Pre-trial Statement Maryland Personal Injury Lawyer

In every personal injury case in Maryland that has been filed in the Circuit Court or subsequently transferred to the Circuit Court on a defendant's request for jury trial there will be a requirement that both parties file a pretrial statement. The content for a pretrial statement has already been predetermined by the Maryland rules. I have outlined below the rules affecting the filing of a pretrial statement.
Rule 2-504.2. Pretrial conference.

(a) Generally.- The court, on motion or on its own initiative, may direct all parties to appear before it for a conference before trial. If the court directs, each party shall file not later than five days before the conference a written statement addressing the matters listed in section (b) of this Rule.

(b) Matters to be considered.- The following matters may be considered at a pretrial conference:


(1) A brief statement by each plaintiff of the facts to be relied on in support of a claim;


(2) A brief statement by each defendant of the facts to be relied on as a defense to a claim;


(3) Similar statements as to any counterclaims, cross-claim, or third-party claim;


(4) Any amendments required of the pleadings;


(5) Simplification or limitation of issues;


(6) Stipulations of fact or, if unable to agree, a statement of matters of which any party requests an admission;


(7) The details of the damage claimed or any other relief sought as of the date of the pretrial conference;

(8) A listing of the documents and records to be offered in evidence by each party at the trial, other than those expected to be used solely for impeachment, indicating which documents the parties agree may be offered in evidence without the usual authentication and separately identifying those that the party may offer only if the need arises;

(9) A listing by each party of the name, address, and telephone number of each non-expert whom the party expects to call as a witness at trial (other than those expected to be used solely for impeachment) separately identifying those whom the party may call only if the need arises;


(10) A listing by each party of those witnesses whose testimony is expected to be presented by means of a deposition (other than those expected to be used solely for impeachment) and a transcript of the pertinent portions of any deposition testimony that was not taken stenographically;

(11) A listing by each party of the names and specialties of experts the party proposes to call as witnesses;

(12) Any other matter that the party wishes to raise at the conference.


If you have questions regarding the filing of a pretrial statement please feel free to call me 1-888-760-7339