Our deposition, discovery, litigation, and trial forms product list.
ON THIS CATALOG PAGE ARE LISTED ALL our legal checklists, deposition question outlines, discovery motions, trial exhibit objections (in short, discovery and trial forms, outlines, and proven tactics that attorneys and legal assistants use). There is a link for more information on each form.
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MVA6010 Before or After Witness. Interview, deposition, or trial questions checklist. For witnesses who were not riding in a vehicle involved in the motor vehicle accident (MVA), but who saw the occurrence or events leading to it; or witnesses who arrived only after the crash, including ambulance, fire, and tow truck personnel.
MVA6016 Initial Litigation
Hold - Spoliation Notice - to Truck Company This copyrighted
Plaintiff's Initial Spoliation Letter to Truck Company is so powerful, even
experienced truck company risk management officers will know you are organized
and loaded for action.
MVA310411
Photo Assignment
Checklist. Lists the needed photos to be taken by your client,
your investigator, or yourself.
MVA007 Plaintiff's Request for
Admissions, Rear End MVA (Auto or Truck Vehicle Accident
Premises Liability
PREM001 Notice Taking
Deposition of Defendant Organization in Premises Case
PREM002 Request for Inspection of
Premises
PREM003 Premises Liability
Depo Checklist - of Defendant
PREM006 Premises Liability
Deposition Checklist -of Plaintiff
PREM111 Interrogatories and Demands for Production, to Defendant.
Always needed in premises liability cases involving either the condition of real
estate and buildings, or what happened on the premises. For plaintiffs only,
this unified set gives you a solid foundation for drafting the needed initial
written discovery.
Bodily Injury
Litigation: Deposition, Litigation, and Trial
BI3009 Stipulation for Physical Exam
-
Plaintiff's should demand this stipulation if the defense is asking for an IME.
BI3010 Handout for Plaintiff
Client Before the Adverse Medical Examination.
BI3121
Bodily Injury Claimant Take-Home Form - Four single spaced pages of items
you should ask your plaintiff client to bring you, plus some standard advice you
do not want to forget to give your client.
BI002 Request for Admissions, Medical
Expenses - Good for states like Texas, where a general denial pleading is
used, or anytime the defense is denying medical expenses without justification.
BI3106 Checklist for Deposition of
Plaintiff's Bodily Injury (also Injuries Checklist - for both
Plaintiff and Defense offices - for both depositions and trials.
"Used most often."
BI3006 Bodily Injury Client's
Checklist - for Plaintiff's offices. A check-the-box approach like
doctors' offices use, to have a client list areas of injury.
BI005 Spouse's Testimony re Plaintiff's
Personal Injury Checklist
BI4706
Parent's Testimony of Damages in Wrongful Death Case - a checklist of
questions that is used again and again over the years of your litigation
practice.
BI3005
Defense Demand For Disclosure of Damages - Aggressive, but civil and
ethical, form
is designed for defense attorneys only. And only for BI cases. A Defense
Demand for Bodily Injury Damages Disclosure moves the defense ahead in the
pace of the case.
Do the math! If you gain only an hour by
using our form, and your billing rate is $150 per hour, our form is
worth $150 to you. Use the form five times and gain five hours, and
you will have gained $750 of billable time.
DEP1217
Objections to Taking Notice Deposition, with Motion for Protective Order
When you need to prevent a deposition set for next week, this is a form to do
it, ASAP.
MED4612
Lawyers' Medical Abbreviations Summary
- Made for a lawyer's deposition and trial notebook! Every
BI plaintiff or defense lawyer finds he/she needs a medical abbreviations list.
BI4613 HIPAA Compliant
Subpoena Process. HIPAA has made subpoenaing a medical witness time and
effort consuming. Our checklist and forms will get you there faster.
BI4617 Medical Release /
Authorization Forms. Medical authorizations must comply with federal
HIPAA regulations. Seventeen page report and four choices of medical releases.
BI4632 Packet of Form
Authorizations for Employment/Education Info. These authorization forms
speed you on your way to educational and employment information about a party
(your client or theirs).
SET017
Plaintiff Atty Letter of Protection - BI Case
In today's world of lien-savvy doctors,
chiropractors, physical therapists, and hospitals, plaintiff's BI attorneys always need this form letter.
SET018
Plaintiff’s Request to Medical Providers for Amount of Medical Bill. Use
before giving final settlement advice in a bodily injury case.
Testimony of
Medical Witnesses
at Depositions and Trials
Legal forms in this section involve the testimony of medical providers, such as doctors, nurses, hospital worker, laboratory and electronic medical technicians, physical therapists, et cetera.
MED3421 Plaintiff's Attorney Direct Examination of Plaintiff's Own Treating Doctor
-
Designed for the plaintiff's attorney who wants to prepare a direct
examination of the plaintiff's treating doctor, for deposition or for trial.
