Judge Marisa Hernandez-Stern
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- 1 copy • Email • If Filed Less Than Five Days Before Scheduled Hearing
- Not Required
Trial Binder
- At Least 5 Court Days Before FSC
Binding: Three Ring Binder
Adjournments
- Parties should cooperate in scheduling IDCs, which ordinarily includes agreeing to extend the deadline to file a discovery motion to allow time for the IDC.
- A continuance may be sought by noticed motion or ex parte application, which must explain the good cause under California Rule of Court, Rule 3.1332.
- CMCs, MSCs, and other pretrial dates that do not change the trial date may be continued by stipulation, noticed motion, or ex parte application.
- +3 more
Request must include
Communication
Chambers
Phone
Chambers, Clerk
Page & Word Limits2 rules
The IDC statement may either be (a) in the form of a letter to the Court, not to exceed four (4) pages, or (b) on the Superior Court's standard form LASC CIV 239 (do not add extra pages).
- Letter
- Up to 4 pages
- IDC statement
Trial briefs (not to exceed 20 pages) are mandatory in all cases.
- Trial brief
- Up to 20 pages
Document Filing Requirements15 rules
The IDC statement must include a short case description, the discovery dispute and requests/objections/answers at issue, informal resolution attempts, and legal authority, and is generally the only document the Court reads in preparation for the IDC.
Court's wording
The IDC statement should include (a) a short description of the case, (b) a description of the discovery dispute including a list or summary of the discovery requests, objections, and/or answers at issue, (c) a description of the parties' informal attempts to resolve the dispute, and (d) any legal authority the Court should consider. Generally, the IDC statement is the only document the Court will read in preparation for the IDC.
Parties and counsel must submit Case Management Statements in advance of the CMC as required by California Rules of Court Rule 3.725.
Court's wording
The parties and their counsel must comply with (a) Rule 3.725 of the California Rules of Court, which requires them to submit Case Management Statements in advance, and (b) Rule 3.724, which requires them to meet and confer—in person or by telephone, not by email— and specifically consider each of the items in Rule 3.727 and in Rule 3.724(1)-(9). The court takes this obligation seriously.
For trials in which there is no court reporter, the Court requires that the parties compile a joint daily summary of testimony.
These briefs should include a description of the claims, defenses, relief sought, evidentiary disputes, and all issues to be decided at trial along with a discussion of any novel or unusual issues of law, with citations to supporting authorities. The briefs must be signed, filed with the Court and served on all parties.
Statement of the Case must be prepared jointly by the parties for use in any jury trial. It should be a short, non-argumentative written statement of the case to be read to the jury. It must be signed by all parties and filed with the Court.
Witness List must be prepared jointly by the parties. The list must include all witnesses' names, a brief description of the proposed testimony, including whether it will be lay testimony or expert opinion, time estimates for direct and cross examination, and whether the witness will be assisted by an interpreter. The joint witness list must be signed by all parties and filed the Court.
The parties shall cooperate in preparing a chart for each witness that includes a column for each of the following: (1) the proponent's designations by page and line; (2) counter-designations by other parties; (3) objections to specific language included in the designations; and (4) a blank column for the Court's rulings.
The joint exhibit list must be prepared in chart format, signed by all parties, and filed with the Court.
Court's wording
Exhibit List must be prepared jointly by the parties. It should be prepared in chart format with each exhibit identified by title and its assigned exhibit number. Additional columns should indicate whether the exhibit will be admitted by stipulation, authenticated by stipulation, or challenged with objections, which shall be set forth in a column for objections. A final column should be included on the right for the Court's notation of whether the exhibit was admitted at trial. The joint exhibit list must be signed by all parties and filed the Court.
The joint list of proposed jury instructions must be in chart format identifying proponents and opponents of each instruction, signed by all parties, and filed with the Court.
Court's wording
List of Proposed Jury Instructions must be prepared jointly by the parties. It should be prepared in chart format and include all CACI and special jury instructions that are jointly proposed by the parties as well as those that are proposed by only some of the parties but opposed by another party. A column in the chart must indicate the proponent(s) and opponent(s) of each proposed instruction. A final column should be included on the right for the Court's notation of whether the instruction was given at trial. The joint list of jury instructions must be signed by all parties and filed the Court.
