Los Angeles Superior Court Document Filing Requirements

CRITICAL

Applies to

Joint exhibit list

The parties must jointly prepare and file an exhibit list with specified columns for each trial exhibit and must meet and confer to resolve objections to the authenticity and admissibility of each exhibit.

The parties' counsel and any self-represented parties shall work together to prepare and file a joint exhibit list organized with columns (in the format set forth below) which state, as to each exhibit any party intends to offer at trial: (1) the exhibit number, (2) a brief description of the exhibit, (3) which party is offering the exhibit, (4) whether the parties have stipulated to authentication of the exhibit, (5) whether the parties have stipulated to admissibility of the exhibit, (6) any evidentiary objections to admission of the exhibit, (7) the date the exhibit was marked for identification, and (8) the date the exhibit was admitted into evidence. (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 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 containing six required items for each instruction (number, title, requesting party, agreed/contested status, objection, and whether 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”).

CRITICAL

Applies to

Joint chart of page and line designations

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

In the joint chart, each counter-designating party’s counter-designations of additional deposition or former testimony of the witness that relates to the designations shall include columns which state: (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

Opposition and reply papers

Must include

caption

Opposition and reply papers for motions in limine must include 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

Joint witness list

Must include

caption

Joint Witness List required, filed before trial, with specified columns including witness details and exam length estimates.

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. The joint witness list shall be organized with columns (in the format set forth below) which state (1) the name of each witness (in alphabetical order), if the witness is being called to testify as an expert, and, if applicable, that the witness requires an 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) an estimate of the length of redirect (in hours).

CRITICAL

Applies to

Trial binder

For jury trials, the trial binder shall include the following documents with tabs: A – Trial Briefs (Optional) B – Joint Statement of the Case Joint Witness List C – Joint Witness List D – Joint Exhibit List E – Joint List of Jury Instructions; [Written] Jury Instructions F – Joint or Contested Verdict Form G – Joint Chart of Page and Line Designations for Testimony H – Operative Pleadings

For jury trials, the trial binder shall include the following documents with tabs: A – Trial Briefs (Optional) B – Joint Statement of the Case Joint Witness List C – Joint Witness List D – Joint Exhibit List E – Joint List of Jury Instructions; [Written] Jury Instructions F – Joint or Contested Verdict Form G – Joint Chart of Page and Line Designations for Testimony H – Operative Pleadings

CRITICAL

Applies to

Bench trial submissions

Bench trial parties must submit a joint exhibit list and joint witness list and have copies of the exhibits available for the court, judicial assistant, opposing counsel, and witnesses.

Counsel/parties must submit a joint exhibit list and joint witness list as described below. The parties are expected to have a witness list completed and to have copies of the exhibits available for the court, judicial assistant, opposing counsel, and any witnesses.

CRITICAL

Applies to

Ex parte application

Every ex parte application must affirmatively show irreparable harm, immediate danger, or another statutory basis for ex parte relief.

All ex parte applications must make an affirmative showing of “irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte” as required by California Rules of Court, rule 3.1202.

CRITICAL

Applies to

Motion in limine

Must include

certificate of conference

All motions in limine must include a sworn declaration certifying meet and confer with opposing party and their position; failure results in summary denial.

All MILs 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 the motion(s).

CRITICAL

Applies to

Motion in limine

Must include

certificate of conference

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

All MILs 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 the motion(s).

CRITICAL

Applies to

Final status conference submissions

Before the FSC, counsel must meet and confer to prepare jury instructions, verdict form, statement of the case, and exhibit and witness lists for submission to the court, and attempt stipulations on ultimate facts and exhibit authenticity/admissibility.

Prior to the FSC, counsel are ordered to meet and confer to exchange, discuss, and prepare for submission to the court the jury instructions, verdict form, a statement of the case, and exhibit and witness lists. Counsel shall also attempt to reach stipulations regarding ultimate facts and issues, and authenticity/admissibility of exhibits.

CRITICAL

Applies to

Stipulation and order

A Stipulation and Order for a temporary judge must include a copy of the Temporary Judge's Oath of Office, Consent and Certification, and the Scope of Appointment.

The Stipulation and Order must have a copy of the Temporary Judge's Oath of Office, Consent and Certification, and the Scope of Appointment.

CRITICAL

Applies to

Voter confidentiality petition

Voter confidentiality petitions must be filed using mandatory forms LASC CIV 273 (petition) and LASC CIV 274 (proposed order).

