Prompt Pilotby Write.law
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Communicate

Hand off a matter to co-counsel

Produces a handoff memo that lets incoming co-counsel take the next deposition without calling you: posture, live deadlines with dates, locked decisions, and the risks that are not visible from the file.

About 15 minintermediateLitigation

Your prompt5,073 characters

Still to fill in: Matter and posture, Theory and status, Decisions locked in, and the risks, Court / forum

RoleYou are a partner who has been on both ends of a bad handoff, including the one where the memo said "discovery ongoing" and the receiving team blew a deadline nobody flagged. You write for the lawyer who will stand up in court without you. You lead with what is decided and what is dangerous, you never bury an unfavorable fact in an attachment, and you refuse to write a status line without a date on it.What I needDraft a handoff memo to incoming co-counsel on the matter below, venued in Court / forum. Their engagement is Full transfer: they run the matter. Write to what they have to run, not to everything I know.InputsMatter and posture: Matter and posture Theory and status: Theory and status Decisions locked in, and the risks: Decisions locked in, and the risks Court / forum: Court / forum Scope of the handoff: Full transfer: they run the matterHow to work this1. Open with posture in two sentences: type of case, stage, who we represent. No background section. 2. State the theory in three sentences: the version you would say out loud to the client, not the version in the brief. 3. Build a status table where every row carries an item, its state, and a date. If I did not give you a date, write "DATE NOT SUPPLIED - confirm on the docket" rather than inventing one. 4. Name the 5–10 documents that anchor the case. One line each: what it is, why it matters, whether it helps or hurts. At least one must hurt us. 5. List the decisions locked in with the reason for each. Where the reason was the client's call and not a legal judgment, label it so co-counsel knows what they cannot reopen without the client. 6. List every open question with your recommendation and a one-line rationale. No bare questions. 7. Close with what is not in the file: witness weaknesses, how the judge in Court / forum rules on issues like these, opposing counsel's habits, and client sensitivities.Close with these four sections, every time, without being askedAssumptions I made. Every factual, procedural, and strategic assumption behind the memo. Mark each [verify] or [safe]. Flag every date you carried forward from my input rather than confirmed against a docket. Where this is weakest. The two or three places incoming counsel is still most likely to be surprised: a status line that is thinner than it looks, a decision whose rationale will not survive their scrutiny, a risk I described too gently. Name the section, not "the memo generally." What only you can decide. The judgment calls I deliberately left to you. At minimum: how much of the sensitive material goes in writing. A full-disclosure memo makes co-counsel effective on day one but creates a document that is discoverable if the common-interest privilege is later contested, while a sanitized memo plus a live call keeps the worst material off paper at the cost of an hour and the risk it never lands. Also yours: whether to send before or after the conflicts check and common-interest agreement are signed, and whether the client sees this memo. Give me the options and the tradeoffs, not a caution. What would make this materially better. The specific document or answer from me that would most improve the next pass: the current scheduling order, the docket sheet, the client's actual settlement authority, or the deposition transcripts. Rank by impact.Output formatA ready-to-send memo: posture (2 sentences), theory (3 sentences), a status table (Item / State / Date), numbered key documents labeled helps or hurts, decisions locked in with rationale, open questions each with a recommendation, "What is not in the file," then the four closing sections.Never do this- If this memo would read the same with a different caption dropped in, it is too generic. Start over from this docket and these deadlines. - No hedging filler. Cut "arguably," "it should be noted," "discovery is ongoing," and "it depends." Do not tell co-counsel to consult an attorney. They are the attorney. - Every date, docket number, exhibit number, and citation must come from my inputs or be marked [UNVERIFIED - confirm on the docket]. Never invent a hearing date or an exhibit number. A wrong date here becomes a missed deadline. - If you do not know whether a deposition was taken or a motion decided, say you do not know and flag it. Do not smooth over the gap with fluent prose. - Do not pad. A four-page memo that gets read beats a twelve-page memo that gets skimmed. Length is not value.Before you answer- Could co-counsel take the next deposition from this memo without calling me? - Would this memo be useless to a lawyer on any other case? It should be. - Does every status line carry a date, or a flag that the date is unconfirmed? - Did I include at least one document and one fact that hurt us, and a recommendation for every open question? - Is any date, docket number, or exhibit number here something I generated rather than something I was given?

Adds driver's-seat tunes: options instead of answers, questions before work, every citation flagged. Your values come with it.

2

Pressure-test it

Makes the AI switch hats and attack its own answer.

Three days into the case, with a status conference Thursday, incoming trial counsel is reading this memo for one thing: whatever the outgoing team is embarrassed about. Go through it as the lawyer who just inherited the file. List every question you would still have to email me. Then tell me which of those questions the memo should have answered and which one I am hiding, and rewrite the two weakest sections so the email never gets sent.
3

Go deeper

Pushes the work further once the basics are right.

Some of this does not survive email. Build the agenda for the 30-minute live handoff call: the four topics that cannot be handled in writing, the two documents to open together on screen, the decisions to formalize on the call, and the three questions I should ask incoming counsel to confirm they actually read the memo.

Before you run it

What to gather first

  • Caption, case number, court, and who we represent
  • Theory of the case and the three facts it rests on
  • Every pending deadline with its date, pulled from the docket or scheduling order
  • Decisions already made and who made them: you or the client
  • Settlement authority, client sensitivities, and anything unfavorable co-counsel must not discover from the other side

Watch for

  • A handoff memo is work product, but protection depends on a signed common-interest or joint-defense agreement being in place first. Confirm the agreement and clear conflicts before this leaves your building.
  • The model will repeat whatever dates you feed it. Reconcile every deadline against the docket and the operative scheduling order before sending. A stale date in a handoff memo is how deadlines get blown.
  • Do not omit unfavorable facts to make the file look better. Co-counsel who learns about the bad document from opposing counsel will never trust the rest of the memo.
  • Client consent is usually required before sharing confidences with new counsel, and fee-sharing or scope arrangements must be papered separately from this memo.
  • The model cannot see your document management system. Any exhibit number, Bates range, or transcript cite it produces is a guess unless you supplied it.

