Judge Ryan D. White
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
All filings
- Hand Delivery • Per General Order Re Mandatory Electronic Filing
Ex Parte Application, Ex Parte Opposition
- Hand Delivery • Upon Filing
Summary Judgment Motion Brief, Ex Parte Application, Ex Parte Opposition, Trial Document
- Hand Delivery • Within One Day Of Electronic Filing
Communication
Chambers, Clerk
Phone
Chambers
Phone
Clerk
Page & Word Limits2 rules
The quote is in the court's document. The summary is not checked yet.Mandatory?
exceed three (3) pages that succinctly summarizes the nature of the dispute, the necessity for the discovery, the basis for any objection or withholding of information, and the overall status of discovery.
Summary: The Informal Discovery Conference request (sentence continues from the prior page) must not exceed three pages and must summarize the nature of the dispute, the necessity for the discovery, any objections or withholding of information, and the overall status of discovery.
Request For Idc
3 pages
The quote is in the court's document. The summary is not checked yet.Mandatory?
Each party shall file a trial brief, not to exceed 15 pages, succinctly identifying: (1) the claims and defenses subject to litigation; (2) the legal and factual issues to be decided (with supporting points and authorities); (3) the relief claimed and the calculation of damages sought; (4) the ultimate facts or issues to which they will stipulate; (5) the major evidentiary issues anticipated; and (6) any other information that may assist the Court at trial.
Summary: Each party's trial brief must not exceed 15 pages.
Trial Brief
15 pages
Document Format Requirements11 rules
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 that 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
Summary: Each designating party's designations in the joint chart must include columns for the witness designation number/name, date and type of testimony, and page and line designations (remaining columns truncated in the source text).
The quote is in the court's document. The summary is not checked yet.Mandatory?
The proposed jury instructions shall be prepared on SCLAC form LASC LACIV 129 or in a Word document that is in the same format including the disposition box.
Summary: Proposed jury instructions must be prepared on SCLAC form LASC LACIV 129 or in a Word document in the same format, including the disposition box.
The quote is in the court's document. The summary is not checked yet.Mandatory?
After the jury-instruction conference, the Court will require one of the parties to submit a final set of jury instructions approved by the Court, including any modifications ordered by the Court, and excluding the disposition table from the top of each instruction.
Summary: The final set of jury instructions must exclude the disposition table from the top of each instruction.
The quote is in the court's document. The summary is not checked yet.Mandatory?
If after exhaustive meet and confer efforts the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form, and bring an electronic copy of their proposed verdict form in Word to the FSC, ready to be edited in the courtroom.
Summary: Each party must bring an electronic Word copy of its proposed verdict form to the FSC, ready to be edited in the courtroom.
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 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?
Each designation or counter-designation shall be highlighted, with each party using a different color highlighter.
Summary: Each 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.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 designation number/name, testimony date and type, page and line counter-designations, objections, the related designation number, and the Court's ruling.
The quote is in the court's document. The summary is not checked yet.Mandatory?
The Motions in Limine Binder shall include two-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders not to exceed 3" per binder, indexed and 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 two-sided conformed copies organized in tabbed, indexed three-ring binders no larger than 3 inches per binder with colored sheets separating moving, opposition, and reply papers.
The quote is in the court's document. The summary is not checked yet.Mandatory?
Copies of documentary exhibits shall be one-sided copies.
Summary: Copies of documentary exhibits must be one-sided.
The quote is in the court's document. The summary is not checked yet.Mandatory?
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.
We could not find this wording in the court's document. Open the source before relying on it.Mandatory?
The parties' counsel and any self-represented parties shall work together to jointly prepare three sets of tabbed, internally paginated by document, and properly marked exhibits, organized numerically in three-ring binders (not to exceed 3" per binder) (one set for the Court, one set for the Judicial Assistant, and one set for the witnesses) ("Exhibit Binders"). For example, if exhibit 5 is a five-page document, its pages should be numbered 5-1, 5-2, 5-3.
Machine summary and details
Summary: Parties must jointly prepare three sets of tabbed, internally paginated (e.g., 5-1, 5-2), properly marked exhibits organized numerically in three-ring binders no larger than 3 inches for the Court, Judicial Assistant, and witnesses.
