Workflow template for legal and contracts

Hearing preparation pack

Before a set hearing, the arguing attorney has one draft pack: the hearing as the notice states it, the docket history, each order's directives quoted, each witness's prior statements with page cites, exhibit and checklist status as the firm records them, and an open-items list. The attorney decides every argument.

This workflow template prepares legal work for a lawyer to review. It gives no legal advice and has not been reviewed by a lawyer. A lawyer decides and signs.

View this template on GitHub

Put this on your planBuild this in a sprint

Add it to a workflow in the Fully Powered Planner, beside the teams and roles that will run it. Book a fit call

The outcome

The attorney who will stand up at the hearing opens one pack and finds everything assembled in the same order every time. The date, time, courtroom, judge and every direction in the notice, in the notice's own words. Every docket entry, as docketed. Every directive in the orders the attorney asked for, quoted with its page and paragraph, footnotes included. Each witness, in the attorney's order, with their declarations or transcripts quoted under the topics the attorney named, every passage cited to paragraph and page or to page and line. Each exhibit with its marking, exchange and stipulation status exactly as the tracker shows it, and each item on the firm's own pre-hearing checklist shown done or open. A separate open-items list gathers what the sources show is still outstanding: a checklist item past its recorded date, a blank in the tracker, a witness with no statement on file, an email a declaration mentions that is not on the exhibit list, an order on the docket nobody supplied.

The gathering arrives done, for the paralegal to check, and the attorney's time goes to the arguments, which only a lawyer can make. The same pack works for a deposition: the witness's earlier statements, the documents and exhibits, and the firm's deposition checklist, with no question outline.

What it does not do. It gives no legal advice. It decides nothing about legal meaning, merit, validity, privilege, conflicts or deadlines. It sends, files, signs and calendars nothing. It writes no argument, states no legal standard and makes no strategic assessment; the arguments, the legal standard, the order of proof and every filing are the attorney's. It says nothing about whether a witness is believable or an exhibit admissible, and it never sets one witness's words against another's. It writes no witness list or exhibit list for filing, no stipulation, no letter and no examination questions, even for the attorney to edit. A date the notice or an order states is copied; a date that has to be counted is proposed only under the firm's own counsel-approved rule file, with every day shown, or left uncounted. It names no case, statute or rule from memory, and any that reaches it is marked to be verified by the lawyer and never called good law. Asked what the standard is, whether the firm will win, or whether something is ready to file, it says that is for the named attorney and points to the line of the pack concerned. Everything it prepares is a draft for the named attorney.

Who starts the work, and when

A paralegal starts it once a hearing is set and the arguing attorney has asked for the pack, naming the witnesses, the topics for each and the orders to include. It runs again whenever the docket, the tracker or the checklist changes before the hearing. The arguing attorney reviews it. In a company with no lawyer of its own, the pack is prepared for the outside counsel who will argue the hearing and goes to that counsel, never to the business as an answer.

It is not for a hearing that has not been set, and it is not for planning a board meeting or a company event: board meeting pack and event plan do that work.

What they supply

  • The attorney's request: the matter and case number, the arguing attorney, the notice that sets the hearing, the witnesses in the attorney's order with the topics for each, the orders to include and today's date.
  • The notice setting the hearing, every page. For a deposition, the notice of deposition.
  • The docket, exported with the columns Entry, Date Filed and Docket Text, or the docket sheet itself.
  • The orders the attorney listed, every page.
  • Each witness's prior statements: declarations and affidavits with numbered paragraphs, and transcripts with their page and line numbers.
  • The exhibit tracker, exported with the columns Exhibit, Description, Bates Range, Offered By, Witness, Pre-marked, Exchanged and Stipulation.
  • The firm's own pre-hearing checklist, exported with the columns ID, Item, Owner, Due, Status, Done On and Notes.
  • The firm's deadline rule file, if it keeps one, approved by an attorney, with the court-closure list.

If an export's column headers differ, the workflow template stops and asks which column is which. It brings no checklist and no court rules of its own, and it uses nothing the firm did not supply: nothing remembered, nothing from the internet.

What comes out

One draft pack, headed for the named attorney to review, in a fixed order:

  • Hearing: each detail in the notice's words, with its cite, and any later docket entry that reads as moving it.
  • Procedural history: every docket entry, as docketed.
  • Orders: each directive quoted with page and paragraph, and any other order on the docket that was not supplied.
  • Witnesses: each statement listed, passages quoted under the attorney's topics, and the documents each statement refers to, checked against the tracker.
  • Exhibits: every field as the tracker records it, with gaps in the numbering noted.
  • Checklist: every item done or open as the firm records it.
  • Dates: each one copied, proposed under a named rule with the working shown, or marked not computed.
  • Attorney to confirm: a line for each part of the pack and each date.
  • Check: what was read and how.

