SIMPLE TRIAL PREPARATION CHECKLIST
I can't remember if I have published this trial checklist before, but I'm posting it again anyway. The purpose of this checklist is to have a very simple outline for preparing a non major case. My comments are added for explanation. This is to serve as an example for you to use in creating your own checklist.
TRIAL CHECKLIST
CASE TITLE: (The case of too little, too late)
CASE THEME: (An ounce of prevention is worth a pound of cure)
FAULT
1. (Ignored the increasing & multiple signs of a clot in the leg)
2. (When he react, he didn't do the correct medical steps)
3. (When he finally realized he needed to involve a vascular surgeon it was too late to save the leg)
CASE DESCRIPTION -
No more than four sentences(Knee replacement surgery resulted in blood clot. The doctor didn't respond until it was too late and the lower leg had to be amputated)
A. EXHIBITS
__1. "STORY BOARD" PHOTOS
__2. MEDICAL BILLS
__3. DAMAGE PHOTO ENLARGEMENTS
__4. DAMAGE ELEMENT POSTER
__5. CLIENT BACKGROUND POSTER (Family, dates etc)
__6. FAULT POSTER WITH KEY EVENTS
__7. CLAIMS OF FAULT LIST
__8. EXHIBIT BLOW UPS
__9. AERIAL PHOTOS
__10. MEDICAL POSTERS WITH INJURY LIST
__11. MEDICAL ILLUSTRATION
__12. "STORY BOARD" OF EVENTS
__13. POSITIVE PRINTS X RAYS
__14. CT, MRI etc PREPARED
__15. HOSPITAL RECORDS: (subpoena originals or stipulation)
__16. DAY IN LIFE/VIDEO/STILL
__17 WAGE LOSS EXHIBITS
__18. COMPUTER SIMULATION
__19. PHOTOS OR VIDEOS
__20. AUTHORATIATIVE ARTICLES OR BOOKS (CX)
B. EQUIPMENT
__1. ELMO
__2. PROJECTOR
__3. SCREEN
__4. COMPUTER
C. TRIAL NOTEBOOKS
1.__TRIAL NOTEBOOK - Trial and Cross examinatin material
__2. TESTIMONY NOTEBOOK - Witness testimony arranged alphabetically
__3. RESOURCE NOTEBOOK - Data and exhibits
__4. JURY NOTEBOOK - Outlines for voir dire & forms
C. TRIAL PREPARATION
__1. MOTION IN LIMINE
__2. TRIAL BRIEF
__3. JURY INSTRUCTIONS
__4. VOIR DIRE
__5. OPENING STATEMENT
__6. DIRECT EXAM
__7. CROSS EXAM
__8. SUMMATION
C. WITNESS PREPARATION
__1. WITNESS SCHEDULE DETERMINED
__2. CLIENTS PREPARED: a. Advised re dress b. See video c. Read depo + interrogs
__3. FACT WITNESSES: a. Subpoenaed/Prepared b. Given depos/statements
__4. MEDICAL EXPERTS: a. Seen medical exhibits b. Seen bills c. Prepared
__5. NON MEDICAL EXPERTS: a. Seen exhibits b. Prepared
__6. NOTICE OF ATTENDANCE TO DEFENDANT
__7. LAY DAMAGE WITNESSES PREPARED
__8. INVESTIGATION OFFICER PREPARED
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