Judge Kristin S. Escalante
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Exhibit Binders
- 1 copy • At Final Status Conference
Communication
Chambers
Phone
Chambers
Page & Word Limits2 rules
IDC memoranda are limited to two pages for the moving party and two pages for the responding party's responsive memorandum.
- IDC memorandum
- Up to 2 pages
- IDC responsive memorandum
- Up to 2 pages
Court's wording
At least five court days prior to the IDC, the moving party must file and serve a memorandum no longer than two pages setting forth the outstanding issues. The relevant discovery requests and responses may be attached. The responding party may file and serve a responsive memorandum of no more than two pages at least two court days prior to the IDC.
IDC memoranda are limited to 2 pages for both moving and responding parties.
- Memorandum
- Up to 2 pages
- Responsive memorandum
- Up to 2 pages
Court's wording
At least five court days prior to the IDC, the moving party must file and serve a memorandum no longer than two pages setting forth the outstanding issues. The relevant discovery requests and responses may be attached. The responding party may file and serve a responsive memorandum of no more than two pages at least two court days prior to the IDC.
Document Format Requirements6 rules
Each designation or counter-designation shall be highlighted, with each party using a different color highlighter.
Motions in Limine Binder must be three-ring binders with one-sided conformed copies, tabbed numerically, colored sheets separating papers.
- Binding
- Three-ring binder
- Motions in limine binder
Formatting
- •One-sided conformed copies
- •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.
Exhibit Binders require one-sided documentary copies, marked non-documentary exhibits with written descriptions behind tabs.
- Exhibit binder
Formatting
- •Organized numerically
- •One-sided copies of documentary exhibits
Court's wording
Copies of documentary exhibits shall be one-sided copies. The parties’ counsel and any self-represented parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the Exhibit Binders.
Parties must jointly prepare four sets of tabbed, internally paginated, properly marked exhibits organized numerically in three-ring binders (for the court, Judicial Assistant, and witnesses), with one-sided documentary exhibit copies and written descriptions of non-documentary exhibits behind the corresponding tabs.
- Binding
- Three-ring binder
- Exhibit binders
- Exhibits
Court's wording
The parties’ counsel and any self-represented parties shall work together to jointly prepare four sets of tabbed, internally paginated by document, and properly marked exhibits, organized numerically in three-ring binders (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) (“Exhibit Binders”). Copies of documentary exhibits shall be one-sided copies. The parties’ counsel and any self-represented parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the Exhibit Binders.
The joint witness list must be organized into specified columns (witness name, calling party, expected testimony, and estimated direct/cross/redirect times) with a grand total of estimated testimony times stated in the last column.
- Joint witness list
Formatting
- •Column stating the party calling the witness (plaintiff/defendant)
- •Column stating whether the witness is actually expected to testify (Yes/No)
Court's wording
The joint witness list shall be organized with columns (in the format set forth below) which state (1) the name of each witness (in alphabetical order), if the witness is being called to testify as an expert, and, if applicable, that the witness requires an 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, (5) an estimate of the length of direct examination (in hours), (6) an estimate of the length of cross- examination (in hours), and (7) an estimate of the length of redirect (in hours). At the end of the joint witness list, the parties and any self-represented parties shall add up the estimated times for all witnesses’ testimony and state the grand total in the last column.
Parties filing more than one motion in limine shall number them consecutively.
Document Filing Requirements22 rules
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 identified on the witness list must first make a showing of good cause to the court.
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.
Joint Witness List required, filed before trial, with specified columns including witness details and exam length estimates.
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. The joint witness list shall be organized with columns (in the format set forth below) which state (1) the name of each witness (in alphabetical order), if the witness is being called to testify as an expert, and, if applicable, that the witness requires an 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, (5) an estimate of the length of direct examination (in hours), (6) an estimate of the length of cross-examination (in hours), and (7) an estimate of the length of redirect (in hours).
In jury trials, the parties must jointly prepare and file a brief written statement of the case for the court to read to the jury.
Court's wording
For jury trials, the parties' counsel and any self-represented parties shall work together to prepare and file a brief, joint written statement of the case for the court to read to the jury. (Local Rule 3.25, subd. (g)(4).)
