Los Angeles Superior Court Document Filing Requirements

CRITICAL

Applies to

Joint witness list

The parties must submit a joint witness list with per-witness time estimates and a total, and absent good cause total testimony hours may not exceed the trial estimate given at the case management conference.

The parties must submit a joint list of all witnesses each party actually intends to call. Next to each witness, indicate the total time estimated for that witness's testimony (including direct, cross, redirect). Make realistic time estimates. At the end of the list, total the time estimated for testimony. Absent good cause, the total number of hours listed for testimony shall not exceed the trial estimate given at the case management conference, including the allocation of one day of the trial estimate for jury selection and sufficient time for opening statements and closing arguments.

CRITICAL

Applies to

Expert declaration

No later than the final status conference, counsel must present the Court and opposing counsel a Code of Civil Procedure section 2034.260 declaration stating the substance of each trial expert's proffered opinion.

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

CRITICAL

Applies to

Motion in limine and bifurcation motion

Compliance with SCLAC 3.57, including its declaration and meet and confer requirements, is mandatory for in limine and bifurcation motions.

Compliance with SCLAC 3.57, including the declaration and meet and confer requirements, is mandatory.

CRITICAL

Applies to

Joint statement of the case

The parties must submit a joint statement of the case, which the Court will read to prospective jurors.

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

CRITICAL

Applies to

Motion in limine

Must include

certificate of conference

Every motion in limine must be accompanied by a sworn declaration attesting that the subject was discussed with the opposing party and setting forth the opposing party's position.

All motions in limine must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party and setting forth the opposing party's position regarding the motion(s)

CRITICALCivil cases

Applies to

Motion in limine

Motions in limine must comply with LR 3.57, including its declaration and meet-and-confer requirements, and boilerplate or form motions in limine are disfavored.

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

CRITICALCivil cases

Applies to

Settled statement

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

The Court strongly encourages the parties to use a court reporter for trial. If no court reporter is used, the parties must jointly prepare a settled statement summarizing the day's proceedings, and lodge it in the courtroom the next morning before proceedings resume.

CRITICALCivil cases

Applies to

Idc request

IDC requests on form LACIV094 must describe the nature of the dispute in appropriate detail or the request will be denied.

If an IDC is requested, the party requesting it must describe in appropriate detail the nature of the dispute on form LACIV094. Vague and amorphous descriptions of the dispute (for example, “the other side is not complying with my discovery requests”) will result in the denial of the IDC request.

CRITICALCivil cases

Applies to

Joint exhibit list

The joint exhibit list must allocate number blocks by party and include each exhibit's number, a brief description, and three columns headed 'Stipulation: Authenticity/Admission', 'Date Identified', and 'Date Admitted', with counsel asked to attempt stipulations to admissibility or foundation.

Counsel are to agree on a block of numbers to be allocated to each party for exhibits. The exhibit list shall include the exhibit number and a brief description of the exhibit. There shall be three columns to the right of the description. The first of these should be a column headed "Stipulation: Authenticity/Admission." The second of these should be a column headed "Date Identified." The third should be a column headed "Date Admitted." The Court requests that counsel attempt to stipulate to the admissibility or foundation of exhibits contained on the list.

CRITICALCivil cases

Applies to

Joint witness list

Parties must submit a joint witness list showing each witness's estimated total testimony time (direct, cross, redirect, recross) plus a total of all time estimates.

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

CRITICALCivil cases

Applies to

Proposed jury instructions

Strict compliance with CRC Rule 2.1055's form and format requirements for proposed jury instructions will be enforced, and counsel are strongly encouraged to use the CACI instructions without deviation.

CRC Rule 2.1055 contains specific requirements regarding the filing and submission of proposed jury instructions, including form and format. Strict compliance with CRC 2.1055 will be enforced. The Court strongly encourages counsel to adhere to the proposed CACI instructions and not deviate from them.

CRITICALCivil cases

Applies to

Proposed verdict forms

Parties must submit proposed general or special verdict forms, should submit alternative forms if they cannot agree on a single form, and must identify areas of disagreement, with strong encouragement to use the CACI verdict forms.

submit proposed general or special verdict forms. If counsel cannot agree advance on a single verdict form, alternative verdict forms should be submitted. Counsel shall identify for the Court the areas of disagreement with respect to the verdict form. Counsel are strongly encouraged to use the suggest verdict forms in the CACI instructions and not deviate from them.

