Judge Brock T. Hammond
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Reply
- On Day Reply Is Due
Summary Judgment Motions, Summary Adjudication Motions, Anti SLAPP Motions
- Within One Court Day Of Electronic Filing
Voir Dire Question Request
- 1 copy • Hand Delivery • At Fsc
Communication
Chambers
Page & Word Limits2 rules
The quote is in the court's document. The summary is not checked yet.Mandatory?
At least seven court days prior to the IDC, the moving party should file and serve a memorandum no longer than two pages setting forth the outstanding issues. The responding party may file and serve a responsive memorandum of no more than two pages at least four court days prior to the IDC.
Summary: The moving party's IDC memorandum is limited to 2 pages (filed and served at least 7 court days before the IDC) and the responding party's responsive memorandum is limited to 2 pages (filed and served at least 4 court days before the IDC).
Idc Memorandum
2 pages
Responsive Idc Memorandum
2 pages
The quote is in the court's document. The summary is not checked yet.Mandatory?
Except in extraordinary cases, trial briefs should not exceed fifteen pages in length.
Summary: Trial briefs should not exceed 15 pages except in extraordinary cases.
Trial Brief
15 pages
Document Format Requirements23 rules
The quote is in the court's document. The summary is not checked yet.Mandatory?
The courtesy copies must comply with CRC, rule 3.1110(f), which requires that each exhibit be separated by a tab extending below the bottom of the page bearing the exhibit designation. Failure to comply with this rule may result in the Court continuing the hearing or not considering the exhibits.
Summary: Courtesy copies must comply with CRC 3.1110(f): each exhibit must be separated by a tab extending below the bottom of the page bearing the exhibit designation, and noncompliance may result in the hearing being continued or the exhibits not being considered.
The quote is in the court's document. The summary is not checked yet.Mandatory?
PowerPoint presentations or other displays to the jury must be reduced to paper to be filed in the Court's docket.
Summary: PowerPoint presentations and other displays to the jury must be reduced to paper and filed in the Court's docket.
Paper
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. (Local Rules, rule 3.174.)
Summary: Final jury instructions and verdict forms must be in a jury-ready format containing no citations to authority, no identification of the requesting party, and no letterhead or markings identifying the preparing attorney.
The quote is in the court's document. The summary is not checked yet.Mandatory?
The instructions should be in Word, Times New Roman, 14 point font.
Summary: Jury instructions must be in Word format using Times New Roman 14-point font.
DOCX
The quote is in the court's document. The summary is not checked yet.Mandatory?
Each instruction should be on its own page or pages.
Summary: Each jury instruction must begin on its own page or pages.
The quote is in the court's document. The summary is not checked yet.Mandatory?
Do not include any headers or footers, except for page numbers.
Summary: Jury instructions must not include headers or footers, except that page numbers are permitted.
The quote is in the court's document. The summary is not checked yet.Mandatory?
Do not include a "tear-away" box at the top of the page or the title of the document in the footer. The footer may include page numbers.
Summary: Jury instructions must not include a tear-away box at the top of the page or the document title in the footer; the footer may only include page numbers.
The quote is in the court's document. The summary is not checked yet.Mandatory?
final (or close to final verdict form). The documents shall be in Word, 14 point font.
Summary: Proposed jury instruction documents and the verdict form must be submitted in Word format with 14 point font.
DOCX
The quote is in the court's document. The summary is not checked yet.Mandatory?
Behind Tab B, the parties shall separate each motion in limine with a side tabbed number that corresponds to the number of the motion in limine. The motion, opposition, and reply shall be separated by a colored sheet of paper. The plaintiff's motions in limine shall come first and the defendant's motions in limine shall follow. For the defendant's motions in limine, the numbered side tabs shall start over with the number one, indicating the start of the defendant's motions in limine.
Summary: In the FSC notebook behind Tab B, each motion in limine must be separated by a numbered side tab matching the motion number, motion/opposition/reply separated by colored sheets, plaintiff's MILs placed first, and defendant's side tabs restart at one.
The quote is in the court's document. The summary is not checked yet.Mandatory?
The List of Proposed Jury Instructions must be prepared in the index format required by CRC, rule 2.1055(b)(3), including a checklist for the Court to indicate the disposition of the proposed instructions.
