Los Angeles Superior Court Filing Bundling Requirements

CRITICALCivil cases

Each motion in limine must be filed separately with its own supporting papers, and pleadings may not be stapled, bundled together, or filed as an omnibus motion.

Each motion should be filed separately with its own points and authorities, supporting declarations and other evidence. Please do not staple or bundle the individual pleadings together with other motions in limine or file them as an “omnibus” series of motions in a single pleading.

CRITICALCivil cases

Bundling or filing omnibus motions in limine is prohibited; each motion must be filed separately.

Please do not staple or bundle the individual pleadings together with other motions in limine or file them as an “omnibus” series of motions in a single pleading.

CRITICALCivil cases

Motions in limine must be submitted in separate packets per motion; bundling multiple motions is prohibited.

In Limine motions shall be submitted in discrete packets (i.e. a separate packet for each motion) including the moving, opposition, and reply papers.

CRITICALCivil cases

Motions in limine should be submitted in a separate tabbed binder with a table of contents.

Motions in limine should be submitted in a separate tabbed binder with a table of contents.

CRITICALCivil cases

Motions in limine must be organized behind Tab B with numbered side tabs matching each motion number, colored-sheet separators between motion/opposition/reply, plaintiff's MILs first, and defendant's side tabs restarting at one.

Behind Tab B, the parties shall separate each motion in limine with a side tabbed number that corresponds to the number of the motion in limine. The motion, opposition, and reply shall be separated by a colored sheet of paper. The plaintiffs motions in limine shall come first and the defendant's motions in limine shall follow. For the defendant's motions in limine, the numbered side tabs shall start over with the number one, indicating the start of the defendant's motions in limine.

CRITICALCivil cases

If the motions in limine are too voluminous for a single FSC Trial Notebook, the parties must submit a separately labeled motion in limine notebook following the same internal format.

If the motions in limine are voluminous and will make use of a single FSC Trial Notebook impractical, the parties shall submit a separate motion in limine notebook, labeled accordingly, that follows the same internal format as described above.

CRITICALCivil cases

FSC Trial Notebook required in three-ring binder (max 3 inches), tabbed, one-sided, with table of contents, lodged 3 court days before FSC.

No later than three (3) court days before the FSC, the parties shall jointly prepare and lodge in Department P an "FSC Trial Notebook," consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder (no larger than three inches) with a table of contents that includes the following:

CRITICAL

Trial and exhibit binders must be three-ring binders; parties need 5 exhibit binders and at least 4 trial binders for trial readiness.

To be deemed ready for trial and immediate assignment to a trial court, parties and counsel shall have a three-ring TRIAL BINDER and EXHIBIT BINDER. The parties must have 5 Exhibit Binders and at least 4 Trial Binders.

CRITICAL

Motion in limine papers must be lodged in an indexed tabbed three-ring binder 5 court days before the FSC.

No later than five court days before the FSC, the moving party for each motion in limine must lodge directly in Dept. 54 an indexed and tabbed three-ring binder containing conformed copies of all moving, opposition, and reply papers for their motions in limine.

CRITICAL

Motions in Limine Binder required, lodged 3 days before Final Status Conference, three-ring binders, tabbed numerically, 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 24 a Motions in Limine Binder. 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 colored sheet of paper separating the moving, opposition, and reply papers.

CRITICAL

Trial Binder required, lodged 3 days before Final Status Conference, three-ring binder, tabbed with specified tabs, 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 24 a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of tabs A-I as specified.

CRITICAL

Four sets of Exhibit Binders required, tabbed, three-ring binders, internally paginated, one-sided documentary copies.

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.

CRITICAL

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 TabE: 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 Tab I: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).

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 TabE: 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 Tab I: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).

CRITICAL

The Motions in Limine Binder must contain one-sided conformed copies of all motions in limine, opposition papers, and reply papers, tabbed in numerical order in three-ring binders with opposition/reply papers behind the moving papers and colored separator sheets between them.

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 colored sheet of paper separating the moving, opposition, and reply papers.

CRITICAL

Proposed jury instructions must be organized behind Tab F in three cover-sheet-labeled groups: agreed-upon 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) plaintiff's requested instructions to which defendant objects, and (3) defendant's requested instructions to which plaintiff objects.

