Judge Alexander C. D. Giza
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Ex Parte Opposition Motions, Summary Judgment Motions, Summary Adjudication Motions
- Hand Delivery • Upon Filing
Exhibits
- At Trial
Opposition To Ex Parte Application, Summary Judgment Papers, Summary Adjudication Papers
- Chambers Drop Off
Summary Judgment Motions, Summary Adjudication Motions
- Hand Delivery • Upon Filing
Binding: Three Ring Binder
Communication
Chambers
Phone
Chambers
Page & Word Limits1 rule
Machine summary. Not checked yet.Mandatory?
After meeting and conferring about available dates for an IDC, the parties should file a joint statement (no longer than 5 pages) that succinctly summarizes the nature of the dispute, necessity for the discovery, and objection or other basis for withholding the information, as well as overall status of discovery.
Summary: Joint statements for Informal Discovery Conferences must not exceed 5 pages.
Joint Statement Idc
5 pages
Applies to: Attorney
Document Format Requirements12 rules
The quote is in the court's document. The summary is not checked yet.Mandatory?
All electronically filed documents must be text-searchable and bookmarked. (See operative General Order re Mandatory Electronic Filing in Civil., referenced above.)
Summary: All electronically filed documents must be text-searchable and bookmarked.
The quote is in the court's document. The summary is not checked yet.Mandatory?
All deposition excerpts referenced in briefs must be marked on the transcripts attached as exhibits. (Rules of Court, rule 3.1116(c).)
Summary: Deposition excerpts cited in briefs must be marked on the transcript exhibits attached to the filing.
The quote is in the court's document. The summary is not checked yet.Mandatory?
Any courtesy copies of documents with declarations and/or exhibits must be tabbed. (Rules of Court, rule 3.1110(f).)
Summary: Courtesy copies of documents containing declarations and/or exhibits must be tabbed.
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties shall jointly prepare (and be ready to temporarily lodge for inspection at the FSC) one set of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (a set for the Court, the Judicial Assistant, and the witnesses).
Summary: Parties must jointly prepare one set of tabbed, internally paginated, properly marked exhibits organized numerically in three-ring binders for the Court, the Judicial Assistant, and the witnesses, ready to lodge for inspection at the FSC.
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the exhibit binder.
Summary: All non-documentary exhibits must be marked, with a simple written description inserted behind the corresponding numerical tab in the exhibit binder.
The quote is in the court's document. The summary is not checked yet.Mandatory?
The final set of jury instructions and verdict forms shall be in a format suitable for submission to the jury during deliberations, and shall not include any citations to authority, identification of the party requesting the instruction or verdict, or any letterhead or markings identifying the attorney who prepared or printed them. (LASCR 3.174).
Summary: Final jury instructions and verdict forms must be suitable for jury deliberations and may not contain citations to authority, party identification, or attorney letterhead/markings.
The quote is in the court's document. The summary is not checked yet.Important?
The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Motions in Limine Tab C: Joint Statement of the Case Tab D: Joint Witness List Tab E: Joint List of Jury Instructions (joint and contested) Tab F: Full Text Jury Instructions Tab G: Joint and/or Contested Verdict Forms
Summary: The trial binder must be tabbed and organized in the specified order: Tab A Trial Briefs, Tab B Motions in Limine, Tab C Joint Statement of the Case, Tab D Joint Witness List, Tab E Joint List of Jury Instructions, Tab F Full Text Jury Instructions, and Tab G Verdict Forms.
The quote is in the court's document. The summary is not checked yet.Important?
Whether in a separate binder or Tab B, Plainti ’s should come first, followed by those of Defendant. There should be numbered tabs separating each motion and colored sheets of paper between the motion and any opposition and between the opposition and any reply.
Summary: Motions in limine must be ordered with plaintiff's papers first followed by defendant's, separated by numbered tabs, with colored sheets of paper between the motion and opposition and between the opposition and any reply.
Machine summary. Not checked yet.Mandatory?
All electronically filed documents must be text-searchable and bookmarked. (See operative General Order re Mandatory Electronic Filing in Civil., referenced above.)
Summary: All electronically filed documents must be text-searchable and include bookmarks.
Machine summary. Not checked yet.Mandatory?
