one instruction per page, with irrelevant material edited out.
The parties/counsel shall prepare a complete set of full-text proposed jury instructions, printed on one side only, with one instruction per page, editing all proposed California Civil irrelevant material.
Exhibits must be pre-marked with Arabic numerals and multi-page exhibits must have sequentially numbered pages, per Local Rules 3.52 and 3.53.
Pursuant to Local Rules 3.52 and 3.53, the exhibits must be pre-marked using Arabic numerals and in instances where exhibits consist of multiple pages, each page must be numbered sequentially.
Exhibits must be pre-marked with Arabic numerals, page numbered, exchanged 5 days before FSC, lodged first day of trial, 5 tabbed/paginated sets required.
Pursuant to Local Rules 3.52 and 3.53, the exhibits must be pre-marked using Arabic numerals and in instances where exhibits consist of multiple pages, each page must be numbered sequentially. The exhibits must be exchanged at least five (5) calendar days before the FSC and lodged with the Court on the first day of trial. At least five sets of exhibit binders – tabbed and paginated – are required on the first day of trial: a complete set each for the Court, the judicial assistant, and the witness. Counsel must also supply an exhibit binder to each opposing party, and one for counsel themselves.
The table of contents of any e-filed document must be bookmarked.
The table of contents for any document submitted must be bookmarked.
Electronic documents such as declarations, proofs of service, and exhibits must be bookmarked with hyperlinks to each item's first page and bookmark titles that identify and briefly describe each item.
Electronic documents, including but not limited to declarations, proofs of service, and exhibits or attachments, must be bookmarked within the document pursuant to California Rules of Court, rule 3.1110(f)(4). Electronic bookmarks must include links to the first page of each bookmarked item (e.g., exhibits, declarations, deposition excerpts) and with bookmark titles that identify the bookmark item and briefly describe the item.
Bookmarks are required for documents including depositions, declarations, exhibits, transcripts, points and authorities, citations, and supporting briefs (lead-in sentence truncated by page split).
but are not limited to, the following: (A) Depositions; (B) Declarations; (C) Exhibits (including exhibits to declarations); (D) Transcripts (including excerpts within transcripts); (E) Points and Authorities; (F) Citations; and (G) Supporting Briefs.
Accompanying documents must be e-filed as separate digital documents in PDF format.
Accompanying documents must be electronically submitted as a separate digital document in PDF format.
Use of hyperlinks within e-filed documents, exhibits, and attachments is strongly encouraged.
Use of hyperlinks within documents (including exhibits and attachments) is strongly encouraged.
Hyperlinks within documents (including exhibits and attachments) are strongly encouraged.
Use of hyperlinks within documents (including exhibits and attachments) is strongly encouraged.
Multiple case-related documents may be submitted in one electronic envelope.
Multiple documents relating to one case can be uploaded and submitted in one electronic envelope.
Document Filing Requirements25 rules
Ex parte applications must include a declaration making an affirmative factual showing of irreparable harm, immediate danger, or another statutory basis for ex parte relief.
Ex parte applications are reserved for exigent circumstances and must comply with Cal. Rules of Court, rule 3.1202(c): "An applicant must make an affirmative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte."
Document Type
Ex Parte Application
Ex parte applications must include a declaration with affirmative factual showing of exigent circumstances per CRC 3.1202(c).
Ex parte applications are reserved for exigent circumstances and must comply with Cal. Rules of Court, rule 3.1202(c): “An applicant must make an affirmative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte.”
Document Type
Ex Parte Application
Plaintiff must submit a declaration of service efforts 5 days before case management conference if defendants not served.
If all defendants have not been served, plaintiff or plaintiff’s counsel must submit a declaration to the Court five (5) days prior to the hearing explaining what efforts have been undertaken to accomplish service. Cal. Rules of Court, rule 3.110.
Document Type
Case Management Conference
A separately filed proposed order is required for a stipulated request for an order.
Document Type
Stipulated Request For Order
In Song-Beverly Warranty Act discovery disputes, parties must identify each disputed item, quote the corresponding Dept. 410 guideline, and explain what dispute remains, or the motion to compel hearing may be continued.
Any discovery dispute that comes before the Court in a Song-Beverly Warranty Act case, either in a MCC or in a discovery motion, shall identify with specificity each discovery item in dispute, cross-reference and quote the corresponding relevant Dept. 410’s Courtroom guideline for Song-Beverly discovery disputes (if any), and advise the Court as to what dispute remains after reviewing the relevant corresponding guideline, which party asserts the remaining dispute, and why it contends a dispute remains beyond the Courtroom’s corresponding guideline. The failure to do so may result in the hearing on the motion to compel being continued until after such identification is made.
