Los Angeles Superior Court Document Filing Requirements

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Proposed sealing order

Proposed sealing orders must state non-conclusory, express facts supporting sealing, separately identify each proposed redaction by document name, page, and line number, and include a 'Granted'/'Denied' ruling space for the court.

The proposed sealing order must state proposed non-conclusory, express facts supporting sealing. (CRC 2.550(d), (c)(1)(A).) "Non-conclusory" means findings more specific than merely repeating the wording of CRC 2.550, subdivisions (d)(1-5). Without repeating the language of each proposed redaction, the proposed sealing order must separately identify by document name, page, and line number each and every proposed redaction. For each proposed redaction, the proposed sealing order must, akin to a ruling sheet, contain immediately to the right a space for the court to mark "Granted" or "Denied" for each proposed redaction.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Trial brief

Each party must file a trial brief succinctly identifying the claims and defenses in dispute, the major legal issues with authorities, the relief and damages calculation, and any other helpful information.

Each party shall file a trial brief succinctly identifying: (1) the claims and defenses that remain in dispute for trial; (2) the major legal issues (with supporting points and authorities); (3) the relief and calculation of damages sought; and (4) any other information that may assist the court at trial.

Checked and corrected to match the court's document on Sep 20, 2026CRITICAL

Applies to

Witness list

Witnesses not on the joint witness list are subject to exclusion from testifying except for impeachment or rebuttal, and a party seeking to call an unlisted witness must first show good cause to the court.

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 ===== PAGE 8 ===== rebuttal testimony. Any party who seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the court.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Exhibit list

Parties must jointly prepare and file a joint exhibit list with specified columns for each exhibit offered at trial, including stipulations to authentication and admissibility, objections, and marking/admission dates.

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 for each exhibit any party intends to offer at trial: (1) the exhibit number; (2) a brief description of the exhibit; (3) which party is offering the exhibit; (4) whether the parties have stipulated to authentication of the exhibit; (5) whether the parties have stipulated to admissibility of the exhibit; (6) any evidentiary objections to admission of the exhibit; (7) the date the exhibit was marked for identification; and, (8) the date the exhibit was admitted into evidence.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Joint chart deposition testimony

Designation columns in the joint chart must include witness number/name, date and type of testimony, page/line designations, objections, counter-designation status, and the court's ruling.

In the joint chart, each designating party's designations of deposition or former testimony shall include columns which state: (1) the designation number and name of the witness; (2) the date and type of testimony (e.g., deposition or trial testimony); (3) the page and line designations of the deposition or former testimony requested to be used; (4) any objections; (5) whether the other party has counter-designated any additional deposition or former testimony of the witness that relates to the designation, and, if so, the designation number of the counter-designation; and, (6) the court's ruling.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Joint chart deposition testimony

Counter-designation columns in the joint chart must include witness number/name, date and type of testimony, page/line counter-designations, objections, the related designation number, and the court's ruling.

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.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Motion in limine

Must include

caption

Each motion in limine caption must concisely identify the evidence sought to be excluded.

The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to exclude.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Motion in limine

Multiple motions in limine from a party must be numbered consecutively.

Parties filing more than one motion in limine shall number them consecutively.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Trial binder

The Trial Binder must include a table of contents with specified tabs: Trial Briefs, Joint Witness List, Joint Exhibit List, Deposition Designations chart, and Operative Pleadings.

a table of contents that includes the following: Tab A: Trial Briefs Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab E: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Trial brief

Each party must file a trial brief identifying remaining claims and defenses, major legal issues with authorities, relief and damages sought, and other information useful at trial.

Each party shall file a trial brief succinctly identifying: (1) the claims and defenses that remain in dispute for trial; (2) the major legal issues (with supporting points and authorities); (3) the relief and calculation of damages sought; and, (4) any other information that may assist the court at trial.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Witness list

Any party eliciting testimony from a witness not on the witness list must first show good cause to the court.

Any party who seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the court.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Exhibit list

Parties and self-represented litigants must prepare and file a joint exhibit list containing specified columns for each trial exhibit and must meet and confer to resolve authenticity and admissibility objections.

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 for each exhibit any party intends to offer at trial: (1) the exhibit number; (2) a brief description of the exhibit; (3) which party is offering the exhibit; (4) whether the parties have stipulated to authentication of the exhibit; (5) whether the parties have stipulated to admissibility of the exhibit; (6) any evidentiary objections to admission of the exhibit; (7) the date the exhibit was marked for identification; and, (8) the date the exhibit was admitted into evidence. (Local Rule 3.25, subd. (g)(6).) As set forth above, the parties' counsel and any self-represented parties shall meet and confer to try to resolve objections to the authenticity and admissibility of each exhibit.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Jury instructions

For jury trials, parties must prepare and file a joint list of proposed jury instructions stating number, title, requesting party, agreed/contested status, objections, and whether given by the court.

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 for each proposed jury instruction: (1) the jury instruction number (listed in numerical order); (2) the title of the jury instruction; (3) the party requesting the jury instruction; (4) whether the jury instruction is agreed upon or contested; (5) a concise statement of any objection; and, (6) whether the jury instruction was given by the court ("Joint List of Proposed Jury Instructions").

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Jury instructions

For jury trials, parties must prepare a complete set of full-text proposed jury instructions, editing CACI instructions, inserting party names, and eliminating blanks and inapplicable material.

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.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Verdict form

For jury trials, parties must jointly file a proposed verdict form, or each party must separately file one if no agreement is reached, and the court expects use of the applicable CACI special verdict form.

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, subd. (g)(8).) If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form. When a special verdict form is requested, if there is an appropriate CACI special verdict form for a cause of action, affirmative defense, or other finding, the court expects the parties to use the CACI special verdict form.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Motion in limine

Motions in limine must be noticed for hearing at the Final Status Conference.

Motions in limine shall be noticed for hearing at the Final Status Conference.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Trial binder

The Trial Binder must include a table of contents with Tabs A through I; for bench trials without a jury, only Tabs A, B, C, H, and I are required.

a table of contents that includes the following (for bench trials without a jury, the Trial Binder shall only include the documents listed under Tabs A, B, C, H, and I): 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 and Line Designations for Deposition and Former Testimony Tab I: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Jury instructions

Proposed jury instructions behind Tab F must be organized into three labeled groups in a specified order.

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.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Demurrer

Must include

certificate of conference

A demurrer must include the required meet and confer declaration per CCP § 430.41.

The demurrer must contain the required declaration regarding the meet and confer per CCP § 430.41.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Motion

All motions must be reserved through the Court Reservation System on the Court’s website.

All motions must be reserved via Court Reservation System (CRS) on the Court’s website at www.lacourt.ca.gov under “Online Services, Court Reservation System.”

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Joint proposed special verdict form

Counsel must prepare and lodge the joint proposed special verdict form directly in Department 412; it must not be e-filed and must be lodged before the matter is taken under submission.

Joint Proposed Special Verdict Form to be prepared by counsel and lodged directly in Department 412 (no e-filing) before the matter will be taken under submission.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Trial brief

Each party or counsel must file a trial brief identifying the claims and defenses, major legal issues with supporting authorities, claimed relief and damages calculation, and other information helpful to the Court.

Each party/counsel shall file a trial brief succinctly identifying: 1. The claims and defenses subject to litigation 2. The major legal issues (with supporting points & authorities) 3. The relief claimed and calculation of damages sought 4. Any other information that may assist the Court at Trial.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Motion in limine

Each motion in limine must have a caption that concisely identifies the evidence the moving party seeks to preclude.

The caption of each motion-in-limine shall concisely identify the evidence that the moving party seeks to preclude.

Checked and corrected to match the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Joint witness list

The parties must jointly file an alphabetized witness list identifying each witness, expert status, estimated examination lengths, and total testimony hours.

The parties/counsel shall work together to prepare and file a joint list of all witnesses arranged alphabetically by last name. The joint witness list shall identify each witness by full name, specify which witnesses are experts, estimate the length of the direct, cross examination and re- direct examination of each, and include a total of the number of hours for all witness testimony.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Proposed jury instruction list

The parties must jointly file a numerically ordered list identifying agreed and contested proposed jury instructions.

The parties/counsel shall jointly prepare and file a list of proposed jury instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Proposed jury instructions

After the case-in-chief, counsel must prepare a complete, unedited set of full-text proposed jury instructions.

After the case-in-chief, counsel to prepare a complete set of full-text proposed jury instructions without edits.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Proposed jury instructions

At closing, counsel must have a complete set of full-text proposed instructions with California Civil Jury Instructions edited to insert party names and remove blanks, brackets, and irrelevant material.

At closing, counsel shall then have prepared a complete set of full-text proposed jury instructions, editing all proposed California Civil Jury Instructions and inserting party name(s) and eliminating blanks, brackets and irrelevant material.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Special jury instructions

Special instructions must be jury-ready and contain only the instruction number, title, and text, without markings identifying the requesting party.

The parties/counsel shall prepare any special instructions in a format ready for submission to the jury with the instruction number, title, and text only (i.e. there should be no boxes or other indication on the printed instruction itself as to the requesting party).

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Proposed verdict form

The parties must jointly file an agreed general or special verdict form with interrogatories, or separately file proposed forms if they cannot agree.

The parties/counsel shall prepare and jointly file a proposed general verdict form or special verdict form (with interrogatories) acceptable to all sides (L.A. County Rule 3.25(g)(8)). If the parties/counsel cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Joint exhibit list

The parties must file a joint exhibit list with columns for the exhibit, offering party, authenticity or admissibility stipulation, identification date, and admission date.

The parties/counsel shall prepare and file a joint exhibit list organized with columns identifying: (1) the exhibit, (2) the party offering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) the date on which the exhibit was identified in court and (5) the date on which the exhibit was admitted.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Exhibit binder

If exhibits were not exchanged electronically, counsel must provide an exhibit binder to each opposing party.

Counsel must also supply an exhibit binder(s) to each opposing party if not exchanged electronically.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Testimony designation chart

When deposition or former trial testimony will replace live testimony, the parties must meet and confer and jointly file a chart of designations, objections, counter-designations, responses, and the Court’s ruling.

If the parties/counsel intend to use deposition testimony or former trial testimony in lieu of any witnesses’ live testimony, the parties/counsel shall meet & confer and jointly prepare and file a chart for each of the following: (1) the page and line designations of the deposition or former testimony requested for use (2) objections (3) counter-designations (4) and responses thereto and (5) the Court’s ruling.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Motion in limine

Each party must use a distinct numbering or lettering designation for its motions in limine to avoid duplication and confusion.

THE PARTIES MUST ASSIGN DIFFERENT NUMBERS OR LETTERS TO THEIR MOTIONS IN LIMINE (e.g., Plaintiff’s motions in limine may be numbered 1-5; Defendant’s motions in limine may be lettered A-E; additional parties may use double numbers or letters or some other agreed-upon designation to avoid duplication and confusion.)

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Trial documents

Trial Documents must comply with Los Angeles Superior Court Rule 3.25(f)–(h).

The Trial Documents must comply with LA Superior Court Rule 3.25 (f)-(h).

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Joint list of stipulated facts

The parties must file a joint list of all relevant undisputed facts.

The parties must file a joint list of all relevant facts not in dispute.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Joint statement of relief requested

The parties must file a joint statement of requested relief itemizing each party’s claimed damages and amounts, except emotional-distress and punitive damages need not be itemized.

The parties must file a Joint Statement of Relief Requested, including itemization of all elements of damages claimed, if any, by each party, and the amount; no itemization is required for emotional distress and punitive damages.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Joint written statement of case

For jury trials, the parties must file a joint written case statement for the Court to read to the jury panel.

For jury trials, the parties must file a Joint Written Statement of the Case for the Court to read to the jury panel.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Joint witness list

The parties must file a joint witness list identifying each party’s intended witnesses, excluding impeachment witnesses.

The parties must file a Joint Witness List, identifying the witnesses each party intends to call, except for impeachment witnesses.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Joint witness list

The joint witness list must identify each testifying witness’s name and type and estimate the time for each examination and for the witness overall.

The Joint Witness List must include the name of each witness who is actually going to testify, whether that person is a fact witness or an expert witness, and the expected length of the direct and redirect, the cross-examination and recross-examination, and the total time for that witness.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Joint witness list

The joint witness list must end with the total witness time and time estimates for jury selection, opening, and closing.

At the end of the list, the parties must provide a total time for the witnesses plus the time estimates for jury selection, opening and closing.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Undisclosed witnesses may not be called unless good cause is shown.

Unless good cause is shown, no undisclosed witnesses may be called.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Joint list of proposed jury instructions

The parties must file a numerically organized joint list of proposed jury instructions identifying agreed and contested instructions.

The parties must file a Joint List of Proposed Jury Instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Joint list of proposed jury instructions

The joint jury-instruction list must provide a space for the Court’s disposition of each instruction and a place for the Court to date and sign it.

The Joint List of Jury Instructions must include a space by each instruction for the Court to indicate whether the instruction was given, not given or given as modified. It must also provide a place for the Court to date and sign the list.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Proposed jury instructions

The parties must prepare complete, full-text proposed jury instructions, editing proposed CACI instructions to insert party names and remove blanks and irrelevant material.

The parties must prepare a complete set of full-text proposed Jury Instructions, editing all proposed Judicial Council of California Civil Jury Instructions (“CACI”) to insert party names and eliminate blanks and irrelevant material.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Proposed joint verdict form

The parties must file a proposed joint general or special verdict form, with interrogatories for a special verdict, acceptable to all sides.

The parties must file a proposed Joint General Verdict form or a proposed Joint Special Verdict form (with interrogatories) acceptable to all sides.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Proposed verdict form

If good-faith efforts do not resolve verdict-form differences, each party must bracket and bold disputed wording or separately file a proposed form when too much is disputed.

If, after making a good faith effort to resolve differences, the parties cannot agree on the verdict form, each party must either (a) insert the disputed wording in bold brackets, or (b) separately file a proposed verdict form if too much of the verdict form is in dispute (e.g., because a ruling on a motion in limine is needed to resolve the issue).

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Joint exhibit list

The initial joint exhibit-list exchange must state for each exhibit whether it may be admitted without objection or, if not, the ground for objection.

The initial exchange of the Joint Exhibit List must include a column in which the parties indicate whether the particular exhibit may be admitted without objection or, if not, the ground for the objection.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Jury questionnaire

A requested jury questionnaire must be exchanged sufficiently before the FSC for opposing parties to propose questions, and the filed questionnaire must be joint.

If either party requests a jury questionnaire, it must be exchanged sufficiently in advance of the FSC so the opposing parties may propose additional questions. The questionnaire filed must be a joint questionnaire.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Exhibit binder

Each nondocumentary exhibit must be marked and accompanied by a brief written description behind its corresponding numerical tab in the exhibit binder.

The parties must mark all nondocumentary exhibits (e.g. a CD) and insert a brief written description of the exhibit behind the corresponding numerical tab in the exhibit binder.

Checked against the court's document on Oct 3, 2026CRITICAL

Civil cases

Applies to

Opening statement exhibit or aid

Counsel must show each other party any exhibit or visual or auditory aid intended for use in opening statement at or before the FSC.

Any exhibit or other visual or auditory aid that counsel wishes to use in opening statement must be shown to each other party at or in advance of the FSC.

Checked against the court's document on Oct 3, 2026CRITICAL

Applies to

Joint chart of page and line designations

The parties must attach the designated transcript pages to the joint chart, using numbered tabs to separate each deposition or trial transcript.

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.

Checked against the court's document on Oct 3, 2026CRITICAL

Applies to

Meet and confer

Counsel and self-represented parties must meet and confer no later than 11 calendar days before the Final Status Conference on the specified trial-preparation matters.

No later than 11 calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall meet and confer to do the following: (1) discuss and prepare the documents required in Sections 2.B-H below, and the Motions in Limine Binder, Exhibit Binders, and Trial Binder required in Sections 3-5 below, (2) discuss and make a good faith effort to stipulate to the authenticity and admissibility of each trial exhibit, (3) discuss and make a good faith effort to stipulate to resolve each motion in limine, (4) discuss and make a good faith effort to stipulate to ultimate facts and legal issues, and (5) discuss and make a good faith effort to settle the case.

