Orange Superior Court Document Filing Requirements

CRITICAL

Applies to

Exhibits

Exhibits may not be published to the jury before being admitted and without court approval.

No exhibit shall be published to the jury prior to being admitted and without court approval.

CRITICAL

Applies to

Jury instructions compendium

Parties must provide a separately indexed joint compendium of jury instructions and verdict forms organized by agreement and proponent before trial.

Prior to the commencement of trial, the Parties shall also provide the Court with a separately indexed joint compendium identifying all agreed upon and contested instructions or verdict forms, with all instructions attached and organized by proponent and competing verdict forms appended collectively (e.g., attachment A consists of jointly requested instructions, attachment B consists of instructions requested by Plaintiff but disputed by Defendant, attachment C consists of instructions requested by Defendant but disputed by Plaintiff, attachment D consists of the Parties’ competing verdict forms).

CRITICAL

Applies to

Proposed judgment

Proposed Judgment must include the exact wording of the verdict.

After the verdict is read and the jury discharged, the prevailing Party shall prepare a Proposed Judgment, which must include the exact wording of the verdict.

CRITICAL

Applies to

Statement of compliance

Must include

caption

Parties must e-file a fully executed Statement of Compliance (Form L-0081) and include a copy in the Trial Notebook.

The Parties must e-file a fully executed Statement of Compliance (Form L-0081) and a copy also should be included in the Trial Notebook.

CRITICAL

Applies to

Video audio evidence

Video and audio tape evidence must be accompanied by a separately marked transcript or still picture representation.

Video tape or audio tape evidence may not be introduced unless accompanied by a separately marked audio transcript and/or “still picture” representation of what the proponent seeks to present as evidence. The parties are required to comply with CRC 2.1040.

CRITICAL

Applies to

Joint exhibit list

Must include

caption

Joint exhibit list must be e-filed and included in the Trial Notebook and each exhibit binder.

The joint exhibit list must be e-filed and included in both the Court's Trial Notebook and each exhibit binder.

CRITICALCivil cases

Applies to

Statement of compliance

A signed Statement of Compliance (Form L0081) must be filed no later than the Wednesday before trial.

No later than the Wednesday prior to the commencement of trial file a signed Statement of Compliance (Form L0081)

CRITICALCivil cases

Applies to

Trial binder

Must include

index

Two sets of joint 3-ring trial binders with detailed index must be brought to court on trial day; motions in limine, oppositions, and replies must be numbered on the face page.

Motions in Limine and all other Trial Documents (Jury Instructions, Exhibit List, etc.) - Two sets of joint 3 ring trial binders shall be brought to Courtroom on the day of Trial. (One for the Clerk and one for the Judge). Binders shall include a very detailed joint index setting forth which trial documents are included in the binder; and for Motions in Limine, the name of the motion, the identity of the moving party and the number of the motion. All Motions in Limine, Oppositions and Replies must be numbered on the face page of the motion.

CRITICALCivil cases

Applies to

Ex parte application

Must include

proposed order

Ex parte application must include: declaration of notice, statement of irreparable harm, declaration based on personal knowledge, points and authorities, and a separate proposed order with a copy to conform.

Ex Parte application must be in writing and include the following: • A declaration of Notice of Ex Parte hearing. • A statement that irreparable harm the will occur if the relief requested is not granted. • A declaration based on personal knowledge. • A brief and concise Points and Authorities. • A Separate proposed Order and a copy to conform.

CRITICALCivil cases

Applies to

Video audio evidence

Video or audio tape evidence may not be introduced unless accompanied by a separately marked audio transcript and/or still picture representation.

Video tape or audio tape evidence may not be introduced unless accompanied by a separately marked audio transcript and/or “still picture” representation of what the proponent seeks to present as evidence.

CRITICALCivil cases

Applies to

Ex parte application

Ex parte applications must make an affirmative factual showing of irreparable harm, immediate danger, or a statutory basis, demonstrate proper notice, and state whether the application will be opposed.

applications must comply with California Rules of Court, rules 3.1200 through 3.1207, including, but not limited to, making an "affirmative factual showing in a declaration containing competent testimony based on Rev. 1/13/25 personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte.” (Cal. Rules Ct., rule 3.1202.) The papers also must demonstrate notice was properly given and state whether the application will be

CRITICALCivil cases

Applies to

Deposition transcript

The opposing party must mark counter-designations on the same hard copy in a different color and indicate objections to designated testimony in the margin.

The other Party shall, on the same hard copy of the document, mark its counter-designations (by highlighting them in a different color) and also indicate, in the margin next to any testimony designated by the other side, any objections to the admissibility of the designated testimony.

CRITICALCivil cases

Applies to

Witness list

Must include

caption

The joint witness list must have a caption page and a specific table format with defined columns and totals.

The joint witness list must include a caption page identifying it, and the list should be in a table format that includes the following columns: (1) a number for each witness, (2) “Witness,” (3) “Title and/or Role in Case,” (4) “Direct Examination Time Estimate,” (5) “Cross Examination Time Estimate,” and (6) “Total Time Estimate.” Each time estimate column should include a total time estimate at the bottom so the list provides a total of all direct examination time estimates, a total of all cross-examination time estimates, and a total of all time estimates.

CRITICALCivil cases

Applies to

Witness list

The Trial Notebook must include a joint witness list, with two additional copies as required by Orange County Local Rule 317.

As part of the Trial Notebook, the Parties are required to submit a joint witness list. As stated in Orange County Local Rule 317, two additional copies

CRITICALCivil cases

Applies to

Jury instructions

Proposed jury instructions must begin with three table-format indexes with specified columns and titles.

The jury instructions must start with three indexes in table format that includes the following columns: (1) “Instruction”—this column should identify each instruction by CACI number and title (e.g., CACI 100 – Preliminary Admonition) or, for a special instruction, by the party proposing it, the number of the special instruction proposed by that party, and a brief description (e.g., Plaintiff’s Special Instruction No. 1 – Negligence), (2) “Given as Proposed,” (3) “Given as Modified,” (4) “Withdrawn,” and (5) “Refused.” The first index shall be entitled Agreed Upon Jury Instructions, the second index shall be entitled Plaintiff’s Requested Jury Instructions, and the third index shall be entitled Defendant’s Requested Jury Instructions.

CRITICALCivil cases

Applies to

Exhibit list

Joint exhibit list must include a caption page and a table with specific columns, exhibits must be numbered separately (no letters), and no exhibit may be identified as a plaintiff or defendant exhibit.

The joint exhibit list must include a caption page identifying it, and the list should be in a table format that includes the following columns: (1) “Exhibit Number,” (2) “Description,” (3) “Stipulation,” (4) “Date Identified,” and (5) “Date Admitted.” All exhibits must be identified by a separate number; do not use letters. The description of each exhibit should include each exhibit’s date or state it is undated. The stipulation column should state whether the Parties stipulate to authenticity, foundation, admissibility, or none. The exhibit list should NOT identify any exhibit as a plaintiff or defendant exhibit.

