Judge Lauren A. R. Lofton
Individual Rules, Standing Orders & Policies
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Chambers
Document Format Requirements4 rules
Jury trial binders must include tabbed sections A-H with specified documents; trial briefs are optional.
- Trial binder
Formatting
- •Tab A: Trial Briefs (Optional)
- •Tab C: Joint Witness List
- •Tab D: Joint Exhibit List
- •Tab H: Operative Pleadings
Court's wording
For jury trials, the trial binder shall include the following documents with tabs: A – Trial Briefs (Optional) B – Joint Statement of the Case Joint Witness List C – Joint Witness List D – Joint Exhibit List E – Joint List of Jury Instructions; [Written] Jury Instructions F – Joint or Contested Verdict Form G – Joint Chart of Page and Line Designations for Testimony H – Operative Pleadings
The parties shall organize proposed jury instructions into groups behind Tab 6 in the following order labeled by cover sheets: (1) agreed-upon instructions, (2)
Documentary exhibits consisting of more than one page must be internally paginated in sequential numerical order.
Designated and counter-designated transcript pages must be attached to the Joint Chart with numbered or named tabs and highlighted with each party using a different color highlighter; highlighted transcripts may be printed condensed (four pages per page) and double-sided.
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 Testimony, with numbered or named tabs separating each deposition or trial transcript. Each designation or counter-designation shall be highlighted on the transcript, with each party using a different color highlighter. Highlighted transcripts may be printed condensed – four pages per page – and double-sided.
Document Filing Requirements20 rules
All ex parte applications must make an affirmative showing of “irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte” as required by California Rules of Court, rule 3.1202.
For jury trials, the trial binder shall include the following documents with tabs: A – Trial Briefs (Optional) B – Joint Statement of the Case Joint Witness List C – Joint Witness List D – Joint Exhibit List E – Joint List of Jury Instructions; [Written] Jury Instructions F – Joint or Contested Verdict Form G – Joint Chart of Page and Line Designations for Testimony H – Operative Pleadings
- Document
- Trial binder
Must include
- •Exhibit list
Counsel/parties must submit a joint exhibit list and joint witness list as described below. The parties are expected to have a witness list completed and to have copies of the exhibits available for the court, judicial assistant, opposing counsel, and any witnesses.
- Document
- Bench trial submissions
Must include
- •Exhibit list
Prior to the FSC, counsel are ordered to meet and confer to exchange, discuss, and prepare for submission to the court the jury instructions, verdict form, a statement of the case, and exhibit and witness lists. Counsel shall also attempt to reach stipulations regarding ultimate facts and issues, and authenticity/admissibility of exhibits.
All motions in limine must include a sworn declaration certifying meet and confer with opposing party and their position; failure results in summary denial.
Court's wording
All MILs must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party and setting forth the opposing party’s position regarding the motion(s). Failure to include such a declaration will result in summary denial of the motion(s).
All MILs must be accompanied by a sworn declaration attesting that the subject of the motion has been discussed with the opposing party and setting forth the opposing party’s position regarding the motion(s). Failure to include such a declaration will result in summary denial of the motion(s).
If all parties submit on the court’s tentative ruling, counsel for moving party shall give notice of ruling unless otherwise ordered by the court. This may be done by incorporating verbatim the court’s tentative ruling.
Trial briefs are optional but preferred; if submitted, they should identify major legal issues with supporting authorities, the relief claimed, damages calculation, and other information that may assist the court at trial.
Court's wording
Trial briefs are optional but preferred to the extent they highlight any issues or evidence to which there will be a significant dispute at trial. Any trial brief submitted by a party should identify any major legal issues anticipated with supporting points and authorities, a brief statement of the relief claimed and calculation of damages, and any other information which counsel believes may assist the court in ruling upon trial objections or matters that may arise in trial.
In lieu of a statement of the case, if the parties wish to make a mini-opening statement prior to conducting their voir dire, they must write out their brief statement and share it with opposing counsel.
All witnesses must be listed on one list in alphabetical order by last name. Do not repeat the name of a witness. Indicate the total time expected for that testimony, including direct and re-direct, as well as cross and re-cross. At the end of the list, state the total time estimated for each witness’ testimony.
Exhibits written in a foreign language must be accompanied by a certified English translation.
Counsel are to submit a joint set of CACI instructions with brackets or blanks filled in.
All exhibits must be exchanged and pre-numbered, except those anticipated in good faith to be used for impeachment or rebuttal.
