Los Angeles Superior Court Document Filing Requirements

CRITICALCivil cases

Applies to

Joint statement of the case

In jury trials, the parties must prepare and sign a joint written statement of the case for the Court to read to the jury.

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 parties/counsel shall sign the joint statement.

CRITICALCivil cases

Applies to

Deposition designation chart

If deposition or former trial testimony will be used in lieu of live testimony, the parties must meet and confer and file a signed chart listing 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. The objecting party shall specify all objections in the respective column. The parties/counsel shall sign the designations.

CRITICALCivil cases

Applies to

Ex parte application

Ex parte applications must include a declaration with personal knowledge testimony of irreparable harm or exigent circumstances.

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.

CRITICALCivil cases

Applies to

Pretrial filings

Parties must file the pretrial documents required by Local Rule 3.25(f) and (g) in advance of the Final Status Conference.

The parties are required to file the documents set forth in Local Rule 3.25(f) and (g) in advance of the FSC and should be familiar with Local Rules 3.48 through 3.58.

CRITICALCivil cases

Applies to

Joint exhibit list

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

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/counsel shall sign the joint exhibit list.

CRITICALCivil cases

Applies to

Declaration of service efforts

If any defendant remains unserved by the CMC, plaintiff must file a declaration, at least five days before the hearing, explaining the service efforts undertaken.

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 hearing explaining what efforts have been undertaken to accomplish service. Cal. Rules of Court, rule 3.110.

CRITICALCivil cases

Applies to

Ex parte application

Must include

proposed order

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

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.

CRITICALCivil cases

Applies to

Opposition and reply brief

Opposition and reply briefs on motions in limine must identify the corresponding motion number in the caption of their pages.

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

CRITICALCivil cases

Applies to

Declaration

Declaration of service efforts required 5 days before CMC if defendants not served.

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 hearing explaining what efforts have been undertaken to accomplish service.

CRITICALCivil cases

Applies to

Trial brief

Each party must file a trial brief identifying the claims and defenses, major legal issues with supporting points and authorities, relief claimed and damages calculation, and any other information assisting the Court.

Trial Briefs – Each party shall file 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.

CRITICALCivil cases

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.

CRITICALCivil cases

Applies to

Joint discovery report

The parties must file a joint report at least five court days before the IDC covering the nature of the dispute, necessity for the discovery, justification for non-production, and overall discovery status.

At least five court days before the IDC, the parties shall file a joint report that succinctly sets forth the nature of the dispute, the necessity for the discovery, the justification for its non-production, and the overall status of discovery.

CRITICALCivil cases

Applies to

Ex parte application

Must include

proposed order

Ex parte applicants must submit a proposed order with the application and pay the filing fee 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.

CRITICALCivil cases

Applies to

Joint list of jury instructions

Parties must file a signed joint list of proposed jury instructions in numerical order identifying agreed and contested instructions, with a space by each instruction for the Court to indicate whether it was given.

and file a list 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/counsel shall sign the joint list of proposed jury instructions.

CRITICALCivil cases

Applies to

Jury instructions

Parties must prepare a complete set of full-text proposed jury instructions, with special instructions formatted for submission to the jury containing 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.

CRITICALCivil cases

Applies to

Motion in limine binder

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

CRITICALCivil cases

Applies to

Joint statement

A motion to compel further responses must be accompanied by a four-column joint statement identifying the request number, the request text, the response text, and each party's bullet-point arguments.

In the event a motion to compel further responses is filed, the parties are required to submit a JOINT STATEMENT consisting of a four-column document set up as follows: The first column will identify the number of the discovery request; the second, the text of the discovery request; the third, the text of the response; and the fourth, brief bullet-point statements, one from each party, as to why a further response should or should not be compelled.

CRITICALCivil cases

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 for ex parte relief.

Ex parte applications are reserved for exigent circumstances. The applicant shall comply with Cal. 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."

CRITICALCivil cases

Applies to

Joint statement

Motions to compel further responses require a four-column joint statement with specified content.

In the event a motion to compel further responses is filed, the parties are required to submit a JOINT STATEMENT consisting of a four-column document set up as follows: The first column will identify the number of the discovery request; the second, the text of the discovery request; the third, the text of the response; and the fourth, brief bullet-point statements, one from each party, as to why a further response should or should not be compelled.

