Judge William H. Forman
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- Discouraged
Exhibits
- 3 copies • First Day of Trial
Joint IDC Report
- 1 copy • Within 1 Court Day of Electronic Filing
Motion, Opposition, Reply
- No Later Than Two Days Before FSC
Page & Word Limits1 rule
The joint IDC report is limited to no more than eight pages.
- Joint IDC report
- Up to 8 pages
Court's wording
At least seven (7) days before the IDC, the parties shall file a joint report, of no more than eight pages, that succinctly sets forth the nature of the dispute, the necessity for the discovery, the justification for its non-production, and the overall status of discovery.
Document Format Requirements1 rule
Pursuant to Local Rules 3.52 and 3.53, the exhibits must be pre-marked using Arabic numerals and in instances where exhibits consist of multiple pages, each page must be numbered sequentially.
Document Filing Requirements21 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.
Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in court.
- Document
- Ex parte application
Must include
- •Proposed order
At least seven (7) days before the IDC, the parties shall file a joint report, of no more than eight pages, that succinctly sets forth the nature of the dispute, the necessity for the discovery, the justification for its non-production, and the overall status of discovery.
Ex parte applicants must include a declaration making an affirmative factual showing of irreparable harm, immediate danger, or another statutory basis for ex parte relief.
Court's wording
Ex parte applications are reserved for exigent circumstances. The applicant shall comply with Cal. Rules of Court, rule 3.1202(c): "An applicant must make an affirmative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte."
Joint Statement – For jury trials, the parties shall prepare a joint written statement of the case for the Court to read to the jury. The parties/counsel shall sign the joint statement.
The parties must file a signed joint witness list identifying each witness by name, expert status, estimated examination times, total testimony hours, and any scheduling issues or special requirements.
Court's wording
Joint Witness List – The parties shall work together and file a joint list of all witnesses that each party intends to call, excluding impeachment and rebuttal witnesses. The joint witness list shall identify each witness by name, specify which witnesses are experts, estimate the length of direct examination, cross-examination, and re-direct examination of each, and include a total of the number of hours for all witness testimony. The parties shall identify all potential witness scheduling issues and special requirements. The parties/counsel shall sign the joint witness list.
Trial Briefs – Each party shall file a trial brief succinctly identifying: (1) the claims and defenses subject to litigation, (2) the major legal issues (with supporting points and authorities), (3) the relief claimed and the 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 file a signed joint list of proposed jury instructions in numerical order, identifying agreed and contested instructions, with a space for the Court to mark whether each instruction was given.
Court's wording
Joint List of Proposed Jury Instructions – The parties shall jointly prepare and file a list of proposed jury instructions, organized in numerical order, specifying the instructions upon which all sides agree and the contested instructions, if any. The list of proposed jury instructions must include a space by each instruction for the Court to indicate whether the instruction was given. The parties/counsel shall sign the joint list of proposed jury instructions.
The parties must meet-and-confer and then file a signed joint exhibit list with columns for the exhibit, offering party, stipulations to authenticity/admissibility, date identified, and date admitted, with all objections specified.
Court's wording
Joint Exhibit List – The parties shall prepare and file a joint exhibit list organized with columns identifying: (1) the exhibit, (2) which party is offering the exhibit, (3) whether there is a stipulation to authenticity and/or admissibility of the exhibit, (4) the date on which the exhibit was identified, and (5) the date on which the exhibit was admitted. Prior to filing the joint exhibit list, the parties shall meet-and-confer to determine whether they will stipulate to the authenticity and/or admissibility of each exhibit or whether there are objections to any exhibit. If there are stipulations, the parties shall note that in the respective column. If not, the objecting party shall specify all objections in the respective column. The parties/counsel shall sign the joint exhibit list.
If deposition or former trial testimony will be used in lieu of live testimony, the parties must meet-and-confer and file a signed joint designations chart with page/line designations, objections, counter-designations, responses, and the Court's rulings.
Court's wording
Page and Line Designations for Deposition and Former Testimony – If the parties intend to use deposition testimony or former trial testimony in lieu of any witness's live testimony, the parties shall meet-and-confer and jointly prepare and file a chart with columns for each of the following: (1) the page and line designations of the deposition or former testimony requested for use, (2) objections, (3) counter-designations, (4) any responses thereto, and (5) the Court's rulings. The objecting party shall specify all objections in the respective column. The parties/counsel shall sign the designations.
set of full-text proposed jury instructions. The parties shall prepare special instructions in a format ready for submission to the jury with the instruction number, title, and text only.
