Los Angeles Superior Court Pre-Motion Conference Requirements

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

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

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

CRITICAL

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

You must reserve a hearing date for any motion through the court reservation system.

CRITICAL

With the exception of motions to compel initial discovery responses, any party/counsel seeking to file a motion relating to any other form of discovery should also call Department 410 to schedule an MCC, so that the Court can facilitate your meet and confer efforts.

With the exception of motions to compel initial discovery responses, any party/counsel seeking to file a motion relating to any other form of discovery should also call Department 410 to schedule an MCC, so that the Court can facilitate your meet and confer efforts.

CRITICAL

Other than a motion to compel initial discovery responses, the failure to engage in a MCC prior to the hearing may result in the Court finding that the meet and confer efforts required by Code to have been insufficient, resulting in a continuance of the hearing on the motions until a MCC is held.

Other than a motion to compel initial discovery responses, the failure to engage in a MCC prior to the hearing may result in the Court finding that the meet and confer efforts required by Code to have been insufficient, resulting in a continuance of the hearing on the motions until a MCC is held.

CRITICAL

Parties filing more than 10 motions in limine must contact Department 410 to schedule a Motions in Limine Conference before the filing deadline, and parties are strongly discouraged from filing more than 5 contested motions in limine.

Any party/counsel seeking to file in excess of 10 motions in limine shall contact Department 410 to schedule a Motions in Limine Conference before doing so. This conference must occur prior to the deadline for filing the motions. The parties/counsel are strongly discouraged from filing more than 5 contested motions in limine. The parties/counsel are strongly encouraged to stipulate to uncontested motions.

CRITICAL

With the exception of motions to compel initial discovery responses, any party/counsel seeking to file a motion relating to any other form of discovery should also call Department 410 to schedule an MCC, so that the Court can facilitate your meet and confer efforts. Prior to your call, please have at least 3 possible dates for the MCC that work for all counsel/self-represented parties.

With the exception of motions to compel initial discovery responses, any party/counsel seeking to file a motion relating to any other form of discovery should also call Department 410 to schedule an MCC, so that the Court can facilitate your meet and confer efforts. Prior to your call, please have at least 3 possible dates for the MCC that work for all counsel/self-represented parties.

CRITICAL

The Court expects and encourages counsel and any self-represented parties to informally resolve discovery disputes, instead of using expensive and cumbersome discovery motions. Thus, counsel and any self- represented parties shall meet and confer on the phone, by video, or in person, to make a reasonable and good faith attempt to informally resolve each discovery issue in dispute.

The Court expects and encourages counsel and any self-represented parties to informally resolve discovery disputes, instead of using expensive and cumbersome discovery motions. Thus, counsel and any self- represented parties shall meet and confer on the phone, by video, or in person, to make a reasonable and good faith attempt to informally resolve each discovery issue in dispute.

CRITICAL

Everyone attending the MCC must have full authority to enter into stipulations, and agreements will be reduced to an order or confirmed in writing.

At the MCC, all present at the MCC must have full authority to enter into stipulations about the pending dispute. If there is agreement from the parties/counsel to do so, the Court will reduce the stipulations into an order. Otherwise, the Court will request the parties/counsel to confirm any agreements made at the MCC in writing and to proceed accordingly.

CRITICAL

Omnibus discovery motions (multiple sets/types of discovery in one motion) prohibited without prior written leave.

The Court does not accept omnibus discovery motions without prior written leave of this Court. An omnibus discovery motion is a motion that seeks to compel responses to more than one set of discovery and/or more than one type of discovery in a single motion.

CRITICAL

Motions in limine may not seek dispositive relief that should be requested via summary judgment/adjudication or judgment on pleadings.

Motions in limine shall not be used to seek dispositive orders that should have been sought through a motion for summary judgment, summary adjudication or judgment on the pleadings.

CRITICAL

Parties filing more than 10 motions in limine must schedule a pre-filing conference with Department 410.

Any party/counsel seeking to file in excess of 10 motions in limine shall contact Department 410 to schedule a Motions in Limine Conference before doing so. This conference must occur prior to the deadline for filing the motions.

CRITICAL

Parties must meet and confer in good faith prior to filing motions in limine.

