PAPER: Fulton County Daily Report DATE: 08/22/95 SECTION:TECHNOLOGY HEADLINE:Casing Litigation-Support Software TECHNOLOGY BY BARRY D. BAYER AND BENJAMIN H. COHEN Barry D. Bayer and Benjamin H. Cohen write from their offices in Homewood, Ill., and Chicago, respectively. They can be reached at Law Office Technology Review, P.O. Box 2577, Homewood, IL 60430, or via Lexis Counsel Connect. Provided by American Lawyer News Service. We've read a lot about litigation support technology, but everyone seems to have a different idea of what litigation support is. The phrase has been applied to calendar programs, programs that create lists of documents, software that creates and displays photograph equivalents and reconstructive motion pictures, document imaging systems, cost-recovery systems, and a host of other candidates. And to some lesser or greater extent, each of these support functions is integral to litigation. Rather than adopt anyone else's specific definitions, we thought we would provide an overview of the products available to assist litigation efforts. We'll mention specific products not as endorsements, but simply as examples of the product category being discussed. We divide "litigation support" products into two major categories: systems that help keep track of the people and events involved in a case, and systems that aid the collection, organization, and understanding of the facts and law of the case, that help develop trial strategies, and that litigators can use in preparing for trial. In the first category, we have calendar and docketing programs and so-called case management systems, which record everything you could possibly wish to know about what is happening with each case in the office. A case management system is a highly structured data base that stores information about the case. The classic program is Chesapeake Software's PINS, specially designed for plaintiffs personal injury attorneys. Back to Basics Such a program starts with basic information about the client, the court, the judge, opposing party and counsel, witnesses, insurance adjusters and responsible office personnel. This information can be reviewed on a case-by- case basis or, as a byproduct, on a category-by-category basis. For example, if you wish to know which adjuster is involved with the case, simply pull up the case file. If you wish to know what other active cases involve that same adjuster or how the firm has done with that adjuster on closed cases, a few keystrokes should display a report of all cases in which the firm dealt with that adjuster. Thus, the case management system not only assists with individual cases, but also helps manage the firm's entire litigation practice. Along the same lines, the case management system should store notes on the results of telephone conversations and settlement discussions. There should also be a place to record costs advanced and money received associated with the case, although we would hope that, these days, such matters could be integrated with the firm's general accounting system. The program could, at the same time, be used to collect time-charge data for eventual billing. Once again, at least some level of integration with the firm's general time-and- billing system would be hoped for. Amicus Attorney performs many of these functions, although the current version, to be updated soon, cannot handle multiple users on a local area network. A good case management system includes a calendar/docketing program that keeps track of every event that has occurred or is scheduled on each case in the office. The date on which the file is opened and the statute of limitations date are likely the first two entries, but other important dates, including scheduled depositions and court appearances, due dates for pleadings and memorandums, closing dates for discovery, and the date of trial, are included as well. Entries can be made either to a case docket or to an overall calendar, but because of the versatility of the data base program, calendar information can be retrieved either generally or for a specific case. Thus, an attorney working on a specific case can be interested in the information about that case, while someone responsible for ensuring that all of tomorrow's routine "court calls" are handled efficiently can look at all such matters on a given day and assign staff so that each location is covered. A better case management system includes rule-based docket entry so that the entry of only one of a series of related events automatically triggers the others. Therefore, if the receipt of a complaint requires filing of an answer 30 days later, the notation that a complaint has been received automatically triggers a reminder as to when the answer is due. Since such rules vary so widely by jurisdiction and by firm practice, the system should make it easy for each firm to set up its own rule sets to accommodate one jurisdiction's rocket docket or a second jurisdiction's plodding schedule. We recently reviewed the heavily promoted Abacus Law, which, despite the hype, is an excellent program running under MS- DOS. Integration Now The best case management system does not have a separate calendar data base, but instead integrates with the firmwide calendar system so that the individual schedule of each lawyer, and even each conference room, can be considered as events are set. Each litigation event will automatically appear on the calendar of each attorney involved in the specific matter. We must admit that although we know of some systems that are close, such a "best" system may not yet exist in a mass- marketed program. We wouldn't be surprised to see such