General Checklist Litigation Practice Form

GENERAL CHECKLIST FILING COMPLAINT: __ Elements of each cause of action checked __ Statute of limitations checked __ Summons attached __ Local forms required ______________________ ______________________ __ Complaint filed __ Received file-stamped copy from court __ Complaint sent to client SERVICE OF COMPLAINT: __ Complaint sent out for service __ Complaint served __ Proof of Service filed with court ANSWER: __ Answer filed/received __ Answer served on plaintiff __ Received file-stamped copy of answer from court __ Answer sent to client CROSS-COMPLAINT: __ Elements of each cause of action checked __ Statute of Limitations Checked __ Cross-complaint filed __ Received file-stamped copy from court __ Cross-complaint sent to client ANSWER TO CROSS-COMPLAINT: __ Answer to cross-complaint filed/received __ Answer served on cross-complaintant __ Received file-stamped copy of answer from court __ Answer sent to client DEFAULT __ Statutory time to answer expired __ Notice of default completed __ Notice of default filed with court __ Notice of default served on defendant __ Notice of default sent to client __ Check local rules for default prove-up requirements ______________________________________ _______________________________________ _______________________________________ _______________________________________ __ Default prove-up hearing scheduled __ Default prove-up hearing calendared __ Default prove-up hearing evidence gathered ______________________________________ ______________________________________ DEFAULT JUDGMENT __ Default judgment prepared __ Default judgment signed by judge __ Default judgment filed with court __ Default Judgment recorded DEMURRER: __ Demurrer researched for each cause of action __ Demurrer filed with court __ Demurrer hearing date set __ Demurrer hearing date calendared __ Demurrer served on plaintiff __ Order on demurrer prepared __ Order on demurrer filed __ Order on demurrer served on plaintiff OPPOSITION TO DEMURRER: __ Each point of demurrer researched __ Opposition filed with court __ Opposition served on defendant __ Demurrer hearing date calendared REPLY TO OPPOSITION TO DEMURRER: __ Reply filed with court __ Reply served on plaintiff DISCOVERY: __ Discovery plan developed __ Interrogatories sent ___ Answered by Opposition __ Form Interrogatories sent ___ Answered by Opp. __ Request for production of documents __ Answered by Opp. __ Request for examination of plaintiff __ Answered by Opp. __ Request to examine land or items __ Answered by Opp. __ Requests for Admissions __ Answered by Opp. __ Depositions set: __ Plaintiff __ Defendant __ Other_______________ _______________ _______________ __ Other discovery __________________________________ __ Motions to compel deadline checked ___________________ __ Motion filed __ Motion served RESPONSE TO OPPOSITION DISCOVERY __ Interrogatories Answered and Verified __ Form Interrogatories Answered and Verified __ Request for Production of Documents Answered and Verified __ Request for Admissions Answered and Verified __ Deposition dates calendared: __ Plaintiff __ Defendant __ Other __ Other discovery answered TRIAL PREPARATION __ Trial brief prepared __ Written settlement offers sent __ Status Conference Statements prepared __ Stipulations signed __ Trial notebook prepared __ Motions in Limne prepared ___________________________ ___________________________ ___________________________ __ Jury Instructions prepared __ Witness List Prepared __ Exhibit List prepared __ Subpoenas prepared __ served __ Subpoena dueces tecum prepared __ served __ Jury fees posted __ Court reporter fees posted __ Voir Dire questions prepared __ Short statement of case prepared __ Notice to produce witnesses and evidence at trial served on opposition __ Witnesses prepared for trial __ Copies of all documents or document books prepared