Judge Alexander C. D. Giza
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Ex Parte Opposition Motions, Summary Judgment Motions, Summary Adjudication Motions
Exhibits
- At Trial
Opposition to Ex Parte Application, Summary Judgment Papers, Summary Adjudication Papers
Summary Judgment Motions, Summary Adjudication Motions
Communication
Chambers
Phone
Chambers
Page & Word Limits1 rule
After meeting and conferring about available dates for an IDC, the parties should file a joint statement (no longer than 5 pages) that succinctly summarizes the nature of the dispute, necessity for the discovery, and objection or other basis for withholding the information, as well as overall status of discovery.
- Joint statement IDC
- Up to 5 pages
Document Format Requirements12 rules
All electronically filed documents must be text-searchable and bookmarked. (See operative General Order re Mandatory Electronic Filing in Civil., referenced above.)
Formatting
- •Text-searchable
- •Bookmarked
All electronically filed documents must be text-searchable and bookmarked. (See operative General Order re Mandatory Electronic Filing in Civil., referenced above.)
All deposition excerpts referenced in briefs must be marked on the transcripts attached as exhibits. (Rules of Court, rule 3.1116(c).)
Any courtesy copies of documents with declarations and/or exhibits must be tabbed. (Rules of Court, rule 3.1110(f).)
Counsel must provide a joint trial binder for the Court at the FSC. The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Motions in Limine Tab C: Joint Statement of the Case Tab D: Joint Witness List Tab E: Joint List of Jury Instructions (joint and contested) Tab F: Full Text Jury Instructions Tab G: Joint and/or Contested Verdict Forms Tab I: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab J: Operative Pleadings Tab K: Stipulations If there are more than a few motions in limine, they should be placed in a separate binder. Whether in a separate binder or Tab B, Plainti ’s should come first, followed by those of Defendant. There should be numbered tabs separating each motion and colored sheets of paper between the motion and any opposition and between the opposition and any reply.
- Binding
- Binder
Formatting
- •Tab A: Trial Briefs
- •Tab B: Motions in Limine
- •Tab D: Joint Witness List
- •Tab F: Full Text Jury Instructions
- •Tab G: Joint/Contested Verdict Forms
- •Tab I: Deposition Page/Line Designations
- •Tab J: Operative Pleadings
- •Tab K: Stipulations
- •Plaintiff's motions in limine first, then Defendant's
- •Numbered tabs between motions
- •Colored sheets between motion/opposition/reply
Exhibits must be tabbed, internally paginated, properly marked, organized numerically in three-ring binders for court, judicial assistant, and witnesses, with non-documentary exhibits described.
- Binding
- Three-ring binder
Formatting
- •Tabbed
- •Internally paginated by document
- •Properly marked
- •Organized numerically
- •Non-documentary exhibits must have written description behind numerical tab
Court's wording
The parties shall jointly prepare (and be ready to temporarily lodge for inspection at the FSC) one set of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (a set for the Court, the Judicial Assistant, and the witnesses). At trial, the parties will need additional copies of the exhibits for the Court’s clerk, for use on the witness stand, and for each counsel. The parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the exhibit binder.
The parties shall jointly prepare (and be ready to temporarily lodge for inspection at the FSC) one set of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (a set for the Court, the Judicial Assistant, and the witnesses).
- Binding
- Tabbed three-ring binder
- Exhibits
Formatting
- •Exhibits jointly prepared by the parties
- •Internally paginated by document
- •Properly marked
- •Organized numerically
The parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the exhibit binder.
- Exhibits
Formatting
- •Mark all non-documentary exhibits
Final jury instructions and verdict forms must not include citations, party identification, or attorney letterhead/markings, and must be suitable for jury deliberation.
Formatting
- •No citations to authority
- •No party identification
- •No attorney letterhead or markings
- •Suitable for jury deliberation
Court's wording
The parties are jointly responsible for the preparation of a final set of jury instructions and verdict forms after the Court rules on any disputes. The final set of jury instructions and verdict forms shall be in a format suitable for submission to the jury during deliberations, and shall not include any citations to authority, identification of the party requesting the instruction or verdict, or any letterhead or markings identifying the attorney who prepared or printed them. (LASCR 3.174).
