Los Angeles Superior Court Document Filing Requirements

CRITICALCivil cases

Applies to

Joint idc report

The joint IDC report must set forth the nature of the dispute, the necessity for the discovery, the justification for non-production, and the overall status of discovery.

At least seven (7) days before the IDC, the parties shall file a joint report, of no more than eight pages, that succinctly sets forth the nature of the dispute, the necessity for the discovery, the justification for its non-production, and the overall status of discovery.

CRITICALCivil cases

Applies to

Joint statement

In jury trials, the parties must prepare and sign a joint written statement of the case for the Court to read to the jury.

Joint Statement – For jury trials, the parties shall prepare a joint written statement of the case for the Court to read to the jury. The parties/counsel shall sign the joint statement.

CRITICALCivil cases

Applies to

Joint exhibit list

The parties must meet-and-confer and then file a signed joint exhibit list with columns for the exhibit, offering party, stipulations to authenticity/admissibility, date identified, and date admitted, with all objections specified.

Joint Exhibit List – The parties shall prepare and file a joint exhibit list organized with columns identifying: (1) the exhibit, (2) which party is offering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) the date on which the exhibit was identified, and (5) the date on which the exhibit was admitted. Prior to filing the joint exhibit list, the parties shall meet-and-confer to determine whether they will stipulate to the authenticity and/or admissibility of each exhibit or whether there are objections to any exhibit. If there are stipulations, the parties shall note that in the respective column. If not, the objecting party shall specify all objections in the respective column. The parties/counsel shall sign the joint exhibit list.

CRITICALCivil cases

Applies to

Motion in limine

Each motion in limine caption must concisely identify the evidence the moving party seeks to admit or exclude.

The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to admit or exclude.

CRITICALCivil cases

Applies to

Ex parte application

Ex parte applicants must include a declaration making an affirmative factual showing of irreparable harm, immediate danger, or another statutory basis for ex parte relief.

Ex parte applications are reserved for exigent circumstances. The applicant shall comply with Cal. Rules of Court, rule 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

Joint witness list

The parties must file a signed joint witness list identifying each witness by name, expert status, estimated examination times, total testimony hours, and any scheduling issues or special requirements.

Joint Witness List – The parties shall work together and file a joint list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. The joint witness list shall identify each witness by name, specify which witnesses are experts, estimate the length of direct examination, cross-examination, and re-direct examination of each, and include a total of the number of hours for all witness testimony. The parties shall identify all potential witness scheduling issues and special requirements. The parties/counsel shall sign the joint witness list.

CRITICALCivil cases

Applies to

Trial brief

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

Trial Briefs – Each party shall file a trial brief succinctly identifying: (1) the claims and defenses subject to litigation, (2) the major legal issues (with supporting points and authorities), (3) the relief claimed and the calculation of damages sought, and (4) any other information that may assist the Court at trial.

CRITICALCivil cases

Applies to

Motion in limine

Motions in limine must comply with Local Rule 3.57, including the required declaration where applicable.

When filing motions in limine, the parties must comply with Local Rule 3.57, including the required declaration, if applicable.

CRITICALCivil cases

Applies to

Deposition designation chart

If deposition or former trial testimony will be used in lieu of live testimony, the parties must meet-and-confer and file a signed joint designations chart with page/line designations, objections, counter-designations, responses, and the Court's rulings.

Page and Line Designations for Deposition and Former Testimony – If the parties intend to use deposition testimony or former trial testimony in lieu of any witness's live testimony, the parties shall meet-and-confer and jointly prepare and file a chart with columns for each of the following: (1) the page and line designations of the deposition or former testimony requested for use, (2) objections, (3) counter-designations, (4) any responses thereto, and (5) the Court's rulings. The objecting party shall specify all objections in the respective column. The parties/counsel shall sign the designations.

CRITICALCivil cases

Applies to

Proposed jury instructions

The parties must submit a set of full-text proposed jury instructions, with special instructions formatted for submission to the jury showing only the instruction number, title, and text.

set of full-text proposed jury instructions. The parties shall prepare special instructions in a format ready for submission to the jury with the instruction number, title, and text only.

CRITICALCivil cases

Applies to

Verdict form

The parties must file a joint proposed general or special verdict form, or each party must separately file a proposed verdict form if they cannot agree.

Joint Verdict Forms – The parties shall prepare and file a joint proposed general verdict form or special verdict form (with interrogatories). If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

CRITICALCivil cases

Applies to

Joint list of proposed jury instructions

The parties must file a signed joint list of proposed jury instructions in numerical order, identifying agreed and contested instructions, with a space for the Court to mark whether each instruction was given.

Joint List of Proposed Jury Instructions – The parties shall jointly prepare and file a list of proposed jury instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any. The list of proposed jury instructions must include a space by each instruction for the Court to indicate whether the instruction was given. The parties/counsel shall sign the joint list of proposed jury instructions.

CRITICALCivil cases

Applies to

Opposition and reply brief

Oppositions and replies to motions in limine must identify the corresponding motion number in the caption.

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

CRITICALCivil cases

Applies to

Motion in limine

Parties filing more than one motion in limine must number the motions consecutively.

