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Standing Pre-Trial Order in Jury Trials Division A

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PRE-TRIAL MEMORANDUM ON BEHALF OF
IN OPPOSITION TO INCREASE IN CHILD SUPPORT

VS

: PARISH OF LOUISIANA

: DOCKET NO.

MAY IT PLEASE THE COURT:

This matter comes before the Court on a Rule to Increase Child Support set
before the Honorable on , 20 at o'clock .M. as a fixing.

FACTS:

The plaintiff and Defendant were divorced by Judgment of this Court on , 20 wherein Plaintiff and Defendant were awarded joint custody of the minor children, with the Plaintiff being designated the custodial parent according to the Joint Custody Plan. According to said Joint Custody Plan, signed on , 20 the selection of where the children would attend school will be a joint decision made by both parents. There has never been an agreement by the parties that the children will attend public or private school.

is years old and is in the grade at in

is years old and is in at in

LAW:

Louisiana Revised Statute 9:315.6(1) sets forth other expenses which may be included in addition to the basic child support obligation and provides, in part, as follows:

"By agreement of the paties or order of the Court, the following expenses incurred on behalf of the child may be added to the basic child support obligation:

(1) Any expenses for attending a special or private elementary or secondary school to meet the particular educational needs of the child."

In the absence of an agreement between the parties, in order to warrant the inclusion of private school tuition expenses in a child support award, some evidence must be presented to show a particular educational need of the child which is met by the attendance at private school. Bertrand v. Bertrand, 637 So.2d 531 (La. App. 1st Cir., 1993) A particular educational need of a child to remain in private school includes consideration of the child's history of attending a private school and whether a continuation of their education in that setting is in the child's best interest. Schulz v. Schulz, 630 So.2d 847, 850 (La. App. 4th Cir. 1993).

It is respectfully submitted that the educational needs of the children can be satisfied by a public school just as well as at a private school. Counsel for defendant concedes that it is late in the school year and would probably be appropriate for the children to remain in their respective schools until the end of this school term. At the end of this school term, it is respectfully suggested that the two minor children should be enrolled in the public school system in Parish.

RESPECTFULLY SUBMITTED,


, LA
La. Bar Roll No.
ATTORNEY FOR DEFENDANT

* * *

CERTIFICATE

I hereby certify that a copy of the above and foregoing Pre-Trial Memorandum on Behalf of in Opposition to Increase in Child Support has been forwarded to , Louisiana , attorney for plaintiff, by depositing a copy of same in the United States mail, postage prepaid.

, Louisiana, this day of , 20

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What the Standing Pre-Trial Order in Jury Trials Division A Is

A Standing Pre-Trial Order in Jury Trials Division A is a court-issued procedural document that establishes case-specific deadlines, disclosure obligations, exhibit lists, witness schedules, and trial logistics for jury cases assigned to Division A. It standardizes pre-trial tasks, clarifies required filings, sets hearing and conference dates, and instructs parties on submission formats. The order is intended to streamline trial readiness, reduce last-minute disputes, and provide the court with a single roadmap for pre-trial compliance; it may be modified only by leave of the court or by agreement subject to court approval.

Why this Standing Pre-Trial Order Matters for Case Management and Compliance

The order centralizes critical deadlines, reduces discovery disputes, and preserves the court’s trial calendar. For electronic submissions, applicable federal and state laws such as the ESIGN Act (15 U.S.C. §7001) and state UETA statutes generally permit electronic records and signatures when courts and local rules allow.

Why this Standing Pre-Trial Order Matters for Case Management and Compliance

Who prepares and relies on a Standing Pre-Trial Order in Jury Trials Division A

Parties, counsel, and court staff use the order to coordinate pre-trial steps and ensure timely compliance.

  • Plaintiff counsel: drafts proposed dates, disclosures, and exhibit lists for court approval and serves opposing counsel promptly.
  • Defense counsel: reviews proposed order, submits objections or modifications, and confirms witness and exhibit availability before conferences.
  • Court clerk and calendar staff: enter deadlines, schedule conferences, and circulate the signed order to the docket and parties.

Who Signs and Who Oversees the Order

Presiding Judge

The presiding judge or judicial officer signs or issues the standing pre-trial order to make deadlines binding and to record the court's expectations. The judge may reserve rights to modify the schedule for good cause and enforces compliance through calendaring and sanctions.

Lead Counsel

Lead counsel for each party typically prepares, reviews, and certifies the proposed order before submission. Counsel are responsible for verifying accuracy, confirming party authority, and serving the signed order on opposing counsel and relevant court units.

Essential Fields Required by the Standing Pre-Trial Order

Case Caption: Full case title
Case Number: Court docket number
Division and Judge: Division A | Judge name
Deadlines Table: Key dates listed
Witness List: Names and addresses
Exhibit Index: Exhibit identifiers

Consequences of an Incorrect or Late Standing Pre-Trial Order

Court Sanctions: Monetary or procedural
Continuance: Trial delay possible
Contempt: If willful disobedience
Evidence Exclusion: Late exhibits may be barred
Appeal Risk: Preservation issues arise
Filing Fees: Additional court costs

Common Mistakes When Preparing the Standing Pre-Trial Order

  • Using inconsistent party names or abbreviations that differ from the docket, which causes confusion and may require corrective filings.
  • Missing or misdating deadlines such as witness disclosure or exhibit exchange, creating disputes and possible exclusion of evidence.
  • Failing to serve the finalized and signed order on opposing counsel and the court clerk before the scheduled conference.
  • Submitting exhibits without a clear index or Bates range, which complicates identification at trial and during motions in limine.

Key Components to Include in a Professional Standing Pre-Trial Order

A complete standing pre-trial order should itemize deadlines, disclosures, and courtroom procedures so all parties and the court know obligations and timing.