Final jury instructions and verdict forms must be suitable for jury deliberations and may not contain citations to authority, party identification, or attorney letterhead/markings.
- Jury instructions
- Verdict forms
Formatting
- •Format must be suitable for submission to the jury during deliberations
- •No citations to authority
- •No identification of the party requesting the instruction or verdict
- •No letterhead or markings identifying the attorney who prepared or printed them
Court's wording
The final set of jury instructions and verdict forms shall be in a format suitable for submission to the jury during deliberations, and shall not include any citations to authority, identification of the party requesting the instruction or verdict, or any letterhead or markings identifying the attorney who prepared or printed them. (LASCR 3.174).
The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Motions in Limine Tab C: Joint Statement of the Case Tab D: Joint Witness List Tab E: Joint List of Jury Instructions (joint and contested) Tab F: Full Text Jury Instructions Tab G: Joint and/or Contested Verdict Forms
- Trial binder
Formatting
- •Tab A: Trial Briefs
- •Tab B: Motions in Limine
- •Tab D: Joint Witness List
- •Tab F: Full Text Jury Instructions
Whether in a separate binder or Tab B, Plainti ’s should come first, followed by those of Defendant. There should be numbered tabs separating each motion and colored sheets of paper between the motion and any opposition and between the opposition and any reply.
- Binding
- Tabbed binder
- Motion in limine
- Opposition
- Reply
Formatting
- •Numbered tabs separating each motion
Document Filing Requirements19 rules
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."
Parties filing more than one 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 opposition and reply
- Placement
- Caption
Parties must file timely Case Management Conference Statements (preferably joint) describing the case, discovery timeline, and agreements, with sanctions up to $250 per violation for noncompliance.
Court's wording
The parties must then file timely Case Management Conference Statements pursuant to Rules of Court, rule 3.725 (preferably a joint statement), describing the nature of the case, when discovery will be completed (“per code” does not assist the Court), and any agreements the parties have reached (see 19(b) of the Statement). A failure to comply with Rules of Court, rules 3.724 and 3.725 may subject the o ending counsel to sanctions of up to $250 per violation. (Rules of Court, rule 2.30.)
Parties filing opposition and reply briefs shall identify the corresponding motion number in the caption of their papers.
- Document
- Opposition and reply brief
- Placement
- Caption
The parties shall prepare a complete set of full- text proposed jury instructions, editing all proposed California Civil Jury Instructions, insert party name(s), eliminate blanks, brackets, and irrelevant material.
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 time, and scheduling issues; testimony from unlisted witnesses requires a showing of good cause.
Court's wording
The parties shall work together and file a joint list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. (Local 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 time for all witness testimony. The parties shall identify all potential witness scheduling issues and special requirements. 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 trial court. The parties/counsel shall sign the joint witness list.
Each party shall file a trial brief succinctly identifying (i) the claims and defenses subject to litigation; (ii) the major legal issues (with supporting points and authorities); (iii) the relief claimed, and calculation of damages sought; and (iv) any other information that may assist the court at trial.
- Document
- Trial brief
Must include
- •Legal argument
Parties filing more than one motion in limine shall number the motions consecutively.
The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to preclude.
- Document
- Motion in limine
- Placement
- Caption
In jury trials, parties must file a signed joint statement of the case that is neutral and does not exceed 2 paragraphs, for the court to read to the jury.
Court's wording
For jury trials, the parties shall prepare a joint written statement of the case for the Court to read to the jury. (Local Rule 3.25(g)(4).) The joint statement shall be a neutral short statement of the case and not exceed 2 paragraphs. The parties/counsel shall sign the joint statement.
The parties shall prepare 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 indications on the printed
Uncontested and contested instructions shall be separated into subsections, with all uncontested instructions together, and all contested instructions together.
Parties must file a signed joint exhibit list with columns for the exhibit, offering party, authenticity/admissibility stipulations, evidentiary objections, and identification/admission dates, after meeting and conferring to resolve objections.
