West Palm Auto wreck Master Trial Preparation Checklist 1800-HURT-911

West Palm Auto wreck Master Trial Preparation Checklist 1800-HURT-911
Trial Date: ______________
Master Trial Preparation Checklist
____________________ vs. ___________________

I. To Be Completed by AT LEAST 60 DAYS Before Trial (By __________, 20__)
Completed
• Any Motions for Summary Judgment __________
• All experts (ours and other parties) identified and deposed __________
• All our discovery responses reviewed and supplemented,
where necessary __________
• All of opponents’ discovery reviewed and request for
supplementation, if any, sent out and any motions to
compel filed and taken up __________
• Outline what we must prove on liability or
defense and how we will prove it __________
• All special damages itemized and either how we will prove
them outlined or stipulations and/or admissions by
requests for admission received __________
• All our witnesses’ contact information and subject
matter of their testimony identified __________
• All potential exhibits identified and means of admission
determined (any expensive exhibits may not be prepared at
this point but we should know what we will need) __________
• Affidavits or certifications have all been obtained to meet
requirements of business records exception and any required notices
sent or we are prepared to subpoena records and/or custodian __________
• All depositions for proof have been taken or are scheduled __________
• Legal research list prepared __________
• All potential subjects of motions in limine identified
(both from us and against us) __________
• Identify objectionable portions of depositions for proof __________
• Decisions made regarding focus group and, if needed, it has been
conducted or is scheduled __________
• Discussions had as to case themes and trial presentation __________
• Trial notebook being prepared __________
• Witness and/or issue notebooks prepared __________
• Calendar prepared for all deadlines (after consulting
scheduling order, local rules, judges’ rules) __________
• Our experts and witnesses have been informed of
trial date and cleared of conflicts __________
• Determination and reservations made as to necessary
equipment for trial; e.g., VCR, TV, Projector,
Screens, Laptop, Visual Presenter, etc. __________
Notes:
II. Items to Be Completed by AT LEAST 30 DAYS Before Trial (By __________, 20__)
Completed
• Prepare all Motions in Limine and Supporting Suggestions
to be filed __________
• Prepare all designations of deposition testimony to be filed __________
• Research and draft all trial briefs or memoranda __________
• Try to reach agreements on all stipulations with opposing counsel __________
• Discuss with videographer the editing of all video depositions
to be shown jury with tentative designations of those depositions
(subject to any objections which may be sustained) __________
• Prepare remaining exhibits including scanning all documents that will be used electronically at trial __________
• Preparation of all parts of trial notebook and trial
manual that can be completed __________
• Any focus groups completed __________
• Refine decisions concerning case presentation and trial themes __________
• Identify order of proof __________
• Update calendars with any changing deadlines __________
• Develop outline for voir dire __________
• Outline opening, closing, and witness direct and cross-examinations __________
• Develop with videographer and place on laptop video clips for
impeachment of key witnesses __________
• Prepare all proposed possible jury instructions and verdict forms __________
• Start getting psyched for trial __________
Notes:

III. Items to Be Completed in Last 30 Days Before Trial Date Due Completed
(By __________, 20__)
• Disclose witnesses and exhibits to opponents __________ __________
• Disclose intent to use any video depositions at trial __________ __________
• Submit any objections to the opponent’s use of
video depositions at trial __________ __________
• Obtain daytime telephone numbers from all witnesses
so that you may contact them during trial __________ __________
• Issue subpoenas for witnesses __________ __________
• Schedule, meet with, and prepare witnesses __________ __________
• Confirm equipment for trial __________ __________
• Organize, copy, pre-mark (where permitted) exhibits __________ __________
• Edit video depositions for use at trial __________ __________
• Argue all motions, including motions in limine
(if not already completed) __________ __________
• File trial brief __________ __________
• File jury instructions and verdict forms __________ __________
• Get jury list if available __________ __________
• Make any checklist of proof for use during trial __________ __________
• Prepare for pretrial conference __________ __________
• Complete and meet all requirements and required
dates of scheduling order and pretrial orders __________ __________

Topics to Cover at Pretrial Conference
• Jury selection and location of panel during jury selection
• Any time limitations on opening statements, closing arguments, etc.
• Daily schedule court follows
• Equipment available in the courtroom
• Pre-marking of exhibits
Notes: