Los Angeles Superior Court Document Filing Requirements

CRITICAL

Applies to

Motion in limine

Parties filing multiple motions in limine must number them consecutively.

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

CRITICAL

Applies to

Joint exhibit list

Counsel and self-represented parties must jointly prepare and file a joint exhibit list containing seven required columns of information 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) that state, as to each exhibit any party intends to offer at trial: (1) the exhibit number (not letter), (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) the date the exhibit was marked for identification, and (7) date the exhibit was admitted into evidence.

CRITICAL

Applies to

Special jury instructions

Special jury instructions on which counsel cannot agree must be submitted as a separate set or sets.

Any proposed special instruction to which counsel cannot agree shall be submitted as a separate set or sets.

CRITICALCivil cases

Applies to

Evidence documents

The court's order lists required documents concerning the subject vehicle, including the purchase/lease contract, repair orders and invoices, and documents supporting the plaintiff's claim for incidental and/or consequential damages.

8. Purchase and/or lease contract concerning the subject vehicle. 9. Repair orders and invoices concerning the subject vehicle. 10. Any documents supporting plaintiffs claim for incidental and/or consequential damages

CRITICALCivil cases

Applies to

Motion in limine opposition and reply

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

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

CRITICALCivil cases

Applies to

Ex parte application

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

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

CRITICALCivil cases

Applies to

Motion in limine

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

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

CRITICALCivil cases

Applies to

Statement of the case

If the parties cannot agree on a joint statement of the case after meet and confer efforts, each party must file a separate statement of the case.

If, after efforts to meet and confer, the parties cannot agree on a written joint statement, each party shall file a separate statement of the case.

CRITICALCivil cases

Applies to

Joint exhibit list

The parties must meet and confer before submitting the joint exhibit list to resolve admissibility objections, and should begin those discussions early rather than at the last minute.

Before submitting their joint exhibit list, the parties shall meet and confer to resolve objections to the admissibility of each exhibit. Do not wait until the last minute to discuss the exhibits.

CRITICALCivil cases

Applies to

Witness list

Counsel must deliver a written witness list to the clerk each morning stating that day's witnesses, full names with correct spellings, and the order of testimony.

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

CRITICALCivil cases

Applies to

Transcript of audio visual recording

Parties must prepare transcripts of all recordings to be offered as exhibits, meet and confer on transcript content before the Final Status Conference, and bring the transcripts to the FSC so the Court can rule on objections.

California Rules of Court ("CRC"), rule 2.1040 requires the parties to prepare transcripts of all recordings counsel plan to introduce as exhibits. Counsel must meet and confer regarding the content of any such transcripts prior to the Final Status Conference ("FSC") to resolve any objections. The proponent of the recording must bring their transcripts to the FSC so the Court may rule on any objections to the transcripts.

CRITICALCivil cases

Applies to

Fsc notebook

In bench trials, parties may omit Tabs C and H from the FSC Notebook, but all other items identified in Sections III and IV must still be provided to the Court.

For bench trials, the parties do not need to include Tabs C and H listed in Section III in the FSC Notebook. Everything else identified in Sections III and IV must be provided to the Court.

CRITICALCivil cases

Applies to

Joint chart of page and line designations

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

If the parties intend to use deposition testimony or former trial testimony in lieu of or in addition to a witness's live testimony, the parties shall meet and confer to discuss, and work together to prepare and file, a joint chart in the format set forth below (''Joint Chart of Page and Line Designations for Deposition and Former Testimony").

CRITICALCivil cases

Applies to

Ex parte application

Must include

proposed order

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

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

CRITICALCivil cases

Applies to

Declaration

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

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

CRITICALCivil cases

Applies to

Trial brief

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

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

CRITICALCivil cases

Applies to

Joint exhibit list

Failure to file a timely joint exhibit list may result in the Court prohibiting the use of exhibits at trial.

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

CRITICALCivil cases

Applies to

Appearance check in

Must include

case number

Parties must check in with the courtroom assistant on arrival, and counsel must provide a business card showing the party represented and the calendar matter number.

Upon arrival, parties must check in with the courtroom assistant. Counsel must provide a business card that indicates the party represented and the calendar matter number on which counsel is appearing.

CRITICALCivil cases

Applies to

Joint witness list

The joint witness list must identify scheduling issues, special requirements (including interpreters and ADA accommodations), and whether each witness will testify remotely.

The list must identify potential witness scheduling issues and special requirements, including whether any interpreters will be necessary and whether any ADA accommodation is anticipated. The list must identify whether the witness will testify remotely.

CRITICALCivil cases

Applies to

Joint statement of the case

In jury trials, the parties must prepare and file a joint written statement of the case for the court to read to the jury, and it should be brief and non-argumentative.

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

CRITICALCivil cases

Applies to

Joint witness list

The joint witness list must include time estimates for any testimony presented via video deposition excerpts or by reading transcripts of depositions or former testimony.

The joint witness list must also include time estimates for any witness whose testimony is intended to be presented by playing video deposition excerpts or by reading transcripts of depositions or former testimony.

CRITICALCivil cases

Applies to

Joint witness list

All witness time estimates must be reasonable and accurate under Local Rule 3.25(h), and the joint witness list must include a grand total of the estimated examination time for all listed witnesses.

All time estimates must comply with Local Rules, rule 3.25(h), which requires counsel to provide the Court with reasonable to and accurate time estimates. The list must also provide a calculation of the total estimated time for the examination of all listed witnesses (i.e., a grand total).

CRITICALCivil cases

Applies to

Motion in limine

Each motion in limine must identify the specific evidence it is directed at, and form or boilerplate motions in limine are strongly discouraged.

A motion in limine must identify the specific evidence to which it is directed. Form or boilerplate motions in limine are strongly discouraged.

