I’m preparing for a major damage trial scheduled to start in a couple of weeks. I’m going through my check lists to get ready so I thought I’d share this basic check list I use/ My procedure is to have individual check list for different aspects of the trial. This one is simply a general reminder list of things to consider. Perhaps something her will be of help to you in your trial practice. 

                                                           
                                                     ATTORNEY TRIAL OUTLINE

PRE-TRIAL

Experts  

Economist

Cost of care
Animation
Posters/illustrations
Medical illustrations

Other

Focus – internet?
Time line/chronology
Review file contents
Pleadings & discovery
Prepare notebooks:

    (1) Cx
    (2) Resource
    (3) Witness
    (4) Jury
    (5) Trial

Discovery work

Depo summaries
Loaded into software

Medical – Damages

Day in life
Medical chronology

TRIAL PREPARATION

General

Theme
Fault list
Tech at trial
Trial schedule
Sadow jurors?l

Trial

Jury Selection outline
One page summary
Written jury questions
Opening outline
Direct Outline

    (1) exhibits
    (2) depo excerpts

Witnesses

Lay witnesses
Liability
Damage
Witness schedule
Prepare
Notice of attendance
Subpoenas

Exhibits

Depo excerpts in trial software
Key documents same
Key photos
Posters

    (1) Facts/dates
    (2) Bills
Blow ups
PowerPoint
Time line
Medical chronology
Model
Animation
Day in life
Wage loss
Calendar for period
Medical bills
Photos
Injury list
Fault list
Xrays etc
Hospital & records

Pre-trial Legal

Notebook for judge
Motions in limine
Jury instructions
Trial brief
Evidence briefs
Exhibits in opening
Witness disclosure
Alternate juror
Exclusion of witnesses
Judge question list
Written jury questions

Other Trial Preparation

Trial materials