Can I write in first person when write my pretrial memorandum

CAN you, yes. Should you, no. Litigation is complex and there are a lot of rules governing it. You are obviously pro per [representing your self], so you need to become very familiar with the code of civil procedure of your state and the local rules of your county. Learn to love the law library because that is where you should spend a lot of time. It would be better to have an attorney. Use the .com web site to find an attorney in your area. In addition to that, contact your local bar association for referral to an attorney who specializes in this or talk to friends and neighbors to ask about an attorney they have used and liked. Often, but not always, the attorney will do an initial consultation free of charge. You will then be in a better position to determine what to do next. Best of luck to you!

In addition to Attorney Mason's excellent answer, I strongly suggest you go to a law library and find examples of pre-trial memoranda, so you have a basis for comparison. The facts in those samples and your case will be different, but the structure should be the same.

The purpose of a pre-trial memorandum is to frame the action for the court in preparation for trial. It is not an explicitly advocacy piece of writing (although written in best light) — it is more a procedural piece to let the court know what facts, law, and issues are in dispute and what and how evidence is expected be presented at trial. It is also provides the judge a scheduling tool for the trial, a progress report of the litigant’s preparation for trial, and an indicator of a possible settlement between the litigants. Based on the Judge’s reading of the memo, the judge may even suggest avenues for approaching settlement. The pretrial memo is expected to be an objectively presented and consequently a third-person presentation lends itself best to the task. It more clearly separates facts from opinion and opinion from pleading. I would stay away from using first-person writing. This is not legal advice and is not intended to create an a ttorney-client relationship. You should speak to an attorney for further information.