Judge Teresa A. Beaudet
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Courtesy Copies
Ex Parte Application
Filing with Points and Authorities, Filing Over 15 Pages
- On Date of Filing or Next Business Day If Efile on Holiday or Weekend
Filings > 30 pages
- 16 Court Days Before Hearing
Motion, Opposition, Reply
- Upon Filing
Document Format Requirements10 rules
Do not attach any documents, do not type in miniscule font and do not use more than the allotted space on the IDC form to describe the dispute.
- IDC form
Formatting
- •Do not attach any documents
- •Do not type in miniscule font
Your motion could be rejected for failure to comply with the rules regarding tabbing.
Simultaneously with the filing of the Trial Documents, the parties also must lodge by 4 p.m., an indexed and tabbed three-ring Trial Readiness Binder containing copies of all of the Trial Documents and the motions in limine, and indexed and tabbed Exhibit Binders.
- Binding
- Three-ring binder
- Trial readiness binder
- Exhibit binders
For jury trials, the Joint List of Stipulated Facts must be in a form and tone (i.e., not “legalese”) that can be read to the jury as stipulated facts.
The parties must prepare instructions in a format ready for submission to the jury with the instruction number, title and text only (i.e., there should be no boxes or other indication on the printed instruction itself as to the requesting party, revised date, tear offs, etc.)
For trial, the parties must jointly prepare three sets of exhibits in numerical order in three-ring binders, with tabs, internal pagination, and markings matching the joint exhibit list.
- Binding
- Three-ring binder
- Exhibits
Formatting
- •Organize exhibits numerically
Court's wording
For the trial, the parties must jointly prepare three sets of tabbed, internally paginated and properly marked exhibits (i.e., the exhibit numbers must correspond to those on the joint exhibit list), organized numerically in three- ring binders (i.e., one for the witness, one for the courtroom clerk, and one for the Court).
PLEASE PROVIDE TABS FOR ALL DECLARATIONS AND EXHIBITS ATTACHED TO MOTIONS.
The instructions should be prepared in WORD and, when final, emailed to Dept. 508.
The proposed verdict form should be prepared in WORD and, when final, emailed to Dept. 508.
If the motions in limine are too voluminous to fit in the Trial Readiness Binder, they may be filed in a separate binder properly labeled with the case name and with an index and tabs.
- Binding
- Binder
- Motion in limine
Document Filing Requirements31 rules
The declarations regarding notice must contain all the information listed in CRC 3.1204(b).
Each party must use a distinct numbering or lettering designation for its motions in limine to avoid duplication and confusion.
Court's wording
THE PARTIES MUST ASSIGN DIFFERENT NUMBERS OR LETTERS TO THEIR MOTIONS IN LIMINE (e.g., Plaintiff’s motions in limine may be numbered 1-5; Defendant’s motions in limine may be lettered A-E; additional parties may use double numbers or letters or some other agreed-upon designation to avoid duplication and confusion.)
The parties must file a Joint Statement of Relief Requested, including itemization of all elements of damages claimed, if any, by each party, and the amount; no itemization is required for emotional distress and punitive damages.
The parties must file a joint list of all relevant facts not in dispute.
The Trial Documents must comply with LA Superior Court Rule 3.25 (f)-(h).
Trial counsel must attend the FSC.
At the end of the list, the parties must provide a total time for the witnesses plus the time estimates for jury selection, opening and closing.
The parties must file a Joint List of Proposed Jury Instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any.
For jury trials, the parties must file a Joint Written Statement of the Case for the Court to read to the jury panel.
Unless good cause is shown, no undisclosed witnesses may be called.
The Joint List of Jury Instructions must include a space by each instruction for the Court to indicate whether the instruction was given, not given or given as modified. It must also provide a place for the Court to date and sign the list.
The parties must file a Joint Witness List, identifying the witnesses each party intends to call, except for impeachment witnesses.
The parties must identify any potential witness scheduling issues and special requirements.
If for some reason the parties cannot agree upon the wording of a sentence, they must put the alternative versions of the sentence in brackets and bold and the Court will rule on it.
