Los Angeles Superior Court Document Filing Requirements

INFO

Applies to

Joint exhibit list

The joint exhibit list should avoid duplicative exhibits.

The list should avoid duplication.

INFO

Applies to

Trial brief

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

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

INFOCivil cases

Applies to

Trial brief

Trial briefs are encouraged but not required, and parties should prepare them where issues are atypical or technical.

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 but preferred; if filed, each party's trial brief must contain a description of claims and defenses, major legal issues with supporting authorities, the relief claimed and damages calculation, and any other information assisting the court.

TRIAL BRIEFS (Optional but Preferred) A trial brief from each party containing: (1) A brief description of the claims and defenses subject to litigation; (2) List of major legal issues anticipated with supporting points and authorities; (3) A brief statement of the relief claimed and calculation of damages sought; and (4) Any other information which counsel believes may assist the court in ruling upon trial objections or matters that may arise in trial.

INFOCivil cases

Applies to

Trial brief

The Court recommends (but does not require) that each side file a trial brief in either a bench or jury trial.

Trial Briefs: The Court recommends that each side file a trial brief in either a bench or jury trial.

INFOCivil cases

Applies to

Proposed verdict form

Counsel are encouraged to agree on a special verdict form and submit it with the joint materials; if they cannot agree, the Court may prepare a general verdict form.

Counsel are encouraged to agree upon a special verdict form and submit it to the Court with the other joint materials. If counsel cannot agree on a special verdict form, the Court may prepare a general verdict form.

INFO

Applies to

Proposed jury instructions

The court expects parties to request applicable CACI jury instructions instead of specially prepared 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.

INFOCivil cases

Applies to

Judgment

Judgments must be delivered to the Clerk's Office for processing.

Judgments: Deliver to Clerk's Office for processing.

INFOCivil cases

Applies to

Trial brief

Trial briefs are encouraged (not required) for unique or out-of-the-ordinary issues.

Trial Briefs on unique or out-of-ordinary issues encouraged.

INFOCivil cases

Applies to

Default judgment package

Default packages must be submitted to the Clerk's Office for processing.

Default Packages: Submit to Clerk's Office for processing.

INFOCivil cases

Applies to

Orders

Orders must be delivered to either the Clerk's Office or the Courtroom.

Orders: Delivered to either Clerk's Office or Courtroom.

INFO

Applies to

Jury instructions

Each counsel may submit specially requested, properly edited instructions not requested by opposing counsel, inserted into the joint packet for the court's consideration during trial.

Each counsel may submit specifically requested and properly edited instructions not requested by any opposing counsel. These instructions shall be inserted into the aforementioned packet of the jointly submitted jury instructions, all to be considered and discussed by the court at an appropriate time during the pendency of the trial.

INFO

Applies to

Proposed verdict form

Parties should strive to ensure the proposed verdict form guards against an award of duplicative damages.

The parties should strive to ensure that the proposed verdict form ensures against an award of duplicative damages.

INFO

Applies to

Concise joint statement

The concise joint statement is a brief, neutral case description to be read to the jury and should generally not exceed two paragraphs.

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

INFO

Applies to

Mini opening statement

Parties wishing to give a mini opening statement before voir dire must write it out, share it with opposing counsel, and read it verbatim to the jury.

If the parties wish to make a mini opening statement prior to conducting their voir dire they must write out their brief statement and share it with opposing counsel. They will then be required to read their statement verbatim to the jury at the appropriate time.

INFO

Applies to

Jury instructions

The Court strongly encourages the use of CACI jury instructions.

The Court strongly encourages the use of CACI jury instructions.

INFO

Applies to

Trial brief

Trial briefs are highly recommended 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.

INFOCivil cases

The parties are encouraged, when reasonably necessary, to accommodate requests to take witnesses out of order.

The parties are encouraged to accommodate each other with regard to taking witnesses out of order if reasonably necessary.

INFOCivil cases

Applies to

Settlement agreement

For a conditional settlement, the parties are encouraged to include a stipulation for the Court to retain jurisdiction under CCP section 664.6.

The parties are encouraged to include a stipulation for the Court to retain jurisdiction pursuant to CCP section 664.6 if the settlement is conditional.

INFOCivil cases

The parties are permitted to arrange for a privately retained court reporter at hearings.

The parties may arrange for a privately retained court reporter at hearings.

INFOCivil cases

Applies to

Trial brief

Each party may file an optional Trial Brief succinctly identifying the specified trial information.

Each party may file a Trial Brief succinctly identifying the following:

INFO

Applies to

Proposed jury instructions

Parties should consider and may suggest the order of jury instructions; the Court typically reads CACI 100 and 200 series before opening statements or evidence, other instructions before closing argument, and some CACI 5000 series after closings.