CRITICAL

3-ring trial binder with specified documents in order must be delivered to Dept U at least 10 court days before FSC.

the parties shall cooperate in compiling a 3-ring trial binder that shall be delivered to Department U at least 10 court days before the FSC. The binder must include all the following documents placed in the binder in the following order:

CRITICAL

On or before the day of trial, the parties shall lodge three (3) sets of exhibit binders, with an exhibit list in the front of each binder to serve as an index, and with divider tabs numbered by exhibit. The binders should be labeled with the name and case number for the case, and each binder shall be labeled "Judicial Assistant," "Judge" or "Witness."

On or before the day of trial, the parties shall lodge three (3) sets of exhibit binders, with an exhibit list in the front of each binder to serve as an index, and with divider tabs numbered by exhibit. The binders should be labeled with the name and case number for the case, and each binder shall be labeled "Judicial Assistant," "Judge" or "Witness."

CRITICAL

Parties must prepare a tabbed Joint Trial Binder containing trial briefs, operative pleadings, motions in limine (numerical order with oppositions/replies), joint statement of the case, joint witness and exhibit lists, jury instructions, voir dire questions, and separately tabbed verdict forms.

The parties shall prepare a tabbed Joint Trial Binder for the Court to include the above- described trial briefs; operative pleadings; motions in limine in numerical order with opposition and reply for each number; joint statement of the case; joint witness list; joint exhibit list; jury instructions; voir dire questions; and verdict form(s) separately tabbed.

CRITICAL

The binder must include all the following documents placed in the binder in the following order:

The binder must include all the following documents placed in the binder in the following order:

CRITICAL

Any important orders that may impact the scope or nature of the trial must be included in the Trial Binder.

Any Important Orders that may impact the scope or nature of the trial shall be included in the Trial Binder.

CRITICAL

Proposed Jury Instructions shall be included in the Trial Binder. These should include a jointly submitted packet of all requested and properly edited CACI jury instructions as to which there is no objection, as well as packets from any party offering CACI or special instructions that are not agreed to by all parties. The Proposed Jury Instructions should be submitted with CACI titles and numbers as well as numbered Special Instructions.

Proposed Jury Instructions shall be included in the Trial Binder. These should include a jointly submitted packet of all requested and properly edited CACI jury instructions as to which there is no objection, as well as packets from any party offering CACI or special instructions that are not agreed to by all parties. The Proposed Jury Instructions should be submitted with CACI titles and numbers as well as numbered Special Instructions.

CRITICAL

Any proposed jury questionnaire and all competing versions advanced by other parties must be included in the Trial Binder.

If any party seeks to use a jury questionnaire, its proposed questionnaire and all competing versions advanced by other parties must be included in the Trial Binder.

CRITICAL

All motions in limine briefing must be assembled in tabbed three-ring binders (moving papers, opposition, and reply behind a tab per motion) and delivered to the Court at least 5 court days before the FSC.

The parties are ordered to collect the briefing on all motions in limine and present them in one or more three-ring binders, with the moving papers, opposition and reply for each motion arranged behind a tab for each motion. The motion in limine binders shall be delivered to the Court at least five (5) court days before the FSC.

CRITICAL

The party filing the most motions in limine must assemble the MILs, oppositions, and any replies into a single binder for the Court.

The party filing the most MILs must assemble the MILs into a binder for the Court containing: (1) the MIL; (2) opposition to the MIL; and (3) any reply.

CRITICALCivil cases

Multiple motions-in-limine should be tabbed and indexed and submitted in a 3-ring binder containing copies of those motions e-filed by each party in numerical order and grouped with corresponding opposition and reply. Three-ring binders to be lodged directly in Department 412 at the FSC.

Multiple motions-in-limine should be tabbed and indexed and submitted in a 3-ring binder containing copies of those motions e-filed by each party in numerical order and grouped with corresponding opposition and reply. Three-ring binders to be lodged directly in Department 412 at the FSC.

CRITICAL

Three sets of tabbed, numerically organized exhibit binders not exceeding 3" per binder required for court, judicial assistant, witnesses; sets to opposing parties before trial.

The parties' counsel and any self-represented parties shall work together to jointly prepare three sets of tabbed, internally paginated by document, and properly marked exhibits, organized numerically in three-ring binders (not to exceed 3" per binder) (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) ("Exhibit Binders"). A set of properly marked exhibits must also be provided to each opposing party prior to the start of trial.

