Judge David K. Reinert
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Anti SLAPP Motions
Motion
Summary Judgment Motions, Summary Adjudication Motions, Anti SLAPP Motions, Motion with Voluminous Exhibits or Declarations Motions
Communication
Chambers
Phone
Chambers
Document Format Requirements6 rules
The proposedjury instructions shall be prepared on Superior Court of Los Angeles County form SCLAC LACIV 129 or in a Word document that is in the same format.
- File type
- Word
- Proposed jury instructions
Exhibit binders must be tabbed three-ring binders with one-sided copies, numerically organized exhibits, each with separate exhibit numbers.
- Binding
- Tabbed three-ring binder
- Exhibits
Formatting
- •One-sided copies; each exhibit separately numbered; multi-page exhibits require per-page numbering
Court's wording
The parties’ counsel and any self-represented parties shall work together to jointly prepare at least three sets of tabbed exhibit binders organized numerically in three-ring binders (Exhibit Binders): a set for the Court, a set for the Judicial Assistant, and a set for the witnesses, in addition to any sets necessary for each party. Copies of documentary exhibits shall be one-sided copies. All multi-page exhibits must have each page separately numbered. Separate documents and photographs shall not be grouped into one exhibit, but must be separately numbered with their own exhibit number.
The proposedjury instructions shall be prepared on Superior Court of Los Angeles County form SCLAC LACIV 129 or in a Word document that is in the same format.
The Motions in limine Binder(s) shall include 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.
- Binding
- Three-ring binder
- Motions in limine binder
Formatting
- •Tabbed in numerical order
- •Conformed copies required
The Trial Binder must be a physical, tabbed three-ring binder containing conformed copies with a table of contents.
- Binding
- Three-ring binder
- Trial binder
Formatting
- •Physical binder (not electronic)
- •Tabbed
- •Conformed copies
- •Table of contents required
Court's wording
On the date of the Final Status Conference, the parties' counsel and any self-represented parties must jointly prepare and lodge in Department P a physical Trial Binder, consisting of conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following:
Copies of documentary exhibits shall be one-sided copies.
Document Filing Requirements32 rules
OSC set concurrent with CMC for case prosecution, proof of service filing, and CMC statement submission; failure to file CMC statement with no proof of service triggers sanctions.
Court's wording
An OSC will be set concurrently with the CMC date regarding 1) prosecution of the case, 2) filing a proof of service of the summons and complaint; and 3) filing a case management statement. A represented Plaintiff’s failure to file a CMC statement when no proof of service has been filed will result in monetary sanctions against Plaintiff’s counsel.
Written showing must be filed prior to OSC hearing for failure to comply with court order; oral explanations are not accepted.
Court's wording
If the court sets an order to show cause for a failure to comply with a direct court order, sanctions will be imposed unless a written showing is filed prior to the hearing on the OSC. Oral explanations will neither be sought nor accepted.
If the court sets an order to show cause for a failure to comply with a direct court order, sanctions will be imposed unless a written showing is filed prior to the hearing on the OSC. Oral explanations will neither be sought nor accepted.
A represented Plaintiff's failure to file a CMC statement when no proof of service has been filed will result in monetary sanctions against Plaintiff's counsel.
Counsel and self-represented parties must jointly prepare and file a witness list covering all trial witnesses (excluding impeachment and rebuttal witnesses) organized to include each witness's name, expert status, accommodations, calling party, expected-testimony status and description, and estimated direct, cross, and total examination times in minutes.
Court's wording
The parties' counsel and any self-represented parties must work together to prepare and file a joint witness list of all witnesses whom any party intends to call at trial, excluding impeachment and rebuttal witnesses. (Los Angeles County Court Rule (Local Rule) 3.25, subd. (g)(5).) The joint witness list shall be organized to include: (1) the name of each witness, whether 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 description of the witness's expected testimony; (5) an estimate of the length of direct examination (in minutes); (6) an estimate of the length of cross-examination (in minutes), and; (7) the total estimated length of examination (in minutes).
For jury trials, counsel and self-represented parties must jointly prepare and file a list of proposed jury instructions stating, for each instruction, the number, title, requesting party, agreed/contested status, any objection, and whether it was given.
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 which states, as to 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.
For jury trials, the parties' counsel and any self-represented parties must 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).)
Counsel and self-represented parties must jointly prepare and file a joint exhibit list containing eight required columns: exhibit number, description, offering party, authentication stipulation, admissibility stipulation, objections, date marked, and date admitted.
