Judge Michael Shultz
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Trial Notebook
Communication
Chambers
Chambers
Phone
Chambers
Phone
Clerk
Phone
Page & Word Limits2 rules
At least five court days before the IDC, the moving party must file and serve a memorandum no longer than three pages setting forth the outstanding issues.
- Memorandum
- Up to 3 pages
The responding party may file and serve a responsive memorandum of no more than three pages at least two court days prior to the IDC.
- Responsive memorandum
- Up to 3 pages
- Memorandum
Document Format Requirements2 rules
Leave at least four inches of blank space of the top of every page of any proposed special jury instructions, or any addenda to form instructions.
Each exhibit must be separately numbered, with the numbers corresponding to the number of the exhibit on the joint exhibit list. If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3 etc.
Document Filing Requirements8 rules
Proposed jury instructions must include a joint set plus each side's objected-to instructions in full text, with blanks completed, compliance with SCLAC 3.170-3.171, and CACI used for form instructions.
Court's wording
The parties are to submit a joint set of instructions, plus a set of instructions from each side to which there are objections. The parties shall provide the full text of all requested instructions (not just a list). Before submitting the instructions, counsel must fill in the blanks, make any appropriate modifications, and comply with SCLAC 3.170 - 3.171. Use CACI for form instructions.
The parties must submit a joint witness list with per-witness time estimates and a total, and absent good cause total testimony hours may not exceed the trial estimate given at the case management conference.
Court's wording
The parties must submit a joint list of all witnesses each party actually intends to call. Next to each witness, indicate the total time estimated for that witness's testimony (including direct, cross, redirect). Make realistic time estimates. At the end of the list, total the time estimated for testimony. Absent good cause, the total number of hours listed for testimony shall not exceed the trial estimate given at the case management conference, including the allocation of one day of the trial estimate for jury selection and sufficient time for opening statements and closing arguments.
Compliance with SCLAC 3.57, including the declaration and meet and confer requirements, is mandatory.
JOINT STATEMENT OF THE CASE (which will be read by the Court to the prospective jurors).
As to experts counsel intends to call at trial, no later than the FSC, Counsel shall present to the Court and opposing counsel a copy of the Code of Civil Procedure section 2034.260 declaration that states the substance of the proffered opinion.
All motions in limine 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)
The first paragraph shall be formatted as follows: (1) a neutral statement of the dispute; and (2) one to three sentences describing (not arguing) each parties' position.
TRIAL BRIEFS for each party are highly recommended in all cases, whether bench or jury trial.
Filing & Service rules
Electronic Filing Rules
Plaintiff must eFile the Notice of Settlement using Judicial Council Form CM-200, even if the case settled at a Judicial MSC.
Notice of Settlement must be eFiled by plaintiff using Judicial Council Form CM-200, even if the case settled at a Judicial MSC.
Page 4 | NOTICE OF SETTLEMENT/ REQUEST FOR DISMISSAL
All ex parte applications and supporting documents must be electronically 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 4 | EX PARTE APPLICATIONS
The parties must provide both a paper "trial notebook" for the Court and must also submit FSC/trial documents electronically.
The parties must provide both a paper "trial notebook" for the Court and must also submit FSC/trial documents electronically.
Page 5 | FINAL STATUS CONFERENCE
The parties shall work together to provide trial exhibits electronically, where feasible.
The parties shall work together to provide exhibits electronically, if feasible.
Page 6 | TRIAL PROCEDURES
Self-represented litigants are exempt from the mandatory electronic filing requirements for ex parte applications under CRC 2.253(b)(2).
Pursuant to California Rules of Court, rule 2.253(b)(2), self-represented litigants are exempt from these mandatory Electronic Filing requirements.
Page 4 | EX PARTE APPLICATIONS
Filing Timing and Cure Windows
The moving party must file and serve the IDC memorandum at least five court days before the IDC.
At least five court days before the IDC, the moving party must file and serve a memorandum no longer than three pages setting forth the outstanding issues.
Page 3 | DISCOVERY MOTIONS
The responding party may file and serve a responsive memorandum of no more than three pages at least two court days prior to the IDC.
The responding party may file and serve a responsive memorandum of no more than three pages at least two court days prior to the IDC.
Page 3 | DISCOVERY MOTIONS
Written opposition to an ex parte application must be electronically filed by 8:30 a.m. the day of the hearing.
Any written opposition shall be electronically filed by 8:30 a.m. the day of the hearing.
Page 4 | EX PARTE APPLICATIONS
Ex parte filings are due by a 10:00 a.m. cutoff on 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 4 | 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 4 | CASE MANAGEMENT CONFERENCES
Motions in limine and bifurcation motions must be filed and set for hearing on the final status conference date.
MOTIONS IN LIM/NE AND BIFURCATION MOTIONS must have been filed and served with proper statutory notice and set for hearing on the FSC date.
Page 6 | TRIAL PROCEDURES
Motions in limine must be submitted with timely statutory notice so they can be heard at the final status conference.
must be submitted with timely statutory notice so the motion in limine can be heard at the final status conference.
Page 7 | MOTIONS IN LIMINE
Lodged trial binders must be picked up within two weeks of filing the Notice of Settlement or they will be discarded.
