Judge Karen Moskowitz
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Courtesy copies
- 5 copies
E Filed Document
- Upon Filing
Exhibit Notebook
- First Day Of Trial
Motion In Limine Notebook
- 1 copy • At Final Status Conference
Adjournments
- A stipulated continuance must state the complaint filing date, proposed continuance dates, and good-cause grounds; absent a stipulation, a continuance may be sought by noticed motion or ex parte application, and lack of diligence rarely qualifies as good cause.
- Trial dates will not be continued absent unforeseen good cause.
Request must include
Communication
Phone
Chambers
Document Format Requirements1 rule
The quote is in the court's document. The summary is not checked yet.Mandatory?
All exhibits MUST be placed in binders under tabs, and each page must be numbered (bate stamped) within each tab.
Summary: All trial exhibits must be placed in binders under tabs, with each page numbered (bate stamped) within each tab.
Document Filing Requirements10 rules
The quote is in the court's document. The summary is not checked yet.Mandatory?
All ex parte applications require a proposed order, which shall be submitted separate from the ex parte application.
Summary: Every ex parte application must be accompanied by a proposed order submitted separately from the application.
Document Type
Ex Parte Application
The quote is in the court's document. The summary is not checked yet.Mandatory?
The court does not provide court reporters unless there is a fee waiver and timely request for a reporter. Even so, there is still no guarantee that the court will have a reporter available under those circumstances. Any party otherwise seeking the presence of a court reporter must secure the service of a private court reporter with a proposed order designating the court reporter as the official reporter.
Summary: The court does not provide reporters absent a fee waiver and timely request; a party seeking a reporter must hire a private court reporter and submit a proposed order designating that reporter as the official reporter.
Document Type
Court Reporter Designation Order
The quote is in the court's document. The summary is not checked yet.Mandatory?
BINDER ONE: 1. Joint Witness List 2. Joint Exhibit List a. Include any objections and grounds b. Include columns for date identified and date admitted c. Include columns for stipulation, authenticity and admissibility 3. Joint Statement of the Case 4. Joint Proposed Special Verdict Form OR each side’s proposed verdict form 5. List of Joint and Contested Jury Instructions 6. Printed Jury instruction - fully edited 7. Briefs (if any)
Summary: Binder One provided at the FSC must contain the joint witness list, joint exhibit list (with objections/grounds and columns for date identified, date admitted, stipulation, authenticity and admissibility), joint statement of the case, proposed verdict form(s), list of joint and contested jury instructions, fully edited printed jury instructions, and any briefs.
Document Type
Final Status Conference Trial Binder
The quote is in the court's document. The summary is not checked yet.Mandatory?
The Status Report shall advise the Court of the status of ADR and fact discovery (vehicle inspection as well for Song-Beverly actions); anticipated pre-trial motions, if any; trial time estimate; and lead trial counsel mutual availability in months 18 – 24 from filing.
Summary: The post-mediation joint status report must advise the court of ADR/fact discovery status (including vehicle inspection for Song-Beverly actions), anticipated pre-trial motions, trial time estimate, and lead trial counsel mutual availability in months 18-24 from filing.
Document Type
Joint Status Report
The quote is in the court's document. The summary is not checked yet.Mandatory?
The notebook is to contain an index of each parties MILs, oppositions & replies
Summary: The Motions in Limine notebook must contain an index of each party's MILs, oppositions, and replies.
Document Type
Motion In Limine Notebook
The quote is in the court's document. The summary is not checked yet.Mandatory?
The exhibit list must be e-filed and included in the binders
Summary: A copy of the e-filed exhibit list must be included in the exhibit binders.
Document Type
Exhibit Binder
The quote is in the court's document. The summary is not checked yet.Important?
The Court requires timely compliance with California Rules of Court 3-300 regarding Notice of Related Cases.
Summary: Parties must timely comply with California Rules of Court rule 3.300 regarding notice of related cases.
Document Type
Notice Of Related Case
The quote is in the court's document. The summary is not checked yet.Important?
Please be sure to include on the proposed order an address, telephone number and email address of the client(s).
Summary: The proposed order on a motion to withdraw as counsel must include the client's address, telephone number, and email address.
Document Type
Proposed Order Granting Motion To Be Relieved As Counsel
The quote is in the court's document. The summary is not checked yet.Important?
documents with a declaration explaining why joint documents are not provided.
Summary: Documents that are not provided jointly must be accompanied by a declaration explaining why joint documents were not provided (continuation of FSC binder requirements).
Document Type
Final Status Conference Trial Binder
The quote is in the court's document. The summary is not checked yet.Important?
No mention of insurance
Summary: Trial order submissions must not contain any mention of insurance.
Document Type
Trial Order
Filing & Service rules
Electronic Filing Rules
Complaints, answers, petitions, and responses must be separately filed (e-filed if by counsel) and cannot be deemed filed as attachments to another document.
