Los Angeles Superior Court Document Filing Requirements

CRITICAL

Applies to

Notice of settlement

The Notice of Settlement must be prepared on Judicial Council Form CM-200.

Notice of Settlement must be filed electronically by plaintiff using Judicial Council Form CM-200, even if the case settled at a judicial settlement conference.

CRITICAL

Applies to

Ex parte notice

The ex parte notice must state the hearing details (date, time, and location) and the relief sought.

The notice must include the hearing details (date, time, and location), and a statement of what relief the ex parte applicant is seeking.

CRITICAL

Applies to

Trial binder

All Trial Binder documents must be signed, filed, and conformed before being placed in the binder, except Jury Instructions (Full Text) and Verdict Form(s).

All documents in the Trial Binder, except the Jury Instructions (Full Text) and the Verdict Form(s) must be signed, filed and conformed before they are put into the Trial Binder.

CRITICAL

Applies to

Daily admitted exhibit list

At the end of each trial day, counsel must meet and confer and submit an agreed-upon list of all exhibits admitted that day to the judicial assistant.

END OF COURT DAY: At the end of each trial day counsel must meet and confer and submit to the Court's judicial assistant an agreed-upon list of all exhibits admitted that day.

CRITICAL

Applies to

Exhibits

No exhibit may be referenced by counsel or a witness unless it has been pre-marked with an exhibit number.

No exhibit may be referenced by counsel or a witness unless it has been pre-marked with an exhibit number.

CRITICAL

Applies to

Proposed jury instructions

Self-represented parties and counsel must prepare a list of joint and disputed jury instructions plus a complete set of printed, full-text edited proposed instructions for the Trial Binder.

Self-represented parties and counsel shall prepare a list of joint and disputed jury instructions, and must also prepare a complete set of printed, full- text and edited proposed jury instructions and include them in the Trial Binder.

CRITICAL

Applies to

Trial binder

Must include

filed, signed, conformed

All Trial Binder documents except jury instructions and verdict forms must be signed, filed, and conformed.

All documents in the Trial Binder, except the Jury Instructions (Full Text) and the Verdict Form(s) must be signed, filed and conformed before they are put into the Trial Binder.

CRITICAL

Applies to

Ex parte application

Ex parte applicants must file a declaration containing competent testimony detailing the information given in the notice.

The ex parte applicant must file a declaration containing competent testimony detailing the information given in the notice

CRITICAL

Applies to

Evidence

Evidence on law and motion must be by declaration or request for judicial notice unless the Court orders otherwise for good cause.

Unless the Court orders otherwise for good cause shown, evidence must be by declaration or request for judicial notice. (California Rules of Court, rule 3.1304.)

CRITICAL

Applies to

Deposition designation pleading

If deposition transcripts or videotapes will be used in lieu of live testimony, a pleading must set out all designated testimony, objections, and cross-designated testimony.

When deposition transcript(s) or videotape(s) are to be used in lieu of live testimony (not just for impeachment), a pleading must be prepared setting out all designated testimony, objections and cross-designated testimony.

CRITICAL

Applies to

Oral testimony permission statement

Oral testimony is not allowed without court permission, and parties seeking permission must file a statement consistent with CRC rule 3.1306.

Oral testimony will not be allowed without court permission. Parties seeking permission to introduce oral testimony must file a statement consistent with California Rules of Court, rule 3.1306. (Local Rule 3.7.)

CRITICAL

Applies to

Initial discovery disclosures

All civil actions filed after January 1, 2024 must comply with the initial discovery disclosure requirements of CCP §2016.090, which the Court may enforce on its own motion or a party's motion.

All civil actions filed after January 1, 2024 are subject to the initial discovery Disclosures requirements of CCP §2016.090. The Court may enforce the requirements of section 2016.090 on its own motion or on motion by a party.

CRITICAL

Applies to

Exhibit binder

Parties must jointly prepare three sets of exhibit binders (Judge, Judicial Assistant, Witness), each labeled on the front and side.

The parties shall jointly prepare three sets of evidentiary exhibit binders (a set for Judge, Judicial Assistant and Witness). The Exhibit Binders shall have labels on the front and side.

CRITICAL

Applies to

Joint verdict form

Self-represented parties and counsel must prepare and jointly file Joint Verdict Form(s).

