TORT TALK PRACTICE TIP

CAREFULLY READ TRIAL MANAGEMENT ORDERS

When a Trial Management Order is issued read the Order in its entirety--Judges expect them to be followed to the letter. Immediately have all deadlines marked on your calendar.

Also mark a tickler on your calendar at least 45 days before the start of trial to re-read the Trial Management Order and get started on all materials that have to be filed by certain deadlines such as Trial Briefs, Motions in Limine, Proposed Voir Dire Questions, Proposed Points for Charge, and the like.

Take the time to draft an excellent Trial Brief that thoroughly advances your client's case and argues all anticipated legal issues in your client's favor.  There may come times during trial where the Judge, bored with the tedium of trial, may pick up your Trial Brief to skim or read to pass the time, all to the potential benefit of your client's case.