CRITICALCivil cases

Applies to

Special instruction

Special instructions must have the supporting authority and explanation on a separate attached page with the same number and title.

The authority supporting the propriety of the special instruction and a short explanation of why the special instruction is necessary or appropriate must appear on a separate page attached to the instruction that bears the same number and title as the instruction itself.

CRITICALCivil cases

Applies to

Exhibit binder

Each exhibit binder's cover and spine must identify the exhibit binder, volume number, and specific exhibits, and each page of each exhibit must be numbered sequentially per exhibit starting at one.

The outside cover of each binder must include a caption page identifying the binder as an exhibit binder, the volume number of the binder (e.g., Volume 3 of 7), and the specific exhibits included in the binder (e.g., Exhibit Nos. 27-45). The outer spine of the binder also must identify the volume number and the specific exhibits included in the binder. Moreover, each page of each exhibit must be separately numbered with each exhibit starting with number one. For example, if Exhibit 7 is a three-page exhibit, its pages should be numbered 7-1, 7-2, and 7-3, and the first page of Exhibit 8 would then be 8-1.

CRITICALCivil cases

Applies to

Exhibit

Each original exhibit must have a green court exhibit tag attached.

Each exhibit must have a green court exhibit tag attached (This is for the original exhibits only).

CRITICALCivil cases

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include a proposed order.

Application (including the proposed order) and Opposition must be viewable in the Court's Public Website no later than 2:00 p.m, the day before the hearing.

CRITICALCivil cases

Applies to

Verdict form

Verdict forms must not include attorney identity, address, or Doe defendants.

The verdict form must not contain the identity or address of any attorney, nor shall Doe defendants be listed thereon.

CRITICALCivil cases

Applies to

Pleading

Documents must be electronically signed before submission or they will be rejected.

Stipulations, pleadings, declarations, and other documents must be electronically signed before submission to the Court. Failure to comply will result in the document being rejected.

CRITICALCivil cases

Applies to

All

All documents must be electronically signed before submission; non-compliance results in rejection.

Stipulations, pleadings, declarations, and other documents must be electronically signed before submission to the Court. Failure to comply will result in the document being rejected.

CRITICAL

Applies to

Filing with ai generated content

Generative AI may be used in filings, but the filer must personally verify the accuracy of AI-conducted research and bears ethical responsibility for all statements made.

Use of generative AI is not prohibited, but counsel or the self-represented party must personally confirm for themselves the accuracy of any research conducted by these means, and counsel or the self-represented party alone bears ethical responsibility for all statements made in filings.

CRITICAL

Applies to

Filing with ai generated content

Signing or being listed on a filing with AI-generated content certifies that the signer and all listed parties have personally verified the content's accuracy.

The signature or listing of counsel or a self-represented party on a filing containing AI- generated content, including citations generated by AI, constitutes a certification the signer (and any attorney or other self-represented party listed on the filing) has personally verified the content’s accuracy.

CRITICAL

Applies to

Filing with ai generated content

Parties using generative AI or automated tools must fully comply with applicable protective orders and all ethical and legal obligations involving AI use, disclosure, and submission.

Counsel for a party, or a self-represented party, choosing to use generative AI or other automated tools shall fully comply with any applicable protective order and all applicable ethical/legal obligations in their use, disclosure to, submission to, or other interaction with any such AI tools.

CRITICAL

Applies to

Ex parte application

Ex parte applications must include declaration showing irreparable harm, demonstrate notice, and state whether opposed.

All Parties must comply with CRC 3.1200 through 3.1207, including but not limited to making an “affirmative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte.” CRC 3.1202 (c). Papers must also demonstrate appropriate notice and state whether the application will be opposed.

CRITICALCivil cases

Applies to

Ex parte application

Must include

proposed order

Ex parte applicants must submit a proposed order.

a proposed Order

CRITICALCivil cases

Applies to

Ex parte application

Ex parte applicants must show the irreparable harm that will occur if the requested relief is not granted.

a showing of the irreparable harm that will occur if the relief requested is not granted

CRITICALCivil cases

All parties must strictly comply with Orange County Local Rule 314A regarding Register of Actions references for related documents.

All parties must strictly comply with Orange County Local Rule 314A "Register of Actions References for Related Documents."

CRITICALCivil cases

Applies to

Trial documents

Counsel must comply fully with OCSC Local Rule 317 for trial documents.

The court requires that counsel comply fully with Local Rule 317.

CRITICALCivil cases

Applies to

Video audio evidence

Video or audio tape evidence may only be introduced if accompanied by a separately marked transcript or still-picture representation.

Video tape or audio tape evidence may not be introduced unless accompanied by a separately marked audio transcript and/or “still picture” representation of what the proponent seeks to present as evidence.

CRITICALCivil cases

Applies to

Statement of compliance

The Statement of Compliance must be accompanied by a Joint Statement of Case, Joint Witness List, Stipulated Facts, Requested Voir Dire Questions, and List of Controverted Issues.

Please attach to this Statement of Compliance: Joint Statement of Case, Joint Witness List, Stipulated Facts, Requested Voir Dire Questions and List of Controverted Issues.

CRITICALCivil cases

Applies to

Ex parte application

Ex parte moving papers must demonstrate proper notice with admissible evidence and state whether the other parties will oppose the application.

The moving papers must demonstrate with admissible evidence that the moving party gave proper notice and must state whether the other parties to the case will oppose the application.

CRITICALCivil cases

Applies to

Trial notebook

Counsel must jointly prepare a trial notebook for the court containing specified separately tabbed documents.

In addition to the exhibit binders required for trial exhibits, counsel shall jointly prepare a trial notebook for the court. The trial notebook is a courtesy copy for the Court's use; it does not absolve the parties of the need to e-file all trial-related documents. The Court's trial notebook shall contain the following documents, each separately tabbed:

CRITICALCivil cases

Applies to

In limine motion

Each in limine motion must show a number, the moving party's identity, and a short description on its face page.

Each in limine motion shall be assigned a number, which must be set forth on the face page of the motion, along with the identity of the party bringing the motion and a short description of the motion (e.g. “Plaintiff’s Motion In Limine No. 1 to Exclude Reference to Plaintiff’s 2013 Theft Conviction”).

CRITICALCivil cases

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must comply with CRC 3.1200-3.1207 and include a notice declaration, an irreparable harm declaration, a memorandum of points and authorities, and a proposed order.

Ex parte applications must comply with CRC 3.1200 through 3.1207. Applications must be in writing and include the following: 1. Declaration setting forth details of the notice given to opposing counsel of the ex parte hearing and stating whether the application will be opposed. 2. Declaration, based on personal knowledge, describing the irreparable harm that would occur if the relief requested is not granted. 3. Memorandum of Points and Authorities in support of the application. 4. Proposed Order in Word format.

