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hello this is Dane Ciolino and welcome to our class on case map fact chronologies report books witness preparation and brief writing in our past lectures we focused on the document tables on the person's tables and to some extent on the fact table and issues table this lecture brings everything together and focuses principally on the queen bee of all the tables namely the fact table but of course it does rely upon the other tables the issues tables the document tables the persons table and this lecture really brings together is really the kind of a capstone case map lecture in the sense that all that we've discussed is now relevant and we'll show you in this lecture how to use that kind of powerful fact chronicling functionality of case map to do specific tasks that you as a lawyer will be called upon to do in your practice namely to prepare a chronology for the case to share information with your client by generating a report book to get ready for witness examinations and by witness examinations I mean witness depositions and witness examinations at trial cross examinations direct examinations and finally using case map in conjunction with text map another LexisNexis product to do brief writing and the powerful functionality of case map in this area comes from its ability to sort and filter mostly filter away extraneous information and by extraneous I don't mean irrelevant because it wouldn't be on your case map in your case map file if it were irrelevant but irrelevant for present purposes by present purposes I mean either writing this particular issue of the brief or preparing for an examination of that particular witness okay now let's talk about using case map to generate reports about your case and chronologies obviously one of the most important functions of case map relates to organizing your facts and letting you see factually what your case is all about now in previous lectures of course we've talked about managing documents producing documents bates numbering documents all of that functionality is is very important in case map but at the end of the day as we've talked about many times before cases are about facts and organizing those facts is really at the heart of what case map is all about as we've said before the case map Queen Bee table is the fact table the document table the other tables simply service that table so getting your fact table right and getting it to have a comprehensive and well sourced listing of all of the facts in your cases is important well what we're going to talk about now of course deals with manipulating the fact table we're going to start with this assumption and that assumption is that you have already done a pretty good job organizing or populating the fact table with in case map by populating the fact table I mean you've mined documents you have talked to witnesses and when you get those atoms of your case those nuggets from your case what you're going to do is you are going to put them right here on the fact table so for example on the fact table that is before us and by the way what we're looking at right now is the Hawkins case which is a case that comes with case map that allows you to practice with a set of cases that excuse me a set of facts documents that are all fictitious and of course we're not disclosing any sorts of privileges or confidential information by using this sample case and that's that's why we're using it now okay well right over before us we have the fact table and of course this shows the date and time that column is critically important the fat text is the heart of the fact table which is the what happened and then the source is of course critically important because facts without sources are useless we want to make sure that we have good source information on all of our facts now the other columns on this table really are optional and I can hide them like for example whether this is a material fact again that might be useful if I was getting ready to put together a motion for summary judgment but I'm not going to do that now so I'm going to hide that field status is disputed or undisputed again important in analyzing what you might need to do by way of proving facts sometimes good to track but I'm not going to talk about it now linked issues again all facts should be related to an issue and one way to see the issues to which facts are linked is by looking at this linked issue column another way is to simply open the issue linking window over here on the right side of case map and you can see that the issues are linked there and the one this has not linked to any issues so there are no check marks over here on the right in contrast the record that follows it is checked off for wrongful termination so you can see the issue either here on the right side of the issue pane or over here by looking at the linked issues column and then finally and we'll leave this open for now finally the last column that is available to view in this particular configuration is the evaluation column this allows you to give a thumbs up or a thumbs down or a neutral to all of the facts a lot of facts really are just kind of neutral they just are they don't really help your case they don't really hurt your case but they might put things into perspective obviously some facts are good and some facts are bad some worse than others and that that this evaluation field allows you to to look at all the facts and evaluate them so you can later do what we're going to do now which is filter and sort to essentially see what you've got to see the strengths and weaknesses of your case okay well since we're going to talk about using case map to prepare chronologies very simple to prepare just a basic case chronology from start to finish what you do is you open up case maps fact table you make sure that you have the date/time table on the column on the left you know rather than over here you have it on the far left you include what other issues you want if you just want a simple a simple case chronology you might hide the other columns