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 which state, as to 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).)
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 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 intending to use deposition or former trial testimony must meet and confer and file a joint designation chart with five required columns; testimony used for impeachment purposes only need not be included.
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 of former testimony the parties intend to use. The parties do not, however, need to include in the joint chart deposition testimony or former trial testimony they plan on using for impeachment purposes only. In the joint chart, each designating party's designations (or counter-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 testimony requested to be used, (4) any objections, and (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.
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 and court trials, the parties must jointly file a proposed general or special verdict form, or if they cannot agree, each party must separately file a proposed verdict form, using CACI special verdict forms where appropriate.
Court's wording
For jury and court trials, the parties' counsel and any self-represented parties must 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.
All of the above listed documents should be jointly prepared and submitted. However, in the absence of agreed-upon joint documents, each party must prepare and submit the party's own documents.
Motions in limine shall be noticed for hearing at the Final Status Conference. 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 Local Rule 3.57, subdivision (a).
Jointly prepared Motions in Limine Binders containing conformed copies of all motions in limine, opposition papers, and reply papers must be lodged in Department P no later than five court days before the Final Status Conference.
Court's wording
No later than five (5) court days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department P Motions in limine Binders). The Motions in limine Binder(s) shall include 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.
The parties' counsel and any self-represented parties shall bring one set of the Exhibit Binders to the Final Status Conference for the court to review.
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 caption of each motion in limine shall concisely identify the evidence that the moving party seeks to exclude.
- Document
- Motion in limine
- Placement
- Caption
The parties' counsel and any self-represented parties shall work together to jointly prepare at least three sets of tabbed exhibit binders organized numerically in three-ring binders (Exhibit Binders): a set for the Court, a set for the Judicial Assistant, and a set for the witnesses, in addition to any sets necessary for each party.
A jointly prepared, tabbed physical Trial Binder with conformed copies and a table of contents (including tabs for operative pleadings, optional trial briefs, joint witness list, joint statement of the case, jury instruction lists, verdict forms, and the deposition designation chart) must be lodged in Department P on the date of the Final Status Conference.
- Document
- Trial binder
Must include
- •Table of contents
Court's wording
On the date of the Final Status Conference, the parties' counsel and any self-represented parties must jointly prepare and lodge in Department P a physical Trial Binder, consisting of conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following: Tab: Copies of the Operative Pleadings (Complaint, Answer, Cross-Complaint, etc.) Tab: Trial Briefs (optional but recommended) Tab: Joint Witness List Tab: Joint Short Statement of the Case to Be Read to the Jury Tab: Joint List of Jury Instructions Tab: Joint and Contested Jury Instructions Tab: Joint or Contested Verdict Form(s) Tab: Joint Chart of Page and Line Designations for Deposition and Former Testimony.
The parties shall organize proposed jury instructions into groups 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.
Issues of service or prosecution should be addressed in the CMC statement.
As set forth above, the parties' counsel and any self-represented parties must meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit.
estimated times for all witnesses' testimony and state the grand total in the last column (in hours).
The parties shall eliminate duplicate exhibits which may bear different numbers from each party.
If there is an appropriate CACI jury instruction on a point of law, the court anticipates that the parties shall request the CACI instruction instead of a specially prepared jury instruction.
Counsel filing a motion in limine must have a good faith belief that the matter addressed in the motion shall actually be at issue in the case.
Parties filing more than one motion in limine shall number them consecutively.
Separate documents and photographs shall not be grouped into one exhibit, but must be separately numbered with their own exhibit number.
All multi-page exhibits must have each page separately numbered.
Each party may, but is not required to, 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, such as evidentiary issues that are anticipated that may merit discussion.
- Document
- Trial brief
Include
- •Legal argument
During trial, if circumstances change, the parties may request additional applicable jury instruction.
Filing & Service rules
Filing Timing and Cure Windows
If no discovery motions have been filed, please provide a Joint Statement of the discovery issues in contention at least two days prior to the IDC.
If no discovery motions have been filed, please provide a Joint Statement of the discovery issues in contention at least two days prior to the IDC.
Page 3 | F. Discovery
If no discovery motions have been filed, please provide a Joint Statement of the discovery issues in contention at least two days prior to the IDC.
If no discovery motions have been filed, please provide a Joint Statement of the discovery issues in contention at least two days prior to the IDC.
