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Pre-Trial Memorandum

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PRE-TRIAL MEMORANDUM ON BEHALF OF PLAINTIFF

VS

: JUDICIAL DISTRICT COURT

: PARISH OF , LOUISIANA

: DOCKET NO.

MAY IT PLEASE THE COURT:

This matter comes before the Court on Rules for Child Support, Visitation and Restraining Orders scheduled for , 20 at : o'clock .M. before the Honorable as a fixing.

LSA-R.S. 9:315 et seq., known as "Louisiana Uniform Child Support Act", codified the jurisprudence requiring that child support be in an amount to maintain the children at the standard of living to which they have been accustomed and that it is not only the "free Income" of the father which is to be considered in setting child support, but the gross income and totality of the financial abilities and circumstances of the parents which determine the amount of child support to be awarded (ROBERTS vs. ROBERTS, [4th Cir. App. 1962), 145 So.2d 69; LORMAND vs. LORMAND, [3rd Cir. App. 1976], 337 So.2d 920; NELSON vs. NELSON, [lst Cir. App. 1976], 335 So.2d 787; FRAZIER vs. FRAZIER, [La. App. 2nd Cir. 1975], 318 So.2d 625; and BERNARD vs BERNARD [La. App. 3rd Cir. 1974], 300 So. 2d 499.

Evidence will be introduced at the hearing herein to establish not only 'S and 'S financial capabilities, but also the needs of their minor child, , all in accord with LSA-C.C. ART. 227, 230 and 231 and LSA-R.S. 9:315, et seq. and the above cited cases.

The child support worksheet completed in accord with LSA-R.S. 9:315.8 is attached hereto and made a part hereof.

Accordingly, it is respectfully submitted that judgment should be rendered herein as requested by

Respectfully Submitted,

LA

* * *
CERTIFICATE

I HEREBY CERTIFY that a copy of the above and foregoing Pre-Trial Memorandum on Behalf of Plaintiff has been served upon , , Louisiana , attorney for Defendant, by placing a copy of same in the United States mail, postage prepaid and properly addressed.

, Louisiana, this day of , 20

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What a Pre-Trial Memorandum Is and When It’s Used

A Pre-Trial Memorandum is a written submission to a court that summarizes the parties' positions, the factual background, the legal issues to be decided, anticipated evidence, and proposed witnesses and exhibits. Courts typically require or permit a memorandum to streamline trial preparation, narrow disputed issues, and set the scope of admissible evidence under local rules and the scheduling order. While formats vary by jurisdiction and judge, the memorandum functions as the single-source roadmap for trial counsel, the court, and opposing parties.

Why a Clear Pre-Trial Memorandum Matters

A well-prepared Pre-Trial Memorandum reduces surprises at trial, focuses legal argument, and helps preserve objections and evidentiary positions. It supports efficient case management and assists the court in ruling on evidentiary disputes and pretrial motions.

Why a Clear Pre-Trial Memorandum Matters

Who Prepares and Relies on the Pre-Trial Memorandum

Lead counsel typically prepares the memorandum but it is used broadly by trial teams and the court.

  • Plaintiff or defense counsel preparing case theory and evidence lists.
  • In-house or corporate counsel coordinating witnesses and exhibits for trial.
  • Pro se litigants submitting a concise statement of issues for judge review.

Representative Signatories

Lead Trial Counsel

An attorney representing a party signs or files the memorandum to present the party's trial plan, identify witnesses and exhibits, and state evidentiary objections. The filing attorney is responsible for accuracy and compliance with the court’s format and deadlines.

Pro Se Litigant

A self-represented party may file a pre-trial memorandum when permitted by local rules; courts may offer simplified templates or require shorter submissions. Accuracy and adherence to the judge’s scheduling order remain the filer's responsibility.

Step-by-Step: Prepare and File a Pre-Trial Memorandum

Follow a consistent sequence from drafting to service to filing to ensure the court and parties receive complete materials on time.

  • 01
    Draft: Assemble facts, witness and exhibit lists, and legal points into the court’s required format.
  • 02
    Review: Confirm citations, exhibit numbering, and that all parties are properly identified.
  • 03
    Serve: Serve opposing counsel per local rules before filing with the court to allow meet-and-confer if required.
  • 04
    File: File via the court’s electronic filing system by the deadline and retain proof of filing.

Core Sections to Include in a Professional Pre-Trial Memorandum

A standard Pre-Trial Memorandum contains specific sections that enable the court to understand the case posture quickly and rule on pretrial matters.

Caption

Court name, docket number, party names, and title identifying the document as a Pre-Trial Memorandum.

Issues Presented

Numbered statement of legal questions to be resolved at trial or by pretrial motions.

Statement of Facts

Concise chronological summary of material facts with precise dates and references to supporting exhibits.

Witness and Exhibit Lists

Detailed roster of witnesses and exhibits, including deposition designations and exhibit numbers.

Evidentiary Issues

Notice of anticipated objections, motions in limine topics, and foundation or authentication concerns.

