Judge Sarvenaz Bahar
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- 4 copies
Exhibits
- 5 copies • First Day of Trial
- 5 copies • Hand Delivery • On First Day of Trial
Interrogatory Excerpts, Requests for Admission, Deposition Excerpts, Video Deposition Excerpts
- First Day of Trial
Motion in Limine
- At Least 2 Calendar Days Before FSC
Binding: Three Ring Binder
Communication
Phone
Clerk
Phone
Chambers
Page & Word Limits2 rules
Trial briefs are mandatory for all (both Court and jury) trials and must include the following information and not exceed 20 pages:
- Trial brief
- Up to 20 pages
Trial briefs are mandatory for all (both Court and jury) trials and must include the following information and not exceed 20 pages:
- Trial brief
- Up to 20 pages
Document Format Requirements12 rules
Unlawful Detainer trial exhibits must be in tabbed binders with numbered pages and exhibit list; binders should be provided to judge, judicial assistant, opposing counsel, and reporter.
- Binding
- Tabbed binder
- Exhibits
Formatting
- •Each page numbered within each tab
- •Exhibit list included in binder
Court's wording
Exhibits: All document exhibits MUST be placed in binders under tabs, and each page must be numbered within each tab. The exhibit list must be included in the binders. Exhibits must be brought to Court on the first day of trial. Binders should be provided for the Judge, Judicial Assistant, Opposing Counsel and Reporter.
All document exhibits MUST be placed in binders under tabs, and each page must be numbered within each tab. The exhibit list must be included in the binders.
- Binding
- Tabbed binder
- Exhibits
3-Ring Trial Binder containing all the documents above with a table of contents.
- Binding
- Three-ring binder
- Trial binder
Formatting
- •Include a table of contents
Parties filing motions in limine must also submit a 3-ring binder notebook containing all motions, oppositions, and replies, with a Table of Contents and tab dividers for each numbered motion.
- Binding
- Three-ring binder
Formatting
- •Include a Table of Contents
Court's wording
Separate Notebooks Are Required for All Motions in Limine: In addition to filing electronically, the party filing the motion(s) in limine must also submit a 3-ring binder notebook containing all motions, oppositions, and replies. The notebook must have both a Table of Contents and tab dividers to separate each numbered motion and its corresponding opposition and reply.
h. 3-Ring Trial Binder containing all the documents above in 4.b through 4.g, with a table of contents.
- Binding
- Three-ring binder
- Trial binder
Formatting
- •Contain all jury trial documents listed in items 4.b through 4.g
- •Include a table of contents
Identical copies of the Exhibit List and all exhibits must be provided in 3-ring binders as follows: one for each party, one for the Court, and one for the witness stand.
- Binding
- Three-ring binder
- Exhibit list
- Exhibits
Printed jury instructions must be on 2-hole punched perforated paper with specified identifying information for each instruction.
- File type
- Paper
- Joint jury instructions
Formatting
- •2-hole punched perforated paper
Court's wording
The printed, hard copy of the jury instructions delivered directly to Department F44 shall be submitted on 2-hole punched, perforated paper so as to allow for separation of the identification of the instruction from the text of the instruction, to be submitted to the jury for reference during deliberation. All requested CACI instructions, per the foregoing, must be submitted in proper form which includes: A) At the top of each requested jury instruction, identification of the party/parties requesting the instruction; B) Whether the instruction is to be given as requested or modified; C) Whether the instruction is withdrawn; and D) A signature line for the Court.
The printed, hard copy of the jury instructions delivered directly to Department F44 shall be submitted on 2-hole punched, perforated paper so as to allow for separation of the identification of the instruction from the text of the instruction, to be submitted to the jury for reference during deliberation.
All exhibits sought to be admitted by the parties shall be placed in Exhibit Notebooks.
MIL oppositions must be in writing, numbered, and must refer to the numbers used by the moving party.
Court's wording
An opposition to any motion in limine must be in writing, numbered, and served and electronically filed by represented parties at least five (5) calendar days prior to the FSC. The opposition must refer to the numbers used by the moving party.
All motions in limine, if any, must be in writing, numbered, and shall be served on all opposing parties and counsel and electronically filed at least ten (10) calendar days before the FSC.
