Los Angeles Superior Court Document Filing Requirements

WARNINGCivil cases

Applies to

Opposition

The opposing party should not only state the grounds for opposition in the caption but also provide the reasons for the opposition with pertinent legal authorities and factual reasons.

The opposing party should not only state the grounds for opposition in the caption but also provide the reasons for the opposition with pertinent legal authorities and factual reasons.

WARNINGCivil cases

Applies to

Witness list

Parties must make additional copies of the witness list for each juror and confer with opposing counsel about drafting a single witness list for trial.

Make additional copies of the witness list for each juror. Confer with opposing counsel regarding drafting a single list of witnesses for trial.

WARNINGCivil cases

Applies to

Motion in limine

The memorandum of points and authorities in support of the motion in limine should avoid boilerplate verbiage and citations. Vague motions to “exclude testimony” without specifics do not assist the Court. Use appropriate and brief citations to support legal authorities and evidence.

The memorandum of points and authorities in support of the motion in limine should avoid boilerplate verbiage and citations. Vague motions to “exclude testimony” without specifics do not assist the Court. Use appropriate and brief citations to support legal authorities and evidence.

WARNINGCivil cases

Applies to

Exhibit list

A copy of the exhibit list must be provided to each counsel, the court, and the clerk, and counsel must comply with the specified LACCR exhibit rules.

A copy of the exhibit list shall be provided to each counsel, the court, a n d the clerk of the court. Counsel shall comply with LACCR, Rules 3.52, 3.151, 3.53, 3.149, 3.150, and 3.152..

WARNINGCivil cases

Applies to

Concise joint statement

The concise joint statement is a brief neutral case description for the jury and should generally not exceed two paragraphs.

This is a brief, neutral description of the case to be read to the jury. In most instances, it should not exceed two paragraphs.

WARNINGCivil cases

Applies to

Motion in limine

Motions in limine should be submitted in a separate tabbed binder with a table of contents.

Motions in limine should be submitted in a separate tabbed binder with a table of contents.

WARNINGCivil cases

Applies to

Expert designations

Copies of all parties' expert designations must be submitted without attachments.

Provide a copy of all parties' expert designations without attachments.

WARNINGCivil cases

Applies to

Minor compromise petition

If the petition contends that the minor has fully recovered from the injuries, a medical record or declaration should be submitted supporting that contention.

If the petition contends that the minor has fully recovered from the injuries, a medical record or declaration should be submitted supporting that contention.

WARNING

Applies to

Special verdict form

When a special verdict form is requested, parties are expected 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

Idc request form

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, in requesting an IDC, the parties should indicate on their IDC forms what efforts were made to informally resolve pending discovery issues, which should include in-person or virtual meetings or telephonic communications.

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, in requesting an IDC, the parties should indicate on their IDC forms what efforts were made to informally resolve pending discovery issues, which should include in-person or virtual meetings or telephonic communications.

WARNING

Applies to

Jury instructions

When an appropriate CACI instruction exists, parties are expected to request it rather than a specially prepared instruction, and special instructions with out-of-context quotes or non-plain-English wording are usually inappropriate.

If there is an appropriate CACI jury instruction on a point of law, the court expects the parties to request the CACI instructions instead of a specially prepared jury instruction. The court rarely uses a special jury instruction on a topic covered by a CACI instruction. Special jury instructions that use quotes from appellate cases taken out of context, or that do not use plain English, are usually not appropriate.

WARNING

Applies to

Joint witness list

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

At the end of the joint witness list, the parties and any self-represented parties shall add up the estimated times for all witness testimony and state the grand total in the last column.

WARNING

Applies to

Jury instructions

Parties should not request CACI instructions that do not apply when trial begins (e.g., CACI 5013 applies only if there is a deadlocked jury).

The parties should not request CACI instructions that do not apply when the trial begins. For example, CACI 5013 shall not apply unless and until there is a deadlocked jury.

WARNING

Applies to

Joint statement

The joint statement to be read to the jury should usually be only a few sentences and written in plain English without legal jargon.

