The Attorney-Ready Case File: A Standardized Fifteen-Part Case-Review Package

The fifteen parts#

Part 1 — One-page factual synopsis#

One page. Who the reader is (role: employee; former employee; clinician; patient; former detainee; family member; estate representative). What happened, in no more than ten dated sentences, each supportable. What the reader wants (to be reinstated; to be paid; to understand whether a death was preventable; to have a license reviewed; to know whether bankruptcy ended everything). No legal labels. No adjectives. The synopsis is the first thing the lawyer reads and the only thing some lawyers read before deciding whether to take the consultation.

Part 2 — Parties and entity chart#

The legacy Entity Identity Worksheet (historically numbered 101; current canonical destination held pending subject reconciliation), reduced to a one-page chart: every candidate employer, contractor, professional corporation, county, sheriff, facility, insurer, debtor and non-debtor, each with its exact legal name, its role as the documents assign it, the document that names it, and its bankruptcy status from the public notice (debtor with case number; non-debtor; unknown). Every individual by name, title, license and employer. The discrepancy log attached. Never "Wellpath" or "CFMG" alone; always the name on the document.

Part 3 — Chronology#

The legacy chronology worksheet (historically numbered 100; current canonical destination unverified), with the tag column (protected activity; adverse action; request for care; response; preservation events) and the records key for every row. Gaps and unknowns listed separately at the end.

Part 4 — Claim candidates#

A list, not an analysis, of the families of law the facts might engage, by Roadmap number and name, drawn from Guidebook 002.1's gateways and the action-forum matrix (legacy 096.1; canonical identity unverified), with for each: the one or two chronology rows that make it a candidate; the Roadmap that carries it; and whether it is an employment, wage, licensing, EDD, malpractice, death, constitutional, Government Claims Act, regulatory or bankruptcy matter. The word "candidate" is deliberate. The reader does not decide which are claims; counsel does.

Part 5 — Procedural prerequisites#

For each candidate: the prerequisite the Roadmap names (EEOC charge; CRD complaint; LWDA notice; § 364 notice; Government Claims Act claim; PLRA grievance exhaustion; ERISA plan appeal; none), whether it has been done, the date, the document, and where the document is. Drawn from source-verified action/forum subject guidance rather than an unverified numbered link, and the toolkits (125–131), whose titles and numbering must also be checked before hyperlinking.

Part 6 — Deadlines requiring counsel verification#

The five-component statement for each candidate, as the Roadmaps give it — source; period as the statute states it; trigger as the records show it; tolling provisions that may exist; certainty grade — with the trigger date from the chronology written next to it and no computed deadline. The heading is the instruction: these are deadlines for counsel to verify, and the package's job is to put the trigger dates and the sources in front of counsel at once. Flag any candidate whose trigger is more than a few months old in a way the lawyer cannot miss.

Part 7 — Evidence index#

The legacy exhibit index (historically Worksheet 113, not the newer identically numbered Government Claims Act worksheet), numbered once, each document with its date, author, source, records key, the chronology rows it proves, and whether the reader holds it, has requested it, or expects it only in discovery. Attach the documents the reader holds, in exhibit order, with a separator sheet for each. Attach nothing the reader is not authorized to possess. Maintain two inventories: (1) an authorized, disclosure-cleared consultation set and (2) a restricted existence-only index of records not lawfully held or not cleared for transfer. Do not copy third-party patient charts, inmate records, personnel data, or credentialing material into an intake folder merely because they might be relevant. Record custodian, lawful acquisition basis, disclosure restrictions, and counsel-review status; seek lawful discovery or consent where required. A legal subpoena is not itself blanket permission to circulate medical records. Where the HIPAA Privacy Rule governs a covered entity, a court order authorizes only the information expressly specified; a subpoena or other lawful process without an order generally requires qualifying patient-notice or qualified-protective-order safeguards under 45 C.F.R. § 164.512(e), with applicable minimum-necessary and other legal restrictions assessed separately. The litigation-intake author must not assume the covered-entity disclosure exception authorizes their personal acquisition or republication of protected information.

Part 8 — Witness index#

The legacy witnesses worksheet (historically 103; canonical destination held): each person, role, entity, the events they witnessed, what they personally saw or heard, contact information, and whether they are still employed or in custody. No characterization of what they will say.

Part 9 — Damages documentation#

The legacy damages and mitigation worksheet (historically 112; canonical destination held): economic losses by category with the documents; the mitigation record; the non-economic facts stated as facts (treatment sought; dates; providers — the reader's own information only). No totals the reader has not computed from documents; no estimate of what the case is "worth."

