Judge William A. Crowfoot
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Courtesy Copies
Exhibits
- 1 copy • At Final Status Conference
Joint Statement
- 1 copy
Opposition
- 1 copy
Document Format Requirements13 rules
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 tab separating the moving, opposition, and reply papers.
- Binding
- Tabbed three-ring binder
- Motions in limine binder
Formatting
- •Tabbed in numerical order
Parties must jointly prepare four sets of tabbed, paginated, numerically organized exhibits in three-ring binders, with one-sided documentary exhibit copies.
- Binding
- Tabbed three-ring binder
- Exhibits
Formatting
- •Exhibits internally paginated by document
- •Exhibits properly marked and organized numerically
Court's wording
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”). Copies of documentary exhibits shall be one-sided copies.
consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents
- Binding
- Tabbed three-ring binder
- Trial binder
Formatting
- •One-sided, conformed copies
The parties shall organize proposed jury instructions into groups behind Tab F in the following order (labeled by cover sheets): (1) the agreed-upon instructions; (2) plaintiff’s requested instructions to which defendant objects; and (3) defendant’s requested instructions to which plaintiff objects.
- Jury instructions
Formatting
- •Label each group with cover sheets
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 tabs separating the moving, opposition, and reply
- Binding
- Tabbed three-ring binder
- Motions in limine binder
Formatting
- •May be organized in one or more three-ring binders
- •Tabbed in numerical order
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”).
- Binding
- Tabbed three-ring binder
- Exhibits
- Exhibit binder
Formatting
- •Exhibits must be internally paginated by document
- •Joint preparation by counsel and self-represented parties
The jury instructions should be prepared in a Word document ready for distribution to the jury.
- File type
- Word
- Jury instructions
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:
- Binding
- Tabbed three-ring binder
- Trial binder
Formatting
- •One-sided, conformed copies
- •Table of contents required
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.
- Exhibits
- Exhibit binder
Formatting
- •Mark all non-documentary exhibits
indicating the tab number and the caption title of each such motion or opposition included in the binder. This index makes it easier for the parties, the Court, and the Court’s Judicial Assistant to keep track of the MILs.
Copies of documentary exhibits shall be one-sided copies.
The parties’ counsel and any self-represented parties shall also place the court’s yellow evidence tags (with only the case number and exhibit number filled in) on each exhibit in the Judicial Assistant’s copy of the Exhibit Binder.
In most cases, the Court will expect the parties to prepare a sufficient number of copies of the jury instructions to be able to give one to each juror and alternate.
Document Filing Requirements44 rules
The parties must comply with California Rules of Court, rule 3.722, et seq., and Local Rule 3.25 in connection with such conferences.
The Court may from time to time after the Case Management Conference schedule status conferences regarding mediation and discovery and order the parties to submit a joint statement informing the Court whether mediation or other efforts to resolve the case have occurred, and providing the Court with a discovery plan for the remaining discovery in the case. ... The failure to timely file a joint statement will result in the Court scheduling an order to show cause for sanctions.
Ex parte applicants must comply with the requirements of California Rules of Court, rules 3.1200-3.1207, submit a proposed order, and pay the filing fee before appearing in court.
- Document
- Ex parte application
Must include
- •Proposed order
In any trial conducted without the benefit of a court reporter, the parties will be required to prepare a joint settled statement at the end of each day of trial to be filed with the Court prior to the commencement of the following day of trial.
The parties must also file a proposed order that the Court may issue granting or denying the request for an IDC, with a blank for the Court to set the date and time of the IDC.
- Document
- IDC request stipulation
Must include
- •Proposed order
An IDC request must be made by joint stipulation that briefly summarizes the discovery at issue and explains the parties' meet-and-confer efforts beyond the exchange of correspondence.
Court's wording
To request an informal discovery conference, the parties must file a stipulation jointly requesting the IDC. The stipulation should briefly summarize the discovery at issue and explain what efforts the parties have made to meet and confer, beyond the exchange of correspondence, to narrow the scope of their discovery dispute.
