Some Thoughts About Organizing Discovery Documents & Trial Exhibits

After preparing for trial a few times, here are my thoughts about organizing discovery documents (usually in pdf format) and deciding which should be used at trial.

Use an excel spreadsheet to organize discovery documents as they come in.  

This spreadsheet can be very useful in several ways:

1.  To sort documents by bates number or by date or by element of the cause of action.  All you need to do is click the top box down arrow and the documents are automatically sorted in ascending or descending order based on bates number or date, etc.  This can be very useful to look at the documents:

-- in chronological order (instead of the order in which they are produced)

-- in order of element of the cause of action (because you can see when you don't have documents relating to a certain element eg causation)

-- you can sort the trial exhibits column so just the exhibits you want to use at trial will be listed at the top of the spreadsheet.

2.  If all the discovery documents are placed in the same folder as this spreadsheet, you can right click in a cell with a bates number and link that cell to the exact document.  After you link each bates cell to the specific document, you can click on the bates number while in the spreadsheet and the document will open so you can look at it.  

3.  Finally, when it comes to trial, you can delete columns E through H and you have your list of exhibits for use at trial.