(A) All instructions contained within the Final Pretrial Order must be followed. The submissions in the pretrial materials will be binding on the parties at trial. If any counsel believes that any of the instructions allow for any part of the Pretrial Order to be deferred until after the submission date, counsel shall file a motion seeking leave of court for such deferral.
(B) To prepare the pretrial materials required for the Final Pretrial Order, counsel for all parties are directed to meet in order to (1) reach any possible stipulations narrowing the issues of law and fact; (2) identify non-stipulated issues of law and fact; and (3) identify documents that will be offered in evidence.
(C) Plaintiff has the responsibility to initiate conferences, to prepare the initial draft of pretrial materials, and to ensure that timely completion occurs. Defendant has the responsibility to work cooperatively with opposing counsel to the same end, and where counterclaims or affirmative defenses are pled, the defendant has the initiating responsibility and plaintiff the responding responsibility.
Counsel’s meeting shall be held sufficiently in advance of the submission date to permit thorough preparation of the pretrial materials.
(D) The judge will issue an order in advance of the pretrial order due date, similar to that reproduced below: