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Standard Paragraphs Stored for Easy Retrieval Typical Material Which should be Stored Electronically Data which should be Indexed and Stored for Easy Retrieval Typical Material Which
Should be Stored Electronically Payroll/accounting data Client identification for determining possible conflicts of interest as to representation of a client Key relevant documents Facts of similar cases wherein you might find a common denominator, such as a common supplier or distributor Summaries and pages from trial transcripts Former decisions of your local trial judges coded by subject matter of the cases that were heard before them Witness testimony Discovery matters Research, whether substantive law with supporting cases or other. Subject matter Cross indexing of facts The legal issues Summary of facts Other affirmative defenses Other bases for motion to dismiss (demurrer) Diplomatic immunity Unclean hands Doctrine of res judicata Rescission Another action pending Partial payment of obligation Exemption from prosecution lack of capacity to sue Laches Imputed negligence Statute of frauds Statute of limitations Discharge of bankruptcy Wrong party Wrong jurisdiction A counter-breach of plaintiff Duress Comparative negligence Assumption of risk Estoppel Accord and satisfaction Failure of consideration Failure to state a claim from which relief can be granted Failure to state a cause of action Deposition methodology Deposition digest transcript of deposition summary of deposition entire testimony of deposition