Then the open-items list, in a fixed order, each item with its source and its owner as recorded, and no recommendation. If a page is missing or a later docket entry may have moved the hearing, the pack says so at the top in capitals.

An invented example

Illustrative example with invented data. Marrowgate Pell LLP, Quorvale Fixtures, Inc., Tamberlyn Freight LLC, every person named, the Superior Court of Vellandor and its County of Marrowfield, the case, the docket, the notice, the order, the declarations, the tracker, the checklist and the rule file below are all invented. Nothing here describes a real case, court, firm or person.

The paralegal's eight inputs come first, in full, then what the workflow template prepares: the pack and the open-items list.

Input 1: the request

Sent by Tobias Hale, paralegal, on Monday 23 November 2026.

Rosalind wants the hearing pack for the release hearing.

Matter: Quorvale Fixtures, Inc. v. Tamberlyn Freight LLC,
case no. MF-CV-26-01188. We act for the plaintiff.
Hearing: the evidentiary hearing on our release application, set by
the notice at Dkt. 8.
Arguing attorney: Rosalind Achterberg.

Witnesses, in Rosalind's order:
1. Dana Okafor. Quorvale's operations manager. We call her.
   Topics: the order and the shipment; the hold and the request for
   release.
2. Marcus Feld. Tamberlyn's warehouse lead. Tamberlyn has said it
   will call him.
   Topics: the hold.
3. Priya Lindgren. Quorvale's accounts manager. We call her.
   Topics: payment.

Orders to include: Dkt. 9.
Procedural history: from the first entry.
Today's date: Monday 23 November 2026.
Nothing in the file is marked confidential.

Input 2: the notice setting the hearing (Dkt. 8)

                SUPERIOR COURT OF VELLANDOR
                   COUNTY OF MARROWFIELD

QUORVALE FIXTURES, INC.,              Case No. MF-CV-26-01188
          Plaintiff,
     v.                               NOTICE OF EVIDENTIARY HEARING
TAMBERLYN FREIGHT LLC,
          Defendant.

TO ALL PARTIES AND THEIR COUNSEL OF RECORD:

1. An evidentiary hearing on Plaintiff's Application for Release of
   Goods (Dkt. 4) is set for December 10, 2026, at 9:30 a.m., in
   Department 14 of the Marrowfield Civic Courthouse, 200 Tallis
   Street, Marrowfield, before the Honorable Ilse Marchbank.

2. Two hours have been reserved for the hearing.

3. Counsel and witnesses shall appear in person. Remote appearance
   is permitted only by leave of court requested no later than
   December 7, 2026.

4. Each party shall exchange its exhibit list and copies of its
   exhibits no later than five court days before the hearing.

5. Each party shall file and serve its witness list no later than
   December 3, 2026.

Dated: November 16, 2026               Clerk of the Court
                                       By: H. Strand, Deputy Clerk

                                                       Page 1 of 1

Input 3: the docket, exported

Entry,Date Filed,Docket Text
1,2026-06-02,"COMPLAINT filed by Quorvale Fixtures, Inc."
2,2026-07-14,"ANSWER filed by Tamberlyn Freight LLC"
3,2026-08-05,"SCHEDULING ORDER. Signed by Judge Ilse Marchbank."
4,2026-10-12,"APPLICATION for Release of Goods filed by Quorvale Fixtures, Inc."
5,2026-10-12,"DECLARATION of Dana Okafor in support of [4] Application"
6,2026-10-30,"OPPOSITION to [4] Application filed by Tamberlyn Freight LLC"
7,2026-10-30,"DECLARATION of Marcus Feld in support of [6] Opposition"
8,2026-11-16,"NOTICE OF EVIDENTIARY HEARING on [4] Application. Hearing set for 12/10/2026 09:30 AM in Department 14."
9,2026-11-17,"ORDER RE: EVIDENTIARY HEARING PROCEDURES. Signed by Judge Ilse Marchbank."

Input 4: the order the attorney listed (Dkt. 9)

                SUPERIOR COURT OF VELLANDOR
                   COUNTY OF MARROWFIELD

QUORVALE FIXTURES, INC. v. TAMBERLYN FREIGHT LLC
Case No. MF-CV-26-01188

ORDER RE: EVIDENTIARY HEARING PROCEDURES

The Court, having set an evidentiary hearing on Plaintiff's
Application for Release of Goods (Dkt. 4) for December 10, 2026,
orders as follows:

1. The declarations filed with the Application and the Opposition
   stand as each declarant's direct testimony. Each declarant shall
   be present at the hearing and available for cross-examination.

2. Each side shall have sixty minutes, including cross-examination
   of the other side's witnesses.

3. Exhibits shall be pre-marked: Plaintiff's exhibits P-1 onward,
   Defendant's exhibits D-1 onward. Each party shall bring three
   copies of its exhibit binder.¹

4. Any written stipulation as to exhibits shall be lodged with the
   Department no later than December 8, 2026.

IT IS SO ORDERED.

