Judge Andrew E. Cooper
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- First Day of Trial
- Hand Delivery
Exhibit Notebook
- 5 copies • On First Day of Trial
Jury Instructions
- 1 copy • Hand Delivery
Motion in Limine, Opposition, Reply
- At Least 2 Calendar Days Prior to FSC
Binding: Three Ring Binder
Adjournments
- Continuances may be sought by written stipulation stating the complaint filing date, current trial date, and proposed FSC and trial dates; absent a stipulation, by noticed motion or ex parte application.
- CONTINUANCES: All hearing dates, including trial dates, may be considered for a continuance by written Stipulation and Order. Said Stipulation and Order shall state the date the Complaint was filed, the current trial date, as well as the proposed Final Status Conference date and proposed trial date. If there is no stipulation, the parties may seek a continuance by noticed motion or an ex parte application.
Request must include
Communication
Phone
Clerk
Page & Word Limits2 rules
Trial briefs are mandatory for all (both Court and jury) trials and must include the following information and not exceed 20 pages:
- Trial brief
- Up to 20 pages
Trial briefs are mandatory for all (both Court and jury) trials and must include the following information and not exceed 20 pages:
- Trial brief
- Up to 20 pages
Document Format Requirements7 rules
All papers filed by self-represented litigants must be stapled separately before filing, or they will be rejected.
- Self-represented parties
- Binding
- Stapled
All papers filed by self-represented litigants must be stapled separately before filing, or they will be rejected.
- Papers
- Self-represented parties
- Binding
- Stapled
Identical copies of the Exhibit List and all exhibits must be provided in 3-ring binders as follows: one for each party, one for the Court, and one for the witness stand.
- Binding
- Three-ring binder
- Exhibit list
- Exhibits
The notebook must have both a Table of Contents and tab dividers to separate each numbered motion and its corresponding opposition and reply.
containing the required trial documents, tabbed and organized into 3-ring binders, with a Table of Contents in the front of each binder
- Binding
- Tabbed three-ring binder
- Trial binder
pages, it should have a “-“ (dash) delineating each page. For example, if Exhibit 1 consists of 3 pages, it would be numbered as follows: Exhibit 1-1, 1-2, and 1-3.
Reporters at trial should provide Real Time connections.
Document Filing Requirements26 rules
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.
Please note that the Court may not consider ex parte applications submitted/filed without a proposed order.
Please note that the Court may not consider ex parte applications submitted/filed without a proposed order.
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.
Court's wording
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.
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;
- Document
- Trial brief
Must include
- •Statement of facts
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.
Court's wording
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.
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.
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.
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.
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.
Court's wording
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.
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.
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.
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.
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.
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:
- Document
- Trial binder
Must include
- •Table of contents
A jointly submitted packet of all requested and properly edited jury instructions to which there is no objection.
Each party must also submit its own specifically requested, properly edited instructions and insert them into the jointly submitted packet.
Court's wording
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.
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.
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.
Oppositions to motions in limine must be in writing, numbered, and refer to the numbers used by the moving party.
Court's wording
An opposition to any motion in limine must be in writing, numbered, and served and electronically filed by represented parties at least five (5) calendar days prior to the FSC. (Exempt parties may file same by conventional means on printed paper directly in Department F51.) The opposition must refer to the numbers used by the moving party.
All motions in limine, if any, must be in writing, numbered, and shall be served on all opposing parties and counsel and electronically filed at least ten (10) calendar days before the FSC.
The parties shall organize proposed jury instructions behind Tab F, with the agreed upon instructions first in order followed by the contested instructions (including special instructions) submitted by each party.
Do not provide the same pages of exhaustive case description for context in every MIL. Instead, put this in the trial brief.
Do not file a MIL to educate the court on an issue---do this in the trial brief instead.
