Revised Discussion Draft
LT100 Case Assessment and Administration
LT110 Initial Fact Investigation and Interviews All work relating to ascertaining the facts of the matter, such as interviews of potential witnesses, basic review of documents, etc.
Recommend subtasks:
- Dividing merits versus procedural investigation.
LT120 Initial Document Production and Formal Review Covers pre-discovery document productions and review projects; does not include ad hoc document review.
LT130 Early Case Assessment and Strategy Activities relating to initial case assessment and strategic analysis including preparation of the report and presentation to the client, legal research, etc. This category is not intended to include investigatory work for the purpose of compiling the facts of the matter, or legal research and strategy pertaining to other categories of work.
LT140 Case Organization General case management activities particularly those not pertaining to other categories; examples include technology provision, docketing tasks, assembling the team, document file and records management, database administration.
LT150 Case Management Plan and Budget Preparation and maintenance of the project plan and budget for the entirety of the case.
LT200 Pleadings
LT210 Pleadings Drafting and reviewing complaints, answers, counterclaims, etc. Does not include motions related to other categories such as jurisdictional motions and motions to dismiss.
LT220 Motions Regarding Forum/Venue/Service of Summons & Stays/Transfers Developing, responding to, and arguing all Rule 12(b)(3)-(5) and (7) motions.
LT230 Motions Regarding Personal and Subject Matter Jurisdiction Developing, responding to, and arguing all Rule 12(b)(1) and (2) motions.
LT240 Motion to Dismiss Developing, responding to, and arguing all Rule 12(b)(6) and 12(c) motions.
LT250 Preliminary Injunctions / Provisional Remedies Acivities relating to developing strategy, preparing motions, affidavits and briefs, etc. for preliminary injunctions and provisional remedies.
LT260 Court Mandated Conferences and Mandatory Initial Disclosures Preparation for and attendance at court conferences, including drafting of relevant filings; does not include court appearances connected with another category such as settlement.
LT270 Interlocutory Appeals Filings for interlocutory appeal and all related activity.
LT280 Class Action Certification and Notice Activities specific to class action proceedings including class strategy & analysis, class certification motion & response, depositions (fact and expert), hearings & conferences.
LT300 Settlement and Alternative Dispute Resolution
LT310 Demand Letters and Settlement Discussions All tasks related to settlement discussions including any proposals for settlement, and expert and third party conferences in support of settlement. Demand letter drafting and response are included in this category.
LT320 Mediation Briefing, documentation in support of mediation and post-mediation activities.
LT330 Arbitration Evaluation of arbitrators, briefing, and documentation in support of arbitration and post-arbitration activities.
LT400 Discovery
LT410 Written Discovery to Opposing Party Developing interrogatories and requests to admit.
LT420 Written Responses to Discovery Requests Responding to interrogatories and requests to admit.
LT430 Document Collection and Preservation All tasks relating to identification, preservation, and collection of documents, including activities surrounding document requests. See eDiscovery code set for technical aspects of document production.
LT440 Document Review and Analysis Review and analysis of inbound and outbound documents, and all related activities.
LT450 Protective Orders, Motions to Compel and Extended Discovery Disputes Developing, responding to, and arguing all motions that arise out of the discovery process. Includes the protective order process and meet and confer tasks.
LT460 Depositions - Taking All work pertaining to taking depositions.
Proposed subtasks for this area include:
- Deposition of Named Plaintiff(s)
- Depositions (Other Fact Witnesses)
- Depositions (30(b)(6) Witnesses)
- Preparation
- Attendance
LT470 Depositions - Defending All work pertaining to defending depositions.
Proposed subtasks for this area include:
- Deposition of Named Plaintiff(s)
- Depositions (Other Fact Witnesses)
- Depositions (30(b)(6) Witnesses)
- Preparation
- Attendance
LT500 Motion for Summary Judgment
LT510 Summary Judgment Motions and Briefing All work associated with briefing in support or in opposition to a summary judgment motion. Includes preparation for and attendance at hearing.
LT520 Assemble Evidence to Support Summary Judgment Compile and present evidence to support summary judgment.
LT530 Assemble Evidence to Oppose Summary Judgment Compile and present evidence to oppose summary judgment.
LT600 Experts
LT610 Retain Experts Evaluation and retention of experts and consultants.
LT620 Depositions and Discovery of Retained Experts All work concerning expert depositions and discovery except the preparation of reports.
Subtasks for this category could include:
- Adverse Experts
- Supporting Experts
LT630 Reports of Retained Experts Identifying and interviewing experts and consultants and developing expert reports. Includes any motion practice relating to expert reports.
Subtasks for this category could include:
- Adverse Experts
- Supporting Experts
LT700 Trial
LT710 Trial Theme Development and Other Prep Time spent in preparing for and supporting a trial, including developing overall trial strategy, preparing opening and closing arguments, establishing an off-site support office, identifying documents for use at trial, preparing demonstrative materials, etc.
Subtasks for this category could include:
- Mock Trial
- Jury Consultants
LT720 Trial Motions, Submissions and Hearings Developing, responding to and arguing written motions during preparation for trial and trial, such as motions in limine and motions to strike proposed evidence. Also includes developing other written pre-trial and trial filings, such as jury instructions, witness lists, proposed findings of fact and conclusions of law, and trial briefs.
Subtasks for this category could include:
- Motions In Limine
- Voir Dire
- Jury Instructions
- Proposed Findings of Fact / Trial Briefs
- Witness List
- Exhibit Lists
- Trial Exhibits and Trial Presentation Materials
LT730 Witness Preparation and Outlines Preparing for examination and cross-examination of expert and non-expert witnesses.
LT740 Trial Attendance Appearing at trial, at hearings and at court-mandated conferences, including the pre-trial conferences to prepare for trial.
LT750 In-Trial Strategy This is intended to include daily preparation required for appearance at trial.
LT800 Post-Trial
LT810 Post-Trial Motions (JNOV) and Submissions Developing, responding to and arguing all post-verdict matters in the trial court, such as motions for new trial or j.n.o.v., for stay pending appeal, bills of costs, and requests for attorney's fees.
LT820 Enforcement of Judgment All work performed in enforcing and collecting judgments and asserting or addressing defenses thereto.
LT900 Appeal
LT910 Appellate Motions and Submissions This is intended to include notice of appeal and preparation of the record.
LT920 Appellate Briefs Preparing and reviewing appellate briefs.
LT930 Appellate Arguments Preparing for and arguing an appeal before a reviewing body.