Dated: November 17, 2026               ______________________
                                       Hon. Ilse Marchbank
                                       Judge of the Superior Court

¹ One binder for the Court, one for the witness stand, and one for
opposing counsel.
                                                       Page 1 of 1

Input 5: the witnesses' prior statements

The declaration of Dana Okafor, filed as Dkt. 5:

                SUPERIOR COURT OF VELLANDOR
                   COUNTY OF MARROWFIELD
QUORVALE FIXTURES, INC. v. TAMBERLYN FREIGHT LLC
Case No. MF-CV-26-01188

DECLARATION OF DANA OKAFOR IN SUPPORT OF PLAINTIFF'S
APPLICATION FOR RELEASE OF GOODS

I, Dana Okafor, declare:

1. I am the operations manager of Quorvale Fixtures, Inc. I have
   held that position since January 2022.

2. On March 2, 2026, Quorvale issued purchase order no. 4471 to its
   supplier for 640 display shelving units (QF-000014 to QF-000015).

3. The units were collected by Tamberlyn Freight LLC on March 9,
   2026, under bill of lading no. TB-58821 (QF-000021), for delivery
   to Quorvale's Marrowfield store.
                                                       Page 1 of 2

4. The units were not delivered. On April 14, 2026, I received a
   notice from Tamberlyn stating that the units were being held at
   its Brack Lane warehouse (TF-000103).

5. On April 15, 2026, I emailed Tamberlyn asking for the units to
   be released. I received no reply to that email.

6. As of the date of this declaration, Tamberlyn still holds the
   units at the Brack Lane warehouse.

I declare under penalty of perjury that the foregoing is true and
correct. Executed on October 9, 2026, at Marrowfield.

                                       /s/ Dana Okafor
                                                       Page 2 of 2

The declaration of Marcus Feld, filed as Dkt. 7:

                SUPERIOR COURT OF VELLANDOR
                   COUNTY OF MARROWFIELD
QUORVALE FIXTURES, INC. v. TAMBERLYN FREIGHT LLC
Case No. MF-CV-26-01188

DECLARATION OF MARCUS FELD IN SUPPORT OF DEFENDANT'S OPPOSITION

I, Marcus Feld, declare:

1. I am the warehouse lead at the Brack Lane warehouse of Tamberlyn
   Freight LLC.

2. Tamberlyn holds the units described in the storage terms
   (TF-000088 to TF-000095) because storage and handling charges of
   $12,480 are unpaid.

3. On April 14, 2026, I sent Quorvale the hold notice (TF-000103).

4. I did not receive an email from Quorvale on April 15, 2026.

I declare under penalty of perjury that the foregoing is true and
correct. Executed on October 28, 2026, at Marrowfield.

                                       /s/ Marcus Feld
                                                       Page 1 of 1

No statement of Priya Lindgren was supplied.

Input 6: the exhibit tracker, exported

Exhibit,Description,Bates Range,Offered By,Witness,Pre-marked,Exchanged,Stipulation
P-1,"Purchase order no. 4471, March 2, 2026",QF-000014 to QF-000015,Plaintiff,Dana Okafor,Yes,No,Authenticity stipulated (email from opposing counsel 2026-11-17)
P-2,"Bill of lading no. TB-58821, March 9, 2026",QF-000021,Plaintiff,Dana Okafor,Yes,No,
P-3,"Hold notice, April 14, 2026",TF-000103,Plaintiff,Marcus Feld,No,No,None
P-5,"Quorvale payment record, invoice TF-2210",,Plaintiff,Priya Lindgren,No,No,None
D-1,"Storage terms",TF-000088 to TF-000095,Defendant,Marcus Feld,,Received 2026-11-20,Not stipulated

Input 7: the firm's pre-hearing checklist, exported

ID,Item,Owner,Due,Status,Done On,Notes
C1,Confirm hearing date and department with the clerk,Tobias Hale,2026-11-18,Done,2026-11-18,
C2,File and serve witness list,Owen Barrie,2026-12-03,Open,,Rosalind to approve list
C3,Exchange exhibit list and exhibit copies,Tobias Hale,5 court days before hearing,Open,,
C4,Pre-mark exhibits; three binders,Tobias Hale,2026-12-08,In progress,,
C5,Confirm each witness is available on the hearing date,Owen Barrie,2026-11-20,Open,,
C6,Book courtroom display equipment,Tobias Hale,2026-12-01,Done,,
C7,Lodge any written exhibit stipulation,Owen Barrie,2026-12-08,Open,,

Input 8: the firm's deadline rule file

MARROWGATE PELL LLP · LITIGATION DEADLINE RULE FILE
Version 3 · approved by Imre Castellan, supervising attorney,
on November 2, 2026 · next review May 2027

Part 1. Counts staff may propose

R1. "[N] court days before a hearing"
    Start from the hearing date. Count backwards one day at a time,
    not counting the hearing date itself. Count a day only if it is
    a Monday to Friday and not a court closure day in Part 2. The Nth
    day counted is the proposed last day.

