| name | pre-trial-report |
| title | Insurance Defense Pre-Trial Report |
| description | Drafts objective pre-trial reports for insurance carriers in personal injury defense litigation. Covers liability analysis, damages evaluation, venue/jury analysis, cost projections, expert testimony, settlement recommendations, and trial outcome predictions (~60 days before trial). Use when preparing carrier pre-trial reports, defense trial assessments, or settlement recommendation memos. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/pre-trial-report |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | us |
| practice | personal-injury |
| language | en |
| tags | ["drafting","litigation","memo"] |
Insurance Defense Pre-Trial Report
Produces a structured, objective pre-trial report to an insurance carrier with honest risk assessment and actionable settlement/trial recommendations.
Required Inputs
- Case file — pleadings, discovery, depositions, prior status reports
- Trial date — confirmed date, judge, courtroom
- Medical records — treatment history, IME results, pre-existing conditions
- Expert reports — all retained experts (both sides)
- Billing records — fees/costs to date, projected trial costs
- Settlement history — demand/offer chronology, mediation results
- Surveillance/impeachment materials — if obtained
Header Block
PRE-TRIAL REPORT
TO: [Claims Manager Name and Title]
[Insurance Company]
FROM: [Attorney Name], [Firm Name]
DATE: [Current Date]
RE: [Insured] v. [Plaintiff]
[Court and Case Number]
Policy No: [Number] | Claim No: [Number]
Date of Loss: [Date] | Trial Date: [Date]
Report Sections
Draft each section. Be direct — acknowledge weaknesses, quantify risks, avoid over-promising.
| # | Section | Key Content |
|---|
| 1 | Introduction | Purpose, timeline (~60 days out), developments since last report |
| 2 | Trial Logistics | Trial date, duration estimate, judge, remaining deadlines |
| 3 | Factual Summary | Chronological, evidence-supported; flag disputed facts |
| 4 | Venue & Jury Analysis | Historical verdict data, jury demographics, comparable verdicts |
| 5 | Judge & Opposing Counsel | Judge tendencies, ruling patterns; counsel trial record and style |
| 6 | Costs & Fees | Incurred to date; projected trial costs (attorney, experts, exhibits, post-trial) |
| 7 | Motions Practice | Completed motions and impact; pending (especially MSJ); planned MILs |
| 8 | Liability Analysis |
