Judge Jon R. Takasugi
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Exhibits
- 3 copies • At FSC
Motion for Summary Judgment, Motion for Summary Adjudication, Motion for Judgment on the Pleadings, Anti SLAPP Motion to Strike, IDC Brief, Ex Parte Application
- Within 24 Hours of Electronic Filing
Opposition
- Hand Delivery • Directly in Courtroom
Adjournments
- The Court accepts stipulations and liberally grants extensions of time to respond.
- Trial continuance requests must be made by noticed motion, ex parte application when appropriate, or stipulation, and all requests to continue must be supported by good cause.
- depositions, or file Motions for Summary Judgment are not good cause to continue a jury trial date.
Request must include
Communication
Chambers
Page & Word Limits1 rule
If the parties/counsel are pursuing a court trial, Trial Briefs are required to be prepared so thoroughly that counsel would be confident submitting on the paperwork alone (20 page limit).
- Court trial brief
- Up to 20 pages
- Trial brief
Document Format Requirements3 rules
The parties/counsel shall prepare special instructions in a format ready for submission to the jury with the instruction number, title, and text only (i.e., there should be no boxes or other indication on the printed instruction itself as to the requesting party).
page must be “Bates” numbered sequentially. For example: if Exhibit 5 has 20 pages, “Exh. 5-012” would be the 12th page of Exhibit 5.
The Court requests all electronically filed documents be bookmarked and searchable.
- Electronically filed document
Formatting
- •Bookmarked
- •Text-searchable
Document Filing Requirements20 rules
The applicant shall 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.”
The notice must be included in the declaration and a proposed order must be presented with the moving papers.
Must include
- •Proposed order
The caption of each motion in Iimine shall concisely identify the evidence that the moving party seeks to preclude.
- 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
- Opposition and reply papers
- Placement
- Caption
Each party must file a trial brief identifying the claims and defenses, major legal issues with authorities, relief and damages calculation, and any other helpful information.
- Document
- Trial brief
Must include
- •Legal argument
Court's wording
Each party/counsel shall file a trial brief succinctly identifying: 1. The claims and defenses subject to litigation; 2. The major legal issues (with supporting points and authorities); 3. The relief claimed and calculation of damages sought; and 4. Any other information that may assist the Court at trial.
In jury trials, the parties must jointly prepare and file a signed joint written statement of the case for the court to read to the jury.
Court's wording
For jury trials, the parties/counsel shall work together to prepare and file a joint written statement of the case for the court to read to the jury (L.A. County Court Rule 3.25(g)(4)). The parties/counsel shall sign the joint statement, and all other joint
Before filing motions in Iimine, the parties/counsel shall comply with the statutory notice provisions of Code of Civil Procedure (CCP) Section I005 and the MIL requirements of L.A. County Court Rule 3.57(a).
Counsels must bring two Joint Trial Notebooks to the FSC with tabs A-K prepared as follows:
Parties filing more than one motion in Iimine shall number them consecutively.
The parties/counsel shall prepare a complete set of full-text proposed jury instructions, editing all proposed California Civil Jury Instructions and insert party name(s) and eliminate blanks, brackets, and irrelevant material.
The parties must jointly file a numbered list of proposed jury instructions identifying agreed and contested instructions, with a column for the judge to mark whether each instruction was given.
Court's wording
The parties/counsel shall jointly prepare and file a list of proposed jury instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any. The List of Proposed Jury Instructions must include a column by each instruction for the judge to indicate whether the instruction was given.
The parties must file a joint witness list (alphabetical, with full names, expert designations, estimated direct/cross/re-direct lengths, and total testimony hours); witnesses not on the list may be excluded absent good cause.
Court's wording
The parties/counsel shall work together to prepare and file a joint list of all witnesses arranged alphabetically by last name. The joint witness list shall identify each witness by full name, specify which witnesses are experts, estimate the length of the direct, cross examination and re-direct examination of each, and include a total of the number of hours for all witness testimony. Any party/counsel who seeks to elicit testimony from a witness not identified on the witness list may have that witness excluded absent a showing of good cause.
The parties must file a joint exhibit list with columns for the exhibit, offering party, stipulation to authenticity/admissibility, date identified in court, and date admitted.
