Judge Robert B. Broadbelt
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Exhibit Binders
- Until Trial Begins
Communication
Phone
Chambers
Document Format Requirements7 rules
The proposed jury instructions shall be prepared on Los Angeles County Superior Court form LASC LACIV 129 or in a Word document that is in the same format.
Parties must jointly prepare three sets of tabbed, internally paginated, properly marked exhibits in three-ring binders (court, Judicial Assistant, witnesses), with documentary exhibits copied one-sided.
- Binding
- Tabbed three-ring binder
- Exhibits
Formatting
- •Exhibits internally paginated by document
- •Properly marked and organized numerically
- •Documentary exhibits must be one-sided copies
Court's wording
The parties’ counsel and any self-represented parties shall work together to jointly prepare three 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”). Copies of documentary exhibits shall be one-sided copies.
The Motions in Limine Binder must contain one-sided, conformed copies organized in tabbed three-ring binders in numerical order, with colored sheets separating moving, opposition, and reply papers.
- Binding
- Tabbed three-ring binder
- Motion in limine
- Opposition
- Reply
Formatting
- •Tabbed in numerical order
Court's wording
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.
consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents
- Binding
- Tabbed three-ring binder
- Trial binder
Formatting
- •One-sided conformed copies
- •Table of contents required
Each designation or counter-designation shall be highlighted, with each party using a different color highlighter.
The parties’ counsel and any self-represented parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the Exhibit Binders.
Formatting
- •Mark all non-documentary exhibits
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 set of the Exhibit Binders.
Document Filing Requirements22 rules
Ex parte applications must comply with the requirements of California Rules of Court, rules 3.1200-3.1207.
When the court sets a case for trial, the court usually issues a Trial Preparation Order in the form posted with this Courtroom Information for Department 513. The court requires the parties' counsel and any self-represented parties to work together to jointly prepare and submit the documents and binders required by that order.
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. Any party who seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the court.
The parties must jointly prepare and file a single witness list of all witnesses any party intends to call at trial, excluding impeachment and rebuttal witnesses.
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 Superior Court Rules (“Local Rules”), Rule 3.25, subd. (g)(5).)
Exhibits not listed on the joint exhibit list may be excluded at trial (except for impeachment or rebuttal), require a good-cause showing to be admitted, and objections not stated on the list may be deemed waived.
Court's wording
Any exhibit that is not included on the joint exhibit list is subject to being excluded at trial other than for purposes of actual impeachment or rebuttal. Any party who seeks to introduce an exhibit that is not identified on the joint exhibit list must first make a showing of good cause to the court. Any objection to an exhibit that is not stated on the joint exhibit list is subject to being deemed waived by the court.
Counsel and self-represented parties must jointly prepare and file a joint exhibit list containing eight specified columns of information for each exhibit offered at trial.
- Document
- Joint exhibit list
Must include
- •Exhibit list
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, (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. (Local Rule 3.25, subd. (g)(6).)
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, counsel and self-represented parties must jointly prepare and file a joint list of proposed jury instructions stating six specified items 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 objections, and (6) whether the jury instruction was given by the court (“Joint List of Proposed Jury Instructions”).
In jury trials, the parties must jointly file a complete set of full-text proposed jury instructions with CACI instructions edited to insert party names and remove blanks and irrelevant material.
Court's wording
For jury trials, the parties’ counsel and any self-represented parties shall work together to prepare and file 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 proposed general or special verdict form acceptable to all parties, or file 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.
Each counter-designating party's counter-designations in the joint chart must include six required columns (witness, date/type of testimony, page:line counter-designations, objections, related designation number, and ruling).
Court's wording
In the joint chart, each counter-designating party’s counter-designations of additional deposition or former testimony of the witness that relates to the designations 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 counter-designations of the deposition or former testimony requested to be used, (4) any objections, (5) the designation number of the other party’s designation to which the counter-designation relates, and (6) the court’s ruling.
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.
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”).
Each designating party's designations in the joint chart must include six required columns (witness, date/type of testimony, page:line designations, objections, counter-designation info, and ruling).
