Northumberland Cnty. C.P. Rule NCV-212.2 Pre-Trial Memorandum Form

RULE NCV-212.2. PRE-TRIAL MEMORANDUM FORM

NORTHUMBERLAND COUNTY

PRE-TRIAL MEMORANDUM

CIVIL CASES

NOTE: The memorandum is to be submitted to the Court and to each party at least 5 (five) days prior

to the time of the scheduled pre-trial conference.

(CAPTION)

CASE NO. _________________________________________________

NAME OF PARTY ___________________________________________

NAME OF ATTORNEY ________________________________________

DATE & TIME OF PRE-TRIAL ___________________________________

1. List all parties and counsel to action.

2. A summarized version of facts.

3. Legal theory of liability – list those theories upon which you will rely, each party may be limited to

those theories at trial.

4. If there is a counterclaim, set forth the theory of liability.

5. Damages – give detailed description and itemized statement of damages.

6. Names of witnesses:

(a) Definite witnesses and scope of testimony (liability, damages or both).

(b) Possible witnesses and scope of testimony (liability, damages or both).

7. Expert witnesses – state expected scope of testimony.

8. Exhibits – list all exhibits and indicate whether or not they have been shown to opposing counsel.

Each party may be limited to the use of the listed exhibits at trial.

9. Scheduling – list any unusual scheduling problems which are anticipated. Civil trials are held in

February, June, September, and December.

10. Requested stipulations (qualification of experts, admissibility of documents, special damages, etc.)

11. Unusual legal issues – issues on which trial briefs should be required.

12. Has there been a timely demand for a jury trial? Yes________ No________

13. Estimated time to try the case.

14. Outstanding motions.

15. Settlement – your lowest demand or highest offer $_____________.

(party must be available in person or by phone at the time of pre-trial conference for purpose of

settlement discussions).

16. Miscellaneous – list any matter which you feel is important but which hasn’t been covered.

17. Pre-trial orders requested.

Respectfully submitted:

__________________________________

Counsel for: ________________________