Judge Michael J. O'Gara
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- Two Calendar Days Before FSC
Binding: Tabbed Three Ring
Deposition Transcripts
- First Day of Trial Before Trial Begins
Discovery Excerpts
- First Day of Trial
Exhibit
- 4 copies • First Day of Trial
Adjournments
- Continuances of hearing dates, including trial dates, may be sought by written Stipulation and Order.
- Continuance requests via Stipulation and Order must state complaint filing date, current trial date, and proposed FSC and trial dates.
- Absent a stipulation, continuances may be sought by noticed motion or ex parte application.
Request must include
Communication
Phone
Clerk
Page & Word Limits2 rules
Trial briefs are mandatory for all (both Court and jury) trials and must include the following information and not exceed 20 pages:
- Trial brief
- Up to 20 pages
Trial briefs are mandatory for all (both Court and jury) trials and must include the following information and not exceed 20 pages:
- Trial brief
- Up to 20 pages
Document Format Requirements8 rules
All papers filed by self-represented litigants must be stapled separately before filing, or they will be rejected.
- Self-represented parties
- Binding
- Stapled
All papers filed by self-represented litigants must be stapled separately before filing, or they will be rejected.
- Self-represented parties
- Binding
- Stapled
Formatting
- •Papers not stapled separately will be rejected
All document exhibits MUST be placed in binders under tabs, and each page must be numbered within each tab.
- Binding
- Tabbed binder
- Exhibits
All document exhibits must be placed in tabbed binders with numbered pages, exhibit list included, and provided to judge, staff, and opposing counsel.
- Exhibit
Formatting
- •Each page numbered within each tab
- •Exhibit list included in binders
Court's wording
EXHIBITS: All document exhibits MUST be placed in binders under tabs, and each page must be numbered within each tab. The exhibit list must be included in the binders. Exhibits must be brought to Court on the first day of trial. Binders should be provided for the Judge, Judicial Assistant, Opposing Counsel and Reporter.
Hard copy jury instructions must be on 2-hole punched, perforated paper.
- Jury instruction
Formatting
- •2-hole punched
- •Perforated paper
Court's wording
The printed, hard copy of the jury instructions delivered directly to Department F43 shall be submitted on 2-hole punched, perforated paper so as to allow for separation of the identification of the instruction from the text of the instruction, to be submitted to the jury for reference during deliberation.
The printed, hard copy of the jury instructions delivered directly to Department F43 shall be submitted on 2-hole punched, perforated paper so as to allow for separation of the identification of the instruction from the text of the instruction, to be submitted to the jury for reference during deliberation.
All motions in limine, if any, must be in writing, numbered, and shall be served on all opposing parties and counsel and electronically filed at least ten (10) calendar days before the FSC.
Exhibits should be numbered consecutively in the lower right-hand corner, with each page given an exhibit number using a dash for multi-page exhibits (e.g., Exhibit 1-1, 1-2, 1-3).
Court's wording
Those exhibits can be numbered consecutively in the lower, right-hand corner of each document. Each page should be given an exhibit number, so that if an exhibit contains multiple pages, it should have a "-" (dash) delineating each page. For example, if Exhibit 1 consists of 3 pages, it would be numbered as follows: Exhibit 1-1, 1-2, and 1-3.
Document Filing Requirements24 rules
Parties requiring a court reporter must file Form LACIV237 or LACIV236 in the courtroom prior to the case being called.
Court's wording
COURT REPORTERS: If you require a court reporter, you must provide your own. The following forms must be filed in the courtroom prior to the judge calling your case: Form LACIV237, if the court reporter is listed on the court's Pro Tempore Court Reporter Directory; or, Form LACIV236, if the court reporter is not listed on said directory.
Judgments, orders, and stipulations may be filed directly in the courtroom but must include self-addressed, stamped envelopes and copies to conform.
If you require a court reporter, you must provide your own. The following forms must be filed in the courtroom prior to the judge calling your case: Form LACIV237, if the court reporter is listed on the court's Pro Tempore Court Reporter Directory; or, Form LACIV236, if the court reporter is not listed on said directory.
Please note that the Court may not consider ex parte applications submitted/filed without a proposed order.
Please note that the Court may not consider ex parte applications submitted/filed without a proposed order.
The exhibit list must be included in the binders.
- Document
- Exhibit binder
Must include
- •Exhibit list
Said Stipulation and Order shall state the date the Complaint was filed, the current trial date, as well as the proposed Final Status Conference date and proposed trial date.
h. 3-Ring Trial Binder containing all the documents above in 4.b through 4.g, with a table of contents.