The following MILs usually should never be drafted or at least not survive meet and confer because counsel should not disagree: a) Exclude speculative evidence. b) Exclude expert opinion from non-experts. c) Confine experts to the area of their disclosure. d) Bar evidence of insurance coverage, prior settlements. e) Bar evidence not produced in discovery. f) Seeking bifurcation of punitive damages (its automatic on request) or to exclude the finances of a party in the liability phase. g) Witnesses to be disclosed in advance. h) Exclude percipient witnesses from trial before they have testified.
The Court strongly encourages the use of CACI jury instructions.
Filing & Service rules
Electronic Filing Rules
Represented litigants must electronically file all documents through the approved Electronic Filing Service Provider.
FILINGS BY REPRESENTED LITIGANTS: Represented litigants are required to electronically file all documents with the Court through the approved Electronic Filing Service Provider.
Page 1 | FILINGS BY REPRESENTED LITIGANTS
Represented litigants must e-file all documents through the Court's approved Electronic Filing Service Provider.
Represented litigants are required to electronically file all documents with the Court through the approved Electronic Filing Service Provider.
Page 1 | FILINGS BY REPRESENTED LITIGANTS
Self-represented litigants may file judgments, orders, and stipulations directly in the courtroom, but must include self-addressed stamped envelopes and conforming copies.
Judgments, orders, and stipulations may be filed directly in the courtroom but must include self-addressed, stamped envelopes and copies to conform.
Page 1 | FILINGS BY SELF-REPRESENTED LITIGANTS
Self-represented litigants are exempt from mandatory electronic filing requirements.
FILINGS BY SELF-REPRESENTED LITIGANTS: Self-represented litigants are exempt from mandatory electronic filing requirements.
Page 1 | FILINGS BY SELF-REPRESENTED LITIGANTS
Self-represented parties may e-file ex parte documents by 10:00 a.m. day before hearing, or bring documents to Clerk’s Office by 8:30 a.m. day of hearing with fee payment.
Self-represented parties must either electronically file by 10:00 a.m. the day before the ex parte hearing or personally bring the ex parte hearing, declaration of notice, and a proposed order to the Clerk’s Office for payment of the fee by 8:30 a.m. on the day of the hearing and proceed immediately to the courtroom with the ex parte application, declaration of notice, a proposed order, and proof of payment.
Page 3 | EX PARTE APPLICATIONS
Represented parties must e-file all trial documents pursuant to the Final Status Conference Order, except exhibits.
All trial documents filed by represented parties must be electronically filed pursuant to the Final Status Conference Order (except for exhibits).
Page 3 | TRIALS
Self-represented parties may either e-file ex parte papers by 10:00 a.m. the day before the hearing or personally deliver the application, declaration of notice, and proposed order to the Clerk's Office by 8:30 a.m. on the hearing day.
Self-represented parties must either electronically file by 10:00 a.m. the day before the ex parte hearing or personally bring the ex parte hearing, declaration of notice, and a proposed order to the Clerk’s Office for payment of the fee by 8:30 a.m. on the day of the hearing and proceed immediately to the courtroom with the ex parte application, declaration of notice, a proposed order, and proof of payment.
Page 3 | EX PARTE APPLICATIONS
Self-represented litigants must file all trial documents directly in Department F51 pursuant to the Final Status Conference Order.
All trial documents filed by self-represented litigants must be filed directly in Department F51 pursuant to the Court’s Final Status Conference Order.
Page 3 | TRIALS
For court trials, motions in limine, trial briefs, and the joint witness and exhibit lists must be e-filed; exempt parties may file them electronically or on paper.
For all Court trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC.
Page 5 | FINAL STATUS CONFERENCE (FSC) ORDER
Upon settlement, a Request for Dismissal or Notice of Settlement must be electronically filed before the FSC; parties exempt from e-filing must instead file and serve a printed copy.
