Los Angeles Superior Court Document Filing Requirements

CRITICAL

Applies to

Motion in limine

Motions in limine must comply with CCP section 1005 notice provisions and include declarations complying 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).

CRITICAL

Applies to

Joint chart of page and line designations

Each counter-designating party's counter-designations in the joint chart must include six columns: witness number/name, date/type of testimony, page:line counter-designations, objections, the related designation number, and the court's ruling.

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

CRITICAL

Applies to

Joint witness list

The parties must jointly prepare and file a joint witness list (excluding impeachment and rebuttal witnesses) with specified columns and a grand total of estimated testimony times, and any witness not included on the list is subject to being excluded from testifying at trial.

The parties’ counsel and any self-represented parties shall work together to prepare and file a joint list of all witnesses whom any party intends to call at trial, excluding impeachment and rebuttal witnesses. (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. Any witness who is not included on the joint witness list is subject to being excluded from testifying at

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 Statement to Be Read to the Jury Tab E: Joint List of Jury Instructions Tab F: Joint and Contested Jury Instructions Tab G: Joint or Contested Verdict Form(s) Tab H: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab I: 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 Statement to Be Read to the Jury Tab E: Joint List of Jury Instructions Tab F: Joint and Contested Jury Instructions Tab G: Joint or Contested Verdict Form(s) Tab H: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab I: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).

CRITICAL

Applies to

Proposed jury instructions

For jury trials, the parties must jointly prepare a complete set of full-text proposed jury instructions with CACI instructions edited, party names inserted, and blanks and inapplicable material eliminated.

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

Ex parte application

Ex parte applications must comply with California Rules of Court, rules 3.1200-3.1207.

Ex parte applications must comply with the requirements of California Rules of Court, rules 3.1200-3.1207.

CRITICAL

Applies to

Joint exhibit list

Counsel and self-represented parties must jointly prepare and file an exhibit list in a prescribed column format and must meet and confer to resolve authentication 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.

CRITICAL

Applies to

Joint list of proposed jury instructions

For jury trials, counsel and self-represented parties must jointly prepare and file a joint 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”).

CRITICAL

Applies to

Joint chart of page and line designations

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

CRITICAL

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 for Deposition and Former Testimony.

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”).

CRITICAL

Applies to

Joint exhibit list

Counsel and self-represented parties must jointly prepare and file a joint exhibit list stating eight specified items 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 (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).)

CRITICAL

Applies to

Witness list

A 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.

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

Trial preparation binders

Parties must prepare the documents required in Sections 2.B-D and the Motions in Limine Binder, Exhibit Binders, and Trial Binder required in Sections 3-5 for discussion at the meet and confer.

(1) discuss and prepare the documents required in Sections 2.B-D, below, and the Motions in Limine Binder, Exhibit Binders, and Trial Binder required in Sections 3-5, below,

CRITICAL

Applies to

Opposition and reply papers

Must include

caption

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

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

CRITICAL

Applies to

Proposed order

Proposed orders for motions to withdraw as counsel must include client address, phone number, and email.

MOTIONS TO WITHDRAW AS COUNSEL: Proposed order must contain the address, telephone number and email address of the client(s).

CRITICAL

Applies to

Proposed order

Any party may secure a private court reporter with a proposed order designating the reporter as the official reporter.

Any party may secure a private court reporter with a proposed order designating the reporter as the official reporter.

CRITICAL

Applies to

Notice of related cases

Notices of related cases must comply with California Rules of Court 3-300 and be filed in both the older and the newer case.

Comply with California Rules of Court 3-300 regarding Notice of Related Cases. Notice must be filed in the low-number (older) case, as well as the higher- number (younger) case.

CRITICAL

Applies to

Joint proposed verdict form

A joint proposed verdict form must be efiled five court days before the FSC.

Joint Proposed Verdict Form

CRITICAL

Applies to

Motion

Must include

proposed order

Please submit proposed orders for all motions and ex parte applications.

Please submit proposed orders for all motions and ex parte applications.

