Help! My to-do list is empty but I need to put in some hours. What are some sure fire things all my cases probably need? (It’s standard insurance defense litigation.)

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Send out 10 1-sentence emails then chill for 50 minutes. It is efficient even

likefunny

Summaries. Summarize discovery, summarize depositions, summarize medical records (if not done by a paralegal). Partners will also love if you take initiative and review cases for what needs to be done. I would then send an email to the partner on the file saying, Hey I reviewed case Mark v. Scott and it looks like we still need to send discovery to the Plaintiff, or its been more than six months since we updated the client, should I prepare a status report to the client with a recommended plan of action?

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If you are in insurance defense, you almost certainly have files that need attention.

likefunny

Pull out the jury instructions and start making a proof chart. It will show you gaps in your evidence that you need to figure out before SJ/trial.

likehelpful

Strategy! What are next steps, how can you move the ball for the client? Are there any issues to research? Potential exhibits to review/mark in the file? Also agree with summaries of documents.

likefunny

Am I the only one who needs to check with the partner before taking initiative so as to not rack up the bill

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Organization in general.

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I'd say the hard copy files. They could always stand to be tidied up.

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Reporting on literally anything, phone calls, emails. If you are in insurance defense there is always something to do. “Plan and prepare to make phone call to counsel regarding discovery by reviewing xxx”; “Phone call to xxx regarding discovery”; “Draft and send follow up correspondence to counsel regarding phone call and discovery”; “Draft and send correspondence to the carrier relating to phone call with counsel regarding discovery”. - Really easy stuff.

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Med chron in prep for trial (of not done by paralegal). There never seems to be enough time as you get closer to trial to you start one and always need one.

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Make a chronology table of an important event in litigation. This is so helpful to have an outline of the dates, times, and events that happened come summary judgment.

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Social media search!!!!! Easy .6 or .7

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Check to see if Plaintiff’s discovery is overdue. If so, send a 10-day letter and then a boilerplate motion to compel. You can bill tons in drafting discovery motions when they only take you minutes.

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Doc review

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Every open matter should get a review/client update at least once a month.

You can also review pleadings, discovery, and any settlement developments to keep your memory of issues in the case fresh.

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Status letters, doc review, IME designations, review of transcripts for review

Depends if you are micromanaged. But report on everything and once all depositions are done time for a mediation.

Request for production, supplement discovery, amended answers, pretrial documents, social media checks of parties and witnesses.

Go down the list of tasks you can bill the client and send email based on something that’s happened in the last 2 weeks. Likely things have happened but you may not have had time to let client know. I also randomly check to see if opposing parties have filed any new cases against any similar entities to my client. If so, there’s a lot of factual research re that you can do

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