If the action is settled or otherwise resolved before the FSC, no appearance will be necessary as long as either a Request for Dismissal of the entire action or a Notice of Settlement under California Rules of Court Rule 3.1385 is electronically filed with this Court at least two (2) court days before the scheduled FSC. If a party is exempt from the electronic filing requirements, that party shall file and serve a printed copy of the Request for Dismissal or Notice of Settlement at least two (2) court days before the scheduled FSC.
Page 5 | FINAL STATUS CONFERENCE (FSC) ORDER
Represented parties must electronically file MIL oppositions; exempt parties may file printed paper copies directly in Department F51.
An opposition to any motion in limine must be in writing, numbered, and served and electronically filed by represented parties at least five (5) calendar days prior to the FSC. (Exempt parties may file same by conventional means on printed paper directly in Department F51.)
Page 7 | REQUIREMENTS FOR SPECIFIC TRIAL DOCUMENTS - MOTIONS IN LIMINE
For all jury trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC.
For all jury trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC.
Page 7 | TRIALS
Self-represented parties only need to deliver a printed copy of jury instructions directly to Department F51; electronic filing is not required for them.
However, non-represented parties are only required to submit jury instructions by delivering a printed copy directly to Department F51.
Page 11 | TRIALS
Exhibits for trial and evidentiary hearings are prohibited from electronic filing.
Trial and evidentiary hearing exhibits shall not be filed electronically.
Page 11 | EXHIBITS
Trial and evidentiary hearing exhibits may not be filed electronically.
Trial and evidentiary hearing exhibits shall not be filed electronically.
Page 11 | EXHIBITS
Represented parties must submit jury instructions by both electronic filing and a printed copy delivered directly to Department F51.
Jury Instructions shall be submitted by both electronic filing and by a printed copy delivered directly to Department F51.
Page 11 | TRIALS
Self-represented litigants may file judgments, orders, and stipulations directly in the courtroom, but must include self-addressed stamped envelopes and copies to conform.
Judgments, orders, and stipulations may be filed directly in the courtroom but must include self-addressed, stamped envelopes and copies to conform.
Page 1 | FILINGS BY SELF-REPRESENTED LITIGANTS
Self-represented litigants are exempt from mandatory electronic filing and are not required to e-file.
Self-represented litigants are exempt from mandatory electronic filing requirements.
Page 1 | FILINGS BY SELF-REPRESENTED LITIGANTS
Filing Timing and Cure Windows
Ex parte applications, supporting documents, and proposed order must be e-filed by 10:00 a.m. the court day before the hearing.
Ex Parte applications, supporting documents, and a proposed order must be electronically filed no later than 10:00 a.m. the court day before the ex parte hearing.
Page 3 | EX PARTE APPLICATIONS
Written oppositions to ex parte applications must be e-filed by 8:30 a.m. on the day of the hearing.
Written oppositions shall be electronically filed by 8:30 a.m. the day of the ex parte hearing.
Page 3 | EX PARTE APPLICATIONS
Written oppositions to ex parte applications must be e-filed by 8:30 a.m. the day of the hearing.
Written oppositions shall be electronically filed by 8:30 a.m. the day of the ex parte hearing.
Page 3 | EX PARTE APPLICATIONS
Mandatory settlement briefs must be filed directly in the courtroom at least 5 days prior to the MSC.
Mandatory settlement briefs must be filed directly in the Courtroom at least 5-days prior to the MSC.
Page 3 | MANDATORY SETTLEMENT CONFERENCE
Mandatory settlement briefs must be filed directly in the Courtroom at least 5-days prior to the MSC.
Mandatory settlement briefs must be filed directly in the Courtroom at least 5-days prior to the MSC.
Page 3 | MANDATORY SETTLEMENT CONFERENCE
Ex parte applications, supporting documents, and a proposed order must be e-filed no later than 10:00 a.m. the court day before the hearing.
Ex Parte applications, supporting documents, and a proposed order must be electronically filed no later than 10:00 a.m. the court day before the ex parte hearing.
