Use when drafting a single section of a litigation brief — such as a statement of facts, argument section, standard of review, or conclusion — that is cited to the record, consistent with the case theory, and fully flagged for attorney verification before filing.
When to use
Counsel needs a first draft of a specific brief section: a statement of facts, an argument section or sub-section, a standard of review section, a conclusion, or a similar discrete component of a written submission.
A user asks to "draft the argument section," "write the statement of facts," or "put together the standard-of-review section."
The case theory and the relevant record materials are available and can be provided as inputs.
The matter is in active litigation or an imminent filing posture and the section type is known.
The draft is for a written submission (motion, opposition, brief, reply) or, with appropriate scope adjustment, a structured outline for oral argument preparation.
Required inputs
Matter identification — matter name, matter number, or a brief description sufficient to identify the case.
Case theory — one sentence stating the factual and legal proposition the filing party is advancing. The entire draft turns on this sentence; without it, the skill cannot produce a coherent section.
Section type — the specific section to be drafted: statement of facts, argument (identify the proposition), standard of review, conclusion, or another named section. If the section type is ambiguous, the skill will ask for clarification before drafting.
Written submission or oral argument — confirm which posture applies. Written submissions call for thorough authority development with full citation placeholders; oral argument preparation produces a leaner structure with a sharper lead and fewer supporting points.
Forum and local rules — paste the relevant local rules, standing orders, or page and word-count limits directly into the input. If this material is not provided, the skill will flag all format and length requirements as [CONFIRM: forum rules not provided — attorney to verify]. Do not rely on the skill's background knowledge of any court's rules; treat all unstated rules as unconfirmed.
House style sample — a sample brief or excerpt from the supervising attorney or firm showing the expected tone, heading style, citation format, and prose register. If none is provided, the skill will note the absence and apply a neutral, professional default, flagging the style choice for attorney review.
Record materials — the documents, deposition transcripts, declarations, pleadings, or other record items that will supply the factual predicate for this section. Every fact in the draft must be tied to a provided record item or flagged [VERIFY: record cite needed]. If no record materials are provided, the skill cannot draft a fact-intensive section and will stop to request them.
Authorities already identified by counsel — any cases, statutes, rules, or secondary sources that the supervising attorney has already confirmed and directed the skill to use. The skill will insert these as placeholders in the proper locations; it will not add authority beyond what is provided and directed.
Optional: the practice group's practice-profiles/litigation.md if it has been populated and is loaded alongside this skill. If present, the skill uses its Preferred Output Style and Standard Positions tables to benchmark the draft against the group's house style. If absent, the skill proceeds without practice-profile benchmarking and asks the user to supply standing positions inline if needed.
If matter identification, case theory, or section type is missing, stop and request the missing information before proceeding. Do not fabricate any input.
Use when building an element-by-element claim chart — mapping patent claim limitations or the elements of a civil cause of action or affirmative defense against evidence — to produce a structured gap analysis for attorney review.
When to use
Counsel needs an element-by-element mapping of patent claim limitations against an accused product, system, or process (infringement analysis) or against prior art (invalidity analysis).
Counsel needs the required elements of a civil cause of action or affirmative defense mapped against the evidence corpus to identify what is supported and what still needs to be developed.
A matter is approaching a case-dispositive filing — summary judgment, trial preparation, or a pre-filing infringement analysis — and a structured gap analysis is needed before strategy decisions are made.
Discovery is closing and counsel needs to audit which elements are evidentially supported and which require additional fact or expert development.
A party is evaluating whether to assert or defend a claim and needs a preliminary map of the elements against available evidence before making that decision.
Required inputs
For all modes:
Matter name and a one-line case theory (e.g., "Plaintiff contends Defendant's product infringes Claim 1; we are defending").
Mode: patent (infringement or invalidity) or civil (cause of action or affirmative defense).
Side: asserting or defending.
Jurisdiction and court. If not provided, insert [verify jurisdiction] throughout and flag for attorney confirmation before proceeding.
Whether any documents were obtained via discovery or are subject to a protective order or other use restriction — a use-restriction check must be run before mapping begins.
Patent mode — additional inputs:
The patent (text or key excerpts) and the specific asserted claim(s).
Any claim-construction ruling, agreed constructions, or disputed terms. If none are provided, flag all potentially disputed terms as [VERIFY: construction not confirmed].
The accused product, system, or process description (for infringement) or the prior-art reference(s) (for invalidity).
Civil mode — additional inputs:
The pleaded claim or defense as stated in the operative pleading.
The controlling elements — from the jurisdiction's pattern jury instruction, approved jury charge, or governing statute. If not provided, insert [ATTORNEY TO CONFIRM: elements source and governing authority — verify jurisdiction] and do not proceed with mapping until the elements are confirmed.
The evidence corpus: documents, deposition excerpts, declarations, expert reports, or other materials to be mapped.
If mode, side, or jurisdiction is not provided, stop and request them before proceeding. Do not begin mapping without confirmed controlling elements.
Use when drafting a demand letter for attorney review — running a structured intake, a pre-draft risk gate, and a draft with every legal conclusion, damages figure, and deadline flagged for attorney confirmation before sending.
