Pre trial memorandum child custody example 2026

1. Click ‘Get Form’ to open the pre trial memorandum in the editor.
2. Begin by filling in the caption and docket number at the top of the form. This information is crucial for identifying your case.
3. Enter your name and attorney’s name in the designated fields, followed by the judge's name and the date of the pre-trial.
4. List all parties involved in the action along with their counsel. Ensure accuracy to avoid any confusion during proceedings.
5. Indicate whether a jury trial has been demanded by checking 'Yes' or 'No', and specify the number of jurors requested.
6. Detail any anticipated scheduling problems that may arise during the trial process.
7. Provide an estimated time required for trial, which helps in planning court schedules.
8. Write a brief narrative statement outlining your version of the case, attaching any diagrams that may assist in clarifying your position.
9. List your legal theories of liability, ensuring you include all relevant theories you plan to rely on during trial.
10. If applicable, outline any counterclaims and associated damages clearly.
11. Specify whether there is a written or oral agreement involved, quoting key provisions central to your dispute.
12. Enumerate types and amounts of damages claimed, providing clarity on what you seek from this action.
13. List names of witnesses along with their expected scope of testimony regarding liability or damages.
14. Identify expert witnesses by name and specialty, attaching all relevant expert reports for reference.
15. Document all exhibits intended for presentation, noting if they have been shared with opposing counsel and detailing any technological equipment needed for their presentation.
16. Outline any requested stipulations regarding qualifications of experts or admissibility of documents without custodianship.
17. Mention any unusual legal issues that may require trial briefs for clarification.
18. List outstanding motions that are pending resolution before proceeding further with your case.
19. Include any miscellaneous matters that are important but not covered elsewhere in this memorandum.

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