Los Angeles Superior Court Document Filing Requirements

CRITICAL

Applies to

Joint settled statement

In trials conducted without a court reporter, the parties must prepare a joint settled statement at the end of each trial day to be filed with the Court before the next day of trial.

In any trial conducted without the benefit of a court reporter, the parties will be required to prepare a joint settled statement at the end of each day of trial to be filed with the Court prior to the commencement of the following day of trial.

CRITICAL

Applies to

Joint exhibit list

Counsel and self-represented parties must jointly prepare and file a joint exhibit list containing eight specified columns for each trial exhibit, after meeting and conferring 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 chart of page and line designations

Must include

caption

Parties must attach tabbed transcript pages to the joint chart and highlight each designation, using a different highlighter color per party.

The parties shall attach copies of the pages of the transcripts of the deposition or former testimony they are designating or counter-designating to the Joint Chart of Page and Line Designations for Deposition and Former Testimony, with numbered tabs separating each deposition or trial transcript. Each designation or counter-designation shall be highlighted, with each party using a different color highlighter.

CRITICAL

Applies to

Joint chart of page and line designations

Designating parties must include six specified columns in the joint chart of deposition and former testimony designations.

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

Ex parte application

Must include

proposed order

Ex parte applicants must comply with the requirements of California Rules of Court, rules 3.1200-3.1207, submit a proposed order, and pay the filing fee before appearing in court.

Ex parte applicants must comply with the requirements of California Rules of Court, rules 3.1200-3.1207, submit a proposed order, and pay the filing fee before appearing in court.

CRITICAL

Applies to

Proposed jury instructions

For jury trials, counsel and self-represented parties must jointly prepare a complete set of full-text proposed jury instructions with CACI instructions edited, party names inserted, and blanks/irrelevant material removed.

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

Joint statement

The Joint Statement must use a four-column format: discovery request number, full text of the request, text of the response, and each party's brief bullet-point argument on compelling a further response.

document set up as follows: the first column will identify the number of the discovery request at issue (e.g., SROG No. 1, or FROG No.1, etc.); the second, the full text of the discovery request; the third, the text of the response; and the fourth, a brief bullet-point statement, one from each party, as to why a further response should or should not be compelled.

CRITICAL

Applies to

Joint witness list

The joint witness list must use a specified column format including witness name, expert status, accommodations, calling party, expected testimony, and estimated examination times.

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

CRITICAL

Applies to

Idc request stipulation

Must include

proposed order

An IDC request must include a proposed order, with a blank for the Court to set the date and time of the IDC.

The parties must also file a proposed order that the Court may issue granting or denying the request for an IDC, with a blank for the Court to set the date and time of the IDC.

CRITICAL

Applies to

Joint witness list

Counsel and self-represented parties must jointly prepare and file a 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.

CRITICAL

Applies to

Joint list of proposed jury instructions

For jury trials, counsel and self-represented parties must jointly prepare and file a joint list of proposed jury instructions stating, for each instruction, its number, title, requesting party, agreed/contested status, any objection, and the court's disposition.

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 as proposed, modified, refused, or withdrawn (CRC 2.1055) (“Joint List of Proposed Jury Instructions”).

CRITICAL

Applies to

Joint exhibit list

Parties must jointly prepare and file a joint exhibit list using a specified column format 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; (7) the date the exhibit was marked for identification; and, (8) the date the exhibit was admitted into evidence.

CRITICAL

Applies to

Trial brief

Each party must file a trial brief identifying remaining claims/defenses, major legal issues with authorities, relief and damages calculation, and other helpful information.

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

Joint chart of page and line designations

Each designating party's designations in the joint chart must include columns for the designation number, page and line designations requested, objections, related counter-designations, and the Court's ruling.

In the joint chart, each designating party's designations of deposition or former testimony shall include columns which state: (1) the designation number ... 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 statement of case

For jury trials, counsel and any 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

Idc request stipulation

An IDC request must be made by joint stipulation that briefly summarizes the discovery at issue and explains the parties' meet-and-confer efforts beyond the exchange of correspondence.

