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Court Rules
Judge

Judge Ann H. Park

Individual Rules, Standing Orders & Policies

Los Angeles Superior Court

Limits & Logistics

Document Limits

IDC Responsive Memorandum
3 pgs
Memorandum
3 pgs
IDC Memorandum
3 pgs

Courtesy Copies

Trial Notebook

Communication

Email

Chambers

nordept-p@lacourt.ca.gov
Hours: By 8:00 a.m. the day of the hearing
Phone

Chambers

562-345-3727
Hours: Monday to Friday 8:30 am to 12:00 pm & 1:30 pm to 4:30 pm
Filters:

Page & Word Limits3 rules

Page LimitsMandatory

The responding party may file and serve a responsive memorandum of no more than three pages at least two court days prior to the IDC.

IDC responsive memorandum
Up to 3 pages
Ca Lasc Courtroom SE P · p. 4
|SectionInformal Discovery Conferences
Page LimitsMandatory

At least five court days before the IDC, the moving party must file and serve a memorandum no longer than three pages setting forth the outstanding issues.

IDC memorandum
Up to 3 pages
Ca Lasc Courtroom SE P · p. 4
|SectionInformal Discovery Conferences
Page LimitsMandatory

Moving party IDC memorandum limited to 3 pages, responding party responsive memorandum limited to 3 pages.

Memorandum
Up to 3 pages
Responsive memorandum
Up to 3 pages

Court's wording

At least five court days before the IDC, the moving party must file and serve a memorandum no longer than three pages setting forth the outstanding issues. The responding party may file and serve a responsive memorandum of no more than three pages at least two court days prior to the IDC.

Document Format Requirements5 rules

FormattingMandatory

The parties must provide both a paper “trial notebook” for the Court and submit FSC/trial documents electronically.

File type
Paper
FormattingMandatory

Each exhibit must be separately numbered, with the numbers corresponding to the number of theexhibit on the joint exhibit list. If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3 etc.

FormattingMandatory

Leave at least four inches of blank ... any addenda to form instructions.

FormattingMandatory

The parties shall work together to provide exhibits electronically, if feasible.

FormattingImportant

Any party responding to a Kennemur v. State of California (1982) 133 Cal.App.3d 907 objection at trial must be prepared to have the page and line marked in any deposition testimony and any attorney communication demonstrating that the objecting party had reasonable advance notice of any opinion that departs from the prior notice.

Document Filing Requirements18 rules

Filing RequirementsMandatory

Parties with fee waivers must file Form FW-020 to request official court reporter before hearing/trial.

Court's wording

A party who has received a fee waiver pursuant to CRC 3.55(7) may request an official court reporter by filing form FW-020 https://selfhelp.courts.ca.gov/jcc-form/FW-020 before the hearing or trial (See CRC 2.956(c)).

Filing RequirementsMandatory

The first paragraph shall be formatted as follows: (1) a neutral statement of the dispute; and (2) one to three sentences describing (not arguing) each party’s position.

Filing RequirementsMandatory

Ex parte applications must show irreparable harm/immediate danger/statutory basis and why other relief methods are not feasible.

Court's wording

There must be an affirmative showing of "irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte." (See Cal. Rules of Court, rule 3.1202 (c).) You will need to demonstrate to the court the reason(s) why you cannot seek the requested relief by other means, such as a noticed motion or continuance of the trial.

Filing RequirementsMandatory

There must be an affirmative showing of "irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte." (See Cal. Rules of Court, rule 3.1202 (c).) You will need to demonstrate to the court the reason(s) why you cannot seek the requested relief by other means, such as a noticed motion or continuance of the trial.

Ca Lasc Courtroom SE P · p. 4
|SectionEx Parte Applications
Filing RequirementsMandatory

Motions in limine must include sworn declaration of conference with opposing party and their position, plus statutory notice.