The parties must jointly prepare and file an exhibit list with specified columns for each trial exhibit and must meet and confer to resolve objections to the authenticity and admissibility of each exhibit.
- 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) which state, as to each exhibit any party intends to offer at trial: (1) the exhibit number, (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) any evidentiary objections to admission of the exhibit, (7) the date the exhibit was marked for identification, and (8) the date the exhibit was admitted into evidence. (Local Rule 3.25, subd. (g)(6).) As set forth above, the parties' counsel and any self-represented parties shall meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit.
For jury trials, the parties must jointly prepare a complete set of full-text proposed jury instructions by editing CACI instructions, inserting party names, and removing blanks and irrelevant material.
Court's wording
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 Civil Jury Instructions (“CACI”) instructions, inserting party names, and eliminating blanks and other irrelevant or inapplicable material.
For jury trials, the parties must jointly prepare and file a proposed general or special verdict form acceptable to all parties.
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 3.25, 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, counsel and self-represented parties must jointly prepare and file a Joint List of Proposed Jury Instructions containing six required items for each instruction (number, title, requesting party, agreed/contested status, objection, and whether given).
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) which states, as to each proposed jury instruction: (1) the jury instruction number (listed in numerical order), (2) the title of the jury instruction, (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”).
Parties must attach copies of the designated or counter-designated transcript pages to the joint chart, with numbered tabs separating each deposition or trial transcript.
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.
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 for Deposition and Former Testimony.
Court's wording
If any 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 Designations for Deposition and Former Testimony”).
Each designating party’s designations in the joint chart must include six required columns (witness number/name, date and type of testimony, page/line designations, objections, related counter-designations, and court ruling).
Court's wording
In the joint chart, each designating party’s designations of deposition or former testimony shall include columns which 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.
Each counter-designating party’s counter-designations in the joint chart must include six required columns (witness number/name, date and type of testimony, page/line counter-designations, objections, related designation number, and court ruling).
Court's wording
In the joint chart, each counter-designating party’s counter-designations of additional deposition or former testimony of the witness that relates to the designations shall include columns which 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 counter-designations of the deposition or former testimony requested to be used, (4) any objections, (5) the designation number of the other party’s designation to which the counter-designation relates, and (6) the court’s ruling.
The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to exclude. Parties filing more than one motion in limine shall number them consecutively.
- Document
- Motion in limine
Must include
- •Caption
The parties’ counsel and any self-represented parties shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and file declarations that comply with the requirements of Los Angeles County Court Rule 3.57, subdivision (a).
Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.
- Document
- Opposition and reply papers
Must include
- •Caption
The court strongly encourages the parties to arrange for a court reporter for trial. If no court reporter is used, the parties must jointly prepare a summary of the day's proceedings, including a detailed summary of any witness testimony, and lodge it in the courtroom the next morning before proceedings resume.
If there is an appropriate CACI jury instruction on a point of law, the court expects the parties to request the CACI instruction instead of a specially prepared jury instruction.
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 opposition and reply papers shall identify the corresponding motion number in the caption of their papers.
- Document
- Motion in limine opposition and reply
- Placement
- Caption
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
When a special verdict form is defense, or other finding, the court expects the parties to use the CACI special verdict form.
Filing & Service rules
Filing Timing and Cure Windows
The responding party may file and serve a responsive memorandum of no more than two pages at least two court days prior to the IDC.
The responding party may file and serve a responsive memorandum of no more than two pages at least two court days prior to the IDC.
Page 3
Case Management Statements must be filed at least 7 calendar days before the scheduled Case Management Conference.
Case Management Statements must be filed at least 7 calendar days before the date scheduled for the conference.
Page 3 | Case Management Conferences
Ex parte applications must be filed by 10:00 am on the court day prior to the ex parte hearing, absent an exemption.
Ex parte applications are heard each day at the end of the morning calendar. 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
Case Management Statements must be filed at least 7 calendar days before the scheduled Case Management Conference.
Case Management Statements must be filed at least 7 calendar days before the date scheduled for the conference.
Page 3
Moving party's IDC memorandum must be filed at least 5 court days prior to the IDC.
At least five court days prior to the IDC, the moving party must file and serve a memorandum no longer than two pages setting forth the outstanding issues.
