Los Angeles Superior Court Document Filing Requirements

CRITICAL

Applies to

Recording transcript

Parties must prepare transcripts of all recordings they plan to introduce as exhibits, per CRC rule 2.1040.

California Rules of Court (“CRC”), rule 2.1040 requires the parties to prepare transcripts of all recordings counsel plan to introduce as an exhibit.

CRITICAL

Applies to

Jury instructions

The CACI Number and Title should be at the top of each instruction.

The CACI Number and Title should be at the top of each instruction.

CRITICAL

Applies to

Trial brief

Trial briefs (joint or separate) must include five elements: description of claims/defenses, major legal issues with authority, major evidentiary issues with authority, detailed relief sought with damages breakdown, and other helpful information.

Whether jointly filed by multiple parties, or separately filed by individual parties, the trial brief must include: (1) A brief description of the claims and defenses to be presented at trial; (2) A brief discussion of the major legal issues supported by relevant authority; (3) A brief discussion of any major evidentiary issues supported by relevant authority; (4) A detailed statement of the relief sought, including a breakdown of the damages, if any; (5) A brief discussion of any other information that may assist the Court at trial.

CRITICAL

Applies to

Fsc trial notebook

The FSC Trial Notebook must include a table of contents with Section A (Trial Briefs), Section B (Motions in Limine), and Section C (Joint Statement of the Case).

with a table of contents that includes the following: Section A: Trial Briefs Section B: Motions in Limine Section C: Joint Statement of the Case

CRITICAL

Applies to

Verdict form

Parties must jointly file a proposed general or special verdict form acceptable to all sides, or each party must separately file a proposed verdict form if they cannot agree.

The parties shall prepare and jointly file a proposed general verdict form or special verdict form (with interrogatories) acceptable to all sides. (Local Rules, rule 3.25(g)(8).) If the parties/counsel cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

CRITICALCivil cases

Applies to

Stipulated continuance request

Must include

proposed order

Requests for continuances may be made by stipulation and proposed order or, if no agreement is possible after good faith discussion among counsel in-person or by telephone, by noticed motion.

Requests for continuances may be made by stipulation and proposed order or, if no agreement is possible after good faith discussion among counsel in-person or by telephone, by noticed motion.

CRITICAL

Applies to

Ex parte application

Ex parte applications are reserved for exigent circumstances and must include a declaration with an affirmative factual showing of irreparable harm, immediate danger, or another statutory basis.

Ex parte applications are reserved for exigent circumstances. The applicant shall comply with California Rules of Court, rule 3.1202(c): “An applicant must make an affirmative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte.”

CRITICAL

Applies to

Joint list of proposed jury instructions

Parties must file a signed joint list of proposed jury instructions organized numerically, distinguishing agreed from contested instructions, with a space for the Court to mark whether each instruction was given.

Joint List of Proposed Jury Instructions – The parties shall jointly prepare and file a of proposed jury instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any. The list of proposed jury instructions must include a space by each instruction for the Court to indicate whether the instruction was given. The parties and counsel shall sign the joint list of proposed jury instructions.

CRITICAL

Applies to

Court reporter stipulation or appointment order

Parties must provide their own court reporter and file a reporter stipulation or appointment order before the hearing is called.

It is the responsibility of the parties to provide their own Court Reporter for hearings and trial. The parties are to file either the Stipulation and Order to use Certified Shorthand Reporter or Order Appointing Court Approved Reporter as Official Reporter Pro Tempore prior to the hearing being called.

CRITICAL

Applies to

Motion in limine

Motions in limine may not be used to seek dispositive orders that should have been sought via summary judgment, summary adjudication, or judgment on the pleadings.

Motions in limine shall not be used to seek dispositive orders that should have been sought through a motion for summary judgment, summary adjudication or judgment on the pleadings.

CRITICAL

Applies to

Request for informal discovery conference

Requests for an Informal Discovery Conference must be filed using Form LACIV-094.

The parties are instructed to file their Request for an IDC using Form LACIV-094.

