Los Angeles Superior Court Pre-Motion Conference Requirements
514 rules from official source documents
Rules 1 to 50, page 1 of 11
Pre-motion conference and letter requirements before filing motions, including sequential steps.
CRITICALCivil cases
Parties must meet and confer to resolve objections to the admissibility of each exhibit, per Local Rules 3.52(i)(5) and 3.53.
To comply with Local Rules 3.52(i)(5) and 3.53, the parties shall meet and confer in an effort to resolve objections to the admissibility of each exhibit.
CRITICALCivil cases
Parties must meet and confer in real time (video conference or telephone) before preparing any motion challenging or seeking to amend the pleadings.
To avoid the inefficiency of preparing, opposing and potentially hearing demurrers that are moot or to otherwise cannot be granted, the court requires the parties to meet and confer in real time (video conference or telephone) before preparing any motion challenging or seeking to amend the pleadings.
CRITICALCivil cases
Parties must meet and confer twice by telephone or video before requesting an IDC, and are expected to extend motion-to-compel deadlines to accommodate the process.
Judge Cunningham requires the parties to meet and confer twice via telephone or video conference before requesting an IDC and expects the parties to extend the time for filing motions to compel to accommodate this process.
CRITICALCivil cases
Before investing any time in the preparation of an ex parte application, please post a joint request for an informal conference on the e-service bulletin and contact the courtroom staff to obtain a time and date.
Before investing any time in the preparation of an ex parte application, please post a joint request for an informal conference on the e-service bulletin and contact the courtroom staff to obtain a time and date.
CRITICALCivil cases
Before filing a motion challenging or amending the pleadings, the parties must confer with the Court at a status conference or an informal pleadings conference scheduled via joint bulletin board posting.
Before such a motion is filed, the Court also requires the parties confer with the Court, either at a status conference or an informal pleadings conference scheduled in response to a joint posting on the bulletin board.
CRITICALCivil cases
Parties must meet and confer both before and after filing motions in limine to reach evidentiary stipulations and limit contested motions to a manageable number.
Before and after filing motions in limine, the parties shall meet and confer in an effort to reach stipulations resolving disputes over the admissibility of evidence and to limit the contested motions in limine to a manageable number.
CRITICALCivil cases
The Court expects counsel to identify all intended motions when counsel appear for status conferences so that the Court can explore, with counsel, whether the Court can reach the substantive issue such a motion and whether the proposed motion is the most efficient and effective "next step" in the proceedings. The parties should not surprise the court by filing motions they have not proposed to the Court. Before starting work on a motion not previously discussed with eCourt, a party should request, via the bulleting board, an information conference with the court, or porose the motion at the next status conference.
The Court expects counsel to identify all intended motions when counsel appear for status conferences so that the Court can explore, with counsel, whether the Court can reach the substantive issue such a motion and whether the proposed motion is the most efficient and effective "next step" in the proceedings. The parties should not surprise the court by filing motions they have not proposed to the Court. Before starting work on a motion not previously discussed with eCourt, a party should request, via the bulleting board, an information conference with the court, or porose the motion at the next status conference.
CRITICALCivil cases
Motions in limine will be heard at the time of the FSC. See Local Rule 3.25(f)(2). Motions in limine are governed by the statutory notice requirements set forth in Code of Civil Procedure sections 1005(b) and 1013. Because motions in limine will be heard at the time of the FSC, they should not be calendared through the Court Reservation System.
Motions in limine will be heard at the time of the FSC. See Local Rule 3.25(f)(2). Motions in limine are governed by the statutory notice requirements set forth in Code of Civil Procedure sections 1005(b) and 1013. Because motions in limine will be heard at the time of the FSC, they should not be calendared through the Court Reservation System.
CRITICALCivil cases
Moving parties must reserve a hearing date through the online civil Court Reservation System before filing any motion, except motions in limine which are heard at the Final Status Conference.
Moving parties must secure a hearing date via the online Court Reservation System on the Superior Court of Los Angeles County website. Please see the "Online Services" section to find the civil Court Reservation System at www.lacourt.ca.gov to reserve a hearing date prior to filing any motion, except for motions in limine, which, by Local Rule, are heard during the Final Status Conference.
CRITICAL
All motions to be heard in Department W must first be reserved through the Court Reservation System (CRS) on the court's website.