To request an informal discovery conference, the parties must file a stipulation jointly requesting the IDC. The stipulation should briefly summarize the discovery at issue and explain what efforts the parties have made to meet and confer, beyond the exchange of correspondence, to narrow the scope of their discovery dispute.

CRITICAL

Parties must comply with California Rules of Court rule 3.722 et seq. and Local Rule 3.25 in connection with case management conferences (held Monday through Friday at 8:30 a.m.).

The parties must comply with California Rules of Court, rule 3.722, et seq., and Local Rule 3.25 in connection with such conferences.

CRITICAL

Applies to

Joint witness list

Witnesses not on the joint witness list are subject to exclusion from testifying at trial, except for impeachment or rebuttal, unless the party shows good cause.

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. 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

Trial binder

No later than five court days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department 3 a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following: 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

No later than five court days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department 3 a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following: 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

CRITICAL

Applies to

Joint statement

The Court may from time to time after the Case Management Conference schedule status conferences regarding mediation and discovery and order the parties to submit a joint statement informing the Court whether mediation or other efforts to resolve the case have occurred, and providing the Court with a discovery plan for the remaining discovery in the case. ... The failure to timely file a joint statement will result in the Court scheduling an order to show cause for sanctions.

The Court may from time to time after the Case Management Conference schedule status conferences regarding mediation and discovery and order the parties to submit a joint statement informing the Court whether mediation or other efforts to resolve the case have occurred, and providing the Court with a discovery plan for the remaining discovery in the case. ... The failure to timely file a joint statement will result in the Court scheduling an order to show cause for sanctions.

CRITICAL

Applies to

Trial brief

Each party must file a trial brief identifying disputed claims and defenses, major legal issues with supporting authorities, relief and damages calculation, and 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

Joint chart of page and line designations

If any party intends to use deposition or former trial testimony, counsel and self-represented parties must meet and confer and jointly prepare and file a Joint Chart of Page and Line Designations for Deposition and Former Testimony.

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 counter-designating party's counter-designations in the joint chart must include six specified columns covering designation number and witness name, date and type of testimony, page and line counter-designations, objections, the related designation number, and the Court's 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 counter designations

Must include

caption

Counter-designating parties must include six specified columns in the joint chart for their counter-designations.

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 witness list

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.

CRITICAL

Applies to

Joint witness list

Witnesses not listed on the joint witness list may be excluded from testifying (except for impeachment or rebuttal) unless the party first shows 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

Joint statement of controverted issues of law and fact

The parties must submit a jointly prepared statement of controverted issues of law and fact for consideration at the Final Status Conference.

In order to ensure that the parties properly address, both before and during trial, the legal and factual issues upon which they are seeking a judicial decision, the Court requires the parties to submit a jointly prepared statement of controverted issues of law and fact for consideration at the Final Status Conference.

CRITICAL

Applies to

Proposed verdict form

Jury trial parties must file a joint proposed verdict form acceptable to all parties, or, if they cannot agree after meeting and conferring, each party must separately file its own proposed verdict form.

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 after meeting and conferring the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

CRITICALCivil cases

Applies to

Joint exhibit list and witness list

In court trials, the parties must submit a joint exhibit list and a joint witness list as described for the trial notebook.

The parties must submit a joint exhibit list and joint witness list as described above.

CRITICALCivil cases

Applies to

Joint witness list

The joint witness list must list each witness once with expected testimony time per witness and a total estimated testimony time at the end.

All witnesses must be listed on one list. Do not repeat the name of a witness who will be called by more than one party. Next to each witness, indicate the total time expected for that testimony (including direct, cross, redirect, etc.) At the end of the list, calculate the total amount of time estimated for testimony.

CRITICALCivil cases

Applies to

Exhibit notebook

At trial, parties must provide exhibit notebooks for the Court, Judicial Assistant, witness, and opposing parties, plus a complete exhibit list for the Judicial Assistant.

At trial, the parties must provide exhibit notebooks for the Court, the Judicial Assistant, the witness, and the opposing parties. The parties must also provide the Judicial Assistant with a complete exhibit list. Local Rules 3.52 and 3.53.

