Attorneys and pro se litigants shall consult the pretrial practices and procedures of the
judge to whom their case is assigned.
In every case scheduled for trial, as a minimum requirement, counsel must file a pre-trial
memorandum that sets forth a factual summary of the case, the parties’ respective claims
and defenses, the relief sought, and a list of witnesses and exhibits to be used or
introduced into evidence. Failure to do so can result in the imposition of sanctions,
including the preclusion of witnesses or evidence.
In a jury trial, counsel must submit proposed instructions no later than the
commencement of trial, unless otherwise ordered by the court, and failure to do so can
constitute waiver of a claim, defense, or legal position.
