Washington Cnty. C.P. Local Rules of Civil Procedure (Updated August 1, 2025) Rule 212.1

(a) Purpose. In any civil action in which the damages sought exceed the jurisdictional limit

for compulsory arbitration and which is to be tried by a judge or a jury, the Court may order

the attorneys and any unrepresented parties to appear for one or more pre-trial conferences

for such purposes as:

(1) expediting disposition of the case;

(2) establishing early and continuing control so that the case will not be protracted

because of lack of management;

(3) discouraging wasteful pre-trial activities;

(4) improving the quality of trial through more preparation; and

(5) facilitating settlement.

(b) Unless otherwise ordered by the Court, there shall be a minimum of three (3) court

conferences in every civil action in which the damages sought exceed the jurisdictional

limit for compulsory arbitration and which is to be tried by a jury: an initial case

management conference; a status conference; and a pre-trial conference.

(c) Initial Case Management Conference. As soon as practical, but no later than thirty (30)

days after the service of a complaint, the Court shall enter an order setting forth the date

and time of an initial scheduling conference.

(1) Unless the Court finds good cause for delay, the initial scheduling conference

shall be held within the earlier of ninety (90) days after service of the complaint or

sixty (60) days after any defendant has appeared. The Court may defer the initial

scheduling conference if a motion that would dispose of all of the claims within the

complaint is pending.

(2) Following the conclusion of the conference, the Court shall issue an order

setting forth dates for the following:

(a) the completion of expert and fact discovery;

(b) the date(s) in which to file dispositive motions at an early stage

of the proceedings; and

(c) the date of the status conference.

(3) In the order issued after the case management conference, the Court may

address any other topic it deems necessary to the serve the purposes of this rule,

including the designation, if appropriate, of the case for arbitration, mediation,

appointment of a special master, or other special procedure.

(4) Prior to filing a motion to modify any case management order, all counsel, or a

party if unrepresented, shall confer in an effort to reach agreement on the proposed

modification.

(5) Nothing in this rule shall be read to expand or otherwise enlarge the time for

filing a pleading as set forth in Pa.R.C.P. 1026 or 1042.4.

(d) Status Conference. A represented party must authorize at least one of its attorneys to

make stipulations and admissions about all matters that can reasonably be anticipated for

discussion at a status conference. If appropriate, the Court may require attendance by a

party or its representative or any other individual deemed necessary to the litigation, or the

reasonable availability by other means to consider possible settlement. For the purposes of

this rule, the term “representative” shall include an insurance or similar representative with

full authority to negotiate or settle the case as in accordance with Pa.R.C.P. 212.5(b)(2).

(1) At the conclusion of discovery, the Court shall hold a conference to review the

status of the case, including:

(a) any outstanding issues concerning discovery;

(b) disposing of pending motions;

(c) settling the case and using special procedures to assist in

resolving the dispute when authorized by statute or rule of court;

(d) setting forth a date for the filing of a motion of summary

judgment pursuant to Pa.R.C.P. 1035.2, and issuing a briefing

schedule; and

(e) setting forth a date for the scheduling of a pre-trial conference.

(e) Pre-trial Conference.

(1) All trial counsel shall attend the pre-trial conference. If counsel is not present

for the pre-trial conference, the Court may bar their participation at trial.

(2) A party and its representative, or any other person deemed necessary to the

litigation by the Court, shall be present in person at the pre-trial conference;

telephonic or remote participation shall not be permitted absent prior approval by

the Court for good cause. For the purposes of this rule, the term “representative”

shall include an insurance or similar representative with full authority to negotiate

or settle the case as in accordance with Pa.R.C.P. 212.5(b)(2).

(3) At any pre-trial conference, the Court may consider and take appropriate action

on the following matters:

(a) formulating and simplifying the issues, and eliminating frivolous

claims or defenses;

(b) obtaining admissions and stipulations from the parties, and

ruling in advance on the admissibility of evidence;

(c) settling the case and using special procedures to assist in

resolving the dispute when authorized by statute or rule of court;

(d) disposing of pending motions;

(e) setting forth deadlines for the filing of pre-trial statements and/or

briefs by the parties;

(f) setting forth deadlines for the filing of motions in limine,

proposed voir dire questions and interrogatories, and proposed jury

instructions;

(g) setting a date for trial; and

(h) determining the form and content of the pre-trial order.

(4) The Court may hold a final pre-trial conference to develop a trial plan, including

a plan to limit testimony or facilitate the admission of evidence. The conference

shall be held as close to the start of trial as is reasonable, and shall be attended by

trial counsel and any unrepresented party.

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

or sanctions, including the imposition of reasonable expenses, including attorney’s fees, if

a party or its attorney:

(1) fails to appear at an initial case management conference, a status conference, or

a pre-trial conference;

(2) is substantially unprepared to participate, or does not participate in good faith;

or

(3) fails to obey an order issued pursuant to this rule.

Note: 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.

(g) Continuances. When a case is scheduled for a conference pursuant to this rule, it shall

not be continued except for good cause shown.