Judge Ralph C. Hofer
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Ex Parte Application
- By Noon the Day Before Hearing
- Day Before Hearing
Motion
- At Least Two Weeks Before Hearing
- Two Weeks Prior to Hearing Date
Motion, Pleading
- Upon Filing
Opposition, Reply
- On Day of Electronic Filing
Communication
Chambers
Phone
Chambers
Phone
Chambers
Document Format Requirements8 rules
Each page of each exhibit needs to be labelled to reflect the exhibit number and the individual page number as reflected by the total pages in the exhibit in the format below. Exhibit 102-Pg. 001 of 017
The proposed jury instructions shall be prepared on the Superior Court of Los Angeles County form LASC LACIV 129 or in a Word document that is in the same format.
Parties must attach copies of designated transcript pages to the Joint Chart with numbered tabs, keeping each transcript's designation pages in page order behind a single tab.
Formatting
- •Copy of designated/counter-designated transcript pages must be attached to the Joint Chart
- •Numbered tabs must separate each deposition or trial transcript
Court's wording
The parties shall attach a copy of the pages of the transcripts of the deposition or former testimony they are designating or counter-designating to the Joint Chart of Page and Line Designations for Deposition and Former Testimony, with numbered tabs separating each deposition or trial transcript. For each transcript, all pages containing the designations and counter-designations shall be included in a single document in page order behind a single tab.
Each designation and counter-designation shall be highlighted, with each party using a different color highlighter.
The parties’ counsel and any self-represented parties shall work together to jointly prepare four sets of tabbed, internally paginated by document, and properly marked exhibits, organized numerically in three-ring binders (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) (“Exhibit Binders”).
- Binding
- Tabbed three-ring binder
- Exhibits
Formatting
- •Joint preparation by counsel and any self-represented parties
- •Internally paginated by document
- •Properly marked
- •Organized numerically
The Motions in Limine Binder shall include one-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders, tabbed in numerical order with the opposition papers and reply papers for each motion placed directly behind the moving papers with a colored sheet of paper separating the moving, opposition, and reply papers.
- Binding
- Tabbed three-ring binder
- Motion in limine
- Opposition
- Reply
Formatting
- •One-sided conformed copies required
- •Tabbed in numerical order
a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following
- Binding
- Tabbed three-ring binder
- Trial binder
Formatting
- •One-sided conformed copies
- •Table of contents required
Plaintiff must file the completed addendum in the format attached here to.
Document Filing Requirements34 rules
The joint ADR status report must describe all settlement efforts but must not reveal the numbers or amounts of settlement offers exchanged.
Court's wording
Attorneys must file a joint status report ten (10) court days before the OSC Re ADR Compliance hearing detailing all efforts the attorneys undertook to settle the case, but without revealing any settlement offers exchanged between the parties.
Each party shall file a trial brief succinctly identifying: (1) the claims and defenses that remain in dispute for trial; (2) the major legal issues (with supporting points and authorities); (3) the relief and calculation of damages sought; (4) any other information that may assist the court at trial; and (5) an itemized statement of damages.
- Document
- Trial brief
Must include
- •Legal argument
The parties must jointly prepare and file a witness list (excluding impeachment and rebuttal witnesses) in a specified column format with examination time estimates and a grand total, and any witness not listed may be excluded from testifying at trial except for actual impeachment or rebuttal.
Court's wording
The parties’ counsel and any self-represented parties shall work together to prepare and file a joint list of all witnesses whom any party intends to call at trial, excluding impeachment and rebuttal witnesses. (Los Angeles County Court Rule (“Local Rule”) 3.25, subd. (g)(5).) The joint witness list shall be organized with columns (in the format set forth below) which state (1) the name of each witness (in alphabetical order), if the witness is being called to testify as an expert, and any special requirements or accommodations needed for the witness (e.g., interpreter), (2) the party calling the witness, (3) whether the witness is actually expected to testify, (4) a brief description of the witness’s expected testimony, (5) an estimate of the length of direct examination (in hours), (6) an estimate of the length of cross- examination (in hours), and (7) the total estimated length of examination (in hours). At the end of the joint witness list, the parties and any self-represented parties shall add up the estimated times for all witnesses’ testimony and state the grand total in the last column. Any witness who is not included on the joint witness list is subject to being excluded from testifying at trial other than for purposes of giving actual impeachment or rebuttal testimony.
