Los Angeles Superior Court Document Filing Requirements

CRITICALCivil cases

Applies to

Motion

All in limine motions must be written and accompanied by a declaration complying with Local Rule 3.57.

5. In Limine Motions. All Motions in limine must be in writing and be accompanied by a declaration in compliance with Local Rule 3.57.

CRITICALCivil cases

Applies to

Standing order paragraph 15 documents

Documents required by Paragraph 15 of the Fifth Amended Standing Order must be prepared before the first trial date.

Counsel shall fully comply with the Standing Order (Fifth Amended Standing Order (effective as of June 1, 2021)) as it relates to trials, paragraphs 14, 15, 16 and 17. All documents required by Paragraph 15 of the Standing Order shall be prepared in advance of the first trial date.

CRITICALCivil cases

Applies to

Motion in limine

All in limine motions must be in writing and accompanied by a declaration complying with Local Rule 3.57.

All Motions in limine must be in writing and be accompanied by a declaration in compliance with Local Rule 3.57.

CRITICALCivil cases

Applies to

Jury instructions

Counsel must prepare, submit, and meet and confer on proposed jury instructions, identifying agreed and disputed instructions; briefs for disputed instructions are encouraged.

3. Jury Instructions and Verdict Form: 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.

CRITICALCivil cases

Applies to

Joint exhibit list

Counsel and self-represented parties must jointly prepare and file a joint exhibit list stating eight specified data points for each trial 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 with a date or dates of the documents and the number of pages 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.

CRITICALCivil cases

Applies to

Case management statement addendum non opt in cases

In non-opt-in cases, defendant must plainly state why the vehicle does not qualify for a buyback or, if it does qualify, identify any remaining buyback issues.

Defendant shall plainly state why the vehicle at issue does not qualify for a “buy back,” or state that the vehicle does qualify for a buyback, and if so, identify any remaining issues regarding any “buy back.”

CRITICALCivil cases

Applies to

Joint case management conference statement addendum

The Case Management Conference Statement Addendum must include a signed attestation (typed/printed name and signature of party or attorney) that the signer is fully familiar with the case, prepared to discuss discovery and ADR, and possesses authority, including written authority where required, to enter into stipulations at the initial CMC.

I am completely familiar with this case and will be fully prepared to discuss the status discovery and alternative dispute resolution, as well as other issues raised by this addendum, and will possess the authority to enter into stipulations on these issues at the time of the initial case management conference, including the written authority of the party where required.

CRITICALCivil cases

Applies to

Exhibit binder

Counsel must bring an exhibit binder to the Final Status Conference for the court's review.

Counsel must bring an exhibit binder to the Final Status Conference for the court’s review.

CRITICALCivil cases

Applies to

Document production

Within 60 days of service of the CMC order, both plaintiff and defendant must produce to the opposing side copies of specified case documents in their possession, custody, or control (purchase/lease contracts, repair and work orders, rental/loaner agreements, communications records, warrant claims, warranty and claim-handling policies).

Production of Documents: Within 60 days of service of this Order both plaintiff and defendant shall provide copies of the following documents, which are in their respective possession, custody and/or control, to the opposing side(s):

CRITICALCivil cases

Applies to

Proposed jury instructions

In jury trials, the parties must jointly prepare a complete set of full text proposed jury instructions with CACI instructions edited 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.

CRITICALCivil cases

Applies to

Joint case management conference statement addendum

Signers of the Joint Case Management Conference Statement Addendum must certify complete familiarity with the case, full preparation to discuss discovery and ADR, and possession of authority (including written party authority where required) to enter into stipulations at the initial case management conference.

I am completely familiar with this case and will be fully prepared to discuss the status discovery and alternative dispute resolution, as well as other issues raised by this addendum, and will possess the authority to enter into stipulations on these issues at the time of the initial case management conference, including the written authority of the party where required.

CRITICALCivil cases

Applies to

Substantially similar customer complaint list

Defendant's list of substantially similar customer complaints must include the VIN, repair visit date, reporting location, and complaint text, and must exclude customers' personal identifying information.

The list provided by defendant may be in the chart or spreadsheet format, and shall include the VIN, date of repair visit, dealership or other reporting location, and text of the other customers’ reported complaint, but shall not include the other customers’ names, addresses, phone numbers, e-mail addresses, or other personal identifying information.

CRITICALCivil cases

Applies to

Joint chart deposition 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 containing six specified columns.

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”). 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.

