Judge Tanya S. Chutkan

Absent agreement of the parties or Order of the Court to the contrary, the parties shall be limited to no more than ten (10) depositions and no more than twenty-five (25) interrogatories per side.

one omnibus motion per side of not more than twenty (20) pages raising all issues in limine shall be filed with the court and served on opposing counsel no later than [Date]

oppositions of not more than fifteen (15) pages shall be due not later than [Date]

oppositions of not more than fifteen (15) pages shall be due not later than [Date].

All evidence that a party plans to offer at trial under Fed. R. Evid. 404(b) must be disclosed to all other parties by no later than [Date]. Motions in limine should be fully briefed at the time of filing of the parties’ Joint Pretrial Statement. Accordingly, one omnibus motion per side of not more than twenty (20) pages raising all issues in limine shall be filed with the court and served on opposing counsel no later than [Date]; oppositions of not more than fifteen (15) pages shall be due not later than [Date]. A party may not file a reply without first requesting leave of the court.

The Joint Pretrial Statement shall be double-spaced, in 12-point Times New Roman font, in Microsoft Word format, with margins of no less than one (1) inch.

No exhibit will be admitted at trial unless it is listed on the Joint Pretrial Statement. Each listed exhibit will be presumed authentic and admissible at trial unless a written objection specifying the specific basis of the objection is made in the Joint Pretrial Statement. If there are objections to an exhibit listed in the Joint Pretrial Statement, the exhibit shall be produced at the time the Joint Pretrial Statement is submitted. Two copies of the challenged exhibits shall be submitted to the court in separate three ring

the proposed instructions shall be formatted so that each individual instruction begins a new page

The Joint Pretrial Statement shall be double-spaced, in 12-point Times New Roman font, in Microsoft Word format, with margins of no less than one (1) inch.

A Pretrial Conference will be held at [TIME] on [DATE], in Courtroom 9. Counsel are instructed that individuals with settlement authority must be present or available by telephone during the pretrial conference.

Prior to the pretrial conference the parties shall meet and confer for the purpose of preparing the Joint Pretrial Statement and discussing the prospects for settlement. To the extent possible, the parties shall conduct a face-to-face meeting. The parties are directed to confer in good faith and Counsel for Plaintiff shall file a Joint Pretrial Statement pursuant to Local Civil

Failure to comply with the requirements and deadlines established in this Pretrial Order may result in sanctions including, but not limited to, fines payable to the Clerk of the Court, a court order striking untimely or non-compliant pretrial submissions and pleadings, dismissal of claims/defenses, and/or public admonishment of counsel. See Fed. R. Civ. P. 16(f); Fed. R. Civ. P. 37(b)(2)(A)(ii)–(vii); Gregory P. Joseph, Sanctions: The Federal Law of Litigation Abuse 598 (5th ed. 2013) (“The primary purpose for imposing Rule 16(f) sanctions is deterrent: to insure expeditious and sound management of the preparation of cases for trial. Secondarily, sanctions are awarded to compensate parties for inconvenience and expense incurred because of an opponent's noncompliance.”).

No party may call at trial any witness the party has not listed in the Joint Pretrial Statement (except those called for impeachment purposes).

If there are objections to an exhibit listed in the Joint Pretrial Statement, the exhibit shall be produced at the time the Joint Pretrial Statement is submitted. Two copies of the challenged exhibits shall be submitted to the court in separate three ring

No exhibit will be admitted at trial unless it is listed on the Joint Pretrial Statement.

No party may call at trial any witness the party has not listed in the Joint Pretrial Statement (except those called for impeachment purposes).

Objections not disclosed in the Joint Pretrial Statement, except those pursuant to Fed. R. Evid. 402 and 403, shall be deemed waived, unless such failure to timely object is excused by the court for good cause shown.

Describe all demonstrative, physical and/or videotape evidence that will be used at trial. Such evidence listed in the Joint Pretrial Statement shall be deemed potentially admissible at trial, unless an objection is made in the Joint Pretrial Statement, along with the specific basis for the objection and supporting legal authority.

Identify each deposition or portion thereof, by page and line numbers, that the party intends to offer in evidence. All cross-designations under Fed. R. Evid. 106 must be identified as well.

Designated or cross-designated deposition testimony will be deemed potentially admissible at trial, unless an objection is made in the Joint Pretrial Statement. The objecting party must note the basis for the objection, as well as provide supporting authority.

Each party that anticipates offering more than five (5) exhibits as substantive evidence shall pre-mark such exhibits in advance of trial, using exhibit labels and lists available from the Clerk of the Court. The court will provide up to 100 labels; if a party needs more labels, that party must use labels of the same type as those supplied by the court.

Any objections to deposition testimony shall be accompanied by excerpts from the depositions, including the testimony to which the objection relates.

Set forth separately each element of damages and the monetary amount claimed (including prejudgment interest, punitive damages, and attorney’s fees). Do not include amounts claimed for intangible damages. Set forth all other types of relief sought against any party.

In non-jury cases, the parties must submit detailed proposed findings of fact and conclusions of law with supporting authorities.

Any objections shall be listed immediately following the voir dire question, jury instruction, or verdict question. The objecting party shall specifically identify the objectionable portion of the voir dire question, instruction, or verdict form, along with the basis of the objection and citations to supporting legal authority. Any objections to the verdict form shall be accompanied by a proposed alternative form.

List the number of days estimated for trial, and set forth any scheduling problems with witnesses.

In jury cases, the parties also must submit (b) Any objections or proposed additions to Judge Chutkan’s standard voir dire, including i. the voir dire questions on which the parties agree; and ii. the voir dire questions on which the parties disagree, with specific objections noted below each disputed question and supporting legal authority (if any);

In jury cases, the parties also must submit (d) a proposed verdict form, as well as proposed special interrogatories (if any), that includes a date and signature line for the jury foreperson.

In jury cases, the parties also must submit (a) Any waiver of a jury trial;

In non-jury cases, the parties must submit detailed proposed findings of fact and conclusions of law with supporting authorities.

In jury cases, the parties also must submit (c) A list of proposed jury instructions, followed by the text of each proposed instruction, as well as the specific source and citation for the proposed instructions (e.g., Standardized Civil Jury Instruction for the District of Columbia 2.01: Evidence in the Case) or, for modified or new instructions, specific supporting legal authority. Any variations or alterations of standard jury instructions shall be so noted and the proposed instructions shall be formatted so that each individual instruction begins a new page. Additionally, the parties shall indicate i. the instructions on which the parties agree; and ii. the instructions on which the parties disagree, with specific objections noted below each disputed instruction and supporting legal authority (if any);

In jury cases, the parties also must submit (a) Any waiver of a jury trial; (b) Any objections or proposed additions to Judge Chutkan's standard voir dire... (c) A list of proposed jury instructions... (d) a proposed verdict form

In accordance with Local Civil Rule 16.5(b), the Joint Pretrial Statement must include the following: 1. Parties and Counsel: List names, addresses, and telephone numbers of all counsel on whose behalf the Joint Pretrial Statement is filed. In addition, provide the names of lead counsel who intend to try the case. List names and addresses of all parties.