Los Angeles Superior Court Document Filing Requirements

CRITICAL

Applies to

Traditional mandamus evidence

Evidence in traditional mandamus must comply with Local Rule 3.231(h), with the petitioner submitting evidence by declaration or judicial notice with the opening brief and the respondent with the opposition brief.

The parties shall comply with Local Rule 3.231(h) when preparing and submitting evidence for a petition for traditional mandamus. In general, the Petitioner presents evidence by way of declaration or judicial notice with the opening brief and the Respondent submits evidence by way of declaration or judicial notice with the opposition brief.

CRITICAL

Applies to

Joint status report

The joint status report must inform the Court whether the matter has been resolved or whether a continuance of the trial setting conference is necessary.

informing the Court whether there has been a resolution of the matter or whether a continuance of the trial setting conference is necessary.

CRITICAL

Applies to

Proposed jury instructions

Before submitting proposed jury instructions, counsel must fill in the blanks, make appropriate modifications, and comply with SCLAC 3.170 to 3.171.

Before submitting the instructions, counsel must fill in the blanks, make any appropriate modifications, and comply with SCLAC 3.170 to 3.171.

CRITICAL

Applies to

Fsc documents

The following FSC documents must be provided to the Court prior to the FSC:

The following FSC documents must be provided to the Court prior to the FSC:

CRITICAL

Applies to

Ccp 2034 260 expert declaration

For experts counsel intends to call at trial, counsel must present the Court and opposing counsel with a CCP 2034.260 declaration stating the substance of the proffered opinion no later than the FSC.

As to experts that counsel intends to call at trial, no later than the FSC, Counsel shall present to the Court and opposing counsel a copy of the Code of Civil Procedure section 2034.260 declaration that states the substance of the proffered opinion.

CRITICAL

Applies to

Proposed jury instructions

CACI must be used for form jury instructions.

Use CACI for form instructions.

CRITICAL

Applies to

Joint witness list

The parties must submit a joint list of all witnesses they actually intend to call, with per-witness time estimates for direct, cross, and redirect testimony and a total estimated testimony time at the end.

5. JOINT WITNESS LIST AND TRIAL SCHEDULE. The parties must submit a joint list of all witnesses each party actually intends to call. Next to each witness, indicate the total time estimated for that witness's testimony (including direct, cross, and redirect). Make realistic time estimates. At the end of the list, total the time estimated for testimony.

CRITICAL

Applies to

Proposed jury instructions

Parties must submit a joint set of jury instructions plus a separate set of instructions from each side to which there are objections.

The parties are to submit a joint set of instructions, plus a set of instructions from each side to which there are objections.

CRITICAL

Applies to

Joint statement of the case

A joint statement of the case, which the Court will read to prospective jurors, must be provided to the Court prior to the FSC.

3. JOINT STATEMENT OF THE CASE (which will be read by the Court to the prospective jurors).

CRITICAL

Applies to

Trial notebook

The parties must provide a paper "trial notebook" for the Court in connection with the FSC.

The parties must provide both a paper "trial notebook" for the Court and submit FSC/trial documents electronically.

CRITICAL

Applies to

Motion in limine

Every motion in limine must be accompanied by a sworn declaration attesting that the subject was discussed with the opposing party and setting forth the opposing party's position, submitted with timely statutory notice so it can be heard at the FSC.

In compliance with SCLAC Rule 3.57, 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, setting forth the opposing party's position regarding the motions, and must be submitted with timely statutory notice so the motion in limine can be heard at the FSC.

CRITICAL

Applies to

Proposed jury instructions

Proposed jury instructions must include the full text of all requested instructions, not just a list.

The parties shall provide the full text of all requested instructions (not just a list).

CRITICAL

Applies to

Joint exhibit list

4. JOINT EXHIBIT LIST AND EXHIBITS. The parties shall work together to provide exhibits electronically, if feasible.

4. JOINT EXHIBIT LIST AND EXHIBITS. The parties shall work together to provide exhibits electronically, if feasible.

CRITICAL

Applies to

Motion in limine

Motions in limine must be accompanied by a sworn declaration confirming discussion with opposing party and their 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, setting forth the opposing party’s position regarding the motions, and must be submitted with timely statutory notice so the motion in limine can be heard at the FSC.

CRITICAL

Applies to

Summary of proceedings

If no court reporter is retained, the parties must jointly prepare a summary of the day's proceedings and lodge it in the courtroom the next morning before proceedings resume.

If no court reporter is used, the parties must jointly prepare a summary of the day's proceedings and lodge it in the courtroom the next morning before proceedings resume.

CRITICAL

Applies to

Proposed verdict forms

Parties must meet and confer in advance and then file proposed general or special verdict forms.

