Los Angeles Superior Court Pre-Motion Conference Requirements

WARNING

Before filing a discovery motion on an unresolved dispute, the parties are requested to schedule an Informal Discovery Conference (heard Mondays and Wednesdays at 10:00 a.m.) by filing a Form LACIV-094 request describing the discovery at issue, the legal authorities, and any applicable statutory deadlines.

If the dispute remains unresolved, and the deadline to file a motion to compel has not lapsed, the Court requests that the parties schedule an Informal Discovery Conference (“IDC”) prior to filing any discovery motion. The Court hears such conferences Mondays and Wednesdays starting 10:00 a.m., unless it is in trial at which point the Court will reschedule the conference. The parties can reserve IDCs on the Court Reservation System and are instructed to file their Request for an IDC using Form LACIV-094. The IDC Request Form should include information about the discovery at issue, and list the legal authorities relied upon by parties to compel or resist discovery. When filing a request, please indicate whether any statutory deadlines apply and the specific date by which a motion must be filed.

WARNING

Parties must meet and confer in good faith before filing a discovery motion, and either party may request an informal discovery conference before filing if both agree.

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. If the parties do not resolve their dispute by meeting and conferring but the parties mutually agree that an informal discovery conference might help, either party may request before filing a discovery motion that the court conduct an informal discovery conference to discuss the dispute.

WARNINGCivil cases

If the meet-and-confer does not resolve the discovery dispute, the parties are encouraged (but not required) to schedule an Informal Discovery Conference before filing a motion to compel.

If the parties cannot resolve the issue, they are encouraged to schedule an IDC before filing any motion to compel.

WARNINGCivil cases

Parties are urged (not required) to schedule an Informal Discovery Conference before filing motions to compel further discovery responses.

Parties seeking to compel further responses to discovery are urged to schedule an Informal Discovery Conference (IDC) before even filing their motions.

WARNINGCivil cases

Reservation requestors should immediately cancel the CRS reservation as soon as they realize the motion hearing or other reserved proceeding (such as an Informal Discovery Conference) will not be necessary.

As soon as a reservation requestor realizes that a motion hearing, or other proceeding requiring a reservation, such as in Informal Discovery Conference, will not be necessary, the reservation requestor should immediately use CRS to cancel the reservation for the motion hearing, or other proceeding requiring a reservation.

WARNING

The Court strongly discourages discovery motions, and parties should meet and confer in person, by phone, or by videoconference to resolve or narrow the dispute before filing one.

2. 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, the parties should meet and confer in person, by phone or by videoconference to resolve or at least narrow the dispute.

WARNING

Parties should meet and confer before filing discovery motions; discovery motions are strongly discouraged.

2. 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, the parties should meet and confer in person, by phone or by videoconference to resolve or at least narrow the dispute.

WARNING

The court strongly recommends (but does not require) an informal discovery conference before or after filing discovery motions.

The court strongly recommends having an informal discovery conference prior to, or after, filing of discovery motions.

WARNING

The court strongly encourages an informal discovery conference before filing a motion to compel; contact the court to schedule one (typically Mondays at 1:30, in person or by LACourtConnect).

The court strongly encourages parties to engage in an informal discovery conference prior to filing a motion to compel. In many instances such a conference may efficiently obviate a discovery motion (or at least narrow the issues). Contact the court to schedule an informal discovery conference, which may be attended in person or by LACourtConnect. Informal discovery conferences are typically held on Mondays at 1:30.

WARNING

The Court prefers no more than five motions in limine per party; parties should meet and confer before filing, and if proposed MILs exceed five per party without stipulation, the Court encourages an informal conference with Judge Boxer at least 30 days before the FSC.

The Court prefers each party file no more than five (5) motions in limine. Parties should meet and confer prior to filing motions in limine to reach stipulations as to evidence and other issues. If the parties cannot reach a stipulation to settle the dispute, and the remaining proposed motions in limine exceed five per party, the Court encourages the parties to schedule an informal conference with Judge Boxer to discuss the issues at least 30 days before the FSC.

WARNING

Absent good cause, the Court will conduct the Informal Discovery Conference before hearing the discovery motion.

Absent a showing of good cause, the Court will conduct the IDC before hearing the motion.

WARNINGCivil cases

A defendant seeking redacted records must first meet and confer in good faith with plaintiff and, if unresolved, the parties must comply with the General Order's Informal Discovery Conference procedure.

Should a defendant wish to obtain the subject redacted records, defendant shall contact plaintiff to meet and confer in good faith, to resolve the related issues. If parties are unable to resolve the issues and defendant still desires to obtain the subject records, the parties shall comply with the provisions of the General Order regarding an Informal Discovery Conference.

WARNING

soon as practicable prior to the hearing on a motion if the matter has settled, or the motion is withdrawn or unopposed. If a moving party takes a motion off the Court's calendar, the moving party should notify the court immediately and should remove the item from the Court's calendar on CRS. (Cal. Rules of Court, rule 3.1304(b).)

soon as practicable prior to the hearing on a motion if the matter has settled, or the motion is withdrawn or unopposed. If a moving party takes a motion off the Court's calendar, the moving party should notify the court immediately and should remove the item from the Court's calendar on CRS. (Cal. Rules of Court, rule 3.1304(b).)

