Los Angeles Superior Court Document Filing Requirements

CRITICAL

Applies to

Trial brief

Each trial brief must identify the disputed claims and defenses, major legal issues with supporting authorities, the relief and calculation of damages sought, and any other information assisting the court at trial.

(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.

CRITICAL

Applies to

Joint chart of page and line designations

Designating parties' entries in the joint chart must include columns for witness number/name, date and type of testimony, page and line designations, objections, related counter-designations, 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

Motion in limine

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

CRITICAL

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.

CRITICAL

Applies to

Joint list of proposed jury instructions

For jury trials, the parties must jointly prepare and file a Joint List of Proposed Jury Instructions stating, for each instruction, its 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 (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”).

CRITICALCivil cases

Applies to

Joint exhibit list

Counsel must meet and confer to prepare a joint list of exhibits that will be marked for identification and introduced at trial.

Counsel must meet and confer to prepare a joint list of exhibits, which will be marked for identification and introduced at trial.

CRITICALCivil cases

Applies to

Pretrial documents

At least five days before the final status conference, counsel must serve and file pre-marked exhibit lists, jury instruction requests, trial witness lists, and a proposed short statement of the case.

(1) At least five days prior to this conference, counsel must serve and file lists of pre-marked exhibits to be used at trial [see Local Rules 3.151, 3.53 and 3.149], jury instruction requests, trial witness lists, and a proposed short statement of the case to be read to the jury panel explaining the case. S.C.L.A.C. Rule 3.25 (f) (1).

CRITICALCivil cases

Applies to

Pretrial documents

Counsel must comply with S.C.L.A.C. Rule 3.25(f)-(h) regarding preparation for the final status conference and trial.

You are required to comply with S.C. L.A.C. Rule 3.25(f)-(h) concerning preparation for the final status conference and trial.

CRITICALCivil cases

Applies to

Original depositions

All original depositions must be lodged with the court before trial begins.

All original depositions must be lodged with the court prior to the beginning of trial.

CRITICALCivil cases

Applies to

Notice of case resolution

Must include

caption, case number

The notice of case resolution must include the caption, title, and case number.

The notice of case resolution shall be prepared on 28-lined legal paper to include caption, title, and case number.

CRITICALCivil cases

Must include

caption, case number

Notice of case resolution must include caption, title, and case number.

The notice of case resolution shall be prepared on 28-lined legal paper to include caption, title, and case number.

CRITICALCivil cases

Applies to

Verdict form

A general verdict form is mandatory and must be jointly prepared, and the special verdict form must be adapted to CACI with proper spacing for clarity and direction.

A general verdict form is mandatory and shall be jointly prepared in draft or final form. The special verdict form shall be adapted to CACI with proper spacing, particularly noted to allow for both clarity and direction. (LACCR 3-172,3.25 (i)(8).)

CRITICALCivil cases

Applies to

Exhibit objection

Objections to listed exhibits must be filed in writing with a brief statement of the grounds; objections not made in writing are deemed waived absent a showing of good cause.

Any party objecting to any listed exhibit, either as to foundation or admissibility, must file the objection in writing, together with 3 brief statement of the ground for objection. Any objections not so stated as per the foregoing shall be deemed waived except upon a showing of good cause.

CRITICALCivil cases

Applies to

Jury instructions

Jury instructions must be submitted in the court's specified format; instructions not submitted in that format will be returned.

Jury instructions shall be submitted as follows: (Note: Jury instructions not submitted in this format will be returned.)

CRITICALCivil cases

Applies to

Jury instructions

Each requested jury instruction must identify the requesting party/parties at the top, state whether it is to be given as requested or as modified or is withdrawn, and include a signature line for the Court.

form, which includes: a. At the top of each requested jury instruction, identification of the party/parties requesting instruction; b. Whether the instruction is to be given as requested or as modified; c. Whether the instruction is withdrawn; and d. A signature line for the Court.

CRITICALCivil cases

Applies to

Witness list

The jointly prepared witness list must include each witness's name, a description of testimony, direct/cross time estimates, potential scheduling problems, and interpreter needs.

The jointly prep ared witness list must include each witness’ name, a brief description of the testimony, a time estimate on direct and cross, any potential scheduling problems, and whether he/she will be assisted by an interpreter.

CRITICALCivil cases

Applies to

Motion in limine

Motions in limine must be in writing, served 10 court days before FSC, accompanied by LACCR 3.57 declaration, and numbered sequentially.

