Judge William A. Crowfoot

The Motions in Limine Binder shall include one-sided, 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 tab separating the moving, opposition, and reply papers.

The parties' counsel and any self-represented parties shall work together to jointly prepare four sets of tabbed, internally paginated by document, and properly marked exhibits, organized numerically in three-ring binders (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) ("Exhibit Binders"). Copies of documentary exhibits shall be one-sided copies.

consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents

The parties shall organize proposed jury instructions into groups behind Tab F in the following order (labeled by cover sheets): (1) the agreed-upon instructions; (2) plaintiff's requested instructions to which defendant objects; and (3) defendant's requested instructions to which plaintiff objects.

The Motions in Limine Binder shall include one-sided, 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 tabs separating the moving, opposition, and reply

The parties' counsel and any self-represented parties shall work together to jointly prepare four sets of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) ("Exhibit Binders").

The parties must comply with California Rules of Court, rule 3.722, et seq., and Local Rule 3.25 in connection with such conferences.

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 Cal. Rules of Court, rule 3.110.

The Court may from time to time after the Case Management Conference schedule status conferences regarding mediation and discovery and order the parties to submit a joint statement informing the Court whether mediation or other efforts to resolve the case have occurred, and providing the Court with a discovery plan for the remaining discovery in the case. ... The failure to timely file a joint statement will result in the Court scheduling an order to show cause for sanctions.

Ex parte applicants must comply with the requirements of California Rules of Court, rules 3.1200-3.1207, submit a proposed order, and pay the filing fee before appearing in court.

In any trial conducted without the benefit of a court reporter, the parties will be required to prepare a joint settled statement at the end of each day of trial to be filed with the Court prior to the commencement of the following day of trial.

The parties must also file a proposed order that the Court may issue granting or denying the request for an IDC, with a blank for the Court to set the date and time of the IDC.

To request an informal discovery conference, the parties must file a stipulation jointly requesting the IDC. The stipulation should briefly summarize the discovery at issue and explain what efforts the parties have made to meet and confer, beyond the exchange of correspondence, to narrow the scope of their discovery dispute.

document set up as follows: the first column will identify the number of the discovery request at issue (e.g., SROG No. 1, or FROG No.1, etc.); the second, the full text of the discovery request; the third, the text of the response; and the fourth, a brief bullet-point statement, one from each party, as to why a further response should or should not be compelled.

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), if the witness is being called to testify as an expert, and any special requirements or accommodations needed for the witness (e.g., interpreter); (2) the party calling the witness; (3) whether the witness is actually expected to testify; (4) a brief description of the witness’s expected testimony; (5) an estimate of the length of direct examination (in hours); (6) an estimate of the length of cross-examination (in hours); and, (7) the total estimated length of examination (in

Each party shall 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.

The parties’ counsel and any self-represented parties shall work together to prepare and file a joint list of all witnesses whom any party intends to call at trial, excluding impeachment and rebuttal witnesses.

The parties’ counsel and any self-represented parties shall work together to prepare and file a joint exhibit list organized with columns (in the format set forth below) which state, as to each exhibit any party intends to offer at trial: (1) the exhibit number; (2) a brief description of the exhibit; (3) which party is offering the exhibit; (4) whether the parties have stipulated to authentication of the exhibit; (5) whether the parties have stipulated to admissibility of the exhibit; (6) any evidentiary objections to admission of the exhibit; (7) the date the exhibit was marked for identification; and, (8) the date the exhibit was admitted into evidence.

represented parties shall add up the estimated times for all witnesses’ testimony and state the grand total in the last column. Any witness who is not included on the joint witness list is subject to being excluded from testifying at trial other than for purposes of giving actual impeachment or rebuttal testimony. Any party who seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the Court.

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 as proposed, modified, refused, or withdrawn (CRC 2.1055) ("Joint List of Proposed Jury Instructions").

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).)

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.

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).) If after meeting and conferring the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

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.

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.

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.

No later than five court days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department 3 a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following: Tab A: Trial Briefs Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Statement to Be Read to the Jury Tab E: Joint List of Jury Instructions Tab F: Joint and Contested Jury Instructions Tab G: Joint or Contested Verdict Form(s) Tab H: Joint Chart of Page and Line Designations for Deposition and Former Testimony

Each party shall 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.

In order to ensure that the parties properly address, both before and during trial, the legal and factual issues upon which they are seeking a judicial decision, the Court requires the parties to submit a jointly prepared statement of controverted issues of law and fact for consideration at the Final Status Conference.

The parties' counsel and any self-represented parties shall work together to prepare and file a joint list of all witnesses whom any party intends to call at trial, excluding impeachment and rebuttal witnesses.

Any witness who is not included on the joint witness list is subject to being excluded from testifying at trial other than for purposes of giving actual impeachment or rebuttal testimony. Any party who seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the Court.

The parties' counsel and any self-represented parties shall work together to prepare and file a joint exhibit list organized with columns (in the format set forth below) which state, as to each exhibit any party intends to offer at trial: (1) the exhibit number; (2) a brief description of the exhibit; (3) which party is offering the exhibit; (4) whether the parties have stipulated to authentication of the exhibit; (5) whether the parties have stipulated to admissibility of the exhibit; (6) any evidentiary objections to admission of the exhibit; (7) the date the exhibit was marked for identification; and, (8) the date the exhibit was admitted into evidence. (Local Rule 3.25, subd. (g)(6).) 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.

In the joint chart, each designating party's designations of deposition or former testimony shall include columns which state: (1) the designation number ... 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.

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").

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.

Tab A: Trial Briefs Tab B: Joint Statement of Controverted Issues of Law and Fact Tab B: Joint Witness List Tab C: Joint Exhibit List and Former Testimony Tab E: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).