Los Angeles Superior Court Document Filing Requirements

CRITICAL

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include the notice in the declaration and present a proposed order with the moving papers.

The notice must be included in the declaration and a proposed order must be presented with the moving papers.

CRITICAL

Applies to

Proposed verdict form

For jury trials, parties must jointly file a proposed verdict form acceptable to all parties, or, if they cannot agree, each party must separately file a proposed verdict form.

For jury trials, the parties’ counsel and any self-represented parties shall work together to prepare and file a joint proposed general verdict form or a joint proposed special verdict form acceptable to all parties. (Local Rule 3.25, subd. (g)(8).) If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

CRITICALCivil cases

Applies to

Notice of settlement

Notice of settlement must not be filed until all parties have signed the settlement agreement.

BUT DO NOT FILE A NOTICE OF SETTLEMENT UNTIL ALL PARTIES ON BOTH SIDES HAVE SIGNED THE SETTLEMENT AGREEMENT.

CRITICALCivil cases

Applies to

Original order or judgment

The lodged original order must not say 'proposed' in the caption and must not have a proof of service attached to it.

It should not say "proposed" in the caption and should not have a proof of service attached to it.

CRITICALCivil cases

Applies to

Motion

Must include

proposed order

A “proposed order” should continue to be included in the package of moving papers and served upon the parties.

A “proposed order” should continue to be included in the package of moving papers and served upon the parties.

CRITICALCivil cases

Applies to

Motion

Must include

proposed order

A "proposed order" should continue to be included in the package of moving papers and served upon the parties.

A "proposed order" should continue to be included in the package of moving papers and served upon the parties.

CRITICALCivil cases

Applies to

Waiver of participation

Parties/counsel of record must participate by phone unless a waiver of participation is filed earlier.

of record must be on the phone unless a waiver of participation is earlier filed.

CRITICALCivil cases

Applies to

Original order for signature

The Court asks that all moving parties lodge the original order or judgment that they wish the Judge in Department 636 to sign no later than the hearing set on a motion or as requested by the court after trial. It should not say “proposed” in the caption and should not have a proof of service attached to it. Do not put “Proposed” on that original order or judgment, and most importantly, DO NOT ATTACH A PROOF OF SERVICE TO THE ORIGINAL!

The Court asks that all moving parties lodge the original order or judgment that they wish the Judge in Department 636 to sign no later than the hearing set on a motion or as requested by the court after trial. It should not say “proposed” in the caption and should not have a proof of service attached to it. Do not put “Proposed” on that original order or judgment, and most importantly, DO NOT ATTACH A PROOF OF SERVICE TO THE ORIGINAL!

CRITICALCivil cases

Applies to

Original order or judgment

The Court asks that all moving parties lodge the original order or judgment that they wish the Judge in Department 636 to sign no later than the hearing set on a motion or as requested by the court after trial.

The Court asks that all moving parties lodge the original order or judgment that they wish the Judge in Department 636 to sign no later than the hearing set on a motion or as requested by the court after trial.

CRITICALCivil cases

Applies to

Exhibit list

Counsel must agree on allocated blocks of exhibit numbers (per LASC Local Rule 3.53), and the exhibit list must include the exhibit number and a brief description of each exhibit.

Counsel are to agree on a block of numbers to be allocated to each party for exhibits. (See LASC Local Rule 3.53) The exhibit list shall include the exhibit number and a brief description of the exhibit.

CRITICALCivil cases

Applies to

Special verdict forms

The parties must meet and confer and file any special verdict forms.

The parties are ordered to meet and confer and file any special verdict forms.

CRITICALCivil cases

Applies to

Proposed special verdict forms

If the parties do not agree, each party must submit its own proposed special verdict (or special fact finding) forms accompanied by points and authorities supporting the request.

If no agreement is reached, each party is to submit their own proposed special verdict (or special fact finding) forms along with points and authorities supporting what is requested.

