Judge Eric Harmon
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- Not required
- Not Required
Exhibit Books
- 3 copies
Jury Instructions
Adjournments
- Trial continuances require a noticed motion, ex parte application, or stipulation and order accompanied by a mandatory declaration showing good cause; a stipulation alone is insufficient.
- If no stipulation is reached, any party may seek a continuance by noticed motion or ex parte application.
- Trial continuances require noticed motion, ex parte application, or stipulation with good cause declaration; filing fee required.
- +1 more
Request must include
- Trial and specified conferences may be continued by stipulation showing good cause, subject to Court approval at least 2 court days before the hearing.
Communication
Phone
Phone
Chambers
Page & Word Limits4 rules
involved in a discovery dispute to be addressed in an IDC shall file and serve an IDC statement of no more than (5) pages at least three (3) court days before the scheduled IDC.
- IDC statement
- Up to 5 pages
involved in a discovery dispute to be addressed in an IDC shall file and serve an IDC statement of no more than (5) pages at least three (3) court days before the scheduled IDC.
- IDC statement
- Up to 5 pages
a memorandum, not exceeding 5 pages in length, explaining why a particular proposed settled statement is more accurate.
- Settled statement memorandum
- Up to 5 pages
The memorandum explaining why a proposed settled statement is more accurate must not exceed 5 pages.
- Settled statement memorandum
- Up to 5 pages
Court's wording
These proposals will be accompanied by a declaration stating that the parties have met and conferred in good faith for no less than three hours on the day of trial to arrive at a settled statement as well as a memorandum, not exceeding 5 pages in length, explaining why a particular proposed settled statement is more accurate.
Document Format Requirements1 rule
Documentary exhibits consisting of more than one page must be internally paginated in sequential numerical order.
Document Filing Requirements32 rules
Counsel must comply with their obligation to submit case management statements pursuant to rule 3.725 of the California Rules of Court. Failure to comply with the California Rules of Court, Rules 3.722, 3.724, 3.727 and 3.728, local rules 3.24 and 3.25, and/or this court's scheduling orders may result in monetary sanctions and/or delay in trial setting.
An IDC statement must include a short case description, a description of the discovery dispute, the parties' informal resolution attempts and compromises, and any legal authority for the Court to consider.
- Document
- IDC statement
Must include
- •Legal argument
Court's wording
The IDC statement shall include (a) a short description of the case, (b) a description of the discovery dispute including a list or summary of the discovery requests, objections, and/or answers at issue, (c) a description of the parties' informal attempts and any compromises offered to resolve the dispute, and (d) any legal authority the Court should consider in conducting the IDC.
Among the most common grounds for denial of ex parte applications are failure to provide proof of required notice and failure to prove why the application could not be brought as a noticed motion. An emergency caused by procrastination or other unexcused delay on the part of the applicant is not grounds for ex parte relief.
IDC statements must include case description, dispute details, informal resolution attempts, and relevant legal authority.
Court's wording
The IDC statement shall include (a) a short description of the case, (b) a description of the discovery dispute including a list or summary of the discovery requests, objections, and/or answers at issue, (c) a description of the parties' informal attempts and any compromises offered to resolve the dispute, and (d) any legal authority the Court should consider in conducting the IDC.
The request must be made by using the local form (SCLAC LACIV 269).
Competing settled statement proposals must be accompanied by a declaration stating the parties met and conferred in good faith for at least three hours on the day of trial.
Court's wording
These proposals will be accompanied by a declaration stating that the parties have met and conferred in good faith for no less than three hours on the day of trial to arrive at a settled statement as well as a memorandum, not exceeding 5 pages in length, explaining why a particular proposed settled statement is more accurate.
As explained below, if a court reporter is not utilized, counsel must prepare a daily Settled Statement pursuant to California Rules of Court 8.137.
Motions in limine must include a sworn declaration confirming meet and confer and stating opposing party's position.
Court's wording
All motions in limine must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party and setting forth the opposing party’s position regarding the motion(s)
Los Angeles County Superior Court Rule 3.57 requires the parties to meet and confer before filing any motion in limine. All motions in limine must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party and setting forth the opposing party’s position regarding the motion(s)
Joint exhibit lists must include specific columns, exhibits pre-numbered, exchanged, with pagination and translation requirements, filed 5 court days before FSC.
