Los Angeles Superior Court Document Filing Requirements

CRITICAL

Applies to

Objection to discovery material

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

Ex parte application

Must include

proposed order

A proposed order is required with ex parte applications.

Proposed orders are required

CRITICAL

Applies to

Special verdict form

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

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

Jury instructions

Contested or special instructions requested by an opposing party must be inserted into the joint jury instruction packet for the Court to consider during trial.

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

Jury instructions

Each requested CACI instruction must identify the requesting party at the top, state whether it is given as requested or modified, state whether it is withdrawn, and include a signature line for the Court.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the instruction; B) Whether the instruction is to be given as requested or modified; C) Whether the instruction is withdrawn; and D) A signature line for the Court.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

Behind Tab F of the trial binder, agreed-upon jury instructions must come first, followed by contested (including special) instructions from each party.

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

Ex parte motion

Must include

proposed order

Proposed orders are required for Unlawful Detainer ex parte motions.

Proposed orders are required

CRITICAL

Applies to

Joint witness list

The joint witness list must include each witness's name, estimated direct and cross-examination times, total combined testimony time, and any potential scheduling problems.

The jointly prepared Witness List must include the name of each witness, an estimate of time for direct and cross-examination, and the total amount of time of all witness testimony combined for the entire trial. Potential scheduling problems must be noted.

CRITICAL

Applies to

Small claims trial

Must include

proof of service

Small Claims plaintiffs must file proof of proper service prior to the trial date.

Trial Preparation: Prior to the trial date, Plaintiff must file proof of proper service.

CRITICAL

Applies to

Joint exhibit list

Parties must jointly prepare and exchange an exhibit list showing stipulations, with pre-agreed numbering ranges, separately identified exhibits and subparts, and consecutively paginated multi-page exhibits.

All parties must jointly prepare and exchange a completed Exhibit List, indicating each document and item of physical evidence, and whether there is a stipulation to authenticity and/or admissibility. Each exhibit shall be numbered or lettered. All parties shall agree in advance that their respective party will have a range of exhibit numbers or letters (e.g. Plaintiff No. 1: 1-99; PlaintiffNo. 2: 100-199; Defendant: A-Z). Each exhibit must be separately identified. Subparts to an exhibit (e.g., IA, lB, etc.) must also be identified and listed separately. Each page of a multi-page exhibit must be consecutively paginated.

CRITICAL

Applies to

Joint statement of case

Parties must submit a printed copy of a jointly prepared, short, non-argumentative statement of the case to be read to the jury.

The parties shall submit a printed copy of the jointly prepared, short, non-argumentative written statement of the case to be read to the jury.

CRITICAL

Applies to

Trial discovery material list

Each party must prepare a list of discovery material to be used at trial specifically identifying the date, document, page, and line.

Each party must prepare a list of discovery material intended to be used at trial, including but not limited to interrogatories and requests for admissions and any responses thereto as well as deposition(s), all of which shall specifically identify the date, document, page and line.

CRITICAL

Applies to

Depositions and discovery responses

Originals of depositions or discovery responses to be used at trial must be lodged with the Court at the time of trial.

If depositions or other discovery responses are intended to be used at trial, originals shall be lodged with the Court at the time of trial.

CRITICAL

Applies to

Jury instructions

Parties must jointly submit a 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

Joint exhibit list

All items listed in the exhibit list must be exchanged and/or reviewed by counsel or the parties before the Final Status Conference.

All items so referred to in the Exhibit List must be exchanged and/or reviewed by each counsel or the parties prior to the FSC.

CRITICAL

Applies to

Summary of daily proceedings

When no court reporter is retained at trial, the parties must jointly prepare a summary of the day's proceedings and lodge it in the courtroom the next morning before proceedings resume.

If no court reporter is used, the parties must jointly prepare a summary of the day's proceedings and lodge it in the courtroom the next morning before proceedings resume.

CRITICAL

Applies to

Idc request

IDC requests must be filed online using form LACIV094 and list all disputed discovery issues.

If the dispute remains unresolved, counsel may request an Informal Discovery Conference (IDC) by filing an IDC request online [LACIV094] list all discovery issues that are in dispute.

