Orange Superior Court Document Filing Requirements

Applies to

Statement of compliance

Must include

caption

Parties must e-file a fully executed Statement of Compliance (Form L-0081) and include a copy in the Trial Notebook.

The Parties must e-file a fully executed Statement of Compliance (Form L-0081) and a copy also should be included in the Trial Notebook.

Applies to

Joint exhibit list

Must include

caption

Joint exhibit list must be e-filed and included in the Trial Notebook and each exhibit binder.

The joint exhibit list must be e-filed and included in both the Court's Trial Notebook and each exhibit binder.

Applies to

Exhibits

Exhibits may not be published to the jury before being admitted and without court approval.

No exhibit shall be published to the jury prior to being admitted and without court approval.

Applies to

Video audio evidence

Video and audio tape evidence must be accompanied by a separately marked transcript or still picture representation.

Video tape or audio tape evidence may not be introduced unless accompanied by a separately marked audio transcript and/or “still picture” representation of what the proponent seeks to present as evidence. The parties are required to comply with CRC 2.1040.

Applies to

Proposed judgment

Proposed Judgment must include the exact wording of the verdict.

After the verdict is read and the jury discharged, the prevailing Party shall prepare a Proposed Judgment, which must include the exact wording of the verdict.

Applies to

Jury instructions compendium

Parties must provide a separately indexed joint compendium of jury instructions and verdict forms organized by agreement and proponent before trial.

Prior to the commencement of trial, the Parties shall also provide the Court with a separately indexed joint compendium identifying all agreed upon and contested instructions or verdict forms, with all instructions attached and organized by proponent and competing verdict forms appended collectively (e.g., attachment A consists of jointly requested instructions, attachment B consists of instructions requested by Plaintiff but disputed by Defendant, attachment C consists of instructions requested by Defendant but disputed by Plaintiff, attachment D consists of the Parties’ competing verdict forms).

Applies to

Statement of compliance

A signed Statement of Compliance (Form L0081) must be filed no later than the Wednesday before trial.

No later than the Wednesday prior to the commencement of trial file a signed Statement of Compliance (Form L0081)

Applies to

Trial binder

Must include

index

Two sets of joint 3-ring trial binders with detailed index must be brought to court on trial day; motions in limine, oppositions, and replies must be numbered on the face page.

Motions in Limine and all other Trial Documents (Jury Instructions, Exhibit List, etc.) - Two sets of joint 3 ring trial binders shall be brought to Courtroom on the day of Trial. (One for the Clerk and one for the Judge). Binders shall include a very detailed joint index setting forth which trial documents are included in the binder; and for Motions in Limine, the name of the motion, the identity of the moving party and the number of the motion. All Motions in Limine, Oppositions and Replies must be numbered on the face page of the motion.

Applies to

Ex parte application

Must include

proposed order

Ex parte application must include: declaration of notice, statement of irreparable harm, declaration based on personal knowledge, points and authorities, and a separate proposed order with a copy to conform.

Ex Parte application must be in writing and include the following: • A declaration of Notice of Ex Parte hearing. • A statement that irreparable harm the will occur if the relief requested is not granted. • A declaration based on personal knowledge. • A brief and concise Points and Authorities. • A Separate proposed Order and a copy to conform.

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include a proposed order.

Application (including the proposed order) and Opposition must be viewable in the Court's Public Website no later than 2:00 p.m, the day before the hearing.

Applies to

Verdict form

Verdict forms must not include attorney identity, address, or Doe defendants.

The verdict form must not contain the identity or address of any attorney, nor shall Doe defendants be listed thereon.

Applies to

Exhibit

Each original exhibit must have a green court exhibit tag attached.

Each exhibit must have a green court exhibit tag attached (This is for the original exhibits only).

Applies to

Pleading

Documents must be electronically signed before submission or they will be rejected.

Stipulations, pleadings, declarations, and other documents must be electronically signed before submission to the Court. Failure to comply will result in the document being rejected.

Applies to

All

All documents must be electronically signed before submission; non-compliance results in rejection.

Stipulations, pleadings, declarations, and other documents must be electronically signed before submission to the Court. Failure to comply will result in the document being rejected.

Applies to

Filing with ai generated content

Must include

ai disclosure

Generative AI may be used in filings, but the filer must personally verify the accuracy of AI-conducted research and bears ethical responsibility for all statements made.

Use of generative AI is not prohibited, but counsel or the self-represented party must personally confirm for themselves the accuracy of any research conducted by these means, and counsel or the self-represented party alone bears ethical responsibility for all statements made in filings.

Applies to

Filing with ai generated content

Must include

ai disclosure

Signing or being listed on a filing with AI-generated content certifies that the signer and all listed parties have personally verified the content's accuracy.

The signature or listing of counsel or a self-represented party on a filing containing AI-generated content, including citations generated by AI, constitutes a certification the signer (and any attorney or other self-represented party listed on the filing) has personally verified the content’s accuracy.

Applies to

Filing with ai generated content

Parties using generative AI or automated tools must fully comply with applicable protective orders and all ethical and legal obligations involving AI use, disclosure, and submission.

Counsel for a party, or a self-represented party, choosing to use generative AI or other automated tools shall fully comply with any applicable protective order and all applicable ethical/legal obligations in their use, disclosure to, submission to, or other interaction with any such AI tools.

Applies to

Ex parte application

Ex parte applications must include declaration showing irreparable harm, demonstrate notice, and state whether opposed.

All Parties must comply with CRC 3.1200 through 3.1207, including but not limited to making an 'affirmative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte.' CRC 3.1202 (c). Papers must also demonstrate appropriate notice and state whether the application will be opposed.

Applies to

Case management statement

A case management statement must be filed for case management conferences.

File a case management statement. (Cal. Rules of Court, rule 3.725.)

Applies to

Stipulation

Must include

proposed order

Stipulations must be filed as a single document containing the stipulation and proposed order, with space left for the court's terms.

Please file a single document containing both the parties’ stipulation and the proposed order. Please leave space for the court to add appropriate terms.

Applies to

Joint trial documents

Joint trial documents must be agreed upon by all sides, and witness lists must include time commitments.

Prepare joint trial documents: “Joint” means all sides agree. Each side does not get to make their own. Witness lists must have time commitments.

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include declarations of notice and irreparable harm, a memorandum of points and authorities, and a proposed order in Word format.

Ex parte applications must comply with CRC 3.1200 through 3.1207. Applications must be in writing and include all of the following: 1. A declaration setting forth details of the notice given to opposing counsel of the ex parte hearing and stating whether the application will be opposed; 2. A declaration, based on personal knowledge, describing the irreparable harm that will occur if the relief requested is not granted; 3. A concise memorandum of points and authorities in support of the application; and 4. A separate proposed order in Word format.

Applies to

Stipulation

Must include

electronic signature

Documents must be electronically signed by all parties before submission; non-compliance results in rejection.

Stipulations, pleadings, declarations, and other documents must be electronically signed by all parties before submission to the Court. Failure to comply will result in the document being rejected.

Applies to

All documents

All documents must be electronically signed before submission; non-compliance leads to rejection.

Stipulations, pleadings, declarations, and other documents must be electronically signed before submission to the Court. Failure to comply will result in the document being rejected.

Applies to

Ex parte motion

Must include

proposed order, certificate of service

Ex parte moving papers must include a declaration of notice, declaration based on personal knowledge, points and authorities, proposed order, and must state the irreparable harm.

Moving papers must include a declaration of notice of ex parte hearing, a declaration based on personal knowledge, points and authorities, and a proposed order. The application shall set forth the irreparable harm that will occur if the relief requested is not granted.

Applies to

Continuance request

Must include

proposed order

A proposed order must accompany any continuance request, stipulation, and supporting declaration.

A proposed order is to be submitted with the request, stipulation, and supporting declaration.

Applies to

Ex parte papers

Must include

proposed order

Ex parte papers must include a declaration of notice, declaration on personal knowledge, points and authorities, and a proposed order.

papers must include a declaration of notice of ex parte hearing, a declaration based on personal knowledge, points and authorities, and a proposed order in both PDF format and in editable word-processing format.

Applies to

Continuance request

Must include

proposed order

Continuance requests must include a supporting declaration showing good cause and a proposed order.