Counsel and self-represented parties must jointly prepare and file a joint exhibit list stating eight specified data points for each trial exhibit.
Court's wording
The parties’ counsel and any self-represented parties shall work together to prepare and file a joint exhibit list organized with columns (in the format set forth below) which state, as to each exhibit any party intends to offer at trial: (1) the exhibit number, (2) a brief description of the exhibit with a date or dates of the documents and the number of pages of the exhibit, (3) which party is offering the exhibit, (4) whether the parties have stipulated to authentication of the exhibit, (5) whether the parties have stipulated to admissibility of the exhibit, (6) any evidentiary objections to admission of the exhibit, (7) the date the exhibit was marked for identification, and (8) the date the exhibit was admitted into evidence.
Counsel must bring an exhibit binder to the Final Status Conference for the court’s review.
In jury trials, the parties must jointly prepare a complete set of full text proposed jury instructions with CACI instructions edited to insert party names and eliminate blanks and irrelevant material.
Court's wording
For jury trials, the parties’ counsel and any self-represented parties shall work together to prepare a complete set of full text proposed jury instructions, editing all proposed Judicial Council of California Civil Jury Instructions (“CACI”) instructions, inserting party names, and eliminating blanks and other irrelevant or inapplicable material.
In jury trials, the parties must jointly prepare and file a brief written statement of the case for the court to read to the jury.
Court's wording
For jury trials, the parties’ counsel and any self-represented parties shall work together to prepare and file a brief, joint written statement of the case for the court to read to the jury. (Local Rule 3.25, subd. (g)(4).)
In jury trials, the parties must jointly prepare and file a Joint List of Proposed Jury Instructions stating six specified data points for each instruction.
Court's wording
For jury trials, the parties’ counsel and any self-represented parties shall work together to prepare and file a joint list of proposed jury instructions (in the format set forth below) which states, as to each proposed jury instruction: (1) the jury instruction number (listed in numerical order), (2) the title of the jury instruction, (3) the party requesting the jury instruction, (4) whether the jury instruction is agreed upon or contested, (5) a concise statement of any objection, and (6) whether the jury instruction was given by the court (“Joint List of Proposed Jury Instructions”).
Parties intending to use deposition or former trial testimony must meet and confer and jointly prepare and file a Joint Chart of Page and Line Designations containing six specified columns.
Court's wording
If any parties intend to use deposition testimony or former trial testimony in lieu of, or in addition to a witness’s live testimony, the parties’ counsel and any self-represented parties shall meet and confer to discuss, and work together to prepare and file, a joint chart in the format set forth below (“Joint Chart of Page and Line Designations for Deposition and Former Testimony”). In the joint chart, each designating party’s designations of deposition or former testimony shall include columns which state: (1) the designation number and name of the witness, (2) the date and type of testimony (e.g., deposition or trial testimony), (3) the page and line designations of the deposition or former testimony requested to be used, (4) any objections, (5) whether the other party has counter-designated any additional deposition or former testimony of the witness that relates to the designation, and, if so, the designation number of the counter-designation, and (6) the court’s ruling.
In jury trials, parties must file a joint proposed general or special verdict form acceptable to all parties, or separate proposed verdict forms if they cannot agree.
Court's wording
For jury trials, the parties’ counsel and any self-represented parties shall work together to prepare and file a joint proposed general verdict form or a joint proposed special verdict form acceptable to all parties. (Local Rule 3.25, subd. (g)(8).) If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.
The parties’ counsel and any self-represented parties shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and file declarations that comply with the
The parties’ counsel and any self-represented parties shall bring one set of the Exhibit Binders to the Final Status Conference for the court to review.
28. Plaintiff shall state why the vehicle qualifies for a "buyback." State what was (or still is) wrong with the vehicle,
Defendant shall plainly state why the vehicle at issue does not qualify for a “buy back,” or state that the vehicle does qualify for a buyback, and if so, identify any remaining issues regarding any “buy back.”