The joint witness list must identify each testifying witness’s name and type and estimate the time for each examination and for the witness overall.
Court's wording
The Joint Witness List must include the name of each witness who is actually going to testify, whether that person is a fact witness or an expert witness, and the expected length of the direct and redirect, the cross-examination and recross-examination, and the total time for that witness.
If good-faith efforts do not resolve verdict-form differences, each party must bracket and bold disputed wording or separately file a proposed form when too much is disputed.
Court's wording
If, after making a good faith effort to resolve differences, the parties cannot agree on the verdict form, each party must either (a) insert the disputed wording in bold brackets, or (b) separately file a proposed verdict form if too much of the verdict form is in dispute (e.g., because a ruling on a motion in limine is needed to resolve the issue).
The parties must prepare a complete set of full-text proposed Jury Instructions, editing all proposed Judicial Council of California Civil Jury Instructions (“CACI”) to insert party names and eliminate blanks and irrelevant material.
The parties must file a proposed Joint General Verdict form or a proposed Joint Special Verdict form (with interrogatories) acceptable to all sides.
The initial exchange of the Joint Exhibit List must include a column in which the parties indicate whether the particular exhibit may be admitted without objection or, if not, the ground for the objection.
The parties must mark all nondocumentary exhibits (e.g. a CD) and insert a brief written description of the exhibit behind the corresponding numerical tab in the exhibit binder.
If either party requests a jury questionnaire, it must be exchanged sufficiently in advance of the FSC so the opposing parties may propose additional questions. The questionnaire filed must be a joint questionnaire.
Any exhibit or other visual or auditory aid that counsel wishes to use in opening statement must be shown to each other party at or in advance of the FSC.
Please prepare written oppositions.
Counsel are ordered to have available to them whatever materials are needed to make the IDC session productive and successful.
When identifying deposition testimony, include and mark both the question and answer, even if intervening colloquy separates them by five pages.
Court's wording
Be sure to include a reference to both a question and an answer when identifying deposition testimony (not just the answer) and be sure to mark the question and answer even if the question appears five pages before the answer as a result of intervening colloquy.
The joint case statement should be one or two paragraphs describing the nature of the case and each party’s basic claim.
Court's wording
This statement should be no more than one or two paragraphs that simply inform the jury panel of the nature of the case and each party’s basic claim (e.g., a contract dispute, a discrimination claim, etc.)
The initial exhibit-list exchange must occur sufficiently before the final list is due to allow a serious, good-faith meet and confer on all exhibit objections.
Court's wording
This exchange must take place sufficiently in advance of the day that the final Joint Exhibit List is to be filed and included in the Trial Readiness Binder so the parties will have had time to meet and confer in a serious and good faith effort to resolve all objections to each exhibit to be offered at trial.
The parties are encouraged to include a stipulation for the Court to retain jurisdiction pursuant to CCP section 664.6 if the settlement is conditional.
The parties may arrange for a privately retained court reporter at hearings.
Each party may file a Trial Brief succinctly identifying the following:
The parties are encouraged to accommodate each other with regard to taking witnesses out of order if reasonably necessary.
Filing & Service rules
Filing Timing and Cure Windows
When a matter is resolved by an executed settlement agreement, the parties must promptly file a Notice of Settlement under Rule 3.1385.
If a matter is resolved by an executed settlement agreement, the parties must promptly file a Notice of Settlement pursuant to Rule 3.1385 of the California Rules of Court.
Civil cases
Page 1 | Initial Case Management Conference (“CMC”)
The party seeking additional discovery must file the one-page IDC form seven days before the IDC; the responding party may file a response on the same form three days before it.
The party seeking the additional discovery must file Dept. 508’s one-page IDC form in the department seven days prior to the IDC, and the responding party may file the same form in the department setting forth a response three days prior to the IDC.
Civil cases
Page 2 | Discovery Issues
Except for motions in limine, the parties must meet and confer and file and serve the Trial Documents on the fifth court day before the FSC.