Court's wording
submit to Dept. 107 the following JOINT documents at least five court days before the FSC: b. Filed-Joint Exhibit List -- include columns for DATE ID'd and DATE ADMITTED. Pursuant to California Rule of Court 3.1110(f) and Los Angeles County Superior Court Rules 3.52 and 3.53, all exhibits must be exchanged and pre-numbered, except for those anticipated in good faith to be used for impeachment or during rebuttal. For exhibits a party intends to admit into evidence, please indicate the moving party, stipulations on authentication in one column and stipulations on admissibility in the next column. If there are no objections, please state the basis for any objection i.e., hearsay, etc. Documentary exhibits consisting of more than one page must be internally paginated in sequential numerical order. Exhibits written in a foreign language must be accompanied by a certified English translation.
Joint witness lists must list all witnesses once with estimated testimony time, filed 5 court days before FSC.
Court's wording
submit to Dept. 107 the following JOINT documents at least five court days before the FSC: a. Filed-Joint Witness List -- All witnesses must be listed on one list. Do not repeat the name of a witness. Indicate the total time expected for that testimony, including direct, cross, and re-direct. At the end of the list, state the total time estimated for each witness’s testimony.
Pursuant to Los Angeles County Superior Court Rules 3.97 and 3.180, the parties shall not publish to the jury any exhibits or graphics at any time during trial except after being marked and received into evidence, or with the court's permission.
Failure to timely comply will result in monetary sanctions in the sum of $250 against counsel of record for violation of court orders, CCP section 177.5.
Fully edited, printed jury instructions must be delivered to Dept. 107, with a joint complete set of CACI instructions and separate sets for any disputed instructions.
Court's wording
Delivered-Jury instructions, fully edited, printed out and delivered to Dept. 107. Submit a joint set of CACI instructions with all information filled in — no remaining brackets or blanks. If instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction.
Delivered-3 Sets of Exhibit Books, tabbed and indexed, and delivered to Dept. 107. (One set for the clerk, one set for the judge, one set for the witness box).
Lodge-Depositions must be lodged with the Clerk of the Court prior to the start of trial, with Notice of Lodging and means of return.
No later than 48 hours before opening statement, the parties shall file and serve a trial brief indicating which causes of action and which affirmative defenses are still in issue.
No later than 48 hours before opening statement, the parties shall file and serve a trial brief indicating which causes of action and which affirmative defenses are still in issue.
If no court reporter is used, lead counsel must personally prepare a daily Settled Statement under CRC 8.137 after meet-and-confer sessions at lunch and close of the trial day, a task that cannot be delegated; unrepresented parties bear this responsibility themselves.
Court's wording
If a court reporter is not utilized, counsel must prepare a daily Settled Statement pursuant to California Rules o f Court 8.137. This means that if there is no court reporter, then lead counsel for each party must meet and confer at lunch and again at the close of the trial day to arrive at a settled statement. This task may not be delegated to another lawyer. If a party is unrepresented, then that party has the responsibility to meet with the other side to arrive at a settled statement.
The Court requires timely compliance with California Rules of Court, rule 3.300 Re: Notice of Related Cases.
Exhibits written in a foreign language must be accompanied by a certified English translation. Cal. Rule of Court 3.1110(g).
All exhibits must be exchanged and pre-numbered, except exhibits anticipated in good faith for impeachment or rebuttal.
Court's wording
Pursuant to California Rule of Court 3.1110(f) and Los Angeles County Superior Court Rules 3.52 and 3.53, all exhibits must be exchanged and pre-numbered, except for those anticipated in good faith to be used for impeachment or during rebuttal.
A joint witness list must be filed listing all witnesses once, with expected testimony time (direct, cross, re-direct) indicated for each witness.
Court's wording
Filed-Joint Witness List -- All witnesses must be listed on one list. Do not repeat the name of a witness. Indicate the total time expected for that testimony, including direct, cross, and re-direct. At the end of the list, state the total time estimated for each witness's testimony.
The exhibit list must identify the moving party, authentication and admissibility stipulations, and the basis for any objections, which the Court will likely rule on at the FSC.
Court's wording
For exhibits a party intends to admit into evidence, please indicate the moving party, stipulations on authentication in one column and stipulations on admissibility in the next column. If there are no objections, please state the basis for any objection i.e., hearsay, etc. The Court will likely rule on objections to admission of Exhibits at the Final Status Conference.
Filed-Joint Exhibit List -- include columns for DATE ID'd and DATE ADMITTED.
- Document
- Joint exhibit list
Include
- •Exhibit list
All demonstrative exhibits, not admitted into evidence, must be shown to the opposing party before use at trial. Any objections to the use of demonstrative exhibits must be brought to the court's attention in a timely manner and before publication to the jury.
Filed-Joint Statement of the Case. This is brief, neutral description of the case to be read to the jury. In most instances, it should not exceed two paragraphs.
If there is a lack of cooperation in preparing joint documents, then please file individual documents with a declaration explaining the difficulty.
A list of jury instructions with a disposition table (instruction number, proposing party, and court disposition columns) must be filed.
Court's wording
Filed-List of jury instructions -- Submit a disposition table which lists all jury instructions by number, the identity of the party or parties proposing the instruction, and columns for the court to indicate whether the instruction is given, modified, withdrawn, or refused.
verdict form, each party must submit their own proposed verdict form. Any proposed special verdict should be in a form that is easily used and understood by the jury, and which does not require the jury to answer unnecessary questions.
A proposed juror questionnaire must be filed if requested, and it may not ask about prospective jurors' residence locations.
Court's wording
Filed-Proposed Juror Questionnaire, if requested. Questionnaires will not include questions concerning the location of the prospective jurors' residences in accordance with changes to the Standards for Judicial Administration.
Ex parte applicants must review CRC 3.1200-3.1207 and LASC Rule 3.26, and satisfy the notice requirements and the affirmative factual showing of good cause.
Court's wording
Before bringing an ex parte application, counsel should review California Rules of Court 3.1200-3.1207 and Los Angeles County Superior Court Rule 3.26. Please pay particular attention to the notice requirements and the requirement of an affirmative factual showing of good cause.
Filing & Service rules
Electronic Filing Rules
Attorneys must comply with electronic filing requirements, while self-represented litigants without electronic filing means may file documents in the courtroom.
Compliance with electronic filing is required for attorneys. Please refer to the Court's website for electronic filing orders. Self-Represented Litigants without means for filing electronically may file their documents in the courtroom.
Page 3 | Filings
Attorneys must e-file; self-represented litigants without e-filing means may file paper in the courtroom.
Filings: Compliance with electronic filing is required for attorneys. Please refer to the Court’s website for electronic filing orders. Self-Represented Litigants without means for filing electronically may file their documents in the courtroom.
Page 3 | Filings
Filing Timing and Cure Windows
The IDC statement must be filed and served at least three court days before the scheduled IDC.
involved in a discovery dispute to be addressed in an IDC shall file and serve an IDC statement of no more than (5) pages at least three (3) court days before the scheduled IDC.
Page 4 | Discovery Motions
IDC statements must be filed at least 3 court days before the scheduled IDC.
involved in a discovery dispute to be addressed in an IDC shall file and serve an IDC statement of no more than (5) pages at least three (3) court days before the scheduled IDC.
Page 4 | Discovery Motions
A fee-waiver party's Request for Court Reporting Services must be filed at least ten calendar days before the hearing or trial.
The Request for Court Reporting Services by a Party with a Fee Waiver should be filed at least ten calendar days before the hearing or trial for which the reporter is requested.
Page 5 | Court Reporters
Motions in limine must be filed with statutory notice of 16 court days for the motion, 9 court days for the opposition, and 5 court days for the reply, and are heard at the final status conference without reserving a hearing date.
must be submitted with timely statutory notice (16 court days for motion, 9 court days for opposition, 5 court days for reply) so as to be heard at the final status conference. You do not need to reserve a date as the FSC will be the hearing date.
Page 8 | Motions in Limine
Joint FSC documents must be submitted at least 5 court days before the Final Status Conference.
submit to Dept. 107 the following JOINT documents at least five court days before the FSC:
Page 9 | Final Status Conference Orders
Joint Final Status Conference documents must be submitted to Dept. 107 at least five court days before the FSC.
submit to Dept. 107 the following JOINT documents at least five court days before the FSC:
Page 9 | Final Status Conference
Trial briefs must be filed no later than 48 hours before opening statement.
No later than 48 hours before opening statement, the parties shall file and serve a trial brief indicating which causes of action and which affirmative defenses are still in issue.
Page 11 | Trial Policies
Trial briefs must be filed and served no later than 48 hours before opening statement.
No later than 48 hours before opening statement, the parties shall file and serve a trial brief indicating which causes of action and which affirmative defenses are still in issue.
Page 11 | TRIAL POLICIES
A request for an official court reporter (form FW-020) must be filed at least 10 calendar days before the hearing or trial.
A party who has received a fee waiver pursuant to CRC 3.55(7) may request an official court reporter by filing form FW-020 (https://www.courts.ca.gov/documents/fw020.pdf ) at least 10 calendar days before the hearing or trial. (See CRC 2.956(c).)
Page 11 | TRIAL POLICIES
If the parties cannot agree on a settled statement, plaintiff presents its proposal and defendant presents a redlined counter-proposal at 8:00 am the following court morning.
If the parties are unable to agree upon a settled statement, then at 8:00 am the following court morning, the plaintiff will present its proposal and the defendant will present a red-lined version of its proposal against the plaintiffs proposal.
Page 12 | TRIAL POLICIES
Court reporter requests by fee waiver recipients must be filed at least 10 calendar days before the hearing or trial.
The Request for Court Reporting Services by a Party with a Fee Waiver should be filed at least ten calendar days before the hearing or trial for which the reporter is requested.
Page 5 | Court Reporters
Motions in limine may be entertained at any point during trial upon a showing of good cause.
The Court will entertain motions in limine throughout the trial if there is good cause shown.
Page 8 | Motions in Limine
Service and Proof of Service Rules
IDC statements must be served at least 3 court days before the scheduled IDC.
involved in a discovery dispute to be addressed in an IDC shall file and serve an IDC statement of no more than (5) pages at least three (3) court days before the scheduled IDC.
Page 4 | Discovery Motions
Filing Fees and Waivers
A filing fee is required for trial continuance requests.
A filing fee is required.
Page 2 | Continuances
A filing fee is required for trial continuances.
CONTINUANCES: Trial continuances must be heard on a noticed motion OR Ex Parte Application OR by Stipulation and Order with a mandatory declaration showing Good Cause. A stipulation alone without a good faith reason stated by declaration is insufficient. A filing fee is required.
Page 2 | Continuances
Jury fees must be posted no later than 30 days before trial.
Jury fees shall be posted no later than 30 days before trial.
Page 8 | Jury Fees
Jury fees must be posted no later than 30 days before trial.
JURY FEES Jury fees shall be posted no later than 30 days before trial.
Page 8 | Jury Fees
The Court does not provide a court reporter absent a fee waiver; a party with a CRC 3.55 fee waiver may request an official court reporter by filing form FW-020.
The Court does not provide a court reporter absent a fee waiver. A party who has received a fee waiver pursuant to CRC 3.55(7) may request an official court reporter by filing form FW-020 (https://www.courts.ca.gov/documents/fw020.pdf ) at least 10 calendar days before the hearing or trial. (See CRC 2.956(c).)
Page 11 | TRIAL POLICIES
A party who has received a fee waiver may request an official court reporter pursuant to California rule of Court 2.956(b)(3).
A party who has received a fee waiver may request an official court reporter pursuant to California rule of Court 2.956(b)(3).
Page 5 | Court Reporters
Courtesy Copy Requirements
Department 107 does not accept courtesy copies.
Department 107 does not accept courtesy copies.
Page 4 | Courtesy Copies
Department 107 does not accept any courtesy copies.
Courtesy Copies: Department 107 does not accept courtesy copies.
Page 4 | Courtesy Copies
Three tabbed, indexed exhibit books must be delivered to Dept 107 5 court days before FSC.
g. Delivered-3 Sets of Exhibit Books, tabbed and indexed, and delivered to Dept. 107. (One set for the clerk, one set for the judge, one set for the witness box).
Page 10 | Final Status Conference Orders
Joint CACI jury instructions must be delivered to Dept 107, no blanks, separate sets if disputed.
f. Delivered-Jury instructions, fully edited, printed out and delivered to Dept. 107. Submit a joint set of CACI instructions with all information filled in — no remaining brackets or blanks. If instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction.
Page 10 | Final Status Conference Orders
Pre-Motion Conference Requirements
Discovery motions require pre-filing meet and confer; unresolved disputes require an informal video IDC with the court.
Before filing a discovery motion, trial counsel (meaning the lawyers who will try the case) should meet and confer in person, by phone, or by videoconference to resolve, or at least narrow the dispute. If the dispute remains unresolved, counsel must contact the court staff to arrange an informal, video discovery conference (IDC) between counsel and Judge Harmon unless the Discovery Act requires no meet and confer.
Page 3 | Discovery Motions
Counsel considering filing a demurrer should review the new requirements, including meet and confer requirements, set forth in Code of Civil Procedure section 430.41, and rethink whether a demurrer is necessary or even advisable. Demurrers filed without compliance with the meet and confer requirements may be taken off calendar.
Counsel considering filing a demurrer should review the new requirements, including meet and confer requirements, set forth in Code of Civil Procedure section 430.41, and rethink whether a demurrer is necessary or even advisable. Demurrers filed without compliance with the meet and confer requirements may be taken off calendar.
Page 3 | Demurrers
Law and motion hearings in Department 107 must be scheduled through the CRS system, and parties may not reserve more than one hearing date for the same motion.
The Court reservation system (CRS) is required for scheduling law and motion hearings in Department 107. CRS is available 24 hours a day, 7 days a week and reservations can be made from a computer or smartphone. Please note, you are prohibited from reserving more than one hearing date for the same motion.
Page 3 | Law & Motion
If a discovery dispute remains unresolved after meet and confer, counsel must contact court staff to arrange an informal video discovery conference (IDC) with Judge Harmon, unless the Discovery Act requires no meet and confer.
If the dispute remains unresolved, counsel must contact the court staff to arrange an informal, video discovery conference (IDC) between counsel and Judge Harmon unless the Discovery Act requires no meet and confer.
Page 3 | Discovery Motions
Motions in limine require pre-filing meet and confer, sworn declaration, and 16/9/5 court day briefing schedule.
Los Angeles County Superior Court Rule 3.57 requires the parties to meet and confer before filing any motion in limine. All motions in limine must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party and setting forth the opposing party’s position regarding the motion(s) and must be submitted with timely statutory notice (16 court days for motion, 9 court days for opposition, 5 court days for reply) so as to be heard at the final status conference.
Page 8 | Motions in Limine
Before filing a discovery motion, trial counsel (meaning the lawyers who will try the case) should meet and confer in person, by phone, or by videoconference to resolve, or at least narrow the dispute.
Before filing a discovery motion, trial counsel (meaning the lawyers who will try the case) should meet and confer in person, by phone, or by videoconference to resolve, or at least narrow the dispute.
Page 3 | Discovery Motions
The parties should meet and confer before filing any motion and avoid filing any motion which is designed to delay the proceedings or filed solely for tactical reasons.
The parties should meet and confer before filing any motion and avoid filing any motion which is designed to delay the proceedings or filed solely for tactical reasons.
Page 3 | Law & Motion
Adjournment & Extension Requirements
Trial continuances require noticed motion, ex parte application, or stipulation with good cause declaration; filing fee required.
CONTINUANCES: Trial continuances must be heard on a noticed motion OR Ex Parte Application OR by Stipulation and Order with a mandatory declaration showing Good Cause. A stipulation alone without a good faith reason stated by declaration is insufficient. A filing fee is required. Please do not wait until the last minute to seek any continuances.
Page 2 | Continuances
Trial continuances require a noticed motion, ex parte application, or stipulation and order accompanied by a mandatory declaration showing good cause; a stipulation alone is insufficient.
Trial continuances must be heard on a noticed motion OR Ex Parte Application OR by Stipulation and Order with a mandatory declaration showing Good Cause. A stipulation alone without a good faith reason stated by declaration is insufficient.
Page 2 | Continuances
Trial and specified conferences may be continued by stipulation showing good cause, subject to Court approval at least 2 court days before the hearing.
Trial, trial setting conferences, Case management conferences and mandatory settlement conferences may be continued by stipulation setting forth the facts showing good cause for the continuance, subject to approval by the Court at least 2 court days before the hearing.
Page 4 | Continuances
If no stipulation is reached, any party may seek a continuance by noticed motion or ex parte application.
If there is no stipulation, any party may seek a continuance by noticed motion or ex parte application.
Page 4 | Continuances
Law and motion matters may be continued through the CRS system.
Law and motion matters may be continued by the CRS system.
Page 4 | Continuances
Chambers Communication Rules
DIFFICULTIES WITH SIGNING IN FOR REMOTE APPEARANCES: If you have difficulty signing in, please completely disconnect and try again. If you are on hold for more than 10 minutes and cannot hear anything, please call the department.
DIFFICULTIES WITH SIGNING IN FOR REMOTE APPEARANCES: If you have difficulty signing in, please completely disconnect and try again. If you are on hold for more than 10 minutes and cannot hear anything, please call the department.
Page 2 | Telephonic/Video Appearances
Parties should call the courtroom assistant to obtain available IDC dates.
Parties should call the courtroom assistant to obtain available dates.
Page 3 | Discovery Motions
Contact courtroom at (818) 989-6987 to reschedule multiple motions to the same date.
For multiple motions: After motions are reserved through the online reservation system, please call the courtroom directly at (818) 989-6987 for assistance with rescheduling them for the same date.
Page 3 | Law & Motion Scheduling
For multiple motions: After motions are reserved through the online reservation system, please call the courtroom directly at (818) 989-6987 for assistance with rescheduling them for the same date.
For multiple motions: After motions are reserved through the online reservation system, please call the courtroom directly at (818) 989-6987 for assistance with rescheduling them for the same date.
Page 3 | Law & Motion