Pretrial Order

I spent most of Friday doing to final workup on a pretrial order for a jury trial I have in a few weeks on a medical malpractice case.  While I was going through it, I started thinking that this would be a much better way to handle complex divorces cases too.  In the order typically used, all witness including experts have to be listed along with all evidence and any objections.  This way, the court can go ahead and clear up any evidentiary issues before the trial gets going.  It also assists in that if you get an adverse ruling on some critical evidence, you have time to figure out how to get the evidence in another way or can tweak the strategy as needed.