Check List

90 days and counting

Don t let the details slip through the cracks on your way to the courthouse. Keep this checklist handy during your last three months of trial preparation.

90 days to trial

  • Review the file to refocus your theme
    • Assign tasks and responsibilities
    • Schedule periodic meetings to check status
    • Refine your theme
  • Meet with your client
    • Discuss current medical condition and other damages issues
    • Identify trigger testimony
    • Meet with family members and friends
    • Give client copies of discovery materials
  • Review medical records and bills
    • Order updated records and bills
    • Call client to identify new health care providers
    • Pay attention to records produced before depositions
  • Give updated records to experts
  • Organize medical expense binder
  • Notify experts of the trial date
  • Update expert information
    • Schedule time for experts to re-examine client
    • Have life care planner and economist supplement reports
    • Provide supplemental reports to the defense
    • Find out whether life care plan recommendations have been or can be implemented
    • Give experts copies of their depositions and completed errata sheets, as well as other relevant depositions
  • Follow up on depositions
    • Create time line using deposition testimony and records
    • Follow up on requests for records revealed during depositions
  • Review elements of proof
    • Create checklist that identifies the source of proof for each element of the case
    • Correct deficits if some proof is lacking
  • Prepare witness checklist
  • Have factual and legal research ready
  • Review learned treatises
    • Make sure you understand the information in learned treatises
    • If not exclusively for impeachment, disclose to defense if necessary
    • Use experts to locate articles
    • Determine who is authenticating
  • Update discovery responses
    • Review and supplement discovery responses
    • Review defendants discovery responses to determine whether they are sufficient
    • If deficient, send good-faith letter
    • If good-faith letter goes unanswered, file motion to compel
  • Prepare testimony outlines
  • Organize trial notebooks
  • Update lien information
  • Prepare demonstrative evidence
    • Determine witnesses to authenticate and verify accuracy
    • Research and prepare arguments for objections
  • Develop impeachment evidence
    • Review defense expert deposition transcripts
    • Get transcripts of experts depositions in other cases
  • Plan for jury selection
  • Conduct focus groups

60 days to trial

  • Continue client preparation
  • Send experts another reminder
    • Schedule trial preparation sessions for two weeks before trial
    • Schedule preparation time the night before trial testimony
    • Check with experts about presentation of exhibits or suggestions for exhibits
  • Update motions in limine
  • Prepare subpoenas
  • Request admission of facts
  • Look into members of the jury pool
  • Prepare pretrial conference filings
  • Organize joint medical records and expenses
    • Send letter to defense to gauge interest in joint exhibit
    • If defense agrees, send a copy of records in draft format
    • Place into final format, Bates stamped, and make copies
    • Send invoice to all counsel for their portion
  • Take time off

30 days to trial

  • Confirm logistics
  • Get subpoenas in order
  • Transport the file
  • Continue client and witness preparation
  • Visit the courtroom
  • Narrow down field of witnesses

Finalize demonstrative evidence

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