Case Filing Checklist

Record client name, related entities, opposing parties, key witnesses, and any non-party companies tied to the dispute. Conflicts under Rule 1.7 / 1.9 turn on the names you collect here — missed adverse parties are the most common source of late-stage disqualification.

Search Clio, NetDocuments, or whichever conflicts database the firm uses against current clients, former clients, adverse parties, and witnesses. Document the search parameters and results — bar auditors expect a written record, not just a clean screen.

Walk the managing partner through the hit and document the decision: decline, accept with informed-written-consent waiver under Rule 1.7(b), or build a Rule 1.10 ethical screen. Do not open the matter until this is resolved in writing.

Collect government ID for individuals or formation documents and a corporate resolution for entities. Confirm the signer has authority to retain counsel and to file suit in the entity's name.

Use the litigation engagement template — set scope (named claims and forum), fee structure (hourly, contingency, or hybrid), retainer amount, evergreen replenishment trigger, billing cycle, and the fee-dispute clause. Tight scope language is the defense against scope-creep grievances later.

Route through DocuSign or Clio's e-signature with the responsible attorney as the firm signer. Save the countersigned PDF to the matter folder in the DMS once both parties sign.

Per Rule 1.15, retainers go to the IOLTA trust account and post to the client's individual ledger. Do not draw against the retainer or pay filing fees from trust until funds clear — typically 7-10 banking days for a check, same-day for wire. Disbursing on uncleared funds is the fastest path to a Rule 1.15 violation.

Create the matter in the PMS, assign matter number and responsible attorney, and calendar the statute of limitations with redundancy: docket entry, responsible attorney's calendar, and a paper or DMS file note. Add 90-day, 30-day, and 7-day SOL ticklers.

Confirm the elements of each claim, the controlling jurisdiction, statute of limitations, and any pre-suit notice or administrative-exhaustion requirements (e.g., EEOC right-to-sue, pre-suit demand, certificate of merit). Westlaw or Lexis citations get saved to the matter's research folder.

Issue a written document-request list to the client covering contracts, correspondence, financial records, and any text or social media. Load received documents to NetDocuments or the matter folder with consistent Bates-ready naming.

Produce a dated chronology with cites to source documents — this becomes the spine of the complaint, deposition outlines, and trial prep. Flag gaps where third-party subpoenas or FOIA requests will be needed.

Send a written hold identifying custodians, date range, and ESI sources (email, Slack, Teams, mobile, cloud drives). Save the signed acknowledgment to the matter file — this is the document that defends against spoliation motions later.

Plead each cause of action with elements tracked to the chronology. Include jurisdictional and venue allegations, jury demand if applicable, and any verification or certificate-of-merit required by the forum.

Check the division's local rules and the assigned judge's standing order: font, line spacing, page or word limits, exhibit numbering, signature block, and any required courtesy copy. Local-rule defects are the most common reason a clerk rejects an e-filing.

Federal: JS-44 cover sheet plus AO-440 summons for each defendant. State: forum-specific cover sheet (e.g., CM-010 in California, UCS-840 in New York). Match defendant names exactly to the caption — mismatches force re-issuance.

Responsible partner reads the final draft, signs off on Rule 11 basis, and approves filing. Capture approval in writing — email or PMS comment — so the audit trail shows attorney supervision under Rule 5.1.

Submit through PACER/CM-ECF, NYSCEF, Texas eFile, or the relevant portal. Build in a 4-hour buffer before any midnight cutoff — filings stamped 12:01 a.m. count as the next day in most courts. Save the filing receipt and stamped complaint to the matter folder.

Read the rejection notice carefully — most rejections are caption, signature, or fee-payment issues, not substance. Refile same-day if SOL is close; the original filing date is not preserved on rejection.

Transmit the issued summons and stamped complaint to a licensed process server. Confirm service address against the most recent secretary-of-state filing for entity defendants — stale registered-agent addresses cause failed service.

Federal Rule 4(m) gives 90 days to serve and file proof; many state courts are tighter. File the affidavit of service promptly — late proof can trigger a show-cause order even when actual service was timely.

Docket the defendant's answer date (21 days federal, varies by state), Rule 26(f) conference, initial disclosures, and any case-management conference. Use CalendarRules or Court Alert for jurisdiction-specific computations and add 7-day, 3-day, and 1-day reminders on each.

Send the case number, stamped complaint, and a plain-language summary of what happens next — when the defendant must answer, what discovery looks like, and the realistic timeline to first hearing.

Walk the associate and paralegal through the chronology, the named claims, immediate discovery priorities, and Rule 26(f) conference prep. Assign first substantive task with due date in the PMS.