Los Angeles Superior Court Document Filing Requirements

WARNING

Applies to

Court reporter form

Parties using a court reporter must file Form LACIV237 (reporter listed on the Pro Tempore Directory) or Form LACIV236 (reporter not listed) in the courtroom before the judge calls the case.

The following forms must be filed in the courtroom prior to the judge calling your case: Form LACIV237, if the court reporter is listed on the court's Pro Tempore Court Reporter Directory; or, Form LACIV236, if the court reporter is not listed on said directory.

WARNING

Applies to

Motion in limine

Counsel filing a motion in limine must have a good faith belief that the matter addressed will actually be at issue in the case.

Counsel filing a motion in limine must have a good faith belief that the matter addressed in the motion shall actually be at issue in the case.

WARNING

Applies to

Joint exhibit list

Counsel and self-represented parties must meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit.

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

WARNING

Applies to

Joint witness list

The joint witness list must state estimated times for all witnesses' testimony and the grand total in hours in the last column.

estimated times for all witnesses' testimony and state the grand total in the last column (in hours).

WARNING

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 them consecutively.

WARNING

Applies to

Exhibits

Separate documents and photographs may not be grouped into one exhibit and must each bear their own exhibit number.

Separate documents and photographs shall not be grouped into one exhibit, but must be separately numbered with their own exhibit number.

WARNING

Applies to

Joint exhibit list

The parties must eliminate duplicate exhibits even where they bear different numbers assigned by each party.

The parties shall eliminate duplicate exhibits which may bear different numbers from each party.

WARNING

Applies to

Proposed jury instructions

Where an appropriate CACI instruction exists on a point of law, the court anticipates the parties will request the CACI instruction instead of a specially prepared instruction.

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

WARNING

Applies to

Case management statement

Issues of service or prosecution should be addressed in the CMC statement.

Issues of service or prosecution should be addressed in the CMC statement.

WARNING

Applies to

Exhibits

Each page of all multi-page exhibits must be separately numbered.

All multi-page exhibits must have each page separately numbered.

WARNINGCivil cases

Applies to

Trial brief

Trial briefs should describe the facts, remaining causes of action, parties' status, defenses, anticipated legal issues with points and authorities, and the relief claimed.

A trial brief should contain a brief description of the facts, remaining cause of actions, parties’ status (dismissed, defaulted, etc.), brief description of defenses, list of legal issues anticipated with points and authorities supporting and defending the issues, a brief statement of the relief claimed and

WARNINGCivil cases

Applies to

Joint statement of case

Counsel must meet and confer to prepare a joint, neutral, plain-English statement of the case (unless all parties agree to mini-opening statements) that should not exceed 2-3 paragraphs.

JOINT SHORT STATEMENT OF THE CASE TO BE READ TO THE JURY. Unless all parties agree to mini-opening statements; counsel shall meet and confer with opposing counsel to prepare a brief, neutral description of the case. See, LASCR 3.25(g)(4). The statement should inform the jury about the parties and their claims, without favoring one side, and gives jurors reasons why they would want to serve on your case. The statement should be in plain English, not expound legal theories, or be factual advocacy for either side. In most instances, it should not exceed 2-3 paragraphs.

WARNINGCivil cases

Applies to

Joint verdict form

Parties should seek agreement on a joint verdict form, and any special verdict should be easy for the jury to use without unnecessary questions.

JOINT PROPOSED VERDICT FORM. The parties should seek to reach agreement on a joint verdict form. See, LASCR 3.25(g)(8). Any proposed special verdict should be in a form that is easily used by the jury, and which does not require the jury to answer unnecessary questions.

WARNINGCivil cases

Applies to

Joint exhibit list

The joint exhibit list must list exhibits to be offered using consecutive arabic numerals. See, LASCR 3.52 and 3.53. Documentary exhibits consisting of more than one page should be internally paginated in sequential numerical order to facilitate reference to the document during interrogation of witnesses (e.g., 1-2, 1-2, 1-3). Counsel should agree in advance that their respective party will have a range of exhibit numbers, e.g., Plaintiff 1-99; Defendant 100-199.

The joint exhibit list must list exhibits to be offered using consecutive arabic numerals. See, LASCR 3.52 and 3.53. Documentary exhibits consisting of more than one page should be internally paginated in sequential numerical order to facilitate reference to the document during interrogation of witnesses (e.g., 1-2, 1-2, 1-3). Counsel should agree in advance that their respective party will have a range of exhibit numbers, e.g., Plaintiff 1-99; Defendant 100-199.

WARNINGCivil cases

Applies to

Joint witness list

Absent good cause, total listed testimony hours may not exceed the trial estimate from the case management conference, reserving 1 day for jury selection/motions in limine and 1 day for deliberations (e.g., a 5-day estimate allows 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 motions in limine and 1 day for deliberations. For example, a 5-day trial estimate means no more than 3 days of testimony.