When the instructions are finalized, the parties are to submit a full set of all instructions given at trial without any titles or number so these instructions can be presented to the jury to be used during deliberations.
Verdict forms must be jointly prepared (or separately proposed if pending rulings may affect format), and each proposed form must be signed, filed with the Court, and served on the other parties.
Court's wording
Verdict Forms must be jointly prepared by the parties. If rulings on evidentiary issues or pre-trial motions may impact on the proper format for the verdict forms, the parties may each submit their own proposed verdict forms. Each proposed verdict form must be signed by the party or counsel proposing it, filed with the Court and served on the other parties.
Each party's motions in limine must be labeled sequentially, i.e., Plaintiff's Motion in Limine No. 1, et seq., and Defendant's Motion in Limine No. 1, et seq.
the operative complaints and cross-complaints and the operative answers thereto.
If there is an applicable CACI instruction on a point of law, the Court expects the parties to request the CACI instruction instead of a specially prepared instruction.
The Court requires timely compliance with California Rules Court, Rule 3-300 regarding notices of related cases.
Filing & Service rules
Electronic Filing Rules
All attorneys must comply with the Los Angeles Superior Court's rules, orders, and procedures governing electronic filing.
All attorneys must comply with the Superior Court of Los Angeles County's rules, orders, and procedures governing electronic filing. Please refer to www.lacourt.ca.gov for more information on electronic filing.
Page 4 | Filings and E-Mail Courtesy Copies – No Paper Courtesy Copies
Filing Timing and Cure Windows
Each party involved in a discovery dispute must file and serve an IDC statement at least three court days before the scheduled IDC.
Each party involved in a discovery dispute to be addressed in an IDC must file and serve an IDC statement at least three (3) court days before the scheduled IDC.
Page 3 | Discovery and Informal Discovery Conferences
The joint daily summary of testimony must be submitted to the Court by 4:00 p.m. on the day following the testimony.
The joint daily summary must be completed and submitted to the Court by 4:00 p.m. on the day following the testimony.
Page 6 | Daily Summaries for Trials Without a Reporter
All trial documents must be filed at least seven court days before the FSC.
Pursuant to LACCR 3.25 (g)(3), the parties shall file all trial documents at least seven (7) court days before the FSC.
Page 8 | DEPARTMENT 507
Replies to motions in limine must be in writing and properly filed and served before the FSC; noncompliance with the motion-in-limine timelines may result in the Court refusing to hear the motion or consider an opposition.
Reply briefs must be in writing and properly filed and served before the FSC. The failure to comply with these rules and timelines may result in the Court's refusal to hear a motion in limine or consider an opposition thereto, consistent with applicable rules.
Page 10 | Motions in Limine
All motions in limine must be in writing and filed and served at least 12 court days before the FSC.
All motions in limine must be in writing and must be filed and served at least twelve (12) court days before the FSC.
Page 10 | Motions in Limine
Oppositions to motions in limine must be in writing and filed and served at least 7 court days before the FSC.
Any opposition to a motion in limine must be in writing and must be filed and served at least seven (7) court days before the FSC.
Page 10 | Motions in Limine
A proposed protective order must be served and filed within 5 days of this order.
If a party believes any of the information described in sections 2 or 3 of this Order should be subject to a protective order, that party shall serve and file a proposed protective order within 5 days of this order and the parties shall meet and confer as to agreeable language for the same.
Page 14 | Protective Orders
Service and Proof of Service Rules
Proposed jury questionnaires must be filed with the Court and served on all parties.
Proposed jury questionnaires shall be filed with the Court and served on all parties.
Page 11
Within 30 days of the CMC order, plaintiff must provide copies of specified documents (purchase/lease contracts, vehicle registration, finance/account information, repair orders, incidental damages documents, market value information, and pre-suit communications) to the opposing side(s).
Within 30 days of this order plaintiff shall provide copies of the following documents, which are in Plaintiff's possession, custody and/or control, to the opposing side(s):
Page 12 | Production of Documents (Plaintiff)
The party producing documents in discovery must serve verifications along with the produced documents.
The producing party shall serve verifications with the documents produced.
Page 14 | Production of Documents (Defendant)
When all parties submit on the tentative ruling, it becomes the order of the Court and the moving party must give notice of the ruling.
Upon receiving notice that all parties have submitted on the tentative, the tentative ruling will become the order of the Court and the moving party shall give notice of the ruling.
Page 6 | Tentative Rulings
Each proposed verdict form must be served on the other parties.
Each proposed verdict form must be signed by the party or counsel proposing it, filed with the Court and served on the other parties.
Page 9
Documents produced in discovery may be served on the opposing party electronically as a PDF at the producing party's option.
The information may be provided to the opposing party in electronic form as a PDF at the option of the producing party.
Page 14 | Production of Documents (Defendant)
Filing Fees and Waivers
Jury fees must be posted no later than 30 days before trial, and the deadline shifts to 30 days before any continued trial date.
Jury Fees must be posted no later than 30 days before the date of trial, unless otherwise ordered by the Court. If the trial date is continued, the deadline for jury fees is continued to 30 days prior to the new trial date.
Page 6 | Jury Fees
Self-represented litigants with a granted fee waiver may use LACourtConnect at no cost.
Self-represented litigants who have been granted a fee waiver may use LACourtConnect at no cost.
Page 7 | Special Information for Self-Represented Litigants
Courtesy Copy Requirements
A courtesy copy of any document filed less than five days before the scheduled hearing must be emailed to the Court at SMCDept507@lacourt.org.
A courtesy copy of any document filed less than five days before the scheduled hearing must be submitted to the Court by email only. The Court's email address is SMCDept507@lacourt.org.
Page 4 | Filings and E-Mail Courtesy Copies – No Paper Courtesy Copies
Paper courtesy copies are not required for any document and should not be provided.
The Court does not require or request paper courtesy copies. No paper courtesy copies of any document are needed, and no paper courtesy copies should be provided.
Page 4 | Filings and E-Mail Courtesy Copies – No Paper Courtesy Copies
The parties must jointly compile a three-ring trial binder and deliver it to Department 507 at least five court days before the FSC.
Trial Binder: The parties shall cooperate in compiling a three-ring trial binder that shall be delivered to Department 507 at least five (5) court days before the FSC.
Page 8 | Trial Binder
Sealing & Redaction Procedures
A party seeking protection for information covered by sections 2 or 3 must serve and file a proposed protective order within 5 days and meet and confer on language, with the standard LASC protective order as the default.
If a party believes any of the information described in sections 2 or 3 of this Order should be subject to a protective order, that party shall serve and file a proposed protective order within 5 days of this order and the parties shall meet and confer as to agreeable language for the same. The default will be the standard Protective Order provided by the LASC in its website.
Page 14 | Protective Orders
Filing Bundling Requirements
The binder must include all the following documents placed in the binder in the following order:
The binder must include all the following documents placed in the binder in the following order:
Page 8 | Trial Binder
Proposed Jury Instructions shall be included in the Trial Binder. These should include a jointly submitted packet of all requested and properly edited CACI jury instructions as to which there is no objection, as well as packets from any party offering CACI or special instructions that are not agreed to by all parties. The Proposed Jury Instructions should be submitted with CACI titles and numbers as well as numbered Special Instructions.
Proposed Jury Instructions shall be included in the Trial Binder. These should include a jointly submitted packet of all requested and properly edited CACI jury instructions as to which there is no objection, as well as packets from any party offering CACI or special instructions that are not agreed to by all parties. The Proposed Jury Instructions should be submitted with CACI titles and numbers as well as numbered Special Instructions.
Page 9
Any important orders that may impact the scope or nature of the trial must be included in the Trial Binder.
Any Important Orders that may impact the scope or nature of the trial shall be included in the Trial Binder.
Page 10
All motions in limine briefing must be assembled in tabbed three-ring binders (moving papers, opposition, and reply behind a tab per motion) and delivered to the Court at least 5 court days before the FSC.
