Judge Colin Leis
Individual Rules, Standing Orders & Policies
- Rules last changed:
Communication
Chambers
Document Format Requirements10 rules
Transcript pages for deposition/trial designation must be submitted with numbered tabs separating each transcript and each designation highlighted using a distinct color per party.
Court's wording
The parties shall submit copies of the pages of the transcripts of the deposition or former testimony they are designating or counter-designating with numbered tabs separating each deposition or trial transcript. Each designation or counter-designation shall be highlighted, with each party using a different color highlighter.
Copies of documentary exhibits shall be one-sided copies.
Formatting
- •One-sided copies of documentary exhibits
Parties must jointly prepare four sets of tabbed, internally paginated, properly-marked exhibits organized numerically in three-ring binders.
- Binding
- Tabbed three-ring binder
Formatting
- •Internally paginated by document
- •Properly-marked exhibits
- •Organized numerically
Court's wording
The parties' counsel and any self-represented parties shall work together to jointly prepare four sets of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) ("Exhibit Binders").
The Trial Binder must consist of one-sided, conformed copies, tabbed and organized in a three-ring binder.
- Binding
- Tabbed three-ring binder
Formatting
- •One-sided, conformed copies
Court's wording
No later than five court days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department 74 a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents
On LACIV 094 briefly describe the nature of the discovery dispute in font no smaller than 12-point, double or one-and-a-half spaced in the area provided on the form. No attachments are allowed.
- Font size
- At least 12 points
- LACIV 094 form
Formatting
- •Double or one-and-a-half line spacing
- •No attachments allowed
Parties must jointly prepare four tabbed, internally paginated, numerically organized exhibit sets in three-ring binders, with one-sided copies for documentary exhibits.
- Binding
- Three-ring binder
Formatting
- •Tabbed
- •Internally paginated by document
- •Properly-marked
- •Organized numerically
- •Four sets
- •One-sided copies for documentary exhibits
Court's wording
The parties' counsel and any self-represented parties shall work together to jointly prepare four sets of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) ("Exhibit Binders"). Copies of documentary exhibits shall be one-sided copies.
The Motions in Limine Binder must contain one-sided conformed copies of all motion papers, arranged in tabbed three-ring binders with colored separators.
- Binding
- Three-ring binder
Formatting
- •One-sided
- •Conformed copies
- •Tabbed in numerical order
- •Colored separator sheets
Court's wording
The Motions in Limine Binder shall include one-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders, tabbed in numerical order with the opposition papers and reply papers for each motion placed directly behind the moving papers with a colored sheet of paper separating the moving, opposition, and reply papers.
consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents
- Binding
- Three-ring binder
Formatting
- •One-sided
- •Conformed copies
- •Tabbed
- •Table of contents
a proposed sealing order that is MS-Word editable at least 15 days before the hearing on the motion to seal
- Proposed sealing order
Formatting
- •MS-Word editable
Exhibit binders are not needed until the first day of trial.
Document Filing Requirements30 rules
Proposed sealing orders must state non-conclusory, express facts supporting sealing, separately identify each proposed redaction by document name, page, and line number, and include a 'Granted'/'Denied' ruling space for the court.
Court's wording
The proposed sealing order must state proposed non-conclusory, express facts supporting sealing. (CRC 2.550(d), (c)(1)(A).) "Non-conclusory" means findings more specific than merely repeating the wording of CRC 2.550, subdivisions (d)(1-5). Without repeating the language of each proposed redaction, the proposed sealing order must separately identify by document name, page, and line number each and every proposed redaction. For each proposed redaction, the proposed sealing order must, akin to a ruling sheet, contain immediately to the right a space for the court to mark "Granted" or "Denied" for each proposed redaction.
Each party shall file a trial brief succinctly identifying: (1) the claims and defenses that remain in dispute for trial; (2) the major legal issues (with supporting points and authorities); (3) the relief and calculation of damages sought; and (4) any other information that may assist the court at trial.
The parties' counsel and any self-represented parties shall work together to prepare and file a joint list of all witnesses whom any party intends to call at trial, excluding impeachment and rebuttal witnesses.
who is not included on the joint witness list is subject to being excluded from testifying at trial other than for purposes of giving actual impeachment or ===== PAGE 8 ===== rebuttal testimony. Any party who seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the court.
