Los Angeles Superior Court Document Filing Requirements

CRITICAL

Applies to

Motion in limine

The caption of each motion in limine 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

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 an exhibit list in the required column format (exhibit number, description, offering party, authentication/admissibility stipulations, marking and admission dates) and must meet and confer to resolve objections to each exhibit's authenticity and admissibility.

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 letters), (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) 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 witness list

Counsel and self-represented parties must jointly prepare and file a witness list in the required column format (name, expert status, accommodations, calling party, expected testimony, estimated direct/cross/total examination times, and grand total); witnesses not listed are subject to exclusion from testifying except for impeachment or rebuttal, unless the party shows good cause.

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 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 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 to the court of good cause.

CRITICAL

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 must include a sworn declaration detailing notice to the opposing party per Cal. Rule of Court 3.1200 et seq.

All ex parte applications must include a sworn declaration detailing the notice provided to the opposing party, in strict compliance with Cal. Rule of Court 3.1200, et seq., including the date, time and manner of notification; to whom notification was made; and the opposing party’s response, if any, regarding the relief sought and its intent to attend the hearing. Any ex parte application that does not contain this information regarding notice cannot be entertained by the Court.

CRITICALCivil cases

Applies to

Business card

Remote parties must check in 10 minutes before hearing; in-person parties must provide a business card with specified details.

If appearing remotely, please be prepared to check in 10 minutes prior to the hearing time. If in person, please provide a business card to the Judicial Assistant that also states: (1) the calendar number of the matter; (2) the party you represent; (3) your bar number; and (4) whether interpreter services will be needed and in which language.

CRITICALCivil cases

Applies to

Trial binder

The jury trial binder must contain tabbed sections A through I covering operative pleadings, joint statement of the case, motions in limine, joint witness list, joint exhibits and exhibit list, joint proposed jury instructions, joint proposed verdict form, and each side's disputed proposed jury instructions.

A – Operative Pleadings B – Joint Statement of the Case C – Motions in Limine D – Joint Witness List E – Joint Exhibits in exhibit books and Joint Exhibit List F – Joint Proposed Jury Instructions G – Joint Proposed Verdict Form H – Plaintiff's Proposed Jury Instructions (disputed) I – Defendant's Proposed Jury Instructions (disputed)

CRITICALCivil cases

Applies to

Trial binder

Trial documents must be jointly prepared, with a meet and confer no later than 5 days before the first scheduled trial date; failure to meet and confer and contribute may result in monetary or evidentiary sanctions or both.

The above documents must be prepared by the parties jointly. Parties are directed to meet and confer no later than 5 days before the first scheduled trial date in order jointly to prepare trial-ready documents and place them in a tabbed and labeled binder. Failure to meet and confer with the opposing party and to contribute to the joint preparation of the trial binder may result in monetary or evidentiary sanctions or both.

CRITICALCivil cases

Applies to

Ex parte application

Ex parte applications to shorten time for a motion hearing or seeking a stay of execution must demonstrate irreparable harm, immediate danger, or statutory grounds under CRC 3.1202(c); absent such a showing the Court will not shorten time.

Proper Basis for Ex Parte Applications: All ex parte applications to shorten time for a motion hearing or that seek a stay of execution must demonstrate irreparable harm, immediate danger, or statutory grounds for relief, per Cal. Rule of Court 3.1202(c). Please carefully review whether there is a proper basis to seek ex parte relief. The Court will not shorten the time for a future motion absent such a showing.

CRITICALCivil cases

Applies to

Request to set trial

Trial continuances require a showing of good cause, and trial dates must be requested via the specified form.

Court trials are held at 8:30 AM on Monday through Friday. Because trial dates are requested by the parties by filing a “Request/Counter-Request to Set Case for Trial – Unlawful Detainer” form, the Court will presume readiness for trial at the first date set for trial and will continue the trial only upon a showing of good cause.

CRITICALCivil cases

Applies to

Trial binder

If trial binders do not exactly comply with the Standing Order, the Court will order compliance and set a Trial Readiness Conference, and the case will not be deemed ready for trial and no jury panel will be called until compliance is completed.

Should the Court determine that the trial binders are not in exact compliance with the Standing Order, then the Court will order the parties to comply with the Standing Order and will set a Trial Readiness Conference in order to ascertain compliance and readiness for jury trial. Cases will not be deemed ready for trial and no jury panel will be called until the above is completed.

CRITICALCivil cases

Applies to

Settlement agreement

In 'pay and stay' settlements, the agreement is lodged with the Court and the case dismissed without prejudice only if the agreement calls for the Court to retain jurisdiction to enforce its terms under CCP § 664.6.

