PRE-TRIAL (CIV)

COUNSEL (APPEARANCE): GOOD MORNING/AFTERNOON, YOUR HONOR. ATTY.

______, RESPECTFULLY APPEARING FOR THE PLAINTIFF/DEFENDANT.
JUDGE: READY FOR PRE-TRIAL?
COUNSEL: YES, YOUR HONOR
JUDGE: STIPULATIONS, COUNSEL?
COUNSEL: WE PROPOSE FOR THE FOLLOWING STIPULATIONS *FOLLOW PRE-TRIAL
BRIEF*
(IT WILL BE DENIED BY THE OPPOSING COUNSEL. OPPOSING COUNSEL
WILL BE ASKED FOR THEIR STIPULATIONS. LIKEWISE, DENY THE SAME.
IF ASKED, “WE MAINTAIN THE STIPULATION OF FACTS AS STATED IN
OUR COMPLAINT”)
JUDGE: WHAT IS/ARE YOUR ISSUE/S?
COUNSEL: *FOLLOW PRE-TRIAL BRIEF*
JUDGE: DOCUMENTARY EXHIBITS?
COUNSEL: *FOLLOW PRE-TRIAL BRIEF* “WE ARE ADOPTING THE DOCUMENTARY
EXHIBITS WHICH IS STATED IN THE PRE-TRIAL BRIEF”
(IF NO ORIGINALS ON HAND OR IF DOCUMENTARY EXHIBITS ARE
VOLUMINOUS – “IN RELATION TO THE DOCUMENTARY EXHIBITS, MAY WE
RESPECTFULLY REQUEST FOR A DIFFERENT SETTING FOR PRE-
MARKING.”)
(ONLY MAKE RESERVATION FOR DOCUMENTARY EXHIBITS IF READILY
IDENTIFIABLE)
JUDGE: WITNESS/ES?
COUNSEL: WE WOULD LIKE TO PRESENT *NAME OF WITNESS* AS OUR WITNESS.
(ONLY MAKE RESERVATION FOR WITNESSES IF READILY IDENTIFIABLE,
E.G. “A WITNESS COMING FROM THE ACCOUNTING DEPARTMENT OF THE
PLAINTIFF/DEFENDANT”)
JUDGE: *WILL SET TRIAL DATES*
END