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Litigation Support

Chronologies, discovery, deposition prep, and the statements and outlines that move a case forward.

PROMPTS 20 // OPEN SAMPLES 2 // FREE WITH ACCOUNT 18

Master chronology — first build from a document set

OPEN SAMPLE

Builds a date-ordered case chronology from a stack of document excerpts or summaries. Reach for it at the start of discovery or before drafting a statement of facts.

[CASE NAME] ·[CLAIMS AND DEFENSES] ·[KEY PLAYERS] ·[DATE RANGE] ·[DOCUMENT EXCERPTS OR SUMMARIES]
## Context
You are a litigation paralegal building a master chronology in [CASE NAME]. The claims and defenses: [CLAIMS AND DEFENSES]. Key players: [KEY PLAYERS]. The relevant period runs [DATE RANGE]. I will paste document excerpts or summaries below, each tagged with a Bates number or exhibit reference.

## Task
Build a chronology table with these columns: Date | Event | Source (Bates or exhibit no.) | Players involved | Why it matters to the claims or defenses.

## Standards
- One row per event. Sort by date, earliest first.
- Use exact dates from the documents. If a document gives only a month or an approximate date, write it as stated and add "(approx.)".
- Every row cites at least one source document. No row without a cite.
- Describe events in neutral terms. No characterizations of intent and no legal conclusions in the Event column. Argument-relevant notes go only in the last column, marked "Possible significance:".
- If two documents conflict on a date or fact, put both versions in one row and flag it "CONFLICT".
- Do not infer events no document supports. If a gap looks important, list it under a final heading "Gaps and missing periods".
- Plain English. No adjectives like "damning" or "smoking-gun".

Documents:
[DOCUMENT EXCERPTS OR SUMMARIES]

If any document lacks a date or a Bates reference, ask me before placing it rather than guessing.
BEFORE YOU RUN IT
  • Remove client-identifying details, or confirm your AI tool sits under your firm's confidentiality and bar guidance before pasting case documents (ABA Formal Op. 512)
  • Document excerpts or summaries, each tagged with its Bates number or exhibit reference
  • One-paragraph statement of the claims and defenses
  • List of key players with roles
  • The relevant date range
VERIFY BEFORE IT LEAVES YOUR HANDS
  • Spot-check every date against its source document; transposed dates are the most common error
  • Confirm each cited Bates number exists and matches the document described
  • Check that no row describes an event absent from the pasted documents
  • Confirm rows flagged CONFLICT reflect a real discrepancy, not two descriptions of the same event
  • Read the "Possible significance" notes as suggestions, not analysis you adopt without thought
  • Check the gaps list against your own knowledge of the production; the AI sees only what you pasted
Sample output
Sample output — AI-generated from sample inputs:
(Meridian Supply Co. v. Harlan Fabrication LLC — breach of supply agreement)

| Date | Event | Source | Players | Why it matters |
|---|---|---|---|---|
| 2024-01-15 | Parties sign Supply Agreement; 24-month term, 5,000-unit monthly minimum | MER-000112 | Whitfield (Meridian), Okafor (Harlan) | Sets the minimum-quantity term at issue |
| 2024-06-03 | Okafor emails Whitfield: April shipment "short by roughly 1,200 units" due to "press downtime" | MER-000487 | Okafor, Whitfield | Possible significance: first written notice of shortfall; states a cause |
| 2024-06-20 (approx.) | Internal Harlan memo cites "ongoing capacity issue since spring" | HAR-002201 | Reyes, Okafor | Possible significance: internal knowledge before the June 3 assurances |
| 2024-07-08 | CONFLICT — Meridian letter states cure deadline of July 1 (MER-000530); Harlan reply states July 15 (HAR-002340) | MER-000530; HAR-002340 | Whitfield, Okafor | Cure-period dispute bears on the termination claim |

Gaps and missing periods: no documents between 2024-02-01 and 2024-05-30 despite monthly shipments due under § 3.2.
CUSTOMIZATION

Add columns the matter needs — a Damages column for commercial disputes, a Treatment column for injury cases. For document-heavy matters, run the prompt in batches of 20-30 documents and combine results with the chronology-merge prompt in this section. Match the date format to your jurisdiction's filing conventions before the chronology feeds a brief.

Chronology update — merge a new production into the timeline

Folds newly produced documents into your existing chronology and flags entries the new material contradicts. Run it after each rolling production.

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Timeline conflict check — testimony against the documents

Compares witness testimony against the documentary timeline and lists every discrepancy with cites. Use it to prepare a deposition or cross-examination outline.

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Exhibit summaries — one paragraph per document

Produces a numbered entry for each exhibit: identifying details, a neutral summary, and a relevance line. Use it when assembling exhibits for a motion, hearing, or mediation statement.

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Trial exhibit list — draft with objection flags

Drafts a court-format exhibit list plus a work-product appendix flagging likely evidentiary objections to each exhibit. Use it ahead of the pretrial order deadline.

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Production gap analysis — RFP responses vs. documents received

Maps each request for production against what the other side produced and lists the shortfalls with cites. Use it to build a meet-and-confer letter or a motion to compel.

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Production gap scan — missing attachments, Bates breaks, silent periods

Scans a production log for internal gaps: referenced-but-missing attachments, broken email threads, Bates skips, and quiet date ranges. Run it soon after a production lands, while the conferral window is open.

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Deposition digest — page-line summary by topic

Turns a deposition transcript into a topic-organized digest with page:line cites and verbatim quotes for the testimony that matters. Run it when the transcript arrives, before memory fades.

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Deposition vs. prior statements — inconsistency table

Compares deposition testimony against the witness's earlier statements — interrogatory answers, declarations, emails, prior testimony — and tables every inconsistency with cites. Use it to build an impeachment workup.

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Post-deposition memo — admissions, damage, leads, next steps

Digests a fresh deposition into a working memo: best testimony, worst testimony, blocked questions, new leads, and follow-up discovery. Write it within days of the deposition, while discovery is still open.

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Witness prep outline — fact witness deposition

Produces a 90-minute prep-session outline for a fact witness before deposition. Reach for it the week before, once you know which exhibits the witness will face.

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Witness prep — cross-examination vulnerability map

Maps where a testifying client or key witness is exposed on cross, sourced to transcripts and documents. Run it before the final prep session for trial or arbitration.

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Confidential mediation statement — first draft

OPEN SAMPLE

Drafts a confidential mediation statement for the mediator's eyes only. Use it two to three weeks out, once you have the damages numbers and the negotiation history in hand.

[CASE CAPTION AND COURT] ·[CLIENT AND POSITION] ·[MEDIATOR NAME AND BACKGROUND, IF KNOWN] ·[TWO-PARAGRAPH DISPUTE SUMMARY] ·[POSTURE — MOTIONS PENDING, DISCOVERY STATUS, TRIAL DATE] ·[STRENGTHS] ·[WEAKNESSES AND BAD FACTS] ·[DAMAGES BREAKDOWN WITH NUMBERS] ·[PRIOR DEMANDS AND OFFERS] ·[TARGET RANGE AND MUST-HAVE TERMS]
## Context
You are a litigation drafting assistant for a solo attorney. Draft a confidential mediation statement for the mediator only — the other side will not see it. Case: [CASE CAPTION AND COURT]. Client: [CLIENT AND POSITION]. Mediator: [MEDIATOR NAME AND BACKGROUND, IF KNOWN]. Dispute summary: [TWO-PARAGRAPH DISPUTE SUMMARY]. Procedural posture: [POSTURE — MOTIONS PENDING, DISCOVERY STATUS, TRIAL DATE]. Liability strengths: [STRENGTHS]. Weaknesses and bad facts: [WEAKNESSES AND BAD FACTS]. Damages: [DAMAGES BREAKDOWN WITH NUMBERS]. Settlement history: [PRIOR DEMANDS AND OFFERS]. Goal: [TARGET RANGE AND MUST-HAVE TERMS].

## Task
Draft the statement, five to eight pages of content, in this order: introduction and what the client wants from mediation; factual background told as a clear story; procedural posture; liability analysis that addresses our weaknesses head-on instead of hiding them; damages with a simple table; settlement history and why talks stalled; obstacles to settlement and how the mediator can help; conclusion with our realistic range.

## Standards
- Candid tone. This document persuades the mediator we are reasonable, not that we are invincible. Concede what the record makes us concede.
- No case citations unless I supply them. Where law matters, write [CITE] and describe the point so I can add verified authority.
- Plain sentences. No adjectives doing the work facts should do.
- Label the settlement-range section CONFIDENTIAL — MEDIATOR'S EYES ONLY.
- Flag every factual statement you cannot trace to my inputs as [CONFIRM].

