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.
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.
MVA310409 Attorney's Combination Checklist for Police Officer (MVA) Interview, Deposition, Trial Testimony  This MVA - Police Officer Interview - Deposition - Trial Testimony - Checklist Will be Used in Almost All of Your Motor Vehicle Accident Cases.
MVA310411 Photo Assignment Checklist.
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.
MVA007 Plaintiff's Request for Admissions, Rear End MVA (Auto or Truck Vehicle Accident

PREM001 Notice of Taking Deposition of Defendant Organization in Premises Case
PREM002 Request for Inspection of Premises
PREM003 Premises Liability Deposition Checklist - of Defendant 
PREM006 Premises Liability Deposition Checklist -of Plaintiff  

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 in federal court.
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.
SET017 Letter of Protection - BI Case - Plaintiff to Doctor Exclusively for personal injury plaintiffs. In today's world of lien-savvy doctors 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. Exclusively for personal injury plaintiffs.
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.

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.

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
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. Prepare your expert witness to answer three ultimate questions in most negligence cases.

Product Liability

PROD001 Products Liability Deposition Checklist - Plaintiff

Liquor Law Liability, Dram Shop, Forms

Discovery of Electronic Records

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.

Settlement Forms

Here at LawyerTrialForms™  our mission statement is "Making Good Lawyers Better." We take our mission seriously. From time to time we post free articles about deposition or trial preparation, such as the following.

All our deposition checklists  are designed to give you questions to ask in both depositions and trials.  They will help you organize, focus on critical questions, and prevent overlooking questions you should ask.  The customer category favorites are:

# 1 Motor Vehicle Liability Forms

Auto accidents. Truck accidents.  Highway and street accidents have common elements.  Our deposition and trial checklists for MVA are conveniently grouped.

# 2 Bodily Injury Forms and Medical Testimony Question Checklists [a tie for second place.] Medical Testimony Question Checklists are so important, and so specialized, that we made a separate place from bodily injury forms of other sorts.

# 2 Premises Liability Forms.

Premises cases involve more than slip and fall cases.  A falling object was one of the first negligence cases in old English law, and they still are cases that occur today.  Fires and explosions are another sort of premises liability case.  Products that cause harm are frequently on the premises of a defendant, and the case involves aspects of both premises and product liability. 

# 3 Liquor Law Liability, Dram Shop, Forms.

The law of liquor law liability (also known as dram shop liability) for selling or giving alcohol to persons who cause accidents, differs significantly from state to state.  But the techniques and the questions to ask to establish the liability, or defend against liability, can be put into forms that make good lawyers better in depositions and trials.

# 4 Expert Witnesses Forms

For the attorney or legal assistant to use in a lawsuit in which either side has an expert.