Judge Daniel S. Murphy
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Courtesy Copies
All filings
- 1 copy • Chambers Drop Off • Within 5 Court Days Of Filing
Motion, Brief
- 1 copy • Hand Delivery • Within 5 Court Days
Opposition
- 1 copy
- 1 copy • Upon Filing
Communication
Phone
Clerk
Phone
Chambers
Document Format Requirements1 rule
The quote is in the court's document. The summary is not checked yet.Mandatory?
If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3, etc.
Summary: Multi-page exhibits must have internally numbered pages corresponding to the exhibit number (e.g., 3.1, 3.2, 3.3).
Document Filing Requirements21 rules
The quote is in the court's document. The summary is not checked yet.Mandatory?
For an informal discovery conference, counsel shall file a stipulation and proposed order which sets forth dates that counsel would be available for the informal discovery conference.
Summary: Counsel must file a stipulation and proposed order setting forth available dates to obtain an informal discovery conference.
Document Type
Stipulation And Proposed Order
The quote is in the court's document. The summary is not checked yet.Mandatory?
JOINT EXHIBIT LIST. All exhibits must be listed on one list, identified by a number and brief description. Notebooks containing all exhibits must be available on the final status conference date and all parties must be prepared to tell the court that they have had the opportunity to review all documents in the exhibit book.
Summary: For jury trials, all exhibits must be listed on a single numbered joint exhibit list with brief descriptions, and exhibit notebooks must be available at the final status conference with all parties prepared to confirm they reviewed the exhibit book.
Document Type
Joint Exhibit List
The quote is in the court's document. The summary is not checked yet.Mandatory?
Counsel filing evidentiary objections in connection with a motion for summary judgment or summary adjudication should comply with California Rules of Court Rule 3.1354. Please note an evidentiary objection must specifically identify the document in which the objectionable material is located and quote or set forth the objectionable statement or material. Counsel should not object to a “statement” contained in opposing party’s statement of undisputed material facts; rather the objection must be directed to the evidence in support of that fact and state the basis for the objection.
Summary: Evidentiary objections must comply with CRC 3.1354, specifically identify and quote the objectionable material, be directed to the supporting evidence (not the undisputed fact statements), and state the basis for the objection.
Document Type
Evidentiary Objection
The quote is in the court's document. The summary is not checked yet.Mandatory?
Submit a joint set of CACI instructions with all information filled in, no remaining brackets or blanks. Do not use tear sheets for the instructions and do not include the disposition box on the page of the individual instruction. If some instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction. Submit a disposition table which lists all jury instructions by number, the identity of the party or parties proposing the instruction, and which contains columns for the court to indicate whether the instruction is given, modified, withdrawn or refused.
Summary: Parties must submit a joint, fully completed set of CACI instructions (no brackets, blanks, tear sheets, or disposition boxes), separate sets for disputed instructions identifying proposer and opponent, and a disposition table listing all instructions with columns for the court's rulings.
Document Type
Jury Instructions
The quote is in the court's document. The summary is not checked yet.Mandatory?
All witnesses must be listed on one list. Do not repeat the name of a witness who will be called by more than one party. Next to each witness, indicate the total time expected for that testimony (including direct, cross, redirect, etc.) At the end of the list, total the time estimated for testimony.
Summary: The joint witness list must include all witnesses on a single list without duplicated names, with expected testimony time for each witness and a total time estimate at the end.
Document Type
Joint Witness List
The quote is in the court's document. The summary is not checked yet.Mandatory?
If the parties cannot agree on the verdict form, each party must submit a proposed verdict form. Any proposed special verdict should be in a form that is easily used by the jury, and which does not require the jury to answer unnecessary questions.
Summary: If parties cannot agree on a verdict form, each must submit a proposed verdict form, and any special verdict should be easy for the jury to use without unnecessary questions.
Document Type
Proposed Verdict Form
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties must submit a joint exhibit list and joint witness list as described above.
Summary: In court trials, the parties must submit a joint exhibit list and a joint witness list as described in the order.
