January 2011 - National Labor Relations Board

10338 PREPARATION OF EXHIBITSPreliminary motions to be made, with brief statement in support thereofStipulations that have been procured, are expected or should be soughtDocuments and materials expected to be offered and sought to beproduced by other partiesOrder of witnesses, together with a brief statement of their expectedtestimony, key questions, exhibits to be introduced during their testimonyand copies of their affidavitsOrder of introduction of exhibits, showing the witnesses through whomexhibits will be introducedPreparation for examination under Rule 611(c), Federal Rules ofEvidence, or cross-examination of prospective respondent witnesses,including an outline or narrative summary for such witnesses, priorstatements or affidavits, pertinent memos, letters and impeachmentmaterialPoints on which each witness’ testimony is corroborated by otherwitnesses and the names of such witnessesLegal authorities applicable to anticipated trial problems, including theadmission or rejection of certain evidenceRebuttal witnesses with their prospective testimonyClosing motionsClosing argument outline10338 Preparation of ExhibitsDocuments or records expected to be introduced in evidence should be reproducedin advance, so that sufficient copies are available for introduction into evidenceand for the Administrative Law Judge and all other parties. Where only a part of adocument or record will be offered and is reproduced, the whole should be kept availablefor inspection. No informal markings should be inserted on documents or records thatare to be introduced.10340 Service of Trial SubpoenasSubpoenas should, where circumstances allow, normally be served at least 2weeks prior to trial. This allows sufficient time to arrange for production of the witnessRevised 01/11