Rule 3.25, subd. (g)(4). A joint statement should usually be only a few sentences. It should be in plain English without legal jargon.

WARNING

Applies to

Stipulation and order re settlement conference with trial judge

A Stipulation and Order re Settlement Conference with Trial Judge, signed by all parties, is required for the court to conduct a mandatory settlement conference.

Upon stipulation of the parties, the court is also available to conduct mandatory settlement conferences. A Stipulation and Order re Settlement Conference with Trial Judge is required to be signed by all parties.

WARNING

Applies to

Joint witness list

Each witness entry on the joint witness list must include the estimated length of cross-examination and the total estimated length of examination, in hours (remaining required columns appear earlier in the order).

(6) an estimate of the length of cross-examination (in hours), and (7) the total estimated length of examination (in hours.

WARNING

Applies to

Trial preparation order documents

Department 516 will order compliance with a Trial Preparation Order, and counsel and self-represented parties are expected to jointly prepare and submit the required documents and binders.

Department 516 normally will order the parties' compliance with a Trial Preparation Order (example attached hereto). 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.

WARNING

Applies to

Joint exhibit list

The parties must confer in an effort to resolve objections to the authenticity and admissibility of each exhibit.

confer in an effort to resolve objections to the authenticity and admissibility of each exhibit.

WARNING

Applies to

Final status conference documents

Before the FSC, counsel must meet and confer to prepare jury instructions, verdict forms, a statement of the case, exhibits, exhibit lists, and witness lists, and attempt stipulations on ultimate facts and exhibit authenticity/admissibility.

Prior to the Final Status Conference, counsel are to meet and confer to exchange, discuss, and prepare for submission to the court the jury instructions, a verdict form or forms, a statement of the case, exhibits, exhibit lists, and witness lists. Counsel shall also attempt to reach stipulations with regard to ultimate facts and issues, and the authenticity/ admissibility of exhibits.

WARNING

Applies to

Joint chart deposition designations

Deposition or former trial testimony planned for impeachment purposes only does not need to be included in the joint chart.

The parties do not, however, need to include in the joint chart deposition testimony or former trial testimony they plan on using for impeachment purposes only.

WARNING

Applies to

Motion in limine

The parties should not file generic motions in limine untethered to actual anticipated disputes about evidence. Motions in limine that seek rulings “which would merely be declaratory of existing law” and do not include a discussion about the particular evidence the moving party seeks to exclude are not appropriate.

The parties should not file generic motions in limine untethered to actual anticipated disputes about evidence. Motions in limine that seek rulings “which would merely be declaratory of existing law” and do not include a discussion about the particular evidence the moving party seeks to exclude are not appropriate.

WARNINGCivil cases

Applies to

Special verdict form

When a special verdict form is requested, the parties are expected to use the applicable CACI special verdict form where 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.

WARNINGCivil cases

Applies to

Daily summary of proceedings

If no court reporter is used, parties must jointly prepare and lodge a daily summary of proceedings (including detailed witness testimony summaries) the next morning before proceedings resume.

If no court reporter is used, the parties must jointly prepare a summary of the day's proceedings, including a detailed summary of any witness testimony, and lodge the daily summary the next morning before J proceedings resume.

WARNINGCivil cases

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 two categories open for the Court to complete.

At the FSC, each of the first six categories on the chart should have already been completed, leaving only the last two categories open for the Court to complete.

WARNINGCivil cases

Applies to

Joint witness list

Expert witnesses must be identified as such, only witnesses who will actually be called should be listed, and plaintiff's witnesses are listed first followed by defendant's witnesses, each in the expected order of call.

A witness who is being called as expert must be identified as an expert. Counsel should include only those witnesses who are going to 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.

WARNINGCivil cases

Applies to

Stipulation

Stipulations should be reduced to writing and/or placed on the record to reduce misunderstandings among counsel.

Stipulations: Stipulations should be reduced to writing and/or placed on the record to reduce misunderstandings among counsel.

