Northum. Cnty. Pa NCV-212(c)
NORTHUMBERLAND COUNTY
PRE-TRIAL MEMORANDUM
| (CAPTION) |
| CASE NO. _________________________________________________ |
| NAME OF PARTY ___________________________________________ |
| NAME OF ATTORNEY ________________________________________ |
| DATE & TIME OF PRE-TRIAL ___________________________________ |
1. List all parties and counsel to action.
2. A summarized version of facts.
3. Legal theory of liability - list those theories upon which you will rely, each party may be limited to those theories at trial.
4. If there is a counterclaim, set forth the theory of liability.
5. Damages - give detailed description and itemized statement of damages.
6. Names of witnesses:
(a) Definite witnesses and scope of testimony (liability, damages or both).
(b) Possible witnesses and scope of testimony (liability, damages or both).
7. Expert witnesses - state expected scope of testimony.
8. Exhibits - list all exhibits and indicate whether or not they have been shown to opposing counsel. Each party may be limited to the use of the listed exhibits at trial.
9. Scheduling - list any unusual scheduling problems which are anticipated. Civil trials are held in February, June, September, and December.
10. Requested stipulations (qualification of experts, admissibility of documents, special damages, etc.)
11. Unusual legal issues - issues on which trial briefs should be required.
12. Has there been a timely demand for a jury trial? Yes________ No________
13. Estimated time to try the case.
14. Outstanding motions.
15. Settlement - your lowest demand or highest offer $_____________. (party must be available in person or by phone at the time of pre-trial conference for purpose of settlement discussions).
16. Miscellaneous - list any matter which you feel is important but which hasn't been covered.
17. Pre-trial orders requested.
| Respectfully submitted: |
| __________________________________ |
| Counsel for: ________________________ |
Northum. Cnty. Pa NCV-212(c)