A special verdict form is mandatory, must be jointly prepared in final form, and must be adapted to CACI with proper spacing.
Court's wording
A special verdict form is mandatory and shall be jointly prepared in final form. This special verdict form shall be adapted to CACI with proper spacing, particularly noted to allow for both clarity and direction.
Each requested CACI instruction must identify the requesting party/parties at the top, state whether it is given as requested or modified, state whether it is withdrawn, and include a signature line for the Court.
Court's wording
All requested CACI instructions, per the foregoing, must be submitted in proper form which includes: A) At the top of each requested jury instruction, identification of the party/parties requesting the instruction; B) Whether the instruction is to be given as requested or modified; C) Whether the instruction is withdrawn; and D) A signature line for the Court.
A jointly submitted packet of all requested and properly edited jury instructions to which there is no objection.
Each party must submit its own specifically requested and properly edited instructions not requested by the opposing party, inserted into the joint packet.
Court's wording
Each party shall also submit specifically requested and properly edited instructions not requested by the opposing counsel/party. These instructions shall be inserted into the aforementioned packet of the jointly submitted jury instructions, all to be considered and discussed by the Court at an appropriate time during the pendency of the trial.
For all trials (jury and non-jury), the parties/counsel shall jointly prepare and lodge a trial binder with the Court at least two (2) calendar days before the FSC, containing the required trial documents, tabbed and organized into 3-ring binders, with a Table of Contents in the front of each binder, as follows: Tab A: Trial Briefs of all parties Tab B: Joint Witness List Tab C: Joint Statement to be Read to the Jury Tab D: Joint Exhibit List Tab E: Joint List of Jury Instructions (identifying the agreed upon and contested instructions) Tab F: Joint and Contested Jury Instructions
- Document
- Trial binder
Must include
- •Exhibit list
- •Table of contents
Any objections to the use of discovery material shall be done by way of an in limine motion.
The parties shall organize proposed jury instructions behind Tab F, with the agreed upon instructions first in order followed by the contested instructions (including special instructions) submitted by each party.
Judgments, orders, and stipulations may be filed directly in the courtroom but must include self-addressed, stamped envelopes and copies to conform.
Oppositions to motions in limine must be in writing, numbered, and must refer to the numbers used by the moving party.
Court's wording
An opposition to any motion in limine must be in writing, numbered, and served and electronically filed by represented parties at least five (5) calendar days prior to the FSC. (Exempt parties may file the same by conventional means on printed paper directly in Department F43.) The opposition must refer to the numbers used by the moving party.
Trial briefs are mandatory for all (both Court and jury) trials and must include the following information and not exceed 20 pages:
Each party must prepare a list of discovery material intended for use at trial identifying date, document, page and line, and must lodge originals of depositions or discovery responses with the Court at the time of trial.
Court's wording
Each party must prepare a list of discovery material intended to be used at trial, including but not limited to interrogatories and requests for admissions and any responses thereto as well as deposition(s), all of which shall specifically identify the date, document, page and line. If depositions or other discovery responses are intended to be used at trial, originals shall be lodged with the Court at the time of trial.
The parties shall submit a printed copy of the jointly prepared, short, non-argumentative written statement of the case to be read to the jury.
The jointly prepared Witness List must include the name of each witness, an estimate of time for direct and cross-examination, and the total amount of time of all witness testimony combined for the entire trial. Potential scheduling problems must be noted.
Parties must jointly prepare and exchange a completed exhibit list identifying each exhibit and stipulations, with pre-agreed numbering ranges, separately identified subparts, consecutive pagination, and exchange/review of all listed items prior to the FSC.
Court's wording
All parties must jointly prepare and exchange a completed Exhibit List, indicating each document and item of physical evidence, and whether there is a stipulation to authenticity and/or admissibility. Each exhibit shall be numbered or lettered. All parties shall agree in advance that their respective party will have a range of exhibit numbers or letters (e.g. Plaintiff No. 1: 1-99; Plaintiff No. 2: 100-199; Defendant: A- Z). Each exhibit must be separately identified. Subparts to an exhibit (e.g., 1A, IB, etc.) must also be identified and listed separately. Each page of a multi-page exhibit must be consecutively paginated. All items so referred to in the Exhibit List must be exchanged and/or reviewed by each counsel or the parties prior to the FSC.
The list provided by Defendant may be in the chart or spreadsheet format, and shall include the CIN, date of repair visit, dealership or other reporting location, and the text of the other customers' reported complaint, but shall not include the other customers' names, addresses, phone numbers, e-mail addresses, or other personal identifying information.
