Inyo County trial binder and trial document requirements

The Court shall set a pre-trial conference date approximately five (5) judicial days prior to the date of trial. Personal appearances are mandatory for all attorneys representing the parties, and who will actually be trying the case.

Inyo calls it a Pre-trial Conference. It is this court's trial readiness conference and there is no other. Two cautions on the number. The rule says "approximately," so the real interval comes off the court's setting order under Rule 6.10(c)(7), not off this rule. And it says "judicial days," not court days. The rules use "court days" elsewhere (6.9, 6.11(e)) and never define judicial day, so I am keeping the rule's own word rather than converting.

As to all cases, Mandatory Settlement Conferences shall be set approximately six (6) weeks prior to the trial, or at such other date the Court determines to be appropriate.

I define -6_weeks as approximately six calendar weeks before trial, subject to the court choosing another date. The rest of the subdivision gives the court's reasons and they predict how the date moves: early enough to avoid an unnecessary visiting trial judge or juror summonses, late enough to let the parties finish discovery. The date is ordered at the Case Management and Trial Setting Conference under Rule 6.10(c)(7).

Settlement Conferences are mandatory and require personal appearances of all attorneys and self-represented litigants who will be actually trying the case. Personal appearances are also mandatory for all parties. In those cases where a party is represented by an insurance carrier, or in any tort case wherein a party who might be liable for damages has insurance coverage, a representative of that carrier must also be present, who is authorized to make all decisions regarding the case, unless excused by the judge. Where such an excuse has been granted, such representative must be immediately accessible by telephone at all times during the conference. Corporate parties and governmental entities must be represented by a responsible officer in addition to and separate from counsel for such parties, who are authorized to make all decisions regarding the case, subject only to the approval of any governing board having the ultimate power to make such decisions.

Read this closely in any construction defect case with carrier participation. The carrier trigger is broader than an insured party: it reaches any tort case where a party who might be liable has coverage. The entity requirement is a person "in addition to and separate from counsel," so outside counsel alone does not satisfy it. Rule 6.11(d) makes non-appearance an unlawful interference with the proceedings of the court.

Each party shall serve and file at least five (5) judicial days prior to the Settlement Conference, a settlement conference brief including a statement identifying the parties and their attorneys, a statement of facts, injuries, damages, legal issues and contentions, and a statement as to the status of settlement negotiations between the parties to date.

Filed, not merely lodged, and nothing on the face of the rule makes it confidential. The negotiations-to-date requirement is unusual and is mandatory. Reading Rule 6.11 in full, no provision allows a separate confidential submission to the judge. Note the term is judicial days here while Rule 6.11(e) below says court days, and the rules define neither.

For those cases previously referred to or stipulating to mediation, at least ten (10) court days prior to the Settlement Conference, the parties shall file a Statement of Agreement or Non-agreement, Form ADR-100. Parties who fail to file the Statement will be subject to sanctions at an Order to Show Cause hearing.

Applies only to mediated or mediation-stipulated cases, which under Rule 6.4.1 can include cases the court refers on its own or that fall in the mandatory referral categories. This is the earliest deadline in the trial run and the only one in the sequence the rules state in court days rather than judicial days.

The failure of any person to appear at, prepare for, or participate in good faith in a mandatory settlement conference, in conformity with the requirements of these rules, unless good cause is shown for such failure, is an unlawful interference with the proceedings of the Court and may result in sanctions.

Reaches "any person," not just counsel, so it covers the carrier representative and the corporate officer Rule 6.11(b) requires. "Prepare for" is a separate trigger from "appear at," which puts the Rule 6.11(c) brief inside the sanction exposure.

On a case by case basis, the Court may direct the parties to lodge with the Court an additional copy of any or all pleadings and exhibits, so that the same may be used by the Court.

The closest thing Inyo publishes to a bench binder requirement, and it is entirely discretionary. No tabs, no index, no copy count, no format, no deadline. Ask the assigned judge at or before the Case Management and Trial Setting Conference whether judge's copies will be directed, and build to that instruction. I confirmed the county rule supplies no answer: the words binder, notebook, three-ring, tabbed and index appear zero times in the full rule set.

