Division 11. Law and Motion · Chapter 2. Format of Motion Papers · Last amended 2008 · Last verified July 29, 2026
In one sentenceRule 3.1112 lists the papers a motion must include — a notice of hearing, the motion itself, and a supporting memorandum — describes what a motion must state, allows combined filings, and exempts motions in limine from the notice-of-hearing requirement.
(a)Motions required papers Unless otherwise provided by the rules in this division, the papers filed in support of a motion must consist of at least the following:
(1)A notice of hearing on the motion;
(2)The motion itself; and
(3)A memorandum in support of the motion or demurrer. (Subd (a) amended effective January 1, 2007.)
(b)Other papers Other papers may be filed in support of a motion, including declarations, exhibits, appendices, and other documents or pleadings. (Subd (b) adopted effective January 1, 2007.)
(c)Form of motion papers The papers filed under (a) and (b) may either be filed as separate documents or combined in one or more documents if the party filing a combined pleading specifies these items separately in the caption of the combined pleading. (Subd (c) amended and lettered effective January 1, 2007 adopted as part of subd (a).)
(1)Identify the party or parties bringing the motion;
(2)Name the parties to whom it is addressed;
(3)Briefly state the basis for the motion and the relief sought; and
(4)If a pleading is challenged, state the specific portion challenged. (Subd (d) amended and relettered effective January 1, 2007; adopted as subd (b).)
(e)Additional requirements for motions In addition to the requirements of this rule, a motion relating to the subjects specified in chapter 6 of this division must comply with any additional requirements in that chapter. (Subd (e) amended effective July 1, 2008; previously amended effective January 1, 2007.)
(f)Motion in limine Notwithstanding (a), a motion in limine filed before or during trial need not be accompanied by a notice of hearing. The timing and place of the filing and service of the motion are at the discretion of the trial judge. (Subd (f) adopted effective January 1, 2007.)
Plain-English Summary
Rule 3.1112 spells out the paperwork a motion needs to be complete. At minimum, unless another rule in the division says otherwise, the filing has to include a notice of hearing, the motion itself, and a memorandum backing it up. Parties can add more — declarations, exhibits, appendices, whatever else supports the request — and none of these pieces has to stand alone as a separate document; a party can combine them into one filing as long as the caption spells out each component separately.
The rule also tells you what the motion document itself has to say: who is bringing it, who it is directed at, the basis for the request and the relief sought, and, if a pleading is under attack, exactly which part of it. Motions on subjects covered by chapter 6 of the division — things like demurrers, motions to strike, or motions for summary judgment — pick up extra requirements layered on top of this baseline. And motions in limine get a break from the general rule: because they are typically filed right before or during trial, they do not need a separate notice of hearing, and the trial judge controls when and how they get filed and served.
Frequently Asked Questions
Can I combine my notice of motion, the motion, and my memorandum into one document?
Yes. Rule 3.1112(c) allows a combined filing as long as the caption of the combined document lists each component — notice of hearing, motion, and memorandum — separately.
Does a motion in limine need a notice of hearing?
No. Rule 3.1112(f) exempts motions in limine filed before or during trial from the notice-of-hearing requirement, and leaves the timing and manner of filing to the trial judge’s discretion.
What does a motion itself have to state?
Under Rule 3.1112(d), it must identify who is bringing the motion, name the parties it is directed at, briefly state the basis for the motion and the relief requested, and, when a pleading is being challenged, identify the specific part being challenged.
Amendment History
Rule 3.1112 amended effective July 1, 2008; adopted as rule 312 effective July 1, 1997; previously amended and renumbered effective January 1, 2007.
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
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