Judge James I. Montgomery Jr.
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Documents with Declarations, Documents with Exhibits
Exhibits
- 2 copies • At Outset of Trial
Final Status Conference Documents
- At FSC Hearing
Lengthy Motion for Summary Judgment or Adjudication, Lengthy Opposition to Motion for Summary Judgment or Adjudication
Communication
Phone
Chambers
Document Format Requirements17 rules
Attachments to primary documents must be bookmarked (e.g. depositions, declarations, exhibits, etc.);
Each document accompanying a single pleading must be filed as a separate digital PDF document;
- File type
- Documents accompanying pleading
The table of contents for any filing must be bookmarked;
Electronic documents must be electronically filed in PDF, test searchable format when technologically feasible without impairment of the document's image;
- File type
Electronic documents (including declarations, proofs of service, and exhibits) must be bookmarked per CRC 3.1110(f)(4), with links to each bookmarked item's first page and titles that identify and briefly describe the item.
Court's wording
Electronic documents, including but not limited to, declarations, proofs of service, and exhibits, must be bookmarked within the document pursuant to California Rules of Court, rule 3.1110(f)(4). Electronic bookmarks must include links to the first page of each bookmarked item (e.g. exhibit, declaration, deposition excerpt) and with bookmark titles that identify the bookmarked item and briefly describe the item;
All electronically filed documents must be text searchable and bookmarked.
All deposition excerpts referenced in briefs must be marked on the transcripts attached as exhibits. (Cal. Rules of Court, rule 3.1116(c).)
The exhibits shall be placed in one or more 3-ring binders for ease of access and shall be properly marked.
- Binding
- Three-ring binder
- Exhibits
Formatting
- •Exhibits shall be properly marked
Special instructions should be submitted in a format suitable for jury review, i.e., citations of authority and the identity of the requesting party shall be placed above the text.
- Jury instructions
Formatting
- •Format suitable for jury review
Parties must attach designated transcript page copies to the joint chart with numbered tabs separating each transcript, and each designation must be highlighted 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
- •Copies of documentary exhibits must be one-sided copies
The Motions in Limine Binder must contain one-sided conformed copies tabbed in numerical order in three-ring binders, with opposition/reply behind each motion separated by colored sheets.
- Binding
- Tabbed three-ring binder
- Motions in limine binder
Formatting
- •Tabbed in numerical order
Court's wording
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.
The parties shall organize proposed jury instructions into group 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.
- Jury instructions
Formatting
- •Each group must be labeled by cover sheets
Each exhibit shall be internally paginated.
- Exhibits
Formatting
- •Each exhibit shall be internally paginated
Non-documentary exhibits shall be represented in the binder with a simple written description.
The use of hyperlinks within documents (including attachments and exhibits) is helpful to the court and strongly encouraged;
The Trial Binder must be organized with tabbed sections A through I containing trial briefs, joint witness and exhibit lists, jury statements and instructions, verdict forms, deposition designations, and operative pleadings, with only tabs A, B, C, H, and I required in non-jury trials.
Court's wording
without a jury, the Trial Binder shall only include the documents listed under tabs A, B, C, H, and I): Tab A: Trial Briefs 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) Tab H: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab I: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).
Document Filing Requirements41 rules
Ex parte applications must comply with the requirements of California Rules of Court, rules 3.1200-3.1207.
Ex parte applications are reserved for exigent circumstances and must include an affirmative factual showing in a declaration of irreparable harm, immediate danger, or another statutory basis for relief.
Court's wording
Ex parte applications are reserved for exigent circumstances and must comply with Cal. Rules of Court, rule 3.1202(c): "An applicant must make an affirmative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte."
After reserving a motion hearing date, the reservation requestor must submit the moving papers for filing with the reservation receipt number printed on the face page of the document under the caption and attach the reservation receipt as the last page.
- Document
- Moving papers
- Placement
- Caption
(The court requires this same showing in declarations filed in support of, and in opposition to, motions to compel further discovery responses.)
