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					                                          LITIGATION CHART

  Elements of the          Sources of        Informal Fact        Formal               Problematic
      Claim                  Proof           Investigation       Discovery                Areas
Duty to take          Official            None               Depositions,          Duty owed to
reasonable            representative of                      Interrogatories,      protect another
precautions to        International                          Requests to Produce   from third party’s
prevent foreseeable   Department Store.                      Documents to          criminal acts?
harm from dangers                         None               determine what
that the premises     Sam Security                           Sam Security knew     Was Timothy a
owner knew about,                         None               about Timothy and     foreseeable plaintiff?
should have known     Sandy Security                         the Young Hoods.
about, or created.                        None               Also need to          Was harm to
                      Clarence Confused                      determine if Sam      Timothy from Young
                                          Interview          created the danger    Hoods foreseeable?
                      Timothy Cowling                        by expelling
                                          Interview          Timothy from the
                      Sandra Cowling                         store.

Breach of duty        Sam Security        None               Deposition            Need to know if Sam
                                                                                   escorted the youths
                      Sandy Security      None               Deposition            outside the store.
                                                                                   What did Sam say
                      Sarah Sawitall      Interview                                out there? Did
                                                                                   Timothy try to say
                      Timothy Cowling     Interview                                anything? What
                                                                                   happened just
                      Sandra Cowling      Interview                                before Sam took the
                                                                                   youths to office?
                      Clarence Confused   None               Deposition
Causation   Timothy Cowling      Interview                                     Argument that the
                                                                               Hoods caused
            Sandra Cowling       Interview                                     accident by pushing
                                                                               Timothy off of the
            Sarah Sawitall       Interview                                     curb.

            Clarence Confused    None                   Deposition

            Police Officers      Interview and Police   Subpoena if
                                 Report                 necessary
Damages     Will Treatum, M.D.   Interview and          Deposition and         Marijuana use and
                                 Medical Records        subpoena for           lying to teacher.
                                                        records if necessary
            I.M. Nutt, M.D.      Interview and                                 Previous injury to
                                 Medical Records                               arm; any residual
                                                                               damage from that?
            Timothy Cowling      Interview              None

            Sandra Cowling       Interview and          None
                                 records before and
                                 after photos           Deposition and
                                                        subpoena for
            Any other treating   Interviews and         records if necessary
            doctors              records

            Police officers      Interviews and

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Description: sample chart or table as to preparing case & updating with eye toward litigation which forces atty or staff to fill in theor(ies), facts, evidencetestimony, analysis and weak areas.