(a) Time for filing and service of objections Unless otherwise excused by the court on a showing of good cause, all written objections to evidence in support of or in opposition to a motion for summary judgment or summary adjudication must be served and filed at the same time as the objecting party’s opposition or reply papers are served and filed. (Subd (a) amended and relettered effective January 1, 2007; adopted as untitled subd; previously amended and lettered subd (b) effective January 1, 2007.)
Rule 3.1354.Written objections to evidence
Division 11. Law and Motion · Chapter 6. Particular Motions · Article 5. Summary Judgment Motions · Last amended 2016 · Last verified July 29, 2026
In one sentenceRule 3.1354 requires written evidentiary objections on a summary judgment motion to be filed and served with the opposition or reply, in a separate document that numbers each objection, quotes the challenged material, states the grounds, and comes with a proposed order the judge can sign to rule on every objection.
Full Text of Rule 3.1354
(b) Format of objections All written objections to evidence must be served and filed separately from the other papers in support of or in opposition to the motion. Objections to specific evidence must be referenced by the objection number in the right column of a separate statement in opposition or reply to a motion, but the objections must not be restated or reargued in the separate statement. Each written objection must be numbered consecutively and must:
(1) Identify the name of the document in which the specific material objected to is located;
(2) State the exhibit, title, page, and line number of the material objected to;
(3) Quote or set forth the objectionable statement or material; and
(4) State the grounds for each objection to that statement or material. Written objections to evidence must follow one of the following two formats: (First Format): Objections to Jackson Declaration Objection Number 1 “Johnson told me that no widgets were ever received.” (Jackson declaration, page 3, lines 7–8.) Grounds for Objection 1: Hearsay (Evid. Code, § 1200); lack of personal knowledge (Evid. Code, § 702(a)). (Second Format): Objections to Jackson Declaration Material Objected to: Grounds for Objection: 1. Jackson declaration, page 3, lines Hearsay (Evid. Code, §1200); lack of 7–8: “Johnson told me that no personal knowledge (Evid. Code, § widgets were ever received.” 702(a)). (Subd (b) amended effective January 1, 2016; adopted effective January 1, 2007.)
(c) Proposed order A party submitting written objections to evidence must submit with the objections a proposed order. The proposed order must include places for the court to indicate whether it has sustained or overruled each objection. It must also include a place for the signature of the judge. The court may require that the proposed order be provided in electronic form. The proposed order must be in one of the following two formats: (First Format): Objections to Jackson Declaration Objection Number 1 “Johnson told me that no widgets were ever received.” (Jackson declaration, page 3, lines 7–8.) Grounds for Objection 1: Hearsay (Evid. Code, § 1200); lack of personal knowledge (Evid. Code, § 702(a)). Court’s Ruling on Objection 1: Sustained: _________ Overruled:_________ (Second Format): Objections to Jackson Declaration Material Grounds for Objection: Ruling on the Objection Objected to: 1. Jackson Hearsay (Evid. Code, § Sustained: _________ declaration, 1200); lack of personal Overruled:_________ page 3, lines knowledge (Evid. Code, § 7–8: 702(a)). “Johnson told me that no widgets were ever received.” Date: ______________________ _______________________________ Judge (Subd (c) amended effective January 1, 2016; adopted effective January 1, 2007.)
Plain-English Summary
Rule 3.1354 turns the written-objection option under Rule 3.1352 into a precise checklist. Written objections must be served and filed at the same time as the objecting party’s opposition or reply papers, unless the court excuses that timing for good cause. They cannot be folded into the memorandum or separate statement — they have to stand as their own document, though a party can flag which objections apply to which disputed facts by referencing the objection numbers in the separate statement without re-arguing them there.
Each objection has to do four things: name the document containing the challenged material, give its exhibit, title, page, and line number, quote or set out the objectionable statement itself, and state the specific ground for objecting to it. The rule offers two acceptable layouts for presenting that information — one that lists each objection followed by its grounds, another that lays the material and grounds side by side in a table — and either satisfies the requirement.
The objecting party also has to submit a proposed order alongside the objections, built in a matching format, with blank lines for the judge to mark each objection sustained or overruled and to sign. That proposed order saves the court from drafting a ruling from scratch and gives the parties, and any reviewing court later, a clean record of exactly which pieces of evidence survived and which did not.
Frequently Asked Questions
When must written objections to summary judgment evidence be filed in California?
At the same time as the objecting party’s opposition or reply papers, unless the court excuses that timing on a showing of good cause, under Rule 3.1354(a).
What must each written objection to evidence include?
Under Rule 3.1354(b), the name of the document containing the material, its exhibit, title, page, and line number, the quoted material objected to, and the grounds for the objection.
Do I need to submit a proposed order with evidentiary objections in California?
Yes. Rule 3.1354(c) requires a proposed order in a matching format, with room for the judge to sustain or overrule each objection and sign.
Can I restate my evidentiary objections in the separate statement?
No. Rule 3.1354(b) requires objections to be referenced by number in the separate statement, not restated or reargued there.
Amendment History
Rule 3.1354 amended effective January 1, 2016; adopted as rule 345 effective January 1, 1984; previously amended and renumbered as rule 3.1354 effective January 1, 2007; previously amended effective January 1, 2002, and 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
Also known as: how to format evidentiary objections summary judgment Californiaproposed order objections to evidence CaliforniaCRC rule 3.1354 written objections