All complaints and answers (or petitions and responses) must be separately filed (efiled if by counsel). Complaints (or amended complaints) and answers (or amended answers) cannot be "deemed" filed as an attachment to another document.
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Page 2 | COMPLAINTS AND ANSWERS AS ATTACHMENTS
Represented litigants in Limited and Unlimited Non-Complex Civil matters must electronically file all documents through an approved Electronic Filing Service Provider.
The Los Angeles County Superior Court has implemented electronic filing of all documents filed in the Limited and Unlimited Non-Complex Civil matters by litigants represented by attorneys pursuant to the operative General Order re Mandatory Electronic Filing for Civil. Pursuant to California Rules of Court, Rule 2.253(b), represented litigants are required to electronically file documents with the Court through an approved Electronic Filing Service Provider.
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Page 2 | FILINGS
All motions in Department I must be reserved through the Court Reservation System (CRS) online portal, with hearings set at 8:30 AM; self-represented parties may also contact the courtroom for hearing dates.
All motions to be heard in Department I are to be reserved through the Court Reservation System. Follow the links Online Services – Court Reservation System (CRS) on the court's website. Motions are set for hearing at 8:30 AM. Self Represented Parties may use the Court Reservation System or contact the courtroom for hearing dates.
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Page 4 | MOTIONS
The exhibit list must be e-filed and also included in the exhibit binders.
The exhibit list must be e-filed and included in the binders
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Page 6 | EXHIBIT NOTEBOOKS FOR TRIAL
Self-represented litigants are exempt from mandatory e-filing and may file papers at the filing window or electronically.
Pursuant to California Rules of Court, Rule 2.253(b)(2), self-represented litigants are exempt from mandatory Electronic Filing requirements and papers may be filed at the filing window or electronically.
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Page 2 | FILINGS
Filing Timing and Cure Windows
Represented litigants must electronically file ex parte applications and all supporting documents no later than 10:00 a.m. on the court day before the ex parte hearing.
Represented litigants: All ex parte applications and 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
Self-represented litigants may submit ex parte applications up until 8:30 a.m. on the day of the hearing.
Self-Represented Litigants: May submit ex parte applications up until 8:30 a.m. the day of the hearing.
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Page 1 | EX PARTE APPLICATIONS
The court must receive the proposed order designating the private court reporter as official before the hearing.
The court must be in receipt of the order prior to the hearing.
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Page 3 | COURT REPORTERS
Because the court will rarely continue the trial date to hear MSJ/MSA motions, such motions must be timely filed and served.
The Court will rarely continue the Trial date to hear any Motions for Summary Judgment and/or Adjudication. Therefore, any Motions for Summary Judgment and/or Adjudication MUST BE TIMELY FILED AND SERVED.
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Page 4 | MOTIONS FOR SUMMARY JUDGMENT AND/OR ADJUDICATION
CMC statements must be filed and served no later than 15 calendar days before the case management conference.
CMC Statements must be filed and served no later than 15 calendar days prior to the CMC per CRC 3.725.
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Page 4 | CASE MANAGEMENT CONFERENCES
For post-mediation status conferences, parties must meet and confer and file a joint status report 5 court days before the hearing.
Parties are to meet and confer and file a joint status report 5 court days prior to the hearing.
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Page 5 | POST MEDIATION STATUS CONFERENCE
Parties must meet and confer and file a Joint Status Report at least 5 court days before the Trial Setting Conference.
At least 5 court days in advance of the Trial Setting conference, parties are ordered to meet and confer and file a Joint Status Report.
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Page 5 | TRIAL SETTING CONFERENCES
Depositions must be lodged with the Clerk of the Court before trial begins.
Depositions must be lodged with the Clerk of the Court prior to the start of trial.
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Page 6 | EXHIBIT NOTEBOOKS FOR TRIAL
Motions in Limine briefing follows CCP 1005(b) using the Final Status Conference as the hearing date, and the court may disregard untimely MILs.
Briefing schedules for Motions in Limine will be based on Code of Civil Procedure section 1005(b) using the Final Status Conference as the hearing date. The Court reserves the discretion to disregard untimely Motions in Limine.
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Page 6 | BINDER TWO – MOTIONS IN LIMINE
Service and Proof of Service Rules
An order granting a motion to be relieved as counsel is effective only upon filing proof of service of the order on all parties and the client(s).
Orders are effective only upon filing the proof of service of the Order Granting Motion to be Relieved on all parties and the client(s).
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Page 4 | MOTIONS TO WITHDRAW AS COUNSEL
The notice and service requirements for all ex parte documents also apply to self-represented litigants.
NOTE: Rules pertaining to notice and service of all ex party documents apply to Self Represented Litgants.
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Page 1 | EX PARTE APPLICATIONS
Filing Fees and Waivers
A stipulation and order for continuance must be submitted with payment of the stipulation and order fee and, if applicable, the first appearance fee of all parties to the stipulation.
