Los Angeles Superior Court Pre-Motion Conference Requirements

CRITICALCivil cases

Before filing the joint exhibit list, the parties must meet and confer about stipulations or objections for each exhibit.

Prior to filing the joint exhibit list, the parties shall meet & confer to determine whether they will stipulate to the authenticity and/or admissibility of each exhibit

CRITICALCivil cases

Before filing motions in limine, parties and counsel must comply with CCP section 1005 notice provisions and L.A. County Court Rule 3.57(a).

Before filing motions-in-limine, the parties/counsel shall comply with the statutory notice provisions of CCP Section 1005 and the motions-in-limine requirements of L.A. County Court Rule 3.57(a).

CRITICAL

Meet and confer efforts for motions in limine must consist of more than one email advising the opposing party of the nature of the motion.

Meet and confer efforts shall consist of more than one email advising the opposing party(ies) of the nature of the motion.

CRITICAL

All parties must first meet and confer in person, by videoconference, or by telephone to attempt to informally resolve discovery issues before pursuing discovery motions.

Per the Discovery Act, all parties shall first meet and confer, in person, by videoconference or by telephone, to attempt to informally resolve discovery issues.

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

If the parties cannot agree after meet and confer, they must schedule an Informal Discovery Conference with the Judicial Assistant or the Courtroom Assistant.

If the parties cannot agree, the parties shall schedule an Informal Discovery Conference with the Judicial Assistant or the Courtroom Assistant.

CRITICAL

Any party intending to file a motion for summary judgment or summary adjudication must immediately reserve a hearing date on the Court Reservation System, without waiting for discovery to be completed, because hearing dates may be unavailable at least 30 days before trial.

Any party who intends to file a motion for summary judgment or summary adjudication must reserve a hearing date immediately because the reservation dates for such motions are limited on the Court Reservation System, they fill up fast, and the present reservation dates available for such motions are very close to the trial dates being set by the Court. Do not wait until discovery has been completed to reserve a hearing date for a motion for summary judgment or summary adjudication because hearing dates might not be available at least 30 days before the trial date set in a case.

CRITICAL

Motion hearing dates must be reserved in advance via the Court Reservation System (CRS); motions are heard Monday through Thursday and tentative rulings are typically posted the afternoon before the hearing.

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 Thursday. The Court endeavors to post tentative rulings the afternoon before any hearing.

CRITICAL

Counsel and self-represented parties must meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit.

As set forth above, the parties' counsel and any self-represented parties shall meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit.

CRITICAL

Demurrers must comply with meet and confer requirements under CCP §430.41 or will be taken off calendar.

Demurrers filed without compliance with the meet and confer requirements will be taken off calendar.

CRITICAL

Parties objecting to listed exhibits must meet and confer before trial; objections not discussed are deemed waived except upon a showing of good cause.

Any party objecting to any listed exhibit, either 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.

CRITICAL

Parties must exhaust meet and confer efforts before filing discovery motions, and in Department 43 meet and confer must be in person or by 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 43 means in person or via phone. A letter or email does not suffice.

CRITICAL

All motions to be heard in Dept. F43 must be reserved in advance through the Court Reservation System (CRS) on the court's website.

All motions to be heard in Dept. F43 are to be reserved through the Court Reservation System (CRS).

CRITICAL

Demurrers require compliance with the CCP 430.41 meet and confer requirements, and non-compliant demurrers 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

Meet and confer before drafting MILs.

Meet and confer before drafting MILs.

CRITICAL

All parties must meet and confer on motions in limine before filing them; failure to do so may result in the Court refusing to hear the motion, and boilerplate or form motions in limine are disfavored.

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. Before a party files a motion in limine, the court expects counsel and self-represented parties to know the legal principles governing the appropriate and inappropriate use of such motions. (Kelley v. New West Federal Savings (1996) 49 Cal.App.4th 659, 670-671; Los Angeles County Court Rule 3.57; and attached Motions in Limine Best Practices.) Boilerplate or form motions in limine are disfavored.

CRITICAL

Discovery motions require exhausting meet and confer efforts in person or via phone before filing.

DISCOVERY MOTIONS: 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 43 means in person or via phone. A letter or email does not suffice.

CRITICAL

Parties must meet and confer in advance and then file proposed general or special verdict forms.

to meet and confer in advance, and then file proposed general or special verdict forms.

