Los Angeles Superior Court Document Filing Requirements

WARNING

Applies to

Trial exhibits

New exhibits offered in Trial that have not been pre-marked should conform to the requirements above and should be identified on a supplemental exhibit list added to each copy.

New exhibits offered in Trial that have not been pre-marked should conform to the requirements above and should be identified on a supplemental exhibit list added to each copy.

WARNING

Applies to

Special verdict form

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 departure from a CACI special verdict form should be clearly explained.

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 departure from a CACI special verdict form should be clearly explained.

WARNING

Applies to

Proposed jury instructions

Parties should not request CACI instructions that do not apply when trial begins (e.g., CACI 5013 applies only upon 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

Joint witness list

The witness list time totals, combined with estimates for jury selection, openings, closings, and jury instructions, should match the parties' total estimated trial time and any time limits set at the Case Management Conference.

The total time shown in the witness list may serve as part of the Court's basis for setting time limits at Trial and together with estimated time for jury selection, opening statements, closing arguments, and instructing the jury should match the parties total estimated Trial time and should match the anticipated date to present the case to the jury. The total time should also meet the time limits the Court set (if any) at the Case Management Conference ("CMC").

WARNING

Applies to

Joint appendix

The joint appendix should contain only the pages cited in the briefs (pin cites preferred), may include cover/witness-identification pages for context, and may have labeled side tabs separating different documents.

Only the document pages cited in the parties’ briefs should be included in the joint appendix, not the entire document. To reduce the number of pages, briefs should pin cite, not blanket cite, to pertinent record pages. If it is necessary to provide context to a cited page, the joint appendix may include a document cover page or witness identification page. The joint appendix may have labeled side tabs separating the pages from different documents.

WARNING

Applies to

Ex parte application

The ex parte application must include a copy of the complaint (sentence continues from the prior page).

a copy of your complaint with the ex parte application.

WARNING

Applies to

Joint appendix

A joint appendix may be ordered if the administrative record for a writ of mandate exceeds 450 pages.

If the administrative record for a writ of mandate exceeds 450 pages, the court may order the parties to prepare a joint appendix.

WARNING

Applies to

Proposed verdict form

If the parties cannot agree, each must submit its own proposed verdict form, and any special verdict must be easily understood by the jury without unnecessary questions.

If the parties cannot agree on the verdict form, each party must submit their own 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.

WARNING

Applies to

Stipulation to policies and procedures for mandatory settlement conference

Please also review and execute the Stipulation to Policies and Procedures for Mandatory Settlement Conferences at the following link:

Please also review and execute the Stipulation to Policies and Procedures for Mandatory Settlement Conferences at the following link:

WARNING

Applies to

Trial brief

In bench trials, parties should submit a trial brief setting forth the elements of each cause of action, supporting proposed evidence, the major legal issues with relevant authority, and other helpful information.

Except for joint jury instructions, parties must comply with all of the above requirements. In addition, it is helpful to the Court if the parties submit a trial brief setting forth the elements of each cause of action, the proposed evidence supporting each element, a brief discussion of the major legal issues supported by relevant authority, and a brief discussion of any other information that may assist the Court at trial.

WARNING

Applies to

Ex parte application

Failing to timely reserve a motion date does not constitute irreparable harm.

Failing to timely reserve a motion date does not constitute irreparable harm.

WARNING

Applies to

Joint statement of case

Joint statement of the case must be neutral and not exceed two paragraphs.

The parties shall submit a concise— not to exceed two paragraphs—neutral statement of the case.

WARNING

Applies to

Joint witness list

A party seeking testimony from an unlisted witness must first show good cause to the Court.

Any party who seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the court.

WARNING

Applies to

Joint witness list

A witness omitted from the joint witness list may be excluded from testifying, except to give actual impeachment or rebuttal testimony.

Any witness who is not included on the joint witness list is subject to being excluded from testifying at trial other than for purposes of giving actual impeachment or rebuttal testimony.

WARNING

Applies to

Meet and confer

The Court will inquire about the required meet and confer, and failure to conduct it will likely result in sanctions.

The Court will specifically inquire into this meet and confer at the Final Status Conference and failure to have conducted it will likely result in sanctions.

WARNING

Applies to

Voir dire

Counsel may conduct reasonable voir dire, but may not precondition or indoctrinate jurors or question them about the pleadings or applicable law.