Court's wording
The parties shall prepare and file a joint exhibit list organized with columns identifying : (1) the exhibit, (2) which party is o ering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) each party's evidentiary objection, if any, to admission of each exhibit, (5) the date on which the exhibit was identified, and (6) the date on which the exhibit was admitted. The parties shall meet and confer to resolve objections to the admissibility of each exhibit. The parties shall sign the joint exhibit list.
Parties using deposition or former trial testimony in lieu of live testimony must jointly prepare and file a signed designation chart with columns for page/line designations, objections, counter-designations, responses, and the court's rulings.
Court's wording
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.
Parties must file a joint proposed verdict form; if they cannot agree, each party must separately file a proposed verdict form and bring an electronic copy to the FSC ready to be edited in the courtroom.
Court's wording
The parties shall prepare and file a joint proposed general verdict form or special verdict form (with interrogatories) acceptable to all sides. (Local 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, and bring an electronic copy of their proposed verdict form to the FSC, ready to be edited in the courtroom.
The parties/counsel are strongly encouraged to stipulate to uncontested motions. Uncontested motions should note “uncontested” in the caption.
- Document
- Motion in limine
- Placement
- Caption
Should include
- •Uncontested
Each morning, counsel must provide the Court Attendant with a written list of witnesses to be called that day including their full names with correct spellings and the order in which they will be called.
The following motions in limine are deemed filed and granted: (A) to preclude non-testifying, non-party witnesses from being present in the courtroom when others are testifying (see Evid. Code § 777) (B) to preclude reference to the liability insurance in a case defended by that liability insurance policy; and (C) to preclude references to settlement discussions.
Filing & Service rules
Electronic Filing Rules
Parties must electronically file documents unless exempt from mandatory e-filing; facsimile filings are prohibited, and filed documents may take 1-2 business days to appear on the docket.
Except for parties or attorneys who have obtained an exemption from mandatory electronic filing, parties must electronically file documents. Filings are not accepted via facsimile. Please be aware that it may take 1-2 business days for a filed document to appear in the Court’s docket. The requirements for electronic filing are detailed in the operative General Order re Mandatory Electronic Filing for Civil (Superior Court, L.A. County).
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All parties must electronically file documents unless they have obtained an exemption from mandatory electronic filing.
Except for parties or attorneys who have obtained an exemption from mandatory electronic filing, parties must electronically file documents.
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Documents may not be filed by facsimile in Department 78.
Filings are not accepted via facsimile.
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Filing Timing and Cure Windows
Parties must meet and confer 30 days before CMC and file timely CMC statements including case nature, discovery timeline, and agreements; non-compliance may result in $250 sanctions per violation.
Thirty days before a scheduled Case Management Conference, the parties are ordered to meet and confer in person, by telephone, or by video to discuss the items listed in Rules of Court, rule 3.724. The Court expects this to be a meaningful conference in which counsel with authority discuss the pleadings, discovery, and a path to case resolution, whether by settlement or trial. The parties must then file timely Case Management Conference Statements pursuant to Rules of Court, rule 3.725 (preferably a joint statement), describing the nature of the case, when discovery will be completed (“per code” does not assist the Court), and any agreements the parties have reached (see 19(b) of the Statement). A failure to comply with Rules of Court, rules 3.724 and 3.725 may subject the o ending counsel to sanctions of up to $250 per violation. (Rules of Court, rule 2.30.)
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Papers for a reserved hearing must be filed within 3 days of making the CRS reservation or the reservation will be cancelled.
Note that papers for a reserved matter must be filed within 3 days of making the reservation, otherwise the reservation will be cancelled.
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Page 2 | F. LAW AND MOTION - 1. Reservation Hearing Date
Motion papers must be filed within 3 days of reserving a hearing date, or the reservation will be cancelled.
Note that papers for a reserved matter must be filed within 3 days of making the reservation, otherwise the reservation will be cancelled.
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Trial readiness documents must be served and filed at least five court days before the final status conference.
At least five court days prior to the FSC, the parties shall serve and file the following trial readiness documents:
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Page 5 | 1. Final Status Conference ("FSC") and Pretrial Filings
Motions in limine must comply with CCP section 1005 notice provisions and Local Rule 3.57(a) before filing.
