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Standard Paragraphs Stored for Easy Retrieval
Typical Material Which should be Stored Electronically
Data which should be Indexed and Stored for Easy Retrieval
Typical Material Which
Should be Stored Electronically
Payroll/accounting data
Client identification for determining possible conflicts of interest as to representation of a client
Key relevant documents
Facts of similar cases wherein you might find a common denominator, such as a common supplier or distributor
Summaries and pages from trial transcripts
Former decisions of your local trial judges coded by subject matter of the cases that were heard before them
Witness testimony
Discovery matters
Research, whether substantive law with supporting cases or other.
Subject matter
Cross indexing of facts
The legal issues
Summary of facts
Other affirmative defenses
Other bases for motion to dismiss (demurrer)
Diplomatic immunity
Unclean hands
Doctrine of res judicata
Rescission
Another action pending
Partial payment of obligation
Exemption from prosecution
lack of capacity to sue
Laches
Imputed negligence
Statute of frauds
Statute of limitations
Discharge of bankruptcy
Wrong party
Wrong jurisdiction
A counter-breach of plaintiff
Duress
Comparative negligence
Assumption of risk
Estoppel
Accord and satisfaction
Failure of consideration
Failure to state a claim from which relief can be granted
Failure to state a cause of action
Deposition methodology
Deposition digest
transcript of deposition
summary of deposition
entire testimony of deposition