Checked against the court's document on Oct 3, 2026CRITICAL

Applies to

Trial brief

Trial briefs are mandatory and must contain a brief description of the claims, defenses, and issues, along with ultimate facts or issues for stipulation.

1. TRIAL BRIEFS: File and lodge five (5) court days before the FSC and shall not exceed fifteen (15) pages. Trial briefs are mandatory in all cases and shall include: 1. A brief description of the claims and defenses presented and the issues to be decided. 2. Statement of ultimate facts or issues to which you will stipulate.

Checked against the court's document on Oct 3, 2026CRITICAL

Applies to

Joint witness list

The joint witness list must use the specified columns for witness identity and accommodations, calling party, expected testimony, testimony description, and estimated examination times.

The joint witness list shall be organized with columns (in the format set forth below) which state (1) the name of each witness (in alphabetical order), if the witness is being called to testify as an expert, and any special requirements or accommodations needed for the witness (e.g., interpreter), (2) the party calling the witness, (3) whether the witness is actually expected to testify, (4) a brief description of the witness’s expected testimony, (5) an estimate of the length of direct examination (in hours), (6) an estimate of the length of cross-examination (in hours), and (7) the total estimated length of examination (in hours).

Checked against the court's document on Oct 3, 2026CRITICAL

Applies to

Trial brief

Trial briefs must also address established facts, contested factual and legal issues, evidentiary issues, requested relief and damages, other helpful information, opening-statement time, and any intended mini opening in jury trials.

3. Those facts established by admissions in pleadings, by discovery and/or stipulation by counsel. 4. All contested issues of fact. 5. All contested issues of law, together with points and authorities supporting the party’s position. 6. A list of major evidentiary issues anticipated and points and authorities in support of the party’s position. 7. A detailed statement of the relief claimed including a breakdown of the elements of damages claimed. 8. Any other information that will assist the Court. 9. Time estimate of opening statement. 10. Confirm whether the party and/or counsel intends to make a mini opening statement (applies only to jury trials).

Checked against the court's document on Oct 3, 2026CRITICAL

Applies to

Statement of the case

Counsel must meet and confer to prepare a joint, short, non-argumentative statement suitable for reading to the jury and lodge it five court days before the FSC.

2. STATEMENT OF THE CASE: File and lodge five (5) court days before the FSC Counsel shall meet and confer to prepare a JOINT short, non-argumentative written statement of the case suitable to be read to the jury and shall lodge the Statement of the Case five (5) court days prior to the FSC.

Checked against the court's document on Oct 3, 2026CRITICAL

Applies to

Proposed voir dire questions

The parties must serve and file proposed voir dire questions for the Court five court days before the FSC.

Five (5) court days prior to the FSC the partes shall serve and file proposed Voir Dire questions for the Court.

Checked against the court's document on Oct 3, 2026CRITICAL

Applies to

Joint witness list

The joint witness list must include the grand total of estimated witness testimony time in its last column.

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.

Checked against the court's document on Oct 3, 2026CRITICAL

Applies to

Verdict form

Counsel must meet and confer to prepare a joint general or special verdict form for the jury.

Counsel shall meet and confer to prepare a JOINT General Verdict Form or Special Verdict Form to be presented to the jury.

Checked against the court's document on Oct 3, 2026CRITICAL

Applies to

Joint chart of page and line designations

The designating party’s portion of the joint chart must include columns for each specified designation, witness, testimony, objection, counter-designation, and ruling detail.

In the joint chart, each designating party’s designations of deposition or former testimony shall include columns which state: (1) the designation number and name of the witness, (2) the date and type of testimony (e.g., deposition or trial testimony), (3) the page and line designations of the deposition or former testimony requested to be used, (4) any objections, (5) whether the other party has counter-designated any additional deposition or former testimony of the witness that relates to the designation, and, if so, the designation number of the counter-designation, and (6) the court’s ruling.

Checked against the court's document on Oct 3, 2026CRITICAL

Applies to

Joint chart of page and line designations

The counter-designating party’s portion of the joint chart must include columns for each specified counter-designation, witness, testimony, objection, related designation, and ruling detail.

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.

Checked against the court's document on Oct 3, 2026CRITICAL

Applies to

Motion in limine

Each motion in limine caption must concisely identify the evidence the moving party seeks to exclude.

The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to exclude.

Checked against the court's document on Oct 3, 2026CRITICAL

Applies to

Motion in limine

Parties filing multiple motions in limine must number them consecutively.

Parties filing more than one motion in limine shall number them consecutively.

Checked against the court's document on Oct 3, 2026CRITICAL

Applies to

Exhibits

The Judicial Assistant’s Exhibit Binder copy must have a yellow evidence tag on each exhibit, filled in only with the case number and exhibit number.

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.

Checked against the court's document on Oct 3, 2026CRITICAL

Applies to

Exhibits

One set of Exhibit Binders must be brought to the Final Status Conference for the court’s review.

The parties’ counsel and any self-represented parties shall bring one set of the Exhibit Binders to the Final Status Conference for the court to review.

Checked against the court's document on Oct 3, 2026CRITICAL

Applies to

Trial binder

Tab J of the Trial Binder must contain motions in limine unless they are too voluminous and require a separate binder.

Tab J: Motions in Limine, unless they are too voluminous and require their own binder.

Checked against the court's document on Oct 3, 2026CRITICAL

Applies to

Jury instructions

Proposed jury instructions behind Tab F must be grouped in the specified order and labeled with cover sheets.

The parties shall organize proposed jury instructions into groups behind Tab F in the following order (labeled by cover sheets): (1) agreed-upon instructions, (2) plaintiff’s requested instructions to which defendant objects, and (3) defendant’s requested instructions to which plaintiff objects.

Checked against the court's document on Sep 20, 2026WARNING

Applies to

Informal discovery conference request

Informal discovery conference requests must be made using form LACIV 094 with a hearing date reserved on the Court Reservation System.

To request an informal discovery conference, you must use Los Angeles Superior Court form LACIV 094, and reserve a hearing date on the Court Reservation System.

Checked against the court's document on Sep 20, 2026WARNING

Applies to

Jury instructions

Proposed jury instructions must be prepared on LASC LACIV 129 form or in a Word document in the same format.

The proposed jury instructions shall be prepared on Los Angeles Superior Court form LASC LACIV 129 or in a Word document that is in the same format.

Checked against the court's document on Sep 20, 2026WARNING

Applies to

Deposition transcript

Parties must submit the designated or counter-designated transcript pages with numbered tabs separating each transcript, with each party's designations highlighted in a different color.

The parties shall submit copies of the pages of the transcripts of the deposition or former testimony they are designating or counter-designating with numbered tabs separating each deposition or trial transcript. Each designation or counter-designation shall be highlighted, with each party using a different color highlighter.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Notice of continuance cancellation withdrawal

Counsel must file a notice of continuance/cancellation/withdrawal when a motion is continued or cancelled on CRS.

If a motion is continued or cancelled on CRS, counsel must file a notice of continuance/cancellation/withdrawal.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Settled statement

Parties without a court reporter at trial must prepare and file a joint settled statement of testimony and evidence each trial day.

Parties who do not provide a court reporter for trial are required to prepare and file a joint, settled statement of the testimony and evidence admitted each day of the trial.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Statement

The IDC statement must be in pleading format and briefly summarize the dispute.

At least five (5) court days prior to the IDC, the parties must file a statement in pleading format, of no more than two (2) pages, briefly summarizing the dispute.

Checked against the court's document on Oct 3, 2026WARNING

Civil cases

Applies to

Motion in limine

Multiple motions in limine should be numbered consecutively.

Multiple motions-in-limine should be numbered consecutively.

Checked against the court's document on Oct 3, 2026WARNING

Civil cases

Applies to

Jury instructions

Jury instructions are settled after the close of evidence and before closing arguments.

Settling of jury instructions will occur after the close of evidence but before closing arguments.

Checked against the court's document on Oct 3, 2026WARNING

Civil cases

Applies to

Current operative pleadings

The current operative complaint, answer, cross-complaint, and any answer to a cross-complaint are to be included.

The operative complaint, answer, cross-complaint and answer to any cross-complaint.

Checked against the court's document on Oct 3, 2026WARNING

Civil cases

Applies to

Idc materials

Counsel must have available whatever materials are needed to make the IDC productive and successful.

Counsel are ordered to have available to them whatever materials are needed to make the IDC session productive and successful.

Checked against the court's document on Oct 3, 2026WARNING

Civil cases

Applies to

Joint written statement of case

The joint case statement should be one or two paragraphs describing the nature of the case and each party’s basic claim.

This statement should be no more than one or two paragraphs that simply inform the jury panel of the nature of the case and each party’s basic claim (e.g., a contract dispute, a discrimination claim, etc.)

Checked against the court's document on Oct 3, 2026WARNING

Civil cases

Applies to

Joint exhibit list

The initial exhibit-list exchange must occur sufficiently before the final list is due to allow a serious, good-faith meet and confer on all exhibit objections.

This exchange must take place sufficiently in advance of the day that the final Joint Exhibit List is to be filed and included in the Trial Readiness Binder so the parties will have had time to meet and confer in a serious and good faith effort to resolve all objections to each exhibit to be offered at trial.

Checked against the court's document on Oct 3, 2026WARNING

Applies to

Meet and confer

The Court will inquire about the required meet and confer, and failure to conduct it will likely result in sanctions.

The Court will specifically inquire into this meet and confer at the Final Status Conference and failure to have conducted it will likely result in sanctions.

Checked against the court's document on Oct 3, 2026WARNING

Applies to

Voir dire

Counsel may conduct reasonable voir dire, but may not precondition or indoctrinate jurors or question them about the pleadings or applicable law.

The Court will also permit counsel to conduct reasonable Voir Dire not designed to precondition or indoctrinate the jury, nor may the jurors be questioned about the pleadings or the applicable law.

Checked against the court's document on Oct 3, 2026WARNING

Applies to

Joint witness list

A witness omitted from the joint witness list may be excluded from testifying, except to give actual impeachment or rebuttal testimony.

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.

Checked against the court's document on Sep 20, 2026INFO

Applies to

Jury instructions

The court expects parties to request an appropriate CACI jury instruction rather than a specially prepared instruction.

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.

Checked against the court's document on Oct 3, 2026INFO

Civil cases

Applies to

Settlement agreement

For a conditional settlement, the parties are encouraged to include a stipulation for the Court to retain jurisdiction under CCP section 664.6.

The parties are encouraged to include a stipulation for the Court to retain jurisdiction pursuant to CCP section 664.6 if the settlement is conditional.

Checked against the court's document on Oct 3, 2026INFO

Civil cases

The parties are permitted to arrange for a privately retained court reporter at hearings.

The parties may arrange for a privately retained court reporter at hearings.

Checked against the court's document on Oct 3, 2026INFO

Civil cases

The parties are encouraged, when reasonably necessary, to accommodate requests to take witnesses out of order.

The parties are encouraged to accommodate each other with regard to taking witnesses out of order if reasonably necessary.

Checked against the court's document on Oct 3, 2026INFO

Applies to

Proposed jury instructions

When an appropriate CACI instruction exists, the court expects the parties to request it instead of a specially prepared instruction.

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.

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Applies to

Ex parte application

Ex parte applications should only be filed in cases involving "irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte." (CRC 3.1202(c).) Applicants should verify that the matter addressed may properly be sought by ex parte application and does not otherwise require a noticed motion.

Summary: Ex parte applications may only be filed where irreparable harm, immediate danger, or another statutory basis exists under CRC 3.1202(c), and applicants must verify the matter is proper for ex parte relief rather than a noticed motion.

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Applies to

Motion to compel further responses

Must include

certificate of conference ?

As a reminder, motions to compel further responses must be accompanied by a meet and confer declaration stating facts that show a reasonable and good faith attempt was made to informally resolve each issue presented by the motion. (CCP § 2016.040; Local Rule, Appendix 3.A (2024).)

Summary: Motions to compel further responses must be accompanied by a meet and confer declaration showing a reasonable and good faith attempt to informally resolve each issue presented.

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Applies to

Trial preparation order

Counsel and parties are expected to follow and comply with the Court's "Standing Order: Dept E re Final Status Conference - Trial Preparation Order" ("Standing Order"), which will be included in the minute order at the time the initial trial date is set. (See attached Standing Order.) Failure to comply with the Standing Order may result in sanctions and a delay in trial.

Summary: Counsel and parties must comply with the Dept E Standing Order re Final Status Conference - Trial Preparation Order; failure to comply may result in sanctions and a delay in trial.

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Applies to

Bench trial submissions ?

(Note: Bench trials do not require submission of jury instructions, however, substantive CACI instructions must be submitted, together with special verdict forms that the Court may use in crafting a decision.

Summary: Bench trials do not require jury instructions, but substantive CACI instructions together with special verdict forms must be submitted.

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Applies to

Joint trial binder

Counsel and any self-represented parties are ordered to meet and confer prior to the FSC to exchange, discuss, and prepare for submission to the Court, at least five (5) court days in advance of the FSC, a joint trial binder(s) and joint trial exhibit binder(s). The Court will verify at the FSC that all parties/counsel have met and conferred to prepare joint trial documents.

Summary: Parties must meet and confer before the FSC and submit joint trial binder(s) and joint trial exhibit binder(s) to the Court at least five court days in advance of the FSC.

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Applies to

Motion in limine

Motions in limine are to be noticed with due statutory notice for the date of the FSC. Before filing motions in limine, the parties/counsel shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and be accompanied by the required declaration prescribed under Local Rule 3.57(a).

Summary: Motions in limine must be noticed with due statutory notice for the FSC date, comply with CCP section 1005, and be accompanied by the declaration required under Local Rule 3.57(a).

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Applies to

Joint witness list

d. Joint Witness List: The parties/counsel shall work together to prepare and file a joint list of all witnesses in alphabetical order by last name that each party intends to call (excluding impeachment and rebuttal witnesses). The joint witness list shall identify each witness by name, specify which witnesses are experts, and estimate the length of direct examination, cross examination, and re-direct examination (if any) of each witness. The parties/counsel shall identify all potential witness scheduling issues and special requirements. The list must be signed by each counsel or non-represented litigant with the understanding that the parties can expect to be held to the estimates in accordance with Local Rule 3.25(h).

Summary: The parties must jointly file a signed witness list in alphabetical order identifying each witness, experts, examination time estimates, and scheduling issues, with parties held to the estimates per Local Rule 3.25(h).

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Applies to

Special verdict form

For both jury and bench trials, the parties/counsel shall prepare and jointly file a proposed special verdict form acceptable to all sides. If the parties/counsel cannot agree on a joint special verdict form, each party must separately file a proposed verdict from. Verdict forms are required even though the parties may waive jury.

Summary: Parties must jointly file a proposed special verdict form for both jury and bench trials, or file separate proposed forms if agreement cannot be reached, and verdict forms are required even if the jury is waived.

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Applies to

Joint exhibit list

The parties/counsel shall prepare and file a joint exhibit list organized with columns identifying each exhibit and specifying each party's evidentiary objections, if any, to admission of each exhibit. The parties/counsel shall meet and confer in an effort to resolve objections to the authenticity/foundation/admissibility of each exhibit.

Summary: Parties must file a joint exhibit list identifying each exhibit and each party's evidentiary objections, and must meet and confer to resolve authenticity/foundation/admissibility objections.

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Applies to

Deposition designation chart ?

If the parties/counsel intend to use deposition testimony or former trial testimony in lieu of any witnesses live testimony, the parties/counsel shall meet and confer and jointly prepare and file a chart with columns for each of the following: (1) The line and page designation of the deposition or former testimony requested for use, (2) Objections, (3) Counter designations, (4) Any responses, and (5) Court ruling.

Summary: If deposition or former trial testimony will be used in lieu of live testimony, parties must jointly file a designation chart containing page/line designations, objections, counter-designations, responses, and court ruling columns.

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Applies to

Trial binder

The parties/counsel shall jointly prepare and lodge with the Court at the FSC, a trial binder containing the above-described trial documents, which shall be tabbed and organized into three-ring binders with a table of contents, as noted below and in the following order:

Summary: Parties must jointly prepare and lodge a tabbed trial binder (three-ring, with table of contents) containing the required trial documents at the Final Status Conference.

