Confirm the filing requirements
Identify the court, motion, applicable rules, local requirements, and orders. Determine the required form and treatment of factual statements through counsel.
Do not reuse a format from another court without checking. The Federal Rules alone may not describe every required filing detail.
Break assertions into propositions
Separate statements containing several facts so each can be checked against the record. Record the proposed wording, source, passage, and reviewer.
Keep legal argument and factual assertion distinguishable. A sentence that combines both can obscure the evidentiary basis.
Test an overbroad assertion
Suppose a draft states that the company never received a complaint, while the cited witness testified only about their own inbox. Narrow the proposition or obtain additional evidence.
A source can support part of a statement without supporting its full breadth.
Record disputes and evidentiary issues
Include contrary material and questions about the evidence's use. Counsel must assess admissibility, foundation, and other relevant requirements.
Do not mark a fact undisputed merely because the uploaded collection contains no response.
Approve the final statement
Recheck record references after drafting and exhibit changes. Save the verified source matrix with the filing version.
Use AI assistance to organise and revise working material, while counsel remains responsible for the factual representations and procedural compliance.
Sources and next steps
This is an editorial workflow guide for legal professionals. The suggested checks are our practical recommendations, not a statement that a regulator requires a particular software workflow.
Explore Review Matrix and Drafting, or review Judicio's regional coverage and limitations. Check the underlying source and your organisation's approved process before relying on an output.