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.
Where the case stands and every date that constrains a filing.
Your side and what the client is actually trying to buy.
Every motion on the table, including the ones you suspect are not worth filing.
The forum and anything you know about how this judge handles motion practice.
Hours, dollars, or people you actually have.
Watch for these throughout
Standing orders and chambers practices control timing, page limits, and pre-motion conference requirements, and they are not in the local rules. Read the judge's own order before you calendar anything.
The model will invent deadlines and page limits that sound plausible. Verify every date against the scheduling order and the docket.
A summary judgment motion that loses on a genuinely disputed fact can spend the credibility you needed for the partial motion that would have capped damages. Sequence accordingly.
Daubert timing varies widely; many judges defer to the final pretrial conference or to trial, which changes when the ruling can affect settlement.
This analysis is work product and reveals what you know and what you fear. Keep it inside the client team and out of anything you might produce.