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Rewrite a draft for a different reader
Rewrites a document for the person who actually has to act on it (judge, GC, board, client) without losing a number, a date, or the privilege.
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Rewritten for the board (one page, ~140 words):
We are asking the board to approve $500,000 in settlement authority for the Reyes matter before the May 14 mediation.
Reyes is a retaliation claim by a former regional manager terminated four days after she reported unpaid overtime to HR. In February we described this case as defensible. That assessment has changed. In her March 12 deposition, our CHRO testified that the CEO directed the termination and that Reyes had never been formally disciplined (Tr. 92:6, 118:21). Both statements are now on the record.
Our trial estimate is $1.4M to $2.1M in compensatory damages, before fees, with a fee-shifting statute in play. Defense costs through trial run roughly $600,000. Mediation on May 14 is our last opportunity to resolve this before expert discovery opens on June 2.
We recommend authority up to $500,000, with an opening posture of $200,000.
What changed and why:
- Opened with the ask. The board's only job here is to approve a number; everything else is support.
- Replaced "prima facie case of retaliation under Title VII" with the four-day gap and the deposition testimony, the facts that made the assessment change.
- Named the February update and said plainly that the assessment moved. Two directors think this case is frivolous; leaving that unaddressed would have lost them.
- Kept every figure at full precision. $1.4M-$2.1M, not "substantial exposure."
What I cut:
- McDonnell Douglas burden-shifting framework: the board does not decide it.
- Discussion of our summary judgment odds: replaced by the cost and calendar consequences that actually bear on the vote.
- Case citations and the errata-sheet analysis.
Fact ledger check: $500,000 authority (carried) · May 14 mediation (carried) · four-day gap (carried) · Tr. 92:6 and 118:21 (carried) · $1.4M-$2.1M (carried) · ~$600,000 defense costs (carried) · June 2 expert deadline (carried) · March 12 deposition date (carried) · 2019 hire date (cut; not decision-relevant).
Assumptions I made. The board has not seen the deposition transcript [verify]. "Trial estimate" in the source meant compensatory damages only, excluding fees [verify - the source is ambiguous and the fee exposure could double this number]. The February update was oral [safe].
Where this is weakest. "That assessment has changed" is the sentence a plaintiff's lawyer would most like to read someday. It is also the sentence that gets the two skeptical directors to vote yes. Second: "our trial estimate is $1.4M to $2.1M" reads as a settled valuation; the source called it preliminary.
What only you can decide. Whether the exposure range goes in the deck at all. Putting $1.4M-$2.1M in writing makes the $500,000 ask look conservative and will likely get you the full authority, but it is a board document, and in a bad-faith or coverage fight it will be read back to you. The alternative is "materially exceeds the requested authority," which protects the record and risks the board approving $250,000. Also yours: the CHRO testimony summary is legal analysis of your own witness. If this deck circulates to the auditor, that paragraph is the exposure.
What would make this materially better. (1) Confirmation the board deck is privileged and how it is distributed. (2) Whether the $1.4M-$2.1M range includes fee-shifting. (3) What the two skeptical directors were told in February, verbatim.
Why this prompt is built the way it is
## Framework
1. **Lead with their decision.** Whatever the reader must do, the sentence that gets them there goes first, even if the original buried it on page three. State the target length before writing, then hit it.
2. **Build a fact ledger first.** Every number, date, dollar figure, deadline, party name, and defined term in the source survives the rewrite unchanged, or the rewrite says why it was cut.
3. **Re-rank and translate for this reader.** A GC needs exposure and next step, a judge needs the standard and the record, a client needs what happens to them and when. Name the concept in their words; keep the legal term only where they will meet it again.
4. **Cut by reader need, and list what you cut.** Never a fact that cuts against you.
5. **Check the privilege line.** If the new reader sits outside the privilege, flag every sentence revealing legal advice, mental impressions, or settlement evaluation. Flag, do not silently delete.