CRITICAL

Parties must jointly prepare and lodge in Department A a Motions in Limine Binder 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 A a Motions in Limine Binder which is no larger than 3".

CRITICAL

Trial Binder with specified tabs, one-sided conformed copies in three-ring binder required, lodged 3 calendar days before FSC.

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 A 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 (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; 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/Line Designations for Deposition/Former Testimony; Tab I: Copies of the Current Operative Pleadings.

CRITICAL

Parties must jointly prepare three sets of tabbed, internally paginated, properly marked exhibits in three-ring binders no larger than 3 inches each: a set for the court, the Judicial Assistant, and the witnesses.

The parties' counsel and any self-represented parties shall work together to jointly prepare three sets of tabbed, internally paginated by document, and properly marked exhibits, organized numerically in three-ring binders (not to exceed 3" per binder) (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) ("Exhibit Binders").

CRITICAL

Parties must jointly prepare and lodge a tabbed Trial Binder in Department A no later than three calendar days before the Final Status Conference containing trial briefs, witness and exhibit lists, jury statement, jury instructions, and verdict forms (bench trials require only Tabs A, B, C, H, and I).

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 A 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 (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; 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)

CRITICAL

Motions in limine, opposition, and reply papers must be bound in 3" three-ring binders, tabbed, indexed, lodged 3 calendar days before FSC; no proposed orders.

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 A a Motions in Limine Binder which is no larger than 3". The Motions in Limine Binder shall include two-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders not to exceed 3" per binder, indexed and 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. Proposed orders should not be included in the Motions in Limine Binder.

CRITICAL

Parties must jointly prepare and lodge a Motions in Limine Binder in Department 207 no later than five calendar days before the Final Status Conference.

No later than five calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department 207 a Motions in Limine Binder.

CRITICAL

Duplicative motions, objections and jury instructions: Multiple parties should not make the same motions and objections. Coordinate with each other. For example, if two parties will be making the same motion in limine, motion for a directed verdict, or written objection to evidence, submit one document only as a joint document.

Duplicative motions, objections and jury instructions: Multiple parties should not make the same motions and objections. Coordinate with each other. For example, if two parties will be making the same motion in limine, motion for a directed verdict, or written objection to evidence, submit one document only as a joint document.

CRITICAL

Motions in limine, oppositions, and replies must be bundled in a tabbed binder with table of contents, provided to court 2 days before FSC.

As explained above, the parties and counsel must provide a tabbed binder at the FSC containing all motions in limine, oppositions, and replies in sequential order consistent with the number assigned to each motion in limine. The binder also must contain a table of contents identifying each motion in limine, opposition, and reply, and the corresponding tab for each. The binder(s) must be provided to the court no later than two (2) days before the FSC.

CRITICALCivil cases

No later than 7 court days before the Final Status Conference, the parties must submit a tabbed hard copy trial binder (Tabs A–J) of the previously filed trial documents; in non-jury trials Tabs D–G are inapplicable and should be left empty, and voluminous motions in limine may merit their own binder.

By no later than 7 court days before the Final Status Conference, the parties are to submit to the Court a hard copy binder containing these previously filed documents under the following tabs: 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 – List of Proposed Jury Instructions (Joint and Contested) Tab F – Full Text Jury Instructions (Joint and Contested) Tab G – Joint Verdict Form Tab H – Joint Page and Line Designation for Deposition and Former Testimony answer, cross-complaint, and answer to any cross-complaint). Tab J – Motions in Limine (unless they are voluminous enough to merit their own binder). For non-jury trials, the documents behind Tabs D, E, F and G do not apply and need not be filed. In non-jury trials, those tabs of the trial binder should be left empty.

CRITICALCivil cases

Jury instructions must be filed together in a prescribed sequence (joint instructions, then plaintiff's contested instructions, then defendant's contested instructions) with a first-page pleading caption page.

following order (filed with a first page pleading caption page): (1) the agreed-upon instructions (“Joint Jury Instructions”), (2) plaintiff’s requested instructions to which defendant objects (Plaintiff’s Contested Jury Instructions”), and (3) defendant’s requested instructions to which plaintiff objects (“Defendant’s Contested Jury Instructions”).

