EXPEDITED JURY TRIAL FORM
SUPERIOR COURT OF NEW JERSEY
LAW DIVISION
PLAINTIFF
County
v.
Docket Number
DEFENDANT
(to be filled in by the court)
CONSENT ORDER FOR EXPEDITED
JURY TRIAL
1. This Order is entered pursuant to Rule 1:1-2 and Evidence Rules 101(a)(4) and 102.
2. The parties request that the Court conduct a binding Expedited Jury Trial to resolve this
case. Counsel voluntarily agree to follow the rules and procedures set forth in this Order
and represent that their client(s) consent to same.
3. The jury shall consist of six persons with no alternates. Each party will be permitted
three peremptory challenges. The parties stipulate that if one juror is excused, the trial
shall proceed and a verdict may be rendered by 5 of the jury agreeing.
4. EVIDENCE: Each party may call one lay witness for live testimony. A videotape
deposition is considered to be live testimony. In addition, counsel may read, show or
present to the jury such of the following materials as are marked as exhibits in evidence
before the trial begins: any materials obtained or produced in discovery including but not
limited to depositions, answers to interrogatories, documents, admissions, expert reports,
statements, medical and hospital records, police reports, business records, “writings”
(Rule 801e), “photographs” (Rule 1001b), diagrams, and other materials. Documents and
materials not produced in discovery may be admitted in evidence by consent. The
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evidence will include definitions and diagrams of medical and other specialized terms
and procedures of which judicial justice is taken.
5. OBJECTIONS: The parties stipulate to: (1) the authenticity of all documents, writings,
and photographs; (2) the admission of all business records, expert reports and written
statements of persons not giving live testimony, subject to redaction of inadmissible
included statements; and (3) the reasonableness and necessity of charges in bills and
invoices for services, treatments, therapies, prescriptions, goods, materials and supplies.
The following types of objections to deposition testimony are waived: leading, asked and
answered, narrative answer, answer not responsive, cumulative, over broad,
argumentative, self-serving, and compound question. Before the trial begins, the Court
will rule on the following types of objections to the materials listed in paragraph 4:
relevance, undue prejudice, misleading, speculative, assuming facts not in evidence,
misquoting the evidence or the witness, inadmissible opinion or conclusion, privilege,
competence of declarant, and noncompliance with discovery rules or orders; and
appropriate redactions will be made. All arguments and rulings shall be placed on the
record and preserved for appeal. Except for highly prejudicial evidence inadvertently
overlooked, none of these types of objections may be made after the trial begins.
Counsel may object at trial to any misreading or mischaracterization of the evidence or
improper argument by counsel.
6. Subject to modification at the court’s discretion, each attorney shall have a maximum of
15 minutes for opening statements and 30 minutes for summations.
7. Requests to Charge may be submitted only on issues not covered by the Model Civil Jury
Charges.
8. Judgment will be entered upon the jury’s verdict.
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9. The following is also stipulated or ordered:
IT IS SO ORDERED: Date: ,
J.S.C.
We hereby consent to entry of this Order and certify that our clients agree to its
provisions:
Attorney for Plaintiff(s) Attorney for Defendant(s)
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