CRITICALCivil cases

Applies to

Joint witness list

Parties must file a signed joint witness list (excluding impeachment and rebuttal witnesses) identifying each witness by name, designating experts, estimating direct/cross/re-direct examination times with total testimony hours, and noting scheduling issues and 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/counsel shall sign the joint witness list.

CRITICALCivil cases

Applies to

Motion in limine

Parties filing multiple motions in limine must number the motions consecutively.

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

CRITICALCivil cases

Applies to

Joint witness list

Parties must identify all potential witness scheduling issues and special requirements.

The parties shall identify all potential witness scheduling issues and special requirements.

CRITICALCivil cases

Applies to

Joint summary of testimony

When no court reporter is present, counsel must jointly provide the court a daily summary of testimony and admitted evidence by the morning following the testimony.

If the parties do not have a court reporter, counsel will be required to provide the court with a joint summary of the testimony and evidence admitted on a daily basis by the morning following the testimony.

CRITICALCivil cases

Applies to

Motion in limine

Each motion in limine caption must concisely identify the evidence the moving party seeks to preclude.

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

CRITICALCivil cases

Applies to

Joint witness list

Parties must file a joint witness list, alphabetized by last name and excluding impeachment and rebuttal witnesses, that identifies each witness by name, expert status, estimated examination times, and total testimony hours.

The parties shall prepare and file a joint, alphabetized by last name, list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. (Super. Ct., L.A. County, Local Rules, rule 3.25(g)(5).) The joint witness list shall identify each witness by name, specify which witnesses are non-experts and experts, estimate the length of the direct, cross examination and re-direct examination of each witness, and include a total of the number of hours for all witness testimony.

CRITICALCivil cases

Applies to

Deposition transcripts

Deposition excerpts cited in briefs must be marked on the transcripts attached as exhibits.

All deposition excerpts referenced in briefs must be marked on the transcripts attached as exhibits. (Cal. Rules of Court, rule 3.1116(c).)

CRITICALCivil cases

Applies to

Joint statement of case

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

For jury trials, the parties shall prepare and file a joint written statement of the case for the trial court to read to the jury. (Super. Ct. L.A. County, Local Rules, rule 3.25(g)(4).)

CRITICALCivil cases

Applies to

Jury instructions

Parties must prepare a complete set of full-text proposed jury instructions ready for submission to the jury, with party names inserted and blanks, brackets, and irrelevant material eliminated.

The parties shall prepare a complete set of full text proposed jury instructions in a format ready for submission to the jury, by editing all proposed California Civil Jury Instructions including inserting party name(s) and eliminating blanks, brackets, and irrelevant material.

CRITICALCivil cases

Applies to

Trial binder

Tab A: Trial Briefs (Optional) Tab B: Joint Statement to Be Read to the Jury Tab C: Joint Witness List (in the format prescribed at § 8(B)(b)) Tab D: Joint Exhibit List (in the format prescribed at § 8(B)(h)) Tab E: Joint List of Jury Instructions (identifying the agreed upon and contested instructions) Tab F: Joint and Contested Jury Instructions. The parties shall organize proposed jury instructions behind Tab F, with the agreed upon instructions first in order followed by the contested instructions (including special instructions) submitted by each side. Tab G: Joint and/or Contested Verdict Form(s) Tab H: Joint Chart of Page and Line Designation(s) 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 A: Trial Briefs (Optional) Tab B: Joint Statement to Be Read to the Jury Tab C: Joint Witness List (in the format prescribed at § 8(B)(b)) Tab D: Joint Exhibit List (in the format prescribed at § 8(B)(h)) Tab E: Joint List of Jury Instructions (identifying the agreed upon and contested instructions) Tab F: Joint and Contested Jury Instructions. The parties shall organize proposed jury instructions behind Tab F, with the agreed upon instructions first in order followed by the contested instructions (including special instructions) submitted by each side. Tab G: Joint and/or Contested Verdict Form(s) Tab H: Joint Chart of Page and Line Designation(s) 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).

CRITICALCivil cases

Applies to

Opposition and reply papers

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

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

CRITICALCivil cases

Applies to

Joint exhibit list

Parties must file a joint exhibit list with columns identifying each exhibit, specifying any evidentiary objections (unarticulated objections may result in the exhibit being deemed admitted), and blanks for the Court to enter the dates the exhibit was first identified and admitted.

The parties shall prepare and file a joint exhibit list organized with columns 1) identifying each exhibit, 2) specifying evidentiary objections, if any, to the admission of the exhibit (if an objection to an exhibit is not articulated on the exhibit list, the trial court may deem the exhibit admitted) 3) a blank column for the Court to enter the date the exhibit was first identified, and 4) a blank column for the Court to enter the date the exhibit was admitted.

CRITICALCivil cases

Applies to

Jury instructions

Parties must separate proposed jury instructions into groups of agreed-upon versus not-agreed-upon instructions.

The parties shall separate the instructions into groups of agreed-upon versus not-agreed-upon instructions.

CRITICALCivil cases

Applies to

List of proposed jury instructions

The List of Proposed Jury Instructions must be organized in numerical order with columns showing whether each instruction is agreed or contested, plus columns for the trial judge to indicate given, given as modified, refused, or withdrawn.

those contested), organized in numerical order, including columns to indicate whether an instruction is agreed to or contested. In addition, the List of Proposed Jury Instructions must include columns for a trial judge to indicate whether an instruction was given, given as modified, refused, or withdrawn. (See Cal. Rules of Court, rule 2.1055.)

CRITICALCivil cases

Applies to

Verdict form

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

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

CRITICALCivil cases

Applies to

Moving papers

Moving papers must be filed with the CRS reservation receipt number printed on the face page under the caption and with the reservation receipt attached as the last page.

After reserving a motion hearing date, the reservation requestor must submit the moving papers for filing with the reservation receipt number printed on the face page of the document under the caption and attach the reservation receipt as the last page.

CRITICALCivil cases

Applies to

Ex parte application

Ex parte relief is granted only upon an admissible-evidence showing of irreparable harm or immediate danger (or other grounds stated in the continuation of the sentence).

The Court will only grant ex parte relief upon a showing, by admissible evidence, that the moving party will suffer “irreparable harm,” “immediate danger,” or where the moving party

CRITICALCivil cases

Applies to

Deposition designation chart

Parties intending to use deposition or former trial testimony must meet and confer and jointly file a chart containing columns for designations, objections, counter-designations, responses, and the Court's ruling.

If the parties intend to use deposition testimony or former trial testimony in lieu of any witness' 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 ruling.

CRITICAL

Applies to

Jury instructions

Parties must submit a joint, fully completed set of CACI instructions (no brackets, blanks, tear sheets, or disposition boxes), separate sets for disputed instructions identifying proposer and opponent, and a disposition table listing all instructions with columns for the court's rulings.

Submit a joint set of CACI instructions with all information filled in, no remaining brackets or blanks. Do not use tear sheets for the instructions and do not include the disposition box on the page of the individual instruction. If some instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction. Submit a disposition table which lists all jury instructions by number, the identity of the party or parties proposing the instruction, and which contains columns for the court to indicate whether the instruction is given, modified, withdrawn or refused.

CRITICAL

Applies to

Joint short statement

4. JOINT SHORT STATEMENT TO BE READ TO THE JURY. This statement should be a brief, neutral description of the case. In most instances, it should not exceed 2-3 paragraphs.

4. JOINT SHORT STATEMENT TO BE READ TO THE JURY. This statement should be a brief, neutral description of the case. In most instances, it should not exceed 2-3 paragraphs.

CRITICAL

Applies to

Stipulation and proposed order

Must include

proposed order

Counsel must file a stipulation and proposed order setting forth available dates to obtain an informal discovery conference.

For an informal discovery conference, counsel shall file a stipulation and proposed order which sets forth dates that counsel would be available for the informal discovery conference.

CRITICAL

Applies to

Joint jury instructions

Joint CACI jury instructions and disposition table required 5 court days before final status conference for jury trials.

3. JOINT JURY INSTRUCTIONS. Submit a joint set of CACI instructions with all information filled in, no remaining brackets or blanks. Do not use tear sheets for the instructions and do not include the disposition box on the page of the individual instruction. If some instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction. Submit a disposition table which lists all jury instructions by number, the identity of the party or parties proposing the instruction, and which contains columns for the court to indicate whether the instruction is given, modified, withdrawn or refused.