The parties are to meet and confer in advance and then file proposed general or special verdict forms.

CRITICAL

Applies to

Motion in limine notebook

The Motions in Limine notebook must contain an index of each party's MILs, oppositions, and replies.

The notebook is to contain an index of each parties MILs, oppositions & replies

CRITICAL

Applies to

Court reporter designation order

Must include

proposed order

The court does not provide reporters absent a fee waiver and timely request; a party seeking a reporter must hire a private court reporter and submit a proposed order designating that reporter as the official reporter.

The court does not provide court reporters unless there is a fee waiver and timely request for a reporter. Even so, there is still no guarantee that the court will have a reporter available under those circumstances. Any party otherwise seeking the presence of a court reporter must secure the service of a private court reporter with a proposed order designating the court reporter as the official reporter.

CRITICAL

Applies to

Final status conference trial binder

Binder One provided at the FSC must contain the joint witness list, joint exhibit list (with objections/grounds and columns for date identified, date admitted, stipulation, authenticity and admissibility), joint statement of the case, proposed verdict form(s), list of joint and contested jury instructions, fully edited printed jury instructions, and any briefs.

BINDER ONE: 1. Joint Witness List 2. Joint Exhibit List a. Include any objections and grounds b. Include columns for date identified and date admitted c. Include columns for stipulation, authenticity and admissibility 3. Joint Statement of the Case 4. Joint Proposed Special Verdict Form OR each side’s proposed verdict form 5. List of Joint and Contested Jury Instructions 6. Printed Jury instruction - fully edited 7. Briefs (if any)

CRITICAL

Applies to

Ex parte application

Must include

proposed order

Every ex parte application must be accompanied by a proposed order submitted separately from the application.

All ex parte applications require a proposed order, which shall be submitted separate from the ex parte application.

CRITICAL

Applies to

Joint status report

The post-mediation joint status report must advise the court of ADR/fact discovery status (including vehicle inspection for Song-Beverly actions), anticipated pre-trial motions, trial time estimate, and lead trial counsel mutual availability in months 18-24 from filing.

The Status Report shall advise the Court of the status of ADR and fact discovery (vehicle inspection as well for Song-Beverly actions); anticipated pre- trial motions, if any; trial time estimate; and lead trial counsel mutual availability in months 18 – 24 from filing.

CRITICAL

Applies to

Exhibit binder

A copy of the e-filed exhibit list must be included in the exhibit binders.

The exhibit list must be e-filed and included in the binders

CRITICAL

Applies to

Joint statement of the case

JOINT STATEMENT OF THE CASE (which will be read by the Court to the prospective jurors). This is a brief, neutral statement of what the case is about.

JOINT STATEMENT OF THE CASE (which will be read by the Court to the prospective jurors). This is a brief, neutral statement of what the case is about.

CRITICAL

Applies to

Trial exhibits

Each exhibit must be separately numbered to match the joint exhibit list, and multi-page exhibits must have internally numbered pages (e.g., 3.1, 3.2, 3.3).

Each exhibit must be separately numbered, with the numbers corresponding to the number of the exhibit on the joint exhibit list. If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3 etc.

CRITICAL

Applies to

Exhibit list

At the end of each trial day, counsel must meet and confer and submit an agreed-upon list of all exhibits admitted that day to the Court's judicial assistant.

At the end of each trial day counsel must meet and confer and submit to the Court's judicial assistant an agreed-upon list of all exhibits admitted that day.

CRITICAL

Applies to

Trial exhibits

Counsel must prepare three separate sets of exhibits: for the Court, the witness stand, and the Judicial Assistant.

Counsel must prepare a separate set of exhibits for each of the Court, the witness stand, and the Judicial Assistant.

CRITICAL

Applies to

Deposition designation chart

Parties using deposition or former trial testimony must meet and confer and jointly file a designation chart with columns for 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’s live testimony, the parties/counsel shall meet and confer and jointly prepare and file a chart with columns for: 1) the line and page designations of the deposition or former testimony requested, 2) objections, 3) counter- designations, 4) any responses to the objections, and 5) the Court’s ruling.

CRITICAL

Applies to

Ex parte application

Ex parte applications must comply with California Rules of Court, rule 3.1200 et seq.

Ex parte applications must comply with CRC 3.1200 et seq.

CRITICAL

Applies to

Proposed jury instructions

Proposed jury instructions must include full text (not just a list), have blanks filled in and appropriate modifications made, comply with LASC 3.170-3.171, and use CACI for form instructions.

The parties shall provide the full text of all requested instructions (not just a list). Before submitting the instructions, counsel must fill in the blanks, make any appropriate modifications, and comply with LASC 3.170 – 3.171. Use CACI for form instructions.

