Court Rules
Judge

Judge Sarah J. Heidel

Individual Rules, Standing Orders & Policies

Rules last changed:
Los Angeles Superior Court
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Document Format Requirements1 rule

Formatting

The quote is in the court's document. The summary is not checked yet.Important?

Documentary exhibits consisting of more than one page must be internally paginated in sequential numerical order.

Summary: Multi-page documentary exhibits must be internally paginated in sequential numerical order.

Ca Lasc Courtroom ALH V · Feb 2024 · p. 3
|SecTrial Preparation Order - Joint Exhibit List

Document Filing Requirements14 rules

Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

Pursuant to California Rule of Court 3.1110(f) and Los Angeles County Superior Court Rules 3.52 and 3.53, all exhibits must be exchanged and pre-numbered, except for those anticipated in good faith to be used for impeachment or during rebuttal.

Summary: All exhibits must be exchanged and pre-numbered, except exhibits anticipated in good faith for impeachment or rebuttal.

Document Type

Exhibits

Specific requirements detailed in rule text.
Ca Lasc Courtroom ALH V · Feb 2024 · p. 3
|SecTrial Preparation Order - Joint Exhibit List
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

All motions in limine must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party and setting forth the opposing party's position regarding the motion(s). Failure to include such a declaration will result in summary denial of MIL.

Summary: Every motion in limine must include a sworn meet-and-confer declaration stating the opposing party's position or the motion will be summarily denied.

Document Type

Motion In Limine

Content & Formatting
Certificate Of Conference
Ca Lasc Courtroom ALH V · Feb 2024 · p. 4
|SecTrial Preparation Order - Motions in Limine
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Mandatory?

The parties must submit a joint exhibit list and joint witness list as described above.

Summary: In bench trials, the parties must submit a joint exhibit list and joint witness list as described in the order.

Document Type

Bench Trial Submissions

Specific requirements detailed in rule text.
Ca Lasc Courtroom ALH V · Feb 2024 · p. 4
|SecTrial Preparation Order - Bench Trials
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Important?

Submit a disposition table which lists all jury instructions by number, the identity of the party or parties proposing the instruction, and columns for the court to indicate whether the instruction is given, modified, withdrawn or refused.

Summary: A disposition table listing all jury instructions by number, proposing parties, and court ruling columns must be submitted with the jury instructions.

Document Type

Jury Instruction Disposition Table

Specific requirements detailed in rule text.
Ca Lasc Courtroom ALH V · Feb 2024 · p. 3
|SecTrial Preparation Order - Joint Jury Instructions
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Important?

All witnesses must be listed on one list. Do not repeat the name of a witness. Indicate the total time expected for that testimony, including direct, cross, and re-direct. At the end of the list, state the total time estimated for each witness's testimony.

Summary: The joint witness list must include each witness once on a single list with estimated testimony time (direct, cross, re-direct) and total time stated at the end of the list.

Document Type

Joint Witness List

Specific requirements detailed in rule text.
Ca Lasc Courtroom ALH V · Feb 2024 · p. 3
|SecTrial Preparation Order - Joint Witness List
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Important?

Exhibits written in a foreign language must be accompanied by a certified English translation. Cal. Rule of Court 3.1110(g).

Summary: Foreign-language exhibits must be accompanied by a certified English translation.

Document Type

Foreign Language Exhibits

Specific requirements detailed in rule text.
Ca Lasc Courtroom ALH V · Feb 2024 · p. 3
|SecTrial Preparation Order - Joint Exhibit List
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Important?

All demonstrative exhibits, not admitted into evidence, must be shown to the opposing party before use at trial. Any objections to the use of demonstrative exhibits must be brought to the court's attention in a timely manner and before publication to the jury.

Summary: Demonstrative exhibits not admitted into evidence must be shown to the opposing party before use at trial, and objections must be raised timely and before publication to the jury.

Document Type

Demonstrative Exhibits

Specific requirements detailed in rule text.
Ca Lasc Courtroom ALH V · Feb 2024 · p. 3
|SecTrial Preparation Order - Joint Exhibit List
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Important?

If instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction.

Summary: Disputed jury instructions must be submitted in separate sets identifying the proposing and opposing parties.

