Los Angeles Superior Court Document Filing Requirements

WARNINGCivil cases

Applies to

Stipulation

Stipulations served via FSX must use an 's/___' signature block for each attorney, and the serving party certifies each signatory's agreement and authority, retaining records of concurrence for production to the Court upon order.

The serving party of any stipulation, using an “s/___” signature block for each attorney. By submitting such a document, the serving party certifies that each signatory has expressly agreed to the form and substance of the document, and that the serving party has the authority and consent to submit the document electronically. The serving party shall retain any records evidencing such concurrence for the production to the Court upon order.

WARNINGCivil cases

Applies to

Motion in limine

Motions in Limine must be accompanied by corresponding oppositions and replies as part of the trial submissions.

Motions in Limine with corresponding oppositions and replies.

WARNINGCivil cases

Applies to

Pleading

Pleadings must set forth "Coordination Proceeding" and "SILICOSIS CASES" in bold in the caption.

set forth Coordination Proceeding, and "SILICOSIS CASES" in bold;

WARNINGCivil cases

Applies to

Motion in limine

Certain specified motions in limine topics are deemed made and granted automatically, subject to the court's modification in a particular case for good cause.

The following motions in limine to exclude, limit, or modify potential evidence or argument are deemed made and granted as to the topic noted, subject to the court’s modification in a particular case for good cause shown:

WARNINGCivil cases

Applies to

Notice of deposition in non standard setting

If a deposition must occur in a non-standard setting (e.g., a hospital or a residence), seven days' advance notice is required, and the notice must contain details on accessibility and specific technological needs.

Notice of Unique Settings. Seven (7) days’ advance notice is required if a deposition must occur in a non-standard setting, such as a hospital or a person’s residence. Such notice shall contain details on accessibility and on specific technological needs for the deposition.

WARNINGCivil cases

Applies to

Objections and responses

Objections and responses must be as specific as possible; vague or unspecific objections or responses may be treated as waived.

Objections and responses to objections should be as specific as possible. Vague and unspecific objections or responses thereto may be treated as being waived. In order to avoid the court treating an objection as being conceded, the responding party should respond to the

WARNINGCivil cases

Applies to

Plaintiff fact sheet

The Plaintiff Fact Sheet must include a signed and dated declaration under penalty of perjury under California law attesting that the information provided is true and correct.

I declare under penalty of perjury under the laws of the State of California that the information provided in this Plaintiff Fact Shect is true and correct to the best of my knowledge, information, and belief at this time.

WARNINGCivil cases

Applies to

Deposition designation

Tier One designations are testimony a party in good faith believes with certainty will be used in its case in chief, and the Coordination Trial Judge rules on them before the case is assigned for trial.

Tier One designations are those designations of testimony that a party, in good faith, believes with certainty will be used in its case in chief. The Coordination Trial Judge will rule on Tier One designations prior to the case being assigned for trial.

WARNINGCivil cases

Applies to

Expert witness materials

General materials and case-specific documents relied upon by experts must be identified on indices, with copies of the documents promptly produced upon request.

All general materials and case specific documents relied upon by the experts shall be identified on indices, with copies of the documents promptly produced upon request.

WARNINGCivil cases

Applies to

Joinder

When seeking to file a joinder, the parties should advise the court which joinder.

When seeking to file a joinder, the parties should advise the court which joinder.

WARNINGCivil cases

Applies to

Pleading

Pleadings must identify the name of the pleading in bold on the right side, under the words Case Number.

identify the name of the pleading in bold on the right side, under the words Case Number;

WARNINGCivil cases

Applies to

Joint witness list

The Joint Witness List should include totals for witnesses actually expected to testify, covering plaintiff case total, defendant case total (direct and cross examination), and grand total for the entire case.

The Joint Witness list should include the totals for witnesses who are actually expected to testify, including total for plaintiff(s) case (direct and cross examination), total for defendant(s) case (direct and cross examination); and grand total for entire case.

WARNINGCivil cases

Applies to

Pleading

All other papers concurrently filed with the pleading must be identified in bolded brackets.

identify bolded in brackets all other papers concurrently being filed with the pleadings;

WARNING

Applies to

Trial documents

Counsel and self-represented parties must jointly prepare and submit the required trial documents and binders and meet and confer in good faith, with a possible exception for filing separately if another party will not cooperate (exception text truncated).

The court expects the parties' counsel and any self-represented parties to work together to jointly prepare and submit the required trial documents and binders in accordance with the Trial Preparation Order, and to meet and confer in good faith with respect to all trial documents. If after making a diligent effort a party is unable to obtain one or more other party's/parties' cooperation in the preparation and submission of joint trial documents as required herein, that party may submit

WARNING

Applies to

Exhibits

Photos within electronic media that are also marked with separate exhibit numbers must be printed out with an exhibit tag affixed to each.

