Trial Notebook Template and Checklist

Cover Page

• Case caption and number
• Court, judge, trial date, and location
• Lead counsel contact information
• Opposing counsel contact information

Section Tabs

1. Pleadings
   - Complaint/petition
   - Answer/counterclaims
   - Pretrial motions and rulings
   - Amendments

2. Case Chronology
   - Timeline of key events with dates and citations
   - Procedural history summary

3. Witnesses
   - Witness list with contact information and status (fact/expert)
   - Direct examination outlines and exhibits
   - Cross-examination outlines and impeachment material
   - Witness availability schedule and subpoenas served

4. Exhibits
   - Exhibit list with descriptions, Bates numbers, admissibility notes
   - Copies of marked exhibits (tabs or sleeves)
   - Exhibit tracking log for admission status

5. Jury Materials (if applicable)
   - Jury instructions (proposed and final)
   - Voir dire questions and juror profiles
   - Verdict forms and special interrogatories
   - Juror questionnaires and seating charts

6. Motions in Limine and Trial Briefs
   - Filed motions, responses, and court rulings
   - Trial briefs and memoranda of law
   - Evidentiary objections and supporting authority

7. Opening Statement
   - Outline/script of key themes
   - Visual aids or demonstratives inventory

8. Closing Argument
   - Key evidence summary and jury instruction references
   - Damages calculations or verdict request

9. Damages/Relief
   - Economic damages calculations (spreadsheets, expert reports)
   - Non-economic damages arguments
   - Equitable relief checklist (injunction factors, findings of fact)

10. Legal Research
    - Case law summaries for anticipated evidentiary or substantive issues
    - Copies of key statutes, regulations, pattern instructions

11. Settlement Materials
    - Settlement offers/demands
    - Mediation summaries
    - Authority to settle and client approvals

12. Logistics
    - Trial calendar and daily agenda
    - Courtroom technology checklist
    - Witness travel/hotel arrangements
    - Support staff assignments and contact sheet

13. Post-Trial
    - Proposed findings of fact/conclusions of law (bench trial)
    - Post-trial motions deadlines
    - Appeal notice deadline calculator

Checklist Summary

• ☐ Confirm all deadlines and court orders reviewed.
• ☐ Update witness and exhibit lists per local rules.
• ☐ Prepare pre-marked exhibits and copies for court/opposing counsel.
• ☐ Coordinate technology needs with courtroom staff.
• ☐ Conduct mock openings/closings and witness prep.
• ☐ Assemble digital version with searchable PDFs.
• ☐ Prepare trial team contact sheet and communication plan.

Maintain both physical binder and electronic folder mirroring this structure for real-time updates during trial.