Rule 212.2A - Pre-Trial Conference and Pre-Trial StatementsUnless otherwise directed by the court, a Pre-Trial Conference shall be scheduled by the Court Administrator for every case certified for jury trial, or by the Court in a case management order. Pre-Trial Conferences shall be scheduled on those dates designated for that purpose on the court calendar and on such other dates as may from time to time be designated by the court.
(1) No less than twenty (20) days prior to the Pre-Trial Conference, a party shall provide the opposing party with a copy of all documents or records secured through an authorization of the opposing party. Any such documents or records not so provided may not be used at trial for any purpose except for good cause shown.(2) Pre-Trial statements which comply with Pa.R.C.P. No 212.2 shall be submitted to the judge assigned to conduct the Pre-Trial Conference not later than seven (7) days prior thereto. Failure to file a timely pre-trial statement may result in continuance of the Pre-Trial Conference and sanctions in the form of counsel fees payable to opposing counsel. In addition to the requirements of Pa.R.C.P. No. 212.2, the Pre-Trial Statement shall contain:(a) A statement of legal and evidentiary issues which are anticipated to arise together with a citation to authority:(b) An itemized statement of all medical and hospital and other bills and expenses claimed;(c) An itemized statement of lost earnings and impairment of earning power together with the basis therefore;(d) A statement, if applicable, as to the plaintiff's selection of the limited or full tort option. If a limited tort option applies, a statement to support eligibility for recovery of non-economic damages shall be included;(e) All trial exhibits are to be marked for identification but need not be attached to the PreTrial Statement. Note: Although Pa.R.C.P. No. 212.2(a)(5) requires the inclusion of an expert report or proper answer to interrogatory, and the note thereto permits physician notes or records in lieu of a report, neither copies of hospital records, nor illegible office notes, are to be included.
(3) Unless excused by the court upon cause shown, the Pre-Trial Conference shall be attended by counsel as well as the plaintiff, a representative of the defendant's insurance carrier who has settlement authority, a representative of the MCARE Fund, a representative of any Commonwealth or local agency, and any defendant whose personal approval of a settlement offer is required and has not been given. Counsel attending the Pre-Trial Conference will be deemed to be trial counsel and may only be substituted for good cause shown.(4) After the Pre-Trial Conference has concluded, no Supplemental Pre-Trial Statement may be filed without leave of court for cause shown.Amended effective 3/1/2024