Those exhibits can be numbered consecutively in the lower, right-hand corner of each document. Each page should be given an exhibit number, so that if an exhibit contains multiple pages, it should have a "-"(dash) delineating each page. For example, if Exhibit 1 consists of 3 pages, it would be numbered as follows: Exhibit 1-1, 1-2, and 1-3.
Document Filing Requirements20 rules
Proposed orders are required
Must include
- •Proposed order
Proposed orders are required
Must include
- •Proposed order
Trial Preparation: Prior to the trial date, Plaintiff must file proof of proper service.
- Document
- Small claims trial
Must include
- •Proof of service
The jointly prepared Witness List must include the name of each witness, an estimate of time for direct and cross-examination, and the total amount of time of all witness testimony combined for the entire trial. Potential scheduling problems must be noted.
Parties must jointly prepare and exchange an exhibit list showing stipulations, with pre-agreed numbering ranges, separately identified exhibits and subparts, and consecutively paginated multi-page exhibits.
Court's wording
All parties must jointly prepare and exchange a completed Exhibit List, indicating each document and item of physical evidence, and whether there is a stipulation to authenticity and/or admissibility. Each exhibit shall be numbered or lettered. All parties shall agree in advance that their respective party will have a range of exhibit numbers or letters (e.g. Plaintiff No. 1: 1-99; PlaintiffNo. 2: 100-199; Defendant: A-Z). Each exhibit must be separately identified. Subparts to an exhibit (e.g., IA, lB, etc.) must also be identified and listed separately. Each page of a multi-page exhibit must be consecutively paginated.
The parties shall submit a printed copy of the jointly prepared, short, non-argumentative written statement of the case to be read to the jury.
Each party must prepare a list of discovery material to be used at trial specifically identifying the date, document, page, and line.
Court's wording
Each party must prepare a list of discovery material intended to be used at trial, including but not limited to interrogatories and requests for admissions and any responses thereto as well as deposition(s), all of which shall specifically identify the date, document, page and line.
If depositions or other discovery responses are intended to be used at trial, originals shall be lodged with the Court at the time of trial.
A jointly submitted packet of all requested and properly edited jury instructions to which there is no objection.
All items so referred to in the Exhibit List must be exchanged and/or reviewed by each counsel or the parties prior to the FSC.
For all jury trials, the parties/counsel shall jointly prepare and lodge a trial binder with the Court at least two (2) calendar days before the FSC, containing the required trial documents, tabbed and organized into 3-ring binders, with a Table of Contents in the front of each binder, as follows:
- Document
- Trial binder
Must include
- •Table of contents
A special verdict form is mandatory and shall be jointly prepared in final form. This special verdict form shall be adapted to CACI with proper spacing, particularly noted to allow for both clarity and direction.
These instructions shall be inserted into the aforementioned packet of the jointly submitted jury instructions, all to be considered and discussed by the Court at an appropriate time during the pendency of the trial.
Each requested CACI instruction must identify the requesting party at the top, state whether it is given as requested or modified, state whether it is withdrawn, and include a signature line for the Court.
Court's wording
All requested CACI instructions, per the foregoing, must be submitted in proper form which includes: A) At the top of each requested jury instruction, identification of the party/parties requesting the instruction; B) Whether the instruction is to be given as requested or modified; C) Whether the instruction is withdrawn; and D) A signature line for the Court.
The parties shall organize proposed jury instructions behind Tab F, with the agreed upon instructions first in order followed by the contested instructions (including special instructions) submitted by each party.
Any objections to the use of discovery material shall be done by way of an in limine motion.
Trial briefs are mandatory for all (both Court and jury) trials and must include the following information and not exceed 20 pages: 1) A brief description of each cause of action and key affirmative defenses presented and the issues to be decided; 2) Statement of ultimate facts or issues to which you will stipulate; 3) Those facts established by admissions in pleadings; admissions by discovery and/or stipulation of the parties; 4) All contested issues of fact; 5) All contested issues of law, together with points and authorities supporting the position of the parties;
- Document
- Trial brief
Must include
- •Legal argument
- •Statement of facts
All parties shall meet and confer in a good-faith effort to resolve admissibility issues related to these excerpts. Any unresolved disputes must be memorialized in writing.