CRITICALCivil cases

Applies to

Ex parte application

Ex parte applications are reserved for exigent circumstances and must include a declaration making an affirmative factual showing of irreparable harm, immediate danger, or another statutory basis for relief (CRC 3.1202(c)).

Ex parte applications are reserved for exigent circumstances. The applicant shall comply with CRC 3.1202(c): "An applicant must make an affirmative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte."

CRITICALCivil cases

Applies to

Daily proceedings summary

The Court strongly encourages bringing a court reporter, but if none is used the parties must jointly prepare a summary of the day's proceedings (including detailed witness testimony summaries) and lodge it in the courtroom the next morning before proceedings resume for potential use in a Settled Statement on appeal.

The Court strongly encourages the parties to bring a court reporter for trial. If no court reporter is used, the parties must jointly prepare a summary of the day's proceedings, including a detailed summary of the testimony of any witness, and lodge it in the courtroom the next morning before proceedings resume, for use in a Settled Statement if the Court's judgment is appealed.

CRITICALCivil cases

Applies to

Joint jury instructions

Must include

proposed order

A proposed order with a disposition table for all jury instructions must be submitted with the joint jury instructions.

Submit a proposed order which contains a disposition table listing all jury instructions by number, the identity of the party or parties proposing the instruction, and which contains columns for the court to indicate whether the instruction is given, modified, withdrawn, or refused.

CRITICALCivil cases

Applies to

Joint jury instructions

Joint jury instructions must be submitted as a complete CACI notebook with no brackets, blanks, tear sheets, or disposition boxes, with disputed instructions in separate identified sets.

Submit a notebook with a joint set of CACI instructions with all information filled in, no remaining brackets or blanks. Do not use tear sheets for the instructions and do not include the disposition box on the page of the individual instruction. If some instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction.

CRITICALCivil cases

Applies to

Exhibit notebook

Exhibit notebooks must be available on the FSC date and all parties must be prepared to confirm they reviewed all documents in the exhibit book.

Notebooks containing all exhibits must be available on the FSC date and all parties must be prepared to tell the Court that they have had the opportunity to review all documents in the exhibit book.

CRITICALCivil cases

Applies to

Proposed verdict form

Parties must jointly file a proposed verdict form acceptable to all sides, or if they cannot agree, each party must separately submit a proposed verdict form.

The parties shall prepare and jointly file a proposed general or special verdict form acceptable to all sides. Local Rule 3.25(g)(8). If the parties cannot agree on a joint verdict form, each party must separately submit a proposed verdict form. Any proposed special verdict should be in a form that is easily used by the jury and does not require the jury to answer unnecessary questions.

CRITICALCivil cases

Applies to

Joint exhibit list

The joint exhibit list must contain all exhibits on one list with numbered descriptions and columns for marking, receipt into evidence, and stipulations to authenticity and admissibility.

All exhibits must be listed on one list, identified by a number and brief description with columns for the clerk and Court to use to indicate whether the exhibit is marked and received into evidence. There should be a column to reflect stipulations to authenticity and a column for stipulations to admissibility.

CRITICALCivil cases

Applies to

Trial readiness binder

Counsel and any self-represented parties must jointly prepare and submit the trial readiness binders required by the Trial Preparation Order at least five days before the FSC.

The Court expects the parties' counsel and any self-represented parties to work together to jointly prepare and submit the binders required by the order at least five days before the FSC.

CRITICALCivil cases

Applies to

Joint trial notebook

At the Final Status Conference the parties must submit a tabbed joint trial notebook containing the operative pleadings, relevant minute orders (demurrers, motions to strike, and granted summary adjudication motions), a joint short statement of the case, joint witness list, and joint exhibit list.

At the Final Status Conference, the parties must submit a joint trial notebook, tabbed and containing: • Operative complaint and cross-complaints, if any • Operative answers • Copies of minute orders sustaining demurrers or motions to strike pleadings that have not been covered by amendments • Minute orders or any motions for summary adjudication that were granted • Joint Short Statement of the Case • Joint Witness List • Joint Exhibit List

CRITICAL

Applies to

Exhibit list

Counsel must prepare, exchange, and lodge a complete exhibit list noting admissibility stipulations and foundation/authentication waivers 5 court days before the final status conference.

