Clin. Cnty. Pa. 212.3.2

As amended through December 4, 2023
Rule 212.3.2 - Report of Counsel's Pre-Trial Conference
(A) Within ten (10) days of the completion of counsel's conference, plaintiff's counsel shall prepare a report thereof and submit the same to the assigned Judge and counsel. To the extent the report requires information and rules of law pertaining to defendant's case, it shall be the responsibility of defendant's counsel to provide plaintiff's counsel with such data. The report shall contain the following as applicable:
(1) A statement of the date and place where counsel's conference was held.
(2) A list of all prospective witnesses and accompanying data as required by Clinton R.C.P. No. 212.3.1(B)(1).
(3) A list of all exhibits which have been examined, numbered and listed in accordance with Clinton R.C.P. No. 212.3.1(B)(2). Each numbered exhibit shall be briefly but adequately identified on this list together with an indication is in dispute the objecting party's statement of reasons for the objection shall be included.
(4) The agreed upon brief statement of facts to be read to the jury for voir dire purposes together with each party's proposed questions for voir dire.
(5) Plaintiff's statement of the legal principles being relief upon to support the case together with an indication as to whether those principles are in dispute as well as a statement of the legal principles being relief upon by all other parties.
(6) A statement of damages as required by Clinton R.C.P. No. 212.3.1(B)(5).
(7) Any stipulation of fact which the parties have agreed upon for use at trial including any waivers of specific claims or defenses.
(8) Concise trial briefs regarding the anticipated legal issues to be presented at trial. When any portion of a trial brief relies upon an unreported opinion, photocopies of that opinion shall be attached to the briefs.
(9) A concise statement, in narrative form, from each party as to the basic facts intended to be proven at trial.
(10) Proposed special verdict questions which any party anticipates submitting at the time of trial.
(B) If any party disagrees with any representation made in plaintiff's report of counsel's conference, a written objection to said report shall be submitted to the assigned Judge within ten (10) days of the filing of plaintiff's report.

Clin. Cnty. Pa. 212.3.2