Los Angeles Superior Court Document Filing Requirements

Applies to

Ex parte application

Ex parte applications may only be filed where irreparable harm, immediate danger, or another statutory basis exists under CRC 3.1202(c), and applicants must verify the matter is proper for ex parte relief rather than a noticed motion.

Ex parte applications should only be filed in cases involving "irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte." (CRC 3.1202(c).) Applicants should verify that the matter addressed may properly be sought by ex parte application and does not otherwise require a noticed motion.

Applies to

Motion to compel further responses

Must include

certificate of conference

Motions to compel further responses must be accompanied by a meet and confer declaration showing a reasonable and good faith attempt to informally resolve each issue presented.

As a reminder, motions to compel further responses must be accompanied by a meet and confer declaration stating facts that show a reasonable and good faith attempt was made to informally resolve each issue presented by the motion. (CCP § 2016.040; Local Rule, Appendix 3.A (2024).)

Applies to

Trial preparation order

Counsel and parties must comply with the Dept E Standing Order re Final Status Conference - Trial Preparation Order; failure to comply may result in sanctions and a delay in trial.

Counsel and parties are expected to follow and comply with the Court's "Standing Order: Dept E re Final Status Conference - Trial Preparation Order" ("Standing Order"), which will be included in the minute order at the time the initial trial date is set. (See attached Standing Order.) Failure to comply with the Standing Order may result in sanctions and a delay in trial.

Applies to

Bench trial submissions

Bench trials do not require jury instructions, but substantive CACI instructions together with special verdict forms must be submitted.

(Note: Bench trials do not require submission of jury instructions, however, substantive CACI instructions must be submitted, together with special verdict forms that the Court may use in crafting a decision.

Applies to

Joint trial binder

Parties must meet and confer before the FSC and submit joint trial binder(s) and joint trial exhibit binder(s) to the Court at least five court days in advance of the FSC.

Counsel and any self-represented parties are ordered to meet and confer prior to the FSC to exchange, discuss, and prepare for submission to the Court, at least five (5) court days in advance of the FSC, a joint trial binder(s) and joint trial exhibit binder(s). The Court will verify at the FSC that all parties/counsel have met and conferred to prepare joint trial documents.

Applies to

Motion in limine

Motions in limine must be noticed with due statutory notice for the FSC date, comply with CCP section 1005, and be accompanied by the declaration required under Local Rule 3.57(a).

Motions in limine are to be noticed with due statutory notice for the date of the FSC. Before filing motions in limine, the parties/counsel shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and be accompanied by the required declaration prescribed under Local Rule 3.57(a).

Applies to

Joint witness list

The parties must jointly file a signed witness list in alphabetical order identifying each witness, experts, examination time estimates, and scheduling issues, with parties held to the estimates per Local Rule 3.25(h).

d. Joint Witness List: The parties/counsel shall work together to prepare and file a joint list of all witnesses in alphabetical order by last name that each party intends to call (excluding impeachment and rebuttal witnesses). The joint witness list shall identify each witness by name, specify which witnesses are experts, and estimate the length of direct examination, cross examination, and re-direct examination (if any) of each witness. The parties/counsel shall identify all potential witness scheduling issues and special requirements. The list must be signed by each counsel or non-represented litigant with the understanding that the parties can expect to be held to the estimates in accordance with Local Rule 3.25(h).

Applies to

Special verdict form

Parties must jointly file a proposed special verdict form for both jury and bench trials, or file separate proposed forms if agreement cannot be reached, and verdict forms are required even if the jury is waived.

For both jury and bench trials, the parties/counsel shall prepare and jointly file a proposed special verdict form acceptable to all sides. If the parties/counsel cannot agree on a joint special verdict form, each party must separately file a proposed verdict from. Verdict forms are required even though the parties may waive jury.

Applies to

Joint exhibit list

Parties must file a joint exhibit list identifying each exhibit and each party's evidentiary objections, and must meet and confer to resolve authenticity/foundation/admissibility objections.

The parties/counsel shall prepare and file a joint exhibit list organized with columns identifying each exhibit and specifying each party's evidentiary objections, if any, to admission of each exhibit. The parties/counsel shall meet and confer in an effort to resolve objections to the authenticity/foundation/admissibility of each exhibit.

Applies to

Deposition designation chart

If deposition or former trial testimony will be used in lieu of live testimony, parties must jointly file a designation chart containing page/line designations, objections, counter-designations, responses, and court ruling columns.

If the parties/counsel intend to use deposition testimony or former trial testimony in lieu of any witnesses live testimony, the parties/counsel shall meet and confer and jointly prepare and file a chart with columns for each of the following: (1) The line and page designation of the deposition or former testimony requested for use, (2) Objections, (3) Counter designations, (4) Any responses, and (5) Court ruling.

Applies to

Trial binder

Parties must jointly prepare and lodge a tabbed trial binder (three-ring, with table of contents) containing the required trial documents at the Final Status Conference.

The parties/counsel shall jointly prepare and lodge with the Court at the FSC, a trial binder containing the above-described trial documents, which shall be tabbed and organized into three-ring binders with a table of contents, as noted below and in the following order:

Applies to

Trial exhibit binder

Three sets of trial exhibit binders (for the trial court, clerk, and witnesses) must be submitted to the Court at the time of trial.

Three sets of trial exhibit binders must be submitted to the Court at the time of trial (i.e., set for the trial court, clerk, and witnesses).

Applies to

Joint exhibit list

Parties must bring a joint signed exhibit list and electronic copies of their exhibits to the FSC, and if they do, exhibit binders are not required at the FSC.

The parties/counsel shall have a joint signed exhibit list and electronic copies of their respective exhibits at the FSC, then the parties/counsel will not be required to produce exhibit binders at the FSC.

Applies to

Trial exhibit binder

Hard copy exhibit binders must be in the courtroom on the day trial commences.

However, hard copy exhibit binders are required to be in the courtroom on the day trial commences.

Applies to

Original deposition transcripts

Original deposition transcripts must be lodged with the clerk on the first day of trial.

Original deposition transcripts are to be lodged with the clerk on the first day of trial.

Applies to

Motion to compel further responses

Must include

certificate of conference

Motions to compel further responses must include meet and confer declaration.

motions to compel further responses must be accompanied by a meet and confer declaration stating facts that show a reasonable and good faith attempt was made to informally resolve each issue presented by the motion. (CCP § 2016.040; Local Rule, Appendix 3.A (2024).)

Applies to

Motion in limine

Must include

local rule certificate

Motions in limine must comply with CCP §1005 and include declaration under 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 be accompanied by the required declaration prescribed under Local Rule 3.57(a).

Applies to

Proof of service

Proof of service of summons and complaint must be filed; failure leads to OSC.

An OSC will be set concurrently with the Case Management Conference date regarding any failure to 1) prosecute of the case, 2) filing a proof of service of the summons and complaint, 3) file request for entry of default and 4) filing a case management statement.

Applies to

Ex parte application

Ex parte applications are reserved for exigent circumstances and must include a declaration making an affirmative factual showing of irreparable harm, immediate danger, or another statutory basis for relief.

Ex parte applications are reserved for exigent circumstances and must comply with Rules of Court, rule 3.1202(c): "An applicant must make an a irmative 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."

Applies to

Motion in limine

Parties filing more than one motion in limine must number the motions consecutively.

Parties filing more than one motion in limine shall number them consecutively.

Applies to

Motion in limine opposition and reply

Opposition and reply papers on motions in limine must identify the corresponding motion number in the caption.

Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.

Applies to

FW-020

Form FW-020 must be filed to request a court reporter with a fee waiver.

A party who has received a fee waiver pursuant to CRC 3.55(7) may request an official court reporter by filing form FW-020 at least 10 calendar days before the hearing or trial. (See CRC 2.956(c).)

Applies to

Court reporter stipulation or appointment order

Parties must provide their own court reporter for hearings and trial and file either a Stipulation and Order to use a Certified Shorthand Reporter or an Order Appointing a Court Approved Reporter as Official Reporter Pro Tempore before the hearing is called.

Official court reporters are not assigned to Civil Courtrooms. It is the responsibility of the parties to provide their own Court Reporter for hearings and trial. The parties are to file either the Stipulation and Order to use Certified Shorthand Reporter or Order Appointing Court Approved Reporter as Official Reporter Pro Tempore prior to the hearing being called.

Applies to

Case management statement

Parties must file a case management statement on Judicial Council Form CM-110 no later than 15 calendar days before the case management conference.

The parties and counsel shall file a case management statement using Judicial Council Form CM-110 no later than fifteen (15) calendar days before the date set for the conference.

Applies to

Motion or application

A filing concerning incomplete service must explain why service has not been completed, document the efforts made to complete service, and specify the proposed completion date (Cal. Rules of Court, rule 3.110).

explaining why service has not been completed, documenting the efforts that have been made to complete service, and specifying the date by which service is proposed to be completed. (Cal. Rules of Court, rule 3.110.)

Applies to

Ex parte application

Must include

proposed order

Ex parte applicants must comply with CRC 3.1200 et seq., submit a proposed order, and pay the filing fee before appearing in court.

Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in court.

Applies to

Ex parte application

Ex parte applications are reserved for exigent circumstances and must include a declaration making an affirmative factual showing of irreparable harm, immediate danger, or another statutory basis for relief.

Ex parte applications are reserved for exigent circumstances. The applicant shall comply with California 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."

Applies to

Request for informal discovery conference

Requests for an Informal Discovery Conference must be filed using Form LACIV-094.

The parties are instructed to file their Request for an IDC using Form LACIV-094.

Applies to

Idc brief

IDC briefs must succinctly summarize the nature of the dispute, the necessity for the discovery, the basis for any objection or withholding of information, and (continuing on the next page) the deadline for the filing of any motion to compel further responses.

At least five (5) calendar days before the IDC, the parties shall file IDC briefs not to exceed five (5) pages that succinctly summarize the nature of the dispute, the necessity for the discovery, the basis for any objection or withholding of information,

Applies to

Trial brief

Each party must file a trial brief identifying the claims and defenses, legal and factual issues with supporting points and authorities, relief and damages calculation, stipulated facts, anticipated evidentiary issues, and other trial-assisting information.

Trial Briefs – Each party shall file a trial brief succinctly identifying: (1) the claims and defenses subject to litigation; (2) the legal and factual issues to be decided (with supporting points and authorities); (3) the relief claimed and the calculation of damages sought; (4) the ultimate facts or issues to which you will stipulate; (5) the major evidentiary issues anticipated; and (6) any other information that may assist the Court at trial.

Applies to

Joint statement

For jury trials, the parties must file a signed joint statement of the case not exceeding two paragraphs, or, if no agreement is reached after a good faith meet-and-confer, each party must separately file a proposed joint statement.

Joint Statement – For jury trials, the parties shall prepare a joint written statement of the case for the Court to read to the jury. The statement should not exceed two paragraphs. The parties and counsel shall sign the joint statement. If the parties cannot agree on a joint statement after a good faith meet-and-confer session conducted in person, over the phone, or via videoconference, each party must separately file a proposed joint statement.

Applies to

Joint witness list

The parties must file a signed joint witness list (excluding impeachment and rebuttal witnesses) identifying each witness by name, expert status, estimated examination times, total testimony hours, and any scheduling issues or special requirements.

Joint Witness List – The parties shall work together and file a joint list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. The joint witness list shall identify each witness by name, 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. The parties shall identify all potential witness scheduling issues and special requirements. The parties and counsel shall sign the joint witness list.

Applies to

Joint list of proposed jury instructions

The parties must jointly prepare and file a signed joint list of proposed jury instructions, organized in numerical order, identifying agreed and contested instructions.

Joint List of Proposed Jury Instructions – The parties shall jointly prepare and file a joint list of proposed jury instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any. The parties and counsel shall sign the joint list of proposed jury instructions.

Applies to

Full text jury instructions

The parties must prepare a complete set of full-text proposed jury instructions edited to include all case-specific information requested in the Judicial Council of California Civil Jury Instructions.

Jury Instructions (Joint and Contested) – The parties shall prepare a complete set of full-text proposed jury instructions. The submitted full-text instructions shall be appropriately edited to include all case-specific information requested in Judicial Council of California Civil Jury

Applies to

Proposed verdict form

Parties must file a joint proposed verdict form, or if they cannot agree after a good faith meet-and-confer, each party must separately file a proposed verdict form.

The parties shall prepare and file a joint proposed general verdict form or special verdict form (with interrogatories). If the parties cannot agree on a joint verdict form after a good faith meet-and-confer session conducted in person, over the phone, or via videoconference, each party must separately file a proposed verdict form.

Applies to

Joint exhibit list

Parties must file a joint exhibit list with five required columns, meet and confer before filing to identify stipulations or objections, and sign the list.

The parties shall prepare and file a joint exhibit list organized with columns identifying: (1) the exhibit, (2) which party is offering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) the date on which the exhibit was identified, and (5) the date on which the exhibit was admitted. Prior to filing the joint exhibit list, the parties shall meet and confer in person, over the phone, or via videoconference to determine whether they will stipulate to the authenticity and/or admissibility of each exhibit or whether there are objections to any exhibit. If there are stipulations, the parties shall note that in the respective column. If not, the objecting party shall specify all objections in the respective column. The parties and counsel shall sign the joint exhibit list.

Applies to

Deposition designation chart

Parties using deposition or former trial testimony in lieu of live testimony must meet and confer and jointly file a designation chart with five required columns, signed by the parties and counsel.

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 and counsel shall sign the designations.

Applies to

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.

Applies to

Motions in limine binder

The motions in limine binder must include a table of contents identifying each motion, opposition, reply, and corresponding tab.

The binder also must contain a table of contents identifying each motion in limine, opposition, and reply, and the corresponding tab for each.

Applies to

Court reporter form

Parties must provide their own court reporters and file Form LACIV237 (reporter on the Pro Tempore directory) or Form LACIV236 (reporter not on the directory) in the courtroom before the judge calls the case.

If you require a court reporter, you must provide your own. The following forms must be filed in the courtroom prior to the judge calling your case: Form LACIV237, if the court reporter is listed on the court's Pro Tempore Court Reporter Directory; or, Form LACIV236, if the court reporter is not listed on said directory.

Applies to

Ex parte application

Must include

proposed order

The Court may not consider ex parte applications that are filed without a proposed order.

Please note that the Court may not consider ex parte applications submitted/filed without a proposed order.

Applies to

Motion in limine

All parties must meet and confer on motions in limine before filing them; failure to do so may result in the court refusing to hear the motion.

All parties must meet and confer on all motions in limine prior to filing said motions. Failure by any party or counsel to exchange or discuss any motion in limine may result in the refusal by the Court to hear any such motion in limine, pursuant to applicable court rules.

Applies to

Trial brief

Trial briefs must include a description of each cause of action and key affirmative defenses, the issues to be decided, and a statement of ultimate facts or issues to be stipulated (required-content list continues beyond this excerpt).

Trial briefs are mandatory for all (both Court and jury) trials and must include the following information and not exceed 20 pages: 1) A brief description of each cause of action and key affirmative defenses presented and the issues to be decided; 2) Statement of ultimate facts or issues to which you will stipulate;

Applies to

Joint pretrial statement

The joint statement must include contested issues of fact and law with supporting authorities, major evidentiary issues, a detailed breakdown of damages and relief claimed, and any other information assisting the Court.

4) All contested issues of fact; 5) All contested issues of law, together with points and authorities supporting the position of the parties; 6) A list of major evidentiary issues anticipated, any relevant points and authorities supporting the position of the parties; 7) A detailed statement of the damages and relief claimed, including a specific breakdown of the elements of damages claimed and the amount sought; and, 8) Any other information that will assist the Court.

Applies to

Witness list

The joint witness list must name each witness, estimate direct and cross-examination time, give total combined testimony time, and note potential scheduling problems.

The jointly prepared Witness List must include the name of each witness, an estimate of time for direct and cross-examination, and the total amount of time of all witness testimony combined for the entire trial. Potential scheduling problems must be noted.

Applies to

Exhibit list

All parties must jointly prepare and exchange a completed exhibit list indicating each document, physical evidence item, and any stipulation to authenticity and/or admissibility.

All parties must jointly prepare and exchange a completed Exhibit List, indicating each document and item of physical evidence, and whether there is a stipulation to authenticity and/or admissibility.

Applies to

Exhibits

Exhibits must be numbered or lettered from pre-agreed party-specific ranges, separately identified (including subparts listed separately), with each page of multi-page exhibits consecutively paginated.

Each exhibit shall be numbered or lettered. All parties shall agree in advance that their respective party will have a range of exhibit numbers or letters (e.g. Plaintiff No. 1: 1-99; Plaintiff No. 2: 100-199; Defendant: A-Z). Each exhibit must be separately identified. Subparts to an exhibit (e.g., 1A, 1B, etc.) must also be identified and listed separately. Each page of a multi-page exhibit must be consecutively paginated.

Applies to

Exhibits

All items referenced in the exhibit list must be exchanged and/or reviewed by counsel or the parties before the Final Status Conference.

All items so referred to in the Exhibit List must be exchanged and/or reviewed by each counsel or the parties prior to the FSC.