Court's wording
Pursuant to California Rules of Court, rule 3.1110(f) and Local Rules 3.52 and 3.53, all exhibits must be exchanged and pre-numbered, except for those anticipated in good faith to be used for impeachment or during rebuttal.
The list of instructions must include a table which includes columns for all jury instructions by number, name, any objection to the instruction, and whether the instruction is given.
If the parties cannot agree on a general or special verdict form, each party must submit their own proposed verdict form.
If any parties intend to use deposition testimony or former trial testimony in lieu of or in addition to a witness’ 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.
As a reminder, MILs should not be used to seek summary judgment or adjudication of issues, or judgment on the pleadings.
A Statement of the Case is a brief, neutral description of the case to be read to the jury. In most instances, it should not exceed two paragraphs.
Any proposed special verdict should be in a form that is easily used and understood by the jury and which does not require the jury to answer unnecessary questions.
Motions in limine should be specific and tailored to the facts of the case rather than generic or summarizing general legal principles.
Court's wording
Parties are discouraged from filing generic MILs that lack specificity, that are not specifically tailored to the facts of the case, or that summarize general legal principles (e.g., exclude all discovery not disclosed, exclude all hearsay evidence, prohibit reference to settlement negotiations, exclude evidence of a party’s financial condition).
Filing & Service rules
Electronic Filing Rules
Ex parte applications, supporting documents, and written oppositions must be electronically filed, with self-represented litigants exempt.
All ex parte applications and documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the hearing. Any written opposition shall be electronically filed by 8:30 a.m. on the day of the hearing. Pursuant to California Rules of Court, rule 2.253(b)(2), self- represented litigants are exempt from these mandatory electronic filing requirements.
Page 2 | CASE MANAGEMENT CONFERENCES
Ex parte applications, supporting documents, and oppositions must be e-filed by specified deadlines; self-represented litigants are exempt.
All ex parte applications and documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the hearing. Any written opposition shall be electronically filed by 8:30 a.m. on the day of the hearing. Pursuant to California Rules of Court, rule 2.253(b)(2), self- represented litigants are exempt from these mandatory electronic filing requirements.
Page 2 | EX PARTE APPLICATIONS
Filing Timing and Cure Windows
Written opposition to an ex parte application must be e-filed by 8:30 a.m. on the day of the hearing.
Any written opposition shall be electronically filed by 8:30 a.m. on the day of the hearing.
Page 2 | CASE MANAGEMENT CONFERENCES
Ex parte applications and supporting documents must be e-filed no later than 10:00 a.m. the court day before the hearing.
All ex parte applications and documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the hearing.
Page 2 | CASE MANAGEMENT CONFERENCES
Ex parte applications and supporting documents must be e-filed by 10:00 a.m. the court day before the hearing.
All ex parte applications and documents in support thereof must be electronically filed no later than 10:00 a.m. the court day before the hearing.
Page 2 | EX PARTE APPLICATIONS
Written oppositions to ex parte applications must be e-filed by 8:30 a.m. on the hearing day.
Any written opposition shall be electronically filed by 8:30 a.m. on the day of the hearing.
Page 2 | EX PARTE APPLICATIONS
Physical trial binders must be submitted to the courtroom at least five court days before the FSC.
The parties must submit their physical trial binders to the courtroom at least five court days in advance of the FSC.
Page 4 | FINAL STATUS CONFERENCE
Physical trial binders must be submitted to the courtroom at least five court days before the Final Status Conference.
The parties must submit their physical trial binders to the courtroom at least five court days in advance of the FSC.
Page 4 | FINAL STATUS CONFERENCE
A written opposition to a motion in limine may be served and filed no later than five court days prior to the FSC.
A written opposition to a motion in limine may be served and filed no later than five court days prior to the FSC.
Page 7 | FSC
A written opposition to a motion in limine may be served and filed no later than five court days prior to the FSC.
A written opposition to a motion in limine may be served and filed no later than five court days prior to the FSC.
Page 7 | FINAL STATUS CONFERENCE
Replies to motions in limine are optional, but any reply must be served and filed no later than the Friday preceding the trial date.
Replies are not required but may be served and filed no later than the Friday preceding the trial date.
Page 7 | FINAL STATUS CONFERENCE
Replies to motions in limine may be filed no later than the Friday before the trial date.
Replies are not required but may be served and filed no later than the Friday preceding the trial date.
Page 7 | FSC
Filing Fees and Waivers
Motion fees must be paid at the time the motion date reservation is made online.
Motion fee payments are required at the time reservations are made online.