The Joint Statement must use a four-column format: discovery request number, full text of the request, text of the response, and each party's brief bullet-point argument on compelling a further response.
Court's wording
document set up as follows: the first column will identify the number of the discovery request at issue (e.g., SROG No. 1, or FROG No.1, etc.); the second, the full text of the discovery request; the third, the text of the response; and the fourth, a brief bullet-point statement, one from each party, as to why a further response should or should not be compelled.
The joint witness list must use a specified column format including witness name, expert status, accommodations, calling party, expected testimony, and estimated examination times.
Court's wording
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
Each party must file a trial brief identifying remaining claims/defenses, major legal issues with authorities, relief and damages calculation, and other helpful information.
Court's wording
Each party shall file a trial brief succinctly identifying: (1) the claims and defenses that remain in dispute for trial; (2) the major legal issues (with supporting points and authorities); (3) the relief and calculation of damages sought; and, (4) any other information that may assist the court at trial.
The parties’ counsel and any self-represented parties shall work together to prepare and file a joint list of all witnesses whom any party intends to call at trial, excluding impeachment and rebuttal witnesses.
Parties must jointly prepare and file a joint exhibit list using a specified column format covering exhibit number, description, offering party, stipulations, objections, and marking/admission dates.
- Document
- Joint exhibit list
Must include
- •Exhibit list
Court's wording
The parties’ counsel and any self-represented parties shall work together 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 at trial: (1) the exhibit number; (2) a brief description of the exhibit; (3) which party is offering the exhibit; (4) whether the parties have stipulated to authentication of the exhibit; (5) whether the parties have stipulated to admissibility of the exhibit; (6) any evidentiary objections to admission of the exhibit; (7) the date the exhibit was marked for identification; and, (8) the date the exhibit was admitted into evidence.
Witnesses not on the joint witness list are subject to exclusion from testifying at trial, except for impeachment or rebuttal, unless the party shows good cause.
Court's wording
represented parties shall add up the estimated times for all witnesses’ testimony and state the grand total in the last column. Any witness who is not included on the joint witness list is subject to being excluded from testifying at trial other than for purposes of giving actual impeachment or rebuttal testimony. Any party who seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the Court.
For jury trials, counsel and self-represented parties must jointly prepare and file a joint list of proposed jury instructions stating, for each instruction, its number, title, requesting party, agreed/contested status, any objection, and the court's disposition.
Court's wording
For jury trials, the parties’ counsel and any self-represented parties shall work together 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 as proposed, modified, refused, or withdrawn (CRC 2.1055) (“Joint List of Proposed Jury Instructions”).
For jury trials, the parties’ counsel and any self-represented parties shall work together to prepare and file a brief, joint written statement of the case for the Court to read to the jury. (Local Rule 3.25, subd. (g)(4).)
For jury trials, the parties’ counsel and any self-represented parties shall work together 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.
Jury trial parties must file a joint proposed verdict form acceptable to all parties, or, if they cannot agree after meeting and conferring, each party must separately file its own proposed verdict form.
Court's wording
For jury trials, the parties’ counsel and any self-represented parties shall work together to prepare and file a joint proposed general verdict form or a joint proposed special verdict form acceptable to all parties. (Local Rule 3.25, subd. (g)(8).) If after meeting and conferring the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.
Parties must attach tabbed transcript pages to the joint chart and highlight each designation, using a different highlighter color per party.
Court's wording
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. Each designation or counter-designation shall be highlighted, with each party using a different color highlighter.
Designating parties must include six specified columns in the joint chart of deposition and former testimony designations.
Court's wording
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.
Counter-designating parties must include six specified columns in the joint chart for their counter-designations.
Court's wording
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.
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 3 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: Tab A: Trial Briefs Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Statement to Be Read to the Jury Tab E: Joint List of Jury Instructions Tab F: Joint and Contested Jury Instructions Tab G: Joint or Contested Verdict Form(s) Tab H: Joint Chart of Page and Line Designations for Deposition and Former Testimony
- Document
- Trial binder
Must include
- •Table of contents
Each party shall file a trial brief succinctly identifying: (1) the claims and defenses that remain in dispute for trial; (2) the major legal issues (with supporting points and authorities); (3) the relief and calculation of damages sought; and, (4) any other information that may assist the court at trial.
