====== Trial preparation checklist ======
===== Or, the general conduct of an action =====

  - Memorandum of proof/proof chart.
  - Pleadings review--**A**--ensure that all necessary parties have been joined and properly named; and--**B**--consider any amendments required to pleadings, including whether the relief claimed is adequate.
  - Discovery matters--**A**--ensure that transcripts from examinations for discovery have been obtained;--**B**--ensure completion of undertakings from examinations for discovery;--**C**--consider whether any information given by your client on discovery should be corrected or updated; and--**D**--compile a list of discovery extracts to be read in at trial.
  - Non-expert witnesses--**A**--develop a list of witnesses to be called at trial;--**B**--interview or re-interview witnesses and determine availability for trial;--**C**--obtain summonses and serve on all witnesses, together with appropriate conduct money;--**D**--determine whether a notice to call the adverse party as a witness ought to be served; and--**E**--determine appropriate procedure to compel attendance of out-of-province witnesses.
  - Legal research--**A**--update legal research on the issues; and--**B**--prepare briefs of authorities intended to be relied upon at trial.
  - Experts--**A**--are any expert witnesses required?--**B**--serve expert reports in accordance with the Rules of the relevant jurisdiction.
  - Pre-trial notices--**A**--consider issuing requests to admit documents or facts;--**B**--ensure that responses have been made to any requests to admit which have been received; and--**C**--serve notices required under the relevant provincial Evidence Act in regard to proof of business records.
  - Trial brief--**A**--prepare brief of documents to be used at trial;--**B**--prepare counsel’s trial brief(s); and--**C**--prepare briefs of authorities.
  - Counsel preparation--**A**--opening statement;--**B**--examinations-in-chief;--**C**--cross-examinations;--**D**--argument on anticipated evidentiary and other procedural issues; and--**E**--closing argument.