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Applies to

Trial exhibit binder

Three sets of trial exhibit binders must be submitted to the Court at the time of trial (i.e., set for the trial court, clerk, and witnesses).

Summary: Three sets of trial exhibit binders (for the trial court, clerk, and witnesses) must be submitted to the Court at the time of trial.

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Applies to

Joint exhibit list ?

The parties/counsel shall have a joint signed exhibit list and electronic copies of their respective exhibits at the FSC, then the parties/counsel will not be required to produce exhibit binders at the FSC.

Summary: Parties must bring a joint signed exhibit list and electronic copies of their exhibits to the FSC, and if they do, exhibit binders are not required at the FSC.

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Applies to

Trial exhibit binder ?

However, hard copy exhibit binders are required to be in the courtroom on the day trial commences.

Summary: Hard copy exhibit binders must be in the courtroom on the day trial commences.

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Applies to

Original deposition transcripts

Original deposition transcripts are to be lodged with the clerk on the first day of trial.

Summary: Original deposition transcripts must be lodged with the clerk on the first day of trial.

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Civil cases

Applies to

Ex parte application

Ex parte applications are reserved for exigent circumstances and must comply with Rules of Court, rule 3.1202(c): "An applicant must make an a irmative 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.

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Civil cases

Applies to

Motion in limine

Parties filing more than one motion in limine shall number them consecutively.

Summary: Parties filing more than one motion in limine must number the motions consecutively.

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Civil cases

Applies to

Motion in limine opposition and reply ?

Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.

Summary: Opposition and reply papers on motions in limine must identify the corresponding motion number in the caption.

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Civil cases

Applies to

Court reporter stipulation or appointment order ?

Official court reporters are not assigned to Civil Courtrooms. It is the responsibility of the parties to provide their own Court Reporter for hearings and trial. 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 provide their own court reporter for hearings and trial and file either a Stipulation and Order to use a Certified Shorthand Reporter or an Order Appointing a Court Approved Reporter as Official Reporter Pro Tempore before the hearing is called.

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Civil cases

Applies to

Case management statement

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 conference.

Summary: Parties must file a case management statement on Judicial Council Form CM-110 no later than 15 calendar days before the case management conference.

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Civil cases

Applies to

Motion or application ?

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. (Cal. Rules of Court, rule 3.110.)

Summary: A filing concerning incomplete service must explain why service has not been completed, document the efforts made to complete service, and specify the proposed completion date (Cal. Rules of Court, rule 3.110).

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Civil cases

Applies to

Ex parte application ?

Must include

proposed order

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 comply with CRC 3.1200 et seq., submit a proposed order, and pay the filing fee before appearing in court.

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Civil cases

Applies to

Ex parte application

Ex parte applications are reserved for exigent circumstances. The applicant shall comply with California Rules of Court, 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.

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Civil cases

Applies to

Request for informal discovery conference ?

The parties are instructed to file their Request for an IDC using Form LACIV-094.

Summary: Requests for an Informal Discovery Conference must be filed using Form LACIV-094.

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Civil cases

Applies to

Idc brief

At least five (5) calendar days before the IDC, the parties shall file IDC briefs not to exceed five (5) pages that succinctly summarize the nature of the dispute, the necessity for the discovery, the basis for any objection or withholding of information,

Summary: IDC briefs must succinctly summarize the nature of the dispute, the necessity for the discovery, the basis for any objection or withholding of information, and (continuing on the next page) the deadline for the filing of any motion to compel further responses.

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Civil cases

Applies to

Trial brief

Trial Briefs – Each party shall file a trial brief 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 you will stipulate; (5) the major evidentiary issues anticipated; and (6) any other information that may assist the Court at trial.

Summary: Each party must file a trial brief identifying the claims and defenses, legal and factual issues with supporting points and authorities, relief and damages calculation, stipulated facts, anticipated evidentiary issues, and other trial-assisting information.

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Civil cases

Applies to

Joint statement

Joint Statement – For jury trials, the parties shall prepare a joint written statement of the case for the Court to read to the jury. The statement should not exceed two paragraphs. The parties and counsel shall sign the joint statement. If the parties cannot agree on a joint statement after a good faith meet-and-confer session conducted in person, over the phone, or via videoconference, each party must separately file a proposed joint statement.

Summary: For jury trials, the parties must file a signed joint statement of the case not exceeding two paragraphs, or, if no agreement is reached after a good faith meet-and-confer, each party must separately file a proposed joint statement.

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Civil cases

Applies to

Joint witness list

Joint Witness List – The parties shall work together and file a joint list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. The joint witness list shall identify each witness by name, specify which witnesses are experts, estimate the length of direct examination, cross-examination, and re-direct examination of each, and include a total of the number of hours for all witness testimony. The parties shall identify all potential witness scheduling issues and special requirements. The parties and counsel shall sign the joint witness list.

Summary: The parties must file a signed joint witness list (excluding impeachment and rebuttal witnesses) identifying each witness by name, expert status, estimated examination times, total testimony hours, and any scheduling issues or special requirements.

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Civil cases

Applies to

Joint list of proposed jury instructions

Joint List of Proposed Jury Instructions – The parties shall jointly prepare and file a joint list of proposed jury instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any. The parties and counsel shall sign the joint list of proposed jury instructions.

Summary: The parties must jointly prepare and file a signed joint list of proposed jury instructions, organized in numerical order, identifying agreed and contested instructions.

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Civil cases

Applies to

Full text jury instructions ?

Jury Instructions (Joint and Contested) – The parties shall prepare a complete set of full-text proposed jury instructions. The submitted full-text instructions shall be appropriately edited to include all case-specific information requested in Judicial Council of California Civil Jury

Summary: The parties must prepare a complete set of full-text proposed jury instructions edited to include all case-specific information requested in the Judicial Council of California Civil Jury Instructions.

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Civil cases

Applies to

Proposed verdict form

The parties shall prepare and file a joint proposed general verdict form or special verdict form (with interrogatories). If the parties cannot agree on a joint verdict form after a good faith meet-and-confer session conducted in person, over the phone, or via videoconference, each party must separately file a proposed verdict form.

Summary: Parties must file a joint proposed verdict form, or if they cannot agree after a good faith meet-and-confer, each party must separately file a proposed verdict form.

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Civil cases

Applies to

Joint exhibit list

The parties shall prepare and file a joint exhibit list organized with columns identifying: (1) the exhibit, (2) which party is offering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) the date on which the exhibit was identified, and (5) the date on which the exhibit was admitted. Prior to filing the joint exhibit list, the parties shall meet and confer in person, over the phone, or via videoconference to determine whether they will stipulate to the authenticity and/or admissibility of each exhibit or whether there are objections to any exhibit. If there are stipulations, the parties shall note that in the respective column. If not, the objecting party shall specify all objections in the respective column. The parties and counsel shall sign the joint exhibit list.

Summary: Parties must file a joint exhibit list with five required columns, meet and confer before filing to identify stipulations or objections, and sign the list.

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Civil cases

Applies to

Deposition designation chart ?

If the parties intend to use deposition testimony or former trial testimony in lieu of any witness's live testimony, the parties shall meet and confer and jointly prepare and file a chart with columns for each of the following: (1) the page and line designations of the deposition or former testimony requested for use, (2) objections, (3) counter-designations, (4) any responses thereto, and (5) the Court's rulings. The objecting party shall specify all objections in the respective column. The parties and counsel shall sign the designations.

Summary: Parties using deposition or former trial testimony in lieu of live testimony must meet and confer and jointly file a designation chart with five required columns, signed by the parties and counsel.

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Civil cases

Applies to

Motion in limine

When filing motions in limine, the parties must comply with Local Rule 3.57, including the required declaration, if applicable.

Summary: Motions in limine must comply with Local Rule 3.57, including the required declaration if applicable.

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Civil cases

Applies to

Motions in limine binder ?

The binder also must contain a table of contents identifying each motion in limine, opposition, and reply, and the corresponding tab for each.

Summary: The motions in limine binder must include a table of contents identifying each motion, opposition, reply, and corresponding tab.

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Applies to

Court reporter form ?

If you require a court reporter, you must provide your own. The following forms must be filed in the courtroom prior to the judge calling your case: Form LACIV237, if the court reporter is listed on the court's Pro Tempore Court Reporter Directory; or, Form LACIV236, if the court reporter is not listed on said directory.

Summary: Parties must provide their own court reporters and file Form LACIV237 (reporter on the Pro Tempore directory) or Form LACIV236 (reporter not on the directory) in the courtroom before the judge calls the case.

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Applies to

Ex parte application

Must include

proposed order

Please note that the Court may not consider ex parte applications submitted/filed without a proposed order.

Summary: The Court may not consider ex parte applications that are filed without a proposed order.

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Applies to

Motion in limine

All parties must meet and confer on all motions in limine prior to filing said motions. Failure by any party or counsel to exchange or discuss any motion in limine may result in the refusal by the Court to hear any such motion in limine, pursuant to applicable court rules.

Summary: All parties must meet and confer on motions in limine before filing them; failure to do so may result in the court refusing to hear the motion.

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Applies to

Trial brief

Trial briefs are mandatory for all (both Court and jury) trials and must include the following information and not exceed 20 pages: 1) A brief description of each cause of action and key affirmative defenses presented and the issues to be decided; 2) Statement of ultimate facts or issues to which you will stipulate;

Summary: Trial briefs must include a description of each cause of action and key affirmative defenses, the issues to be decided, and a statement of ultimate facts or issues to be stipulated (required-content list continues beyond this excerpt).

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Applies to

Joint pretrial statement ?

4) All contested issues of fact; 5) All contested issues of law, together with points and authorities supporting the position of the parties; 6) A list of major evidentiary issues anticipated, any relevant points and authorities supporting the position of the parties; 7) A detailed statement of the damages and relief claimed, including a specific breakdown of the elements of damages claimed and the amount sought; and, 8) Any other information that will assist the Court.

Summary: The joint statement must include contested issues of fact and law with supporting authorities, major evidentiary issues, a detailed breakdown of damages and relief claimed, and any other information assisting the Court.

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Applies to

Witness list

The jointly prepared Witness List must include the name of each witness, an estimate of time for direct and cross-examination, and the total amount of time of all witness testimony combined for the entire trial. Potential scheduling problems must be noted.

Summary: The joint witness list must name each witness, estimate direct and cross-examination time, give total combined testimony time, and note potential scheduling problems.

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Applies to

Exhibit list

All parties must jointly prepare and exchange a completed Exhibit List, indicating each document and item of physical evidence, and whether there is a stipulation to authenticity and/or admissibility.

Summary: All parties must jointly prepare and exchange a completed exhibit list indicating each document, physical evidence item, and any stipulation to authenticity and/or admissibility.

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Applies to

Exhibits

Each exhibit shall be numbered or lettered. All parties shall agree in advance that their respective party will have a range of exhibit numbers or letters (e.g. Plaintiff No. 1: 1-99; Plaintiff No. 2: 100-199; Defendant: A-Z). Each exhibit must be separately identified. Subparts to an exhibit (e.g., 1A, 1B, etc.) must also be identified and listed separately. Each page of a multi-page exhibit must be consecutively paginated.

Summary: Exhibits must be numbered or lettered from pre-agreed party-specific ranges, separately identified (including subparts listed separately), with each page of multi-page exhibits consecutively paginated.

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Applies to

Exhibits

All items so referred to in the Exhibit List must be exchanged and/or reviewed by each counsel or the parties prior to the FSC.

Summary: All items referenced in the exhibit list must be exchanged and/or reviewed by counsel or the parties before the Final Status Conference.

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Applies to

Discovery material list ?

Each party must prepare a list of discovery material intended to be used at trial, including but not limited to interrogatories and requests for admissions and any responses thereto as well as deposition(s), all of which shall specifically identify the date, document, page and line.

Summary: Each party must prepare a list of discovery material intended for use at trial, specifically identifying the date, document, page, and line for each item.

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Applies to

Deposition originals ?

If depositions or other discovery responses are intended to be used at trial, originals shall be lodged with the Court at the time of trial.

Summary: Originals of depositions or discovery responses intended to be used at trial must be lodged with the Court at the time of trial.

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Applies to

Exhibit objections ?

Any party objecting to any listed exhibit, either as to foundation or admissibility, must first meet and confer prior to trial. Any objections not so discussed in the meet and confer shall be deemed waived except upon a showing of good cause.

Summary: Parties objecting to a listed exhibit on foundation or admissibility grounds must meet and confer before trial, and objections not raised in the meet and confer are deemed waived absent good cause.

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Applies to

Statement of the case

The parties shall submit a printed copy of the jointly prepared, short, non-argumentative written statement of the case to be read to the jury.

Summary: Parties must submit a printed, short, non-argumentative joint written statement of the case to be read to the jury.

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Applies to

Jury instructions

A jointly submitted packet of all requested and properly edited jury instructions to which there is no objection.

Summary: Jury instructions must include a jointly submitted packet of all requested, properly edited, unopposed instructions.

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Applies to

Jury instructions

Each party shall also submit specifically requested and properly edited instructions not requested by the opposing counsel/party. These instructions shall be inserted into the aforementioned packet of the jointly submitted jury instructions, all to be considered and discussed by the Court at an appropriate time during the pendency of the trial.

Summary: Each party must also submit its own specifically requested, properly edited instructions and insert them into the jointly submitted packet.

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Applies to

Special verdict form

A special verdict form is mandatory and shall be jointly prepared in final form. Verdict forms shall be clear and direct to avoid any juror confusion.

Summary: A special verdict form is mandatory, must be jointly prepared in final form, and must be clear and direct to avoid juror confusion.

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Applies to

Trial binder

For all jury trials, the parties/counsel shall jointly prepare and lodge a trial binder with the Court at least two (2) calendar days before the FSC, containing the required trial documents, tabbed and organized into 3-ring binders, with a Table of Contents in the front of each binder, as follows:

Summary: For jury trials, the parties must jointly prepare and lodge a tabbed 3-ring trial binder with a Table of Contents, with required documents organized under Tabs A-G (trial briefs, joint witness list, joint statement to the jury, joint exhibit list, jury instruction list, jury instructions, and verdict forms); trial binders are required for jury trials but discretionary for court trials.

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Applies to

Exhibit notebook

All exhibits sought to be admitted by the parties shall be placed in Exhibit Notebooks. On the first day of trial, the parties are ordered to jointly submit five identical copies of the Exhibit Notebooks as follows: one for each party, two for the Court, and one for the witness stand.

Summary: All exhibits must be placed in Exhibit Notebooks, and on the first day of trial the parties must jointly submit five identical copies (one per party, two for the Court, one for the witness stand).

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Applies to

Trial brief

TRIAL BRIEFS. (optional for jury trials, mandatory for bench trials).

Summary: Trial briefs are optional for jury trials and mandatory for bench trials.

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Applies to

Joint statement of case ?

A jointly prepared, short, non-argumentative written statement of the case to be read to the jury. Local Rule 3.25 (g)(4).

Summary: Jury trials require a jointly prepared, short, non-argumentative written statement of the case to be read to the jury per Local Rule 3.25(g)(4).

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Applies to

Joint witness list

All witnesses, other than those to be called exclusively for impeachment or rebuttal, must be identified on one list. Do not repeat the name of a witness who will be called by more than one party. The joint witness list must (1) identify each witness by name, (2) specify which witnesses are experts, (3) briefly describe the expected testimony, and (4) estimate the length of the direct, cross-examination and re-direct examination (if any) of each witness. In an additional column, the parties must total the time estimated for each witness’s testimony. At the bottom of the witness list, the parties must total the time for all witnesses on direct, cross, and redirect. Make realistic time estimates.

Summary: The joint witness list must identify all witnesses (other than impeachment/rebuttal) on one list with name, expert status, expected testimony, per-witness time estimates, and time totals.

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Applies to

Joint witness list ?

Identify all potential witness scheduling issues and special requirements, including interpreters on the witness list. Any party seeking to elicit testimony from a witness for other than impeachment or rebuttal who is not identified on the witness list must first make a showing of good cause to the court.

Summary: Witness scheduling issues and special requirements (including interpreters) must be identified on the witness list, and calling an unlisted witness (other than for impeachment/rebuttal) requires a prior good cause showing.