Page 3
The moving party must file and serve its IDC memorandum at least five court days before the informal discovery conference.
At least five court days prior to the IDC, the moving party must file and serve a memorandum no longer than two pages setting forth the outstanding issues.
Page 3 | Discovery Motions and Informal Discovery Conferences
The responding party may file and serve a responsive IDC memorandum (max two pages) at least two court days before the IDC.
The responding party may file and serve a responsive memorandum of no more than two pages at least two court days prior to the IDC.
Page 3 | Discovery Motions and Informal Discovery Conferences
Ex parte applications must be filed by 10:00 AM on the court day prior to the hearing, unless exempt.
Absent an exemption, you must file the application by 10:00 am on the court day prior to the ex parte hearing.
Page 3
No later than four 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 four calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall file and serve the following documents:
Page 5 | TRIAL DOCUMENTS TO BE FILED
Parties must jointly prepare and lodge a Trial Binder in Department 24 no later than three calendar days before the Final Status Conference, consisting of one-sided conformed copies tabbed and organized in a three-ring binder (source text truncated mid-sentence).
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 24 a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of
Page 10 | 5. TRIAL BINDER
The parties must jointly prepare and lodge a Motions in Limine Binder in Department 24 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 24 a Motions in Limine Binder.
Page 10 | Motions in Limine
If no court reporter is present, parties must lodge a summary of the previous day's proceedings the next morning before trial resumes.
If no court reporter is used, the parties must jointly prepare a summary of the day’s proceedings, including a detailed summary of any witness testimony, and lodge it in the courtroom the next morning before proceedings resume.
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Service and Proof of Service Rules
All trial exhibits must be exchanged between the 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 4 | Trial Preparation Order
Filing Fees and Waivers
Fee-waiver parties may request an official court reporter by filing local form LACIV 2699 at least 10 calendar days before the hearing or trial.
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 at least 10 calendar days before the hearing or trial.
Page 1 | GENERAL INFORMATION
Courtesy Copy Requirements
Parties must bring one set of the Exhibit Binders 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 Binders to the Final Status Conference for the court to review.
Page 10 | 4. EXHIBIT BINDERS
Filing Bundling Requirements
Motions in Limine Binder required, lodged 3 days before Final Status Conference, three-ring binders, tabbed numerically, one-sided conformed copies.
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 24 a Motions in Limine Binder. 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.
Page 10
Trial Binder required, lodged 3 days before Final Status Conference, three-ring binder, tabbed with specified tabs, one-sided conformed copies.
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 24 a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of tabs A-I as specified.
Page 10
Four sets of Exhibit Binders required, tabbed, three-ring binders, internally paginated, one-sided documentary copies.
The parties’ counsel and any self-represented parties shall work together to jointly prepare four sets of tabbed, internally paginated by document, and properly marked exhibits, organized numerically in three-ring binders (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) (“Exhibit Binders”). Copies of documentary exhibits shall be one-sided copies.
Page 10
The Motions in Limine Binder must contain one-sided conformed copies of all motions in limine, opposition papers, and reply papers, tabbed in numerical order in three-ring binders with opposition/reply papers behind the moving papers and colored separator sheets between them.
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.
Page 10 | Motions in Limine
include the documents listed under Tabs A, B, C, H, and I): Tab A: Trial Briefs (Optional. If no trial briefs are filed, leave Tab A empty.) Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Statement to Be Read to the Jury TabE: 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).
include the documents listed under Tabs A, B, C, H, and I): Tab A: Trial Briefs (Optional. If no trial briefs are filed, leave Tab A empty.) Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Statement to Be Read to the Jury TabE: 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).
Page 11 | Trial Preparation Order
Proposed jury instructions must be organized behind Tab F in three cover-sheet-labeled groups: agreed-upon instructions, plaintiff's requested instructions to which defendant objects, and defendant's requested instructions to which plaintiff objects.
The parties shall organize proposed jury instructions into groups 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.
Page 11 | Trial Preparation Order
Trial briefs are optional; if no trial briefs are filed, Tab A of the trial preparation binder is left empty.
Tab A: Trial Briefs (Optional. If no trial briefs are filed, leave Tab A empty.)