Applies to

Discovery material list

Each party must prepare a list of discovery material intended for use at trial, specifically identifying the date, document, page, and line for each item.

Each party must prepare a list of discovery material intended to be used at trial, including but not limited to interrogatories and requests for admissions and any responses thereto as well as deposition(s), all of which shall specifically identify the date, document, page and line.

Applies to

Deposition originals

Originals of depositions or discovery responses intended to be used at trial must be lodged with the Court at the time of trial.

If depositions or other discovery responses are intended to be used at trial, originals shall be lodged with the Court at the time of trial.

Applies to

Exhibit objections

Parties objecting to a listed exhibit on foundation or admissibility grounds must meet and confer before trial, and objections not raised in the meet and confer are deemed waived absent good cause.

Any party objecting to any listed exhibit, either as to foundation or admissibility, must first meet and confer prior to trial. Any objections not so discussed in the meet and confer shall be deemed waived except upon a showing of good cause.

Applies to

Statement of the case

Parties must submit a printed, short, non-argumentative joint written statement of the case to be read to the jury.

The parties shall submit a printed copy of the jointly prepared, short, non-argumentative written statement of the case to be read to the jury.

Applies to

Jury instructions

Jury instructions must include a jointly submitted packet of all requested, properly edited, unopposed instructions.

A jointly submitted packet of all requested and properly edited jury instructions to which there is no objection.

Applies to

Jury instructions

Each party must also submit its own specifically requested, properly edited instructions and insert them into the jointly submitted packet.

Each party shall also submit specifically requested and properly edited instructions not requested by the opposing counsel/party. These instructions shall be inserted into the aforementioned packet of the jointly submitted jury instructions, all to be considered and discussed by the Court at an appropriate time during the pendency of the trial.

Applies to

Special verdict form

A special verdict form is mandatory, must be jointly prepared in final form, and must be clear and direct to avoid juror confusion.

A special verdict form is mandatory and shall be jointly prepared in final form. Verdict forms shall be clear and direct to avoid any juror confusion.

Applies to

Trial binder

For jury trials, the parties must jointly prepare and lodge a tabbed 3-ring trial binder with a Table of Contents, with required documents organized under Tabs A-G (trial briefs, joint witness list, joint statement to the jury, joint exhibit list, jury instruction list, jury instructions, and verdict forms); trial binders are required for jury trials but discretionary for 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:

Applies to

Exhibit notebook

All exhibits must be placed in Exhibit Notebooks, and on the first day of trial the parties must jointly submit five identical copies (one per party, two for the Court, one for the witness stand).

All exhibits sought to be admitted by the parties shall be placed in Exhibit Notebooks. On the first day of trial, the parties are ordered to jointly submit five identical copies of the Exhibit Notebooks as follows: one for each party, two for the Court, and one for the witness stand.

Applies to

Ex parte application

Must include

proposed order

Ex parte applications filed without a proposed order may not be considered by the Court.

Please note that the Court may not consider ex parte applications submitted/filed without a proposed order.

Applies to

Trial brief

Trial briefs are optional for jury trials and mandatory for bench trials.

TRIAL BRIEFS. (optional for jury trials, mandatory for bench trials).

Applies to

Joint statement of case

Jury trials require a jointly prepared, short, non-argumentative written statement of the case to be read to the jury per Local Rule 3.25(g)(4).

A jointly prepared, short, non-argumentative written statement of the case to be read to the jury. Local Rule 3.25 (g)(4).

Applies to

Joint witness list

The joint witness list must identify all witnesses (other than impeachment/rebuttal) on one list with name, expert status, expected testimony, per-witness time estimates, and time totals.

All witnesses, other than those to be called exclusively for impeachment or rebuttal, must be identified on one list. Do not repeat the name of a witness who will be called by more than one party. The joint witness list must (1) identify each witness by name, (2) specify which witnesses are experts, (3) briefly describe the expected testimony, and (4) estimate the length of the direct, cross-examination and re-direct examination (if any) of each witness. In an additional column, the parties must total the time estimated for each witness’s testimony. At the bottom of the witness list, the parties must total the time for all witnesses on direct, cross, and redirect. Make realistic time estimates.

Applies to

Joint witness list

Witness scheduling issues and special requirements (including interpreters) must be identified on the witness list, and calling an unlisted witness (other than for impeachment/rebuttal) requires a prior good cause showing.

Identify all potential witness scheduling issues and special requirements, including interpreters on the witness list. Any party seeking to elicit testimony from a witness for other than impeachment or rebuttal who is not identified on the witness list must first make a showing of good cause to the court.

Applies to

Joint exhibit list

The joint exhibit list must identify all exhibits by number and description, include Objections, DATE ID'd, and DATE ADMITTED columns, and the parties must meet and confer to resolve authenticity and admissibility objections.

All exhibits, other than those to be used exclusively for impeachment or rebuttal, must be listed on the list, identified by a number and brief description. The parties/counsel shall meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit. The exhibit list must have a column labeled “Objections”. If any party has any objection to the admissibility of any exhibit, the objecting party must be identified, and the grounds for the objection must be set forth in the “Objections” column next to that exhibit. The exhibit list must have two columns on the far right labeled “DATE ID’d” and “DATE ADMITTED” in which the Court Clerk may note the dates of identification and admission of each exhibit.

Applies to

Joint proposed jury instructions

Parties must jointly prepare and file one list of proposed jury instructions organized in CACI numerical order with 5 columns.

The parties/counsel shall jointly prepare and file one list of proposed jury instructions, organized in CACI numerical order. The instruction list must have 5 columns

Applies to

Proposed jury instructions

Parties/counsel must jointly prepare a complete set of full-text proposed jury instructions with CACI edits, party names inserted, blanks filled, and brackets eliminated.

The parties/counsel shall jointly prepare a complete set of full text proposed jury instructions, editing all proposed CACI, inserting party name(s) and all other information, filling in all blanks, and eliminating all brackets and irrelevant bracketed language.

Applies to

Proposed special verdict form

The proposed special verdict form must be joint, with contested questions bracketed, and in a form easily used by the jury without unnecessary questions.

The proposed special verdict form must be joint. If the parties cannot agree on each question on a proposed verdict form, they must agree on what they can and put contested questions in brackets. Any proposed special verdict should be in form that is easily used by the jury, and which does not require the jury to answer unnecessary questions.

Applies to

Deposition designation chart

Parties intending to use deposition or former trial testimony (other than exclusively for impeachment or rebuttal) must meet and confer and jointly file a designation chart with seven specified columns.

If the parties/counsel intend to use deposition testimony or former trial testimony in lieu of any witness’s live testimony, other than exclusively for impeachment or rebuttal, the parties/counsel shall meet and confer and jointly prepare and file a chart with columns for each of the following: (1) the name of the witness; (2) the date and type of testimony (e.g., deposition or trial); (3) the line and page designations of the testimony requested for use, (4) any objections, (5) any related counter-designations by line and page, (6) any responses thereto, and (7) the Court’s ruling.

Applies to

Motion in limine

Motions in limine seeking to preclude inadmissible/prejudicial matters before the jury must be accompanied by a declaration complying with Local Rule 3.57 and Kelly v. New West Federal Savings.

Each motion in limine for the purpose of precluding the mention or display of inadmissible and prejudicial matters in the presence of the jury shall be accompanied by a declaration in compliance with the requirements of Rule 3.57 of the Local Rules and must comply with Kelly v. New West Federal Savings (1996) 49 Cal. App.4th 659, 670-71.

Applies to

Motion in limine

Each party must assign different, sequential numbers or letters to its motions in limine (e.g., Plaintiff 1-5, Defendant A-E), and oppositions must identify which motion they oppose.

The parties must assign different, sequential numbers or letters to their motions in limine and the party opposing the motion must identify to which motion the opposition applies. For example, Plaintiff’s motions in limine may be numbered 1-5; Defendant’s motions in limine may be lettered A-E; additional parties may use double numbers or letters or some other agreed-upon designation to avoid duplication and confusion.

Applies to

Joint motions in limine statement

If more than five motions in limine are filed collectively, the parties must file a joint document at least 4 court days before the final status conference describing each motion with a one-paragraph argument in support and a one-paragraph argument in opposition.

If the parties file, collectively, more than five (5) motions in limine, they must file a joint document at least four (4) court days before the final status conference that (a) describes the motion, (b) has a one- paragraph argument in support and (c) has a one-paragraph argument in opposition.

Applies to

Court trial submissions

For court trials, parties must submit trial briefs, a joint exhibit list, and a joint witness list, and comply with the deposition designation and motions in limine provisions.

The parties must submit trial briefs, a joint exhibit list, and a joint witness list, as described above. The parties must also comply with the provisions above concerning designation of deposition and former testimony and concerning motions in limine, if any.

Applies to

Trial readiness binder

The Trial Readiness Binder must contain conformed copies of the trial briefs, joint statement of the case, joint witness and exhibit lists, joint jury instructions (agreed and contested), joint verdict form, joint page-line designation chart, and motions (list continues beyond provided text).

The binder must contain conformed copies of the trial briefs, joint statement of the case. joint witness list, joint exhibit list, joint list of jury instructions, joint full-text jury instructions (organized as agreed-upon, plaintiff’s requested to which defendant objects and defendant’s requested to which plaintiff objects), joint verdict form, joint page-line designation chart, motions

Applies to

Daily settled statement

Parties must meet and confer about arranging a court reporter; if no court reporter is arranged, counsel must prepare a daily settled statement summarizing each day's witness testimony.

The parties must meet and confer to discuss whether they plan to have a court reporter transcribe the trial proceedings. In order to ensure a proper record for appellate purposes, if the parties do not arrange for a court reporter, then counsel for the parties will be required to prepare a daily settled statement summarizing witnesses’ testimony who have testified each day at trial.

Applies to

Ex parte application

Ex parte applications must affirmatively show irreparable harm, immediate danger, or another statutory basis for relief, and must demonstrate why the relief cannot be sought by other means such as a noticed motion or trial continuance.

There must be an affirmative showing of "irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte." (See Cal. Rules of Court, rule 3.1202 (c).) You will need to demonstrate to the court the reason(s) why you cannot seek the requested relief by other means, such as a noticed motion or continuance of the trial.

Applies to

Motion in limine

Must include

certificate of conference

Motions in limine must include a sworn declaration describing the meet-and-confer and the opposing party's position, and must be filed with timely statutory notice so the motion can be heard at the FSC.

motions in limine must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party, setting forth the opposing party’s position regarding the motions, and must be submitted with timely statutory notice so the motion in limine can be heard at the FSC. Motions in limine may be heard at the FSC unless the Court orders otherwise.

Applies to

Joint witness list

The parties must file a joint witness list showing each witness they actually intend to call, the estimated testimony time per witness (direct, cross, redirect), and a total time estimate at the end of the list.

The parties must submit a joint list of all witnesses each party actually intends to call. Next to each witness, indicate the total time estimated for that witness’s testimony (including direct, cross, and redirect). Make realistic time estimates. At the end of the list, total the time estimated for testimony.

Applies to

Joint witness list

Absent good cause, total estimated testimony hours on the joint witness list may not exceed the trial estimate given at the case management conference, including one day for jury selection and sufficient time for opening and closing arguments.

Absent good cause, the total number of hours listed for testimony shall not exceed the trial estimate given at the case management conference, including the allocation of one day of the trial estimate for jury selection and sufficient time for opening statements and closing arguments.

Applies to

Proposed jury instructions

Parties must submit a joint set of jury instructions plus each side's disputed instructions, providing the full text of all requested instructions rather than just a list.

The parties are to submit a joint set of instructions, plus a set of instructions from each side to which there are objections. The parties shall provide the full text of all requested instructions (not just a list).

Applies to

Proposed jury instructions

Before submitting proposed jury instructions, counsel must fill in blanks, make appropriate modifications, comply with SCLAC 3.170-3.171, and use CACI for form instructions.

Before submitting the instructions, counsel must fill in the blanks, make appropriate modifications, and comply with SCLAC 3.170 to 3.171. Use CACI for form instructions.

Applies to

Proposed verdict forms

Parties must meet and confer in advance and then file proposed general or special verdict forms using CACI model forms where applicable; the Court discourages competing proposed verdict forms.

The parties are to meet and confer in advance and then file proposed general or special verdict forms. Use CACI model verdict forms where applicable. The Court discourages submission of competing proposed verdict forms.

Applies to

Expert declaration ccp 2034 260

For any expert counsel intends to call at trial, counsel must present the Court and opposing counsel with a CCP section 2034.260 declaration stating the substance of the proffered opinion no later than the FSC.

As to experts that counsel intends to call at trial, no later than the FSC, Counsel shall present to the Court and opposing counsel a copy of the Code of Civil Procedure section 2034.260 declaration that states the substance of the proffered opinion.

Applies to

Motion for additional discovery

A motion for additional discovery beyond sections 2-6 must specifically identify the contemplated discovery and include a statement of the parties' respective positions.

Any motion seeking to commence any additional discovery beyond sections 2-6 shall specifically identify the contemplated additional discovery and shall include a statement of the parties' respective positions regarding the same.

Applies to

Customer complaint list

Defendant's list of substantially similar customer complaints may be in chart or spreadsheet format, must include VIN, repair-visit date, reporting location, and complaint text, and must exclude customers' personal identifying information.

The list provided by Defendant may be in the chart or spreadsheet format, and shall include the VIN, date of repair visit, dealership or other reporting location, and text of the other customers' reported complaint, but shall not include the other customers' names, addresses, phone numbers, e-mail addresses, or other personal identifying information

Applies to

Request for court reporter

Must include

form fw 020

Parties with fee waivers must file Form FW-020 to request official court reporter before hearing/trial.

A party who has received a fee waiver pursuant to CRC 3.55(7) may request an official court reporter by filing form FW-020 https://selfhelp.courts.ca.gov/jcc-form/FW-020 before the hearing or trial (See CRC 2.956(c)).

Applies to

Memorandum

IDC memoranda first paragraph must include neutral dispute statement and 1-3 sentence description per party position.

The first paragraph shall be formatted as follows: (1) a neutral statement of the dispute; and (2) one to three sentences describing (not arguing) each party’s position.

Applies to

Ex parte application

Ex parte applications must show irreparable harm/immediate danger/statutory basis and why other relief methods are not feasible.

There must be an affirmative showing of "irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte." (See Cal. Rules of Court, rule 3.1202 (c).) You will need to demonstrate to the court the reason(s) why you cannot seek the requested relief by other means, such as a noticed motion or continuance of the trial.

Applies to

Motion in limine

Must include

statutory notice, sworn declaration, certificate of conference

Motions in limine must include sworn declaration of conference with opposing party and their position, plus statutory notice.

motions in limine must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party, setting forth the opposing party’s position regarding the motions, and must be submitted with timely statutory notice so the motion in limine can be heard at the FSC.

Applies to

Cmc statement

Parties must file a CMC statement on Judicial Council Form CM-110 within five days of the case management conference hearing.

The parties are to (1) meet and confer—in person or by telephone—no later than 30 days before the hearing, and (2) file a CMC statement on Judicial Council Form CM-110 within five (5) days of the hearing.

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include the notice in the declaration and present a proposed order with the moving papers.

The notice must be included in the declaration and a proposed order must be presented with the moving papers.

Applies to

Joint statement of witness testimony

Parties without a court reporter must prepare a joint statement of each day's witness testimony at the close of the session and lodge it with the Court the next morning before proceedings resume — no exceptions.

Parties who do not provide a court reporter for trial are directed to meet at the close of each session and prepare a joint statement of the witness testimony presented that day. The joint statement must be lodged with the Court the next morning before proceedings resume. No exceptions.

Applies to

Trial brief

Each party must file a trial brief identifying the disputed claims and defenses, major legal issues with supporting authorities, relief and damages calculation, and any other information assisting the court at trial.

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.

Applies to

Joint witness list

Parties' counsel and self-represented parties must jointly prepare and file a list of all trial witnesses, excluding impeachment and rebuttal witnesses (Local Rule 3.25(g)(5)).

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.

Applies to

Joint witness list

The joint witness list must contain seven specified columns (witness name/expert status/accommodations, calling party, expected testimony, direct/cross/total time estimates in hours) plus a grand total, and any witness not listed is subject to being excluded.

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 hours). At the end of the joint witness list, the parties and any self-represented parties shall add up the estimated times for all witnesses' testimony and state the grand total in the last column. Any witness who is not included on the joint witness list is subject to being excluded from

Applies to

Joint exhibit list

Counsel and self-represented parties must jointly prepare and file an exhibit list stating eight specified items for each trial exhibit and must meet and confer to resolve authenticity and admissibility objections.

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.

Applies to

Joint statement of case

For jury trials, the parties must jointly prepare and file a brief written statement of the case for the court to read to the jury.

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).)

Applies to

Joint list of proposed jury instructions

For jury trials, the parties must jointly prepare and file a list of proposed jury instructions stating six specified items for each instruction.