Court's wording
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.
The Trial Binder must contain a table of contents with Tabs A-I (trial briefs, joint witness list, joint exhibit list, jury statement, jury instructions, verdict forms, deposition designations, and operative pleadings); bench trials require only Tabs A, B, C, H, and I.
- Document
- Trial binder
Must include
- •Table of contents
Court's wording
with a table of contents that includes the following (for trials by the court without a jury, the Trial Binder shall only include the documents listed under Tabs A, B, C, H, and I): 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).
The joint witness list must use mandated columns (alphabetical witness name, expert status, accommodations, calling party, expected-to-testify status, testimony description, and direct/cross/total time estimates in hours) and conclude with a grand total of estimated testimony time.
Court's wording
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.
Each party shall file a trial brief succinctly identifying: (1) the causes of action 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; and (4) any other information that may assist the court at trial.
- Document
- Trial brief
Must include
- •Legal argument
When a special verdict form is requested, the parties are expected to use the applicable CACI special verdict form.
Court's wording
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
- Opposition and reply papers
- Placement
- Caption
The notice of motion for each motion in limine shall concisely identify the evidence that the moving party seeks to exclude.
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.
Parties must attach copies of the transcript pages they designate or counter-designate to the Joint Chart.
Court's wording
The parties shall attach copies 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 or trial transcript.
Filing & Service rules
Electronic Filing Rules
Motion hearing dates must be reserved in advance through the Court Reservation System (CRS) on the court's online portal.
All motion hearing dates must be reserved in advance on the Court Reservation System at www.lacourt.ca.gov under "Online Services," "Court Forms & Filing," "EFiling", "Civil Efiling," and "Court Reservation System (CRS)."
Page 2 | 3. Motions
Ex parte applications and all supporting documents subject to mandatory electronic filing must be e-filed (per Local Rule 3.4(l)).
Ex parte applications subject to mandatory electronic filing, including all documents in support thereof, must be electronically filed no later than 10:00 a.m. on the date before the ex parte hearing.
Page 3 | 4. Ex Parte Applications
To request an informal discovery conference, please reserve a hearing date on the Court Reservation System, which will reflect "Confirmed" upon approval by the court, and e-file Los
To request an informal discovery conference, please reserve a hearing date on the Court Reservation System, which will reflect "Confirmed" upon approval by the court, and e-file Los
Page 4 | 6. Discovery Disputes
Filing Timing and Cure Windows
Written opposition to an ex parte application must be e-filed by 8:30 a.m. on the day of the ex parte hearing.
Any written opposition to an ex parte application must be electronically filed by 8:30 a.m. on the day of the ex parte hearing.
Page 3 | 4. Ex Parte Applications
Ex parte applications and supporting documents must be e-filed no later than 10:00 a.m. on the day before the ex parte hearing.
Ex parte applications subject to mandatory electronic filing, including all documents in support thereof, must be electronically filed no later than 10:00 a.m. on the date before the ex parte hearing.
Page 3 | 4. Ex Parte Applications
All parties, including self-represented parties, must exchange every exhibit they intend to introduce at trial no later than 18 calendar days before the Final Status Conference.
No later than 18 calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall exchange all exhibits they intend to introduce at trial.
Page 7 | 1. MEET AND CONFER
No later than four calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall file and serve the following documents:
No later than four calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall file and serve the following documents:
Page 8 | 2. TRIAL DOCUMENTS TO BE FILED
Only one volume of the Exhibit Binders per side must be lodged in Department 513 no later than three calendar days before the Final Status Conference.
No later than three calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall lodge in Department 513 only one volume (i.e., only one binder) of the Exhibit Binders for each side (e.g., one volume or binder for plaintiffs, and one for defendants).
Page 14 | 4. EXHIBIT BINDERS
Counsel and self-represented parties must jointly prepare and lodge a Trial Binder in Department 53 no later than three calendar days before the Final Status Conference.
No later than three calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department 53 a Trial Binder,
Page 15 | 5. Trial Binder
Parties must meet and confer no later than 11 calendar days before the Final Status Conference to prepare the required trial documents and binders, attempt to stipulate to exhibit authenticity/admissibility, narrow issues, and attempt settlement.
