Judge Michael E. Whitaker
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Exhibits
- 5 copies • Chambers Drop Off • At Final Status Conference
Binding: Three Ring Binder
Motion, Opposition, Reply
- 1 copy • Chambers Drop Off • No Later Than Five Calendar Days Before Final Status Conference
Binding: Three Ring Binder
Motion, Opposition, Reply, Anti-SLAPP Motions, Summary Judgment Motions, Summary Adjudication Motions, Motion To Compel Further Discovery Responses Motions, Trial Documents Motions
- Chambers Drop Off • No Later Than 3 Court Days Before Scheduled Hearing
Motion, Opposition, Reply, Ex Parte Application, Demurrer, Motion To Strike, Anti Slapp Motion, Motion For Judgment On The Pleadings, Motion For Preliminary Injunction, Motion To Compel Further Discovery Responses, Motion For Summary Judgment Or Adjudication
- Chambers Drop Off • Before Scheduled Hearing
Communication
Phone
Chambers
Page & Word Limits2 rules
The quote is in the court's document. The summary is not checked yet.Mandatory?
Five court days before an Informal Discovery Conference, the parties shall file (on eCourt) a joint statement of issues to be covered at the conference, not to exceed five (5) pages.
Summary: The joint statement of issues for an Informal Discovery Conference must not exceed five (5) pages.
Joint Statement
5 pages
Machine summary. Not checked yet.Mandatory?
Five court days before an Informal Discovery Conference, the parties shall file (on eCourt) a joint statement of issues to be covered at the conference, not to exceed five (5) pages.
Summary: Joint statements for Informal Discovery Conferences are limited to 5 pages.
Joint Statement Informal Discovery Conference
5 pages
Document Format Requirements12 rules
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.
Summary: Parties must attach copies of the designated transcript pages to the joint chart, with numbered tabs separating each deposition or trial transcript.
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties' counsel and any self-represented parties shall work together to jointly prepare five sets of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (a set for the Court, a set for the Judicial Assistant, a set for the witnesses, and a set for each party) ("Exhibit Binders").
Summary: Parties must jointly prepare five sets of tabbed, internally paginated, properly marked exhibits organized numerically in three-ring binders for the Court, Judicial Assistant, witnesses, and each party.
The quote is in the court's document. The summary is not checked yet.Mandatory?
The proposed jury instructions shall be prepared on Superior Court of Los Angeles County form SCLAC LACIV 129 or in a Word document that is in the same format.
Summary: Proposed jury instructions must be prepared on LA Superior Court form SCLAC LACIV 129 or in a Word document in the same format.
DOCX
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
Summary: Parties must attach copies of the designated transcript pages to the Joint Chart, with numbered tabs separating each deposition.
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.
The quote is in the court's document. The summary is not checked yet.Important?
Each designation or counter-designation shall be highlighted, with each party using a different color highlighter.
Summary: Every designation or counter-designation must be highlighted, with each party using a different color highlighter.
The quote is in the court's document. The summary is not checked yet.Important?
Copies of documentary exhibits shall be one-sided copies.
Summary: Copies of documentary exhibits must be one-sided.
The quote is in the court's document. The summary is not checked yet.Important?
The Motions in Limine Binder shall include one-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders, tabbed in numerical order with the opposition papers and reply papers for each motion placed directly behind the moving papers with a colored sheet of paper separating the moving, opposition, and reply papers.
Summary: The Motions in Limine Binder must contain one-sided conformed copies of all MIL papers in tabbed three-ring binders organized numerically, with opposition/reply behind moving papers and colored separator sheets between each set.
The quote is in the court's document. The summary is not checked yet.Important?
a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents
Summary: The Trial Binder must consist of one-sided, conformed copies tabbed and organized in a three-ring binder with a table of contents.
Machine summary. Not checked yet.Mandatory?
No later than five calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department 207 a Motions in Limine Binder. The Motions in Limine Binder shall include one-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders, tabbed in numerical order with the opposition papers and reply papers for each motion placed directly behind the moving papers with a colored sheet of paper separating the moving, opposition, and reply papers.
Summary: Motions in Limine Binders must be three-ring bound, tabbed, one-sided, and lodged 5 calendar days before the Final Status Conference.
Machine summary. Not checked yet.Mandatory?
The parties’ counsel and any self-represented parties shall work together to jointly prepare five sets of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (a set for the Court, a set for the Judicial Assistant, a set for the witnesses, and a set for each party) (“Exhibit Binders”). Copies of documentary exhibits shall be one-sided copies.
Summary: Exhibit Binders must be three-ring bound, tabbed, internally paginated, one-sided, and five sets must be prepared.
Machine summary. Not checked yet.Mandatory?
No later than five calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department 207 a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following (for trials by the Court without a jury, the Trial Binder shall only include the documents listed under Tabs A, B, C, H, and I):
Summary: Trial Binders must be three-ring bound, tabbed, one-sided, include a table of contents, and be lodged 5 calendar days before the Final Status Conference.
Document Filing Requirements33 rules
The quote is in the court's document. The summary is not checked yet.Mandatory?
