Judge Michele E. Flurer
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Courtesy copies
- 1 copy • During Courtroom Hours
Post Trial Motion
- 1 copy • Email
Proposed Verdict Form
- 1 copy • Email • Before Trial Commences
Verdict Form
- 1 copy • Email • Before Trial Commences
Communication
Chambers
Phone
Clerk
Document Format Requirements5 rules
Each party intending to present any evidence by way of deposition testimony (except impeachment) shall do the following unless the parties have no objection to the admission of testimony: 1. Highlight the testimony the party intends to offer in one color. 2. The opposing party shall countermark (different color) any testimony it plans to offer. 3. Highlight in a separate color or draw a box around the objected testimony.
Jury Instruction --Display Copy: The Court requests one electronic copy of the instructions to the Department's email box (LBCDeptS29@lacourt.org) for display to the jury in the following format: title and text in Word, landscape format, Arial font, 14pt font, no headers or footers - except title/CACI Numbers.
- File type
- Word
- Font
- Arial
- Font size
- 14 points
- Jury instructions
Formatting
- •Landscape format
Exception
Title/CACI Numbers
for display to the jury in the following format: title and text in Word, landscape format, Arial font, 14pt font, no headers or footers - except title/CACI Numbers.
- File type
- Word
- Font
- Arial
- Font size
- 14 points
- Jury instructions
Formatting
- •Title and text in Word
- •Landscape format
Exception
Title/CACI Numbers
Counsel must remove all brackets, fill in allblanks in advance. Examples are names of the parties, appropriate gender and number (singular or plural). Each instr�ction shall conform to the requirements of Rule 2.1055, California Rules of Court.
- Jury instructions
Formatting
- •Remove all brackets
If the parties cannot agree on a joint form, each party must file their version and email Department 529 the draft in Word.
- File type
- Word
- Verdict form
Document Filing Requirements11 rules
Counsel must provide a complete hard copy set of jury instructions to the court, with all brackets removed and blanks filled in, conforming to Rule 2.1055 California Rules of Court.
Court's wording
As required by General Order 3.F and by Los Angeles County Court Rules 3.170 - 3.172, it is the responsibility of counsel to provide the Court with a complete set (hard copy) of jury instructions. Counsel must remove all brackets, fill in all blanks in advance. Examples are names of the parties, appropriate gender and number (singular or plural). Each instruction shall conform to the requirements of Rule 2.1055, California Rules of Court. Hard copies must be filed with the clerk.
Any case-specific special instructions not covered by CACI instructions shall be separately numbered and be a clear accurate statement of the law with complete citations to authorities in support.
Hard copies must be filed with the clerk.
File a numbered index of the portions of the deposition offered, stating the pages and lines offered, the objections of the party and summary of the basis for the objections. Please include two boxes or columns for the Court's ruling: ■ Sustained ■ Overruled and room to indicate further comments.
Other than insertions for pronouns, names, and CACI parentheticals, any other modifications of a CACI instruction must be submitted as a Special Instruction or highlighting showing the modification.
As required by General Order 3.F and by Los Angeles County Court Rules 3.170 - 3.172, it is the responsibility of counsel to provide the Court with a complete set (hard copy) of jury instructions.
Proposed joint verdict forms must be submitted before trial, with a courtesy copy via email; if no agreement, each party files their version in Word to Department 529.
Court's wording
Submit a proposed joint verdict form before trial commences sending a courtesy copy to the Court's email box. Follow the language and pattern of CACI instructions as much as possible. If the parties cannot agree on a joint form, each party must file their version and email Department 529 the draft in Word.
Verdict Form: Submit a proposed joint verdict form before trial commences sending a courtesy copy to the Court's email box. Follow the language and pattern of CACI instructions as much as possible. If the parties cannot agree on a joint form, each party must file their version and email Department 529 the draft in Word.
In a simple issue case, submit a general verdict form. If a special verdict form is requested, submit a single proposed special verdict form which includes any special questions of fact on which a party is requesting a finding. The special questions, of course, must be submitted in logical position in relation to other questions on the verdict form. This will require a conference between counsel which may take substantial time. PLEASE HAVE A PROPOSED DRAFT COMPLETED BEFORE YOU APPEAR IN DEPARTMENT S29.
