# Matter Management Checklists

## Litigation Milestones

### Pre-Filing Phase

- [ ] Initial client interview completed
- [ ] Conflict check cleared
- [ ] Engagement letter signed
- [ ] Retainer received
- [ ] Matter opened in billing system
- [ ] Litigation hold issued (if applicable)
- [ ] Document collection initiated
- [ ] Statute of limitations verified
- [ ] Venue analysis completed
- [ ] Claims and defenses identified
- [ ] Preliminary damages assessment
- [ ] Budget prepared and approved
- [ ] Insurance coverage reviewed
- [ ] Pre-suit demand/notice sent (if required)

### Pleadings Phase

- [ ] Complaint drafted/reviewed
- [ ] Filing fee arranged
- [ ] Complaint filed
- [ ] Summons issued
- [ ] Service of process effected
- [ ] Proof of service filed
- [ ] Answer deadline calendared
- [ ] Answer/response drafted
- [ ] Affirmative defenses identified
- [ ] Counterclaims/crossclaims assessed
- [ ] Answer filed
- [ ] Rule 26(f) conference scheduled

### Discovery Phase

- [ ] Scheduling order entered
- [ ] Discovery plan prepared
- [ ] Initial disclosures served
- [ ] Document preservation confirmed
- [ ] E-discovery protocol agreed
- [ ] Interrogatories drafted and served
- [ ] Document requests drafted and served
- [ ] Requests for admission served
- [ ] Discovery responses prepared
- [ ] Privilege log created
- [ ] Depositions scheduled
- [ ] Deposition outlines prepared
- [ ] Depositions completed
- [ ] Expert witnesses retained
- [ ] Expert reports exchanged
- [ ] Expert depositions completed
- [ ] Discovery disputes resolved
- [ ] Discovery cutoff met

### Dispositive Motions Phase

- [ ] Summary judgment deadline noted
- [ ] Statement of undisputed facts drafted
- [ ] Supporting evidence compiled
- [ ] Motion brief drafted
- [ ] Opposition deadline calendared
- [ ] Reply deadline calendared
- [ ] Oral argument scheduled (if applicable)
- [ ] Order received and analyzed

### Trial Preparation Phase

- [ ] Trial date confirmed
- [ ] Pretrial order requirements reviewed
- [ ] Witness list prepared
- [ ] Exhibit list prepared
- [ ] Exhibit binders assembled
- [ ] Motions in limine drafted
- [ ] Jury instructions proposed
- [ ] Verdict form proposed
- [ ] Trial brief prepared
- [ ] Opening statement outlined
- [ ] Witness examinations prepared
- [ ] Closing argument prepared
- [ ] Trial technology tested
- [ ] Witness subpoenas served

### Trial Phase

- [ ] Daily trial binders ready
- [ ] Witness availability confirmed
- [ ] Exhibits admitted/rejected tracked
- [ ] Objections preserved
- [ ] Daily transcripts ordered (if needed)
- [ ] Jury notes addressed
- [ ] Verdict received
- [ ] Post-trial motions deadline noted

## Corporate Transaction Milestones

### Letter of Intent Phase

- [ ] NDA executed
- [ ] Term sheet reviewed
- [ ] LOI negotiated and signed
- [ ] Exclusivity period noted
- [ ] Due diligence timeline established
- [ ] Transaction team assembled
- [ ] Data room access arranged

### Due Diligence Phase

- [ ] Due diligence request list sent
- [ ] Data room documents reviewed
- [ ] Corporate records reviewed
- [ ] Material contracts identified
- [ ] Employment matters reviewed
- [ ] IP portfolio assessed
- [ ] Real property reviewed
- [ ] Environmental issues identified
- [ ] Litigation review completed
- [ ] Regulatory compliance assessed
- [ ] Tax structure analyzed
- [ ] Financial statements reviewed
- [ ] Due diligence memo prepared
- [ ] Risk allocation issues identified