CRITICAL

Applies to

Joint statement of the case

A joint statement of the case must be efiled five court days before the FSC unless the parties request mini-openings.

Joint Statement of the Case (unless parties request mini opening)

CRITICAL

Applies to

Joint proposed jury instructions

Joint proposed jury instructions must be submitted in three categories (agreed; plaintiff-requested/defendant-objected; defendant-requested/plaintiff-objected), fully edited, printed out and delivered to Dept. B.

Joint Proposed jury instructions in three categories: (1) agreed by counsel; (2) plaintiff requests/defendant objects; (3) defendant requests/plaintiff objects. All instructions, fully edited, printed out and delivered to Dept. B

CRITICAL

Applies to

Motion

Must include

proposed order

PROPOSED ORDERS: Please submit proposed orders for all motions and ex parte applications.

PROPOSED ORDERS: Please submit proposed orders for all motions and ex parte applications.

CRITICAL

Applies to

Depositions

Depositions must be lodged before trial with page and line designations.

Depositions must be lodged prior to trial, with page/line designations

CRITICAL

Applies to

Exhibit books

Five sets of exhibit books, tabbed and indexed, must be delivered to Dept. B.

Exhibit Books, 5 sets, tabbed and indexed, delivered to Dept. B

CRITICAL

Applies to

Joint witness list

A joint witness list including testimony time estimates must be efiled five court days before the FSC.

Joint Witness List, including testimony time estimates.

CRITICAL

Applies to

Notice of lodging depositions

Depositions must be lodged with a Notice of Lodging Depositions that includes all page/line designations.

Depositions shall be lodged 5 court days before trial with a Notice of Lodging Depositions, including all page/line designations.

CRITICAL

Applies to

Joint exhibit list

The joint exhibit list must include columns for the date the exhibit was identified and the date it was admitted.

Joint Exhibit List: include columns for DATE ID’d and DATE ADMITTED

CRITICAL

Applies to

Motion to withdraw as counsel

Must include

proposed order

A proposed order on a motion to withdraw as counsel must state the client's address, telephone number, and email address.

Proposed order must contain the address, telephone number and email address of the client(s).

CRITICAL

Applies to

Notice of lodging depositions

Notice of Lodging Depositions must include all page/line designations.

Depositions shall be lodged 5 court days before trial with a Notice of Lodging Depositions, including all page/line designations.

CRITICALCivil cases

Applies to

Designation charts

Each designation chart must contain the designation, objection, counter-designation, and response to counter-designation, plus a far-right column for the court's rulings.

Three charts, in Word® or Adobe® format, (and/or hard copy/paper, if ordered by the court) organized separately into Tier One, Tier Two and Tier Three, in the matrix set forth below containing the designation, objection, counter-designation, and response to counter-designation, together with a column on the far right side of the chart for the court's rulings.

CRITICALCivil cases

Applies to

Document production

Subsequently produced documents must be labeled in consecutive Bates order, and previously produced documents must retain their original Bates numbering sequence.

Documents which are subsequently produced must be labeled in consecutive Bates Stamp order. If any documents have been previously produced in another matter, the parties shall use the same Bates numbering sequence originally assigned, rather than applying a new set of identification numbers.

CRITICALCivil cases

Applies to

Joint exhibit list

The JOINT EXHIBIT LIST shall include the following information in column format: 1. Exhibit number 2. Party offering exhibit 3. Exhibit description 4. Whether authenticity is stipulated (Yes/No) 5. Whether admissibility is stipulated (Yes/No) 6. Objection 7. Bases of objection

The JOINT EXHIBIT LIST shall include the following information in column format: 1. Exhibit number 2. Party offering exhibit 3. Exhibit description 4. Whether authenticity is stipulated (Yes/No) 5. Whether admissibility is stipulated (Yes/No) 6. Objection 7. Bases of objection

CRITICALCivil cases

Applies to

Proposed jury instructions

Jury instruction submissions must include full-text copies of agreed CACI instructions and requested CACI instructions with objections (all blanks filled in), plus agreed and contested plaintiff/defendant special instructions with authorities cited.