Page 3 | EX PARTE APPLICATIONS
Court-trial filings (motions in limine, trial briefs, joint witness list, joint exhibit list) are due at least ten (10) calendar days before the FSC.
For all Court trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC.
Page 5 | FINAL STATUS CONFERENCE (FSC) ORDER
Settlement or dismissal filings must be e-filed 2 court days before FSC; exempt parties may file printed copy.
If the action is settled or otherwise resolved before the FSC, no appearance will be necessary as long as either a Request for Dismissal of the entire action or a Notice of Settlement under California Rules of Court Rule 3.1385 is electronically filed with this Court at least two (2) court days before the scheduled FSC. If a party is exempt from the electronic filing requirements, that party shall file and serve a printed copy of the Request for Dismissal or Notice of Settlement at least two (2) court days before the scheduled FSC.
Page 5 | FINAL STATUS CONFERENCE (FSC) ORDER
Court trial documents (MILs, trial briefs, joint witness/exhibit lists) must be e-filed 10 calendar days before FSC; exempt parties may use electronic or paper.
For all Court trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC. a. Motions in Limine (if any), b. Trial Briefs, c. Joint Witness List, and d. Joint Exhibit List.
Page 5 | FINAL STATUS CONFERENCE (FSC) ORDER
The Request for Dismissal or Notice of Settlement must be filed at least two (2) court days before the scheduled FSC to avoid an appearance.
no appearance will be necessary as long as either a Request for Dismissal of the entire action or a Notice of Settlement under California Rules of Court Rule 3.1385 is electronically filed with this Court at least two (2) court days before the scheduled FSC
Page 5 | FINAL STATUS CONFERENCE (FSC) ORDER
MIL oppositions must be served and filed at least 5 calendar days before the FSC; exempt parties may file printed paper copies directly in Department F51.
An opposition to any motion in limine must be in writing, numbered, and served and electronically filed by represented parties at least five (5) calendar days prior to the FSC. (Exempt parties may file same by conventional means on printed paper directly in Department F51.)
Page 7 | REQUIREMENTS FOR SPECIFIC TRIAL DOCUMENTS - MOTIONS IN LIMINE
MIL oppositions must be written, numbered, served, and e-filed by represented parties 5 calendar days before FSC; exempt parties may file by paper.
An opposition to any motion in limine must be in writing, numbered, and served and electronically filed by represented parties at least five (5) calendar days prior to the FSC. (Exempt parties may file same by conventional means on printed paper directly in Department F51.)
Page 7 | REQUIREMENTS FOR SPECIFIC TRIAL DOCUMENTS
Motions in limine must be electronically filed at least 10 calendar days before the FSC; untimely motions may not be considered.
All motions in limine, if any, must be in writing, numbered, and shall be served on all opposing parties and counsel and electronically filed at least ten (10) calendar days before the FSC. Untimely motions may not be considered.
Page 7 | REQUIREMENTS FOR SPECIFIC TRIAL DOCUMENTS - MOTIONS IN LIMINE
For all jury trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC.
For all jury trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC.
Page 7 | TRIALS
Jury trial documents must be e-filed 10 calendar days before FSC; exempt parties may use electronic or paper filing.
For all jury trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC. a. Motions in Limine (if any), b. Trial Briefs, c. Joint Witness List, d. Joint Exhibit List, e. Joint Statement of the Case, f. Joint Jury Instructions, g. Joint Verdict Form, and, h. 3-Ring Trial Binder containing all the documents above (except Motions in Limine---see below).
Page 7 | FINAL STATUS CONFERENCE (FSC) ORDER
Motions in limine must be written, numbered, served on all parties, and e-filed 10 calendar days before FSC.
All motions in limine, if any, must be in writing, numbered, and shall be served on all opposing parties and counsel and electronically filed at least ten (10) calendar days before the FSC.
Page 7 | REQUIREMENTS FOR SPECIFIC TRIAL DOCUMENTS
The trial binder must be lodged with the Court at least two calendar days before the Final Status Conference in jury trials.
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
Page 11 | TRIAL BINDERS ARE REQUIRED FOR ALL JURY TRIALS BUT ARE DISCRETIONARY FOR ALL COURT TRIALS
A list of all deposition and discovery-response excerpts to be used at trial (except for impeachment), plus any admissibility stipulations, must be submitted to the judge no later than 10 court days before the FSC.
All parties shall submit to the judge no later than 10 court days before the FSC a list of all excerpts from depositions and other discovery responses to be used at trial except for impeachment, along with any stipulations to their admissibility.
Page 13 | 9. DISCOVERY
Service and Proof of Service Rules
Parties exempt from e-filing must file and serve a printed copy of the Request for Dismissal or Notice of Settlement at least two (2) court days before the FSC.
If a party is exempt from the electronic filing requirements, that party shall file and serve a printed copy of the Request for Dismissal or Notice of Settlement at least two (2) court days before the scheduled FSC.
Page 5 | FINAL STATUS CONFERENCE (FSC) ORDER
Motions in limine must be served on all opposing parties and counsel at least 10 calendar days before the FSC.
All motions in limine, if any, must be in writing, numbered, and shall be served on all opposing parties and counsel and electronically filed at least ten (10) calendar days before the FSC.
Page 7 | REQUIREMENTS FOR SPECIFIC TRIAL DOCUMENTS - MOTIONS IN LIMINE
Parties must serve discovery excerpts to be used at trial on opponents in writing 10 court days before FSC.
All parties must serve on the opposing attorney/in pro per party in writing and no later than 10 court days before the FSC all excerpts from depositions, responses to interrogatories, responses to requests for admissions, or other discovery responses to be used for any purpose at trial other than solely for impeachment and mark each excerpt as an exhibit.
Page 13 | DISCOVERY
Parties intending to use discovery at trial must exchange the particulars in writing at least 10 court days before the FSC, or risk a court order prohibiting use of the discovery.
If the parties intend to use any discovery during trial, the parties must exchange in writing no later than 10 court days prior to the FSC the particulars of any such discovery. For example, if a party proposes to read or show a video excerpt from a deposition, the proffering party must identify in writing by name the deponent, page, and line numbers to opposing counsel no later than 10 court days prior to the FSC. Failure to provide the specific discovery intended to be used at trial in writing and on a timely basis may result in a Court order prohibiting the use of said discovery.
Page 13 | 9. DISCOVERY
All parties must serve written discovery excerpts (except those used solely for impeachment), each marked as an exhibit, on the opposing party no later than 10 court days before the FSC.
All parties must serve on the opposing attorney/in pro per party in writing and no later than 10 court days before the FSC all excerpts from depositions, responses to interrogatories, responses to requests for admissions, or other discovery responses to be used for any purpose at trial other than solely for impeachment and mark each excerpt as an exhibit.
Page 13 | 9. DISCOVERY
Self-represented parties bringing an opposition to the courtroom on the hearing day must bring enough copies for the court and all other parties.
If a self-represented party elects to bring in his or her opposition to the Court on the day of the hearing, he or she shall bring a sufficient number of copies of the opposition to provide to the court and all other parties.
Page 3 | EX PARTE APPLICATIONS
Filing Fees and Waivers
Self-represented parties delivering ex parte papers in person must pay the fee at the Clerk's Office by 8:30 a.m. on the hearing day and bring proof of payment to the courtroom.
Self-represented parties must either electronically file by 10:00 a.m. the day before the ex parte hearing or personally bring the ex parte hearing, declaration of notice, and a proposed order to the Clerk’s Office for payment of the fee by 8:30 a.m. on the day of the hearing and proceed immediately to the courtroom with the ex parte application, declaration of notice, a proposed order, and proof of payment.
Page 3 | EX PARTE APPLICATIONS
Courtesy Copy Requirements
A printed courtesy copy of all verdict forms and jury instructions must be filed directly in Department F51 at the time of e-filing.
Additionally, a printed courtesy copy of all verdict forms and jury instructions shall be filed directly in Department F51 at the time of the electronic filing.
Page 3 | TRIALS
Courtesy copies must be delivered directly to Department F51.
Courtesy copies: Please deliver courtesy copies directly to Department F51.
Page 3 | Courtesy copies
MIL filers must submit a 3-ring binder notebook containing all motions, oppositions, and replies (with TOC and tab dividers) at least 2 calendar days before the FSC; late notebooks may result in the motions not being considered.
Separate Notebooks Are Required for All Motions in Limine: In addition to filing electronically, the party filing the motion(s) in limine must also submit a 3-ring binder notebook containing all motions, oppositions, and replies. The notebook must have both a Table of Contents and tab dividers to separate each numbered motion and its corresponding opposition and reply. The notebook shall be submitted at least two (2) calendar days prior to the FSC. Late filed notebooks may result in the motions not being considered.
Page 7 | REQUIREMENTS FOR SPECIFIC TRIAL DOCUMENTS - MOTIONS IN LIMINE
Jury instructions must be e-filed and a printed copy delivered to Dept F51; self-represented parties only need printed copy.
Jury Instructions shall be submitted by both electronic filing and by a printed copy delivered directly to Department F51. However, non-represented parties are only required to submit jury instructions by delivering a printed copy directly to Department F51.
Page 11 | REQUIREMENTS FOR SPECIFIC TRIAL DOCUMENTS
Parties must submit 5 identical exhibit notebooks on the first day of trial for parties, court, and witness stand.
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.
Page 11 | EXHIBITS
On the first day of trial, parties must provide sufficient copies of all discovery excerpts for the judge, the opposing parties, and the witness.
On the first day of trial, the parties must provide sufficient copies for the judge, the opposing parties, and the witness of all excerpts from interrogatories, requests for admission, depositions, and video depositions.
Page 13 | 9. DISCOVERY
Filing Bundling Requirements
MILs must be submitted in a 3-ring binder with table of contents and tabs, 2 calendar days before FSC.
Separate Notebooks Are Required for All Motions in Limine: In addition to filing electronically, the party filing the motion(s) in limine must also submit a 3-ring binder notebook containing all motions, oppositions, and replies. The notebook must have both a Table of Contents and tab dividers to separate each numbered motion and its corresponding opposition and reply. The notebook shall be submitted at least two (2) calendar days prior to the FSC. Late filed notebooks may result in the motions not being considered.
Page 7 | REQUIREMENTS FOR SPECIFIC TRIAL DOCUMENTS
Jury trial parties must jointly lodge a tabbed 3-ring trial binder with table of contents 2 calendar days before FSC.
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: Tab A: Trial Briefs of all parties Tab B: Joint Witness List Tab C: Joint Statement to be Read to the Jury Tab D: Joint Exhibit List Tab E: Joint List of Jury Instructions (identifying the agreed upon and contested instructions) Tab F: Joint and Contested Jury Instructions Tab G: Joint and/or Contested Verdict Forms
Page 11 | TRIAL BINDERS ARE REQUIRED FOR ALL JURY TRIALS
Please note that the trial binder and Motions in limine binder(s) should be in separate notebooks.
Please note that the trial binder and Motions in limine binder(s) should be in separate notebooks.
Page 11 | TRIAL BINDERS ARE REQUIRED FOR ALL JURY TRIALS BUT ARE DISCRETIONARY FOR ALL COURT TRIALS
The Court strongly prefers a joint exhibit notebook containing both parties' exhibits in one notebook, with exhibits numbered consecutively in the lower right-hand corner (sentence continues beyond this excerpt).