Document Type
Discovery Motion
Before filing motions in limine, parties must comply with CCP section 1005 notice provisions and Los Angeles County Local Rule 3.57(a).
Before filing motions in limine, the parties/counsel shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and the requirements of Los Angeles County Local Rule 3.57(a).
Document Type
Motion In Limine
Parties must file a signed joint witness list (excluding impeachment and rebuttal witnesses) identifying each witness by name, expected testimony, expert status, estimated direct/cross/re-direct time, total testimony hours, scheduling issues, and special requirements, with no duplicate names.
The parties/counsel shall work together and file a joint list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. (Local Rule 3.25(g)(5).) The joint witness list shall identify each witness by name, a general description of expected testimony, specify which witnesses are experts, estimate the length of direct examination, cross-examination, and re-direct examination of each, and include a total of the number of hours for all witness testimony at the end. There should be no duplicate names on the list. The parties shall identify all potential witness scheduling issues and special requirements. The parties/counsel shall sign the joint witness list.
Document Type
Joint Witness List
For jury trials, the parties must file a signed, neutral joint statement of the case of no more than 2 paragraphs for the Court to read to the jury.
For jury trials, the parties/counsel shall prepare a joint written statement of the case for the Court to read to the jury. (Local Rule 3.25(g)(4).) The joint statement shall be a neutral short statement of the case and not exceed 2 paragraphs. The parties/counsel shall sign the joint statement.
Document Type
Joint Statement Of Case
Parties filing multiple motions in limine must number them consecutively.
Parties filing more than one motion in limine shall number the motions consecutively.
Document Type
Motion In Limine
Oppositions and replies to motions in limine must identify the corresponding motion number in the caption of their pages.
Parties filing opposition and reply briefs shall identify the corresponding motion number in the caption of their pages.
Document Type
Opposition And Reply Brief
Parties must jointly file a signed list of proposed jury instructions in numerical order identifying agreed and contested instructions, with a space for the Court to note whether each instruction was given.
The parties/counsel shall jointly prepare and file a list of proposed jury instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any. The list of proposed jury instructions must include a space by each instruction for the Court to indicate whether the instruction was given. The parties/counsel shall sign the joint list of proposed jury instructions.
Document Type
Proposed Jury Instructions List
Each motion in limine's caption must concisely identify the evidence the moving party seeks to preclude.
The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to preclude.
Document Type
Motion In Limine
Parties using deposition or former trial testimony must meet and confer and file a signed designation chart with columns for page/line designations, objections, counter-designations, responses, and Court rulings.
If the parties intend to use deposition testimony or former trial testimony in lieu of any witness's live testimony, the parties shall meet-and-confer and jointly prepare and file a chart with columns for each of the following: (1) the page and line designations of the deposition or former testimony requested for use, (2) objections, (3) counter-designations, (4) any responses thereto, and (5) the Court's rulings. The objecting party shall specify all objections in the respective column. The parties/counsel shall sign the designations.
Document Type
Deposition Designation Chart
Special jury instructions must be jury-ready showing only number, title, and text (no requesting-party indication); CACI instructions are preferred over substitutes; substantively modified CACI instructions must be prominently identified; and uncontested and contested instructions must be separated into subsections.
The parties shall prepare special instructions printed 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 instruction itself as to the requesting party). Where there is an available CACI instruction, the Court will generally not give a substituted special instruction. Substantively modified CACI instructions beyond bracketed language must be prominently identified. Uncontested and contested instructions shall be separated into subsections, with all uncontested instructions together, and all contested instructions together.
Document Type
Jury Instructions
Parties must file a joint proposed verdict form; if they cannot agree, the Court prefers one joint form with redlines showing disputed language, and parties should bring an editable electronic copy to the FSC and trial.
The parties/counsel shall prepare and file a joint proposed general verdict form or special verdict form acceptable to all sides. (Local Rule 3.25(g)(8).) If the parties/counsel cannot agree on a joint verdict form, and if feasible, the Court prefers a single proposed joint verdict form with redlines identifying each party's proposed language where the language is disputed. The parties should bring an electronic copy of their proposed verdict form to the FSC and to trial, ready to be edited in the courtroom.
Document Type
Verdict Form
Parties must file a signed joint exhibit list with columns for exhibits, stipulations, and objections, after meeting and conferring on each exhibit and marking the results of that conference.