Parties filing more than one motion in limine shall number the motions consecutively.

WARNING

Applies to

Declarations memoranda briefs

Declarations, memoranda, and briefs should cite specific Bates-numbered pages supporting each factual assertion instead of referencing an exhibit as a whole.

Declarations, memoranda, and briefs should cite to the specific Bates-numbered pages supporting each factual assertion rather than making generalized references to an entire exhibit. For example, instead of stating that "the account statement is attached as Exhibit A," the declaration should identify the precise pages, such as "Exhibit A, Bates Nos. 0012-0015," rather than simply referring to the exhibit as a whole.

WARNING

Applies to

Trial submission

Trial submissions should be exchanged sufficiently in advance of trial and should identify the anticipated trial witnesses and include the proposed trial exhibits.

exchange trial documents sufficiently in advance of trial to permit meaningful review and preparation. Such submissions should identify the anticipated trial witnesses and include the proposed trial exhibits.

WARNING

Applies to

Filing with multiple exhibits

Filings containing multiple exhibits should also include a table of contents identifying each exhibit and the corresponding Bates-number range (or beginning Bates number) for that exhibit.

Filings containing multiple exhibits should also include a table of contents identifying each exhibit and the corresponding Bates-number range (or beginning Bates number) for that exhibit.

WARNING

Applies to

Filing

All pleadings, motions, applications, stipulations, requests, proposed orders, and other filings should clearly and specifically identify the relief sought in both the title of the filing and, where appropriate, the accompanying proposed order. Generic titles such as "Motion," "Application," “Declaration” or "Request" should be avoided. Instead, the title should describe the specific relief requested.

All pleadings, motions, applications, stipulations, requests, proposed orders, and other filings should clearly and specifically identify the relief sought in both the title of the filing and, where appropriate, the accompanying proposed order. Generic titles such as "Motion," "Application," “Declaration” or "Request" should be avoided. Instead, the title should describe the specific relief requested.

WARNING

Applies to

Trial submission

Must include

proposed order

The parties should also submit a Memorandum of Costs and a Proposed Judgment. The parties may submit a trial brief for the Court's review.

The parties should also submit a Memorandum of Costs and a Proposed Judgment. The parties may submit a trial brief for the Court's review.

WARNING

Applies to

List of proposed jury instructions

In jury trials, the parties must jointly file a numerically organized list of proposed jury instructions identifying agreed and contested instructions, with a space for the judge to mark whether each was given.

e. List of Proposed Jury Instructions (Joint and Contested): For jury trials, the parties/counsel shall jointly prepare and file a list of proposed jury instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any. The list of proposed jury instructions must include a space by each instruction for the judge to indicate whether the instruction was given.

WARNING

Applies to

Trial brief

Trial briefs must succinctly identify the claims and defenses, major legal issues with supporting authorities, relief claimed and damages calculation, and any other information assisting the court.

succinctly identifying: 1. The claims and defenses subject to litigation; 2. The major legal issues (with supporting points and authorities); 3. The relief claimed, and calculation of damages sought; 4. Any other information that may assist the court at trial.

WARNING

Applies to

Motion in limine

Must include

caption

Each motion in limine must be numbered consecutively in the caption, and opposition and reply papers must identify the corresponding motion number in their captions.

The caption of each motion in limine shall number them consecutively. Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.

WARNING

Applies to

Joint trial stipulations

Parties must meet and confer before the FSC to attempt reasonable stipulations on the joint statement of the case, motions in limine, legal issues, exhibit admissibility, witnesses, jury instructions, and verdict forms.

Counsel and any self-represented parties shall also meet and confer prior to the FSC to try and reasonably stipulate to a joint statement of the case, motions in limine, legal issues, authentication/foundation/admissibility of exhibits, witnesses, witness time estimates, jury instructions, and verdict forms.

WARNING

Applies to

Non documentary exhibits

All non-documentary exhibits must be marked with a simple written description inserted in the exhibit binder with a corresponding numerical tab.

The parties/counsel shall mark all non-documentary exhibits and insert a simple written description of the exhibit with a corresponding numerical tab in the exhibit binder.

WARNING

Applies to

Trial time estimates

Parties must be prepared to provide the Court with reasonable and accurate trial time estimates per Local Rule 3.25(h).

Parties shall be prepared to provide the Court with reasonable and accurate time estimates for trial as prescribed under Local Rule 3.25(h).

WARNING

Applies to

Trial binder

Tab B: Motions in Limine, Oppositions, and Replies. Tab C: Joint Statement of Case (for jury trials only). Tab D: Joint Witness List with Time Estimates. Tab E: Joint Exhibit List. Tab F: Proposed Jury Instructions List (for jury trials only). Tab G: Joint and Contested Jury Instructions. Tab H: Joint and/or Contested Special Verdict Form(s). Tab I: Joint Chart of Page and Line Designations for Deposition and Former Testimony. Tab J: Copies of Operative Pleadings (Complaint, Answer, Cross-Complaint, Answer).