Document Type

Disputed Jury Instructions

Specific requirements detailed in rule text.
Ca Lasc Courtroom ALH V · Feb 2024 · p. 3
|SecTrial Preparation Order - Joint Jury Instructions
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Important?

Submit a joint set of CACI instructions will all information filled in – no remaining brackets or blanks.

Summary: The joint jury instructions must be a complete set of CACI instructions with all information filled in and no remaining brackets or blanks.

Document Type

Joint Jury Instructions

Specific requirements detailed in rule text.
Ca Lasc Courtroom ALH V · Feb 2024 · p. 3
|SecTrial Preparation Order - Joint Jury Instructions
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Important?

Any proposed special verdict should be in a form that is easily used and understood by the jury and which does not require the jury to answer unnecessary questions.

Summary: Proposed special verdict forms must be easy for the jury to use and understand and must not require unnecessary questions.

Document Type

Joint Proposed Verdict Form

Specific requirements detailed in rule text.
Ca Lasc Courtroom ALH V · Feb 2024 · p. 4
|SecTrial Preparation Order - Joint Proposed Verdict Form
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Note?

This is brief, neutral description of the case to be read to the jury. In most instances, it should not exceed two paragraphs.

Summary: The concise joint statement is a brief, neutral case description to be read to the jury and should generally not exceed two paragraphs.

Document Type

Concise Joint Statement

Specific requirements detailed in rule text.
Ca Lasc Courtroom ALH V · Feb 2024 · p. 3
|SecTrial Preparation Order - Concise Joint Statement
Filing Requirements

The quote is in the court's document. The summary is not checked yet.Note?

If the parties wish to make a mini opening statement prior to conducting their voir dire they must write out their brief statement and share it with opposing counsel. They will then be required to read their statement verbatim to the jury at the appropriate time.

Summary: Parties wishing to give a mini opening statement before voir dire must write it out, share it with opposing counsel, and read it verbatim to the jury.

Document Type

Mini Opening Statement

Specific requirements detailed in rule text.
Ca Lasc Courtroom ALH V · Feb 2024 · p. 3
|SecTrial Preparation Order - Mini Opening Statement
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Pursuant to California Rule of Court 3.1110(f) and Los Angeles County Superior Court Rules 3.52 and 3.53, all exhibits must be exchanged and pre-numbered, except for those anticipated in good faith to be used for impeachment or during rebuttal. Documentary exhibits consisting of more than one page must be internally paginated in sequential numerical order. Exhibits written in a foreign language must be accompanied by a certified English translation.

Summary: Joint exhibit lists must include pre-numbered exhibits, internal pagination for multi-page exhibits, and certified translations for foreign language exhibits.

Document Type

Joint Exhibit List

Content & Formatting
Exhibit List
Filing Requirements

Machine summary. Not checked yet.Mandatory?

All motions in limine must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party and setting forth the opposing party’s position regarding the motion(s). Failure to include such a declaration will result in summary denial of MIL.

Summary: Motions in limine must include a sworn declaration attesting to meet and confer with opposing party, or face summary denial.

Document Type

Motion In Limine

Content & Formatting
Certificate Of Conference

Filing & Service rules

Electronic Filing Rules

Written opposition to an ex parte application must be electronically filed by 8:30 a.m. on the day of the hearing.

Any written opposition shall be electronically filed by 8:30 a.m. the day of the hearing.

The quote is in the court's document. The summary is not checked yet.

Page 1 | Ex Parte Applications

Ex parte applications and all supporting documents must be electronically filed no later than 10:00 a.m. on the court day before the hearing.

All Ex parte applications and documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the hearing.

The quote is in the court's document. The summary is not checked yet.

Page 1 | Ex Parte Applications

Parties must reserve a motion date through the online Court Reservation System (CRS) at www.lacourt.org before filing any motion papers.

Parties must obtain a motion date via the online Court Reservation System (CRS) on the Los Angeles Court website "LA Court Online, Court Reservation System," at www.lacourt.org to reserve a date prior to filing any motion papers.

The quote is in the court's document. The summary is not checked yet.

Page 2 | Law and Motion

Self-represented litigants are exempt from the mandatory electronic filing requirements under California Rules of Court, rule 2.253(b)(2).

