Kings County Superior Court Local Rules of Court (July 1, 2026) — Chapter 3, Civil Law and Motion, continued (Joining Motions of Other Parties, Motions in Limine, Rules for Civil Trial and Tentative Rulings) (Rules 310 to 313)

Requirement

RULE 310 – Joining Motions of Other Parties If a party desires to receive the same relief as another party and files papers “joining” another party’s motion, the court will not consider the papers to be a separate motion and will not grant relief to the party joining the motion unless that party has complied with all procedural requirements for the filing of motions, including the payment of filing fees, proper notice, format of motion and method of service. (Eff. 1/1/10) RULE 311 – Motions in Limine A. All motions in limine and any opposition thereto must be filed with the court not less than five (5) court days prior to date on which they will be considered by the court. Additionally, parties shall lodge with the clerk of the court all motions in limine and any opposition consistent with the format set forth in Section (B). The court reserves the right to modify such deadline to meet the particular case management needs of any action. Any failure by a party to comply with the deadlines set forth herein and/or alternate deadlines set by the assigned trial judge, may result in the non-compliant pleading being disregarded by the court. B. Prior to lodging any motion in limine with the court, the parties to all civil cases must meet and confer, as follows: 1. The parties must exchange their in limine motions not less than fifteen (15) court days prior to the motion in limine hearing date. The court encourages parties to utilize available forms of electronic transmission. 2. The parties must discuss orally or in writing the exchanged motions with an eye towards limiting the disputes or issues to be addressed by the court. 3. The parties shall draft a stipulation and proposed order to be lodged not less than five (5) court days prior to the motion in limine hearing date, setting forth all motions that the parties agree should be granted by the court. 4. As to all motions in limine to which opposition will be lodged, the parties shall submit to the court in a binder, a document which includes a not more than three (3) page argument for, and a not more than three (3) page argument against, each of the motions. The six (6) page per motion limitation provided for herein is exclusive of exhibits and any table of contents or table of authorities offered by the parties. 5. All documentary evidence relied on in support of or in opposition to a motion in limine regarding which an opposition has been offered, must be compiled into a single binder. The exhibits shall be tabbed to correspond with each of the motions and shall be clearly identified so that the court can easily determine the motion or opposition to which such evidence is directed. The binder shall be lodged with the clerk of the court at the filing window. The binder must be lodged not less than five (5) court days prior to the scheduled motion in limine hearing date. 6. A proposed order must be submitted for each motion to be ruled on by the court. The proposed order shall be submitted with the motion in limine to which it applies. The proposed order, which may be submitted at the end of the relevant motion or as a separate pleading, shall include blank boxes so that the court may mark the motion granted, denied, denied without prejudice to renew at an appropriate time, or modified (with space for the modification). C. In cases where one party is unrepresented and/or opposing counsel is refusing to comply with the requirements set forth in paragraph B, the party filing a motion in limine must submit a declaration with their motion setting forth good cause for their failure to comply with this local rule of court. The declaration must set forth in specific detail all attempts made by the filing party to comply with paragraph B. (Eff. 1/1/13; amended eff. 1/1/23) RULE 312 – Rules for Civil Trial The following shall apply in all limited and unlimited jurisdiction civil trials conducted in the Kings County Superior Court. The court will consider modifications to specific terms of this rule on a case-by-case basis, which should be raised, if possible, before the scheduled Motion in Limine Hearing or Pretrial Conference. To comply with this rule, the parties must meet and confer prior to the Motion in Limine Hearing or Pretrial Conference. Any failure by counsel and/or parties to comply with this rule may result in the court vacating and rescheduling the trial date. Where one or more of the parties is not represented by counsel, a good faith attempt must be made to comply with this rule. 1. Pretrial Conference or Motions in Limine Hearing In all limited and unlimited civil cases not falling under California Code of Civil Procedure §§ 90-98 (Economic Litigation), California Rules of Court, rule 3.400 et seq. (Complex Cases) and/or California Rules of Court, rule 3.2220 et seq. (CEQA), the court conducts a Pretrial Conference or Motions in Limine Hearing. The parties should be prepared to provide/address the following at the conference/hearing, as appropriate: A. The estimated length of trial (including jury selection); B. The joint list of witness names to be read to the jury; C. Any witness or attorney scheduling issues; D. Any witness issues (e.g., unavailability, need for interpreters, etc.); E. Any anticipated evidentiary or other legal issues; F. Any party stipulations; G. A joint statement of the case to be read to the jury; H. A joint list of exhibits expected to be introduced at trial, with any exhibit-related disputes clearly identified for the court. To the extent allowed by law, exhibits shall be exchanged prior to the Pretrial Conference or Motions in Limine Hearing. Exhibits shall be presented the court in a binder or other organized fashion ready for the clerk’s processing during trial. The clerk will use a numerical system of designation of all exhibits. Except as to rebuttal exhibits, the clerk will generally not mark exhibits at the time designated for the start of trial. Exhibits that are not marked during the Pretrial Conference or Motion in Limine Hearing must be presented to the clerk at least two (2) court days prior to the start of trial for marking; I. A joint list of jury instructions and verdicts, with any disputes clearly identified for the court. The parties shall lodge