Judge Susan Bryant-Deason
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Anti-SLAPP Motions
Courtesy copies
- No Later Than 830 Am Day After Filing
- No Later Than 830 Am the Day After Filing
Demurrer Motions
Discovery Motions
Page & Word Limits4 rules
Trial briefs in Department J are limited to 10 pages.
- Trial brief
- Up to 10 pages
Court's wording
TRIAL BRIEFS. Trial briefs are required in jury trials and court trials in Department J. A trial brief should be no longer than 10 pages and contain a brief description of the facts, remaining cause of actions, parties' status (dismissed, defaulted, etc.), a brief description of defenses, a brief statement of the relief claimed, and calculation of damages sought.
Trial briefs in Department J are limited to 10 pages.
- Trial brief
- Up to 10 pages
Court's wording
Trial briefs are required in jury trials and court trials in Department J. A trial brief should be no longer than 10 pages and contain a brief description of the facts, remaining cause of actions, parties’ status (dismissed, defaulted, etc.), a brief description of defenses, a brief statement of the relief claimed, and calculation of damages sought.
Third, a joint brief – less than five-pages in length that summarizes the discovery dispute(s) at issue – shall be filed and provided to the Court at least two court days prior to the hearing.
- Joint brief
- Up to 5 pages
- Discovery motions
a joint brief – less than five-pages in length that summarizes the discovery dispute(s) at issue – shall be filed and provided to the Court at least two court days prior to the hearing.
- Joint brief
- Up to 5 pages
Document Format Requirements5 rules
The binders should be labeled with the name and case number for the case, and each binder shall be labeled "Judicial Assistant," "Judge," or "Witness."
Jury instructions must not be three-hole punched or placed in a binder and must be assembled into three stacks (agreed-upon; plaintiff's objected-to; defendant's objected-to).
- Jury instructions
Formatting
- •Not three-hole punched
- •Not placed in a binder
Court's wording
They are not to be three-hole punched and not to be placed in a binder. They are to be assembled into stacks: (1) an agreed-upon stack; (2) a stack, if any, of plaintiff's instructions to which defendant objects; and (3) a stack, if any, of defendant's instructions to which plaintiff objects.
Non-documentary exhibits shall be represented in a binder with a simple written description.
Jury instructions should use perforated forms with authorities above the perforation and boxes filled in, and all sets must be in the same format.
- Jury instructions
Formatting
- •All sets in the same format
Court's wording
Use the perforated forms as a guide for the instructions with any authorities place above perforation and with the boxes filled in. The final set of jury instructions will be printed on the perforated forms; however, all sets should be in the same format.
Bulk exhibits, e.g., voluminous medical records may not be permitted; however, counsel may separately mark and identify the specific items within the bulk exhibit. Blow-ups of portions of those exhibits may also be identified and marked consistently.
Document Filing Requirements16 rules
If all defendants have not been served, plaintiff or plaintiff's counsel must submit a declaration to the court five (5) days prior to the hearing explaining what efforts have been undertaken to accomplish service. CRC 3.110.
BRIEF JOINT STATEMENT OF THE CASE. Even if all parties agree to mini-opening statements; counsel shall meet and confer to prepare a brief, neutral description of the case to be read to the jury. LASCR 3.25(g)(4).
The parties shall prepare three (3) sets of exhibit binders, with an exhibit list in the front of each binder to serve as an index, and with divider tabs numbered by exhibit.
- Document
- Exhibit binders
Must include
- •Exhibit list
Joint witness list must be in columns with all expected witnesses, time estimates for direct/cross/redirect, column totals, and percipient/expert designation; witnesses not listed may be excluded or limited to impeachment or rebuttal.
Court's wording
JOINT WITNESS LIST. The list shall be with columns and include all witnesses actually expected to testify with time estimates for direct, cross-examination redirect examination. LASCR 3.25(g)(5). Do not repeat the name of a witness who will be called by more than one party. At the bottom of the list, total each column and all testimony. Specify if the witness is a percipient witness or an expert witness with the area of expertise. Any person not listed on the joint witness list shall be either excluded from testifying or his or her testimony shall be limited to only impeachment or rebuttal.
