Los Angeles Superior Court Pre-Motion Conference Requirements

CRITICAL

Moving parties must reserve a hearing date through the online Civil Court Reservation System at www.lacourt.org 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 SCLAC 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.

CRITICAL

The Court generally will not hear discovery motions until an IDC is conducted, and motions filed before an IDC will be continued absent good cause.

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 the date of or after the IDC, which the parties should schedule as soon as possible after the dispute emerges.

CRITICAL

Counsel and self-represented parties must meet and confer in person or by videoconference and attempt resolution before filing any motion in limine.

The parties' counsel and any self-represented parties shall meet and confer in person or by videoconference to discuss the motion in limine prior to its filing and attempt to reach resolution of the issue.

CRITICAL

Before filing any discovery motion, including motions to compel further responses, parties must first meet and confer in good faith in person, by telephone, or by videoconference pursuant to CCP § 2016.040.

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. Thus, should the parties wish to file a motion to compel further responses to discovery, or other discovery motions regarding depositions, subpoenas, protective orders, or otherwise, the parties must first meet and confer in good faith either in person or by telephone or videoconference.

CRITICAL

Motion hearing dates must be reserved via the Court Reservation System; oppositions and replies are due per statute.

Motions/Oppositions/Replies: Date reserved via the Court Reservation System / Oppositions and Replies per statute.

CRITICAL

Parties must reserve a motion date via the online 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 “LA Court Online, Court Reservation System,” at www.lacourt.org to reserve a date prior to filing any motion papers.

CRITICAL

Parties must meet and confer before filing any motion in limine per local rule.

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

CRITICAL

Parties must meet and confer before filing any motion in limine under LA 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.

CRITICAL

Demurrers must comply with CCP §430.41 meet-and-confer requirements; non-compliant demurrers will be taken off calendar.

Demurrers: Must comply with CCP §430.41 meet-and-confer requirements. Demurrers filed without proper meet and confer will be taken off calendar.

CRITICAL

All parties must meet and confer on all motions in limine before filing them, and failure to do so may result in the Court refusing to hear the motions.

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."

CRITICAL

Parties must meet and confer or exchange information 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).

CRITICAL

Absent a showing of good cause, the Court may continue any discovery motion filed before the IDC process is concluded.

Absent a showing of good cause, the Court may continue any discovery motion filed before the IDC process is concluded.

CRITICAL

Before discovery motions, trial counsel must meet and confer in person, by telephone, or by videoconference to resolve or narrow the dispute; merely exchanging letters or emails 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.

CRITICALCivil cases

Meet and confer per CRC 3.724 and 3.727 is required prior to each Case Management Conference.

Meet and confer per CRC 3.724 and 3.727 is required prior to each CMC.

CRITICAL

All parties must meet and confer in good faith to informally resolve discovery disputes before filing a discovery motion, and the court encourages informal resolution over motion practice.

The court encourages the parties’ counsel and self-represented litigants to informally resolve discovery disputes, instead of filing discovery motions. The court requires all parties to meet and confer in good faith to informally resolve all such disputes before filing a discovery motion.

CRITICAL

All 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

Parties must meet and confer in good faith to resolve discovery disputes before filing a discovery motion.

The court requires all parties to meet and confer in good faith to informally resolve all such disputes before filing a discovery motion.

CRITICALCivil cases

Parties must meet and confer in person before filing joint trial documents.

PARTIES MUST MEET AND CONFER "IN PERSON", AND THEN FILE THE JOINT TRIAL DOCUMENTS AT LEAST FIVE COURT DAYS BEFORE THE FINAL STATUS CONFERENCE.

CRITICALCivil cases

Before a Motion to Compel Furthers is set for hearing, the moving party must confer with opposing counsel, obtain three available IDC dates (Tuesday or Thursday at 10:00 a.m. or 2:00 p.m.), contact the Court to schedule the IDC, and give notice.

First, prior to any Motion to Compel Furthers being set for hearing by the Court, the moving party shall confer with opposing counsel and obtain three available dates on either a Tuesday or a Thursday for an IDC at either 10:00 a.m. or 2:00 p.m., and then contact the Court to schedule the IDC. Moving party shall also give notice.

CRITICALCivil cases

Motions to compel further require an informal discovery conference scheduled before the motion is set for hearing.

prior to any Motion to Compel Furthers being set for hearing by the Court, the moving party shall confer with opposing counsel and obtain three available dates on either a Tuesday or a Thursday for an IDC at either 10:00 a.m. or 2:00 p.m., and then contact the Court to schedule the IDC.

