pre-hearing-statement

name	pre-hearing-statement
language	en
description	Drafts a Pre-Hearing Statement of Proof for personal injury litigation. Use when preparing prehearing statements, statements of proof, or evidentiary summaries for hearings before courts or administrative agencies.
tags	["brief","drafting","litigation"]

Pre-Hearing Statement of Proof

Produces a numbered-paragraph prehearing submission presenting evidentiary foundation, witness summaries, and legal arguments for a personal injury matter.

Required Inputs

1. Case identifiers — name, number, forum/agency, hearing date, submitting party
2. Chronological facts — key dates, events, parties, relationships
3. Witness list — names, contact info, relationship, expected testimony
4. Documentary evidence — medical records, photos, correspondence, reports
5. Medical records — providers, diagnoses, treatment history, causation opinions
6. Damages — itemized breakdown by category and time period

Quick Start

1. Gather all required inputs above.
2. Draft each section below using numbered paragraphs throughout.
3. Tie every factual assertion to identified evidence — no unsupported claims.
4. Mark uncertain citations with [VERIFY].
5. Review against the Pitfalls checklist before finalizing.

Document Sections

I. Introduction

Element	Content
Caption	Case name, number, forum/agency
Hearing date	Date and location
Submitting party	Name, role (plaintiff/claimant)
Nature of claim	Concise description of dispute
Legal basis	Statutes, regulations, or common law grounds
Relief sought	Specific remedy or damages requested

II. Statement of Facts

• Strict chronological order
• Identify all parties and relationships
• Every assertion tied to evidence to be presented
• Objective tone building factual foundation for legal position

III. Issues for Determination

• Frame each disputed question as a precise issue statement
• Order logically for the hearing officer
• Distinguish legal questions from factual disputes

IV. Witness Summary

Per witness:

Field	Content
Name	Full name
Contact	Address, phone
Relationship	Connection to case
Expected testimony	Key facts/opinions to establish
Purpose	How testimony supports position

For expert witnesses, add: qualifications, expertise area, substance of opinions.

V. Exhibit List

Exhibit	Description	Relevance
A, B, C…	Document type	What it proves

Organize chronologically or by category. Assign identification letters/numbers.

VI. Medical Proof

• All treating/evaluating providers
• Diagnoses and treatment history
• Opinions on causation and impairment/disability
• Connect to applicable legal standards
• Persuasive but accurate tone favoring submitting party

VII. Legal Argument

• Cite applicable statutes, regulations, case law
• Show how evidence satisfies each legal element
• Anticipate and rebut likely opposing arguments

VIII. Damages / Relief Sought

• Itemize monetary damages by category (medical, lost wages, pain/suffering, etc.)
• Show calculation methodology and time periods
• For non-monetary relief, specify action requested and legal basis

IX. Stipulations

• Facts agreed to by both parties
• Exhibits admitted without objection
• Any narrowing of issues

X. Procedural History

• Prior hearings or proceedings
• Relevant discovery conducted
• Never reference settlement discussions (inadmissible)

Pitfalls

• Unsupported facts — every assertion needs identified evidence; no speculation
• Settlement references — exclude all settlement communications per FRE 408 / state equivalents
• Unverified citations — tag with [VERIFY]; do not present uncertain authority as definitive
• Local rule non-compliance — incorporate jurisdiction-specific procedural requirements when known
• Missing numbered paragraphs — all sections must use numbered paragraphs for easy reference