(b) Documents to Accompany Final Pretrial Statements

The following documents shall be filed simultaneously as separate documents with each party's final pretrial statement:

(1) Requests for Jury Instructions

Requested jury instructions shall cover the elements of all claims and defenses raised in the case and any unusual issues that may arise in the case that will warrant a special instruction.  Instructions such as the role of the jury, evaluating witness credibility, burden of proof, and other instructions routinely given by the court are not to be included.  Parties may file supplemental requests at the close of the evidence or at such earlier time during trial as the court reasonably directs.

(2) Trial Memoranda and Requests for Findings of Fact and Rulings of Law

In all actions tried upon the facts without a jury or with an advisory jury, the parties shall file memoranda of law and requests for findings of fact and rulings of law with their final pretrial statements.  The parties may file supplemental requests and/or further memoranda at such time as the court directs.  

Requests for findings of fact shall concern only facts that are genuinely disputed and material to the outcome of the case.  Such requests shall be set forth in chronological order in separately numbered paragraphs.  Proposed rulings of law shall be set forth in separately numbered paragraphs and contain brief citations to supporting authority.

(3) Motions in Limine

(4) Voir Dire Requests

(5) Proof of Special Damages

The defendant shall notify the plaintiff if it requires testimonial proof of special damages.

(6) Use of JERS

To the extent at least one but not all parties would like to present evidence electronically to the jury during deliberations using the Jury Evidence Recording System (JERS), the party who desires to use JERS shall file a motion requesting leave to do so.