Joint Verdict Forms – The parties shall prepare and file a joint proposed general verdict form or special verdict form (with interrogatories). If the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form.
The binder also must contain a table of contents identifying each motion in limine, opposition, and reply, and the corresponding tab for each.
- Document
- Motion in limine binder
Must include
- •Table of contents
The caption of each motion in limine shall concisely identify the evidence that the moving party seeks to admit or exclude.
- Document
- Motion in limine
- Placement
- Caption
When filing motions in limine, the parties must comply with Local Rule 3.57, including the required declaration, if applicable.
Parties filing opposition and reply briefs shall identify the corresponding motion number in the caption of their pages.
- Document
- Opposition and reply brief
- Placement
- Caption
Parties filing more than one motion in limine shall number the motions consecutively.
If a party intends to move to modify the Addendum in a particular case, it should so note in its Case Management Conference state
For this reason, any party opposing an ex parte should timely file a written opposition. Absent a written opposition, the Court will assume the ex parte is unopposed.
Tab G: Joint and/or Contested Verdict Forms Tab H: Joint Exhibit List Tab I: Page and Line Designations for Deposition and Former Testimony Tab J: Stipulations
Include
- •Exhibit list
Motions in limine should not be a request that the Court follow the law. For example, a motion in limine to exclude all hearsay evidence is improper and will be denied. Motions in limine should instead identify the specific evidence to be excluded.
Filing & Service rules
Filing Timing and Cure Windows
The parties must file the joint IDC report at least seven days before the IDC.
At least seven (7) days before the IDC, the parties shall file a joint report, of no more than eight pages, that succinctly sets forth the nature of the dispute, the necessity for the discovery, the justification for its non-production, and the overall status of discovery.
Civil cases
Page 2 | D. INFORMAL DISCOVERY CONFERENCES
Trial readiness documents must be served and filed at least five calendar days before the Final Status Conference.
In accordance with the Local Rules, at least five (5) calendar days prior to the FSC, the parties/counsel shall serve and file the following trial readiness documents:
Civil cases
Page 3 | 1. Final Status Conference ("FSC") and Pretrial Filings
Exhibits must be exchanged between the parties at least five calendar days before the FSC.
The exhibits must be exchanged at least five (5) calendar days before the FSC and lodged with the Court on the first day of trial.
Civil cases
Page 5 | 4. Exhibits
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.
Civil cases
Page 1 | B. CASE MANAGEMENT CONFERENCES
Both plaintiff and defendant must provide copies of the enumerated case documents in their possession, custody, or control to the opposing side within 30 days of this order.
Within 30 days of this order both plaintiff and defendant shall provide copies of the following documents, which are in their respective possession, custody and/or control, to the opposing side(s):
Civil cases
Page 7 | Discovery - 2. Production of Documents
Both parties must serve verifications along with the documents they produce.
Plaintiff and defendant shall serve verifications with the documents they produce.
Civil cases
Page 8 | Discovery - 2. Production of Documents
Pre-trial service deadlines are extended based on the manner of service under Code of Civil Procedure § 1013, unless otherwise ordered.
Unless otherwise ordered, the following pre-trial filing and service deadlines apply. All deadlines for service are extended based on the manner of service as set forth in Code of Civil Procedure § 1013.
Civil cases
Page 3 | F. TRIALS (including Final Status Conference and Pretrial Filings, Trial Binders, Motions in Limine)
Produced discovery information may be provided to the opposing party in electronic PDF form at the producing party's option.
The information may be provided to the opposing party in electronic form as a PDF at the option of the producing party
Civil cases
Page 8 | Discovery - 2. Production of Documents
Notice of the Addendum is deemed served on all parties' attorneys through its inclusion in the Courtroom Information sheet at the Case Management Conference.
By inclusion in the Courtroom Information sheet, the Notice of this Addendum is deemed provided to the parties' respective attorneys at the Case Management Conference.
