Judge Daniel S. Murphy
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Courtesy Copies
Courtesy copies
- 1 copy • Within 5 Court Days of Filing
Motion
- 1 copy • Within 5 Court Days
Opposition
- 1 copy
Communication
Phone
Chambers
Phone
Document Format Requirements1 rule
If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3, etc.
Document Filing Requirements21 rules
For an informal discovery conference, counsel shall file a stipulation and proposed order which sets forth dates that counsel would be available for the informal discovery conference.
- Document
- Stipulation and proposed order
Must include
- •Proposed order
For an informal discovery conference, counsel shall file a stipulation and proposed order which sets forth dates that counsel would be available for the informal discovery conference.
- Document
- Stipulation
Must include
- •Proposed order
JOINT EXHIBIT LIST. All exhibits must be listed on one list, identified by a number and brief description. Notebooks containing all exhibits must be available on the final status conference date and all parties must be prepared to tell the court that they have had the opportunity to review all documents in the exhibit book.
- Document
- Joint exhibit list
Must include
- •Exhibit list
Counsel filing evidentiary objections in connection with a motion for summary judgment or summary adjudication should comply with California Rules of Court Rule 3.1354. Please note an evidentiary objection must specifically identify the document in which the objectionable material is located and quote or set forth the objectionable statement or material. Counsel should not object to a “statement” contained in opposing party’s statement of undisputed material facts; rather the objection must be directed to the evidence in support of that fact and state the basis for the objection.
Counsel filing evidentiary objections in connection with a motion for summary judgment or summary adjudication should comply with California Rules of Court Rule 3.1354. Please note an evidentiary objection must specifically identify the document in which the objectionable material is located and quote or set forth the objectionable statement or material. Counsel should not object to a “statement” contained in opposing party’s statement of undisputed material facts; rather the objection must be directed to the evidence in support of that fact and state the basis for the objection.
Parties must submit a joint, fully completed set of CACI instructions (no brackets, blanks, tear sheets, or disposition boxes), separate sets for disputed instructions identifying proposer and opponent, and a disposition table listing all instructions with columns for the court's rulings.
Court's wording
Submit a joint set of CACI instructions with all information filled in, no remaining brackets or blanks. Do not use tear sheets for the instructions and do not include the disposition box on the page of the individual instruction. If some instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction. Submit a disposition table which lists all jury instructions by number, the identity of the party or parties proposing the instruction, and which contains columns for the court to indicate whether the instruction is given, modified, withdrawn or refused.
4. JOINT SHORT STATEMENT TO BE READ TO THE JURY. This statement should be a brief, neutral description of the case. In most instances, it should not exceed 2-3 paragraphs.
Joint CACI jury instructions and disposition table required 5 court days before final status conference for jury trials.
- Document
- Joint jury instructions
Include
- •Jury instructions
Court's wording
3. JOINT JURY INSTRUCTIONS. Submit a joint set of CACI instructions with all information filled in, no remaining brackets or blanks. Do not use tear sheets for the instructions and do not include the disposition box on the page of the individual instruction. If some instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction. Submit a disposition table which lists all jury instructions by number, the identity of the party or parties proposing the instruction, and which contains columns for the court to indicate whether the instruction is given, modified, withdrawn or refused.
Joint witness list with time estimates required 5 court days before final status conference for jury trials.
- Document
- Joint witness list
Must include
- •Witness list
Court's wording
2. JOINT WITNESS LIST. All witnesses must be listed on one list. Do not repeat the name of a witness who will be called by more than one party. Next to each witness, indicate the total time expected for that testimony (including direct, cross, redirect, etc.) At the end of the list, total the time estimated for testimony. Make realistic time estimates. Absent good cause, the total number of hours listed for testimony should not exceed the trial estimate given at the case management conference, including the allocation of 1 day for jury selection and 1 day for deliberations. For example, a 5 day trial estimate means no more than 3 days of testimony.
5. JOINT PROPOSED VERDICT FORM. If the parties cannot agree on the verdict form, each party must submit a proposed verdict form. Any proposed special verdict should be in a form that is easily used by the jury, and which does not require the jury to answer unnecessary questions.