The Court strongly encourages the use of CACI jury instructions.
Trial briefs must include 8 specified categories of information for all court and jury trials.
Court's wording
Trial briefs are mandatory for all (both Court and jury) trials and must include the following information and not exceed 20 pages: 1) A brief description of each cause of action and key affirmative defenses presented and the issues to be decided; 2) Statement of ultimate facts or issues to which you will stipulate; 3) Those facts established by admissions in pleadings; admissions by discovery and/or stipulation of the parties; 4) All contested issues of fact; 5) All contested issues of law, together with points and authorities supporting the position of the parties; 6) supporting the position of the parties; 7) A detailed statement of the damages and relief claimed, including a specific breakdown of the elements of damages claimed and the amount sought; and, 8) Any other information that will assist the Court.
Filing & Service rules
Electronic Filing Rules
Represented parties must electronically file all documents except exhibits pursuant to the Final Status Conference Order.
filed by represented parties must be electronically filed pursuant to the Final Status Conference Order (except for exhibits).
Page 2 | Final Status Conference Order
Jury trial documents (motions in limine, trial briefs, joint witness/exhibit lists, joint statement of the case, joint jury instructions, joint verdict form, and trial binder) must be filed electronically, with exempt parties allowed to file by conventional means.
For all jury trials, the following documents shall be filed electronically at least ten (I 0) calendar days before the trial date. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the trial date.
Page 2 | UD JURY TRIALS
Documents filed by represented parties in unlawful detainer court trials must be electronically filed per the Final Status Conference Order, except exhibits.
filed by represented parties must be electronically filed pursuant to the Final Status Conference Order (except for exhibits).
Page 2 | UD COURT TRIALS
Court trial documents (motions in limine, trial briefs, joint witness list, joint exhibit list) must be filed electronically; exempt parties may file by printed paper instead.
For all Court trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC. a. Motions in Limine (if any), b. Trial Briefs, c. Joint Witness List, and d. Joint Exhibit List.
Page 3 | 3. COURT TRIALS
Parties exempt from e-filing must file and serve a printed Request for Dismissal or Notice of Settlement at least 2 court days before the scheduled FSC.
If a party is exempt from the electronic filing requirements, that party shall file and serve a printed copy of the Request for Dismissal or Notice of Settlement at least two (2) court days before the scheduled FSC.
Page 3 | FINAL STATUS CONFERENCE ORDER ¶ 2
Represented parties must e-file oppositions to motions in limine; exempt parties may file printed paper directly in Department F44.
An opposition to any motion in limine must be in writing, numbered, and served and electronically filed by represented parties at least five (5) calendar days prior to the FSC. (Exempt parties may file same by conventional means on printed paper directly in Department F44.)
Page 4 | 5.a. MOTIONS IN LIMINE
Jury instructions must be e-filed and printed copy delivered to Department F44; non-represented parties only need printed copy.
Jury Instructions shall be submitted by both electronic filing and by a printed copy delivered directly to Department F44. However, non-represented parties are only required to submit jury instructions by delivering a printed copy directly to Department F44.
Page 5 | FINAL STATUS CONFERENCE ORDER - 5.f
Jury instructions must be filed both electronically and as a printed copy delivered directly to Department F44, but self-represented parties need only deliver a printed copy to Department F44.
Jury Instructions shall be submitted by both electronic filing and by a printed copy delivered directly to Department F44. However, non-represented parties are only required to submit jury instructions by delivering a printed copy directly to Department F44.
Page 5 | JOINT JURY INSTRUCTIONS
Hearing exhibits are not to be filed electronically.
hearing exhibits shall not be filed electronically.
Page 6 | FINAL STATUS CONFERENCE ORDER - 7
Hearing exhibits must not be filed electronically.
hearing exhibits shall not be filed electronically.
Page 7 | EXHIBITS
Self-represented parties may deliver physical copies of ex parte papers to the Clerk's Office by 8:30 a.m. on the hearing day instead of e-filing.