Except as to motions in limine, which must be filed and served per code, the parties have a joint obligation to meet and confer, and to file and serve on the fifth court day prior to the FSC, the documents described below (the “Trial Documents”).
Civil cases
Page 6 | Trial Documents for the FSC
The parties must lodge one complete set of all exhibit binders by 4 p.m. five court days before the FSC.
Five court days prior to the FSC, the parties must lodge by 4 p.m. one complete set of all exhibit binders.
Civil cases
Page 9 | Joint Exhibit Binders
Service and Proof of Service Rules
Notice of an ex parte application may be given by the listed methods, including mail when time permits five days of mail time.
Notice must be given via telephone, in person, electronically if permitted by the CCP or CRC, by other agreed-upon methods evidenced in writing, or, if time permits, with five days of mail time.
Civil cases
Page 1 | Ex Parte Applications
Motions in limine and motions affecting the order of proof must be filed and served with sufficient CCP § 1005 notice to be heard by the FSC at the latest.
All motions in limine and motions that affect the order of proof, such as motions pursuant to CCP Sections 597 (trial of special defenses), 598 (change in the order of proof or bifurcation of the trial), and 1048 (consolidation or severance), must be filed and served with sufficient statutory notice under CCP Section 1005 so that they may be heard no later than at the FSC.
Civil cases
Page 5 | All Motions
Any objections to the proposed jury instructions or verdict form must be filed and served.
The parties must file and serve their objections, if any, to the proposed jury instructions and to the proposed verdict form.
Civil cases
Page 8 | The FSC: Trial Documents and Exhibit Binders
A party’s failure to attend the ex parte hearing does not imply waiver of an objection to notice.
If the party does not attend the ex parte hearing, no waiver is implied.
Civil cases
Page 1 | Ex Parte Applications
A party waives objections to email, text, or facsimile notice by failing to raise them in the opposition.
A party is deemed to have waived any objection to email, text or facsimile notice if no objection is raised in the opposition to the application.
Civil cases
Page 1 | Ex Parte Applications
Filing Fees and Waivers
Motion fees must be paid when the online reservation is made.
Motion fee payments are required at the time reservations are made online.
Civil cases
Page 3 | Pleading and Pretrial Motions
Courtesy Copy Requirements
Lodge courtesy conformed copies in Department 508 on the filing date for filings with points and authorities or over 15 pages, or on the next business day if e-filed on a holiday or weekend.
Courtesy conformed copies of any filings with a points and authorities or that exceed 15 pages must be lodged in Dept. 508 on the date of filing or, if the filing is efiled on a holiday or weekend, on the next business day.
Civil cases
Page 3 | Pleading and Pretrial Motions
When filing an MSJ/MSA reply brief, the moving party must concurrently lodge indexed and tabbed binders or spiral-bound compilations of the moving, opposing, and reply papers and their supporting papers.
Concurrently with the filing of the reply brief on an MSJ/MSA, the moving party must lodge binders or spiral-bound compilations containing the moving and supporting papers, the opposing and supporting papers and the reply and supporting papers, all indexed and tabbed.
Civil cases
Page 4 | Motions for Summary Judgment or Summary Adjudication
Courtesy copies of ex parte papers should be delivered to the courtroom.
Please deliver courtesy copies of your papers to the courtroom.
Civil cases
Page 1 | Ex Parte Applications
If a motion is filed more than 30 calendar days before its hearing, wait until 16 court days before the hearing to file its courtesy copies.
If your motion has been filed more than 30 calendar days before the hearing date, please wait to file the courtesy copies of the motion until 16 court days before the hearing.
Civil cases
Page 5 | All Motions
Courtesy copies should be provided for all motion, opposition, and reply papers.
Please provide courtesy copies of all motion, opposition and reply papers.
Civil cases
Page 5 | All Motions
Courtesy copies are not required in addition to the spiral-bound or binder compilations.
It is not necessary to file courtesy copies in addition to the spiral-bound (or binder) compilations.