CRITICALCivil cases

Applies to

Motion in limine

Motions in limine must comply with the statutory notice provisions of Code of Civil Procedure section 1005 and be supported by compliant declarations.

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

CRITICALCivil cases

Applies to

Joint statement of the case

In jury trials, the 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).)

CRITICALCivil cases

Applies to

Joint case management conference statement addendum

In the Joint Case Management Conference Statement Addendum, defendant must state either why the vehicle does not qualify for a buyback or that it does qualify and state the remaining issues (e.g., buyback price, credits, attorney's fees, costs).

Defendant shall state either a. Why the vehicle does not qualify for a “buyback,” or b. Simply state that it does qualify and state the remaining issues, e.g., buyback price, credits, attorney’s fees, costs, etc.

CRITICALCivil cases

Applies to

Trial brief

Each party's trial brief must succinctly identify disputed claims and defenses, major legal issues with supporting authorities, relief and calculation of damages, other trial-assisting information, and an itemized statement of damages.

Each party shall file a trial brief succinctly identifying: (1) 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 damages sought; (4) any other information that may assist the court at trial; and (5) an itemized statement of damages.

CRITICALCivil cases

Applies to

Joint cmc statement addendum

In the Joint Case Management Conference Statement Addendum, plaintiff must state why the vehicle qualifies for a buyback and what was (or still is) wrong with the vehicle.

28. Plaintiff shall state why the vehicle qualifies for a "buyback." State what was (or still is) wrong with the vehicle,

CRITICALCivil cases

Applies to

Joint case management conference statement addendum

In the Joint Case Management Conference Statement Addendum, plaintiff must plainly state the specific facts supporting buyback qualification and may not rely on conclusory terms such as 'engine' problems.

Plaintiff shall plainly state the facts as to why the vehicle qualifies for a “buyback.” Don’t use conclusionary terms as “engine” problems. BE SPECIFIC, as noted above.

CRITICALCivil cases

Applies to

Proposed verdict form

In jury trials, parties must file a joint proposed general or special verdict form acceptable to all parties, or separate proposed verdict forms if they cannot agree.

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

CRITICALCivil cases

Applies to

Cmc addendum

The Addendum must be filed as a separate pleading and must not be attached to the Case Management Statement.

Do not attach the Addendum to the Case Management Statement. File the Addendum as a separate pleading.

CRITICALCivil cases

Applies to

Exhibit binders

One set of the Exhibit Binders must be brought to the Final Status Conference for the court to review.

The parties’ counsel and any self-represented parties shall bring one set of the Exhibit Binders to the Final Status Conference for the court to review.

CRITICALCivil cases

Applies to

Joint witness list

The parties must jointly prepare and file a witness list (excluding impeachment and rebuttal witnesses) in a specified column format with examination time estimates and a grand total, and any witness not listed may be excluded from testifying at trial except for actual impeachment or rebuttal.

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 (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. 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.

CRITICALCivil cases

Applies to

Joint list of proposed jury instructions

In jury trials, the parties must jointly prepare and file a Joint List of Proposed Jury Instructions stating six specified data points for each instruction.

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”).

CRITICALCivil cases

Applies to

Joint status report

The joint ADR status report must describe all settlement efforts but must not reveal the numbers or amounts of settlement offers exchanged.

Attorneys must file a joint status report ten (10) court days before the OSC Re ADR Compliance hearing detailing all efforts the attorneys undertook to settle the case, but without revealing any settlement offers exchanged between the parties.

CRITICAL

Applies to

Ex parte declaration

An ex parte declaration must state that proper and detailed notice of the specific relief sought was given to all interested parties; general notice statements are insufficient.

The declaration must state that you gave proper and detailed notice to all interested parties of “the relief sought.” For example, if you are requesting a continuance of the trial date, and if you are also requesting that all related cut-off dates (in whole or in part) be extended to the new date, you must give specific notice of such a request, and the declaration must contain that specific notice. Simply stating that you gave “notice of the instant ex parte application,” or other types of general statements are insufficient.

CRITICAL

Applies to

Joint case management statement

The joint case management statement must address six issues: status of the mandatory document exchange, mandatory mediation, any optional deposition, each party's position on CCP § 871.24, plaintiff's specific buyback facts, and defendant's position on why the vehicle does or does not qualify for a buyback.