Pro Per (self-represented) parties may bring physical copies to the Clerk's Office by 8:30 a.m. on the hearing day.
Page 1 | UNLAWFUL DETAINERS - HEARINGS
Pro Per (self-represented) parties may bring physical copies to the Clerk's Office by 8:30 a.m. on the hearing day.
Pro Per (self-represented) parties may bring physical copies to the Clerk's Office by 8:30 a.m. on the hearing day.
Page 1 | UNLAWFUL DETAINERS - HEARINGS
Jury trial documents must be filed electronically; exempt parties may file by printed paper instead.
For all jury trials, the following documents shall be filed electronically at least ten (l 0) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC. a. Motions in Limine (if any), b. Trial Briefs, d. Joint Exhibit List, e. Joint Statement of the Case, f. Joint Jury Instructions, g. Joint Verdict Form, and, h. 3-Ring Trial Binder containing all the documents above in 4.b through 4.g, with a table of contents.
Page 3 | 4. JURY TRIALS
Filing Timing and Cure Windows
Exhibits must be brought to court on the first day of trial.
Exhibits must be brought to Court on the first day of trial.
Page 1 | UNLAWFUL DETAINERS - HEARINGS
Unlawful Detainer ex parte filings must be electronically filed by 10:00 a.m. on the court day prior to the hearing.
Ex Parle: 8:30 a.m. Monday- Friday; Must be electronically filed by 10:00 a.m. on the court day prior to the hearing.
Page 1 | UNLAWFUL DETAINERS - HEARINGS
Ex parte applications must be electronically filed by 10:00 a.m. on the court day prior to the hearing.
Ex Parle: 8:30 a.m. Monday- Friday; Must be electronically filed by 10:00 a.m. on the court day prior to the hearing.
Page 1 | UNLAWFUL DETAINERS - HEARINGS
Oppositions to ex parte applications must be filed by 8:30 a.m. on the day of hearing, a hard deadline with no exceptions.
oppositions must be filed by 8:30 a.m. on the day of hearing. THIS IS A HARD DEADLINE. NO EXCEPTIONS.
Page 1 | UNLAWFUL DETAINERS - HEARINGS
Oppositions to Unlawful Detainer ex parte motions must be filed by 8:30 a.m. on the hearing day, with no exceptions.
oppositions must be filed by 8:30 a.m. on the day of hearing. THIS IS A HARD DEADLINE. NO EXCEPTIONS.
Page 1 | UNLAWFUL DETAINERS - HEARINGS
Unlawful Detainer jury trial documents must be filed electronically 10 calendar days before trial; exempt parties may use paper.
For all jury trials, the following documents shall be filed electronically at least ten (I 0) calendar days before the trial date. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the trial date. 1. Motions in Limine (if any), 2. Trial Briefs, 3. Joint Witness List, 4. Joint Exhibit List, 5. Joint Statement of the Case, 6. Joint Jury Instructions, 7. Joint Verdict Form, and, 8. 3-Ring Trial Binder containing all the documents above with a table of contents.
Page 2 | UNLAWFUL DETAINERS - UD JURY TRIALS
Jury trial documents must be filed at least ten (10) calendar days before the trial date.
For all jury trials, the following documents shall be filed electronically at least ten (I 0) calendar days before the trial date. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the trial date.
Page 2 | UD JURY TRIALS
Settlement documents must be filed 2 court days before FSC; exempt parties may use printed copies.
If the action is settled or otherwise resolved before the FSC, no appearance will be necessary as long as either a Request for Dismissal of the entire action or a Notice of Settlement under California Rules of Court Rule 3.1385 is electronically filed with this Court at least two (2) court days before the scheduled FSC. If a party is exempt from the electronic filing requirements, that party shall file and serve a printed copy of the Request for Dismissal or Notice of Settlement at least two (2) court days before the scheduled FSC.
Page 3 | FINAL STATUS CONFERENCE ORDER - 2
Court trial documents must be filed electronically 10 calendar days before FSC; exempt parties may use paper.
For all Court trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC. a. Motions in Limine (if any), b. Trial Briefs, c. Joint Witness List, and d. Joint Exhibit List.