The parties/counsel shall prepare and file a joint exhibit list organized with columns identifying each exhibit, stipulations as to admissibility and/or authenticity, and specifying each party's evidentiary objections, if any, to admission of each exhibit. The parties/counsel shall meet and confer as to each individual exhibit in an effort to resolve objections to the authenticity and admissibility of each individual exhibit, and thereafter mark the appropriate box to advise the Court of the results of that meet and confer. The parties/counsel shall sign the joint exhibit list.
Document Type
Joint Exhibit List
Each motion in limine must identify the specific evidence or witness sought to be limited or excluded, and lack of specificity may result in summary denial.
Each motion in limine must identify a specific item or category of evidence, or a specific witness, that is sought to be limited or excluded. Lack of specificity in the request may result in a summary denial of the motion.
Document Type
Motion In Limine
Motions in limine must comply with Local Rule 3.57, including the required declaration if applicable.
When filing motions in limine, the parties must comply with Local Rule 3.57, including the required declaration, if applicable.
Document Type
Motion In Limine
Each separately efiled motion and related papers (including all opposition and reply papers) should include the last four digits of the CRS reservation ID number in the uploaded document title.
The Court respectfully requests that each and every separately efiled motion (and related papers) include the last four digits of the CRS reservation ID number to be included in the title that is uploaded. This request includes all opposition and reply papers.
Document Type
Motion
Each party's trial brief should succinctly identify the claims and defenses, major legal issues with supporting authorities, relief claimed and damages calculation, and any other helpful trial information.
Trial Briefs –The Court appreciates it when each party files a trial brief succinctly identifying: (1) the claims and defenses subject to litigation; (2) the major legal issues (with supporting points and authorities); (3) the relief claimed and the calculation of damages sought; and (4) any other information that may assist the Court at trial.
Document Type
Trial Brief
Uncontested motions in limine should be marked "uncontested" in the caption.
Uncontested motions should note "uncontested" in the caption.
Document Type
Motion In Limine
Proposed orders are not required to be filed with motions unless otherwise ordered or statutorily required, because the minute order operates as the Court's order.
Unless otherwise ordered by the Court, or unless the proposed order is statutorily required to be in a certain format, the Court does not require the filing of proposed orders along with motions. The minute order operates as the order of the Court.
Document Type
Motion
Proposed orders not required with motions unless stipulated or statutorily required; required for stipulated requests.
Unless otherwise ordered by the Court, or unless the proposed order is statutorily required to be in a certain format, the Court does not require the filing of proposed orders along with motions. The minute order operates as the order of the Court. A separately filed proposed order is required for a stipulated request for an order.
Document Type
Motion
E-filed motions, oppositions, and replies should include last 4 digits of CRS reservation ID in title.
The Court respectfully requests that each and every separately efiled motion (and related papers) include the last four digits of the CRS reservation ID number to be included in the title that is uploaded. This request includes all opposition and reply papers.
Document Type
Brief
Parties moving to compel further responses may file a concise outline (per CRC 3.1345(b)) in lieu of a separate statement, grouping issues and preferably using a table format.
The Court grants permission to any party filing a motion to compel further responses to file a concise outline of the discovery request(s), response(s), and the legal positions of each of the parties to the dispute, see Cal. Rule of Court Rule 3.1345(b), in lieu of a separate statement. Such concise outlines should group together discovery issues where possible. The Court appreciates a table format for the concise outlines, with columns for each category of discovery request, response, and legal positions of the parties.
Document Type
Motion To Compel Further Responses
Filing & Service rules
Electronic Filing Rules
All parties represented by counsel must comply with Los Angeles Superior Court Local Rule 3.4 mandatory e-filing and its technical requirements.
All parties represented by counsel shall comply with Los Angeles Superior Court Local Rule 3.4 on mandatory e-filing.
Page 1 | B. MANDATORY eFILING
Parties represented by counsel must comply with Local Rule 3.4 for mandatory e-filing.
All parties represented by counsel shall comply with Los Angeles Superior Court Local Rule 3.4 on mandatory e-filing.
Page 1 | B. MANDATORY eFiling
Moving parties must reserve law and motion hearing dates online via the Court Reservation System (CRS) on the Los Angeles Superior Court portal.
Moving parties must reserve a hearing date via the online Court Reservation System (CRS) on the Los Angeles Superior Court website at the LosAngelesSuperiorCourt|JournalTechnologiesCourtPortal.
Page 4 | Law and Motion
Filing Timing and Cure Windows
Counsel must e-file ex parte applications and supporting documents by 10am court day before hearing.
Parties represented by counsel must electronically file ex parte applications with all documentary support no later than 10:00 a.m. the court day before the ex parte hearing.