The parties/counsel MUST 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 evidentiary issues. A simple exchange of letters that identify the motions to be filed is not a good faith meet and confer. Failure to meet and confer in good faith may result in a summary denial of the motion.

CRITICAL

Parties must meet and confer in good faith before filing motions in limine, and failure to do so may result in summary denial of the motion.

The parties/counsel MUST 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 evidentiary issues. A simple exchange of letters that identify the motions to be filed is not a good faith meet and confer. Failure to meet and confer in good faith may result in a summary denial of the motion.

CRITICAL

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

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

Counsel for the parties must appear in person in court for the informal discovery conference.

The Court requires that counsel for the parties appear in person in court for the IDC.

CRITICAL

Counsel and self-represented parties must first meet and confer in a reasonable, good faith attempt to informally resolve each discovery dispute before pursuing discovery motions, and an exchange of position-taking emails alone is not ordinarily sufficient.

The Court expects the parties' counsel and any self-represented parties first to meet and confer to make a reasonable and good faith attempt to informally resolve each discovery issue in dispute. The mere exchange of position-taking emails would not ordinarily be enough to satisfy this expectation.

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

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

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)."

CRITICALCivil cases

An Informal Discovery Conference (IDC) is expected to occur before the hearing on any discovery-related motion.

The Court expects that an Informal Discovery Conference (IDC) will occur before the hearing on any motion relating to a discovery dispute.

CRITICALCivil cases

Trial counsel must meet in person or by telephone or video conference well before the FSC to address the submission of joint trial readiness documents.

The Court requires trial counsel to meet in person or by telephone or video conference well before the FSC concerning the submission of joint trial readiness documents. Local Rule 3.25(g).

CRITICALCivil cases

Parties must make good faith efforts to meet and confer in person, by telephone, or by video conference to resolve or narrow discovery disputes (CCP § 2016.040).

faith efforts to meet and confer in person, by telephone or by video conference, to resolve or narrow the discovery dispute. (See CCP § 2016.040.)

CRITICAL

Should the filing of a motion become necessary, the moving party must obtain and schedule a motion hearing date via the online Court Reservation System (CRS) on the Superior Court of Los Angeles County website. The parties may choose their own hearing dates, Monday through Friday at 9:30 a.m.

Should the filing of a motion become necessary, the moving party must obtain and schedule a motion hearing date via the online Court Reservation System (CRS) on the Superior Court of Los Angeles County website. The parties may choose their own hearing dates, Monday through Friday at 9:30 a.m.

CRITICAL

Parties must meet and confer before filing any motion and must avoid unnecessary, delaying, or purely tactical motions.

The parties shall meet and confer before filing any motion and avoid filing an unnecessary motion or one which is designed to delay the proceedings or solely for tactical reasons.

CRITICALCivil cases

Moving parties must reserve a hearing date through 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.ca.gov to reserve a hearing date prior to filing any motion, except for motions in limine, which are heard on the first day of trial which is normally a Friday (with jury selection to begin the following Monday).

CRITICALCivil cases

Motions in limine are to be set for hearing at the FSC, and should be filed to be heard on statutory notice, in accord with Code of Civil Procedure sections 1005(b) and 1013 and Local Rule 3.25(f)(2). While the Court typically will defer formal hearing on motions in limine on the first day of trial, the parties should be prepared at the FSC to discuss the content with the Court and efforts to resolve disputed motions in limine.

Motions in limine are to be set for hearing at the FSC, and should be filed to be heard on statutory notice, in accord with Code of Civil Procedure sections 1005(b) and 1013 and Local Rule 3.25(f)(2). While the Court typically will defer formal hearing on motions in limine on the first day of trial, the parties should be prepared at the FSC to discuss the content with the Court and efforts to resolve disputed motions in limine.

WARNINGCivil cases

If unable to resolve a discovery dispute, parties should schedule an Informal Discovery Conference (IDC) before filing any discovery motion.

If the parties are unable to resolve their discovery disputes, the Court requests that the parties schedule an Informal Discovery Conference (“IDC”) prior to filing any discovery motion.

WARNING

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

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

WARNING

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

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

WARNING

Parties must exhaust in-person or phone meet and confer efforts before filing discovery motions.

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 51 means in person or via phone. A letter or email does not suffice.

WARNING

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.

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.

WARNING

Counsel attending the CMC must know the case and be prepared to discuss all issues identified in CRC Rule 3.727.

