Los Angeles Superior Court Document Filing Requirements

WARNINGCivil cases

Applies to

Declaration

If all defendants are not served, plaintiff must submit a declaration 5 days before the CMC explaining service efforts.

If all defendants have not been served, plaintiff or plaintiff's counsel must submit a declaration five (5) days prior to the CMC explaining what efforts have been undertaken to accomplish service.

WARNINGCivil cases

Applies to

Statement

The IDC statement must be in pleading format and briefly summarize the dispute.

At least five (5) court days prior to the IDC, the parties must file a statement in pleading format, of no more than two (2) pages, briefly summarizing the dispute.

WARNINGCivil cases

Applies to

Notice of continuance cancellation withdrawal

Counsel must file a notice of continuance/cancellation/withdrawal when a motion is continued or cancelled on CRS.

If a motion is continued or cancelled on CRS, counsel must file a notice of continuance/cancellation/withdrawal.

WARNING

Applies to

Motion in limine

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

Proposed jury instructions

When an appropriate CACI jury instruction exists, the court expects the parties to request it rather than 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

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

Mini opening statement

Parties choosing a mini-opening statement before voir dire in lieu of a statement of the case must write out the statement and share it with opposing counsel.

In lieu of a statement of the case, if the parties wish to make a mini-opening statement prior to conducting their voir dire, they must write out their brief statement and share it with opposing counsel.

WARNING

Applies to

Joint list of proposed jury instructions

The joint list of proposed jury instructions must include a table with columns for each instruction's number, name, any objection, and whether it is given.

The list of instructions must include a table which includes columns for all jury instructions by number, name, any objection to the instruction, and whether the instruction is given.

WARNING

Applies to

Joint witness list

The Joint Witness List must contain all witnesses on one alphabetical list without duplicates, with expected testimony time (direct, re-direct, cross, re-cross) indicated for each witness and the total estimated time stated at the end of the list.

All witnesses must be listed on one list in alphabetical order by last name. Do not repeat the name of a witness. Indicate the total time expected for that testimony, including direct and re-direct, as well as cross and re-cross. At the end of the list, state the total time estimated for each witness’ testimony.

WARNING

Applies to

Trial brief

Trial briefs are optional but preferred; if submitted, they should identify major legal issues with supporting authorities, the relief claimed, damages calculation, and other information that may assist the court at trial.

Trial briefs are optional but preferred to the extent they highlight any issues or evidence to which there will be a significant dispute at trial. Any trial brief submitted by a party should identify any major legal issues anticipated with supporting points and authorities, a brief statement of the relief claimed and calculation of damages, and any other information which counsel believes may assist the court in ruling upon trial objections or matters that may arise in trial.

WARNING

Applies to

Proposed verdict form

If the parties cannot agree on a verdict form, each party must submit its own proposed verdict form.

If the parties cannot agree on a general or special verdict form, each party must submit their own proposed verdict form.

WARNING

Applies to

Notice of ruling

If all parties submit on the court’s tentative ruling, counsel for moving party shall give notice of ruling unless otherwise ordered by the court. This may be done by incorporating verbatim the court’s tentative ruling.

If all parties submit on the court’s tentative ruling, counsel for moving party shall give notice of ruling unless otherwise ordered by the court. This may be done by incorporating verbatim the court’s tentative ruling.

WARNING

Applies to

Joint chart of page and line designations

Counsel and any self-represented parties intending to use deposition or former trial testimony must meet and confer and jointly prepare and file a joint chart of page and line designations.

If any parties intend to use deposition testimony or former trial testimony in lieu of or in addition to a witness’ live testimony, the parties’ counsel and any self-represented parties shall meet and confer to discuss, and work together to prepare and file, a joint chart in the format set forth below.

WARNING

Applies to

Exhibits

Exhibits written in a foreign language must be accompanied by a certified English translation.

Exhibits written in a foreign language must be accompanied by a certified English translation.

WARNING

Applies to

Joint proposed jury instructions

Counsel must submit a joint set of CACI jury instructions with all brackets or blanks filled in.

Counsel are to submit a joint set of CACI instructions with brackets or blanks filled in.