Part 10 — Agency history#

Every agency contact, from the legacy agency/court correspondence subject index (historically also attributed to Worksheet 113; conflicting labels require source verification): the EEOC, the CRD, the Labor Commissioner, EDD, Cal/OSHA, a licensing board, HHS OCR, the county's claims office, the BSCC, the Attorney General — each with the date, the document filed, the file or charge number, the agency's responses, the employer's or respondent's position statement if one was received (Roadmap 036), and the current status. Attach only filings and notices lawfully obtained and cleared for restricted counsel review. A document provided by an agency is not automatically unrestricted for redistribution; preserve any Section 83, FOIA, protective-order, trade-secret, health-information or other release restrictions. Keep the private counsel set separate from public-facing materials. A right-to-sue notice, a notice of determination, a claim rejection or an order, decision or award is the single most time-sensitive document in the package and should be the first attachment in this part.

Part 11 — Prior proceedings#

Every court case, arbitration, grievance, workers'-compensation claim, bankruptcy claim or proof of claim, or other proceeding involving the reader and any of the entities, with the case or claim number, the court or forum, the dates, the outcome or status, and the documents. Include proceedings the reader was not a party to but that concern the same facts (a coworker's case; a public inspection report), as public records, in a separate list.

Part 12 — Bankruptcy and entity complications#

From the separately preserved historical Chapter 11 and bankruptcy-stay/discharge Roadmaps 090 and 091 (not treated as collisions merely because omitted from a newer index), and the legacy entity-identity worksheet: for each entity in the chart that is a debtor, the case number, the petition date, the confirmation and effective dates, whether the reader filed a proof of claim and when, whether any claim arose before or after the petition and before or after the effective date, whether the reader received any notice (including an opt-out notice) and what the reader did with it, and the public docket entries the reader has located. For each non-debtor, the basis for believing it is one. For professional corporations and management entities, what the public record shows. No conclusion about what was discharged; the facts and the docket only.

Part 13 — Defenses likely to arise#

From the defense-playbook subject reference (historically 133; verify title before linking) and the toolkits' Part 13 sections: a list of the defenses the lawyer will expect to meet — wrong defendant; no employment relationship; limitations; failure to exhaust; arbitration; bankruptcy; legitimate reason; same decision; no disability; not qualified; no notice; undue hardship; direct threat; no protected activity; no causation; medical judgment; no deliberate indifference; no policy or custom; no state action; qualified immunity; no duty, breach or causation; expert failure; Government Claims Act; PLRA; privileges; workers' compensation exclusivity; mitigation; real party in interest — with, for each, the chronology rows and exhibits that bear on it. This part is not an assessment. It is a list of what to expect and where the relevant facts are, so that counsel can assess.

Part 14 — Documents still needed#

From the legacy preservation/records-distinction and records-request worksheet subjects (historically 114 and 104, respectively; canonical destinations unverified): what has been requested and not received; what is obtainable only in discovery; what preservation demands have been sent and to whom; what is privileged or belongs to others and must not be sought by the reader. The lawyer's first letters often come from this list.

Part 15 — Questions for counsel#

The reader's own questions, written plainly, in the reader's words: whether to file, where, against whom, whether the bankruptcy ended anything, what the reader should and should not do in the meantime, what it will cost, how long it will take, what the reader should expect from the employer or facility once a filing is made. The list tells the lawyer what the client cares about, which is information the rest of the package cannot carry.

Form of the package#

A single binder or a single electronic folder, in the order above, with a table of contents, a one-page cover sheet giving the reader's name, contact information, the date, and the roles and entities from Part 2 in one paragraph, and the exhibits in numbered order at the end. Black-and-white printable. No colored annotations, no highlighting that conveys an opinion. Every page numbered. Every document dated. Preserve unchanged source bytes and metadata separately from working copies; record SHA-256, acquisition time, source, collection method, sender/recipient headers where available, and any redaction log. Do not edit native emails or exported metadata merely to create a cleaner exhibit. Log replacements, duplicates, and chain-of-custody gaps as limitations rather than silently merging versions.

Intake confidentiality, privilege and source-integrity gate

A case file assembled before retention is not automatically attorney-client privileged or attorney work product. Existing underlying emails, payroll records, medical records and public filings do not become privileged merely by being placed in a folder for counsel. A genuine prospective-client consultation can trigger confidentiality protections before formal retention, but the scope depends on the communication, applicable California law, reasonable expectations, recipients and waivers; a public website or indiscriminate distribution does not create a confidential legal consultation. Keep a minimal conflicts-check synopsis separate from a restricted substantive package, and transmit sensitive exhibits only through an agreed secure channel after counsel confirms intake procedures. California-specific privilege conclusions require counsel verification.

