Greetings!

Please allow this memo to serve as my instructions and/or suggestions for your pre-trial conference to be held on [trial date].

At pre-trial you’ll be dealing with motions in limine, witness lists, deposition designations and, of course, exhibits. The Court prefers that both sides exchange and discuss these items prior to the hearing and see what agreements can be reached.

Please provide a copy of the witness and exhibit lists to the court reporter upon arrival to pre-trial.

EXHIBITS:

Please pre-mark all exhibits with stickers and use numbers.

(No letters please).

Once an exhibit has been offered, whether admitted or not, it becomes a part of the record and must be submitted to the reporter.

All exhibits, once offered, are to be put on the reporter’s desk and must remain there. If you use an exhibit with a witness, return it to the reporter’s desk and not to counsel’s table.

You will be going on the record at the conclusion of the trial to verify all the admitted exhibits prior to them being sent back to the jury.

DEPOSITIONS:

If deposition testimony is going to be offered, provide the reporter with either the complete transcript with the page/line designations, or the designations themselves.

REALTIME: If you think you may want daily copy or rough drafts, please alert the reporter as soon possible. My contact info is: Minnie.cadena@gmail.com or Minnie_cadena@justex.net.

My direct line to my office is 832-927-2655.

See you at pre-trial!