CRITICALCivil cases

Ex parte applications related to law and motion matters require prior motion reservation in the Court Reservation System.

If the Ex Parte pertains to a Law and Motion matter, the Motion must be reserved in the Court Reservation System (or E-Court) prior to the Ex Parte filing.

CRITICALCivil cases

A hearing date must be reserved through CRS for every motion; motions are heard Monday through Thursday at 8:30 a.m. and Friday at 9:00 a.m.

You must reserve a hearing date for any motion through CRS. The Court hears motions Monday through Thursday at 8:30 a.m., and on Friday at 9:00 a.m.

CRITICALCivil cases

All motions require a hearing date reserved through CRS; motions are heard Mon-Thu 8:30 a.m., Fri 9:00 a.m.

You must reserve a hearing date for any motion through CRS. The Court hears motions Monday through Thursday at 8:30 a.m., and on Friday at 9:00 a.m.

CRITICALCivil cases

Filed motions to compel further will not receive a hearing date until the informal discovery conference (IDC) process is completed.

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

CRITICALCivil cases

Counsel must meet and confer before filing the Joint Exhibit List to resolve foundation and admissibility objections, stipulating where feasible.

Counsel must meet and confer prior to filing of the Joint Exhibit List in an effort to resolve any objections as to the foundation and admissibility of exhibits, with stipulations as to foundation and admissibility where feasible.

CRITICALCivil cases

All parties are required to participate in an Informal Discovery Conference (IDC) before any Motion to Compel Furthers.

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.

CRITICALCivil cases

Lead counsel or other designated counsel with full authority must appear for any scheduled IDC as directed by the Court.

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.

CRITICALCivil cases

If discovery disputes are resolved before the IDC date, the Moving Party must notify the Court and take both the IDC and any underlying motions to compel further 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 Furthers off calendar as soon as possible.

CRITICALCivil cases

Counsel must meet and confer by telephone or video conference before the IDC 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.

CRITICALCivil cases

If an ex parte application pertains to a law and motion matter, the underlying motion must be reserved in the Court Reservation System (or E-Court) before the ex parte is filed.

If the Ex Parte pertains to a Law and Motion matter, the Motion must be reserved in the Court Reservation System (or E-Court) prior to the Ex Parte filing.

CRITICAL

All motion hearing dates must be reserved in advance via the Court Reservation System (CRS), and motions are heard Monday through Thursday at 8:30 a.m.

All motion hearing dates must be reserved in advance on the Court Reservation System at www.lacourt.ca.gov, under “Online Services,” “Court Reservation System (CRS).” Motions are set for hearing Monday through Thursday at 8:30 a.m. The court encourages reserving non-discovery motion dates as soon as possible.

CRITICAL

Counsel must meet and confer verbally (telephone, video conference, Teams, Zoom, or in person) before filing any discovery motion, except a motion to compel initial responses to party discovery.

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, Teams, Zoom, or in person).

CRITICAL

Parties intending to file a summary judgment or summary adjudication motion must reserve a hearing date immediately, because dates fill quickly and may not be available 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, at a later date, hearing dates might not be available at least 30 days before the trial date set in your case.

CRITICAL

The court expects and encourages the parties’ counsel and any self-represented parties to informally resolve discovery disputes, instead of using expensive and cumbersome discovery motions. 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 before filing a discovery motion.

The court expects and encourages the parties’ counsel and any self-represented parties to informally resolve discovery disputes, instead of using expensive and cumbersome discovery motions. 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 before filing a discovery motion.

CRITICALCivil cases

Parties wishing to bring any discovery motion, including a motion to compel, must complete the prescribed meet-and-confer process.

Pursuant to the Court’s power to “amend and control its process and orders so as to make them conform to law and justice” (CCP § 128(a)(8)), the Court orders that parties who wish to bring any discovery motion (including motions to compel) must participate in the meet and confer process outlined below.

CRITICALCivil cases

Counsel with full authority must first meet and confer in person, by telephone, or by videoconference; written messages without a phone call do not satisfy the requirement.

First, the counsel for the parties with full authority must meet and confer in person or via telephone or videoconference to comply with the code requirements to “meet and confer.” Sending letters, emails or text messages without a phone call does not comply with the code requirements.

CRITICALCivil cases

Before demurrers, motions to strike, and motions for judgment on the pleadings, the parties must meet and confer in person, by telephone, or by video conference—not by email, text, or letter—and file the required declaration.

The parties are reminded to “meet and confer” in person, via telephone or video conference (not via email, texts or letters) regarding demurrers, motions to strike and motions for judgment on the pleadings and to file the requisite declaration re same with the pleading motions.

CRITICALCivil cases

If the parties’ initial conference is unsuccessful, they must participate in an IDC with the Court, and lead or designated counsel with full authority must attend.

Second, if the in-person, telephone or video conference is not successful, then the parties must participate in another meet and confer with the Court in the form of what is referred to as an “informal discovery conference” or “IDC.” Lead or other designated counsel for the parties with full authority are ordered to participate in the IDC.

CRITICALCivil cases

If a discovery motion is filed before the IDC is completed, the moving party must promptly reserve an IDC after consulting opposing counsel and, if needed, continue the motion hearing until after the IDC.

If a motion has been filed (which the Court strongly discourages doing before an IDC has been completed), after consulting with opposing counsel regarding available dates, the moving party must make a prompt reservation for the IDC using the Court’s online reservation system and, if necessary, continue the hearing on the motion to a date after the IDC.

CRITICAL

Before scheduling an IDC, parties to a discovery dispute must confer person-to-person in real time by phone, videoconference, or in person.

Parties to a discovery dispute are therefore required to confer person-to-person in real time, either by phone, videoconference, or in person before scheduling an informal discovery conference.

CRITICAL

Trial counsel must hold a real-time meeting well before the final status conference regarding submission of joint trial readiness documents.

The Court requires a real-time meeting of trial counsel well before the final status conference concerning the submission of joint trial readiness documents. See LASC Rule 3.25 (g).

CRITICAL

The Court requires an informal discovery conference before a hearing on a pending motion to compel, and before filing a discovery motion if the parties agree.

The Court strongly encourages the resolution of discovery disputes without motion practice and requires informal discovery conferences before a hearing on a pending motion to compel or, if agreed to by the parties, before the filing of a discovery motion.

CRITICAL

Attorneys conducting the discovery conference must be familiar with the discovery at issue and have authority to make and accept proposals and stipulations.

The attorneys conducting the conference must be familiar with the discovery at issue and have the authority to make and accept proposals and appropriate stipulations to resolve the dispute.

CRITICAL

After a motion to compel is filed on an unresolved dispute, counsel must contact court staff to arrange a video IDC with Judge Traber before the hearing.

If the dispute remains unresolved and a motion to compel has been filed, counsel must contact the court staff to arrange an informal, video discovery conference (IDC) between counsel and Judge Traber before the hearing on the motion.

CRITICAL

Informal Discovery Conferences are not held in Department 506 (except rarely by special request), so motions to compel further discovery must be accompanied by a joint statement for discovery disputes per Exhibit A, along with a notice of motion and motion to schedule the hearing.

Informal Discovery Conferences (IDCs) are not conducted in Department 506 (except rarely by special request). You may file your motions to compel further discovery. However, the Court now requires the parties to also file a joint statement for discovery disputes (as outlined in Exhibit A) together with your motions. Please note that you still must file a notice of motion and motion to schedule your hearing date.

CRITICAL

Trial Counsel must meet and confer by telephone or video conference (or in person) to resolve or narrow discovery disputes before proceeding with a discovery motion.

Trial Counsel must meet and confer by telephone or video conference (or in person, when consistent with public health recommendations) to resolve or narrow further discovery disputes. If the disputes remain unresolved, Counsel may proceed with a motion.

CRITICAL

For motions to compel further responses, the moving party must meet and confer with opposing counsel, then reserve a hearing date and file a notice of motion and motion to secure the hearing date.

After meeting and conferring with opposing counsel, the moving party shall reserve a hearing date for the motion and file a notice of motion. A notice of motion and motion must be filed to secure a hearing date.

CRITICAL

Counsel and self-represented parties must meet and confer no later than 11 calendar days before the Final Status Conference to prepare required trial documents, attempt stipulations on exhibit authenticity/admissibility, motions in limine, and ultimate facts and legal issues, and attempt to settle the case.

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 3.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

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

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

CRITICAL

Parties must meet and confer before filing any motion in limine per LA 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.