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Applies to

Joint exhibit list ?

All exhibits, other than those to be used exclusively for impeachment or rebuttal, must be listed on the list, identified by a number and brief description. The parties/counsel shall meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit. The exhibit list must have a column labeled “Objections”. If any party has any objection to the admissibility of any exhibit, the objecting party must be identified, and the grounds for the objection must be set forth in the “Objections” column next to that exhibit. The exhibit list must have two columns on the far right labeled “DATE ID’d” and “DATE ADMITTED” in which the Court Clerk may note the dates of identification and admission of each exhibit.

Summary: The joint exhibit list must identify all exhibits by number and description, include Objections, DATE ID'd, and DATE ADMITTED columns, and the parties must meet and confer to resolve authenticity and admissibility objections.

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Applies to

Joint proposed jury instructions ?

The parties/counsel shall jointly prepare and file one list of proposed jury instructions, organized in CACI numerical order. The instruction list must have 5 columns

Summary: Parties must jointly prepare and file one list of proposed jury instructions organized in CACI numerical order with 5 columns.

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Applies to

Proposed jury instructions

The parties/counsel shall jointly prepare a complete set of full text proposed jury instructions, editing all proposed CACI, inserting party name(s) and all other information, filling in all blanks, and eliminating all brackets and irrelevant bracketed language.

Summary: Parties/counsel must jointly prepare a complete set of full-text proposed jury instructions with CACI edits, party names inserted, blanks filled, and brackets eliminated.

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Applies to

Proposed special verdict form

The proposed special verdict form must be joint. If the parties cannot agree on each question on a proposed verdict form, they must agree on what they can and put contested questions in brackets. Any proposed special verdict should be in form that is easily used by the jury, and which does not require the jury to answer unnecessary questions.

Summary: The proposed special verdict form must be joint, with contested questions bracketed, and in a form easily used by the jury without unnecessary questions.

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Applies to

Deposition designation chart ?

If the parties/counsel intend to use deposition testimony or former trial testimony in lieu of any witness’s live testimony, other than exclusively for impeachment or rebuttal, the parties/counsel shall meet and confer and jointly prepare and file a chart with columns for each of the following: (1) the name of the witness; (2) the date and type of testimony (e.g., deposition or trial); (3) the line and page designations of the testimony requested for use, (4) any objections, (5) any related counter-designations by line and page, (6) any responses thereto, and (7) the Court’s ruling.

Summary: Parties intending to use deposition or former trial testimony (other than exclusively for impeachment or rebuttal) must meet and confer and jointly file a designation chart with seven specified columns.

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Applies to

Motion in limine

Each motion in limine for the purpose of precluding the mention or display of inadmissible and prejudicial matters in the presence of the jury shall be accompanied by a declaration in compliance with the requirements of Rule 3.57 of the Local Rules and must comply with Kelly v. New West Federal Savings (1996) 49 Cal. App.4th 659, 670-71.

Summary: Motions in limine seeking to preclude inadmissible/prejudicial matters before the jury must be accompanied by a declaration complying with Local Rule 3.57 and Kelly v. New West Federal Savings.

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Applies to

Motion in limine

The parties must assign different, sequential numbers or letters to their motions in limine and the party opposing the motion must identify to which motion the opposition applies. For example, Plaintiff’s motions in limine may be numbered 1-5; Defendant’s motions in limine may be lettered A-E; additional parties may use double numbers or letters or some other agreed-upon designation to avoid duplication and confusion.

Summary: Each party must assign different, sequential numbers or letters to its motions in limine (e.g., Plaintiff 1-5, Defendant A-E), and oppositions must identify which motion they oppose.

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Applies to

Joint motions in limine statement ?

If the parties file, collectively, more than five (5) motions in limine, they must file a joint document at least four (4) court days before the final status conference that (a) describes the motion, (b) has a one- paragraph argument in support and (c) has a one-paragraph argument in opposition.

Summary: If more than five motions in limine are filed collectively, the parties must file a joint document at least 4 court days before the final status conference describing each motion with a one-paragraph argument in support and a one-paragraph argument in opposition.

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Applies to

Court trial submissions ?

The parties must submit trial briefs, a joint exhibit list, and a joint witness list, as described above. The parties must also comply with the provisions above concerning designation of deposition and former testimony and concerning motions in limine, if any.

Summary: For court trials, parties must submit trial briefs, a joint exhibit list, and a joint witness list, and comply with the deposition designation and motions in limine provisions.

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Applies to

Trial readiness binder ?

The binder must contain conformed copies of the trial briefs, joint statement of the case. joint witness list, joint exhibit list, joint list of jury instructions, joint full-text jury instructions (organized as agreed-upon, plaintiff’s requested to which defendant objects and defendant’s requested to which plaintiff objects), joint verdict form, joint page-line designation chart, motions

Summary: The Trial Readiness Binder must contain conformed copies of the trial briefs, joint statement of the case, joint witness and exhibit lists, joint jury instructions (agreed and contested), joint verdict form, joint page-line designation chart, and motions (list continues beyond provided text).

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Applies to

Daily settled statement

The parties must meet and confer to discuss whether they plan to have a court reporter transcribe the trial proceedings. In order to ensure a proper record for appellate purposes, if the parties do not arrange for a court reporter, then counsel for the parties will be required to prepare a daily settled statement summarizing witnesses’ testimony who have testified each day at trial.

Summary: Parties must meet and confer about arranging a court reporter; if no court reporter is arranged, counsel must prepare a daily settled statement summarizing each day's witness testimony.

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Applies to

Ex parte application ?

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).) You will need to demonstrate to the court the reason(s) why you cannot seek the requested relief by other means, such as a noticed motion or continuance of the trial.

Summary: Ex parte applications must affirmatively show irreparable harm, immediate danger, or another statutory basis for relief, and must demonstrate why the relief cannot be sought by other means such as a noticed motion or trial continuance.

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Applies to

Motion in limine

Must include

certificate of conference ?

motions in limine must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party, setting forth the opposing party’s position regarding the motions, and must be submitted with timely statutory notice so the motion in limine can be heard at the FSC. Motions in limine may be heard at the FSC unless the Court orders otherwise.

Summary: Motions in limine must include a sworn declaration describing the meet-and-confer and the opposing party's position, and must be filed with timely statutory notice so the motion can be heard at the FSC.

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Applies to

Joint witness list ?

The parties must submit a joint list of all witnesses each party actually intends to call. Next to each witness, indicate the total time estimated for that witness’s testimony (including direct, cross, and redirect). Make realistic time estimates. At the end of the list, total the time estimated for testimony.

Summary: The parties must file a joint witness list showing each witness they actually intend to call, the estimated testimony time per witness (direct, cross, redirect), and a total time estimate at the end of the list.

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Applies to

Joint witness list ?

Absent good cause, the total number of hours listed for testimony shall not exceed the trial estimate given at the case management conference, including the allocation of one day of the trial estimate for jury selection and sufficient time for opening statements and closing arguments.

Summary: Absent good cause, total estimated testimony hours on the joint witness list may not exceed the trial estimate given at the case management conference, including one day for jury selection and sufficient time for opening and closing arguments.

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Applies to

Proposed jury instructions ?

The parties are to submit a joint set of instructions, plus a set of instructions from each side to which there are objections. The parties shall provide the full text of all requested instructions (not just a list).

Summary: Parties must submit a joint set of jury instructions plus each side's disputed instructions, providing the full text of all requested instructions rather than just a list.

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Applies to

Proposed jury instructions ?

Before submitting the instructions, counsel must fill in the blanks, make appropriate modifications, and comply with SCLAC 3.170 to 3.171. Use CACI for form instructions.

Summary: Before submitting proposed jury instructions, counsel must fill in blanks, make appropriate modifications, comply with SCLAC 3.170-3.171, and use CACI for form instructions.

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Applies to

Proposed verdict forms

The parties are to meet and confer in advance and then file proposed general or special verdict forms. Use CACI model verdict forms where applicable. The Court discourages submission of competing proposed verdict forms.

Summary: Parties must meet and confer in advance and then file proposed general or special verdict forms using CACI model forms where applicable; the Court discourages competing proposed verdict forms.

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Applies to

Expert declaration ccp 2034 260 ?

As to experts that 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: For any expert counsel intends to call at trial, counsel must present the Court and opposing counsel with a CCP section 2034.260 declaration stating the substance of the proffered opinion no later than the FSC.

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Applies to

Motion for additional discovery ?

Any motion seeking to commence any additional discovery beyond sections 2-6 shall specifically identify the contemplated additional discovery and shall include a statement of the parties' respective positions regarding the same.

Summary: A motion for additional discovery beyond sections 2-6 must specifically identify the contemplated discovery and include a statement of the parties' respective positions.

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Applies to

Customer complaint list ?

The list provided by Defendant may be in the chart or spreadsheet format, and shall include the VIN, date of repair visit, dealership or other reporting location, and text of the other customers' reported complaint, but shall not include the other customers' names, addresses, phone numbers, e-mail addresses, or other personal identifying information

Summary: Defendant's list of substantially similar customer complaints may be in chart or spreadsheet format, must include VIN, repair-visit date, reporting location, and complaint text, and must exclude customers' personal identifying information.

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Applies to

Cmc statement

The parties are to (1) meet and confer—in person or by telephone—no later than 30 days before the hearing, and (2) file a CMC statement on Judicial Council Form CM-110 within five (5) days of the hearing.

Summary: Parties must file a CMC statement on Judicial Council Form CM-110 within five days of the case management conference hearing.

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Applies to

Ex parte application ?

Must include

proposed order

The notice must be included in the declaration and a proposed order must be presented with the moving papers.

Summary: Ex parte applications must include the notice in the declaration and present a proposed order with the moving papers.

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Applies to

Joint statement of witness testimony ?

Parties who do not provide a court reporter for trial are directed to meet at the close of each session and prepare a joint statement of the witness testimony presented that day. The joint statement must be lodged with the Court the next morning before proceedings resume. No exceptions.

Summary: Parties without a court reporter must prepare a joint statement of each day's witness testimony at the close of the session and lodge it with the Court the next morning before proceedings resume — no exceptions.

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Applies to

Trial brief

Each party shall file a trial brief succinctly identifying: (1) the claims and defenses that remain in dispute for trial; (2) the major legal issues (with supporting points and authorities); (3) the relief and calculation of damages sought; and (4) any other information that may assist the court at trial.

Summary: Each party must file a trial brief identifying the disputed claims and defenses, major legal issues with supporting authorities, relief and damages calculation, and any other information assisting the court at trial.

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Applies to

Joint witness list ?

The parties' counsel and any self-represented parties shall work together to prepare and file a joint list of all witnesses whom any party intends to call at trial, excluding impeachment and rebuttal witnesses.

Summary: Parties' counsel and self-represented parties must jointly prepare and file a list of all trial witnesses, excluding impeachment and rebuttal witnesses (Local Rule 3.25(g)(5)).

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Applies to

Joint witness list

The joint witness list shall be organized with columns (in the format set forth below) which state (1) the name of each witness (in alphabetical order), if the witness is being called to testify as an expert, and any special requirements or accommodations needed for the witness (e.g., interpreter), (2) the party calling the witness, (3) whether the witness is actually expected to testify, (4) a brief description of the witness's expected testimony, (5) an estimate of the length of direct examination (in hours), (6) an estimate of the length of cross-examination (in hours), and (7) the total estimated length of examination (in hours). At the end of the joint witness list, the parties and any self-represented parties shall add up the estimated times for all witnesses' testimony and state the grand total in the last column. Any witness who is not included on the joint witness list is subject to being excluded from

Summary: The joint witness list must contain seven specified columns (witness name/expert status/accommodations, calling party, expected testimony, direct/cross/total time estimates in hours) plus a grand total, and any witness not listed is subject to being excluded.

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Applies to

Joint exhibit list

The parties' counsel and any self-represented parties shall work together to prepare and file a joint exhibit list organized with columns (in the format set forth below) which state, as to each exhibit any party intends to offer at trial: (1) the exhibit number, (2) a brief description of the exhibit, (3) which party is offering the exhibit, (4) whether the parties have stipulated to authentication of the exhibit, (5) whether the parties have stipulated to admissibility of the exhibit, (6) any evidentiary objections to admission of the exhibit, (7) the date the exhibit was marked for identification, and (8) the date the exhibit was admitted into evidence. (Local Rule 3.25, subd. (g)(6).) As set forth above, the parties' counsel and any self-represented parties shall meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit.

Summary: Counsel and self-represented parties must jointly prepare and file an exhibit list stating eight specified items for each trial exhibit and must meet and confer to resolve authenticity and admissibility objections.

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Applies to

Joint statement of case ?

For jury trials, the parties' counsel and any self-represented parties shall work together to prepare and file a brief, joint written statement of the case for the court to read to the jury. (Local Rule 3.25, subd. (g)(4).)

Summary: For jury trials, the parties must jointly prepare and file a brief written statement of the case for the court to read to the jury.

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Applies to

Joint list of proposed jury instructions

For jury trials, the parties' counsel and any self-represented parties shall work together to prepare and file a joint list of proposed jury instructions (in the format set forth below) which states, as to each proposed jury instruction: (1) the jury instruction number (listed in numerical order), (2) the title of the jury instruction, (3) the party requesting the jury instruction, (4) whether the jury instruction is agreed upon or contested, (5) a concise statement of any objection, and (6) whether the jury instruction was given by the court ("Joint List of Proposed Jury Instructions").

Summary: For jury trials, the parties must jointly prepare and file a list of proposed jury instructions stating six specified items for each instruction.

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Applies to

Proposed jury instructions

For jury trials, the parties' counsel and any self-represented parties shall work together to prepare a complete set of full text proposed jury instructions, editing all proposed Judicial Council of California Civil Jury Instructions ("CACI") instructions, inserting party names, and eliminating blanks and other irrelevant or inapplicable material.

Summary: For jury trials, the parties must jointly prepare a complete set of full-text proposed jury instructions, editing CACI instructions, inserting party names, and removing blanks and irrelevant material.

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Applies to

Proposed verdict form

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, subd. (g)(8).) If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

Summary: For jury trials, parties must jointly file a proposed verdict form acceptable to all parties, or, if they cannot agree, each party must separately file a proposed verdict form.

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Applies to

Joint chart of page and line designations

If any parties intend to use deposition testimony or former trial testimony in lieu of or in addition to a witness's live testimony, the parties' counsel and any self-represented parties shall meet and confer to discuss, and work together to prepare and file, a joint chart in the format set forth below ("Joint Chart of Page and Line Designations for Deposition and Former Testimony").

Summary: Parties intending to use deposition or former trial testimony must meet and confer and jointly prepare and file a Joint Chart of Page and Line Designations.

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Applies to

Motion in limine ?

The parties' counsel and any self-represented parties shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and file declarations that comply with the requirements of Los Angeles County Court Rule 3.57, subdivision (a).

Summary: Motions in limine must be accompanied by declarations that comply with Los Angeles County Court Rule 3.57(a).

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Applies to

Trial binder ?

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 F: Joint and Contested Jury Instructions Tab G: Joint or Contested Verdict Form(s) Tab H: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab I: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint). Tab J: Motions in Limine, unless they are too voluminous and require their own binder.

Summary: The Trial Binder must contain tabbed sections for Trial Briefs, Joint Witness List, Joint Exhibit List, Joint Statement to the Jury, Jury Instructions, Verdict Forms, Deposition Designation Chart, Operative Pleadings, and Motions in Limine (unless too voluminous for the binder).

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Applies to

Customer complaint list ?

The list provided by defendant may be in the chart or spreadsheet format, and shall include the VIN, date of repair visit, dealership or other reporting location, and text of the other customers' reported complaint, but shall not include the other customers' names, addresses, phone numbers, e-mail addresses, or other personal identifying information.

Summary: The list of substantially similar customer complaints must be in chart or spreadsheet form including VIN, repair visit date, location, and complaint text, and must exclude all other customers' personal identifying information.

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Applies to

Document production ?

Plaintiff and defendant shall serve verification with the documents they produce.

Summary: Both plaintiff and defendant must serve a verification along with the documents they produce.

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Applies to

Joint case management conference statement addendum ?

You are ordered to meet and confer in person or by telephone and to respond to the following questions, stating your respective positions.

