Judge Dean J. Kitchens
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- 4 copies
Exhibits
- 5 copies • First Day of Trial
Binding: Three Ring Binder
Communication
Chambers
Phone
Chambers
Page & Word Limits1 rule
The informal discovery conference statement is limited to two pages, and the page limit will be strictly enforced.
- Page limit
- Up to 2 pages
- Discovery dispute statement
Court's wording
At least five (5) court days before the conference, each party to the dispute will be required to efile with the court a statement, of no more than two (2) pages, summarizing the dispute. The page limit will be strictly enforced.
Document Format Requirements5 rules
Exhibits should be numbered. Counsel should agree in advance that their respective party will have a range of exhibit numbers, i.e., plaintiff 1-99; defendant 100-199. Each exhibit must be separately identified. Subparts to an exhibit, i.e., 1A, 1B, etc., must also be identified and listed separately.
Bulk exhibits, e.g., voluminous medical records, will not be permitted. Counsel must separately mark and identify the specific items within a bulk exhibit.
All instructions must be submitted on perforated paper forms.
- File type
- Paper
- Jury instructions
exhibit must be consecutively paginated.
Blow-ups of portions of exhibits should be identified and marked as sub-part A.
Document Filing Requirements5 rules
No exhibits may be attached.
All parties to a motion must place the reservation number associated with the motion on each document associated with that motion.
Each party must prepare an exhibit list in the form attached hereto.
If counsel plan to admit media such as video or audio tapes, counsel must raise the issue at the final status conference.
Should the parties not provide a court reporter, the parties will be required to provide a joint summary of the testimony and evidence admitted each day for the court's use in preparing a settled statement for appeal purposes.
Filing & Service rules
Electronic Filing Rules
Each party to a discovery dispute must efile a statement summarizing the dispute at least five court days before the informal discovery conference.
At least five (5) court days before the conference, each party to the dispute will be required to efile with the court a statement, of no more than two (2) pages, summarizing the dispute.
Page 2 | DISCOVERY MOTIONS
Filing Timing and Cure Windows
A case management statement must be filed at least 15 days before the case management conference hearing.
A case management statement must be filed at least fifteen (15) days prior to the hearing as required by CRC 3.725(a).
Page 1 | PRE-TRIAL INFORMATION
If all defendants have not been served, plaintiff must file a declaration five days before the hearing explaining the service efforts undertaken.
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.
Page 1 | PRE-TRIAL INFORMATION
In a demurrer, the plaintiff or cross-complainant must immediately notify the court if a first amended complaint will be filed in lieu of an opposition.
In the case of a demurrer to a complaint or cross-complaint, the plaintiff or cross- complainant must notify the court immediately if they will be filing a first amended complaint in lieu of an opposition.
Page 2 | MOTIONS
Trial documents (statement of case, exhibit list, witness list, jury instructions, verdict form) must be filed with the court five days before the final status conference.
Pursuant to SCLAC Rule 3.25(f)(1), trial documents, including a statement of the case, exhibit list, witness list, jury instructions and verdict form must be filed with the court and served on opposing counsel five (5) days prior to the final status conference.
Page 3 | Final Status Conference
Motions in limine must be filed with the required statutory notice for hearing at the final status conference and must comply with SCLAC Rule 3.57.
Pursuant to SCLAC Rule 3.25(f)(2), motions in limine must be filed with the appropriate statutory notice for hearing at the final status conference. Motions in limine must comply with SCLAC Rule 3.57.
Page 3 | Final Status Conference
Objections to the court's jury questionnaire questions and requests for additional questions must be made in writing by the time of the Final Status Conference.
Any objections to the court's questions or requests for additional questions must be made to the court, in writing, by the time of the Final Status Conference.
Page 4 | Jury Selection
Proof of payment must be provided to the clerk no later than the next day before trial can resume.
Proof of payment must be provided to the clerk no later than the next day before trial can resume.
Page 4 | Jury Selection
Requests for more than 35 jurors or for prescreening jurors as to time must be made to the court at least 20 days before the trial date.
Any request for more than 35 jurors or for prescreening of jurors as to time must be made to the court at least 20 days in advance of the trial date.
Page 4 | Jury Selection
Ex parte applications are heard Monday through Friday at 8:30 a.m. and must comply with CRC 3.1200 et seq.
Ex parte applications are heard Monday through Friday at 8:30 a.m. and must comply with California Rule of Court 3.1200 et. seq.
Page 1 | PRE-TRIAL INFORMATION
Participating in an informal discovery conference does not automatically extend the deadline to file a motion to compel; the parties may stipulate to an extension.
If the parties elect to participate in an informal discovery conference, it will not automatically extend the time in which a motion to compel must be filed. The parties may stipulate to extend the deadline.
Page 2 | DISCOVERY MOTIONS
Counsel are urged to agree on a special verdict form to be submitted with the other trial documents five days before the final status conference; otherwise the Court will prepare a general verdict form.
Counsel are urged to agree upon a special verdict form to be submitted to the court with the other trial documents five (5) days prior to the final status conference. If counsel cannot agree, the Court will prepare a general verdict form.
Page 5 | Jury Instructions
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.
Page 1 | PRE-TRIAL INFORMATION
Trial documents must be served on opposing counsel five days prior to the final status conference.
Pursuant to SCLAC Rule 3.25(f)(1), trial documents, including a statement of the case, exhibit list, witness list, jury instructions and verdict form must be filed with the court and served on opposing counsel five (5) days prior to the final status conference.
Page 3 | Final Status Conference
Filing Fees and Waivers
Jury fees must be posted by the time of the case management conference.
Jury fees must be posted by the time of the case management conference pursuant to CCP Section 631.
Page 1 | PRE-TRIAL INFORMATION
Counsel will be billed daily jury fees.
Counsel will be billed daily jury fees.
Page 4 | Jury Selection
Courtesy Copy Requirements
Additional exhibit binders must be provided for the Court, the witness, opposing counsel, and counsel.
Additional binders must be provided for: (1) the Court; (2) the witness; (3) opposing counsel; and (4) yourself.
Page 5 | Exhibits
Typically, at least five copies of all exhibits in a 3-ring binder should be provided on the first day of trial.
Typically, at least five (5) copies of all exhibits, in a 3-ring binder, should be provided on the first day of trial.
Page 5 | Exhibits
Sealing & Redaction Procedures
Counsel must comply with the sealing requirements of CRC 2.550 and 2.551 or the submission may be rejected and related hearings delayed.
Counsel must familiarize themselves with the requirements for sealing documents pursuant to CRC 2.550 and 2.551. Failure to comply with the CRC may result in rejection of the submission and delay any hearing related to the sealed documents.
Page 2 | MOTIONS
Pre-Motion Conference Requirements
Counsel must reserve a hearing date through the court reservation system for any motion; motions are heard Monday through Friday at 8:30 a.m.
You must reserve a hearing date for any motion through the court reservation system. The court hears motions Monday through Friday at 8:30 am.
Page 2 | MOTIONS
The court strongly encourages an informal discovery conference before filing a motion to compel; contact the court to schedule one (typically Mondays at 1:30, in person or by LACourtConnect).
The court strongly encourages parties to engage in an informal discovery conference prior to filing a motion to compel. In many instances such a conference may efficiently obviate a discovery motion (or at least narrow the issues). Contact the court to schedule an informal discovery conference, which may be attended in person or by LACourtConnect. Informal discovery conferences are typically held on Mondays at 1:30.
Page 2 | DISCOVERY MOTIONS
Adjournment & Extension Requirements
Trial continuance requests must be made by noticed motion or, when appropriate, ex parte application.
Requests for trial continuances must be made by noticed motion or ex parte application when appropriate.
Page 1 | PRE-TRIAL INFORMATION
The moving party must immediately notify the court if a motion is going off-calendar or being continued, and must remove it from the court reservation management system if taken off calendar.
Pursuant to CRC 3.1304(b), the moving party on a motion must notify the court immediately if the motion is going off-calendar or is being continued. If the motion is taken off calendar, please be sure to remove the motion from the court reservation management system.
Page 2 | MOTIONS
Chambers Communication Rules
Counsel wishing to submit on a Tentative Ruling should email the courtroom at smcdept400@lacourt.ca.gov.
In matters for which a Tentative Ruling is provided, counsel wishing to submit on the Tentative should email the courtroom at smcdept400@lacourt.ca.gov.
Page 2 | MOTIONS
Counsel are expected to arrive promptly each morning at the time designated by the court the night before. Any anticipated disputes or evidentiary issues should be raised with the court as soon as counsel arrive in the morning.
Counsel are expected to arrive promptly each morning at the time designated by the court the night before. Any anticipated disputes or evidentiary issues should be raised with the court as soon as counsel arrive in the morning.
Page 5 | Courtroom Decorum
Department 400's courtroom telephone number is (213) 633-0150.
TELEPHONE NUMBER: (213) 633-0150
Page 1 | COURTROOM INFORMATION