Table of Contents

Chapter 1: Master Checklist and Summaries
1.10 Checklist – Vehicle Accident
1.20 Checklist – Civil Trial Notebook
1.30 Checklist – Things Litigation Assistants Do
1.40 Legal Assistant’s Checklist for Handling of Accident Cases for Plaintiff
1.50 Legal Assistant’s Checklist for Handling of Accident Cases for Defendant
1.60 Summary – Litigation (General)
1.70 Case Summary – Auto Accident
1.80 Case Summary – Accident (Production – Construction – Premises – Fire)
1.90 Checklist – Litigation Computer Indexing of Documents
1.100 Computer Document Abstract Form
1.110 Checklist – Initial Interview of Client
1.120 Checklist – File Organization
1.130 Checklist – Trial Notebook Instructions
1.140 Checklist – Medical Records, Organization and Review
1.150 Liability File Review or Report
1.160 Checklist – List of Folder Contents

Chapter 2: Retainer and Investigation
2.10 Acknowledgment of Receipt of File or Matter
2.20 Hourly Fee Services Agreement
2.30 Minimum Fee and Hourly Services Agreement
2.40 Defense Combination Hourly and Contingent Fee Agreement
2.50 Plaintiff’s Contingent Fee Services Agreement
2.60 Retainer Agreement
2.70 Agreement to Employ Joint Counsel
2.80 Expense and Disbursal Agreement – Joint Recovery Effort
2.90 Expense and Disbursal Agreement – Joint Recovery Effort – Extra Costs and Fees
2.100 Letter to Referring Attorney on Hourly Fee Case
2.110 Hourly Fee Services Agreement – Associated Attorneys
2.120 Letter to Referring Attorney on Contingent Fee Case
2.130 Letter to Referring Attorney on Contingent Fee Case (Where We Sign-up Client)
2.140 Letter to Attorney Sharing Large Part of Fee
2.150 Letter Obtaining Local Counsel
2.160 Client Information Questionnaire, Plaintiff, Personal Injury
2.170 First Letter to Client Plaintiff in Personal Injury Case
2.180 First Letter to Client Defendant
2.190 First Letter to Referred Client on Hourly Fee Basis
2.200 Letter to Insured Regarding Claim for His Insurer
2.210 Notice to Adverse Insurer of Our Representation of Client
2.220 Letter to Referring Attorney in Medical Malpractice Case
2.230 Letter to Client re Medical Malpractice Case
2.240 First Letter to Insured Defendant
2.250 Excess Letter to Insured with Request Regarding Counterclaim
2.260 Excess Letter to Insured with Reservation of Rights
2.270 Company Letter Reserving Rights
2.280 Letter Advising Insurer of Counterclaim
2.290 Notice to Insured re Subrogation Claim to Be Made
2.300 Letter to Insured re Recovery of Fire Loss by Insurer
2.310 Referral Letter to Attorney re Medical Malpractice
2.320 Authorization for Inquiry for Medical Information and Bills
2.330 Notes Regarding Inquiry to Be Done
2.340 Chain of Evidence Form
2.350 Witness Sheet
2.360 Checklist – Automobile Liability
2.370 Checklist – Premises Liability
2.380 Checklist – Products Liability
2.390 Checklist – Professional Malpractice Liability
2.400 Freedom of Information Request to OSHA
2.410 Checklist – Investigator, Preparation for Witness Interviews
2.420 Checklist – Investigator, Interview Vehicle Accident
2.430 Checklist – Investigator, Premises Witness
2.440 Request for Accident Report
2.450 Checklist – Questions to Ask Police Investigating Officer
2.460 Checklist – Traffic Accident Photos to Take
2.470 Checklist – Auto Accident Witness Interview
2.480 Checklist – Falling Accident Witness Interview
2.490 Checklist – Products Liability Witness Interview
2.500 Witness Interview, Request to Confirm Content
2.510 Your Right not to Talk
2.520 Witness’s Request for Statements
2.530 Letter Advising Client of Limited Claims Made
2.540 Letter Declining Case

