Los Angeles Superior Court Document Filing Requirements

CRITICAL

Applies to

Meet and confer declaration

A meet and confer declaration filed in support of a motion must state facts showing a reasonable and good faith attempt at informal resolution of each issue presented by the motion.

A meet and confer declaration in support of a motion shall state facts showing a reasonable and good faith attempt at an informal resolution of each issue presented by the motion. (Code of Civ. Proc. §2016.040.)

CRITICAL

Applies to

Joint witness list

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.

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.

CRITICAL

Applies to

Visual aids

Visual aids may not be used in opening statement unless opposing counsel has first been given the opportunity to review them prior to trial.

No visual aids shall be used in opening statement without opposing counsel first having been given the opportunity to review the visual aids prior to trial. (LASCR 3.97.)

CRITICAL

Applies to

Proposed verdict form

For jury trials, the parties must jointly prepare and file a proposed general or special verdict form acceptable to all parties, per Local Rule 3.25(g)(8).

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).)

CRITICAL

Applies to

Joint exhibit list

If an objection to an exhibit is not articulated on the exhibit list, the trial court may deem the exhibit admitted.

If an objection to an exhibit is not articulated on the exhibit list, the trial court may deem the exhibit admitted.

CRITICAL

Applies to

Joint witness list

Parties must jointly prepare and file a joint witness list (excluding impeachment and rebuttal witnesses) in a required column format; the format description is truncated in the provided text.

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 (I) 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

CRITICAL

Applies to

Ex parte application

An ex parte applicant must make an affirmative factual showing in a declaration of irreparable harm, immediate danger, or another statutory basis under CRC 3.1202(c); failure to do so is the most common reason for denial.

An applicant must make an affmnative 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. Rule 3.1202(c). This is the most common reason for denial of an ex parte application.

CRITICAL

Applies to

Joint statement of case

For jury trials, the parties must jointly prepare and file a brief joint written statement of the case for the court to read to the jury, per Local Rule 3.25(g)(4).

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).)

CRITICAL

Applies to

Joint chart deposition 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 chart deposition designations

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

In the joint chart, each designating party's designations of deposition or former testimony shall include columns which state: (I) 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

Request for idc

IDC requests must use form LACIV 094, lodged in Dept A, with hearing date reserved on CRS, indicating meet and confer method.

To request an IDC, please complete Los Angeles Superior Court form LACIV 094, lodge it in Department A, and reserve a hearing date on the Court Reservation System, which will reflect "Confirmed" upon approval by the court. The request shall indicate whether the parties have met and conferred in person or by videoconference.

CRITICAL

Applies to

Motion in limine

Meet and confer efforts for motions in limine must consist of more than one email advising the opposing party of the nature of the motion.

Meet and confer efforts shall consist of more than one email advising the opposing party(ies) of the nature of the motion.

CRITICAL

Applies to

Joint chart deposition designations

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

Powerpoint slides

Counsel intending to use PowerPoint must inform the Court at the final status conference and share a copy of the slides with opposing counsel before the presentation.

If counsel intends to use PowerPoint, the Court shall be informed at the FSC and a copy of the slides must be shared with opposing counsel prior to the presentation.

CRITICAL

Applies to

Final jury instructions

After the jury instruction conference, one party must submit the court-approved final set of jury instructions with court-ordered modifications and without the disposition table at the top of each instruction.

After the jury instruction conference, the court will require one of the parties to submit a final set of jury instructions approved by the court, including any modifications ordered by the court, and excluding the disposition table from the top of each instruction.

CRITICAL

Applies to

Trial binder

Tab A: Trial Briefs Tab B: Joint Witness List Tab C: Joint Exhibit List TabD: 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) TabH: Joint Chart of Page/Line Designations for Deposition/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 Tab B: Joint Witness List Tab C: Joint Exhibit List TabD: 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) TabH: Joint Chart of Page/Line Designations for Deposition/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

Informal discovery conference request

IDC requests must be made on form LACIV 094, lodged in Department A with a hearing date reserved on the Court Reservation System, and must indicate whether the parties met and conferred in person or by videoconference.

To request an IDC, please complete Los Angeles Superior Court form LACIV 094, lodge it in Department A, and reserve a hearing date on the Court Reservation System, which will reflect "Confirmed" upon approval by the court. The request shall indicate whether the parties have met and conferred in person or by videoconference.

CRITICAL

Applies to

Joint exhibit list

Joint exhibit lists must include specific columns, exhibits pre-numbered, exchanged, with pagination and translation requirements, filed 5 court days before FSC.

submit to Dept. 107 the following JOINT documents at least five court days before the FSC: b. Filed-Joint Exhibit List -- include columns for DATE ID'd and DATE ADMITTED. Pursuant to California Rule of Court 3.1110(f) and Los Angeles County Superior Court 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. For exhibits a party intends to admit into evidence, please indicate the moving party, stipulations on authentication in one column and stipulations on admissibility in the next column. If there are no objections, please state the basis for any objection i.e., hearsay, etc. Documentary exhibits consisting of more than one page must be internally paginated in sequential numerical order. Exhibits written in a foreign language must be accompanied by a certified English translation.

CRITICAL

Applies to

Trial brief

Trial briefs must be filed and served no later than 48 hours before opening statement, stating remaining causes of action and affirmative defenses.

No later than 48 hours before opening statement, the parties shall file and serve a trial brief indicating which causes of action and which affirmative defenses are still in issue.

CRITICAL

Applies to

Daily settled statement

If no court reporter is used, lead counsel must personally prepare a daily Settled Statement under CRC 8.137 after meet-and-confer sessions at lunch and close of the trial day, a task that cannot be delegated; unrepresented parties bear this responsibility themselves.

If a court reporter is not utilized, counsel must prepare a daily Settled Statement pursuant to California Rules o f Court 8.137. This means that if there is no court reporter, then lead counsel for each party must meet and confer at lunch and again at the close of the trial day to arrive at a settled statement. This task may not be delegated to another lawyer. If a party is unrepresented, then that party has the responsibility to meet with the other side to arrive at a settled statement.

CRITICAL

Applies to

Idc statement

An IDC statement must include a short case description, a description of the discovery dispute, the parties' informal resolution attempts and compromises, and any legal authority for the Court to consider.

The IDC statement shall include (a) a short description of the case, (b) a description of the discovery dispute including a list or summary of the discovery requests, objections, and/or answers at issue, (c) a description of the parties' informal attempts and any compromises offered to resolve the dispute, and (d) any legal authority the Court should consider in conducting the IDC.

CRITICAL

Applies to

Joint documents

Failure to timely comply with the FSC document requirements results in $250 monetary sanctions against counsel of record under CCP section 177.5.

Failure to timely comply will result in monetary sanctions in the sum of $250 against counsel of record for violation of court orders, CCP section 177.5.

CRITICAL

Applies to

Request for court reporting services

Requests for court reporting services must be made using local form SCLAC LACIV 269.

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

CRITICAL

Applies to

Settled statement proposals

Competing settled statement proposals must be accompanied by a declaration stating the parties met and conferred in good faith for at least three hours on the day of trial.

These proposals will be accompanied by a declaration stating that the parties have met and conferred in good faith for no less than three hours on the day of trial to arrive at a settled statement as well as a memorandum, not exceeding 5 pages in length, explaining why a particular proposed settled statement is more accurate.

CRITICAL

Applies to

Ex parte application

Ex parte applications must include proof of required notice and a showing of why the matter could not be brought as a noticed motion, and emergencies caused by procrastination or unexcused delay do not qualify for relief.

Among the most common grounds for denial of ex parte applications are failure to provide proof of required notice and 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.

CRITICAL

Applies to

Trial brief

The trial brief must indicate which causes of action and which affirmative defenses remain in issue.

No later than 48 hours before opening statement, the parties shall file and serve a trial brief indicating which causes of action and which affirmative defenses are still in issue.

CRITICAL

Applies to

Case management statement

Counsel must submit case management statements per California Rules of Court rule 3.725, and noncompliance with the cited rules or the court's scheduling orders 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 California Rules of Court, Rules 3.722, 3.724, 3.727 and 3.728, local rules 3.24 and 3.25, and/or this court's scheduling orders may result in monetary sanctions and/or delay in trial setting.

CRITICAL

Applies to

Joint witness list

Joint witness lists must list all witnesses once with estimated testimony time, filed 5 court days before FSC.

submit to Dept. 107 the following JOINT documents at least five court days before the FSC: a. Filed-Joint Witness List -- 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.

CRITICAL

Applies to

Jury instructions

Fully edited, printed jury instructions must be delivered to Dept. 107, with a joint complete set of CACI instructions and separate sets for any disputed instructions.