and just leave the date the time the fact text and the source information you always want the source information and then what do you do well you sort it ascending in ascending order which means you're sorting it chronologically from the earliest date to the latest date of course I can do it otherwise from the reverse chronological order if I wanted but that's not the normal course of fun of doing this and once you've sorted it by date and time and you have moved the the column that you are sorting by into the far left hand of the table then all you simply do is this you just generate a report and we have a report here that says fact chronology and as we turn the page there it is just the the fields and the columns that we have we wanted to see and now we can just looked at our report and see what's going on in our case chronologically very simple now that's just your basic report suppose you wanted a report on all issues we're going to open up our our issue field again linked issues if you wanted to generate a report to see all of the facts that you have on the issue of let's say wrongful termination what you would do is come over here to the linked issues column right click and then hit filter by selection what this does is leaves only those facts linked to the issue of wrongful termination and now you can see what facts you have in your fact chronology that bear on that issue yeah why would you want to do this you might want to do this because you want to just see whether you need to do some additional discovery or you need to interview some additional witnesses you might have enough already you don't know what you have until you filter out all of the rest of the extraneous facts and they're not necessarily extraneous they just relate to other issues that you're not dealing with at the moment and once you have all that's left is the wrongful termination records you can look and see what you have now if you also wanted to see what facts were good and what facts were bad on that issue pretty simple you just we're gonna go back and find that evaluation field add it back there it is and then we can see all the facts good and bad now keep in mind we can continue to filter this further if we just wanted to see all the really bad facts that that related to the issue of wrongful termination we can use multiple layers of filters now notice that when I'm since I've already got a filter in place and I know it's a filters in place because I can see that up here in the right-hand corner that the the table is filtered and six of twenty-nine records are visible now once I decide that I want to add another filter I've got some decisions to make does it want me to see does it do you want to add them together so you can see all records that contain either wrongful termination or heavily against us do you want to show those records that have both that are both heavily against us and wrong in the wrongful termination linked to wrongful termination or if you want to start a new filter that is just going to be heavily against us and it'll bring back in all of the other 29 records and then filter out only those that are heavily against us well just for our purposes we'll do the and the we're gonna add this new layer on the filter and take out all of those wrongful termination facts that are not heavily against us and let's see what happens there it is we've generated a report that shows these three facts bearing on the issue of wrongful termination that are heavily against us now having done that let's just if we want to generate a report we can do that and and we are going to want to see this is not really a full fact chronology so we're gonna want to go into page setup report options and we're going to want to show this subtitle how do we do that we want to go into the title page information encase information we want to show the report subtitle now the subtitle here is filter linked to issues of wrongful termination and evaluation heavily against us so we want to make sure that that appears on the title page and well it doesn't allow us to add that we we could add it if we wanted to by editing comment we can insert a field we could add report well it doesn't allow us to add a report subtitle only the report title well that's fine because you can see that it's going to appear on the second page it's not just the fact chronology unfiltered it's the fact phonology that is contains filtered documents that is only those that are linked to wrongful termination and evaluation is heavily against us okay well that's just the let's close out the filter that's just a very base take manipulation of the fact table one in which you have moved the sort by field to the far left hand of the table you have filtered out whatever issues you don't want to see or you have filtered out whatever other forms excuse me fields that you don't characteristics that you don't want to see leaving only those remaining documents excuse me those remaining facts for you to view and then generate a report and of course once you generate a report you could print it to the PDF you could print it to PDF and email and again by just doing those simple filtering and sorting sorting of facts now as opposed to documents you can get a pretty good handle on what you've got in your case now let's talk about a more advanced report creating functionality that is built right into case map and this is called report books we've already talked about how it is you might want to sort and filter data so you can generate particular reports that deal with kind of an overall chronology or that deal with a particular issue or that deals with a particular evaluation but case map has under the reports menu up here has a functionality called report books and report books and actually a good interview of report books or excuse me a good overview of report books is set forth on the case map website so you can just click on that and see that if you'd like by going to tools excuse me report book report books overview I would recommend that you go take a look at that because it will give you some more