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Pre-Trial Statement

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PRE-TRIAL STATEMENT

Name:

Address:

City, State. Zip:

Telephone:

State Bar Code:

Client:

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA

In and for the County of

IN RE THE MARRIAGE OF

CASE NO.

Petitioner

VS.

Respondent

PRE - TRIAL STATEMENT

Filed By :

Petitioner

Respondent

(Assigned to the Honorable DR18DIV

COMES NOW the Petitioner Respondent, and submits his/her pre-trial statement as follows:

STATEMENT OF UNCONTESTED ISSUES OF LAW AND/OR OF FACT

A. The Petitioner Parties were domiciled in the State of Arizona for at least

ninety (90) days at the time of the filing of the Petition for Dissolution of Marriage, Legal

Separation, or Other (identify)

B. The parties were married to each other on , 19 in

and are still husband and wife.

C. The Wife is is not now pregnant.

D. There are are no minor children common to the marriage. (Names and birthdates of children

common to the marriage, if any, are listed below):

E. The marriage is irretrievably broken, with no reasonable prospect of reconciliation, or,

One or both parties desire to live separate and apart.

The conciliation provisions of the Arizona Revised Statutes have been met do not apply in this

matter.

F. The Petitioner Respondent is employed as a

Is Unemployed. His/her date of birth is

G. The Petitioner Respondent is employed as a

Is Unemployed. His/her date of birth is

H. The parties have have not acquired certain community property during the course of their

marriage. If yes, Such community property should be allocated as follows:

I. The parties have have not acquired certain community obligations during the course of their

marriage. If yes, such community debt should be allocated as follows.

J. Custody of the minor children has been resolved has not been resolved has been

partially resolved as follows:

CONTESTED ISSUES OF LAW AND/OR OF FACT

Addendum page(s) attached

SPOUSAL AFFIDAVITS

A. Spousal Affidavits have have not been completed.

B. Spousal affidavits have been completed by Petitioner Respondent. If completed, they

have have not been filed.

WITNESSES AND EXHIBITS

A. Petitioner has has not filed a list of Witnesses.

B. Petitioner has has not filed a list of Exhibits.

C. Respondent has has not filed a list of Witnesses.

D. Respondent has has not filed a list of Exhibits.

INVENTORY OF PROPERTY

There is is not an inventory of property filed attached incorporated within

this document or in this matter.

PRETRIAL DISCOVERY

A. Petitioner Respondent has responded to all discovery propounded.

B. No discovery has been propounded to either party.

PROPOSED RESOLUTION OF THE ISSUES

A. The Petitioner's proposed resolution of the issues is hereby attached.

B. The Respondent's proposed resolution of the issues is hereby attached.

SETTLEMENT DISCUSSIONS

A. There have have not been any settlement discussions. Addendum page(s) attached.

B.

LENGTH OF TRIAL

Petitioner Respondent submits that said trial will encompass day(s).

RESPECTFULLY SUBMITTED this date: 19

Filing Party

PROPOSED RESOLUTION OF THE ISSUES AND STATEMENT OF POSITION

Addendum page(s) attached

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

A Pre-Trial Statement is a formal case summary filed by parties before a scheduled trial that identifies legal claims, defenses, witnesses, exhibits, and contested facts. It organizes each side’s position, narrows issues for the court, and supports the judge’s pre-trial rulings on evidence and scheduling. Courts and local rules vary on format and content, but the document typically replaces or supplements discovery summaries and trial briefs to streamline in-court proceedings and trial readiness.

Why a Clear Pre-Trial Statement Matters

A well-prepared Pre-Trial Statement reduces surprises, focuses the court on live issues, and can limit late evidence or arguments. It helps preserve objections, clarifies witness order, and supports efficient trial management under court scheduling rules.

Why a Clear Pre-Trial Statement Matters

Who Prepares and Uses the Pre-Trial Statement

Lead counsel or an assigned litigation attorney usually prepares the Pre-Trial Statement, sometimes with input from paralegals and client representatives.

  • Plaintiff counsel — Presents claims, damages, and exhibits the plaintiff will use at trial.
  • Defense counsel — Lists defenses, anticipated witnesses, and exhibits to rebut claims.
  • Pro se litigants or corporate litigation teams — May prepare statements when counsel is absent or as required by local rules.

Core Elements to Include in a Professional Pre-Trial Statement

A complete Pre-Trial Statement is structured to let the court quickly identify contested issues, evidence, and the trial plan. Use clear headings and attach exhibit lists when required by local rules.

Case Summary

Short factual background, procedural posture, and precise relief sought to orient the court and opposing parties.

Claims & Defenses

Numbered list of legal claims and affirmative defenses with citations to controlling statutes or rules where helpful.

Witness List

Names, brief topics, and estimated direct-examination time for each witness, distinguishing fact and expert witnesses.

Exhibit Index

Numbered exhibit list with short descriptions, Bates ranges or attachment references, and authenticity stipulations if agreed.

Motions in Limine

Pending evidentiary disputes or proposed exclusions the party asks the court to decide before trial.

Trial Logistics

Estimated trial length, preferred witness order, anticipated scheduling conflicts, and any requested special procedures.

Step-by-Step: Preparing a Pre-Trial Statement

Follow a sequential approach to assemble a statement that complies with court rules and minimizes last-minute revisions.

  • 01
    Collect Orders: Review the judge’s scheduling order and local rules for required content and page limits.
  • 02
    Draft Core Sections: Write the case summary, claims/defenses, witness list, and exhibit index first to shape the document.
  • 03
    Coordinate with Experts: Confirm expert witness availability, topics, and any stipulated limits on testimony.
  • 04
    Finalize and File: Serve opposing counsel, obtain required signatures, and file with the clerk by the court’s deadline.

