Penn. TC- 212.2
______________ | : IN THE COURT OF COMMON PLEAS |
v. | : OF TIOGA COUNTY, PENNSYLVANIA |
______________ | : NO. _____ CIVIL DIVISION 20 _____ |
PRE-TRIAL MEMORANDUM
(Representing Plaintiff/Counterclaimant)
1. A Brief statement of the factual situation or a reference to the pleadings.
2. An itemized list of all specials, including loss of wages.
3. The amount being demanded, payment of which would result in settlement. This demand to be broken down to reflect the specific amounts being demanded for specials, pain and suffering, permanent injury, loss or consortium, etc.
(Representing Defendant/Plaintiff as Additional Defendant)
1. Paragraphs in plaintiff's complaint which will be admitted at trial without requirement of proof.
2. The defense to be presented to plaintiff's claim.
3. The offer being made which, if accepted, would result in settlement. (Both Plaintiff & Defendant)
4. The names and addresses of all witnesses to be called, including a designation as to whether the witness will testify to liability or damages.
5. A list of exhibits to be offered, including a brief description of each.
6. A summary of expected expert testimony if the expert will testify in person and a copy of expert's report.
7. Legal issues or questions which will likely require ruling by the Court, together with any citations which will support rulings to be requested.
8. Estimated time for trial of the case.
9. Any legal or factual issues to which the parties will stipulate.
10. A copy of any plan or plot to be introduced into evidence. In negligence cases, there shall be drawing or plot of the accident submitted at the pre-trial conference.
In addition, all attorneys shall be accompanied by or have direct access to their respective parties or representatives who have the authority to agree upon a settlement or the attorney shall have such authority.
Penn. TC- 212.2