Parties must jointly prepare and file a joint exhibit list with specified columns for each exhibit offered at trial, including stipulations to authentication and admissibility, objections, and marking/admission dates.
Court's wording
The parties' counsel and any self-represented parties shall work together to prepare and file a joint exhibit list organized with columns (in the format set forth below) which state for each exhibit any party intends to offer at trial: (1) the exhibit number; (2) a brief description of the exhibit; (3) which party is offering the exhibit; (4) whether the parties have stipulated to authentication of the exhibit; (5) whether the parties have stipulated to admissibility of the exhibit; (6) any evidentiary objections to admission of the exhibit; (7) the date the exhibit was marked for identification; and, (8) the date the exhibit was admitted into evidence.
Designation columns in the joint chart must include witness number/name, date and type of testimony, page/line designations, objections, counter-designation status, and the court's ruling.
Court's wording
In the joint chart, each designating party's designations of deposition or former testimony shall include columns which state: (1) the designation number and name of the witness; (2) the date and type of testimony (e.g., deposition or trial testimony); (3) the page and line designations of the deposition or former testimony requested to be used; (4) any objections; (5) whether the other party has counter-designated any additional deposition or former testimony of the witness that relates to the designation, and, if so, the designation number of the counter-designation; and, (6) the court's ruling.
When deposition or former trial testimony will be used, counsel and self-represented parties must meet and confer and jointly file a deposition designation chart.
Court's wording
If any parties intend to use deposition testimony or former trial testimony in lieu of or in addition to a witness's live testimony, the parties' counsel and any self-represented parties shall meet and confer to discuss, and work together to prepare and file, a joint chart in the format set forth below
Counter-designation columns in the joint chart must include witness number/name, date and type of testimony, page/line counter-designations, objections, the related designation number, and the court's ruling.
Court's wording
In the joint chart, each counter-designating party's counter-designations of additional deposition or former testimony of the witness that relates to the designations shall include columns which state: (1) the designation number and name of the witness; (2) the date and type of testimony (e.g., deposition or trial testimony); (3) the page and line counter-designations of the deposition or former testimony requested to be used; (4) any objections; (5) the designation number of the other party's designation to which the counter-designation relates; and, (6) the court's ruling.
Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.
- Document
- Opposition reply
Must include
- •Caption
Motions in limine must comply with CCP §1005 notice provisions and include declarations meeting LR 3.57(a) requirements.
Court's wording
The parties' counsel and any self-represented parties shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and file declarations that comply with the requirements of Los Angeles County Court Rule 3.57, subdivision (a).
The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to exclude.
- Document
- Motion in limine
Must include
- •Caption
The parties' counsel and any self-represented parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the Exhibit Binders.
Parties filing more than one motion in limine shall number them consecutively.
The Trial Binder must include a table of contents with specified tabs: Trial Briefs, Joint Witness List, Joint Exhibit List, Deposition Designations chart, and Operative Pleadings.
- Document
- Trial binder
Include
- •Table of contents
Court's wording
a table of contents that includes the following: Tab A: Trial Briefs Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab E: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).
Each party must file a trial brief identifying remaining claims and defenses, major legal issues with authorities, relief and damages sought, and other information useful at trial.
Court's wording
Each party shall file a trial brief succinctly identifying: (1) the claims and defenses that remain in dispute for trial; (2) the major legal issues (with supporting points and authorities); (3) the relief and calculation of damages sought; and, (4) any other information that may assist the court at trial.
Joint witness list must be organized by specified columns (name, party calling, expected testimony, examination estimates) with a grand total, and any witness omitted from the list is subject to exclusion from trial testimony.
Court's wording
The joint witness list shall be organized with columns (in the format set forth below) which state: (1) the name of each witness (in alphabetical order), if the witness is being called to testify as an expert, and any special requirements or accommodations needed for the witness (e.g., interpreter); (2) the party calling the witness; (3) whether the witness is actually expected to testify; (4) a brief (e.g. approximately 8-12 words), non-conclusory description of the witness's expected testimony (e.g. "percipient" is too conclusory; instead, describe what the witness perceived); (5) an estimate of the length of direct examination (in hours); (6) an estimate of the length of cross-examination (in hours); and, (7) the total estimated length of examination (in hours). At the end of the joint witness list, the parties and any self-represented parties shall add up the estimated times for all witnesses' testimony and state the grand total in the last column. Any witness who is not included on the joint witness list is subject to being excluded from testifying at trial other than for purposes of giving actual impeachment or
Any party who seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the court.
