Plaintiff's Opening Statement Outline for a Personal Injury Trial, Tied to the Evidence
Builds a plaintiff's opening statement outline only from evidence you list as admissible and expected, with a table mapping every statement to the witness or exhibit that will prove it and a list of statements removed for lack of proof.
The Prompt
Variables (8)
| Variable | Description | Example |
|---|---|---|
| {{court_and_jurisdiction}} | Court and Jurisdiction | District Court, Clark County, Nevada (state court), jury trial |
| {{governing_rules_and_rulings}} | Governing Rules and Pretrial Rulings | Order on motions in limine dated 02/20/2026: no reference to defendant's traffic citation; plaintiff's 2017 wrist claim excluded. Trial order: 30 minutes per side; exhibits may be shown in opening only if stipulated. |
| {{plaintiff_name}} | Plaintiff Name | Maria Gonzalez |
| {{defendant_name}} | Defendant Name | Sunline Logistics LLC and Daniel Reyes |
| {{time_allotted}} | Time Allotted (Minutes) | 30 |
| {{theme_ideas}} | Theme Ideas | A driver looking at a scanner instead of the road. Open to alternatives. |
| {{admissible_evidence_list}} | Admissible Evidence List | Witness T. Alvarez (deposition 11/14/2025, 22:4-9): "the van never slowed down." Witness D. Reyes (deposition 01/22/2026, 47:2): "I looked down at the scanner." Exhibit 12, telematics report: speed at impact as recorded. Dr. Chen, treating surgeon: C5-C6 fusion on 09/18/2025. |
| {{damages_evidence}} | Damages Evidence | Exhibit 20, medical bills summary: $101,670.00 billed. Exhibit 22, employer letter: 6 weeks at $1,150.00 per week. Plaintiff and spouse will testify to daily limitations. |
Expected Output
Two parts. Part 1, attorney-only notes: (A) a proof register of the evidence you listed; (B) evidence excluded by a supplied ruling; (C) conflicts between sources; (D) recomputed damages figures; (E) three candidate themes, a recommendation and the themes dropped; (F) a proof table mapping every spoken statement to its witness or exhibit; (G) unsupported statements declined, with the evidence needed to restore each; (H) declined requests; (I) time allocation; (J) missing information. Part 2, the opening outline as counsel will speak it (theme, story, witness preview, liability, damages, request to the jury), with no notes, flags or mention of excluded evidence. A verification list closes the output.
Usage Notes
Use after rulings on motions in limine, when the witness and exhibit lists are final. List only evidence you expect to be admitted, with its source, and paste the rulings, the standard of care instruction and the time limits that apply. Evidence a pasted ruling excludes is kept out of the spoken outline entirely, and no dollar figure is spoken unless a pasted rule allows it. Failure mode to watch for: a strong line with no proof behind it, especially a causal link ("as a result of the crash") that no listed witness states; anything under "Unsupported statements declined" stays out unless you add the supporting evidence, and a promise the evidence does not keep will be used against you in closing. The federal rule listed is a reference point and does not govern a state-court trial. 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.
Legal Sources Referenced
- Fed. R. Evid. 103(d) (to the extent practicable, the court must conduct a jury trial so that inadmissible evidence is not suggested to the jury by any means)
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.