Rohas Legal AI: Litigation

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---
name: appeal-grounds-drafter
description: >-
  Draft and review grounds of appeal tied to challenged findings, preserved
  errors, the applicable standard of review, the record, prejudice, and relief.
  Use for civil, commercial, administrative, tribunal, or other appellate matters.
---

# Appeal Grounds Drafter

Draft grounds that identify an appealable error and its consequence. Do not use
an appeal as an unstructured retrial or introduce material outside the record
without a recognised procedural basis.

## Intake

Obtain the jurisdiction, appellate route, challenged judgment or order, decree,
reasons, lower record, pleadings, evidence, transcripts, objections, submissions,
issues, dates of decision and service, limitation position, permission or
certificate requirements, existing stay, client objective, and relief sought.

## Drafting method

1. Verify the appeal lies to the proposed forum, who may appeal, whether leave is
   required, which orders are appealable, and the current filing and service deadline.
2. Build a finding-and-record table: challenged paragraph, finding, issue, party's
   case below, supporting material, contrary material, objection, and preservation.
3. Identify the governing standard for each issue: law, fact, discretion,
   procedure, jurisdiction, mixed question, or constitutional review.
4. Classify the proposed error precisely: wrong test, misconstruction, irrelevant
   consideration, ignored material evidence, no evidence, procedural unfairness,
   inadequate reasons, excess of jurisdiction, perversity, or abuse of discretion.
5. Distinguish an adverse outcome from reversible error. Explain materiality,
   prejudice, and why the result or process may have differed.
6. Address harmless-error, waiver, acquiescence, invited-error, preservation,
   alternative-basis, mootness, and finality objections.
7. Draft one proposition per numbered ground. Cite the challenged finding and
   record locator without pleading evidence or argument at excessive length.
8. Separate grounds requiring permission, new evidence, additional findings,
   remand, rehearing, substitution, variation, costs, or interim stay.
9. Test every ground against the judgment as a whole and against the respondent's
   strongest answer.
10. Reconcile the notice, grounds, prayer, chronology, record citations, and
    proposed order.

## Output

Provide a jurisdiction and deadline note, finding-and-error matrix, draft grounds,
preservation and standard-of-review table, record gaps, relief analysis, and
filing checklist.

## Guardrails

Do not invent preservation, quote the record inaccurately, recast factual
disagreement as legal error, or omit adverse reasoning. Do not assume a notice,
review, revision, intra-court appeal, statutory appeal, or special-leave route is
interchangeable. Require appellate counsel to verify current rules and deadlines.

Referenced files: 1

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---
name: case-law-analyst
description: >-
  Turn judgments into source-verified case notes covering procedural posture,
  material facts, issues, holdings, ratio, obiter, separate opinions, treatment,
  and application. Use when researching, citing, comparing, distinguishing, or
  updating judicial authorities.
---

# Case Law Analyst

Read the full authoritative judgment, not a headnote or search snippet. Separate
what the court decided from what a party argued or a later summary says.

## Intake

Obtain the legal question, jurisdiction, court hierarchy, decision date, citation,
full judgment and separate opinions, procedural history, later treatment, relevant
statutory version, intended proposition, and citation or filing format.

## Analysis method

1. Verify the judgment, neutral or official citation, court, bench, date, parties,
   disposition, publication status, and authoritative text.
2. State the procedural posture and the questions the court had power to decide.
3. Extract only facts material to each issue and identify disputed or assumed facts.
4. Frame the issue at the level of specificity actually resolved.
5. Record the order or outcome separately from the reasons.
6. Identify the holding and trace the necessary reasoning that supports it.
   Distinguish ratio from dicta, illustrations, assumptions, concessions, and
   fact-specific observations.
7. Treat majority, plurality, concurrence, dissent, and per curiam reasoning
   separately. Do not combine propositions lacking a controlling majority.
8. Quote sparingly with pinpoint references and preserve qualifying language.
9. Check subsequent history, appeal, affirmance, reversal, overruling, statutory
   amendment, negative treatment, and jurisdictional weight as of the research date.
10. Compare the authority's material facts, issue, rule, policy, and posture with
    the present matter; explain application and distinction.
11. List unresolved questions and authorities the court considered, followed, or
    rejected where material.

## Output

Provide citation and status, procedural posture, material facts, issues, outcome,
holding and ratio, obiter, opinions, key pinpoint passages, later treatment,
application, distinctions, and a concise proposition the case safely supports.

## Guardrails

Do not fabricate a citation, quote, pinpoint, treatment, or proposition. Do not
call a persuasive authority binding or treat a dissent as the holding. Verify
live status in an authoritative citator or official source before filing and
flag paywalled, incomplete, translated, redacted, or unofficial texts.

Referenced files: 1

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---
name: chronology-builder
description: >-
  Build source-linked litigation chronologies from pleadings, correspondence,
  records, evidence, filings, and testimony. Use when reconstructing events,
  knowledge, notice, accrual, procedural history, delay, causation, or evidential gaps.
---

# Chronology Builder

Create a reproducible chronology, not a persuasive narrative disguised as data.
Keep event time, document time, filing time, receipt time, and asserted knowledge distinct.

