Judge Christian R. Gullon
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Courtesy copies
- 1 copy
- 3 copies
Exhibits
- 4 copies • On Day of Trial
Binding: Tabbed Three Ring
Joint Exhibit Binder
- 4 copies • On Day of Trial
Communication
Clerk
Phone
Chambers
Document Format Requirements6 rules
Please also submit the Verdict Form to the clerk via email (POMDeptEAO@LACourt.org) in MS Word format.
- File type
- Word
Please also submit the Verdict Form to the clerk via email (POMDeptEAO@LACourt.org) in MS Word format.
- File type
- Word
- Proposed verdict form
Formatting
- •MS Word format required for the verdict form submitted to the clerk
Parties are to abide by California Rules of Court Rule 2.1055.
Formatting
- •Jury instructions must abide by California Rules of Court Rule 2.1055
If ten (10) or more exhibits are to be used, copies of the exhibits shall be placed in one or more 3-ring binders. Non- documentary exhibits shall be represented in the binder with a simple written description.
- Binding
- Three-ring binder
- Exhibits
The information may be provided to the opposing party in electronic form as a PDF at the option of the producing party.
The information may be provided to the opposing party in electronic form as a PDF at the option of the producing party.
- Document production
Formatting
- •Electronic PDF form is optional, at the option of the producing party
Document Filing Requirements16 rules
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.
- Document
- Case management statement
Must include
- •Using Judicial Council Form CM-110
All Counsel are to prepare a Joint Trial Binder which is to include the following:
Motions in limine must be numbered consecutively, opposed with corresponding motion number, and filed in numerical order with replies/oppositions attached.
Court's wording
If more than one Motion in Limine is filed, each shall be numbered consecutively. Opposition papers shall include the number of the motion to which it corresponds. Motions in Limine are to be placed in numerical order starting with Plaintiff’s Motions in Limine then Defense Motions in Limine. All replies and opposition are to be placed directly behind the Motion in Limine in question.
Parties must file a joint proposed general or special verdict form, or if they cannot agree, 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. The parties are urged to agree on a verdict form. If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.
Counsel must submit a Joint Exhibit List numbered from 1 with three copies containing columns for the Clerk and Court, with exhibits numbered per Rules 3.52–3.53.
Court's wording
Counsel shall submit a Joint Exhibit List beginning with the number 1 and provide three copies of the exhibit list with columns for the Clerk and the Court to use to indicate whether the exhibit is marked and received into evidence. Exhibits shall be numbered in conformance with Rules 3.52 – 3.53.
At the Final Status Conference counsel must submit a Joint List of all requested jury instructions with fully completed copies, attaching disputed instructions separately with the requesting party identified, and must meet and confer no later than two days before the conclusion of evidence to create a final set of instructions, without waiving objections.
Court's wording
At the Final Status Conference, Counsel shall provide the Court with a Joint List of all Jury Instructions requested and a copy of all requested instructions fully filled out. Those instructions not agreed upon should be attached separately and the party making the request should be identified. No later than two days before the conclusion of evidence, the Court will require Counsel to meet and confer for the purpose of creating a final set of instructions. Submission of the Joint Jury Instructions shall not be deemed a waiver of any objection to the giving of an instruction on the Joint List.
Counsel must submit a Joint Deposition Designation List numbered from 1 with three copies containing Clerk and Court columns, indicating whether excerpts are stipulated or the legal grounds for objections.
Court's wording
Counsel shall submit a Joint Deposition Designation List beginning with the number 1 and provide three copies of the Deposition Designation List with columns for the Clerk and the Court to use to indicate whether the Deposition Designation is admitted or not. The Joint Deposition Designation List is to include whether excerpts are stipulated or the Legal Grounds for Objections.
At least five (5) court days before the Informal Discovery Conference, the parties and counsel shall file a joint statement that succinctly summarizes the nature of the dispute, the necessity for the discovery, the basis for any objection or withholding of information, and the overall status of discovery.
If any Defendants have not been served, Plaintiff or Plaintiff's Counsel must submit a declaration to the Court seven (7) days prior to the hearing explaining why service has not been completed
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.
The Joint Witness List shall identify each witness by name and estimate the length of the direct, cross, and redirect examination of each witness, and include a total number of hours for all witness testimony.