Should a settlement contemplate that the Defendant "pay and stay," then the settlement agreement will be lodged with the Court and the Court will dismiss the case, without prejudice, provided that the settlement agreement calls for the Court to retain jurisdiction to enforce the terms of the agreement, pursuant to CCP § 664.6.

CRITICALCivil cases

Applies to

Stipulation

Must include

proposed order

Any such stipulation should: (1) be prepared and signed by all parties to the case (excluding any party who is in default status) and be deemed “jointly submitted”; (2) provide a concise request of the judicial action sought; (3) provide a [Proposed] Order for approval and filing; (4) indicate on the face sheet that the parties do not seek a hearing or court appearance and request that the Court take action based on the writing only; and (5) indicate any future court dates or hearings that have already been calendared and request that they either be taken off-calendar or remain, which should be indicated on the [Proposed] Order.

Any such stipulation should: (1) be prepared and signed by all parties to the case (excluding any party who is in default status) and be deemed “jointly submitted”; (2) provide a concise request of the judicial action sought; (3) provide a [Proposed] Order for approval and filing; (4) indicate on the face sheet that the parties do not seek a hearing or court appearance and request that the Court take action based on the writing only; and (5) indicate any future court dates or hearings that have already been calendared and request that they either be taken off-calendar or remain, which should be indicated on the [Proposed] Order.

CRITICALCivil cases

Applies to

Ex parte application

Ex parte applications to shorten motion time or seek a stay of execution must show irreparable harm, immediate danger, or statutory grounds.

All ex parte applications to shorten time for a motion hearing or that seek a stay of execution must demonstrate irreparable harm, immediate danger, or statutory grounds for relief, per Cal. Rule of Court 3.1202(c).

CRITICALCivil cases

Applies to

Joint stipulation

Must include

proposed order

Joint stipulations must be signed by all parties (excluding defaulting parties), state a concise request, include a [Proposed] Order, indicate on the face sheet that no hearing is sought, and address any already-calendared future dates.

The Court encourages parties to meet and confer as to any issue that can be resolved without the need for a hearing and welcomes the parties to file any Joint Stipulation for the Court's consideration. Any such stipulation should: (1) be prepared and signed by all parties to the case (excluding any party who is in default status) and be deemed "jointly submitted"; (2) provide a concise request of the judicial action sought; (3) provide a [Proposed] Order for approval and filing; (4) indicate on the face sheet that the parties do not seek a hearing or court appearance and request that the Court take action based on the writing only; and (5) indicate any future court dates or hearings that have already been calendared and request that they either be taken off-calendar or remain, which should be indicated on the [Proposed] Order. The Court will reach out with any questions or else take the action requested.

CRITICALCivil cases

Applies to

Stipulation

Jointly filed settlement stipulations must be signed by all parties.

Please ensure that any such filing is signed by all parties.

CRITICALCivil cases

Applies to

Ex parte application

Every ex parte application must include a sworn declaration of notice to the opposing party (date, time, and manner of notification, person notified, and any response) per CRC 3.1200; without it, the application cannot be entertained.

Notice Requirements: All ex parte applications must include a sworn declaration detailing the notice provided to the opposing party, in strict compliance with Cal. Rule of Court 3.1200, et seq., including the date, time and manner of notification; to whom notification was made; and the opposing party’s response, if any, regarding the relief sought and its intent to attend the hearing. Any ex parte application that does not contain this information regarding notice cannot be entertained by the Court.

CRITICAL

Applies to

Jury instructions

The parties must prepare a complete set of full-text proposed jury instructions edited from CACI, with party names inserted and blanks, brackets, and irrelevant material removed.

The parties/counsel shall prepare a complete set of full-text proposed jury instructions, editing all proposed California Civil Jury Instructions and insert party name(s) and eliminate blanks, brackets, and irrelevant material.

CRITICAL

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 Iimine shall concisely identify the evidence that the moving party seeks to preclude.

CRITICAL

Applies to

Trial exhibit binder

Tab J – Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, and answer to any cross-complaint).Tab K – Stipulations

Tab J – Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, and answer to any cross-complaint).Tab K – Stipulations

CRITICAL

Applies to

Opposition and reply papers

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.

CRITICAL

Applies to

Proposed jury instructions list

The parties must jointly file a numbered list of proposed jury instructions identifying agreed and contested instructions, with a column for the judge to mark whether each instruction was given.

The parties/counsel shall jointly prepare and file a list of proposed jury instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any. The List of Proposed Jury Instructions must include a column by each instruction for the judge to indicate whether the instruction was given.

CRITICAL

Applies to

Trial brief

Each party must file a trial brief identifying the claims and defenses, major legal issues with authorities, relief and damages calculation, and any other helpful information.

Each party/counsel shall file a trial brief succinctly identifying: 1. The claims and defenses subject to litigation; 2. The major legal issues (with supporting points and authorities); 3. The relief claimed and calculation of damages sought; and 4. Any other information that may assist the Court at trial.

CRITICAL

Applies to

Joint statement of case

In jury trials, the parties must jointly prepare and file a signed joint written statement of the case for the court to read to the jury.

For jury trials, the parties/counsel shall work together to prepare and file a joint written statement of the case for the court to read to the jury (L.A. County Court Rule 3.25(g)(4)). The parties/counsel shall sign the joint statement, and all other joint

CRITICAL

Applies to

Ex parte application

Ex parte applicants must make an affirmative factual showing in a declaration containing competent, personal-knowledge testimony of irreparable harm, immediate danger, or another statutory basis for ex parte relief, per CRC 3.1202(c).

The applicant shall 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 statement of witness testimony

Parties without a court reporter must prepare a joint statement of each day's witness testimony and lodge it with the Court the next morning before proceedings resume, with no exceptions.

Parties who do not provide a court reporter for trial are directed to meet at the close of each session and prepare a joint statement of the witness testimony presented that day. The joint statement must be lodged with the Court the next morning before proceedings resume. No exceptions.

CRITICAL

Applies to

Motion in limine

Before filing motions in limine, parties must comply with CCP Section 1005 notice provisions and L.A. County Court Rule 3.57(a) MIL requirements.

Before filing motions in Iimine, the parties/counsel shall comply with the statutory notice provisions of Code of Civil Procedure (CCP) Section I005 and the MIL requirements of L.A. County Court Rule 3.57(a).

CRITICAL

Applies to

Joint witness list

The parties must file a joint witness list (alphabetical, with full names, expert designations, estimated direct/cross/re-direct lengths, and total testimony hours); witnesses not on the list may be excluded absent good cause.

The parties/counsel shall work together to prepare and file a joint list of all witnesses arranged alphabetically by last name. The joint witness list shall identify each witness by full name, specify which witnesses are experts, estimate the length of the direct, cross examination and re-direct examination of each, and include a total of the number of hours for all witness testimony. Any party/counsel who seeks to elicit testimony from a witness not identified on the witness list may have that witness excluded absent a showing of good cause.

CRITICAL

Applies to

Joint exhibit list

The parties must file a joint exhibit list with columns for the exhibit, offering party, stipulation to authenticity/admissibility, date identified in court, and date admitted.

The parties/counsel shall prepare and file a joint exhibit list organized with columns identifying: (1) the exhibit, (2) the party offering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) the date on which the exhibit was identified in court, and (5) the date on which the exhibit was admitted.

CRITICAL

Applies to

Proposed verdict form

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

The parties/counsel shall prepare and jointly file a proposed general verdict form or special verdict form (with interrogatories) acceptable to all sides (L.A. County Court 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.

CRITICAL

Applies to

Ex parte application

Must include

proposed order

Ex parte moving papers must include the notice within the declaration and must present a proposed order.

The notice must be included in the declaration and a proposed order must be presented with the moving papers.

CRITICAL

Applies to

Exhibits

Exhibits must be pre-marked using numbers pursuant to L.A. County Court Rules 3.52 and 3.53.

Pursuant to L.A. County Court Rules 3.52 and 3.53, the exhibits must be pre-marked using numbers.

CRITICAL

Applies to

Deposition designation chart

Parties intending to use deposition or former trial testimony must meet and confer and jointly file a designation chart with five required columns (designations, objections, counter-designations, responses, and the Court's ruling).

If the parties/counsel intend to use deposition testimony or former trial testimony in lieu of any witness' live testimony, the parties/counsel shall meet and confer and jointly prepare and file a chart with columns for each of the following: 1) the page and line designations of the deposition or former testimony requested for use, 2) objections, 3) counter-designations, 4) any responses thereto, and 5) the Court's ruling.

CRITICAL

Applies to

Joint exhibit list

Before filing the joint exhibit list, the parties must meet and confer on stipulations/objections to each exhibit, note stipulations or specify objections in the respective column, and sign the joint exhibit list.

Prior to filing the joint exhibit list, the parties shall meet-and-confer to determine whether they will stipulate to the authenticity and/or admissibility of each exhibit or whether there are objections to any exhibit. If there are stipulations, the parties shall note that in the respective column. If not, the objecting party shall specify all objections in the respective column. The parties/counsel shall sign the joint exhibit list.

