Case Chronology

# Case Chronology

Builds a master, sourced chronology for a civil or business litigation matter, with a key-facts summary on top, for use in case assessment, discovery, depositions, motions, mediation and trial.

## What to ask for
- Pleadings (complaint, answer, cross-claims), key documents and productions (with Bates numbers), emails and texts, deposition transcripts, declarations, discovery responses, expert reports, and any existing chronology to update.
- The claims and defenses (or the pleading), and which side the firm represents.
- Key people (parties, employees, witnesses) and their roles, if known.
- Any focus: a claim element, a time window, a witness, or a specific issue (notice, knowledge, damages, limitations).
- If something is missing, build from what's given and mark gaps as [MISSING: ...]. Never fill a date by assumption.

## How to work
1. **Cast of characters.** Every person and entity: name, role, affiliation, and when they enter the story. Note aliases, initials and email addresses so entries can be matched.
2. **Extract events.** One row per event: what happened, who, when. Pull from every source. Keep the source's words for key statements (short quotes in quotation marks).
3. **Source every row.** Document name or Bates number and page; transcript as Witness Dep. page:line; pleading as document and paragraph. No source, no row (put it in "Unsourced assertions").
4. **Dates.** Use exact dates (YYYY-MM-DD). For approximate dates, give the range and say "approx." Sort by date; undated items go at the end. Where sources give different dates for one event, keep one row and list both in Disputed?.
5. **Significance.** One short line tying the event to a claim element, defense, credibility, damages, notice or knowledge, limitations, or a pending motion. Leave blank rather than stretch.
6. **Disputed?** Yes/No, and if yes, who disputes it and the contrary source (e.g. "Yes: Smith Dep. 45:3-12 says meeting was in May"). Mark what's admitted in the pleadings.
7. **Key-facts summary.** The 8-15 facts that matter most, each with its cite, written so a reader who sees nothing else understands the case.
8. **Gaps.** Periods with no documents, events referenced but not documented, witnesses not yet deposed, documents to request.

## Output

**Case Chronology: [Case caption]**  Case no. [ ]  Representing: [ ]  Current through: [date / sources reviewed]

1. **Key facts** (numbered, 8-15, each with cite)
2. **Cast of characters** table: Name | Role / affiliation | Notes
3. **Master chronology** table: Date | Event | Source (doc / Bates / page) | Significance | Disputed?
4. **Date unknown** table (same columns)
5. **Unsourced assertions** (bullets: what, who asserts it, what would prove it)
6. **Gaps and follow-up** (numbered: documents to request, witnesses to ask, facts to confirm)
7. **To verify** (e.g. limitations periods tied to dates in the chronology, discovery cutoffs, trial-related deadlines)

## Rules
- Draft for attorney review; attorney work product. Mark it "Privileged and Confidential, Attorney Work Product".
- Limitations periods, discovery cutoffs and court deadlines vary by jurisdiction and change: list them under "To verify", never state them as final.
- Never invent facts, dates, amounts, case law or citations. Unknown = [MISSING].
- Describe events neutrally in the Event column; put advocacy only in Significance.
- Don't merge two sources into one fact unless both say the same thing; cite both.
- When updating an existing chronology, mark new rows "(new)" and keep existing source cites intact.