I am completely familiar with this case and will be fully prepared to discuss the status discovery and alternative dispute resolution, as well as other issues raised by this addendum, and will possess the authority to enter into stipulations on these issues at the time of the initial case management conference, including the written authority of the party where required.
Defendant shall state either a. Why the vehicle does not qualify for a “buyback,” or b. Simply state that it does qualify and state the remaining issues, e.g., buyback price, credits, attorney’s fees, costs, etc.
Plaintiff shall plainly state the facts as to why the vehicle qualifies for a “buyback.” Don’t use conclusionary terms as “engine” problems. BE SPECIFIC, as noted above.
Production of Documents: Within 60 days of service of this Order both plaintiff and defendant shall provide copies of the following documents, which are in their respective possession, custody and/or control, to the opposing side(s):
Defendant's list of substantially similar customer complaints must include the VIN, repair visit date, reporting location, and complaint text, and must exclude customers' personal identifying information.
Court's wording
The list provided by defendant may be in the chart or spreadsheet format, and shall include the VIN, date of repair visit, dealership or other reporting location, and 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.
Do not attach the Addendum to the Case Management Statement. File the Addendum as a separate pleading.
I am completely familiar with this case and will be fully prepared to discuss the status discovery and alternative dispute resolution, as well as other issues raised by this addendum, and will possess the authority to enter into stipulations on these issues at the time of the initial case management conference, including the written authority of the party where required.
If there is an appropriate CACI jury instruction on a point of law, the court expects the parties to request the CACI instruction instead of a specially prepared jury instruction.
The court urges the parties to consider a general verdict form. When a special verdict form is requested, if there is an appropriate CACI special verdict form for a cause of action, affirmative defense, or other finding, the court expects the parties to use the CACI special verdict form.
Parties filing more than one motion in limine shall number them consecutively.
Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.
- Document
- Motion in limine opposition reply
- Placement
- Caption
For the motions in limine for each party, the attorney must prepare a score sheet in the format below.
The parties’ counsel and any self- represented parties shall also place the court’s yellow evidence tags (with only the case number and exhibit number filled in) on each exhibit in the Judicial Assistant’s copy of the Exhibit Binder.
all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the Exhibit Binders.
Tab A: Trial Briefs Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Statement to Be Read to the Jury Tab E: Joint List of Jury Instructions Tab F: Joint and Contested Jury Instructions Tab G: Joint or Contested Verdict Form(s) Tab H: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab I: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint). Tab J: Motions in Limine, unless they are too voluminous and require their own binder.
(for trials by the court without a jury, the Trial Binder shall include only the documents listed under Tabs A, B, C, H, I, and J with the other sections left empty):
a. No conclusionary terms such as "engine, mechanical or electrical" problems. b. BE SPECIFIC, e.g., CEL comes on, Infotainment screen turns black when backing up, etc.
Identify all remaining issues by providing answers to the above questions as applicable.
The Joint Case Management Conference Statement Addendum must include a Liability section addressing claims for motor vehicle negligence, general negligence, negligent entrustment, per se negligence, vehicle code violations, whether the defendant will admit liability, and any pending or contemplated criminal charges or investigations.
Court's wording
8. Liability a. Is there a claim for motor vehicle negligence? 0Yes No b. Is there a claim for general negligence? 0Yes no c. Is there a claim for negligent entrustment? 0Yes no d. If so, what is the basis for the claim? e. Is there a claim for per se negligence? 0Yes No f. Is there a claim for violations of the vehicle code? Yes no g. If so, what section of the vehicle code? h. Will the defendant admit liability? 0Yes No 1 Are there any criminal charges pending or contemplated? 0Yes No J. Is there a criminal investigation on-going? Yes no
The Joint Case Management Conference Statement Addendum must include an Insurance section disclosing each party's auto insurance, policy limits, whether the insurance company is providing a defense, and any uninsured motorist issue.
