Los Angeles Superior Court Document Filing Requirements

CRITICAL

Applies to

Statement of the case

Parties must submit a printed, short, non-argumentative joint written 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

Exhibit notebook

All exhibits sought to be admitted by the parties shall be placed in Exhibit Notebooks. On the first day of trial, the parties are ordered to jointly submit five identical copies of the Exhibit Notebooks as follows: one for each party, two for the Court, and one for the witness stand.

All exhibits sought to be admitted by the parties shall be placed in Exhibit Notebooks. On the first day of trial, the parties are ordered to jointly submit five identical copies of the Exhibit Notebooks as follows: one for each party, two for the Court, and one for the witness stand.

CRITICAL

Applies to

Proposed jury instructions

Parties/counsel must jointly prepare a complete set of full-text proposed jury instructions with CACI edits, party names inserted, blanks filled, and brackets eliminated.

The parties/counsel shall jointly prepare a complete set of full text proposed jury instructions, editing all proposed CACI, inserting party name(s) and all other information, filling in all blanks, and eliminating all brackets and irrelevant bracketed language.

CRITICAL

Applies to

Court trial submissions

For court trials, parties must submit trial briefs, a joint exhibit list, and a joint witness list, and comply with the deposition designation and motions in limine provisions.

The parties must submit trial briefs, a joint exhibit list, and a joint witness list, as described above. The parties must also comply with the provisions above concerning designation of deposition and former testimony and concerning motions in limine, if any.

CRITICAL

Applies to

Joint witness list

The joint witness list must identify all witnesses (other than impeachment/rebuttal) on one list with name, expert status, expected testimony, per-witness time estimates, and time totals.

All witnesses, other than those to be called exclusively for impeachment or rebuttal, must be identified on one list. Do not repeat the name of a witness who will be called by more than one party. The joint witness list must (1) identify each witness by name, (2) specify which witnesses are experts, (3) briefly describe the expected testimony, and (4) estimate the length of the direct, cross-examination and re-direct examination (if any) of each witness. In an additional column, the parties must total the time estimated for each witness’s testimony. At the bottom of the witness list, the parties must total the time for all witnesses on direct, cross, and redirect. Make realistic time estimates.

CRITICAL

Applies to

Joint motions in limine statement

If more than five motions in limine are filed collectively, the parties must file a joint document at least 4 court days before the final status conference describing each motion with a one-paragraph argument in support and a one-paragraph argument in opposition.

If the parties file, collectively, more than five (5) motions in limine, they must file a joint document at least four (4) court days before the final status conference that (a) describes the motion, (b) has a one- paragraph argument in support and (c) has a one-paragraph argument in opposition.

CRITICAL

Applies to

Motion in limine

Motions in limine seeking to preclude inadmissible/prejudicial matters before the jury must be accompanied by a declaration complying with Local Rule 3.57 and Kelly v. New West Federal Savings.

Each motion in limine for the purpose of precluding the mention or display of inadmissible and prejudicial matters in the presence of the jury shall be accompanied by a declaration in compliance with the requirements of Rule 3.57 of the Local Rules and must comply with Kelly v. New West Federal Savings (1996) 49 Cal. App.4th 659, 670-71.

CRITICAL

Applies to

Joint proposed jury instructions

Parties must jointly prepare and file one list of proposed jury instructions organized in CACI numerical order with 5 columns.

The parties/counsel shall jointly prepare and file one list of proposed jury instructions, organized in CACI numerical order. The instruction list must have 5 columns

CRITICAL

Applies to

Joint statement of case

Jury trials require a jointly prepared, short, non-argumentative written statement of the case to be read to the jury per Local Rule 3.25(g)(4).

A jointly prepared, short, non-argumentative written statement of the case to be read to the jury. Local Rule 3.25 (g)(4).

CRITICAL

Applies to

Motion in limine

Each party must assign different, sequential numbers or letters to its motions in limine (e.g., Plaintiff 1-5, Defendant A-E), and oppositions must identify which motion they oppose.

The parties must assign different, sequential numbers or letters to their motions in limine and the party opposing the motion must identify to which motion the opposition applies. For example, Plaintiff’s motions in limine may be numbered 1-5; Defendant’s motions in limine may be lettered A-E; additional parties may use double numbers or letters or some other agreed-upon designation to avoid duplication and confusion.

CRITICAL

Applies to

Trial brief

Trial briefs are optional for jury trials and mandatory for bench trials.

TRIAL BRIEFS. (optional for jury trials, mandatory for bench trials).

CRITICAL

Applies to

Trial readiness binder

The Trial Readiness Binder must contain conformed copies of the trial briefs, joint statement of the case, joint witness and exhibit lists, joint jury instructions (agreed and contested), joint verdict form, joint page-line designation chart, and motions (list continues beyond provided text).