CRITICAL

Law and motion matters are heard Tuesdays and Thursdays at 9:00 a.m., and parties must reserve a hearing date in advance for all law and motion hearings via the Court Reservation System (CRS).

The Court hears law and motion matters on Tuesdays and Thursdays at 9:00 a.m. Parties must reserve a date for all law and motion hearings via the Court Reservation System (CRS).

CRITICAL

Trial counsel must meet and confer to resolve or narrow discovery disputes before seeking an Informal Discovery Conference (LACIV094), which should eliminate the need for a discovery motion.

Trial counsel must meet and confer by telephone or videoconference (or in person, when consistent with public health recommendations) to resolve or narrow the discovery dispute. If the dispute remains unresolved, counsel can request an Informal Discovery Conference by filing an IDC request [LACIV094].

CRITICAL

Parties must meet and confer before filing any motion in limine, as required by Los Angeles County Superior Court Rule 3.57.

Los Angeles County Superior Court Rule 3.57 requires the parties to meet and confer before filing any motion in limine.

CRITICALCivil cases

Counsel must meet and confer no later than 15 calendar days before each Case Management Conference to address the issues in CRC Rules 3.724 and 3.727.

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 CRC Rules 3.724 and 3.727.

CRITICALCivil cases

Trial counsel must meet by videoconference, telephone, or in person well before the FSC regarding joint trial readiness documents.

The Court requires trial counsel to meet by videoconference, telephone or in person well before the final status conference concerning the submission of joint trial readiness documents. LR 3.25 (g).

CRITICAL

do not file a written motion during trial unless you have first discussed it with opposing counsel. If Counsel is unable to resolve it, then advise court staff that you need a conference with the Court

do not file a written motion during trial unless you have first discussed it with opposing counsel. If Counsel is unable to resolve it, then advise court staff that you need a conference with the Court

CRITICAL

Hearing dates for regularly noticed motions must be reserved before filing by calling the calendar clerk during specified hours.

Hearing dates must be reserved before filing the motion by calling the calendar clerk at (213) 633-1091 between the hours of 8:30 A.M. to 12:00 P.M. and 1:30 P.M. to 3:30 P.M.

CRITICAL

All regularly noticed motions are heard Wednesday mornings at 8:30 A.M., and a hearing date must be reserved by phone with the calendar clerk before the motion is filed.

All regularly noticed motions (including motions to quash, demurrers, discovery motions, and motions for summary judgment) will be heard on Wednesday mornings at 8:30 A.M. Hearing dates must be reserved before filing the motion by calling the calendar clerk at (213) 633-1091 between the hours of 8:30 A.M. to 12:00 P.M. and 1:30 P.M. to 3:30 P.M.

CRITICAL

All parties must meet and confer before filing any motion in limine per Local Rule 3.57.

Local Rule 3.57 requires all parties to meet and confer before filing any motion in limine.

CRITICAL

All parties must meet and confer before filing any motion in limine, per Local Rule 3.57.

Local Rule 3.57 requires all parties to meet and confer before filing any motion in limine.

CRITICAL

In any case filed in this Department, 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 any discovery motion. The parties are instructed to file their Request for an IDC using Form LACIV-094.

In any case filed in this Department, 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 any discovery motion. The parties are instructed to file their Request for an IDC using Form LACIV-094.

CRITICAL

Parties must file a joint statement at least five calendar days before the IDC summarizing the dispute, the necessity for the discovery, any objections, and the overall discovery status, grouped by issue if possible.

At least five (5) calendar days before the IDC, the parties and counsel shall file a joint statement that succinctly summarizes the nature of the dispute, the necessity for the discovery, the basis for any objection or withholding of information, and the overall status of discovery. Please group the identified discovery by issue in dispute, if possible.

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).)

CRITICAL

In any case filed in this Department, 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 any discovery motion. The court hears such conferences Monday through Wednesday at 11:00 a.m. unless it is in trial at which point it will reschedule the conference.

In any case filed in this Department, 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 any discovery motion. The court hears such conferences Monday through Wednesday at 11:00 a.m. unless it is in trial at which point it will reschedule the conference.

CRITICAL

Not later than two days before the conclusion of evidence, the court will require counsel to meet and confer for the purpose of creating a final set of instructions.

Not later than two days before the conclusion of evidence, the court will require counsel to meet and confer for the purpose of creating a final set of instructions.

CRITICAL

Moving parties must reserve a hearing date through the online 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.

