Los Angeles Superior Court Document Filing Requirements

WARNING

Applies to

Proposed jury instructions

The Court expects the parties to request the applicable CACI jury instruction rather than a specially prepared instruction when an appropriate CACI instruction 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

Opposition and reply papers

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

Proposed 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.

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

Discovery material list

Each party must prepare a list of discovery material intended for use at trial identifying date, document, page and line, and must lodge originals of depositions or discovery responses with the Court at the time of trial.

Each party must prepare a list of discovery material intended to be used at trial, including but not limited to interrogatories and requests for admissions and any responses thereto as well as deposition(s), all of which shall specifically identify the date, document, page and line. If depositions or other discovery responses are intended to be used at trial, originals shall be lodged with the Court at the time of trial.

WARNING

Applies to

Joint statement of the case

Parties must submit a printed copy of a jointly prepared, short, non-argumentative written statement of the case to be read to the jury.

The parties shall submit a printed copy of the jointly prepared, short, non-argumentative written statement of the case to be read to the jury.

WARNING

Applies to

Joint witness list

The joint witness list must include each witness's name, estimated direct and cross-examination time, total combined testimony time, and any potential scheduling problems.

The jointly prepared Witness List must include the name of each witness, an estimate of time for direct and cross-examination, and the total amount of time of all witness testimony combined for the entire trial. Potential scheduling problems must be noted.

WARNING

Applies to

Joint exhibit list

Parties must jointly prepare and exchange a completed exhibit list identifying each exhibit and stipulations, with pre-agreed numbering ranges, separately identified subparts, consecutive pagination, and exchange/review of all listed items prior to the FSC.

All parties must jointly prepare and exchange a completed Exhibit List, indicating each document and item of physical evidence, and whether there is a stipulation to authenticity and/or admissibility. Each exhibit shall be numbered or lettered. All parties shall agree in advance that their respective party will have a range of exhibit numbers or letters (e.g. Plaintiff No. 1: 1-99; Plaintiff No. 2: 100-199; Defendant: A- Z). Each exhibit must be separately identified. Subparts to an exhibit (e.g., 1A, IB, etc.) must also be identified and listed separately. Each page of a multi-page exhibit must be consecutively paginated. All items so referred to in the Exhibit List must be exchanged and/or reviewed by each counsel or the parties prior to the FSC.

WARNING

Applies to

Motion in limine opposition

Oppositions to motions in limine must be in writing, numbered, and must refer to the numbers used by the moving party.

An opposition to any motion in limine must be in writing, numbered, and served and electronically filed by represented parties at least five (5) calendar days prior to the FSC. (Exempt parties may file the same by conventional means on printed paper directly in Department F43.) The opposition must refer to the numbers used by the moving party.

WARNING

Applies to

Trial brief

Trial briefs must include a description of causes of action and defenses, facts established by admissions, contested issues of fact and law with authorities, evidentiary issues, and a detailed statement of damages and relief claimed.

Trial briefs are mandatory for all (both Court and jury) trials and must include the following information and not exceed 20 pages:

WARNING

Applies to

Customer complaint list

Defendant's list of other customers' complaints must include the CIN, repair visit date, reporting location, and complaint text (chart or spreadsheet format permitted) and must exclude other customers' personal identifying information.

The list provided by Defendant may be in the chart or spreadsheet format, and shall include the CIN, date of repair visit, dealership or other reporting location, and the text of the other customers' reported complaint, but shall not include the other customers' names, addresses, phone numbers, e-mail addresses, or other personal identifying information.

WARNING

Applies to

Judgments orders stipulations

Self-represented litigants may file judgments, orders, and stipulations directly in the courtroom, but these filings must include self-addressed, stamped envelopes and copies to conform.

Judgments, orders, and stipulations may be filed directly in the courtroom but must include self-addressed, stamped envelopes and copies to conform.

WARNING

Applies to

Trial brief

All parties are encouraged to submit trial briefs on the first day of trial. The brief should address the factual and legal support for all causes of action and defenses each party intends to pursue at trial. Evidence should not be attached, but reference to digital exhibits with hyperlinks, is encouraged.