Civil cases
Page 9
Filing Fees and Waivers
Motion fees must be paid online at the time the hearing date reservation is made through CRS.
Motion fee payments are required at the time reservations are made online.
Civil cases
Page 2 | C. LAW AND MOTION
Ex parte applicants must pay the filing fee before appearing in court.
Applicants must comply with California Rules of Court, rule 3.1200, et seq., submit a proposed order, and pay the filing fee before appearing in court.
Civil cases
Page 2 | E. EX PARTE APPLICATIONS
Courtesy Copy Requirements
A courtesy copy of the report shall be delivered to the courtroom within one (1) court day of the electronic filing.
A courtesy copy of the report shall be delivered to the courtroom within one (1) court day of the electronic filing.
Civil cases
Page 2 | D. INFORMAL DISCOVERY CONFERENCES
Counsel must provide a joint trial binder for the Court at the FSC (or shortly before, if appearing remotely). The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Blank Tab C: Joint Statement of the Case Tab D: Joint Witness List Tab E: Joint List of Jury Instructions
Counsel must provide a joint trial binder for the Court at the FSC (or shortly before, if appearing remotely). The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Blank Tab C: Joint Statement of the Case Tab D: Joint Witness List Tab E: Joint List of Jury Instructions
Civil cases
Page 4 | 2. Trial Binders
Counsel must deliver a tabbed binder containing all motions in limine, oppositions, and replies in sequential order no later than two days before the FSC.
As soon as practicable before the FSC, but no later than two days beforehand, counsel must provide a tabbed binder containing all motions in limine, oppositions, and replies in sequential order consistent with the number assigned to each motion in limine.
Civil cases
Page 5 | 3. Motions in Limine
At least three sets of exhibit binders – tabbed and paginated – are required on the first day of trial: a set each for the Court, judicial assistant, and
At least three sets of exhibit binders – tabbed and paginated – are required on the first day of trial: a set each for the Court, judicial assistant, and
Civil cases
Page 5 | 4. Exhibits
The Court discourages courtesy copies for law and motion filings.
Courtesy copies are discouraged.
Civil cases
Page 2 | C. LAW AND MOTION
Sealing & Redaction Procedures
A party seeking protection for produced discovery information must serve and file a proposed protective order within 5 days of the order and meet and confer on its language, with the standard LASC Protective Order applying by default.
If a party believes any of this information should be subject to a protective order, that party shall serve and file a proposed protective order within 5 days of this order and the parties shall meet and confer as to agreeable language for the same. The default will be the standard Protective Order provided by the LASC in its website.
Civil cases
Page 8 | Discovery - 2. Production of Documents
Pre-Motion Conference Requirements
Moving parties must reserve a hearing date through the online Court Reservation System (CRS) before filing any motion, except motions in limine.
Moving parties must secure a hearing date via the online Court Reservation System (CRS) on the Los Angeles Superior Court website. Please see the "Online Services" section to find the civil Court Reservation System at www.lacourt.ca.gov to reserve a hearing date prior to filing any motion, except for motions in limine, which are heard on the first day of trial which is normally a Friday (with jury selection to begin the following Monday).
Civil cases
Page 2 | C. LAW AND MOTION
Motions in limine are to be set for hearing at the FSC, and should be filed to be heard on statutory notice, in accord with Code of Civil Procedure sections 1005(b) and 1013 and Local Rule 3.25(f)(2). While the Court typically will defer formal hearing on motions in limine on the first day of trial, the parties should be prepared at the FSC to discuss the content with the Court and efforts to resolve disputed motions in limine.
Motions in limine are to be set for hearing at the FSC, and should be filed to be heard on statutory notice, in accord with Code of Civil Procedure sections 1005(b) and 1013 and Local Rule 3.25(f)(2). While the Court typically will defer formal hearing on motions in limine on the first day of trial, the parties should be prepared at the FSC to discuss the content with the Court and efforts to resolve disputed motions in limine.
Civil cases
Page 5 | 3. Motions in Limine
An Informal Discovery Conference is not required before filing or hearing a discovery motion, but the Court considers it best practice.
While the Court does not require an IDC be held before a discovery motion is filed or heard, the best practice is to engage in an IDC before bringing a motion.
Civil cases
Page 2 | D. INFORMAL DISCOVERY CONFERENCES