The Court will also permit counsel to conduct reasonable Voir Dire not designed to precondition or indoctrinate the jury, nor may the jurors be questioned about the pleadings or the applicable law.

WARNING

Applies to

Motion in limine

Uncontested motions in limine should be marked "uncontested" in the caption.

Uncontested motions should note "uncontested" in the caption.

WARNING

Applies to

Trial brief

Each party's trial brief should succinctly identify the claims and defenses, major legal issues with supporting authorities, relief claimed and damages calculation, and any other helpful trial information.

Trial Briefs –The Court appreciates it when each party files a trial brief succinctly identifying: (1) the claims and defenses subject to litigation; (2) the major legal issues (with supporting points and authorities); (3) the relief claimed and the calculation of damages sought; and (4) any other information that may assist the Court at trial.

WARNING

Applies to

Motion

Each separately efiled motion and related papers (including all opposition and reply papers) should include the last four digits of the CRS reservation ID number in the uploaded document title.

The Court respectfully requests that each and every separately efiled motion (and related papers) include the last four digits of the CRS reservation ID number to be included in the title that is uploaded. This request includes all opposition and reply papers.

WARNING

Applies to

Motion in limine

Parties filing multiple motions in limine must number them consecutively.

Parties filing more than one motion in limine shall number them consecutively.

WARNING

Applies to

Joint witness list

The joint witness list must end with a grand total of all estimated witness testimony times stated 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 witnesses’ testimony and state the grand total in the last column.

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

Motion in limine

Motions in limine must comply with CCP section 1005 notice provisions and include declarations meeting Los Angeles County Court Rule 3.57(a).

The parties’ counsel and any self-represented parties shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and file declarations that comply with the requirements of Los Angeles County Court Rule 3.57, subdivision (a).

WARNING

Applies to

Non documentary exhibit

Non-documentary exhibits must be marked and a simple written description inserted behind the corresponding numerical tab in the Exhibit Binders.

The parties’ counsel and any self-represented parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the Exhibit Binders.

WARNING

Applies to

Opposition and reply

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

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

WARNING

Applies to

Joint chart of deposition and former testimony designations

Parties intending to use deposition or former trial testimony must meet and confer and jointly prepare a 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's live testimony, the parties' counsel and any self-represented parties shall meet and confer to discuss, and work together to prepare

WARNING

Applies to

Joint exhibit list

Parties must meet and confer 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 an effort to resolve objections to the authenticity and admissibility of each exhibit.

WARNING

Applies to

Exhibit

Court yellow evidence tags (with only case number and exhibit number filled in) must be placed 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.

WARNING

Applies to

Joint witness list

The joint witness list must be organized in specified columns covering witness name (alphabetical), expert status and accommodations, calling party, expected testimony, and estimated direct, cross, and total examination times in hours.

The joint witness list shall be organized with 7 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);

WARNING

Applies to

Motions in limine binder

Each Motions in Limine Binder must include a detailed table of contents showing the tab number and caption title of each motion or opposition.

Please make sure that each such binder has a detailed table of contents indicating the tab number and the caption title of each such motion or opposition included in the binder. This index makes it easier for the parties, the Court, and the Court’s Judicial Assistant to keep track of the MILs.

WARNING

Applies to

Trial document binders

Counsel and self-represented parties are expected to jointly prepare and timely submit the trial document binders.

The Court expects the parties' counsel and any self-represented parties to work together to jointly prepare and timely submit the trial document binders

WARNINGCivil cases

Applies to

Joint witness list

Estimated testimony time should not exceed the trial estimate given at the case management conference, allocating one day each for jury selection and deliberations (e.g., a 5-day estimate allows no more than 3 days of testimony).

should not exceed the trial estimate given at the case management conference, including the allocation of one day for jury selection and one day for deliberations. For example, a 5-day trial estimate means no more than 3 days of testimony.

WARNINGCivil cases

Applies to

Trial brief

Trial briefs are optional but highly recommended in jury trials and are required in court trials.

Trial briefs are optional but are highly recommended in jury trials. Trial briefs are required for court trials.

WARNINGCivil cases

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

WARNINGCivil cases

Applies to

Joint statement to jury

The joint statement to be read to the jury should be a brief, neutral description of the case not exceeding two to three paragraphs.

This statement should be a brief, neutral description of the case. In most instances, the joint statement should not exceed two to three paragraphs.