Document Filing Requirements49 rules
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties are to file either the Stipulation and Order to Use Certified Shorthand Reporter or Order Appointing Court Approved Reporter as Official Reporter Pro Tempore prior to the hearing being called.
Summary: Parties must file either a Stipulation and Order to Use Certified Shorthand Reporter or an Order Appointing a Court Approved Reporter as Official Reporter Pro Tempore before the hearing is called.
Document Type
Court Reporter Stipulation Or Appointment Order
The quote is in the court's document. The summary is not checked yet.Mandatory?
Ex parte applications are reserved for exigent circumstances. The applicant shall comply with CRC, rule 3.1202(c): "An applicant must make an affirmative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte."
Summary: Ex parte applications are reserved for exigent circumstances and must include a declaration making an affirmative factual showing of irreparable harm, immediate danger, or another statutory basis for relief.
Document Type
Ex Parte Application
The quote is in the court's document. The summary is not checked yet.Mandatory?
Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in Court.
Summary: Ex parte applicants must submit a proposed order and pay the filing fee before appearing in Court.
Document Type
Ex Parte Application
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 trial other than for purposes of giving actual impeachment or rebuttal testimony. Any party that 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 included on the joint witness list may be excluded from testifying at trial (except for actual impeachment or rebuttal testimony), and calling an unlisted witness requires a showing of 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?
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. Local Rule 3.25(g)(5).
Summary: Parties' counsel and self-represented parties must jointly prepare and file a joint witness list of all trial witnesses, excluding impeachment and rebuttal witnesses.
Document Type
Joint Witness List
The quote is in the court's document. The summary is not checked yet.Mandatory?
Each party shall file a trial brief, not to exceed 15 pages, succinctly identifying: (1) the claims and defenses subject to litigation; (2) the legal and factual issues to be decided (with supporting points and authorities); (3) the relief claimed and the calculation of damages sought; (4) the ultimate facts or issues to which they will stipulate; (5) the major evidentiary issues anticipated; and (6) any other information that may assist the Court at trial.
Summary: Trial briefs must succinctly identify the claims and defenses, legal and factual issues with supporting authorities, relief and damages calculation, stipulated facts/issues, major evidentiary issues, and other information assisting the Court at trial.
Document Type
Trial Brief
The quote is in the court's document. The summary is not checked yet.Mandatory?
If an objection to an exhibit is not articulated on the exhibit list, the Court may deem the exhibit admitted.
Summary: Exhibit objections not articulated on the joint exhibit list may result in the Court deeming the exhibit admitted.
Document Type
Joint Exhibit 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 with reference to the applicable evidence code section(s) or other legal authority; (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: Parties' counsel and self-represented parties must jointly prepare and file a joint exhibit list with eight required columns covering exhibit number, description, offering party, stipulations, objections, and marking/admission dates.
Document Type
Joint Exhibit 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 concise, joint written statement of the case for the Court to read to the jury. Local Rule 3.25(g)(4).
Summary: For jury trials, parties' counsel and self-represented parties must jointly prepare and file a concise joint written statement of the case for the Court to read to the jury.
Document Type
Joint Statement Of Case
The quote is in the court's document. The summary is not checked yet.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/parties 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.
Summary: For jury trials, parties' counsel and self-represented parties must jointly prepare and file a joint list of proposed jury instructions stating each instruction's number, title, requesting party, agreed/contested status, any objection, and whether it was given.
Document Type
Joint Proposed Jury Instructions
The quote is in the court's document. The summary is not checked yet.Mandatory?
If after exhaustive meet and confer efforts the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form, and bring an electronic copy of their proposed verdict form in Word to the FSC, ready to be edited in the courtroom.
Summary: If the parties cannot agree on a joint verdict form after exhaustive meet and confer, each party must separately file a proposed verdict form.
Document Type
Proposed Verdict Form
The quote is in the court's document. The summary is not checked yet.Mandatory?
After the jury-instruction conference, the Court will require one of the parties to submit a final set of jury instructions approved by the Court, including any modifications ordered by the Court, and excluding the disposition table from the top of each instruction.
Summary: After the jury-instruction conference, one party must submit the final set of Court-approved jury instructions incorporating the Court's modifications.