5. EXHIBIT LIST. File and Lodge 5 court days before FSC. Counsel shall .prepare, exchange and lodge a complete exhibit list noting stipulations regarding the admissibility of exhibits and regarding waiver of foundation and/or authentication of exhibits. (SCLAC Rules 3.25(9)(6), 3.52, 3.53.)

CRITICAL

Applies to

Verdict form

Counsel must meet and confer and file/lodge a joint general verdict form (CACI VF-5001) 5 court days before the final status conference.

8. VERDICT FORM. File and Lodge 5 court days before FSC. Counsel shall meet and confer to prepare a JOINT General Verdict Form to be presented to the jury. (CACI VF-5001.)

CRITICAL

Applies to

Proposed voir dire questions

Parties must serve and file proposed voir dire questions five court days before the final status conference.

The parties shall, five court days prior to the FSC, serve and file proposed Vair Dire questions for the court.

CRITICAL

Applies to

Jury instructions

Counsel must meet and confer to prepare jointly requested and other jury instructions with all objections, and lodge them 5 days prior to the final status conference in the prescribed format.

7. JURY INSTRUCTIONS. File and Lodge 5 court days before FSC. Counsel shall meet and confer to prepare: (a) the jointly requested jury instructions; and (b) all other requested jury instructions, and all objections thereto. All jointly requested jury instructions and other jury instructions, with objections thereto, shall be lodged 5 days prior to the FSC in the format set forth below (see SCLAC Rules 3.25(g)(7), 3.170, 3.171):

CRITICAL

Applies to

Witness list

Counsel must prepare, exchange, and lodge a complete witness list with proffers of anticipated testimony and estimated direct examination lengths 5 court days before the final status conference.

4. WITNESS LIST. File and Lodge 5 court days before FSC. Counsel shall prepare, exchange and lodge a complete witness list including proffers of anticipated testimony and estimated length of direct examination of each witness. (SCLAC Rule 3.25(g)(5).)

CRITICAL

Applies to

Joint statement of case

Counsel must meet and confer and lodge a joint written statement of the case, suitable to be read to the jury, 5 court days before the final status conference.

Counsel shall meet and confer to prepare a joint written statement of the case suitable to be read to the jury and shall lodge said statement 5 court days prior to the FSC. (See SCLAC Rules 3.25(g)(4); 3.73.)

CRITICAL

Applies to

Pretrial report

The pretrial report must specify the causes of action and affirmative defenses to be tried or dismissed, stipulations as to ultimate facts (after meet and confer), all expected evidentiary issues with points and authorities, and a time estimate for opening statement.

Each counsel shall prepare a written pretrial report, including the following items and serve and file the report 5 court days prior to the FSC: a. Specification of the precise causes of action and affirmative defenses which are to be tried and specification of those which are to be dismissed. b. Stipulations as to ultimate facts and issues. Counsel must meet and confer in an attempt to reach such stipulations. c. Specification of all evidentiary issues expected to be raised at trial and points and authorities in connection with each party's position thereon. d. Time estimate of opening statement.

CRITICALCivil cases

Applies to

Motion in limine binder

The motions in limine binder must include a table of contents identifying each motion, opposition, and reply and its corresponding tab.

The binder also must contain a table of contents identifying each motion in limine, opposition, and reply, and the corresponding tab for each.

CRITICALCivil cases

Applies to

Declaration

If any defendant remains unserved, plaintiff must file a declaration explaining service efforts at least five days before the case management conference hearing.

If all defendants have not been served, plaintiff or plaintiff's counsel must submit a declaration to the court five (5) days prior to the hearing explaining what efforts have been undertaken to accomplish service.

CRITICALCivil cases

Applies to

Ex parte application

Must include

proposed order

Ex parte applicants must submit a proposed order before appearing in court.

Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in court.