Recently we were getting ready for a trial. We had a little over 400 exhibits to account for and that needed to be organized.
Fortunately for me the paralegal that had the case before me started an Excel spreadsheet that contained every exhibit from every deposition. The spreadsheet contained the exbhit number, the date of the document, a brief description of the document and the name of the deponent. This saved us about 900 hours of work during trial prep.
Both parties agreed to keep the original deposition exhibit numbers for any documents that were used in the deposition that were also going to be used at trial. If an exhibit was removed that number was left blank. You can avoid alot of confusion by not renumbering exhibits.
Each party was then given a range of numbers to add any additional exhibits on to the spreadsheet using the same format.
We kept only one set of hard copy exhibits. Each was in a separate file folder, labeled and in numerical order in boxes that were in a central location where we could access the exhibits if necessary.
We then had each exhibit scanned and named by its exhibit number. These scanned exhibits were placed in a folder on computer desktop with a the spreadsheet. We then linked each exhibit on the spreadsheet where the exhibit number was located. So if you were viewing the spreadsheet you would only need to click on the exhibit number and the exhibit would be viewable. We then had the folders downloaded to about 12 flash drives and given to each attorney. Now each attorney had access to the exhibits 24/7. We didn't have to worry about the originals. They were kept safe and sound beauase the attorneys rarely needed to touch them.
OK here were some issues, hey we work in law offices...there's always and issue.
1. Some of the attorneys had problems with the flash drives not reading on their desktops so we simply downloaded the folder with the exhibits and spreadsheet to a new folder on thier desktop. Worked like a charm.
2. We had one attorney that insisted that she have a set of hard copies of each exhibit. I convincingly made the "your killing trees" argument. She agreed to try the flash drive and I agreed that if it didn't work for her I would, against my better judgment have a set of exhibits copied for her. She loved the flash drive!
3. One paralegal needs to be responsible for the exhibits this way if exhibits are added or removed it can be done on their desktop then copied to each flash drive so that all of the flash drives were up to date.
4. If you have confidential documents on the flash drives encrypt the file to need a password to access the documents. Trust me -- an attorney or two will lose their flash drives.
We actually downloaded every possible document we could need for the trial onto our flash drives. It was great having everything at our fingertips and easily accessible. I feel good about not killing any trees and I was thrilled because we had no binders! Not one!
On another topic I think you can see how organizing deposition exhibits from day one will save you a ton of grief, aggravation and time down the road.
