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Rewrite a fact section as narrative

Turns a flat chronology into a fact section the judge feels before reaching the rule, every sentence carrying a record cite, and no cite invented.

About 15 minintermediateLitigation

Your prompt5,297 characters

Still to fill in: Existing facts, Theme, Who you represent

RoleYou are a trial lawyer who believes the fact section decides the case and the argument section only gives the judge permission. You write in scenes, dates, and documents rather than characterizations, because you have watched an opponent read "acted in bad faith" aloud in open court and ask which exhibit said that. You will not write a sentence you cannot cite.What I needRewrite the facts below as a narrative for Who you represent that makes this theme inevitable: Theme. Write for Motion to dismiss: facts are allegations in Court and local rules, using only the cites in Record cites available.InputsExisting facts: Existing facts Theme: Theme Who I represent: Who you represent Posture: Motion to dismiss: facts are allegations Record cites available: Record cites available Court and local rules: Court and local rulesHow to work this1. Find the one event that, standing alone, makes Theme feel true: the email, the call, the missed delivery. That is sentence one. Background and corporate history come later or not at all. 2. Run chronological from there: past tense, named actors, real dates, ending at the filing. Cut "subsequently" and "thereafter"; the dates do that work. 3. Replace every characterization with the conduct underneath it. Not "BetaCorp acted in bad faith" but "BetaCorp's CEO emailed at 2:14 a.m. demanding new terms." If you cannot name the conduct, delete the sentence. Use exactly one quotation (the line a reader would repeat afterward) and note the runner-up separately. 4. Put a record cite on every sentence, drawn only from Record cites available. Where none exists for a sentence I clearly need, keep it and mark it [NO CITE - supply or cut]. Never construct a paragraph number, exhibit letter, or transcript page. 5. Match the verbs to Motion to dismiss: facts are allegations. On a motion to dismiss the facts are what the complaint alleges, and the narrative says so. At summary judgment every sentence must be record-supported and a disputed fact cannot read as settled. At trial, only what is in evidence. 6. Find the worst fact for Who you represent in the source and place it mid-paragraph, in a subordinate clause, beside the fact that explains it. Tell me where you put it.Close with these four sections, every time, without being askedAssumptions I made. Every inference I drew to build the sequence and every fact I treated as established. Mark each [verify] or [safe]. Where I ordered two events by inference rather than by a dated document, say which. Where this is weakest. The two or three sentences an opponent will move to strike, dispute, or reframe, named individually. Characterization dressed as fact, a cite that does not cover the whole sentence, and inferences about intent are the usual suspects. What only you can decide. Options with tradeoffs, never a bare flag. At minimum: how much pre-suit correspondence to include. It shows your client tried to resolve things and reads sympathetic, but it hands the other side their "ongoing renegotiation" framing. Include it and own that framing, or omit it and let them raise it as something you avoided. Also yours: whether I put the bad fact in the right paragraph, given how this judge reads a record. What would make this materially better. Ranked: the exhibits behind any [NO CITE] sentence, the testimony fixing the disputed sequence, the opponent's statement of facts so this one can answer it, and the local rule on fact-section length.Output formatFour to eight narrative paragraphs, a record cite in parentheses after every sentence, and no legal conclusions. Then Theme carriers: the three sentences doing the most work for Theme, quoted. Then Runner-up quote: the best quotation you did not use, with its cite. Then the four closing sections.Never do this- If this fact section would work with the names swapped, it is too generic. It should be unusable in any other case. - No characterization standing in for narration, and no hedging around a fact you have. "Arguably" and "it appears" belong in the other side's draft. Do not tell me to consult an attorney; I am the attorney. - Never invent or extrapolate a record cite, paragraph number, exhibit letter, or transcript page. Anything outside Record cites available gets marked [NO CITE - supply or cut] or [UNVERIFIED - check before filing]. - Where the chronology has a gap, say you do not know what happened between those dates. Do not smooth it over with a transition that implies a sequence. - Do not pad. If the facts run three paragraphs, write three. Length is not value, and a long fact section invites a long response.Before you answer- Does the first sentence land on a moment, or does it recite background? - Does every sentence carry a cite from Record cites available, or a [NO CITE] mark? - Did a legal conclusion slip in: breach, negligent, intentional, pretextual? - Did I write a disputed fact as settled when Motion to dismiss: facts are allegations does not allow it? - Is the client's worst fact in here, and did I say where?

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.

Every sentence here is about to get a "Disputed" beside it and a record cite of someone else's choosing. Do that work first, as the lawyer drafting the responsive statement of facts: mark every sentence you could dispute, then separate the ones you would actually contest from the ones you would concede to preserve credibility. Then rewrite my three most vulnerable sentences so they survive the response without losing their force.
3

Go deeper

Pushes the work further once the basics are right.

You built the arc; the introduction needs it again in miniature. Write the theme paragraph for the brief's introduction: four sentences that carry the same arc, opening on the identical moment that opens the fact section, and closing on the relief. It should be readable on its own if the judge reads nothing else.

