Tioga Cnty. C.P. Civil Rules of Court Rule TC 212.1

_____________________________ : IN THE COURT OF COMMON PLEAS

v: OF TIOGA COUNTY, PENNSYLVANIA

_____________________________ : NO. _____ CIVIL DIVISION 20_____

PRAECIPE FOR TRIAL

AND NOW, ______________________, 20____ comes the

___________________ by his/her counsel, ___________________, Esq. and requests the

Court to schedule the above captioned matter for trial. In support thereof, the

_______________ makes the following statements.

(1) That a complaint was filed on _____ day of _______, 20____.

(2) That all pleadings are closed and all discovery has been completed,

including depositions.

(3) That all attorneys of record or unrepresented parties (agree/disagree) that

the matter is ready for trial. (If all parties do not agree, identify those parties and note

their objections).

WHEREFORE, _____________ requests the Court to schedule the matter for

trial.

Rule TC - 212.2. Pre-Trial Memorandum Form.

_____________________________ : IN THE COURT OF COMMON PLEAS

v. : OF TIOGA COUNTY, PENNSYLVANIA

_____________________________ : NO. _____ CIVIL DIVISION 20_____

PRE-TRIAL MEMORANDUM

(Representing Plaintiff/Counterclaimant)

1. A Brief statement of the factual situation or a reference to the pleadings.

2. An itemized list of all specials, including loss of wages.

3. The amount being demanded, payment of which would result in settlement. This

demand to be broken down to reflect the specific amounts being demanded for specials,

pain and suffering, permanent injury, loss or consortium, etc.

(Representing Defendant/Plaintiff as Additional Defendant)

1. Paragraphs in plaintiff’s complaint which will be admitted at trial without requirement

of proof.

2. The defense to be presented to plaintiff’s claim.

3. The offer being made which, if accepted, would result in settlement.

(Both Plaintiff & Defendant)

4. The names and addresses of all witnesses to be called, including a designation as to

whether the witness will testify to liability or damages.

5. A list of exhibits to be offered, including a brief description of each.

6. A summary of expected expert testimony if the expert will testify in person and a copy

of expert’s report.

7. Legal issues or questions which will likely require ruling by the Court, together with

any citations which will support rulings to be requested.

8. Estimated time for trial of the case.

9. Any legal or factual issues to which the parties will stipulate.

10. A copy of any plan or plot to be introduced into evidence. In negligence cases, there

shall be drawing or plot of the accident submitted at the pre-trial conference.

In addition, all attorneys shall be accompanied by or have direct access to their

respective parties or representatives who have the authority to agree upon a settlement or

the attorney shall have such authority.