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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.

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

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

  • 1CCP § 2034.260 requires expert witness exchange 30 days before trial - include expert reports as exhibits
  • 2Los Angeles Superior Court has specific exhibit formatting in LASC Local Rule 3.231
  • 3Orange County requires exhibits to be pre-marked before trial readiness conference
  • 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?

Yes, most California courts require exhibits to be pre-marked and exchanged before trial. The specific deadline varies by county. In Los Angeles, exhibits must be lodged per LASC Local Rule 3.231. 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?

Most California courts using File & ServeXpress have a 25 MB limit per document. 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.

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