Page 11 | Trial Preparation Order
Pre-Motion Conference Requirements
Counsel must meet and confer in good faith before scheduling an IDC or filing a motion to compel further responses.
Before scheduling an IDC or filing a motion to compel further responses, counsel with authority to compromise the dispute must meet and confer by telephone, videoconference, or in person and make a good faith attempt to resolve the discovery dispute without the assistance of the court.
Page 2
All law and motion hearings must be reserved via the Court Reservation System (CRS).
Parties must reserve a date for all law and motion hearings via the Court Reservation System ("CRS").
Page 2
Before scheduling an IDC or filing a motion to compel further responses, counsel with authority to compromise the dispute must meet and confer by telephone, videoconference, or in person and make a good-faith attempt to resolve the dispute.
Before scheduling an IDC or filing a motion to compel further responses, counsel with authority to compromise the dispute must meet and confer by telephone, videoconference, or in person and make a good faith attempt to resolve the discovery dispute without the assistance of the court.
Page 2 | DISCOVERY MOTIONS AND INFORMAL DISCOVERY CONFERENCES
All law and motion hearing dates must be reserved in advance through the Court Reservation System (CRS).
Parties must reserve a date for all law and motion hearings via the Court Reservation System ("CRS").
Page 2 | LAW&MOTION
Trial counsel must meet and confer (by videoconference, telephone, or in person) no later than 15 calendar days before each Case Management Conference to address the issues 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 Conferences
Trial counsel must meet and confer no later than 15 calendar days before each Case Management Conference.
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
Parties must meet and confer no later than 11 calendar days before the Final Status Conference to prepare required documents and binders and to attempt stipulations regarding trial exhibits.
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 Binder required in Sections 3-5, below, (2) discuss and make a good faith effort to stipulate to the authenticity and admissibility of each trial exhibit, (3) discuss and make a good faith effort to
Page 4 | Trial Preparation Order
Motions in limine must be noticed for hearing at the Final Status Conference.
Motions in limine shall be noticed for hearing at the Final Status Conference.
Page 10 | Motions in Limine
An informal discovery conference is strongly encouraged before filing a motion to compel further responses to written discovery, but is no longer required.
The court strongly encourages the parties to schedule an informal discovery conference ("IDC") before filing a motion to compel further responses to written discovery, but IDCs are no longer required.
Page 2 | DISCOVERY MOTIONS AND INFORMAL DISCOVERY CONFERENCES
IDCs are strongly encouraged but not required before filing motions to compel further responses to written discovery.
The court strongly encourages the parties to schedule an informal discovery conference ("IDC") before filing a motion to compel further responses to written discovery, but IDCs are no longer required.
Page 2
Adjournment & Extension Requirements
Motions may be continued or withdrawn only via CRS, and parties must also call the courtroom so the court is aware of the change.
Parties must use CRS to continue or withdraw motions; please also call the courtroom so we are aware of the change.
Page 2 | LAW&MOTION
Parties are strongly encouraged to stipulate to extend motion-to-compel filing deadlines to accommodate IDCs, but the court does not toll those deadlines.
The court strongly encourages the parties to agree to extend the deadline for filing motions to compel further responses to accommodate IDCs, but the deadlines are not tolled by order of the court.
Page 2 | DISCOVERY MOTIONS AND INFORMAL DISCOVERY CONFERENCES
Motions must be continued or withdrawn via CRS, and the courtroom must be notified by phone.
Parties must use CRS to continue or withdraw motions; please also call the courtroom so we are aware of the change.
Page 2
Chambers Communication Rules
please also call the courtroom so we are aware of the change.
please also call the courtroom so we are aware of the change.
Page 2 | LAW&MOTION
Disability accommodation requests must be submitted to Department 2 or the ADA Coordinator (ADACoordinator@LACourt.ca.gov) using form MC-410 or any written format, as far in advance as possible.
If you have a disability and need an accommodation, please submit a request for accommodation directly to Department 2 or to the court's ADA Coordinator at ADACoordinator@LACourt.ca.gov. Requests may be made using form MC-410 or in any other written format. Please make your request as far in advance as possible.
Page 1 | GENERAL INFORMATION
Chambers telephone number is (213) 310-7002.
Telephone Number: (213) 310-7002
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