Berk. Cnty. Pa. 212.2

As amended through May 6, 2024
Rule 212.2 - Memorandum
(a) Counsel for each party or a party without counsel shall file a pretrial conference memorandum with the prothonotary at least seven (7) calendar days prior to the date of the scheduled pretrial conference along with a proof of service of a copy of the memorandum upon counsel of record or a party without counsel. Service shall be made by personal service or by registered, certified or first-class mail addressed to the last address of such counsel or party as listed with the prothonotary. Proof of service shall consist of a verified statement, as verified is defined in Pa.R.C.P. 76.
(b) Each party's pretrial conference memorandum shall contain the following information where applicable:
(1) Summary Statement of Facts.
(2) Amendments to Pleadings.
(3) Admissions in Pleadings.
(4) Admissions in Discovery by:
(i) Requests for Admission.
(ii) Answers to Interrogatories.
(iii) Oral Depositions of a Party.
(5) Itemized Special Damages.
(6) General Unliquidated Damages.
(7) Stipulations Desired.
(8) Objections to Depositions Taken Specifically For Use at Trial.
(9) Witnesses Expected to be Called.
(10) Exhibits Expected to be Offered Into Evidence.
(11) Legal Issues Anticipated.
(12) Special Problems.

Berk. Cnty. Pa. 212.2

Amended effective 2/12/2018 ; amended effective 7/9/2019; amended effective 3/14/2020.