If a Status Conference is set by the Court, all parties shall meet and confer in person, telephonically or by videoconference, and cooperate in the preparation of a Joint Report which shall be filed no later than 5 court days before the Status Conference. The Joint Report shall provide detailed information regarding the following: a) Discovery i. What discovery has been completed? ii. What discovery is outstanding and the anticipated dates of completion? answer is Yes, parties shall provide a brief summary of the discovery issues and their efforts to resolve the issues informally without Court intervention. b) Alternative Dispute Resolution i. Have the parties agreed to resolve the action through ADR, including private mediation, a Mandatory Settlement Conference through the Resolve Law LA program or a Settlement Conference with a judicial officer? If the answer is no, the parties shall explain why and what impediments preclude resolving the action through ADR. If the parties have agreed to private mediation, the parties should provide information about the mediator and the date of the mediation. c) Motion Practice i. Are there any motions the parties contemplate filing? If so, parties shall provide a brief summary of the contemplated motions and their efforts to resolve the issues informally without Court intervention.
Summary: If the Court sets a Status Conference, all parties must meet and confer and file a Joint Report detailing discovery status, ADR efforts, and contemplated motions.
Document Type
Joint Report
The quote is in the court's document. The summary is not checked yet.Mandatory?
The Court will grant ex parte relief only upon a showing, by admissible evidence, that the moving party will suffer "irreparable harm," "immediate danger," or where the moving party identifies "a statutory basis for granting relief ex parte." (Cal. Rules of Court, rule 3.1202(c).)
Summary: Ex parte relief will be granted only upon an admissible-evidence showing of irreparable harm, immediate danger, or a statutory basis for granting ex parte relief.
Document Type
Ex Parte Application
The quote is in the court's document. The summary is not checked yet.Mandatory?
If the parties do not have a court reporter, all parties will be required to provide the Court with a joint summary of the testimony and evidence admitted on a daily basis by the morning following the testimony.
Summary: If the parties do not have a court reporter, all parties must jointly provide the Court with a daily summary of the testimony and admitted evidence by the morning following each day's testimony.
Document Type
Joint Summary Of Testimony
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 being excluded from testifying at
Summary: Witnesses who are not included on the joint witness list are subject to being excluded from testifying at trial.
Document Type
Joint Witness List
The quote is in the court's document. The summary is not checked yet.Mandatory?
The joint witness list shall be organized with columns (in the format set forth below) which state (1) the name of each witness (in alphabetical order), if the witness is being called to testify as an expert, and any special requirements or accommodations needed for the witness (e.g., interpreter), (2) the party calling the witness, (3) whether the witness is actually expected to testify, (4) a brief description of the witness's expected testimony, (5) an estimate of the length of direct examination (in hours), (6) an estimate of the length of cross-examination (in hours), and (7) the total estimated length of examination (in hours). At the end of the joint witness list, the parties and any self-represented parties shall add up the estimated times for all witnesses' testimony and state the grand total in the last column.
Summary: The joint witness list must be organized in specified columns (witness name in alphabetical order with expert status and accommodations, calling party, expected-testimony status, description of expected testimony, and direct/cross/total examination time estimates in hours) and must state the grand total of all estimated testimony times in the last column.
Document Type
Joint Witness List
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties' counsel and any self-represented parties shall work together to prepare and file a joint list of all witnesses whom any party intends to call at trial, excluding impeachment and rebuttal witnesses.
Summary: The parties must jointly prepare and file a list of all witnesses any party intends to call at trial, excluding impeachment and rebuttal witnesses, per Local Rule 3.25(g)(5).
Document Type
Joint Witness List
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties' counsel and any self-represented parties shall work together to prepare and file a joint exhibit list organized with columns (in the format set forth below) which state, as to each exhibit any party intends to offer at trial: (1) the exhibit number, (2) a brief description of the exhibit, (3) which party is offering the exhibit, (4) whether the parties have stipulated to authentication of the exhibit, (5) whether the parties have stipulated to admissibility of the exhibit, (6) any evidentiary objections to admission of the exhibit, (7) the date the exhibit was marked for identification, and (8) the date the exhibit was admitted into evidence. (Local Rule 3.25(g)(6).)
Summary: Counsel and self-represented parties must jointly prepare and file a joint exhibit list containing eight required columns for each trial exhibit (number, description, offering party, stipulations, objections, and dates).
Document Type
Joint Exhibit List
The quote is in the court's document. The summary is not checked yet.Mandatory?
seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the Court.
Summary: A party seeking to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the Court.
Document Type
Showing Of Good Cause
The quote is in the court's document. The summary is not checked yet.Mandatory?
In the joint chart, each designating party's designations of deposition or former testimony shall include columns which state: (1) the designation number and name of the witness, (2) the date and type of testimony (e.g., deposition or trial testimony), (3) the page and line designations of the deposition or former testimony requested to be used, (4) any objections, (5) whether the other party has counter-designated any additional deposition or former testimony of the witness that relates to the designation, and, if so, the designation number of the counter-designation, and (6) the Court's ruling.
Summary: Each designating party's designations in the joint chart must include six required columns, from designation number and witness name through the Court's ruling.
Document Type
Joint Chart Deposition Designations
The quote is in the court's document. The summary is not checked yet.Mandatory?