CRITICALCivil cases

Applies to

Deposition designation chart

Parties using deposition or former testimony in lieu of live testimony must meet and confer and jointly file a designation chart with columns for designations, objections, counter-designations, responses, and the Court's ruling.

If the p a r t i e s intend to use deposition testimony or former trial testimony in lieu of any witness’s live testimony, counsel shall meet and confer and jointly prepare and file a chart with columns for: 1) the line and page designations of the deposition or former testimony requested, 2) objections, 3) counter- designations, 4) any responses to the objections, and 5) the Court’s ruling.

CRITICALCivil cases

Applies to

Proposed jury instructions

Parties must submit a joint set of agreed jury instructions plus each side's objected-to instructions, providing full text of all requested instructions with blanks completed and compliance with LR 3.170–3.171.

The parties are to submit a joint set of agreed- upon 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 in the form instructions, make any appropriate modifications, and comply with LR 3.170 – 3.171.

CRITICAL

Applies to

Jury instructions

Counsel must provide a complete hard copy set of jury instructions to the court, with all brackets removed and blanks filled in, conforming to Rule 2.1055 California Rules of Court.

As required by General Order 3.F and by Los Angeles County Court Rules 3.170 - 3.172, it is the responsibility of counsel to provide the Court with a complete set (hard copy) of jury instructions. Counsel must remove all brackets, fill in all blanks in advance. Examples are names of the parties, appropriate gender and number (singular or plural). Each instruction shall conform to the requirements of Rule 2.1055, California Rules of Court. Hard copies must be filed with the clerk.

CRITICAL

Applies to

Special jury instructions

Case-specific special jury instructions not covered by CACI must be separately numbered and contain a clear, accurate statement of the law with complete citations to supporting authorities.

Any case-specific special instructions not covered by CACI instructions shall be separately numbered and be a clear accurate statement of the law with complete citations to authorities in support.

CRITICAL

Applies to

Verdict form

Proposed joint verdict forms must be submitted before trial, with a courtesy copy via email; if no agreement, each party files their version in Word to Department 529.

Submit a proposed joint verdict form before trial commences sending a courtesy copy to the Court's email box. Follow the language and pattern of CACI instructions as much as possible. If the parties cannot agree on a joint form, each party must file their version and email Department 529 the draft in Word.

CRITICAL

Applies to

Verdict form

In a simple issue case, submit a general verdict form. If a special verdict form is requested, submit a single proposed special verdict form which includes any special questions of fact on which a party is requesting a finding. The special questions, of course, must be submitted in logical position in relation to other questions on the verdict form. This will require a conference between counsel which may take substantial time. PLEASE HAVE A PROPOSED DRAFT COMPLETED BEFORE YOU APPEAR IN DEPARTMENT S29.

In a simple issue case, submit a general verdict form. If a special verdict form is requested, submit a single proposed special verdict form which includes any special questions of fact on which a party is requesting a finding. The special questions, of course, must be submitted in logical position in relation to other questions on the verdict form. This will require a conference between counsel which may take substantial time. PLEASE HAVE A PROPOSED DRAFT COMPLETED BEFORE YOU APPEAR IN DEPARTMENT S29.

CRITICAL

Applies to

Jury instructions

Hard copies of the jury instructions must be filed with the clerk.

Hard copies must be filed with the clerk.

CRITICAL

Applies to

Deposition index

Parties offering deposition testimony must file a numbered index stating the pages and lines offered, the objections and their basis, with two boxes/columns for the Court's ruling (Sustained/Overruled) and room for further comments.

File a numbered index of the portions of the deposition offered, stating the pages and lines offered, the objections of the party and summary of the basis for the objections. Please include two boxes or columns for the Court's ruling: ■ Sustained ■ Overruled and room to indicate further comments.

CRITICAL

Applies to

Jury instructions

Modifications of CACI instructions, other than insertions for pronouns, names, and CACI parentheticals, must be submitted as a Special Instruction or with highlighting showing the modification.

Other than insertions for pronouns, names, and CACI parentheticals, any other modifications of a CACI instruction must be submitted as a Special Instruction or highlighting showing the modification.