WARNING

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.

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.

WARNING

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

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

WARNINGCivil cases

The trial attorneys should meet and confer before generating unnecessary motions in limine.

The trial attorneys should meet and confer before generating unnecessary motions in limine.

WARNINGCivil cases

The Court does not hold informal discovery conferences, so parties should not expect a pre-motion conference for discovery disputes.

The Court does not conduct informal discovery conferences (IDC).

WARNING

The court will factor a party's failure to request an IDC or to stipulate to extend the motion filing deadline into its sanctions analysis on a motion to compel.

The court will consider a party's failure to request an IDC and/or failure to stipulate to extend the time for filing of a motion to compel so that an IDC may be held when contemplating appropriate sanctions on the motion.

WARNINGCivil cases

IDCs are set at 1:30 PM or 3:00 PM if the Court is not in trial, and counsel must appear in person unless their office is over 40 miles from the Pasadena courthouse.

The Court sets IDCs at 1:30 PM or 3:00 PM, if the Court is not in trial. Counsel must appear in person for the IDC, unless counsel's office is over 40 miles from the Pasadena

WARNING

Counsel may request an Informal Discovery Conference (IDC) via form LACIV094 before moving on a discovery dispute, and absent good cause the Court may continue any discovery motion filed before the IDC process concludes.

If the dispute remains unresolved, counsel may request an Informal Discovery Conference (IDC) by filing an IDC request [LACIV094] See https://www.lacourt.org/forms/pdf/LACIV094.pdf. 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

Parties should plan ahead because reserving a hearing date for a summary judgment/adjudication motion can take up to 4 months.

Plan ahead. It may take up to 4 months to reserve a date for MSJ/MSAI.

WARNING

If applicable, counsel are to meet and confer on the number of "sides" for purposes of calculating peremptory challenges during jury selection to discuss at the FSC

If applicable, counsel are to meet and confer on the number of "sides" for purposes of calculating peremptory challenges during jury selection to discuss at the FSC

WARNING

Motions in limine may be heard at the Final Status Conference unless the Court orders otherwise (LR 3.25(f)).

Motions in limine may be heard at the Final Status Conference unless the Court orders otherwise. LR 3.25(f).

WARNINGCivil cases

Parties must resolve discovery disputes courteously and engage in meaningful meet and confer, which the Court will review for sufficiency.

The Court expects the parties to resolve discovery disputes among themselves in a courteous, reasonable, and professional manner. The Court emphasizes meaningful meet and confer and will carefully review the meet and confer declaration to determine its sufficiency.

WARNINGCivil cases

Failure to comply with CCP § 430.41 or an insufficient meet and confer may result in the demurrer being taken off calendar or the hearing continued.

Failure to comply with CCP § 430.41 or a determination by the Court that the meet and confer process was insufficient, may be grounds to take the demurrer off calendar or continue the hearing to allow for a meaningful meet and confer.

WARNINGCivil cases

Counsel with decision-making authority must attend the informal discovery conference.

Counsel with decision-making authority must attend the IDC.

WARNING

An informal discovery conference is strongly encouraged before filing a motion to compel further responses to written discovery, but is no longer required.

The court strongly encourages the parties to schedule an informal discovery conference ("IDC") before filing a motion to compel further responses to written discovery, but IDCs are no longer required.

WARNING

Parties should meet and confer before filing any motion and avoid filing motions designed to delay the proceedings or filed solely for tactical reasons.

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

WARNING

Before filing a discovery motion, trial counsel should meet and confer in person, by phone, or by videoconference to resolve or narrow the dispute; 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, by phone, or by videoconference to resolve, or at least narrow the dispute.

WARNING

If a discovery dispute remains unresolved, the moving party should request an Informal Discovery Conference via Form LACIV094 with three agreed dates; IDCs are held at 11 a.m., the Court may continue discovery motions filed before an IDC, and no IDC is needed before a motion to compel initial discovery.

If the dispute remains unresolved after good faith attempts at resolution, the moving party should request an IDC by using Form LACIV094 available at https://www.lacourt.org/forms/pdf/LACIV094.pdf. The Court conducts IDCs at 11 a.m. The request should include three possible dates agreed upon by the parties. If the request is granted, the clerk will schedule an IDC. The Court may continue any discovery motion filed before an IDC has been conducted. An IDC is not necessary before filing a motion to compel initial discovery.

WARNING

Parties should meet and confer, preferably through a conversation rather than an exchange of emails or letters, before filing any motion.

The parties should meet and confer—preferably, through a conversation, not simply an exchange of emails or letters—before filing any motion.

WARNING

Parties are strongly encouraged (but not required) to participate in an informal discovery conference before filing any motion to compel, motion to quash, or motion for a protective order.

Thus, the Court strongly encourages parties to participate in an informal discovery conference before filing any motion to compel further discovery responses (including a motion to compel, motion to quash, or motion for a protective order).