That JCMCS shall address the following issues: (1) Status of mandatory joint document exchange, per CCP § 871.26 (b). State whether or when the exchange occurred and whether it was adequately completed or not. (2) Status of mandatory mediation, per CCP § 871.26 (d). State the date of the mediation and name of the mediator. (3) State whether any party exercised their optional right to a deposition, per CCP § 871.26 (c), and if so, state the name (and title) of the deponent, when it occurred, and whether it was completed or not. (4) State each party’s position as to the applicability of CCP § 871.24, re: prelitigation demands/double penalties. If you contend that said section applies in this case, state the reasons why, and whether or not there was compliance with same. (5) Plaintiff shall plainly state the facts as to why the automobile qualifies for a “buyback,” to wit, what was (or still is) wrong with the vehicle at issue. Do not use conclusionary terms such as “engine, mechanical or electrical” problems. BE SPECIFIC. E.g., engine light turns on, power screen malfunctions, etc. (6) Defendant shall plainly state why the vehicle at issue does not qualify for a “buyback,” in view of Plaintiff’ statements in No. 5. Alternatively, Defendant can simply state that the vehicle does, in fact, qualify for a buy back, but there are remaining issues as to the buyback price, credits, attorney’s fees, costs, etc. Identify and briefly discuss those issues.

CRITICAL

Applies to

Ex parte application

Ex parte applications must make an affirmative showing of irreparable harm, immediate danger, or another statutory basis under Cal. Rules of Court rule 3.1202(c), and must demonstrate why the relief cannot be sought by noticed motion.

To wit, there must be an affirmative showing of "irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte." See, Cal. Rules of Court, rule 3.1202 (c). You will need to demonstrate to the court as to the reason(s) why you cannot seek the requested relief by means of a noticed motion.

CRITICAL

Applies to

Supplemental separate statement

If no Supplemental Separate Statement is filed for a discovery motion, the Court will deem the MTCFR moot/resolved.

If there is no SSS filed as to any particular discovery motion, this Court will consider the MTCFR to be moot/resolved.

CRITICAL

Applies to

Motion in limine

Motions in limine must designate the specific evidence sought to be precluded; boilerplate or form motions in limine are disfavored.

Boilerplate or form motions in limine are disfavored. Motions in limine shall designate the specific evidence sought to be precluded.

CRITICAL

Applies to

Joint case management statement

Before the continued CMC hearing, both parties must meet and confer and file a joint case management statement signed by both parties' attorneys.

Prior to the next hearing, both parties are to meet and confer, and to file a JOINT Case Management Statement (“JCMCS”), signed by both parties’ attorneys.

CRITICAL

Applies to

Exhibit list

The parties must submit a joint exhibit list with agreed blocks of exhibit numbers, including exhibit number, brief description, and three columns headed Stipulation: Authenticity/Admission, Date Identified, and Date Admitted.

A joint exhibit list. Counsel are to agree on a block of numbers to be allocated to each party for exhibits. (See SCLAC Rule 3.53). The exhibit list shall include the exhibit number and a brief description of the exhibit. There should 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."

CRITICAL

Applies to

Trial preparation order items

Failure to timely submit any item required by the trial preparation order without good cause can result in sanctions including monetary sanctions, exclusion of evidence, issue preclusion, denial of claim or defense, dismissal, and default.

FAILURE TO SUBMIT any item required by this order in a timely manner without good cause will subject the party to the imposition of appropriate SANCTIONS, including monetary sanctions, exclusion of evidence, issue preclusion, denial of claim or defense, dismissal, and default.

CRITICAL

Applies to

Supplemental separate statement

The Supplemental Separate Statement may not contain any further written discussion of why a further response should or should not be compelled; argument may be made orally at the hearing if the Court needs it.

THERE SHALL NOT BE ANY FURTHER WRITTEN DISCUSSION AS TO WHY OR WHY NOT A FURTHER RESPONSE SHOULD BE COMPELLED. Counsel will be able to orally argue at the hearing, if needed by the Court.

CRITICAL

Applies to

Exhibits

Counsel shall prepare a joint set of exhibits.

Counsel shall prepare a joint set of exhibits.

CRITICAL

Applies to

Jury instructions

Parties must meet and confer on a joint set of jury instructions, submit disputed instructions as separate sets, identify the requesting party on each instruction, and complete all CACI blanks while striking irrelevant portions.

A joint set of jury instructions. Counsel shall meet and confer to prepare this joint set. Any proposed instruction to which counsel cannot agree shall be submitted as a separate set or sets. Each instruction must indicate the party/parties requesting the instruction. All blanks on CACI instructions must be completed and any irrelevant portions stricken. (SCLAC Rule 3.170).