Page 3 | F. Discovery
No later than five (5) court days before the Final Status Conference, the parties' counsel and any self-represented parties shall file and serve the following documents:
No later than five (5) court days before the Final Status Conference, the parties' counsel and any self-represented parties shall file and serve the following documents:
Page 4 | H. Trial - 2. Trial Documents to Be Filed
All trial exhibits must be exchanged 10 court days prior to the Final Status Conference.
No later than ten (10) court 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 4 | 1. MEET AND CONFER IN ADVANCE OF FINAL STATUS CONFERENCE
No later than ten court days before the Final Status Conference, counsel and self-represented parties must meet and confer (by telephone or in person) to prepare required trial documents and binders, attempt stipulations on exhibit authenticity/admissibility, motions in limine, and ultimate facts/legal issues, and attempt to settle the case.
No later than ten (10) court days before the Final Status Conference, the parties' counsel and any self-represented parties shall meet and confer by telephone or in person 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 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 the case.
Page 4 | H. Trial - 1. Meet and Confer in Advance of Final Status Conference
All exhibits a party intends to introduce at trial must be exchanged between counsel and any self-represented parties no later than ten court days before the Final Status Conference.
No later than ten (10) court 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 4 | H. Trial - 1. Meet and Confer in Advance of Final Status Conference
Required trial documents must be filed and served 5 court days prior to the Final Status Conference.
No later than five (5) court days before the Final Status Conference, the parties’ counsel and any self-represented parties shall file and serve the following documents: A. TRIAL BRIEFS (OPTIONAL); B. JOINT WITNESS LIST; C. JOINT EXHIBIT LIST; D. JOINT SHORT STATEMENT OF THE CASE; E. JOINT LIST OF PROPOSED JURY INSTRUCTIONS; F. FULL-TEXT PROPOSED JURY INSTRUCTIONS; G. VERDICT FORM(S); H. JOINT CHART OF PAGE AND LINE DESIGNATIONS.
Page 4 | 2. TRIAL DOCUMENTS TO BE FILED
Service and Proof of Service Rules
The court sets an OSC at the CMC regarding, among other things, failure to file a proof of service of the summons and complaint.
An OSC will be set concurrently with the CMC date regarding 1) prosecution of the case, 2) filing a proof of service of the summons and complaint; and 3) filing a case management statement.
Page 2 | D. Orders to Show Cause
Required trial documents must be served 5 court days prior to the Final Status Conference.
No later than five (5) court days before the Final Status Conference, the parties’ counsel and any self-represented parties shall file and serve the following documents: A. TRIAL BRIEFS (OPTIONAL); B. JOINT WITNESS LIST; C. JOINT EXHIBIT LIST; D. JOINT SHORT STATEMENT OF THE CASE; E. JOINT LIST OF PROPOSED JURY INSTRUCTIONS; F. FULL-TEXT PROPOSED JURY INSTRUCTIONS; G. VERDICT FORM(S); H. JOINT CHART OF PAGE AND LINE DESIGNATIONS.
Page 4 | 2. TRIAL DOCUMENTS TO BE FILED
Courtesy Copy Requirements
Physical courtesy copies of motions are required for motions for summary judgment or adjudication, anti-SLAPP motions, and any other motion supported by voluminous exhibits or declarations.
Physical courtesy copies of motions are required for: 1) Motions for Summary Judgment or Adjudication; 2) Anti-SLAPP Motions; and 3) Any other motion supported by voluminous exhibits or declarations.
Page 2 | E. Law and Motion
Physical courtesy copies are required for motions for summary judgment/adjudication, anti-SLAPP motions, and motions with voluminous exhibits or declarations.
Physical courtesy copies of motions are required for: 1) Motions for Summary Judgment or Adjudication; 2) Anti-SLAPP Motions; and 3) Any other motion supported by voluminous exhibits or declarations.
Page 2 | E. Law and Motion
Courtesy copies are not required for other electronically filed motions.
Courtesy copies are not required for other electronically filed motions.
Page 3 | E. Law and Motion
Courtesy copies are not required for electronically filed motions not explicitly mandated to provide them.
Courtesy copies are not required for other electronically filed motions.
Page 3 | E. Law and Motion
Filing Bundling Requirements
Trial binder must be a tabbed three-ring binder with table of contents, lodged on the Final Status Conference date.
On the date of the Final Status Conference, the parties’ counsel and any self-represented parties must jointly prepare and lodge in Department P a physical Trial Binder, consisting of conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following: Tab: Copies of the Operative Pleadings (Complaint, Answer, Cross-Complaint, etc.) Tab: Trial Briefs (optional but recommended) Tab: Joint Witness List Tab: Joint Short Statement of the Case to Be Read to the Jury Tab: Joint List of Jury Instructions Tab: Joint and Contested Jury Instructions Tab: Joint or Contested Verdict Form(s) Tab: Joint Chart ofPage and Line Designations for Deposition and Former Testimony.
Page 7 | 5. TRIAL BINDER
Motions in limine must be bundled in tabbed three-ring binders with conformed copies, lodged 5 court days prior to Final Status Conference.
No later than five (5) court days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department P Motions in limine Binders). The Motions in limine Binder(s) shall include 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.
Page 7 | 3. MOTIONS IN LIMINE
Pre-Motion Conference Requirements
The court strongly recommends (but does not require) an informal discovery conference before or after filing discovery motions.
The court strongly recommends having an informal discovery conference prior to, or after, filing of discovery motions.
Page 3 | F. Discovery
Adjournment & Extension Requirements
Once a trial date is set, the court presumes that no continuance of the trial date will be necessary.
Once a trial date is set, the court presumes no continuance will be necessary.
Page 1 | C. Case Management Conferences and Trial Setting Conferences
Requests for priority or second call are liberally granted; failure to appear at second call results in OSC and continued hearing.
the court liberally grants requests for priority or second call. If counsel does not appear at first call, the matter will be placed at the end of the calendar. Ifcounsel does not appear for second call, the court will set an order to show cause and continue the hearing to a date convenient with the court and any counsel who do appear.
Page 1 | A. Daily Calendar Call
Chambers Communication Rules
Chambers email contact is tordeptp@lacourt.ca.gov.
Courtroom Email: tordeptp@lacourt.ca.gov
Page 1 | Courtroom Information
The courtroom/chambers email address for Department P is tordeptp@lacourt.ca.gov.
Courtroom Email: tordeptp@lacourt.ca.gov
Page 1 | Courtroom Information
The courtroom telephone number for Department P is 787-3834.
Courtroom Telephone: 787-3834
Page 1 | Courtroom Information
Courtroom Telephone: 787-3834; Courtroom Assistant: Patricia Aranda (310).
Courtroom Telephone: 787-3834; Courtroom Assistant: Patricia Aranda (310).
Page 1 | Courtroom Information
VSCs are scheduled at 11:00 AM or 1:30 PM on non-trial days; schedule by calling the Judicial Assistant after meet and confer.
To schedule a VSC, counsel should meet and confer as to a proposed time and call the Judicial Assistant to schedule a conference. VSC’s may be scheduled at 11:00 AM or 1:30 PM on any day that the court is not in trial.
Page 3 | G. Settlement and Contested Issue Conferences
To schedule an IDC, counsel should meet and confer as to a proposed time and call the Judicial Assistant to schedule the hearing. IDC’s may be scheduled at 11:00 AM on any day that the court is not engaged in trial.
To schedule an IDC, counsel should meet and confer as to a proposed time and call the Judicial Assistant to schedule the hearing. IDC’s may be scheduled at 11:00 AM on any day that the court is not engaged in trial.
Page 3 | F. Discovery
Voluntary Settlement Conferences are scheduled by meeting and conferring on a proposed time and calling the Judicial Assistant; VSCs may be set at 11:00 AM or 1:30 PM on days the court is not in trial and may be rescheduled by the Judicial Assistant by email if trial intervenes.
If the parties need the court's guidance in such a situation, they should meet and confer as to a proposed time and call the Judicial Assistant to schedule a conference. VSC's may be scheduled at 11:00 AM or 1:30 PM on any day that the court is not in trial. If the court becomes engaged in trial, the Judicial Assistant may send an email to the involved parties rescheduling the conference.
Page 3 | G. Settlement and Contested Issue Conferences
Informal discovery conferences are scheduled by meeting and conferring on a proposed time and calling the Judicial Assistant; IDCs may be set at 11:00 AM on days the court is not in trial and may be rescheduled by the Judicial Assistant by email if trial intervenes.
To schedule an IDC, counsel should meet and confer as to a proposed time and call the Judicial Assistant to schedule the hearing. IDC's may be scheduled at 11:00 AM on any day that the court is not engaged in trial. If the court becomes engaged in trial, the Judicial Assistant may send an email to the involved parties rescheduling the conference.
Page 3 | F. Discovery