Claude Prompt: Plaintiff's Mediation Statement for a Personal Injury Case
Drafts the plaintiff's mediation statement: liability in evidence order, damages with documented totals and visible arithmetic, the defense's best arguments answered from the record, and a separate confidential section for the mediator.
The Prompt
Variables (9)
| Variable | Description | Example |
|---|---|---|
| {{court_and_posture}} | Court and Procedural Posture | Superior Court of Fulton County, Georgia (state court); discovery closed, trial set for 03/09/2026, mediation ordered |
| {{mediator_name}} | Mediator Name | Hon. Patricia Lowell (Ret.) |
| {{governing_law_supplied}} | Governing Law Supplied by Attorney | Fault allocation, collateral source and mediation confidentiality rules pasted below as verified by counsel on 01/05/2026. No damages cap applies to this claim per counsel's research memo. |
| {{current_demand_amount}} | Current Demand Amount (USD) | 425000 |
| {{liability_evidence}} | Liability Evidence | Crash report 24-118733, p. 2: "Unit 1 failed to stop for red signal." Alvarez deposition 11/14/2025, 22:4-9: "the van never slowed down." Reyes deposition 01/22/2026, 47:2: "I looked down at the scanner." |
| {{damages_documentation}} | Damages Documentation | Banner Health ER 03/14/2025: billed $8,420.00, paid by insurer $3,115.40. Spine surgery center 09/18/2025: billed $86,300.00. Employer letter 05/01/2025: 6 weeks at $1,150.00 per week. |
| {{defense_positions}} | Defense Positions | Defense IME report 11/20/2025, p. 9: "The cervical findings are degenerative and pre-existed the collision." Adjuster letter 12/02/2025: plaintiff was speeding; gap in treatment May to July 2025. |
| {{settlement_history}} | Settlement History | 08/04/2025 demand $500,000; 09/15/2025 offer $60,000; 10/20/2025 demand $425,000; 12/02/2025 offer $85,000. |
| {{confidential_notes}} | Confidential Notes for the Mediator | Client wants resolution before trial for family reasons. Health plan lien asserted at $41,220.18, reduction request pending. Concern: prior neck complaint in a 2019 chiropractic record. |
Expected Output
An analysis block with the cross-check, the arithmetic and the sorting, then two parts. Part 1, attorney-only notes: (A) conflicts between sources, including conflicts inside plaintiff's own evidence; (B) the medical ledger columns added as supplied, wage loss and settlement moves recomputed, with every difference from a stated total; (C) unsupported statements declined; (D) declined requests; (E) placement decisions and items withheld from both documents; (F) missing information. Part 2, two clean documents: the shared statement (liability, injuries and treatment, damages, defense arguments answered, settlement history, demand) and the confidential memorandum for the mediator. A verification list closes the output.
Usage Notes
Use one to two weeks before mediation, once the records, bills, key testimony and the defense report are collected. Paste the governing rules you have verified, including the confidentiality rules of your mediation. The shared statement is written as a finished outgoing document: your internal notes, addition errors and unanswered points stay in Part 1 or in the mediator memorandum. Failure modes to watch for: a confidential fact leaking into the shared statement, and two of your own exhibits that contradict each other being cited together; read the conflicts section first, then the shared statement against your confidential notes line by line. The ledger columns are copied and added as you supply them, never derived from one another, and a defense argument resting on a cited case is left for you to answer. The prompt reports your demand and never proposes a settlement value. The federal rule listed is a reference point and does not govern a state-court mediation. Read the document part line by line before it leaves the office: in testing, a small model sometimes left an internal remark, a comparison with the file or an unresolved point inside the document despite the instructions. Not legal advice. The attorney remains responsible for verifying every fact, figure and authority before use.
Double-check before use
- Check that nothing marked do-not-disclose appears in either document.
- Check that every figure is copied from your ledger, not derived from other columns.
These are the places where this prompt was seen to slip when tested on sample cases with a small AI model.
Legal Sources Referenced
- Fed. R. Evid. 408 (offers to compromise and conduct or statements made during compromise negotiations are not admissible to prove or disprove the validity or amount of a disputed claim, but may be admitted for another purpose such as proving a witness's bias or prejudice)
Originally featured in: AI for Personal Injury Lawyers: Prompts for Demand Letters, Medical Summaries & Depositions
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* These prompts are drafting and analysis aids for licensed attorneys. They are not legal advice and do not replace professional judgment. AI output can contain errors, including invented citations and incorrect deadlines: verify every fact, figure, authority and deadline against primary sources before relying on it. Rules vary by jurisdiction, and you remain responsible for the final work product.