Judge Alan B. Honeycutt
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Summary Judgment Motions, Anti SLAPP Motions
Communication
Chambers
Phone
Chambers
Page & Word Limits2 rules
Each party/counsel shall file a trial brief not to exceed 10 pages in length
- Trial brief
- Up to 10 pages per party
Trial briefs are limited to 10 pages.
- Trial brief
- Up to 10 pages per party
Court's wording
Trial briefs: Each party/counsel shall file a trial brief not to exceed 10 pages in length 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 calculation of damages sought; 4. Any other information that may assist the court at trial.
Document Format Requirements5 rules
The caption of each motion in limine shall number them consecutively.
Formatting
- •Caption must number each motion in limine consecutively
The trial binder must be tabbed, organized into three-ring binders, and include a table of contents.
- Binding
- Tabbed three-ring binder
- Trial binder
Court's wording
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
Exhibits must be bate stamped and tabbed with exhibit numbers that correspond to those on the joint exhibit list.
Exhibits must be bate stamped and tabbed with exhibit numbers that correspond to those on the joint exhibit list.
Exhibit binders must be tabbed, internally paginated by document, and properly marked and identified as trial exhibits, organized numerically in three-ring binders.
- Binding
- Tabbed three-ring binder
- Exhibits
Formatting
- •Internally paginated by document
- •Organized numerically
Document Filing Requirements29 rules
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.
Proof of service of summons and complaint must be filed; failure leads to OSC.
Court's wording
An OSC will be set concurrently with the Case Management Conference date regarding any failure to 1) prosecute of the case, 2) filing a proof of service of the summons and complaint, 3) file request for entry of default and 4) filing a case management statement.
Motions to compel further responses must include meet and confer declaration.
- Document
- Motion to compel further responses
Must include
- •Certificate of conference
Court's wording
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).)
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.
Court's wording
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.
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).)
- Document
- Motion to compel further responses
Must include
- •Certificate of conference
(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.
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).
Court's wording
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).
Motions in limine must comply with CCP §1005 and include declaration under Local Rule 3.57(a).
Court's wording
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).
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.
Court's wording
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.
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).
Court's wording
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).
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.
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.
Court's wording
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.
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:
- Document
- Trial binder
Must include
- •Table of contents
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.
Court's wording
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.
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.
However, hard copy exhibit binders are required to be in the courtroom on the day trial commences.
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).
Original deposition transcripts are to be lodged with the clerk on the first day of trial.
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 calculation of damages sought; 4. Any other information that may assist the court at trial.
- Document
- Trial brief
Include
- •Legal argument
The caption of each motion in limine shall number them consecutively. Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.
- Document
- Motion in limine
- Placement
- Caption
Counsel and any self-represented parties shall also meet and confer prior to the FSC to try and reasonably stipulate to a joint statement of the case, motions in limine, legal issues, authentication/foundation/admissibility of exhibits, witnesses, witness time estimates, jury instructions, and verdict forms.
Parties shall be prepared to provide the Court with reasonable and accurate time estimates for trial as prescribed under Local Rule 3.25(h).
In jury trials, the parties must jointly file a numerically organized list of proposed jury instructions identifying agreed and contested instructions, with a space for the judge to mark whether each was given.
Court's wording
e. List of Proposed Jury Instructions (Joint and Contested): For jury trials, 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. The list of proposed jury instructions must include a space by each instruction for the judge to indicate whether the instruction was given.
C. Joint Statement of Case: For jury trials, the parties/counsel shall work together to prepare and file a joint written statement of the case for the Court to read to the jury.
In jury trials, the parties must prepare a complete set of full-text proposed jury instructions edited from CACI with party names inserted and blanks removed, with special instructions in jury-ready format showing only the instruction number and text.
Court's wording
f. Jury Instructions (Joint and Contested): For jury trials, the parties/counsel shall prepare a complete set of full text proposed jury instructions, editing all proposed California Civil Jury Instructions (CACI) and insert party name(s) and eliminate blanks and irrelevant materials. The parties/counsel shall prepare special instructions in a format ready for submission to the jury with the instruction number, and text only (i.e. there should§ be no boxes or other indication on the printed instruction itself as to the requesting party).
The parties/counsel shall mark all non-documentary exhibits and insert a simple written description of the exhibit with a corresponding numerical tab in the exhibit binder.
Tab B: Motions in Limine, Oppositions, and Replies. Tab C: Joint Statement of Case (for jury trials only). Tab D: Joint Witness List with Time Estimates. Tab E: Joint Exhibit List. Tab F: Proposed Jury Instructions List (for jury trials only). Tab G: Joint and Contested Jury Instructions. Tab H: Joint and/or Contested Special Verdict Form(s). Tab I: Joint Chart of Page and Line Designations for Deposition and Former Testimony. Tab J: Copies of Operative Pleadings (Complaint, Answer, Cross-Complaint, Answer).