Even if a continuance is unopposed, counsel must submit a supporting declaration stating facts that constitute good cause for a continuance. A proposed order is to be submitted with the request, stipulation, and supporting declaration.

Applies to

Continuance stipulation

Stipulations for continuance must be signed by all appearing parties.

Said stipulations must be signed by ALL appearing parties.

Applies to

Joint compendium of instructions and verdict forms

Parties must provide a separately indexed joint compendium of agreed and contested jury instructions and verdict forms before trial.

Prior to the commencement of trial, the parties shall also provide the Court with a separately indexed joint compendium identifying all agreed upon and contested instructions or verdict forms, with all instructions attached and organized by proponent and competing verdict forms appended collectively (e.g., attachment A consists of jointly requested instructions, attachment B consists of instructions requested by Plaintiff but disputed by Defendant, attachment C consists of instructions requested by Defendant but disputed by Plaintiff, attachment D consists of the parties competing verdict forms).

Applies to

Motion in limine

Motions in limine must be in writing and specifically identify the evidence to be excluded.

Motions in limine must be in writing, comport with the purposes of such motions, and identify specifically the evidence to be excluded.

Applies to

Joint witness list

Parties must submit a joint witness list.

Parties are required to submit a joint witness list.

Applies to

Stipulation

Stipulations must be in writing.

Stipulations must be reduced to writing.

Applies to

Proposed jury instructions and verdict forms

Proposed jury instructions and verdict forms must be submitted in the Joint Trial Notebook.

All proposed jury instructions and verdict forms must be submitted to the clerk as part of the 'Joint Trial Notebook'.

Applies to

Ex parte application

Ex parte applications must include a concise memorandum of points and authorities in support of the relief requested.

A concise memorandum of points and authorities in support of the application; and

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include a separate proposed order in Word format.

A separate proposed order in Word format.

Applies to

Issue conference materials

Parties must conduct an Issue Conference under Local Rule 317 and prepare and file all required items.

The Parties must conduct an Issue Conference in compliance with Local Morality Rule 317 and produce and file all required items pursuant to that rule.

Applies to

Proposed judgment

Prevailing counsel must prepare a Proposed Judgment containing the exact wording of the verdict.

After the verdict is read and the jury discharged, Counsel for the prevailing party shall prepare a Proposed Judgment, which must include the exact wording of the verdict.

Applies to

Statement of compliance

The Statement of Compliance must be executed by all counsel and filed with the court clerk in the department of the judge assigned to the case for trial.

This Statement of Compliance shall be executed by all counsel and filed with the court clerk in the department of the judge to whom the case has been assigned for trial.

Applies to

Ex parte application

Must include

declaration

Ex parte applications must include a declaration showing irreparable harm, immediate danger, or other statutory basis.

Comply with all requirements for ex partes, including 'an affirmative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte.' (Cal. Rules of Court, rule 3.1202(c).)

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include a notice declaration, irreparable harm declaration, memorandum, and proposed order in Word format.

Ex parte applications must comply with CRC 3.1200 through 3.1207. Applications must be in writing and include all of the following: 1. A declaration setting forth details of the notice given to the opposing Party of the ex parte hearing and stating whether the application will be opposed; 2. A declaration, based on personal knowledge, describing the irreparable harm that will occur if the relief requested is not granted; 3. A concise memorandum of points and authorities in support of the application; and 4. A separate proposed order in Word format.

Applies to

Request for judicial notice

Requests for judicial notice must be in a separate document, attach copies, and specify legal basis.

All requests for judicial notice must be set forth in a separate document, must attach a copy of the document(s) of which notice is requested, and must specify (with appropriate legal citation) the legal basis on which judicial notice is sought.

Applies to

Separate statement

Summary judgment separate statements must comply with CRC 3.1350.

Separate statements must comply with CRC 3.1350.

Applies to

Declaration

Summary judgment declarations must be filed separately, not attached to the motion or memorandum.

Declarations filed in support of or in opposition to a motion for summary judgment and/or adjudication must be separately filed, i.e., not attached to or made part of the notice of motion and motion or the memorandum of points and authorities.

Applies to

Proposed judgment

Proposed Judgment must include the exact wording of the verdict.

