Court Rules

Los Angeles Superior Court Pre-Motion Conference Requirements

514 rules from official source documents

Rules 51 to 100, page 2 of 11

Pre-motion conference and letter requirements before filing motions, including sequential steps.

CRITICAL

Parties must meet and confer on all motions in limine before the Court considers them, and boilerplate motions in limine are highly discouraged.

confer on all motions in limine before they are considered by the Court. Boilerplate motions are highly discouraged.

Judge Bernie C. LaForteza

CRITICAL

If the discovery disputes are resolved before the IDC date, the moving party must notify the Court and take both the IDC and the underlying motion off calendar as soon as possible.

If the parties resolve their discovery disputes before the IDC date, Moving Party shall notify the Court and take both the IDC and any underlying Motion to Compel Further Responses off calendar as soon as possible.

Judge Bradley S. Phillips

CRITICAL

Lead counsel or designated counsel with full authority must appear at any scheduled IDC, and IDC sessions may not be transcribed without prior Court approval.

Fourth, lead counsel (or other designated counsel for the parties with full authority) are ordered to appear for any scheduled IDC as directed by the Court. IDC sessions are informal and shall not be transcribed without prior Court approval.

Judge Bradley S. Phillips

CRITICAL

Counsel must meet and confer on all motions in limine, and boilerplate or form motions in limine are disfavored.

Counsel shall meet and confer on all motions in limine. Boilerplate or form motions in limine are disfavored.

Judge Bradley S. Phillips

CRITICAL

Filed Motions to Compel Further Responses will not receive a hearing date until the IDC process is completed, after which the Court will schedule hearings for any remaining motions.

The filed Motions to Compel Further Responses will not receive a hearing date until the IDC process is completed. At the conclusion of the IDC process, the Court will schedule hearing dates for any remaining motions to compel further.

Judge Bradley S. Phillips

CRITICAL

Before the IDC, counsel must meet and confer by telephone or video conference to attempt to resolve all pending discovery disputes, in addition to the statutory meet-and-confer requirements.

Second, prior to the IDC, counsel must meet and confer, via telephone or video conference, in an effort to resolve all pending discovery disputes. Counsel are advised to keep track of when and for how long counsel met and conferred. This meet and confer is in addition to the standard meet and confer requirements set forth in the Code.

Judge Bradley S. Phillips

CRITICAL

Before a Motion to Compel Further Responses can be set for hearing, the moving party must obtain three available Friday dates for an Informal Discovery Conference at 10:00 a.m., contact the Court to schedule it, and give notice.

First, prior to any Motion to Compel Further Responses being set for hearing by the Court, the moving party shall confer with opposing counsel and obtain three available dates on a Friday for an IDC at 10:00 a.m. and then contact the Court to schedule the IDC. Moving party shall also give notice.

Judge Bradley S. Phillips

CRITICAL

All parties must reserve a motion 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 www.lacourt.org to reserve a date prior to filing any motion papers.

Judge Bradley S. Phillips

CRITICAL

Trial counsel must meet and confer 15 calendar days before Case Management Conference.

Trial counsel are required to meet and confer by video conference, telephone or in person no later than 15 calendar days before the date set for the initial and any succeeding Case Management Conference to consider each of the issues identified in CRC Rules 3.724 and 3.727.

Judge Brian F. Gasdia

CRITICAL

Trial counsel must meet and confer (by video, telephone, or in person) no later than 15 calendar days before each Case Management Conference to address the issues in CRC Rules 3.724 and 3.727.

Trial counsel are required to meet and confer by video conference, telephone or in person no later than 15 calendar days before the date set for the initial and any succeeding Case Management Conference to consider each of the issues identified in CRC Rules 3.724 and 3.727.

Judge Brian F. Gasdia

CRITICAL

Parties must reserve a motion hearing date through the online Court Reservation System (CRS) before filing any motion papers.

Parties must obtain a motion date via the online Court Reservation System (CRS) on the Los Angeles Court website. Go to "LA Court Online Services, Court Reservation System," at www.lacourt.ca.gov to reserve a date prior to filing any motion papers.

Judge Brian F. Gasdia

CRITICAL

Before pursuing a discovery motion, counsel with settlement authority must meet and confer live (by telephone, videoconference, or in person); exchanging only letters or emails is insufficient.

Counsel with authority to compromise the dispute (preferably trial counsel) must meet and confer by telephone, videoconference, or in person to resolve or narrow the discovery dispute. Merely exchanging letters or emails is insufficient.

Judge Brian F. Gasdia

CRITICAL

Counsel must meet and confer to resolve discovery disputes before filing IDC request or discovery motion.

