Los Angeles Superior Court Document Filing Requirements

INFOCivil cases

Applies to

Case management statement

Case management statements are not required for initial case management conferences.

NO CASE MANAGEMENT STATEMENT IS REQUIRED.

INFOCivil cases

Applies to

Case management statement

No case management statement is required in this department, notwithstanding the CRC 3.700 case management rules.

NO CASE MANAGEMENT STATEMENT IS REQUIRED.

INFO

Applies to

Trial brief

Trial briefs are strongly encouraged (not mandatory) and should describe the facts/claims/defenses, elements and burden of proof, major legal issues with points and authorities, and relief and damages sought.

Trial Briefs are strongly encouraged to be filed and should contain: • A brief description of the facts, claims, and defenses subject to litigation. • The elements and burden of proof for each of the cause(s) of action. • A list of major legal issues anticipated with points and authorities supporting and defending the issues. • A brief statement of the relief claimed, and calculations of damages sought. • Any further information that counsels believes may assist the court in ruling upon trial objections or matters that may arise during trial.

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Applies to

Joint statement

The court requests (does not mandate) that counsel submit a Joint Witness List and a Joint Statement of the case to be read to the jury.

The Court requests that Counsel submit a Joint Witness List and Joint Statement of the case to be read to the jury.

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Applies to

Operative complaint

Plaintiff and cross-complainant counsel are requested to provide the Court a copy of the operative complaint(s) before trial and to indicate in advance any causes of action that will be dismissed.

Counsel for the 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 any cause(s) of action which will be dismissed.

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Applies to

Request for accommodation

Accommodation requests should be filed early using form MC-410 or any written format.

Requests for accommodation should be filed early using form MC-410 or any written format.

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Applies to

Proposed order

Proposed orders must comply with California Rules of Court, rule 3.1312.

Proposed orders must comply with California Rules of Court, rule 3.1312.

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Applies to

Objection to proposed judgment

Objections to proposed judgments must comply with California Rules of Court, rule 3.1590.

Objections to proposed judgments must comply with California Rules of Court, rule 3.1590.

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Applies to

Proposed order

The Court may sign a proposed order without delay if no timely objection is filed or the proponent files a statement that the non-proposing party failed to timely object under CRC 3.1312.

The Court may assume there is no objection to a proposed order and sign the order without delay, if the non-proposing party has not timely objected or the proponent has filed a statement that the non-proposing party failed to timely object per California Rules of Court, rule 3.1312.

INFO

Applies to

Jury instructions

The court expects parties to request an appropriate CACI jury instruction 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.

INFOCivil cases

Applies to

Trial brief

Trial briefs are optional, but if filed they should succinctly identify the claims and defenses and the major legal issues with supporting points and authorities.

Each party may, but is not required to, file a trial brief succinctly identifying: (a) the claims and defenses subject to litigation; (b) the major legal issues (with supporting points and authorities);

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Applies to

Stipulation

Must include

proposed order

Stipulation and proposed order required to request mandatory settlement conference.

The court will consider referring the parties to a mandatory settlement conference, if counsel file a stipulation and proposed order seeking a mandatory settlement conference.

INFO

Applies to

Jury instructions

The Court strongly encourages (but does not require) the use of CACI jury instructions.

The Court strongly encourages the use of CACI jury instructions.

INFO

Applies to

Trial brief

Each party may, but is not required to, file a trial brief succinctly identifying: (1) the claims 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, such as evidentiary issues that are anticipated that may merit discussion.

Each party may, but is not required to, file a trial brief succinctly identifying: (1) the claims 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, such as evidentiary issues that are anticipated that may merit discussion.

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Applies to

Proposed jury instructions

During trial, the parties may request additional applicable jury instructions if circumstances change.

During trial, if circumstances change, the parties may request additional applicable jury instruction.

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Applies to

Voir dire questions

The parties should collaborate to propose additional voir dire questions for prospective jurors.

Additionally, the parties should collaborate to propose any additional voir dire questions they wish the Court to ask prospective jurors.

INFO

Applies to

Trial brief

Trial briefs are optional; if filed, they should succinctly identify disputed claims and defenses, major legal issues with supporting authorities, relief and damages sought, and other information assisting the court at trial.

Each party may, but is not required to, file a trial brief succinctly identifying: (1) the claims 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.

INFO

Applies to

Accommodation request

Accommodation requests should be filed early using form MC-410 or any written format.

Requests for accommodation should be filed early using form MC-410 or any written format.

