Los Angeles Superior Court Document Format Requirements

CRITICAL

The trial binder must be tabbed, organized into three-ring binders, and include a table of contents.

The parties/counsel shall jointly prepare and lodge with the Court at the FSC, a trial binder containing the above-described trial documents, which shall be tabbed and organized into three-ring binders with a table of contents

CRITICAL

Applies to

Motion in limine

Motions in limine must be numbered consecutively in the caption.

The caption of each motion in limine shall number them consecutively.

CRITICAL

Applies to

Exhibits

Exhibits must be bate stamped and tabbed with numbers matching joint exhibit list.

Exhibits must be bate stamped and tabbed with exhibit numbers that correspond to those on the joint exhibit list.

CRITICALCivil cases

Applies to

Jury instruction

Final jury instructions and verdict forms must not include citations, party identification, or attorney letterhead/markings, and must be suitable for jury deliberation.

The parties are jointly responsible for the preparation of a final set of jury instructions and verdict forms after the Court rules on any disputes. The final set of jury instructions and verdict forms shall be in a format suitable for submission to the jury during deliberations, and shall not include any citations to authority, identification of the party requesting the instruction or verdict, or any letterhead or markings identifying the attorney who prepared or printed them. (LASCR 3.174).

CRITICALCivil cases

Deposition excerpts cited in briefs must be marked on the transcript exhibits attached to the filing.

All deposition excerpts referenced in briefs must be marked on the transcripts attached as exhibits. (Rules of Court, rule 3.1116(c).)

CRITICALCivil cases

Applies to

Exhibit

Exhibits must be tabbed, internally paginated, properly marked, organized numerically in three-ring binders for court, judicial assistant, and witnesses, with non-documentary exhibits described.

The parties shall jointly prepare (and be ready to temporarily lodge for inspection at the FSC) one set of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (a set for the Court, the Judicial Assistant, and the witnesses). At trial, the parties will need additional copies of the exhibits for the Court’s clerk, for use on the witness stand, and for each counsel. The parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the exhibit binder.

CRITICALCivil cases

Applies to

Trial binder

Counsel must provide a joint trial binder for the Court at the FSC. The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Motions in Limine Tab C: Joint Statement of the Case Tab D: Joint Witness List Tab E: Joint List of Jury Instructions (joint and contested) Tab F: Full Text Jury Instructions Tab G: Joint and/or Contested Verdict Forms Tab I: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab J: Operative Pleadings Tab K: Stipulations If there are more than a few motions in limine, they should be placed in a separate binder. Whether in a separate binder or Tab B, Plainti ’s should come first, followed by those of Defendant. There should be numbered tabs separating each motion and colored sheets of paper between the motion and any opposition and between the opposition and any reply.

Counsel must provide a joint trial binder for the Court at the FSC. The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Motions in Limine Tab C: Joint Statement of the Case Tab D: Joint Witness List Tab E: Joint List of Jury Instructions (joint and contested) Tab F: Full Text Jury Instructions Tab G: Joint and/or Contested Verdict Forms Tab I: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab J: Operative Pleadings Tab K: Stipulations If there are more than a few motions in limine, they should be placed in a separate binder. Whether in a separate binder or Tab B, Plainti ’s should come first, followed by those of Defendant. There should be numbered tabs separating each motion and colored sheets of paper between the motion and any opposition and between the opposition and any reply.

CRITICALCivil cases

All electronically filed documents must be text-searchable and include bookmarks.

All electronically filed documents must be text-searchable and bookmarked. (See operative General Order re Mandatory Electronic Filing in Civil., referenced above.)

CRITICALCivil cases

Final jury instructions and verdict forms must be suitable for jury deliberations and may not contain citations to authority, party identification, or attorney letterhead/markings.

The final set of jury instructions and verdict forms shall be in a format suitable for submission to the jury during deliberations, and shall not include any citations to authority, identification of the party requesting the instruction or verdict, or any letterhead or markings identifying the attorney who prepared or printed them. (LASCR 3.174).

CRITICALCivil cases

Parties must jointly prepare one set of tabbed, internally paginated, properly marked exhibits organized numerically in three-ring binders for the Court, the Judicial Assistant, and the witnesses, ready to lodge for inspection at the FSC.

The parties shall jointly prepare (and be ready to temporarily lodge for inspection at the FSC) one set of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (a set for the Court, the Judicial Assistant, and the witnesses).

CRITICALCivil cases

All non-documentary exhibits must be marked, with a simple written description inserted behind the corresponding numerical tab in the exhibit binder.

The parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the exhibit binder.

CRITICALCivil cases

Courtesy copies of documents containing declarations and/or exhibits must be tabbed.

Any courtesy copies of documents with declarations and/or exhibits must be tabbed. (Rules of Court, rule 3.1110(f).)

CRITICALCivil cases

All electronically filed documents must be text-searchable and bookmarked.

All electronically filed documents must be text-searchable and bookmarked. (See operative General Order re Mandatory Electronic Filing in Civil., referenced above.)

CRITICALCivil cases

Exhibits must be pre-marked with Arabic numerals, and each page of multi-page exhibits must be numbered sequentially.

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.

CRITICALCivil cases

All filings must comply with the technical requirements set forth in the General Order re Mandatory Electronic Filing for Civil (May 3, 2019).

All filings shall comply with the technical requirements set forth in that general order.

CRITICAL

Self-represented litigants must staple all papers separately before filing, or they will be rejected.

All papers filed by self-represented litigants must be stapled separately before filing, or they will be rejected.

CRITICAL

Self-represented litigants' papers must be stapled separately before filing or they will be rejected.

All papers filed by self-represented litigants must be stapled separately before filing, or they will be rejected.

CRITICAL

Identical copies of the exhibit list and all exhibits must be provided in 3-ring binders — one for each party, one for the Court, and one for the witness stand.

Identical copies of the Exhibit List and all exhibits must be provided in 3-ring binders as follows: one for each party, one for the Court, and one for the witness stand.

CRITICAL

Exhibit binders must be three-ring binders available at the final status conference, with the exhibit list in front, tabs matching exhibit numbers, and internally numbered pages for multi-page exhibits.

Three-ring binders containing all exhibits must be available on the final status conference date, and all parties must be prepared to tell the Court that they have had an opportunity to review all documents in the exhibit notebooks. Place a copy of the exhibit list in the front of each exhibit notebook and place tabs in the notebook to correspond with the exhibit number. If an exhibit contains more than one page, pages must be internally numbered, i.e., 3.1, 3.2, 3.3, etc.

CRITICAL

Proposed jury instructions must be in a jury-ready format containing only the instruction number, title, and text, with no tear sheets or markings indicating the requesting party.

The parties/counsel shall prepare proposed instructions in a format ready for submission to the jury with the instruction number, title, and text only (i.e., there should be no tear sheets and no boxes or other indication on the printed instruction itself as to the requesting party).

CRITICAL

Each designation or counter-designation must be highlighted, with each party using a different color highlighter.

Each designation or counter-designation shall be highlighted with each party using a different color highlighter.

CRITICAL

Parties must attach copies of the designated or counter-designated transcript pages to the designation chart, with tabs separating each deposition or trial transcript.

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 chart, with tabs separating each deposition or trial transcript.

CRITICAL

Trial documents must be tabbed and the trial notebook must include a table of contents listing documents by tab number.

The trial documents must be tabbed, and the notebook must contain a table of contents listing the trial documents by tab number.

CRITICAL

Each exhibit must be separately numbered to correspond with the joint exhibit list, and multi-page exhibits must have internally numbered pages (e.g., 3.1, 3.2, 3.3).

Each exhibit must be separately numbered, with the numbers corresponding to the number of theexhibit on the joint exhibit list. If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3 etc.

CRITICAL

Counsel must leave at least four inches of blank space on any addenda to form jury instructions (sentence continues across a page break; see source).

Leave at least four inches of blank ... any addenda to form instructions.

CRITICAL

The parties shall work together to provide exhibits electronically, if feasible.

The parties shall work together to provide exhibits electronically, if feasible.

CRITICAL

Applies to

Trial notebook

Format

PAPER

Trial notebook must be provided in paper format to the court.

The parties must provide both a paper “trial notebook” for the Court and submit FSC/trial documents electronically.

CRITICAL

Copies of motions in limine, opposition, and reply papers must be organized in one or more three-ring binders, tabbed numerically, with opposition and reply papers placed directly behind the moving papers and separated by colored sheets (sentence continues from prior page).

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.

CRITICAL

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 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”).

CRITICAL

CMC statements must be filed on Judicial Council Form CM-110 within 5 days of the hearing.

file a CMC statement on Judicial Council Form CM-110 within five (5) days of the hearing.

CRITICAL

Format

DOCX

Proposed jury instructions must be prepared on Los Angeles Superior Court form SCLAC LACIV 129 or in a Word document in the same format.

The proposed jury instructions shall be prepared on Superior Court of Los Angeles County form SCLAC LACIV 129 or in a Word document that is in the same format.

CRITICAL

Parties must attach copies of the designated transcript pages to the Joint Chart with numbered tabs separating each transcript, and all designated pages for each transcript must appear in page order behind a single tab.

The parties shall attach a copy 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. For each transcript, all pages containing the designations and counter-designations shall be included in a single document in page order behind a single tab.

CRITICALCivil cases

Exhibits must be numbered (not lettered), Bates stamped, identified separately, organized with plaintiff starting at number 1 and a separate defendant numerical block, and multi-page exhibits consecutively paginated; bulk exhibits are not permitted.

The joint exhibit list should begin with the number 1 for plaintiff and a separate numerical block for defendant. Exhibits should be numbered and not designated by letters. Each exhibit must be identified separately and Bates stamped. Bulk exhibits (e.g., "plaintiffs medical records") will not be permitted. Each page of a multi-page exhibit must be consecutively paginated (e.g., exhibit 1 will be 1-1, 1-2, etc.).

CRITICAL

The trial binder must be a 3-ring binder delivered to Dept. F46 at least 10 court days before the Final Status Conference.

Trial Binder: the parties shall cooperate in compiling a 3-ring trial binder that shall be delivered to Dept. F46 at least 10 court days before the FSC.

CRITICAL

Exhibits must be pre-numbered, the requisite number of exhibit books must be produced, and parties may not produce exhibits opposing counsel has never seen (unless for impeachment) or expect the clerk to track exhibits.

Please do not: 1. Fail to pre-number your exhibits 2. Expect the clerk to keep track of your exhibits 3. Produce exhibits at trial which opposing counsel has never seen, unless they are used for impeachment 4. Fail to produce the requisite number of exhibit books

CRITICAL

Trial Readiness Binder documents must be tabbed and the notebook must include a table of contents listing the documents by tab number.

The trial documents must be tabbed, and the notebook must contain a table of contents listing the trial documents by tab number.

CRITICAL

Non-documentary exhibits must be represented in a binder with a simple written description.

Non-documentary exhibits shall be represented in a binder with a simple written description.

CRITICAL

Each page of a multi-page exhibit must be consecutively paginated.

Each page of a multi-page exhibit must be consecutively paginated.

CRITICAL

Bulk exhibits such as voluminous medical records are not permitted, and counsel must separately mark and identify the specific items within any bulk exhibit.

Bulk exhibits, e.g., voluminous medical records will not be permitted. Counsel must separately mark and identify the specific items within a bulk exhibit.

CRITICAL

Motions in limine papers must be lodged in indexed, tabbed three-ring binder 5 court days before FSC.

No later than five court days before the FSC, the moving party for each motion in limine must lodge directly in Department R an indexed and tabbed three-ring binder containing conformed copies of all moving, opposition, and reply papers for their motions in limine.

CRITICAL

Proposed special jury instructions must have 4 inches of blank space at top of each page.

Leave at least four inches of blank space of the top of every page of any proposed special jury instructions, or any addenda to form instructions.

CRITICAL

Proposed jury instructions must be organized into three cover-sheet-labeled groups: agreed-upon instructions; plaintiff's requested instructions with defendant highlighting objections; and defendant's requested instructions with plaintiff highlighting objections.

The parties shall organize proposed jury instructions into groups in the following order (labeled by cover sheets): (1) the agreed-upon instructions; (2) plaintiff’s requested instructions to which defendant objects. Defendant is to highlight the objectionable portions of the proposed instruction; and (3) defendant’s requested instructions to which plaintiff objects. Plaintiff is to highlight the objectionable portion of the proposed instruction.

CRITICAL

The List of Proposed Jury Instructions must be prepared in the index format required by CRC rule 2.1055(b)(3), including a checklist for the Court to indicate the disposition of each proposed instruction.

The List of Proposed Jury Instructions must be prepared in the index format required by CRC, rule 2.1055(b)(3), including a checklist for the Court to indicate the disposition of the proposed instructions.

CRITICAL

Format

DOCX

The instructions should be in Word, Times New Roman, 14 point font.

The instructions should be in Word, Times New Roman, 14 point font.

CRITICAL

Documentary exhibits must be one-sided copies.

Copies of documentary exhibits shall be one-sided copies.

CRITICAL

Each instruction should be on its own page or pages.

Each instruction should be on its own page or pages.

CRITICAL

Format

DOCX

Proposed jury instruction documents and the verdict form must be submitted in Word format with 14 point font.

final (or close to final verdict form). The documents shall be in Word, 14 point font.

CRITICAL

Jury instructions must not include headers or footers, except that page numbers are permitted.

Do not include any headers or footers, except for page numbers.

CRITICAL

The Joint Chart must attach copies of designated or counter-designated transcript pages separated by numbered tabs, with each designation highlighted and each party using a different color highlighter.

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.

CRITICAL

In the FSC notebook behind Tab B, each motion in limine must be separated by a numbered side tab matching the motion number, motion/opposition/reply separated by colored sheets, plaintiff's MILs placed first, and defendant's side tabs restart at one.

Behind Tab B, the parties shall separate each motion in limine with a side tabbed number that corresponds to the number of the motion in limine. The motion, opposition, and reply shall be separated by a colored sheet of paper. The plaintiff’s motions in limine shall come first and the defendant’s motions in limine shall follow. For the defendant’s motions in limine, the numbered side tabs shall start over with the number one, indicating the start of the defendant’s motions in limine.

CRITICAL

Final jury instructions and verdict forms must be in a jury-ready format containing no citations to authority, no identification of the requesting party, and no letterhead or markings identifying the preparing attorney.

The final set of jury instructions and verdict forms shall be in a format suitable for submission to the jury during deliberations, and shall not include any citations to authority, identification of the party requesting the instruction or verdict, or any letterhead or markings identifying the attorney who prepared or printed them. (Local Rules, rule 3.174.)

CRITICAL

Jury instructions must not include a tear-away box at the top of the page or the document title in the footer; the footer may only include page numbers.

Do not include a “tear-away” box at the top of the page or the title of the document in the footer. The footer may include page numbers.

CRITICAL

Format

DOCX

The agreed upon or contested verdict form must be emailed to the judicial assistant in Word format, and the case may be continued if the form is not ready at the FSC.

The Court will review the form at the FSC and if it is not ready, the case may be continued. The parties shall email to the judicial assistant the agreed upon or contested verdict form (whether general or special) in Word.

CRITICAL

Parties must jointly prepare three sets of tabbed, internally paginated, properly marked exhibits organized numerically in three-ring binders (for the Court, Judicial Assistant, and witnesses); if notebooks for each side are included, the number increases to five or more depending on the number of parties.

The parties shall work together jointly to prepare three sets of tabbed, internally paginated and properly marked exhibits, organized numerically in three-ring binders for the Court (a set for the Court, a set for the Judicial Assistant, and a set for the witnesses) ("Exhibit Binders")

CRITICAL

Courtesy copies must comply with CRC 3.1110(f): each exhibit must be separated by a tab extending below the bottom of the page bearing the exhibit designation, and noncompliance may result in the hearing being continued or the exhibits not being considered.

The courtesy copies must comply with CRC, rule 3.1110(f), which requires that each exhibit be separated by a tab extending below the bottom of the page bearing the exhibit designation. Failure to comply with this rule may result in the Court continuing the hearing or not considering the exhibits.

CRITICAL

Non-documentary exhibits must be marked and a simple written description or picture inserted behind the corresponding numerical tab in the Exhibit Binders.

The parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit or a picture behind the corresponding numerical tab in the Exhibit Binders.

CRITICAL

Format

PAPER

PowerPoint presentations and other displays to the jury must be reduced to paper and filed in the Court's docket.

PowerPoint presentations or other displays to the jury must be reduced to paper to be filed in the Court’s docket.

CRITICAL

Exhibits must be pre-marked with Arabic numerals, pages numbered sequentially, exchanged 14 calendar days before FSC, lodged first day of trial, with tabbed/paginated binders for Court, staff, witnesses, and opposing parties.

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. The exhibits must be exchanged at least fourteen (14) calendar days before the FSC and lodged with the Court on the first day of trial. 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 witness. Counsel must also additionally supply an exhibit binder to each opposing party.

CRITICAL

Parties must provide a joint trial binder to the Court at the FSC organized with Tabs A through J covering trial briefs through current operative pleadings.

The parties and counsel shall provide a joint trial binder for the Court at the FSC. The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Motions in Limine Tab C: Joint Statement of the Case Tab D: Joint Witness List Tab E: Joint List of Jury Instructions Tab F: Joint and Contested Jury Instructions Tab G: Joint and/or Contested Verdict Forms Tab H: Joint Exhibit List Tab I: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab J: Copies of all Current Operative Pleadings

CRITICAL

At least three tabbed, paginated sets of exhibit binders are required on the first day of trial: one set each for the Court, judicial assistant, and witness.

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 witness.

CRITICAL

Parties must provide a tabbed binder at the FSC containing all motions in limine, oppositions, and replies in sequential order matching each motion's assigned number.

As explained above, the parties and counsel must provide a tabbed binder at the FSC containing all motions in limine, oppositions, and replies in sequential order consistent with the number assigned to each motion in limine.

CRITICAL

Joint trial binder with tabbed sections for all trial documents must be provided to Court at Final Status Conference.

The parties and counsel shall provide a joint trial binder for the Court at the FSC. The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Motions in Limine Tab C: Joint Statement of the Case Tab D: Joint Witness List Tab E: Joint List of Jury Instructions Tab F: Joint and Contested Jury Instructions Tab G: Joint and/or Contested Verdict Forms Tab H: Joint Exhibit List Tab I: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab J: Copies of all Current Operative Pleadings

CRITICAL

Proposed orders lodged with the Court should be separate documents and must not include the proof of service.

Proposed orders lodged with the Court should be separate documents and must not include the proof of service.

CRITICALCivil cases

Format

DOCX

Please send an editable Word version to the court’s resource account SMCDept300@lacourt.ca.gov in the final format that will be actually presented to the jury.

Please send an editable Word version to the court’s resource account SMCDept300@lacourt.ca.gov in the final format that will be actually presented to the jury.

CRITICALCivil cases

Multi-page documentary exhibits must be internally paginated in sequential numerical order.

Documentary exhibits consisting of more than one page must be internally paginated in sequential numerical order.

CRITICAL

Format

DOCX

Verdict forms submitted to the clerk must be in MS Word format.

Please also submit the Verdict Form to the clerk via email (POMDeptEAO@LACourt.org) in MS Word format.

CRITICAL

Parties must comply with California Rules of Court Rule 2.1055 for jury instructions.

Parties are to abide by California Rules of Court Rule 2.1055.

CRITICAL

Applies to

Verdict form

Format

DOCX

Please also submit the Verdict Form to the clerk via email (POMDeptEAO@LACourt.org) in MS Word format.

Please also submit the Verdict Form to the clerk via email (POMDeptEAO@LACourt.org) in MS Word format.

CRITICAL

When ten or more exhibits will be used, exhibit copies must be placed in one or more 3-ring binders, with non-documentary exhibits represented by a simple written description.

If ten (10) or more exhibits are to be used, copies of the exhibits shall be placed in one or more 3-ring binders. Non- documentary exhibits shall be represented in the binder with a simple written description.

CRITICAL

Non-document exhibits must be identified with a page after the tab containing a disc, photograph, or description of the exhibit.

All non-document exhibits shall be identified with a page inserted after the tab with either a disc, a photograph or a description of the exhibit.

CRITICAL

The operative Complaint, Answers, Cross Complaints and Answers, and Stipulation of Facts must each be placed behind individual tabs in the Trial Binder.

Place behind individual tabs the operative Complaint; Answer(s); Cross Complaint(s) and Answer(s); and Stipulation of Facts.

CRITICAL

Format: The Trial Binder should have labels on the front and side, advising the Court as to the contents. The Trial Binder must have as the first page an Index to the Trial Binder.

Format: The Trial Binder should have labels on the front and side, advising the Court as to the contents. The Trial Binder must have as the first page an Index to the Trial Binder.

CRITICAL

Trial continuance requests must not use LASC CIV CTRL-242 or similar optional forms.

Requests for trial continuances shall not be made on LASC CIV CTRL-242 or any other similar “Optional” form.

CRITICAL

Exhibit Binders must have front/side labels, conformed joint exhibit list first, exhibits numbered and tabbed.

The parties shall jointly prepare three sets of evidentiary exhibit binders (a set for Judge, Judicial Assistant and Witness). The Exhibit Binders shall have labels on the front and side. EACH Exhibit Binder shall have a conformed copy of the Joint Exhibit List in front, followed by all exhibits numbered and tabbed.

CRITICAL

The Joint Witness List must be a single combined grid with alphabetized, deduplicated names, interpreter/accommodation notes, calling-party designations, and completed time estimates with sub-totals and grand total.

The Joint Witness List shall be on one grid. There should not be separate grids for plaintiff and defendant. The witness names should be alphabetized by last name and there should be no duplicates. Note whether the witness needs an interpreter, a reasonable accommodation, or has another special need. Designate which party is calling each witness. All time estimates must be filled in and sub-totals and a grand total completed.

CRITICAL

The Court requests that all electronically filed documents be bookmarked and searchable. (Local Rule 3.4.)

The Court requests that all electronically filed documents be bookmarked and searchable. (Local Rule 3.4.)

CRITICAL

Each Exhibit Binder must have a conformed Joint Exhibit List in front followed by all exhibits numbered and tabbed.

EACH Exhibit Binder shall have a conformed copy of the Joint Exhibit List in front, followed by all exhibits numbered and tabbed.

CRITICAL

Joint verdict forms must not bear any party's or counsel's name, and any separate proposed forms must each be preceded by a page identifying the proposing party.

The Joint Verdict Form(s) shall not have any party's or counsel's name thereon. If the parties cannot agree on a Joint Verdict Form, or if the verdict form will depend upon circumstances at trial, separate proposed forms are permitted. In that case, each party's proposed form shall be preceded by a page marked, e.g., "Plaintiff's Proposed Verdict Form" or "Defendant's Proposed Verdict Form."

CRITICAL

Each exhibit page must be internally paginated (e.g., 1-1, 1-2, 2-1) and show only ONE page number, with all other numbering covered or removed.

Each page of each exhibit must be internally paginated, e.g., 1-1; 1 2; 2-1, etc. Exhibits should have only ONE page number showing, and all others (e.g., deposition exhibit numbers or document production Bates numbers) should be covered up or otherwise removed.

CRITICAL

Multi-page documentary exhibits must be internally paginated in sequential numerical order.

In addition, documentary exhibits that consist of multiple pages must be internally paginated in sequential numerical order. This requirement is intended to facilitate clear and efficient reference to specific portions of an exhibit during the examination of witnesses.

CRITICAL

Trial Binder must have front/side labels and an index as the first page.

Format: The Trial Binder should have labels on the front and side, advising the Court as to the contents. The Trial Binder must have as the first page an Index to the Trial Binder.

CRITICAL

Exhibits must show only one page number per page; others must be covered.

Each page of each exhibit must be internally paginated, e.g., 1-1; 1 2; 2-1, etc. Exhibits should have only ONE page number showing, and all others (e.g., deposition exhibit numbers or document production Bates numbers) should be covered up or otherwise removed.

CRITICAL

Only pages of large exhibits likely to be used at trial may be included in the Exhibit Binder, and partial exhibits generally will not be admitted without good cause.

The parties shall refrain from including uncommonly large exhibits as a single exhibit if only a few pages are likely to be used at trial. In that case, only those pages should be included in the Exhibit Binder(s). The Court will generally not permit the admission of partial exhibits without good cause.

CRITICAL

Multi-page documentary exhibits must be internally paginated sequentially.

In addition, documentary exhibits that consist of multiple pages must be internally paginated in sequential numerical order.

CRITICAL

Copies of documentary exhibits must be one-sided.

Copies of documentary exhibits shall be one-sided copies.

CRITICAL

Transcript pages for deposition/trial designation must be submitted with numbered tabs separating each transcript and each designation highlighted using a distinct color per party.

The parties shall submit copies of the pages of the transcripts of the deposition or former testimony they are designating or counter-designating 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.

CRITICAL

The Trial Binder must consist of one-sided, conformed copies, tabbed and organized in a three-ring binder.

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 74 a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents

CRITICAL

Parties must jointly prepare four sets of tabbed, internally paginated, properly-marked exhibits organized numerically in three-ring binders.

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").

CRITICALCivil cases

Format

PAPER

The joint appendix shall be a hard copy submitted in accordance with the guidance below.

The joint appendix shall be a hard copy submitted in accordance with the guidance below.

CRITICALCivil cases

When a joint appendix is submitted, the complete record may be provided in electronic format (USB flash drive preferred), and any electronic-format record must be searchable by Bates-stamp number.

If the parties submit a joint appendix, the complete record may be submitted in electronic format (USB flash drive preferred). When the record is provided in electronic format, it must be searchable by Bates-stamp number.

CRITICALCivil cases

Applies to

Exhibit

Exhibits must be pre-marked with Arabic numerals and sequentially numbered per page if multi-page.

Pursuant to Local Rules 3.52 and 3.53, exhibits must be pre-marked using Arabic numerals and in instances where exhibits consist of multiple pages, each page must be numbered sequentially.

CRITICALCivil cases

Applies to

Exhibit binder

Tabbed, paginated exhibit binders are required for court, staff, witnesses, and opposing parties on first day of trial.

At least three sets of exhibit binders – tabbed and paginated – are required on the first day of trial: a set each for the Court, the judicial assistant, and the witness. Counsel must also supply an exhibit binder to each opposing party.

CRITICALCivil cases

Applies to

Motions in limine binder

Motions in limine must be submitted in a tabbed binder with table of contents at least five calendar days before trial.

At least five calendar days before the first day of trial, 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. The binder also must contain a table of contents identifying each motion in limine, opposition, and reply, and the corresponding tab for each.

CRITICALCivil cases

Exhibits must be pre-marked using Arabic numerals, and each page of multi-page exhibits must be numbered sequentially.

Pursuant to Local Rules 3.52 and 3.53, exhibits must be pre-marked using Arabic numerals and in instances where exhibits consist of multiple pages, each page must be numbered sequentially.

CRITICALCivil cases

Parties must jointly lodge tabbed, properly marked, internally paginated exhibit binders for inspection at the FSC and must mark all non-documentary exhibits with a written description behind the corresponding numerical tab.

The parties shall jointly prepare and lodge for inspection at the FSC 3-ring binders containing tabbed, properly marked exhibits, internally paginated, (At trial, the parties will need additional copies of the exhibits for the Court's clerk, for use on the witness stand, and for each counsel.) The parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit behind the corresponding numerical tab in the exhibit binder.

CRITICALCivil cases

Parties filing more than one motion in limine must number the motions consecutively.

Parties filing more than one motion in limine shall number them consecutively.

CRITICALCivil cases

The parties should submit three ring binders containing any motions in limine. The parties shall organize motions in limine (tabbed in numerical order) with the opposition papers and reply papers for each motion placed directly behind the moving papers. Sheets of colored paper should be used to separate moving papers from oppositions and oppositions from replies.

The parties should submit three ring binders containing any motions in limine. The parties shall organize motions in limine (tabbed in numerical order) with the opposition papers and reply papers for each motion placed directly behind the moving papers. Sheets of colored paper should be used to separate moving papers from oppositions and oppositions from replies.

CRITICALCivil cases

Declarations and/or exhibits filed with court papers must be tabbed.

declarations and/or exhibits must be tabbed. (Cal. Rules of Court, rule 3.1110(f).)

CRITICALCivil cases

Parties must jointly prepare and lodge 3-ring trial binders containing conformed copies 2 days before the Final Status Conference.

The parties shall jointly prepare and lodge 2 days prior to the Final Status Conference 3-ring binders containing one set of the conformed copies of all the following:

CRITICALCivil cases

All electronically filed documents must be text searchable and bookmarked, per the General Order re Mandatory Electronic Filing in Civil.

All electronically filed documents must be text searchable and bookmarked. (See operative General Order re Mandatory Electronic Filing in Civil, (http: lacourt.ca.gov/division/civil/pdf/GeneralOrderreMandatoryElectronicFilingforCivil.pdf.)

CRITICAL

Multi-page exhibits must have internally numbered pages corresponding to the exhibit number (e.g., 3.1, 3.2, 3.3).

If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3, etc.

CRITICAL

All trial binder documents must be signed conformed copies from counsel and self-represented parties, each placed behind a separate tab.

conformed copies of each of the following (each signed by counsel and parties representing themselves) behind a separate tab:

CRITICAL

Identical copies of the Exhibit List and all exhibits must be provided in 3-ring binders, one for each party, one for the Court, and one for the witness stand.

Identical copies of the Exhibit List and all exhibits must be provided in 3-ring binders as follows: one for each party, one for the Court, and one for the witness stand.

CRITICAL

Jury trial binders must be jointly prepared, tabbed and organized into 3-ring binders with a Table of Contents in the front, containing the required documents behind Tabs A through G.

For all jury trials, the parties/counsel shall jointly prepare and lodge a trial binder with the Court at least two (2) calendar days before the FSC, containing the required trial documents, tabbed and organized into 3-ring binders, with a Table of Contents in the front of each binder, as follows: Tab A: Trial Briefs of all parties Tab B: Joint Witness List Tab C: Joint Statement to be Read to the Jury Tab D: Joint Exhibit List Tab E: Joint List of Jury Instructions (identifying the agreed upon and contested instructions) Tab F: Joint and Contested Jury Instructions Tab G: Joint and/or Contested Verdict Forms

CRITICAL

Self-represented litigants must staple all papers separately before filing or the filings will be rejected.

All papers filed by self-represented litigants must be stapled separately before filing, or they will be rejected.

CRITICAL

Exhibits must be numbered or lettered using pre-agreed party ranges, each exhibit and subpart separately identified and listed, and each page of multi-page exhibits consecutively paginated.

Each exhibit shall be numbered or lettered. All parties shall agree in advance that their respective party will have a range of exhibit numbers or letters (e.g. Plaintiff No. 1: 1-99; Plaintiff No. 2: 100-199; Defendant: A-Z). Each exhibit must be separately identified. Subparts to an exhibit (e.g., 1A, 1B, etc.) must also be identified and listed separately. Each page of a multi-page exhibit must be consecutively paginated.

CRITICAL

All document exhibits must be placed in tabbed binders with each page numbered within each tab.

All document exhibits MUST be placed in binders under tabs, and each page must be numbered within each tab.

CRITICAL

The printed hard copy of jury instructions delivered to Department F49 must be on 2-hole punched, perforated paper so instruction identification can be separated from instruction text for jury deliberation.

The printed, hard copy of the jury instructions delivered directly to Department F49 shall be submitted on 2-hole punched, perforated paper so as to allow for separation of the identification of the instruction from the text of the instruction, to be submitted to the jury for reference during deliberation.

CRITICAL

Self-represented litigants must staple all papers separately before filing, or they will be rejected.

All papers filed by self-represented litigants must be stapled separately before filing, or they will be rejected.

CRITICAL

Printed jury instructions delivered to Dept F49 must be on 2-hole punched, perforated paper.

The printed, hard copy of the jury instructions delivered directly to Department F49 shall be submitted on 2-hole punched, perforated paper so as to allow for separation of the identification of the instruction from the text of the instruction, to be submitted to the jury for reference during deliberation.

CRITICAL

Format

DOCX

Proposed jury instructions must be prepared on form SCLAC LACIV 129 or a matching Word document format.

The proposedjury instructions shall be prepared on Superior Court of Los Angeles County form SCLAC LACIV 129 or in a Word document that is in the same format.

CRITICAL

Exhibit binders must be tabbed three-ring binders with one-sided copies, numerically organized exhibits, each with separate exhibit numbers.

The parties’ counsel and any self-represented parties shall work together to jointly prepare at least three sets of tabbed exhibit binders organized numerically in three-ring binders (Exhibit Binders): a set for the Court, a set for the Judicial Assistant, and a set for the witnesses, in addition to any sets necessary for each party. Copies of documentary exhibits shall be one-sided copies. All multi-page exhibits must have each page separately numbered. Separate documents and photographs shall not be grouped into one exhibit, but must be separately numbered with their own exhibit number.

CRITICALCivil cases

Format

DOCX

Counsel shall bring to Department P copies of all trial documents and an electronic version of the joint witness list, exhibit list, jury instructions, and verdict forms on a thumb/USB drive or CD disk with the documents in Microsoft Word format or compatible format. In the alternative, Counsel may email those documents directly to Department P.

Counsel shall bring to Department P copies of all trial documents and an electronic version of the joint witness list, exhibit list, jury instructions, and verdict forms on a thumb/USB drive or CD disk with the documents in Microsoft Word format or compatible format. In the alternative, Counsel may email those documents directly to Department P.

CRITICALCivil cases

All motions must comply with the California Code of Civil Procedure and California Rules of Court as to format and filing, or risk denial and/or sanctions.

The Court expects counsel 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 code sections or rules may result in denial of the motion and/or sanctions.

CRITICALCivil cases

MILs must comply with LASC Rule 3.57.

MILs must comply with LASC Rule 3.57.

CRITICALCivil cases

Each page of a multi-page exhibit must be consecutively paginated.

Each page of a multi-page exhibit must be consecutively paginated.

CRITICALCivil cases

Non-documentary exhibits must be represented in a binder with a simple written description.

Non-documentary exhibits shall be represented in a binder with a simple written description.

CRITICALCivil cases

Bulk exhibits such as voluminous medical records are not permitted; counsel must separately mark and identify the specific items within a bulk exhibit.

Bulk exhibits, e.g., voluminous medical records will not be permitted. Counsel must separately mark and identify the specific items within a bulk exhibit.

CRITICAL

Format

PAPER

All jury instructions must be submitted on perforated paper forms.

All instructions must be submitted on perforated paper forms.

CRITICAL

Exhibits must be consecutively paginated.

exhibit must be consecutively paginated.

CRITICAL

Exhibits should be numbered. 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., 1A, 1B, etc., must also be identified and listed separately.

Exhibits should be numbered. 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., 1A, 1B, etc., must also be identified and listed separately.

CRITICAL

Bulk exhibits such as voluminous medical records are not permitted, and specific items within any bulk exhibit must be separately marked and identified.

Bulk exhibits, e.g., voluminous medical records, will not be permitted. Counsel must separately mark and identify the specific items within a bulk exhibit.

CRITICAL

Each page of each exhibit must be internally paginated (e.g., 1-1; 1-2; 2-1).

Each page of each exhibit must be internally paginated, e.g., 1-1; 1 2; 2-1, etc.

CRITICAL

Parties must jointly prepare three sets of tabbed, internally paginated, numerically organized exhibits in three-ring binders (for the court, the Judicial Assistant, and the witnesses), with one-sided copies of documentary exhibits.

The parties’ counsel and any self-represented parties shall work together to jointly prepare three 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.

CRITICAL

The Trial Binder must consist of one-sided, conformed copies, tabbed and organized in a three-ring binder prepared in compliance with Exhibits 1–7 (pages 8–15).

consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder prepared in compliance with Exhibits 1 – 7, pages 8 - 15 below.

CRITICAL

Format

PDF

Each document accompanying a pleading must be filed as a separate digital PDF document.

