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The purpose of a trial memorandum is to assist the court at trial. Among other things, a trial memo might include: An outline of the important facts and how those facts support your claims. A list of the claims for relief you included in your pleadings and the damages being sought for each claim.
WITNESS LIST The Pretrial Catalogue shall contain a list of witnesses to be called at trial. This includes rebuttal and impeachment witnesses who, in the exercise of diligent pretrial preparation, you should know might be called. Expert witnesses shall be so specified.
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