Self-represented parties and counsel shall prepare and jointly file Joint Verdict Form(s).

CRITICAL

Applies to

Settled statement

In trials without court reporters, the parties must jointly prepare a settled statement of the testimony and evidence admitted each day of trial.

For trials without court reporters, parties will be ordered to jointly prepare a settled statement of the testimony and list of evidence admitted each day of the trial.

CRITICAL

Applies to

Declaration

A party seeking to introduce an unexchanged exhibit on its direct case must file a written declaration containing competent evidence of its inability to comply with the Trial Preparation Order.

NOTE: If a party would like to introduce an exhibit on its direct case that was not exchanged as described herein, the party must file a written declaration containing competent evidence in support of any claim that the party was unable to comply with this Court's Trial Preparation Order and with these policies and procedures.

CRITICAL

Applies to

Summary of daily proceedings

If no court reporter is used at trial, the parties must jointly prepare a summary of each day's proceedings and lodge it in the courtroom before proceedings resume.

COURT REPORTERS OR SETTLED STATEMENTS: The Court encourages the parties to bring a court reporter to the courtroom for trial. If no court reporter is used, the parties shall jointly prepare a summary of each day's proceedings, and lodge it in the courtroom before proceedings resume.

CRITICAL

Applies to

Joint chart deposition testimony

Designation columns in the joint chart must include witness number/name, date and type of testimony, page/line designations, objections, counter-designation status, and the court's ruling.

In the joint chart, each designating party's designations of deposition or former testimony shall include columns which state: (1) the designation number and name of the witness; (2) the date and type of testimony (e.g., deposition or trial testimony); (3) the page and line designations of the deposition or former testimony requested to be used; (4) any objections; (5) whether the other party has counter-designated any additional deposition or former testimony of the witness that relates to the designation, and, if so, the designation number of the counter-designation; and, (6) the court's ruling.

CRITICAL

Applies to

Trial brief

Each party must file a trial brief succinctly identifying the claims and defenses in dispute, the major legal issues with authorities, the relief and damages calculation, and any other helpful information.

Each party shall 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.

CRITICAL

Applies to

Opposition reply

Must include

caption

Opposition and reply papers to 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.

CRITICAL

Applies to

Trial brief

Each party must file a trial brief identifying remaining claims and defenses, major legal issues with authorities, relief and damages sought, and other information useful at trial.

Each party shall 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.

CRITICAL

Applies to

Witness list

Parties must jointly prepare and file a joint witness list of all witnesses intended to be called at trial, excluding impeachment and rebuttal witnesses; witnesses not on the list are subject to exclusion except for impeachment or rebuttal, and a party must show good cause to call an unlisted witness.

The parties' counsel and any self-represented parties shall work together to prepare and file a joint list of all witnesses whom any party intends to call at trial, excluding impeachment and rebuttal witnesses.

CRITICAL

Applies to

Exhibit list

Parties must jointly prepare and file a joint exhibit list with specified columns for each exhibit offered at trial, including stipulations to authentication and admissibility, objections, and marking/admission dates.

The parties' counsel and any self-represented parties shall work together to prepare and file a joint exhibit list organized with columns (in the format set forth below) which state for each exhibit any party intends to offer at trial: (1) the exhibit number; (2) a brief description of the exhibit; (3) which party is offering the exhibit; (4) whether the parties have stipulated to authentication of the exhibit; (5) whether the parties have stipulated to admissibility of the exhibit; (6) any evidentiary objections to admission of the exhibit; (7) the date the exhibit was marked for identification; and, (8) the date the exhibit was admitted into evidence.

CRITICAL

Applies to

Motion in limine

Motions in limine must comply with CCP §1005 notice provisions and include declarations meeting LR 3.57(a) requirements.

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).

CRITICAL

Applies to

Witness list

Any party eliciting testimony from a witness not on the witness list 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.

CRITICAL

Applies to

Statement of case

For jury trials, parties must prepare and file a brief joint written statement of the case for the court to read to the jury.

For jury trials, the parties' counsel and any self-represented parties shall work together to prepare and file a brief, joint written statement of the case for the court to read to the jury. (Local Rule 3.25, subd. (g)(4).)

