Chronology

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A chronology means the list of sentences put in order of time, from the oldest to the most recent. In litigation, the list is a list of

facts or allegations⁠

The purpose of a chronology is to provide a written account of everything meaningful that happened in the litigation. After a chronology is created, the attorney can easily navigate what happened, what is legally important and what facts are the most helpful and which facts are potentially harmful. A chronology that is completed early in the case, drives discovery and deposition preparation, and dramatically reduces the time, effort and stress of discovery and deposition preparation.

This article explores the features and characteristics of a chronology and helps the prospective client help the attorney create the chronology.

Every sentence in a chronology starts with a time-stamp

In the context of a chronology, a time stamp is a group of words, a phrase, that indicates when the facts or allegations occurred.

This time stamp varies, as follows: (1) a statement of fact before a certain date; (2) a statement of fact as of a certain date; (3) a statement of fact, between dates; (4) a statement of fact, after a certain date.

Combing the four, we can craft a very basic chronology, which, if effective, tells an entire story

Example of the types of time stamp statements, in a complete, simple chronology

Before November 2, 2025, nobody knew which team would win Major League Baseball’s World Series.

On March 27, 2025, the 2025-Major League Baseball season started and every team had the same win-loss record, 0-0.

Between March 28, 2025 and the end of the 2025-regular season on September 28, 2025, the Los Angeles Dodgers led the National League West division.

On November 2, 2025, the the Los Angeles Dodgers defeated the Toronto Blue Jays to win game 7 of the 2025-World Series, and become the 2025 Major League World Series Champions.

After November 2, 2025, the the Los Angeles Dodgers were the 2025 Major League World Series Champions.

This chronology was designed to be extremely simple and easy to follow to make a [prospective] client understand. If you do not understand the concepts, I suggest you review the

don’t understand article⁠

Chronologies use allegations as facts, but avoid characterizations, opinions, and legal conclusions

It is very important for the chronology to use facts or allegations, but avoid characterizations, opinions, emotions and legal conclusions.

A fact or allegation is something that a person can perceive, meaning see, hear, touch, smell.

An emotion is the subjective and internal reaction that a person has to a fact. For example for some people will be happy that the Dodgers won the 2025 World Series. Others will be unhappy. These are emotions. Emotions should be avoided in chronologies.

An opinion is a statement that qualifies a fact or an allegation. For example, some people will thing is is good that the Dodgers won the 2025 World Series; others will think that it is bad. These are opinions. Opinions should be avoided in chronologies.

Characterizations are statements that seem like facts, but are much more like an emotion, opinion or legal conclusion. For example, some people say that their landlord abused them. However, in that sentence it is impossible to know what abused means. An allegation that may be abuse is a statement such as the landlord entered into the apartment 12 times over one weekend, but appeared to have no reason, because no notice was given, no defective condition existed, and no repair was attempted. Characterizations should be avoided in chronologies.

A legal conclusion is a conclusion of law. A conclusion of law is a statement that makes or implies a legal result. For example, the assertion, John breached the contract, implies that John failed to perform according to the contract, without excuse and must pay for damages.

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