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Court Rules
Judge

Judge Edward B. Moreton Jr.

Individual Rules, Standing Orders & Policies

Los Angeles Superior Court

Limits & Logistics

Document Limits

Joint Statement of Issues
5 pgs
Joint Statement IDC
5 pgs

Courtesy Copies

Exhibits

  • 1 copy • At Final Status Conference

Filings >= 26 pages

Motion in Limine

Motion, Opposition, Reply

Communication

Phone

Chambers

310-281-2425
Hours: 8:30-12, 1:30-4:30
Filters:

Page & Word Limits2 rules

Page LimitsMandatory

Five court days prior to the IDC, the parties are to file (on eCourt) a joint statement of issues to be covered at the IDC, not to exceed five (5) pages.

Joint statement of issues
Up to 5 pages
Ca Lasc Courtroom BH 205 · p. 5
|Section10. Discovery Motions
Page LimitsMandatory

Five court days prior to the IDC, the parties are to file (on eCourt) a joint statement of issues to be covered at the IDC, not to exceed five (5) pages.

Joint statement IDC
Up to 5 pages
Ca Lasc Courtroom BH 205 · p. 5
|Section10. Discovery Motions

Document Format Requirements7 rules

FormattingMandatory

Motions to compel further responses require a four-column joint statement with specified columns.

Court's wording

In the event a motion to compel further responses is filed, the parties are required to submit a JOINT STATEMENT consisting of a four-column document set up as follows: The first column will identify the number of the discovery request; the second, the text of the discovery request; the third, the text of the response; and the fourth, brief bullet-point statements, one from each party, as to why a further response should or should not be compelled.

Ca Lasc Courtroom BH 205 · p. 5
|Section10. Discovery Motions
FormattingMandatory

Parties must attach copies of the designated or counter-designated transcript pages to the joint chart, with numbered tabs separating each deposition or trial transcript.

Court's wording

The parties shall attach copies of the pages of the transcripts of the deposition or former testimony they are designating or counter-designating to the Joint Chart of Page and Line Designations for Deposition and Former Testimony, with numbered tabs separating each deposition or trial transcript.

Ca Lasc Courtroom BH 205 · p. 11
|SectionTrial Preparation Order
FormattingMandatory

The proposed jury 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.

Ca Lasc Courtroom BH 205 · p. 18
|SectionF. Jury Instructions (Joint and Contested)
FormattingMandatory

The Motions in Limine Binder must contain one-sided conformed copies of all motions in limine, opposition, and reply papers in tabbed three-ring binders with colored separator sheets.

Binding
Three-ring binder
Applies to
  • Motions in limine binder

Formatting

  • Tabbed in numerical order

Court's wording

The Motions in Limine Binder shall include one-sided, 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.

Ca Lasc Courtroom BH 205 · p. 21
|SectionTRIAL PREPARATION ORDER - Motions in Limine
FormattingImportant

Each designation or counter-designation shall be highlighted, with each party using a different color highlighter.

Ca Lasc Courtroom BH 205 · p. 11
|SectionTrial Preparation Order
FormattingImportant

Copies of documentary exhibits shall be one-sided copies.

Ca Lasc Courtroom BH 205 · p. 21
|SectionTRIAL PREPARATION ORDER - 4. Exhibit Binders
FormattingMandatory

Parties must attach the designated transcript pages to the joint chart with numbered tabs separating each deposition, using a different color highlighter for each deposition.

Applies to
  • Joint chart of page and line designations

Formatting

  • Numbered tabs must separate each deposition

Court's wording

The parties shall attach copies of the pages of the transcripts of the deposition or former testimony they are designating or counter-designating to the Joint Chart of Page and Line Designations for Deposition and Former Testimony, with numbered tabs separating each deposition using a different color highlighter.

Ca Lasc Courtroom BH 205 · p. 19
|SectionH. Joint Chart of Page and Line Designations for Deposition and Former Testimony

Document Filing Requirements32 rules

Filing RequirementsMandatory

Ex parte applications must comply with the requirements of California Rules of Court, rules 3.1200-3.1207.

Ca Lasc Courtroom BH 205 · p. 4
|Section8. Ex Parte Applications
Filing RequirementsMandatory

Motions to compel further responses must be accompanied by a joint statement in a four-column format (request number, request text, response text, and brief bullet points from each party).

Court's wording

In the event a motion to compel further responses is filed, the parties are required to submit a JOINT STATEMENT consisting of a four-column document set up as follows: The first column will identify the number of the discovery request; the second, the text of the discovery request; the third, the text of the response; and the fourth, brief bullet-point statements, one from each party, as to why a further response should or should not be compelled.

Ca Lasc Courtroom BH 205 · p. 5
|Section10. Discovery Motions
Filing RequirementsMandatory

prepare and submit the documents and binders required by that order.

Ca Lasc Courtroom BH 205 · p. 6
|Section11. Trial Preparation Order
Filing RequirementsMandatory

(1) discuss and prepare the documents required in Sections 2.B-D, below, and the Motions in Limine Binder, Exhibit Binders, and Trial Binder required in Sections 3-5, below,

Ca Lasc Courtroom BH 205 · p. 8
|Section1. MEET AND CONFER
Filing RequirementsMandatory

Any witness who is not included on the joint witness list is subject to being excluded from testifying at [...] seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the court.

