Our deposition, discovery, litigation, and trial forms product list.

MVA310401 Driver (Client or Adverse) Deposition Checklist A customers' favorite because in every motor vehicle accident there is a driver that must be deposed.  Doing that deposition skillfully leads to better settlements and verdicts.
MVA310409 Motor Vehicle Police Officer Checklist: Interview - Deposition - Trial Testimony. In every bodily injury or death that involves an auto, truck, motorcycle, or highway pedestrian accident there is a police officer involved.
LIQ3111 Dram Shop Suite. If one of the drivers was drinking, this suite of several forms has question outlines for the driver, the police officer, and the witnesses to the drinking, including the bar employees.
MVA310403 Request to Adverse Driver to Bring Items to the Deposition.
MVA310405 Truck Driver Under Control of Defendant, Deposition Checklist
This checklist is for a the deposition of the company driver or executive that is taken to establish that the company was in control of the driver at the time of the MVA.
MVA310407 Notice of Taking Deposition of Corporation Regarding Driver Employee.

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 Seven page, single spaced, legal form for Notice of Taking Deposition of an Organization form (plus seven page of law summary and tactical tips for you). Written only for the benefit of attorneys on one side of a lawsuit (plaintiffs), and only for one class of cases (premises liability).
PREM002 Request for Inspection of Premises Form for either plaintiff or defendant who wants ease and certainty of access to premises to inspect them - with experts, and seeing - in situ -relevant machinery or other personal property  on the site that was there at the incidents in litigation.
PREM003 Premises Liability Depo Checklist - of Defendant 
PREM006 Premises Liability Deposition -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.

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.

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.
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.

Medical Witnesses: Testimony at Depositions and Trials

Deposition Aids and Witness Preparation

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.

Experts: Tips and Forms and Deposition Checklists

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 Involvement:  Depositions & Forms

LIQ3111  Liquor liability lawsuit deposition questions and tips to establish liability, or prepare defense witnesses.  It is not only in cases involving DUI or dram shop (statutory) liability, but also in any case when a party or a witness might have been under the influence of anything from prescription drugs to "just a drink after work," that some special questions to parties (and possible parties) and witnesses become helpful to the litigator.

ESI - Electronically Stored Information: Discovery & Use.

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.) is found in our gateway page to a collection of recent  ESI tips, forms, and articles.-->