Page 3 | FINAL STATUS CONFERENCE ORDER - 3
No FSC appearance is required if a Request for Dismissal or Notice of Settlement (CRC 3.1385) is electronically filed at least 2 court days before the scheduled FSC.
If the action is settled or otherwise resolved before the FSC, no appearance will be necessary as long as either a Request for Dismissal of the entire action or a Notice of Settlement under California Rules of Court Rule 3.1385 is electronically filed with this Court at least two (2) court days before the scheduled FSC.
Page 3 | FINAL STATUS CONFERENCE ORDER ¶ 2
For court trials, motions in limine, trial briefs, the joint witness list, and the joint exhibit list must be filed at least 10 calendar days before the FSC.
For all Court trials, the following documents shall be filed electronically at least ten (10) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC. a. Motions in Limine (if any), b. Trial Briefs, c. Joint Witness List, and d. Joint Exhibit List.
Page 3 | 3. COURT TRIALS
All parties must meet and confer and/or exchange information at least 15 court days before the FSC, and failure to timely comply with any item of the order may result in sanctions.
All parties shall meet and confer and/or exchange information at least fifteen (15) court days before the FSC as required by this order and Los Angeles County Court Rules, Rule 3.25(g). Any failure to timely comply with any item required by this order shall subject any such non-complying party to the imposition of appropriate sanctions, including but not limited to monetary, exclusion of evidence, issue preclusion, denial of a claim or defense, dismissal, or contempt (pursuant to CCP §§128.5, 177.5, 575.5 and 583.410; Government Code §68608, CRC Rule 526).
Page 3 | FINAL STATUS CONFERENCE ORDER ¶ 1
The motions in limine notebook must be submitted at least 2 calendar days before the FSC, and late notebooks may result in the motions not being considered.
The notebook shall be submitted at least two (2) calendar days prior to the FSC. Late filed notebooks may result in the motions not being considered.
Page 4 | 5.a. MOTIONS IN LIMINE
Oppositions to motions in limine must be written, numbered, refer to moving party's numbers, and e-filed 5 calendar days before FSC.
An opposition to any motion in limine must be in writing, numbered, and served and electronically filed by represented parties at least five (5) calendar days prior to the FSC. (Exempt parties may file same by conventional means on printed paper directly in Department F44.) The opposition must refer to the numbers used by the moving party.
Page 4 | FINAL STATUS CONFERENCE ORDER - 5.a
Motions in limine must be written, numbered, served on opposing parties, and e-filed 10 calendar days before FSC.
All motions in limine, if any, must be in writing, numbered, and shall be served on all opposing parties and counsel and electronically filed at least ten (10) calendar days before the FSC. Untimely motions may not be considered.
Page 4 | FINAL STATUS CONFERENCE ORDER - 5.a
Oppositions to motions in limine must be served and electronically filed by represented parties at least 5 calendar days prior to the FSC.
An opposition to any motion in limine must be in writing, numbered, and served and electronically filed by represented parties at least five (5) calendar days prior to the FSC.
Page 4 | 5.a. MOTIONS IN LIMINE
Motions in limine must be served and electronically filed at least 10 calendar days before the FSC, and untimely motions may not be considered.
All motions in limine, if any, must be in writing, numbered, and shall be served on all opposing parties and counsel and electronically filed at least ten (10) calendar days before the FSC. Untimely motions may not be considered.
Page 4 | 5.a. MOTIONS IN LIMINE
The trial binder must be lodged with the Court at least two calendar days before the Final Status Conference in jury trials.
For all jury trials, the parties/counsel shall jointly prepare and lodge a trial binder with the Court at least two (2) calendar days before the FSC
Page 6 | TRIAL BINDERS ARE REQUIRED FOR ALL JURY TRIALS BUT ARE DISCRETIONARY FOR ALL COURT TRIALS
Parties must lodge original deposition transcripts with the courtroom clerk before trial begins on the first day of trial.
On the first day of trial, the parties must lodge with the courtroom clerk the originals of all deposition transcripts, to be used for any purpose, before trial begins.