CRITICAL

The court requests that a separate book/binder be submitted to the chambers at the time of the Pre-Trial Conference, containing all MILs. The motions should be tabbed by number and contain all relevant pleadings to each MIL, including the motion, the P&As in support thereof, the prosed order, any opposition pleadings, and any reply pleadings. Each party who files any MIL shall submit such a book/binder for their own MILs. Alternatively, the parties may submit a joint book/binder.

The court requests that a separate book/binder be submitted to the chambers at the time of the Pre-Trial Conference, containing all MILs. The motions should be tabbed by number and contain all relevant pleadings to each MIL, including the motion, the P&As in support thereof, the prosed order, any opposition pleadings, and any reply pleadings. Each party who files any MIL shall submit such a book/binder for their own MILs. Alternatively, the parties may submit a joint book/binder.

CRITICAL

Please do not lodge an entire set of all Exhibit Binders with the court before the first day of

Please do not lodge an entire set of all Exhibit Binders with the court before the first day of

CRITICAL

Parties must jointly prepare and lodge a Motions in Limine Binder in Department 513 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 513 a Motions in Limine Binder.

CRITICALCivil cases

Jury trial parties must have a joint binder complying with the general order, or the case will not receive a trial court assignment.

including have a joint binder or the case will not be given a trial court assignment.

CRITICAL

In the Motions in Limine Binder, opposition and reply papers must be placed directly behind the corresponding moving papers, and proposed orders must not be included.

The Motions in Limine Binder shall include two-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders not to exceed 3" per binder, indexed and 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. Proposed orders should not be included in the Motions in Limine Binder.

CRITICALCivil cases

Exhibits must be placed in a 3-ring binder.

The exhibits shall be placed in a 3-ring binder.

CRITICAL

Jury trial binders are required, court trial binders discretionary; must be tabbed 3-ring binders with TOC, lodged 2 calendar days before FSC.

TRIAL BINDERS ARE REQUIRED FOR ALL JURY TRIALS BUT ARE DISCRETIONARY FOR ALL COURT TRIALS For all jury trials, the parties/counsel shall jointly prepare and lodge a trial binder with the Court at least two (2) calendar days before the FSC, containing the required trial documents, tabbed and organized into 3-ring binders, with a Table of Contents in the front of each binder, as follows: Tab A: Trial Briefs of all parties Tab B: Joint Witness List Tab C: Joint Statement to be Read to the Jury Tab D: Joint Exhibit List Tab E: Joint List of Jury Instructions (identifying the agreed upon and contested instructions) Tab F: Joint and Contested Jury Instructions Tab G: Joint and/or Contested Verdict Forms

CRITICALCivil cases

Complaints and answers cannot be deemed filed as attachments to another document and must be filed separately.

Complaints (or amended complaints) and answers (or amended answers) cannot be "deemed" filed as an attachment to another document.

CRITICALCivil cases

MILs, oppositions, and replies must be assembled into binders that are tabbed and indexed with a Table of Contents.

MILs must be assembled into binders containing: (1) the MIL; (2) opposition; and (3) replies to the MIL which are tabbed and indexed into a Table of Contents.

CRITICAL

All motions in limine and oppositions must be combined into a single joint binder, tabbed with each motion, supporting declarations/exhibits, and proposed order, followed by the respective opposition with supporting evidence.

JOINT MOTION IN LIMINE BINDER containing all motions in limine and oppositions thereto, tabbed with each motion, supporting declarations/exhibits, and a proposed order, followed by the respective opposition with supporting evidence.

CRITICAL

Proposed jury questionnaires and all competing versions must be included in the Trial Binder.

If any party seeks to use a jury questionnaire, its proposed questionnaire and all competing versions advanced by other parties must be included in the Trial Binder.

CRITICAL

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.

CRITICAL

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

CRITICAL

The parties will be ordered to prepare a mandamus trial notebook to be lodged when the reply is due or as set by the court, and no courtesy copies of briefs are necessary if a trial notebook is prepared and lodged.

The parties will be ordered to prepare a trial notebook for the mandamus trial. The trial notebook shall be lodged on the date that the reply must be filed or as set by the court. No courtesy copies of briefs are necessary if a trial notebook is prepared and lodged.