Los Angeles Superior Court Document Filing Requirements

WARNINGCivil cases

Applies to

Motion in limine

Parties filing multiple motions in limine must number them consecutively.

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

WARNINGCivil cases

Applies to

Deposition designation chart

Parties using deposition or former trial testimony in lieu of live testimony must jointly prepare and file a signed designation chart with columns for page/line designations, objections, counter-designations, responses, and the court's rulings.

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.

WARNINGCivil cases

Applies to

Verdict form

Parties must file a joint proposed verdict form; if they cannot agree, each party must separately file a proposed verdict form and bring an electronic copy to the FSC ready to be edited in the courtroom.

The parties shall prepare and file a joint proposed general verdict form or special verdict form (with interrogatories) acceptable to all sides. (Local Rule 3.25(g)(8).) If the parties/counsel cannot agree on a joint verdict form, each party must separately file a proposed verdict form, and bring an electronic copy of their proposed verdict form to the FSC, ready to be edited in the courtroom.

WARNINGCivil cases

Applies to

Motion in limine

Each motion in limine's caption must concisely identify the evidence the moving party seeks to preclude.

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

WARNINGCivil cases

Applies to

Joint statement of case

In jury trials, parties must file a signed joint statement of the case that is neutral and does not exceed 2 paragraphs, for the court to read to the jury.

For jury trials, the parties shall prepare a joint written statement of the case for the Court to read to the jury. (Local Rule 3.25(g)(4).) The joint statement shall be a neutral short statement of the case and not exceed 2 paragraphs. The parties/counsel shall sign the joint statement.

WARNINGCivil cases

Applies to

Special jury instructions

Special jury instructions must be ready for submission to the jury with only the instruction number, title, and text (no boxes or other indications on the printed page), and the court will generally not give a substituted special instruction.

The parties shall prepare special instructions in a format ready for submission to the jury with the instruction number, title, and text only (i.e. there should be no boxes or other indications on the printed

WARNING

Applies to

Trial conference order documents and binders

The Court expects the parties' counsel and any self-represented parties to work together to jointly prepare and submit the documents and binders required by that order.

The Court expects the parties' counsel and any self-represented parties to work together to jointly prepare and submit the documents and binders required by that order.

WARNINGCivil cases

Applies to

Motion in limine

Motions in limine may not be used to seek dispositive orders or declaratory rulings that should be pursued through other motions.

Motions in limine shall not be used to seek (1) dispositive orders that should have been sought through a motion for summary judgment, summary adjudication, or judgment on the pleadings, or (2) rulings that are "declaratory of existing law or

WARNING

Applies to

Motion in limine

Motions in limine should not repeat exhaustive case-description context; background belongs in the trial brief.

Do not provide the same pages of exhaustive case description for context in every MIL. Instead, put this in the trial brief.

WARNING

Applies to

Motion in limine

Motions in limine must not be used to educate the court on an issue; that content belongs in the trial brief.

Do not file a MIL to educate the court on an issue---do this in the trial brief instead.

WARNING

Applies to

Trial binder

Proposed jury instructions must be organized behind Tab F with agreed-upon instructions 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.

WARNING

Applies to

Motion in limine opposition

Oppositions to motions in limine must be in writing, numbered, and refer to the numbers used by the moving party.

An opposition to any motion in limine must be in writing, numbered, and served and electronically filed by represented parties at least five (5) calendar days prior to the FSC. (Exempt parties may file same by conventional means on printed paper directly in Department F51.) The opposition must refer to the numbers used by the moving party.

WARNING

Applies to

Motion in limine

The following MILs usually should never be drafted or at least not survive meet and confer because counsel should not disagree: a) Exclude speculative evidence. b) Exclude expert opinion from non-experts. c) Confine experts to the area of their disclosure. d) Bar evidence of insurance coverage, prior settlements. e) Bar evidence not produced in discovery. f) Seeking bifurcation of punitive damages (its automatic on request) or to exclude the finances of a party in the liability phase. g) Witnesses to be disclosed in advance. h) Exclude percipient witnesses from trial before they have testified.

