Pre-Trial Statement / Report

Draft a court-compliant pre-trial statement that narrows issues and provides the trial roadmap.

Quick Start

Gather before drafting:

1. Local rules / judge order — controls required sections and format.
2. Case posture — claims, defenses, key rulings.
3. Stipulated facts — agreed wording from opposing counsel (if joint).
4. Contested issues — law and fact, aligned to trial themes.
5. Witness disclosures and expert reports.
6. Exhibit inventory — Bates numbers, exhibit IDs.
7. Trial management inputs — length, jury/bench, motions in limine status.

Document Structure

1. Caption + Title
2. Introductory paragraph (filing type, governing order)
3. Stipulated Facts
4. Contested Issues of Law
5. Contested Issues of Fact
6. Witness List
7. Exhibit List
8. Procedural / Trial Management Matters
9. Signature block(s) per local rule

Section Details

Stipulated Facts

One fact per number; use verbatim agreed wording. Non-argumentative only.

| No. | Stipulated Fact (verbatim) | Source / Record Cite | Notes | |---|---|---|---|

Contested Issues of Law

Frame each as a discrete question the court must decide.

| No. | Legal Issue (question) | Authority | Impact on Trial | |---|---|---|---|

Phrasing patterns:

• "Whether [legal standard] applies to [claim/defense] where [key fact]…"
• "Whether [doctrine] bars [claim] given [contract/statute]…"

Contested Issues of Fact

State neutrally at meaningful granularity.

| No. | Factual Issue (neutral) | Key Evidence Sources | Notes | |---|---|---|---|

Phrasing patterns:

• "Whether [party] represented [fact] on [date]."
• "Whether [event] caused [harm/damages]."

Witness List

Only properly disclosed witnesses; flag proposed additions.

| Order | Witness Name | Type (Fact/Expert) | City/State | Subject of Testimony | Disclosure / Report | |---|---|---|---|---|---|

Exhibit List

Follow local numbering convention and joint numbering rules.

| Exh No. | Description | Bates / ID | Offered By | Objection / Stipulation | |---|---|---|---|---|

Procedural / Trial Management Matters

Include only items required by local rule or judge order:

• Trial type (jury/bench) and estimated length
• Damages categories and amounts (if required)
• Motions in limine list and status
• Deposition designations and counter-designations
• Technology / courtroom needs
• Proposed jury instructions or verdict form issues (if required)
• Bifurcation / sequencing proposals
• ADR history or settlement status (if allowed by rule)

Signature Block

Include counsel signatures per local rule. If joint, include all parties.

Pitfalls & Checks

• Local rules and judge orders are controlling authority — verify required sections and format before drafting.
• Never concede contested elements in stipulated facts or issue framing.
• Stipulated facts must be purely factual, actually agreed, and non-argumentative.
• Align issues with claims/defenses and anticipated jury instructions.
• Verify every witness and exhibit is properly disclosed; flag gaps.
• Maintain consistent numbering and labels throughout.
• Confirm page limits, font, spacing, and header/footer requirements.
• Flag missing inputs or unresolved joint wording for attorney review.

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