Los Angeles Superior Court Document Format Requirements

CRITICAL

The trial binder must be tabbed, organized into three-ring binders, and include a table of contents.

The parties/counsel shall jointly prepare and lodge with the Court at the FSC, a trial binder containing the above-described trial documents, which shall be tabbed and organized into three-ring binders with a table of contents

CRITICAL

Applies to

Motion in limine

Motions in limine must be numbered consecutively in the caption.

The caption of each motion in limine shall number them consecutively.

CRITICAL

Applies to

Exhibits

Exhibits must be bate stamped and tabbed with numbers matching joint exhibit list.

Exhibits must be bate stamped and tabbed with exhibit numbers that correspond to those on the joint exhibit list.

CRITICALCivil cases

Applies to

Jury instruction

Final jury instructions and verdict forms must not include citations, party identification, or attorney letterhead/markings, and must be suitable for jury deliberation.

The parties are jointly responsible for the preparation of a final set of jury instructions and verdict forms after the Court rules on any disputes. The final set of jury instructions and verdict forms shall be in a format suitable for submission to the jury during deliberations, and shall not include any citations to authority, identification of the party requesting the instruction or verdict, or any letterhead or markings identifying the attorney who prepared or printed them. (LASCR 3.174).

CRITICALCivil cases

Deposition excerpts cited in briefs must be marked on the transcript exhibits attached to the filing.

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

CRITICALCivil cases

Applies to

Exhibit

Exhibits must be tabbed, internally paginated, properly marked, organized numerically in three-ring binders for court, judicial assistant, and witnesses, with non-documentary exhibits described.

The parties shall jointly prepare (and be ready to temporarily lodge for inspection at the FSC) one set of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (a set for the Court, the Judicial Assistant, and the witnesses). At trial, the parties will need additional copies of the exhibits for the Court’s clerk, for use on the witness stand, and for each counsel. The parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the exhibit binder.

CRITICALCivil cases

Applies to

Trial binder

Counsel must provide a joint trial binder for the Court at the FSC. The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Motions in Limine Tab C: Joint Statement of the Case Tab D: Joint Witness List Tab E: Joint List of Jury Instructions (joint and contested) Tab F: Full Text Jury Instructions Tab G: Joint and/or Contested Verdict Forms Tab I: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab J: Operative Pleadings Tab K: Stipulations If there are more than a few motions in limine, they should be placed in a separate binder. Whether in a separate binder or Tab B, Plainti ’s should come first, followed by those of Defendant. There should be numbered tabs separating each motion and colored sheets of paper between the motion and any opposition and between the opposition and any reply.

Counsel must provide a joint trial binder for the Court at the FSC. The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Motions in Limine Tab C: Joint Statement of the Case Tab D: Joint Witness List Tab E: Joint List of Jury Instructions (joint and contested) Tab F: Full Text Jury Instructions Tab G: Joint and/or Contested Verdict Forms Tab I: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab J: Operative Pleadings Tab K: Stipulations If there are more than a few motions in limine, they should be placed in a separate binder. Whether in a separate binder or Tab B, Plainti ’s should come first, followed by those of Defendant. There should be numbered tabs separating each motion and colored sheets of paper between the motion and any opposition and between the opposition and any reply.

CRITICALCivil cases

All electronically filed documents must be text-searchable and include bookmarks.

All electronically filed documents must be text-searchable and bookmarked. (See operative General Order re Mandatory Electronic Filing in Civil., referenced above.)

CRITICALCivil cases

Final jury instructions and verdict forms must be suitable for jury deliberations and may not contain citations to authority, party identification, or attorney letterhead/markings.

The final set of jury instructions and verdict forms shall be in a format suitable for submission to the jury during deliberations, and shall not include any citations to authority, identification of the party requesting the instruction or verdict, or any letterhead or markings identifying the attorney who prepared or printed them. (LASCR 3.174).

CRITICALCivil cases

Parties must jointly prepare one set of tabbed, internally paginated, properly marked exhibits organized numerically in three-ring binders for the Court, the Judicial Assistant, and the witnesses, ready to lodge for inspection at the FSC.

The parties shall jointly prepare (and be ready to temporarily lodge for inspection at the FSC) one set of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (a set for the Court, the Judicial Assistant, and the witnesses).

CRITICALCivil cases

All non-documentary exhibits must be marked, with a simple written description inserted behind the corresponding numerical tab in the exhibit binder.

The parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the exhibit binder.

CRITICALCivil cases

Courtesy copies of documents containing declarations and/or exhibits must be tabbed.

