1	A Litigation Management Proposal Submitted by Suchocki & Associates, PC One Summit Avenue, Suite 312 Fort Worth, Texas 76102 (817) 338-0088 @copyright
2	Outline Objective The Management Method Litigation Management: Definition Representative Categories: To Be Defined Litigation Management Case Categories Discovery Categories Direct Reporting Advantages for Management
3	Objective To recommend a Management Method that can: Maintain & increase quality of representation. Provide comprehensive visibility to management. Reduce overall litigation costs. Create and maintain a plan for the disposition of each case. Create a feed-back mechanism to provide growth, refinement and/or re-definition.
4	The Management Method The proposed management method is a proven, effective method of managing a large project that provides control, visibility and accountability. It has a built-it mechanism for re-definition, growth, feed back and fine tuning. This is a management tool used by NASA to define, develop and test the space shuttle software. A firm member has personal experience with NASA development of space shuttle software. Our firm has experience in implementing a form of this management method. We previously managed litigation for an elevator company throughout the State of Texas.
5	Litigation Management Definition We propose to apply the management method to Litigation Management. Organize each case into a category, as a function of liability and damages. Define and assign a discovery level for each category. In addition to standard reporting, include a periodic personal briefing to management that will provide: Visibility as to number of cases in each category. Current accounting of attorney fees and costs. Critical reporting of major cases and category changes. Attorney accountability for case development. Discussion of problems, strategy and goals. An ongoing forum to control costs. A basis for an action plan for case disposition.
6	Representative Categories To be Defined Liability 0 to 20% Minimal Risk 20 to 40% Acceptable Risk 40 to 60% Equal Risk 60 to 80% High Risk 80 to 100% Unacceptable Risk Damages Less that 10K D1 10K to 50K D2 50K to 100K D3 100K to 250K D4 250K to 500K D5 500K to 1M D6
7	Litigation Management Case Categories Category One Minimal Risk with D1- D2 Damages Level 1 Discovery Nuisance Settlement or Trial Category Two Minimal Risk with D2-D5 Damages Level 2 Discovery Defense Cost Settlement or Trial Category Three Minimal Risk with D5 or Greater Level 3 Discovery Demand Risk
8	Litigation Management Case Categories Category Four Acceptable Risk with D1-D4 Damages Level 2 Discovery Defense Cost Settlement or Trial Category Five Acceptable Risk with D4 or Greater Level 3 Discovery Demand Risk
9	Litigation Management Case Categories Category Six Equal Risk with D1-D4 Damages Level 2 Discovery Defense Cost Settlement or Trial Category Seven Equal Risk with D4 or Greater Level 3 Discovery Demand Risk
10	Litigation Management Case Categories Category Eight High Risk with D1-D3 Damages Level 4 Discovery Demand Risk Category Nine High Risk with D3 or Greater Damages Level 4 Discovery Mediation
11	Litigation Management Case Categories Category Ten Unacceptable Risk with any Damages Level 4 Discovery Mediation
12	Litigation Management Discovery Categories Level 1 Interrogatories; Production; Admissions; Disclosure Medical, Personnel Records and Photographs Non-Stenographic Deposition of Plaintiff Telephone Interview of Witnesses Level 2 Interrogatories; Production; Admissions; Disclosure Medical, Personnel Records and Photographs Deposition of Plaintiff Interview/Deposition of Witnesses
13	Litigation Management Discovery Categories Level 3 Interrogatories; Production; Admissions; Disclosure Medical, Personnel Records and Photographs Deposition of Plaintiff Mediation Deposition of Critical Witnesses Medical/Liability Expert, as necessary Level 4 Interrogatories; Production; Admissions, Disclosure Medical, Personnel Records and Photographs Deposition of Plaintiff Depositions of Critical Witnesses Liability Consultant Mediation/Settlement
14	Litigation Management Direct Reporting to Management Periodic reporting to management by defense attorneys to include such items as: Comprehensive report of status of all cases in manageable format. Number and category of cases. Red flags, problems & concerns. Cases set for trial. Disposition dates for each case. Summary of ongoing costs and project costs, per case and total. Visibility for significant litigation. Forum for discussion of strategy and options. Forum for discussion of methods to control costs. Overall budget control. Action item list for follow up.
15	Advantages For Management Provides Management the opportunity for direct review and input into defense strategies on a cooperative level. Defense counsel is directly accountable for explaining status, rationale and strategy. Provides visibility into significant cases for both liability/damages and costs. Strengthen the relationship of trust, understanding and loyalty between defense counsel and client. Provides comprehensive visibility into all litigation for a section of Texas. Provides a direct means of controlling overall litigation costs. Develop a working relationship and guideline for cost control Guard against protracted and unnecessary discovery Generate and maintain statistics on average cost per case Provides a goal oriented disposition plan for each case