Judge Gregory W. Alarcon
Individual Rules, Standing Orders & Policies
Document Format Requirements14 rules
Three-ring binders with numbered divider tabs containing all exhibits marked for identification must be prepared prior to trial, including copies for the Court, Clerk, testifying witnesses and all counsel.
- Binding
- Tabbed three-ring binder
- Exhibits
Three-ring binders with numbered divider tabs containing all exhibits marked for identification must be prepared prior to trial, including copies for the Court, Clerk, testifying witnesses and all counsel.
- Binding
- Tabbed three-ring binder
- Exhibits
Formatting
- •Must be prepared prior to trial
Demonstrative evidence and blow-ups must be marked for identification and shown to or played for opposing counsel before trial.
Exhibit marking must conform to S.C.L.A.C. Rule 3.53: Arabic numerals in sequential party-number blocks, with multi-page documentary exhibits internally paginated in sequential order.
- Exhibits
Formatting
- •Exhibits must be marked using Arabic numerals
Court's wording
Your joint exhibit list must conform to S.C.L.A.C. Rule 3.53, which provides: "The most efficient method of marking exhibits is the use of Arabic numerals in which each party is allocated a block of numbers to be used sequentially. For instance, plaintiff may be allocated numbers 1 to 200, the first defendant numbers 201 to 400, and the second defendant numbers 401 to 600. Documentary exhibits consisting of more than one page must be internally paginated in sequential numerical order to facilitate reference to the document during interrogation of witnesses."
Hard copies of agreed and not-agreed jury instructions must be filed 5 court days before the final status conference.
- File type
- Paper
- Jury instructions
Court's wording
Five court days before the final status conference, please file a “hard copy” of jointly agreed instructions, and each counsel's separate statement set of "not-agreed-upon" instructions with your objections.
A computer disk in Word format of the agreed upon instructions should be brought to court on the first day of trial.
- File type
- Word
- Jury instructions
Formatting
- •Agreed-upon instructions must be provided on a computer disk in Word format
- •Disk must be brought to court on the first day of trial
Any submitted jury instructions must be in proper format per California Rules of Court, rule 2.1055, with correct party references and no blanks, brackets, empty spaces, or inapplicable options.
- Jury instructions
Formatting
- •Incorporate all changes and modifications applicable to the case
- •Correct references to the parties required
Court's wording
a set of agreed jury instructions (and, if necessary, a separate set of instructions to which there is disagreement), in the proper format with all changes and modifications applicable to the case in accordance with California Rules of Court, rule 2.1055, (i.e., correct references to the parties, no blanks, brackets, empty spaces, or inapplicable options);
Please do not: • Fail to premark your exhibits. • Expect the clerk to keep track of your exhibits. • Produce exhibits at trial which opposing counsel has never seen, unless they are used for impeachment. • Fail to produce the requisite numbers of exhibit books.
- Exhibits
Formatting
- •Exhibits must be premarked
- •Counsel may not expect the clerk to keep track of exhibits
- •The requisite numbers of exhibit books must be produced
Documents with original page numbers, or numbers which were attached to deposition transcripts, should be re- numbered (e.g., 31-1, 31-2, etc.). Avoid using letters for exhibits. Each photograph should have its own exhibit number and be presented separately (e.g., Ex. 1-1, Ex. 1-2, etc.).
- Exhibits
Formatting
- •Do not use letters for exhibits
A CD in Word format should be brought to court on the first day of trial.
- File type
- Word
As with jury instructions, prepare a computer disk of the proposed verdict form and have it ready at trial.
A computer disk in Word format of the agreed upon instructions should be brought to court on the first day of trial.
- File type
- Word
- Jury instructions
In drafting a form of special verdict, counsel should rely upon the suggested formats set forth in the CACI instructions.
A CD in Word format should be brought to court on the first day of trial.
- File type
- Word
Document Filing Requirements10 rules
At least five days before the final status conference, counsel must serve and file pre-marked exhibit lists, jury instruction requests, trial witness lists, and a proposed short statement of the case.
