x Michael Ablan Law Firm LLC


If the case does not settle within the time prescribed by the court, then the matter will go to litigation. Most often this is a jury trial. 120 days before the jury trial is scheduled we began preparing a trial notebook. In addition to preparing questions for the jury to determine the qualifications, bias and adaptability to your case, we include a sketch of the opening statement and closing statement, detailed questionnaire concerning each witness whether adverse or not, all of the jury instructions, motion orders, evidentiary objections, exhibits and photographs, deposition transcripts, and most importantly a description of the theme of the case. Here is our preparation check list which we review with you continuously:

Preparation: 120 Days before Trial

  • Review and determine applicability of local rules.
  • Do final review of entire case file and attach scheduling order.
  • Do final detailed review of case pleadings.
  • Develop final discovery plan.
  • Summarize testimony of witnesses.

Preparation: 90 Days before Trial

  • Review and post deadlines from scheduling order.
  • Choose witnesses and order of appearance at trial.
  • Notify witnesses of trial dates.
  • Gather documents and tangible evidence.
  • If medical records are involved, mark calendar to comply with statutory requirements for admissibility at least 40 days before trial.
  • If learned treatises will be used, mark calendar to comply with statutory requirements for admissibility at least 40 days before trial.
  • Select photos, models, and devices to be used at trial.
  • Consider evidentiary problems likely to arise at trial.
  • Create demonstrative exhibits.

Preparation: 60 Days before Trial

  • Explore late settlement negotiations and mediation.
  • Prepare questioning strategies for witnesses.
  • Learn trial judge’s customs and practices if in a new County.
  • Schedule trial days and hours of testimony.
  • Check equipment to be used with demonstrative evidence.
  • Repeat: If medical records are involved, comply with statute at least 40 days before trial.
  • Repeat: If learned treatises will be used, comply statute at least 40 days before trial.

Preparation: 30 Days before Trial

  • Review and comply with the Scheduling Order.
  • Prepare lay witnesses for trial.
  • Prepare expert witnesses for trial.
  • Issue trial subpoenas for witnesses.
  • Study juror questionnaires and prepare for voir dire.
  • Prepare jury instructions and verdict form.
  • Prepare final trial notebook.
  • Prepare for courtroom use of audiovisual equipment.
  • Gather rules and evidence books for trial.
  • Gather office supplies necessary for trial.

Preparation: 10 Days before Trial

Prepare and serve Offer of Settlement to opposing counsel. Our preparation for your case is unparalleled. We can assure you of excellent trial representation. Before the matter is taken to litigation, you will be given an opinion of what the jury will do, and if this opinion fluctuates up or down as a result of negotiations or witness statements or other evidence procured, you will be continuously updated. We handle wrongful death cases in the same fashion.

If you or a loved one have been injured in an accident and if you are looking for an experienced personal injury lawyer to maximize the remedies that you have available to you and to reach the highest possible award for your injuries or if you wish to compromise, negotiate, or effectively deal with either your insurance company or the adverse insurance company we, the Michael Ablan Law Firm can help you. We have been serving injured clients since 1974. With an experienced and aggressive yet honest, trustworthy and friendly legal team consisting of a lawyer with 35 years of experience, specialized paralegals, and a tax accountant, the Michael Ablan Law Firm in La Crosse, WI can help you. We also have offices in La Crescent, Minnesota and Hayward, Wisconsin. Contact us for a free consultation. Our expert legal services are available to you anywhere in the State of Wisconsin including but not limited to the counties of La Crosse, Trempealeau, Monroe, Pierce, Crawford, Vernon, Grant, Sawyer, Jackson or any other county in Wisconsin or in the state of Minnesota, including all counties surrounding La Crescent, MN, such as Houston and Winona and any other county.