Document
Motion in limine

Must include

  • Statutory notice
  • Sworn declaration

Court's wording

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

Filing RequirementsMandatory

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

Court's wording

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

Filing RequirementsMandatory

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

Filing RequirementsMandatory

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

Filing RequirementsMandatory

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

Filing RequirementsMandatory

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

Filing RequirementsMandatory

As to experts that counsel intends to call at trial, no later than the FSC, Counsel shall present to the Court and opposing counsel a copy of the Code of Civil Procedure section 2034.260 declaration that states the substance of the proffered opinion.

Filing RequirementsMandatory

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

Filing RequirementsMandatory

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

Ca Lasc Courtroom SE P · p. 9
|SectionDiscovery - General Orders
Filing RequirementsMandatory

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

Ca Lasc Courtroom SE P · p. 10
|SectionDiscovery - Production of Documents
Filing RequirementsImportant

The email must include the case number and identify the party submitting on the tentative with a copy (cc) to opposing counsel.

Document
Tentative submission email

Must include

  • Case number
Ca Lasc Courtroom SE P · p. 3
|SectionLAW & MOTION
Filing RequirementsImportant

The first paragraph shall be formatted as follows: (1) a neutral statement of the dispute; and (2) one to three sentences describing (not arguing) each party's position.

Ca Lasc Courtroom SE P · p. 4
|SectionInformal Discovery Conferences
Filing RequirementsImportant

Ex parte applications must comply with CRC 3.1200 et seq.

Ca Lasc Courtroom SE P · p. 4
|SectionEx Parte Applications
Filing RequirementsNote

TRIAL BRIEFS for each party are highly recommended in all cases, whether bench or jury trial.

Filing & Service rules

Electronic Filing Rules

Parties must use the Court Reservation System (CRS) to continue or withdraw motions and must inform the courtroom of the change.

Parties must use CRS to continue or withdraw motions and inform the courtroom of the change.

Page 3 | LAW & MOTION

Parties must reserve a hearing date for all law and motion hearings through the Court Reservation System (CRS); moderate-to-complex motions are heard Tuesdays and Thursdays and routine motions on Fridays.

The Court hears moderate to complex motions on Tuesdays and Thursdays, and routine motions on Fridays. Parties must reserve a date for all law and motion hearings via the Court Reservation System (CRS).

Page 3 | LAW & MOTION

Ex parte applications and supporting documents must be e-filed by 10:00 a.m. court day prior to hearing.

All ex parte applications and documents in support thereof must be electronically filed no later than 10:00 a.m. on the court day before the hearing.

Page 4

All ex parte applications and supporting documents must be electronically filed no later than 10:00 a.m. on the court day before the hearing.

All ex parte applications and documents in support thereof must be electronically filed no later than 10:00 a.m. on the court day before the hearing.

Page 4 | Ex Parte Applications

Plaintiff must e-file Notice of Settlement using Judicial Council Form CM-200.

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

Page 5

The plaintiff must e-file the Notice of Settlement on Judicial Council Form CM-200, even if the case settled at a Judicial mandatory settlement conference.

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

Page 5 | NOTICE OF SETTLEMENT / REQUEST FOR DISMISSAL

The parties must provide both a paper “trial notebook” for the Court and submit FSC/trial documents electronically.

The parties must provide both a paper “trial notebook” for the Court and submit FSC/trial documents electronically.

Page 6 | TRIAL PROCEDURES

Parties must submit paper trial notebook to court and FSC/trial documents electronically.

The parties must provide both a paper “trial notebook” for the Court and submit FSC/trial documents electronically.

Page 6

Self-represented litigants are exempt from the mandatory electronic filing requirements under California Rules of Court, rule 2.253(b)(2).

Pursuant to California Rules of Court, rule 2.253(b)(2), self-represented litigants are exempt from these mandatory Electronic Filing requirements.

Page 4 | Ex Parte Applications

Filing Timing and Cure Windows

Scheduling an IDC does not toll the deadline for filing a discovery motion unless the parties stipulate to toll deadlines.

California Code of Civil Procedure § 2016.080 has been repealed, therefore, the scheduling of an IDC does not toll the deadline for filing a discovery motion unless the parties stipulate to toll deadlines.

