Los Angeles Superior Court Document Filing Requirements

CRITICALCivil cases

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.

CRITICALCivil cases

Applies to

Joint jury instructions

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the instruction, and include columns for the court to use to indicate whether the instruction is given, modified, withdrawn or refused.

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the instruction, and include columns for the court to use to indicate whether the instruction is given, modified, withdrawn or refused.

CRITICALCivil cases

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.

CRITICALCivil cases

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.

CRITICAL

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.

CRITICAL

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.

CRITICAL

Applies to

Discovery dispute statement

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

No exhibits may be attached.

CRITICAL

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.

CRITICAL

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.

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.

CRITICAL

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,

CRITICAL

Applies to

Joint witness list

Witnesses not on the joint witness list may be excluded from testifying (except for impeachment or rebuttal) unless the party first shows good cause to the court.

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

CRITICAL

Applies to

Trial binder

Tab A Trial Briefs (Optional. If no trial briefs are filed, leave Tab A empty.) Tab B Motions in limine Tab C Joint Statement of the Case Tab D Joint Witness List Tab E Joint Exhibit List Tab F Joint and Disputed Jury Instructions List Tab G Jury Instructions (Full Text) Tab H Verdict Form(s) Tab I Deposition and Former Testimony Transcript Designations Tab J Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint) Tab K Proposed Additional Voir Dire Questions for the Court

Tab A Trial Briefs (Optional. If no trial briefs are filed, leave Tab A empty.) Tab B Motions in limine Tab C Joint Statement of the Case Tab D Joint Witness List Tab E Joint Exhibit List Tab F Joint and Disputed Jury Instructions List Tab G Jury Instructions (Full Text) Tab H Verdict Form(s) Tab I Deposition and Former Testimony Transcript Designations Tab J Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint) Tab K Proposed Additional Voir Dire Questions for the Court

CRITICAL

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 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.)

CRITICAL

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.)

CRITICAL

Applies to

List of admitted exhibits

The parties must submit to the Court's judicial assistant an agreed-upon list of all exhibits admitted that day.

submit to the Court's judicial assistant an agreed-upon list of all exhibits admitted that day.

CRITICAL

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.

CRITICAL

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.

CRITICAL

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.

CRITICAL

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.

CRITICAL

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.

CRITICAL

Applies to

Trial binder

For bench trials (trials without a jury), the Trial Binder must include only the documents listed under Tabs A, B, D, E, I, and J.

For trials by the court without a jury, the Trial Binder shall only include the documents listed under Tabs A, B, D, E, I, and J:

CRITICAL

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.

CRITICAL

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.

CRITICAL

Applies to

Trial binder

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.

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.

CRITICAL

Applies to

Proposed jury instructions list

For jury trials, the parties must jointly file a list of proposed jury instructions per Exhibit 4 indicating joint/stipulated status, disputes, objections, and a column for the Court's ruling.

For jury trials, the self-represented parties and counsel shall work together to prepare and file a joint list of proposed jury instructions in accordance with Exhibit 4, page 11 below. The jury instructions should be listed on the appropriate table, indicating whether the jury instruction is joint or stipulated to, disputed, a concise statement of any objection, and a column for the Court’s ruling.

CRITICAL

Applies to

Joint deposition designation chart

Parties intending to use deposition or former trial testimony must meet and confer and jointly prepare and file a joint Deposition Testimony Designation and Objections chart in the format set forth in Exhibit 6.

If any parties intend to use deposition testimony or former trial testimony in lieu of or in addition to a witness's live testimony, self-represented parties and counsel shall meet and confer to discuss, and work together to prepare and file, a joint Deposition Testimony Designation and Objections chart in the format set forth in Exhibit 6, page 13 – 14 below.

CRITICAL

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.

CRITICAL

Applies to

Joint exhibit list

Counsel and self-represented parties must jointly prepare and file an exhibit list organized per Exhibit 5 with eight specified columns for each trial exhibit.

The parties’ counsel and any self-represented parties shall work together to prepare and file a joint exhibit list organized with columns prepared in accordance with Exhibit 5 at page 12 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.)

CRITICAL

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.

CRITICAL

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.

CRITICAL

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.

CRITICAL

Applies to

Joint witness list

Counsel and self-represented parties must jointly prepare and file a witness list, organized per Exhibit 3, covering all direct-case witnesses (excluding impeachment and rebuttal witnesses).

The parties' counsel and any self-represented parties shall work together to prepare and file a joint list of all witnesses any party intends to call on their direct case at trial (excluding impeachment and rebuttal witnesses). (Local Rule 3.25.) The joint witness list shall be organized as shown in Exhibit 3, page 10 below.

