Judge Daniel M. Crowley
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Courtesy Copies
Courtesy copies
- Destroyed After Hearing
Opposition to Ex Parte Application, Motion for Summary Judgment, Opposition to Motion for Summary Judgment, Reply to Opposition to Motion for Summary Judgment
Communication
Phone
Chambers
Document Format Requirements8 rules
All electronically filed documents must be text searchable and bookmarked, per the General Order re Mandatory Electronic Filing in Civil.
Formatting
- •Text-searchable
- •Bookmarked
Court's wording
All electronically filed documents must be text searchable and bookmarked. (See operative General Order re Mandatory Electronic Filing in Civil, (http: lacourt.ca.gov/division/civil/pdf/GeneralOrderreMandatoryElectronicFilingforCivil.pdf.)
declarations and/or exhibits must be tabbed. (Cal. Rules of Court, rule 3.1110(f).)
Parties filing more than one motion in limine shall number them consecutively.
The parties shall jointly prepare and lodge 2 days prior to the Final Status Conference 3-ring binders containing one set of the conformed copies of all the following:
- Binding
- Three-ring binder
- Trial binder
Formatting
- •Binders must be jointly prepared by the parties
- •Binders must be lodged 2 days prior to the Final Status Conference
Parties must jointly lodge tabbed, properly marked, internally paginated exhibit binders for inspection at the FSC and must mark all non-documentary exhibits with a written description behind the corresponding numerical tab.
- Binding
- Tabbed three-ring binder
- Exhibit binder
Court's wording
The parties shall jointly prepare and lodge for inspection at the FSC 3-ring binders containing tabbed, properly marked exhibits, internally paginated, (At trial, the parties will need additional copies of the exhibits for the Court's clerk, for use on the witness stand, and for each counsel.) The parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the exhibit binder.
The parties should submit three ring binders containing any motions in limine. The parties shall organize motions in limine (tabbed in numerical order) with the opposition papers and reply papers for each motion placed directly behind the moving papers. Sheets of colored paper should be used to separate moving papers from oppositions and oppositions from replies.
- Binding
- Tabbed three-ring binder
- Motion in limine
Formatting
- •Motions in limine must be tabbed in numerical order
Discovery requests and responses should not be marked as exhibits.
The parties may prepare special instructions in a format ready for submission to the jury with the instruction number, title, and text only (i.e., there should be no boxes or other indication on the printed instruction itself as to which party is requesting the instruction).
- Jury instructions
Formatting
- •Special instructions must include the instruction number, title, and text only
Document Filing Requirements21 rules
After reserving a motion hearing date, the reservation requestor must submit the moving papers for filing with the reservation receipt number printed on the face page of the document under the caption and attach the reservation receipt as the last page.
All deposition excerpts referenced in briefs must be marked on the transcripts attached as exhibits. (Cal. Rules of Court, rule 3.1116(c).)
The Court will only grant ex parte relief upon a showing, by admissible evidence, that the moving party will suffer “irreparable harm,” “immediate danger,” or where the moving party
The parties shall identify all potential witness scheduling issues and special requirements.
The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to preclude.
- Document
- Motion in limine
- Placement
- Caption
Parties must file a joint witness list, alphabetized by last name and excluding impeachment and rebuttal witnesses, that identifies each witness by name, expert status, estimated examination times, and total testimony hours.
Court's wording
The parties shall prepare and file a joint, alphabetized by last name, list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. (Super. Ct., L.A. County, Local Rules, rule 3.25(g)(5).) The joint witness list shall identify each witness by name, specify which witnesses are non-experts and experts, estimate the length of the direct, cross examination and re-direct examination of each witness, and include a total of the number of hours for all witness testimony.
For jury trials, the parties shall prepare and file a joint written statement of the case for the trial court to read to the jury. (Super. Ct. L.A. County, Local Rules, rule 3.25(g)(4).)
Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.
- Document
- Opposition and reply papers
- Placement
- Caption
The parties shall prepare a complete set of full text proposed jury instructions in a format ready for submission to the jury, by editing all proposed California Civil Jury Instructions including inserting party name(s) and eliminating blanks, brackets, and irrelevant material.
The parties shall prepare and file a joint exhibit list organized with columns 1) identifying each exhibit, 2) specifying evidentiary objections, if any, to the admission of the exhibit (if an objection to an exhibit is not articulated on the exhibit list, the trial court may deem the exhibit admitted) 3) a blank column for the Court to enter the date the exhibit was first identified, and 4) a blank column for the Court to enter the date the exhibit was admitted.
