Judge Karine Mkrtchyan
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- Not Required
Motion in Limine Motions
- No Later Than Five Court Days Before FSC
Binding: Tabbed Three Ring
Communication
Chambers
Phone
Page & Word Limits2 rules
At least two court days before the IDC, each side shall serve and file a memorandum of no longer than two pages setting forth the outstanding issues.
- Memorandum
- Up to 2 pages per side
At least two court days before the IDC, each side shall serve and file a memorandum of no longer than two pages setting forth the outstanding issues.
- IDC memorandum
- Up to 2 pages per side
Document Format Requirements10 rules
The Court requests that all electronically filed documents be bookmarked and searchable.
- Electronic filing
Formatting
- •Bookmarked
- •Searchable
Motion in limine papers must be bound in an indexed tabbed three-ring binder for lodging.
- Binding
- Tabbed three-ring binder
- Motion in limine
Court's wording
No later than five court days before the FSC, the moving party for each motion in limine must lodge directly in Dept. 54 an indexed and tabbed three-ring binder containing conformed copies of all moving, opposition, and reply papers for their motions in limine.
The chart shall be submitted to the Court in a three-ring binder, along with all deposition transcripts necessary for the Court to rule on the objections.
- Binding
- Three-ring binder
- Deposition designation
Exhibits must be separately numbered with internal page numbering for multi-page exhibits.
- Exhibit
Formatting
- •Separately numbered
- •Pages internally numbered for multi-page exhibits
Court's wording
Each exhibit must be separately numbered, with the numbers corresponding to the number of the exhibit on the joint exhibit list. If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3 etc.
Proposed jury instructions must be submitted in an indexed tabbed binder with full text, CACI forms, and 4 inches of blank top margin.
- Binding
- Tabbed three-ring binder
- Proposed jury instruction
Formatting
- •Full text of instructions
- •Use CACI for form instructions
Court's wording
The parties are to submit an indexed and tabbed three-ring binder containing (a) a joint set of instructions, (b) any instructions proposed by Plaintiff and objected to by Defendant; and (c) and instructions proposed by Defendant and objected to by Plaintiff. The parties shall provide the full text of all requested instructions (not just a list). Before submitting the instructions, counsel must fill in the blanks, make any appropriate modifications, and comply with LASC 3.170 – 3.171. Use CACI for form instructions. Leave at least four inches of blank space of the top of every page of any proposed special
Counsel must prepare a separate set of exhibits for each of the Court, the witness stand, and the Judicial Assistant.
The Court requests that all electronically filed documents be bookmarked and searchable.
- Electronically filed document
Formatting
- •Electronically filed documents should be bookmarked
- •Electronically filed documents should be searchable
Leave at least four inches of blank space of the top of every page of any proposed special
Proposed jury instructions must be submitted in an indexed, tabbed three-ring binder containing the joint set plus each side's disputed instructions.
- Binding
- Tabbed three-ring binder
- Proposed jury instructions
Formatting
- •Binder must be indexed and tabbed
Court's wording
The parties are to submit an indexed and tabbed three-ring binder containing (a) a joint set of instructions, (b) any instructions proposed by Plaintiff and objected to by Defendant; and (c) and instructions proposed by Defendant and objected to by Plaintiff.
The chart shall be submitted to the Court in a three-ring binder, along with all deposition transcripts necessary for the Court to rule on the objections.
- Binding
- Three-ring binder
- Deposition designation chart
Document Filing Requirements18 rules
At least two court days before the IDC, each side shall serve and file a memorandum of no longer than two pages setting forth the outstanding issues.
Ex parte applications must comply with CRC 3.1200 et seq.
The following FSC documents must be provided to the Court prior to the FSC:
Compliance with LASC Rule 3.57, including the declaration and meet and confer requirements, is mandatory. Boilerplate or form motions in limine are disfavored.
- Document
- Motion in limine
Must include
- •Certificate of conference
JOINT STATEMENT OF THE CASE (which will be read by the Court to the prospective jurors). This is a brief, neutral statement of what the case is about.
Each exhibit must be separately numbered, with the numbers corresponding to the number of the exhibit on the joint exhibit list. If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3 etc.
Counsel must prepare a separate set of exhibits for each of the Court, the witness stand, and the Judicial Assistant.
Parties using deposition or former trial testimony must meet and confer and jointly file a designation chart with columns for 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’s live testimony, the parties/counsel shall meet and confer and jointly prepare and file a chart with columns for: 1) the line and page designations of the deposition or former testimony requested, 2) objections, 3) counter- designations, 4) any responses to the objections, and 5) the Court’s ruling.
The parties shall provide the full text of all requested instructions (not just a list). Before submitting the instructions, counsel must fill in the blanks, make any appropriate modifications, and comply with LASC 3.170 – 3.171. Use CACI for form instructions.
