TRIAL REMINDER OUTLINE

We returned from our family cruise and and I am working to prepare for a trial starting Monday in Seattle involving a Florida corporation’s operation of delivery trucks transporting goods purchased from Sears and Best Buy on our public roads. Their breach of trust to the traveling public for providing safe drivers resulted in a rear end collision with our client’s pick up truck. The resulting fire burned him to death leaving a young pregnant wife. Due to the trial I haven’t had time to prepare something so I’m printing a basic trial checklist which I may have shared before. You can revise to fit your own approach to trials.

TRIAL CHECKLIST

CASE TITLE:
CASE THEME:

FAULT -RULES BROKEN
1.
2.
3.

CASE DESCRIPTION: (briefly stated starting with defendant’s betrayal of trust)

A. PREPARE KEY DOCUMENTS
__1. DECIDE WHAT LARGE POSTERS vs SLIDES OR ELMO
__2. MEDICAL BILLS
__3. DAMAGE & LIABILITY PHOTOS
__4. DAMAGE ELEMENTS OUTLINE
__5. BACKGROUND OUTLINE (Family, dates etc)
__6. FAULT & RULES OUTLINE
__7. AERIAL PHOTOS
__8. BODY – INJURY AREA DRAWING
__9. ANNIMATION OR VIDEOS
__10. MEDICAL RECORDS
__11. MEDICAL ILLUSTRATIONS
__12. “STORY BOARD” DRAWING
__13. POSITIVE PRINTS X RAYS
__14. CT, MRI etc PREPARED
__15. HOSPITAL RECORDS
__16. DAY IN LIFE/VIDEO/STILL
__17 WAGE LOSS
__18. ARTICLES OR BOOKS (CX)
__19. KEYNOTE OR POWERPOINT SLIDES

B. EQUIPMENT

__1. ELMO
__2. PROJECTOR & SCREEN
__3. LAP TOP & IPADS
__4. PORTABLE PRINTER
__5. PORTABLE PAPER
__6. CORDS & POWER STRIPS

C. TRIAL NOTEBOOKS-IPADS

__1. TRIAL NOTEBOOK COMPLETED – IPAD DOWNLOADED
__2. TESTIMONY NOTEBOOKS HARDSCOPY ALPHABETICAL
__3. RESOURCE NOTEBOOK HARDCOPY NUMERICAL TABS WITH INDEX
__4. JURY NOTEBOOK COMPLETE
__5. SOFTWARE FOR JURY, TRIAL ETC

D. TRIAL PREPARATION

__1. MOTION IN LIMINE FILED/ORDERS (see standard set)
__2. TRIAL BRIEF
__3. JURY INSTRUCTIONS INCLUDING PRELIMINARY
__4. VOIR DIRE PREPARED
__5. OPENING STATEMENT PREPARED WITH EXHIBITS/SLIDES
__6. DIRECT EXAM OUTLINES PLUS EXHIBITS TO BE USED
__7. CROSS EXAM OUTLINES SAME
__8. SUMMATION OUTLINE WITH PLANNED EXHIBITS

E. WITNESS PREPARATION

__1. WITNESS SCHEDULE DETERMINED
__2. CLIENTS
a. Advised re dress
b. Seen video about trial
c. Read depostion & interrogatory answers
__3. FACT WITNESSES
a. See above
b. Subpoenaed/Prepared
c. read depos/statements
__4. MEDICAL EXPERTS
a. Seen medical exhibits
b. Seen bills – “reasonable & necessary”
c. Prepared – exhibits & articles
__5. NON MEDICAL EXPERTS
a. Read depositions, reports & interrogatories
b. Reviwed exhibits, illustrations & video
c. Reviewed testimony
__6. NOTICE OF ATTENDANCE?
__7. LAY DAMAGE WITNESSES – selected & prepared
__8. INVESTIGATION OFFICERS – seen reports & exhibits

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