The parties shall separate the instructions into groups of agreed-upon versus not-agreed-upon instructions.
those contested), organized in numerical order, including columns to indicate whether an instruction is agreed to or contested. In addition, the List of Proposed Jury Instructions must include columns for a trial judge to indicate whether an instruction was given, given as modified, refused, or withdrawn. (See Cal. Rules of Court, rule 2.1055.)
Parties must jointly file a proposed general or special verdict form acceptable to all sides, or, if they cannot agree, each party must separately file a proposed verdict form.
Court's wording
The parties shall prepare and jointly file a proposed general verdict form or special verdict form (with interrogatories) acceptable to all sides. (Super. Ct. L.A. County, Local Rules, rule 3.25(g)(8).) If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.
Tab A: Trial Briefs (Optional) Tab B: Joint Statement to Be Read to the Jury Tab C: Joint Witness List (in the format prescribed at § 8(B)(b)) Tab D: Joint Exhibit List (in the format prescribed at § 8(B)(h)) Tab E: Joint List of Jury Instructions (identifying the agreed upon and contested instructions) Tab F: Joint and Contested Jury Instructions. The parties shall organize proposed jury instructions behind Tab F, with the agreed upon instructions first in order followed by the contested instructions (including special instructions) submitted by each side. Tab G: Joint and/or Contested Verdict Form(s) Tab H: Joint Chart of Page and Line Designation(s) 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).
Parties intending to use deposition or former trial testimony must meet and confer and jointly file a chart containing columns for designations, objections, counter-designations, responses, and the Court's ruling.
Court's wording
If the parties intend to use deposition testimony or former trial testimony in lieu of any witness' 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 ruling.
If the parties do not have a court reporter, counsel will be required to provide the court with a joint summary of the testimony and evidence admitted on a daily basis by the morning following the testimony.
Case Management Conference Statements (preferably joint) must describe the nature of the case, when discovery will be completed, and any agreements the parties have reached.
Court's wording
The parties must then file Case Management Conference Statements fifteen days prior to the Case Management Conference (preferably a joint statement), describing the nature of the case, when discovery will be completed ("per code" or "TBD" does not assist the Court in assigning a trial date for your case), and any agreements the parties have reached (see 19(b) of the Statement).
The Statements should identify the specific discovery request in dispute, the last iteration of a response, and a factual discussion by each side as to why the response is or is not sufficient.
The parties should also document their settlement agreement in a writing signed by all parties whether before or at the scheduled MSC.
At the conclusion of each court day, counsel must advise opposing counsel of the witnesses to be called the next day and the order in which they will testify. (LASCR 3.81.)
Each party may, but is not required to, file a trial brief succinctly identifying: (a) the claims and defenses subject to litigation; (b) the major legal issues (with supporting points and authorities);
- Document
- Trial brief
Include
- •Legal argument
Filing & Service rules
Electronic Filing Rules
All parties must electronically file documents, except self-represented litigants and parties or attorneys who have obtained an exemption from mandatory electronic filing, per the Los Angeles County Superior Court General Order Re Mandatory Electronic Filing for Civil.
Except for self-represented litigants, or parties or attorneys who have obtained an exemption from mandatory electronic filing, parties must electronically file documents. The requirements for electronic filing are detailed in the Superior Court, Los Angeles County's operative General Order Re Mandatory Electronic Filing for Civil, available online at http://www.lacourt.ca.gov/division/civil/pdf/GeneralOrderreMandatoryElectronicFilingforCivil.pdf
Civil cases
Page 1 | Filing of Documents
Filing Timing and Cure Windows
Case Management Conference Statements must be filed fifteen days before the Case Management Conference, and failure to comply with Cal. Rules of Court rules 3.724 and 3.725 may result in sanctions of up to $250 per violation.
The parties must then file Case Management Conference Statements fifteen days prior to the Case Management Conference (preferably a joint statement), describing the nature of the case, when discovery will be completed ("per code" or "TBD" does not assist the Court in assigning a trial date for your case), and any agreements the parties have reached (see 19(b) of the Statement). A failure to comply with Cal. Rules of Court, rules 3.724 and 3.725 may subject the offending counsel to sanctions of up to $250 per violation. (Cal. Rules of Court, rule 2.30.)
