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Trial Prep for Paralegals: Working With Your Attorney (Part I)

Trial Prep for Paralegals: Working With Your Attorney (Part I)

by Michael L. Coyne, Esq. and Ursula Furi-Perry, Esq.

How can the attorney-paralegal team best work together in preparation for and during trial? Paralegals will find valuable tips for working together with their attorneys in this chapter.
Chapter 14 Overview

After reading this chapter, you should be familiar with

  • tasks that attorneys assign to their paralegals before and during trial;
  • the importance of collaboration between the attorney and paralegal;
  • tips for working together with your attorney;
  • tips for strengthening the attorney-paralegal team.

By now, you understand that paralegals perform integral practical functions as part of the attorney’s preparation for trial; you also know that paralegals must be familiar with the substantive and procedural rules that govern the trial process. But there is one more key component to assisting your attorney efficiently and effectively: working together as the attorney-paralegal team.Consider the following twenty “commandments” for working together with your attorney:

  1. Cooperate. You should always strive for cooperation and collaboration with your attorney. For example, arrive early to work or offer to stay late and work with the attorney whenever a case requires you to, rather than running out of the office at 5 PM on the dot. Working together as a team will make for more efficient and effective trial preparation.
  2. Collaborate. You should keep the lines of communication open between you and your attorney. Do not assume that you know what the attorney is thinking-or vice versa. When things are the craziest, say, “How is it that I can help you get done what needs to be done?” Don’t just wait for a task to be assigned. Keep the dialogue between you and the attorney going to make your team stronger and more effective.
  3. Strategize. You should ensure that you fully understand and know your attorney’s goals and strategies before and at trial. For instance, before you call the copy shop to place an order, ask the attorney whether there are any copies of exhibits he or she would like you to order in color. Ideally, you should discuss with your attorney any new task that you are entrusted with to see how the task-and your work-fits into your attorney’s trial prep strategy.
  4. Coordinate. You should ensure that your plans and workload correspond to your attorney’s plans and workload before and at trial. If you are not on the same page as your attorney, your team will not be effective at planning and conducting litigation. For example, after you’ve finished a discovery-related task that the attorney assigned to you, ask the attorney what you can work on next. Understand what your attorney needs from you-for everything the attorney does, you should be familiar with the corresponding paralegal tasks that you need to do to facilitate your attorney’s job.
  5. Anticipate. You should anticipate your attorney’s needs at trial. Whether it is extra copies of exhibits, last-minute research, or witness coordination, things may pop up during the trial that your attorney will need your immediate help with. Take extra supplies and copies with you to trial. Make your job (and your attorney’s) as easy as possible by accounting for your attorney’s needs at trial before you get to the courtroom.
  6. Organize. You should assist your attorney with organization in preparation for and during trial. Have a checklist ready for every paralegal task in preparing for trial, and keep to your checklists. From the trial notebook to the war room to electronically stored information, your attorney is counting on you to keep things organized, thereby ensuring efficiency and productivity.
  7. Stay efficient. You should strive for efficiency in preparation for trial and during trial. For example, anticipate what documents the attorney will need to conduct a deposition, put them together early, and make sure the attorney has them in an organized format at the deposition. Perhaps the most important way litigation paralegals can assist their attorneys in preparation for trial is by increasing the attorney-paralegal team’s efficiency.
  8. Research. You should hone your research skills and assist effectively in research tasks. Find legal authority for that new case that the attorney intends to file on behalf of a new client. From legal research to fact-gathering and factual investigation, the paralegal’s involvement is essential.
  9. Maintain files. You should assist your attorney with case and file maintenance. Paralegals are often in charge of setting up and maintaining new files, both electronically and in hard copy form. Master the skills you need to ensure that your attorney’s files stay organized, secure, and easy to retrieve. There are five words that every busy trial attorney likes to hear: “I know where that is.”
  10. Keep secure. You should assist your attorney with keeping the case secure. For example, ensure that the contents of the trial notebook and war room are secure at all times and their contents are accounted for and properly overseen by you. Protecting confidentiality is essential, and the paralegal can play a big part.

Excerpted from Trial Prep for Paralegals by Michael L. Coyne, Esq. and Ursula Furi-Perry, Esq. (National Institute for Trial Advocacy, 2009). Part II, 11-20 of the “commandments”, will be posted next Monday at Practical Paralegalism.

3 Responses to Trial Prep for Paralegals: Working With Your Attorney (Part I)

  1. Thanks, Lynne, for featuring a great resource for litigation paralegals! While every area mentioned is important, I have personally found that "Anticipate" is a key to success in the everyday life of a paralegal. The value of a paralegal who can anticipate her attorney's needs and be one step ahead of him/her is priceless!

Contact Info:

Lynne J. DeVenny, N.C. State Bar Certified Paralegal

Owner & Virtual Paralegal, DeVenny Paralegal Services

Email: lynne.devenny[at]

Telephone: 336-582-0003

Inquiries are welcome, with free quotes available.

Meet Lynne:

Lynne DeVenny is a North Carolina State Bar Certified Paralegal with over 27 years of experience working on complex litigation cases, including medical malpractice, personal injury, workers’ compensation, and Social Security disability.

Disclosure: I am not a lawyer and cannot provide legal representation or legal advice.

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