Thank you for your question.
The pre-trial conference will cover the following types of issues:
1. How much discovery is left in the case? You need to be able to tell the judge whether you need to conduct any further discovery, and if so what kind of discovery exactly and how long it is going to take you. You also need to be prepared to answer an argument from the plaintiff that they will need additional discovery. If you disagree with the plaintiff, then you need to be able to state why the plaintiff should have already finished the discovery and that the plaintiff is merely delaying now.
2. How long will the trial take? You need to know how many witnesses you are going to call and have an approximation of how much time you will need to make your case.
3. When are the parties available for trial? You need to know the dates on which you can for sure go to trial. If you have any third-party witnesses, you need to know whether they are available on your proposed dates as well.
4. Any other motions which you want the court to hear? If there are other motions, such as motions for summary judgment or motions to exclude experts, you need to tell the court that these motions need to be submitted and heard before the trial starts.
In regard to your question about your deposition, if you are being deposed then there is absolutely no reason that you need to blow anythiing up or mount it. That is the other sides responsibility. You only have to bring with you the actual documents being requested. If these are photographs, then you only have to bring the photographs. You will want to make sure that the photos you bring are copies and not the originals.
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