Form 40.04A
(rule 40.04)

File number: 20____ ____ G __________

IN THE SUPREME COURT OF NEWFOUNDLAND AND LABRADOR
GENERAL DIVISION

BETWEEN :
                     (Plaintiff’s name) ____________________________            PLAINTIFF

AND 
                     (Defendant’s name) ___________________________        DEFENDANT

      (Modify title of proceeding as necessary.)

Certificate of Readiness

1.	The parties hereby jointly certify that, as of this date, this proceeding is ready for trial and that
•	pleadings have closed
•	no amendments to pleadings are contemplated
•	all relevant parties are before the court
•	all examinations for discovery have been completed, or are hereby waived
•	all interrogatories have been delivered and answered, or are hereby waived
•	lists of documents have been exchanged in accordance with the rules
•	all appropriate pre-trial applications have been taken
2.	Current estimates of the number of witnesses to be called are as follows (insert additional lines as necessary):

Party
	Number of Witnesses	
First Plaintiff:	                
	                             ______________	
Second Plaintiff:	                             ______________	
Third Plaintiff:
	                             ______________	
First Defendant:				                             ______________	
Second Defendant:
	                             ______________	
Third Defendant:
	                             ______________	

3.	(a)	Current estimates of the total of documents to be presented at trial are as follows (insert additional lines as necessary):

Party	Number of Documents
	
First Plaintiff:	
	                                ____________	
Second Plaintiff:	                                ____________	
Third Plaintiff:
	                                ____________	
First Defendant:				                                ____________	
Second Defendant:
	                                ____________	
Third Defendant:
	                                ____________	

(b)	A joint Book of Documents will/will not (choose one) be entered in evidence by consent.

(c)	It is anticipated that (check as required):

•	audio recordings may be entered/played in evidence
•	video recordings may be entered/played in evidence
•	a view of 			        may be required
•	a 			      language interpreter may be required for the evidence of  			             .

And the party or parties proposing same hereby undertake to make all necessary arrangements to facilitate such activities at trial.

4.	Current estimates of the number and area of expertise of expert witnesses to be called to give evidence are as follows:
Party	Number of Experts	Area of Expertise
	
First Plaintiff:	
	     ___________             	             _____________________	
Second Plaintiff:	     ___________             	             _____________________	
Third Plaintiff:
	     ___________             	             _____________________	
First Defendant:				     ___________             	             _____________________	
Second Defendant:
	     ___________             	             _____________________	
Third Defendant:
	     ___________             	             _____________________	

5.		It has been agreed that not more than 	         sitting days is a reasonable time for the hearing of all evidence and argument in this proceeding.

	OR

•	The parties are not in agreement as to their estimate of a reasonable time for the hearing of all evidence and argument in this proceeding. The estimates of each party of the time involved in presentation of that party’s case are as follows:

Party	Estimate of Time Required to Present Case
	
First Plaintiff:	
	                __________________________	
Second Plaintiff:	                __________________________	
Third Plaintiff:
	                __________________________	
First Defendant:				                __________________________	
Second Defendant:
	                __________________________	
Third Defendant:
	                __________________________	

6.	The parties do/do not [delete one] request a settlement conference in which case they estimate 	   hours for its completion.

7.	The parties do/do not [delete one] request a mini-trial in which case, they estimate 	     hours for its completion.

8.	The trial record has been filed pursuant to Rule 40.04(1)(c).

9.	(Check box if applicable)

•	Pursuant to the Jury Act we hereby jointly request that this proceeding be tried by a Judge with a Jury

	OR

•	This proceeding involves an action of defamation, malicious prosecution, false imprisonment, seduction or breach of promise of marriage and the      			    hereby requests, pursuant to subsections 32(1) and (2) of the Jury Act, that the issues of fact be tried by a judge with a jury.