Page 2 | C. EX PARTE APPLICATIONS
Ex parte opposition counsel must e-file by 4pm day before hearing and deliver courtesy copy to Dept 410 by 4:30pm same day.
Any written opposition to the ex parte application by parties represented by counsel must be electronically filed no later than 4:00 p.m. of the day before the ex parte hearing, with a courtesy copy delivered directly to Dept. 410 no later than 4:30 p.m. that same day.
Page 2 | C. EX PARTE APPLICATIONS
Written opposition to an ex parte application by represented parties must be e-filed no later than 4:00 p.m. the day before the hearing.
Any written opposition to the ex parte application by parties represented by counsel must be electronically filed no later than 4:00 p.m. of the day before the ex parte hearing, with a courtesy copy delivered directly to Dept. 410 no later than 4:30 p.m. that same day.
Page 2 | C. EX PARTE APPLICATIONS
Represented parties must e-file ex parte applications with all documentary support no later than 10:00 a.m. the court day before the ex parte hearing.
Parties represented by counsel must electronically file ex parte applications with all documentary support no later than 10:00 a.m. the court day before the ex parte hearing.
Page 2 | C. EX PARTE APPLICATIONS
Case management statements must be filed at least 15 calendar days before the case management conference.
Case management statements must be filed at least fifteen (15) calendar days before the conference. (CRC 3.725(a).)
Page 3 | E. CASE MANAGEMENT CONFERENCES
If all defendants have not been served, plaintiff must submit a declaration explaining service efforts five days before the case management conference hearing.
If all defendants have not been served, plaintiff or plaintiff's counsel must submit a declaration to the Court five (5) days prior to the hearing explaining what efforts have been undertaken to accomplish service. Cal. Rules of Court, rule 3.110.
Page 3 | E. CASE MANAGEMENT CONFERENCES
Ex parte application papers must be filed with the Judicial Assistant in Dept. 410 by 8:45 a.m. on the day of the hearing.
application must file them with the Judicial Assistant in Dept. 410 by 8:45 a.m. on the day of the hearing
Page 3 | C. EX PARTE APPLICATIONS
Case management statements must be filed at least 15 calendar days before the conference.
Case management statements must be filed at least fifteen (15) calendar days before the conference. (CRC 3.725(a).)
Page 3 | E. CASE MANAGEMENT CONFERENCES
Ex parte papers filed by self-represented parties after 8:45 a.m. will not be accepted for a hearing that same day.
The Court will not accept ex parte papers from self-represented parties for hearings that same day if filed after 8:45 a.m.
Page 3 | C. EX PARTE APPLICATIONS
Joint MCC statement must be filed at least 5 days before the MCC.
At least five (5) days before the MCC, the parties/counsel shall file a joint statement that succinctly summarizes the nature of the dispute, the necessity for the discovery, the basis for any objection or withholding of information, and the overall status of discovery.
Page 4 | G. DISCOVERY DISPUTES
Parties must file a joint statement at least 5 days before the MCC summarizing the dispute, the necessity for the discovery, the basis for any objections, and the overall status of discovery.
At least five (5) days before the MCC, the parties/counsel shall file a joint statement that succinctly summarizes the nature of the dispute, the necessity for the discovery, the basis for any objection or withholding of information, and the overall status of discovery.
Page 4 | G. DISCOVERY DISPUTES
All pretrial documents must be filed and served at least 5 calendar days before the final status conference.
At least five (5) calendar days prior to the FSC, the parties/counsel shall serve and file the following: Trial Briefs – Motions in Limine – Joint Statement – Joint Witness List – Joint List of Proposed Jury Instructions – Jury Instructions (Joint and Contested) – Joint Verdict Form(s) – Joint Exhibit List – Page and Line Designations for Deposition and Former Testimony
Page 6 | H. TRIAL PROCEDURES 1. Final Status Conference
Parties must serve and file the specified pretrial documents at least five calendar days before the FSC.
At least five (5) calendar days prior to the FSC, the parties/counsel shall serve and file the following
Page 6 | H. TRIAL PROCEDURES - Final Status Conference (FSC) and Pretrial Filings
All pretrial documents must be filed before the Final Status Conference, which is held 10 days prior to the scheduled trial date.
All pretrial documents must be filed in advance of the FSC.
Page 6 | H. TRIAL PROCEDURES - Final Status Conference (FSC) and Pretrial Filings
Late motions in limine are considered only for witnesses deposed after the filing deadline and only if filed within 36 hours of the completion of the deposition.
