(a) Prior to Pretrial. In cases that are to be pretried, the attorneys shall confer before the date assigned for the pretrial conference in order to reach agreement on as many matters as possible.
Rule 4:25-7.Attorney conferences; exchange of information
Last amended September 3, 2002 · Current through June 18, 2026 · Last verified July 7, 2026
In one sentenceRule 4:25-7 requires attorneys to confer before trial and, in cases not pretried, to exchange pretrial information seven days before trial — including proposed voir dire, jury instructions, and a verdict form in jury cases — with sanctions for non-compliance.
Full Text of Rule 4:25-7
(b) Exchange of Information. Except as otherwise provided by paragraph (d) of this rule, in cases that have not been pretried, attorneys shall confer and, seven days prior to the initial trial date, exchange the pretrial information as prescribed by Appendix XXIII to these rules. At trial and prior to opening statements, the parties shall submit to the court the following in writing: (1) copies of any Pretrial Information Exchange materials that have been exchanged pursuant to this rule, and any objections made thereto; and (2) stipulations reached on contested procedural, evidentiary, and substantive issues. In addition, in jury trials, the parties shall also exchange and submit (1) any proposed voir dire questions, (2) a list of proposed jury instructions pursuant to R. 1:8-7, with specific reference either to the Model Civil Jury Charges, if applicable, or to applicable legal authority, and (3) a proposed jury verdict form that includes all possible verdicts the jury may return. Failure to exchange and submit all the information required by this rule may result in sanctions as determined by the trial judge.
(c) Continuing Obligation. Attorneys shall have the continuing obligation to report to the court any stipulations reached during the course of the trial.
(d) Waiver of Exchange. The parties may, in writing, waive the requirement of the exchange of information as set forth in paragraph (b) of this rule, but such waiver shall not affect the obligation to provide that information to the court at the commencement of trial.
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 of paragraph (a)-R. 4:25-3(a). New rule adopted July 13, 1994 to be effective September 1, 1994; caption; amended, paragraph (b); amended, and new paragraph (c) adopted July 5, 2000 to be effective September 5, 2000; paragraph (b); amended and new paragraph (d) added July 12, 2002 to be effective September 3, 2002.
Plain-English Summary
Trial preparation includes a duty to cooperate. In cases to be pretried, attorneys confer before the pretrial conference to narrow disagreements. In cases that are not pretried, they confer and, seven days before the initial trial date, exchange the pretrial information the court’s form prescribes.
Jury cases require more. At trial, before opening statements, the parties submit the exchanged materials and their objections, any stipulations, and, in jury trials, proposed voir dire questions, a list of proposed jury instructions keyed to the model charges or legal authority, and a proposed verdict form covering all possible verdicts. Failing to exchange and submit the required information may result in sanctions, and the parties may waive the exchange in writing without waiving the duty to give the information to the court.
Frequently Asked Questions
What must attorneys exchange before trial in New Jersey?
In cases not pretried, the pretrial information prescribed by the court’s form, seven days before trial, plus — in jury cases — proposed voir dire questions, a list of proposed jury instructions, and a proposed verdict form submitted before opening statements.
Source & verification. The rule text and amendment history are reproduced verbatim from the
official New Jersey Rules of Court (N.J. Ct. R. 4:25-7). 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: attorney conferencesexchange of informationpretrial information exchangevoir direjury instructionsverdict form