Summary: The List of Proposed Jury Instructions must be prepared in the index format required by CRC rule 2.1055(b)(3), including a checklist for the Court to indicate the disposition of each proposed instruction.
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties shall organize proposed jury instructions into groups in the following order (labeled by cover sheets): (1) the agreed-upon instructions; (2) plaintiff's requested instructions to which defendant objects. Defendant is to highlight the objectionable portions of the proposed instruction; and (3) defendant's requested instructions to which plaintiff objects. Plaintiff is to highlight the objectionable portion of the proposed instruction.
Summary: Proposed jury instructions must be organized into three cover-sheet-labeled groups: agreed-upon instructions; plaintiff's requested instructions with defendant highlighting objections; and defendant's requested instructions with plaintiff highlighting objections.
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties shall attach copies of the pages of the transcripts of the deposition or former testimony they are designating or counter-designating to the Joint Chart of Page and Line Designations for Deposition and Former Testimony, with numbered tabs separating each deposition or trial transcript. Each designation or counter-designation shall be highlighted, with each party using a different color highlighter.
Summary: The Joint Chart must attach copies of designated or counter-designated transcript pages separated by numbered tabs, with each designation highlighted and each party using a different color highlighter.
The quote is in the court's document. The summary is not checked yet.Mandatory?
Copies of documentary exhibits shall be one-sided copies.
Summary: Documentary exhibits must be one-sided copies.
The quote is in the court's document. The summary is not checked yet.Mandatory?
The Court will review the form at the FSC and if it is not ready, the case may be continued. The parties shall email to the judicial assistant the agreed upon or contested verdict form (whether general or special) in Word.
Summary: The agreed upon or contested verdict form must be emailed to the judicial assistant in Word format, and the case may be continued if the form is not ready at the FSC.
DOCX
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties shall work together jointly to prepare three sets of tabbed, internally paginated and properly marked exhibits, organized numerically in three-ring binders for the Court (a set for the Court, a set for the Judicial Assistant, and a set for the witnesses) ("Exhibit Binders")
Summary: Parties must jointly prepare three sets of tabbed, internally paginated, properly marked exhibits organized numerically in three-ring binders (for the Court, Judicial Assistant, and witnesses); if notebooks for each side are included, the number increases to five or more depending on the number of parties.
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 or a picture behind the corresponding numerical tab in the Exhibit Binders.
Summary: Non-documentary exhibits must be marked and a simple written description or picture inserted behind the corresponding numerical tab in the Exhibit Binders.
The quote is in the court's document. The summary is not checked yet.Important?
If certain portions of the instruction are the subject of dispute as opposed to the instruction generally, the portion that is the subject of dispute should be highlighted.
Summary: When only certain portions of a jury instruction are disputed, the disputed portions must be highlighted.
The quote is in the court's document. The summary is not checked yet.Important?
consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder (no larger than three inches)
Summary: The FSC Trial Notebook must consist of one-sided, conformed copies, tabbed and organized in a three-ring binder no larger than three inches.
The quote is in the court's document. The summary is not checked yet.Important?
If the motions in limine are voluminous, the parties shall submit a separate motion in limine notebook, labeled accordingly, that follows the same internal format as described above.
Summary: If the motions in limine are voluminous, parties must submit a separate labeled motion in limine notebook following the same internal format.
The quote is in the court's document. The summary is not checked yet.Important?
Each party should select a block of exhibit numbers. For example, plaintiff may take exhibits numbers 1-200 and defendant may take exhibit numbers 201-400. Documents consisting of more than one page should be internally paginated and sequentially marked (e.g., 1-1; 1-2; 1-3). For ease of reference, the exhibits should follow a rational order that tracks the witnesses to be called.
Summary: Each party should use a separate block of exhibit numbers, multi-page exhibits should be internally paginated and sequentially marked, and exhibits should follow a rational order tracking the witnesses to be called.
The quote is in the court's document. The summary is not checked yet.Important?
"Special jury instructions, meaning instructions from other sources, those specially prepared by the party, or approved instructions that have been substantially modified by the party," must be numbered consecutively. (CRC, rule 2.1055(b)(3).)
Summary: Special jury instructions (from other sources, specially prepared, or substantially modified) must be numbered consecutively per CRC rule 2.1055(b)(3).
The quote is in the court's document. The summary is not checked yet.Important?
