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I. Preliminary Analysis of Financial Issues to Assist with Determining Viability of Causes of Action
A. Delineation of financial issues to be included in complaint
B. Assistance with response to complaints that contain allegations involving financial issues and economic damages
II. Development of Discovery Program to Address Financial and Accounting Issues
A. Identification of documents to be requested for financial and accounting analysis. Assistance with correct terminology for accounting, and other business records.
1. Document demands
2. Interrogatories
3. On-site document discovery of opposing parties
a. Selection of documents to be copied
b. Supervision of reproduction
4. Document indexing and management
B. Preparation of deposition outlines and questions for opposing parties' experts and percipient witnesses on financial and accounting issues.
C. Attendance at depositions to assist counsel with follow-up questions on financial and accounting issues and interpretation of answers (particularly those replete with accounting jargon).
III. Analysis of Documents and Development of Findings, Conclusions and Opinions
A. In consultation with counsel, determine scope of assignments
B. Review and analyze relevant documents
C. Perform tasks as directed by counsel
D. Meet periodically with counsel to discuss findings
E. Quantify and calculate economic damages
F. Formulation of conclusions and opinions
G. Evaluation of opposing parties' damage claims and financial and accounting experts' opinions
IV. Testimony and Exhibits
A. Pre-trial
1. Affidavits
2. Declaration
3. Depositions
4. Trial notebooks
B. At trial
1. Expert testimony
a. Direct testimony
b. Rebuttal of opposing parties' experts
2. Trial exhibits