UNLAWFUL DETAINER JURY TRIALS: In a simple issue case, submit a general verdict form. If a special verdict form is requested, submit a single proposed special verdict form which includes any special questions of fact on which a party is requesting a finding. ... PLEASE HAVE A PROPOSED DRAFT COMPLETED BEFORE YOU APPEAR IN DEPARTMENT S29.
If your modified or "special" instruction is not being requested in lieu of a CACI Instruction, then insert the instruction in the submitted packet after the CACI instruction -- where you believe it would logically be positioned when read to the jury.
Filing & Service rules
Electronic Filing Rules
Post-trial motions must comply with the General Order Re: Mandatory Electronic Filing for Civil.
Post-trial motions, please follow the General Order Re: Mandatory Electronic Filing for Civil.
Page 1
Post-trial motions, please follow the General Order Re: Mandatory Electronic Filing for Civil.
Post-trial motions, please follow the General Order Re: Mandatory Electronic Filing for Civil.
Page 1 | PROCEDURES FOR SETTING MATTERS
Courtesy (in-person/paper) filings may be made at the courthouse during open hours (8:30 a.m.-12:00 p.m. and 1:30 p.m.-4:30 p.m.).
During these hours, the phones will be answered and courtesy filings may be made.
Page 1 | COURTROOM HOURS
Filing Timing and Cure Windows
Ex parte papers should be filed by 3:00 p.m. the day before the scheduled hearing.
Ex parte papers should be filed by 3:00 p.m. the day before the ex parte is to be heard. This enables the Court to read the papers prior to the arrival of counsel.
Page 1
Ex parte papers should be filed by 3:00 p.m. the day before the ex parte is to be heard. This enables the Court to read the papers prior to the arrival of counsel.
Ex parte papers should be filed by 3:00 p.m. the day before the ex parte is to be heard. This enables the Court to read the papers prior to the arrival of counsel.
Page 1 | PROCEDURES FOR SETTING MATTERS
Deposition transcripts must be lodged with the clerk before the witness takes the stand.
Lodge deposition transcripts with the clerk before the witness takes the stand.
Page 4 | Jury Trial Procedures (Voir Dire, Challenges, Exhibits, Jury Instructions, Depositions)
Deposition transcripts must be lodged with the clerk before the witness testifies.
Lodge deposition transcripts with the clerk before the witness takes the stand.
Page 4
Counsel shall prepare a judgment on the jury's verdict within 10 days of the date of the verdict unless otherwise directed. If there is a verdict that includes any money damages for any party, then that party shall prepare the judgment and lodge it with the court (with a copy to opposing counsel). If the jury awards no damages to any plaintiff, then defendant is to prepare the judgment and lodge it with the court (with a copy to opposing counsel). Objections to be filed within 10 days unless otherwise ordered by the Court.
Counsel shall prepare a judgment on the jury's verdict within 10 days of the date of the verdict unless otherwise directed. If there is a verdict that includes any money damages for any party, then that party shall prepare the judgment and lodge it with the court (with a copy to opposing counsel). If the jury awards no damages to any plaintiff, then defendant is to prepare the judgment and lodge it with the court (with a copy to opposing counsel). Objections to be filed within 10 days unless otherwise ordered by the Court.
Page 5
Objections to the proposed judgment must be filed within 10 days unless otherwise ordered by the Court.
Objections to be filed within 10 days unless otherwise ordered by the Court.
Page 5 | Preparing the judgment
The party awarded money damages (or the defendant if no damages are awarded) must prepare the judgment within 10 days of the verdict and lodge it with the court with a copy to opposing counsel, unless otherwise directed.
Counsel shall prepare a judgment on the jury's verdict within 10 days of the date of the verdict unless otherwise directed. If there is a verdict that includes any money damages for any party, then that party shall prepare the judgment and lodge it with the court (with a copy to opposing counsel). If the jury awards no damages to any plaintiff, then defendant is to prepare the judgment and lodge it with the court (with a copy to opposing counsel).