R2. "[N] calendar days before a hearing"
    Start from the hearing date. Count backwards every day, not
    counting the hearing date itself. If the Nth day is a Saturday,
    a Sunday or a court closure day in Part 2, the proposed last day
    is the nearest Monday to Friday before it that is not a closure
    day.

Any other count goes to the attorney uncounted.

Part 2. Court closure days, Superior Court of Vellandor, County of
Marrowfield, as kept by docketing. Covers November 1, 2026 to
January 31, 2027.
- Thursday, November 26, 2026
- Friday, November 27, 2026
- Friday, December 4, 2026
- Friday, December 25, 2026
- Friday, January 1, 2027

What the workflow template prepares

DRAFT HEARING PACK · FOR Rosalind Achterberg TO REVIEW
Prepared for Rosalind Achterberg, who will argue the hearing. It gives no
legal advice. It decides nothing about legal meaning, merit, validity,
privilege, conflicts or deadlines. It sends, files, signs and calendars
nothing: nothing has been sent, filed, signed or calendared. It writes no
argument, states no legal standard and makes no strategic assessment.

Matter: Quorvale Fixtures, Inc. v. Tamberlyn Freight LLC
Case no.: MF-CV-26-01188
Hearing: the evidentiary hearing on our release application (Dkt. 8)
Prepared for: Rosalind Achterberg, who reviews and decides
Prepared by: Tobias Hale, Monday 23 November 2026
Witnesses, in the attorney's order: 1. Dana Okafor; 2. Marcus Feld;
3. Priya Lindgren

HEARING, AS THE NOTICE STATES IT
- Kind of hearing: "An evidentiary hearing" (Dkt. 8, p. 1, ¶ 1)
- Set to be heard: "Plaintiff's Application for Release of Goods
  (Dkt. 4)" (Dkt. 8, p. 1, ¶ 1)
- Date and time: "December 10, 2026, at 9:30 a.m." (Dkt. 8, p. 1, ¶ 1)
- Place: "Department 14 of the Marrowfield Civic Courthouse, 200 Tallis
  Street, Marrowfield" (Dkt. 8, p. 1, ¶ 1)
- Before: "the Honorable Ilse Marchbank" (Dkt. 8, p. 1, ¶ 1)
- Time reserved: "Two hours have been reserved for the hearing."
  (Dkt. 8, p. 1, ¶ 2)
- Appearance: "Counsel and witnesses shall appear in person. Remote
  appearance is permitted only by leave of court requested no later
  than December 7, 2026." (Dkt. 8, p. 1, ¶ 3)
- Other directions: "Each party shall exchange its exhibit list and
  copies of its exhibits no later than five court days before the
  hearing." (Dkt. 8, p. 1, ¶ 4); "Each party shall file and serve its
  witness list no later than December 3, 2026." (Dkt. 8, p. 1, ¶ 5)
- Issued: "Dated: November 16, 2026 Clerk of the Court By: H. Strand,
  Deputy Clerk" (Dkt. 8, p. 1)
- Later docket entries about the setting: None in the docket supplied.

PROCEDURAL HISTORY, FROM THE DOCKET
Dkt. 1. 2026-06-02. "COMPLAINT filed by Quorvale Fixtures, Inc."
Dkt. 2. 2026-07-14. "ANSWER filed by Tamberlyn Freight LLC"
Dkt. 3. 2026-08-05. "SCHEDULING ORDER. Signed by Judge Ilse Marchbank."
Dkt. 4. 2026-10-12. "APPLICATION for Release of Goods filed by Quorvale
   Fixtures, Inc."
Dkt. 5. 2026-10-12. "DECLARATION of Dana Okafor in support of [4]
   Application"
Dkt. 6. 2026-10-30. "OPPOSITION to [4] Application filed by Tamberlyn
   Freight LLC"
Dkt. 7. 2026-10-30. "DECLARATION of Marcus Feld in support of [6]
   Opposition"
Dkt. 8. 2026-11-16. "NOTICE OF EVIDENTIARY HEARING on [4] Application.
   Hearing set for 12/10/2026 09:30 AM in Department 14."
Dkt. 9. 2026-11-17. "ORDER RE: EVIDENTIARY HEARING PROCEDURES. Signed by
   Judge Ilse Marchbank."