The following documents should be included in the joint trial binders and signed by each counsel for each party:
Joint exhibit list must have specified columns (Exhibit No., Description, Offered by, Stipulated, Date ID, Date Admit) with all exhibits exchanged and prenumbered; submission does not waive objections.
- Document
- Joint exhibit list
Must include
- •Exhibit list
Court's wording
JOINT EXHIBIT LIST. All exhibits must be exchanged and prenumbered. The parties shall prepare a joint exhibit list which shall have the following columns: Exhibit. No., Description, Offered by, Stipulated, Date ID, and Date Admit. Counsel must meet and confer prior to filing of the Joint Exhibit List in an effort to resolve any objections as to the foundation and admissibility of exhibits, with stipulations as to foundation and admissibility where feasible. Submission of the joint exhibit list shall not be deemed a waiver of any objection to the admission into evidence at trial of any exhibit on the list. LASCR 3.25(g)(6).
MILs may not be used to seek summary judgment, summary adjudication of issues, judgment on the pleadings, or bifurcation issues. LASC Rule 3.57.
Trial briefs are required in jury and court trials in Department J and must describe the facts, remaining causes of action, parties' status, defenses, relief claimed, and damages calculation.
Court's wording
Trial briefs are required in jury trials and court trials in Department J. A trial brief should be no longer than 10 pages and contain a brief description of the facts, remaining cause of actions, parties' status (dismissed, defaulted, etc.), a brief description of defenses, a brief statement of the relief claimed, and calculation of damages sought.
MILs must be assembled into binders containing: (1) the MIL; (2) opposition; and (3) replies to the MIL which are tabbed and indexed into a Table of Contents.
- Document
- Motion in limine
Must include
- •Table of contents
Parties must file joint filled-in sets of agreed and not-agreed CACI jury instructions with headings and no remaining brackets or blanks.
Court's wording
JOINT JURY INSTRUCTIONS: The parties shall file a joint filled in set of proposed agreed upon and a joint filled in set of proposed not agreed upon CACI jury instructions with headings, and no remaining brackets or blanks. LASCR 3.25(g)(7).
Counsel shall file and execute stipulations, if any, prior to trial regarding ultimate facts and issues and the admissibility of exhibits (i.e. foundation and/or authentication).
Before trial, copies of deposition transcripts or other discovery responses shall be lodged with the Court. LASCR 3.56.
If the parties do not provide a court reporter at trial, counsel will be required to provide the Court with a joint summary of the testimony and evidence, with exhibit numbers included, admitted on a daily basis by the morning following the testimony.
MILs should be numbered consecutively with a caption that identifies the subject of the motion.
- Document
- Motion in limine
Should include
- •Caption
sequential numerical order to facilitate reference to the document during interrogation of witnesses (e.g., 1-2, 1-2, 1-3). Counsel should agree in advance that their respective party will have a range of exhibit numbers, e.g., Plaintiff 1-99; Defendant 100-199.
JOINT PROPOSED VERDICT FORM. The parties should submit an agreed upon joint verdict form with interrogatories. LASCR 3.25(g)(8).
Filing & Service rules
Electronic Filing Rules
All parties are to comply with the First Amended General Order re Mandatory Electronic Filing for Civil dated May 3, 2019.
All parties are to comply with the First Amended General Order re Mandatory Electronic Filing for Civil dated May 3, 2019.
Civil cases
Page 1 | FILINGS
All parties must comply with mandatory electronic filing for civil cases; self-represented litigants are exempt and may file at the first floor filing window.
All parties are to comply with the First Amended General Order re Mandatory Electronic Filing for Civil dated May 3, 2019. Pursuant to California Rules of Court (“CRC”), rule 2.253(b)(2), self-represented litigants are exempt from mandatory electronic filing requirements and may file papers at the filing window located on the first floor of the courthouse.
Civil cases
Page 1 | FILINGS
Self-represented litigants are exempt from mandatory electronic filing under CRC 2.253(b)(2) and may file papers at the first-floor filing window.
