The Paralegal Trial Prep Checklist: Every Task From 60 Days Out to Verdict

Trials rarely go wrong in the big moments. They go wrong in small places: a subpoena served without the witness fee, an exhibit sticker that doesn’t match the list, a laptop that won’t connect to the courtroom display. A paralegal trial prep checklist exists to catch those problems weeks before the attorney is standing at the podium.

The countdown below uses the Federal Rules of Civil Procedure and Evidence as its reference point because they are the common template; state rules often follow a similar structure with different numbers and deadlines. Replace every default here with the dates in your scheduling order, pretrial order and the judge’s standing procedures, which control over any checklist.

What should a paralegal do first when a trial date is set?

Build the master deadline list from the controlling orders, then calendar backward. Every other task depends on getting these dates right.

• The scheduling order under Rule 16(b) and any amendments.
• The final pretrial conference date and pretrial order requirements under Rule 16(e).
• The judge’s standing orders and trial procedures, including exhibit numbering and copy requirements.
• Pretrial disclosures under Rule 26(a)(3): unless the court orders otherwise, due at least 30 days before trial, with objections due within 14 days after service.
• Deadlines for motions in limine, proposed jury instructions or proposed findings, deposition designations and exhibit exchange.
• Notice requirements for business records and electronic data certifications under Federal Rules of Evidence 902(11), 902(13) and 902(14).

Turn the list into a countdown keyed to the trial date, so every task has a “T-minus” date and an owner. A simple version looks like this:

What goes on the checklist 60 to 30 days before trial?

Witnesses, subpoenas, certifications and the first full exhibit list. This is the window where long-lead items have to start.

• Witness list and availability. Confirm each witness, their contact details and any blackout dates.
• Trial subpoenas. Under Rule 45, tender one day’s attendance fee and mileage with service, and check the rule’s geographic limits.
• Expert logistics. Travel, fees, testimony dates and the materials each expert will need on the stand.
• Preliminary exhibit list. Every potential exhibit with source, Bates range and sponsoring witness.
• Originals. Locate any physical originals the attorney may need under Rules 1001 to 1004.
• Certifications. Records custodian certifications under Rule 902(11), and certifications for electronic records or copied device data under Rules 902(13) and 902(14), with the required written notice to the other side.
• Deposition designations. Page-and-line designations for witnesses who won’t appear live, and counter-designations under the fairness principle in Rule 32(a)(6).
• Summaries. Any summary of voluminous records under Rule 1006, with the underlying records made available to the other side.
• Illustrative aids. Demonstratives the attorney plans to use, prepared with Rule 107 in mind.
• Stipulations. Proposed stipulations on authenticity and undisputed facts to reduce foundation time.

Schedule witness preparation sessions in this window too. The attorney runs the substance; the paralegal books the time, sends each witness the documents the attorney approves, and confirms travel, parking and what to bring.

What needs to happen 30 to 7 days out?

Exhibits become physical and digital sets, binders get built, and the attorney’s materials take shape. The paralegal’s job here is version control.

• Final exhibit list in the court’s format. See exhibit lists judges can actually follow.
• Exhibit binders built from a single numbered source. The exhibit binder checklist covers tabs and indexing.
• Witness binders: prior statements, deposition excerpts with page:line cites, and the exhibits each witness will see.
• Impeachment materials, organized by witness and topic.
• The attorney’s trial notebook, updated as outlines arrive. See building the attorney’s trial notebook.
• Courtroom technology request, if the court requires advance notice to bring equipment.

Source-linked preparation saves time when exhibits change. If your team keeps facts and working notes tied to source documents, CourtBriefly’s hearing preparation tools can assemble source-linked exhibit binders and track revisions before anything is printed. Exhibit PDFs that are exhibit-numbered, captioned and hashed make it easier to prove the set the court received is the set you prepared.

What has to be confirmed in the final week?

Everything that depends on another person or a piece of equipment. Assume nothing works until you have seen it work.

• Proof of service for every subpoena, filed if the court requires it.
• A witness schedule with arrival windows, phone numbers and a backup plan for each day.
• A technology run-through in the courtroom, if the court permits one, with adapters, a spare laptop and every electronic exhibit in the required format.
• A printed backup of every electronic exhibit.
• Supply kit: stickers, tabs, highlighters, extension cord, chargers, stapler, blank paper.
• Team contact sheet and war-room logistics.
• Client logistics: arrival, attire, seating, and what not to bring into the courtroom.

What does a paralegal track during trial?

Exhibits, witnesses, time and promises. Update the logs in real time and reconcile them every evening.

• Witness log. Who testified, who is next, who is on call. If the court enters an exclusion order under Rule 615, which since 2023 can also restrict excluded witnesses’ access to trial testimony, don’t send transcripts or summaries to a witness without the attorney’s approval.
• Rulings and undertakings. Note every ruling and every on-the-record promise, such as “counsel will provide the full document tomorrow.”
• Time. If the court allocates trial time, keep a running total for each side.
• Next-day prep. Pull exhibits, update witness binders, order daily transcripts if the attorney needs them.

End each trial day with a short reconciliation meeting. Compare your exhibit log with the attorney’s notes and, where possible, the clerk’s list; confirm which witnesses are called for tomorrow and in what order; list every undertaking made on the record and who owns it; and note any exhibit that was referred to but never formally offered. That last item is easy to miss in the moment and hard to fix after the evidence closes. Send the attorney a one-page summary that night so the morning starts with decisions rather than reconstruction.

What is left after the verdict?

Post-trial deadlines and the record. Calendar deadlines the day judgment is entered; in federal court, motions under Rules 50(b), 52(b) and 59 are generally due no later than 28 days after entry of judgment, and appeal deadlines run separately.

• Reconcile your exhibit log with the clerk’s record of admitted exhibits and resolve any differences while memories are fresh.
• Retrieve, store or return exhibits as the court’s rules require.
• Order any transcripts the attorney needs for post-trial motions or appeal.
• Archive the final versions of the exhibit list, binders and trial notebook separately from working drafts.
• Send witnesses and experts a thank-you and confirm any outstanding fee or expense payments.

Where do trial prep checklists break down?

Usually where a task depends on someone outside the team or where versions multiply.

• Subpoenas served late or without fees, leaving a key witness free to decline.
• Certifications without notice. A records certification is only useful if the required written notice went out in time.
• Two exhibit lists in circulation, one in the attorney’s outline and another in the binders.
• Untested technology, especially video clips and audio that play on the office network but not in the courtroom.
• Annotated copies on the witness stand, where they may be seen or requested by the other side.
• No one owns the in-trial log, so admitted exhibits are reconstructed from memory at the end of the day.

Deadlines and procedures vary between courts and between judges, and the supervising attorney decides every strategic question on this list. Your job is to make sure nothing on it is a surprise.