WARNING

Applies to

Exhibits

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

Pursuant to California Rules of Court, rule 3.1110(f) and Local 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

Motion in limine

As a reminder, MILs should not be used to seek summary judgment or adjudication of issues, or judgment on the pleadings.

As a reminder, MILs should not be used to seek summary judgment or adjudication of issues, or judgment on the pleadings.

WARNING

Applies to

Ex parte application

The moving party should indicate in the declaration regarding notice whether any opposition to the application is expected.

The moving party should indicate in the declaration regarding notice whether any opposition to the application is expected.

WARNING

Applies to

Request for court reporting services

Requests for official court reporting services by a fee-waiver party must be made on local form SCLAC LACIV 269.

The request must be made by using the local form (SCLAC LACIV 269).

WARNING

Applies to

Joint trial documents

Plaintiff(s) are responsible for filing joint trial documents unless the parties agree otherwise.

Plaintiff(s) shall be responsible for filing joint documents unless the parties agree otherwise.

WARNING

Applies to

Stipulation

As noted above, to the extent feasible, stipulations are to be filed prior to trial.

As noted above, to the extent feasible, stipulations are to be filed prior to trial.

WARNING

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.

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.

WARNING

Applies to

Joint jury instructions

The jury instructions should include a disposition table that lists all jury instructions by number, the identity of the party or parties proposing (or opposing) the instruction and include columns for the court to use to indicate whether the instruction is given, modified, withdrawn or refused.

The jury instructions should include a disposition table that lists all jury instructions by number, the identity of the party or parties proposing (or opposing) the instruction and include columns for the court to use to indicate whether the instruction is given, modified, withdrawn or refused.

WARNING

Applies to

Joint summary of daily testimony and evidence

If no court reporter is present, counsel must provide the court a joint summary of each day's testimony and admitted evidence by the morning following the testimony.

If the parties do not have a court reporter, counsel will be required to provide the court with a joint summary of the testimony and evidence admitted daily by the morningfol/owing the testimony.

WARNING

Applies to

Trial brief

Trial briefs should contain a description of facts, remaining causes of action, party status, defenses, legal issues with points and authorities, relief claimed, damages calculation, and other information helpful to the Court.

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 calculation of damages sought, and any additional information that may assist the Court in ruling upon trial objections or matters that may arise during trial.

WARNING

Applies to

Motion in limine

MILs should not be used to seek summary judgment, summary adjudication of issues, or judgment on the pleadings.

MILs should not be used to seek summary judgment, summary adjudication of issues, or judgment on the pleadings.

WARNING

Applies to

Joint jury instructions

Instructions as to which there are disagreements should be provided in separate sets. However, disputed jury instructions may be filed only if counsel have met and conferred.

Instructions as to which there are disagreements should be provided in separate sets. However, disputed jury instructions may be filed only if counsel have met and conferred.

WARNING

Applies to

Joint witness list

Absent good cause, total listed testimony hours may not exceed the CMC trial estimate, reserving one day for jury selection/MILs and one day for deliberations (e.g., 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 l 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

Motion in limine

Must include

caption

MILs and trial motions should be numbered consecutively with a caption clearly identifying the motion's subject.

MILs and other trial motions should be numbered consecutively, with a caption that clearly and concisely identifies the subject of the motion.

WARNING

Applies to

Joint verdict form

The parties should agree on a joint verdict form, and any special verdict should be easy for the jury to use and free of unnecessary questions.

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 fonn that is easily used by the jury, and which does not require the jury to answer unnecessary questions.

WARNING

Applies to

Jury instructions

Agreed jury instructions must be filed jointly, fully filled out and organized in numerical order, while non-agreed instructions must be filed separately identifying the requesting party.

a copy of all requested instructions fully filled out, organized in numerical order. Those instructions not agreed upon should be filed separately and the party making the request should be identified.

WARNING

Applies to

Operative pleadings

Fragment from the Trial Binder contents list indicating the operative complaints, cross-complaints, and operative answers are Trial Binder contents (the operative verb/context appears on a prior page).

the operative complaints and cross-complaints and the operative answers thereto.