When to use
A user asks to "draft a demand letter," "write a demand," or "send a letter before filing suit."
Counsel wants a structured first draft before editing and sending a pre-litigation demand.
A client has suffered a harm and counsel needs to frame and communicate a pre-suit demand.
A breach of contract, tort claim, employment dispute, property damage, or similar matter requires a formal written demand as a precursor to litigation or negotiation.
A statutory or contractual pre-suit notice requirement must be met (attorney must confirm applicability and form).
Required inputs
The client's identity and role (the party making the demand).
The recipient's identity and, if known, address and counsel information.
A description of the dispute, the alleged harm, and the factual background (from documents or a client summary).
The nature of the claim or legal theory to be asserted (e.g., breach of contract, negligence, fraud) — attorney will confirm.
The relief or remedy being demanded (e.g., payment of a specific amount, return of property, specific performance).
Any prior correspondence on the matter, and the underlying contract or authority (pasted in full where possible, not summarized).
The desired posture: tone (measured / firm / aggressive), the response window, how the letter will be sent, and who will sign it.
If the client identity, recipient identity, or nature of the demand is not provided, stop and request it. Do not draft a demand letter without knowing who is demanding what from whom.
Use when building a structured deposition outline from the case theory, witness profile, and documentary record to produce a focused, attorney-ready map for taking or defending a deposition.
When to use
Counsel needs to prepare for an upcoming deposition and wants a structured question outline organized around topic blocks.
A user asks to "prep for a deposition," "draft a depo outline," or "organize the documents for the [witness] deposition."
The case theory and witness role are clear enough to define a deposition goal.
Preparing for an adverse, neutral, friendly, or organizational-representative witness.
Required inputs
Matter identification — matter name, matter number, or a brief description sufficient to identify the case.
Case theory — one sentence stating the factual and legal proposition the deposing party is trying to establish or defend.
Witness profile — the witness's name, role in the matter, why this witness is being deposed, and posture: adverse, friendly, neutral, or organizational representative (an entity's designated representative).
Deposition rules of the forum — the procedural rules governing the deposition (duration limits, objection conventions, scope limitations). Treat any statement of forum rules as [verify jurisdiction] until confirmed by the responsible attorney.
Documentary record — documents to be used in the deposition, provided in full or described with Bates range or a clear identifying description. At minimum, a list of the key documents must be provided.
Prior testimony — prior deposition transcripts, sworn statements, or hearing testimony, if any (pasted or described). If none exists, state that explicitly.
If the matter identification, case theory, witness profile, or at least a summary of the documentary record is not provided, stop and request the missing information. Do not begin the outline. Do not fabricate any of these inputs.
Use when preparing a litigation hold notice and preservation-scope summary — issuing a new hold, refreshing an existing one, or releasing a closed one — as draft legal work product for attorney review before distribution to custodians.
When to use
An attorney has determined that a duty to preserve has been triggered and needs a first-draft hold notice to send to custodians.
A prior hold must be refreshed because the scope has changed, additional custodians have been identified, the date range has expanded, or new systems are in scope.
A matter has closed and counsel needs a draft hold-release notice confirming that preservation obligations have lifted.
The attorney wants a preservation-scope summary alongside the notice to document what was covered and why.
Required inputs
For all modes:
Matter identification — name, number, or brief description sufficient to identify the matter.
Trigger event — the event that prompted the hold (e.g., receipt of a complaint, a threat of litigation, a regulatory inquiry). The attorney must have already determined that this event triggers a preservation duty; this skill does not make that determination.
Preservation scope — the categories of documents, communications, and data to be preserved (e.g., contracts, correspondence, financial records, project files, metadata).
Named custodians — the individuals who may possess responsive information, with their roles or titles. Identify any departed custodians separately.
Date range — the start date and end date (or "ongoing") for responsive material. The attorney must supply these dates; this skill does not compute or assert a trigger date.
Systems in scope — the platforms, applications, and devices from which material must be preserved (e.g., email, chat and messaging tools, file-share and cloud-storage platforms, devices, CRM systems, legacy or archival systems, voicemail).
Effective date of the hold — the date on which the preservation obligation begins. Provided by the attorney; do not compute.
Additional inputs for Refresh mode:
The prior hold notice (or a reference to it) and the date it was issued.
A description of what has changed: new custodians, expanded scope, updated date range, new systems, or other amendments.
Additional inputs for Release mode:
Confirmation from the attorney that the matter is closed and the preservation duty has lifted.
Confirmation that no related matter, appeal, cross-claim, or insurance recovery is still live that could independently sustain the preservation obligation.
The date the release is effective.
If matter identification, trigger event, custodian list, or preservation scope is not provided, stop and request the missing information. Do not draft a hold notice without knowing what is being preserved, from whom, and why. Do not fabricate custodian names, systems, or scope categories.
Use when building a factual timeline for litigation from provided source documents, producing a structured chronology table with citations, disputed/undisputed flags, and gap analysis for attorney review.
When to use
A user asks to "build a timeline," "create a chronology," or "put the facts in order" from a set of documents.
