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Jimoh v. Costco Wholesale Corp.

United States District Court, D. Maryland

October 24, 2016

Jimoh
v.
Costco Wholesale Corporation

          MEMORANDUM TO COUNSEL

          Paul W. Grimm United States District Judge.

         This 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.

         Monday, 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

         Monday, January 30, 2017 Deadline for submission of Responses in Opposition to Motions in Limine

         Monday, February 6, 2017 Pretrial Conference at 1:30PM

         Tuesday, March 7, 2017 Jury Selection and Beginning of Four-Day Trial at 9:00 AM

         Proposed Pretrial Order

         The 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).

         In 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).

         Voir Dire, Jury Instructions, and Verdict Forms

         You 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.[1] 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 mddpwgchambers@mdd.uscourts.gov.

         Your 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.

         Your 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, [2] 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 Changes” function.

         Motions ...


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