Washington Cnty. C.P. Local Rules of Civil Procedure (Updated August 1, 2025) Rule 212.2

(a) Unless otherwise ordered by the Court, the deadline for the filing of a pre-trial statement

by a party shall be governed by Pa.R.C.P. 212.2. All pre-trial statements shall be filed with

the Prothonotary.

(b) In addition to the requirements of Pa.R.C.P. 212.2, a pre-trial statement shall contain

the following:

(1) a brief narrative statement of the facts and contentions as to liability;

(2) a listing of all exhibits available at the time of pre-trial which the party intends

to introduce at trial;

(3) a specific description of damages;

(4) any presently known motions in limine and any legal research, memorandum,

or brief in support thereof. Failure to include any motion in limine in the pre-trial

statement will not bar a future filing of the motion if it could not have been

anticipated at the time of filing the pre-trial statement or if, in the interest of justice,

the Court permits late filing;

(5) a summary of legal issues involved and applicable legal authorities relied upon;

(6) the settlement status of the case to include settlement offers and demands; and

(7) the reasons supporting the settlement posture set forth by the party.

(c) There shall be attached to the pre-trial statement:

(1) a copy of all reports containing findings or conclusions of any healthcare

provider who has treated or examined a party or has been consulted in connection

with any injuries complained of and whom a party expects to call as a witness at

the trial of the case. If timely production of any report is not made, the testimony

of such healthcare provider shall be excluded at the trial except upon consent of the

party or parties or upon express order of the Court;

(2) a copy of all reports containing findings and conclusions of any expert who has

been consulted in connection with the matters involved in the case and whom the

party expects to call at trial. If timely production of any such report is not made, the

testimony of such expert shall be excluded at the trial, except upon consent of the

party or parties or upon express order of Court; and

(3) the names and addresses of all witnesses the party expects to call at trial. The

witnesses shall be classified as liability or damage witnesses.

(d) Upon failure of any party to file a pre-trial statement within the time required, the Court

may impose the sanctions provided in Pa.R.C.P. 4019(c). The Court may order other

appropriate relief, including, but not limited to, the barring of testimony, assessment and

award of attorney fees, and expenses and costs to opposing counsel.

(e) Counsel shall file supplemental pre-trial statements up to the time of trial. Supplemental

statements shall include, but not be limited to, additional claims for damages, additional

liability witnesses, damage witnesses, expert witnesses, and/or exhibits intended to be used

at trial.