For jury trials, the parties' counsel and any self-represented parties shall work together to prepare and file a joint list of proposed jury instructions (in the format set forth below) which states, as to each proposed jury instruction: (1) the jury instruction number (listed in numerical order), (2) the title of the jury instruction, (3) the party requesting the jury instruction, (4) whether the jury instruction is agreed upon or contested, (5) a concise statement of any objection, and (6) whether the jury instruction was given by the court ("Joint List of Proposed Jury Instructions").

Applies to

Proposed jury instructions

For jury trials, the parties must jointly prepare a complete set of full-text proposed jury instructions, editing CACI instructions, inserting party names, and removing blanks and irrelevant material.

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.

Applies to

Proposed verdict form

For jury trials, parties must jointly file a proposed verdict form acceptable to all parties, or, if they cannot agree, each party must separately file a proposed verdict form.

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 the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

Applies to

Joint chart of page and line designations

Parties intending to use deposition or former trial testimony must meet and confer and jointly prepare and file a Joint Chart of Page and Line Designations.

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").

Applies to

Motion in limine

Motions in limine must be accompanied by declarations that comply with Los Angeles County Court Rule 3.57(a).

The parties' counsel and any self-represented parties shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and file declarations that comply with the requirements of Los Angeles County Court Rule 3.57, subdivision (a).

Applies to

Trial binder

The Trial Binder must contain tabbed sections for Trial Briefs, Joint Witness List, Joint Exhibit List, Joint Statement to the Jury, Jury Instructions, Verdict Forms, Deposition Designation Chart, Operative Pleadings, and Motions in Limine (unless too voluminous for the binder).

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 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). Tab J: Motions in Limine, unless they are too voluminous and require their own binder.

Applies to

Customer complaint list

The list of substantially similar customer complaints must be in chart or spreadsheet form including VIN, repair visit date, location, and complaint text, and must exclude all other customers' personal identifying information.

The list provided by defendant may be in the chart or spreadsheet format, and shall include the VIN, date of repair visit, dealership or other reporting location, and text of the other customers' reported complaint, but shall not include the other customers' names, addresses, phone numbers, e-mail addresses, or other personal identifying information.

Applies to

Document production

Both plaintiff and defendant must serve a verification along with the documents they produce.

Plaintiff and defendant shall serve verification with the documents they produce.

Applies to

Joint case management conference statement addendum

All parties must meet and confer in person or by telephone and respond to the addendum's questions, stating their respective positions.

You are ordered to meet and confer in person or by telephone and to respond to the following questions, stating your respective positions.

Applies to

Case management conference addendum

The case management conference addendum must include a signed certification that the signer is fully familiar with the case, prepared to discuss discovery, ADR, and other addendum issues, and possesses authority (including written party authority where required) to enter stipulations at the initial case management conference.

l am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this addendum, and will possess the authority to enter into stipulations on these issues at the time of the initial case management conference, including the written authority of the party where required.

Applies to

Case management conference addendum

The case management conference addendum must bear the typed or printed name and signature of the party or attorney, with two signature blocks provided.

(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)

Applies to

Discovery production

Parties must serve verification with all produced discovery documents.

Plaintiff and defendant shall serve verification with the documents they produce.

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include a proposed order with the moving papers.

the notice must be included in the declaration and a proposed order must be presented with the moving papers.

Applies to

Joint case management conference statement addendum

Joint Case Management Conference Statement Addendum must include a statement that the signer is familiar with the case and has authority to enter into stipulations.

l am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this addendum, and will possess the authority to enter into stipulations on these issues at the time of the initial case management conference, including the written authority of the party where required.

Applies to

Summary judgment papers

In summary judgment papers, every factual statement must be supported by a citation to the supporting declaration(s) and/or exhibit(s) placed next to the statement; citing only the 'statement of undisputed facts' is not permitted.

When a factual claim is made in these documents, just as is the case with regard to all other kinds of motions and responsive papers, a citation to the declaration(s) and/or exhibit(s) supporting that claim assertion must be set forth next to the factual statement, NOT A REFERENCE TO THE "STATEMENT OF UNDISPUTED" FACTS WHICH HAS THE EFFECT OF DIRECTING THE COURT TO SEARCH ONE SOURCE IN ORDER TO GET TO ANOTHER SOURCE FOR EVIDENTIARY SUPPORT FOR THE FACTS IN ISSUE!

Applies to

Original order or judgment

Moving parties must lodge the original order or judgment they want signed no later than the motion hearing (or as requested by the court after trial).

The Court asks that all moving parties lodge the original order or judgment that they wish the Judge in Department 636 to sign no later than the hearing set on a motion or as requested by the court after trial.

Applies to

Original order or judgment

The lodged original order must not say 'proposed' in the caption and must not have a proof of service attached to it.

It should not say "proposed" in the caption and should not have a proof of service attached to it.

Applies to

Motion

Must include

proposed order

A proposed order must be included in the package of moving papers and served upon the parties.

A "proposed order" should continue to be included in the package of moving papers and served upon the parties.

Applies to

Waiver of participation

Parties/counsel of record must participate by phone unless a waiver of participation is filed earlier.

of record must be on the phone unless a waiver of participation is earlier filed.

Applies to

Exhibit list

Counsel must agree on allocated blocks of exhibit numbers (per LASC Local Rule 3.53), and the exhibit list must include the exhibit number and a brief description of each exhibit.

Counsel are to agree on a block of numbers to be allocated to each party for exhibits. (See LASC Local Rule 3.53) The exhibit list shall include the exhibit number and a brief description of the exhibit.

Applies to

Special verdict forms

The parties must meet and confer and file any special verdict forms.

The parties are ordered to meet and confer and file any special verdict forms.

Applies to

Proposed special verdict forms

If the parties do not agree, each party must submit its own proposed special verdict (or special fact finding) forms accompanied by points and authorities supporting the request.

If no agreement is reached, each party is to submit their own proposed special verdict (or special fact finding) forms along with points and authorities supporting what is requested.

Applies to

Original order for signature

Original orders/judgments submitted for signature in Dept 636 must not be marked 'proposed' and must not have a proof of service attached.

The Court asks that all moving parties lodge the original order or judgment that they wish the Judge in Department 636 to sign no later than the hearing set on a motion or as requested by the court after trial. It should not say “proposed” in the caption and should not have a proof of service attached to it. Do not put “Proposed” on that original order or judgment, and most importantly, DO NOT ATTACH A PROOF OF SERVICE TO THE ORIGINAL!

Applies to

Motion

Must include

proposed order

Proposed orders must be included in the moving papers package and served on parties.

A “proposed order” should continue to be included in the package of moving papers and served upon the parties.

Applies to

Motion in limine

Must include

certificate of conference

Motions in limine seeking to restrict opposing counsel's conduct require prior contact with opposing counsel confirming intent to engage in the conduct.

No motion in limine is to be filed asking the court to order that opposing counsel not do “x,” “y,” or “z,” unless that opposition attorney has first been contacted and stated that they intend to do what the moving party wants to prevent.

Applies to

Notice of settlement

Notice of settlement must not be filed until all parties have signed the settlement agreement.

BUT DO NOT FILE A NOTICE OF SETTLEMENT UNTIL ALL PARTIES ON BOTH SIDES HAVE SIGNED THE SETTLEMENT AGREEMENT.

Applies to

Brief

Motions and briefs must include evidentiary citations next to factual claims, not just references to separate statement of undisputed facts.

When a factual claim is made in these documents, just as is the case with regard to all other kinds of motions and responsive papers, a citation to the declaration(s) and/or exhibit(s) supporting that claim assertion must be set forth next to the factual statement, NOT A REFERENCE TO THE “STATEMENT OF UNDISPUTED” FACTS WHICH HAS THE EFFECT OF DIRECTING THE COURT TO SEARCH ONE SOURCE IN ORDER TO GET TO ANOTHER SOURCE FOR EVIDENTIARY SUPPORT FOR THE FACTS IN ISSUE!

Applies to

Trial brief

Trial briefs are mandatory in all cases and must include seven specified elements, including facts/issues, elements and burden of proof, stipulations, anticipated legal and evidentiary issues, relief and damages calculations, a joint list of jury instructions, and other helpful information.

TRIAL BRIEFS – Trial Briefs are mandatory in all cases and must include: (1) a brief description of the facts and the claims and defenses presented and the issues to be decided; (2) the elements and burden of proof for each of the cause(s) of action; (3) a brief statement of ultimate facts or issues to which you will stipulate; (4) a list of major legal and evidentiary issues anticipated with succinct points and authorities supporting and defending the issues; (5) a brief statement of the relief claimed, including a succinct breakdown of the elements of damages claimed, and calculations of damages sought (do not hesitate to use bullet points); (6) a joint list of jury instructions; and (7) any further information the parties believe may assist the Court in ruling upon trial objections or matters that may arise during trial.

Applies to

Motion in limine

Must include

certificate of conference

Motions in Limine must be in writing, numbered, filed and served per Local Rule 3.25(f)(2), and accompanied by a declaration representing that the motion was discussed with opposing counsel, or the motion will be summarily denied; boilerplate or form motions are disfavored.

Motions in Limine must be in writing, numbered, and shall be filed and served on opposing parties in accordance with Local Rule 3.25(f)(2). The motion must be accompanied by a declaration that includes, among other items, a representation that the motion has been discussed with opposing counsel. If not, the motion will be summarily denied. Boilerplate or form motions are disfavored.

Applies to

Joint statement of the case

In jury trials, the parties must prepare and file a brief, factual joint written statement of the case for the Court to read to the jury.

JOINT STATEMENT OF THE CASE – For jury trials, the parties shall prepare and file a joint written statement of the case for the Court to read to the jury. The Joint Statement of the Case should be brief and factual.

Applies to

Joint witness list

The parties must file a joint witness list identifying all intended witnesses (excluding impeachment and rebuttal), with each witness's name, expert status, and estimated direct, cross, and re-direct examination lengths.

JOINT WITNESS LIST – The parties shall prepare and file a joint witness list identifying all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. The joint witness list will identify each witness by name, specify which witnesses are experts, estimate the length of direct examination, cross-examination, and re-direct examination of each,

Applies to

Joint exhibit list

Parties must file a joint exhibit list organized with columns identifying the exhibit, offering party, stipulation to authenticity/admissibility, date identified, and date admitted.

The parties shall prepare and file a joint exhibit list organized with columns identifying: (1) the exhibit, (2) which party is offering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) the date on which the exhibit was identified, and (5) the date on which the exhibit was admitted.

Applies to

Joint exhibit list

Parties must meet and confer before filing the joint exhibit list and note stipulations, or specify all objections, in the respective column.

Prior to filing the joint exhibit list, the parties shall meet and confer to determine whether they will stipulate to the authenticity and/or admissibility of each exhibit or whether there are objections to any exhibit. If there are stipulations, the parties shall note that in the respective column. If not, the objecting party shall specify all objections in the respective column.

Applies to

Exhibit binder

Parties must supply an exhibit binder to each opposing party, with non-documentary exhibits represented by a simple written description.

The parties must also supply an exhibit binder to each opposing party. Non-documentary exhibits shall be represented in the binder with a simple written description.

Applies to

Jury instructions

Parties must file a joint list of requested jury instructions with fully completed copies in numerical order, file disputed instructions separately identifying the requesting party, and meet and confer on a final set no later than two days before the conclusion of evidence.

The parties shall prepare and file a joint list of all jury instructions requested and a copy of all requested instructions fully filled out, organized in numerical order. Those instructions not agreed upon should be filed separately and the party making the request should be identified. Not later than two days before the conclusion of evidence, the Court will require the parties to meet and confer to create a final set of instructions.

Applies to

Voir dire questions

Parties must prepare and file a joint list of voir dire questions for the Court's questioning and may independently question prospective jurors afterward.

The Court will question the prospective jurors during voir dire. The parties shall prepare and file a joint list of questions to be asked by the Court. The parties will have an opportunity to independently question the prospective jurors following the Court’s questioning.

Applies to

Verdict form

Parties must file a joint proposed general or special verdict form; if they cannot agree, each party must separately file a proposed verdict form.

The parties shall prepare and file a joint proposed general verdict form or special verdict form. The parties are urged to agree on a verdict form. If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

Applies to

Joint trial binder

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

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.

Applies to

Trial record

Parties must either provide a court reporter for court and jury trials or submit daily agreed statements/proposed settled statements during trial.

YOU MUST PROVIDE A COURT REPORTER FOR TRIAL (COURT AND JURY TRIAL) OR SUBMIT DAILY AGREED STATEMENTS / PROPOSED SETTLED STATEMENTS during a trial.

Applies to

Notice of related cases

A notice of related cases complying with California Rules of Court 3.300 must be timely filed in each related case.

The Court requires timely compliance with Cal. Rules of Court 3.300 Re: Notice of Related Cases. The Notice must be filed in each related case.

Applies to

Case management statement

Counsel must submit case management statements per CRC 3.725, and failure to comply with related rules may result in monetary sanctions and/or delay in trial setting.

Counsel must comply with their obligation to submit case management statements pursuant to rule 3.725 of the California Rules of Court. Failure to comply with the Cal. Rules of Court., rules 3.722, 3.724, 3.727 and 3.728, Los Angeles County Superior Court Rules 3.24 and 3.25, and/or this court's scheduling orders may result in monetary sanctions and/or delay in trial setting.

Applies to

Request for court reporting services

A fee-waiver party's request for an official court reporter must be made on local form LASC LACIV 269 (Request for Court Reporting Services by a Party with a Fee Waiver).

The request must be made by using the local form (LASC LACIV 269).

Applies to

Statement of the case

The Statement of the Case must be jointly prepared by the parties, short and non-argumentative for reading to the jury, signed by all parties, and filed with the Court.

Statement of the Case: must be prepared jointly by the parties. It should be a short, non-argumentative written statement of the case to be read to the jury. It must be signed by all parties and filed with the Court.

Applies to

Joint witness list

The joint witness list must include witnesses' names, time estimates for direct and cross-examination, and interpreter needs, and must be signed by all parties and filed with the Court.

witnesses' names, time estimates for direct and cross-examination, and whether the witnesses will be assisted by an interpreter. The joint witness list must be signed by all parties filed with the Court.

Applies to

Joint exhibit list

The joint exhibit list must be prepared jointly in chart format with columns for exhibit title/number, stipulation status, objections, and the Court's trial notation, and must be signed by all parties and filed with the Court.

Exhibit list: must be prepared jointly by the parties. It should be prepared in chart format with each exhibit identified by title and its assigned exhibit number. Additional columns should indicate whether the exhibit will be admitted by stipulation, authenticated by stipulation, or challenged with objections, which shall be set forth in a column for objections. A final column should be included on the right for the Court's notation of whether the exhibit was admitted at trial. The joint exhibit list must be signed by all parties and filed with the Court.

Applies to

Depositions

All original or certified copies of depositions must be lodged with the Court before trial begins.

Depositions: All original/certified copy of depositions must be lodge with the Court prior to the beginning of trial.

Applies to

Proposed jury instructions

The joint list of proposed jury instructions must be prepared jointly in chart format showing proponents and opponents of each instruction, and must be signed by all parties and filed with the Court.

List of proposed jury instructions: must be prepared jointly by the parties. It should be prepared in chart format to include all CACI and special jury instructions that are jointly proposed by the parties as well as those that are proposed by only some of the parties but opposed by another party. A column in the chart must indicate the proponent(s) and opponent(s) of each proposed instruction. A final column should be included on the right of the Court's notation of whether the instruction was given at trial. The joint list of jury instructions must be signed by all parties and filed with the Court.

Applies to

Trial binder

Proposed jury instructions must be included in the trial binder as a jointly submitted packet in the proper format for presentation to the jury.

Proposed Instructions: shall be included in the trial binder. These should include a jointly submitted packet of all requested and properly edited CACI or special instructions that are agreed to or not. The instructions shall be submitted in the proper format for presentation to the jury.

Applies to

Verdict form

The verdict form must be jointly prepared by the parties; if they cannot agree, the Court will provide a general verdict form to the jury.

Verdict Form: must be jointly prepared by the parties. If the parties cannot agree on joint verdict forms, then the Court will provide a general verdict form to the jury.

Applies to

Trial binder

The trial binder must include all operative pleadings, including operative complaints, cross-complaints, and the operative answers.

All operative pleadings: must be included in the trial binder. This includes the operative complaints and cross-complaints and the operative answers thereto.

Applies to

Motion in limine

Motions in limine must be in writing.

All motions in limine must be in writing and must be filed and served at least 10 court days before the FSC.

Applies to

Opposition

Oppositions to motions in limine must be in writing.

Any opposition to a motion in limine must be in writing and must be filed and served at least 5 court days before the FSC.

Applies to

Reply brief

Reply briefs on motions in limine must be in writing and properly filed and served.

Reply briefs must be in writing and properly filed and served.

Applies to

Trial checklist

The parties' trial submission must include a brief outline of the nature of the case, proposed voir dire questions and procedures, witness names, witness/attorney scheduling issues, anticipated evidentiary or legal issues, party stipulations, and any other anticipated trial issues.

ii. A brief outline of the nature of the case; iii. Proposed questions and voir dire procedures; iv. The witness names to be read to the jury; v. Any witness or attorney scheduling issues; any witness issues (e.g., availability, need for interpreters, etc.); Any anticipated evidentiary or other legal issues; vi. Any party stipulations; and any other trial issues that the parties reasonably can anticipate.