CRITICAL

Applies to

Verdict form

UNLAWFUL DETAINER JURY TRIALS: In a simple issue case, submit a general verdict form. If a special verdict form is requested, submit a single proposed special verdict form which includes any special questions of fact on which a party is requesting a finding. ... PLEASE HAVE A PROPOSED DRAFT COMPLETED BEFORE YOU APPEAR IN DEPARTMENT S29.

UNLAWFUL DETAINER JURY TRIALS: In a simple issue case, submit a general verdict form. If a special verdict form is requested, submit a single proposed special verdict form which includes any special questions of fact on which a party is requesting a finding. ... PLEASE HAVE A PROPOSED DRAFT COMPLETED BEFORE YOU APPEAR IN DEPARTMENT S29.

CRITICAL

Applies to

Jury instructions

Counsel must provide the Court with a complete hard copy set of jury instructions, as required by General Order 3.F and Los Angeles County Court Rules 3.170-3.172.

As required by General Order 3.F and by Los Angeles County Court Rules 3.170 - 3.172, it is the responsibility of counsel to provide the Court with a complete set (hard copy) of jury instructions.

CRITICAL

Applies to

Verdict form

Parties must submit a proposed joint verdict form before trial following CACI language and pattern; if they cannot agree, each party must file its own version and email Department 529 the draft in Word.

Verdict Form: Submit a proposed joint verdict form before trial commences sending a courtesy copy to the Court's email box. Follow the language and pattern of CACI instructions as much as possible. If the parties cannot agree on a joint form, each party must file their version and email Department 529 the draft in Word.

CRITICAL

Applies to

Ex parte application

Ex parte applications must include a declaration with an affirmative factual showing of irreparable harm, immediate danger, or statutory basis for ex parte relief.

There must be 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.” (See Cal. Rules of Court, rule 3.1202 (c).)

CRITICAL

Applies to

Ex parte application

The ex parte applicant must demonstrate to the court why the requested relief cannot be sought by means of a noticed motion.

You will need to demonstrate to the court the reason(s) why you cannot seek the requested relief by means of a noticed motion.

CRITICAL

Applies to

Ex parte application

An ex party application must include a declaration with an affirmative factual showing, based on competent personal-knowledge testimony, of irreparable harm, immediate danger, or another statutory basis for ex parte relief (CRC 3.1202(c)).

PLEASE CAREFULLY REVIEW WHETHER YOU HAVE A PROPER BASIS TO SEEK EX PARTE RELIEF. There must be 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.” (See Cal. Rules of Court, rule 3.1202 (c).)

CRITICAL

Applies to

Joint exhibit list

Parties must meet and confer and file a single joint exhibit list in chart format showing exhibit number, description, page count, and stipulations to admissibility and authentication.

All parties are ordered to have a meaningful meet and confer and file a single joint exhibit list. The single joint 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

Joint exhibit list

For the joint exhibit list, parties must confer on each exhibit separately and a blanket refusal to stipulate is insufficient; an in-person meet and confer is encouraged.

The court encourages an in-person meet and confer conference. The parties must confer on each exhibit separately. It is insufficient to simply compile the list and exchange a blanket refusal to stipulate.

CRITICAL

Applies to

Jury instructions

All parties are ordered to have a meaningful meet and confer, prepare and provide a complete set of full-text proposed jury instructions editing all proposed instructions – no remaining brackets or blanks. If the instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction. Compliance with California Rules of Court, Rule 2.1055 is mandatory. An additional copy must be provided to the

All parties are ordered to have a meaningful meet and confer, prepare and provide a complete set of full-text proposed jury instructions editing all proposed instructions – no remaining brackets or blanks. If the instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction. Compliance with California Rules of Court, Rule 2.1055 is mandatory. An additional copy must be provided to the

CRITICAL

Applies to

Request for court reporting services

A party who has received a fee waiver may request an official court reporter pursuant to California rule of Court 2.956(b)(3). The request must be made by using the local form (LASC LACIV 269).

A party who has received a fee waiver may request an official court reporter pursuant to California rule of Court 2.956(b)(3). The request must be made by using the local form (LASC LACIV 269).

CRITICAL

Applies to

Proposed verdict form

In jury trials, counsel and self-represented parties must file a joint proposed general or special verdict form, or separate proposed verdict forms if they cannot agree.

