What Does A Paralegal Do At Trial: Six Things Your War Room Must Have

By: Christina Roberts, CP

Going to trial can sometimes seem as if you are going to war.  You suit up – putting on your finest armor and best effort, yet sometimes you still hit brick walls all day long during a trial. Having a well-organized place to concentrate and collaborate during trial can calm the trial tension.  A “war room” basically serves as an office away from the office with all the comforts of the office back home.  Sounds simple enough, right? There are many ways to organize your trial war room. There is no absolute right or wrong way to organize the war room, as long as you can find what you are looking for and the trial team can be semi-self-sufficient, you have done a good job.

Trial war room organization really begins months before you set eyes on the actual war room. As the documents are reviewed, analyzed and discussed among the trial team, keep notes. Use these notes to organize the case into categories. There are many litigation technology products that can help with this aspect of trial planning. It is very important at this point to keep a record of everything and know where everything is located, even if you must use Excel spreadsheets. If you ignore this step, your trial will likely have a few hiccups.

Contacts. There must be a comprehensive list of everyone involved in the case. Organize them by their role in the trial. Remember to ensure everyone has an electronic copy of your Contact List, and put several copies of these in the trial war rooms and attorney notebooks.

  • Courts: Judge, Judge Administrator, Court Reporter
  • Vendors: Printer Rental, Fax Rental, Copier Rental, Hotel Rental, Travel Agent
  • Trial Team: Lead Attorney, Associate Attorney, Paralegal, Legal Assistant, Technology Assistant

Equipment. Always have extra equipment. Spend some time thinking about supplies you may need during a trial and make a personalized list. Take or rent everything you need to set up a mini office, including:

  • High-quality copier;
  • Fax machine;
  • High-quality printer, computers.

Remember to bring simple things like:

  • Power strips and broadband plug-ins (just in case the wireless access is bad);
  • Extra paper and envelopes;
  • Pens, pencils, and Sharpies;
  • Pencil sharpener, a hole puncher, and a stapler.

Trial Index Notebook. To truly ensure a smooth trial, a notebook dedicated solely to the index of the case materials is a necessity. The idea is for anyone working on the case to have access to the tools to help them locate documents. Each document should be on one of the indices in this notebook.

  • Voir Dire
  • Motions in Limine
  • Opening Statements
  • Exhibits
  • Plaintiff Witnesses (in-chief)
  • Defense Cross
  • Defense Witnesses (in-chief)
  • Plaintiff Cross
  • Closing Statements
  • Judgment
  • “Miscellaneous” (other documents-related-to-case-but-not-an-exhibit)

Assistants. An often over-looked asset at trial is the technology assistant. A technology assistant can save the whole trial team if a computer dies, or a power surge knocks the war room off-line. Anything can happen at trial. An effective trial team has a paralegal and legal assistant. Some trial teams are huge, some are small. It does not matter, as long as the work is done and done correctly.

Personal Supplies. Take some food and water. Going out to eat every night of a trial only happens in the movies. In reality you will probably work late every night. You may have time to eat, or you may find yourself needing a pack of crackers and water until the next break. In the heat of trial, I have known many trial teams to be so keyed-up that their appetite has fled and insomnia has set in. Be sure to have caffeine in your war room.

Physical Set-Up. There are tons of ways to physically set-up a war room. Ideally a conference room at the courthouse or hotel should be procured. Usually the courthouse war room is a temporary location for day-to-day activities and the hotel war room is the permanent trial war room. It is wise to have some bigger equipment or supplies you can leave in the courthouse war room: extra printer, printer toner, paper, and general office supplies – anything that does not have personal case information. The permanent trial war room sometimes has to be set-up in a suite or a hotel room because of hotel availability. The furniture can be re-arranged, or even removed from the room, but the main goal is that everything can be found in a logical location.

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