Pursuant to California Rules of Court, rule 2.253(b)(2), self-represented litigants are exempt from these mandatory Electronic Filing requirements.

The quote is in the court's document. The summary is not checked yet.

Page 1 | Ex Parte Applications

Ex parte applications, supporting documents, and oppositions must be e-filed; self-represented litigants are exempt from this mandatory e-filing requirement.

All Ex parte applications and documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the hearing. Any written opposition shall be electronically filed by 8:30 a.m. the day of the hearing. Pursuant to California Rules of Court, rule 2.253(b)(2), self-represented litigants are exempt from these mandatory Electronic Filing requirements.

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Page 1 | Ex Parte Applications

Filing Timing and Cure Windows

Ex parte opposition papers must be filed by an 8:30 a.m. cutoff on the day of the hearing.

Any written opposition shall be electronically filed by 8:30 a.m. the day of the hearing.

The quote is in the court's document. The summary is not checked yet.

Page 1 | Ex Parte Applications

Ex parte application papers must be filed by a 10:00 a.m. cutoff on the court day before the hearing.

All Ex parte applications and documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the hearing.

The quote is in the court's document. The summary is not checked yet.

Page 1 | Ex Parte Applications

Parties must meet and confer and submit all required trial preparation documents five court days before the Final Status Conference.

Parties must meet and confer and submit the following documents five court days before the FSC.

The quote is in the court's document. The summary is not checked yet.

Page 3 | Trial Preparation Order - Final Status Conference

Failure to timely submit any required item without good cause may result in sanctions, including monetary sanctions, exclusion of evidence, issue preclusion, denial of claims or defenses, dismissal, or default.

Failure to submit any item required in this order in a timely manner without good cause may result in the imposition of sanctions, including monetary sanctions, exclusion of evidence, issue preclusion, denial of a claim or defense, dismissal, or default.

The quote is in the court's document. The summary is not checked yet.

Page 4 | Trial Preparation Order - Compliance

Replies to motions in limine are optional but, if filed, must be served and filed no later than the Friday before trial.

Replies are not required but may be served and filed no later than the Friday preceding the trial date.

The quote is in the court's document. The summary is not checked yet.

Page 4 | Trial Preparation Order - Motions in Limine

Written oppositions to motions in limine may be served and filed no later than the Final Status Conference.

A written opposition to a motion in limine may be served and filed no later than the FSC.

The quote is in the court's document. The summary is not checked yet.

Page 4 | Trial Preparation Order - Motions in Limine

Written oppositions to ex parte applications must be e-filed by 8:30 a.m. the day of the hearing.

Any written opposition shall be electronically filed by 8:30 a.m. the day of the hearing.

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Page 1 | Ex Parte Applications

Ex parte applications and supporting documents must be e-filed by 10:00 a.m. the court day before the hearing.

All Ex parte applications and documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the hearing.

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Page 1 | Ex Parte Applications

Required FSC documents must be submitted five court days before the Final Status Conference.

Parties must meet and confer and submit the following documents five court days before the FSC.

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Page 3 | Trial Preparation Order

Motions in limine must be served and submitted five court days before the Final Status Conference.

Motions in limine must be served on the opposing party and submitted to the court five court days prior to the FSC.

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Page 4 | Motions in Limine

Oppositions to motions in limine may be filed no later than the Final Status Conference.

A written opposition to a motion in limine may be served and filed no later than the FSC.

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Page 4 | Motions in Limine

Replies to motions in limine may be filed no later than the Friday before the trial date.

Replies are not required but may be served and filed no later than the Friday preceding the trial date.

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Page 4 | Motions in Limine

Service and Proof of Service Rules

Motions in limine must be served on the opposing party and submitted to the court five court days before the FSC.

Motions in limine must be served on the opposing party and submitted to the court five court days prior to the FSC.

The quote is in the court's document. The summary is not checked yet.

Page 4 | Trial Preparation Order - Motions in Limine

Motions in limine must be served on the opposing party five court days before the FSC.

Motions in limine must be served on the opposing party and submitted to the court five court days prior to the FSC.

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Page 4 | Motions in Limine

Filing Fees and Waivers

Motion filing fees must be paid at the time the motion date reservation is made online through CRS.