All motions to be heard in Department W are to be reserved through the Court Reservation System. Follow the links Online Services – Court Reservation System (CRS) on the court's website.
CRITICAL
Counsel must meet and confer on all motions in limine, and failure to exchange or discuss them may result in the court refusing to hear the motion.
Counsel shall meet and confer on all motions in limine.
CRITICAL
discovery conference (IDC) prior to the filing of any discovery motion. After completion of the mandatory good faith meet and confer process, parties can request an informal discovery conference.
discovery conference (IDC) prior to the filing of any discovery motion. After completion of the mandatory good faith meet and confer process, parties can request an informal discovery conference.
CRITICAL
Counsel and parties must make meaningful good-faith meet-and-confer efforts to resolve discovery disputes before resorting to discovery motions.
Counsel and parties must make all efforts to resolve discovery disputes among themselves in a courteous, reasonable, and professional manner through a credible and meaningful meet and confer process, instead of simply defaulting to expensive and cumbersome discovery motions.
CRITICALCivil cases
Moving parties must reserve a hearing date via the online Court Reservation System (CRS) before filing any motion, except motions in limine.
Moving parties must secure a hearing date via the online Court Reservation System (CRS) on the Los Angeles Superior Court website. Please see the "Online Services" section to find the civil Court Reservation System at www.lacourt.org to reserve a hearing date prior to filing any motion, except for motions in limine, which are normally heard at the final status conference or the first day of trial.
CRITICALCivil cases
Parties are ordered to meet and confer in good faith to informally resolve discovery disputes, and the Court generally finds conferring only by letters and emails to be insufficient.
Per CCP section 2016.040, the parties are ordered to meet and confer to make reasonable, good-faith e orts to informally resolve discovery disputes. The Court generally finds that meeting and conferring by only exchanging letters and e-mails, as opposed to phone or video conversation, is insu icient and ine ective.
CRITICALCivil cases
After meeting and conferring about available dates for an IDC, the parties should file a joint statement (no longer than 5 pages) that succinctly summarizes the nature of the dispute, necessity for the discovery, and objection or other basis for withholding the information, as well as overall status of discovery. Parties should briefly indicate what e orts were made to informally resolve the issue.
After meeting and conferring about available dates for an IDC, the parties should file a joint statement (no longer than 5 pages) that succinctly summarizes the nature of the dispute, necessity for the discovery, and objection or other basis for withholding the information, as well as overall status of discovery. Parties should briefly indicate what e orts were made to informally resolve the issue.
CRITICALCivil cases
Parties must meet and confer in good faith before filing motions in limine; failure to do so may result in summary denial.
Parties must meet and confer in good faith prior to filing the motions in limine, to try to reach a stipulation on the evidence and other issues. A simple exchange of letters that identify the motions to be filed is not su icient. Failure to meet and confer in good faith may result in a summary denial of the motion.
CRITICALCivil cases
Parties must meet and confer in good faith before filing motions in limine to attempt to reach a stipulation, and failure to do so may result in summary denial of the motion.
Parties must meet and confer in good faith prior to filing the motions in limine, to try to reach a stipulation on the evidence and other issues. A simple exchange of letters that identify the motions to be filed is not su icient. Failure to meet and confer in good faith may result in a summary denial of the motion.
CRITICAL
Final Status Conference set at least 10 days before trial; lead trial counsel must appear unless excused.
The Court will set a Final Status Conference at least 10 days before the trial date. Unless the Court orders otherwise, lead trial counsel shall appear at the FSC.
CRITICAL
All motion hearing dates must be reserved in advance via the Court Reservation System (CRS), with motions heard at 8:30 a.m. Monday through Friday.
Parties must reserve all motion hearing dates in advance on the Court Reservation System at www.lacourt.ca.org, under "Online Services," "Civil," "Court Reservation System (CRS)." Motions are set for hearing at 8:30 a.m., Monday through Friday.
CRITICAL
Before filing any discovery motion, parties must meet and confer and, if unresolved, schedule and participate in an Informal Discovery Conference with the Courtroom Assistant, which tolls the discovery motion filing deadline.
The parties must first meet and confer in person, by video conference, or by telephone call to attempt to informally resolve all discovery disputes. If the parties cannot agree, the Court requests that the parties schedule an Informal Discovery Conference (IDC) with the Courtroom Assistant and participate in an IDC before filing any discovery motion. Scheduling an IDC tolls the deadline for filing a discovery motion until further order of the Court.