Before filing motions in limine, the parties shall comply with the statutory notice provisions of CCP section 1005 and the requirements of Local Rule 3.57(a).
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Page 5 | 1. Final Status Conference ("FSC") and Pretrial Filings
All pretrial documents must be filed in advance of the final status conference.
All pretrial documents must be filed in advance of the FSC.
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Page 5 | 1. Final Status Conference ("FSC") and Pretrial Filings
Before filing motions in limine, parties must comply with the CCP § 1005 statutory notice provisions and Los Angeles Superior Court Local Rule 3.57(a).
Before filing motions in limine, the parties shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and the requirements of the Superior Court, Los Angeles County, Local Rules, rule 3.57(a).
Civil cases
Page 7 | 3. Motions in Limine
Copies of deposition transcripts or other discovery responses must be lodged with the Court before trial.
Before trial, copies of deposition transcripts or other discovery responses shall be lodged with the Court. (LASCR 3.56.)
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Page 8 | 7. Reading from Discovery Responses/Deposition Transcripts
Visual aids for closing arguments must be disclosed to opposing counsel by 8:30 AM on the day of closing arguments, or the Court may prohibit their use.
If a party wishes to use graphics, demonstrative exhibits, or other visual aids during their closing arguments, including presentations created with PowerPoint or other presentation software, they must disclose such material to their opposing counsel no later than 8:30 am on the day that closing arguments are scheduled, so that any objections may be identified and resolved. (Local Rule 3.180.) Failure to comply with this requirement may result in the Court prohibiting the use of such material.
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Stipulations are to be filed before trial to the extent feasible.
To the extent feasible, stipulations are to be filed before trial. (LASCR 3.125)
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Page 8 | 6. Stipulations
Filed documents may take 1-2 business days to appear on the Court's docket.
Please be aware that it may take 1-2 business days for a filed document to appear in the Court's docket.
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Three motions in limine are automatically deemed filed and granted: witness sequestration of non-testifying non-party witnesses, preclusion of liability insurance references, and preclusion of settlement discussion references.
The following motions in limine are deemed filed and granted: (A) to preclude non-testifying, non-party witnesses from being present in the courtroom when others are testifying (see Evid. Code § 777) (B) to preclude reference to the liability insurance in a case defended by that liability insurance policy; and (C) to preclude references to settlement discussions.
Civil cases
Page 7 | 3. Motions in Limine
All trial readiness documents must be served and filed at least 5 court days before the Final Status Conference, including trial briefs, motions in limine, joint statements, witness lists, jury instructions, verdict forms, exhibit lists, deposition designations, and stipulations.
At least five court days prior to the FSC, the parties shall serve and file the following trial readiness documents: Trial briefs. Each party shall file a trial brief succinctly identifying (i) the claims and defenses subject to litigation; (ii) the major legal issues (with supporting points and authorities); (iii) the relief claimed, and calculation of damages sought; and (iv) any other information that may assist the court at trial. Motions in limine. Before filing motions in limine, the parties shall comply with the statutory notice provisions of CCP section 1005 and the requirements of Local Rule 3.57(a). The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to preclude. Parties filing more than one motion in limine shall number the motions consecutively. Joint statement. For jury trials, the parties shall prepare a joint written statement of the case for the Court to read to the jury. (Local Rule 3.25(g)(4).) The joint statement shall be a neutral short statement of the case and not exceed 2 paragraphs. 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. (Local Rule 3.25(g)(5).) Jury instructions (joint and contested). The parties shall prepare a complete set of full-text proposed jury instructions, editing all proposed California Civil Jury Instructions, insert party name(s), eliminate blanks, brackets, and irrelevant material. Joint verdict form(s). The parties shall prepare and file a joint proposed general verdict form or special verdict form (with interrogatories) acceptable to all sides. (Local Rule 3.25(g)(8).) Joint exhibit list. The parties shall prepare and file a joint exhibit list organized with columns identifying : (1) the exhibit, (2) which party is o ering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) each party’s evidentiary objection, if any, to admission of each exhibit, (5) the date on which the exhibit was identified, and (6) the date on which the exhibit was admitted. 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. Stipulations. The Court orders the parties to meet and confer regarding potential stipulations to the ultimate facts and issues, as well as to the admissibility of exhibits.