Each document accompanying a single pleading must be filed as a separate digital PDF document;

CRITICAL

Non-document exhibits must be identified with a page inserted after the tab containing a disc, photograph, or description of the exhibit.

All non-document exhibits shall be identified with a page inserted after the tab with either a disc, a photograph or a description of the exhibit.

CRITICAL

additional questions should be in the same format as the standard voir dire questions in Trial Preparation Order, Exhibit 7, paragraph B (i.e., Yes or No answers with Yes answers leading to additional inquiry) and shall be included in the Trial Binder at TAB K.

additional questions should be in the same format as the standard voir dire questions in Trial Preparation Order, Exhibit 7, paragraph B (i.e., Yes or No answers with Yes answers leading to additional inquiry) and shall be included in the Trial Binder at TAB K.

CRITICAL

The Trial Binder must have front and side labels and an Index as the first page, both in the format of Trial Preparation Order Exhibit 1.

FORMAT: The Trial Binder shall have labels on the front and side in the format attached as Trial Preparation Order, Exhibit 1. The Trial Binder must have as the first page an Index to the Trial Binder, in the format attached as Trial Preparation Order, Exhibit 1.

CRITICAL

B. Exhibit Binder Plaintiff v. Defendant Case No. __________ Exhibit Binder(s) If there will be more than one Exhibit Binder, then label on the front and side, e.g., "Exhibit Binder I of IV - Exhibits 1 - 25."

B. Exhibit Binder Plaintiff v. Defendant Case No. __________ Exhibit Binder(s) If there will be more than one Exhibit Binder, then label on the front and side, e.g., "Exhibit Binder I of IV - Exhibits 1 - 25."

CRITICAL

Parties must not include uncommonly large exhibits as a single exhibit when only a few pages are likely to be used at trial; only those pages belong in the Exhibit Binder(s).

The parties shall refrain from including uncommonly large exhibits as a single exhibit if only a few pages are likely to be used at trial. In that case, only those pages should be included in the Exhibit Binder(s).

CRITICAL

No exhibit may be referenced by counsel or a witness unless pre-marked with an exhibit number, using Arabic numerals in distinct sequential blocks assigned per party.

No exhibit may be referenced by counsel or a witness unless it has been pre- marked with an exhibit number. The most efficient system for numbering exhibits is to use Arabic numerals, with each party assigned a distinct block of numbers to be applied sequentially. For example, the plaintiff might be assigned numbers 1 through 200, the first defendant numbers 201 through 400, and the second defendant numbers 401 through 600.

CRITICAL

Format

PDF

E-filed documents must be in PDF, text searchable format when technologically feasible without impairment of the document's image.

Electronic documents must be electronically filed in PDF, text searchable format when technologically feasible without impairment of the document’s image;

CRITICAL

Format

DOCX

Proposed jury instructions must be prepared on Los Angeles Superior Court form LASCIV 129 or in a Word document in the same format.

The proposed jury instructions shall be prepared on Los Angeles Superior Court form LASCIV 129 or in a Word document that is in the same format.

CRITICAL

Each Exhibit Binder must have a conformed Joint Exhibit List at the front followed by all exhibits numbered and tabbed.

EACH Exhibit Binder shall have a conformed copy of the Joint Exhibit List in front, followed by all exhibits numbered and tabbed.

CRITICAL

Trial continuance requests must not be made on LASC CIV CTRL-242 or any similar 'Optional' form.

Requests for trial continuances shall not be made on LASC CIV CTRL-242 or any other similar "Optional" form.

CRITICAL

Exhibit binders must not be labeled by party (e.g., 'Plaintiff's Exhibit Book I of III'); a single shared sequential labeling format (e.g., 'Exhibit Book I of V') is required.

Do NOT label them by party, e.g., "Plaintiff's Exhibit Book I of III" and "Defendant's Exhibit Book I of II" instead of "Exhibit Book I of V," etc.

CRITICAL

Parties must jointly prepare three sets of evidentiary exhibit binders (Judge, Judicial Assistant, Witness) with front and side labels formatted per Trial Preparation Order Exhibit 1.

The parties shall jointly prepare three sets of evidentiary exhibit binders (a set for Judge, Judicial Assistant and Witness). The Exhibit Binders shall have labels on the front and side in the format described in the Trial Preparation Order, Exhibit 1, see attached below.

CRITICAL

Trial and Exhibit Binders must use tabs placed on the right side (not the bottom) and may not contain stapled documents.

Tabs are required and must be on the right side, not the bottom. Do not put stapled documents in any of the binders.

CRITICAL

Trial binders must be labeled on the front and spine with 'Plaintiff v. Defendant', the case number, and either 'Trial Binder' or 'Trial Binder I – Tabs A - ___' identifying the last tab included.

LABELS ON FRONT AND SPINE OF TRIAL AND EXHIBIT BINDERS A. Trial Binder Plaintiff v. Defendant Case No. __________ Trial Binder or, Trial Binder I – Tabs A - ___ (e.g., Tab A – Tab K, or whichever is the last Tab in that binder

CRITICAL

Motions to compel further responses require a four-column joint statement with specified columns.

In the event a motion to compel further responses is filed, the parties are required to submit a JOINT STATEMENT consisting of a four-column document set up as follows: The first column will identify the number of the discovery request; the second, the text of the discovery request; the third, the text of the response; and the fourth, brief bullet-point statements, one from each party, as to why a further response should or should not be compelled.

CRITICAL

Parties must attach copies of the designated or counter-designated transcript pages to the joint chart, with numbered tabs separating each deposition or trial transcript.

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.

CRITICAL

The Motions in Limine Binder must contain one-sided conformed copies of all motions in limine, opposition, and reply papers in tabbed three-ring binders with colored separator 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 a colored sheet of paper separating the moving, opposition, and reply papers.

CRITICAL

Proposed jury instructions must be prepared on Superior Court of Los Angeles County form SCLAC LACIV 129 or in a Word document in the same format.

The proposed jury instructions shall be prepared on Superior Court of Los Angeles County form SCLAC LACIV 129 or in a Word document that is in the same format.

CRITICAL

FSC Exhibit Books must be 5 tabbed, indexed sets delivered to Dept. B.

6. Exhibit Books, 5 sets, tabbed and indexed, delivered to Dept. B

CRITICAL

Motions in limine must be placed in binders organized by MIL (plaintiff's MIL, defendant's opposition, reply), with the party filing more MILs providing the binders for the court.

Motions in Limine in binders in the following format: (1) plaintiffs MIL#1;(2) defendant's opposition to MIL#1; (3) reply to MIL #1, for all plaintiffs MILs, then the same format for all defendants MILs. The party who files more MILs is to provide binders for the court.

CRITICALCivil cases

Pre-Trial Document trial binders must be three-ring binders containing one-sided, conformed copies, tabbed, and must include a table of contents.

At least five days before the Final Status Conference, the parties shall submit to the court Pre-Trial Document trial binders (3-ring), consisting of one-sided, conformed copies, tabbed, with a table of contents of the following:

CRITICALCivil cases

For documents (other than transcripts of depositions or other pretrial or trial proceedings), the designating party must affix a 'Confidential' or 'Highly Confidential' legend on each page containing designated material.

For Documents (apart from transcripts of depositions or other pretrial or trial proceedings), the Designating Party must affix the legend “Confidential” or “Highly Confidential” on each page of any Document containing such designated material.

CRITICALCivil cases

Confidential or Highly Confidential designations must be clearly made before the material is disclosed or produced.

Any Documents, Testimony, or Information to be designated as “Confidential” or “Highly Confidential” must be clearly so designated before the Document, Testimony, or Information is Disclosed or produced.

CRITICALCivil cases

Format

DOCX

Separate Statements for summary judgment, summary adjudication, or discovery motions must be uploaded to FSX in Microsoft Word format.

Separate Statements for motions for summary judgement, summary adjudication, or discovery motions shall be uploaded to FSX in Microsoft Word.

CRITICALCivil cases

Format

PDF

All documents and correspondence uploaded to FSX must be in PDF format, except spreadsheets which may be uploaded in Excel format.

All documents and correspondence uploaded to FSX must be in .pdf format, except spreadsheets, which may be uploaded in Excel format.

CRITICALCivil cases

objections to evidence contained in a declaration that is filed in connection with a motion for summary judgment or summary adjudication shall be made by filing a copy of the declaration, annotated with the objections asserted and in a format, such as bold, underlined, italics, or highlighted text (but not different text color) so as to distinguish the objection from the original text of the declaration.

objections to evidence contained in a declaration that is filed in connection with a motion for summary judgment or summary adjudication shall be made by filing a copy of the declaration, annotated with the objections asserted and in a format, such as bold, underlined, italics, or highlighted text (but not different text color) so as to distinguish the objection from the original text of the declaration.

CRITICALCivil cases

All filed documents and documents served through eService must be in OCR searchable format.

All filed documents and documents served through eService must be in OCR searchable format.

CRITICALCivil cases

Proposed jury instructions must be prepared on Los Angeles Superior Court form LASC LACIV 129 or in a Word document in the same format.

The proposed jury instructions shall be prepared on Los Angeles Superior Court form LASC LACIV 129 or in a Word document that is in the same format.

CRITICAL

Parties must jointly prepare three sets of tabbed, internally paginated, properly marked exhibits in three-ring binders (max 3 inches) for the court, the Judicial Assistant, and the witnesses.

The parties' counsel and any self-represented parties shall work together to jointly prepare three sets of tabbed, internally paginated by document, and properly-marked exhibits, organized numerically in three-ring binders (not to exceed 3" per binder) (a set for the court, a set for the Judicial Assistant, and a set for the witnesses) ("Exhibit Binders").

CRITICAL

Proposed jury instructions must be placed in the trial notebook under a separate tab and prepared on LASC form LACIV 129 or an identically formatted Word document including the disposition box.

The proposed jury instructions shall be inserted into the trial notebook under a separate tab than the joint list of proposed jury instructions, and shall be prepared on Los Angeles Superior Court form LASC LACIV 129 or in a Word document that is in the same format including the disposition box.

CRITICAL

Electronic media evidence must be lodged on a flash drive because the court and jury cannot view CD/DVD format evidence.

The court does not have access to a CD or DVD player to view electronic evidence. Nor does the jury have access to any electronic evidence on CD/DVD format. Any evidence to be submitted on electronic media shall be lodged on a flash drive.

CRITICALCivil cases

Format

PDF

E-filed documents must be in text-searchable PDF form.

Documents must be electronically filed in PDF, text searchable form.

CRITICALCivil cases

Attachments to e-filed documents (depositions, declarations, exhibits, transcripts, points and authorities, and briefs) must be bookmarked per CRC 8.74; hyperlinks are suggested but not mandatory.

Attachments to primary documents including depositions, declarations, exhibits (including exhibits to declarations), transcripts (including excerpts), points and authorities, and supporting brief must be bookmarked and hyperlinks per California Rules of Court 8.74. Although bookmarks are mandatory, hyperlinks are suggested as well.

CRITICAL

Counsel and self-represented parties must jointly prepare three sets of tabbed, internally paginated, properly marked exhibits organized numerically in three-ring binders (for the court, the Judicial Assistant, and the witnesses).

The parties’ counsel and any self-represented parties shall work together to jointly prepare three 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”).

CRITICAL

Proposed jury instructions must be prepared on Superior Court of Los Angeles County form SCLAC LACIV 129 or in a Word document in the same format (sentence truncated in source).

The proposed jury instructions shall be prepared on Superior Court of Los Angeles County form SCLAC LACIV 129 or in a Word document that is in the same

CRITICALCivil cases

Format

PAPER

Hard copies of agreed and not-agreed jury instructions must be filed 5 court days before the final status conference.

Five court days before the final status conference, please file a “hard copy” of jointly agreed instructions, and each counsel's separate statement set of "not-agreed-upon" instructions with your objections.

CRITICALCivil cases

Format

DOCX

A computer disk in Word format of the agreed upon instructions should be brought to court on the first day of trial.

A computer disk in Word format of the agreed upon instructions should be brought to court on the first day of trial.

CRITICALCivil cases

Exhibits must be prepared in three-ring binders with numbered divider tabs, with copies for court, clerk, witnesses, and counsel, prior to trial.

Three-ring binders with numbered divider tabs containing all exhibits marked for identification must be prepared prior to trial, including copies for the Court, Clerk, testifying witnesses and all counsel.

CRITICALCivil cases

Tabbed three-ring binders containing all marked exhibits must be prepared before trial, with copies for the Court, Clerk, testifying witnesses, and all counsel.

Three-ring binders with numbered divider tabs containing all exhibits marked for identification must be prepared prior to trial, including copies for the Court, Clerk, testifying witnesses and all counsel.

CRITICALCivil cases

Demonstrative evidence and blow-ups must be marked for identification and shown or played for opposing counsel before trial.

Demonstrative evidence and blow-ups must be marked for identification and shown to or played for opposing counsel before trial.

CRITICALCivil cases

Exhibit marking must conform to S.C.L.A.C. Rule 3.53: Arabic numerals in sequential party-number blocks, with multi-page documentary exhibits internally paginated in sequential order.

Your joint exhibit list must conform to S.C.L.A.C. Rule 3.53, which provides: "The most efficient method of marking exhibits is the use of Arabic numerals in which each party is allocated a block of numbers to be used sequentially. For instance, plaintiff may be allocated numbers 1 to 200, the first defendant numbers 201 to 400, and the second defendant numbers 401 to 600. Documentary exhibits consisting of more than one page must be internally paginated in sequential numerical order to facilitate reference to the document during interrogation of witnesses."

CRITICALCivil cases

The notice of case resolution must be prepared on 28-lined legal paper.

The notice of case resolution shall be prepared on 28-lined legal paper to include caption, title, and case number.

CRITICALCivil cases

Requested jury instructions must be submitted on perforated paper so the instruction identification can be separated from the instruction text for the jury's reference during deliberations.

All requested instructions shall be submitted on perforated paper so as to allow for separation of the identification of the instruction from the text of the instruction, to be submitted to the jury for reference during deliberation.

CRITICALCivil cases

Jury instructions must be submitted on perforated paper to allow separation of instruction ID and text.

All requested instructions shall be submitted on perforated paper so as to allow for separation of the identification of the instruction from the text of the instruction, to be submitted to the jury for reference during deliberation.

CRITICALCivil cases

Notice of case resolution must be prepared on 28-lined legal paper.

The notice of case resolution shall be prepared on 28-lined legal paper to include caption, title, and case number.

CRITICALCivil cases

Multi-page documentary exhibits must be internally paginated in sequential numerical order.

Documentary exhibits consisting of more than one page must be internally paginated in sequential numerical order.

CRITICALCivil cases

Motions in limine should be submitted in a separate tabbed binder with a table of contents.

Motions in limine should be submitted in a separate tabbed binder with a table of contents.

CRITICALCivil cases

All exhibits must be exchanged and pre-numbered, except exhibits anticipated in good faith for impeachment or rebuttal.

Pursuant to California Rule of Court 3.1110(f) and Los Angeles County Superior Court Rules 3.52 and 3.53, all exhibits must be exchanged and pre-numbered, except for those anticipated in good faith to be used for impeachment or during rebuttal.

CRITICAL

Documentary exhibit copies must be one-sided.

Copies of documentary exhibits shall be one-sided copies.

CRITICAL

Trial exhibits must be placed in one or more 3-ring binders and properly marked.

The exhibits shall be placed in one or more 3-ring binders for ease of access and shall be properly marked.

CRITICAL

All electronically filed documents must be text searchable and bookmarked.

All electronically filed documents must be text searchable and bookmarked.

CRITICAL

Special instructions should be submitted in a format suitable for jury review, i.e., citations of authority and the identity of the requesting party shall be placed above the text.

Special instructions should be submitted in a format suitable for jury review, i.e., citations of authority and the identity of the requesting party shall be placed above the text.

CRITICAL

Attachments to primary documents, such as depositions, declarations, and exhibits, must be bookmarked.

Attachments to primary documents must be bookmarked (e.g. depositions, declarations, exhibits, etc.);

CRITICAL

The Motions in Limine Binder must contain one-sided conformed copies tabbed in numerical order in three-ring binders, with opposition/reply behind each motion separated by colored 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 a colored sheet of paper separating the moving, opposition, and reply papers.

CRITICAL

Format

PDF

Each document accompanying a single pleading must be filed as a separate digital PDF document.

Each document accompanying a single pleading must be filed as a separate digital PDF document;

CRITICAL

The table of contents for any filing must be bookmarked.

The table of contents for any filing must be bookmarked;

CRITICAL

Proposed jury instructions must be grouped behind Tab F of the Trial Binder, labeled by cover sheets, in the order of agreed-upon instructions, plaintiff's objected-to requests, then defendant's objected-to requests.

The parties shall organize proposed jury instructions into group 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.

CRITICAL

Deposition excerpts referenced in briefs must be marked on the transcripts attached as exhibits.

All deposition excerpts referenced in briefs must be marked on the transcripts attached as exhibits. (Cal. Rules of Court, rule 3.1116(c).)

CRITICAL

Format

PDF

Electronic documents must be e-filed in PDF format that is text searchable when technologically feasible without impairment of the document's image.

Electronic documents must be electronically filed in PDF, test searchable format when technologically feasible without impairment of the document's image;

CRITICAL

Electronic documents (including declarations, proofs of service, and exhibits) must be bookmarked per CRC 3.1110(f)(4), with links to each bookmarked item's first page and titles that identify and briefly describe the item.

Electronic documents, including but not limited to, declarations, proofs of service, and exhibits, must be bookmarked within the document pursuant to California Rules of Court, rule 3.1110(f)(4). Electronic bookmarks must include links to the first page of each bookmarked item (e.g. exhibit, declaration, deposition excerpt) and with bookmark titles that identify the bookmarked item and briefly describe the item;

CRITICAL

Parties must attach designated transcript page copies to the joint chart with numbered tabs separating each transcript, and each designation must be highlighted with each party using a different color highlighter.

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.

CRITICALCivil cases

Final jury instructions and verdict forms must be in a clean format suitable for jury deliberations, without citations to authority, party identification, or letterhead/markings identifying the attorney.