information on on what it is we're talking about but I'm just going to show you the basic functionality at this point all right so suppose I want to prepare a report book now a report book is kind of a comprehensive overview of your case it doesn't involve just printing out the fact table or just the document table or just the issues table for example but it's a comprehensive book of report courts that relate to your entire case your documents your issues your facts so what you do is you go to report books and you the best one to take a look at to get a sense of this functionality is the case summary and this is one that is that comes with case map that's built into case map and let's go to preview all right what first of all what it does is it generates this report called case report book it has gone and pulled information from all of your tables now before that it does have a statement of confidentiality because it presumes that you're going to send this out of your office usually to your client maybe your co-counsel or your associates and again we want to make sure that people understand that this is confidential now the contents of the report book show that it is a comprehensive report of what you've done in your case and what information you've collected it's got a just an introduction as then we'll see that in just a second as to what a report book is it goes on to give you a report of all the issues in the case all the people and organizations in your case the fact chronology which is just a basic chronology document index open questions and then if you're using the research authorities and extract functionality those functions all right next page again that's what we're going to see here's the introduction this just gives the reader a quick overview of what is in the pages to follow or what's contained in those pages and then we have the issue outline and you can see it's got the name of the issue a description of the issue and the number of facts linked to that issue all of the people in the case the name of the people their role the type whether their key and the number of linked facts organizations again the name the reason that there's a different table for organizations as opposed to people is because one organization may employ or have associated with it a number of different people now we also have the fact chronology which of course contains the basic fact information the date and time the fact text the sources of that information whether it's key the staff and the linked issues this goes on for some pages and we have all the documents in the case again you can see case map is pulling all of the information that you've been entering on all of your tables and preparing this very comprehensive report now of course you have to collect and you have to keep all and post and keep all this data on your tables for case map to be able to pull it from somewhere but once it's there these reports are generated automatically open questions the question text they do date for the question who's assigned to it and the status of that research authorities if you were using the research functionality these are all the cases and statutes that you've pulled that relate to the case all right again very very important and comprehensive overview of your case now note that this is highly customizable I've created my own case summary that I use in my cases it's called DSC dana stealing okay summary and just so you can see I did spend a good good bit of time modifying the format like for example I have made my report a in portrait format I have kind of changed the statement of confidentiality a little bit and put some contact information on this first page I have again I haven't really changed that much I've changed kind of an into the introduction a little bit to explain what this is and that this is not polished word product this is a tool to organize and analyze information relating to our investigation and as that analysis process continues the information these reports will change as you review these reports it's highly likely that you'll see inaccuracies you may also think of important information that's not included in either case case please let me know mark up the report book and send it back yeah see this introduction is written in such a way that it assumes that this report book is going to be sent usually to a client so the client can see what the status of the investigation is and what the status of the document gathering and fact mining is I also have the basic chronology and notice that I've picked which feels to include I use the date and time field fact text field linked issues field cast of characters full name role in case number of linked facts organizations document index now I've made this a little shorter I just conclude the date of the document the full name the short name which is the Bates beginning number and the number of pages I haven't cluttered it with as much information as the report that case map includes just a very basic issue outline with the full name of the issue and the number of linked facts and then I've got open questions and again I haven't included as much information on my version this report has in the version that case map comes with I only have the question text who's been assigned to in its criticality now how do you generate your own custom reports well what you do is you come here and you go to manage report books you open it up and you can open up case summary and you could for example make a copy of it and it says copy of case summary and then you can modify that any way you'd like by including what topics you would you want a title page whether you want a confidentiality statement again and which reports you want to include within the report book very highly customizable and then you can just rename it whatever you'd like and we can call it my report book you know whatever you'd like there it is my report book and then again I was just showing you this I'm going to delete this so I don't have it but but that shows you how you can function you can you can make a highly