CRITICAL

Applies to

Trial binder

The Trial Binder must include a table of contents with Tabs A through I; for bench trials without a jury, only Tabs A, B, C, H, and I are required.

a table of contents that includes the following (for bench trials without a jury, the Trial Binder shall only include the documents listed under Tabs A, B, C, H, and I): 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 E: Joint List of Jury Instructions 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).

CRITICAL

Applies to

Trial binder

The Trial Binder must include a table of contents with specified tabs: Trial Briefs, Joint Witness List, Joint Exhibit List, Deposition Designations chart, and Operative Pleadings.

a table of contents that includes the following: Tab A: Trial Briefs Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab E: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).

CRITICAL

Applies to

Jury instructions

For jury trials, parties must prepare a complete set of full-text proposed jury instructions, editing CACI instructions, inserting party names, and eliminating blanks and inapplicable material.

For jury trials, the parties' counsel and any self-represented parties shall work together to prepare a complete set of full-text proposed jury instructions, editing all proposed Judicial Council of California Civil Jury Instructions ("CACI") instructions, inserting party names, and eliminating blanks and other irrelevant or inapplicable material.

CRITICAL

Applies to

Joint witness list

Joint witness list must be organized by specified columns (name, party calling, expected testimony, examination estimates) with a grand total, and any witness omitted from the list is subject to exclusion from trial testimony.

The joint witness list shall be organized with 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 (e.g. approximately 8-12 words), non-conclusory description of the witness's expected testimony (e.g. "percipient" is too conclusory; instead, describe what the witness perceived); (5) an estimate of the length of direct examination (in hours); (6) an estimate of the length of cross-examination (in hours); and, (7) the total estimated length of examination (in hours). 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. 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

CRITICAL

Applies to

Deposition designation chart

Parties intending to use deposition or former trial testimony must meet and confer and jointly prepare and file a chart of page and line designations in the specified format.

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 and file, a joint chart in the format set forth below ("Joint Chart of Page and Line Designations for Deposition and Former Testimony").

CRITICAL

Applies to

Motion in limine

Must include

caption

Each motion in limine caption must concisely identify the evidence sought to be excluded.

The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to exclude.

CRITICAL

Applies to

Joint chart deposition testimony

When deposition or former trial testimony will be used, counsel and self-represented parties must meet and confer and jointly file a deposition designation chart.

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 and file, a joint chart in the format set forth below

CRITICAL

Applies to

Verdict form

For jury trials, parties must jointly file a proposed verdict form, or each party must separately file one if no agreement is reached, and the court expects use of the applicable CACI special 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. 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.

CRITICAL

Applies to

Motion in limine

Motions in limine must be noticed for hearing at the Final Status Conference.

Motions in limine shall be noticed for hearing at the Final Status Conference.

CRITICAL

Applies to

Jury instructions

For jury trials, parties must prepare and file a joint list of proposed jury instructions stating number, title, requesting party, agreed/contested status, objections, and whether given by the court.

For jury trials, the parties' counsel and any self-represented parties shall work together to prepare and file a joint list of proposed jury instructions (in the format set forth below) which states for each proposed jury instruction: (1) the jury instruction number (listed in numerical order); (2) the title of the jury instruction; (3) the party requesting the jury instruction; (4) whether the jury instruction is agreed upon or contested; (5) a concise statement of any objection; and, (6) whether the jury instruction was given by the court ("Joint List of Proposed Jury Instructions").

CRITICAL

Applies to

Witness list

Witnesses not on the joint witness list are subject to exclusion from testifying except for impeachment or rebuttal, and a party seeking to call an unlisted witness must first show good cause to the court.

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 ===== PAGE 8 ===== rebuttal testimony. 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.

CRITICAL

Applies to

Exhibit

Non-documentary exhibits must be marked and a 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.

CRITICAL

Applies to

Exhibit list

Parties and self-represented litigants must prepare and file a joint exhibit list containing specified columns for each trial exhibit and must meet and confer to resolve authenticity and admissibility objections.