Summary: All parties must meet and confer in person or by telephone and respond to the addendum's questions, stating their respective positions.

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Applies to

Case management conference addendum ?

l am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this addendum, and will possess the authority to enter into stipulations on these issues at the time of the initial case management conference, including the written authority of the party where required.

Summary: The case management conference addendum must include a signed certification that the signer is fully familiar with the case, prepared to discuss discovery, ADR, and other addendum issues, and possesses authority (including written party authority where required) to enter stipulations at the initial case management conference.

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Applies to

Case management conference addendum ?

(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)

Summary: The case management conference addendum must bear the typed or printed name and signature of the party or attorney, with two signature blocks provided.

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Civil cases

Applies to

Summary judgment papers ?

When a factual claim is made in these documents, just as is the case with regard to all other kinds of motions and responsive papers, a citation to the declaration(s) and/or exhibit(s) supporting that claim assertion must be set forth next to the factual statement, NOT A REFERENCE TO THE "STATEMENT OF UNDISPUTED" FACTS WHICH HAS THE EFFECT OF DIRECTING THE COURT TO SEARCH ONE SOURCE IN ORDER TO GET TO ANOTHER SOURCE FOR EVIDENTIARY SUPPORT FOR THE FACTS IN ISSUE!

Summary: In summary judgment papers, every factual statement must be supported by a citation to the supporting declaration(s) and/or exhibit(s) placed next to the statement; citing only the 'statement of undisputed facts' is not permitted.

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Civil cases

Applies to

Original order or judgment

The Court asks that all moving parties lodge the original order or judgment that they wish the Judge in Department 636 to sign no later than the hearing set on a motion or as requested by the court after trial.

Summary: Moving parties must lodge the original order or judgment they want signed no later than the motion hearing (or as requested by the court after trial).

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Civil cases

Applies to

Original order or judgment ?

It should not say "proposed" in the caption and should not have a proof of service attached to it.

Summary: The lodged original order must not say 'proposed' in the caption and must not have a proof of service attached to it.

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Civil cases

Applies to

Motion ?

Must include

proposed order

A "proposed order" should continue to be included in the package of moving papers and served upon the parties.

Summary: A proposed order must be included in the package of moving papers and served upon the parties.

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Civil cases

Applies to

Waiver of participation

of record must be on the phone unless a waiver of participation is earlier filed.

Summary: Parties/counsel of record must participate by phone unless a waiver of participation is filed earlier.

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Civil cases

Applies to

Exhibit list

Counsel are to agree on a block of numbers to be allocated to each party for exhibits. (See LASC Local Rule 3.53) The exhibit list shall include the exhibit number and a brief description of the exhibit.

Summary: Counsel must agree on allocated blocks of exhibit numbers (per LASC Local Rule 3.53), and the exhibit list must include the exhibit number and a brief description of each exhibit.

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Civil cases

Applies to

Special verdict forms

The parties are ordered to meet and confer and file any special verdict forms.

Summary: The parties must meet and confer and file any special verdict forms.

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Civil cases

Applies to

Proposed special verdict forms ?

If no agreement is reached, each party is to submit their own proposed special verdict (or special fact finding) forms along with points and authorities supporting what is requested.

Summary: If the parties do not agree, each party must submit its own proposed special verdict (or special fact finding) forms accompanied by points and authorities supporting the request.

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Civil cases

Applies to

Trial brief

TRIAL BRIEFS – Trial Briefs are mandatory in all cases and must include: (1) a brief description of the facts and the claims and defenses presented and the issues to be decided; (2) the elements and burden of proof for each of the cause(s) of action; (3) a brief statement of ultimate facts or issues to which you will stipulate; (4) a list of major legal and evidentiary issues anticipated with succinct points and authorities supporting and defending the issues; (5) a brief statement of the relief claimed, including a succinct breakdown of the elements of damages claimed, and calculations of damages sought (do not hesitate to use bullet points); (6) a joint list of jury instructions; and (7) any further information the parties believe may assist the Court in ruling upon trial objections or matters that may arise during trial.

Summary: Trial briefs are mandatory in all cases and must include seven specified elements, including facts/issues, elements and burden of proof, stipulations, anticipated legal and evidentiary issues, relief and damages calculations, a joint list of jury instructions, and other helpful information.

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Civil cases

Applies to

Motion in limine

Must include

certificate of conference ?

Motions in Limine must be in writing, numbered, and shall be filed and served on opposing parties in accordance with Local Rule 3.25(f)(2). The motion must be accompanied by a declaration that includes, among other items, a representation that the motion has been discussed with opposing counsel. If not, the motion will be summarily denied. Boilerplate or form motions are disfavored.

Summary: Motions in Limine must be in writing, numbered, filed and served per Local Rule 3.25(f)(2), and accompanied by a declaration representing that the motion was discussed with opposing counsel, or the motion will be summarily denied; boilerplate or form motions are disfavored.

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Civil cases

Applies to

Joint statement of the case

JOINT STATEMENT OF THE CASE – For jury trials, the parties shall prepare and file a joint written statement of the case for the Court to read to the jury. The Joint Statement of the Case should be brief and factual.

Summary: In jury trials, the parties must prepare and file a brief, factual joint written statement of the case for the Court to read to the jury.

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Civil cases

Applies to

Joint witness list

JOINT WITNESS LIST – The parties shall prepare and file a joint witness list identifying all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. The joint witness list will identify each witness by name, specify which witnesses are experts, estimate the length of direct examination, cross-examination, and re-direct examination of each,

Summary: The parties must file a joint witness list identifying all intended witnesses (excluding impeachment and rebuttal), with each witness's name, expert status, and estimated direct, cross, and re-direct examination lengths.

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Civil cases

Applies to

Joint exhibit list

The parties shall prepare and file a joint exhibit list organized with columns identifying: (1) the exhibit, (2) which party is offering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) the date on which the exhibit was identified, and (5) the date on which the exhibit was admitted.

Summary: Parties must file a joint exhibit list organized with columns identifying the exhibit, offering party, stipulation to authenticity/admissibility, date identified, and date admitted.

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Civil cases

Applies to

Joint exhibit list

Prior to filing the joint exhibit list, the parties shall meet and confer to determine whether they will stipulate to the authenticity and/or admissibility of each exhibit or whether there are objections to any exhibit. If there are stipulations, the parties shall note that in the respective column. If not, the objecting party shall specify all objections in the respective column.

Summary: Parties must meet and confer before filing the joint exhibit list and note stipulations, or specify all objections, in the respective column.

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Civil cases

Applies to

Exhibit binder

The parties must also supply an exhibit binder to each opposing party. Non-documentary exhibits shall be represented in the binder with a simple written description.

Summary: Parties must supply an exhibit binder to each opposing party, with non-documentary exhibits represented by a simple written description.

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Civil cases

Applies to

Jury instructions

The parties shall prepare and file a joint list of all jury instructions requested and a copy of all requested instructions fully filled out, organized in numerical order. Those instructions not agreed upon should be filed separately and the party making the request should be identified. Not later than two days before the conclusion of evidence, the Court will require the parties to meet and confer to create a final set of instructions.

Summary: Parties must file a joint list of requested jury instructions with fully completed copies in numerical order, file disputed instructions separately identifying the requesting party, and meet and confer on a final set no later than two days before the conclusion of evidence.

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Civil cases

Applies to

Voir dire questions ?

The Court will question the prospective jurors during voir dire. The parties shall prepare and file a joint list of questions to be asked by the Court. The parties will have an opportunity to independently question the prospective jurors following the Court’s questioning.

Summary: Parties must prepare and file a joint list of voir dire questions for the Court's questioning and may independently question prospective jurors afterward.

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Civil cases

Applies to

Verdict form

The parties shall prepare and file a joint proposed general verdict form or special verdict form. The parties are urged to agree on a verdict form. If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

Summary: Parties must file a joint proposed general or special verdict form; if they cannot agree, each party must separately file a proposed verdict form.

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Civil cases

Applies to

Joint trial binder

The parties shall prepare a tabbed Joint Trial Binder for the Court to include the above-described trial briefs; operative pleadings; motions in limine in numerical order with opposition and reply for each number; joint statement of the case; joint witness list; joint exhibit list; jury instructions; voir dire questions; and verdict form(s) separately tabbed.

Summary: Parties must prepare a tabbed Joint Trial Binder containing trial briefs, operative pleadings, motions in limine (with oppositions and replies), joint statement of the case, witness list, exhibit list, jury instructions, voir dire questions, and verdict forms, separately tabbed.

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Civil cases

Applies to

Trial record ?

YOU MUST PROVIDE A COURT REPORTER FOR TRIAL (COURT AND JURY TRIAL) OR SUBMIT DAILY AGREED STATEMENTS / PROPOSED SETTLED STATEMENTS during a trial.

Summary: Parties must either provide a court reporter for court and jury trials or submit daily agreed statements/proposed settled statements during trial.

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Applies to

Notice of related cases

The Court requires timely compliance with Cal. Rules of Court 3.300 Re: Notice of Related Cases. The Notice must be filed in each related case.

Summary: A notice of related cases complying with California Rules of Court 3.300 must be timely filed in each related case.

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Applies to

Case management statement

Counsel must comply with their obligation to submit case management statements pursuant to rule 3.725 of the California Rules of Court. Failure to comply with the Cal. Rules of Court., rules 3.722, 3.724, 3.727 and 3.728, Los Angeles County Superior Court Rules 3.24 and 3.25, and/or this court's scheduling orders may result in monetary sanctions and/or delay in trial setting.

Summary: Counsel must submit case management statements per CRC 3.725, and failure to comply with related rules may result in monetary sanctions and/or delay in trial setting.

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Applies to

Request for court reporting services ?

The request must be made by using the local form (LASC LACIV 269).

Summary: A fee-waiver party's request for an official court reporter must be made on local form LASC LACIV 269 (Request for Court Reporting Services by a Party with a Fee Waiver).

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Applies to

Statement of the case

Statement of the Case: must be prepared jointly by the parties. It should be a short, non-argumentative written statement of the case to be read to the jury. It must be signed by all parties and filed with the Court.

Summary: The Statement of the Case must be jointly prepared by the parties, short and non-argumentative for reading to the jury, signed by all parties, and filed with the Court.

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Applies to

Joint witness list

witnesses' names, time estimates for direct and cross-examination, and whether the witnesses will be assisted by an interpreter. The joint witness list must be signed by all parties filed with the Court.

Summary: The joint witness list must include witnesses' names, time estimates for direct and cross-examination, and interpreter needs, and must be signed by all parties and filed with the Court.

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Applies to

Joint exhibit list

Exhibit list: must be prepared jointly by the parties. It should be prepared in chart format with each exhibit identified by title and its assigned exhibit number. Additional columns should indicate whether the exhibit will be admitted by stipulation, authenticated by stipulation, or challenged with objections, which shall be set forth in a column for objections. A final column should be included on the right for the Court's notation of whether the exhibit was admitted at trial. The joint exhibit list must be signed by all parties and filed with the Court.

Summary: The joint exhibit list must be prepared jointly in chart format with columns for exhibit title/number, stipulation status, objections, and the Court's trial notation, and must be signed by all parties and filed with the Court.

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Applies to

Depositions

Depositions: All original/certified copy of depositions must be lodge with the Court prior to the beginning of trial.

Summary: All original or certified copies of depositions must be lodged with the Court before trial begins.

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Applies to

Proposed jury instructions

List of proposed jury instructions: must be prepared jointly by the parties. It should be prepared in chart format to include all CACI and special jury instructions that are jointly proposed by the parties as well as those that are proposed by only some of the parties but opposed by another party. A column in the chart must indicate the proponent(s) and opponent(s) of each proposed instruction. A final column should be included on the right of the Court's notation of whether the instruction was given at trial. The joint list of jury instructions must be signed by all parties and filed with the Court.

Summary: The joint list of proposed jury instructions must be prepared jointly in chart format showing proponents and opponents of each instruction, and must be signed by all parties and filed with the Court.

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Applies to

Trial binder

Proposed Instructions: shall be included in the trial binder. These should include a jointly submitted packet of all requested and properly edited CACI or special instructions that are agreed to or not. The instructions shall be submitted in the proper format for presentation to the jury.

Summary: Proposed jury instructions must be included in the trial binder as a jointly submitted packet in the proper format for presentation to the jury.

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Applies to

Verdict form

Verdict Form: must be jointly prepared by the parties. If the parties cannot agree on joint verdict forms, then the Court will provide a general verdict form to the jury.

Summary: The verdict form must be jointly prepared by the parties; if they cannot agree, the Court will provide a general verdict form to the jury.

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Applies to

Trial binder

All operative pleadings: must be included in the trial binder. This includes the operative complaints and cross-complaints and the operative answers thereto.

Summary: The trial binder must include all operative pleadings, including operative complaints, cross-complaints, and the operative answers.

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Applies to

Motion in limine

All motions in limine must be in writing and must be filed and served at least 10 court days before the FSC.

Summary: Motions in limine must be in writing.

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Applies to

Opposition

Any opposition to a motion in limine must be in writing and must be filed and served at least 5 court days before the FSC.

Summary: Oppositions to motions in limine must be in writing.

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Applies to

Reply brief

Reply briefs must be in writing and properly filed and served.

Summary: Reply briefs on motions in limine must be in writing and properly filed and served.

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Applies to

Trial checklist ?

ii. A brief outline of the nature of the case; iii. Proposed questions and voir dire procedures; iv. The witness names to be read to the jury; v. Any witness or attorney scheduling issues; any witness issues (e.g., availability, need for interpreters, etc.); Any anticipated evidentiary or other legal issues; vi. Any party stipulations; and any other trial issues that the parties reasonably can anticipate.

Summary: The parties' trial submission must include a brief outline of the nature of the case, proposed voir dire questions and procedures, witness names, witness/attorney scheduling issues, anticipated evidentiary or legal issues, party stipulations, and any other anticipated trial issues.

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Applies to

Transcript of recordings ?

The parties shall comply with Cal. R. Ct. 2.1040, requiring the provision of a transcript of various recordings. The Court shall deem that the party receiving the transcript before announcing "ready" waives any objection to the accuracy of the transcript unless raised at the first trial appearance before this Court.

Summary: Parties must provide transcripts of recordings under Cal. R. Ct. 2.1040, and a party receiving the transcript before announcing ready waives any objection to its accuracy unless raised at the first trial appearance.

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Applies to

Trial setting conference joint filings ?

Counsel and/or self-represented parties are ordered to meet and confer in person or by video at least 14 calendar days in advance of the TSC and, at least 7 calendar days in advance of the hearing, jointly file (1) a statement of the issues to be tried, (2) a witness list with time estimates, and (3) a report on the status of discovery.

Summary: Parties must meet and confer at least 14 calendar days before the TSC and jointly file a statement of the issues to be tried, a witness list with time estimates, and a report on the status of discovery at least 7 calendar days before the hearing.

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Applies to

Joint witness list

The joint witness list must identify each witness by name, specify which witnesses are experts, and estimate the length of the direct, cross examination and re-direct examination (if any) of each witness. In an additional column, the parties must total the time estimated for each witness's testimony. At the bottom of the witness list, the parties must total the time for all witnesses on direct, cross, and redirect. Make realistic time estimates. Absent good cause, the total number of hours listed for testimony should not exceed the trial estimate given at the CMC, including an allocation of one day for jury selection and one day for instructions, closing arguments, and deliberations. Identify all potential witness scheduling issues and special requirements, including interpreters on the witness list.

Summary: The joint witness list must identify each witness by name, designate experts, estimate direct/cross/re-direct time with totals, and absent good cause may not exceed the CMC trial estimate, including scheduling issues and interpreter needs.

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Applies to

Exhibit list

impeachment or rebuttal, must be listed on the list, identified by a number and brief description. The parties/counsel shall meet and confer in an effort to resolve objections to the admissibility of each exhibit. The exhibit list must have a column labeled "Objections". If any party has any objection to the admissibility of any exhibit, the objecting party must be identified, and the grounds for the objection must be set forth in the "Objections" column next to that exhibit. The exhibit list must have two columns on the far right labeled "DATE ID'd" and "DATE ADMITTED" in which the Court Clerk may note the dates of identification and admission of each exhibit.