- Document
- Trial brief
Must include
- •Legal argument
The parties must submit a jointly prepared statement of controverted issues of law and fact for consideration at the Final Status Conference.
Court's wording
In order to ensure that the parties properly address, both before and during trial, the legal and factual issues upon which they are seeking a judicial decision, the Court requires the parties to submit a jointly prepared statement of controverted issues of law and fact for consideration at the Final Status Conference.
The parties’ counsel and any self-represented parties shall work together to prepare and file a joint list of all witnesses whom any party intends to call at trial, excluding impeachment and rebuttal witnesses.
Witnesses not listed on the joint witness list may be excluded from testifying (except for impeachment or rebuttal) unless the party first shows good cause to the Court.
Court's wording
Any witness who is not included on the joint witness list is subject to being excluded from testifying at trial other than for purposes of giving actual impeachment or rebuttal testimony. Any party who seeks to elicit testimony from a witness not identified on the witness list must first make a showing of good cause to the Court.
Counsel and self-represented parties must jointly prepare and file a joint exhibit list containing eight specified columns for each trial exhibit, after meeting and conferring to resolve authenticity and admissibility objections.
Court's wording
The parties' counsel and any self-represented parties shall work together 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 at trial: (1) the exhibit number; (2) a brief description of the exhibit; (3) which party is offering the exhibit; (4) whether the parties have stipulated to authentication of the exhibit; (5) whether the parties have stipulated to admissibility of the exhibit; (6) any evidentiary objections to admission of the exhibit; (7) the date the exhibit was marked for identification; and, (8) the date the exhibit was admitted into evidence. (Local Rule 3.25, subd. (g)(6).) As set forth above, the parties' counsel and any self-represented parties shall meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit.
Each designating party's designations in the joint chart must include columns for the designation number, page and line designations requested, objections, related counter-designations, and the Court's ruling.
Court's wording
In the joint chart, each designating party's designations of deposition or former testimony shall include columns which state: (1) the designation number ... 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.
If any parties intend to use deposition testimony or former trial testimony in lieu of or in addition to a witness's live testimony, the parties' counsel and any self-represented parties shall meet and confer to discuss, and work together to prepare and file, a joint chart in the format set forth below ("Joint Chart of Page and Line Designations for Deposition and Former Testimony").
Each counter-designating party's counter-designations in the joint chart must include six specified columns covering designation number and witness name, date and type of testimony, page and line counter-designations, objections, the related designation number, and the Court's ruling.
Court's wording
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 Court expects the parties' counsel and any self-represented parties to work together to jointly prepare and timely submit the trial document binders
As set forth above, the parties’ counsel and any self-represented parties shall meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit.
Parties intending to use deposition or former trial testimony must meet and confer and jointly prepare a chart of page and line designations.
Court's wording
If any parties intend to use deposition testimony or former trial testimony in lieu of or in addition to a witness's live testimony, the parties' counsel and any self-represented parties shall meet and confer to discuss, and work together to prepare
Parties filing more than one motion in limine shall number them consecutively.
The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to exclude.
- Document
- Motion in limine
- Placement
- Caption
Motions in limine must comply with CCP section 1005 notice provisions and include declarations meeting Los Angeles County Court Rule 3.57(a).
Court's wording
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).
Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.
- Document
- Opposition and reply
- Placement
- Caption
Each Motions in Limine Binder must include a detailed table of contents showing the tab number and caption title of each motion or opposition.
- Document
- Motions in limine binder
Include
- •Table of contents
Court's wording
Please make sure that each such binder has a detailed table of contents indicating the tab number and the caption title of each such motion or opposition included in the binder. This index makes it easier for the parties, the Court, and the Court’s Judicial Assistant to keep track of the MILs.
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 also place the court’s yellow evidence tags (with only the case number and exhibit number filled in) on each exhibit in the Judicial Assistant’s copy of the Exhibit Binder.