Page 5 | Preparing the judgment
Service and Proof of Service Rules
Anything sent to the Department's email box must copy all counsel or self-represented litigants.
[Note: ALLcounsel or self-represented litigantsmust be copied on anything sent to the Department's email box]
Page 1 | PROCEDURES FOR SETTING MATTERS
Courtesy Copy Requirements
For post-trial motions, the Court requests an additional courtesy copy emailed to LBCDeptS29@LACourt.org, with all counsel or self-represented litigants copied.
The Court requests an additional courtesy copy via email sent to: LBCDeptS29@LACourt.org [Note: ALLcounsel or self- represented litigantsmust be copied on anything sent to the Department's email box]
Page 1 | PROCEDURES FOR SETTING MATTERS
The Court requests an additional courtesy copy via email sent to: LBCDeptS29@LACourt.org [Note: ALL counsel or self-represented litigants must be copied on anything sent to the Department's email box]
The Court requests an additional courtesy copy via email sent to: LBCDeptS29@LACourt.org [Note: ALL counsel or self-represented litigants must be copied on anything sent to the Department's email box]
Page 1
Proposed verdict forms require a courtesy copy sent via email to the Court's email box before trial commences.
Submit a proposed joint verdict form before trial commences sending a courtesy copy to the Court's email box.
Page 5
A courtesy copy of the proposed joint verdict form must be sent to the Court's email box before trial commences.
Submit a proposed joint verdict form before trial commences sending a courtesy copy to the Court's email box.
Page 5 | Verdict Form
Courtesy filings are accepted in person during courtroom hours (8:30 a.m. - 12:00 p.m. and 1:30 p.m. - 4:30 p.m. daily).
The Court is open 8:30 a.m. - 12:00 p.m. and 1:30p.m. - 4:30 p.m. each day. During these hours, the phones will be answered and courtesy filings may be made.
Page 1
Sealing & Redaction Procedures
Exhibits containing sensitive personal information (e.g., Social Security number, home address, phone numbers, email) may not be displayed to the jury or shown to a witness unless the Court rules the information stays on the exhibit; before redacting, the party must show the document and proposed redaction to opposing counsel, and any objection is taken to the Court.
No exhibit that contains sensitive personal information is to be displayed to the jury or shown to a witness unless the Court rules that the information shall remain on the exhibit. Examples of sensitive personal information include but are not limited to: social security number, home address, phone number(s) and email address. Before redacting personal identifying information on a document, a party who wishes to use the document shall show the document to opposing counsel and the portion to be redacted. If there is any objection to redacting any information on the document, counsel is to take up the issue with the court.
Page 3 | Jury Trial Procedures (Voir Dire, Challenges, Exhibits, Jury Instructions, Depositions)
Exhibits with Personal Information: No exhibit that contains sensitive personal information is to be displayed to the jury or shown to a witness unless the Court rules that the information shall remain on the exhibit. Examples of sensitive personal information include but are not limited to: social security number, home address, phone number(s) and email address. Before redacting personal identifying information on a document, a party who wishes to use the document shall show the document to opposing counsel and the portion to be redacted. If there is any objection to redacting any information on the document, counsel is to take up the issue with the court.
Exhibits with Personal Information: No exhibit that contains sensitive personal information is to be displayed to the jury or shown to a witness unless the Court rules that the information shall remain on the exhibit. Examples of sensitive personal information include but are not limited to: social security number, home address, phone number(s) and email address. Before redacting personal identifying information on a document, a party who wishes to use the document shall show the document to opposing counsel and the portion to be redacted. If there is any objection to redacting any information on the document, counsel is to take up the issue with the court.
Page 3
Filing Bundling Requirements
Duplicative motions, objections and jury instructions: Multiple parties should not make the same motions and objections. Coordinate with each other. For example, if two parties will be making the same motion in limine, motion for a directed verdict, or written objection to evidence, submit one document only as a joint document.
Duplicative motions, objections and jury instructions: Multiple parties should not make the same motions and objections. Coordinate with each other. For example, if two parties will be making the same motion in limine, motion for a directed verdict, or written objection to evidence, submit one document only as a joint document.