Counsel must provide a joint trial binder for the Court at the FSC. The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Motions in Limine Tab C: Joint Statement of the Case Tab D: Joint Witness List Tab E: Joint List of Jury Instructions (joint and contested) Tab F: Full Text Jury Instructions Tab G: Joint and/or Contested Verdict Forms Tab I: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab J: Operative Pleadings Tab K: Stipulations If there are more than a few motions in limine, they should be placed in a separate binder. Whether in a separate binder or Tab B, Plainti ’s should come first, followed by those of Defendant. There should be numbered tabs separating each motion and colored sheets of paper between the motion and any opposition and between the opposition and any reply.
Summary: Joint trial binders must be organized with specified tabbed sections; motions in limine should be in a separate binder if numerous, with plaintiff's first, numbered tabs, and colored sheets between motion papers.
Machine summary. Not checked yet.Mandatory?
The parties shall jointly prepare (and be ready to temporarily lodge for inspection at the FSC) one set of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (a set for the Court, the Judicial Assistant, and the witnesses). At trial, the parties will need additional copies of the exhibits for the Court’s clerk, for use on the witness stand, and for each counsel. The parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the exhibit binder.
Summary: Exhibits must be tabbed, internally paginated, properly marked, organized numerically in three-ring binders for court, judicial assistant, and witnesses, with non-documentary exhibits described.
Machine summary. Not checked yet.Mandatory?
The parties are jointly responsible for the preparation of a final set of jury instructions and verdict forms after the Court rules on any disputes. The final set of jury instructions and verdict forms shall be in a format suitable for submission to the jury during deliberations, and shall not include any citations to authority, identification of the party requesting the instruction or verdict, or any letterhead or markings identifying the attorney who prepared or printed them. (LASCR 3.174).
Summary: Final jury instructions and verdict forms must not include citations, party identification, or attorney letterhead/markings, and must be suitable for jury deliberation.
Document Filing Requirements19 rules
The quote is in the court's document. The summary is not checked yet.Mandatory?
Ex parte applications are reserved for exigent circumstances and must comply with Rules of Court, rule 3.1202(c): "An applicant must make an a irmative 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."
Summary: Ex parte applications are reserved for exigent circumstances and must include a declaration making an affirmative factual showing of irreparable harm, immediate danger, or another statutory basis for relief.
Document Type
Ex Parte Application
The quote is in the court's document. The summary is not checked yet.Mandatory?
Parties filing more than one motion in limine shall number them consecutively.
Summary: Parties filing more than one motion in limine must number the motions consecutively.
Document Type
Motion In Limine
The quote is in the court's document. The summary is not checked yet.Mandatory?
Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.
Summary: Opposition and reply papers on motions in limine must identify the corresponding motion number in the caption.
Document Type
Motion In Limine Opposition And Reply
The quote is in the court's document. The summary is not checked yet.Important?
The parties must then file timely Case Management Conference Statements pursuant to Rules of Court, rule 3.725 (preferably a joint statement), describing the nature of the case, when discovery will be completed ("per code" does not assist the Court), and any agreements the parties have reached (see 19(b) of the Statement). A failure to comply with Rules of Court, rules 3.724 and 3.725 may subject the offending counsel to sanctions of up to $250 per violation. (Rules of Court, rule 2.30.)
Summary: Parties must file timely Case Management Conference Statements (preferably joint) describing the case, discovery timeline, and agreements, with sanctions up to $250 per violation for noncompliance.
Document Type
Case Management Conference Statement
The quote is in the court's document. The summary is not checked yet.Important?
Parties filing opposition and reply briefs shall identify the corresponding motion number in the caption of their papers.
Summary: Opposition and reply briefs must identify the corresponding motion in limine number in the caption.
Document Type
Opposition And Reply Brief
The quote is in the court's document. The summary is not checked yet.Important?
The parties shall prepare a complete set of full-text proposed jury instructions, editing all proposed California Civil Jury Instructions, insert party name(s), eliminate blanks, brackets, and irrelevant material.
Summary: Parties must prepare a complete set of full-text proposed jury instructions edited from the CACI with party names inserted and blanks, brackets, and irrelevant material eliminated.
Document Type
Jury Instructions
The quote is in the court's document. The summary is not checked yet.Important?
