Local Rule 3.06 sets forth the requirements for the final pretrial meeting and statement. The Rule provides as follows:
(a) FINAL PRETRIAL MEETING. At least fourteen days before either the final pretrial conference described in the Federal Rules of Civil Procedure or another deadline set by the judge, the parties must meet and in good faith: (1) discuss settlement, (2) discuss the efficient presentation of the evidence and the duration of the trial, (3) stipulate to as many facts and resolve as many legal issues as possible, (4) examine each exhibit, and (5) exchange the name, address, and telephone number of each witness.
(b) FINAL PRETRIAL STATEMENT. At least seven days before either the final pretrial conference described in the Federal Rules of Civil Procedure or another deadline set by the judge, the parties must file a final pretrial statement that will govern the trial. The statement must contain: (1) the basis for the court's jurisdiction, (2) a concise statement of the action, (3) a concise statement of each party's position, (4) a list of each exhibit with a notation of each objection, (5) a list of each witness by name only with a notation of: (A) the likelihood the witness will testify and (B) each objection to the witness's testifying, (6) a list of each expert witness, with a notation of: (A) the substance of the testimony and (B) each objection to the witness's testifying, (7) a breakdown of the type and amount of monetary damages, (8) a list of each deposition offered in lieu of live testimony, unless the deposition is only for impeachment, (9) a concise statement of each admitted fact, (10) a concise statement of each agreed principle of law, (11) a concise statement of each issue of fact without incorporating another paper, (12) a concise statement of each issue of law without incorporating another paper, (13) a list of each pending motion or other unresolved issue, (14) a statement of the usefulness of further settlement discussions, and (15) the signatures of trial counsel and any pro se party following this certification: "In preparing this final pretrial statement, I have aimed for the just, speedy, and inexpensive resolution of this action."
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