The parties are ordered to collect the briefing on all motions in limine and present them in one or more three-ring binders, with the moving papers, opposition and reply for each motion arranged behind a tab for each motion. The motion in limine binders shall be delivered to the Court at least five (5) court days before the FSC.
Page 10 | Motions in Limine
Any proposed jury questionnaire and all competing versions advanced by other parties must be included in the Trial Binder.
If any party seeks to use a jury questionnaire, its proposed questionnaire and all competing versions advanced by other parties must be included in the Trial Binder.
Page 11
The Court encourages written stipulations narrowing triable issues, which should be filed with the Court and included in the Trial Binder if reached before trial.
The Court encourages the parties to narrow the scope of triable issues by reaching stipulations as to certain undisputed facts. Such stipulations should be reduced to writing and filed with the Court. They should also be included in the Trial Binder, if reached before trial.
Page 10 | Trial Rules
Pre-Motion Conference Requirements
Parties must check in at 8:30 a.m. (mornings) or 1:30 p.m. (afternoons); ex parte applications are heard at 8:30 a.m. and law-and-motion at 9:00 a.m.
Check In: 8:30 (mornings); 1:30 (afternoon). Ex Parte applications are heard at 8:30 and law-and motion at 9:00.
Page 1 | Courtroom Information for Department 507
Appearance at a scheduled Informal Discovery Conference is mandatory and will be confirmed by court order.
Once the IDC is scheduled, appearance at the IDC will be confirmed by court order and appearance is mandatory.
Page 3 | Discovery and Informal Discovery Conferences
A party is prohibited from reserving more than one hearing date for the same motion.
Note: you are prohibited from reserving more than one hearing date for the same motion.
Page 4 | Scheduling Law and Motion Hearings
A CRS reservation is required to schedule law and motion hearings in Department 507; CRS is available 24/7 from a computer or smartphone.
The Court Reservation System (CRS) is required for scheduling law and motion hearings in Department 507. CRS is available 24 hours a day, seven days a week and reservations can be made from a computer or smart phone.
Page 4 | Scheduling Law and Motion Hearings
Before the Case Management Conference, parties must meet and confer in person or by telephone (not by email) and specifically consider each item in CRC Rules 3.727 and 3.724(1)-(9).
The parties and their counsel must comply with (a) Rule 3.725 of the California Rules of Court, which requires them to submit Case Management Statements in advance, and (b) Rule 3.724, which requires them to meet and confer—in person or by telephone, not by email— and specifically consider each of the items in Rule 3.727 and in Rule 3.724(1)-(9). The court takes this obligation seriously.
Page 4 | Case Management Conferences
Counsel and self-represented litigants must meet and confer (in person, by telephone, or by video conference) at least 12 court days before the FSC regarding the trial documents identified in LACCR 3.25(f) and (g)(3)-(8).
To prepare for the Final Status Conference (FSC), counsel and/or self- represented litigants shall meet and confer in person, on the telephone, or by video conference at least twelve (12) court days before the FSC to discuss, arrange for the exchange of, and prepare for submission to court of all documents identified in LACCR 3.25 (f) and (g) (3)-(8).
Page 8 | DEPARTMENT 507
Counsel and self-represented litigants must meet and confer (in person, by telephone, or by video) on all motions in limine before the Court considers them; boilerplate or form motions are strongly discouraged.
Counsel and/or self-represented litigants shall meet and confer in person or by telephone or video conference on all motions in limine before they are considered by the Court. Boilerplate or form motions are strongly discouraged.
Page 10 | Motions in Limine
Parties are strongly encouraged (but not required) to participate in an informal discovery conference before filing any motion to compel, motion to quash, or motion for a protective order.
Thus, the Court strongly encourages parties to participate in an informal discovery conference before filing any motion to compel further discovery responses (including a motion to compel, motion to quash, or motion for a protective order).
Page 2 | 3. Discovery and Informal Discovery Conferences
Parties should meet and confer, preferably through a conversation rather than an exchange of emails or letters, before filing any motion.
The parties should meet and confer—preferably, through a conversation, not simply an exchange of emails or letters—before filing any motion.