Page 4 | Informal Discovery Conferences

Ex parte oppositions must be e-filed by 8:30 a.m. on the day of the hearing.

Any written opposition shall be electronically filed by 8:30 am on the day of the hearing.

Page 4

Moving party must file IDC memorandum at least 5 court days before IDC.

At least five court days before the IDC, the moving party must file and serve a memorandum no longer than three pages setting forth the outstanding issues.

Page 4

The responding party may file and serve a responsive memorandum of no more than three pages at least two court days prior to the IDC.

The responding party may file and serve a responsive memorandum of no more than three pages at least two court days prior to the IDC.

Page 4

The moving party must file and serve the IDC memorandum at least five court days before the IDC.

At least five court days before the IDC, the moving party must file and serve a memorandum no longer than three pages setting forth the outstanding issues.

Page 4 | Informal Discovery Conferences

Ex parte applications must be filed by 10:00 a.m. court day prior to hearing.

All ex parte applications and documents in support thereof must be electronically filed no later than 10:00 a.m. on the court day before the hearing.

Page 4

Absent an exemption, ex parte applications must be filed by 10:00 a.m. on the court day prior to the ex parte hearing.

Absent an exemption, you must file the application by 10:00 am on the court day prior to the ex parte hearing.

Page 4 | Ex Parte Applications

Written opposition to an ex parte application must be electronically filed by 8:30 a.m. on the day of the hearing.

Any written opposition shall be electronically filed by 8:30 am on the day of the hearing.

Page 4 | Ex Parte Applications

The responding party may file and serve a responsive memorandum of no more than three pages at least two court days prior to the IDC.

The responding party may file and serve a responsive memorandum of no more than three pages at least two court days prior to the IDC.

Page 4 | Informal Discovery Conferences

The following FSC documents must be provided to the Court prior to the FSC: 1. MOTIONS IN LIMINE AND BIFURCATION MOTIONS must have been filed and served with proper statutory notice and set for hearing on the FSC

The following FSC documents must be provided to the Court prior to the FSC: 1. MOTIONS IN LIMINE AND BIFURCATION MOTIONS must have been filed and served with proper statutory notice and set for hearing on the FSC

Page 6 | TRIAL PROCEDURES

If no court reporter is retained for trial, the parties must jointly prepare a summary of each day's proceedings and lodge it in the courtroom the next morning before proceedings resume.

The Court strongly encourages the parties to retain a court reporter for trials. If no court reporter is used, the parties must jointly prepare a summary of the day's proceedings and lodge it in the courtroom the next morning before proceedings resume.

Page 6 | TRIAL PROCEDURES

A proposed protective order must be served and filed within 5 days of the CMC order.

If a party believes any of this information should be subject to a protective order, that party shall serve and file a proposed protective order within 5 days of this order and the parties shall meet and confer as to agreeable language for the same.

Page 10 | Discovery - Production of Documents

Trial binders lodged before settlement must be picked up within two weeks of filing the Notice of Settlement or they will be discarded.

If trial binders were lodged prior to settlement, they must be picked up within two weeks of filing the Notice of Settlement or they will be discarded.

Page 5 | NOTICE OF SETTLEMENT / REQUEST FOR DISMISSAL

Service and Proof of Service Rules

All parties who use e-filing must accept electronic service, except when personal service is required by law or where any party is self-represented.

Pursuant to Code of Civil Procedure §1010.6, local Rule 3.4, and General Order 2019-GEN-014-00 issued May 3, 2019, the Court orders all parties who use e-filing to accept electronic service, except in those circumstances when personal service is required by law or where any of the parties are self-represented.

Page 3 | LAW & MOTION

All e-filing parties must accept electronic service except when personal service required by law or any party is self-represented.

Pursuant to Code of Civil Procedure §1010.6, local Rule 3.4, and General Order 2019-GEN-014-00 issued May 3, 2019, the Court orders all parties who use e-filing to accept electronic service, except in those circumstances when personal service is required by law or where any of the parties are self-represented.

Page 3

Motions in limine and bifurcation motions must be served with proper statutory notice.

MOTIONS IN LIMINE AND BIFURCATION MOTIONS must have been filed and served with proper statutory notice and set for hearing on the FSC

Page 6 | TRIAL PROCEDURES

Both parties must serve verifications along with the documents they produce in discovery.

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

Page 11 | Discovery Addendum - Document Production

Courtesy Copy Requirements

Parties must provide a paper trial notebook to the Court.

The parties must provide both a paper “trial notebook” for the Court and submit FSC/trial documents electronically.

Page 6 | TRIAL PROCEDURES

Sealing & Redaction Procedures

A party seeking protection for the ordered discovery must serve and file a proposed protective order within 5 days of the order and meet and confer on language, with the standard SCLAC protective order as the default.

If a party believes any of this information should be subject to a protective order, that party shall serve and file a proposed protective order within 5 days of this order and the parties shall meet and confer as to agreeable language for the same. The default will be the standard Protective Order provided by the SCLAC in its website.

Page 10 | Discovery - Production of Documents

Pre-Motion Conference Requirements

Trial counsel must meet and confer (in person, videoconference, or telephone) no later than 15 calendar days before the initial and any succeeding CMC to address the issues in CRC Rules 3.724 and 3.727.

Trial counsel are required to meet and confer in person, via videoconference, or by telephone no later than 15 calendar days before the date set for the initial and any succeeding CMC to consider each of the issues identified in CRC Rules 3.724 and 3.727.

Page 2 | CASE MANAGEMENT CONFERENCE (CMC)

Trial counsel must meet and confer in person, by telephone, or by videoconference before bringing a discovery motion, and exchanging letters or emails alone is insufficient.

The Court strongly discourages discovery motions and encourages informal resolution of discovery disputes. Trial counsel must meet and confer in person, by telephone, or videoconference to resolve or narrow the discovery dispute. Merely exchanging letters or emails is insufficient.

Page 3 | Informal Discovery Conferences

Trial counsel must meet and confer in person, by phone, or video to resolve discovery disputes before filing discovery motions; letters/emails insufficient.

Trial counsel must meet and confer in person, by telephone, or videoconference to resolve or narrow the discovery dispute. Merely exchanging letters or emails is insufficient.

Page 3

Discovery Conference (IDC) by filing an IDC request [LACIV094] See https://www.lacourt.org/forms/pdf/LACIV094.pdf. The court will review the request and issue an order granting or denying the request. If granted, the clerk will schedule an IDC. The IDC should eliminate any need for a motion. Absent a showing of good cause, the Court may continue any discovery motion filed before the IDC process is concluded.

Discovery Conference (IDC) by filing an IDC request [LACIV094] See https://www.lacourt.org/forms/pdf/LACIV094.pdf. The court will review the request and issue an order granting or denying the request. If granted, the clerk will schedule an IDC. The IDC should eliminate any need for a motion. Absent a showing of good cause, the Court may continue any discovery motion filed before the IDC process is concluded.

Page 4

Before filing a noticed motion for discovery beyond sections 2-6, the parties must meet and confer regarding the additional discovery needed to prepare the case for trial.

To the extent any party concludes that additional discovery is necessary beyond sections 2-6, that party shall by noticed motion request such discovery. In advance of any such request, the parties are ordered to meet and confer regarding any additional discovery needed to prepare this case for trial.

Page 9 | Discovery - General Orders

Counsel attending the CMC must know the case and be prepared to discuss all issues identified in CRC Rule 3.727.

Counsel attending the CMC must be knowledgeable about the case and be prepared to discuss all the issues set forth in CRC Rule 3.727.

Page 2 | CASE MANAGEMENT CONFERENCE (CMC)

The court will review the request and issue an order granting or denying the request. If granted, the clerk will schedule an IDC. The IDC should eliminate any need for a motion. Absent a showing of good cause, the Court may continue any discovery motion filed before the IDC process is concluded.

