Attachment C
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ALABAMA
Choose an item. DIVISION
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Plaintiffs, }
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Defendants. }
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PROPOSED PRETRIAL ORDER
The court held the final pretrial conference in this case on ____. Consistent
with the discussions held on the record at the conference, the court ENTERS the
following rulings.
1. Parties and Trial Counsel. Any remaining fictitious parties are hereby
STRICKEN. The parties and designated trial counsel are correctly named as set out
below: [Include a line and designation for each party in the case.]
Parties: Trial Counsel:
[Name of the Plaintiff(s] [Name of Counsel]
[Name of the Defendant(s)] [Name of Counsel]
2. Nature of the Action, Jurisdiction and Venue.
(a) The nature of this action is as follows: [For example,
employment discrimination; Fair Labor Standard Act,
breach of contract, etc.]
(b) The court has subject matter jurisdiction of this action under
[List each statute, rule or case claimed to authorize the
court’s subject matter jurisdiction in this action].
(c) All jurisdictional and procedural requirements prerequisite to
maintaining this action [have/have not] been met.
(d) Personal jurisdiction and/or venue [are/are not] contested. [If
personal jurisdiction or venue is contested, briefly set out the
relevant arguments.]
3. Pleadings. The following pleadings have been allowed:
[List pleadings in the order in which they were filed and allowed. Do not include
pleadings that have been stricken or otherwise disallowed. See Fed. R. Civ. P.
7(a) for a list of allowable pleadings.]
4. Statement of the Case.
[Taken from statement of facts submitted by parties before pretrial
scheduling conference]
5. Contentions of the Parties
[Taken from the contentions submitted by parties before the pretrial
scheduling conference .]
(a) Plaintiff’s Contentions
(b) Defendant’s Contentions
6. Stipulated Facts The parties stipulate to the facts set out in Exhibit A to
this pretrial order. [In a separate document identified as Exhibit A, please
separate out each stipulated fact in numbered paragraphs. These facts will be
read to the jury in advance of opening argument]
7. Trial Exhibit List. Consistent with § III(3) of the pretrial scheduling
order, a thumb drives containing a .pdf document of the joint trial exhibit list and a
separate file for each premarked exhibit has been submitted to the courtroom deputy.
Additionally, a Word version of the joint trial exhibit list has been submitted to
chambers via email. The joint trial exhibit list is incorporated here by reference.
8. Witness List [identify all witnesses and separate into the following
categories]
(a) Live Witnesses
(b) Deposition Testimony
(c) Video Deposition
9. Damages
The damages sought in this action are as follows: [using the same format as
plaintiff’s initial damages submission, provide the list of damages and equitable
relief claimed with any necessary revisions to reflect rulings made during the
pretrial conference].
10. Proposed Jury Instructions. The proposed jury instructions are set out
in Exhibit B. The parties reserve all objections set out therein.
10. Voir Dire Questions. The parties do not object to the court asking the
questions set out in Exhibit C during voir dire. [Exhibit C should include all
questions set out in Attachment B to the pretrial scheduling order along with
any additional questions the parties agree on]
DONE and ENTERED this ____