2. Full text copies of agreed upon CACI jury instructions, edited with all blanks filled in as appropriate. filled in as appropriate, to which there are objections. 4. Full text copies of defendant requested CACI instructions, edited with all blanks filled in as appropriate, to which there are objections. 5. Agreed upon special instructions, with authorities cited. 6. Plaintiff special instructions to which there are objections with authorities cited. 7. Defendant special instructions to which there are objections, with authorities cited.

CRITICALCivil cases

Applies to

Joint jury verdict form

Parties must submit a proposed Joint Jury Verdict Form containing agreed-upon parts plus separately stated objected-to additional portions from plaintiff and defendant.

The parties shall submit to the court a proposed Joint Jury Verdict Form containing: 1. Agreed upon parts of proposed Joint Verdict Form; 2. Separately stated, plaintiff’s additional portions of proposed Jury Verdict Form, to which there are objections; 3. Separately stated, defendant’s additional portions of proposed Jury Verdict Form to which there are objections.

CRITICALCivil cases

Applies to

Production cover letter

Produced documents must be provided as secure files via a downloadable link in a dedicated cover letter stating the cases, general document categories, and Bates range.

Parties shall provide secure files via a downloadable link included in a dedicated cover letter, setting forth the cases to which the documents relate, the general categories of documents, and the Bates range for the documents.

CRITICALCivil cases

Applies to

Deposition document production

Deposition document productions must include an index mirroring the response to the Standard Request for Production of Documents to Defendant (Exhibit 14F to General Order No. 14), identifying responsive documents by Bates number and stating when no documents are produced for a request.

The document production must include an index that mirrors the response to Standard Request for Production of Documents to Defendant (Exhibit 14F to General Order No. 14), in order to clarify which specific documents (by Bates number) are responsive to each request. If there are no documents produced for a request, that must be stated in the index.

CRITICALCivil cases

Applies to

Production response

Parties must identify all produced documents in their production responses by the specific request number and the beginning and ending Bates-stamped page numbers.

All parties either in their response to document production requests or in a production response served at the time of production, shall generally identify all documents which they produce in a case, with the specific request number to which the document responds pursuant to Code of Civil Procedure section 2031.280, by the beginning and ending number-stamped pages.

CRITICALCivil cases

Applies to

Motion to compel discovery

A party relying on pleadings, file documents, or other discovery items in a motion to compel must summarize each relevant document.

(5) If the pleadings, other documents in the file, or other items of discovery are relevant to the motion, the party relying on them must summarize each relevant document.

CRITICALCivil cases

Applies to

Motion to compel discovery

The opposing party must include a statement of the factual and legal reasons against compelling further responses, answers, or production as to each disputed matter.

(7) A statement by the opposing party of the factual and legal reasons for not compelling further responses, answers, or production as to each matter in dispute.

CRITICALCivil cases

Applies to

Third party document production

Documents obtained from third parties must be promptly Bates stamped using letters identifying the producing entity, unless already Bates stamped by the third party.

Parties who obtain documents from third parties, including medical providers, pursuant to business records subpoenas, deposition subpoenas, or otherwise, shall promptly Bates stamp all such documents, using letters identifying the entity producing the documents (unless the documents have been already Bates stamped by the third party, in which case re-stamping is not necessary), and upload the documents via FSX in compliance with the court’s electronic service orders.

CRITICALCivil cases

Applies to

Joint exhibit list

The Joint Exhibit List must be signed by counsel for each party.

The JOINT EXHIBIT LIST must be signed by counsel for each party.

CRITICALCivil cases

Applies to

Certification

Recipients of Confidential or Highly Confidential Materials may not disclose them (including notes or records made about them) to anyone except as expressly permitted by the Protective Order, and may not copy or use them except solely for purposes of the Proceeding.

