STANDING ORDER REGARDING TRIAL AND PRE-TRIAL PROCEDURES
Judge Nina Y. Wang
United States District Court
District of Colorado
Alfred A. Arraj United States Courthouse
901 19th Street, Courtroom A-902
Denver, Colorado 80294-3589
Email:
[email protected]
Telephone: 303.335.2600
Revised: December 1, 2025
TABLE OF CONTENTS
A. Title and Citation................................................................................................... 3
B. Final Pretrial/Trial Preparation Conference .......................................................... 3
C. Jury Instructions and Verdict Form ....................................................................... 4
D. Exhibits and Exhibit Lists ...................................................................................... 5
E. Witness Lists ........................................................................................................ 6
F. Depositions ........................................................................................................... 7
G. Motions in Limine.................................................................................................. 8
H. Trial Briefs ............................................................................................................ 8
I. Jury Trials ............................................................................................................. 8
J. Bench Trials........................................................................................................ 10
TABLE OF PRE-TRIAL/TRIAL DEADLINES ................................................................. 11
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TRIAL AND PRE-TRIAL PROCEDURES
A. Title and Citation
1. This Standing Order shall be cited as “NYW Standing Order Regarding
Trial and Pre-Trial Procedures, Section, Subsection, Paragraph” (e.g., NYW
Standing Order Regarding Trial and Pre-Trial Procedures § E.5.a).
B. Final Pretrial/Trial Preparation Conference
1. Unless otherwise ordered, this Court will conduct one joint Final
Pretrial/Trial Preparation Conference, to be held after the resolution of all
dispositive motions, should any be filed.
2. If no dispositive motions are filed, the parties shall, no later than seven
days after the dispositive motions deadline has passed, file a joint motion for a
status conference for purposes of setting firm dates for the Final Pretrial/Trial
Preparation Conference and the trial. In cases in which one of the parties is an
incarcerated pro se litigant, the motion may be filed by the non-incarcerated
party.
a. If dispositive motions are filed, the Court will sua sponte set the
status conference when resolving the dispositive motion(s), should the
dispositive motion(s) not fully dispose of the case.
b. The parties should be prepared to discuss at the status conference
the anticipated length of trial. If the parties believe that the trial should
last longer than five days, the parties should be prepared to explain
why good cause exists for a trial longer than five days.
3. The Final Pretrial/Trial Preparation Conference will be held approximately
six weeks prior to the beginning of the trial. Counsel who will try the case must
attend the Final Pretrial/Trial Preparation Conference in person. It is the
expectation of the Court that, in cases in which one of the parties is an
incarcerated pro se litigant, the incarcerated litigant will participate in the Final
Pretrial/Trial Preparation Conference by telephone.
4. Seven days prior to the Final Pretrial/Trial Preparation Conference, the
parties shall submit a proposed Final Pretrial Order using the form found on the
District of Colorado’s website. The parties shall jointly file their proposed Final
Pretrial Order via CM/ECF and shall also send an editable Microsoft Word
version to
[email protected]. In a case with a pro se litigant,
counsel for represented parties shall take the lead in preparing the proposed
Final Pretrial Order.
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5. The parties shall submit their respective proposed voir dire questions to
the Court no later than seven days prior to the Final Pretrial/Trial Preparation
Conference. The parties shall file their respective proposed voir dire questions
via CM/ECF and shall send editable Microsoft Word versions to
[email protected]. The parties shall be prepared to discuss
their proposed voir dire at the Conference.
C. Jury Instructions and Verdict Form
1. The parties shall submit their proposed jury instructions and proposed
verdict form fourteen days prior to the Final Pretrial/Trial Preparation
Conference, unless otherwise ordered. The parties shall jointly file their
proposed jury instructions and proposed verdict form (in separate filings) via
CM/ECF and shall also jointly send an editable Microsoft Word version of each
document to
[email protected].
2. Each proposed jury instruction must be submitted on a separate page, be
numbered, and identify the source of the instruction and supporting authority.
3. The parties must use their best efforts to stipulate to jury instructions. To
the extent there are disputes with respect to proposed jury instructions, each
party shall submit its own proposed jury instruction. In addition, for each
disputed instruction, the parties shall jointly submit a single, redlined jury
instruction in which they delineate the language they respectively propose. For
example:
Plaintiff’s Proposed Jury Instruction: The reasonableness of an insurer’s
conduct is to be determined objectively, according to industry standards
and must be evaluated based on the information before the insurer at the
time of the conduct.
Defendant’s Proposed Jury Instruction: The reasonableness of an
insurer’s conduct is to be determined objectively, according to industry
standards. and must be evaluated based on the information before the
insurer at the time of the conduct.
4. The parties shall meet and confer and stipulate to a proposed verdict form.
The Court strongly encourages counsel to craft a stipulated verdict form that is
readily understandable to laypersons.
5. Stylistic conventions: Please capitalize party names and refrain from
using articles when referring to parties (e.g., “Plaintiff” rather than “the plaintiff”).
Where parties or other individuals are referenced by name, please use the
appropriate title (e.g., Ms., Mr., Dr.) and not the last name alone.
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D. Exhibits and Exhibit Lists
1. For all evidentiary hearings and trials, the parties shall use the format for
exhibit lists located on the District Court’s website at
http://www.cod.uscourts.gov/JudicialOfficers/ActiveArticleIIIJudges/HonNinaY
Wang.aspx.
2. Exhibits shall be labeled on the parties’ joint exhibit list in numeric order,
with no designation as to whether it is “Plaintiff’s Exhibit” or “Defendant’s
Exhibit.” The parties must stipulate to the authenticity and admissibility of as
many exhibits as possible, marking the appropriate box on the proposed exhibit
list. Failure to appropriately stipulate to exhibits may lead to further
conferences with the Court and/or a resetting of the trial date. The parties’
stipulation as to the admissibility of a document does not guarantee its
admissibility; each document the parties intend to submit to the jury must be
offered to and accepted by the Court.
3. For all trials, exhibit lists are due no later than seven days prior to the
Final Pretrial/Trial Preparation Conference, unless otherwise ordered. The
parties shall jointly file their exhibit list via CM/ECF and shall also send an
editable Microsoft Word version to
[email protected].
4. For all evidentiary hearings, exhibit lists are due no later than two
business days prior to the hearing, unless otherwise ordered. The parties
shall jointly file their exhibit list via CM/ECF and shall also send an editable
Microsoft Word version to
[email protected].
5. Exhibit Notebooks
a. Prior to a hearing or trial, the parties shall jointly provide to the
courtroom deputy a copy of all exhibits in a notebook format. This
notebook will be used for the witnesses and/or the jury. For all trials, the
exhibit notebook is due no later than seven days prior to the Final
Pretrial/Trial Preparation Conference, unless otherwise ordered. For all
hearings, the exhibit notebook is due no later than two business days
prior to the hearing, unless otherwise ordered.
b. Exhibit notebooks should be labeled with the following information:
(a) case caption; and (b) scheduled commencement date and time of the
hearing or trial.
c. The parties shall separate all documents by numbered tabs and
reproduce each exhibit in the manner in which it will be shown to the
witness and jury, e.g., colored exhibits should appear in color in the
notebooks. Multi-page exhibits should include internal numbering for
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ease of the witness and the Court. All exhibits will be sequentially
numbered, without any attribution to the plaintiff or the defendant.
d. In addition to submitting exhibit notebooks, the parties shall jointly
provide to the courtroom deputy two flash drives that each contains a copy
of all exhibits, numbered sequentially in the same numeric order used in
the exhibit notebook. For all trials, exhibit flash drives are due no later
than seven days prior to the Final Pretrial/Trial Preparation Conference,
unless otherwise ordered. For all hearings, exhibit flash drives are due no
later than two business days prior to the hearing, unless otherwise
ordered.
6. Demonstrative Exhibits
a. To the extent any party wishes to use demonstrative exhibits during
trial, those exhibits must be prepared in advance outside of court. The
Court does not permit parties to create demonstratives during the trial (for
example, writing on an easel pad during cross-examination).
b. The Court does not permit the use of demonstrative exhibits that
contain unadmitted documentary evidence, even if the parties have
stipulated to that evidence.
c. Demonstrative exhibits are permitted for in-court use only and will
not be sent back to the jury for use during deliberations.
E. Witness Lists
1. For all evidentiary hearings and trials, the parties shall use the format for
witness lists located on the District Court’s website at
http://www.cod.uscourts.gov/JudicialOfficers/ActiveArticleIIIJudges/HonNinaY
Wang.aspx.
2. For each witness, please provide a brief description of the subjects that
will be covered in the witness’s testimony. Please also estimate the time for all
examinations, e.g., direct and re-direct. Please note that the cumulative
estimated times for trial witnesses should not exceed the total time allotted for
a party to present its case. The Court will strictly enforce the estimated time
allotted for each witness’s testimony.
3. For all trials, witness lists are due no later than seven days prior to the
Final Pretrial/Trial Preparation Conference, unless otherwise ordered. The
parties shall file their witness lists via CM/ECF and shall also jointly send
editable Microsoft Word versions to
[email protected].
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4. For all evidentiary hearings, witness lists are due no later than two
business days prior to the hearing, unless otherwise ordered. The parties
shall file their witness lists via CM/ECF and shall also jointly send editable
Microsoft Word versions to
[email protected].
5. On the morning of the first day of trial or the evidentiary hearing, each
party shall provide the courtroom deputy with four paper copies of a final list of
its witnesses that includes an estimate of the time anticipated for each witness’s
direct and cross examination. One copy will be made available to the court
reporter to assist in the transcription of court proceedings, so please be sure
that names are spelled correctly.
F. Depositions
1. Together with Fed. R. Civ. P. 32, this Practice Standard governs the use
of both regular and videotaped depositions in court proceedings.
2. If the parties intend to offer deposition testimony in lieu of a live witness at
trial or at an evidentiary hearing:
a. No later than twenty-one days prior to the Final Pretrial/Trial
Preparation Conference, the party offering such testimony must designate
the deposition testimony and inform the opposing party whether the
testimony will be read or presented from a video recording. The
deposition designations should be provided to the opposing party but
should not be filed on the docket.
b. Counter-designations must be made no later than fourteen days
prior to the Final Pretrial/Trial Preparation Conference. The counter-
designations should be provided to the opposing party but should not be
filed on the docket.
c. The parties should be prepared to address any anticipated
objections at the Final Pretrial/Trial Preparation Conference. Prior to the
Final Pretrial/Trial Preparation Conference, the parties shall meet and
confer regarding their designations and objections. After a good-faith
meet and confer process, the parties shall identify any remaining
objections by page and line citation and jointly submit a chart that sets
forth (1) the page and line citations of the deposition testimony subject to
objection; (2) an explanation for each objection; and (3) any relevant or
supporting case law. The objection chart shall be filed on CM/ECF and
submitted to
[email protected] no later than seven
days prior to the Final Pretrial/Trial Preparation Conference. In addition,
no later than seven days prior to the Final Pretrial/Trial Preparation
Conference, the parties shall jointly submit a copy of the deposition
transcript(s) to
[email protected].
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i. Transcripts submitted to the Court should have each party’s
designations in a different color of highlighting, with a clear legend of
the designated colors.
3. To accommodate evidentiary objections to deposition testimony
presented by video, the proponent must have the technical ability to “mute”
excluded responses and efficiently “fast forward” to the next segment of
testimony. Otherwise, the deposition testimony will be read into the record.
4. For jury trials, if evidence will be presented through a written deposition
transcript, the proponent shall supply a person to read from a written deposition
transcript in a non-argumentative fashion.
G. Motions in Limine
1. Each party may file one omnibus motion in limine, not to exceed fifteen
pages.
2. Motions in limine shall be filed no later than forty-two days prior to the
Final Pretrial/Trial Preparation Conference, unless otherwise ordered.
Responses shall be filed no later than twenty-eight days prior to the Final
Pretrial/Trial Preparation Conference, or fourteen days after the motion is filed,
whichever is earlier. No replies will be permitted absent leave of Court and
good cause shown.
H. Trial Briefs
1. The Court typically does not permit the filing of trial briefs. However, if a
party believes that the circumstances of the case necessitate a trial brief, the
party may seek leave of Court to submit a trial brief by filing a formal motion,
and must articulate specific issue(s) that the party seeks to brief. The trial brief
should not be used to repeat any arguments made in a motion in limine or a
dispositive motion. Only after leave is granted shall the Court enter an order
with page limitations and/or specific instructions. Trial briefs must be submitted
to the Court via CM/ECF no later than forty-five days prior to the
commencement of trial.
I. Jury Trials
1. Counsel and all pro se parties shall be present no later than 8:30 a.m.
each day during the trial to discuss any last-minute trial matters. Trial days will
typically begin at 9:00 a.m. and end at 4:00 p.m., with a fifteen-minute break in
the morning, an hour break for lunch, and a fifteen-minute break in the
afternoon. However, counsel and witnesses should be aware that the general
schedule may be modified to promote the efficiency of the trial.
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2. Unless otherwise ordered, civil juries will consist of at least 7 jurors.
3. Jury Selection and Voir Dire:
a. The Court will conduct voir dire of prospective jurors. Unless
otherwise ordered, each side will then be permitted to conduct a voir dire
examination of potential jurors for 15 minutes after the Court has
completed its voir dire examination.
b. After voir dire is complete, the Court will entertain challenges for
cause. If any prospective jurors are struck for cause, the Court will
conduct voir dire of any replacement juror(s). Each side will be permitted
three peremptory strikes.
4. Jurors will be permitted to take notes during the trial.
5. After the close of evidence but before closing arguments, the Court will
read the jury instructions to the jurors. Each juror will be given a copy of the
jury instructions for use during deliberations.
6. Opening Statements and Closing Arguments:
a. Opening statements will generally be limited to thirty minutes per
party. Should the parties believe that they require more time, the parties
should be prepared to discuss their request at the Final Pretrial/Trial
Preparation Conference. Typically, only one attorney per party will be
permitted to make opening statements, unless the Court finds good cause
to permit otherwise. The courtroom deputy will provide a five minute
warning before time expires.
b. After the close of evidence, the Court will inform the parties how
much time will be allotted for closing arguments. Typically, only one
attorney per party will be permitted to make closing arguments, unless the
Court finds good cause to permit otherwise. Counsel for each party
should inform the courtroom deputy whether counsel would like a warning
before their time expires. Should the plaintiff wish to reserve any time for
rebuttal, counsel must make the request prior to beginning closing
arguments.
c. To the extent any party intends to utilize PowerPoints, slides, or any
other demonstrative items for opening statements, the parties shall
exchange such items no later than two business days prior to the
commencement of trial and shall provide copies of the same to
[email protected]. To the extent any party intends to
use these demonstrative items for closing arguments, the parties shall
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exchange such items no later than 6:00 P.M. the evening before closing
arguments and shall provide copies of the same to
[email protected]. Counsel shall not use any
documents that have not been stipulated to in their opening statements
and shall not use any documents not admitted in evidence in their closing
arguments. The Court will generally consider objections to the use of such
items on the morning of the first day of trial for opening statements, or at
a break preceding the presentation of closing arguments, respectively.
J. Bench Trials
1. Generally, the Court will permit no more than fifteen minutes for opening
statements and thirty minutes for closing arguments. To the extent that the
parties agree, they may substitute a written submission of no more than ten
pages in lieu of closing arguments.
2. No later than three business days before the Final Pretrial/Trial
Preparation Conference, the parties shall submit Proposed Findings of Fact,
Conclusions of Law, and Orders. A joint Proposed Findings of Fact,
Conclusions of Law, and Orders shall be submitted that reflects stipulated facts
and/or law to which the parties agree. Each party may then file separate
proposed Findings of Fact, Conclusions of Law, and Orders with respect to any
disputed points. The proposed Findings of Fact shall include citations to the
trial exhibits, and the proposed Conclusions of Law shall include legal citations.
The documents shall be filed via CM/ECF and shall also be submitted as an
editable Microsoft Word version to
[email protected]. The
parties are expected to state their proposed findings of fact in the same order
as the anticipated order of proof at trial.
3. For a trial to the Court, a proper résumé or curriculum vitae, marked as an
exhibit, generally will suffice for the qualification of an expert witness.