The parties shall work together and file a joint list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. (Local Rule 3.25(g)(5).) The joint witness list shall identify each witness by name, specify which witnesses are non-experts and experts, estimate the length of the direct, cross examination and re-direct examination of each witness, and include a total time for all witness testimony. The parties shall identify all potential witness scheduling issues and special requirements. Any party who seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the trial court. The parties/counsel shall sign the joint witness list.
Summary: Parties must file a signed joint witness list (excluding impeachment and rebuttal witnesses) identifying each witness by name, expert status, estimated examination times, total testimony time, and scheduling issues; testimony from unlisted witnesses requires a showing of good cause.
Document Type
Joint Witness List
The quote is in the court's document. The summary is not checked yet.Important?
Each party shall file a trial brief succinctly identifying (i) the claims and defenses subject to litigation; (ii) the major legal issues (with supporting points and authorities); (iii) the relief claimed, and calculation of damages sought; and (iv) any other information that may assist the court at trial.
Summary: Each party's trial brief must identify the claims and defenses, major legal issues with supporting authorities, relief and damages sought, and other information assisting the court at trial.
Document Type
Trial Brief
The quote is in the court's document. The summary is not checked yet.Important?
Parties filing more than one motion in limine shall number the motions consecutively.
Summary: Parties filing multiple motions in limine must number them consecutively.
Document Type
Motion In Limine
The quote is in the court's document. The summary is not checked yet.Important?
The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to preclude.
Summary: Each motion in limine's caption must concisely identify the evidence the moving party seeks to preclude.
Document Type
Motion In Limine
The quote is in the court's document. The summary is not checked yet.Important?
For jury trials, the parties shall prepare a joint written statement of the case for the Court to read to the jury. (Local Rule 3.25(g)(4).) The joint statement shall be a neutral short statement of the case and not exceed 2 paragraphs. The parties/counsel shall sign the joint statement.
Summary: In jury trials, parties must file a signed joint statement of the case that is neutral and does not exceed 2 paragraphs, for the court to read to the jury.
Document Type
Joint Statement Of Case
The quote is in the court's document. The summary is not checked yet.Important?
The parties shall prepare special instructions in a format ready for submission to the jury with the instruction number, title, and text only (i.e. there should be no boxes or other indications on the printed
Summary: Special jury instructions must be ready for submission to the jury with only the instruction number, title, and text (no boxes or other indications on the printed page), and the court will generally not give a substituted special instruction.
Document Type
Special Jury Instructions
The quote is in the court's document. The summary is not checked yet.Important?
Uncontested and contested instructions shall be separated into subsections, with all uncontested instructions together, and all contested instructions together.
Summary: Proposed jury instructions must be separated into subsections with all uncontested instructions together and all contested instructions together.
Document Type
Jury Instructions
The quote is in the court's document. The summary is not checked yet.Important?
The parties shall prepare and file a joint exhibit list organized with columns identifying : (1) the exhibit, (2) which party is o ering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) each party's evidentiary objection, if any, to admission of each exhibit, (5) the date on which the exhibit was identified, and (6) the date on which the exhibit was admitted. The parties shall meet and confer to resolve objections to the admissibility of each exhibit. The parties shall sign the joint exhibit list.
Summary: Parties must file a signed joint exhibit list with columns for the exhibit, offering party, authenticity/admissibility stipulations, evidentiary objections, and identification/admission dates, after meeting and conferring to resolve objections.
Document Type
Joint Exhibit List
The quote is in the court's document. The summary is not checked yet.Important?
If the parties intend to use deposition testimony or former trial testimony in lieu of any witness's live testimony, the parties shall meet-and-confer and jointly prepare and file a chart with columns for each of the following: (1) the page and line designations of the deposition or former testimony requested for use, (2) objections, (3) counter-designations, (4) any responses thereto, and (5) the Court's rulings. The objecting party shall specify all objections in the respective column. The parties/counsel shall sign the designations.
Summary: Parties using deposition or former trial testimony in lieu of live testimony must jointly prepare and file a signed designation chart with columns for page/line designations, objections, counter-designations, responses, and the court's rulings.
Document Type
Deposition Designation Chart
The quote is in the court's document. The summary is not checked yet.Important?