A stipulation and order shall state the date the complaint was filed, proposed continuance date(s), grounds showing good cause for the continuance, and be submitted with payment of the stipulation and order fee and first appearance fee, if applicable, of all parties to the stipulation.
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Page 3
Counsel must notify the court who will pay jury fees, and jury fees must be paid forthwith when directed by the Judicial Assistant.
Notify the Court who will be paying for the jury fees. Jury fees are to be paid forthwith when directed by the Judicial Assistant
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Page 6 | EXHIBIT NOTEBOOKS FOR TRIAL
Courtesy Copy Requirements
Courtesy copies are only required when a document is e-filed within 2 court days of the scheduled hearing.
COURTESY COPIES are only required if a document is e-filed within 2 court days of scheduled hearing pursuant to the General Order re: Electronic Filing.
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Page 2 | COURTESY COPIES
Parties must bring 5 tabbed and indexed sets of exhibit books: one each for the judicial assistant, the judge, and the witness box, plus a copy for each side.
Bring 5 Sets of Exhibit Books, tabbed and indexed: One set for the judicial assistant, one set for the judge, one set for the witness box and each side to have a copy
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Page 6 | EXHIBIT NOTEBOOKS FOR TRIAL
Only one set of the Motions in Limine notebook is to be provided.
Provide one set only.
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Page 6 | BINDER TWO – MOTIONS IN LIMINE
Exhibit notebooks must be provided on the first day of trial under the department trial orders.
Provide exhibit notebooks (on the first day of trial)
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Page 6 | DEPARTMENT TRIAL ORDERS
Pre-Motion Conference Requirements
Lead trial counsel must attend the Final Status Conference in person with trial binders.
LEAD TRIAL COUNSEL ARE TO ATTEND THE FSC IN PERSON WITH TRIAL BINDERS
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Page 5 | FINAL STATUS CONFERENCE ORDERS
Lead trial counsel are ordered to appear at the Trial Setting Conference.
LEAD TRIAL COUNSEL ARE ORDERED TO APPEAR.
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Page 5 | TRIAL SETTING CONFERENCES
Parties should plan ahead because reserving a hearing date for a summary judgment/adjudication motion can take up to 4 months.
Plan ahead. It may take up to 4 months to reserve a date for MSJ/MSAI.
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Page 4 | MOTIONS
If applicable, counsel must meet and confer on the number of "sides" for calculating peremptory challenges during jury selection, to be discussed at the FSC.
If applicable, counsel are to meet and confer on the number of "sides" for purposes of calculating peremptory challenges during jury selection to discuss at the FSC
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Page 6 | EXHIBIT NOTEBOOKS FOR TRIAL
An Informal Discovery Conference is held case-by-case and is not required before filing a discovery motion; to request one, file the IDC request form (LACIV 094).
The Court will hold an Informal Discovery Conference (IDC) on a case-by-case basis. There is no requirement to hold an IDC prior to filing a discovery motion. Please file an IDC request form (LACIV 094).
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Page 4 | INFORMAL DISCOVERY CONFERENCES
Informal discovery conferences will not be held in Song-Beverly cases.
An IDC will not be held for Song-Beverly cases.
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Page 5 | INFORMAL DISCOVERY CONFERENCES
Adjournment & Extension Requirements
A stipulated continuance must state the complaint filing date, proposed continuance dates, and good-cause grounds; absent a stipulation, a continuance may be sought by noticed motion or ex parte application, and lack of diligence rarely qualifies as good cause.
A stipulation and order shall state the date the complaint was filed, proposed continuance date(s), grounds showing good cause for the continuance, and be submitted with payment of the stipulation and order fee and first appearance fee, if applicable, of all parties to the stipulation. If there is no stipulation, the parties may seek a continuance by noticed motion or an ex parte application. Failure to timely and diligently conduct discovery or timely file motions will rarely be considered good cause.
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Page 3
Trial dates will not be continued absent unforeseen good cause.
trial dates will not be continued absent unforeseen good cause.
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Page 4 | TRIAL AND FINAL STATUS CONFERENCE SCHEDULING
Chambers Communication Rules
Parties may not email the courtroom without prior court approval, and the courtroom email is not regularly monitored.
From time to time counsel/parties may receive emails from the courtroom. However, you may not email the department without prior court approval. The courtroom email is not regularly monitored.
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Page 3 | EMAILS
The Department I courtroom can be reached by phone at (818) 901-4732 during courtroom hours of 8:30 AM to 4:30 PM, excluding the 12:00 PM to 1:30 PM lunch hour.
Courtroom Telephone Number: (818) 901-4732 Courtroom Hours: 8:30 AM to 4:30 PM (Lunch Hour 12:00 PM ‐ 1:30 PM)
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Page 1 | GENERAL INFORMATION