Pursuant to California Rules of Court (“CRC”), rule 2.253(b)(2), self- represented litigants are exempt from mandatory electronic filing requirements and may file papers at the filing window located on the first floor of the courthouse.
Civil cases
Page 1 | FILINGS
Filing Timing and Cure Windows
A case management statement must be filed at least fifteen (15) days prior to the hearing as required by CRC 3.725(a).
A case management statement must be filed at least fifteen (15) days prior to the hearing as required by CRC 3.725(a).
Civil cases
Page 1 | CASE MANAGEMENT CONFERENCES
A case management statement must be filed at least 15 days before the case management conference hearing, per CRC 3.725(a).
A case management statement must be filed at least fifteen (15) days prior to the hearing as required by CRC 3.725(a).
Civil cases
Page 1 | CASE MANAGEMENT CONFERENCES
If not all defendants are served, plaintiff must submit a declaration of service efforts 5 days prior to case management conference hearing.
If all defendants have not been served, plaintiff or plaintiff’s counsel must submit a declaration to the court five (5) days prior to the hearing explaining what efforts have been undertaken to accomplish service. CRC 3.110.
Civil cases
Page 1 | CASE MANAGEMENT CONFERENCES
Ex parte applications must be electronically filed by 10:00 a.m. on the day before the hearing.
Ex Parte applications must be electronically filed and served by 10:00 a.m. on the day before the hearing.
Civil cases
Page 1 | EX PARTES
Plaintiff(s) are responsible for filing the joint trial documents unless the parties agree otherwise.
Plaintiff(s) shall be responsible for filing joint documents unless the parties agree otherwise.
Civil cases
Page 3 | FINAL STATUS CONFERENCE
Joint trial documents must be filed at least five court days before the final status conference.
PARTIES MUST MEET AND CONFER "IN PERSON", AND THEN FILE THE JOINT TRIAL DOCUMENTS AT LEAST FIVE COURT DAYS BEFORE THE FINAL STATUS CONFERENCE.
Civil cases
Page 3 | FINAL STATUS CONFERENCE
Motions in limine must be filed with timely statutory notice to be heard on the final status conference day.
(MILs) must be filed with timely statutory notice, so as to be heard on the day of the final status conference. LASCR 3.25(f)(2).
Civil cases
Page 4 | TRIAL DOCUMENTS
MILs must be filed with timely statutory notice so they can be heard on the day of the final status conference.
Motions in Limine (MILs) must be filed with timely statutory notice, so as to be heard on the day of the final status conference. LASCR 3.25(f)(2).
Civil cases
Page 4 | TRIAL DOCUMENTS
Deposition transcripts and discovery responses must be lodged with the court before trial.
Before trial, copies of deposition transcripts or other discovery responses shall be lodged with the Court. LASCR 3.56.
Civil cases
Page 6 | READING FROM DISCOVERY RESPONSES/DEPOSITION TRANSCRIPTS
IDC joint briefs must be filed at least 2 court days prior to the hearing.
a joint brief – less than five-pages in length that summarizes the discovery dispute(s) at issue – shall be filed and provided to the Court at least two court days prior to the hearing.
Civil cases
Page 8 | MOTIONS TO COMPEL FURTHER AND INFORMAL DISCOVERY CONFERENCES
The joint brief must be filed and provided to the Court at least two court days prior to the IDC hearing.
Third, a joint brief – less than five-pages in length that summarizes the discovery dispute(s) at issue – shall be filed and provided to the Court at least two court days prior to the hearing.
Civil cases
Page 8 | DEPARTMENT J - MOTIONS TO COMPEL FURTHER AND INFORMAL DISCOVERY CONFERENCES
Service and Proof of Service Rules
Ex parte applications must be electronically filed and served by 10:00 a.m. the day before the hearing.
Ex Parte applications must be electronically filed and served by 10:00 a.m. on the day before the hearing.
Civil cases
Page 1 | EX PARTES
Ex Parte applications must be electronically filed and served by 10:00 a.m. on the day before the hearing.
Ex Parte applications must be electronically filed and served by 10:00 a.m. on the day before the hearing.
Civil cases
Page 1 | EX PARTES
All defendants must be served with the complaint by the time of the case management conference.