- Document
- Trial binder
Include
- •Exhibit list
Parties/counsel should also be prepared with an electronic flash drive containing the proposed jury instructions at the time of trial for modifications
If there are unique issues a party wishes to have the Court task, a short list of questions may be proposed. (The Court initially conducts voir dire, followed by parties/counsel.)
Filing & Service rules
Electronic Filing Rules
All documents must be e-filed prior to the hearing date per Local Rule 3.4.
Fi il ngs: All documents are to be e-filed prior to the hearing date. (Local Rule 3.4.)
Page 1 | GENERAL INFORMATION
All documents must be electronically filed prior to the hearing date pursuant to Local Rule 3.4.
All documents are to be e-filed prior to the hearing date. (Local Rule 3.4.)
Page 1 | General Information
Parties must reserve law and motion hearing dates (Monday through Thursday at 9:30 a.m.) through the Court's online Court Reservation System at www.lacourt.ca.gov.
Motions are reserved/scheduled Monday through Thursday at 9:30 a.m. Parties must reserve a date for all law and motion hearings through the Court's online "Court Reservation System" www.lacourt.ca.gov.
Page 3 | Law & Motion
The moving party must e-file a supplemental brief identifying the specific discovery items that remain unresolved after the IDC.
At least five (5) court days prior to the discovery motion hearing date, the moving party shall e-file a supplemental brief identifying for the Court the specific discovery items that remain unresolved subsequent to the IDC.
Page 4 | Discovery
IDC briefs should be e-filed, individually or jointly, at least two (2) court days prior to the IDC.
IDC briefs should be e-filed, individually or jointly, at least two (2) court days prior to the IDC.
Page 4 | Discovery
The application or motion to submit documents under seal must be electronically filed and must comply with CRC Rules 2.550-2.551.
The actual application or motion to submit documents under seal must be electronically filed and comply with Cal. Rules of Court ("CRC"), Rules 2.550-2.551.
Page 2 | General Information - Documents Filed Under Seal
Filing Timing and Cure Windows
All documents are to be e-filed prior to the hearing date. (Local Rule 3.4.)
All documents are to be e-filed prior to the hearing date. (Local Rule 3.4.)
Page 1 | General Information
The supplemental brief on unresolved discovery items must be filed at least five court days before the discovery motion hearing date.
At least five (5) court days prior to the discovery motion hearing date, the moving party shall e-file a supplemental brief identifying for the Court the specific discovery items that remain unresolved subsequent to the IDC.
Page 4 | Discovery
IDC briefs should be e-filed, individually or jointly, at least two (2) court days prior to the IDC.
IDC briefs should be e-filed, individually or jointly, at least two (2) court days prior to the IDC.
Page 4 | IDC Summary Briefs
Supplemental brief for unresolved discovery disputes must be e-filed 5 court days prior to hearing.
At least five (5) court days prior to the discovery motion hearing date, the moving party shall e-file a supplemental brief identifying for the Court the specific discovery items that remain unresolved subsequent to the IDC.
Page 4 | Unresolved Discovery Disputes Following IDC
Original deposition transcripts must be lodged with clerk on first day of trial.
Original deposition transcripts are to be lodged with the clerk on the first day of trial.
Page 10 | TRIAL EXHIBIT BINDERS (REQUIRED)
IDC briefs should be e-filed, individually or jointly, at least two (2) court days prior to the IDC.
IDC briefs should be e-filed, individually or jointly, at least two (2) court days prior to the IDC.
Page 4 | Discovery
Service and Proof of Service Rules
Parties must exchange and serve all enumerated trial documents at least 5 calendar days before the FSC unless the Court orders otherwise.
Unless otherwise specified, at least 5 calendar days prior to the FSC, the parties/counsel shall exchange and serve the following trial documents:
Page 7 | 3. TRIAL DOCUMENTS
Courtesy Copy Requirements
Courtesy copies are optional but appreciated for summary judgment motions, anti-SLAPP motions, and any other motions supported by voluminous exhibits (sentence continues on page 2).
courtesy copies are not required, but are appreciated for Motions for Summary Judgement, Anti-SLAPP, and any other motions supported by voluminous exhibits or
Page 1 | General Information
Sealing & Redaction Procedures
Conditionally sealed documents must be emailed unredacted to Dept E for review.
Documents Filed Under Seal. Documents submitted conditionally under seal are to be emailed unredacted directly to Department E’s email address for review. Please see the Court’s email address above.
Page 2 | Documents Filed Under Seal
Conditionally sealed documents must be emailed unredacted directly to Department E's email address (tordepte@lacourt.ca.gov) for review.
Documents submitted conditionally under seal are to be emailed unredacted directly to Department E's email address for review. Please see the Court's email address above.
