Los Angeles Superior Court Document Filing Requirements

WARNING

Applies to

Jury instructions

Department 407 has a CACI Jury Instruction Order that directs counsel to organize the CACI jury instruction in a logical sequence. Counsel and self-represented litigants should review this Order prior to the FSC and prepare their jury instructions in compliance with the Order.

Department 407 has a CACI Jury Instruction Order that directs counsel to organize the CACI jury instruction in a logical sequence. Counsel and self-represented litigants should review this Order prior to the FSC and prepare their jury instructions in compliance with the Order.

WARNING

Applies to

Joint exhibit list

The parties must confer to resolve objections to each exhibit's admissibility and should discuss exhibits early rather than waiting until the last minute, which may eliminate the need for foundational witnesses.

confer to resolve objections to the admissibility of each exhibit. Do not wait until the last minute to discuss the exhibits. By discussing the exhibits early on, the parties may be able to eliminate the need to call unnecessary witnesses, such as foundational witnesses (i.e., custodians of record).

WARNING

Applies to

Joint exhibit list

At the FSC, each of the first six categories on the chart should have already been completed, leaving only the last three categories open for the Court to complete. The Court will go over the exhibits with counsel at the FSC. The Court will focus primarily upon any exhibit for which an objection is noted.

At the FSC, each of the first six categories on the chart should have already been completed, leaving only the last three categories open for the Court to complete. The Court will go over the exhibits with counsel at the FSC. The Court will focus primarily upon any exhibit for which an objection is noted.

WARNING

Applies to

Jury instructions

Agreed-upon jury instructions must be listed in the face-sheet index.

Agreed upon instructions should be included in the face-sheet index.

WARNING

Applies to

Jury instructions

The sequence of instructions is identified below. The index/list of instructions and the instructions themselves should follow this sequence. Of course, instructions are to be included or excluded as appropriate for each case.

The sequence of instructions is identified below. The index/list of instructions and the instructions themselves should follow this sequence. Of course, instructions are to be included or excluded as appropriate for each case.

WARNING

Applies to

Special jury instructions

Special jury instructions must include citations to the authority on which they are based.

Any special instructions must include citations to the authority on which the instructions are based.

WARNING

Applies to

Final status conference binders

Department 407 has a Final Status Conference Order that is filed in every case set for trial. A copy of the Order is attached. The Court expects counsel and self-represented litigants to work together to prepare and submit jointly the binders required by the Order.

Department 407 has a Final Status Conference Order that is filed in every case set for trial. A copy of the Order is attached. The Court expects counsel and self-represented litigants to work together to prepare and submit jointly the binders required by the Order.

WARNING

Applies to

Jury instructions

Disputed jury instructions must be listed on a separate face-sheet index identifying the specific instructions in dispute.

Instructions that are not agreed upon should be listed on a separate instruction face-sheet index along with the specific instructions that are the subject of disagreement.

WARNING

Applies to

Fsc notebook

Bench trials are exempt from including Tabs C and H in the FSC Notebook, but all other items identified in Sections III and IV must still be provided to the Court.

For bench trials, the parties do not need to include Tabs C and H listed in Section III in the FSC Notebook. Everything else identified in Sections III and IV must be provided to the Court.

WARNING

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 them consecutively.

WARNING

Applies to

Trial brief

Each party's trial brief must succinctly identify the claims and defenses, legal and factual issues with supporting authorities, relief and damages calculation, stipulated facts, anticipated evidentiary issues, and other information helpful to the Court.

Each party shall file a trial brief succinctly identifying: (1) the claims and defenses subject to litigation; (2) the legal and factual issues to be decided (with supporting points and authorities); (3) the relief claimed and the calculation of damages sought; and (4) the ultimate facts or issues to which you will stipulate; (5) the major evidentiary issues anticipated; and (6) any other information that may assist the Court at trial.

WARNING

Applies to

Motion in limine

Must include

caption

Each motion in limine's 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.

WARNING

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.

