United States District Court, D. Maryland
MEMORANDUM TO COUNSEL
W. Grimm United States District Judge
memorandum confirms the trial date that has been set in this
case and it provides the schedule for this case and certain
instructions relating to trial preparation.
Thursday, January 12, 2017
Deadline for Motions in Limine
Thursday, January 19, 2017
Deadline for Responses to Motions in Limine
Thursday, February 2, 2017
Deadline for submitting Joint Pretrial Order; Joint
Proposed Voir Dire Questions, Jury Instructions, and
Special Verdict Forms; and any Unagreed Proposed Voir
Dire Questions, Jury Instructions, and Special
Thursday, February 23, 2017 at 1:00 PM
Tuesday, March 14, 2017 at 9:00 AM
Tuesday, March 21, 2017
Four-Day Jury Trial to Begin.
pretrial order must comply with all provisions of Local Rule
106. The purpose of this proposed order is to summarize what
is established and what needs to be resolved at trial. The
proposed pretrial order shall include final stipulations, or
requests for stipulations, of specific facts, which include
the legal theories relied upon in each claim and defense.
See Loc. R. 106.2(f). With regard to evidence, the
proposed pretrial order must include a detailed list of
“exhibits the parties agree may be offered in evidence
without the usual authentication.” Loc. R. 106.2(h).
The list of documents should be detailed and include each
document by title. The list of witnesses must satisfy Local
Rule 106.2(i). For depositions under Fed.R.Civ.P. 32, the
parties shall include “[a] list of the pages and/or
lines of any portion of a deposition to be offered in a
party's case in chief or any counter-designations.”
Loc. R. 106.2(k). If the parties do not plan to use
depositions in their cases in chief, they may indicate the
same and reserve the right to use depositions for
impeachment. The parties will indicate their agreement, or
lack thereof, as to admissibility of each document and any
testimony to be presented as evidence. See Loc. R.
106.2(g), (1), (m).
addition to the information required by Local Rule 106.2(j),
the pretrial order shall include for each party a concise
summary of the opinion testimony expected from each witness
identified by that party pursuant to Fed.R.Civ.P. 26(a)(2)(A)
and (B) who may testify at trial. See Loc. R.
106.2(m). The parties shall identify those witnesses
designated pursuant to Rule 26(a)(2)(A) separately from those
designated pursuant to Rule 26(a)(2)(B).
in Limine and Responses in Opposition should be submitted in
informal letters of no more than three pages, single-spaced,
for each discreet evidentiary issue.
Dire, Jury Instructions, and Verdict Forms
should submit proposed joint voir dire questions, proposed
joint jury instructions on issues specifically relating to
this case, and a proposed joint special verdict
form. You may
submit separately any voir dire questions, jury instructions,
and special verdict forms upon which you cannot agree.
However, it is expected that counsel will be able to reach
agreement as to the vast majority of the jury instructions.
In this regard, you should be guided by the applicable
pattern instructions. All of your proposed voir dire
questions, jury instructions, special verdict forms, and
proposed pretrial order should be filed electronically via
the CM/ECF system, submitted in hard copy to my Chambers, and
emailed, as Microsoft Word documents, to chambers at
proposed joint voir dire should include a brief proposed
statement to be read to the venire panel explaining the
nature of the case in general terms.
proposed jury instructions should (a) be typed one per page;
(b) be numbered and assembled in the order in which you
request that they be read to the jury; and (c) include a
citation of the authorities supporting the instruction. Any
request for an instruction ordinarily should be based on the
pattern Modern Federal Jury Instructions,  or where Maryland law is
applicable, on the Maryland Pattern Jury Instructions.
Submissions should be in Microsoft Word format with the
changes or modifications made using the “Track
emergency circumstances, a party will guarantee the presence
at trial of any witness that party lists in the pretrial
order, in accordance with Local Rule ...