Document Type
Court Trial Submissions
The quote is in the court's document. The summary is not checked yet.Important?
If you have motions reserved under the Court Reservation System for multiple hearing dates, please submit a proposed order for the motions to be heard on one date. Make sure the motions are reserved on the Court Reservation System before you submit a proposed order.
Summary: Parties with motions reserved for multiple hearing dates must submit a proposed order consolidating them to one date, and the motions must be reserved on CRS before submitting the proposed order.
Document Type
Motion
The quote is in the court's document. The summary is not checked yet.Important?
The court will consider referring the parties to a mandatory settlement conference, if counsel file a stipulation and proposed order seeking a mandatory settlement conference..
Summary: The court will consider referring the parties to a mandatory settlement conference if counsel file a stipulation and proposed order seeking one.
Document Type
Stipulation And Proposed Order
The quote is in the court's document. The summary is not checked yet.Important?
Absent good cause, the total number of hours listed for testimony should not exceed the trial estimate given at the case management conference, including the allocation of 1 day for jury selection and 1 day for deliberations. For example, a 5 day trial estimate means no more than 3 days of testimony.
Summary: Absent good cause, total listed testimony time must not exceed the CMC trial estimate after allocating 1 day for jury selection and 1 day for deliberations (e.g., a 5-day trial estimate allows no more than 3 days of testimony).
Document Type
Joint Witness List
The quote is in the court's document. The summary is not checked yet.Important?
This statement should be a brief, neutral description of the case. In most instances, it should not exceed 2-3 paragraphs.
Summary: The joint short statement to be read to the jury should be a brief, neutral case description not exceeding 2-3 paragraphs in most instances.
Document Type
Joint Statement To Jury
Machine summary. Not checked yet.Mandatory?
For an informal discovery conference, counsel shall file a stipulation and proposed order which sets forth dates that counsel would be available for the informal discovery conference.
Summary: Stipulation and proposed order required to request informal discovery conference.
Document Type
Stipulation
Machine summary. Not checked yet.Mandatory?
Counsel filing evidentiary objections in connection with a motion for summary judgment or summary adjudication should comply with California Rules of Court Rule 3.1354. Please note an evidentiary objection must specifically identify the document in which the objectionable material is located and quote or set forth the objectionable statement or material. Counsel should not object to a “statement” contained in opposing party’s statement of undisputed material facts; rather the objection must be directed to the evidence in support of that fact and state the basis for the objection.
Summary: Evidentiary objections in summary judgment motions must identify document, quote objectionable material, and state basis for objection per CRC 3.1354.
Document Type
Evidentiary Objection
Machine summary. Not checked yet.Mandatory?
4. JOINT SHORT STATEMENT TO BE READ TO THE JURY. This statement should be a brief, neutral description of the case. In most instances, it should not exceed 2-3 paragraphs.
Summary: Joint neutral case statement (2-3 paragraphs) required 5 court days before final status conference for jury trials.
Document Type
Joint Short Statement
Machine summary. Not checked yet.Mandatory?
3. JOINT JURY INSTRUCTIONS. Submit a joint set of CACI instructions with all information filled in, no remaining brackets or blanks. Do not use tear sheets for the instructions and do not include the disposition box on the page of the individual instruction. If some instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction. Submit a disposition table which lists all jury instructions by number, the identity of the party or parties proposing the instruction, and which contains columns for the court to indicate whether the instruction is given, modified, withdrawn or refused.
Summary: Joint CACI jury instructions and disposition table required 5 court days before final status conference for jury trials.
Document Type
Joint Jury Instructions
Machine summary. Not checked yet.Mandatory?
2. JOINT WITNESS LIST. All witnesses must be listed on one list. Do not repeat the name of a witness who will be called by more than one party. Next to each witness, indicate the total time expected for that testimony (including direct, cross, redirect, etc.) At the end of the list, total the time estimated for testimony. Make realistic time estimates. Absent good cause, the total number of hours listed for testimony should not exceed the trial estimate given at the case management conference, including the allocation of 1 day for jury selection and 1 day for deliberations. For example, a 5 day trial estimate means no more than 3 days of testimony.