customized report last point you can do other report there are other reports that are that are baked in here like for example what's new in the last 14 days if if you want to well I go back up to reports report books what's new in the last 14 days preview nothing there's nothing in here that's that's new so again if you just wanted to show your client what developments were have been what progress had been made in the case that might be a way to do it mark me up again another version of this it's got a kind of a different introduction asking the recipient to check things for accuracy fill in blanks what's missing etc again another very good report that's baked in to case map and one that if you wanted to start with making your own customized report book you you might start start there okay well that's report books very powerful and a very convenient and comprehensive way to see what you have and not only for you to see what you have but also to share the information in your and your case map file with with your clients and and with others let's now talk about the use of case map filled case Maps filtering and sorting functionalities for one particular use mainly to get ready for a deposition or a witness examination a cross-examination or a direct examination now the reason why this is important obviously you we understand that case map is simply a tool we use case map to help us get ready for our cases to have all of the information and documents that we need to examine witnesses to make arguments this is really where the rubber meets the road with case map this is where you are going to get yourself ready to do what you do as a lawyer at least one of the things that you do which is to go to a deposition and ask a witness some questions and not just to kind of wallow around in a disorganized fashion but to do an effective deposition one that is going to set the witness up for a trial examination or make the case ready for summary judgment whatever it is you you want to go to the deposition prepared and case map is here to prepare you now much the same could be said about how you would go about preparing for a cross-examination or a witness examination okay well that having been said let us now prepare for the examination of the plaintiffs you're the defense lawyer your company has been sued in some sort of employment discrimination case and you are preparing for the deposition of Phillip Hawkins well what would you do to prepare for this deposition obviously one of the things that you're going to do is you're going to want to see all of the facts that mr. Hawkins is referenced in and you also want to see and probably use at least consider using in the deposition all of the documents that mr. Hawkins is the author of or otherwise mentioned it alright so how would you do that well there really are you can do the same way it's the same exercise three different ways one way is to come to where we are now which is the person's table find mr. Hawkins if we want to find all of the facts linked to him we can go to the number of facts these are all facts linked to mr. Hawkins now of course remember how the facts are late to mr. Hawkins once you start typing his name in that field it autocompletes his name and then Auto links it to the person's table so what would you do here you would go to the Phillip Hawkins Phillip Hawkins name on the on the persons table come to the number of facts click on this and now what we have is a sub table of all of the facts that mention mr. Hawkins and you can see mr. Hawkins name is mentioned here right because it's his name underlined there he is again and we're not going to find any facts that don't have phil Hawkins Phillip Hawkins in them why because we essentially by going to the fact table looking at the number of facts mentioning mr. Hawkins opening up that sub table there we have how so what can I do now well I could print it out this is 24 facts linked to Phillip Hawkins I could print out a hard copy I can make this a PDF file and I'll use this to sit down and generate a make a mind map of the outline of my examination of Phillip Hawkins whether it's a to prepare for a deposition examination or the cross-examination of mr. Hawkins now the question you might ask is am I going to do the examination directly from the the report from case map well you know I might but generally I'm going to take this particularly if it's for trial if it's for a deposition I might simply use this I might for example have this in front of me while he is sitting across the table with a court reporter there and I might say well mr. Hawkins when did you first meet william lang and he might go on and talk about when he first met William lang and then I would ask him about the circumstances under which mr. lang invited you to visit and Starr biotech industries again this is in chronological order and that might be the best way to do the deposition I mean it certainly almost certainly wouldn't be the best way to do a director a cross-examination those are going to be organized really by issue more than by chronology but for a deposition sometimes it makes sense and again you might have taxable reasons for doing it otherwise but for a deposition it often makes sense just to start at the beginning and have the witness tell the story about all of those those facts from start to finish and having all of the facts that you know about that are related to his case in front of you is one way to do that and you've done that essentially by generating this sub table from the person's table now you can also do the same thing with you know documents these are all the documents that he's authored and again you can do the same kind of thing 24 documents author you don't want to think about all of these documents thinking and decide which ones you might want to use during the deposition which ones you're gonna ask him questions about all right that's one way to generate this report is from the person's table another way is to go to the fact table find Phil Hawkins there he is filter by selection and there we have it it's team number