Chapter 3: Damages
3.10 Special Damages Sheet
3.20 Diary Request
3.30 Bodily Injury Description
3.40 Authorization re Employment and Education (Adverse)
3.50 Authorization re Employment and Education (Client’s)
3.60 Authorization for Medical Information and Bills (Client’s)
3.70 Authorization for Medical Information and Bills (Client’s Minor Child)
3.80 Authorization for Medical Information and Bills (Adverse Party)
3.90 Request for Medical Records (Patient’s Direct Request)
3.100 Authorization to Adverse Attorney for Medical Records Only
3.110 Authorization to Adverse Insurance Company for Medical Records Only
3.120 Procedure, Response to Medical Records Demand, with Sample Letter
3.130 Authorization for Information
3.140 Request to Employer for Employment Data
3.150 Request for Doctor for Medical Report on Client
3.160 Request for Pharmaceutical Records
3.170 Request for Medical Records Limited to Certain Dates – Client
3.180 Request for All Medical Records – Adverse Party
3.190 Request for Medical Records after Certain Date
3.200 Authorization for Workers’ Compensation and Employment Information
3.210 Request for Medical Bills for Trial Use
3.220 Authorization for Disability Claim File Information
3.230 Social Security Request for Detailed Earnings Information – Form SSA-7050-F4
3.240 Authorization to Disclose Customer Information (Bank/Lending Institution)
3.250 Letter Regarding Client’s Unpaid Medical Bills
3.260 Letter from Medical Creditor to Wait for Collection

Chapter 4: [Reserved]

Chapter 5: Collections
5.10 Checklist – Collection System
5.20 First Collection Letter
5.30 Letter After First Partial Payment
5.40 Advice to Client of Service on Defendant
5.50 Notification to Client of Judgment
5.60 Complaint
5.70 Affidavit of Default
5.80 Affidavit of Proof
5.90 Affidavit of Identification and of No-Military Service
5.100 Order for Judgment
5.110 Statement of Costs and Disbursements
5.120 Judgment
5.130 Asking Client to Sign Affidavit of Proof
5.140 Letter to Judge for Default Judgment Order
5.150 Request to Docket Judgment to Another County
5.160 Interrogatories in Aid of Judgment or Execution
5.170 Notice of Taking Deposition of Judgment Debtor
5.180 Checklist – Suggested Interrogation of Debtor
5.190 Assets Listing

Chapter 6: [Reserved]

Chapter 7: [Reserved]

Chapter 8: Interrogatories
8.10 Legal Assistant’s Checklist for Interrogatories
8.20 Basic Interrogatories, Accident Case
8.30 Interrogatories, Plaintiff’s, Auto Property Damage
8.40 Interrogatories and Demands – Plaintiff’s, Basic, Personal Injury, Motor Vehicle, Served with Complaint
8.50 Interrogatories, Defendant’s Personal Injury
8.60 Interrogatories, Defendant to Co-Defendant, Product Defect
8.70 Interrogatories, Defendant’s, Product Defect
8.80 Interrogatories and Demands, Plaintiff’s, Product Defect, Basic, Served With Complaint, Follow Up Not Expected
8.90 Interrogatories, Plaintiff’s, Product Defect (Set 1), Served With Complaint, Needs Follow-Up
8.100 Interrogatories, Plaintiff’s, Product Defect (Set 2)
8.110 Interrogatories, Defendant’s, Death Case
8.120 Interrogatories, Plaintiff, Payments Made or Payable by Defendant to Plaintiff
8.130 Interrogatories, Defendant’s, Collateral Source Damages
8.140 Interrogatories, Expert
8.150 Expert Witness Disclosure, Letter to Expert
8.160 Interrogatories, Defendant, “Mary Carter”
8.170 Interrogatories, Defendant, re Damages
8.180 Interrogatories Regarding Punitive Damages, to Defendant
8.190 [Reserved]
8.200 Interrogatories, Miscellaneous Common
8.210 Request for Admissions by Plaintiff (with Interrogatories If There Is Failure to Admit) re Medical Expenses
8.220 Interrogatories, re Statute of Limitations
8.230 Interrogatories, re Personal Jurisdiction
8.240 Interrogatories, re Failure to State a Cause of Action
8.250 Interrogatories, If You Deny Request to Admit
8.260 Interrogatories, Notice to Supplement
8.270 Request to Supplement Interrogatory Answers
8.280 Interrogatories, Signature
8.290 Interrogatories, Objections Signature, Attorney’s
8.300 Interrogatories, Corporate Party Signature for Answers
8.310 Interrogatories, Definitions and Demand for Production
8.320 Interrogatories, General Demands
8.330 Request to Client to Answer Interrogatories
8.340 Request to Client to Sign Interrogatories and Return
8.350 Request to Answer Overdue Interrogatories
8.360 Motion for Sanctions for Failure to Answer Interrogatories
8.370 Affidavit in Support of Motions
8.380 Order on Motion for Sanctions
8.390 [Reserved]
8.400 Expert Witness Disclosure, Letter to Expert
8.410 Expert Witness Disclosure, Format
8.420 Stipulation Extending Time