All parties are encouraged to submit trial briefs on the first day of trial. The brief should address the factual and legal support for all causes of action and defenses each party intends to pursue at trial. Evidence should not be attached, but reference to digital exhibits with hyperlinks, is encouraged.

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 parties' position.

WARNINGCivil cases

Applies to

Joint statement of the case

The joint statement of the case must be prepared by meet-and-confer and be a brief, neutral document informing the jury about the parties and their claims/defenses without favoring either side.

JOINT STATEMENT OF THE CASE. This statement will be read by the Court to the prospective jurors. Counsel must meet and confer to prepare the statement, which shall bea brief and neutral document that informs the jury about the parties and their claims/defenses without favoring one side.

WARNINGCivil cases

Applies to

Ex parte application

Ex parte applications must comply with CRC 3.1200 et seq. and be properly calendared in Department 517 per LR 2.8 and 2.9.

Please consult Local Rules (“LR”) 2.8 and 2.9 to determine whether the ex parte application is properly calendared in Department 517. Ex parte applications must comply with CRC 3.1200 et seq.

WARNING

Applies to

Jury instructions

Modified or special jury instructions not requested in lieu of a CACI instruction must be inserted in the submitted packet after the corresponding CACI instruction at the logically appropriate position.

If your modified or "special" instruction is not being requested in lieu of a CACI Instruction, then insert the instruction in the submitted packet after the CACI instruction -- where you believe it would logically be positioned when read to the jury.

WARNING

Applies to

Special verdict form

Parties should use the applicable CACI special verdict form when requesting a special verdict, keep special verdicts simple for the jury, and general verdict forms are preferred.

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. 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, however, general verdict forms are preferred.

WARNING

Applies to

Joint witness list

The format should be as follows: JOINT WITNESS LIST Name Party Expected to Brief Description of Length of Length of Total (State if Expert) Calling Testify Testimony Direct Cross Length (Y/N)? (in Hours) (in hours) (in hours)

The format should be as follows: JOINT WITNESS LIST Name Party Expected to Brief Description of Length of Length of Total (State if Expert) Calling Testify Testimony Direct Cross Length (Y/N)? (in Hours) (in hours) (in hours)

WARNING

Applies to

Idc statement

IDC statements must include a short case description, the discovery dispute at issue, the parties' informal resolution attempts, and any legal authority for the Court to consider.

The IDC statement shall include (a) a short description of the case, (b) a description of the discovery dispute including a list or summary of the discovery requests, objections, and/or answers at issue, (c) a description of the parties' informal attempts and any compromises offered to resolve the dispute, and (d) any legal authority the Court should consider in conducting the IDC.

WARNING

Applies to

Joint witness list

Counsel and self-represented parties must jointly prepare and file a list of all trial witnesses, excluding impeachment and rebuttal witnesses.

Joint Witness List: The parties’ counsel and any self-represented parties shall work together to prepare and file a joint list of all witnesses whom any party intends to call at trial, excluding impeachment and rebuttal witnesses. (Local Rule 3.25, subd. (g)(5).)

WARNING

Applies to

Joint statement of the case

Parties must file a joint statement of the case — a brief, neutral description of the case to be read to the jury, generally not exceeding two paragraphs.

Joint Statement of the Case: The parties must file a brief, neutral description of the case to be read to the jury. In most instances, it should not exceed two paragraphs.

WARNING

Applies to

Joint witness list

The joint witness list must be organized in columns stating witness name/expert status/accommodations, calling party, expected appearance, description of testimony, and estimated direct and cross-examination lengths.

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

WARNING

Applies to

Trial brief

Trial briefs are strongly encouraged (not mandatory) and should contain five specified elements: facts/claims/defenses, elements and burden of proof, major legal issues with authorities, relief and damages calculations, and other helpful information.

