Venango Cnty. C.P. Local Rules on Civil Procedure Rule 212.1

This rule shall apply to all civil actions, both jury and non-jury, with the exception of custody

matters, appeals from compulsory arbitration, actions in divorce, and other issues permitted by

law relating to the termination or validity of marriages.

(a) Case Tracks and Case Events: Upon the filing of a civil action, the District Court

Administrator shall assign a Judge to the case. Within four months of filing a case, the

Court will issue a Case Management Order providing notice of the earliest date the case

may be tried, pursuant to Pa.R.C.P. 212.1. The Order will set forth a Case Track and

(b) establish timelines for Case Events, in accordance with the following schedules:

MANAGEMENT DISPOSITION

CASE TYPE

TRACK WITHIN

 Cases involving damages of less than $50,000

 Landlord/Tenant actions and appeals

 Residential Assessment appeals

 Contract

 Debt Collection Fast 12 Months

 Employment Dispute

 Replevin

 Mechanic’s Lien

 Tax/Judicial sale petitions

 Cases involving damages in excess of $50,000

 Actions to Quiet Title

 Ejectment (other than residential lease)

 Ejectment/Eminent Domain/Condemnation

 Declaratory Judgment

 Mortgage Foreclosure Standard 18 Months

 Commercial assessment appeals

 Partition

 Right to Know

 Tort

 Civil appeals/Administrative Agencies

 Class Action

 Medical/Professional Liability

 Product Liability

 Mass Tort: Asbestos, Tobacco

Complex 24 months

 Toxic Tort/Waste

 Personal Injury

 Injunctions

 Actions in Equity

Any case type not listed will be allocated to a Case Track by the Court in its own discretion.

FAST STANDARD COMPLEX

CASE EVENT

TRACK TRACK TRACK

Case Management

4 Months after 4 Months after 4 Months after

Conference/

the date of filing the date of filing the date of filing

Management Order

Discovery Complete;

6 Months 9 Months 12 Months

Motion to Compel Filed

Plaintiff Expert Reports 6 Months 9 Months 16 Months

Defense Expert Reports 8 Months 12 Months 18 Months

Dispositive Motions 8 Months 12 Months 18 Months

Praecipe for Arbitration

9 Months

Filed

Pre-Trial Statement Due 60 days prior to trial 60 days prior to trial

Pre-Trial Conference 14 Months 18 Months

within 18 months of within 24 months of

Trial Date

filing filing

(1) The case track and/or deadlines established by the case management order may be

modified by the Court in its own discretion or for good cause shown. A party seeking

modification shall seek the written concurrence of all parties and make the request for

modification by written motion.

(2) Pursuant to Local Rule 2, arbitration is compulsory for all cases where the amount in

controversy is fifty thousand dollars ($50,000.00) or less, except those involving the

title to real property. Cases involving more than fifty thousand dollars ($50,000.00) may

be heard by the Arbitration Board upon agreement. See 42 Pa. C.S.A. §§ 7361-7362.

(c) Case Management, Status, and Pre-Trial Conferences:

(1) Trial counsel shall attend all case management, status, and pre-trial conferences. If

counsel is not present for these conferences, the Court may sanction as it deems

appropriate. Attendance at scheduled conferences shall be in person unless

appearance by remote means is approved by the Court prior to the hearing or

conference.

(2) A Motion to the Court to participate in the conferences via telephone or

videoconference must be submitted no later than seven (7) days prior to the pre-trial

conference date, which the Court may grant in its discretion. The party requesting

remote appearance is responsible for coordinating the appearance with the Court

Administrator. All arrangements shall be made by counsel.

(3) Counsel attending any conference shall have full authority to settle the case, schedule

all hearings and trial, and make stipulations and admissions where appropriate. The

Court may require attendance of a party, its representative, or any other individual

deemed necessary to the litigation, or require other reasonable availability to

consider settlement.

(d) Pre-Trial Statements:

(1) Pre-Trial Statements shall be filed no later than seven (7) days before the pre-trial conference

and shall contain:

(i) Name of client, name and telephone number of the attorney who will try the case;

(ii) In jury cases, the demand and offer of settlement which shall be binding upon the

parties for purposes of Pa.R.C.P. 212.1(b), unless otherwise scheduled by the Court;

(iii) The name and coverage limits of any insurance carrier;

(iv) The names and addresses of all witnesses to be called at trial with a description of

their purpose, e.g. liability, damages, etc.;

(v) A list of exhibits to be introduced at trial. Counsel shall certify in the pre-trial

memorandum that all exhibits were furnished to opposing counsel;

(vi) A list of voir dire questions;

(vii) A statement of damages with a detailed analysis of the claim, including the manner

of calculating damages;

(viii) The estimated length of trial time necessary for counsel to present a party’s evidence;

(ix) A statement of the status of discovery, which shall include whether any further

discovery is required and a proposed schedule for completing discovery;

(x) A statement of the status of the scheduling of an independent medical examination;

(xi) A statement of the status of any depositions for use at trial;

(xii) A statement of novel questions of law, including whether any motions in limine will

be filed; Motions in limine must be in writing and shall be filed with the

Prothonotary no later than the pre-trial conference. The trial judge will schedule

opposing party responses and argument as required;

(2) At trial, the parties will be limited to those witnesses and exhibits disclosed in the

pre-trial memoranda, unless opposing counsel waives such restrictions or the

Court finds such a limitation to be unjust. If a party has indicated a witness will

be called, three (3) days’ notice shall be given to opposing counsel if the witness

will not be called for any reason.

(3) Pre-trial Statements shall be filed with the office of the Prothonotary/Clerk of

Courts.

(e) Sanctions:

(1) Upon motion of a party, or sua sponte, the Court may issue any just orders or

sanctions, included but not limited to precluding witness testimony evidence, the

imposition of reasonable expenses and/or attorney’s fees, if a party or its

attorney:

(i) Fails to appear at an initial case management conference, a status

conference, or a pre-trial conference;

(ii) Is substantially unprepared to participate, or does not participate in good

faith; or

(iii) Fails to obey an order issued by the Court.

(2) Unrepresented parties are subject to the same obligations as those imposed upon

attorneys representing a party. This includes sufficient knowledge of the

claim(s) asserted, potential defenses, damages and/or other relief sought, and

legal issues raised in the pleadings.

(3) Failure of any party or attorney to appear for any scheduled conference or to

comply with the requirements set forth in this Rule may result in dismissal of the

case or other sanctions.