Los Angeles Superior Court Document Filing Requirements

CRITICAL

Applies to

Joint chart deposition designations

Each designating party's designations in the joint chart must include six required columns, from designation number and witness name through the Court's 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.

CRITICAL

Applies to

Joint exhibit list

All parties (including self-represented parties) must jointly prepare and file a joint exhibit list in the mandated eight-column format 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(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

Motion in limine

Must include

caption

Each motion in limine's caption must concisely identify the evidence the moving party seeks to exclude.

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

CRITICAL

Applies to

Joint chart deposition designations

If any party intends to use deposition or former trial testimony, counsel and self-represented parties 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

Proposed verdict form

For jury trials, the parties must jointly prepare and file a proposed verdict form acceptable to all parties, and if they cannot agree, each party must separately file its own proposed verdict form.

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

CRITICAL

Applies to

Trial binder

No later than five calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department 207 a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following (for trials by the Court without a jury, the Trial Binder shall only include the documents listed under Tabs A, B, C, H, and I): Tab A: Trial Briefs (Optional. If no trial briefs are filed, leave Tab A empty.) Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab E: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).

No later than five calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department 207 a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following (for trials by the Court without a jury, the Trial Binder shall only include the documents listed under Tabs A, B, C, H, and I): Tab A: Trial Briefs (Optional. If no trial briefs are filed, leave Tab A empty.) Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab E: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).

CRITICAL

Applies to

Joint report

If the Court sets a Status Conference, all parties must meet and confer and file a Joint Report detailing discovery status, ADR efforts, and contemplated motions.

If a Status Conference is set by the Court, all parties shall meet and confer in person, telephonically or by videoconference, and cooperate in the preparation of a Joint Report which shall be filed no later than 5 court days before the Status Conference. The Joint Report shall provide detailed information regarding the following: a) Discovery i. What discovery has been completed? ii. What discovery is outstanding and the anticipated dates of completion? answer is Yes, parties shall provide a brief summary of the discovery issues and their efforts to resolve the issues informally without Court intervention. b) Alternative Dispute Resolution i. Have the parties agreed to resolve the action through ADR, including private mediation, a Mandatory Settlement Conference through the Resolve Law LA program or a Settlement Conference with a judicial officer? If the answer is no, the parties shall explain why and what impediments preclude resolving the action through ADR. If the parties have agreed to private mediation, the parties should provide information about the mediator and the date of the mediation. c) Motion Practice i. Are there any motions the parties contemplate filing? If so, parties shall provide a brief summary of the contemplated motions and their efforts to resolve the issues informally without Court intervention.

CRITICAL

Applies to

Joint witness list

Witnesses who are not included on the joint witness list are subject to being excluded from testifying at trial.

Any witness who is not included on the joint witness list is subject to being excluded from testifying at

CRITICAL

Applies to

Joint statement of the case

For jury trials, counsel and self-represented parties must jointly prepare and file a brief joint statement of the case for the Court to read to the jury, usually only a few sentences without legal jargon.

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(g)(4).) A joint statement should usually be only a few sentences without legal jargon.

CRITICAL

Applies to

Joint list of proposed jury instructions

For jury trials, the parties must jointly prepare and file a Joint List of Proposed Jury Instructions stating, for each instruction, its 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: (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

Motion in limine

Motions in limine must comply with the statutory notice provisions of Code of Civil Procedure section 1005.

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 Local Rule 3.57(a).

CRITICAL

Applies to

Joint summary of testimony

If the parties do not have a court reporter, all parties must jointly provide the Court with a daily summary of the testimony and admitted evidence by the morning following each day's testimony.

If the parties do not have a court reporter, all parties will be required to provide the Court with a joint summary of the testimony and evidence admitted on a daily basis by the morning following the testimony.

CRITICAL

Applies to

Motion in limine

Must include

caption

Motions in limine captions must identify excluded evidence, be numbered consecutively, and opposition/reply papers must reference the motion number in their 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

Proposed jury instructions

Proposed jury instructions must be organized behind Tab F into three groups, labeled by cover sheets, in the order of agreed-upon instructions, plaintiff's contested requests, then defendant's contested requests.