Chapter 9: Other Discovery
9.10 Checklist – Discovery
9.20 Legal Assistant’s Checklist for Instructions for Depositions
9.30 Checklist – Cost Saving Ideas for Depositions
9.40 Notice of Oral Deposition
9.50 Notice of Deposition of an Organization
9.60 Notice to Doctor re Deposition
9.70 Notice to Expert Witness re Deposition
9.80 Letter to Client re Deposition
9.90 Notice to Adverse Doctor re Deposition
9.100 Letter to Witness not Previously Contacted re Deposition Set by Us
9.110 Letter to Friendly Witness re Deposition Set by Others
9.120 Deposition Bill Transmittal to Client
9.130 Deposition Correction Sheet
9.140 Checklist – Legal Assistant Request to Witness to Sign Signature and Correction Sheet Pages and Return
9.150 Notice of Taking Audio-Visual Deposition without Written Transcript
9.160 Notice of Taking Audio-Visual Deposition with Written Transcript
9.170 Notice of Taking Written Deposition
9.180 Stipulation for Medical Records Deposition
9.190 Questions for Written Deposition, Medical Records Foundation
9.200 Deposition Witness Summary Sheet
9.210 Instructions to Person Taking Videotaped Deposition
9.220 Opening Statement for Taking Videotape Deposition
9.230 Suggested Ending Statement for Videotape Deposition
9.240 Stipulation for Taking Telephone Deposition
9.250 Order for Telephone Deposition
9.260 Motion to Inspect Depositions on File (with Proposed Form of Order)
9.270 Demand for Production of Documents
9.280 Demand for Inspection of Medical Records with Options
9.290 Demand for Inspection of Workers’ Compensation Records
9.300 Demand for Evidentiary Items
9.310 Defendant’s Request for Medical Records
9.320 Request for Admissions
9.330 Request for Admission, with Interrogatories on Failure to Admit
9.340 Request for Admission, with Interrogatories on Failure to Admit – Alternate Form
9.350 [Reserved]
9.360 Request for Admissions, re Medical Expenses
9.370 Request for Admissions, re Medical Records
9.380 Affidavit of No Response
9.390 Deposition Checklist – Defendant’s for Falling Accident
9.400 Deposition Checklist – Premises, of Defendant
9.410 Deposition Checklist – Products Liability, Plaintiff or Fact Witness
9.420 Deposition Checklist – Products Liability – Manufacturer’s Representative
9.430 Deposition Checklist – Deposing Expert Witness
9.440 Preparation Checklist – Deposition of Expert
9.450 Deposition Checklist – Witness or Plaintiff on Personal Injuries
9.460 Deposition Checklist – Treating Doctor’s Direct Testimony
9.470 Deposition Checklist – Defendant Doctor (Medical Malpractice)
9.480 Deposition Checklist – Expert Witness (Medical Malpractice)
9.490 Preparation Checklist – Deposition of Expert Doctor (Medical Malpractice)
9.500 Deposition Checklist – Burns
9.510 Deposition Checklist – Auto Accident
9.520 Deposition Checklist – Investigating Police Officer
9.530 Rules for Reconstructing Reality: Preparing the Attorney to Prepare the Deponent to Testify

Chapter 10: Subpoenas
10.10 Checklist – Legal Assistant’s Instructions for Subpoenas
10.20 Attorney’s Civil Subpoena in State Court
10.30 Receipt for Subpoena in Lieu of Service
10.40 Witness Instructions
10.50 Witness Expense Claim Form Transmittal
10.60 Witness Expense Claim Form
10.70 Witness Fee Check Transmittal
10.80 Objection to Subpoena Duces Tecum
10.90 Checklist – Federal Subpoena for Depositions
10.100 Attorney’s Civil Subpoena in Federal Court
10.110 [Reserved]
10.120 Letter to Clerk Regarding Letters Rogatory
10.130 Application for Letters Rogatory
10.140 Order Granting Letters Rogatory
10.150 Letters Rogatory
10.160 Subpoena for Inspection, Production or Copying

