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OneNote e-Trial Notebook – Bucklin’s Trial Notebook Sections (Access)

Unlimited access to Leonard Bucklin’s “Building Trial Notebooks” sections and trial practice manual.

At Checkout: Please be careful to provide your correct email address which will be used to grant access to these trial notebook resources.

List of Forms Included:

Chapter 01 The Plan

Checklist: Your Duties in E-Discovery
1.5 Your Duties in E-Discovery Checklist.DOC

Litigation Checklist
1.7 Litigation Checklist.DOC

Attorney’s Notes of Additional Tasks
1.8 Attorney’s Notes of Additional Task.DOC

Assistant’s Notes of Additional Tasks
1.9 Assistants Notes of Additional Tasks.DOC

Chapter 02 Summary

One-Sheet Case Summary
2.4 One-Sheet Case Summary.DOC

Chapter 03 Pretrial Orders

Worksheet for Pretrial Order Dates
3.2 Worksheet for Pretrial Order Dates.DOC

Pretrial Order Regarding Daubert-Style Challenges
3.3 Pretrial Order Regarding Daubert-Style Challenges.DOC

Chapter 04 Our Witnesses

Witness Summary
4.08 Witness Summary.DOC

What Other Possible Witnesses Are There
4.09 What Other Possible Witnesses Are There.DOC

Witness Expense Report
4.11 Witness Expense Report.doc

Chapter 05 Their Witnesses

Checklist: Six Standard Items in Cross-Examination
5.2 Six Standard Items in Cross-Examination.DOC

Checklist: Standard Questions to Use Against Adverse Witness
5.3 Standard Questions to Use Against Adverse Witness.DOC

Checklist: When the Witness Says “I Don’t Remember”
5.5 When the Witness Says ‘I Don’t Remeber’-Checklist.DOC

Witness Summary
5.6 Witness Summary.DOC

Chapter 06 Third Party Witnesses

Checklist: Six Standard Items in Cross-Examination
6.2 Six Standard Items in Cross-Examination.DOC

Witness Summary
6.3 Witness Summary.DOC

Chapter 07 Our Experts

Request by Hiring Attorney to Expert Regarding Report
7.6 Request by Hiring Attorney to Expert Regarding Report.DOC

Witness Summary
7.8 Witness Summary.DOC

Checklist: Admissibility of Expert Opinion
7.9 Admissibility of Expert Opinion.DOC

Chapter 08 Their Experts

Checklist: Ten Standard Items to Consider in Cross-Exam of Experts
8.2 Ten Standard Items to Consider in Cross-Exam of Experts.DOC

Witness Summary
8.3 Witness Summary.DOC

Request for Production of Documents of Adverse Expert
8.5 Request for Documents of Adverse Expert.DOC

Subpoena Duces Tecum List of Items Adverse Expert is to Bring to Deposition
8.7 Subpoena Duces Tecum List of Items for Depo.DOC

Chapter 09 Exhibit List

General Exhibit List
9.5 General Exhibit List.DOC

Medical Records and Bills Exhibit List
9.6 Medical Records and Bills Exhibit List.doc

Chain of Possession Memo and Receipt
9.7 Chain of Possession Memo and Receipt.doc

Chapter 10 Finder

Client, Insurer, and Co-Attorney Finder
10.2 Client, Insurer, and Co-Attorney Finder.DOC

Adverse Party and Attorney Finder
10.3 Adverse Party and Attorney Finder.DOC

List of Witnesses and Persons Having Relevant Knowledge
10.4 List of Witnesses & Persons Having Relevant Knowledge.DOC

Chapter 12 Deposition Arrangements

Deposition Availability Coordination
12.06 Deposition Availability Coordination.DOC

Instructions to Person Videotaping Deposition
12.07 Instructions to Person Videotaping Deposition.DOC

The Rules Do Let You Add Video To A DWQ
12.09 The Rules Do Let You Add Video to a DWQ.docx

Notice of Taking Written Deposition [With Documents] [With Video]
12.10 Notice of Taking Written Depo-DocVideo.DOC

Plaintiff’s Cross Questions to Medical Custodian
12.11 Plaintiffs Cross Questions to Medical Custodian.DOC

Notice of Taking Audio-Visual Deposition Without Written Transcript
12.12 Notice of Taking A-V Depo no Transcript.DOC

Objections to Taking Deposition and Motion for Protective Order
12.18 Objections to Taking Depo & Motion-Protective Order.DOC

Receipt for Subpoena
12.22 Receipt for Subpoena.doc

Additional Paragraph to Add to the Subpoena Duces Tecum to an Adverse Expert for His or Her Deposition
12.27 Additional Paragraph to Add to the Subpoena Duces Tecum to an Adverse Expert for His or Her Deposition.DOC

Portion of Notice to Take a Deposition of Adverse Expert
12.28 Portion of Notice to Take a Deposition of Adverse Expert.DOC

Chapter 13 Damages List

Plaintiff’s Request for Admissions Re Medical Expenses
13.2 Plaintiff’s Request for Admissions Re Medical Expenses.DOC

Personal Injury Special Damages List
13.4 Personal Injury Special Damages List.DOC

Chapter 17 Motions in Limine

Motion in Limine Opening Section
17.1 Motion in Limine Opening Section.DOC

Plaintiff’s Motion in Limine
17.2 Plaintiff’s Motion in Limine.DOC

Defendant’s Motion in Limine
17.3 Defendant’s Motion in Limine.DOC

Chapter 18 Motions – Orders

Plaintiff’s Oral Dictation of Motion for Directed Verdict
18.2 Plaintiff’s Dictation of Motion for Directed Verdict.DOC

Defendant’s Oral Dictation of Motion for Directed Verdict
18.3 Defendant’s Dictation of Motion for Directed Verdict.DOC

Chapter 19 Voir Dire – Juror List

Voir Dire Diagram
19.04 Voir Dire Diagram.DOC

Basic Jury Questionnaire
19.10 Basic Jury Questionnaire.DOC

Jury Questionnaire, Bodily Injury Cases
19.11 Jury Questionnaire–Bodily Injury Cases.DOC

Jury Questionnaire, Breach Of Contract Cases
19.12 Jury Questionnaire, Breach of Contract Cases.DOC

Jury Questionnaire, Product Liability Cases
19.13 Jury Questionnaire–Product Liability Cases.DOC

Voir Dire Preparation Worksheet
19.14.01 Voir Dire Preparation Worksheet.DOC

Sample Challenge Questions
19.16 Sample Challenge Questions.DOC

Chapter 20 Opening Summation

Form Checklist — Objections During Opening Statements
20.4 Checklist — Objections During Opening Statements(2).DOC

Chapter 22 Settlement

Settlement Offers Record
22.4 Settlement Offers Record(2).DOC

Negotiation Preparation Worksheet
22.5 Negotiation Preparation Worksheet(2).DOC

Settlement Conference Computations
22.6 Settlement Conference Computations(2).DOC

Plaintiff Attorney’s Closing Letter On Successful Settlement
22.8 Plaintiff Attrny Closing Letter Success Settlement(2).DOC

Chapter 23 Insurance

Insurance Coverage, Handling, & Subrogation Liens
23.4 Insurance Coverage, Handling, & Subrogation Liens.DOC

Chapter 30 Planning and Delegation

Request For Admission To Defendant
30.04 Request for Admission to Defendant.DOC

Request For Damages Disclosure
30.06 Request for Damages Disclosure.DOC

Prioritizing Cases In Your Office
30.10 Prioritizing Cases in Your Office.DOC

Defense Attorney Time Guideline
30.13 Defense Attorney Time Guideline.DOC

Bodily Injury Case – First Letter To Client Plaintiff
30.14.02 Bodily Injury Case – First Letter to Client Plaintiff.DOC

Bodily Injury Case – First Letter To Client Defendant Assigned To You By Insurer
30.14.03 Bodily Injury Case – First Letter to Client Defendant Assigned to You by Insurer.DOC

First Letter With Attachments By Defense Attorney To Insurer
30.14.05 First Letter With Attachments by Defense Attorney to Insurer.DOC

Attachment With First Letter By Defense Attorney To Insurer; Law Firm’s Checklist Of Work To Be Done
30.14.06 Attachment With First Letter by Defense Attorney to Insurer; Law Firm’s Checklist of Work to Be Done.DOC

RYON — A Form For Delegating Common Tasks
30.21 RYON – Form For Delegating Common Tasks.doc

Checklist Of Actions To Take If You Miss The Deadline
30.24 Checklist – Actions if You Miss Deadline.DOC

“Outsourcing Work” Clauses For Retainer Agreements
30.29 Outsourcing Work Clauses.DOC

Checklist On The Ethics Of Outsourcing Legal Work
30.30 Checklist on the Ethics of Outsourcing Legal Work.doc