CRITICALCivil cases

Applies to

Summary judgment papers

In summary judgment papers, every factual statement must be supported by a citation to the supporting declaration(s) and/or exhibit(s) placed next to the statement; citing only the 'statement of undisputed facts' is not permitted.

When a factual claim is made in these documents, just as is the case with regard to all other kinds of motions and responsive papers, a citation to the declaration(s) and/or exhibit(s) supporting that claim assertion must be set forth next to the factual statement, NOT A REFERENCE TO THE "STATEMENT OF UNDISPUTED" FACTS WHICH HAS THE EFFECT OF DIRECTING THE COURT TO SEARCH ONE SOURCE IN ORDER TO GET TO ANOTHER SOURCE FOR EVIDENTIARY SUPPORT FOR THE FACTS IN ISSUE!

CRITICALCivil cases

Applies to

Motion in limine

Motions in limine seeking to restrict opposing counsel's conduct require prior contact with opposing counsel confirming intent to engage in the conduct.

No motion in limine is to be filed asking the court to order that opposing counsel not do “x,” “y,” or “z,” unless that opposition attorney has first been contacted and stated that they intend to do what the moving party wants to prevent.

CRITICALCivil cases

Applies to

Brief

Motions and briefs must include evidentiary citations next to factual claims, not just references to separate statement of undisputed facts.

When a factual claim is made in these documents, just as is the case with regard to all other kinds of motions and responsive papers, a citation to the declaration(s) and/or exhibit(s) supporting that claim assertion must be set forth next to the factual statement, NOT A REFERENCE TO THE “STATEMENT OF UNDISPUTED” FACTS WHICH HAS THE EFFECT OF DIRECTING THE COURT TO SEARCH ONE SOURCE IN ORDER TO GET TO ANOTHER SOURCE FOR EVIDENTIARY SUPPORT FOR THE FACTS IN ISSUE!

CRITICALCivil cases

Applies to

Joint statement of the case

JOINT STATEMENT OF THE CASE – For jury trials, the parties shall prepare and file a joint written statement of the case for the Court to read to the jury. The Joint Statement of the Case should be brief and factual.

JOINT STATEMENT OF THE CASE – For jury trials, the parties shall prepare and file a joint written statement of the case for the Court to read to the jury. The Joint Statement of the Case should be brief and factual.

CRITICALCivil cases

Applies to

Trial record

Parties must either provide a court reporter for court and jury trials or submit daily agreed statements/proposed settled statements during trial.

YOU MUST PROVIDE A COURT REPORTER FOR TRIAL (COURT AND JURY TRIAL) OR SUBMIT DAILY AGREED STATEMENTS / PROPOSED SETTLED STATEMENTS during a trial.

CRITICALCivil cases

Applies to

Joint witness list

The parties must file a joint witness list identifying all intended witnesses (excluding impeachment and rebuttal), with each witness's name, expert status, and estimated direct, cross, and re-direct examination lengths.

JOINT WITNESS LIST – The parties shall prepare and file a joint witness list identifying all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. The joint witness list will identify each witness by name, specify which witnesses are experts, estimate the length of direct examination, cross-examination, and re-direct examination of each,

CRITICALCivil cases

Applies to

Joint exhibit list

Parties must meet and confer before filing the joint exhibit list and note stipulations, or specify all objections, in the respective column.

Prior to filing the joint exhibit list, the parties shall meet and confer to determine whether they will stipulate to the authenticity and/or admissibility of each exhibit or whether there are objections to any exhibit. If there are stipulations, the parties shall note that in the respective column. If not, the objecting party shall specify all objections in the respective column.

CRITICALCivil cases

Applies to

Motion in limine

Motions in Limine must be in writing, numbered, filed and served per Local Rule 3.25(f)(2), and accompanied by a declaration representing that the motion was discussed with opposing counsel, or the motion will be summarily denied; boilerplate or form motions are disfavored.

Motions in Limine must be in writing, numbered, and shall be filed and served on opposing parties in accordance with Local Rule 3.25(f)(2). The motion must be accompanied by a declaration that includes, among other items, a representation that the motion has been discussed with opposing counsel. If not, the motion will be summarily denied. Boilerplate or form motions are disfavored.

CRITICALCivil cases

Applies to

Verdict form

Parties must file a joint proposed general or special verdict form; if they cannot agree, each party must separately file a proposed verdict form.

The parties shall prepare and file a joint proposed general verdict form or special verdict form. The parties are urged to agree on a verdict form. If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

CRITICALCivil cases

Applies to

Joint exhibit list

Parties must file a joint exhibit list organized with columns identifying the exhibit, offering party, stipulation to authenticity/admissibility, date identified, and date admitted.

The parties shall prepare and file a joint exhibit list organized with columns identifying: (1) the exhibit, (2) which party is offering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) the date on which the exhibit was identified, and (5) the date on which the exhibit was admitted.

CRITICALCivil cases

Applies to

Exhibit binder

Parties must supply an exhibit binder to each opposing party, with non-documentary exhibits represented by a simple written description.

The parties must also supply an exhibit binder to each opposing party. Non-documentary exhibits shall be represented in the binder with a simple written description.

CRITICALCivil cases

Applies to

Trial brief

Trial briefs are mandatory in all cases and must include seven specified elements, including facts/issues, elements and burden of proof, stipulations, anticipated legal and evidentiary issues, relief and damages calculations, a joint list of jury instructions, and other helpful information.

TRIAL BRIEFS – Trial Briefs are mandatory in all cases and must include: (1) a brief description of the facts and the claims and defenses presented and the issues to be decided; (2) the elements and burden of proof for each of the cause(s) of action; (3) a brief statement of ultimate facts or issues to which you will stipulate; (4) a list of major legal and evidentiary issues anticipated with succinct points and authorities supporting and defending the issues; (5) a brief statement of the relief claimed, including a succinct breakdown of the elements of damages claimed, and calculations of damages sought (do not hesitate to use bullet points); (6) a joint list of jury instructions; and (7) any further information the parties believe may assist the Court in ruling upon trial objections or matters that may arise during trial.

CRITICALCivil cases

Applies to

Jury instructions

Parties must file a joint list of requested jury instructions with fully completed copies in numerical order, file disputed instructions separately identifying the requesting party, and meet and confer on a final set no later than two days before the conclusion of evidence.

The parties shall prepare and file a joint list of all jury instructions requested and 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. Not later than two days before the conclusion of evidence, the Court will require the parties to meet and confer to create a final set of instructions.

CRITICALCivil cases

Applies to

Joint trial binder

Parties must prepare a tabbed Joint Trial Binder containing trial briefs, operative pleadings, motions in limine (with oppositions and replies), joint statement of the case, witness list, exhibit list, jury instructions, voir dire questions, and verdict forms, separately tabbed.

The parties shall prepare a tabbed Joint Trial Binder for the Court to include the above-described trial briefs; operative pleadings; motions in limine in numerical order with opposition and reply for each number; joint statement of the case; joint witness list; joint exhibit list; jury instructions; voir dire questions; and verdict form(s) separately tabbed.

CRITICALCivil cases

Applies to

Voir dire questions

Parties must prepare and file a joint list of voir dire questions for the Court's questioning and may independently question prospective jurors afterward.

The Court will question the prospective jurors during voir dire. The parties shall prepare and file a joint list of questions to be asked by the Court. The parties will have an opportunity to independently question the prospective jurors following the Court’s questioning.

CRITICAL

Applies to

Trial binder

Proposed Instructions: shall be included in the trial binder. These should include a jointly submitted packet of all requested and properly edited CACI or special instructions that are agreed to or not. The instructions shall be submitted in the proper format for presentation to the jury.

Proposed Instructions: shall be included in the trial binder. These should include a jointly submitted packet of all requested and properly edited CACI or special instructions that are agreed to or not. The instructions shall be submitted in the proper format for presentation to the jury.

CRITICAL

Applies to

Notice of related cases

Notice of Related Cases must be filed in each related case per Cal. Rules of Court 3.300.