INFO

Applies to

Trial brief

Trial briefs are optional, but if filed must succinctly identify disputed claims and defenses, major legal issues with supporting authorities, relief and damages calculation, and other trial-assisting information.

Each party may, but is not required to, file a trial brief succinctly identifying: (1) the claims 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.

INFOCivil cases

Applies to

Document production

Documents responsive to more than one request for production need only be produced once, provided the response indicates the multiple responsiveness.

If documents are responsive to more than one request for production, the response should so indicate and the documents only need to be produced only once.

INFOCivil cases

Applies to

Highly confidential designation

Parties may agree to include the case name and number as part of the 'Highly Confidential' designation.

The parties may agree that a case name and number are to be part of the “Highly Confidential” designation.

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Applies to

Trial binder

In bench trials, the Trial Binder only needs Tabs A, B, C, H, and I.

For trials by the court without a jury, the Trial Binder shall only include the documents listed under Tabs A, B, C, H, and I.

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Applies to

Motion in limine

Parties and counsel are strongly encouraged to stipulate to uncontested motions in limine.

The parties/counsel are strongly encouraged to stipulate to uncontested motions.

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Applies to

Motion in limine reply

Replies to motions in limine are not required, and the parties are encouraged to stipulate to waive them.

Replies are not required. The parties are encouraged to stipulate to waive the filing of replies to motions in limine.

INFO

Applies to

Proposed juror questionnaire

A proposed juror questionnaire must be filed if requested, and it may not ask about prospective jurors' residence locations.

Filed-Proposed Juror Questionnaire, if requested. Questionnaires will not include questions concerning the location of the prospective jurors' residences in accordance with changes to the Standards for Judicial Administration.

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Applies to

Ex parte application

When filing an ex parte application to advance a summary judgment/adjudication hearing because no reservation dates are available before trial, the moving party is advised to also include an alternative request to continue the trial to a date after the hearing.

Because it is usually extremely difficult for the court to advance the hearing on a motion for summary judgment or summary adjudication, if a party files an ex parte application to advance the hearing on such a motion because no hearing dates are available on the Court Reservation System before the trial date, the moving party should also consider including an alternative request that the court continue the trial to a date after the hearing on the motion.

INFO

Applies to

Joint witness list

Objections to witnesses need not be made on the joint witness list, and the list does not waive or preserve objections.

There is no need to make objections to any witness on the joint witness list. The parties do not waive or preserve objections on the joint witness list.

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Applies to

Stipulation

Must include

proposed order

If the parties stipulate to an order, they may file a stipulation and proposed order instead of an ex parte application, which the court generally decides promptly.

If the parties stipulate to an order, there is no need to file an ex parte application. The parties may instead file a stipulation and proposed order. The court generally promptly decides whether to grant stipulated proposed orders.

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Applies to

Joint exhibit list

Specific objections need not be made on the joint exhibit list, and the list does not waive or preserve objections.

There is no need to make specific objections on the joint exhibit list. The parties do not waive or preserve objections on the joint exhibit list.

INFO

Applies to

Trial brief

Filing a trial brief is optional; if filed, it must succinctly identify the claims and defenses still in dispute, the major legal issues with supporting points and authorities, the relief and calculation of damages sought, and any other information that may assist the court at trial.

Each party may, but is not required to, file a trial brief succinctly identifying: (1) the claims 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.

INFOCivil cases

Applies to

Final jury instructions and verdict forms

Counsel are jointly responsible for preparing the final set of jury instructions and verdict forms after the Court rules on any disputes.

Counsel are jointly responsible for the preparation of a final set of jury instructions and verdict fonns after the Court rules on any disputes.

INFOCivil cases

Applies to

Final status conference binder

Counsel and self-represented litigants are expected to work together to jointly prepare and submit the trial binders required by the Final Status Conference Order filed in every case set for trial.

Department P has a Final Status Conference Order that is filed in every case set for trial. A copy of the Order is attached. The Court expects counsel and self-represented litigants to work together to prepare and submit jointly the binders required by the Order.

INFOCivil cases

Applies to

Trial brief

Trial briefs are encouraged but not required, particularly for non-typical or technical issues.

Trial briefs are encouraged but not required. In cases where an issue is not typical or may be technical in nature, the parties should prepare trial briefs that address important issues in the case.

INFO

Applies to

Trial brief

Trial briefs are optional; if filed, each party's trial brief must succinctly identify the claims and defenses remaining in dispute, the major legal issues with supporting authorities, the relief and calculation of damages sought, and any other information that may assist the court at trial.

