Judge Bernie C. LaForteza
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- 1 copy
Exhibit Binder
- 2 copies
Exhibits
- 2 copies
- 3 copies • When New Exhibit Identified
Papers Filed Less Than 5 Days Before Scheduled Hearing, Voluminous Compilations of Exhibits
Adjournments
- Continuance stipulations must be filed 5 court days before hearing, showing good cause.
- Stipulations to continue hearings must be filed no later than 5 court days before the hearing; absent a stipulation, any party may seek a continuance by noticed motion or ex parte application.
Communication
Phone
Chambers
Phone
Clerk
Page & Word Limits2 rules
Trial briefs limited to 20 pages, must be signed, filed, and served on all parties.
- Trial brief
- Up to 20 pages
Court's wording
Trial briefs: (not to exceed 20 pages) These briefs should include a description of the claims, defenses, relief sought, evidentiary disputes, and all issues to be decided at trial along with a discussion of any novel or unusual issues of law, with citations to supporting authorities. The briefs must be signed, filed with the Court and served on all parties.
Trial briefs: (not to exceed 20 pages)
- Trial brief
- Up to 20 pages
Document Format Requirements2 rules
Trial Binder: the parties shall cooperate in compiling a 3-ring trial binder that shall be delivered to Dept. F46 at least 10 court days before the FSC.
- Binding
- Three-ring binder
- Trial binder
Please do not: 1. Fail to pre-number your exhibits 2. Expect the clerk to keep track of your exhibits 3. Produce exhibits at trial which opposing counsel has never seen, unless they are used for impeachment 4. Fail to produce the requisite number of exhibit books
- Exhibits
Formatting
- •Pre-number all exhibits
Document Filing Requirements23 rules
The Court requires timely compliance with Cal. Rules of Court 3.300 Re: Notice of Related Cases. The Notice must be filed in each related case.
Counsel must comply with their obligation to submit case management statements pursuant to rule 3.725 of the California Rules of Court.
Counsel must submit case management statements per CRC 3.725, and failure to comply with related rules may result in monetary sanctions and/or delay in trial setting.
Court's wording
Counsel must comply with their obligation to submit case management statements pursuant to rule 3.725 of the California Rules of Court. Failure to comply with the Cal. Rules of Court., rules 3.722, 3.724, 3.727 and 3.728, Los Angeles County Superior Court Rules 3.24 and 3.25, and/or this court's scheduling orders may result in monetary sanctions and/or delay in trial setting.
The Court requires timely compliance with Cal. Rules of Court 3.300 Re: Notice of Related Cases. The Notice must be filed in each related case.
The request must be made by using the local form (LASC LACIV 269).
Court reporter requests with fee waiver must use form LASC LACIV 269, filed 10 calendar days before hearing.
Court's wording
The Request for Court Reporting Services by a Party with a Fee Waiver should be filed at least ten calendar days before the hearing or trial for which the reporter is requested. The request must be made by using the local form (LASC LACIV 269).
Statement of the Case: must be prepared jointly by the parties. It should be a short, non-argumentative written statement of the case to be read to the jury. It must be signed by all parties and filed with the Court.
The briefs must be signed, filed with the Court and served on all parties.
Proposed Instructions: shall be included in the trial binder. These should include a jointly submitted packet of all requested and properly edited CACI or special instructions that are agreed to or not. The instructions shall be submitted in the proper format for presentation to the jury.
Depositions: All original/certified copy of depositions must be lodge with the Court prior to the beginning of trial.
The joint exhibit list must be prepared jointly in chart format with columns for exhibit title/number, stipulation status, objections, and the Court's trial notation, and must be signed by all parties and filed with the Court.
Court's wording
Exhibit list: must be prepared jointly by the parties. It should be prepared in chart format with each exhibit identified by title and its assigned exhibit number. Additional columns should indicate whether the exhibit will be admitted by stipulation, authenticated by stipulation, or challenged with objections, which shall be set forth in a column for objections. A final column should be included on the right for the Court's notation of whether the exhibit was admitted at trial. The joint exhibit list must be signed by all parties and filed with the Court.
