(a) Contents

Final pretrial statements shall be filed in accordance with Fed. R. Civ. P. 26(a)(3) and, in addition to the requirements of that rule, shall contain:

(1) a brief statement of the case assented to by all parties, except assent shall not be required in cases in which one or more of the parties is an incarcerated pro se litigant;

(2) the name of each witness, separately identifying those whom the party expects to present and those whom the party may call if the need arises, and the parties shall simultaneously exchange between themselves the address and telephone number for each listed witness;

(3) a written waiver of claims or defenses, if any;

(4) a list of all depositions which may be read into evidence, with page/line designations filed ten (10) days prior to trial, counter-designations filed five (5) days prior to trial, and objections filed two (2) days prior to trial;

(5) a list of all exhibits to be offered at trial separately identifying those which the party expects to offer and those which the party may offer if the need arises.  Exhibits intended to be used solely for impeachment need not be listed;

(6) a statement confirming that the parties have met and conferred on whether they intend to have the jury use the Jury Evidence Recording System (JERS) to review evidence and their respective positions on the use of JERS;

(7) an itemized statement of special damages;

(8) except in actions tried without a jury, a statement of the latest demand and offer, and a statement describing the parties' participation in any alternative dispute resolution process;

(9) a statement of a claim for attorney's fees, if applicable, with citation to the statutory and/or regulatory authorities relied upon as the basis for the claim;

(10) any requests for a view pursuant to LR 39.3, and a designation as to who shall pay the cost of the view in the first instance; and

(11) an estimate of the length of trial.