Page 2 | General Information - Documents Filed Under Seal
Motion to seal must be e-filed and comply with CRC 2.550-2.551.
Application or Motion. The actual application or motion to submit documents under seal must be electronically filed and comply with Cal. Rules of Court (“CRC”), Rules 2.550-2.551.
Page 2 | Application or Motion
Filing Bundling Requirements
Three sets of trial exhibit binders are required at trial, tabbed, paginated, in three-ring binders.
TRIAL EXHIBIT BINDERS (REQUIRED) 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). Exhibit binders must be tabbed, internally paginated by document, and properly marked and identified as trial exhibits, organized numerically in three-ring binders.
Page 10 | TRIAL EXHIBIT BINDERS (REQUIRED)
Trial binders with specified documents are required, must be tabbed, in three-ring binders with table of contents, lodged at FSC.
TRIAL BINDERS (REQUIRED) 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:
Page 10 | TRIAL BINDERS (REQUIRED)
Separate the motion, any corresponding opposition, any corresponding reply,
Separate the motion, any corresponding opposition, any corresponding reply,
Page 7 | 3. TRIAL DOCUMENTS
Pre-Motion Conference Requirements
Counsel and parties must make meaningful good-faith meet-and-confer efforts to resolve discovery disputes before resorting to discovery motions.
Counsel and parties must make all efforts to resolve discovery disputes among themselves in a courteous, reasonable, and professional manner through a credible and meaningful meet and confer process, instead of simply defaulting to expensive and cumbersome discovery motions.
Page 3 | Discovery
discovery conference (IDC) prior to the filing of any discovery motion. After completion of the mandatory good faith meet and confer process, parties can request an informal discovery conference.
discovery conference (IDC) prior to the filing of any discovery motion. After completion of the mandatory good faith meet and confer process, parties can request an informal discovery conference.
Page 4 | DISCOVERY
discovery conference (IDC) prior to the filing of any discovery motion. After completion of the mandatory good faith meet and confer process, parties can request an informal discovery conference.
discovery conference (IDC) prior to the filing of any discovery motion. After completion of the mandatory good faith meet and confer process, parties can request an informal discovery conference.
Page 4 | Discovery
Adjournment & Extension Requirements
As a matter of professional courtesy, counsel should endeavor to agree to reasonable time extensions on motions to compel pending completion of an IDC.
Professional courtesy dictates, however, that counsel endeavor to agree to reasonable time extensions pending completion of an IDC.
Page 4 | Discovery
Chambers Communication Rules
Motion dates must be reserved via online system, not by phone.
Parties must reserve a date for all law and motion hearings through the Court's online "Court Reservation System" www.lacourt.ca.gov. Please do not call the courtroom to reserve a motion date.
Page 3 | LAW & MOTION - Scheduling
Parties may not call the courtroom to reserve a motion hearing date; reservations must be made through the online Court Reservation System.
Please do not call the courtroom to reserve a motion date.
Page 3 | Law & Motion
Department E's courtroom telephone number is (310) 787-3713, reachable during courtroom hours of 8:30 a.m. to 12:00 p.m. / 1:30 p.m. to 4:30 p.m.
COURTROOM TELEPHONE: (310) 787-3713
Page 1 | Courtroom Information
COURTROOM EMAIL: tordepte@lacourt.ca.gov
COURTROOM EMAIL: tordepte@lacourt.ca.gov
Page 1 | COURTROOM INFORMATION
COURTROOM TELEPHONE: (310) 787-3713
COURTROOM TELEPHONE: (310) 787-3713
Page 1 | COURTROOM INFORMATION
Department E's courtroom email address is tordepte@lacourt.ca.gov.
COURTROOM EMAIL: tordepte@lacourt.ca.gov
Page 1 | Courtroom Information
Voluntary settlement conferences in Dept E are scheduled by contacting the department and speaking with the courtroom assistant or judicial assistant.
To schedule a VSC, contact Dept E and speak with the courtroom assistant or judicial assistant.
Page 1 | Alternative Dispute Resolution
If all parties are prepared to submit on the tentative ruling, they may contact the Judicial Assistant to have the tentative ruling adopted as the ruling.
If all parties are prepared to submit on the tentative, contact the Judicial Assistant and the Tentative Ruling will be adopted as the ruling.
Page 3 | Law & Motion
To schedule an informal discovery conference, contact Dept E and speak with the courtroom assistant or judicial assistant; IDCs are generally conducted via LACourtConnect at 1:30 p.m. on any day the Court is not in trial.
To schedule an IDC, contact Dept E and speak with the courtroom assistant or judicial assistant. Generally, IDCs are conducted via LACourtConnect at 1:30 p.m any day the Court is not in trial.
Page 4 | Discovery