Motion fee payments are required at the time reservations are made online.

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Page 2 | Law and Motion

Motion filing fees must be paid when making online motion date reservations.

Motion fee payments are required at the time reservations are made online.

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Page 2 | Law and Motion

Sealing & Redaction Procedures

Counsel submitting motion materials under seal must strictly comply with California Rules of Court Rule 2.551 et seq.

If counsel wishes to submit any materials in support of a motion under seal, counsel must strictly comply with California Rules of Court Rule 2.551 et. seq.

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Page 2 | Law and Motion

Motion support materials submitted under seal must comply with California Rules of Court Rule 2.551 et seq.

If counsel wishes to submit any materials in support of a motion under seal, counsel must strictly comply with California Rules of Court Rule 2.551 et. seq.

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Page 2 | Law and Motion

Pre-Motion Conference Requirements

Parties must meet and confer before filing any motion in limine under LA County Superior Court Rule 3.57.

Los Angeles County Superior Court Rule 3.57 requires the parties to meet and confer before filing any motion in limine.

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Page 4 | Trial Preparation Order - Motions in Limine

Upon written request of counsel, the Court may hold an informal discovery conference to resolve discovery disputes informally; IDCs are held Monday-Thursday 2:30-3:30 p.m.

Upon a written request of counsel, the Court may conduct an informal discovery conference (IDC) to assist counsel in resolving discovery disputes informally. IDCs are held Monday-Thursday 2:30-3:30 p.m.

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Page 2 | Discovery

Parties must reserve a motion date via the online CRS before filing any motion papers.

Parties must obtain a motion date via the online Court Reservation System (CRS) on the Los Angeles Court website “LA Court Online, Court Reservation System,” at www.lacourt.org to reserve a date prior to filing any motion papers.

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Page 2 | Law and Motion

Parties must meet and confer before filing any motion in limine per local rule.

Los Angeles County Superior Court Rule 3.57 requires the parties to meet and confer before filing any motion in limine.

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Page 4 | Motions in Limine

Chambers Communication Rules

Parties must not call the courtroom to reserve a motion date; reservations must be made online through CRS.

Please do not call the courtroom to reserve a motion date.

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Page 2 | Law and Motion

Parties are prohibited from calling the courtroom to reserve a motion date.

Please do not call the courtroom to reserve a motion date.

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Page 2 | Law and Motion

Documents of departments with no single judge listed

About Judge Sarah J. Heidel

Judge Sarah J. Heidel is a judge on the Superior Court of California, County of Los Angeles, the state trial court serving Los Angeles County.

Judge Heidel's procedures are published through the court's general rules.

Common questions about Judge Sarah J. Heidel's rules

Does Judge Sarah J. Heidel require a pre-motion conference or letter before filing a motion?

Judge Sarah J. Heidel's rules set a pre-motion procedure for motion in limine. Parties must meet and confer before filing any motion in limine under LA County Superior Court Rule 3.57.

View ruleSource: page 4, section Trial Preparation Order - Motions in Limine

What must be included with exhibits filings before Judge Sarah J. Heidel?

The rule identifies required filing content or certificates. All exhibits must be exchanged and pre-numbered, except exhibits anticipated in good faith for impeachment or rebuttal.

View ruleSource: page 3, section Trial Preparation Order - Joint Exhibit List

What must be included with motion in limine filings before Judge Sarah J. Heidel?

The rule requires certificate of conference. Every motion in limine must include a sworn meet-and-confer declaration stating the opposing party's position or the motion will be summarily denied.

View ruleSource: page 4, section Trial Preparation Order - Motions in Limine

How may parties contact Judge Sarah J. Heidel's chambers?

The rule addresses phone communications with Judge Sarah J. Heidel's chambers. Parties must not call the courtroom to reserve a motion date; reservations must be made online through CRS.

View ruleSource: page 2, section Law and Motion

How does Judge Sarah J. Heidel handle sealed or redacted filings?

Judge Sarah J. Heidel's rules set procedures for sealed or redacted filings. Counsel submitting motion materials under seal must strictly comply with California Rules of Court Rule 2.551 et seq.

View ruleSource: page 2, section Law and Motion

Is electronic filing required before Judge Sarah J. Heidel?

