We went to assignment court on Friday and set a combined case management and settlement conference for Feb. 9. We learned that the trial record has to be filed 30 days before trial and that the trial period begins on February 21 meaning we have until Monday to serve and file the trial record.
I have read rule 23 and everything else I can find online and think that I am ready to put together the trial record with the exception of the statement of agreed facts, that is, I expect, very important.
However, getting this part of the record done would require that we follow the process for submitting a Form 22 - request to admit that gives the Respondent 20 days to respond.
Have I just screwed up badly or do I just serve and file the trial record Monday with no agreed statement of facts and serve the admit asap then go to the trial management conference and ask for an adjournment to allow for the admit process to finish. It seems that, as the applicant it is on me to be ready for trial and I fear that the Judge at the trial management conference might not be too pleased with this and the respondent might present it as a delaying or rushing tactic.
Alternately, could I ask the trial management judge for leave to amend the trial record once the 20 days for response to the admit is done?
Any advice appreciated.
I have read rule 23 and everything else I can find online and think that I am ready to put together the trial record with the exception of the statement of agreed facts, that is, I expect, very important.
However, getting this part of the record done would require that we follow the process for submitting a Form 22 - request to admit that gives the Respondent 20 days to respond.
Have I just screwed up badly or do I just serve and file the trial record Monday with no agreed statement of facts and serve the admit asap then go to the trial management conference and ask for an adjournment to allow for the admit process to finish. It seems that, as the applicant it is on me to be ready for trial and I fear that the Judge at the trial management conference might not be too pleased with this and the respondent might present it as a delaying or rushing tactic.
Alternately, could I ask the trial management judge for leave to amend the trial record once the 20 days for response to the admit is done?
Any advice appreciated.
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