Page 7 | FINAL STATUS CONFERENCE ORDER - 8
A list of all deposition excerpts and discovery responses to be used at trial (except impeachment), with any admissibility stipulations, must be submitted to the judge no later than 10 court days before the FSC.
All parties shall submit to the judge no later than 10 court days before the FSC a list of all excerpts from depositions and other discovery responses to be used at trial except for impeachment, along with any stipulations to their admissibility.
Page 7 | DISCOVERY
On the first day of trial, before trial begins, the parties must lodge the originals of all deposition transcripts with the courtroom clerk.
On the first day of trial, the parties must lodge with the courtroom clerk the originals of all deposition transcripts, to be used for any purpose, before trial begins.
Page 7 | DISCOVERY
For jury trials, the listed trial documents must be filed at least 10 calendar days before the FSC.
For all jury trials, the following documents shall be filed electronically at least ten (l 0) calendar days before the FSC. Exempt parties may file the following documents either electronically or by conventional means (i.e., printed copies on paper) at least ten (10) calendar days before the FSC. a. Motions in Limine (if any), b. Trial Briefs, d. Joint Exhibit List, e. Joint Statement of the Case, f. Joint Jury Instructions, g. Joint Verdict Form, and, h. 3-Ring Trial Binder containing all the documents above in 4.b through 4.g, with a table of contents.
Page 3 | 4. JURY TRIALS
Service and Proof of Service Rules
In small claims cases, the plaintiff must file proof of proper service before the trial date.
Trial Preparation: Prior to the trial date, Plaintiff must file proof of proper service.
Page 2 | SMALL CLAIMS - TRIALS
Small Claims parties must exchange trial exhibits at least 10 days before trial; confirm receipt if submitted via portal or mail.
All parties are required to exchange trial exhibits, at least, 10 days before trial. Any party submitting exhibits via the Court's digital portal or by mail must confirm that the opposing party has received a copy of the exhibits or has access to them.
Page 2 | SMALL CLAIMS - TRIALS
All parties must exchange trial exhibits at least 10 days before trial.
All parties are required to exchange trial exhibits, at least, 10 days before trial.
Page 2 | SMALL CLAIMS - TRIALS
Parties intending to use discovery at trial must exchange written particulars (e.g., deponent name, page and line numbers) no later than 10 court days before the FSC, or risk a court order prohibiting use of that discovery.
If the parties intend to use any discovery during trial, the parties must exchange in writing no later than 10 court days prior to the FSC the particulars of any such discovery. For example, if a party proposes to read or show a video excerpt from a deposition, the proffering party must identify in writing the name of the deponent, page, and line numbers to opposing counsel no later than 10 court days prior to the FSC. Failure to provide the specific discovery intended to be used at trial in writing and on a timely basis may result in a Court order prohibiting the use of said discovery.
Page 7 | DISCOVERY
All parties must serve the opposing attorney or in pro per party, in writing, no later than 10 court days before the FSC, all deposition excerpts and discovery responses to be used at trial (except those used solely for impeachment) and mark each excerpt as an exhibit.
All parties must serve on the opposing attorney/in pro per party in writing and no later than 10 court days before the FSC all excerpts from depositions, responses to interrogatories, responses to requests for admissions, or other discovery responses to be used for any purpose at trial other than solely for impeachment and mark each excerpt as an exhibit.
Page 7 | DISCOVERY
Parties must serve discovery excerpts to be used at trial (except impeachment) 10 court days before FSC, marked as exhibits.
All parties must serve on the opposing attorney/in pro per party in writing and no later than 10 court days before the FSC all excerpts from depositions, responses to interrogatories, responses to requests for admissions, or other discovery responses to be used for any purpose at trial other than solely for impeachment and mark each excerpt as an exhibit.
Page 7 | FINAL STATUS CONFERENCE ORDER - 8
Parties submitting exhibits via the Court's digital portal or by mail must confirm the opposing party received a copy or has access to them.
Any party submitting exhibits via the Court's digital portal or by mail must confirm that the opposing party has received a copy of the exhibits or has access to them.
Page 2 | SMALL CLAIMS - TRIALS
Motions in limine must be served on all opposing parties and counsel.
