Trial Checklist 2017-01-06T10:58:08+00:00

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Practice Tip Sheet

Trial Checklists

I like checklists, don’t you? Especially in a project, such as a trial or arbitration, where there are so many details to attend to, I can’t survive without a checklist. I’ve had a number of versions over the years; here is a recent iteration. Do you have any items to add?


  • Review all Court Rules, Local Rules, and Standing Orders or Pretrial Orders issued by your Judge
  • Calendar all deadlines for submitting all required pre-trial materials

Materials Lodged or Filed with the Court

  • Jury fees, if applicable
  • Joint Pretrial Statement (federal court)
  • Exhibit list and objections
  • Witness list
  • Deposition designations, counter-designations, and objections
  • Discovery response designations, counter-designations, and objections
  • Original deposition transcripts, if applicable
  • Trial briefs on disputed issues of law, if required by Court
  • Motions in limine, and oppositions
  • Proposed voir dire questions (joint or separate, as required by Court)
  • Proposed jury instructions and verdict forms (joint or separate, as required by Court)

Organization of Prep Materials

  • Identify who will be drafting each motion, brief or document
  • Coordinate with each drafter about cite checking and exhibits
  • Assign paralegal staff to each document, as appropriate
  • Prepare trial notebooks or electronic files for attorney team

Presentation and Visuals

  • Contract with trial presentation vendor, if applicable
  • Prepare demonstrative exhibits
  • Prepare slides for opening and closing arguments


  • Prepare witness files with deposition transcripts, declarations, direct or cross examination outlines, trial exhibits, designations, and other useful information
  • Draft proposed schedule for testimony of each fact and expert witness
  • Schedule trial preparation meetings with witnesses
  • Prepare and serve trial subpoenas or notices to attend trial


  • Prepare premarked trial exhibits in paper or electronic formats as required by Court
  • Prepare chart of proposed trial exhibits identifying sponsoring witness and date marked for identification and date admitted

Courtroom and Travel Logistics

  • Determine courtroom setup – size and lay-out, availability of court reporter, real time, wi-fi, projector screen or monitors, document camera, procedures for use of electronics
  • Gather courtroom supplies (electronic equipment, cables, electronic files with backup, notepads, pens/pencils, markers, labels, file folders, etc.)
  • War room arrangements, if applicable
  • Arrange for transport of all trial and war room materials to courtroom and war room
  • Any special arrangements needed for travel, hotel rooms, meals

What’s on your trial checklist?

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