Statement of Undisputed Material Facts (MSJ) Builder
Turn the record into a numbered Statement of Undisputed Material Facts for summary judgment — each fact a single sentence tied to a cite, with the genuinely disputed ones pulled out.
Worked example · Synthetic fictional details
Sample prompt
Synthetic example: The names, dates, case details, and issues below are fictional CasePrompts sample values, not client data or evidence from a real matter. They demonstrate the prompt format, not the accuracy of any AI model's output.
Preview the complete sample prompt
CONTEXT: You are a litigation support analyst assisting defense counsel in a premises liability matter in Sixth Judicial Circuit, Florida. defense counsel is preparing a motion for summary judgment against the plaintiff. The attached materials are the record excerpts assembled for that motion. The issues the motion turns on are: actual or constructive notice of the spill; time on the floor; inspection interval. INSTRUCTIONS: Working only from the attached record, draft a Statement of Undisputed Material Facts. 1. State each fact as a single, self-contained declarative sentence — material to actual or constructive notice of the spill; time on the floor; inspection interval, and supported by a specific record cite. 2. Number the facts sequentially in a logical order, chronological or by issue. 3. Include no argument, characterization, or legal conclusion — only what the record establishes. 4. Separate any fact the record shows is genuinely DISPUTED (conflicting testimony or documents) from the undisputed set; a disputed fact cannot anchor summary judgment. 5. Note the material facts you will need but the record does not yet support, so they can be shored up before filing. TEMPLATE — format your output exactly as follows: Produce three sections. ## Undisputed Material Facts | # | Undisputed material fact (one sentence) | Record cite | Issue it supports | |---|---|---|---| ## Facts that appear disputed — do NOT place in the SUMF | Proposed fact | Cite A | Conflicting cite B | Nature of the conflict | |---|---|---|---| ## Gaps — material facts not yet supported by the record A short list, each with the issue it goes to and where the support would have to come from. EVIDENCE REQUIREMENTS: For every finding, identify the source document by name and cite page:line for transcripts, timestamps for audio/video, and Bates/page for documents. Every fact in the undisputed table must carry a specific cite; if a proposed fact is not supported, place it under Gaps rather than stating it — write "not found in the record." Do not merge two facts into one numbered statement, and do not soften a genuine dispute into an undisputed fact. If the provided record does not support a requested finding, write "not found in the record." Do not infer or fill gaps from outside knowledge. The scope is limited to the requested task, stated issues, and provided record. Do not introduce outside subjects or sources. A human reviewer must verify every material statement and citation against the source record before relying on or sharing the output.
Through the Civil / insurance defense lens
Maintain a neutral, evaluative tone appropriate for carrier reporting; keep established facts and the plaintiff's contentions visibly separate throughout.
Through the Commercial litigation lens
Tie every factual premise to a document with a Bates cite; recollection unsupported by the record gets flagged, not adopted.
Through the Criminal defense lens
Build examination sequences that commit witnesses to specifics before any confrontation, and never embed a factual premise the discovery does not contain.
Through the Employment litigation lens
Build examination sequences that commit decision-makers to the reasons and the timing before any confrontation with the documents.
Through the Family law lens
Keep the tone measured and factual; inflammatory framing reliably backfires in family court, and specificity does the persuading.
Through the Medical malpractice — defense lens
Keep established chart facts and the plaintiff's allegations visibly separate, and let the contemporaneous documentation carry the persuasion.
Through the Medical malpractice — plaintiff lens
Write toward the causation chain — each clinical decision linked to its consequence — with provider language quoted verbatim and no medical conclusions the record does not state.
Through the Personal injury — plaintiff lens
Write toward a coherent narrative of fault and harm; specificity about the client's documented losses carries the persuasion — never adjectives.
Through the Probate & estate litigation lens
Keep it factual and element-driven; probate courts reward precision over heat, and a clean record cite persuades where adjectives do not.
Through the Prosecution lens
Build examinations that establish elements through specifics and anticipate the defense themes the record itself suggests.
Through the Workers' compensation — claimant lens
Write toward the statutory touchpoints — notice, causal connection, restrictions, wage loss — with provider and employer language quoted verbatim.
Through the Workers' compensation — employer/carrier lens
Maintain a neutral, evaluative tone appropriate for carrier reporting, keeping established facts and the claimant's contentions visibly separate.
AI output is a starting point, not work product. Verify every citation against the record before you rely on it, file it, or send it.
What you'll fill in
- 01Your role
- 02Case typee.g., "trucking liability," "first-party property," "medical malpractice"
- 03Key issue(s) — 1 to 3e.g., "vehicle speed at impact; brake maintenance; visibility"
- 04Opposing party(optional)
- 05Jurisdiction(optional)e.g., "Sixth Judicial Circuit, Florida"
Pro tip Draft the SUMF before you draft the brief — the Gaps section tells you what discovery or affidavits you still need while there's still time to get them.
Record-first path
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