The Court strongly encourages the use of CACI jury instructions.
Filing & Service rules
Electronic Filing Rules
Represented litigants must electronically file all documents with the Court through the approved Electronic Filing Service Provider.
Represented litigants are required to electronically file all documents with the Court through the approved Electronic Filing Service Provider.
Page 1 | Filings by Represented Litigants
Self-represented litigants are exempt from mandatory electronic filing requirements.
FILINGS BY SELF-REPRESENTED LITIGANTS: Self-represented litigants are exempt from mandatory electronic filing requirements.
Page 1 | FILINGS BY SELF-REPRESENTED LITIGANTS
Represented litigants must electronically file all documents through the approved Electronic Filing Service Provider.
FILINGS BY REPRESENTED LITIGANTS: Represented litigants are required to electronically file all documents with the Court through the approved Electronic Filing Service Provider.
Page 1 | FILINGS BY REPRESENTED LITIGANTS
Self-represented parties may file ex parte oppositions electronically by 8:30 a.m. on the hearing day or bring them to the courtroom on the day of the hearing.
Oppositions by self-represented parties, if any, shall either be filed electronically by no later than 8:30 a.m. the day of the hearing or be brought to the courtroom on the day of the ex parte hearing.
Page 3 | Ex Parte Applications
Represented parties must e-file all trial documents except exhibits per the Final Status Conference Order.
All trial documents filed by represented parties must be electronically filed pursuant to the Final Status Conference Order (except for exhibits).
Page 3 | TRIALS
Represented parties must e-file all trial documents pursuant to the Final Status Conference Order, except exhibits.
All trial documents filed by represented parties must be electronically filed pursuant to the Final Status Conference Order (except for exhibits).
Page 3 | Trials
Self-represented parties may either e-file ex parte documents by 10:00 a.m. the day before the hearing or personally deliver the ex parte application, declaration of notice, and proposed order to the Clerk's Office by 8:30 a.m. on the hearing day and bring proof of payment to the courtroom (timely e-filers may appear via LACourtConnect).
Self-represented parties must either electronically file by I 0:00 a.m. the day before the ex parte hearing or personally bring the ex parte hearing, declaration of notice, and a proposed order to the Clerk's Office for payment of the fee by 8:30 a.m. on the day of the hearing and proceed immediately to the courtroom with the ex parte application, declaration of notice, a proposed order, and proof of payment.
Page 3 | Ex Parte Applications
All trial documents filed by self-represented litigants must be filed directly in Department F43 pursuant to the Court's Final Status Conference Order.
All trial documents filed by self-represented litigants must be filed directly in Department F43 pursuant to the Court's Final Status Conference Order.
Page 3 | Trials
If the case settles before the FSC, no appearance is required as long as a Request for Dismissal or Notice of Settlement is electronically filed at least 2 court days before the FSC.
If the action is settled or otherwise resolved before the FSC, no appearance will be necessary as long as either a Request for Dismissal of the entire action or a Notice of Settlement under California Rules of Court Rule 3.1385 is electronically filed with this Court at least two (2) court days before the scheduled FSC.
Page 5 | Final Status Conference Order
Motions in limine, trial briefs, joint witness lists, and joint exhibit lists must be filed electronically at least 10 calendar days before the FSC; exempt parties may file by paper instead.
For all Court trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC. a. Motions in Limine (if any), b. Trial Briefs, c. Joint Witness List, and d. Joint Exhibit List.
Page 5 | Final Status Conference Order
Oppositions to motions in limine must be electronically filed by represented parties; exempt parties may file printed paper copies directly in Department F43.
An opposition to any motion in limine must be in writing, numbered, and served and electronically filed by represented parties at least five (5) calendar days prior to the FSC. (Exempt parties may file the same by conventional means on printed paper directly in Department F43.)
Page 7 | Requirements for Specific Trial Documents - Motions in Limine
In jury trials, all trial documents (motions in limine, trial briefs, joint witness and exhibit lists, joint statement of the case, joint jury instructions, joint verdict form, and the 3-ring trial binder) must be filed electronically at least 10 calendar days before the FSC, with exempt parties allowed to file printed paper copies.
For all jury trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC.
Page 7 | Trials
Jury instructions must be e-filed plus hard copy delivered to Dept F43; self-represented only need hard copy.
Jury Instructions shall be submitted by both electronic filing and by a printed copy delivered directly to Department F43. However, non-represented parties are only required to submit jury instructions by delivering a printed copy directly to Department F43.