After the verdict is read and the jury discharged, the prevailing Party shall prepare a Proposed Judgment, which must include the exact wording of the verdict.

Applies to

Letter

Must include

certificate of conference

IDC joint letter brief must include an attestation that parties previously met and conferred.

Parties must attest to having previously met and conferred in person, by phone, or by video conference.

Applies to

Joint exhibit list

Must include

caption

Joint exhibit list must have a caption page and a table with specific columns.

The joint exhibit list must include a caption page identifying it, and the list should be in a table format that includes the following columns: (1) "Exhibit Number," (2) "Description," (3) "Stipulation," (4) "Date Identified," and (5) "Date Admitted."

Applies to

Exhibits

Exhibits must be moved into evidence as soon as admissibility is established, not at the end of testimony or case.

Each exhibit should be moved into evidence as soon as admissibility has been established; DO NOT wait until the end of a witness's testimony or the end of a party's case to move exhibits into evidence.

Applies to

Joint exhibit list

Parties must attempt to stipulate to admissibility and foundation for all exhibits, with agreements reflected on the joint exhibit list.

The Parties are expected to have already attempted to stipulate to the admissibility and/or foundation for all exhibits with those agreements reflected on the joint exhibit list.

Applies to

Witness list

Joint witness list must include a caption page and be in table format with specified columns and time estimate totals.

Parties are required to submit a joint witness list. The joint witness list must include a caption page identifying it, and the list should be in a table format that includes the following columns: (1) a number for each witness, (2) “Witness,” (3) “Title and/or Role in Case,” (4) “Direct Examination Time Estimate,” (5) “Cross Examination Time Estimate,” and (6) “Total Time Estimate.” Each time estimate column should include a total time estimate at the bottom so the list provides a total of all direct examination time estimates, a total of all cross-examination time estimates, and a total of all time estimates.

Applies to

In limine motion

Each in limine motion must be numbered, with the number and party identity on the face page.

Each in limine motion shall be assigned a number, which must be set forth on the face page of the motion, along with the identity of the party bringing the motion

Applies to

Exhibits

Page numbers must be placed on each page of multiple-page exhibits that are not Bates-stamped before uploading to the Portal.

Before uploading exhibits to the Portal, if the document is not bate-stamped, page numbers shall be placed on each page of a multiple-page document.

Applies to

Exhibits

Exhibits on the Portal must be identified by numbers only, with no special characters, letters, or party designations.

Only numbers shall be used to identify an exhibit on the Portal. No special characters or letters shall be added to the exhibit number. Please do not designate exhibits as plaintiff's or defendant's exhibit.

Applies to

Verdict form

Verdict forms must not list Doe defendants or contain any attorney's identity or address.

Verdict forms shall not list Doe defendants or contain the identity or address of any attorney.

Applies to

Case management statement

Initial Case Management Conference Statement must discuss subjects set forth in CRC 3.727 and 3.750(b).

should include in the statement a discussion of the applicable subjects set forth in California Rules of Court 3.727 and 3.750(b).

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include declarations of notice and irreparable harm, a memorandum, and a proposed order in Word format.

Ex parte applications must comply with CRC 3.1200 through 3.1207. Applications must be in writing and include all of the following: 1. A declaration setting forth details of the notice given to opposing counsel of the ex parte hearing and stating whether the application will be opposed; 2. A declaration, based on personal knowledge, describing the irreparable harm that will occur if the relief requested is not granted; 3. A concise memorandum of points and authorities in support of the application; and 4. A separate proposed order in Word format.

Applies to

Msc statement

MSC statements must include email address of settlement counsel.

PLEASE INCLUDE E-MAIL ADDRESS OF SETTLEMENT COUNSEL ON THE MSC STATEMENT.

Applies to

Cmc statement

CMC statement must be timely filed per CRC 3.725(a).

Case Management Conferences – The court strictly enforces the timely filing of a CMC statement pursuant to CRC 3.725(a).

Applies to

Motion

Must include

proposed order, certificate of service

The moving party must give notice or prepare the order after a ruling, per CRC 3.1312.

The moving party shall give notice or prepare the order, if appropriate, per California Rule of Court 3.1312.

Applies to

Filing with ai generated content

Any errors caused by AI tools are imputed to the signer and every listed attorney or self-represented party on the filing.