Counsel shall prepare a joint set of exhibits.
A jury panel cannot be ordered until an acceptable verdict form has been prepared.
Each such special instruction shall indicate the party/parties requesting the instruction.
A joint set of Jury Instructions. Counsel shall meet and confer to prepare this joint set.
A Joint General Verdict Form, and/or any special verdict forms that are requested.
All blanks on CACI instructions must be filled in and any irrelevant portions stricken.
Any proposed special instruction to which counsel cannot agree shall be submitted as a separate set or sets.
The parties must jointly prepare and file a witness list (excluding impeachment and rebuttal witnesses) organized in columns showing each witness's name in alphabetical order, expert status and any special accommodations needed, the calling party, whether the witness is expected to testify, and a brief description of the expected testimony.
Court's wording
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. (Los Angeles County Court Rule (Local rule) 3.25, subd. (g)(5).) The joint witness list shall be organized with columns (in the format set forth below) that state: (1) the name or 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,
Witnesses not included on the joint witness list may be excluded from testifying at trial (except for impeachment or rebuttal) unless the party first shows good cause to the court.
Court's wording
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 in the witness list must first make a showing to the court of good cause.
Counsel and self-represented parties must jointly prepare and file a joint exhibit list containing seven required columns of information for each exhibit to be offered at trial.
- Document
- Joint exhibit list
Must include
- •Exhibit list
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) that state, as to each exhibit any party intends to offer at trial: (1) the exhibit number (not letter), (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) the date the exhibit was marked for identification, and (7) date the exhibit was admitted into evidence.
In jury trials, counsel and self-represented parties must jointly prepare and file a joint list of proposed jury instructions stating six required items for each instruction.
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) that states, as to each jury instruction: (1) the jury instruction number (listed in numerical order), (2) the title of the jury instructions, (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).
For jury trials, 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, subd. (g)(8).) If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.
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 Jury Instructions (CACI) instructions, inserting party names, and eliminating blanks, brackets, and other irrelevant or inapplicable material.
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 in the specified format.
Court's wording
If the 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 Designation for Deposition and Former Testimony).
Each designation in the joint chart must include six required columns: witness designation number/name, date and type of testimony, page and line designations, objections, counter-designation information, and the court's ruling.
Court's wording
In the joint chart, each designating party's designation of deposition or former testimony shall include column that 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.
Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.
- Document
- Opposition and reply papers
- Placement
- Caption
Parties must jointly prepare at least five identical tabbed exhibit binders organized numerically in three-ring binders (court, judicial assistant, witnesses, and each party).
Court's wording
The parties counsel and any self-represented parties shall work together to jointly prepare at least five identical sets of tabbed, exhibit binders organized numerically in three-ring binders (Exhibit Binders): a set for the court, a set for the judicial assistant, a set for the witnesses, and a set for each party.
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 more than one motion in limine shall number them consecutively.
Each party must submit a Trial Brief containing a description of claims and defenses, the primary legal issues with supporting authorities, the relief and damages sought, and any other information assisting the court with trial matters.
- Document
- Trial brief
Include
- •Legal argument
Court's wording
A Trial Brief from each party containing: 1. A brief description of the claims and defenses subject to litigation; 2. A list of the primary legal issues anticipated with supporting points and authorities; 3. A brie statement of the relief sought and a calculation of the damages sought; and 4. Any other information which counsel believes may assist the court in ruling upon trial objections or other matters that may arise at trial.
The court generally finds that meeting and conferring by only exchanging letters and e-mails, as opposed to actual conversation, is insufficient and ineffective. Thus, in requesting an IDC, the parties should indicate on their IDC forms what efforts were made to informally resolve pending discovery issues, which should include in-person or virtual meetings or telephonic communications.
Upon stipulation of the parties, the court is also available to conduct mandatory settlement conferences. A Stipulation and Order re Settlement Conference with Trial Judge is required to be signed by all parties.