WARNING

Applies to

Joint summary of testimony and evidence

If no court reporter is provided, the parties must provide a joint summary of the testimony and evidence admitted each day for the court's use in preparing a settled statement on appeal.

Should the parties not provide a court reporter, the parties will be required to provide a joint summary of the testimony and evidence admitted each day for the court's use in preparing a settled statement for appeal purposes.

WARNING

Applies to

Operative pleadings and stipulations

Trial Binder TAB J must contain the operative Complaint, Answer(s), Cross Complaint(s) and Answer(s), and Stipulation of Facts, each behind individual tabs.

Place behind individual tabs the operative Complaint; Answer(s); Cross Complaint(s) and Answer(s); and Stipulation of Facts.

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 California Rules of Court, rule 3.1200 et seq.

WARNING

Applies to

Settled statement

In trials without court reporters, parties must jointly prepare a daily settled statement of the testimony and a list of evidence admitted.

For trials without court reporters, parties will be ordered to jointly prepare a settled statement of the testimony and list of evidence admitted each day of the trial.

WARNING

Applies to

Remote appearance request

Parties must file the appropriate form or forms to request a remote appearance.

Nevertheless, 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

Ex parte notice

The ex parte notice must include the hearing details (date, time, location) and a statement of the relief sought.

The notice must include the hearing details (date, time, and location), and a statement of what relief the ex parte applicant is seeking.

WARNING

Applies to

Joint and disputed jury instructions list

The Joint and Disputed Jury Instructions List must follow Trial Preparation Order Exhibit 4 and be placed behind TAB F of the Trial Binder.

The Joint and Disputed Jury Instructions List shall be prepared in accordance with the instructions in the Trial Preparation Order, Exhibit 4 see attached below, and the list shall be included behind TAB F of the Trial Binder.

WARNING

Applies to

Proposed jury instructions

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. The proponent must signify if a submitted pattern jury instruction is modified.

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. The proponent must signify if a submitted pattern jury instruction is modified.

WARNING

Applies to

Request for court reporting services

The request must be made by using the local form, Request for Court Reporting Services by

The request must be made by using the local form, Request for Court Reporting Services by

WARNING

Applies to

Exhibit list

Any stipulations should be clearly noted on the Exhibit List. If the parties have stipulated to the admission of any exhibits, those exhibits will be admitted into evidence at the beginning of trial without the need for further motions.

Any stipulations should be clearly noted on the Exhibit List. If the parties have stipulated to the admission of any exhibits, those exhibits will be admitted into evidence at the beginning of trial without the need for further motions.

WARNING

Applies to

Jury instructions

The parties shall organize proposed jury instructions into groups behind Tab G in the following order (labeled by cover sheets): (1) the agreed-upon instructions, (2) plaintiff’s requested

The parties shall organize proposed jury instructions into groups behind Tab G in the following order (labeled by cover sheets): (1) the agreed-upon instructions, (2) plaintiff’s requested

WARNING

Applies to

Motion in limine

Each motion in limine must have a caption that concisely identifies 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

Jury instructions

A complete set of full-text joint and disputed jury instructions goes behind TAB G of the Trial Binder, organized behind tabs marked "Plaintiff's" and "Defendant's."

A complete set of the full text joint and disputed jury instructions shall be included behind TAB G of the Trial Binder. Please provide a tab marked "Plaintiff's" followed by those Jury Instructions proposed by Plaintiff and objected to by Defendant, then a tab marked "Defendant's," followed by those jury instructions proposed by Defendant and objected to by Plaintiff.

WARNING

Applies to

Motion in limine opposition or reply

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

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

WARNING

Applies to

Trial binder trial briefs tab

The Trial Briefs tab must state 'No Trial Briefs' if none were filed, or must identify the single brief filed (e.g., 'Plaintiff’s Trial Brief; No Defendant’s Trial Brief') if only one was submitted.

A Trial Briefs – Plaintiff’s Trial Brief; Defendant’s Trial Brief If no trial briefs, state “No Trial Briefs”– if only one brief filed, state, e.g., Plaintiff’s Trial Brief; No Defendant’s Trial Brief

WARNING

Applies to

Trial brief

TAB A: Trial Briefs (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

TAB A: Trial Briefs (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

WARNING

Applies to

Law and motion papers

Law and motion evidence must be by declaration or request for judicial notice (unless the Court orders otherwise for good cause), and oral testimony requires court permission supported by a statement filed under CRC 3.1306.

Unless the Court orders otherwise for good cause shown, evidence must be by declaration or request for judicial notice. (California Rules of Court, rule 3.1304.) Oral testimony will not be allowed without court permission. Parties seeking permission to introduce oral testimony must file a statement consistent with California Rules of Court, rule 3.1306. (Local Rule 3.7.)

