pre-trial-statement

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.

1. Jurisdiction & local rules — filing templates, exhibit-labeling conventions, page/style limits, e-filing requirements
2. Core case file — complaint, answer/counterclaim, motions/orders, case management orders, discovery responses, deposition excerpts, stipulations, admissions
3. Party & claims info — identities, roles, claims, defenses, relief requested, key deadlines (discovery cutoff, expert disclosure, trial date)
4. Confidentiality — sealing requirements for addresses, medical records, trade secrets, sensitive personal data
5. Witnesses — availability, live vs. stipulation vs. deposition designation
6. Exhibits — produced, pre-marked, contested (authenticity/admissibility), redactions
7. 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

1. Caption & cover block — court, case number, parties, judge, trial date
2. Procedural posture — chronological, neutral tone
3. Undisputed facts — numbered declarative paragraphs; no legal conclusions
4. Contested issues of fact — issue title + why material