I understand that the Confidential Materials and Highly Confidential Materials, as defined in the Protective Order, including any notes or other records that may be made regarding any such materials, shall not be Disclosed to anyone except as expressly permitted by the Protective Order. I will not copy or use, except solely for the purposes of this Proceeding, any Confidential Materials or Highly Confidential Materials obtained pursuant to this Protective Order, except as provided therein or otherwise ordered by the Court in the Proceeding.

CRITICALCivil cases

Applies to

Joint statement of the case

The Joint Brief Statement of the Case must be signed by counsel for each party.

The Joint Brief Statement of the Case shall be signed by counsel for each party.

CRITICALCivil cases

Applies to

Conformed copy of complaint

For cases originally filed in a county other than Los Angeles County, a party may file a conformed copy of the complaint indicating “New JCCP No. 5378 Coordination Proceeding-Silicosis Case” and file a Petition for Coordination of Add-On case pursuant to Rule of Court 3.544, including service on all appearing parties and on the Judicial Council.

For cases originally filed in a county other than Los Angeles County, a party may file a conformed copy of the complaint indicating “New JCCP No. 5378 Coordination Proceeding-Silicosis Case” and file a Petition for Coordination of Add-On case pursuant to Rule of Court 3.544, including service on all appearing parties and on the Judicial Council.

CRITICALCivil cases

Applies to

Joint witness list

The Joint Witness List must include, in column format, the witness's name (alphabetical), calling party, relationship to case, brief description of testimony, and whether the witness is actually expected to testify.

The JOINT WITNESS LIST shall include the following information in column format: 1. Name of the Witness (listed alphabetically) 2. Party calling witness 3. Relationship to case 4. Brief description of testimony 5. Indication whether witness, in good faith, is actually expected to testify

CRITICALCivil cases

Applies to

Deposition notice

A deposition notice for a defendant's Person Most Knowledgeable and/or Custodian of Records must state whether the deposition will be conducted in person or via Zoom.

Plaintiff may notice the deposition of defendant, including but not limited to, defendant’s Person Most Knowledgeable and/or Custodian of Records, either in person or via Zoom. This election shall be set forth in the deposition notice.

CRITICALCivil cases

Applies to

Plaintiff disclosure

A plaintiff seeking trial preference must provide case defendants with a completed Plaintiff Fact Sheet, a list of all known medical providers including the Primary Treating Physician, signed record authorizations, and all non-privileged medical and pharmacy records.

Plaintiff will also provide the case defendants with the following: (1) Plaintiff Fact Sheet- To the extent not previously provided, plaintiff shall provide a completed PFS. A completed PFS is defined as, at minimum, providing answers to all questions contained in the PFS, and all required documents; (2) A list of all known medical providers of the plaintiff, including the identity of the Primary Treating Physician; (3) Authorizations- to the extent not previously provided, completed and signed originals of all record authorization forms that are part of the PFS, including medical record authorizations for all known medical providers within the claimed exposure period; (4) Medical and pharmacy records- all non-privileged medical and pharmacy records within the Plaintiffs' possession, custody or control.

CRITICALCivil cases

Applies to

Pleading

Pleadings must identify the lowest numbered JCCP case name, Gonzalez vs. ADB Global Trade.

identify the lowest numbered JCCP Case name (Gonzalez vs. ADB Global Trade);

CRITICALCivil cases

Applies to

Plaintiff preliminary fact sheet

The Plaintiff Preliminary Fact Sheet must be verified by the Plaintiff, or in wrongful death cases by the personal representative/successor in interest of the decedent's estate.

The Plaintiff Preliminary Fact Sheet shall be verified by the Plaintiff or, in wrongful death cases, by the personal representative/successor in interest of the decedent's estate.

CRITICALCivil cases

Applies to

Defendant preliminary fact sheet

The Defendant Preliminary Fact Sheet must be verified by a declaration under penalty of perjury under California law, identifying the declarant's role and the defendant, and including the execution date, location, signature, and printed name.

I , declare that I am the of (Defendant Name], a party to this action. I have read the foregoing DEFENDANT PRELIMINARY FACT SHEET and know the contents thercof are true and correct. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on , at Signature: Printed Name: