INFORMATION and GUIDELINES
for Civil Practice before
The Honorable Jane M. Beckering
United States District Judge
United States District Court
for the Western District of Michigan
Honorable Jane M. Beckering
601 Ford Federal Building
110 Michigan St., N.W.
Grand Rapids, MI 49503-2363
Revised: September 2025
TABLE OF CONTENTS
Directory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
I. Calendar . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
II. Alternative Dispute Resolution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
III. Motions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
A. Dispositive . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
B. Non-Dispositive . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
IV. Ex Parte Applications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
V. Orders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
VI. Transcripts of Court Proceedings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
VII. Stipulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
VIII. Final Pretrial Conference . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
A. Matters to be Addressed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
B. Submissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
C. Preparation of Order . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
IX. Trial . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
A. Courtroom Decorum . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
B. Daily Schedule and Time Frames . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
C. Recesses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
D. Bench Trial . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
E. Submissions for Jury Trial . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
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F. Jury Selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
G. Witnesses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
H. Exhibits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
I. Deposition Designations and Motions in Limine . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
Attachment 1 - Exhibit List. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
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DIRECTORY
HONORABLE JANE M. BECKERING
United States District Judge
United States District Court
601 Ford Federal Building
110 Michigan St., N.W.
Grand Rapids, MI 49503-2363
Telephone: (616) 456-2687
Judicial Assistant – Lauren Packard
Email:
[email protected]
Telephone: (616) 456-2687
Case Manager – Rick Wolters
Email:
[email protected]
Telephone: (616) 456-2351
Law Clerks – Rita Buitendorp
Stephen Mayer
Court Reporter – Jean Ann Hamlin
Email:
[email protected]
Telephone: (517) 881-9582
United States District Court Clerk’s Office
Ann E. Filkins, Clerk of Court
399 Ford Federal Building
110 Michigan St., N.W.
Grand Rapids, MI 49503-2363
Telephone: (616) 456-2381
Electronic Filing Help Desk: (616) 456-2206
(800) 290-2742
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I. Calendar
The Case Manager is in charge of all calendar matters. All proceedings are set according
to the Court’s schedule. If you need a scheduling change, you must first reach agreement with
opposing counsel and then contact the Case Manager. It is incumbent upon the party requesting a
change to notify the opposing party of the request and, if granted, the new date. Judge Beckering’s
Case Manager, Rick Wolters, may be contacted by calling (616) 456-2351 or by emailing
[email protected]. In situations where an opposing attorney will not consent to
the proposed change, the party requesting it should submit a CM/ECF filing, stating reasons for
the change.
Do not contact the Judge or her law clerks to request a scheduling change.
II. Alternative Dispute Resolution
In the interest of conserving judicial resources, this Court will require the parties to
participate in some form of Alternative Dispute Resolution. Voluntary Facilitative Mediation is
encouraged, but the parties are free to consider other methods as permitted by W.D. Mich. LCivR
16.2. At a minimum, the Court will schedule a settlement conference before a magistrate judge
prior to the final pretrial conference. The parties are under an ongoing obligation to engage in
good faith settlement negotiations.
III. Motions
A. Dispositive
1. Joint Statement of Material Facts and Joint Exhibits for Summary Judgment Motions
a. Upon any motion for summary judgment pursuant to Rule 56 of the Federal Rules
of Civil Procedure, the parties shall confer and file a Joint Statement of Material
Facts, setting forth in numbered paragraphs, separate, short and concise statements
of the material facts that are not in dispute. Citations to the record shall be included
as appropriate for each paragraph. A key purpose of the Joint Statement is to
establish a nonargumentative foundation of the core material facts for the issues
presented. The Joint Statement shall be filed as a separate document on CM/ECF.
b. To the extent the parties rely on additional material facts to support their
arguments, those facts shall be concisely set forth in their respective motion briefs,
and must include citations to the record.
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c. The parties shall collaborate to file joint exhibits where possible.
