Los Angeles Superior Court Document Filing Requirements

CRITICALCivil cases

Applies to

Exhibit list

Counsel are to cooperate so that exhibits to be offered by both sides are identified with the same exhibit number. Discovery instruments and discovery responses are not trial exhibits and are not to be included on the Exhibit List. If a party intends to introduce individual pages of a larger document, the individual pages should be given individual exhibit numbers.

Counsel are to cooperate so that exhibits to be offered by both sides are identified with the same exhibit number. Discovery instruments and discovery responses are not trial exhibits and are not to be included on the Exhibit List. If a party intends to introduce individual pages of a larger document, the individual pages should be given individual exhibit numbers.

CRITICALCivil cases

Applies to

Idc request

IDC requests must be joint and stipulated by all parties, submitted via e-filing, and must include three proposed IDC dates and state all reasons for the request.

Department 307 will consider conducting an Informal Discovery Conference upon submission of a joint request stipulated upon by all parties. The request shall be made by a joint brief not to exceed 5 pages to be submitted via e-filing and shall include three (3) proposed dates for the IDC to be held and shall state all reasons for the request.

CRITICALCivil cases

Applies to

Motion in limine

Each motion in limine must bear a number and title identifying what is being addressed.

If there are multiple motions they must each bear a number and title of what is being addressed.

CRITICALCivil cases

Applies to

Motion in limine

Motions in limine must not be used as a substitute for statutorily authorized dispositive motions.

Note that these motions must not be used as a substitute for statutorily authorized dispositive motions.

CRITICALCivil cases

Applies to

Jury instructions

Parties must submit joint proposed jury instructions plus each side's objected-to instructions with full text, completed and compliant with Local Rules 3.170-3.171 using CACI forms, with citations and requesting party removed before submission to the jury.

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. Before submitting, counsel must fill in the blanks, make every appropriate modifications, and comply with Local Rule 3.170-3.171. Use CACI for form instructions. Citation of authority and the party requesting will be required to be removed by counsel after the jury instruction conference and before submission to the jury.

CRITICALCivil cases

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 ex parte relief.

The Court will only grant ex parte relief 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." (See Cal. Rules of Ct. Rule 3.1202(c).)

CRITICALCivil cases

Applies to

Motion in limine

Motions in limine must comply with Local Rules 3.25(f)(2) and 3.57, including the meet and confer requirements.

Compliance with Local Rules 3.25(f)(2) and 3.57 is required, including the meet and confer requirements.

CRITICALCivil cases

Applies to

Joint witness list

The parties must submit a joint witness list of all intended witnesses, noting expert status and realistic per-witness time estimates (direct, cross, redirect), with a total at the end of the list.

The parties must submit a joint witness list of all witnesses each party actually intends to call. Next to each witness, note if the witness is an expert, indicate the total time estimated for that witness's testimony, including direct, cross and redirect. Time estimates must be realistic. At the end of the list, total the time estimated for testimony.

CRITICALCivil cases

Applies to

Joint summary of testimony

If no court reporter is provided, the parties must jointly submit a daily summary of the testimony and evidence admitted for use in preparing a settled statement on appeal.

Should parties not provide a court reporter, they will be required to provide a joint summary of testimony and evidence admitted each day, for the Court's use in preparing a settled statement for appellate purposes.

CRITICALCivil cases

Applies to

Joint witness list

Absent good cause, the total testimony hours on the joint witness list may not exceed the trial estimate given at the CMG, including one day allocated for jury selection and time for opening and closing.

Absent good cause, the total number of hours listed for testimony shall not exceed the trial estimate given at the CMG, including the allocation of one day of the estimate for jury selection and sufficient time for opening statements and closing arguments.

CRITICALCivil cases

Applies to

Joint exhibit list

Counsel must file a joint exhibit list with columns identifying each exhibit and each party's evidentiary objections, meet and confer before submitting it, and objections not stated in writing on the list are deemed waived absent good cause.

Counsel shall prepare and file a joint exhibit list organized with columns identifying each exhibit and specifying each party's evidentiary objections, if any, to the admission of each exhibit. Before submitting the joint exhibit list, counsel must meet and confer in an effort to resolve objections to the admissibility of each exhibit. Objections not stated in writing on the joint list shall be deemed waived except upon a showing of good cause.

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 list of proposed jury instructions

In jury trials, counsel and self-represented parties must jointly prepare and file a joint list of proposed jury instructions stating six specified items 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 objections, and (6) whether the jury instruction was given by the court (“Joint List of Proposed Jury Instructions”).

CRITICAL

Applies to

Trial preparation order

When a case is set for trial, the court issues a Trial Preparation Order and requires counsel and self-represented parties to jointly prepare and submit the documents and binders required by that order.

When the court sets a case for trial, the court usually issues a Trial Preparation Order in the form posted with this Courtroom Information for Department 513. The court requires the parties' counsel and any self-represented parties to work together to jointly prepare and submit the documents and binders required by that order.