The final set of jury instructions and verdict fonns shall be in a fonnat suitable for submission to the jury during deliberations, and shall not include any citations to authority, identification of the party requesting the instruction or verdict, or any letterhead or markings identifying the attorney who prepared or printed them.

CRITICALCivil cases

Counsel may not ask Court staff to print or photocopy the jury instructions or verdict forms.

Counsel shall not ask the Court's staff to print or photocopy the jury instructions or verdict fonns.

CRITICALCivil cases

Parties must jointly prepare three sets of tabbed, internally paginated, numerically organized exhibits in three-ring binders, with one-sided copies of documentary exhibits.

The parties shall work together jointly to prepare three sets of tabbed, internally paginated and properly marked exhibits, organized numerically in three-ring binders for the Court (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.

CRITICALCivil cases

Format

PAPER

PowerPoint presentations and displays to the jury must be filed as paper copies.

PowerPoint presentations or other displays to the jury must be reduced to paper to be filed in the Court's docket.

CRITICALCivil cases

The FSC Trial Notebook must consist of one-sided, conformed copies tabbed and organized in a three-ring binder no larger than three inches.

consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder (no larger than three inches)

CRITICALCivil cases

Special jury instructions (from other sources, specially prepared, or substantially modified approved instructions) must be numbered consecutively per CRC rule 2.1055(b)(3).

"Special jury instructions, meaning instructions from other sources, those specially prepared by the party, or approved instructions that have been substantially modified by the party," must be numbered consecutively. (CRC, rule 2.1055(b)(3).)

CRITICALCivil cases

Designated and counter-designated transcript pages must be attached to the Joint Chart, with numbered tabs separating each deposition or trial transcript.

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.

CRITICALCivil cases

Courtesy copies must comply with CRC rule 3.1110(t): each exhibit must be separated by a tab extending below the bottom of the page bearing the exhibit designation, or the Court may continue the hearing or not consider the exhibits.

The courtesy copies must comply with CRC, rule 3.1110(t), which requires that each exhibit be separated by a tab extending below the bottom of the page bearing the exhibit designation. Failure to comply with this rule may result in the Court continuing the hearing or not considering the exhibits.

CRITICALCivil cases

All electronically filed documents must be text searchable and bookmarked.

All electronically filed documents must be text searchable and bookmarked. (See operative General Order re Mandatory Electronic Filing in Civil.)

CRITICALCivil cases

Each designation or counter-designation must be highlighted, with each party using a different color highlighter.

Each designation or counter-designation shall be highlighted, with each party using a different color highlighter.

CRITICALCivil cases

Proposed jury instructions must be organized into three cover-sheet-labeled groups: agreed instructions, plaintiff's contested requests, and defendant's contested requests.

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

CRITICALCivil cases

The FSC Notebook must be labeled on the face and spine with the case name, case number, FSC hearing date, and trial date.

The parties are to label the/ace and the spine of the Notebook with the case name, case number, FSC hearing date and Trial date.

CRITICALCivil cases

All electronically filed documents must be text searchable and bookmarked.

All electronically filed documents must be text searchable and bookmarked. (See operative General Order re Mandatory Electronic Filing in Civil.)

CRITICALCivil cases

Courtesy copies must have exhibits separated by tabs extending below the page, per CRC 3.1110(t).

The courtesy copies must comply with CRC, rule 3.1110(t), which requires that each exhibit be separated by a tab extending below the bottom of the page bearing the exhibit designation.

CRITICALCivil cases

The List of Proposed Jury Instructions must use the CRC rule 2.1055(b)(3) index format and include a checklist for the Court to indicate disposition of proposed instructions.

The List of Proposed Jury Instructions must be prepared in the index format required by CRC, rule 2.1055(b)(3), including a checklist for the Court to indicate the disposition of the proposed instructions.

CRITICALCivil cases

Exhibits must be pre-numbered numerically (plaintiffs start at 1, defendants at 101), with no letters, no grouping, multiple pages numbered, exchanged except impeachment exhibits.

All Exhibits must be pre-numbered (1, 2, 3, etc.) and exchanged except for those anticipated in good faith to be used for impeachment. (Rule 3.52.) Plaintiffs shall number exhibits beginning with Exhibit 1 and Defendants shall number exhibits beginning with Exhibit 101. Letters shall not be used. Letters shall not be used to designate subparts. Each separate exhibit shall bear only a numeric designation. (Rule 3.53.) Multiple page exhibits shall have page numbers on each page so as to facilitate reference to the document during interrogation of the witnesses. Separate documents shall not be grouped together as one exhibit or as subparts to one exhibit. Each shall be separately numbered.

CRITICALCivil cases

Parties must place exhibits in tabbed three-ring binders, with one binder for each party, clerk, judge, and witness stand (5 total in typical two-party cases).

The Parties shall place exhibits in three ring binders, with tabs to separate each exhibit. There shall be a binder for each party, the Court Clerk, the Judge and the witness stand. In a typical two-party case this shall require 5 separate, fully numbered and tabbed exhibit binders.

CRITICALCivil cases

Motions in limine must be submitted in writing rather than orally.

All Motions in limine must be in writing and be accompanied by a declaration in compliance with Local Rule 3.57.

CRITICALCivil cases

Exhibits must be placed in tabbed three-ring binders, with a separate binder for each party, the Court Clerk, the Judge, and the witness stand (five binders in a typical two-party case).

The Parties shall place exhibits in three ring binders, with tabs to separate each exhibit. There shall be a binder for each party, the Court Clerk, the Judge and the witness stand. In a typical two-party case this shall require 5 separate, fully numbered and tabbed exhibit binders.

CRITICALCivil cases

Plaintiff exhibits are numbered starting at Exhibit 1 and defendant exhibits at Exhibit 101 using numeric designations only; multi-page exhibits must be paginated and separate documents may not be grouped together.

Plaintiffs shall number exhibits beginning with Exhibit 1 and Defendants shall number exhibits beginning with Exhibit 101. Letters shall not be used. Letters shall not be used to designate subparts. Each separate exhibit shall bear only a numeric designation. (Rule 3.53.) Multiple page exhibits shall have page numbers on each page so as to facilitate reference to the document during interrogation of the witnesses. Separate documents shall not be grouped together as one exhibit or as subparts to one exhibit. Each shall be separately numbered.

CRITICAL

The Motions in Limine Binder must contain one-sided, conformed copies of all motions in limine, opposition, and reply papers, organized in tabbed three-ring binders with colored separator sheets between moving, opposition, and reply papers.

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.

CRITICAL

Each designation or counter-designation in the Joint Chart must be highlighted, with each party using a different color highlighter.

Each designation or counter-designation shall be highlighted, with each party using a different color highlighter.

CRITICAL

Parties must attach copies of the designated or counter-designated transcript pages to the Joint Chart, with numbered tabs separating each deposition or trial transcript.

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.

CRITICAL

Counsel and self-represented parties must jointly prepare at least five identical sets of tabbed exhibit binders organized numerically in three-ring binders (for the court, Judicial Assistant, witnesses, and each party).

The parties’ counsel and any self-represented parties shall work together to jointly prepare at least five identical sets of tabbed, exhibit binders organized numerically in three-ring binders (Exhibit Binders): a set for the court, a set for the Judicial Assistant, a set for the witnesses, and a set for each party.

CRITICAL

The Trial Binder must be a physical binder consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents.

No later than three calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department 510 a physical Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents

CRITICALCivil cases

Jury trial binders must comply with Standing Order ¶¶ 16-18 requirements.

The parties must comply strictly with the Standing Order, ¶¶ 16-18, regarding jury trial document preparation. Specifically, at the first date set for jury trial, the parties must bring to court a three-ring binder with table of contents and the documents below, clearly labeled, and behind separate tabs:

CRITICALCivil cases

At the first jury trial date, parties must bring a three-ring binder with a table of contents, with all required documents clearly labeled behind separate tabs.

The parties must comply strictly with the Standing Order, ¶¶ 16-18, regarding jury trial document preparation. Specifically, at the first date set for jury trial, the parties must bring to court a three-ring binder with table of contents and the documents below, clearly labeled, and behind separate tabs

CRITICALCivil cases

Jury trial parties must submit a tabbed three-ring binder with a table of contents and specified labeled documents.

at the first date set for jury trial, the parties must bring to court a three-ring binder with table of contents and the documents below, clearly labeled, and behind separate tabs: A – Operative Pleadings B – Joint Statement of the Case C – Motions in Limine D – Joint Witness List E – Joint Exhibits in exhibit books and Joint Exhibit List F – Joint Proposed Jury Instructions G – Joint Proposed Verdict Form H – Plaintiff’s Proposed Jury Instructions (disputed) I – Defendant’s Proposed Jury Instructions (disputed)

CRITICAL

Special jury instructions must be formatted for submission to the jury showing only the instruction number, title, and text, with no boxes or indication of the requesting party.

The parties/counsel shall prepare special 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).

CRITICAL

All exhibit pages must be Bates numbered sequentially using the format 'Exh. [number]-[page]'.

page must be “Bates” numbered sequentially. For example: if Exhibit 5 has 20 pages, “Exh. 5-012” would be the 12th page of Exhibit 5.

CRITICAL

Parties must have three-ring Trial Binders and Exhibit Binders (at least 4 Trial Binders and 5 Exhibit Binders) to be deemed ready for trial.

To be deemed ready for trial and immediate assignment to a trial court, parties and counsel shall have a three-ring TRIAL BINDER and EXHIBIT BINDER. The parties must have 5 Exhibit Binders and at least 4 Trial Binders.

CRITICAL

Trial and exhibit binders must be three-ring bound, with 5 exhibit binders and at least 4 trial binders required.

parties and counsel shall have a three-ring TRIAL BINDER and EXHIBIT BINDER. The parties must have 5 Exhibit Binders and at least 4 Trial Binders.

CRITICAL

For records exceeding 450 pages, the parties must submit the entire record on a Bates-searchable flash drive and also prepare and submit a joint appendix.

If the record exceeds 450 pages (including any transcripts), the parties shall (a) submit the entire record on a flash drive in a format searchable by Bates-Stamp number and (b) must also prepare and submit a joint appendix as described immediately below.

CRITICAL

The joint appendix must be in a three-inch spiral bound or three-ring binder, with each volume of a multi-volume appendix clearly labeled on its cover and/or spine.

The joint appendix must be submitted in a three-inch spiral bound or three-ring binder. If the joint appendix consists of more than one volume, each volume shall be clearly labeled on its cover and/or spine (e.g. Vol. 1 of ).

CRITICAL

For records of 450 pages or less, the parties must submit both an electronic copy and a hard copy binder containing the entire record.

If the record is 450 pages or less, the parties shall submit both (a) an electronic copy as explained in the following sentence; and (b) a hard copy binder containing the entire record.

CRITICAL

Joint appendix pages must be arranged in numerical Bates-stamped order regardless of which party cited the page.

The pages in the joint appendix shall be in numerical Bates-stamped order no matter which party cited the particular page.

CRITICAL

Margins

top 4 in

Proposed special jury instructions and any addenda to form instructions must leave at least four inches of blank space at the top of every page.

Leave at least four inches of blank space of the top of every page of any proposed special jury instructions, or any addenda to form instructions.

CRITICAL

Applies to

Proposed jury instruction

Proposed special jury instructions must have at least four inches of blank space at the top of each page.

Leave at least four inches of blank space of the top of every page of any proposed special jury instructions, or any addenda to form instructions.

CRITICAL

Exhibits must be separately numbered to correspond with the joint exhibit list, and multi-page exhibits must have internally numbered pages (e.g., 3.1, 3.2, 3.3).

Each exhibit must be separately numbered, with the numbers corresponding to the number of theexhibit on the joint exhibit list. If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3 etc.

CRITICAL

All trial exhibits must be placed in binders under tabs, with each page numbered (bate stamped) within each tab.

All exhibits MUST be placed in binders under tabs, and each page must be numbered (bate stamped) within each tab.

CRITICAL

Applies to

Deposition designation

Deposition page/line designation charts must be submitted in a three-ring binder with supporting transcripts.

The chart shall be submitted to the Court in a three-ring binder, along with all deposition transcripts necessary for the Court to rule on the objections.

CRITICAL

The Court requests that all electronically filed documents be bookmarked and searchable.

The Court requests that all electronically filed documents be bookmarked and searchable.

CRITICAL

Applies to

Exhibit

Exhibits must be separately numbered with internal page numbering for multi-page exhibits.

Each exhibit must be separately numbered, with the numbers corresponding to the number of the exhibit on the joint exhibit list. If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3 etc.

CRITICAL

Applies to

Proposed jury instruction

Proposed jury instructions must be submitted in an indexed tabbed binder with full text, CACI forms, and 4 inches of blank top margin.

The parties are to submit an indexed and tabbed three-ring binder containing (a) a joint set of instructions, (b) any instructions proposed by Plaintiff and objected to by Defendant; and (c) and instructions proposed by Defendant and objected to by Plaintiff. The parties shall provide the full text of all requested instructions (not just a list). Before submitting the instructions, counsel must fill in the blanks, make any appropriate modifications, and comply with LASC 3.170 – 3.171. Use CACI for form instructions. Leave at least four inches of blank space of the top of every page of any proposed special

CRITICAL

Applies to

Exhibit

Counsel must prepare separate exhibit sets for the Court, witness stand, and Judicial Assistant.

Counsel must prepare a separate set of exhibits for each of the Court, the witness stand, and the Judicial Assistant.

CRITICAL

Applies to

Motion in limine

Motion in limine papers must be bound in an indexed tabbed three-ring binder for lodging.

No later than five court days before the FSC, the moving party for each motion in limine must lodge directly in Dept. 54 an indexed and tabbed three-ring binder containing conformed copies of all moving, opposition, and reply papers for their motions in limine.

CRITICALCivil cases

Format

PDF

All filings must comply with the technical requirements set forth in the General Order (PDF, text searchable, bookmarked per CRC 31110(f)(4), hyperlinks, etc.).

All filings must comply with the technical requirements set forth in the General Order (PDF, text searchable, bookmarked per CRC 31110(f)(4), hyperlinks, etc.).

CRITICAL

Motions in Limine Binder must be three-ring binders with one-sided conformed copies, tabbed numerically, colored sheets separating papers.

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.

CRITICAL

Exhibit Binders require one-sided documentary copies, marked non-documentary exhibits with written descriptions behind tabs.

Copies of documentary exhibits shall be one-sided copies. 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.

CRITICAL

Each designation or counter-designation must be highlighted, with each party using a different color highlighter.

Each designation or counter-designation shall be highlighted, with each party using a different color highlighter.

CRITICAL

Parties must jointly prepare four sets of tabbed, internally paginated, properly marked exhibits organized numerically in three-ring binders (for the court, Judicial Assistant, and witnesses), with one-sided documentary exhibit copies and written descriptions of non-documentary exhibits behind the corresponding tabs.

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. 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.

CRITICAL

Format

PAPER

Jury trial binders must include tabbed sections A-H with specified documents; trial briefs are optional.

For jury trials, the trial binder shall include the following documents with tabs: A – Trial Briefs (Optional) B – Joint Statement of the Case Joint Witness List C – Joint Witness List D – Joint Exhibit List E – Joint List of Jury Instructions; [Written] Jury Instructions F – Joint or Contested Verdict Form G – Joint Chart of Page and Line Designations for Testimony H – Operative Pleadings

CRITICAL

Jury instructions may not use tear sheets and must not include the disposition box on the individual instruction page.

Do not use tear sheets for the instructions and do not include the disposition box on the page of the individual instruction.

CRITICAL

Bulk exhibits such as voluminous medical records are not permitted; counsel must separately mark and identify the specific items within a bulk exhibit.

Bulk exhibits, e.g., voluminous medical records will not be permitted. Counsel must separately mark and identify the specific items within a bulk exhibit.

CRITICAL

Non-documentary exhibits must be represented in a binder with a simple written description.

Non-documentary exhibits shall be represented in a binder with a simple written description.

CRITICAL

Each page of a multi-page exhibit must be consecutively paginated.

Each page of a multi-page exhibit must be consecutively paginated.

CRITICAL

The joint exhibit list must list exhibits to be offered using consecutive arabic numerals. See, LASCR 3.52 and 3.53. Documentary exhibits consisting of more than one page should be internally paginated in sequential numerical order to facilitate reference to the document during interrogation of witnesses (e.g., 1-2, 1-2, 1-3). Counsel should agree in advance that their respective party will have a range of exhibit numbers, e.g., Plaintiff 1-99; Defendant 100-199.

The joint exhibit list must list exhibits to be offered using consecutive arabic numerals. See, LASCR 3.52 and 3.53. Documentary exhibits consisting of more than one page should be internally paginated in sequential numerical order to facilitate reference to the document during interrogation of witnesses (e.g., 1-2, 1-2, 1-3). Counsel should agree in advance that their respective party will have a range of exhibit numbers, e.g., Plaintiff 1-99; Defendant 100-199.

CRITICAL

Format

DOCX

The verdict form submitted to the clerk must be in MS Word format.

Please also submit the Verdict Form to the clerk via email (WCC-Dept6@lacourt.org) in MS Word format.

CRITICAL

Each page of a multi-page exhibit must be consecutively paginated.

Each page of a multi-page exhibit must be consecutively paginated.

CRITICAL

Non-documentary exhibits must be presented in a binder with a simple written description.

Non-documentary exhibits shall be represented in a binder with a simple written description.

CRITICAL

Bulk exhibits such as voluminous medical records are not permitted; counsel must separately mark and identify the specific items within a bulk exhibit.

Bulk exhibits, e.g., voluminous medical records will not be permitted. Counsel must separately mark and identify the specific items within a bulk exhibit.

CRITICAL

Counsel must bring copies of all trial documents plus electronic versions of the joint witness list, exhibit list, jury instructions, and verdict forms on USB/CD in Microsoft Word format, or alternatively email them directly to Department M.

In addition, Counsel shall bring to Department M copies of all trial documents and an electronic version of the joint witness list, exhibit list, jury instructions, and verdict forms on a thumb/USB drive or CD disk with the documents in Microsoft Word format or compatible format. In the alternative, Counsel may email those documents directly to Department M.

