Baltimore Litigation Attorneys - Maryland's Civil Litigation Timeline: From Filing a Lawsuit to Trial and Appeal

WHAT COURT?	COMPLAINT	SERVICE OF PROCESS	PRELIMINARY MOTIONS	ANSWER THE COMPLAINT	DISCOVERY	DUTY TO SUPPLEMENT	PRE-TRIAL MOTIONS	TRIAL	POST-TRIAL MOTIONS	APPEAL
• Power to Hear Type of Case • Power over Defendant? • Venue: The right county? .	• Concise Factual Allegations Supporting Each Element of Claim • Requesting Damages or Other Relief • Liberal Amendment Policy Prior to 15 Days of Trial • Need Leave to Amend Within 15 Days of Trial [amendment stricken if prejudice to opposing party]	• Process = [1] summons + [2] complaint • Methods of Service: 1. Personally Serving Defendant; 2. Certified Mail; 3. Serving Corporation's Resident Agent/President/ Secretary/Treasurer .	• For More Definite Statement • To Strike Certain Allegations • To Dismiss * waivable defenses * non-waivable defenses	• Specific v. General Denials • Defenses: * Non-Waivable Defenses omitted from Preliminary Motion * Negative Defenses * Affirmative Defenses	• Within Scope? * not privileged * relevant to case * reasonably calculated to lead to discovery of evidence • Work Product Immunity • Protective Orders • Discovery Tools: * depositions * interrogatories * document requests * admission requests	• All discovery responses, except depositions • Sanctions for Failing to Provide Discovery?	• Default Judgment • Involuntary Dismissals for Lack of Prosecution • Voluntary Dismissals • Summary Judgment	• Voir Dire: Picking Jurors • Opening Statements • Presentation of Evidence: * Plaintiff v. Defendant ⇨ P's Case-in-Chief D's Motion for Judgment? ⇨ D's Case-in-Chief P's Motion for Judgment? Either side must move for judgment at close of all evidence to preserve post-trial motion for JNOV! • Jury Instructions • Closing Arguments • Verdict	• 10-Day Motions * for Judgment Notwithstanding the Verdict [JNOV] * for New Trial * to Alter/Amend a Judgment • 30-Day Revisory Power	• Final Judgment? • Timely Notice of Appeal?

WHAT COURT?

COMPLAINT

SERVICE OF PROCESS

PRELIMINARY MOTIONS

ANSWER THE COMPLAINT

DISCOVERY

DUTY TO SUPPLEMENT

PRE-TRIAL MOTIONS

TRIAL

POST-TRIAL MOTIONS

APPEAL

• Power to Hear Type of Case

• Power over Defendant?

• Venue: The right county?

• Concise Factual Allegations Supporting Each Element of Claim

• Requesting Damages or Other Relief

• Liberal Amendment Policy Prior to 15 Days of Trial

• Need Leave to Amend Within 15 Days of Trial [amendment stricken if prejudice to opposing party]

• Process =
[1] summons +
[2] complaint

• Methods of Service:

1. Personally Serving Defendant;
2. Certified Mail;
3. Serving Corporation's Resident Agent/President/ Secretary/Treasurer

.

• For More Definite Statement

• To Strike Certain Allegations

• To Dismiss

* waivable defenses

* non-waivable defenses

• Specific v. General Denials

• Defenses:

* Non-Waivable Defenses omitted from Preliminary Motion
* Negative Defenses
* Affirmative Defenses

• Within Scope?
* not privileged
* relevant to case
* reasonably calculated to lead to discovery of evidence

• Work Product Immunity

• Protective Orders

• Discovery Tools:

* depositions
* interrogatories
* document requests
* admission requests

• All discovery responses, except depositions

• Sanctions for Failing to Provide Discovery?

• Default Judgment

• Involuntary Dismissals for Lack of Prosecution

• Voluntary Dismissals

• Summary Judgment

• Voir Dire: Picking Jurors

• Opening Statements

• Presentation of Evidence:

* Plaintiff v. Defendant

⇨ P's Case-in-Chief
D's Motion for Judgment?

⇨ D's Case-in-Chief
P's Motion for Judgment?

Either side must move for judgment at close of all evidence to preserve post-trial motion for JNOV!

• Jury Instructions

• Closing Arguments

• Verdict

• 10-Day Motions

* for Judgment Notwithstanding the Verdict [JNOV]

* for New Trial

* to Alter/Amend a Judgment

• 30-Day Revisory Power

• Final Judgment?

• Timely Notice of Appeal?