Trial briefs are strongly encouraged to be filed and should contain (1) a brief description of the facts and the claims and defenses subject to litigation; (2) the elements and burden of proof for each of the cause(s) of action; (3) a list of major legal issues anticipated with points and authorities supporting and defending the issues; (4) a brief statement of the relief claimed and calculations of damages sought; and (5) any further information that counsel believes may assist the court in ruling upon trial objections or matters that may arise during trial.

WARNING

Applies to

Operative pleading

Plaintiff and cross-complainant counsel are requested (not required) to provide the court a copy of the operative complaint(s) before trial and to indicate which causes of action will be dismissed.

Counsel for plaintiffs and/or cross-complainants are requested to provide the court with a copy of the operative complaint(s) prior to trial. Counsel should indicate prior to trial and cause(s) of action which will be dismissed.

WARNINGCivil cases

Applies to

Motion in limine

Must include

case number

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.

WARNINGCivil cases

Applies to

Joint cmc statement addendum

Defect descriptions supporting a buyback claim in the Joint CMC Statement Addendum must be specific and may not use conclusory terms such as "engine, mechanical or electrical" problems.

a. No conclusionary terms such as "engine, mechanical or electrical" problems. b. BE SPECIFIC, e.g., CEL comes on, Infotainment screen turns black when backing up, etc.

WARNINGCivil cases

Applies to

Special verdict form

The court urges consideration of a general verdict form and expects parties requesting a special verdict form to use the applicable CACI special verdict form when one exists.

The court urges the parties to consider a general 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 finding, the court expects the parties to use the CACI special verdict form.

WARNINGCivil cases

Applies to

Joint case management conference statement addendum

The Joint Case Management Conference Statement Addendum must include a Liability section addressing claims for motor vehicle negligence, general negligence, negligent entrustment, per se negligence, vehicle code violations, whether the defendant will admit liability, and any pending or contemplated criminal charges or investigations.

8. Liability a. Is there a claim for motor vehicle negligence? 0Yes No b. Is there a claim for general negligence? 0Yes no c. Is there a claim for negligent entrustment? 0Yes no d. If so, what is the basis for the claim? e. Is there a claim for per se negligence? 0Yes No f. Is there a claim for violations of the vehicle code? Yes no g. If so, what section of the vehicle code? h. Will the defendant admit liability? 0Yes No 1 Are there any criminal charges pending or contemplated? 0Yes No J. Is there a criminal investigation on-going? Yes no

WARNINGCivil cases

Applies to

Exhibit

Counsel and self-represented parties must place the court's yellow evidence tags (filled in only with the case number and exhibit number) on each exhibit in the Judicial Assistant's copy of the Exhibit Binder.

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.

WARNINGCivil cases

Non-documentary exhibits must have a simple written description inserted behind the corresponding numerical tab in the Exhibit Binders (sentence continues from the prior page regarding copies of documentary exhibits).

all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the Exhibit Binders.

WARNINGCivil cases

Applies to

Motion in limine opposition reply

Must include

caption

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

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

WARNINGCivil cases

Applies to

Motion in limine score sheet

Attorneys must prepare a motion in limine score sheet, in the format prescribed by the order, for each party's motions in limine.

For the motions in limine for each party, the attorney must prepare a score sheet in the format below.

WARNINGCivil cases

Applies to

Joint case management conference statement addendum

The Joint Case Management Conference Statement Addendum must include an Insurance section disclosing each party's auto insurance, policy limits, whether the insurance company is providing a defense, and any uninsured motorist issue.

7. Insurance a. Does the plaintiff have auto insurance? 0Yes No b. If so, what are the policy limits? c. Does the defendant have auto insurance? 0Yes No d. If so, what are the policy limits? e. Is the insurance company providing a defense? 0Yes no f. Is there an uninsured motorist issue? 0Yes no

WARNINGCivil cases

Applies to

Trial binder

Tab A: Trial Briefs Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Statement to Be Read to the Jury Tab E: Joint List of Jury Instructions Tab F: Joint and Contested Jury Instructions Tab G: Joint or Contested Verdict Form(s) Tab H: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab I: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint). Tab J: Motions in Limine, unless they are too voluminous and require their own binder.

