Los Angeles Superior Court Document Filing Requirements

CRITICAL

Applies to

Trial preparation order

Counsel and parties must comply with the Dept E Standing Order re Final Status Conference - Trial Preparation Order; failure to comply may result in sanctions and a delay in trial.

Counsel and parties are expected to follow and comply with the Court's "Standing Order: Dept E re Final Status Conference - Trial Preparation Order" ("Standing Order"), which will be included in the minute order at the time the initial trial date is set. (See attached Standing Order.) Failure to comply with the Standing Order may result in sanctions and a delay in trial.

CRITICAL

Applies to

Special verdict form

Parties must jointly file a proposed special verdict form for both jury and bench trials, or file separate proposed forms if agreement cannot be reached, and verdict forms are required even if the jury is waived.

For both jury and bench trials, the parties/counsel shall prepare and jointly file a proposed special verdict form acceptable to all sides. If the parties/counsel cannot agree on a joint special verdict form, each party must separately file a proposed verdict from. Verdict forms are required even though the parties may waive jury.

CRITICAL

Applies to

Motion to compel further responses

Must include

certificate of conference

Motions to compel further responses must be accompanied by a meet and confer declaration showing a reasonable and good faith attempt to informally resolve each issue presented.

As a reminder, motions to compel further responses must be accompanied by a meet and confer declaration stating facts that show a reasonable and good faith attempt was made to informally resolve each issue presented by the motion. (CCP § 2016.040; Local Rule, Appendix 3.A (2024).)

CRITICAL

Applies to

Trial exhibit binder

Hard copy exhibit binders must be in the courtroom on the day trial commences.

However, hard copy exhibit binders are required to be in the courtroom on the day trial commences.

CRITICAL

Applies to

Bench trial submissions

(Note: Bench trials do not require submission of jury instructions, however, substantive CACI instructions must be submitted, together with special verdict forms that the Court may use in crafting a decision.

(Note: Bench trials do not require submission of jury instructions, however, substantive CACI instructions must be submitted, together with special verdict forms that the Court may use in crafting a decision.

CRITICAL

Applies to

Joint exhibit list

Parties must file a joint exhibit list identifying each exhibit and each party's evidentiary objections, and must meet and confer to resolve authenticity/foundation/admissibility objections.

The parties/counsel shall prepare and file a joint exhibit list organized with columns identifying each exhibit and specifying each party's evidentiary objections, if any, to admission of each exhibit. The parties/counsel shall meet and confer in an effort to resolve objections to the authenticity/foundation/admissibility of each exhibit.

CRITICAL

Applies to

Trial exhibit binder

Three sets of trial exhibit binders (for the trial court, clerk, and witnesses) must be submitted to the Court at the time of trial.

Three sets of trial exhibit binders must be submitted to the Court at the time of trial (i.e., set for the trial court, clerk, and witnesses).

CRITICAL

Applies to

Joint witness list

The parties must jointly file a signed witness list in alphabetical order identifying each witness, experts, examination time estimates, and scheduling issues, with parties held to the estimates per Local Rule 3.25(h).

d. Joint Witness List: The parties/counsel shall work together to prepare and file a joint list of all witnesses in alphabetical order by last name that each party intends to call (excluding impeachment and rebuttal witnesses). The joint witness list shall identify each witness by name, specify which witnesses are experts, and estimate the length of direct examination, cross examination, and re-direct examination (if any) of each witness. The parties/counsel shall identify all potential witness scheduling issues and special requirements. The list must be signed by each counsel or non-represented litigant with the understanding that the parties can expect to be held to the estimates in accordance with Local Rule 3.25(h).

CRITICAL

Applies to

Trial binder

Parties must jointly prepare and lodge a tabbed trial binder (three-ring, with table of contents) containing the required trial documents at the Final Status Conference.

The parties/counsel shall jointly prepare and lodge with the Court at the FSC, a trial binder containing the above-described trial documents, which shall be tabbed and organized into three-ring binders with a table of contents, as noted below and in the following order:

CRITICAL

Applies to

Proof of service

Proof of service of summons and complaint must be filed; failure leads to OSC.

An OSC will be set concurrently with the Case Management Conference date regarding any failure to 1) prosecute of the case, 2) filing a proof of service of the summons and complaint, 3) file request for entry of default and 4) filing a case management statement.

CRITICAL

Applies to

Original deposition transcripts

Original deposition transcripts must be lodged with the clerk on the first day of trial.

Original deposition transcripts are to be lodged with the clerk on the first day of trial.

CRITICAL

Applies to

Joint trial binder

Parties must meet and confer before the FSC and submit joint trial binder(s) and joint trial exhibit binder(s) to the Court at least five court days in advance of the FSC.