Counsel with authority to compromise the dispute (preferably trial counsel) must meet and confer by telephone, videoconference, or in person to resolve or narrow the discovery dispute. Merely exchanging letters or emails is insufficient. The Court expects the parties to work together in good faith to resolve discovery issues. If the dispute remains unresolved, counsel can request an Informal Discovery Conference (IDC) by filing an IDC request [LACIV094].

Judge Brian F. Gasdia

CRITICAL

Counsel must meet and confer with opposing counsel about the subject of each contemplated motion in limine before filing it.

Local Rules, rule 3.57(a)(2) requires that counsel meet and confer with their opposing counsel regarding the subject of each contemplated motion in limine before filing.

Judge Brock T. Hammond

CRITICALCivil cases

Counsel must meet and confer in person or by telephone to resolve or narrow the dispute before filing a discovery motion.

Before filing a discovery motion, counsel must meet and confer in person or by telephone to attempt to resolve or at least narrow the dispute.

Judge Bruce G. Iwasaki

CRITICAL

Parties must meet and confer in good faith before filing motions in limine in an attempt to reach a stipulation on the evidence and other issues.

The parties and counsel shall meet and confer in good faith prior to filing the motions in limine in an attempt to reach a stipulation on the evidence and other issues. (See Local Rule 3.57(a)(2).)

Judge Bryant Y. Yang

CRITICAL

Parties and counsel are ordered to meet and confer in good faith to informally resolve discovery disputes before bringing them to the Court.

The Court expects the parties to resolve discovery disputes among themselves in a courteous, reasonable, and professional manner. 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.

Judge Bryant Y. Yang

CRITICAL

Regularly noticed motions are heard Mondays at 1:30 p.m., and a hearing date must be reserved with the calendar clerk before the motion is filed.

Regularly noticed motions (e.g. discovery motions, motions for summary judgment, motions for attorney's fees) are heard on Mondays at 1:30 p.m. Hearing dates must be reserved before filing the motion.

Judge Cherisse Heidi A. Cleofe

CRITICALCivil cases

Before filing any discovery motion (other than a motion to compel initial responses to party discovery), counsel must first meet and confer verbally, and the court may instruct counsel to meet face-to-face if the verbal meet and confer is not productive.

Should any party wish to file any discovery motion, other than a motion to compel initial responses to party discovery, at any time during the pendency of their case, counsel must first meet and confer verbally (i.e. by telephone, video conference, or in person). If counsel’s conversations are not productive, the court may, in any given case, instruct counsel to meet face-to-face (i.e. by video conference or in person).

Judge Cherol J. Nellon

CRITICALCivil cases

Discovery motions (except motions to compel initial responses) require verbal meet and confer, then IDC if unsuccessful; joint IDC statement (max 7 pages) filed 10 calendar days before hearing.

Should any party wish to file any discovery motion, other than a motion to compel initial responses to party discovery, at any time during the pendency of their case, counsel must first meet and confer verbally (i.e. by telephone, video conference, or in person). If counsel’s conversations are not productive, the court may, in any given case, instruct counsel to meet face-to-face (i.e. by video conference or in person). If the meeting and conference is unsuccessful, counsel must then schedule an Informal Discovery Conference (IDC) by calling the Courtroom Assistant at the phone number given above. If counsel file their motion without first attending an IDC, the motion may be continued to permit an IDC, or it may be taken off-calendar altogether. The court requires counsel to meet and confer and file a joint statement of the issues to be discussed at the IDC. The joint statement should be filed 10 calendar days before the hearing. The joint statement and any attached exhibits should be no more than 7 pages long.

Judge Cherol J. Nellon

CRITICALCivil cases

Law and motion hearings begin at 8:30 a.m., and hearing dates must be reserved in advance through the Court's Reservation System (CRS).

Law and motion hearings are conducted beginning at 8:30 a.m. Hearing dates must be reserved through the Court’s Reservation System (CRS).

Judge Cherol J. Nellon

CRITICALCivil cases

If the meet and confer is unsuccessful, counsel must schedule an Informal Discovery Conference (IDC) before filing the motion, and a motion filed without first attending an IDC may be continued or taken off-calendar altogether.

If the meeting and conference is unsuccessful, counsel must then schedule an Informal Discovery Conference (IDC) by calling the Courtroom Assistant at the phone number given above. If counsel file their motion without first attending an IDC, the motion may be continued to permit an IDC, or it may be taken off-calendar altogether.

Judge Cherol J. Nellon

CRITICAL

Parties and counsel are ordered to meet and confer in good faith to informally resolve discovery disputes before involving the Court.

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.

Judge Christian R. Gullon

CRITICAL

If the Parties are unable to settle their discovery disputes, pursuant to Code of Civil Procedure section 128(a)(3), the Court requests that they schedule an Informal Discovery Conference (“IDC”) prior to filing a discovery motion.