Only motions in limine relating to witnesses whose depositions were taken after the deadline to file the motions in limine herein will be considered after this deadline, and only if filed within 36 hours of the completion of that deposition.
Page 9 | 3. Motions in Limine
Exhibits must be exchanged at least five calendar days before the final status conference and lodged with the Court on the first day of trial.
The exhibits must be exchanged at least five (5) calendar days before the FSC and lodged with the Court on the first day of trial.
Page 10 | 4. Exhibits
Because of a lag between e-filing and appearance in the court's review system, documents filed within 3-5 days of a hearing may not be reviewed before the hearing, so courtesy copies are the fastest way to ensure timely consideration.
The Court also notes that there is a lag time between the e-filing of a document, and its appearance in the system the Court accesses to review case files. The Court does not receive any notification when a document has been filed in the e-filing system. Thus, documents filed within 3-5 days of a hearing might not appear in the court file review system in time and the Judge may not be aware that the document has been filed - with the result that the Judge is unable to review the filings before a hearing. Courtesy copies are the fastest way to ensure that documents filed in this time window are actually received and considered in a timely manner.
Page 2 | B. MANDATORY eFILING
The standing order does not change statutory discovery motion filing deadlines unless the parties stipulate to an extension in writing.
Nothing stated herein affects the statutory deadline to file any discovery motion unless the parties stipulate to an extension in writing.
Page 5
Motions in limine are governed by CCP sections 1005(b) and 1013 notice requirements, should be set for hearing on the final status conference date, and will mostly be heard on the first day of trial.
Most motions in limine will be heard on the first day of trial (normally a Friday). Motions in limine are governed by the statutory notice requirements set forth in Code of Civil Procedure sections 1005(b) and 1013, and should be set with a hearing date of the final status conference.
Page 9 | 3. Motions in Limine
Ex parte applications are considered Monday through Friday at 8:30 a.m., following the morning calendar.
Ex parte applications will be considered Monday through Friday at 8:30 a.m., to follow the morning calendar.
Page 2 | C. EX PARTE APPLICATIONS
Service and Proof of Service Rules
All defendants must be served with the complaint no later than the case management conference.
All defendants must be served with the complaint by the case management conference.
Page 3 | E. CASE MANAGEMENT CONFERENCES
Parties must promptly notify the Court and all other parties when taking a motion off calendar.
A party/counsel who takes a motion off calendar shall promptly notify the Court and all other parties/attorneys.
Page 4 | F. LAW AND MOTION
Pre-trial filing and service deadlines apply unless otherwise ordered, and all service deadlines are extended per Code of Civil Procedure § 1013 based on the manner of service.
Unless otherwise ordered, the following pre-trial filing and service deadlines apply. All deadlines for service are extended based on the manner of service as set forth in Code of Civil Procedure § 1013.
Page 6 | H. TRIAL PROCEDURES
Filing Fees and Waivers
Ex parte applicants must pay the filing fee before appearing in Department 410.
Applicants must comply with California Rules of Court, rule 3.1200, et seq. and pay the filing fee before appearing in Dept. 410.
Page 2 | C. EX PARTE APPLICATIONS
Ex parte applicants must pay filing fee before appearing in Department 410.
Applicants must comply with California Rules of Court, rule 3.1200, et seq. and pay the filing fee before appearing in Dept. 410.
Page 2 | C. EX PARTE APPLICATIONS
Any applicable filing fee for ex parte papers must be paid at the filing window in Room 102 unless the party has a fee waiver.
after paying any applicable filing fee at the filing window in room 102 (unless the party has a fee waiver)
Page 3 | C. EX PARTE APPLICATIONS
Motion filing fees must be paid when reserving hearing date online via CRS.
Motion fee payments are required at the time reservations are made online.
Page 4 | F. LAW AND MOTION
Motion filing 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 4 | Law and Motion
Courtesy Copy Requirements
A courtesy copy of the ex parte opposition must be delivered directly to Dept. 410 no later than 4:30 p.m. the day before the hearing.
Any written opposition to the ex parte application by parties represented by counsel must be electronically filed no later than 4:00 p.m. of the day before the ex parte hearing, with a courtesy copy delivered directly to Dept. 410 no later than 4:30 p.m. that same day.
Page 2 | C. EX PARTE APPLICATIONS
Ex parte opposition counsel must deliver a courtesy copy to Dept 410 by 4:30pm day before hearing.
Any written opposition to the ex parte application by parties represented by counsel must be electronically filed no later than 4:00 p.m. of the day before the ex parte hearing, with a courtesy copy delivered directly to Dept. 410 no later than 4:30 p.m. that same day.
