Most young lawyers don’t lose cases because they don’t know the law.

They lose cases because they don’t run the case.

They don’t drive it. They don’t manage it. They don’t control it. They let it control them. And then one day, they look up and realize discovery closed last week, the client is asking why nobody has taken the key depo, the adjuster wants a status report “by the end of the day,” and the partner is asking the question that makes your stomach drop:

“Where are we on this file?”

If you want to run a case from beginning to end, here’s the mindset shift:

You are not assigned to the file. The file is assigned to you.

Own it.

And yes, it’s a lot, which is why we’re going to reduce it to basics, blocking and tackling, and turn chaos into a workflow.

Because everything we do can be reduced to workflows, checklists, and decision trees, and if you build the right ones, you stop reacting and start running the show.

Here’s the playbook from intake to closing letter.

1. Start With The End

Before you do anything, do the thing nobody does:

Start with the end.

Not a trial. Not summary judgment. The end.

What is the best realistic outcome for your client? What is the worst? What does “winning” look like in this jurisdiction, with this judge, with this plaintiff, with this venue?

What’s the hill we’re trying to take?

If you don’t know the hill, you’ll be sprinting in random directions until you collapse.

So: read the complaint. Then read it again. Then read it like you’re the plaintiff’s lawyer trying to beat you. Identify:

The legal elements that matter (not all the elements, the elements)
The facts you can prove today
The facts you need to prove later
The facts you can’t ever prove (which is where your leverage lives)

Then create your case theme in one sentence. Not a paragraph. One sentence.

If you can’t say it in one sentence, you don’t own the case yet.

2. The First 72 Hours: Triage, Don’t Tour

New file comes in. Everyone panics. People start doing busywork. They “tour the file.”

Don’t tour the file.

Triage it.

Like the ER. Who is bleeding? What is time-sensitive? What is about to explode?

Start with three lists:

Deadlines (answer date, removal, responsive pleading, preservation, early disclosures)
Evidence (what exists, what can disappear, what you need to lock down now)
People (who matter, who know what, who need to be interviewed before memories rot)

Calendar is king.

Set the answer date. Set every downstream deadline you can reasonably predict. Set reminders in the calendar that prompt you to act early, not on the due date. The due date is a tombstone.

And call your client early. Not to recite the complaint. To establish trust.

Clients don’t want a lawyer who sounds smart. They want a lawyer who sounds like they have a plan.

So give them the plan. High level. Calm. Confident.

3. Early Case Evaluation: Numbers And Reality

One of the most difficult jobs for trial lawyers is placing a dollar value on a case and making decisions based on that valuation.

You can’t run a case if you don’t know what it’s worth.

So early on, do a disciplined evaluation:

Liability exposure
Damages exposure
Venue risk
Plaintiff counsel risk
Your client’s risk tolerance
Insurance/indemnity landscape
Evidence quality

And here’s a line that should live in your head:

A different jury may agree with them.

That sentence keeps you humble and strategic. It reminds you that litigation isn’t math.

It’s human beings.

So build a range. Not one number. A range. Then revisit it as facts develop.

Update the number, or the number will update you.

4. Pleadings: Don’t Just Answer, Position

Pleadings are not paperwork. They’re positioning.

Yes, you answer the complaint. But you’re also laying tracks for the train you want to run six, 12, 18 months from now.

Ask yourself:

What defenses actually matter?
What affirmative defenses do we need to preserve?
Are there jurisdictional issues?
Arbitration? Venue? Immunity? Statutes?
Third-party practice? Crossclaims?

And if you’re going to file a motion to dismiss or motion for more definite statement, don’t do it because it’s what lawyers do.

Do it because it moves the case.

Motion practice without strategy is just exercise.

5. Discovery: Build The Map Before You Start Walking

Most associates approach discovery like a buffet.

A little of this. A little of that. No plan.

Start with the map.

Here’s the workflow:

A. Written discovery

Your first set should be aligned with your theme and valuation drivers. Not “standard interrogatories” because someone used them in 2009.

