Judge Upinder S. Kalra
Individual Rules, Standing Orders & Policies
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Limits & Logistics
Document Limits
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Page & Word Limits6 rules
The quote is in the court's document. The summary is not checked yet.Mandatory?
At least four court days before the IDC, the moving party shall file and serve a memorandum no longer than three pages setting identifying the disputed issues.
Summary: The moving party's IDC memorandum may be no longer than three pages.
Informal Discovery Conference Memorandum
3 pages
The quote is in the court's document. The summary is not checked yet.Mandatory?
Except in extraordinary cases, trial briefs should not exceed fifteen pages in length.
Summary: Trial briefs should not exceed 15 pages, except in extraordinary cases.
Trial Brief
15 pages
The quote is in the court's document. The summary is not checked yet.Important?
The responding party may file and serve a responsive memorandum of no more than three pages at least two court days prior to the IDC using the same protocol set forth above.
Summary: The responding party's responsive IDC memorandum may be no more than three pages.
Responsive Memorandum
3 pages
Machine summary. Not checked yet.Mandatory?
At least four court days before the IDC, the moving party shall file and serve a memorandum no longer than three pages setting identifying the disputed issues.
Summary: IDC memoranda are limited to three pages, filed and served at least four court days before the IDC.
Memorandum
3 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
The responding party may file and serve a responsive memorandum of no more than three pages at least two court days prior to the IDC using the same protocol set forth above.
Summary: Responsive IDC memoranda are limited to three pages, filed and served at least two court days before the IDC.
Responsive Memorandum
3 pages
Applies to: Attorney
Machine summary. Not checked yet.Important?
Except in extraordinary cases, trial briefs should not exceed fifteen pages in length.
Summary: Bench trial briefs are limited to 15 pages except in extraordinary cases.
Trial Brief
15 pages
Applies to: Attorney
Document Format Requirements3 rules
The quote is in the court's document. The summary is not checked yet.Mandatory?
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 trial exhibits must be exchanged and pre-numbered, except exhibits anticipated in good faith for impeachment or rebuttal.
The quote is in the court's document. The summary is not checked yet.Mandatory?
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.
The quote is in the court's document. The summary is not checked yet.Mandatory?
The parties shall submit a concise— not to exceed two paragraphs—neutral statement of the case.
Summary: The parties' joint statement of the case must be concise and not exceed two paragraphs.
Document Filing Requirements19 rules
The quote is in the court's document. The summary is not checked yet.Mandatory?
The opening paragraph shall include: (1) a neutral statement of the dispute; and (2) a concise, non-argumentative summary of each party’s position.
Summary: The IDC memorandum's opening paragraph must include a neutral statement of the dispute and a concise, non-argumentative summary of each party's position.
Document Type
Informal Discovery Conference Memorandum
The quote is in the court's document. The summary is not checked yet.Mandatory?
Parties are advised to carefully evaluate whether a proper basis exists for ex parte relief. There must be an affirmative showing of “irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte.” (See Cal.Rules of Court, rule 3.1202 (c).) The applicant shall demonstrate why the requested relief cannot be obtained through other means, such as a noticed motion.
Summary: An ex parte application must affirmatively show irreparable harm, immediate danger, or another statutory basis for relief, and must demonstrate why the relief cannot be obtained through other means such as a noticed motion.
Document Type
Ex Parte Application
The quote is in the court's document. The summary is not checked yet.Mandatory?
The Court requires cause to be presented in a written declaration, based upon personal knowledge, filed at least five days before the hearing date.
Summary: For an order to show cause, the cause must be presented in a written declaration based upon personal knowledge.
Document Type
Order To Show Cause
The quote is in the court's document. The summary is not checked yet.Mandatory?
For exhibits a party intends to admit into evidence, please indicate the moving party, stipulations on authentication in one column and stipulations on admissibility in the next column. If there are no objections, please state the basis for any objection i.e., hearsay, etc.
Summary: The joint exhibit list must indicate the moving party, stipulations on authentication and admissibility in separate columns, and the basis for any objection.
