TRIAL PREPARATION CHECKLIST45 Days Prior to Mediation
(Mediation is usually scheduled 60 days prior to trial)
___ Check to make sure that all medical bills have been obtained and a spreadsheet compiledto show the total amount of the bills. ____ Check for any subrogation liens from collateral sources, i.e., health insurance payments,worker
s compensation benefits, Medicaid, Medicare, ERISA. ____ Review discovery requests for any unanswered interrogatories, or outstanding requestsfor production, and whether or not all requests for copies have been complied with. Sendfollow-up letters to opposing counsel. ____ Propound any supplemental interrogatories or requests for production necessaryfollowing depositions of parties, fact witnesses, etc. (Rule. 1.340) ____ Schedule any examination of the client with any experts, i.e., physicians, rehabilitationspecialists, economists, etc. ____ Prepare a
Day in the Life
videotape of the client, utilizing testimony from
witnesses. ____ Summarize depositions of fact witnesses - Use page/line format. ____ Begin scanning to CD-ROM/database key documents,
documents, photographs,etc. (This should be a ongoing process from this point to trial). ____ Prepare PowerPoint for use at mediation. (This includes any photographs of the accidentscene, witness statements, treating physician
s prognosis, etc.) ____ Fax letter to all defense counsel requesting the names, titles, and companies of anyperson attending the mediation. Determine if any claims adjuster not in attendance, whowill attend by telephone, is the person with the highest authority to settle for his insured.
60 Days Prior to Pre-Trial Conference
(Pretrial Conference is usually held 10 days to 2 weeks prior to the trial)
____ Serve any Proposals for Settlement on opposing counsel
(do not file original with the Court)
____ Set up an Action List for the trial team with responsibilities for certain tasks listed and datesfor completion.
____ Plaintiff to furnish Expert Witness Disclosure and file original with Courta. Name and address of each expertb. Areas of expertise as to each expertc. Subject matter of the expected testimony of the expertd. Substance of the facts and opinions about which witness is expected to testifye. Summary of the grounds on which each of the opinions of the witness will bebased.f. Copy of Curriculum Vitae for each expert to be attached to disclosure.