Court's wording
7. Insurance a. Does the plaintiff have auto insurance? 0Yes No b. If so, what are the policy limits? c. Does the defendant have auto insurance? 0Yes No d. If so, what are the policy limits? e. Is the insurance company providing a defense? 0Yes no f. Is there an uninsured motorist issue? 0Yes no
Filing & Service rules
Electronic Filing Rules
As set forth in more detail in the Trial Preparation Order, no later than 7 court days before the Final Status Conference, the parties must electronically file the documents listed below.
As set forth in more detail in the Trial Preparation Order, no later than 7 court days before the Final Status Conference, the parties must electronically file the documents listed below.
Civil cases
Page 5 | Final Status Conference
All trial documents must be filed electronically under the General Order re Mandatory Electronic Filing for Civil, with self-represented litigants exempt under California Rules of Court, Rule 2.253(b)(2).
All trial documents are to be filed pursuant to the General Order re Mandatory Electronic Filing for Civil dated November 5, 2018. Pursuant to California Rules of Court, Rule 2.253 (b)(2), self-represented litigants are exempt from the mandatory electronic filing requirement.
Civil cases
Page 10 | TRIAL PREPARATION ORDER
Filing Timing and Cure Windows
The parties are to meet and confer within 30 days of the hearing and file a CMC statement on Judicial Council Form CM-110 within five (5) days of the hearing.
The parties are to meet and confer within 30 days of the hearing and file a CMC statement on Judicial Council Form CM-110 within five (5) days of the hearing.
Civil cases
Page 4 | Case Management Conferences
Requests must be made in the portal at least ten (10) court days before the hearing.
Parties' and/or counsels' request must be made in the portal at least ten (10) court days before the hearing.
Civil cases
Page 4 | Court Reporters (continued from page 3)
The Court reserves the right not to consider any late-filed oppositions and replies.
Please note that the court reserves the right not to consider any late filings of oppositions and replies.
Civil cases
Page 5 | Law and Motion
Trial preparation documents are due to be filed no later than 7 court days before the Final Status Conference.
As set forth in more detail in the Trial Preparation Order, no later than 7 court days before the Final Status Conference, the parties must electronically file the documents listed below.
Civil cases
Page 5 | Final Status Conference
Motion hearing dates must be reserved through the online Court Reservation System (CRS), and a reserved motion will be automatically taken off calendar if the pleadings are not filed within 3 days of making the reservation.
Parties must obtain and schedule a motion hearing date via the online Court Reservation System (CRS) on the Superior Court of California, Los Angeles County website: https:// www.lacourt.ca.gov “Online Services” tab. Please be advised that a motion reserved on CRS automatically will be taken off calendar if the pleadings are not filed within 3 days of the date of making the reservation.
Civil cases
Page 5 | Law and Motion
Parties who do not provide a court reporter for trial must prepare a joint statement of each day's witness testimony and lodge it with the Court the next morning before proceedings resume — no exceptions.
Parties who do not provide a court reporter for trial are directed to meet at the close of each session and prepare a joint statement of the witness testimony presented that day. The joint statement must be lodged with the Court the next morning before proceedings resume. No exceptions.
Civil cases
Page 6 | Court Reporter
Deposition transcripts and discovery responses must be lodged with the Court before trial commences.
Prior to the commencement of the trial, deposition transcripts and discovery responses shall be lodged with the Court (LASC Local Rule 3.56).
Civil cases
Page 7 | Use of Deposition Transcripts and Discovery Responses
Attorneys must file a joint status report ten (10) court days before the OSC Re: ADR Compliance hearing.
Attorneys must file a joint status report ten (10) court days before the OSC Re ADR Compliance hearing detailing all efforts the attorneys undertook to settle the case, but without revealing any settlement offers exchanged between the parties.
Civil cases
Page 8 | Alternative Dispute Resolution (ADR)
The listed trial documents (including trial briefs and the joint witness list) must be filed and served no later than seven court days before the Final Status Conference.
No later than seven court days before the Final Status Conference, the parties’ counsel and any self-represented parties shall file and serve the following documents:
Civil cases
Page 10 | TRIAL PREPARATION ORDER
Voluminous motions in limine that cannot fit behind Tab J in the Trial Binder must be submitted in a separate binder no later than seven court days before the Final Status Conference.
If the motions in limine are too voluminous to fit behind Tab J in the Trial Binder, the parties must submit a separate motion in limine no later than seven court days before the Final Status Conference.