Document Type
Joint Exhibit List
The quote is in the court's document. The summary is not checked yet.Mandatory?
All witnesses must be listed on one list. Do not repeat the name of a witness. 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, with estimated total testimony time (direct, cross, re-direct) indicated for each witness.
Document Type
Joint Witness List
The quote is in the court's document. The summary is not checked yet.Mandatory?
Exhibits written in a foreign language must be accompanied by a certified English translation.
Summary: Foreign-language exhibits must be accompanied by a certified English translation.
Document Type
Foreign Language Exhibit
The quote is in the court's document. The summary is not checked yet.Mandatory?
As to all experts counsel intends to call at trial, no later than the FSC, Counsel shall present to the Court and opposing counsel a copy of the Code of Civil Procedure section 2034.260 declaration that states the substance of the proffered opinion.
Summary: By the FSC, counsel must present to the Court and opposing counsel a CCP section 2034.260 declaration stating the substance of each expert's proffered opinion.
Document Type
Ccp 2034 260 Expert Declaration
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) and must be submitted with timely statutory notice to be heard at the final status conference.
Summary: Every motion in limine must include a sworn declaration attesting to conferral with the opposing party and stating their position, and must be filed with timely statutory notice to be heard at the FSC.
Document Type
Motion In Limine
The quote is in the court's document. The summary is not checked yet.Mandatory?
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, the proposing party or parties, and columns for the Court to mark given, modified, withdrawn, or refused must be submitted.
Document Type
Joint Jury Instructions
The quote is in the court's document. The summary is not checked yet.Mandatory?
Submit a joint set of CACI instructions will all information filled in – no remaining brackets or blanks. If instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction.
Summary: Joint jury instructions must be submitted as fully completed CACI instructions with no remaining brackets or blanks, with disputed instructions submitted in separate sets identifying the proposing and opposing parties.
Document Type
Joint Jury Instructions
The quote is in the court's document. The summary is not checked yet.Important?
Please also review and execute the Stipulation to Policies and Procedures for Mandatory Settlement Conferences at the following link:
Summary: Parties must review and execute the Stipulation to Policies and Procedures for Mandatory Settlement Conferences for court-conducted settlement conferences.
Document Type
Stipulation To Policies And Procedures For Mandatory Settlement Conference
The quote is in the court's document. The summary is not checked yet.Important?
Failing to timely reserve a motion date does not constitute irreparable harm.
Summary: Failing to timely reserve a motion date does not constitute irreparable harm supporting ex parte relief, particularly where relief could be sought via motion for summary judgment or adjudication.
Document Type
Ex Parte Application
The quote is in the court's document. The summary is not checked yet.Important?
If the parties cannot agree on the verdict form, each party must submit their own proposed verdict form. 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: If the parties cannot agree, each must submit its own proposed verdict form, and any special verdict must be easily understood by the jury without unnecessary questions.
Document Type
Proposed Verdict Form
The quote is in the court's document. The summary is not checked yet.Important?
Except for joint jury instructions, parties must comply with all of the above requirements. In addition, it is helpful to the Court if the parties submit a trial brief setting forth the elements of each cause of action, the proposed evidence supporting each element, a brief discussion of the major legal issues supported by relevant authority, and a brief discussion of any other information that may assist the Court at trial.
Summary: In bench trials, parties should submit a trial brief setting forth the elements of each cause of action, supporting proposed evidence, the major legal issues with relevant authority, and other helpful information.
Document Type
Trial Brief
The quote is in the court's document. The summary is not checked yet.Note?
Parties and counsel are encouraged to advise the Court of their preferred pronouns, either in writing or at any appearance. Attorneys are further encouraged to include pronouns in signature blocks on filed documents. All parties and counsel shall address individuals in accordance with the pronouns identified.
Summary: Parties are encouraged to advise the Court of preferred pronouns, attorneys are encouraged to include pronouns in signature blocks on filed documents, and all parties must address individuals per the pronouns identified.
