Committee for Public Counsel Services
Children and Family Law Division
Prepared by Margaret Winchester, Esq.

Trial Kit

  • Extra paper
  • Extra pens including a red pen
  • White out
  • Black marker
  • Paper clips
  • Change
  • Colored paper
  • Pad of paper for clients
  • Colored highlighters
  • Stapler and staple remover
  • Hole punch
  • Extra file folders
  • Extra dividers for trial notebook
  • Stickies/post-its
  • Copy of your facts sorted by date or similar document
  • Copy of facts sorted by issue or chapter or similar
  • Copy of dictation and all records
  • Opening outline
  • Master list of all pre-marked exhibits
  • Master list of all potential witnesses with notation as to party calling
  • Master list of your witnesses with contact information
  • Objection list/evidentiary foundations
  • Master binder with all pre-marked and potential exhibits with a table of contents. If MIL were heard prior to trial make sure all exhibits are appropriately redacted including the master list, the courts exhibits and your working copies.
  • Copies of MIL with each exhibit
  • Direct examination
  • Questions written out or closely structured examinations for each witness with any documents you intend to exam them on plus an extra copy of the document. One for you and one for the witness. Copies of the document for other counsel and the court if it’s not already a pre-marked exhibit.
  • Copies of subpoenas with return of service
  • Cross examination
  • Questions written out or closely structured examinations for each witness with any documents you intend to examine them on plus an extra copy of the document. One for you and one for the witness. Copies of the document for other counsel and the court if it’s not already a pre-marked exhibit.
  • Memorandum of law on any potential evidentiary issues that you expect. Copies of the relevant cases with each memo
  • Master checklist of issues required to prove your case and disprove the opponents
  • Separate pad of paper to keep track of de bene evidence
  • Closing argument
  • List of all potential rebuttal witnesses
  • Proposed findings