All defendants must be served with the complaint by the case management conference.
Civil cases
Page 1 | CASE MANAGEMENT CONFERENCES
The Moving Party is ordered to provide notice of this Standing Order.
Moving Party is ordered to provide notice of this Standing Order.
Civil cases
Page 9 | MOTIONS TO COMPEL FURTHER AND INFORMAL DISCOVERY CONFERENCES
Filing Fees and Waivers
Proof of jury fee payment must be provided to the clerk no later than the next day before trial resumes.
Counsel will be billed daily for jury fees. Proof of payment must be provided to the clerk no later than the next day before trial can resume.
Civil cases
Page 5 | JURY SELECTION
Counsel are billed daily for jury fees and must provide proof of payment to the clerk no later than the next day, or trial cannot resume.
Counsel will be billed daily for jury fees. Proof of payment must be provided to the clerk no later than the next day before trial can resume.
Civil cases
Page 5 | OTHER TRIAL GUIDELINES (Joint Jury Instructions, Stipulations, Jury Selection)
Courtesy Copy Requirements
Courtesy copies are required for pleadings and motions (including attachments) of 26 pages or more.
Courtesy copies are required for: (1) any printed document required pursuant to a Standing or General Order; (2) pleadings and motions (including attachments) of 26 pages or more
Civil cases
Page 1 | FILINGS
Oppositions and replies to demurrers, anti-SLAPP, summary judgment, and motions to compel further discovery require courtesy copies.
any oppositions/replies to demurrers/anti-SLAPP, motions for summary judgement/adjudication, or motions to compel further discovery
Civil cases
Page 1 | FILINGS
Pleadings and motions (including attachments) of 26 or more pages require courtesy copies.
pleadings and motions (including attachments) of 26 pages or more
Civil cases
Page 1 | FILINGS
Motions for summary judgment or adjudication require courtesy copies.
motions for summary judgment/adjudication
Civil cases
Page 1 | FILINGS
Demurrers require courtesy copies.
demurrers
Civil cases
Page 1 | FILINGS
Courtesy copies of ex parte applications must be brought to the Court on the morning of the hearing.
Courtesy copies must be brought for the Court on the morning of the hearing.
Civil cases
Page 1 | EX PARTES
Ex parte applications require courtesy copies delivered to the court on the morning of the hearing.
Courtesy copies must be brought for the Court on the morning of the hearing.
Civil cases
Page 1 | EX PARTES
Courtesy copies are required for documents required by a standing or general order, pleadings and motions with points and authorities, demurrers, anti-SLAPP filings, MSJ/MSA motions, motions to compel further discovery, related oppositions/replies, and all trial documents.
Courtesy copies are required for: (1) any printed document required pursuant to a Standing or General Order; (2) pleadings and motions (including attachments) of 26 pages or more; (3) pleadings and motions that include points and authorities; (4) demurrers; (5) anti-SLAPP filings; (6) motions for summary judgment/adjudication. (7) motions to compel further discovery; (8) any oppositions/replies to demurrers/anti-SLAPP, motions for summary judgement/adjudication, or motions to compel further discovery; and (9) all trial documents as described below.
Civil cases
Page 1 | FILINGS
Motions to compel further discovery require courtesy copies.
motions to compel further discovery
Civil cases
Page 1 | FILINGS
Anti-SLAPP filings require courtesy copies.
anti-SLAPP filings
Civil cases
Page 1 | FILINGS
all trial documents as described below
all trial documents as described below
Civil cases
Page 1 | FILINGS
Department J requires courtesy copies of all filings to be delivered to the department no later than 8:30 a.m. the day after filing.
Department J is a courtesy copy courtroom. Courtesy copies of any filings are to be delivered to Department J no later than 8:30 a.m. the day after filing.
Civil cases
Page 2 | COURTESY COPIES
All courtesy copies for Department J must be delivered no later than 8:30 a.m. the day after filing.
Department J is a courtesy copy courtroom. Courtesy copies of any filings are to be delivered to Department J no later than 8:30 a.m. the day after filing.