Page 3 | Scheduling Law and Motion Hearings
Adjournment & Extension Requirements
Trial dates are firm and continuances are disfavored; any request to continue a trial or trial setting conference must specifically demonstrate good cause under California Rules of Court, Rule 3.1332.
"To ensure the prompt disposition of civil cases, the dates assigned for a trial are firm. All parties and their counsel must regard the date set for trial as certain." (California Rule of Court, rule 3.1332(a); see also rule 3.1332(c) ["continuances of trials are disfavored"].) Any request for a continuance of trial or a trial setting conference must specifically demonstrate good cause under the standards set by California Rules of Court, Rule 3.1332.
Page 5 | Continuances
A continuance may be sought by noticed motion or ex parte application, which must explain the good cause under California Rule of Court, Rule 3.1332.
Alternately, any party may seek a continuance by noticed motion or ex parte application. The motion or application must explain the good cause for the continuance under the standards set by California Rule of Court, Rule 3.1332.
Page 5 | Continuances
Stipulated requests to continue the trial date are disfavored and will be rejected without a proper showing of good cause.
The parties may seek a continuance by stipulation setting out proffered good cause. However, even stipulated continuances of the trial date are disfavored—the Court will reject a stipulated request for continuance without a proper showing of good cause.
Page 5 | Continuances
Parties may continue Law and Motion matters through the CRS system.
The parties may continue Law and Motion matters through the CRS system.
Page 5 | Continuances
CMCs, MSCs, and other pretrial dates that do not change the trial date may be continued by stipulation, noticed motion, or ex parte application.
Requests to continue Case Management Conferences, Mandatory Settlement Conferences, and other pretrial dates that do not require a change in the trial date may be made via stipulation of the parties (if the parties agree) or by noticed motion or ex parte application.
Page 5 | Continuances
Parties should cooperate in scheduling IDCs, which ordinarily includes agreeing to extend the deadline to file a discovery motion to allow time for the IDC.
The Court requests civility and cooperation in scheduling an IDC. Civility and cooperation ordinarily includes an agreement to extend the time to file a discovery motion to allow time for an IDC.
Page 3 | Discovery and Informal Discovery Conferences
Chambers Communication Rules
If all counsel and self-represented parties intend to submit on the tentative ruling and do not wish oral argument, please advise the Court's clerk by calling (213) 633-0647 before the scheduled time for the hearing.
If all counsel and self-represented parties intend to submit on the tentative ruling and do not wish oral argument, please advise the Court's clerk by calling (213) 633-0647 before the scheduled time for the hearing.
Page 6 | Tentative Rulings
Parties may submit on the tentative ruling by emailing SMCDept507@lacourt.org no later than 8:30 a.m. on the day of the hearing.
The parties may also submit on the tentative ruling via email to SMCDept507@lacourt.org no later than 8:30 a.m. on the day of the hearing.
Page 6 | Tentative Rulings
Department 507 chambers can be reached by phone at (213) 633-0647, with courtroom hours of 8:30 a.m. to 12:00 p.m. and 1:30 p.m. to 4:30 p.m.
Telephone number: (213) 633-0647 Courtroom hours: 8:30 a.m. to 12:00 p.m. and 1:30 p.m. to 4:30 p.m.
Page 1 | Courtroom Information for Department 507
An IDC may be scheduled either through the CRS system or by calling the department.
The IDC may be scheduled either through the CRS system or by calling the department.
Page 3 | Discovery and Informal Discovery Conferences
The Court's email address for courtesy copies and submissions is SMCDept507@lacourt.org.
The Court's email address is SMCDept507@lacourt.org.
Page 4 | Filings and E-Mail Courtesy Copies – No Paper Courtesy Copies
Junior Lawyer Participation Incentives
The Court encourages (but does not require) senior lawyers to let junior lawyers who substantially drafted motion papers or prepared trial examinations argue and examine witnesses.
The Court encourages and welcomes active participation by less-experienced attorneys. When more than one attorney represents a client, and where a more junior lawyer has played a substantial part in drafting motion papers or preparing a trial examination, the Court encourages (but does not require) the more senior lawyer to allow the more junior lawyer to speak and practice before the Court and/or to examine a witness.
Page 7 | Less-Experienced Attorneys