Judge Elizabeth L. Bradley
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Exhibits
- 1 copy • At Final Status Conference
- 3 copies • First Day of Trial
Communication
Chambers
Chambers
Phone
Page & Word Limits4 rules
Each party's trial brief is limited to 15 pages.
- Trial brief
- Up to 15 pages per party
Court's wording
Each party is required to file a trial brief not to exceed 15 pages succinctly identifying: (I) 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 any damages sought; and (4) any other information that may assist the court at trial.
Trial briefs are limited to 15 pages.
- Trial brief
- Up to 15 pages per party
Court's wording
Each party is required to file a trial brief not to exceed 15 pages succinctly identifying: (I) 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 any damages sought; and (4) any other information that may assist the court at trial.
Motions in limine shall be filed with statutory notice for hearing at the Final Status Conference, and are not to exceed five pages without leave of court.
- Motion in limine
- Up to 5 pages
Exception
More pages with leave of court
Motions in limine shall be filed with statutory notice for hearing at the Final Status Conference, and are not to exceed five pages without leave of court.
- Motion in limine
- Up to 5 pages
Exception
More pages with leave of court
Document Format Requirements6 rules
The proposed jury instructions shall be inserted into the trial notebook under a separate tab than the joint list of proposed jury instructions, and shall be prepared on Los Angeles Superior Court form LASC LACIV 129 or in a Word document that is in the same format including the disposition box.
Parties must jointly prepare three sets of tabbed, internally paginated, properly marked exhibits in three-ring binders (max 3 inches) for the court, the Judicial Assistant, and the witnesses.
- Binding
- Tabbed three-ring binder
- Exhibits
Formatting
- •Exhibits properly marked and organized numerically
Court's wording
The parties' counsel and any self-represented parties shall work together to jointly prepare three sets of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (not to exceed 3" per binder) (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) ("Exhibit Binders").
Electronic media evidence must be lodged on a flash drive because the court and jury cannot view CD/DVD format evidence.
Court's wording
The court does not have access to a CD or DVD player to view electronic evidence. Nor does the jury have access to any electronic evidence on CD/DVD format. Any evidence to be submitted on electronic media shall be lodged on a flash drive.
The joint chart must include attached transcript pages separated by numbered tabs, with each designation or counter-designation highlighted in a different color per party.
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. Each designation or counter-designation shall be highlighted, with each party using a different color highlighter.
Copies of documentary exhibits shall be one-sided copies.
The Motions in Limine Binder must contain two-sided conformed copies organized in tabbed three-ring binders (max 3 inches) with colored separators between moving, opposition, and reply papers.
- Binding
- Tabbed three-ring binder
- Motions in limine
Formatting
- •Indexed and tabbed in numerical order
Court's wording
The Motions in Limine Binder shall include two-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders not to exceed 3" per binder, indexed and 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.
Document Filing Requirements50 rules
Ex parte applications must comply with the requirements of California Rules of Court, rules 3.1200-3.1207.
An applicant must make an affmnative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte. Rule 3.1202(c). This is the most common reason for denial of an ex parte application.
A meet and confer declaration in support of a motion shall state facts showing a reasonable and good faith attempt at an informal resolution of each issue presented by the motion. (Code of Civ. Proc. §2016.040.)
IDC requests must use form LACIV 094, lodged in Dept A, with hearing date reserved on CRS, indicating meet and confer method.
Court's wording
To request an IDC, please complete Los Angeles Superior Court form LACIV 094, lodge it in Department A, and reserve a hearing date on the Court Reservation System, which will reflect "Confirmed" upon approval by the court. The request shall indicate whether the parties have met and conferred in person or by videoconference.
To request an IDC, please complete Los Angeles Superior Court form LACIV 094, lodge it in Department A, and reserve a hearing date on the Court Reservation System, which will reflect "Confirmed" upon approval by the court. The request shall indicate whether the parties have met and conferred in person or by videoconference.
Each trial brief must identify the disputed claims and defenses, major legal issues with supporting authorities, relief and damages calculation, and any other information assisting the court at trial.
Court's wording
Each party is required to file a trial brief not to exceed 15 pages succinctly identifying: (I) 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 any damages sought; and (4) any other information that may assist the court at trial.
Parties must jointly prepare and file a joint witness list (excluding impeachment and rebuttal witnesses) in a required column format; the format description is truncated in the provided text.