Petitioners must use mandatory forms LASC CIV 273 – Petition to Have Voter Registration Information Declared Confidential and LASC CIV 274 – (Proposed) Order to Have Voter Registration Information Declared Confidential.

CRITICAL

Applies to

Request for trial court assignment

Before Department 534 will consider a request for assignment of a trial court, parties must represent the case is trial-ready with discovery complete and must have filed a brief statement of the case, joint witness and exhibit lists, trial briefs, jury instructions, special verdict forms, and motions in limine with oppositions and replies.

Before Department 534 will consider such a request, the parties must: • represent the case is trial-ready and that all discovery is complete; and • have filed their: o Brief Statement of the Case, o Joint Witness List (with the parties’ “must call” witnesses so identified and expected duration of direct- and cross-examination together with a cumulative total of hours of witness testimony); o Joint exhibit list (with reasonably specific descriptions); o Trial briefs; o Jury Instructions (agreed-upon and the parties’ disputed, all clearly identified); o Special Verdict form(s); and o Motions in limine and oppositions and replies thereto.

CRITICAL

Applies to

Proposed jury instructions

g. Proposed Instructions: shall be included in the trial binder. These should include a jointly submit a packet of all requested and properly edited CACI or special instructions that are not agreed to by all parties. The instructions shall be submitted in the proper format for presentation to the jury.

g. Proposed Instructions: shall be included in the trial binder. These should include a jointly submit a packet of all requested and properly edited CACI or special instructions that are not agreed to by all parties. The instructions shall be submitted in the proper format for presentation to the jury.

CRITICAL

Applies to

Proposed jury instructions list

The parties must jointly prepare a chart-format list of proposed jury instructions (including contested ones with proponents/opponents identified), signed by all parties and filed with the Court.

f. List of Proposed Jury Instructions: must be prepared jointly by the parties. It should be prepared in chart format and should include all CACI and special jury instructions that are jointly proposed by the parties as well as those that are requested by one or more of the parties, but opposed by another party. A column in the chart must indicate the proponent(s) and opponent(s) of each proposed instruction. A final column should be included on the right of the Court's notation of whether the instruction was given at trial. The joint list of jury instructions must be signed by all parties and filed with the Court.

CRITICAL

Applies to

Joint exhibit list

The parties must jointly prepare a chart-format joint exhibit list with specified columns, signed by all parties and filed with the Court.

Exhibit list: must be prepared jointly by the parties. It should be prepared in chart format with each exhibit identified by title and its assigned exhibit number. Additional columns should indicate whether the exhibit will be admitted by stipulation, authenticated by stipulation, or challenged with objections, which shall be set forth in a column for objections. A final column should be included on the right for the Court's notation of whether the exhibit was admitted at trial. The joint exhibit list must be signed by all parties and filed with the Court.

CRITICAL

Applies to

Ex parte application

Before bringing an ex parte application, counsel should review California Rules of Court 3.1200-3.1207 and Los Angeles County Superior Court Rule 3.26. Please pay particular attention to the notice requirements and the requirement of an affirmative factual showing of good cause.

Before bringing an ex parte application, counsel should review California Rules of Court 3.1200-3.1207 and Los Angeles County Superior Court Rule 3.26. Please pay particular attention to the notice requirements and the requirement of an affirmative factual showing of good cause.

CRITICAL

Applies to

Case management statement

Counsel must submit case management statements as required by California Rules of Court rule 3.725; failure to comply with the CMC rules and local rules may result in monetary sanctions and/or trial-setting delay.

Counsel must comply with their obligation to submit case management statements pursuant to rule 3.725 of the California Rules of Court.

CRITICAL

Applies to

Trial binder

Parties must compile a 3-ring trial binder delivered to Department U at least 10 court days before the FSC containing all required documents in the specified order.

1. Trial Binder: the parties shall cooperate in compiling a 3-ring trial binder that shall be delivered to Department U at least 10 court days before the FSC. The binder must include all the following documents placed in the binder in the following order:

CRITICAL

Applies to

Ex parte application

Before bringing an ex parte application, counsel should review California Rules of Court 3.1200-3.1207 and Los Angeles County Superior Court Rule 3.26. Please pay particular attention to the notice requirements and the requirement of an affirmative factual showing of good cause.

Before bringing an ex parte application, counsel should review California Rules of Court 3.1200-3.1207 and Los Angeles County Superior Court Rule 3.26. Please pay particular attention to the notice requirements and the requirement of an affirmative factual showing of good cause.

CRITICAL

Applies to

Statement of case

The parties must jointly prepare a short, nonargumentative Statement of the Case that is signed by all parties and filed with the Court.