Civil cases
Page 15 | Motions in Limine (Trial Preparation Order)
The jointly prepared Trial Binder must be lodged in Department D no later than seven court days before the Final Status Conference.
No later than seven court days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department D a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following
Civil cases
Page 16 | 6. TRIAL BINDER
Plaintiff must file the completed Joint Case Management Conference Statement Addendum no later than ten (10) court days before the Initial Case Management Conference.
Plaintiff is responsible for filing the completed Joint Case Management Conference Statement Addendum no later than ten (10) court days before the date set for the Initial Case Management Conference.
Civil cases
Page 18 | Joint Case Management Conference Statement Addendum
A proposed protective order must be served and filed within 5 days of this 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 and the parties shall meet and confer as to agreeable language for the same.
Civil cases
Page 27
Plaintiff must file the completed Joint Case Management Conference Statement Addendum no later than 10 court days before the Initial Case Management Conference.
Plaintiff is responsible for filing the completed Joint Case Management Conference Statement Addendum no later than ten (10) court days before the date set for the Initial Case Management Conference. (See California Rules of Court, Rules 3.724, 3.725.)
Civil cases
Page 30 | Joint Case Management Conference Statement Addendum
Service and Proof of Service Rules
All defendants must be served with the complaint by the case management conference.
All defendants must be served with the complaint by the case management conference.
Civil cases
Page 4 | Case Management Conferences
A copy of any PowerPoint slides must be shared with opposing counsel before the trial presentation, leaving sufficient time to object.
If a PowerPoint is to be used, a copy of the slides must be shared with the opposing counsel prior to the presentation leaving sufficient time to object.
Civil cases
Page 7 | FSCs and Trials
All trial exhibits must be exchanged between counsel and self-represented parties no later than 18 court days before the Final Status Conference.
No later than 18 court days before the Final Status Conference, the parties’ counsel and any self-represented parties shall exchange all exhibits they intend to introduce at trial.
Civil cases
Page 9 | MEET AND CONFER
The listed trial documents must be served on all parties no later than seven court days before the Final Status Conference, together with filing.
No later than seven court days before the Final Status Conference, the parties’ counsel and any self-represented parties shall file and serve the following documents:
Civil cases
Page 10 | TRIAL PREPARATION ORDER
The Song-Beverly Act Addendum to the Case Management Conference Statement must be served on all parties/attorneys of record concurrently with the Notice of Case Management Conference.
You are ordered to serve this Song-Beverly Act Addendum to Case Management Conference Statement on all parties/attorneys of record concurrently with the Notice of Case Management Conference.
Civil cases
Page 18 | Joint Case Management Conference Statement Addendum
Both plaintiff and defendant must serve verification along with the documents they produce in discovery.
Plaintiff and defendant shall serve verification with the documents they produce.
Civil cases
Page 27
Plaintiff's attorney must serve this Order and the attached Joint Case Management Conference Statement Addendum on all defense attorneys upon service of the Summons and Complaint.
Plaintiff’s attorney is ordered to provide service of this Order and the attached Joint Case Management Conference Statement Addendum to all defense attorneys upon service of the Summons and the Complaint.
Civil cases
Page 28
Plaintiffs and their attorneys of record must serve the Motor Vehicle Personal Injury Case Addendum on all parties/attorneys of record concurrently with the Notice of Case Management Conference.
You are ordered to serve this Motor Vehicle Personal Injury Case Addendum to Case Management Conference Statement on all parties/attorneys of record concurrently with the Notice of Case Management Conference.
Civil cases
Page 30 | Joint Case Management Conference Statement Addendum
Plaintiff's attorney must serve the discovery standing order and attached Joint Case Management Conference Statement Addendum on all defense attorneys upon service of the Summons and Complaint.
Plaintiff's attorney is ordered to provide service of this Order and the attached Joint Case Management Conference Statement Addendum to all defense attorneys upon service of the Summons and the Complaint.
Civil cases
Page 38 | Standing Order Re Discovery
Counsel must appear at every status conference concerning proofs of service in Lemon Law and Motor Vehicle Personal Injury cases.
