Vernon's Texas Rules Annotated - VTRA TX R WEBB CTY Appendix E. Joint Final Pretrial Report

a. On a form similar to the one provided by the clerk, each party will attach two lists of all exhibits expected to be offered and will make the exhibits available for examination by opposing counsel. All documentary exhibits must be exchanged before trial, except for rebuttal exhibits or those whose use cannot be anticipated.

b. A party requiring authentication of an exhibit must notify the offering counsel in writing within five (5) days after the exhibit is listed and made available; failure to object in advance of trial in writing concedes authenticity.

c. Within reason, other objections to admissibility of exhibits must be made at least three (3) days before trial; the Court will be notified in writing of disputes, with copies of the disputed exhibit and authority.

d. Parties must mark their exhibits to include the date and case number on each.

e. At the trial, the first step will be the offer and receipt in evidence of exhibits.

a. List the names and addresses of witnesses who may be called with a brief statement of the nature of their testimony. Include the qualifications of expert witnesses; these will be used to qualify the expert at trial.

b. Include:

“If other witnesses to be called at the trial become known, their names, addresses and subject matter of their testimony will be reported to opposing counsel in writing as soon as they are known; this does not apply to rebuttal or impeachment witnesses.”

a. For a jury trial: proposed charge (including instructions, definitions, and special interrogatories, with authority).

b. For a non-jury trial: proposed findings of fact (without repeating uncontested facts) and conclusions of law, with authority.