| name | trial-prep-summary |
| description | Generates a structured courtroom-ready trial preparation summary synthesizing procedural history, facts, legal issues, evidence, witnesses, and strategy into a quick-reference document. Trigger when preparing trial binders, pre-trial review documents, courtroom reference materials, or trial strategy memos in commercial litigation. |
| tags | ["litigation","summarization","summary"] |
Trial Preparation Summary
Synthesizes case materials into a single courtroom-ready reference organized for rapid access during examination, argument, and tactical decisions.
Required Inputs
- Pleadings — complaint, answer, counterclaims, amended pleadings
- Discovery — interrogatory responses, RFP productions, RFA responses
- Depositions — transcripts with page:line citations
- Expert reports — opinions, methodology, bases
- Motions & orders — dispositive motions, MILs, rulings
- Exhibit list — pre-marked exhibits with Bates ranges
- Witness list — anticipated witnesses for both sides
Quick Start
- Collect all inputs above
- Build sections 1–9 below in order
- Cite every assertion to exhibit #, depo page:line, or Bates range
- Mark uncertain legal citations
[VERIFY]
- Use tables over prose throughout
Output Sections
1. Case Overview
| Field | Content |
|---|
| Caption | Full case caption |
| Court / Judge | Court, department, judge |
| Trial date | Date(s), estimated duration |
| Causes of action | Claims/counterclaims with statutory or common-law basis |
| Burden of proof | Party bearing burden per claim/defense |
| Relief sought | Damages figures, equitable relief, fees |
2. Procedural History
Reverse-chronological table of significant docket entries:
| Date | Event | Order/Ruling | Impact on Trial |
|---|
Flag pending motions, unresolved discovery disputes, deferred evidentiary rulings, and approaching deadlines (pretrial conference, exhibit exchange, witness disclosure).
3. Factual Narrative
- Chronology table — date, event, source (exhibit #, depo cite), disputed/undisputed
- Undisputed facts — stipulated or established by RFA admissions
- Disputed facts — competing versions with supporting evidence for each side
4. Element Mapping
One table per claim/defense (repeat for multi-count cases):
| Element | Governing Law | Our Evidence | Their Evidence | Strength (1–5) |
|---|
Per claim, also note: jury instruction references, standard of proof, key distinguishing case law.
5. Evidence Inventory
| Exhibit # | Description | Auth. Witness | Foundation Issues | Anticipated Objections | MIL Status |
|---|
Flag exhibits needing business-records foundation (FRE 803(6)), expert authentication, or chain-of-custody proof.
6. Witness Summaries
Per witness:
| Field | Content |
|---|
| Name / Role | |
| Calling party | Plaintiff / Defendant / Both |
| Key topics | |
| Favorable depo cites | Page:line |
| Impeachment material | Prior inconsistent statements, bias, interest |
| Availability | Voluntary / subpoenaed / issues |
Separate fact witnesses from experts. For experts add: opinions offered, methodology, Daubert challenge status.
7. Motions in Limine Tracker
| Motion | Filed By | Subject | Status | Impact if Granted | Impact if Denied |
|---|
8. Damages / Relief Analysis
- Damages model — methodology, supporting docs, expert basis
- Damages table — category, amount claimed, evidence, vulnerabilities
- Equitable relief — terms sought, legal standard, factual predicates
- Fees/costs — contractual or statutory basis, documented amounts
9. Strategic Assessment
- Case theory — one-paragraph narrative for the fact-finder
- Strongest arguments — ranked with supporting evidence
- Key vulnerabilities — candid weaknesses with mitigation strategies
- Anticipated opposing themes — their narrative and rebuttal points
- Trial flow — suggested witness order, examination priorities
- Contingencies — if-then scenarios for adverse rulings or unexpected testimony
Pitfalls
- Unsourced assertions — every fact must cite exhibit #, depo page:line, or Bates range
- Stale citations — mark all legal citations
[VERIFY] unless confirmed current and jurisdictionally on-point
- Advocacy creep — maintain neutral analytical tone; flag weaknesses candidly
- General legal summaries — skip principles the attorney already knows; focus on case-specific application
- Missing Daubert flags — always note whether a reliability challenge is pending or viable for expert testimony