At the end of the joint witness list, the parties and any self-represented parties shall add up the estimated times for all witnesses’ testimony and state the grand total in the last column.
The joint witness list must be organized in specified columns covering witness name (alphabetical), expert status and accommodations, calling party, expected testimony, and estimated direct, cross, and total examination times in hours.
Court's wording
The joint witness list shall be organized with 7 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);
When a special verdict form is requested, if there is an appropriate CACI special verdict form for a cause of action, affirmative defense, or other finding, the Court expects the parties to use the CACI special verdict form.
If there is an appropriate CACI jury instruction on a point of law, the court expects the parties to request the CACI instruction instead of a specially prepared jury instruction.
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 Cal. Rules of Court, rule 3.110.
Tab A: Trial Briefs Tab B: Joint Statement of Controverted Issues of Law and Fact Tab B: Joint Witness List Tab C: Joint Exhibit List and Former Testimony Tab E: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).
- Document
- Trial binder
Include
- •Exhibit list
Filing & Service rules
Electronic Filing Rules
All filings must be electronically filed unless the filer is a self-represented litigant or otherwise exempted from mandatory e-filing.
Under the rules of court and the court's general orders, all filings must be electronically filed unless the filer is a self-represented litigant or otherwise exempted from mandatory electronic filing.
Page 2 | E. MOTIONS
Ex parte applications, supporting documents, and written oppositions must be electronically filed, except for self-represented litigants and others excused from e-filing.
Please note that section 8 of the First Amended General Order governing Mandatory Electronic Filing for Civil, filed May 3, 2019, provides that, with the exception of self-represented litigants and other persons excused from filing documents electronically: (a) ex parte applications and all documents in support thereof must be electronically filed no later than 10:00 a.m. the day before the ex parte hearing, and (b) any written opposition to an ex parte application must be electronically filed by 8:30 a.m. the day of the ex parte hearing.
Page 3
Filing Timing and Cure Windows
Written opposition to an ex parte application must be e-filed by 8:30 a.m. on the day of the ex parte hearing.
(b) any written opposition to an ex parte application must be electronically filed by 8:30 a.m. the day of the ex parte hearing.
Page 3
Ex parte applications are heard at 9:00 a.m., Monday through Friday.
Ex parte applications are heard at 9:00 a.m., Monday through Friday.
Page 3
Ex parte applications and all supporting documents must be e-filed no later than 10:00 a.m. the day before the ex parte hearing.
(a) ex parte applications and all documents in support thereof must be electronically filed no later than 10:00 a.m. the day before the ex parte hearing
Page 3
After the Court schedules an IDC, the parties must file their IDC submissions not less than 5 court days before the IDC (the documents to be filed are cut off in this excerpt).
In order to make the IDC useful and efficient, after the Court has scheduled the IDC but not less than 5 court days prior to the IDC, the parties shall file
Page 4 | I. DISCOVERY ISSUES/IDCs/SONG-BEVERLY CASES
Failure to timely file the required Joint Statement will cause the informal discovery conference to be taken off calendar.
The failure of the parties to timely file the required Joint Statement will result in the IDC being taken off calendar.
Page 5 | I. DISCOVERY ISSUES/IDCs/SONG-BEVERLY CASES
Trial document binders and motion in limine binders must be delivered to Department 3 no later than 4:00 p.m. at least 5 court days before the Final Status Conference.
trial document binders, and motion in limine binders, to Department 3 not later than 4:00 p.m. at least 5 court days before the date of the Final Status Conference.
Page 9
Counsel and self-represented parties must meet and confer no later than 11 calendar days before the Final Status Conference to discuss and prepare the Section 2.B-H documents and the Motions in Limine, Exhibit, and Trial binders.
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
Page 10 | 1. MEET AND CONFER
Trial documents must be filed and served no later than five court days before the Final Status Conference.