Civil cases
Page 2 | Case Management Conferences
Papers for a reserved matter must be filed within 3 days of making the reservation or the reservation will be cancelled.
Be mindful that papers for a reserved matter must be filed within 3 days of making the reservation, or else the reservation will be cancelled.
Civil cases
Page 4 | Law and Motion - A. Reservation Hearing Date
Trial Readiness Documents must be served and filed at least five calendar days before the Final Status Conference.
At least five calendar days prior to the Final Status Conference, the parties shall serve and file the following Trial Readiness Documents:
Civil cases
Page 6 | 10. Final Status Conference - B. Trial Documents to Be Filed
Before filing motions in limine, parties must comply with the notice provisions of Code of Civil Procedure section 1005 and Los Angeles Superior Court Local Rule 3.57(a).
Before filing motions in limine, the parties shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and the requirements of the Superior Court, Los Angeles County, Local Rules, rule 3.57(a).
Civil cases
Page 7 | Motions in Limine
Parties with a fee waiver may request a court reporter for a hearing by completing Los Angeles Superior Court Form FW-020 and filing it in the Clerk’s Office at least 10 days before the hearing (or as soon as possible). The clerk will notify the requesting party if a court reporter is available. This notification may occur on the day of your hearing or trial. If no court reporter is available that day, your hearing may be continued.
Parties with a fee waiver may request a court reporter for a hearing by completing Los Angeles Superior Court Form FW-020 and filing it in the Clerk’s Office at least 10 days before the hearing (or as soon as possible). The clerk will notify the requesting party if a court reporter is available. This notification may occur on the day of your hearing or trial. If no court reporter is available that day, your hearing may be continued.
Civil cases
Page 11 | B. Court Reporters
Scheduling an IDC does not extend the deadline to file a motion to compel further discovery responses unless the parties stipulate otherwise.
Note: Unless the parties so stipulate, scheduling an IDC does not extend the time to file a motion to compel further responses to discovery.
Civil cases
Page 5 | E. Motions to Compel Further Responses to Discovery
Joint IDC Statements must be e-filed at least 3 court days before the Informal Discovery Conference.
Joint IDC Statements should be e-filed 3 court days in advance of the conference.
Civil cases
Page 5 | E. Motions to Compel Further Responses to Discovery
Stipulations are to be filed prior to trial, to the extent feasible.
As noted above, to the extent feasible, stipulations are to be filed prior to trial.
Civil cases
Page 12 | E. Stipulations
Filed documents may take 1-2 business days to appear on the Court's docket.
Please be aware that it may take 1-2 business days for a filed document to appear on the Court's docket.
Civil cases
Page 1 | Filing of Documents
Service and Proof of Service Rules
Plaintiffs must serve the summons and complaint on defendants within 60 days of filing the complaint, or risk dismissal unless they show cause why dismissal should not be ordered.
Plaintiff(s) shall serve the summons and complaint upon Defendant(s) within 60 days of filing of the complaint. (California Rules of Court, rule 3.110 (b).) Failure to do so may result in including dismissal (Code Civ. Proc., §§ 583.410, 583.420), unless Plaintiff(s) shows cause why the court should not make such an order.
Civil cases
Page 1 | Service of Summons and Complaint
Filing Fees and Waivers
Jury fees must be paid no later than 365 calendar days after the initial complaint is filed.
Parties must pay jury fees no later than 365 calendar days after the filing of the initial complaint. (Code Civ. Proc., § 631, subd. (c)(2).)
Civil cases
Page 6 | 9. Jury Fees
Counsel are billed daily jury fees and must provide proof of payment to the clerk by the next day before trial can resume.
Counsel will be billed daily jury fees. Proof of payment must be provided to the clerk no later than the next day before trial can resume.
Civil cases
Page 12 | C. Jury Selection and Fees
Parties without a fee waiver must arrange and pay for their own court reporter for hearings and trials, as the Court no longer provides reporters for civil trials.
Court reporters are no longer provided by the Court for civil trials for parties without a fee waiver. If any party wishes to have a hearing or trial reported the party is responsible for arranging for a court reporter to be present for the trial at their own expense.
Civil cases
Page 11 | B. Court Reporters
Courtesy Copy Requirements
Courtesy copies are required only for oppositions to ex parte applications and for motions for, oppositions to, and replies to oppositions to summary judgment/summary adjudication, and must be submitted directly to Department 729.
