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Use Of Matrix Appendices In Complex Civil Litigation In Lieu Of Attaching Large Document Files To Yo

Many attorneys file complex civil complaints both in federal and state courts and append hundreds of pages of documents to the complaint to buttress complaint averments, especially in cases where there there is a heightened specificity requirement.

If you are filing a civil complaint with hundreds or even thousands of pages of supporting documents that are repetitive in nature, consider this approach instead. You may find that it is just as effective, saves time redacting privacy information, and winds up easier to follow by the Court.

Make a Matrix for the repetitive documents and attach the Matrix to the complaint instead of bulk source documents. Here is an approach that has been known to work:

1. Take your source documents and consolidate them into piles by complaint claim.

2. Make a copy of your source documents so that you can keep the original documents clean.

3. Number the copy of the source documents with a Bates Stamp or other numbering device.

4. Make a Matrix or Matrices using pertinent data taken off of the source documents and referencing the Bates Number of the document for each individual cell of the Matrix, per claim

in your complaint. For instance, you may have 100 examples for claim 1 of your complaint as consolidated, or you can use the Matrix to set forth 100 separate but related claims in the complaint. You can use initials instead of names present on the source documents that would normally need to be redacted ad nauseam.

5. PDF the Bates Numbered documents and copy them onto a peripheral device for service of process with the complaint. Flash drives work well.

6. Write your complaint referencing the Matrices and line items in the Matrices, as opposed to source documents that would normally be appended to the complaint for service of process.

7. Write your complaint using one source document redacted as an example for the Court, per category of claim in your complaint, so the Court gets an idea of the bulk repetitive documents provided to defendant upon service of the complaint.

8. Serve the complaint together with the Matrices and all of the source documents referenced in the Matrices as Bates Stamped and referenced in the complaint. You can serve a flash drive with the documents copied.

This approach seems to work fairly well, keeps you organized from the start, and produces a very tidy and concise complex civil complaint filing with the Court. You can make a Matrix in Word, Wordperfect, Excel and from many other data massaging programs.

Give it a try, you may like it. The Matrix approach to complex civil litigation has definite advantages

over appending hundreds or even thousands of pages to a civil complaint to meet specificity requirements.

If you would like an example of how a complex civil litigation complaint Appendix-Matrix could look in real life, please email Joe at and one example will be forwarded to you.

This article is for informational and educational purposes only and should not be construed as constituting legal advice. In fact it is not legal advice and was written by a non-attorney. You should consult with your attorney to determine the best course of action to take on your case.

Copyright 2018 All Right Reserved, by Joseph J. Pappacoda, JD, Senior Litigation Paralegal, GhostWriter Paralegal, Chartered, Fort Lauderdale, Florida

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