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 (I) 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
The parties, including self-represented parties, must jointly prepare and file a joint exhibit list stating eight required items for each trial exhibit, per Local Rule 3.25(g)(6).
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 with reference to the applicable evidence code section(s) or other legal authority, (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).)
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.
Witnesses not identified on the joint witness list may be excluded from testifying except for impeachment or rebuttal, and calling an unlisted witness requires a prior showing of good cause.
Court's wording
Any witness who is not included on the joint witness list is subject to being excluded from testifying at trial other than for purposes of giving actual impeachment or rebuttal testimony. Any party who seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the court.
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.
If an objection to an exhibit is not articulated on the exhibit list, the trial court may deem the exhibit admitted.
For jury trials, the parties must jointly prepare and file a joint list of proposed jury instructions stating six required items for each proposed 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: (I) the jury instruction number (listed in numerical order), (2) the title of the jury instruction, (3) the party/parties 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
If after exhaustive meet and confer efforts the parties carmot agree on a joint verdict form, each party must separately file a proposed verdict form, and bring an electronic copy of their proposed verdict form in Word to the FSC, ready to be edited in the courtroom.
For jury trials, the parties must jointly prepare a complete set of full-text proposed jury instructions using edited CACI instructions with party names inserted and blanks or irrelevant material removed.
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.
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).)
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).)
After the jury instruction conference, the court will require one of the parties to submit a final set of jury instructions approved by the court, including any modifications ordered by the court, and excluding the disposition table from the top of each instruction.
A party may not collectively designate an entire deposition transcript under one entry, as a record is required for the court's rulings on any evidentiary objections.
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").
Each designating party's entries in the joint chart must include six required columns (witness name, date/type of testimony, page/line designations, objections, counter-designation info, and court ruling).
Court's wording
In the joint chart, each designating party's designations of deposition or former testimony shall include columns which state: (I) 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.
Each counter-designating party's entries in the joint chart must include six required columns (witness name, date/type of testimony, page/line counter-designations, objections, related designation number, and court 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: (I) 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.
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
Meet and confer efforts shall consist of more than one email advising the opposing party(ies) of the nature of the motion.
If more than five motions in limine were collectively filed, the first volume of the Motions in Limine Binder must include a joint table of motions listing motion numbers, descriptions of evidence to be excluded, opposition status, and a blank column for the court.
Court's wording
If more than five motions in limine have been collectively filed by the parties, the parties are required to include at the front of the first volume of the Motions in Limine Binder a joint table of motions in limine filed with columns listing the moving party/motion number (i.e. mil m/2, n#3, !J.#1, !J.#2, !J.#3, etc.), a brief description of the evidence sought to be excluded, whether the motion is opposed in full or in part, and a blank column for the court's use.
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) plaintiffs requested instructions to which defendant objects, and (3) defendant's requested instructions to which plaintiff objects.
If the flash drive contains a recording, the description on the Exhibit List must state whether it contains an audio file, and the submitting party must confinn that a transcript of the audio has been filed with the flash drive at the time the exhibit is offered to the court. [CRC, Rule 2.1040],
Tab A: Trial Briefs Tab B: Joint Witness List Tab C: Joint Exhibit List TabD: 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) TabH: Joint Chart of Page/Line Designations for Deposition/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
A copy of the slides must be lodged with the court.
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.)
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.
The court generally finds that meeting and conferring by only exchanging letters and e- mails, as opposed to actual conversation, is insufficient and ineffective. Thus, the parties should indicate in any declaration filed in support of or in opposition to a discovery motion what efforts
Counsel and self-represented parties must jointly prepare and submit the required trial documents and binders and meet and confer in good faith, with a possible exception for filing separately if another party will not cooperate (exception text truncated).
Court's wording
The court expects the parties' counsel and any self-represented parties to work together to jointly prepare and submit the required trial documents and binders in accordance with the Trial Preparation Order, and to meet and confer in good faith with respect to all trial documents. If after making a diligent effort a party is unable to obtain one or more other party's/parties' cooperation in the preparation and submission of joint trial documents as required herein, that party may submit
The parties are required to comply with Paragraph 5, infra, regarding Electronic Media as Exhibits.
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
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. Specially prepared jury instructions should be used sparingly and should not be repetitive of CACI instructions or argumentative in nature.
