Lawyers work most efficiently and effectively when they have a detailed history of a dispute from a client. Lawyers frequently call them "case chronologies". A good case chronology helps a lawyer:

• understand who is involved in the dispute;
• know when key events happened;
• learn what exactly happened; and,
• identify key documents that a lawyer should review.

Here is a process of producing the best, most detailed chronology you can for your lawyer.

1. Blast out the first draft

Take 20 or 30 minutes and just write out everything you can about the dispute. Don't worry about whether it is relevant or not. Use whatever writing technique works for you. Some people draw diagrams and then write out their story. Some outline. Some create bullet points. Some people talk into a recording device or speech recognition program. It doesn't really matter. It's more important to just get the whole story out as you can best remember it.

2. MAKE A CHRONOLOGY

Now, go through your written story and organize it by date. Your story can most likely be broken up into a series of events that led to the dispute. That series of events can be listed in date order. Here are some basic pointers:

1. One fact per entry. If there are multiple facts on one day, then enter separate entries for the same day.
2. Write facts. Not opinions. The best kinds of facts are the ones that start with something like "I saw", "I heard", "I read", "I wrote", "I participated" - note the focus on personal observations. You may be recalling events perceived by someone else. In those situations, make clear that you are relating descriptions of events from another person's perspective.
3. Identify key documents associated with each fact.
4. Review the whole chronology and make sure the chronology answers the following questions:
   1. Who are all of the persons who are involved in the dispute?
   2. What are the relationships between each of the persons?
   3. Where did this dispute take place?
   4. When did the dispute and the events in the dispute take place?
   5. How did the dispute arise? What are the points in dispute?

3. REVIEW EACH POINT

For each fact, a reader should be able to answer the following questions either because the answer is clear when reading in the context of the whole chronology or because it is stated in the fact entry:

• Who is involved in the fact?
• When did the fact take place?
• Where did the fact take place?
• What took place?

4. PROVIDE BASIC DETAILS

As part of the chronology, add a list of key persons, places and contact information for those items. Be sure to include:

• Full legal names wherever possible for all persons.
• Full legal names, to the best extent possible, for all companies involved.
• Full civic addresses for all places named.

1. Blast out the first draft

In business disputes, there are some common elements that should be described fully:

Conversations

Where did the conversation take place? Who was present? When did it take place? How did it take place? (in person, by phone, by teleconference, online chat) Who said what to whom? Was the conversation recorded or a written summary taken?

Correspondence

Who wrote the correspondence (email, letter, note, memo)? When was the correspondence sent? When was it received? To whom was it sent or intended to be sent? Who received it? Where was it addressed? What did it say? Where is a copy?

Formal Instruments/Agreements

Who prepared it? Who signed it? Where was it signed? Who witnessed it? When was it signed?

Payments

What was supposed to be paid? How much was supposed to be paid? From whom was the payment to originate? To whom was the payment supposed to be made? When was the payment supposed to be made? Was form of payment important?

Delivery of goods or services

Exactly what was supposed to be delivered? What was the quantity (even labour hours) was supposed to be delivered? How was quality supposed to be measured and objectively agreed upon? Who was supposed to supply? Who was supposed to receive? When was supply to take place? Where was supply to take place?

6. YOU ARE DONE

This chronology will serve as a great starting point for you or your lawyer to prepare a case, develop legal arguments, review documents, and interview witnesses. It is now a key document - helping you and your lawyer prepare your litigation case efficiently.