WARNING

Applies to

Joint statement

The IDC joint statement must summarize the nature of the dispute, the necessity for the discovery, the basis for any objection, and the status of discovery, grouping the discovery by issue if possible.

At least seven (7) calendar days before the IDC, the parties and counsel shall file a joint statement that succinctly summarizes the nature of the dispute, the necessity for the discovery, the basis for any objection or withholding of information, and the overall status of discovery. Please group the identified discovery by issue in dispute, if possible.

WARNING

Applies to

Opposition and reply brief

Must include

caption

Opposition and reply briefs on motions in limine must identify the corresponding motion number in the caption of their pages.

Parties filing opposition and reply briefs shall identify the corresponding motion number in the caption of their pages for the Court to read to the jury.

WARNING

Applies to

Joint trial documents

If an opposing counsel or party refuses to cooperate in the filing of joint trial documents, the party should file the trial documents unilaterally, along with a declaration stating the attempts made by the party to file jointly trial documents and the refusal of the other party to cooperate.

If an opposing counsel or party refuses to cooperate in the filing of joint trial documents, the party should file the trial documents unilaterally, along with a declaration stating the attempts made by the party to file jointly trial documents and the refusal of the other party to cooperate.

WARNING

Applies to

Ex parte application

Ex parte applications should be noticed for the 1:30 p.m. hearing time in Department 633.

Pursuant to the Fifth Amended Standing Order (effective June 1, 2021), ex parte applications should be noticed for 1:30 p.m. in Department 633.

WARNINGCivil cases

Applies to

Stipulation

The court requests that all parties sign and file a general stipulation, using language similar to Item 5 of Optional Form LACIV 036, tolling the discovery motion filing deadline between the request for and holding of a conference.

To avoid issues with jurisdictional filing deadlines, the court requests that all parties sign and file a general stipulation containing language similar to that of Item 5 in Optional Form LACIV 036, tolling the deadline to file any discovery motion during the period between the date a conference is requested and the date that conference is held.

WARNINGCivil cases

Applies to

Separate statement

Where counsel intends to move for summary adjudication in the alternative, the court asks counsel not to repeat verbatim facts that were previously given or to re-start the numbering sequence for each issue. Counsel should simply list the relevant repeated facts by number and incorporate them by reference beneath each issue heading.

Where counsel intends to move for summary adjudication in the alternative, the court asks counsel not to repeat verbatim facts that were previously given or to re-start the numbering sequence for each issue. Counsel should simply list the relevant repeated facts by number and incorporate them by reference beneath each issue heading.

WARNINGCivil cases

Applies to

Exhibits

For exhibits a party intends to admit into evidence, the party must indicate the moving party, stipulations on admissibility, or the basis for any objection.

For exhibits a party intends to admit into evidence, please indicate the moving party, stipulations on admissibility, and if not, the basis for any objection i.e., authentication, hearsay, etc.

WARNING

Applies to

Joint witness list

The Joint Witness List must identify each witness by name, estimate direct/cross/redirect examination lengths, and include total hours for all witness testimony.

The Joint Witness List shall identify each witness by name and estimate the length of the direct, cross, and redirect examination of each witness, and include a total number of hours for all witness testimony.

WARNING

Applies to

Opposition

Opposition papers to a motion in limine must include the number of the motion they oppose.

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

WARNING

Applies to

Declaration

The declaration regarding unserved defendants must explain why service has not been completed.

If any Defendants have not been served, Plaintiff or Plaintiff's Counsel must submit a declaration to the Court seven (7) days prior to the hearing explaining why service has not been completed

WARNING

Applies to

Case management statement

The Case Management Statement must be submitted on Judicial Council Form CM-110.

The parties and counsel shall file a Case Management Statement using Judicial Council Form CM-110 no later than fifteen (15) calendar days before the date set for the conference.

WARNING

Applies to

Motion in limine

Multiple motions in limine must be numbered consecutively.

If more than one Motion in Limine is filed, each shall be numbered consecutively.

