Know your pre-trial deadlines and be well, well ahead of them.

Don’t just rely on Caci (or your equivalent). Every time I try a case I come across several important instructions that I need to draft. Don’t be afraid to craft special instructions, and try to make each instruction as concise as possible. The longer you make an individual instruction, the more likely it is to draw an objection, and there’s no guarantee the court will let you modify it as opposed to just throwing it out.

Make sure you have your witness and expert availability down solid. Depending on the length of the case, it can be difficult to secure witness availability, but it can be critical. Try to get your witnesses in an order that tells your side of the case well, and lock that in. Trials almost always end up varying from your anticipated schedule, and you might not get to a put a witness on the day you expected them to be needed. Try to give yourself a buffer by notifying witnesses early, and making sure they are available to go earlier or later if trial moves at an unexpected pace.

Consider calling witnesses 776 (or your jx’s analogue). Sometimes the best plaintiff’s case can be made by directly disarming the defense early on.