Delivered-Jury instructions, fully edited, printed out and delivered to Dept. 107. Submit a joint set of CACI 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.

CRITICAL

Applies to

Motion in limine

Must include

certificate of conference

Motions in limine must include a sworn declaration confirming meet and confer and stating opposing party's 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)

CRITICAL

Applies to

Daily settled statement

If no court reporter is used, counsel must prepare a daily Settled Statement pursuant to California Rules of Court 8.137.

As explained below, if a court reporter is not utilized, counsel must prepare a daily Settled Statement pursuant to California Rules of Court 8.137.

CRITICAL

Applies to

Exhibit books

Three tabbed and indexed sets of exhibit books must be delivered to Dept. 107, one each for the clerk, the judge, and the witness box.

Delivered-3 Sets of Exhibit Books, tabbed and indexed, and delivered to Dept. 107. (One set for the clerk, one set for the judge, one set for the witness box).

CRITICAL

Applies to

IDC statement

IDC statements must include case description, dispute details, informal resolution attempts, and relevant legal authority.

The IDC statement shall include (a) a short description of the case, (b) a description of the discovery dispute including a list or summary of the discovery requests, objections, and/or answers at issue, (c) a description of the parties' informal attempts and any compromises offered to resolve the dispute, and (d) any legal authority the Court should consider in conducting the IDC.

CRITICAL

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 meet-and-confer and stating the opposing party's position.

Los Angeles County Superior Court 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)

CRITICAL

Applies to

Depositions

Depositions must be lodged with the Clerk of the Court before trial begins, with a Notice of Lodging and means of return.

Lodge-Depositions must be lodged with the Clerk of the Court prior to the start of trial, with Notice of Lodging and means of return.

CRITICAL

Applies to

Exhibits

Parties may not publish any exhibits or graphics to the jury during trial unless they have been marked and received into evidence or the court permits it.

Pursuant to Los Angeles County Superior Court Rules 3.97 and 3.180, the parties shall not publish to the jury any exhibits or graphics at any time during trial except after being marked and received into evidence, or with the court's permission.

CRITICALCivil cases

Applies to

Notice of settlement

A trial date will not be vacated based on a telephonic representation of settlement; the plaintiff must file a Notice of Settlement to vacate the trial date.

The Court will not vacate a trial based on a telephonic representation that the case settled. Plaintiff must file a Notice of Settlement in order to vacate a trial date based on a settlement of the case.

CRITICAL

Applies to

Motions in limine

Each side may file no more than 5 motions in limine without leave of court.

Each side is limited to no more than 5 motions in limine, in the absence of leave of court.

CRITICAL

Applies to

Joint chart of page and line designations

Counter-designating parties' entries in the joint chart must include columns for witness designation number/name and date and type of testimony (remaining required columns truncated in source).

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

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

The parties must meet and confer to resolve authenticity and admissibility objections to each exhibit, and the joint exhibit list must reflect the result of that meet and confer.

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. The joint exhibit list must reflect the result of this meet and confer.

CRITICAL

Applies to

Joint witness list

Counsel and self-represented parties must jointly prepare and file a joint witness list of all trial 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 whom any party intends to call at trial, excluding impeachment and rebuttal witnesses.

CRITICAL

Applies to

Daily witness list

Each morning, counsel must give the Court Attendant a written list of that day's witnesses with correctly spelled full names and the order in which they will be called.

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.

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 with specified columns for each exhibit to be offered at trial.

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.

CRITICAL

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 to insert party names and remove 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.

CRITICAL

Applies to

Joint statement of case

For jury trials, counsel and any 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, subd. (g)(4).)

CRITICAL

Applies to

Motion for relief from motions in limine limit

A motion for relief from the motions in limine limit must include a declaration listing the proposed motions with supporting authority and a detailed description of meet-and-confer efforts.

The motion must include a declaration listing the proposed motions in limine as well as the authority pursuant to which each is properly brought as a motion in limine. The motion must also include a detailed description of the meet and confer efforts today concerning the matter raised in the motion in limine.

CRITICAL

Applies to

Joint witness list

Witnesses not on the joint witness list are subject to exclusion from testifying except for impeachment or rebuttal, and calling an unlisted witness requires a prior showing of good cause to the court.

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.

CRITICAL

Applies to

Proposed verdict form

For jury trials, the parties must jointly prepare and file a proposed general or special verdict form acceptable to all parties, and 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.