CRITICALCivil cases

Applies to

Exhibits

Every exhibit in the witness copy must have a filled-out exhibit tag attached.

Every exhibit in the witness copy must have an exhibit tag filled out and attached.

CRITICALCivil cases

Applies to

Statement of compliance

The Statement of Compliance must be executed by all counsel and filed with the clerk in the assigned judge's department.

This Statement of Compliance shall be executed by all counsel and filed with the court clerk in the department of the judge to whom the case has been assigned for trial.

CRITICALCivil cases

Applies to

Case management statement

A case management statement must be filed for case management conferences.

File a case management statement. (Cal. Rules of Court, rule 3.725.)

CRITICALCivil cases

Applies to

Joint trial documents

Joint trial documents must be agreed upon by all sides, and witness lists must include time commitments.

Prepare joint trial documents: “Joint” means all sides agree. Each side does not get to make their own. Witness lists must have time commitments.

CRITICALCivil cases

Applies to

Stipulation

Must include

proposed order

Stipulations must be filed as a single document containing the stipulation and proposed order, with space left for the court's terms.

Please file a single document containing both the parties’ stipulation and the proposed order. Please leave space for the court to add appropriate terms.

CRITICALCivil cases

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include declarations of notice and irreparable harm, a memorandum of points and authorities, and a proposed order in Word format.

Ex parte applications must comply with CRC 3.1200 through 3.1207. Applications must be in writing and include all of the following: 1. A declaration setting forth details of the notice given to opposing counsel of the ex parte hearing and stating whether the application will be opposed; 2. A declaration, based on personal knowledge, describing the irreparable harm that will occur if the relief requested is not granted; 3. A concise memorandum of points and authorities in support of the application; and 4. A separate proposed order in Word format.

CRITICALCivil cases

Applies to

Stipulation

Must include

electronic signature

Documents must be electronically signed by all parties before submission; non-compliance results in rejection.

Stipulations, pleadings, declarations, and other documents must be electronically signed by all parties before submission to the Court. Failure to comply will result in the document being rejected.

CRITICALCivil cases

Applies to

All documents

All documents must be electronically signed before submission; non-compliance leads to rejection.

Stipulations, pleadings, declarations, and other documents must be electronically signed before submission to the Court. Failure to comply will result in the document being rejected.

CRITICALCivil cases

Applies to

Continuance request

Must include

proposed order

A proposed order must accompany any continuance request, stipulation, and supporting declaration.

A proposed order is to be submitted with the request, stipulation, and supporting declaration.

CRITICALCivil cases

Applies to

Ex parte motion

Must include

proposed order

Ex parte moving papers must include a declaration of notice, declaration based on personal knowledge, points and authorities, proposed order, and must state the irreparable harm.

Moving papers must include a declaration of notice of ex parte hearing, a declaration based on personal knowledge, points and authorities, and a proposed order. The application shall set forth the irreparable harm that will occur if the relief requested is not granted.

CRITICAL

Applies to

Proposed jury instructions and verdict forms

Proposed jury instructions and verdict forms must be submitted in the Joint Trial Notebook.

All proposed jury instructions and verdict forms must be submitted to the clerk as part of the “Joint Trial Notebook”.

CRITICAL

Applies to

Motion in limine

Motions in limine must be in writing and specifically identify the evidence to be excluded.

Motions in limine must be in writing, comport with the purposes of such motions, and identify specifically the evidence to be excluded.

CRITICAL

Applies to

Joint witness list

Parties must submit a joint witness list.

Parties are required to submit a joint witness list.

CRITICAL

Applies to

Continuance stipulation

Stipulations for continuance must be signed by all appearing parties.

Said stipulations must be signed by ALL appearing parties.

CRITICAL

Applies to

Continuance request

Must include

proposed order

Continuance requests must include a supporting declaration showing good cause and a proposed order.

Even if a continuance is unopposed, counsel must submit a supporting declaration stating facts that constitute good cause for a continuance. A proposed order is to be submitted with the request, stipulation, and supporting declaration.

CRITICAL

Applies to

Stipulation

Stipulations must be in writing.

Stipulations must be reduced to writing.

CRITICAL

Applies to

Ex parte papers

Must include

proposed order

Ex parte papers must include a declaration of notice, declaration on personal knowledge, points and authorities, and a proposed order.

papers must include a declaration of notice of ex parte hearing, a declaration based on personal knowledge, points and authorities, and a proposed order in both PDF format and in editable word-processing format.

CRITICAL

Applies to

Joint compendium of instructions and verdict forms

Parties must provide a separately indexed joint compendium of agreed and contested jury instructions and verdict forms before trial.

Prior to the commencement of trial, the parties shall also provide the Court with a separately indexed joint compendium identifying all agreed upon and contested instructions or verdict forms, with all instructions attached and organized by proponent and competing verdict forms appended collectively (e.g., attachment A consists of jointly requested instructions, attachment B consists of instructions requested by Plaintiff but disputed by Defendant, attachment C consists of instructions requested by Defendant but disputed by Plaintiff, attachment D consists of the parties competing verdict forms).

CRITICAL

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include a separate proposed order in Word format.

A separate proposed order in Word format.

CRITICAL

Applies to

Proposed judgment

Prevailing counsel must prepare a Proposed Judgment containing the exact wording of the verdict.

After the verdict is read and the jury discharged, Counsel for the prevailing party shall prepare a Proposed Judgment, which must include the exact wording of the verdict.

CRITICAL

Applies to

Ex parte application

Ex parte applications must include a concise memorandum of points and authorities in support of the relief requested.

A concise memorandum of points and authorities in support of the application; and

CRITICAL

Applies to

Issue conference materials

Parties must conduct an Issue Conference under Local Rule 317 and prepare and file all required items.

The Parties must conduct an Issue Conference in compliance with Local Rule 317 and prepare and file all required items pursuant to that rule.

CRITICAL

Applies to

Statement of compliance

The Statement of Compliance must be executed by all counsel and filed with the court clerk in the department of the judge assigned to the case for trial.

This Statement of Compliance shall be executed by all counsel and filed with the court clerk in the department of the judge to whom the case has been assigned for trial.

CRITICAL

Applies to

Ex parte application

Must include

declaration

Ex parte applications must include a declaration showing irreparable harm, immediate danger, or other statutory basis.

Comply with all requirements for ex partes, including “an affirmative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte.” (Cal. Rules of Court, rule 3.1202(c).)

CRITICAL

Applies to

Ex parte application

Must include

proposed order

An ex parte application must include a separate proposed order in Word format.

4. A separate proposed order in Word format.

CRITICAL

Applies to

Proposed judgment

After the verdict is read and the jury is discharged, the prevailing party must prepare a proposed judgment containing the exact wording of the verdict.