CRC, rule 2.1055 governs the form in which the jury instructions must be prepared.
Summary: CRC rule 2.1055 governs the form in which proposed jury instructions must be prepared.
The quote is in the court's document. The summary is not checked yet.Important?
The jury instructions should not have a "tear-away" box at the top of the page. The jury instruction should be in the format that will be sent to the jury.
Summary: Jury instructions should not include a tear-away box at the top of the page and should be in the format that will be sent to the jury.
Document Filing Requirements51 rules
The quote is in the court's document. The summary is not checked yet.Mandatory?
Evidentiary objections. Counsel filing evidentiary objections in connection with a motion for summary judgment or summary adjudication shall comply with CRC, rule 3.1354.
Summary: Evidentiary objections filed in connection with a motion for summary judgment or summary adjudication must comply with CRC, rule 3.1354.
Document Type
Evidentiary Objections
The quote is in the court's document. The summary is not checked yet.Mandatory?
For trials in which there is no court reporter or electronic recording, counsel are required to provide the court with daily summaries of testimony.
Summary: In trials without a court reporter or electronic recording, counsel must provide the court with daily summaries of testimony.
Document Type
Daily Summaries Of Testimony
The quote is in the court's document. The summary is not checked yet.Mandatory?
The proponent of the recording must bring their transcripts to the FSC so the Court may rule on any objections to the transcripts.
Summary: The proponent of a recording must bring the transcript to the Final Status Conference so the Court can rule on any objections.
Document Type
Recording Transcript
The quote is in the court's document. The summary is not checked yet.Mandatory?
Counsel is responsible for bringing copies of the transcript to pass out for the jury and alternates.
Summary: Counsel must bring copies of recording transcripts to distribute to the jury and alternates.
Document Type
Recording Transcript
The quote is in the court's document. The summary is not checked yet.Mandatory?
California Rules of Court (“CRC”), rule 2.1040 requires the parties to prepare transcripts of all recordings counsel plan to introduce as an exhibit.
Summary: Parties must prepare transcripts of all recordings they plan to introduce as exhibits, per CRC rule 2.1040.
Document Type
Recording Transcript
The quote is in the court's document. The summary is not checked yet.Mandatory?
Each morning, counsel must give the clerk a written list of witnesses to be called that day, their full names with correct spellings, and the order in which they will be called.
Summary: Counsel must deliver a written witness list to the clerk each morning listing that day's witnesses with their full correct names and the order in which they will be called.
Document Type
Witness List
The quote is in the court's document. The summary is not checked yet.Mandatory?
The Court strongly encourages the parties to arrange for a court reporter for trial. If no court reporter is used, the parties must jointly prepare a summary of the day's proceedings, including a detailed summary of any witness testimony, and lodge the daily summary the next morning before proceedings resume.
Summary: If no court reporter is used at trial, the parties must jointly prepare a daily proceedings summary including detailed witness testimony and lodge it the next morning before proceedings resume.
Document Type
Daily Proceedings Summary
The quote is in the court's document. The summary is not checked yet.Mandatory?
Plaintiff and defendant shall serve verifications with the documents they produce.
Summary: Both plaintiff and defendant must serve verifications together with the documents they produce in discovery.
Document Type
Document Production
The quote is in the court's document. The summary is not checked yet.Mandatory?
The CACI Number and Title should be at the top of each instruction.
Summary: Each jury instruction must display the CACI number and title at the top of the instruction.
Document Type
Jury Instructions
The quote is in the court's document. The summary is not checked yet.Mandatory?
Counsel are to fill in the blanks and to remove unnecessary brackets in the CACI instructions.
Summary: Counsel must fill in the blanks and remove unnecessary brackets in CACI instructions before submitting them.
Document Type
Jury Instructions
The quote is in the court's document. The summary is not checked yet.Mandatory?
For Non-CACI instructions, the proposed instructions must contain case citations that support the party's request for inclusion of the instruction.
Summary: Proposed Non-CACI jury instructions must include case citations supporting the request for their inclusion.
Document Type
Non Caci Proposed Jury Instructions
The quote is in the court's document. The summary is not checked yet.Mandatory?
If counsel cannot secure the participation of another party/counsel in the meet and confer discussions, counsel must (1) file a declaration detailing the efforts taken to initiate meet and confer discussions, and (2) file a separate set of Trial Readiness Documents and Trial Exhibits.
Summary: If counsel cannot secure another party's participation in the meet and confer, counsel must file a declaration detailing the efforts taken to initiate meet and confer discussions.
Document Type
Meet And Confer Declaration
The quote is in the court's document. The summary is not checked yet.Mandatory?
with a table of contents that includes the following: Section A: Trial Briefs Section B: Motions in Limine Section C: Joint Statement of the Case
Summary: The FSC Trial Notebook must include a table of contents with Section A (Trial Briefs), Section B (Motions in Limine), and Section C (Joint Statement of the Case).
Document Type
Fsc Trial Notebook
The quote is in the court's document. The summary is not checked yet.Mandatory?
Each party must file a trial brief, or the parties may file a joint trial brief if they wish.
Summary: Each party must file a trial brief, unless the parties instead file a joint trial brief.
Document Type
Trial Brief
The quote is in the court's document. The summary is not checked yet.Mandatory?
Motions in limine may not be used as substitutes for statutorily authorized dispositive motions. (Amtower v. Photon Dynamics, Inc. (2008) 158 Cal.App.4th 1582, 1594.) A motion in limine must identify the specific evidence to which it is directed. Form or boilerplate motions in limine are strongly discouraged.
Summary: Motions in limine must identify the specific evidence targeted, may not substitute for statutorily authorized dispositive motions, and boilerplate forms are strongly discouraged.
Document Type
Motion In Limine
The quote is in the court's document. The summary is not checked yet.Mandatory?
Whether jointly filed by multiple parties, or separately filed by individual parties, the trial brief must include: (1) A brief description of the claims and defenses to be presented at trial; (2) A brief discussion of the major legal issues supported by relevant authority; (3) A brief discussion of any major evidentiary issues supported by relevant authority; (4) A detailed statement of the relief sought, including a breakdown of the damages, if any; (5) A brief discussion of any other information that may assist the Court at trial.
Summary: Trial briefs (joint or separate) must include five elements: description of claims/defenses, major legal issues with authority, major evidentiary issues with authority, detailed relief sought with damages breakdown, and other helpful information.
Document Type
Trial Brief
The quote is in the court's document. The summary is not checked yet.Mandatory?
The caption of each motion in limine shall identify concisely the evidence 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.Mandatory?
Counsel shall cooperate in the preparation of a joint list of all witnesses each party intends to call (excluding impeachment and rebuttal witnesses). (Local Rules, rule 3.25(g)(5).) The joint witness list shall identify each witness by name, specify which witnesses are experts, identify which
Summary: Counsel must jointly prepare a witness list of all intended trial witnesses (excluding impeachment and rebuttal), identifying each witness by name and expert status.
Document Type
Joint Witness List
The quote is in the court's document. The summary is not checked yet.Mandatory?
For jury trials, the parties shall prepare and file a joint written statement of the case for the Court to read to the jury. (Local Rules, rule 3.25(g)(4).) The purpose of the joint statement is to inform prospective jurors of the identities of the parties and the general subject matter of the trial; as such, it should be brief and should not be argumentative. If, after efforts to meet and confer, the parties cannot agree on a written joint statement, each party shall file a separate statement of the case.
Summary: In jury trials the parties must file a joint written statement of the case (brief and non-argumentative) for the court to read to the jury, or separate statements if they cannot agree after meet and confer.
Document Type
Joint Statement Of The Case
The quote is in the court's document. The summary is not checked yet.Mandatory?
The joint witness list must also include time estimates for any witness whose testimony is intended to be presented by playing video deposition excerpts or by reading transcripts of depositions or former testimony. All time estimates must comply with Local Rules, rule 3.25(h), which requires counsel to provide the Court with reasonable and accurate time estimates. The list must also provide a calculation of the total estimated time for the examination of all listed witnesses (i.e., a grand total).
Summary: The joint witness list must include time estimates for witnesses presented via video deposition excerpts or transcript reading, comply with Local Rule 3.25(h)'s reasonable and accurate estimate requirement, and provide a grand total of estimated examination time.
Document Type
Joint Witness List
The quote is in the court's document. The summary is not checked yet.Mandatory?
The list must identify potential witness scheduling issues and special requirements, including whether any interpreters will be necessary and whether any ADA accommodation is anticipated. The list must identify whether the witness will testify remotely. A witness who is being called as expert must be identified as an expert. Counsel should include only those witnesses who are going to be called.
Summary: The joint witness list must identify scheduling issues, special requirements (interpreters, ADA accommodations), remote-testimony status, and expert witnesses, and should include only witnesses who will actually be called.
Document Type
Joint Witness List
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties shall prepare and file a joint exhibit list organized with columns identifying each exhibit and specifying each party's evidentiary objections, if any, to the admission of each exhibit.
Summary: The parties must prepare and file a joint exhibit list with columns identifying each exhibit and stating each party's evidentiary objections.
Document Type
Joint Exhibit List
The quote is in the court's document. The summary is not checked yet.Mandatory?
Any witness who is not included on the joint witness list is subject to exclusion other than for purposes of giving actual impeachment or rebuttal testimony. If a party includes a witness on the list and the opposing party similarly wants the witness to be called, both parties must ensure the witness’s attendance in case the original designating party decides not to call the witness. Any party who seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause.
Summary: Witnesses not on the joint witness list are excluded except for impeachment or rebuttal testimony, both parties must ensure attendance of a mutually desired listed witness, and eliciting testimony from an unlisted witness requires a prior showing of good cause.
Document Type
Joint Witness List
The quote is in the court's document. The summary is not checked yet.Mandatory?
Transcripts: California Rules of Court (“CRC”), rule 2.1040 requires the parties to prepare transcripts of all audio recordings.
Summary: Under CRC rule 2.1040, the parties must prepare transcripts of all audio recordings.
Document Type
Transcripts Of Audio Recordings
The quote is in the court's document. The summary is not checked yet.Mandatory?
Objections not stated in writing on the exhibit list shall be deemed waived except upon a showing of good cause.
Summary: Evidentiary objections not stated in writing on the joint exhibit list are deemed waived unless the party shows good cause.
Document Type
Joint Exhibit List
The quote is in the court's document. The summary is not checked yet.Mandatory?
Demonstrative evidence, blow-ups, and transcripts must be marked for identification and included on the exhibit list.
Summary: Demonstrative evidence, blow-ups, and transcripts must be marked for identification and included on the joint exhibit list.
Document Type
Exhibits
The quote is in the court's document. The summary is not checked yet.Mandatory?
A failure to file a timely exhibit list may result in the Court prohibiting the use of exhibits at trial. (Local Rules, rule 3.25(g)(3).)
Summary: Failure to file a timely joint exhibit list may result in the Court prohibiting use of exhibits at trial, per Local Rule 3.25(g)(3).
Document Type
Joint Exhibit List
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties must meet and confer regarding the contents of any such transcripts prior to the FSC to resolve any objections. The proponent of the transcript must bring a copy of the transcripts to the FSC so the Court may rule on any objections.
Summary: The parties must meet and confer on transcript contents before the FSC to resolve objections, and the transcript proponent must bring copies to the FSC so the Court can rule on objections.
Document Type
Transcripts Of Audio Recordings
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties shall prepare and file jointly a list of proposed jury instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any.
Summary: Parties must jointly prepare and file a list of proposed jury instructions organized in numerical order that identifies the agreed-upon and contested instructions.
Document Type
Joint List Of Proposed Jury Instructions
The quote is in the court's document. The summary is not checked yet.Mandatory?
For jury trials, the parties shall work together to prepare a complete set of full-text proposed jury instructions, editing all proposed CACI instructions, inserting party names, and eliminating blanks and other irrelevant or inapplicable material.
Summary: For jury trials, parties must jointly prepare a complete set of full-text proposed jury instructions, editing all CACI instructions, inserting party names, and eliminating blanks and inapplicable material.
Document Type
Full Text Proposed Jury Instructions
The quote is in the court's document. The summary is not checked yet.Mandatory?
If the parties intend to use deposition testimony or former trial testimony in lieu of or in addition to a witness's live testimony, the parties shall meet and confer to discuss, and work together to prepare and file, a joint chart in the format set forth below ("Joint Chart of Page and Line Designations for Deposition and Former Testimony").
Summary: If deposition or former trial testimony will be used in lieu of or in addition to live testimony, the parties must meet and confer and jointly prepare and file a Joint Chart of Page and Line Designations for Deposition and Former Testimony.
Document Type
Joint Chart Of Page And Line Designations
The quote is in the court's document. The summary is not checked yet.Mandatory?
In addition to preparing a chart of designations and counter-designations, counsel must ensure that the joint witness list (described above) includes time estimates for each witness who will be presented through prior testimony.
Summary: The joint witness list must include time estimates for each witness who will be presented through prior testimony.
Document Type
Joint Witness List
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties must submit conformed copies of the operative pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint.)
Summary: Parties must submit conformed copies of the operative pleadings, including the operative complaint, answer, and any cross-complaints and answers thereto.
Document Type
Operative Pleadings
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties shall prepare and jointly file a proposed general verdict form or special verdict form (with interrogatories) acceptable to all sides. (Local Rules, 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.
Summary: Parties must jointly file a proposed general or special verdict form acceptable to all sides, or each party must separately file a proposed verdict form if they cannot agree.
Document Type
Verdict Form
The quote is in the court's document. The summary is not checked yet.Important?
Department 407 has a CACI Jury Instruction Order that directs counsel to organize the CACI jury instruction in a logical sequence. Counsel and self-represented litigants should review this Order prior to the FSC and prepare their jury instructions in compliance with the Order.
Summary: CACI jury instructions must be organized in a logical sequence and prepared in compliance with the Department 407 CACI Jury Instruction Order, which should be reviewed before the Final Status Conference.
Document Type
Jury Instructions
The quote is in the court's document. The summary is not checked yet.Important?
Department 407 has a Final Status Conference Order that is filed in every case set for trial. A copy of the Order is attached. The Court expects counsel and self-represented litigants to work together to prepare and submit jointly the binders required by the Order.
Summary: In every case set for trial, counsel and self-represented litigants are expected to work together to jointly prepare and submit the binders required by the Final Status Conference Order.
Document Type
Final Status Conference Binders
The quote is in the court's document. The summary is not checked yet.Important?
Counsel should prepare the instructions jointly and in compliance with the court’s FSC Order.
Summary: Counsel must jointly prepare the jury instructions in compliance with the court's Final Status Conference Order.
Document Type
Jury Instructions
The quote is in the court's document. The summary is not checked yet.Important?
The sequence of instructions is identified below. The index/list of instructions and the instructions themselves should follow this sequence. Of course, instructions are to be included or excluded as appropriate for each case.
Summary: The index/list of jury instructions and the instructions themselves must follow the sequence identified in the court's order, with instructions included or excluded as appropriate for each case.
Document Type
Jury Instructions
The quote is in the court's document. The summary is not checked yet.Important?
Agreed upon instructions should be included in the face-sheet index.
Summary: Agreed-upon jury instructions must be listed in the face-sheet index.
Document Type
Jury Instructions
The quote is in the court's document. The summary is not checked yet.Important?
Instructions that are not agreed upon should be listed on a separate instruction face-sheet index along with the specific instructions that are the subject of disagreement.
Summary: Disputed jury instructions must be listed on a separate face-sheet index identifying the specific instructions in dispute.
Document Type
Jury Instructions
The quote is in the court's document. The summary is not checked yet.Important?
The parties are to label the face and the spine of the Notebook with the case name, case number, FSC hearing date and Trial date.
Summary: Parties must label the face and spine of the FSC Notebook with the case name, case number, FSC hearing date, and trial date.
Document Type
FSC Notebook
The quote is in the court's document. The summary is not checked yet.Important?
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?
Parties filing more than one motion in limine shall number them 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?
Plaintiff’s witnesses shall be listed first and preferably in the order in which they will be called. Defendant’s witnesses shall follow and, similarly, in the order in which they will be called.
Summary: Plaintiff's witnesses must be listed first on the joint witness list, followed by defendant's witnesses, each preferably in the order they will be called.
Document Type
Joint Witness List
The quote is in the court's document. The summary is not checked yet.Important?
confer to resolve objections to the admissibility of each exhibit. Do not wait until the last minute to discuss the exhibits. By discussing the exhibits early on, the parties may be able to eliminate the need to call unnecessary witnesses, such as foundational witnesses (i.e., custodians of record).
Summary: The parties must confer to resolve objections to each exhibit's admissibility and should discuss exhibits early rather than waiting until the last minute, which may eliminate the need for foundational witnesses.