CRITICAL

Applies to

Proposed verdict forms

Parties must meet and confer in advance and then file proposed general or special verdict forms, using CACI model forms where applicable; competing proposed verdict forms are discouraged.

The parties are to meet and confer in advance and then file proposed general or special verdict forms. Use CACI model verdict forms where applicable. The Court discourages submission of competing proposed verdict forms.

CRITICAL

Applies to

Joint witness list

Parties must submit a joint witness list with per-witness and total testimony time estimates and discuss at the FSC which witnesses will appear in person or by video.

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, and 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. The parties shall discuss with the Court at the final status conference which witnesses will appear in person, and which will appear by video.

CRITICAL

Applies to

Memorandum

IDC moving memorandum first paragraph must include neutral dispute statement and 1-3 sentences per party’s position.

The first paragraph shall be formatted as follows: (1) a neutral statement of the dispute; and (2) one to three sentences describing (not arguing) each party’s position.

CRITICAL

Applies to

Ex parte application

Ex parte applications must make an affirmative showing of irreparable harm, immediate danger, or another statutory basis for relief, and must demonstrate why the relief cannot be sought by other means such as a noticed motion or continuance of the trial.

PLEASE CAREFULLY REVIEW WHETHER YOU HAVE A PROPER BASIS TO SEEK EX PARTE RELIEF. 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 the reason(s) why you cannot seek the requested relief by other means, such as a noticed motion or continuance of the trial.

CRITICAL

Applies to

Motion in limine

Motions in limine must set forth the opposing party's position and be submitted with timely statutory notice so they can be heard at the FSC.

setting forth the opposing party’s position regarding the motions, and must be submitted with timely statutory notice so the motions in limine can be heard at the FSC. Motions in limine may be heard at the FSC unless the Court orders otherwise.

CRITICAL

Applies to

Motion in limine

All motions in limine must be accompanied by a sworn declaration (per LASC Rule 3.57); the source text is truncated mid-sentence.

In compliance with LASC Rule 3.57, all motions in limine must be accompanied by a sworn declaration attesting

CRITICAL

Applies to

Ccp 2034 260 expert declaration

No later than the FSC, counsel must present to the Court and opposing counsel a CCP § 2034.260 declaration stating the substance of the proffered expert opinion for each trial expert.

As to experts that 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

Trial notebook

Parties must provide a paper trial notebook to the Court in connection with the FSC/trial.

The parties must provide both a paper "trial notebook" for the Court and submit FSC/trial documents electronically.

CRITICAL

Applies to

Proposed jury instructions

Proposed jury instructions must include a joint set plus each side's disputed sets, provide full text, be completed and modified before submission, comply with LASC 3.170 to 3.171, and use CACI 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 appropriate modifications, and comply with LASC 3.170 to 3.171. Use CACI for form instructions.

CRITICAL

Applies to

Ex parte application

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

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).)

CRITICALCivil cases

Applies to

Proposed order

Must include

proposed order

Parties seeking a private court reporter must submit a proposed order designating the reporter as official.

Any party otherwise seeking the presence of a court reporter must secure the service of a private court reporter with a proposed order designating the court reporter as the official reporter.

CRITICALCivil cases

Applies to

Jury instructions list

List of jury instructions must be filed by the Final Status Conference.

5. Filed-List of jury instructions

CRITICALCivil cases

Applies to

Joint statement of the case

Joint Statement of the Case must be filed by the Final Status Conference.

3. Filed-Joint Statement of the Case.

CRITICALCivil cases

Applies to

Joint witness list

A joint witness list must be filed by the time of the Final Status Conference.

Filed-Joint Witness List

CRITICALCivil cases

Applies to

Joint exhibit list

A joint exhibit list, including columns for DATE ID'd and DATE ADMITTED, must be filed by the time of the Final Status Conference.

Filed-Joint Exhibit List, include columns for DATE ID'd and DATE ADMITTED.

CRITICALCivil cases

Applies to

Request for court reporter

Must include

proposed order

Parties seeking a court reporter must retain a private court reporter and submit a proposed order designating that reporter as the official reporter.