Page 9 | JURY INSTRUCTIONS
Jury instructions must be submitted both electronically and as a printed copy delivered directly to Department F43, except self-represented parties need only deliver the printed copy.
Jury Instructions shall be submitted by both electronic filing and by a printed copy delivered directly to Department F43. However, non-represented parties are only required to submit jury instructions by delivering a printed copy directly to Department F43.
Page 9 | Jury Instructions
Trial and evidentiary hearing exhibits must not be filed electronically.
Trial and evidentiary hearing exhibits shall not be filed electronically.
Page 10 | 7. EXHIBITS
Self-represented litigants are exempt from mandatory electronic filing requirements.
Self-represented litigants are exempt from mandatory electronic filing requirements.
Page 1 | Filings by Self-Represented Litigants
Remote appearance at the Final Status Conference via the LACourtConnect portal is optional, requires no prior court approval, and is scheduled through the Attorney Portal at LACourt.ca.gov.
Appearance at the FSC through LACourtConnect is optional. No prior Court approval is necessary. To schedule an appearance through LACourtConnect, please visit LACourt.ca.gov, then go to "Here For You/Safe For You" and in the "Attorney Portal" you may set up an account then schedule your remote appearance.
Page 5 | Final Status Conference Order
Filing Timing and Cure Windows
Written oppositions to ex parte applications must be e-filed by 8:30 a.m. the day of the hearing.
Written oppositions shall be electronically filed by 8:30 a.m. the day of the ex parte hearing.
Page 3 | EX PARTE APPLICATIONS
Ex parte applications, supporting documents, and proposed order must be e-filed by 10:00 a.m. the court day before the hearing.
Ex Parte applications, supporting documents, and a proposed order must be electronically filed no later than 10:00 a.m. the court day before the ex parte hearing.
Page 3 | EX PARTE APPLICATIONS
Self-represented parties may e-file ex parte documents by 10:00 a.m. before the hearing or hand-deliver to Clerk's Office by 8:30 a.m. hearing day.
Self-represented parties must either electronically file by 10:00 a.m. the day before the ex parte hearing or personally bring the ex parte hearing, declaration of notice, and a proposed order to the Clerk's Office for payment of the fee by 8:30 a.m. on the day of the hearing and proceed immediately to the courtroom with the ex parte application, declaration of notice, a proposed order, and proof of payment.
Page 3 | EX PARTE APPLICATIONS
Written oppositions to ex parte applications must be e-filed by 8:30 a.m. on the day of the hearing.
Written oppositions shall be electronically filed by 8:30 a.m. the day of the ex parte hearing.
Page 3 | Ex Parte Applications
Ex parte applications, supporting documents, and a proposed order must be e-filed by 10:00 a.m. the court day before the ex parte hearing.
Ex Parte applications, supporting documents, and a proposed order must be electronically filed no later than 10:00 a.m. the court day before the ex parte hearing.
Page 3 | Ex Parte Applications
Trial documents (motions in limine, trial briefs, joint witness list, joint exhibit list) must be filed at least 10 calendar days before the FSC.
For all Court trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC. a. Motions in Limine (if any), b. Trial Briefs, c. Joint Witness List, and d. Joint Exhibit List.
Page 5 | Final Status Conference Order
Request for Dismissal or Notice of Settlement must be e-filed at least 2 court days before FSC to avoid appearance.
If the action is settled or otherwise resolved before the FSC, no appearance will be necessary as long as either a Request for Dismissal of the entire action or a Notice of Settlement under California Rules of Court Rule 3.1385 is electronically filed with this Court at least two (2) court days before the scheduled FSC.
Page 5 | FINAL STATUS CONFERENCE ORDER
Court trial documents (MILs, trial briefs, witness list, exhibit list) must be filed 10 calendar days before FSC.
For all Court trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC. a. Motions in Limine (if any), b. Trial Briefs, c. Joint Witness List, and d. Joint Exhibit List.
Page 5 | FINAL STATUS CONFERENCE ORDER
A Request for Dismissal or Notice of Settlement must be filed at least 2 court days before the scheduled FSC.
If the action is settled or otherwise resolved before the FSC, no appearance will be necessary as long as either a Request for Dismissal of the entire action or a Notice of Settlement under California Rules of Court Rule 3.1385 is electronically filed with this Court at least two (2) court days before the scheduled FSC.
Page 5 | Final Status Conference Order
Jury trial documents must be filed 10 calendar days before FSC.
