TABLE OF CONTENTS

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 Checklist - Legal Assistant's - for Handling of Accident Cases for Plaintiff

1.50 Checklist - Legal Assistant's Handling of Accident Cases for Defendant

1.60 Summary - Litigation (General)

1.70 Summary - Auto Accident

1.80 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 on Report

1.160 Checklist - List of Folder Contents

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

2.42 Letter to Potential Client Re: Inquiry to be Done

2.50 Plaintiff's Contingent Fee Services Agreement

2.60 Retainer Agreement

2.70 Agreement to Employ Joint Counsel, Plaintiffs, Hourly Fee

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

2.150 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, Auto Witness

2.430 Checklist, Investigator, Premises Witness

2.440 Request for Accident Report, Auto

2.450 Checklist, Questions to Ask N.D. 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

3. DAMAGES

3.10 Special Damages Sheet

3.20 Diary Request

3.21 Diary Request to Spouse or Parent

3.30 Bodily Injury Description

3.40 Authorization Re Employment and Education

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

4. NO-FAULT AND WORKERS COMPENSATION

4.10 Checklist - No-Fault Procedures and Thresholds

4.20 Standard Brief on No Fault Evidence Exclusion

4.30 Checklist - Workers Compensation Bureau Forms

4.40 Workers Compensation Recovery Examples

4.50 Notice to Workers Compensation Bureau of Third Party Claim

4.60 Attorney's Agreement to Represent the Workers Compensation Bureau's Subrogated Interest

4.70 Notice to Workers Compensation Bureau of Claim Against It

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 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 Pursuant to Rule 69

5.170 Notice of Taking Deposition of Judgment Debtor

5.180 Checklist, Suggested Interrogation of Debtor

5.190 Assets Listing

5.200 Checklist, Execution

5.210 Checklist, Debtor's Exemptions Checklist

6. PLEADINGS AND SUIT PREPARATION

6.10 Notice of Appearance

6.20 Guardian Ad Litem Appointment

6.30 Consent to Amended Pleading & Admission of Service

6.40 Third Party Complaint for Contribution or Indemnity

6.50 Verification

6.60 Acknowledgment by Individual

6.70 Acknowledgment by Corporation

6.80 Service Directions to Sheriff

6.90 Affidavit of Mailing and Certificate of Service

6.100 Affidavit of Service

6.110 Alternative Dispute Resolution Statement (Rule 8.8)

6.120 Summons - Basic Form

6.130 Summons For Publication

6.140 Summons and Notice of No Personal Claim - Quiet Title

6.150 Summons - Mortgage Foreclosure

6.160 Affidavit for Service by Publication

6.170 Affidavit for Service by Publication - Mortgage Foreclosure

6.180 Demand to File the Complaint

6.190 Notice of Filing Complaint

6.200 Notice of Filing Answer

6.210 Pretrial Conference Scheduling Order

7. JURISDICTION; VENUE

7.10 Checklist - Removal to Federal Court

7.20 Notice of Removal to Federal Court

7.30 Removal Bond

7.40 Notice of Removal

7.50 Affidavit of Filing Petition in State Court

7.60 Demand for Change of Venue

7.70 Stipulation for Change of Venue

7.80 Request for Stipulation for Change of Venue

7.90 Venue Change Motion and Affidavit

7.100 Rule 12 Motion for Dismissal

7.110 Brief to Dismiss for Lack of Jurisdiction (Products Case)

7.120 Demand for Change of Judge (by a party)

7.130 Demand for Change of Judge (by attorney)

8. INTERROGATORIES

8.10 Checklist For Legal Assistants Interrogatories

8.20 Interrogatories, Basic, Accident Case

8.30 Interrogatories, Plaintiff, Auto Property Damage

8.40 Interrogatories and Demands - Plaintiffs - Basic, Personal Injury - Motor Vehicle - Served with Complaint

8.50 Interrogatories, Defendant, 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, Re Punitive Damages, to Defendant

8.190 Interrogatories, In Aid of Judgment or Execution Pursuant to Rule 69

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 Rule 37 Sanctions for Failure to Answer Interrogatories

8.370 Affidavit in Support of Rule 37 Motions

8.380 Order on Motion for Rule 37 Sanctions

8.390 Objections to Interrogatories, Common, Sample and Objections Signature

8.400 Expert Witness Disclosure, Letter to Expert

8.410 Expert Witness Disclosure, Format

8.420 Stipulation Extending Time

9. OTHER DISCOVERY

9.10 Discovery Checklist

9.20 Checklist, Legal Assistant's 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 Letter 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 re Deposition Corrections