The Court requires timely compliance with Cal. Rules of Court 3.300 Re: Notice of Related Cases. The Notice must be filed in each related case.

CRITICAL

Applies to

Statement of the case

The Statement of the Case must be jointly prepared by the parties, short and non-argumentative for reading to the jury, signed by all parties, and filed with the Court.

Statement of the Case: must be prepared jointly by the parties. It should be a short, non-argumentative written statement of the case to be read to the jury. It must be signed by all parties and filed with the Court.

CRITICAL

Applies to

Case management statement

Case management statements must be submitted per Cal. Rules of Court 3.725.

Counsel must comply with their obligation to submit case management statements pursuant to rule 3.725 of the California Rules of Court.

CRITICAL

Applies to

Depositions

All original or certified copies of depositions must be lodged with the Court before trial begins.

Depositions: All original/certified copy of depositions must be lodge with the Court prior to the beginning of trial.

CRITICAL

Applies to

Motion in limine

Motions in limine must be in writing.

All motions in limine must be in writing and must be filed and served at least 10 court days before the FSC.

CRITICAL

ii. A brief outline of the nature of the case; iii. Proposed questions and voir dire procedures; iv. The witness names to be read to the jury; v. Any witness or attorney scheduling issues; any witness issues (e.g., availability, need for interpreters, etc.); Any anticipated evidentiary or other legal issues; vi. Any party stipulations; and any other trial issues that the parties reasonably can anticipate.

ii. A brief outline of the nature of the case; iii. Proposed questions and voir dire procedures; iv. The witness names to be read to the jury; v. Any witness or attorney scheduling issues; any witness issues (e.g., availability, need for interpreters, etc.); Any anticipated evidentiary or other legal issues; vi. Any party stipulations; and any other trial issues that the parties reasonably can anticipate.

CRITICAL

Applies to

Transcript of recordings

Parties must provide transcripts of recordings under Cal. R. Ct. 2.1040, and a party receiving the transcript before announcing ready waives any objection to its accuracy unless raised at the first trial appearance.

The parties shall comply with Cal. R. Ct. 2.1040, requiring the provision of a transcript of various recordings. The Court shall deem that the party receiving the transcript before announcing "ready" waives any objection to the accuracy of the transcript unless raised at the first trial appearance before this Court.

CRITICAL

Applies to

Request for court reporting services

A fee-waiver party's request for an official court reporter must be made on local form LASC LACIV 269 (Request for Court Reporting Services by a Party with a Fee Waiver).

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

CRITICAL

Applies to

Opposition

Oppositions to motions in limine must be in writing.

Any opposition to a motion in limine must be in writing and must be filed and served at least 5 court days before the FSC.

CRITICAL

Applies to

Joint exhibit list

The joint exhibit list must be prepared jointly in chart format with columns for exhibit title/number, stipulation status, objections, and the Court's trial notation, and must be signed by all parties and filed with the Court.

Exhibit list: must be prepared jointly by the parties. It should be prepared in chart format with each exhibit identified by title and its assigned exhibit number. Additional columns should indicate whether the exhibit will be admitted by stipulation, authenticated by stipulation, or challenged with objections, which shall be set forth in a column for objections. A final column should be included on the right for the Court's notation of whether the exhibit was admitted at trial. The joint exhibit list must be signed by all parties and filed with the Court.

CRITICAL

Applies to

Trial binder

The trial binder must include all operative pleadings, including operative complaints, cross-complaints, and the operative answers.

All operative pleadings: must be included in the trial binder. This includes the operative complaints and cross-complaints and the operative answers thereto.

CRITICAL

Applies to

Verdict form

The verdict form must be jointly prepared by the parties; if they cannot agree, the Court will provide a general verdict form to the jury.

Verdict Form: must be jointly prepared by the parties. If the parties cannot agree on joint verdict forms, then the Court will provide a general verdict form to the jury.

CRITICAL

Applies to

Trial brief

Trial briefs must be signed, filed, and served on all parties.

The briefs must be signed, filed with the Court and served on all parties.

CRITICAL

Applies to

Request for court reporting services

Court reporter requests with fee waiver must use form LASC LACIV 269, filed 10 calendar days before hearing.

The Request for Court Reporting Services by a Party with a Fee Waiver should be filed at least ten calendar days before the hearing or trial for which the reporter is requested. The request must be made by using the local form (LASC LACIV 269).

CRITICAL

Applies to

Joint witness list

The joint witness list must include witnesses' names, time estimates for direct and cross-examination, and interpreter needs, and must be signed by all parties and filed with the Court.

witnesses' names, time estimates for direct and cross-examination, and whether the witnesses will be assisted by an interpreter. The joint witness list must be signed by all parties filed with the Court.

CRITICAL

Applies to

Proposed jury instructions

The joint list of proposed jury instructions must be prepared jointly in chart format showing proponents and opponents of each instruction, and must be signed by all parties and filed with the Court.

List of proposed jury instructions: must be prepared jointly by the parties. It should be prepared in chart format to include all CACI and special jury instructions that are jointly proposed by the parties as well as those that are proposed by only some of the parties but opposed by another party. A column in the chart must indicate the proponent(s) and opponent(s) of each proposed instruction. A final column should be included on the right of the Court's notation of whether the instruction was given at trial. The joint list of jury instructions must be signed by all parties and filed with the Court.

CRITICAL

Applies to

Case management statement

Counsel must submit case management statements per CRC 3.725, and failure to comply with related rules may result in monetary sanctions and/or delay in trial setting.

Counsel must comply with their obligation to submit case management statements pursuant to rule 3.725 of the California Rules of Court. Failure to comply with the Cal. Rules of Court., rules 3.722, 3.724, 3.727 and 3.728, Los Angeles County Superior Court Rules 3.24 and 3.25, and/or this court's scheduling orders may result in monetary sanctions and/or delay in trial setting.

CRITICAL

Applies to

Notice of related cases

A notice of related cases complying with California Rules of Court 3.300 must be timely filed in each related case.

The Court requires timely compliance with Cal. Rules of Court 3.300 Re: Notice of Related Cases. The Notice must be filed in each related case.

CRITICAL

Applies to

Reply brief

Reply briefs on motions in limine must be in writing and properly filed and served.

Reply briefs must be in writing and properly filed and served.

CRITICAL

Applies to

Motion in limine

Parties must assign different, sequential numbers or letters to their motions in limine to avoid duplication (e.g., Plaintiff numbered, Defendant lettered).

The parties must assign different, sequential numbers or letters to their motions in limine. For example, Plaintiff’s motions in limine may be numbered 1-5; Defendant’s motions in limine may be lettered A-E; additional parties may use double numbers or letters or some other agreed- upon designation to avoid duplication and confusion.

CRITICAL

Applies to

Page line designation chart

Parties must meet and confer and jointly file a designation chart with five required columns before using deposition or former trial testimony in lieu of live testimony (except purely for impeachment or rebuttal).

If the parties/counsel intend to use deposition testimony or former trial testimony in lieu of any witness's live testimony, other than exclusively for impeachment or rebuttal, the parties/counsel shall meet and confer and jointly prepare and file a chart with columns for each of the following: 1) the line and page designations of the deposition or former testimony requested for use, 2) objections, 3) counter-designations, 4) any responses thereto, and 5) the Court's ruling.

CRITICAL

Applies to

Trial setting conference joint filings

Parties must meet and confer at least 14 calendar days before the TSC and jointly file a statement of the issues to be tried, a witness list with time estimates, and a report on the status of discovery at least 7 calendar days before the hearing.

Counsel and/or self-represented parties are ordered to meet and confer in person or by video at least 14 calendar days in advance of the TSC and, at least 7 calendar days in advance of the hearing, jointly file (1) a statement of the issues to be tried, (2) a witness list with time estimates, and (3) a report on the status of discovery.