Document Type
Filed Documents
Machine summary. Not checked yet.Mandatory?
The opening paragraph shall include: (1) a neutral statement of the dispute; and (2) a concise, non-argumentative summary of each party’s position.
Summary: IDC memorandum opening paragraph must include neutral dispute statement and non-argumentative summary of each party's position.
Document Type
Memorandum
Machine summary. Not checked yet.Mandatory?
The Court requires cause to be presented in a written declaration, based upon personal knowledge, filed at least five days before the hearing date.
Summary: OSC cause must be in a written declaration based on personal knowledge, filed at least five days before hearing.
Document Type
Declaration
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) and must be submitted with timely statutory notice to be heard at the final status conference.
Summary: Motions in limine must include a sworn declaration of meet and confer and opposing party's position.
Document Type
Motion In Limine
Machine summary. Not checked yet.Important?
The parties shall submit a concise— not to exceed two paragraphs—neutral statement of the case.
Summary: Joint statement of the case must be neutral and not exceed two paragraphs.
Document Type
Joint Statement Of Case
Filing & Service rules
Electronic Filing Rules
All ex parte applications and supporting documents must be electronically filed.
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 3 | Ex Parte Applications
Self-represented litigants are exempt from the mandatory electronic filing requirements for ex parte filings.
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 3 | Ex Parte Applications
Mandatory electronic filing is required for all parties except self-represented litigants.
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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Filing Timing and Cure Windows
The moving party must file and serve the IDC memorandum at least four court days before the IDC.
At least four court days before the IDC, the moving party shall file and serve a memorandum no longer than three pages setting identifying the disputed issues.
The quote is in the court's document. The summary is not checked yet.
Page 2 | Discovery
Written opposition to an ex parte application must be electronically 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 3 | Ex Parte Applications
Ex parte applications and supporting documents must be e-filed no later than 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 3 | Ex Parte Applications
The written declaration presenting cause for an order to show cause must be filed at least five days before the hearing date.
The Court requires cause to be presented in a written declaration, based upon personal knowledge, filed at least five days before the hearing date.
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Page 4 | Orders to Show Cause
Parties must meet and confer and jointly submit the required Final Status Conference documents five court days before the FSC.
Pursuant to Local Rule 3.25(f), parties must meet and confer and submit the following JOINT documents five court days before the FSC
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Page 5 | Final Status Conference
A party with a CRC 3.55(7) fee waiver may request an official court reporter by filing form FW-020 at least 10 calendar days before the hearing or trial.
A party who has received a fee waiver pursuant to CRC 3.55(7) may request an official court reporter by filing form FW-020 at least 10 calendar days before the hearing or trial. (See CRC 2.956(c).)
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Page 7 | Clerk's Office And Court Support Services
If filed, the responding party's responsive IDC memorandum must be filed and served at least two court days prior to the IDC using the same protocol as the moving party's memorandum.
The responding party may file and serve a responsive memorandum of no more than three pages at least two court days prior to the IDC using the same protocol set forth above.
The quote is in the court's document. The summary is not checked yet.
Page 2 | Discovery
Scheduling an IDC temporarily tolls the discovery motion filing deadline from the IDC request until the IDC date; further extensions require party agreement and tolling is not indefinite.
Scheduling an IDC temporarily tolls the deadline for filing a discovery motion beginning upon the request for the IDC and concluding on the date of the IDC. Any further extension must be agreed upon by the parties. Such tolling is not indefinite.
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Page 2 | Discovery
The Court generally rules on late motions in limine submissions but may impose sanctions if the late filing prejudices a party or was tactical.
The Court, however, will generally rule on late submissions. If late submissions prejudice a party or were filed late in order to gain a tactical advantage, the Court may impose sanctions.
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Page 6 | Motions in Limine
The Court will entertain motions in limine at any time throughout the trial.
Trials are fluid so the Court will entertain motions in limine throughout the trial.
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Page 6 | 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 3
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 3
Responding party's IDC memorandum must be filed and served at least two court days before the IDC.
