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Communicate
Recap a client meeting
Turns your notes into a recap the client uses as their own record (decisions, owners, dates), written to survive being read back at a deposition.
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2
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3
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What to gather first
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See an example of what you’ll get
Subject: Smith v. Acme; April 27 strategy call recap; mediation May 14; next call May 8
The team agreed to mediate on May 14 before Hon. Lila Reyes (ret.), opening at $1.85M, and to move the Rivera deposition to May 7 so the admissions are locked before the session.
Decisions
- We will mediate on May 14 with Judge Reyes; Acme's counsel confirmed availability on the call.
- We will open at $1.85M. The floor will not be shared with the mediator.
- We will re-notice Rivera for May 7, ahead of mediation.
- Northwind will confirm settlement authority in writing before May 6.
Action items
| Item | Owner | Deadline | Deliverable |
|---|---|---|---|
| Draft the mediation statement | Doe | May 6 | Confidential statement, mediator's eyes only |
| Re-notice the Rivera deposition | Patel | May 1 | Amended notice plus meet-and-confer email |
| Confirm settlement authority | Chen (Northwind) | May 2 | Written confirmation of the authorized range |
| Assemble the exhibit set for mediation | Okoro | May 9 | Tabbed set, 12 exhibits, one copy for the neutral |
Open issues
- Whether to approach the co-defendant separately before May 14. Owner: Doe, to recommend by May 5.
- Whether Okoro attends the mediation in person. Owner: Chen.
Next meeting: May 8, 9:00 a.m. PT. Agenda: review the draft mediation statement and confirm the opening number. Second item: the co-defendant question, if Doe's recommendation is in.
---
Assumptions I made. That "landed 1.85" in your notes means the group settled on $1.85M as the opening rather than as a target [verify - this is the line most likely to be wrong and the most consequential]. That Okoro owns the exhibit set; your notes say "exhibits: Devin" [verify]. That the May 7 deposition date has been cleared with opposing counsel [verify - the recap states it as decided]. That Chen has authority to confirm the range without board sign-off [verify - your notes mention board sign-off and I did not put it in the recap].
Where this is weakest. The line "The floor will not be shared with the mediator" records real strategy, and Okoro is a business stakeholder on the send list. It is probably still privileged, but it is the one line an opposing party would most want to read. Consider cutting it from the recap and confirming it separately with Chen.
What only you can decide. How wide to send: the full list including Okoro creates alignment and puts operations on notice for the exhibit deadline, but every added recipient increases the chance a privilege fight goes badly and invites correction from someone who was half on the call; sending only to Chen and co-counsel keeps the record clean but leaves Okoro's May 9 deliverable resting on memory. Second: whether the co-defendant question belongs in writing. Recording it documents that you considered it, but it also tells a future reader you were weighing a separate deal. Third: whether to record the board sign-off condition, which is protective of you and slightly embarrassing to Chen.
What would make this materially better. (1) Confirmation of whether $1.85M was the opening or the target: it is the difference between an accurate record and a misstatement of the client's position. (2) Whether the May 7 date is actually cleared with Acme's counsel. (3) The board sign-off timeline, which determines whether the May 2 authority deadline is real.
Why this prompt is built the way it is
## Framework
1. **One headline.** What the meeting decided, in one sentence. If nothing was decided, say that.
2. **Decisions, not discussion.** "We will X" or "Client will X," with the date it takes effect, plus a line recommending a separate memo whenever the decision is material. No narration of the conversation and no characterization of who said what.
3. **Action items with teeth.** Owner by name, date, and a deliverable you could hold up. Open issues get owners too, and the recap closes on the next meeting.
4. **Write for the distribution list.** Strategy, evaluation, and procedural shorthand come out when the send list cannot carry them.