WARNINGCivil cases

Applies to

Motion

The reservation number should be placed in bold on the caption page of all motion papers.

The reservation number should be placed in bold on the caption page of all motion papers.

WARNING

Applies to

Deposition excerpts

Portions of depositions, interrogatories, or requests for admission to be introduced at trial must be extracted and marked as exhibits.

Portions of depositions, interrogatories, and/or requests for admission, sought to be introduced at trial, shall be extracted and marked as exhibits. (CCP 2025.620; SCLAC Rule 3.158.)

WARNING

Applies to

Exhibits

Two complete sets of exhibits must be lodged: one for the court and one for the witnesses.

Two complete sets of exhibits shall be lodged: one for the court and one for the witnesses.

WARNING

Applies to

Jury instructions

Jury instructions must use Standard Judicial Council of California Civil instructions with all blanks filled in and inappropriate brackets stricken.

Standard Judicial Council of California Civil instructions shall be used with all blanks filled in and inappropriate brackets stricken.

WARNINGCivil cases

Applies to

Case management conference statement

If a party intends to move to modify the Addendum in a particular case, it should so note in its Case Management Conference state

If a party intends to move to modify the Addendum in a particular case, it should so note in its Case Management Conference state

WARNINGCivil cases

Applies to

Trial binder

The trial binder must include Tab G (verdict forms), Tab H (joint exhibit list), Tab I (deposition/page-line designations), and Tab J (stipulations).

Tab G: Joint and/or Contested Verdict Forms Tab H: Joint Exhibit List Tab I: Page and Line Designations for Deposition and Former Testimony Tab J: Stipulations

WARNINGCivil cases

Applies to

Ex parte opposition

Parties opposing an ex parte application must timely file a written opposition, otherwise the Court will assume the ex parte is unopposed.

For this reason, any party opposing an ex parte should timely file a written opposition. Absent a written opposition, the Court will assume the ex parte is unopposed.

WARNINGCivil cases

Applies to

Motion in limine

Motions in limine should not be a request that the Court follow the law. For example, a motion in limine to exclude all hearsay evidence is improper and will be denied. Motions in limine should instead identify the specific evidence to be excluded.

Motions in limine should not be a request that the Court follow the law. For example, a motion in limine to exclude all hearsay evidence is improper and will be denied. Motions in limine should instead identify the specific evidence to be excluded.

INFO

Applies to

Accommodation request

Individuals requiring accommodations should notify the courtroom as early as practicable using Judicial Council Form MC-410 or any other sufficient written request.

Individuals requiring accommodations should notify the courtroom as early as practicable. Requests may be submitted using Judicial Council Form MC-410 or any other written request sufficient to advise the Court of the accommodation sought.

INFO

Applies to

Jury instructions

Parties should bring an electronic flash drive containing the proposed jury instructions at the time of trial for modifications.

Parties/counsel should also be prepared with an electronic flash drive containing the proposed jury instructions at the time of trial for modifications

INFO

Applies to

Proposed voir dire questions

Proposed voir dire questions are optional; a short list may be submitted for unique issues, with the Court conducting voir dire first followed by parties/counsel.

If there are unique issues a party wishes to have the Court task, a short list of questions may be proposed. (The Court initially conducts voir dire, followed by parties/counsel.)

INFOCivil cases

Applies to

Motion in limine

The following motions in limine are deemed filed and granted: (A) to preclude non-testifying, non-party witnesses from being present in the courtroom when others are testifying (see Evid. Code § 777) (B) to preclude reference to the liability insurance in a case defended by that liability insurance policy; and (C) to preclude references to settlement discussions.

The following motions in limine are deemed filed and granted: (A) to preclude non-testifying, non-party witnesses from being present in the courtroom when others are testifying (see Evid. Code § 777) (B) to preclude reference to the liability insurance in a case defended by that liability insurance policy; and (C) to preclude references to settlement discussions.

INFO

Applies to

Jury instructions

The Court strongly encourages use of CACI jury instructions (recommended, not mandatory).

The Court strongly encourages the use of CACI jury instructions.

INFO

Applies to

Trial brief

Trial briefs are highly recommended (though not mandatory) for each party in all cases, whether bench or jury trial.

TRIAL BRIEFS for each party are highly recommended in all cases, whether bench or jury trial.