The custodian must distinguish preservation from acquisition. Preserve legitimately held originals, avoid deleting or altering relevant data, and seek prompt attorney guidance on any litigation hold. Do not access another person's account, bypass employer credentials, export a restricted clinical system, or obtain patient, inmate, personnel, peer-review or trade-secret records through unauthorized means. Where potentially relevant material is in someone else's custody, index its existence and possible custodian without copying it. Federal Rule of Civil Procedure 37(e) governs specified remedies for lost ESI in federal litigation; it does not independently create a general duty to preserve, and adverse-inference sanctions require particular findings including intent to deprive. Different state-law rules may apply.

Minimum provenance columns: exhibit ID; original filename/format; source custodian; acquisition authority and date; originating record date; hash of original bytes; complete/partial status; metadata/headers status; transformations and redactions; confidentiality tier; release permission; fact asserted; alternative interpretation; authentication witness; retention location; and legal review status. The public version should ordinarily contain none of the confidential source files.

Adverse-evidence test: counsel should see the strongest contemporaneous records contrary to the preferred position; distinguish the record's authenticity from the truth of assertions within it, identify missing context and witnesses, and flag claims dependent on speculation. For each adverse document, record the best plausible defense interpretation and the specific evidence that could resolve it.

What the package is not#

It is not a demand letter, a complaint, a charge, a claim, a board complaint, or a regulatory report, and it should not be sent to any of the entities or agencies it describes. It is not an assessment of the matter's strength, and it should not contain one. It is not a substitute for the lawyer's own intake. It is a package that lets the lawyer do the lawyer's work.

Why this may matter in a CFMG/Wellpath setting#

A lawyer receiving a matter involving a correctional health-care contractor in California faces, before anything else, the entity and bankruptcy questions that Parts 2 and 12 answer from the public record: which of the many related entities is involved, whether it was one of the 39 debtors, whether the claim arose before or after November 11, 2024 and before or after May 9, 2025, and whether a county or a non-debtor professional corporation stands behind the facts (Roadmaps 090, 091). A package that answers those questions on its first two pages saves the consultation. Nothing here states that any entity did anything.

Related roadmaps#

001.1, 002.1, 006, 007, 008, 009, 036, 090, 091, 094, 096.1, 100–114, 125–133.

Supplement: source integrity, referral readiness, and the fifteen-part attorney-review file#

October 11, 2026 internal expansion for 009.1. This is a general educational guide to organizing information for independent legal counsel. It is not an individualized filing package, a solicitation for case documents, or a recommendation of litigation strategy.

What an organized record can and cannot accomplish

An attorney-review package cannot create standing, cure a missed deadline, manufacture missing proof, or turn a grievance into a lawsuit. Its purpose is narrower: to reduce the work required for a professional to understand the sequence of events, distinguish the named legal persons, spot potentially relevant procedural processes and identify missing source records. A package organized around confirmed facts can be useful even when the ultimate legal conclusion is unfavorable. A package written as a closing argument before facts are checked can be counterproductive because the reader must first undo its assumptions.

The most useful distinction is between a factual index and a legal assessment. The factual index records dates, participants, documents and statuses. The legal assessment requires expertise about jurisdiction, law, defenses, deadlines and remedy. A public guide should teach construction of the former while explaining why the latter remains counsel's responsibility. A person can prepare a factual table without deciding whether an action amounted to discrimination, constitutional indifference or breach of a contract.

The synopsis: compress the story without losing its uncertainty

The first section should state who was involved, where an event occurred, its approximate sequence, the most important contemporaneous records and the outcome being questioned. A sound synopsis uses source labels: “Contract document names Entity A,” “agency correspondence says a notice was received,” and “the complaint alleges a different employer.” This prevents contradictory names from being silently reconciled by the writer. It also avoids claiming a judicial finding where the source is merely an allegation. If the writer does not know which of two events occurred first, the synopsis should indicate the ambiguity instead of imposing a polished chronology.

For a complex correctional-healthcare matter, a synopsis may identify a facility, custody status at the relevant time, the broad clinical issue and the institutions appearing in public records. But an online project should not solicit an individual's health information or incident narrative. The guide can describe a standard for what a person might privately discuss with retained counsel; it should not create an intake mechanism at KPSGILL.com.