The parties should consider the order in which they want instructions read. The Court typically reads all requested CACI series 100 and 200 instructions before the opening statements or before evidence is taken. All other instructions are usually given before closing argument, although some CACI 5000 series instructions should be given after closings. The Court invites the parties' suggestions on the order of 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.

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

Joint discovery dispute statement

Exhibits to the joint statement may include declarations, proofs of service of the disputed discovery requests, and other documents.

Exhibits to the statement may include declarations, proofs of service of the discovery requests at issue, and other documents.

INFO

Applies to

Joint discovery dispute statement

If allegations made in a prior filing are relevant, the filing should be cited by name, date filed, and page and line.

If allegations made in a prior filing are relevant, the filing should be cited by name, date filed, and page and line.

INFO

Applies to

Joint discovery dispute statement

Where the arguments for multiple discovery requests are the same, those arguments should be stated once after the group of requests and responses to which they apply.

Where the arguments for multiple discovery requests are the same, those arguments should be stated once after the group of requests and responses to which they apply.

INFO

Applies to

Filed documents

Parties are encouraged to advise the Court of preferred pronouns, attorneys are encouraged to include pronouns in signature blocks on filed documents, and all parties must address individuals per the pronouns identified.

Parties and counsel are encouraged to advise the Court of their preferred pronouns, either in writing or at any appearance. Attorneys are further encouraged to include pronouns in signature blocks on filed documents. All parties and counsel shall address individuals in accordance with the pronouns identified.

INFO

Applies to

Proposed jury instructions

When an appropriate CACI instruction exists, the court expects the parties to request it instead of 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.

INFO

Applies to

Motion

Proposed orders are not required to be filed with motions unless otherwise ordered or statutorily required, because the minute order operates as the Court's order.

Unless otherwise ordered by the Court, or unless the proposed order is statutorily required to be in a certain format, the Court does not require the filing of proposed orders along with motions. The minute order operates as the order of the Court.

INFO

Applies to

Motion

Proposed orders not required with motions unless stipulated or statutorily required; required for stipulated requests.

Unless otherwise ordered by the Court, or unless the proposed order is statutorily required to be in a certain format, the Court does not require the filing of proposed orders along with motions. The minute order operates as the order of the Court. A separately filed proposed order is required for a stipulated request for an order.

INFO

E-filed motions, oppositions, and replies should include last 4 digits of CRS reservation ID in 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.

INFO

Applies to

Motion to compel further responses

Parties moving to compel further responses may file a concise outline (per CRC 3.1345(b)) in lieu of a separate statement, grouping issues and preferably using a table format.

The Court grants permission to any party filing a motion to compel further responses to file a concise outline of the discovery request(s), response(s), and the legal positions of each of the parties to the dispute, see Cal. Rule of Court Rule 3.1345(b), in lieu of a separate statement. Such concise outlines should group together discovery issues where possible. The Court appreciates a table format for the concise outlines, with columns for each category of discovery request, response, and legal positions of the parties.

INFO

Applies to

Special verdict form

When a special verdict form is requested, parties are expected to use the applicable CACI special verdict form for a cause of action, affirmative defense, or other finding.

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.

INFO

Applies to

Proposed jury instructions

Parties are expected to request the applicable 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.

CRITICALCivil cases

Applies to

Joint statement

For jury trials, the parties must file a signed joint statement of the case not exceeding two paragraphs, or, if no agreement is reached after a good faith meet-and-confer, each party must separately file a proposed joint statement.

Joint Statement – For jury trials, the parties shall prepare a joint written statement of the case for the Court to read to the jury. The statement should not exceed two paragraphs. The parties and counsel shall sign the joint statement. If the parties cannot agree on a joint statement after a good faith meet-and-confer session conducted in person, over the phone, or via videoconference, each party must separately file a proposed joint statement.

CRITICAL

The Trial Binder must contain tabbed sections for Trial Briefs, Joint Witness List, Joint Exhibit List, Joint Statement to the Jury, Jury Instructions, Verdict Forms, Deposition Designation Chart, Operative Pleadings, and Motions in Limine (unless too voluminous for the 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 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.

CRITICAL

Must include

declaration

Ex parte applicants must file a declaration with competent testimony detailing notice information and rule 3.1204 requirements.

The ex parte applicant must file a declaration containing competent testimony detailing the information given in the notice as well as the information required by California Rules of Court, rule 3.1204.

CRITICAL

Applies to

Joint exhibit list

Joint exhibit list required 5 court days before final status conference for jury trials.

JURY TRIALS 1. JOINT EXHIBIT LIST. All exhibits must be listed on one list, identified by a number and brief description. Notebooks containing all exhibits must be available on the final status conference date and all parties must be prepared to tell the court that they have had the opportunity to review all documents in the exhibit book. Place the correspond with the exhibit number. If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3, etc. Exhibits should be lodged with the court on the first day of trial.