No later than five court days before the Final Status Conference, the parties’ counsel and any self-represented parties shall file and serve the following documents:
Page 11 | 2. TRIAL DOCUMENTS TO BE FILED
The Motions in Limine Binder must be lodged in Department 3 no later than five court days before the Final Status Conference.
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 3 a Motions in Limine Binder.
Page 17 | Motions in Limine
The jointly prepared Trial Binder must be lodged in Department 3 no later than five court days before the Final Status Conference.
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 3 a Motions in Limine Binder.
Page 18 | 5. TRIAL BINDER
No later than five court days before the Final Status Conference, the parties’ counsel and any self-represented parties shall file and serve the following documents:
No later than five court days before the Final Status Conference, the parties’ counsel and any self-represented parties shall file and serve the following documents:
Page 21 | 2. TRIAL DOCUMENTS TO BE FILED
Motions in limine must be noticed in compliance with the statutory notice provisions of Code of Civil Procedure section 1005.
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).
Page 26
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 | B. CASE MANAGEMENT CONFERENCES
Both plaintiff and defendant must serve verification together with the documents they produce in discovery.
Plaintiff and defendant shall serve verification with the documents they produce.
Page 7 | I. DISCOVERY ISSUES/IDCs/SONG-BEVERLY CASES
Counsel and self-represented parties must exchange all exhibits they intend to introduce at trial no later than 18 calendar days before the Final Status Conference.
No later than 18 calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall exchange all exhibits they intend to introduce at trial.
Page 10 | 1. MEET AND CONFER
Counsel and self-represented parties must exchange all trial exhibits no later than 18 calendar days before the Final Status Conference.
No later than 18 calendar days before the Final Status Conference, the parties' counsel and any self-represented parties shall exchange all exhibits they intend to introduce at trial.
Page 20 | 1. MEET AND CONFER
The required trial documents must be served along with filing no later than five court days before the Final Status Conference.
No later than five court days before the Final Status Conference, the parties’ counsel and any self-represented parties shall file and serve the following documents:
Page 21 | 2. TRIAL DOCUMENTS TO BE FILED
Producing parties may serve discovery information on the opposing party electronically as a PDF at their option.
The information may be provided to the opposing party in electronic form as a PDF at the option of the producing party.
Page 7 | I. DISCOVERY ISSUES/IDCs/SONG-BEVERLY CASES
Filing Fees and Waivers
Ex parte applicants must pay the filing fee before appearing in court.
Ex parte applicants must comply with the requirements of California Rules of Court, rules 3.1200-3.1207, submit a proposed order, and pay the filing fee before appearing in court.
Page 3
Courtesy Copy Requirements
The parties must deliver a 3-hole punched courtesy hard-copy of the Joint Statement to the Court.
The parties shall also deliver to the Court a 3-hole punched courtesy hard-copy of the Joint Statement.
Page 5 | I. DISCOVERY ISSUES/IDCs/SONG-BEVERLY CASES
One set of the Exhibit Binders must be brought to the Final Status Conference for the court to review.
The parties’ counsel and any self-represented parties shall bring one set of the Exhibit Binders to the Final Status Conference for the court to review.
Page 18 | Exhibit Binders
Opposing parties should file ex parte oppositions early and deliver a courtesy copy to the Court, since an opposition filed at 8:30 a.m. on the hearing date is unlikely to be seen before the hearing.
Because the Court takes the bench each day at 8:30 a.m., as a practical matter an opposition filed at 8:30 a.m. on the date of the hearing is unlikely to have been seen by the Court prior to the ex parte hearing. The opposing party should make every effort to file its opposition earlier and provide the Court with a courtesy copy delivered to the Court.
Page 3
Filing Bundling Requirements
Parties must jointly prepare a Motions in Limine Binder bundling all MIL moving, opposition, and reply papers and lodge it in Department 3 at least five court days before the Final Status Conference.
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 3 a Motions in Limine Binder. 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 tab separating the moving, opposition, and reply papers.
Page 17 | Motions in Limine
Counsel and self-represented parties must jointly prepare and lodge a Motions in Limine Binder in Department 3 no later than five court days before the Final Status Conference.
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 3 a Motions in Limine Binder.