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

9.201 Deposition Report

9.210 Instructions to Person Taking Videotaped Deposition

9.220 Opening Statement for Taking Video Deposition

9.230 Ending Statement for Video Deposition

9.240 Stipulation for Taking Telephone Deposition

9.250 Order for Telephone Deposition

9.260 Motion to Inspect Depositions on File With Notice of Motion and Brief (with Proposed Form of Order)

9.270 Rule 34 Demand for Production of Documents

9.280 Rule 34 Demand for Inspection of Medical Records with Options for Method of Inspection

9.290 Rule 34 Demand for Inspection of Worker's Compensation Records

9.300 Rule 34 Demand for Evidentiary Items

9.305 Notice for Inspection, Production or Copying

9.310 Rule 35 Defendant's Request for Medical Records

9.320 Rule 36 Request for Admission

9.330 Rule 36 Request for Admission (with Interrogatories on Failure to Admit)

9.340 Rule 36 Request for Admission, with Interrogatories on Failure to Admit - Alternate Form

9.350 Rule 36 Request re "No-Fault"

9.360 Rule 36 Request re Medical Expenses

9.370 Rule 36 Request re Medical Records

9.380 Rule 36 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 - Mfgr's Representative

9.430 Deposition Checklist - Deposing Expert Witness

9.440 Preparation Checklist - Deposition of Expert

9.450 Deposition Checklist - Witness or Plaintiff Personal Injuries

9.460 Deposition Checklist - Treating Doctor's Direct Testimony

9.470 Checklist - Deposition of Defendant Doctor (Medical Malpractice)

9.480 Deposition Checklist - of Expert Doctor (Medical Malpractice)

9.490 Preparation Checklist - Deposition of Expert Doctor (Medical Malpractice)

9.500 Deposition Checklist - Burns

9.510 Deposition Checklist - Vehicle Accident

9.520 Deposition Checklist - Investigating Police Officer

9.530 Rules for the Reconstructing Reality: Preparing the Attorney to Prepare the Deponent to Testify

9.540 Discovery Response Signature, Attorney's

10. SUBPOENAS

10.10 Checklist, Legal Assistant's Instructions for Subpoenas

10.20 Attorney's Civil Subpoena in State Court

10.25 Subpoena Duces Tecum for Inspection, Production or Copying

10.30 Receipt for Subpoena in Lieu of Service

10.40 Deposition and Trial Witness Pointers

10.50 Witness Expense Claim Form Transmittal

10.60 Witness Expense Claim Form

10.70 Witness Fee Check Transmittal

10.80 Rule 45 Objection to Subpoena Duces Tecum

10.90 Checklist for Legal Assistant, Subpoenas in Federal Court

10.100 Attorney's Civil Subpoena in Federal Court

10.110 Letter to Clerk Requesting Minnesota Subpoena

10.120 Letter to Clerk Regarding Letters Rogatory

10.130 Application for Letters Rogatory

10.140 Order Granting Letters Rogatory

10.150 Letters Rogatory

11. TRIAL PREPARATION

11.10 Checklist, Trial Preparation

11.20 Checklist, Legal Assistant's Pretrial Conference

11.30 Checklist, Jury List Procedure

11.40 Jury List Summary

11.41 Jury List

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

11.111 Witness List

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

11.200 Exhibit List

11.210 Request for Resetting Trial/Hearing

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 Checklist, Liens on Settlement - North Dakota

12.60 Checklist: Legal Assistant, Settlement of Plaintiff's Case

12.70 Structured Settlement Information Form

12.80 Worksheet - Negotiation Preparation (Plaintiff)

12.90 Worksheet - Negotiation Preparation (Defendant)

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 Clause

12.150 Professional Malpractice Case Release

12.160 Release of All Claims with Spouse and Child

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, Alternative

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 Release

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

13. JUDGMENT

13.10 Summary Judgment Motion

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

13.91 Judgment on Jury Verdict - Economic and Exemplary Damages

13.92 Judgment on Jury Verdict - Multiple Defendants - Joint and Several Liability

13.93 Judgment on Jury Verdict - Multiple Defendants - Joint and Several Liability - Economic and Exemplary Damages

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

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 Rule 68 Offer of Settlement

14.60 Rule 68 Offer of Judgment for Bartels Effect

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 for 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

15. MOTIONS

15.10 Notice of Motion (Oral Hearing)

15.20 Notice of Motion (Submitted on Brief)

15.30 Order on Motion

15.40 Motion for New Trial

15.50 Stipulation to Appear by Telephone

16. ATTORNEY FEES

16.10 Motion for Attorney Fees

16.20 Notice of Attorney's Lien

16.30 Award of Attorney Fees, Statutory

16.40 Motion to Set Amount of Attorney's Fees and Costs

17. INDEX