CRITICAL

Applies to

Joint exhibit list

For jury trials, all exhibits must be listed on a single numbered joint exhibit list with brief descriptions, and exhibit notebooks must be available at the final status conference with all parties prepared to confirm they reviewed the exhibit book.

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.

CRITICAL

Applies to

Trial brief

COURT TRIALS. The parties must submit a joint exhibit list and joint witness list as described above. A trial brief must be served and filed no later than the final status conference.

COURT TRIALS. The parties must submit a joint exhibit list and joint witness list as described above. A trial brief must be served and filed no later than the final status conference.

CRITICAL

Applies to

Court trial submissions

In court trials, the parties must submit a joint exhibit list and a joint witness list as described in the order.

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

CRITICAL

Applies to

Joint witness list

Joint witness list with time estimates required 5 court days before final status conference for jury trials.

2. JOINT WITNESS LIST. All witnesses must be listed on one list. Do not repeat the name of a witness who will be called by more than one party. Next to each witness, indicate the total time expected for that testimony (including direct, cross, redirect, etc.) At the end of the list, total the time estimated for testimony. Make realistic time estimates. Absent good cause, the total number of hours listed for testimony should not exceed the trial estimate given at the case management conference, including the allocation of 1 day for jury selection and 1 day for deliberations. For example, a 5 day trial estimate means no more than 3 days of testimony.

CRITICAL

Applies to

Evidentiary objection

Counsel filing evidentiary objections in connection with a motion for summary judgment or summary adjudication should comply with California Rules of Court Rule 3.1354. Please note an evidentiary objection must specifically identify the document in which the objectionable material is located and quote or set forth the objectionable statement or material. Counsel should not object to a “statement” contained in opposing party’s statement of undisputed material facts; rather the objection must be directed to the evidence in support of that fact and state the basis for the objection.

Counsel filing evidentiary objections in connection with a motion for summary judgment or summary adjudication should comply with California Rules of Court Rule 3.1354. Please note an evidentiary objection must specifically identify the document in which the objectionable material is located and quote or set forth the objectionable statement or material. Counsel should not object to a “statement” contained in opposing party’s statement of undisputed material facts; rather the objection must be directed to the evidence in support of that fact and state the basis for the objection.

CRITICAL

Applies to

Stipulation

Must include

proposed order

Stipulation and proposed order required to request informal discovery conference.

For an informal discovery conference, counsel shall file a stipulation and proposed order which sets forth dates that counsel would be available for the informal discovery conference.

CRITICAL

Applies to

Joint proposed verdict form

5. JOINT PROPOSED VERDICT FORM. If the parties cannot agree on the verdict form, each party must submit a proposed verdict form. Any proposed special verdict should be in a form that is easily used by the jury, and which does not require the jury to answer unnecessary questions.

5. JOINT PROPOSED VERDICT FORM. If the parties cannot agree on the verdict form, each party must submit a proposed verdict form. Any proposed special verdict should be in a form that is easily used by the jury, and which does not require the jury to answer unnecessary questions.

CRITICAL

Applies to

Joint witness list

The joint witness list must include all witnesses on a single list without duplicated names, with expected testimony time for each witness and a total time estimate at the end.

All witnesses must be listed on one list. Do not repeat the name of a witness who will be called by more than one party. Next to each witness, indicate the total time expected for that testimony (including direct, cross, redirect, etc.) At the end of the list, total the time estimated for testimony.

CRITICAL

Applies to

Evidentiary objection

Counsel filing evidentiary objections in connection with a motion for summary judgment or summary adjudication should comply with California Rules of Court Rule 3.1354. Please note an evidentiary objection must specifically identify the document in which the objectionable material is located and quote or set forth the objectionable statement or material. Counsel should not object to a “statement” contained in opposing party’s statement of undisputed material facts; rather the objection must be directed to the evidence in support of that fact and state the basis for the objection.

Counsel filing evidentiary objections in connection with a motion for summary judgment or summary adjudication should comply with California Rules of Court Rule 3.1354. Please note an evidentiary objection must specifically identify the document in which the objectionable material is located and quote or set forth the objectionable statement or material. Counsel should not object to a “statement” contained in opposing party’s statement of undisputed material facts; rather the objection must be directed to the evidence in support of that fact and state the basis for the objection.