Judge Allison L. Westfahl Kong
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Ex Parte Application, Opposition
- Upon Filing
Exhibits
- 3 copies • First Day of Trial
Motion
- Hand Delivery • Within One Day of Electronic Filing
Motion in Limine, Opposition, Reply
- At FSC
Page & Word Limits2 rules
At least five (5) calendar days before the IDC, the parties shall file IDC briefs not to exceed five (5) pages
- IDC brief
- Up to 5 pages
For each contested jury instruction, the objecting party's explanation and the proposing party's response are each limited to one page.
- Page limit
- Up to 1 page
- Jury instructions
Court's wording
For each contested instruction, the party opposing the instruction may provide a short explanation of its objection (not to exceed one page) and the party proposing the instruction may provide a short response to the objection (not to exceed one page).
Document Format Requirements2 rules
All filings shall comply with the technical requirements set forth in that general order.
Pursuant to Local Rules 3.52 and 3.53, the exhibits must be pre-marked using Arabic numerals and in instances where exhibits consist of multiple pages, each page must be numbered sequentially.
Document Filing Requirements18 rules
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.
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.
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.
Court's wording
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."
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.)
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.
- Document
- Ex parte application
Must include
- •Proposed order
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,
The parties are instructed to file their Request for an IDC using Form LACIV-094.
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.
- Document
- Trial brief
Must include
- •Legal argument
Court's wording
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.
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
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.
Court's wording
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.
The parties must jointly prepare and file a signed joint list of proposed jury instructions, organized in numerical order, identifying agreed and contested instructions.
Court's wording
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.
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.
Court's wording
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.
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.
- Document
- Joint exhibit list
Must include
- •Exhibit list
Court's wording
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.
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.
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 and counsel shall sign the designations.
The binder also must contain a table of contents identifying each motion in limine, opposition, and reply, and the corresponding tab for each.
- Document
- Motions in limine binder
Must include
- •Table of contents
When filing motions in limine, the parties must comply with Local Rule 3.57, including the required declaration, if applicable.
Motions in limine may not be used to seek dispositive orders or declaratory rulings that should be pursued through other motions.
Court's wording
Motions in limine shall not be used to seek (1) dispositive orders that should have been sought through a motion for summary judgment, summary adjudication, or judgment on the pleadings, or (2) rulings that are "declaratory of existing law or
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.
Court's wording
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.
Filing & Service rules
Electronic Filing Rules
Electronic filing is mandatory for all documents, except for self-represented litigants and litigants who have received an eFiling exemption.
The Court mandates electronic filing (“eFiling”) of all documents unless the litigant is self-represented or has received an exemption from eFiling requirements. All parties represented by counsel shall comply with Local Rule 3.4 and the operative General Order re Mandatory Electronic Filing for Civil (May 3, 2019).
Civil cases
Page 2 | B. Mandatory eFiling
Parties represented by counsel must electronically file ex parte applications with all documentary support no later than 10:00 a.m. the court day before the ex parte hearing. Any written opposition to the ex parte application by parties represented by counsel must be electronically filed by 8:30 a.m. on the day of the ex parte hearing.
Parties represented by counsel must electronically file ex parte applications with all documentary support no later than 10:00 a.m. the court day before the ex parte hearing. Any written opposition to the ex parte application by parties represented by counsel must be electronically filed by 8:30 a.m. on the day of the ex parte hearing.
Civil cases
Page 5 | B. Ex Parte Applications
Filing Timing and Cure Windows
Written opposition to ex parte applications by represented parties must be e-filed by 8:30 a.m. on the day of the hearing.
Any written opposition to the ex parte application by parties represented by counsel must be electronically filed by 8:30 a.m. on the day of the ex parte hearing.
Civil cases
Page 5 | B. Ex Parte Applications
Ex parte applications by represented parties must be e-filed, with all documentary support, no later than 10:00 a.m. the court day before the hearing.
Parties represented by counsel must electronically file ex parte applications with all documentary support no later than 10:00 a.m. the court day before the ex parte hearing.
Civil cases
Page 5 | B. Ex Parte Applications
Self-represented parties must file ex parte papers with the Judicial Assistant in Department H or the clerk's office by 9:00 a.m. on the day of the hearing.
opposition to an ex parte application must file them with the Judicial Assistant in Department H or the clerk's office by 9:00 a.m. on the day of the hearing, after paying any applicable filing fee (unless the party has a fee waiver).
