1) A copy of the operative pleadings
including complaint, answer, special defenses, if any,
counterclaims, if any, disclosure of experts, if any.
2) A brief, non argumentative
description of the facts of the case.
3) A list of issues which are not in
dispute.
4) A list of issues which are in
dispute.
5) A statement of the theories of
recovery and/or defense with respect to each issue with citation of
authorities.
6) A list of exhibits indexed by
number for plaintiff(s) and by letter for defendant(s). The list
shall briefly describe each exhibit and indicate whether any party
objects to the admission of such exhibit and the legal grounds for
the objection. All exhibits as to which there is no objection shall
be pre-marked as full exhibits. All other exhibits shall be marked
for identification. The parties shall endeavor to agree on all
redactions prior to trial. Counsel shall provide one another with
copies of all documentary exhibits prior to trial.
7) A list of all witnesses in the
order in which they are planned to be called, including the name and
relationship of each witness to the case (e.g. party, eye witness,
treating physician, expert) and a brief summary of the witness'
testimony.
8) Requested jury instructions.
9) A description of all pending or
impending motions that could dispose of part or all of the issues in
the case.
10) A description of all pending or
impending motions to seal, if any.
11) A stipulation with respect to
facts not genuinely in dispute.
12) Identification of all anticipated
evidentiary disputes.
13) Draft special interrogatories and
special verdict forms if appropriate.
14) A statement of the law of damages
that applies with citations.
15) All motions in limine are to be
filed two weeks before commencement of jury selection and objections
one week before. (copies to caseflow)