For all jury trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC. a. Motions in Limine (if any), b. Trial Briefs, c. Joint Witness List, d. Joint Exhibit List, e. Joint Statement of the Case, f. Joint Jury Instructions, g. Joint Verdict Form, and, h. 3-Ring Trial Binder containing all the documents above in 4.b through 4.g, with a table of contents.
Page 7 | FINAL STATUS CONFERENCE ORDER
Oppositions to motions in limine must be served and electronically filed at least five (5) calendar days before the FSC.
An opposition to any motion in limine must be in writing, numbered, and served and electronically filed by represented parties at least five (5) calendar days prior to the FSC. (Exempt parties may file the same by conventional means on printed paper directly in Department F43.)
Page 7 | Requirements for Specific Trial Documents - Motions in Limine
Motions in limine must be e-filed 10 calendar days before FSC; oppositions e-filed 5 calendar days before FSC.
All motions in limine, if any, must be in writing, numbered, and shall be served on all opposing parties and counsel and electronically filed at least ten (10) calendar days before the FSC. Untimely motions may not be considered. An opposition to any motion in limine must be in writing, numbered, and served and electronically filed by represented parties at least five (5) calendar days prior to the FSC.
Page 7 | REQUIREMENTS FOR SPECIFIC TRIAL DOCUMENTS
Motions in limine must be electronically filed at least 10 calendar days before the FSC; untimely motions may not be considered.
All motions in limine, if any, must be in writing, numbered, and shall be served on all opposing parties and counsel and electronically filed at least ten (10) calendar days before the FSC. Untimely motions may not be considered.
Page 7 | Requirements for Specific Trial Documents - Motions in Limine
For all jury trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC.
For all jury trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC.
Page 7 | Trials
The jointly prepared trial binder must be lodged with the Court at least two calendar days before the Final Status Conference.
For all trials (jury and non-jury), the parties/counsel shall jointly prepare and lodge a trial binder with the Court at least two (2) calendar days before the FSC
Page 9 | 6. TRIAL BINDERS ARE REQUIRED FOR ALL TRIALS
A list of all deposition and discovery-response excerpts to be used at trial (except for impeachment), with any stipulations to admissibility, must be submitted to the judge no later than 10 court days before the FSC.
All parties shall submit to the judge no later than 10 court days before the FSC a list of all excerpts from depositions and other discovery responses to be used at trial except for impeachment, along with any stipulations to their admissibility.
Page 10 | 8. DISCOVERY
Proposed protective order must be served and filed within 5 days of the order.
If a party believes any of this information should be subject to a protective order, that party shall serve and file a proposed protective order within 5 days of this order
Page 14 | Production of Documents
Service and Proof of Service Rules
Parties exempt from e-filing must file and serve a printed copy of the Request for Dismissal or Notice of Settlement at least 2 court days before the FSC.
If a party is exempt from the electronic filing requirements, that party shall file and serve a printed copy of the Request for Dismissal or Notice of Settlement at least two (2) court days before the scheduled FSC.
Page 5 | Final Status Conference Order
Motions in limine must be served on all opposing parties and counsel.
All motions in limine, if any, must be in writing, numbered, and shall be served on all opposing parties and counsel and electronically filed at least ten (10) calendar days before the FSC.
Page 7 | Requirements for Specific Trial Documents - Motions in Limine
All parties must serve written excerpts of depositions and discovery responses to be used at trial (except solely for impeachment) on the opposing party no later than 10 court days before the FSC, marking each excerpt as an exhibit.
All parties must serve on the opposing attorney/in pro per party in writing and no later than 10 court days before the FSC all excerpts from depositions, responses to interrogatories, responses to requests for admissions, or other discovery responses to be used for any purpose at trial other than solely for impeachment and mark each excerpt as an exhibit.
Page 10 | 8. DISCOVERY
Parties intending to use discovery at trial must exchange written particulars (e.g., deponent name, page and line numbers) no later than 10 court days before the FSC or risk a Court order prohibiting use of the discovery.
If the parties intend to use any discovery during trial, the parties must exchange in writing no later than 10 court days prior to the FSC the particulars of any such discovery. For example, if a party proposes to read or show a video excerpt from a deposition, the proffering party must identify in writing by name the deponent, page, and line numbers to opposing counsel no later than 10 court days prior to the FSC. Failure to provide the specific discovery intended to be used at trial in writing and on a timely basis may result in a Court order prohibiting the use of said discovery.
