Judge Salvatore Sirna
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Courtesy Copies
Exhibit
- 3 copies • On First Day of Trial
Exhibits
- 3 copies • First Day of Trial
Binding: Three Ring Binder
Adjournments
- Trial continuance requests are disfavored and must show good cause, include a statement that all experts, percipient witnesses, and principals will be available on the proposed trial date, and — if mediation has not occurred — a date certain for mediation with the mediator's name.
- Trial continuance requests are disfavored, require good cause, and must include specified statements about the proposed date and mediation.
Request must include
Communication
Phone
Clerk
Document Format Requirements5 rules
MOTIONS IN LIMINE must be in writing, numbered, and shall be filed and served on opposing parties in accordance with Local Rule 3.25(f)(2).
- Motion in limine
Formatting
- •Numbered
Each exhibit must be identified separately and Bates stamped. b. Bulk exhibits (e.g., "plaintiffs medical records") will not be permitted. Each page of a multi-page exhibit must be consecutively paginated (e.g., exhibit 1 will be 1-1, 1-2, etc.). c. Blow-ups of portions of exhibits will not be identified nor marked as a sub-part to the exhibit. Typically, a blow-up will not be admitted into evidence.
- Exhibit
Formatting
- •Bates stamped
- •Bulk exhibits not permitted
- •Blow-ups not admitted into evidence
Each exhibit must be identified separately and Bates stamped. b. Bulk exhibits (e.g., "plaintiffs medical records") will not be permitted. Each page of a multi-page exhibit must be consecutively paginated (e.g., exhibit 1 will be 1-1, 1-2, etc.).
- Exhibits
Formatting
- •Bulk exhibits will not be permitted
Please submit the Special Verdict to the clerk via email in MS Word format.
- File type
- Word
- Special verdict form
Blow-ups of portions of exhibits will not be identified nor marked as a sub-part to the exhibit. Typically, a blow-up will not be admitted into evidence.
Document Filing Requirements14 rules
Motions in limine must include a declaration with a certificate of conference, else will be summarily denied.
Court's wording
The motion must be accompanied by a declaration that includes, among other items, a representation that the motion has been discussed with opposing counsel. If not, the motion will be summarily denied.
CACI JURY INSTRUCTIONS - The parties shall file a joint document which provides a list of all requested jury instructions, by CACI ... lists (all on the same document) of all jury instructions requested by one party and objected to by the other. The parties need not print the text of each requested CACI instruction.
MOTIONS IN LIMINE must be in writing, numbered, and shall be filed and served on opposing parties in accordance with Local Rule 3.25(f)(2).
Counsel must read and be familiar with Local Rule 3.57. The motion must be accompanied by a declaration that includes, among other items, a representation that the motion has been discussed with opposing counsel. If not, the motion will be summarily denied.
STATEMENT OF THE CASE - The parties must file a Joint Statement of the Case to be read to the jury.
SPECIAL VERDICT - Counsel are urged to agree upon a special verdict. If counsel cannot agree, each counsel is required to submit a proposed special verdict form.
Trial briefs are mandatory in all cases and must describe claims, defenses, and issues; stipulated facts; major evidentiary issues with points and authorities; relief claimed with a breakdown of damages elements; and any other information assisting the Court.
- Document
- Trial brief
Must include
- •Statement of facts
Court's wording
TRIAL BRIEFS – Trial Briefs are mandatory in all cases and must include: a. Brief description of the claims and defenses presented and the issues to be decided. b. Brief statement of ultimate facts or issues to which you will stipulate. c. List of major evidentiary issues anticipated, with succinct points and authorities. d. Statement of the relief claimed, including a succinct breakdown of the elements of damages claimed. (Do not hesitate to use bullet points.) e. Any other information that will assist the Court.
WITNESS LIST - The parties shall submit a joint witness list in the attached form must include the name, a brief description of the testimony, a time estimate on direct and cross, any potential scheduling problem, and any special requirements (e.g., interpreter, etc.).
STATEMENT OF THE CASE - The parties must file a Joint Statement of the Case to be read to the jury.
EXHIBIT LIST - The parties shall file a joint exhibit list in the attached form. Exhibits should be numbered and not designated by letters.
Trial briefs are mandatory and must include specified sections on claims, facts, evidence, and relief.
- Document
- Trial brief
Must include
- •Legal argument
- •Statement of facts
Court's wording
TRIAL BRIEFS – Trial Briefs are mandatory in all cases and must include: a. Brief description of the claims and defenses presented and the issues to be decided. b. Brief statement of ultimate facts or issues to which you will stipulate. c. List of major evidentiary issues anticipated, with succinct points and authorities. d. Statement of the relief claimed, including a succinct breakdown of the elements of damages claimed. (Do not hesitate to use bullet points.) e. Any other information that will assist the Court.
Joint witness lists must include name, testimony description, time estimates, scheduling issues, and special requirements.
Court's wording
WITNESS LIST - The parties shall submit a joint witness list in the attached form must include the name, a brief description of the testimony, a time estimate on direct and cross, any potential scheduling problem, and any special requirements (e.g., interpreter, etc.).
G. Plaintiff's counsel and Cross-Complainant's counsel shall provide the Court at the FSC with a copy of the operative pleading(s) and be prepared to state on the record the claims that will be pursued during trial. FAILURE TO COMPLY WITH THIS ORDER MAY RESULT IN SANCTIONS.
