Judge Loren G. Freestone
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Courtesy Copies
Pro Hac Vice Application, Motion, Opposition, Reply, Trial Readiness Report, Trial Brief
- Chambers Drop Off • Upon Filing
Document Filing Requirements8 rules
A completed joint trial readiness conference report must be filed in advance of the hearing per local rule 2.1.15.
A completed joint trial readiness conference report shall be filed in advance of the hearing pursuant to local rule 2.1.15.
Document Type
Trial Readiness Report
Pro hac vice applications must include proof of service on the State Bar of California, proof of payment of the required fee, and a proposed order.
Applications must include proof of service on the State Bar of California, proof of payment of the required fee, and a proposed order.
Document Type
Pro Hac Vice Application
All motions in limine must be filed per local rule 2.1.18.
Document Type
Motion In Limine
At trial call, counsel must bring a joint trial notebook containing the enumerated pretrial materials.
At trial call, counsel must bring a joint trial notebook, which should be comprised of the following: 1. Table of Contents 2. Copy of Joint Trial Readiness Report 3. Copies of Motion in Limine and Oppositions (in order) 4. Joint Witness List (with description of witnesses’ expected testimony) 5. Joint Exhibit List 6. Copies of Trial Briefs (if any) 7. Joint Statement of the Case 8. Proposed Voir Dire Questions (if any) 9. Jury Instructions (packet agreed upon and packet of those not agreed upon, with indication of who is offering and objecting)
Document Type
Joint Trial Notebook
All exhibits must be pre-marked in an up-to-date exhibit book.
Document Type
Exhibit Book
Default judgment papers must strictly comply with California Rules of Court rule 3.1800; non-complying papers will be returned with a notation of defects.
Papers must comply strictly with California Rules of Court, rule 3.1800. Non-complying papers will be returned with a notation of defects.
Document Type
Default Judgment Papers
If the parties fail to make a genuine effort to limit disputes on the special verdict form, the court will utilize a general verdict form.
10. Special Verdict Form (either an agreed upon form or each side’s proposed forms). If the parties fail to make a genuine effort to limit disputes on the form of the special verdict, a general verdict form will be utilized.
Document Type
Special Verdict Form
Proposed default judgments claiming punitive or non-economic damages will usually require a hearing.
Proposed default judgments claiming punitive damages and/or non-economic damages will usually require a hearing.
Document Type
Proposed Default Judgment
Filing & Service rules
Filing Timing and Cure Windows
Trial briefs must be filed five court days before trial call.
Trial briefs must be filed five court days prior to trial call.
Page 3 | Trial Calls
A party opposing an application may appear ex parte within five days to request a briefing schedule.
If a party opposes an application, that party may appear ex parte within five days to request a briefing schedule.
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Service and Proof of Service Rules
All exhibits, demonstrative aids, and other material for opening statements must be shared with opposing counsel in advance.
All exhibits, demonstrative aids, or other material to be used in opening statements must be shared with opposing counsel in advance.
Page 3 | Trial Calls
Filing Fees and Waivers
A required fee applies to pro hac vice applications, and proof of its payment must accompany the application.
proof of payment of the required fee
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Courtesy Copy Requirements
Courtesy copies of pro hac vice applications, noticed motions, oppositions, replies, joint trial readiness conference reports, and trial briefs should be placed in the Department 64 drop box outside the Business Office.
Courtesy copies of the following documents should be placed in the Department 64 drop box, located outside the Business Office on the second floor of the Hall of Justice: • Ex parte applications (delivered no later than 12:00 p.m. the day before the hearing) • Pro hac vice applications • Noticed motions, oppositions, and replies • Joint trial readiness conference reports • Trial briefs
Page 3 | Courtesy Copies