What else should be discussed before trial?
Items to be finalized no later than a week before trial include: • General stipulations • Whether a lesser number of jurors will be used • Whether the judge will be present for voir dire • Civil voir dire standards • Submission of proposed jury instructions • Submission of request for special findings (for bench trials, suggest that parties submit proposed findings and conclusions in lieu of a brief to reduce the amount of rhetoric in pretrial filings) • Confirmation of time estimate • How time will be recorded and enforced • Pre-marking of exhibits • Whether to waive reporter • Court hours