The Court strongly prefers the parties to file a joint exhibit notebook, containing both parties’ exhibits in one notebook. Those exhibits can be numbered consecutively in the lower, right-hand corner of
Page 11 | EXHIBITS
Pre-Motion Conference Requirements
All motions to be heard in Dept. F51 must be reserved in advance through the Court Reservation System (CRS).
All motions to be heard in Dept. F51 are to be reserved through the Court Reservation System (CRS).
Page 1 | MOTIONS
Before filing a discovery motion, parties must exhaust meet and confer efforts in person or via phone; a letter or email does not suffice.
The Court strongly discourages discovery motions and requires the parties to exhaust meet and confer efforts before filing discovery motions. “Meet and confer” in Department 51 means in person or via phone. A letter or email does not suffice.
Page 3 | DISCOVERY MOTIONS
Meet and confer before drafting MILs.
Meet and confer before drafting MILs.
Page 17 | FINAL STATUS CONFERENCE (FSC) ORDER
Counsel intending to file a demurrer should review the new requirements, including meet and confer requirements, set forth in Code of Civil Procedure section 430.41, and rethink whether a demurrer is
Counsel intending to file a demurrer should review the new requirements, including meet and confer requirements, set forth in Code of Civil Procedure section 430.41, and rethink whether a demurrer is
Page 1 | DEMURRERS
Counsel intending to file a demurrer should review the new requirements, including meet and confer requirements, set forth in Code of Civil Procedure section 430.41
Counsel intending to file a demurrer should review the new requirements, including meet and confer requirements, set forth in Code of Civil Procedure section 430.41
Page 1 | DEMURRERS
Parties must exhaust in-person or phone meet and confer efforts before filing discovery motions.
DISCOVERY MOTIONS: The Court strongly discourages discovery motions and requires the parties to exhaust meet and confer efforts before filing discovery motions. “Meet and confer” in Department 51 means in person or via phone. A letter or email does not suffice.
Page 3 | DISCOVERY MOTIONS
Adjournment & Extension Requirements
Continuances may be sought by written stipulation stating the complaint filing date, current trial date, and proposed FSC and trial dates; absent a stipulation, by noticed motion or ex parte application.
All hearing dates, including trial dates, may be considered for a continuance by written Stipulation and Order. Said Stipulation and Order shall state the date the Complaint was filed, the current trial date, as well as the proposed Final Status Conference date and proposed trial date. If there is no stipulation, the parties may seek a continuance by noticed motion or an ex parte application.
Page 3 | CONTINUANCES
CONTINUANCES: All hearing dates, including trial dates, may be considered for a continuance by written Stipulation and Order. Said Stipulation and Order shall state the date the Complaint was filed, the current trial date, as well as the proposed Final Status Conference date and proposed trial date. If there is no stipulation, the parties may seek a continuance by noticed motion or an ex parte application.
CONTINUANCES: All hearing dates, including trial dates, may be considered for a continuance by written Stipulation and Order. Said Stipulation and Order shall state the date the Complaint was filed, the current trial date, as well as the proposed Final Status Conference date and proposed trial date. If there is no stipulation, the parties may seek a continuance by noticed motion or an ex parte application.
Page 3 | CONTINUANCES
Chambers Communication Rules
Parties may submit on the tentative ruling by contacting the Judicial Assistant; if both parties agree to submit, the tentative ruling becomes the Court's order and no appearance is required.
The attorneys/self-represented litigants may submit on the tentative ruling by contacting the Judicial Assistant, and, if both parties agree to submit, then the tentative will become the Court's order, and no appearance at the hearing is necessary.
Page 1 | MOTIONS
Parties are requested to immediately call the Clerk at (818) 407-2233 when the action settles or is otherwise resolved.
The parties are also requested to notify the Clerk of this Court immediately by phone [(818) 407-2233] upon settlement or resolution of the action.
Page 5 | FINAL STATUS CONFERENCE (FSC) ORDER