Document Type
Final 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).
Summary: For jury trials, counsel and self-represented parties must jointly prepare and file a proposed general or special verdict form acceptable to all parties under Local Rule 3.25(g)(8).
Document Type
Proposed Verdict Form
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, counsel and self-represented parties must jointly prepare a complete set of full-text proposed jury instructions edited from CACI, with party names inserted and blanks removed.
Document Type
Proposed Jury Instructions
The quote is in the court's document. The summary is not checked yet.Mandatory?
If any party intends to use deposition testimony or former trial testimony in lieu of or in addition to a witness's live testimony, all 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.
Summary: If a party intends to use deposition or former trial testimony, all parties must meet and confer and jointly prepare and file a joint chart of page and line designations in the required format.
Document Type
Joint Chart Deposition Designations
The quote is in the court's document. The summary is not checked yet.Mandatory?
Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.
Summary: Opposition and reply papers must identify the corresponding motion in limine number in their caption.
Document Type
Opposition And Reply Papers
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 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?
Parties filing more than one motion in limine shall number them consecutively.
Summary: Parties filing multiple motions in limine must number them consecutively.
Document Type
Motion In Limine
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties shall lodge the entire three sets of exhibit binders on the first day of trial.
Summary: All three sets of exhibit binders must be lodged on the first day of trial.
Document Type
Exhibit Binder
The quote is in the court's document. The summary is not checked yet.Mandatory?
description of the exhibit behind the corresponding numerical tab in the Exhibit Binders, and shall comply with XIII(G), below.
Summary: Exhibit Binders must include a description of each exhibit behind the corresponding numerical tab and comply with section XIII(G) (rule continues from the prior page).
Document Type
Exhibit 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 each bring one volume (not a full set) of the Exhibit Binders containing their exhibits to the Final Status Conference for the Court to review.
Summary: Each party must bring one volume (not a full set) of its Exhibit Binders to the Final Status Conference for the Court's review.
Document Type
Exhibit Binder
The quote is in the court's document. The summary is not checked yet.Mandatory?
Tab A: Trial Briefs 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/Line Designations for Deposition/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 contain, under tabs A through I, the trial briefs, joint witness list, joint exhibit list, joint statement to the jury, jury instruction lists, verdict forms, deposition designation chart, and operative pleadings.
Document Type
Trial Binder
The quote is in the court's document. The summary is not checked yet.Mandatory?
Every exhibit that is marked must contain an exhibit tag.
Summary: Every marked exhibit must contain an exhibit tag.
Document Type
Exhibit
The quote is in the court's document. The summary is not checked yet.Mandatory?
(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: In bench trials, the Trial Binder need only include the documents listed under 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 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, labeled by cover sheets, in the order of agreed-upon instructions, plaintiff's requested instructions to which defendant objects, and defendant's requested instructions to which plaintiff objects.
Document Type
Proposed Jury Instructions
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties' counsel and any self-represented parties shall also place the Court's yellow evidence tags (with only the case number and exhibit number filled in) on each exhibit in the Judicial Assistant's copy of the Exhibit Binder.
Summary: Parties must place the Court's yellow evidence tags (showing only the case number and exhibit number) on each exhibit in the Judicial Assistant's copy of the Exhibit Binder.
Document Type
Exhibit
The quote is in the court's document. The summary is not checked yet.Mandatory?
If a flash drive or CD/DVD is offered into evidence, it must be listed on the Exhibit List, with a placeholder in the Exhibit Book identifying the exhibit and exhibit number, and the flash drive or CD/DVD must be marked as an exhibit.
Summary: A flash drive or CD/DVD offered into evidence must be listed on the Exhibit List, have a placeholder in the Exhibit Book, and be marked as an exhibit.
Document Type
Electronic Media Exhibit
The quote is in the court's document. The summary is not checked yet.Mandatory?
If the flash drive or CD/DVD is marked as an exhibit and any of the photos contained or presented within the electronic media are also marked with a separate exhibit number, then each of the marked photos must be printed out and have an exhibit tag affixed to each item.
Summary: Photos within marked electronic media that bear separate exhibit numbers must be printed out with an exhibit tag affixed to each item.