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Service and Proof of Service Rules
Plaintiffs must serve the summons and complaint on defendants within 60 days of filing the complaint or face sanctions, including dismissal.
Plaintiff(s) shall service the summons and complaint upon Defendant(s) within 60 days of filing of the complaint. (Rules of Court, rule 3.110 (b).) Failure to do so may result in the imposition of sanctions (See CCP §§ 128, 177.5; Rules of Court, rule 2.30), including dismissal (CCP §§ 583.410, 583.420), unless Plaintiff(s) shows cause why the court should not make such an order.
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Page 2 | D. SERVICE OF SUMMONS AND COMPLAINT
Plaintiffs must serve summons and complaint on defendants within 60 days of filing the complaint, or face potential sanctions or dismissal.
Plainti (s) shall service the summons and complaint upon Defendant(s) within 60 days of filing of the complaint. (Rules of Court, rule 3.110 (b).) Failure to do so may result in the imposition of sanctions (See CCP §§ 128, 177.5; Rules of Court, rule 2.30), including dismissal (CCP §§ 583.410, 583.420), unless Plainti (s) shows cause why the court should not make such an order.
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Parties must disclose closing-argument graphics, demonstrative exhibits, and visual aids to opposing counsel by 8:30 am on the day of closing arguments or risk the Court prohibiting their use.
If a party wishes to use graphics, demonstrative exhibits, or other visual aids during their closing arguments, including presentations created with PowerPoint or other presentation software, they must disclose such material to their opposing counsel no later than 8:30 am on the day that closing arguments are scheduled, so that any objections may be identified and resolved. (Local Rule 3.180.) Failure to comply with this requirement may result in the Court prohibiting the use of such material.
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Page 9 | J. TRIAL PROCEDURES — 11. Closing Arguments
Filing Fees and Waivers
Motion filing fees must be paid when reserving a hearing date online via the Court Reservation System.
Motion fee payments are required at the time reservations are made online.
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Motion fees must be paid at the time the hearing reservation is made online.
Motion fee payments are required at the time reservations are made online.
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Page 2 | F. LAW AND MOTION - 1. Reservation Hearing Date
Ex parte applications must comply with California Rules of Court, rule 3.1200 et seq., and the filing fee must be paid before appearing in Department 78.
Ex parte applications must comply with Rules of Court, rule 3.1200, et seq. and pay the filing fee before appearing in Dept. 78.
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Page 4 | G. EX PARTE APPLICATIONS
Parties must pay jury fees no later than 365 calendar days after the initial complaint is filed.
Parties must pay jury fees no later than 365 calendar days after the filing of the initial complaint. (CCP § 631, subd. (c)(2).)
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Page 4 | H. JURY FEES
Ex parte applications require filing fee payment before appearance and must include a declaration with affirmative factual showing of irreparable harm, immediate danger, or statutory ex parte basis.
Ex parte applications must comply with Rules of Court, rule 3.1200, et seq. and pay the filing fee before appearing in Dept. 78. 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.”
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Jury fees must be paid within 365 calendar days of filing the initial complaint.
Parties must pay jury fees no later than 365 calendar days after the filing of the initial complaint. (CCP § 631, subd. (c)(2).)
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Courtesy Copy Requirements
Except for oppositions to ex parte applications and papers related to motions for summary judgment/adjudication, Department 78 does not require courtesy copies of any filed papers. Such courtesy copies must be submitted directly to Department 78.
Except for oppositions to ex parte applications and papers related to motions for summary judgment/adjudication, Department 78 does not require courtesy copies of any filed papers. Such courtesy copies must be submitted directly to Department 78.
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Page 3 | F. LAW AND MOTION
Except for oppositions to ex parte applications and papers related to motions for summary judgment/adjudication, Department 78 does not require courtesy copies of any filed papers. Such courtesy copies must be submitted directly to Department 78. Courtesy copies, including any media attached thereto, will be destroyed by the Court without notice following the hearing.
