From a different Court ..with a Jury trial..Joint Pretrial Order, and Subject matter...
In the event the Joint Final Pretrial Order is to be delivered to the court at the FinalPretrial Conference, the Order will be reviewed by the Magistrate Judge at the conference and entered upon the record. Another purpose of the Final Pretrial Conference is to attempt to settle the action. For that reason, at that conference, each party must be represented by an attorney who is vested with full settlement authority. Clients are to be either present or on call so that any settlement proposals made at the conference can be immediately conveyed.Sanctions may be imposed for the unexcused failure of counsel to cooperate in submitting the Joint Final Pretrial Order when due, or for failing to obey a Scheduling Order or Discovery Order. See Rules 16(f) and 37(b)(2) and (g), Federal Rules of Civil Procedure.Once the Joint Final Pretrial Order is entered upon the record, it shall only be modified in exceptional circumstances “to prevent manifest injustice.” Fed. R. Civ. P. 16(e). All requests to
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3 amend the Joint Final Pretrial Order shall be made by formal motion.4.FINAL PRETRIAL CONFERENCEThe date of the Final Pretrial Conference will be set forth in the Scheduling Order and shall be held in accordance with Fed. R. Civ. P. 16(d). If a summary judgment or other dispositive motion is pending before the District Judge at the time of the Final Pretrial Conference, the conference may be postponed until such time as the motion is resolved. In such circumstances, counsel shall inform the Magistrate Judge of such pending motion in advance of the scheduled Final Pretrial Conference date.5.SETTLEMENT CONFERENCES Settlement conferences will be held prior to the submission of the Joint Final Pretrial Order upon the request of any counsel or upon Order of the court.6.TRIAL DATE and PRETRIAL SUBMISSIONS TO THE COURT The trial date set forth by the court is firm. Any application concerning the trial date should be directed to the District Judge assigned to the action.Counsel are advised that the failure to submit trial briefs, voir dire questions, and requests to charge or proposed findings of fact and conclusions of law when required is a serious matter which will be dealt with by the District Judge.
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4IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OFNEW JERSEYCAMDEN VICINAGEHONORABLE ____________________(Plaintiffs)::Civil No. ____________v.::(Indicate Jury or Non-Jury)(Defendants):JOINT FINAL PRETRIAL ORDERThe following shall constitute the Final Pretrial Order pursuant to Rule 16, Federal Rulesof Civil Procedure. This Final Pretrial Order shall govern the conduct of the trial of this case. Amendments to this Order will be allowed only in exceptional circumstances to prevent manifestinjustice. See Fed. R. Civ. P. 16(e). Counsel are urged to move to amend in a timely fashion anyportion of the Order that must be changed or modified between the filing of the Order and thetrial date.APPEARANCES:PART I.JURISDICTION and BRIEFSUMMARY OF THE CASE:Counsel shall specifically set forth the jurisdictional basis of this action as well asa brief summaryof the claims and defenses.PART II.STIPULATED FACTS:Stipulated facts shall be set forth in numbered paragraphs.
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5PART III.EACH PLAINTIFF’S CONTESTED FACTS:1. Plaintiff intends to prove the following contested facts with regard to liability:2. Plaintiff intends to prove the following contested facts with regard to damages:PART IV:EACH DEFENDANT’S CONTESTED FACTS:1. Defendant intends to prove the following contested facts with regard to liability:2. Defendant intends to prove the following contested facts with regard to damages:PART V:WITNESSES and SUMMARY OF TESTIMONY:Only the witnesses whose names and addresses are listed herein will be permitted to testify at the time of trial. For each witness listed, there must be a description of their testimony. Any objection to a witness must be noted by opposing counsel and for each such witness objected to, the name of the witness and the reason for the objection shall be given.A.Plaintiff’s Witnesses and Summary of Their Testimony1.Plaintiff intends to call the following witnesses with regard to liability and anticipates they will testify as follows:2.Plaintiff intends to call the following witnesses with regard to damages and anticipates they will testify as follows:B.Defendant’s Objections to Plaintiff’s Witnesses: If there are no objections to any of the witnesses, defendant shall so state that in this portion of the Order. If there are objections to any of plaintiff’s witnesses, they shall be listed here.
