Los Angeles Superior Court Document Filing Requirements

WARNING

Applies to

Witness list

The jointly prepared witness list must include each witness's name, testimony description, direct/cross time estimates, scheduling problems, and interpreter needs.

The jointly prepared witness list must include each witness' name, a brief description of the testimony, a time estimate on direct and cross, any potential scheduling problems, and whether he/she will be assisted by an interpreter.

WARNING

Applies to

Motion in limine

Each motion in limine must be numbered sequentially (e.g., Plaintiff's Motion in Limine No. 1, Defendant's Motion in Limine No. 1).

Each motion must be numbered sequentially (Plaintiff's Motion in Limine No., 1, Defendant's Motion in Limine No.1).

WARNING

Applies to

Court reporter request

In unlimited civil proceedings, parties who have received a fee waiver pursuant to California Rules of Court rule 3.55(7) may request an official court reporter pursuant to California Rules of Court rule 2.956(b)(3) prior to the hearing or trial on court form LACIV269.

In unlimited civil proceedings, parties who have received a fee waiver pursuant to California Rules of Court rule 3.55(7) may request an official court reporter pursuant to California Rules of Court rule 2.956(b)(3) prior to the hearing or trial on court form LACIV269.

WARNING

Applies to

Motion in limine

Uncontested motions in limine should note 'uncontested' in the caption.

Uncontested motions should note "uncontested" in the caption.

WARNING

Applies to

Declaration of incomplete service

If defendants have not been served by the CMC, plaintiff must submit a declaration seven days before the CMC explaining why service is incomplete, documenting service efforts, and proposing a completion date.

If all defendants have not been served, plaintiff or plaintiff's counsel must submit a declaration to the Court seven (7) days prior to the CMC explaining why service has not been completed, documenting the efforts that have been made to complete service, and specifying the date by which service is proposed to be completed.

WARNING

Applies to

Electronic media exhibits

The parties must comply with Section XIII(G) regarding Electronic Media as Exhibits (details set forth in that section).

The parties are required to comply with Section XIII(G), below, regarding Electronic Media as Exhibits.

WARNING

Applies to

Motion in limine

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

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

WARNING

Applies to

Proposed special verdict form

When a special verdict form is requested, parties are expected to use or incorporate 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 (or incorporate) the CACI special verdict form.

WARNING

Applies to

Joint exhibit list

Parties' counsel and self-represented parties must meet and confer in good faith to resolve objections to the authenticity and admissibility of each exhibit.

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

WARNING

Applies to

Stipulation and order

Must include

proposed order

Parties agreeing to use a settlement program that requires a court order must file a proposed stipulation and order.

If the parties agree to utilize a settlement program requiring a court order, please file a proposed stipulation and order.

WARNING

Applies to

Binder

In addition to the required filings, the parties must lodge a binder, as described in Section XIII(F), at least five days prior to the FSC.

At least five (5) days prior to the FSC, the parties shall file the following documents and, as discussed in Section XIII(F), below, lodge a binder as described therein.

WARNING

Applies to

Motion in limine

Parties and counsel are discouraged from filing more than 5 contested motions in limine.

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

WARNING

Applies to

Joint witness list

The joint witness list must contain seven required columns (witness name/expert status/accommodations, calling party, expected to testify, testimony description, direct/redirect hours, cross hours, total hours) and state a grand total of estimated testimony hours.

The joint witness list shall be organized with columns (in the format set forth below) that 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 and redirect 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

Disability accommodation request

If you require an accommodation relating to a disability, please inform the courtroom staff at least five (5) court days in advance so the Court can attempt to facilitate your request. Requests can be made by filing Judicial Council Form MC-410.

If you require an accommodation relating to a disability, please inform the courtroom staff at least five (5) court days in advance so the Court can attempt to facilitate your request. Requests can be made by filing Judicial Council Form MC-410.

WARNING

Applies to

Joint witness list

Absent good cause, the total estimated testimony hours on the joint witness list should not exceed the trial estimate given at the case management conference, including one day for jury selection.

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 one (1) day for jury selection.

WARNING

Applies to

Motion in limine

Generic motions in limine that do not identify the specific evidence (exhibits, testimony, or witnesses) to be excluded or that seek merely declaratory rulings are disfavored.

Motions in limine that are generic, do not identify the specific evidence sought to be excluded (e.g., exhibits, testimony, 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 disfavored.

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

Exhibits

Counsel must provide remote witnesses with copies of exhibits before trial or default prove up proceedings.

Counsel/parties are to provide remote witnesses copies of exhibits prior to trial/default prove up/etc.

WARNING

Applies to

Attorney check in

Attorneys must check in at the courtroom with one attorney card showing the calendar number and party represented.

Check in Procedures: Check in courtroom with 1 attorney card with calendar # and party represented.

WARNINGCivil cases

Applies to

Motion in limine

Please abstain from motions in limine that seek to require the court to follow the law (e.g., exclude irrelevant information; exclude hearsay) or ask for unspecific orders (e.g., "preclude 'reptile' voir dire".) Such matters, if there is a specific concern, are better set out in a trial brief.

Please abstain from motions in limine that seek to require the court to follow the law (e.g., exclude irrelevant information; exclude hearsay) or ask for unspecific orders (e.g., "preclude 'reptile' voir dire".) Such matters, if there is a specific concern, are better set out in a trial brief.

WARNINGCivil cases

Applies to

Class action settlement approval motion

Parties seeking preliminary or final approval for class action settlements should carefully adhere to the guidelines posted, and utilize the settlement forms, on the court’s website.

Parties seeking preliminary or final approval for class action settlements should carefully adhere to the guidelines posted, and utilize the settlement forms, on the court’s website.

WARNINGCivil cases

Applies to

Motion in limine

Motions in limine must comply with Code of Civil Procedure Section 1005 and Local Rule 3.57(a) (sentence truncated in source).

provisions of Code of Civil Procedure Section 1005 and the requirements of Local Rule 3.57(a).

WARNING

Applies to

Jury instruction disposition table

A disposition table listing all jury instructions by number, proposing parties, and court ruling columns must be submitted with the 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

Joint 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.

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 witness list

The joint witness list must include each witness once on a single list with estimated testimony time (direct, cross, re-direct) and total time stated at the end of the 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

Foreign language 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

Demonstrative exhibits

Demonstrative exhibits not admitted into evidence must be shown to the opposing party before use at trial, and objections must be raised timely and 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

Disputed jury instructions

Disputed jury instructions must be submitted in separate sets identifying the proposing and opposing parties.

If instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction.

WARNING

Applies to

Joint jury instructions

The joint jury instructions must be a complete set of CACI instructions with all information filled in and no remaining brackets or blanks.

Submit a joint set of CACI instructions will all information filled in – no remaining brackets or blanks.

WARNING

Applies to

Trial brief

Trial briefs are mandatory for all (both Court and jury) trials and must include the following information and not exceed 20 pages: 1) A brief description of each cause of action and key affirmative defenses presented and the issues to be decided; 2) Statement of ultimate facts or issues to which you will stipulate; 3) Those facts established by admissions in pleadings; admissions by discovery and/or stipulation of the parties; 4) All contested issues of fact; 5) All contested issues of law, together with points and authorities supporting the position of the parties;

Trial briefs are mandatory for all (both Court and jury) trials and must include the following information and not exceed 20 pages: 1) A brief description of each cause of action and key affirmative defenses presented and the issues to be decided; 2) Statement of ultimate facts or issues to which you will stipulate; 3) Those facts established by admissions in pleadings; admissions by discovery and/or stipulation of the parties; 4) All contested issues of fact; 5) All contested issues of law, together with points and authorities supporting the position of the parties;

WARNING

Applies to

Memorialization of unresolved disputes

Parties must meet and confer in good faith on admissibility issues for discovery excerpts, and any unresolved disputes must be memorialized in writing.

All parties shall meet and confer in a good-faith effort to resolve admissibility issues related to these excerpts. Any unresolved disputes must be memorialized in writing.

WARNING

Applies to

Joint witness list

Total testimony hours on the joint witness list may not exceed the trial estimate given at the CMC (including one day for jury selection and time for opening and closing) absent good cause.

Absent good cause, the total number of hours listed for testimony shall not exceed the trial estimate given at the case management conference, including the allocation of one day of the trial estimate for jury selection and sufficient time for opening statements and closing arguments.

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

Joint statement of case

JOINT STATEMENT OF THE CASE (which will be read by the Court to the prospective jurors). Counsel should be prepared to discuss whether they are agreeable to mini-opening statements to be given by counsel to the prospective jurors.