Civil cases
Page 6 | B. Ex Parte Applications
The Court will not accept self-represented parties' ex parte papers for same-day hearings if filed after 9:00 a.m.
The Court will not accept ex parte papers from self-represented parties for hearings that same day if filed after 9:00 a.m.
Civil cases
Page 6 | B. Ex Parte Applications
IDC briefs must be filed at least five calendar days before the IDC.
At least five (5) calendar days before the IDC, the parties shall file IDC briefs
Civil cases
Page 7 | II. Pretrial Proceedings — D. Discovery Disputes and Informal Discovery Conferences
Trial documents must be served and filed at least 7 calendar days before the Final Status Conference.
At least seven (7) calendar days prior to the FSC, the parties and counsel shall serve and file the following trial documents:
Civil cases
Page 9 | A. Final Status Conference
The moving party may file a reply brief on motions in limine 3 calendar days before the final status conference.
The moving party may file a reply brief three (3) calendar days before the FSC.
Civil cases
Page 12 | B. Motions in Limine
Oppositions to motions in limine must be filed and served 7 calendar days before the final status conference.
Any opposition to the motions in limine shall be filed and served seven (7) calendar days before the FSC.
Civil cases
Page 12 | B. Motions in Limine
Motions in limine must be filed and served 14 calendar days before the final status conference.
Motions in limine shall be filed and served fourteen (14) calendar days before the FSC.
Civil cases
Page 12 | B. Motions in Limine
Exhibits must be exchanged at least 14 calendar days before the FSC and lodged with the Court on the first day of trial.
The exhibits must be exchanged at least fourteen (14) calendar days before the FSC and lodged with the Court on the first day of trial.
Civil cases
Page 14 | C. Trial Binder
Scheduling or participating in an IDC does not extend any deadlines for filing discovery motions.
Scheduling or participating in an IDC does not extend any deadlines for filing discovery motions.
Civil cases
Page 7 | II. Pretrial Proceedings — D. Discovery Disputes and Informal Discovery Conferences
Service and Proof of Service Rules
All defendants must be served with the complaint no later than the case management conference.
All defendants must be served with the complaint by the case management conference.
Civil cases
Page 4 | II. Pretrial Proceedings - A. Case Management Conferences
An exhibit binder must also be supplied to each opposing party.
An exhibit binder must also be supplied to each opposing party.
Civil cases
Page 14 | C. Trial Binder
Unless otherwise ordered, all pre-trial service deadlines are extended based on the manner of service as set forth in Code of Civil Procedure section 1013.
Unless otherwise ordered, the below pre-trial filing and service deadlines apply. All deadlines for service are extended based on the manner of service as set forth in Code of Civil Procedure section 1013.
Civil cases
Page 8 | III. Trials
Filing Fees and Waivers
Ex parte applicants must pay the filing fee before appearing in court.
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.
Civil cases
Page 5 | B. Ex Parte Applications
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.
Civil cases
Page 6 | C. Law and Motion
Ex parte papers filed with the Judicial Assistant or clerk's office require payment of any applicable filing fee unless the party has a fee waiver.
opposition to an ex parte application must file them with the Judicial Assistant in Department H or the clerk's office by 9:00 a.m. on the day of the hearing, after paying any applicable filing fee (unless the party has a fee waiver).
Civil cases
Page 6 | B. Ex Parte Applications
Fee-waiver parties may request an official court reporter by filing form LASC LACIV 269 at least 10 calendar days before the hearing or trial, subject to reporter availability.
A party who has a fee waiver pursuant to California Rules of Court, rule 3.55(7) may request an official court reporter by filing form LASC LACIV 269 at least ten (10) calendar days before the hearing or trial. Given the limited availability of official court reporters, the Court may not know whether a reporter is available until the day of the hearing or trial.
Civil cases
Page 3 | D. Court Reporters
Courtesy Copy Requirements
Courtesy copies with tabbed exhibits are required for summary judgment motion briefs, ex parte applications and oppositions, trial documents, and motion papers exceeding a page threshold (threshold value cut off in source).
The Court requires courtesy copies (with tabbed exhibits) for the following categories of documents: (1) summary judgment motions briefs, (2) ex parte applications and oppositions, (3) trial documents, and (4) motion papers exceeding
Civil cases
Page 2 | C. Courtesy Copies
the type of motion. The conformed, printed courtesy copies are to be delivered directly to Department H within one day of electronic filing.
the type of motion. The conformed, printed courtesy copies are to be delivered directly to Department H within one day of electronic filing.
