| name | pre-trial-statement |
| title | Pre-Trial Statement |
| description | Drafts U.S. civil/commercial pre-trial statements that narrow issues, fix trial assumptions, and prevent evidentiary surprises. Converts pleadings, discovery, and deposition materials into a court-compliant filing with undisputed facts, contested issues, witness and exhibit summaries, trial logistics, and settlement posture. Use when preparing for pretrial conferences, final pretrial orders, or trial. Trigger keywords: pre-trial statement, pretrial statement, trial roadmap, witness list, exhibit list, disputed issues of fact, disputed issues of law. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/pre-trial-statement |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | us |
| practice | litigation |
| language | en |
| tags | ["drafting","pleading"] |
Pre-Trial Statement
Draft a court-ready pre-trial statement that narrows issues, fixes trial assumptions, and prevents evidentiary surprises.
Prerequisites
Pause and gather before drafting. If any item is missing, ask.
- Jurisdiction & local rules — filing templates, exhibit-labeling conventions, page/style limits, e-filing requirements
- Core case file — complaint, answer/counterclaim, motions/orders, case management orders, discovery responses, deposition excerpts, stipulations, admissions
- Party & claims info — identities, roles, claims, defenses, relief requested, key deadlines (discovery cutoff, expert disclosure, trial date)
- Confidentiality — sealing requirements for addresses, medical records, trade secrets, sensitive personal data
- Witnesses — availability, live vs. stipulation vs. deposition designation
- Exhibits — produced, pre-marked, contested (authenticity/admissibility), redactions
- Settlement/ADR — whether obligations are satisfied per case plan or court order
Output Structure
1) Source Matrix
Build before drafting to map inputs to output sections.
| Section | Required Inputs | Statement Output |
|---|
| Caption | Court, case number, parties, judge | Exact caption block |
| Procedural history | Filings/orders log | Chronological timeline |
| Undisputed facts | Stipulations, admissions | Numbered facts |
| Contested issues | Pleading/deposition conflicts | Fact + law dispute sections |
| Witnesses | Notes, designations, party lists | Party-organized witness table |
| Exhibits | Document lists, custodians | Exhibit index + objections |
| Trial posture | Motions, scheduling orders | Trial requirements |
2) Drafting Sequence
- Caption & cover block — court, case number, parties, judge, trial date
- Procedural posture — chronological, neutral tone
- Undisputed facts — numbered declarative paragraphs; no legal conclusions
- Contested issues of fact — issue title + why material