Chapter 11: Trial Preparation
11.10 Checklist – Trial Preparation
11.20 Checklist – Legal Assistant’s Pretrial Conference
11.30 Jury List Procedure
11.40 Jury List Summary
11.50 Pretrial Authorization Letter from Client
11.60 Checklist – Pretrial Conference Memo
11.70 Liability File Review or Report
11.80 Plaintiff Attorney’s Suit Report
11.90 Defense Attorney’s Suit Report
11.100 Conflict Dates Sent to Court Administrator
11.110 Request to Witness for Dates not Available
11.120 Subpoena and Trial Outline Transmittal to Friendly Witness
11.130 Notice to Witness That He Will Be Subpoenaed
11.140 Notice to Medical Witness for Trial
11.150 Notice to Client of Trial Date
11.160 Demand for Preservation and Production at Trial
11.170 Note of Issue and Certificate of Readiness
11.180 Certificate of Nonreadiness
11.190 Motion to Prevent Prejudice

Chapter 12: Settlement and Releases
12.10 Personal Injury Evaluation Summary
12.20 Demand Letter for Settlement
12.30 Checklist – Preparation of Settlement Brochure
12.40 Checklist – Legal Assistant Settlement of Defendant’s Case
12.50 [Reserved]
12.60 Checklist – Legal Assistant Settlement of Plaintiff’s Case
12.70 Structured Settlement Information Form
12.80 Worksheet – Negotiation Preparation (Plaintiff) – Confidential, Destroy All Copies After Use
12.90 Worksheet – Negotiation Preparation (Defendant) – Confidential, Destroy All Copies After Use
12.100 Release of All Claims
12.110 Release of All Claims, Alternative
12.120 Release of Unknown Future Claims Clause
12.130 Agreement to be Confidential
12.140 Payment Free of Medical Liens
12.150 Professional Malpractice Case Release Form
12.160 Release of All Claims with Spouse and Child Indemnity
12.170 No Release of Subrogation or No-Fault Clause
12.180 Release and Covenant Not to Sue
12.190 Release and Covenant Not to Sue Agreement
12.200 Minor’s Release
12.210 Release of Parents’ Claims and Indemnity Agreement of Parents Against Future Claims By Child
12.220 Order Approving Minor’s Settlement
12.230 Release of Policy and All Claims
12.240 Release of Claims (Property Damage Only)
12.250 Structured Settlement Agreement
12.260 Release of All Claims, Structured Settlement
12.270 Structured Settlement Agreement and Final Release of Claims
12.280 Settlement Agreement and Release
12.290 Stipulation of Dismissal
12.300 Settlement Letter to Adverse Attorney Requesting Signatures
12.310 Request to Court Administrator for Dismissal Order
12.320 Request to Judge for Dismissal Order
12.330 Closing Letter to Insurer
12.340 Petition for Protective Arrangement
12.350 Order for Protective Arrangement
12.360 Report to Court and Petition for Discharge as Special Conservator
12.370 Discharge of Special Conservator
12.380 Disbursal Sheet
12.390 Form Letter to Witness/Thank You/Case Concluded

Chapter 13: Judgment
13.10 [Reserved]
13.20 Summary Judgment Order for Defendant on Part of Issues
13.30 Checklist – Judgment After Trial By Jury
13.40 Order for Judgment for Defendant
13.50 Order for Judgment for Plaintiff
13.60 Statement of Costs
13.70 Checklist – Costs of Witnesses
13.80 Affidavit of Identification and No Military Service
13.90 Judgment on Jury Verdict
13.100 Judgment on Trial to the Court
13.110 Notice of Entry of Judgment
13.120 Satisfaction of Judgment
13.130 Partial Satisfaction of Judgment
13.140 Application for Court to Set Expert Witness Fees and Costs
13.150 Affidavit of Fees and Costs of Expert Witness
13.160 Order Approving Expert Witness Fees and Costs
13.170 Checklist – Judgment After Trial by Court
13.180 Findings of Fact, Conclusions of Law, and Order for Judgment After Trial by the Court
13.190 Checklist – Default Judgment
13.200 Checklist – Summary Judgment
13.210 Checklist – Judgment in Federal Court

Chapter 14: Miscellaneous
14.10 Acknowledgments
14.20 Verification
14.30 Request to Judge to Sign Order
14.40 Confidential Information, Order for Handling
14.50 Offer of Settlement
14.60 [Reserved]
14.70 Motion to Dismiss for Lack of Surety
14.80 Withdrawal of Attorney, Petition For
14.90 Consolidation of Actions, Order For
14.100 Checklist – Temporary Restraining Order
14.110 Motion for Temporary Restraining Order
14.120 Certificate of Service or Attempts at Service
14.130 Bond on Temporary Restraining Order
14.140 Temporary Restraining Order
14.150 Application for Preliminary Injunction
14.160 Policy on Media Requests for Information
14.170 Form Letter for Auditor’s Request for Information
14.180 Form of Bill for Auditor’s Request for Information

Alphabetical List of Forms