right 24 records out of 29 all linked to him we could generate a report fact chronology and again facts linked to Phillip Hawkins and there they have there we have it just those facts none others the last way to do this same exercise which is to see just the facts that relate to a particular issue or just the documents excuse me all the facts that relate to a particular person or all the documents that relate to a particular person is to go back to report books we've discussed report books in an earlier segment of this lecture but note that there is one that's entitled let's see facts and documents grouped by person now this is going to show us everything that we have well let's take a look at what it does and again this is one of these report books that is baked into case map let's see what it shows us I will here it it it says that it's a case report book and what it says we've got here are people facts group by person these are all the facts that Linda Collins has shown up in these are all the facts that Randy Foshan has shown up in Phillip Hawkins again these are all the facts that he has shown up in william lang george knife susan sheridan and these are all the documents that are linked to either here Linda Collins Phillip Hawkins now no in order to print out this comprehend a report you're gonna have to collect a lot of information like who the author of the documents of each document that you put into case map was who the recipient was who is copied you know again I generally don't do this I generally used the document table and all the document fields just to collect basic name rank and serial number information about each document and when I mined the document for information at that point I'm going to spend some time pulling out the names so I generally are going to get I'm going to get to all the important documents and important facts through the fact table rather than running a search within the document table by searching for authors recipients and whatnot that's just my practice there are people who want to have that information in in the document table and then there's nothing wrong with that it just takes just time-consuming if you have a document intensive case to spend a lot of time logging authors recipients and then recipients via cc or BCC again you have to record that information in order for this report to be meaningful but case map does it for you right here in the report book functionality okay well those are three different ways to generate the same reports right one you can generate it from within the person's table by going to the number of reference faxed and open up a small sub table and then printing that you can get the same information by going to the fact table finding the person who you want to filter for filter by selection will start a new filter and there we back to twenty-four facts tagged to Phillip Hawkins and there we have fact chronology linked to Phillip Hawkins and then last we could do it through the report book by saying facts grouped by person and here we can find all of the facts linked to Phillip Hawkins all those facts grouped by diem now as I said case as a tool it's not going to do your examinations for you it is going to make it easier and make you a better easier to prepare and a better prepared lawyer by having all of the documents all the facts related to a particular person right there with you while you are preparing your outline now again and this is my closing point here you could do the examination particularly in a deposition or perhaps even a direct examination but unlikely across straight from the case map tables it's filtered tables that you're going to produce but it's far better and far more elegant by way of organization to take the information from these filtered and sorted case map tables and to prepare your own outline using some hierarchical method of organization of course I use mind mapping and then to do your examination off of the mind map rather than off of the case map table let's now talk about using case map to write a brief well when you have to write a brief obviously you are going to write the brief in a way that is logical that appears to have some organization to it and usually it's going to have a hierarchical structure for example the brief might first address issues of liability and negligence and causation those sorts of things and then it might have a discussion of of damages for example because of those you know the way that you would organize a brief it at least hopefully the way you would organize a brief in a way that's logical case map can be very useful and how can it be useful well because all of the facts and documents exhibits that you're going to use to write your brief are gonna be in case map so what you want to do here is you want to go to issues and you know what you ought to do of course is you ought to make sure that case map has its issues arranged in a hierarchical format by hierarchical I mean just like this age discrimination retaliation and then the sub the sub issues under that transfer demotion etc those I think are useful because what they do is allow you to have one section and one sub section for each section and subsection in your brief what you'll do is you'll make sure that you have the same issues that you're going to address in the brief in different sections of the brief right here in your issues table then you're gonna go to the fact table and make sure that you have tagged all of the facts each fact should be tagged to some issue and you can see the issue hierarchy over here on the right now one thing that I usually want to do is I want to see this you know the full names of the issues rather than the short names and I'm just see toggled between display full name display partial name so now when I get ready to write the age discrimination portion of the brief all I'm gonna do is do what we've talked about in the other segments of this lecture we're going to filter and look at only those facts bearing on age discrimination how do we do that again there are three different ways you can do it you