Counsel and any self-represented parties are ordered to meet and confer prior to the FSC to exchange, discuss, and prepare for submission to the Court, at least five (5) court days in advance of the FSC, a joint trial binder(s) and joint trial exhibit binder(s). The Court will verify at the FSC that all parties/counsel have met and conferred to prepare joint trial documents.

CRITICAL

Applies to

Deposition designation chart

If deposition or former trial testimony will be used in lieu of live testimony, parties must jointly file a designation chart containing page/line designations, objections, counter-designations, responses, and court ruling columns.

If the parties/counsel intend to use deposition testimony or former trial testimony in lieu of any witnesses 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 line and page designation of the deposition or former testimony requested for use, (2) Objections, (3) Counter designations, (4) Any responses, and (5) Court ruling.

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

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 making an affirmative factual showing of irreparable harm, immediate danger, or another statutory basis for relief.

Ex parte applications are reserved for exigent circumstances and must comply with Rules of Court, rule 3.1202(c): "An applicant must make an a irmative 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

FW-020

A party who has received a fee waiver pursuant to CRC 3.55(7) may request an official court reporter by filing form FW-020 at least 10 calendar days before the hearing or trial. (See CRC 2.956(c).)

A party who has received a fee waiver pursuant to CRC 3.55(7) may request an official court reporter by filing form FW-020 at least 10 calendar days before the hearing or trial. (See CRC 2.956(c).)

CRITICALCivil cases

Applies to

Motions in limine binder

The motions in limine binder must include a table of contents identifying each motion, opposition, reply, and corresponding tab.

The binder also must contain a table of contents identifying each motion in limine, opposition, and reply, and the corresponding tab for each.

CRITICALCivil cases

Applies to

Proposed verdict form

Parties must file a joint proposed verdict form, or if they cannot agree after a good faith meet-and-confer, each party must separately file a proposed verdict form.

The parties shall prepare and file a joint proposed general verdict form or special verdict form (with interrogatories). If the parties cannot agree on a joint verdict form after a good faith meet-and-confer session conducted in person, over the phone, or via videoconference, each party must separately file a proposed verdict form.

CRITICALCivil cases

Applies to

Ex parte application

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

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

CRITICALCivil cases

Applies to

Full text jury instructions

The parties must prepare a complete set of full-text proposed jury instructions edited to include all case-specific information requested in the Judicial Council of California Civil Jury Instructions.

Jury Instructions (Joint and Contested) – The parties shall prepare a complete set of full-text proposed jury instructions. The submitted full-text instructions shall be appropriately edited to include all case-specific information requested in Judicial Council of California Civil Jury

CRITICALCivil cases

Applies to

Joint witness list

The parties must file a signed joint witness list (excluding impeachment and rebuttal witnesses) identifying each witness by name, expert status, estimated examination times, total testimony hours, and any scheduling issues or special requirements.

Joint Witness List – The parties shall work together and file a joint list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. The joint witness list shall identify each witness by name, specify which witnesses are experts, estimate the length of direct examination, cross-examination, and re-direct examination of each, and include a total of the number of hours for all witness testimony. The parties shall identify all potential witness scheduling issues and special requirements. The parties and counsel shall sign the joint witness list.

CRITICALCivil cases

Applies to

Deposition designation chart

Parties using deposition or former trial testimony in lieu of live testimony must meet and confer and jointly file a designation chart with five required columns, signed by the parties and counsel.

If the parties intend to use deposition testimony or former trial testimony in lieu of any witness's live testimony, the parties 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 rulings. The objecting party shall specify all objections in the respective column. The parties and counsel shall sign the designations.

CRITICALCivil cases

Applies to

Court reporter stipulation or appointment order

Parties must provide their own court reporter for hearings and trial and file either a Stipulation and Order to use a Certified Shorthand Reporter or an Order Appointing a Court Approved Reporter as Official Reporter Pro Tempore before the hearing is called.

Official court reporters are not assigned to Civil Courtrooms. It is the responsibility of the parties to provide their own Court Reporter for hearings and trial. The parties are to file either the Stipulation and Order to use Certified Shorthand Reporter or Order Appointing Court Approved Reporter as Official Reporter Pro Tempore prior to the hearing being called.

CRITICALCivil cases

A filing concerning incomplete service must explain why service has not been completed, document the efforts made to complete service, and specify the proposed completion date (Cal. Rules of Court, rule 3.110).

explaining why service has not been completed, documenting the efforts that have been made to complete service, and specifying the date by which service is proposed to be completed. (Cal. Rules of Court, rule 3.110.)