Tab A: Trial Briefs Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Statement to Be Read to the Jury Tab E: Joint List of Jury Instructions Tab F: Joint and Contested Jury Instructions Tab G: Joint or Contested Verdict Form(s) Tab H: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab I: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint). Tab J: Motions in Limine, unless they are too voluminous and require their own binder.

WARNINGCivil cases

Applies to

Trial binder

In bench trials, the Trial Binder need include only Tabs A, B, C, H, I, and J, with the other tab sections left empty.

(for trials by the court without a jury, the Trial Binder shall include only the documents listed under Tabs A, B, C, H, I, and J with the other sections left empty):

WARNINGCivil cases

Applies to

Proposed jury instructions

The court expects parties to request the applicable CACI instruction rather than a specially prepared jury 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.

WARNINGCivil cases

Applies to

Case management statement addendum non opt in cases

In non-opt-in cases, the parties must identify all remaining issues by answering the addendum questions as applicable.

Identify all remaining issues by providing answers to the above questions as applicable.

WARNING

Applies to

Joint case management statement

Plaintiff must state specific facts about the vehicle's defects in the JCMCS and may not use conclusory terms such as 'engine, mechanical or electrical' problems.

Plaintiff shall plainly state the facts as to why the automobile qualifies for a “buyback,” to wit, what was (or still is) wrong with the vehicle at issue. Do not use conclusionary terms such as “engine, mechanical or electrical” problems. BE SPECIFIC. E.g., engine light turns on, power screen malfunctions, etc.

WARNING

Applies to

Exhibit list

The court requests that counsel attempt to stipulate to the admissibility or foundation of documents on the exhibit list.

The court requests that counsel attempt to stipulate to the admissibility or foundation of documents contained on the list.

WARNINGCivil cases

Applies to

Motion to compel

Motions to compel must show the discovery instrument has narrow and specific demands, including good cause under CCP 2031.310(b)(1) and that the demand is not unreasonably cumulative and duplicative under CCP 2031.310(g).

The Court expects the party moving to compel responses or further responses to show that the discovery instrument has narrow and specific demands. Requests for production of documents and subpoenas duces tecum must comply with CCP 2031.310(b)(1) to provide “specific facts showing good cause justifying the discovery sought by the demand” and with CCP 2031.310(g) in showing the demand is not “unreasonably cumulative and duplicative.”

WARNINGCivil cases

Applies to

Joint statement of case

For jury trials, counsel should agree on a joint statement of the case that identifies the parties and neutrally describes the general subject matter, to be read to the jury.

Joint Statement of the Case: For jury trials, counsel should reach an agreement on a joint statement of the case to be read to the jury. See Local Rule 3.25(g)(4). The statement should identify the parties and be neutral in describing the general subject matter of the case.

WARNINGCivil cases

Applies to

Stipulation for settlement conference

Parties must obtain and execute a stipulation for settlement conferences conducted by the trial judge.

Parties will need to obtain and execute a stipulation for settlement conferences conducted by the trial judge.

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

Special verdict form

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

WARNING

Applies to

Opposition and reply papers

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 witness list

The joint witness list must use mandated columns (alphabetical witness name, expert status, accommodations, calling party, expected-to-testify status, testimony description, and direct/cross/total time estimates in hours) and conclude with a grand total of estimated testimony time.

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

Notice of motion

Each motion in limine notice must concisely identify the evidence the moving party seeks to exclude.

The notice of motion for each motion in limine shall concisely identify the evidence that the moving party seeks to exclude.

WARNING

Applies to

Trial brief

Each party must file a trial brief identifying the disputed causes of action and defenses, major legal issues with supporting authorities, requested relief and damages calculation, and any other information assisting the court at trial.

Each party shall file a trial brief succinctly identifying: (1) the causes of action 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

Statement of the case

Parties must jointly prepare a short, non-argumentative written statement of the case to be read to the jury.

Jointly prepare a short, non-argumentative written statement of the case to be read to the jury.

WARNING

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 LACCR Rules 3.52, 3.151, 3.53, 3.149, 3.150, and 3.152.

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