All motions in limine, if any, must be in writing, numbered, and shall be served on all opposing parties and counsel and electronically filed at least ten (10) calendar days before the FSC.
Page 4 | 5.a. MOTIONS IN LIMINE
Oppositions to motions in limine must be served on opposing parties.
An opposition to any motion in limine must be in writing, numbered, and served and electronically filed by represented parties at least five (5) calendar days prior to the FSC.
Page 4 | 5.a. MOTIONS IN LIMINE
Courtesy Copy Requirements
Motions in limine must be submitted in a 3-ring binder with TOC and tabs, 2 calendar days before FSC.
Separate Notebooks Are Required for All Motions in Limine: In addition to filing electronically, the party filing the motion(s) in limine must also submit a 3-ring binder notebook containing all motions, oppositions, and replies. The notebook must have both a Table of Contents and tab dividers to separate each numbered motion and its corresponding opposition and reply. The notebook shall be submitted at least two (2) calendar days prior to the FSC. Late filed notebooks may result in the motions not being considered.
Page 4 | FINAL STATUS CONFERENCE ORDER - 5.a
On the first day of trial, the parties are ordered to jointly submit five identical copies of the Exhibit Notebooks
On the first day of trial, the parties are ordered to jointly submit five identical copies of the Exhibit Notebooks
Page 6 | EXHIBITS
On the first day of trial, parties must provide sufficient copies of all discovery excerpts for the judge, the opposing parties, and the witness.
On the first day of trial, the parties must provide sufficient copies for the judge, the opposing parties, and the witness of all excerpts from interrogatories, requests for admission, depositions, and video depositions.
Page 7 | DISCOVERY
Exhibit binders should be provided for the Judge, Judicial Assistant, Opposing Counsel, and Reporter.
Binders should be provided for the Judge, Judicial Assistant, Opposing Counsel and Reporter.
Page 1 | UNLAWFUL DETAINERS - HEARINGS
Binders should be provided for the Judge, Judicial Assistant, Opposing Counsel and Reporter.
Binders should be provided for the Judge, Judicial Assistant, Opposing Counsel and Reporter.
Page 1 | UNLAWFUL DETAINERS - Exhibits
Exhibits must be in numbered notebooks, 5 copies submitted on first day of trial; exhibits numbered consecutively with dash for multi-page.
On the first day of trial, the parties are ordered to jointly submit five identical copies of the Exhibit Notebooks as hearing exhibits shall not be filed electronically. Those exhibits can be numbered consecutively in the lower, right-hand corner of each document. Each page should be given an exhibit number, so that if an exhibit contains multiple pages, it should have a "-"(dash) delineating each page. For example, if Exhibit 1 consists of 3 pages, it would be numbered as follows: Exhibit 1-1, 1-2, and 1-3.
Page 6 | FINAL STATUS CONFERENCE ORDER - 7
Filing Bundling Requirements
Jury trial binders are required, court trial binders discretionary; must be tabbed 3-ring binders with TOC, lodged 2 calendar days before FSC.
TRIAL BINDERS ARE REQUIRED FOR ALL JURY TRIALS BUT ARE DISCRETIONARY FOR ALL COURT TRIALS For all jury trials, the parties/counsel shall jointly prepare and lodge a trial binder with the Court at least two (2) calendar days before the FSC, containing the required trial documents, tabbed and organized into 3-ring binders, with a Table of Contents in the front of each binder, as follows: Tab A: Trial Briefs of all parties Tab B: Joint Witness List Tab C: Joint Statement to be Read to the Jury Tab D: Joint Exhibit List Tab E: Joint List of Jury Instructions (identifying the agreed upon and contested instructions) Tab F: Joint and Contested Jury Instructions Tab G: Joint and/or Contested Verdict Forms
Page 6 | FINAL STATUS CONFERENCE ORDER - 6
Please note that the trial binder and Motions in Limine binder(s) should be in separate notebooks.
Please note that the trial binder and Motions in Limine binder(s) should be in separate notebooks.
Page 6 | TRIAL BINDERS ARE REQUIRED FOR ALL JURY TRIALS BUT ARE DISCRETIONARY FOR ALL COURT TRIALS
The Court strongly prefers the parties to file a single joint exhibit notebook containing both parties' exhibits.