If any parties intend to use deposition testimony or former trial testimony in lieu of or in addition to a witness's live testimony, the parties' counsel and any self-represented 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 any party intends to use deposition or former trial testimony, counsel and self-represented 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 Deposition Designations
The quote is in the court's document. The summary is not checked yet.Mandatory?
In the joint chart, each counter-designating party's counter-designations of additional deposition or former testimony of the witness that relates to the designations shall include columns which state: (1) the designation number and name of the witness, (2) the date and type of testimony (e.g., deposition or trial testimony), (3) the page and line counter-designations of the deposition or former testimony requested to be used, (4) any objections, (5) the designation number of the other party's designation to which the counter-designation relates, and (6) the Court's ruling.
Summary: Each counter-designating party's counter-designations in the joint chart must include six required columns, from designation number and witness name through the Court's ruling.
Document Type
Joint Chart Deposition Designations
The quote is in the court's document. The summary is not checked yet.Mandatory?
The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to exclude.
Summary: Each motion in limine's caption must concisely identify the evidence the moving party seeks to exclude.
Document Type
Motion In Limine
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties' counsel and any self-represented parties shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and file declarations that comply with the requirements of Local Rule 3.57(a).
Summary: Motions in limine must comply with the statutory notice provisions of Code of Civil Procedure section 1005.
Document Type
Motion In Limine
The quote is in the court's document. The summary is not checked yet.Mandatory?
No later than five calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department 207 a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following (for trials by the Court without a jury, the Trial Binder shall only include the documents listed under Tabs A, B, C, H, and I): Tab A: Trial Briefs (Optional. If no trial briefs are filed, leave Tab A empty.) Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab E: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).
Summary: Counsel and self-represented parties must jointly lodge a tabbed, three-ring Trial Binder in Department 207 no later than five calendar days before the Final Status Conference containing optional trial briefs, joint witness list, joint exhibit list, deposition designations, and operative pleadings, with bench trials requiring only Tabs A, B, C, H, and I.
Document Type
Trial Binder
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties’ counsel and any self-represented parties shall work together to prepare and file a joint list of all witnesses whom any party intends to call at trial, excluding impeachment and rebuttal witnesses. (Los Angeles County Court Rule (“Local Rule”) 3.25(g)(5).) The joint witness list shall be organized with columns (in the format set forth below) which state (1) the name of each witness (in alphabetical order), if the witness is being called to testify as an expert, and any special requirements or accommodations needed for the witness (e.g., interpreter), (2) the party calling the witness, (3) whether the witness is actually expected to testify, (4) a brief description of the witness’s expected testimony, (5) an estimate of the length of direct examination (in hours), (6) an estimate of the length of cross-examination (in hours), and (7) the total estimated length of examination (in hours). At the end of the joint witness list, the parties and any self-represented parties shall add up the estimated times for all witnesses’ testimony and state the grand total in the last column.
Summary: All parties (including self-represented parties) must jointly prepare and file a joint witness list, excluding impeachment and rebuttal witnesses, in the mandated seven-column format with a grand total of estimated testimony times.
Document Type
Joint Witness List
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties’ counsel and any self-represented parties shall work together to prepare and file a joint exhibit list organized with columns (in the format set forth below) which state, as to each exhibit any party intends to offer at trial: (1) the exhibit number, (2) a brief description of the exhibit, (3) which party is offering the exhibit, (4) whether the parties have stipulated to authentication of the exhibit, (5) whether the parties have stipulated to admissibility of the exhibit, (6) any evidentiary objections to admission of the exhibit, (7) the date the exhibit was marked for identification, and (8) the date the exhibit was admitted into evidence. (Local Rule 3.25(g)(6).) As set forth above, the parties’ counsel and any self-represented parties shall meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit.
Summary: All parties (including self-represented parties) must jointly prepare and file a joint exhibit list in the mandated eight-column format and must meet and confer to resolve objections to the authenticity and admissibility of each exhibit.
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 being excluded from testifying at ... seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the court.
Summary: Witnesses not listed on the joint witness list are subject to exclusion from testifying, and a party seeking to elicit testimony from an unlisted witness must first show good cause to the court.
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’ counsel and any self-represented parties shall work together to prepare and file a brief, joint written statement of the case for the Court to read to the jury. (Local Rule 3.25(g)(4).) A joint statement should usually be only a few sentences without legal jargon.
Summary: For jury trials, counsel and self-represented parties must jointly prepare and file a brief joint statement of the case for the Court to read to the jury, usually only a few sentences without legal jargon.
Document Type
Joint Statement Of The Case
The quote is in the court's document. The summary is not checked yet.Mandatory?
For jury trials, the parties’ counsel and any self-represented parties shall work together to prepare and file a joint list of proposed jury instructions (in the format set forth below) which states, as to each proposed jury instruction: (1) the jury instruction number (listed in numerical order), (2) the title of the jury instruction, (3) the party requesting the jury instruction, (4) whether the jury instruction is agreed upon or contested, (5) a concise statement of any objection, and (6) whether the jury instruction was given by the Court (“Joint List of Proposed Jury Instructions”).
Summary: For jury trials, the parties must jointly prepare and file a Joint List of Proposed Jury Instructions stating, for each instruction, its number, title, requesting party, agreed/contested status, any objection, and whether it was given.