CRITICALCivil cases

Applies to

Joint list of proposed jury instructions

The parties must jointly prepare and file a signed joint list of proposed jury instructions, organized in numerical order, identifying agreed and contested instructions.

Joint List of Proposed Jury Instructions – The parties shall jointly prepare and file a joint list of proposed jury instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any. The parties and counsel shall sign the joint list of proposed jury instructions.

CRITICALCivil cases

Applies to

Case management statement

Parties must file a case management statement on Judicial Council Form CM-110 no later than 15 calendar days before the case management conference.

The parties and counsel shall file a case management statement using Judicial Council Form CM-110 no later than fifteen (15) calendar days before the date set for the conference.

CRITICALCivil cases

Applies to

Idc brief

At least five (5) calendar days before the IDC, the parties shall file IDC briefs not to exceed five (5) pages that succinctly summarize the nature of the dispute, the necessity for the discovery, the basis for any objection or withholding of information,

At least five (5) calendar days before the IDC, the parties shall file IDC briefs not to exceed five (5) pages that succinctly summarize the nature of the dispute, the necessity for the discovery, the basis for any objection or withholding of information,

CRITICALCivil cases

Applies to

Trial brief

Each party must file a trial brief identifying the claims and defenses, legal and factual issues with supporting points and authorities, relief and damages calculation, stipulated facts, anticipated evidentiary issues, and other trial-assisting information.

Trial Briefs – Each party shall file a trial brief succinctly identifying: (1) the claims and defenses subject to litigation; (2) the legal and factual issues to be decided (with supporting points and authorities); (3) the relief claimed and the calculation of damages sought; (4) the ultimate facts or issues to which you will stipulate; (5) the major evidentiary issues anticipated; and (6) any other information that may assist the Court at trial.

CRITICALCivil cases

Applies to

Request for informal discovery conference

Requests for an Informal Discovery Conference must be filed using Form LACIV-094.

The parties are instructed to file their Request for an IDC using Form LACIV-094.

CRITICALCivil cases

Applies to

Joint exhibit list

Parties must file a joint exhibit list with five required columns, meet and confer before filing to identify stipulations or objections, and sign the list.

The parties shall prepare and file a joint exhibit list organized with columns identifying: (1) the exhibit, (2) which party is 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, and (5) the date on which the exhibit was admitted. Prior to filing the joint exhibit list, the parties shall meet and confer in person, over the phone, or via videoconference 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 and counsel shall sign the joint exhibit list.

CRITICALCivil cases

Applies to

Ex parte application

Must include

proposed order

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

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

CRITICALCivil cases

Applies to

Motion in limine

Motions in limine must comply with Local Rule 3.57, including the required declaration if applicable.

When filing motions in limine, the parties must comply with Local Rule 3.57, including the required declaration, if applicable.

CRITICAL

Applies to

Trial binder

For jury trials, the parties must jointly prepare and lodge a tabbed 3-ring trial binder with a Table of Contents, with required documents organized under Tabs A-G (trial briefs, joint witness list, joint statement to the jury, joint exhibit list, jury instruction list, jury instructions, and verdict forms); trial binders are required for jury trials but discretionary for court trials.

For all jury trials, the parties/counsel shall jointly prepare and lodge a trial binder with the Court at least two (2) calendar days before the FSC, containing the required trial documents, tabbed and organized into 3-ring binders, with a Table of Contents in the front of each binder, as follows:

CRITICAL

Applies to

Discovery material list

Each party must prepare a list of discovery material intended for use at trial, specifically identifying the date, document, page, and line for each item.

Each party must prepare a list of discovery material intended to be used at trial, including but not limited to interrogatories and requests for admissions and any responses thereto as well as deposition(s), all of which shall specifically identify the date, document, page and line.

CRITICAL

Applies to

Deposition originals

Originals of depositions or discovery responses intended to be used at trial must be lodged with the Court at the time of trial.

If depositions or other discovery responses are intended to be used at trial, originals shall be lodged with the Court at the time of trial.

CRITICAL

Applies to

Exhibits

All items referenced in the exhibit list must be exchanged and/or reviewed by counsel or the parties before the Final Status Conference.

All items so referred to in the Exhibit List must be exchanged and/or reviewed by each counsel or the parties prior to the FSC.

CRITICAL

Applies to

Jury instructions

Jury instructions must include a jointly submitted packet of all requested, properly edited, unopposed instructions.

A jointly submitted packet of all requested and properly edited jury instructions to which there is no objection.

CRITICAL

Applies to

Witness list

The joint witness list must name each witness, estimate direct and cross-examination time, give total combined testimony time, and note potential scheduling problems.

