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 provides the schedule for this case and certain
instructions relating to trial preparation.
January 16, 2017 Deadline for submitting Joint Pretrial
Order; Joint Proposed Voir Dire Questions, Jury Instructions,
and Special Verdict Forms; Unagreed Proposed Voir Dire
Questions, Jury Instructions, and Special Verdict Forms; and
Motions in Limine
January 30, 2017 Deadline for submission of Responses in
Opposition to Motions in Limine
February 6, 2017 Pretrial Conference at 1:30PM
March 7, 2017 Jury Selection and Beginning of Four-Day Trial
at 9:00 AM
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).
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 email@example.com.
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, on the Maryland Pattern Jury Instructions.
Submissions should be in Microsoft Word format with the
changes or modifications made using the “Track