CRITICAL

Applies to

Trial binder

The trial binder must contain, in the order indexed, trial briefs, motions in limine, joint statement of the case, joint witness list, joint exhibit list, joint and disputed jury instruction list, full-text jury instructions, verdict forms, deposition/former testimony designations, operative pleadings and stipulations, and proposed additional voir dire questions.

TRIAL BINDER INDEX TAB DOCUMENT A Trial Briefs – Plaintiff’s Trial Brief; Defendant’s Trial Brief B Motions in Limine C Joint Statement of the Case D Joint Witness List E Joint Exhibit List F Joint and Disputed Jury Instruction List G Jury Instructions (Full Text) H Verdict Forms I Deposition and Former Testimony Transcript Designations J Operative Pleadings and Stipulations K Proposed Additional Voir Dire Questions for the Court

CRITICAL

Applies to

Exhibit list

A flash drive offered into evidence must be listed on the Exhibit List with a placeholder in the Exhibit Book, and anything marked must contain an exhibit tag.

If a flash drive is offered into evidence, it must be listed on the Exhibit List, with a placeholder in the Exhibit Book identifying that is marked must contain an exhibit tag.

CRITICAL

Applies to

Ex parte application

Ex parte applicants must review CRC 3.1200-3.1207 and LASC Rule 3.26, and satisfy the notice requirements and the affirmative factual showing of good cause.

Before bringing an ex parte application, counsel should review California Rules of Court 3.1200-3.1207 and Los Angeles County Superior Court Rule 3.26. Please pay particular attention to the notice requirements and the requirement of an affirmative factual showing of good cause.

CRITICAL

Applies to

Trial binder

The Trial Binder must include a table of contents with the designated tabs A through I (trial briefs, joint witness list, joint exhibit list, jury statement, jury instructions, verdict forms, testimony, and the current operative pleadings), with bench trials limited to Tabs A, B, C, H, and I.

with a table of contents that includes the following (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): Tab A: Trial Briefs (Optional. If no trial briefs are filed, leave Tab A empty.) 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)

CRITICALCivil cases

Applies to

Jury instructions

Requested CACI jury instructions must be submitted as a jointly edited packet, with any counsel-specific requested instructions inserted into that packet for the Court's consideration during trial.

1.) A jointly submitted packet of all requested and properly and fully edited CACI jury instructions to which there is objection (LACCR. Rule 8.25) (Note: Counsel are advised to make all edits necessary to eliminate duplicate instructions and inconsistencies.) 2.) Each counsel may submit specifically requested and properly edited instructions not requested by any opposing counsel. These instructions shall be inserted into the aforementioned packet of the jointly submitted jury instructions, all to be considered and discussed by the Court at an appropriate time during the pendency of the trial.

CRITICAL

Applies to

Joint exhibit list

Counsel must meet and confer before filing the Joint Exhibit List to resolve foundation/admissibility objections and stipulate where possible.

Counsel must meet and confer prior to filing of the Joint Exhibit List in an effort to resolve any objections as to the foundation and admissibility of exhibits, with stipulations as to foundation and admissibility to the admission into evidence at trial of any exhibit on the list.

CRITICALCivil cases

Applies to

Proposed verdict form

Jury trial parties must submit proposed verdict forms with objections, and are encouraged to stipulate.

3. Proposed Verdict Forms and objections. The objection to a verdict form should be because the form used is improper (for example, that the question to be answered is not properly framed or that the form is insufficient to result in a valid verdict); no form to a special verdict form. The parties are strongly encouraged to stipulate to a verdict form, which means that they must meet and confer in advance of filing their respective proposals, but, if they cannot do so, the parties should be able to resolve any objections to a form.

CRITICAL

Parties must attach copies of the transcript pages they designate or counter-designate to the Joint Chart.

The parties shall attach copies of the pages of the transcripts of the deposition or former testimony they are designating or counter-designating to the Joint Chart of Page and Line or trial transcript.

CRITICAL

Applies to

Trial brief

Trial briefs must include 8 specified categories of information for all court and jury trials.

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; 6) supporting the position of the parties; 7) A detailed statement of the damages and relief claimed, including a specific breakdown of the elements of damages claimed and the amount sought; and, 8) Any other information that will assist the Court.

CRITICAL

Applies to

Motion in limine

Motions in limine must be accompanied by a sworn declaration attesting the opposing party’s position.

In compliance with LASC Rule 3.57, all motions in limine must be accompanied by a sworn declaration attesting setting forth the opposing party’s position regarding the motions, and must be submitted with timely statutory notice so the motions in limine can be heard at the FSC.

CRITICAL

If any defendant has not been served, plaintiff or plaintiff's counsel must submit a declaration to the Court five days prior to the Cal. Rules of Court, rule 3.110 deadline.

If all defendants have not been served, plaintiff or plaintiff's counsel must submit a declaration to the Court five (5) days prior to the Cal. Rules of Court, rule 3.110.