MED3423
Defense
Attorney Depo of Plaintiff's Treating Doctor -
A solid standard
format for personal injury defense attorneys to have in their notebook of
deposition checklists.
MED3424-
Duces Tecum Demand to
Doctor being Deposed. A checklist form for building the duces tecum list in
your subpoena to the doctor you are deposing.
MED3426 Defense Direct Examination of
Defense Doctor. Question checklist form built for the defendant’s
attorney to use as a checklist in performing the direct examination of the
defense medical doctor.
MED3428 Plaintiff's
Attorney's Cross-Exam of the Defense Doctor. Question checklist form
designed for plaintiffs’ attorneys in bodily injury cases. It is based on the
assumption that the defense hired a doctor to examine your client plaintiff and
you need to cross-examine the doctor.
MED3434
Plaintiff's Personal Injury Direct Exam of Physical Therapist. An excellent
source for objective evidence of injury is the physical therapist, too often
overlooked by trial counsel.
MED3432
Additional Testimony: Plastic Surgeon. This is
for use as additional questions to ask when the doctor is a reconstructive
surgeon. It is an "add-on" on to the materials in the general forms for M.D.
testimony in our forms MED3421 through MED3428.
MED4612
Lawyers' Medical Abbreviations Summary
- Made for a lawyer's deposition and trial notebook! Every
BI plaintiff or defense lawyer finds he/she needs a medical abbreviations list.
MED4707
Written Deposition Questions to Medical Records Custodian. Obtain
medical records, plus the foundation to put those records into evidence ---
even if the medical records are stored electronically.
Deposition Aids and Witness Preparation
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DEP4006 "Pointers for
Witnesses" for Deposition or Trial --- A Witness Preparation
Instruction Handout The one best aid for preparing witnesses to
testify. Witness Instruction Handout is an easy to use tool for you to teach in
the office, and for your witness to learn at home.
DEP4008 Pointers for Witness in
Videotaped Deposition The "Pointers" with instructions
adapted specially for witnesses whose depositions will be videotaped.
DEP009 Personal Injury Client
Testimony: Additional Preparation Instructions Exclusively for personal
injury plaintiffs, to improve their damages testimony. The Client Prep handout
is a unique "How To Testify" skill builder.
DEP1207 Instructions to Video
Photographer at Deposition that will be shown at trial Send this to
the person who is going to be doing the actual videotaping of the deposition you
have scheduled of your own witness (or an adverse witness) that may be used at
trial.
DEP1217
Objections to Taking Notice Deposition, with Motion for Protective Order
When a five day notice of deposition arrives, this is a form that an attorney
should have ready in their computer, before they need it, to give him/her the
assurance they know what to do and how to do it ASAP.
DEP4003
Deposition Objections Report and Checklist. Before you go to a deposition,
use this report as a checklist and memory refresher on the objections you and
the other side properly can make at a deposition. Put this checklist in your
deposition/trial notebook!
DEP4011
Notice of Taking Deposition of an Organization. A complete and
powerful form notice for taking the deposition of a corporation, partnership, or
other organization, plus proven best tips and tactical advice on the subject of
these depositions.
DEP4014 Deposition
Checklist: Assets Examination Questions. Need to ask about assets of the
person who is the adversary? Here is the deposition checklist of questions you
need, because they never taught you to do an asset examination in law school.
WIT5102
Telling witnesses not to talk to the other side gives you short
statement of limitations of what you can do, and then a form to do the maximum
you can do in asking independent witnesses not to talk to the other side.
Tips and Forms regarding Experts
EX0804
Deposition Checklist to
Cross-Exam the Adverse Expert Witness [Checklist
plus Advice Why and what to ask. A law summary report plus a general
outline checklist that gets you started on most non-medical expert depositions.]
EX0805 Request to Produce
Adverse
Expert's Files
EX0807 Subpoena
Duces Tecum for Adverse Expert's File at
Deposition Rule 26 and 45 combine to give you power, if you use the
paragraphs of the Advanced Subpoena Duces Tecum.
EX0709 Expert
Opinion Admissibility Checklist Law summary report plus checklist
from for your trial notebook.
EX0706 Request by Hiring Attorney re
Retained Expert's Report Send to your expert before he/she writes a report. A disclosable communication in some
jurisdictions, but it's crafted to help, not hurt you, before a jury.
EXDEP004
Witness Pointers for
Expert's Video
Depositions. Applicable when the
expert's deposition is videoed.
EX0303 Court Pretrial
Order Regulating Challenges to Admission of Expert Witness Opinions
Law summary report plus a form order to submit to the court.
EX03 The Ultimate Liability Questions for Your
Expert.
Free! Prepare
your expert witness to answer three ultimate questions in most negligence cases.
EX0802
Ten Categories Cross (of experts).