The following MILs usually should never be drafted or at least not survive meet and confer because counsel should not disagree: a) Exclude speculative evidence. b) Exclude expert opinion from non-experts. c) Confine experts to the area of their disclosure. d) Bar evidence of insurance coverage, prior settlements. e) Bar evidence not produced in discovery. f) Seeking bifurcation of punitive damages (its automatic on request) or to exclude the finances of a party in the liability phase. g) Witnesses to be disclosed in advance. h) Exclude percipient witnesses from trial before they have testified.

WARNING

Applies to

Motion in limine

Motions in limine must be in writing and numbered.

All motions in limine, if any, must be in writing, numbered, and shall be served on all opposing parties and counsel and electronically filed at least ten (10) calendar days before the FSC.

WARNING

Applies to

Joint witness list

Absent good cause, the total number of hours listed for testimony should not exceed the trial estimate given at the CMC, including an allocation of one day for jury selection and one day for instructions, closing arguments, and deliberations.

Absent good cause, the total number of hours listed for testimony should not exceed the trial estimate given at the CMC, including an allocation of one day for jury selection and one day for instructions, closing arguments, and deliberations.

WARNING

Applies to

Proposed special verdict form

Where an appropriate CACI special verdict form exists, the court expects the parties to use it.

If the parties request a special verdict form and there is an appropriate CACI special verdict form for a cause of action, affirmative defense or other finding, the court expects the parties to use the CACI special verdict form.

WARNING

Applies to

Motion in limine

Failure by any party or counsel to exchange or discuss motions in limine may result in the Court refusing to hear the motion.

Any failure by any party or counsel to exchange or discuss any motions in limine may result in the refusal of the Court to hear any such motion in limine, pursuant to applicable court rules.

WARNING

Applies to

Impeachment exhibits

Parties should pre-mark five copies of all impeachment exhibits with pages paginated by exhibit and page number before cross-examination.

In preparation for cross-examination of witnesses, each party should pre-mark five copies of all impeachment exhibits with each page properly paginated to reflect the exhibit number and page number so that they are ready for distribution during cross-examination.

WARNING

Applies to

Proposed jury instructions

Where an appropriate CACI instruction exists, the court expects the parties to request the CACI instruction rather than a specially prepared instruction.

If there is an appropriate CACI instruction on a point of law, the court expects the parties to request the CACI instruction instead of a specially prepared jury instruction.

WARNING

Applies to

Proposed special verdict form

Failure of the parties to agree on a proper special verdict form may result in the Court using a general verdict form.

Failure of the parties to agree on a proper special verdict form may result in the Court’s using a general verdict form.

WARNING

Applies to

Idc memorandum

The first paragraph of the IDC memorandum must contain a neutral statement of the dispute and one to three sentences describing (not arguing) each 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.

WARNING

Applies to

Ex parte application

Ex parte applications must comply with California Rules of Court, rule 3.1200 et seq.

Ex parte applications must comply with CRC 3.1200 et seq.

WARNING

Applies to

Tentative submission email

Must include

case number

The submit-on-tentative email must include the case number, identify the party submitting on the tentative, and copy opposing counsel.

The email must include the case number and identify the party submitting on the tentative with a copy (cc) to opposing counsel.

WARNING

Applies to

Declaration of service efforts

If any defendant remains unserved, plaintiff or plaintiff's counsel must submit a declaration to the court explaining what service efforts have been undertaken.

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.

WARNING

Applies to

Case management conference addendum

d. If so, what is the basis for the claim? e. Is there a claim for per se negligence? f. Is there a claim for violations of the vehicle code? g. If so, what section of the vehicle code? h. Will the defendant admit liability? i. Are there any criminal charges pending or contemplated? j. Is there a criminal investigation on-going?

d. If so, what is the basis for the claim? e. Is there a claim for per se negligence? f. Is there a claim for violations of the vehicle code? g. If so, what section of the vehicle code? h. Will the defendant admit liability? i. Are there any criminal charges pending or contemplated? j. Is there a criminal investigation on-going?

