At the pre trial conference, or prior to that day if specified in the pre trial calendar, counsel for each party shall have prepared and shall file with the court a proposed pre trial order in substantially the following form:
IN THE SUPERIOR COURT OF _____ COUNTY
STATE OF GEORGIA
CIVIL ACTION, CASE NO. ______
(STYLE OF CASE)
PRE TRIAL ORDER
The following constitutes a Pre Trial Order entered in the above styled case after conference with counsel for the parties:
(1) The name, address and phone number of the attorneys who will conduct the trial are as follows:
Plaintiff _____________________
Defendant _____________________
Other _____________________
(2) The estimated time required for trial is __________________________
(3) There are no motions or other matters pending for consideration by the court except as follows:_____________________
_____________________
(4) The jury will be qualified as to relationship with the following:
(5)a. All discovery has been completed, unless otherwise noted, and the court will not consider any further motions to compel discovery except for good cause shown. The parties, however, shall be permitted to take depositions of any person(s) for the preservation of evidence for use at trial.
b. Unless otherwise noted, the names of the parties as shown in the caption to this order are correct and complete and there is no question by any party as to the misjoinder or nonjoinder of any parties.
(6) The following is the Plaintiff’s brief and succinct outline of the case and contentions: (USE SPACE AS NEEDED)
__________________________________________
__________________________________________
(7) The following is the Defendant’s brief and succinct outline of the case and contentions: (USE SPACE AS NEEDED)
__________________________________________
__________________________________________
(8) The issues for determination by the jury are as follows:
__________________________________________
__________________________________________
(9) Specifications of negligence including applicable code sections are as follows:
__________________________________________
__________________________________________
(10) If the case is based on a contract, either oral or written, the terms of the contract are as follows (or, the contract is attached as an Exhibit to this order):
__________________________________________
__________________________________________
__________________________________________
(11) The types of damages and the applicable measure of those damages are stated as follows:
__________________________________________
__________________________________________
(12) If the case involves divorce, each party shall present to the court at the pre trial conference the affidavits required by Rule 24.2.
(13) The following facts are stipulated:
__________________________________________
__________________________________________
(14) The following is a list of all documentary and physical evidence that will be tendered at the trial by the Plaintiff or Defendant. Unless noted, the parties have stipulated as to the authenticity of the documents listed and the exhibits listed may be admitted without further proof of authenticity. All exhibits shall be marked by counsel prior to trial so as not to delay the trial before the jury.
a. By the Plaintiff:
__________________________________________
__________________________________________
__________________________________________
b. By the Defendant:
__________________________________________
__________________________________________
__________________________________________
(15) Special authorities relied upon by Plaintiff relating to peculiar evidentiary or other legal questions are as follows:
__________________________________________
__________________________________________
(16) Special authorities relied upon by Defendant relating to peculiar evidentiary or other legal questions are as follows:
__________________________________________
(17) All requests to charge anticipated at the time of trial will be filed in accordance with Rule 10.3.
(18) The testimony of the following persons may be introduced by depositions:
__________________________________________
Any objection to the depositions or questions or arguments in the depositions shall be called to the attention of the court prior to trial.
(19) The following are lists of witnesses the
a. Plaintiff will have present at trial:
__________________________________________
__________________________________________
b. Plaintiff may have present at trial:
__________________________________________
__________________________________________
c. Defendant will have present at trial:
__________________________________________
__________________________________________
d. Defendant may have present at trial:
__________________________________________
__________________________________________
Opposing counsel may rely on representation that the designated party will have a witness present unless notice to the contrary is given in sufficient time prior to trial to allow the other party to subpoena the witness or obtain his testimony by other means.
(20) The form of all possible verdicts to be considered by the jury are as follows:
__________________________________________
(21)a. The possibilities of settling the case are: ____________________
b. The parties do/do not want the case reported.
c. The cost of take down will be paid by: _____________________________
d. Other matters:
Submitted by:
__________________________________________
__________________________________________
It is hereby ordered that the foregoing, including the attachments thereto, constitutes the PRE TRIAL ORDER in the above case and supersedes the pleadings which may not be further amended except by order of the court to prevent manifest injustice.
This _______ day of __________, 20__.
__________________________________________
Judge, Superior Court
______ Judicial Circuit
Ga. R. Sup. Ct. 7.2