Judge Daniel L. Alexander
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Exhibits, Exhibit Binder
- 3 copies • On First Day of Trial
Joint Discovery Report
- Within One Court Day of Electronic Filing
Joint Report
- Within One Court Day
Motion
- Within One Court Day of Electronic Filing
Document Format Requirements6 rules
Pursuant to Local Rules 3.52 and 3.53, exhibits must be pre-marked using Arabic numerals and in instances where exhibits consist of multiple pages, each page must be numbered sequentially.
Formatting
- •Pre-marked with Arabic numerals
- •Multi-page exhibits must have sequentially numbered pages
Tabbed, paginated exhibit binders are required for court, staff, witnesses, and opposing parties on first day of trial.
Formatting
- •Paginated
- •One set per opposing party
Court's wording
At least three sets of exhibit binders – tabbed and paginated – are required on the first day of trial: a set each for the Court, the judicial assistant, and the witness. Counsel must also supply an exhibit binder to each opposing party.
Motions in limine must be submitted in a tabbed binder with table of contents at least five calendar days before trial.
Court's wording
At least five calendar days before the first day of trial, counsel must provide a tabbed binder containing all motions in limine, oppositions, and replies in sequential order consistent with the number assigned to each motion in limine. The binder also must contain a table of contents identifying each motion in limine, opposition, and reply, and the corresponding tab for each.
Pursuant to Local Rules 3.52 and 3.53, exhibits must be pre-marked using Arabic numerals and in instances where exhibits consist of multiple pages, each page must be numbered sequentially.
The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Joint Statement of the Case Tab C: Joint Witness List Tab D: Joint List of Jury Instructions Tab E: Joint and Contested Jury Instructions
- Trial binder
Formatting
- •Tab A: Trial Briefs
- •Tab C: Joint Witness List
Joint trial binder for FSC must be organized with specified tabs A–I.
- Binding
- Tabbed binder
Court's wording
Counsel must provide a joint trial binder for the Court at the FSC. The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Joint Statement of the Case Tab C: Joint Witness List Tab D: Joint List of Jury Instructions Tab E: Joint and Contested Jury Instructions Tab G: Joint Exhibit List Tab H: Page and Line Designations for Deposition and Former Testimony Tab I: Stipulations
Document Filing Requirements23 rules
If all defendants have not been served, plaintiff or plaintiff's counsel must submit a declaration to the court five (5) days prior to the hearing explaining what efforts have been undertaken to accomplish service. Cal. Rules of Court, rule 3.110.
Declaration of service efforts required 5 days before CMC if defendants not served.
Court's wording
If all defendants have not been served, plaintiff or plaintiff’s counsel must submit a declaration to the court five (5) days prior to the hearing explaining what efforts have been undertaken to accomplish service.
Ex parte applications must include a declaration with personal knowledge testimony of irreparable harm or exigent circumstances.
Court's wording
An applicant must make an affirmative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte.
Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in court.
- Document
- Ex parte application
Must include
- •Proposed order
At least five court days before the IDC, the parties shall file a joint report that succinctly sets forth the nature of the dispute, the necessity for the discovery, the justification for its non-production, and the overall status of discovery.
Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in court.
- Document
- Ex parte application
Must include
- •Proposed order
A motion to compel further responses must be accompanied by a four-column joint statement identifying the request number, the request text, the response text, and each party's bullet-point arguments.
Court's wording
In the event a motion to compel further responses is filed, the parties are required to submit a JOINT STATEMENT consisting of a four-column document set up as follows: The first column will identify the number of the discovery request; the second, the text of the discovery request; the third, the text of the response; and the fourth, brief bullet-point statements, one from each party, as to why a further response should or should not be compelled.
Ex parte applications are reserved for exigent circumstances and must include a declaration making an affirmative factual showing of irreparable harm, immediate danger, or another statutory basis for ex parte relief.
Court's wording
Ex parte applications are reserved for exigent circumstances. The applicant shall comply with Cal. Rules of Court, rule 3.1202(c): "An applicant must make an affirmative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte."
Motions to compel further responses require a four-column joint statement with specified content.
Court's wording
In the event a motion to compel further responses is filed, the parties are required to submit a JOINT STATEMENT consisting of a four-column document set up as follows: The first column will identify the number of the discovery request; the second, the text of the discovery request; the third, the text of the response; and the fourth, brief bullet-point statements, one from each party, as to why a further response should or should not be compelled.
The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to admit or exclude.
