Judge Loren G. Freestone
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Courtesy Copies
Pro Hac Vice Application, Motion, Opposition, Reply, Trial Readiness Report, Trial Brief
Document Filing Requirements8 rules
A completed joint trial readiness conference report shall be filed in advance of the hearing pursuant to local rule 2.1.15.
Applications must include proof of service on the State Bar of California, proof of payment of the required fee, and a proposed order.
- Document
- Pro hac vice application
Must include
- •Proposed order
- •Certificate of service
All motions in limine must be filed per local rule 2.1.18.
At trial call, counsel must bring a joint trial notebook containing the enumerated pretrial materials.
- Document
- Joint trial notebook
Must include
- •Exhibit list
- •Table of contents
Court's wording
At trial call, counsel must bring a joint trial notebook, which should be comprised of the following: 1. Table of Contents 2. Copy of Joint Trial Readiness Report 3. Copies of Motion in Limine and Oppositions (in order) 4. Joint Witness List (with description of witnesses’ expected testimony) 5. Joint Exhibit List 6. Copies of Trial Briefs (if any) 7. Joint Statement of the Case 8. Proposed Voir Dire Questions (if any) 9. Jury Instructions (packet agreed upon and packet of those not agreed upon, with indication of who is offering and objecting)
All exhibits must be pre-marked in an up-to-date exhibit book.
Papers must comply strictly with California Rules of Court, rule 3.1800. Non- complying papers will be returned with a notation of defects.
10. Special Verdict Form (either an agreed upon form or each side’s proposed forms). If the parties fail to make a genuine effort to limit disputes on the form of the special verdict, a general verdict form will be utilized.
Proposed default judgments claiming punitive damages and/or non-economic damages will usually require a hearing.
Filing & Service rules
Filing Timing and Cure Windows
Trial briefs must be filed five court days before trial call.
Trial briefs must be filed five court days prior to trial call.
Civil cases
Page 3 | Trial Calls
A party opposing an application may appear ex parte within five days to request a briefing schedule.
If a party opposes an application, that party may appear ex parte within five days to request a briefing schedule.
Civil cases
Page 3
Service and Proof of Service Rules
All exhibits, demonstrative aids, and other material for opening statements must be shared with opposing counsel in advance.
All exhibits, demonstrative aids, or other material to be used in opening statements must be shared with opposing counsel in advance.
Civil cases
Page 3 | Trial Calls
Filing Fees and Waivers
A required fee applies to pro hac vice applications, and proof of its payment must accompany the application.
proof of payment of the required fee
Civil cases
Page 3
Courtesy Copy Requirements
Courtesy copies of pro hac vice applications, noticed motions, oppositions, replies, joint trial readiness conference reports, and trial briefs should be placed in the Department 64 drop box outside the Business Office.
Courtesy copies of the following documents should be placed in the Department 64 drop box, located outside the Business Office on the second floor of the Hall of Justice: • Ex parte applications (delivered no later than 12:00 p.m. the day before the hearing) • Pro hac vice applications • Noticed motions, oppositions, and replies • Joint trial readiness conference reports • Trial briefs
Civil cases
Page 3 | Courtesy Copies