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Evidence Preparation Checklist

Complete pre-trial checklist for organizing exhibits, coordinating with witnesses, and meeting court deadlines. Never miss a critical step.

Trial Preparation Timeline

4 Weeks Before Trial

  • Inventory all potential exhibits from discovery
  • Review depositions for marked exhibits
  • Compile expert reports and demonstratives
  • Identify missing documents—subpoena if needed

3 Weeks Before Trial

  • Plan authentication witness for each exhibit
  • Identify self-authenticating documents
  • Review opposing party's exhibit list
  • Prepare motions in limine for questionable exhibits

2 Weeks Before Trial

  • Assign exhibit numbers/letters
  • Apply exhibit stamps to all documents
  • Create master exhibit list
  • Organize by witness or chronologically

10-30 Days Before (per rules)

  • Exchange exhibit lists with opposing counsel
  • File exhibit list with court if required
  • Serve formal pretrial disclosures
  • Object to opposing exhibits if needed

1 Week Before Trial

  • Prepare trial binders with TOC
  • Create witness-specific exhibit tabs
  • Make copies for court, counsel, witness
  • Test electronic presentation systems

Day Before Trial

  • Final review of all exhibits
  • Verify courtroom technology
  • Pack backup copies
  • Organize impeachment materials

Printable Evidence Checklist

Types of Exhibits to Prepare

Documentary Evidence

  • Contracts and agreements
  • Correspondence (emails, letters)
  • Business records
  • Financial documents
  • Medical records
  • Government records

Demonstrative Aids

  • Charts and timelines
  • Diagrams and maps
  • Summaries (FRE 1006)
  • Animations or simulations
  • Enlargements for jury

Photographs & Media

  • Scene photographs
  • Surveillance video
  • Audio recordings
  • Social media posts
  • Website screenshots

Expert Materials

  • Expert reports
  • Supporting data and studies
  • Visual aids for testimony
  • Demonstrative models

How Many Copies?

1 set

Court Clerk

Original for the record

1 set

Witness Stand

For witness examination

1 set

Opposing Counsel

Courtesy copy

1-2 sets

Your Table

Working copy

For jury trials, prepare additional courtesy copies for deliberation (check local rules).

Common Evidence Preparation Mistakes

Waiting too long to start—exhibit prep takes weeks, not days
Missing exhibit exchange deadline—exhibits can be excluded
No authentication plan—scrambling at trial to find witnesses
Disorganized binders—unable to find exhibits quickly
No backup copies—exhibits lost during trial chaos
Untested technology—projector failures mid-presentation
Forgetting impeachment materials—missing cross-examination opportunities
Not reviewing opposing exhibits—surprised by new evidence

Time Estimates for Exhibit Prep

Simple Case

10-25 exhibits

4-8 hours total

Medium Case

25-75 exhibits

12-24 hours total

Complex Case

75+ exhibits

40+ hours total

ExhibitPrep reduces stamping time by 80%—50 exhibits in 15 minutes vs. 2-3 hours manually.

Ready to Prepare Your Exhibits?

Stamp exhibits, create trial binders, and generate tables of contents—all in one session.

Evidence Preparation FAQ

When should I start preparing trial exhibits?

Start 4-6 weeks before trial. Begin with inventorying all potential exhibits and planning authentication. Apply exhibit stamps 2-3 weeks before trial to allow time for review and changes. Exchange exhibit lists per court deadlines (typically 10-30 days before trial). Prepare trial binders the week before. Rushing exhibit preparation leads to missing documents and authentication failures.

How many copies of exhibits do I need for trial?

Prepare at least 4 sets: (1) original for the court clerk, (2) copy for the witness stand, (3) copy for opposing counsel, (4) your working copy. For jury trials, consider courtesy copies for jurors during deliberation (check local rules). Some courts require all exhibits pre-filed electronically. Always bring backup copies—exhibits get lost during busy trials.

How should I organize exhibits for trial?

Common organization methods: (1) Chronological—best for timeline-driven cases, (2) By witness—group exhibits each witness will authenticate, (3) By topic/issue—for complex cases with multiple claims, (4) In order of introduction—if you know your presentation order. Use tabbed dividers and slipsheets to separate categories. Include a table of contents for quick reference during trial.

What is a trial binder and what goes in it?

A trial binder is an organized collection of exhibits and reference materials for use during trial. Contents typically include: (1) exhibit list and table of contents, (2) all stamped exhibits with tabs, (3) witness outlines with exhibit references, (4) key deposition excerpts, (5) important pleadings and motions in limine, (6) jury instructions, (7) contact information. Some attorneys create separate binders for witnesses and exhibits.

When do I need to exchange exhibit lists with opposing counsel?

Check your pretrial order and local rules. Federal court requires disclosure 30 days before trial under FRCP 26(a)(3). State deadlines vary—California requires 30 days (CRC 3.1302), some courts require 14-21 days. Many judges set specific deadlines in pretrial orders. Missing the deadline can result in exhibit exclusion. File any motions in limine regarding exhibits at this time.

How do I handle voluminous exhibits?

For large document sets: (1) Consider summary exhibits under FRE 1006 to condense voluminous records, (2) Use sub-numbering (1.1, 1.2, 1.3) for related documents, (3) Create exhibit binders by category with slipsheet dividers, (4) Prepare a digital exhibit database for quick search, (5) File a motion regarding exhibit handling if needed. Alert the court early about voluminous exhibits—some have special procedures.

What exhibits should I bring but may not offer?

Prepare more exhibits than you plan to use. Bring: (1) impeachment documents for cross-examination, (2) rebuttal exhibits responding to anticipated defense, (3) backup exhibits if primary ones are excluded, (4) documents referenced in depositions you may read, (5) prior statements of witnesses. Having these ready prevents scrambling mid-trial. Mark them for identification but only offer if needed.

How do I prepare electronic exhibits for trial?

For electronic presentation: (1) Test all technology before trial—courtroom screens, your laptop, connection cables, (2) Convert exhibits to PDF for consistent display, (3) Create a digital exhibit folder matching your physical binder, (4) Have USB backup of all files, (5) Prepare video/audio exhibits in court-compatible formats, (6) Coordinate with court staff on equipment. Always have paper backup—technology fails.

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