CRITICALCivil cases

Applies to

Trial transcripts

Parties must provide the Court with transcripts at the FSC or risk continuance of the FSC and/or trial or exclusion of the prior testimony.

A failure to provide the Court with transcripts at the FSC may result in continuance of the FSC and/or trial, or the exclusion of the prior testimony.

CRITICALCivil cases

Applies to

Joint witness list

Counsel must jointly prepare a witness list (excluding impeachment and rebuttal witnesses) that identifies each witness by name, expert status, calling party, and time estimates for direct, cross, and re-direct examination.

Counsel shall cooperate in the preparation of a joint list of all witnesses each party intends to call (excluding impeachment and rebuttal witnesses). (Local Rules, rule 3.25(g)(5).) The joint witness list shall identify each witness by name, specify which witnesses are experts, identify which party or parties seek to call the witness, provide time estimates for the direct, cross examination and re-direct examination (if any) of each witness.

CRITICALCivil cases

Applies to

Operative pleadings

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

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

CRITICALCivil cases

Applies to

FSC trial notebook

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

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

CRITICALCivil cases

Applies to

Joint witness list

Witnesses not included on the joint witness list are subject to exclusion from testifying at trial, except for actual impeachment or rebuttal testimony.

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.

CRITICALCivil cases

Applies to

Special jury instructions

Special jury instructions must include citations to the authority on which the instructions are based.

Any special instructions must include citations to the authority on which the instructions are based.

CRITICALCivil cases

Applies to

Joint exhibit list

The parties must prepare and file a joint exhibit list organized in columns that identifies each exhibit and states each party's evidentiary objections to its admission.

The parties shall prepare and file a joint exhibit list organized with columns identifying each exhibit and specifying each party's evidentiary objections, if any, to the admission of each exhibit. (Local Rules, rule 3.25(g)(6).)

CRITICALCivil cases

Applies to

Motion in limine

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

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

CRITICALCivil cases

Applies to

Ex parte application

Must include

proposed order

Ex parte applications require a proposed order and filing fee paid before appearing in court.

Ex parte applications will be considered Monday through Friday at 8:30 a.m. Applicants must comply with CRC, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in court.

CRITICALCivil cases

Applies to

Joint witness list

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

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

CRITICALCivil cases

Applies to

Joint list of proposed jury instructions

Parties must jointly prepare and file a list of proposed jury instructions in numerical order identifying agreed and contested instructions.

The parties sha11 prepare and file jointly a list of proposed jury instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any.

CRITICALCivil cases

Applies to

Joint exhibit list

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

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

CRITICALCivil cases

Applies to

Trial brief

Trial briefs must include a description of claims and defenses, discussions of major legal and evidentiary issues with authority, a detailed statement of relief sought with a damages breakdown, and any other helpful information.

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

CRITICALCivil cases

Applies to

Proposed verdict form

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

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

CRITICALCivil cases

Applies to

Demonstrative evidence

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

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

CRITICALCivil cases

Applies to

Proposed jury instructions

Counsel must prepare, submit, and meet and confer on proposed jury instructions, identifying agreed and disputed instructions.

Counsel shall prepare and submit proposed jury instructions. (See C.C.P. § 607a.) Counsel shall meet and confer in an attempt to reach agreement on the proposed jury instructions. Counsel must identify those jury instructions that they agree shall be given and shall identify those proposed instructions as to which there is disagreement. As to disputed proposed instructions the parties are encouraged to submit legal briefs setting forth the legal basis for the request and objection.

CRITICALCivil cases

Applies to

Motion in limine

Every motion in limine must be accompanied by a declaration complying with Local Rule 3.57.

All Motions in limine must be in writing and be accompanied by a declaration in compliance with Local Rule 3.57.

CRITICALCivil cases

Applies to

In limine motion

All in limine motions must be written and accompanied by a declaration complying with Local Rule 3.57.

All Motions in limine must be in writing and be accompanied by a declaration in compliance with Local Rule 3.57.

CRITICAL

Applies to

Motion in limine

Motions in limine must be noticed for hearing at the Final Status Conference, comply with the statutory notice provisions of CCP § 1005, and include declarations complying with 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 file declarations that comply with the requirements of Local Rule 3.57, subdivision (a).

CRITICAL

Applies to

Trial binder

The Trial Binder's table of contents must include Tabs A-I (Trial Briefs (optional), Joint Witness List, Joint Exhibit List, Joint Statement to Be Read to the Jury, Joint List of Jury Instructions, Joint and Contested Jury Instructions, Joint or Contested Verdict Form(s), Joint Chart of Page and Line Designations for Deposition and Former Testimony, and Current Operative Pleadings); for bench trials only Tabs A, B, C, H, and I are required.

with a table of contents that includes the following (for trials by the court without a jury, the Trial Binder shall only include the documents listed under Tabs A, B, C, H, and I): 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

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 in the prescribed format showing instruction number, title, requesting party, agreed/contested status, objections, and whether the instruction 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) that 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 deposition designations

Counter-designations in the Joint Chart must include columns for witness number/name, date and 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 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 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 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, excluding testimony to be used only for impeachment.

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). The parties do not, however, need to include in the joint chart deposition testimony or former trial testimony they plan on using for impeachment purposes only.

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.

CRITICAL

Applies to

Joint chart deposition designations

Each designating party's designations in the joint chart must include columns for witness designation number and name, date and type of testimony, page and line designations, objections, and additional content continuing beyond this page.

In the joint chart, each designating party’s designations of deposition or former testimony shall include columns 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

CRITICAL

Applies to

Joint written statement of case

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.

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.

CRITICAL

Applies to

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 eliminate blanks, brackets, 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, brackets, and other irrelevant or inapplicable material.