If a required input is missing, list what you need and stop. Do not draft around gaps.
BEFORE YOU RUN IT
  • Two-paragraph dispute summary and the procedural posture
  • An honest list of strengths and weaknesses — the statement fails if you feed it only strengths
  • Damages numbers with backup (medicals, lost profits, contract amounts)
  • Full demand-and-offer history with dates
  • The mediator's requirements: page limit, due date, and whether statements are confidential or exchanged
  • Remove client-identifying details, or confirm your AI tool sits under your firm's confidentiality and bar guidance before pasting case facts (ABA Formal Op. 512)
VERIFY BEFORE IT LEAVES YOUR HANDS
  • Confirm whether your mediation order calls for an exchanged statement, a confidential one, or both — this draft assumes confidential, and an exchanged version needs the weaknesses and range sections rewritten or removed
  • Trace every factual assertion to the record; resolve every [CONFIRM] flag
  • Recompute the damages table yourself — AI arithmetic errors in damages tables are common
  • Verify the demand-and-offer numbers and dates against your file; one wrong prior-offer figure costs you credibility with the mediator
  • Replace every [CITE] with authority verified in Westlaw, Lexis, or an official reporter — never send AI-suggested citations unchecked
  • Read the weaknesses section as the mediator will: does it concede enough to be credible without conceding liability?
  • Confirm nothing in the statement admits facts you would dispute at trial — mediation confidentiality and Rule 408 protection have limits that vary by state
Sample output
Sample output — AI-generated from sample inputs (Pell Family Dental v. Meridian Supply Co., defective autoclave, plaintiff side):

III. Liability
Meridian will say Dr. Pell's staff ignored the maintenance schedule. The argument has surface appeal, and we address it directly. The service log shows two missed monthly checks in 2024. [CONFIRM: log produced as Ex. 9.] But Meridian's own technician inspected the unit in January 2025 and certified it serviceable — six weeks before the chamber failure. The missed checks cannot explain a sealed-component failure that Meridian's manual says only factory service can reach.

IV. Damages
Equipment replacement: $41,200 (invoice attached)
Practice interruption, 11 days: $38,940 (production reports, 2024 daily average)
Repair attempts: $6,150
Total: $86,290

VII. Obstacles to Settlement
The parties value the maintenance defense differently, and Meridian's last offer predates the technician's deposition. The mediator can help by testing Meridian's read of that testimony in caucus.

CONFIDENTIAL — MEDIATOR'S EYES ONLY
Dr. Pell will accept $70,000 paid within 30 days. The number reflects real trial risk on the maintenance defense, which we estimate cuts our verdict expectation by roughly 20 percent.
CUSTOMIZATION

For court-annexed mediation, check the local rule first — some districts cap statements at five pages and bar exhibits. Defense-side drafts should expand the obstacles section to cover insurance authority and approval timing. In employment and family matters, add a non-monetary terms section (references, confidentiality, parenting logistics) — those terms often unlock the deal.

Mediation opening — joint-session talking points

Drafts spoken talking points for a joint-session mediation opening aimed at the opposing principal, plus a do-not-say list. Use it once the mediator confirms a joint session will happen.

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Settlement conference statement — court-ordered format

Drafts a settlement conference statement that tracks the judge's order section by section. Use it when a court-ordered statement is due and the order dictates the format.

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Settlement conference prep memo — client risk and range

Drafts a plain-English memo preparing your client for a settlement conference: the process, the honest numbers, and the authority you need. Send it a week before the conference.

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Voir dire question drafts — civil jury

Drafts a case-specific voir dire question set built around your bad-juror profile, with cause-challenge follow-ups. Use it once the trial date and voir dire format are set.

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Voir dire follow-ups — building the cause-challenge record

Turns a problem juror's answer into a follow-up sequence that builds a for-cause record — or protects a favorable juror from one. Use it in final trial prep and at counsel table.

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Opening statement outline — civil trial scaffold

Builds an opening statement outline with an auditable list of every promise made to the jury. Use it after the witness and exhibit lists are settled.

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Closing argument outline — elements-to-evidence map

Builds a closing argument outline that maps each jury instruction element to the admitted evidence. Use it during trial, once the instruction set is near final.

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Unlock free with an account →
  • Nothing on this page is legal advice. The prompts are drafting tools, not counsel.
  • AI output is a draft. Every document, email, or filing it touches requires attorney review before use.
  • Check your bar's guidance on AI and confidentiality before any client information goes into an AI tool.