Where to File and How the Statement Travels

A Pre-Trial Statement is filed with the court and served on opposing parties according to the court’s electronic filing procedures and local rules.

  • Court Clerk: File via the court’s e-filing system (CM/ECF) or clerk’s office if electronic filing is not available.
  • Opposing Counsel: Serve via e-service, email, or personal service as specified in the scheduling order.
  • Chambers Copy: Provide the judge’s chambers with any required courtesy copies or USB submissions per local guidance.
  • Record Retention: Keep a complete filed copy with the proof of service or filing confirmation for the case file.

How to Customize and Complete a Statement Online

Online completion tools let you add structured witness and exhibit fields, apply templates, and generate consistent outputs for court filing.

Template Use a court-compliant template to enforce required sections and page limits.
Metadata Fields Populate caption, case number, and filing date to auto-fill headers and the proof of service.
Signature Block Configure signer details and eSignature method to capture attorney attribution.
Attachment Links Attach exhibits as numbered PDFs and include Bates ranges where applicable.
Export Format Export as PDF/A for long-term archiving and stable court submission.

Digital Signing, eFiling, and Technical Requirements

Verify the court accepts electronic submissions and whether the Pre-Trial Statement may be uploaded as a formatted PDF or entered directly into the court’s e-filing system.

  • File Format: PDF/A is widely accepted; follow local rules for size limits and bookmarks.
  • Authentication: Use an eSignature method that captures signer attribution, timestamp, and audit trail.
  • Integrations: Connect with court e-filing portals or case management systems where supported.

Typical Timelines and Deadlines

Deadlines for filing a Pre-Trial Statement are set by the court’s scheduling order; missing them can limit testimony or evidence at trial.

Pre-Trial Submission:

Usually due 14–30 days before trial per the scheduling order.

Objection Deadline:

Opposing parties often have 7–14 days to file objections or list counter-designations.

Amendments:

Courts may permit amendments only for good cause or by leave; check local rules.

Exhibit Exchange:

Exhibits commonly exchanged with the statement or on a set earlier date under the scheduling order.

Chambers Conference:

Final pre-trial conference often occurs within 7 days of trial to resolve outstanding issues.

Key Milestones from Discovery to Trial

Sequence the statement within the broader trial timeline so each milestone informs the next and supports court readiness.

01

Discovery Close

Completes evidence gathering needed for witness and exhibit lists.

02

Exchange Exhibits

Parties swap marked exhibits and agree on numbering.

03

File Pre-Trial Statement

Submit the statement and proof of service to the clerk by the deadline.

04

Pre-Trial Conference

Judge addresses motions in limine, evidence disputes, and final scheduling.

Common Mistakes to Avoid

  • Late filing that prevents admission of witnesses or exhibits at trial and can prompt sanctions.
  • Inaccurate exhibit numbering or missing Bates ranges that cause confusion and delay in-court admissions.
  • Vague witness descriptions that do not allow the court to assess relevance or need for sequestration.
  • Failure to follow the judge’s local format, length limits, or required attachments leading to rejection.

Consequences of an Incorrect or Incomplete Statement

Evidentiary Exclusion: Court may preclude late-listed witnesses or exhibits.
Sanctions: Sanctions under Federal Rule of Civil Procedure 37 or state equivalents for discovery violations.
Perjury Risk: False sworn statements may expose a signer to perjury charges (18 U.S.C. §1621 at the federal level).
Case Management Orders: Judicial orders may impose limitations on witness testimony or document use.
Reputational Harm: Counsel credibility may suffer with repeated inaccurate submissions.
Delay: Court may continue trial or reorder calendar, increasing cost and client disruption.

Essential Information to Include for Compliance and Authentication

Caption: Court name and case number
Party Identity: Full legal names and roles
Signature Details: Attorney name, bar number, and method of signature
Service Proof: Proof of service date and method
Exhibit Index: Sequential exhibit numbering
Authentication Notes: Statements about exhibit custody or stipulations

Real-World Examples of How Pre-Trial Statements Are Used

These short examples show typical uses of Pre-Trial Statements in different disputes.

Commercial Contract Dispute

A plaintiff summarized breach allegations and damages in numbered paragraphs to narrow issues for a seven-day bench trial.

  • Counsel attached a 50-item exhibit index.
  • The judge used the statement to rule on admissibility of multiple invoices and limited surprise testimony at trial, shortening oral argument time.

Personal Injury Case

Defense counsel listed medical witnesses and expert affidavits in detail to oppose causation.

  • Parties exchanged exhibits two weeks before trial.
  • The pre-trial exchange prompted a settlement conference that resolved the case without a jury trial.

Practical Tips for a Clear, Court-Ready Statement

Follow these practical practices to reduce disputes over form and substance and to improve courtroom efficiency.

Follow Local Rules
Confirm wording, page limits, and filing method in the judge’s standing orders or local rules before drafting.
Be Concise and Specific
Use numbered lists, short witness topic summaries, and precise exhibit descriptions to aid quick judicial review.
Coordinate with Opposing Counsel
Agree where possible on exhibits and stipulations to reduce in-court objections and save time.
Preserve Audit Trails
When e-signing or e-filing, retain timestamps, IP logs, and proof of service for future verification.

eSignature Vendor Comparison for Preparing and Serving a Pre-Trial Statement

Common eSignature features for legal workflows relevant to Pre-Trial Statements are compared below; signNow appears first as the baseline entry.

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 Yes Yes Yes No
Audit Trail Yes Yes Yes Yes Yes
HIPAA Compliant Yes Yes Yes No No

Common Questions and Troubleshooting

Answers to frequent questions about preparing, signing, and filing Pre-Trial Statements in U.S. courts.


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