The only courtesy copies required in Department 729 are Oppositions to Ex Parte Applications and Motions for, Oppositions to, and Replies to Oppositions to Motions for Summary Judgment/Summary Adjudication. Courtesy copies of these must be submitted directly to Department 729.
Civil cases
Page 4 | Law and Motion - C. Courtesy Copies Not Required except for Ex Partes and Motion for Summary Judgment Containing Media Exhibits
Courtesy copies, including any attached media, will be destroyed by the Court without notice after the hearing.
Courtesy copies, including any media attached thereto, will be destroyed by the Court without notice following the hearing.
Civil cases
Page 5 | Law and Motion
Filing Bundling Requirements
Department 729 strongly encourages parties filing or opposing lengthy motions for summary judgment or adjudication to submit one or more binders (sentence truncated in source at 'one or more three-').
Department 729 also strongly encourages the parties filing and opposing lengthy motions for summary judgment or adjudication, to submit one or more three-
Civil cases
Page 4 | Law and Motion - C. Courtesy Copies Not Required except for Ex Partes and Motion for Summary Judgment Containing Media Exhibits
Pre-Motion Conference Requirements
Parties must reserve motion hearing dates in advance using the Court Reservation System (CRS) online at www.lacourt.ca.gov.
Parties must reserve hearing dates for motions using the Court Reservation System (CRS) available online (www.lacourt.ca.gov).
Civil cases
Page 4 | Law and Motion - A. Reservation Hearing Date
Reservation requestors should immediately cancel the CRS reservation as soon as they realize the motion hearing or other reserved proceeding (such as an Informal Discovery Conference) will not be necessary.
As soon as a reservation requestor realizes that a motion hearing, or other proceeding requiring a reservation, such as in Informal Discovery Conference, will not be necessary, the reservation requestor should immediately use CRS to cancel the reservation for the motion hearing, or other proceeding requiring a reservation.
Civil cases
Page 4 | Law and Motion - A. Reservation Hearing Date
Parties are urged (not required) to schedule an Informal Discovery Conference before filing motions to compel further discovery responses.
Parties seeking to compel further responses to discovery are urged to schedule an Informal Discovery Conference (IDC) before even filing their motions.
Civil cases
Page 5 | E. Motions to Compel Further Responses to Discovery
If the reserved hearing date is too far in the future (e.g., after the trial date), parties should periodically check CRS for earlier dates that may become available as cases settle or hearings are taken off calendar.
If the moving party deems the hearing date to be too far in the future (say after the trial date), Parties should check CRS from time to time because earlier hearing dates may become available as cases settle or hearings are taken off calendar.
Civil cases
Page 4 | Law and Motion - A. Reservation Hearing Date
Parties interested in an MSC should first discuss the matter between themselves and then discuss the matter with the Court, either at a hearing or by means of an ex parte application.
Parties interested in an MSC should first discuss the matter between themselves and then discuss the matter with the Court, either at a hearing or by means of an ex parte application.
Civil cases
Page 10 | 11. Mandatory Settlement Conferences
Adjournment & Extension Requirements
Continuances will not be granted for witnesses who fail to timely appear and trial will proceed without them, though the Court may accommodate the scheduling needs of expert, professional, or out-of-state witnesses when circumstances warrant.
If witnesses are not under subpoena and do not timely appear, trial will proceed without them. Continuances will not be granted due to witnesses who do not appear in a timely manner. If possible, the Court will make an effort to accommodate the scheduling needs of expert witnesses, professionals, out-of-state witnesses, or others if the circumstances warrant.
Civil cases
Page 12 | F. Witnesses
Breaks or early recesses will not be permitted due to witness unavailability absent unusual circumstances.
Absent unusual circumstances, breaks or early recesses will not be permitted due to witness unavailability.
Civil cases
Page 12 | F. Witnesses
Chambers Communication Rules
Department 729's chambers/courtroom phone number is (213) 830-0771.
Phone: (213) 830-0771
Civil cases
Page 1 | Department Information
After meeting and conferring about available dates for an IDC, the moving/propounding party should reserve an IDC by calling Dept. 729’s staff at (213) 830-0771.
After meeting and conferring about available dates for an IDC, the moving/propounding party should reserve an IDC by calling Dept. 729’s staff at (213) 830-0771.
Civil cases
Page 5 | E. Motions to Compel Further Responses to Discovery