Opposition papers shall include the number of the motion to which it corresponds.
If more than one Motion in Limine is filed, each shall be numbered consecutively.
Trial briefs are strongly encouraged (not mandatory) and should describe the facts/claims/defenses, elements and burden of proof, major legal issues with points and authorities, and relief and damages sought.
- Document
- Trial brief
Should include
- •Legal argument
Court's wording
Trial Briefs are strongly encouraged to be filed and should contain: • A brief description of the facts, claims, and defenses subject to litigation. • The elements and burden of proof for each of the cause(s) of action. • A list of major legal issues anticipated with points and authorities supporting and defending the issues. • A brief statement of the relief claimed, and calculations of damages sought. • Any further information that counsels believes may assist the court in ruling upon trial objections or matters that may arise during trial.
The Court requests that Counsel submit a Joint Witness List and Joint Statement of the case to be read to the jury.
Counsel for the Plaintiffs and/or Cross-Complainants are requested to provide the Court with a copy of the Operative Complaint(s) prior to trial. Counsel should indicate prior to Trial any cause(s) of action which will be dismissed.
Filing & Service rules
Electronic Filing Rules
Self-represented litigants may file ex parte applications in person by 8:30 a.m. on the day of the hearing.
Litigants in Propria Persona are permitted to file Ex Partes in-person by 8:30 a.m. the day the Ex Parte is to be heard.
Page 1 | Ex Parte Information - Litigants in Propria Persona
Attorneys must e-file ex parte applications by 10:00 a.m. the day prior to the hearing, with 24 hours' notice to opposing parties.
For Attorneys: Ex Partes are heard Monday through Friday at 9:00 a.m. Parties are to e-file the Ex Parte the day prior before 10:00 a.m. Ensure to give proper 24 hours’ notice.
Page 1 | Ex Parte Information
Pro se litigants may file ex parte applications in-person by 8:30 a.m. the day of the hearing, with 24 hours' notice to opposition.
Litigants in Propria Persona: Litigants in Propria Persona are permitted to file Ex Partes in-person by 8:30 a.m. the day the Ex Parte is to be heard. Litigants in Propria Persona are required to give the opposition 24 hours’ notice.
Page 1 | Ex Parte Information
Attorneys must e-file ex parte applications (heard weekdays at 9:00 a.m.) the day before the hearing, no later than 10:00 a.m.
For Attorneys: Ex Partes are heard Monday through Friday at 9:00 a.m. Parties are to e-file the Ex Parte the day prior before 10:00 a.m.
Page 1 | Ex Parte Information
Moving parties can schedule an Informal Discovery Conference by e filing LACIV 094.
Moving parties can schedule an Informal Discovery Conference by e filing LACIV 094.
Page 5 | Discovery Disputes and Informal Discovery Conferences
Moving parties can schedule an Informal Discovery Conference by e filing LACIV 094.
Moving parties can schedule an Informal Discovery Conference by e filing LACIV 094.
Page 5 | Discovery Disputes and Informal Discovery Conferences
Filing Timing and Cure Windows
Litigants in Propria Persona are permitted to file Ex Partes in-person by 8:30 a.m. the day the Ex Parte is to be heard.
Litigants in Propria Persona are permitted to file Ex Partes in-person by 8:30 a.m. the day the Ex Parte is to be heard.
Page 1 | Ex Parte Information - Litigants in Propria Persona
Ex parte applications must be e-filed by 10:00 a.m. on the day before the hearing.
Parties are to e-file the Ex Parte the day prior before 10:00 a.m.
Page 1 | Ex Parte Information
Ex parte applications must be e-filed by 10:00 a.m. the day prior to the hearing.
Parties are to e-file the Ex Parte the day prior before 10:00 a.m.
Page 1 | Ex Parte Information
Case Management Statements must be filed using Judicial Council Form CM-110 no later than 15 calendar days before the Case Management Conference.
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.
Page 1 | Case Management Conferences
If any defendant remains unserved, plaintiff must submit a declaration at least 7 days before the hearing explaining why service has not been completed.
