Judge Ian C. Fusselman
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Exhibits
- 5 copies • First Day of Trial
Adjournments
- the primary factors the Court considers with regard to requests for trial continuances are an affirmative showing of: 1. Reasonable diligence in preparing for trial. 2. Unforeseen circumstances preventing the parties from being prepared for trial. what preparation remains to be completed, why it has yet to be completed, and a schedule for completing those tasks.
- Trial continuance requests must include an affirmative showing of reasonable diligence in preparing for trial and unforeseen circumstances preventing trial preparation.
Request must include
Document Format Requirements6 rules
Documentary exhibits consisting of more than one page must be internally paginated in sequential numerical order.
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.
Motions in limine should be submitted in a separate tabbed binder with a table of contents.
- Motion in limine
Formatting
- •Table of contents
Documentary exhibits must be internally paginated; foreign language exhibits require certified English translation.
- Exhibits
Formatting
- •Internal pagination in sequential numerical order for multi-page exhibits
Court's wording
Documentary exhibits consisting of more than one page must be internally paginated in sequential numerical order. Photographs should be grouped together in separate exhibits by subject matter or other logically related groups rather than marking all photographs as one exhibit. Exhibits written in a foreign language must be accompanied by a certified English translation.
Photographs should be grouped together in separate exhibits by subject matter or other logically related groups rather than marking all photographs as one exhibit.
Motions in limine should be submitted in a separate tabbed binder with a table of contents.
- Motion in limine
Formatting
- •Must be submitted in a separate tabbed binder
Document Filing Requirements12 rules
For personal injury cases, please ensure that all pertinent medical records are included in the petition, including admission reports, discharge reports, and treatment records. There is no need to include nursing notes, labs, radiology reports or other records unless they contain other information.
Exhibits written in a foreign language must be accompanied by a certified English translation. Cal. Rule of Court 3.1110(g).
The joint witness list must list every witness once, with per-witness testimony time estimates (direct, cross, re-direct) and total time estimates for each party and the entire trial, except for witnesses listed only to preserve the right to call them.
Court's wording
All witnesses must be listed on a joint witness 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 party and the entire trial. The parties do not need to provide time estimates for witnesses they do not intend to call but are being listed to preserve the right to call them if needed.
Joint CACI jury instructions must be fully completed with no brackets or blanks, omit the 'Requested By' chart, place disputed instructions in separate sets identifying proposer and opposer, and include a disposition table.
Court's wording
Submit a joint set of CACI instructions will all information filled in – no remaining brackets or blanks. Do not include the chart at the top (i.e., "Requested By"). If instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction. 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.
If the parties cannot agree on the 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.
Every motion in limine must be accompanied by a sworn meet-and-confer declaration stating the opposing party's position, and failure to include it results in summary denial.
Court's wording
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). Failure to include such a declaration will result in summary denial of MIL.
Motions in limine should not be used to seek summary judgment, summary adjudication of issues, or judgement on the pleadings. Also, do not file motions in limine that simply state the law. For example, do not file motions seeking to exclude hearsay evidence. Instead, the motion must cite specific hearsay evidence that is expected to be proffered.
Motions in limine require a pre-filing meet and confer and a sworn declaration attesting to the conference and opposing party's position.
Court's wording
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). Failure to include such a declaration will result in summary denial of MIL.
If the petition contends that the minor has fully recovered from the injuries, a medical record or declaration should be submitted supporting that contention.
This is a brief, neutral description of the case to be read to the jury. In most instances, it should not exceed two paragraphs.
Provide a copy of all parties' expert designations without attachments.
Motions in limine should be submitted in a separate tabbed binder with a table of contents.
- Document
- Motion in limine
Should include
- •Table of contents
Filing & Service rules
Electronic Filing Rules
Ex parte applications, supporting documents, and oppositions must be e-filed; self-represented litigants are exempt.
All ex parte applications and documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the hearing. Any written opposition shall be electronically filed by 8:30 a.m. the day of the hearing. Pursuant to California Rules of Court, rule 2.253(b)(2), self-represented litigants are exempt from these mandatory Electronic Filing requirements.
Civil cases
Page 1 | Ex Parte Applications
Ex parte applications and all supporting documents must be electronically filed no later than 10:00 a.m. on the court day before the hearing.
All ex parte applications and documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the hearing.
Civil cases
Page 1 | Ex Parte Applications
Written opposition to ex parte applications must be electronically filed by 8:30 a.m. on the day of the hearing.
Any written opposition shall be electronically filed by 8:30 a.m. the day of the hearing.
Civil cases
Page 1 | Ex Parte Applications
Self-represented litigants are exempt from the mandatory electronic filing requirements under California Rules of Court, rule 2.253(b)(2).
Pursuant to California Rules of Court, rule 2.253(b)(2), self-represented litigants are exempt from these mandatory Electronic Filing requirements.
Civil cases
Page 1 | Ex Parte Applications
Filing Timing and Cure Windows
Ex parte applications and supporting documents must be filed by 10:00 a.m. the court day before the hearing.
All ex parte applications and documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the hearing.
Civil cases
Page 1 | Ex Parte Applications
Written oppositions to ex parte applications must be filed by 8:30 a.m. the day of the hearing.
Any written opposition shall be electronically filed by 8:30 a.m. the day of the hearing.
Civil cases
Page 1 | Ex Parte Applications
The filing deadline for written opposition to ex parte applications is 8:30 a.m. on the day of the hearing.
