What if parties disagree on facts?

If parties cannot stipulate facts, identify disputed issues clearly and provide competing statements of fact. The court will schedule resolution at the pretrial conference or rule on admissibility at trial; unresolved disputes typically appear on the trial issue list.

How are exhibits authenticated under the order

Authentication methods should be listed: stipulation of authenticity, witness testimony, or business records foundation. Record whether parties agreed to admit exhibits without foundation. Disputes over authenticity require foundation witness or pretrial motion ruling to admit evidence at trial.

Can the court modify the pretrial order?

Yes. Courts retain discretion to amend pretrial orders for good cause, to correct clerical errors, or to accommodate late-discovered evidence. Requests to modify require prompt motion identifying justification and proposed revised language for the court's consideration.

What if a signature is missing on the order

A missing signature can render portions unenforceable. Parties should promptly submit a corrected order with all required signatures and a certificate of service. If timing prevents amendment, raise the issue at the pretrial conference to seek court direction.

Are eSignatures acceptable on pretrial orders

Electronic signatures are generally valid under the ESIGN Act (15 U.S.C. ch. 96) and UETA where adopted, provided the court or local rules permit e-filing and the signature meets intent, attribution, consent, and retention requirements.

When must the order be filed with the court

Filing deadlines vary by jurisdiction and the judge's scheduling order. File the proposed pretrial order by the court's stated deadline and serve all parties. Missing deadlines can lead to sanctions or exclusion of evidence at trial.

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General Form of Pretrial Order

General Form of Pretrial Order

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Court Document

Re: The Marriage of

and

County District Court File No.

Dear

Enclosed please find the which sets a for .m. on . I have also enclosed a Rehearing Statement form that must be completed prior to the settlement hearing. To facilitate my preparation of the Rehearing Statement, you should provide me with a draft of the form with current information. If you have any questions about the requested information, please call me. Your draft should be returned to me by . After I review your draft of the Rehearing Statement, I will prepare a final draft for my review with you.

Sincerely,

What the General Form of Pretrial Order Is

The General Form of Pretrial Order is a standardized court document used to summarize agreed facts, identify contested issues, set evidentiary limits, and establish trial logistics in civil litigation. Courts issue or approve a pretrial order after discovery and pretrial conferences to streamline trial preparation and reduce surprise. It typically records stipulations, witness lists, exhibit lists, motions in limine rulings, and time allocations for trial. Parties and counsel must review the order carefully because it governs trial evidence, witness testimony, and procedural deadlines unless the court later modifies it.

Who Prepares and Relies on the Pretrial Order

Typical users of the General Form of Pretrial Order include plaintiff and defense counsel, litigants, and the presiding judge.

Plaintiff counsel: prepares witness and exhibit lists, negotiates stipulations, and proposes trial schedule to the court.
Defense counsel: identifies contested issues, files motions in limine, and confirms availability of expert witnesses at trial.
Parties and corporate representatives: verify factual summaries, confirm exhibits, and approve stipulated admissions for trial efficiency.

The document is a shared roadmap: everyone named in the order should confirm accuracy before filing and prior to trial.

Step-by-Step: Preparing and Submitting the Order

Follow these sequential steps to prepare, circulate, and obtain the court's approval of the General Form of Pretrial Order.

01

Prepare Draft: Assemble stipulations, witness lists, exhibit lists, and proposed time allocations.
02

Exchange with Opposing: Provide opposing counsel draft and request corrections or additional stipulations.
03

File with Court: Submit proposed order by deadline and include certificate of service.
04

Attend Conference: Present contested issues and agree on final text for court entry.

Common Questions About Pretrial Orders

Common questions about preparing and implementing a General Form of Pretrial Order are answered below to reduce delays and errors.

Need help? Contact support

What if parties disagree on facts?
If parties cannot stipulate facts, identify disputed issues clearly and provide competing statements of fact. The court will schedule resolution at the pretrial conference or rule on admissibility at trial; unresolved disputes typically appear on the trial issue list.
How are exhibits authenticated under the order
Authentication methods should be listed: stipulation of authenticity, witness testimony, or business records foundation. Record whether parties agreed to admit exhibits without foundation. Disputes over authenticity require foundation witness or pretrial motion ruling to admit evidence at trial.
Can the court modify the pretrial order?
Yes. Courts retain discretion to amend pretrial orders for good cause, to correct clerical errors, or to accommodate late-discovered evidence. Requests to modify require prompt motion identifying justification and proposed revised language for the court's consideration.
What if a signature is missing on the order
A missing signature can render portions unenforceable. Parties should promptly submit a corrected order with all required signatures and a certificate of service. If timing prevents amendment, raise the issue at the pretrial conference to seek court direction.
Are eSignatures acceptable on pretrial orders
Electronic signatures are generally valid under the ESIGN Act (15 U.S.C. ch. 96) and UETA where adopted, provided the court or local rules permit e-filing and the signature meets intent, attribution, consent, and retention requirements.
When must the order be filed with the court
Filing deadlines vary by jurisdiction and the judge's scheduling order. File the proposed pretrial order by the court's stated deadline and serve all parties. Missing deadlines can lead to sanctions or exclusion of evidence at trial.