Applies to

Transcript of recordings

Parties must provide transcripts of recordings under Cal. R. Ct. 2.1040, and a party receiving the transcript before announcing ready waives any objection to its accuracy unless raised at the first trial appearance.

The parties shall comply with Cal. R. Ct. 2.1040, requiring the provision of a transcript of various recordings. The Court shall deem that the party receiving the transcript before announcing "ready" waives any objection to the accuracy of the transcript unless raised at the first trial appearance before this Court.

Applies to

Case management statement

Case management statements must be submitted per Cal. Rules of Court 3.725.

Counsel must comply with their obligation to submit case management statements pursuant to rule 3.725 of the California Rules of Court.

Applies to

Notice of related cases

Notice of Related Cases must be filed in each related case per Cal. Rules of Court 3.300.

The Court requires timely compliance with Cal. Rules of Court 3.300 Re: Notice of Related Cases. The Notice must be filed in each related case.

Applies to

Trial brief

Must include

certificate of service

Trial briefs must be signed, filed, and served on all parties.

The briefs must be signed, filed with the Court and served on all parties.

Applies to

Request for court reporting services

Court reporter requests with fee waiver must use form LASC LACIV 269, filed 10 calendar days before hearing.

The Request for Court Reporting Services by a Party with a Fee Waiver should be filed at least ten calendar days before the hearing or trial for which the reporter is requested. The request must be made by using the local form (LASC LACIV 269).

Applies to

Trial setting conference joint filings

Parties must meet and confer at least 14 calendar days before the TSC and jointly file a statement of the issues to be tried, a witness list with time estimates, and a report on the status of discovery at least 7 calendar days before the hearing.

Counsel and/or self-represented parties are ordered to meet and confer in person or by video at least 14 calendar days in advance of the TSC and, at least 7 calendar days in advance of the hearing, jointly file (1) a statement of the issues to be tried, (2) a witness list with time estimates, and (3) a report on the status of discovery.

Applies to

Joint witness list

The joint witness list must identify each witness by name, designate experts, estimate direct/cross/re-direct time with totals, and absent good cause may not exceed the CMC trial estimate, including scheduling issues and interpreter needs.

The joint witness list must identify each witness by name, specify which witnesses are experts, and estimate the length of the direct, cross examination and re-direct examination (if any) of each witness. In an additional column, the parties must total the time estimated for each witness's testimony. At the bottom of the witness list, the parties must total the time for all witnesses on direct, cross, and redirect. Make realistic time estimates. Absent good cause, the total number of hours listed for testimony should not exceed the trial estimate given at the CMC, including an allocation of one day for jury selection and one day for instructions, closing arguments, and deliberations. Identify all potential witness scheduling issues and special requirements, including interpreters on the witness list.

Applies to

Exhibit list

The exhibit list must identify each exhibit by number and brief description, include an 'Objections' column with objecting party and grounds, and far-right 'DATE ID'd' and 'DATE ADMITTED' columns, after a meet and confer on admissibility objections.

impeachment or rebuttal, must be listed on the list, identified by a number and brief description. The parties/counsel shall meet and confer in an effort to resolve objections to the admissibility of each exhibit. The exhibit list must have a column labeled "Objections". If any party has any objection to the admissibility of any exhibit, the objecting party must be identified, and the grounds for the objection must be set forth in the "Objections" column next to that exhibit. The exhibit list must have two columns on the far right labeled "DATE ID'd" and "DATE ADMITTED" in which the Court Clerk may note the dates of identification and admission of each exhibit.

Applies to

Jury instruction list

Parties must jointly file one list of proposed jury instructions in CACI numerical order with five specific columns for CACI number, title, proposer, objector, and court ruling.

The parties/counsel shall jointly prepare and file one list of proposed jury instructions, organized in CACI numerical order. The instruction list must have 5 columns labeled: "CACI #," "Title," "Proposed by," "Objections By," and "Given." If all parties agree on an instruction, indicate "joint" in the "Proposed By" column, and leave the "Objections By" column blank. Otherwise, indicate the party proposing the instruction in the "Proposed By" column and the party objection to the instruction in the "Objections By" column. Leave the "Given" column blank for the Court to decide whether the instruction was given.

Applies to

Jury instructions

Parties must jointly prepare a complete set of full text proposed CACI jury instructions with party names inserted, blanks filled, and all brackets and irrelevant bracketed language eliminated.

The parties/counsel shall jointly prepare a complete set of full text proposed jury instructions, editing all proposed CACI, inserting party name(s) and all other information, filling in all blanks, and eliminating all brackets and irrelevant bracketed language.

Applies to

Proposed verdict form

The proposed special verdict form must be joint, easy for the jury to use without unnecessary questions, submitted electronically in Word on a thumb drive, or the Court may use a general verdict form.

The proposed special verdict form must be joint. Any proposed special verdict should be in form that is easily used by the jury, and which does not require the jury to answer unnecessary questions. Submit an electronic version of the verdict form in Word on a thumb drive. Failure of the parties to agree on a proper special verdict form may result in the Court's using a general verdict form.

Applies to

Page line designation chart

Parties must meet and confer and jointly file a designation chart with five required columns before using deposition or former trial testimony in lieu of live testimony (except purely for impeachment or rebuttal).

If the parties/counsel intend to use deposition testimony or former trial testimony in lieu of any witness's live testimony, other than exclusively for impeachment or rebuttal, the parties/counsel shall meet and confer and jointly prepare and file a chart with columns for each of the following: 1) the line and page designations of the deposition or former testimony requested for use, 2) objections, 3) counter-designations, 4) any responses thereto, and 5) the Court's ruling.

Applies to

Motion in limine

Motions in limine seeking to preclude inadmissible or prejudicial matters before the jury must be accompanied by a declaration complying with Local Rule 3.57 and Kelly v. New West Federal Savings.

Each motion in limine for the purpose of precluding the mention or display of inadmissible and prejudicial matters in the presence of the jury shall be accompanied by a declaration in compliance with the requirements of Rule 3.57 of the Local Rules and must comply with Kelly v. New West Federal Savings (1996) 49 Cal. App.4th 659, 670-71.

Applies to

Motion in limine

Parties must assign different, sequential numbers or letters to their motions in limine to avoid duplication (e.g., Plaintiff numbered, Defendant lettered).

The parties must assign different, sequential numbers or letters to their motions in limine. For example, Plaintiff's motions in limine may be numbered 1-5; Defendant's motions in limine may be lettered A-E; additional parties may use double numbers or letters or some other agreed-upon designation to avoid duplication and confusion.

Applies to

Joint motion in limine document

When more than five motions in limine are filed collectively, the parties must file a joint document describing each motion with one-paragraph support and opposition arguments.

If the parties file, collectively, more than five (5) motions in limine, they must file a joint document at least four (4) court days before the final status conference that (a) describes the motion, (b) has a one-paragraph argument in support and (c) has a one-paragraph argument in opposition.

Applies to

Trial briefs and joint lists

Parties must submit trial briefs, a joint exhibit list, and a joint witness list as described earlier in the order.

The parties must submit trial briefs, a joint exhibit list, and a joint witness list, as described above.

Applies to

Trial readiness binder

A Trial Readiness Binder containing conformed copies of specified trial documents must be presented to the Court at the Final Status Conference.

A Trial Readiness Binder must be presented to the Court at the FSC. The binder must contain conformed copies of the trial briefs, joint statement of the case. joint witness list, joint exhibit list, joint list of jury instructions, joint full-text jury instructions, joint verdict form, joint page-line designation chart, motions in limine, and current operative pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).

Applies to

Daily settled statement

Parties must meet and confer about court reporter arrangements, and if none is arranged, counsel must prepare daily settled statements summarizing each day's witness testimony.

The parties must meet and confer to discuss whether they plan to have a court reporter transcribe the trial proceedings. In order to ensure a proper record for appellate purposes, if the parties do not arrange for a court reporter, then Counsel for the parties will be required to prepare a daily settled statement summarizing witnesses' testimony who have testified each day at trial.

Applies to

Revised exhibit list

At the end of trial, counsel must prepare and lodge a revised exhibit list reflecting only admitted exhibits, which will be provided to the jury during deliberations.

At the end of the trial, counsel will be required to prepare and lodge with the court a revised exhibit list that reflects only those exhibits that have been admitted. The revised exhibit list will be provided to the jury during their deliberations.

Applies to

Ex parte application

An ex parte application must affirmatively show irreparable harm, immediate danger, or another statutory basis for ex parte relief under CRC 3.1202(c).

PLEASE CAREFULLY REVIEW WHETHER YOU HAVE A PROPER BASIS TO SEEK EX PARTE RELIEF. There must be an affirmative showing of "irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte." (See Cal.Rules of Court, rule 3.1202 (c).)

Applies to

Ex parte application

Ex parte applicants must demonstrate why the requested relief cannot be obtained by other means, such as a noticed motion or continuance of the trial.

You will need to demonstrate to the court the reason(s) why you cannot seek the requested relief by other means, such as a noticed motion, or continuance of the trial.

Applies to

Motion in limine

Must include

certificate of conference

Motions in limine must comply with SCLAC Rule 3.57's mandatory declaration and meet and confer requirements, and boilerplate or form motions are disfavored.

Compliance with SCLAC Rule 3.57, including the declaration and meet and confer requirements, is mandatory. Boilerplate or form motions in limine are disfavored.

Applies to

Joint witness list

Parties must submit a joint witness list with per-witness time estimates (direct, cross, redirect) and a total estimated testimony time at the end.

The parties must submit a joint list of all witnesses each party actually intends to call. Next to each witness, indicate the total time estimated for that witness's testimony (including direct, cross, redirect). Make realistic time estimates. At the end of the list, total the time estimated for testimony.

Applies to

Joint witness list

Absent good cause, total listed testimony hours cannot exceed the trial estimate from the case management conference, including one day for jury selection and time for opening and closing arguments.

Absent good cause, the total number of hours listed for testimony shall not exceed the trial estimate given at the case management conference, including the allocation of one day of the trial estimate for jury selection and sufficient time for opening statements and closing arguments.

Applies to

Deposition designation chart

Parties using deposition or former trial testimony must meet and confer and jointly file a chart containing designations, objections, counter-designations, responses, and the Court's ruling.

If the parties/counsel intend to use deposition testimony or former trial testimony in lieu of any witness's live testimony, the parties/counsel shall meet and confer and jointly prepare and file a chart with columns for: 1) the line and page designations of the deposition or former testimony requested, 2) objections, 3) counter-designations, 4) any responses to the objections, and 5) the Court's ruling.

Applies to

Jury instructions

Jury instructions must be submitted in full text (not just a list), with blanks filled in and modifications made in compliance with SCLAC 3.170-3.171, using CACI for form instructions.

The parties shall provide the full text of all requested instructions (not just a list). Before submitting the instructions, counsel must fill in the blanks, make any appropriate modifications, and comply with SCLAC 3.170 - 3.171. Use CACI for form instructions.

Applies to

Special verdict form

The Court requires a single, finalized special verdict form, initialed by all counsel, using CACI model forms where applicable.

Use CACI model verdict forms where applicable. The Court requires a single, finalized special verdict form, initialed by all counsel, for use by the jury.

Applies to

Daily proceedings summary

If no court reporter is used at trial, the parties must jointly prepare a daily proceedings summary and lodge it in the courtroom the next morning before proceedings resume.

If no court reporter is used, the parties must jointly prepare a summary of the day’s proceedings, and lodge it in the courtroom the next morning before proceedings resume.

Applies to

Motion

Must include

proposed order

Proposed order required when requesting multiple motions to be heard on one date.

If you have motions reserved under the Court Reservation System (CRS) for multiple hearing dates, please submit a proposed order for the motions to be heard on one date.

Applies to

Evidentiary objections

Evidentiary objections filed in connection with a motion for summary judgment or summary adjudication must comply with CRC, rule 3.1354.

Evidentiary objections. Counsel filing evidentiary objections in connection with a motion for summary judgment or summary adjudication shall comply with CRC, rule 3.1354.

Applies to

Daily summaries of testimony

In trials without a court reporter or electronic recording, counsel must provide the court with daily summaries of testimony.

For trials in which there is no court reporter or electronic recording, counsel are required to provide the court with daily summaries of testimony.

Applies to

Recording transcript

Parties must prepare transcripts of all recordings they plan to introduce as exhibits, per CRC rule 2.1040.

California Rules of Court (“CRC”), rule 2.1040 requires the parties to prepare transcripts of all recordings counsel plan to introduce as an exhibit.

Applies to

Recording transcript

The proponent of a recording must bring the transcript to the Final Status Conference so the Court can rule on any objections.

The proponent of the recording must bring their transcripts to the FSC so the Court may rule on any objections to the transcripts.

Applies to

Recording transcript

Counsel must bring copies of recording transcripts to distribute to the jury and alternates.

Counsel is responsible for bringing copies of the transcript to pass out for the jury and alternates.

Applies to

Witness list

Counsel must deliver a written witness list to the clerk each morning listing that day's witnesses with their full correct names and the order in which they will be called.

Each morning, counsel must give the clerk a written list of witnesses to be called that day, their full names with correct spellings, and the order in which they will be called.

Applies to

Daily proceedings summary

If no court reporter is used at trial, the parties must jointly prepare a daily proceedings summary including detailed witness testimony and lodge it the next morning before proceedings resume.

The Court strongly encourages the parties to arrange for a court reporter for trial. If no court reporter is used, the parties must jointly prepare a summary of the day's proceedings, including a detailed summary of any witness testimony, and lodge the daily summary the next morning before proceedings resume.

Applies to

Document production

Both plaintiff and defendant must serve verifications together with the documents they produce in discovery.

Plaintiff and defendant shall serve verifications with the documents they produce.

Applies to

Jury instructions

Each jury instruction must display the CACI number and title at the top of the instruction.

The CACI Number and Title should be at the top of each instruction.

Applies to

Jury instructions

Counsel must fill in the blanks and remove unnecessary brackets in CACI instructions before submitting them.

Counsel are to fill in the blanks and to remove unnecessary brackets in the CACI instructions.

Applies to

Non caci proposed jury instructions

Proposed Non-CACI jury instructions must include case citations supporting the request for their inclusion.

For Non-CACI instructions, the proposed instructions must contain case citations that support the party's request for inclusion of the instruction.

Applies to

Meet and confer declaration

If counsel cannot secure another party's participation in the meet and confer, counsel must file a declaration detailing the efforts taken to initiate meet and confer discussions.

If counsel cannot secure the participation of another party/counsel in the meet and confer discussions, counsel must (1) file a declaration detailing the efforts taken to initiate meet and confer discussions, and (2) file a separate set of Trial Readiness Documents and Trial Exhibits.

Applies to

Fsc trial notebook

The FSC Trial Notebook must include a table of contents with Section A (Trial Briefs), Section B (Motions in Limine), and Section C (Joint Statement of the Case).

with a table of contents that includes the following: Section A: Trial Briefs Section B: Motions in Limine Section C: Joint Statement of the Case

Applies to

Trial brief

Each party must file a trial brief, unless the parties instead file a joint trial brief.

Each party must file a trial brief, or the parties may file a joint trial brief if they wish.

Applies to

Trial brief

Trial briefs (joint or separate) must include five elements: description of claims/defenses, major legal issues with authority, major evidentiary issues with authority, detailed relief sought with damages breakdown, and other helpful information.

Whether jointly filed by multiple parties, or separately filed by individual parties, the trial brief must include: (1) A brief description of the claims and defenses to be presented at trial; (2) A brief discussion of the major legal issues supported by relevant authority; (3) A brief discussion of any major evidentiary issues supported by relevant authority; (4) A detailed statement of the relief sought, including a breakdown of the damages, if any; (5) A brief discussion of any other information that may assist the Court at trial.

Applies to

Motion in limine

Motions in limine must identify the specific evidence targeted, may not substitute for statutorily authorized dispositive motions, and boilerplate forms are strongly discouraged.

Motions in limine may not be used as substitutes for statutorily authorized dispositive motions. (Amtower v. Photon Dynamics, Inc. (2008) 158 Cal.App.4th 1582, 1594.) A motion in limine must identify the specific evidence to which it is directed. Form or boilerplate motions in limine are strongly discouraged.

Applies to

Motion in limine

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 identify concisely the evidence the moving party seeks to preclude.

Applies to

Joint statement of the case

In jury trials the parties must file a joint written statement of the case (brief and non-argumentative) for the court to read to the jury, or separate statements if they cannot agree after meet and confer.

For jury trials, the parties shall prepare and file a joint written statement of the case for the Court to read to the jury. (Local Rules, rule 3.25(g)(4).) The purpose of the joint statement is to inform prospective jurors of the identities of the parties and the general subject matter of the trial; as such, it should be brief and should not be argumentative. If, after efforts to meet and confer, the parties cannot agree on a written joint statement, each party shall file a separate statement of the case.

Applies to

Joint witness list

Counsel must jointly prepare a witness list of all intended trial witnesses (excluding impeachment and rebuttal), identifying each witness by name and expert status.