All motions in limine must be in writing and shall be served (in the possession of) opposing party or counsel at least ten (10) court days before the Final Status Conference date. Any opposition to any motion in limine must be in writing and served (in the possession of opposing party or counsel) at least five (5) court days prior to the Final Status Conference. Each motion in limine... shall be accompanied by a declaration in compliance with the requirements of Rule 3.57 of the LACCR. Each motion must be numbered sequentially (Plaintiff s Motion in Limine No., 1, Defendant’s Motion in Limine No.1).

CRITICALCivil cases

Applies to

Statement of case

Counsel must jointly prepare a short, non-argumentative written statement of the case to be read to the jury.

Jointly prepare a short, non-argumentative written statement of the case to be read to the jury.

CRITICALCivil cases

Applies to

Exhibit list

Counsel must jointly prepare and exchange a complete exhibit list of documents and physical evidence (excluding depositions, declarations, motions, interrogatories, responses, and pleadings), with all listed items exchanged or reviewed before the Final Status Conference.

Counsel must jointly prepare and exchange a complete Exhibit List including each document and item of physical evidence. Do not attach the exhibits to the list. Do not include depositions, declarations, motions, interrogatories, responses, or pleadings as exhibits. All items so referred to on the Exhibit List must be exchanged and/or reviewed by counsel prior to the Final Status Conference.

CRITICALCivil cases

Applies to

Trial brief

Trial briefs are mandatory in all cases and must include a description of claims/defenses, stipulated and admitted facts, contested issues of fact and law with supporting authorities, major evidentiary issues, and a detailed statement of relief with a damages breakdown.

Trial briefs are mandatory in all cases and must include: 1.) A brief description of the claims and 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 counsel. 4.) All contested issues of fact . 5.) All contested issues of law, together with points and authorities supporting the position of counsel. 6.) A list of major evidentiary issues anticipated and any relevant points and authorities in support of a position o f counsel. 7. ) A detailed statement of the relief claimed including a breakdown of the elements of damages claimed. 8.) Any other information that will assist the court

CRITICALCivil cases

Applies to

Motion in limine

Each motion in limine seeking to preclude inadmissible or prejudicial matter in the presence of the jury must be accompanied by a declaration complying with LACCR Rule 3.57.

Each motion in limine, for the purpose o f precluding the mention or display of inadmissible and prejudicial matter in the presence of the jury, shall be accompanied by a declaration in compliance with the requirements of Rule 3.57 of the LACCR.

CRITICALCivil cases

Applies to

Motion in limine

Must include

certificate of conference

Every motion in limine must be accompanied by a sworn meet-and-confer declaration stating the opposing party's position, and failure to include it results in summary denial.

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). Failure to include such a declaration will result in summary denial of MIL.

CRITICALCivil cases

Applies to

Joint witness list

The joint witness list must list every witness once, with per-witness testimony time estimates (direct, cross, re-direct) and total time estimates for each party and the entire trial, except for witnesses listed only to preserve the right to call them.

All witnesses must be listed on a joint witness 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 party and the entire trial. The parties do not need to provide time estimates for witnesses they do not intend to call but are being listed to preserve the right to call them if needed.

CRITICALCivil cases

Applies to

Joint jury instructions

Joint CACI jury instructions must be fully completed with no brackets or blanks, omit the 'Requested By' chart, place disputed instructions in separate sets identifying proposer and opposer, and include a disposition table.

Submit a joint set of CACI instructions will all information filled in – no remaining brackets or blanks. Do not include the chart at the top (i.e., "Requested By"). If 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 columns for the court to indicate whether the instruction is given, modified, withdrawn or refused.

CRITICALCivil cases

Applies to

Minor compromise petition

For personal injury cases, please ensure that all pertinent medical records are included in the petition, including admission reports, discharge reports, and treatment records. There is no need to include nursing notes, labs, radiology reports or other records unless they contain other information.

For personal injury cases, please ensure that all pertinent medical records are included in the petition, including admission reports, discharge reports, and treatment records. There is no need to include nursing notes, labs, radiology reports or other records unless they contain other information.

CRITICALCivil cases

Applies to

Motion in limine

Motions in limine should not be used to seek summary judgment, summary adjudication of issues, or judgement on the pleadings. Also, do not file motions in limine that simply state the law. For example, do not file motions seeking to exclude hearsay evidence. Instead, the motion must cite specific hearsay evidence that is expected to be proffered.

Motions in limine should not be used to seek summary judgment, summary adjudication of issues, or judgement on the pleadings. Also, do not file motions in limine that simply state the law. For example, do not file motions seeking to exclude hearsay evidence. Instead, the motion must cite specific hearsay evidence that is expected to be proffered.