CRITICALCivil cases

When there is more than one motion in limine, submit them tabbed and indexed in a three-ring binder, in numerical order and grouped with the corresponding opposition and reply.

Multiple (more than 1) Motions in Limine should be tabbed and indexed and submitted in a three ring binder containing copies of those motions in limine e-filed by each party in numerical order and grouped with corresponding opposition and reply.

CRITICALCivil cases

Exhibits must be pre-marked with numbers.

Pursuant to L.A. County Court Rules 3.52 and 3.53, the exhibits must be pre-marked using numbers.

CRITICALCivil cases

Each page of a multi-page exhibit must be sequentially Bates numbered.

In stances where an exhibit consists of multiple pages, each page must be “Bates” numbered sequentially.

CRITICAL

Papers filed directly by self-represented litigants must be stapled separately before filing or will be rejected.

All papers filed by self-represented litigants directly in the Clerk’s Office or courtroom must be stapled separately before filing or they will be rejected.

CRITICAL

Self-represented litigants must staple each paper separately before filing at the Clerk's Office or courtroom, or the papers will be rejected.

All papers filed by self-represented litigants directly in the Clerk's Office or courtroom must be stapled separately before filing or they will be rejected.

CRITICAL

Trial exhibits must be placed in tabbed binders with numbered pages, exhibit list included, and brought to court first day of trial.

TRIAL EXHIBITS: All document exhibits MUST be placed in binders under tabs, and each page must be numbered within each tab. The exhibit list must be included in the binders. Exhibits must be brought to the Court on the first day of trial.

CRITICAL

Trial document exhibits must be placed in binders under tabs with each page numbered within each tab.

All document exhibits MUST be placed in binders under tabs, and each page must be numbered within each tab.

CRITICAL

Copies of documentary exhibits must be one-sided.

Copies of documentary exhibits shall be one-sided copies.

CRITICAL

Trial binder must include a joint chart of deposition page/line designations behind Tab H and copies of the current operative pleadings behind Tab I.

TabH: Joint Chart of Page/Line Designations for Deposition/Former Testimony Tab I: Copies of the Current Operative Pleadings (including the operative complaint, answer, cross-complaint, if any, and answer to any cross-complaint).

CRITICAL

Format

DOCX

Each party must bring an electronic copy of its proposed verdict form in Word format to the Final Status Conference, ready to be edited in the courtroom.

each party must separately file a proposed verdict form, and bring an electronic copy of their proposed verdict form in Word to the FSC, ready to be edited in the courtroom

CRITICAL

Format

DOCX

Proposed jury instructions must be prepared on LASC form LACIV 129 or a Word document in the same format, including the disposition box.

The proposed jury instructions shall be prepared on Los Angeles Superior Court form LASC LACIV 129 or in a Word document that is in the same format including the disposition box.

CRITICAL

The Trial Binder must consist of one-sided conformed copies, tabbed, organized in a three-ring binder with a table of contents.

consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents

CRITICAL

Proposed jury instructions must be organized behind Tab F into three labeled groups: agreed-upon instructions, plaintiff's requested instructions to which defendant objects, and defendant's requested instructions to which plaintiff objects.

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.

CRITICAL

Parties must attach copies of designated transcript pages to the joint chart with numbered tabs separating each transcript, and each designation or counter-designation must be highlighted using a different color highlighter per party.

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.

CRITICAL

Motions in Limine Binder must be two-sided, conformed copies in 3" three-ring binders, tabbed, indexed, with colored separators.

The Motions in Limine Binder shall include two-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders not to exceed 3" per binder, indexed and 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.

CRITICAL

The Motions in Limine Binder must contain two-sided conformed copies in 3-inch three-ring binders, indexed and tabbed numerically with colored separator sheets, and must not include proposed orders.

The Motions in Limine Binder shall include two-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders not to exceed 3" per binder, indexed and 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. Proposed orders should not be included in the Motions in Limine Binder.

CRITICAL

Parties must jointly prepare five sets of tabbed, internally paginated, properly marked exhibits organized numerically in three-ring binders for the Court, Judicial Assistant, witnesses, and each party.

The parties’ counsel and any self-represented parties shall work together to jointly prepare five 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, a set for the witnesses, and a set for each party) (“Exhibit Binders”).

CRITICAL

Motions in Limine Binders must be three-ring bound, tabbed, one-sided, and lodged 5 calendar days before the Final Status Conference.

No later than five calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department 207 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 colored sheet of paper separating the moving, opposition, and reply papers.

CRITICAL

Trial Binders must be three-ring bound, tabbed, one-sided, include a table of contents, and be lodged 5 calendar days before the Final Status Conference.

No later than five calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department 207 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 only include the documents listed under Tabs A, B, C, H, and I):

CRITICAL

Parties filing more than one motion in limine must number the motions consecutively.

Parties filing more than one motion in limine shall number them consecutively.

CRITICAL

Parties must attach copies of the designated transcript pages to the joint chart, with numbered tabs separating each deposition or trial transcript.

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.

CRITICAL

Parties must attach copies of the designated transcript pages to the Joint Chart, with numbered tabs separating each deposition.

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

CRITICAL

Format

DOCX

Proposed jury instructions must be prepared on LA Superior Court form SCLAC LACIV 129 or in a Word document in the same format.

The proposed jury instructions shall be prepared on Superior Court of Los Angeles County form SCLAC LACIV 129 or in a Word document that is in the same format.

CRITICAL

Exhibit Binders must be three-ring bound, tabbed, internally paginated, one-sided, and five sets must be prepared.

The parties’ counsel and any self-represented parties shall work together to jointly prepare five 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, a set for the witnesses, and a set for each party) (“Exhibit Binders”). Copies of documentary exhibits shall be one- sided copies.

CRITICAL

Document exhibits must be placed in binders under tabs, with each page numbered within each tab.

All document exhibits MUST be placed in binders under tabs, and each page must be numbered within each tab.

CRITICAL

All document exhibits must be placed in tabbed binders with numbered pages, exhibit list included, and provided to judge, staff, and opposing counsel.

EXHIBITS: All document exhibits MUST be placed in binders under tabs, and each page must be numbered within each tab. The exhibit list must be included in the binders. Exhibits must be brought to Court on the first day of trial. Binders should be provided for the Judge, Judicial Assistant, Opposing Counsel and Reporter.

CRITICAL

Hard copy jury instructions must be on 2-hole punched, perforated paper.

The printed, hard copy of the jury instructions delivered directly to Department F43 shall be submitted on 2-hole punched, perforated paper so as to allow for separation of the identification of the instruction from the text of the instruction, to be submitted to the jury for reference during deliberation.

CRITICAL

All papers filed by self-represented litigants must be stapled separately before filing or will be rejected.

All papers filed by self-represented litigants must be stapled separately before filing, or they will be rejected.

CRITICAL

Self-represented litigants must staple each paper separately before filing, or the papers will be rejected.

All papers filed by self-represented litigants must be stapled separately before filing, or they will be rejected.

CRITICAL

The printed hard copy of jury instructions delivered to Department F43 must be on 2-hole punched, perforated paper so the instruction identification can be separated from the instruction text.

The printed, hard copy of the jury instructions delivered directly to Department F43 shall be submitted on 2-hole punched, perforated paper so as to allow for separation of the identification of the instruction from the text of the instruction, to be submitted to the jury for reference during deliberation.

CRITICAL

Format

PDF

Digital exhibits for the judge must be combined into a single PDF with the first page of every exhibit bookmarked with its exhibit number.

The digital copy for the judge must be in PDF format. All exhibits must be contained within one PDF. The first page of every exhibit must be bookmarked with the number of the exhibit.

CRITICAL

Paper exhibits for the clerk must be in a binder hard tabbed with exhibit numbers, and no exhibit may be used at trial unless the clerk has a copy.

The parties must provide the clerk with a paper or "hard" copy of every exhibit. No exhibit may be used during trial unless the clerk has a copy. The clerk's exhibits should be in a binder and must be hard tabbed with the exhibit number.

CRITICAL

Format

DOCX

An additional Word-format copy of proposed jury instructions must be provided on a flash drive, which will be returned after the court loads the document.

An additional copy must be provided to the court, Word format, on a portable storage device such as a flash drive. The device will be returned after the court has loaded the document.

CRITICAL

Proposed special jury instructions and addenda to form instructions must leave at least four inches of blank space at the top of every page.

Leave at least four inches of blank space of the top of every page of any proposed special jury instructions, or any addenda to form instructions.

CRITICAL

Each exhibit must be separately numbered to match the joint exhibit list, and multi-page exhibits must have internally numbered pages (e.g., 3.1, 3.2, 3.3).

Each exhibit must be separately numbered, with the numbers corresponding to the number of the exhibit on the joint exhibit list. If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3 etc.

CRITICALCivil cases

Exhibits must be separately numbered to match the joint exhibit list, multi-page exhibits must be internally numbered (e.g., 3.1, 3.2, 3.3), and documents with original or deposition-transcript page numbers must be renumbered for trial.

Each exhibit must be separately numbered, with the numbers corresponding to the number of the exhibit on the joint exhibit list. If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3 etc. Documents with original page numbers or that were attached to deposition transcripts shall be renumbered for use at trial.

CRITICALCivil cases

Margins

top 4 in

Proposed special jury instructions and addenda to form instructions must leave at least four inches of blank space at the top of every page.

Leave at least four inches of blank space of the top of every page of any proposed special jury instructions, or any addenda to form instructions.

CRITICAL

Parties offering deposition testimony must highlight the testimony they intend to offer in one color, the opposing party must countermark its intended testimony in a different color, and objected-to testimony must be highlighted in a separate color or boxed (except impeachment and where there is no objection to admission).

Each party intending to present any evidence by way of deposition testimony (except impeachment) shall do the following unless the parties have no objection to the admission of testimony: 1. Highlight the testimony the party intends to offer in one color. 2. The opposing party shall countermark (different color) any testimony it plans to offer. 3. Highlight in a separate color or draw a box around the objected testimony.

CRITICAL

Format

DOCX

Jury Instruction --Display Copy: The Court requests one electronic copy of the instructions to the Department's email box (LBCDeptS29@lacourt.org) for display to the jury in the following format: title and text in Word, landscape format, Arial font, 14pt font, no headers or footers - except title/CACI Numbers.

Jury Instruction --Display Copy: The Court requests one electronic copy of the instructions to the Department's email box (LBCDeptS29@lacourt.org) for display to the jury in the following format: title and text in Word, landscape format, Arial font, 14pt font, no headers or footers - except title/CACI Numbers.

CRITICAL

Format

DOCX

for display to the jury in the following format: title and text in Word, landscape format, Arial font, 14pt font, no headers or footers - except title/CACI Numbers.

for display to the jury in the following format: title and text in Word, landscape format, Arial font, 14pt font, no headers or footers - except title/CACI Numbers.

CRITICAL

Jury instructions must have all brackets removed and all blanks filled in advance (e.g., party names, gender, number) and each instruction must conform to Rule 2.1055 of the California Rules of Court.

Counsel must remove all brackets, fill in allblanks in advance. Examples are names of the parties, appropriate gender and number (singular or plural). Each instr�ction shall conform to the requirements of Rule 2.1055, California Rules of Court.

CRITICAL

Format

DOCX

An additional copy of the proposed verdict form must be provided to the court in Microsoft Word format on a portable storage device such as a flash drive, which will be returned after loading.

An additional copy must be provided to the court, in Microsoft Word format, on a portable storage device such as a flash drive. The device will be returned after the court has loaded the document.

CRITICAL

Exhibits must be pre-marked with the exhibit number and have a page number on each page.

The exhibits must be pre-marked with the exhibit number and a page number must appear on each page of the exhibit.

CRITICAL

Pre-marked Exhibits: The exhibits must be pre-marked with the exhibit number and a page number must appear on each page of the exhibit. 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 identified and listed separately.

Pre-marked Exhibits: The exhibits must be pre-marked with the exhibit number and a page number must appear on each page of the exhibit. 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 identified and listed separately.

CRITICAL

Format

DOCX

An additional copy must be provided to the court, in Microsoft Word format, on a portable storage device such as a flash drive.

An additional copy must be provided to the court, in Microsoft Word format, on a portable storage device such as a flash drive.

CRITICAL

As explained above, the parties and counsel must provide a tabbed binder at the FSC containing all motions in limine, oppositions, and replies in sequential order consistent with the number assigned to each motion in limine. The binder also must contain a table of contents identifying each motion in limine, opposition, and reply, and the corresponding tab for each.

As explained above, the parties and counsel must provide a tabbed binder at the FSC containing all motions in limine, oppositions, and replies in sequential order consistent with the number assigned to each motion in limine. The binder also must contain a table of contents identifying each motion in limine, opposition, and reply, and the corresponding tab for each.

CRITICAL

When 10 or more exhibits will be used, exhibit copies must be placed in one or more 3-ring binders, with non-documentary exhibits represented by a simple written description.

If ten (10) or more exhibits are to be used, copies of the exhibits shall be placed in one or more 3-ring binders. Non-documentary exhibits shall be represented in the binder with a simple written description.

CRITICAL

When more than one motion in limine is filed, each motion must be numbered consecutively.

If more than one motion in limine is filed, each shall be numbered consecutively.

CRITICALCivil cases

Exhibits must be pre-numbered, exchanged (except impeachment exhibits), placed in tabbed three-ring binders with party-specific numbering and no letter designations.

2. Exhibits. All Exhibits must be pre-numbered (1, 2, 3, etc.) and exchanged except for those anticipated in good faith to be used for impeachment. (Rule 3.52.) The Parties shall place exhibits in three ring binders, with tabs to separate each exhibit. There shall be a binder for each party, the Court Clerk, the Judge and the witness stand. In a typical two-party case this shall require 5 separate, fully numbered and tabbed exhibit binders. Plaintiffs shall number exhibits beginning with Exhibit 1 and Defendants shall number exhibits beginning with Exhibit 101. Letters shall not be used. Letters shall not be used to designate subparts. Each separate exhibit shall bear only a numeric designation. (Rule 3.53.) Multiple page exhibits shall have page numbers on each page so as to facilitate reference to the document during interrogation of the witnesses. Separate documents shall not be grouped together as one exhibit or as subparts to one exhibit. Each shall be separately numbered.

CRITICALCivil cases

Exhibits must be placed in tabbed three-ring binders, with a separate binder for each party, the Court Clerk, the Judge, and the witness stand (5 binders in a typical two-party case).

The Parties shall place exhibits in three ring binders, with tabs to separate each exhibit. There shall be a binder for each party, the Court Clerk, the Judge and the witness stand. In a typical two-party case this shall require 5 separate, fully numbered and tabbed exhibit binders.

CRITICALCivil cases

Plaintiffs number exhibits starting at 1 and Defendants starting at 101; letters are prohibited (including for subparts) and each separate exhibit must bear only a numeric designation.

Plaintiffs shall number exhibits beginning with Exhibit 1 and Defendants shall number exhibits beginning with Exhibit 101. Letters shall not be used. Letters shall not be used to designate subparts. Each separate exhibit shall bear only a numeric designation. (Rule 3.53.)

CRITICALCivil cases

Separate documents may not be grouped together as one exhibit or as subparts; each must be separately numbered.

Separate documents shall not be grouped together as one exhibit or as subparts to one exhibit. Each shall be separately numbered.

CRITICALCivil cases

Parties must attach copies of designated transcript pages to the Joint Chart with numbered tabs, keeping each transcript's designation pages in page order behind a single tab.

The parties shall attach a copy 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. For each transcript, all pages containing the designations and counter-designations shall be included in a single document in page order behind a single tab.

CRITICALCivil cases

Every page of every exhibit must be labeled with the exhibit number and page number in the format 'Exhibit 102-Pg. 001 of 017'.

Each page of each exhibit needs to be labelled to reflect the exhibit number and the individual page number as reflected by the total pages in the exhibit in the format below. Exhibit 102-Pg. 001 of 017

CRITICALCivil cases

Every designation and counter-designation must be highlighted, with each party using a different color highlighter.

Each designation and counter-designation shall be highlighted, with each party using a different color highlighter.

CRITICALCivil cases

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 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”).

CRITICALCivil cases

Proposed jury instructions must be prepared on LASC form LACIV 129 or a Word document in the same format.

The proposed jury instructions shall be prepared on the Superior Court of Los Angeles County form LASC LACIV 129 or in a Word document that is in the same format.

CRITICAL

Exhibits must be placed in 3-ring binders, properly marked, internally paginated, with non-documentary exhibits represented by a simple written description.

The exhibits shall be placed in one or more 3-ring binders for ease of access and shall be properly marked. Each exhibit shall be internally paginated. Non-documentary exhibits shall be represented in the binder with a simple written description.

CRITICALCivil cases

Exhibits to be used at trial should be provided in binders.

Exhibits to be used at trial should be provided in binders.

CRITICALCivil cases

Motions in limine and oppositions thereto must be filed in a separate notebook/binder.

Motions in Limine: These motions and opposition thereto must be filed in a separate notebook/binder.

CRITICALCivil cases

Each exhibit must be separately numbered, and multi-page exhibits must have internally numbered pages (e.g., Exh. 3, 3.1, 3.2).

NOTE: Each exhibit must be separately numbered. If an exhibit contains more than one page, the pages must be internally numbered, i.e. Exh. 3, 3.1, 3.2 etc.

CRITICAL

The Trial Binder must consist of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents.

consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents

CRITICAL

Parties must jointly prepare three sets of tabbed, internally paginated, properly marked exhibits in three-ring binders (court, Judicial Assistant, witnesses), with documentary exhibits copied one-sided.

The parties’ counsel and any self-represented parties shall work together to jointly prepare three 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.

CRITICAL

Proposed jury instructions must be prepared on LASC form LACIV 129 or in a Word document in the same format.

The proposed jury instructions shall be prepared on Los Angeles County Superior Court form LASC LACIV 129 or in a Word document that is in the same format.