The parties shall prepare and file a joint proposed general verdict form or special verdict form (with interrogatories) acceptable to all sides. (Local Rule 3.25(g)(8).) If the parties/counsel cannot agree on a joint verdict form, each party must separately file a proposed verdict form, and bring an electronic copy of their proposed verdict form to the FSC, ready to be edited in the courtroom.
Summary: Parties must file a joint proposed verdict form; if they cannot agree, each party must separately file a proposed verdict form and bring an electronic copy to the FSC ready to be edited in the courtroom.
Document Type
Verdict Form
The quote is in the court's document. The summary is not checked yet.Important?
The parties/counsel are strongly encouraged to stipulate to uncontested motions. Uncontested motions should note “uncontested” in the caption.
Summary: Parties are strongly encouraged to stipulate to uncontested motions in limine, and uncontested motions should be marked 'uncontested' in the caption.
Document Type
Motion In Limine
The quote is in the court's document. The summary is not checked yet.Important?
Each morning, counsel must provide the Court Attendant with a written list of witnesses to be called that day including their full names with correct spellings and the order in which they will be called.
Summary: Each morning, counsel must give the Court Attendant a written list of that day's witnesses including full names with correct spellings and the order of calling.
Document Type
Daily Written Witness List
Machine summary. Not checked yet.Note?
The following motions in limine are deemed filed and granted: (A) to preclude non-testifying, non-party witnesses from being present in the courtroom when others are testifying (see Evid. Code § 777) (B) to preclude reference to the liability insurance in a case defended by that liability insurance policy; and (C) to preclude references to settlement discussions.
Summary: Three specific motions in limine are deemed filed and granted if properly filed: precluding non-testifying witnesses, liability insurance references, and settlement discussions.
Document Type
Motion In Limine
Filing & Service rules
Electronic Filing Rules
All parties must electronically file documents unless they have obtained an exemption from mandatory electronic filing.
Except for parties or attorneys who have obtained an exemption from mandatory electronic filing, parties must electronically file documents.
The quote is in the court's document. The summary is not checked yet. · Civil cases
Page 2
Documents may not be filed by facsimile in Department 78.
Filings are not accepted via facsimile.
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Parties must electronically file documents unless exempt from mandatory e-filing; facsimile filings are prohibited, and filed documents may take 1-2 business days to appear on the docket.
Except for parties or attorneys who have obtained an exemption from mandatory electronic filing, parties must electronically file documents. Filings are not accepted via facsimile. Please be aware that it may take 1-2 business days for a filed document to appear in the Court’s docket. The requirements for electronic filing are detailed in the operative General Order re Mandatory Electronic Filing for Civil (Superior Court, L.A. County).
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Filing Timing and Cure Windows
Papers for a reserved hearing must be filed within 3 days of making the CRS reservation or the reservation will be cancelled.
Note that papers for a reserved matter must be filed within 3 days of making the reservation, otherwise the reservation will be cancelled.
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Page 2 | F. LAW AND MOTION - 1. Reservation Hearing Date
Trial readiness documents must be served and filed at least five court days before the final status conference.
At least five court days prior to the FSC, the parties shall serve and file the following trial readiness documents:
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Page 5 | 1. Final Status Conference ("FSC") and Pretrial Filings
Motions in limine must comply with CCP section 1005 notice provisions and Local Rule 3.57(a) before filing.
Before filing motions in limine, the parties shall comply with the statutory notice provisions of CCP section 1005 and the requirements of Local Rule 3.57(a).
The quote is in the court's document. The summary is not checked yet. · Civil cases
Page 5 | 1. Final Status Conference ("FSC") and Pretrial Filings
All pretrial documents must be filed in advance of the final status conference.
All pretrial documents must be filed in advance of the FSC.
The quote is in the court's document. The summary is not checked yet. · Civil cases
Page 5 | 1. Final Status Conference ("FSC") and Pretrial Filings
Before filing motions in limine, parties must comply with the CCP § 1005 statutory notice provisions and Los Angeles Superior Court Local Rule 3.57(a).
Before filing motions in limine, the parties shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and the requirements of the Superior Court, Los Angeles County, Local Rules, rule 3.57(a).