Court's wording
The parties/counsel shall prepare and file a joint exhibit list organized with columns identifying: (1) the exhibit, (2) the party offering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) the date on which the exhibit was identified in court, and (5) the date on which the exhibit was admitted.
The parties must jointly file a proposed general or special verdict form acceptable to all sides, or, if they cannot agree, each party must separately file a proposed verdict form.
Court's wording
The parties/counsel shall prepare and jointly file a proposed general verdict form or special verdict form (with interrogatories) acceptable to all sides (L.A. County Court Rule 3.25(g)(8)). If the parties/counsel cannot agree on a joint verdict form, each party must separately file a proposed verdict form.
Pursuant to L.A. County Court Rules 3.52 and 3.53, the exhibits must be pre-marked using numbers.
Before filing the joint exhibit list, the parties must meet and confer on stipulations/objections to each exhibit, note stipulations or specify objections in the respective column, and sign the joint exhibit list.
Court's wording
Prior to filing the joint exhibit list, the parties shall meet-and-confer to determine whether they will stipulate to the authenticity and/or admissibility of each exhibit or whether there are objections to any exhibit. If there are stipulations, the parties shall note that in the respective column. If not, the objecting party shall specify all objections in the respective column. The parties/counsel shall sign the joint exhibit list.
Tab J – Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, and answer to any cross-complaint).Tab K – Stipulations
Parties who do not provide a court reporter for trial are directed to meet at the close of each session and prepare a joint statement of the witness testimony presented that day. The joint statement must be lodged with the Court the next morning before proceedings resume. No exceptions.
Parties intending to use deposition or former trial testimony must meet and confer and jointly file a designation chart with five required columns (designations, objections, counter-designations, responses, and the Court's ruling).
Court's wording
If the parties/counsel intend to use deposition testimony or former trial testimony in lieu of any witness' live testimony, the parties/counsel shall meet and confer and jointly prepare and file a chart with columns for each of the following: 1) the page and line designations of the deposition or former testimony requested for use, 2) objections, 3) counter-designations, 4) any responses thereto, and 5) the Court's ruling.
the propounding party can request an IDC by filing form LACIV 094 and including three (3) dates all parties are available to appear at 1:30 p.m., Monday through Thursday.
Filing & Service rules
Electronic Filing Rules
Oppositions to ex parte applications must be e-filed no later than 8:30 a.m. on the day of the hearing.
Oppositions must be e-filed no later than by 8:30 a.m. on the day of the hearing and courtesy copies are required directly in the courtroom.
Page 4 | E. Ex Parte Applications
Ex parte applications must be e-filed and noticed no later than 10 a.m. the court day before the hearing.
Ex parte applications must be e-filed and noticed no later than 10 a.m. the court day prior to the hearing.
Page 4 | E. Ex Parte Applications
Self-represented litigants may file documents in person at the Clerk's Office, Room 102.
Self-represented litigants may file in the Clerk's Office, Room 102.
Page 2 | II. PRETRIAL MATTERS - B. Law And Motion
Self-represented litigants must still give proper notice but may file their ex parte application in person at 8:30 a.m. on the hearing day in the Clerk's Office, first floor, Room 102.
Self-represented litigants must still give proper notice but may file their ex parte application at 8:30 a.m. on the day of the hearing in the Clerk’s Office on the first floor, Room 102.
Page 4 | E. Ex Parte Applications
Filing Timing and Cure Windows
Plaintiff's request for entry of default (form CIV-100) must be filed within 10 days after expiration of defendant's time to respond (the source sentence is cut off mid-exception).
Plaintiff's request for entry of default (Judicial Council form CIV-100) must be filed within 10 days after expiration of defendant's time to respond
Page 2 | II. PRETRIAL MATTERS - C. Entry of Default and Default Judgment
If any defendant remains unserved, plaintiff must file a declaration explaining service efforts at least five (5) days before the CMC hearing.
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 2 | II. PRETRIAL MATTERS - A. Case Management Conferences
days after entry of default, plaintiff must obtain a default judgment against the defendant unless the court grants an extension of time (CRC 3.110(h)).
days after entry of default, plaintiff must obtain a default judgment against the defendant unless the court grants an extension of time (CRC 3.110(h)).