Plaintiff and cross-complainant counsel must provide operative pleadings at the FSC and state claims pursued.
Court's wording
Plaintiff’s counsel and Cross-Complainant's counsel shall provide the Court at the FSC with a copy of the operative pleading(s) and be prepared to state on the record the claims that will be pursued during trial.
Filing & Service rules
Electronic Filing Rules
Please submit the Special Verdict to the clerk via email in MS Word format.
Please submit the Special Verdict to the clerk via email in MS Word format.
Civil cases
Page 2 | Jury Trial Filing Requirements (CACI Jury Instructions, Special Verdict, Exhibit List, Witness List, Trial Briefs, Statement of the Case)
Filing Timing and Cure Windows
Joint trial documents must be filed five court days before the Final Status Conference (FSC).
Joint trial documents are to be filed five (5) court days before the FSC.
Civil cases
Page 1 | Section C
Counsel must meet and confer before the FSC to prepare joint trial documents, which must be filed five court days before the FSC.
Counsel are ordered to meet and confer before the FSC to exchange, discuss and prepare for submission to the Court the joint jury instructions, exhibits, joint exhibit lists, joint witness list, joint statement of the case, and special verdict form. Joint trial documents are to be filed five (5) court days before the FSC.
Civil cases
Page 1 | FINAL STATUS CONFERENCE ORDER (Sections A-G)
For jury trials, the following documents shall be filed five (5) court days before the FSC:
For jury trials, the following documents shall be filed five (5) court days before the FSC:
Civil cases
Page 1 | Jury Trial Filing Requirements (CACI Jury Instructions, Special Verdict, Exhibit List, Witness List, Trial Briefs, Statement of the Case)
Counsel must exchange exhibits at least ten days before the FSC, with exhibits placed in a 3-ring binder.
Counsel are ordered to exchange exhibits at least ten (10) days before the FSC. The exhibits shall be placed in a 3-ring binder.
Civil cases
Page 2 | Jury Trial Filing Requirements (CACI Jury Instructions, Special Verdict, Exhibit List, Witness List, Trial Briefs, Statement of the Case)
Service and Proof of Service Rules
Motions in limine must be filed and served on opposing parties in accordance with Local Rule 3.25(f)(2).
MOTIONS IN LIMINE must be in writing, numbered, and shall be filed and served on opposing parties in accordance with Local Rule 3.25(f)(2).
Civil cases
Page 1 | MOTIONS IN LIMINE
Counsel are ordered to exchange exhibits at least ten (10) days before the FSC.
Counsel are ordered to exchange exhibits at least ten (10) days before the FSC.
Civil cases
Page 2 | Section F3d
Please submit the Special Verdict to the clerk via email in MS Word format.
Please submit the Special Verdict to the clerk via email in MS Word format.
Civil cases
Page 2 | Section F2
Courtesy Copy Requirements
Three copies of all exhibits (3-ring binder format) must be provided on the first day of trial — one for the Court, the clerk, and the witness stand.
The exhibits shall be placed in a 3-ring binder. Three (3) copies of all exhibits shall be provided on the first day of trial—one for the Court, the clerk, and a separate copy for the witness stand.
Civil cases
Page 2 | Jury Trial Filing Requirements (CACI Jury Instructions, Special Verdict, Exhibit List, Witness List, Trial Briefs, Statement of the Case)
Three copies of all exhibits must be provided on the first day of trial for the court, clerk, and witness stand.
Three (3) copies of all exhibits shall be provided on the first day of trial—one for the Court, the clerk, and a separate copy for the witness stand.
Civil cases
Page 2 | Section F3d
Filing Bundling Requirements
Exhibits must be placed in a 3-ring binder.
The exhibits shall be placed in a 3-ring binder.
Civil cases
Page 2 | Section F3d
Adjournment & Extension Requirements
Trial continuance requests are disfavored, require good cause, and must include specified statements about the proposed date and mediation.
REQUESTS FOR A TRIAL CONTINUANCE – Requests for a trial continuance are disfavored. Any request for a trial continuance must include the requisite showing of good cause, as well as the following: 1. A statement from each party that the proposed trial date is a date upon which all experts, percipient witnesses, and principals will be available; and 2. To the extent mediation has not taken place, a date certain for mediation, to include the name of the mediator.
Civil cases
Page 1 | Section D
Trial continuance requests are disfavored and must show good cause, include a statement that all experts, percipient witnesses, and principals will be available on the proposed trial date, and — if mediation has not occurred — a date certain for mediation with the mediator's name.
REQUESTS FOR A TRIAL CONTINUANCE – Requests for a trial continuance are disfavored. Any request for a trial continuance must include the requisite showing of good cause, as well as the following: 1. A statement from each party that the proposed trial date is a date upon which all experts, percipient witnesses, and principals will be available; and 2. To the extent mediation has not taken place, a date certain for mediation, to include the name of the mediator.
Civil cases
Page 1 | REQUESTS FOR A TRIAL CONTINUANCE
Chambers Communication Rules
Department G's clerk (Melissa Vasquez) and court assistant (Londie Olmos) can be reached at (909) 802-1104.
Clerk: Melissa Vasquez 400 Civic Center Plaza Court Assistant: Londie Olmos Pomona, CA 91766-3299 (909) 802-1104
Civil cases
Page 5 | TRIAL PROCEDURES - Department G