Uniform Pretrial Scheduling Order Virginia City Of Alexandria

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V I R G I N I A:
IN THE CIRCUIT COURT FOR THE CITY OF ALEXANDRIA
Plaintiff
v.
CASE NO.
Defendant
UNIFORM PRETRIAL SCHEDULING ORDER
It is ORDERED that:
I.
Trial
The trial date is
at 10:00 a.m. (with a jury) (without a jury).
The estimated length of trial is
.
Pretrial conference at 9:00 a.m. on
.
A pretrial conference is
mandatory for all cases scheduled for more than 2 days and all Equitable Distribution cases.
II. Discovery
The parties shall complete discovery, including depositions, by 30 days before trial; however,
depositions taken in lieu of live testimony at trial will be permitted until 15 days before trial. “Complete”
means that all interrogatories, requests for production, requests for admissions and other discovery must
be served sufficiently in advance of trial to allow a timely response at least 30 days before trial.
Depositions may be taken after the specified time period by agreement of counsel of record or for good
cause shown, provided however, that the taking of a deposition after the deadline established herein shall
not provide a basis for continuance of the trial date or the scheduling of motions inconsistent with the
normal procedures of the court. The parties have a duty to seasonably supplement and amend discovery
responses pursuant to Rule 4:1(e) of the Rules of Supreme Court of Virginia. Seasonably means as soon
as practical. No provision of this Order supersedes the Rules of Supreme Court of Virginia governing
discovery. Any discovery motion filed shall contain a certification that counsel has made a good faith
effort to resolve the matters set forth in the motion with opposing counsel.
III. Designation of Experts
If requested in discovery, plaintiff’s, counter-claimant’s, third party plaintiff’s and cross-claimant’s
experts shall be identified on or before 90 days before trial. If requested in discovery, defendant’s and all
other opposing experts shall be identified on or before 60 days before trial. If requested in discovery,
experts or opinions responsive to new matters raised in the opposing parties’ identification of experts
shall be designated no later than 45 days before trial. If requested, all information discoverable under
Rule 4:1(b)(4)(A)(1) of the Rules of Supreme Court of Virginia shall be provided or the expert will not
ordinarily be permitted to express any non-disclosed opinions at trial. The foregoing deadlines shall not
relieve a party of the obligation to respond to discovery requests within the time periods set forth in the
Rules of Supreme Court of Virginia, including, in particular, the duty to supplement or amend prior
responses pursuant to Rule 4:1(e).
IV. Dispositive Motions
All dispositive motions shall be presented to the court for hearing as far in advance of the trial date
as practical. All counsel of record are encouraged to bring on for hearing all demurrers, special pleas,
motions for summary judgment or other dispositive motions not more than 60 days after being filed.
V. Exhibit and Witness List
Counsel of record shall exchange 15 days before trial a list specifically identifying each exhibit to
be introduced at trial, copies of any exhibits not previously supplied in discovery, and a list of witnesses
proposed to be introduced at trial. The lists of exhibits and witnesses shall be filed with the Clerk of the
Court simultaneously therewith but the exhibits shall not then be filed. Any exhibit or witness not so
identified and filed will not be received in evidence, except in rebuttal or for impeachment or unless the
(over)

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