Civil cases
Page 2 | COURTESY COPIES
Joint courtesy copies of all trial documents must be lodged in Department J five court days before the final status conference in JOINT three-ring binders (spines max 2.5 inches), with each document tabbed, paginated, and indexed.
Counsel must also lodge joint courtesy copies of all trial documents in Department J five (5) court days before the final status conference, placed in JOINT three ring binders with spines which do not exceed 2.5 inches. Each document shall be tabbed, paginated, and include an index in the front of each binder.
Civil cases
Page 3 | FINAL STATUS CONFERENCE
Trial document courtesy copies must be lodged 5 court days before final status conference in joint three-ring binders with spines ≤2.5 inches, tabbed, paginated, with index.
Counsel must also lodge joint courtesy copies of all trial documents in Department J five (5) court days before the final status conference, placed in JOINT three ring binders with spines which do not exceed 2.5 inches. Each document shall be tabbed, paginated, and include an index in the front of each binder.
Civil cases
Page 3 | FINAL STATUS CONFERENCE
Filing Bundling Requirements
MILs, oppositions, and replies must be assembled into binders that are tabbed and indexed with a Table of Contents.
MILs must be assembled into binders containing: (1) the MIL; (2) opposition; and (3) replies to the MIL which are tabbed and indexed into a Table of Contents.
Civil cases
Page 4 | TRIAL DOCUMENTS
Pre-Motion Conference Requirements
Ex parte applications related to law and motion matters require prior motion reservation in the Court Reservation System.
If the Ex Parte pertains to a Law and Motion matter, the Motion must be reserved in the Court Reservation System (or E-Court) prior to the Ex Parte filing.
Civil cases
Page 1 | EX PARTES
If an ex parte application pertains to a law and motion matter, the underlying motion must be reserved in the Court Reservation System (or E-Court) before the ex parte is filed.
If the Ex Parte pertains to a Law and Motion matter, the Motion must be reserved in the Court Reservation System (or E-Court) prior to the Ex Parte filing.
Civil cases
Page 1 | EX PARTES
A hearing date must be reserved through CRS for every motion; motions are heard Monday through Thursday at 8:30 a.m. and Friday at 9:00 a.m.
You must reserve a hearing date for any motion through CRS. The Court hears motions Monday through Thursday at 8:30 a.m., and on Friday at 9:00 a.m.
Civil cases
Page 2 | MOTIONS
All motions require a hearing date reserved through CRS; motions are heard Mon-Thu 8:30 a.m., Fri 9:00 a.m.
You must reserve a hearing date for any motion through CRS. The Court hears motions Monday through Thursday at 8:30 a.m., and on Friday at 9:00 a.m.
Civil cases
Page 2 | MOTIONS
Parties must meet and confer in person before filing joint trial documents.
PARTIES MUST MEET AND CONFER "IN PERSON", AND THEN FILE THE JOINT TRIAL DOCUMENTS AT LEAST FIVE COURT DAYS BEFORE THE FINAL STATUS CONFERENCE.
Civil cases
Page 3 | FINAL STATUS CONFERENCE
Counsel must meet and confer before filing the Joint Exhibit List to resolve foundation and admissibility objections, stipulating where feasible.
Counsel must meet and confer prior to filing of the Joint Exhibit List in an effort to resolve any objections as to the foundation and admissibility of exhibits, with stipulations as to foundation and admissibility where feasible.
Civil cases
Page 3 | TRIAL DOCUMENTS
Before a Motion to Compel Furthers is set for hearing, the moving party must confer with opposing counsel, obtain three available IDC dates (Tuesday or Thursday at 10:00 a.m. or 2:00 p.m.), contact the Court to schedule the IDC, and give notice.
First, prior to any Motion to Compel Furthers being set for hearing by the Court, the moving party shall confer with opposing counsel and obtain three available dates on either a Tuesday or a Thursday for an IDC at either 10:00 a.m. or 2:00 p.m., and then contact the Court to schedule the IDC. Moving party shall also give notice.
