This page lists three turns, the messages you send to the AI one after another in the same chat, and then a check of the answer. Keep it open next to your chat. Each turn shows the next thing to paste, with the values you entered already filled in. Nothing is sent from this page, and your conversation stays in the AI tool you are using.
Caption, case number, claims, who we represent, and where the case sits.
Your theory of the case plus everything pending, with dates where you have them.
What is settled and why, plus what worries you, including anything unflattering.
Court, judge, and any assigned magistrate or special master.
How much of the matter incoming counsel actually takes over. Changes what belongs in the memo.
Watch for these throughout
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.