# NOZBE TEMPLATE STRUCTURE: "Law Firm: Civil & Commercial Litigation (US)"


Scope: Civil / Commercial Litigation (State & Federal Courts), Trial & Appellate Level.


## PROJECT STRUCTURE

Legend: **[M]** Lead Attorney · **[A]** Paralegal / Legal Assistant · **[P]** Associate / Junior Attorney · ⏱ Task with deadline · 🔁 Recurring · ☑ Checklist in comments

### SECTION 0 · CASE COVER SHEET (Pinned Task, No Date)

1 task "CASE COVER SHEET" [M], in the comments:
- Client: details, contact, corporate authorized signatory
- Opposing Party and Trial Counsel (Firm & Lead Attorney)
- Jurisdiction / Court (e.g., SDNY, Chancery Court), Case / Docket Number, Presiding Judge
- Claims / Causes of Action, Damages Sought (Amount in Controversy)
- Fee Structure (Hourly / Contingency Fee / Hybrid / Retainer Amount)
- Link to Executed Engagement Letter & Power of Attorney / Representation Agreement
- Communication Protocol (Preferred channel & reporting cadence)

### SECTION 1 · CLIENT ONBOARDING & CONFLICTS

- ⏱ Conflict check clearing [M] ☑ opposing parties / affiliates / key witnesses / prior representation
- ⏱ Initial client interview & merit evaluation [M] – in comments: liability risks, damages, litigation budget
- ⏱ Engagement Letter signed by Client [A] ☑ scope / fee structure / trust retainer deposit / billing terms
- ⏱ Retainer deposit received into IOLTA / Trust Account [A] – **blocks start of work**
- ⏱ Document hold & collection [A] ☑ litigation hold notice issued to client
- ⏱ Verify Statute of Limitations (SOL) expiration [M] – critical date in task title
- ⏱ Issue retainer receipt & initial invoice [A]

### SECTION 2 · PLEADINGS STAGE (Complaint / Answer)
Option A – We represent Plaintiff:
- ⏱ Draft Complaint & Summons [P] → ⏱ Review Complaint [M]
- ⏱ Pay Court Filing Fees / E-File Complaint [A] – attach receipt in comments
- ⏱ Serve Summons & Complaint on Defendant (Process Server / Sheriff) [A] + file Proof of Service
- ⏱ Monitor Answer deadline (21 days Federal / 30 days State) [A]

Option B – We represent Defendant:
- ⏱ **Answer / Responsive Pleading – Statutory Deadline [DATE]** [P]; internal deadline −3 days
- ⏱ Evaluate Motion to Dismiss (Rule 12(b)) [M]
- ⏱ File Answer with Affirmative Defenses & Counterclaims [P] → [M]
- ⏱ Serve filing on Opposing Counsel via ECF / Email [A]
- ⏱ Issue billing invoice for Pleadings stage [A]

### SECTION 3 · DISCOVERY STAGE (Pre-Trial Evidence Exchange)
- ⏱ Form 26(f) Conference / Joint Discovery Plan [M]
- ⏱ Initial Disclosures served (Rule 26(a)(1)) [P]
- ⏱ Serve Interrogatories, Requests for Production (RFPs), and Admissions (RFAs) [P]
- ⏱ Respond & Object to Opposing Party's Discovery Requests [P] → [M]
- ⏱ Third-Party Subpoenas issued [A]
- ⏱ Depositions schedule [DATE/TIME] [M] ☑ court reporter booked / witness prep / exhibit binders
- ⏱ Expert Witness Disclosures & Expert Depositions [M]
- ⏱ Motion for Summary Judgment (MSJ) – draft & file [P] → [M]

### SECTION 4 · TRIAL PREPARATION & TRIAL
- 🔁 ECF / Court Docket Review – daily (business days) [A] – log all Orders and Docket entries
- ⏱ Pre-Trial Conference [DATE] [M] ☑ Joint Pre-Trial Order / Motions in Limine
- ⏱ Prepare Trial Notebook & Exhibit Lists [A]
- ⏱ Subpoena Trial Witnesses [A]
- ⏱ **Trial / Jury Selection (Voir Dire) [DATE, Time, Courtroom]** [M]
- ⏱ Daily Trial debrief note + Client status update [M]
- ⏱ Post-Trial Motions (JMOL / Motion for New Trial) [P] → [M]
- ⏱ Issue billing invoice for Trial stage [A]

### SECTION 5 · JUDGMENT & APPEALS
- ⏱ Entry of Final Judgment [DATE] [M] – copy in comments
- ⏱ **Notice of Appeal Filing Deadline (30 days from Judgment) [DATE]** [P]; internal deadline −5 days
- ⏱ Client decision: file Appeal or Settlement? [M] – recorded in comments
- ⏱ File Notice of Appeal & Post Supersedeas/Appeal Bond [A]
- ⏱ Appellant / Appellee Briefing schedule [P] → [M]
- ⏱ Oral Argument [DATE] [M]
- ⏱ Appellate Court Decision / Remand Order [M]
- ⏱ Issue billing invoice for Appellate stage [A]

### SECTION 6 · ENFORCEMENT & COLLECTION
- ⏱ Registration of Foreign Judgment (if out-of-state assets) [A]
- ⏱ Asset Discovery / Citation to Discover Assets [P]
- ⏱ Wage Garnishment / Bank Levy Motions [P]
- ⏱ Monitor Collections 🔁 monthly [A]
- ⏱ Issue billing invoice [A]

### SECTION 7 · CASE CLOSURE & FILE RETENTION
- ⏱ Final accounting & reconciliation of Trust Account (IOLTA) [A]
- ⏱ Final invoice issued / Unused retainer refunded [A]
- ⏱ Closing Letter sent to Client + Return of original documents [A]
- ⏱ Close Litigation Hold & Archive Case File – destruction date in title (per state bar Rules) [A]
- ⏱ Request review / testimonial / referral [M] (optional)
- Close project.


ITEMS TO VERIFY FOR US COMPLIANCE:

1. **State vs. Federal Rules:** Deadlines differ significantly between Federal Rules (FRCP) and State Courts (e.g., California CCP, New York CPLR). Verify local court rules (*Local Local Rules*).
2. **IOLTA / Trust Account Rules:** US State Bars strictly regulate trust accounts for retainers.
3. **Discovery Focus:** Unlike in civil law systems (like Poland/France), US civil litigation is dominated by Discovery and Depositions, which take up 60–80% of litigation time.