Civil cases
Page 8 | DEPARTMENT J - MOTIONS TO COMPEL FURTHER AND INFORMAL DISCOVERY CONFERENCES
Motions to compel further require an informal discovery conference scheduled before the motion is set for hearing.
prior to any Motion to Compel Furthers being set for hearing by the Court, the moving party shall confer with opposing counsel and obtain three available dates on either a Tuesday or a Thursday for an IDC at either 10:00 a.m. or 2:00 p.m., and then contact the Court to schedule the IDC.
Civil cases
Page 8 | MOTIONS TO COMPEL FURTHER AND INFORMAL DISCOVERY CONFERENCES
All parties are required to participate in an Informal Discovery Conference (IDC) before any Motion to Compel Furthers.
The Court has the power to “amend and control its process and orders so as to make them conform to law and justice” pursuant to CCP § 128(a)(8), and therefore, the Court issues the following standing order requiring all parties to participate in an IDC to resolve any Motion to Compel Furthers.
Civil cases
Page 8 | DEPARTMENT J - MOTIONS TO COMPEL FURTHER AND INFORMAL DISCOVERY CONFERENCES
Lead counsel or other designated counsel with full authority must appear for any scheduled IDC as directed by the Court.
Fourth, lead counsel (or other designated counsel for the parties with full authority) are ordered to appear for any scheduled IDC as directed by the Court.
Civil cases
Page 8 | DEPARTMENT J - MOTIONS TO COMPEL FURTHER AND INFORMAL DISCOVERY CONFERENCES
Counsel must meet and confer by telephone or video conference before the IDC to resolve all pending discovery disputes, in addition to the statutory meet and confer requirements, and should track when and how long they met.
Second, prior to the IDC, counsel must meet and confer, via telephone or video conference, in an effort to resolve all pending discovery disputes. Counsel are advised to keep track of when and for how long counsel met and conferred. This meet and confer is in addition to the standard meet and confer requirements set forth in the Code.
Civil cases
Page 8 | DEPARTMENT J - MOTIONS TO COMPEL FURTHER AND INFORMAL DISCOVERY CONFERENCES
Filed motions to compel further will not receive a hearing date until the informal discovery conference (IDC) process is completed.
The filed motions to compel further will not receive a hearing date until the IDC process is completed.
Civil cases
Page 9 | MOTIONS TO COMPEL FURTHER AND INFORMAL DISCOVERY CONFERENCES
If discovery disputes are resolved before the IDC date, the Moving Party must notify the Court and take both the IDC and any underlying motions to compel further off calendar as soon as possible.
If the parties resolve their discovery disputes before the IDC date, Moving Party shall notify the Court and take both the IDC and any underlying Motion to Compel Furthers off calendar as soon as possible.
Civil cases
Page 9 | MOTIONS TO COMPEL FURTHER AND INFORMAL DISCOVERY CONFERENCES
Parties must comply with the Court's Informal Discovery Conference Order, available at www.lacourt.ca.gov, for motions to compel further discovery and informal discovery conferences.
the parties are ordered to comply with the Court's Informal Discovery Conference Order, which may be found at www.lacourt.ca.gov.
Civil cases
Page 2 | MOTIONS TO COMPEL FURTHER AND INFORMAL DISCOVERY CONFERENCES
IDC sessions are informal and may not be transcribed without prior Court approval.
IDC sessions are informal and shall not be transcribed without prior Court approval.
Civil cases
Page 8 | DEPARTMENT J - MOTIONS TO COMPEL FURTHER AND INFORMAL DISCOVERY CONFERENCES
After the IDC process concludes, the Court will schedule hearing dates for any remaining motions to compel further.
At the conclusion of the IDC process, the Court will schedule hearing dates for any remaining motions to compel further.
Civil cases
Page 9 | MOTIONS TO COMPEL FURTHER AND INFORMAL DISCOVERY CONFERENCES
Adjournment & Extension Requirements
Trial continuance requests must be made via noticed motion or ex parte application when appropriate.
Requests for trial continuances must be made by noticed motion or ex parte application when appropriate.
Civil cases
Page 1 | CONTINUANCES
Requests for trial continuances must be made by noticed motion or, when appropriate, ex parte application.
Requests for trial continuances must be made by noticed motion or ex parte application when appropriate.
Civil cases
Page 1 | CONTINUANCES