Columbia Cnty. C.P. Civil Local Rules 11

D. Clients shall be consulted by counsel in advance of the Pretrial Conference as to authority

with respect to settlement, including definite minimum or maximum limits of amounts of

authority, and respecting such other questions as may be reasonable and anticipated to be

relevant.

E. At trial, each party will be limited to those witnesses, exhibits and documents set forth in the

Pretrial Memorandum unless:

1. All parties affected by any change agree in writing, which shall be filed with the

Court;

2. Prompt notice of changes in the list of witnesses, exhibits or documents is made by

filing with the trial Judge and servicing other counsel with s Supplemental Pretrial

Memorandum;

F. At the conclusion of the Pretrial Conference, the Court may issue an Order deciding the

action taken. The Order may reflect any amendments to the pleadings allowed, agreements

between counsel, admissions of fact, notation of any exhibits which counsel stipulate may be

received in evidence without formal proof, the limitation on the number of expert witnesses and

other appropriate matters.

L.R. No. 212.5 MEDIATION

In all medical malpractice cases (and other cases deemed appropriate by the Court) in which a

Praecipe for Trial Listing has been filed, the Court Administrator, in its discretion, or at the

direction of the Court, may promptly refer the case to Mediation or a Settlement Conference

under the direction of the Court as follows:

1. Trial counsel must attend the Mediation or Settlement Conference. No substitute

counsel shall be permitted to attend in place of trial counsel.

2. Trial counsel must be authorized to discuss and conclude settlement at the Mediation

or Settlement Conference. The parties or their insurance representatives shall be available either

in person or by telephone if necessary to conclude settlement.

3. Notice of the date, time and place of the Mediation or Settlement Conference will be

sent to counsel by the Court.

4. At least seven (7) days prior to the Mediation or Settlement Conference, counsel shall

submit Pre-Conference Statements to the Court which shall contain all of the following:

a. A brief statement of the facts and events out of which the party’s claim or

counterclaim arose or upon which the party’s defense is based.

b. A brief summary of the known special damages the party has incurred to date,

if applicable.

c. A list of witnesses who will testify at trial.

d. An estimate of the trial time required.

e. A statement of unusual legal issues presented, including significant questions

of evidence.

f. A list of exhibits to be introduced at trial.

g. A statement of settlement negotiations to date, including the plaintiff’s most

recent demand and the defendant’s most recent offer.

h. Expert reports shall be attached to the Pre-Conference Statements.

L.R. No. 4005 DISCOVERY PRACTICE

Interrogatories to a party, as a matter of right, shall not exceed forty (40) in number.

Interrogatories inquiring as to the name and location of witnesses, or the existence, location and

custodian of documents or physical evidence shall be construed as one interrogatory. All other

interrogatories, including subdivisions of one number interrogatory, shall be construed as

separate interrogatories. If counsel for a party believes that more than 40 interrogatories are

necessary he shall consult with opposing counsel promptly and attempt to reach a written

Stipulation as to a reasonable number of additional interrogatories. Counsel are expected to

comply with this requirement in good faith. In the event a written Stipulation cannot be agreed

upon, the party seeking to submit additional interrogatories shall file a Motion with the Court

showing the necessity of relief.

L.R. No. 4007.1 PROCEDURE IN DEPOSITION BY ORAL EXAMINATION

A. A period of at least twenty (20) days is hereby determined by the Court to be “reasonable

notice” required by Pa.R.C.P. 4007.1(b).

B. In the scheduling of any deposition, the party noticing the deposition is required to make

reasonable efforts to first contact opposing counsel and agree upon a mutually convenient date,

time and place of deposition before issuing a notice of deposition.

L.R. No. 4011 OBJECTIONS TO DISCOVERY REQUEST

Any objection to an interrogatory, request for production of documents or request for admission

shall be served upon opposing counsel within thirty (30) days of service of said request. Failure

to service upon opposing counsel a timely objection in accordance with the provisions of this

Rule shall be deemed a waiver of objection to the interrogatory, request for production of

documents or request for admission. If no answers or objections to discovery requests have been

served, and if no written extensions of time for providing responses to discovery requests have

been granted, a Moving Party, pursuant to L.R. 26.3, may present a Motion to Compel Discovery

ex parte.

L.R. No. 4014 NUMBER OF REQUESTS FOR ADMISSIONS

Requests for admissions to a party, as a matter of right shall not exceed (40) in number. If

counsel for a party believes that more than (40) requests for admissions are necessary, counsel

shall consult with opposing counsel promptly and attempt to reach a written Stipulation as to a

reasonable number of additional requests for admissions. Counsel are expected to comply with

this requirement in good faith. In the event a written Stipulation cannot be agreed upon, the

party seeking to submit additional requests for admissions shall file a Motion with the Court

showing the necessity for relief.