After the verdict is read and the jury discharged, the prevailing Party shall prepare a Proposed Judgment, which must include the exact wording of the verdict.

CRITICAL

Applies to

Ex parte application

Ex parte applications must comply with CRC 3.1200 through 3.1207, be in writing, and include the specified required materials.

Ex parte applications must comply with CRC 3.1200 through 3.1207. Applications must be in writing and include all of the following:

CRITICAL

Applies to

Joint witness list

The Joint Witness List must state a realistic witness schedule, estimated direct and cross-examination time for each witness, and total examination hours.

Whatever form the Parties select, the Joint Witness List must include a realistic schedule of when each witness will be called, the estimated total time for direct and cross-examination of each witness, and the total number of hours the examination of all witnesses is expected to consume.

CRITICAL

Applies to

Joint exhibit list

The Joint Exhibit List must give each exhibit’s number and brief description, including its date or an indication that it is undated.

The Joint Exhibit List shall include the exhibit number and a brief description of each exhibit, including the date of the document or a notation that the document is undated (e.g., “Exhibit 100, Letter from J. Jones to C. Clark dated 1/12/2000”).

CRITICAL

Applies to

In limine motion

Each in limine motion must show its assigned number, moving party, and a short description on its face page.

Each in limine motion shall be assigned a number, which must be set forth on the face page of the motion, along with the identity of the party bringing the motion and a short description of the motion (e.g., “Plaintiff’s Motion In Limine No. 1 to Exclude Reference to Plaintiff’s 2013 Theft Conviction”).

CRITICAL

Applies to

Ex parte application

An ex parte application must include a declaration based on personal knowledge describing the irreparable harm that will occur without the requested relief.

2. A declaration, based on personal knowledge, describing the irreparable harm that will occur if the relief requested is not granted;

CRITICAL

Applies to

Proposed jury instructions

Each agreed or disputed CACI instruction must include its CACI number and title at the top.

Each CACI instruction (whether agreed upon or disputed) must include the CACI number and title at the top.

CRITICAL

Applies to

Ex parte application

An ex parte application must include a concise supporting memorandum of points and authorities.

3. A concise memorandum of points and authorities in support of the application; and

CRITICAL

Applies to

Summary judgment declaration

Declarations supporting or opposing summary judgment or adjudication motions must be filed separately, not attached to or incorporated into the motion papers or memorandum.

Declarations filed in support of or in opposition to a motion for summary judgment and/or adjudication must be separately filed, i.e., not attached to or made part of the notice of motion and motion or the memorandum of points and authorities.

CRITICAL

Applies to

Jury trial documents

For a jury trial, the parties must exchange proposed jury instructions and proposed findings or verdict forms before trial begins.

If trial is by jury, proposed jury instructions, proposed special findings and/or general verdict and/or special verdicts will be exchanged before the commencement of trial.

CRITICAL

Applies to

Ex parte application

Must include

certificate section

An ex parte application must include a declaration detailing notice to the opposing party and stating whether the application will be opposed.

1. A declaration setting forth details of the notice given to the opposing Party of the ex parte hearing and stating whether the application will be opposed;

CRITICAL

Applies to

Proposed jury instructions

Substantively modified CACI instructions must identify exactly what was modified.

Substantively modified CACI instructions must specify exactly what has been modified.

CRITICAL

Applies to

Request for judicial notice

Each request for judicial notice must be a separate document that attaches the materials for notice and cites the legal basis for the request.

All requests for judicial notice must be set forth in a separate document, must attach a copy of the document(s) of which notice is requested, and must specify (with appropriate legal citation) the legal basis on which judicial notice is sought.

CRITICAL

Applies to

Ex parte moving papers

Ex parte moving papers must show with admissible evidence that proper notice was given and state whether the other parties will oppose the application.

The moving papers must demonstrate with admissible evidence that the moving party gave proper notice and must state whether the other parties to the case will oppose the application.

CRITICAL

Applies to

Deposition designation objections

Objections to deposition designations must be filed in a document identifying the challenged designation and legal basis in column format.

If either Party has objections to the designated portions, they will file a document which identifies the objectionable designation, and the legal basis for the objection, in column format.

CRITICAL

Applies to

Exhibit binders

Both exhibit binders must be provided to the Courtroom Clerk on the first day of trial.

Both exhibit binders shall be provided to the Courtroom Clerk on the first day of trial.

CRITICAL

Applies to

Videotaped deposition

Must include

exhibit list

Videotaped depositions must be transcribed and marked as exhibits.

Videotaped depositions must be transcribed and marked as an exhibit.

CRITICAL

Applies to

Proposed jury instructions

Special or modified instructions must include supporting authority and a short explanation of why the instruction is necessary and appropriate at the bottom.

Special or Modified Instructions must include, at the bottom of the proposed instruction, citation to authority supporting the propriety of the instruction and a short explanation of why the special or modified instruction is necessary and appropriate.

CRITICAL

Applies to

Statement of compliance

The Statement of Compliance must include the listed joint statements, lists, stipulated facts, and requested voir dire questions as attachments.

**Please attach to this Statement of Compliance: Joint Statement of Case, Joint Witness List, Stipulated Facts, Requested Voir Dire Questions and List of Controverted Issues.

CRITICAL

Applies to

Joint exhibit list

The Parties must cooperate in preparing a Joint Exhibit List by the Issue Conference.

At or before the Issue Conference, the Parties must cooperate in preparing a Joint Exhibit List for trial.

CRITICAL

Applies to

Statement of compliance

All counsel must execute the Statement of Compliance and file it with the clerk in the trial judge’s department.

This Statement of Compliance shall be executed by all counsel and filed with the court clerk in the department of the judge to whom the case has been assigned for trial.

CRITICAL

Applies to

Proposed jury instructions

Each special or modified CACI instruction must carry the specified party and instruction-number heading at the top of the page.

Each special or modified CACI instruction shall state at the top of the page “Plaintiff’s [or Defendant’s] Special Instruction No. __” or “Plaintiff’s [or Defendant’s] Modified CACI Instruction No. __.”

WARNINGCivil cases

Applies to

Letter

Must include

certificate of conference

Parties must attest to having previously met and conferred in person, by phone, or by video conference.

Parties must attest to having previously met and conferred in person, by phone, or by video conference.

WARNING

Applies to

Joint exhibit list

Must include

caption

Joint exhibit list must have a caption page and a table with specific columns.

The joint exhibit list must include a caption page identifying it, and the list should be in a table format that includes the following columns: (1) "Exhibit Number," (2) "Description," (3) "Stipulation," (4) "Date Identified," and (5) "Date Admitted."

WARNING

Applies to

Exhibits

Exhibits must be moved into evidence as soon as admissibility is established, not at the end of testimony or case.