Any courtesy copies of documents with declarations and/or exhibits must be tabbed. (Rules of Court, rule 3.1110(f).)

CRITICALCivil cases

All electronically filed documents must be text-searchable and bookmarked.

All electronically filed documents must be text-searchable and bookmarked. (See operative General Order re Mandatory Electronic Filing in Civil., referenced above.)

CRITICALCivil cases

Exhibits must be pre-marked with Arabic numerals, and each page of multi-page exhibits must be numbered sequentially.

Pursuant to Local Rules 3.52 and 3.53, the exhibits must be pre-marked using Arabic numerals and in instances where exhibits consist of multiple pages, each page must be numbered sequentially.

CRITICALCivil cases

All filings must comply with the technical requirements set forth in the General Order re Mandatory Electronic Filing for Civil (May 3, 2019).

All filings shall comply with the technical requirements set forth in that general order.

CRITICAL

Self-represented litigants must staple all papers separately before filing, or they will be rejected.

All papers filed by self-represented litigants must be stapled separately before filing, or they will be rejected.

CRITICAL

Self-represented litigants' papers must be stapled separately before filing or they will be rejected.

All papers filed by self-represented litigants must be stapled separately before filing, or they will be rejected.

CRITICAL

Identical copies of the exhibit list and all exhibits must be provided in 3-ring binders — one for each party, one for the Court, and one for the witness stand.

Identical copies of the Exhibit List and all exhibits must be provided in 3-ring binders as follows: one for each party, one for the Court, and one for the witness stand.

CRITICAL

Exhibit binders must be three-ring binders available at the final status conference, with the exhibit list in front, tabs matching exhibit numbers, and internally numbered pages for multi-page exhibits.

Three-ring binders 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 an opportunity to review all documents in the exhibit notebooks. Place a copy of the exhibit list in the front of each exhibit notebook and place tabs in the notebook to correspond with the exhibit number. If an exhibit contains more than one page, pages must be internally numbered, i.e., 3.1, 3.2, 3.3, etc.

CRITICAL

Proposed jury instructions must be in a jury-ready format containing only the instruction number, title, and text, with no tear sheets or markings indicating the requesting party.

The parties/counsel shall prepare proposed instructions in a format ready for submission to the jury with the instruction number, title, and text only (i.e., there should be no tear sheets and no boxes or other indication on the printed instruction itself as to the requesting party).

CRITICAL

Each designation or counter-designation must be highlighted, with each party using a different color highlighter.

Each designation or counter-designation shall be highlighted with each party using a different color highlighter.

CRITICAL

Parties must attach copies of the designated or counter-designated transcript pages to the designation chart, with tabs separating each deposition or trial transcript.

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 chart, with tabs separating each deposition or trial transcript.

CRITICAL

Trial documents must be tabbed and the trial notebook must include a table of contents listing documents by tab number.

The trial documents must be tabbed, and the notebook must contain a table of contents listing the trial documents by tab number.

CRITICAL

Each exhibit must be separately numbered to correspond with the joint exhibit list, and multi-page exhibits must have internally numbered pages (e.g., 3.1, 3.2, 3.3).

Each exhibit must be separately numbered, with the numbers corresponding to the number of theexhibit on the joint exhibit list. If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3 etc.

CRITICAL

Counsel must leave at least four inches of blank space on any addenda to form jury instructions (sentence continues across a page break; see source).

Leave at least four inches of blank ... any addenda to form instructions.

CRITICAL

The parties shall work together to provide exhibits electronically, if feasible.

The parties shall work together to provide exhibits electronically, if feasible.

CRITICAL

Applies to

Trial notebook

Format

PAPER

Trial notebook must be provided in paper format to the court.

The parties must provide both a paper “trial notebook” for the Court and submit FSC/trial documents electronically.

CRITICAL

Copies of motions in limine, opposition, and reply papers must be organized in one or more three-ring binders, tabbed numerically, with opposition and reply papers placed directly behind the moving papers and separated by colored sheets (sentence continues from prior page).

copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders, tabbed in numerical order with the opposition papers and reply papers for each motion placed directly behind the moving papers with a colored sheet of paper separating the moving, opposition, and reply papers.

CRITICAL

The parties’ counsel and any self-represented parties shall work together to jointly prepare four sets of tabbed, internally paginated by document, and properly marked exhibits, organized numerically in three-ring binders (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) (“Exhibit Binders”).

The parties’ counsel and any self-represented parties shall work together to jointly prepare four sets of tabbed, internally paginated by document, and properly marked exhibits, organized numerically in three-ring binders (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) (“Exhibit Binders”).