The jointly prepared Witness List must include the name of each witness, an estimate of time for direct and cross-examination, and the total amount of time of all witness testimony combined for the entire trial. Potential scheduling problems must be noted.

CRITICAL

Applies to

Exhibits

Exhibits must be numbered or lettered from pre-agreed party-specific ranges, separately identified (including subparts listed separately), with each page of multi-page exhibits consecutively paginated.

Each exhibit shall be numbered or lettered. All parties shall agree in advance that their respective party will have a range of exhibit numbers or letters (e.g. Plaintiff No. 1: 1-99; Plaintiff No. 2: 100-199; Defendant: A-Z). Each exhibit must be separately identified. Subparts to an exhibit (e.g., 1A, 1B, etc.) must also be identified and listed separately. Each page of a multi-page exhibit must be consecutively paginated.

CRITICAL

Applies to

Exhibit objections

Parties objecting to a listed exhibit on foundation or admissibility grounds must meet and confer before trial, and objections not raised in the meet and confer are deemed waived absent good cause.

Any party objecting to any listed exhibit, either as to foundation or admissibility, must first meet and confer prior to trial. Any objections not so discussed in the meet and confer shall be deemed waived except upon a showing of good cause.

CRITICAL

Applies to

Jury instructions

Each party must also submit its own specifically requested, properly edited instructions and insert them into the jointly submitted packet.

Each party shall also submit specifically requested and properly edited instructions not requested by the opposing counsel/party. These instructions shall be inserted into the aforementioned packet of the jointly submitted jury instructions, all to be considered and discussed by the Court at an appropriate time during the pendency of the trial.

CRITICAL

Applies to

Special verdict form

A special verdict form is mandatory, must be jointly prepared in final form, and must be clear and direct to avoid juror confusion.

A special verdict form is mandatory and shall be jointly prepared in final form. Verdict forms shall be clear and direct to avoid any juror confusion.

CRITICAL

4) All contested issues of fact; 5) All contested issues of law, together with points and authorities supporting the position of the parties; 6) A list of major evidentiary issues anticipated, any relevant points and authorities supporting the position of the parties; 7) A detailed statement of the damages and relief claimed, including a specific breakdown of the elements of damages claimed and the amount sought; and, 8) Any other information that will assist the Court.

4) All contested issues of fact; 5) All contested issues of law, together with points and authorities supporting the position of the parties; 6) A list of major evidentiary issues anticipated, any relevant points and authorities supporting the position of the parties; 7) A detailed statement of the damages and relief claimed, including a specific breakdown of the elements of damages claimed and the amount sought; and, 8) Any other information that will assist the Court.

CRITICAL

Applies to

Motion in limine

All parties must meet and confer on motions in limine before filing them; failure to do so may result in the court refusing to hear the motion.

All parties must meet and confer on all motions in limine prior to filing said motions. Failure by any party or counsel to exchange or discuss any motion in limine may result in the refusal by the Court to hear any such motion in limine, pursuant to applicable court rules.

CRITICAL

Applies to

Exhibit list

All parties must jointly prepare and exchange a completed exhibit list indicating each document, physical evidence item, and any stipulation to authenticity and/or admissibility.

All parties must jointly prepare and exchange a completed Exhibit List, indicating each document and item of physical evidence, and whether there is a stipulation to authenticity and/or admissibility.

CRITICAL

Applies to

Court reporter form

Parties must provide their own court reporters and file Form LACIV237 (reporter on the Pro Tempore directory) or Form LACIV236 (reporter not on the directory) in the courtroom before the judge calls the case.

If you require a court reporter, you must provide your own. The following forms must be filed in the courtroom prior to the judge calling your case: Form LACIV237, if the court reporter is listed on the court's Pro Tempore Court Reporter Directory; or, Form LACIV236, if the court reporter is not listed on said directory.

CRITICAL

Applies to

Trial brief

Trial briefs must include a description of each cause of action and key affirmative defenses, the issues to be decided, and a statement of ultimate facts or issues to be stipulated (required-content list continues beyond this excerpt).

Trial briefs are mandatory for all (both Court and jury) trials and must include the following information and not exceed 20 pages: 1) A brief description of each cause of action and key affirmative defenses presented and the issues to be decided; 2) Statement of ultimate facts or issues to which you will stipulate;

CRITICAL

Applies to

Ex parte application

Must include

proposed order

The Court may not consider ex parte applications that are filed without a proposed order.

Please note that the Court may not consider ex parte applications submitted/filed without a proposed order.

CRITICAL

Applies to

Ex parte application

Must include

proposed order

Ex parte applications filed without a proposed order may not be considered by the Court.

Please note that the Court may not consider ex parte applications submitted/filed without a proposed order.