PROOFS OF SERVICE: Counsel must appear for all Status Conferences regarding proofs of service for Lemon Law cases and Motor Vehicle Personal Injury cases.
Civil cases
Page 1 | PROOFS OF SERVICE
Produced discovery information may be provided to 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.
Civil cases
Page 27
Filing Fees and Waivers
Jury fees must be paid on a daily basis during trial, with the daily rate provided by the judicial assistant.
Jury fees must be paid on a daily basis. The judicial assistant will advise of the daily rate.
Civil cases
Page 6 | Jury Fees
Self-represented litigants may be entitled to a court reporter at state expense if they obtain a fee waiver application approved in advance by the Court.
Self-represented litigants may be entitled to a court reporter at the state's expenses, subject to a fee waiver application approved in advance by the Court.
Civil cases
Page 3 | Court Reporters
Courtesy Copy Requirements
For ex parte applications, courtesy copies must be provided to the courtroom by noon the day before the hearing.
Courtesy copies to be provided to the courtroom by noon the day before the hearing.
Civil cases
Page 3 | Ex Parte Applications
Courtesy copies are due at the courtroom two weeks prior to the hearing date.
COURTESY COPIES ARE DUE AT THE COURTROOM TWO WEEKS PRIOR TO HEARING DATE AT THE COURTROOM.
Civil cases
Page 3 | Law and Motion
The moving party must deliver moving pleadings to Department D at least two weeks before a Friday law and motion hearing.
For law and motion matters set for hearing on the Friday calendar, the moving party must deliver the moving pleadings to Department D at least two weeks before the hearing date.
Civil cases
Page 4 | Courtesy Copies
Courtesy copies of all oppositions and replies must be delivered to Department D on the day of electronic filing.
Courtesy copies of all oppositions and replies must be delivered to Department D on the day of the electronic filing.
Civil cases
Page 4 | Courtesy Copies
For ex parte applications, the parties must deliver courtesy copies to Department D the day before the hearing.
For ex parte applications, the parties must deliver courtesy copies to Department D the day before the hearing with any oppositions being delivered to Department D no later than 9:00 a.m. the day of the hearing.
Civil cases
Page 4 | Courtesy Copies
Courtesy copies of all motions and related pleadings must be delivered to Department D even though the documents are filed electronically.
In compliance with the Court's policy regarding electronic filing, courtesy copies of all motions and related pleadings must be delivered to Department D, even though the documents have been filed electronically.
Civil cases
Page 4 | Courtesy Copies
Sealing & Redaction Procedures
A party who believes the ordered discovery information needs protection must serve and file a proposed protective order within 5 days of this Order and meet and confer on its language, with the Los Angeles Superior Court standard Protective Order as the default.
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 Superior Court of Los Angeles in its website.
Civil cases
Page 27
A party who believes produced discovery information should be protected must serve and file a proposed protective order within 5 days of the order and meet and confer on language, with the LASC standard protective order as the default.
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 LASC in its website.
Civil cases
Page 37 | Production of Documents
Filing Bundling Requirements
No later than 7 court days before the Final Status Conference, the parties must submit a tabbed hard copy trial binder (Tabs A–J) of the previously filed trial documents; in non-jury trials Tabs D–G are inapplicable and should be left empty, and voluminous motions in limine may merit their own binder.
By no later than 7 court days before the Final Status Conference, the parties are to submit to the Court a hard copy binder containing these previously filed documents under the following tabs: Tab A – Trial Briefs Tab B – Joint Witness List Tab C – Joint Exhibit List Tab D – Joint Statement to be Read to the Jury Tab E – List of Proposed Jury Instructions (Joint and Contested) Tab F – Full Text Jury Instructions (Joint and Contested) Tab G – Joint Verdict Form Tab H – Joint Page and Line Designation for Deposition and Former Testimony answer, cross-complaint, and answer to any cross-complaint). Tab J – Motions in Limine (unless they are voluminous enough to merit their own binder). For non-jury trials, the documents behind Tabs D, E, F and G do not apply and need not be filed. In non-jury trials, those tabs of the trial binder should be left empty.
