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Personal Injury
CA

Personal Injury Exhibits for California Courts

California personal injury cases require careful attention to CRC 3.1110 formatting requirements and CCP § 2034 expert witness exchange deadlines. With 58 counties and varying local rules, understanding your specific court's requirements is critical. This guide covers exhibit preparation for auto accidents, premises liability, medical malpractice, and other PI cases in California.

Personal Injury exhibits in California: key facts
  • California's primary exhibit rule is CRC 3.1110, CCP § 2034.
  • Personal Injury cases in California e-file through File & ServeXpress.
  • File & ServeXpress caps each uploaded document at 25 MB.
  • The exhibit exchange deadline in California is 30 days before trial (CCP § 2034.260).
  • Common Personal Injury exhibits in California include Medical records and bills (with HIPAA redactions) and Police/accident reports.
  • ExhibitPrep stamps exhibits in the browser, so case files never leave the computer.

Before you file

ExhibitPrep formats documents. It does not provide legal advice, submit filings, or determine whether evidence is admissible or a filing meets court requirements.

Some guidance has not been verified against current official sources. A citation supports only its stated claim and scope. Compare the finished PDF with current court instructions and orders in your case. Follow the filing review checklist.

File & ServeXpress30 days before trial (CCP § 2034.260)CRC 3.1110, CCP § 2034

Opens the tool set up for California — plaintiff: Numbers starting at 1; defendant: Letters starting at A.

Free California Guide

California Quick Reference

E-Filing SystemFile & ServeXpress ↗
File Size Limit25 MB
Exchange Deadline30 days before trial (CCP § 2034.260)
Primary RuleCRC 3.1110, CCP § 2034

Common Personal Injury Exhibits in California

Medical records and bills (with HIPAA redactions)
Police/accident reports
Expert witness declarations (30 days before trial)
Photographs of injuries and accident scene
Employment records for lost wages
Insurance correspondence
Deposition transcripts
Medical expert reports (orthopedic, neurological)
Life care plans for catastrophic injury
Economic loss calculations
Prior medical records (defense may request)
Surveillance footage (if applicable)

California Personal Injury Tips

  • 1On a demand for expert witness exchange, the exchange date is 50 days before the initial trial date or 20 days after service of the demand, whichever is closer to trial
  • 2Los Angeles Superior Court has specific exhibit formatting in LASC Local Rule 3.231
  • 3Exchange exhibits at the Issue Conference, held at least 14 days before trial (Local Rule 317).
  • 4San Francisco and other counties may have different local rules - always check
  • 5Medical records must have proper HIPAA authorizations on file
  • 6Bates stamp all medical records for easy reference at deposition and trial
  • 7Consider organizing exhibits chronologically for injury timeline

Common Personal Injury Filing Mistakes in California

Missing the 30-day expert witness exchange deadline under CCP § 2034
Failing to redact sensitive patient information (SSN, other patients)
Not checking county-specific local rules (LA, OC, SD all differ)
Exceeding 25 MB file size limit without splitting documents
Forgetting to include updated medical records close to trial
Not organizing medical records chronologically with Bates numbers

Personal Injury Exhibits in California: FAQ

What is the expert witness disclosure deadline in California personal injury cases?

Under CCP § 2034.260, parties must simultaneously exchange expert witness information at least 30 days before trial. This includes expert designations and any reports they will rely on. Missing this deadline can result in exclusion of expert testimony.

Do California courts require exhibits to be pre-marked before trial?

In Los Angeles, counsel must serve and file lists of pre-marked trial exhibits at least five days before the final status conference; other counties vary, so check your department's rules. The specific deadline varies by county. Local Rule 3.231 governs prerogative writ proceedings, in which the record must be consecutively numbered (Bates-stamped) from beginning to end. Always check your assigned department's rules.

How should I organize medical records as exhibits in California PI cases?

Organize medical records chronologically with Bates numbering for easy reference. Consider separating by provider or treatment phase. ExhibitPrep can batch stamp hundreds of pages with sequential Bates numbers.

What file size limits apply to California court e-filings?

Confirm the current per-document file-size limit with the court's e-filing service provider. For large medical record exhibits, split into multiple parts (e.g., "Exhibit 1A - Medical Records Part 1 of 3").

Are there different exhibit rules for California arbitration vs. court cases?

Yes, arbitrations (including personal injury matters under JAMS or AAA rules) have different exhibit requirements. Court rules like CRC 3.1110 don't apply to private arbitration, though organized, professionally stamped exhibits are still important.

Related Resources

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Opens the tool set up for California — plaintiff: Numbers starting at 1; defendant: Letters starting at A.

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