Summary: Joint witness list with time estimates required 5 court days before final status conference for jury trials.
Document Type
Joint Witness List
Machine summary. Not checked yet.Mandatory?
JURY TRIALS 1. JOINT EXHIBIT LIST. All exhibits must be listed on one list, identified by a number and brief description. Notebooks containing all exhibits must be available on the final status conference date and all parties must be prepared to tell the court that they have had the opportunity to review all documents in the exhibit book. Place the correspond with the exhibit number. If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3, etc. Exhibits should be lodged with the court on the first day of trial.
Summary: Joint exhibit list required 5 court days before final status conference for jury trials.
Document Type
Joint Exhibit List
Machine summary. Not checked yet.Mandatory?
5. JOINT PROPOSED VERDICT FORM. If the parties cannot agree on the verdict form, each party must submit a proposed verdict form. Any proposed special verdict should be in a form that is easily used by the jury, and which does not require the jury to answer unnecessary questions.
Summary: Joint proposed verdict form required 5 court days before final status conference for jury trials.
Document Type
Joint Proposed Verdict Form
Machine summary. Not checked yet.Mandatory?
COURT TRIALS. The parties must submit a joint exhibit list and joint witness list as described above. A trial brief must be served and filed no later than the final status conference.
Summary: Court trials require joint exhibit list, witness list, and trial brief filed by final status conference.
Document Type
Trial Brief
Machine summary. Not checked yet.Important?
If you have motions reserved under the Court Reservation System for multiple hearing dates, please submit a proposed order for the motions to be heard on one date. Make sure the motions are reserved on the Court Reservation System before you submit a proposed order.
Summary: Proposed order required to have multiple motions heard on the same date.
Document Type
Proposed Order
Machine summary. Not checked yet.Note?
The court will consider referring the parties to a mandatory settlement conference, if counsel file a stipulation and proposed order seeking a mandatory settlement conference.
Summary: Stipulation and proposed order required to request mandatory settlement conference.
Document Type
Stipulation
Filing & Service rules
Electronic Filing Rules
Self-represented litigants are exempt from the mandatory electronic filing requirements under CRC 2.253(b)(2).
Pursuant to California Rules of Court, rule 2.253(b)(2), self-represented litigants are exempt from the mandatory Electronic Filing requirements.
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Page 1 | Ex Parte Applications
Represented litigants must electronically file all ex parte applications and supporting documents no later than 10:00 a.m. the court day before the ex parte hearing.
For represented litigants, all Ex parte applications and all documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the ex parte hearing.
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Page 1 | Ex Parte Applications
Represented litigants must electronically file ex parte applications and supporting documents by 10:00 a.m. the court day before the hearing.
For represented litigants, all Ex parte applications and all documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the ex parte hearing.
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Written opposition to ex parte applications must be electronically filed by 8:30 a.m. the day of the hearing.
Any written opposition to an ex parte application shall be electronically filed by 8:30 a.m. the day of the ex parte hearing.
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Self-represented litigants are exempt from mandatory electronic filing requirements per CRC Rule 2.253(b)(2).
Pursuant to California Rules of Court, rule 2.253(b)(2), self-represented litigants are exempt from the mandatory Electronic Filing requirements.
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Filing Timing and Cure Windows
Ex parte applications and supporting papers must be e-filed by a 10:00 a.m. cutoff on the court day before the hearing.
For represented litigants, all Ex parte applications and all documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the ex parte hearing.
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Page 1 | Ex Parte Applications
Written opposition to an ex parte application must be electronically filed by 8:30 a.m. on the day of the ex parte hearing.
Any written opposition to an ex parte application shall be electronically filed by 8:30 a.m. the day of the ex parte hearing.
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Page 1 | Ex Parte Applications
Parties must meet and confer and submit the required trial documents five court days before the final status conference.
