Los Angeles Superior Court Pre-Motion Conference Requirements

CRITICALCivil cases

Filed motions to compel further responses will not receive a hearing date until the IDC process is completed.

The filed motions to compel further will not receive a hearing date until the IDC process is completed.

CRITICALCivil cases

Motions to Compel Further require an Informal Discovery Conference (IDC) with meet and confer, joint brief (max 5 pages) filed 3 court days prior, and lead counsel appearance.

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. Second, prior to the IDC, counsel must meet and confer, via telephone or video conference, in an effort to resolve all pending discovery disputes. Third, a joint brief – no more than five-pages in length that summarizes the discovery dispute(s) at issue – shall be filed and provided to the Court at least three court days prior to the hearing. 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.

CRITICAL

Counsel must reserve a hearing date through the court reservation system for any motion; motions are heard Monday through Friday at 8:30 a.m.

You must reserve a hearing date for any motion through the court reservation system. The court hears motions Monday through Friday at 8:30 am.

CRITICAL

Counsel and self-represented parties must meet and confer by videoconference, telephone, or in person at least 18 days before the Final Status Conference.

Counsel and self-represented parties are required to meet and confer by videoconference, telephone, or in person at least 18 days before the FSC. (See, Trial Preparation Order, below.)

CRITICAL

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

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.

CRITICAL

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

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.

CRITICAL

Required

Always

Parties' counsel and any self-represented parties must meet and confer no later than 11 calendar days before the Final Status Conference to prepare the required trial documents and binders and to make a good faith effort to stipulate.

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-D, 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

CRITICAL

Parties must first meet and confer on discovery issues and, if unresolved, schedule an Informal Discovery Conference with the Court Reservation System or Courtroom Assistant.

The parties are first to meet and confer to attempt to informally resolve all discovery issues. If the parties cannot agree, the parties are to schedule an Informal Discovery Conference with the Court Reservation System or the Courtroom Assistant.

CRITICAL

All motion hearing dates must be reserved in advance through the Court Reservation System (CRS) at www.lacourt.ca.gov, with motions heard Monday through Friday.

All motion hearing dates must be reserved in advance on the Court Reservation System at www.lacourt.ca.gov, under "Online Services," "Civil," "Court Reservation System (CRS)." Motions are set for hearing Monday through Friday.

CRITICAL

Informal Discovery Conference or court permission required before filing motions to compel discovery.

An IDC or permission from the court must occur prior to filing any motions to compel or compel further discovery responses.

CRITICAL

An Informal Discovery Conference or court permission is a prerequisite to filing any motion to compel or compel further discovery responses.

An IDC or permission from the court must occur prior to filing any motions to compel or compel further discovery responses.

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

Motion hearing dates must be reserved via the Court Reservation System (CRS) unless scheduled by the court.

Hearing dates must be reserved via the Court Reservation System (CRS), unless scheduled by the court.

CRITICAL

Parties must meet and confer on all Motions in Limine prior to filing.

The parties are to meet and confer on ALL MILs prior to filing.

CRITICAL

The parties are to schedule an IDC prior to filing discovery motions. If motions have been filed, an IDC will proceed before the motion will be heard.

The parties are to schedule an IDC prior to filing discovery motions. If motions have been filed, an IDC will proceed before the motion will be heard.

CRITICAL

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

The parties are to meet and confer on ALL MILs prior to filing.

CRITICAL

Parties must schedule an informal discovery conference before filing discovery motions, and any filed discovery motion will not be heard until an IDC is held.

The parties are to schedule an IDC prior to filing discovery motions. If motions have been filed, an IDC will proceed before the motion will be heard.

CRITICAL

Motion hearing dates must be reserved through the Court Reservation System (CRS) unless the court schedules them, and motions are heard daily at 8:30 a.m.

Hearing dates must be reserved via the Court Reservation System (CRS), unless scheduled by the court.

CRITICAL

For an Ex Parte Application to shorten time for hearing on a motion, the motion date should first be reserved on CRS before the ex parte hearing.