For jury trials, the parties' counsel and any self-represented parties shall 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).) If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

CRITICAL

Applies to

Joint witness list

On the joint witness list, all parties including self-represented parties must total the estimated testimony times for all witnesses and state the grand total in the last column.

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

Exhibits

Exhibits must be brought to court on the first day of trial.

Exhibits are to be brought on the first day of the trial.

CRITICAL

Applies to

Joint witness list

Witnesses not listed on the joint witness list may be excluded from testifying (except impeachment or rebuttal), and a party must first show good cause to call an unlisted witness.

Any witness who is not included on the joint witness list is subject to being excluded from testifying at trial other than for purposes of giving actual impeachment or rebuttal testimony. Any party who seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the court.

CRITICAL

Applies to

Request for court reporting services

A fee-waiver party may request an official court reporter (not provided in unlimited civil cases) using local form LASC LACIV 269.

Official court reporters are not provided in unlimited civil cases. A party who has received a fee waiver may request an official court reporter pursuant to California rule of Court 2.956(b)(3). The request must be made by using the local form (LASC LACIV 269).

CRITICAL

Applies to

Jury instructions

Parties must meet and confer and develop a single joint list of CACI and special jury instructions in the required chart format with disposition columns.

All parties are ordered to have a meaningful meet and confer and develop a single joint list of Judicial Council of California Civil Jury Instructions (“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 instruction, 4) four disposition columns showing a) given as requested, b) given as modified, c) withdrawn, d) refused.

CRITICAL

Applies to

Ex parte application

Must include

proposed order

Ex parte applicants must 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.

CRITICAL

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

Exhibits

A copy of all exhibits must be provided to the court on the first day of trial.

first day of the trial, a copy of all exhibits shall be provided to the court.

CRITICAL

Applies to

Case management statement

Case management statement must be filed using Judicial Council form CM-110, 15 calendar days before the 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.

CRITICAL

Applies to

Witness list

The joint witness list must identify each witness by name, estimate the length of direct, cross, and redirect examination, and include total hours for all witness testimony.

The joint witness list shall identify each witness by name and estimate the length of the direct, cross, and redirect examination of each witness, and include a total number of hours for all witness testimony.

CRITICAL

Applies to

Opposition

Opposition papers to motions in limine must include the number of the motion they respond to.

Opposition papers shall include the number of the motion to which it responds.

CRITICAL

Applies to

Request for informal discovery conference

IDC requests must be filed on Form LACIV-094 and must indicate any applicable statutory deadlines and the specific date by which a motion must be filed.

The parties are instructed to file their Request for an IDC using Form LACIV-094. When filing a request, please indicate if any statutory deadlines apply and the specific date by which a motion must be filed.

CRITICAL

Applies to

Witness list

Parties must provide a joint witness list and a joint statement of the case to be read to the jury.

A joint witness list and joint statement of the case to be read to the jury.

CRITICAL

Applies to

Ex parte application

Must include

proposed order

Ex parte applications require a proposed order and filing fee payment before appearing in court.

Ex parte applications will be considered Monday through Friday at 8:30 a.m. 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.

CRITICAL

Applies to

Jury instructions

Parties must provide a joint list of all requested jury instructions with a fully filled-out copy of each requested instruction, with disputed instructions attached separately and identified by the requesting party.

A joint list of all jury instructions requested and a copy of all requested instructions fully filled out. Those instructions not agreed upon should be attached separately and the party making the request should be identified.

CRITICAL

Applies to

Exhibit list

A joint exhibit list beginning with number 1 is required, with three copies provided containing columns for the clerk and the court to indicate whether each exhibit is marked.

A joint exhibit list beginning with the number 1 and provide three copies of the exhibit list with columns for the clerk and the court to use to indicate whether the exhibit is marked

CRITICAL

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 ex parte 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

Proposed jury instructions

Counsel must prepare and submit proposed jury instructions, meet and confer, and identify which instructions are agreed and which are disputed (with legal briefs encouraged for disputed instructions).

Counsel shall prepare and submit proposed jury instructions. (See C.C.P. § 607a.) Counsel shall meet and confer in an attempt to reach agreement on the proposed jury instructions. Counsel must identify those jury instructions that they agree shall be given and shall identify those proposed instructions as to which there is disagreement. As to disputed proposed instructions the parties are encouraged to submit legal briefs setting forth the legal basis for the request and objection.