## Intake

Obtain the issues and date range, document set, metadata, time zones, pleadings,
witness accounts, procedural docket, naming conventions, disputed dates,
limitation questions, and requested level of detail.

## Building method

1. Create stable source IDs and preserve native dates, time zones, page or
   paragraph locators, authors, recipients, and document relationships.
2. Extract dates without silently converting an estimate, range, relative phrase,
   metadata field, signature date, or later recollection into a certain event date.
3. Create separate fields for event, creation, sent, received, filed, served,
   discovered, and recorded dates where they differ.
4. Normalise display dates and times while retaining the source value.
5. Attribute every entry to a source and label direct evidence, reported account,
   inference, allegation, agreed fact, judicial finding, and procedural event.
6. Deduplicate copies without losing annotations, attachments, versions,
   forwarding chains, or contradictory metadata.
7. Link cause and response sequences, notice, opportunity, decision, performance,
   breach, damage, mitigation, and procedural consequences only where supported.
8. Record conflicting dates and accounts side by side. State the basis and
   confidence of any proposed resolution.
9. Identify unexplained gaps, missing attachments, absent periods, clock drift,
   impossible sequence, late-created records, and discovery or preservation needs.
10. Produce focused views for limitation, witness preparation, pleadings,
    submissions, disclosure, damages, and hearing bundles without changing the master.

## Output

Provide a master chronology with date, event, actor, source, locator, status,
confidence, issue tags, and notes; plus conflict, gap, and key-date schedules.

## Guardrails

Do not infer that a document was sent, received, read, agreed, or acted on merely
because it exists. Do not overwrite uncertainty or privilege labels. Protect
personal and confidential data and ensure exported chronologies remain traceable
to preserved sources.

Referenced files: 1

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---
name: cross-examination-planner
description: >-
  Plan ethical, issue-led cross-examination grounded in testimony, documents,
  contradictions, perception, memory, bias, and admissible impeachment material.
  Use for civil, criminal, arbitration, tribunal, or administrative hearings.
---

# Cross-Examination Planner

Plan propositions and evidential destinations, not a script that assumes the
witness will cooperate. Apply current forum rules, professional duties, and
special protections for vulnerable witnesses.

## Intake

Obtain the issues and burden, witness statements and prior accounts, pleadings,
depositions or transcripts, exhibits, disclosed convictions or bias material,
expert reports, admissibility rulings, examination time, interpreter or
accommodation needs, prohibited topics, and the theory of the case.

## Planning method

1. Define the one-sentence forensic objective for each issue and whether the
   witness can advance, limit, or undermine it.
2. Build a proposition-to-proof table linking each intended proposition to an
   admission, document, prior statement, another witness, expert material, or
   permissible inference.
3. Analyse opportunity to observe, perception, memory, recording, communication,
   consistency, interest, bias, capacity, expertise, and limits of knowledge.
4. Separate genuine contradiction, omission, development, ambiguity, translation,
   refreshed memory, and difference in emphasis.
5. Sequence short topics from safe foundation to material proposition. Use one
   fact per question and reserve open questions for a deliberate purpose.
6. Prepare exhibit foundations, exact prior-statement locators, required
   confrontation steps, authenticity, completeness, context, and fallback proof.
7. Anticipate explanation, rehabilitation, objection, adverse ruling, denial,
   inability to recall, and the point at which to stop.
8. Distinguish credibility impeachment from impermissible character attack.
9. Plan sensitive questioning with necessity, proportionality, trauma awareness,
   privacy, support, breaks, intermediaries, and judicial directions.
10. End each topic after securing the useful answer or establishing the
    contradiction; avoid arguing with the witness.

## Output

Provide objectives, issue and proposition map, topic sequence, key questions,
document and prior-statement references, expected answers, follow-ups, objections,
fallback proof, time budget, and points to preserve for submissions.

## Guardrails

Do not coach false evidence, intimidate, humiliate, harass, misstate the record,
conceal context, or ask a question lacking a good-faith basis. Do not expose
protected identities or privileged material. Adapt to forum limits and obtain
trial counsel review before use.

Referenced files: 1

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---
name: disclosure-request-drafter
description: >-
  Drafts targeted requests for disclosure, discovery, inspection, production,
  interrogatories, admissions, or further information in litigation or similar
  proceedings. Use when requests must be tied to pleaded issues, custodians,
  sources, time periods, proportionality, format, metadata, privilege, objections,
  deadlines, or a meet-and-confer process.
---

# Disclosure Request Drafter

Draft enforceable, proportionate requests that seek information needed to resolve
identified issues rather than conducting an unsupported fishing exercise.

## Intake

Obtain the jurisdiction, forum and current rules or order; pleadings and live
issues; burdens and defences; existing disclosures; disputed requests and
responses; known custodians, systems and date ranges; search or technology
protocols; confidentiality arrangements; privilege position; deadlines; and the
purpose for which each requested category is needed.

Do not assume that common-law discovery, civil-law disclosure, arbitration
document production, regulator demands, and criminal disclosure use the same
test, terminology, scope, or remedy.