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’ counsel and any self-represented parties shall work together to prepare a complete set of full-text proposed jury instructions, editing all proposed Judicial Council of California Civil Jury Instructions (“CACI”) instructions, inserting party names, and eliminating blanks and other irrelevant or inapplicable material.
Summary: For jury trials, the parties must jointly prepare a complete set of full-text proposed jury instructions, editing all CACI instructions to insert party names and eliminate blanks and inapplicable material.
Document Type
Proposed Jury Instructions
The quote is in the court's document. The summary is not checked yet.Mandatory?
For jury trials, the parties’ counsel and any self-represented parties shall work together to prepare and file a joint proposed general verdict form or a joint proposed special verdict form acceptable to all parties. (Local Rule 3.25(g)(8).) If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.
Summary: For jury trials, the parties must jointly prepare and file a proposed verdict form acceptable to all parties, and if they cannot agree, each party must separately file its own proposed verdict form.
Document Type
Proposed Verdict Form
The quote is in the court's document. The summary is not checked yet.Mandatory?
In the joint chart, each counter-designating party’s counter-designations of additional deposition or former testimony of the witness that relates to the designations shall include columns which state: (1) the designation number and name of the witness, (2) the date and type of testimony (e.g., deposition or trial testimony), (3) the page and line counter-designations of the deposition or former testimony requested to be used, (4) any objections, (5) the designation number of the other party’s designation to which the counter-designation relates, and (6) the Court’s ruling.
Summary: Counter-designations in the joint chart must include columns for the witness name and designation number, date and type of testimony, page and line counter-designations, objections, the related designation number, and the Court’s ruling.
Document Type
Joint Chart Of Deposition Designations
The quote is in the court's document. The summary is not checked yet.Mandatory?
In the joint chart, each designating party’s designations of deposition or former testimony shall include columns which state: (1) the designation number and name of the witness, (2) the date and type of testimony (e.g., deposition or trial testimony), (3) the page and line designations of the deposition or former testimony requested to be used, (4) any objections, (5) whether the other party has counter-designated any additional deposition or former testimony of the witness that relates to the designation, and, if so, the designation number of the counter-designation, and (6) the Court’s ruling.
Summary: Designations in the joint chart must include columns for the witness name and designation number, date and type of testimony, page and line designations, objections, related counter-designations, and the Court’s ruling.
Document Type
Joint Chart Of Deposition Designations
The quote is in the court's document. The summary is not checked yet.Mandatory?
If any parties intend to use deposition testimony or former trial testimony in lieu of or in addition to a witness’s live testimony, the parties’ counsel and any self-represented 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 a party intends to use deposition or former trial 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 Deposition Designations
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties shall organize proposed jury instructions into groups behind Tab F in the following order (labeled by cover sheets): (1) the agreed-upon instructions, (2) plaintiff's requested instructions to which defendant objects, and (3) defendant's requested instructions to which plaintiff objects.
Summary: Proposed jury instructions must be organized behind Tab F into three groups, labeled by cover sheets, in the order of agreed-upon instructions, plaintiff's contested requests, then defendant's contested requests.
Document Type
Proposed Jury Instructions
The quote is in the court's document. The summary is not checked yet.Mandatory?
contents that includes the following (for trials by the Court without a jury, the Trial Binder shall only include the documents listed under Tabs A, B, C, H, and I): Tab A: Trial Briefs (Optional. If no trial briefs are filed, leave Tab A empty.) Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Statement to Be Read to the Jury Tab E: Joint List of Jury Instructions Tab F: Joint and Contested Jury Instructions Tab G: Joint or Contested Verdict Form(s) Tab H: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab I: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).
Summary: The Trial Binder must include designated documents organized under Tabs A through I, with bench trials (jury-waived) requiring only Tabs A, B, C, H, and I and Tab A (trial briefs) optional.
Document Type
Trial Binder
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 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.Important?
Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.
Summary: Opposition and reply papers must identify the corresponding motion in limine number in the caption.
Document Type
Opposition And Reply Papers
The quote is in the court's document. The summary is not checked yet.Important?
If there is an appropriate CACI jury instruction on a point of law, the Court expects the parties to request the CACI instruction instead of a specially prepared jury instruction.
Summary: The Court expects the parties to request the applicable CACI jury instruction rather than a specially prepared instruction when an appropriate CACI instruction exists.
Document Type
Proposed Jury Instructions
The quote is in the court's document. The summary is not checked yet.Important?
When a special verdict form is requested, if there is an appropriate CACI special verdict form for a cause of action, affirmative defense, or other finding, the Court expects the parties to use the CACI special verdict form.
Summary: When a special verdict form is requested, the Court expects the parties to use the CACI special verdict form if an appropriate one exists.
Document Type
Proposed Special Verdict Form
The quote is in the court's document. The summary is not checked yet.Note?
Because it is usually extremely difficult for the Court to advance the hearing on a motion for summary judgment or summary adjudication, if a party files an ex parte application to advance the hearing on such a motion because no hearing dates are available on the Court Reservation System before the trial date, the moving party should also consider including an alternative request that the Court continue the trial to a date after the hearing on the motion.
Summary: In ex parte applications to advance a summary judgment or summary adjudication hearing when no hearing dates are available before trial, the Court recommends also including an alternative request to continue the trial to a date after the hearing.