CRITICAL

Applies to

Verdict form

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

Joint Verdict Forms – The parties shall prepare and file a joint proposed general verdict form or special verdict form (with interrogatories). If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

CRITICAL

Applies to

Joint exhibit list

Parties must meet and confer and file a signed joint exhibit list with specified columns for the exhibit, offering party, stipulations/objections to authenticity and admissibility, and identification/admission dates.

Joint Exhibit List – 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. 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. The parties and counsel shall sign the joint exhibit list.

CRITICAL

Applies to

Motions in limine binder

The motions-in-limine binder must include a table of contents identifying each motion, opposition, and reply with its corresponding tab.

The binder also must contain a table of contents identifying each motion in limine, opposition, and reply, and the corresponding tab for each.

CRITICAL

Applies to

Motion in limine

Motions in limine must comply with Local Rule 3.57, including the required declaration where applicable.

When filing motions in limine, the parties must comply with Local Rule 3.57, including the required declaration, if applicable.

CRITICAL

Applies to

Ex parte application

Must include

proposed order

Ex parte applicants must submit a proposed order (and comply with CRC 3.1200) before appearing in court.

Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in court.

CRITICAL

Applies to

Jury instructions

Parties must prepare a complete set of full-text proposed jury instructions, with special instructions in jury-ready format showing only the instruction number, title, and text.

Jury Instructions (Joint and Contested) – The parties shall prepare a complete set of full-text proposed jury instructions. The parties shall prepare special instructions in a format ready for submission to the jury with the instruction number, title, and text only.

CRITICAL

Applies to

Deposition designation chart

If deposition or former testimony will be used in lieu of live testimony, parties must meet and confer and jointly file a chart with columns for page/line designations, objections, counter-designations, responses, and the Court's rulings.

Page and Line Designations for Deposition and Former Testimony – If the parties intend to use deposition testimony or former trial testimony in lieu of any witness’s live testimony, the parties shall meet and confer and jointly prepare and file a chart with columns for each of the following: (1) the page and line designations of the deposition or former testimony requested for use, (2) objections, (3) counter- designations, (4) any responses thereto, and (5) the Court’s rulings.

CRITICAL

Applies to

Joint witness list

Parties must file a signed joint witness list identifying each witness by name, expert status, estimated examination time, total testimony hours, and any scheduling issues or special requirements.

Joint Witness List – The parties shall work together and file a joint list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. The joint witness list shall identify each witness by name, specify which witnesses are experts, estimate the length of direct examination, cross-examination, and re-direct examination of each, and include a total of the number of hours for all witness testimony. The parties shall identify all potential witness scheduling issues and special requirements. The parties and counsel shall sign the joint witness list.

CRITICAL

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include a proposed order and have filing fee paid before appearing in court.

Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in court.

CRITICAL

Applies to

Motion

Must include

proposed order

Every noticed motion must be accompanied by a proposed order.

All noticed motions must be accompanied by a proposed order.

CRITICAL

Applies to

Ex parte application

Ex parte applications must include an affirmative showing of irreparable harm, immediate danger, or another statutory basis for granting relief ex parte.

A party seeking ex parte relief must provide an affirmative showing of"irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte" (Cal. Rules of Court, Rule 3.1202 (c).) Please ensure that you have a proper basis to seek the requested relief.

CRITICALCivil cases

Applies to

Ex parte application

Ex parte applications must include affirmative showing of irreparable harm, immediate danger, or statutory basis.

There must be an affirmative showing of “irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte.” (See Cal. Rules of Court, rule 3.1202 (c).)

CRITICALCivil cases

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).

CRITICALCivil cases

Applies to

Reply separate statement

Reply separate statements will not be considered by the court.

Reply separate statements are not provided for in the Rules of Court and will not be considered.

CRITICALCivil cases

Applies to

Ccp 2034 260 expert declaration

A party intending to call an expert at trial must present to the Court and opposing counsel a CCP section 2034.260 declaration stating the substance of the proffered opinion.