## Method

1. Build an issue-and-element map before drafting. Link every request to a pleaded
   allegation, defence, remedy, credibility issue, or defined procedural purpose.
2. Select the correct procedural device and recipient. Separate document requests,
   inspection, interrogatories, admissions, particulars, third-party process, and
   informal requests.
3. Define documents and electronically stored information precisely, including
   date range, custodian, system, subject, document family, version, attachment,
   communication channel, structured-data fields, native format, and metadata only
   where justified.
4. Use objectively testable language. Avoid vague terms such as "relating to" or
   "all documents" unless narrowed by a clear subject and proportional scope.
5. For each request, record relevance, expected source, burden, likely objection,
   narrower fallback, and why another source is inadequate or less efficient.
6. Address preservation, reasonable search, deduplication, threading, families,
   date and time zones, OCR, load files, numbering, confidentiality designations,
   redactions, privilege logs, clawback, and rolling production only as the actual
   procedure permits.
7. Reconcile requests against material already supplied. Do not demand duplicates
   without explaining the missing version, attachment, metadata, or completeness
   issue.
8. Draft response and objection deadlines from verified rules or orders. Show the
   source and calculation; do not infer extensions or holiday treatment.
9. Prepare a focused deficiency and meet-and-confer agenda before seeking relief.
   Preserve agreements, disputed points, proportional compromises, and next steps.

## Output

Provide the issue-to-request matrix, numbered draft requests, definitions and
instructions, format and metadata schedule, proportionality record, anticipated-
objection table, narrower fallback set, deadline note, and meet-and-confer agenda.

## Guardrails

Do not request privileged, protected, irrelevant, oppressive, illegally obtained,
or unnecessarily sensitive material. Do not represent that a request is permitted
or compulsory without the governing procedure. Preserve adverse material and do
not use disclosure demands to harass, expose protected identities, or bypass
privacy, secrecy, employment, blocking-statute, or cross-border restrictions.

Referenced files: 1

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---
name: document-review-protocol-builder
description: >-
  Designs defensible document-review protocols for litigation, arbitration,
  investigations, or regulatory productions. Use when defining review population,
  responsiveness and issue codes, privilege and confidentiality treatment,
  document families, technology-assisted review, reviewer instructions, sampling,
  quality control, escalation, or production readiness.
---

# Document Review Protocol Builder

Create a repeatable protocol that different reviewers can apply consistently and
that preserves a review decision's source, reason, and quality-control history.

## Intake

Obtain the mandate, jurisdiction and procedural orders, pleadings and issues,
collection map, review population and processing report, requested categories,
search methodology, technology platform, document languages, confidentiality
regime, privilege law and client structure, production specifications, team roles,
deadline, budget, and known high-risk custodians or subjects.

## Method

1. Define the review universe and exclusions. Reconcile collected, processed,
   deduplicated, promoted, excluded, corrupted, encrypted, and unreviewable items.
2. Translate the issues and requests into concise responsiveness, issue,
   confidentiality, personal-data, hot-document, and technical-problem codes.
   Give inclusion, exclusion, and boundary examples without inventing case facts.
3. Define family treatment for emails and attachments, duplicates, near-duplicates,
   threads, loose files, embedded objects, containers, versions, translations, and
   structured data.
4. State the applicable privilege categories and required facts. Create separate
   paths for withheld documents, redactions, potentially privileged material,
   privilege exceptions, common-interest or joint-client issues, and inadvertent
   production. Do not infer privilege from lawyer involvement alone.
5. Define escalation triggers for unclear scope, novel issues, personal or secret
   data, technical failure, potential crime-fraud or equivalent exceptions,
   inconsistent family coding, and material adverse documents.
6. Specify reviewer training, calibration, decision notes, coding permissions,
   batching, re-review, audit trail, productivity reporting, and conflict controls.
7. Build quality control using reasoned samples: random and targeted checks,
   confidence or error reporting where supported, senior review, disagreement
   resolution, corrective action, and re-sampling. Do not claim statistical
   assurance without a valid design and complete figures.
8. If analytics or technology-assisted review is used, document objectives,
   inputs, validation, sampling, stopping criteria, limitations, human oversight,
   version changes, and reproducibility. Do not describe opaque scores as truth.
9. Define production readiness: responsiveness, family completeness, privilege,
   redaction, confidentiality, metadata, numbering, format, exception handling,
   and final sign-off.

## Output

Provide the protocol, coding dictionary, decision tree, issue-and-request map,
privilege and redaction rules, reviewer escalation matrix, training examples,
quality-control plan, exception log, production gate, and change-control record.

## Guardrails

Do not instruct reviewers to suppress adverse or inconvenient material, encode
legal conclusions unsupported by counsel, disclose privileged review notes, or
permit automated tools to make unreviewed dispositive decisions. Protect reviewer
access, client confidentiality, personal data, source material, and audit logs.

Referenced files: 1

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---
name: evidence-organizer
description: >-
  Organise physical, documentary, digital, demonstrative, witness, and expert
  evidence against disputed facts and legal elements. Use for case preparation,
  disclosure, admissibility review, hearing bundles, proof charts, or evidence gaps.
---

# Evidence Organizer

Build an issue-to-proof system in which every item retains provenance, custody,
authenticity, admissibility, privilege, and source locators.

## Intake

Obtain the jurisdiction and forum, pleadings and issues, elements and burdens,
disclosure orders, evidence inventory, custody and metadata, witness and expert
materials, objections, confidentiality restrictions, bundle rules, and trial plan.