Document Type
Electronic Media Exhibit
The quote is in the court's document. The summary is not checked yet.Mandatory?
marked as an exhibit, it must be described accurately on the Exhibit List (e.g., "Plaintiff's Exhibit 2 (flash drive or CD/DVD containing 3 photographs)").
Summary: Electronic media marked as an exhibit must be described accurately on the Exhibit List (sentence continues from the prior page).
Document Type
Electronic Media Exhibit
The quote is in the court's document. The summary is not checked yet.Mandatory?
If the flash drive or CD/DVD contains a recording, the description on the Exhibit List must state whether it contains an audio file, and the submitting party must confirm that a transcript of the audio has been filed with the CD/DVD at the time the exhibit is offered to the Court. CRC, Rule 2.1040
Summary: The submitting party must confirm that a transcript of any audio recording has been filed with the CD/DVD at the time the exhibit is offered to the Court.
Document Type
Electronic Media Exhibit
The quote is in the court's document. The summary is not checked yet.Mandatory?
A copy of the slides must be lodged with the Court.
Summary: A copy of the PowerPoint slides must be lodged with the Court.
Document Type
Powerpoint Slides
The quote is in the court's document. The summary is not checked yet.Mandatory?
If the flash drive or CD/DVD contains a recording, the description on the Exhibit List must state whether it contains an audio file, and the submitting party must confirm that a transcript of the audio has been filed with the CD/DVD at the time the exhibit is offered to the Court.
Summary: The Exhibit List description of a recording must state whether it contains an audio file.
Document Type
Exhibit List
The quote is in the court's document. The summary is not checked yet.Mandatory?
If a CD/DVD is in an envelope, sleeve, or case, the description on the Exhibit List must state language similar to the following: "Plaintiff's 1 – DVD in a white sleeve containing 5 photographs of the defendant."
Summary: If a CD/DVD is in an envelope, sleeve, or case, the Exhibit List description must use language similar to the specified example.
Document Type
Exhibit List
The quote is in the court's document. The summary is not checked yet.Mandatory?
If counsel intends to use PowerPoint, the Court shall be informed at the FSC and a copy of the slides must be shared with opposing counsel prior to the presentation.
Summary: Counsel must inform the Court at the Final Status Conference if using PowerPoint and share a copy of the slides with opposing counsel before the presentation.
Document Type
Powerpoint Slides
The quote is in the court's document. The summary is not checked yet.Important?
If the parties agree to utilize a settlement program requiring a court order, please file a proposed stipulation and order.
Summary: Parties agreeing to use a settlement program that requires a court order must file a proposed stipulation and order.
Document Type
Stipulation And Order
The quote is in the court's document. The summary is not checked yet.Important?
If you require an accommodation relating to a disability, please inform the courtroom staff at least five (5) court days in advance so the Court can attempt to facilitate your request. Requests can be made by filing Judicial Council Form MC-410.
Summary: Disability accommodation requests must be made to courtroom staff at least five court days in advance by filing Judicial Council Form MC-410.
Document Type
Disability Accommodation Request
The quote is in the court's document. The summary is not checked yet.Important?
If all defendants have not been served, plaintiff or plaintiff's counsel must submit a declaration to the Court seven (7) days prior to the CMC explaining why service has not been completed, documenting the efforts that have been made to complete service, and specifying the date by which service is proposed to be completed.
Summary: If defendants have not been served by the CMC, plaintiff must submit a declaration seven days before the CMC explaining why service is incomplete, documenting service efforts, and proposing a completion date.
Document Type
Declaration Of Incomplete Service
The quote is in the court's document. The summary is not checked yet.Important?
At least five (5) days prior to the FSC, the parties shall file the following documents and, as discussed in Section XIII(F), below, lodge a binder as described therein.
Summary: In addition to the required filings, the parties must lodge a binder, as described in Section XIII(F), at least five days prior to the FSC.
Document Type
Binder
The quote is in the court's document. The summary is not checked yet.Important?
The joint witness list shall be organized with columns (in the format set forth below) that 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 and redirect 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 contain seven required columns (witness name/expert status/accommodations, calling party, expected to testify, testimony description, direct/redirect hours, cross hours, total hours) and state a grand total of estimated testimony hours.