Department 516 normally will order the parties' compliance with a Trial Preparation Order (example attached hereto). The court expects the parties' counsel and any self-represented parties to work together to jointly prepare and submit the documents and binders required by that order.
Prior to the Final Status Conference, counsel are to meet and confer to exchange, discuss, and prepare for submission to the court the jury instructions, a verdict form or forms, a statement of the case, exhibits, exhibit lists, and witness lists. Counsel shall also attempt to reach stipulations with regard to ultimate facts and issues, and the authenticity/ admissibility of exhibits.
- Document
- Final status conference documents
Must include
- •Exhibit list
At the end of the joint witness list, the parties and any self-represented parties shall add up the estimated times for all witness testimony and state the grand total in the last column.
(6) an estimate of the length of cross-examination (in hours), and (7) the total estimated length of examination (in hours.
Rule 3.25, subd. (g)(4). A joint statement should usually be only a few sentences. It should be in plain English without legal jargon.
confer in an effort to resolve objections to the authenticity and admissibility of each exhibit.
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.
When an appropriate CACI instruction exists, parties are expected to request it rather than a specially prepared instruction, and special instructions with out-of-context quotes or non-plain-English wording are usually inappropriate.
Court's wording
If there is an appropriate CACI jury instruction on a point of law, the court expects the parties to request the CACI instructions instead of a specially prepared jury instruction. The court rarely uses a special jury instruction on a topic covered by a CACI instruction. Special jury instructions that use quotes from appellate cases taken out of context, or that do not use plain English, are usually not appropriate.
The parties should not request CACI instructions that do not apply when the trial begins. For example, CACI 5013 shall not apply unless and until there is a deadlocked jury.
The parties do not, however, need to include in the joint chart deposition testimony or former trial testimony they plan on using for impeachment purposes only.
The parties should not file generic motions in limine untethered to actual anticipated disputes about evidence. Motions in limine that seek rulings “which would merely be declaratory of existing law” and do not include a discussion about the particular evidence the moving party seeks to exclude are not appropriate.
If the parties stipulate to an order, there is no need to file an ex parte application. The parties may instead file a stipulation and proposed order. The court generally promptly decides whether to grant stipulated proposed orders.
- Document
- Stipulation
Include
- •Proposed order
Each party may, but is not required to, file a trial brief succinctly 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
- Trial brief
Include
- •Legal argument
There is no need to make objections to any witness on the joint witness list. The parties do not waive or preserve objections on the joint witness list.
There is no need to make specific objections on the joint exhibit list. The parties do not waive or preserve objections on the joint exhibit list.
Filing & Service rules
Electronic Filing Rules
All parties represented by counsel must comply with mandatory electronic filing for civil cases under SCLAC rule 3.4 and the operative General Order re Mandatory Electronic Filing for Civil.
All parties represented by counsel shall comply with SCLAC rule 3.4 and the operative General Order re Mandatory Electronic Filing for Civil (May 3,
Page 1 | 2. MANDATORY EFiling
Writs and Abstracts must be submitted in their own separate electronic envelope.
Writs and Abstracts must be submitted as a separate electronic envelope.
Page 3 | 2. MANDATORY EFiling
Documents ordered sealed must be filed electronically unless exempted under the operative General Order, and the submitting party bears the burden of accurately designating them as sealed at electronic submission.
In cases where a judicial officer orders that documents be filed under seal, those documents must be filed electronically (unless exempted under the operative General Order.) The burden of accurately designating the documents sealed at the time of electronic submission is the submitting party's responsibility;
Page 3 | 2. MANDATORY EFiling
Represented parties must electronically file ex parte applications with all documentary support by 10:00 a.m. the court day before the hearing, and any written opposition by 8:30 a.m. on the hearing day.
Parties represented by counsel must electronically file ex parte applications with all documentary support no later than 10:00 a.m. the court day before the ex parte hearing. Any written opposition to the ex parte application by parties represented by counsel must be electronically filed by 8:30 a.m. on the day of the ex parte hearing.