Statement of the Case: must be prepared jointly by the parties. It should be a short, nonargumentative written statement of the case to be read to the jury. It must be signed by all parties and filed with the Court.

CRITICAL

Applies to

Trial brief

These briefs should include a description of the claims, defenses, relief sought, evidentiary disputes, and all issues to be decided at trial along with a discussion of any novel or unusual issues of law, with citations to supporting authorities. The briefs must be signed, filed with the Court and served on all parties.

These briefs should include a description of the claims, defenses, relief sought, evidentiary disputes, and all issues to be decided at trial along with a discussion of any novel or unusual issues of law, with citations to supporting authorities. The briefs must be signed, filed with the Court and served on all parties.

CRITICAL

Applies to

Notice of related cases

Parties must timely comply with California Rules of Court, rule 3.300 regarding notice of related cases.

The Court requires timely compliance with California Rules of Court, rule 3.300 Re: Notice of Related Cases.

CRITICAL

Applies to

Trial brief

Must include

signature blocks

Trial briefs must be signed, filed with the Court, and served on all parties.

The briefs must be signed, filed with the Court and served on all parties.

CRITICAL

Applies to

Operative pleadings

All operative pleadings, including operative complaints, cross-complaints, and answers, must be included in the trial binder.

All operative pleadings: must be included in the trial binder. This includes the operative complaints and cross-complaints and the operative answers thereto.

CRITICAL

Applies to

Joint witness list

The joint witness list must include witnesses' names, direct/cross-examination time estimates, and interpreter needs, and must be signed by all parties and filed with the Court.

all witnesses' names, time estimates for direct and cross-examination, and whether the witness requires an interpreter. The joint witness list must be signed by all parties and filed with the Court.

CRITICAL

Applies to

Verdict forms

Verdict forms must be jointly prepared by the parties; if they cannot agree, the Court will provide a general verdict form.

h. Verdict Forms: must be jointly prepared by the parties. If the parties cannot agree on joint verdict forms, then the Court will provide a general verdict form to the jury.

CRITICAL

Applies to

Reply brief

Reply briefs on motions in limine must be in writing and properly filed and served.

Reply briefs must be in writing and properly filed and served.

CRITICAL

Applies to

Transcript of recordings

Parties must provide transcripts of recordings in compliance with Cal. R. Ct. 2.1040.

The parties shall comply with Cal. R. Ct. 2.1040, requiring the provision of a transcript of various recordings.

CRITICAL

Applies to

Exhibits

Parties must exchange exhibits in advance of trial as required by law.

The parties shall exchange exhibits in advance of trial to the extent required by law.

CRITICAL

Applies to

Final status conference documents

Before the FSC, the parties must jointly prepare and file a joint jury statement, joint witness list, joint exhibit list, agreed jury instructions, and an agreed special verdict form with interrogatories.

The parties shall work together to prepare and file, no later than five days before the FSC, a joint statement to be read to the jury, a joint witness list, a joint exhibit list, a set of agreed jury instructions, and an agreed special verdict form with interrogatories.

CRITICAL

Applies to

Informal discovery conference brief

IDC briefs must contain a neutral statement of the case, the issues in dispute, and the parties' respective positions, and may attach the relevant discovery requests and responses.

At least five days before the IDC, the parties shall separately file briefs not to exceed three pages setting forth a neutral statement of the case, the issues in dispute, and their respective positions. The relevant discovery requests and responses may be attached.

CRITICAL

Applies to

Joint witness list

The joint witness list must estimate total testimony time per witness (direct, cross, and redirect) and total testimony time for the entire trial.

The joint witness list shall estimate the total time for each witness's testimony (including direct, cross, and redirect) and the total time for all testimony in the trial.

CRITICAL

Applies to

Motion in limine

Motions in limine must comply with LASC Rule 3.57.

Mils must comply with LASC Rule 3.57.

CRITICAL

Applies to

Joint jury instructions

The parties must file a joint set of agreed and not agreed CACI jury instructions with headings, all information filled in, and no remaining brackets or blanks.

The parties shall file a joint set of proposed agreed and not agreed CACI jury instructions with headings and all infonnation filled in (e.g., singular or plural, gender, etc.), and no remaining brackets or blanks. See, LASCR 3.25(g)(7).

CRITICAL

Applies to

Deposition transcripts and discovery responses

Before trial, copies of deposition transcripts or other discovery responses must be lodged with the Court.

