Judge Huey P. Cotton
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Communication
Phone
Clerk
Page & Word Limits4 rules
A two (2) page summary of the dispute should be delivered to the Court twenty-four (24) hours prior to the scheduled IDC.
- Page limit
- Up to 2 pages
Except in extraordinary cases, trial briefs should not exceed twenty (20) pages in length.
- Trial brief
- Up to 20 pages
Except in extraordinary cases, trial briefs should not exceed twenty (20) pages in length.
- Trial brief
- Up to 20 pages
A two (2) page summary of the dispute should be delivered to the Court twenty-four (24) hours prior to the scheduled IDC.
- IDC summary
- Up to 2 pages
Document Format Requirements5 rules
The notice of case resolution shall be prepared on 28-lined legal paper to include caption, title, and case number.
- Paper size
- Legal
- Notice of case resolution
Formatting
- •28-lined legal paper
The notice of case resolution shall be prepared on 28-lined legal paper to include caption, title, and case number.
- Paper size
- Legal
- Lines per page
- 28
All requested instructions shall be submitted on perforated paper so as to allow for separation of the identification of the instruction from the text of the instruction, to be submitted to the jury for reference during deliberation.
Jury instructions must be submitted on perforated paper to allow separation of instruction ID and text.
- Jury instructions
Formatting
- •Perforated paper
Court's wording
All requested instructions shall be submitted on perforated paper so as to allow for separation of the identification of the instruction from the text of the instruction, to be submitted to the jury for reference during deliberation.
Each motion must be numbered sequentially (Plaintiff s Motion in Limine No., 1, Defendant’s Motion in Limine No.1).
Document Filing Requirements14 rules
The notice of case resolution shall be prepared on 28-lined legal paper to include caption, title, and case number.
- Document
- Notice of case resolution
Must include
- •Caption
- •Case number
The notice of case resolution shall be prepared on 28-lined legal paper to include caption, title, and case number.
Must include
- •Caption
- •Case number
Motions in limine must be in writing, served 10 court days before FSC, accompanied by LACCR 3.57 declaration, and numbered sequentially.
Court's wording
All motions in limine must be in writing and shall be served (in the possession of) opposing party or counsel at least ten (10) court days before the Final Status Conference date. Any opposition to any motion in limine must be in writing and served (in the possession of opposing party or counsel) at least five (5) court days prior to the Final Status Conference. Each motion in limine... shall be accompanied by a declaration in compliance with the requirements of Rule 3.57 of the LACCR. Each motion must be numbered sequentially (Plaintiff s Motion in Limine No., 1, Defendant’s Motion in Limine No.1).
Trial briefs are mandatory in all cases and must include a description of claims/defenses, stipulated and admitted facts, contested issues of fact and law with supporting authorities, major evidentiary issues, and a detailed statement of relief with a damages breakdown.
- Document
- Trial brief
Must include
- •Legal argument
- •Statement of facts
Court's wording
Trial briefs are mandatory in all cases and must include: 1.) A brief description of the claims and defenses presented and the issues to be decided. 2.) Statement of ultimate facts or issues to which you will stipulate. 3.) Those facts established by admissions in pleadings; admissions by discovery and/or stipulation of counsel. 4.) All contested issues of fact . 5.) All contested issues of law, together with points and authorities supporting the position of counsel. 6.) A list of major evidentiary issues anticipated and any relevant points and authorities in support of a position o f counsel. 7. ) A detailed statement of the relief claimed including a breakdown of the elements of damages claimed. 8.) Any other information that will assist the court
Each motion in limine, for the purpose o f precluding the mention or display of inadmissible and prejudicial matter in the presence of the jury, shall be accompanied by a declaration in compliance with the requirements of Rule 3.57 of the LACCR.
Objections to listed exhibits must be filed in writing with a brief statement of the grounds; objections not made in writing are deemed waived absent a showing of good cause.
Court's wording
Any party objecting to any listed exhibit, either as to foundation or admissibility, must file the objection in writing, together with 3 brief statement of the ground for objection. Any objections not so stated as per the foregoing shall be deemed waived except upon a showing of good cause.
Jury instructions shall be submitted as follows: (Note: Jury instructions not submitted in this format will be returned.)
The jointly prep ared witness list must include each witness’ name, a brief description of the testimony, a time estimate on direct and cross, any potential scheduling problems, and whether he/she will be assisted by an interpreter.