If counsel or any unrepresented party intends to call an expert at trial, counsel shall present to the Court and opposing counsel a copy of the Code of Civil Procedure section 2034.260 declaration that states the substance of the proffered opinion.

CRITICALCivil cases

Applies to

Joint exhibit list

The parties must submit a joint exhibit list and a joint witness list.

The parties must submit a joint exhibit list and joint witness list as described above.

CRITICALCivil cases

Applies to

Proposed verdict form

If the parties cannot agree on a verdict form, each party must submit its own proposed verdict form, and any special verdict must be simple and easy for the jury to use.

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.

CRITICALCivil cases

Applies to

Motion in limine

Must include

certificate of conference

Motions in limine must include a sworn declaration confirming meet and confer with opposing party and their position.

All motions in limine must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party and setting forth the opposing party’s position regarding the motion(s) and must be submitted with timely statutory notice.

CRITICALCivil cases

Applies to

Motion

Motion hearing dates must be reserved via CRS; reservation number included on caption page.

Hearing dates must be reserved through the Court’s Reservation System (CRS). Counsel shall include the reservation number of the motion on the CAPTION page.

CRITICALCivil cases

Applies to

Motion in limine

Must include

certificate of conference

Parties must meet and confer before filing any motion in limine, and every motion in limine must be accompanied by a sworn declaration attesting to the discussion and stating the opposing party's position.

Local Rule 3.57 requires the parties to meet and confer before filing any motion in limine. All motions in limine must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party and setting forth the opposing party's position regarding the motion(s)

CRITICALCivil cases

Applies to

Joint witness list

The joint witness list must list each witness once, with expected testimony time (direct, cross, re-direct) and total estimated time stated for each witness.

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.

CRITICALCivil cases

Applies to

Ex parte application

Ex parte applications must affirmatively show irreparable harm, immediate danger, or another statutory basis for relief, and must demonstrate why relief cannot be sought by other means such as a noticed motion.

PLEASE CAREFULLY REVIEW WHETHER YOU HAVE A PROPER BASIS TO SEEK EX PARTE RELIEF. There must be an affirmative showing of “irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte.” (See Cal. Rules of Court, rule 3.1202 (c).) You will need to demonstrate to the court the reason(s) why you cannot seek the requested relief by other means, such as a noticed motion.

CRITICALCivil cases

Applies to

Idc joint statement

Counsel must meet and confer and file a joint statement of the issues to be discussed at the IDC.

The court requires counsel to meet and confer and file a joint statement of the issues to be discussed at the IDC.

CRITICALCivil cases

Applies to

Joint jury instructions

Joint jury instructions must be submitted with all information filled in (no brackets or blanks), and disputed instructions must be submitted in separate sets identifying the proposing and opposing parties.

Submit a joint set of instructions with all information filled in – no remaining brackets or blanks. If instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction.

CRITICALCivil cases

Applies to

Exhibits

All exhibits must be exchanged and pre-numbered, except exhibits anticipated in good faith to be used for impeachment or rebuttal.

Pursuant to California Rule of Court 3.1110(f) and Local Rules 3.52 and 3.53, all exhibits must be exchanged and pre-numbered, except for those anticipated in good faith to be used for impeachment or during rebuttal.

CRITICALCivil cases

Applies to

Motion

The motion's CRS reservation number must appear on the caption page.

Counsel shall include the reservation number of the motion on the CAPTION page.

CRITICALCivil cases

Applies to

Jury instruction disposition table

A disposition table listing all jury instructions by number, proposing parties, and court disposition 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.

CRITICAL

Applies to

Proposed verdict form

Parties must file a joint proposed general or special verdict form, or 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.

CRITICAL

Applies to

Idc joint statement

The IDC joint statement must succinctly summarize the nature of the dispute, the necessity for the discovery, the basis for any objection or withholding of information, and the overall status of discovery.

At least five (5) court days before the Informal Discovery Conference, the parties and counsel shall file a joint statement that succinctly summarizes the nature of the dispute, the necessity for the discovery, the basis for any objection or withholding of information, and the overall status of discovery.