No later than 11 calendar 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 Exhibit Binders, Trial Binder, and Motions in Limine 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 ... ultimate facts and legal issues, and (5) discuss and make a good faith effort to settle the case.
Page 7 | 1. MEET AND CONFER
Service and Proof of Service Rules
Motions in limine must be noticed for hearing at the Final Status Conference and must comply with the notice provisions of CCP section 1005 and Los Angeles County Rule 3.57(a).
Motions in limine shall be noticed for hearing at the Final Status Conference. The parties’ counsel and any self-represented parties shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and the requirements of Los Angeles County Court Rules, Rule 3.57, subdivision (a).
Page 14 | Trial Preparation Order
Courtesy Copy Requirements
complete sets of Exhibit Binders for cases until trial begins.
complete sets of Exhibit Binders for cases until trial begins.
Page 15 | Trial Preparation Order (form)
Filing Bundling Requirements
Please do not lodge an entire set of all Exhibit Binders with the court before the first day of
Please do not lodge an entire set of all Exhibit Binders with the court before the first day of
Page 14 | 4. EXHIBIT BINDERS
Parties must jointly prepare and lodge a Motions in Limine Binder in Department 513 no later than three calendar days before the Final Status Conference.
No later than three calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department 513 a Motions in Limine Binder.
Page 14 | Trial Preparation Order
Pre-Motion Conference Requirements
The court requires the parties' counsel and any self-represented parties, with full authority to enter into a stipulation to resolve the discovery disputes at issue, to participate in the informal discovery conference with the court. Because an informal discovery conference is not a hearing on a motion, the court normally does not make any orders at the informal discovery conference unless the parties stipulate.
The court requires the parties' counsel and any self-represented parties, with full authority to enter into a stipulation to resolve the discovery disputes at issue, to participate in the informal discovery conference with the court. Because an informal discovery conference is not a hearing on a motion, the court normally does not make any orders at the informal discovery conference unless the parties stipulate.
Page 5 | 6. Discovery Disputes
The court encourages counsel and self-represented parties to hold an informal discovery conference before filing a discovery motion.
To save the parties the time and expense of preparing a discovery motion and opposition papers, the court encourages the parties' counsel and any self-represented parties to schedule and conduct an informal discovery conference before a discovery motion is filed.
Page 4 | 6. Discovery Disputes
Adjournment & Extension Requirements
Parties are expected to grant reasonable requests for extensions of time to respond to pleadings, discovery, or other matters as a professional courtesy.
The court expects all attorneys and parties to grant reasonable requests for professional courtesies, such as requests for reasonable extensions of time for deadlines to respond to pleadings, discovery, or other matters.
Page 1 | 1. Civility and Professionalism
Chambers Communication Rules
After electronically lodging a document requiring court action, parties should not call court staff for status updates and instead track the document's progress on the court's website.
The court requests that, after the parties' counsel or any self-represented parties electronically lodge a document which requires action by the court (e.g., stipulation and proposed order, and proposed judgment), they please refrain from calling the court's staff to ask about the status of the document, and that they instead follow the document's progress on the court's Website (which the court updates as soon and as often as possible).
Page 5 | 8. Electronically Lodged Documents Which Require Action by the Court
Chambers staff (Judicial Assistant K. Mason and Courtroom Assistant Cherie E. Vaughn) can be reached by phone at (213) 633-0653.
Judicial Assistant: K. Mason (213) 633-0653 Courtroom Assistant: Cherie E. Vaughn (213) 633-0653
Page 1 | Courtroom Information for Department 513
Junior Lawyer Participation Incentives
The court strongly encourages firms and agencies to let less experienced attorneys argue motions at law and motion hearings and take important roles at trial.
The court strongly encourages law firms and governmental agencies to give less experienced attorneys the opportunity to argue motions at law and motion hearings, and to have an important role at trial, including examining witnesses, conducting voir dire, and giving opening statements and closing arguments.
Page 5 | 9. Less Experienced Attorneys