Counsel shall cooperate in the preparation of a joint list of all witnesses each party intends to call (excluding impeachment and rebuttal witnesses). (Local Rules, rule 3.25(g)(5).) The joint witness list shall identify each witness by name, specify which witnesses are experts, identify which

Applies to

Joint witness list

The joint witness list must include time estimates for witnesses presented via video deposition excerpts or transcript reading, comply with Local Rule 3.25(h)'s reasonable and accurate estimate requirement, and provide a grand total of estimated examination time.

The joint witness list must also include time estimates for any witness whose testimony is intended to be presented by playing video deposition excerpts or by reading transcripts of depositions or former testimony. All time estimates must comply with Local Rules, rule 3.25(h), which requires counsel to provide the Court with reasonable and accurate time estimates. The list must also provide a calculation of the total estimated time for the examination of all listed witnesses (i.e., a grand total).

Applies to

Joint witness list

The joint witness list must identify scheduling issues, special requirements (interpreters, ADA accommodations), remote-testimony status, and expert witnesses, and should include only witnesses who will actually be called.

The list must identify potential witness scheduling issues and special requirements, including whether any interpreters will be necessary and whether any ADA accommodation is anticipated. The list must identify whether the witness will testify remotely. A witness who is being called as expert must be identified as an expert. Counsel should include only those witnesses who are going to be called.

Applies to

Joint witness list

Witnesses not on the joint witness list are excluded except for impeachment or rebuttal testimony, both parties must ensure attendance of a mutually desired listed witness, and eliciting testimony from an unlisted witness requires a prior showing of good cause.

Any witness who is not included on the joint witness list is subject to exclusion other than for purposes of giving actual impeachment or rebuttal testimony. If a party includes a witness on the list and the opposing party similarly wants the witness to be called, both parties must ensure the witness’s attendance in case the original designating party decides not to call the witness. Any party who seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause.

Applies to

Joint exhibit list

The parties must prepare and file a joint exhibit list with columns identifying each exhibit and stating each party's evidentiary objections.

The parties shall prepare and file a joint exhibit list organized with columns identifying each exhibit and specifying each party's evidentiary objections, if any, to the admission of each exhibit.

Applies to

Joint exhibit list

Evidentiary objections not stated in writing on the joint exhibit list are deemed waived unless the party shows good cause.

Objections not stated in writing on the exhibit list shall be deemed waived except upon a showing of good cause.

Applies to

Joint exhibit list

Failure to file a timely joint exhibit list may result in the Court prohibiting use of exhibits at trial, per Local Rule 3.25(g)(3).

A failure to file a timely exhibit list may result in the Court prohibiting the use of exhibits at trial. (Local Rules, rule 3.25(g)(3).)

Applies to

Exhibits

Demonstrative evidence, blow-ups, and transcripts must be marked for identification and included on the joint exhibit list.

Demonstrative evidence, blow-ups, and transcripts must be marked for identification and included on the exhibit list.

Applies to

Transcripts of audio recordings

Under CRC rule 2.1040, the parties must prepare transcripts of all audio recordings.

Transcripts: California Rules of Court (“CRC”), rule 2.1040 requires the parties to prepare transcripts of all audio recordings.

Applies to

Transcripts of audio recordings

The parties must meet and confer on transcript contents before the FSC to resolve objections, and the transcript proponent must bring copies to the FSC so the Court can rule on objections.

The parties must meet and confer regarding the contents of any such transcripts prior to the FSC to resolve any objections. The proponent of the transcript must bring a copy of the transcripts to the FSC so the Court may rule on any objections.

Applies to

Joint list of proposed jury instructions

Parties must jointly prepare and file a list of proposed jury instructions organized in numerical order that identifies the agreed-upon and contested instructions.

The parties shall prepare and file jointly a list of proposed jury instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any.

Applies to

Full text proposed jury instructions

For jury trials, parties must jointly prepare a complete set of full-text proposed jury instructions, editing all CACI instructions, inserting party names, and eliminating blanks and inapplicable material.

For jury trials, the parties shall work together to prepare a complete set of full-text proposed jury instructions, editing all proposed CACI instructions, inserting party names, and eliminating blanks and other irrelevant or inapplicable material.

Applies to

Joint chart of page and line designations

If deposition or former trial testimony will be used in lieu of or in addition to live testimony, the parties must meet and confer and jointly prepare and file a Joint Chart of Page and Line Designations for Deposition and Former Testimony.

If the parties intend to use deposition testimony or former trial testimony in lieu of or in addition to a witness's live testimony, the 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").

Applies to

Joint witness list

The joint witness list must include time estimates for each witness who will be presented through prior testimony.

In addition to preparing a chart of designations and counter-designations, counsel must ensure that the joint witness list (described above) includes time estimates for each witness who will be presented through prior testimony.

Applies to

Verdict form

Parties must jointly file a proposed general or special verdict form acceptable to all sides, or each party must separately file a proposed verdict form if they cannot agree.

The parties shall prepare and jointly file a proposed general verdict form or special verdict form (with interrogatories) acceptable to all sides. (Local Rules, rule 3.25(g)(8).) If the parties/counsel cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

Applies to

Operative pleadings

Parties must submit conformed copies of the operative pleadings, including the operative complaint, answer, and any cross-complaints and answers thereto.

The parties must submit conformed copies of the operative pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint.)

Applies to

Stipulated continuance request

Must include

proposed order

A stipulated request for continuance must include a proposed order.

Requests for continuances may be made by stipulation and proposed order or, if no agreement is possible after good faith discussion among counsel in-person or by telephone, by noticed motion.

Applies to

Court reporter stipulation or appointment order

Parties must provide their own court reporter and file a reporter stipulation or appointment order before the hearing is called.

It is the responsibility of the parties to provide their own Court Reporter for hearings and trial. The parties are to file either the Stipulation and Order to use Certified Shorthand Reporter or Order Appointing Court Approved Reporter as Official Reporter Pro Tempore prior to the hearing being called.

Applies to

Ex parte application

Must include

proposed order

Ex parte applicants must submit a proposed order (and comply with CRC 3.1200) before appearing in court.

Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in court.

Applies to

Ex parte application

Ex parte applications are reserved for exigent circumstances and must include a declaration with an affirmative factual showing of irreparable harm, immediate danger, or another statutory basis.

Ex parte applications are reserved for exigent circumstances. The applicant shall comply with California 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.”

Applies to

Request for informal discovery conference

Requests for an Informal Discovery Conference must be filed using Form LACIV-094.

The parties are instructed to file their Request for an IDC using Form LACIV-094.

Applies to

Joint witness list

Parties must file a signed joint witness list identifying each witness by name, expert status, estimated examination time, total testimony hours, and any scheduling issues or special requirements.

Joint Witness List – The parties shall work together and file a joint list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. The joint witness list shall identify each witness by name, 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. The parties shall identify all potential witness scheduling issues and special requirements. The parties and counsel shall sign the joint witness list.

Applies to

Joint list of proposed jury instructions

Parties must file a signed joint list of proposed jury instructions organized numerically, distinguishing agreed from contested instructions, with a space for the Court to mark whether each instruction was given.

Joint List of Proposed Jury Instructions – The parties shall jointly prepare and file a 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 and counsel shall sign the joint list of proposed jury instructions.

Applies to

Jury instructions

Parties must prepare a complete set of full-text proposed jury instructions, with special instructions in jury-ready format showing only the instruction number, title, and text.

Jury Instructions (Joint and Contested) – The parties shall prepare a complete set of full-text proposed jury instructions. The parties shall prepare special instructions in a format ready for submission to the jury with the instruction number, title, and text only.

Applies to

Verdict form

Parties must file a joint proposed general or special verdict form (with interrogatories), or if they cannot agree, each party must separately file a proposed verdict form.

Joint Verdict Forms – The parties shall prepare and file a joint proposed general verdict form or special verdict form (with interrogatories). If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

Applies to

Joint exhibit list

Parties must meet and confer and file a signed joint exhibit list with specified columns for the exhibit, offering party, stipulations/objections to authenticity and admissibility, and identification/admission dates.

Joint Exhibit List – The parties shall prepare and file a joint exhibit list organized with columns identifying: (1) the exhibit, (2) which party is offering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) the date on which the exhibit was identified, and (5) the date on which the exhibit was admitted. Prior to filing the joint exhibit list, the parties shall meet and confer to determine whether they will stipulate to the authenticity and/or admissibility of each exhibit or whether there are objections to any exhibit. If there are stipulations, the parties shall note that in the respective column. If not, the objecting party shall specify all objections in the respective column. The parties and counsel shall sign the joint exhibit list.

Applies to

Deposition designation chart

If deposition or former testimony will be used in lieu of live testimony, parties must meet and confer and jointly file a chart with columns for page/line designations, objections, counter-designations, responses, and the Court's rulings.

Page and Line Designations for Deposition and Former Testimony – 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.

Applies to

Motion in limine

Motions in limine may not be used to seek dispositive orders that should have been sought via summary judgment, summary adjudication, or judgment on the 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.

Applies to

Motion in limine

Motions in limine must comply with Local Rule 3.57, including the required declaration where applicable.

When filing motions in limine, the parties must comply with Local Rule 3.57, including the required declaration, if applicable.

Applies to

Motions in limine binder

The motions-in-limine binder must include a table of contents identifying each motion, opposition, and reply with its corresponding tab.

The binder also must contain a table of contents identifying each motion in limine, opposition, and reply, and the corresponding tab for each.

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include a proposed order and have filing fee paid before appearing in court.

Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in court.

Applies to

Ex parte application

Ex parte applications must include an affirmative showing of irreparable harm, immediate danger, or another statutory basis for granting relief ex parte.

A party seeking ex parte relief must provide an affirmative showing of"irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte" (Cal. Rules of Court, Rule 3.1202 (c).) Please ensure that you have a proper basis to seek the requested relief.

Applies to

Motion

Must include

proposed order

Every noticed motion must be accompanied by a proposed order.

All noticed motions must be accompanied by a proposed order.

Applies to

Idc joint statement

Counsel must meet and confer and file a joint statement of the issues to be discussed at the IDC.

The court requires counsel to meet and confer and file a joint statement of the issues to be discussed at the IDC.

Applies to

Motion

The motion's CRS reservation number must appear on the caption page.

Counsel shall include the reservation number of the motion on the CAPTION page.

Applies to

Reply separate statement

Reply separate statements will not be considered by the court.

Reply separate statements are not provided for in the Rules of Court and will not be considered.

Applies to

Ex parte application

Ex parte applications must affirmatively show irreparable harm, immediate danger, or another statutory basis for relief, and must demonstrate why relief cannot be sought by other means such as a noticed motion.

PLEASE CAREFULLY REVIEW WHETHER YOU HAVE A PROPER BASIS TO SEEK EX PARTE RELIEF. There must be an affirmative showing of “irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte.” (See Cal. Rules of Court, rule 3.1202 (c).) You will need to demonstrate to the court the reason(s) why you cannot seek the requested relief by other means, such as a noticed motion.

Applies to

Exhibits

All exhibits must be exchanged and pre-numbered, except exhibits anticipated in good faith to be used for impeachment or rebuttal.

Pursuant to California Rule of Court 3.1110(f) and Local Rules 3.52 and 3.53, all exhibits must be exchanged and pre-numbered, except for those anticipated in good faith to be used for impeachment or during rebuttal.

Applies to

Foreign language exhibits

Foreign-language exhibits must be accompanied by a certified English translation.

Exhibits written in a foreign language must be accompanied by a certified English translation. Cal. Rule of Court 3.1110(g).

Applies to

Joint witness list

The joint witness list must list each witness once, with expected testimony time (direct, cross, re-direct) and total estimated time stated for each witness.

All witnesses must be listed on one list. Do not repeat the name of a witness. Indicate the total time expected for that testimony, including direct, cross, and re-direct. At the end of the list, state the total time estimated for each witness's testimony.

Applies to

Joint jury instructions

Joint jury instructions must be submitted with all information filled in (no brackets or blanks), and disputed instructions must be submitted in separate sets identifying the proposing and opposing parties.

Submit a joint set of instructions with all information filled in – no remaining brackets or blanks. If instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction.

Applies to

Jury instruction disposition table

A disposition table listing all jury instructions by number, proposing parties, and court disposition columns must be submitted with the jury instructions.

Submit a disposition table which lists all jury instructions by number, the identity of the party or parties proposing the instruction, and columns for the court to indicate whether the instruction is given, modified, withdrawn, or refused.

Applies to

Proposed verdict form

If the parties cannot agree on a verdict form, each party must submit its own proposed verdict form, and any special verdict must be simple and easy for the jury to use.

If the parties cannot agree on the verdict form, each party must submit their own proposed verdict form. Any proposed special verdict should be in a form that is easily used and understood by the jury, and which does not require the jury to answer unnecessary questions.

Applies to

Motion in limine

Must include

certificate of conference

Parties must meet and confer before filing any motion in limine, and every motion in limine must be accompanied by a sworn declaration attesting to the discussion and stating the opposing party's position.

Local Rule 3.57 requires the parties to meet and confer before filing any motion in limine. All motions in limine must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party and setting forth the opposing party's position regarding the motion(s)

Applies to

Ccp 2034 260 expert declaration

A party intending to call an expert at trial must present to the Court and opposing counsel a CCP section 2034.260 declaration stating the substance of the proffered opinion.

If counsel or any unrepresented party intends to call an expert at trial, counsel shall present to the Court and opposing counsel a copy of the Code of Civil Procedure section 2034.260 declaration that states the substance of the proffered opinion.

Applies to

Joint exhibit list

The parties must submit a joint exhibit list and a joint witness list.

The parties must submit a joint exhibit list and joint witness list as described above.

Applies to

Motion in limine

Must include

certificate of conference

Motions in limine must include a sworn declaration confirming meet and confer with opposing party and their position.

All motions in limine must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party and setting forth the opposing party’s position regarding the motion(s) and must be submitted with timely statutory notice.

Applies to

Ex parte application

Ex parte applications must include affirmative showing of irreparable harm, immediate danger, or statutory basis.

There must be an affirmative showing of “irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte.” (See Cal. Rules of Court, rule 3.1202 (c).)

Applies to

Motion

Motion hearing dates must be reserved via CRS; reservation number included on caption page.

Hearing dates must be reserved through the Court’s Reservation System (CRS). Counsel shall include the reservation number of the motion on the CAPTION page.

Applies to

Joint trial binder

All counsel must prepare a Joint Trial Binder containing the specified tabs (Trial Briefs, Motions in Limine, Joint Statement, Witness List).

All Counsel are to prepare a Joint Trial Binder which is to include the following:

Applies to

Joint jury instructions

At the Final Status Conference counsel must submit a Joint List of all requested jury instructions with fully completed copies, attaching disputed instructions separately with the requesting party identified, and must meet and confer no later than two days before the conclusion of evidence to create a final set of instructions, without waiving objections.

At the Final Status Conference, Counsel shall provide the Court with a Joint List of all Jury Instructions requested and a copy of all requested instructions fully filled out. Those instructions not agreed upon should be attached separately and the party making the request should be identified. No later than two days before the conclusion of evidence, the Court will require Counsel to meet and confer for the purpose of creating a final set of instructions. Submission of the Joint Jury Instructions shall not be deemed a waiver of any objection to the giving of an instruction on the Joint List.

Applies to

Proposed verdict form

Parties must file a joint proposed general or special verdict form, or if they cannot agree, each party must separately file a proposed verdict form.

The parties shall prepare and file a joint proposed general verdict form or special verdict form. The parties are urged to agree on a verdict form. If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

Applies to

Joint exhibit list

Counsel must submit a Joint Exhibit List numbered from 1 with three copies containing columns for the Clerk and Court, with exhibits numbered per Rules 3.52–3.53.

Counsel shall submit a Joint Exhibit List beginning with the number 1 and provide three copies of the exhibit list with columns for the Clerk and the Court to use to indicate whether the exhibit is marked and received into evidence. Exhibits shall be numbered in conformance with Rules 3.52 – 3.53.

Applies to

Joint deposition designation list

Counsel must submit a Joint Deposition Designation List numbered from 1 with three copies containing Clerk and Court columns, indicating whether excerpts are stipulated or the legal grounds for objections.

Counsel shall submit a Joint Deposition Designation List beginning with the number 1 and provide three copies of the Deposition Designation List with columns for the Clerk and the Court to use to indicate whether the Deposition Designation is admitted or not. The Joint Deposition Designation List is to include whether excerpts are stipulated or the Legal Grounds for Objections.

Applies to

Idc joint statement

The IDC joint statement must succinctly summarize 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.

At least five (5) court days before the Informal Discovery Conference, the parties and 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.

Applies to

Case management statement

Case Management Statements must use Judicial Council Form CM-110.

The parties and counsel shall file a Case Management Statement using Judicial Council Form CM-110 no later than fifteen (15) calendar days before the date set for the conference.

Applies to

Motion in limine

Motions in limine must be numbered consecutively, opposed with corresponding motion number, and filed in numerical order with replies/oppositions attached.

If more than one Motion in Limine is filed, each shall be numbered consecutively. Opposition papers shall include the number of the motion to which it corresponds. 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.

