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          Dot your “i’s” and cross your “t’s” – –

        In law, we mean that literally and figuratively.  No matter what’s going on, paralegals have to take every measure to make sure they are working productively and efficiently.  More often than not, you’re doing this under high pressure and tight time constraints.  One of the most effective ways to make sure everything gets done is to use a checklist.

        Keep in mind that each state operates differently, so the requirements and the order in which things are done will vary.  This list is simply serves as a foundation.                     

1. If an attorney’s certification is required, did the attorney sign the certifications of everything that needs to be served? 

2. If there are other parties, experts, etc., do you have sets for all parties involved? 

3. Do you have the Affidavits or Admissions of Service of papers if you have to serve before filing? 

4. Did you make your copies for your office file and for your client? 

            Note: If your other copies of the document you are filing can be put together when you return to the office, I highly recommend that you make at least one full set (with exhibits) to leave at the office to use as a model.  Attorneys and legal assistants tend to think that since they have all the paperwork available to them at the office, they will remember the order in which everything was placed and they will remember everything that was included, etc. in the copy that went to the court or that was served.  I can assure you that you may not recall if, e.g., you included that fax cover sheet as part of the exhibit or which pages of X were left out or redacted or whether “that element” was the change your boss made at the last minute.     

            I implore you: Do at least one full set BEFORE YOU LEAVE.  It’s a nightmare when you cannot properly reconstruct motion papers, and the paralegal may ultimately be held responsible.  

5. Are all filing applications accurately completed and ready to go?  Get the attorney’s signature, if needed? 

6. Is there a cover letter that is supposed to be included in the outgoing package? Is your adversary supposed to get a copy? 

7. Is there a Memorandum of Law and do you have it ready to go? 

8. Is the client’s signature properly notarized and does the jurat or acknowledgment read properly? 

9. Does the “Wherefore clause” or other closing read properly?  Make sure it bears the proper parties’ names, especially if you used another document as model and did a “save as.”

 10. Are your citations correct? Did someone fill in all the blanks?

 11. Have all last minute changes (typographical, calculations, etc.) been made on all copies of the papers?

 12. Has reorganization of exhibits been made or done on all copies of papers?

 13. If reorganization of exhibits was done, are those changes reflected in the Affidavit or Affirmation that references them? 

 14. Did someone carefully check caption?

 15. Did someone carefully check to see if document has the proper index, docket or file number? Make sure the index no. is for this case, and not for a related case or the case of the client whose computer file you may have copied this document from when you decided to use it a model?

 16. Remember that element that the court clerk told you you needed the last time you filed motion papers.  Are you repeating that mistake this time or did you correct it?

 17. Do you have an envelope ready for Judge and Adversary?  Does your envelope or label have everyone’s current address?  Did the client give you specific instruction about mailing a package to him or her and are you following them? Make sure if your cover letter says it’s being sent by Federal Express that you are not accidently sending it by regular mail.

18.  Do you have all the checks for fees? (Sometimes there is more than one)?

        An eye for detail is an advantage that many paralegals have, but even the most competent and detail-oriented paralegal can forget when under enormous pressure.  Checklists help take some of the pressure off and can facilitate the process.



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