Legal entities: use a two-column identity standard

A single organization can appear under its legal registered name, assumed business name, national enterprise brand, benefits administrator and contract title. The file should preserve the exact name on each source and separately record any verified relationship. An affiliation that appears obvious in marketing materials may have a narrower or different legal meaning in a contract or public registry. Employer identity may turn on payroll arrangements, agreements, control or statutory definitions; debtor identity may depend on named bankruptcy petitions and schedules. Those questions are not interchangeable.

A useful factual column says, for example, “The letterhead names Company A” or “the county agenda recommends an amendment with Corporation B.” A second column says “relationship to other entities established by” and cites the actual public instrument, if one exists. If the relationship has not been proven, mark it unresolved. Do not write “Company A was the real employer” as though the label itself settles a contested legal conclusion.

Chronology: chronology must tolerate contradictions

An effective event chronology includes the date as recorded, source of the date, event description, participants, record location, whether the information is firsthand or reported by another person, and discrepancies. Some events have several timestamps: when an email was composed, when it was sent, when a portal marked it received, when a letter was dated and when it was delivered. Those timestamps can matter differently. The chronological table should not silently prefer the time most favorable to a narrative. Use separate rows or columns where the clocks differ and label any timezone or system-clock uncertainty.

Corrections also need provenance. A revised personnel form may supersede an old one without erasing the old form's historical significance. A corrected medical record may preserve an audit trail. A subsequent agency status letter may close an investigation without deciding the truth of the original allegations. Keep the supersession date and reason where available, rather than overwriting the earlier entry.

Potential claim categories without conclusions

A reader may hear terms such as wage claim, discrimination charge, malpractice, §1983 action, government claim and bankruptcy proof of claim and treat them as interchangeable routes. They are not. The file may identify a category of legal question to ask counsel, but it should not decide whether the category applies to any particular facts. A labor-agency retaliation process may have distinct jurisdiction from a California FEHA investigation. A licensing board's investigative process does not award private civil damages. A county claim-presentation process generally serves a different function from federal civil-rights litigation. A bankruptcy process can affect a debtor claim without deciding every possible proceeding involving affiliated nondebtors.

The best organizing technique is to preserve separate folders for each process and keep shared underlying factual records indexed once by an evidence ID. This avoids altering one chronological fact in one folder while leaving inconsistent copies elsewhere. The file can also note the kind of remedy each institution generally has legal power to supply, without recommending which forum an individual should choose.

Deadlines and procedural prerequisites: disclose uncertainty

A general guide should encourage identifying the source of each relevant time limit, what event may trigger it and what exceptions or tolling doctrines may be involved. It should never calculate a deadline from a reader's dates or state that a particular period remains open. An agency's acknowledgment may not equal a perfected charge, and a right-to-sue notice may start a distinct clock. A California public-entity notice requirement for covered state-law damages causes may coexist with federal-law claims governed by different rules. The bankruptcy court may have specified orders, claim types and notice requirements. An individualized answer belongs to counsel reviewing the primary documents.

A deadline index can contain an agency or court's name, the relevant form or notice, recorded date, receipt evidence, cited statutory source, unresolved exceptions and a prominent request for counsel verification. It should preserve adverse interpretations. If the same event could be characterized as a discrete employment action or part of a broader sequence, the file should note the disagreement without silently choosing the interpretation that produces a later date.

Evidence index: source identity is not evidentiary truth

For each document, record a neutral file identifier, source category, document date, acquisition route, custodian if known, substantive issue, whether it is complete and any version conflicts. “Email obtained from a personal inbox” is a provenance statement; it does not automatically prove that the recipient read its content. “Report attached to a complaint” means the report was filed; its factual statements may still be contested. “County agreement approved” establishes the governmental act and the text adopted; it does not prove every operational representation subsequently occurred. Evidence categories preserve the difference between authenticity, procedural fact and truth of disputed propositions.

Where an electronic file will be reviewed, a checksum can assist with version integrity. A checksum does not authenticate who created a document or whether its content is accurate; it only helps show that a particular byte sequence has not changed between recorded copies. The index should therefore combine the file's original source location and acquisition description with a stable identifier, not rely on the hash as self-validating evidence.

