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pre-trial checklist

The Appellate or Appeals Checklist: What An Appellate Attorney Needs To Begin An Appeal

Ciyou & Dixon, P.C. has a significant practice area addressing civil and criminal appeals taken to the Indiana Court of Appeals and sought to be transferred to the Indiana Supreme Court. Typically, these cases come by referral from other attorneys or because a litigant wants to change counsel for a fresh appellate perspective.

We find that in meeting with most appellate clients, there are a number of checklist items that a client may bring to keep costs down (i.e., to keep the lawyer from spending time collecting something the client may easily obtain) and make for meaningful appellate consults and representation.

They are listed below:

  • The final order (general judgment, special findings or jury verdict; the abstract of judgment and sentencing order in criminal cases).
  • A copy of any Motion to Correct Error and order on it.
  • Permission from trial counsel to consult or a termination letter by attorney or client.
  • Contact information for trial counsel or a list of what he or she thinks are the viable appellate issue(s).
  • A copy of the chronological case summary (a list of what has been filed) and any transcripts that have been obtained for any reason reflecting hearings on this final judgment.
  • A copy of the pleadings and motions file, if available.
  • A three to five page summary of the who, what, when, where, why and how of the case and any non-legal dynamics, such as emotional issues.
  • A copy of any stay that has been filed in the trial court (to stop the order from being enforced).
  • A copy of the certification of any interlocutory order or order sought to be certified or order of the Court of Appeals accepting the interlocutory order.

With these documents, it provides for an efficient consultation and rapid determination of controlling dates. Appeals, unlike most other parts of trial court practice, has fairly rigid rules and time lines that if not followed, waive the right to appeal.

As appellate attorneys, we hope you find this checklist useful in helping your counsel of choice prepare for an efficient and cost-effective appeal. Ciyou & Dixon, P.C. advocates handle interlocutory appeals in criminal and civil cases for a wide array of clients located through the State, ranging from those taken on behalf of local government to domestic litigants to criminals appealing jury verdicts and sentencing. Perhaps we may be your counsel.


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Dixon & Moseley, P.C., is a law firm located in Indianapolis, Indiana. We serve clients in six core practice areas: family lawappellate practicefirearms lawgeneral practicepersonal injury and criminal law.

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