Summary: The exhibit list must identify each exhibit by number and brief description, include an 'Objections' column with objecting party and grounds, and far-right 'DATE ID'd' and 'DATE ADMITTED' columns, after a meet and confer on admissibility objections.

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Applies to

Jury instruction list ?

The parties/counsel shall jointly prepare and file one list of proposed jury instructions, organized in CACI numerical order. The instruction list must have 5 columns labeled: "CACI #," "Title," "Proposed by," "Objections By," and "Given." If all parties agree on an instruction, indicate "joint" in the "Proposed By" column, and leave the "Objections By" column blank. Otherwise, indicate the party proposing the instruction in the "Proposed By" column and the party objection to the instruction in the "Objections By" column. Leave the "Given" column blank for the Court to decide whether the instruction was given.

Summary: Parties must jointly file one list of proposed jury instructions in CACI numerical order with five specific columns for CACI number, title, proposer, objector, and court ruling.

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Applies to

Jury instructions

The parties/counsel shall jointly prepare a complete set of full text proposed jury instructions, editing all proposed CACI, inserting party name(s) and all other information, filling in all blanks, and eliminating all brackets and irrelevant bracketed language.

Summary: Parties must jointly prepare a complete set of full text proposed CACI jury instructions with party names inserted, blanks filled, and all brackets and irrelevant bracketed language eliminated.

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Applies to

Proposed verdict form ?

The proposed special verdict form must be joint. Any proposed special verdict should be in form that is easily used by the jury, and which does not require the jury to answer unnecessary questions. Submit an electronic version of the verdict form in Word on a thumb drive. Failure of the parties to agree on a proper special verdict form may result in the Court's using a general verdict form.

Summary: The proposed special verdict form must be joint, easy for the jury to use without unnecessary questions, submitted electronically in Word on a thumb drive, or the Court may use a general verdict form.

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Applies to

Page line designation chart ?

If the parties/counsel intend to use deposition testimony or former trial testimony in lieu of any witness's live testimony, other than exclusively for impeachment or rebuttal, the parties/counsel shall meet and confer and jointly prepare and file a chart with columns for each of the following: 1) the line and page designations of the deposition or former testimony requested for use, 2) objections, 3) counter-designations, 4) any responses thereto, and 5) the Court's ruling.

Summary: Parties must meet and confer and jointly file a designation chart with five required columns before using deposition or former trial testimony in lieu of live testimony (except purely for impeachment or rebuttal).

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Applies to

Motion in limine

Each motion in limine for the purpose of precluding the mention or display of inadmissible and prejudicial matters in the presence of the jury shall be accompanied by a declaration in compliance with the requirements of Rule 3.57 of the Local Rules and must comply with Kelly v. New West Federal Savings (1996) 49 Cal. App.4th 659, 670-71.

Summary: Motions in limine seeking to preclude inadmissible or prejudicial matters before the jury must be accompanied by a declaration complying with Local Rule 3.57 and Kelly v. New West Federal Savings.

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Applies to

Motion in limine

The parties must assign different, sequential numbers or letters to their motions in limine. For example, Plaintiff's motions in limine may be numbered 1-5; Defendant's motions in limine may be lettered A-E; additional parties may use double numbers or letters or some other agreed-upon designation to avoid duplication and confusion.

Summary: Parties must assign different, sequential numbers or letters to their motions in limine to avoid duplication (e.g., Plaintiff numbered, Defendant lettered).

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Applies to

Joint motion in limine document ?

If the parties file, collectively, more than five (5) motions in limine, they must file a joint document at least four (4) court days before the final status conference that (a) describes the motion, (b) has a one-paragraph argument in support and (c) has a one-paragraph argument in opposition.

Summary: When more than five motions in limine are filed collectively, the parties must file a joint document describing each motion with one-paragraph support and opposition arguments.

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Applies to

Trial briefs and joint lists ?

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

Summary: Parties must submit trial briefs, a joint exhibit list, and a joint witness list as described earlier in the order.

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Applies to

Trial readiness binder

A Trial Readiness Binder must be presented to the Court at the FSC. The binder must contain conformed copies of the trial briefs, joint statement of the case. joint witness list, joint exhibit list, joint list of jury instructions, joint full-text jury instructions, joint verdict form, joint page-line designation chart, motions in limine, and current operative pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).

Summary: A Trial Readiness Binder containing conformed copies of specified trial documents must be presented to the Court at the Final Status Conference.

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Applies to

Daily settled statement

The parties must meet and confer to discuss whether they plan to have a court reporter transcribe the trial proceedings. In order to ensure a proper record for appellate purposes, if the parties do not arrange for a court reporter, then Counsel for the parties will be required to prepare a daily settled statement summarizing witnesses' testimony who have testified each day at trial.

Summary: Parties must meet and confer about court reporter arrangements, and if none is arranged, counsel must prepare daily settled statements summarizing each day's witness testimony.

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Applies to

Revised exhibit list

At the end of the trial, counsel will be required to prepare and lodge with the court a revised exhibit list that reflects only those exhibits that have been admitted. The revised exhibit list will be provided to the jury during their deliberations.

Summary: At the end of trial, counsel must prepare and lodge a revised exhibit list reflecting only admitted exhibits, which will be provided to the jury during deliberations.

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Applies to

Ex parte application ?

PLEASE CAREFULLY REVIEW WHETHER YOU HAVE A PROPER BASIS TO SEEK 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).)

Summary: An ex parte application must affirmatively show irreparable harm, immediate danger, or another statutory basis for ex parte relief under CRC 3.1202(c).

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Applies to

Ex parte application ?

You will need to demonstrate to the court the reason(s) why you cannot seek the requested relief by other means, such as a noticed motion, or continuance of the trial.

Summary: Ex parte applicants must demonstrate why the requested relief cannot be obtained by other means, such as a noticed motion or continuance of the trial.

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Applies to

Motion in limine

Must include

certificate of conference ?

Compliance with SCLAC Rule 3.57, including the declaration and meet and confer requirements, is mandatory. Boilerplate or form motions in limine are disfavored.

Summary: Motions in limine must comply with SCLAC Rule 3.57's mandatory declaration and meet and confer requirements, and boilerplate or form motions are disfavored.

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Applies to

Joint witness list ?

The parties must submit a joint list of all witnesses each party actually intends to call. Next to each witness, indicate the total time estimated for that witness's testimony (including direct, cross, redirect). Make realistic time estimates. At the end of the list, total the time estimated for testimony.

Summary: Parties must submit a joint witness list with per-witness time estimates (direct, cross, redirect) and a total estimated testimony time at the end.

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Applies to

Joint witness list ?

Absent good cause, the total number of hours listed for testimony shall not exceed the trial estimate given at the case management conference, including the allocation of one day of the trial estimate for jury selection and sufficient time for opening statements and closing arguments.

Summary: Absent good cause, total listed testimony hours cannot exceed the trial estimate from the case management conference, including one day for jury selection and time for opening and closing arguments.

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Applies to

Deposition designation chart ?

If the parties/counsel intend to use deposition testimony or former trial testimony in lieu of any witness's live testimony, the parties/counsel shall meet and confer and jointly prepare and file a chart with columns for: 1) the line and page designations of the deposition or former testimony requested, 2) objections, 3) counter-designations, 4) any responses to the objections, and 5) the Court's ruling.

Summary: Parties using deposition or former trial testimony must meet and confer and jointly file a chart containing designations, objections, counter-designations, responses, and the Court's ruling.

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Applies to

Jury instructions ?

The parties shall provide the full text of all requested instructions (not just a list). Before submitting the instructions, counsel must fill in the blanks, make any appropriate modifications, and comply with SCLAC 3.170 - 3.171. Use CACI for form instructions.

Summary: Jury instructions must be submitted in full text (not just a list), with blanks filled in and modifications made in compliance with SCLAC 3.170-3.171, using CACI for form instructions.

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Applies to

Special verdict form

Use CACI model verdict forms where applicable. The Court requires a single, finalized special verdict form, initialed by all counsel, for use by the jury.

Summary: The Court requires a single, finalized special verdict form, initialed by all counsel, using CACI model forms where applicable.

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Applies to

Daily proceedings summary ?

If no court reporter is used, the parties must jointly prepare a summary of the day’s proceedings, and lodge it in the courtroom the next morning before proceedings resume.

Summary: If no court reporter is used at trial, the parties must jointly prepare a daily proceedings summary and lodge it in the courtroom the next morning before proceedings resume.

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Applies to

Evidentiary objections

Evidentiary objections. Counsel filing evidentiary objections in connection with a motion for summary judgment or summary adjudication shall comply with CRC, rule 3.1354.

Summary: Evidentiary objections filed in connection with a motion for summary judgment or summary adjudication must comply with CRC, rule 3.1354.

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Applies to

Daily summaries of testimony

For trials in which there is no court reporter or electronic recording, counsel are required to provide the court with daily summaries of testimony.

Summary: In trials without a court reporter or electronic recording, counsel must provide the court with daily summaries of testimony.

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Applies to

Recording transcript ?

California Rules of Court (“CRC”), rule 2.1040 requires the parties to prepare transcripts of all recordings counsel plan to introduce as an exhibit.

Summary: Parties must prepare transcripts of all recordings they plan to introduce as exhibits, per CRC rule 2.1040.

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Applies to

Recording transcript ?

The proponent of the recording must bring their transcripts to the FSC so the Court may rule on any objections to the transcripts.

Summary: The proponent of a recording must bring the transcript to the Final Status Conference so the Court can rule on any objections.

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Applies to

Recording transcript ?

Counsel is responsible for bringing copies of the transcript to pass out for the jury and alternates.

Summary: Counsel must bring copies of recording transcripts to distribute to the jury and alternates.

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Applies to

Witness list ?

Each morning, counsel must give the clerk a written list of witnesses to be called that day, their full names with correct spellings, and the order in which they will be called.

Summary: Counsel must deliver a written witness list to the clerk each morning listing that day's witnesses with their full correct names and the order in which they will be called.

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Applies to

Daily proceedings summary ?

The Court strongly encourages the parties to arrange for a court reporter for trial. If no court reporter is used, the parties must jointly prepare a summary of the day's proceedings, including a detailed summary of any witness testimony, and lodge the daily summary the next morning before proceedings resume.

Summary: If no court reporter is used at trial, the parties must jointly prepare a daily proceedings summary including detailed witness testimony and lodge it the next morning before proceedings resume.

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Applies to

Document production ?

Plaintiff and defendant shall serve verifications with the documents they produce.

Summary: Both plaintiff and defendant must serve verifications together with the documents they produce in discovery.

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Applies to

Jury instructions ?

The CACI Number and Title should be at the top of each instruction.

Summary: Each jury instruction must display the CACI number and title at the top of the instruction.

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Applies to

Jury instructions ?

Counsel are to fill in the blanks and to remove unnecessary brackets in the CACI instructions.

Summary: Counsel must fill in the blanks and remove unnecessary brackets in CACI instructions before submitting them.

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Applies to

Non caci proposed jury instructions ?

For Non-CACI instructions, the proposed instructions must contain case citations that support the party's request for inclusion of the instruction.

Summary: Proposed Non-CACI jury instructions must include case citations supporting the request for their inclusion.

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Applies to

Meet and confer declaration ?

If counsel cannot secure the participation of another party/counsel in the meet and confer discussions, counsel must (1) file a declaration detailing the efforts taken to initiate meet and confer discussions, and (2) file a separate set of Trial Readiness Documents and Trial Exhibits.

Summary: If counsel cannot secure another party's participation in the meet and confer, counsel must file a declaration detailing the efforts taken to initiate meet and confer discussions.

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Applies to

Fsc trial notebook ?

with a table of contents that includes the following: Section A: Trial Briefs Section B: Motions in Limine Section C: Joint Statement of the Case

Summary: The FSC Trial Notebook must include a table of contents with Section A (Trial Briefs), Section B (Motions in Limine), and Section C (Joint Statement of the Case).

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Applies to

Trial brief

Each party must file a trial brief, or the parties may file a joint trial brief if they wish.

Summary: Each party must file a trial brief, unless the parties instead file a joint trial brief.

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Applies to

Trial brief

Whether jointly filed by multiple parties, or separately filed by individual parties, the trial brief must include: (1) A brief description of the claims and defenses to be presented at trial; (2) A brief discussion of the major legal issues supported by relevant authority; (3) A brief discussion of any major evidentiary issues supported by relevant authority; (4) A detailed statement of the relief sought, including a breakdown of the damages, if any; (5) A brief discussion of any other information that may assist the Court at trial.

Summary: Trial briefs (joint or separate) must include five elements: description of claims/defenses, major legal issues with authority, major evidentiary issues with authority, detailed relief sought with damages breakdown, and other helpful information.

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Applies to

Motion in limine

Motions in limine may not be used as substitutes for statutorily authorized dispositive motions. (Amtower v. Photon Dynamics, Inc. (2008) 158 Cal.App.4th 1582, 1594.) A motion in limine must identify the specific evidence to which it is directed. Form or boilerplate motions in limine are strongly discouraged.

Summary: Motions in limine must identify the specific evidence targeted, may not substitute for statutorily authorized dispositive motions, and boilerplate forms are strongly discouraged.

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Applies to

Motion in limine

The caption of each motion in limine shall identify concisely the evidence the moving party seeks to preclude.

Summary: Each motion in limine's caption must concisely identify the evidence the moving party seeks to preclude.

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Applies to

Joint statement of the case ?

For jury trials, the parties shall prepare and file a joint written statement of the case for the Court to read to the jury. (Local Rules, rule 3.25(g)(4).) The purpose of the joint statement is to inform prospective jurors of the identities of the parties and the general subject matter of the trial; as such, it should be brief and should not be argumentative. If, after efforts to meet and confer, the parties cannot agree on a written joint statement, each party shall file a separate statement of the case.

Summary: In jury trials the parties must file a joint written statement of the case (brief and non-argumentative) for the court to read to the jury, or separate statements if they cannot agree after meet and confer.

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Applies to

Joint witness list

Counsel shall cooperate in the preparation of a joint list of all witnesses each party intends to call (excluding impeachment and rebuttal witnesses). (Local Rules, rule 3.25(g)(5).) The joint witness list shall identify each witness by name, specify which witnesses are experts, identify which

Summary: Counsel must jointly prepare a witness list of all intended trial witnesses (excluding impeachment and rebuttal), identifying each witness by name and expert status.

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Applies to

Joint witness list

The joint witness list must also include time estimates for any witness whose testimony is intended to be presented by playing video deposition excerpts or by reading transcripts of depositions or former testimony. All time estimates must comply with Local Rules, rule 3.25(h), which requires counsel to provide the Court with reasonable and accurate time estimates. The list must also provide a calculation of the total estimated time for the examination of all listed witnesses (i.e., a grand total).

Summary: The joint witness list must include time estimates for witnesses presented via video deposition excerpts or transcript reading, comply with Local Rule 3.25(h)'s reasonable and accurate estimate requirement, and provide a grand total of estimated examination time.

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Applies to

Joint witness list ?

The list must identify potential witness scheduling issues and special requirements, including whether any interpreters will be necessary and whether any ADA accommodation is anticipated. The list must identify whether the witness will testify remotely. A witness who is being called as expert must be identified as an expert. Counsel should include only those witnesses who are going to be called.

Summary: The joint witness list must identify scheduling issues, special requirements (interpreters, ADA accommodations), remote-testimony status, and expert witnesses, and should include only witnesses who will actually be called.

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Applies to

Joint witness list

Any witness who is not included on the joint witness list is subject to exclusion other than for purposes of giving actual impeachment or rebuttal testimony. If a party includes a witness on the list and the opposing party similarly wants the witness to be called, both parties must ensure the witness’s attendance in case the original designating party decides not to call the witness. Any party who seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause.

Summary: Witnesses not on the joint witness list are excluded except for impeachment or rebuttal testimony, both parties must ensure attendance of a mutually desired listed witness, and eliciting testimony from an unlisted witness requires a prior showing of good cause.

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Applies to

Joint exhibit list

The parties shall prepare and file a joint exhibit list organized with columns identifying each exhibit and specifying each party's evidentiary objections, if any, to the admission of each exhibit.