Civil cases
Page 3
When filing ex parte papers, a separate courtesy copy must be brought for each party in the case.
A separate courtesy copy of the papers shall also be brought for each party in the case.
Civil cases
Page 6 | B. Ex Parte Applications
Parties must deliver a tabbed binder at the FSC containing all motions in limine, oppositions, and replies in sequential order.
the parties and counsel must provide a tabbed binder at the FSC containing all motions in limine, oppositions, and replies in sequential order consistent with the number assigned to each motion in limine.
Civil cases
Page 13 | III. Trials
Parties must provide a joint trial binder to the Court at the FSC, organized with Tabs A through J covering trial briefs, motions in limine, joint statements, witness and exhibit lists, jury instructions, verdict forms, deposition designations, and operative pleadings.
The parties and counsel shall 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 Tab F: Joint and Contested Jury Instructions Tab G: Joint and/or Contested Verdict Forms Tab H: Joint Exhibit List Tab I: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab J: Copies of all Current Operative Pleadings
Civil cases
Page 13 | C. Trial Binder
At least three tabbed and paginated sets of exhibit binders are required on the first day of trial, one each for the Court, Judicial Assistant, and witness.
At least three sets of exhibit binders – tabbed and paginated – are required on the first day of trial: one set each for the Court, Judicial Assistant, and witness.
Civil cases
Page 14 | C. Trial Binder
Pre-Motion Conference Requirements
Moving parties must reserve a hearing date via the civil Court Reservation System before filing any motion, except motions in limine which are heard at the Final Status Conference.
Moving parties must secure a hearing date via the online Court Reservation System 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, by Local Rule, are heard during the Final Status Conference.
Civil cases
Page 6 | C. Law and Motion
Pursuant to Code of Civil Procedure section 2016.040, the parties and counsel are ordered to meet and confer to make reasonable, good-faith efforts to informally resolve discovery disputes. Should the parties wish to file a motion to compel further responses to discovery, or other discovery motions regarding depositions or subpoenas, the parties must first meet and confer in good faith either in person or by telephone or videoconference.
Pursuant to Code of Civil Procedure section 2016.040, the parties and counsel are ordered to meet and confer to make reasonable, good-faith efforts to informally resolve discovery disputes. Should the parties wish to file a motion to compel further responses to discovery, or other discovery motions regarding depositions or subpoenas, the parties must first meet and confer in good faith either in person or by telephone or videoconference.
Civil cases
Page 7 | II. Pretrial Proceedings — D. Discovery Disputes and Informal Discovery Conferences
The Court generally will not hear discovery motions until an IDC is conducted, and absent good cause, motions filed before an IDC will be continued until after the IDC.
The Court generally will not hear motions to compel further discovery, or the other above-described discovery motions until an IDC is conducted. Absent a showing of good cause, motions filed before an IDC is conducted will be continued until after the IDC, which the parties should schedule as soon as possible after the dispute emerges.
Civil cases
Page 8 | II. Pretrial Proceedings — D. Discovery Disputes and Informal Discovery Conferences
Parties must meet and confer in good faith before filing motions in limine, in person, by telephone, or via videoconference, to attempt to reach a stipulation on the evidence.
The parties and counsel shall meet and confer in good faith prior to filing the motions in limine to attempt to reach a stipulation on the evidence and other issues. (See Local Rule 3.57(a)(2).) This meet-and-confer session shall take place in person, over the telephone, or via videoconference.
Civil cases
Page 12 | B. Motions in Limine
If unable to resolve a discovery dispute, parties should schedule an Informal Discovery Conference (IDC) before filing any discovery motion.
If the parties are unable to resolve their discovery disputes, the Court requests that the parties schedule an Informal Discovery Conference (“IDC”) prior to filing any discovery motion.
Civil cases
Page 7 | II. Pretrial Proceedings — D. Discovery Disputes and Informal Discovery Conferences
Junior Lawyer Participation Incentives
When a junior attorney argues a motion, the Court will permit one senior attorney for the same party to augment the argument if needed and will allocate more hearing time.
When a junior attorney argues for whatever relief is requested, the Court will permit one senior attorney for the same party to augment the argument, if needed, and will allocate more time to the hearing to accommodate.
Civil cases
Page 7 | II. Pretrial Proceedings