Simple trial preparation checklist

I can’t remember if I have published thistrial checklist before, but I’mposting it again anyway. The purpose of this checklist isto have a very simple outline for preparing a non major case. My commentsare 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 foursentences

(Knee replacement surgery resulted inblood clot. The doctordidn’t respond until it was too late and the lower leg had to be amputated)

A.

__1. "STORY BOARD" PHOTOS

__2. MEDICAL BILLS

__3. DAMAGE PHOTO ENLARGEMENTS

__4. DAMAGE ELEMENT POSTER

__5. CLIENT BACKGROUNDPOSTER (Family, dates etc)

__6. FAULT POSTER WITH KEY EVENTS

__7. CLAIMS OF FAULT LIST

__8. EXHIBIT BLOW UPS

__9. AERIAL PHOTOS

__10. MEDICAL POSTERS WITHINJURY 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

—–

About Paul Luvera

Plaintiff trial lawyer for 50 years. Past President of the Inner Circle of Advocates & Washington State Trial Lawyers Association. Member American Board of Trial Advocates, American College of Trial Lawyers, International Academy, International Society of Barristers, member of the National Trial Lawyers Hall of Fame & speaker at Spence Trial College
This entry was posted in Uncategorized. Bookmark the permalink.

Leave a Reply

Your email address will not be published. Required fields are marked *

This site uses Akismet to reduce spam. Learn how your comment data is processed.