Court's wording
(1) At least five days prior to this conference, counsel must serve and file lists of pre-marked exhibits to be used at trial [see Local Rules 3.151, 3.53 and 3.149], jury instruction requests, trial witness lists, and a proposed short statement of the case to be read to the jury panel explaining the case. S.C.L.A.C. Rule 3.25 (f) (1).
You are required to comply with S.C. L.A.C. Rule 3.25(f)-(h) concerning preparation for the final status conference and trial.
Counsel must meet and confer to prepare a joint list of exhibits, which will be marked for identification and introduced at trial.
All original depositions must be lodged with the court prior to the beginning of trial.
The court may, in its discretion, require an in-person meeting of counsel and joint trial documents (early submission of trial documents, joint jury statement, joint witness list, joint exhibit list, agreed jury instructions in proper format, and an agreed special verdict form with interrogatories).
- Document
- Joint trial documents
Must include
- •Exhibit list
Court's wording
S.C.L.A.C. Rule 3.25(g)(2)-(8) allows the court, in its discretion, to require: "an 'in person" meeting of counsel before the final status conference concerning the submission to the court of joint trial documents: the submission of trial documents to the court more than five days before the final status conference; a joint statement to be read to the jury; a joint witness list; a joint exhibit list; a set of agreed jury instructions (and, if necessary, a separate set of instructions to which there is disagreement), in the proper format with all changes and modifications applicable to the case in accordance with California Rules of Court, rule 2.1055, (i.e., correct references to the parties, no blanks, brackets, empty spaces, or inapplicable options); and an agreed special verdict form with interrogatories."
Be certain to note objections filed in a separate document for the court.
The opposing party should not only state the grounds for opposition in the caption but also provide the reasons for the opposition with pertinent legal authorities and factual reasons.
- Document
- Opposition
- Placement
- Caption
The memorandum of points and authorities in support of the motion in limine should avoid boilerplate verbiage and citations. Vague motions to “exclude testimony” without specifics do not assist the Court. Use appropriate and brief citations to support legal authorities and evidence.
Make additional copies of the witness list for each juror. Confer with opposing counsel regarding drafting a single list of witnesses for trial.
If counsel cannot agree in advance on a verdict form, alternative verdict forms should be submitted.
Filing & Service rules
Filing Timing and Cure Windows
Pre-trial documents must be filed 5 court days before the final status conference.
You are required to file your pre-trial documents five (5) court days before the final status conference.
Civil cases
Page 1 | FINAL TRIAL PREPARATION
Pre-trial documents must be filed five court days before the final status conference.
You are required to file your pre-trial documents five (5) court days before the final status conference.
Civil cases
Page 1 | FINAL TRIAL PREPARATION
Counsel must serve and file pre-marked exhibit lists, jury instruction requests, trial witness lists, and proposed case statement 5 days before the final status conference.
At least five days prior to this conference, counsel must serve and file lists of pre-marked exhibits to be used at trial [see Local Rules 3.151, 3.53 and 3.149], jury instruction requests, trial witness lists, and a proposed short statement of the case to be read to the jury panel explaining the case. S.C.L.A.C. Rule 3.25 (f) (1).
Civil cases
Page 1 | FINAL TRIAL PREPARATION
A joint exhibit list must be filed five court days before the final status conference.
A joint exhibit list is required to be filed five (5) court days before the final status conference.
Civil cases
Page 3 | VI. EXHIBIT LIST
A joint exhibit list must be filed 5 court days before the final status conference.
A joint exhibit list is required to be filed five (5) court days before the final status conference.
Civil cases
Page 3 | EXHIBIT LIST
All original depositions must be lodged with the court before trial starts.
All original depositions must be lodged with the court prior to the beginning of trial.
Civil cases
Page 4 | EXHIBIT LIST
Motions in limine must be filed 5 court days before the final status conference.
Motions in limine are due five (5) court days before the final status conference.
Civil cases
Page 4 | MOTIONS IN LIMINE
Motions in limine are due five court days before the final status conference and will be heard on the day of trial unless specially set as noticed motions.
Motions in limine are due five (5) court days before the final status conference. Unless specially set as noticed motions, they will be heard on the day of trial.
