Lisa S. Small

After the trial-setting hearing: file and exchange witness and exhibit lists within one week; file pre-trial motions within two weeks (untimely motions are deemed waived absent agreement, good cause, or manifest injustice); file the joint case brief, e-mail pertinent case law, and deliver redacted records within four weeks. In dependency matters DCF prepares the proposed order (14 days from hearing) — objections not placed on the record are waived if no alternative order is submitted. Case-plan approvals are not accepted as agreed orders absent good cause and prior approval.

Prepare for trial fast when a youth is in secure detention: the Court intends to try those cases within 21 days of arrest. Exchange witness and exhibit lists before calendar call, file pre-trial motions before calendar call, file business-records notices within 2 days of calendar call, and e-mail agreed jury instructions, motions in limine, and memoranda to the JA no later than 48 hours before the first day of trial.

Make at least three (3) good-faith attempts to meet and confer before noticing any motion, and certify the conferral in the Notice of Hearing. File and docket the motion BEFORE requesting hearing time, e-mail the JA (copying all parties) with a copy of the motion, and file the Notice of Hearing only after receiving the JA's confirmation e-mail. Responses are due 5 days and replies 2 days before the hearing.