Page 5 | 3. EX PARTE APPLICATIONS
Parties must reserve motion hearing dates online through the Court Reservation System (CRS).
Parties must reserve hearing dates for motions using the Court Reservation System (CRS) available online (www.lacourt.ca.gov).
Page 7 | 6. LAW AND MOTION - A. Reservation Hearing Date
As soon as a reservation requestor realizes that a motion hearing, or other proceeding requiring a reservation, such as in Informal Discovery Conference, will not be necessary, the reservation requestor should immediately use CRS to cancel the reservation for the motion hearing, or other proceeding requiring a reservation.
As soon as a reservation requestor realizes that a motion hearing, or other proceeding requiring a reservation, such as in Informal Discovery Conference, will not be necessary, the reservation requestor should immediately use CRS to cancel the reservation for the motion hearing, or other proceeding requiring a reservation.
Page 7 | 6. LAW AND MOTION - A. Reservation Hearing Date
Multiple documents relating to one case may be uploaded together in a single envelope transaction.
Multiple documents relating to one case can be uploaded in one envelope transaction;
Page 3 | 2. MANDATORY EFiling
Filing Timing and Cure Windows
Ex parte applications with all documentary support must be filed no later than 10:00 a.m. the court day before the ex parte hearing.
Parties represented by counsel must electronically file ex parte applications with all documentary support no later than 10:00 a.m. the court day before the ex parte hearing.
Page 5 | 3. EX PARTE APPLICATIONS
Written opposition to an ex parte application must be electronically filed by 8:30 a.m. on the day of the ex parte hearing.
Any written opposition to the ex parte application by parties represented by counsel must be electronically filed by 8:30 a.m. on the day of the ex parte hearing.
Page 5 | 3. EX PARTE APPLICATIONS
Papers for a reserved matter must be filed within 3 days of making the reservation or the reservation will be cancelled.
Be mindful that papers for a reserved matter must be filed within 3 days of making the reservation, else the reservation will be cancelled.
Page 7 | 6. LAW AND MOTION - A. Reservation Hearing Date
A joint statement setting forth the discovery issues and the parties' positions is due within three court days after the IDC.
A joint statement setting forth the discovery issues and the position of the parties is due within three court days of the IDC.
Page 11 | 6. LAW AND MOTION
All FSC documents must be filed/lodged directly in Department 516 at least five calendar days before the FSC unless the court specifies otherwise.
All documents required for the Final Status Conference, unless otherwise specified by the court, shall be FILED/LODGED DIRECTLY IN DEPT. 516 AT LEAST FIVE CALENDAR DAYS PRIOR to the FSC
Page 19 | 13. TRIAL PROCEDURES - B. Filings and Submissions
No later than five calendar days before the final status conference, the parties’ counsel and any self-represented parties shall file and serve the following documents:
No later than five calendar days before the final status conference, the parties’ counsel and any self-represented parties shall file and serve the following documents:
Page 30 | 2. TRIAL DOCUMENTS TO BE FILED
The jointly prepared physical Trial Binder (one-sided, conformed, tabbed copies) must be lodged in Department 516 no later than three calendar days before the Final Status Conference.
No later than three calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department 516 a physical Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a
Page 36 | 5. TRIAL BINDER
The jointly prepared Motions in Limine Binder must be lodged in Department 516 no later than three calendar days before the Final Status Conference.
No later than three calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department 516 a Motions in limine Binder.
Page 36 | 3. MOTIONS IN LIMINE
One set of the Exhibit Binders must be brought to the Final Status Conference for the court to review.
The parties’ counsel and any self-represented parties shall bring one set of the Exhibit Binder to the Final Status Conference for the court to review.
Page 36 | 4. EXHIBIT BINDERS
Scheduling an IDC does not extend the deadline to file a motion to compel further discovery responses.
Note: Scheduling an IDC does not extend the time to file a motion to compel further responses to discovery.