Jointly prepare a short, non-argumentative written statement of the case to be read to the jury.
Counsel must jointly prepare and exchange a complete Exhibit List including each document and item of physical evidence. Do not attach the exhibits to the list. Do not include depositions, declarations, motions, interrogatories, responses, or pleadings as exhibits. All items so referred to on the Exhibit List must be exchanged and/or reviewed by counsel prior to the Final Status Conference.
A general verdict form is mandatory and shall be jointly prepared in draft or final form. The special verdict form shall be adapted to CACI with proper spacing, particularly noted to allow for both clarity and direction. (LACCR 3-172,3.25 (i)(8).)
form, which includes: a. At the top of each requested jury instruction, identification of the party/parties requesting instruction; b. Whether the instruction is to be given as requested or as modified; c. Whether the instruction is withdrawn; and d. A signature line for the Court.
A copy of the exhibit list shall be provided to each counsel, the court, a n d the clerk of the court. Counsel shall comply with LACCR, Rules 3.52, 3.151, 3.53, 3.149, 3.150, and 3.152..
Requested CACI jury instructions must be submitted as a jointly edited packet, with any counsel-specific requested instructions inserted into that packet for the Court's consideration during trial.
Court's wording
1.) A jointly submitted packet of all requested and properly and fully edited CACI jury instructions to which there is objection (LACCR. Rule 8.25) (Note: Counsel are advised to make all edits necessary to eliminate duplicate instructions and inconsistencies.) 2.) Each counsel may submit specifically requested and properly edited instructions not requested by any opposing counsel. These instructions shall be inserted into the aforementioned packet of the jointly submitted jury instructions, all to be considered and discussed by the Court at an appropriate time during the pendency of the trial.
Filing & Service rules
Electronic Filing Rules
All hearing dates must be reserved through the Court Reservation System (CRS) at www.LACourt.ca.gov.
All hearing dates must be reserved using the Court Reservation System (CRS”) located at www.LACourt.ca.gov.
Civil cases
Page 4 | LAW AND MOTION
Filing Timing and Cure Windows
Ex parte applications in Department A are heard Monday through Thursday at 8:30 a.m.
EX PARTE APPLICATIONS: Ex parte applications for Department A are heard MONDAY-THURSDAY at 8:30 a.m.
Civil cases
Page 1 | EX PARTE APPLICATIONS
All party MSC briefs must be filed five court days before the Mandatory Settlement Conference.
All party MSC briefs must be filed five (5) court days prior to the conference.
Civil cases
Page 3 | ALTERNATE DISPUTE RESOLUTION
All party Mandatory Settlement Conference briefs must be filed five court days before the MSC.
All party MSC briefs must be filed five (5) court days prior to the conference.
Civil cases
Page 3 | Mandatory Settlement Conference
Law and motion matters must be filed and noticed per statutory deadlines, and using CRS does not alter or extend statutory deadlines or notice obligations.
All law and motion matters shall be filed and noticed for hearing not later than as required by statute. NOTE: Use of CRS does not alter or extend any statutory deadlines or obligations, including giving notice. It is your sole responsibility to serve and file the corresponding documents pursuant to the statutory requirements.
Civil cases
Page 4 | LAW AND MOTION
A two (2) page summary of the dispute should be delivered to the Court twenty-four (24) hours prior to the scheduled IDC.
A two (2) page summary of the dispute should be delivered to the Court twenty-four (24) hours prior to the scheduled IDC.
Civil cases
Page 4 | DISCOVERY
Expert-witness depositions must be completed no later than 15 days before the initial trial date.
All expert-witness depositions arc to be completed in accordance with applicable statutes (i.e., 15 days before the initial trial date—C.C.P. § 2024.010; 2024.030).
Civil cases
Page 5 | EXPERT WITNESSES
Expert witness information must be exchanged no later than 50 days before the initial trial date or 20 days after service of the demand, whichever is closer to trial, unless the court orders a different date for good cause.
Exchange o f information concerning expert trial witnesses shall be made no later than 50 days before the initial trial date or 20 days after service of the demand for exchange of information, whichever is closer to the trial date, unless the Court, on motion and a showing of good cause, orders an earlier or later date of exchange [C.C.P. § 2034.230 (a)(b)]. If date falls on a Saturday, Sunday, or holiday, the last day shall be the next court day closer to the trial date.
