Los Angeles Superior Court Filing Bundling Requirements

CRITICAL

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.

CRITICAL

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.

CRITICAL

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.

CRITICAL

Parties must jointly prepare a Motions in Limine Binder bundling all MIL moving, opposition, and reply papers and lodge it in Department 3 at least 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 jointly prepare and lodge in Department 3 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 tab separating the moving, opposition, and reply papers.

CRITICAL

Counsel and self-represented parties must jointly prepare and lodge a Motions in Limine Binder in Department 3 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 jointly prepare and lodge in Department 3 a Motions in Limine Binder.

WARNING

Separate the motion, any corresponding opposition, any corresponding reply,

Separate the motion, any corresponding opposition, any corresponding reply,

WARNINGCivil cases

For lengthy summary judgment/adjudication motions, filing and opposing parties are strongly encouraged to submit courtesy copies organized behind tabs in one or more three-ring binders.

Parties filing and opposing lengthy motions for summary judgment or adjudication are strongly encouraged to submit one or more three-ring binders organizing the courtesy copy behind tabs.

WARNINGCivil cases

If there are more than a few motions in limine, they should be placed in a separate binder.

If there are more than a few motions in limine, they should be placed in a separate binder.

WARNING

Please note that the trial binder and Motions in limine binder(s) should be in separate notebooks.

Please note that the trial binder and Motions in limine binder(s) should be in separate notebooks.

WARNING

The deposition designation chart must be submitted in a three-ring binder together with all deposition transcripts needed for the Court to rule on objections.

The chart shall be submitted to the Court in a three-ring binder, along with all deposition transcripts necessary for the Court to rule on the objections.

WARNING

In the trial binder, motions in limine must be arranged in numerical order (plaintiff's first, then defense's), with replies and oppositions placed directly behind the corresponding motion.

Motions in Limine are to be placed in numerical order starting with Plaintiff's Motions in Limine then Defense Motions in Limine. All replies and opposition are to be placed directly behind the Motion in Limine in question.

WARNING

The court prefers that all motions concerning a matter be heard on the same date when possible.

It is the court’s desire, if possible, that all motions concerning a matter be heard on the same date.

WARNING

Please note that the trial binder and Motions in Limine binder(s) should be in separate notebooks.

Please note that the trial binder and Motions in Limine binder(s) should be in separate notebooks.

WARNING

The Court strongly prefers the parties to file a single joint exhibit notebook containing both parties' exhibits.

The Court strongly prefers the parties to file a joint exhibit notebook, containing both parties' exhibits in one notebook.

WARNING

Motions in limine must be included in the Trial Binder, or placed in a separate binder if too voluminous, following the instructions in Exhibits 1 and 2.

Motions in limine shall be included in the Trial Binder, or, if too voluminous, in a separate binder in accordance with the instructions in Exhibits 1 and 2, below at pages 8 – 9.

WARNINGCivil cases

Joint motions or oppositions on behalf of all joining parties are encouraged where appropriate and feasible.

Where appropriate and/or feasible, motions or oppositions should be filed jointly on behalf of all joining parties.

WARNINGCivil cases

Parties should avoid filing duplicative motions or joinders that differ in form only.

Parties should avoid filing duplicative motions and joinders in form only.

WARNING

Proposed orders must not be included in the Motions in Limine Binder.

Proposed orders should not be included in the Motions in Limine Binder.

WARNING

The Motions in Limine Binder must contain one-sided conformed copies of all motions in limine, opposition, and reply papers, organized in tabbed three-ring binders with opposition and reply papers placed directly behind the moving papers and colored sheets separating each set.

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.

WARNINGCivil cases

In limine motions must be submitted in discrete packets — a separate packet for each motion containing the moving, opposition, and reply papers.

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

WARNING

When multiple motions are filed, parties should make efforts to schedule them on the same hearing date.

If multiple motions are filed, please make efforts to schedule them on the same date.

WARNINGCivil cases

If filed, optional jury trial briefs should be filed together with the other Final Status Conference materials.

But if they are to be filed, they should be filed along with the other Final Status Conference materials and should not exceed 20 pages exclusive of the table of contents, table of authorities, and exhibits.

WARNINGCivil cases

Multiple (more than 1) Motions in Limine should be tabbed and indexed and submitted in a three ring binder containing copies of those motions in limine e-filed by each party in numerical order and grouped with corresponding opposition and reply.

Multiple (more than 1) Motions in Limine should be tabbed and indexed and submitted in a three ring binder containing copies of those motions in limine e-filed by each party in numerical order and grouped with corresponding opposition and reply.

WARNING

Please note that the trial binder and Motions in Limine binder(s) should be in separate notebooks.

Please note that the trial binder and Motions in Limine binder(s) should be in separate notebooks.

WARNING

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.

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.

WARNINGCivil cases

The Joint Case Management Conference Statement Addendum must be filed as a separate pleading and must not be attached to the Case Management Statement.