If the flash drive is marked as an exhibit and any of the photos contained or presented within the electronic media are also marked with a separate exhibit number, then each of the marked photos must be printed out and have an exhibit tag affixed to each item.

WARNING

Applies to

Exhibit list

Flash drives containing photographs not individually marked as exhibits must be accurately described on the Exhibit List.

If the flash drive contains photographs that are not individually marked as an exhibit, it must be described accurately on the Exhibit List, for example Plaintiff's Exhibit 2 (flash drive containing 3 photographs).

WARNING

Applies to

Electronic media exhibits

The parties must comply with Paragraph 5 of the standing order regarding Electronic Media as Exhibits (content of that paragraph is outside this excerpt).

The parties are required to comply with Paragraph 5, infra, regarding Electronic Media as Exhibits.

WARNING

Applies to

Discovery motion declaration

The court generally finds meet-and-confer efforts consisting only of letters and e-mails insufficient; parties should describe their meet-and-confer efforts in any declaration supporting or opposing a discovery motion (sentence continues beyond the provided text).

The court generally finds that meeting and conferring by only exchanging letters and e- mails, as opposed to actual conversation, is insufficient and ineffective. Thus, the parties should indicate in any declaration filed in support of or in opposition to a discovery motion what efforts

WARNING

Applies to

Special verdict form

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

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

WARNING

Applies to

Motion in limine

Generic motions in limine that fail to identify the specific evidence to be excluded or seek merely declaratory rulings are disfavored (consequence truncated in source).

Motions in limine that are generic, do not identify the specific evidence sought to be excluded (e.g. exhibits, testimony and/or witnesses), seek rulings which would merely be declaratory of existing law or would not provide any meaningful guidance for the parties

WARNING

Applies to

Motion in limine

Uncontested motions in limine should be marked with the word 'uncontested' in the caption.

Uncontested motions should note "uncontested" in the caption.

WARNING

Applies to

Electronic media trial exhibit

The proffering party must ensure a method to promptly display electronic media trial exhibits in the jury room during deliberations upon the jury's request.

It is the proffering party's responsibility to ensure a method of promptly displaying any electronic media trial exhibit in the jury room during deliberations upon request of the jury.

WARNING

Applies to

Motion in limine

Parties and counsel are strongly discouraged from filing more than five contested motions in limine.

The parties/counsel are strongly discouraged from filing more than 5 contested motions in limine.

WARNING

Applies to

Motion in limine opposition and reply

Must include

caption

Opposition and reply papers must identify the corresponding motion in limine 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

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

Exhibits

All non-documentary exhibits must be marked and a simple written description inserted behind the corresponding numerical tab in the Exhibit Binders, with compliance with Paragraph 5 (electronic media).

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, and shall comply with Paragraph 5, irifra.

WARNING

Applies to

Exhibit list

If a flash drive is in an envelope, sleeve, or case, the Exhibit List description must state so.

If a flash drive is in an envelope, sleeve, or case, the description on the Exhibit List must state the following, Plaintiff's I - Flash drive in a white sleeve containing 5 photographs of the defendant.

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. Specially prepared jury instructions should be used sparingly and should not be repetitive of CACI instructions or argumentative in nature.

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. Specially prepared jury instructions should be used sparingly and should not be repetitive of CACI instructions or argumentative in nature.

WARNING

Applies to

Notice of related case

Parties must timely comply with California Rules of Court rule 3.300 regarding notice of related cases.

The Court requires timely compliance with California Rules of Court, rule 3.300 Re: Notice of Related Cases.

WARNING

Applies to

Joint documents

If the parties cannot cooperate on joint FSC documents, they must file individual documents with a declaration explaining the difficulty.

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

WARNING

Applies to

List of jury instructions

A list of jury instructions with a disposition table (instruction number, proposing party, and court disposition columns) must be filed.

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

WARNING

Applies to

Exhibits

Foreign-language exhibits must be accompanied by a certified English translation.

Exhibits written in a foreign language must be accompanied by a certified English translation. Cal. Rule of Court 3.1110(g).

WARNING

Applies to

Exhibits

All exhibits must be exchanged and pre-numbered, except exhibits anticipated in good faith for impeachment or rebuttal.

Pursuant to California Rule of Court 3.1110(f) and Los Angeles County Superior Court Rules 3.52 and 3.53, all exhibits must be exchanged and pre-numbered, except for those anticipated in good faith to be used for impeachment or during rebuttal.

WARNING

Applies to

Joint witness list

A joint witness list must be filed listing all witnesses once, with expected testimony time (direct, cross, re-direct) indicated for each witness.

