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