All operative pleadings: must be included in the trial binder. This includes the operative complaints and cross-complaints and the operative answers thereto.
Verdict Form: must be jointly prepared by the parties. If the parties cannot agree on joint verdict forms, then the Court will provide a general verdict form to the jury.
witnesses' names, time estimates for direct and cross-examination, and whether the witnesses will be assisted by an interpreter. The joint witness list must be signed by all parties filed with the Court.
The joint list of proposed jury instructions must be prepared jointly in chart format showing proponents and opponents of each instruction, and must be signed by all parties and filed with the Court.
Court's wording
List of proposed jury instructions: must be prepared jointly by the parties. It should be prepared in chart format to include all CACI and special jury instructions that are jointly proposed by the parties as well as those that are proposed by only some of the parties but opposed by another party. A column in the chart must indicate the proponent(s) and opponent(s) of each proposed instruction. A final column should be included on the right of the Court's notation of whether the instruction was given at trial. The joint list of jury instructions must be signed by all parties and filed with the Court.
All motions in limine must be in writing and must be filed and served at least 10 court days before the FSC.
Any opposition to a motion in limine must be in writing and must be filed and served at least 5 court days before the FSC.
Reply briefs must be in writing and properly filed and served.
ii. A brief outline of the nature of the case; iii. Proposed questions and voir dire procedures; iv. The witness names to be read to the jury; v. Any witness or attorney scheduling issues; any witness issues (e.g., availability, need for interpreters, etc.); Any anticipated evidentiary or other legal issues; vi. Any party stipulations; and any other trial issues that the parties reasonably can anticipate.
The parties shall comply with Cal. R. Ct. 2.1040, requiring the provision of a transcript of various recordings. The Court shall deem that the party receiving the transcript before announcing "ready" waives any objection to the accuracy of the transcript unless raised at the first trial appearance before this Court.
Upon receiving such notice, the tentative ruling will become the order of the Court and the prevailing party shall give notice of the ruling.
These briefs should include a description of the claims, defenses, relief sought, evidentiary disputes, and all issues to be decided at trial along with a discussion of any novel or unusual issues of law, with citations to supporting authorities.
The Court encourages the parties to narrow the scope of triable issues by reaching stipulations as to certain undisputed facts. Such stipulations should be reduced to writing and filed with the Court. They should also be included in the trial binder, if reached before trial.
Filing & Service rules
Electronic Filing Rules
Self-represented litigants without electronic filing means may file paper documents in the clerk’s office.
Self-represented litigants who lack the means for filing electronically may file their documents in the clerk’s office.
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Self-represented litigants who lack the means to file electronically may file their documents in the clerk's office.
Self-represented litigants who lack the means for filing electronically may file their documents in the clerk's office.
Page 2 | Law & Motion
Filing Timing and Cure Windows
Requests for court reporting services by fee-waiver parties must be filed at least ten calendar days before the hearing or trial.
The Request for Court Reporting Services by a Party with a Fee Waiver should be filed at least ten calendar days before the hearing or trial for which the reporter is requested.
Page 3 | Court Reporters
Motions in limine must be filed 10 court days before FSC, oppositions 5 days before.
All motions in limine must be in writing and must be filed and served at least 10 court days before the FSC. Any opposition to a motion in limine must be in writing and must be filed and served at least 5 court days before the FSC.
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Motions in limine must be filed and served at least 10 court days before the Final Status Conference.
All motions in limine must be in writing and must be filed and served at least 10 court days before the FSC.
Page 6 | Final Status Conferences and Trials
Oppositions to motions in limine must be filed and served at least 5 court days before the Final Status Conference.
Any opposition to a motion in limine must be in writing and must be filed and served at least 5 court days before the FSC.
Page 6 | Final Status Conferences and Trials
Service and Proof of Service Rules
Ex parte applications must include proof of the required notice, and failure to provide proof of notice is a common ground for denial.