Any party otherwise seeking the presence of a court reporter must secure the service of a private court reporter with a proposed order designating the court reporter as the official reporter.

CRITICALCivil cases

Applies to

Exhibit books

Five sets of exhibit books must be delivered to Department T by the FSC — one set each for the clerk, the judge, and the witness box, and one for each side.

Delivered-5 Sets of Exhibit Books, tabbed and indexed, and delivered to Dept. T. (One set for the clerk, one set for the judge, one set for the witness box and each side to have a copy.)

CRITICALCivil cases

Applies to

Joint exhibit list

Joint Exhibit List with DATE ID'd and DATE ADMITTED columns must be filed by FSC.

2. Filed-Joint Exhibit List, include columns for DATE ID'd and DATE ADMITTED.

CRITICALCivil cases

Applies to

Proposed verdict form

Proposed Verdict Form must be filed by the Final Status Conference.

4. Filed-Proposed Verdict Form

CRITICALCivil cases

Applies to

Motion

Must include

proposed order

Proposed orders are required for all motions.

Please submit proposed orders for all motions and ex parte applications.

CRITICALCivil cases

Applies to

Proposed verdict form

A proposed verdict form must be filed by the time of the Final Status Conference.

Filed-Proposed Verdict Form

CRITICALCivil cases

Applies to

List of jury instructions

A list of jury instructions must be filed by the time of the Final Status Conference.

Filed-List of jury instructions

CRITICALCivil cases

Applies to

Jury instructions

Fully edited jury instructions must be printed out and delivered to Department T by the time of the Final Status Conference.

Delivered-Jury instructions, fully edited, printed out and delivered to Dept. T.

CRITICALCivil cases

Applies to

Proposed juror questionnaire

Proposed juror questionnaires must not include questions concerning the location of prospective jurors' residences.

Questionnaires will not include questions concerning the location of the prospective jurors' residences in accordance with changes to the Standards for Judicial Administration.

CRITICALCivil cases

Applies to

Motion

Must include

proposed order

A proposed order must be submitted with every motion.

Please submit proposed orders for all motions and ex parte applications.

CRITICALCivil cases

Applies to

Lodged depositions

Depositions must be lodged before trial accompanied by a Notice of Lodging Depositions.

LODGING DEPOSITIONS: Depositions shall be lodged before trial with a Notice of Lodging Depositions.

CRITICALCivil cases

Applies to

Joint witness list

Joint Witness List must be filed by the Final Status Conference.

1. Filed-Joint Witness List

CRITICALCivil cases

Applies to

Proposed juror questionnaire

Proposed Juror Questionnaires (if requested) must not include questions about jurors' residences.

8. Filed-Proposed Juror Questionnaire, if requested. Questionnaires will not include questions concerning the location of the prospective jurors' residences in accordance with changes to the Standards for Judicial Administration.

CRITICALCivil cases

Applies to

RA-010 remote appearance request

Judicial Council Form RA-010 is mandatory for remote appearances at evidentiary hearings and trials.

Also, please review Judicial Council Form, RA-010 for mandatory use for Evidentiary and Trial Remote Appearances.

CRITICALCivil cases

Applies to

Notice of related cases

Parties must timely comply with California Rules of Court 3-300 regarding notice of related cases.

The Court requires timely compliance with California Rules of Court 3-300 regarding Notice of Related Cases.

CRITICALCivil cases

Applies to

Individual documents

If there is a lack of cooperation in preparing joint documents, then please file individual documents with a declaration explaining the difficulty.

If there is a lack of cooperation in preparing joint documents, then please file individual documents with a declaration explaining the difficulty.

CRITICALCivil cases

Applies to

Joint statement of the case

A joint statement of the case must be filed by the time of the Final Status Conference.

Filed-Joint Statement of the Case.

CRITICALCivil cases

Applies to

Motion in limine

MILs may not be used to seek summary judgment, summary adjudication, judgment on the pleadings, or bifurcation.

MILs may not be used to seek summary judgment, summary adjudication of issues, judgment on the pleadings, or bifurcation issues. LASC Rule 3.57.