What comes back

A ready-to-send memo: two-sentence posture, three-sentence theory, a status table with Item / State / Date, 5–10 numbered key documents each labeled helps or hurts, decisions locked in with rationale, open questions each carrying a recommendation, and a "what is not in the file" section. Closes with Assumptions / Where this is weakest / What only you can decide / What would make this better.

See an example of what you’ll get
MEMORANDUM - ATTORNEY WORK PRODUCT / COMMON INTEREST To: R. Okonkwo, Vance & Boyd LLP (incoming co-counsel) Re: Ashford v. Meridian Logistics, No. 3:25-cv-01142 (N.D. Cal., Judge Chhabria) Posture. Defense of Title VII retaliation, FLSA overtime, and breach-of-contract claims brought by a former VP of Operations. Fact discovery is roughly 70% complete and trial is set for October 5, 2026. Theory of the case. Meridian decided to terminate Ashford for documented performance failures before she filed her March 3 HR complaint. The complaint was positioning, not protected activity that caused anything. If liability attaches, damages are bounded by the FLSA two-year limitations period and her failure to mitigate after June 2025. Status and deadlines | Item | State | Date | |---|---|---| | CHRO (Delgado) deposition | Noticed, confirmed | May 14, 2026 | | Fact discovery cutoff | 70% complete | June 1, 2026 | | Summary judgment motion | Drafting, Sections I-II done | Due June 29, 2026 | | Pretrial conference | Set | September 10, 2026 | | Plaintiff's expert report (Kalman, economist) | Received Apr. 2 | Daubert deadline DATE NOT SUPPLIED - confirm on the docket | Key documents 1. Ex. 22: Ashford's Outlook calendar, Feb. 18 entry "exit plan w/ legal." *Helps.* Our best pre-complaint evidence. 2. Ex. 9: Delgado's 2023 memo calling plaintiff "our strongest operator." *Hurts badly.* We have no clean answer for it. 3. Ex. 14: the March 3 HR email. *Hurts.* Plaintiff's headline exhibit; expect it in her opening. 4. Ex. 18: personnel file. *Mixed.* Thin on pre-March discipline, which cuts against pretext. 5. Ex. 30: 2022 arbitration agreement. *Unused.* See locked decisions. Decisions locked in 1. We are not moving to compel arbitration. Client's call, not mine. The CEO wanted the federal forum. Do not reopen without her. 2. Bifurcation abandoned after Magistrate Judge Allen signaled denial at the February CMC. 3. Settlement authority is $0-$425,000, confirmed in writing by GC on April 8. Open questions and my recommendation 1. Preserve the arbitration issue for appeal if we lose summary judgment? *Recommend yes*: footnote it in the MSJ opposition; costs nothing, preserves the record. 2. Daubert motion on Kalman? *Recommend filing at the pretrial conference* rather than now. His back-pay model assumes no mitigation, which our May 14 deposition should undercut. What is not in the file. Delgado is a poor witness: she over-explains and gets defensive on cross; budget three prep sessions, not one. Judge Chhabria has denied summary judgment in four of the last five retaliation cases on his docket. Plaintiff's counsel (Reyes) is quick on her feet and weak on damages. The client's GC does not want the CEO deposed under any circumstances and has not said why. --- Assumptions I made. All deadlines come from your input rather than the docket [verify]. I assumed the March 3 email is authenticated and will come in [verify]. I assumed "settlement authority" means full and final resolution including fees [verify - this is the single most expensive assumption in the memo]. Ninth Circuit law governs the retaliation framework [safe]. Where this is weakest. The "decisions locked in" section reads cleaner than the record supports: item 1 is a client instruction with no memorialized reasoning, and incoming counsel will ask why. The Daubert recommendation also assumes the May 14 deposition goes well; if it does not, the timing recommendation flips. What only you can decide. How much of the Delgado weakness and the CEO-deposition issue goes on paper. Putting it in the memo makes Okonkwo effective immediately but creates a document that is discoverable if the common-interest privilege is challenged later; keeping it to a call protects the material but risks it never landing before the May 14 deposition. Also yours: whether this memo goes out before or after the common-interest agreement is signed, and whether the GC gets a copy. She will read the Delgado paragraph as criticism of her hire. What would make this materially better. (1) The current scheduling order: it would resolve the Daubert deadline and three other dates. (2) The Delgado deposition transcript from the related state case, if it exists. (3) The GC's written settlement authority, so incoming counsel is not relying on my summary of it.
Why this prompt is built the way it is
## Framework 1. **Posture in two sentences.** What kind of case, what stage, who we represent. No background section. 2. **Theory in three sentences.** The version you would say out loud to the client, not the version in the brief. 3. **Status with dates.** Every row of the status table carries an item, a state, and a date. "Ongoing" is not a status. 4. **The 5–10 documents that anchor everything.** One line each on why it matters and whether it helps or hurts. At least one must hurt. 5. **Decisions locked in, with the reason.** So co-counsel does not relitigate settled ground, and knows which calls were the client's rather than counsel's. 6. **Open questions, each with a recommendation.** A question without a recommendation is a phone call you are trying to avoid. 7. **Where the bodies are.** Witness weaknesses, judicial tendencies, opposing counsel's habits, client sensitivities: the things that are not in the file and would embarrass us if co-counsel learned them from the other side.