The parties must meet and confer and submit the following documents FIVE COURT DAYS BEFORE THE FINAL STATUS CONFERENCE.
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Page 2 | Meet and Confer Required Prior to Final Status Conference
Written oppositions to motions in limine may be served and filed no later than the final status conference.
A written opposition to a motion in limine may be served and filed no later than the final status conference.
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Page 3 | Trial Preparation Order
Motions in limine must be served on the opposing party and submitted to the court five court days before the final status conference.
Motions in limine must be served on the opposing party and submitted to the court five court days prior to the final status conference.
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Page 3 | Trial Preparation Order
In court trials, the trial brief must be served and filed no later than the final status conference.
A trial brief must be served and filed no later than the final status conference.
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Page 4 | Court Trials
Replies to motions in limine are optional but, if served and filed, must be submitted no later than the Friday preceding the trial date.
Replies are not required but may be served and filed no later than the Friday preceding the trial date.
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Page 3 | Trial Preparation Order
Exhibits should be lodged with the court on the first day of trial.
Exhibits should be lodged with the court on the first day of trial.
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Page 3 | Trial Preparation Order
Ex parte opposition must be filed by 8:30 a.m. the day of the hearing.
Any written opposition to an ex parte application shall be electronically filed by 8:30 a.m. the day of the ex parte hearing.
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Ex parte applications and supporting documents must be filed by 10:00 a.m. the court day before the hearing.
For represented litigants, all Ex parte applications and all documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the ex parte hearing.
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Motions in limine must be served and filed 5 court days before final status conference; opposition by FSC, reply by Friday before trial.
6. MOTIONS IN LIMINE. Motions in limine must be served on the opposing party and submitted to the court five court days prior to the final status conference. A written opposition to a motion in limine may be served and filed no later than the final status conference. Replies are not required but may be served and filed no later than the Friday preceding the trial date. The court does not rule on motions in limine until the first day of trial. Motions in limine should not be used to seek summary judgment, summary adjudication of issues, or judgment on the pleadings.
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Service and Proof of Service Rules
Papers required to be served under this order must be served in a manner calculated to reach the other party by the stated deadline, and the parties are encouraged to agree on the service method (e-mail, fax, etc.).
NOTE RE SERVICE- any papers required to be served on another party pursuant to this order must be served in a manner calculated to reach that party no later than the date indicated in this order. The parties are encouraged to agree on the method (e-mail, fax, etc).
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Page 4 | Note Re Service
Motions in limine must be served on opposing party 5 court days before final status conference.
6. MOTIONS IN LIMINE. Motions in limine must be served on the opposing party and submitted to the court five court days prior to the final status conference. A written opposition to a motion in limine may be served and filed no later than the final status conference. Replies are not required but may be served and filed no later than the Friday preceding the trial date. The court does not rule on motions in limine until the first day of trial. Motions in limine should not be used to seek summary judgment, summary adjudication of issues, or judgment on the pleadings.
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Service must be calculated to reach party by the deadline; e-mail/fax encouraged.
NOTE RE SERVICE- any papers required to be served on another party pursuant to this order must be served in a manner calculated to reach that party no later than the date indicated in this order. The parties are encouraged to agree on the method (e-mail, fax, etc).
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Filing Fees and Waivers
Motion fees must be paid at the time the motion date reservation is made online via CRS.
Motion fee payments are required at the time reservations are made online.
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Page 1 | Law and Motion
Motion fees must be paid online when reserving a motion date via CRS.
Motion fee payments are required at the time reservations are made online.
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Courtesy Copy Requirements
A printed courtesy copy of ex parte opposition is required if it is e-filed after 4:00 p.m. the court day before the hearing.
If written opposition is electronically filed after 4:00 p.m. the court day before, a printed courtesy copy is required.
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Page 1 | Ex Parte Applications
Counsel must deliver a courtesy copy of the material to Department 406 within 5 court days of filing (the triggering condition appears before this excerpt and is cut off).
within 5 court days of the filing, counsel should deliver a courtesy copy of the material to Department 406.