WARNING

Applies to

Proposed jury instructions

When an appropriate CACI instruction exists on a point of law, the court expects the parties to request it instead of a specially prepared instruction.

If there is an appropriate CACI jury instruction on a point of law, the court expects the parties to request the CACI instruction instead of a specially prepared jury instruction.

WARNING

Applies to

Motion in limine opposition and reply papers

Must include

caption

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

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

WARNING

Applies to

Motion in limine

Must include

caption

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

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

WARNING

Applies to

Joint chart of page and line designations

The Joint Chart must include specified columns for both designations (witness name/number, date and type of testimony, page/line designations, objections, counter-designation info, and court ruling) and counter-designations (witness name/number, date and type of testimony, page/line counter-designations, objections, related designation number, and court ruling).

In the joint chart, each designating party's designations of deposition or former testimony shall include columns which state: (1) the designation number and name of the witness, (2) the date and type of testimony (e.g., deposition or trial testimony), (3) the page and line designations of the deposition or former testimony requested to be used, (4) any objections, (5) whether the other party has counter-designated any additional deposition or former testimony of the witness that relates to the designation, and, if so, the designation number of the counter-designation, and (6) the court's ruling. 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.

WARNING

Applies to

Jury instructions

Proposed jury instructions must be grouped behind Tab F in order (labeled by cover sheets): agreed-upon instructions, plaintiff's contested requests, then defendant's contested requests.

The parties shall organize proposed jury instructions into groups behind Tab F in the following order (labeled by cover sheets): (1) the agreed-upon instructions, (2) plaintiff’s requested instructions to which defendant objects, and (3) defendant’s requested instructions to which plaintiff objects.

WARNING

Applies to

Special verdict form

Where an appropriate CACI special verdict form exists, the court expects the parties to use it for causes of action, affirmative defenses, or other findings.

there is an appropriate CACI special verdict form for a cause of action, affirmative defense, or other finding, the court expects the parties to use the CACI special verdict form.

WARNING

Applies to

Trial binder

In bench trials (trial by the court without a jury), the Trial Binder includes only Tabs A, B, C, H, and I, with the other sections left empty.

(for trials by the court without a jury, the Trial Binder shall include only the documents listed under Tabs A, B, C, H, and I with the other sections left empty):

WARNINGCivil cases

Applies to

Trial brief

Trial briefs are optional (appreciated but not required) at the case management conference, but if submitted they must include a statement of facts with expected evidence and pertinent law on all causes of action and affirmative defenses.

The court appreciates trial briefs at or before the time for appearance at the case management conference, but such briefs are not required. If provided, the brief is to include a statement of the facts with a summary of what it is expected the evidence will show along with all pertinent law in support of and/or against all cause of action contentions as well as with respect to affirmative defense matters.

WARNINGCivil cases

Applies to

Jury instructions

The court strongly prefers BAJI jury instructions over CACI.

The court has a strong preference for BAJI Instructions, not CACI.

WARNINGCivil cases

Applies to

Motion in limine

Motions in Limine will be heard at the FSC, and when more than one is filed, each must be numbered consecutively.

Motions in Limine will be heard at the FSC. If more than one motion in limine is filed, each shall be numbered consecutively.

WARNINGCivil cases

Applies to

Opposition

Opposition papers to motions in limine must include the number of the motion they respond to.

Opposition papers shall include the number of the motion to which it responds.

WARNING

Applies to

Stipulations

Parties are encouraged to stipulate to undisputed facts, and such stipulations should be reduced to writing, filed with the Court, and included in the trial binder if reached before trial.

The Court encourages the parties to narrow the scope of triable issues by reaching stipulations as to certain undisputed facts. Such stipulations should be reduced to writing and filed with the Court. They should also be included in the trial binder, if reached before trial.