Tab B: Motions in Limine, Oppositions, and Replies. Tab C: Joint Statement of Case (for jury trials only). Tab D: Joint Witness List with Time Estimates. Tab E: Joint Exhibit List. Tab F: Proposed Jury Instructions List (for jury trials only). Tab G: Joint and Contested Jury Instructions. Tab H: Joint and/or Contested Special Verdict Form(s). Tab I: Joint Chart of Page and Line Designations for Deposition and Former Testimony. Tab J: Copies of Operative Pleadings (Complaint, Answer, Cross-Complaint, Answer).

WARNING

Applies to

Joint statement of case

C. Joint Statement of Case: For jury trials, the parties/counsel shall work together to prepare and file a joint written statement of the case for the Court to read to the jury.

C. Joint Statement of Case: For jury trials, the parties/counsel shall work together to prepare and file a joint written statement of the case for the Court to read to the jury.

WARNING

Applies to

Jury instructions

In jury trials, the parties must prepare a complete set of full-text proposed jury instructions edited from CACI with party names inserted and blanks removed, with special instructions in jury-ready format showing only the instruction number and text.

f. Jury Instructions (Joint and Contested): For jury trials, the parties/counsel shall prepare a complete set of full text proposed jury instructions, editing all proposed California Civil Jury Instructions (CACI) and insert party name(s) and eliminate blanks and irrelevant materials. The parties/counsel shall prepare special instructions in a format ready for submission to the jury with the instruction number, and text only (i.e. there should§ be no boxes or other indication on the printed instruction itself as to the requesting party).

WARNINGCivil cases

Applies to

Daily written witness list

Each morning, counsel must give the Court Attendant a written list of that day's witnesses including full names with correct spellings and the order of calling.

Each morning, counsel must provide the Court Attendant with a written list of witnesses to be called that day including their full names with correct spellings and the order in which they will be called.

WARNINGCivil cases

Applies to

Opposition and reply brief

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

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

WARNINGCivil cases

Applies to

Jury instructions

Parties must prepare a complete set of full-text proposed jury instructions edited from the CACI with party names inserted and blanks, brackets, and irrelevant material eliminated.

The parties shall prepare a complete set of full- text proposed jury instructions, editing all proposed California Civil Jury Instructions, insert party name(s), eliminate blanks, brackets, and irrelevant material.

WARNINGCivil cases

Applies to

Joint witness list

Parties must file a signed joint witness list (excluding impeachment and rebuttal witnesses) identifying each witness by name, expert status, estimated examination times, total testimony time, and scheduling issues; testimony from unlisted witnesses requires a showing of good cause.

The parties shall work together and file a joint list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. (Local Rule 3.25(g)(5).) The joint witness list shall identify each witness by name, specify which witnesses are non-experts and experts, estimate the length of the direct, cross examination and re-direct examination of each witness, and include a total time for all witness testimony. The parties shall identify all potential witness scheduling issues and special requirements. 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 trial court. The parties/counsel shall sign the joint witness list.

WARNINGCivil cases

Applies to

Motion in limine

Parties are strongly encouraged to stipulate to uncontested motions in limine, and uncontested motions should be marked 'uncontested' in the caption.

The parties/counsel are strongly encouraged to stipulate to uncontested motions. Uncontested motions should note “uncontested” in the caption.

WARNINGCivil cases

Applies to

Trial brief

Each party's trial brief must identify the claims and defenses, major legal issues with supporting authorities, relief and damages sought, and other information assisting the court at trial.

Each party shall file a trial brief succinctly identifying (i) the claims and defenses subject to litigation; (ii) the major legal issues (with supporting points and authorities); (iii) the relief claimed, and calculation of damages sought; and (iv) any other information that may assist the court at trial.

WARNINGCivil cases

Applies to

Jury instructions

Proposed jury instructions must be separated into subsections with all uncontested instructions together and all contested instructions together.

Uncontested and contested instructions shall be separated into subsections, with all uncontested instructions together, and all contested instructions together.

WARNINGCivil cases

Applies to

Joint exhibit list

Parties must file a signed joint exhibit list with columns for the exhibit, offering party, authenticity/admissibility stipulations, evidentiary objections, and identification/admission dates, after meeting and conferring to resolve objections.

The parties shall prepare and file a joint exhibit list organized with columns identifying : (1) the exhibit, (2) which party is o ering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) each party's evidentiary objection, if any, to admission of each exhibit, (5) the date on which the exhibit was identified, and (6) the date on which the exhibit was admitted. The parties shall meet and confer to resolve objections to the admissibility of each exhibit. The parties shall sign the joint exhibit list.

WARNINGCivil cases

Applies to

Case management conference statement

Parties must file timely Case Management Conference Statements (preferably joint) describing the case, discovery timeline, and agreements, with sanctions up to $250 per violation for noncompliance.

The parties must then file timely Case Management Conference Statements pursuant to Rules of Court, rule 3.725 (preferably a joint statement), describing the nature of the case, when discovery will be completed (“per code” does not assist the Court), and any agreements the parties have reached (see 19(b) of the Statement). A failure to comply with Rules of Court, rules 3.724 and 3.725 may subject the o ending counsel to sanctions of up to $250 per violation. (Rules of Court, rule 2.30.)