If any Defendants have not been served, Plaintiff or Plaintiff's Counsel must submit a declaration to the Court seven (7) days prior to the hearing explaining why service has not been completed
Page 1 | Case Management Conferences
A Case Management Statement must be filed no later than 15 calendar days before the Case Management Conference.
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.
Page 1 | Case Management Conferences
Trial documents must be provided to the court no later than 5 court days before the Final Status Conference.
The parties are to provide the Court with the below indicated Trial Documents no later than 5 Court Days prior to the Final Status Conference.
Page 2 | Final Status Conference
Trial documents must be provided to the court no later than 5 court days prior to the Final Status Conference.
The parties are to provide the Court with the below indicated Trial Documents no later than 5 Court Days prior to the Final Status Conference.
Page 2 | Final Status Conference
A joint statement on the discovery dispute must be filed at least five court days before the Informal Discovery Conference.
At least five (5) court days before the Informal Discovery Conference, the parties and counsel shall file a joint statement that succinctly summarizes the nature of the dispute, the necessity for the discovery, the basis for any objection or withholding of information, and the overall status of discovery.
Page 5 | Discovery Disputes and Informal Discovery Conferences
A joint discovery dispute statement must be filed at least 5 court days before the Informal Discovery Conference.
At least five (5) court days before the Informal Discovery Conference, the parties and counsel shall file a joint statement that succinctly summarizes the nature of the dispute, the necessity for the discovery, the basis for any objection or withholding of information, and the overall status of discovery.
Page 5 | Discovery Disputes and Informal Discovery Conferences
Proposed protective orders must be served and filed within 5 days of the 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
Page 6 | Discovery
A proposed protective order must be served and filed within 5 days of the 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 7
Plaintiffs must file a declaration explaining failure to serve defendants 7 days prior to the Case Management Conference.
If any Defendants have not been served, Plaintiff or Plaintiff’s Counsel must submit a declaration to the Court seven (7) days prior to the hearing explaining why service has not been completed, documenting the be completed. (Cal. Rules of Court, rule 3.110.)
Page 1 | Case Management Conferences
Service and Proof of Service Rules
Attorneys must give proper 24 hours' notice before an ex parte hearing.
Ensure to give proper 24 hours' notice.
Page 1 | Ex Parte Information
Pro se litigants must give the opposition 24 hours' notice before an ex parte hearing.
Litigants in Propria Persona are required to give the opposition 24 hours' notice.
Page 1 | Ex Parte Information - Litigants in Propria Persona
All defendants must be served with the complaint by the time of the Case Management Conference.
All defendants must be served with the complaint by the Case Management Conference.
Page 1 | Case Management Conferences
Pro se litigants must give opposing parties 24 hours' notice for ex parte applications.
Litigants in Propria Persona are required to give the opposition 24 hours’ notice.
Page 1 | Ex Parte Information
Proper 24 hours' notice must be given to opposing parties for ex parte applications.
Ensure to give proper 24 hours’ notice.
Page 1 | Ex Parte Information
Please also submit the Verdict Form to the clerk via email (POMDeptEAO@LACourt.org) in MS Word format.
Please also submit the Verdict Form to the clerk via email (POMDeptEAO@LACourt.org) in MS Word format.
Page 2 | Tab G – Joint Verdict Forms
Verification must be served with all produced discovery documents.
Plaintiff and defendant shall serve verification with the documents they produce.
Page 6 | Discovery
Both plaintiff and defendant must serve verification along with the documents they produce.
Plaintiff and defendant shall serve verification with the documents they produce.
Page 7
Discovery documents may be provided to opposing parties in PDF electronic format at the producing party's option.
The information may be provided to the opposing party in electronic form as a PDF at the option of the producing party.
Page 6 | Discovery
Courtesy Copy Requirements
Counsel shall submit a Joint Deposition Designation List beginning with the number 1 and provide three copies of the Deposition Designation List with columns for the Clerk and the Court to use to indicate whether the Deposition Designation is admitted or not.
Counsel shall submit a Joint Deposition Designation List beginning with the number 1 and provide three copies of the Deposition Designation List with columns for the Clerk and the Court to use to indicate whether the Deposition Designation is admitted or not.
Page 3 | Tab I – Deposition Designations
On the day of trial counsel must provide a total of four tabbed joint exhibit binders for the Court, Judicial Assistant, witness stand, and opposing counsel.
