Fill and Sign the Checklist Short of Sequential Activities to Organize Automobile Action 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 - 1 - 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 - 2 -