Page 2 | C. EX PARTE APPLICATIONS
A separate courtesy copy of the ex parte papers must be brought for each other party in the case.
A separate courtesy copy of the papers shall also be brought for each other party in the case.
Page 3 | C. EX PARTE APPLICATIONS
Self-represented parties must file ex parte papers by 8:45am day of hearing, pay fee, and bring courtesy copies for each party.
Self-represented parties: file with Judicial Assistant in Dept. 410 by 8:45 a.m. on the day of the hearing, after paying any applicable filing fee at the filing window in room 102 (unless the party has a fee waiver). A separate courtesy copy of the papers shall also be brought for each other party in the case. If you wish to have a stamped copy for your own records, please bring another extra copy for that purpose.
Page 3 | C. EX PARTE APPLICATIONS
Printed courtesy copies of efiled motion-related documents (with tab separators between exhibits) must be delivered to Dept. 410 by 4:30 p.m. the same business day, or by 10:00 a.m. the next business day if efiled after 4:30 p.m.
The Court strongly appreciates a printed courtesy copy (with inserted tab separators between exhibits) of motion-related documents filed electronically to be delivered to Department 410 by 4:30 p.m. on the same business day the document is efiled. If the efiling is submitted after 4:30 p.m., the courtesy copy must be delivered to Department 410 no later than 10:00 a.m. the next business day.
Page 4 | Law and Motion
Motion-related e-filed documents require a printed courtesy copy with tab separators, delivered by 4:30 p.m. same business day or 10:00 a.m. next business day if e-filed after 4:30 p.m.
The Court strongly appreciates a printed courtesy copy (with inserted tab separators between exhibits) of motion-related documents filed electronically to be delivered to Department 410 by 4:30 p.m. on the same business day the document is efiled. If the efiling is submitted after 4:30 p.m., the courtesy copy must be delivered to Department 410 no later than 10:00 a.m. the next business day.
Page 4 | F. LAW AND MOTION
Counsel must deliver one joint tabbed trial binder to the Court at the FSC, organized with Tab A: Trial Briefs and Tab B: Motions in Limine (additional tabs continue in source).
Counsel must provide a joint trial binder for the Court at the FSC. The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Motions in Limine
Page 8 | 2. Trial Binders
At least five tabbed and paginated exhibit binder sets are required on the first day of trial for the Court, judicial assistant, witness, each opposing party, and counsel.
At least five sets of exhibit binders – tabbed and paginated – are required on the first day of trial: a complete set each for the Court, the judicial assistant, and the witness. Counsel must also supply an exhibit binder to each opposing party, and one for counsel themselves.
Page 10 | 4. Exhibits
For law and motion filings—especially complex motions or motions exceeding 30 pages with exhibits—the Court strongly appreciates a printed, tab-separated courtesy copy with proof of e-filing delivered by 4:30 p.m. the same business day, or by 10:00 a.m. the next business day if efiled after 4:30 p.m.
With a busy courtroom that is frequently in trial, Department 410 reviews and analyzes law and motion best in paper form. This is especially true for complex motions or motions that exceed 30 pages (with exhibits). The Court strongly appreciates a printed courtesy copy with inserted tab separators between exhibits (along with proof of electronic submission) to be delivered to Department 410 by 4:30 p.m. on the same business day the document is efiled. If the efiling is submitted after 4:30 p.m., the courtesy copy should be delivered to Department 410 no later than 10:00 a.m. the next business day. All courtesy copies with attachments should have physical identifying tabs separating each such attachment.
Page 2 | B. MANDATORY eFILING
Parties may optionally bring an extra copy of ex parte papers to be date stamped by the Judicial Assistant and returned for their records.
If you wish to have a stamped copy for your own records, please bring another extra copy for that purpose. The Judicial Assistant will date stamp that copy and return it to you.
Page 3 | C. EX PARTE APPLICATIONS
Filing Bundling Requirements
A separate motion must still be filed for each set of discovery in dispute, even when using the concise-outline option.
This permission does not abrogate the requirement to file a separate motion for each set of discovery in dispute.
Page 5
Omnibus discovery motions (compelling responses to more than one set or type of discovery in a single motion) are not accepted without prior written leave of the Court.
The Court does not accept omnibus discovery motions without prior written leave of this Court. An omnibus discovery motion is a motion that seeks to compel responses to more than one set of discovery and/or more than one type of discovery in a single motion.
Page 5
Motions in limine must be tabbed in numerical order behind Tab B, with opposition and reply papers placed directly behind the moving papers and a tab identifying each filing.