Checklist For Terminating Representation
30.31 Checklist for Terminating Representation.doc

Advice To Client About Messages Using Workplace Devices
30.34 Advice to Client about Messages Using Workplace Devices.doc

Chapter 31 Litigation Tips and Tactics

Non-Engagement Letter
31.02 Non-Engagement Letter.DOC

Joint Counsel Agreement — Plaintiffs
31.06 Joint Counsel Agreement – Plaintiffs.DOC

Joint Counsel Agreement — Defendants
31.07 Joint Counsel Agreement – Defendants.DOC

Joint Working Agreement
31.11 Joint Working Agreement.DOC

Rules For The Individual Client In The Average Case
31.14 Rules for Individual Client in Average Case.DOC

Attorney And Client Response To The Media
31.15 Attorney and Client Response to the Media.DOC

Social Media Building Blocks For Your Deposition Questions
31.20 Social Media Building Blocks for Your Deposition Questions(2).doc

Instructions To Individual Client About Social Media Internet Pages
31.22 Instructions to Individual Client About Social Media Internet Pages.DOC

Social Media Building Block For Depositions
31.23 Social Media Building Block for Depositions.DOC

Demand For Production Of Social Media Content, With Attached Consent
31.25 Demand for Production of Social Media Site Content, With Attached Consent.DOC

Chapter 40 Discovery Depositions

The “Always Ask Block” of Deposition Questions
40.02.02 The Always Ask Block of Deposition Questions.DOC

Notice of Plaintiff’s Deposition of Corporate Defendant
40.11 Notice of Plaintiff’s Depo of Corp Defdnt.DOC

Deposition Checklist: Assets Examination Questions
40.15 Deposition Checklist — Assets Examination Questions.DOC

Form: Add-On to Notice of Deposition if Asking Questions About Assets
40.16 Form — Add-On to Notice of Depo if Asking Questions About Assets.DOC

Chapter 45 ESI – Tactics and Discovery

The First ESI Mistake To Avoid — and a Checklist to Avoid It
45.03 The First ESI Mistake to Avoid-Checklist.DOC

Preservation Letter To Client
45.20 Preservation Letter to Client.DOC

Preservation Letter To Adversary Attorney
45.21 Preservation Letter to Adversary Attorney.DOC

Meet And Confer Report Regarding ESI
45.22 Meet and Confer Report Regarding ESI.DOC

Clawback Privilege Non-Waiver Agreement
45.23.06 Clawback Privilege Non-Waiver Agreement.doc

Motion Requesting Court Order For Clawback Protective Order
45.23.07 Motion Requesting Court Order for Clawback Protective Order.doc

Clawback Protective Order
45.23.08 Clawback Protective Order.doc

Quick-Peek Privilege Non-Waiver Agreement
45.23.09 Quick-Peek Privilege Non-Waiver Agreement.doc

Checklist: Deposition of IT Person Regarding ESI; the “IT/ESI Depo”
45.24 Deposition of IT Person Regarding ESI-Checklist.DOC

Checklist: Protocol for On-Site Computer Search and Inspection
45.28 Protocol-On-Site Comp Search & Inspection-Checklist.DOC

Agreement, Order, or Directions for Forensic Imaging (Only) of Computer or Other ESI Storage Devices (Yours or Theirs)
45.29 Agmt, Order, or Dir for Forensic Imaging of Comp or other ESI Storage.doc

Agreement or Court Order for Inspection of Forensic Image Previously Made of Computer or Other ESI Storage Devices (Yours or Theirs)
45.29.01 Agrmt or Order for Inspec of Forensic Img Previously Made of Comp or Other ESI device.DOC

Agreement or Order for Examination of Opponent’s Computers and ESI Storage Devices
45.30 Agmt or Order for Exam of Opponent’s Computers and ESI Storage.doc

Impasse Clause
45.31 Impasse Clause.doc

Chapter 46 Bodily Injuries – Tactics and Discovery

Plaintiff’s HIPAA-Compliant Release
46.16 Plaintiff’s HIPAA-Compliant Release.DOC

Defendant’s HIPAA-Compliant Release
46.17 Defendant’s HIPAA-Compliant Release.DOC

HIPAA-Compliant Release Form — Authorized Person and Specific Directions
46.18 HIPAA-Compliant Release Form.DOC

Release For Records Which Must Be Separately Requested
46.18.02 Release for Records Which Must Be Separately Requested.doc

