Baltimore Injury Lawyer Blog by John Bratt
In Part I, I talked about how useful a set of portable office supplies can be for staying organized at trial. But that is just a small part of the required level of organization. In this installment, I discuss another vital part of my overall organizational system- the trial box. Keep in mind that I am describing how I organize the typical 2-3 day jury trial. Longer, more complex trials travel in a larger set of boxes that are organized following the same basic outline.
I have a portable file box with wheels that all of my paper materials go in. This is a collapsible plastic box the size of a milk crate with wheels and a handle- the kind you see sales reps and business “road warriors” use. I organize it from front to back using file folders and large Redweld-style folders. Less important or less frequently used items go in the back, more important or often-used items are toward the front.
Starting at the back and moving forward, this is what it contains:
•The “hard” file for the case. I include this “just in case” although I rarely use it for the trial.
•The bound “pleadings binders” containing all the pleadings filed in the case. Each of the pleadings is indexed and tabbed in chronological order for quick reference.
•A folder for defense experts. This has deposition and video transcripts, extra copies of their reports, exhibits, and cross-examination material.
•A similar folder for plaintiff’s experts, containing the same things. If there is a video deposition to be played at trial, I attach it to the transcript with a rubber band or a binder clip, so that it can’t easily be lost.
•A folder (or folders) containing all of the exhibits I intend to admit into evidence, with courtesy copies for defense counsel.
•A folder containing all motions in limine, responses, and copies of the important cases referenced.
•A folder with my requested voir dire, draft jury instructions and verdict sheet. This includes an original for the court and a courtesy copy for defense counsel. None for me- that goes in my trial binder. I clip all three together, and label the ones for the court and counsel. Once I receive the defense versions of these, they go in this folder as well. That way, later in the trial when the court wants to go over instructions on short notice, I can lay my hands on the defense version quickly.
•The “medicals binder” containing a tabbed and indexed set of the Plaintiff’s medical records and bills (I will discuss this in detail in a later post).
•My trial binder (also to be discussed later). Often this goes on top, since I use it the most and it sometimes won’t fit front to back.
•Volume I of the Maryland Rules. This contains the rules for evidence and civil procedure. In my box, it goes on the right-hand side, since the box is wider than an 11-inch folder, so there is extra room over there. I can’t believe that many (if not most) lawyers go to trial without this.
This setup lets me have most of what I need to try the case available at a moment’s notice, in a way that is easy to transport. Next in this series, I will be discussing one of the most important items needed for trial- the trial binder.
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