CRITICAL
All motion hearing dates must be reserved in advance via the Court Reservation System; motions heard at 8:30 AM Mon-Fri.
Parties must reserve all motion hearing dates in advance on the Court Reservation System at www.lacourt.ca.org, under “Online Services,” “Civil,” “Court Reservation System (CRS).” Motions are set for hearing at 8:30 a.m., Monday through Friday.
CRITICAL
If the parties cannot agree, the Court requests that the parties schedule an Informal Discovery Conference (IDC) with the Courtroom Assistant and participate in an IDC before filing any discovery motion. Scheduling an IDC tolls the deadline for filing a discovery motion until further order of the Court.
If the parties cannot agree, the Court requests that the parties schedule an Informal Discovery Conference (IDC) with the Courtroom Assistant and participate in an IDC before filing any discovery motion. Scheduling an IDC tolls the deadline for filing a discovery motion until further order of the Court.
CRITICALCivil cases
Moving parties must reserve a hearing date via the civil Court Reservation System before filing any motion, except motions in limine which are heard at the Final Status Conference.
Moving parties must secure a hearing date via the online Court Reservation System on the Los Angeles Superior Court website. Please see the "Online Services" section to find the civil Court Reservation System at www.lacourt.org to reserve a hearing date prior to filing any motion, except for motions in limine, which, by Local Rule, are heard during the Final Status Conference.
CRITICALCivil cases
Pursuant to Code of Civil Procedure section 2016.040, the parties and counsel are ordered to meet and confer to make reasonable, good-faith efforts to informally resolve discovery disputes. Should the parties wish to file a motion to compel further responses to discovery, or other discovery motions regarding depositions or subpoenas, the parties must first meet and confer in good faith either in person or by telephone or videoconference.
Pursuant to Code of Civil Procedure section 2016.040, the parties and counsel are ordered to meet and confer to make reasonable, good-faith efforts to informally resolve discovery disputes. Should the parties wish to file a motion to compel further responses to discovery, or other discovery motions regarding depositions or subpoenas, the parties must first meet and confer in good faith either in person or by telephone or videoconference.
CRITICALCivil cases
Parties must meet and confer in good faith before filing motions in limine, in person, by telephone, or via videoconference, to attempt to reach a stipulation on the evidence.
The parties and counsel shall meet and confer in good faith prior to filing the motions in limine to attempt to reach a stipulation on the evidence and other issues. (See Local Rule 3.57(a)(2).) This meet-and-confer session shall take place in person, over the telephone, or via videoconference.
CRITICALCivil cases
The Court generally will not hear discovery motions until an IDC is conducted, and absent good cause, motions filed before an IDC will be continued until after the IDC.
The Court generally will not hear motions to compel further discovery, or the other above-described discovery motions until an IDC is conducted. Absent a showing of good cause, motions filed before an IDC is conducted will be continued until after the IDC, which the parties should schedule as soon as possible after the dispute emerges.
CRITICAL
Meet and confer before drafting MILs.
Meet and confer before drafting MILs.
CRITICAL
Before filing a discovery motion, parties must exhaust meet and confer efforts in person or via phone; a letter or email does not suffice.
The Court strongly discourages discovery motions and requires the parties to exhaust meet and confer efforts before filing discovery motions. “Meet and confer” in Department 51 means in person or via phone. A letter or email does not suffice.
CRITICAL
All motions to be heard in Dept. F51 must be reserved in advance through the Court Reservation System (CRS).
All motions to be heard in Dept. F51 are to be reserved through the Court Reservation System (CRS).
CRITICAL
Parties must meet and confer in person, by video conference, or by telephone to attempt to informally resolve all discovery disputes. If the parties cannot agree, the Court requests that the parties schedule an Informal Discovery Conference (“IDC”) with the Courtroom or Judicial Assistant and participate in an IDC before filing any discovery motion. Scheduling an IDC tolls the deadline for filing a discovery motion until further order of the Court. If a motion is filed without a prior IDC, the Court may continue the hearing so that the parties can schedule an IDC.