Civil cases
Page 5
Pre-Motion Conference Requirements
Parties wishing to bring any discovery motion, including a motion to compel, must complete the prescribed meet-and-confer process.
Pursuant to the Court’s power to “amend and control its process and orders so as to make them conform to law and justice” (CCP § 128(a)(8)), the Court orders that parties who wish to bring any discovery motion (including motions to compel) must participate in the meet and confer process outlined below.
Civil cases
Page 2 | Discovery Issues
Counsel with full authority must first meet and confer in person, by telephone, or by videoconference; written messages without a phone call do not satisfy the requirement.
First, the counsel for the parties with full authority must meet and confer in person or via telephone or videoconference to comply with the code requirements to “meet and confer.” Sending letters, emails or text messages without a phone call does not comply with the code requirements.
Civil cases
Page 2 | Discovery Issues
If the parties’ initial conference is unsuccessful, they must participate in an IDC with the Court, and lead or designated counsel with full authority must attend.
Second, if the in-person, telephone or video conference is not successful, then the parties must participate in another meet and confer with the Court in the form of what is referred to as an “informal discovery conference” or “IDC.” Lead or other designated counsel for the parties with full authority are ordered to participate in the IDC.
Civil cases
Page 2 | Discovery Issues
If a discovery motion is filed before the IDC is completed, the moving party must promptly reserve an IDC after consulting opposing counsel and, if needed, continue the motion hearing until after the IDC.
If a motion has been filed (which the Court strongly discourages doing before an IDC has been completed), after consulting with opposing counsel regarding available dates, the moving party must make a prompt reservation for the IDC using the Court’s online reservation system and, if necessary, continue the hearing on the motion to a date after the IDC.
Civil cases
Page 2 | Discovery Issues
Before demurrers, motions to strike, and motions for judgment on the pleadings, the parties must meet and confer in person, by telephone, or by video conference—not by email, text, or letter—and file the required declaration.
The parties are reminded to “meet and confer” in person, via telephone or video conference (not via email, texts or letters) regarding demurrers, motions to strike and motions for judgment on the pleadings and to file the requisite declaration re same with the pleading motions.
Civil cases
Page 3 | Pleading and Pretrial Motions
If the Court finds that the parties collectively have raised more than a handful of objections (10 or less), the Court may order the parties to meet and confer in person or via telephone to resolve the objections before the Court considers the motion.
If the Court finds that the parties collectively have raised more than a handful of objections (10 or less), the Court may order the parties to meet and confer in person or via telephone to resolve the objections before the Court considers the motion.
Civil cases
Page 4 | Evidence
The parties are encouraged to meet and confer before filing other motions, including summary judgment and summary adjudication motions.
The parties encouraged to meet and confer prior to filing any other motions, including summary judgment and summary adjudication motions.
Civil cases
Page 3 | Pleading and Pretrial Motions
Adjournment & Extension Requirements
Parties should seek timely written extensions for deadline-bound discovery motions, and such extensions should be granted to allow an IDC.
Parties should seek timely written extensions for discovery motions that have deadlines (e.g., motions to compel further) and such extensions should be granted so an IDC can take place.
Civil cases
Page 2 | Discovery Issues
Chambers Communication Rules
Parties must obtain and reserve a motion hearing date and time through the online Court Reservation System, and motions are heard Monday through Friday.
Motions are heard on Monday through Friday. Parties must obtain and reserve a motion hearing date and time via the online Court Reservation System (CRS) on the L. A. Superior Court website.
Civil cases
Page 3 | Pleading and Pretrial Motions
If motions in limine will be numerous and time-consuming, the parties must contact the Dept. 508 courtroom assistant to schedule a separate hearing.
If the motions in limine will be numerous and time-consuming, the parties must contact the courtroom assistant in Dept. 508 to schedule a separate hearing for the motions in limine.
Civil cases
Page 5 | All Motions
Do not call the courtroom to reserve a motion date.
Please do not call the courtroom to reserve a motion date.
Civil cases
Page 3 | Pleading and Pretrial Motions