Civil cases
Page 5 | EXPERT WITNESSES
A written demand for exchange of expert trial witness information must be made no later than the 10th day after the initial trial date is set or 70 days before trial, whichever is closer, with weekend/holiday deadlines rolling to the next court day closer to trial.
Demand for exchange of information concerning expert trial witnesses shall be in writing and shall be made no later than the 10th day after the initial trial date has been set or 70 days before that trial date, whichever is closer to the trial date [C.C.P. §2034.2201. If the date falls on a Saturday, Sunday, or holiday, the last day shall be the next court day closer to the trial date.
Civil cases
Page 5 | EXPERT WITNESSES
If the case settles before the Final Status Conference, no appearance is required as long as a Request for Dismissal or Notice of Settlement is filed directly with the court at least two court days before the conference.
If the action is settled or otherwise resolved before the Final Status Conference, no appearance will be necessary as long as a Request for Dismissal of the entire action or Notice of Settlement under California Rules of Court, §3.1385 is filed direedy with this court at least two (2) court days before the scheduled Final Status Conference.
Civil cases
Page 7 | FINAL STATUS CONFERENCE ORDER
Counsel shall meet and confer in person at least ten (10) days before the Final Status Conference to exchange, discuss, and prepare for submission to this court all edited jury instructions; a jointly submitted draft of: final special verdict form(s); a statement of witnesses (see below).
Counsel shall meet and confer in person at least ten (10) days before the Final Status Conference to exchange, discuss, and prepare for submission to this court all edited jury instructions; a jointly submitted draft of: final special verdict form(s); a statement of witnesses (see below).
Civil cases
Page 7 | FINAL STATUS CONFERENCE ORDER
The required trial documents (including motions in limine and trial briefs) must be prepared, exchanged among all counsel, and filed directly in the department at least five days before the Final Status Conference.
The following documents shall be prepared and exchanged between (in the possession of) all counsel and filed directly in this department at least five (5) days before the Final Status Conference.
Civil cases
Page 8 | FINAL STATUS CONFERENCE ORDER
The following documents shall be prepared and exchanged between (in the possession of) all counsel and filed directly in this department at least five (5) days before the Final Status Conference.
The following documents shall be prepared and exchanged between (in the possession of) all counsel and filed directly in this department at least five (5) days before the Final Status Conference.
Civil cases
Page 8 | Final Status Conference Required Documents
A two (2) page summary of the dispute should be delivered to the Court twenty-four (24) hours prior to the scheduled IDC.
A two (2) page summary of the dispute should be delivered to the Court twenty-four (24) hours prior to the scheduled IDC.
Civil cases
Page 4 | Discovery - Informal Discovery Conference
In multi-party cases, counsel must supply the trial counsel list no later than the Final Status Conference date.
See attached list (for multi-party cases) to be supplied by counsel no later than the Final Status Conference date:
Civil cases
Page 6 | TRIAL COUNSEL
Exhibits need not be lodged before the first day of trial unless necessary for in limine determinations.
Exhibits need not be lodged prior to the first day of trial, except as necessary for any in limine determinations.
Civil cases
Page 9 | E. EXHIBIT LIST
A Request for Dismissal must be filed within twenty-one (21) days from case resolution.
upon resolution of this case and to file a Request for Dismissal within twenty-one (21) days from case resolution.
Civil cases
Page 4 | ALTERNATE DISPUTE RESOLUTION
Request for Dismissal must be filed within 21 days of case resolution.
Counsel is requested to notify the clerk of this court immediately by phone [(818) 901-4603] upon settlement or resolution of the action and to file a Request for Dismissal within twenty-one (21) days from case resolution.
Civil cases
Page 4 | Notice of Case Resolution
Service and Proof of Service Rules
Motions in limine must be in writing and served on (in the possession of) the opposing party or counsel at least ten court days before the Final Status Conference.
All motions in limine must be in writing and shall be served (in the possession of) opposing party or counsel at least ten (10) court days before the Final Status Conference date.
Civil cases
Page 8 | MOTIONS IN LIMINE
Oppositions to motions in limine must be in writing and served on (in the possession of) the opposing party or counsel at least five court days before the Final Status Conference.
Any opposition to any motion in limine must be in writing and served (in the possession of opposing party or counsel) at least five (5) court days prior to the Final Status Conference.