Filed-Joint Witness List -- All witnesses must be listed on one list. Do not repeat the name of a witness. Indicate the total time expected for that testimony, including direct, cross, and re-direct. At the end of the list, state the total time estimated for each witness's testimony.

WARNING

Applies to

Proposed verdict form

verdict form, each party must submit their own proposed verdict form. Any proposed special verdict should be in a form that is easily used and understood by the jury, and which does not require the jury to answer unnecessary questions.

verdict form, each party must submit their own proposed verdict form. Any proposed special verdict should be in a form that is easily used and understood by the jury, and which does not require the jury to answer unnecessary questions.

WARNING

Applies to

Joint exhibit list

The exhibit list must identify the moving party, authentication and admissibility stipulations, and the basis for any objections, which the Court will likely rule on at the FSC.

For exhibits a party intends to admit into evidence, please indicate the moving party, stipulations on authentication in one column and stipulations on admissibility in the next column. If there are no objections, please state the basis for any objection i.e., hearsay, etc. The Court will likely rule on objections to admission of Exhibits at the Final Status Conference.

WARNING

Applies to

Joint exhibit list

The joint exhibit list must include columns for the date the exhibit was identified and the date it was admitted.

Filed-Joint Exhibit List -- include columns for DATE ID'd and DATE ADMITTED.

WARNING

Applies to

Demonstrative exhibits

Demonstrative exhibits not admitted into evidence must be shown to opposing counsel before use at trial, and objections must be raised before publication to the jury.

All demonstrative exhibits, not admitted into evidence, must be shown to the opposing party before use at trial. Any objections to the use of demonstrative exhibits must be brought to the court's attention in a timely manner and before publication to the jury.

WARNING

Applies to

Joint statement of the case

Filed-Joint Statement of the Case. This is brief, neutral description of the case to be read to the jury. In most instances, it should not exceed two paragraphs.

Filed-Joint Statement of the Case. This is brief, neutral description of the case to be read to the jury. In most instances, it should not exceed two paragraphs.

WARNING

Applies to

Motion in limine

The caption of each motion in limine 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

Special verdict form

When a special verdict form is requested, the court expects the parties to use the CACI special verdict form if an appropriate 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

Joint witness list

The joint witness list must use specified columns (witness name/expert status/accommodations, calling party, expected to testify, testimony description, estimated direct/cross/total examination hours) and end with a grand total of estimated testimony 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 hours). At the end of the joint witness list, the parties and any self-represented parties shall add up the estimated times for all witnesses’ testimony and state the grand total in the last column.

WARNING

Applies to

Motion in limine opposition and reply

Opposition and reply papers must identify the corresponding motion in limine 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

Joint chart of page and line designations

The Joint Chart of Page and Line Designations must include any objections, the designation number of the other party's designation being countered, and the court's ruling (partial list; earlier items appear on the prior page).

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

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

Proposed jury instructions

parties to request the CACI instruction instead of a specially prepared jury instruction.

parties to request the CACI instruction instead of a specially prepared jury instruction.

WARNING

Applies to

Proposed jury instructions

Proposed jury instructions must be grouped behind Tab F in this order: agreed-upon instructions, plaintiff's requested instructions to which defendant objects, and defendant's requested instructions to which plaintiff objects, each labeled by cover sheets.

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.

WARNINGCivil cases

Applies to

Verdict form

If counsel cannot agree on a verdict form in advance, alternative verdict forms should be submitted.

If counsel cannot agree in advance on a verdict form, alternative verdict forms should be submitted.

WARNINGCivil cases

Applies to

Jury instruction objections

Objections to jury instructions must be noted in a separate document filed for the court.

Be certain to note objections filed in a separate document for the court.

WARNINGCivil cases

Applies to

Joint trial documents

The court may, in its discretion, require an in-person meeting of counsel and joint trial documents (early submission of trial documents, joint jury statement, joint witness list, joint exhibit list, agreed jury instructions in proper format, and an agreed special verdict form with interrogatories).

S.C.L.A.C. Rule 3.25(g)(2)-(8) allows the court, in its discretion, to require: "an 'in person" meeting of counsel before the final status conference concerning the submission to the court of joint trial documents: the submission of trial documents to the court more than five days before the final status conference; a joint statement to be read to the jury; a joint witness list; a joint exhibit list; a set of agreed jury instructions (and, if necessary, a separate set of instructions to which there is disagreement), in the proper format with all changes and modifications applicable to the case in accordance with California Rules of Court, rule 2.1055, (i.e., correct references to the parties, no blanks, brackets, empty spaces, or inapplicable options); and an agreed special verdict form with interrogatories."