Applies to

Ex parte application

Must include

proposed order

Ex parte applicants must submit a proposed order and comply with CRC 3.1200 et seq. before appearing.

Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing.

Applies to

Ex parte application

Ex parte applications are reserved for exigent circumstances and must include a declaration making an affirmative factual showing of irreparable harm, immediate danger, or another statutory basis (CRC 3.1202(c)).

Ex parte applications are reserved for exigent circumstances. The applicant must comply with Cal. Rule 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."

Applies to

Request for court reporting services

A fee-waiver party's request for court reporting services must be made using local form LACIV 269 or Judicial Council form FW-020.

The request must be made by using the local form, Request for Court Reporting Services by a Party with Fee Waiver (LACIV 269), or Judicial Council form FW-020, and should be filed at least ten calendar days before the hearing or trial for which the reporter is requested.

Applies to

Settled statement

In trials without court reporters, the parties must jointly prepare a settled statement of the testimony and evidence admitted each day of trial.

For trials without court reporters, parties will be ordered to jointly prepare a settled statement of the testimony and list of evidence admitted each day of the trial.

Applies to

Evidence

Evidence on law and motion must be by declaration or request for judicial notice unless the Court orders otherwise for good cause.

Unless the Court orders otherwise for good cause shown, evidence must be by declaration or request for judicial notice. (California Rules of Court, rule 3.1304.)

Applies to

Oral testimony permission statement

Oral testimony is not allowed without court permission, and parties seeking permission must file a statement consistent with CRC rule 3.1306.

Oral testimony will not be allowed without court permission. Parties seeking permission to introduce oral testimony must file a statement consistent with California Rules of Court, rule 3.1306. (Local Rule 3.7.)

Applies to

Initial discovery disclosures

All civil actions filed after January 1, 2024 must comply with the initial discovery disclosure requirements of CCP §2016.090, which the Court may enforce on its own motion or a party's motion.

All civil actions filed after January 1, 2024 are subject to the initial discovery Disclosures requirements of CCP §2016.090. The Court may enforce the requirements of section 2016.090 on its own motion or on motion by a party.

Applies to

Ex parte notice

The ex parte notice must state the hearing details (date, time, and location) and the relief sought.

The notice must include the hearing details (date, time, and location), and a statement of what relief the ex parte applicant is seeking.

Applies to

Ex parte application

Ex parte applicants must file a declaration containing competent testimony detailing the information given in the notice.

The ex parte applicant must file a declaration containing competent testimony detailing the information given in the notice

Applies to

Notice of settlement

The Notice of Settlement must be prepared on Judicial Council Form CM-200.

Notice of Settlement must be filed electronically by plaintiff using Judicial Council Form CM-200, even if the case settled at a judicial settlement conference.

Applies to

Declaration

A party seeking to introduce an unexchanged exhibit on its direct case must file a written declaration containing competent evidence of its inability to comply with the Trial Preparation Order.

NOTE: If a party would like to introduce an exhibit on its direct case that was not exchanged as described herein, the party must file a written declaration containing competent evidence in support of any claim that the party was unable to comply with this Court's Trial Preparation Order and with these policies and procedures.

Applies to

Trial binder

All Trial Binder documents must be signed, filed, and conformed before being placed in the binder, except Jury Instructions (Full Text) and Verdict Form(s).

All documents in the Trial Binder, except the Jury Instructions (Full Text) and the Verdict Form(s) must be signed, filed and conformed before they are put into the Trial Binder.

Applies to

Exhibits

All exhibits must be exchanged and pre-numbered, except exhibits anticipated in good faith for impeachment or rebuttal.

Pursuant to California Rule of Court, Rule 3.1110(f), and Los Angeles Superior Court Local Rules 3.52 and 3.53, all exhibits must be exchanged and pre-numbered, except those anticipated in good faith to be used for impeachment or rebuttal.

Applies to

Exhibits

No exhibit may be referenced by counsel or a witness unless it has been pre-marked with an exhibit number.

No exhibit may be referenced by counsel or a witness unless it has been pre-marked with an exhibit number.

Applies to

Proposed jury instructions

Self-represented parties and counsel must prepare a list of joint and disputed jury instructions plus a complete set of printed, full-text edited proposed instructions for the Trial Binder.

Self-represented parties and counsel shall prepare a list of joint and disputed jury instructions, and must also prepare a complete set of printed, full-text and edited proposed jury instructions and include them in the Trial Binder.

Applies to

Joint verdict form

Self-represented parties and counsel must prepare and jointly file Joint Verdict Form(s).

Self-represented parties and counsel shall prepare and jointly file Joint Verdict Form(s).

Applies to

Deposition designation pleading

If deposition transcripts or videotapes will be used in lieu of live testimony, a pleading must set out all designated testimony, objections, and cross-designated testimony.

When deposition transcript(s) or videotape(s) are to be used in lieu of live testimony (not just for impeachment), a pleading must be prepared setting out all designated testimony, objections and cross-designated testimony.

Applies to

Exhibit binder

Parties must jointly prepare three sets of exhibit binders (Judge, Judicial Assistant, Witness), each labeled on the front and side.

The parties shall jointly prepare three sets of evidentiary exhibit binders (a set for Judge, Judicial Assistant and Witness). The Exhibit Binders shall have labels on the front and side.

Applies to

Summary of daily proceedings

If no court reporter is used at trial, the parties must jointly prepare a summary of each day's proceedings and lodge it in the courtroom before proceedings resume.

COURT REPORTERS OR SETTLED STATEMENTS: The Court encourages the parties to bring a court reporter to the courtroom for trial. If no court reporter is used, the parties shall jointly prepare a summary of each day's proceedings, and lodge it in the courtroom before proceedings resume.

Applies to

Daily admitted exhibit list

At the end of each trial day, counsel must meet and confer and submit an agreed-upon list of all exhibits admitted that day to the judicial assistant.

END OF COURT DAY: At the end of each trial day counsel must meet and confer and submit to the Court's judicial assistant an agreed-upon list of all exhibits admitted that day.

Applies to

Ex parte application

Must include

declaration

Ex parte applicants must file a declaration with competent testimony detailing notice information and rule 3.1204 requirements.

The ex parte applicant must file a declaration containing competent testimony detailing the information given in the notice as well as the information required by California Rules of Court, rule 3.1204.

Applies to

Trial binder

Must include

filed, signed, conformed

All Trial Binder documents except jury instructions and verdict forms must be signed, filed, and conformed.

All documents in the Trial Binder, except the Jury Instructions (Full Text) and the Verdict Form(s) must be signed, filed and conformed before they are put into the Trial Binder.

Applies to

Ex parte application

Must include

proposed order

For an ex parte application seeking a TRO and order to show cause re preliminary injunction, the moving party must submit a proposed form of order (source text is truncated mid-sentence).

If the ex parte application seeks a temporary restraining order and order to show cause re preliminary injunction, the moving party must submit a proposed form of

Applies to

Off calendar written confirmation

A moving party who takes a motion off calendar must confirm that fact in writing.

If the moving party takes a motion off calendar, the moving party shall confirm that fact in writing.

Applies to

Opening brief

If the parties cannot agree on a joint appendix, the petitioner must bates-stamp its evidence and submit it with the Opening Brief.

If the parties cannot agree upon a joint appendix, petitioner must bates-stamp any evidence it wants the Court to consider and submit such evidence with the Opening Brief.

Applies to

Opposition brief

The respondent must bates-stamp its evidence (starting with the number following the petitioner's evidence) and submit it with the Opposition Brief.

Respondent shall, in turn, bates-stamp any evidence it wants the Court to consider (starting with the number following the petitioner's evidence) and submit such evidence with the Opposition Brief.

Applies to

Proposed judgment and writ of mandate

The prevailing party on a prerogative writ will be ordered to prepare, serve, and ultimately file a proposed judgment and, if applicable, a proposed writ of mandate.

In accordance with Local Rule 3.231(n), the prevailing party on a prerogative writ will be ordered to prepare, serve, and ultimately file a proposed judgment and, if applicable, a proposed writ of mandate.

Applies to

Declaration of service efforts

If any defendant remains unserved by the CMC, plaintiff must file a declaration, at least five days before the hearing, explaining the service efforts undertaken.

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.

Applies to

Joint discovery report

The parties must file a joint report at least five court days before the IDC covering the nature of the dispute, necessity for the discovery, justification for non-production, and overall discovery status.

At least five court days before the IDC, the parties shall file a joint report that succinctly sets forth the nature of the dispute, the necessity for the discovery, the justification for its non-production, and the overall status of discovery.

Applies to

Joint statement

A motion to compel further responses must be accompanied by a four-column joint statement identifying the request number, the request text, the response text, and each party's bullet-point arguments.

In the event a motion to compel further responses is filed, the parties are required to submit a JOINT STATEMENT consisting of a four-column document set up as follows: The first column will identify the number of the discovery request; the second, the text of the discovery request; the third, the text of the response; and the fourth, brief bullet-point statements, one from each party, as to why a further response should or should not be compelled.

Applies to

Ex parte application

Must include

proposed order

Ex parte applicants must submit a proposed order with the application and pay the filing fee before appearing in court.

Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in court.

Applies to

Ex parte application

Ex parte applications are reserved for exigent circumstances and 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. The applicant shall 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."

Applies to

Pretrial filings

Parties must file the pretrial documents required by Local Rule 3.25(f) and (g) in advance of the Final Status Conference.

The parties are required to file the documents set forth in Local Rule 3.25(f) and (g) in advance of the FSC and should be familiar with Local Rules 3.48 through 3.58.

Applies to

Trial brief

Each party must file a trial brief identifying the claims and defenses, major legal issues with supporting points and authorities, relief claimed and damages calculation, and any other information assisting the Court.

Trial Briefs – Each party shall file 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.

Applies to

Motion in limine

The caption of each motion in limine must concisely identify the evidence the moving party seeks to admit or exclude.

The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to admit or exclude.

Applies to

Motion in limine

Parties filing multiple motions in limine must number the motions consecutively.

Parties filing more than one motion in limine shall number the motions consecutively.

Applies to

Opposition and reply brief

Opposition and reply briefs on 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.

Applies to

Joint statement of the case

In jury trials, the parties must prepare and sign a joint written statement of the case for the Court to read to the jury.

Joint Statement – For jury trials, the parties shall prepare a joint written statement of the case for the Court to read to the jury. The parties/counsel shall sign the joint statement.

Applies to

Joint witness list

Parties must file a signed joint witness list (excluding impeachment and rebuttal witnesses) identifying each witness by name, designating experts, estimating direct/cross/re-direct examination times with total testimony hours, and noting scheduling issues and special requirements.

Joint Witness List – The parties shall work together and file a joint list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. The joint witness list shall identify each witness by name, 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. The parties shall identify all potential witness scheduling issues and special requirements. The parties/counsel shall sign the joint witness list.

Applies to

Joint list of jury instructions

Parties must file a signed joint list of proposed jury instructions in numerical order identifying agreed and contested instructions, with a space by each instruction for the Court to indicate whether it was given.

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.

Applies to

Jury instructions

Parties must prepare a complete set of full-text proposed jury instructions, with special instructions formatted for submission to the jury containing only the instruction number, title, and text.

Jury Instructions (Joint and Contested) – The parties shall prepare a complete set of full-text proposed jury instructions. The parties shall prepare special instructions in a format ready for submission to the jury with the instruction number, title, and text only.

Applies to

Verdict form

Parties must prepare and file a joint proposed general or special verdict form (with interrogatories), or if they cannot agree, each party must separately file a proposed verdict form.

Joint Verdict Forms – The parties shall prepare and file a joint proposed general verdict form or special verdict form (with interrogatories). If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

Applies to

Joint exhibit list

Parties must meet and confer, then file a signed joint exhibit list with columns for the exhibit, offering party, stipulations or objections to authenticity/admissibility, identification date, and admission date.

Joint Exhibit List – The parties shall prepare and file a joint exhibit list organized with columns identifying: (1) the exhibit, (2) which party is offering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) the date on which the exhibit was identified, and (5) the date on which the exhibit was admitted. Prior to filing the joint exhibit list, the parties shall meet-and-confer to determine whether they will stipulate to the authenticity and/or admissibility of each exhibit or whether there are objections to any exhibit. If there are stipulations, the parties shall note that in the respective column. If not, the objecting party shall specify all objections in the respective column. The parties/counsel shall sign the joint exhibit list.

Applies to

Deposition designation chart

If deposition or former trial testimony will be used in lieu of live testimony, the parties must meet and confer and file a signed chart listing page/line designations, objections, counter-designations, responses, and the Court's rulings.

Page and Line Designations for Deposition and Former Testimony – 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.

Applies to

Motion in limine

Must include

local rule certificate

Motions in limine must comply with Local Rule 3.57, including the required declaration where applicable.

When filing motions in limine, the parties must comply with Local Rule 3.57, including the required declaration, if applicable.

Applies to

Motion in limine binder

The motions in limine binder must include a table of contents identifying each motion in limine, opposition, and reply with the corresponding tab.

The binder also must contain a table of contents identifying each motion in limine, opposition, and reply, and the corresponding tab for each.

Applies to

Declaration

Declaration of service efforts required 5 days before CMC 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.

Applies to

Joint statement

Motions to compel further responses require a four-column joint statement with specified content.

In the event a motion to compel further responses is filed, the parties are required to submit a JOINT STATEMENT consisting of a four-column document set up as follows: The first column will identify the number of the discovery request; the second, the text of the discovery request; the third, the text of the response; and the fourth, brief bullet-point statements, one from each party, as to why a further response should or should not be compelled.

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include a proposed order and have filing fee paid before court appearance.

Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in court.

Applies to

Ex parte application

Ex parte applications must include a declaration with personal knowledge testimony of irreparable harm or exigent circumstances.

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.

Applies to

Moving papers

Moving papers must be filed with the CRS reservation receipt number printed on the face page under the caption and with the reservation receipt attached as the last page.

After reserving a motion hearing date, the reservation requestor must submit the moving papers for filing with the reservation receipt number printed on the face page of the document under the caption and attach the reservation receipt as the last page.

Applies to

Deposition transcripts

Deposition excerpts cited in briefs must be marked on the transcripts attached as exhibits.

All deposition excerpts referenced in briefs must be marked on the transcripts attached as exhibits. (Cal. Rules of Court, rule 3.1116(c).)

Applies to

Ex parte application

Ex parte relief is granted only upon an admissible-evidence showing of irreparable harm or immediate danger (or other grounds stated in the continuation of the sentence).

The Court will only grant ex parte relief upon a showing, by admissible evidence, that the moving party will suffer “irreparable harm,” “immediate danger,” or where the moving party

Applies to

Motion in limine

Each motion in limine 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.

Applies to

Opposition and reply papers

Opposition and reply papers on motions in limine must identify the corresponding motion number in the caption.

Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.

Applies to

Joint statement of case

In jury trials, parties must prepare and file a joint written statement of the case for the trial court to read to the jury.

For jury trials, the parties shall prepare and file a joint written statement of the case for the trial court to read to the jury. (Super. Ct. L.A. County, Local Rules, rule 3.25(g)(4).)

Applies to

Joint witness list

Parties must file a joint witness list, alphabetized by last name and excluding impeachment and rebuttal witnesses, that identifies each witness by name, expert status, estimated examination times, and total testimony hours.

The parties shall prepare and file a joint, alphabetized by last name, list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. (Super. Ct., L.A. County, Local Rules, rule 3.25(g)(5).) The joint witness list shall identify each witness by name, specify which witnesses are non-experts and experts, estimate the length of the direct, cross examination and re-direct examination of each witness, and include a total of the number of hours for all witness testimony.

Applies to

Joint witness list

Parties must identify all potential witness scheduling issues and special requirements.

The parties shall identify all potential witness scheduling issues and special requirements.

Applies to

List of proposed jury instructions

The List of Proposed Jury Instructions must be organized in numerical order with columns showing whether each instruction is agreed or contested, plus columns for the trial judge to indicate given, given as modified, refused, or withdrawn.

those contested), organized in numerical order, including columns to indicate whether an instruction is agreed to or contested. In addition, the List of Proposed Jury Instructions must include columns for a trial judge to indicate whether an instruction was given, given as modified, refused, or withdrawn. (See Cal. Rules of Court, rule 2.1055.)

Applies to

Jury instructions

Parties must prepare a complete set of full-text proposed jury instructions ready for submission to the jury, with party names inserted and blanks, brackets, and irrelevant material eliminated.

The parties shall prepare a complete set of full text proposed jury instructions in a format ready for submission to the jury, by editing all proposed California Civil Jury Instructions including inserting party name(s) and eliminating blanks, brackets, and irrelevant material.

Applies to

Jury instructions

Parties must separate proposed jury instructions into groups of agreed-upon versus not-agreed-upon instructions.

The parties shall separate the instructions into groups of agreed-upon versus not-agreed-upon instructions.

Applies to

Verdict form

Parties must jointly file a proposed general or special verdict form acceptable to all sides, or, if they cannot agree, each party must separately file a proposed verdict form.

