In addition to compliance with the Trial Preparation Order, a Pretrial Statement and a Pretrial Checklist shall be prepared by the attorneys, filed with the clerk and presented for discussion at the pretrial hearing date, set in accordance with the Docket Control Order, or other instructions from the Court. 

The Pretrial Statement shall be filed three business days prior to the pretrial conference setting date and a courtesy copy emailed or faxed to the Court's chambers. 

If a Pretrial conference is not scheduled, the Pretrial Statement with attachments and the Pretrial Checklist should be filed with the Clerk and a copy provided to the Court 10 days before trial. 

The Pretrial Statement shall provide, by separate paragraph, the following:

1. Appearance of Counsel: List the parties, their respective counsel and the address, telephone numbers, email address and fax numbers of counsel in separate sub-paragraphs.

2. Statement of the Case: Give a brief statement of the party’s case for the information of the Court. This is not an opportunity for advocacy. This paragraph simply states the causes of action or defenses of the parties.

3. Exhibits

  • a) Pursuant to the Trial Preparation Order, Counsel must provide an Exhibit List for opposing counsel, the Court Reporter, and the Court. Counsel will mark exhibits with appropriate stickers in the lower right-hand corner of the document, or on the lower right-hand back of the document. By agreement the parties may present a Joint Exhibit List. A “courtesy copy” of all Exhibits should be provided for the Court. 
  • b) Counsel requiring authentication of an opponent’s exhibit must notify opposing counsel of that requirement at least 10-days prior to the pretrial hearing, or within 5-days following receipt of the document, whichever is later. Failure to do so may result in an admission of authenticity.
  • c) Objections to admissibility of exhibits must be filed and presented for discussion at the pretrial hearing. Counsel will be prepared to argue the issue and provide supporting legal authorities.

4. Witnesses: Provide a list of the names of witnesses who will or may be called at trial. The Rules of Civil Procedure shall control the calling of witnesses not otherwise disclosed through discovery.

5. Trial Time Requirements: Provide an estimate of the time needed for voir dire, for opening argument and the probable length of trial. Please note that counsel’s estimate will not necessarily be followed by the Court. If witness availability is expected to be an issue, be prepared to discuss that at the pretrial hearing.

6. Motions in Limine: Motions in Limine will be filed prior to the pretrial hearing, with a copy to opposing counsel, and shall be heard at the pretrial hearing. Absent surprise or by leave of the Court, Motions in Limine will not be heard on the day the jury is called.

7. Charge of the Court: Counsel shall provide copies of proposed jury questions, together with any special instructions requested for the Jury Charge, at the pretrial hearing. 

8. Additional Requirements: At the pretrial hearing the Court may provide additional requirements depending on the nature of the case.