Limits & Logistics
Document Limits
Courtesy Copies
Joint Trial Notebook
- By 12 Pm Wednesday Before Trial
Motion in Limine Binder
- At Monday Trial Call
Joint Exhibit List
Court-wide- 2 copies
Joint Witness List
Court-wide- 2 copies
Communication
Phone
Chambers
Phone
Court-widePage & Word Limits1 rule
Each side is limited to 5 motions in limine, each not exceeding 5 pages. Anything above these limits requires leave of court.
- Motion in limine
- Up to 5 pages per side
- Motions in limine
Document Format Requirements7 rules
Number every page of every exhibit.
Formatting
- •Number every page of every exhibit
Attach a numbered exhibit tag to the front of each original exhibit.
Make sure each page is numbered.
Formatting
- •Number each page of every exhibit
Please leave space for the court to add appropriate terms.
Notebooks should be 3” thick or less.
Be prepared to supply a Word version.
Coordinate motion numbering with opposing counsel. There should be only one Motion #1, one Motion #2, etc.
Document Filing Requirements12 rules
File a case management statement. (Cal. Rules of Court, rule 3.725.)
Please file a single document containing both the parties’ stipulation and the proposed order.
- Document
- Stipulation
Include
- •Proposed order
At Monday trial call □ Deliver the original, tagged exhibits to Dept. C24 (Local Rule 317-C)
Prepare joint trial documents: “Joint” means all sides agree. Each side does not get to make their own.
At Monday trial call □ Deliver all deposition transcripts to Dept. C24 and e-file a notice of lodging
Witness lists must have time commitments.
It must contain 12 things.
Exercise professional judgment before proposing special instructions. If you cannot agree to all instructions, file three sets of instructions: (1) agreed- upon, (2) plaintiff’s proposed, and (3) defendant’s proposed.
Proposals shall be legally correct and logical.
If there is no joint special verdict form, file a general verdict form.
If you are requesting a new date, please include as many proposed dates as possible to aid the court in managing its calendar.
Motions to exclude “any evidence” are often improper. Motions should identify the exhibit number or specific words of testimony to be excluded. (Kelly v. New West Federal Savings (1996) 49 Cal.App.4th 659, 670-671.)
Filing & Service rules
Electronic Filing Rules
A notice of lodging must be e-filed at Monday trial call.
At Monday trial call □ Deliver all deposition transcripts to Dept. C24 and e-file a notice of lodging
Civil cases
Page 2 | Pretrial Checklist
Parties must submit trial exhibits through the Electronic Evidence Portal.
Parties must submit trial exhibits through the Electronic Evidence Portal.
Civil cases
Page 2 | Electronic Evidence Portal
Joint trial documents and motions in limine must be e-filed by noon on the Wednesday before trial.
By 12 pm on the Wednesday before trial (Local Rule 317-B) □ E-file all joint trial documents and motions in limine.
Civil cases
Page 2 | Pretrial Checklist
Filing Timing and Cure Windows
File the motion before applying ex parte to advance its hearing date.
File your motion before applying ex parte to advance a motion hearing date.
Civil cases
Page 1 | Ex Parte
The ex parte application must be filed by noon on the court day before the hearing.
file the application by 12 pm the court day before the hearing.
Civil cases
Page 1 | Ex Parte
The filing deadline for joint trial documents and motions in limine is noon on the Wednesday before trial.
By 12 pm on the Wednesday before trial (Local Rule 317-B) □ E-file all joint trial documents and motions in limine.
Civil cases
Page 2 | Pretrial Checklist
The notice of lodging must be e-filed by Monday trial call.
At Monday trial call □ Deliver all deposition transcripts to Dept. C24 and e-file a notice of lodging
Civil cases
Page 2 | Pretrial Checklist
Jury instructions are due up front.
Jury instructions are due up front.
Civil cases
Page 3 | Jury Selection and Instructions
To expedite a ruling, parties are encouraged to stipulate to filing briefs early and submitting the matter on the papers.
To expedite a ruling, stipulate to file briefs early and submit on the papers.
Civil cases
Page 1 | Motions
Any opposition to an ex parte application should be filed as soon as possible.
File any opposition as soon as you can.
Civil cases
Page 1 | Ex Parte
Summary judgment motions may be reserved early and are exempt from the 24-hour filing rule.
MSJs can be reserved early and are exempt from the 24-hour filing rule.
Civil cases
Page 1 | Motions
Service and Proof of Service Rules
Notice to all parties must be given by 10 a.m. on the court day before the ex parte hearing.
Give notice to all parties by 10 am
Civil cases
Page 1 | Ex Parte
All exhibits must be exchanged at least 14 days before trial.
14 or more days before trial (Local Rule 317-A) □ Exchange all exhibits.
Civil cases
Page 2 | Pretrial Checklist
All motions in limine must be exchanged at least 14 days before trial.
14 or more days before trial (Local Rule 317-A) □ Exchange all motions in limine.
Civil cases
Page 2 | Pretrial Checklist
Courtesy Copy Requirements
The Motion in Limine binder must be delivered to Dept. C24 at Monday trial call.
At Monday trial call □ Deliver the Motion in Limine binder to Dept. C24 (Local Rule 317-C)
Civil cases
Page 2 | Pretrial Checklist
A Joint Trial Notebook must be delivered to Dept. C24 by noon on the Wednesday before trial.
By 12 pm on the Wednesday before trial (Local Rule 317-B) □ Deliver a Joint Trial Notebook to Dept. C24.
Civil cases
Page 2 | Pretrial Checklist
Filing Bundling Requirements
The parties’ stipulation and proposed order must be filed together in a single document.
Please file a single document containing both the parties’ stipulation and the proposed order.
Civil cases
Page 1 | Stipulations
Pre-Motion Conference Requirements
Counsel must meet and confer before filing any motion in limine.
Meet and confer before filing any motion in limine.
Civil cases
Page 3 | Motions in Limine
Adjournment & Extension Requirements
Trial dates are firm, and continuances are disfavored.
Trial dates are firm, and continuances are disfavored.
Civil cases
Page 2 | DEPT. C24 PRETRIAL ORDER
Chambers Communication Rules
Call the department by 10 a.m. on the court day before the requested ex parte date to reserve it.
Call the dept. by 10 am the court day before you would like your ex parte to be set to make a reservation.
Civil cases
Page 1 | Ex Parte
Call all parties about the tentative ruling; call the clerk if everyone submits to it.
Call all parties. If everyone submits to the tentative ruling, call the clerk.
Civil cases
Page 1 | Motions
Raise issues as soon as possible to avoid surprising the court.
Avoid surprising the court. Raise issues as soon as possible.
Civil cases
Page 3 | Courtroom Expectations
Sidebars are rarely granted; raise issues before trial or wait until a break.
Sidebars are rarely granted. Raise issues before trial or wait until a break.
Civil cases
Page 3 | Courtroom Expectations
Junior Lawyer Participation Incentives
Counsel should prepare junior attorneys to examine a witness or argue a motion.
Prepare junior attorneys to examine a witness or argue a motion.
Civil cases
Page 3 | Courtroom Expectations