Summary: The parties must prepare and file a joint exhibit list with columns identifying each exhibit and stating each party's evidentiary objections.

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Applies to

Joint exhibit list ?

Objections not stated in writing on the exhibit list shall be deemed waived except upon a showing of good cause.

Summary: Evidentiary objections not stated in writing on the joint exhibit list are deemed waived unless the party shows good cause.

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Applies to

Joint exhibit list ?

A failure to file a timely exhibit list may result in the Court prohibiting the use of exhibits at trial. (Local Rules, rule 3.25(g)(3).)

Summary: Failure to file a timely joint exhibit list may result in the Court prohibiting use of exhibits at trial, per Local Rule 3.25(g)(3).

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Applies to

Exhibits

Demonstrative evidence, blow-ups, and transcripts must be marked for identification and included on the exhibit list.

Summary: Demonstrative evidence, blow-ups, and transcripts must be marked for identification and included on the joint exhibit list.

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Applies to

Transcripts of audio recordings ?

Transcripts: California Rules of Court (“CRC”), rule 2.1040 requires the parties to prepare transcripts of all audio recordings.

Summary: Under CRC rule 2.1040, the parties must prepare transcripts of all audio recordings.

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Applies to

Transcripts of audio recordings ?

The parties must meet and confer regarding the contents of any such transcripts prior to the FSC to resolve any objections. The proponent of the transcript must bring a copy of the transcripts to the FSC so the Court may rule on any objections.

Summary: The parties must meet and confer on transcript contents before the FSC to resolve objections, and the transcript proponent must bring copies to the FSC so the Court can rule on objections.

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Applies to

Joint list of proposed jury instructions ?

The parties shall prepare and file jointly a list of proposed jury instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any.

Summary: Parties must jointly prepare and file a list of proposed jury instructions organized in numerical order that identifies the agreed-upon and contested instructions.

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Applies to

Full text proposed jury instructions

For jury trials, the parties shall work together to prepare a complete set of full-text proposed jury instructions, editing all proposed CACI instructions, inserting party names, and eliminating blanks and other irrelevant or inapplicable material.

Summary: For jury trials, parties must jointly prepare a complete set of full-text proposed jury instructions, editing all CACI instructions, inserting party names, and eliminating blanks and inapplicable material.

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Applies to

Joint chart of page and line designations

If the parties intend to use deposition testimony or former trial testimony in lieu of or in addition to a witness's live testimony, the parties shall meet and confer to discuss, and work together to prepare and file, a joint chart in the format set forth below ("Joint Chart of Page and Line Designations for Deposition and Former Testimony").

Summary: If deposition or former trial testimony will be used in lieu of or in addition to live testimony, the parties must meet and confer and jointly prepare and file a Joint Chart of Page and Line Designations for Deposition and Former Testimony.

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Applies to

Joint witness list

In addition to preparing a chart of designations and counter-designations, counsel must ensure that the joint witness list (described above) includes time estimates for each witness who will be presented through prior testimony.

Summary: The joint witness list must include time estimates for each witness who will be presented through prior testimony.

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Applies to

Verdict form

The parties shall prepare and jointly file a proposed general verdict form or special verdict form (with interrogatories) acceptable to all sides. (Local Rules, rule 3.25(g)(8).) If the parties/counsel cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

Summary: Parties must jointly file a proposed general or special verdict form acceptable to all sides, or each party must separately file a proposed verdict form if they cannot agree.

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Applies to

Operative pleadings

The parties must submit conformed copies of the operative pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint.)

Summary: Parties must submit conformed copies of the operative pleadings, including the operative complaint, answer, and any cross-complaints and answers thereto.

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Civil cases

Applies to

Stipulated continuance request ?

Must include

proposed order

Requests for continuances may be made by stipulation and proposed order or, if no agreement is possible after good faith discussion among counsel in-person or by telephone, by noticed motion.

Summary: A stipulated request for continuance must include a proposed order.

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Applies to

Court reporter stipulation or appointment order ?

It is the responsibility of the parties to provide their own Court Reporter for hearings and trial. 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 provide their own court reporter and file a reporter stipulation or appointment order before the hearing is called.

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Applies to

Ex parte application ?

Must include

proposed order

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 comply with CRC 3.1200) before appearing in court.

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Applies to

Ex parte application

Ex parte applications are reserved for exigent circumstances. The applicant shall comply with California Rules of Court, 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 with an affirmative factual showing of irreparable harm, immediate danger, or another statutory basis.

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Applies to

Request for informal discovery conference ?

The parties are instructed to file their Request for an IDC using Form LACIV-094.

Summary: Requests for an Informal Discovery Conference must be filed using Form LACIV-094.

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Applies to

Joint witness list

Joint Witness List – The parties shall work together and file a joint list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. The joint witness list shall identify each witness by name, specify which witnesses are experts, estimate the length of direct examination, cross-examination, and re-direct examination of each, and include a total of the number of hours for all witness testimony. The parties shall identify all potential witness scheduling issues and special requirements. The parties and counsel shall sign the joint witness list.

Summary: Parties must file a signed joint witness list identifying each witness by name, expert status, estimated examination time, total testimony hours, and any scheduling issues or special requirements.

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Applies to

Joint list of proposed jury instructions

Joint List of Proposed Jury Instructions – The parties shall jointly prepare and file a of proposed jury instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any. The list of proposed jury instructions must include a space by each instruction for the Court to indicate whether the instruction was given. The parties and counsel shall sign the joint list of proposed jury instructions.

Summary: Parties must file a signed joint list of proposed jury instructions organized numerically, distinguishing agreed from contested instructions, with a space for the Court to mark whether each instruction was given.

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Applies to

Jury instructions

Jury Instructions (Joint and Contested) – The parties shall prepare a complete set of full-text proposed jury instructions. The parties shall prepare special instructions in a format ready for submission to the jury with the instruction number, title, and text only.

Summary: Parties must prepare a complete set of full-text proposed jury instructions, with special instructions in jury-ready format showing only the instruction number, title, and text.

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Applies to

Verdict form

Joint Verdict Forms – The parties shall prepare and file a joint proposed general verdict form or special verdict form (with interrogatories). If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

Summary: Parties must file a joint proposed general or special verdict form (with interrogatories), or if they cannot agree, each party must separately file a proposed verdict form.

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Applies to

Joint exhibit list

Joint Exhibit List – The parties shall prepare and file a joint exhibit list organized with columns identifying: (1) the exhibit, (2) which party is offering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) the date on which the exhibit was identified, and (5) the date on which the exhibit was admitted. Prior to filing the joint exhibit list, the parties shall meet and confer to determine whether they will stipulate to the authenticity and/or admissibility of each exhibit or whether there are objections to any exhibit. If there are stipulations, the parties shall note that in the respective column. If not, the objecting party shall specify all objections in the respective column. The parties and counsel shall sign the joint exhibit list.

Summary: Parties must meet and confer and file a signed joint exhibit list with specified columns for the exhibit, offering party, stipulations/objections to authenticity and admissibility, and identification/admission dates.

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Applies to

Deposition designation chart ?

Page and Line Designations for Deposition and Former Testimony – If the parties intend to use deposition testimony or former trial testimony in lieu of any witness's live testimony, the parties shall meet and confer and jointly prepare and file a chart with columns for each of the following: (1) the page and line designations of the deposition or former testimony requested for use, (2) objections, (3) counter-designations, (4) any responses thereto, and (5) the Court's rulings.

Summary: If deposition or former testimony will be used in lieu of live testimony, parties must meet and confer and jointly file a chart with columns for page/line designations, objections, counter-designations, responses, and the Court's rulings.

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Applies to

Motion in limine

Motions in limine shall not be used to seek dispositive orders that should have been sought through a motion for summary judgment, summary adjudication or judgment on the pleadings.

Summary: Motions in limine may not be used to seek dispositive orders that should have been sought via summary judgment, summary adjudication, or judgment on the pleadings.

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Applies to

Motion in limine

When filing motions in limine, the parties must comply with Local Rule 3.57, including the required declaration, if applicable.

Summary: Motions in limine must comply with Local Rule 3.57, including the required declaration where applicable.

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Applies to

Motions in limine binder ?

The binder also must contain a table of contents identifying each motion in limine, opposition, and reply, and the corresponding tab for each.

Summary: The motions-in-limine binder must include a table of contents identifying each motion, opposition, and reply with its corresponding tab.

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Applies to

Ex parte application ?

A party seeking ex parte relief must provide an affirmative showing of"irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte" (Cal. Rules of Court, Rule 3.1202 (c).) Please ensure that you have a proper basis to seek the requested relief.

Summary: Ex parte applications must include an affirmative showing of irreparable harm, immediate danger, or another statutory basis for granting relief ex parte.

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Applies to

Motion

Must include

proposed order

All noticed motions must be accompanied by a proposed order.

Summary: Every noticed motion must be accompanied by a proposed order.

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Civil cases

Applies to

Idc joint statement ?

The court requires counsel to meet and confer and file a joint statement of the issues to be discussed at the IDC.

Summary: Counsel must meet and confer and file a joint statement of the issues to be discussed at the IDC.

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Civil cases

Applies to

Motion

Counsel shall include the reservation number of the motion on the CAPTION page.

Summary: The motion's CRS reservation number must appear on the caption page.

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Civil cases

Applies to

Reply separate statement

Reply separate statements are not provided for in the Rules of Court and will not be considered.

Summary: Reply separate statements will not be considered by the court.

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Civil cases

Applies to

Ex parte application ?

PLEASE CAREFULLY REVIEW WHETHER YOU HAVE A PROPER BASIS TO SEEK 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).) You will need to demonstrate to the court the reason(s) why you cannot seek the requested relief by other means, such as a noticed motion.

Summary: Ex parte applications must affirmatively show irreparable harm, immediate danger, or another statutory basis for relief, and must demonstrate why relief cannot be sought by other means such as a noticed motion.

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Civil cases

Applies to

Exhibits

Pursuant to California Rule of Court 3.1110(f) and Local 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 to be used for impeachment or rebuttal.

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Civil cases

Applies to

Foreign language exhibits ?

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.

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Civil cases

Applies to

Joint witness list ?

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 list each witness once, with expected testimony time (direct, cross, re-direct) and total estimated time stated for each witness.

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Civil cases

Applies to

Joint jury instructions ?

Submit a joint set of instructions with 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 with all information filled in (no brackets or blanks), and disputed instructions must be submitted in separate sets identifying the proposing and opposing parties.

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Civil cases

Applies to

Jury instruction disposition table ?

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 disposition columns must be submitted with the jury instructions.

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Civil cases

Applies to

Proposed verdict form

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 on a verdict form, each party must submit its own proposed verdict form, and any special verdict must be simple and easy for the jury to use.

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Civil cases

Applies to

Motion in limine

Must include

certificate of conference ?

Local Rule 3.57 requires the parties to meet and confer before filing any motion in limine. 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)

Summary: Parties must meet and confer before filing any motion in limine, and every motion in limine must be accompanied by a sworn declaration attesting to the discussion and stating the opposing party's position.

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Civil cases

Applies to

Ccp 2034 260 expert declaration ?

If counsel or any unrepresented party intends to call an expert at trial, 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: A party intending to call an expert at trial must present to the Court and opposing counsel a CCP section 2034.260 declaration stating the substance of the proffered opinion.

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Civil cases

Applies to

Joint exhibit list

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

Summary: The parties must submit a joint exhibit list and a joint witness list.

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Applies to

Joint trial binder

All Counsel are to prepare a Joint Trial Binder which is to include the following:

Summary: All counsel must prepare a Joint Trial Binder containing the specified tabs (Trial Briefs, Motions in Limine, Joint Statement, Witness List).

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Applies to

Joint jury instructions

At the Final Status Conference, Counsel shall provide the Court with a Joint List of all Jury Instructions requested and a copy of all requested instructions fully filled out. Those instructions not agreed upon should be attached separately and the party making the request should be identified. No later than two days before the conclusion of evidence, the Court will require Counsel to meet and confer for the purpose of creating a final set of instructions. Submission of the Joint Jury Instructions shall not be deemed a waiver of any objection to the giving of an instruction on the Joint List.

Summary: At the Final Status Conference counsel must submit a Joint List of all requested jury instructions with fully completed copies, attaching disputed instructions separately with the requesting party identified, and must meet and confer no later than two days before the conclusion of evidence to create a final set of instructions, without waiving objections.

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Applies to

Proposed verdict form

The parties shall prepare and file a joint proposed general verdict form or special verdict form. The parties are urged to agree on a verdict form. If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

Summary: Parties must file a joint proposed general or special verdict form, or if they cannot agree, each party must separately file a proposed verdict form.

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Applies to

Joint exhibit list

Counsel shall submit a Joint Exhibit List beginning with the number 1 and provide three copies of the exhibit list with columns for the Clerk and the Court to use to indicate whether the exhibit is marked and received into evidence. Exhibits shall be numbered in conformance with Rules 3.52 – 3.53.

Summary: Counsel must submit a Joint Exhibit List numbered from 1 with three copies containing columns for the Clerk and Court, with exhibits numbered per Rules 3.52–3.53.

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Applies to

Joint deposition designation list

Counsel shall submit a Joint Deposition Designation List beginning with the number 1 and provide three copies of the Deposition Designation List with columns for the Clerk and the Court to use to indicate whether the Deposition Designation is admitted or not. The Joint Deposition Designation List is to include whether excerpts are stipulated or the Legal Grounds for Objections.

Summary: Counsel must submit a Joint Deposition Designation List numbered from 1 with three copies containing Clerk and Court columns, indicating whether excerpts are stipulated or the legal grounds for objections.

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Applies to

Idc joint statement ?

At least five (5) court days before the Informal Discovery Conference, the parties and counsel shall file a joint statement 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 IDC joint statement must succinctly summarize 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.

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Applies to

Ex parte application ?

Must include

proposed order

Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing.

Summary: Ex parte applicants must submit a proposed order and comply with CRC 3.1200 et seq. before appearing.

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Applies to

Ex parte application

Ex parte applications are reserved for exigent circumstances. The applicant must comply with Cal. Rule of Court, 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 (CRC 3.1202(c)).

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Applies to

Request for court reporting services

The request must be made by using the local form, Request for Court Reporting Services by a Party with Fee Waiver (LACIV 269), or Judicial Council form FW-020, and should be filed at least ten calendar days before the hearing or trial for which the reporter is requested.

Summary: A fee-waiver party's request for court reporting services must be made using local form LACIV 269 or Judicial Council form FW-020.

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Applies to

Settled statement

For trials without court reporters, parties will be ordered to jointly prepare a settled statement of the testimony and list of evidence admitted each day of the trial.

Summary: In trials without court reporters, the parties must jointly prepare a settled statement of the testimony and evidence admitted each day of trial.

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Applies to

Evidence

Unless the Court orders otherwise for good cause shown, evidence must be by declaration or request for judicial notice. (California Rules of Court, rule 3.1304.)

Summary: Evidence on law and motion must be by declaration or request for judicial notice unless the Court orders otherwise for good cause.

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Applies to

Oral testimony permission statement ?

Oral testimony will not be allowed without court permission. Parties seeking permission to introduce oral testimony must file a statement consistent with California Rules of Court, rule 3.1306. (Local Rule 3.7.)

Summary: Oral testimony is not allowed without court permission, and parties seeking permission must file a statement consistent with CRC rule 3.1306.

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Applies to

Initial discovery disclosures

All civil actions filed after January 1, 2024 are subject to the initial discovery Disclosures requirements of CCP §2016.090. The Court may enforce the requirements of section 2016.090 on its own motion or on motion by a party.

Summary: All civil actions filed after January 1, 2024 must comply with the initial discovery disclosure requirements of CCP §2016.090, which the Court may enforce on its own motion or a party's motion.

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Applies to

Ex parte notice ?

The notice must include the hearing details (date, time, and location), and a statement of what relief the ex parte applicant is seeking.

Summary: The ex parte notice must state the hearing details (date, time, and location) and the relief sought.

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Applies to

Ex parte application ?

The ex parte applicant must file a declaration containing competent testimony detailing the information given in the notice

Summary: Ex parte applicants must file a declaration containing competent testimony detailing the information given in the notice.