The parties/counsel shall organize motions in limine (tabbed in numerical order) behind Tab B with the opposition papers and reply papers for each motion placed directly behind the moving papers, with a tab identifying each filing.
Page 10 | 3. Motions in Limine
Writs and abstracts must be e-filed in their own separate electronic envelope and may not be bundled with other documents.
Writs and abstracts must be submitted in a separate electronic envelope.
Page 2 | B. MANDATORY eFILING
The trial binder must include Tabs D through J containing the joint witness list, joint and contested jury instructions, verdict forms, joint exhibit list, deposition designation chart, and operative pleadings.
Tab D: Joint Witness List; Tab E: Joint List of Jury Instructions; Tab F: Joint and Contested Jury Instructions; Tab G: Joint and/or Contested Verdict Forms; Tab H: Joint Exhibit List; Tab I: Joint Chart of Page and Line Designations for Deposition and Former Testimony; Tab J: Copies of all Current Operative Pleadings
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Multiple documents relating to one case may be uploaded and submitted together in one electronic envelope.
Multiple documents relating to one case can be uploaded and submitted in one electronic envelope.
Page 2 | B. MANDATORY eFILING
Pre-Motion Conference Requirements
Discovery motions (except initial discovery responses) require scheduling an MCC with Department 410 prior to filing.
With the exception of motions to compel initial discovery responses, any party/counsel seeking to file a motion relating to any other form of discovery should also call Department 410 to schedule an MCC, so that the Court can facilitate your meet and confer efforts.
Page 4 | G. DISCOVERY DISPUTES
Except for motions to compel initial discovery responses, parties seeking to file any other discovery motion must call Dept. 410 to schedule a meet and confer conference (MCC) and have at least 3 possible MCC dates ready before calling.
With the exception of motions to compel initial discovery responses, any party/counsel seeking to file a motion relating to any other form of discovery should also call Department 410 to schedule an MCC, so that the Court can facilitate your meet and confer efforts. Prior to your call, please have at least 3 possible dates for the MCC that work for all counsel/self-represented parties.
Page 4 | G. DISCOVERY DISPUTES
Counsel and self-represented parties must meet and confer by phone, video, or in person and make a reasonable, good faith attempt to informally resolve each discovery dispute before filing discovery motions.
The Court expects and encourages counsel and any self-represented parties to informally resolve discovery disputes, instead of using expensive and cumbersome discovery motions. Thus, counsel and any self-represented parties shall meet and confer on the phone, by video, or in person, to make a reasonable and good faith attempt to informally resolve each discovery issue in dispute.
Page 4 | G. DISCOVERY DISPUTES
A meet and confer conference (MCC) must be held before the hearing on discovery motions, except for motions to compel initial discovery responses, or the hearing may be continued.
Other than a motion to compel initial discovery responses, the failure to engage in a MCC prior to the hearing may result in the Court finding that the meet and confer efforts required by Code to have been insufficient, resulting in a continuance of the hearing on the motions until a MCC is held.
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Everyone attending the MCC must have full authority to enter into stipulations, and agreements will be reduced to an order or confirmed in writing.
At the MCC, all present at the MCC must have full authority to enter into stipulations about the pending dispute. If there is agreement from the parties/counsel to do so, the Court will reduce the stipulations into an order. Otherwise, the Court will request the parties/counsel to confirm any agreements made at the MCC in writing and to proceed accordingly.
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Omnibus discovery motions (multiple sets/types of discovery in one motion) prohibited without prior written leave.
The Court does not accept omnibus discovery motions without prior written leave of this Court. An omnibus discovery motion is a motion that seeks to compel responses to more than one set of discovery and/or more than one type of discovery in a single motion.
Page 5 | G. DISCOVERY DISPUTES
Parties filing more than 10 motions in limine must contact Department 410 to schedule a Motions in Limine Conference before the filing deadline, and parties are strongly discouraged from filing more than 5 contested motions in limine.
Any party/counsel seeking to file in excess of 10 motions in limine shall contact Department 410 to schedule a Motions in Limine Conference before doing so. This conference must occur prior to the deadline for filing the motions. The parties/counsel are strongly discouraged from filing more than 5 contested motions in limine. The parties/counsel are strongly encouraged to stipulate to uncontested motions.
Page 9 | 3. Motions in Limine
Motions in limine may not seek dispositive relief that should be requested via summary judgment/adjudication or judgment on pleadings.
Motions in limine shall not be used to seek dispositive orders that should have been sought through a motion for summary judgment, summary adjudication or judgment on the pleadings.