CRITICAL

The Motions in Limine Binder must contain one-sided, conformed copies organized in tabbed three-ring binders in numerical order, with colored sheets separating moving, opposition, and reply papers.

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.

CRITICALCivil cases

Trial exhibits require 5 sets, tabs between exhibits, plaintiffs use numbers, defendants use letters or 101+.

Parties must bring 5 sets of labeled exhibits. Plaintiffs shall use numbers and defendants shall use letters. Binders must include tabs between exhibits. MUST USE TABS IN BETWEEN EXHIBITS. Plaintiffs use numbers, Defendants use alphabet letters or start with 101.

CRITICALCivil cases

For all trials, parties must bring 5 sets of labeled exhibits (plaintiffs use numbers, defendants use letters) and binders must include tabs between exhibits.

Trial Preparation - All trials must comply with the Local Rules and Unlawful Detainer Fourth Amended Standing Order. Parties must bring 5 sets of labeled exhibits. Plaintiffs shall use numbers and defendants shall use letters. Binders must include tabs between exhibits.

CRITICALCivil cases

Trial Documents: Must be according to Court Rules. Should include 5 sets of numbered trial exhibits. Plaintiffs use numbers, Defendants use alphabet letters or start with 101. MUST USE TABS IN BETWEEN EXHIBITS.

Trial Documents: Must be according to Court Rules. Should include 5 sets of numbered trial exhibits. Plaintiffs use numbers, Defendants use alphabet letters or start with 101. MUST USE TABS IN BETWEEN EXHIBITS.

CRITICALCivil cases

For jury trials, parties must meet and confer and comply with the general order, including having a joint binder, or the case will not be given a trial court assignment.

In addition, the parties are required to meet and confer and to comply with all aspects of the general order, including have a joint binder or the case will not be given a trial court assignment.

CRITICAL

All document exhibits must be placed in three-ring binders under numbered tabs, with each page numbered within its tab.

All document exhibits MUST be placed in three ring binders, under number tabs, and each page of the Exhibit must be numbered within each tab. (i.e. Exhibit 1 page 1, Exhibit 1/3, or 1.1, etc.)

CRITICAL

The Trial Binder must consist of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents.

consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents

CRITICAL

In the joint chart, each designating party's designations of deposition or former testimony shall include columns that 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

In the joint chart, each designating party's designations of deposition or former testimony shall include columns that 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

CRITICAL

Proposed jury instructions must be prepared on SCLAC form LASC LACIV 129 or in a Word document in the same format, including the disposition box.

The proposed jury instructions shall be prepared on SCLAC form LASC LACIV 129 or in a Word document that is in the same format including the disposition box.

CRITICAL

Parties must attach copies of the designated transcript pages to the joint chart, with numbered tabs separating each deposition or trial transcript.

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.

CRITICAL

The Motions in Limine Binder must contain two-sided conformed copies organized in tabbed, indexed three-ring binders no larger than 3 inches per binder with colored sheets separating moving, opposition, and reply papers.

The Motions in Limine Binder shall include two-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders not to exceed 3" per binder, indexed and 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.

CRITICAL

The final set of jury instructions must exclude the disposition table from the top of each instruction.

After the jury- instruction conference, the Court will require one of the parties to submit a final set of jury instructions approved by the Court, including any modifications ordered by the Court, and excluding the disposition table from the top of each instruction.

CRITICAL

Each designation or counter-designation must be highlighted, with each party using a different color highlighter.

Each designation or counter-designation shall be highlighted, with each party using a different color highlighter.

CRITICAL

Parties must jointly prepare three sets of tabbed, internally paginated (e.g., 5-1, 5-2), properly marked exhibits organized numerically in three-ring binders no larger than 3 inches for the Court, Judicial Assistant, and witnesses.

The parties' counsel and any self-represented parties shall work together to jointly prepare three sets of tabbed, internally paginated by document, and properly marked exhibits, organized numerically in three-ring binders (not to exceed 3" per binder) (one set for the Court, one set for the Judicial Assistant, and one set for the witnesses) ("Exhibit Binders"). For example, if exhibit 5 is a five-page document, its pages should be numbered 5-1, 5-2, 5-3.

CRITICAL

Copies of documentary exhibits must be one-sided.

Copies of documentary exhibits shall be one-sided copies.

CRITICAL

Counter-designations in the joint chart must include columns for the witness designation number/name, testimony date and type, page and line counter-designations, objections, the related designation number, and 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.

CRITICAL

Format

DOCX

Each party must bring an electronic Word copy of its proposed verdict form to the FSC, ready to be edited in the courtroom.

If after exhaustive meet and confer efforts the parties cannot agree on a joint verdict form, each party must separately file a proposed verdict form, and bring an electronic copy of their proposed verdict form in Word to the FSC, ready to be edited in the courtroom.

CRITICAL

Each motion in limine filing must include a separate summation page listing each motion's number and title.

A separate Summation Page must be included listing each Motion in Limine number and title.

CRITICALCivil cases

Each exhibit must be identified separately and Bates stamped. b. Bulk exhibits (e.g., "plaintiffs medical records") will not be permitted. Each page of a multi-page exhibit must be consecutively paginated (e.g., exhibit 1 will be 1-1, 1-2, etc.). c. Blow-ups of portions of exhibits will not be identified nor marked as a sub-part to the exhibit. Typically, a blow-up will not be admitted into evidence.

Each exhibit must be identified separately and Bates stamped. b. Bulk exhibits (e.g., "plaintiffs medical records") will not be permitted. Each page of a multi-page exhibit must be consecutively paginated (e.g., exhibit 1 will be 1-1, 1-2, etc.). c. Blow-ups of portions of exhibits will not be identified nor marked as a sub-part to the exhibit. Typically, a blow-up will not be admitted into evidence.

CRITICALCivil cases

Each exhibit must be separately identified and Bates stamped; bulk exhibits are prohibited and each page of a multi-page exhibit must be consecutively paginated.

Each exhibit must be identified separately and Bates stamped. b. Bulk exhibits (e.g., "plaintiffs medical records") will not be permitted. Each page of a multi-page exhibit must be consecutively paginated (e.g., exhibit 1 will be 1-1, 1-2, etc.).

CRITICALCivil cases

Format

DOCX

Please submit the Special Verdict to the clerk via email in MS Word format.

Please submit the Special Verdict to the clerk via email in MS Word format.

CRITICALCivil cases

Motions in limine must be in writing, numbered, and filed/served per Local Rule 3.25(f)(2).

MOTIONS IN LIMINE must be in writing, numbered, and shall be filed and served on opposing parties in accordance with Local Rule 3.25(f)(2).

CRITICAL

Parties filing motions in limine must also submit a 3-ring binder notebook containing all motions, oppositions, and replies, with a Table of Contents and tab dividers for each numbered motion.

Separate Notebooks Are Required for All Motions in Limine: In addition to filing electronically, the party filing the motion(s) in limine must also submit a 3-ring binder notebook containing all motions, oppositions, and replies. The notebook must have both a Table of Contents and tab dividers to separate each numbered motion and its corresponding opposition and reply.

CRITICAL

Unlawful Detainer trial exhibits must be in tabbed binders with numbered pages and exhibit list; binders should be provided to judge, judicial assistant, opposing counsel, and reporter.

Exhibits: All document exhibits MUST be placed in binders under tabs, and each page must be numbered within each tab. The exhibit list must be included in the binders. Exhibits must be brought to Court on the first day of trial. Binders should be provided for the Judge, Judicial Assistant, Opposing Counsel and Reporter.

CRITICAL

Identical copies of the exhibit list and all exhibits must be provided in 3-ring binders — one for each party, one for the Court, and one for the witness stand.

Identical copies of the Exhibit List and all exhibits must be provided in 3-ring binders as follows: one for each party, one for the Court, and one for the witness stand.

CRITICAL

Document exhibits must be placed in tabbed binders with pages numbered within each tab and the exhibit list included in the binder.

All document exhibits MUST be placed in binders under tabs, and each page must be numbered within each tab. The exhibit list must be included in the binders.

CRITICAL

Jury trial parties must submit a 3-Ring Trial Binder containing the documents in items 4.b through 4.g with a table of contents.

h. 3-Ring Trial Binder containing all the documents above in 4.b through 4.g, with a table of contents.

CRITICAL

A 3-ring trial binder containing all the listed jury trial documents with a table of contents must be filed.

3-Ring Trial Binder containing all the documents above with a table of contents.

CRITICAL

The printed hard copy of jury instructions delivered to Department F44 must be on 2-hole punched, perforated paper so instruction identification can be separated from instruction text for jury deliberation.

The printed, hard copy of the jury instructions delivered directly to Department F44 shall be submitted on 2-hole punched, perforated paper so as to allow for separation of the identification of the instruction from the text of the instruction, to be submitted to the jury for reference during deliberation.

CRITICAL

All exhibits sought to be admitted must be placed in Exhibit Notebooks.

All exhibits sought to be admitted by the parties shall be placed in Exhibit Notebooks.

CRITICAL

Format

PAPER

Printed jury instructions must be on 2-hole punched perforated paper with specified identifying information for each instruction.

The printed, hard copy of the jury instructions delivered directly to Department F44 shall be submitted on 2-hole punched, perforated paper so as to allow for separation of the identification of the instruction from the text of the instruction, to be submitted to the jury for reference during deliberation. All requested CACI instructions, per the foregoing, must be submitted in proper form which includes: A) At the top of each requested jury instruction, identification of the party/parties requesting the instruction; B) Whether the instruction is to be given as requested or modified; C) Whether the instruction is withdrawn; and D) A signature line for the Court.

CRITICAL

Applies to

Proposed jury instruction

Margins

top 4 in

Proposed special jury instructions must have at least 4 inches of blank space at the top of every page.

Leave at least four inches of blank space at the top of every page of any proposed special jury instructions, or any addenda to form instructions.

CRITICAL

Each exhibit must be separately numbered to match the joint exhibit list, and multi-page exhibits must have internally numbered pages (e.g., 3.1, 3.2, 3.3).

Each exhibit must be separately numbered, with the numbers corresponding to the number of the exhibit on the joint exhibit list. If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3 etc.

CRITICAL

At least four inches of blank space must be left at the top of every page of proposed special jury instructions and addenda to form instructions.

Leave at least four inches of blank space at the top of every page of any proposed special jury instructions, or any addenda to form instructions.

CRITICALCivil cases

Exhibit books delivered for the Final Status Conference must be tabbed and indexed.

Delivered-5 Sets of Exhibit Books, tabbed and indexed, and delivered to Dept. T.

CRITICALCivil cases

Stipulations reached at an Informal Discovery Conference must be in writing.

Any stipulations at an Informal Discovery Conference shall be in writing.

CRITICALCivil cases

Non-documentary trial exhibits must be represented in a binder with a simple written description.

Non-documentary exhibits shall be represented in a binder with a simple written description.

CRITICALCivil cases

Jury instructions must not be three-hole punched or placed in a binder and must be assembled into three stacks (agreed-upon; plaintiff's objected-to; defendant's objected-to).

They are not to be three-hole punched and not to be placed in a binder. They are to be assembled into stacks: (1) an agreed-upon stack; (2) a stack, if any, of plaintiff's instructions to which defendant objects; and (3) a stack, if any, of defendant's instructions to which plaintiff objects.

CRITICALCivil cases

Exhibit binders must be labeled with the case name and number, and each binder must be labeled 'Judicial Assistant,' 'Judge,' or 'Witness.'

The binders should be labeled with the name and case number for the case, and each binder shall be labeled "Judicial Assistant," "Judge," or "Witness."

CRITICAL

Reply separate statements are not recognized by the Rules of Court and will not be considered by the court.

Reply separate statements are not provided for in the Rules of Court and will not be considered.

CRITICALCivil cases

When filing the Trial Documents, the parties must lodge by 4 p.m. an indexed, tabbed three-ring Trial Readiness Binder with copies of all Trial Documents and motions in limine, plus indexed and tabbed Exhibit Binders.

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.

CRITICALCivil cases

IDC forms must not include attached documents, miniscule font, or text exceeding the allotted space.

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.

CRITICALCivil cases

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.

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).

CRITICALCivil cases

A motion may be rejected for failure to comply with tabbing rules.

Your motion could be rejected for failure to comply with the rules regarding tabbing.

CRITICALCivil cases

For jury trials, the joint stipulated-facts list must be written in a non-legalistic form and tone suitable for reading to the jury.

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.

CRITICALCivil cases

Proposed jury instructions must be jury-ready and contain only the instruction number, title, and text, without boxes or requester, revision-date, or tear-off markings.

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.)

CRITICAL

Margins

top 4 in

Proposed special jury instructions and addenda to form instructions must leave at least four inches of blank space at the top of every page.

Leave at least four inches of blank space at the top of every page of any proposed special jury instructions, or any addenda to form instructions.

CRITICAL

Parties must prepare binder(s) for the Clerk containing pre-numbered exhibits, with each exhibit inserted behind a numbered tab matching the exhibit number on the joint exhibit list per LASC Rule 3.52.

The parties will prepare a binder, or set of binders, for the Clerk containing pre-numbered exhibits. LASC Rule 3.52. Each exhibit will be inserted behind a numbered tab, with the numbers corresponding to the number of the exhibit on the joint exhibit list.

CRITICAL

Parties must attach tabbed copies of designated transcript pages to the joint chart, highlight each designation with a party-distinct color, and label lodged transcript spines with witness name, date, and volume number.

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. Deposition transcripts lodged with the Court should be labeled with the witness's name, date, volume number on the spine (e.g., "John Doe, 12/24/20, Vol. 1 of 3"), as well as the case name and number if it fits.

CRITICAL

Parties must jointly prepare at least five sets of tabbed, numerically organized three-ring exhibit binders: one for the Court, the Judicial Assistant, the witnesses, and each party.

The parties’ counsel and any self-represented parties shall work together to jointly prepare at least five sets of tabbed, exhibit binders organized numerically in three-ring binders (Exhibit Binders): a set for the Court, a set for the Judicial Assistant, a set for the witnesses, and a set for each party.

CRITICAL

The Motions in Limine Binder must be marked with the case caption, number, and title, contain conformed copies of all MIL papers, and be organized in tabbed three-ring binders with opposition/reply papers directly behind each motion separated by colored sheets.

The Motions in Limine Binder shall be marked with the case caption, number, and title on its front and spine and shall include 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.

CRITICAL

Format

DOCX

Briefs and reply briefs must be submitted on Microsoft Word in a cut-and-paste friendly format (no dragged rules/numbering/footers) so the court can prepare its tentative decision.

and reply briefs on Microsoft Word in a format from which the court may cut and paste without dragging the brief’s rule and numbering or footers, so that the court can prepare its tentative decision.

CRITICAL

The joint appendix must be a single three-ring binder (preferably three-inch) or a binder spiral bound on the side.

The joint appendix shall consist of a single three- ring binder -- preferably a three-inch binder -- or a binder that is spiral bound on the side.

CRITICAL

The mandamus trial notebook must be a one- or three-inch three-ring binder lodged when the reply brief is filed, containing only the bates-stamped agency decision, the parties' briefs, and requests for judicial notice separated by labeled tabs, with documentary evidence included (with exhibit tabs, possibly in separate binders) only in traditional mandamus cases.

The trial notebook shall be in a one or three-inch, three-ring binder as appropriate and lodged with the court when the reply brief is filed. The trial notebook shall contain only copies of the bates- stamped agency decision, the parties’ briefs, and any requests for judicial notice. The documents should be separated by labeled tabs. Except in traditional mandamus cases, documentary evidence should not be included in the trial notebook. In traditional mandamus cases, the trial notebook shall have documentary evidence with exhibit tabs, which may be in a separate three-ring binder(s) if voluminous.

CRITICAL

The parties' joint statement of the case must be concise and not exceed two paragraphs.

The parties shall submit a concise— not to exceed two paragraphs—neutral statement of the case.

CRITICAL

All trial exhibits must be exchanged and pre-numbered, except exhibits anticipated in good faith for impeachment or rebuttal.

all exhibits must be exchanged and pre-numbered, except for those anticipated in good faith to be used for impeachment or during rebuttal

CRITICAL

Multi-page documentary exhibits must be internally paginated in sequential numerical order.

Documentary exhibits consisting of more than one page must be internally paginated in sequential numerical order.

CRITICAL

Counsel and self-represented parties must jointly prepare four sets of properly marked exhibits, tabbed, internally paginated by document, and numerically organized in three-ring binders.

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”).

CRITICAL

Documentary exhibits must be copied one-sided.

Copies of documentary exhibits shall be one-sided copies.

CRITICAL

Exhibits longer than one page must be internally paginated.

Note: Any exhibits greater than one page must be internally paginated.

CRITICAL

The Motions in Limine Binder must contain one-sided, conformed copies organized in numerical order in three-ring binders, with each motion’s opposition and reply directly behind it and separated by colored 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 a colored sheet of paper separating the moving, opposition, and reply papers.

CRITICAL

The Trial Binder must consist of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents; for court trials without a jury, it includes only Tabs A, B, C, H, and I.

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):

CRITICAL

Format

PDF

Electronically filed documents must be text-searchable PDFs, and specified attachments to primary documents must be bookmarked and hyperlinked.

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.

CRITICAL

Every document associated with a motion must display the reservation number associated with that motion.

All parties to a motion must place the reservation number associated with the motion on each document associated with that motion.

CRITICAL

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.

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.

CRITICAL

Bulk exhibits such as voluminous medical records are not permitted; specific items within them must be separately marked and identified.

Bulk exhibits, e.g., voluminous medical records, will not be permitted. Counsel must separately mark and identify the specific items within a bulk exhibit.

CRITICAL

Format

PAPER

All jury instructions must be submitted on perforated paper forms.

All instructions must be submitted on perforated paper forms.

CRITICAL

Format

PDF

E-filed documents must be PDF text searchable when technologically feasible.

Documents must be electronically submitted in PDF text searchable format when technologically feasible without impairment of the document’s image.

CRITICAL

Format

PDF

Accompanying documents must be submitted as separate PDF digital documents.

Accompanying documents must be electronically submitted as a separate digital document in PDF format.

