Judge David W. Swift
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- 3 copies • On or Before First Day of Trial
Ex Parte Application
- Morning of Hearing
Exhibit Binders
- 3 copies
Exhibit Binders, Trial Documents, Joint Witness List, Joint Exhibit List, Jury Instructions, Verdict Forms
- 3 copies
Adjournments
- Hearings, conferences, and trial dates may be continued via stipulation and proposed order filed on eCourt; absent stipulation, the continuance may be pursued at a CMC or by ex parte application upon good cause.
- Moving parties may continue motion hearing dates to the next available date without leave of court, and motion hearing dates must be reserved on the Court Reservation System.
- Continuances will not be granted because witnesses fail to timely appear; trial proceeds without them, though the Court may accommodate scheduling needs of experts, professionals, and out-of-state witnesses.
Request must include
Communication
Phone
Page & Word Limits2 rules
Third, a joint brief – no more than five-pages in length that summarizes the discovery dispute(s) at issue – shall be filed and provided to the Court at least three court days prior to the hearing.
- Joint brief
- Up to 5 pages
a joint brief – no more than five-pages in length that summarizes the discovery dispute(s) at issue – shall be filed and provided to the Court at least three court days prior to the hearing.
- Joint brief
- Up to 5 pages
Document Format Requirements9 rules
All motions must comply with the California Code of Civil Procedure and California Rules of Court as to format and filing, or risk denial and/or sanctions.
Court's wording
The Court expects counsel to be familiar with and abide by the California Code of Civil Procedure and the California Rules of Court with respect to the format and filing of all motions. Failure to comply with the relevant code sections or rules may result in denial of the motion and/or sanctions.
Counsel shall bring to Department P copies of all trial documents and an electronic version of the joint witness list, exhibit list, jury instructions, and verdict forms on a thumb/USB drive or CD disk with the documents in Microsoft Word format or compatible format. In the alternative, Counsel may email those documents directly to Department P.
- File type
- Word
- Joint witness list
- Jury instructions
- Verdict form
MILs must comply with LASC Rule 3.57.
Each page of a multi-page exhibit must be consecutively paginated.
Non-documentary exhibits shall be represented in a binder with a simple written description.
Bulk exhibits, e.g., voluminous medical records will not be permitted. Counsel must separately mark and identify the specific items within a bulk exhibit.
an electronic version of the joint witness list, exhibit list, jury instructions, and verdict forms on a thumb/USB drive or CD disk with the documents in Microsoft Word format or compatible format. In the alternative, Counsel may email those documents directly to Department P.
- File type
- Word
- Joint witness list
- Joint exhibit list
- Jury instructions
- Verdict forms
Formatting
- •Electronic version must be delivered on a thumb/USB drive or CD disk
MILs and other trial motions should be numbered consecutively, with a caption that clearly and concisely identifies the subject of the motion.
- Motion in limine
- Trial motion
Formatting
- •Numbered consecutively
Blow-ups of portions of exhibits should be identified and marked as sub-part A. Typically, a blow-up will not be admitted into evidence.
Document Filing Requirements15 rules
All hearings and conference dates, including trial dates, may be considered for continuance via stipulation and proposed order (filed on eCourt).
- Document
- Continuance stipulation
Include
- •Proposed order
If the Ex Parte pertains to a Law and Motion matter, the Motion must be reserved in the Court Reservation System (or E-Court) prior to the Ex Parte filing.
Parties must reserve a hearing date for any motion through the Court Reservation System.
The joint witness list must include all witnesses on one list with realistic time estimates for direct, cross, and redirect testimony, totals at the bottom, no duplicate names, and designation of each witness as percipient or expert with area of expertise.
Court's wording
JOINT WITNESS LIST. The parties shall list all witnesses, with realistic estimates for direct and cross-examination on one list. See, LASCR 3.25(g)(5). Do not repeat the name of a witness who will be called by more than one party. The witness list should have columns that indicate for each witness the total time expected for direct, cross, and redirect testimony. At the bottom of the list, provide the total the time estimated for all testimony. Make realistic time estimates. The list should specify if the witness is percipient or expert (with area of expertise).
Any person who is not listed on the joint witness list shall be either excluded from testifying or his or her testimony shall be limited to only impeachment or rebuttal.
The parties must file a joint set of CACI jury instructions with all headings and information completed, no remaining brackets or blanks, no tear sheets, and no disposition box on individual instruction pages.
Court's wording
JOINT JURY INSTRUCTIONS. The parties shall file a joint set of proposed agreed and not agreed CACI jury instructions with headings and all information filled in (e.g., singular or plural, gender, etc.), and no remaining brackets or blanks. See, LASCR 3.25(g)(7). Do not use tear sheets for the instructions and do not include the disposition box on the page of the individual instruction.
Instructions as to which there are disagreements should be provided in separate sets. However, disputed jury instructions may be filed only if counsel have met and conferred. The jury instructions should include a disposition table that lists all jury instructions by number, the identity of the party or parties proposing (or opposing) the instruction, and include columns for the court to use to indicate whether the instruction is given, modified, withdrawn or refused.
The joint exhibit list must contain specified columns (Ex. No., Description, Offered by, Stipulated, Objection, Date ident., Date admit), counsel must meet and confer before filing to resolve foundation/admissibility objections, and submission does not waive objections.
Court's wording
The Joint Exhibit List shall have the following columns: Ex. No., Description, Offered by, Stipulated, Objection, Date ident., and Date admit. Counsel must meet and confer prior to filing of the Joint Exhibit List in an effort to resolve any objections as to the foundation and admissibility of exhibits, with stipulations as to foundation and admissibility where feasible. Submission of the joint exhibit list shall not be deemed a waiver of any objection to the admission into evidence at trial of any exhibit on the list.
Each morning counsel must provide the Court Attendant with a written list of witnesses to be called that day including their full names with correct spellings and the order in which they will be called.
At the end of the trial, counsel will be required to prepare and lodge with the court a revised exhibit list that reflects only those exhibits that have been admitted. The revised exhibit list will be provided to the jury during their deliberations.
Counsel must meet and confer to prepare a joint, neutral, plain-English statement of the case (unless all parties agree to mini-opening statements) that should not exceed 2-3 paragraphs.
Court's wording
JOINT SHORT STATEMENT OF THE CASE TO BE READ TO THE JURY. Unless all parties agree to mini-opening statements; counsel shall meet and confer with opposing counsel to prepare a brief, neutral description of the case. See, LASCR 3.25(g)(4). The statement should inform the jury about the parties and their claims, without favoring one side, and gives jurors reasons why they would want to serve on your case. The statement should be in plain English, not expound legal theories, or be factual advocacy for either side. In most instances, it should not exceed 2-3 paragraphs.
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 motions in limine and 1 day for deliberations. For example, a 5-day trial estimate means no more than 3 days of testimony.
Trial briefs should describe the facts, remaining causes of action, parties' status, defenses, anticipated legal issues with points and authorities, and the relief claimed.
Court's wording
A trial brief should contain a brief description of the facts, remaining cause of actions, parties’ status (dismissed, defaulted, etc.), brief description of defenses, list of legal issues anticipated with points and authorities supporting and defending the issues, a brief statement of the relief claimed and
Parties should seek agreement on a joint verdict form, and any special verdict should be easy for the jury to use without unnecessary questions.
Court's wording
JOINT PROPOSED VERDICT FORM. The parties should seek to reach agreement on a joint verdict form. See, LASCR 3.25(g)(8). 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.
The joint exhibit list must list exhibits to be offered using consecutive arabic numerals. See, LASCR 3.52 and 3.53. Documentary exhibits consisting of more than one page should be internally paginated in sequential numerical order to facilitate reference to the document during interrogation of witnesses (e.g., 1-2, 1-2, 1-3). Counsel should agree in advance that their respective party will have a range of exhibit numbers, e.g., Plaintiff 1-99; Defendant 100-199.
Filing & Service rules
Electronic Filing Rules
All parties must comply with mandatory e-filing for civil cases; self-represented litigants are exempt and may file at the courthouse window.
All parties are to comply with the First Amended General Order re Mandatory Electronic Filing for Civil dated May 3, 2019. Pursuant to California Rules of Court (“CRC”), rule 2.253(b)(2), self-represented litigants are exempt from mandatory electronic filing requirements and may file papers at the filing window located on the first floor of the courthouse.
Civil cases
Page 1 | FILINGS
All parties must comply with mandatory electronic filing for civil cases per the First Amended General Order dated May 3, 2019.
FILINGS: All parties are to comply with the First Amended General Order re Mandatory Electronic Filing for Civil dated May 3, 2019.
Civil cases
Page 1 | FILINGS
Self-represented litigants are exempt from mandatory e-filing and may file papers at the first-floor filing window of the courthouse.
Pursuant to California Rules of Court (“CRC”), rule 2.253(b)(2), self-represented litigants are exempt from mandatory electronic filing requirements and may file papers at the filing window located on the first floor of the courthouse.
Civil cases
Page 1 | FILINGS
Filing Timing and Cure Windows
The case management statement must be filed at least fifteen (15) days before the CMC hearing.
A case management statement must be filed at least fifteen (15) days prior to the hearing as required by CRC 3.725(a).
Civil cases
Page 1 | CASE MANAGEMENT CONFERENCES
If any defendant remains unserved, plaintiff must file a declaration explaining service efforts five (5) days before the CMC hearing.
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. CRC 3.110.
Civil cases
Page 1 | CASE MANAGEMENT CONFERENCES
Plaintiff must file a declaration of service efforts 5 days before CMC if all defendants are not served.
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. CRC 3.110.
Civil cases
Page 1 | CASE MANAGEMENT CONFERENCES
Case management statements must be filed at least 15 days before the hearing.
A case management statement must be filed at least fifteen (15) days prior to the hearing as required by CRC 3.725(a).
Civil cases
Page 1 | CASE MANAGEMENT CONFERENCES
Ex Parte applications must be e-filed by 10:00 a.m. the day before the hearing, with courtesy copies delivered the morning of the hearing.
Ex Parte applications must be electronically filed by 10:00 a.m. on the day before the hearing. Courtesy copies must be brought for the Court on the morning of the hearing.
Civil cases
Page 1 | EX PARTES
Ex parte applications must be electronically filed by 10:00 a.m. on the day before the hearing.
Ex Parte applications must be electronically filed by 10:00 a.m. on the day before the hearing.
Civil cases
Page 1 | EX PARTES
Operative pleadings, joint witness list, joint exhibit list, and trial briefs (court trials only; trial briefs optional in jury trials) must be filed five court days before the final status conference, with plaintiff(s) responsible for filing joint documents unless the parties agree otherwise.
The following documents shall be filed five court days before the final status conference for a jury trial, except that a trial brief is optional. The parties shall file the operative pleadings, joint witness list, joint exhibit list and trial briefs for a court trial. Plaintiff(s) shall be responsible for filing joint documents unless the parties agree otherwise.
Civil cases
Page 3 | TRIAL DOCUMENTS
Counsel must comply with LASCR 3.25(f)-(h), meet and confer, and then file the final status conference documents five court days before the conference.
FINAL STATUS CONFERENCE: Counsel must comply with Los Angeles Superior Court Local Rules (“LASCR”) 3.25(f)-(h) and other local rules concerning preparation for the final status conference and trial. You must meet and confer, and then file the following documents: FIVE COURT DAYS BEFORE THE FINAL STATUS CONFERENCE.
Civil cases
Page 3 | FINAL STATUS CONFERENCE
The following documents shall be filed five court days before the final status conference for a jury trial, except that a trial brief is optional. The parties shall file the operative pleadings, joint witness list, joint exhibit list and trial briefs for a court trial.
The following documents shall be filed five court days before the final status conference for a jury trial, except that a trial brief is optional. The parties shall file the operative pleadings, joint witness list, joint exhibit list and trial briefs for a court trial.
Civil cases
Page 3 | TRIAL DOCUMENTS
Trial briefs are required for court trials, filed 5 court days before FSC; optional for jury trials.
Trial briefs are not required in jury trials but can be useful to the Court. They are required in court trials and must be filed at least five (5) court days before the FSC.
Civil cases
Page 4 | TRIAL DOCUMENTS
Trial briefs are optional in jury trials but required in court trials and must be filed at least five court days before the final status conference.
TRIAL BRIEFS. Trial briefs are not required in jury trials but can be useful to the Court. They are required in court trials and must be filed at least five (5) court days before the FSC.
Civil cases
Page 4 | TRIAL DOCUMENTS
Stipulations regarding ultimate facts, issues, and exhibit admissibility must be filed and executed on or before the time of filing trial documents.
Counsel shall file and execute stipulations, if any, regarding ultimate facts and issues and the admissibility of exhibits (i.e. foundation and/or authentication) on or before the time of filing trial documents.
Civil cases
Page 5 | STIPULATIONS
MILs and trial motions must be filed with timely statutory notice so they can be heard on the day of the final status conference.
Motions in limine (MILs) and trial motions must be filed with timely statutory notice, so as to be heard on the day of the final status conference. See LASCR 3.25(f)(2).
Civil cases
Page 5 | MOTIONS IN LIMINE/TRIAL MOTIONS
Requests for more than 35 jurors or for pre-screening jurors as to time must be made to the Court at least 20 days before the trial date.
In most cases, a panel of 35 jurors will be ordered to begin the jury selection process. Any request for more than 35 jurors or for pre-screening of jurors as to time must be made to the Court at least 20 days in advance of the trial date.
Civil cases
Page 6 | JURY SELECTION
Requests for >35 jurors or jury pre-screening must be made 20 days before trial.
Any request for more than 35 jurors or for pre-screening of jurors as to time must be made to the Court at least 20 days in advance of the trial date.
Civil cases
Page 6 | JURY SELECTION
If no court reporter is present, counsel must provide the court a daily joint summary of testimony and admitted evidence by the morning following the testimony.
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.
Civil cases
Page 6 | COURT REPORTERS
Proof of payment of daily jury fees must be provided to the clerk by the next day or trial cannot resume.
Proof of payment must be provided to the clerk no later than the next day before trial can resume.
Civil cases
Page 6 | JURY SELECTION
Copies of deposition transcripts or other discovery responses must be lodged with the Court before trial.
Before trial, copies of deposition transcripts or other discovery responses shall be lodged with the Court. (LASCR 3.56)
Civil cases
Page 7 | READING FROM DISCOVERY RESPONSES/DEPOSITION TRANSCRIPTS
Objections to PowerPoint slides must be submitted to the court as soon as possible and before the jury is empaneled.
If there are any objections to any slide, the objecting party must submit the objections to the court as soon as possible and before the jury is empaneled.
Civil cases
Page 8 | REFERENCE TO EVIDENCE
A copy of the PowerPoint slides must be lodged with the court.
A copy of the slides must be lodged with the court.
Civil cases
Page 8 | REFERENCE TO EVIDENCE
The joint brief summarizing the discovery dispute(s) must be filed and provided to the Court at least three court days before the hearing.
Third, a joint brief – no more than five-pages in length that summarizes the discovery dispute(s) at issue – shall be filed and provided to the Court at least three court days prior to the hearing.
Civil cases
Page 9 | DEPARTMENT P
The IDC standing order does not extend the deadline for bringing a motion to compel further responses, although the parties are encouraged (but not required) to reach a written stipulation on that timing.
Fifth, this order does not extend the time within which a motion to compel furthers must be brought. The parties, however, are encouraged to reach a written stipulation relating thereto, although such an agreement is not mandated by this order.
Civil cases
Page 9 | DEPARTMENT P
Service and Proof of Service Rules
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 | CASE MANAGEMENT CONFERENCES
All defendants must be served with the complaint by the date of the case management conference.
All defendants must be served with the complaint by the case management conference.
Civil cases
Page 1 | CASE MANAGEMENT CONFERENCES
Papers must be served to reach parties by the date specified in the order; parties are encouraged to agree on e-mail, fax, or overnight delivery.
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 of service, e.g., by e-mail, fax, or overnight delivery
Civil cases
Page 2 | SERVICE OF PAPERS
Papers required to be served under this order must be served so as to reach the other party no later than the date indicated, with the parties encouraged to agree on the service method (e.g., e-mail, fax, or overnight delivery).
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 of service, e.g., by e-mail, fax, or overnight delivery
Civil cases
Page 2 | SERVICE OF PAPERS
At the end of each court day, counsel must notify opposing counsel of the witnesses to be called the next day and the order of testimony.
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)
Civil cases
Page 7 | WITNESSES
Exhibits and demonstrative evidence may not be referenced at trial unless opposing counsel first had an opportunity to review them and assert objections.
No exhibit or demonstrative evidence shall be referred to at trial without opposing counsel having had the opportunity to review and assert any objections. (LASCR 3.150)
Civil cases
Page 7 | REFERENCE TO EVIDENCE
Before reading a deposition, interrogatory, or request for admission into evidence, counsel must advise the Court and opposing counsel of the specific page, line, or numbers to be read or shown.
Before reading into evidence any portion of a deposition, interrogatory or request for admission, counsel shall advise the Court and opposing counsel of the page and the line of the deposition or the numbers of the interrogatories or requests for admission to be read or shown to the witness. (LASCR 3.158)
Civil cases
Page 7 | READING FROM DISCOVERY RESPONSES/DEPOSITION TRANSCRIPTS
Visual aids may not be used in opening statement unless opposing counsel was first given the opportunity to review them prior to trial.
No visual aids shall be used in opening statement without opposing counsel first having been given the opportunity to review the visual aids prior to trial. (LASCR 3.97)
Civil cases
Page 8 | REFERENCE TO EVIDENCE
Counsel intending to use PowerPoint must inform the Court at the FSC and share a copy of the slides with opposing counsel before the presentation.
If counsel intends to use PowerPoint, the Court shall be informed at the FSC and a copy of the slides must be shared with opposing counsel prior to the presentation.
Civil cases
Page 8 | REFERENCE TO EVIDENCE
Before questioning about potentially inflammatory or highly prejudicial evidence, counsel should flag the intended area of inquiry to opposing counsel and the Court outside the jury's presence.
Before inquiring into evidence that may reasonably be anticipated to be inflammatory or highly prejudicial, and potentially excludable pursuant to Evidence Code section 352, counsel should bring the intended area of inquiry to the attention of opposing counsel and the Court outside the presence of the jury. (LASCR 3.107)
Civil cases
Page 8 | HIGHLY PREJUDICIAL EVIDENCE
The moving party must provide notice of this Standing Order.
Moving Party is ordered to provide notice of this Standing Order.
Civil cases
Page 10 | DEPARTMENT P
Filing Fees and Waivers
Parties must pay daily jury fees; proof of payment must be provided to the clerk by the next day before trial resumes.
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 6 | COURT REPORTERS
Counsel will be billed daily jury fees during trial.
Counsel will be billed daily jury fees.
Civil cases
Page 6 | JURY SELECTION
Courtesy Copy Requirements
Other than for Motions in Limine (discussed below), no courtesy copies are required.
Other than for Motions in Limine (discussed below), no courtesy copies are required.
Civil cases
Page 1 | FILINGS
Ex Parte applications require courtesy copies delivered to the court on the morning of the hearing.
Courtesy copies must be brought for the Court on the morning of the hearing.
Civil cases
Page 1 | EX PARTES
Courtesy copies of ex parte applications must be brought to the Court on the morning of the hearing.
Courtesy copies must be brought for the Court on the morning of the hearing.
Civil cases
Page 1 | EX PARTES
These binders should be provided to the court five court days prior to the Final Status Conference.
These binders should be provided to the court five court days prior to the Final Status Conference.
Civil cases
Page 2 | FINAL STATUS CONFERENCES
On or before the first day of trial, counsel must bring three exhibit binders, copies of all trial documents, and an electronic version (Word format on USB/CD or emailed) of the joint witness list, exhibit list, jury instructions, and verdict forms to Department P.
On or before the first day of trial, counsel shall bring three Exhibit binders (discussed below) to Department P. In addition, Counsel shall bring to Department P copies of all trial documents and an electronic version of the joint witness list, exhibit list, jury instructions, and verdict forms on a thumb/USB drive or CD disk with the documents in Microsoft Word format or compatible format. In the alternative, Counsel may email those documents directly to Department P.
Civil cases
Page 3 | FINAL STATUS CONFERENCE
Courtesy copies of all trial documents must be lodged in Department P five court days before the final status conference in joint three-ring binders, tabbed with an index in front.
Counsel must also lodge courtesy copies of all trial documents in Department P five court days before the final status conference, placed in JOINT three ring binders. Each document shall be tabbed, with an index provided in the front of each binder.
Civil cases
Page 3 | FINAL STATUS CONFERENCE
Three sets of exhibit binders must be lodged on or before the day of trial, each with an exhibit list index in front, divider tabs numbered by exhibit, case name/number labels, and each binder labeled 'Judicial Assistant,' 'Judge' or 'Witness.'
On or before the day of trial, the parties shall lodge three (3) sets of exhibit binders, with an exhibit list in the front of each binder to serve as an index, and with divider tabs numbered by exhibit. The binders should be labeled with the name and case number for the case, and each binder shall be labeled “Judicial Assistant,” “Judge” or “Witness.”
Civil cases
Page 4 | TRIAL DOCUMENTS
The documents must be tabbed and indexed with the courtesy copy delivered to the Court five court days before the final status conference.
The documents must be tabbed and indexed with the courtesy copy delivered to the Court five court days before the final status conference.
Civil cases
Page 5 | MOTIONS IN LIMINE/TRIAL MOTIONS
Because the Court often rules on ex partes without oral argument, oppositions should be timely delivered to Department P.
The Court often rules without oral argument so any oppositions should be timely delivered to Department P.
Civil cases
Page 1 | EX PARTES
No courtesy copies are required except for Motions in Limine.
Other than for Motions in Limine (discussed below), no courtesy copies are required.
Civil cases
Page 1 | FILINGS
Party with most MILs must deliver a tabbed, indexed binder of all MIL filings to the court five court days before the final status conference.
The party filing the most motions in limine (or Plaintiff if the number of motions in limine filed by each side is equal) is to create binders of ALL MILs, including moving papers, opposition and reply briefs. These binders should be provided to the court five court days prior to the Final Status Conference. The party filing the most MILs must assemble the MILs into a binder for the Court containing: (1) the MIL; (2) opposition to the MIL; and (3) any reply. The documents must be tabbed and indexed with the courtesy copy delivered to the Court five court days before the final status conference.
Civil cases
Page 2 | MOTIONS IN LIMINE/TRIAL MOTIONS
Three exhibit binders must be delivered to Department P on or before the first day of trial, labeled and tabbed by exhibit number.
On or before the first day of trial, counsel shall bring three Exhibit binders (discussed below) to Department P. On or before the day of trial, the parties shall lodge three (3) sets of exhibit binders, with an exhibit list in the front of each binder to serve as an index, and with divider tabs numbered by exhibit. The binders should be labeled with the name and case number for the case, and each binder shall be labeled “Judicial Assistant,” “Judge” or “Witness.”
Civil cases
Page 3 | FINAL STATUS CONFERENCE
Filing Bundling Requirements
For the Final Status Conference, the party filing the most motions in limine (or Plaintiff if equal) must create binders of all MILs, including moving papers, opposition, and reply briefs.
The party filing the most motions in limine (or Plaintiff if the number of motions in limine filed by each side is equal) is to create binders of ALL MILs, including moving papers, opposition and reply briefs.
Civil cases
Page 2 | FINAL STATUS CONFERENCES
Trial documents for FSC must be bundled in joint three-ring binders, tabbed with an index, lodged 5 court days before FSC.
Counsel must also lodge courtesy copies of all trial documents in Department P five court days before the final status conference, placed in JOINT three ring binders. Each document shall be tabbed, with an index provided in the front of each binder.
Civil cases
Page 3 | FINAL STATUS CONFERENCE
The party filing the most MILs must assemble all MILs, oppositions, and replies into a single binder for the Court.
The party filing the most MILs must assemble the MILs into a binder for the Court containing: (1) the MIL; (2) opposition to the MIL; and (3) any reply.
Civil cases
Page 5 | MOTIONS IN LIMINE/TRIAL MOTIONS
Pre-Motion Conference Requirements
Lead counsel or other designated counsel with full authority must appear at any scheduled IDC, and IDC sessions are informal and may not be transcribed without prior Court approval.
Fourth, lead counsel (or other designated counsel for the parties with full authority) are ordered to appear for any scheduled IDC as directed by the Court. IDC sessions are informal and shall not be transcribed without prior Court approval.
Civil cases
Page 9 | DEPARTMENT P
Before any Motion to Compel Further Responses can be set for hearing, all parties must participate in an Informal Discovery Conference, which the moving party schedules by obtaining three available Monday or Friday dates at 10:00 a.m., contacting the Court, and giving notice.
The Court has the power to "amend and control its process and orders so as to make them conform to law and justice" pursuant to CCP § 128(a)(8), and therefore, the Court issues the following standing order requiring all parties to participate in an IDC to resolve any Motion to Compel Furthers. First, prior to any Motion to Compel Further Responses being set for hearing by the Court, the moving party shall confer with opposing counsel and obtain three available dates on either a Monday or a Friday for an IDC at 10:00 a.m. and then contact the Court to schedule the IDC. Moving party shall also give notice.
Civil cases
Page 9 | DEPARTMENT P
Counsel must meet and confer by telephone or video conference before the IDC to attempt to resolve all pending discovery disputes, in addition to the statutory meet and confer requirements, and should track when and how long they met.
Second, prior to the IDC, counsel must meet and confer, via telephone or video conference, in an effort to resolve all pending discovery disputes. Counsel are advised to keep track of when and for how long counsel met and conferred. This meet and confer is in addition to the standard meet and confer requirements set forth in the Code.
Civil cases
Page 9 | DEPARTMENT P
Filed motions to compel further responses will not receive a hearing date until the IDC process is completed.
The filed motions to compel further will not receive a hearing date until the IDC process is completed.
Civil cases
Page 9 | DEPARTMENT P
Motions to Compel Further require an Informal Discovery Conference (IDC) with meet and confer, joint brief (max 5 pages) filed 3 court days prior, and lead counsel appearance.
Prior to any Motion to Compel Further Responses being set for hearing by the Court, the moving party shall confer with opposing counsel and obtain three available dates on either a Monday or a Friday for an IDC at 10:00 a.m. and then contact the Court to schedule the IDC. Second, prior to the IDC, counsel must meet and confer, via telephone or video conference, in an effort to resolve all pending discovery disputes. Third, a joint brief – no more than five-pages in length that summarizes the discovery dispute(s) at issue – shall be filed and provided to the Court at least three court days prior to the hearing. Fourth, lead counsel (or other designated counsel for the parties with full authority) are ordered to appear for any scheduled IDC as directed by the Court.
Civil cases
Page 9 | DISCOVERY MOTIONS
If the discovery disputes are resolved before the IDC date, the moving party must notify the Court and take both the IDC and the underlying Motion to Compel Furthers off the hearing dates.
If the parties resolve their discovery disputes before the IDC date, Moving Party shall notify the Court and take both the IDC and any underlying Motion to Compel Furthers off hearing dates for any remaining motions to compel further.
Civil cases
Page 9 | DEPARTMENT P
Adjournment & Extension Requirements
Continuances will not be granted because witnesses fail to timely appear; trial proceeds without them, though the Court may accommodate scheduling needs of experts, professionals, and out-of-state witnesses.
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 7 | WITNESSES
Moving parties may continue motion hearing dates to the next available date without leave of court, and motion hearing dates must be reserved on the Court Reservation System.
Motion hearing dates must be reserved on the Court Reservation System and can be continued to the next available date by the moving party, without need for leave of court.
Civil cases
Page 1 | CONTINUANCES
Hearings, conferences, and trial dates may be continued via stipulation and proposed order filed on eCourt; absent stipulation, the continuance may be pursued at a CMC or by ex parte application upon good cause.
All hearings and conference dates, including trial dates, may be considered for continuance via stipulation and proposed order (filed on eCourt). If there is no stipulation, the requested continuance may be discussed at a Case Management Conference or via ex parte application, if there is good cause for the requested relief.
Civil cases
Page 1 | CONTINUANCES
Chambers Communication Rules
Contact the courtroom at 310-255-1877 for remote appearance connection issues.
If you are having trouble connecting or have a poor connection, please contact the courtroom at (310) 255-
Civil cases
Page 1 | REMOTE APPEARANCES
For remote appearance connection problems, parties should call the courtroom at (310) 255-1877.
LACourtConnect is available for remote appearances. If you are having trouble connecting or have a poor connection, please contact the courtroom at (310) 255-
Civil cases
Page 1 | REMOTE APPEARANCES
Courtroom hours are 8:30 AM to 12:00 PM and 1:30 PM to 4:30 PM.
Courtroom Hours: 8:30-12; 1:30-4:30
Civil cases
Page 1 | Header