WARNING

Before the Final Status Conference, parties must meet and confer to resolve evidentiary issues and avoid filing unnecessary Motions in Limine (Local Rule 8.92(a)).

Prior to the Final Status Conference date, the parties are instructed to meet and confer to resolve evidentiary issues to avoid filing unnecessary Motions in Limine. Local Rule 8.92(a).

WARNINGCivil cases

If discovery issues remain unresolved after the informal conference, counsel may reserve the first available hearing date through CRS.

In the event discovery issues are not resolved, counsel may then reserve the first available hearing date on the Court’s Online Reservation System (CRS).

WARNINGCivil cases

Motions in limine will be heard on the first day of trial or later at the Court’s discretion.

Motions-in-limine will be heard on the first day of trial (or soon thereafter at the discretion of the Court).

WARNING

An informal discovery conference is encouraged but not required before filing a discovery motion.

The Court strongly encourages the parties to request an IDC if there is a discovery dispute, but there is no requirement to hold an IDC prior to filing a discovery motion.

WARNING

Routine MILs (e.g., to exclude speculative evidence, non-expert opinion, insurance/settlement evidence, or unproduced evidence) should generally not be drafted and should not survive meet and confer.

The following MILs usually should never be drafted or at least not survive meet and confer because counsel should not disagree: a) Exclude speculative evidence. b) Exclude expert opinion from non-experts. c) Confine experts to the area of their disclosure. d) Bar evidence of insurance coverage, prior settlements. e) Bar evidence not produced in discovery. f) Seeking bifurcation of punitive damages (it's automatic on request) or to exclude the finances of a party in the liability phase. g) Witnesses to be disclosed in advance. h) Exclude percipient witnesses from trial before they have testified.

WARNING

Before filing a post-trial motion, parties are asked to meet and confer, and if unresolved, the Court may hold a conference call with all counsel arranged through the courtroom clerk.

The parties are asked to meet and confer prior to filing a post- trial motion. If the parties are unable to resolve their dispute, The Court may be available for a conference call with ALL counsel to help informally resolve a dispute before a motion is filed. If you would like to set-up a conference call, please contact the Courtroom clerk at: 562-256-2237.

WARNING

Trial counsel should meet and confer before filing a discovery motion.

Before filing a discovery motion, trial counsel should meet and confer in person, by phone, or by videoconference to resolve, or at least narrow the dispute.

WARNING

Before filing a discovery motion, counsel should meet and confer by any means, and the Court will participate in an informal discovery conference (IDC) upon request of all counsel.

Before filing a discovery motion, trial counsel should meet and confer in person, by phone, or by videoconference to resolve, or at least narrow the dispute. The Court is amenable to participating in informal discovery conferences (IDC) upon request of all counsel.

WARNING

Motions in limine will be heard at the time of the Final Status Conference unless otherwise ordered.

Unless otherwise ordered, motions in limine will be heard at the time of the FSC. (See Local Rule 3.25(f)(2).)

WARNING

The court encourages counsel and self-represented parties to hold an informal discovery conference before filing a discovery motion.

To save the parties the time and expense of preparing a discovery motion and opposition papers, the court encourages the parties' counsel and any self-represented parties to schedule and conduct an informal discovery conference before a discovery motion is filed.

WARNING

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. Scheduling or participating in an IDC does not extend any deadlines for filing discovery motions. The parties are instructed to file their Request for an IDC using Form LACIV-094.

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. Scheduling or participating in an IDC does not extend any deadlines for filing discovery motions. The parties are instructed to file their Request for an IDC using Form LACIV-094.

WARNINGCivil cases

The court strongly recommends that parties discuss pleadings challenges informally and stipulate to amended pleadings before filing demurrers or motions challenging the pleadings.

Many pleadings challenges can be resolved informally before the expenditure of time and money to file demurrer or motion papers. The court recommends strongly that the parties take the time and make the effort to discuss these matters, and to stipulate to the filing of amended pleadings where feasible.

WARNINGCivil cases

The court strongly recommends (but does not require) that parties engage in the Informal Discovery Conference process before filing any discovery motion.

The court requests and recommends that parties engage in the IDC process before filing any discovery motion. This is a strong recommendation. However, the court does not require an IDC as a predicate to the filing of a discovery motion.

WARNING

Parties must meet and confer on all motions in limine before filing; failure may result in motion not being heard.

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.

WARNING

Demurrers must comply with CCP §430.41 meet-and-confer requirements or they 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.

WARNING

Parties must meet and confer by phone or in person before filing discovery motions; letters or emails do not satisfy the requirement.

Discovery Motions: Strongly discouraged. Parties must meet and confer by phone or in person before filing. Letters/emails do not satisfy the meet-and-confer requirement.

WARNING

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

Discovery Motions: Strongly discouraged. Parties must meet and confer by phone or in person before filing. Letters/emails do not satisfy the meet-and-confer requirement.

WARNINGCivil cases

Parties must comply with the Court's Informal Discovery Conference Order, available at www.lacourt.ca.gov, for motions to compel further discovery and informal discovery conferences.

the parties are ordered to comply with the Court's Informal Discovery Conference Order, which may be found at www.lacourt.ca.gov.