The responding party may file and serve a responsive memorandum of no more than three pages at least two court days prior to the IDC using the same protocol set forth above.
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Page 2
Moving party's IDC memorandum must be filed and served at least four court days before the IDC.
At least four court days before the IDC, the moving party shall file and serve a memorandum no longer than three pages setting identifying the disputed issues.
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Page 2
Joint FSC documents must be submitted five court days before the Final Status Conference.
pursuant to Local Rule 3.25(f), parties must meet and confer and submit the following JOINT documents five court days before the FSC:
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Page 5
Expert declarations under CCP § 2034.260 must be submitted to court and opposing counsel by the FSC.
As to all experts counsel intends to call at trial, no later than the FSC, Counsel shall present to the Court and opposing counsel a copy of the Code of Civil Procedure section 2034.260 declaration that states the substance of the proffered opinion.
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Page 6
Court reporter request form FW-020 must be filed 10 calendar days before hearing or trial.
A party who has received a fee waiver pursuant to CRC 3.55(7) may request an official court reporter by filing form FW-020 at least 10 calendar days before the hearing or trial.
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Service and Proof of Service Rules
All parties who use e-filing must accept electronic service, except when personal service is required by law or where any party is self-represented.
Pursuant to CCP § 1010.6 and local Rule 3.4 which references General Order 2020-GEN-018-00 issued June 11, 2020, the Court orders all parties who use e-filing to accept electronic service, except in those circumstances when personal service is required by law or where any of the parties are self-represented.
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Page 3 | Law and Motion
All parties using e-filing must accept electronic service, except when personal service is required by law or any party is self-represented.
Pursuant to CCP § 1010.6 and local Rule 3.4 which references General Order 2020-GEN-018-00 issued June 11, 2020, the Court orders all parties who use e-filing to accept electronic service, except in those circumstances when personal service is required by law or where any of the parties are self-represented.
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Page 3
Filing Fees and Waivers
The Court provides an official court reporter only to parties who have obtained a fee waiver.
The Court does not provide a court reporter absent a fee waiver.
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Page 7 | Clerk's Office And Court Support Services
Court reporters are provided only with fee waiver; request via FW-020 10 calendar days before hearing.
The Court does not provide a court reporter absent a fee waiver. A party who has received a fee waiver pursuant to CRC 3.55(7) may request an official court reporter by filing form FW-020 at least 10 calendar days before the hearing or trial.
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Pre-Motion Conference Requirements
Parties must meet and confer before filing any motion in limine per 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 6 | Motions in Limine
The parties are encouraged to schedule an IDC before filing a discovery motion, and absent good cause the Court may continue any discovery motion filed before an IDC is conducted (sentence truncated across page break).
The Court requires all discovery motion, and absent a showing of good cause, the Court may continue any discovery motion filed before an informal discovery conference (IDC) is conducted. Accordingly, the parties are encouraged to schedule an IDC before incurring the expense of filing a discovery motion.
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Page 2 | Discovery
Parties must meet and confer before filing any motion in limine per Local 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 6
Chambers Communication Rules
Counsel must call or email the Courtroom Assistant at SMCDEPT511@lacourt.ca.gov to schedule an informal discovery conference and be prepared with three possible dates.
Counsel shall call or email the Courtroom Assistant (SMCDEPT511@lacourt.ca.gov) to schedule an IDC. Please be prepared with three possible dates.
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Page 2 | Discovery
Counsel intending to submit on a tentative ruling must email smcdept511@lacourt.ca.gov by 8:00 a.m. on the hearing day with the case number, submitting party identified, and a cc to opposing counsel; if all parties submit the tentative becomes the final order.
Counsel who intend to submit on the tentative shall send an email to the Court at smcdept511@lacourt.ca.gov by 8:00 a.m. the day of the hearing. The email shall include the case number and identify the party submitting, with a copy (cc) to opposing counsel. If all parties submit, the tentative ruling will become the final order. If any party does not submit, the matter will be called and the Court may modify its ruling. If no submissions are received and no appearances are made, the matter may be placed off calendar.
