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Break these up into multiple billed tasks if it is going to be a lot of review over multiple days:
Detailed analysis of key documents and evidence (identify document categories and/or page numbers to show why it is taking that amount of time, such as over 300 pages of written discovery responses or trial exhibits) to identify and prepare for issues to address at trial, including [ specific tasks where possible, such as (voir dire, jury charges, motions in limine, evidentiary arguments, witness examinations, exhibit selection, objections, deposition designations, impeachment evidence, damages analysis, etc.)], and prepare for trial presentation and arguments.
I would generally group things together and bill in this way. Such as:
Detailed analysis of plaintiff’s medical bills and records (280 pages) to plan and prepare for trial analysis of damages and strategies for impeachment. (Would do by provider if a lot and bill for each separately)
Detailed analysis of plaintiff’s pleadings and causes of action to plan and prepare trial presentation to refute allegations, present affirmative defenses, and determine requests for charge.
Review plaintiff’s discovery responses to identify key admissions and prepare for examination at trial.
Review deposition testimony of X to identify necessary designations and testimony to highlight at trial for impeachment and general questioning to support defense.
@Attorney2 Your billing game is superb!
Review file, trial prep, etc. at the end of the day, the partner will review the billing and make edits if they need to
Roll it into trial prep. If you frame it as reviewing file to get up to speed it's gonna get denied.
@author you need to be descriptive. If you're reviewing deposition of plaintiff, something like "Review and analysis of Plaintiff's deposition transcript (128 pages) for the purpose of preparing for trial, specifically identifying prior testimony that could be used for impeachment purposes and attacking Plaintiff's credibility during trial."
Is it bullshit? Probably. Will it get paid, also probably.
Review and analyze file [or pleadings, discovery, deposition transcript, etc] to ensure thorough understanding of the record in preparation for trial.
Agreed with LA1, I would probably add something. Else in here like prepare outline of topics for direct cross etc or identify subpoenas needed etc
I agree with breaking it up. I would also use this time to “Itemize and identify defense trial exhibits in furtherance of defense strategy and ultimate defense of case at trial”
When I review the file generally, i try to be specific to why i reviewed what i reviewed because let’s be real - i’m going to need to read a deposition or check out records again. So at this point i would bill for :
“Comprehensive and analytic review of (deposition, record, etc) in furtherance of formation of defense strategy and ultimate defense of case at trial” because that’s what you’re doing. You’re trying to figure out the case and learn what you’ve got.
In 3 weeks though, you may need to read the same depo again to do page lines or build a cross exam. You’re not expected to be an almanac and just remember everything in a depo from reading it once, so that specificity provides the client the opportunity to read the bill, get why you read the same depo each time, and likely pay both entries.