ORDERS THE ATTORNEY LISTED
Dkt. 9, filed 2026-11-17: "ORDER RE: EVIDENTIARY HEARING PROCEDURES".
   Signed: "Hon. Ilse Marchbank Judge of the Superior Court" (Dkt. 9,
   p. 1).
   9.1 "The declarations filed with the Application and the Opposition
       stand as each declarant's direct testimony." (p. 1, ¶ 1)
   9.2 "Each declarant shall be present at the hearing and available
       for cross-examination." (p. 1, ¶ 1)
   9.3 "Each side shall have sixty minutes, including cross-examination
       of the other side's witnesses." (p. 1, ¶ 2)
   9.4 "Exhibits shall be pre-marked: Plaintiff's exhibits P-1 onward,
       Defendant's exhibits D-1 onward." (p. 1, ¶ 3)
   9.5 "Each party shall bring three copies of its exhibit binder."
       (p. 1, ¶ 3)
   9.6 "One binder for the Court, one for the witness stand, and one
       for opposing counsel." (p. 1, n. 1)
   9.7 "Any written stipulation as to exhibits shall be lodged with the
       Department no later than December 8, 2026." (p. 1, ¶ 4)
Other orders on the docket, not supplied: Dkt. 3, 2026-08-05:
   "SCHEDULING ORDER. Signed by Judge Ilse Marchbank."

WITNESSES, IN THE ATTORNEY'S ORDER
W1. Dana Okafor. As the request gives it: "Quorvale's operations
    manager. We call her."
   Statements supplied:
   S1. "DECLARATION OF DANA OKAFOR IN SUPPORT OF PLAINTIFF'S APPLICATION
         FOR RELEASE OF GOODS", "Executed on October 9, 2026, at
         Marrowfield." (S1, p. 2). Filed as Dkt. 5, 2026-10-12. 2 pages.
         Signed "/s/ Dana Okafor" (S1, p. 2)
   Topic 1. the order and the shipment
      - "On March 2, 2026, Quorvale issued purchase order no. 4471 to
        its supplier for 640 display shelving units (QF-000014 to
        QF-000015)." (S1, ¶ 2, p. 1)
      - "The units were collected by Tamberlyn Freight LLC on March 9,
        2026, under bill of lading no. TB-58821 (QF-000021), for
        delivery to Quorvale's Marrowfield store." (S1, ¶ 3, p. 1)
      - "The units were not delivered. On April 14, 2026, I received a
        notice from Tamberlyn stating that the units were being held
        at its Brack Lane warehouse (TF-000103)." (S1, ¶ 4, p. 2)
   Topic 2. the hold and the request for release
      - See S1, ¶ 4, p. 2, under Topic 1.
      - "On April 15, 2026, I emailed Tamberlyn asking for the units to
        be released. I received no reply to that email." (S1, ¶ 5,
        p. 2)
      - "As of the date of this declaration, Tamberlyn still holds the
        units at the Brack Lane warehouse." (S1, ¶ 6, p. 2)
   Other passages not placed under a topic: S1, ¶ 1, p. 1.
   Documents the statements refer to:
      - QF-000014 to QF-000015 (S1, ¶ 2, p. 1): on the tracker as P-1
      - QF-000021 (S1, ¶ 3, p. 1): on the tracker as P-2
      - TF-000103 (S1, ¶ 4, p. 2): on the tracker as P-3
      - "I emailed Tamberlyn asking for the units to be released"
        (S1, ¶ 5, p. 2): referred to by description only; not matched

W2. Marcus Feld. As the request gives it: "Tamberlyn's warehouse lead.
    Tamberlyn has said it will call him."
   Statements supplied:
   S2. "DECLARATION OF MARCUS FELD IN SUPPORT OF DEFENDANT'S
         OPPOSITION", "Executed on October 28, 2026, at Marrowfield."
         (S2, p. 1). Filed as Dkt. 7, 2026-10-30. 1 page. Signed
         "/s/ Marcus Feld" (S2, p. 1)
   Topic 1. the hold
      - "Tamberlyn holds the units described in the storage terms
        (TF-000088 to TF-000095) because storage and handling charges
        of $12,480 are unpaid." (S2, ¶ 2, p. 1)
      - "On April 14, 2026, I sent Quorvale the hold notice
        (TF-000103)." (S2, ¶ 3, p. 1)
   Other passages not placed under a topic: S2, ¶ 1, p. 1; S2, ¶ 4,
      p. 1.
   Documents the statements refer to:
      - TF-000088 to TF-000095 (S2, ¶ 2, p. 1): on the tracker as D-1
      - TF-000103 (S2, ¶ 3, p. 1): on the tracker as P-3
      - "an email from Quorvale on April 15, 2026" (S2, ¶ 4, p. 1):
        referred to by description only; not matched

W3. Priya Lindgren. As the request gives it: "Quorvale's accounts
    manager. We call her."
   Statements supplied: None supplied.
   Topic 1. payment
      - No passage on this topic in the statements supplied.
   Other passages not placed under a topic: None.
   Documents the statements refer to:
      - None.