Page 10 | 8. DISCOVERY
Discovery excerpts for trial use must be served on opponents 10 court days before FSC.
All parties must serve on the opposing attorney/in pro per party in writing and no later than 10 court days before the FSC all excerpts from depositions, responses to interrogatories, responses to requests for admissions, or other discovery responses to be used for any purpose at trial other than solely for impeachment and mark each excerpt as an exhibit.
Page 10 | DISCOVERY
Both plaintiff and defendant must serve verifications along with the documents they produce in discovery.
Plaintiff and defendant shall serve verifications with the documents they produce.
Page 15
Produced discovery information 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 the electronic form as a PDF at the option of the producing party.
Page 15
Filing Fees and Waivers
Self-represented parties paper filing ex parte documents must pay the fee at the Clerk's Office by 8:30 a.m. on the hearing day and bring proof of payment to the courtroom.
Self-represented parties must either electronically file by I 0:00 a.m. the day before the ex parte hearing or personally bring the ex parte hearing, declaration of notice, and a proposed order to the Clerk's Office for payment of the fee by 8:30 a.m. on the day of the hearing and proceed immediately to the courtroom with the ex parte application, declaration of notice, a proposed order, and proof of payment.
Page 3 | Ex Parte Applications
Courtesy Copy Requirements
Any other motion whose points and authorities and accompanying supporting materials exceed 35 pages requires lodging courtesy copies with the court, and failure to do so may result in the motion being taken off calendar.
and any other motions of any kind where the points and authorities and any accompanying supporting materials exceed 35 pages in length. Failure to do so may result in the motion being taken off calendar.
Page 1 | Motions
Specific motion types require lodging courtesy copies of points and authorities and supporting documents.
The following motions require lodging with the court courtesy copies of each party's points and authorities, along with any separate statements, exhibits, or other documents filed in support or opposition: Summary judgment motions; anti-SLAPP motions, petitions for writ of attachment; applications for preliminary injunctions; motions to compel further discovery responses, and any other motions of any kind where the points and authorities and any accompanying supporting materials exceed 35 pages in length.
Page 1 | MOTIONS
The following motions require lodging with the court courtesy copies of each party's points and authorities, along with any separate statements, exhibits, or other documents filed in support or opposition: Summary judgment motions; anti-SLAPP motions, petitions for writ of attachment; applications for preliminary injunctions; motions to compel further discovery responses, and any other motions of any kind where the points and authorities and any accompanying supporting materials exceed 35 pages in length. Failure to do so may result in the motion being taken off calendar.
The following motions require lodging with the court courtesy copies of each party's points and authorities, along with any separate statements, exhibits, or other documents filed in support or opposition: Summary judgment motions; anti-SLAPP motions, petitions for writ of attachment; applications for preliminary injunctions; motions to compel further discovery responses, and any other motions of any kind where the points and authorities and any accompanying supporting materials exceed 35 pages in length. Failure to do so may result in the motion being taken off calendar.
Page 1 | Motions
A printed courtesy copy of all verdict forms and jury instructions must be delivered directly to Department F43 at the time of electronic filing.
Additionally, a printed courtesy copy of all verdict forms and jury instructions shall be filed directly in Department F43 at the time of the electronic filing.
Page 3 | Trials
A printed courtesy copy of verdict forms and jury instructions must be filed in Dept F43 when e-filing.
Additionally, a printed courtesy copy of all verdict forms and jury instructions shall be filed directly in Department F43 at the time of the electronic filing.
Page 3 | TRIALS
Motions in limine require a 3-ring binder notebook with table of contents and tabs, submitted 2 calendar days before FSC.
Separate Notebooks Are Required for All Motions in Limine: In addition to filing electronically, the party filing the motion(s) in limine must also submit a 3-ring binder notebook containing all motions, oppositions, and replies. The notebook must have both a Table of Contents and tab dividers to separate each numbered motion and its corresponding opposition and reply. The notebook shall be submitted at least two (2) calendar days prior to the FSC.
Page 7 | REQUIREMENTS FOR SPECIFIC TRIAL DOCUMENTS
Motions in limine filers must also submit a 3-ring binder with a table of contents and tab dividers containing all MIL motions, oppositions, and replies at least 2 calendar days before the FSC; late notebooks may result in the motions not being considered.
Separate Notebooks Are Required for All Motions in Limine: In addition to filing electronically, the party filing the motion(s) in limine must also submit a 3-ring binder notebook containing all motions, oppositions, and replies. The notebook must have both a Table of Contents and tab dividers to separate each numbered motion and its corresponding opposition and reply. The notebook shall be submitted at least two (2) calendar days prior to the FSC. Late filed notebooks may result in the motions not being considered.
