Ind. Marion Cnty. Civ. Local Rule LR49-TR16-208

A. Pre-trial Conference Mandatory. A pre-trial conference shall be held in every civil

jury action. Each party shall be represented at the pre-trial conference by the attorney who will

conduct the trial.

B. Pre-trial Stipulation Must Be Filed. Counsel for the plaintiff shall see that a pre-trial

stipulation is prepared, executed by counsel for all parties, and filed with the Court no later than

five days prior to the pre-trial conference. The pre-trial stipulation shall contain the following

statements in separate numbered paragraphs as indicated:

1. the nature of the action.

2. the basis of jurisdiction.

3. the pleadings raising the issues.

4. a list of all motions or other matters requiring action by the Court.

5. a concise statement of stipulated facts, with reservations, if any.

6. a statement of issues of fact which remain to be litigated at trial.

7. a concise statement of issues of law on which there is agreement.

8. a concise statement of issues of law which remain for determination by the Court.

9. each party’s numbered list of trial exhibits, other than impeachment exhibits, with

objections, if any, to each exhibit. The list of exhibits shall be on separate schedules

attached to the stipulation.

10. each party’s numbered list of trial witnesses, with their addresses. Impeachment

witnesses need not be listed. Expert witnesses shall be so designated.

11. estimated trial time.

C. Unilateral Filing of Pre-trial Stipulation Where Counsel Do Not Agree. If for any

reason the pre-trial stipulation is not executed by all counsel, each counsel shall file a proposed

pre-trial stipulation not later than five days prior to the pre-trial conference with a statement why

no agreement was reached.

D. Memoranda of Law. Counsel shall file memoranda treating any unusual questions of

law involved in the trial no later than five days prior to the pre-trial conference.

E. Proposed Jury Instructions. Seven days prior to trial, counsel shall submit proposed

jury instructions to the Court, with copies to all other counsel. Instructions covering matters

occurring at the trial which could not reasonably be anticipated may be substituted at the

conclusion of the testimony. Each instruction shall be accompanied by citations of authority.

F. Objections to Proposed Jury Instructions. Written objections to proposed jury

instructions shall be submitted to the Court on or before the first day of trial. Written objections

shall be numbered and shall specify distinctly the objectionable matter in the proposed

instruction. Each objection shall be accompanied by citations of authority.