CRITICAL

Applies to

Joint trial notebook

Counsels must bring two Joint Trial Notebooks to the FSC with tabs A-K prepared as follows:

Counsels must bring two Joint Trial Notebooks to the FSC with tabs A-K prepared as follows:

CRITICAL

Applies to

Motion in limine

Parties filing multiple motions in limine must number them consecutively.

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

CRITICAL

Applies to

Trial documents

Trial documents must include a joint witness list (with offer of proof, anticipated testimony length, and interpreter needs), a joint exhibit list, and for jury trials a joint statement of the case, proposed jury instructions, and proposed verdict form.

a. Joint Witness List: i. Brief offer of proof as to each witness' testimony ii. The anticipated length of that testimony and iii. Whether interpreters will be used b. Joint Exhibit List c. Joint Statement of the Case (jury trial only) d. Joint Proposed Jury Instructions (jury trial only; printed and edited) e. Joint Proposed Verdict Form (jury trial only; printed)

CRITICAL

Applies to

Exhibit binder

The Exhibit Binder must include a table of contents and each exhibit appropriately numbered.

EXHIBIT BINDER must include a table of contents and each exhibit appropriately numbered.

CRITICAL

Applies to

Trial binder

The Trial Binder must include, designated by a separate tab, the current operative pleadings and motions in limine served and filed per Los Angeles Rule of Court, rule 3.57.

following documents, designated by a separate tab: 1. Current Operative Pleadings, including: a. Operative Complaint b. Answer to Complaint c. Cross-Complaint, if any d. Answer to Cross-Complaint, if any 2. Motions in Limine (served and filed per Los Angeles Rule of Court, rule 3.57)

CRITICAL

Applies to

Tentative ruling submission email

Must include

case number

The tentative-ruling submission email must include the case number, identify the submitting party, and be copied (cc) to opposing party or counsel.

If counsel or self-represented party submits on the tentative, party's or counsel's e-mail must include the case number and identify the party submitting on the tentative with a copy (cc) to opposing party or counsel.

CRITICAL

Applies to

Ex parte application

An ex parte application must affirmatively show irreparable harm, immediate danger, or another statutory basis for ex parte relief, and demonstrate why the relief cannot be sought by noticed motion.

To have a proper basis to seek ex parte relief, there must be an affirmative showing of "irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte." (See Cal. Rules of Court, rule 3.1202 (c).) You will need to demonstrate to the court the reason(s) why you cannot seek the requested relief by means of a noticed motion.

CRITICAL

Applies to

Exhibit binder

Exhibit binders must include a table of contents and each exhibit appropriately numbered.

EXHIBIT BINDER must include a table of contents and each exhibit appropriately numbered.

CRITICAL

Applies to

Petition or complaint

Petitions and complaints must list every cause of action, including its statutory basis, on the face sheet.

All petitions and complaints shall list every cause of action on the face sheet, including the statutory basis.

CRITICAL

Applies to

Notice of withdrawal

A moving party who takes a motion off calendar must confirm this by filing a notice of withdrawal.

If the moving party takes a motion off calendar, the moving party shall confirm that fact by filing a notice of withdrawal.

CRITICAL

Applies to

Proposed judgment

Must include

proposed order

Unless otherwise ordered, the prevailing party on a prerogative writ must prepare, serve, and file a proposed judgment and, if applicable, a proposed writ of mandate.

In accordance with Local Rule 3.231(n), unless otherwise ordered, the prevailing party on a prerogative writ will be ordered to prepare, serve, and ultimately file a proposed judgment and, if applicable, a proposed writ of mandate.

CRITICAL

Applies to

Ex parte application

Must include

proposed order

Ex parte applications seeking a TRO and order to show cause re: preliminary injunction must include a proposed order.

If the ex parte application seeks a temporary restraining order and order to show cause re: preliminary injunction, the moving party must submit a proposed order.

CRITICAL

Applies to

Trial binder

The trial binder must include the opening brief, opposition brief, reply brief, and any evidence submitted by declaration or request for judicial notice.

The trial binder shall include the opening brief, the opposition brief, the reply brief, and any evidence submitted by declaration or request for judicial notice.

CRITICAL

Applies to

Administrative record

For administrative mandamus, the parties must comply with Local Rule 3.231(g) regarding the administrative record.

For administrative mandamus (or for traditional mandamus review of quasi-legislative agency actions), the parties shall comply with the requirements of Local Rule 3.231(g).

CRITICAL

Applies to

Joint appendix

The joint appendix must include the entire operative agency decision being challenged and all pages of the record cited in the parties' briefs.

The joint appendix shall include the entire operative agency decision that is being challenged, as well as all pages of the record cited in the parties’ briefs.