Parties and self-represented litigants must prepare and file a joint exhibit list containing specified columns for each trial exhibit and must meet and confer to resolve authenticity and admissibility objections.
Court's wording
The parties' counsel and any self-represented parties shall work together to prepare and file a joint exhibit list organized with columns (in the format set forth below) which state for each exhibit any party intends to offer at trial: (1) the exhibit number; (2) a brief description of the exhibit; (3) which party is offering the exhibit; (4) whether the parties have stipulated to authentication of the exhibit; (5) whether the parties have stipulated to admissibility of the exhibit; (6) any evidentiary objections to admission of the exhibit; (7) the date the exhibit was marked for identification; and, (8) the date the exhibit was admitted into evidence. (Local Rule 3.25, subd. (g)(6).) As set forth above, the parties' counsel and any self-represented parties shall meet and confer to try to resolve objections to the authenticity and admissibility of each exhibit.
For jury trials, parties must prepare and file a brief joint written statement of the case for the court to read to the jury.
Court's wording
For jury trials, the parties' counsel and any self-represented parties shall work together to prepare and file a brief, joint written statement of the case for the court to read to the jury. (Local Rule 3.25, subd. (g)(4).)
For jury trials, parties must prepare a complete set of full-text proposed jury instructions, editing CACI instructions, inserting party names, and eliminating blanks and inapplicable material.
Court's wording
For jury trials, the parties' counsel and any self-represented parties shall work together to prepare a complete set of full-text proposed jury instructions, editing all proposed Judicial Council of California Civil Jury Instructions ("CACI") instructions, inserting party names, and eliminating blanks and other irrelevant or inapplicable material.
For jury trials, parties must prepare and file a joint list of proposed jury instructions stating number, title, requesting party, agreed/contested status, objections, and whether given by the court.
Court's wording
For jury trials, the parties' counsel and any self-represented parties shall work together to prepare and file a joint list of proposed jury instructions (in the format set forth below) which states for each proposed jury instruction: (1) the jury instruction number (listed in numerical order); (2) the title of the jury instruction; (3) the party requesting the jury instruction; (4) whether the jury instruction is agreed upon or contested; (5) a concise statement of any objection; and, (6) whether the jury instruction was given by the court ("Joint List of Proposed Jury Instructions").
Parties intending to use deposition or former trial testimony must meet and confer and jointly prepare and file a chart of page and line designations in the specified format.
Court's wording
If any parties intend to use deposition testimony or former trial testimony in lieu of or in addition to a witness's live testimony, the parties' counsel and any self-represented parties shall meet and confer to discuss, and work together to prepare and file, a joint chart in the format set forth below ("Joint Chart of Page and Line Designations for Deposition and Former Testimony").
For jury trials, parties must jointly file a proposed verdict form, or each party must separately file one if no agreement is reached, and the court expects use of the applicable CACI special verdict form.
Court's wording
For jury trials, the parties' counsel and any self-represented parties shall work together to prepare and file a joint proposed general verdict form or a joint proposed special verdict form acceptable to all parties. (Local Rule 3.25, subd. (g)(8).) If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form. When a special verdict form is requested, if there is an appropriate CACI special verdict form for a cause of action, affirmative defense, or other finding, the court expects the parties to use the CACI special verdict form.
Motions in limine shall be noticed for hearing at the Final Status Conference.
The Trial Binder must include a table of contents with Tabs A through I; for bench trials without a jury, only Tabs A, B, C, H, and I are required.
- Document
- Trial binder
Must include
- •Table of contents
Court's wording
a table of contents that includes the following (for bench trials without a jury, the Trial Binder shall only include the documents listed under Tabs A, B, C, H, and I): Tab A: Trial Briefs Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Statement to Be Read to the Jury Tab E: Joint List of Jury Instructions Tab F: Joint and Contested Jury Instructions Tab G: Joint or Contested Verdict Form(s) Tab H: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab I: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).
Proposed jury instructions behind Tab F must be organized into three labeled groups in a specified order.