Ca Lasc Courtroom BH 205 · p. 9
|SectionTRIAL PREPARATION ORDER - 2. TRIAL DOCUMENTS TO BE FILED - B. JOINT WITNESS LIST
Filing RequirementsMandatory

Counsel and self-represented parties must jointly prepare and file a witness list (excluding impeachment and rebuttal witnesses) in a prescribed column format with time estimates and a grand total.

Court's wording

The parties’ counsel and any self-represented parties shall work together to prepare and file a joint 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 with columns (in the format set forth below) which state (1) the name of each witness (in alphabetical order), if 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 hours), (6) an estimate of the length of cross-examination (in hours), and (7) the total estimated length of examination (in hours). At the end of the joint witness list, the parties and any self-represented parties shall add up the estimated times for all witnesses’ testimony and state the grand total in the last column.

Ca Lasc Courtroom BH 205 · p. 9
|SectionTRIAL PREPARATION ORDER - 2. TRIAL DOCUMENTS TO BE FILED - B. JOINT WITNESS LIST
Filing RequirementsMandatory

Counsel and self-represented parties must jointly prepare and file an exhibit list in a prescribed column format and must meet and confer to resolve authentication and admissibility objections.

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 (in the format set forth below) 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).) As set forth above, the parties’ counsel and any self-represented parties shall meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit.

Ca Lasc Courtroom BH 205 · p. 10
|SectionTRIAL PREPARATION ORDER - 2. TRIAL DOCUMENTS TO BE FILED - C. JOINT EXHIBIT LIST
Filing RequirementsMandatory

Each counter-designating party's counter-designations in the joint chart must include six columns: witness number/name, date/type of testimony, page:line counter-designations, objections, the related designation number, and the court's ruling.

Court's wording

In the joint chart, each counter-designating party’s counter-designations of additional deposition or former testimony of the witness that relates to the designations 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 counter-designations of the deposition or former testimony requested to be used, (4) any objections, (5) the designation number of the other party’s designation to which the counter-designation relates, and (6) the court’s ruling.

Ca Lasc Courtroom BH 205 · p. 11
|SectionTrial Preparation Order
Filing RequirementsMandatory

Each designating party's designations in the joint chart must include six columns: witness number/name, date/type of testimony, page:line designations, objections, counter-designation information, and the court's ruling.

Court's wording

In the joint chart, each designating party’s 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 deposition or former testimony requested to be used, (4) any objections, (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, and (6) the court’s ruling.

Ca Lasc Courtroom BH 205 · p. 11
|SectionTrial Preparation Order
Filing RequirementsMandatory

Parties intending to use deposition or former trial testimony must meet and confer and jointly prepare and file a Joint Chart of Page and Line Designations for Deposition and Former Testimony.

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 in the format set forth below (“Joint Chart of Page and Line Designations for Deposition and Former Testimony”).

Ca Lasc Courtroom BH 205 · p. 11
|SectionTrial Preparation Order
Filing RequirementsMandatory

Motions in limine must be noticed for hearing at the Final Status Conference, with CCP § 1005 notice and declarations complying with Los Angeles County Court Rule 3.57(a).

Court's wording

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 Los Angeles County Court Rule 3.57, subdivision (a).

Ca Lasc Courtroom BH 205 · p. 13
|SectionMotions in Limine
Filing RequirementsMandatory

Tab A: Trial Briefs (Optional. If no trial briefs are filed, leave Tab A empty.) Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab E: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).

Document
Trial binder

Include

  • Exhibit list
Ca Lasc Courtroom BH 205 · p. 14
|Section5. TRIAL BINDER
Filing RequirementsMandatory

The parties must jointly prepare and file a joint witness list (excluding impeachment and rebuttal witnesses) with specified columns and a grand total of estimated testimony times, and any witness not included on the list is subject to being excluded from testifying at trial.

Court's wording

The parties’ counsel and any self-represented parties shall work together to prepare and file a joint 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 with columns (in the format set forth below) which state (1) the name of each witness (in alphabetical order), if 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 hours), (6) an estimate of the length of cross-examination (in hours), and (7) the total estimated length of examination (in hours). At the end of the joint witness list, the parties and any self-represented parties shall add up the estimated times for all witnesses’ testimony and state the grand total in the last column. Any witness who is not included on the joint witness list is subject to being excluded from testifying at

Ca Lasc Courtroom BH 205 · p. 16
|Section2.B. JOINT WITNESS LIST
Filing RequirementsMandatory

Counsel and self-represented parties must jointly prepare and file a joint exhibit list stating eight specified items for each trial exhibit.

Document
Joint exhibit list

Must include

  • Exhibit list

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 (in the format set forth below) 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).)

Ca Lasc Courtroom BH 205 · p. 17
|SectionC. Joint Exhibit List
Filing RequirementsMandatory

seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the court.