Key Sections to Include in a Professional Pretrial Order

Essential parts of the General Form of Pretrial Order provide clarity on trial scope, streamline admissibility, and create an enforceable roadmap for courtroom procedure and timing.

Caption

Court name, case number, and party captions must match court filings exactly. Discrepancies can cause filing errors and create confusion about which matter the order governs, so verify against the complaint.

Stipulations

List factual stipulations and admitted evidence to narrow triable issues. Agreed facts remove need for proof and focus trial time on genuine disputes that the jury or judge must resolve.

Witnesses

Provide identities, designations (fact or expert), and estimated testimony scope. Note deposition designations and expected availability to reduce last-minute witness challenges and scheduling conflicts effectively.

Exhibits

Attach an indexed exhibit list with short descriptions and Bates ranges where applicable. State agreed admissibility or objections and whether duplicates or composite exhibits exist.

Motions

Record unresolved pretrial motions and the court's rulings on evidentiary challenges. Include any limitations imposed by motions in limine to guide during-trial evidence handling decisions.

Time

Specify trial length, per-side time limits, and allocation for openings, direct and cross examinations, and closings to prevent disputes and enable efficient courtroom management scheduling.

Security and Compliance Considerations

Encryption in transit: TLS 1.2 and TLS 1.3 used in transit.

Encryption at rest: AES-256 encryption to protect stored data.

Certifications and compliance: SOC 2 Type II, ISO 27001, PCI DSS.

HIPAA compliance: Business Associate Agreement available on request.

Regulatory standards: ESIGN, UETA, 21 CFR Part 11 supported.

Access controls: Role-based access and audit logs retained.

Penalties and Risks of an Incorrect Order

Missed Deadline: Sanctions or exclusion possible.

Incorrect Caption: Filing may be rejected.

Unsigned Order: Portions unenforceable.

False Stipulation: May lead to sanctions.

Improper Authentication: Court may require re-signing.

Missing Exhibits: Evidence exclusion risk.

Common Preparation Pitfalls to Avoid

Incomplete exhibit lists often lack Bates ranges or descriptions, causing delays and additional motions to admit evidence at trial.
Disputed witness designations create last-minute scheduling conflicts; failing to confirm availability in advance increases the risk of trial adjournment.
Vague motions in limine leave evidentiary decisions unresolved; specify contested issues clearly to obtain meaningful pretrial rulings from the judge.
Inconsistent naming of parties or counsel across filings can lead to misfiling; verify names match official pleadings before submission.

Setting Up a Digital Review and Filing Workflow

Set up a digital workflow to draft, review, and e-file the General Form of Pretrial Order with accurate routing and audit logs.

Field name and configuration setting	Configuration and recommended values for setup
Signer authentication and verification settings	Email link, SMS code, or KBA as required.
Field placement and required fields	Signature, date, witness, exhibit index fields marked required.
Routing order, approvals, and notifications	Set role-based signer order and automated reminders for pending signatures.
Audit trail and retention policy	Enable timestamping, IP capture, and long-term retention per record policy.

Technical Requirements for eFiling and eSigning

Digital filing requires compatible PDF files, accurate metadata, and a known e-filing channel approved by the court.

File formats: PDF/A preferred; DOCX accepted in some courts.
Integrations available: Salesforce, Microsoft 365, NetSuite, Box integrations supported.
Authentication options: Email, SMS, or advanced methods (KBA, SSO).

How the Order Moves From Draft to Court Entry

This workflow outlines how the General Form of Pretrial Order moves from draft to court entry and distribution to parties.

Draft: Draft the order incorporating stipulations and exhibits.
Review: Exchange drafts with opposing counsel and resolve comments.
File: File or e-file the proposed order with certificate of service.
Entry: Court signs or enters order and clerk circulates final document.

eSignature Pricing and Feature Comparison for Pretrial Order Workflows

Compare common eSignature pricing and technical limits for preparing and circulating a General Form of Pretrial Order; vendor columns follow.

	signNow	DocuSign	Adobe Sign	PandaDoc	HelloSign
Starting Price	$8/user/mo	$15/user/mo	$14/user/mo	$19/user/mo	$15/user/mo
Free Trial	7-day free trial	Varies by plan	Varies by plan	Varies by plan	Varies by plan
Bulk Send	Yes	Yes	Yes	Yes	No
Audit Trail	Yes	Yes	Yes	Yes	Yes
HIPAA Compliant	Yes	Yes	Yes	No	No

Example Scenarios Where the Pretrial Order Added Value

Real-world uses of the General Form of Pretrial Order show how courts and counsel reduce disputes and clarify trial scope before trial.

Commercial Dispute

In a contract breach case, parties used the pretrial order to list agreed facts, narrow issues, and set exhibit lists in advance.

This removed days of trial testimony over routine facts.
As a result, the court entered a focused trial schedule, counsel avoided repetitive foundational testimony, and the jury heard only contested evidence, which shortened trial and reduced costs for both parties through efficient case management.

Personal Injury

In a tort trial, defense counsel stipulated to medical records authenticity in the pretrial order, reserving dispute only for causation and damages.

Expert testimony scope was narrowly defined.
The limited expert issues reduced the number of expert witnesses called, decreased expert fees, and allowed the parties to focus openings and closings on contested liability and the quantification of damages, improving juror comprehension.

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