Civil cases
Page 8 | MOTIONS IN LIMINE
Filing Fees and Waivers
The party demanding a jury trial is responsible for posting jury fees in accordance with C.C.P. § 631.
Jury is demanded by _____________________________________ who shall be responsible for posting jury fees in accordance with applicable statute (i.e., C.C.P. §631).
Civil cases
Page 2 | JURY/NON-JURY
Filing Bundling Requirements
Motions in limine must be submitted in separate packets per motion; bundling multiple motions is prohibited.
In Limine motions shall be submitted in discrete packets (i.e. a separate packet for each motion) including the moving, opposition, and reply papers.
Civil cases
Page 8 | Motions in Limine
In limine motions must be submitted in discrete packets — a separate packet for each motion containing the moving, opposition, and reply papers.
In Limine motions shall be submitted in discrete packets (i.e. a separate packet for each motion) including the moving, opposition, and reply papers.
Civil cases
Page 8 | MOTIONS IN LIMINE
Pre-Motion Conference Requirements
Counsel must meet and confer on all motions in limine, and boilerplate form motions in limine are disfavored.
Boilerplate of form motions in limine are disfavored. Counsel shall meet and confer on all motions in limine.
Civil cases
Page 8 | MOTIONS IN LIMINE
Adjournment & Extension Requirements
Continuances of trial, FSC, or MSC dates require good cause, CRC Rule 3.1332 compliance, a court order, and must be made via ex parte application or noticed motion; stipulated continuances are prohibited.
Trial dates are firm and will not be continued absent a showing of good cause in accordance with C.R.C, Rule 3.1332. The parties will comply with the C.R.C., Rule 3.1332 with respect to continuances. A court order is required to change any dates in the case management order. Any request to change trial dates must be made by ex parte application or by noticed motion. Stipulated continuances of Trial, FSC, or MSC dates will not be permitted.
Civil cases
Page 2 | Trial Date Continuances
Notice: Counsel are respectfully requested not to become engaged in any matter that would interfere with the above trial date. Trial dates are firm and will not be continued absent a showing of good cause in accordance with C.R.C, Rule 3.1332. The parties will comply with the C.R.C., Rule 3.1332 with respect to continuances.
Notice: Counsel are respectfully requested not to become engaged in any matter that would interfere with the above trial date. Trial dates are firm and will not be continued absent a showing of good cause in accordance with C.R.C, Rule 3.1332. The parties will comply with the C.R.C., Rule 3.1332 with respect to continuances.
Civil cases
Page 2 | TRIAL DATE
Stipulated continuances of Trial, FSC, or MSC dates are not permitted.
Stipulated continuances of Trial, FSC, or MSC dates will not be permitted.
Civil cases
Page 2 | TRIAL DATE
Changing any case management order date requires a court order sought by ex parte application or noticed motion.
A court order is required to change any dates in the case management order. Any request to change trial dates must be made by ex parte application or by noticed motion.
Civil cases
Page 2 | TRIAL DATE
Chambers Communication Rules
Telephone number: {818) 901-4603
Telephone number: {818) 901-4603
Civil cases
Page 1 | Courtroom Information
Department A courtroom is located at 6230 Sylmar Avenue, Van Nuys, and may be reached by telephone at (818) 901-4603 during courtroom hours of 8:30 a.m.-12:00 p.m. and 1:30 p.m.-4:30 p.m.
Courtroom Information: 6230 Sylmar Avenue, Department A, Van Nuys, CA 91401. Telephone number: {818) 901-4603 Courtroom hours: 8:30 a.m. to 12:00 p.m. and 1:30 p.m. to 4:30 p.m.
Civil cases
Page 1 | Courtroom Information
For Further Discovery Motion dates or when otherwise directed, parties may contact the Clerk at (818) 901-4603.
For Further Discovery Motion dates, or if otherwise directed to do so. you may contact the Clerk in this court at (818) 901-4603.
Civil cases
Page 4 | LAW AND MOTION
Counsel are requested to immediately notify the clerk by phone at (818) 901-4603 upon settlement or resolution of the action.
Counsel is also requested to notify the clerk o f this court immediately by phone [(818) 901-4603] upon settlement or resolution of the action.
Civil cases
Page 7 | FINAL STATUS CONFERENCE ORDER