Document Type
Ex Parte Application
The quote is in the court's document. The summary is not checked yet.Note?
Each party may, but is not required to, file a trial brief succinctly identifying: (1) the claims and defenses that remain in dispute for trial; (2) the major legal issues (with supporting points and authorities); (3) the relief and calculation of damages sought; and (4) any other information that may assist the Court at trial.
Summary: Trial briefs are optional; if filed, they should succinctly identify the disputed claims and defenses, major legal issues with supporting authorities, relief and damages calculation sought, and any other information that may assist the Court at trial.
Document Type
Trial Brief
Machine summary. Not checked yet.Mandatory?
The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to exclude. Parties filing more than one motion in limine shall number them consecutively. Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.
Summary: Motions in limine captions must identify excluded evidence, be numbered consecutively, and opposition/reply papers must reference the motion number in their caption.
Document Type
Motion In Limine
Filing & Service rules
Electronic Filing Rules
Electronic filing is mandatory, but self-represented parties are exempt pursuant to California Rules of Court, rule 2.253(b)(2).
Further, pursuant to California Rules of Court, rule 2.253(b)(2), self-represented parties are exempt from the mandatory electronic filing requirements.
The quote is in the court's document. The summary is not checked yet.
Page 2 | Filings
All motions, oppositions and replies must be electronically filed under the LA County mandatory civil e-filing general order, except that self-represented litigants are exempt.
All motions, oppositions and replies shall be filed pursuant to the FIRST AMENDED GENERAL ORDER IN RE SUPERIOR COURT OF LOS ANGELES COUNTY - MANDATORY ELECTRONIC FILING FOR CIVIL filed May 3, 2019. Pursuant to California Rules of Court, rule 2.253(b)(2), self-represented litigants are exempt from the mandatory electronic filing requirement.
The quote is in the court's document. The summary is not checked yet.
Page 6 | Filing of Motions
Except for self-represented litigants and other persons excused from e-filing, ex parte applications, supporting documents, and written oppositions must be electronically filed under the mandatory civil e-filing order.
Please note that section 8 of the FIRST AMENDED GENERAL ORDER IN RE SUPERIOR COURT OF LOS ANGELES COUNTY - MANDATORY ELECTRONIC FILING FOR CIVIL filed May 3, 2019, provides that, with the exception of self-represented litigants and other persons excused from filing documents electronically:
The quote is in the court's document. The summary is not checked yet.
Page 9 | Motions
Mandatory e-filing required for motions, oppositions, and replies; self-represented litigants are exempt.
All motions, oppositions and replies shall be filed pursuant to the FIRST AMENDED GENERAL ORDER IN RE SUPERIOR COURT OF LOS ANGELES COUNTY - MANDATORY ELECTRONIC FILING FOR CIVIL filed May 3, 2019. Pursuant to California Rules of Court, rule 2.253(b)(2), self-represented litigants are exempt from the mandatory electronic filing requirement.
Machine summary. Not checked yet.
Page 6 | 10. Motions
Filing Timing and Cure Windows
CMC statements (Judicial Council Form CMC-110) must be filed no later than 15 calendar days before the CMC date, and parties must comply with California Rules of Court rules 3.724 and 3.725.
All parties shall comply with the California Rules of Court regarding Case Management Conferences (CMC) including but not limited to Rules 3.724 and 3.725. CMC statements (Judicial Council Form CMC-110) shall be filed and served on all attorneys and self-represented parties no later than 15 calendar days before the date of the CMC.
The quote is in the court's document. The summary is not checked yet.
Page 2 | Case Management Conferences
The Joint Report must be filed no later than 5 court days before the Status Conference.
If a Status Conference is set by the Court, all parties shall meet and confer in person, telephonically or by videoconference, and cooperate in the preparation of a Joint Report which shall be filed no later than 5 court days before the Status Conference.
The quote is in the court's document. The summary is not checked yet.
Page 3 | Status Conferences re Discovery, Alternative Dispute Resolution and Motion Practice
Parties must file a joint statement of the issues to be covered at the Informal Discovery Conference on eCourt five court days before the conference.
Five court days before an Informal Discovery Conference, the parties shall file (on eCourt) a joint statement of issues to be covered at the conference, not to exceed five (5) pages.
The quote is in the court's document. The summary is not checked yet.
Page 8 | Status Conferences re Discovery, Alternative Dispute Resolution and Motion Practice
Scheduling an Informal Discovery Conference does not extend the statutory deadlines to file discovery motions.
NOTE: SCHEDULING INFORMAL DISCOVERY CONFERENCES DO NOT EXTEND STATUTORY DEADLINES TO FILE DISCOVERY MOTIONS.
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Page 8 | Status Conferences re Discovery, Alternative Dispute Resolution and Motion Practice
Ex parte applications and all supporting documents must be e-filed no later than 10:00 a.m. on the court day before the ex parte hearing.
a) 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 9 | Motions
Written opposition to an ex parte application must be e-filed by 8:30 a.m. on the day of the ex parte hearing.
b) Any written opposition to an ex parte application must be electronically filed by 8:30 a.m. on the day of the ex parte hearing.