Page 9 | H. TRIAL PROCEDURES 3. Motions in Limine
Parties filing more than 10 motions in limine must schedule a pre-filing conference with Department 410.
Any party/counsel seeking to file in excess of 10 motions in limine shall contact Department 410 to schedule a Motions in Limine Conference before doing so. This conference must occur prior to the deadline for filing the motions.
Page 9 | H. TRIAL PROCEDURES 3. Motions in Limine
Parties must meet and confer in good faith prior to filing motions in limine.
The parties/counsel MUST meet and confer in good faith prior to filing the motions in limine in an attempt to reach a stipulation on the evidence and other evidentiary issues. A simple exchange of letters that identify the motions to be filed is not a good faith meet and confer. Failure to meet and confer in good faith may result in a summary denial of the motion.
Page 9 | H. TRIAL PROCEDURES 3. Motions in Limine
Parties must meet and confer in good faith before filing motions in limine, and failure to do so may result in summary denial of the motion.
The parties/counsel MUST meet and confer in good faith prior to filing the motions in limine in an attempt to reach a stipulation on the evidence and other evidentiary issues. A simple exchange of letters that identify the motions to be filed is not a good faith meet and confer. Failure to meet and confer in good faith may result in a summary denial of the motion.
Page 9 | 3. Motions in Limine
Adjournment & Extension Requirements
A party or counsel who takes a motion off calendar must promptly notify the Court and all other parties/attorneys.
A party/counsel who takes a motion off calendar shall promptly notify the Court and all other parties/attorneys.
Page 4 | Law and Motion
The Court strongly encourages parties to stipulate in writing to extend motion-to-compel deadlines to at least two weeks after the MCC hearing, and will weigh such stipulations in evaluating good faith meet and confer efforts on sanctions requests.
The Court strongly encourages the parties to stipulate in writing to extend any deadline to file a motion to compel further responses to a date that is at least two weeks after the hearing on an MCC, to facilitate the meet and confer efforts. The parties may stipulate to a further extended deadline at the MCC. The Court will consider such stipulations when evaluating the good faith nature of the parties’ meet and confer efforts when ruling on sanctions requests.
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Chambers Communication Rules
Parties or counsel who will be late for a hearing must contact court staff at (213) 633-0156 before the hearing.
If parties/counsel are going to be late for a hearing, please contact court staff prior to the hearing at (213) 633-0156.
Page 3 | D. HEARINGS IN GENERAL
Parties must contact court staff at 213-633-0156 prior to hearing if late.
If parties/counsel are going to be late for a hearing, please contact court staff prior to the hearing at (213) 633-0156.
Page 3 | D. HEARINGS IN GENERAL
Interpreter requests should be made to Court Staff at least 2 days before the hearing (and no later than check-in) to improve the chance an interpreter is available.
If you require the services of an interpreter for your hearing, please advise Court Staff no later than when you check in. Courtroom interpreters are not always available on the same day as requested. If you contact Court Staff at least 2 days prior to your hearing with your request for an interpreter, there is a higher chance we will have one available at the time of your hearing.
Page 3 | E. CASE MANAGEMENT CONFERENCES
Department 410 can be reached by phone at 213-633-0156 during courtroom hours of 8:30 a.m.–12:00 p.m. and 1:30 p.m.–4:30 p.m.
Contact Information: 213-633-0156 Courtroom Hours: 8:30 a.m. – 12:00 p.m.; and 1:30 p.m. – 4:30 p.m.
Page 1 | Courtroom Information for Department 410
Interpreter requests should be made to court staff at least 2 days prior to hearing for best availability.
If you require the services of an interpreter for your hearing, please advise Court Staff no later than when you check in. Courtroom interpreters are not always available on the same day as requested. If you contact Court Staff at least 2 days prior to your hearing with your request for an interpreter, there is a higher chance we will have one available at the time of your hearing.
Page 3 | E. CASE MANAGEMENT CONFERENCES
Junior Lawyer Participation Incentives
Department 410 encourages junior/associate attorneys to argue or question witnesses, and when they do, one senior attorney for the same party may augment the argument or questioning.
Department 410 strongly encourages the active participation of junior/associate attorneys in hearings or trial before the Court, to help develop their skillset. To that end, while the Court will normally only permit one attorney per side to argue, when a junior/associate attorney argues for whatever relief is requested or participates in questioning a witness, the Court will permit one senior attorney for the same party to augment the argument or questioning, to eliminate risk to the client.
Page 3 | D. HEARINGS IN GENERAL