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GENERAL CHECKLIST

FILING COMPLAINT:
__ Elements of each cause of action checked
__ Statute of limitations checked
__ Summons attached
__ Local forms required
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__ Complaint filed
__ Received file-stamped copy from court
__ Complaint sent to client

SERVICE OF COMPLAINT:
__ Complaint sent out for service
__ Complaint served
__ Proof of Service filed with court

ANSWER:
__ Answer filed/received
__ Answer served on plaintiff
__ Received file-stamped copy of answer from court
__ Answer sent to client

CROSS-COMPLAINT:
__ Elements of each cause of action checked
__ Statute of Limitations Checked
__ Cross-complaint filed
__ Received file-stamped copy from court
__ Cross-complaint sent to client

ANSWER TO CROSS-COMPLAINT:
__ Answer to cross-complaint filed/received
__ Answer served on cross-complaintant
__ Received file-stamped copy of answer from court
__ Answer sent to client

DEFAULT
__ Statutory time to answer expired
__ Notice of default completed
__ Notice of default filed with court
__ Notice of default served on defendant
__ Notice of default sent to client
__ Check local rules for default prove-up requirements
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__ Default prove-up hearing scheduled
__ Default prove-up hearing calendared
__ Default prove-up hearing evidence gathered
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DEFAULT JUDGMENT
__ Default judgment prepared
__ Default judgment signed by judge
__ Default judgment filed with court
__ Default Judgment recorded

DEMURRER:
__ Demurrer researched for each cause of action
__ Demurrer filed with court
__ Demurrer hearing date set
__ Demurrer hearing date calendared
__ Demurrer served on plaintiff
__ Order on demurrer prepared
__ Order on demurrer filed
__ Order on demurrer served on plaintiff

OPPOSITION TO DEMURRER:
__ Each point of demurrer researched
__ Opposition filed with court
__ Opposition served on defendant
__ Demurrer hearing date calendared

REPLY TO OPPOSITION TO DEMURRER:
__ Reply filed with court
__ Reply served on plaintiff

DISCOVERY:
__ Discovery plan developed
__ Interrogatories sent ___ Answered by Opposition
__ Form Interrogatories sent ___ Answered by Opp.
__ Request for production of documents __ Answered by Opp.
__ Request for examination of plaintiff __ Answered by Opp.
__ Request to examine land or items __ Answered by Opp.
__ Requests for Admissions __ Answered by Opp.
__ Depositions set:
__ Plaintiff
__ Defendant
__ Other_______________
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_______________
__ Other discovery __________________________________
__ Motions to compel deadline checked ___________________
__ Motion filed
__ Motion served

RESPONSE TO OPPOSITION DISCOVERY
__ Interrogatories Answered and Verified
__ Form Interrogatories Answered and Verified
__ Request for Production of Documents Answered and Verified
__ Request for Admissions Answered and Verified
__ Deposition dates calendared:
__ Plaintiff
__ Defendant
__ Other
__ Other discovery answered

TRIAL PREPARATION
__ Trial brief prepared
__ Written settlement offers sent
__ Status Conference Statements prepared
__ Stipulations signed
__ Trial notebook prepared
__ Motions in Limne prepared
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__ Jury Instructions prepared
__ Witness List Prepared
__ Exhibit List prepared
__ Subpoenas prepared
__ served
__ Subpoena dueces tecum prepared
__ served
__ Jury fees posted
__ Court reporter fees posted
__ Voir Dire questions prepared
__ Short statement of case prepared
__ Notice to produce witnesses and evidence at trial
served on opposition
__ Witnesses prepared for trial
__ Copies of all documents or document books prepared

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Relevant Laws We STRONGLY SUGGEST Checking Out
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