The court will review the request and issue an order granting or denying the request. If granted, the clerk will schedule an IDC. The IDC should eliminate any need for a motion. Absent a showing of good cause, the Court may continue any discovery motion filed before the IDC process is concluded.

Page 4 | Informal Discovery Conferences

Chambers Communication Rules

Counsel submitting on tentative ruling may email judicial assistant by 8am hearing day; email must include case number, party, cc opposing counsel.

Counsel who intend to submit on the tentative may call the courtroom or send an email to the Judicial Assistant by 8:00 a.m. the day of the hearing. The email must include the case number and identify the party submitting on the tentative with a copy (cc) to opposing counsel.

Page 3

Counsel may submit on the tentative by calling the courtroom or emailing the Judicial Assistant by 8:00 a.m. on the day of the hearing.

Counsel who intend to submit on the tentative may call the courtroom or send an email to the Judicial Assistant by 8:00 a.m. the day of the hearing.

Page 3 | LAW & MOTION

Department P chambers email is NORDept-P@lacourt.ca.gov, with staff available Monday to Friday 8:30 am-12:00 pm and 1:30 pm-4:30 pm.

Email: NORDept-P@lacourt.ca.gov Hours: Monday to Friday 8:30 am to 12:00 pm & 1:30 pm to 4:30 pm

Page 1 | GENERAL INFORMATION

Department P contact details: phone 562-345-3727, email NORDept-P@lacourt.ca.gov, hours M-F 8:30am-12pm and 1:30pm-4:30pm.

Telephone Number: 562-345-3727 Email: NORDept-P@lacourt.ca.gov Hours: Monday to Friday 8:30 am to 12:00 pm & 1:30 pm to 4:30 pm

Page 1

Department P chambers can be reached by phone at 562-345-3727 during posted hours (Monday to Friday 8:30 am-12:00 pm and 1:30 pm-4:30 pm).

Telephone Number: 562-345-3727 Email: NORDept-P@lacourt.ca.gov Hours: Monday to Friday 8:30 am to 12:00 pm & 1:30 pm to 4:30 pm

Page 1 | GENERAL INFORMATION

Documents of departments with no single judge listed

About Judge Ann H. Park

Judge Ann H. Park is a judge of the Superior Court of California, County of Los Angeles, the state trial court serving Los Angeles County, and serves in the district division.

This judge's procedures are published through the court's general rules.

Common questions about Judge Ann H. Park's rules

Are courtesy copies required for Judge Ann H. Park?

Courtesy-copy rule applies for trial notebooks. Parties must provide a paper trial notebook to the Court.

View ruleSource: page 6, section TRIAL PROCEDURES

Does Judge Ann H. Park require a pre-motion conference or letter before filing a motion?

Trial counsel must meet and confer in person, by telephone, or by videoconference before bringing a discovery motion, and exchanging letters or emails alone is insufficient.

View ruleSource: page 3, section Informal Discovery Conferences

What page or word limits apply to idc responsive memorandum before Judge Ann H. Park?

Judge Ann H. Park's rule states these limits: 3 pages. The responding party's IDC responsive memorandum is limited to three pages.

View ruleSource: page 4, section Informal Discovery Conferences

What page or word limits apply to memorandum before Judge Ann H. Park?

Judge Ann H. Park's rule states these limits: 3 pages; 3 pages. Moving party IDC memorandum limited to 3 pages, responding party responsive memorandum limited to 3 pages.

View ruleSource: page 4

What formatting rules apply to filings before Judge Ann H. Park?

Judge Ann H. Park's formatting rule includes file format paper. Trial notebook must be provided in paper format to the court.

View ruleSource: page 6

What must be included with ex parte application filings before Judge Ann H. Park?

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

View ruleSource: page 4, section Ex Parte Applications

What must be included with joint witness list filings before Judge Ann H. Park?

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

View ruleSource: page 7

How may parties contact Judge Ann H. Park's chambers?

The rule lists email NORDept-P@lacourt.ca.gov. Counsel submitting on tentative ruling may email judicial assistant by 8am hearing day; email must include case number, party, cc opposing counsel.