Document Type
Joint Exhibit List
Filing & Service rules
Electronic Filing Rules
Parties must arrange with the judicial assistant to email the proposed jury instructions to the Court in Word format.
The parties shall arrange with the judicial assistant to e-mail the instructions in Word format to the Court.
The quote is in the court's document. The summary is not checked yet.
Page 30 | G. Full Text Jury Instructions (Joint and Contested)
Filing Timing and Cure Windows
Daily summaries of testimony must be completed and submitted to the court by 4 p.m. the day following the day of testimony.
Daily summaries must be completed and submitted to the court by 4 pm the day following day.
The quote is in the court's document. The summary is not checked yet.
Page 4 | J. COURTROOM OPERATIONS
All Trial Readiness Documents must be filed and served no later than 7 court days before the FSC.
the Court orders that all Trial Readiness Documents addressed herein shall be filed and served no later than seven (7) court days before the FSC
The quote is in the court's document. The summary is not checked yet.
Page 24 | III. TRIAL READINESS DOCUMENTS TO BE FILED
The parties must jointly prepare and lodge an FSC Trial Notebook in Department 407 no later than 5 court days before the FSC.
No later than five (5) court days before the FSC, the parties shall jointly prepare and lodge in Department 407 an "FSC Trial Notebook," consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder (no larger than three inches) with a table of contents that includes the following:
The quote is in the court's document. The summary is not checked yet.
Page 24 | III. TRIAL READINESS DOCUMENTS TO BE FILED
Motions in limine must comply with the notice provisions of CCP Section 1005 and Local Rule 3.57(a), and noncompliance may result in denial of the motion or a continuance of the FSC and/or trial.
Code of Civil Procedure Section 1005 and the motion requirements of Local Rules, rule 3.57(a). A failure to comply with applicable notice provisions and deadlines may result in denial of the motion, or the Court may continue the FSC and/or the trial in order to consider the motions in limine before trial begins. Depending on the volume and circumstances, the Court may not rule on the motions in limine until the first day of trial.
The quote is in the court's document. The summary is not checked yet.
Page 26 | B. Motions in Limine
One set of Exhibit Binders must be delivered to the Court along with the FSC Notebook at least five court days before the FSC for the Court to review.
The parties shall deliver one set of the Exhibit Binders to the Court along with FSC Notebook at least five court days before the FSC for the Court to review.
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Page 32 | IV. EXHIBIT BINDER(S)
Parties who want the Court to ask specific voir dire questions must file the request, along with the specific questions, at least five court days before the FSC and may not wait until the morning of trial.
However, if any party has specific voir dire questions for the prospective jurors that you would like the Court to ask, file the request, along with the specific questions, at least five court days in advance of the FSC and bring a copy of the filing to the FSC. Do not wait until the morning of trial to submit specific requests.
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Page 33 | V. VOIR DIRE
Scheduling an IDC does not extend the deadline to file a motion to compel further responses to discovery, and the parties are urged to stipulate to an extension.
Note: Scheduling an IDC does not extend the time to file a motion to compel further responses to discovery. The parties are urged to reach a stipulation to do so.
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Page 3 | F. INFORMAL DISCOVERY CONFERENCES
Service and Proof of Service Rules
PowerPoint slides must be shared with opposing counsel in advance of opening or closing with sufficient time to raise issues with the Court before the presentation.
All PowerPoint slides shall be shared in advance of opening or closing in sufficient time to allow opposing counsel to raise issues with the Court before the presentation.
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Page 8 | C. OPENING STATEMENTS
Within 30 days of the CMC order, both plaintiff and defendant must provide copies of specified case documents (purchase/lease contracts, repair orders and invoices, rental or loaner agreements, communications records, warranty claims, and warranty policy manuals) to the opposing side.
Production of Documents: Within 30 days of this order both plaintiff and defendant shall provide copies of the following documents, which are in their respective possession, custody and/or control, to the opposing side(s):
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Page 14 | Production of Documents
Parties must exchange all exhibits they intend to introduce at trial no later than 21 days before the FSC.
No later than 21 days before the FSC, the parties shall exchange all exhibits they intend to introduce at trial.
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Page 24 | FINAL STATUS CONFERENCE ORDER
Discovery information produced under this Order may, at the producing party's option, be provided to the opposing party in electronic form as a PDF.