Parties must meet and confer in person, by video conference, or by telephone to attempt to informally resolve all discovery disputes. If the parties cannot agree, the Court requests that the parties schedule an Informal Discovery Conference (“IDC”) with the Courtroom or Judicial Assistant and participate in an IDC before filing any discovery motion. Scheduling an IDC tolls the deadline for filing a discovery motion until further order of the Court. If a motion is filed without a prior IDC, the Court may continue the hearing so that the parties can schedule an IDC.
CRITICAL
All parties must reserve a motion hearing date through the online Court Reservation System (CRS) before filing any motion papers.
All parties must obtain a motion date via the online Court Reservation System (CRS) on the Los Angeles Court website. Go to “LA Court Online, Court Reservation System,” at http://www.lacourt.ca.gov/ to reserve a date prior to filing any motion papers.
CRITICAL
Trial counsel must meet and confer (in person, videoconference, or telephone) no later than 15 calendar days before the initial and any succeeding CMC to address the issues in CRC Rules 3.724 and 3.727.
Trial counsel are required to meet and confer in person, via videoconference, or by telephone no later than 15 calendar days before the date set for the initial and any succeeding CMC to consider each of the issues identified in CRC Rules 3.724 and 3.727.
CRITICAL
Trial counsel must meet and confer in person, by telephone, or by videoconference before bringing a discovery motion, and exchanging letters or emails alone is insufficient.
The Court strongly discourages discovery motions and encourages informal resolution of discovery disputes. Trial counsel must meet and confer in person, by telephone, or videoconference to resolve or narrow the discovery dispute. Merely exchanging letters or emails is insufficient.
CRITICAL
Trial counsel must meet and confer in person, by phone, or video to resolve discovery disputes before filing discovery motions; letters/emails insufficient.
Trial counsel must meet and confer in person, by telephone, or videoconference to resolve or narrow the discovery dispute. Merely exchanging letters or emails is insufficient.
CRITICAL
Before filing a noticed motion for discovery beyond sections 2-6, the parties must meet and confer regarding the additional discovery needed to prepare the case for trial.
To the extent any party concludes that additional discovery is necessary beyond sections 2-6, that party shall by noticed motion request such discovery. In advance of any such request, the parties are ordered to meet and confer regarding any additional discovery needed to prepare this case for trial.
CRITICAL
Discovery Conference (IDC) by filing an IDC request [LACIV094] See https://www.lacourt.org/forms/pdf/LACIV094.pdf. The court will review the request and issue an order granting or denying the request. If granted, the clerk will schedule an IDC. The IDC should eliminate any need for a motion. Absent a showing of good cause, the Court may continue any discovery motion filed before the IDC process is concluded.
Discovery Conference (IDC) by filing an IDC request [LACIV094] See https://www.lacourt.org/forms/pdf/LACIV094.pdf. The court will review the request and issue an order granting or denying the request. If granted, the clerk will schedule an IDC. The IDC should eliminate any need for a motion. Absent a showing of good cause, the Court may continue any discovery motion filed before the IDC process is concluded.
CRITICAL
Parties must meet and confer no later than 11 calendar days before the Final Status Conference to prepare required trial documents and binders, attempt stipulations on exhibit authenticity/admissibility and motions in limine, and discuss settlement.
No later than 11 calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall meet and confer to do the following: (1) discuss and prepare the documents required in Sections 2.B-H below, and the Motions in Limine Binder, Exhibit Binders, and Trial Binder required in Sections 3-5 below, (2) discuss and make a good faith effort to stipulate to the authenticity and admissibility of each trial exhibit, (3) discuss and make a good faith effort to stipulate to resolve each motion in limine, (4) discuss and make a good faith effort to settle the case.
CRITICAL
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
The parties must first meet and confer in person, by video conference, or by telephone call to attempt to informally resolve all discovery issues. If the parties cannot agree, the Court requests that the parties schedule an Informal Discovery Conference (IDC) with the Courtroom Assistant and participate in the IDC before filing any discovery motion.
The parties must first meet and confer in person, by video conference, or by telephone call to attempt to informally resolve all discovery issues. If the parties cannot agree, the Court requests that the parties schedule an Informal Discovery Conference (IDC) with the Courtroom Assistant and participate in the IDC before filing any discovery motion.
CRITICAL
Parties must obtain and schedule a motion hearing date through the online Court Reservation System (CRS) on the Superior Court of Los Angeles County website.
Parties must obtain and schedule a motion hearing date via the online Court Reservation System (CRS) on the Superior Court of Los Angeles County website: “Online Services” tab.