The court will impute any errors by such AI tools to the signer and any other attorney or self-represented party listed on the filing.

Applies to

Filing with ai generated content

Failure to verify the accuracy of submissions, especially citations to law and evidence, may result in sanctions or State Bar disciplinary action.

Failure to verify the accuracy of submissions, particularly the accuracy of citations to law and evidence, may be grounds for sanctions or disciplinary action before the State Bar.

Applies to

Initial case management conference statement

CMC statement must discuss subjects in CRC 3.727 and 3.750(b).

should include in the statement a discussion of the applicable subjects set forth in California Rules of Court 3.727 and 3.750(b).

Applies to

Video audio evidence

Video or audio evidence must be accompanied by a transcript or still picture.

Video tape or audio tape evidence may not be introduced unless accompanied by a separately marked audio transcript and/or “still picture” representation of what the proponent seeks to present as evidence.

Applies to

Motion in limine

Must include

caption

Motions in limine must be numbered and have a caption identifying the subject and specific evidence.

Each motion in limine must be numbered on the face page of the motion. The caption (or notice) of each motion in limine shall concisely identify the subject of the motion and designate the specific evidence or argument sought to be excluded.

Applies to

Joint compendium

Parties must provide a joint compendium with an index, all instructions/verdict forms, and tabbed sections by the pretrial conference.

No later than the pretrial conference, the Parties shall also provide the Court with a separately indexed joint compendium in a notebook format containing an index or table identifying all agreed upon and contested instructions or verdict forms, with all instructions and verdict forms included and separately tabbed to indicate proponent/opponent (e.g., Tab 1 consists of jointly requested instructions, Tab 2 consists of instructions requested by Plaintiff but disputed by Defendant, Tab 3 consists of instructions requested by Defendant but disputed by Plaintiff, Tab 4 consists of the Parties’ competing verdict forms).

Applies to

Motion in limine

Motions in limine must identify the exhibit number or specific words of testimony to be excluded; blanket motions to exclude 'any evidence' are often improper.

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.)

Applies to

Motion

Parties must coordinate motion numbering with opposing counsel so there is only one Motion #1, one Motion #2, etc.

Coordinate motion numbering with opposing counsel. There should be only one Motion #1, one Motion #2, etc.

Applies to

Jury instructions

If the parties cannot agree on all jury instructions, they must file three sets: agreed-upon, plaintiff's proposed, and defendant's proposed.

If you cannot agree to all instructions, file three sets of instructions: (1) agreed-upon, (2) plaintiff’s proposed, and (3) defendant’s proposed.

Applies to

Special verdict form

Special verdict form proposals must be legally correct and logical.

Proposals shall be legally correct and logical.

Applies to

Special verdict form

If there is no joint special verdict form, counsel must file a general verdict form (CACI No. VF-5000, 5001).

If there is no joint special verdict form, file a general verdict form. (CACI No. VF-5000, 5001.)

Applies to

Case management statement

Initial Case Management Conference Statement must discuss subjects per CRC 3.727 and 3.750(b).

should include in the statement a discussion of the applicable subjects set forth in California Rules of Court 3.727 and 3.750(b).

Applies to

Ex parte application

Ex parte moving papers must demonstrate proper notice, state opposition, and counsel must make good faith efforts to confer with opposing counsel.

The moving papers must demonstrate with admissible evidence that the moving party gave proper notice and must state whether the other parties to the case will oppose the application. Counsel for the moving party must make good faith efforts to speak with opposing counsel to determine their position(s) on the ex parte application.

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include declaration of notice, declaration of irreparable harm, memorandum, and proposed order in Word format.

Applications must be in writing and include all of the following: 1. A declaration setting forth details of the notice given to opposing counsel of the ex parte hearing and stating whether the application will be opposed; 2. A declaration, based on personal knowledge, describing the irreparable harm that will occur if the relief requested is not granted; 3. A concise memorandum of points and authorities in support of the application; and 4. A separate proposed order in Word format.

Applies to

Request for judicial notice

Requests for judicial notice must be separate document, attach copy, and specify legal basis.

All requests for judicial notice must be set forth in a separate document, must attach a copy of the document(s) of which notice is requested, and must specify (with appropriate legal citation) the legal basis on which judicial notice is sought.

