Michael McMahon

Unless a rule or statute provides otherwise, file and serve documents, briefs, proposed orders, proposed judgments, and other communications before presenting them to the court.

no document, including briefs, proposed orders and proposed judgments, or other communications, may be presented to the court at any time unless it is first filed with the court and served on all parties.

Unless the court orders otherwise, expect a pretrial conference in every contested civil case.

Unless otherwise ordered by the court, a pre-trial conference shall be held in all contested civil cases.

No later than seven days before the pretrial conference, the plaintiff must convene all parties to prepare the proposed pretrial order and present it for signature at the conference.

Not later than seven days prior to the pre-trial conference, Plaintiff shall convene a conference of all parties for the purpose of preparing a pre-trial order.

Identify each trial exhibit and any objection in the pretrial order. An exhibit offered at trial without a stated pretrial-order objection will be admitted.

Any exhibit offered at the trial to which no objection was made in the pre-trial order will be admitted into evidence.

Every exhibit filed or offered in evidence remains in the clerk's custody unless the court orders a copy substituted or permits withdrawal.

Every exhibit placed on file or offered in evidence shall be held in the custody of the clerk.

List in the pretrial order the witnesses who may be called, except rebuttal witnesses.

The following witnesses and no others will (may) be called to testify except on rebuttal.

Deliver proposed jury instructions and verdict forms to the court in duplicate, and serve every opposing party, at the time fixed in the pretrial order.

All proposed jury instructions and verdict forms must be delivered to the court in duplicate and a copy served upon all opposing parties at the time fixed in the pre-trial order.

Identify each proposed jury instruction's source and cite supporting authority at the bottom.

Each proposed instruction shall identify at the bottom its source and cite supporting authorities, if any.

Unless the court orders otherwise, file and serve proposed findings of fact and conclusions of law at least seven days before a trial or hearing where Rule 52 requires them.

all parties shall file with the court, and serve upon all opposing parties, at least seven days prior to the scheduled trial or hearing, proposed findings of fact and conclusions of law.