The parties shall organize proposed jury instructions into groups behind Tab F in the following order (labeled by cover sheets): (1) the agreed-upon instructions, (2) plaintiff’s requested instructions to which defendant objects, and (3) defendant’s requested instructions to which plaintiff objects.

CRITICAL

Applies to

Joint witness list

The joint witness list must be organized in specified columns (witness name in alphabetical order with expert status and accommodations, calling party, expected-testimony status, description of expected testimony, and direct/cross/total examination time estimates in hours) and must state the grand total of all estimated testimony times in the last column.

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 any special requirements or accommodations needed for the witness (e.g., interpreter), (2) the party calling the witness, (3) whether the witness is actually expected to testify, (4) a brief description of the witness’s expected testimony, (5) an estimate of the length of direct examination (in hours), (6) an estimate of the length of cross-examination (in hours), and (7) the total estimated length of examination (in hours). At the end of the joint witness list, the parties and any self-represented parties shall add up the estimated times for all witnesses’ testimony and state the grand total in the last column.

CRITICAL

Applies to

Joint chart deposition designations

Each counter-designating party's counter-designations in the joint chart must include six required columns, from designation number and witness name through 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 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

Joint chart of deposition designations

Counter-designations in the joint chart must include columns for the witness name and designation number, 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 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

Proposed jury instructions

For jury trials, the parties must jointly prepare a complete set of full-text proposed jury instructions, editing all CACI instructions to insert party names and eliminate blanks and inapplicable 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 witness list

All parties (including self-represented parties) must jointly prepare and file a joint witness list, excluding impeachment and rebuttal witnesses, in the mandated seven-column format with a grand total of estimated testimony times.

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(g)(5).) 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 any special requirements or accommodations needed for the witness (e.g., interpreter), (2) the party calling the witness, (3) whether the witness is actually expected to testify, (4) a brief description of the witness’s expected testimony, (5) an estimate of the length of direct examination (in hours), (6) an estimate of the length of cross-examination (in hours), and (7) the total estimated length of examination (in hours). At the end of the joint witness list, the parties and any self-represented parties shall add up the estimated times for all witnesses’ testimony and state the grand total in the last column.

CRITICAL

Applies to

Joint witness list

The parties must jointly prepare and file a list of all witnesses any party intends to call at trial, excluding impeachment and rebuttal witnesses, per Local Rule 3.25(g)(5).

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 chart of deposition designations

Designations in the joint chart must include columns for the witness name and designation number, date and type of testimony, page and line designations, objections, related counter-designations, and the Court’s 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.

CRITICAL

Applies to

Joint exhibit list

Counsel and self-represented parties must jointly prepare and file a joint exhibit list containing eight required columns for each trial exhibit (number, description, offering party, stipulations, objections, and 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, (7) the date the exhibit was marked for identification, and (8) the date the exhibit was admitted into evidence. (Local Rule 3.25(g)(6).)

CRITICAL

Applies to

Trial binder

The Trial Binder must include designated documents organized under Tabs A through I, with bench trials (jury-waived) requiring only Tabs A, B, C, H, and I and Tab A (trial briefs) optional.

contents that includes the following (for trials by the Court without a jury, the Trial Binder shall only include the documents listed under Tabs A, B, C, H, and I): Tab A: Trial Briefs (Optional. If no trial briefs are filed, leave Tab A empty.) Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Statement to Be Read to the Jury Tab E: Joint List of Jury Instructions Tab F: Joint and Contested Jury Instructions Tab G: Joint or Contested Verdict Form(s) Tab H: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab I: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).

CRITICAL

Applies to

Ex parte application

Ex parte relief will be granted only upon an admissible-evidence showing of irreparable harm, immediate danger, or a statutory basis for granting ex parte relief.

The Court will grant ex parte relief only upon a showing, by admissible evidence, that the moving party will suffer "irreparable harm," "immediate danger," or where the moving party identifies "a statutory basis for granting relief ex parte." (Cal. Rules of Court, rule 3.1202(c).)