WARNING

Applies to

Trial brief

Trial briefs should describe the facts, remaining causes of action, parties' status, defenses, anticipated legal issues with supporting authorities, relief and damages sought, and any other information helpful to the Court at trial.

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 calculation of damages sought, and any additional information that may assist the Court in ruling upon trial objections or matters that may arise during trial.

WARNING

Applies to

Jury instructions

The jury instructions should include a disposition table that lists all jury instructions by number, the identity of the party or parties proposing (or opposing) the instruction, and include columns for the court to use to indicate whether the instruction is given, modified, withdrawn or refused.

The jury instructions should include a disposition table that lists all jury instructions by number, the identity of the party or parties proposing (or opposing) the instruction, and include columns for the court to use to indicate whether the instruction is given, modified, withdrawn or refused.

WARNING

Applies to

Motions in limine

Must include

caption

MILs and other trial motions should be numbered consecutively with a caption that clearly and concisely identifies the subject of the motion.

MILs and other trial motions should be numbered consecutively, with a caption that clearly and concisely identifies the subject of the motion.

WARNING

Applies to

Joint statement of the case

Counsel must meet and confer to prepare a brief, neutral joint statement of the case in plain English, generally not exceeding 2-3 paragraphs, unless all parties agree to mini-opening statements.

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.

WARNING

Applies to

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.

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

Electronic exhibits

Any such drive should be certified by counsel or the party that it contains no malicious materials or programs.

Any such drive should be certified by counsel or the party that it contains no malicious materials or programs.

WARNINGCivil cases

Applies to

Trial brief

Bench trial briefs should include a statement of the case and any legal issues that will need to be resolved.

It should include a statement of the case and any legal issues that will need to be resolved.

WARNINGCivil cases

Applies to

Joint witness list

A witness omitted from the witness list may be excluded unless good cause is shown.

Any party/counsel who seeks to elicit testimony from a witness not identified on the witness list may have that witness excluded absent a showing of good cause.

WARNINGCivil cases

Applies to

Current operative pleadings

The current operative complaint, answer, cross-complaint, and any answer to a cross-complaint are to be included.

The operative complaint, answer, cross-complaint and answer to any cross-complaint.

WARNINGCivil cases

Applies to

Motion in limine

Multiple motions in limine should be numbered consecutively.

Multiple motions-in-limine should be numbered consecutively.

WARNINGCivil cases

Applies to

Jury instructions

Jury instructions are settled after the close of evidence and before closing arguments.

Settling of jury instructions will occur after the close of evidence but before closing arguments.

WARNING

Applies to

Motion in limine

Uncontested motions in limine should be marked "uncontested" in the caption and parties are encouraged to stipulate to them.

The parties/counsel are strongly encouraged to stipulate to uncontested motions. Uncontested motions should note "uncontested" in the caption.

WARNING

Applies to

Jury instructions

Parties should request the applicable CACI instruction instead of a specially prepared instruction, and specially prepared instructions should be used sparingly without repetition of CACI or argument.

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

Special verdict form

For special verdict forms, the court expects parties to use or incorporate the applicable CACI special verdict form when 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 (or incorporate) the CACI special verdict form.

WARNING

Applies to

Motion in limine

Generic or merely declaratory motions in limine are strongly disfavored and motions in limine may not be used to seek summary judgment, summary adjudication of issues, or judgment on the pleadings.

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 or witnesses are strongly disfavored. (See, Kelly v. New West Federal Savings (1996) 49 Cal.App.4th 659.) Motions in limine should not be used to seek summary judgment, summary adjudication of issues, or judgment on the pleadings.

WARNING

Applies to

Electronic media exhibits

Parties must comply with Paragraph 5 of these requirements regarding electronic media as exhibits.

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

WARNING

Applies to

Ex parte application

The Court may rule on the ex parte papers without any oral argument if a hearing is deemed unnecessary. With that in mind, please include all necessary information and evidence in the ex parte application; waiting to present evidence at oral argument may result in denial of the application if a hearing is deemed unnecessary.

The Court may rule on the ex parte papers without any oral argument if a hearing is deemed unnecessary. With that in mind, please include all necessary information and evidence in the ex parte application; waiting to present evidence at oral argument may result in denial of the application if a hearing is deemed unnecessary.

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.