A Method of Organizing a Trial Notebook

Here's a typical organization scheme for a trial notebook, easily modified to suit your purposes:

• To-do's


• Follow Up and Reminders


• Case Chronology


• A list of case weaknesses


• Proof Chart (a chart showing what witnesses and exhibits will be used to prove the key elements of the claim or defense)


• Order of Trial (used for thinking about the order of witnesses)


• Rule 237 Notice to Produce


• Motion in Limine


• Exhibits


• Demonstratives


• Voir Dire


• Opening


• Outlines for direct examination


• Admissions/Stips/Discovery Responses to read


• Outlines for cross examination


• Response to Motion for D.V.


• Outlines for cross examination


• Jury instructions


• Closing

Related Link: Trial Notebooks

Comments

[John Day]

Let me suggest an addition: Trial Error. This section serves as a place to write down all potentially reversible error. Do not write down every ruling that goes against you, but only those errors that you would later include on a motion for new trial if you lose the trial. Write down the date and time of the error so that you can quickly find it later in the transcript. Use of such a list reduces the likelihood of failing to include an itemof error on a motion for new trial which, in many jurisdictions, results in a waiver of that issue as a ground for appeal.