Page 2 | LAW AND MOTION
Motion fees must be paid online when reserving motion date via CRS prior to filing.
Motion fee payments are required at the time reservations are made online.
Page 2 | LAW AND MOTION
Courtesy Copy Requirements
Courtesy copies of moving, opposing, and reply papers are requested for summary judgment/adjudication motions.
Courtesy copies of any moving, opposing, and reply papers are requested for motions for summary judgment/adjudication and any other non-discovery motion where the declaration and exhibits exceed 30 pages.
Page 2 | LAW AND MOTION
Pre-Motion Conference Requirements
Counsel must exhaust all legally required meet and confer efforts before filing any discovery motion.
The court requires all counsel to exhaust all legally required meet and confer efforts before filing a discovery motion.
Page 2 | DISCOVERY
All counsel must complete all legally required meet and confer efforts before filing a discovery motion.
The court requires all counsel to exhaust all legally required meet and confer efforts before filing a discovery motion.
Page 2 | DISCOVERY
Motion dates must be reserved via online CRS prior to filing motion papers; do not call courtroom to reserve.
Please do not call the courtroom to reserve a motion date. Parties must reserve a motion date via the online Court Reservation System (CRS) on the Los Angeles Superior Court website https://portal-lasc.journaltech.com/public-portal/?q=node/388 prior to filing any motion papers.
Page 2 | LAW AND MOTION
Parties must reserve a motion date through the online Court Reservation System (CRS) before filing any motion papers.
Parties must reserve a motion date via the online Court Reservation System (CRS) on the Los Angeles Superior Court website https://portal-lasc.journaltech.com/public-portal/?q=node/388 prior to filing any motion papers.
Page 2 | LAW AND MOTION
Parties must meet and confer before filing any motion in limine per Local Rule 3.57.
Local Rule 3.57 requires the parties to meet and confer before filing any MIL.
Page 6 | Motions in Limine (MILs)
Parties must meet and confer before filing any motion in limine, and the court will not rule on MILs until the first day of trial.
Motions in Limine (MILs): The court does not rule on motions in limine until the first day of trial. Local Rule 3.57 requires the parties to meet and confer before filing any MIL.
Page 6 | Motions in Limine (MILs)
The court strongly encourages (but does not legally require) parties to confer on resolution of issues before filing any motion.
Although not legally required for every motion, the court strongly encourages parties and counsel to confer on potential resolution of issues prior to any motion being filed.
Page 1 | CIVILITY
The court may hold informal discovery conferences to resolve discovery disputes, held Monday through Thursday between 2:00 and 3:00 p.m.
The court may conduct an informal discovery conference (IDC) to assist counsel in resolving discovery disputes informally. IDCs are held Monday through Thursday, between 2:00 and 3:00 p.m.
Page 2 | DISCOVERY
Adjournment & Extension Requirements
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.
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 | CIVILITY
Chambers Communication Rules
Counsel submitting on a tentative ruling must email alhdeptx@lacourt.org, copying all counsel/parties, of their intent to submit.
Counsel wishing to submit on a tentative ruling must send an email to alhdeptx@lacourt.org, and copied to all counsel/parties, advising the court and all counsel of their intention to submit.
Page 2 | TENTATIVE RULINGS
Counsel submitting on a tentative ruling must email alhdeptx@lacourt.org with copies to all parties.
Counsel wishing to submit on a tentative ruling must send an email to alhdeptx@lacourt.org, and copied to all counsel/parties, advising the court and all counsel of their intention to submit.
Page 2 | TENTATIVE RULINGS
Parties may not call the courtroom to reserve motion dates; reservations must be made online via CRS.
Please do not call the courtroom to reserve a motion date.
Page 2 | LAW AND MOTION
Department X courtroom phone is (626) 293-2119, available during 8:30 a.m. to 12:00 p.m. and 1:30 p.m. to 4:30 p.m.
Courtroom Telephone No.: (626) 293-2119 Courtroom Hours: 8:30 a.m. to 12:00 p.m. and 1:30 p.m. to 4:30 p.m.
Page 1 | Department X Courtroom Information
Junior Lawyer Participation Incentives
The court strongly encourages law firms and governmental agencies to give less experienced attorneys the opportunity to argue motions at law and motion hearings and to play an important role at trial.
In accord with Local Rules 3.47 and 3.93, the court strongly encourages law firms and governmental agencies to give less experienced attorneys the opportunity to argue motions at law and motion hearings, and to have an important role at trial, including examining witnesses, conducting voir dire, and giving opening statements and closing arguments.
Page 3 | CIVILITY