NEW CASES:

• Organize & index medical records

• Prepare detailed medical chronology on case-by-case basis

• Prepare KOR subpoenas / Notice of Deposition in absence of secretary

• Prepare medical records releases to be signed by plaintiff for out of state health providers

TRIAL PREPARATION:

• Prepare trial notebook & trial boxes

• Completion of medical binders

• Prepare summary of depositions

• Prepare list of all notices of depositions & KOR subpoenas issued

• Prepare chart of all parties' experts

• Prepare chart of all documents available for expert review in this case (offer of proof with expert report; answers to interrogatories; depositions; medical records; 79C medical articles),

• Review all correspondence sent to experts throughout case to determine what documents they have received to date.

• Review chart with associate to determine which additional documents experts are to review

• Prepare 79G Notice of Intent and Affidavit for use at trial

• Obtain all medical articles for plantiff 79Cl

• Review all Production of Documents to label contents

• Review IDEX testimonial history reports

• When transcripts arrive, label folder with case description & verdict outcome h would be most helpful in his preparation for that expert at trial

• Search internet including MA Medical Board of Registration for info on plaintiff's experts, and any media information re; expert

• Request updated CVs from our experts

• Schedule attorney meetings experts prior to trial, and set up trial testimony date as attorney directs