Absent good cause, the total number of hours listed for testimony shall not exceed the trial estimate given at the case management conference, including the allocation of one day of the trial estimate for jury selection and sufficient time for opening statements and closing arguments.
The parties must submit a joint list of all witnesses each party actually intends to call. Next to each witness, indicate the total time estimated for that witness's testimony (including direct, cross, redirect). Make realistic time estimates. At the end of the list, total the time estimated for testimony.
JOINT EXHIBIT LIST AND EXHIBITS. Counsel must comply with LASC Rules 3.52, 3.53 and 3.151.
- Document
- Joint exhibit list and exhibits
Must include
- •Exhibit list
At the end of each trial day counsel must meet and confer and submit to the Court's judicial assistant an agreed-upon list of all exhibits admitted that day.
COURT REPORTERS AND SETTLED STATEMENTS. The Court strongly encourages the parties to bring a court reporter for trial. If no court reporter is used, the parties must jointly prepare a summary of the day's proceedings, and lodge it in the courtroom the next morning before proceedings resume.
- Document
- Summary of proceedings
Must include
- •Summary of the day's proceedings
8. JOINT PROPOSED VERDICT AND SPECIAL INTERROGATORY FORMS. Use CACI model verdict forms where applicable. The Court discourages submission of competing proposed verdict forms.
identity of the party requesting the instruction will be removed after the jury instruction conference and before submission to the jury for deliberation.
A party who has received a fee waiver pursuant to CRC 3.55(7) may request an official court reporter by filing local form LACIV 2699 as soon as possible before the hearing or trial.
Requests may be made using form MC-410 or in any other written format.
Filing & Service rules
Filing Timing and Cure Windows
Each side must serve and file its IDC memorandum at least two court days before the informal discovery conference.
At least two court days before the IDC, each side shall serve and file a memorandum of no longer than two pages setting forth the outstanding issues.
Page 2 | DISCOVERY MOTIONS AND INFORMAL DISCOVERY CONFERENCES
Case Management Statements must be filed at least 15 calendar days before the scheduled Case Management Conference.
Case Management Statements must be filed at least 15 calendar days before the date scheduled for the conference.
Page 3 | CASE MANAGEMENT
Ex parte applications must be filed by 10:00 am on the court day before the hearing.
Absent an exemption, you must file the application by 10:00 am on the court day prior to the ex parte hearing.
Page 3 | EX PARTE APPLICATIONS
Motions in limine and bifurcation motions must be filed and served with proper statutory notice and set for hearing on the FSC date.
MOTIONS IN LIMINE AND BIFURCATION MOTIONS must have been filed and served with proper statutory notice and set for hearing on the FSC date. LASC Rule 3.25 (f)(2).
Page 3 | TRIAL PROCEDURES
Ex parte applications are heard daily at 8:30 a.m. and, absent an exemption, must be filed by 10:00 a.m. on the court day before the hearing.
Ex parte applications are heard each day at 8:30 am. Absent an exemption, you must file the application by 10:00 am on the court day prior to the ex parte hearing.
Page 3 | LAW & MOTION
Case Management Statements must be filed at least 15 calendar days before the conference.
Case Management Statements must be filed at least 15 calendar days before the date scheduled for the conference.
Page 3 | CASE MANAGEMENT CONFERENCES
Settled statements must be lodged the morning after trial day if no court reporter is used.
If no court reporter is used, the parties must jointly prepare a summary of the day’s proceedings, and lodge it in the courtroom the next morning before proceedings resume.
Page 5 | COURT REPORTERS AND SETTLED STATEMENTS
Service and Proof of Service Rules
IDC memoranda must be served and filed at least two court days before the conference.
At least two court days before the IDC, each side shall serve and file a memorandum of no longer than two pages setting forth the outstanding issues.
Page 2 | DISCOVERY MOTIONS AND INFORMAL DISCOVERY CONFERENCES
Each side must serve the IDC memorandum on the opposing side in addition to filing it.
At least two court days before the IDC, each side shall serve and file a memorandum of no longer than two pages setting forth the outstanding issues.
Page 2 | DISCOVERY MOTIONS AND INFORMAL DISCOVERY CONFERENCES
Courtesy Copy Requirements
Courtesy copies are not required in this department.
The Court does not require courtesy copies.
Page 2 | LAW & MOTION
No later than five court days before the FSC, the moving party on each motion in limine must lodge in Dept. 54 an indexed, tabbed three-ring binder of conformed moving, opposition, and reply papers.
No later than five court days before the FSC, the moving party for each motion in limine must lodge directly in Dept. 54 an indexed and tabbed three-ring binder containing conformed copies of all moving, opposition, and reply papers for their motions in limine.
Page 3 | TRIAL PROCEDURES
No courtesy copies are required for filings in this courtroom.