Applies to

Declaration

Declarations for summary judgment motions must be filed separately, not attached to motion or memorandum.

Declarations filed in support of or in opposition to a motion for summary judgment and/or adjudication must be separately filed, i.e., not attached to or made part of the notice of motion and motion or the memorandum of points and authorities.

Applies to

In limine motion

Each in limine motion must be numbered and include party identity and short description on the face page.

Each in limine motion shall be assigned a number, which must be set forth on the face page of the motion, along with the identity of the party bringing the motion and a short description of the motion (e.g., “Plaintiff’s Motion In Limine No. 1 to Exclude Reference to Plaintiff’s 2013 Theft Conviction”).

Applies to

Verdict form

Verdict forms must not list Doe defendants or contain attorney identity or address.

Verdict forms should not list Doe defendants or contain the identity or address of any attorney.

Applies to

Witness list

Joint Witness List must include a schedule, estimated examination times, and total hours.

The Joint Witness List must include a realistic schedule of when each witness will be called, the estimated total time for direct and cross-examination of each witness, and the total number of hours the examination of all witnesses is expected to consume.

Applies to

Exhibit list

Plaintiff exhibits start at 1; Defendant exhibits start at 200.

In a two-party case, Plaintiff shall number its exhibits starting with 1. Defendant shall number its exhibits starting with 200.

Applies to

Proposed judgment

Proposed Judgment must include the exact wording of the verdict.

After the verdict is read and the jury discharged, Counsel for the prevailing party shall prepare a Proposed Judgment, which must include the exact wording of the verdict.

Applies to

Videotaped deposition

Videotaped depositions must be transcribed, marked as exhibit, and edited to remove objections and argument.

Videotaped depositions must be transcribed and marked as an exhibit. The videotape must be edited before being shown to the jury to remove objections and argument by counsel.

Applies to

Mandatory settlement conference statement

The MSC statement must include the email address of settlement counsel.

PLEASE INCLUDE E-MAIL ADDRESS OF SETTLEMENT COUNSEL ON THE MSC STATEMENT.

Applies to

Ex parte application

Ex parte applications must include an affirmative factual showing in a declaration, demonstrate appropriate notice, and state whether the application will be opposed.

All Parties must comply with CRC 3.1200 through 3.1207, including but not limited to making an 'affirmative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte.' CRC 3.1202 (c). Papers must also demonstrate appropriate notice and state whether the application will be opposed.

Applies to

Ex parte application

Must include

proposed order

An ex parte application must include a proposed order.

All papers in support of an ex-parte application (including the proposed order) must be e-filed – and courtesy copies distributed to the courtroom – no later than 3:00 p.m. the business day before the ex parte hearing.

Applies to

Ex parte application

Ex parte applications must comply with CRC 3.1200 through 3.1207, be in writing, and include a declaration stating notice details and whether the application will be opposed.

Ex-Parte applications must comply with CRC 3.1200 through 3.1207. Applications must be in writing and include all of the following: 1. A declaration setting forth the details of the terms of notice given to the opposing counsel of the ex-parte hearing and stating whether the application will be opposed.

Applies to

Ex parte application

Ex parte moving papers must show admissible evidence of proper notice, state whether the other parties will oppose, and the moving counsel must attempt to learn the opposing position.

The moving papers must demonstrate with admissible evidence that the moving party gave proper notice and must state whether the other parties to the case will return oppose the application. Counsel for the moving party must make good faith efforts to speak with opposing counsel to determine their position(s) on the ex-parte application.

Applies to

Joint meet and confer statement

Counsel must comply with Local Rule 315, requiring an early meet and confer and the filing of a Joint Meet and Confer Statement.

Counsel must comply with Local Rule 315, which (among other things) requires a generalized early meet-and-confer on the enumerated subjects and the design of a Joint Now Meet and Confer Statement, all within specified time limits.

Applies to

Case management statement

All parties must file a Case Management Statement in compliance with CRC 3.725 and comply with CRC 3.720 through 3.734.

All Parties must be fully familiar with, and comply with as applicable, CRC 3.720 through 3.734, including but not limited to the requirement that all Parties file a Case Management Statement in compliance with CRC 3.725.