CRITICALCivil cases
A motion in limine seeking to restrain opposing counsel's conduct may not be filed unless the moving party first contacts opposing counsel and that attorney states an intent to do the act; motions in limine must also not be misused or frivolous.
No motion in limine is to be filed asking the court to order that opposing counsel not do “x,” “y,” or “z,” unless that opposition attorney has first been contacted and stated that they intend to do what the moving party wants to prevent. Also, motions in limine should not be misused or frivolous such as general requests to direct an opponent “not to use documents not produced in discovery” or “not to ask leading questions,” etc.
CRITICALCivil cases
Discovery motions will not be heard until an IDC is conducted; except for good cause, motions filed before an IDC are continued until after the IDC.
No motion to compel further discovery, or the other above-described discovery motions will be heard until an IDC is conducted so do not wait until the deadline to attempt to meet and confer. Except for good cause, motions filed before an IDC is conducted will be continued until after the IDC, which the parties should schedule as soon as possible after the dispute emerges.
CRITICALCivil cases
Parties must reserve a motion hearing date via the online Court Reservation System (CRS) at lacourt.org before filing any motion papers, except ex parte motions.
Parties are required to obtain and reserve a motion hearing date via the online Court Reservation System (CRS) on the Los Angeles Superior Court website. Go to "LA Court Online, Court Reservation System" at http://www.lacourt.org to reserve a date before filing any motion papers (except ex parte motions).
CRITICALCivil cases
Before filing a motion to compel further discovery or other discovery motions, counsel must meet and confer in good faith and, if unresolved, request an Informal Discovery Conference by filing form LACIV 094.
Should the parties wish to file a motion to compel further responses to discovery, or other discovery motions regarding depositions or subpoenas, at any time during the pendency of this case, counsel must first meet and confer in good faith either in person, telephonically or by video conference. If the parties are unable to resolve their discovery disputes, the Court requests that counsel schedule an Informal Discovery Conference (IDC). Counsel must request an IDC by filing form LACIV 094 – Informal Discovery Conference and the responding counsel may file an Answer using the same form.
CRITICALCivil cases
Parties must meet and confer in person, by telephone, or by video conference before filing any motion, and the Court may continue the hearing if they did not.
Parties are required to meet and confer in person, by telephone, or by video conference before filing any motion. The Court may elect to continue a hearing on a motion where the parties have not met and conferred in advance.
CRITICAL
Law and motion hearings must be scheduled through the Court Reservation System (CRS), and reserving more than one hearing date for the same motion is prohibited.
The Court Reservation System (CRS) is required for scheduling law and motion hearings in Dept. F46. CRS is available 24 hours a day, 7 days a week and reservations can be made from a computer or smartphone. Please note, you are prohibited from reserving more than one hearing date for the same motion.
CRITICAL
Demurrers must comply with the Code of Civil Procedure section 430.41 meet and confer requirements or they will be taken off calendar.
Counsel intending to file a demurrer should review the new requirements, including meet and confer requirements, set forth in Code of Civil Procedure section 430.41, and rethink whether a demurrer is necessary or even advisable. Demurrers filed without compliance with the meet and confer requirements will be taken off calendar.
CRITICAL
Demurrers without meet and confer compliance will be taken off calendar.
Demurrers filed without compliance with the meet and confer requirements will be taken off calendar.
CRITICAL
Counsel and self-represented litigants must meet and confer 10 court days before Final Status Conference.
counsel and/or self-represented litigants shall meet and confer on the telephone or by video conference at least 10 court days before the FSC to discuss, arrange for the exchange of, and the submission to the Court all documents identified in LACSCR 3.25(f) and(f)(3)-(8).
Does Los Angeles Superior Court require a pre-motion conference or letter before filing a motion?
Judge Upinder S. Kalra and Judge Lauren A. R. Lofton: Parties must meet and confer before filing any motion in limine per Local Rule 3.57.
Judge Mark A. Young: Motions to Compel Further require an Informal Discovery Conference scheduled by the moving party, who must confer with opposing counsel to obtain three available dates and notice the court.
Judge Jerrold Abeles: Parties intending to file a summary judgment or summary adjudication motion must reserve a hearing date immediately, since reservation dates fill quickly and may not be available at least 30 days before trial.
492 more rules answer this question.
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