EXHIBITS, AS THE TRACKER RECORDS THEM
P-1. "Purchase order no. 4471, March 2, 2026". Bates: QF-000014 to
   QF-000015. Offered by: Plaintiff. Witness: Dana Okafor. Pre-marked:
   Yes. Exchanged: No. Stipulation: Authenticity stipulated (email from
   opposing counsel 2026-11-17).
   Referred to in: S1, ¶ 2, p. 1
P-2. "Bill of lading no. TB-58821, March 9, 2026". Bates: QF-000021.
   Offered by: Plaintiff. Witness: Dana Okafor. Pre-marked: Yes.
   Exchanged: No. Stipulation: not recorded.
   Referred to in: S1, ¶ 3, p. 1
P-3. "Hold notice, April 14, 2026". Bates: TF-000103. Offered by:
   Plaintiff. Witness: Marcus Feld. Pre-marked: No. Exchanged: No.
   Stipulation: None.
   Referred to in: S1, ¶ 4, p. 2; S2, ¶ 3, p. 1
P-5. "Quorvale payment record, invoice TF-2210". Bates: not recorded.
   Offered by: Plaintiff. Witness: Priya Lindgren. Pre-marked: No.
   Exchanged: No. Stipulation: None.
   Referred to in: not referred to in the statements supplied
D-1. "Storage terms". Bates: TF-000088 to TF-000095. Offered by:
   Defendant. Witness: Marcus Feld. Pre-marked: not recorded.
   Exchanged: Received 2026-11-20. Stipulation: Not stipulated.
   Referred to in: S2, ¶ 2, p. 1
Tracker checks: Numbering: no P-4 in the tracker. Repeated numbers:
   none. Witnesses not on the attorney's list: none.

PRE-HEARING CHECKLIST, AS THE FIRM'S LIST RECORDS IT
C1. "Confirm hearing date and department with the clerk". Owner:
   Tobias Hale. Due: 2026-11-18. Status: Done on 2026-11-18.
C2. "File and serve witness list". Owner: Owen Barrie. Due: 2026-12-03.
   Status: Open. Notes: "Rosalind to approve list"
C3. "Exchange exhibit list and exhibit copies". Owner: Tobias Hale.
   Due: 5 court days before hearing; proposed Wednesday 2 December 2026,
   see Date 3. Status: Open.
C4. "Pre-mark exhibits; three binders". Owner: Tobias Hale. Due:
   2026-12-08. Status: Open ("In progress").
C5. "Confirm each witness is available on the hearing date". Owner:
   Owen Barrie. Due: 2026-11-20. Status: Open. Due date recorded is
   before today.
C6. "Book courtroom display equipment". Owner: Tobias Hale. Due:
   2026-12-01. Status: Done; date not recorded.
C7. "Lodge any written exhibit stipulation". Owner: Owen Barrie. Due:
   2026-12-08. Status: Open.
Items: 7. Done: 2. Open: 5.

DATES
Date 1. "An evidentiary hearing on Plaintiff's Application for Release
   of Goods (Dkt. 4) is set for December 10, 2026, at 9:30 a.m., in
   Department 14 …" (Dkt. 8, p. 1, ¶ 1).
   Copied: Thursday 10 December 2026, 9:30 a.m.
Date 2. "Remote appearance is permitted only by leave of court requested
   no later than December 7, 2026." (Dkt. 8, p. 1, ¶ 3).
   Copied: Monday 7 December 2026
Date 3. "Each party shall exchange its exhibit list and copies of its
   exhibits no later than five court days before the hearing." (Dkt. 8,
   p. 1, ¶ 4).
   Proposed: Wednesday 2 December 2026, under R1 of the rule file
   Working: start Thursday 10 December 2026, not counted. Counted:
   Wednesday 9 December (1); Tuesday 8 December (2); Monday 7 December
   (3); Thursday 3 December (4); Wednesday 2 December (5). Skipped:
   Sunday 6 December (not Monday to Friday); Saturday 5 December (not
   Monday to Friday); Friday 4 December (court closure day, Part 2).
   Day 5 counted: Wednesday 2 December 2026.
Date 4. "Each party shall file and serve its witness list no later than
   December 3, 2026." (Dkt. 8, p. 1, ¶ 5).
   Copied: Thursday 3 December 2026
Date 5. "Any written stipulation as to exhibits shall be lodged with the
   Department no later than December 8, 2026." (Dkt. 9, p. 1, ¶ 4).
   Copied: Tuesday 8 December 2026