On the day of trial, Counsel are to provide TABBED Joint Exhibit Binder set for the Court, Judicial Assistant, the witness stand, and opposing Counsel for a total of four (4) binders.
Page 3 | Tab H – Joint Exhibit List
Four tabbed joint exhibit binders must be delivered to the Court, Judicial Assistant, witness stand, and opposing counsel on the day of trial.
On the day of trial, Counsel are to provide TABBED Joint Exhibit Binder set for the Court, Judicial Assistant, the witness stand, and opposing Counsel for a total of four (4) binders.
Page 3 | Tab H – Joint Exhibit List
Please deliver a courtesy copy of the succinct joint statement.
Please deliver a courtesy copy of the succinct joint statement.
Page 5 | Discovery Disputes and Informal Discovery Conferences
Please deliver a courtesy copy of the succinct joint statement.
Please deliver a courtesy copy of the succinct joint statement.
Page 5 | Discovery Disputes and Informal Discovery Conferences
Sealing & Redaction Procedures
Defendant's list of other customers' repair visits must include the VIN, repair date, location, and complaint text but must exclude all other customers' personal identifying information.
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.
Page 7
A party believing produced information needs protection must serve and file a proposed protective order within 5 days of the order and meet and confer, with the default being the standard LASC Protective 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. The default will be the standard Protective Order provided by the LASC on its website.
Page 7
Filing Bundling Requirements
Ten or more exhibits must be placed in 3-ring binders; tabbed joint exhibit binders must be provided to four parties on the day of trial.
If ten (10) or more exhibits are to be used, copies of the exhibits shall be placed in one or more 3-ring binders. On the day of trial, Counsel are to provide TABBED Joint Exhibit Binder set for the Court, Judicial Assistant, the witness stand, and opposing Counsel for a total of four (4) binders.
Page 3 | Tab H – Joint Exhibit List
In the trial binder, motions in limine must be arranged in numerical order (plaintiff's first, then defense's), with replies and oppositions placed directly behind the corresponding motion.
Motions in Limine are to be placed in numerical order starting with Plaintiff's Motions in Limine then Defense Motions in Limine. All replies and opposition are to be placed directly behind the Motion in Limine in question.
Page 2 | Guidelines for Trial - Tab B Motions in Limine
Pre-Motion Conference Requirements
Parties and counsel are ordered to meet and confer in good faith to informally resolve discovery disputes before involving the Court.
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.
Page 5 | Discovery Disputes and Informal Discovery Conferences
If the Parties are unable to settle their discovery disputes, pursuant to Code of Civil Procedure section 128(a)(3), the Court requests that they schedule an Informal Discovery Conference (“IDC”) prior to filing a discovery motion.
If the Parties are unable to settle their discovery disputes, pursuant to Code of Civil Procedure section 128(a)(3), the Court requests that they schedule an Informal Discovery Conference (“IDC”) prior to filing a discovery motion.
Page 5 | Discovery Disputes and Informal Discovery Conferences
Adjournment & Extension Requirements
Trials will be conducted five (5) days per week unless otherwise ordered. Court will convene promptly at the times previously set. Counsel should advise the Court well in advance if special circumstances require an adjustment to this schedule.
Trials will be conducted five (5) days per week unless otherwise ordered. Court will convene promptly at the times previously set. Counsel should advise the Court well in advance if special circumstances require an adjustment to this schedule.
Page 4 | Trial (LASC Rule 3.37, et seq.)
Chambers Communication Rules
Please also submit the Verdict Form to the clerk via email (POMDeptEAO@LACourt.org) in MS Word format.
Please also submit the Verdict Form to the clerk via email (POMDeptEAO@LACourt.org) in MS Word format.
Page 3 | Tab G – Joint Verdict Forms
Courtroom Telephone Number: (909) 802-1126
Courtroom Telephone Number: (909) 802-1126
Page 1 | Department O Courtroom Information
The clerk can be contacted via email at POMDeptEAO@LACourt.org for verdict form submissions.
Please also submit the Verdict Form to the clerk via email (POMDeptEAO@LACourt.org) in MS Word format.
Page 2 | Tab G – Joint Verdict Forms