If the plaintiff merely denies everything stated by the defendant in his plea, no reply is necessary. If a defendant filed a claim in reconvention (called a counterclaim), the plaintiff will be obliged to file a plea to such a counterclaim, which is similar to the defendant's plea to the claim in convention (the plaintiff's claim). Rule 21 (MC) indicates specifically when pleadings are considered closed. This is called "litis contestatio", and it means that the litigants have reached finality in regard to all the allegations of fact forming the basis of the claim and defence. Once the pleadings are closed, a plaintiff or defendant may apply for a trial date. Various documents are exchanged before the matter is ready to proceed to trial. The three most important are   Rule 23 (MC) and Rule 35 (HC) deal with the discovery of documents. Both are substantial and indicative of the importance of this step prior to proceeding to trial. Both plaintiff and defendant will normally provide each other with a request to discover. This notice will contain portions consisting of Rule 23 (1), (6) and (11) of the MC, and Rule 35 of the HC. It requests either party to discover—that is, set out in a list—all the documents, correspondence, etc., which they have available, and to make these items available to the other party. A party receiving such a request must respond by filing a discovery affidavit within a certain period. On receipt thereof, the receiving party may request copies of any or all documents listed therein. The purpose of discovery is to ensure that an opponent is not caught by surprise at trial. Any document not discovered may normally not be used at trial unless by consent or on application to court. While the issues will have been resolved, to a large extent, prior to the close of pleadings, it may be possible to reach consensus on some further issues that were placed in dispute before the close of pleadings or were not dealt with in the pleadings. This is normally done at a pre trial conference. Rule 25 (MC) and Rule 37 (HC) deal with this question. Rule 37 lists the issues that should be raised at the conference:   Although it is generally thought to be advisable that all these aspects be covered in a pre-trial conference in the magistrate's court, the rule does not specify this. The pre-trial conference is normally attended by the parties' legal representatives. In some courts, the registrar will refuse to award a trial date until the pre-trial conference has been held.