As amended through February 1, 2024
Rule 212.2 - PRE-TRIAL CONFERENCE(a) Pre-trial conferences shall be mandatory in all contested civil actions listed for trial by jury, and shall be held in the chambers of the Judge for the purposes set forth in Pa.R.C.P. 212.(b) At least 1 week prior to the pre-trial conference, each of the parties shall submit a memorandum to the Court, with a copy to opposing counsel, containing: 1) A narrative statement of the facts which will be offered into evidence on behalf of that party.2) The names and addresses of all witnesses the party expects to call, classifying them as witness to liability, non-liability, damages, diminution of damages, or expert.3) A statement of the legal theory upon which the cause of action or defense is predicated, together with a complete citation of authorities relied on.4) A complete list of photographs, contracts, maps, models, records or other documents or things intended to be used for evidence at the time of trial.5) A written statement setting forth an itemized list of damages that any party intends to claim and prove at the time of trial.6) A written detailed statement of items of claim for which a defense is believed available and the method to be used for proving such defense items.7) A list of stipulations which opposing counsel reasonably can be expected to agree for purposes of avoiding need for proof.8) A history of negotiations to date.9) Where appropriate, a rough sketch illustrating the incident giving rise to the cause of action.10) Copies of reports received from expert listed as a witness.11) Such other matters as may be required by the Conference Judge.(c) The attorneys who will actively try the case shall attend the pre-trial conference. At the time of the pre-trial conference, the parties or their authorized representatives shall be present or immediately available by telephone at the time of the conference. If a party, by contract or otherwise, has relinquished the right to settle and to control the conduct of the case, the person with such authority must be present or immediately available by telephone at the time of the conference. Any failure to comply with the foregoing may result in the imposition of sanctions.(d) Failure to fully disclose in the pre-trial memorandum or the pre-trial conference the substance of the evidence as to liability, defenses, witnesses, exhibits, damages proposed to be offered at the trial, etc., may result in the exclusion of that evidence at the trial.(e) The Judge may, at his discretion:1) Require any party to file a supplemental memorandum, communicate to his client the recommendations of the Court or conduct additional negotiations.2) Require the parties to submit points for charge on or before a designated date.3) Schedule an additional pre-trial settlement conference.4) Certify the case as ready for trial.(f) Failure to file a pre-trial memorandum in accordance with these rules and/or failure to promptly attend the pre-trial conference may be deemed contempt of court and subject to such sanctions as the Court may impose.Amended effective 3/1/2021; revised 2/23/2022; amended effective 2/1/2024.