## Organisation method

1. Preserve originals and assign stable IDs to each item, version, attachment,
   extract, demonstrative, and derivative.
2. Record source, custodian, collection method, date, time zone, integrity checks,
   confidentiality, privilege, production number, and page or media locator.
3. Create a fact-and-element matrix showing burden, standard, supporting evidence,
   contrary evidence, agreed facts, admissions, and missing proof.
4. Describe what each item directly proves, what inference is requested, and
   alternative explanations. Do not label relevance as truth.
5. Identify the sponsoring witness or other foundation for authenticity,
   completeness, custody, personal knowledge, business records, expert opinion,
   digital evidence, translations, summaries, and demonstratives.
6. Test forum-specific objections and exceptions: relevance, prejudice,
   hearsay, opinion, character, privilege, without-prejudice protection,
   best-evidence or original-document rules, notice, and late disclosure.
7. Link contradictions and corroboration across pleadings, testimony, documents,
   metadata, physical items, and expert material.
8. Separate admissibility from weight and disputed authenticity from proven falsity.
9. Build hearing and witness views without changing the master evidence register.
10. Track proposed redactions, confidentiality measures, objections, rulings,
    admissions, agreed bundles, and exhibit status through the hearing.

## Output

Provide the master register, element-to-proof chart, witness and foundation map,
admissibility and objection schedule, contradiction matrix, gap list, exhibit
list, and bundle or hearing index.

## Guardrails

Do not alter originals, break custody, waive privilege, disclose protected
material, suppress exculpatory evidence, or assume production means admissibility.
Flag illegal collection, integrity failures, missing context, and specialist
forensic or expert needs immediately.

Referenced files: 1

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---
name: interim-application-drafter
description: >-
  Draft evidence-backed applications for interim injunctions, stays,
  preservation, disclosure, security, attachment, receivership, interim payment,
  or other temporary relief. Use when urgency, notice, candour, undertakings,
  proportionality, and a workable draft order are central.
---

# Interim Application Drafter

Draft for the actual relief and current procedural route. Treat without-notice,
freezing, search, anti-suit, and other exceptional orders as specialist matters.

## Intake

Obtain the forum and jurisdiction, live or proposed proceeding, pleaded right,
target conduct or asset, evidence, chronology, urgency, notice history, status
quo, harm, balance, respondent impact, third parties, undertakings, security,
parallel proceedings, service logistics, and requested duration.

## Drafting method

1. Verify jurisdiction, power, standing, procedural vehicle, filing rules,
   notice requirement, service, evidence form, fee, deadline, and appeal or review route.
2. State the precise legal test and map each limb to admissible evidence.
3. Explain urgency with dated events and why ordinary case management is inadequate.
4. Define the status quo and distinguish preventable interim harm from harm
   remediable by damages, final relief, or a narrower measure.
5. Assess merits only to the degree required by the applicable test.
6. Address adequacy of damages, irreparable harm, balance of convenience or
   hardship, public interest, delay, clean hands, proportionality, and third-party effects.
7. For without-notice relief, explain why notice is impracticable or self-defeating,
   make full and frank disclosure of material adverse facts, and propose prompt return.
8. Offer required undertakings, cross-undertakings, security, preservation,
   reporting, carve-outs, supervision, confidentiality, and duration.
9. Draft an order that is clear, enforceable, no broader than necessary, and
   workable for parties, banks, platforms, custodians, and third parties.
10. Align the application, affidavit or statement, exhibits, chronology,
    authorities, oral note, service plan, and draft order.

## Output

Provide the application, supporting-evidence outline, legal-test matrix,
urgency and notice note, adverse-fact schedule, undertakings, draft order,
service plan, hearing checklist, and return-date calendar.

## Guardrails

Do not conceal adverse facts, exaggerate urgency, seek punitive restraints, or
use interim process for improper leverage. Do not request asset restraint,
search, disclosure, or speech restrictions without a clear legal basis and
specialist review. Recheck local rules and judge-specific directions before filing.

Referenced files: 1

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---
name: legal-hold-planner
description: >-
  Plans defensible preservation and legal-hold measures for anticipated or active
  disputes, investigations, regulatory matters, or disclosure obligations. Use
  when identifying custodians and data sources, defining preservation scope,
  drafting hold notices, suspending deletion, monitoring compliance, documenting
  collection, or deciding when a hold may be narrowed or released.
---

# Legal Hold Planner

Build a proportionate, auditable preservation plan without deciding that every
potentially relevant item must be collected or produced.

## Intake

Obtain the jurisdiction and forum, trigger event and date, claims or issues,
parties, relevant period, known custodians, information systems, devices,
third-party repositories, routine deletion settings, existing holds, applicable
orders or protocols, responsible legal and IT personnel, and any cross-border,
employment, privacy, secrecy, privilege, or regulatory constraints.

Treat the preservation trigger, governing duties, scope, and release standard as
jurisdiction-specific. If an immediate deletion risk exists, lead with interim
steps that preserve material without altering or over-collecting it.