Each exhibit should be moved into evidence as soon as admissibility has been established; DO NOT wait until the end of a witness's testimony or the end of a party's case to move exhibits into evidence.

WARNING

Applies to

Joint exhibit list

The Parties are expected to have already attempted to stipulate to the admissibility and/or foundation for all exhibits with those agreements reflected on the joint exhibit list.

The Parties are expected to have already attempted to stipulate to the admissibility and/or foundation for all exhibits with those agreements reflected on the joint exhibit list.

WARNING

Applies to

Witness list

Joint witness list must include a caption page and be in table format with specified columns and time estimate totals.

Parties are required to submit a joint witness list. The joint witness list must include a caption page identifying it, and the list should be in a table format that includes the following columns: (1) a number for each witness, (2) “Witness,” (3) “Title and/or Role in Case,” (4) “Direct Examination Time Estimate,” (5) “Cross Examination Time Estimate,” and (6) “Total Time Estimate.” Each time estimate column should include a total time estimate at the bottom so the list provides a total of all direct examination time estimates, a total of all cross-examination time estimates, and a total of all time estimates.

WARNINGCivil cases

Applies to

Exhibits

Exhibits on the Portal must be identified by numbers only, with no special characters, letters, or party designations.

Only numbers shall be used to identify an exhibit on the Portal. No special characters or letters shall be added to the exhibit number. Please do not designate exhibits as plaintiff's or defendant's exhibit.

WARNINGCivil cases

Applies to

In limine motion

Each in limine motion must be numbered, with the number and party identity on the face page.

Each in limine motion shall be assigned a number, which must be set forth on the face page of the motion, along with the identity of the party bringing the motion

WARNINGCivil cases

Applies to

Exhibits

Page numbers must be placed on each page of multiple-page exhibits that are not Bates-stamped before uploading to the Portal.

Before uploading exhibits to the Portal, if the document is not bate-stamped, page numbers shall be placed on each page of a multiple-page document.

WARNINGCivil cases

Applies to

Verdict form

Verdict forms must not list Doe defendants or contain any attorney's identity or address.

Verdict forms shall not list Doe defendants or contain the identity or address of any attorney.

WARNINGCivil cases

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include declarations of notice and irreparable harm, a memorandum, and a proposed order in Word format.

Ex parte applications must comply with CRC 3.1200 through 3.1207. Applications must be in writing and include all of the following: 1. A declaration setting forth details of the notice given to opposing counsel of the ex parte hearing and stating whether the application will be opposed; 2. A declaration, based on personal knowledge, describing the irreparable harm that will occur if the relief requested is not granted; 3. A concise memorandum of points and authorities in support of the application; and 4. A separate proposed order in Word format.

WARNINGCivil cases

Applies to

Case management statement

should include in the statement a discussion of the applicable subjects set forth in California Rules of Court 3.727 and 3.750(b).

should include in the statement a discussion of the applicable subjects set forth in California Rules of Court 3.727 and 3.750(b).

WARNINGCivil cases

Applies to

Msc statement

MSC statements must include email address of settlement counsel.

PLEASE INCLUDE E-MAIL ADDRESS OF SETTLEMENT COUNSEL ON THE MSC STATEMENT.

WARNINGCivil cases

Applies to

Motion

Must include

proposed order

The moving party must give notice or prepare the order after a ruling, per CRC 3.1312.

The moving party shall give notice or prepare the order, if appropriate, per California Rule of Court 3.1312.

WARNINGCivil cases

Applies to

Cmc statement

CMC statement must be timely filed per CRC 3.725(a).

Case Management Conferences – The court strictly enforces the timely filing of a CMC statement pursuant to CRC 3.725(a).

WARNINGCivil cases

Applies to

Ex parte application

Before seeking ex parte relief to advance a motion hearing date, counsel should file the motion first.

Before applying ex parte to advance a motion hearing date, counsel should make sure to file the motion first. The court likely will deny any request to advance a motion that has not been filed.

WARNINGCivil cases

Applies to

Order

Must include

proposed order

When all sides submit on a tentative ruling it becomes final, and the prevailing party must give notice and prepare an order for the court's signature.

If all sides submit on the tentative ruling and advise the court, the tentative ruling shall become the court's final ruling and the prevailing party shall give notice of the ruling and prepare an order for the court's signature if appropriate under California Rules of Court, rule 3.1312.

WARNINGCivil cases

Applies to

Msc statement

The MSC statement must include the email address for settlement counsel.

Please include the email address for settlement counsel on the MSC statement.

WARNINGCivil cases

Applies to

Stipulation and order

Stipulations must set forth detailed good cause, and the judge's signature line must not be the only item on the page.

The stipulation portion must set forth, in detail, good cause for the requested order. The Parties' stipulation alone is often not sufficient good cause. Please ensure the signature line for the judge is not the only item on the page; there also must be at least two lines of text from the order portion.

WARNINGCivil cases

Applies to

Motion in limine

In limine motions may not be used as substitutes for dispositive motions.

Counsel should not use in limine motions as substitutes for summary adjudication motions, motions for judgment on the pleadings, or other dispositive motions. (See, e.g., Johnson v. Chiu (2011) 199 Cal.App.4th 775, 777; Amtower v. Photon Dynamics (2008) 158 Cal.App.4th 1582, 1588; R&B Auto Center, Inc. v. Farmers Group, Inc. (2006) 140 Cal.App.4th 327, 333.)

WARNINGCivil cases

Applies to

Motion in limine

Matters of day-to-day trial logistics and common professional courtesy are not proper subjects for in limine motions.

Also, "[m]atters of day-to-day trial logistics and common professional courtesy" are not proper subjects of in limine motions. (Id. at p. 671.)

WARNINGCivil cases

Applies to

Motion in limine

In limine motions should be specific and address particular items of evidence, not broad categories.

Counsel should avoid broad, general motions, such as to exclude "all hearsay evidence" or "all cumulative evidence" or "evidence not disclosed in discovery." Such motions are not likely to be granted. (See Kelly v. New West Federal Savings (1996) 49 Cal.App.4th 659.) Motions in limine usually are intended to exclude specific items of evidence, not broad categories. Be specific and concrete in what you want to exclude.

WARNING

Applies to

Filing with ai generated content

Any errors caused by AI tools are imputed to the signer and every listed attorney or self-represented party on the filing.

The court will impute any errors by such AI tools to the signer and any other attorney or self-represented party listed on the filing.

WARNING

Applies to

Filing with ai generated content

Failure to verify the accuracy of submissions, especially citations to law and evidence, may result in sanctions or State Bar disciplinary action.

Failure to verify the accuracy of submissions, particularly the accuracy of citations to law and evidence, may be grounds for sanctions or disciplinary action before the State Bar.

WARNING

Applies to

Motion in limine

Must include

caption

Motions in limine must be numbered and have a caption identifying the subject and specific evidence.

Each motion in limine must be numbered on the face page of the motion. The caption (or notice) of each motion in limine shall concisely identify the subject of the motion and designate the specific evidence or argument sought to be excluded.

WARNINGCivil cases

Applies to

Case management statement

The Case Management Statement must use pleading paper rather than Judicial Council Form CM-110 and include a discussion of the subjects set forth in CRC Rule 3.727.

Counsel should use pleading paper rather than Judicial Council Form CM-110 but should include in the Statement a discussion of the applicable subjects set forth in CRC Rule 3.727.

WARNING

Applies to

Initial case management conference statement

should include in the statement a discussion of the applicable subjects set forth in California Rules of Court 3.727 and 3.750(b).

should include in the statement a discussion of the applicable subjects set forth in California Rules of Court 3.727 and 3.750(b).

WARNING

Applies to

Joint compendium

Parties must provide a joint compendium with an index, all instructions/verdict forms, and tabbed sections by the pretrial conference.

No later than the pretrial conference, the Parties shall also provide the Court with a separately indexed joint compendium in a notebook format containing an index or table identifying all agreed upon and contested instructions or verdict forms, with all instructions and verdict forms included and separately tabbed to indicate proponent/opponent (e.g., Tab 1 consists of jointly requested instructions, Tab 2 consists of instructions requested by Plaintiff but disputed by Defendant, Tab 3 consists of instructions requested by Defendant but disputed by Plaintiff, Tab 4 consists of the Parties’ competing verdict forms).

WARNING

Applies to

Video audio evidence

Video or audio evidence must be accompanied by a transcript or still picture.

Video tape or audio tape evidence may not be introduced unless accompanied by a separately marked audio transcript and/or “still picture” representation of what the proponent seeks to present as evidence.

WARNINGCivil cases

Applies to

Jury instructions

All proposed jury instructions and verdict forms must be submitted to the clerk as part of the Joint Trial Notebook.

All proposed jury instructions and verdict forms must be submitted to the clerk as party of the “Joint Trial Notebook”.

WARNINGCivil cases

Applies to

Evidentiary objections

Written evidentiary objections must comply with CRC 3.1354.

Written evidentiary objections must comply with CRC 3.1354.

WARNINGCivil cases

Applies to

Separate statement

Separate statements must comply with CRC 3.1350.

Separate statements must comply with CRC 3.1350.

WARNINGCivil cases

Applies to

Jury instruction compendium

Before trial, the parties must give the Court a separately indexed joint compendium of agreed-upon and contested jury instructions and verdict forms, organized by proponent with competing verdict forms appended collectively.

Prior to the commencement of trial, the parties shall also provide the Court with a separately indexed joint compendium identifying all agreed upon and contested instructions or verdict forma, with all instructions attached and organized by proponent and competing verdict forms appended collectively (e.g., attachment A consists of jointly requested instructions, attachment B consists of instructions requested by Plaintiff but disputed by Defendant, attachment C consists of instructions requested by Defendant but disputed by Plaintiff, attachment D consists of the parties competing verdict forms:

WARNINGCivil cases

Applies to

Witness list

The parties must submit a joint witness list.

Parties are required to submit a joint witness list.

WARNINGCivil cases

Applies to

Motion in limine

Motions to exclude “any evidence” are often improper. Motions should identify the exhibit number or specific words of testimony to be excluded. (Kelly v. New West Federal Savings (1996) 49 Cal.App.4th 659, 670-671.)

Motions to exclude “any evidence” are often improper. Motions should identify the exhibit number or specific words of testimony to be excluded. (Kelly v. New West Federal Savings (1996) 49 Cal.App.4th 659, 670-671.)

WARNINGCivil cases

Applies to

Motion

Coordinate motion numbering with opposing counsel. There should be only one Motion #1, one Motion #2, etc.

Coordinate motion numbering with opposing counsel. There should be only one Motion #1, one Motion #2, etc.

WARNINGCivil cases

Applies to

Special verdict form

Special verdict form proposals must be legally correct and logical.

Proposals shall be legally correct and logical.

WARNINGCivil cases

Applies to

Jury instructions

If the parties cannot agree on all jury instructions, they must file three sets: agreed-upon, plaintiff's proposed, and defendant's proposed.

If you cannot agree to all instructions, file three sets of instructions: (1) agreed- upon, (2) plaintiff’s proposed, and (3) defendant’s proposed.

WARNINGCivil cases

Applies to

Special verdict form

If there is no joint special verdict form, counsel must file a general verdict form (CACI No. VF-5000, 5001).

If there is no joint special verdict form, file a general verdict form. (CACI No. VF-5000, 5001.)

WARNING

Applies to

In limine motion

Each in limine motion must be numbered and include party identity and short description on the face page.

Each in limine motion shall be assigned a number, which must be set forth on the face page of the motion, along with the identity of the party bringing the motion and a short description of the motion (e.g., “Plaintiff’s Motion In Limine No. 1 to Exclude Reference to Plaintiff’s 2013 Theft Conviction”).

WARNING

Applies to

Ex parte application

Must include

proposed order

Ex parte applications must include declaration of notice, declaration of irreparable harm, memorandum, and proposed order in Word format.

Applications must be in writing and include all of the following: 1. A declaration setting forth details of the notice given to opposing counsel of the ex parte hearing and stating whether the application will be opposed; 2. A declaration, based on personal knowledge, describing the irreparable harm that will occur if the relief requested is not granted; 3. A concise memorandum of points and authorities in support of the application; and 4. A separate proposed order in Word format.

WARNING

Applies to

Verdict form

Verdict forms should not list Doe defendants or contain the identity or address of any attorney.

Verdict forms should not list Doe defendants or contain the identity or address of any attorney.

WARNING

Applies to

Declaration

Declarations for summary judgment motions must be filed separately, not attached to motion or memorandum.

Declarations filed in support of or in opposition to a motion for summary judgment and/or adjudication must be separately filed, i.e., not attached to or made part of the notice of motion and motion or the memorandum of points and authorities.

WARNING

Applies to

Exhibit list

Plaintiff exhibits start at 1; Defendant exhibits start at 200.

In a two-party case, Plaintiff shall number its exhibits starting with 1. Defendant shall number its exhibits starting with 200.

WARNING

Applies to

Request for judicial notice

Requests for judicial notice must be separate document, attach copy, and specify legal basis.

All requests for judicial notice must be set forth in a separate document, must attach a copy of the document(s) of which notice is requested, and must specify (with appropriate legal citation) the legal basis on which judicial notice is sought.

WARNING

Applies to

Ex parte application

Ex parte moving papers must demonstrate proper notice, state opposition, and counsel must make good faith efforts to confer with opposing counsel.

The moving papers must demonstrate with admissible evidence that the moving party gave proper notice and must state whether the other parties to the case will oppose the application. Counsel for the moving party must make good faith efforts to speak with opposing counsel to determine their position(s) on the ex parte application.