Civil cases
Page 5 | Final Status Conference
Jury instructions must be filed together in a prescribed sequence (joint instructions, then plaintiff's contested instructions, then defendant's contested instructions) with a first-page pleading caption page.
following order (filed with a first page pleading caption page): (1) the agreed-upon instructions (“Joint Jury Instructions”), (2) plaintiff’s requested instructions to which defendant objects (Plaintiff’s Contested Jury Instructions”), and (3) defendant’s requested instructions to which plaintiff objects (“Defendant’s Contested Jury Instructions”).
Civil cases
Page 17 | Trial Preparation Order
The Joint Case Management Conference Statement Addendum must be filed as a separate pleading and must not be attached to the Case Management Statement.
Do not attach the addendum to the Case Management Statement. File the Addendum as a separate pleading.
Civil cases
Page 18 | Joint Case Management Conference Statement Addendum
Pre-Motion Conference Requirements
All motion hearing dates in Department D must be reserved in advance through the Court Reservation System (CRS).
MOTIONS: All motion hearing dates must be reserved in advance using the Court Reservation System (CRS).
Civil cases
Page 2 | MOTIONS
Counsel and self-represented parties must meet and confer no later than 11 court days before the Final Status Conference to prepare trial documents and binders, attempt stipulations (exhibit authenticity/admissibility, motions in limine, ultimate facts and legal issues), and discuss settlement.
No later than 11 court days before the Final Status Conference, the parties’ counsel and any self-represented parties shall meet and confer to do the following: (1) discuss and prepare the documents required in Sections 2.B-H below, and the Motions in Limine Binder, Exhibit Binders, and Trial Binder required in Sections 3-5 below, (2) discuss and make a good faith effort to stipulate to the authenticity and admissibility of each trial exhibit, (3) discuss and make a good faith effort to stipulate to resolve each motion in limine, (4) discuss and make a good faith effort to stipulate to ultimate facts and legal issues, and (5) discuss and make a good faith effort to settle the case.
Civil cases
Page 9 | MEET AND CONFER
Motions in limine must be noticed for hearing at the Final Status Conference.
Motions in limine shall be noticed for hearing at the Final Status Conference.
Civil cases
Page 14 | 4. Motions in Limine
Adjournment & Extension Requirements
Trial continuances must be sought by noticed motion or ex parte application (ex parte application or joint stipulation preferred), and the Court will not grant continuances without a showing of good cause.
Trial continuances must be heard on a noticed motion or Ex Parte application basis, unless otherwise ordered by the Court. The Court prefers Ex Parte Applications or Joint Stipulation and Order. In most instances, a noticed motion is not necessary. The Court's policy is to hold all trial dates and not to grant continuances without a showing of good cause.
Civil cases
Page 3 | Continuances
Chambers Communication Rules
Telephone calls to Department D (818-265-6413) are accepted 8:30 a.m.-12:00 p.m. and 1:30 p.m.-4:30 p.m.; calls before 11:00 a.m. should be limited to calendared cases for that day.
Telephone Hours: 8:30 a.m. to 12:00 p.m. and 1:30 p.m. to 4:30 p.m. (Phone calls from 8:30 a.m. to 11:00 a.m. should be limited to matters pertaining to calendared cases for that day. The best time to reach Department D staff is between 11:00 a.m. and 12:00 p.m. and 1:30 p.m. to 4:30 p.m.)
Civil cases
Page 2 | COURTROOM INFORMATION
Parties may call the Court at (818) 265-6414 to notify it when both sides agree to submit on the tentative ruling, but if only one party agrees, the Court may still hold the hearing without them and issue a ruling different from the tentative.
The Court usually posts tentative rulings on the court's website prior to the hearing. If both parties agree to submit on the tentative, you may let the Court know by calling the Court at (818) 265-6414. However, if you agree to submit, and the other party does not, the Court may proceed with the hearing even if you do not appear and may issue a ruling different from the tentative.
Civil cases
Page 5 | Law and Motion
Department D's chambers email address is GlnDeptD@lacourt.ca.gov.
Department Email: GlnDeptD@lacourt.ca.gov
Civil cases
Page 2 | COURTROOM INFORMATION