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

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

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

[The first 10 “commandments” for working with your attorney were posted last Monday; here are “commandments” 11-20:]

11. Observe. You should serve as your attorney’s extra set of eyes and ears. For example, you can help by observing a witness’s behavior for credibility or looking out for a witness’s arrival to court. The paralegal is often entrusted with observing the things that a busy attorney cannot.
12. Meet deadlines. You should stay productive, meet deadlines, and handle your share of the workload. Trials are busy, and they are often fraught with time crunches, stress, and deadlines (some of them cropping up at the last minute). For instance, you can play a key role in a case by obtaining that last-minute exhibit that the attorney needs for his or her trial presentation. Better your time management skills to make the most of the time you have on the job, thereby increasing your attorney’s productivity.
13. Stay current. You should keep up-to-date on relevant rules, technology, and trial preparation methods and tools. Technology and the law have something in common: they can both change quickly, sometimes from one day to the next. You should strive to keep up-to-date in your role as a paralegal, so you can ensure that your attorney is up-to-date on both legal and technical issues. One way to stay current is by reading relevant books, trade journals, and other publications.
14. Assist. You should assist your attorney with coordinating the witnesses, exhibits, and documents that will be presented at trial. For example, you may be the person in charge of coordinating witnesses and exhibits. Whatever tasks are assigned to you, make efficient use of your time when it comes to assistance at trial.
15. Understand. You should understand the work of your attorney, as well as any constraints on your attorney. Paralegals must be familiar with the daily work of their attorneys and they must also understand any boundaries that the attorney must keep, in order to tailor the paralegal’s own work to the attorney. For example, you have to be familiar with the rules of ethics, any budgetary or time constraints, and any strategy considerations that may a part in the attorney’s approach before and during trial.
16. Serve your purpose. You should be clear about your job responsibilities and how your work fits into trial preparation. Understand the tasks you are there to do (as well as the tasks that should be left up to your attorney) and the purpose and roles you serve as a member of the trial team. For instance, you may be entrusted with interviewing the client during intake, though you should never give the client legal advice about the client’s case.
17. Seek guidance. You should be willing and able to ask your attorney for guidance whenever you need it. It is essential that you know whom you can turn to if you have questions or need assistance on the job. For example, if you’re handling a type of case with which you’re not familiar, seek out the advice of a more experienced paralegal or other legal professional about some of the key tasks and checklists you can anticipate. Do not assume that you can figure out the answers when you are not entirely sure of the correct thing to do or say; ask for help.
18. Seek training. You should request training when you need it, seek out training on your own, and keep up with your training through continuing education and professional development opportunities. For example, you can find training and professional development opportunities through paralegal associations, paralegal schools, bar associations, and other groups for legal professionals. Also take advantage of any training opportunities that your firm or attorney offers.
19. Seek evaluation. You should seek to be evaluated periodically, and ask your attorney about areas in which you can improve your work. Request a periodic evaluation, asking the attorney about your strengths and weaknesses. You should also conduct periodic self-evaluations and keep track of your professional accomplishments and goals.
20. Stay professional. You should aim to have a professional and pleasant relationship with your attorney-as with any relationship, the “Golden Rule” applies to the attorney-paralegal team. Even when trial preparation becomes stressful or you encounter a difficult client, strive to keep your cool. Stay courteous, clear, and professional-doing so will help you establish a positive reputation in the legal field.

By keeping these twenty tips in mind, you can work towards strengthening your professional relationship with your attorney, which will ultimately make the attorney-paralegal team stronger when it comes to trial preparation. Remember: effective and efficient trial preparation requires that the attorney and paralegal work together as a team.


Excerpted from Trial Prep for Paralegals by Michael L. Coyne, Esq. and Ursula Furi-Perry, Esq. (National Institute for Trial Advocacy, 2009).

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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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