Judge Sarah J. Heidel
Individual Rules, Standing Orders & Policies
- Rules last changed:
Document Format Requirements1 rule
Documentary exhibits consisting of more than one page must be internally paginated in sequential numerical order.
Document Filing Requirements14 rules
Joint exhibit lists must include pre-numbered exhibits, internal pagination for multi-page exhibits, and certified translations for foreign language exhibits.
Court's wording
Pursuant to California Rule of Court 3.1110(f) and Los Angeles County Superior Court Rules 3.52 and 3.53, all exhibits must be exchanged and pre-numbered, except for those anticipated in good faith to be used for impeachment or during rebuttal. Documentary exhibits consisting of more than one page must be internally paginated in sequential numerical order. Exhibits written in a foreign language must be accompanied by a certified English translation.
All exhibits must be exchanged and pre-numbered, except exhibits anticipated in good faith for impeachment or rebuttal.
Court's wording
Pursuant to California Rule of Court 3.1110(f) and Los Angeles County Superior Court Rules 3.52 and 3.53, all exhibits must be exchanged and pre-numbered, except for those anticipated in good faith to be used for impeachment or during rebuttal.
Every motion in limine must include a sworn meet-and-confer declaration stating the opposing party's position or the motion will be summarily denied.
Court's wording
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). Failure to include such a declaration will result in summary denial of MIL.
The parties must submit a joint exhibit list and joint witness list as described above.
Motions in limine must include a sworn declaration attesting to meet and confer with opposing party, or face summary denial.
Court's wording
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). Failure to include such a declaration will result in summary denial of MIL.
Submit a disposition table which lists all jury instructions by number, the identity of the party or parties proposing the instruction, and columns for the court to indicate whether the instruction is given, modified, withdrawn or refused.
All witnesses must be listed on one list. Do not repeat the name of a witness. Indicate the total time expected for that testimony, including direct, cross, and re-direct. At the end of the list, state the total time estimated for each witness's testimony.
Exhibits written in a foreign language must be accompanied by a certified English translation. Cal. Rule of Court 3.1110(g).
All demonstrative exhibits, not admitted into evidence, must be shown to the opposing party before use at trial. Any objections to the use of demonstrative exhibits must be brought to the court's attention in a timely manner and before publication to the jury.
If instructions are disputed, submit a separate set or sets indicating the party proposing and opposing the instruction.
Submit a joint set of CACI instructions will all information filled in – no remaining brackets or blanks.
Any proposed special verdict should be in a form that is easily used and understood by the jury and which does not require the jury to answer unnecessary questions.
This is brief, neutral description of the case to be read to the jury. In most instances, it should not exceed two paragraphs.
Parties wishing to give a mini opening statement before voir dire must write it out, share it with opposing counsel, and read it verbatim to the jury.
Court's wording
If the parties wish to make a mini opening statement prior to conducting their voir dire they must write out their brief statement and share it with opposing counsel. They will then be required to read their statement verbatim to the jury at the appropriate time.
Filing & Service rules
Electronic Filing Rules
Written opposition to an ex parte application must be electronically filed by 8:30 a.m. on the day of the hearing.
Any written opposition shall be electronically filed by 8:30 a.m. the day of the hearing.
Page 1 | Ex Parte Applications
Ex parte applications, supporting documents, and oppositions must be e-filed; self-represented litigants are exempt from this mandatory e-filing requirement.
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. Any written opposition shall be electronically filed by 8:30 a.m. the day of the hearing. Pursuant to California Rules of Court, rule 2.253(b)(2), self-represented litigants are exempt from these mandatory Electronic Filing requirements.
Page 1 | Ex Parte Applications
Ex parte applications and all supporting documents must be electronically filed no later than 10:00 a.m. 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 1 | Ex Parte Applications
Parties must reserve a motion date through the online Court Reservation System (CRS) at www.lacourt.org before filing any motion papers.
Parties must obtain a motion date via the online Court Reservation System (CRS) on the Los Angeles Court website "LA Court Online, Court Reservation System," at www.lacourt.org to reserve a date prior to filing any motion papers.
Page 2 | Law and Motion
Self-represented litigants are exempt from the mandatory electronic filing requirements under California Rules of Court, rule 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 1 | Ex Parte Applications
Filing Timing and Cure Windows
Ex parte opposition papers must be filed by an 8:30 a.m. cutoff on the day of the hearing.
Any written opposition shall be electronically filed by 8:30 a.m. the day of the hearing.