Court's wording
The parties shall organize proposed jury instructions into groups behind Tab F in the following order (labeled by cover sheets): (1) the agreed-upon instructions; (2) plaintiff's requested instructions to which defendant objects; and, (3) defendant's requested instructions to which plaintiff objects.
To request an informal discovery conference, you must use Los Angeles Superior Court form LACIV 094, and reserve a hearing date on the Court Reservation System.
The proposed jury instructions shall be prepared on Los Angeles Superior Court form LASC LACIV 129 or in a Word document that is in the same format.
Parties must submit the designated or counter-designated transcript pages with numbered tabs separating each transcript, with each party's designations highlighted in a different color.
Court's wording
The parties shall submit copies of the pages of the transcripts of the deposition or former testimony they are designating or counter-designating with numbered tabs separating each deposition or trial transcript. Each designation or counter-designation shall be highlighted, with each party using a different color highlighter.
If there is an appropriate CACI jury instruction on a point of law, the court expects the parties to request the CACI instruction instead of a specially prepared jury instruction.
Filing & Service rules
Electronic Filing Rules
All filings must be electronically filed unless the filer is a self-represented litigant or otherwise exempted from mandatory electronic filing.
Under the rules of court and the court's general orders, all filings must be electronically filed unless the filer is a self-represented litigant or otherwise exempted from mandatory electronic filing.
Page 1 | 1. Motions
Ex parte applications and supporting documents must be electronically filed, with exceptions for self-represented litigants and other persons excused from electronic filing.
Please note that section 8 of the First Amended General Order governing Mandatory Electronic Filing for Civil, filed May 3, 2019, provides that, with the exception of self-represented litigants and other persons excused from filing documents electronically: a) Ex parte applications and all documents in support thereof must be electronically filed no later than 10:00 a.m. the day before the ex parte hearing.
Page 3 | 3. Ex Parte Applications
Filing Timing and Cure Windows
Written opposition to an ex parte application must be electronically filed by 8:30 a.m. the day of the ex parte hearing.
b) Any written opposition to an ex parte application must be electronically filed by 8:30 a.m. the day of the ex parte hearing.
Page 3 | 3. Ex Parte Applications
Ex parte applications and supporting documents must be electronically filed no later than 10:00 a.m. the day before the ex parte hearing.
a) Ex parte applications and all documents in support thereof must be electronically filed no later than 10:00 a.m. the day before the ex parte hearing.
Page 3 | 3. Ex Parte Applications
Parties must meet and confer no later than 11 calendar days before the Final Status Conference to prepare required trial documents and binders.
No later than 11 calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall meet and confer to do the following: (1) discuss and prepare the documents required in Sections 2.B-D, below, and the Motions in Limine Binder, Exhibit Binders,
Page 6 | 1. MEET AND CONFER
Parties must exchange all trial exhibits no later than 18 calendar days before the Final Status Conference.
No later than 18 calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall exchange all exhibits they intend to introduce at trial.
Page 6 | 1. MEET AND CONFER
Trial briefs, the joint witness list, and the joint exhibit list must be filed and served no later than five court days before the Final Status Conference.
No later than five court days before the Final Status Conference, the parties' counsel and any self-represented parties shall file and serve the following documents:
Page 7 | 2. TRIAL DOCUMENTS TO BE FILED
Motions in limine must be noticed for hearing at the Final Status Conference.
Motions in limine shall be noticed for hearing at the Final Status Conference.
Page 11 | MOTIONS IN LIMINE
The Motions in Limine Binder must be prepared and lodged in Department 735 at least five court days before the Final Status Conference.
No later than five court days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department 735 a Motions in Limine Binder.
Page 11 | MOTIONS IN LIMINE
The Trial Binder must be prepared and lodged in Department 735 at least five court days before the Final Status Conference.
No later than five court days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department 735 a Trial Binder,
Page 12 | TRIAL BINDER
Parties must meet and confer no later than 11 calendar days before the Final Status Conference to prepare trial documents, attempt stipulations on exhibits and motions in limine, and discuss settlement.