- Document
- Motion in limine
- Placement
- Caption
Joint Statement – For jury trials, the parties shall prepare a joint written statement of the case for the Court to read to the jury. The parties/counsel shall sign the joint statement.
The parties are required to file the documents set forth in Local Rule 3.25(f) and (g) in advance of the FSC and should be familiar with Local Rules 3.48 through 3.58.
Parties filing opposition and reply briefs shall identify the corresponding motion number in the caption of their pages.
- Document
- Opposition and reply brief
- Placement
- Caption
Trial Briefs – Each party shall file a trial brief succinctly identifying: (1) the claims and defenses subject to litigation, (2) the major legal issues (with supporting points and authorities), (3) the relief claimed and the calculation of damages sought, and (4) any other information that may assist the Court at trial.
- Document
- Trial brief
Must include
- •Legal argument
Parties must file a signed joint witness list (excluding impeachment and rebuttal witnesses) identifying each witness by name, designating experts, estimating direct/cross/re-direct examination times with total testimony hours, and noting scheduling issues and special requirements.
Court's wording
Joint Witness List – The parties shall work together and file a joint list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. The joint witness list shall identify each witness by name, specify which witnesses are experts, estimate the length of direct examination, cross-examination, and re-direct examination of each, and include a total of the number of hours for all witness testimony. The parties shall identify all potential witness scheduling issues and special requirements. The parties/counsel shall sign the joint witness list.
Parties filing more than one motion in limine shall number the motions consecutively.
Joint Verdict Forms – The parties shall prepare and file a joint proposed general verdict form or special verdict form (with interrogatories). If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.
If deposition or former trial testimony will be used in lieu of live testimony, the parties must meet and confer and file a signed chart listing page/line designations, objections, counter-designations, responses, and the Court's rulings.
Court's wording
Page and Line Designations for Deposition and Former Testimony – If the parties intend to use deposition testimony or former trial testimony in lieu of any witness's live testimony, the parties shall meet-and-confer and jointly prepare and file a chart with columns for each of the following: (1) the page and line designations of the deposition or former testimony requested for use, (2) objections, (3) counter-designations, (4) any responses thereto, and (5) the Court's rulings. The objecting party shall specify all objections in the respective column. The parties/counsel shall sign the designations.
Parties must meet and confer, then file a signed joint exhibit list with columns for the exhibit, offering party, stipulations or objections to authenticity/admissibility, identification date, and admission date.
- Document
- Joint exhibit list
Must include
- •Exhibit list
Court's wording
Joint Exhibit List – The parties shall prepare and file a joint exhibit list organized with columns identifying: (1) the exhibit, (2) which party is offering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) the date on which the exhibit was identified, and (5) the date on which the exhibit was admitted. Prior to filing the joint exhibit list, the parties shall meet-and-confer to determine whether they will stipulate to the authenticity and/or admissibility of each exhibit or whether there are objections to any exhibit. If there are stipulations, the parties shall note that in the respective column. If not, the objecting party shall specify all objections in the respective column. The parties/counsel shall sign the joint exhibit list.
Parties must file a signed joint list of proposed jury instructions in numerical order identifying agreed and contested instructions, with a space by each instruction for the Court to indicate whether it was given.
Court's wording
and file a list of proposed jury instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any. The list of proposed jury instructions must include a space by each instruction for the Court to indicate whether the instruction was given. The parties/counsel shall sign the joint list of proposed jury instructions.
Jury Instructions (Joint and Contested) – The parties shall prepare a complete set of full-text proposed jury instructions. The parties shall prepare special instructions in a format ready for submission to the jury with the instruction number, title, and text only.
When filing motions in limine, the parties must comply with Local Rule 3.57, including the required declaration, if applicable.
The binder also must contain a table of contents identifying each motion in limine, opposition, and reply, and the corresponding tab for each.
- Document
- Motion in limine binder
Must include
- •Table of contents
Filing & Service rules
Filing Timing and Cure Windows
IDC joint report must be filed at least five court days before the informal discovery conference.
At least five court days before the IDC, the parties shall file a joint report that succinctly sets forth the nature of the dispute, the necessity for the discovery, the justification for its non-production, and the overall status of discovery.
Civil cases
Page 2 | Informal Discovery Conferences
Trial readiness documents must be served and filed at least five calendar days before the Final Status Conference.
At least five (5) calendar days prior to the FSC, the parties/counsel shall serve and file the following trial readiness documents:
Civil cases
Page 3 | 1. Final Status Conference ("FSC") and Pretrial Filings
Exhibits must be exchanged at least five calendar days before the FSC and lodged with the Court on the first day of trial.