At least five (5) judicial days prior to the pre-trial conference, counsel shall have served, exchanged, and filed with the Court the following:

trc_date here is Inyo's Pre-trial Conference under Rule 6.15(a). Rule 6.2(a) makes "counsel" include parties representing themselves, and Rule 3.3 says the same, so the deadline binds self-represented parties. Do not calendar this off the trial date. Stacking the two approximations (about five judicial days to the conference, five more to the filing) gets you near ten judicial days out, but Rule 6.15(a) says "approximately" and no rule sets a trial-anchored deadline for these documents. Take the conference date off the setting order and count back from it. The eight items are broken out below.

A witness list containing a brief statement of anticipated testimony of each witness;

Each party files and exchanges its own under the 6.15(b) lead-in. No joint witness list is required. The per-witness summary is a real content burden and more than most California local rules ask for.

A list of pre-marked exhibits to be used at trial;

"Pre-marked" is doing real work. Marking has to be finished before the list is served, because Rule 6.13 then requires every counsel to have personally inspected those pre-marked exhibits before the conference. The rules do not say who marks, or whether plaintiff uses numbers and defendant letters.

Prior to the Pre-trial Conference, attorneys and self-represented litigants for all parties shall have personally inspected all pre-marked exhibits which are intended by the attorneys and self-represented litigants to be used at the time of trial.

I define before_event as: the rule fixes no measured interval, only that the act be complete before the Pre-trial Conference. "Personally inspected" is the operative phrase, so a paralegal review will not do. This is what forces exhibit exchange well ahead of the five-day filing mark, since you cannot inspect what has not been marked and produced.

Requested CACI and special jury instructions;

CACI named specifically. Reading Article VI in full, the rules set no page limit, no format, no joint set, and no requirement to identify which instructions are disputed.

Proposed verdict forms, and in any case where special verdicts or findings will be required, proposed form of any special verdicts or interrogatories which will be required for the resolution of the case;

Two obligations in one subdivision. The first is unqualified as written. The second is conditional on special verdicts or findings being required. The rule does not limit either to jury trials on its face.

A proposed short statement of the case to be read to the jury. Counsel shall meet and confer and make a good faith effort to submit an agreed upon joint statement of the case.

The only item in the Rule 6.15(b) list carrying a meet and confer obligation and the only one the court asks the parties to make joint. Build in exchange time ahead of the five-day mark.

A Pre-trial Conference Brief which includes an estimate as to the length of trial, a statement of the facts, law and respective contentions of the parties regarding liability, damages, nature and extent of injuries, any unusual evidentiary or legal issues anticipated at trial, and all matters of fact believed by any party to be appropriate for stipulation.

This is Inyo's trial brief and the civil rules require no other. The phrase "trial brief" appears nowhere in the local rules. The contents list is specific enough to use as a checklist. The proposed-stipulations item is easy to miss and is mandatory. No page limit is published.

Transcripts of all depositions which will be utilized during the trial shall be lodged with the Clerk of the Court prior to or at the time of the Pre-trial Conference. The Court will utilize the lodged deposition, and it is counsel's responsibility to provide sufficient copies for use by counsel and the witness, if desired.

A lodging requirement for complete transcripts, not a page-and-line designation procedure. The copies obligation runs to counsel and the witness, not to the court. Deadline is "prior to or at the time of" the conference, so earlier is fine. Lodged documents cannot be e-filed under Rule 12.3(c), so the transcripts go over conventionally in paper.

Any in limine motions; and,

Same deadline as the standalone in limine rule, 6.12, so the two are consistent. Article VI provides no opposition briefs and no briefing schedule on in limine motions. Do not confuse this with Rule 10.2, which is the criminal in limine rule and sits in Article X.

Absent leave of Court, upon a showing of good cause, all motions in limine shall be heard at the Pre-trial Conference, be in writing, and are to be served and filed at least five (5) judicial days prior to the Pre-trial Conference.

The rule opens by giving its reason: the court summons jurors for individual trials and wants to minimize delay and inconvenience to them. Practical effect is that evidentiary fights get resolved before jurors are called, so an in limine motion held for the morning of trial is out absent leave.

Any proposed voir dire questionnaires;

Conditional. Nothing requires a party to propose a questionnaire. No rule states what happens if one is raised late, so the exposure is the general sanction power in Rules 3.2 and 6.19, which names exclusion of evidence.

The following documents will not be accepted electronically: ... Exhibits to be lodged for hearings or trials ... Lodged Documents (Notice of Lodgment may be electronically filed, however documents to be lodged must be lodged and/or served conventionally in paper form.)