WARNING

Applies to

Videotaped deposition

Videotaped depositions must be transcribed, marked as exhibit, and edited to remove objections and argument.

Videotaped depositions must be transcribed and marked as an exhibit. The videotape must be edited before being shown to the jury to remove objections and argument by counsel.

WARNING

Applies to

Proposed judgment

Proposed Judgment must include the exact wording of the verdict.

After the verdict is read and the jury discharged, Counsel for the prevailing party shall prepare a Proposed Judgment, which must include the exact wording of the verdict.

WARNINGCivil cases

Applies to

Case management statement

should include in the statement a discussion of the applicable subjects set forth in California Rules of Court 3.727 and 3.750(b).

should include in the statement a discussion of the applicable subjects set forth in California Rules of Court 3.727 and 3.750(b).

WARNING

Applies to

Witness list

Joint Witness List must include a schedule, estimated examination times, and total hours.

the Joint Witness List must include a realistic schedule of when each witness will be called, the estimated total time for direct and cross- examination of each witness, and the total number of hours the examination of all witnesses is expected to consume.

WARNINGCivil cases

Applies to

Mandatory settlement conference statement

The MSC statement must include the email address of settlement counsel.

PLEASE INCLUDE E-MAIL ADDRESS OF SETTLEMENT COUNSEL ON THE MSC STATEMENT.

WARNING

Applies to

Ex parte application

Ex parte applications must include an affirmative factual showing in a declaration, demonstrate appropriate notice, and state whether the application will be opposed.

All Parties must comply with CRC 3.1200 through 3.1207, including but not limited to making an “affirmative factual showing in a declaration containing competent testimony based on personal knowledge of irreparable harm, immediate danger, or any other statutory basis for granting relief ex parte.” CRC 3.1202 (c). Papers must also demonstrate appropriate notice and state whether the application will be opposed.

WARNING

Applies to

Declaration

Declarations in summary judgment motions must be filed separately and not attached to the notice of motion or memorandum.

Declarations filed in support of or in opposition to a motion for summary judgment and/or adjudication must be separately filed, i.e., not attached to or made part of the notice of motion and motion or the memorandum of points and authorities.

WARNING

Applies to

Joint statement of case and joint witness list

A Joint Statement of the Case and a joint witness list must be prepared for submission to the court.

4. Joint Statement of the case and joint witness list has been prepared for submission to the court as required.**

WARNING

Applies to

Joint witness list

The Joint Witness List must include a realistic witness schedule, estimated direct/cross-examination time per witness, and total examination hours; it need not include impeachment or rebuttal witnesses.

Whatever form Counsel selects, the Joint Witness List must include a realistic schedule of when each witness will be called, the estimated total time for direct and cross-examination of each witness, and the total number of hours the examination of all witnesses is expected to consume. Pursuant to Local Rule 317, the Joint Witness List need not include impeachment or rebuttal witnesses.

WARNING

Applies to

Ex parte application

Ex parte applications must comply with CRC 3.1200 through 3.1207, be in writing, and include a declaration stating notice details and whether the application will be opposed.

Ex-Parte applications must comply with CRC 3.1200 through 3.1207. Applications must be in writing and include all of the following: 1. A declaration setting forth details of the notice given to opposing counsel of the ex-parte hearing and stating whether the application will be opposed;

WARNING

Applies to

Deposition designations

Deposition designations must be in writing on a highlighted hard copy of the transcript provided to opposing counsel by the Issue Conference, with counter-designations in a different color and objections noted in the margin.

A party that expects to present one or more witnesses at trial by deposition shall, no later than the Issue Conference, provide opposing counsel with its written deposition designations. This shall be done by providing a hard copy of the deposition transcript with that party’s designations highlighted. The other party shall, on the same hard copy of the document, mark its counter-designations (by highlighting them in a different color) and also indicate, in the margin next to any testimony designated by the other side, any objections to the admissibility of the designated testimony.

WARNING

Applies to

Ex parte application

Ex parte moving papers must show admissible evidence of proper notice, state whether the other parties will oppose, and the moving counsel must attempt to learn the opposing position.

The moving papers must demonstrate with admissible evidence that the moving party gave proper notice and must state whether the other parties to the case will oppose the application. Counsel for the moving party must make good faith efforts to speak with opposing counsel to determine their position(s) on the ex-parte application.

WARNING

Applies to

Request for judicial notice

Requests for judicial notice must be in a separate document, attach the document(s), and specify the legal basis with citation.

All requests for judicial notice must be set forth in a separate document, must attach a copy of the document(s) of which notice is requested, and must specify (with appropriate legal citation) the legal basis on which judicial notice is sought.

WARNING

Applies to

Joint list of controverted issues

Counsel must prepare a joint list of controverted issues for trial.

5. Counsel has prepared a joint list of controverted issues.**

WARNING

Applies to

Exhibits

Counsel must inspect all exhibits and diagrams, ensure they are ready for clerk premarking, and submit stipulations as to admission or foundation waiver with the exhibits.

1. Counsel has inspected all exhibits and diagrams and the exhibits are ready for premarking by the clerk. All stipulations as to admission into evidence or waiver of foundation are submitted with the exhibits(s).

WARNING

Applies to

Videotaped deposition

c. Videotaped depositions must be transcribed and marked as an exhibit. The videotape must be edited before being shown to the jury to remove objections and argument by counsel.

c. Videotaped depositions must be transcribed and marked as an exhibit. The videotape must be edited before being shown to the jury to remove objections and argument by counsel.

WARNING

Applies to

Trial notebook

The trial notebook must contain ten specified documents, double-sided and each separately tabbed.

The court’s trial notebook shall contain the following double-sided documents, each separately tabbed: 1. Joint Statement of the Case; 2. Executed Statement of Compliance; 3. Joint List of Stipulated Facts; 4. Joint List of Controverted Issues; 5. Joint Exhibit List; 6. Joint Witness List; 7. Proposed Voir Dire Questions (if any) for court voir dire; 8. Procedural Stipulations; 9. Proposed Verdict Form; and 10. In Limine Motions and Oppositions

WARNING

Applies to

Separate statement

Separate statements must comply with CRC 3.1350.

Separate statements must comply with CRC 3.1350.

WARNING

Applies to

Case management statement

All parties must file a Case Management Statement in compliance with CRC 3.725 and comply with CRC 3.720 through 3.734.

All Parties must be fully familiar with, and comply with as applicable, CRC 3.720 through 3.734, including but not limited to the requirement that all Parties file a Case Management Statement in compliance with CRC 3.725.