- Document
- Joint proposed verdict form
Must include
- •Verdict form
The joint witness list must include all witnesses on a single list without duplicated names, with expected testimony time for each witness and a total time estimate at the end.
Court's wording
All witnesses must be listed on one list. Do not repeat the name of a witness who will be called by more than one party. Next to each witness, indicate the total time expected for that testimony (including direct, cross, redirect, etc.) At the end of the list, total the time estimated for testimony.
If the parties cannot agree on the verdict form, each party must submit a proposed verdict form. Any proposed special verdict should be in a form that is easily used by the jury, and which does not require the jury to answer unnecessary questions.
COURT TRIALS. The parties must submit a joint exhibit list and joint witness list as described above. A trial brief must be served and filed no later than the final status conference.
- Document
- Trial brief
Must include
- •Exhibit list
- •Witness list
The parties must submit a joint exhibit list and joint witness list as described above.
If you have motions reserved under the Court Reservation System for multiple hearing dates, please submit a proposed order for the motions to be heard on one date. Make sure the motions are reserved on the Court Reservation System before you submit a proposed order.
If you have motions reserved under the Court Reservation System for multiple hearing dates, please submit a proposed order for the motions to be heard on one date. Make sure the motions are reserved on the Court Reservation System before you submit a proposed order.
- Document
- Motion
Include
- •Proposed order
The court will consider referring the parties to a mandatory settlement conference, if counsel file a stipulation and proposed order seeking a mandatory settlement conference..
- Document
- Stipulation and proposed order
Must include
- •Proposed order
Absent good cause, the total number of hours listed for testimony should not exceed the trial estimate given at the case management conference, including the allocation of 1 day for jury selection and 1 day for deliberations. For example, a 5 day trial estimate means no more than 3 days of testimony.
This statement should be a brief, neutral description of the case. In most instances, it should not exceed 2-3 paragraphs.
The court will consider referring the parties to a mandatory settlement conference, if counsel file a stipulation and proposed order seeking a mandatory settlement conference.
- Document
- Stipulation
Must include
- •Proposed order
Joint exhibit list required 5 court days before final status conference for jury trials.
- Document
- Joint exhibit list
Must include
- •Exhibit list
Court's wording
JURY TRIALS 1. JOINT EXHIBIT LIST. All exhibits must be listed on one list, identified by a number and brief description. Notebooks containing all exhibits must be available on the final status conference date and all parties must be prepared to tell the court that they have had the opportunity to review all documents in the exhibit book. Place the correspond with the exhibit number. If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3, etc. Exhibits should be lodged with the court on the first day of trial.
Filing & Service rules
Electronic Filing Rules
Self-represented litigants are exempt from the mandatory electronic filing requirements under CRC 2.253(b)(2).
Pursuant to California Rules of Court, rule 2.253(b)(2), self-represented litigants are exempt from the mandatory Electronic Filing requirements.
Page 1 | Ex Parte Applications
Represented litigants must electronically file ex parte applications and supporting documents by 10:00 a.m. the court day before the hearing.
For represented litigants, all Ex parte applications and all documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the ex parte hearing.
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Represented litigants must electronically file all ex parte applications and supporting documents no later than 10:00 a.m. the court day before the ex parte hearing.
For represented litigants, all Ex parte applications and all documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the ex parte hearing.
Page 1 | Ex Parte Applications
Written opposition to ex parte applications must be electronically filed by 8:30 a.m. the day of the hearing.
Any written opposition to an ex parte application shall be electronically filed by 8:30 a.m. the day of the ex parte hearing.
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Self-represented litigants are exempt from mandatory electronic filing requirements per CRC Rule 2.253(b)(2).
Pursuant to California Rules of Court, rule 2.253(b)(2), self-represented litigants are exempt from the mandatory Electronic Filing requirements.
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Filing Timing and Cure Windows
Ex parte applications and supporting papers must be e-filed by a 10:00 a.m. cutoff on the court day before the hearing.
For represented litigants, all Ex parte applications and all documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the ex parte hearing.
Page 1 | Ex Parte Applications
Written opposition to an ex parte application must be electronically filed by 8:30 a.m. on the day of the ex parte hearing.