CRITICALCivil cases

Applies to

Motion in limine

Must include

certificate of conference

Motions in limine require a pre-filing meet and confer and a sworn declaration attesting to the conference and 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). Failure to include such a declaration will result in summary denial of MIL.

CRITICALCivil cases

Applies to

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).

CRITICALCivil cases

Applies to

Proposed verdict form

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

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.

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 witness list

Witnesses not included on the joint witness list may be excluded from testifying at trial (except for impeachment or rebuttal) unless the party first shows 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 in the witness list must first make a showing to the court of good cause.

CRITICAL

Applies to

Moving papers

Moving papers for a reserved hearing date must display the reservation receipt number under the caption on the face page and attach the reservation receipt 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.

CRITICAL

Applies to

Declaration

Declarations filed in support of and in opposition to motions to compel further discovery responses must show the same meet-and-confer efforts, including in-person, virtual, or telephonic communications.

(The court requires this same showing in declarations filed in support of, and in opposition to, motions to compel further discovery responses.)

CRITICAL

Applies to

Exhibits

Counsel must prepare a joint set of exhibits for trial.

Counsel shall prepare a joint set of exhibits.

CRITICAL

Applies to

Verdict form

A jury panel cannot be ordered until an acceptable verdict form has been prepared.

A jury panel cannot be ordered until an acceptable verdict form has been prepared.

CRITICAL

Applies to

Opposition and reply papers

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

Special jury instruction

Each special jury instruction must indicate the party or parties requesting it.

Each such special instruction shall indicate the party/parties requesting the instruction.

CRITICAL

Applies to

Proposed verdict form

For jury trials, 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, 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

Proposed jury instructions

For jury trials, counsel and self-represented parties must jointly prepare a complete set of full-text proposed jury instructions using edited CACI instructions with party names inserted and blanks, brackets, and inapplicable material removed.

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 Jury Instructions (CACI) instructions, inserting party names, and eliminating blanks, brackets, and other irrelevant or inapplicable material.

CRITICAL

Applies to

Exhibit binder

Parties must jointly prepare at least five identical tabbed exhibit binders organized numerically in three-ring binders (court, judicial assistant, witnesses, and each party).

The parties counsel and any self-represented parties shall work together to jointly prepare at least five identical sets of tabbed, exhibit binders organized numerically in three-ring binders (Exhibit Binders): a set for the court, a set for the judicial assistant, a set for the witnesses, and a set for each party.

CRITICAL

Applies to

Joint list of proposed jury instructions

In jury trials, counsel and self-represented parties must jointly prepare and file a joint list of proposed jury instructions stating six required 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) that states, as to each jury instruction: (1) the jury instruction number (listed in numerical order), (2) the title of the jury instructions, (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

Jury instructions

Counsel must meet and confer to prepare a joint set of jury instructions.

A joint set of Jury Instructions. Counsel shall meet and confer to prepare this joint set.

CRITICAL

Applies to

Verdict form

A joint general verdict form and/or any requested special verdict forms must be prepared.

A Joint General Verdict Form, and/or any special verdict forms that are requested.

CRITICAL

Applies to

Joint witness list

The parties must jointly prepare and file a witness list (excluding impeachment and rebuttal witnesses) organized in columns showing each witness's name in alphabetical order, expert status and any special accommodations needed, the calling party, whether the witness is expected to testify, and a brief description of the expected testimony.

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) that state: (1) the name or 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,

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 in the specified format.

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’ 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 Designation for Deposition and Former Testimony).

CRITICAL

Applies to

Motion in limine

Each motion in limine caption 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.

CRITICAL

Applies to

Trial brief

Each party must submit a Trial Brief containing a description of claims and defenses, the primary legal issues with supporting authorities, the relief and damages sought, and any other information assisting the court with trial matters.

A Trial Brief from each party containing: 1. A brief description of the claims and defenses subject to litigation; 2. A list of the primary legal issues anticipated with supporting points and authorities; 3. A brie statement of the relief sought and a calculation of the damages sought; and 4. Any other information which counsel believes may assist the court in ruling upon trial objections or other matters that may arise at trial.

CRITICAL

Applies to

Ex parte application

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

Ex parte applications are reserved for exigent circumstances and must 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."

CRITICAL

Applies to

Joint chart deposition designations

Each designation in the joint chart must include six required columns: witness designation 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 designation of deposition or former testimony shall include column that 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

Jury instructions

All blanks on CACI jury instructions must be filled in and any irrelevant portions stricken.

All blanks on CACI instructions must be filled in and any irrelevant portions stricken.