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6C.Defendant’s Witnesses and Summary of Their Testimony1.Defendant intends to call the following witnesses with regard to liability and anticipates they will testify as follows:2.Defendant intends to call the following witnesses with regard to damages and anticipates they will testify as follows:D.Plaintiff’s Objections to Defendant’s Witnesses: If there are no objections to any of the witnesses, plaintiff shall so state that in this portion of theOrder. If there are objections to any of defendant’s witnesses, theys hall be listed here.PART VI.EXPERT WITNESSES:Any prior Scheduling Order of the court concerning experts is applicable to this action and the directives of the Scheduling Order shall govern expert testimony in this case. Any expert not listed in this portion of the Final Pretrial Order shall not be permitted to testify at the time of trial. Additionally, the curriculum vitae of every expert expected to testify at the time of trial shall be attached to this Final Pretrial Order. The curriculum vitae or summary of the expert’s qualifications may be read into the record at the time the expert takes the stand, and no opposing counsel shall be permitted to question the qualifications of the expert unless the basis of the objection is set forth in this Final Pretrial Order. No expert will be permitted to testify at trial unless all opposing counsel have received the curriculum vitae of the expert and the information required by Fed. R. Civ. P. 26(a)(2) as directed in the Scheduling Order.If any hypothetical questions are to be put to an expert witness on direct examination, they shall be written in advance and submitted to the court and counsel prior to commencement of trial.1.Plaintiff’s expert witnesses are:2.Defendant’s objection to the qualifications of plaintiff’s expert witnesses are: (The objections shall be referenced to the name of each listed expert.)3.Defendant’s expert witnesses are:4.Plaintiff’s objection to the qualifications of plaintiff’s expert witnesses are: (The objections shall be referenced to the name of each listed expert.).
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7PART VII. EXHIBITSIn this section of the Final Pretrial Order, counsel should number each proposed exhibit and upon receipt of the exhibit list of an adversary, opposing counsel should prepare a response to this exhibit list indicating as to each exhibit whether there will be an objection and if there is, the nature of the objection. Absent an extraordinary showing of good cause, ONLY THE EXHIBITS LISTED BELOW SHALL BE INTRODUCED AT THE TIME OF TRIAL. You are not required to list exhibits that will be used, if at all, only for impeachment purposes.Counsel are reminded that each such exhibit shall be physically pre-marked corresponding to the designation below. Copies of exhibit lists shall be provided to the District Judge and the assigned court reporter at the time of trial.A.Plaintiff’s Exhibits1.Plaintiff intends to introduce the following exhibits into evidence (list bynumbers with a description of each exhibit);2.Defendant objects to the introduction of plaintiff’s exhibit (set forthnumber of exhibit and grounds for objection).B.Defendant’s Exhibits1.Defendant intends to introduce the following exhibits into evidence (list bynumber with a description of each exhibit);2.Plaintiff objects to the introduction of defendant’s exhibit (set forthnumber of exhibit and grounds for objection).PART VIII. LAWB.Plaintiff1.Plaintiff’s statement of the legal issues in this case:C.Defendant2.Defendant’s statement of the legal issues in this case.
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8PART IX.MISCELLANEOUSSet forth any additional stipulations of counsel and/or motions on other matterswhich require action of the court.Set forth any notice required to be given under Rules 404(b), 609(b), 803(24) and804(b)(5), Federal Rules of Evidence.PART X.NON-JURY TRIALS (If Applicable)No later than seven days prior to the scheduled trial date, counsel for each party shall submit to the District Judge, with a copy to opposing counsel, proposed findings of fact and conclusions of law. There is reserved to counsel the right to submit additional requests during the course of the trial on those matters that cannot reasonably be anticipated. PART XI.JURY TRIALS (If Applicable)No later than seven days prior to the scheduled trial date or at such time as the court may direct:1.Each party shall submit to the District Judge and to opposing counsel a trial brief or memorandum with citations and authorities and arguments in support of the party’s position on all issues of law.2.Each party shall submit to the District Judge and to opposing counsel written requests for charges to the jury. Supplemental requests to charge that could not have been anticipated may be submitted any time prior to the arguments to thejury. All requests for charge shall be on a separate page or pages plainly marked with the name and number of the case; shall contain citations of supporting authorities; shall designate the party submitting the same; and shall be numbered in sequence.IF you have the capability, the Proposed Requests for Charge should be submitted on computer disk, Word Perfect format. Apaper original for filing, as well as a paper copy, must be providedin any event.3.Each partyshall submit to the judge and to opposing counsel proposed voir direquestions.
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9EACH OF THESE ITEMS IS TO BE FILED PRIOR TO THEFIRST TRIAL DATE EVEN IF THE CASE IS CONTINUED.COUNSEL ARE ON NOTICE THAT FAILURE TOPROVIDE TIMELY COMPLIANCE WITH THEREQUESTS OF PART X AND PART XI MAY RESULT INTHE POSTPONEMENT OFTRIAL AND THEASSESSMENT OF JUROR AND OTHER COSTS AND/ORTHE IMPOSITION OF SANCTIONS.
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10CONCLUDING CERTIFICATIONWe hereby certify bythe affixing of our signature to this Final Pretrial Order that itreflects the efforts of all counsel and that we have carefullyand completely reviewed all parts ofthis Order prior to its submission to the court. Further, itis acknowledged that amendments tothis Joint Final Pretrial Order will not be permitted except where the court determines thatmanifest injustice would result if the amendment is not allowed.Attorney(s) for Plaintiff(s):Attorney(s) for Defendant
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