Checklist Of Plaintiff’s Bodily Injuries
46.20 Checklist of Plaintiff’s Bodily Injuries.DOC

Stipulation For Physical Examination
46.23 Stipulation for Physical Examination.DOC

Client Handout For Defense Medical Exam
46.24 Client Handout for Defense Medical Exam.DOC

Request For Social Security Earnings Info
46.26 Request for Social Security Earnings Info.pdf

Request for Copy of Tax Return, Form 4506
46.27 Request for Copy of Tax Return–IRS 4506.pdf

Request for Transcript of Tax Return, Form 4506-T
46.28 Request for Transcipt of Tax Return–IRS 4506t.pdf

Take-Home Instructions – Bodily Injury Client
46.30 Take-Home Instructions – Bodily Injury Client.DOC

Form: Authorization re Employment and Education – From Client to Own Attorney
46.32 Form — Authorization re Emplymt and Edu – From Client to Atty.DOC

Form: Authorization re Employment and Education – Requested From Adverse Party
46.33 Form — Authorization re Emplymt and Edu – Requested From Adverse Party.DOC

Form: Additional Paragraph Protecting Client Giving Authorization re Employment and Education
46.34 Form — Addl Paragraph Protecting Client re Emplymt and Edu.DOC

Form: Letter Request for Employment Records to Compute Loss of Earnings
46.36 Form — Letter Req for Emplymt Records to Compute Loss of Earnings.DOC

Chapter 47 Bodily Injuries – Deposition Checklists

Checklist: Defendant’s Deposition of Personal Injury Plaintiff
47.02 Defendant’s Deposition of Personal Injury Plaintiff.DOC

Checklist: Personal Injury Plaintiff’s Trial Testimony
47.03 Personal Injury Plaintiff’s Trial Testimony.DOC

Checklist: Testimony of Personal Injury Plaintiff’s Spouse
47.05 Testimony of Personal Injury Plaintiff’s Spouse.DOC

Deposition or Trial Testimony: Parent in Wrongful Death Case
47.06 Depo or Trial Test – Parent in Wrongful Death Case.DOC

Written Deposition, Medical Records Foundation
47.07 Written Depo – Medical Records Foundation.DOC

Plaintiff’s Cross-Questions to Medical Custodian, or Reasonableness of Medical Expenses
47.09 Plaintiff’s Cross-Quest to Med Custodian.DOC

Deposition or Trial Checklist — Plaintiff’s Direct Examination of Treating Doctor
47.12 Checklist – Plaintiff Examines Treating Doctor.DOC

Deposition Checklist — Defense Examination of Plaintiff’s Treating Doctor
47.13 Checklist – Defense Examination of Plaintiffs Doctor.DOC

Notice to Doctor Being Deposed re What to Bring to Deposition
47.15 Notice to Doctor Being Deposed – What to Bring.DOC

Trial Checklist — Defense Direct Examination of Defense Doctor
47.17 Checklist – Defense Examination of Defns Doctor.DOC

Plaintiff’s Cross-Examination of Defense Doctor’s Testimony
47.19 Plaintiffs XExam of Defense Doctors Testimony.DOC

Additional Direct Testimony: Plastic Surgeon
47.23 Additional Direct Testimony-Plastic Surgeon.DOC

Checklist: Deposition or Trial Checklist — Direct Examination by Plaintiff of Plaintiff’s Physical Therapist
47.25 Depo, Trial Checklist-Direct by P of Plaintiff’s PT.DOC

Chapter 51 Testimony

Form: Telling Witnesses About Talking to the Other Side
51.2.01 Form — Telling Witnesses About Talking to Other Side.DOC

Pointers for Witnesses
51.3 Pointers for Witnesses.DOC

Pointers for Your Video Deposition
51.5 Pointers for your Video Depo.DOC

Request for Notice of Intent to Use Conviction
51.7 Request for Notice of Intent to Use Conviction.DOC

Chapter 52 Exhibits and Evidence

Objections Checklist, a Quick Reference List for Your Trial Notebook
52.10 Objections Checklist – Quick Ref for Trial Notebook.DOC

Checklist of Tools to Attack Adverse Demonstrative Exhibits
52.12.02 Checklist of Tools to Attack Adverse Demonstrative Exhibits.doc

Exhibits Foundations Checklist, a Quick Reference List of Your Trial Notebook
52.13 Exhibits Foundatns Chcklst – Quick Ref for Trial Notebook.DOC

Practical Tips for the Investigator, to Prevent Charges of Spoliation
52.27 Practical tips for the investigator.doc

