Employment Law Exhibits for California Courts
California employment law cases—including FEHA discrimination claims, wrongful termination, wage and hour disputes, and PAGA actions—require meticulous exhibit preparation. California's employee-friendly laws under the Labor Code and FEHA create unique documentation requirements. This guide covers exhibit preparation for employment disputes in California Superior Court and federal courts.
California Quick Reference
| E-Filing System | File & ServeXpress ↗ |
| File Size Limit | 25 MB |
| Exchange Deadline | 30 days before trial (CCP § 2034.260) |
| Primary Rule | FEHA, Labor Code, CRC 3.1110 |
Common Employment Law Exhibits in California
California Employment Law Tips
- 1DFEH (now CRD) right-to-sue letter is a prerequisite exhibit for FEHA claims
- 2PAGA cases require the LWDA notice letter and any response as foundational exhibits
- 3Wage and hour cases need complete timekeeping records - request in discovery
- 4Personnel files are discoverable under Labor Code § 1198.5 - include CPRA request
- 5Los Angeles Superior Court has specific employment case handling in Complex Litigation
- 6San Francisco has strong local employment ordinances - include relevant city laws
- 7Bates stamp all HR documents and emails for deposition reference
Common Employment Law Filing Mistakes in California
Employment Law Exhibits in California: FAQ
What exhibits are required for a California FEHA discrimination case?
FEHA cases require the DFEH/CRD right-to-sue letter as a foundational exhibit. You'll also need personnel records, the alleged discriminatory communications or actions, company policies, comparator evidence, and any written complaints made during employment.
How do I organize wage and hour exhibits for California courts?
Organize wage exhibits chronologically: (1) employment agreement showing pay rate, (2) time records showing hours worked, (3) pay stubs showing amounts paid, (4) calculations showing underpayment. Bates stamp all pages for easy reference during testimony.
What is required for PAGA representative action exhibits?
PAGA cases require the written notice to the LWDA and employer (Labor Code § 2699.3) and any LWDA response. You'll also need evidence of the alleged violations affecting "aggrieved employees" - often including policy documents and sample records.
Are text messages and personal email admissible as exhibits in California employment cases?
Yes, text messages and personal emails are discoverable and admissible if relevant. Preserve them carefully - screenshot with metadata showing dates and participants. California courts increasingly see workplace communications on personal devices.
What California-specific documents should I request in employment discovery?
Request the complete personnel file (Labor Code § 1198.5), all policies and handbooks, time records, pay records, investigation files, and communications about the employee. California law provides broad access to personnel records.
Related Resources
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