Los Angeles Superior Court Document Filing Requirements

CRITICALCivil cases

Applies to

Proposed jury instructions

At closing, counsel must have a complete set of full-text proposed instructions with California Civil Jury Instructions edited to insert party names and remove blanks, brackets, and irrelevant material.

At closing, counsel shall then have prepared a complete set of full-text proposed jury instructions, editing all proposed California Civil Jury Instructions and inserting party name(s) and eliminating blanks, brackets and irrelevant material.

CRITICALCivil cases

Applies to

Motion

All motions must be reserved through the Court Reservation System on the Court’s website.

All motions must be reserved via Court Reservation System (CRS) on the Court’s website at www.lacourt.ca.gov under “Online Services, Court Reservation System.”

CRITICALCivil cases

Applies to

Joint exhibit list

The joint exhibit list must be signed by the parties or counsel.

The parties/counsel shall sign the joint exhibit list.

CRITICALCivil cases

Applies to

Joint exhibit list

The parties must file a joint exhibit list with columns for the exhibit, offering party, authenticity or admissibility stipulation, identification date, and admission date.

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.

CRITICALCivil cases

Applies to

Proposed jury instructions

After the case-in-chief, counsel must prepare a complete, unedited set of full-text proposed jury instructions.

After the case-in-chief, counsel to prepare a complete set of full-text proposed jury instructions without edits.

CRITICALCivil cases

Applies to

Joint witness list

The parties must jointly file an alphabetized witness list identifying each witness, expert status, estimated examination lengths, and total testimony hours.

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.

CRITICALCivil cases

Applies to

Proposed jury instruction list

The parties must jointly file a numerically ordered list identifying agreed and contested proposed jury instructions.

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.

CRITICALCivil cases

Applies to

Exhibit binder

If exhibits were not exchanged electronically, counsel must provide an exhibit binder to each opposing party.

Counsel must also supply an exhibit binder(s) to each opposing party if not exchanged electronically.

CRITICALCivil cases

Applies to

Joint proposed special verdict form

Counsel must prepare and lodge the joint proposed special verdict form directly in Department 412; it must not be e-filed and must be lodged before the matter is taken under submission.

Joint Proposed Special Verdict Form to be prepared by counsel and lodged directly in Department 412 (no e-filing) before the matter will be taken under submission.

CRITICALCivil cases

Applies to

Trial brief

Each party or counsel must file a trial brief identifying the claims and defenses, major legal issues with supporting authorities, claimed relief and damages calculation, and other information helpful to the Court.

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 & authorities) 3. The relief claimed and calculation of damages sought 4. Any other information that may assist the Court at Trial.

CRITICALCivil cases

Applies to

Proposed verdict form

The parties must jointly file an agreed general or special verdict form with interrogatories, or separately file proposed forms if they cannot agree.

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 Rule 3.25(g)(8)). If the parties/counsel cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

CRITICALCivil cases

Applies to

Motion in limine

Each motion in limine must have a caption that concisely identifies the evidence the moving party seeks to preclude.

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

CRITICALCivil cases

Applies to

Joint exhibit list

The joint exhibit list must record stipulations in the corresponding column or, if there are none, the objecting party must specify all objections there.

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.

CRITICALCivil cases

Applies to

Joint statement of case

Must include

caption

For jury trials, the parties and counsel must prepare and file a joint written statement of the case for the Court to read to the jury, and must sign the statement and all other joint documents.

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 jury (L.A. County Court Rule 3.25(g)(4)). The parties/counsel shall sign the joint statement, and all other joint documents.

CRITICALCivil cases

Applies to

Special jury instructions

Special instructions must be jury-ready and contain only the instruction number, title, and text, without markings identifying the requesting party.

The parties/counsel shall prepare any special instructions in a format ready for submission to the jury with the instruction number, title, and text only (i.e. there should be no boxes or other indication on the printed instruction itself as to the requesting party).

CRITICALCivil cases

Applies to

Testimony designation chart

When deposition or former trial testimony will replace live testimony, the parties must meet and confer and jointly file a chart of 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 witnesses’ live testimony, the parties/counsel shall meet & confer and jointly prepare and file a chart 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) and responses thereto and (5) the Court’s ruling.

CRITICAL

Applies to

Judgments orders stipulations

Judgments, orders, and stipulations must be submitted with self-addressed stamped envelopes and copies to conform.

Judgments, orders, and stipulations must include self-addressed, stamped envelopes and copies to conform.