For an Ex Parte Application to shorten time for hearing on a motion, the motion date should first be reserved on CRS before the ex parte hearing.

CRITICAL

For an Ex Parte Application to shorten time for hearing on a motion, the motion date should first be reserved on CRS before the ex parte hearing. CRC Rule 3.1203.

For an Ex Parte Application to shorten time for hearing on a motion, the motion date should first be reserved on CRS before the ex parte hearing. CRC Rule 3.1203.

CRITICALCivil cases

A plaintiff may serve a motion for trial preference only after the Committee submits its recommendation or fails to report within 5 days, and the motion must comply with Code of Civil Procedure section 36.

After the Committee submits its recommendation to the court, or if the Committee fails to submit its report within five (5) days, plaintiff may serve a motion for trial preference that complies with the provisions of Code of Civil Procedure section 36.

CRITICALCivil cases

When multiple preference motions are filed, the parties must confer on their appropriateness and order of consideration, present recommendations to the Court, and unresolved disputes are decided by the Court.

If multiple preference motions are filed, then the parties shall confer regarding the appropriateness of multiple motions, as well as the order in which the motions for trial preference should be considered, and present their recommendations to the Court. Any unresolved disputes among the parties will be decided by the Court.

CRITICALCivil cases

Parties must meet and confer in good faith on any discovery dispute and, if unresolved, must request an Informal Discovery Conference before filing a motion on the dispute.

Before the filing of a motion concerning a discovery dispute, the parties are required to meet and confer, in good faith, to attempt to resolve the dispute. In the event the dispute cannot be resolved after a good faith meet and confer discussion, the parties must request an informal discovery conference (IDC).

CRITICALCivil cases

Before filing a motion in limine, parties must comply with LASC Local Rule 3.57's meet and confer requirement, which must be in real time (in person, by telephone, or video conference) — correspondence exchanges are insufficient — and must address possible stipulations on the limited purpose for admitting certain evidence.

Parties must adhere to the provisions of LASC Local Rule 3.57. including the ... the motion being filed. Such meet and confer must be in real time and in person, by telephone, or by video conference. Exchange of correspondence is not sufficient. Among the issues to be discussed in any meet and confer is whether a stipulation may be reached concerning the limited purpose for which certain evidence may be admitted.

CRITICALCivil cases

Parties seeking to join another party’s motion or opposition must meet and confer prior to filing a joinder.

Parties seeking to join another party’s motion or opposition must meet and confer prior to filing a joinder.

CRITICALCivil cases

Parties must meet and confer on a proposed Preference Case Trial Setting Order at least 5 court days before the hearing on any motion for a preferential trial date.

At least five (5) court days prior to hearing on any motion for a preferential trial date, the parties shall meet and confer on a proposed Preference Case Trial Setting Order (in the event the motion is granted).

CRITICALCivil cases

Plaintiff's counsel who has a good faith basis for asserting entitlement to a preferential trial setting in a case under Code of Civil Procedure §36 should provide written notice ("Preference Notice") to the Committee and the case defendants of the potential claim of preferential trial setting eligibility at least 10 days before a motion for preference is filed. At the time this Preference Notice is given, the submitting plaintiff's counsel shall also submit to the Committee and Defendants the information set forth below in section (c).

Plaintiff's counsel who has a good faith basis for asserting entitlement to a preferential trial setting in a case under Code of Civil Procedure §36 should provide written notice ("Preference Notice") to the Committee and the case defendants of the potential claim of preferential trial setting eligibility at least 10 days before a motion for preference is filed. At the time this Preference Notice is given, the submitting plaintiff's counsel shall also submit to the Committee and Defendants the information set forth below in section (c).

CRITICALCivil cases

In punitive damages cases, counsel must meet and confer before the final status conference to determine the documents/information needed to establish the defendant's financial condition, and any disagreement must be presented to the court at the Final Status Conference.