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Page 2 | Law and Motion
Courtesy copy required for ex parte opposition filed after 4:00 p.m. the court day before the hearing.
If written opposition is electronically filed after 4:00 p.m. the court day before, a printed courtesy copy is required.
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Counsel should deliver a courtesy copy of filed motion materials to Department 406 within 5 court days.
within 5 court days of the filing, counsel should deliver a courtesy copy of the material to Department 406.
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Sealing & Redaction Procedures
Materials submitted in support of a motion under seal must strictly comply with California Rules of Court Rule 2.551 et seq.
If counsel wishes to submit any materials in support of a motion under seal, counsel must strictly comply with California Rules of Court Rule 2.551 et. seq.
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Page 2 | Sealed Documents
Materials filed under seal must strictly comply with CRC Rule 2.551 et seq.
If counsel wishes to submit any materials in support of a motion under seal, counsel must strictly comply with California Rules of Court Rule 2.551 et. seq.
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Filing Bundling Requirements
If more than 10 motions in limine are filed, parties must submit a separate tabbed and indexed notebook containing the motion, opposition, and any reply.
If there are more than 10 motions in limine, the court requires the parties to submit a separate notebook containing the motion, opposition, and reply (if any), tabbed and indexed.
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Page 3 | Trial Preparation Order
The court prefers that all motions concerning a matter be heard on the same date when possible.
It is the court’s desire, if possible, that all motions concerning a matter be heard on the same date.
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Page 1 | Law and Motion
More than 10 motions in limine require a tabbed, indexed separate notebook.
If there are more than 10 motions in limine, the court requires the parties to submit a separate notebook containing the motion, opposition, and reply (if any), tabbed and indexed.
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Pre-Motion Conference Requirements
Counsel must exhaust meet and confer efforts before filing any discovery motion, and the court will conduct an in-person informal discovery conference if the parties agree.
The Court requires all counsel to exhaust meet and confer efforts before filing a discovery motion. If the parties agree, the Court will help counsel resolve discovery disputes through an in person informal discovery conference.
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Page 1 | Discovery
Parties must reserve a motion hearing date through the online Court Reservation System (CRS) before filing any motion papers.
As of January 4, 2016, parties must obtain a motion date via the online Court Reservation System (CRS) on the Los Angeles Court website. Go to “LA Court Online, Court Reservation System,” at Superior Court of Los Angeles County Webpage to reserve a date prior to filing any motion papers.
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Page 1 | Law and Motion
Parties must reserve motion dates via CRS before filing any motion papers.
As of January 4, 2016, parties must obtain a motion date via the online Court Reservation System (CRS) on the Los Angeles Court website. Go to “LA Court Online, Court Reservation System,” at Superior Court of Los Angeles County Webpage to reserve a date prior to filing any motion papers.
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Meet and confer required before filing discovery motions.
The Court requires all counsel to exhaust meet and confer efforts before filing a discovery motion.
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Parties must meet and confer before final status conference.
The parties must meet and confer and submit the following documents FIVE COURT DAYS BEFORE THE FINAL STATUS CONFERENCE.
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Chambers Communication Rules
Counsel must arrange telephonic appearances through LACourtConnect at (888) 882-6878 at least three hours before the hearing.
LACourtConnect may be contacted at (888)882-6878. Counsel will need to make arrangements with LACourtConnect at least three hours before the hearing.
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Page 2 | Telephonic Appearance
Parties may not call the courtroom to reserve motion dates; reservations must be made online through CRS.
Please do not call the courtroom to reserve a motion date.
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Page 1 | Law and Motion
The judicial assistant for Department 406, Shantal Luqueno, can be reached at (213) 633-0152.
Shantal Luqueno, Judicial Assistant (213) 633-0152
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Page 1 | Courtroom Information - Department 406
Telephonic appearance arrangements via LACourtConnect must be made at least 3 hours before hearing.
Counsel will need to make arrangements with LACourtConnect at least three hours before the hearing.
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