IN THE SUPERIOR COURT OF FULTON COUNTY STATE OF GEORGIA FAMILY DIVISION __________________________ , Petitioner, and __________________________ , Respondent. ) ) ) ) ) ) ) ) Civil Action File No. PROPOSED PRE-TRIAL ORDER Each party is required to complete each and every portion of this form that pertains to such party, and to return this form and the attachments with a cover sheet showing the style of the case, the Civil Action File Number, and the title, `Proposed Pre-trial Order'. The original is to be filed directly with the Clerk, a courtesy copy shall be served with the case manager, and a copy shall be served on the other party no later than fourteen (14) days before the scheduled date of the late case evaluation or as otherwise ordered by the Court. By seven (7) days prior to trial or as otherwise ordered by the Court the parties shall confer and consolidate statements and attachments and return this form and the attachments with a cover sheet showing the style of the case, the Civil Action File Number, and the title `Consolidated Pretrial Order'. The original is to be filed directly with the Clerk, a courtesy copy with the case manager and a copy shall be served on the other party. After each party has been served with the opposing party's attachments, they may file an objection as to either the form or substance of such attachments and the contentions contained therein. Proposed Pre-Trial Order Fulton County Family Division American LegalNet, Inc. www.FormsWorkFlow.com The primary purpose of this Order is to narrow the issues and to disclose to each side and to the Court what matters are in dispute and what matters are undisputed, agreed upon or stipulated. The Court deems that all parties are under a continuing duty to promptly advise the other party prior to both the late case evaluation and trial if any new theory of liability or defense arises, if new witnesses or evidence is discovered, or if any statement in the Pre-trial Order is discovered to be misleading or untrue so as to mislead, deceive or cause surprise to any party or the Court. I. ATTORNEY INFORMATION The following individually-named attorneys are hereby designated as lead counsel for the parties (include addresses, telephone and facsimile numbers): Mother: __________________________________________________________ ________________________________________________________________________________ ________________________________________________________________ Father: ___________________________________________________________ ________________________________________________________________________________ ________________________________________________________________ Guardian ad Litem: _________________________________________________ ________________________________________________________________________________ ________________________________________________________________ II. ISSUES OF JURISDICTION, VENUE OR SERVICE Any issue of jurisdiction, venue, or service must be set forth in Attachment `' with particularity and the alleged fact basis for the same, or it is deemed waived. Proposed Pre-Trial Order Fulton County Family Division American LegalNet, Inc. www.FormsWorkFlow.com III. MOTHER'S CONTENTIONS Mother has prepared Attachment `B' which contains a short and concise statement explaining her contentions regarding the following issues where appropriate: A. B. C. Divorce/annulment - state the grounds for divorce or annulment; Paternity/legitimation; Child Custody - include with the concise statement the name(s) and age(s) of the child(ren); list all prior custody orders and/or visitation arrangements; and provide a proposed custody and visitation schedule; D. E. F. G. Child Support; Alimony/separate maintenance; Property Division - include proposed division using the attached form; Other. IV. FATHER'S CONTENTIONS Father has prepared Attachment `C' which contains a short and concise statement explaining his contentions regarding the following issues where appropriate: A. B. C. Divorce/Annulment - state the grounds for divorce or annulment; Paternity/legitimation; Child Custody - include with the concise statement the name(s) and age(s) of the child(ren); list all prior custody orders and/or visitation arrangements; and provide a proposed custody and visitation schedule; Proposed Pre-Trial Order Fulton County Family Division American LegalNet, Inc. www.FormsWorkFlow.com D. E. F. G. Child Support; Alimony/separate maintenance; Property Division - include proposed division using the attached form; Other V. FINANCIAL AFFIDAVITS For actions involving alimony, child support, property division, and attorney's fees, both parties have prepared and attached hereto Financial Affidavits, Child Support Worksheet and Schedules pursuant to Uniform Superior Court Rule 24.2 (as modified for Family Division) with their proposed orders. VI. DISCOVERY All discovery has been completed, unless otherwise noted in Attachment `D', and the Court will not consider any further motions to compel discovery. Provided there is no resulting delay in readiness for trial, the parties shall, however, be permitted to take the depositions of any person(s) for the preservation of evidence and for use at trial. VII. MOTIONS There are no motions or other matters pending for consideration by the court except as indicated in Attachment `E'. This excludes Motions in Limine which should be presented to the Court as soon as possible prior to commencement of trial. Proposed Pre-Trial Order Fulton County Family Division American LegalNet, Inc. www.FormsWorkFlow.com VIII. LIST OF WITNESSES Attached hereto as Attachment `F-1' for the Mother and Attachment `F-2' for the Father, is a list of all the witnesses and their addresses. The list must designate the witnesses whom the party will have present at trial and those witnesses whom the party may have present at trial. Each and every witness, even if a factual witness only, who, by reason of training, skill, or experience, could be qualified at trial to render an expert opinion must be listed as a potential expert witness. A witness designated by a party as one who will be present can be relied upon by the other party to be at trial without the necessity of subpoena, unless notice to the contrary is given ten (10) days prior to trial to allow the other party(s) to subpoena the witness or to obtain testimony by other means. A party must subpoena or otherwise independently arrange to have witnes