The quote is in the court's document. The summary is not checked yet. · Civil cases
Page 7 | 3. Motions in Limine
Copies of deposition transcripts or other discovery responses must be lodged with the Court before trial.
Before trial, copies of deposition transcripts or other discovery responses shall be lodged with the Court. (LASCR 3.56.)
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Page 8 | 7. Reading from Discovery Responses/Deposition Transcripts
Stipulations are to be filed before trial to the extent feasible.
To the extent feasible, stipulations are to be filed before trial. (LASCR 3.125)
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Page 8 | 6. Stipulations
Filed documents may take 1-2 business days to appear on the Court's docket.
Please be aware that it may take 1-2 business days for a filed document to appear in the Court's docket.
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Three motions in limine are automatically deemed filed and granted: witness sequestration of non-testifying non-party witnesses, preclusion of liability insurance references, and preclusion of settlement discussion references.
The following motions in limine are deemed filed and granted: (A) to preclude non-testifying, non-party witnesses from being present in the courtroom when others are testifying (see Evid. Code § 777) (B) to preclude reference to the liability insurance in a case defended by that liability insurance policy; and (C) to preclude references to settlement discussions.
The quote is in the court's document. The summary is not checked yet. · Civil cases
Page 7 | 3. Motions in Limine
Parties must meet and confer 30 days before CMC and file timely CMC statements including case nature, discovery timeline, and agreements; non-compliance may result in $250 sanctions per violation.
Thirty days before a scheduled Case Management Conference, the parties are ordered to meet and confer in person, by telephone, or by video to discuss the items listed in Rules of Court, rule 3.724. The Court expects this to be a meaningful conference in which counsel with authority discuss the pleadings, discovery, and a path to case resolution, whether by settlement or trial. The parties must then file timely Case Management Conference Statements pursuant to Rules of Court, rule 3.725 (preferably a joint statement), describing the nature of the case, when discovery will be completed (“per code” does not assist the Court), and any agreements the parties have reached (see 19(b) of the Statement). A failure to comply with Rules of Court, rules 3.724 and 3.725 may subject the o ending counsel to sanctions of up to $250 per violation. (Rules of Court, rule 2.30.)
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Motion papers must be filed within 3 days of reserving a hearing date, or the reservation will be cancelled.
Note that papers for a reserved matter must be filed within 3 days of making the reservation, otherwise the reservation will be cancelled.
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All trial readiness documents must be served and filed at least 5 court days before the Final Status Conference, including trial briefs, motions in limine, joint statements, witness lists, jury instructions, verdict forms, exhibit lists, deposition designations, and stipulations.
At least five court days prior to the FSC, the parties shall serve and file the following trial readiness documents: Trial briefs. Each party shall file a trial brief succinctly identifying (i) the claims and defenses subject to litigation; (ii) the major legal issues (with supporting points and authorities); (iii) the relief claimed, and calculation of damages sought; and (iv) any other information that may assist the court at trial. Motions in limine. Before filing motions in limine, the parties shall comply with the statutory notice provisions of CCP section 1005 and the requirements of Local Rule 3.57(a). The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to preclude. Parties filing more than one motion in limine shall number the motions consecutively. Joint statement. For jury trials, the parties shall prepare a joint written statement of the case for the Court to read to the jury. (Local Rule 3.25(g)(4).) The joint statement shall be a neutral short statement of the case and not exceed 2 paragraphs. Joint witness list. The parties shall work together and file a joint list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. (Local Rule 3.25(g)(5).) Jury instructions (joint and contested). The parties shall prepare a complete set of full-text proposed jury instructions, editing all proposed California Civil Jury Instructions, insert party name(s), eliminate blanks, brackets, and irrelevant material. Joint verdict form(s). The parties shall prepare and file a joint proposed general verdict form or special verdict form (with interrogatories) acceptable to all sides. (Local Rule 3.25(g)(8).) Joint exhibit list. The parties shall prepare and file a joint exhibit list organized with columns identifying : (1) the exhibit, (2) which party is o ering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) each party’s evidentiary objection, if any, to admission of each exhibit, (5) the date on which the exhibit was identified, and (6) the date on which the exhibit was admitted. Page and line designations for deposition and former testimony. If the parties intend to use deposition testimony or former trial testimony in lieu of any witness’s live testimony, the parties shall meet-and-confer and jointly prepare and file a chart with columns for each of the following: (1) the page and line designations of the deposition or former testimony requested for use, (2) objections, (3) counter-designations, (4) any responses thereto, and (5) the Court’s rulings. Stipulations. The Court orders the parties to meet and confer regarding potential stipulations to the ultimate facts and issues, as well as to the admissibility of exhibits.