Motions in limine that are generic, do not identify the specific evidence sought to be excluded (e.g. exhibits, testimony and/or witnesses), seek rulings which would merely be declaratory of existing law or would not provide any meaningful guidance for the parties
Uncontested motions should note "uncontested" in the caption.
- Document
- Motion in limine
- Placement
- Caption
Should include
- •Uncontested
The parties/counsel are strongly discouraged from filing more than 5 contested motions in limine.
Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.
- Document
- Motion in limine opposition and reply
- Placement
- Caption
Parties filing more than one motion in limine shall number them consecutively.
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, and shall comply with Paragraph 5, irifra.
Photos within electronic media that are also marked with separate exhibit numbers must be printed out with an exhibit tag affixed to each.
Court's wording
If the flash drive is marked as an exhibit and any of the photos contained or presented within the electronic media are also marked with a separate exhibit number, then each of the marked photos must be printed out and have an exhibit tag affixed to each item.
Flash drives containing photographs not individually marked as exhibits must be accurately described on the Exhibit List.
Court's wording
If the flash drive contains photographs that are not individually marked as an exhibit, it must be described accurately on the Exhibit List, for example Plaintiff's Exhibit 2 (flash drive containing 3 photographs).
It is the proffering party's responsibility to ensure a method of promptly displaying any electronic media trial exhibit in the jury room during deliberations upon request of the jury.
If a flash drive is in an envelope, sleeve, or case, the Exhibit List description must state so.
Court's wording
If a flash drive is in an envelope, sleeve, or case, the description on the Exhibit List must state the following, Plaintiff's I - Flash drive in a white sleeve containing 5 photographs of the defendant.
The parties/counsel are strongly encouraged to stipulate to uncontested motions.
Replies are not required. The parties are encouraged to stipulate to waive the filing of replies to motions in limine.
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.
If a flash drive is offered into evidence, it must be listed on the Exhibit List, with a placeholder in the Exhibit Book identifying that is marked must contain an exhibit tag.
Filing & Service rules
Electronic Filing Rules
Please note that section 8 of the First Amended General Order governing Mandatory Electronic Filing for Civil, filed May 3, 2019, provides that, with the exception of self-
Please note that section 8 of the First Amended General Order governing Mandatory Electronic Filing for Civil, filed May 3, 2019, provides that, with the exception of self-
Page 4 | 7. Ex Parte Applications
a) 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. b) Any written opposition to an ex parte application must be electronically filed by 8:30 a.m. the day of the ex parte hearing.
a) 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. b) 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 5 | 7. Ex Parte Applications
All filers except self-represented parties must electronically file all civil documents including ex parte applications under CRC Rule 3.1203.
Please note that section 8 of the First Amended General Order governing Mandatory Electronic Filing for Civil, filed May 3, 2019, provides that, with the exception of self-represented parties, all filers must electronically file all civil documents, including ex parte applications falling under CRC Rule 3.1203
Page 5 | 7. Ex Parte Applications
Filing Timing and Cure Windows
Written opposition to an ex parte application must be electronically filed by 8:30 a.m. on the day of the ex parte hearing.
b) 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 5 | 7. Ex Parte Applications
Ex parte applications and all supporting documents must be electronically filed no later than 10:00 a.m. the day before the ex parte hearing.
a) 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 5 | 7. 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 5 | 7. Ex Parte Applications
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 5 | 7. Ex Parte Applications
Requesting or holding an IDC does not automatically toll the filing deadline for a motion to compel discovery.
Neither the request for an IDC nor an IDC automatically tolls the filing deadline for a motion to compel discovery.
Page 7 | Discovery / Informal Discovery Conferences
The required trial documents (Trial Preparation Requirements Section 2) must be filed and served 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 file and serve the following documents:
Page 10 | TRIAL PREPARATION REQUIREMENTS - 2. TRIAL DOCUMENTS TO BE FILED
All trial exhibits must be exchanged 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 10 | TRIAL PREPARATION REQUIREMENTS - 1. MEET AND CONFER
Parties must meet and confer no later than 11 calendar days before the Final Status Conference to prepare required trial documents and binders, seek stipulations on exhibits, motions in limine, and ultimate facts/legal issues, and attempt settlement.
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: (I) discuss and prepare the documents required in Sections 2.B-H, below, and the Motions in Limine Binder, Exhibit Binders, and Trial Binder required in Sections 3-5, below, (2) discuss and make a good faith effort to stipulate to the authenticity and admissibility of each trial exhibit, (3) discuss and make a good faith effort to stipulate to resolve each motion in Iirnine, (4) discuss and make a good faith effort to stipulate to ultimate facts and legal issues, and (5) discuss and make a good faith effort to settle the case.
Page 10 | TRIAL PREPARATION REQUIREMENTS - 1. MEET AND CONFER
Transcripts of each deposition identified on the joint chart must be lodged with the court before trial begins.
The parties shall meet and confer to ensure that transcripts of each deposition identified on the Joint Chart of Page and Line Designations for Deposition and Farmer Testimony is lodged with the court prior to the commencement of trial.
Page 13 | H. Joint Chart of Page and Line Designations for Deposition and Former Testimony
Counsel and self-represented parties must comply with CCP section 1005 statutory notice provisions and Los Angeles County Court Rule 3.57(a) for motions in limine heard 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 the requirements of Los Angeles County Court Rule 3.57, subdivision (a).
Page 14 | 3. Motions in Limine
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.
Page 17
Trial documents must be filed and served no later than 5 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 file and serve the following documents: A. TRIAL BRIEFS B. JOINT WITNESS LIST C. JOINT EXHIBIT LIST D. JOINT STATEMENT TO BE READ TO THE JURY E. JOINT LIST OF PROPOSED JURY INSTRUCTIONS F. JURY INSTRUCTIONS (JOINT AND CONTESTED) G. VERDICT FORM(S) H. JOINT CHART OF PAGE AND LINE DESIGNATIONS FOR DEPOSITION AND FORMER TESTIMONY
Page 10 | 2. TRIAL DOCUMENTS TO BE FILED
Service and Proof of Service Rules
A set of properly marked exhibits must be provided to each opposing party before trial begins.
A set of properly-marked exhibits must also be provided to each opposing party prior to the start of trial.
Page 15 | 4. EXHIBIT BINDERS
Courtesy Copy Requirements
All three sets of exhibit binders must be lodged on the first day of trial.
The parties shall lodge the entire three sets of exhibit binders on the first day of trial.
Page 15 | 4. EXHIBIT BINDERS
Each party must bring one volume (not a full set) of its Exhibit Binders to the Final Status Conference for court review.
The parties' counsel and any self-represented parties shall each bring one volume (not a full set) of the Exhibit Binders containing their exhibits to the Final Status Conference for the court to review.
Page 15 | 4. EXHIBIT BINDERS
Filing Bundling Requirements
Three sets of tabbed, numerically organized exhibit binders (max 3" per volume) required for court, judicial assistant, and witnesses; lodged first day of trial.
The parties' counsel and any self-represented parties shall work together to jointly prepare three sets of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (not to exceed 3" per binder) (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) ("Exhibit Binders"). A set of properly- marked exhibits must also be provided to each opposing party prior to the start of trial. For example, if exhibit 5 is a five-page document, its pages should be numbered 5-1, 5-2, 5-3, etc. or 5.1, 5.2, 5.3, etc. Copies of documentary exhibits shall be one-sided copies. ... The parties shall lodge the entire three sets of exhibit binders on the first day of trial.
Page 15 | 4. EXHIBIT BINDERS
Parties' counsel and self-represented parties must jointly prepare and lodge a Motions in Limine Binder in Department A no later than three calendar days before the Final Status Conference, with each volume no larger than 3 inches.
No later than three calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department A a Motions in Limine Binder (each volume of which is no larger than 3").
Page 15 | Motions in Limine
Motions in limine and related papers must be bundled into a tabbed three-ring binder (max 3" per volume) lodged 3 days before FSC; proposed orders excluded.
No later than three calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department A a Motions in Limine Binder (each volume of which is no larger than 3"). The Motions in Limine Binder shall include two-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders not to exceed 3" per binder, indexed and 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. Proposed orders should not be included in the Motions in Limine Binder.
Page 15 | 3. MOTIONS IN LIMINE
Parties must jointly prepare and lodge a Trial Binder in Department A no later than three calendar days before the Final Status Conference, consisting of one-sided conformed copies signed by all parties in a tabbed three-ring binder with a table of contents.
No later than three calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department A a Trial Binder, consisting of one-sided, conformed copies, signed by all parties, tabbed and organized in a three- ring binder with a table of contents that includes the following:
Page 16 | 6. TRIAL BINDER
Trial Binder with specified tabbed sections required, lodged 3 days before FSC, one-sided conformed copies signed by all parties.
No later than three calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall jointly prepare and lodge in Department A a Trial Binder, consisting of one-sided, conformed copies, signed by all parties, tabbed and organized in a three- ring binder with a table of contents that includes the following: Tab A: Trial Briefs Tab B: Joint Witness List Tab C: Joint Exhibit List TabD: 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) TabH: Joint Chart of Page/Line Designations for Deposition/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).
Page 16 | 6. TRIAL BINDER
Proposed orders must not be included in the Motions in Limine Binder.
Proposed orders should not be included in the Motions in Limine Binder.
Page 15 | Motions in Limine
Pre-Motion Conference Requirements
Parties must appear at the scheduled motion hearing even if all parties submitted to the tentative ruling, unless the court advises the tentative was adopted as the final order and no appearance is required.
Even where all parties submit to the court's tentative ruling, the parties are required to appear at the scheduled hearing unless the court advises that the tentative ruling has been adopted as the final order of the court and that no appearance is required.
Page 3 | 6. Motions
All motion hearing dates must be reserved in advance through the Court Reservation System (CRS) at www.lacourt.org.
All motion hearing dates must be reserved in advance on the Court Reservation System at www.lacourt.org, under "Online Services," "Civil," "Court Reservation System (CRS)."
Page 3 | 6. Motions
The court may impose sanctions on a party who fails to take a motion off calendar.
The Court may sanction a party for failing to take a motion off calendar.
Page 4 | 6. Motions
Parties must meet and confer in good faith to resolve discovery disputes before filing discovery motions; declaration of attempt required.
The court first expects the parties' counsel and any self-represented parties to meet and confer to make a reasonable and good faith attempt to informally resolve each discovery issue in dispute, as required by statute. This requirement is strictly construed. A meet and confer declaration in support of a motion shall state facts showing a reasonable and good faith attempt at an informal resolution of each issue presented by the motion. (Code of Civ. Proc. §2016.040.)
Page 6 | 6. Motions (Discovery)
Before filing a discovery motion, counsel and self-represented parties must meet and confer in a reasonable, good faith attempt to informally resolve each disputed discovery issue, and this requirement is strictly construed.
The court first expects the parties' counsel and any self-represented parties to meet and confer to make a reasonable and good faith attempt to informally resolve each discovery issue in dispute, as required by statute. This requirement is strictly construed.
Page 6
Counsel and any self-represented parties with full authority to stipulate must participate in the IDC, and the court normally makes no orders at the IDC unless the parties stipulate.
The court requires the parties' counsel and any self-represented parties, with full authority to enter into a stipulation to resolve the discovery disputes at issue, to participate in the IDC. Because an informal discovery conference is not a hearing on a motion, the court normally does not make any orders at the informal discovery conference unless the parties stipulate.
Page 7 | Discovery / Informal Discovery Conferences
Absent good cause, parties must meet and confer in person or by videoconference to attempt to informally resolve each disputed item before requesting an IDC.
Absent a showing of good cause, the parties are required to meet and confer either in person or by videoconference in an attempt to informally resolve each item in dispute before requesting an IDC.
Page 7 | Discovery / Informal Discovery Conferences
soon as practicable prior to the hearing on a motion if the matter has settled, or the motion is withdrawn or unopposed. If a moving party takes a motion off the Court's calendar, the moving party should notify the court immediately and should remove the item from the Court's calendar on CRS. (Cal. Rules of Court, rule 3.1304(b).)
soon as practicable prior to the hearing on a motion if the matter has settled, or the motion is withdrawn or unopposed. If a moving party takes a motion off the Court's calendar, the moving party should notify the court immediately and should remove the item from the Court's calendar on CRS. (Cal. Rules of Court, rule 3.1304(b).)
Page 4 | 6. Motions
On most motions the court issues written tentative rulings, posted on the court's website and at the courtroom no later than the morning of the hearing.
On most motions, the court issues written tentative rulings which the court will post on the court's Website and at the courtroom not later than on the morning of the hearing.
Page 3 | 6. Motions
Summary judgment/adjudication motions are heard on Fridays, while all other motions are heard on Tuesdays and Thursdays.
Motions for Summary Judgment/Adjudication are set for hearing on Fridays. All other motions are set for hearing on Tuesdays and Thursdays.
Page 3 | 6. Motions
Ex parte applications are heard at 8:30 a.m., Monday through Friday.
Ex parte applications are heard at 8:30 a.m., Monday through Friday.
Page 4 | 7. Ex Parte Applications
Attorneys and self-represented parties may appear at ex parte hearings in person or remotely by audio or videoconference on LACourt Connect.
Attorneys and self-represented parties may appear for ex parte hearings either in person, or remotely by audio or videoconference appearance on LACourt Connect.
Page 4 | 7. Ex Parte Applications
Ex parte applications are typically decided in chambers on the papers without oral argument.
The court typically considers and rules on ex parte applications in chambers based on the papers, without hearing oral argument.
Page 4 | 7. Ex Parte Applications
Parties are strongly encouraged to meet and confer and submit a stipulation and proposed order as an alternative to ex parte relief, especially where exigency is absent or questionable.
Parties are strongly encouraged to meet and confer with respect to the submission of a stipulation and proposed order as an alternative to seeking ex parte relief, particularly where there is no exigency or exigency is questionable.
Page 4 | 7. Ex Parte Applications
When a party amends a pleading in response to a demurrer, the court requests that party to work with the demurrer/motion-to-strike filer to take the motion off calendar (a request, not a mandate).
If, in response to a demurrer, a party exercises its right to amend a pleading as prescribed by Code of Civil Procedure section 472, subdivision (a), the Court requests that party to work with the party who filed the demurrer or motion to strike to take the demurrer or motion to strike off calendar so that the Court does not needlessly prepare tentative rulings.
Page 4 | 6. Motions
Informal Discovery Conferences are not required, but the court will ordinarily hold one upon request, particularly where the parties appear to be acting in good faith.
The court does not require Informal Discovery Conferences ("IDC"). The court will ordinarily exercise its discretion to hold an IDC upon request, particularly where it appears the parties are acting in good faith.
Page 7 | Discovery / Informal Discovery Conferences
Adjournment & Extension Requirements
The court expects responding parties to grant moving parties a reasonable extension of time to file a discovery motion so the parties can schedule and conduct an IDC.
The court expects the responding party to grant the moving party a reasonable extension of time to file a motion concerning the discovery in dispute in order to enable the parties to schedule and conduct an informal discovery conference.
Page 7 | Discovery / Informal Discovery Conferences
Continuances will not be granted because of witnesses who fail to appear in a timely manner.
Continuances will not be granted due to witnesses who do not appear in a timely manner.
Page 17 | 8. WITNESSES
Chambers Communication Rules
Counsel may submit to the court's tentative ruling by emailing the court at COMDeptA@lacourt.org by 8:00 a.m. the day of the hearing, indicating the case number and submitting party, and copying all counsel on the email.
Counsel may submit to the court's tentative ruling by emailing the court at COMDeptA@lacourt.org by 8:00 a.m. the day of the hearing, indicating the case number and submitting party, and copying all counsel on the email.
Page 3 | 6. Motions
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 please 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 please 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 8 | 10. Electronically Lodged Documents Which Require Action by the Court
Department A's email address is restricted to submissions on tentative rulings only.
Dept. A email: COMDeptA@lacomt.org (for submission on tentative rulings only)
Page 1 | COURTROOM INFORMATION FOR DEPARTMENT A
Dept. A email: COMDeptA@lacomt.org (for submission on tentative rulings only)
Dept. A email: COMDeptA@lacomt.org (for submission on tentative rulings only)
Page 1 | Courtroom Information for Department A
If you experience technical difficulty while appearing remotely, disconnect and attempt to log in again. If problems persist, call Department A to advise of the problem.
If you experience technical difficulty while appearing remotely, disconnect and attempt to log in again. If problems persist, call Department A to advise of the problem.
Page 2
Counsel may submit to a tentative ruling by emailing COMDeptA@lacourt.org by 8:00 a.m. on the hearing day, stating the case number and submitting party and copying all counsel; if all counsel submit, the court will most likely adopt the tentative as the final order.
Counsel may submit to the court's tentative ruling by emailing the court at COMDeptA@lacourt.org by 8:00 a.m. the day of the hearing, indicating the case number and submitting party, and copying all counsel on the email.
Page 3 | 6. Motions
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 please 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 please 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 8 | 10. Electronically Lodged Documents Which Require Action by the Court