ATTORNEY TO CONFIRM
[ ] Hearing details are as the notice states, and which setting
    stands.                                                        ____
[ ] Procedural history: Dkt. 1 to Dkt. 9, as docketed.                ____
[ ] Orders: the directives of Dkt. 9 are complete. Whether any other
    order bears on the hearing is yours.                           ____
[ ] W1 Dana Okafor: the statements and the passages under each
    topic.                                                         ____
[ ] W2 Marcus Feld: the statements and the passages under each
    topic.                                                         ____
[ ] W3 Priya Lindgren: the statements and the passages under each
    topic.                                                         ____
[ ] Exhibits P-1 to D-1: status as the tracker records it.             ____
[ ] Checklist C1 to C7: done and open as recorded.                    ____
[ ] Date 1: Thursday 10 December 2026, 9:30 a.m. Whether it is right
    is yours.                                                       ____
[ ] Date 2: Monday 7 December 2026. Whether it is right is yours.     ____
[ ] Date 3: Wednesday 2 December 2026. Whether it is right is yours.  ____
[ ] Date 4: Thursday 3 December 2026. Whether it is right is yours.   ____
[ ] Date 5: Tuesday 8 December 2026. Whether it is right is yours.    ____
[ ] Open items OI1 to OI14: what is done about each is yours.          ____
[ ] Quotations and cites checked against the sources by Tobias
    Hale.                                                           ____

CHECK
- Read: notice Dkt. 8, 1 of 1 pages; order Dkt. 9, 1 of 1 pages; S1,
  2 of 2 pages; S2, 1 of 1 pages. Docket: 9 entries, numbering
  continuous, last entry 2026-11-17. Tracker: 5 rows. Checklist: 7
  items.
- Rule file: version 3, approved by Imre Castellan on November 2, 2026;
  closure list covering November 1, 2026 to January 31, 2027.
- Dates: 4 copied, 1 proposed, 0 not computed.
- Not used: nothing.
- Written to these rules, for Tobias Hale to check against the
  sources: every detail quoted with its cite; statements not compared
  with each other or with any exhibit; no argument, legal standard or
  assessment; no date counted except under the rule file.

Reviewed by Rosalind Achterberg: ____________  Date: ________
This is a draft for Rosalind Achterberg. The arguments, the legal
standard, the order of proof and every filing are the attorney's.

OPEN ITEMS · DRAFT FOR Rosalind Achterberg TO REVIEW
What the pack's sources show is still open. What is done about any item,
and by whom, is for Rosalind Achterberg.
OI1. "File and serve witness list". Source: checklist C2. Owner: Owen
   Barrie. Due: 2026-12-03.
OI2. "Exchange exhibit list and exhibit copies". Source: checklist C3.
   Owner: Tobias Hale. Due: 5 court days before hearing.
OI3. "Pre-mark exhibits; three binders", status "In progress". Source:
   checklist C4. Owner: Tobias Hale. Due: 2026-12-08.
OI4. "Confirm each witness is available on the hearing date"; due date
   recorded is before today. Source: checklist C5. Owner: Owen Barrie.
   Due: 2026-11-20.
OI5. "Lodge any written exhibit stipulation". Source: checklist C7.
   Owner: Owen Barrie. Due: 2026-12-08.
OI6. "Book courtroom display equipment" is marked Done; Done On not
   recorded. Source: checklist C6. Owner: Tobias Hale.
OI7. P-2, Stipulation not recorded. Source: tracker P-2. Owner: not
   recorded.
OI8. P-5, Bates Range not recorded. Source: tracker P-5. Owner: not
   recorded.
OI9. D-1, Pre-marked not recorded. Source: tracker D-1. Owner: not
   recorded.
OI10. No P-4 in the tracker. Source: tracker, Exhibit column. Owner:
   not recorded.
OI11. W3 Priya Lindgren: no statement supplied. Source: request,
   witness 3. Owner: not recorded.
OI12. "I emailed Tamberlyn asking for the units to be released":
   referred to by description only; not matched to a tracker row.
   Source: S1, ¶ 5, p. 2. Owner: not recorded.
OI13. "an email from Quorvale on April 15, 2026": referred to by
   description only; not matched to a tracker row. Source: S2, ¶ 4,
   p. 1. Owner: not recorded.
OI14. Dkt. 3, "SCHEDULING ORDER. Signed by Judge Ilse Marchbank.": on
   the docket, not supplied. Source: docket, Dkt. 3. Owner: not
   recorded.

Three things to notice. Date 3 is the only date counted, and it is counted under the firm's own rule R1 with every day shown, including the court closure on Friday 4 December; whether it is right is Rosalind Achterberg's line to answer. The two declarations each say something about an email of 15 April. Dana Okafor's paragraph speaks of asking for the units' release, so it is quoted under the hold and the request for release; Marcus Feld's paragraph speaks of no topic the attorney named for him, so it is listed by its cite under other passages and among the documents his statement refers to. Neither is set against the other or called right. The scheduling order at Dkt. 3 is on the docket but was not supplied, so the pack lists it and leaves to the attorney whether it bears on the hearing.

Tobias Hale checks every quotation and cite against the sources, recounts Date 3 against the rule file and the closure list, and gives the pack and the open-items list to Rosalind Achterberg. What is argued, in what order, and what is filed are her decisions.