Document Type
Joint Witness List
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 one (1) day for jury selection.
Summary: Absent good cause, the total estimated testimony hours on the joint witness list should not exceed the trial estimate given at the case management conference, including one day for jury selection.
Document Type
Joint Witness List
The quote is in the court's document. The summary is not checked yet.Important?
The parties are required to comply with Section XIII(G), below, regarding Electronic Media as Exhibits.
Summary: The parties must comply with Section XIII(G) regarding Electronic Media as Exhibits (details set forth in that section).
Document Type
Electronic Media Exhibits
The quote is in the court's document. The summary is not checked yet.Important?
As set forth above, the parties’ counsel and any self-represented parties shall meet and confer in good faith in an effort to resolve objections to the authenticity and admissibility of each exhibit.
Summary: Parties' counsel and self-represented parties must meet and confer in good faith 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.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 (or incorporate) the CACI special verdict form.
Summary: When a special verdict form is requested, parties are expected to use or incorporate the applicable CACI special verdict form.
Document Type
Proposed Special Verdict Form
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. Specially prepared jury instructions should be used sparingly and should not be repetitive of CACI instructions or argumentative in nature.
Summary: Parties are expected to request the applicable CACI instruction rather than a specially prepared one, and specially prepared instructions should be used sparingly and must not be repetitive of CACI or argumentative.
Document Type
Proposed Jury Instructions
The quote is in the court's document. The summary is not checked yet.Important?
Uncontested motions should note "uncontested" in the caption.
Summary: Uncontested motions in limine should note 'uncontested' in the caption.
Document Type
Motion In Limine
The quote is in the court's document. The summary is not checked yet.Important?
Motions in limine should not be used to seek summary judgment, summary adjudication of issues, or judgment on the pleadings.
Document Type
Motion In Limine
The quote is in the court's document. The summary is not checked yet.Important?
The parties/counsel are discouraged from filing more than 5 contested motions in limine.
Summary: Parties and counsel are discouraged from filing more than 5 contested motions in limine.
Document Type
Motion In Limine
The quote is in the court's document. The summary is not checked yet.Important?
Motions in limine that are generic, do not identify the specific evidence sought to be excluded (e.g., exhibits, testimony, or witnesses), seek rulings which would merely be declaratory of existing law or would not provide any meaningful guidance for the parties or witnesses are disfavored.
Summary: Generic motions in limine that do not identify the specific evidence (exhibits, testimony, or witnesses) to be excluded or that seek merely declaratory rulings are disfavored.
Document Type
Motion In Limine
The quote is in the court's document. The summary is not checked yet.Note?
The parties should strive to ensure that the proposed verdict form ensures against an award of duplicative damages.
Summary: Parties should strive to ensure the proposed verdict form guards against an award of duplicative damages.
Document Type
Proposed Verdict Form
Filing & Service rules
Electronic Filing Rules
Represented litigants must electronically file all documents in Limited and Unlimited Non-Complex Civil matters 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 CRC, rule 2.253(b), represented litigants are required to electronically file documents with the Court through an approved Electronic Filing Service Provider.
The quote is in the court's document. The summary is not checked yet.
Page 2 | V. MANDATORY E-FILING
Self-represented litigants are exempt from mandatory e-filing and should file their papers at the filing window.
Pursuant to CRC, rule 2.253(b)(2), self-represented litigants are exempt from mandatory electronic filing requirements, and papers should be filed at the filing window.
The quote is in the court's document. The summary is not checked yet.
Page 2 | V. MANDATORY E-FILING
Represented parties must electronically file any written opposition to an ex parte application by 8:30 a.m. on the day of the hearing.
Any written opposition to the ex parte application by parties represented by counsel must be electronically filed by 8:30 a.m. on the day of the ex parte hearing.
The quote is in the court's document. The summary is not checked yet.
Page 4 | B. Ex Parte Applications
Represented parties must electronically file ex parte applications with all documentary support by 10:00 a.m. the court day before the hearing.
Parties represented by counsel must electronically file ex parte applications with all documentary support no later than 10:00 a.m. the court day before the ex parte hearing.
