Say you're in a lawsuit. You have a photo, or video, or some other piece of physical evidence that you think is great. Give it to your lawyer NOW. Do not wait. Even if discovery hasn't been served, you can't wait until the day you walk in to the courthouse to give your attorney your great evidence.

Over 30-plus years of practice, I can't tell you how many times that I have had clients show up at trial with photos, videos, documents, or other last-minute evidence that they think is useful. It is painful to have to explain to them that it is too late for their evidence to be used at trial.

Copies need to be made for the Judge, opposing counsel, and (possibly) witnesses to use at trial. If discovery was served, or court rules required exhibits to be exchanged, your lawyer might not be able to use your great evidence, if it was not provided to the other side ahead of time. So, don't be shy. Get with your attorney as soon as you realize that you have some important evidence that needs to be used at your trial. You'll both be glad you did.