Where it fits

  • Legal and contracts: the litigation team owns the hearing, the witnesses and every decision about how it is argued.
  • Law firms, in litigation groups where several hearings a week each need the same careful gathering, and a missed direction in a procedures order is expensive.
  • Insurance, where coverage and claims disputes bring hearing after hearing and in-house counsel works alongside outside counsel on each.
  • Real estate, where a lease, possession or title dispute can come to a hearing with declarations, documents and a procedures order to gather.
  • Established businesses, where a long-running dispute builds a docket and a record too large for one person to carry.

Case chronology and deposition transcript summary do the deeper reading of the documents and transcripts, and court-order deadline notice preparation is where a new order's dates go to the attorney.

What has to change for your company

The checklist is yours, and so is the rule file. Write the pre-hearing and deposition checklists the firm actually uses, with owners and due dates, because the workflow template adds no items of its own. A supervising attorney decides which kinds of count staff may propose and keeps the closure list for each court; anything the file leaves out stays uncounted. Map your docket, tracker and checklist exports to the column names once. Keep standing topics for the kinds of hearing you see most, add the words your attorneys never want in a pack, and decide who checks the cites and recounts the dates. The attorney confirms that the firm's policy and any protective order allow the material to be used in the AI product you have approved.

We sit with the paralegal who builds the packs and the attorneys who argue from them, on hearings they already know well, and set it up in ChatGPT, Claude, Copilot or Gemini. Your firm keeps control of how the work gets done.

What has been checked

Fully Powered AI wrote this workflow template, drawing on a published hearing preparation method credited in its sources, with that method's issue analysis, legal standards, examination questions and strategic assessment taken out. It was editorially reviewed on 11 November 2026. It has not been reviewed by a lawyer. It was tried on its invented example in Claude on 11 November 2026, the wording was tightened after an independent review, and it was then run again the same day on the template as it now stands, together with its deposition variant on invented inputs. The record of that run is published with the template. It has not yet been tested in a client environment. It has not yet been tested as a packaged version in ChatGPT, Claude, Copilot or Gemini.

Testing in your firm means running it on two or three past hearings your attorneys remember well, plus hard cases written in advance: a docket entry that moves the hearing, an order listed but not supplied, a count with a court closure inside it, a gap in the exhibit numbers, two declarations that disagree, and a request to say which argument is strongest. The paralegal checks every cite and recounts every proposed date before the pack goes to the attorney. Pilot acceptance-test preparation builds that test set, and what we test before we call an AI workflow ready describes the record we keep.

Who decides

People decide

Your people keep

  • The arguments, the legal standard and the order of proof
  • Every filing
  • Whether each proposed date is right
  • What is done about each open item
By design

It does not

  • Gives no legal advice
  • Decides nothing about legal meaning, merit, validity, privilege, conflicts or deadlines
  • Sends, files, signs and calendars nothing
  • Writes no argument, states no legal standard and makes no strategic assessment
  • Writes no examination questions, witness list or exhibit list for filing
  • Names no case, statute or rule from memory

Questions people ask

Who is it for?

A paralegal starts it once a hearing is set and the arguing attorney has asked for the pack. The arguing attorney reviews it, or the outside counsel who will argue the hearing where the company has no lawyer of its own.

What do I need to supply?

The attorney's request, the notice setting the hearing, the docket, the orders the attorney listed, each witness's prior statements, the exhibit tracker, the firm's own pre-hearing checklist and, if the firm keeps one, its deadline rule file.

What does it not do?

It gives no legal advice. It decides nothing about legal meaning, merit, validity, privilege, conflicts or deadlines. It sends, files, signs and calendars nothing. It writes no argument, states no legal standard and makes no strategic assessment.

What do I get?

One draft pack for the named attorney: the hearing, the procedural history, the orders, the witnesses, the exhibits, the checklist and the dates, with a line for the attorney to confirm each part, and an open-items list.

What has been checked?

It was editorially reviewed by Fully Powered AI. It was tried on its invented example in Claude on 11 November 2026, and run again the same day on the template as it now stands. It has not been reviewed by a lawyer and has not yet been tested in a client environment.

The full workflow template

Everything above is the outline. The complete workflow template is the working version: the roles, the inputs, the procedure, the exceptions and stop conditions, the output format, the reviewer checklist, the acceptance tests, the instructions for an AI assistant and what to customize for your company. It comes with a download and the link to its folder in Fully Powered’s public repository.

View the full template

Free with an account. Sign in by email: no password and no card.

Next step

Put this workflow template to work for your team: on your plan, or built with you in a sprint.

Put this on your plan

Add it to a workflow in the Fully Powered Planner, beside the teams and roles that will run it.

Build this in a sprint

In a sprint, Fully Powered adapts this workflow template to your rules, proves it on your own work and puts it in the hands of the roles that own it.

Two ways to begin:

Rather talk it through first? Book a fit callDiscuss adapting this