Page 7 | Requirements for Specific Trial Documents - Motions in Limine
Identical copies of the exhibit list and all exhibits must be provided in 3-ring binders - one for each party, one for the Court, and one for the witness stand.
Identical copies of the Exhibit List and all exhibits must be provided in 3-ring binders as follows: one for each party, one for the Court, and one for the witness stand.
Page 8 | Requirements for Specific Trial Documents - Joint Exhibit List
All trials require a tabbed 3-ring trial binder with table of contents, lodged 2 calendar days before FSC.
For all trials (jury and non-jury), the parties/counsel shall jointly prepare and lodge a trial binder with the Court at least two (2) calendar days before the FSC, containing the required trial documents, tabbed and organized into 3-ring binders, with a Table of Contents in the front of each binder,
Page 9 | TRIAL BINDERS ARE REQUIRED FOR ALL TRIALS
On the first day of trial and before trial begins, the parties must lodge the originals of all deposition transcripts with the courtroom clerk.
On the first day of trial, the parties must lodge with the courtroom clerk the originals of all deposition transcripts, to be used for any purpose, before trial begins.
Page 10 | 8. DISCOVERY
On the first day of trial, parties must provide sufficient copies of all discovery excerpts for the judge, the opposing parties, and the witness.
On the first day of trial, the parties must provide sufficient copies for the judge, the opposing parties, and the witness of all excerpts from interrogatories, requests for admission, depositions, and video depositions.
Page 10 | 8. DISCOVERY
Four copies of exhibit notebooks must be submitted on first day of trial; exhibits not filed electronically.
On the first day of trial, the parties are ordered to jointly submit four identical copies of the Exhibit Notebooks as follows: one for each party, one for the Court, and one for the witness stand. Trial and evidentiary hearing exhibits shall not be filed electronically.
Page 10 | EXHIBITS
All trial exhibits must be placed in Exhibit Notebooks, and on the first day of trial the parties must jointly submit four identical copies (one per party, one for the Court, one for the witness stand).
All exhibits sought to be admitted by the parties shall be placed in Exhibit Notebooks. On the first day of trial, the parties are ordered to jointly submit four identical copies of the Exhibit Notebooks as follows: one for each party, one for the Court, and one for the witness stand.
Page 10 | 7. EXHIBITS
Exhibit binders must be brought to court on the first day of trial, with binders provided for the Judge, Judicial Assistant, Opposing Counsel, and Reporter.
Exhibits must be brought to Court on the first day of trial. Binders should be provided for the Judge, Judicial Assistant, Opposing Counsel and Reporter.
Page 3 | Exhibits
Self-represented parties bringing paper ex parte oppositions on the hearing day must bring enough copies for the court and all other parties.
If a self represented party elects to bring in his or her opposition to the Court on the day of the hearing, he or she shall bring a sufficient number of copies of the opposition to provide to the court and all other parties.
Page 3 | Ex Parte Applications
Sealing & Redaction Procedures
A party seeking protection for exchanged discovery information must serve and file a proposed protective order within 5 days of the order, meet and confer on language, and the default is the standard SCLAC protective order from its website.
If a party believes any of this information 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 SCLAC on its website.
Page 15
Filing Bundling Requirements
Please note that the trial binder and Motions in Limine binder(s) should be in separate notebooks.
Please note that the trial binder and Motions in Limine binder(s) should be in separate notebooks.
Page 10 | 6. TRIAL BINDERS ARE REQUIRED FOR ALL TRIALS
The Court strongly prefers (encourages but does not require) the parties to file a single joint exhibit notebook containing both parties' exhibits.
The Court strongly prefers the parties to file a joint exhibit notebook, containing both parties' exhibits in one notebook.
Page 10 | 7. EXHIBITS
Pre-Motion Conference Requirements
Demurrers must comply with meet and confer requirements under CCP §430.41 or will be taken off calendar.
Demurrers filed without compliance with the meet and confer requirements will be taken off calendar.
Page 1 | DEMURRERS
All motions to be heard in Dept. F43 must be reserved in advance through the Court Reservation System (CRS) on the court's website.
All motions to be heard in Dept. F43 are to be reserved through the Court Reservation System (CRS).
Page 1 | Motions
Parties must exhaust meet and confer efforts before filing discovery motions, and in Department 43 meet and confer must be in person or by phone (a letter or email does not suffice).