Chapter 56 Opening Statement and Closing Argument

Form: Workspace for Forming an Opening Statement
56.11 Form — Workspace for Forming Opening Stmt.DOC

Form: Pattern for Outline of Closing Argument
56.28 Form — Pattern for Outline of Closing Argument.DOC

Chapter 57 Attorney Fee Awards

Checklist: Content of the Billing Attorney’s Affidavit or Testimony
57.11 Checklist Content of Billing Attrnys Affidavit-Testimo.DOC

Exemplar Format: Billing Attorney’s Affidavit
57.12 Exemplar Format Billing Attrnys Affidavit.DOC

Motion to Grant Attorney Fees
57.13 Motion to Grant Attorney Fees.DOC

Special Jury Question on Attorney Fees
57.14 Special Jury Question on Attrny Fees.DOC

Order by Court as Fact Finder on Attorney Fee
57.15 Order by Court as Fact Finder on Attrny Fee.DOC

Checklist for Direct Examination, Expert Witness on “Reasonable Attorney Fee”
57.18 Checklist for Direct Exam, Expert Witness.DOC

Deposition Checklist, Adverse Fee Expert
57.20 Depo Checklist Adverse Fee Expert.DOC

Chapter 60 Motor Vehicle Accident Case

MVA, One-Sheet Plus One Page, Summary
60.02 MVA, One-Sheet Plus One Page Summary.DOC

Take-Home Instructions to MVA Plaintiff Client
60.04 Take-Home Instructions to MVA Plaintiff Client.DOC

Checklist: Deposing the Driver in an Auto Accident
60.05 Checklist Depo the Driver in Auto Accident.DOC

Notice to Bring Items to Deposition — Motor Vehicle Accident
60.07 Notice to Bring Items to Depo–MVA.DOC

Checklist: Deposition/Interview/Trial — MVA — Police Investigating Officer
60.09 Checklist Depo-Interview-Trial MVA Police Officer.DOC

Checklist: Deposition/Interview/Trial Direct Testimony — MVA — Scene Witness Not in Involved Vehicles
60.10 Depo-Interv-Direct Test – MVA – Witness Not Involved.DOC

Deposition Checklist — Truck Driver Under Control of Defendant Company
60.12 Depo Checklist–Truck Driver with Defendant Co.DOC

Notice of Plaintiff’s Deposition of Company Controlling Driver
60.14 Notice of Plaintiffs Depo of Co Control Driver.DOC

Initial Spoliation Letter in Truck Accident Case
60.16 Initial Spoliation Letter in Truck Accident.DOC

Short Checklist — Photo Assignment — Motor Vehicle Accident
60.18 Short Checklist Photo Assignment MVA.DOC

Chapter 61 Premises Liability Cases

Plaintiff’s Fall-Down Allegations Checklist
61.04 Plaintiff’s Fall-Down Allegations Checklist.doc

Interrogatories and Demands for Production to Premises Liability Defendant
61.08 Interrog and Demands for Production – Premises Liabl Def.DOC

Request for Inspection of Premises
61.09 Request for Inspection of Premises.DOC

Inspection of Premises Combined With Demand for Production of Items on the Premises
61.11 Inspection of Premises Combined With Demand for Production of Items on the Premises.doc

Checklist: Plaintiff’s Deposition of Premises Liability Defendant
61.13 Plaintiff’s Deposition of Premises Liability Defendant.DOC

Checklist: Defendant’s Deposition of Slip & Fall Plaintiff
61.15 Defendant’s Deposition of Slip & Fall Plaintiff.DOC

Notice of Plaintiff’s Deposition of Corporate Premises Liability Defendant
61.16 Notice of Plaint Depo of Co Premises Liabl Def.DOC

Chapter 62 Liquor Liability Involvement

Deposition Checklist — Liquor Liability: The Intoxicated Person
62.2 Liquor Liability – Intoxicated Person.DOC

Deposition Checklist — Liquor Liability: The Nonparty Witness
62.3 Liquor Liability – Nonparty Witness.DOC

Checklist: Deposition/Interview/Trial — Liquor Liability: The Investigating Police Officer
62.4 Liquor Liability – Investigating Officer.doc

Request for Production of Documents to Dram Shop
62.6 Request for Prod of Docs to Dram Shop.DOC

Deposition Checklist — Liquor Liability: The Dram Shop Owner or Employee
62.7 Liquor Liability – Dram Shop Owner or Employee.DOC