The parties shall prepare and jointly file a proposed general verdict form or special verdict form (with interrogatories) acceptable to all sides. (Super. Ct. L.A. County, Local Rules, rule 3.25(g)(8).) If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

Applies to

Joint exhibit list

Parties must file a joint exhibit list with columns identifying each exhibit, specifying any evidentiary objections (unarticulated objections may result in the exhibit being deemed admitted), and blanks for the Court to enter the dates the exhibit was first identified and admitted.

The parties shall prepare and file a joint exhibit list organized with columns 1) identifying each exhibit, 2) specifying evidentiary objections, if any, to the admission of the exhibit (if an objection to an exhibit is not articulated on the exhibit list, the trial court may deem the exhibit admitted) 3) a blank column for the Court to enter the date the exhibit was first identified, and 4) a blank column for the Court to enter the date the exhibit was admitted.

Applies to

Deposition designation chart

Parties intending to use deposition or former trial testimony must meet and confer and jointly file a chart containing columns for designations, objections, counter-designations, responses, and the Court's ruling.

If the parties intend to use deposition testimony or former trial testimony in lieu of any witness' 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 ruling.

Applies to

Trial binder

The FSC trial binder must contain conformed copies organized behind Tabs A through I (trial briefs, joint jury statement, witness list, exhibit list, jury instructions, verdict forms, deposition designation chart, and operative pleadings), with agreed jury instructions placed before contested instructions behind Tab F.

Tab A: Trial Briefs (Optional) Tab B: Joint Statement to Be Read to the Jury Tab C: Joint Witness List (in the format prescribed at § 8(B)(b)) Tab D: Joint Exhibit List (in the format prescribed at § 8(B)(h)) Tab E: Joint List of Jury Instructions (identifying the agreed upon and contested instructions) Tab F: Joint and Contested Jury Instructions. The parties shall organize proposed jury instructions behind Tab F, with the agreed upon instructions first in order followed by the contested instructions (including special instructions) submitted by each side. Tab G: Joint and/or Contested Verdict Form(s) Tab H: Joint Chart of Page and Line Designation(s) 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).

Applies to

Joint summary of testimony

When no court reporter is present, counsel must jointly provide the court a daily summary of testimony and admitted evidence by the morning following the testimony.

If the parties do not have a court reporter, counsel will be required to provide the court with a joint summary of the testimony and evidence admitted on a daily basis by the morning following the testimony.

Applies to

Stipulation and proposed order

Must include

proposed order

Counsel must file a stipulation and proposed order setting forth available dates to obtain an informal discovery conference.

For an informal discovery conference, counsel shall file a stipulation and proposed order which sets forth dates that counsel would be available for the informal discovery conference.

Applies to

Evidentiary objection

Evidentiary objections must comply with CRC 3.1354, specifically identify and quote the objectionable material, be directed to the supporting evidence (not the undisputed fact statements), and state the basis for the objection.

Counsel filing evidentiary objections in connection with a motion for summary judgment or summary adjudication should comply with California Rules of Court Rule 3.1354. Please note an evidentiary objection must specifically identify the document in which the objectionable material is located and quote or set forth the objectionable statement or material. Counsel should not object to a “statement” contained in opposing party’s statement of undisputed material facts; rather the objection must be directed to the evidence in support of that fact and state the basis for the objection.

Applies to

Joint exhibit list

For jury trials, all exhibits must be listed on a single numbered joint exhibit list with brief descriptions, and exhibit notebooks must be available at the final status conference with all parties prepared to confirm they reviewed the exhibit book.

JOINT EXHIBIT LIST. All exhibits must be listed on one list, identified by a number and brief description. Notebooks containing all exhibits must be available on the final status conference date and all parties must be prepared to tell the court that they have had the opportunity to review all documents in the exhibit book.

Applies to

Joint witness list

The joint witness list must include all witnesses on a single list without duplicated names, with expected testimony time for each witness and a total time estimate at the end.

All witnesses must be listed on one list. Do not repeat the name of a witness who will be called by more than one party. Next to each witness, indicate the total time expected for that testimony (including direct, cross, redirect, etc.) At the end of the list, total the time estimated for testimony.

Applies to

Jury instructions

Parties must submit a joint, fully completed set of CACI instructions (no brackets, blanks, tear sheets, or disposition boxes), separate sets for disputed instructions identifying proposer and opponent, and a disposition table listing all instructions with columns for the court's rulings.

Submit a joint set of CACI instructions with all information filled in, no remaining brackets or blanks. Do not use tear sheets for the instructions and do not include the disposition box on the page of the individual instruction. If some instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction. Submit a disposition table which lists all jury instructions by number, the identity of the party or parties proposing the instruction, and which contains columns for the court to indicate whether the instruction is given, modified, withdrawn or refused.

Applies to

Proposed verdict form

If parties cannot agree on a verdict form, each must submit a proposed verdict form, and any special verdict should be easy for the jury to use without unnecessary questions.

If the parties cannot agree on the verdict form, each party must submit a proposed verdict form. Any proposed special verdict should be in a form that is easily used by the jury, and which does not require the jury to answer unnecessary questions.

Applies to

Court trial submissions

In court trials, the parties must submit a joint exhibit list and a joint witness list as described in the order.

The parties must submit a joint exhibit list and joint witness list as described above.

Applies to

Stipulation

Must include

proposed order

Stipulation and proposed order required to request informal discovery conference.

For an informal discovery conference, counsel shall file a stipulation and proposed order which sets forth dates that counsel would be available for the informal discovery conference.

Applies to

Evidentiary objection

Evidentiary objections in summary judgment motions must identify document, quote objectionable material, and state basis for objection per CRC 3.1354.

Counsel filing evidentiary objections in connection with a motion for summary judgment or summary adjudication should comply with California Rules of Court Rule 3.1354. Please note an evidentiary objection must specifically identify the document in which the objectionable material is located and quote or set forth the objectionable statement or material. Counsel should not object to a “statement” contained in opposing party’s statement of undisputed material facts; rather the objection must be directed to the evidence in support of that fact and state the basis for the objection.

Applies to

Joint exhibit list

Joint exhibit list required 5 court days before final status conference for jury trials.

JURY TRIALS 1. JOINT EXHIBIT LIST. All exhibits must be listed on one list, identified by a number and brief description. Notebooks containing all exhibits must be available on the final status conference date and all parties must be prepared to tell the court that they have had the opportunity to review all documents in the exhibit book. Place the correspond with the exhibit number. If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3, etc. Exhibits should be lodged with the court on the first day of trial.

Applies to

Joint jury instructions

Joint CACI jury instructions and disposition table required 5 court days before final status conference for jury trials.

3. JOINT JURY INSTRUCTIONS. Submit a joint set of CACI instructions with all information filled in, no remaining brackets or blanks. Do not use tear sheets for the instructions and do not include the disposition box on the page of the individual instruction. If some instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction. Submit a disposition table which lists all jury instructions by number, the identity of the party or parties proposing the instruction, and which contains columns for the court to indicate whether the instruction is given, modified, withdrawn or refused.

Applies to

Joint proposed verdict form

Joint proposed verdict form required 5 court days before final status conference for jury trials.

5. JOINT PROPOSED VERDICT FORM. If the parties cannot agree on the verdict form, each party must submit a proposed verdict form. Any proposed special verdict should be in a form that is easily used by the jury, and which does not require the jury to answer unnecessary questions.

Applies to

Trial brief

Court trials require joint exhibit list, witness list, and trial brief filed by final status conference.

COURT TRIALS. The parties must submit a joint exhibit list and joint witness list as described above. A trial brief must be served and filed no later than the final status conference.

Applies to

Joint short statement

Joint neutral case statement (2-3 paragraphs) required 5 court days before final status conference for jury trials.

4. JOINT SHORT STATEMENT TO BE READ TO THE JURY. This statement should be a brief, neutral description of the case. In most instances, it should not exceed 2-3 paragraphs.

Applies to

Joint witness list

Joint witness list with time estimates required 5 court days before final status conference for jury trials.

2. JOINT WITNESS LIST. All witnesses must be listed on one list. Do not repeat the name of a witness who will be called by more than one party. Next to each witness, indicate the total time expected for that testimony (including direct, cross, redirect, etc.) At the end of the list, total the time estimated for testimony. Make realistic time estimates. Absent good cause, the total number of hours listed for testimony should not exceed the trial estimate given at the case management conference, including the allocation of 1 day for jury selection and 1 day for deliberations. For example, a 5 day trial estimate means no more than 3 days of testimony.

Applies to

Trial binder

The trial binder must include conformed copies of the operative pleadings, Joint Statement of the Case (jury trials), Motions in Limine complying with LASC Rule 3.57, a Joint Witness List with testimony details, joint exhibits with a Joint Exhibit List, and edited joint proposed jury instructions and verdict forms (jury trials).

i. Copies of the current operative pleadings (including the operative complaint and answer); ii. Joint Statement of the Case (if a jury trial); iii. Motions in Limine, if any, which must be drafted in accordance with LASC Rule 3.57 and served and filed; iv. Joint Witness List disclosing the witnesses who will be called, what they will testify to, whether an interpreter is needed, and how long their testimony will take; v. Joint exhibits in exhibit books, numbered appropriately, and a Joint Exhibit List (See LASC Rules 3.52 and 3.53). vi. Edited Joint Proposed Jury Instruction printed out for the Court (if a jury trial); and vii. Edited Joint Proposed Verdict Form(s) printed out for the Court (if a jury trial).

Applies to

Joint exhibits

All exhibits must be exchanged between the parties before trial.

All exhibits must be exchanged prior to trial;

Applies to

Ex parte application

Must include

certificate of service

Ex parte applications must comply with CRC 3.1200–3.1207 and LASC Rule 3.26, including proof of the required notice and an affirmative factual showing of good cause, and are commonly denied for failure to prove notice or why the matter could not be a noticed motion.

EX-PARTE APPLICATIONS: Before bringing an ex parte application, all parties should review California Rules of Court 3.1200 – 3.1207 and Los Angeles County Superior court Rule 3.26. Please pay particular attention to the notice requirements and the requirement of an affirmative factual showing of good cause. Among the most common grounds for denial of an ex parte application is the failure to provide proof of the required notice and/or failure to prove why the application could not be brought as a noticed motion. An "emergency" caused by procrastination or other unexcused delay on the part of the applicant is not grounds for ex parte relief.

Applies to

Ex parte application

All necessary information and evidence must be included in the ex parte application because the Court may rule without oral argument, and withholding evidence for argument may result in denial.

The Court may rule on the ex parte papers without any oral argument if a hearing is deemed unnecessary. With that in mind, please include all necessary information and evidence in the ex parte application; waiting to present evidence at oral argument may result in denial of the application.

Applies to

Motions in limine

Must include

local rule certificate

Motions in Limine must be drafted in accordance with LASC Rule 3.57 and served and filed.

Motions in Limine, if any, which must be drafted in accordance with LASC Rule 3.57 and served and filed;

Applies to

Ex parte application

Must include

proposed order

Ex parte filings must include a proposed order.

Ex Parte applications, supporting documents, and a proposed order must be electronically filed no later than 10:00 a.m. the court day before the Ex Parte hearing.

Applies to

Ex parte application

Must include

proposed order

The Court will not consider an Ex Parte application unless it is submitted with a proposed order.

Please note that the Court may not consider Ex Parte applications submitted/filed without a proposed order.

Applies to

Exhibit binder

The exhibit binders must include the exhibit list.

The exhibit list must be included in the binders.

Applies to

Final status conference preparation

All parties must meet and confer and/or exchange information at least 15 court days before the FSC, and failure to timely comply with any item of the FSC order may result in sanctions including monetary sanctions, exclusion of evidence, issue preclusion, denial of a claim or defense, dismissal, or contempt.

All parties shall meet and confer and/or exchange information at least fifteen (15) court days before the FSC as required by this order and Los Angeles County Court Rules, Rule 3.25(g). Any failure to timely comply with any item required by this order shall subject any such non-complying party to the imposition of appropriate sanctions, including but not limited to monetary, exclusion of evidence, issue preclusion, denial of a claim or defense, dismissal, or contempt (pursuant to CCP §§128.5, 177.5, 575.5 and 583.410; Government Code §68608, CRC Rule 526).

Applies to

Court trial fsc filings

Court trials require the filing of Motions in Limine (if any), Trial Briefs, a Joint Witness List, and a Joint Exhibit List before the FSC.

a. Motions in Limine (if any), b. Trial Briefs, c. Joint Witness List, and d. Joint Exhibit List.

Applies to

Jury trial fsc filings

Jury trials require the filing of Motions in Limine (if any), Trial Briefs, Joint Witness List, Joint Exhibit List, Joint Statement of the Case, Joint Jury Instructions, and Joint Verdict Form before the FSC, with the enumerated list appearing to continue beyond this excerpt.

a. Motions in Limine (if any), b. Trial Briefs, c. Joint Witness List, d. Joint Exhibit List, e. Joint Statement of the Case, f. Joint Jury Instructions, g. Joint Verdict Form, and,

Applies to

Trial brief

Trial briefs are mandatory for all court and jury trials and must include eight specified content items, including descriptions of causes of action and defenses, stipulated facts, contested issues of fact and law with points and authorities, anticipated evidentiary issues, and a detailed damages breakdown.

Trial briefs are mandatory for all (both Court and jury) trials and must include the following information and not exceed 20 pages: 1) A brief description of each cause of action and key affirmative defenses presented and the issues to be decided; 2) Statement of ultimate facts or issues to which you will stipulate; 3) Those facts established by admissions in pleadings; admissions by discovery and/or stipulation of the parties; 4) All contested issues of fact; 5) All contested issues of law, together with points and authorities supporting the position of the parties; 6) A list of major evidentiary issues anticipated, any relevant points and authorities supporting the position of the parties; 7) A detailed statement of the damages and relief claimed, including a specific breakdown of the elements of damages claimed and the amount sought; and, 8) Any other information that will assist the Court.

Applies to

Exhibit list

Parties must jointly prepare and exchange a completed Exhibit List identifying each document and item of physical evidence and any stipulations to authenticity or admissibility.

All parties must jointly prepare and exchange a completed Exhibit List, indicating each document and item of physical evidence, and whether there is a stipulation to authenticity and/or admissibility.

Applies to

Discovery material list

Each party must prepare a list of discovery material intended for use at trial, specifically identifying the date, document, page and line for each item.

Each party must prepare a list of discovery material intended to be used at trial, including but not limited to interrogatories and requests for admissions and any responses thereto as well as deposition(s), all of which shall specifically identify the date, document, page and line.

Applies to

Depositions

Originals of depositions or other discovery responses intended for use at trial must be lodged with the Court at the time of trial.

If depositions or other discovery responses are intended to be used at trial, originals shall be lodged with the Court at the time of trial.

Applies to

Joint statement of the case

Parties must submit a printed copy of a jointly prepared, short, non-argumentative written statement of the case to be read to the jury.

The parties shall submit a printed copy of the jointly prepared, short, non-argumentative written statement of the case to be read to the jury.

Applies to

Jury instructions

Jury instructions must be submitted as a jointly submitted packet of unopposed instructions, with each party's disputed instructions separately submitted and inserted into that packet for the Court's consideration.

A jointly submitted packet of all requested and properly edited jury instructions to which there is no objection. Each party shall also submit specifically requested and properly edited instructions not requested by the opposing counsel/party. These instructions shall be inserted into the aforementioned packet of the jointly submitted jury instructions, all to be considered and discussed by the Court at an appropriate time during the pendency of the trial.

Applies to

Jury instruction

Each proposed jury instruction must identify who requested it, whether it is to be given as requested or modified, whether it is withdrawn, and must include a signature line for the Court.

requesting the instruction; B) Whether the instruction is to be given as requested or modified; C) Whether the instruction is withdrawn; and D) A signature line for the Court.

Applies to

Special verdict form

A joint special verdict form is mandatory and must be prepared in final form adapted to CACI.

A special verdict form is mandatory and shall be jointly prepared in final form. This special verdict form shall be adapted to CACI with proper spacing, particularly noted to allow for both clarity and direction.

Applies to

Discovery designation

A proffering party must identify in writing the deponent's name and the page and line numbers of any deposition video excerpt proposed for use at trial.

For example, if a party proposes to read or show a video excerpt from a deposition, the proffering party must identify in writing the name of the deponent, page, and line numbers to opposing counsel

Applies to

In limine motion

Objections to the use of discovery material must be raised by way of an in limine motion.

Any objections to the use of discovery material shall be done by way of an in limine motion.

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include a proposed order and be e-filed by 10:00 a.m. the court day before the hearing.

Ex Parte applications, supporting documents, and a proposed order must be electronically filed no later than 10:00 a.m. the court day before the Ex Parte hearing.

Applies to

Written showing

For OSCs based on failure to comply with a direct court order, a written showing must be filed before the OSC hearing or sanctions will be imposed, and oral explanations will not be accepted.

If the court sets an order to show cause for a failure to comply with a direct court order, sanctions will be imposed unless a written showing is filed prior to the hearing on the OSC. Oral explanations will neither be sought nor accepted.