CRITICAL

CMC statements must be filed on Judicial Council Form CM-110 within 5 days of the hearing.

file a CMC statement on Judicial Council Form CM-110 within five (5) days of the hearing.

CRITICAL

Format

DOCX

Proposed jury instructions must be prepared on Los Angeles Superior Court form SCLAC LACIV 129 or in a Word document in the same format.

The proposed jury instructions shall be prepared on Superior Court of Los Angeles County form SCLAC LACIV 129 or in a Word document that is in the same format.

CRITICAL

Parties must attach copies of the designated transcript pages to the Joint Chart with numbered tabs separating each transcript, and all designated pages for each transcript must appear in page order behind a single tab.

The parties shall attach a copy 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 Designations for Deposition and Former Testimony, with numbered tabs separating each deposition or trial transcript. For each transcript, all pages containing the designations and counter-designations shall be included in a single document in page order behind a single tab.

CRITICALCivil cases

Exhibits must be numbered (not lettered), Bates stamped, identified separately, organized with plaintiff starting at number 1 and a separate defendant numerical block, and multi-page exhibits consecutively paginated; bulk exhibits are not permitted.

The joint exhibit list should begin with the number 1 for plaintiff and a separate numerical block for defendant. Exhibits should be numbered and not designated by letters. Each exhibit must be identified separately and Bates stamped. Bulk exhibits (e.g., "plaintiffs medical records") will not be permitted. Each page of a multi-page exhibit must be consecutively paginated (e.g., exhibit 1 will be 1-1, 1-2, etc.).

CRITICAL

The trial binder must be a 3-ring binder delivered to Dept. F46 at least 10 court days before the Final Status Conference.

Trial Binder: the parties shall cooperate in compiling a 3-ring trial binder that shall be delivered to Dept. F46 at least 10 court days before the FSC.

CRITICAL

Exhibits must be pre-numbered, the requisite number of exhibit books must be produced, and parties may not produce exhibits opposing counsel has never seen (unless for impeachment) or expect the clerk to track exhibits.

Please do not: 1. Fail to pre-number your exhibits 2. Expect the clerk to keep track of your exhibits 3. Produce exhibits at trial which opposing counsel has never seen, unless they are used for impeachment 4. Fail to produce the requisite number of exhibit books

CRITICAL

Trial Readiness Binder documents must be tabbed and the notebook must include a table of contents listing the documents by tab number.

The trial documents must be tabbed, and the notebook must contain a table of contents listing the trial documents by tab number.

CRITICAL

Non-documentary exhibits must be represented in a binder with a simple written description.

Non-documentary exhibits shall be represented in a binder with a simple written description.

CRITICAL

Each page of a multi-page exhibit must be consecutively paginated.

Each page of a multi-page exhibit must be consecutively paginated.

CRITICAL

Bulk exhibits such as voluminous medical records are not permitted, and counsel must separately mark and identify the specific items within any bulk exhibit.

Bulk exhibits, e.g., voluminous medical records will not be permitted. Counsel must separately mark and identify the specific items within a bulk exhibit.

CRITICAL

Motions in limine papers must be lodged in indexed, tabbed three-ring binder 5 court days before FSC.

No later than five court days before the FSC, the moving party for each motion in limine must lodge directly in Department R an indexed and tabbed three-ring binder containing conformed copies of all moving, opposition, and reply papers for their motions in limine.

CRITICAL

Proposed special jury instructions must have 4 inches of blank space at top of each page.

Leave at least four inches of blank space of the top of every page of any proposed special jury instructions, or any addenda to form instructions.

CRITICAL

Proposed jury instructions must be organized into three cover-sheet-labeled groups: agreed-upon instructions; plaintiff's requested instructions with defendant highlighting objections; and defendant's requested instructions with plaintiff highlighting objections.

The parties shall organize proposed jury instructions into groups in the following order (labeled by cover sheets): (1) the agreed-upon instructions; (2) plaintiff’s requested instructions to which defendant objects. Defendant is to highlight the objectionable portions of the proposed instruction; and (3) defendant’s requested instructions to which plaintiff objects. Plaintiff is to highlight the objectionable portion of the proposed instruction.

CRITICAL

The List of Proposed Jury Instructions must be prepared in the index format required by CRC rule 2.1055(b)(3), including a checklist for the Court to indicate the disposition of each proposed instruction.

The List of Proposed Jury Instructions must be prepared in the index format required by CRC, rule 2.1055(b)(3), including a checklist for the Court to indicate the disposition of the proposed instructions.