Before trial, copies of deposition transcripts or other discovery responses shall be lodged with the Court. (LASCR 3.56)

CRITICAL

Applies to

Stipulations

Counsel must file and execute any stipulations regarding ultimate facts, issues, and exhibit admissibility (foundation/authentication) on or before the time for filing trial documents.

Counsel shall file and execute stipulations, if any, regarding ultimate facts and issues and the admissibility of exhibits (i.e. foundation and/or authentication) on or before the time of filing trial documents.

CRITICAL

Applies to

Revised exhibit list

At the end of trial, counsel must prepare and lodge a revised exhibit list reflecting only admitted exhibits, which will be provided to the jury during deliberations.

At the end of the trial, counsel will be required to prepare and lodge with the court a revised exhibit list that reflects only those exhibits that have been admitted. The revised exhibit list will be provided to the jury during their deliberations.

CRITICAL

Applies to

Joint witness list

Witnesses not listed on the joint witness list will be excluded from testifying or limited to impeachment or rebuttal only.

Any person who is not listed on the joint witness list shall be either excluded from testifying or his or her testimony shall be limited to only impeachment or rebuttal.

CRITICAL

Applies to

Witness list

Each morning counsel must give the Court Attendant a written witness list including full names with correct spellings and the order of calling.

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

CRITICAL

Applies to

Powerpoint slides

Must include

lodge with court, share with opposing counsel

PowerPoint slides must be shared with opposing counsel before presentation and lodged with the court; court informed at FSC.

If counsel intends to use PowerPoint, the Court shall be informed at the Final Status Conference and a copy of the slides must be shared with opposing counsel prior to the presentation. A copy of the slides must be lodged with the court.

CRITICAL

Applies to

Joint exhibit list

The parties must prepare a joint exhibit list containing the columns: Ex. No., Description, Offered by, Stipulated, Objection, Date ident., and Date admit.

The parties shall prepare a joint exhibit 1ist. See, LASCR 3.25(g)(6). The Joint Exhibit List shall have the following columns: Ex. No., Description, Offered by, Stipulated, Objection, Date ident., and Date admit..

CRITICAL

Applies to

Joint witness list

The joint witness list must include all witnesses on one list with realistic direct/cross estimates, no duplicated names, columns for direct/cross/redirect time, a total of all testimony time, and designation of percipient or expert witnesses with area of expertise.

The parties shall list all witnesses, with realistic estimates for direct and cross-examination on one list. See, LASCR 3.25(g)(5). Do not repeat the name of a witness who will be called by more than one party. The witness list should have columns that indicate for each witness the total time expected for direct, cross, and redirect testimony. At the bottom of the list, total the time estimated for all testimony. Make realistic time estimates. The list should specify if the witness is percipient or expert (with area of expertise).

CRITICAL

Applies to

Trial brief

Trial briefs are optional in jury trials but required in court trials, and must be filed at least five (5) court days before the FSC.

Trial briefs are not required injury trials but can be useful to the Court. They are required in court trials and must be filed at least five (5) court days before the FSC.

CRITICAL

Applies to

Powerpoint slides

A copy of PowerPoint slides intended for use at trial must be lodged with the court.

A copy of the slides must be lodged with the court.

CRITICAL

Applies to

Trial documents

Operative pleadings, joint witness list, joint exhibit list, and trial briefs (court trials) must be filed five court days before the FSC; trial briefs are optional in jury trials.

The following documents shall be filed five court days before the final status conference for a jury trial, except that a trial brief is optional. The parties shall file the operative pleadings, joint witness list, joint exhibit list and trial briefs for a court trial.

CRITICAL

Applies to

Verdict form

Must include

joint filing

Parties must file a joint proposed general or special verdict form, or, if they cannot agree, each party must separately file its own proposed verdict form.

The parties shall prepare and file a joint proposed general verdict form or special verdict form. The parties are urged to agree on a verdict form. If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

CRITICAL

Applies to

Court reporter or daily statements

Parties must provide a court reporter for court and jury trials or submit daily agreed/proposed settled statements during trial, with Real Time reporting preferred.

YOU MUST PROVIDE A COURT REPORTER FOR TRIAL (COURT AND JURY TRIAL) OR SUBMIT DAILY AGREED STATEMENTS / PROPOSED SETTLED STATEMENTS during a trial. Refer to the LASC Court website for policy, assignment list and stipulation forms. Real Time reporting is preferred for trials.

CRITICAL

Applies to

Voir dire questions

Must include

joint filing

The parties must prepare and file a joint list of voir dire questions to be asked by the Court.

The parties shall prepare and file a joint list of questions to be asked by the Court.