Witnesses: knowledge, role and lawful contact

A witness index is not a recruitment list. It should distinguish what a witness directly perceived, what the witness learned from another person, the role the witness held and which contemporaneous sources might corroborate the recollection. The presence of a person's name in a document does not establish consent to be contacted. Former employees, healthcare professionals and incarcerated individuals may face confidentiality, professional or anti-retaliation constraints. A public website should not invite them to transmit nonpublic records or narratives to its author. Counsel should direct any lawful investigation or contact appropriate to a pending matter.

Harms and remedies: bookkeeping without predictions

A damages section can record documents relating to earnings, medical costs, leave dates, lost benefits, invoices, insurance reimbursements, mortality records and other objectively measurable categories when relevant. It should not predict settlement value or assert legal recoverability. Insurance payments, offsets, mitigation, wage replacement and benefit plans may affect particular categories differently. A document showing an expense occurred is not proof that a defendant legally owes it. A record of distress can be important but is not converted into a dollar award by putting it in a spreadsheet.

Similarly, a personal-injury, employment or wrongful-death outcome may involve different plaintiffs, damages rules and procedural prerequisites. A single summary total can mislead where amounts refer to different people, periods or legal capacities. Keep the accounting as a factual record for counsel and avoid presenting a prospective recovery amount as established.

Agency and case history: outcomes must be classified

A complete package should distinguish an inquiry, intake, administrative charge, investigation, accusation, agency finding, settlement and final adjudication. An agency may close a file without resolving whether the underlying account is true. A court may deny a motion to dismiss while expressly assuming allegations true. A remand order may select the proper forum without deciding the merits. A settlement usually is not an admission of liability. The case-history section should record the procedural nature and date of each development and cite the signed order or official source whenever possible.

The reader should also distinguish pleadings from orders. A party's motion is a request for judicial action and a statement of the party's position. The court's order shows what the court decided. Unfiled correspondence, settlement communications and privileged attorney advice may require handling restrictions and generally do not belong in a public website archive.

Bankruptcy and professional-corporation overlays

An entity map becomes especially important where a corporate group has undertaken Chapter 11 proceedings while affiliated or related actors continued operating. The package should separate the particular debtor, the nondebtor professional corporation, the management organization, insurance entities, covered claim class, petition date, confirmation order, plan effective date and any post-confirmation order relevant to the legal question. A brand's presence in a plan narrative does not make every associated legal person a debtor. Conversely, a party's formal separateness is not a substitute for analyzing the actual order applicable to an asserted claim.

The educational package may state these distinctions generally, but no public template should tell a reader that a particular claim was discharged, preserved, stayed, released or payable by a trust. Those conclusions often depend on the precise debtor, timing, notice and plan provisions. Such a determination must remain counsel's responsibility.

Strong contrary facts and gaps in the record

Every case-review file benefits from a table of the best evidence inconsistent with the preferred account. This is not a rhetorical concession; it saves counsel from building a theory on incomplete information. A written accommodation offered by an employer, a contemporaneous refusal of care, a signed medical assessment, a documented deadline notice or an independent cause of an injury may materially change the analysis. The table should distinguish genuine contrary facts from the opposing party's unproved allegations. Where a document could support multiple interpretations, record both and identify what would resolve the conflict.

A missing-document list should assign no inference of suppression merely because an item has not been obtained. The record may be missing because it was never created, is held by another custodian, was lawfully destroyed under a retention policy, or has not yet been requested. Note the potential custodian and lawful access route; do not encourage misappropriation of confidential employer or patient records.

The final attorney consultation question set

Instead of a speculative legal conclusion, the concluding section can present a neutral list of questions for independent counsel: Which entity is legally relevant to each event? Which forums have jurisdiction over distinct subjects? Which actions require administrative exhaustion or claim presentation? What evidence is needed to substantiate a disputed fact? What sources cannot lawfully be disclosed? Which deadlines require immediate independent review? Which alternative explanation has the strongest factual support? How does bankruptcy affect only those claims and parties actually subject to an identified order? What additional fact would change the preliminary assessment?

That question set is useful precisely because it does not answer the questions. It makes the eventual consultation more efficient while preserving the attorney's role in interpreting law and assuming professional responsibility for advice. A print-ready case-file guide can teach indexing and source honesty without becoming a bespoke legal-document service or a data-collection mechanism.

Publication limits

This is general legal information. It does not advise a particular filing, defendant selection, remedy, deadline or strategy. No examples derive from the author's nonpublic matters or patient care. The site does not receive completed review files. Where a hypothetical is used, it is invented and should be distinguishable from any real individual event.

What this page cannot do#

It cannot evaluate a matter, identify a defendant, compute a deadline, or decide whether any claim is viable. It specifies a package; counsel does the rest.