	OR

•	The 			          hereby requests, pursuant to section 32(3) of the Jury Act, that this proceeding be tried by a judge with a jury, for the reasons that: ________________________________________________
___________________________________________________________
___________________________________________________________
______________________________________________________________________________________________________________________

10.	The parties hereby request, or if a settlement conference or mini-trial is requested, anticipate they will ultimately request:

•	the earliest available position on the General List;

	OR

•	a position that will result in trial not before 			         , on the General List;

	OR

•	a fixed date, for the reasons that: (Set out reasons.) 
_________________________________________________________________________________________________________________________________________________________________________________

OR

•	an early fixed trial date, for the reasons that: (Set out reasons.)
_________________________________________________________________________________________________________________________________________________________________________________

OR

•	The parties cannot agree on the manner and times of setting down of this proceeding for trial:
Party
	Party’s position and reasons	
First Plaintiff:	
	__________________________________________
__________________________________________
__________________________________________
__________________________________________

Second Plaintiff:	__________________________________________
__________________________________________
__________________________________________
__________________________________________

Third Plaintiff:
	__________________________________________
__________________________________________
__________________________________________
__________________________________________

	
First Defendant:				__________________________________________
__________________________________________
__________________________________________
__________________________________________

	
Second Defendant:
	__________________________________________
__________________________________________
__________________________________________
__________________________________________

	
Third Defendant:
	__________________________________________
__________________________________________
__________________________________________
__________________________________________

	

11.	If the proceeding is settled before trial, we will give the Registrar prompt notice of the settlement by filing a Memorandum of Settlement or Notice of Discontinuance pursuant to Rule 39.03.

12.	If we undertake to give promptly to the Registrar notice in writing of any information that may affect the estimated duration of trial or any changes in contemplated procedure or any circumstance that may result in delay of trial.

13.	The counsel who shall have carriage of the proceeding at trial and/or who are authorized and will be fully briefed to attend and participate in any pre-trial or other conference are:

Party	Name of counsel (you may list more than one)
	
First Plaintiff:	
	__________________________________________

Second Plaintiff:	__________________________________________

Third Plaintiff:
	__________________________________________

First Defendant:				__________________________________________

Second Defendant:
	__________________________________________

Third Defendant:
	__________________________________________

14.	 The parties jointly estimate that 		    hours is a reasonable time for the conduct of the pre-trial conference in this proceeding.

OR

 The parties cannot agree as to the estimate of a reasonable time for the conduct of the pre-trial conference.  The longest estimate of any party is 		     hours.

15.					 Practices outside of the judicial centre in which the pre-trial conference will likely be held and therefore requests permission to participate in any pre-trial conference by telephone/teleconference and hereby agrees to be responsible for the actual costs of such telephone call or teleconference.

DATED at _____________ (city/town), _______________________ (province or, if outside of Canada, country), on the ________ (day) of __________________ (month), ________ (year). 

__________________________
(Signature)
First Plaintiff/Solicitor for First Plaintiff

DATED at _____________ (city/town), _______________________ (province or, if outside of Canada, country), on the ________ (day) of __________________ (month), ________ (year). 

__________________________
(Signature)
Second Plaintiff/Solicitor for Second Plaintiff

DATED at _____________ (city/town), _______________________ (province or, if outside of Canada, country), on the ________ (day) of __________________ (month), ________ (year). 

__________________________
(Signature)
Third Plaintiff/Solicitor for Third Plaintiff

DATED at _____________ (city/town), _______________________ (province or, if outside of Canada, country), on the ________ (day) of __________________ (month), ________ (year). 

__________________________
(Signature)
First Defendant/Solicitor for First Defendant

DATED at _____________ (city/town), _______________________ (province or, if outside of Canada, country), on the ________ (day) of __________________ (month), ________ (year). 

__________________________
(Signature)
Second Defendant/Solicitor for Second Defendant

DATED at _____________ (city/town), _______________________ (province or, if outside of Canada, country), on the ________ (day) of __________________ (month), ________ (year). 

__________________________
(Signature)
Third Defendant/Solicitor for Third Defendant