Judge Victor Avila

1. TRIAL BRIEFS: File and lodge five (5) court days before the FSC and shall not exceed fifteen (15) pages. Trial briefs are mandatory in all cases and shall include: 1. A brief description of the claims and defenses presented and the issues to be decided. 2. Statement of ultimate facts or issues to which you will stipulate.

Documents must be electronically filed in PDF, text searchable form. Attachments to primary documents including depositions, declarations, exhibits (including exhibits to declarations), transcripts (including excerpts), points and authorities, citations and supporting brief must be bookmarked and hyper linked.

The parties’ counsel and any self-represented parties shall work together to jointly prepare four sets of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) (“Exhibit Binders”).

The Motions in Limine Binder shall include one-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders, tabbed in numerical order with the opposition papers and reply papers for each motion placed directly behind the moving papers with a colored sheet of paper separating the moving, opposition, and reply papers.

No later than five court days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department B a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following (for trials by the court without a jury, the Trial Binder shall include only the documents listed under Tabs A, B, C, H, and I):

1. TRIAL BRIEFS: File and lodge five (5) court days before the FSC and shall not exceed fifteen (15) pages. Trial briefs are mandatory in all cases and shall include: 1. A brief description of the claims and defenses presented and the issues to be decided. 2. Statement of ultimate facts or issues to which you will stipulate.

No later than 11 calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall meet and confer to do the following: (1) discuss and prepare the documents required in Sections 2.B-H below, and the Motions in Limine Binder, Exhibit Binders, and Trial Binder required in Sections 3-5 below, (2) discuss and make a good faith effort to stipulate to the authenticity and admissibility of each trial exhibit, (3) discuss and make a good faith effort to stipulate to resolve each motion in limine, (4) discuss and make a good faith effort to stipulate to ultimate facts and legal issues, and (5) discuss and make a good faith effort to settle the case.

4. JOINT WITNESS LIST: File and lodge five (5) court days before the FSC The parties’ counsel and any self-represented parties shall meet and confer to prepare and file a joint list of all witnesses whom any party intends to call at trial, excluding impeachment and rebuttal witnesses.

3. Those facts established by admissions in pleadings, by discovery and/or stipulation by counsel. 4. All contested issues of fact. 5. All contested issues of law, together with points and authorities supporting the party’s position. 6. A list of major evidentiary issues anticipated and points and authorities in support of the party’s position. 7. A detailed statement of the relief claimed including a breakdown of the elements of damages claimed. 8. Any other information that will assist the Court. 9. Time estimate of opening statement. 10. Confirm whether the party and/or counsel intends to make a mini opening statement (applies only to jury trials).

2. STATEMENT OF THE CASE: File and lodge five (5) court days before the FSC Counsel shall meet and confer to prepare a JOINT short, non-argumentative written statement of the case suitable to be read to the jury and shall lodge the Statement of the Case five (5) court days prior to the FSC.

5. JOINT EXHIBIT LIST: File and lodge five (5) court days before the FSC The parties’ counsel and any self-represented parties shall meet and confer to prepare and file a joint exhibit list organized with columns (in the format set forth below) which state, as to each exhibit any party intends to offer

The joint witness list shall be organized with columns (in the format set forth below) which state (1) the name of each witness (in alphabetical order), if the witness is being called to testify as an expert, and any special requirements or accommodations needed for the witness (e.g., interpreter), (2) the party calling the witness, (3) whether the witness is actually expected to testify, (4) a brief description of the witness’s expected testimony, (5) an estimate of the length of direct examination (in hours), (6) an estimate of the length of cross-examination (in hours), and (7) the total estimated length of examination (in hours).

For jury trials, the parties’ counsel and any self-represented parties shall meet and confer to prepare a complete set of full-text proposed jury instructions, editing all proposed Judicial Council of California Civil Jury Instructions (“CACI”) instructions, inserting party names, and eliminating blanks and other irrelevant or inapplicable material.

For jury trials, the parties’ counsel and any self-represented parties shall meet and confer to prepare and file a joint list of proposed jury instructions (in the format set forth below) which states, as to each proposed jury instruction: (1) the jury instruction number (listed in numerical order), (2) the title of the jury instruction, (3) the party requesting the jury instruction, (4) whether the jury instruction is agreed upon or contested, (5) a concise statement of any objection, and (6) whether the jury instruction was given by the court.

In the joint chart, each designating party’s designations of deposition or former testimony shall include columns which state: (1) the designation number and name of the witness, (2) the date and type of testimony (e.g., deposition or trial testimony), (3) the page and line designations of the deposition or former testimony requested to be used, (4) any objections, (5) whether the other party has counter-designated any additional deposition or former testimony of the witness that relates to the designation, and, if so, the designation number of the counter-designation, and (6) the court’s ruling.

In the joint chart, each counter-designating party’s counter-designations of additional deposition or former testimony of the witness that relates to the designations shall include columns which state: (1) the designation number and name of the witness, (2) the date and type of testimony (e.g., deposition or trial testimony), (3) the page and line counter-designations of the deposition or former testimony requested to be used, (4) any objections, (5) the designation number of the other party’s designation to which the counter-designation relates, and (6) the court’s ruling.

The parties shall attach copies of the pages of the transcripts of the deposition or former testimony they are designating or counter-designating to the Joint Chart of Page and Line Designations for Deposition and Former Testimony, with numbered tabs separating each deposition or trial transcript.

The parties’ counsel and any self- represented parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the Exhibit Binders.

The parties’ counsel and any self represented parties shall comply with the statutory notice provisions of Code of Civil Procedure section 1005 and file declarations that comply with the requirements of Los Angeles County Court Rule 3.57, subdivision (a).

The parties shall organize proposed jury instructions into groups behind Tab F in the following order (labeled by cover sheets): (1) agreed-upon instructions, (2) plaintiff’s requested instructions to which defendant objects, and (3) defendant’s requested instructions to which plaintiff objects.