Motions in Limine – Exchange with opposing party 7 days before trial. File motions and oppositions with court on first day of trial.
Exhibit List, Witness List, Jury Instructions, Trial Brief, and Statement of the Case – Parties shall meet and confer prior to the first day of trial. These documents shall be submitted to the court on the first day of trial.
Trial Briefs, Statement of the Case, and Witness Lists – File with Court at Civil Trial Conference.
Exhibits – Present to Courtroom clerk on first day of trial.
Motions in Limine– Motions in limine must be filed and served 10 days before trial. Opposition to motions in limine must be filed and served 5 days before trial.
Note: If more than 5 motions are filed, an index of motions is required.
Special Requirements: Motions to Preclude Evidence, must include:
A clear identification of the specific matter alleged to be inadmissible or unduly prejudicial;
A representation to the court that the subject of the motion has been discussed with opposing counsel, and that opposing counsel has either indicated that such matter will be mentioned or displayed in the presence of the jury before it is admitted in evidence or that counsel has refused to stipulate that such matter will not be mentioned or displayed in the presence of the jury unless and until it is admitted in evidence;
A statement of the specific prejudice that will be suffered by the moving party if the motion is not granted;
If the motion seeks to make binding an answer given in response to discovery, the declaration must set forth the question and the answer and state why the use of the answer for impeachment will not adequately protect the moving party against prejudice in the event that evidence inconsistent with the answer is offered.
If the motion concerns deposition testimony, the motion shall be supported or opposed by attached excerpts of relevant deposition testimony, in conformance with California Rule of Court 3.116.
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