Do not attach the addendum to the Case Management Statement. File the Addendum as a separate pleading.

WARNINGCivil cases

counsel providing a complete set of motions in limine with oppositions in a binder.

counsel providing a complete set of motions in limine with oppositions in a binder.

WARNING

In limine motions must be submitted in discrete packets — a separate packet per motion including moving, opposition, and reply papers.

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

WARNING

Please note that the trial binder and Motions in Limine binder(s) should be in separate notebooks.

Please note that the trial binder and Motions in Limine binder(s) should be in separate notebooks.

WARNING

The Court strongly prefers the parties to file a single joint exhibit notebook containing both parties' exhibits.

The Court strongly prefers the parties to file a joint exhibit notebook, containing both parties' exhibits in one notebook.

WARNING

Stipulations as to undisputed facts should be reduced to writing, filed with the Court, and included in the Trial Binder if reached before trial.

Such stipulations should be reduced to writing and filed with the Court. They should also be included in the Trial Binder, if reached before trial.

WARNING

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

WARNING

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.

INFO

The Court strongly prefers a joint exhibit notebook containing both parties' exhibits in one notebook, with exhibits numbered consecutively in the lower right-hand corner (sentence continues beyond this excerpt).

The Court strongly prefers the parties to file a joint exhibit notebook, containing both parties’ exhibits in one notebook. Those exhibits can be numbered consecutively in the lower, right-hand corner of

INFOCivil cases

Parties may submit joint trial documents in all cases, but joint submissions are not required unless specifically ordered by the court.

The parties are welcome to submit joint trial documents in all cases (see LR 3.25(g), but they are not required unless specifically ordered.

INFOCivil cases

Parties with substantially similar or logically related motions may contact the Judicial Assistant or Courtroom Assistant to arrange for the motions to be heard on the same date.

If motions are to be filed that are substantially similar or logically should be heard on the same date (such as similar demurrers by multiple defendants or multiple discovery motions filed by the same party), parties may contact the Judicial Assistant or the Courtroom Assistant to arrange hearings on the same date.

INFO

Relevant discovery requests and responses may optionally be attached to the IDC memoranda, and brevity is encouraged.

The relevant discovery requests and responses may be attached. Brevity is encouraged.

INFOCivil cases

Department 729 strongly encourages parties filing or opposing lengthy motions for summary judgment or adjudication to submit one or more binders (sentence truncated in source at 'one or more three-').

Department 729 also strongly encourages the parties filing and opposing lengthy motions for summary judgment or adjudication, to submit one or more three-

INFO

Multiple documents relating to one case may be uploaded together in a single e-filing envelope transaction.

Multiple documents relating to one case can be uploaded in one envelope transaction;

INFO

Court prefers consolidation of related discovery motions into a single omnibus motion.

Further, moving party is requested to consolidate discovery motions (e.g. if a party is moving to compel interrogatories, RFPs and RFAs, the court prefers ONE omnibus discovery motion, rather than multiple motions).

INFO

The court requests that moving parties consolidate discovery motions into one omnibus discovery motion rather than filing multiple motions.

Further, moving party is requested to consolidate discovery motions (e.g. if a party is moving to compel interrogatories, RFPs and RFAs, the court prefers ONE omnibus discovery motion, rather than multiple motions).

INFO

Trial briefs are optional; if no trial briefs are filed, Tab A of the trial preparation binder is left empty.

Tab A: Trial Briefs (Optional. If no trial briefs are filed, leave Tab A empty.)

INFO

Physical notebooks or binders need not be lodged with Department 534 unless and until the department orders it.

No physical notebooks or binders are required to be lodged with Department 534 unless and until so ordered by Department 534.

INFO

Stipulations as to undisputed facts should be reduced to writing, filed with the Court, and included in the trial binder if reached before trial.

Such stipulations should be reduced to writing and filed with the Court. They should also be included in the trial binder, if reached before trial.

INFO

The Court encourages written stipulations narrowing triable issues, which should be filed with the Court and included in the Trial Binder if reached before trial.

The Court encourages the parties to narrow the scope of triable issues by reaching stipulations as to certain undisputed facts. Such stipulations should be reduced to writing and filed with the Court. They should also be included in the Trial Binder, if reached before trial.

INFO

The Court strongly prefers (encourages but does not require) the parties to file a single joint exhibit notebook containing both parties' exhibits.

The Court strongly prefers the parties to file a joint exhibit notebook, containing both parties' exhibits in one notebook.

INFO

Parties should make efforts to schedule multiple filed motions on the same hearing date.

If multiple motions are filed, please make efforts to schedule them on the same date.

INFO

Preparing a motion notebook is optional; the court may ask for one or the parties may independently decide to prepare one.

The court may ask for, or the parties may independently decide to prepare, a motion notebook in a one or three inch, three-ring binder.

INFO

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.