If trial binders were lodged prior to settlement, they must be picked up within two weeks of filing the Notice of Settlement or they will be discarded.
Page 4 | NOTICE OF SETTLEMENT/ REQUEST FOR DISMISSAL
Service and Proof of Service Rules
All parties who use e-filing must accept electronic service, except where personal service is required by law or where any party is self-represented.
Pursuant to Code of Civil Procedure §1010.6, local Rule 3.4, and General Order 2019-GEN-014-00 issued May 3, 2019, the Court orders all parties who use e-filing to accept electronic service, except in those circumstances when personal service is required by law or where any of the parties are self-represented.
Page 2 | LAW&MOTION
Motions in limine and bifurcation motions must be served with proper statutory notice.
MOTIONS IN LIM/NE AND BIFURCATION MOTIONS must have been filed and served with proper statutory notice and set for hearing on the FSC date.
Page 6 | TRIAL PROCEDURES
Filing Fees and Waivers
Court-employer certified shorthand reporters (court reporters) are not usually provided absent a fee waiver. If you want a court reporter, you must provide one. A party who has received a fee waiver pursuant to CRC 3.55(7) may request an official court reporter by filing form FW-020 www.courts.ca.gov/documents/fw020.pdf before the hearing or trial.
Court-employer certified shorthand reporters (court reporters) are not usually provided absent a fee waiver. If you want a court reporter, you must provide one. A party who has received a fee waiver pursuant to CRC 3.55(7) may request an official court reporter by filing form FW-020 www.courts.ca.gov/documents/fw020.pdf before the hearing or trial.
Page 2 | GENERAL INFORMATION
Courtesy Copy Requirements
The parties must provide a paper trial notebook to the Court in connection with the final status conference/trial.
The parties must provide both a paper "trial notebook" for the Court and must also submit FSC/trial documents electronically.
Page 5 | FINAL STATUS CONFERENCE
Pre-Motion Conference Requirements
Law and motion matters are heard Tuesdays and Thursdays at 9:00 a.m., and parties must reserve a hearing date in advance for all law and motion hearings via the Court Reservation System (CRS).
The Court hears law and motion matters on Tuesdays and Thursdays at 9:00 a.m. 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 to resolve or narrow discovery disputes before seeking an Informal Discovery Conference (LACIV094), which should eliminate the need for a discovery motion.
Trial counsel must meet and confer by telephone or videoconference (or in person, when consistent with public health recommendations) to resolve or narrow the discovery dispute. If the dispute remains unresolved, counsel can request an Informal Discovery Conference by filing an IDC request [LACIV094].
Page 3 | DISCOVERY MOTIONS
Parties must meet and confer in advance and then file proposed general or special verdict forms.
to meet and confer in advance, and then file proposed general or special verdict forms.
Page 7
Parties must meet and confer before filing any motion in limine, as required by Los Angeles County Superior Court Rule 3.57.
Los Angeles County Superior Court Rule 3.57 requires the parties to meet and confer before filing any motion in limine.
Page 7 | MOTIONS IN LIMINE
Adjournment & Extension Requirements
Motions may be continued or withdrawn only through the Court Reservation System (CRS), and parties must also call the courtroom so it 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
Chambers Communication Rules
Counsel submitting on the tentative ruling must email chambers at cwarren1@lacourt.ca.gov by 8:00 a.m. the day of the hearing, including the case number, identifying the submitting party, and cc'ing opposing counsel.
Counsel who intends to submit on the tentative may send an email to the court at cwarren1@lacourt.ca.gov by 8:00 a.m. the day of the hearing. If counsel submits on the tentative, counsel's email must include the case number and identify the party submitting on the tentative with a copy (cc) to opposing counsel.
Page 3 | LAW&MOTION
The Judicial Assistant for Department 414, Chante Warren, can be contacted by email at Cwarren1@lacourt.ca.gov.
Judicial Assistant: Chante Warren Cwarren1@lacourt.ca.gov
Page 1 | GENERAL INFORMATION
The Courtroom Attendant for Department 414, Annfrancis Solis, can be contacted by email at Asolis1@lacourt.ca.gov.
Courtroom Attendant: Annfrancis Solis Asolis1@lacourt.ca.gov
Page 1 | GENERAL INFORMATION
Department 414 can be reached by telephone at (213) 633-0160 during public hours, Monday to Friday 8:30-12:00 and 1:30-4:30.
Telephone Number: (213) 633-0160 Public Hours: Monday to Friday 8:30-12:00 & 1:30-4:30
Page 1 | GENERAL INFORMATION
Self-represented litigants can access Self-Help services by calling (213) 830-0845 or visiting the Superior Court of Los Angeles County Self-Help website.
For Self-Help services, call the Self-Help Center at (213) 830-0845 or go to the Superior Court of Los Angeles County website on Self-Help at www.selfhelp.lacourt.ca.gov
Page 2 | Self-represented Litigants
Self-represented litigants seeking Clerk's Office assistance should call Court Support Services at (213) 830-0800.
For Clerk's Office assistance, please call the Court Support Services number at (213) 830-0800.
Page 2 | Self-represented Litigants