In cases in which plaintiff asserts a claim for punitive damages against a defendant, counsel for the parties shall meet and confer before the final status conference to determine the type of documents and/or other information reasonably necessary to establish the financial condition of the defendant, in the event the finder of fact returns a verdict in phase one of a bifurcated trial relative to fraud, oppression, and/or malice. Should the parties not be able to agree on the necessary documents/information, the parties shall present the issue to the court at the Final Status Conference.

CRITICALCivil cases

Counsel seeking preferential trial setting must submit specified information to the Committee, including bases for preference, supporting facts, discovery status, expert status, anticipated motions, claimed prejudice, and for CCP 36(a)/(d) motions the primary treating physician's identity and plaintiff's prognosis.

Plaintiff's counsel who seeks to present a case to the Court for preferential trial setting shall submit to the Committee the following information: • Bases for preference invoked (e.g., C.C.P. §36(a) age, §36(b) minor, §36(d) health); • Short statement of facts supporting Plaintiff's eligibility for preference; • Fact discovery status (party, non-party, third party medical records) and key gaps in discovery still required; • Expert status (names/fields, report timing, depositions anticipated); • Anticipated or outstanding dispositive, Sargon, or summary judgment motions; • Claimed prejudice from denial of preference; and • For preference motions based on C.C.P. §36(a) or (d): o Identity of plaintiff's primary treating physician, defined as the physician providing the primary care and treatment to Plaintiff ("Primary care physician"); o Plaintiff's prognosis, including expected progression, life expectancy, and risk of further deterioration;

CRITICAL

Parties must appear at the scheduled motion hearing even if all parties submitted to the tentative ruling, unless the court advises the tentative was adopted as the final order and no appearance is required.

Even where all parties submit to the court's tentative ruling, the parties are required to appear at the scheduled hearing unless the court advises that the tentative ruling has been adopted as the final order of the court and that no appearance is required.

CRITICAL

Counsel and any self-represented parties with full authority to stipulate must participate in the IDC, and the court normally makes no orders at the IDC unless the parties stipulate.

The court requires the parties' counsel and any self-represented parties, with full authority to enter into a stipulation to resolve the discovery disputes at issue, to participate in the IDC. Because an informal discovery conference is not a hearing on a motion, the court normally does not make any orders at the informal discovery conference unless the parties stipulate.

CRITICAL

The court may impose sanctions on a party who fails to take a motion off calendar.

The Court may sanction a party for failing to take a motion off calendar.

CRITICAL

Parties must meet and confer in good faith to resolve discovery disputes before filing discovery motions; declaration of attempt required.

The court first expects the parties' counsel and any self-represented parties to meet and confer to make a reasonable and good faith attempt to informally resolve each discovery issue in dispute, as required by statute. This requirement is strictly construed. A meet and confer declaration in support of a motion shall state facts showing a reasonable and good faith attempt at an informal resolution of each issue presented by the motion. (Code of Civ. Proc. §2016.040.)

CRITICAL

All motion hearing dates must be reserved in advance through the Court Reservation System (CRS) at www.lacourt.org.

All motion hearing dates must be reserved in advance on the Court Reservation System at www.lacourt.org, under "Online Services," "Civil," "Court Reservation System (CRS)."

CRITICAL

Absent good cause, parties must meet and confer in person or by videoconference to attempt to informally resolve each disputed item before requesting an IDC.

Absent a showing of good cause, the parties are required to meet and confer either in person or by videoconference in an attempt to informally resolve each item in dispute before requesting an IDC.

CRITICAL

Before filing a discovery motion, counsel and self-represented parties must meet and confer in a reasonable, good faith attempt to informally resolve each disputed discovery issue, and this requirement is strictly construed.

The court first expects the parties' counsel and any self-represented parties to meet and confer to make a reasonable and good faith attempt to informally resolve each discovery issue in dispute, as required by statute. This requirement is strictly construed.

CRITICAL

Discovery motions require pre-filing meet and confer; unresolved disputes require an informal video IDC with the court.