If the Parties are unable to settle their discovery disputes, pursuant to Code of Civil Procedure section 128(a)(3), the Court requests that they schedule an Informal Discovery Conference (“IDC”) prior to filing a discovery motion.

Judge Christian R. Gullon

CRITICAL

All motions except motions in limine must be reserved through the Court's online Court Reservation System (CRS), with motions heard Tuesday through Friday at 8:30 a.m.

All motions to be heard in Department 734, other than motions in limine, must be reserved through the Court Reservation System. Follow the links Online Services - Court Reservation System (CRS) on the Court's website. CRS must also be used to continue or cancel motions. Motions are heard Tuesday-Friday and are set for hearing at 8:30 a.m. The Court strongly encourages parties to appear remotely via LA Court Connect.

Judge Christopher K. Lui

CRITICAL

Self-represented parties and all trial counsel must meet and confer no later than 15 calendar days before the initial and any succeeding Case Management Conference to address the CRC 3.724 and 3.727 issues.

Self-represented parties and all trial counsel are required to meet and confer by videoconference, telephone or in person no later than 15 calendar days before the date set for the initial and any succeeding Case Management Conference to consider each of the issues identified in California Rules of Court, rules 3.724 and 3.727.

Judge Cindy Panuco

CRITICAL

Before filing any discovery motion, counsel with authority to compromise the dispute (preferably trial counsel) must meet and confer by telephone, videoconference, or in person; exchanging letters or emails alone is insufficient.

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. Before filing a discovery motion, counsel with authority to compromise the dispute (preferably trial counsel) must meet and confer by telephone, videoconference, or in person to resolve or narrow the discovery dispute. Merely exchanging letters or emails is insufficient. The Court expects the parties to work together in good faith to resolve discovery issues.

Judge Cindy Panuco

CRITICAL

Counsel must meet and confer in person, by phone, or videoconference to resolve discovery disputes before filing a discovery motion.

Before filing a discovery motion, counsel with authority to compromise the dispute (preferably trial counsel) must meet and confer by telephone, videoconference, or in person to resolve or narrow the discovery dispute. Merely exchanging letters or emails is insufficient.

Judge Cindy Panuco

CRITICAL

Parties must meet and confer before filing any motion in limine, and motions in limine should be noticed to be heard at the final status conference.

Motions in Limine: Los Angeles Superior Court Local Rule, Rule 3.57 requires the parties to meet and confer before filing any motion in limine. The motions should be noticed to be heard at the final status conference, Los Angeles Superior Court Local Rule, Rule 3.25(f)(2).

Judge Cindy Panuco

CRITICALCivil cases

Before filing a motion to compel discovery, the parties must meet-and-confer in good faith in person, by telephone, or by videoconference.

In the event a party seeks to file a motion to compel discovery at any time during the pendency of this action, the parties are required to meet-and-confer in good faith in person, by telephone, or by videoconference.

Judge Daniel L. Alexander

CRITICALCivil cases

Moving parties must reserve a hearing date through the online Court Reservation System (CRS) before filing any motion, except motions in limine which are heard on the first day of trial.

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 at www.lacourt.org to find the civil Court Reservation System to reserve a hearing date before filing any motion, except for motions in limine, which are heard on the first day of trial (normally a Friday with jury selection to begin the following Monday).

Judge Daniel L. Alexander

CRITICALCivil cases

Hearing dates must be reserved via the online 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 at www.lacourt.org to find the civil Court Reservation System to reserve a hearing date before filing any motion, except for motions in limine, which are heard on the first day of trial (normally a Friday with jury selection to begin the following Monday).

Judge Daniel L. Alexander

CRITICALCivil cases

Parties must reserve motion hearing dates in advance using the Court Reservation System (CRS) online at www.lacourt.ca.gov.

Parties must reserve hearing dates for motions using the Court Reservation System (CRS) available online (www.lacourt.ca.gov).

Judge Daniel M. Crowley

CRITICAL

Parties must reserve motion dates via CRS before filing any motion papers.

As of January 4, 2016, 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 Superior Court of Los Angeles County Webpage to reserve a date prior to filing any motion papers.

Judge Daniel S. Murphy

CRITICAL

Counsel must exhaust meet and confer efforts before filing any discovery motion, and the court will conduct an in-person informal discovery conference if the parties agree.

The Court requires all counsel to exhaust meet and confer efforts before filing a discovery motion. If the parties agree, the Court will help counsel resolve discovery disputes through an in person informal discovery conference.

Judge Daniel S. Murphy

CRITICAL

Meet and confer required before filing discovery motions.

The Court requires all counsel to exhaust meet and confer efforts before filing a discovery motion.

Judge Daniel S. Murphy

CRITICAL

Parties must reserve a motion hearing date through the online Court Reservation System (CRS) before filing any motion papers.

As of January 4, 2016, 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 Superior Court of Los Angeles County Webpage to reserve a date prior to filing any motion papers.

Judge Daniel S. Murphy

CRITICAL

Parties must meet and confer before final status conference.

The parties must meet and confer and submit the following documents FIVE COURT DAYS BEFORE THE FINAL STATUS CONFERENCE.

Judge Daniel S. Murphy

CRITICAL

In-person appearance at the Final Status Conference is mandatory.

In-Person appearance at the FSC is mandatory.

Judge David B. Gelfound

CRITICAL

Parties must meet and confer in person or via phone before filing discovery motions; letters/emails are insufficient.

All parties to exhaust meet and confer efforts before filing discovery motions. “Meet and confer” in Department 49 means in person or via phone; A letter or email does not suffice.

Judge David B. Gelfound

CRITICAL

All motions in Department F49 must be reserved through the Court Reservation System (CRS).

All motions to be heard in Dept. F49 are to be reserved through the Court Reservation System (CRS).

Judge David B. Gelfound

CRITICAL

Parties must meet and confer before trial regarding objections to listed exhibits, and objections not raised in the meet and confer are waived absent good cause.

Any party objecting to any listed exhibit, whether as to foundation or admissibility, must first meet and confer prior to trial. Any objections not so discussed in the meet and confer shall be deemed waived except upon a showing of good cause.

Judge David B. Gelfound

CRITICAL

Parties must meet and confer or exchange information at least 15 court days before the Final Status Conference.

All parties shall meet and confer and/or exchange information at least fifteen (15) court days before the FSC as required by this order and Los Angeles County Court Rules, Rule 3.25(g).

Judge David B. Gelfound

CRITICAL

Parties must exhaust meet and confer efforts in person or by phone (letters and emails do not suffice) before filing discovery motions.

All parties to exhaust meet and confer efforts before filing discovery motions. "Meet and confer" in Department 49 means in person or via phone; A letter or email does not suffice.

Judge David B. Gelfound

CRITICAL

Parties must meet and confer on all motions in limine before filing.

All parties must meet and confer on all motions in limine prior to filing said motions.

Judge David B. Gelfound

CRITICAL

All motions to be heard in Dept. F49 must be reserved in advance through the Court Reservation System (CRS).

All motions to be heard in Dept. F49 are to be reserved through the Court Reservation System (CRS). Follow the links on the court's website: Online Services-Court Reservation System (CRS).

Judge David B. Gelfound

CRITICAL

All parties must meet and confer on motions in limine before filing them, and failure to exchange or discuss a motion may result in the Court refusing to hear it.

All parties must meet and confer on all motions in limine prior to filing said motions. Failure by any party or counsel to exchange or discuss any motion in limine may result in the refusal by the Court to hear any such motion in limine, pursuant to applicable court rules. Boilerplate or form motions in limine are disfavored. See “Motions in Limine Best Practices.”

Judge David B. Gelfound

CRITICALCivil cases

Lead counsel or other designated counsel with full authority must appear at any scheduled IDC, and IDC sessions are informal and may not be transcribed without prior Court approval.

Fourth, lead counsel (or other designated counsel for the parties with full authority) are ordered to appear for any scheduled IDC as directed by the Court. IDC sessions are informal and shall not be transcribed without prior Court approval.

Judge David W. Swift

CRITICALCivil cases

Before any Motion to Compel Further Responses can be set for hearing, all parties must participate in an Informal Discovery Conference, which the moving party schedules by obtaining three available Monday or Friday dates at 10:00 a.m., contacting the Court, and giving notice.

The Court has the power to "amend and control its process and orders so as to make them conform to law and justice" pursuant to CCP § 128(a)(8), and therefore, the Court issues the following standing order requiring all parties to participate in an IDC to resolve any Motion to Compel Furthers. First, prior to any Motion to Compel Further Responses being set for hearing by the Court, the moving party shall confer with opposing counsel and obtain three available dates on either a Monday or a Friday for an IDC at 10:00 a.m. and then contact the Court to schedule the IDC. Moving party shall also give notice.

Judge David W. Swift

CRITICALCivil cases

Counsel must meet and confer by telephone or video conference before the IDC to attempt to resolve all pending discovery disputes, in addition to the statutory meet and confer requirements, and should track when and how long they met.

Second, prior to the IDC, counsel must meet and confer, via telephone or video conference, in an effort to resolve all pending discovery disputes. Counsel are advised to keep track of when and for how long counsel met and conferred. This meet and confer is in addition to the standard meet and confer requirements set forth in the Code.

Judge David W. Swift