CRITICAL

Applies to

Proposed jury instructions

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

CRITICAL

Applies to

Joint witness list

JOINT WITNESS LIST FSC: Date TRIAL: Date Witness Name (Alpha by Last Name) Interp., P/D ADA, other? Brief Direct/ Cross Subtotal Description Redir. (Hrs) (Hrs) (Hrs) TOTAL HOURS Proposed Order of Witnesses: Plaintiff Case in Chief Plaintiff Witness One – First Last Plaintiff Witness Two – First Last Defendant Case in Chief: Defense Witness One – First Last Defense Witness Two – First Last DATED: ________________________ NAME Plaintiff/Attorney(s) for Plaintiff DATED: ________________________ NAME Defendant/Attorney(s) for Defendant

JOINT WITNESS LIST FSC: Date TRIAL: Date Witness Name (Alpha by Last Name) Interp., P/D ADA, other? Brief Direct/ Cross Subtotal Description Redir. (Hrs) (Hrs) (Hrs) TOTAL HOURS Proposed Order of Witnesses: Plaintiff Case in Chief Plaintiff Witness One – First Last Plaintiff Witness Two – First Last Defendant Case in Chief: Defense Witness One – First Last Defense Witness Two – First Last DATED: ________________________ NAME Plaintiff/Attorney(s) for Plaintiff DATED: ________________________ NAME Defendant/Attorney(s) for Defendant

CRITICAL

Applies to

Joint witness list

The joint witness list must total the estimated testimony times for all witnesses and state the grand total in the last column.

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.

CRITICAL

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.

CRITICAL

Applies to

Deposition designation pleading

When deposition transcripts or videotapes will be used in lieu of live testimony, a pleading setting out all designated testimony, objections, and cross-designated testimony must be prepared using the Trial Preparation Order Exhibit 6 format.

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, using the format provided in the Trial Preparation Order, Exhibit 6, see attached below.

CRITICAL

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.

CRITICAL

Applies to

Proposed verdict form

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

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.

CRITICAL

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.

CRITICAL

Applies to

Joint deposition designation chart

The joint deposition designation chart must contain six columns: witness number/name, date and type of testimony, page and line designations, objections, counter-designation information, and the court's ruling.

In the joint chart, each designating party's designations of deposition or former testimony shall include columns which state: (1) the number and name of the witness, (2) the date and type of testimony (e.g., deposition or trial testimony), (3) the page and line designations of the deposition or former testimony requested to be used, (4) any objections, (5) whether the other party has counter-designated any additional deposition or former testimony of the witness that relates to the designation, and, if so, the designation number of the counter-designation, and (6) the court's ruling.

CRITICAL

Applies to

Joint witness list

Witnesses not listed on the joint witness list are subject to exclusion from testifying, and a party seeking testimony from an unlisted witness must first show good cause to the court.

Any witness who is not included on the joint witness list is subject to being excluded from testifying at [...] seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the court.

CRITICAL

Applies to

Joint statement motion to compel further responses

Motions to compel further responses must be accompanied by a joint statement in a four-column format (request number, request text, response text, and brief bullet points from each party).

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.

CRITICAL

Applies to

Trial binder

Tab A: Trial Briefs (Optional. If no trial briefs are filed, leave Tab A empty.) Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab E: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).

Tab A: Trial Briefs (Optional. If no trial briefs are filed, leave Tab A empty.) Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab E: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).

CRITICAL

Applies to

Jury instructions

Proposed jury instructions must be organized behind Tab F in order: agreed-upon instructions, plaintiff's objected-to requests, then defendant's objected-to requests, labeled by cover sheets.

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

CRITICAL

Applies to

Trial preparation order documents and binders

prepare and submit the documents and binders required by that order.

prepare and submit the documents and binders required by that order.

CRITICAL

Applies to

Proposed verdict form

In jury trials, the parties must jointly prepare and file a proposed verdict form, and if they cannot agree, each party must file a separate 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.

CRITICAL

Applies to

Joint witness list

Counsel and self-represented parties must jointly prepare and file a witness list (excluding impeachment and rebuttal witnesses) in a prescribed column format with time estimates and a grand total.

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. (Los Angeles County Court Rule (“Local Rule”) 3.25, subd. (g)(5).) 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.

CRITICAL

Applies to

Motion in limine

Motions in limine must be noticed for hearing at the Final Status Conference, with CCP § 1005 notice and declarations complying with Los Angeles County Court Rule 3.57(a).

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 Los Angeles County Court Rule 3.57, subdivision (a).

CRITICAL

Applies to

Joint statement of the case

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

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).)