can do it from the fact table by right-clicking and filtering by selection and that's what we'll do here we'll start a new filter and I want to include the sub issues as well and here we have just all the facts linked to age discrimination so what I'll want to do now is I'm going to write the portion of the brief that deals with age discrimination and I can see all of the facts that I need to include in that portion of the discussion of course there are other ways that I can do this I can go to the issue table I can look for the number of facts linked to age discrimination and there we have another way to get at the same information the second way a third way is using the report book functionality I can see the fact stocks and law grouped by issue I can do that it generates this report and here are all the issues that relate to age discrimination all the ones that are hoc and specific so again case book case map is very powerful as long as you're tagging all of your facts to issues then you can make sure then you can filter away all of the other unrelated issues focus just on that portion of the brief and write the brief now that's all the facts that are in in case map keep in mind that you will also have in addition to the facts that are in the fact table the rut that are derived from documents you'll often have facts that are sourced to transcripts and depositions well this is where text map comes in text map is a very useful corollary program to case map and what it does is it manages the transcripts and they could be transcripts from a trial if you're writing an appellate brief that's generally what you're going to be working from is a trial transcript it could be transcripts from depositions and that's what we have here could also be interview notes and also video tape depositions it's so that this it's that powerful way you can see that now you can see here as you read through the documents excuse me read through the well let me back up this is what I do if it comes time to write an appellate brief and I've got in front of me all of my exhibits I'm got those in case map and I have tagged them to the facts in the crow in the fact table I also need to mine the transcript if the in the transcript if it's a one-day trial is going to be to 300 pages I'll read the whole transcript and as I'm reading I will highlight and as I highlight I will send the fact to case map and once I send it to case map I'm going to link it to an issue I can do that down here if I want to link it to age discrimination for example I do that it's highlighted here and it's now been sent to case map now I'll do this throughout the whole transcripts start all the transcripts start to finish then when I'm done I have mind the the trial transcript for useful information I'll then go back to case map and look at the facts now note that this is the fact that I just brought over I tagged it to age discrimination I it's got so it's got a length issue it's got its source so if I want to go see it I can just double click on this and it's going to pop up in the transcript but the nice thing is is now when I'm writing the portion of the brief on age discrimination it's going to be included in there so this is incredibly powerful when you're writing a brief using case map why because you can then have before you in your fact table all of the transcript excerpts related to an issue all the facts that you've otherwise tagged to documents for example which would be exhibits in our in this hypothetical tag two issues all of that would make it very very powerful to to write an effective brief now also keep in mind that briefs contain not just facts but law facts in the law are the yin in the an of legal analysis and case map does have the functionality in its research table to keep track of law now this is not one that I use a lot I should probably use it more often and I think I will start using it more often it allows you to keep track of the authorities that you've researched kind of differ not only for purposes of a research trail so you don't redo the research you do but also because you can tag them to issues and when it comes time to write your brief you can look at all of the law that relates to a particular issue and make sure that you've got the legal discussion in that in that portion of the brief as well now also note that you've got linked documents they can be linked both to PDF documents for example if we open up this case there's the case oh it's just a sample it doesn't have the case actually there but but these are linked to online ok well that's not working it assuming you have a LexisNexis account this would log you into LexisNexis once you're logged in into the account then yeah and I'm not going to do it but it does allow you to log into the into LexisNexis and gives you the ability to see actually the source document now of course you're gonna wind up extracting and these are extracts for example that the good language from the case or the good the actual language from the statute or something that's that's relevant to your case and again all linked to issues the point is is that when you are getting ready to write a brief but an appellate brief case map is invaluable you are going to want to make sure that you have all of the facts relevant to that brief in the fact table and whether they've gotten there because they Eve mind them from exhibits or you've mined them from the transcripts that doesn't really matter they're there and they're tagged to an issue you filter out all of the other issues other than the one you're working on and then you look and see what facts you have related to that issue and you look at all the law that you have in the authorities and extracts from authorities table to see what what law you have and then you write unfortunately case map will not write your brief for you you are going to have to do that yourself but it does get before you only those facts and law excerpts that you need for that particular portion of the brief it does put blinders on you temporarily so you can focus write and get your job done