CRITICAL

Proposed jury instructions must be printed on one side only, one instruction per page.

Jury Instructions (Joint and Contested) – The parties/counsel shall prepare a complete set of full-text proposed jury instructions, printed on one side only, with one instruction per page, editing all proposed California Civil

CRITICAL

Format

PDF

E-filed documents must be submitted in PDF text-searchable format when technologically feasible without impairment of the document's image.

Documents must be electronically submitted in PDF text searchable format when technologically feasible without impairment of the document's image.

CRITICAL

Exhibits must be pre-marked with Arabic numerals and multi-page exhibits must have sequentially numbered pages, per Local Rules 3.52 and 3.53.

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.

CRITICAL

Table of contents for any submitted document must be bookmarked.

The table of contents for any document submitted must be bookmarked.

CRITICAL

Electronic documents (declarations, proofs of service, exhibits) must be bookmarked with links to first page and descriptive titles.

Electronic documents, including but not limited to declarations, proofs of service, and exhibits or attachments, must be bookmarked within the document pursuant to California Rules of Court, rule 3.1110(f)(4). Electronic bookmarks must include links to the first page of each bookmarked item (e.g., exhibits, declarations, deposition excerpts) and with bookmark titles that identify the bookmark item and briefly describe the item.

CRITICAL

Proposed jury instructions must be a complete full-text set printed one side only, one instruction per page, with irrelevant material edited out.

The parties/counsel shall prepare a complete set of full-text proposed jury instructions, printed on one side only, with one instruction per page, editing all proposed California Civil irrelevant material.

CRITICAL

Format

PDF

Proposed orders must be submitted in PDF and Word formats, with Word as a separate document in the same electronic transaction.

Proposed Orders must be in both PDF and Word versions. The Word version must be submitted as a separate document in the same electronic envelope/transaction. (Cal. Rules of Court, rule 3.1312.)

CRITICAL

Format

PDF

Proposed orders must be submitted in both PDF and Word versions, with the Word version filed as a separate document in the same electronic envelope.

Proposed Orders must be in both PDF and Word versions. The Word version must be submitted as a separate document in the same electronic envelope/transaction.

CRITICAL

Writs and abstracts must be submitted in a separate electronic envelope.

Writs and abstracts must be submitted in a separate electronic envelope.

CRITICAL

Exhibits must be pre-marked with Arabic numerals, page numbered, exchanged 5 days before FSC, lodged first day of trial, 5 tabbed/paginated sets required.

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. 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. At least five sets of exhibit binders – tabbed and paginated – are required on the first day of trial: a complete set each for the Court, the judicial assistant, and the witness. Counsel must also supply an exhibit binder to each opposing party, and one for counsel themselves.

CRITICAL

Proposed jury instructions must be organized behind Tab F in a specified order (agreed-upon instructions first, then plaintiff's requested instructions objected to by defendant, then defendant's requested instructions objected to by plaintiff), with each group labeled by cover sheets.

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.

CRITICAL

Parties must jointly prepare four sets of tabbed, paginated, numerically organized exhibits in three-ring binders, with one-sided documentary exhibit copies.

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.

CRITICAL

The Trial Binder must consist of one-sided conformed copies tabbed and organized in a three-ring binder.

consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents

CRITICAL

The Motions in Limine Binder must contain one-sided conformed copies in three-ring binders, tabbed in numerical order with opposition and reply papers placed behind each motion and tabs separating moving, opposition, and reply papers.

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.

CRITICAL

Counsel and self-represented parties must jointly prepare four sets of tabbed, internally paginated, properly marked exhibits organized numerically in three-ring binders (for the court, the Judicial Assistant, and the witnesses).

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”).

CRITICAL

The Motions in Limine Binder must contain one-sided conformed copies of all motions in limine, opposition, and reply papers, organized in tabbed three-ring binders in numerical order with opposition and reply papers placed directly behind the moving papers.

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

CRITICALCivil cases

If there are more than five motions in limine, the parties must submit a separate notebook containing the motions.

If there are more than five motions in limine, the parties must submit a separate notebook containing the motion,

CRITICALCivil cases

In court trials, all trial documents must be tabbed and placed in a notebook that includes a table of contents.

All the trial documents must be tabbed and placed in a notebook that includes a table of contents.

CRITICAL

Trial counsel must submit typed jury instructions on perforated paper with all titles above the perforation.

TRIAL COUNSEL MUST SUBMIT TYPED JURY INSTRUCTIONS ON PERFORATED PAPER. ALL TITLES MUST BE ABOVE THE PERFORATION.

CRITICALCivil cases

Exhibits must be pre-marked with Arabic numerals, and each page of multi-page exhibits must be numbered sequentially.

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.

WARNING

In matters with voluminous documentary evidence, parties should Bates stamp all exhibit pages using one consecutive numbering sequence across the entire submission rather than restarting with each exhibit.

In matters involving lengthy exhibits, business records, contracts, account statements, or other voluminous documentary evidence, parties should Bates stamp all exhibit pages using a single, consecutive numbering sequence throughout the entire submission, rather than restarting the numbering with each exhibit.

WARNING

Trial exhibit binders must be tabbed, internally paginated by document, properly marked and identified as trial exhibits, and organized numerically in three-ring binders.

Exhibit binders must be tabbed, internally paginated by document, and properly marked and identified as trial exhibits, organized numerically in three-ring binders.

WARNING

Exhibits must be bate stamped and tabbed with exhibit numbers matching the joint exhibit list.

Exhibits must be bate stamped and tabbed with exhibit numbers that correspond to those on the joint exhibit list.

WARNINGCivil cases

Motions in limine must be ordered with plaintiff's papers first followed by defendant's, separated by numbered tabs, with colored sheets of paper between the motion and opposition and between the opposition and any reply.

Whether in a separate binder or Tab B, Plainti ’s should come first, followed by those of Defendant. There should be numbered tabs separating each motion and colored sheets of paper between the motion and any opposition and between the opposition and any reply.

WARNINGCivil cases

The trial binder must be tabbed and organized in the specified order: Tab A Trial Briefs, Tab B Motions in Limine, Tab C Joint Statement of the Case, Tab D Joint Witness List, Tab E Joint List of Jury Instructions, Tab F Full Text Jury Instructions, and Tab G Verdict Forms.

The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Motions in Limine Tab C: Joint Statement of the Case Tab D: Joint Witness List Tab E: Joint List of Jury Instructions (joint and contested) Tab F: Full Text Jury Instructions Tab G: Joint and/or Contested Verdict Forms

WARNING

The MIL notebook must include a Table of Contents and tab dividers separating each numbered motion and its corresponding opposition and reply.

The notebook must have both a Table of Contents and tab dividers to separate each numbered motion and its corresponding opposition and reply.

WARNING

Trial binders must be tabbed, organized into 3-ring binders, and contain a Table of Contents in the front of each binder.

containing the required trial documents, tabbed and organized into 3-ring binders, with a Table of Contents in the front of each binder

WARNING

pages, it should have a “-“ (dash) delineating each page. For example, if Exhibit 1 consists of 3 pages, it would be numbered as follows: Exhibit 1-1, 1-2, and 1-3.

pages, it should have a “-“ (dash) delineating each page. For example, if Exhibit 1 consists of 3 pages, it would be numbered as follows: Exhibit 1-1, 1-2, and 1-3.

WARNING

Format

DOCX

An electronic version of the jury instructions in Word format must be submitted on a thumb drive.

Please submit an electronic version of the jury instructions in Word format in a thumb drive.

WARNING

Proposed jury instructions should be divided into two packages separated by a colored sheet of paper: agreed-upon instructions and disputed instructions.

The instructions should be divided into two packages separated by a colored sheet of paper: those agreed upon, and those that are disputed.

WARNING

Format

DOCX

An electronic version of the verdict form in Word must be submitted on a thumb drive.

Submit an electronic version of the verdict form in Word on a thumb drive.

WARNING

A party responding to a Kennemur objection at trial must be prepared with the page and line marked in deposition testimony and attorney communications showing the objecting party had reasonable advance notice of any departing opinion.

Any party responding to a Kennemur v. State of California (1982) 133 Cal.App.3d 907 objection at trial must be prepared to have the page and line marked in any deposition testimony and any attorney communication demonstrating that the objecting party had reasonable advance notice of any opinion that departs from the prior notice.

WARNING

All non-documentary exhibits must be marked and a simple written description of each inserted behind the corresponding numerical tab in the Exhibit Binders.

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.

WARNING

Parties filing more than one motion in limine must number the motions consecutively.

Parties filing more than one motion in limine shall number them consecutively.

WARNING

Each designation and counter-designation in the Joint Chart must be highlighted, with each party using a different color highlighter.

Each designation and counter-designation shall be highlighted, with each party using a different color highlighter.

WARNING

The court's yellow evidence tags (filled in with only the case number and exhibit number) must be placed on each exhibit in the Judicial Assistant's copy of the Exhibit Binder.

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.

WARNING

Name on signature line of Joint Case Management Conference Statement Addendum must be typed or printed.

(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)

WARNING

The Trial Binder must consist of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents.

a Trial Binder, consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents

WARNING

Documentary exhibit copies must be one-sided.

Copies of documentary exhibits shall be one-sided copies.

WARNINGCivil cases

Motions in limine should be numbered sequentially by each side for easy reference.

Motions in limine should be numbered sequentially by each side for easy reference.

WARNINGCivil cases

Blow-ups of exhibit portions may not be marked as sub-parts and typically will not be admitted; the actual exhibits do not need to be submitted for the FSC.

Blow-ups of portions of exhibits will not be identified nor marked as a sub-part to the exhibit. Typically, a blow-up will not be admitted into evidence. The actual exhibits do not need to be submitted for the FSC.

WARNING

Jury instructions must be in jury-ready format (number, title, and text only, with no tear sheets, boxes, or requesting-party indications) and divided into two packages separated by a colored sheet: agreed and disputed.

The parties/counsel shall prepare special instructions in a format ready for submission to the jury with the instruction number, title, and text only (i.e., there should be no tear sheets and no boxes or other indication on the printed instruction itself as to the requesting party).The instructions should be divided into two packages separated by a colored sheet of paper: those agreed upon, and those that are disputed.

WARNING

Format

DOCX

An electronic version of the jury instructions in Word format must be submitted on a thumb drive.

Please submit an electronic version of the jury instructions in Word format in a thumb drive.

WARNING

Exhibit notebooks must be three-ring binders available on the final status conference date, with the exhibit list in front, tabs matching exhibit numbers, and internally numbered pages for multi-page exhibits.

Three-ring binders containing all exhibits must be available on the final status conference date, and all parties must be prepared to tell the Court that they have had an opportunity to review all documents in the exhibit notebooks. Place a copy of the exhibit list in the front of each exhibit notebook and place tabs in the notebook to correspond with the exhibit number. If an exhibit contains more than one page, pages must be internally numbered, i.e., 3.1, 3.2, 3.3, etc.

WARNING

Format

DOCX

An electronic version of the verdict form in Word format must be submitted on a thumb drive.

Submit an electronic version of the verdict form in Word on a thumb drive.

WARNING

Blow-ups of exhibit portions should be identified and marked as sub-part A and typically will not be admitted into evidence.

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.

WARNING

Proposed special jury instructions and addenda to form instructions must leave at least four inches of blank space at the top of every page.

Leave at least four inches of blank space of the top of every page of any proposed special jury instructions, or any addenda to form instructions.

WARNING

The first paragraph of the IDC memorandum must be formatted starting with (1) a neutral statement of the dispute, with additional required elements continuing in the next part of the document.

The first paragraph shall be formatted as follows: (1) a neutral statement of the dispute; and (2)

WARNING

Counsel must prepare three separate sets of exhibits: one for the Court, one for the witness stand, and one for the Judicial Assistant.

Counsel must prepare a separate set of exhibits for each of the Court, the witness stand, and the Judicial Assistant.

WARNING

Exhibits must be separately numbered to match the joint exhibit list, and multi-page exhibits must have internally numbered pages (e.g., 3.1, 3.2, 3.3).

Counsel must comply with SCLAC Rules 3.52, 3.53 and 3.151. Each exhibit must be separately numbered, with the numbers corresponding to the number of the exhibit on the joint exhibit list. If an exhibit contains more than one page, the pages must be internally numbered, i.e., 3.1, 3.2, 3.3 etc.

WARNING

Each party should select a block of exhibit numbers. For example, plaintiff may take exhibits numbers 1-200 and defendant may take exhibit numbers 201-400. Documents consisting of more than one page should be internally paginated and sequentially marked (e.g., 1-1; 1-2; 1-3). For ease of reference, the exhibits should follow a rational order that tracks the witnesses to be called.

Each party should select a block of exhibit numbers. For example, plaintiff may take exhibits numbers 1-200 and defendant may take exhibit numbers 201-400. Documents consisting of more than one page should be internally paginated and sequentially marked (e.g., 1-1; 1-2; 1-3). For ease of reference, the exhibits should follow a rational order that tracks the witnesses to be called.

WARNING

If certain portions of the instruction are the subject of dispute as opposed to the instruction generally, the portion that is the subject of dispute should be highlighted.

If certain portions of the instruction are the subject of dispute as opposed to the instruction generally, the portion that is the subject of dispute should be highlighted.

WARNING

If the motions in limine are voluminous, parties must submit a separate labeled motion in limine notebook following the same internal format.

If the motions in limine are voluminous, the parties shall submit a separate motion in limine notebook, labeled accordingly, that follows the same internal format as described above.

WARNING

CRC rule 2.1055 governs the form in which proposed jury instructions must be prepared.

CRC, rule 2.1055 governs the form in which the jury instructions must be prepared.

WARNING

Jury instructions should not include a tear-away box at the top of the page and should be in the format that will be sent to the jury.

The jury instructions should not have a “tear-away” box at the top of the page. The jury instruction should be in the format that will be sent to the jury.

WARNING

The FSC Trial Notebook must consist of one-sided, conformed copies, tabbed and organized in a three-ring binder no larger than three inches.

consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder (no larger than three inches)

WARNING

Special jury instructions (from other sources, specially prepared, or substantially modified) must be numbered consecutively per CRC rule 2.1055(b)(3).

“Special jury instructions, meaning instructions from other sources, those specially prepared by the party, or approved instructions that have been substantially modified by the party,” must be numbered consecutively. (CRC, rule 2.1055(b)(3).)

WARNING

Counsel must supply an additional exhibit binder to each opposing party.

Counsel must also additionally supply an exhibit binder to each opposing party.

WARNING

Trial exhibits must be pre-marked with Arabic numerals and each page of multi-page exhibits must be numbered sequentially.

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.

WARNING

The Court requests that all electronically filed documents be bookmarked and searchable.

The Court requests that all electronically filed documents be bookmarked and searchable. (Local Rule 3.4.)

WARNING

Parties must jointly prepare four tabbed, internally paginated, numerically organized exhibit sets in three-ring binders, with one-sided copies for documentary exhibits.

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.

WARNING

The LACIV 094 form must describe the discovery dispute in font no smaller than 12-point, double or one-and-a-half spaced, and no attachments are allowed.

On LACIV 094 briefly describe the nature of the discovery dispute in font no smaller than 12-point, double or one-and-a-half spaced in the area provided on the form. No attachments are allowed.

WARNING

The Trial Binder must contain one-sided conformed copies, tabbed and organized in a three-ring binder with a table of contents.

consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder with a table of contents

WARNING

The Motions in Limine Binder must contain one-sided conformed copies of all motion papers, arranged in tabbed three-ring binders with colored separators.

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.

WARNINGCivil cases

Each volume of a multi-volume joint appendix must be clearly labeled on its cover and/or spine (e.g., Vol. 1 of ___).

If the joint appendix consists of more than one volume, each volume shall be clearly labeled on its cover and/or spine (e.g. Vol. 1 of

WARNINGCivil cases

Joint appendix pages must be arranged in numerical Bates-stamped order regardless of which party cited them.

The pages in the joint appendix shall be in numerical Bates-stamped order no matter which party cited the particular page.

WARNINGCivil cases

The traditional mandamus joint appendix must be Bates-numbered consecutively and briefs must refer to evidence by the joint appendix Bates numbers.

Such joint appendix shall be bates-numbered consecutively, and the parties shall refer in their briefs to the evidence by the joint appendix Bates numbers.

WARNINGCivil cases

The joint appendix must be submitted in a three-inch spiral bound or three-ring binder.

The joint appendix must be submitted in a three-inch spiral bound or three-ring binder.

WARNINGCivil cases

Such proposed judgment and writ of mandate should substantially conform to the suggested Form of Judgment and Form of Writ at the end of this document.

Such proposed judgment and writ of mandate should substantially conform to the suggested Form of Judgment and Form of Writ at the end of this document.

WARNINGCivil cases

The trial binder must be organized with Tab A (Trial Briefs), Tab B (Joint Statement of the Case), Tab C (Joint Witness List), Tab D (Joint List of Jury Instructions), and Tab E (Joint and Contested Jury Instructions).

The trial binder shall be organized as follows: Tab A: Trial Briefs Tab B: Joint Statement of the Case Tab C: Joint Witness List Tab D: Joint List of Jury Instructions Tab E: Joint and Contested Jury Instructions

WARNINGCivil cases

Discovery requests and responses should not be marked as exhibits.

Discovery requests and responses should not be marked as exhibits.

WARNING

Exhibits should be numbered consecutively in the lower right-hand corner, with each page delineated by a dash (e.g., Exhibit 1-1, 1-2, 1-3).

Those exhibits can be numbered consecutively in the lower, right-hand corner of each document. Each page should be given an exhibit number, so that if an exhibit contains multiple pages, it should have a "-"(dash) delineating each page. For example, if Exhibit 1 consists of 3 pages, it would be numbered as follows: Exhibit 1-1, 1-2, and 1-3.

WARNING

The motions in limine notebook must include a Table of Contents and tab dividers separating each numbered motion and its corresponding opposition and reply.

The notebook must have both a Table of Contents and tab dividers to separate each numbered motion and its corresponding opposition and reply.

WARNING

Oppositions to motions in limine must refer to the numbers used by the moving party.

The opposition must refer to the numbers used by the moving party.

WARNING

Motions in limine must be in writing and numbered.

All motions in limine, if any, must be in writing, numbered, and shall be served on all opposing parties and counsel and electronically filed at least ten (10) calendar days before the FSC.

WARNING

Proposed jury instructions must be organized behind Tab F with agreed instructions first, followed by contested instructions.

The parties shall organize proposed jury instructions behind Tab F, with the agreed upon instructions first in order followed by the contested instructions (including special instructions) submitted by each party.

WARNING

Motions in Limine Binders must be organized in tabbed three-ring binders in numerical order with opposition and reply papers placed directly behind the moving papers and colored separator sheets between the moving, opposition, and reply papers.

The Motions in limine Binder(s) shall include 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.

WARNING

Proposed jury instructions must be prepared on Los Angeles Superior Court form SCLAC LACIV 129 or in a Word document in the same format.

The proposedjury instructions shall be prepared on Superior Court of Los Angeles County form SCLAC LACIV 129 or in a Word document that is in the same format.

WARNING

The Trial Binder must be a physical, tabbed three-ring binder containing conformed copies with a table of contents.

On the date of the Final Status Conference, the parties' counsel and any self-represented parties must jointly prepare and lodge in Department P a physical Trial Binder, consisting of conformed copies, tabbed and organized in a three-ring binder with a table of contents that includes the following:

WARNING

Documentary exhibits must be one-sided copies.

Copies of documentary exhibits shall be one-sided copies.

WARNINGCivil cases

Format

DOCX

an electronic version of the joint witness list, exhibit list, jury instructions, and verdict forms on a thumb/USB drive or CD disk with the documents in Microsoft Word format or compatible format. In the alternative, Counsel may email those documents directly to Department P.

an electronic version of the joint witness list, exhibit list, jury instructions, and verdict forms on a thumb/USB drive or CD disk with the documents in Microsoft Word format or compatible format. In the alternative, Counsel may email those documents directly to Department P.

WARNINGCivil cases

MILs and trial motions should be numbered consecutively with a caption that clearly and concisely identifies the subject of the motion.

MILs and other trial motions should be numbered consecutively, with a caption that clearly and concisely identifies the subject of the motion.

WARNINGCivil cases

Blow-ups of exhibit portions should be identified and marked as sub-part A, and typically will not be admitted into evidence.

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.

WARNING

Blow-ups of portions of exhibits should be identified and marked as sub-part A.

Blow-ups of portions of exhibits should be identified and marked as sub-part A.

WARNING

The table of contents for any filing must be bookmarked.

The table of contents for any filing must be bookmarked;

WARNING

Parties filing more than one motion in limine must number the motions consecutively.

Parties filing more than one motion in limine shall number them consecutively.

WARNING

TRIAL BINDER INDEX TAB DOCUMENT A Trial Briefs B Motions in Limine C Joint Statement of the Case D Joint Witness List E Joint Exhibit List F Joint and Disputed Jury Instruction List G Jury Instructions (Full Text) H Verdict Forms I Deposition and Former Testimony Transcript Designations J Operative Pleadings and Stipulations K Proposed Additional Voir Dire Questions for the Court

TRIAL BINDER INDEX TAB DOCUMENT A Trial Briefs B Motions in Limine C Joint Statement of the Case D Joint Witness List E Joint Exhibit List F Joint and Disputed Jury Instruction List G Jury Instructions (Full Text) H Verdict Forms I Deposition and Former Testimony Transcript Designations J Operative Pleadings and Stipulations K Proposed Additional Voir Dire Questions for the Court

WARNING

Attachments to primary documents, such as depositions, declarations, and exhibits, must be bookmarked.

Attachments to primary documents must be bookmarked (e.g. depositions, declarations, exhibits, etc.);

WARNING

Multi-page documentary exhibits must be internally paginated in sequential numerical order.

In addition, documentary exhibits that consist of multiple pages must be internally paginated in sequential numerical order.

WARNING

All non-documentary exhibits must be marked and a simple written description of each inserted behind the corresponding numerical tab in the Exhibit Binder.

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 Binder.

WARNING

Electronic documents (including declarations, proofs of service, and exhibits) must be bookmarked per CRC 3.1110(f)(4), with links to each bookmarked item's first page and titles that identify and briefly describe the item.

Electronic documents, including but not limited to, declarations, proofs of service, and exhibits, must be bookmarked within the document pursuant to California Rules of Court, rule 3.1110(f)(4). Electronic bookmarks must include links to the first page of each bookmarked item (e.g. exhibit, declaration, deposition excerpt) and with bookmark titles that identify the book marked item and briefly describe the item;

WARNING

Designating parties must attach the designated transcript pages to the joint chart with numbered tabs separating each transcript, and highlight each designation using a different color highlighter per party.

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.

WARNING

Copies of all designated transcript pages must be attached to the designation form with different color markings for each party's designations and objections.

Copies of all pages of each transcript so designated shall be attached to the form, annotated with different color markings for Plaintiff's designation, Defendant's objection and Defendant's designation and Plaintiff's objection.

WARNING

All exhibits must be pre-numbered in advance of trial, except exhibits anticipated to be used solely for impeachment.

All exhibits must be exchanged between the parties and pre- numbered in advance of the trial, except those exhibits that are reasonably and in good faith anticipated to be used solely for purposes of impeachment.

WARNING

The court's yellow evidence tags (with only the case number and exhibit number filled in) must be placed on each exhibit in the Judicial Assistant's set; the sentence continues on the next page.

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

WARNING

Exhibits should have only ONE page number showing, and all others (e.g., deposition exhibit numbers or document production Bates numbers) should be covered up or otherwise removed.

Exhibits should have only ONE page number showing, and all others (e.g., deposition exhibit numbers or document production Bates numbers) should be covered up or otherwise removed.

WARNING

Each designation or counter-designation in the joint chart must be highlighted, with each party using a different color highlighter.

Each designation or counter-designation shall be highlighted, with each party using a different color highlighter.

WARNING

Documentary exhibits must be copied one-sided.

Copies of documentary exhibits shall be one-sided copies.

WARNINGCivil cases

The final submission must be lodged via USB drive, with hard copy/paper in 3-ring binders only if requested by the court.

At least five days before the Final Status Conference, the testimony designating party must lodge with the court via USB drive (and/or hard copy/paper in 3 ring binders, if requested by the court):

WARNINGCivil cases

Responses to the Standard Request for Production must identify responsive documents by Bates stamp number, and each produced document must be Bates stamped with the defendant name abbreviation, the request number, and the page numbers produced.

Defendant shall respond to oOo each request, by identifying the specific documents that are responsive to the request by Bates stamp number. Each document produced must be Bates stamped with 1) an abbreviation for BS the Defendants’ name; 2) the number of the request for production; and 3) the pages produced for that request.

WARNINGCivil cases

Parties should submit transcripts in proper paginated form, with one page of testimony per printed page. If only a .txt version of the transcript is available, parties must paginate the transcript (in Word, for example) and print it to PDF, so that each page of the transcript corresponds to a single page of the document. Condensed transcripts, with four pages per sheet, are difficult to process electronically and are disfavored.

Parties should submit transcripts in proper paginated form, with one page of testimony per printed page. If only a .txt version of the transcript is available, parties must paginate the transcript (in Word, for example) and print it to PDF, so that each page of the transcript corresponds to a single page of the document. Condensed transcripts, with four pages per sheet, are difficult to process electronically and are disfavored.

WARNINGCivil cases

Documents produced after the initial production must be labeled in consecutive Bates stamp number order.

Any DH BR DH documents that are subsequently produced must be labeled in consecutive Bates stamp number order.

WARNINGCivil cases

Testimony transcripts highlighted to correspond with the designations. Parties should use light colors for highlighting, as dark colors make the text illegible.

Testimony transcripts highlighted to correspond with the designations. Parties should use light colors for highlighting, as dark colors make the text illegible.

WARNINGCivil cases

In circumstances where portions of the deposition Testimony are designated for protection, the transcript pages containing "Confidential" or "Highly Confidential" Information may be separately bound by the court reporter, who must affix to the top of each page the legend "Confidential" or "Highly Confidential," as instructed by the Designating Party.

In circumstances where portions of the deposition Testimony are designated for protection, the transcript pages containing "Confidential" or "Highly Confidential" Information may be separately bound by the court reporter, who must affix to the top of each page the legend "Confidential" or "Highly Confidential," as instructed by the Designating Party.

WARNINGCivil cases

Confidential or Highly Confidential deposition testimony may be designated either by identifying the qualifying portions on the record before the close of the deposition or by designating the entirety of the deposition testimony.

For Testimony given in depositions the Designating Party may either: i. identify on the record, before the close of the deposition, all "Confidential" or "Highly Confidential" Testimony, by specifying all portions of the Testimony that qualify as "Confidential" or "Highly Confidential;" or ii. designate the entirety of the Testimony at the deposition as

WARNINGCivil cases

Three charts in Word or Adobe format (and/or hard copy if ordered) must be organized separately by tier, with a separate set of charts submitted for each transcript.

Three charts, in Word® or Adobe® format, (and/or hard copy/paper, if ordered by the court) organized separately into Tier One, Tier Two and Tier Three, in the matrix set forth below containing the designation, objection, counter-designation, and response to counter-designation, together with a column on the far right side of the chart for the court's rulings. A separate set of charts should be submitted for each transcript.

WARNINGCivil cases

The “Confidential” or “Highly Confidential” designation should not obscure or interfere with the legibility of the designated Information.

The “Confidential” or “Highly Confidential” designation should not obscure or interfere with the legibility of the designated Information.

WARNINGCivil cases

In the joint proposed preference case trial setting order, competing provisions must be placed adjacent to one another with a bracket identifying each provision's proponent.

Competing provisions should be placed adjacent to one another, together with a bracket identifying the proponent of the provision.

WARNING

Copies of documentary exhibits must be one-sided.

Copies of documentary exhibits shall be one-sided copies.

WARNING

The joint chart must include attached transcript pages separated by numbered tabs, with each designation or counter-designation highlighted in a different color per party.

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.

WARNING

The Motions in Limine Binder must contain two-sided conformed copies organized in tabbed three-ring binders (max 3 inches) with colored separators between moving, opposition, and reply papers.

The Motions in Limine Binder shall include two-sided, conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders not to exceed 3" per binder, indexed and 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.

WARNING

Multi-page documentary exhibits must be internally paginated in sequential numerical order.

Documentary exhibits consisting of more than one page must be internally paginated in sequential numerical order.

WARNING

Copies of documentary exhibits must be one-sided.

Copies of documentary exhibits shall be one-sided copies.

WARNING

Parties must attach tabbed copies of designated transcript pages to the Joint Chart and highlight each designation or counter-designation, with each party using a different color highlighter.

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.

WARNING

The Trial Binder must consist of one-sided, conformed copies tabbed and organized in a three-ring binder.

consisting of one-sided, conformed copies, tabbed and organized in a three-ring binder

WARNING

All non-documentary exhibits must be marked and a simple written description inserted behind the corresponding numerical tab in the Exhibit Binders.

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.

WARNING

The court's yellow evidence tags (filled in with only the case number and exhibit number) must be placed on each exhibit in the Judicial Assistant's copy of the Exhibit Binder.

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.

WARNINGCivil cases

Counsel must premark exhibits and produce the requisite number of exhibit books, and may not rely on the clerk to track exhibits or produce exhibits at trial that opposing counsel has never seen (except for impeachment).

Please do not: • Fail to premark your exhibits. • Expect the clerk to keep track of your exhibits. • Produce exhibits at trial which opposing counsel has never seen, unless they are used for impeachment. • Fail to produce the requisite numbers of exhibit books.

WARNINGCivil cases

Format

DOCX

A CD in Word format should be brought to court on the first day of trial.

A CD in Word format should be brought to court on the first day of trial.

WARNINGCivil cases

Any submitted jury instructions must be in proper format per California Rules of Court, rule 2.1055, with correct party references and no blanks, brackets, empty spaces, or inapplicable options.

a set of agreed jury instructions (and, if necessary, a separate set of instructions to which there is disagreement), in the proper format with all changes and modifications applicable to the case in accordance with California Rules of Court, rule 2.1055, (i.e., correct references to the parties, no blanks, brackets, empty spaces, or inapplicable options);

WARNINGCivil cases

Documents with original page numbers, or numbers which were attached to deposition transcripts, should be re- numbered (e.g., 31-1, 31-2, etc.). Avoid using letters for exhibits. Each photograph should have its own exhibit number and be presented separately (e.g., Ex. 1-1, Ex. 1-2, etc.).

Documents with original page numbers, or numbers which were attached to deposition transcripts, should be re- numbered (e.g., 31-1, 31-2, etc.). Avoid using letters for exhibits. Each photograph should have its own exhibit number and be presented separately (e.g., Ex. 1-1, Ex. 1-2, etc.).

WARNINGCivil cases

As with jury instructions, prepare a computer disk of the proposed verdict form and have it ready at trial.

As with jury instructions, prepare a computer disk of the proposed verdict form and have it ready at trial.

WARNINGCivil cases

Each motion in limine must be numbered sequentially (e.g., Plaintiff's Motion in Limine No. 1, Defendant's Motion in Limine No. 1).

Each motion must be numbered sequentially (Plaintiff s Motion in Limine No., 1, Defendant’s Motion in Limine No.1).

WARNINGCivil cases

Documentary exhibits must be internally paginated; foreign language exhibits require certified English translation.

Documentary exhibits consisting of more than one page must be internally paginated in sequential numerical order. Photographs should be grouped together in separate exhibits by subject matter or other logically related groups rather than marking all photographs as one exhibit. Exhibits written in a foreign language must be accompanied by a certified English translation.

WARNINGCivil cases

Photographs should be grouped into separate exhibits by subject matter or logical relation rather than marked as a single exhibit.

Photographs should be grouped together in separate exhibits by subject matter or other logically related groups rather than marking all photographs as one exhibit.

WARNINGCivil cases

Motions in limine should be submitted in a separate tabbed binder with a table of contents.

Motions in limine should be submitted in a separate tabbed binder with a table of contents.

WARNING

Each trial exhibit must be internally paginated.

Each exhibit shall be internally paginated.

WARNING

Non-documentary exhibits must be represented in the binder with a simple written description.

Non-documentary exhibits shall be represented in the binder with a simple written description.

WARNINGCivil cases

Non-documentary exhibits must be marked and a written description or picture inserted behind the corresponding numerical tab in the Exhibit Binders.

The parties shall mark all non-documentary exhibits and insert a simple written description of the exhibit or a picture behind the corresponding numerical tab in the Exhibit Binders.

WARNINGCivil cases

Each party should select a block of exhibit numbers. For example, plaintiff may take exhibits numbers 1-200 and defendant will take exhibit numbers 201-400. Documents consisting of more than one page should be internally paginated and sequentially marked (e.g., 1-1; 1-2; 1-3). For ease of reference, the exhibits should follow a rational order that tracks the witnesses to be called.

Each party should select a block of exhibit numbers. For example, plaintiff may take exhibits numbers 1-200 and defendant will take exhibit numbers 201-400. Documents consisting of more than one page should be internally paginated and sequentially marked (e.g., 1-1; 1-2; 1-3). For ease of reference, the exhibits should follow a rational order that tracks the witnesses to be called.

WARNINGCivil cases

Evidentiary objections filed with a summary judgment or summary adjudication motion must comply with CRC rule 3.1354.

Evidentiary objections. Counsel filing evidentiary objections in connection with a motion for summary judgment or summary adjudication shall comply with CRC, rule 3.1354.

WARNINGCivil cases

Format

DOCX

The parties should bring a thumb-drive to Court on the first day of trial with the agreed upon and contested instructions in Word (or the parties may arrange with the judicial assistant to e-mail the instructions in Word format).

The parties should bring a thumb-drive to Court on the first day of trial with the agreed upon and contested instructions in Word (or the parties may arrange with the judicial assistant to e-mail the instructions in Word format).

WARNINGCivil cases

The face and spine of each Exhibit Binder must be labeled with the case name, case number, FSC hearing date, and trial date.

The parties are to label the face and the spine of the Binders with the case name, case number, FSC hearing date and Trial date.

WARNINGCivil cases

The jury instructions should not have a "tear-away" box at the top of the page. The jury o instruction should be in the format that will be sent to the jury.

The jury instructions should not have a "tear-away" box at the top of the page. The jury o instruction should be in the format that will be sent to the jury.

WARNING

Documentary exhibit copies must be one-sided.

Copies of documentary exhibits shall be one-sided copies.

WARNING

The Court requests (not strictly mandates) that all electronically filed documents be bookmarked and searchable.

The Court requests all electronically filed documents be bookmarked and searchable.

WARNING

The trial binder may be submitted as either three-ring binders or three-inch spiral bound volumes.

The trial binder may be submitted either in the form of three-ring binders or three-inch spiral bound volumes.

WARNING

At least four inches of blank space must be left at the top of every page of any proposed special instructions (sentence truncated at page break).

Leave at least four inches of blank space of the top of every page of any proposed special

WARNING

The Court requests that all electronically filed documents be bookmarked and searchable.

The Court requests that all electronically filed documents be bookmarked and searchable.

WARNING

Proposed jury instructions must be submitted in an indexed, tabbed three-ring binder containing the joint set plus each side's disputed instructions.

The parties are to submit an indexed and tabbed three-ring binder containing (a) a joint set of instructions, (b) any instructions proposed by Plaintiff and objected to by Defendant; and (c) and instructions proposed by Defendant and objected to by Plaintiff.

WARNING

The deposition designation chart must be submitted in a three-ring binder with all deposition transcripts the Court needs to rule on objections.

The chart shall be submitted to the Court in a three-ring binder, along with all deposition transcripts necessary for the Court to rule on the objections.

WARNING

The joint witness list must be organized into specified columns (witness name, calling party, expected testimony, and estimated direct/cross/redirect times) with a grand total of estimated testimony times stated in the last column.

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, if applicable, that the witness requires an 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) an estimate of the length of redirect (in hours). 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.