a system hit the stores soon. Finally, a case-management system might be able to store or at least link to formal pleadings and memorandums. With this capability, a lawyer could, at his desk in the office, in court, or at home, have complete control of virtually all information about the case, making an extensive paper file little more than a place to archive a case. You don't have to buy a specialized case management program to get the job done. If you've purchased one of the "suites" produced by Microsoft, Novell (formerly WordPerfect), or Lotus Development, you already own Access, Paradox, or Approach. A good programmer using any of these packages or one of the tried-and-true dBase clones, could develop an application program to do whatever the commercially available case management programs can do. We do not recommend the procedure for most firms, however, as the $500 or $5,000 that a commercial program might cost would be small change compared with the cost of programming and debugging a major application. As many of the case management packages store information in one of the standard data base formats, it might make sense to hire a programmer to write a routine to deal with the information in some way not provided by the purchased case management package. Cases must be managed, but they also must be prepared and tried, and deposition testimony must be reviewed and analyzed. Court reporters may furnish deposition testimony on disk for use with CatLinks or Discovery, while such full- text indexing products as Folio Views, ZyIndex or dtSearch can be used to build a searchable index. Such programs not only should index, but also should permit the user to insert his own notes into the record. Document production must be numbered and listed, and these days should probably be scanned and converted to text using OCR (optical character recognition) technology to form a searchable full-text data base in addition to the key words associated with the scanned documents. There are many scanners and OCR packages on the market, but Hewlett Packard scanners and OCR software by Calera or Xerox's Kurzweil are commonly used. Preparing a Notebook Putting the deposition testimony and the document discovery together, it should be easy to find all of the information in the case referring or relating to Witness X or Issue Y. Even with the ability to keep all of this information online, some lawyers prefer to work with a physical notebook for each witness. Robins Analytic's Ready for Trial! gathers depositions, documents, pleadings and other matters as they relate to each witness, and prints out a notebook, complete with divider tabs. Litigation support can also include outline, idea-generator, or cluster programs-Inspiration by Inspiration Software Inc. is a good example-that allow the lawyer or litigation team to display and organize known facts and organize them around legal theories. Some of these programs try to replicate group brainstorming that could be done with pen and paper, or on a large bulletin board. The concept, of course, is to toss what we know into the system, without analysis, and then determine whether patterns not previously relevant emerge. Another product type we should mention is the decision tree/risk analysis programs like Tree Age Software's DATA or Applied Decision Analysis' DPL. These programs are not yet in the user-friendly stage, but this type of analysis seems rather powerful and could certainly help build a suitable case strategy. The user sets up various points in a litigation where important decisions are to be made, assigns probabilities to the possible results from each decision point, and thereupon evaluates the expected value of the outcome of the litigation. When this expected value is compared with likely cost, it should be possible to make some early estimate of the most profitable approach to the matter. Outcome estimates in the personal injury field, of course, can be determined by analyzing electronic verdict and settlement data bases for a best estimate of the value of the case. Finally, a good electronic spreadsheet program such as Lotus' 1-2-3 or Excel can be vital in valuing everything from a structured settlement to a spouse's pension rights. Of course, we've skipped right by a plethora of software and hardware that any litigator should consider in appropriate circumstances-systems that create charts and other demonstrative evidence; hardware that displays exhibits to the jury; programs that build tables of authorities in briefs and others that can check citations online; outline programs; research archive programs; software and hardware that produce instant transcripts online in the courtroom; and programs that keep track of airline, meal and hotel charges for those out-of-town trials. And we have no doubt that someday soon the members of a jury will be asked to don virtual-reality helmets and experience a vivid recreation of what the victims of some horrific mass tragedy must have felt in the minutes prior to death. (If a picture is worth a thousand words, actually being there must be worth more than a few pictures.) But while a VR accident recreation may be some order of magnitude more effective than a photograph, it is important to recognize that almost none of the product types mentioned in this article do things that litigators did not do before computers. These products may work faster, more efficiently, with less lawyer and paralegal effort, and sometimes more effectively, but the litigator's traditional tasks of finding out what happened, and telling judge and jury why justice demands a verdict in favor of her client, still remain. *