Any written opposition shall be electronically filed by 8:30 a.m. the day of the hearing.
Civil cases
Page 1 | Ex Parte Applications
The filing deadline for ex parte applications and supporting documents is 10:00 a.m. on the court day before the hearing.
All ex parte applications and documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the hearing.
Civil cases
Page 1 | Ex Parte Applications
Parties must reserve a motion hearing date through the online Court Reservation System (CRS) before filing any motion papers.
Parties must obtain a motion date via the online Court Reservation System (CRS) on the Los Angeles Court website “LA Court Online, Court Reservation System,” at www.lacourt.org to reserve a date prior to filing any motion papers.
Civil cases
Page 2 | Law and Motion
Parties must meet and confer and submit all required final status conference documents five court days before the FSC.
Parties must meet and confer and submit the following documents five court days before the FSC:
Civil cases
Page 3 | Trial Preparation - Final Status Conference
FSC required documents must be submitted five court days before the Final Status Conference.
Parties must meet and confer and submit the following documents five court days before the FSC:
Civil cases
Page 3 | Trial Preparation
Motions in limine should be filed and served in compliance with C.C.P. § 1005 using the FSC date as the hearing date. They be heard at the FSC or at a pre-trial conference scheduled at the time of the FSC.
Motions in limine should be filed and served in compliance with C.C.P. § 1005 using the FSC date as the hearing date. They be heard at the FSC or at a pre-trial conference scheduled at the time of the FSC.
Civil cases
Page 5 | Trial Preparation
Service and Proof of Service Rules
Motions in limine should be filed and served in compliance with C.C.P. § 1005 using the FSC date as the hearing date.
Motions in limine should be filed and served in compliance with C.C.P. § 1005 using the FSC date as the hearing date.
Civil cases
Page 5 | Motions in Limine
Filing Fees and Waivers
Motion fees must be paid at the time the motion date reservation is made online through CRS.
Motion fee payments are required at the time reservations are made online.
Civil cases
Page 2 | Law and Motion
Motion filing fees must be paid when reserving a motion date online via CRS.
Motion fee payments are required at the time reservations are made online.
Civil cases
Page 2 | Law and Motion
Courtesy Copy Requirements
Five complete sets of exhibits must be provided to the court on the first day of trial.
Five complete sets of exhibits need to be provided on the first day of trial.
Civil cases
Page 3 | Trial Preparation - Final Status Conference - 1. Joint Exhibit List
Sealing & Redaction Procedures
Materials submitted in support of a motion under seal must strictly comply with California Rules of Court, rule 2.551 et seq.
If counsel wishes to submit any materials in support of a motion under seal, counsel must strictly comply with California Rules of Court Rule 2.551 et. seq.
Civil cases
Page 2 | Law and Motion
Materials in support of a motion filed under seal must comply with California Rules of Court Rule 2.551 et seq.
If counsel wishes to submit any materials in support of a motion under seal, counsel must strictly comply with California Rules of Court Rule 2.551 et. seq.
Civil cases
Page 2 | Law and Motion
Filing Bundling Requirements
Motions in limine should be submitted in a separate tabbed binder with a table of contents.
Motions in limine should be submitted in a separate tabbed binder with a table of contents.
Civil cases
Page 5 | Motions in Limine
Pre-Motion Conference Requirements
Parties must reserve a motion date via the online CRS prior to filing any motion papers.
Parties must obtain a motion date via the online Court Reservation System (CRS) on the Los Angeles Court website “LA Court Online, Court Reservation System,” at www.lacourt.org to reserve a date prior to filing any motion papers.
Civil cases
Page 2 | Law and Motion
Parties must meet and confer before filing any motion in limine.
Los Angeles County Superior Court Rule 3.57 requires the parties to meet and confer before filing any motion in limine.
Civil cases
Page 5 | Motions in Limine
The Court does not hold informal discovery conferences, so parties should not expect a pre-motion conference for discovery disputes.
The Court does not conduct informal discovery conferences (IDC).
Civil cases
Page 1 | Discovery Disputes
Adjournment & Extension Requirements
the primary factors the Court considers with regard to requests for trial continuances are an affirmative showing of: 1. Reasonable diligence in preparing for trial. 2. Unforeseen circumstances preventing the parties from being prepared for trial. what preparation remains to be completed, why it has yet to be completed, and a schedule for completing those tasks.
the primary factors the Court considers with regard to requests for trial continuances are an affirmative showing of: 1. Reasonable diligence in preparing for trial. 2. Unforeseen circumstances preventing the parties from being prepared for trial. what preparation remains to be completed, why it has yet to be completed, and a schedule for completing those tasks.
Civil cases
Page 2 | Trial Continuances
Trial continuance requests must include an affirmative showing of reasonable diligence in preparing for trial and unforeseen circumstances preventing trial preparation.
As such, the primary factors the Court considers with regard to requests for trial continuances are an affirmative showing of: 1. Reasonable diligence in preparing for trial. 2. Unforeseen circumstances preventing the parties from being prepared for trial.
Civil cases
Page 2 | Trial Continuances
Chambers Communication Rules
Do not call the courtroom to reserve motion dates; use online CRS instead.
Please do not call the courtroom to reserve a motion date.
Civil cases
Page 2 | Law and Motion
Parties may not call the courtroom to reserve a motion date; reservations must be made online via CRS.
Please do not call the courtroom to reserve a motion date.
Civil cases
Page 2 | Law and Motion