CRITICAL

Applies to

Judgment, order, stipulation

Judgments, orders, and stipulations filed by self-represented litigants must include self-addressed stamped envelopes and conforming copies.

Judgments, orders, and stipulations must include self-addressed, stamped envelopes and copies to conform.

CRITICAL

Applies to

Form LACIV237, Form LACIV236

Court reporter forms LACIV237 (approved) or LACIV236 (non-approved, requires stipulation) must be filed in courtroom before case is called.

The following forms must be filed in the courtroom prior to the judge calling your case: Form LACIV237 - for reporters listed on Court’s Pro Tempore Court Reporter Directory (court approved) Form LACIV236 - for reporters not listed on court’s directory (not court approved). NOTE: A stipulation is required for the appointment of court reporters that are not on the Court’s approved list.

CRITICAL

Applies to

Stipulation for court reporter appointment

A stipulation signed by all parties, secured by the hiring party before the hearing, is required to appoint a court reporter not on the Court's approved list.

A stipulation is required for the appointment of court reporters that are not on the Court's approved list. It is the responsibility of the hiring party to secure the stipulation/signatures of all other parties prior to the hearing.

CRITICAL

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include a proposed order.

Self-represented parties must bring the ex parte application, declaration of notice, and proposed order to the Clerk’s Office for payment of filing fee by 8:30 a.m. on the day of the hearing

CRITICAL

Applies to

Court reporter forms

Parties requiring a court reporter must provide their own and file Form LACIV237 (court-approved reporters) or Form LACIV236 (non-approved reporters) 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 - for reporters listed on Court’s Pro Tempore Court Reporter Directory (court approved) Form LACIV236 - for reporters not listed on court’s directory (not court approved).

CRITICAL

Applies to

Exhibit binder

The exhibit list must be included in the trial exhibit binders.

The exhibit list must be included in the binders.

CRITICAL

Applies to

Objections to visual aids

Objections to PowerPoint slides must be submitted to the court as soon as possible and before the jury is empaneled.

If there are any objections to any slide, the objecting party must submit the objections to the court as soon as possible and before the jury is empaneled.

CRITICAL

Applies to

Electronic media exhibit

The proffering party is responsible for ensuring a method of promptly displaying electronic media trial exhibits in the jury room during deliberations upon the jury's request.

It is the proffering patty's responsibility to ensure a method of promptly displaying any electronic media trial exhibit in the jury room during deliberations upon request of the jury.

CRITICAL

Applies to

Proposed verdict form

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

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

CRITICAL

Applies to

Final jury instructions

After the jury instruction conference, one party must submit the final court-approved set of jury instructions, including court-ordered modifications and excluding the disposition table from the top of each instruction.

After the jury instruction conference, the court will require one of the parties to submit a final set of jury instructions approved by the court, including any modifications ordered by the court, and excluding the disposition table from the top of each instruction.

CRITICAL

Applies to

Trial brief

Each party must file a trial brief identifying disputed claims and defenses, major legal issues with supporting authorities, relief and damages calculations, and other trial-assisting information.

Each party is required to file a trial brief succinctly identifying: (I) the claims and defenses that remain in dispute for trial; (2) the major legal issues (with supporting points and authorities); (3) the relief and calculation of any damages sought; and (4) any other information that may assist the court at trial.

CRITICAL

Applies to

Joint exhibit list

Counsel and self-represented parties must jointly prepare and file an exhibit list stating, for each exhibit, the exhibit number, description, offering party, authentication and admissibility stipulations, evidentiary objections, and marking/admission dates.

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 with reference to the applicable evidence code section(s) or other legal authority, (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).)

CRITICAL

Applies to

Exhibit

The court's yellow evidence tags, filled in with only the case number and exhibit number, must be placed on each exhibit in the Judicial Assistant's copy of the Exhibit Binder.

The parties' counsel and any self-represented parties shall also place the court's yellow evidence tags (with only the case number and exhibit number filled in) on each exhibit in the Judicial Assistant's copy of the Exhibit Binder.

CRITICAL

Applies to

Joint chart page line designations

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

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

Proposed jury instructions

In jury trials, parties must jointly prepare a complete set of full-text proposed jury instructions, editing CACI instructions to insert party names and eliminate 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

Exhibit list

Flash drives or CD/DVDs containing unmarked photographs must be accurately described on the Exhibit List.

If the flash drive or CD/DVD contains photographs that are not individually marked as an exhibit, it must be described accurately on the Exhibit List, for example Plaintiff's Exhibit 2 (flash drive or CD/DVD containing 3 photographs).

