Rule 3.1548.Pretrial submissions for voluntary expedited jury trials

Division 15. Trial · Chapter 4.5. Expedited Jury Trials · Article 3. Rules Applicable Only to Cases with Voluntary Expedited Jury Trials · Last amended 2016 · Last verified July 29, 2026

In one sentenceRule 3.1548 sets the pretrial exchange and filing deadlines for a voluntary expedited jury trial, requiring parties to serve evidence and witness lists 25 days before trial, file motions in limine and lodge trial materials with the court 20 days out, and attend a pretrial conference at least 15 days before trial where evidentiary objections get resolved.

Full Text of Rule 3.1548

Text sizeJump to: (a) (b) (c) (d) (e) (f) (g)

(a) Service Service under this rule must be by a means consistent with Code of Civil Procedure sections 1010.6, 1011, 1012, and 1013 or rule 2.251 and be reasonably calculated to assure delivery to the other party or parties no later than the close of business on the last allowable day for service as specified below.

(b) Pretrial exchange for voluntary expedited jury trials Unless otherwise agreed by the parties, no later than 25 days before trial, each party must serve on all other parties the following:

(1) Copies of any documentary evidence that the party intends to introduce at trial (except for documentary evidence to be used solely for impeachment or rebuttal), including, but not limited to, medical bills, medical records, and lost income records;

(2) A list of all witnesses whom the party intends to call at trial, except for witnesses to be used solely for impeachment or rebuttal, and designation of whether the testimony will be in person, by video, or by deposition transcript;

(3) A list of depositions that the party intends to use at trial, except for depositions to be used solely for impeachment or rebuttal;

(4) A copy of any audiotapes, videotapes, digital video discs (DVDs), compact discs (CDs), or other similar recorded materials that the party intends to use at trial for evidentiary purposes, except recorded materials to be used solely for impeachment or rebuttal and recorded material intended to be used solely in closing argument;

(5) A copy of any proposed jury questionnaires (parties are encouraged to agree in advance on a questionnaire);

(6) A list of proposed approved introductory instructions, preinstructions, and instructions to be read by the judge to the jury;

(7) A copy of any proposed special jury instructions in the form and format described in rule 2.1055;

(8) Any proposed verdict forms;

(9) A special glossary, if the case involves technical or unusual vocabulary; and

(10) Motions in limine. (Subd (b) amended effective July 1, 2016.)

(c) Supplemental exchange for voluntary expedited jury trials No later than 20 days before trial, a party may serve on any other party any additional documentary evidence and a list of any additional witnesses whom the party intends to use at trial in light of the exchange of information under subdivision (b). (Subd (c) amended effective July 1, 2016.)

(d) Submissions to court for voluntary expedited jury trials No later than 20 days before trial, each party must file all motions in limine and must lodge with the court any items served under (b)(2)–(9) and (c). (Subd (d) amended effective July 1, 2016.)

(e) Preclusionary effect Unless good cause is shown for any omission, failure to serve documentary evidence as required under this rule will be grounds for preclusion of the evidence at the time of trial.

(f) Pretrial conference for voluntary expedited jury trials No later than 15 days before trial, unless that period is modified by the consent order, the judicial officer assigned to the case must conduct a pretrial conference, at which time objections to any documentary evidence previously submitted will be ruled on. If there are no objections at that time, counsel must stipulate in writing to the admissibility of the evidence. Matters to be addressed at the pretrial conference, in addition to the evidentiary objections, include the following:

(1) Any evidentiary matters agreed to by the parties, including any stipulations or admissions regarding factual matters;

(2) Any agreement of the parties regarding limitations on necessary or relevant evidence, including any limitations on expert witness testimony;

(3) Any agreements of the parties to use photographs, diagrams, slides, electronic presentations, overhead projections, notebooks of exhibits, or other methods of presenting information to the jury;

(4) Admissibility of any exhibits or demonstrative evidence without legally required authentication or foundation;

(5) Admissibility of video or written depositions and declarations and objections to any portions of them;

(6) Objections to and admissibility of any recorded materials that a party has designated for use at trial;

(7) Jury questionnaires;

(8) Jury instructions;

(9) Special verdict forms;

(10) Allocation of time for each party’s case;

(11) Motions in limine filed before the pretrial conference; and

(12) The parties’ intention on how any high/low agreement will affect an award of fees and costs. (Subd (f) amended effective July 1, 2016.)

(g) Expert witness documents Any documents produced at the deposition of an expert witness are deemed to have been timely exchanged for the purpose of (c) above.

End

Plain-English Summary

Because a voluntary expedited jury trial compresses the trial itself into a few hours, the pretrial exchange has to do work that a longer trial would leave for cross-examination and argument. Rule 3.1548 sets that exchange on a strict calendar. Service under the rule must use one of the recognized methods under the Code of Civil Procedure’s service statutes or the court’s electronic filing rule, timed to reach the other side by the close of business on the deadline. Unless the parties agree otherwise, 25 days before trial each side must serve the documentary evidence it plans to use, its witness list with the method of presenting each witness’s testimony, its list of depositions, any recordings it intends to use, proposed jury questionnaires and instructions, proposed verdict forms, a glossary for technical vocabulary if the case needs one, and motions in limine.

A second, narrower exchange follows: 20 days before trial, a party may serve any additional evidence or witnesses that came up in response to what the other side disclosed. That same 20-day mark is also the deadline for filing motions in limine with the court and lodging the previously served trial materials with the court itself, not just with the other parties. Missing the documentary evidence deadline without good cause carries a real consequence — Rule 3.1548(e) makes preclusion of that evidence at trial the default sanction.

Everything converges at a pretrial conference the assigned judicial officer must hold at least 15 days before trial, unless the consent order sets a different timeline. That conference is where evidentiary objections to the previously submitted documents get decided, and where the parties either stipulate to admissibility or leave a live dispute for trial. The same conference covers jury questionnaires and instructions, verdict forms, time allocation, and how a high/low agreement, if any, affects fees and costs. A final provision spares the parties from a technical trap: documents produced at an expert witness’s deposition count as timely exchanged for purposes of the supplemental exchange deadline, even without separately re-serving them.

Frequently Asked Questions

When must parties exchange evidence and witness lists before a voluntary expedited jury trial?

No later than 25 days before trial, unless the parties agree otherwise, under Rule 3.1548(b).

What happens if a party misses the deadline to serve documentary evidence?

Rule 3.1548(e) makes preclusion of that evidence at trial the default consequence, unless good cause is shown for the omission.

When is the pretrial conference held for a voluntary expedited jury trial?

At least 15 days before trial, unless the consent order sets a different period, under Rule 3.1548(f). The conference resolves evidentiary objections and covers jury instructions, verdict forms, and time allocation.

Do expert deposition documents need to be separately served again before trial?

No. Rule 3.1548(g) deems documents produced at an expert witness’s deposition timely exchanged for the supplemental exchange deadline in subdivision (c).

Amendment History

Rule 3.1548 amended effective July 1, 2016; adopted effective January 1, 2011.

Source & verification. Rule text is reproduced verbatim from the Judicial Council of California. Adopted by the Judicial Council of California. Last verified July 29, 2026. · Official source

Also known as: pretrial exchange deadlines expedited jury trial Californiamotions in limine expedited jury trial deadlineCRC rule 3.1548 pretrial conference