View ruleSource: page 3

How does Judge Ann H. Park handle sealed or redacted filings?

A party seeking protection for the ordered discovery must serve and file a proposed protective order within 5 days of the order and meet and confer on language, with the standard SCLAC protective order as the default.

View ruleSource: page 10, section Discovery - Production of Documents

Is electronic filing required before Judge Ann H. Park?

Parties must use the Court Reservation System (CRS) to continue or withdraw motions and must inform the courtroom of the change.

View ruleSource: page 3, section LAW & MOTION

What filing deadlines apply to proposed protective order filings before Judge Ann H. Park?

A proposed protective order must be served and filed within 5 days of the CMC order.

View ruleSource: page 10, section Discovery - Production of Documents

What rule applies to e-service before Judge Ann H. Park?

Details: method: e-service. All parties who use e-filing must accept electronic service, except when personal service is required by law or where any party is self-represented.

View ruleSource: page 3, section LAW & MOTION
Complete rules summary for Judge Ann H. Park

Counsel attending the CMC must know the case and be prepared to discuss all issues identified in CRC Rule 3.727.

Parties must use the Court Reservation System (CRS) to continue or withdraw motions and must inform the courtroom of the change.

Parties must reserve a hearing date for all law and motion hearings through the Court Reservation System (CRS); moderate-to-complex motions are heard Tuesdays and Thursdays and routine motions on Fridays.

All parties who use e-filing must accept electronic service, except when personal service is required by law or where any party is self-represented.

Trial counsel must meet and confer in person, by telephone, or by videoconference before bringing a discovery motion, and exchanging letters or emails alone is insufficient.

The plaintiff must e-file the Notice of Settlement on Judicial Council Form CM-200, even if the case settled at a Judicial mandatory settlement conference.

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

The parties must provide both a paper “trial notebook” for the Court and submit FSC/trial documents electronically.

The parties shall work together to provide exhibits electronically, if feasible.

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

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

Counsel must leave at least four inches of blank space on any addenda to form jury instructions (sentence continues across a page break; see source).

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

A party responding to a Kennemur objection at trial must be prepared with the page and line marked in deposition testimony and attorney communications showing the objecting party had reasonable advance notice of any departing opinion.

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

Before filing a noticed motion for discovery beyond sections 2-6, the parties must meet and confer regarding the additional discovery needed to prepare the case for trial.

A party seeking protection for the ordered discovery must serve and file a proposed protective order within 5 days of the order and meet and confer on language, with the standard SCLAC protective order as the default.

Both parties must serve verifications along with the documents they produce in discovery.

A proposed protective order must be served and filed within 5 days of the CMC order.

The following FSC documents must be provided to the Court prior to the FSC: 1. MOTIONS IN LIMINE AND BIFURCATION MOTIONS must have been filed and served with proper statutory notice and set for hearing on the FSC

The first paragraph of the IDC memorandum must contain a neutral statement of the dispute and one to three sentences describing (not arguing) each party's position.

Trial counsel must meet and confer (in person, videoconference, or telephone) no later than 15 calendar days before the initial and any succeeding CMC to address the issues in CRC Rules 3.724 and 3.727.

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

Each exhibit must be separately numbered to correspond with the joint exhibit list, and multi-page exhibits must have internally numbered pages (e.g., 3.1, 3.2, 3.3).

Ex parte applications must comply with California Rules of Court, rule 3.1200 et seq.

Ex parte applications and supporting documents must be e-filed by 10:00 a.m. court day prior to hearing.

Trial briefs are highly recommended (though not mandatory) for each party in all cases, whether bench or jury trial.

Counsel submitting on tentative ruling may email judicial assistant by 8am hearing day; email must include case number, party, cc opposing counsel.

Department P chambers email is NORDept-P@lacourt.ca.gov, with staff available Monday to Friday 8:30 am-12:00 pm and 1:30 pm-4:30 pm.

Scheduling an IDC does not toll the deadline for filing a discovery motion unless the parties stipulate to toll deadlines.

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