Page 26
Pre-Motion Conference Requirements
All motion hearing dates must be reserved in advance via the Court Reservation System (CRS) at www.lacourt.ca.gov.
All motion hearing dates must be reserved in advance on the Court Reservation System at www.lacourt.ca.gov, under "Online Services," "Civil," "Court Reservation System (CRS)."
Page 2 | E. MOTIONS
Counsel and self-represented parties must first meet and confer in a reasonable, good faith attempt to informally resolve each discovery dispute before pursuing discovery motions, and an exchange of position-taking emails alone is not ordinarily sufficient.
The Court expects the parties' counsel and any self-represented parties first to meet and confer to make a reasonable and good faith attempt to informally resolve each discovery issue in dispute. The mere exchange of position-taking emails would not ordinarily be enough to satisfy this expectation.
Page 4 | I. DISCOVERY ISSUES/IDCs/SONG-BEVERLY CASES
Counsel and any self-represented parties with full authority to stipulate must participate in the informal discovery conference.
The Court requires the parties' counsel and any self-represented parties, with full authority to enter into a stipulation to resolve the discovery disputes at issue, to participate in the informal discovery conference with the Court.
Page 5 | I. DISCOVERY ISSUES/IDCs/SONG-BEVERLY CASES
Counsel for the parties must appear in person in court for the informal discovery conference.
The Court requires that counsel for the parties appear in person in court for the IDC.
Page 5 | I. DISCOVERY ISSUES/IDCs/SONG-BEVERLY CASES
Motions in limine must be noticed for hearing at the Final Status Conference.
Motions in limine shall be noticed for hearing at the Final Status Conference.
Page 26
Parties planning summary judgment/adjudication motions should expedite discovery and reserve hearing dates early, because CRS reservation slots are limited and hearing dates may be unavailable within 30 days of trial.
Any party expecting to file a motion for summary judgment or summary adjudication should press the discovery process forward swiftly to be able to prepare its motion and reserve a hearing date sufficiently in advance of the scheduled trial date. Reservation dates for such motions are limited on the Court Reservation System and hearing dates might not be available at least 30 days before the trial date set in the case.
Page 2 | F. MOTIONS FOR SUMMARY JUDGMENT/ADJUDICATION
Motions are heard Monday through Friday, and motions in limine are heard at the Final Status Conference rather than on regular motion dates.
Motions are set for hearing Monday through Friday. Motions in limine are heard during the Final Status Conference.
Page 2 | E. MOTIONS
The Court generally does not conduct IDCs in Song-Beverly Warranty Act cases, though parties may still request one and explain why it would be useful.
Song-Beverly Act Litigation. The Court generally does not conduct IDCs in cases alleging violations of the Song-Beverly Warranty Act and related claims, but the parties are not precluded form requesting one and explaining why it might be useful in the particular case.
Page 5 | I. DISCOVERY ISSUES/IDCs/SONG-BEVERLY CASES
Adjournment & Extension Requirements
Scheduling an IDC is not a prerequisite to filing a discovery motion and does not toll its deadline, and the Court expects the responding party to grant a reasonable extension of time to file the discovery motion so the IDC can be scheduled and conducted.
Please note that the scheduling of an IDC is not a prerequisite to filing a discovery motion, nor will it toll any deadline within which a discovery motion must be filed. Thus, for the IDC to have any value in conserving the time, energy, and resources of the parties, and of the Court, the Court expects the responding party to grant the moving party a reasonable extension of time to file a motion concerning the discovery in dispute to enable the parties to schedule and conduct an informal discovery conference.
Page 4 | I. DISCOVERY ISSUES/IDCs/SONG-BEVERLY CASES
Chambers Communication Rules
Any inquiries may be directed to Court staff every court day between 10:00 a.m. and 12:00 p.m. or between 2:00 p.m. and 5:00 p.m.
Any inquiries may be directed to Court staff every court day between 10:00 a.m. and 12:00 p.m. or between 2:00 p.m. and 5:00 p.m.
Page 1 | Courtroom Information