WARNING

Applies to

Idc joint statement

The joint statement should consist of a narrative description of the dispute and meet and confer efforts and must not simply reproduce the disputed discovery requests and responses thereto.

The joint statement should consist of a narrative description of the dispute and meet and confer efforts and must not simply reproduce the disputed discovery requests and responses thereto.

WARNING

Applies to

Idc request stipulation

Must include

proposed order

IDCs are scheduled only on the parties' joint request, which must be made by filing a stipulation and proposed order.

An IDC will only be scheduled pursuant to a joint request by the parties. All lDC requests must be made through the filing of a stipulation and proposed order.

WARNING

Applies to

Idc request stipulation

The IDC stipulation must represent that the IDC will assist in resolving the discovery issues, failure to meet and confer is grounds for cancellation or continuance, and the stipulation may also request tolling of discovery motion deadlines.

The stipulation must contain the representations of the IDC will assist in resolving their discovery issues. A failure to meet and confer before an IDC is grounds for the Court to cancel or continue the IDC. A stipulation requesting an IDC may also include a request that the Court toll the deadline for filing discovery motions on issues encompassed by the IDC. (See Code of Civil Procedure § 2016.080(c)(2)).

WARNING

Applies to

Proposed voir dire questions

The list of proposed additional questions should be included in the Trial Binder

The list of proposed additional questions should be included in the Trial Binder

WARNING

Applies to

Trial binder

The Trial Binder should include trial briefs (optional), motions in limine, and (in jury trials) the Joint Statement of the Case, Joint Witness List, and Joint Exhibit List.

To be helpful to the Court, the Trial Binder should include: Trial Briefs (optional but appreciated); Motions in limine; (Jury Trials Only) Joint Statement of the Case; Joint Witness List; Joint Exhibit List

WARNING

Applies to

Song beverly discovery production

In Song-Beverly Warranty Act and related cases, the Court will usually order production of ten categories of documents (purchase/lease contracts, repair orders and invoices, dealer/factory/call-center communications, warranty claims, Warranty Policy and Procedure Manuals, internal defect analyses, customer complaints, repurchase evaluation policies, Technical Service Bulletins/recall notices, and documents supporting damages claims) unless case-specific reasons justify deviation.

For Song-Beverly Warranty Act and related cases, the Court will usually order the parties to produce copies of the following documents unless there are case-specific reasons to deviate from the list:

WARNING

Applies to

Remote appearance request

Parties must file the appropriate form(s) to request a remote appearance.

Parties must comply with applicable law and rules like the requirement to file the appropriate form or forms to request a remote appearance. (See, e.g., California Rules of Court, rule 3.672, Code of Civil Procedure § 367.75.)

WARNING

Applies to

Jury instructions

Proponents of pattern jury instructions must indicate whether the instructions have been modified.

Proponents of pattern jury instructions must note if they have been modified.

WARNING

Applies to

Trial binder

NOTE: All self-represented parties and counsel should strive to reach stipulations regarding all relevant facts that are not in dispute. These stipulations must be clearly documented and included in the Trial Binder.

NOTE: All self-represented parties and counsel should strive to reach stipulations regarding all relevant facts that are not in dispute. These stipulations must be clearly documented and included in the Trial Binder.

WARNING

Applies to

Informal discovery conference request

Informal discovery conference requests must be made using form LACIV 094 with a hearing date reserved on the Court Reservation System.

To request an informal discovery conference, you must use Los Angeles Superior Court form LACIV 094, and reserve a hearing date on the Court Reservation System.

WARNING

Applies to

Jury instructions

Proposed jury instructions must be prepared on LASC LACIV 129 form or in a Word document in the same format.

The proposed jury instructions shall be prepared on Los Angeles Superior Court form LASC LACIV 129 or in a Word document that is in the same format.

WARNING

Applies to

Deposition transcript

Parties must submit the designated or counter-designated transcript pages with numbered tabs separating each transcript, with each party's designations highlighted in a different color.

The parties shall submit copies of the pages of the transcripts of the deposition or former testimony they are designating or counter-designating 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.