Please pay particular attention to the notice requirements and the requirement of an affirmative factual showing of good cause. Among the most common grounds for denial of ex parte applications are failure to provide proof of required notice and failure to prove why the application could not be brought as a noticed motion.
Page 2 | Ex Parte Applications
Trial briefs must be signed, filed with the Court, and served on all parties.
The briefs must be signed, filed with the Court and served on all parties.
Page 4 | Trial Management Order - Final Status Conference Orders
Motions in limine must be served at least 10 court days before FSC.
All motions in limine must be in writing and must be filed and served at least 10 court days before the FSC.
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Parties must exchange trial exhibits in advance of trial to the extent required by law.
The parties shall exchange exhibits in advance of trial to the extent required by law.
Page 8 | Exhibits
Filing Fees and Waivers
Jury fees must be posted on or before the initial case management conference or the party may waive a jury trial under CCP section 631(f).
Jury fees must be posted on or before the initial case management conference. Failure to post jury fees at that time may result in a jury waiver pursuant to CCP section 631(f).
Page 3 | Jury Fees
Jury fees must be posted by initial case management conference.
Jury fees must be posted on or before the initial case management conference. Failure to post jury fees at that time may result in a jury waiver pursuant to CCP section 631(f).
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Courtesy Copy Requirements
Courtesy copies are required for papers filed less than 5 days before the scheduled hearing and for voluminous exhibit compilations, and must be deposited in the Courtesy Copy box outside Dept. F46.
Courtesy copies are required for any papers filed less than 5 days before the scheduled hearing and for voluminous compilations of exhibits. Courtesy copies shall be submitted by depositing the copy in the "Courtesy Copy" box located in the hallway outside Dept. F46.
Page 2 | Courtesy Copies
Courtesy copies required for papers filed less than 5 days before hearing, submitted in Dept. F46 hallway box.
Courtesy copies are required for any papers filed less than 5 days before the scheduled hearing and for voluminous compilations of exhibits. Courtesy copies shall be submitted by depositing the copy in the “Courtesy Copy” box located in the hallway outside Dept. F46.
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Parties must provide two exhibit binders: one for the Judicial Assistant (to be marked) and one courtesy copy for the Judge.
Exhibit Binders: 1 for the Judicial Assistant that will be marked and 1 courtesy copy for the Judge.
Page 5 | Final Status Conferences and Trials
Exhibit binders require 1 copy for Judicial Assistant and 1 courtesy copy for Judge.
Exhibit Binders: 1 for the Judicial Assistant that will be marked and 1 courtesy copy for the Judge.
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A party identifying a new exhibit not previously disclosed to opposing counsel must bring 3 copies: one for the Judicial Assistant, one for the Court, and one for the witness.
If either side is going to identify a new exhibit that was not previously disclosed to opposing counsel, e.g., an exhibit used for impeachment and not disclosed in discovery, then the proponent is responsible for bringing 3 copies (one for the Judicial Assistant, one for the Court and one for the witness).
Page 9 | Courtroom Information and Trial Guidelines
Filing Bundling Requirements
3-ring trial binder required, delivered to Dept. F46 at least 10 court days before FSC.
the parties shall cooperate in compiling a 3-ring trial binder that shall be delivered to Dept. F46 at least 10 court days before the FSC.
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Parties must jointly compile a 3-ring trial binder containing all required documents in the specified order, delivered to Dept. F46 at least 10 court days before the FSC.
Trial Binder: the parties shall cooperate in compiling a 3-ring trial binder that shall be delivered to Dept. F46 at least 10 court days before the FSC. The binder must include all the following documents placed in the binder in the following order:
Page 4 | Trial Management Order - Final Status Conference Orders
Pre-Motion Conference Requirements
Law and motion hearings must be scheduled through the Court Reservation System (CRS), and reserving more than one hearing date for the same motion is prohibited.
The Court Reservation System (CRS) is required for scheduling law and motion hearings in Dept. F46. CRS is available 24 hours a day, 7 days a week and reservations can be made from a computer or smartphone. Please note, you are prohibited from reserving more than one hearing date for the same motion.
