FINAL JOINT PRETRIAL ORDER. This matter is before the Court on a Final Pretrial Conference pursuant to R. 4:25-1.

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1 SUPERIOR COURT OF NEW JERSEY MIDDLESEX COUNTY:LAW DIVISION Docket No. Plaintiff(s), v. Defendant(s). FINAL JOINT PRETRIAL ORDER This matter is before the Court on a Final Pretrial Conference pursuant to R. 4:25-1. This Final Joint Pretrial Order shall govern the conduct of the trial in this case and amendments will be allowed only in exceptional circumstances to prevent manifest injustice. The parties are to confer in person as to the preparation and requirements of this Final Joint Pretrial Order and are to make a good faith effort to resolve all issues. Trial Counsel shall appear at the Final Pretrial conference. The provisions of R.4:25-1(b)(14) shall apply. I. APPEARANCES A. Plaintiff(s) (Designate Trial Counsel): B. Defendant(s) (Designate Trial Counsel): 1

2 II. STATEMENT OF THE NATURE OF THE ACTION (This statement will be read to the jury to briefly describe the nature of the action.) III. ADMISSIONS AND STIPULATIONS (The admissions and stipulations may be read to the jury by the Court or any party.) IV. FACTUAL AND LEGAL CONTENTIONS OF PLAINTIFF(S) AS TO LIABILITY OF DEFENDANT(S) V. FACTUAL AND LEGAL CONTENTIONS OF DEFENDANT(S) AS TO NON-LIABILITY AND AFFIRMATIVE DEFENSES VI. PLAINTIFF(S) STATEMENT OF THE NATURE OF THE DAMAGES VII. STATEMENT OF THE LEGAL ISSUES PRESENTED VIII. PLAINTIFF(S) WITNESSES (Separately identify each witness who (a) will or (b) may be called to testify with a brief description of the subject matter of the testimony. State whether the witness will testify in person, by way of deposition or by way of video conferencing. As to each witness, Defendant is to state whether there is any objection generally (and the grounds therefore) to the witness testifying.) IX. DEFENDANT(S) WITNESSES (Separately identify each witness who (a) will or (b) may be called to testify with a brief description of the subject matter of the testimony. State whether the witness will testify in person, by way of deposition or by way of video conferencing. As to each witness, Plaintiff is to state whether there is any objection generally (and the grounds therefore) to the witness testifying.) 2

3 X. PLAINTIFF(S) EXPERT WITNESSES (Separately identify each expert witness who (a) will or (b) may be called to testify with a brief description of the subject matter of the testimony. State whether the expert witness will testify in person, by way of deposition or by way of video conferencing. As to each expert witness, Defendant is to state whether there is any objection generally (and the grounds therefore) to the expert witness testifying.) XI. DEFENDANT(S) EXPERT WITNESSES (Separately identify each expert witness who (a) will or (b) may be called to testify with a brief description of the subject matter of the testimony. State whether the expert witness will testify in person, by way of deposition or by way of video conferencing. As to each expert witness, Plaintiff is to state whether there is any objection generally (and the grounds therefore) to the expert witness testifying.) XII. PLAINTIFF(S) EXHIBIT LIST (Separately identify each exhibit that (a) will or (b) may be offered at trial. Each Exhibit is to be numbered and pre-marked. A brief description of each exhibit is to be set forth. Defendant is to set forth any objection (and the grounds therefore) to the (1) authenticity of the document and (2) its admission into evidence.) XIII. DEFENDANT(S) EXHIBIT LIST (Separately identify each exhibit that (a) will or (b) may be offered at trial. Each Exhibit is to be numbered and premarked. A brief description of each exhibit is to be set forth. Plaintiff is to set forth any objection (and the grounds therefore) to the (1) authenticity of the document and (2) its admission into evidence.) XIV. DEPOSITION AND DISCOVERY EXCERPTS TO BE USED AS EVIDENCE (Each deposition and discovery excerpt is to be specifically identified: as to deposition excerpts, the parties are to comply with R.4:16-1(d).) A. PLAINTIFF (Defendant is to set forth any objection and the grounds B. DEFENDANT (Plaintiff is to set forth any objection and the grounds 3

4 XV. DEMONSTRATIVE EXHIBITS (Demonstrative exhibits are to be made available for review or specifically described. Each demonstrative exhibit is to be separately set forth.) A. PLAINTIFF (Defendant is to set forth any objection and the grounds B. DEFENDANT (Plaintiff is to set forth any objection and the grounds XVI. VOIR DIRE JURY QUESTIONNAIRE (To be attached) XVII. JURY INSTRUCTIONS (To be attached) XVIII. JURY QUESTIONS (To be attached) XIX. PLAINTIFF(S) IN LIMINE MOTIONS (Each issue shall be separately set forth with a brief description of the subject matter of the motion) XX. DEFENDANT(S) IN LIMINE MOTIONS (Each issue shall be separately set forth with a brief description of the subject matter of the motion) XXI. MISCELLANEOUS A. The jury (may/may not) take notes. B. The jury (may/may not) ask questions. C. The number of jurors on the panel shall be six with alternates. D. The estimated length of the trial is days. E. Further scheduling as to any pretrial issues is as follows: F. The trial date is:. G. Trial Briefs on the following issues shall be filed and served on : 4

5 Dated: ANN G. McCORMICK, J.S.C. Attorney for Plaintiff(s) Attorney for Defendant Attorney for Defendant 5

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