Chester Cnty. C.P. Court of Common Pleas Standard Operating Procedures L

1. Detailed findings of fact are very helpful in civil non-jury trials

and are highly encouraged. Individual judges may request that they be e-mailed to

the judge’s secretary in an appropriate format.

2. In civil cases, counsel should exchange their lists of experts and

the substance of their testimony prior to the beginning of trial or risk having such

expert(s) barred from giving testimony. See C.C.R.C.P. 212.1. Prepare your

expert examination, including questions intended to establish a proper factual

foundation. Experts should be specifically asked if they hold their opinion to a

reasonable degree of certainty within their field of expertise.

3. During jury deliberations, counsel shall let the tipstaff on duty

know where they are, and shall be available, with their clients, to return to the

court on five (5) minutes' notice.

4. From the time the jury is selected until it is discharged, counsel

shall avoid all forms of contact with the individual jurors, and shall advise their

parties and witnesses to do the same.

5. Do not copy the judge on correspondence between counsel. If

there is a discovery dispute, the judge will only entertain a formal motion.

6. Judicial admissions, pleading averments, requests for

admissions of parties, etc., can be very useful to the presentation of a case.

However, they are not part of the evidence unless moved into evidence and

admitted as such.

7. If use of a pre-recorded media e.g. CD, DVD, videotape, is

planned for use in court, please prepare to use such media at the starting point and

review any objections made on the media with the court ahead of time. Such

media shown to juries must be edited to delete inadmissible testimony and

unnecessary questions or statements by counsel. Counsel is expected to effectuate

their own media presentation. Where use of the court’s electronic equipment or

services is requested, arrangements must be made with the Department of

Computer and Information Services at least forty-eight (48) hours in advance of

the hearing/trial date.

8. Although jury views are not encouraged, they may be done with

advance arrangements by counsel with the court. Highly detailed photographs are

preferred and can prove just as informative.