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
Contested legal issues — each side's position and basis for disagreement
Witness summaries — organized by party:

| Witness | Party | Type | Core Testimony | Live/Designation | Objection Risks | |---|---|---|---|---|---|

Exhibit index:

| Exhibit ID | Description | Custodian | Evidentiary Dispute | Intended Use | Foundation Need | |---|---|---|---|---|---|

Trial logistics & ancillary matters — motions in limine, evidentiary fights, expert challenges
Settlement/ADR status — without privileged detail
Quality pass — verify against jurisdictional formatting, paginate, sign

3) Templates

COURT:
CASE NO.:
JUDGE:
PLAINTIFF / DEFENDANT:
NATURE OF ACTION:
HEARING / TRIAL DATE:
PARTY RESPONSIBLE FOR FILING:

DISPUTED ISSUE TABLE
Issue | Governing Rule/Authority | Party A Position | Party B Position | Why Material | Proposed Relief

Guidelines

Mandatory sections — caption, procedural history, undisputed facts, disputed facts/law, witnesses, exhibits, trial logistics, ADR posture
Source grounding — every disputed matter must cite case-file sources; never restate hearsay as fact
Undisputed facts — each paragraph must be unequivocally non-controversial
Neutral tone — no argumentative rhetoric
Privilege guard — preserve litigation positions but never reveal settlement demands, mediation positions, or privileged strategy
Local rules govern — if local rules conflict with this template, defer to local rules
Admissibility citations — cite only authority you can verify in case materials and governing law [VERIFY]