WARNING

Applies to

Trial preparation documents and binders

Department 510's Trial Preparation Order applies to every case set for trial, and counsel and self-represented parties are expected to jointly prepare and submit the documents and binders it requires.

Department 510 has a Trial Preparation Order that applies to every case set for trial. 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.

WARNING

Applies to

Joint chart deposition designations

Partial continuation of a rule requiring the Joint Chart designation columns to state whether there is a counter-designation, its designation number, and the court's ruling (start of sentence appears on the prior page).

designation, and, if so, the designation number of the counter-designation, and (6) the court's ruling.

WARNING

Applies to

Jury instructions

Parties should not request CACI instructions that do not apply when trial begins (e.g., CACI 5013 absent a deadlocked jury), but may request additional applicable instructions during trial if circumstances change.

The parties should not request CACI instructions that do not apply when the trial begins. For example, CACI 5013 shall not apply unless and until there is a deadlocked jury. During trial, if circumstances change, the parties may request additional applicable jury instructions.

WARNING

Applies to

Jury instructions

Parties are expected to request CACI instructions instead of specially prepared instructions when an appropriate CACI instruction exists, and special instructions with out-of-context quotes or non-plain-English wording are usually inappropriate.

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 court rarely uses a special jury instruction on a topic covered by a CACI instruction. Special jury instructions that use quotes from appellate cases taken out of context, or that do not use plain English, are usually not appropriate.

WARNING

Applies to

Special verdict form

When requesting a special verdict form, parties are expected 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

Motion in limine

The parties should not file generic motions in limine untethered to actual anticipated disputes about evidence. Motions in limine that seek rulings “which would merely be declaratory of existing law” and do not include a discussion about the particular evidence the moving party seeks to exclude are not appropriate. (Kelly v. New West Federal Savings (1996) 49 Cal.App.4th 659, 670-671.)

The parties should not file generic motions in limine untethered to actual anticipated disputes about evidence. Motions in limine that seek rulings “which would merely be declaratory of existing law” and do not include a discussion about the particular evidence the moving party seeks to exclude are not appropriate. (Kelly v. New West Federal Savings (1996) 49 Cal.App.4th 659, 670-671.)

WARNING

Applies to

Proposed jury instructions

Proposed jury instructions must be organized into groups behind Tab F in a specified order, with each group labeled by cover sheets (the full ordering is truncated in this chunk).

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

WARNINGCivil cases

Applies to

Notice of settlement

Should the case resolve but the parties require time to effectuate their agreement, the Plaintiff should file a "Notice of Settlement" and indicate on the face sheet any future court dates or hearings that have already been calendared (including trial) so that the Court can take them off calendar.

Should the case resolve but the parties require time to effectuate their agreement, the Plaintiff should file a "Notice of Settlement" and indicate on the face sheet any future court dates or hearings that have already been calendared (including trial) so that the Court can take them off calendar.

WARNINGCivil cases

Applies to

Stipulation

Please also detail any future court dates or hearings in the case and include request to take any such hearings off-calendar.

Please also detail any future court dates or hearings in the case and include request to take any such hearings off-calendar.

WARNINGCivil cases

Applies to

Compliance with standing order for unlawful detainer jury trial readiness

The optional LA CIV form 244 may be used only jointly by the parties to file trial-ready jointly-prepared documents and does not relieve the parties of the obligation to present compliant trial-ready binders.

As discussed in the Standing Order at ¶¶ 20-21, the optional "Compliance with Standing Order for Unlawful Detainer Jury Trial Readiness" (LA CIV form 244) is available for the parties jointly to utilize and to file trial-ready jointly-prepared documents and other trial-ready proposed documents. This is not a vehicle for one party to file its own separate trial documents. Nor is this a substitute or alterative for participating with the other party in preparing joint trial documents and to prepare trial notebooks for the Court's review. To be clear: the parties must present trial-ready binders, in compliance with the Standing Order, regardless of whether any documents are filed with a "Compliance with Standing Order for Unlawful Detainer Jury Trial Readiness."

