(A) On or before the pretrial conference, submit to the Court proposed jury instructions, together with sufficient copies to be served upon opposing counsel. Such proposed instructions shall embody all jury issues raised by each party's theory of the case, except that instructions submitted on behalf of the defendant(s) may be limited to the defendant's theory of the case if the defendant is not prosecuting a counterclaim or cross-claim. Attached to the proposed instructions of all parties (on a separate sheet of paper) shall be a memorandum showing the source of legal authority for each instruction so submitted. Such instructions are to be filed with the Clerk of the Court but shall not be deemed to constitute a part of the official record and tendered instructions on behalf of a party unless and until a party re-submits or tenders such instructions, or portions thereof, to the Court at the conclusion of all evidence on the trial of the case.

(B) Not less than 7 days before the pretrial conference, plaintiff's counsel shall submit a memorandum brief on any unusual problems anticipated to arise in the trial of the action and defendant's counsel may, within 4 days prior to the pretrial conference, reply thereto should he or she desire.

(C) Prior to the pretrial conference, counsel for the parties shall meet, or confer by telephone, for a final discussion of (1) possibility of settlement, and (2) preparation of written stipulation of all possible facts, and shall advise the Court at the pretrial conference that such final conference was held and the results thereof.

(D) Once a trial date has been set, neither party shall be granted a continuance unless the Court is satisfied that the reasons were both unavoidable and unforeseeable on the setting date.