Any written opposition to an ex parte application shall be electronically filed by 8:30 a.m. the day of the ex parte hearing.
Page 1 | Ex Parte Applications
Ex parte opposition must be filed by 8:30 a.m. the day of the hearing.
Any written opposition to an ex parte application shall be electronically filed by 8:30 a.m. the day of the ex parte hearing.
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Ex parte applications and supporting documents must be filed by 10:00 a.m. the court day before the hearing.
For represented litigants, all Ex parte applications and all documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the ex parte hearing.
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Parties must meet and confer and submit the required trial documents five court days before the final status conference.
The parties must meet and confer and submit the following documents FIVE COURT DAYS BEFORE THE FINAL STATUS CONFERENCE.
Page 2 | Meet and Confer Required Prior to Final Status Conference
Written oppositions to motions in limine may be served and filed no later than the final status conference.
A written opposition to a motion in limine may be served and filed no later than the final status conference.
Page 3 | Trial Preparation Order
Motions in limine must be served on the opposing party and submitted to the court five court days before the final status conference.
Motions in limine must be served on the opposing party and submitted to the court five court days prior to the final status conference.
Page 3 | Trial Preparation Order
6. MOTIONS IN LIMINE. Motions in limine must be served on the opposing party and submitted to the court five court days prior to the final status conference. A written opposition to a motion in limine may be served and filed no later than the final status conference. Replies are not required but may be served and filed no later than the Friday preceding the trial date. The court does not rule on motions in limine until the first day of trial. Motions in limine should not be used to seek summary judgment, summary adjudication of issues, or judgment on the pleadings.
6. MOTIONS IN LIMINE. Motions in limine must be served on the opposing party and submitted to the court five court days prior to the final status conference. A written opposition to a motion in limine may be served and filed no later than the final status conference. Replies are not required but may be served and filed no later than the Friday preceding the trial date. The court does not rule on motions in limine until the first day of trial. Motions in limine should not be used to seek summary judgment, summary adjudication of issues, or judgment on the pleadings.
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A trial brief must be served and filed no later than the final status conference.
A trial brief must be served and filed no later than the final status conference.
Page 4 | Court Trials
Replies to motions in limine are optional but, if served and filed, must be submitted no later than the Friday preceding the trial date.
Replies are not required but may be served and filed no later than the Friday preceding the trial date.
Page 3 | Trial Preparation Order
Exhibits should be lodged with the court on the first day of trial.
Exhibits should be lodged with the court on the first day of trial.
Page 3 | Trial Preparation Order
Service and Proof of Service Rules
Motions in limine must be served on opposing party 5 court days before final status conference.
6. MOTIONS IN LIMINE. Motions in limine must be served on the opposing party and submitted to the court five court days prior to the final status conference. A written opposition to a motion in limine may be served and filed no later than the final status conference. Replies are not required but may be served and filed no later than the Friday preceding the trial date. The court does not rule on motions in limine until the first day of trial. Motions in limine should not be used to seek summary judgment, summary adjudication of issues, or judgment on the pleadings.
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Papers required to be served under this order must be served in a manner calculated to reach the other party by the stated deadline, and the parties are encouraged to agree on the service method (e-mail, fax, etc.).
NOTE RE SERVICE- any papers required to be served on another party pursuant to this order must be served in a manner calculated to reach that party no later than the date indicated in this order. The parties are encouraged to agree on the method (e-mail, fax, etc).
Page 4 | Note Re Service
Service must be calculated to reach party by the deadline; e-mail/fax encouraged.
NOTE RE SERVICE- any papers required to be served on another party pursuant to this order must be served in a manner calculated to reach that party no later than the date indicated in this order. The parties are encouraged to agree on the method (e-mail, fax, etc).
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Filing Fees and Waivers
Motion fees must be paid at the time the motion date reservation is made online via CRS.
Motion fee payments are required at the time reservations are made online.
Page 1 | Law and Motion
Motion fees must be paid online when reserving a motion date via CRS.
Motion fee payments are required at the time reservations are made online.
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Courtesy Copy Requirements
Courtesy copy required for ex parte opposition filed after 4:00 p.m. the court day before the hearing.
If written opposition is electronically filed after 4:00 p.m. the court day before, a printed courtesy copy is required.
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A printed courtesy copy of ex parte opposition is required if it is e-filed after 4:00 p.m. the court day before the hearing.
If written opposition is electronically filed after 4:00 p.m. the court day before, a printed courtesy copy is required.
Page 1 | Ex Parte Applications
within 5 court days of the filing, counsel should deliver a courtesy copy of the material to Department 406.
within 5 court days of the filing, counsel should deliver a courtesy copy of the material to Department 406.
Page 2 | Law and Motion
within 5 court days of the filing, counsel should deliver a courtesy copy of the material to Department 406.
within 5 court days of the filing, counsel should deliver a courtesy copy of the material to Department 406.
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Sealing & Redaction Procedures
Materials submitted in support of a motion under seal must strictly comply with California Rules of Court Rule 2.551 et seq.
If counsel wishes to submit any materials in support of a motion under seal, counsel must strictly comply with California Rules of Court Rule 2.551 et. seq.
Page 2 | Sealed Documents
Materials filed under seal must strictly comply with CRC Rule 2.551 et seq.
If counsel wishes to submit any materials in support of a motion under seal, counsel must strictly comply with California Rules of Court Rule 2.551 et. seq.
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Filing Bundling Requirements
More than 10 motions in limine require a tabbed, indexed separate notebook.
If there are more than 10 motions in limine, the court requires the parties to submit a separate notebook containing the motion, opposition, and reply (if any), tabbed and indexed.
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If more than 10 motions in limine are filed, parties must submit a separate tabbed and indexed notebook containing the motion, opposition, and any reply.
If there are more than 10 motions in limine, the court requires the parties to submit a separate notebook containing the motion, opposition, and reply (if any), tabbed and indexed.
Page 3 | Trial Preparation Order
The court prefers that all motions concerning a matter be heard on the same date when possible.
It is the court’s desire, if possible, that all motions concerning a matter be heard on the same date.
Page 1 | Law and Motion
Pre-Motion Conference Requirements
Parties must reserve motion dates via CRS before filing any motion papers.
As of January 4, 2016, parties must obtain a motion date via the online Court Reservation System (CRS) on the Los Angeles Court website. Go to “LA Court Online, Court Reservation System,” at Superior Court of Los Angeles County Webpage to reserve a date prior to filing any motion papers.
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Counsel must exhaust meet and confer efforts before filing any discovery motion, and the court will conduct an in-person informal discovery conference if the parties agree.
The Court requires all counsel to exhaust meet and confer efforts before filing a discovery motion. If the parties agree, the Court will help counsel resolve discovery disputes through an in person informal discovery conference.
Page 1 | Discovery
Meet and confer required before filing discovery motions.
The Court requires all counsel to exhaust meet and confer efforts before filing a discovery motion.
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Parties must reserve a motion hearing date through the online Court Reservation System (CRS) before filing any motion papers.
As of January 4, 2016, parties must obtain a motion date via the online Court Reservation System (CRS) on the Los Angeles Court website. Go to “LA Court Online, Court Reservation System,” at Superior Court of Los Angeles County Webpage to reserve a date prior to filing any motion papers.
Page 1 | Law and Motion
Parties must meet and confer before final status conference.
The parties must meet and confer and submit the following documents FIVE COURT DAYS BEFORE THE FINAL STATUS CONFERENCE.
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Chambers Communication Rules
LACourtConnect may be contacted at (888)882-6878. Counsel will need to make arrangements with LACourtConnect at least three hours before the hearing.
LACourtConnect may be contacted at (888)882-6878. Counsel will need to make arrangements with LACourtConnect at least three hours before the hearing.
Page 2 | Telephonic Appearance
Parties may not call the courtroom to reserve motion dates; reservations must be made online through CRS.
Please do not call the courtroom to reserve a motion date.
Page 1 | Law and Motion
The judicial assistant for Department 406, Shantal Luqueno, can be reached at (213) 633-0152.
Shantal Luqueno, Judicial Assistant (213) 633-0152
Page 1 | Courtroom Information - Department 406
Telephonic appearance arrangements via LACourtConnect must be made at least 3 hours before hearing.
Counsel will need to make arrangements with LACourtConnect at least three hours before the hearing.
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