Judge Virginia Keeny
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Exhibits
- 5 copies • First Day of Trial
Binding: Three Ring Binder
Adjournments
- Continuances of hearings or trials require a written stipulation showing good cause; absent stipulation, a continuance may be sought by noticed motion or ex parte application, and the court will not continue an opposed matter without good cause.
Request must include
Communication
Chambers
Phone
Chambers
Phone
Page & Word Limits1 rule
At least five court days prior to the IDC, the parties must separately file a brief of no more than 5 pages (without attachments), setting forth the issue(s) in dispute and their respective positions.
- IDC brief
- Up to 5 pages
Document Format Requirements7 rules
All parties to a motion must place the reservation number associated with the motion on each document associated with that motion.
All motions must comply with the California Code of Civil Procedure and California Rules of Court as to format and filing, and noncompliance may result in denial and/or sanctions.
Court's wording
The court expects counsel and self-represented parties to be familiar with and abide by the California Code of Civil Procedure and the California Rules of Court with respect to the format and filing of all motions. Failure to comply with the relevant sections or rules may result in denial of the motion and/or sanctions.
Bulk exhibits, e.g., voluminous medical records, will not be permitted. Counsel must separately mark and identify the specific items within a bulk exhibit.
All instructions must be submitted on perforated paper forms.
- File type
- Paper
- Jury instructions
Blow-ups of portions of exhibits should be identified and marked as sub-part A. Typically, a blow-up will not be admitted into evidence.
Counsel should agree in advance that their respective party will have a range of exhibit numbers, i.e., plaintiff 1-99; defendant 100-199. Each exhibit must be separately identified. Subparts to an exhibit, i.e., IA, IB, etc., must also be identified and listed separately.
Each page of a multi-page exhibit must be consecutively paginated.
Document Filing Requirements5 rules
If not all defendants have been served, plaintiff must file a declaration explaining the service efforts undertaken.
Court's wording
If all defendants have not been served, plaintiff or plaintiff's counsel must submit a declaration to the court at least five (5) days prior to the hearing explaining what efforts have been undertaken to accomplish service. CRC 3.110.
The parties' counsel and any self-represented parties shall work together to prepare and file a joint witness list, excluding impeachment and rebuttal witnesses. The joint witness list shall be organized with columns in the format set forth below:
Should the parties not provide a court reporter, the parties will be required to provide a joint summary of the testimony and evidence admitted each day for the court's use in preparing a settled statement for appeal purposes.
Each party must prepare an exhibit list with columns in the format set forth below:
Each counsel is responsible to submit those additional instructions requested by them and not agreed to by opposing counsel, edited to conform to the specifics of the case.
Filing & Service rules
Filing Timing and Cure Windows
A case management statement must be filed at least 15 days before the case management conference hearing.
A case management statement must be filed at least fifteen (15) days prior to the hearing as required by CRC 3.725(a).
Page 1 | CASE MANAGEMENT CONFERENCES
The declaration explaining service efforts must be submitted at least 5 days prior to the case management conference hearing.
If all defendants have not been served, plaintiff or plaintiff's counsel must submit a declaration to the court at least five (5) days prior to the hearing explaining what efforts have been undertaken to accomplish service. CRC 3.110.
Page 1 | CASE MANAGEMENT CONFERENCES
IDC briefs must be filed at least five court days before the Informal Discovery Conference.
At least five court days prior to the IDC, the parties must separately file a brief of no more than 5 pages (without attachments), setting forth the issue(s) in dispute and their respective positions.
Page 2 | INFORMAL DISCOVERY CONFERENCES
The moving party must immediately notify the court if a motion is going off-calendar or being continued, and must remove off-calendar motions from the court reservation management system.
Pursuant to CRC 3.l 304(b), the moving party on a motion must notify the court immediately if the motion is going off-calendar or is being continued. If the motion is taken off calendar, please remove the motion from the court reservation management system.
Page 2 | INFORMAL DISCOVERY CONFERENCES
Motions in limine must be filed with the statutorily required notice for hearing at the final status conference and must comply with SCLAC Rule 3.57.
Pursuant to SCLAC Rule 3.25(f)(2), motions in limine must be filed with the appropriate statutory notice for hearing at the final status conference. Motions in limine must comply with SCLAC Rule 3.57.
Page 3 | FINAL STATUS CONFERENCE
Trial documents (statement of the case, exhibit list, witness list, jury instructions, verdict form) must be filed with the court five days before the final status conference.
Pursuant to SCLAC Rule 3.25(f)(l), trial documents, including a statement of the case, exhibit list, witness list, jury instructions and verdict form must be filed with the court and served on opposing counsel five (5) days prior to the final status conference.
Page 3 | FINAL STATUS CONFERENCE
The joint summary of the prior day's testimony must be submitted no later than 8:30 a.m. on the following day of trial.
The parties must submit the joint summary for the prior day's testimony no later than 8:30 a.m. on the following day of trial.
Page 3 | COURT REPORTERS
Plaintiff's counsel must submit the parties' jointly agreed jury instructions, edited to conform to the specifics of the case, on the first day of trial.
On the first day of trial, plaintiff's counsel will be required to submit those jury instructions that the parties have jointly agreed to, edited to conform to the specifics of the case.
Page 5 | JURY INSTRUCTIONS
A fee-waiver party is entitled to a court reporter if the request is made on form LACIV269 at least 10 calendar days before the hearing.
A party with a fee waiver is entitled to a court reporter pursuant to Cal. Rule of Court 2.956(b)(3), if a request is made at least 10 calendar days prior to the hearing on court form LACIV269.
Page 2 | COURT REPORTERS
Counsel are urged to agree on a special verdict form to be submitted with the other trial documents five days before the final status conference; if they cannot agree, the Court will prepare a general verdict form.
Counsel are urged to agree upon a special verdict form to be submitted to the court with the other trial documents five (5) days prior to the final status conference. If counsel cannot agree, the Court will prepare a general verdict form.
Page 5 | JURY INSTRUCTIONS
Service and Proof of Service Rules
All defendants must be served with the complaint no later than the case management conference.
All defendants must be served with the complaint by the case management conference.
Page 1 | CASE MANAGEMENT CONFERENCES
Trial documents must be served on opposing counsel five days before the final status conference.
Pursuant to SCLAC Rule 3.25(f)(l), trial documents, including a statement of the case, exhibit list, witness list, jury instructions and verdict form must be filed with the court and served on opposing counsel five (5) days prior to the final status conference.
Page 3 | FINAL STATUS CONFERENCE
Counsel must exchange exhibits at the final status conference unless the court and counsel agree otherwise.
Counsel are ordered to exchange exhibits at the time of the Final Status Conference unless the court and counsel agree otherwise.
Page 4 | EXHIBITS
Filing Fees and Waivers
Jury fees should be posted by the time of the case management conference under CCP Section 631.
Jury fees should be posted by the time of the case management conference pursuant to CCP Section 631.
Page 1 | CASE MANAGEMENT CONFERENCES
Courtesy Copy Requirements
Typically, at least five (5) copies of all exhibits, in a 3-ring binder, should be provided on the first day of trial. The original exhibits, those that will be provided to the jury, will be placed in the custody of the judicial assistant. Additional binders must be provided for: (1) the Court; (2) the witness; (3) opposing counsel; and (4) yourself.
Typically, at least five (5) copies of all exhibits, in a 3-ring binder, should be provided on the first day of trial. The original exhibits, those that will be provided to the jury, will be placed in the custody of the judicial assistant. Additional binders must be provided for: (1) the Court; (2) the witness; (3) opposing counsel; and (4) yourself.
Page 4 | EXHIBITS
Pre-Motion Conference Requirements
A hearing date must be reserved through the court reservation system for every motion.
You must reserve a hearing date for any motion through the court reservation system.
Page 2 | MOTIONS
An Informal Discovery Conference is not required before filing a motion to compel, but parties must meet and confer first and may request an IDC if the dispute is unresolved.
The court does not require that parties schedule an Informal Discovery Conference (IDC) before they file a motion to compel. Parties are required to meet and confer prior to filing a motion to compel and they may request an IDC with the Court if they are unable to resolve their discovery dispute.
Page 2 | INFORMAL DISCOVERY CONFERENCES
Adjournment & Extension Requirements
Continuances of hearings or trials require a written stipulation showing good cause; absent stipulation, a continuance may be sought by noticed motion or ex parte application, and the court will not continue an opposed matter without good cause.
Requests for continuances of hearings or trials may be considered upon written stipulation and order. The stipulation must set forth the grounds showing good cause for a continuance. If there is no stipulation, any party may seek a continuance by noticed motion or ex parte application. The court will not continue a hearing or trial if there is opposition without a showing of good cause.
Page 1 | CONTINUANCES
Chambers Communication Rules
To schedule an IDC, the parties must meet and confer and jointly telephone the courtroom; IDCs are held Mondays at 1:30 p.m. subject to calendar availability.
To schedule an IDC, counsel or parties must meet and confer on a date and jointly telephone the courtroom to request a mutually agreeable date. IDCs are conducted at 1:30 p.m. on Mondays, if availability exists on the Court's calendar.
Page 2 | INFORMAL DISCOVERY CONFERENCES
Tentative rulings are posted the afternoon before the hearing, and counsel may accept the tentative by emailing SMCDept529@lacourt.ca.gov by 8:00 a.m. on the hearing day with the case name/number and all counsel copied; if all counsel submit, the tentative becomes the final order.
The court will post a tentative ruling on most motions the afternoon prior to the hearing. Counsel may submit to the court's tentative ruling by emailing the court at SMCDept529@lacourt.ca.gov by 8:00 a.m. the day of the hearing, indicating the case name and number and copying all counsel on the email. If all counsel submit, the court will adopt the tentative as the final order.
Page 2 | MOTIONS
Parties experiencing LACourtConnect connection or audio problems must telephone Department 529 and advise the courtroom assistant/judicial assistant.
If you are having trouble connecting through LACourtConnect or cannot be heard by the court, telephone Department 529 and advise the CA/JA of the problem.
Page 2 | TELEPHONIC/REMOTE APPEARANCES