Syncora Connect/Playbooks/Civil Litigation

Systematic Civil Litigation Playbook

A phase-by-phase roadmap both clients and attorneys can use to align on scope, deadlines, and deliverables across the life of a civil case.

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  1. 1. Intake & Case Assessment

    1–2 weeks · 0/4 done

    Goal: Confirm a viable claim, conflicts, jurisdiction, and engagement scope.

    Your tasks (client)

    Deliverables

    • Engagement letter
    • Litigation hold notice
    • Case theory memo

    Red flags

    • Statute about to expire
    • Undisclosed prior counsel
    • Spoliation risk
  2. 2. Pre-Suit Investigation & Demand

    2–6 weeks · 0/3 done

    Goal: Develop facts, preserve evidence, and attempt resolution before filing.

    Your tasks (client)

    Deliverables

    • Demand letter
    • Evidence preservation log
    • Draft complaint

    Red flags

    • Opposing party going dark
    • Asset dissipation
    • Adverse witness departing
  3. 3. Pleadings & Initial Motions

    1–3 months · 0/3 done

    Goal: Frame the legal claims and survive early dispositive challenges.

    Your tasks (client)

    Deliverables

    • Filed complaint
    • Proof of service
    • Answer or Rule 12 motion

    Red flags

    • Missed service window
    • Forum non conveniens risk
    • Counterclaims filed
  4. 4. Discovery

    3–9 months · 0/3 done

    Goal: Obtain the evidence needed to prove the case and pin down the other side.

    Your tasks (client)

    Deliverables

    • Document productions
    • Deposition transcripts
    • Expert reports

    Red flags

    • Missing custodians
    • Privilege challenges
    • Discovery sanctions
  5. 5. Dispositive Motions & Mediation

    2–4 months · 0/3 done

    Goal: Narrow the case via summary judgment and explore resolution.

    Your tasks (client)

    Deliverables

    • MSJ briefing
    • Mediation statement
    • Settlement term sheet (if reached)

    Red flags

    • Bad-faith negotiation
    • New evidence at the eleventh hour
  6. 6. Trial Preparation

    1–3 months · 0/3 done

    Goal: Build the trial story, exhibits, and witness order for the factfinder.

    Your tasks (client)

    Deliverables

    • Pretrial order
    • Exhibit list
    • Jury instructions
    • Trial binder

    Red flags

    • Witness unavailability
    • Late exhibit objections
  7. 7. Trial

    1–4 weeks · 0/2 done

    Goal: Present the case clearly and preserve the record for appeal.

    Your tasks (client)

    Deliverables

    • Verdict / judgment
    • Trial transcript
    • Preserved record

    Red flags

    • Juror misconduct
    • Evidentiary surprises
  8. 8. Post-Trial, Collection & Appeal

    3–18 months · 0/2 done

    Goal: Convert the judgment into recovery — or perfect an appeal.

    Your tasks (client)

    Deliverables

    • Post-trial motions
    • Notice of appeal
    • Satisfaction of judgment

    Red flags

    • Missed appeal deadline
    • Judgment-proof defendant
This playbook is a general framework — not legal advice. Use it with a licensed attorney to align expectations, deadlines, and deliverables across each phase. Want a custom playbook for family law, criminal defense, or M&A? Bring it into a connection →Need the proof-level view? Open the litigation matrix →