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Visual aids for closing arguments must be disclosed to opposing counsel by 8:30 AM on the day of closing arguments, or the Court may prohibit their use.
If a party wishes to use graphics, demonstrative exhibits, or other visual aids during their closing arguments, including presentations created with PowerPoint or other presentation software, they must disclose such material to their opposing counsel no later than 8:30 am on the day that closing arguments are scheduled, so that any objections may be identified and resolved. (Local Rule 3.180.) Failure to comply with this requirement may result in the Court prohibiting the use of such material.
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Service and Proof of Service Rules
Plaintiffs must serve the summons and complaint on defendants within 60 days of filing the complaint or face sanctions, including dismissal.
Plaintiff(s) shall service the summons and complaint upon Defendant(s) within 60 days of filing of the complaint. (Rules of Court, rule 3.110 (b).) Failure to do so may result in the imposition of sanctions (See CCP §§ 128, 177.5; Rules of Court, rule 2.30), including dismissal (CCP §§ 583.410, 583.420), unless Plaintiff(s) shows cause why the court should not make such an order.
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Page 2 | D. SERVICE OF SUMMONS AND COMPLAINT
Parties must disclose closing-argument graphics, demonstrative exhibits, and visual aids to opposing counsel by 8:30 am on the day of closing arguments or risk the Court prohibiting their use.
If a party wishes to use graphics, demonstrative exhibits, or other visual aids during their closing arguments, including presentations created with PowerPoint or other presentation software, they must disclose such material to their opposing counsel no later than 8:30 am on the day that closing arguments are scheduled, so that any objections may be identified and resolved. (Local Rule 3.180.) Failure to comply with this requirement may result in the Court prohibiting the use of such material.
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Page 9 | J. TRIAL PROCEDURES — 11. Closing Arguments
Plaintiffs must serve summons and complaint on defendants within 60 days of filing the complaint, or face potential sanctions or dismissal.
Plainti (s) shall service the summons and complaint upon Defendant(s) within 60 days of filing of the complaint. (Rules of Court, rule 3.110 (b).) Failure to do so may result in the imposition of sanctions (See CCP §§ 128, 177.5; Rules of Court, rule 2.30), including dismissal (CCP §§ 583.410, 583.420), unless Plainti (s) shows cause why the court should not make such an order.
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Filing Fees and Waivers
Motion fees must be paid at the time the hearing reservation is made online.
Motion fee payments are required at the time reservations are made online.
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Page 2 | F. LAW AND MOTION - 1. Reservation Hearing Date
Ex parte applications must comply with California Rules of Court, rule 3.1200 et seq., and the filing fee must be paid before appearing in Department 78.
Ex parte applications must comply with Rules of Court, rule 3.1200, et seq. and pay the ling fee before appearing in Dept. 78.
The quote is in the court's document. The summary is not checked yet. · Civil cases
Page 4 | G. EX PARTE APPLICATIONS
Parties must pay jury fees no later than 365 calendar days after the initial complaint is filed.
Parties must pay jury fees no later than 365 calendar days after the ling of the initial complaint. (CCP § 631, subd. (c)(2).)
The quote is in the court's document. The summary is not checked yet. · Civil cases
Page 4 | H. JURY FEES
Motion filing fees must be paid when reserving a hearing date online via the Court Reservation System.
Motion fee payments are required at the time reservations are made online.
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Ex parte applications require filing fee payment before appearance and must include a declaration with affirmative factual showing of irreparable harm, immediate danger, or statutory ex parte basis.
Ex parte applications must comply with Rules of Court, rule 3.1200, et seq. and pay the filing fee before appearing in Dept. 78. Ex parte applications are reserved for exigent circumstances and must comply with Rules of Court, rule 3.1202(c): “An applicant must make an a irmative 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.”
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Jury fees must be paid within 365 calendar days of filing the initial complaint.
Parties must pay jury fees no later than 365 calendar days after the filing of the initial complaint. (CCP § 631, subd. (c)(2).)
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Courtesy Copy Requirements
Department 78 requires courtesy copies only for oppositions to ex parte applications and papers related to motions for summary judgment/adjudication, and such copies must be submitted directly to Department 78.
Except for oppositions to ex parte applications and papers related to motions for summary judgment/adjudication, Department 78 does not require courtesy copies of any led papers. Such courtesy copies must be submitted directly to Department 78.
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Page 3 | F. LAW AND MOTION
At trial, parties must have additional exhibit copies for the Court's clerk, the witness stand, and each counsel.
At trial, the parties will need additional copies of the exhibits for the Court’s clerk, for use on the witness stand, and for each counsel.
The quote is in the court's document. The summary is not checked yet. · Civil cases
Page 7 | 4. Evidentiary Exhibits
Courtesy copies are required only for ex parte oppositions and summary judgment/adjudication papers, must be submitted directly to Dept 78, and are destroyed after the hearing.
Except for oppositions to ex parte applications and papers related to motions for summary judgment/adjudication, Department 78 does not require courtesy copies of any filed papers. Such courtesy copies must be submitted directly to Department 78. Courtesy copies, including any media attached thereto, will be destroyed by the Court without notice following the hearing.
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MSJ/MA courtesy copies are encouraged to be in three-ring binders with tabs; all courtesy copies with declarations/exhibits must be tabbed, and deposition excerpts in briefs must be marked on attached transcripts.
Parties filing and opposing lengthy motions for summary judgment or adjudication are strongly encouraged to submit one or more three-ring binders organizing the courtesy copy behind tabs. Any courtesy copies of documents with declarations and/or exhibits must be tabbed. (Rules of Court, rule 3.1110(f).) All deposition excerpts referenced in briefs must be marked on the transcripts attached as exhibits. (Rules of Court, rule 3.1116(c).)
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Filing Bundling Requirements
Counsel must provide the court a joint trial binder at the FSC, organized with tabs for trial briefs, motions in limine, joint statement, joint witness list, jury instructions, and verdict forms (tab list continues on the next page).
Counsel must provide a joint trial binder for the Court at the FSC. The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Motions in Limine Tab C: Joint Statement of the Case Tab D: Joint Witness List Tab E: Joint List of Jury Instructions (joint and contested) Tab F: Full Text Jury Instructions Tab G: Joint and/or Contested Verdict Forms (cont'd on next page)
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Page 6 | 2. Trial Binders
For lengthy summary judgment/adjudication motions, filing and opposing parties are strongly encouraged to submit courtesy copies organized behind tabs in one or more three-ring binders.
Parties ling and opposing lengthy motions for summary judgment or adjudication are strongly encouraged to submit one or more three-ring binders organizing the courtesy copy behind tabs.
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Page 3 | F. LAW AND MOTION
When there are more than a few motions in limine, they should be placed in a separate binder rather than in Tab B of the trial binder.
If there are more than a few motions in limine, they should be placed in a separate binder.
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Page 7 | 3. Motions in Limine
Pre-Motion Conference Requirements
Moving parties must reserve a hearing date via 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.org to reserve a hearing date prior to filing any motion, except for motions in limine, which are normally heard at the final status conference or the first day of trial.
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Page 2 | F. LAW AND MOTION - 1. Reservation Hearing Date
Parties are ordered to meet and confer in good faith to informally resolve discovery disputes, and the Court generally finds conferring only by letters and emails to be insufficient.
Per CCP section 2016.040, the parties are ordered to meet and confer to make reasonable, good-faith e orts to informally resolve discovery disputes. The Court generally nds that meeting and conferring by only exchanging letters and e-mails, as opposed to phone or video conversation, is insu icient and ine ective.
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Page 3 | F. LAW AND MOTION - 5. Motions to Compel Further Responses to Discovery
When pursuing an IDC, parties should file a joint statement of no more than 5 pages summarizing the dispute, the necessity for the discovery, the basis for withholding the information, the status of discovery, and informal resolution efforts.
After meeting and conferring about available dates for an IDC, the parties should le a joint statement (no longer than 5 pages) that succinctly summarizes the nature of the dispute, necessity for the discovery, and objection or other basis for withholding the information, as well as overall status of discovery. Parties should brie y indicate what e orts were made to informally resolve the issue.