The exhibits must be exchanged at least five calendar days before the FSC and lodged with the Court on the first day of trial.
Civil cases
Page 5 | F. TRIAL PROCEDURES - 4. Exhibits
Motions in limine must comply with the statutory notice requirements of Code of Civil Procedure sections 1005(b) and 1013.
Motions in limine are governed by the statutory notice requirements set forth in Code of Civil Procedure sections 1005(b) and 1013.
Civil cases
Page 5 | F. TRIAL PROCEDURES - 3. Motions in Limine
Counsel must provide a tabbed binder containing all motions in limine, oppositions, and replies in sequential order at least five calendar days before the first day of trial.
At least five calendar days before the first day of trial, counsel must provide a tabbed binder containing all motions in limine, oppositions, and replies in sequential order consistent with the number assigned to each motion in limine.
Civil cases
Page 5 | F. TRIAL PROCEDURES - 3. Motions in Limine
Motions in limine will be heard on the first day of trial (normally a Friday).
Motions in limine will be heard on the first day of trial (normally a Friday).
Civil cases
Page 5 | F. TRIAL PROCEDURES - 3. Motions in Limine
Trial readiness documents must be served and filed at least five calendar days before the Final Status Conference.
At least five (5) calendar days prior to the FSC, the parties/counsel shall serve and file the following trial readiness documents: a. Trial Briefs – ... b. Motions in Limine – ... c. Joint Statement – ... d. Joint Witness List – ... e. Joint List of Jury Instructions – ... f. Jury Instructions (Joint and Contested) – ... g. Joint Verdict Forms – ... h. Joint Exhibit List – ... i. Page and Line Designations for Deposition and Former Testimony – ... j. Stipulations Concerning Ultimate Facts and Issues – ...
Civil cases
Page 3 | Trial Procedures
Service and Proof of Service Rules
All defendants must be served with the complaint by the case management conference.
All defendants must be served with the complaint by the case management conference.
Civil cases
Page 1 | Case Management Conferences
All defendants must be served with the complaint no later than the case management conference.
All defendants must be served with the complaint by the case management conference.
Civil cases
Page 1 | B. CASE MANAGEMENT CONFERENCES
Service deadlines are extended based on the method of service per Code of Civil Procedure § 1013.
All deadlines for service are extended based on the manner of service as set forth in Code of Civil Procedure § 1013.
Civil cases
Page 3 | Trial Procedures
Pre-trial filing and service deadlines apply unless otherwise ordered, and all service deadlines are extended based on the manner of service under Code of Civil Procedure § 1013.
Unless otherwise ordered, the following pre-trial filing and service deadlines apply. All deadlines for service are extended based on the manner of service as set forth in Code of Civil Procedure § 1013.
Civil cases
Page 3 | F. TRIAL PROCEDURES
Filing Fees and Waivers
Ex parte application filing fee must be paid before appearing in court.
pay the filing fee before appearing in court.
Civil cases
Page 2 | Ex Parte Applications
Motion filing fees must be paid when reserving a hearing date online via CRS.
Motion fee payments are required at the time reservations are made online.
Civil cases
Page 2 | Law and Motion Hearings
Motion filing fees must be paid at the time the hearing date is reserved online through CRS.
Motion fee payments are required at the time reservations are made online.
Civil cases
Page 2 | LAW AND MOTION
Ex parte applicants must pay the filing fee before appearing in court.
Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in court.
Civil cases
Page 2 | E. EX PARTE APPLICATIONS
Courtesy Copy Requirements
Courtesy copies of all electronically filed motion-related documents must be delivered to Department A15 within one court day of filing.
Courtesy copies of all motion-related documents filed electronically must be delivered to Department A15 within one (1) court day of the electronic filing.
Civil cases
Page 2 | Law and Motion Hearings
Courtesy copies of all electronically filed motion-related documents must be delivered to Department A15 within one court day of electronic filing.
Courtesy copies of all motion-related documents filed electronically must be delivered to Department A15 within one (1) court day of the electronic filing.
Civil cases
Page 2 | LAW AND MOTION
A courtesy copy of the report shall be delivered to the courtroom within one court day of the electronic filing.
A courtesy copy of the report shall be delivered to the courtroom within one court day of the electronic filing.
Civil cases
Page 2 | Informal Discovery Conferences
A courtesy copy of the report shall be delivered to the courtroom within one court day of the electronic filing.