## Method

1. State the event that may trigger preservation, the decision owner, the date
   the duty may have arisen, and every legal or factual uncertainty.
2. Translate the live issues into a preservation scope covering subjects, date
   ranges, people, organisations, systems, locations, file types, communications,
   structured data, physical records, and ephemeral or automatically deleted data.
3. Build a custodian-and-source map. Distinguish possession, custody, control,
   technical access, ownership, and third-party control rather than treating them
   as interchangeable.
4. Identify routine deletion, rotation, overwriting, device replacement, account
   closure, auto-delete, backup expiry, and business processes that require a
   documented suspension or exception.
5. Draft clear notices stating purpose, scope, examples, prohibited actions,
   acknowledgement, questions, confidentiality, update duties, and contact point.
   Do not disclose privileged strategy unnecessarily.
6. Define acknowledgement, reminder, interview, escalation, departure, new-
   custodian, system-change, and compliance-check procedures with owners and dates.
7. Preserve provenance and integrity during collection. Record source, custodian,
   method, operator, date, time zone, filters, exceptions, hashes where suitable,
   chain of custody, and any transformation.
8. Reassess scope after pleadings, orders, interviews, settlements, or new facts.
   Record every expansion, narrowing, and release decision and its authority.
9. Plan release only after counsel confirms that relevant duties, appeals,
   investigations, contractual holds, and overlapping matters have ended.

## Output

Provide a trigger memorandum, issue-to-scope map, custodian-and-source register,
deletion-risk table, hold notice, acknowledgement and reminder plan, collection
and exception log, compliance dashboard, reassessment schedule, and release
checklist. Mark assumptions and unverified legal propositions conspicuously.

## Guardrails

Do not delete, alter, conceal, backdate, or selectively preserve evidence. Do not
promise that a hold creates privilege, suspend systems without authorised IT and
business review, or collect entire accounts merely because preservation is broad.
Escalate suspected spoliation, inaccessible encrypted data, departed custodians,
personal devices, sanctions exposure, or conflicts between preservation and law.

Referenced files: 1

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---
name: limitation-checker
description: >-
  Identify and calculate competing limitation, prescription, repose, appeal,
  review, and procedural deadline scenarios. Use when dates, cause-of-action
  characterisation, accrual, knowledge, continuing breach, exclusion, suspension,
  extension, acknowledgement, fraud, disability, service, or forum choice matter.
---

# Limitation Checker

Treat limitation as an urgent legal analysis, not calendar arithmetic. Use the
law and procedural rules in force for the claim, forum, party, and relevant date.

## Intake

Obtain jurisdiction and forum, proposed causes and relief, parties and capacities,
event chronology, accrual and knowledge facts, contracts, notices, acknowledgements,
payments, fraud or concealment, disabilities, insolvency or moratoria, mediation
or pre-action steps, prior proceedings, foreign elements, decision and service
dates, filing method, holidays, and current procedural status.

## Checking method

1. Identify every plausible characterisation of the claim, application, appeal,
   review, enforcement step, counterclaim, contribution claim, and remedy.
2. Locate the current controlling statute, schedule, rule, contractual period,
   transitional provision, local amendment, and binding authority.
3. Determine the triggering event for each scenario: act, breach, loss, refusal,
   demand, termination, discovery, knowledge, continuing wrong, judgment,
   decree, service, or another event.
4. Build a sourced date table and keep event, knowledge, notice, filing, issue,
   service, and receipt dates separate.
5. Apply the jurisdiction's counting rules, excluded first or last day, court
   closure, electronic filing cut-off, time zone, leap year, and service deeming rules.
6. Test accrual, latent damage, discoverability, fraud, concealment, mistake,
   disability, minority, trust, acknowledgement, part payment, continuing wrong,
   exclusion, suspension, tolling, standstill, moratorium, and extension doctrines.
7. Analyse prior defective or wrong-forum proceedings, amendment, relation back,
   substitution, counterclaims, set-off, and restoration where relevant.
8. Calculate conservative, primary, and alternative deadline scenarios and show
   the formula, assumptions, and authority for each.
9. Identify steps that preserve rights now without assuming an extension will be granted.
10. Escalate any date within the urgent window or any missing fact capable of
    moving the deadline.

## Output

Provide a live deadline alert, claim-characterisation table, source chronology,
authority matrix, calculations, extension and exclusion analysis, assumptions,
evidence gaps, and immediate filing or preservation steps.

## Guardrails

Never guarantee that a claim is in time, rely on a diary date without legal
verification, or assume negotiation, complaint, mediation, acknowledgment, or
refiling stops time. Do not let further research delay protective filing. Require
qualified local counsel to confirm all dispositive deadlines.

Referenced files: 1

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---
name: pleadings-analyst
description: >-
  Analyse claims, defences, replies, counterclaims, amendments, and particulars
  for causes of action, admissions, denials, inconsistencies, missing facts,
  affirmative defences, burdens, and issues for determination. Use during early
  case assessment, amendment, disclosure, witness preparation, or trial planning.
---

# Pleadings Analyst

Read the operative pleadings paragraph by paragraph and preserve the difference
between allegation, admission, denial, non-admission, positive case, and evidence.

## Intake

Obtain the jurisdiction and forum, all pleading versions, filing and service
dates, orders and amendments, causes of action and relief, contracts or statutes
incorporated by reference, particulars, admissions, procedural rules, limitation
position, and the client's current factual instructions.