Free! This one page form is designed to be placed in your trial
notebook, ready for those times when you need to build a cross-examination
quickly during a deposition or trial.
Product Liability
PROD001 Products Liability Deposition Checklist - Plaintiff
More forms in this category are coming this year. But see the expert testimony and premises categories for forms that will also be of use to you in product liability cases.
Liquor Law Liability, Dram Shop, Forms
LIQ3111 Liquor liability lawsuit deposition questions and tips to establish liability, or prepare defense witnesses.
ESI - Discovery and Use of Electronically Stored Information
ELEC3320.
Litigation Hold Letter to Client. Tell your litigation your clients
their obligations to preserve evidence, including electronic evidence.
ELEC3321.
Litigation Hold Letter to Adverse Attorney. The
three pages of this single spaced checklist form demands in this letter form
also will lead you to think clearly on what may be available to you if you use
e-discovery to find electronically stored information, including the meta data.
ELEC22.
Meet and Confer Report.
The checklist style report allows you to sit down with
adverse counsel and stand up later with your form report check marked and ready
to use for your required report to the court.
ELEC3323.
Clawback Agreement
PLUS Court Order.
Protection against waiving our client's privilege or your work-product
protection by inadvertently producing a protected document in a mass of
electronically produced information. The Clawback Agreement PLUS Court Order gives you
the confidence of protection when exchanging either paper
documents or electronic data during discovery. Legal summary and
form for court order included.
ELEC3324.
Checklist for Deposition of Corporate IT Person. Designed for an attorney taking the
deposition of a corporate employee or officer in regard to the electronic
records of the corporation, but equally valuable if you are the responding
attorney as a checklist in your witness preparation. Deposition
eDiscovery is a checklist to use during a deposition to find out what kinds of
records exist and how they may be accessed.
ELEC3325.
Protocol for On-Site Computer Inspection.
A checklist to use for discussions with adverse
counsel about the mechanics of who will do what, when, and with what
safeguards, during an adverse inspection of computers. Although written from
the viewpoint of the attorney asking for the physical inspection or download of
electronic records, the checklist is equally valuable to responding counsel
interested in ideas for protecting the client's computers.
ELEC4526. Agreement
or Order for Expert to Examine Computers. Are you facing the need to
have an expert inspect and copy information from computers? Ready to discuss --
and agree with the adversary attorney or the court --- what the expert is to do?
This form gives you knowledge (what to discuss) and suggested language (how to
say it) for an agreement or court order.
# ELEC4530. Protocol for Inspection of
Forensic Image of ESI.
A form for discovery of the contents of a copy/image of ESI, by agreement or by court order,
that protects privileged matter.
TIP4550
There's a hard drive in most copy and fax machines.
Most attorney's don't know about this security problem and electronic
evidence opportunity.
Negotiation
and settlement: separate catalog.
Our growing collection of negotiation and settlement articles and forms is now kept at our sister website of LawyerSettlementForms™.
We do have available at this website (in our PowerLitigation™ section at this website,
see below) an article about three items that form a basis for better settlement results.
However, to browse a catalog of negotiation and settlement forms, use the link button
for the specialized separate catalog.
Organizing your litigation Practice, and
PowerLitigation™ tips and tactics.
Here is where we list some of our available PowerLitigation™:
proven tips and tactics articles; litigation and discovery ideas,
deposition questions, witness handling forms.
Plus, we have additional office and case organization forms in our
Organization
pages. Several of the articles and forms are available without cost to you. Browse, read,
download. What follows is only a part of the many
articles available.
The patient's HIPAA right to change mistakes in the medical record
--- an opportunity for both sides of the BI case. Read about what the bodily
injury plaintiff should be doing, and how the defense can show the plaintiff
knew he/she had a right to change records that now are disputed in the
courtroom..
"Always Ask": these eight questions when taking the deposition of an adverse
party or witness.
Form the basis for more successful negotiations by using three items.
Move this Case Forward! is an eight page
case management checklist that records and lets you know where
you are in the case, increases delegation, reduces stress, and produces a
superior plan to get you to your goal.
Discovery of expert's communications with attorney Some of it
is protected; some discoverable.
Handling the Media - Public Relations
An $8 "must have." It's purpose is in its name.
What you should do when the witness says: "I don't remember." Don't take that as completely true. There is more you can get. Ask some standard
questions that a top trial attorney recommends
Social
media block of questions
for depositions or in client/witness preparation. Social media
causes trap for you and witnesses. This block of questions, used in your witness
preparation, will unearth possible problems for your witness.
Judicial Notice
and the Internet. Think of asking the judge to take judicial notice of a
fact on the Internet.
The patient's HIPAA right to change mistakes in the medical record
--- an opportunity for both sides of the BI case. Read about what the bodily
injury plaintiff should be doing, and how the defense can show the plaintiff
knew he/she had a right to change records that now are disputed in the
courtroom..