copies of the requested jury instructions and verdicts with the court consistent with California Rules of Court, rule 2.1050 et seq. and California Rules of Court, rule 3.1580. A USB flash drive containing all proposed jury instructions must be provided to the court along with hard copies; J. A trial brief; K. A joint list of voir dire questions, agreed upon juror questionnaire (if appropriate), and brief outline of the case per California Rules of Court, Standard 3.25(b); L. Those documents required by Kings County Superior Court Local Rule 311, in the form required by that rule; M. Any need for an increased panel of potential jurors; N. Whether the jury will be allowed to take notes during trial; O. Whether the jury will automatically be provided with copies of all exhibits during deliberations, or only specific exhibits upon request; P. Any audio, video, or computer needs/accommodations required for trial; Q. Number of alternate jurors to be chosen; R. The preferred method for addressing challenges for cause during voir dire (outside the presence of jury panel, in chambers, etc.); and, S. Any other trial issues that the parties reasonably can anticipate. 2. Jury Selection A. Unless otherwise agreed upon by the court and parties, the court will utilize a “16-pack” method of jury selection (i.e., the prospective jurors in seats 1-16). The court questions the 16 prospective jurors on voir dire, and then each side is given the opportunity to inquire. This process is continued until the jury and the alternates are selected. The objective is to have the jury box and the six-pack seated before the start of each round of peremptory strikes. B. The court and parties will comply with California Code of Civil Procedure section 222.5 and California Rules of Court, Standard 3.25. 3. Witnesses A. It is counsel’s responsibility to have their witnesses available during their case to avoid unnecessary trial delays. If a party has no more witnesses to call, the court may deem that party to have rested. While the court will not make this finding lightly, it does expect that counsel will exercise reasonable judgment in arranging for witnesses. B. If a witness has not completed his or her testimony at the time of a recess or adjournment, counsel shall have the witness on the stand before the jury is seated. C. If a party requests that a witness be called during another party’s case-in-chief, counsel for that party shall meet and confer with opposing counsel promptly upon learning of the need for witness accommodation. D. If a witness requires an interpreter or needs an accommodation based on disability or otherwise, counsel shall make any necessary arrangements with the clerk sufficiently in advance to avoid trial delays. 4. Exhibits A. There shall be made available for use at trial, at least four (4) true and correct copies of all exhibits to be referenced during trial. The parties must have the pages of all exhibits Bates stamped. A USB flash drive containing all documents shall be provided to the court. Each party shall have a copy of the exhibits at counsel table. A copy of the exhibits shall be located at the witness stand, and the court shall be provided with a copy of all exhibits for its own reference during testimony. B. Each party shall request that an exhibit be marked for identification before referencing it. Each exhibit shall only be made up of one (1) document per exhibit. Any subsequent reference to the exhibit shall mention the exhibit designation so the appellate record is clear. C. All disputes regarding exhibits will be heard along with the Motions in Limine. D. A party shall not publish any exhibit to the jury without first requesting to do so. After the request, any objection must be immediately made. Absent a prompt objection, the request generally will be granted as a matter of course. E. The parties shall comply with California Rules of Court, rule 2.1040, requiring the provision of a transcript of various recordings. The court shall deem that the party receiving the transcript before announcing “ready” waives any objection to the accuracy of the transcript unless raised at the first trial appearance before this court. All transcripts of depositions to be read into the record must have all non-read portions redacted. The deposition transcripts will then be incorporated into the official report’s record. F. The party offering an exhibit is responsible for supplying/arranging for any equipment necessary to present that exhibit, such as a sound or video device for a CD or DVD. 5. Motions A. Before bringing any trial motion, the parties shall meet to discuss whether they can reach an informal resolution. B. The parties shall bring any trial motions before the commencement of jury selection, unless the motion reasonably could not have been anticipated previously – in which case the moving party shall seek to have the motion(s) heard before the jury returns the next day at 8:30 a.m., if possible. The court generally will not hear motions while the jury is waiting unless it is necessary to avoid prejudice to one of the parties. (Eff. 1/1/19; amended 1/1/24) RULE 313 – Tentative Rulings A. The court adopts the tentative ruling procedure set out in California Rules of Court, rule 3.1308(a)(2). The tentative ruling or notice to appear will generally be available by 4:00 p.m. the court day before the hearing. Unless the court directs otherwise, the court’s tentative ruling will be available on the court’s website or by calling (559) 582-1010, Ext 6002. B. The court does not require notice of intent to appear. (Cal. Rules of Court, rule 3.1308, subd. (a)(2).) If no parties appear, the court will construe the non-appearance as a submission on the tentative ruling and will adopt the tentative ruling as the order of the court. Parties intending to present oral argument regarding a tentative ruling are expected to contact opposing counsel(s) the day before the hearing to ensure the appearance of all affected parties at the hearing. If only one party appears to present oral argument as to the tentative ruling, the court generally will not allow for oral argument and instead will continue the hearing for the appearance of all parties. C. Pursuant to the restrictions in Code of Civil Procedure § 1161.2, no tentative rulings are posted for unlawful detainer cases and appearances are required. (Eff. 1/1/13 as Rule 312; renumbered 1/1/19; amended 1/1/25; amended 1/1/26) (RULES 314 - 399 Reserved)