Final Pre-Trial Letter Addressed To All Counsel Following Preliminary Conference

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HON. DEBORAH H. KARALUNAS FORM LETTER
Final pre-trial letter addressed to all counsel following Preliminary Conference
The trial in this matter is scheduled to begin on ___________. A final pre-trial
conference is scheduled for ______________ (approximately 10 days before the trial). The pre-
trial conference is to be attended by counsel and the parties, all of whom are expected to be fully
prepared to discuss the settlement of this matter.
Prior to the pre-trial conference, counsel for the parties shall pre-mark their exhibits and
consult in good faith to agree upon the exhibits that will be offered into evidence without
objection. Exhibits not previously demanded which are to be used solely for credibility or
rebuttal need not be pre-marked. In addition, counsel for the parties shall exchange a list of the
deposition testimony that will be offered into evidence and consult in good faith to agree upon
the portions of deposition testimony that will be offered into evidence without objection.
On or before _____________ (five days before the final pre-trial conference), each party
shall file with the Court and serve on opposing counsel:
1)
any motions in limine;
2)
a brief pre-trial memoranda (no more than two (2) pages in length);
3)
an indexed binder of trial exhibits. Plaintiff’s exhibits shall be marked with
numbers and defendant’s exhibits shall be marked with letters. The exhibit binder
shall include a list identifying the exhibits upon which agreement has been
reached and a separate list identifying all disputed exhibits;
4)
an indexed binder of all deposition testimony to be introduced at trial. The binder
shall include pertinent portions of the transcripts, a list identifying all deposition
testimony upon which agreement has been reached, and a separate list identifying
all deposition testimony to which objection is made including the basis for
objection;
5)
proposed jury charges including citations to the PJI or applicable case law;
6)
a proposed jury verdict sheet; and
7)
a list of witnesses including the estimated length of each witnesses’ testimony.
Your cooperation in this matter is appreciated.
Very truly yours,
Deborah H. Karalunas, J.S.C.

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