While it goes without saying that any litigation matter, no matter how large or small, needs to be set up properly to move a case along appropriately and represent the client diligently, it is even more so when dealing with complex litigation matters.
Almost from the start, complex litigations tend to take on a life of their own. While it is possible to "go back" and "fix" some of the below mentioned points in smaller litigations, the sheer volume of documents (correspondence, court filings and discovery, collections and productions) and information (deadlines, due dates, service and distribution lists) makes it very difficult if not impossible to retrace ones steps and attempt to create any missing pieces while the litigation continues to move along. The risk of a never-ending avalanche will haunt you.
Here are some tips to put in place at the beginning in order to avoid such a fate:
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