WARNINGCivil cases

Applies to

Joint appendix

In traditional mandamus cases, the parties must meet and confer to determine whether they can agree upon a joint appendix.

The parties shall meet and confer to determine whether they can agree upon a joint appendix.

WARNINGCivil cases

Applies to

Administrative record

In administrative mandamus and traditional mandamus review of quasi-legislative agency actions, the parties must comply with Local Rule 3.231(g)'s requirements for preparing and submitting the record.

For administrative mandamus or for traditional mandamus review of quasi- legislative agency actions, the parties shall comply with Local Rule 3.231(g)’s requirements for preparation and submission of the record.

WARNINGCivil cases

Applies to

Traditional mandamus evidence

Evidence for a petition for traditional mandamus must be prepared and submitted in compliance with Local Rule 3.231(h).

The parties shall comply with Local Rule 3.231(h) when preparing and submitting evidence for a petition for traditional mandamus.

WARNINGCivil cases

Applies to

Settlement agreement

Parties should document any settlement agreement in a writing signed by all parties, whether the settlement occurs before or at the scheduled MSC.

The parties should also document their settlement agreement in a writing signed by all parties whether before or at the scheduled MSC.

WARNINGCivil cases

Applies to

Joint idc statement

Joint IDC Statements must identify the disputed discovery request, the last iteration of the response, and each side's factual discussion of sufficiency.

The Statements should identify the specific discovery request in dispute, the last iteration of a response, and a factual discussion by each side as to why the response is or is not sufficient.

WARNINGCivil cases

Applies to

Next day witness list

At the end of each court day, counsel must advise opposing counsel of the witnesses to be called the next day and the order of their testimony.

At the conclusion of each court day, counsel must advise opposing counsel of the witnesses to be called the next day and the order in which they will testify. (LASCR 3.81.)

WARNINGCivil cases

Applies to

Case management conference statement

Case Management Conference Statements (preferably joint) must describe the nature of the case, when discovery will be completed, and any agreements the parties have reached.

The parties must then file Case Management Conference Statements fifteen days prior to the Case Management Conference (preferably a joint statement), describing the nature of the case, when discovery will be completed ("per code" or "TBD" does not assist the Court in assigning a trial date for your case), and any agreements the parties have reached (see 19(b) of the Statement).

WARNING

Applies to

Stipulation and proposed order

Must include

proposed order

The court will consider referring the parties to a mandatory settlement conference if counsel file a stipulation and proposed order seeking one.

The court will consider referring the parties to a mandatory settlement conference, if counsel file a stipulation and proposed order seeking a mandatory settlement conference..

WARNING

Applies to

Proposed order

Must include

proposed order

If you have motions reserved under the Court Reservation System 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 before you submit a proposed order.

If you have motions reserved under the Court Reservation System 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 before you submit a proposed order.

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 case management conference, including the allocation of 1 day for jury selection and 1 day for deliberations. For example, a 5 day trial estimate means no more than 3 days of testimony.

Absent good cause, the total number of hours listed for testimony should not exceed the trial estimate given at the case management conference, including the allocation of 1 day for jury selection and 1 day for deliberations. For example, a 5 day trial estimate means no more than 3 days of testimony.

WARNING

Applies to

Joint statement to jury

The joint short statement to be read to the jury should be a brief, neutral case description not exceeding 2-3 paragraphs in most instances.

This statement should be a brief, neutral description of the case. In most instances, it should not exceed 2-3 paragraphs.

WARNING

Applies to

Motion

Must include

proposed order

If you have motions reserved under the Court Reservation System 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 before you submit a proposed order.

If you have motions reserved under the Court Reservation System 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 before you submit a proposed order.

WARNING

Applies to

Joint trial documents

If a party fails to meaningfully participate in preparing joint trial documents, the documents prepared by the participating party will become the operative trial binder.

If, prior to the date of trial, any party fails to meaningfully participate in the preparation and submission of joint trial documents, the trial documents prepared and submitted by the Court by the party seeking to fulfill their meet and confer obligations will be the operative trial binder