Civil Practice Guidelines

Meet and Confer Instructions

Trial counsel and self-represented parties shall confer on the following matters no later than the Meet and Confer Deadline in the case schedule:
  • Counsel shall exchange complete, pre-marked sets of all trial exhibits (and eliminate duplicate exhibits or re-mark them as Joint Exhibits);
  • Discuss stipulations of authenticity of documents, background dates, and other facts that can be jointly submitted to eliminate redundancy or delay;
  • Identify their proposed order of calling witnesses and address any anticipated scheduling issues;
  • Exchange, or at least discuss, any proposed demonstrative exhibits or summaries of evidence under consideration; 
  • Jointly prepare proposed jury instructions and interrogatories to provide for the court at the pre-trial conference;
  • Identify any disagreements over demonstrative evidence, summaries, the jury charge, interrogatories, and potential motions in limine for the court’s consideration.
Absent extraordinarily good cause, no Exhibit may be used at trial that is not pre-marked and exchanged at the pre-trial meeting of counsel; and no demonstrative exhibit or summary may be shown in opening statement unless disclosed to opposing counsel at the pre-trial meeting.

Any requested jury interrogatories should be subject to simple “yes” or “no” answers.  

Counsel shall provide the court at the Final Pre-trial Conference with proposed jury instructions; any proposed jury interrogatories; and final Exhibit and witness lists. Any disagreements identified by counsel as described above must be raised at the Final Pre-trial Conference or risk being deemed waived.