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Applies to

Notice of settlement

Notice of Settlement must be filed electronically by plaintiff using Judicial Council Form CM-200, even if the case settled at a judicial settlement conference.

Summary: The Notice of Settlement must be prepared on Judicial Council Form CM-200.

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Applies to

Declaration

NOTE: If a party would like to introduce an exhibit on its direct case that was not exchanged as described herein, the party must file a written declaration containing competent evidence in support of any claim that the party was unable to comply with this Court's Trial Preparation Order and with these policies and procedures.

Summary: A party seeking to introduce an unexchanged exhibit on its direct case must file a written declaration containing competent evidence of its inability to comply with the Trial Preparation Order.

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Applies to

Trial binder

All documents in the Trial Binder, except the Jury Instructions (Full Text) and the Verdict Form(s) must be signed, filed and conformed before they are put into the Trial Binder.

Summary: All Trial Binder documents must be signed, filed, and conformed before being placed in the binder, except Jury Instructions (Full Text) and Verdict Form(s).

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Applies to

Exhibits

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

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

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Applies to

Exhibits

No exhibit may be referenced by counsel or a witness unless it has been pre-marked with an exhibit number.

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Applies to

Proposed jury instructions

Self-represented parties and counsel shall prepare a list of joint and disputed jury instructions, and must also prepare a complete set of printed, full-text and edited proposed jury instructions and include them in the Trial Binder.

Summary: Self-represented parties and counsel must prepare a list of joint and disputed jury instructions plus a complete set of printed, full-text edited proposed instructions for the Trial Binder.

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Applies to

Joint verdict form

Self-represented parties and counsel shall prepare and jointly file Joint Verdict Form(s).

Summary: Self-represented parties and counsel must prepare and jointly file Joint Verdict Form(s).

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Applies to

Deposition designation pleading ?

When deposition transcript(s) or videotape(s) are to be used in lieu of live testimony (not just for impeachment), a pleading must be prepared setting out all designated testimony, objections and cross-designated testimony.

Summary: If deposition transcripts or videotapes will be used in lieu of live testimony, a pleading must set out all designated testimony, objections, and cross-designated testimony.

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Applies to

Exhibit binder

The parties shall jointly prepare three sets of evidentiary exhibit binders (a set for Judge, Judicial Assistant and Witness). The Exhibit Binders shall have labels on the front and side.

Summary: Parties must jointly prepare three sets of exhibit binders (Judge, Judicial Assistant, Witness), each labeled on the front and side.

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Applies to

Summary of daily proceedings ?

COURT REPORTERS OR SETTLED STATEMENTS: The Court encourages the parties to bring a court reporter to the courtroom for trial. If no court reporter is used, the parties shall jointly prepare a summary of each day's proceedings, and lodge it in the courtroom before proceedings resume.

Summary: If no court reporter is used at trial, the parties must jointly prepare a summary of each day's proceedings and lodge it in the courtroom before proceedings resume.

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Applies to

Daily admitted exhibit list ?

END OF COURT DAY: At the end of each trial day counsel must meet and confer and submit to the Court's judicial assistant an agreed-upon list of all exhibits admitted that day.

Summary: At the end of each trial day, counsel must meet and confer and submit an agreed-upon list of all exhibits admitted that day to the judicial assistant.

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Civil cases

Applies to

Ex parte application

Must include

proposed order ?

If the ex parte application seeks a temporary restraining order and order to show cause re preliminary injunction, the moving party must submit a proposed form of

Summary: For an ex parte application seeking a TRO and order to show cause re preliminary injunction, the moving party must submit a proposed form of order (source text is truncated mid-sentence).

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Civil cases

Applies to

Off calendar written confirmation ?

If the moving party takes a motion off calendar, the moving party shall confirm that fact in writing.

Summary: A moving party who takes a motion off calendar must confirm that fact in writing.

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Civil cases

Applies to

Opening brief

If the parties cannot agree upon a joint appendix, petitioner must bates-stamp any evidence it wants the Court to consider and submit such evidence with the Opening Brief.

Summary: If the parties cannot agree on a joint appendix, the petitioner must bates-stamp its evidence and submit it with the Opening Brief.

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Civil cases

Applies to

Opposition brief

Respondent shall, in turn, bates-stamp any evidence it wants the Court to consider (starting with the number following the petitioner's evidence) and submit such evidence with the Opposition Brief.

Summary: The respondent must bates-stamp its evidence (starting with the number following the petitioner's evidence) and submit it with the Opposition Brief.

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Civil cases

Applies to

Proposed judgment and writ of mandate ?

In accordance with Local Rule 3.231(n), the prevailing party on a prerogative writ will be ordered to prepare, serve, and ultimately file a proposed judgment and, if applicable, a proposed writ of mandate.

Summary: The prevailing party on a prerogative writ will be ordered to prepare, serve, and ultimately file a proposed judgment and, if applicable, a proposed writ of mandate.

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Civil cases

Applies to

Declaration of service efforts ?

If all defendants have not been served, plaintiff or plaintiff's counsel must submit a declaration to the court five (5) days prior to the hearing explaining what efforts have been undertaken to accomplish service. Cal. Rules of Court, rule 3.110.

Summary: If any defendant remains unserved by the CMC, plaintiff must file a declaration, at least five days before the hearing, explaining the service efforts undertaken.

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Civil cases

Applies to

Joint discovery report ?

At least five court days before the IDC, the parties shall file a joint report that succinctly sets forth the nature of the dispute, the necessity for the discovery, the justification for its non-production, and the overall status of discovery.

Summary: The parties must file a joint report at least five court days before the IDC covering the nature of the dispute, necessity for the discovery, justification for non-production, and overall discovery status.

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Civil cases

Applies to

Joint statement

In the event a motion to compel further responses is filed, the parties are required to submit a JOINT STATEMENT consisting of a four-column document set up as follows: The first column will identify the number of the discovery request; the second, the text of the discovery request; the third, the text of the response; and the fourth, brief bullet-point statements, one from each party, as to why a further response should or should not be compelled.

Summary: A motion to compel further responses must be accompanied by a four-column joint statement identifying the request number, the request text, the response text, and each party's bullet-point arguments.

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Civil cases

Applies to

Ex parte application ?

Must include

proposed order

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 with the application and pay the filing fee before appearing in court.

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Civil cases

Applies to

Ex parte application

Ex parte applications are reserved for exigent circumstances. The applicant shall comply with Cal. Rules of Court, 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 ex parte relief.

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Civil cases

Applies to

Pretrial filings ?

The parties are required to file the documents set forth in Local Rule 3.25(f) and (g) in advance of the FSC and should be familiar with Local Rules 3.48 through 3.58.

Summary: Parties must file the pretrial documents required by Local Rule 3.25(f) and (g) in advance of the Final Status Conference.

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Civil cases

Applies to

Trial brief

Trial Briefs – Each party shall file a trial brief succinctly identifying: (1) the claims and defenses subject to litigation, (2) the major legal issues (with supporting points and authorities), (3) the relief claimed and the calculation of damages sought, and (4) any other information that may assist the Court at trial.

Summary: Each party must file a trial brief identifying the claims and defenses, major legal issues with supporting points and authorities, relief claimed and damages calculation, and any other information assisting the Court.

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Civil cases

Applies to

Motion in limine

The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to admit or exclude.

Summary: The caption of each motion in limine must concisely identify the evidence the moving party seeks to admit or exclude.

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Civil cases

Applies to

Motion in limine

Parties filing more than one motion in limine shall number the motions consecutively.

Summary: Parties filing multiple motions in limine must number the motions consecutively.

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Civil cases

Applies to

Opposition and reply brief

Parties filing opposition and reply briefs shall identify the corresponding motion number in the caption of their pages.

Summary: Opposition and reply briefs on motions in limine must identify the corresponding motion number in the caption of their pages.

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Civil cases

Applies to

Joint statement of the case ?

Joint Statement – For jury trials, the parties shall prepare a joint written statement of the case for the Court to read to the jury. The parties/counsel shall sign the joint statement.

Summary: In jury trials, the parties must prepare and sign a joint written statement of the case for the Court to read to the jury.

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Civil cases

Applies to

Joint witness list

Joint Witness List – The parties shall work together and file a joint list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. The joint witness list shall identify each witness by name, specify which witnesses are experts, estimate the length of direct examination, cross-examination, and re-direct examination of each, and include a total of the number of hours for all witness testimony. The parties shall identify all potential witness scheduling issues and special requirements. The parties/counsel shall sign the joint witness list.

Summary: Parties must file a signed joint witness list (excluding impeachment and rebuttal witnesses) identifying each witness by name, designating experts, estimating direct/cross/re-direct examination times with total testimony hours, and noting scheduling issues and special requirements.

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Civil cases

Applies to

Joint list of jury instructions ?

and file a list of proposed jury instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any. The list of proposed jury instructions must include a space by each instruction for the Court to indicate whether the instruction was given. The parties/counsel shall sign the joint list of proposed jury instructions.

Summary: Parties must file a signed joint list of proposed jury instructions in numerical order identifying agreed and contested instructions, with a space by each instruction for the Court to indicate whether it was given.

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Civil cases

Applies to

Jury instructions

Jury Instructions (Joint and Contested) – The parties shall prepare a complete set of full-text proposed jury instructions. The parties shall prepare special instructions in a format ready for submission to the jury with the instruction number, title, and text only.

Summary: Parties must prepare a complete set of full-text proposed jury instructions, with special instructions formatted for submission to the jury containing only the instruction number, title, and text.

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Civil cases

Applies to

Verdict form

Joint Verdict Forms – The parties shall prepare and file a joint proposed general verdict form or special verdict form (with interrogatories). If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

Summary: Parties must prepare and file a joint proposed general or special verdict form (with interrogatories), or if they cannot agree, each party must separately file a proposed verdict form.

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Civil cases

Applies to

Joint exhibit list

Joint Exhibit List – The parties shall prepare and file a joint exhibit list organized with columns identifying: (1) the exhibit, (2) which party is offering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) the date on which the exhibit was identified, and (5) the date on which the exhibit was admitted. Prior to filing the joint exhibit list, the parties shall meet-and-confer to determine whether they will stipulate to the authenticity and/or admissibility of each exhibit or whether there are objections to any exhibit. If there are stipulations, the parties shall note that in the respective column. If not, the objecting party shall specify all objections in the respective column. The parties/counsel shall sign the joint exhibit list.

Summary: Parties must meet and confer, then file a signed joint exhibit list with columns for the exhibit, offering party, stipulations or objections to authenticity/admissibility, identification date, and admission date.

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Civil cases

Applies to

Deposition designation chart ?

Page and Line Designations for Deposition and Former Testimony – If the parties intend to use deposition testimony or former trial testimony in lieu of any witness's live testimony, the parties shall meet-and-confer and jointly prepare and file a chart with columns for each of the following: (1) the page and line designations of the deposition or former testimony requested for use, (2) objections, (3) counter-designations, (4) any responses thereto, and (5) the Court's rulings. The objecting party shall specify all objections in the respective column. The parties/counsel shall sign the designations.

Summary: If deposition or former trial testimony will be used in lieu of live testimony, the parties must meet and confer and file a signed chart listing page/line designations, objections, counter-designations, responses, and the Court's rulings.

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Civil cases

Applies to

Motion in limine

Must include

local rule certificate ?

When filing motions in limine, the parties must comply with Local Rule 3.57, including the required declaration, if applicable.

Summary: Motions in limine must comply with Local Rule 3.57, including the required declaration where applicable.

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Civil cases

Applies to

Motion in limine binder ?

The binder also must contain a table of contents identifying each motion in limine, opposition, and reply, and the corresponding tab for each.

Summary: The motions in limine binder must include a table of contents identifying each motion in limine, opposition, and reply with the corresponding tab.

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Civil cases

Applies to

Moving papers

After reserving a motion hearing date, the reservation requestor must submit the moving papers for filing with the reservation receipt number printed on the face page of the document under the caption and attach the reservation receipt as the last page.

Summary: Moving papers must be filed with the CRS reservation receipt number printed on the face page under the caption and with the reservation receipt attached as the last page.

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Civil cases

Applies to

Deposition transcripts ?

All deposition excerpts referenced in briefs must be marked on the transcripts attached as exhibits. (Cal. Rules of Court, rule 3.1116(c).)

Summary: Deposition excerpts cited in briefs must be marked on the transcripts attached as exhibits.

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Civil cases

Applies to

Ex parte application ?

The Court will only grant ex parte relief upon a showing, by admissible evidence, that the moving party will suffer “irreparable harm,” “immediate danger,” or where the moving party

Summary: Ex parte relief is granted only upon an admissible-evidence showing of irreparable harm or immediate danger (or other grounds stated in the continuation of the sentence).

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Civil cases

Applies to

Motion in limine

The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to preclude.

Summary: Each motion in limine caption must concisely identify the evidence the moving party seeks to preclude.

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Civil cases

Applies to

Opposition and reply papers

Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.

Summary: Opposition and reply papers on motions in limine must identify the corresponding motion number in the caption.

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Civil cases

Applies to

Joint statement of case ?

For jury trials, the parties shall prepare and file a joint written statement of the case for the trial court to read to the jury. (Super. Ct. L.A. County, Local Rules, rule 3.25(g)(4).)

Summary: In jury trials, parties must prepare and file a joint written statement of the case for the trial court to read to the jury.

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Civil cases

Applies to

Joint witness list

The parties shall prepare and file a joint, alphabetized by last name, list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. (Super. Ct., L.A. County, Local Rules, rule 3.25(g)(5).) The joint witness list shall identify each witness by name, specify which witnesses are non-experts and experts, estimate the length of the direct, cross examination and re-direct examination of each witness, and include a total of the number of hours for all witness testimony.

Summary: Parties must file a joint witness list, alphabetized by last name and excluding impeachment and rebuttal witnesses, that identifies each witness by name, expert status, estimated examination times, and total testimony hours.

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Civil cases

Applies to

Joint witness list ?

The parties shall identify all potential witness scheduling issues and special requirements.

Summary: Parties must identify all potential witness scheduling issues and special requirements.

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Civil cases

Applies to

List of proposed jury instructions

those contested), organized in numerical order, including columns to indicate whether an instruction is agreed to or contested. In addition, the List of Proposed Jury Instructions must include columns for a trial judge to indicate whether an instruction was given, given as modified, refused, or withdrawn. (See Cal. Rules of Court, rule 2.1055.)

Summary: The List of Proposed Jury Instructions must be organized in numerical order with columns showing whether each instruction is agreed or contested, plus columns for the trial judge to indicate given, given as modified, refused, or withdrawn.

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Civil cases

Applies to

Jury instructions

The parties shall prepare a complete set of full text proposed jury instructions in a format ready for submission to the jury, by editing all proposed California Civil Jury Instructions including inserting party name(s) and eliminating blanks, brackets, and irrelevant material.

Summary: Parties must prepare a complete set of full-text proposed jury instructions ready for submission to the jury, with party names inserted and blanks, brackets, and irrelevant material eliminated.

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Civil cases

Applies to

Jury instructions ?

The parties shall separate the instructions into groups of agreed-upon versus not-agreed-upon instructions.

Summary: Parties must separate proposed jury instructions into groups of agreed-upon versus not-agreed-upon instructions.

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Civil cases

Applies to

Verdict form

The parties shall prepare and jointly file a proposed general verdict form or special verdict form (with interrogatories) acceptable to all sides. (Super. Ct. L.A. County, Local Rules, rule 3.25(g)(8).) If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.

Summary: Parties must jointly file a proposed general or special verdict form acceptable to all sides, or, if they cannot agree, each party must separately file a proposed verdict form.

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Civil cases

Applies to

Joint exhibit list

The parties shall prepare and file a joint exhibit list organized with columns 1) identifying each exhibit, 2) specifying evidentiary objections, if any, to the admission of the exhibit (if an objection to an exhibit is not articulated on the exhibit list, the trial court may deem the exhibit admitted) 3) a blank column for the Court to enter the date the exhibit was first identified, and 4) a blank column for the Court to enter the date the exhibit was admitted.

Summary: Parties must file a joint exhibit list with columns identifying each exhibit, specifying any evidentiary objections (unarticulated objections may result in the exhibit being deemed admitted), and blanks for the Court to enter the dates the exhibit was first identified and admitted.