Ca Lasc Courtroom BH 205 · p. 17
|SectionJoint Witness List
Filing RequirementsMandatory

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).)

Ca Lasc Courtroom BH 205 · p. 18
|SectionD. Joint Statement to Be Read to the Jury
Filing RequirementsMandatory

For jury trials, the parties must jointly prepare a complete set of full-text proposed jury instructions with CACI instructions edited, party names inserted, and blanks and inapplicable material eliminated.

Court's wording

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.

Ca Lasc Courtroom BH 205 · p. 18
|SectionF. Jury Instructions (Joint and Contested)
Filing RequirementsMandatory

For jury trials, counsel and self-represented parties must jointly prepare and file a joint list of proposed jury instructions stating six specified items for each instruction.

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 (in the format set forth below) 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 (“Joint List of Proposed Jury Instructions”).

Ca Lasc Courtroom BH 205 · p. 18
|SectionE. Joint List of Proposed Jury Instructions (Joint and Contested)
Filing RequirementsMandatory

In jury trials, the parties must jointly prepare and file a proposed verdict form, and if they cannot agree, each party must file a separate proposed verdict form.

Court's wording

For jury trials, the parties’ counsel and any self-represented parties shall 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.

Ca Lasc Courtroom BH 205 · p. 19
|SectionTrial Preparation Order
Filing RequirementsMandatory

Motions in limine must comply with CCP section 1005 notice provisions and include declarations complying with Los Angeles County Court Rule 3.57(a).

Court's wording

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 Los Angeles County Court Rule 3.57, subdivision (a).

Ca Lasc Courtroom BH 205 · p. 21
|SectionTRIAL PREPARATION ORDER - Motions in Limine
Filing RequirementsMandatory

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
Ca Lasc Courtroom BH 205 · p. 21
|SectionTRIAL PREPARATION ORDER - Motions in Limine
Filing RequirementsMandatory

The parties shall organize proposed jury instructions into groups behind Tab F 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.

Ca Lasc Courtroom BH 205 · p. 22
|SectionTRIAL PREPARATION ORDER - 5. Trial Binder
Filing RequirementsMandatory

Tab A: Trial Briefs (Optional. If no trial briefs are filed, leave Tab A empty.) Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Statement to Be Read to the Jury Tab E: Joint List of Jury Instructions Tab F: Joint and Contested Jury Instructions Tab G: Joint or Contested Verdict Form(s) Tab H: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab I: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).

Document
Trial binder

Include

  • Exhibit list
Ca Lasc Courtroom BH 205 · p. 22
|SectionTRIAL PREPARATION ORDER - 5. Trial Binder
Filing RequirementsImportant

Parties filing more than one motion in limine shall number them consecutively. Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.

Ca Lasc Courtroom BH 205 · p. 13
|SectionMotions in Limine
Filing RequirementsImportant

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
Ca Lasc Courtroom BH 205 · p. 13
|SectionMotions in Limine
Filing RequirementsImportant

The parties’ counsel and any self-represented parties shall also place the court’s yellow evidence tags (with only the case number and exhibit number filled in) on each exhibit in the Judicial

Ca Lasc Courtroom BH 205 · p. 13
|Section4. EXHIBIT BINDERS
Filing RequirementsImportant

If there is an appropriate CACI jury instruction on a point of law, the court expects the parties to request the CACI instruction instead of a specially prepared jury instruction.

Ca Lasc Courtroom BH 205 · p. 18
|SectionF. Jury Instructions (Joint and Contested)
Filing RequirementsImportant

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.

Document
Special verdict form

Include

  • CACI special verdict form
Ca Lasc Courtroom BH 205 · p. 19
|SectionTrial Preparation Order
Filing RequirementsImportant

Parties filing more than one motion in limine shall number them consecutively.

Ca Lasc Courtroom BH 205 · p. 21
|SectionTRIAL PREPARATION ORDER - Motions in Limine
Filing RequirementsImportant

The parties’ counsel and any self-represented parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the Exhibit Binders.

Ca Lasc Courtroom BH 205 · p. 21
|SectionTRIAL PREPARATION ORDER - 4. Exhibit Binders
Filing RequirementsImportant

The parties’ counsel and any self-represented parties shall also place the court’s yellow evidence tags (with only the case number and exhibit number filled in) on each exhibit in the Judicial Assistant’s copy of the Exhibit Binder.

Ca Lasc Courtroom BH 205 · p. 21
|SectionTRIAL PREPARATION ORDER - 4. Exhibit Binders
Filing RequirementsNote

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.

Document
Trial brief

Include

  • Legal argument
Ca Lasc Courtroom BH 205 · p. 9
|SectionTRIAL PREPARATION ORDER - 2. TRIAL DOCUMENTS TO BE FILED - A. TRIAL BRIEFS (OPTIONAL)

Filing & Service rules

Electronic Filing Rules

All parties are to comply with the General Order re Mandatory Electronic Filing for Civil dated November 5, 2018. Pursuant to California Rules of Court, Rule 2.253 (b)(2), self-represented litigants are exempt from the mandatory electronic filing requirement.

All parties are to comply with the General Order re Mandatory Electronic Filing for Civil dated November 5, 2018. Pursuant to California Rules of Court, Rule 2.253 (b)(2), self-represented litigants are exempt from the mandatory electronic filing requirement.

Page 1 | 2. Filings

All parties are to comply with the General Order re Mandatory Electronic Filing for Civil dated November 5, 2018.

All parties are to comply with the General Order re Mandatory Electronic Filing for Civil dated November 5, 2018.

Page 1 | 2. Filings

All trial documents must be filed under the mandatory civil e-filing General Order, except that self-represented litigants are exempt under CRC 2.253(b)(2).

All trial documents are to be filed pursuant to the General Order re Mandatory Electronic Filing for Civil dated November 5, 2018. Pursuant to California Rules of Court, Rule 2.253 (b)(2), self-represented litigants are exempt from the mandatory electronic filing requirement.

Page 2 | 3. Case Management Conferences

Case management conference statements must be filed through the court's eCourt system in advance of the CMC.

CMC statements are to be filed via eCourt in advance of the CMC.

Page 2 | 3. Case Management Conferences

Documents must be electronically filed unless the filer is a self-represented litigant or otherwise exempted from mandatory electronic filing.

filed unless the filer is a self-represented litigant or otherwise exempted from mandatory electronic filing.

Page 4 | 7. Motions

The joint statement of issues for the IDC must be filed electronically on eCourt.

Five court days prior to the IDC, the parties are to file (on eCourt) a joint statement of issues to be covered at the IDC, not to exceed five (5) pages.

Page 5 | 10. Discovery Motions

All trial documents must be filed electronically pursuant to the General Order re Mandatory Electronic Filing for Civil dated November 5, 2018, with self-represented litigants exempt under California Rules of Court, Rule 2.253(b)(2).

All trial documents are to be filed pursuant to the General Order re Mandatory Electronic Filing for Civil dated November 5, 2018. Pursuant to California Rules of Court, Rule 2.253 (b)(2), self-represented litigants are exempt from the mandatory electronic filing requirement.

Page 16 | 2. TRIAL DOCUMENTS TO BE FILED

Self-represented litigants are exempt from mandatory electronic filing under California Rules of Court, Rule 2.253(b)(2), making e-filing optional for them.

Pursuant to California Rules of Court, Rule 2.253 (b)(2), self-represented litigants are exempt from the mandatory electronic filing requirement.

Page 2 | 2. Filings

Filing Timing and Cure Windows

Ex parte applications and supporting documents must be e-filed by 10:00 a.m. the day before the hearing.

Ex parte applications and all documents in support thereof must be electronically filed no later than 10:00 a.m. the day before the ex parte hearing.

Page 4 | 8. Ex Parte Applications

Ex parte applications and all supporting documents must be e-filed no later than 10:00 a.m. the day before the ex parte hearing, except for self-represented litigants and others excused from e-filing.

Ex parte applications and all documents in support thereof must be electronically filed no later than 10:00 a.m. the day before the ex parte hearing.

Page 4 | 8. Ex Parte Applications

Written opposition to an ex parte application must be e-filed by 8:30 a.m. on the day of the ex parte hearing, except for self-represented litigants and others excused from e-filing.

Any written opposition to an ex parte application must be electronically filed by 8:30 a.m. the day of the ex parte hearing.

Page 4 | 8. Ex Parte Applications

Written oppositions to ex parte applications must be e-filed by 8:30 a.m. the day of the hearing.

Any written opposition to an ex parte application must be electronically filed by 8:30 a.m. the day of the ex parte hearing.

Page 4 | 8. Ex Parte Applications

The joint statement of issues for the IDC must be filed on eCourt five court days before the IDC.

Five court days prior to the IDC, the parties are to file (on eCourt) a joint statement of issues to be covered at the IDC, not to exceed five (5) pages.

Page 5 | 10. Discovery Motions

No later than five calendar 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 calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall file and serve the following documents:

Page 9 | TRIAL PREPARATION ORDER - 2. TRIAL DOCUMENTS TO BE FILED

No later than five calendar 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 calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall file and serve the following documents:

Page 16 | 2. TRIAL DOCUMENTS TO BE FILED

Trial documents must be filed and served 5 calendar days before Final Status Conference.

No later than five calendar 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 CHART OF PAGE AND LINE DESIGNATIONS FOR DEPOSITION AND FORMER TESTIMONY

Page 9 | 2. TRIAL DOCUMENTS TO BE FILED (Bench Trial)

Service and Proof of Service Rules

Parties' counsel and any self-represented parties must exchange all trial exhibits no later than 18 calendar days before the Final Status Conference.

No later than 18 calendar 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 8 | 1. MEET AND CONFER

Parties' counsel and any self-represented parties must exchange all exhibits they intend to introduce at trial no later than 18 calendar days before the Final Status Conference.

No later than 18 calendar 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 15 | 1. MEET AND CONFER

Courtesy Copy Requirements

Pleadings and motions of 26 or more pages require courtesy copies.

pleadings and motions (including attachments) of 26 pages or more

Page 1 | 2. Filings

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.

Page 2 | 4. Final Status Conferences

One set of the Exhibit Binders must be brought to the Final Status Conference for the court to review.

bring one set of the Exhibit Binders to the Final Status Conference for the court to review.

Page 14 | 4. EXHIBIT BINDERS

One set of Exhibit Binders must be brought to the Final Status Conference for the court to review.

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.

Page 21 | TRIAL PREPARATION ORDER - 4. Exhibit Binders

In addition to mandatory e-filing, the court requests that attorneys and parties lodge courtesy paper copies of all motions, oppositions, and replies in Department 205.

In addition to the requirement set forth in the General Order re Mandatory Electronic Filings for Civil dated November 5, 2018, the court requests attorneys and parties to lodge in Department 205 courtesy paper copies of all motions, oppositions, and replies.

Page 4 | 7. Motions

Court requests courtesy paper copies of all motions, oppositions, and replies be lodged in Department 205.

In addition to the requirement set forth in the General Order re Mandatory Electronic Filings for Civil dated November 5, 2018, the court requests attorneys and parties to lodge in Department 205 courtesy paper copies of all motions, oppositions, and replies.

Page 4 | 7. Motions

Courtesy copies required for specified document types including pleadings/motions over 26 pages, demurrers, anti-SLAPP filings, MSJs, discovery motions, and trial documents.

Courtesy copies are required for (1) any printed document required pursuant to a Standing or General Order; (2) pleadings and motions (including attachments) of 26 pages or more; (3) pleadings and motions that include points and authorities; (4) demurrers; (5) anti-SLAPP filings; (6) motions for summary judgment/adjudication; (7) motions to compel judgment/adjudication, or motions to compel further discovery; and (9) all trial documents as described in the Trial Preparation Orders.

Page 1 | 2. Filings

Courtesy copies are required for pleadings and motions (including attachments) of 26 pages or more.

Courtesy copies are required for (1) any printed document required pursuant to a Standing or General Order; (2) pleadings and motions (including attachments) of 26 pages or more; (3) pleadings and motions that include points and authorities; (4) demurrers; (5) anti-SLAPP filings; (6) motions for summary judgment/adjudication; (7) motions to compel judgment/adjudication, or motions to compel further discovery; and (9) all trial documents as described in the Trial Preparation Orders.

Page 1 | 2. Filings

Filing Bundling Requirements

The parties are to jointly 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 parties are to jointly 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.

Page 2 | 4. Final Status Conferences

The parties must jointly create binders of all motions in limine, including moving papers, opposition and reply briefs.

The parties are to jointly create binders of all MILs, including moving papers, opposition and reply briefs.

Page 2 | 4. Final Status Conferences

Motions in Limine Binder required, lodged 5 calendar days before FSC, three-ring binders, tabbed, colored separators.

No later than five calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department 205 a Motions in Limine Binder. The Motions in Limine Binder shall include one-sided, 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 13 | 3. Motions in Limine Binder (Bench Trial)

Parties must jointly prepare and lodge a tabbed Motions in Limine Binder in Department 205 no later than five calendar days before the Final Status Conference.

No later than five calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department 205 a Motions in Limine Binder. The Motions in Limine Binder shall include one-sided, 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 13 | Motions in Limine

Four sets of tabbed, numbered Exhibit Binders required in three-ring binders, one-sided documentary copies.

The parties’ counsel and any self-represented parties shall work together to jointly prepare four sets of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) (“Exhibit Binders”). Copies of documentary exhibits shall be one-sided copies.

Page 13 | 4. EXHIBIT BINDERS (Bench Trial)

Parties must jointly prepare four sets of tabbed, paginated, properly marked exhibits in three-ring binders, with one-sided documentary copies and written descriptions behind the tabs for non-documentary exhibits.

The parties’ counsel and any self-represented parties shall work together to jointly prepare four sets of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) (“Exhibit Binders”). Copies of documentary exhibits shall be one-sided copies. The parties’ counsel and any self-represented parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the Exhibit Binders.

Page 13 | 4. EXHIBIT BINDERS

Parties must jointly prepare and lodge a tabbed Trial Binder with a table of contents in Department 205 no later than five calendar days before the Final Status Conference; non-jury trials require only Tabs A, B, C, H, and I.

No later than five calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department 205 a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following (for trials by the court without a jury, the Trial Binder shall only include the documents listed under Tabs A, B, C, H, and I):

Page 14 | 5. TRIAL BINDER

Parties must jointly prepare and lodge a Motions in Limine Binder in Department 205 no later than five calendar days before the Final Status Conference.

No later than five calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department 205 a Motions in Limine Binder.

Page 21 | TRIAL PREPARATION ORDER - Motions in Limine

Parties must jointly prepare and lodge a Trial Binder in Department 205 no later than five calendar days before the Final Status Conference; bench trials require only Tabs A, B, C, H, and I.

No later than five calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department 205 a Trial Binder, contents that includes the following (for trials by the court without a jury, the Trial Binder shall only include the documents listed under Tabs A, B, C, H, and I):

Page 21 | TRIAL PREPARATION ORDER - 5. Trial Binder

Parties must jointly prepare four sets of tabbed, internally paginated, properly-marked exhibits organized numerically in three-ring binders for the court, Judicial Assistant, and witnesses.

The parties’ counsel and any self-represented parties shall work together to jointly prepare four sets of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) (“Exhibit Binders”).

Page 21 | TRIAL PREPARATION ORDER - 4. Exhibit Binders

Trial Binder required, lodged 5 calendar days before FSC, three-ring binder, tabbed, table of contents with specified tabs.

No later than five calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department 205 a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following (for trials by the court without a jury, the Trial Binder shall only include the documents listed under Tabs A, B, C, H, and I): Tab A: Trial Briefs (Optional) Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab E: Copies of the Current Operative Pleadings

Page 14 | 5. TRIAL BINDER (Bench Trial)

Pre-Motion Conference Requirements

All motion hearing dates must be reserved in advance through the Court Reservation System (CRS) at www.lacourt.ca.gov, with motions heard Monday through Friday.

All motion hearing dates must be reserved in advance on the Court Reservation System at www.lacourt.ca.gov, under "Online Services," "Civil," "Court Reservation System (CRS)." Motions are set for hearing Monday through Friday.

Page 3 | 7. Motions

Parties must first meet and confer on discovery issues and, if unresolved, schedule an Informal Discovery Conference with the Court Reservation System or Courtroom Assistant.

The parties are first to meet and confer to attempt to informally resolve all discovery issues. If the parties cannot agree, the parties are to schedule an Informal Discovery Conference with the Court Reservation System or the Courtroom Assistant.

Page 5 | 10. Discovery Motions

Informal Discovery Conference or court permission required before filing motions to compel discovery.

An IDC or permission from the court must occur prior to filing any motions to compel or compel further discovery responses.

Page 5 | 10. Discovery Motions

An Informal Discovery Conference or court permission is a prerequisite to filing any motion to compel or compel further discovery responses.

An IDC or permission from the court must occur prior to filing any motions to compel or compel further discovery responses.

Page 5 | 10. Discovery Motions

Parties' counsel and any self-represented parties must meet and confer no later than 11 calendar days before the Final Status Conference to prepare the required trial documents and binders and to make a good faith effort to stipulate.

No later than 11 calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall meet and confer to do the following: (1) discuss and prepare the documents required in Sections 2.B-D, 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

Page 8 | 1. MEET AND CONFER

Motions in limine must be noticed for hearing at the Final Status Conference.

Motions in limine shall be noticed for hearing at the Final Status Conference.

Page 21 | TRIAL PREPARATION ORDER - Motions in Limine

The court expects and encourages counsel and self-represented parties to informally resolve discovery disputes rather than filing discovery motions.

The court expects and encourages the parties’ counsel and any self-represented parties to informally resolve discovery disputes, instead of using expensive and cumbersome discovery motions.

Page 5 | 10. Discovery Motions

Adjournment & Extension Requirements

After a motion hearing date is reserved and noticed, any continuance must be ordered by the court; rescheduling on the Court Reservation System alone is insufficient.

Once a motion is reserved and noticed, any continuance of the hearing date must be ordered by the court; it is not sufficient merely to reschedule the hearing on the Court Reservation System.

Page 3 | 7. Motions

Continuances of motion hearing dates require court order, not just CRS rescheduling.

Once a motion is reserved and noticed, any continuance of the hearing date must be ordered by the court; it is not sufficient merely to reschedule the hearing on the Court Reservation System.

Page 3 | 7. Motions

Parties are expected to grant reasonable requests for extensions of time to respond to pleadings, discovery, or other matters.

The court expects all attorneys and parties to grant reasonable requests for professional courtesies, such as requests for reasonable extensions of time for deadlines to respond to pleadings, discovery, or other matters.

Page 1 | 1. Civility and Professionalism

When filing an ex parte application to advance a summary judgment or summary adjudication hearing because no CRS dates are available before trial, the moving party should also consider including an alternative request to continue the trial to a date after the motion hearing (advisory).

Because it is usually extremely difficult for the court to advance the hearing on a motion for summary judgment or summary adjudication, if a party files an ex parte application to advance the hearing on such a motion because no hearing dates are available on the Court Reservation System before the trial date, the moving party should also consider including an alternative request that the court continue the trial to a date after the hearing on the motion.

Page 4 | 8. Ex Parte Applications

Chambers Communication Rules

The court requests that, after the parties’ counsel or any self-represented parties electronically lodge a document which requires action by the court (e.g., stipulation and proposed order, and proposed judgment), they refrain from calling the court’s staff to ask about the status of the document, and that they instead follow the document’s progress on the court’s Website (which the court updates as soon and as often as possible).

The court requests that, after the parties’ counsel or any self-represented parties electronically lodge a document which requires action by the court (e.g., stipulation and proposed order, and proposed judgment), they refrain from calling the court’s staff to ask about the status of the document, and that they instead follow the document’s progress on the court’s Website (which the court updates as soon and as often as possible).

Page 6 | 12. Electronically Lodged Documents Which Require Action by the Court

Courtroom Telephone: 310-281-2425 Courtroom Hours: 8:30-12, 1:30-4:30

Courtroom Telephone: 310-281-2425 Courtroom Hours: 8:30-12, 1:30-4:30

Page 1 | Header

The Department 205 courtroom telephone number is 310-281-2425 and courtroom hours are 8:30-12:00 and 1:30-4:30.

Courtroom Telephone: 310-281-2425 Courtroom Hours: 8:30-12, 1:30-4:30

Page 1 | Courtroom Information, Beverly Hills, Dept. 205

the court requests that, after the parties’ counsel or any self-represented parties electronically lodge a document which requires action by the court (e.g., stipulation and proposed order, and proposed judgment), they refrain from calling the court’s staff to ask about the status of the document, and that they instead follow the document’s progress on the court’s Website

the court requests that, after the parties’ counsel or any self-represented parties electronically lodge a document which requires action by the court (e.g., stipulation and proposed order, and proposed judgment), they refrain from calling the court’s staff to ask about the status of the document, and that they instead follow the document’s progress on the court’s Website

Page 6 | 12. Electronically Lodged Documents Which Require Action by the Court

Documents of departments with no single judge listed

About Judge Edward B. Moreton Jr.

Judge Edward B. Moreton Jr. is a judge in the Superior Court of California, County of Los Angeles, sitting in a district of that court. The court is the state trial court serving Los Angeles County, handling a wide range of civil, criminal, and family matters.

The judge's published procedures are contained in a document titled 'documents'.

Common questions about Judge Edward B. Moreton Jr.'s rules

Are courtesy copies required for Judge Edward B. Moreton Jr.?

Courtesy-copy rule applies for exhibits. Details: 1 copy, delivery at final status conference. One set of Exhibit Binders must be brought to the Final Status Conference for the court to review.

View ruleSource: page 21, section TRIAL PREPARATION ORDER - 4. Exhibit Binders

Does Judge Edward B. Moreton Jr. require a pre-motion conference or letter before filing a motion?

All motion hearing dates must be reserved in advance through the Court Reservation System (CRS) at www.lacourt.ca.gov, with motions heard Monday through Friday.

View ruleSource: page 3, section 7. Motions

What page or word limits apply to joint statement of issues before Judge Edward B. Moreton Jr.?

Judge Edward B. Moreton Jr.'s rule states these limits: 5 pages. The joint statement of issues for the IDC is limited to five pages.

View ruleSource: page 5, section 10. Discovery Motions

What page or word limits apply to joint statement idc before Judge Edward B. Moreton Jr.?

Judge Edward B. Moreton Jr.'s rule states these limits: attorney: 5 pages. Joint IDC statement must be filed 5 court days before IDC, max 5 pages.

View ruleSource: page 5, section 10. Discovery Motions

What formatting rules apply to filings before Judge Edward B. Moreton Jr.?

Judge Edward B. Moreton Jr.'s formatting rule includes binding three ring binder, one-sided, conformed copies of all motions in limine, opposition papers, and reply papers, tabbed in numerical order, opposition and reply papers for each motion placed directly behind the moving papers, and colored sheet of paper separating the moving, opposition, and reply papers.

View ruleSource: page 21, section TRIAL PREPARATION ORDER - Motions in Limine

What must be included with ex parte application filings before Judge Edward B. Moreton Jr.?

Ex parte applications must comply with California Rules of Court, rules 3.1200-3.1207.

View ruleSource: page 4, section 8. Ex Parte Applications

What must be included with joint statement motion to compel further responses filings before Judge Edward B. Moreton Jr.?

Motions to compel further responses must be accompanied by a joint statement in a four-column format (request number, request text, response text, and brief bullet points from each party).

View ruleSource: page 5, section 10. Discovery Motions

How may parties contact Judge Edward B. Moreton Jr.'s chambers?

The court requests that, after the parties’ counsel or any self-represented parties electronically lodge a document which requires action by the court (e.g., stipulation and proposed order, and proposed judgment), they refrain from calling the court’s staff to ask about the status of the document, and that they instead follow the document’s progress on the court’s Website (which the court updates as soon and as often as possible).

View ruleSource: page 6, section 12. Electronically Lodged Documents Which Require Action by the Court

How do I request an adjournment or extension before Judge Edward B. Moreton Jr.?

After a motion hearing date is reserved and noticed, any continuance must be ordered by the court; rescheduling on the Court Reservation System alone is insufficient.

View ruleSource: page 3, section 7. Motions

Does Judge Edward B. Moreton Jr. require motion papers to be bundled?

Parties must jointly prepare four sets of tabbed, paginated, properly marked exhibits in three-ring binders, with one-sided documentary copies and written descriptions behind the tabs for non-documentary exhibits.

View ruleSource: page 13, section 4. EXHIBIT BINDERS

Is electronic filing required before Judge Edward B. Moreton Jr.?

Yes. Electronic filing is required for the covered filings. All parties are to comply with the General Order re Mandatory Electronic Filing for Civil dated November 5, 2018.

View ruleSource: page 1, section 2. Filings

When is a filing treated as filed before Judge Edward B. Moreton Jr.?

The rule states a 10:00 AM filing cutoff. Ex parte applications and all supporting documents must be e-filed no later than 10:00 a.m. the day before the ex parte hearing, except for self-represented litigants and others excused from e-filing.

View ruleSource: page 4, section 8. Ex Parte Applications

What rule applies to service for exhibits before Judge Edward B. Moreton Jr.?

Details: recipient: all parties, timing: 18 calendar days before hearing. Parties' counsel and any self-represented parties must exchange all exhibits they intend to introduce at trial no later than 18 calendar days before the Final Status Conference.

View ruleSource: page 15, section 1. MEET AND CONFER
Complete rules summary for Judge Edward B. Moreton Jr.

Parties are expected to grant reasonable requests for extensions of time to respond to pleadings, discovery, or other matters.

All parties are to comply with the General Order re Mandatory Electronic Filing for Civil dated November 5, 2018.

All trial documents must be filed under the mandatory civil e-filing General Order, except that self-represented litigants are exempt under CRC 2.253(b)(2).

Case management conference statements must be filed through the court's eCourt system in advance of the CMC.

All motion hearing dates must be reserved in advance through the Court Reservation System (CRS) at www.lacourt.ca.gov, with motions heard Monday through Friday.

Ex parte applications must comply with California Rules of Court, rules 3.1200-3.1207.

In addition to mandatory e-filing, the court requests that attorneys and parties lodge courtesy paper copies of all motions, oppositions, and replies in Department 205.

The court expects and encourages counsel and self-represented parties to informally resolve discovery disputes rather than filing discovery motions.

Ex parte applications and all supporting documents must be e-filed no later than 10:00 a.m. the day before the ex parte hearing, except for self-represented litigants and others excused from e-filing.

When filing an ex parte application to advance a summary judgment or summary adjudication hearing because no CRS dates are available before trial, the moving party should also consider including an alternative request to continue the trial to a date after the motion hearing (advisory).

The joint statement of issues for the IDC must be filed electronically on eCourt.

Motions to compel further responses must be accompanied by a joint statement in a four-column format (request number, request text, response text, and brief bullet points from each party).

An Informal Discovery Conference or court permission is a prerequisite to filing any motion to compel or compel further discovery responses.

prepare and submit the documents and binders required by that order.

The court requests that, after the parties’ counsel or any self-represented parties electronically lodge a document which requires action by the court (e.g., stipulation and proposed order, and proposed judgment), they refrain from calling the court’s staff to ask about the status of the document, and that they instead follow the document’s progress on the court’s Website (which the court updates as soon and as often as possible).

Parties must prepare the documents required in Sections 2.B-D and the Motions in Limine Binder, Exhibit Binders, and Trial Binder required in Sections 3-5 for discussion at the meet and confer.

Trial briefs are optional, but if filed must succinctly identify disputed claims and defenses, major legal issues with supporting authorities, relief and damages calculation, and other trial-assisting information.

Counsel and self-represented parties must jointly prepare and file an exhibit list in a prescribed column format and must meet and confer to resolve authentication and admissibility objections.

Each designating party's designations in the joint chart must include six columns: witness number/name, date/type of testimony, page:line designations, objections, counter-designation information, and the court's ruling.

Parties intending to use deposition or former trial testimony must meet and confer and jointly prepare and file a Joint Chart of Page and Line Designations for Deposition and Former Testimony.

Motions in limine must be noticed for hearing at the Final Status Conference, with CCP § 1005 notice and declarations complying with Los Angeles County Court Rule 3.57(a).

Parties must jointly prepare four sets of tabbed, paginated, properly marked exhibits in three-ring binders, with one-sided documentary copies and written descriptions behind the tabs for non-documentary exhibits.

Parties' counsel and any self-represented parties must exchange all exhibits they intend to introduce at trial no later than 18 calendar days before the Final Status Conference.

Parties must jointly prepare and lodge a tabbed Trial Binder with a table of contents in Department 205 no later than five calendar days before the Final Status Conference; non-jury trials require only Tabs A, B, C, H, and I.

The court's yellow evidence tags (with only the case number and exhibit number filled in) must be placed on each exhibit (sentence continues beyond this chunk).

The parties must jointly prepare and file a joint witness list (excluding impeachment and rebuttal witnesses) with specified columns and a grand total of estimated testimony times, and any witness not included on the list is subject to being excluded from testifying at trial.

Counsel and self-represented parties must jointly prepare and file a joint exhibit list stating eight specified items for each trial exhibit.

A party seeking to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the court.

For jury trials, the parties must jointly prepare a complete set of full-text proposed jury instructions with CACI instructions edited, party names inserted, and blanks and inapplicable material eliminated.

For jury trials, counsel and self-represented parties must jointly prepare and file a joint list of proposed jury instructions stating six specified items for each instruction.

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