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Page 3 | Law and Motion
Parties must email an editable Word version of the jury instructions in the final format to be presented to the jury to the Court's resource account at SMCDept511@lacourt.ca.gov.
Please send an editable Word version to the Court's resource account (SMCDept511@lacourt.ca.gov) in the final format that will be actually presented to the jury.
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Page 7 | Joint Jury Instructions
Parties may not call the courtroom to reserve a motion date.
Please do not call the courtroom to reserve a motion date.
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Page 3 | Law and Motion
Department 511 can be contacted by phone at (213) 633-0351/0350 or email at smcdept511@lacourt.ca.gov, with courtroom hours Monday–Friday 8:30 a.m.–12:00 p.m. and 1:30 p.m.–4:30 p.m.
TELEPHONE NUMBER: (213) 633-0351/0350 EMAIL: smcdept511@lacourt.ca.gov COURTROOM HOURS: Monday through Friday 8:30 A.M. – 12:00 P.M. 1:30 P.M. – 4:30 P.M. (Closed for Lunch: 12:00 P.M. – 1:30 P.M.)
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Page 1 | Department 511 | Courtroom Information
Self-Help services are available by calling the Self-Help Center at 213-830-0845.
For Self-Help services, call the Self-Help Center at 213-830-0845.
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Page 8 | Clerk's Office And Court Support Services
Clerk's Office assistance for Stanley Mosk is available by calling 213-830-0800.
For Clerk's Office assistance, call the Court Support Service numbers: 213-830-0800 Stanley Mosk.
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Page 8 | Clerk's Office And Court Support Services
Counsel must schedule an IDC by emailing the Courtroom Assistant with three possible dates.
Counsel shall call or email the Courtroom Assistant (SMCDEPT511@lacourt.ca.gov) to schedule an IDC. Please be prepared with three possible dates.
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Page 2
Counsel submitting on tentative ruling must email court by 8 AM hearing day with case number, party, cc opposing counsel; all submit = final order.
Counsel who intend to submit on the tentative shall send an email to the Court at smcdept511@lacourt.ca.gov by 8:00 a.m. the day of the hearing. The email shall include the case number and identify the party submitting, with a copy (cc) to opposing counsel. If all parties submit, the tentative ruling will become the final order.
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Page 3
Motion hearing dates must be reserved via CRS; do not call courtroom to reserve.
Law and motion hearings are conducted beginning at 9:00 a.m. Hearing dates must be reserved through the Court’s Reservation System (CRS). Please do not call the courtroom to reserve a motion date.
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Page 3
Joint CACI instructions must be sent as editable Word file to SMCDept511@lacourt.ca.gov.
Please send an editable Word version to the Court’s resource account (SMCDept511@lacourt.ca.gov) in the final format that will be actually presented to the jury.
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Page 7
Department 511 contact phone is (213) 633-0351/0350, available during courtroom hours (8:30 AM-12 PM, 1:30 PM-4:30 PM, closed 12-1:30 PM).
TELEPHONE NUMBER: (213) 633-0351/0350 EMAIL: smcdept511@lacourt.ca.gov COURTROOM HOURS: Monday through Friday 8:30 A.M. – 12:00 P.M. 1:30 P.M. – 4:30 P.M. (Closed for Lunch: 12:00 P.M. – 1:30 P.M.)
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Page 1
Department 511 contact email is smcdept511@lacourt.ca.gov, available during courtroom hours.
EMAIL: smcdept511@lacourt.ca.gov COURTROOM HOURS: Monday through Friday 8:30 A.M. – 12:00 P.M. 1:30 P.M. – 4:30 P.M. (Closed for Lunch: 12:00 P.M. – 1:30 P.M.)
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Page 1
Free court-certified interpreters available for limited English speakers; request via website or Judicial Assistant.
Court-certified language interpreters will be provided to limited English-speaking litigants free of charge. Please make the request at the court’s website at language access services or inform the Judicial Assistant as soon as possible.
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