CRITICAL

Applies to

Proposed jury instructions

In jury trials, the parties must jointly file a complete set of full-text proposed jury instructions with CACI instructions edited to insert party names and remove blanks and irrelevant material.

For jury trials, the parties’ counsel and any self-represented parties shall work together to prepare and file 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

Witnesses omitted from the joint witness list may be excluded from testifying (except for actual impeachment or rebuttal), and a party seeking to call 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 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

Proposed verdict form

In jury trials, the parties must jointly prepare and file a proposed general or special verdict form acceptable to all parties, or file 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.

CRITICAL

Applies to

Trial binder

The Trial Binder must contain a table of contents with Tabs A-I (trial briefs, joint witness list, joint exhibit list, jury statement, jury instructions, verdict forms, deposition designations, and operative pleadings); bench trials require only Tabs A, B, C, H, and I.

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 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

Joint witness list

The parties must jointly prepare and file a single witness list of all witnesses any party intends to call at trial, excluding impeachment and rebuttal witnesses.

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 Superior Court Rules (“Local Rules”), Rule 3.25, subd. (g)(5).)

CRITICAL

Applies to

Joint chart of page and line designations

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

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 chart of page and line designations

Each designating party's designations in the joint chart must include six required columns (witness, date/type of testimony, page:line designations, objections, counter-designation info, and 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

Exhibits not listed on the joint exhibit list may be excluded at trial (except for impeachment or rebuttal), require a good-cause showing to be admitted, and objections not stated on the list may be deemed waived.

Any exhibit that is not included on the joint exhibit list is subject to being excluded at trial other than for purposes of actual impeachment or rebuttal. Any party who seeks to introduce an exhibit that is not identified on the joint exhibit list must first make a showing of good cause to the court. Any objection to an exhibit that is not stated on the joint exhibit list is subject to being deemed waived by the court.

CRITICAL

Applies to

Joint exhibit list

Counsel and self-represented parties must jointly prepare and file a joint exhibit list containing eight specified columns of information for each exhibit offered at trial.

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, subd. (g)(6).)

CRITICAL

Applies to

Ex parte application

Ex parte applications must comply with the requirements of California Rules of Court, rules 3.1200-3.1207.

Ex parte applications must comply with the requirements of California Rules of Court, rules 3.1200-3.1207.

CRITICAL

Applies to

Exhibits

The exhibit list must be included in the exhibit binders.

The exhibit list must be included in the binders.

CRITICAL

Applies to

Exhibit objection

Objections to listed exhibits (foundation or admissibility) must be filed in writing with a brief statement of grounds, and objections not so stated are deemed waived absent good cause.

Any party objecting to any listed exhibit, either as to foundation or admissibility, must file the objection in writing together with a brief statement of the ground for objection. Any objections not so stated as per the foregoing shall be deemed waived except upon a showing of good cause.

CRITICAL

Applies to

Trial brief

Trial briefs are mandatory in all cases and must include the eight specified content items covering claims, stipulated facts, admissions, contested issues, authorities, evidentiary issues, and relief/damages breakdown.

Trial briefs are mandatory in all cases and must include: 1. A brief description of the claims and defenses presented and the issues to be decided. 2. Statement of ultimate facts or issues to which you will stipulate. 3. Those facts established by admissions in pleadings; admissions by discovery and/or stipulation of counsel. 4. All contested issues of fact. 5. All contested issues of law, together with points and authorities supporting the position of counsel. 6. A list of major evidentiary issues anticipated and any relevant points and authorities in support of a position of counsel. 7. A detailed statement of the relief claimed including a breakdown of the elements of damages claimed. 8. Any other information that will assist the court.

CRITICAL

Applies to

Motion in limine

Motions in limine to preclude inadmissible or prejudicial matter before the jury must be accompanied by a declaration complying with LACCR Rule 3.57(a).

Each motion in limine for the purpose of precluding the mention or display of inadmissible and prejudicial matter in the presence of the jury shall be accompanied by a declaration in compliance with the requirements of Rule 3.57(a) of the LACCR.

CRITICAL

Applies to

Jury instructions

Jury instructions must be submitted in the required format or they will be returned, beginning with a jointly submitted packet of all requested, fully edited, unopposed CACI instructions.

Jury instructions shall be submitted as follows: (Note: Jury instructions not submitted in this format will be returned.) A jointly submitted packet of all requested and properly and fully edited CACI jury instructions to which there is no objection. (LACCR, Rule 8.25)

CRITICAL

Applies to

Motion in limine binder

Motion in limine binders must be submitted on the date of the Final Status Conference.

The Court requires motion in limine binders submitted on the date of the Final Status Conference.

CRITICAL

Applies to

Trial documents

All trial documents must be filed pursuant to the Final Status Conference Order, except for exhibits.

All trial documents must be filed pursuant to the Final Status Conference Order (except for exhibits).

CRITICAL

Applies to

Ex parte application

Must include

proposed order

Every ex parte application must include a proposed order submitted separately from the application.

All ex parte applications require a proposed order, which shall be submitted separate from the ex parte application.

CRITICAL

Applies to

Exhibit list

Counsel must jointly prepare and exchange a complete Exhibit List (no exhibits attached; depositions, declarations, motions, interrogatories, responses, and pleadings excluded) with all items exchanged or reviewed before the Final Status Conference.

Counsel must jointly prepare and exchange a complete Exhibit List including each document and item of physical evidence. Do not attach the exhibits to the list. Do not include depositions, declarations, motions, interrogatories, responses, or pleadings as exhibits. All items on the Exhibit List must be exchanged and/or reviewed by counsel prior to the Final Status Conference.

CRITICAL

Applies to

Verdict form

The parties must jointly prepare a general verdict form (and a special verdict form if requested) in draft or final form.

A general verdict form and, if requested, a special verdict form shall be jointly prepared in draft or final form.

CRITICAL

Applies to

Jury instructions

Requested jury instructions must be in proper form: party identification at the top, whether given as requested or modified, whether withdrawn, and a signature line for the court.

All requested instructions must be submitted in the proper form, which includes: a) At the top of each requested jury instruction, identification of the party/parties requesting instruction; b) Whether the instruction to be given as requested or as modified; c) Whether the instruction is withdrawn; and d) A signature line for the court.

CRITICAL

Applies to

Stipulation and order

Once an agreement is reached, the parties must file a Stipulation and Order with the court.

Once an agreement is reached, the parties are directed to file a Stipulation and Order with the court.

CRITICAL

Applies to

Stipulation and order

A continuance stipulation and order must state the complaint filing date, the proposed continuance date, and good-cause grounds, and must be submitted with the required fees.

Said stipulation and order shall state the date the complaint was filed, the proposed continuance date, grounds showing good cause for the continuance, and be submitted with payment of $20.00 stipulation and order fee and first appearance fee of all parties to the stipulation.

CRITICAL

Applies to

Proposed verdict form

If after exhaustive meet and confer efforts the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form, and bring an electronic copy of their proposed verdict form in Word to the FSC, ready to be edited in the courtroom.

If after exhaustive meet and confer efforts the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form, and bring an electronic copy of their proposed verdict form in Word to the FSC, ready to be edited in the courtroom.

CRITICAL

Applies to

Joint exhibit list

Exhibit objections not articulated on the joint exhibit list may result in the Court deeming the exhibit admitted.

If an objection to an exhibit is not articulated on the exhibit list, the Court may deem the exhibit admitted.

CRITICAL

Applies to

Court reporter stipulation or appointment order

Parties must file either a Stipulation and Order to Use Certified Shorthand Reporter or an Order Appointing a Court Approved Reporter as Official Reporter Pro Tempore before the hearing is called.

The parties are to file either the Stipulation and Order to Use Certified Shorthand Reporter or Order Appointing Court Approved Reporter as Official Reporter Pro Tempore prior to the hearing being called.

CRITICAL

Applies to

Exhibit binder

All three sets of exhibit binders must be lodged on the first day of trial.

The parties shall lodge the entire three sets of exhibit binders on the first day of trial.

CRITICAL

Applies to

Joint exhibit list

Parties' counsel and self-represented parties must jointly prepare and file a joint exhibit list with eight required columns covering exhibit number, description, offering party, stipulations, 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(g)(6).

CRITICAL

Applies to

Final jury instructions

After the jury-instruction conference, one party must submit the final set of Court-approved jury instructions incorporating the Court's modifications.

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

Electronic media exhibit

Photos within marked electronic media that bear separate exhibit numbers must be printed out with an exhibit tag affixed to each item.

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

Opposition and reply papers

Opposition and reply papers must identify the corresponding motion in limine number in their caption.

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

CRITICAL

Applies to

Motion in limine

Must include

caption

Each motion in limine 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

Electronic media exhibit

marked as an exhibit, it must be described accurately on the Exhibit List (e.g., "Plaintiff's Exhibit 2 (flash drive or CD/DVD containing 3 photographs)").

marked as an exhibit, it must be described accurately on the Exhibit List (e.g., "Plaintiff's Exhibit 2 (flash drive or CD/DVD containing 3 photographs)").

CRITICAL

Applies to

Joint witness list

Witnesses not included on the joint witness list may be excluded from testifying at trial (except for actual impeachment or rebuttal testimony), and calling an unlisted witness requires a showing of good cause to the Court.

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 that 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

Joint witness list

Parties' counsel and self-represented parties must jointly prepare and file a joint witness list of all trial witnesses, excluding impeachment and rebuttal witnesses.

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. Local Rule 3.25(g)(5).