Counsel needs a fact-organized view of events across multiple documents, productions, or depositions.
Pre-trial preparation requires organizing the documentary record by event date.
A mediation brief, motion, or opening statement requires a supporting factual narrative grounded in the record.
A second attorney is joining the matter and needs a document-grounded orientation to the facts.
Discovery gaps or missing time periods need to be identified and flagged.
Required inputs
One or more source documents (contracts, correspondence, emails, text messages, records, pleadings, deposition excerpts, discovery responses, or other materials). Do not build a chronology without source documents.
Identification of each source document: document name, Bates range or other identifier, and date of the document if known.
The matter name or a brief description of the dispute (to give the chronology appropriate context).
The client's role (plaintiff, defendant, etc.) so that significance assessments can be framed appropriately.
Privilege posture of the source documents. For each source document (or the set as a whole), confirm one of the following: (a) all documents are cleared for use in this chronology (e.g., produced non-privileged materials); (b) some or all documents may be privileged or of mixed privilege status; or (c) privilege status is unknown. If status is unknown or mixed, do not proceed without attorney confirmation — record [ATTORNEY TO CONFIRM: privilege status of source documents before distribution of this chronology] and flag the chronology as potentially sensitive.
If no source documents are provided, stop and request them. Do not populate the chronology from background knowledge, assumed facts, or the description of events alone.
Use when opening a new litigation or dispute matter to produce a structured intake summary capturing parties, claims, jurisdiction, key dates, and immediate action flags for attorney review.
When to use
A new dispute, claim, or litigation matter is being opened and a structured intake record is needed.
A user asks to "open a new matter," "intake this dispute," or "set up a file for this case."
A client has received a complaint, demand letter, or threat of litigation and initial triage is required.
A conflict check, litigation hold, or insurance notice obligation needs to be flagged at the outset.
A lawyer or paralegal needs a repeatable checklist-driven intake process.
Required inputs
Identity of the client: name, entity type, and role in the dispute (plaintiff, defendant, third party, etc.).
Names and roles of all known opposing parties and other significant parties.
A plain-language description of the dispute or claims (summary, complaint, demand letter, or similar).
The relevant jurisdiction(s) and forum (court, arbitral body, regulatory agency, or unknown).
Any known key dates: date of incident, date of filing, service date, response deadline, statute of limitations dates.
If the client identity or a basic description of the dispute is not provided, stop and request them. Do not assume the client's role or fabricate party names, claims, or dates.
Use when conducting a first-pass review of a privilege log to sort entries into three tiers — confidently privileged, uncertain (flagged for attorney decision), and recommend-remove — so attorney review time focuses on the entries that require judgment.
When to use
Counsel needs a first-pass triage of a privilege log before conducting a detailed privilege review.
A privilege log has been received from opposing counsel and counsel wants a structured analysis before a meet-and-confer or motion challenge.
A party is preparing its own privilege log and wants a quality-control pass to identify thin descriptions, format deficiencies, and likely-challengeable designations before service.
A large log needs to be organized so attorney review time is concentrated on the close calls rather than the clear cases.
Required inputs
The full privilege log. Each entry must contain at minimum: date, author, recipients (To / CC / BCC), document type, privilege claimed, and description. If any of these fields are missing across entries, note those entries as format-deficient and proceed with what is available.
The matter name and number.
The forum and jurisdiction (court, arbitral body, or regulatory proceeding). If not provided, stop and request it; the applicable privilege rule varies by forum.
The applicable privilege rule text, if available (e.g., a local rule, standing order, or agreed ESI protocol specifying log format and required fields). If not provided, flag as [CONFIRM: applicable privilege log rule — verify with counsel] and proceed using the required-fields list above as the baseline.
Whether any underlying documents are available for spot-check purposes. If so, identify which entries will be spot-checked; do not review underlying documents beyond the scope provided.
Whether any use-restriction order or clawback agreement is in effect that limits how the log or its contents may be used.
If the privilege log itself is not provided, stop and request it. Do not proceed without it. Do not fabricate or assume log entries.
Use when an incoming subpoena has been received to produce a structured triage summary identifying the compliance deadline, scope, objections, privilege issues, preservation obligations, and internal notification requirements for immediate attorney review.
When to use
A subpoena has been received by the client, the organization, or a custodian of records and triage is needed.
A user asks to "triage this subpoena," "we got a subpoena, what do we do," or "review this subpoena."
Counsel needs to quickly identify objection grounds, privilege issues, and internal notification obligations when a subpoena arrives.
An organization needs a structured process for handling subpoenas received in connection with third-party litigation.
A non-party has been served and needs to evaluate its obligations before a compliance deadline runs.
Required inputs
The full text of the subpoena (uploaded or pasted). Do not triage from a description alone — the actual subpoena must be reviewed.
The identity of the recipient: who was served (the individual, entity, or custodian of records).
Whether the recipient is a party to the underlying litigation or a non-party third party.
The date of service (to evaluate the compliance deadline — attorney must verify the computation).
If the subpoena text is not provided, stop and request it. Do not complete a triage without reviewing the actual subpoena.