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Family Law Mediation Preparation Memo: Issues, Figures and Packages

Builds the internal mediation preparation memo: an issues list, your client's priorities and limits as you give them, the other side's positions with sources, figures reconciled against the documents, package proposals built only from your ranges, and questions to settle with the client.

The Prompt

Variables (9)

VariableDescriptionExample
{{client_name}}Client NameGrace Okafor
{{client_role}}Client RoleRespondent
{{session_date}}Session Date2026-11-10
{{issues}}Issues in DisputeI1 Parenting schedule for two children. I2 Child support. I3 Division of the marital home. I4 Division of the retirement accounts. I5 Fees.
{{priorities}}Client Priorities and LimitsMost important: school-night residence with the client. Will not accept a sale of the home before the youngest finishes school. Open on support.
{{ranges}}Attorney-Supplied RangesI2 support: target $1,850 per month, floor $1,500, ceiling $2,200 (attorney figures). I5 fees: each side bears own. No range for I3 or I4.
{{other_side}}Other Side PositionsLetter from opposing counsel 2026-09-30: "Our client proposes support of $1,100 per month and a sale of the home within 12 months."
{{documents}}Financial DocumentsHer pay stub: $3,900 gross per month. His pay stub: $8,200 gross per month. Mortgage statement: balance $201,000. Home appraisal dated 2026-06-01: $395,000.
{{governing_text}}Governing TextNone pasted.

Expected Output

A memo with: safety flags, conflicts between sources, issues list, client priorities and limits, the other side's stated positions with source, arithmetic reconciled against the financial documents, package proposals showing the supplied range behind every figure, questions to settle with the client, unsupported statements declined, declined requests, missing information. Ends with a Verification list that does not restate private limits.

Usage Notes

Use the week before a mediation session. Paste your client's priorities and limits, the other side's written positions and the financial documents, plus the ranges you are authorized to work within. Packages use only your ranges: if you give none for an issue, it is marked for you to supply, not guessed. The memo is internal; keep it out of any shared folder or the mediator's hands. Watch for the model estimating what a court would do: it is instructed not to. Not legal advice. The attorney remains responsible for verifying every fact, figure and authority before use.

Double-check before use

These are the places where this prompt was seen to slip when tested on sample cases with a small AI model.

Originally featured in: Prompt Engineering for Lawyers: The Complete 2026 Guide

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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.