FJDCR 4.5

(a) Evidentiary hearing and trial statements required without order. Before any evidentiary hearing or trial, except in criminal or juvenile cases, the parties will file a hearing or trial statement, or if ordered, a joint hearing or trial statement. Joint trial statements will include an initial paragraph certifying that the parties have conferred in good faith on all of the information presented in the joint hearing or trial statement. Joint and individual hearing trial statements will include the following headings in numerical order with the required information immediately following the heading:

(1) A brief statement of the facts of the case.

(2) A list of admitted and/or undisputed facts.

(3) A list of disputed facts.

(4) A list of all claims for relief designated by reference to each claim or paragraph of a pleading, a description of the claimant’s theory of recovery with each category of damage requested, and the specific relief requested.

(5) A list of affirmative defenses.

(6) A list of all claims or defenses to be abandoned.

(7) A line-item list of all exhibits, including exhibits that may be used for impeachment. The list will include the identity of the party offering each exhibit, a description of the exhibit, and a specification of any objection(s) a non-offering party has to the admissibility of the exhibit. If no objection is stated, any objection to admissibility is waived.

(8) Any agreements as to the limitation or exclusion of evidence.

(9) A list of the witnesses (including experts), and the address of each witness whom each party intends to call. Failure to list a witness, including impeachment witnesses, may result in the court’s precluding the party from calling that witness.

(10) A statement of the legal issues and for each issue the position of each party, with citations to and a summary of the applicable law.

(11) Any other matter that the attorney or self-represented party desires to bring to the attention of the court prior to trial.

(b) Failure to timely disclose. The court may prohibit a party from presenting any evidence, law, or argument that was not timely disclosed as required under this rule.