Page 3 | C. Entry of Default and Default Judgment
Ex parte applications must be filed and noticed no later than the 10 a.m. cutoff on the court day prior to the hearing.
Ex parte applications must be e-filed and noticed no later than 10 a.m. the court day prior to the hearing.
Page 4 | E. Ex Parte Applications
Oppositions to ex parte applications must be e-filed by the 8:30 a.m. cutoff on the day of the hearing.
Oppositions must be e-filed no later than by 8:30 a.m. on the day of the hearing and courtesy copies are required directly in the courtroom.
Page 4 | E. Ex Parte Applications
Parties must meet and confer in person at least 5 days before the Final Status Conference to prepare the Trial and Exhibit Notebooks, and must serve, sign, and file all joint documents.
At least five (5) days prior to the FSC, the parties must meet and confer in person to exchange, discuss, and prepare the Trial Notebook and Exhibit Notebooks. The parties must serve, sign, and file all joint documents.
Page 5 | III. GUIDELINES FOR FINAL STATUS CONFERENCES AND TRIALS - A. FINAL STATUS CONFERENCE
Exhibits must be exchanged between the parties and lodged with the Court at least five calendar days before the Final Status Conference.
The exhibits must be exchanged at least five (5) calendar days before the FSC and lodged with the Court.
Page 7 | A. FINAL STATUS CONFERENCE (Exhibits)
Deposition transcripts and discovery responses must be lodged with the Court before trial commences.
Prior to the commencement of the trial, deposition transcripts and discovery responses shall be lodged with the Court (L.A. County Court Rule 3.56).
Page 8 | B. TRIALS - 8. Use of Deposition Transcripts and Discovery Responses
Parties must meet and confer within 30 days of the case management conference hearing as required by CRC 3.722 et seq. and Local Rule 3.25.
The parties must comply with California Rules of Court, rule 3.722, et seq., and Local Rule 3.25 in connection with such conferences (the parties are to meet and confer within 30 days of the hearing and file a CMC statement (Judicial Council Form CM-110) within five (5) days of the hearing).
Page 2 | II. PRETRIAL MATTERS - A. Case Management Conferences
Once a Mandatory Settlement Conference is ordered, the parties must register within 14 days at lacourt.ca.gov.
Once ordered, the parties must register within 14 days at lacourt.ca.gov.
Page 4 | F. Mediation and Mandatory Settlement Conferences (MSC)
A party with a fee waiver may request an official court reporter by filing form LASC LACIV 269 at least 10 calendar days before the hearing or trial.
A party who has a fee waiver pursuant to California Rules of Court, rule 3.55(7) may request an official court reporter by filing form LASC LACIV 269 at least 10 calendar days before the hearing or trial.
Page 1 | I. GENERAL INFORMATION - B. Court Reporters
If you require an accommodation relating to a disability, please inform the courtroom staff at least five court days in advance so we can attempt to facilitate your request. Written requests can be made by filing Judicial Council form MC-410.
If you require an accommodation relating to a disability, please inform the courtroom staff at least five court days in advance so we can attempt to facilitate your request. Written requests can be made by filing Judicial Council form MC-410.
Page 2 | I. GENERAL INFORMATION - D. Accessibility and Accommodation
Scheduling or participating in an IDC does not extend any filing deadlines, and the Court urges responding/objecting parties to waive time to avoid unnecessary motion practice.
Because scheduling or participating in an IDC does not extend any deadlines of filing, the Court urges responding/objecting parties to waive time to avoid unnecessary motion practice.
Page 3 | D. Informal Discovery Conferences (IDC)
Service and Proof of Service Rules
All defendants must be served with the complaint no later than the case management conference.
All defendants must be served with the complaint by the case management conference.
Page 2 | II. PRETRIAL MATTERS - A. Case Management Conferences
Before reading any deposition, interrogatory, or request for admission into evidence, the party must advise the Court and opposing party of the specific page, line, or interrogatory/request numbers to be used.
Before reading into evidence any portion of a deposition, interrogatory, or request for admission, the party shall advise the Court and opposing party of the page and line number of the deposition, or the numbers of the interrogatories ore requests for admission to be read or shown to the witness (L.A. County Court Rule 3.158).