CRITICAL

Applies to

Case management statement

Case Management Statements must use Judicial Council Form CM-110.

The parties and counsel shall file a Case Management Statement using Judicial Council Form CM-110 no later than fifteen (15) calendar days before the date set for the conference.

CRITICAL

Applies to

Joint exhibit list

Counsel must submit a Joint Exhibit List numbered from 1 with three copies containing columns for the Clerk and Court, with exhibits numbered per Rules 3.52–3.53.

Counsel shall submit a Joint Exhibit List beginning with the number 1 and provide three copies of the exhibit list with columns for the Clerk and the Court to use to indicate whether the exhibit is marked and received into evidence. Exhibits shall be numbered in conformance with Rules 3.52 – 3.53.

CRITICAL

Applies to

Joint trial binder

All Counsel are to prepare a Joint Trial Binder which is to include the following:

All Counsel are to prepare a Joint Trial Binder which is to include the following:

CRITICAL

Applies to

Motion in limine

Motions in limine must be numbered consecutively, opposed with corresponding motion number, and filed in numerical order with replies/oppositions attached.

If more than one Motion in Limine is filed, each shall be numbered consecutively. Opposition papers shall include the number of the motion to which it corresponds. Motions in Limine are to be placed in numerical order starting with Plaintiff’s Motions in Limine then Defense Motions in Limine. All replies and opposition are to be placed directly behind the Motion in Limine in question.

CRITICAL

Applies to

Joint jury instructions

At the Final Status Conference counsel must submit a Joint List of all requested jury instructions with fully completed copies, attaching disputed instructions separately with the requesting party identified, and must meet and confer no later than two days before the conclusion of evidence to create a final set of instructions, without waiving objections.

At the Final Status Conference, Counsel shall provide the Court with a Joint List of all Jury Instructions requested and a copy of all requested instructions fully filled out. Those instructions not agreed upon should be attached separately and the party making the request should be identified. No later than two days before the conclusion of evidence, the Court will require Counsel to meet and confer for the purpose of creating a final set of instructions. Submission of the Joint Jury Instructions shall not be deemed a waiver of any objection to the giving of an instruction on the Joint List.

CRITICAL

Applies to

Joint deposition designation list

Counsel must submit a Joint Deposition Designation List numbered from 1 with three copies containing Clerk and Court columns, indicating whether excerpts are stipulated or the legal grounds for objections.

Counsel shall submit a Joint Deposition Designation List beginning with the number 1 and provide three copies of the Deposition Designation List with columns for the Clerk and the Court to use to indicate whether the Deposition Designation is admitted or not. The Joint Deposition Designation List is to include whether excerpts are stipulated or the Legal Grounds for Objections.

CRITICAL

Applies to

Ex parte application

Must include

proposed order

Ex parte applicants must submit a proposed order and comply with CRC 3.1200 et seq. before appearing.

Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing.

CRITICAL

Applies to

Ex parte application

Ex parte applications are reserved for exigent circumstances and must include a declaration making an affirmative factual showing of irreparable harm, immediate danger, or another statutory basis (CRC 3.1202(c)).

Ex parte applications are reserved for exigent circumstances. The applicant must comply with Cal. Rule of Court, rule 3.1202(c): "An applicant must make an affirmative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte."

CRITICAL

Applies to

Exhibits

All exhibits must be exchanged and pre-numbered, except exhibits anticipated in good faith for impeachment or rebuttal.

Pursuant to California Rule of Court, Rule 3.1110(f), and Los Angeles Superior Court Local Rules 3.52 and 3.53, all exhibits must be exchanged and pre-numbered, except those anticipated in good faith to be used for impeachment or rebuttal.

CRITICAL

Applies to

Request for court reporting services

A fee-waiver party's request for court reporting services must be made using local form LACIV 269 or Judicial Council form FW-020.

The request must be made by using the local form, Request for Court Reporting Services by a Party with Fee Waiver (LACIV 269), or Judicial Council form FW-020, and should be filed at least ten calendar days before the hearing or trial for which the reporter is requested.