The binder must contain conformed copies of the trial briefs, joint statement of the case. joint witness list, joint exhibit list, joint list of jury instructions, joint full-text jury instructions (organized as agreed-upon, plaintiff’s requested to which defendant objects and defendant’s requested to which plaintiff objects), joint verdict form, joint page-line designation chart, motions

CRITICAL

Applies to

Joint exhibit list

The joint exhibit list must identify all exhibits by number and description, include Objections, DATE ID'd, and DATE ADMITTED columns, and the parties must meet and confer to resolve authenticity and admissibility objections.

All exhibits, other than those to be used exclusively for impeachment or rebuttal, must be listed on the list, identified by a number and brief description. The parties/counsel shall meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit. The exhibit list must have a column labeled “Objections”. If any party has any objection to the admissibility of any exhibit, the objecting party must be identified, and the grounds for the objection must be set forth in the “Objections” column next to that exhibit. The exhibit list must have two columns on the far right labeled “DATE ID’d” and “DATE ADMITTED” in which the Court Clerk may note the dates of identification and admission of each exhibit.

CRITICAL

Applies to

Deposition designation chart

Parties intending to use deposition or former trial testimony (other than exclusively for impeachment or rebuttal) must meet and confer and jointly file a designation chart with seven specified columns.

If the parties/counsel intend to use deposition testimony or former trial testimony in lieu of any witness’s live testimony, other than exclusively for impeachment or rebuttal, the parties/counsel shall meet and confer and jointly prepare and file a chart with columns for each of the following: (1) the name of the witness; (2) the date and type of testimony (e.g., deposition or trial); (3) the line and page designations of the testimony requested for use, (4) any objections, (5) any related counter-designations by line and page, (6) any responses thereto, and (7) the Court’s ruling.

CRITICAL

Applies to

Joint witness list

Witness scheduling issues and special requirements (including interpreters) must be identified on the witness list, and calling an unlisted witness (other than for impeachment/rebuttal) requires a prior good cause showing.

Identify all potential witness scheduling issues and special requirements, including interpreters on the witness list. Any party seeking to elicit testimony from a witness for other than impeachment or rebuttal who is not identified on the witness list must first make a showing of good cause to the court.

CRITICAL

Applies to

Daily settled statement

Parties must meet and confer about arranging a court reporter; if no court reporter is arranged, counsel must prepare a daily settled statement summarizing each day's witness testimony.

The parties must meet and confer to discuss whether they plan to have a court reporter transcribe the trial proceedings. In order to ensure a proper record for appellate purposes, if the parties do not arrange for a court reporter, then counsel for the parties will be required to prepare a daily settled statement summarizing witnesses’ testimony who have testified each day at trial.

CRITICAL

Applies to

Proposed special verdict form

The proposed special verdict form must be joint, with contested questions bracketed, and in a form easily used by the jury without unnecessary questions.

The proposed special verdict form must be joint. If the parties cannot agree on each question on a proposed verdict form, they must agree on what they can and put contested questions in brackets. Any proposed special verdict should be in form that is easily used by the jury, and which does not require the jury to answer unnecessary questions.

CRITICAL

Applies to

Expert declaration ccp 2034 260

For any expert counsel intends to call at trial, counsel must present the Court and opposing counsel with a CCP section 2034.260 declaration stating the substance of the proffered opinion no later than the FSC.

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

Motion in limine

Motions in limine must include a sworn declaration describing the meet-and-confer and the opposing party's position, and must be filed with timely statutory notice so the motion can be heard at the FSC.

motions in limine must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party, setting forth the opposing party’s position regarding the motions, and must be submitted with timely statutory notice so the motion 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

Memorandum

IDC memoranda first paragraph must include neutral dispute statement and 1-3 sentence description per party 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

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; the Court discourages competing proposed verdict forms.

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

Motion for additional discovery

A motion for additional discovery beyond sections 2-6 must specifically identify the contemplated discovery and include a statement of the parties' respective positions.

Any motion seeking to commence any additional discovery beyond sections 2-6 shall specifically identify the contemplated additional discovery and shall include a statement of the parties' respective positions regarding the same.

CRITICAL

Applies to

Motion in limine

Must include

statutory notice, sworn declaration, certificate of conference

Motions in limine must include sworn declaration of conference with opposing party and their position, plus statutory notice.

motions in limine must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party, setting forth the opposing party’s position regarding the motions, and must be submitted with timely statutory notice so the motion in limine can be heard at the FSC.

CRITICAL

Applies to

Customer complaint list

Defendant's list of substantially similar customer complaints may be in chart or spreadsheet format, must include 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

CRITICAL

Applies to

Joint witness list

Absent good cause, total estimated testimony hours on the joint witness list may not exceed the trial estimate given at the case management conference, including one day for jury selection and sufficient time for opening and closing arguments.

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

Proposed jury instructions

Before submitting proposed jury instructions, counsel must fill in blanks, make appropriate modifications, comply with SCLAC 3.170-3.171, and use CACI for form instructions.

Before submitting the instructions, counsel must fill in the blanks, make appropriate modifications, and comply with SCLAC 3.170 to 3.171. Use CACI for form instructions.