CRITICAL

All non-documentary exhibits must be marked and a simple written description inserted behind the corresponding numerical tab in the Exhibit Binders.

The parties' counsel and any self- represented parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the Exhibit Binders, and shall comply with Paragraph 5, infra.

CRITICAL

Applies to

Joint witness list

Parties must jointly prepare and file a witness list in a prescribed column format (name, expert status, accommodations, calling party, expected testimony, examination time estimates) excluding impeachment and rebuttal witnesses, with a grand total of estimated testimony hours.

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) which state (I) 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 and redirect 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.

CRITICAL

Applies to

List of exhibits admitted

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

Joint exhibit list

Parties must meet and confer in good faith to resolve exhibit objections, and any objection not articulated on the exhibit list may result in the exhibit being deemed admitted.

As set forth above, the parties' counsel and any self-represented parties shall meet and confer in good faith an effort to resolve objections to the authenticity and admissibility of each exhibit. If an objection to an exhibit is not articulated on the exhibit list, the trial court may deem the exhibit admitted.

CRITICAL

Applies to

Electronic media exhibit

Recordings must be described as to whether they contain an audio file, and a transcript of the audio must be filed with the CD/DVD when the exhibit is offered.

If the flash drive or CD/DVD contains a recording, the description on the Exhibit List must state whether it contains an audio file, and the submitting party must confirm that a transcript of the audio has been filed with the CD/DVD at the time the exhibit is offered to the court. [CRC, Rule 2.1040]

CRITICAL

Applies to

Joint chart page 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

Motion in limine

Motion in limine captions must identify the evidence to be excluded, motions must be numbered consecutively, and opposition/reply papers must identify the corresponding motion number in the caption.

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

CRITICAL

Applies to

Electronic media exhibit

Flash drives or CD/DVDs offered into evidence must be listed on the Exhibit List, have a placeholder in the Exhibit Book, be marked as an exhibit, and contain an exhibit tag.

If a flash drive or CD/DVD is offered into evidence, it must be listed on the Exhibit List, with a placeholder in the Exhibit Book identifying the exhibit and exhibit number, and the flash drive or CD/DVD must be marked as an exhibit. Every exhibit that is marked must contain an exhibit tag.

CRITICAL

Applies to

Electronic media exhibit

Photos on electronic media that bear separate exhibit numbers must each be printed out and have an exhibit tag affixed.

If the flash drive or CD/DVD is marked as an exhibit and any of the photos contained or presented within the electronic media are also marked with a separate exhibit number, then each of the marked photos must be printed out and have an exhibit tag affixed to each item.

CRITICAL

Applies to

Joint statement of case

In jury trials, counsel and self-represented 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

Joint chart page line designations

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

In the joint chart, each designating party's designations of deposition or former testimony shall include columns which state: (I) 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.

CRITICAL

Applies to

Verdict form

In jury trials, 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

Exhibit list

CD/DVDs in an envelope, sleeve, or case must be described on the Exhibit List including the container (e.g., Plaintiff's 1 - DVD in a white sleeve containing 5 photographs of the defendant).

If a CD/DVD is in an envelope, sleeve, or case, the description on the Exhibit List must state the following, Plaintiff's 1 - DVD in a white sleeve containing 5 photographs of the defendant.

CRITICAL

Applies to

Motion in limine

Must include

caption

Motions in limine captions must identify evidence to exclude, be numbered consecutively; opposition/reply must include motion number; uncontested motions note 'uncontested'.

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. Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers. Uncontested motions should note "uncontested" in the caption.

CRITICAL

Applies to

Trial documents

All trial documents, except exhibits, must be filed in compliance with the Court's TRIAL PREPARATION REQUIREMENTS.

All trial documents must be filed pursuant to the TRIAL PREPARATION REQUIREMENTS (except for exhibits).

CRITICAL

Applies to

Joint summary of daily 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.

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

Joint list of proposed jury instructions

In jury trials, parties must jointly prepare and file a joint list of proposed jury instructions stating, for each instruction, the number, title, requesting party, agreed/contested status, any objection, and whether it was given.

For jury trials, the parties' counsel and any self-represented parties shall work together to prepare and file a joint list of proposed jury instructions (in the format set forth below) which states, as to each proposed jury instruction: (I) the jury instruction number (listed in numerical order), (2) the title of the jury instruction, (3) the party/parties 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").