CRITICAL

Applies to

Joint chart of deposition designations

If a party intends to use deposition or former trial testimony, the parties 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 witness list

Witnesses not listed on the joint witness list are subject to exclusion from testifying, and a party seeking to elicit testimony from an unlisted witness must first show good cause to the court.

Any witness who is not included on the joint witness list is subject to being excluded from testifying at ... 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

Showing of good cause

A party seeking to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the Court.

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

Court reporter filing

Parties requiring a court reporter must file Form LACIV237 or LACIV236 in the courtroom prior to the case being called.

COURT REPORTERS: 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

Ex parte application

Must include

proposed order

Please note that the Court may not consider ex parte applications submitted/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

Judgment

Judgments, orders, and stipulations filed directly in the courtroom must include self-addressed stamped envelopes and conforming copies.

Judgments, orders, and stipulations may be filed directly in the courtroom but must include self-addressed, stamped envelopes and copies to conform.

CRITICAL

Applies to

Ex parte application

Must include

proposed order

Please note that the Court may not consider ex parte applications submitted/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

Special verdict form

A special verdict form is mandatory, must be jointly prepared in final form, and must be adapted to CACI with proper spacing.

A special verdict form is mandatory and shall be jointly prepared in final form. This special verdict form shall be adapted to CACI with proper spacing, particularly noted to allow for both clarity and direction.

CRITICAL

Applies to

Exhibit binder

The exhibit list must be included in the exhibit binders.

The exhibit list must be included in the binders.

CRITICAL

Applies to

Jury instructions

Each requested CACI instruction must identify the requesting party/parties at the top, state whether it is given as requested or modified, state whether it is withdrawn, and include a signature line for the Court.

All requested CACI instructions, per the foregoing, must be submitted in proper form which includes: A) At the top of each requested jury instruction, identification of the party/parties requesting the instruction; B) Whether the instruction is to be given as requested or modified; C) Whether the instruction is withdrawn; and D) A signature line for the Court.

CRITICAL

Applies to

Trial binder

h. 3-Ring Trial Binder containing all the documents above in 4.b through 4.g, with a table of contents.

h. 3-Ring Trial Binder containing all the documents above in 4.b through 4.g, with a table of contents.

CRITICAL

Applies to

In limine motion

Objections to the use of discovery material must be raised by way of an in limine motion.

Any objections to the use of discovery material shall be done by way of an in limine motion.

CRITICAL

Applies to

Jury instructions

Parties must submit a jointly submitted packet of all requested and properly edited jury instructions to which there is no objection.

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

CRITICAL

Applies to

Jury instructions

Proposed jury instructions must be organized behind Tab F with agreed-upon instructions first, followed by contested (including special) instructions.

The parties shall organize proposed jury instructions behind Tab F, with the agreed upon instructions first in order followed by the contested instructions (including special instructions) submitted by each party.

CRITICAL

Applies to

Jury instructions

Each party must submit its own specifically requested and properly edited instructions not requested by the opposing party, inserted into the joint 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

Stipulation and order

A continuance Stipulation and Order must state the date the Complaint was filed, the current trial date, and the proposed Final Status Conference and trial dates.

Said Stipulation and Order shall state the date the Complaint was filed, the current trial date, as well as the proposed Final Status Conference date and proposed trial date.

CRITICAL

Applies to

Trial binder

For all trials (jury and non-jury), 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: Tab A: Trial Briefs of all parties Tab B: Joint Witness List Tab C: Joint Statement to be Read to the Jury Tab D: Joint Exhibit List Tab E: Joint List of Jury Instructions (identifying the agreed upon and contested instructions) Tab F: Joint and Contested Jury Instructions

For all trials (jury and non-jury), 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: Tab A: Trial Briefs of all parties Tab B: Joint Witness List Tab C: Joint Statement to be Read to the Jury Tab D: Joint Exhibit List Tab E: Joint List of Jury Instructions (identifying the agreed upon and contested instructions) Tab F: Joint and Contested Jury Instructions

CRITICAL

Applies to

Court reporter forms

Parties requiring a court reporter must provide their own and must 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

Jury instructions

For jury trials, parties must meet and confer at least 10 days before the FSC to develop a single set of edited jury instructions, with editing responsibility assigned to the requesting party (or plaintiff if both parties demand a jury trial).

