Fill and Sign the Checklist Sequential Form

CHECKLIST FOR SEQUENTIAL ACTIVITIES TO ORGANIZE AUTOMOBILE ACTION _________________ vs. _________________ PRETRIAL [ ] Statute of limitation diaried [ ] Representation contract signed [ ] Medical authorization signed [ ] Thank you letter to referral source [ ] Authorization for Personnel file signed [ ] Letter to defendant and defendant insurance carrier informing them of your representation [ ] Special notice to public entity if necessary [ ] I. R. S. Authorization signed [ ] Initial client information sheet completed [ ] Client information sheet completed [ ] Client recorded statement taken [ ] Client's insurance information obtained [ ] Request for defendant's insurance information mailed [ ] Accident report obtained [ ] Disposition of any traffic citations [ ] Any testimony on traffic citations [ ] Defendant's statement, if possible [ ] Corporation information obtained, if defendant was a corporation [ ] Write Department of Motor Vehicles re: ownership of defendant's vehicle [ ] First settlement demand [ ] Letters written for medical information [ ] Defendant's driving record sent for [ ] Case development plan in file [ ] All accident pictures obtained [ ] Pictures of scene [ ] Pictures of plaintiff [ ] Engineer's drawing [ ] Witness statements [ ] Consider day-in-the-life videotape [ ] Complaint prepared [ ] Request to produce [ ] Interrogatories to the defendant [ ] Defendant's deposition set and taken [ ] Motion and order for partial summary judgment [ ] Motion and order for summary judgment [ ] Motion to set case for trial [ ] Pretrial statement [ ] Pretrial stipulation [ ] Diary relevant dates from pretrial order [ ] Prepare pretrial checklist [ ] Motions in limine [ ] Jury instructions [ ] Jury verdict forms [ ] Final settlement efforts [ ] Determine cost of structured settlement TRIAL PREPARATION [ ] Summarize depositions [ ] Prepare and mark exhibits [ ] Prepare pretrial notebook [ ] Letter to witnesses advising what to expect at trial [ ] Prepare and subpoena witnesses [ ] Prepare witness list, addresses, telephone numbers, and confirm transportation [ ] Arrange last minute briefing conference with: [ ] Trial team [ ] Client [ ] Witnesses [ ] Letters to doctors, hospitals, etc. , for update on medical bills due [ ] Check courtroom for facilities (view boxes, videotape arrangements, etc.) [ ] Obtain court docket [ ] Check sequencing of earlier trial to determine "ready date" POST TRIAL [ ] Prepare final judgment form [ ] Prepare settlement sheet for client indicating distribution of case proceeds [ ] Prepare motion to tax costs