Legal Argument

Short memorandum of law focused on controlling authority and how law applies to undisputed facts.

Required Information and Key Data Points

Case Caption: Exact court and docket
Date Filed: MM/DD/YYYY
Parties: Full legal names
Issues: Concise list
Witnesses: Names and topics
Exhibits: Numbered descriptions

Common Mistakes to Avoid When Preparing the Memorandum

  • Missing or inconsistent captions that cause the clerk to reject or misfile the memorandum.
  • Overlong factual recitations that bury the dispositive legal issues and exceed page limits.
  • Failure to number exhibits or provide exhibit lists, complicating in-court identification and admission.
  • Serving late or failing to comply with local meet-and-confer rules, risking sanctions or exclusion.

Where to File and How to Serve the Memorandum

Follow the court’s local rules and the scheduling order for required filing methods and service procedures.

  • Electronic Filing: File through the court’s e-filing system (CM/ECF) when required by local rules.
  • Service on Opposing Counsel: Serve via email or e-service where permitted; confirm service method under local rules.
  • Paper Filing: If required, deliver physical copies to the clerk and obtain a stamped proof of filing.
  • Certificate of Service: Include a signed certificate showing how and when service was made.

How to Configure an Online Pre-Trial Memorandum Workflow

Set up fields and routing to match the court’s requirements and your internal review process for efficient e-filing.

Field Configuration
Caption Field Auto-fill from case management
Date Field MM/DD/YYYY validation
Witness Table Repeatable row with role and topic
Signature Block Attorney name, bar number, and date

How to Share, Sign, and Submit the Memorandum Electronically

Choose delivery and signing methods that comply with court rules and preserve evidentiary foundations.

  • Delivery: Email, secure link, or court e-service
  • Authentication: Email link, SMS code, or stronger ID verification
  • Integrations: Connect to CME systems and cloud storage

Typical Deadlines and Timing Considerations

Deadlines for Pre-Trial Memoranda depend on the court’s scheduling order and local rules; below are common timing examples to plan around.

Memorandum Due Date:

Often 7–14 days before final pretrial conference

Motions in Limine:

Frequently due 14 days before trial

Exhibit Exchange:

Commonly 10–30 days before trial

Witness Lists:

Typically filed with the memorandum

Objection Deadlines:

Often short—check local rules for specific timing

Key Milestones in the Pre-Trial Phase

A sequential view of milestones clarifies what must happen and when ahead of trial.

01

Discovery Completion

All depositions and document production completed before final pretrial deadline.

02

Exchange Exhibits

Parties exchange and label exhibits for in-court use and objections.

03

Submit Memorandum

File Pre-Trial Memorandum and serve opposing counsel per scheduling order.

04

Pretrial Conference

Judge addresses outstanding evidentiary issues and prepares trial logistics.

How a Pre-Trial Memorandum Differs from a Trial Brief

Comparing common brief types helps determine scope, timing, and appropriate content for each filing.

Criteria Pre-Trial Memorandum Trial Brief
Primary Purpose summarize case posture and evidence argue legal issues in depth
Timing before trial per scheduling order often pre- or post-trial filing
Content Focus witnesses, exhibits, procedure detailed legal argument
Formality court template common narrative, precedent-driven

eSignature Vendor Comparison for Preparing and Signing Pre-Trial Memoranda

Key vendor features and pricing for electronic signing and secure document routing. Place signNow first per platform comparison conventions.

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 Varies Varies Varies
Bulk Send Yes (Premium) Yes Yes Yes Limited
Audit Trail Yes Yes Yes Yes Yes
HIPAA Compliant Yes Yes Yes No No

Real-World Examples of Electronic Pre-Trial Workflows

Organizations use secure e-sign and document workflows to prepare, exchange, and file pre-trial materials while preserving audit trails.

Optica Ventures (Brian Fitzgibbons)

The interface is simple and easy-to-use for our team; more importantly, it is just as easy for our customers.

  • Used digital workflows to consolidate exhibits and signatures quickly.
  • Resulting efficiencies reduced administrative turnaround and improved coordination between counsel and witnesses ahead of trial.

Fertility Centers of Illinois (John Butler)

The airSlate SignNow team has been exceptional, responsive, the API has been great, and we're extremely happy that we chose airSlate SignNow as a company.

  • Adopted e-sign flows for legal intake and consent documents.
  • Improved traceability of signed records and simplified retrieval of documents cited in pre-trial filings.

Penalties and Risks from Incomplete or Late Memoranda

Sanctions: Court sanctions possible
Evidence Exclusion: Key evidence may be barred
Default Risk: Procedural defaults may follow
Delay: Trial date rescheduling
Increased Costs: Additional attorney fees
Recordkeeping Failure: Regulatory consequences

Frequently Asked Questions About Pre-Trial Memoranda

Common questions and concise answers covering e-signature use, filing, revisions, and evidentiary concerns for Pre-Trial Memoranda.


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