The quote is in the court's document. The summary is not checked yet.
Page 4 | B. Ex Parte Applications
Filing Timing and Cure Windows
Written opposition to an ex parte application by represented parties is due by 8:30 a.m. on the day of the ex parte hearing.
Any written opposition to the ex parte application by parties represented by counsel must be electronically filed by 8:30 a.m. on the day of the ex parte hearing.
The quote is in the court's document. The summary is not checked yet.
Page 4 | B. Ex Parte Applications
Case management statements on Judicial Council Form CM-110 must be filed no later than 15 calendar days before the CMC.
The parties and counsel shall file a case management statement using Judicial Council Form CM-110 no later than fifteen (15) calendar days before the date set for the CMC.
The quote is in the court's document. The summary is not checked yet.
Page 4 | A. Case Management Conference
Ex parte applications by represented parties are due by electronic filing no later than 10:00 a.m. the court day before the ex parte hearing.
Parties represented by counsel must electronically file ex parte applications with all documentary support no later than 10:00 a.m. the court day before the ex parte hearing.
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Page 4 | B. Ex Parte Applications
Self-represented parties must file ex parte support or opposition papers with the Judicial Assistant in Department P or the clerk's office by 9:00 a.m. on the day of the hearing.
Self-represented parties seeking to present documents in support of or in opposition to an ex parte application must file them with the Judicial Assistant in Department P or the clerk's office by 9:00 a.m. on the day of the hearing, after paying any applicable filing fee (unless the party has a fee waiver).
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Page 4 | B. Ex Parte Applications
The Court will not accept ex parte papers from self-represented parties for same-day hearings if filed after 9:00 a.m.
The Court will not accept ex parte papers from self-represented parties for hearings that same day if filed after 9:00 a.m.
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Page 4 | B. Ex Parte Applications
The parties must file all required trial preparation documents at least five days before the FSC.
At least five (5) days prior to the FSC, the parties shall file the following documents and, as discussed in Section XIII(F), below, lodge a binder as described therein.
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Page 7
The parties must meet and confer to ensure that transcripts of each deposition identified on the joint chart are lodged with the Court before trial begins.
The parties shall meet and confer to ensure that transcripts of each deposition identified on the Joint Chart of Page and Line Designations for Deposition and Former Testimony is lodged with the Court prior to the commencement of trial.
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Page 10 | viii. Joint Chart of Page and Line Designations for Deposition and Former Testimony
Motions in limine must be filed with statutory notice under CCP section 1005 and Local Rule 3.57(a) for hearing at the FSC.
Motions in limine shall be filed with statutory notice for hearing at the FSC. The parties' counsel and any self-represented parties shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and the requirements of Local Rule 3.57 (a).
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Page 12 | Motions in Limine
A jointly prepared Motions in Limine Binder must be lodged in Department P no later than three calendar days before the FSC.
No later than three calendar days before the FSC, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department P a Motions in Limine Binder which is no larger than 3".
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Page 12 | Motions in Limine
The parties must jointly prepare and lodge a Trial Binder in Department P no later than three calendar days before the Final Status Conference.
No later than three (3) calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department P a Trial Binder
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Page 13 | F. Trial Binder
Objections to PowerPoint slides must be submitted to the Court as soon as possible and before the jury is empaneled.
If there are any objections to any slide, the objecting party must submit the objections to the Court as soon as possible and before the jury is empaneled.
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Page 14 | H. Visual Aids During Opening Statement
The daily trial proceedings summary must be emailed to the Court's resource account by 7:30 p.m. each day of trial, with a physical copy lodged in the courtroom the next morning before proceedings resume.
If no court reporter is used, the parties must jointly prepare a summary of the day's proceedings, email a copy to the Court's resource account at comdeptp@lacourt.ca.gov by 7:30 p.m. each day of trial, and lodge a physical copy in the courtroom the next morning before proceedings resume.
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Page 15 | K. Court Reporters and Settled Statements
A party with a fee waiver under CRC 3.55(7) may request an official court reporter by filing form LASC LACIV 269 at least 10 calendar days before the hearing or trial.
A party who has a fee waiver pursuant to California Rules of Court, rule 3.55(7) may request an official court reporter by filing form LASC LACIV 269 at least ten (10) calendar days before the hearing or trial.
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Page 2 | VII. COURT REPORTERS
Service and Proof of Service Rules
All defendants must be served with the complaint by the date of the Case Management Conference.
All defendants must be served with the complaint by the date of the CMC.
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Page 4 | A. Case Management Conference
A set of properly marked exhibits must be provided to each opposing party prior to the start of trial.
A set of properly marked exhibits must also be provided to each opposing party prior to the start of trial.
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Page 12 | E. Exhibit Binders
Filing Fees and Waivers
Self-represented parties must pay any applicable filing fee when filing ex parte papers, unless they have a fee waiver.
Self-represented parties seeking to present documents in support of or in opposition to an ex parte application must file them with the Judicial Assistant in Department P or the clerk's office by 9:00 a.m. on the day of the hearing, after paying any applicable filing fee (unless the party has a fee waiver).
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Page 4 | B. Ex Parte Applications
Ex parte applicants must pay the filing fee before appearing in Court.
Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in Court.
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Page 4 | B. Ex Parte Applications
Motion fees must be paid at the time the hearing date is reserved online through the Court Reservation System.
Motion fee payments are required at the time reservations are made online.
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Page 5 | Law and Motion
Courtesy Copy Requirements
Conformed, printed courtesy copies with tabbed exhibits are required for summary judgment motion briefs, ex parte applications and oppositions, and trial documents, delivered directly to Department P within one day of electronic filing.
The Court requires courtesy copies (with tabbed exhibits) for the following categories of documents: (1) summary judgment motions briefs; (2) ex parte applications and oppositions; (3) trial documents; and (4) motion papers exceeding 100 pages (i.e., including exhibits and all other supporting documents), regardless of the type of motion. The conformed, printed courtesy copies are to be delivered directly to Department P within one day of electronic filing.
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Page 2 | VI. COURTESY COPIES
Courtesy copies must be delivered directly to the courtroom as provided in the General Order re Mandatory Electronic Filing.
Please deliver courtesy copies directly to the courtroom pursuant to the General Order re Mandatory Electronic Filing.
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Page 2 | V. MANDATORY E-FILING
Self-represented parties must bring a separate courtesy copy of ex parte papers for each party in the case.
A separate courtesy copy of the papers shall also be brought for each party in the case.
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Page 4 | B. Ex Parte Applications
Filing Bundling Requirements
In the Motions in Limine Binder, opposition and reply papers must be placed directly behind the corresponding moving papers, and proposed orders must not be included.
The Motions in Limine Binder shall include two-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders not to exceed 3" per binder, indexed and 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. Proposed orders should not be included in the Motions in Limine Binder.
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Page 12 | Motions in Limine
Pre-Motion Conference Requirements
Moving parties must reserve a hearing date through the online Civil Court Reservation System at www.lacourt.org before filing any motion, except motions in limine, which are heard at the Final Status Conference.
Moving parties must secure a hearing date via the online Court Reservation System on the SCLAC website. Please see the "Online Services" section to find the Civil Court Reservation System at www.lacourt.org to reserve a hearing date prior to filing any motion, except for motions in limine, which, by local rule, are heard during the Final Status Conference.
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Page 5 | Law and Motion
Before filing any discovery motion, including motions to compel further responses, parties must first meet and confer in good faith in person, by telephone, or by videoconference pursuant to CCP § 2016.040.
Pursuant to Code of Civil Procedure section 2016.040, the parties and counsel are ordered to meet and confer to make reasonable, good-faith efforts to informally resolve discovery disputes. Thus, should the parties wish to file a motion to compel further responses to discovery, or other discovery motions regarding depositions, subpoenas, protective orders, or otherwise, the parties must first meet and confer in good faith either in person or by telephone or videoconference.
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Page 5 | D. Discovery Motions
The Court generally will not hear discovery motions until an IDC is conducted, and motions filed before an IDC will be continued absent good cause.
The Court generally will not hear motions to compel further discovery, or the other above-described discovery motions until an IDC is conducted. Absent a showing of good cause, motions filed before an IDC is conducted will be continued until the date of or after the IDC, which the parties should schedule as soon as possible after the dispute emerges.