Page 8 | B. TRIALS - 8. Use of Deposition Transcripts and Discovery Responses
A copy of PowerPoint slides must be shared with opposing counsel before the presentation, leaving sufficient time to object.
If a PowerPoint is to be used, a copy of the slides must be shared with the opposing counsel prior to the presentation leaving sufficient time to object.
Page 8 | B. TRIALS - 6. Display of Demonstrative Evidence
Filing Fees and Waivers
Jury fees must be paid daily, with the judicial assistant advising of the daily rate.
Jury fees must be paid on a daily basis. The judicial assistant will advise of the daily rate.
Page 7 | B. TRIALS - 3. Jury Fees
Courtesy Copy Requirements
Conformed, printed courtesy copies with tabbed exhibits are required for MSJ/MSA motions, motions for judgment on the pleadings, anti-SLAPP motions to strike, IDC briefs, and ex parte applications, and must be delivered directly to Dept. 309 within a day of e-filing.
The Court requires courtesy copies (with tabbed exhibits) for Motions for Summary Judgment/Adjudication, Motions for Judgment on the Pleadings, Motions to Strike (Anti- SLAPP), Informal Discovery Conference briefs, and Ex Parte Applications. The conformed, printed courtesy copies are to be delivered directly to Dept. 309 within a day of electronic filing.
Page 1 | I. GENERAL INFORMATION - A. Courtesy Copies
Courtesy copies of oppositions to ex parte applications must be delivered directly in the courtroom.
Oppositions must be e-filed no later than by 8:30 a.m. on the day of the hearing and courtesy copies are required directly in the courtroom.
Page 4 | E. Ex Parte Applications
At least three tabbed, marked, and paginated exhibit binder sets (Court, judicial assistant, witness) are required at the FSC, plus a binder for each opposing party if not exchanged electronically.
At least three sets of exhibit binders – tabbed, marked, and paginated – are required at the FSC: a set each for the Court, judicial assistant, and witness. Counsel must also supply an exhibit binder to each opposing party if not exchanged electronically.
Page 7 | A. FINAL STATUS CONFERENCE (Exhibits)
Pre-Motion Conference Requirements
Before filing, parties must obtain and reserve a motion hearing date through the online Court Reservation System (CRS) on the LA Superior Court website.
Parties must obtain and schedule a motion hearing date via the online Court Reservation System (CRS) on the Superior Court of Los Angeles County website: https://www.lacourt.ca.gov, "Online Services" tab.
Page 2 | II. PRETRIAL MATTERS - B. Law And Motion
The parties are asked to schedule an IDC prior to filing a Motion to Compel Further Discovery Responses in all matters except Song- Beverly Warranty Act claims. A Motion to Compel an Initial Response does not require an IDC.
The parties are asked to schedule an IDC prior to filing a Motion to Compel Further Discovery Responses in all matters except Song- Beverly Warranty Act claims. A Motion to Compel an Initial Response does not require an IDC.
Page 3 | D. Informal Discovery Conferences (IDC)
Adjournment & Extension Requirements
Trial continuance requests must be made by noticed motion, ex parte application when appropriate, or stipulation, and all requests to continue must be supported by good cause.
Requests for trial continuances must be made by noticed motion, ex parte application when appropriate, or by stipulation. The Court has a strong interest in keeping scheduled jury trial dates, therefore all requests to continue must be supported by good cause.
Page 4 | G. Trial Continuances
depositions, or file Motions for Summary Judgment are not good cause to continue a jury trial date.
depositions, or file Motions for Summary Judgment are not good cause to continue a jury trial date.
Page 5 | II. PRETRIAL MATTERS - G. Trial Continuances (continuation)
The Court accepts stipulations and liberally grants extensions of time to respond.
The Court will accept stipulations and liberally grant extensions in time to respond.
Page 3 | C. Entry of Default and Default Judgment
Chambers Communication Rules
To submit a motion on the tentative ruling, a party must email the courtroom with notice to opposing counsel (or self-represented party) before 8:30 a.m. on the morning of the hearing.
If parties wish to submit on the tentative, please email the courtroom (smcdept309@lacourt.ca.gov) with notice to opposing counsel (or self-represented party) before 8:30 a.m. on the morning of the hearing.
Page 2 | II. PRETRIAL MATTERS - B. Law And Motion