CRITICAL

Applies to

Joint witness list and trial schedule

Absent good cause, total listed testimony hours may not exceed the trial estimate given at the case management conference, including one day for jury selection and time for opening and closing arguments.

Absent good cause, the total number of hours listed for testimony shall not exceed the trial estimate given at the case management conference, including the allocation of one day of the trial estimate for jury selection and sufficient time for opening statements and closing arguments.

CRITICAL

Applies to

Joint witness list and trial schedule

Parties must submit a joint witness list showing each witness they actually intend to call, per-witness estimated testimony time (direct, cross, redirect), and a total of estimated testimony time.

The parties must submit a joint list of all witnesses each party actually intends to call. Next to each witness, indicate the total time estimated for that witness's testimony (including direct, cross, redirect). Make realistic time estimates. At the end of the list, total the time estimated for testimony.

CRITICAL

Applies to

Idc memorandum

The IDC memorandum must set forth the outstanding issues in the discovery dispute.

At least two court days before the IDC, each side shall serve and file a memorandum of no longer than two pages setting forth the outstanding issues.

CRITICAL

Applies to

Final status conference documents

The following FSC documents must be provided to the Court prior to the FSC:

The following FSC documents must be provided to the Court prior to the FSC:

CRITICAL

Applies to

Summary of proceedings

If no court reporter is used at trial, the parties must jointly prepare a summary of the day's proceedings and lodge it in the courtroom the next morning before proceedings resume.

COURT REPORTERS AND SETTLED STATEMENTS. The Court strongly encourages the parties to bring a court reporter for trial. If no court reporter is used, the parties must jointly prepare a summary of the day's proceedings, and lodge it in the courtroom the next morning before proceedings resume.

CRITICAL

Applies to

Motion in limine

Must include

certificate of conference

Motions in limine must comply with LASC Rule 3.57's mandatory declaration and meet and confer requirements, and boilerplate or form motions in limine are disfavored.

Compliance with LASC Rule 3.57, including the declaration and meet and confer requirements, is mandatory. Boilerplate or form motions in limine are disfavored.

CRITICAL

Applies to

Joint exhibit list and exhibits

Counsel must comply with LASC Rules 3.52, 3.53, and 3.151 for the joint exhibit list and exhibits.

JOINT EXHIBIT LIST AND EXHIBITS. Counsel must comply with LASC Rules 3.52, 3.53 and 3.151.

CRITICALCivil cases

Applies to

Ex parte application

Must include

proposed order

A proposed order must be eFiled with ex parte moving papers.

A proposed order must be eFiled with the moving papers.

CRITICALCivil cases

Applies to

Demurrer

Must include

certificate of conference

A demurrer must include the required meet and confer declaration per CCP § 430.41.

The demurrer must contain the required declaration regarding the meet and confer per CCP § 430.41.

CRITICAL

Applies to

Joint witness list

Witnesses not listed on the joint witness list may be excluded 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 jury instructions

For jury trials, the parties must jointly prepare a complete set of full-text proposed jury instructions by editing CACI instructions, inserting party names, and removing 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 chart of page and line designations

Parties must attach copies of the designated or counter-designated transcript pages to the joint chart, with numbered tabs separating each deposition or trial transcript.

The parties shall attach copies of the pages of the transcripts of the deposition or former testimony they are designating or counter-designating to the Joint Chart of Page and Line Designations for Deposition and Former Testimony, with numbered tabs separating each deposition or trial transcript.

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.

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 witness list

The parties must jointly prepare and file a witness list identifying 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

Joint statement of case

In jury trials, the 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

Proposed verdict form

If the parties cannot agree on a joint verdict form, each party must file its own separate proposed verdict form.

If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

CRITICAL

Applies to

Motion in limine

Must include

caption

Motions in limine captions must identify evidence sought to be excluded; multiple motions must be numbered consecutively.

The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to exclude. Parties filing more than one motion in limine shall number them consecutively.

CRITICAL

Applies to

Motion in limine

Motions in limine must comply with the notice provisions of Code of Civil Procedure section 1005 and include declarations complying with Los Angeles County Court Rule 3.57(a).

The parties’ counsel and any self-represented parties shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and file declarations that comply with the requirements of Los Angeles County Court Rule 3.57, subdivision (a).

CRITICAL

Applies to

Daily proceedings summary

The court strongly encourages arranging a court reporter for trial; if no reporter is used, the parties must jointly prepare a daily proceedings summary including detailed witness testimony and lodge it in the courtroom the next morning before proceedings resume.

The court strongly encourages the parties to arrange for a court reporter for trial. If no court reporter is used, the parties must jointly prepare a summary of the day's proceedings, including a detailed summary of any witness testimony, and lodge it in the courtroom the next morning before proceedings resume.

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 chart of page and line designations

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