Before filing a discovery motion, trial counsel (meaning the lawyers who will try the case) should meet and confer in person, by phone, or by videoconference to resolve, or at least narrow the dispute. If the dispute remains unresolved, counsel must contact the court staff to arrange an informal, video discovery conference (IDC) between counsel and Judge Harmon unless the Discovery Act requires no meet and confer.

CRITICAL

Counsel considering filing 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 may be taken off calendar.

Counsel considering filing 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 may be taken off calendar.

CRITICAL

Law and motion hearings in Department 107 must be scheduled through the CRS system, and parties may not reserve more than one hearing date for the same motion.

The Court reservation system (CRS) is required for scheduling law and motion hearings in Department 107. 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

Motions in limine require pre-filing meet and confer, sworn declaration, and 16/9/5 court day briefing schedule.

Los Angeles County Superior Court Rule 3.57 requires the parties to meet and confer before filing any motion in limine. All motions in limine must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party and setting forth the opposing party’s position regarding the motion(s) and must be submitted with timely statutory notice (16 court days for motion, 9 court days for opposition, 5 court days for reply) so as to be heard at the final status conference.

CRITICAL

If a discovery dispute remains unresolved after meet and confer, counsel must contact court staff to arrange an informal video discovery conference (IDC) with Judge Harmon, unless the Discovery Act requires no meet and confer.

If the dispute remains unresolved, counsel must contact the court staff to arrange an informal, video discovery conference (IDC) between counsel and Judge Harmon unless the Discovery Act requires no meet and confer.

CRITICALCivil cases

A motion date must be reserved on CRS before bringing an Ex Parte Application to Shorten Time.

A motion date must be reserved on CRS prior to bringing an Ex Parte Application to Shorten Time.

CRITICALCivil cases

All motion hearing dates must be reserved through the Court Reservation System (CRS) except with leave of Court, and motions are heard on Fridays at 9:00 a.m.

All motion hearing dates must be reserved using the Court Reservation System (CRS) except with leave of Court. Follow the link- Online Services-Court Reservation System (CRS) on the Court's website. Motions are heard on Fridays at 9:00 a.m.

CRITICALCivil cases

Counsel must exhaust meet and confer efforts before filing any discovery motion.

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

CRITICAL

Motion hearing dates must be reserved in advance via the Court Reservation System (CRS) at www.lacourt.ca.gov, and motions are heard Monday through Friday.

All motion hearing dates must be reserved in advance on the Court Reservation System at www.lacourt.ca.gov, under "Online Services," "Civil," "Court Reservation System (CRS)." Motions are set for hearing Monday through Friday.

CRITICAL

Counsel and self-represented parties must meet and confer no later than 14 calendar days before the Final Status Conference to prepare trial documents and binders, attempt stipulations on exhibits, motions in limine, and facts and legal issues, and attempt to settle the case.

No later than 14 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 stipulate to ultimate facts and legal issues, and (5) discuss and make a good faith effort to settle the case.

CRITICAL

Counsel and self-represented parties with full authority to stipulate must participate in the informal discovery conference with the court.

The court requires the parties' counsel and any self-represented parties, with full authority to enter into a stipulation to resolve the discovery disputes at issue, to participate in the informal discovery conference with the court.

CRITICAL

Parties must meet and confer in good faith on each discovery dispute, and a detailed letter or email alone does not satisfy the requirement unless followed by a telephone call or in-person meeting (or a genuine attempt to arrange one).

The court first expects the parties' counsel and any self-represented parties to meet and confer to make a reasonable and good faith attempt to informally resolve each discovery issue in dispute. In general, a letter or email laying out in detail all of the concerns about the discovery in question will not satisfy this requirement, unless it is followed up by a telephone call or in person meeting or a genuine attempt to arrange for a telephone call or in person meeting.

CRITICALCivil cases

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

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

CRITICALCivil cases

Parties must reserve a motion date via the online CRS prior to filing any motion papers.

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