JOINT STATEMENT OF THE CASE (which will be read by the Court to the prospective jurors). Counsel should be prepared to discuss whether they are agreeable to mini-opening statements to be given by counsel to the prospective jurors.

WARNINGCivil cases

Applies to

Proposed juror questionnaire

A proposed juror questionnaire must be filed by the time of the Final Status Conference if requested.

Filed-Proposed Juror Questionnaire, if requested.

WARNING

Applies to

Ex parte application

Ex parte applications must comply with California Rules of Court, rules 3.1200-3.1207.

Ex parte applications must comply with the requirements of California Rules of Court, rules 3.1200-3.1207.

WARNING

Applies to

Trial preparation documents

Department 306 has a Trial Preparation Order which 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.

Department 306 has a Trial Preparation Order which 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.

WARNINGCivil cases

Applies to

Motion in limine

Must include

caption

MILs should be numbered consecutively with a caption identifying the subject of the motion.

MILs should be numbered consecutively with a caption that identifies the subject of the motion.

WARNINGCivil cases

Applies to

Exhibits

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.

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 proposed verdict form

Parties should submit an agreed-upon joint proposed verdict form with interrogatories.

JOINT PROPOSED VERDICT FORM. The parties should submit an agreed upon joint verdict form with interrogatories. LASCR 3.25(g)(8).

WARNINGCivil cases

Applies to

Joint summary of testimony and evidence

If no court reporter is provided at trial, counsel must provide the Court a joint summary of testimony and evidence (with exhibit numbers) on a daily basis by the morning following the testimony.

If the parties do not provide a court reporter at trial, counsel will be required to provide the Court with a joint summary of the testimony and evidence, with exhibit numbers included, admitted on a daily basis by the morning following the testimony.

WARNINGCivil cases

Applies to

Motion evidence

When identifying deposition testimony, include and mark both the question and answer, even if intervening colloquy separates them by five pages.

Be sure to include a reference to both a question and an answer when identifying deposition testimony (not just the answer) and be sure to mark the question and answer even if the question appears five pages before the answer as a result of intervening colloquy.

WARNINGCivil cases

Applies to

Joint written statement of case

The joint case statement should be one or two paragraphs describing the nature of the case and each party’s basic claim.

This statement should be no more than one or two paragraphs that simply inform the jury panel of the nature of the case and each party’s basic claim (e.g., a contract dispute, a discrimination claim, etc.)

WARNINGCivil cases

Applies to

Idc materials

Counsel must have available whatever materials are needed to make the IDC productive and successful.

Counsel are ordered to have available to them whatever materials are needed to make the IDC session productive and successful.

WARNINGCivil cases

Applies to

Joint exhibit list

The initial exhibit-list exchange must occur sufficiently before the final list is due to allow a serious, good-faith meet and confer on all exhibit objections.

This exchange must take place sufficiently in advance of the day that the final Joint Exhibit List is to be filed and included in the Trial Readiness Binder so the parties will have had time to meet and confer in a serious and good faith effort to resolve all objections to each exhibit to be offered at trial.

WARNINGCivil cases

Applies to

Opposition

Parties are asked to prepare written oppositions to ex parte applications.

Please prepare written oppositions.

WARNING

Applies to

Joint statement of stipulated facts

A joint statement of stipulated facts must be submitted where appropriate.

JOINT STATEMENT OF STIPULATED FACTS where appropriate.

WARNING

Applies to

Notice of appearance

An Initial Status Conference Order is issued soon after the filing of the case which provides among other things that all defendants should timely file a Notice of Appearance and pay all fees connected with a first paper filing.

An Initial Status Conference Order is issued soon after the filing of the case which provides among other things that all defendants should timely file a Notice of Appearance and pay all fees connected with a first paper filing.

WARNING

Applies to

Exhibit binder

An exhibit list should be provided at the front of the first volume of exhibits.

An exhibit list should be provided at the front of the first volume of exhibits.

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.) A common example is to seek exclusion of all evidence not produced in discovery. Such a motion is too abstract. Instead, a proper motion would seek to exclude specific evidence clearly sought in a particular discovery request or clearly ordered by the Court and yet not disclosed.

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.) A common example is to seek exclusion of all evidence not produced in discovery. Such a motion is too abstract. Instead, a proper motion would seek to exclude specific evidence clearly sought in a particular discovery request or clearly ordered by the Court and yet not disclosed.