Statement shall be prepared by the attorneys and presented for discussion at the pretrial hearing, set in accordance with
the Docket Control Order, or other instructions from the Court.
For non-jury family law matters, the Pretrial Statement shall be
filed three business days prior to the bench trial setting date and a courtesy copy emailed or faxed to the Court's chambers.
The Pretrial Statement shall provide, by separate paragraph, the
1. Appearance of Counsel. List the
parties, their respective counsel and the address, telephone numbers, email address and fax numbers of counsel in separate
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.
a. Counsel will attach an Exhibit List as an annex to the Pretrial Statement. Counsel
will provide copies of the Exhibit List in check-off form, with copies for the Court, the Reporter and all opposing counsel.
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. To the extent that discovery has been completed, 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.
d. 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.
e. To the extent practicable, all exhibits will be offered and received in evidence as the first item of business at
trial, and outside the presence of the jury.
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
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
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.