Pretrial Procedure

Attorneys and pro se litigants shall consult the pretrial practices and procedures of the judge to whom their case is assigned. In every case scheduled for trial, as a minimum requirement, counsel must file a pre-trial memorandum that sets forth a factual summary of the case, the parties’ respective claims and defenses, the relief sought, and a list of witnesses and exhibits to be used or introduced into evidence. Failure to do so can result in the imposition of sanctions, including the preclusion of witnesses or evidence. In a jury trial, counsel must submit proposed instructions no later than the commencement of trial, unless otherwise ordered by the court, and failure to do so can constitute waiver of a claim, defense, or legal position.