Yes. Electronic filing is required for the covered filings. Ex parte applications and all supporting documents must be electronically filed no later than 10:00 a.m. on the court day before the hearing.

View ruleSource: page 1, section Ex Parte Applications

Are filing fees or waivers addressed before Judge Sarah J. Heidel?

A fee is required for covered filings. Motion filing fees must be paid at the time the motion date reservation is made online through CRS.

View ruleSource: page 2, section Law and Motion

When is a filing treated as filed before Judge Sarah J. Heidel?

The rule states a 10:00 AM filing cutoff. Ex parte application papers must be filed by a 10:00 a.m. cutoff on the court day before the hearing.

View ruleSource: page 1, section Ex Parte Applications

What rule applies to service for motion in limine before Judge Sarah J. Heidel?

The rule addresses service method, recipient, or timing requirements. Details: recipient: the opposing party, timing: 5 business days before hearing. Motions in limine must be served on the opposing party and submitted to the court five court days before the FSC.

View ruleSource: page 4, section Trial Preparation Order - Motions in Limine
Complete rules summary for Judge Sarah J. Heidel

Ex parte applications and all supporting documents must be electronically filed no later than 10:00 a.m. on the court day before the hearing.

Ex parte application papers must be filed by a 10:00 a.m. cutoff on the court day before the hearing.

Ex parte opposition papers must be filed by an 8:30 a.m. cutoff on the day of the hearing.

Self-represented litigants are exempt from the mandatory electronic filing requirements under California Rules of Court, rule 2.253(b)(2).

Upon written request of counsel, the Court may hold an informal discovery conference to resolve discovery disputes informally; IDCs are held Monday-Thursday 2:30-3:30 p.m.

Parties must reserve a motion date through the online Court Reservation System (CRS) at www.lacourt.org before filing any motion papers.

Motion filing fees must be paid at the time the motion date reservation is made online through CRS.

Parties must not call the courtroom to reserve a motion date; reservations must be made online through CRS.

Counsel submitting motion materials under seal must strictly comply with California Rules of Court Rule 2.551 et seq.

Parties must meet and confer and submit all required trial preparation documents five court days before the Final Status Conference.

All exhibits must be exchanged and pre-numbered, except exhibits anticipated in good faith for impeachment or rebuttal.

Multi-page documentary exhibits must be internally paginated in sequential numerical order.

Foreign-language exhibits must be accompanied by a certified English translation.

Demonstrative exhibits not admitted into evidence must be shown to the opposing party before use at trial, and objections must be raised timely and before publication to the jury.

The joint witness list must include each witness once on a single list with estimated testimony time (direct, cross, re-direct) and total time stated at the end of the list.

The joint jury instructions must be a complete set of CACI instructions with all information filled in and no remaining brackets or blanks.

Disputed jury instructions must be submitted in separate sets identifying the proposing and opposing parties.

A disposition table listing all jury instructions by number, proposing parties, and court ruling columns must be submitted with the jury instructions.

The concise joint statement is a brief, neutral case description to be read to the jury and should generally not exceed two paragraphs.

Parties wishing to give a mini opening statement before voir dire must write it out, share it with opposing counsel, and read it verbatim to the jury.

Proposed special verdict forms must be easy for the jury to use and understand and must not require unnecessary questions.

Parties must meet and confer before filing any motion in limine under LA County Superior Court Rule 3.57.

Every motion in limine must include a sworn meet-and-confer declaration stating the opposing party's position or the motion will be summarily denied.

Motions in limine must be served on the opposing party and submitted to the court five court days before the FSC.

Written oppositions to motions in limine may be served and filed no later than the Final Status Conference.

Replies to motions in limine are optional but, if filed, must be served and filed no later than the Friday before trial.

In bench trials, the parties must submit a joint exhibit list and joint witness list as described in the order.

Failure to timely submit any required item without good cause may result in sanctions, including monetary sanctions, exclusion of evidence, issue preclusion, denial of claims or defenses, dismissal, or default.

Ex parte applications, supporting documents, and oppositions must be e-filed; self-represented litigants are exempt from this mandatory e-filing requirement.

Ex parte applications and supporting documents must be e-filed by 10:00 a.m. the court day before the hearing.

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