A delivery-format rule with no deadline of its own. The timing comes from Rules 6.14 and 6.15(c), which is why it sits on the conference row, but nothing is due under 12.3(c) itself. The ellipses stand in for unrelated bullets in the same list (family law defaults, original wills, sealed documents and so on); I verified each retained fragment against the source. Electronic filing is permissive and is allowed in limited and unlimited civil under Rule 12.2, so the Rule 6.15(b) filings may be e-filed even though lodged exhibits may not.

Make Orders setting further interim case management/status conferences, setting the mandatory settlement conference, pre-trial conference, and the trial date.

The whole trial-document calendar is fixed at this one conference, so it is the moment to raise trial length, expert scheduling and any request for judge's copies under Rule 6.14. Rule 6.10(b) requires counsel to be "familiar with the case, prepared to discuss all matters, and commit to the setting of a trial date, and other pre-trial settings," and "Counsel who fails to attend or participate shall be subject to sanctions." Rule 6.10(c)(5) covers expert exchange scheduling and warns the court "shall closely examine a claim that multiple expert witnesses are required," which matters in a construction defect case.

Each appearing party shall file and serve a completed Case Management Statement (form CM-110) at least five (5) court days before the first Case Management and Trial Setting Conference.

Anchored to the conference the court sets, not to trial. The conference itself is set within 150 days of the filing of the original complaint under Rule 6.5(b). This rule says court days, one of only two in the civil article that do.

It is the policy of this Court that once any date has been set, it cannot be changed without a showing of good cause.

Sits inside the delay reduction policy, which presumes 90 percent of civil cases conclude within 12 months of filing and treats every case as a Plan 1 case unless the court says otherwise on good cause. Practical read: assume the Pre-trial Conference, MSC and trial dates set at the Rule 6.10 conference are fixed, and plan the document calendar around them rather than around a continuance.

Each party shall be accompanied at the mediation by the lawyer who will be primarily responsible for handling the trial of the matter.

This is the mediation session, a different event from the Rule 6.11 settlement conference, and it feeds the Rule 6.11(e) ADR-100 filing. Rule 6.4.1(d)(3) adds, in full: "Insurers. Insurer representatives who are necessary are required to attend in person." Rule 6.4.1(d)(4) allows an excuse only on a showing of extraordinary or otherwise unjustifiable hardship, or on stipulation with the mediator's concurrence, and an excused person must still be available by telephone. Rule 6.4.1(d)(5) makes non-compliance sanctionable under Cal. Rules of Court, rule 2.30, CCP 128.5, and Rule 6.19.

Once trial is commenced, each party shall have witnesses available to utilize to the fullest extent possible every trial day.

Short rule, real effect. Paired with the Rule 6.4 delay reduction policy, dark time in a trial day is a compliance problem. Line up standby witnesses, especially experts travelling into the Owens Valley.

The Court neither provides nor arranges for the services of a court reporter in general civil cases.

Rule 2.7(b) says the same under Cal. Rules of Court, rule 2.956, listing civil law and motion and civil trials among the matters with no court-provided reporter, and adds: "A litigant who wishes to obtain a record of a hearing for any of the above types of matters must arrange for a court reporter at their expense." Rule 2.7(b) also notes a fee-waiver party may request an official reporter under rule 2.956(b)(3), and that the court may use electronic recording where allowed by law if no reporter is available. Book the reporter well before the Pre-trial Conference. Availability in Inyo County is a logistics problem, not a formality.

Any unjustified failure to comply with the requirements of any local rule of the Superior Court of the State of California, County of Inyo may result in the imposition of sanctions, including assessment of fines, court costs or attorney fees against the offending party, or other sanctions as determined by the Court, including issue preclusion, exclusion of evidence, striking of pleadings, or dismissal of an action or cause of action.

This is the teeth behind every Rule 6.15(b) deadline, because the rules attach no specific consequence to a late trial-document filing. Exclusion of evidence is named on the face of the rule, which is the exposure that matters on a late exhibit list, witness list or in limine motion. Article III is court-wide, not civil-only, so it reaches Article VI.

If the Court finds that any party has not proceeded with due diligence or has otherwise failed to comply these Rules, sanctions may be imposed.

Quoted exactly as printed, including the dropped "with" after "comply." Duplicates Rule 3.2 inside Article VI and adds the due diligence trigger, which ties back to the Rule 6.4 delay reduction policy. Rules 6.4.1(d)(5) and 6.10(e) both route back to this rule.