CRITICAL

Applies to

Joint witness list

The parties must file a joint witness list showing each witness they actually intend to call, the estimated testimony time per witness (direct, cross, redirect), and a total time estimate at the end of the list.

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.

CRITICAL

Applies to

Request for court reporter

Must include

form fw 020

Parties with fee waivers must file Form FW-020 to request official court reporter before hearing/trial.

A party who has received a fee waiver pursuant to CRC 3.55(7) may request an official court reporter by filing form FW-020 https://selfhelp.courts.ca.gov/jcc-form/FW-020 before the hearing or trial (See CRC 2.956(c)).

CRITICAL

Applies to

Ex parte application

Ex parte applications must show irreparable harm/immediate danger/statutory basis and why other relief methods are not feasible.

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

Proposed jury instructions

Parties must submit a joint set of jury instructions plus each side's disputed instructions, providing the full text of all requested instructions rather than just a list.

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).

CRITICAL

Applies to

Ex parte application

Ex parte applications must affirmatively show 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 trial continuance.

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

Case management conference addendum

l am completely familiar with this case and will be fully prepared to discuss the status of 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.

l am completely familiar with this case and will be fully prepared to discuss the status of 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.

CRITICAL

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include a proposed order with the moving papers.

the notice must be included in the declaration and a proposed order must be presented with the moving papers.

CRITICAL

Applies to

Joint witness list

The joint witness list must contain seven specified columns (witness name/expert status/accommodations, calling party, expected testimony, direct/cross/total time estimates in hours) plus a grand total, and any witness not listed is subject to being excluded.

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

CRITICAL

Applies to

Proposed jury instructions

For jury trials, the parties must jointly prepare a complete set of full-text proposed jury instructions, editing CACI instructions, inserting party names, and removing 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.

CRITICAL

Applies to

Trial brief

Each party must file a trial brief identifying the disputed claims and defenses, major legal issues with supporting authorities, relief and damages calculation, and any other information assisting the court at trial.

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; and (4) any other information that may assist the court at trial.

CRITICAL

Applies to

Case management conference addendum

The case management conference addendum must bear the typed or printed name and signature of the party or attorney, with two signature blocks provided.

(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)

CRITICAL

Applies to

Joint case management conference statement addendum

Joint Case Management Conference Statement Addendum must include a statement that the signer is familiar with the case and has authority to enter into stipulations.

l am completely familiar with this case and will be fully prepared to discuss the status of 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.

CRITICAL

Applies to

Joint statement of witness testimony

Parties without a court reporter must prepare a joint statement of each day's witness testimony at the close of the session and lodge it with the Court the next morning before proceedings resume — no exceptions.

Parties who do not provide a court reporter for trial are directed to meet at the close of each session and prepare a joint statement of the witness testimony presented that day. The joint statement must be lodged with the Court the next morning before proceedings resume. No exceptions.

CRITICAL

Applies to

Joint list of proposed jury instructions

For jury trials, the parties must jointly prepare and file a 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 objection, and (6) whether the jury instruction was given by the court ("Joint List of Proposed Jury Instructions").

CRITICAL

Applies to

Cmc statement

Parties must file a CMC statement on Judicial Council Form CM-110 within five days of the case management conference hearing.

The parties are to (1) meet and confer—in person or by telephone—no later than 30 days before the hearing, and (2) file a CMC statement on Judicial Council Form CM-110 within five (5) days of the hearing.

CRITICAL

Applies to

Joint statement of case

For 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).)

CRITICAL

Applies to

Discovery production

Parties must serve verification with all produced discovery documents.

Plaintiff and defendant shall serve verification with the documents they produce.

CRITICAL

Applies to

Customer complaint list

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.

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.

CRITICAL

Applies to

Document production

Both plaintiff and defendant must serve a verification along with the documents they produce.

Plaintiff and defendant shall serve verification with the documents they produce.

CRITICAL

Applies to

Joint witness list

Parties' counsel and self-represented parties must jointly prepare and file a list of all trial witnesses, excluding impeachment and rebuttal witnesses (Local Rule 3.25(g)(5)).

The parties’ counsel and any self-represented parties shall work together to prepare and file a joint list of all witnesses whom any party intends to call at trial, excluding impeachment and rebuttal witnesses.

CRITICAL

Applies to

Motion in limine

Motions in limine must be accompanied by declarations that comply with Los Angeles County Court Rule 3.57(a).

The parties’ counsel and any self-represented parties shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and file declarations that comply with the requirements of Los Angeles County Court Rule 3.57, subdivision (a).

CRITICAL

Applies to

Joint exhibit list

Counsel and self-represented parties must jointly prepare and file an exhibit list stating eight specified items for each trial exhibit and must meet and confer to resolve authenticity and admissibility objections.

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).) As set forth above, the parties’ counsel and any self-represented parties shall meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit.

CRITICAL

Applies to

Joint case management conference statement addendum

All parties must meet and confer in person or by telephone and respond to the addendum's questions, stating their respective positions.

You are ordered to meet and confer in person or by telephone and to respond to the following questions, stating your respective positions.

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”).