WARNINGCivil cases

Applies to

Stipulation for entry of judgment

To effectuate settlement, parties should jointly use either LASC Local Form CIV 136 or Judicial Council Form UD-115 for the stipulation for entry of judgment, which the Court strongly prefers.

Should the case resolve via settlement, either in open court or else out-of-court, the parties may jointly prepare and file either the "Unlawful Detainer Stipulation and Judgment" (LASC Local Form no. CIV 136) or else the "Stipulation for Entry of Judgment (Unlawful Detainer)" (Judicial Council Form no. UD-115). The Court strongly prefers that the parties use one of these two forms to effectuate settlement.

WARNINGCivil cases

Applies to

Stipulation for judgment

The Court strongly prefers use of specified forms for settlement stipulations for judgment.

Should the case resolve via settlement, either in open court or else out-of-court, the parties may jointly prepare and file either the “Unlawful Detainer Stipulation and Judgment” (LASC Local Form no. CIV 136) or else the “Stipulation for Entry of Judgment (Unlawful Detainer)” (Judicial Council Form no. UD-115). The Court strongly prefers that the parties use one of these two forms to effectuate settlement.

WARNING

Applies to

Informal discovery conference request

the propounding party can request an IDC by filing form LACIV 094 and including three (3) dates all parties are available to appear at 1:30 p.m., Monday through Thursday.

the propounding party can request an IDC by filing form LACIV 094 and including three (3) dates all parties are available to appear at 1:30 p.m., Monday through Thursday.

WARNING

Applies to

Joint appendix

The joint appendix should generally include only cited pages, though context pages (cover page, witness identification page, or other pertinent pages) may be included even if not cited.

Generally, only the cited pages should be included in the joint appendix and not the entire document in which those pages are contained. If it is necessary to provide context to a cited page, the joint appendix may include the document cover page, a witness identification page, and/or other pertinent pages from the source document, even if not actually cited.

WARNING

Applies to

Initial discovery disclosures

Civil actions filed after January 1, 2024 are subject to CCP § 2016.090 initial discovery disclosures, enforceable by the Court on its own or a party's motion; per the document's footnote, this 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.

WARNING

Applies to

Idc memorandum

The first paragraph of the IDC memorandum must contain a neutral statement of the dispute followed by 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

Submit on tentative 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

Trial order

Trial order submissions must not contain any mention of insurance.

No mention of insurance

WARNING

Applies to

Final status conference trial binder

Documents that are not provided jointly must be accompanied by a declaration explaining why joint documents were not provided (continuation of FSC binder requirements).

documents with a declaration explaining why joint documents are not provided.

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 3-300 regarding Notice of Related Cases.

WARNING

Applies to

Proposed order granting motion to be relieved as counsel

Must include

proposed order

The proposed order on a motion to withdraw as counsel must include the client's address, telephone number, and email address.

Please be sure to include on the proposed order an address, telephone number and email address of the client(s).

WARNING

Applies to

Proposed verdict forms

8. JOINT PROPOSED VERDICT AND SPECIAL INTERROGATORY FORMS. Use CACI model verdict forms where applicable. The Court discourages submission of competing proposed verdict forms.

8. JOINT PROPOSED VERDICT AND SPECIAL INTERROGATORY FORMS. Use CACI model verdict forms where applicable. The Court discourages submission of competing proposed verdict forms.

WARNING

Applies to

Proposed jury instructions

The identity of the party requesting a jury instruction is removed after the jury instruction conference and before the instructions are submitted to the jury for deliberation.

identity of the party requesting the instruction will be removed after the jury instruction conference and before submission to the jury for deliberation.

WARNINGCivil cases

Applies to

Settled statement

Parties without a court reporter at trial must prepare and file a joint settled statement of testimony and evidence each trial day.

Parties who do not provide a court reporter for trial are required to prepare and file a joint, settled statement of the testimony and evidence admitted each day of the trial.