Page 6
Multiple parties should not make the same motions and objections. Coordinate with each other. For example, if two parties will be making the same motion in limine, motion for a directed verdict, or written objection to evidence, submit one document only as a joint document.
Multiple parties should not make the same motions and objections. Coordinate with each other. For example, if two parties will be making the same motion in limine, motion for a directed verdict, or written objection to evidence, submit one document only as a joint document.
Page 6 | Duplicative motions, objections and jury instructions
Pre-Motion Conference Requirements
do not file a written motion during trial unless you have first discussed it with opposing counsel. If Counsel is unable to resolve it, then advise court staff that you need a conference with the Court
do not file a written motion during trial unless you have first discussed it with opposing counsel. If Counsel is unable to resolve it, then advise court staff that you need a conference with the Court
Page 6 | Jury Trial Procedures
Before filing a post-trial motion, parties are asked to meet and confer, and if unresolved, the Court may hold a conference call with all counsel arranged through the courtroom clerk.
The parties are asked to meet and confer prior to filing a post- trial motion. If the parties are unable to resolve their dispute, The Court may be available for a conference call with ALL counsel to help informally resolve a dispute before a motion is filed. If you would like to set-up a conference call, please contact the Courtroom clerk at: 562-256-2237.
Page 1 | PROCEDURES FOR SETTING MATTERS
Written motions during trial require discussion with opposing counsel first; unresolved matters need a court conference.
During trial, if counsel needs to make motions instead oral motions, do not file a written motion during trial unless you have first discussed it with opposing counsel. If Counsel is unable to resolve it, then advise court staff that you need a conference with the Court.
Page 6
Chambers Communication Rules
Please reserve a motion date by calling the Courtroom clerk at 562-256-2237.
Please reserve a motion date by calling the Courtroom clerk at 562-256-2237.
Page 1 | PROCEDURES FOR SETTING MATTERS
If a matter is to be taken off calendar, counsel should call the clerk at 562-256-2237 as soon as possible.
If a matter is to be is taken off calendar, counsel is urged to call the Clerk as soon as possible. Please call 562-256-2237.
Page 1 | Tentative Rulings
[Please provide a word document for the Court to.mark its rulings and send a copy to all counsel and the Court via the department's email address]
[Please provide a word document for the Court to.mark its rulings and send a copy to all counsel and the Court via the department's email address]
Page 4 | Jury Trial Procedures (Voir Dire, Challenges, Exhibits, Jury Instructions, Depositions)
The Court requests one electronic copy of the instructions to the Department's email box (LBCDeptS29@lacourt.org) for display to the jury
The Court requests one electronic copy of the instructions to the Department's email box (LBCDeptS29@lacourt.org) for display to the jury
Page 4 | Jury Trial Procedures (Voir Dire, Challenges, Exhibits, Jury Instructions, Depositions)
The Department's email address for courtesy copies is LBCDeptS29@LACourt.org.
The Court requests an additional courtesy copy via email sent to: LBCDeptS29@LACourt.org
Page 1 | PROCEDURES FOR SETTING MATTERS
The court is open 8:30 a.m.-12:00 p.m. and 1:30 p.m.-4:30 p.m. daily; phones are answered during those hours, ex partes are heard at 8:30 a.m., and other motions and status conferences are heard throughout the day.
The Court is open 8:30 a.m. - 12:00 p.m. and 1:30p.m. - 4:30 p.m. each day. During these hours, the phones will be answered and courtesy filings may be made. Ex partes are heard at 8:30 a.m. All other motions and status conferences are heard throughout the day.
Page 1 | COURTROOM HOURS
The Courtroom Clerk can be reached at 562-256-2237 during courtroom hours for scheduling, conference calls, and calendar changes.
Courtroom Clerk: 562-256-2237. During these hours, the phones will be answered and courtesy filings may be made. Please reserve a motion date by calling the Courtroom clerk at 562-256-2237. If you would like to set-up a conference call, please contact the Courtroom clerk at: 562-256-2237. If a matter is to be is taken off calendar, counsel is urged to call the Clerk as soon as possible. Please call 562-256-2237.
Page 1