"Always Ask." Eight questions you should always ask when taking the deposition of an adverse
party or witness.
First Letter
to Bodily Injury Plaintiff Client. Give a dozen type of information
by instructing your secretary to prepare this form letter for you to sign
when you start a new plaintiff's BI case.
First
Letters to Insurance Claims Manager and Insured Bodily Injury Defendant.
When assigned to defend an insured in a bodily injury case, these two form
letters are an inexpensive way (both money and time) to start moving and impress
the insurance claims manager and the insured with your sure handling of the
assigned defense.
Form the basis for more successful negotiations by using three items.
The Claim for
Claim Preparation Preparation Expense. Most attorneys, in presenting an
insurance claim against their client’s own insurer (a first-party claim) don’t
use the Claims Preparation Clause contained in the policy.
Persuader's Real Rules of
Exhibits, 1 - 4. This first article, that was in a series, sets out the "The
Persuader's Real Rules of Exhibits " 1 through 4 - the use of exhibits during
your opening statement to the jury.
Two things to do in every deposition. The
value of offering exhibits; the response to a foundation objection.
Phoning clients at their workplace, or emailing them there. Losing attorney client privilege
happens because clients use the company email or company-issued smartphone.
The ABA has stated your specfic duty of advice you
must give your client..
Terminating
representation of client - 6 page checklist to avoid malpractice and
ethics violations.
Reading a deposition into evidence. Reading a deposition into
evidence should not be frightening to you and it should be interesting to the judge and jurors. Here is the law and 1s theatrical tips to
accomplish what you want - jurors who actively listen to your reading.
Discovery
Most of our discovery forms are listed under other categories in this long list of our products. However, a few of these forms are so universal in use that from time to time we will list special ones here.
DISC4335 Don't leave discovery without a Catch-All Demand for Production! A catch-all demand for production nets you everything that you don’t already have that the adverse counsel is likely to use at trial.
Trial Notebook
& Trial Forms
TRIAL5210
The Workhorse Two Dozen:
a trial testimony evidence objections checklist and
law summary for active in-battle use.
WIT0505 TRIAL5212
The Battle-Quick Exhibit Foundations: a checklist and concise summary for
foundations for exhibits, designed for active in-battle use.
Two versions of Bucklin's Trial Notebook system with forms:
LitigationReady!™ and
Building Trial Notebooks™.
For your own peace of mind you should use a trial
notebook system for organizing any case in litigation. When you get
to a deposition or to the courthouse, everything will be in order so that you
will maintain an appearance of purpose and drive. The object of this
trial notebook system is: deposition and courtroom success through
ability to organize. Take a tip from the best trial lawyers --- use a
trial notebook. For information on either (1) the e-book
format - over 100 pages of advice and basic forms in our immediately
downloadable - now - electronic e book version, or (2) the two volume loose-leaf
binder format - over 500 pages of text and forms, plus searchable CD,
supplemented annually.
ORG1007. Case Management Checklist. (It's included in Bucklin's Trial Notebook system, so don't buy this if you have one of the above two versions of Bucklin's Trial Notebook system.) Use this detailed, multi-page, case management checklist form as your plan to Move this Case Forward! Every item in this form is an instruction that moves your case forward through discovery to conclusion by negotiation or trial. Makes it easy to organize what you do and assign tasks to others.
WIT0503
Standard
Questions
to Use in Cross-ExaminationEvery lawyer should have some stock questions on the tip of his/her tongue
.
TRIAL1914
Attorney's Voir Dire Worksheet.
Formalizes a helpful mental process to determining the questions to
ask prospective jurors.
Attorney
Fee Awards: a handbook for attorneys.
This is 199 pages of compacted, practical, direct advice. Advice you would get if you asked a senior experienced litigator for advice. Law, tactic, and forms, including deposition outline for questioning the adverse expert witness on attorney fees. Even includes a trial question outline for the direct examination of your own expert witness on your request for an attorney's fee award. In PDF format, download into your computer and word processor to print out forms.
Individual Forms:
Trial questions for your direct
examination of your own fee award expert [See note * below].
Or
Question checklist for cross-exam
-deposition or trial - of adverse fee expert [See note * below].
[Note: Attorneys ask to buy this question checklist form separately, so in
response we tell you where you
can find it. But it doesn't make economic sense for you to buy one form for
$27 when the same form plus several others, plus tactics and law text, is
available in the 199 page PDF book, which includes forms.]
Attorney Fee
Awards: a handbook for attorneys.
More Categories -- Our Category "More!" More deposition, settlement, negotiation, and trial forms are made available for sale here about every 120 days. In addition there is a constant flow of Power Litigation™ articles to improve your deposition, trial, and litigation practice.
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