Pretrial memoranda shall include the 16 items enumerated in R. 4:25-1(b), set forth in the same sequence and with corresponding numbers, and the following additional items, numbered as indicated: (17) The date the attorneys for the parties conferred and matters then agreed upon; (18) A certification that all pretrial discovery has been completed or, in lieu thereof, a statement as to those matters of discovery remaining to be completed; (19) A statement as to which parties, if any, have not been served and which parties, if any, have defaulted.
Rule 4:25-3.Form of pretrial memoranda
Last amended September 1, 1994 · Current through June 18, 2026 · Last verified July 7, 2026
In one sentenceRule 4:25-3 prescribes the pretrial memorandum's form: the sixteen items from the pretrial-order rule in the same sequence, plus three more — the attorney-conference date and agreements, a discovery-completion statement, and a statement of unserved or defaulted parties.
Full Text of Rule 4:25-3
Amendment History
New Jersey publishes each rule’s amendment record in a “History” note beneath the rule. It is reproduced verbatim below; the “R.R.” citations refer to the former Revised Rules numbering the current rules replaced.
Source-R.R. 4:29-3(a) (b) (c) (d) (e). Caption amended, paragraph (b) adopted, and former paragraphs (b), (c) and (d) deleted July 7, 1971 to be effective September 13, 1971; paragraph (b); amended July 14, 1972 to be effective September 5, 1972; caption; amended, paragraph (a) deleted and caption of paragraph (b) deleted July 13, 1994 to be effective September 1, 1994.
Plain-English Summary
The pretrial memorandum mirrors the pretrial order and adds a few practical items. It must include the sixteen items enumerated in Rule 4:25-1(b), set out in the same sequence and with corresponding numbers.
Three additional items follow: the date the attorneys conferred and what they agreed on; a certification that discovery is complete or a statement of what remains; and a statement of which parties, if any, have not been served or have defaulted.
Frequently Asked Questions
What goes in a New Jersey pretrial memorandum?
The sixteen items from the pretrial-order rule in the same sequence, plus the attorney-conference date and agreements, a discovery-completion certification, and a statement of any unserved or defaulted parties.
Source & verification. The rule text and amendment history are reproduced verbatim from the
official New Jersey Rules of Court (N.J. Ct. R. 4:25-3). Prescribed by the Supreme Court of New Jersey (N.J. Const. art. VI, § 2, ¶ 3). The plain-English summary is original and written by us. Last verified July 7, 2026. ·
Official source
Also known as: form of pretrial memorandapretrial memorandum contents