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Page 9 | Motions
All trial documents required in Sections 2.A-D of the Trial Preparation Order (including trial briefs and the joint witness list) must be filed and served no later than five calendar days before the Final Status Conference.
No later than five calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall file and serve the following documents:
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Page 12 | TRIAL DOCUMENTS TO BE FILED
The Motions in Limine Binder must be lodged no later than five calendar days before the Final Status Conference.
No later than five calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department 207 a Motions in Limine Binder.
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Page 16
The Trial Binder must be jointly prepared and lodged in Department 207 no later than five calendar days before the Final Status Conference.
No later than five calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department 207 a Trial Binder
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Page 17 | TRIAL BINDER
Counsel and self-represented parties must file and serve the required trial documents (trial brief, joint witness list, joint exhibit list) no later than five calendar days before the Final Status Conference.
No later than five calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall file and serve the following documents:
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Page 19 | TRIAL DOCUMENTS TO BE FILED
Motions in limine must be noticed for hearing at the Final Status Conference.
Motions in limine shall be noticed for hearing at the Final Status Conference.
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Page 24 | Motions in Limine
E-filed documents may take 1-2 business days to appear on the court's docket.
NOTE: IT MAY TAKE 1-2 BUSINESS DAYS FOR AN E-FILED DOCUMENT TO APPEAR ON THE COURT'S DOCKET.
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Page 2 | Filings
CMC statements must be filed and served on all parties no later than 15 calendar days before the CMC.
CMC statements (Judicial Council Form CMC-110) shall be filed and served on all attorneys and self-represented parties no later than 15 calendar days before the date of the CMC.
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Page 2 | 5. Case Management Conferences
Joint Status Conference reports must be filed no later than 5 court days before the conference.
the Joint Report shall be filed no later than 5 court days before the Status Conference.
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Page 3 | 6. Status Conferences re Discovery, Alternative Dispute Resolution and Motion Practice
Written oppositions to ex parte applications must be e-filed by 8:30 a.m. on the day of the hearing.
Any written opposition to an ex parte application must be electronically filed by 8:30 a.m. on the day of the ex parte hearing.
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Page 9 | 13. Ex Parte Applications
Ex parte applications and supporting documents must be e-filed by 10:00 a.m. the court day before the hearing.
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 9 | 13. Ex Parte Applications
E-filed documents may take 1-2 business days to appear on the court’s docket after submission.
IT MAY TAKE 1-2 BUSINESS DAYS FOR AN E-FILED DOCUMENT TO APPEAR ON THE COURT’S DOCKET.
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Page 2 | 2. Filings
Service and Proof of Service Rules
CMC statements (Judicial Council Form CMC-110) must be served on all attorneys and self-represented parties no later than 15 calendar days before the CMC date.
CMC statements (Judicial Council Form CMC-110) shall be filed and served on all attorneys and self-represented parties no later than 15 calendar days before the date of the CMC.
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Page 2 | Case Management Conferences
Summonses, complaints, and/or cross-complaints must be served within 60 days of filing, with sanctions including dismissal possible for failure unless cause is shown.
Parties shall serve summonses, complaints and/or cross-complaints within 60 days of filing of a complaint or cross-complaint. (Cal. Rules of Court, rule 3.110(b).) Failure to do so may result in the imposition of sanctions (Code Civ. Proc., §§ 128, 177.5; Cal. Rules of Court, rule 2.30), including dismissal of the complaint or cross-complaint (Code Civ. Proc., §§ 583.210, et seq.), unless parties show cause why the Court should not make such an order.
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Page 2 | Service of Summonses, Complaints and/or Cross-Complaints
All counsel and self-represented parties must exchange all exhibits they intend to introduce at trial no later than 18 calendar days before the Final Status Conference.
No later than 18 calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall exchange all exhibits they intend to introduce at trial.
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Page 11 | MEET AND CONFER
Summonses, complaints, and cross-complaints must be served within 60 days of filing.
Parties shall serve summonses, complaints and/or cross-complaints within 60 days of filing of a complaint or cross-complaint. (Cal. Rules of Court, rule 3.110(b).)
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Page 2 | 4. Service of Summonses, Complaints and/or Cross-Complaints
CMC statements must be served on all attorneys and self-represented parties no later than 15 calendar days before the CMC.
CMC statements (Judicial Council Form CMC-110) shall be filed and served on all attorneys and self-represented parties no later than 15 calendar days before the date of the CMC.
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Page 2 | 5. Case Management Conferences
Filing Fees and Waivers
All parties must pay jury fees no later than 365 calendar days after the initial complaint is filed, unless otherwise ordered by the Court.
Unless otherwise ordered by the Court, all parties shall pay jury fees no later than 365 calendar days after the filing of the initial complaint. (Code Civ. Proc., § 631, subd. (c)(2).)
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Page 5 | Jury Fees
Parties without a fee waiver may arrange a certified shorthand reporter as official pro tempore reporter, while parties with a fee waiver may request an official court reporter.
A party who has not received a fee waiver may arrange for the presence of a certified shorthand reporter to serve as official pro tempore reporter pursuant to California Rules of Court, rule 2.956(c), and Superior Court of Los Angeles County Local Rules, rule 2.21(a), (e). A party who has received a fee waiver may request an official court reporter pursuant to California Rules of Court, rule 2.956(c), and Superior Court of Los Angeles County Local Rules, rule 2.21(a).
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Page 10 | 16. Court Reporters
Jury fees must be paid no later than 365 calendar days after filing the initial complaint.
Unless otherwise ordered by the Court, all parties shall pay jury fees no later than 365 calendar days after the filing of the initial complaint. (Code Civ. Proc., § 631, subd. (c)(2).)
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Page 5 | 9. Jury Fees
Courtesy Copy Requirements
All litigants except self-represented litigants must lodge courtesy copies directly in Department 207 of all moving, opposition, and reply papers for anti-SLAPP motions, summary judgment/adjudication motions, motions to compel further discovery responses, and trial documents no later than 3 court days before the hearing (the source list begins at item 2; item 1 is not shown).
Except as otherwise provided under Local Rule 3.4, the Court requires all litigants, except Self-Represented Litigants, to lodge courtesy copies directly in Department 207 of all moving, opposition and reply papers, no later than three (3) court days before the scheduled hearing, of the following types of motions: 2. Anti-SLAPP Motions under Code of Civil Procedure section 425.16. 3. Motions for Summary Judgment/ Adjudication. 4. Motions to Compel Further Discovery Responses. 5. Trial Documents in compliance with Trial Preparation Orders.
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Page 1 | Filings
All litigants except self-represented litigants must lodge courtesy copies in Department 207 of moving, opposition and reply papers for preliminary injunction, Anti-SLAPP, summary judgment/adjudication, motions to compel further discovery responses, and trial documents no later than three court days before the scheduled hearing.
Except as otherwise provided under Local Rule 3.4, the Court requires all litigants, except Self-Represented Litigants, to lodge courtesy copies directly in Department 207 of all moving, opposition and reply papers, no later than three (3) court days before the scheduled hearing, of the following types of motions: 1. Motions for Preliminary Injunction. 2. Anti-SLAPP Motions under Code of Civil Procedure section 425.16. 3. Motions for Summary Judgment/ Adjudication. 4. Motions to Compel Further Discovery Responses. 5. Trial Documents in compliance with Trial Preparation Orders.
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Page 6 | Courtesy Copies of Motions
Before any scheduled hearing, all parties must deliver paper courtesy copies of all motions, oppositions and replies (including ex parte applications, demurrers, motions to strike, Anti-SLAPP motions, and other listed motion papers) to Department 207.
Before any scheduled hearing, all parties shall deliver to/lodge in Department 207 courtesy paper copies of all motions, oppositions and replies, including but not limited to ex parte applications, demurrers, motions to strike, Anti-SLAPP motion, motions for judgment on the pleadings, motions for preliminary injunction, motions to compel further discovery responses and motions for summary judgment or summary adjudication.
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Page 6 | Courtesy Copies of Motions
A jointly prepared Trial Binder must be lodged in Department 207 no later than five calendar days before the Final Status Conference.
No later than five calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department 207 a Trial Binder,
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Page 24 | 5. TRIAL BINDER
Parties must jointly prepare five sets of tabbed, one-sided, three-ring Exhibit Binders and bring one set to the Final Status Conference for the Court to review.
The parties' counsel and any self-represented parties shall work together to jointly prepare five sets of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (a set for the Court, a set for the Judicial Assistant, a set for the witnesses, and a set for each party) ("Exhibit Binders"). Copies of documentary exhibits shall be one-sided copies. The parties' counsel and any self-represented parties shall bring one set of the Exhibit Binders to the Final Status Conference for the Court to review.
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Page 24 | 4. EXHIBIT BINDERS
A jointly prepared Motions in Limine Binder containing one-sided, conformed copies of all motions in limine, opposition, and reply papers, tabbed and organized in three-ring binders, must be lodged in Department 207 no later than five calendar days before the Final Status Conference.
No later than five calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department 207 a Motions in Limine Binder. The Motions in Limine Binder shall include one-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders, tabbed in numerical order with the opposition papers and reply papers for each motion placed directly behind the moving papers with a colored sheet of paper separating the moving, opposition, and reply papers.
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Page 24 | Motions in Limine
Filing Bundling Requirements
Parties must jointly prepare and lodge a Motions in Limine Binder in Department 207 no later than five calendar days before the Final Status Conference.
No later than five calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department 207 a Motions in Limine Binder.
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Page 16
Pre-Motion Conference Requirements
Motion hearing dates must be reserved in advance via the Court Reservation System (CRS); motions are heard Monday through Thursday and tentative rulings are typically posted the afternoon before the hearing.
All motion hearing dates must be reserved in advance on the Court Reservation System at www.lacourt.ca.gov, under "Online Services," "Civil," "Court Reservation System (CRS)." Motions are set for hearing Monday through Thursday. The Court endeavors to post tentative rulings the afternoon before any hearing.
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Page 5 | Motions
All parties must first meet and confer in person, by videoconference, or by telephone to attempt to informally resolve discovery issues before pursuing discovery motions.
Per the Discovery Act, all parties shall first meet and confer, in person, by videoconference or by telephone, to attempt to informally resolve discovery issues.
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Page 7 | Status Conferences re Discovery, Alternative Dispute Resolution and Motion Practice
If the parties cannot agree after meet and confer, they must schedule an Informal Discovery Conference with the Judicial Assistant or the Courtroom Assistant.