No later than 11 calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall meet and confer to do the following: (1) discuss and prepare the documents required in Sections 2.B-H, below, and the Motions in Limine Binder, Exhibit Binders, and Trial Binder required in Sections 3-5, below; (2) discuss and make a good faith effort to stipulate ===== PAGE 14 ===== to the authenticity and admissibility of each trial exhibit; (3) discuss and make a good faith effort to stipulate to resolve each motion in limine; (4) discuss and make a good faith effort to stipulate to ultimate facts and legal issues; and, (5) discuss and make a good faith effort to settle
Page 13 | 1. MEET AND CONFER
The Motions in Limine Binder must be lodged no later than five court days before the Final Status Conference.
No later than five court days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department 74 a Motions in Limine Binder.
Page 19 | MOTIONS IN LIMINE
The Trial Binder must be lodged no later than five court days before the Final Status Conference.
No later than five court days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department 74 a Trial Binder,
Page 20 | TRIAL BINDER
The moving party must lodge the red-lined documents subject to the proposed sealing order with Department 735 no later than three days after filing the motion to seal.
The moving party must also lodge with Department 735 no later than three days after filing the motion to seal the documents subject to the proposed sealing order in which the proposed redactions are red-lined.
Page 2 | 2. Motions to Seal
Courtesy Copy Requirements
Department 735 does not require courtesy copies for most filings, except for trial documents, motions in limine, and trial exhibits, unless the court orders otherwise.
Except for trial documents, motions in limine, and trial exhibits, Department 735 aims to be a paperless department. Thus, unless the court orders otherwise, the court does not need courtesy copies.
Page 1 | 1. Motions
Filing Bundling Requirements
Parties must deliver joint motion-in-limine binders and joint trial binders to Department 735 at least five court days before the final status conference.
Please pay particular attention to your mutual obligation to deliver to Department 735 your joint motion-in-limine binders and joint trial binders at least five court days before the final status conference.
Page 4 | 6. Trial Preparation Order
All motions in limine, opposition, and reply papers must be bundled together in a Motions in Limine Binder.
The Motions in Limine Binder shall include one-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders,
Page 11 | MOTIONS IN LIMINE
Parties must jointly prepare and lodge a Motions in Limine Binder in Department 74 no later than five court days before the Final Status Conference.
No later than five court days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department 74 a Motions in Limine Binder.
Page 19 | MOTIONS IN LIMINE
Parties must jointly prepare and lodge a Trial Binder in Department 74 no later than five court days before the Final Status Conference.
No later than five court days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department 74 a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents
Page 20 | TRIAL BINDER
Pre-Motion Conference Requirements
Parties must meet and confer in good faith before filing a discovery motion, and either party may request an informal discovery conference before filing if both agree.
The court expects the parties' counsel and any self-represented parties first to meet and confer to make a reasonable and good faith attempt to informally resolve each discovery issue in dispute. If the parties do not resolve their dispute by meeting and conferring but the parties mutually agree that an informal discovery conference might help, either party may request before filing a discovery motion that the court conduct an informal discovery conference to discuss the dispute.
Page 4 | 5. Discovery Disputes and Informal Discovery Conferences
Adjournment & Extension Requirements
The responding party is expected to grant the moving party a reasonable extension of time to file a discovery motion to allow scheduling of an informal discovery conference.
The court expects the responding party to grant the moving party a reasonable extension of time to file a motion concerning the discovery in dispute in order to enable the parties to schedule and conduct an informal discovery conference.
Page 4 | 5. Discovery Disputes and Informal Discovery Conferences
Chambers Communication Rules
Proposed sealing orders must be emailed to Department 735's email service account at least 15 days before the motion to seal hearing.
In conjunction with setting a hearing on a motion to seal, the moving party must file, serve, and email to Department 735's email service account (smcdept735@lacourt.org) a proposed sealing order that is MS-Word editable at least 15 days before the hearing on the motion to seal.
Page 2 | 2. Motions to Seal
After e-lodging a document that requires court action, parties should not call court staff about its status; they should follow the document's progress on the court's Website instead.
The court requests that, after the parties' counsel or any self-represented parties electronically lodge a document which requires action by the court (e.g., stipulation and proposed order, and proposed judgment), they please refrain from calling the court's staff to ask about the status of the document, and that they instead follow the document's progress on the court's Website (which the court updates as soon and as often as possible).
Page 5 | 7. Electronically Lodged Documents Which Require Action by the Court