Page 1 | Law & Motion - Scheduling Law and Motion Hearings
Demurrers must comply with the Code of Civil Procedure section 430.41 meet and confer requirements or they will be taken off calendar.
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 necessary or even advisable. Demurrers filed without compliance with the meet and confer requirements will be taken off calendar.
Page 2 | Demurrers
Demurrers without meet and confer compliance will be taken off calendar.
Demurrers filed without compliance with the meet and confer requirements will be taken off calendar.
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Counsel and self-represented litigants must meet and confer 10 court days before Final Status Conference.
counsel and/or self-represented litigants shall meet and confer on the telephone or by video conference at least 10 court days before the FSC to discuss, arrange for the exchange of, and the submission to the Court all documents identified in LACSCR 3.25(f) and(f)(3)-(8).
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Parties must meet and confer on all motions in limine before the Court considers them, and boilerplate motions in limine are highly discouraged.
confer on all motions in limine before they are considered by the Court. Boilerplate motions are highly discouraged.
Page 6 | Final Status Conferences and Trials
Parties should meet and confer before filing any motion and avoid unnecessary or tactical-delay motions.
The parties should meet and confer before filing any motion and avoid filing any unnecessary motion for one which is designed to delay the proceedings or filed solely for tactical reasons.
Page 1 | Law & Motion - Scheduling Law and Motion Hearings
Before filing a discovery motion, trial counsel should meet and confer in person to resolve or narrow the dispute, as the court strongly discourages discovery motions.
The court strongly discourages discovery motions and encourages informal resolution of discovery disputes. The rules governing discovery are very clear, and virtually all disputes can be resolved through communication and good faith discussion. Before filing a discovery motion, trial counsel (meaning the lawyers who will try the case) should meet and confer in person to resolve or at least narrow the dispute.
Page 2 | Discovery Motions
Before filing a discovery motion, trial counsel (meaning the lawyers who will try the case) should meet and confer in person to resolve or at least narrow the dispute.
Before filing a discovery motion, trial counsel (meaning the lawyers who will try the case) should meet and confer in person to resolve or at least narrow the dispute.
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Adjournment & Extension Requirements
Stipulations to continue hearings must be filed no later than 5 court days before the hearing; absent a stipulation, any party may seek a continuance by noticed motion or ex parte application.
Stipulations setting forth the facts showing good cause to continue any other hearings must be filed no later than 5 court days before the hearing. If there is no stipulation, any party may seek a continuance by noticed motion or ex parte application.
Page 2 | Continuances
Continuance stipulations must be filed 5 court days before hearing, showing good cause.
Stipulations setting forth the facts showing good cause to continue any other hearings must be filed no later than 5 court days before the hearing.
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The Court will consider trial scheduling conflicts only if they are raised as soon as they are known.
The Court will consider scheduling conflicts, if they are raised as soon as they are known.
Page 6 | 1. Trial Schedule
Law and motion matters may be continued through the CRS system.
Law and motion matters may be continued by the CRS system.
Page 2 | Continuances
Chambers Communication Rules
During jury deliberations, parties and counsel must stay within fifteen minutes of the courthouse (unless granted leave) and must give the Court clerk a telephone number for immediate contact.
During jury deliberations, the parties and counsel must stay within fifteen minutes from the courthouse, unless granted leave to do otherwise, and must provide the Court clerk with a telephone number that allows for immediate contact.
Page 6 | 1. Trial Schedule
Dept. F46 can be reached at (818) 407-2246, and courtroom hours are 8:30 AM to 12:00 PM and 1:30 PM to 4:30 PM.
Court information: 9425 Penfield Ave., Dept. F46, Chatsworth, CA 91311. Telephone number: (818) 407-2246. Courtroom hours: 8:30 AM to 12:00 PM and 1:30 PM to 4:30 PM.
Page 1 | Courtroom Information and Trial Guidelines