The information to be disclosed pursuant to this Order may be provided to the opposing party in electronic form as a PDF at the option of the producing party
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Page 15 | Document Production / Protective Order
Courtesy Copy Requirements
For summary judgment/adjudication and Anti-SLAPP motions, courtesy copies of reply briefs must be delivered on the day the reply is due.
For these motions, courtesy copies must be delivered within one court day of the electronic filing, except for reply briefs which must be delivered on the day the reply is due.
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Page 3 | E. LAW AND MOTION
Courtesy copies for motions for summary judgment/adjudication and Anti-SLAPP motions must be delivered within one court day of electronic filing, and are not required for other electronically filed motions.
judgment/adjudication and Anti-SLAPP motions. For these motions, courtesy copies must be delivered within one court day of the electronic filing, except for reply briefs which must be delivered on the day the reply is due. Courtesy copies are not necessary for other electronically filed motions.
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Page 3 | E. LAW AND MOTION
A copy of the filed voir dire question request must be brought to the FSC.
file the request, along with the specific questions, at least five court days in advance of the FSC and bring a copy of the filing to the FSC.
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Page 33 | V. VOIR DIRE
Sealing & Redaction Procedures
Strict compliance with CRC, rule 2.551 et seq. is required for sealed documents.
Sealed documents. Strict compliance with CRC, rule 2.551 et. seq. is required.
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Page 3 | E. LAW AND MOTION
A party who believes the information disclosed under this Order should be protected must serve and file a proposed protective order within 5 days of the Order, the parties must meet and confer on agreeable language, and the default is the standard LASC Protective Order from its website.
If a party believes any of this information should be subject to a protective order, that party shall serve and file a proposed protective order within 5 days of this Order and the parties shall meet and confer as to agreeable language for the same. The default will be the standard Protective Order provided by the LASC in its website.
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Page 15 | Document Production / Protective Order
The customer complaint list must include the VIN, repair visit date, reporting location, and complaint text, but must exclude other customers' names, addresses, phone numbers, e-mail addresses, and any other personal identifying information.
The list provided by Defendant may be in a chart or spreadsheet format, and shall include the VIN, date of repair visit, dealership or other reporting location, and text of the other customers' reported complaint, but shall not include the other customers' names, addresses, phone numbers, e-mail addresses, or other personal identifying information.
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Page 15 | Document Production, Subparagraph (h)
Pre-Motion Conference Requirements
Counsel must meet and confer with opposing counsel about the subject of each contemplated motion in limine before filing it.
Local Rules, rule 3.57(a)(2) requires that counsel meet and confer with their opposing counsel regarding the subject of each contemplated motion in limine before filing.
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Page 25 | B. Motions in Limine
An informal discovery conference (IDC) is not required before filing a motion to compel further responses but is strongly encouraged, and the court strongly discourages discovery motions.
The court strongly discourages discovery motions and encourages informal resolution of discovery disputes. To this end, while the Court does not require an informal discovery conference (“IDC”) prior to the filing a motion to compel further responses, IDCs are strongly encouraged.
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Page 3 | F. INFORMAL DISCOVERY CONFERENCES
Before scheduling an IDC, counsel with authority to compromise the dispute should meet and confer by telephone, videoconference, or in person and make a good faith attempt to resolve the dispute; if unresolved, moving counsel should contact the judicial assistant to schedule the IDC.
Prior to scheduling an IDC, counsel with authority to compromise the dispute should meet and confer by telephone, videoconference or in person and make a good faith attempt to resolve the discovery dispute without the assistance of the Court. If the dispute cannot be resolved, moving counsel should contact the judicial assistant to schedule an IDC.
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Page 3 | F. INFORMAL DISCOVERY CONFERENCES
Chambers Communication Rules
To schedule an IDC, the parties should stipulate to three possible dates and e-mail them to the judicial assistant at SMCDept407@lacourt.ca.gov; IDC hearings are set Tuesdays through Thursdays at 11:00 a.m. or 1:30 p.m. when the Court is not in trial.
The Court sets IDC hearings on Tuesdays, Wednesdays, and Thursdays at 11:00 a.m. or 1:30 p.m., if the Court is not in trial. The parties should stipulate to three possible dates, contact the judicial assistant and e-mail those dates to SMCDept407@lacourt.ca.gov.
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Page 3 | F. INFORMAL DISCOVERY CONFERENCES