Judge Gary D. Roberts
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Document Required by Standing or General Order, Pleading or Motion with Points and Authorities, Demurrer, Anti SLAPP Filing, Motion for Summary Judgment or Adjudication, Motion to Compel Further Discovery, Opposition to Ex Parte Application
- 1 copy • At Time of Electronic Filing
Filings >= 26 pages
- At Time of Electronic Filing
Motion
Motion in Limine
- No Later Than 5 Calendar Days Before Final Status Conference
Communication
Phone
Page & Word Limits2 rules
The parties shall complete a joint report (not to exceed five pages) and lodge it in Department 73 five (5) calendar days prior to the informal discovery conference.
- Joint report
- Up to 5 pages
In all trials, each party must file a trial brief limited to 10 pages.
- Trial brief
- Up to 10 pages per party
Court's wording
In all trials, each party shall file a trial brief succinctly (limited to 10 pages) 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 Format Requirements7 rules
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
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 (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) (“Exhibit Binders”).
- Binding
- Tabbed three-ring binder
- Exhibits
Formatting
- •Internally paginated by document
- •Properly marked
- •Exhibits organized numerically
Parties must attach tabbed copies of designated transcript pages to the Joint Chart and highlight each designation or counter-designation, with each party using a different color highlighter.
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.
- Exhibits
Formatting
- •Documentary exhibit copies must be one-sided (single-sided)
consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder
- Binding
- Tabbed three-ring binder
- Trial binder
Formatting
- •One-sided conformed 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.
- Exhibits
Formatting
- •Mark all non-documentary exhibits
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.
Document Filing Requirements28 rules
Ex parte applications must comply with the requirements of California Rules of Court, rules 3.1200-3.1207.
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.
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.
(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.
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. The joint exhibit list must reflect the result of this meet and confer.
Counsel and self-represented parties must jointly prepare and file a joint exhibit list with specified columns for each exhibit to be offered at trial.
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.
For jury trials, the parties must jointly prepare a complete set of full-text proposed jury instructions, editing CACI instructions to insert party names and remove blanks and irrelevant material.
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 brief, joint written statement of the case for the court to read to the jury. (Local Rule 3.25, subd. (g)(4).)
For jury trials, the parties must jointly prepare and file a Joint List of Proposed Jury Instructions stating, for each instruction, its number, title, requesting party, agreed/contested status, any objection, and whether it was given.
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”).
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
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”).
For jury trials, the parties must jointly prepare and file a proposed general or special verdict form acceptable to all parties, and if they cannot agree, each party must separately file a 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.
Designating parties' entries in the joint chart must include columns for witness number/name, date and type of testimony, page and line designations, objections, related counter-designations, 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.
Each side is limited to no more than 5 motions in limine, in the absence of leave of court.
The motion must include a declaration listing the proposed motions in limine as well as the authority pursuant to which each is properly brought as a motion in limine. The motion must also include a detailed description of the meet and confer efforts today concerning the matter raised in the motion in limine.
Motions in limine must be noticed for hearing at the Final Status Conference in compliance with Code of Civil Procedure section 1005 and Local 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 the requirements of Local Rule 3.57, subdivision (a).
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.
Each morning counsel must provide the Court Attendant with a written list of witnesses to be called that day including their full names with correct spellings and the order in which they will be called.
The joint witness list must use specified columns (witness name/expert status/accommodations, calling party, expected to testify, testimony description, estimated direct/cross/total examination hours) and end with a grand total of estimated testimony times.
Court's wording
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.
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.
parties to request the CACI instruction instead of a specially prepared jury instruction.
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
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 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.
When filing an ex parte application to advance a summary judgment/adjudication hearing because no reservation dates are available before trial, the moving party is advised to also include an alternative request to continue the trial to a date after the hearing.
Court's wording
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.
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. 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)
- Document
- Trial binder
Must include
- •Exhibit list
- •Table of contents
Filing & Service rules
Electronic Filing Rules
Civil filings are subject to the court's operative general Order re Mandatory Electronic Filing for Civil, which also governs when printed courtesy copies must be submitted.
In certain instances, and pursuant to the operative general Order re Mandatory Electronic Filing for Civil (http://www.lacourt.org/division/efiling/pdf/Civilefiling_FAQ.pdf), printed courtesy copies must be submitted to the Court.
Page 2 | 3. Motions
Under section 8 of the First Amended General Order governing Mandatory Electronic Filing for Civil, ex parte filings must be made electronically, except by self-represented litigants and other persons excused from electronic filing.
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 litigants and other persons excused from filing documents electronically:
Page 4
Filing Timing and Cure Windows
Parties intending to file a summary judgment or summary adjudication motion must reserve a hearing date immediately on the Court Reservation System and should not wait until discovery is completed, since hearing dates at least 30 days before trial may not be available later.
Any party who intends to file a motion for summary judgment or summary adjudication must reserve a hearing date immediately because the reservation dates for such motions are limited on the Court Reservation System, they fill up fast, and the present reservation dates available for such motions are very close to the trial dates being set by the court. Do not wait until discovery has been completed to reserve a hearing date for a motion for summary judgment or summary adjudication because, at a later date, hearing dates might not be available at least 30 days before the trial date set in your case.
Page 3 | 4. Motions for Summary Judgment/Adjudication
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, except for self-represented litigants and others excused from electronic filing.
with the exception of self- represented litigants and other persons excused from filing documents electronically: 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 4
Written opposition to an ex parte application must be electronically filed by 8:30 a.m. on the day of the ex parte hearing, except for self-represented litigants and others excused from electronic filing.
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 4
The joint report must be lodged in Department 73 five calendar days before the informal discovery conference.
The parties shall complete a joint report (not to exceed five pages) and lodge it in Department 73 five (5) calendar days prior to the informal discovery conference.
Page 6 | 7. Discovery Disputes
Counsel and self-represented parties must file the listed trial documents no later than five calendar days before the Final Status Conference, and any documents not previously completed in the required manner will be finalized at the FSC.
No later than five calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall file the documents listed below. PLEASE NOTE: to the extent not previously completed in the required manner, these documents will be finalized at the Final Status Conference. Please do not make any other plans for the day of the FSC;
Page 8 | 2. TRIAL DOCUMENTS TO BE FILED
Relief from the motions in limine limit must be sought by noticed motion set for hearing before the motions in limine due date.
Relief from this limit may be sought by noticed motion, which must be set for hearing prior to the due date of the motions in limine.
Page 14 | 3. Motions in Limine
A jointly prepared Trial Binder must be lodged in Department 73 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 73 a Trial Binder,
Page 15 | 5. Trial Binder
Service and Proof of Service Rules
Counsel and self-represented parties must exchange all trial exhibits no later than 21 calendar days before the Final Status Conference.
No later than 21 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
Courtesy Copy Requirements
Printed courtesy copies must be submitted to the Court in certain instances as governed by the general Order re Mandatory Electronic Filing for Civil.
In certain instances, and pursuant to the operative general Order re Mandatory Electronic Filing for Civil (http://www.lacourt.org/division/efiling/pdf/Civilefiling_FAQ.pdf), printed courtesy copies must be submitted to the Court.
Page 2 | 3. Motions
Pleadings and motions of 26 pages or more, counting attachments such as declarations and exhibits, require a printed courtesy copy at the time of electronic filing.
Pleadings and motions (including attachments such as declarations and exhibits) of 26 pages or more.
Page 3 | 3. Motions
Courtesy copies of all summary judgment/summary adjudication papers must be delivered to the Department.
As stated, courtesy copies of all summary judgment/summary adjudication papers shall be delivered to the Department.
Page 3 | 4. Motions for Summary Judgment/Adjudication
the time of electronic filing, a printed courtesy copy is required for the following documents: • Any printed document required pursuant to a Standing or General Order. • Pleadings and motions (including attachments such as declarations and exhibits) of 26 pages or more. • Pleadings and motions that include points and authorities. • Demurrers. • Anti-SLAPP filings, pursuant to Code of Civil procedure section 425.16. • Motions for Summary Judgment/Adjudication. • Motions to Compel Further Discovery. • Opposition to an ex parte application.
the time of electronic filing, a printed courtesy copy is required for the following documents: • Any printed document required pursuant to a Standing or General Order. • Pleadings and motions (including attachments such as declarations and exhibits) of 26 pages or more. • Pleadings and motions that include points and authorities. • Demurrers. • Anti-SLAPP filings, pursuant to Code of Civil procedure section 425.16. • Motions for Summary Judgment/Adjudication. • Motions to Compel Further Discovery. • Opposition to an ex parte application.
