Module 10 · Chapter 10

Hearing and Trial Preparation

Trial and hearing preparation is the compressed, high-stakes, highly visible work of family law practice. The paralegal who prepares the trial notebook, the exhibits, and the witness logistics is not a support function — they are a primary contributor to whether the case is presented well.

The trial notebook

A complete trial notebook for a family law hearing includes pleadings, the court order setting the hearing, witness list and outlines, exhibit list with copies pre-tabbed, legal authority the attorney may want to reference, financial data in the form the court will want it, and a running chronology of the relevant facts. The paralegal builds the notebook so the attorney can find anything in it in under thirty seconds.

Trial Notebook Completeness · 25 XP

For a temporary custody and support hearing, which of these belong in the trial notebook?

Select all that apply.

Exhibit preparation discipline

Exhibits come pre-tabbed, pre-Bates-numbered where appropriate, with three identical sets (one for the court, one for opposing counsel, one for the witness on the stand). Each exhibit matches the exhibit list. Each exhibit has a clean copy (not a marked-up working copy). The attorney should never have to flip through documents looking for something during a hearing.

Witness logistics

Witness prep is the attorney's work. Witness logistics — confirming arrival time, having contact information current, arranging childcare or travel if needed, managing the waiting area so witnesses don't hear each other's testimony — is the paralegal's work. A witness who doesn't show, or shows up confused, is often a logistics failure, not a preparation failure.

Day-Of Scenario · 15 XP

The morning of a custody hearing, your key witness calls to say her car broke down. What do you do in the next ten minutes?

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