## Analysis method

1. Identify the operative version, parties, capacities, jurisdictional basis,
   procedural posture, verification, and relief claimed.
2. Break each cause, defence, counterclaim, and reply into required elements,
   burden, standard, and pleaded material facts.
3. Map every numbered allegation to the responsive paragraph and classify the
   response as admission, partial admission, denial, non-admission, avoidance,
   inconsistent alternative, or no response.
4. Distinguish a material fact from evidence, law, submission, conclusion, and remedy.
5. Identify missing elements, inadequate particulars, ambiguity, internal
   contradiction, impermissible general denial, departure, new matter, and
   inconsistency across related proceedings.
6. Record formal and deemed admissions, concessions, notices to admit, and facts
   not genuinely disputed, subject to current forum rules.
7. Test standing, capacity, jurisdiction, limitation, conditions precedent,
   causation, loss, mitigation, affirmative defences, set-off, contribution,
   counterclaim, and available relief.
8. Link each live factual proposition to evidence, witness, disclosure request,
   expert issue, and evidential gap.
9. Identify amendment, strike-out, summary disposition, particulars, reply,
   joinder, bifurcation, or issue-narrowing options without assuming availability.
10. Draft neutral issues for determination that reflect both parties' cases.

## Output

Provide a pleading map, element-and-burden table, admission and denial schedule,
inconsistency list, missing-fact and particulars list, live-issue matrix,
evidence and disclosure plan, and procedural recommendations.

## Guardrails

Do not treat allegation as evidence, silence as admission without a verified
rule, or alternative pleading as factual dishonesty. Do not overlook superseded
versions, amendments, privilege, confidentiality, sanctions, or verification
duties. Confirm local pleading standards and deadlines before action.

Referenced files: 1

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---
name: privilege-log-builder
description: >-
  Builds and audits privilege or withheld-document logs for litigation,
  arbitration, investigations, and regulatory productions. Use when identifying
  potentially privileged material, recording defensible claim elements, handling
  document families and redactions, testing waiver or exceptions, reconciling a
  log to a production, or responding to challenges to privilege claims.
---

# Privilege Log Builder

Create a factually supportable log that permits evaluation of each asserted basis
without revealing the protected communication or work product itself.

## Intake

Obtain the governing jurisdiction and forum, procedural rules and orders, parties
and client structure, relevant legal advisers and roles, applicable privilege or
protection categories, document population, review decisions, family relationships,
production and redaction data, confidentiality arrangements, clawback terms,
challenge procedure, deadlines, and any categorical-log agreement.

Treat the governing law and required log fields as blocking for a final log. A
draft may proceed with conspicuous placeholders and verification flags.

## Method

1. Identify every potentially applicable protection and its required elements.
   Distinguish legal-advice privilege, litigation or work-product protection,
   without-prejudice material, joint or common-interest arrangements, regulatory
   protections, and confidentiality; do not collapse them into "privileged."
2. Verify the actors, their capacities, client relationship, purpose, recipients,
   confidentiality, legal context, and document date from evidence rather than
   names, domains, titles, or copied lawyers alone.
3. Assign stable document IDs and preserve family, thread, duplicate, near-
   duplicate, attachment, version, redaction, and production relationships.
4. Draft neutral descriptions that explain the general subject and protected
   purpose without revealing advice, strategy, mental impressions, or substance.
5. Record the precise asserted basis, supporting facts, withholding or redaction
   status, confidentiality basis, and reviewer or counsel approval. Separate mixed-
   purpose material and non-privileged attachments where required.
6. Test waiver, broad distribution, third-party presence, forwarding, dominant or
   primary purpose, client identity, advice capacity, in-house counsel role,
   litigation anticipation, crime-fraud or equivalent exceptions, and governing-
   law uncertainty. Flag; do not decide unsupported facts.
7. Apply categorical, metadata-minimal, or exception treatments only where an
   order, agreement, or applicable rule supports them.
8. Reconcile the log to withheld documents, redacted productions, slip sheets,
   numbering, families, and production totals. Identify orphans and inconsistent
   decisions.
9. Prepare challenge responses by linking each disputed entry to its evidence and
   legal elements, while preserving protected content.

## Output

Provide the privilege log, basis-and-elements key, family reconciliation, waiver
and exception flags, inconsistent-treatment report, missing-facts queue, production
reconciliation, challenge-response schedule, and counsel verification checklist.

## Guardrails

Do not state that a document is privileged solely because it is confidential,
created by a lawyer, copied to a lawyer, or labelled privileged. Do not expose the
protected substance in the description. Do not waive, disclose, delete, or alter
material; require qualified counsel to approve final assertions and withdrawals.

Referenced files: 1

View saved version →

---
name: production-set-checker
description: >-
  Audits document productions before or after disclosure for scope, completeness,
  format, metadata, numbering, document families, redactions, privilege,
  confidentiality, technical integrity, exceptions, and delivery records. Use for
  production quality control, disclosure certification support, deficiency review,
  rolling-production reconciliation, or remediation of a defective production.
---

# Production Set Checker

Run a reproducible release gate that reconciles what was ordered or agreed, what
was reviewed, and what is actually being delivered.

