Tell a story.....that's
what seasoned trial attorneys do in explaining the facts of their case
to a jury. And second only to the theme of the case, the story line, chronology
or sequence of events is the foundation for a clear understanding of the
anatomy of the lawsuit.
In medical malpractice
cases the sequence of events is often the key to the liability. A timeline
will allow the jury to clearly visualize the presence or in many cases
the absence of key players in attending to a patient's needs in a timely
manner. Timelines can illustrate more graphically than words the span
of time showing the concentration of treatment, or conversely, the lack
of treatment over long periods.
In product cases, timelines
are used to illustrate the process by which a machine or device came to
be developed, or in some cases, how a machine came to be used in a particular
situation.
Timelines in commercial
cases trace the sequence of events of business transactions, and through
color and design, graphically allow the fact-finder to sort out what would
otherwise be a most confusing jumble of information.
Another use for timelines
in many cases is that they provide an "outline" of the case for the attorney
to follow during opening statements. One of the purposes of the opening
is to organize the case for the jury,and timelines allow the trial lawyer
to have visual support that he can "lean on" and be assured the jury will
absorb the essence of the case.
In creating a timeline,
the trial attorney is urged to first list the key timepoints in the case.
We then suggest he or she actually stand up next to an easel with a blank
piece of paper or foamboard. Start to practice your opening, and as you
find yourself starting to turn towards your "exhibit," make a note of
the issue or fact, then keep going. As you continue to do this, you will
find your timeline developing, becoming an exhibit that will serve you
well at trial. From this information, we will design the timeline to assure
that it communicates what YOU want the judge or jury to understand about
the issues and facts of your case. For many timelines, you will want the
client to assist in the preparation so that the exhibit can be used as
a testimony aid during this phase of the trial.

Timeline exhibits are generally mounted on 1/2" foamboard and laminated
and framed for protection. Panels can be hinged or bolted together for
ease of transportation and assembly in court. (Be sure to measure the
courtroom, if you can, before the trial. We once made a 30 ft. exhibit
on a case that didn't fit into the courtroom. Fortunately, the key witness
changed her testimony before trial, allowing us to delete one 5 ft. segment!)