Page 1 | Ex Parte Applications
Written oppositions to ex parte applications must be e-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 1 | Ex Parte Applications
Ex parte application papers must be filed 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 1 | Ex Parte Applications
Ex parte applications and supporting documents must be e-filed by 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 1 | Ex Parte Applications
Parties must meet and confer and submit all required trial preparation documents five court days before the Final Status Conference.
Parties must meet and confer and submit the following documents five court days before the FSC.
Page 3 | Trial Preparation Order - Final Status Conference
Required FSC documents must be submitted five court days before the Final Status Conference.
Parties must meet and confer and submit the following documents five court days before the FSC.
Page 3 | Trial Preparation Order
Failure to timely submit any required item without good cause may result in sanctions, including monetary sanctions, exclusion of evidence, issue preclusion, denial of claims or defenses, dismissal, or default.
Failure to submit any item required in this order in a timely manner without good cause may result in the imposition of sanctions, including monetary sanctions, exclusion of evidence, issue preclusion, denial of a claim or defense, dismissal, or default.
Page 4 | Trial Preparation Order - Compliance
Motions in limine must be served and submitted five court days before the Final Status Conference.
Motions in limine must be served on the opposing party and submitted to the court five court days prior to the FSC.
Page 4 | Motions in Limine
Replies to motions in limine are optional but, if filed, must be served and filed no later than the Friday before trial.
Replies are not required but may be served and filed no later than the Friday preceding the trial date.
Page 4 | Trial Preparation Order - Motions in Limine
Oppositions to motions in limine may be filed no later than the Final Status Conference.
A written opposition to a motion in limine may be served and filed no later than the FSC.
Page 4 | Motions in Limine
Written oppositions to motions in limine may be served and filed no later than the Final Status Conference.
A written opposition to a motion in limine may be served and filed no later than the FSC.
Page 4 | Trial Preparation Order - Motions in Limine
Replies to motions in limine may be filed no later than the Friday before the trial date.
Replies are not required but may be served and filed no later than the Friday preceding the trial date.
Page 4 | Motions in Limine
Service and Proof of Service Rules
Motions in limine must be served on the opposing party five court days before the FSC.
Motions in limine must be served on the opposing party and submitted to the court five court days prior to the FSC.
Page 4 | Motions in Limine
Motions in limine must be served on the opposing party and submitted to the court five court days before the FSC.
Motions in limine must be served on the opposing party and submitted to the court five court days prior to the FSC.
Page 4 | Trial Preparation Order - Motions in Limine
Filing Fees and Waivers
Motion filing fees must be paid when making online motion date reservations.
Motion fee payments are required at the time reservations are made online.
Page 2 | Law and Motion
Motion filing fees must be paid at the time the motion date reservation is made online through CRS.
Motion fee payments are required at the time reservations are made online.
Page 2 | Law and Motion
Sealing & Redaction Procedures
Counsel submitting motion materials under seal must strictly comply with California Rules of Court Rule 2.551 et seq.
If counsel wishes to submit any materials in support of a motion under seal, counsel must strictly comply with California Rules of Court Rule 2.551 et. seq.
Page 2 | Law and Motion
Motion support materials submitted under seal must comply with California Rules of Court Rule 2.551 et seq.
If counsel wishes to submit any materials in support of a motion under seal, counsel must strictly comply with California Rules of Court Rule 2.551 et. seq.
Page 2 | Law and Motion
Pre-Motion Conference Requirements
Parties must reserve a motion date via the online CRS before filing any motion papers.
Parties must obtain a motion date via the online Court Reservation System (CRS) on the Los Angeles Court website “LA Court Online, Court Reservation System,” at www.lacourt.org to reserve a date prior to filing any motion papers.
Page 2 | Law and Motion
Parties must meet and confer before filing any motion in limine per local rule.
Los Angeles County Superior Court Rule 3.57 requires the parties to meet and confer before filing any motion in limine.
Page 4 | Motions in Limine
Parties must meet and confer before filing any motion in limine under LA 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 4 | Trial Preparation Order - Motions in Limine
Upon written request of counsel, the Court may hold an informal discovery conference to resolve discovery disputes informally; IDCs are held Monday-Thursday 2:30-3:30 p.m.
Upon a written request of counsel, the Court may conduct an informal discovery conference (IDC) to assist counsel in resolving discovery disputes informally. IDCs are held Monday-Thursday 2:30-3:30 p.m.
Page 2 | Discovery
Chambers Communication Rules
Parties are prohibited from calling the courtroom to reserve a motion date.
Please do not call the courtroom to reserve a motion date.
Page 2 | Law and Motion
Parties must not call the courtroom to reserve a motion date; reservations must be made online through CRS.
Please do not call the courtroom to reserve a motion date.
Page 2 | Law and Motion