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Page 3 | F. LAW AND MOTION - 5. Motions to Compel Further Responses to Discovery
Parties must meet and confer in good faith before filing motions in limine to attempt to reach a stipulation, and failure to do so may result in summary denial of the motion.
Parties must meet and confer in good faith prior to filing the motions in limine, to try to reach a stipulation on the evidence and other issues. A simple exchange of letters that identify the motions to be filed is not su icient. Failure to meet and confer in good faith may result in a summary denial of the motion.
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Page 7 | 3. Motions in Limine
Parties moving to compel further discovery responses are encouraged to schedule an Informal Discovery Conference before the hearing, but doing so does not extend the motion filing deadline and is entirely at the Court's discretion.
Parties seeking to compel further responses to discovery are encouraged to attempt to schedule an Informal Discovery Conference (IDC) before the hearing on their motions. Scheduling the IDC does not extend the time to le a motion to compel further responses to discovery.
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Page 3 | F. LAW AND MOTION - 5. Motions to Compel Further Responses to Discovery
Parties must meet and confer in good faith before filing motions in limine; failure to do so may result in summary denial.
Parties must meet and confer in good faith prior to filing the motions in limine, to try to reach a stipulation on the evidence and other issues. A simple exchange of letters that identify the motions to be filed is not su icient. Failure to meet and confer in good faith may result in a summary denial of the motion.
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Page 7
Adjournment & Extension Requirements
Continuances will not be granted because of witnesses who do not appear timely (trial proceeds without them), though the Court may accommodate scheduling needs of expert, professional, or out-of-state witnesses where circumstances warrant.
If witnesses are not under subpoena and do not appear timely, trial will proceed without them. Continuances will not be granted due to witnesses who do not appear timely. If possible, the Court will try to accommodate the scheduling needs of expert witnesses, professionals, out-of-state witnesses, or others if the circumstances warrant.
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Page 8 | 5. Witnesses
Continuances are not granted for witnesses who fail to appear timely.
Continuances will not be granted due to witnesses who do not appear timely.
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Page 8
Chambers Communication Rules
Department 78 chambers email address is SMCDEPT78@lacourt.org.
EMAIL: SMCDEPT78@lacourt.org
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Page 1 | Courtroom Information
Department 78 chambers can be reached by phone at (213) 830-0878 during courtroom hours of 8:30 a.m. to 12 noon and 1:30 p.m. to 4:30 p.m.
JUDICIAL ASSISTANT: Diana Castro-Martinez TELEPHONE NUMBER: (213) 830-0878 COURTROOM ASSISTANT: Angela Comick TELEPHONE NUMBER: (213) 830-0878 EMAIL: SMCDEPT78@lacourt.org COURTROOM HOURS: 8:30 a.m. to 12 noon and 1:30 p.m. to 4:30 p.m.
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Page 1 | Courtroom Information
After filing the joint statement, the moving/propounding party should reserve the IDC by calling Department 78's staff.
Thereafter, the moving/propounding party should reserve an IDC by calling Dept. 78's sta .
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Page 3 | F. LAW AND MOTION - 5. Motions to Compel Further Responses to Discovery
Department 78 chambers phone contact: (213) 830-0878, available during courtroom hours 8:30 AM-12 PM and 1:30 PM-4:30 PM.
TELEPHONE NUMBER: (213) 830-0878 COURTROOM HOURS: 8:30 a.m. to 12 noon and 1:30 p.m. to 4:30 p.m.
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Department 78 chambers contact details: Judicial Assistant Diana Castro-Martinez and Courtroom Assistant Angela Comick at (213) 830-0878, email SMCDEPT78@lacourt.org, hours 8:30 AM-12 PM and 1:30 PM-4:30 PM.
JUDICIAL ASSISTANT: Diana Castro-Martinez TELEPHONE NUMBER: (213) 830-0878 COURTROOM ASSISTANT: Angela Comick TELEPHONE NUMBER: (213) 830-0878 EMAIL: SMCDEPT78@lacourt.org COURTROOM HOURS: 8:30 a.m. to 12 noon and 1:30 p.m. to 4:30 p.m.
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