Not less than ten days prior to the final status conference, all parties are ordered to have a meaningful meet and confer and develop a single set of jury instructions to be read to the jury. All jury instructions must be edited. The party requesting the instructions should edit the instruction. Instructions requested by both parties should be edited by the party demanding a jury trial. If both parties are demanding a jury trial, plaintiff should edit instructions requested by both parties.

CRITICAL

Applies to

Joint exhibit list

The joint exhibit list must be a chart with columns for exhibit number, brief description, page count, stipulation to admissibility, and stipulation to authentication.

The list must be in a chart format with columns showing 1) exhibit number, 2) a brief description of the exhibit, 3) the number of pages of the exhibit, 4) whether, after a meaningful meet and confer, the parties stipulate to the exhibit's admissibility, and 5) whether, after a meaningful meet and confer, the parties stipulate to the exhibit's authentication.

CRITICAL

Applies to

Jury instructions

Compliance with California Rules of Court, Rule 2.1055 is mandatory for proposed jury instructions.

Compliance with California Rules of Court, Rule 2.1055 is mandatory.

CRITICAL

Applies to

Exhibits

Exhibits require two copies: a paper copy for the clerk due the first day set for trial and a digital copy for the judge due at or prior to the FSC by e-filing or flash drive.

The court requires two copies of exhibits; one paper or "hard" copy for marking by the clerk and a digital copy for the judge. The digital copy must be provided to the court at or prior to the FSC by either e-filing or portable storage device such as a flash drive. The paper copy must be provided to the clerk on the first day set for trial.

CRITICAL

Applies to

Jury instruction list

For jury trials, parties must meet and confer at least 10 days before the FSC and develop a single joint list of CACI and special jury instructions in chart format.

Not less than ten days prior to the final status conference, all parties are ordered to have a meaningful meet and confer and develop a single joint list of CACI and special jury instructions. The list must be in a chart format with columns showing 1) the number of the instruction, 2) a brief description of the instruction, 3) the party or parties requesting the

CRITICAL

Applies to

Witness list

Parties must meet and confer at least 10 days before the FSC and develop a single joint witness list in chart format with six required columns (name, calling party, testimony description, interpreter needs, and direct/cross-examination time estimates).

Not less than ten days prior to the final status conference, all parties are ordered to have a meaningful meet and confer and develop a single joint witness list. The list must be in a chart format with columns showing 1) The witness' name, 2) the party initially calling the witness, 3) a brief description of the witness' expected testimony, 4) whether the witness requires an interpreter and, if so, the language, 5) a considered and realistic time estimate of direct-examination, 6) a considered and realistic time estimate of cross-examination.

CRITICAL

Applies to

Special verdict form

For jury trials, parties must meet and confer at least 10 days before the FSC to develop a single special verdict form, with each side drafting the sections for which it bears the burden of proof before the meet and confer.

Not less than ten days prior to the final status conference, all parties are ordered to have a meaningful meet and confer and develop a single special verdict form for submission to the jury. Plaintiff and any cross-complainants are to develop the first draft of those sections of the special verdict form for which they have the burden of proof, prior to the meet and confer. Defendants and any cross-defendants are to develop the first draft of those sections of the special verdict form for which they have the burden of proof, prior to the meet and confer.

CRITICAL

Applies to

Proposed jury instructions

Proposed jury instructions must include a joint set plus each side's objected-to instructions in full text, with blanks completed, compliance with SCLAC 3.170-3.171, and CACI used for form instructions.

The parties are to submit a joint set of instructions, plus a set of instructions from each side to which there are objections. 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 SCLAC 3.170 - 3.171. Use CACI for form instructions.