2. Filing of Dispositive Motion Papers
a. Pursuant to W.D. Mich. LCivR 7.2(b)(iii), a courtesy copy of all dispositive
motion papers, including responses, replies, and all accompanying exhibits, is
requested to be submitted directly to Chambers. The courtesy copy should comply
with the requirements listed in the local rules and must be hand delivered or sent
via first class mail to Chambers within twenty-four (24) hours of filing the original.
All submitted courtesy copies should be bound. There is no preference on the type
of binding as long as fasteners pass through the pages; paper clips and other types
of clips shall not be used.
3. Dispositive motions must adhere to W.D. Mich. LCivR 7.2. If the dispositive motion
is based on depositions, the Court prefers that parties file the entire deposition
transcript with the relevant portions highlighted. Alternatively, a party may file only
those excerpts that are relevant to the motion. If the dispositive motion references
answers to interrogatories as a supporting document, then only those excerpts that are
relevant to the motion shall be filed.
4. Oral argument may be requested pursuant to W.D. Mich LCivR 7.2(d). To request
oral argument on a motion, state “ORAL ARGUMENT REQUESTED” in the caption
and the heading of the brief. The Court may schedule oral argument or may, in its
discretion, dispose of the motion without argument at the end of the briefing schedule.
5. In cases where counsel wishes to project evidence on the monitors in the courtroom,
projection of exhibits is accomplished by using the electronic evidence presentation
equipment in the courtroom. The evidence presentation allows for the projection of
evidence on various monitors located at the witness stand, the lectern, the jury box,
and the counsel tables. This technology eliminates the cumbersome process of
handling paper evidence, and its use is strongly encouraged. Counsel planning to use
the equipment are required to contact the Court’s IT department well in advance of
their court proceeding to inquire about equipment, training and practice sessions.
Practice sessions and testing of the equipment must occur prior to the day of a
scheduled court appearance. You may contact the Court’s IT department by sending
an e-mail to
[email protected] or by calling (616) 456-2523. Information
concerning the features of the system are available at the court's website:
www.miwd.uscourts.gov (click on Judges’ Info/Judge Jane M. Beckering/Courtroom
Technology tab). Counsel is also required to notify Chambers – in advance of the
hearing – of their intentions to use technology resources in the courtroom and
coordinate the date and time of any practice sessions with Chambers.
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B. Non-Dispositive
Non-dispositive motions shall be filed in accordance with W.D. Mich. LCivR 7.3. They
will usually be referred to a Magistrate Judge pursuant to 28 U.S.C. § 636(b)(1)(A). In accordance
with 28 U.S.C. § 471 et seq., it is the policy of this Court to prohibit the consideration of non-
dispositive motions unless accompanied by a certification that the moving party has made a
reasonable and good faith effort to reach agreement with opposing counsel on the matters set forth
in the motion. See W.D. Mich. LCivR 7.1(d).
IV. Ex Parte Applications
Ex parte applications are disfavored and should be avoided except in the most extreme
circumstances. Where such rare cases arise, the party submitting the application must state in the
application that opposing counsel has been contacted in an attempt to resolve the situation through
normal motion practice and why such an option is unsatisfactory, or, why contacting the opposing
party would be inappropriate under the circumstances. W.D. Mich. LCivR 7.1(d). Applications
for temporary restraining orders must comply strictly with the specific requirements of Fed. R.
Civ. P. 65.
V. Orders
All proposed orders should be filed by means of the Court’s CM/ECF system. Unopposed
motions should include a proposed order.
If the Court has instructed a prevailing party to submit an order, then the prevailing party
must have the proposed order approved by opposing counsel before it is submitted to the Court for
the Judge’s signature. In the event of a disagreement as to the form of an order, the prevailing
party may bring a motion to settle the order.
Whenever a motion to settle an order is made, costs and attorney’s fees will be awarded
against an attorney who unreasonably withholds consent as to form.
VI. Transcripts of Court Proceedings
If a transcript of a court proceeding is desired, Judge Beckering’s Court Reporter, Jean Ann
Hamlin, should be contacted directly by e-mail at
[email protected] or by
telephone at (517) 604-1732.
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VII. Stipulations
All stipulations should be submitted by electronic filing for the judge’s approval with a
proposed order, or the stipulation itself can include the phrase "IT IS SO ORDERED" with a place
for the Judge’s signature and date.
VIII. Final Pretrial Conference
A. Matters to be Addressed
1. At the final pretrial conference, the parties and the Court will formulate a plan for trial,
including facilitating the admission of evidence; consider the prospects of settlement;
and consider such other matters as may aid in the trial or other disposition of the action,
including:
a. Jury Selection Procedure, and
b. Jury Instructions.
2. Unless excused upon a showing of good cause, the attorney who is to conduct the trial
shall attend the pretrial conference and shall come with full authority to act in all
respects, or shall be accompanied by a representative of the party with such authority.
B. Submissions
1. At least seven (7) days prior to the final pretrial conference, counsel shall file:
a. Trial briefs.
b. A joint statement of the case and statement of the elements of the claims. Unless
the case is very complex, the joint statement of the case should not exceed one
paragraph. If the parties are unable to agree on the language of a joint statement
of the case, then separate, concise, non-argumentative statements shall be filed.
The purpose of the joint statement of the case is to summarize the nature of the
case. [In a jury trial, the statement(s) of the case will be read to the prospective
jurors during jury selection. The elements of the claims will be included in the
preliminary jury instructions.]
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c. Proposed voir dire questions in jury trials. The Court will ask basic voir dire
questions. Counsel for the parties will be permitted to question prospective jurors.
Questioning by counsel shall not be repetitive of questions asked by the Court or
of questions asked in the juror questionnaire.
2. The parties are required to submit a copy of the joint statement of the case,
statement of the elements of the claims and proposed voir dire questions in jury
trials in an editable word processing format by e-mail to Judge Beckering’s
Judicial Assistant, Lauren Packard at
[email protected].
C. Preparation of Order
Unless directed otherwise by this Court, a proposed pretrial order, entitled “Final Pretrial
Order,” shall be prepared jointly by counsel and filed by means of the Court’s CM/ECF system
seven (7) days prior to the final pretrial conference in the following form:
A final pretrial conference was held on the ___ day of ______________. Appearing
for the parties as counsel were:
(List the counsel who will attend the final pretrial conference.)
1. Exhibits: The following exhibits will be offered by the plaintiff and the defendant:
(List jointly [JT EX __] all exhibits, including demonstrative evidence and
summaries of other evidence. Exhibits expected to be used solely for
impeachment purposes need not be identified until trial. The exhibits shall be
identified on a form similar to Attachment 1, attached to these Guidelines. The
complete list of exhibits on a form similar to Attachment 1 must be produced at
the final pretrial conference. Failure to list an exhibit required to be listed by this
order will result, except upon a showing of good cause, in a determination of non-
admissibility at trial. Plaintiff shall use numbers [1-99]; defendant shall use letters
[A-Z]. Where the parties are unable to agree on the inclusion of an exhibit,
indicate with respect to each exhibit whether and for what reason its admissibility
is contested. Objections not contained in the Pretrial Order, other than objections
under Evidence Rule 402 or 403, shall be deemed waived except for good cause
shown. See Fed. R. Civ. P. 26(a)(3).)
At least seven (7) days prior to the final pretrial conference, counsel shall provide
to the Court hard copies of any exhibits to which objections have been made.
Counsel for the party objecting is responsible for providing hard copies of the
objected-to exhibits to the Court.
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2. Uncontroverted Facts: The parties have agreed that the following may be accepted
as established facts:
(State in detail all uncontroverted facts.)
3. Controverted Facts and Unresolved Issues: The factual issues remaining to be
determined and issues of law for the Court’s determination are:
(Set out each issue that is genuinely controverted, including issues on the merits
and other matters that should be drawn to the Court’s attention.)
4. Witnesses:
a. Non-expert witnesses to be called by the plaintiff and defendant, except those
who may be called for impeachment purposes only, are:
(List names, addresses, and telephone numbers of all non-experts who will
testify. Indicate whether they are expected to testify in person, by deposition
videotape, or by reading of their deposition transcript. Indicate all objections
to the anticipated testimony of each non-expert witness. For each witness
listed, indicate whether the witness will be called or merely may be called
to testify.)
b. Expert witnesses to be called by the plaintiff and defendant, except those
who may be called for impeachment purposes only, are:
(List names, addresses, and telephone numbers of all experts who will testify,
providing a brief summary of their qualifications and a statement of the
scientific, technical or medical field(s) in which they are offered as experts.
Indicate whether they will testify in person, by deposition videotape, or by
reading of their deposition transcript. Indicate all objections to the
qualifications or anticipated testimony of each expert witness.)
c. It is understood that, except upon a showing of good cause, no witness whose
name and address does not appear in the lists required by subsections (a) and
(b) will be permitted to testify for any purpose, except impeachment, if the
opposing party objects. Any objection to the use of a deposition under Fed.
R. Civ. P. 32(a) not reflected in the Pretrial Order shall be deemed waived,
except for good cause shown.
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5. Depositions and Other Discovery Documents:
All depositions, answers to written interrogatories, and requests for admissions, or
portions thereof, that are expected to be offered in evidence by the plaintiff and
the defendant are:
(Designate portions of depositions by page and line number. Designate answers
to interrogatories and requests for admissions by answer or request number.
Designation need not be made of portions that may be used, if at all, as
impeachment of an adverse party. Indicate any objections to proposed deposition
testimony, answers to interrogatories, and admissions.)
6. Length of Trial: Counsel estimate the trial will last approximately _____ full days,
allocated as follows: _____ days for plaintiff’s case; _____ days for defendant’s
case; _____ days for other parties. In the event the Court imposes limits prior to
the final pretrial conference, the parties’ proposed pretrial order must include those
limits.
7. Form of Alternative Dispute Resolution: The form of Alternative Dispute
Resolution selected was _______________________. The outcome was
unsuccessful for the following reasons: ______________________________.
8. Prospects of Settlement: The current status of settlement negotiations is:
(Indicate persons present during negotiations, progress toward settlement and
issues that are obstacles to settlement.)
The proposed Final Pretrial Order shall be signed by all counsel, signifying their
acceptance. Upon approval by the Court, with such additions, deletions, or modifications as are
necessary, the Final Pretrial Order will be entered.
IX. Trial
A. Courtroom Decorum
The purpose of this paragraph is to describe certain basic principles concerning courtroom
behavior and decorum. The requirements stated in this rule are minimal, not all-inclusive, and are
intended to emphasize and supplement, not supplant or limit, the ethical obligations of counsel
under the Rules of Professional Conduct or the time-honored customs of experienced trial counsel.
These requirements apply to all counsel and all persons at counsel table.
1. This Court expects all attorneys and parties to act with courtesy and respect toward
everyone in the courtroom. Avoid disparaging personal remarks or acrimony toward
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opposing counsel and remain wholly detached from any ill feeling between the
litigants or witnesses. Address all remarks to the Court, not to opposing counsel.
Refer to all persons, including witnesses, other counsel and the parties, by their
surnames and not by their first or given names.
2. Please be careful with the courtroom furniture. For example, do not put briefcases
with metal feet on the tables.
3. Stand near the lectern while examining a witness and making statements to the jury,
except that counsel may approach the clerk’s desk or the witness for purposes of
handling or tendering exhibits. The recording system picks up voices only when they
are speaking into a microphone.
4. Offers of, or requests for, a stipulation should be made privately — not within the
hearing of the jury.
5. Counsel shall admonish all persons at counsel table to refrain from making gestures,
facial expressions, audible comments, and the like, as manifestations of approval or
disapproval, during the testimony of witnesses or at any other time.
6. Cell phones or other electronic devices shall be in silent mode or turned off. The Court
reserves the right to take appropriate action for violation of this policy.
7. Water may be brought into the courtroom in appropriate containers. No other
beverages are allowed.
8. Gum chewing and eating are prohibited in the courtroom. Remove hats when in the
courtroom unless worn for religious purposes.
B. Daily Schedule and Time Frames
Generally, the trial schedule will be Tuesday though Friday, from 9:00 a.m. to 12:00 p.m.
and from 1:00 p.m. to 5:00 p.m.; some trials may be scheduled to begin on Monday, following the
same schedule. Unless otherwise indicated by the Court, Counsel shall be present in the courtroom
one-half hour prior to the start of trial. There will be a break mid-morning and early afternoon and
a lunch break. This schedule is subject to the other demands of the docket. Counsel should plan
the availability of their witnesses accordingly so that trial can move expeditiously.
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C. Recesses
At each recess, outside the presence of the jury, counsel will be asked if there is anything
that should be raised before the next session. Counsel may not be able to anticipate everything,
but many matters should and will be taken up during the recesses.
D. Bench Trial
At least seven (7) days prior to trial the parties are required to submit a copy of the
proposed findings of fact and conclusions of law. The above documents must be in an editable
word processing format and sent by e-mail to Judge Beckering’s Judicial Assistant, Lauren
Packard at
[email protected] and Judge Beckering’s law clerk to whom the
case is assigned, either
[email protected] or
[email protected].
E. Submissions for Jury Trial
1. The parties shall jointly file by means of the Court’s CM/ECF system the following
not later than seven (7) days prior to the trial:
a. Joint proposed jury instructions. The parties shall electronically file one joint
set of instructions and shall make every reasonable effort to agree on the
substantive instructions stating the elements of the claims and defenses. This
Court uses Western District of Michigan’s Standardized Civil Jury
Instructions for the preliminary and final instructions. A copy of these
instructions is available on the Court’s website (www.miwd.uscourts.gov)
under For Attorneys/Civil Case Information. The Court generally uses
O’Malley, Grenig & Lee’s Federal Jury Practice and Instructions for those
not covered in the standard set.
(1) Each instruction shall be submitted in full text, one instruction per
page, in the order in which you propose they be given to the jury.
(2) For standard instructions with blanks or language in brackets, fill in
the blanks and modify or delete the language, as applicable.
(3) If you would like to change language on a standardized instruction,
or submit additional instructions, you must indicate the source of the
additional language or instruction.
(4) Indicate objections, if any, to opposing counsel’s proposed
instructions, with a summary of the reasons and legal authority for
each objection. Place each objection at the bottom of the specific
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instruction page. The parties must make every reasonable effort to
agree on the substantive instructions stating the elements of the
claim.
b. Joint proposed jury verdict form(s).
c. Counsel are required to submit exhibit lists and witness lists in an editable
word processing format by email to Judge Beckering’s Judicial Assistant,
Lauren Packard at
[email protected] and Judge
Beckering’s Case Manager, Rick Wolters at
[email protected].
2. In addition to being electronically filed, the parties are required to submit joint
proposed jury instructions, and joint proposed verdict forms(s) in an editable word
processing format by e-mail to Judge Beckering’s Judicial Assistant, Lauren Packard
at
[email protected] and Judge Beckering’s Case Manager, Rick
Wolters at
[email protected].
F. Jury Selection
1. Counsel and the parties shall be present in the courtroom at 8:30 a.m. to address any
preliminary matters.
2. The Court will seat a jury of 8 members, and all jurors shall participate in the verdict
subject to Fed. R. Civ. P. 47(c) and 48.
3. A jury will generally be selected as follows:
a. The courtroom clerk will call 8 people (by number) for the jury panel, and such
persons will be seated in the order they are called.
b. Voir dire will be conducted by both the Judge and the attorneys.
c. Attorney challenges for cause will be heard at side bar. The Court will excuse
any prospective juror for cause where appropriate, replace the excused juror, and
the process will be repeated.
d. When the Court has determined that none of the prospective jurors in the jury box
should be dismissed for cause, the parties may exercise their peremptory
challenges. See 28 U.S.C. §1870. Peremptory challenges will be exercised in
writing away from the jury, and the Court will then excuse all peremptorily-
challenged jurors.
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(1) In the first round of challenges, plaintiff’s counsel will exercise its
peremptory challenges first and defense counsel second.
(2) The challenged jurors will be replaced, and the process repeated in the same
manner except defense counsel will exercise its peremptory challenges first
during the second and all subsequent even-numbered rounds.
(3) The process repeats itself until there is a jury. Backstrikes are permitted.
(4) In a case with multiple parties, the Court may allow additional peremptory
challenges. See 28 U.S.C. §1870.
G. Witnesses
If a witness is not listed in the final pretrial order, then the Court will not allow either side to
call the non-listed witness unless there is good cause shown. This, of course, does not apply to
rebuttal witnesses. However, rebuttal experts must always be disclosed and listed in the final
pretrial order.
H. Exhibits
1. Six notebooks with the exhibits shall be prepared before trial. The exhibits should be
divided and tabbed with the exhibit numbers or letters. A list of the exhibits on a form
similar to Exhibit 1 attached to these Guidelines should be located in the front of the
notebooks. Three sets of notebooks shall be distributed to the Court, one set shall be
distributed to the jurors/witnesses, and there should be a set of notebooks to be used by
each party or counsel for the parties. Counsel is responsible for ensuring the accuracy of
the notebook ultimately provided to the jurors at the conclusion of trial. When bringing
a document to the attention of the Court and witnesses, counsel asking the questions
should refer to the notebook volume and exhibit number.
2. The exhibits shall be clearly identified. In cases where counsel wishes to publish the
exhibits to the jury, counsel shall arrange to have all exhibits digitized for projection on
the various monitors in the courtroom. Counsel planning to use the equipment are
required to contact the Court’s IT department well in advance of their court proceeding
to inquire about the equipment, training and practice sessions. Practice sessions and
testing of the equipment must occur prior to the day of a scheduled court appearance.
You may contact the Court’s IT department by sending an e-mail to
[email protected] or by calling (616) 456-2523. Information concerning the
features of the system are available at the court’s website: www.miwd.uscourts.gov (click
on Judges’ Info/Judge Jane M. Beckering/Courtroom Technology tab). Counsel is also
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required to notify Chambers – in advance of the hearing – of its intentions to use
technology resources in the courtroom and coordinate the date and time of any practice
sessions with Chambers.
3. If an exhibit has not been listed in the pretrial order, then it will not be admitted in the
case-in-chief unless good cause is shown as to why it was not designated. All exhibits,
charts, blow-ups, etc., must be shown to opposing counsel prior to the beginning of trial.
Do not wait until the witness is on the stand to show these items to opposing counsel.
4. Offer joint exhibits into evidence on the first day of trial for admittance. Additional
exhibits should be offered into evidence as soon as the foundation has been laid. Often,
when counsel waits until the end of the examination or the case to make the offer, the
witness has completely discussed the document during testimony and the document is
not in evidence.
5. Offer exhibits that have identical foundation requirements in a group. It wastes time to
lay a separate foundation on several identical kinds of documents, showing the witness
one at a time. If they are all the same type of document, show the witness exhibits 1
through 10, ask the witness to identify the exhibits and lay a foundation (e.g., checking
account statements of John Doe for the months January through June 2001). If the parties
have stipulated to the admissibility of exhibits before trial, then those exhibits will be
admitted as a group after opening statements and before the first witness is called. These
stipulated exhibits can then be referenced without the necessity of establishing a
foundation.
I. Deposition Designations and Motions in Limine
Deposition designations must be filed prior to the final pretrial conference. Counsel must
confer in good faith to resolve the disputed motions in limine before filing. Motions in Limine
must be filed by the deadline set forth in the case management order. The Court will not entertain
additional motions in limine or deposition designations unless good cause is shown.
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ATTACHMENT 1 - EXHIBIT LIST
Exhibit Description Offered By Objection Date Date
No./Letter Offered Received
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