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Turn intake notes into a triage memo
Converts raw consultation notes into a one-page memo that leads with take or decline, computes every deadline from its trigger event, and names each person to run through conflicts before you sign.
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*(After you answer the three questions: the purchase date and the CarFax date are both documented, she consulted another lawyer last week but signed nothing, and she can manage about $1,500 a month and believes the case is worth the car back plus punitives.)*
TAKE WITH CONDITIONS: viable consumer-protection and fraud claims with statutory fee-shifting, conditional on a $4,500 pre-suit retainer given the prospect's stated cash constraints.
The matter. Prospect reports she bought a 2022 Subaru Outback from Tacoma Motors on August 14, 2025 for $32,400, and that the salesperson represented a clean title and one prior owner. A CarFax report her insurance agent pulled on April 19, 2026 shows two prior accidents (one structural) and a salvage brand later reissued as clean. She returned to the dealer on April 22, 2026 and was refused a refund or replacement. She has the bill of sale; the finance documents are with her credit union.
Deadlines: the trigger dates are fixed, the periods are yours to confirm. You did not give me Washington's limitations periods and I will not supply them from memory. Each line is a trigger date plus the arithmetic to run the moment you have the statute open.
- Consumer Protection Act - trigger: purchase, August 14, 2025 (bill of sale). Period: [UNVERIFIED - confirm the RCW 19.86 limitations period, then add it to 8/14/2025].
- Breach of express warranty - trigger: tender of delivery, August 14, 2025. Period: [UNVERIFIED - confirm Washington's UCC Article 2 period, and read the bill of sale for a contractual shortening before you rely on it].
- Fraud - trigger: discovery, April 19, 2026, the date the CarFax was pulled. That date is documented, so run the clock from it and not from her recollection of when she "suspected something." Period: [UNVERIFIED - confirm Washington's fraud discovery-rule period].
- Pre-suit notice: confirm whether a CPA claim in Washington carries any pre-suit notice or agency-filing prerequisite. If one exists it runs on its own clock and it is the earliest date on this page, whatever the limitations periods turn out to be. [UNVERIFIED - check this before you calendar anything else.]
- Demand letter: May 24, 2026. Your own 30-day practice rule, not a statute. Not jurisdictional, but it fixes the fee-shifting record and dates the dealer's refusal.
Claims.
- *Consumer Protection Act:* unfair or deceptive act (salvage-history misrepresentation) + trade or commerce (licensed dealer) + public interest + injury + causation. Missing: proof the dealer knew or should have known; pull the auction record.
- *Fraud:* misrepresentation, materiality, scienter, reliance, damages. Scienter is the empty element. Everything else is in her account and the bill of sale.
- *Revocation of acceptance (UCC 2-608):* substantial impairment, reasonable time, condition unchanged. Confirm she has stopped driving the car; she said she parked it April 22.
Likely defenses. (1) The dealer relied on the title document from the auction: meets scienter, does not meet the CPA. (2) An "as-is" clause in the bill of sale: read the actual document before the demand goes out. (3) Continued use after discovery: her April 22 parking date answers this if it holds.
Conflicts to run. Maya Okonkwo; Tacoma Motors Inc. and any DBA; Sound Credit Union (lienholder); Subaru of America; Northwest Auto Auction; Dana Okonkwo (spouse, co-signer on the finance contract).
Fee. $4,500 flat for the pre-suit phase (records, demand, one mediation session), then 33% contingency plus statutory fees if suit is filed. Realistic total exposure $4,500-$18,000. She said cash is tight: offer three payments of $1,500 over 60 days, first payment before any work begins.
Capacity and fit. Squarely in the practice; the pre-suit phase fits this quarter. Reassess before filing.
Red flags. She mentioned she "almost went with another lawyer last week": confirm in writing that she signed nothing. Her expectation of a full refund plus punitive damages is off; calibrate at engagement.
Next steps. (1) Confirm the four bracketed periods above and calendar them: today, before anything else in this list. (2) Conflicts today. (3) Engagement letter and first $1,500 by Friday. (4) Title history and auction record within 7 days. (5) Demand letter by May 24.
What your answers changed. That the April 19 CarFax is a document rather than her recollection is what fixed the fraud trigger date. Had the discovery date rested only on her memory, this would be a decline pending a records subpoena, because the one deadline I cannot help you with would also have had a soft start. Her answer about cash is what turned a straight contingency into a staged $4,500 flat fee. And your answer that she consulted counsel last week but signed nothing is the entire red-flag section. Without it there would be no red flag on this memo at all.
Why this prompt is built the way it is
## Framework
1. **Lead with the call, then the facts.** TAKE, DECLINE, or TAKE WITH CONDITIONS in the first line with one sentence of reason; hedging across all three is not a triage memo. Restate the matter in plain facts, marking "prospect reports" wherever the prospect is the only source. Everything in intake notes is one-sided until a record confirms it.
2. **Deadlines before merits.** Every limitations period, notice prerequisite, and filing window computed from a named trigger event, earliest first. Where the period was not supplied, bracket it rather than supplying one from memory. "Check the SOL" is not a deadline.
3. **Claims by element, with the hole named.** For each claim: the elements, the fact supporting each, and the element with nothing under it yet. Same treatment for the two defenses you expect.
4. **Conflicts by name, fee with arithmetic, bandwidth in the call.** Prospect, adverse parties and their entities, spouses, employers, insurers, witnesses, referring source. Categories do not run through a conflicts system. Then the fee model with a realistic range and whether this prospect can pay it, at least one red flag or a statement that you looked, and a good case you cannot staff this quarter treated as a referral.