The Court does not require courtesy copies.
Page 2 | LAW & MOTION
Filing Bundling Requirements
Motion in limine papers must be lodged in an indexed tabbed three-ring binder 5 court days before the FSC.
No later than five court days before the FSC, the moving party for each motion in limine must lodge directly in Dept. 54 an indexed and tabbed three-ring binder containing conformed copies of all moving, opposition, and reply papers for their motions in limine.
Page 3 | TRIAL PROCEDURES
Pre-Motion Conference Requirements
Before pursuing a discovery motion, counsel with authority to compromise the dispute must meet and confer by telephone, videoconference, or in person; exchanging letters or emails alone is insufficient.
Counsel with authority to compromise the dispute (preferably trial counsel) must meet and confer by telephone, videoconference, or in person to resolve or narrow the discovery dispute. Merely exchanging letters or emails is insufficient.
Page 2 | DISCOVERY MOTIONS AND INFORMAL DISCOVERY CONFERENCES
Parties must reserve a hearing date through the Court Reservation System (CRS) for all law and motion hearings.
Parties must reserve a date for all law and motion hearings through the Court Reservation System ("CRS").
Page 2 | LAW & MOTION
Absent a showing of good cause, the Court will conduct the informal discovery conference before hearing the discovery motion.
Absent a showing of good cause, the Court will conduct the IDC before hearing the motion.
Page 2 | DISCOVERY MOTIONS AND INFORMAL DISCOVERY CONFERENCES
Trial counsel must meet and confer no later than 15 calendar days before each Case Management Conference to consider the issues identified in CRC Rules 3.724 and 3.727.
Trial counsel are required to meet and confer by videoconference, telephone or in person no later than 15 calendar days before the date set for the initial and any succeeding Case Management Conference to consider each of the issues identified in CRC Rules 3.724 and 3.727.
Page 3 | CASE MANAGEMENT
Trial counsel must meet by videoconference, telephone, or in person well before the Final Status Conference regarding joint trial readiness documents.
The Court requires trial counsel to meet by videoconference, telephone or in person well before the final status conference concerning the submission of joint trial readiness documents. LASC Rule 3.25 (g).
Page 3 | TRIAL PROCEDURES
Motions in limine may be heard at the Final Status Conference unless the Court orders otherwise (LR 3.25(f)).
Motions in limine may be heard at the Final Status Conference unless the Court orders otherwise. LR 3.25(f).
Page 2 | LAW & MOTION
Adjournment & Extension Requirements
Parties must use CRS to continue or withdraw motions; please also email the courtroom so we are aware of the change.
Parties must use CRS to continue or withdraw motions; please also email the courtroom so we are aware of the change.
Page 2 | LAW & MOTION
The parties are encouraged to stipulate in writing to extend any discovery motion filing deadline until at least 21 days following the IDC.
The parties are encouraged to stipulate in writing to extend any applicable deadline for filing a discovery motion until at least 21 days following the IDC.
Page 2 | DISCOVERY MOTIONS AND INFORMAL DISCOVERY CONFERENCES
Chambers Communication Rules
If a discovery dispute remains unresolved, counsel must call the courtroom to schedule an informal discovery conference (IDC) with Judge Leiter.
If the dispute remains unresolved, counsel must call the courtroom to schedule an informal discovery conference (IDC) with Judge Leiter.
Page 2 | DISCOVERY MOTIONS AND INFORMAL DISCOVERY CONFERENCES
If the parties wish to submit on the tentative, please email the courtroom with notice to opposing counsel (or self- represented party) before 8:30 am on the day of the hearing.
If the parties wish to submit on the tentative, please email the courtroom with notice to opposing counsel (or self- represented party) before 8:30 am on the day of the hearing.
Page 2 | LAW & MOTION
Counsel must call the courtroom to schedule an informal discovery conference.
If the dispute remains unresolved, counsel must call the courtroom to schedule an informal discovery conference (IDC) with Judge Leiter.
Page 2 | DISCOVERY MOTIONS AND INFORMAL DISCOVERY CONFERENCES
Parties must email the courtroom when continuing or withdrawing motions via the Court Reservation System.
Parties must use CRS to continue or withdraw motions; please also email the courtroom so we are aware of the change.
Page 2 | LAW & MOTION
To submit on a tentative ruling, parties must email the courtroom, with notice to opposing counsel or self-represented party, before 8:30 am on the day of the hearing.
If the parties wish to submit on the tentative, please email the courtroom with notice to opposing counsel (or self- represented party) before 8:30 am on the day of the hearing.
Page 2 | LAW & MOTION
When continuing or withdrawing a motion via CRS, parties must also email the courtroom so it is aware of the change.
Parties must use CRS to continue or withdraw motions; please also email the courtroom so we are aware of the change.
Page 2 | LAW & MOTION