Here's a list of things that should be completed in the months or weeks leading up to trial. It's based on a checklist I keep in my computer and transfer from case to case. By necessity, it's somewhat individualized, but it could easily be used as a model for a checklist of your own.
- Supplement discovery
- Complete exhibit list; think about foundation for each exhibit
- Work out stipulations for exhibits
- Prepare demonstrative exhibits
- Complete Rule 237 notice to produce
- Prepare motion in limine
- Complete trial memorandum (required in Madison County and elsewhere; should contain a short statement of the case and a list of the parties and attorneys)
- Complete pretrial brief, if necessary
- Organize trial notebook
- Complete jury instructions
- Draft a "proof chart"--a list of required elements, and how each will be proved
- Sketch out testimony of the witnesses, based on the proof chart
- Line up witnesses
- Prepare voir dire and opening statement; make some preliminary notes about closing
- Solve all trial technology problems
Tomorrow: A Method of Organizing a Trial Notebook
How do you prepare a proof chart? I know that there are two columns, elements and proof, but what is the headings?
Posted by: Jaimie | November 23, 2004 at 06:05 AM
Jaimie: I guess one column would be headed "What I need to prove" and another would be headed "How I'll prove it"--or something to that effect. So in the left column, you might have "medical bill of $500--that is was charged; that the charges were reasonable; and that the charge was for treatment related to the incident" and in the right column "by stipulation or the testimony of Dr. Smith."
Posted by: Evan | November 23, 2004 at 08:32 AM