Page 11 | 6. LAW AND MOTION
Motions in limine must be noticed for hearing at the Final Status Conference in compliance with Local Rule 3.57(a) statutory notice requirements.
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 requirements of Local rule 3.57, subdivision (a).
Page 35 | 3. MOTIONS IN LIMINE
Service and Proof of Service Rules
All defendants must be served with the complaint by the case management conference.
All defendants must be served with the complaint by the case management conference.
Page 7 | 5. CASE MANAGEMENT CONFERENCES
If defendants have not been served by the case management conference, plaintiff must submit a declaration five days before the hearing explaining the service efforts undertaken.
If all defendants have not been served, plaintiff or plaintiff’s counsel must submit a declaration to the court five (5) days prior to the hearing explaining what efforts have been undertaken to accomplish service.
Page 7 | 5. CASE MANAGEMENT CONFERENCES
FSC documents must be served on all opposing counsel early enough to be received before the FSC date.
and must be served on all opposing counsel early enough to be received by other counsel before the FSC date
Page 19 | 13. TRIAL PROCEDURES - B. Filings and Submissions
All trial exhibits must be exchanged between counsel and self-represented parties no later than 18 calendar days before the final status conference.
No later than 18 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 29 | 1. MEET AND CONFER
Filing Fees and Waivers
Parties who have requested a jury trial must comply with CCP section 631 regarding the posting of jury fees.
If any party has requested a jury trial, the party/counsel must comply with California Code of Civil Procedure section 631 regarding the posting of jury fees.
Page 7 | 5. CASE MANAGEMENT CONFERENCES
Fees must be paid on a daily basis, with the judicial assistant advising the amount owed each day.
Fees must be paid on a daily basis. The judicial assistant will advise you how much is owed each day.
Page 25
Parties who have received a fee waiver may request an official court reporter under CRC 2.956(c) and LASC Local Rule 2.21(a).
A party who has received a fee waiver may request an official court reporter pursuant to California Rules of Court, rule 2.956, subdivision (c), and Superior Court of Los Angeles County Local Rules, rule 2.21, subdivision (a).
Page 19
Courtesy Copy Requirements
Courtesy copies of documents containing declarations and/or exhibits must be tabbed.
Any courtesy copies of documents with declarations and/or exhibits must be tabbed. (Cal. Rules of Court, rule 3.1110(f).)
Page 9 | 6. LAW AND MOTION - C. Courtesy Copies Not Required Except For Ex Partes and Motion for Summary Judgment Containing Media Exhibits
Department 516 does not require courtesy copies for most filings, but courtesy copies of oppositions to ex parte applications and summary judgment/adjudication motions, oppositions, and replies must be submitted directly to Department 516.
With the exceptions of Oppositions to Ex Parte Applications and Motions for, Oppositions to and Replies to Oppositions to Motions for Summary Judgment or Summary Adjudication, Department 516 does not require courtesy copies of any filed papers. Courtesy copies of Oppositions to Ex Parte Applications and Motions for, Oppositions to, and Replies to Oppositions to Motions for Summary Judgment or Summary Adjudication must be submitted directly to Department 516.
Page 9 | 6. LAW AND MOTION - C. Courtesy Copies Not Required Except For Ex Partes and Motion for Summary Judgment Containing Media Exhibits
The original and 2 copies of all exhibits must be provided to the court at the outset of trial.
The original and 2 copies of all exhibits shall be provided to the court at the outset of trial.
Page 23 | 8. Exhibits
Parties filing or opposing lengthy summary judgment/adjudication motions are strongly encouraged (not required) to submit courtesy copies in one or more three-ring binders organized behind tabs.
Department 516 also strongly encourages the parties filing and opposing lengthy Motions for Summary Judgment or Adjudication, to submit one or more three ring binders organizing the courtesy copy behind tabs.
Page 9 | 6. LAW AND MOTION - C. Courtesy Copies Not Required Except For Ex Partes and Motion for Summary Judgment Containing Media Exhibits
Be sure to bring copies of all documents to the FSC.
Be sure to bring copies of all documents to the FSC.
Page 19 | 13. TRIAL PROCEDURES - B. Filings and Submissions
Sealing & Redaction Procedures
Submitting parties are responsible for redacting confidential information so that it is not publicly disclosed.
It is the submitting party's responsibility to redact confidential information so that confidential information shall not be publicly disclosed.
Page 3 | 2. MANDATORY EFiling
Pre-Motion Conference Requirements
Parties seeking to compel further responses to discovery should schedule an Informal Discovery Conference (IDC) before the hearing, and preferably, the filing of their motions. The court may deny a motion to compel further responses to discovery if parties fail to schedule and complete an IDC before the scheduled hearing on the motion.
Parties seeking to compel further responses to discovery should schedule an Informal Discovery Conference (IDC) before the hearing, and preferably, the filing of their motions. The court may deny a motion to compel further responses to discovery if parties fail to schedule and complete an IDC before the scheduled hearing on the motion.
Page 11 | 6. LAW AND MOTION
Parties, through counsel of record with full authority to make binding agreements, must participate in the scheduled IDC.
Therefore, parties, through their respective counsel of record with full authority to make binding agreements, shall participate in the scheduled IDC.
Page 11 | 6. LAW AND MOTION
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.
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 13 | 6. LAW AND MOTION - A. Reservation Hearing Date
The court will factor a party's failure to request an IDC or to stipulate to extend the motion filing deadline into its sanctions analysis on a motion to compel.
The court will consider a party's failure to request an IDC and/or failure to stipulate to extend the time for filing of a motion to compel so that an IDC may be held when contemplating appropriate sanctions on the motion.
Page 11 | 6. LAW AND MOTION
In-person appearance at the IDC is preferred but not required if all parties agree; absent agreement, the IDC is conducted virtually.
The court prefers but does not require the parties to appear in person for the IDC if all parties agree. If no agreement, the IDC will be conducted virtually.
Page 11 | 6. LAW AND MOTION
The parties must meet and confer no later than 11 calendar days before the final status conference to prepare the required trial documents and binders, discuss exhibit admissibility, attempt to stipulate to resolve motions in limine and ultimate facts/legal issues, and attempt to settle the case.
No later than 11 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 binders required in sections 3-5 below, (2) discuss 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 29 | 1. MEET AND CONFER
Adjournment & Extension Requirements
Parties are expected to grant reasonable requests for extensions of time to respond to pleadings, discovery, or other matters as professional courtesies.
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
If parties/counsel are going to be late for a hearing, please contact the court staff prior to the hearing.
If parties/counsel are going to be late for a hearing, please contact the court staff prior to the hearing.
Page 5 | 4. HEARINGS IN GENERAL
If you require the services of an interpreter for your hearing, please advise court staff no later than when you check in. Courtroom interpreters are not always available on the same day as requested. If you contact court staff at least 2 days prior to your hearing with your request for an interpreter, there is a higher chance one will be available at the time of your hearing.
If you require the services of an interpreter for your hearing, please advise court staff no later than when you check in. Courtroom interpreters are not always available on the same day as requested. If you contact court staff at least 2 days prior to your hearing with your request for an interpreter, there is a higher chance one will be available at the time of your hearing.
Page 7 | 5. CASE MANAGEMENT CONFERENCES
The moving/propounding party should reserve an IDC by calling Dept. 516's staff after meeting and conferring about available dates.
After meeting and conferring about available dates for an IDC, the moving/propounding party should reserve an IDC by calling Dept. 516's staff.
Page 11 | 6. LAW AND MOTION
information, contact the court's ADR Office at ADRCivil@lacourt.ca.gov.
information, contact the court's ADR Office at ADRCivil@lacourt.ca.gov.
Page 17 | Alternative Dispute Resolution (ADR)