WARNING

Applies to

Special verdict form

When a special verdict form is requested, parties are expected to use the applicable CACI special verdict form if one exists for the cause of action, affirmative defense, or finding.

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

Court reporter request form

The party securing a court reporter must provide the Judicial Assistant with the required completed form before the proceedings begin.

The party securing the court reporter must provide the Judicial Assistant with the required, completed form prior to the commencement of the proceedings.

WARNING

Applies to

Proposed verdict form

If the parties cannot agree on a Joint Verdict Form, separate proposed forms are permitted, each preceded by a page marked "Plaintiff's Proposed Verdict Form" or "Defendant's Proposed Verdict Form."

If the parties cannot agree on a Joint Verdict Form, or if the verdict form will depend upon circumstances at trial, separate proposed forms are permitted. In that case, each party's proposed form shall be preceded by a page marked, e.g., "Plaintiff's Proposed Verdict Form" or "Defendant's Proposed Verdict Form."

WARNING

Applies to

Protective order

Must include

proposed order

The Court prefers the LASC Form Protective Order available at LACourt.CA.gov. Notify the Court of any modifications to the terms of the LASC Form Protective Order by attaching a “redline” version of the proposed protective order.

The Court prefers the LASC Form Protective Order available at LACourt.CA.gov. Notify the Court of any modifications to the terms of the LASC Form Protective Order by attaching a “redline” version of the proposed protective order.

WARNING

Applies to

Motion in limine

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

Parties filing more than one 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

Special verdict form

When a special verdict form is requested, the court expects parties to use the applicable CACI special verdict form if one exists for the cause of action, affirmative defense, or other finding.

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

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

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

Non-documentary exhibits must be marked and a simple written description inserted behind the corresponding numerical tab in the Exhibit Binders.

The parties’ counsel and any self-represented parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the Exhibit Binders.

WARNING

Applies to

Proposed jury instructions

The court expects the parties to request the appropriate CACI jury instruction instead of a specially prepared instruction when one exists.

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

Exhibits

The court's yellow evidence tags (case number and exhibit number only) must be placed on each exhibit in the Judicial Assistant's Exhibit Binder copy.

The parties’ counsel and any self-represented parties shall also place the court’s yellow evidence tags (with only the case number and exhibit number filled in) on each exhibit in the Judicial Assistant’s copy of the Exhibit Binder.

WARNING

Applies to

Exhibits

The court's yellow evidence tags (with only the case number and exhibit number filled in) must be placed on each exhibit (sentence continues beyond this chunk).

The parties’ counsel and any self-represented parties shall also place the court’s yellow evidence tags (with only the case number and exhibit number filled in) on each exhibit in the Judicial

WARNING

Applies to

Final status conference documents

If the parties cannot cooperate on joint FSC documents, individual documents may be filed with a declaration explaining the difficulty.

If there is a lack of cooperation in preparing joint documents, file individual documents with a declaration explaining the difficulty.

WARNING

Applies to

Trial presentation

Parties must exchange any PowerPoint or similar trial presentation 3 court days before trial commences, with objections discussed at the FSC or first day of trial.

The parties must exchange any power-point or similar presentation 3 court days prior to commencement of trial; if a party objects, the matter will be discussed at the FSC or first day of trial.

WARNING

Applies to

Proposed juror questionnaire

A proposed juror questionnaire must be submitted with the FSC documents only if requested.

Proposed Juror Questionnaire, if requested

WARNING

Applies to

Joint status conference report

Joint status conference reports (JSR) are typically requested to address: status of service/answers/parties, discovery (what will be done/timeline), proposed ADR, whether significant motions are contemplated (e.g.: MSA/MSJ), proposed trial date.

Joint status conference reports (JSR) are typically requested to address: status of service/answers/parties, discovery (what will be done/timeline), proposed ADR, whether significant motions are contemplated (e.g.: MSA/MSJ), proposed trial date.

WARNINGCivil cases

Applies to

Proposed preference case trial setting order

The proposed Preference Case Trial Setting Order should, at a minimum, identify fact and expert discovery date cutoffs; summary judgment motion filing deadlines; schedule for exchange and submission of former testimony designations; agreements concerning any modification of notice and hearing timing

The proposed Preference Case Trial Setting Order should, at a minimum, identify fact and expert discovery date cutoffs; summary judgment motion filing deadlines; schedule for exchange and submission of former testimony designations; agreements concerning any modification of notice and hearing timing

WARNINGCivil cases

Applies to

Joint separate statement

The joint separate statement must be a separate self-contained document filed and served with the discovery motion, full and complete on its face, with no material incorporated by reference.

The joint separate statement is a separate document filed and served with the discovery motion that provides all the information necessary to understand each discovery request and all the responses to it that are at issue. The joint separate statement must be full and complete so that no person is required to review any other document in order to determine the full request and the full response. Material must not be incorporated into the joint separate statement by reference.