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Page 6 | D. Discovery Motions
Counsel and self-represented parties must meet and confer in person or by videoconference and attempt resolution before filing any motion in limine.
The parties' counsel and any self-represented parties shall meet and confer in person or by videoconference to discuss the motion in limine prior to its filing and attempt to reach resolution of the issue.
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Page 12 | Motions in Limine
Parties unable to resolve a discovery dispute should schedule an Informal Discovery Conference prior to filing any discovery motion, requesting it via Form LACIV-094; an IDC does not extend discovery motion filing deadlines.
If the parties are unable to resolve their discovery disputes, the Court requests that the parties schedule an Informal Discovery Conference ("IDC") prior to filing any discovery motion. Scheduling or participating in an IDC does not extend any deadlines for filing discovery motions. The parties are instructed to file their Request for an IDC using Form LACIV-094.
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Page 5 | D. Discovery Motions
Adjournment & Extension Requirements
Trial will proceed without witnesses who fail to timely appear, and continuances will not be granted due to witnesses who do not appear in a timely manner.
If witnesses are not under subpoena and do not timely appear, trial will proceed without them. Continuances will not be granted due to witnesses who do not appear in a timely manner.
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Page 14 | I. Witnesses
Chambers Communication Rules
At the end of each trial day, counsel must meet and confer and email the Judicial Assistant at comdeptp@lacourt.ca.gov an agreed-upon list of all exhibits admitted that day.
At the end of each trial day, counsel must meet and confer and submit to the Court’s Judicial Assistant via email at comdeptp@lacourt.ca.gov an agreed-upon list of all exhibits admitted that day.
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Page 8
If no court reporter is used at trial, the parties must jointly prepare a daily proceedings summary, email it to the Court's resource account at comdeptp@lacourt.ca.gov by 7:30 p.m. each trial day, and lodge a physical copy in the courtroom the next morning.
The Court strongly encourages the parties to bring a court reporter for trial. If no court reporter is used, the parties must jointly prepare a summary of the day's proceedings, email a copy to the Court's resource account at comdeptp@lacourt.ca.gov by 7:30 p.m. each day of trial, and lodge a physical copy in the courtroom the next morning before proceedings resume.
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Page 15 | K. Court Reporters and Settled Statements
Parties intending to submit on a tentative ruling should email comdeptp@lacourt.ca.gov, copying all other parties and self-represented litigants, as soon as possible before the hearing.
Parties that intend to submit on this tentative ruling are requested to send an email to the Court, copying counsel for all other parties and all self-represented litigants, at comdeptp@lacourt.ca.gov indicating their intention to submit on the tentative ruling as soon as possible prior to the hearing.
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Page 5 | Law and Motion
Parties or counsel who will be late or want a matter on second call must contact court staff (Department P main line (310) 761-4317) and may request priority with the Judicial Assistant.
If a party or counsel is going to be late for a hearing or wishes for a matter to be placed on second call, please contact the court staff. The parties and counsel also may ask for priority with the Judicial Assistant.
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Page 1 | I. GENERAL INFORMATION
Department P's designated email account for contact is comdeptp@lacourt.ca.gov.
Department P Email Account: comdeptp@lacourt.ca.gov
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Page 1 | Courtroom Information Header
For remote sign-in difficulties, disconnect and retry; if on hold more than 10 minutes call the help desk at (213) 830-0400, and if the help desk is unreachable, call Department P.
If you have difficulty signing in, please completely disconnect and try again. If you are on hold for more than 10 minutes and cannot hear anything, please call the help desk at (213) 830-0400. If you are unable to reach the help desk, please call Department P.
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Page 2 | IV. DIFFICULTIES WITH SIGNING IN FOR REMOTE APPEARANCES
Junior Lawyer Participation Incentives
Junior attorneys are encouraged to argue hearings; when a junior attorney argues, one senior attorney for the same party may augment the argument and the Court will allocate additional hearing time.
The Court encourages the active participation of junior attorneys in hearings before the Court to help develop their litigation skills. When a junior attorney argues, the Court will permit one senior attorney for the same party to augment the argument, if needed, and will allocate more time to the hearing to accommodate.
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Page 5 | Law and Motion