Trial Scheduling Orders 
AudioVisual Equipment
Jury Instructions
Trial Memos

  • Trial Scheduling Orders

For some but not all trials, I will issue a trial scheduling order at the time the trial is set. If you receive a trial scheduling order, please review it carefully and comply with all time deadlines. If you have not received a trial scheduling order, and you have questions about when something needs to be filed, please feel free to contact my staff.

  • Audivisual Equipment

My courtroom has audiovisual equipment which will permit a laptop to be connected to a projector to display documents, photographs, and videos. If you wish to use the equipment, please contact my staff. They will assist you in working with our technical staff to review the use of the equipment with you and ensure that it is working properly before your trial or hearing.

  •  Exhibits

Please pre-mark your exhibits. Multi-page exhibits should have each page marked (IE, Exhibit 5, page 2). In addition to the original exhibits, bring a bench copy, a copy for opposing counsel, and a witness copy (plus a copy for you). Please speak to opposing counsel or the opposing party and stipulate in whatever exhibits you can; this will speed things up. I then prefer to hear any objections to those exhibits which have not been stipulated at the time a foundation is laid and the exhibit is offered. In jury trials it is very helpful to have an enlarged copy of photos or documents; or means to project them; otherwise either the jurors have no idea what you are talking about, or the trial stops while 12 jurors pass around a 4 x 6 photo. However note that no exhibit should be displayed to the jury until it has been admitted into evidence.

  • Jury Instructions

Criminal cases: I need the list of uniform instructions that you are requesting; morning of trial is fine. If you are requesting any special (non-uniform) instructions, please bring a hard copy and email the special instruction in Microsoft Word format to my staff . The electronic format of any non-uniform instructions should be jury-ready — with all variables (EG he/she, date of incident etc) filled out; no citations of authority; no commentary to the instructions; and nothing identifying which party submitted them.

Civil cases: Please provide the following:

1) For the file, list of uniform instructions you are requesting plus full text of any specials, on your pleading paper. For attorneys, this now needs to be efiled through Odyssey.

2) In electronic format (Microsoft Word), full jury ready text of all your requested instructions. This means, include full text of both uniform and special instructions, with all variables (EG he/she, date of incident etc) filled out. There should be no citations of authority, no commentary to the instructions, and nothing identifying which party submitted them (although it helps us if your filename shows who submitted them). Please combine all your requested instructions into one document and email them to my staff.

For the uniform introductory instruction (5.00), I would prefer that counsel agree on the summary of each side’s claims and the summary of the pleadings. If you cannot agree, I would like each side to e-mail theirs by noon the day before trial and I will make the final decision on the summary. The summary in the introductory instruction should be brief, describing the general nature of the case rather than all of the claims and defenses; EG: “This case involves an automobile accident in which plaintiff alleges that defendant negligently rear-ended her; defendant alleges that plaintiff was partly at fault in the accident and that some of her medical treatment relates to a prior injury rather than this accident.”

The uniform instructions assume that in between 13.01 and 13.02, (“Summary of Pleadings Not Evidence”) the jury has just been given a summary of pleadings. Please provide me that summary for your pleadings, again in electronic as well as paper format. This needs to be more detailed than the general summary described above with regard to the introduction; the issues the jury is required to determine are framed by the scope of the pleadings (for example, in a negligence claim the jury must determine if the defendant was negligent in a manner alleged in the plaintiff’s complaint; therefore, the jury must know what the allegations of negligence were).

  • Trial Memos

I usually do not require trial memoranda, but I am always happy to get them. However, if you want me to read them you need to get them to me in advance of the trial. Unless you have been given a different deadline or there is a different deadline in your trial scheduling order, please submit them to my chambers no later than noon the day before trial. Again, note that e-filing the document through Odyssey will not necessarily ensure that it reaches my chambers. Please email or hand-deliver a bench copy.