Each party may, but is not required to, file a trial brief succinctly identifying: (1) the claims 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.

INFO

Applies to

Jury instructions

The court generally does not give redundant jury instructions and, absent unusual circumstances, will give duplicate instructions such as CACI 105 and CACI 5001 only once.

The court generally does not give the jury redundant instructions. For example, CACI 105 and CACI 5001 are the same. Unless unusual circumstances warrant otherwise, the court shall only give this instruction once.

INFOCivil cases

Applies to

Joint statement

Unresolved discovery disputes will be litigated through informal, streamlined proceedings using joint statements that present opposing positions in a point/counterpoint format.

If the parties cannot resolve their disputes, the Court will invite them to litigate their disagreements by way of informal, streamlined proceedings, using joint statements presenting opposing positions in a point/counterpoint format.

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Applies to

Request for official court reporter

A party with a CRC 3.55(7) fee waiver may request an official court reporter by filing local form LACIV 2699 as soon as possible before the hearing or trial.

A party who has received a fee waiver pursuant to CRC 3.55(7) may request an official court reporter by filing local form LACIV 2699 as soon as possible before the hearing or trial.

INFO

Applies to

Interpreter request

Requests may be made using form MC-410 or in any other written format.

Requests may be made using form MC-410 or in any other written format.

INFO

Applies to

Trial brief

Trial briefs are optional, but if filed they must identify the disputed claims and defenses, major legal issues with supporting authorities, relief and damages sought, and other information assisting the court.

Each party may, but is not required to, file a trial brief succinctly identifying: (1) the claims 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.

INFO

Applies to

Motion in limine

Motions in limine should be specific and tailored to the facts of the case rather than generic or summarizing general legal principles.

Parties are discouraged from filing generic MILs that lack specificity, that are not specifically tailored to the facts of the case, or that summarize general legal principles (e.g., exclude all discovery not disclosed, exclude all hearsay evidence, prohibit reference to settlement negotiations, exclude evidence of a party’s financial condition).

INFO

Applies to

Statement of the case

A Statement of the Case is a brief, neutral description of the case to be read to the jury. In most instances, it should not exceed two paragraphs.

A Statement of the Case is a brief, neutral description of the case to be read to the jury. In most instances, it should not exceed two paragraphs.

INFO

Applies to

Proposed special verdict form

Proposed special verdict forms should be easy for the jury to use and understand and should not require answers to 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.

INFO

Applies to

Jury instructions

Parties are expected to request the applicable CACI instruction instead of a specially prepared instruction.

If there is an applicable CACI instruction on a point of law, the Court expects the parties to request the CACI instruction instead of a specially prepared instruction.

INFO

Applies to

Trial brief

Trial briefs are optional in jury trials, though they can be useful to the Court.

Trial briefs are not required in jury trials but can be useful to the Court.

INFOCivil cases

Applies to

Joint deposition chart

Deposition testimony used solely for impeachment may be omitted from the deposition chart.

Deposition testimony to be used solely for impeachment need not be included.

INFOCivil cases

Applies to

Joint exhibit list

Exhibit list objections must be stated without argument or response.

There should be no argument or response to an objection; the Court only requires the objection to be stated so that everyone knows what it is.

INFOCivil cases

Applies to

Joint exhibit list

Exhibits used solely for impeachment may be omitted from the joint exhibit list.

The exhibit list need not contain exhibits that are truly to be used only for impeachment.

INFO

Applies to

Ex parte application

In ex parte applications to advance a summary judgment or summary adjudication hearing when no hearing dates are available before trial, the Court recommends also including an alternative request to continue the trial to a date after the hearing.

Because it is usually extremely difficult for the Court to advance the hearing on a motion for summary judgment or summary adjudication, if a party files an ex parte application to advance the hearing on such a motion because no hearing dates are available on the Court Reservation System before the trial date, the moving party should also consider including an alternative request that the Court continue the trial to a date after the hearing on the motion.

INFO

Applies to

Trial brief

Trial briefs are optional; if filed, they should succinctly identify the disputed claims and defenses, major legal issues with supporting authorities, relief and damages calculation sought, and any other information that may assist the Court at trial.

Each party may, but is not required to, file a trial brief succinctly identifying: (1) the claims 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.

INFO

Applies to

Jury instructions

The Court strongly encourages (but does not require) the use of CACI jury instructions.

The Court strongly encourages the use of CACI jury instructions.