## Intake

Obtain the governing order, request, agreement or protocol; review and collection
reports; source and processed counts; production specification; export, load files,
images, text, natives and metadata; numbering ranges; privilege and redaction logs;
confidentiality designations; exception reports; prior rolling productions;
transmittal; deadline; and authorised release decision-maker.

Never open or transmit a production outside the authorised environment merely to
perform a check.

## Method

1. Freeze the candidate production and record version, export time, operator,
   tool version, settings, file hashes or comparable integrity data, and location.
2. Reconcile requested or ordered scope against collection, processing, review,
   promotion, withholding, exclusion, exception, and production counts. Explain
   differences; do not force totals to match.
3. Validate numbering for uniqueness, continuity, endorsed page ranges, document
   boundaries, parent-child relationships, gaps, overlaps, duplicates, and prior
   rolling ranges.
4. Check that images, extracted text, natives, placeholders, translations, media,
   container contents, attachments, and structured data are present and linked as
   required. Record encrypted, corrupt, unsupported, or missing items separately.
5. Validate required metadata field names, types, encodings, date and time zones,
   delimiters, paths, identifiers, family links, custodians, confidentiality, and
   redaction indicators. Compare a reasoned sample to source data.
6. Reconcile withheld and redacted items to the privilege log, redaction record,
   slip sheets, family treatment, and counsel decisions. Search for inconsistent
   duplicates and near-duplicates without assuming they share privilege.
7. Test redactions visually and technically: applied area, stated basis,
   underlying text or layer removal, OCR, comments, revision history, metadata,
   hidden objects, attachments, thumbnails, and native leakage.
8. Check confidentiality markings, legends, access tiers, personal or secret data,
   agreed protective measures, and any export-control or cross-border restrictions.
9. Perform malware and file-safety checks using authorised tools, then validate
   archive structure, loadability, manifests, checksums, encryption, password
   exchange, media capacity, and delivery method.
10. Produce blocking defects, non-blocking exceptions, remediation owners,
    re-test evidence, final approval, transmittal, receipt, and immutable release
    record. Do not certify legal compliance without the authorised signatory.

## Output

Provide the production control sheet, scope and count reconciliation, numbering
report, family and file-completeness report, metadata validation, privilege and
redaction reconciliation, confidentiality check, technical exception log,
blocking-defect list, remediation tracker, and release-sign-off checklist.

## Guardrails

Do not release a set with unresolved privilege leakage, reversible redactions,
malware, missing families, unexplained count differences, wrong recipients, or
unapproved sensitive data. Do not modify source evidence, hide adverse material,
backfill logs, or describe a technical QC pass as a legal certification.

Referenced files: 1

View saved version →

---
name: redaction-reviewer
description: >-
  Reviews proposed or completed legal redactions for an identified disclosure,
  filing, publication, investigation, or information-access process. Use when
  testing the legal basis, scope, consistency, document-family treatment,
  redaction labels, reversibility, hidden text or metadata leakage, clean and
  confidential versions, or a redaction challenge and justification schedule.
---

# Redaction Reviewer

Assess each redaction against the actual disclosure purpose and governing legal
basis, then verify that the applied redaction cannot be reversed or bypassed.

## Intake

Obtain the jurisdiction, forum and audience; governing rules, order, protocol or
publication standard; complete unredacted source; proposed redacted version;
production or filing format; redaction log; privilege and confidentiality decisions;
protective measures; document families and duplicates; personal-data and secrecy
constraints; and the authorised approver.

Keep unredacted material in the authorised environment. If only the redacted copy
is available, limit the review to visible and technical defects and state that the
substantive basis cannot be verified.

## Method

1. Identify the precise purpose and audience: party disclosure, public filing,
   court inspection, freedom-of-information release, regulator production,
   investigation report, or publication. Do not transfer a redaction standard
   from one setting to another.
2. Build a basis key from current governing authority and orders. Distinguish
   privilege, personal data, secrecy, confidentiality, irrelevance, trade secrets,
   protected identities, security, and court-ordered treatment.
3. Compare source and redacted versions by stable document and page or field
   locators. Record the content category, asserted basis, decision-maker, extent,
   label, and whether a less extensive protective measure is sufficient.
4. Test necessity and proportionality. Avoid hiding context needed to understand
   disclosed material and avoid redacting a fact merely because it is adverse,
   embarrassing, commercially inconvenient, or already confidential.
5. Reconcile treatment across duplicates, near-duplicates, email threads,
   attachments, versions, translations, exhibits, structured data, and prior
   disclosures. Do not assume an earlier mistake authorises repetition.
6. Check partial redactions, legends, confidentiality markings, page numbering,
   cross-references, indexes, bookmarks, filenames, and the separation of public,
   confidential, sealed, and counsel-only versions.
7. Test technical permanence using authorised inspection: selectable text, OCR,
   layers, annotations, comments, revision history, hidden cells or slides,
   metadata, thumbnails, attachments, embedded objects, alternate renditions,
   search indexes, and copy-paste or extraction.
8. Reconcile the final redaction log and privilege log to the released set. Record
   over-redaction, under-redaction, unexplained inconsistency, leakage, and items
   requiring counsel or court determination.
9. Preserve the clean source, approved redacted version, tool and method, operator,
   date, verification results, approver, release recipient, and challenge history.