Applies to

Request for judicial notice

Requests for judicial notice must be in a separate document, attach the document(s), and specify the legal basis with citation.

All requests for judicial notice must be set forth in a separate document, must state a copy of the document(s) of which notice is requested, and must specify (with appropriate legal citation) the legal defense on which judicial notice is sought.

Applies to

Separate statement

Separate statements must comply with CRC 3.1350.

Separate statements must comply with CRC 3.1350.

Applies to

Declaration

Declarations in summary judgment motions must be filed separately and not attached to the notice of motion or memorandum.

Declarations filed in support of or in opposition to a motion for summary judgment and/or adjudication must be separately filed, i.e., not attached to or made part of the notice of motion and motion or the memorandum of points and authorities.

Applies to

Trial notebook

The trial notebook must contain ten specified documents, double-sided and each separately tabbed.

The court's trial notebook shall contain the following double-sided documents, each separately tabbed: 1. Joint Statement of the Case; 2. Executed Statement of Compliance; 3. Joint List of Stipulated Facts; 4. Joint List of Controverted Issues; 5. Joint Exhibit List; 6. Joint Witness List; 7. Proposed Voir Dire Questions (if any) for court voir dire; 8. Procedural Stipulations; 9. Proposed Verdict Form; and 10. In Limine Motions and Oppositions.

Applies to

Deposition designations

Deposition designations must be in writing on a highlighted hard copy of the transcript provided to opposing counsel by the Issue Conference, with counter-designations in a different color and objections noted in the margin.

A party that expects to present one or more witnesses at trial by deposition shall, no later than the Issue Conference, provide opposing counsel with its written deposition designations. This shall be done by providing a hard copy of the deposition transcript with the party's designations highlighted. The other party shall, on the same hard copy of the document, mark its counter-designations (by highlighting them in a different color) and also indicate, in the margin next to any testimony designated by the other side, any objections to the admissibility of the designated testimony.

Applies to

Joint statement of case and joint witness list

A Joint Statement of the Case and a joint witness list must be prepared for submission to the court.

4. Joint Statement of the case and joint witness list has been prepared for submission to the court as required.**

Applies to

Joint witness list

The Joint Witness List must include a realistic witness schedule, estimated direct/cross-examination time per witness, and total examination hours; it need not include impeachment or rebuttal witnesses.

Whatever form Counsel selects, the Joint Witness List must include a realistic schedule of when each witness will be called, the estimated total time for direct and cross-examination of each witness, and the total number of hours the examination of all witnesses is expected to consume. Pursuant to Local Rule 317, the Joint Witness List need not include impeachment or rebuttal witnesses.

Applies to

Joint exhibit list

The Joint Exhibit List must be prepared by the Issue Conference and include each exhibit's number and description with the document date or an undated notation; impeachment/rebuttal exhibits are not required.

At or before the Issue Conference, the Parties must cooperate in preparing each case a Joint Exhibit List. The parties may, but are not required to, use the attached Joint Exhibit List form. The Joint Exhibit List shall include the exhibit number and a brief description of each exhibit, including the date of the document or a notation that the document is undated (e.g., “Exhibit 100, Letter from J. Jones to C. Clark dated 1/12/2000”). Pursuant to Local Rule 317, the parties need not exchange or include the Joint Exhibit List those exhibits contemplated to be used for impeachment or rebuttal.

Applies to

Joint list of controverted issues

Counsel must prepare a joint list of controverted issues for trial.

5. Counsel has prepared a joint list of controverted issues.**

Applies to

Exhibit

In a two-party case, Plaintiff numbers exhibits starting at 1 and Defendant at 200; parties must agree on non-duplicative number ranges, use only numbers not letters, and number each page of each exhibit separately.

c. In a two-party case, Plaintiff shall number its exhibits starting with 1. Defendant shall number number its exhibits starting with 200. If, in any given case, these numbers are not sufficient to accommodate exhibits, the Parties shall cooperate in agreeing on an appropriate number range for each party. If there are more than two parties, the Parties shall cooperate in agreeing on a number range for each party, so that no two parties use the same exhibit numbers. Duplicate exhibits are to be avoided. Only exhibit numbers (not letters) are to be used. Each page of each exhibit must be internally numbered.

