ThomasMoreAI 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]