The Court strongly prefers the parties to file a joint exhibit notebook, containing both parties' exhibits in one notebook.
Page 7 | EXHIBITS
Pre-Motion Conference Requirements
Demurrers must comply with CCP §430.41 meet-and-confer requirements; non-compliant demurrers will be taken off calendar.
Demurrers: Must comply with CCP §430.41 meet-and-confer requirements. Demurrers filed without proper meet and confer will be taken off calendar.
Page 1 | UNLAWFUL DETAINERS - Demurrers
Parties must meet and confer or exchange information 15 court days before the Final Status Conference.
All parties shall meet and confer and/or exchange information at least fifteen (15) court days before the FSC as required by this order and Los Angeles County Court Rules, Rule 3.25(g).
Page 3 | FINAL STATUS CONFERENCE ORDER - 1
All parties must meet and confer on all motions in limine before filing them, and failure to do so may result in the Court refusing to hear the motions.
All parties must meet and confer on all motions in limine prior to filing said motions. Failure by any party or counsel to exchange or discuss any motion in limine may result in the refusal by the Court to hear any such motion in limine, pursuant to applicable court rules. Boilerplate or form motions in limine are disfavored. See "Motions in Limine Best Practices."
Page 4 | 5.a. MOTIONS IN LIMINE
Demurrers must comply with CCP §430.41 meet-and-confer requirements or they will be taken off calendar.
Demurrers: Must comply with CCP §430.41 meet-and-confer requirements. Demurrers filed without proper meet and confer will be taken off calendar.
Page 1 | UNLAWFUL DETAINERS - HEARINGS
Parties must meet and confer by phone or in person before filing discovery motions; letters or emails do not satisfy the requirement.
Discovery Motions: Strongly discouraged. Parties must meet and confer by phone or in person before filing. Letters/emails do not satisfy the meet-and-confer requirement.
Page 1 | UNLAWFUL DETAINERS - HEARINGS
Parties must meet and confer by phone or in person before filing discovery motions; letters/emails are insufficient.
Discovery Motions: Strongly discouraged. Parties must meet and confer by phone or in person before filing. Letters/emails do not satisfy the meet-and-confer requirement.
Page 1 | UNLAWFUL DETAINERS - Discovery Motions
Parties must meet and confer on all motions in limine before filing; failure may result in motion not being heard.
All parties must meet and confer on all motions in limine prior to filing said motions. Failure by any party or counsel to exchange or discuss any motion in limine may result in the refusal by the Court to hear any such motion in limine, pursuant to applicable court rules.
Page 4 | FINAL STATUS CONFERENCE ORDER - 5.a
Adjournment & Extension Requirements
Continuances or taking a case off calendar is only permitted by court order or stipulation.
Continuation/Off Calendar Policy: Per Court Order or by stipulation only.
Page 2 | MISCELLANEOUS
Continuances and requests to take matters off calendar are allowed only by court order or stipulation.
Continuation/Off Calendar Policy: Per Court Order or by stipulation only.
Page 2 | MISCELLANEOUS
Chambers Communication Rules
Telephone Number: (818) 407-2244 Courtroom Hours: 8:30 a.m. to 12:00 p.m. and 1:30 p.m. to 4:30 p.m.
Telephone Number: (818) 407-2244 Courtroom Hours: 8:30 a.m. to 12:00 p.m. and 1:30 p.m. to 4:30 p.m.
Page 1 | DEPARTMENT F44 RULES AND ORDERS
Parties are requested to immediately notify the Clerk by phone at (818) 407-2249 upon settlement or resolution of the action.
The parties are also requested to notify the Clerk of this Court immediately by phone, (818) 407-2249, upon settlement or resolution of the action.
Page 3 | FINAL STATUS CONFERENCE ORDER ¶ 2
The parties are also requested to notify the Clerk of this Court immediately by phone, (818) 407-2249, upon settlement or resolution of the action.
The parties are also requested to notify the Clerk of this Court immediately by phone, (818) 407-2249, upon settlement or resolution of the action.
Page 3 | FINAL STATUS CONFERENCE ORDER - 2