The Court strongly discourages discovery motions and requires the parties to exhaust meet and confer efforts before filing discovery motions. "Meet and confer" in Department 43 means in person or via phone. A letter or email does not suffice.
Page 3 | Discovery Motions
Demurrers require compliance with the CCP 430.41 meet and confer requirements, and non-compliant demurrers will be taken off calendar.
Counsel intending to file a demurrer should review the new requirements, including meet and confer requirements, set forth in Code of Civil Procedure section 430.41, and rethink whether a demurrer is necessary or even advisable. Demurrers filed without compliance with the meet and confer requirements will be taken off calendar.
Page 3 | Demurrers
Discovery motions require exhausting meet and confer efforts in person or via phone before filing.
DISCOVERY MOTIONS: The Court strongly discourages discovery motions and requires the parties to exhaust meet and confer efforts before filing discovery motions. "Meet and confer" in Department 43 means in person or via phone. A letter or email does not suffice.
Page 3 | DISCOVERY MOTIONS
All parties must meet and confer on motions in limine before filing them; failure to do so may result in the Court refusing to hear the motion, and boilerplate or form motions in limine are disfavored.
All parties must meet and confer on all motions in limine prior to filing said motions. Failure by any party or counsel to exchange or discuss any motion in limine may result in the refusal by the Court to hear any such motion in limine, pursuant to applicable court rules. Before a party files a motion in limine, the court expects counsel and self-represented parties to know the legal principles governing the appropriate and inappropriate use of such motions. (Kelley v. New West Federal Savings (1996) 49 Cal.App.4th 659, 670-671; Los Angeles County Court Rule 3.57; and attached Motions in Limine Best Practices.) Boilerplate or form motions in limine are disfavored.
Page 7 | Requirements for Specific Trial Documents - Motions in Limine
Parties objecting to listed exhibits must meet and confer before trial; objections not discussed are deemed waived except upon a showing of good cause.
Any party objecting to any listed exhibit, either as to foundation or admissibility, must first meet and confer prior to trial. Any objections not so discussed in the meet and confer shall be deemed waived except upon a showing of good cause.
Page 8 | Requirements for Specific Trial Documents - Joint Exhibit List
Meet and confer before drafting MILs.
Meet and confer before drafting MILs.
Page 13
Routine MILs (e.g., to exclude speculative evidence, non-expert opinion, insurance/settlement evidence, or unproduced evidence) should generally not be drafted and should not survive meet and confer.
The following MILs usually should never be drafted or at least not survive meet and confer because counsel should not disagree: a) Exclude speculative evidence. b) Exclude expert opinion from non-experts. c) Confine experts to the area of their disclosure. d) Bar evidence of insurance coverage, prior settlements. e) Bar evidence not produced in discovery. f) Seeking bifurcation of punitive damages (it's automatic on request) or to exclude the finances of a party in the liability phase. g) Witnesses to be disclosed in advance. h) Exclude percipient witnesses from trial before they have testified.
Page 13
Adjournment & Extension Requirements
Continuance requests via Stipulation and Order must state complaint filing date, current trial date, and proposed FSC and trial dates.
CONTINUANCES: All hearing dates, including trial dates, may be considered for a continuance by written Stipulation and Order. Said Stipulation and Order shall state the date the Complaint was filed, the current trial date, as well as the proposed Final Status Conference date and proposed trial date.
Page 3 | CONTINUANCES
Absent a stipulation, continuances may be sought by noticed motion or ex parte application.
If there is no stipulation, the parties may seek a continuance by noticed motion or an ex parte application.
Page 3 | Continuances
Continuances of hearing dates, including trial dates, may be sought by written Stipulation and Order.
All hearing dates, including trial dates, may be considered for a continuance by written Stipulation and Order.
Page 3 | Continuances
Chambers Communication Rules
Parties may submit on the tentative ruling by contacting the Judicial Assistant; if both parties agree to submit, the tentative ruling becomes the Court's order and no appearance at the hearing is necessary.
The Court may issue a tentative ruling after 3:00 p.m. the day before the hearing. The attorneys/self-represented litigants may submit on the tentative ruling by contacting the Judicial Assistant, and, if both parties agree to submit, then the tentative will become the Court's order, and no appearance at the hearing is necessary.
Page 1 | Motions
Parties are requested to immediately notify the Clerk by phone at (818) 407-2243 upon settlement or resolution of the action.
The parties are also requested to notify the Clerk of this Court immediately by phone [(818) 407-2243] upon settlement or resolution of the action.
Page 5 | Final Status Conference Order