Except for oppositions to ex parte applications and papers related to motions for summary judgment/adjudication, Department 78 does not require courtesy copies of any filed papers. Such courtesy copies must be submitted directly to Department 78. Courtesy copies, including any media attached thereto, will be destroyed by the Court without notice following the hearing.
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At trial, parties must have additional exhibit copies for the Court's clerk, the witness stand, and each counsel.
At trial, the parties will need additional copies of the exhibits for the Court’s clerk, for use on the witness stand, and for each counsel.
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Page 7 | 4. Evidentiary Exhibits
MSJ/MA courtesy copies are encouraged to be in three-ring binders with tabs; all courtesy copies with declarations/exhibits must be tabbed, and deposition excerpts in briefs must be marked on attached transcripts.
Parties filing and opposing lengthy motions for summary judgment or adjudication are strongly encouraged to submit one or more three-ring binders organizing the courtesy copy behind tabs. Any courtesy copies of documents with declarations and/or exhibits must be tabbed. (Rules of Court, rule 3.1110(f).) All deposition excerpts referenced in briefs must be marked on the transcripts attached as exhibits. (Rules of Court, rule 3.1116(c).)
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Filing Bundling Requirements
Counsel must provide the court a joint trial binder at the FSC, organized with tabs for trial briefs, motions in limine, joint statement, joint witness list, jury instructions, and verdict forms (tab list continues on the next page).
Counsel must provide a joint trial binder for the Court at the FSC. The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Motions in Limine Tab C: Joint Statement of the Case Tab D: Joint Witness List Tab E: Joint List of Jury Instructions (joint and contested) Tab F: Full Text Jury Instructions Tab G: Joint and/or Contested Verdict Forms (cont'd on next page)
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Page 6 | 2. Trial Binders
For lengthy summary judgment/adjudication motions, filing and opposing parties are strongly encouraged to submit courtesy copies organized behind tabs in one or more three-ring binders.
Parties filing and opposing lengthy motions for summary judgment or adjudication are strongly encouraged to submit one or more three-ring binders organizing the courtesy copy behind tabs.
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Page 3 | F. LAW AND MOTION
If there are more than a few motions in limine, they should be placed in a separate binder.
If there are more than a few motions in limine, they should be placed in a separate binder.
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Page 7 | 3. Motions in Limine
Pre-Motion Conference Requirements
Moving parties must reserve a hearing date via the online Court Reservation System (CRS) before filing any motion, except motions in limine.
Moving parties must secure a hearing date via the online Court Reservation System (CRS) on the Los Angeles Superior Court website. Please see the "Online Services" section to find the civil Court Reservation System at www.lacourt.org to reserve a hearing date prior to filing any motion, except for motions in limine, which are normally heard at the final status conference or the first day of trial.
Civil cases
Page 2 | F. LAW AND MOTION - 1. Reservation Hearing Date
Parties are ordered to meet and confer in good faith to informally resolve discovery disputes, and the Court generally finds conferring only by letters and emails to be insufficient.
Per CCP section 2016.040, the parties are ordered to meet and confer to make reasonable, good-faith e orts to informally resolve discovery disputes. The Court generally finds that meeting and conferring by only exchanging letters and e-mails, as opposed to phone or video conversation, is insu icient and ine ective.
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Page 3 | F. LAW AND MOTION - 5. Motions to Compel Further Responses to Discovery
After meeting and conferring about available dates for an IDC, the parties should file a joint statement (no longer than 5 pages) that succinctly summarizes the nature of the dispute, necessity for the discovery, and objection or other basis for withholding the information, as well as overall status of discovery. Parties should briefly indicate what e orts were made to informally resolve the issue.
After meeting and conferring about available dates for an IDC, the parties should file a joint statement (no longer than 5 pages) that succinctly summarizes the nature of the dispute, necessity for the discovery, and objection or other basis for withholding the information, as well as overall status of discovery. Parties should briefly indicate what e orts were made to informally resolve the issue.
Civil cases
Page 3 | F. LAW AND MOTION - 5. Motions to Compel Further Responses to Discovery
Parties must meet and confer in good faith before filing motions in limine; failure to do so may result in summary denial.
Parties must meet and confer in good faith prior to filing the motions in limine, to try to reach a stipulation on the evidence and other issues. A simple exchange of letters that identify the motions to be filed is not su icient. Failure to meet and confer in good faith may result in a summary denial of the motion.
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Parties must meet and confer in good faith before filing motions in limine to attempt to reach a stipulation, and failure to do so may result in summary denial of the motion.
Parties must meet and confer in good faith prior to filing the motions in limine, to try to reach a stipulation on the evidence and other issues. A simple exchange of letters that identify the motions to be filed is not su icient. Failure to meet and confer in good faith may result in a summary denial of the motion.
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Page 7 | 3. Motions in Limine
Parties moving to compel further discovery responses are encouraged to schedule an Informal Discovery Conference before the hearing, but doing so does not extend the motion filing deadline and is entirely at the Court's discretion.
Parties seeking to compel further responses to discovery are encouraged to attempt to schedule an Informal Discovery Conference (IDC) before the hearing on their motions. Scheduling the IDC does not extend the time to file a motion to compel further responses to discovery.
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Page 3 | F. LAW AND MOTION - 5. Motions to Compel Further Responses to Discovery
Adjournment & Extension Requirements
Continuances will not be granted because of witnesses who do not appear timely (trial proceeds without them), though the Court may accommodate scheduling needs of expert, professional, or out-of-state witnesses where circumstances warrant.
If witnesses are not under subpoena and do not appear timely, trial will proceed without them. Continuances will not be granted due to witnesses who do not appear timely. If possible, the Court will try to accommodate the scheduling needs of expert witnesses, professionals, out-of-state witnesses, or others if the circumstances warrant.
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Page 8 | 5. Witnesses
Continuances are not granted for witnesses who fail to appear timely.
Continuances will not be granted due to witnesses who do not appear timely.
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Chambers Communication Rules
Department 78 chambers phone contact: (213) 830-0878, available during courtroom hours 8:30 AM-12 PM and 1:30 PM-4:30 PM.
TELEPHONE NUMBER: (213) 830-0878 COURTROOM HOURS: 8:30 a.m. to 12 noon and 1:30 p.m. to 4:30 p.m.
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Department 78 chambers email address is SMCDEPT78@lacourt.org.
EMAIL: SMCDEPT78@lacourt.org
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Page 1 | Courtroom Information
Department 78 chambers contact details: Judicial Assistant Diana Castro-Martinez and Courtroom Assistant Angela Comick at (213) 830-0878, email SMCDEPT78@lacourt.org, hours 8:30 AM-12 PM and 1:30 PM-4:30 PM.
JUDICIAL ASSISTANT: Diana Castro-Martinez TELEPHONE NUMBER: (213) 830-0878 COURTROOM ASSISTANT: Angela Comick TELEPHONE NUMBER: (213) 830-0878 EMAIL: SMCDEPT78@lacourt.org COURTROOM HOURS: 8:30 a.m. to 12 noon and 1:30 p.m. to 4:30 p.m.
Civil cases
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Department 78 chambers can be reached by phone at (213) 830-0878 during courtroom hours of 8:30 a.m. to 12 noon and 1:30 p.m. to 4:30 p.m.
JUDICIAL ASSISTANT: Diana Castro-Martinez TELEPHONE NUMBER: (213) 830-0878 COURTROOM ASSISTANT: Angela Comick TELEPHONE NUMBER: (213) 830-0878 EMAIL: SMCDEPT78@lacourt.org COURTROOM HOURS: 8:30 a.m. to 12 noon and 1:30 p.m. to 4:30 p.m.
Civil cases
Page 1 | Courtroom Information
After filing the joint statement, the moving/propounding party should reserve the IDC by calling Department 78's staff.
Thereafter, the moving/propounding party should reserve an IDC by calling Dept. 78's sta .
Civil cases
Page 3 | F. LAW AND MOTION - 5. Motions to Compel Further Responses to Discovery