Deadlines

List filing, discovery cutoff, motion, witness disclosure, and exhibit exchange dates with explicit MM/DD/YYYY formatting and any applicable time-of-day limits.

Witness Lists

State witness names, addresses, anticipated testimony, and limits on number or timing for expert rebuttal disclosure to avoid surprise at trial.

Exhibit Index

Provide a numbered exhibit list with short descriptions, custody designations, and Bates ranges when applicable to streamline identification during trial.

Motions Schedule

Specify deadlines for dispositive and in limine motions, briefing lengths, and hearing dates so the court can manage argument time effectively.

Jury Instructions

Outline proposed jury instruction exchange dates and procedures for submitting agreed or disputed instructions before charge conference.

Trial Logistics

Include expected trial length, estimated witness testimony time, courtroom equipment needs, and contact points for last-minute administrative issues.

Step-by-Step: Completing the Standing Pre-Trial Order

Follow these steps in order to prepare, verify, and submit a standing pre-trial order that complies with Division A procedures.

  • 01
    Draft Order: Populate case caption, deadlines, witnesses, and exhibits.
  • 02
    Internal Review: Have lead counsel confirm accuracy and client authority.
  • 03
    Serve Opposing Counsel: Provide the proposed order and obtain any objections.
  • 04
    File with Court: Submit via e-file or clerk per local rules.

How to Configure an Online Workflow for This Order

Set up a digital workflow that matches local e-filing rules and preserves an audit trail for all parties and the court.

Field Configuration
Document Upload PDF/A preferred; flatten fillable fields
Signature Method Judge stamp or electronic signature
Authentication Email verification; optional SMS code
Distribution E-file to court and email serve parties

Where to File and How the Order Moves Through the Court

Know the routing steps so the order is accepted, docketed, and communicated to the parties and the court calendar.

  • E-Filing Portal: Upload the signed order to the court’s e-filing system.
  • Clerk Review: Clerk checks format and docket number, then accepts or returns.
  • Judge Signature: Judge signs or signs electronically per court practice.
  • Service: Serve opposing counsel and upload proof of service to the docket.

Digital Signing and Submission Requirements

Confirm that the chosen e-sign and e-file platform supports required formats, authentication, and an auditable trail before submission.

  • File Formats: PDF, PDF/A, DOCX
  • Authentication: Email or SMS code
  • Integrations: E-file portals supported

Typical Deadlines and Timing Expectations

Division A standing pre-trial orders establish a sequence of deadlines; missing these can affect evidentiary rights and trial scheduling.

Motions Cutoff:

Motions due at least 60 days before trial

Witness Disclosures:

Exchange lists 30 days before trial

Exhibit Exchange:

Share indexes and exhibits 21 days before trial

Final Pretrial Conference:

Held 7–14 days before trial

Trial Date:

Fixed by court calendar; adherence required

How the Standing Pre-Trial Order Differs from Other Orders

The table compares a standing pre-trial order to a scheduling order to clarify purpose and enforceability differences.

Criteria Standing Pre-Trial Order Scheduling Order
Purpose trial readiness case management
Binding Effect yes, on parties yes, but more flexible
Typical Contents witnesses/exhibits deadlines only
Modification Ease court approval required often amended by motion

eSignature Provider Comparison for Preparing and Serving Orders

Document signing and secure distribution tools differ in price, bulk capabilities, and compliance features; signNow appears first for quick vendor comparison.

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 vendor Varies by vendor Varies by vendor Varies by vendor
Bulk Send Yes Yes Yes Yes No
Audit Trail Yes Yes Yes Yes Yes
HIPAA Compliant Yes Yes Yes No No

Real-World Examples of Digital Document Use in Legal Workflows

These short case notes illustrate how electronic signatures and templates support legal operations and document control.

Optica Ventures LLC

Optica needed a simple interface to circulate court forms efficiently.

  • "The interface is simple and easy-to-use for our team; more importantly, it is just as easy for our customers."
  • The streamlined workflow reduced administrative back-and-forth and cut preparation time for pre-trial exchanges in multi-party litigation.

BIS

BIS prioritized compliance and auditability for sensitive legal documents.

  • "We felt most comfortable with airSlate SignNow given their SOC 2 certification and strict focus on ESIGN and UETA act compliance."
  • The verified audit trail and compliance posture supported timely court submissions and internal records retention policies.

Saving, Exporting and Supporting Documents for the Record

After the order is signed, produce stable copies and supporting files to preserve evidentiary value and satisfy court archive requirements.

Export Options

Save a PDF/A version for long-term archival and include the platform’s certificate of completion as embedded metadata.

Certificate of Service

Attach or include a signed certificate of service showing how and when parties were served, with timestamps.

Exhibit Attachments

Bundle exhibits in a single, clearly indexed PDF with cross-references to the exhibit index in the order.

Audit Trail

Preserve the signing audit trail showing signer identity, timestamps, and IP addresses for record and potential challenges.

Tips for Accurate and Efficient Completion

Adopt these practices to reduce errors, speed approval, and maintain a defensible record for court proceedings.

Use Standardized Templates
Begin with a court-approved template to avoid formatting rejections and ensure all required clauses and signature blocks are present.
Confirm Party Details
Verify party names, counsel contacts, and docket number against the official case file before submitting to the clerk.
Preserve Audit Trails
Use an e-sign solution that records attribution, timestamps, and access logs to defend against challenges to authenticity.
Coordinate Service
Serve opposing counsel and upload proof of service promptly to prevent disputes about notice or compliance.

Frequently Asked Questions About the Standing Pre-Trial Order in Jury Trials Division A

Answers to common questions about signing, modifying, serving, and retaining a standing pre-trial order in Division A.


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