Counsel attending the CMC must be knowledgeable about the case and be prepared to discuss all the issues set forth in CRC Rule 3.727.

WARNING

Before filing a discovery motion, trial counsel should meet and confer in person to resolve or narrow the dispute, as the court strongly discourages discovery motions.

The court strongly discourages discovery motions and encourages informal resolution of discovery disputes. The rules governing discovery are very clear, and virtually all disputes can be resolved through communication and good faith discussion. Before filing a discovery motion, trial counsel (meaning the lawyers who will try the case) should meet and confer in person to resolve or at least narrow the dispute.

WARNING

Parties should meet and confer before filing any motion and avoid unnecessary or tactical-delay motions.

The parties should meet and confer before filing any motion and avoid filing any unnecessary motion for one which is designed to delay the proceedings or filed solely for tactical reasons.

WARNING

Before filing a discovery motion, trial counsel (meaning the lawyers who will try the case) should meet and confer in person to resolve or at least narrow the dispute.

Before filing a discovery motion, trial counsel (meaning the lawyers who will try the case) should meet and confer in person to resolve or at least narrow the dispute.

WARNING

Parties must comply with the Court's Informal Discovery Conference Order in connection with discovery motions.

The parties are ordered to comply with the Court's Informal Discovery Conference Order, which is attached hereto.

WARNING

Failure to meet and confer on motions in limine may result in the Court refusing to hear the motion.

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

WARNING

If a discovery dispute remains unresolved after meet and confer, counsel may request an Informal Discovery Conference by filing form LACIV094, and the court may continue any discovery motion filed before the IDC process concludes absent good cause.

If the dispute remains unresolved, counsel can request an Informal Discovery Conference (IDC) by filing an IDC request [LACIV094]. The Court will review the request and issue an order granting or denying the request. If granted, the Courtroom Assistant (CA) 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.

WARNING

An informal discovery conference (IDC) is not required before filing a motion to compel further responses but is strongly encouraged, and the court strongly discourages discovery motions.

The court strongly discourages discovery motions and encourages informal resolution of discovery disputes. To this end, while the Court does not require an informal discovery conference (“IDC”) prior to the filing a motion to compel further responses, IDCs are strongly encouraged.

WARNING

Before scheduling an IDC, counsel with authority to compromise the dispute should meet and confer by telephone, videoconference, or in person and make a good faith attempt to resolve the dispute; if unresolved, moving counsel should contact the judicial assistant to schedule the IDC.

Prior to scheduling an IDC, counsel with authority to compromise the dispute should meet and confer by telephone, videoconference or in person and make a good faith attempt to resolve the discovery dispute without the assistance of the Court. If the dispute cannot be resolved, moving counsel should contact the judicial assistant to schedule an IDC.

WARNING

If the responding/objecting party declines to extend the motion-to-compel deadline, the moving party may file an ex parte application to set an IDC and/or calendar a hearing on the motion to compel.

If the responding/objecting party declines to extend the deadline to file a motion to compel, then the moving party may file an ex parte application to set an IDC and/or to calendar a hearing on the motion to compel.

WARNING

If discovery disputes cannot be informally resolved, the Court requests the parties schedule an Informal Discovery Conference (sentence continues beyond this excerpt).

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

WARNING

In jury trials, parties must meet and confer before the FSC regarding proposed additional court voir dire questions tailored to the case type.

The parties must meet and confer prior to the FSC regarding additional proposed questions for the Court to ask that are tailored to the type of case, without attempting to precondition prospective jury members to favor one side or the other.

WARNING

Parties must meet and confer before the FSC to agree on any stipulations of fact that may be read to the Jury.

The parties are to meet and confer before the FSC to agree on any stipulations of fact that may be read to the Jury.

WARNING

Parties must meet and confer before the FSC to resolve exhibit objections and attempt stipulations to authenticity, foundation, and/or admission, with the Court expecting most exhibits to be stipulated.

The parties are to meet and confer before the FSC to resolve objections and to attempt to stipulate to authenticity, foundation and/or admission of exhibits. The Court expects that most if not all exhibits will be stipulated to for admission, or at least as to authenticity and foundation. To the extent possible, the Court expects to resolve any final objections at the time of the FSC, to avoid protracted arguments.