A courtesy copy of the report shall be delivered to the courtroom within one court day of the electronic filing.
Civil cases
Page 2 | D. INFORMAL DISCOVERY CONFERENCES
Counsel must provide the Court a joint, tabbed trial binder at the Final Status Conference containing the trial briefs, joint statement of the case, joint witness list, joint list of jury instructions, and joint and contested jury instructions.
Counsel must provide a joint trial binder for the Court at the FSC. The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Joint Statement of the Case Tab C: Joint Witness List Tab D: Joint List of Jury Instructions Tab E: Joint and Contested Jury Instructions
Civil cases
Page 4 | 2. Trial Binders
Three tabbed and paginated exhibit binder sets (for the Court, judicial assistant, and witness) plus one for each opposing party are required on the first day of trial.
At least three sets of exhibit binders – tabbed and paginated – are required on the first day of trial: a set each for the Court, the judicial assistant, and the witness. Counsel must also supply an exhibit binder to each opposing party.
Civil cases
Page 5 | F. TRIAL PROCEDURES - 4. Exhibits
Pre-Motion Conference Requirements
Before filing a motion to compel discovery, the parties must meet-and-confer in good faith in person, by telephone, or by videoconference.
In the event a party seeks to file a motion to compel discovery at any time during the pendency of this action, the parties are required to meet-and-confer in good faith in person, by telephone, or by videoconference.
Civil cases
Page 2 | D. INFORMAL DISCOVERY CONFERENCES
Moving parties must reserve a hearing date through the online Court Reservation System (CRS) before filing any motion, except motions in limine which are heard on the first day of trial.
Moving parties must secure a hearing date via the online Court Reservation System (CRS) on the Los Angeles Superior Court website. Please see the "Online Services" section at www.lacourt.org to find the civil Court Reservation System to reserve a hearing date before filing any motion, except for motions in limine, which are heard on the first day of trial (normally a Friday with jury selection to begin the following Monday).
Civil cases
Page 2 | LAW AND MOTION
Hearing dates must be reserved via the online CRS before filing any motion except motions in limine.
Moving parties must secure a hearing date via the online Court Reservation System (CRS) on the Los Angeles Superior Court website. Please see the “Online Services” section at www.lacourt.org to find the civil Court Reservation System to reserve a hearing date before filing any motion, except for motions in limine, which are heard on the first day of trial (normally a Friday with jury selection to begin the following Monday).
Civil cases
Page 2 | Law and Motion Hearings
If the meet-and-confer does not resolve the discovery dispute, the parties are encouraged (but not required) to schedule an Informal Discovery Conference before filing a motion to compel.
If the parties cannot resolve the issue, they are encouraged to schedule an IDC before filing any motion to compel.
Civil cases
Page 2 | D. INFORMAL DISCOVERY CONFERENCES
Adjournment & Extension Requirements
When filing an ex parte application to advance a summary judgment/adjudication hearing because no hearing dates are available before trial, the moving party should also consider requesting that the trial be continued to a date after the hearing.
summary judgment or summary adjudication, if a party files an ex parte application to advance the hearing on such a motion because no hearing dates are available on the Court Reservation System before the trial date, the moving party should also consider including an alternative request that the Court continue the trial to a date after the hearing on the motion.
Civil cases
Page 3 | LAW AND MOTION
Chambers Communication Rules
If parties/counsel are going to be late for a hearing, please contact the court staff.
If parties/counsel are going to be late for a hearing, please contact the court staff.
Civil cases
Page 1 | A. GENERAL
For all other inquiries, please contact the court staff between 10:00 a.m. and 12:00 p.m. or between 2:00 p.m. and 5:00 p.m.
For all other inquiries, please contact the court staff between 10:00 a.m. and 12:00 p.m. or between 2:00 p.m. and 5:00 p.m.
Civil cases
Page 1 | A. GENERAL
If parties/counsel are going to be late for a hearing, please contact the court staff. For all other inquiries, please contact the court staff between 10:00 a.m. and 12:00 p.m. or between 2:00 p.m. and 5:00 p.m.
If parties/counsel are going to be late for a hearing, please contact the court staff. For all other inquiries, please contact the court staff between 10:00 a.m. and 12:00 p.m. or between 2:00 p.m. and 5:00 p.m.
Civil cases
Page 1 | General
IDCs are scheduled by contacting the clerk in Department A15 for availability.
To schedule an IDC, contact the clerk in Department A15 for availability.
Civil cases
Page 2 | D. INFORMAL DISCOVERY CONFERENCES