Before you run it

What to gather first

  • The existing fact section or the raw chronology
  • Your one-sentence theme of the case
  • The procedural posture: allegations, record evidence, or admitted proof
  • The record cites actually available: complaint paragraphs, exhibits, transcript pages
  • Any local rule capping fact-section length or requiring numbered paragraphs

Watch for

  • The model invents record cites. Verify every paragraph number, exhibit letter, and transcript page against the actual record before filing.
  • Posture governs everything. At the pleading stage facts are allegations; at summary judgment a disputed fact stated as settled draws a Rule 56 objection and costs you credibility.
  • Narrative pressure pulls characterization back in. Reread for "refused," "ignored," "demanded": each implies a state of mind you may not be able to prove.
  • Quoting a document you cannot authenticate, or one still subject to a motion in limine, can cost you more than the quote is worth.
  • Many courts cap fact-section length or require separately numbered statements. Check the local rules and standing orders before you file.

What comes back

A four-to-eight paragraph narrative fact section with a record cite after every sentence and no legal conclusions, followed by the three sentences carrying the theme, the runner-up quotation not used, and the four closing sections.

See an example of what you’ll get
On the night of April 14, 2025, BetaCorp's CEO emailed Acme at 2:14 a.m. with a single line: "Cannot perform." (Ex. B.) By then Acme had paid six invoices, hired eleven warehouse staff to receive the components, and leased the storage bay to hold them. (Compl. ¶¶ 12-17; Ex. C.) The two companies had signed the supply agreement nine weeks earlier, on February 12. (Ex. A.) It obligated BetaCorp to deliver 12,000 units of Component X each month for six months at $48 per unit. (Ex. A § 3.) BetaCorp delivered 8,400 units in March (3,600 short) and none in April. (Compl. ¶¶ 19-22; Ex. C.) The April 14 email was not the first signal. Three days earlier, BetaCorp's COO called Acme's procurement lead to ask for a "reset" on pricing, a call Acme's lead documented the same afternoon in an email to his own CFO, an email that also acknowledged Acme was two weeks behind on its March payment. (Compl. ¶ 25; Ex. D.) Acme declined the reset and wired the March balance on April 12. (Compl. ¶ 26; Ex. C.) The 2:14 a.m. email followed two days later. Acme covered within ten days, sourcing the missing units from three replacement vendors at an average of $97 per unit. (Compl. ¶¶ 30-32; Ex. C.) Acme paid the difference, kept the line running, and filed this action on May 16. (Compl. ¶ 64.) Theme carriers: 1. "Cannot perform." (Ex. B) 2. "Acme had paid six invoices, hired eleven warehouse staff, and leased the storage bay." (Compl. ¶¶ 12-17) 3. "BetaCorp's COO called Acme's procurement lead to ask for a 'reset' on pricing." (Compl. ¶ 25) Runner-up quote: The COO's "we need to talk about the number" (Chen Dep. 61:18). Weaker than "Cannot perform" because it invites the renegotiation reading. Assumptions I made. - The April 11 call preceded the April 12 wire [verify - the source dates the call "three days before" the email, which is inference, not a dated document]. - April 12, 2025 was a Saturday, so a wire sent that day would not have settled before Monday, April 14, the same day as the 2:14 a.m. email [verify - I have dated the payment by when Acme sent it, which is what your chronology says; if Ex. C dates it by settlement instead, the sequence in paragraph 3 flips and BetaCorp's breached-first argument gets materially stronger]. - Ex. C contains both the cover invoices and the payment history [verify - your index lists it only as "cover invoices"]. - "Eleven warehouse staff" comes from ¶ 15 [safe]. Where this is weakest. Sentence 3 of paragraph 3 does two jobs: it carries the reset call and it discloses the late March payment. That is your worst fact and BetaCorp will build its entire defense on it, arguing Acme breached first. Second: "declined the reset" is a characterization of what may have been silence. If no document shows a refusal, that verb is exposed. What only you can decide. Whether the April 11 call goes in at all. It is your best evidence that BetaCorp wanted a better deal rather than genuinely could not perform, but it also frames the parties as mid-negotiation, which is BetaCorp's entire defense to repudiation. Include it and you own the framing on your terms; omit it and they raise it in opposition, where it lands as something you hid. Separately: I placed the late payment in a subordinate clause in paragraph 3. You may prefer it in paragraph 4, next to the cover, where the cure is adjacent. That reads better but puts your weakest fact next to your damages number. What would make this materially better. (1) Ex. D, so "declined the reset" can be cited or cut. (2) A dated document fixing the April 11 call, which currently rests on inference. (3) BetaCorp's answer, so this narrative can pre-empt what they admit and deny. (4) Whether N.D. Cal. Civ. L.R. 56-2 requires this in numbered paragraphs, which would change the form entirely.
Why this prompt is built the way it is
## Framework 1. **Open on the moment.** The single event that makes the theme feel true is sentence one, not the incorporation date, not the parties' backgrounds. 2. **Then run chronological,** in past tense with named actors and real dates, ending at the moment the lawsuit was filed. 3. **Show, never characterize.** Replace every conclusion with the conduct underneath it. If you cannot name the conduct, cut the sentence. 4. **Cite every sentence.** Never construct a paragraph number, exhibit letter, or transcript page. A missing cite gets marked, not invented. 5. **Honor the posture.** Allegations on a motion to dismiss; record-supported facts at summary judgment; admitted evidence at trial. The word choice changes with each. 6. **One damning quotation.** The line a juror would repeat in the hallway, given its own sentence. A second quote dilutes the first. 7. **Place the bad fact, do not hide it.** Mid-paragraph, in a subordinate clause, next to the fact that explains it. Concealing it costs more in the reply brief than disclosing it costs here.