The parties' counsel and any self-represented parties shall work together to prepare and file a joint exhibit list organized with columns (in the format set forth below) which state for each exhibit any party intends to offer at trial: (1) the exhibit number; (2) a brief description of the exhibit; (3) which party is offering the exhibit; (4) whether the parties have stipulated to authentication of the exhibit; (5) whether the parties have stipulated to admissibility of the exhibit; (6) any evidentiary objections to admission of the exhibit; (7) the date the exhibit was marked for identification; and, (8) the date the exhibit was admitted into evidence. (Local Rule 3.25, subd. (g)(6).) As set forth above, the parties' counsel and any self-represented parties shall meet and confer to try to resolve objections to the authenticity and admissibility of each exhibit.

CRITICAL

Applies to

Motion in limine

Multiple motions in limine from a party must be numbered consecutively.

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

CRITICAL

Applies to

Jury instructions

Proposed jury instructions behind Tab F must be organized into three labeled groups in a specified order.

The parties shall organize proposed jury instructions into groups behind Tab F in the following order (labeled by cover sheets): (1) the agreed-upon instructions; (2) plaintiff's requested instructions to which defendant objects; and, (3) defendant's requested instructions to which plaintiff objects.

CRITICAL

Applies to

Proposed sealing order

Proposed sealing orders must state non-conclusory, express facts supporting sealing, separately identify each proposed redaction by document name, page, and line number, and include a 'Granted'/'Denied' ruling space for the court.

The proposed sealing order must state proposed non-conclusory, express facts supporting sealing. (CRC 2.550(d), (c)(1)(A).) "Non-conclusory" means findings more specific than merely repeating the wording of CRC 2.550, subdivisions (d)(1-5). Without repeating the language of each proposed redaction, the proposed sealing order must separately identify by document name, page, and line number each and every proposed redaction. For each proposed redaction, the proposed sealing order must, akin to a ruling sheet, contain immediately to the right a space for the court to mark "Granted" or "Denied" for each proposed redaction.

CRITICAL

Applies to

Joint chart deposition testimony

Counter-designation columns in the joint chart must include witness number/name, date and type of testimony, page/line counter-designations, objections, the related designation number, and the court's ruling.

In the joint chart, each counter-designating party's counter-designations of additional deposition or former testimony of the witness that relates to the designations shall include columns which state: (1) the designation number and name of the witness; (2) the date and type of testimony (e.g., deposition or trial testimony); (3) the page and line counter-designations of the deposition or former testimony requested to be used; (4) any objections; (5) the designation number of the other party's designation to which the counter-designation relates; and, (6) the court's ruling.

CRITICALCivil cases

Applies to

Opposition brief

The respondent must bates-stamp its evidence (starting with the number following the petitioner's evidence) and submit it with the Opposition Brief.

Respondent shall, in turn, bates-stamp any evidence it wants the Court to consider (starting with the number following the petitioner's evidence) and submit such evidence with the Opposition Brief.

CRITICALCivil cases

Applies to

Ex parte application

Must include

proposed order

For an ex parte application seeking a TRO and order to show cause re preliminary injunction, the moving party must submit a proposed form of order (source text is truncated mid-sentence).

If the ex parte application seeks a temporary restraining order and order to show cause re preliminary injunction, the moving party must submit a proposed form of

CRITICALCivil cases

Applies to

Proposed judgment and writ of mandate

In accordance with Local Rule 3.231(n), the prevailing party on a prerogative writ will be ordered to prepare, serve, and ultimately file a proposed judgment and, if applicable, a proposed writ of mandate.

In accordance with Local Rule 3.231(n), the prevailing party on a prerogative writ will be ordered to prepare, serve, and ultimately file a proposed judgment and, if applicable, a proposed writ of mandate.

CRITICALCivil cases

Applies to

Off calendar written confirmation

A moving party who takes a motion off calendar must confirm that fact in writing.

If the moving party takes a motion off calendar, the moving party shall confirm that fact in writing.

CRITICALCivil cases

Applies to

Opening brief

If the parties cannot agree on a joint appendix, the petitioner must bates-stamp its evidence and submit it with the Opening Brief.

If the parties cannot agree upon a joint appendix, petitioner must bates-stamp any evidence it wants the Court to consider and submit such evidence with the Opening Brief.

CRITICALCivil cases

Applies to

Verdict form

Parties must prepare and 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.

CRITICALCivil cases

Applies to

Motion in limine

The caption of each motion in limine must concisely identify the evidence the moving party seeks to admit or exclude.

The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to admit or exclude.