Applies to

Videotaped deposition

Videotaped depositions must be transcribed, marked as an exhibit, and edited before trial to remove objections and counsel's arguments.

c. Videotaped depositions must be transcribed and marked as an exhibit. The videotape must be edited before it is shown to the jury to remove objections and argument by counsel.

Applies to

Exhibits

Counsel must inspect all exhibits and diagrams, ensure they are ready for clerk premarking, and submit stipulations as to admission or foundation waiver with the exhibits.

1. Counsel has inspected all exhibits and diagrams and the exhibits are ready for premarking by the clerk. All stipulations as to admission into evidence or waiver of foundation are submitted with the exhibits(s).

Applies to

List of stipulated facts

All counsel must prepare a list of stipulated facts and make a good-faith effort to stipulate to as many documents, foundational waivers, and similar matters as possible.

6. All counsel have prepared a list of stipulated facts and made a good faith effort to stipulate to as many of the facts, waiver of foundational requirements, etc., as reasonably possible.**

Applies to

Trial

Counsel must bring trial and exhibit binders on the first day of trial.

Counsels are to bring trial and exhibit binders on first day of trial.

Applies to

Stipulation

Must include

proposed order

Stipulations must be signed by all parties; proposed orders must have a static signature date.

All stipulations must be signed by all parties or their counsel. If parties submit a proposed order make certain the date associated with their signature is static.

Applies to

Trial notebook

The trial notebook must contain ten specific items, each separately tabbed.

The court’s trial notebook shall contain the following, each separately tabbed: 1. Joint Statement of the Case; 2. Executed Statement of Compliance; 3. Joint List of Stipulated Facts; 4. Joint List of Controverted Issues; 5. Joint Exhibit List; 6. Joint Witness List; 7. Proposed Voir Dire Questions (if any) for court voir dire; 8. Factual Stipulations; 9. Proposed Verdict Form; 10. In Limine Motions and Oppositions.

Applies to

Exhibits

Plaintiff exhibits numbered starting with 1, defendant exhibits starting with 200; parties must cooperate to avoid duplicates; every page must be numbered.

In a two-party case, Plaintiff shall number its exhibits starting with 1; Defendants shall number its exhibits starting with 200. If in a particular case these numbers are not sufficient to cover all exhibits, the Parties are to cooperate and agree to an appropriate number range for each party. If there are more than two Parties, the Parties are to cooperate in agreeing on a number range for each party. No two Parties are to use the same number, and duplicate exhibits are to be avoided. Every page of each exhibit must be separately numbered.

Applies to

Statement of compliance

A Statement of Compliance must be completed and submitted before being signed by all counsel.

A statement of Compliance must be submitted and must be completed prior to being signed by all counsel.

Applies to

Case management statement

Case Management Statement must include discussion of subjects in CRC Rule 3.727.

Counsel should use pleading paper rather than Judicial Council Form CM-110 and include in the Statement a discussion of the applicable subjects set forth in CRC Rule 3.727.

Applies to

Status report

Status Reports should focus on latest developments since last Status Conference.

Please focus on the latest developments since your last Status Conference.

Applies to

Status conference report

Status conference reports must focus on latest developments since last hearing.

Status conference reports shall be filed (using pleading paper) at least 5 court days before the scheduled conference/hearing and should focus on the latest developments since the last conference/hearing.

Applies to

Joint witness list

Parties must submit a joint witness list.

Parties are required to submit a joint witness list (see attached form).

Applies to

Trial notebook

The Joint Trial Notebook must contain 12 specific sections, each separately tabbed.

The Court's trial notebook shall contain the following documents, each separately tabbed: 1. Table of contents 2. Copies of operative pleadings 3. Joint Statement of the Case (Jury Trials) 4. Executed Statement of Compliance 5. Joint Witness List 6. Stipulations of Fact, exhibit admissibility and/or foundation 7. Joint List of Controverted Issues 8. Joint Exhibit List 9. Proposed Voir Dire Questions (if any) for Court voir dire 10. Proposed Jury Instructions (Jury Trials) 11. Proposed Verdict Forms (Jury Trials) 12. Any Trial Briefs