### Documentation Phase

- [ ] Purchase agreement drafted
- [ ] Schedules and exhibits prepared
- [ ] Disclosure schedules reviewed
- [ ] Representations and warranties negotiated
- [ ] Indemnification provisions finalized
- [ ] Closing conditions defined
- [ ] Third-party consents identified
- [ ] Regulatory filings required identified
- [ ] Ancillary documents drafted
- [ ] Financing documents coordinated

### Pre-Closing Phase

- [ ] HSR filing made (if required)
- [ ] Regulatory approvals obtained
- [ ] Third-party consents obtained
- [ ] FIRPTA compliance addressed
- [ ] Closing checklist prepared
- [ ] Funds flow memo prepared
- [ ] Officer certificates prepared
- [ ] Bring-down verification scheduled
- [ ] Title/lien searches completed
- [ ] Insurance requirements satisfied

### Closing Phase

- [ ] Signature pages collected
- [ ] Closing documents executed
- [ ] Funds transferred and confirmed
- [ ] Stock/asset transfers completed
- [ ] UCC filings made
- [ ] Recording completed
- [ ] Closing binder assembled
- [ ] Post-closing items identified

## Employment Matter Milestones

### Charge/Complaint Response

- [ ] Charge/complaint received and logged
- [ ] Response deadline calendared
- [ ] Relevant personnel identified
- [ ] Document hold implemented
- [ ] Initial investigation conducted
- [ ] Witness interviews completed
- [ ] Documents collected and reviewed
- [ ] Position statement drafted
- [ ] Supporting documents compiled
- [ ] Position statement filed
- [ ] EEOC determination received

### Internal Investigation

- [ ] Investigation scope defined
- [ ] Investigation team assembled
- [ ] Upjohn warnings prepared
- [ ] Document preservation notice issued
- [ ] Relevant documents collected
- [ ] Witness list prepared
- [ ] Interview protocol established
- [ ] Witness interviews conducted
- [ ] Interview memos prepared
- [ ] Documents analyzed
- [ ] Investigation report drafted
- [ ] Recommendations developed
- [ ] Remedial actions implemented
- [ ] Follow-up monitoring established

## Intellectual Property Milestones

### Patent Prosecution

- [ ] Invention disclosure received
- [ ] Prior art search completed
- [ ] Patentability opinion provided
- [ ] Provisional application prepared
- [ ] Provisional application filed
- [ ] 12-month deadline calendared
- [ ] Non-provisional prepared
- [ ] Non-provisional filed
- [ ] Office actions responded to
- [ ] Examiner interviews conducted
- [ ] Notice of allowance received
- [ ] Issue fee paid
- [ ] Patent issued
- [ ] Maintenance fees calendared

### Trademark Registration

- [ ] Clearance search ordered
- [ ] Search report analyzed
- [ ] Opinion letter provided
- [ ] Application prepared
- [ ] Application filed
- [ ] Office actions responded to
- [ ] Publication for opposition
- [ ] Opposition period monitored
- [ ] Registration issued
- [ ] Renewal deadlines calendared
- [ ] Use documentation maintained

## Real Estate Transaction Milestones

### Acquisition

- [ ] LOI/PSA negotiated
- [ ] Title commitment ordered
- [ ] Survey ordered
- [ ] Environmental reports ordered
- [ ] Zoning compliance verified
- [ ] Lease review completed
- [ ] Estoppels requested
- [ ] SNDAs requested
- [ ] Title objections submitted
- [ ] Title curative obtained
- [ ] Financing commitment received
- [ ] Closing documents prepared
- [ ] Closing funds confirmed
- [ ] Recording completed
- [ ] Title policy issued

## Milestone Tracking Best Practices

1. **Weekly status reviews** - Check all open matters
2. **Automated reminders** - 30/14/7 day warnings
3. **Responsibility assignment** - Clear ownership per task
4. **Client reporting** - Regular milestone updates
5. **Matter close-out** - Checklist for completed matters
6. **Template customization** - Adapt to specific matters
7. **Dependency mapping** - Note sequential requirements