CRITICALCivil cases

All motion hearing dates in Department D must be reserved in advance through the Court Reservation System (CRS).

MOTIONS: All motion hearing dates must be reserved in advance using the Court Reservation System (CRS).

CRITICALCivil cases

Counsel and self-represented parties must meet and confer no later than 11 court days before the Final Status Conference to prepare trial documents and binders, attempt stipulations (exhibit authenticity/admissibility, motions in limine, ultimate facts and legal issues), and discuss settlement.

No later than 11 court 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.

CRITICALCivil cases

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

Counsel must comply with Local Rule 3.57 before filing any motions in limine.

Counsel shall comply with Local Rule 3.57 before filing any motions in limine.

CRITICAL

To advance a motion hearing date, a party must first actually reserve a hearing date via CRS and then proceed on an ex parte application to advance that date.

However, you must first actually reserve a hearing date, via CRS, and then proceed on an ex parte application to advance that date. (See Ex Partes, infra.)

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 and schedule a motion hearing date via the online Court Reservation System (CRS) on the Superior Court of Los Angeles County website. Go to "LA Court Online, Court Reservation System" at www.lacourt.ca.gov to reserve a date prior to filing any motion papers.

CRITICALCivil cases

Demurrers, motions to strike, and motions for judgment on the pleadings require a mandatory meet and confer with opposing counsel before filing.

MEET & CONFER REQUIREMENT FOR DEMURRERS, MOTIONS TO STRIKE AND MOTIONS FOR JUDGMENT ON THE PLEADINGS. Before filing any of these motions to challenge a complaint, the counsel for the moving party must meet and confer “in person or by telephone” with opposing counsel to discuss “whether an agreement can be reached that would resolve the objections to be raised by the demurrer.” CCP §§ 430.41, 435.5 and 439. This is a mandatory requirement.

CRITICALCivil cases

Before filing a demurrer, motion to strike, or motion for judgment on the pleadings, moving counsel must meet and confer in person or by telephone with opposing counsel — a mandatory requirement under CCP §§ 430.41, 435.5 and 439.

MEET & CONFER REQUIREMENT FOR DEMURRERS, MOTIONS TO STRIKE AND MOTIONS FOR JUDGMENT ON THE PLEADINGS. Before filing any of these motions to challenge a complaint, the counsel for the moving party must meet and confer “in person or by telephone” with opposing counsel to discuss “whether an agreement can be reached that would resolve the objections to be raised by the demurrer.” CCP §§ 430.41, 435.5 and 439. This is a mandatory requirement. It is not to be evaded.

CRITICALCivil cases

The IDC brief must be filed separately or jointly at least five (5) court days before the IDC, and failure to file it will result in the IDC being taken off calendar.

At least five (5) court days before the IDC, the parties MUST separately or jointly file a brief of no more than three (3) pages setting forth the issues in dispute and their respective positions. Failure to file the required IDC brief will result in the IDC being taken off calendar.

CRITICALCivil cases

A hearing must be reserved through the court reservation system for every motion.

A hearing must be reserved for any motion through the court reservation system.

CRITICALCivil cases

Parties must conduct an independent meet and confer before filing any motion to compel discovery.

The parties are required to conduct an independent meet and confer prior to the filing of a motion to compel discovery.

CRITICAL

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. 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.

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. 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

Failure to exchange or discuss a motion in limine may result in the court refusing to hear the motion.

Any failure by any party or counsel to exchange or discuss any motion in limine may result in the refusal of the court to hear any such motion in limine pursuant to applicable court rules.

CRITICAL

An Informal Discovery Conference is required before filing any discovery motion and must be scheduled by the moving party through the Court Reservation System.

An Informal Discovery Conference is required prior to filing ANY discovery motion. Informal Discovery Conferences are held Monday-Thursday at 9:00 a.m. Moving party shall schedule an Informal Discovery Conference by making a reservation through the Court Reservation System.

CRITICAL

All motions in Department 318 must be reserved through the Court Reservation System; motions are heard Monday–Friday at 8:30 a.m. and no written tentative ruling is issued.

All motions to be heard in Department 318 are to be reserved through the Court Reservation System. Follow the links Online Services – Court Reservation System (CRS) on the court's website. Motions are heard Monday- Friday and are set for hearing at 8:30 a.m. The Court does not issue a written tentative ruling.

CRITICAL

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

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