July 23, 2014
The trial notebook is probably the most useful tool a paralegal can prepare for the assigned attorney on a case. The preparation stages should begin in the beginning of the case, not the last few weeks before trial. The sections in the trial book can vary, but should contain a “nutshell” of the case.
Notes
Things to Do
Pleadings
Motions
Plaintiff/Defendant Witness List
Plaintiff/Defendant Exhibit List
Voir Dire
Opening Statement
Closing Argument
Medical Records/Summary
Specials
Pretrial Statements
Special Verdict Form
Jury Instructions
Settlement Conference Statement
Objections at a Glance
Deposition Summaries
Calendar
Witness Phone List
Many of these sections will not come into use until the final stages of trial preparation; however, as the trial date nears the sections are ready for storing the necessary information. The labeled sections are a reminder of information to include. Sections will also vary depending on the type of case. Remember the primary purpose of the trial book is to keep frequently referred to items or very important items readily accessible. Case files grow very quickly and as the trial date nears the trial notebook becomes a quick reference tool and is extremely helpful. Additionally, it is easier for the attorney to carry the trial notebook to depositions and other meetings to use as a reference tool than the actual file. Generally, if an attorney takes only portions of the file, it never fails that the materials may be incomplete or original documents are used as exhibits. A trial notebook helps in that regard and can reduce some of these frustrating moments.