PreTrial statement...

[Cookiemomma4]

I am hoping this is an easy one for you.  All parties are in PA but it is a more general question than that.  
Do you know if there may be an example of what a pre-trial statement (to go to a trial not a custody master) should look like somewhere online or can you give me something to go on here?  It seems everywhere we turn we get, "The lawyer files it" or "The lawyer does that"...but we are pro se.  We have done VERY well so far but we are not sure what this should look like (including the custody master telling the opposing side, at our last hearing, that they know they don't want this going to trial because we have a strong case.  He said they needed to sit down and talk to us, but they have been unwilling to date.  This of course is niether here nor there...).  
I am assuming that it needs the header up top with all of the case info...but after that should it be just paragraphs siting attatched evidence?  Should it be more like an outline?  Should it look like the one going to the custody master but more indepth?  
TIA

Edit to add...in the county where this is being heard ALL evidance and purposed witness testomony must be layed out in this pre-trial statement as it would be in a criminal matter.  This is a change that is less than a year old.  They have found their way around the lack of discovery clause in the law, thus our reason for concern regaurding this matter.

[socrateaser]

The court rules for the jurisdiction should provide some specifics. If not, then you could go to the county court check the calendar for the next (or maybe the last)  family law trial, and then pull the case file and read the pretrial statement.

A pretrial statement may be adversarial: basically a written opening statement of what you intend to prove and how you intend to prove it, or cooperative, where both attorneys get together and agree on the disputed issues of the case and file the joint statement of issues remaining to be heard and the evidence to be offered.

If it's an adversarial brief, then something like this would likely work (I'll use CA as the example jurisdiction, and assume you are Petitioner):

Petitioner's Pre-trial Statement

Introduction

Petitioner is requesting that the court decide the custody rights of the parties minor children. We intend to show that awarding primary custody to Petitioner is in the child(ren)'s best interests.

Family Code Section 3011 describes the elements which the court must consider in determining the best interests of the child, pursuant to a awarding custody under Family Code Section 3021. We will begin by address each element in turn below, by presenting the evidence we intend to produce and an argument as to why the evidence should weigh in favor of Petitioner on the element.

We will then similarly address elements found in Family Code Section ????, ????, and those declared by the Cal. Supreme Court in the case of _____ v. _____.

Finally, we will address our proposed parenting plan (attached as Appendix A), and explain why we believe it serves the child's best interests.

1. Family Code 3011(a) requires the court consider the health, safety and welfare of the child.

Child's Health

We will present testimony from the court-appointed custody evaluator, showing that Respondent refused to provide prescribed medication to the child after the child was diagnosed with strep throat, because of Respondent's religious convictions (Exhibit #1, attached, Custody evaluation Report, P. 25, paragraph 3).

In  ___ v. ____, Cal. App.4th, the court held that "relgious beliefs are not a substitute for a physician's care and are not in the child's best interests." It should be clear to any reasonable person that the failure, on religious grounds, to administer a routine course of antibiotics, which has been proven an effective response to a diagnosis of strep throat, is not in the child's best interests.

Petitioner has no such religious aversion to modern medicine, and Petioner believes that no evidence exists to demonstrate the contrarary. Therefore, the evidence on this element favors Petitioner.

2. ETC...

Conclusion

For all of the foregoing reasons, we believe that the evidence in this action strongly favors awarding primary custody to Petitioner. We hope the court agrees.

Date: _____

Respectfully Submitted


By: ____________
YOURNAME
Petitioner, Pro Se

[Cookiemomma4]

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