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TABLE OF PRE-TRIAL/TRIAL DEADLINES
Note: This table is provided for the convenience of the parties appearing before Judge
Wang. It does not include all the dates and deadlines listed within the Court’s Civil
Practice Standards and Standing Orders and is not a substitute for knowledge of and
familiarity with those texts.
Deadline Days Prior to/After Reference to Applicable
Practice Standard,
Standing Order, or Rule
After the Defendant’s Submission of a Responsive Pleading or Motion
For employment cases which
challenge one or more
employment actions alleged
to be adverse, except the
employment actions listed in
Civ. Practice Standard
26.1A(b):
Exchange documents and 30 days Civ. Practice Standard
information described in the 26.1A(c).
Initial Discovery Protocols,
located on the District Court’s
website, for the relevant time
period.
After the Deadline for the Disclosure of Rebuttal Witnesses
File motions pursuant to 30 days Civ. Practice Standard
Federal Rule of Evidence 7.1C(a).
702.
After the Close of Discovery
File joint status report 14 days Civ. Practice Standard
regarding settlement 16.6(a).
discussions.
After the Dispositive Motions Deadline
File motion to set status 7 days NYW Standing Order
conference, if no dispositive Regarding Trial and Pre-Trial
motions are filed. Procedures § B.2.
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Prior to the Final Pretrial/Trial Preparation Conference
File proposed Final Pretrial 7 days NYW Standing Order
Order. Regarding Trial and Pre-Trial
Procedures § B.4.
File motions in limine. 42 days NYW Standing Order
Regarding Trial and Pre-Trial
Procedures § G.2.
File responses to motions in 28 days (or 14 days after the NYW Standing Order
limine. motion is filed, whichever is Regarding Trial and Pre-Trial
earlier) Procedures § G.2.
Exchange designations of 21 days NYW Standing Order
deposition testimony. Regarding Trial and Pre-Trial
Procedures § F.2.a.
Exchange counter- 14 days NYW Standing Order
designations of deposition Regarding Trial and Pre-Trial
testimony. Procedures § F.2.b.
Submit unresolved deposition 7 days NYW Standing Order
objections. Regarding Trial and Pre-Trial
Procedures § F.2.c.
File proposed jury 14 days NYW Standing Order
instructions and verdict form. Regarding Trial and Pre-Trial
Procedures § C.1.
File proposed voir dire 7 days NYW Standing Order
questions, exhibit list, and Regarding Trial and Pre-Trial
witness lists. Procedures §§ B.5, D.3, E.3.
Submit exhibit notebook and 7 days NYW Standing Order
exhibit flash drives to the Regarding Trial and Pre-Trial
courtroom deputy. Procedures §§ D.5.a, D.5.d.
File Proposed Findings of 3 business days NYW Standing Order
Fact, Conclusions of Law, Regarding Trial and Pre-Trial
and Orders for bench trial. Procedures § J.2.
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Prior to Trial
File any trial briefs. 45 days NYW Standing Order
Regarding Trial and Pre-Trial
Procedures § H.1.
Request daily transcripts 30 days Civ. Practice Standard
from the court reporter. 43.1A(c)(2).
File motion requesting the 7 days Civ. Practice Standard
presentation of testimony by 43.1D(c).
telephone or video
conference.
Request realtime transcripts 7 days Civ. Practice Standard
from the court reporter. 43.1A(c)(2).
File glossary of any difficult, 5 business days Civ. Practice Standard
unusual, scientific, technical, 43.1A(d)(1).
and/or medical jargon, words,
names, terms, and/or
phrases.
Submit and exchange 2 business days NYW Standing Order
PowerPoints, slides, or any Regarding Trial and Pre-Trial
other demonstrative items for Procedures § I.6.c.
opening statements.
Submit and exchange 6:00 P.M. the evening before NYW Standing Order
PowerPoints, slides, or any closing arguments Regarding Trial and Pre-Trial
other demonstrative items for Procedures § I.6.c.
closing arguments.
Submit final witness lists to Morning of the first day of trial NYW Standing Order
the courtroom deputy. Regarding Trial and Pre-Trial
Procedures § E.5.
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