Page 3 | 3. Motions
The parties must jointly prepare and lodge a Motions in Limine Binder in Department 733 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 733 a Motions in Limine Binder.
Page 14 | 3. Motions in Limine
Filing Bundling Requirements
The Motions in Limine Binder must contain one-sided conformed copies of all motions in limine, opposition, and reply papers, organized in tabbed three-ring binders with opposition and reply papers placed directly behind the moving papers and colored sheets separating each set.
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 14 | 3. Motions in Limine
Pre-Motion Conference Requirements
Motion hearing dates must be reserved in advance via the Court Reservation System (CRS) at www.lacourt.ca.gov, and motions are 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 2 | 3. Motions
Parties must meet and confer in good faith on each discovery dispute, and a detailed letter or email alone does not satisfy the requirement unless followed by a telephone call or in-person meeting (or a genuine attempt to arrange one).
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. In general, a letter or email laying out in detail all of the concerns about the discovery in question will not satisfy this requirement, unless it is followed up by a telephone call or in person meeting or a genuine attempt to arrange for a telephone call or in person meeting.
Page 5 | 7. Discovery Disputes
Counsel and self-represented parties with full authority to stipulate must participate in the informal discovery conference with the court.
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 informal discovery conference with the court.
Page 6 | 7. Discovery Disputes
Counsel and self-represented parties must meet and confer no later than 14 calendar days before the Final Status Conference to prepare trial documents and binders, attempt stipulations on exhibits, motions in limine, and facts and legal issues, and attempt to settle the case.
No later than 14 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-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 limine, (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 8 | 1. MEET AND CONFER
The court expects and encourages informal resolution of 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 | 7. Discovery Disputes
If meet and confer fails, either party may request that the court conduct an informal discovery conference to discuss the disputed discovery matters.
If an informal resolution is not reached after meeting and conferring, then either party may request that the court conduct an informal discovery conference for the purpose of discussing discovery matters in dispute between the parties. (Code Civ. Proc., § 2016.080.)
Page 5 | 7. Discovery Disputes
The court makes no orders at the informal discovery conference unless the parties stipulate, because the conference is not a motion hearing.
Because an informal discovery conference is not a hearing on a motion, the court does not make any orders at the informal discovery conference unless the parties stipulate.
Page 6 | 7. Discovery Disputes
The court encourages the parties to schedule and conduct an informal discovery conference before filing a discovery motion.
the court encourages the parties' counsel and any self-represented parties to schedule and conduct an informal discovery conference before a discovery motion is filed.
Page 6 | 7. Discovery Disputes
Adjournment & Extension Requirements
Trial will proceed without witnesses who fail to timely appear, and continuances will not be granted because of witnesses who do not appear in a timely manner.
If witnesses are not under subpoena and do not timely appear, trial will proceed without them. Continuances will not be granted due to witnesses who do not appear in a timely manner.
Page 16 | 6. Witnesses
All parties and counsel must appear in person for both the final status conference and the first day of trial unless they obtain prior leave of court, and the final status conference is an all-day working session to finalize trial documents.
ALL PARTIES AND COUNSEL ARE ORDERED TO APPEAR IN PERSON FOR BOTH THE FINAL STATUS CONFERENCE AND THE FIRST DAY OF TRIAL, ABSENT PRIOR LEAVE OF COURT. The Final Status Conference will be a working session to finalize the trial documents, and the parties and counsel must plan to spend all day here.
Page 17 | Trial Preparation Order
Responding parties are expected to grant moving parties a reasonable extension of time to file discovery motions so the parties can hold an informal discovery conference.
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 6 | 7. Discovery Disputes
Attorneys and 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
Chambers Communication Rules
After electronically lodging a document requiring court action (e.g., stipulation and proposed order, proposed judgment), parties should refrain from calling court staff to ask about it (sentence continues beyond this excerpt).
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
Page 6 | 9. Electronically Lodged Documents Which Require Action by the Court
To request an informal discovery conference, please call the Department and obtain a date.
To request an informal discovery conference, please call the Department and obtain a date.
Page 6 | 7. Discovery Disputes