WARNING

Applies to

Trial brief

These briefs should include a description of the claims, defenses, relief sought, evidentiary disputes, and all issues to be decided at trial along with a discussion of any novel or unusual issues of law, with citations to supporting authorities.

These briefs should include a description of the claims, defenses, relief sought, evidentiary disputes, and all issues to be decided at trial along with a discussion of any novel or unusual issues of law, with citations to supporting authorities.

WARNING

Applies to

Notice of ruling

Upon receiving such notice, the tentative ruling will become the order of the Court and the prevailing party shall give notice of the ruling.

Upon receiving such notice, the tentative ruling will become the order of the Court and the prevailing party shall give notice of the ruling.

WARNING

Applies to

Trial brief

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

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

WARNING

Applies to

Impeachment exhibits

Each party should pre-mark five copies of all impeachment exhibits with pages paginated by exhibit and page number for use during cross-examination.

In preparation for cross-examination of witnesses, each party should pre-mark five copies of all impeachment exhibits with each page properly paginated to reflect the exhibit number and page number so that they are ready for distribution during cross-examination.

WARNING

Applies to

Joint statement of case

For jury trials, the parties must jointly prepare a short, non-argumentative written statement of the case to be read to the jury.

JOINT STATEMENT OF THE CASE TO BE READ TO THE JURY. A jointly prepared, short, non-argumentative written statement of the case to be read to the jury. Local Rule 3.25 (g)(4).

WARNING

Applies to

Initial discovery disclosures

Civil actions filed after January 1, 2024 are subject to the initial discovery disclosure requirements of CCP § 2016.090, enforceable by the court on its own or a party's motion, except that the requirement does not apply to self-represented parties.

All civil actions filed after January 1, 2024, are subject to the initial discovery disclosures requirements of CCP § 2016.090. The Court may enforce the requirements of Section 2016.090 on its own motion or on the motion of a party. ... This section does not apply to any party who is self-represented.

WARNING

Applies to

Motion

Must include

proposed order

It is the Court's desire, if possible, that all motions concerning a matter be heard on the same date. If you have motions reserved under the Court Reservation System (CRS) for multiple hearing dates, please submit a proposed order for the motions to be heard on one date. Make sure the motions are reserved on the Court Reservation System (CRS) before you submit a proposed order.

It is the Court's desire, if possible, that all motions concerning a matter be heard on the same date. If you have motions reserved under the Court Reservation System (CRS) for multiple hearing dates, please submit a proposed order for the motions to be heard on one date. Make sure the motions are reserved on the Court Reservation System (CRS) before you submit a proposed order.

WARNING

Applies to

Transcripts

Counsel must provide the Court with transcripts at the FSC; failure to do so may result in continuance of the FSC and/or trial or exclusion of the prior testimony.

A failure to provide the Court with transcripts at the FSC may result in continuance of the FSC and/or trial, or the exclusion of the prior testimony.

WARNING

Applies to

Joint witness list

Plaintiff's witnesses must be listed first on the joint witness list, followed by defendant's witnesses, each preferably in the order they will be called.

Plaintiff’s witnesses shall be listed first and preferably in the order in which they will be called. Defendant’s witnesses shall follow and, similarly, in the order in which they will be called.

WARNING

Applies to

Motion in limine opposition and reply

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

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

WARNING

Applies to

Special verdict form

When a special verdict form is requested, the parties are expected to use the appropriate CACI special verdict form if one exists.

When a special verdict form is requested, if there is an appropriate CACI special verdict form for a cause of action, affirmative defense, or other finding, the Court expects the parties to use the CACI special verdict form.

WARNING

Applies to

Jury instructions

Counsel should prepare the instructions jointly and in compliance with the court’s FSC Order.

Counsel should prepare the instructions jointly and in compliance with the court’s FSC Order.

WARNING

Applies to

FSC notebook

Must include

case number

Parties must label the face and spine of the FSC Notebook with the case name, case number, FSC hearing date, and trial date.

The parties are to label the face and the spine of the Notebook with the case name, case number, FSC hearing date and Trial date.