Civil cases
Page 4 | VII. MOTIONS IN LIMINE
Oppositions to motions in limine must be filed no less than 5 court days before trial.
Oppositions are due no less than five court days before trial.
Civil cases
Page 5 | MOTIONS IN LIMINE
Motions in limine must be filed five court days before the final status conference and will be heard on the day of trial unless specially set.
Although motions in limine must be filed five court days before the final status conference in this department, they will be heard on the day of trial unless specially set.
Civil cases
Page 5 | VII. MOTIONS IN LIMINE
Five court days before the final status conference, parties must file a hard copy of jointly agreed instructions plus each counsel's separate statement of not-agreed-upon instructions with objections.
Five court days before the final status conference, please file a “hard copy” of jointly agreed instructions, and each counsel's separate statement set of "not-agreed-upon" instructions with your objections.
Civil cases
Page 5 | JURY INSTRUCTIONS
A joint set of proposed, accepted, and unaccepted jury instructions is due five court days before the final status conference.
A joint set of proposed, accepted and unaccepted jury instructions are due five (5) court days before the final status conference.
Civil cases
Page 5 | JURY INSTRUCTIONS
Oppositions to motions in limine, including Evidence Code section 402 hearing requests, are due no less than five court days before trial.
Oppositions are due no less than five court days before trial. This includes requests for hearing under Evidence Code section 402.
Civil cases
Page 5 | VII. MOTIONS IN LIMINE
Joint jury instructions must be filed 5 court days before the final status conference.
A joint set of proposed, accepted and unaccepted jury instructions are due five (5) court days before the final status conference.
Civil cases
Page 5 | JURY INSTRUCTIONS
A joint witness list with time estimates for direct and cross-examination is due five court days before the final status conference.
A joint witness list with time estimates for direct and cross-examination is due five (5) court days before the final status conference.
Civil cases
Page 6
Joint witness list with time estimates must be filed 5 court days before the final status conference.
A joint witness list with time estimates for direct and cross-examination is due five (5) court days before the final status conference.
Civil cases
Page 6
An agreed proposed joint special or general verdict form must be filed five court days before the final status conference.
An agreed proposed joint special verdict form with interrogatories or a general verdict form must be filed five (5) court days before the final status conference.
Civil cases
Page 7 | XI. VERDICT FORM
Joint special verdict or general verdict form must be filed 5 court days before the final status conference.
An agreed proposed joint special verdict form with interrogatories or a general verdict form must be filed five (5) court days before the final status conference.
Civil cases
Page 7 | VERDICT FORM
A proposed joint verdict form must be filed together with the pre-trial conference documents.
A proposed joint verdict must be filed with the pre-trial conference documents.
Civil cases
Page 7 | XI. VERDICT FORM
Service and Proof of Service Rules
All exhibits must be exchanged with opposing counsel early, long before trial.
All exhibits are to be exchanged early, long before jury
Civil cases
Page 3 | VI. EXHIBIT LIST
Demonstrative evidence must be marked and shown/played to opposing counsel before trial.
Demonstrative evidence and blow-ups must be marked for identification and shown to or played for opposing counsel before trial.
Civil cases
Page 4 | EXHIBIT LIST
Filing Bundling Requirements
Each motion in limine must be filed separately with its own supporting papers, and pleadings may not be stapled, bundled together, or filed as an omnibus motion.
Each motion should be filed separately with its own points and authorities, supporting declarations and other evidence. Please do not staple or bundle the individual pleadings together with other motions in limine or file them as an “omnibus” series of motions in a single pleading.
Civil cases
Page 5 | VII. MOTIONS IN LIMINE
Bundling or filing omnibus motions in limine is prohibited; each motion must be filed separately.
Please do not staple or bundle the individual pleadings together with other motions in limine or file them as an “omnibus” series of motions in a single pleading.
Civil cases
Page 5 | MOTIONS IN LIMINE
Pre-Motion Conference Requirements
The trial attorneys should meet and confer before generating unnecessary motions in limine.
The trial attorneys should meet and confer before generating unnecessary motions in limine.
Civil cases
Page 4 | VII. MOTIONS IN LIMINE