WARNING

Applies to

Exhibit

In a two-party case, Plaintiff numbers exhibits starting at 1 and Defendant at 200; parties must agree on non-duplicative number ranges, use only numbers not letters, and number each page of each exhibit separately.

c. In a two-party case, Plaintiff shall number its exhibits starting with 1. Defendant shall number its exhibits starting with 200. If, in any given case, these numbers are not sufficient to accommodate all exhibits, the Parties shall cooperate in agreeing on an appropriate number range for each party. If there are more than two parties, the Parties shall cooperate in agreeing on a number range for each party, so that no two parties use the same exhibit numbers. Duplicate exhibits are to be avoided. Only exhibit numbers (not letters) are to be used. Each page of each exhibit must be separately numbered.

WARNING

Applies to

Ex parte application

Must include

proposed order

An ex parte application must include a proposed order.

All papers in support of an ex-parte application (including the proposed order) must be e-filed – and courtesy copies delivered to the courtroom – no later than 3:00 p.m. the business day before the ex parte hearing.

WARNING

Applies to

Joint exhibit list

The Joint Exhibit List must be prepared by the Issue Conference and include each exhibit's number and description with the document date or an undated notation; impeachment/rebuttal exhibits are not required.

At or before the Issue Conference, the Parties must cooperate in preparing a Joint Exhibit List for trial. The parties may, but are not required to, use the attached Joint Exhibit List form. The Joint Exhibit List shall include the exhibit number and a brief description of each exhibit, including the date of the document or a notation that the document is undated (e.g., “Exhibit 100, Letter from J. Jones to C. Clark dated 1/12/2000”). Pursuant to Local Rule 317, the parties need not exchange or include on the Joint Exhibit List those exhibits contemplated to be used for impeachment or rebuttal.

WARNING

Applies to

List of stipulated facts

All counsel must prepare a list of stipulated facts and make a good-faith effort to stipulate to as many documents, foundational waivers, and similar matters as possible.

6. All counsel have prepared a list of stipulated facts and made a good faith effort to stipulate to as many documents, waiver of foundational requirements, etc., as reasonably possible.**

WARNINGCivil cases

Applies to

Trial

Counsel must bring trial and exhibit binders on the first day of trial.

Counsels are to bring trial and exhibit binders on first day of trial.

WARNING

Applies to

Exhibit binder

Each exhibit binder must have a copy of the Joint Exhibit List at the front.

A copy of the Joint Exhibit List shall be placed in the front of each exhibit binder.

WARNING

Applies to

Deposition counter designations

The opposing party must mark counter-designations on the same transcript copy using a different highlight color.

The other Party shall, on the same copy of the highlighted deposition, mark its counter-designations (by highlighting them in a different color).

WARNING

Applies to

Demonstrative aid

A party must show a demonstrative aid to the opposing party at least 24 hours before its expected use.

A Party wishing to use a demonstrative aid at trial shall show the demonstrative to the opposing Party at least 24 hours before it expects the demonstrative to be used, to give the opposing Party an opportunity to review it and, if necessary, raise any issues regarding it with the court.

WARNING

Applies to

Deposition designations

Written deposition designations must be provided on a copy of the transcript with the party’s designations highlighted.

This shall be done by providing a copy of the deposition transcript with that Party’s designations highlighted.

INFOCivil cases

Applies to

Trial notebook

The trial notebook must contain ten specific items, each separately tabbed.

The court’s trial notebook shall contain the following, each separately tabbed: 1. Joint Statement of the Case; 2. Executed Statement of Compliance; 3. Joint List of Stipulated Facts; 4. Joint List of Controverted Issues; 5. Joint Exhibit List; 6. Joint Witness List; 7. Proposed Voir Dire Questions (if any) for court voir dire; 8. Factual Stipulations; 9. Proposed Verdict Form; 10. In Limine Motions and Oppositions.

INFOCivil cases

Applies to

Exhibits

Plaintiff exhibits numbered starting with 1, defendant exhibits starting with 200; parties must cooperate to avoid duplicates; every page must be numbered.

In a two-party case, Plaintiff shall number its exhibits starting with 1; Defendants shall number its exhibits starting with 200. If in a particular case these numbers are not sufficient to cover all exhibits, the Parties are to cooperate and agree to an appropriate number range for each party. If there are more than two Parties, the Parties are to cooperate in agreeing on a number range for each party. No two Parties are to use the same number, and duplicate exhibits are to be avoided. Every page of each exhibit must be separately numbered.

INFOCivil cases

Applies to

Statement of compliance

A Statement of Compliance must be completed and submitted before being signed by all counsel.

A statement of Compliance must be submitted and must be completed prior to being signed by all counsel.

INFOCivil cases

Applies to

Status report

Please focus on the latest developments since your last Status Conference.

Please focus on the latest developments since your last Status Conference.

INFOCivil cases

Applies to

Case management statement

Counsel should use pleading paper rather than Judicial Council Form CM-110 and include in the Statement a discussion of the applicable subjects set forth in CRC Rule 3.727.

Counsel should use pleading paper rather than Judicial Council Form CM-110 and include in the Statement a discussion of the applicable subjects set forth in CRC Rule 3.727.

INFOCivil cases

Applies to

Exhibit witness copy

The first page of every exhibit in the witness copy should have a filled-out GREEN exhibit tag stapled to the top right corner.

The first page of every exhibit in the witness copy should have a GREEN exhibit tag filled out and stapled to the top right corner.

INFO

Applies to

Status conference report

Status conference reports shall be filed (using pleading paper) at least 5 court days before the scheduled conference/hearing and should focus on the latest developments since the last conference/hearing.

Status conference reports shall be filed (using pleading paper) at least 5 court days before the scheduled conference/hearing and should focus on the latest developments since the last conference/hearing.

INFO

Applies to

Joint witness list

Parties must submit a joint witness list.

Parties are required to submit a joint witness list (see attached form).

INFOCivil cases

Applies to

Case management statement

Parties are encouraged, but not required, to meet and confer and file a joint Case Management Statement.

The parties are encouraged to meet and confer and file a joint statement.

INFO

Applies to

Trial notebook

The Joint Trial Notebook must contain 12 specific sections, each separately tabbed.

The Court's trial notebook shall contain the following documents, each separately tabbed: 1. Table of contents 2. Copies of operative pleadings 3. Joint Statement of the Case (Jury Trials) 4. Executed Statement of Compliance 5. Joint Witness List 6. Stipulations of Fact, exhibit admissibility and/or foundation 7. Joint List of Controverted Issues 8. Joint Exhibit List 9. Proposed Voir Dire Questions (if any) for Court voir dire 10. Proposed Jury Instructions (Jury Trials) 11. Proposed Verdict Forms (Jury Trials) 12. Any Trial Briefs

WARNING

Counsel must comply with Local Rule 315, requiring an early meet and confer and the filing of a Joint Meet and Confer Statement.

Counsel must comply with Local Rule 315, which (among other things) requires a generalized early meet-and-confer on the enumerated subjects and the design of a Joint Now Meet and Confer Statement, all within specified time limits.