Court of Common Pleas
Honorable Robert O. Baldi
Court of Common Pleas
Standard Operating Procedures
Courtroom Procedures Generally
Follow the local court rules.
There should be a heightened sense of civility in a courtroom at all times. Judge Baldi expects all attorneys to be civil to each other and to all parties and witnesses. When in Court attorneys and parties should refer to each other, Court personnel and/or anyone else in the Courtroom, by their last name or title only (Mr. Jones, Ms. Smith, defense counsel, etc.).
The Court welcomes submission of legal authority, either by memo or by copies of relevant cases, statutes, etc. Bring an extra copy for Judge Baldi and his law clerk, and provide an extra copy of any such submissions to opposing counsel and/or parties that are unrepresented.
The Court prefers the parties to exchange and pre-mark exhibits before a trial begins. Therefore, if they have not already done so the parties should arrive in Court early and confer with one another regarding the exhibits. It is the duty and responsibility of the litigants to bring sufficient copies of all exhibits to provide a copy to all the parties, any witness who needs to refer to same during the presentation of the case, and a copy for the Court.
The Court believes that the parties should be able to stipulate to many facts and therefore, at the beginning of the case or controversy, the parties should precisely set forth, to the Court, the following:
Subject matter and nature of the dispute;
Stipulations of fact which are necessary to develop a record, but which are not contested;
A precise statement as to what is being contested and each party’s position regarding each matter contested.
Objections should be stated formally and responded to formally. Objections should not be used as an opportunity to bicker or to make extraneous statements not specifically related to the objection
Prior to selection of the jury, the attorneys must meet, review and exchange, and pre-mark all exhibits either side intends to use or reserves the right to use during the jury trial. This does not include an exhibit which would be used for impeachment only. Courtroom procedure #4 is mandatory for all jury trials.
Any document, exhibit, photo, etc., that counsel wishes to publish to the jury, must be shown to opposing counsel before it is published and the item must have an exhibit number. If counsel intends to use a poster board exhibit, counsel must supply the Court with a smaller version to be kept with the record as the exhibit. Nothing should be projected on a screen, visible to the jury, prior to opposing counsel reviewing same.
Points for Charge should be submitted no later than the first day of trial, at the beginning of the case, with the understanding that something might occur during the course of the Trial which would warrant a supplemental Point for Charge. The Court welcomes the electronic submissions of Points for Charge. Litigating counsel should communicate directly with the Judge’s Law Clerk regarding the method of submitting Points for Charge electronically.
The parties must speak with each other and make a good faith effort to agree on a final set of instructions, and where there is no agreement the parties should be able to articulate, very specifically, objections and counter-proposals.
The Court generally uses Pennsylvania Suggested Standard Civil Jury Instructions. If a party wishes to submit a jury instruction which is not part of the standard civil jury instructions, the submission should be accompanied with legal authority and an explanation of why the specific request is not adequately covered within the standard instructions. The parties should note that the Court tries to incorporate a cohesive final instruction and therefore each separate instruction needs to be located within an appropriate place in the overall charge to the jury. The Court will look to the parties for guidance with respect to same.
Objections should be made formally and counsel must be careful to not make any statements during an objection which could alert a witness to change their testimony or improperly influence the jury. The objections are directed to the Court and, where necessary and appropriate, counsel should promptly request a side bar.
Objections made during a videotaped deposition, which cannot be resolved by the parties, and which require the Court’s ruling, must be brought to the Court’s attention whenever possible, as a pre-trial Motion before the trial begins, but certainly no later than 4 hours prior to the intended use of the videotape deposition to allow the Court time to review same. Prior to submitting an objection to the Court, the parties must confer with one another with respect to each objection and make a good faith effort to resolve the objections on their own before presenting the objections to the Court. Objections which a party wishes to preserve and which require a Court ruling should be identified in a written Motion which contains the basis of the objection, legal authority for same, and the suggested remedy (i.e.: delete lines 6 through 18 on page 4 of the transcript). The party opposing the objection should provide the Court with a written response, legal authority and, where appropriate, a suggested remedy (i.e.: delete lines 6 through 8 but leave lines 9 through 15 with a specific instruction to the jury explaining why the subject matter has limited relevance).
Lawyers should remain civil, one to the other, throughout the proceeding and work in a cooperative fashion with the Court to avoid error.
De Novo Equitable Distribution Trials
Prior to presenting evidence at a De Novo Equitable Distribution Trial, counsel and/or the parties (were parties are unrepresented) must confer with one another to make a good faith effort to limit the scope of the trial, by entering into a written stipulation of facts identifying all relevant facts which are agreed upon and identifying with specificity those issues of fact which have not been agreed upon. Presumably the parties have already appeared before a Master, and a Master’s report has been issued which has identified most, if not all, of the assets, as well as various facts relevant to the Court’s final determination (i.e.: length of marriage, marital health of the parties, tax consequences, etc.) Counsel and the parties may wish to use that report to help them focus on the stipulation that they will jointly present to the Court. If at the beginning of the trial it appears that a good faith effort to complete the stipulation has not been made, counsel and/or the parties will be sent to another room, on the day of the hearing, to begin working on the project, until the project is completed.
Honorable Susan Devlin Scott, President Judge
Honorable Rea B. Boylan
Honorable Alan M. Rubenstein
Honorable Robert J. Mellon
Honorable C. Theodore Fritsch Jr.
Honorable Albert J. Cepparulo
Honorable Clyde W. Waite
Honorable Jeffrey L. Finley
Honorable Diane E. Gibbons
Honorable Wallace H. Bateman
Honorable Robert O. Baldi
Honorable Gary Gilman
Honorable James M. McMaster
Honorable R. Barry McAndrews
Honorable John J. Rufe
Bucks County Courthouse
55 E. Court Street
Doylestown, PA 18901