Q: Can I update a pretrial memorandum to reflect new witnesses before trial and what is protocol to do this?
A:
You're supposed to do that. Check the rules of court for your court and for Massachusetts to ensure compliance.
See: http://www.aeesq.com/divorce-attorney/child-custody/
More details are necessary to provide a professional analysis of your issue. The best first step is an Initial Consultation with an Attorney. You can read more about me, my credentials, awards, honors, testimonials, and media appearances/ publications on my law practice website, www.AEesq.com. I practice law in CA, NY, MA, and DC in the following areas of law: Business & Contracts, Criminal Defense, Divorce & Child Custody, and Education Law. This answer does not constitute legal advice; make any predictions, guarantees, or warranties; or create any Attorney-Client relationship.
A: If you are at the pre-trial stage it is likely that your discovery deadline has also passed. You may need to try to extend the discovery deadline, if so. The other side may want to depose your additional witnesses and so you should be aware that your updating your pretrial memo may be insufficient. Is it your plan to try your case yourself? Be aware that pro se parties are still held to follow the rules of procedure and evidence.
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