CRITICAL

Applies to

Jury statement

The parties must submit a joint written statement of the case suitable to be read to the jury.

A joint written statement of the case suitable to be read to the jury.

CRITICAL

Applies to

Witness list

The parties must submit a joint witness list with names listed alphabetically, time estimates for direct/cross/redirect, total time, scheduling problems, and special requirements.

A joint witness list, including each witness's name, include the time estimate for direct, cross, and redirect, total time for (all witnesses expected to testify), any potential scheduling problem, and any special requirements. The names of the witnesses are to be listed alphabetically.

CRITICAL

Applies to

Final status conference documents

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

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

CRITICAL

Applies to

Exhibits

They shall also prepare a set of exhibits. These may be joint or separate for each party, as may be agreed between the parties.

They shall also prepare a set of exhibits. These may be joint or separate for each party, as may be agreed between the parties.

CRITICAL

Applies to

Case management statement CM-110

Parties must still file a CMC statement on the mandatory court form CM-110, either separately or jointly, despite the JCMCS requirement.

This JCMC does not relieve the parties from filing a proper CMC statement on the mandatory court form (CM-110). They may file that separately, or jointly, as allowed by the form.

CRITICAL

Applies to

Declaration

All counsel must read and consider three specified published discovery articles by Judge Hammock (available on the SCLAC website for Department 509) and each counsel must electronically file and serve a written declaration within 14 days attesting compliance with this order.

All counsel of record in this case are hereby ordered to read and consider the following three published articles concerning discovery disputes written by Judge Hammock: (1) “Common mistakes and pitfalls in responses to Requests for Production of Documents”; (2) “Discover what you may not know about the Discovery Act”; and (3) “Admit or Deny.” A copy of these articles are available on the SCLAC web site (www.lacourt.ca.gov) in “Courtroom Information” for Department 509 (Stanley Mosk). Each counsel is also ordered to electronically file and serve a written declaration in this case, within 14 days, which attests to the compliance of this specific order;

CRITICAL

Applies to

Verdict form

A joint general verdict form, and/or any special verdict forms that will be requested.

A joint general verdict form, and/or any special verdict forms that will be requested.

CRITICAL

Applies to

Supplemental separate statement

A moving party still seeking to compel further responses must file and serve a Supplemental Separate Statement for each motion containing the discovery requests verbatim and every response verbatim, indicating 'no further response was given' where no supplemental response was served.

If the moving/propounding party still wants this Court to compel a further response to any particular discovery item, that party shall file and serve a “Supplemental Separate Statement” (“SSS”) for each motion, which contains the following: (1) The specific discovery request(s) verbatim; (2) Each and every response, verbatim, given to that request by the responding party. If there was no supplemental response given subsequently to this Order, the moving party shall indicate that “no further response was given” to that particular discovery request.

CRITICALCivil cases

Applies to

Motion

All motion documents must include the CRS confirmation number in the filing caption.

Upon reservation, CRS will issue a confirmation number and that number is to be indicated in the filing caption for ALL motion documents, including oppositions and replies.

CRITICALCivil cases

Applies to

Witness list

Witness lists must identify witnesses to be called at trial 'above the line' and witnesses not to be called 'below the line.'

For the list of witnesses, those witnesses that a party intends to call at trial should be identified “above the line” and those witnesses the party does not intend to call at trial should be listed “below the line.”

CRITICALCivil cases

Applies to

Settlement agreement

Settlement agreements should include a provision pursuant to CCP §664.6.

Settlement agreements should include a provision of CCP §664.6.

CRITICALCivil cases

Applies to

Motion

Motion hearing dates must be reserved via the online Court Reservation System (CRS), and the CRS confirmation number must be indicated in the filing caption of all motion documents, including oppositions and replies.

All hearing dates are to be scheduled via the online Court Reservation System (CRS). Upon reservation, CRS will issue a confirmation number and that number is to be indicated in the filing caption for ALL motion documents, including oppositions and replies.

CRITICALCivil cases

Applies to

Ex parte application

Ex-parte applications must include a showing of urgency.

Ex-Parte applications require a showing of urgency.

CRITICALCivil cases

Applies to

Cmc statement

CMC statements (Judicial Council form #CM-110) should be filed at least 15 calendar days prior to the CMC [CRC Rules 3.720-3.730] with a courtesy copy provided to the department upon filing.

CMC statements (Judicial Council form #CM-110) should be filed at least 15 calendar days prior to the CMC [CRC Rules 3.720-3.730] with a courtesy copy provided to the department upon filing.