## Output

Provide a redaction schedule, basis key, source-to-release reconciliation,
consistency report, technical leakage findings, version and audience matrix,
challenge-response table, blocking defects, and final approval checklist.

## Guardrails

Do not alter or overwrite the only source copy, expose protected content in the
report, infer a legal basis from black boxes alone, or promise that visual covering
is secure deletion. Do not remove adverse evidence, defeat lawful access, or apply
redactions without authorised legal and technical review.

Referenced files: 1

View saved version →

---
name: witness-statement-drafter
description: >-
  Draft first-person witness statements, affidavits, declarations, or proofs of
  evidence from a witness's own account. Use when factual evidence must identify
  personal knowledge, information sources, documents, exhibits, uncertainty,
  language, preparation method, and current forum formalities.
---

# Witness Statement Drafter

Preserve the witness's evidence, vocabulary, uncertainty, and independence. A
statement is not written submissions in the witness's voice.

## Intake and interview

Obtain the forum rules and order, issues, pleadings, prior accounts, interview
notes or recording, relevant documents, chronology, witness role and capacity,
language and literacy, memory aids, source of information, exhibits, disclosure
status, privilege boundaries, vulnerabilities, deadline, and statement of truth
or oath requirements.

## Drafting method

1. Explain purpose, disclosure and cross-examination consequences, truth duty,
   privilege limits, document preservation, and the witness's right to correct the draft.
2. Establish identity, role, relationship to the parties, relevant experience,
   and how the statement was prepared.
3. Organise evidence chronologically or by issue in numbered first-person paragraphs.
4. State only facts the witness could properly give orally. Identify personal
   observation, refreshed recollection, usual practice, inference, and information
   or belief with its source.
5. Use the witness's own words and level of certainty. Preserve “I do not know,”
   “I do not recall,” estimates, reconstructed dates, and qualified recollection.
6. Link documents and exhibits with accurate identifiers. Do not imply the
   witness created, sent, received, read, or understood a document without a basis.
7. Reconcile material differences from prior statements, pleadings, documents,
   and other accounts; record the witness's explanation rather than conceal it.
8. Exclude legal argument, commentary on others' motives, inadmissible hearsay,
   expert opinion, privileged content, and unnecessary personal data unless proper.
9. Record interpreter, translation, accessibility, interview, drafting,
   document-review, and remote-signing circumstances where required.
10. Have the witness review the full statement and exhibits, make genuine
    corrections, and sign or swear only the approved final version.

## Output

Provide the draft statement, exhibit list, knowledge-and-source schedule,
uncertainty and inconsistency note, formalities checklist, and unresolved questions.

## Guardrails

Never invent recollection, improve certainty, harmonise accounts artificially,
coach a false answer, suppress adverse facts, or sign for the witness. Do not use
collective corporate knowledge as personal knowledge. Verify current format,
statement-of-truth, oath, filing, service, and language requirements.

Referenced files: 1

View saved version →

---
name: written-submissions-drafter
description: >-
  Draft issue-led written submissions, skeleton arguments, briefs, or closing
  notes tied to the record and current authorities. Use for applications,
  trials, appeals, arbitrations, tribunals, or other hearings requiring concise
  legal argument and precise relief.
---

# Written Submissions Drafter

Make the decision path easy to follow: issue, governing test, material record,
application, answer to the other side, conclusion, and requested order.

## Intake

Obtain the forum and hearing type, issues or questions presented, pleadings,
orders, evidence and transcript, agreed facts, record or bundle index, opponent's
case, current authorities and subsequent treatment, procedural rules, page and
time limits, citation style, oral plan, and exact relief.

## Drafting method

1. Confirm the live issues, burdens, standard, jurisdiction, procedural posture,
   and matters already decided, agreed, abandoned, or outside scope.
2. Draft a short overview stating the result sought and the decisive reasons
   without overstating facts or law.
3. Organise by issue rather than document sequence or witness.
4. For each issue, state the controlling rule with accurate authority and
   pinpoint; then identify the material facts with record locators.
5. Apply the rule to the facts and explain each inferential step. Distinguish
   evidence, finding, concession, allegation, and submission.
6. Address adverse facts, contrary authority, jurisdictional differences,
   standard-of-review constraints, and the opponent's strongest argument fairly.
7. Explain why cited cases are binding or persuasive, factually analogous or
   distinguishable, and still good law at the research date.
8. Avoid unnecessary quotation, string citations, repetition, rhetoric, and
   propositions broader than the authority supports.
9. Tie every requested remedy, interest, costs, stay, direction, timetable, or
   consequential order to power and supporting facts.
10. Reconcile the submissions with pleadings, evidence, prior positions, oral
    argument, chronology, authorities list, and draft order.
11. Conform to current formatting, certification, hypertext, bundle, filing,
    service, confidentiality, and page-limit requirements.

## Output

Provide the submissions, issue roadmap, authority and record-citation table,
adverse-point check, relief schedule, draft-order instructions, and filing checklist.

## Guardrails

Do not misquote, cite nonexistent or overruled authority, conceal binding adverse
law, assert facts outside the record, or change evidence through advocacy. Protect
privilege and confidential material. Reverify every authority, pinpoint, record
reference, rule, deadline, and requested power before filing.

Referenced files: 1