Applies to

Case management statement

Represented plaintiffs' counsel face monetary sanctions if no CMC statement is filed when no proof of service has been filed.

A represented Plaintiff's failure to file a CMC statement when no proof of service has been filed will result in monetary sanctions against Plaintiff's counsel.

Applies to

Joint witness list

Counsel and self-represented parties must jointly prepare and file a witness list covering all trial witnesses (excluding impeachment and rebuttal witnesses) organized to include each witness's name, expert status, accommodations, calling party, expected-testimony status and description, and estimated direct, cross, and total examination times in minutes.

The parties' counsel and any self-represented parties must work together to prepare and file a joint witness list of all witnesses whom any party intends to call at trial, excluding impeachment and rebuttal witnesses. (Los Angeles County Court Rule (Local Rule) 3.25, subd. (g)(5).) The joint witness list shall be organized to include: (1) the name of each witness, whether 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 minutes); (6) an estimate of the length of cross-examination (in minutes), and; (7) the total estimated length of examination (in minutes).

Applies to

Joint witness list

Witnesses not included on the joint witness list may be excluded from testifying at trial except for actual impeachment or rebuttal testimony, and a party must first show good cause to the court to call an unlisted witness.

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.

Applies to

Joint exhibit list

Counsel and self-represented parties must jointly prepare and file a joint exhibit list containing eight required columns: exhibit number, description, offering party, authentication stipulation, admissibility stipulation, objections, date marked, and date admitted.

The parties' counsel and any self-represented parties shall work together to prepare and file a joint exhibit list organized with columns 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).)

Applies to

Joint statement of case

For jury trials, counsel and self-represented parties must jointly prepare and file a brief written statement of the case for the court to read to the jury.

For jury trials, the parties' counsel and any self-represented parties must 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).)

Applies to

Joint proposed jury instructions

For jury trials, counsel and self-represented parties must jointly prepare and file a list of proposed jury instructions stating, for each instruction, the number, title, requesting party, agreed/contested status, any objection, and whether it was given.

For jury trials, the parties' counsel and any self-represented parties shall work together to prepare and file a joint list of proposed jury instructions 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.

Applies to

Proposed jury instructions

For jury trials, counsel and self-represented parties must jointly prepare a complete set of full-text proposed jury instructions, editing all CACI instructions by inserting party names and eliminating blanks and inapplicable material.

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.

Applies to

Proposed verdict form

For jury and court trials, the parties must jointly file a proposed general or special verdict form, or if they cannot agree, each party must separately file a proposed verdict form, using CACI special verdict forms where appropriate.

For jury and court trials, the parties' counsel and any self-represented parties must 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 the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form. When a special verdict form is requested, if there is an appropriate CACI special verdict form for a cause of action, affirmative defense, or other finding, the court expects the parties to use the CACI special verdict form.

Applies to

Joint trial documents

All listed trial documents should be jointly prepared and submitted, but if no joint document is agreed upon, each party must prepare and submit its own documents.

All of the above listed documents should be jointly prepared and submitted. However, in the absence of agreed-upon joint documents, each party must prepare and submit the party's own documents.

Applies to

Joint designation chart

Parties intending to use deposition or former trial testimony must meet and confer and file a joint designation chart with five required columns; testimony used for impeachment purposes only need not be included.

If any parties intend to use deposition testimony or former trial testimony in lieu of or in addition to a witness's live testimony, the parties' counsel and any self-represented parties shall meet and confer to discuss, and work together to prepare and file, a joint chart of former testimony the parties intend to use. The parties do not, however, need to include in the joint chart deposition testimony or former trial testimony they plan on using for impeachment purposes only. In the joint chart, each designating party's designations (or counter-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 testimony requested to be used, (4) any objections, and (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.

Applies to

Motion in limine

Motions in limine must be noticed for hearing at the Final Status Conference and must comply with Code of Civil Procedure section 1005 notice provisions and Local Rule 3.57(a) declaration requirements.

Motions in limine shall be noticed for hearing at the Final Status Conference. The parties' counsel and any self-represented parties shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and file declarations that comply with the requirements of Local Rule 3.57, subdivision (a).

Applies to

Motion in limine

The caption of each motion in limine must concisely identify the evidence the moving party seeks to exclude.

The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to exclude.

Applies to

Opposition and reply papers

Opposition and reply papers on motions in limine must identify the corresponding motion number in the caption.

Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.

Applies to

Motions in limine binder

Jointly prepared Motions in Limine Binders containing conformed copies of all motions in limine, opposition papers, and reply papers must be lodged in Department P no later than five court days before the Final Status Conference.

No later than five (5) court days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department P Motions in limine Binders). The Motions in limine Binder(s) shall include conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders, tabbed in numerical order with the opposition papers and reply papers for each motion placed directly behind the moving papers with a colored sheet of paper separating the moving, opposition, and reply papers.

Applies to

Exhibit binders

Parties must jointly prepare at least three sets of tabbed, numerically organized exhibit binders in three-ring binders for the Court, the Judicial Assistant, and the witnesses, plus any sets needed for each party.

The parties' counsel and any self-represented parties shall work together to jointly prepare at least three sets of tabbed exhibit binders organized numerically in three-ring binders (Exhibit Binders): a set for the Court, a set for the Judicial Assistant, and a set for the witnesses, in addition to any sets necessary for each party.

Applies to

Exhibit binders

One set of the Exhibit Binders must be brought to the Final Status Conference for the court to review.

The parties' counsel and any self-represented parties shall bring one set of the Exhibit Binders to the Final Status Conference for the court to review.

Applies to

Trial binder

A jointly prepared, tabbed physical Trial Binder with conformed copies and a table of contents (including tabs for operative pleadings, optional trial briefs, joint witness list, joint statement of the case, jury instruction lists, verdict forms, and the deposition designation chart) must be lodged in Department P on the date of the Final Status Conference.

On the date of the Final Status Conference, the parties' counsel and any self-represented parties must jointly prepare and lodge in Department P a physical Trial Binder, consisting of conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following: Tab: Copies of the Operative Pleadings (Complaint, Answer, Cross-Complaint, etc.) Tab: Trial Briefs (optional but recommended) Tab: Joint Witness List Tab: Joint Short Statement of the Case to Be Read to the Jury Tab: Joint List of Jury Instructions Tab: Joint and Contested Jury Instructions Tab: Joint or Contested Verdict Form(s) Tab: Joint Chart of Page and Line Designations for Deposition and Former Testimony.

Applies to

Proposed jury instructions

Proposed jury instructions must be organized into 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 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.

Applies to

Written showing

Written showing must be filed prior to OSC hearing for failure to comply with court order; oral explanations are not accepted.

If the court sets an order to show cause for a failure to comply with a direct court order, sanctions will be imposed unless a written showing is filed prior to the hearing on the OSC. Oral explanations will neither be sought nor accepted.

Applies to

Proof of service

Must include

certificate of service

OSC set concurrent with CMC for case prosecution, proof of service filing, and CMC statement submission; failure to file CMC statement with no proof of service triggers sanctions.

An OSC will be set concurrently with the CMC date regarding 1) prosecution of the case, 2) filing a proof of service of the summons and complaint; and 3) filing a case management statement. A represented Plaintiff’s failure to file a CMC statement when no proof of service has been filed will result in monetary sanctions against Plaintiff’s counsel.

Applies to

Ex parte application

If an ex parte pertains to a law and motion matter, the motion must be reserved in the Court Reservation System (or E-Court) before the ex parte is filed.

If the Ex Parte pertains to a Law and Motion matter, the Motion must be reserved in the Court Reservation System (or E-Court) prior to the Ex Parte filing.

Applies to

Motion

Parties must reserve a hearing date for any motion through the Court Reservation System before the motion can be heard.

Parties must reserve a hearing date for any motion through the Court Reservation System.

Applies to

Joint witness list

The joint witness list must include all witnesses on one list with realistic time estimates for direct, cross, and redirect testimony, totals at the bottom, no duplicate names, and designation of each witness as percipient or expert with area of expertise.

JOINT WITNESS LIST. The parties shall list all witnesses, with realistic estimates for direct and cross-examination on one list. See, LASCR 3.25(g)(5). Do not repeat the name of a witness who will be called by more than one party. The witness list should have columns that indicate for each witness the total time expected for direct, cross, and redirect testimony. At the bottom of the list, provide the total the time estimated for all testimony. Make realistic time estimates. The list should specify if the witness is percipient or expert (with area of expertise).

Applies to

Joint witness list

Witnesses not listed on the joint witness list will be excluded from testifying or limited to impeachment or rebuttal only.

Any person who is not listed on the joint witness list shall be either excluded from testifying or his or her testimony shall be limited to only impeachment or rebuttal.

Applies to

Joint exhibit list

The joint exhibit list must contain specified columns (Ex. No., Description, Offered by, Stipulated, Objection, Date ident., Date admit), counsel must meet and confer before filing to resolve foundation/admissibility objections, and submission does not waive objections.

The Joint Exhibit List shall have the following columns: Ex. No., Description, Offered by, Stipulated, Objection, Date ident., and Date admit. Counsel must meet and confer prior to filing of the Joint Exhibit List in an effort to resolve any objections as to the foundation and admissibility of exhibits, with stipulations as to foundation and admissibility where feasible. Submission of the joint exhibit list shall not be deemed a waiver of any objection to the admission into evidence at trial of any exhibit on the list.

Applies to

Joint jury instructions

The parties must file a joint set of CACI jury instructions with all headings and information completed, no remaining brackets or blanks, no tear sheets, and no disposition box on individual instruction pages.

JOINT JURY INSTRUCTIONS. The parties shall file a joint set of proposed agreed and not agreed CACI jury instructions with headings and all information filled in (e.g., singular or plural, gender, etc.), and no remaining brackets or blanks. See, LASCR 3.25(g)(7). Do not use tear sheets for the instructions and do not include the disposition box on the page of the individual instruction.

Applies to

Joint jury instructions

Disputed jury instructions must be filed in separate sets only after counsel meet and confer, and the instructions must include a disposition table listing each instruction by number, the proposing/opposing parties, and court ruling columns.

Instructions as to which there are disagreements should be provided in separate sets. However, disputed jury instructions may be filed only if counsel have met and conferred. The jury instructions should include a disposition table that lists all jury instructions by number, the identity of the party or parties proposing (or opposing) the instruction, and include columns for the court to use to indicate whether the instruction is given, modified, withdrawn or refused.

Applies to

Daily witness list

Each morning, counsel must give the Court Attendant a written list of that day's witnesses with full correct spellings and the order of calling.

Each morning counsel must provide the Court Attendant with a written list of witnesses to be called that day including their full names with correct spellings and the order in which they will be called.

Applies to

Revised exhibit list

At the end of trial, counsel must prepare and lodge a revised exhibit list reflecting only admitted exhibits, which will be provided to the jury during deliberations.

At the end of the trial, counsel will be required to prepare and lodge with the court a revised exhibit list that reflects only those exhibits that have been admitted. The revised exhibit list will be provided to the jury during their deliberations.

Applies to

Continuance stipulation

Must include

proposed order

Continuance stipulations must include a proposed order filed on eCourt.

All hearings and conference dates, including trial dates, may be considered for continuance via stipulation and proposed order (filed on eCourt).

Applies to

Motion

The motion's reservation number must appear on every document filed in connection with that motion.

All parties to a motion must place the reservation number associated with the motion on each document associated with that motion.

Applies to

Discovery dispute statement

No exhibits may be attached to the informal discovery conference statement.

No exhibits may be attached.

Applies to

Exhibit list

Each party must prepare an exhibit list using the form attached to the standing order.

Each party must prepare an exhibit list in the form attached hereto.

Applies to

Media evidence

Counsel planning to admit media such as video or audio tapes must raise the issue at the final status conference.

If counsel plan to admit media such as video or audio tapes, counsel must raise the issue at the final status conference.

Applies to

Ex parte application

Ex parte applicants must file a declaration containing competent testimony about the notice information and the other parties' responses or intent to attend (CRC 3.1204).

The ex parte applicant must file a declaration containing competent testimony detailing the information given in the notice as well as the other party’s/parties’ response(s) or intent to attend. (California Rules of Court, rule 3.1204.)

Applies to

Notice of settlement

The Notice of Settlement must be submitted on Judicial Council Form CM-200.

Notice of Settlement must be filed electronically by plaintiff using Judicial Council Form CM-200, even if the case settled at a judicial settlement conference.

Applies to

Objection to proposed judgment

Objections to proposed judgments must comply with California Rules of Court, rule 3.1590.

Objections to proposed judgments must comply with California Rules of Court, rule 3.1590.

Applies to

Proposed order

Proposed orders must comply with California Rules of Court, rule 3.1312.

Proposed orders must comply with California Rules of Court, rule 3.1312.

Applies to

Declaration unexchanged exhibit

A party introducing an unexchanged exhibit on its direct case must file a written declaration containing competent evidence of its inability to comply with the Trial Preparation Order.

NOTE: If a party would like to introduce an exhibit on its direct case that was not exchanged as described herein, the party must file a written declaration containing competent evidence in support of any claim that the party was unable to comply with this Court's Trial Preparation Order and with these policies and procedures.

Applies to

Joint trial documents

Self-represented parties and counsel must prepare joint trial documents, including deposition testimony designations, and address objections or counter-designations.

Self-represented parties and counsel must prepare joint trial documents, including the designation of deposition testimony to be used as direct evidence at trial (particularly videotaped depositions). Any objections or counter-designations must also be addressed during this process.

Applies to

Trial binder

Stipulations as to undisputed facts must be clearly documented and included in the Trial Binder under Tab J.

NOTE: All self-represented parties and counsel should strive to reach stipulations regarding all relevant facts that are not in dispute. These stipulations must be clearly documented and included in the Trial Binder under TAB J.

Applies to

Joint jury instructions

In jury trials, the parties must work together to agree on joint jury instructions and verdict forms customized with case-specific details such as party names.

JURY TRIALS ONLY - The parties must work together to agree, as much as possible, on joint jury instructions and verdict forms. These documents should be customized to fit the facts of the case, including the insertion of party names and any other case-specific details.

Applies to

Pattern jury instructions

Proponents of pattern jury instructions must indicate whether the instructions have been modified.

Proponents of pattern jury instructions must note if they have been modified.

Applies to

Trial binder documents

All Trial Binder documents (except Jury Instructions (Full Text) in Tab G and Verdict Form(s) in Tab H) must be signed, filed, and conformed before being placed in the binder.

All documents in the Trial Binder, except the Jury Instructions (Full Text) in Tab G and the Verdict Form(s) in Tab H must be signed, filed and conformed before they are put into the Trial Binder.

Applies to

Joint statement of the case

In jury trials, the parties must provide a single Joint Statement of the Case (separate statements not accepted) setting forth the basic facts, to be read to the jury by the judge, and it must be conformed.

The parties must provide a Joint Statement of the Case to be read to the jury by the judge, setting forth the basic facts of the case (e.g., date, time and location of the incident, type of occurrence, names of parties). Separate Statements will not be accepted. The Joint Statement in the Trial Binder must be conformed.

Applies to

Joint witness list

The Joint Witness List must follow the Trial Preparation Order Exhibit 3 format with a single alphabetized grid (no separate plaintiff/defendant grids, no duplicates), noting any interpreter, accommodation, or other special needs.

The Joint Witness List shall be in the format provided in the Trial Preparation Order, Exhibit 3, see attached below. There shall be only one list on the grid – i.e., there should not be separate grids for plaintiff and defendant. The witness names should be alphabetized by last name and there should be no duplicates. Note whether the witness needs an interpreter, a reasonable accommodation, or has another special need.

Applies to

Joint witness list

All witness time estimates must be filled in with sub-totals and a grand total, and the total time on the Witness List may not exceed the time estimate for the testimony portion of the trial.

All time estimates must be filled in and sub-totals and a grand total completed. The total time represented on the Witness List shall not exceed the time estimate for the testimony portion of the trial.

Applies to

Joint witness list

The alphabetical Joint Witness List must be followed by a tentative list of the proposed order of witnesses, and the Joint Witness List in the Trial Binder must be conformed.

The alphabetical list should be followed by a tentative list of the order in which the witnesses are proposed to be presented. The Joint Witness List in the Trial Binder must be conformed.

Applies to

Joint exhibit list

The Joint Exhibit List must be prepared in the format provided in Trial Preparation Order Exhibit 5 as a single list (text truncated in source).

The Joint Exhibit List must be prepared in the format provided in the Trial Preparation Order, Exhibit 5, see attached below. There should be a single,

Applies to

Jury instructions

Self-represented parties and counsel must prepare a list of joint and disputed jury instructions plus a complete set of printed, full-text proposed jury instructions for the Trial Binder.

Self-represented parties and counsel shall prepare a list of joint and disputed jury instructions, and must also prepare a complete set of printed, full-text and edited proposed jury instructions and include them in the Trial Binder.

Applies to

Joint verdict form

Self-represented parties and counsel must prepare and jointly file Joint Verdict Form(s) that bear no party's or counsel's name.

Self-represented parties and counsel shall prepare and jointly file Joint Verdict Form(s). The Joint Verdict Form(s) shall not have any party's or counsel's name thereon.