Think:

What facts do I need to prove?
What facts do I need to disprove?
What facts does the plaintiff need that I can force them to commit to early?

B. Document strategy

Documents are where cases are won quietly.

Set up a system so you can find things fast later. Because “I know it’s in there somewhere” is not a strategy. It’s a cry for help.

If you can’t find it in 30 seconds, it doesn’t exist.

C. The discovery plan

Write it down. One page.

Key issues
Key witnesses
Key documents
Key experts
Sequence (what must happen first)

That one page becomes your compass when the file starts trying to drag you into the weeds.

6. Depositions: You’re A Human Lie Detector

Depositions are not theatre. They are intel gathering.

In deposition, you are a human lie detector. Set a baseline early with easy questions and note changes in tone, cadence, pauses, and body language when you get pointed.

That’s not just a cool line. It’s a method.

Start with a baseline. Then apply pressure.

And keep this in mind: a deposition is often less about the transcript and more about the story you’re building for trial. You’re collecting:

Admissions
Inconsistencies
Themes
Future impeachment
“This witness is not credible” moments (subtle, not melodramatic)

Also: use the phone. The actual phone.

You know that thing we hold in our hands all day? It makes phone calls. Call opposing counsel. Call the court reporter. Call the witness coordinator. It works wonders.

A lot of “litigation problems” are actually “nobody talked to anyone” problems.

7. Experts: Don’t Wait Until You’re Desperate

Experts are not a checkbox. They’re your translator to the jury.

Identify early:

Do you need them?
On what issues?
When do you need to retain?
What documents must they review?

Then budget it and communicate it to the client before it comes as a surprise invoice.

Here’s the rule:

No surprises. No excuses.

8. Mediation And Settlement: Give Them A Way To Save Face

Settlement is not a weakness. It’s a strategy.

Prepare like it’s a trial — because if you don’t, you’ll negotiate from fear.

And remember the truth that too many young lawyers learn too late:

If you corner someone, they don’t surrender; they bite.

So give the other side a path. A narrative they can tell their client. A way to save face. That’s how deals get done.

Also, don’t walk into mediation without updating your evaluation. See above. Update the number, or the number will update you.

9. Pretrial: Make It Boring

The best trial lawyers make trial prep boring. Not because the trial is boring. Because they’ve built systems that remove chaos.

Pretrial is:

Motions in limine
Exhibit lists
Witness lists
Depo designations
Jury instructions/verdict forms
Theme refinement
Demonstratives
Trial binders (physical or digital, but organized)

Win the file before you walk into the courtroom.

Trial is often the final act. The verdict is the applause (or the booing). The work was done months earlier.

10. Trial: Mission Mindset

I once knew a trial lawyer who described himself as a mercenary dropped into the jungle: fulfill the mission, seize the hill, blow up the target, get out in one piece.

That’s not bad framing.

At trial, you need blinders. You need purpose. You need to be calm.

And you need to remember: jurors don’t care how hard you worked. They care whether your story makes sense.

So tell a story they can repeat at dinner.

11. Post-Trial And Closing: Finish Like A Pro

A case is not over when the verdict comes in.

Post-trial is:

Judgment entry
Costs
Post-trial motions
Preservation for appeal
Client debrief
File closing letter
Lessons learned memo to yourself (yes, really)

Do a debrief even if you “won.” Especially if you won.

Because the goal isn’t to win one case, the goal is to become a lawyer who wins consistently.

And if you’re in the middle of it right now, overwhelmed, behind, staring at a deadline like it’s a guillotine, here’s what you do:

Start with one thing.

One call. One email. One outline. One calendar entry. One task completed.

Then do the next thing.

Keep going.

You got this.

Frank Ramos is a partner at Goldberg Segalla in Miami, where he practices commercial litigation, products, and catastrophic personal injury. You can follow him on LinkedIn, where he has about 80,000 followers.

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