If the parties cannot agree, the parties shall schedule an Informal Discovery Conference with the Judicial Assistant or the Courtroom Assistant.
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Page 7 | Status Conferences re Discovery, Alternative Dispute Resolution and Motion Practice
Any party intending to file a motion for summary judgment or summary adjudication must immediately reserve a hearing date on the Court Reservation System, without waiting for discovery to be completed, because hearing dates may be unavailable at least 30 days before trial.
Any party who intends to file a motion for summary judgment or summary adjudication must reserve a hearing date immediately because the reservation dates for such motions are limited on the Court Reservation System, they fill up fast, and the present reservation dates available for such motions are very close to the trial dates being set by the Court. Do not wait until discovery has been completed to reserve a hearing date for a motion for summary judgment or summary adjudication because hearing dates might not be available at least 30 days before the trial date set in a case.
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Page 8 | Motions for Summary Judgment/Adjudication
Counsel and self-represented parties must meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit.
As set forth above, the parties' counsel and any self-represented parties shall meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit.
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Page 13 | JOINT EXHIBIT LIST
Motions in limine must be noticed for hearing at the Final Status Conference.
Motions in limine shall be noticed for hearing at the Final Status Conference.
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Page 16
Adjournment & Extension Requirements
A moving party who takes a motion off calendar must notify the Court immediately and remove the item from the CRS calendar.
If a moving party takes a motion off the Court's calendar, the moving party must notify the Court immediately and should remove the item from the Court's calendar on the CRS. (Cal. Rules of Court, rule 3.1304(b).)
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Page 5 | Motions - Continuing Hearings and Withdrawal of Motions
Any continuance of a scheduled motion hearing date must be ordered by the Court; rescheduling on the CRS alone is insufficient.
Once a motion is reserved and noticed/scheduled, any continuance of the hearing date must be ordered by the Court -- It is insufficient merely to reschedule the hearing on the Court Reservation System.
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Page 5 | Motions - Continuing Hearings and Withdrawal of Motions
When a party amends under CCP 472(a), the Court requests the parties cooperate to take the pending demurrer or motion to strike off calendar, and the Court may sanction a party for failing to take a motion off calendar.
by Code of Civil Procedure section 472, subdivision (a), the Court requests that party to work with the party who filed the demurrer or motion to strike to take the demurrer or motion to strike off calendar so that the Court does not needlessly prepare tentative rulings. The Court may sanction a party for failing to take a motion off calendar.
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Page 6 | Motions - Continuing Hearings and Withdrawal of Motions
The Court expects parties to agree to reasonable extensions of time to file discovery motions to facilitate informal resolution; if they cannot agree, the Court may permit filing only if an Informal Discovery Conference is scheduled and completed before the hearing.
Accordingly, the Court expects the parties to agree to reasonable extensions of time to file discovery motions in order to facilitate an informal resolution of disputes through the Informal Discovery Conference. If the parties are unable to agree to reasonable extensions of time, the Court may permit the parties to file the discovery motions, provided that an Informal Discovery Conference is scheduled and completed before the hearing on the discovery motions.
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Page 8 | Status Conferences re Discovery, Alternative Dispute Resolution and Motion Practice
Parties are expected to grant reasonable requests for extensions of time for deadlines to respond to pleadings, discovery, or other matters.
The Court expects all attorneys and parties to grant reasonable requests for professional courtesies, such as requests for reasonable extensions of time for deadlines to respond to pleadings, discovery or other matters.
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Page 1 | Civility and Professionalism
Continuances of motion hearing dates must be ordered by the Court; rescheduling on the Court Reservation System alone is insufficient.
Once a motion is reserved and noticed/scheduled, any continuance of the hearing date must be ordered by the Court -- It is insufficient merely to reschedule the hearing on the Court Reservation System.
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Page 5 | 10. Motions
Chambers Communication Rules
Parties must not call Department 207 to inquire about the status of lodged or filed documents requiring court action and should instead check status via the Case Access function on the court's website.
Following the lodgment or filing of any document which requires action by the Court (e.g., stipulation and proposed order, proposed order and/or proposed judgment), the Court requests that parties refrain from calling Department 207 to inquire about the status of the document. Instead, parties should first check on the status through the Case Access function on the Court's website -https://www.lacourt.org/casesummary/ui/index.aspx?casetype=civil
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Page 2 | Electronically Lodged Documents Which Require Action by the Court
Department 207's courtroom telephone is 310-281-2427 and courtroom hours are 8:30-12 and 1:30-4:30.
Courtroom Telephone: 310-281-2427 Courtroom Hours: 8:30-12, 1:30-4:30
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Page 1 | Courtroom Information
Parties are prohibited from calling chambers to inquire about document status; status checks must be done via the court website.
Following the lodgment or filing of any document which requires action by the Court (e.g., stipulation and proposed order, proposed order and/or proposed judgment), the Court requests that parties refrain from calling Department 207 to inquire about the status of the document. Instead, parties should first check on the status through the Case Access function on the Court’s website -https://www.lacourt.org/casesummary/ui/index.aspx?casetype=civil
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Page 3 | 3. Electronically Lodged Documents Which Require Action by the Court